HomeMy WebLinkAbout24001 REEP LRC II Decision Memo 202305041
REEP-LRC II/24001-19-060/20220914
DECISION MEMORANDUM
DATE: May 20, 2023
FROM: Bill Schmithorst
TO: BF Assessment File
RE: REEP-LRC II
1900 and 1942 Continental Boulevard and unnamed
Property East of I-485
Charlotte, Mecklenburg County
BF # 24001-19-060
Based on the following information, it has been determined that the above referenced
site, whose intended use is for no uses other than industrial, office, warehousing, parking,
and with DEQ’s prior written approval, other commercial uses, can be made suitable for
such uses.
Introduction:
The Prospective Developer is SPWF-Continental Warehouse, LLC a limited liability
company headquartered at 768 North Bethlehem Pike, Suite 203, Lower Gwynedd,
Pennsylvania 19002. The site consists of two parcels of land totaling 84.664 acres and
located at 1900 and 1942 Continental Boulevard (Mecklenburg County Parcel
Identification Number (PIN) 20308301, 68.78 acres), and a densely wooded parcel east
of Interstate I-485 with no established address (PIN 20302139, 15.884 acres) The
property located at 1900 and 1942 Continental Blvd. is developed with a 1,390,885
square foot warehouse. Current onsite operations include office and warehousing uses.
Properties immediately surrounding the Brownfields Property consist of Pioneer Avenue,
wooded area, two warehouse buildings with multiple tenants to the north; warehouse
buildings to the south; Duke Energy Sub-Station, Interstate 485, Sugar Creek, Coffey
Creek, Commercial/Industrial office buildings, and wooded area to the east; and
Continental Boulevard, Credit Union, Univar USA, Sam’s Club distribution Center, and
Piedmont Distribution Center to the west.
Redevelopment Plans:
The Prospective Developer intends to improve the property with additional warehouse
space.
Site History:
The Brownfields property and surrounding area was formerly occupied by the United
States Navy from approximately 1949 through 1967 as a U.S. Naval Ammunitions Depot
(NAD). The NAD operations consisted of numerous buildings surrounded by protective
soil berms. Following NAD operations, the Brownfields Property was occupied and
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developed by Continental Tire and used for tire manufacturing from 1967 through 2006;
however, the plant continued to produce in-process materials and apply puncture sealant
to a limited quantity of tires manufactured elsewhere until late 2008, when these
operations were also terminated. In late 2008, the Brownfields Property to Patriot
Equities. Decommissioning activities to remove tire manufacturing equipment, storage
vessels, ASTs, and associated piping, and an onsite wastewater treatment facility were
performed from late 2008 through December 31, 2009. After decommissioning, the
existing warehouse building was leased to various tenants for warehousing and
distribution. The Prospective Developer Purchased the Property in December 2019.
Warehouse Property
The existing warehouse building located on PIN 20308301 is currently divided into eight
tenant spaces and is used for warehousing and distribution. Tenants include the
following:
Suites A, G, and H – Spirit Halloween
Suite B – Professional Builders Supply
Suite C – Harris Tire
Suite D – Darnell
Suites E and F – Synders Lance
Suite I – United States Postal Service (USPS)
Suite J – Siemens/ Deufol Charlotte, LLC
Suite K – SnapAV
No underground storage tanks (USTs) or above ground storage tanks remain in service at
the property.
Multiple phases of environmental assessments have been conducted at the Brownfields
property since 2007. The assessments were conducted under the purview of the DEQ
Underground Storage Tank (UST) Section, Inactive Hazardous Sites Branch (IHSB), and
the Brownfields Program. Known releases associated with PINs 20308301 include the
former Wash Rack area (UST Section No Further Action status in June 2010), the former
Boiler Day Tanks area (UST Section No Further Action status in June 2010), the former
Naphtha UST area (UST Section Conditional No Further Action status and Notice of
Residual Petroleum filed in 2003), the former Rail Off-Loading Area (UST Section
Conditional No Further Action status in January 2020), the former Buffing Dust Shed
(active IHSB incident). Brief summaries of these incidents and historical activities at
parcel PIN 20302139 are provided below.
Wash Rack Area
Petroleum contaminated soil was detected in the former wash rack area. Approximately
450 cubic yards of soil was excavated from the area in October 2009 and disposed of at
an offsite location. An assessment report was submitted to the DEQ in December 2009
indicating that no compounds were detected in soil above action levels (DEQ UST
Incident #91071). The DEQ issued a No Further Action Letter for the incident on June
24, 2010.
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Rail Off-Loading Area
In 2009, above ground storage tanks were decommissioned and demolished, along with
buildings to the south and west of the Rail Off-Loading Area (DEQ UST Incident
#91073), where chemical and cement mixing were historically performed. During
decommissioning activities, petroleum product was observed beneath the above ground
storage tanks (ASTs) located in the Rail Off-Loading Area. In accordance with applicable
NCDEQ UST Section guidance, environmental assessment and removal actions were
completed in 2008 and 2009.
In June 2009, approximately 6,992 tons of impacted soil was removed from beneath the
former process oil ASTs at the Rail Off-Loading Area. Additional removal was
performed in previously inaccessible areas beneath the facility’s mixing building and
cement house, to coincide with planned demolition activities in September 2009 and
January 2010. The final combined excavation volume was estimated at approximately
3,000 cubic yards. A No Further Action Letter was issued on April 24, 2020.
Boiler Day Tanks
Initial assessment activities at two 30,000-gallon boiler day tanks indicated elevated
concentrations of TPH O&G (DEQ UST Incident #91072). After additional assessment
was completed in December 2009, an NFA was issued for this incident from the
NCDENR on June 24, 2010.
Naphtha UST
In 1987, a naphtha UST release was discovered at the manufacturing building (DEQ UST
Incident #3399). Remediation activities conducted included soil removal, product
recovery, soil vapor extraction, and groundwater pump and treat. NCDEQ issued a “No
Further Action” for the naptha incident, contingent upon filing a “Notices of Residual
Petroleum”. The notice was filed on March 11, 2003, prohibiting residential and
groundwater use.
Former Buffing Dust Shed PIN 20308301
The former Buffing Dust Shed is located near the eastern boundary of the Brownfields
Property. The site is being managed under the NCDEQ Inactive Hazardous Sites Branch
(IHSB) (Site ID: NONCD0001223). Historical assessment activities indicated low levels
of several volatile organic compounds (VOCs) in soil at concentrations below the DEQ
Industrial/Commercial Preliminary Soil Remediation Goals (PSRGs). Arsenic was the
only metal detected above soil Industrial/Commercial PSRGs. The former buffing shed
groundwater monitoring wells with contaminant exceedances are located within the
boundaries of the adjacent REEP-LRC Brownfields Property (17047-13-060).
Warehouse – 1900 Continental Blvd.
In November 2019, sub-slab soil gas samples were collected at the warehouse building
and submitted for laboratory analysis of VOCs. Additional sub-slab soil gas samples
were collected in March 2021 in accordance with a DEQ-approved Brownfields Work
Plan.
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Based on results from the previous sub-slab soil gas sampling activities, additional sub-
slab soil gas samples and indoor air samples were collected in July 2022. Results
indicated that tricholorethylene and 1,1-dichloroethylene were detected above Non-
Residential VISLs in one sub-slab sample. Trichloroethylene was also detected in two
indoor air samples at concentrations below NC DEQ Indoor Air Screening
Levels(IASLs). Compounds detected above IASLs included ethylbenzene and
naphthalene.
Parcel East of I-485 PIN 20302139
Parcel 2032139 is 15.88 acres of undeveloped densely wooded land located adjacent and
east of I-485. Based on review of aerial photographs from 1958, a road/path that appeared
to connect the former NAD facility (prior to the Continental Tire facility being built) to
Parcel 20302139 was identified. During a Phase I site reconnaissance near the end of this
former road/path, a soil berm area was observed measuring approximately 33 ft by 18 ft.
The berm area is in a similar area (i.e., east of Interstate I-485) identified as “burning
pits” on the 1950 NAD map. In addition, evidence of land disturbance was identified in
the northwestern portion of the parcel based on a 1978 aerial photograph. An unnamed
intermittent stream is located on a portion of the parcel.
Brownfields site assessments were completed in accordance with a DEQ-approved work
plan in January and July 2021. Environmental media sampled included soil, groundwater,
and surface water. Laboratory analyses included VOCs, SVOCs, RCRA metals,
hexavalent chromium, and explosives compounds. Laboratory results indicated that
metals were detected in soil above Commercial/Industrial PSRGs. No other compounds
analyzed were detected above PSRGs. The samples with the highest concentrations of
metals were located within the berm area.
Laboratory results also indicate that no constituents were detected in groundwater above
NC 2L Groundwater Quality Standards. Surface water laboratory results indicate that
phthalate, lead and phenanthrene were detected slightly above 2B Water Quality
screening levels. Surface water drainage is located adjacent to Interstate I-485.
Potential Receptors:
Potential receptors are construction workers and on-site workers. A receptor survey did
not identify potable wells within 1,500 feet of the property.
Contaminated Media:
DEQ has evaluated data collected from the following media at the subject property: soil,
groundwater, sub-slab soil gas, indoor air, and surface water. DEQ relies on the following
data to base its conclusions regarding the subject property and its suitability for its
intended reuse. A summary of contaminated media exceeding screening criteria is
provided in Exhibit B of the Brownfields Agreement and in the reports listed in
paragraph 4 of the Brownfields Agreement.
Soil
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Arsenic was detected above Non-Residential PSRGs on both parcels at
concentrations up to 5.5 mg/kg.
Cadmium was detected on PIN 20302139 above Non-Residential PSRGs at
concentrations up to 636 mg/kg.
Lead was detected above Non-Residential PSRGs at concentrations up to 2,250
mg/kg at PIN 20302139.
Additional compounds detected with no established screening levels included p-
Isopropyltoluene, n-Propylbenzene, and chromium were detected. Hexavalent
chromium was not detected above Non-Residential PSRGs.
Groundwater
Ongoing groundwater monitoring has been conducted at PIN 20308301 sporadically for
approximately 20 years.
Benzene was detected above 2L Groundwater Quality Standards at monitoring
well MW002 at a concentration of 4.9 ug/L.
Benzo(a)pyrene was detected above 2L Groundwater Quality Standards at
monitoring well MW002 at a concentration of 0.005 ug/L.
1,1-Dichloroethane was detected above 2L Groundwater Quality Standards at
monitoring wells MW01D (4.7 ug/L) and MW006 (11 J ug/L).
MADEP VPH C5-C8 Aliphatic Hydrocarbons was detected above 2L
Groundwater Quality Standards and Groundwater VISLs at MW002 at a
concentration of 10,000 ug/L.
No exceedances of 2L Groundwater Quality Standards were detected at I-485 parcel (PIN
20302139).
Surface Water
Surface water is only present at the I-485 parcel (PIN 20302139).
Di-n-butyl phthalate exceeded NC 2B Surface Water Quality Standards at
concentrations up to 25.2 ug/L.
Lead exceeded NC 2B Surface Water Quality Standards at concentrations up to
1.8 ug/L.
Phenanthrene exceeded NC 2B Surface Water Quality Standards at concentrations
up to 27.9 ug/L.
Exterior Soil Gas
Exterior soil gas samples were not collected.
Sub-Slab Vapor
1,1-Dichloroethane was detected above Non-Residential VISLs at a concentration
of 2,200 g/m3.
Ethanol was detected in multiple samples at concentrations up to 4,300 g/m3.
There is no established screening level for the compound.
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4-Ethyltoluene was detected at concentrations up to 4.5 g/m3. There is no
established screening level for the compound.
Trichlorofluoromethane (Freon 11) was detected at concentrations up to 120.
g/m3. There is no established screening level for the compound.
Trichloroethylene was detected at concentrations up to 1,200 g/m3. Above the
non-residential screening level of 180 g/m3.
Indoor Air
Ethylbenzene was detected above IASLs at concentrations up to 5.7 g/m3.
Naphthalene was detected above IASLs at concentrations up to 1.4 g/m3.
Trichlorethylene was detected below IASLs at concentrations up to 0.22 g/m3.
Risk Calculations
Risk calculations were performed using the DEQ Risk Calculator. For the purposes of
looking at the site spatially, the site was divided by parcel (PINs 20308301 and
20302139), due to the distance between the parcels. The highest concentrations of
contaminants detected in groundwater, soil, surface water, indoor air, and sub-slab soil
gas were used to evaluate risk.
Risk for Individual Pathways Output Form 1A
Version Date: January 2022
Basis: November 2021 EPA RSL Table
Site ID: 24001-20-060
Exposure Unit ID: 1900 Continental Blvd. GW, Soil, SG, IA
Receptor Pathway
Carcinogenic
Risk Hazard Index Risk exceeded?
Soil 8.3E-06 3.5E-01 NO
Groundwater Use* 5.0E-05 9.0E+00 YES
Soil 1.9E-06 4.2E-02 NO
Groundwater Use* 9.6E-06 2.1E+00 YES
Construction Worker Soil 3.1E-07 1.6E-01 NO
Soil 4.4E-06 1.5E-01 NO
Surface Water* NC NC NC
Receptor Pathway
Carcinogenic
Risk Hazard Index Risk exceeded?
Groundwater to Indoor Air 7.6E-06 1.2E+03 YES
Soil Gas to Indoor Air 1.7E-04 2.0E+01 YES
Indoor Air 6.0E-05 4.3E+00 YES
Groundwater to Indoor Air 1.7E-06 2.8E+02 YES
Soil Gas to Indoor Air 1.1E-05 1.6E+00 YES
Indoor Air 1.4E-05 1.0E+00 YES
VAPOR INTRUSION CALCULATORS
Resident
Non-Residential Worker
DIRECT CONTACT SOIL AND WATER CALCULATORS
Resident
Non-Residential Worker
Recreator/Trespasser
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Site ID:
Exposure Unit ID: Former Buffing Shed Soil
Receptor Pathway
Carcinogenic
Risk Hazard Index Risk exceeded?
Soil 9.4E-06 6.8E+00 YES
Groundwater Use* NC NC NC
Soil 1.9E-06 4.7E-01 NO
Groundwater Use* NC NC NC
Construction Worker Soil 4.3E-07 1.2E+01 YES
Soil 5.4E-06 3.8E+00 YES
Surface Water* NC NC NC
DIRECT CONTACT SOIL AND WATER CALCULATORS
Resident
Non-Residential Worker
Recreator/Trespasser
Exposure Unit ID: Billboard Property I-485
Receptor Pathway Carcinogenic
Risk Hazard Index Risk exceeded?
Soil 1.3E-05 5.0E+00 YES
Groundwater Use* 3.7E-06 1.2E-01 NO
Soil 2.0E-06 3.5E-01 NO
Groundwater Use* 7.5E-07 1.8E-02 NO
Construction Worker Soil 1.8E-06 7.1E+00 YES
Soil 7.0E-06 2.8E+00 YES
Surface Water* 2.2E-06 6.1E-02 NO
DIRECT CONTACT SOIL AND WATER CALCULATORS
Resident
Non-Residential Worker
Recreator/Trespasser
The risk calculations indicated the following based on available data, including the
following media: groundwater, soil, surface water, indoor air, and sub-slab soil gas.
Results from the risk evaluation indicate that risk indices were exceeded for groundwater
to indoor air at the warehouse parcel, primarily due to elevated concentrations of Total
Petroleum Hydrocarbons. Soil direct contact risk indices were exceeded for construction
worker and recreator/trespasser receptors at Buffing Shed area (PIN 20308301) and the I-
485 parcel (PIN 20302139). Risk indices for sub-slab soil gas were exceeded due to the
presence of elevated concentrations of TCE in one sub-slab soil gas sample. Sub-slab soil
gas and indoor air monitoring will be required on a quarterly basis for a minimum of one
year. An Environmental Management Plan (EMP) was prepared and approved by DEQ.
Required Land Use Restrictions:
The standard land use restrictions including land use, Environmental Management Plan
and reporting requirements, prohibition on groundwater use, soil restrictions, the need for
vapor intrusion sampling/quarterly monitoring, vapor intrusion restrictions, access,
notification, and prohibition on the use of known contaminants, and the annual land use
update obligation are required for this Brownfields Agreement.
Based on the site-specific data provided to the Brownfield program, the site reuse is
suitable for the site as long as the agreed upon land use restrictions in the BFA are abided
by.
Property Management
TCE is present in sub-slab, and low concentrations are present in IA.
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A Vapor Intrusion Monitoring Work Plan will be submitted to the DEQ by the
PD. Indoor air and sub-slab soil vapor samples will be collected quarterly for a
minimum of one year.
EMP