25094_Mock Judson Mill_Decision Memorandum_20240131

Mock Judson Mill/25094-21-041/20240131
DECISION MEMORANDUM
DATE: 1/31/2024
FROM: Claire Sorrell TO: BF Assessment File

RE: Mock Judson Mill 2610 Oakland Avenue and 1001 S. Lindell Road Greensboro, Guilford County Brownfields Project No. 25094-21-041

Based on the following information, it has been determined that the above referenced site, whose intended use is for no uses other than high-density rental residential, office, retail, rental storage, recreational, associated parking, and subject to DEQ’s prior written approval, other commercial or light/flex industrial uses, can be made suitable for such
uses.
Introduction: The Prospective Developer (PD) is Capitol Broadcasting Company, Inc., located at 2619 Western Boulevard, Raleigh, NC 27606. The entity manager is Michael J. Goodmon, Sr.,
Senior Vice President, located at the same address. The property is comprised of two
parcels totaling 8.67 acres and is located at 2610 Oakland Avenue and 1001 S. Lindell Road (also historically addressed as 1004 and 1006 Howard Street), Greensboro, Guilford County (Tax Parcel ID No. 219794). The parcels are currently under construction but are unoccupied.

The Brownfields Property is located on an entire block with Oakland Avenue to the south, South Lindell Road to the west, Hiatt Street to the north, and Howard Street to the east. The Brownfields Property is zoned heavy industrial, but we anticipate that the PD has successfully modified the zoning to include residential. There is a two-story former
main mill structure on the site which has a partial, 700 square foot (ft2) basement, and a
one-story brick and steel boiler house north of the mill building. Redevelopment Plans: Redevelopment plans consist of two phases. Phase 1 includes renovation of the mill
building and boiler house into 173 rental apartments with associated amenities and
recreational uses, including a swimming pool, outdoor lawn, grilling area, and dog park. Phase 2 development is yet to be determined, but may include office, retail, light/flex industrial, commercial, or other recreational reuse.
Sub-grade features include a basement under the 1928 addition to the mill building. This
area is being renovated into a living space. There is a vault and a hallway on the northern side of the mill building basement, both of which have been fully backfilled with soil and

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sealed off from the basement. There are utilities that cross them, parallel with the building.

There is a void space that is presumed to be an old cistern located between the mill building and the boiler room. This space will be left void, the manholes which grant access to the space will be sealed, and a walkway will be installed above the void space.
No testing is planned for this void space, but pre-occupancy sub-slab soil vapor sampling
of the full list of TO-15 volatile organic compounds (VOCs) and pre-occupancy indoor air sampling of select TO-15 VOCs will be collected in the mill building basement and will be used to further assess the need for vapor intrusion (VI) mitigation.
Historically, the boiler room was sub-grade, and contained several feet of standing water,
the source of which is believed to be surface water runoff, and not a result of groundwater infiltration. The boiler room was filled with 11 feet of gravel, and a new four-inch slab was poured.
Site History:
In the 1900s, the site was developed as a nursery and florist with green houses, the Pomona Station post office, and a single-family residence. The existing main mill building was constructed in segments. The eastern, middle, and western portions of the building were built in 1928, 1929, and 1936, respectively. From 1928-1974, the
Brownfields Property was used for the milling of fine hosiery. The Mock-Judson-
Voehringer Company operated here from circa 1928 to the late 1950s. The Brownfields Property was sold circa 1960 to Greensboro Hosiery Mills, Inc., a division of Kayser-Roth Corporation, which operated at the site. By the mid-1960s, a discount clothing outlet, offices, and warehousing occupied the east end of the mill building. Rolane
Corporation retail outlet occupied the site from 1980 to 1997. No operations occurred at
the Brownfields Property from 1997-2017. In 2017, MJM Owner, LLC, a company affiliated with the PD, acquired the Brownfields Property and demolished certain site structures, including three electrical ground-
mounted transformers formerly located along the southern wall of the mill building in
preparation for residential redevelopment. Environmental History: On-property sources of contamination include three No. 4 fuel oil underground storage
tanks (USTs) which have been removed from the site, and polychlorinated biphenyls
(PCB)-contaminated soil that was also removed from the Brownfields Property. Groundwater impacts from these releases have been documented on the Brownfields Property.
In 2012, I C Group collected dielectric fluid samples from the on-site transformers and
soil from the locations of three transformers, as reported in the letter Re: MJV PCB
Sampling, 2610 Oakland Avenue, Greensboro, NC 27403 (ICG, August 7, 2012). Two of the three oil samples indicated that PCBs were present in two of the three transformers.

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This letter report was not signed and sealed by a North Carolina Professional Engineer or Professional Geologist; however, the soil impacted by these PCBs was removed from the
Brownfields Property, and therefore, are not included in the Exhibit 2 nor risk calculator
input for this project. As part of environmental assessment conducted at the Brownfields Property, an investigation report from 2017, Subsurface Investigation Report, 2610 Oakland
Greensboro Owner, LLC Property (Rolane Mill) (Swift Creek Environmental, Inc., May
19, 2017), was signed but not sealed by a North Carolina Professional Geologist. Therefore, the data submitted in this report was not incorporated into the Exhibit 2 nor risk calculator input for this project.
A 500-gallon Varsol underground storage tank (UST) was reportedly located on and
removed from the Brownfields Property during other UST removals in the early 1990s. No closure documentation has been submitted to NC DEQ; therefore, it is unclear if this UST remains on site.
Regulatory interaction with this Brownfields Property includes the following:
1. DEQ UST Section - Incident No. 8934, UST No. WS-3132. At the former Kayser-Roth property, three USTs that held No. 4 fuel oil were formerly located on the west side of the boiler house but were removed from the site in 1991. NCDEQ closed the petroleum incident for Facility ID 18078, as outlined in their
letter dated September 12, 1992.
2. DEQ IHSB: NONCD0002622 – DEQ conducted a Pre-CERCLA Screening of the Brownfields Property in 2020. A Notice of REC Program Eligibility letter was sent to Mark Bouldin, of MJV, LLC, the property owner, on May 3, 2021. IHSB
in their report to EPA, indicated that the surficial PCB contamination could be
addressed either under an REC Agreement or with a Brownfields Agreement. The PD chose the latter. Cleanup of the PCB-contaminated soil was performed by Atlantic Shores Environmental Services, Ltd., for the PD. There were two former PCB transformer leaks that impacted locations south of and adjacent to the main
mill building. On December 20, 2022, approximately 26,672 kilograms of PCB-
contaminated soil were excavated, placed in roll-off containers, and covered. This work was performed under an Environmental Management Plan (EMP) which was approved by DEQ on December 13, 2022. On February 2, 2023, 29.40 tons of PCB-contaminated soil was transported offsite to CWM – Emelle, at 36964
Alabama Highway 17, Emelle, AL, 35459.
In October 2023, fill soil was imported to the Brownfields Property from Martin Marietta Salem Stone Quarry, which was approved by DEQ based on the data provided in the report entitled Import Soil Sampling – Martin Marietta Salem Stone Quarry (Atlantic
Shores Environmental Services, Ltd., October 24, 2023).

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Potential Receptors: Potential receptors are: construction workers, on-site workers, future residents, visitors,
pets, recreators, and trespassers.
Contaminated Media: DEQ has evaluated data collected from the following media at the subject property: soil, groundwater, sub-slab vapor, exterior soil gas, background air, and standing water from
the boiler room.
DEQ relies on the following data to base its conclusions regarding the subject property and its suitability for its intended reuse. Please see the Brownfield Agreement’s Exhibit 2 for specific sample locations, dates, and contaminants of concern (COCs).

Risk Calculations: Risk calculations were performed using the July 2023 DEQ Risk Calculator https://deq.nc.gov/permits-rules/risk-based-remediation/risk-evaluation-resources. For the purposes of looking at the site spatially, assessment was performed site-wide, in
four separate risk calculators – site-wide soil and site-wide groundwater, and mill
building sub-slab vapor risk calculations in one risk calculator (Table 1), sub-slab vapor risk calculations for Boiler Room (Table 2), Sub-slab vapor risk calculations for Mill Building (Table 3), and in a fourth risk calculator, Site-wide exterior soil gas risk calculations (Table 4).

Table 1. Site-wide soil and groundwater calculations

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Table 2. Sub-slab vapor risk calculations for Boiler Room
Table 3. Sub-slab vapor risk calculations for Mill Building

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Table 4. Site-wide exterior soil gas risk calculations
Risk for Individual Pathways Output Form 1A
Version Date: July 2023
Basis: May 2023 EPA RSL Table
Site ID: 25094-21-041
Exposure Unit ID: Site-wide Exterior Soil Gas
Receptor Pathway Carcinogenic
Risk Hazard Index Risk exceeded?
Soil NC NC NC
Groundwater Use*NC NC NC
Soil NC NC NC
Groundwater Use*NC NC NC
Construction Worker Soil NC NC NC
Soil NC NC NC
Surface Water*NC NC NC
Receptor Pathway Carcinogenic
Risk Hazard Index Risk exceeded?
Groundwater to Indoor Air NC NC NC
Soil Gas to Indoor Air 5.8E-06 4.1E-01 NO
Indoor Air NC NC NC
Groundwater to Indoor Air NC NC NC
Soil Gas to Indoor Air 4.3E-07 3.3E-02 NO
Indoor Air NC NC NC
DIRECT CONTACT SOIL AND WATER CALCULATORS
Resident
Non-Residential Worker
Recreator/Trespasser
VAPOR INTRUSION CALCULATORS
Resident
Non-Residential Worker
Soil Soil was collected from 32 soil borings, from ground surface to a depth of 30 feet below
ground surface (bgs), on June 8 and 9, 2021. In July 2022, fourteen sub-slab soil samples
(SS1-SS14) were collected and assessed. Confirmatory PCB sampling was conducted on December 20, 2022. These samples indicate removal of impacted soils containing Aroclor 1254 in excess of the residential PSRG in sample locations SS1 and SS2 from a depth of 0-1 feet bgs, and SS3 from a depth of 3-5 feet bgs. The soil data that was used in
the risk calculator and the Exhibit 2 reflect the soil remaining on the Brownfields
Property after the soil removal and redistribution activities discussed above. There were detections of VOCs in the form of total petroleum hydrocarbons - gasoline range organics (TPH-GRO) in soil in the southern portion of the site. Metals detected in
excess of their residential Preliminary Soil Remedial Goals (PSRGs) were arsenic, benzo(a)pyrene, cadmium, and hexavalent chromium.
Based on the risk calculator output, the acceptable carcinogenic risk range is not exceeded for residential, non-residential worker, construction worker, nor recreator/trespasser scenarios with respect to direct exposure to soil. Additionally, the threshold noncancer hazard index of 1.0E-04 is not exceeded for the direct contact soil pathway for residential nor non-residential worker exposure scenarios.

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Groundwater Groundwater was assessed from September 15, 2021, to March 23, 2023. While samples
were collected in 2017, the Subsurface Investigation Report (Swift Creek Environmental,
Inc., May 19, 2017) in which this data was submitted, was not sealed by a NC PE or NC PG. Therefore, the data presented in this report was not incorporated into the Exhibit 2 nor the risk calculator for this Brownfields Property.
Groundwater was sampled from eleven monitoring wells (MW1 to MW11) in September
2021, for which groundwater was found between 7.79 feet and 27.35 feet below top of well casing. Groundwater was sampled from five monitoring wells (MW-2, MW-3, MW-6, MW-7, MW-8) on July 22, 2022, for which the depth to water was observed from 9.07 feet to 18.5 feet. Groundwater was sampled from three monitoring wells (MW1 to
MW3) with one duplicate (DUP MW-2) on March 23, 2023, for which the depth to
groundwater was observed to be between 8.55 feet and 10.12 feet. Groundwater flows towards the north (Figure 1). Of the groundwater data collected on July 22, 2022, the highest water table measurement
was at a depth of 9.07 ft below ground surface (bgs) at MW3 (north of the boiler room),
which is below the bottom of the boiler room floor. Site data indicate that standing water in the sub-grade area of the boiler room contained TCE, and possible lab contaminants (acetone and phenol). However, these concentrations were below existing 2B and 2L standards and their respective Groundwater Vapor Intrusion Screening Levels (VISLs).
While this standing water does not appear to be sourced from groundwater, its origin
remains unknown. This water has been removed from the Brownfields Property and this area was filled in with 11 feet of gravel and covered with a 4-inch-thick concrete slab during renovations in the building.
Based on a comparison of the groundwater elevation and that of the basement floor, the
standing water does not appear to be related to groundwater flow. These contaminants in the standing water have not been used to evaluate risk in the risk calculators below; however, the presence of TCE in this standing water informs decisions about pre-occupancy sub-slab vapor sampling in this area.

Based on the risk calculator output, the acceptable residential hazard index of 1.0 is exceeded for the direct groundwater contact residential scenario (HI is 3.0). Additionally, the threshold noncancer index of 1.0E-04 is exceeded for direct groundwater contact, as the noncancer
index is 3.6E-04. The calculated non-carcinogenic hazard quotient for residential direct contact with groundwater is 2.4 for arsenic and 0.3 for pentachlorobiphenyl, 3,3',4,4',5-
(PCB 126); these are the contaminant risk drivers based on the risk calculator output.
Based on the risk calculator output, the acceptable carcinogenic risk range is not exceeded for
the non-residential worker scenario with respect to exposure to groundwater. Additionally, the threshold noncancer hazard index of 1.0E-04 is not exceeded for groundwater or the groundwater to indoor air vapor intrusion pathway for non-residential worker exposure scenarios.

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General concentrations of analytes appear to be stable. There are no known offsite issues which are caused by the contaminants on this Brownfields Property. There is no ongoing
monitoring at this Brownfields Property by another DEQ program.

Surface Water Surface water is not located on nor borders the Brownfields Property.
Exterior Soil Gas
Two exterior soil gas samples were collected to the north of the boiler room on July 14, 2023 (Figure 1). TCE was detected in sample SG-1 in July 2023 at a concentration of 7.2 µg/m3. Based on the risk calculator output (Table 4), the acceptable carcinogenic risk range is not exceeded for residential nor non-residential worker soil gas to indoor air vapor intrusion scenarios. Additionally, the threshold noncancer hazard index of 1.0E-04 is not exceeded for the residential or non-residential worker soil gas to indoor air vapor intrusion
scenarios. However, the calculated hazard index for soil gas to indoor air (0.41) while not leading to a requirement for a vapor intrusion mitigation system (VIMS) coupled with other
considerations below indicates that additional pre-occupancy and post-occupancy sampling should be conducted at the Brownfields Property. Sub-Slab Vapor
Sub-slab vapor samples were collected from the boiler room and the main mill building
from September 2021 to July 2023. There were eight locations (AS3 to AS10) within the main mill building which were sampled on September 14 and 15, 2021. During the July 2023 sampling event, there was
one sub-slab vapor sample collected in the basement of the mill building (Sub-1) and two
sample locations (Sub-2, Sub-3, and a duplicate, Sub-3D) within the boiler room which were sampled (Figure 1). PCE was detected in seven of eight sub-slab samples collected during the September
2021 sampling event, and in three samples collected in 2023. The highest concentration
of PCE, 65 µg/m3, was found in sample SG-2; however, these concentrations did not exceed the residential VISL for PCE. While none of PCE concentrations exceeded their respective residential VISL, these contaminants have been detected in sub-slab vapor at the Brownfields Property.
In the boiler room, only concentrations of 1,2-dichloroethane and naphthalene were detected at concentrations that exceeded their residential VISLs of 3.6 µg/m3 and 2.8 µg/m3, respectively resulting in a hazard index for soil gas to indoor air of 0.089; however, the former presence of TCE in the standing water in the boiler room and the
change in conditions brought about by the creation of a gravel-filled space and new
concrete slab in a residential space indicate that pre- and post-occupancy sampling for VI should be performed in the boiler room to confirm the HI remains this low under the new conditions.

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In the main mill building, the only compound detected which exceeded the residential
VISL is naphthalene, which was detected at a concentration of 12.3 µg/m3 (VISL is 2.8).
Additional detected compounds in the main mill building included 4-ethyltoluene, ethanol, naphthalene, and trichlorofluoromethane. Risk was calculated separately for the boiler room (Table 2) and the mill building (Table
3).
Based on the risk calculator output, the acceptable residential hazard index of 1.0 is not
exceeded for the mill building (HI is 0.26 and 0.021 for the residential soil gas to indoor air pathway and the non-residential worker soil gas to indoor air pathway, respectively); however based on the detection of TCE at the Brownfields Property from an unknown source and the HI of 0.26 for residential use, for which we would recommend a VIMS, additional
pre-occupancy and post-occupancy sampling should be conducted to confirm these results.
The calculated carcinogenic risk (CR) for any risk scenario does not exceed the acceptable CR range maximum of 1.0E-4, for the boiler room nor the mill building. The calculated HIs for soil gas to indoor air residential exposure for the boiler room prior to its renovation and exterior soil gas north of the boiler room range from 0.089 to 0.41,
respectively. The presence of TCE in the boiler room standing water from an unknown source and the higher HI from exterior soil data north of the boiler room indicates that pre-occupancy sampling is required for seasonal variability and post-occupancy sampling may be necessary in the boiler room to confirm that VI is not an issue with the new construction and with seasonal variability.
The calculated HI for soil gas to indoor air residential exposure for the main mill building is 0.26, which is in the range for which we do not require, but recommend, a VIMS. On the basis of early sub-slab vapor sampling, the PD selected not to mitigate the space. TCE has not been detected in the sub-slab data collected in the main building and the existing
slab has not been altered except to add utilities for the residential spaces. Based on the HI of 0.26 on previous sub-slab vapor data, the lack of TCE detection in sub-slab vapor, and the building’s non-mitigated status, pre-occupancy sub-slab sampling while the HVAC is operational is required and post-occupancy sub-slab vapor sampling is required for a one year for full list TO-15.
Therefore, based on the DEQ Risk Calculator output and our guidance as to VI sampling, the future pre-occupancy and post-occupancy sampling requirements are noted in the following table (Table 5). All sampling should be conducted with the HVAC system operating. Sampling has the potential to decrease/cease following the year of sampling
with written DWM approval.

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Table 5. VI Sampling for Non-Mitigated Spaces
Building/Area Residential HI Pre-Occupancy Sampling Post-Occupancy Sampling
Boiler Room/Ext Soil Gas 0.089/0.41 SSV – full TO-15
May be waived depending on SSV sample results and resulting HI
Main Mill Building 0.26 SSV - full TO-15 Semi-Annual SSV sampling for one year for
full list
SSV – Sub-slab vapor Land Use Restrictions:
LURs will include the standard land use restrictions including approved land uses, land use definitions, specific prohibitions, requirement for an EMP, redevelopment summary report requirements, groundwater, soil disturbance, known contaminants, access, notification, vapor intrusion, and land use restriction update LURs. 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 ISSUES If there is to be any additional development that is not included in the Environmental
Management Plan (EMP) which was approved by DEQ on December 13, 2022, the
language in paragraph 12.l. of the BFA will apply. Sub-slab vapor should be performed in accordance with DWM policy in the mill building and boiler room until Brownfields approves the reduction or cessation of sampling. If the
results of pre-occupancy or post-occupancy sub-slab vapor sampling increase the
calculated HI, the potential for indoor air sampling should be evaluated. No VIMS has been developed or installed at this Brownfields Property based on early indications that the threshold HI of 1.0 had not been exceeded for soil gas exposure
pathways. However, at the time the brownfields application was submitted, there were
multiple feet of standing water in the basement of the boiler room which contained TCE from an unknown source. As discussed above, the conditions in this area have been renovated such that it is possible that TCE may accumulate in the gravel backfill and therefore the collection of additional sub-slab vapor samples in the area that previously
had standing water in the boiler room and in the main building are appropriate. One
round of sub-slab vapor samples has been collected and indicated that there is not an exceedance of the sub-slab VISL for TCE in sub-slab vapor; however, this will be confirmed with pre-, and possibly post-, occupancy sampling.

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Figure 1. Sub-slab vapor and soil gas sampling locations

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Figure 2. Groundwater Elevation Map