HomeMy WebLinkAbout20094_Belmont_Decision_Memorandum_20170824DECISION MEMORANDUM
DATE: August 17, 2017
FROM: Bill Schmithorst
TO: Brownfields Agreement File
RE: Former Belmont Dyers
18 Linestowe Drive
Belmont, Gaston County
BF # 20094-16-036
Based on the following information, it has been determined that the above referenced
Brownfields Property, whose intended use is for no uses other than high density
residential, multi-family residential, open space, and parking, can be made suitable for
such uses.
Introduction:
The Brownfields Property is approximately 12 acres and it contains an office building
formerly occupied by a dyeing manufacturer (Exhibit 1). The Brownfields Property is
bordered to the north by land used for single family residential; to the east by land used
for single family residential, the City of Belmont Pump Station, and the Catawba River;
to the south by River Drive and land used for low and high density residential; and to the
west by Linestowe Drive and land used for single family residential.
Redevelopment Plans:
Redevelopment plans for the Brownfields Property include high density residential, open
space, recreation, parking, and with prior written DEQ approval, other commercial uses.
Site History:
The Brownfield Property was developed with a textile mill prior to 1929. At that time,
the Brownfield Property contained a main production building, a boiler building, an
attached warehouse, caustic and sulphuric acid tanks, gasoline underground storage tanks
(USTs), a detached warehouse, and the current office building. Two railroad spurs
serviced the Brownfield Property’s operations until the mid-1960s. An attached dye
house addition was completed by 1965. Former textile operations at the Brownfields
Property consisted of yarn mercerizing, bleaching, and dyeing.
The Brownfields Property was occupied by the Belmont Processing Company until the
mid-1940s, when Aberfoyle Manufacturing Company took over operations at the
Brownfields Property. The Brownfields Property was operated by Belmont Dyers
Company from the mid-1970s until 2003. Meridian Specialty Yarn Group, Inc.
(Meridian), a division of Meridian Industries, Inc., obtained the Brownfields Property
through the acquisition of Belmont Dyers Company in June 1990. During this time
period, Michelle Textiles also operated in a portion of the building. The former main
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production building and former dye house contained textile bleaching and dyeing
operations that began in late 1920s and continued through closure of the mill in 2003.
The former mill buildings were razed beginning in mid-2007, and the Brownfields
Property has remained vacant since that time. The Brownfields Property is comprised of
three parcels and is currently owned by The Metropolitan Group, Inc. The Prospective
Developer contracted to purchase the Brownfields Property on September 16, 2016.
Historic Sanborn Fire Insurance maps from the 1920s through 1940s indicate the
presence of three gasoline underground storage tanks (USTs) off the southeast corner of
the former manufacturing building. A 1990 environmental assessment report identified
one gasoline UST and one spent dye liquor underground tank at the Brownfields
Property. It is unclear from available reports if the USTs have been closed and removed.
Environmental Conditions Summary
Soil and groundwater assessments were conducted at the Brownfields Property from
1991 to the present. Assessment and remediation at the Brownfields Property are
currently being conducted by the Remediating Party Meridian Specialty Yarn Group, Inc.
pursuant to a voluntary Administrative Agreement with the DEQ Inactive Hazardous
Sites Branch (IHSB) Registered Environmental Consultant (REC) program under Site ID
No. NONCD0001335. A summary of the environmental conditions at the Brownfield
Property exceeding their respective standard and/or screening levels is provided in
Exhibit 2.
Soil
Soil assessments were conducted at the Brownfield Property in 1991, 2005, and 2016.
The soil assessment conducted in 1991 indicated the presence of low level pesticides and
volatile organic compounds (VOCs) in shallow soil at the Brownfields Property.
However, the 1991 assessment results are presented in an unsigned draft report, therefore,
the results are not valid for risk screening purposes. A total of 13 soil borings were
advanced during a September 2005 site assessment for the purpose of collecting soil
samples for VOC analysis. Analytical laboratory results showed that no VOCs were
detected above residential risk screening levels. During the September 2005 assessment,
a suspected abandoned sewer line was encountered while drilling along the southern
boundary of the Brownfields Property. A sludge sample was collected from the sewer
line and analyzed by a laboratory for VOCs. Compounds detected in the sludge sample
included 1,4-dichorobenzene (170 ug/kg), tetrachloroethylene (23 ug/kg), and 1,2,4-
trichlorobenzene (270 ug/kg). Analytical results indicate that the sewer line could be a
possible source of VOCs in groundwater.
On February 6, 2007, a fuel line associated with the 5,000-gallon oil aboveground storage
tank (AST) was ruptured during demolition activities at the Brownfields Property
resulting in a release of fuel oil. The oil entered a stormwater drain and discharged into
the Catawba River east of the Brownfields Property. Because the discharge of oil to the
Catawba River violated the Clean Water Act, the United States Environmental Protection
Agency (US EPA) oversaw the assessment and remediation of the incident (FPN#
E07408). Impacted soil was subsequently excavated and transported to an off-site facility
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for disposal. No reports have been provided documenting results from assessment or
remediation activities related to the incident.
A limited soil assessment was conducted at the Brownfields Property in November 2016.
Soil samples were analyzed for SVOCs and RCRA metals. Results from the assessment
showed that select SVOC compounds, arsenic, and manganese detected in soil exceeded
residential screening levels. Although the samples were submitted for analysis of RCRA
metals, the samples were not analyzed by the laboratory for arsenic.
A soil and soil gas assessment was conducted in May and June 2017. Shallow soil
samples were collected and analyzed for SVOCs. One sample located in the southeastern
area of the Brownfields Property was analyzed for RCRA metals. Laboratory results
showed an exceedance of residential risk based screening levels for arsenic. No SVOCs
were detected above residential risk based screening levels.
Soil Vapor
A soil gas assessment was conducted at the Brownfields Property in May 2017. Results
from the assessment showed that VOCs (primarily PCE) exceeded residential soil gas
risk screening levels near the southern property boundary. The highest concentration of
TCE reported was 16,000 ug/m3.
Groundwater
Groundwater assessment activities have been conducted at the Brownfield Property from
1991 through 2017. Groundwater assessment results indicate that shallow groundwater
impacts (primarily PCE) are present in the central, southern, and eastern portions of the
Brownfields Property at concentrations exceeding North Carolina groundwater 2L
standards. In addition, results indicate that groundwater contamination may have
migrated off-site to the south and southeast of the Brownfields Property.
Surface Water
The Catawba River is located to the east and southeast of the Brownfields Property and is
a potential receptor. Surface water samples were collected annually from the Catawba
River from 2005 through 2009, and analyzed for VOCs. No VOCs were detected in
surface water above surface water quality standards.
Potential Receptors
Potential receptors are: construction workers, on-site workers, residents, adjacent
residential properties, City of Belmont pump station, Catawba River, and trespassers.
Contaminated Media
DEQ has evaluated data collected from the following media at the subject property: soil,
soil-gas, surface water, and groundwater. DEQ relies on the following data to base its
conclusions regarding the subject property and its suitability for its intended reuse.
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Soil
Soil contaminants above residential screening levels include: arsenic, manganese,
Benzo(a)anthracene, Benzo(a)pyrene, Benzo(b)fluoranthene, Dibenzo(a,h)anthracene.
Groundwater
Groundwater contaminants above the NCAC 2L Standard include: benzene,
chlorobenzene, 1,4-dichlorobenzene, cis-1,2-dichloroethene, tetrachloroethene,
trichloroethene, and 1,2,4-trichlorobenzene.
Soil Vapor
Soil vapor contaminants detected above IHSB Residential Screening Levels include:
tetrachloroethene, trichloroethene, 1,2,4-trimethylbenzene.
Risk Calculations
Risk Calculations were performed using Excel worksheets provided by Sandy Mort,
NCDEQ Brownfields Toxicologist. The risk calculations indicated the following based
on available data, including the following media: groundwater, subsurface residual soil,
and soil gas:
PRIMARY CALCULATORS
Receptor Pathway Carcinogenic
Risk
Hazard
Index
Risk
exceeded?
Resident Soil Combined
Pathways
7.0E-05 5.0E-01 No
Groundwater
Combined Pathways
1.7E-04 3.4E+01 YES
Groundwater
Combined Pathways
1.3E-06 1.9E+00 YES
Construction
Worker
Soil Combined
Pathways
1.3E-06 3.1E+00 YES
VAPOR INTRUSION CALCULATORS
Receptor Pathway Carcinogenic
Risk
Hazard
Index
Risk
exceeded?
Resident Groundwater to
Indoor Air
3.2E-05 7.8E+00 YES
Soil Gas to Indoor
Air
5.6E-05 1.2E+01 YES
The mediums affected include groundwater, groundwater to indoor air, soil vapor, and
subsurface soil. The groundwater, groundwater to indoor air and soil vapor risk drivers
are primarily related to PCE detected in groundwater and potentially subsurface soil. The
risk drivers for subsurface soil are arsenic and SVOCs. The PD is proposing to add
appropriate vapor mitigation systems to buildings constructed onsite in areas with
elevated VOC soil vapor concentrations to address potential vapor intrusion issues. In
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addition, the PD will add appropriate dust control measures to address potential exposure
to arsenic and SVOCs during construction.
Required Land Use Restrictions
Based on the site-specific data provided to the Brownfield program, the site reuse is
suitable for high density residential, multi-family residential, open space, and parking, as
long as the agreed upon land use restrictions in the BFA are followed.
1. No use other than for. Definitions for Hotel, Open Space, High Density Residential,
Commercial, Recreation, Open Space, and Parking.
2. No groundwater use
3. No disturbing soil without DEQ approval or for landscape/mowing/pruning/repair of
underground infrastructure (written notice to DEQ)/work for EMP.
5. Soil Import/Export.
6. No new buildings until DEQ says indoor air is safe/no VI issues/VI protection
installed.
8. EMP
9. Access to Brownfields Property for environmental assessment.
10. NBP reference in deed.
11. No contaminants on property except for de minimis amounts, fluid in vehicles, fuels
for generators/equipment.
12. Written agreement with homeowners association for ongoing maintenance of vapor
mitigation systems.
13. Final grade soil sampling for RCRA metals, SVOCs, VOCs and pesticides will be
conducted.
14. LURU submission January 1st
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Exhibit 2
The most recent environmental sampling at the Property reported in the
Environmental Reports occurred on May 16, 2017. The following tables set forth, for
contaminants present at the Property above unrestricted use standards or screening levels,
the maximum and most recent concentrations found at each sample location, and the
applicable standard or screening level. Screening levels and groundwater standards are
shown for reference only and are not set forth as cleanup levels for purposes of this
Agreement.
GROUNDWATER
Groundwater contaminants in micrograms per liter (the equivalent of parts per
billion), the standards for which are contained in Title 15A of the North Carolina
Administrative Code, Subchapter 2L (2L), Rule .0202, (April 1, 2013 version):
Groundwater
Contaminant
Sample
Location
Date of
Sampling
Maximum
Concentration
Exceeding
Standard
(g/L)
Date of
Sampling
Most Recent
Concentration
Exceeding
Standard
(g/L)
Standard
(g/L)
Benzene MW-1D 11/5/07 1.6 11/5/07 1.6 1 MW-1IR 1/24/09 1 1/24/09 1
Chlorobenzene PMW-6IR 3/22/16 58 3/22/16 58 50
1,4-Dichlorobenzene PMW-6IR 3/22/16 26 3/22/16 26 6 PMW-6SR 3/22/16 9.7 3/22/16 9.7
cis-1,2-Dichloroethene PMW-6SR 3/22/16 96 3/22/16 96 70
Tetrachloroethylene
GP-10-42’ 9/27/05 1.4 9/27/05 1.4
0.7
GP-8-48’ 9/27/05 5.5 9/27/05 5.5
MW-1 5/10/05 64 11/18/06 52
MW-1D 6/8/05 280 11/5/07 130
MW-1DR 7/12/09 18 7/12/09 18
MW-1I 9/20/04 36 11/18/06 24
MW-1R 7/12/09 9.1 7/12/09 9.1
MW-1IR 1/24/09 2.1 1/24/09 2.1
MW-2 5/10/05 2.7 11/5/07 1.2
MW-2R 7/12/09 2.7 7/12/09 2.7
MW-3 5/10/05 1.9 7/12/09 <0.5
PMW-1IR 3/22/16 3.2 3/22/16 3.2
PMW-1SR 3/22/16 6.2 3/22/16 6.2
PMW-3SR 3/22/16 1.2 3/22/16 1.2
PMW-4SR 3/22/16 5.6 3/22/16 5.6
Tetrachloroethylene PMW-5SR 3/22/16 110 3/22/16 110 0.7 PMW-6IR 3/22/16 91 3/22/16 91
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PMW-6SR 3/22/16 200 3/22/16 200
Trichloroethylene
MW-1 9/20/04 &
5/10/05 11 11/18/06 6.2
3 MW-1D 6/8/05 15 11/5/07 9
PMW-1DR 3/22/16 9 3/22/16 9
1,2,4-
Trichlorobenzene PMW-6IR 3/22/16 86 3/22/16 86 70
GROUNDWATER VAPOR INTRUSION RISK
Groundwater contaminants with potential for vapor intrusion (VI) in micrograms
per liter (the equivalent of parts per billion), the vapor intrusion screening levels for
which are derived from the Residential Vapor Intrusion Screening Levels of the Division
of Waste Management October 2016 version):
Groundwater
Contaminant with
Potential for Vapor
Intrusion
Sample
Location
Date of
Sampling
Maximum
Concentration
Exceeding
Screening
Level (g/L)
Date of
Sampling
Most Recent
Concentration
Exceeding
Screening
Level (g/L)
Residential
VI
Screening
Level1
(g/L)
1,4-
Dichlorobenzene
PMW-
6IR 3/22/16 26 3/22/16 26 25.9
cis-1,2-
Dichloroethene
PMW-
6SR 3/22/16 96 3/22/16 96 70
Tetrachloroethylene
MW-1 5/10/05 64 11/18/06 52
11.5
MW-1D 6/8/05 280 11/5/07 130
MW-1DR 7/12/09 18 7/12/09 18
MW-1I 9/20/04 36 11/18/06 24
PMW-
5SR 3/22/16 110 3/22/16 110
PMW-
6IR 3/22/16 91 3/22/16 91
PMW-
6SR 3/22/16 200 3/22/16 200
Trichloroethylene
MW-1
9/20/04
&
5/10/05
11 11/18/06 6.2
1 MW-1D 6/8/05 15 11/5/07 9
PMW-
1DR 3/22/16 9 3/22/16 9
1,2,4-
Trichlorobenzene
PMW-
6IR 3/22/16 86 3/22/16 86
7.19 PMW-
6SR 3/22/16 29 3/22/16 29
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1 Screening levels displayed for non-carcinogens are for a hazard quotient equal to 0.2. Screening
levels displayed for carcinogens are for a 1.0E-5 lifetime incremental cancer risk.
2 NS – Screening level or regulatory not established.
SOIL
Soil contaminants in milligrams per kilogram (the equivalent of parts per million),
the screening levels for which are derived from the Preliminary Residential Health-
Based Soil Remediation Goals of the Inactive Hazardous Sites Branch of DEQ’s
Superfund Section (October 2016 version):
Soil
Contaminant
Sample
Location
Depth
(ft)
Date of
Sampling
Concentration
Exceeding
Screening Level
(mg/kg)
Residential
Screening
Level1 (mg/kg)
Arsenic
HHSB-5 4-6 5/16/17 2.6
0.68 SB-3 1-3 11/21/16 3.8
SB-4 3-5 11/21/16 2.9
SB-5 2-4 11/21/16 3.1
Benzo(a)anthracene SB-2 1-3 11/21/16 0.61 0.16
Benzo(a)pyrene SB-2 1-3 11/21/16 0.62 0.016
Benzo(b)fluoranthene SB-2 1-3 11/21/16 0.57 0.16
Dibenzo(a,h)anthracene SB-2 1-3 11/21/16 0.111 J 0.016
Indeno(1,2,3-cd)pyrene SB-2 1-3 11/21/16 0.53 0.16
Manganese SB-1 0-2 11/21/16 624 360 SB-4 2-4 11/21/16 527
1Screening levels displayed for non-carcinogens are for a hazard quotient equal to 0.2. Screening
levels displayed for carcinogens are for a 1.0E-6 lifetime incremental cancer risk.
NE – No established screening level
SOIL GAS
Soil gas contaminants in micrograms per cubic meter, the screening levels for
which are derived from Residential Vapor Intrusion Screening Levels of the Division of
Waste Management (October 2016 version):
Soil Gas Contaminant
Sample Location Date of
Sampling
Concentration
Exceeding
Screening
Level (g/m3)
Residential
Screening
Limit1
(g/m3)
Tetrachloroethylene
HHSG-2 5/16/17 320
278 HHSG-4/DUP-1 5/16/17 16,000
HHSG-5 5/16/17 1,900
HHSG-8 6/20/17 360
1,2,4-Trimethylbenzene HHSG-5 5/16/17 85 48.7
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1Screening levels displayed for non-carcinogens are for a hazard quotient equal to 0.2.
Screening levels displayed for carcinogens are for a 1.0E-5 lifetime incremental cancer risk.