SF_F_NCD044513307_20220927_FRB_PASI(1)

September 27, 2022
Ms. Sandra Bramble, RPM
Superfund Restoration and Site Evaluation Section
Superfund Division
US EPA Region IV Waste Division
61 Forsyth Street SW, 11th Floor, Atlanta, GA 30303
Subject: Preliminary Assessment (PA) Report
Old Battleground Road TCE Site
NCD 044 513 307
Greensboro, Guilford County, NC
Dear Ms. Bramble,
Under authority of the Comprehensive Environmental Response, Compensation, and
Liability Act of 1980 (CERCLA) and the Superfund Amendments and Reauthorization Act of
1986 (SARA), the North Carolina Department of Environmental Quality (DEQ) Superfund
Section conducted a Preliminary Assessment (PA) at the above site. The purpose of this
investigation was to collect information concerning conditions at the site sufficient to determine
the need for additional CERCLA/SARA or other appropriate evaluation.
The scope of this PA included reviews of historical NC Hazardous Waste Section
correspondence, plus contractor and EPA reporting on a Removal Action completed on site as
part of a March 2021 Administrative Settlement Agreement and Order on Consent (ASAOC)
between EPA and Battleground Storage, LLC, the present site owner (Refs. 3, 4). NC DEQ and
Guilford County geographic information services (GIS) data were also reviewed.
Site Description, Operational and Regulatory History and Waste Characteristics:
The site is a self-storage facility and a former metal stamping and fabricating facility
located on two contiguous land parcels at 3700 and 3704 Old Battleground Road in northwestern
Greensboro, NC, 27410 (Ref. 3) (see Figure 1). Site geographic coordinates are 36.12840o N
Latitude and 79.84509o West Longitude (Ref. 4). The approximately 3.8-acre northern site
property contains a large steel-framed structure constructed in the mid-1960s, with two attached
smaller units on the south side and a separate warehouse to the east (Ref. 3). The site property is
bounded by commercial facilities to the north and south, by a greenway, cemetery and a national
military park to the east-northeast and by Battleground Road and by open parkland to the west
(Ref. 5) (see Figure 2).
Ms. Bramble
September 27, 2022
Page 2
C. E. Smith Company, Inc. (CES) operated at 3704 Old Battleground Road as a metal
stamping and fabricating facility from the 1960s until the 1980s. Battleground Storage LLC
(Battleground) purchased both properties in December 1981 and converted the southeastern
portion of the main structure into climate-controlled storage units. A dry-cleaning business
reportedly operated in the southwestern portion of the 3704 structure from the late 1980s until
1990. Both CES and the dry-cleaner reportedly used tetrachloroethene (PCE) and/or
trichloroethene (TCE) (Ref. 3). Both properties are currently owned by Battleground storage
LLC (Ref. 6). Portions of the northern property (3704) are currently leased to a graphics
company and a realtor, and contained a single apartment unit and storage compartments (see Fig
3). The southern property (3700) is developed as a self-storage facility (Ref. 5).
In 1982, the NC Division of Health Services (DHS) changed CES’s status under the
Resource Conservation and Recovery Act (RCRA), from generator to small generator. During a
subsequent 1982 DHS RCRA inspection, the facility vice president reported that the facility had
not generated any hazardous waste, but had requested small generator status in case of a future
need to manifest wastes (Refs. 7, 8). In 1989, the NC Hazardous Waste Management Branch
agreed to delete CES as a small quantity generator but the site retained its EPA ID number (Ref.
9). In 1990, CES, having relocated, requested and was granted deletion as a conditionally
exempt small quantity generator under RCRA (Refs. 10, 11). According to other sources,
however, hazardous waste manifests indicated that CES generated F002 halogenated solvent
waste, and that the dry cleaner on site used PCE (Ref. 12).
In January 2020, Battleground contractors conducted Phase I and Phase II environmental
site assessments (ESAs) as part of a planned property transaction. The assessments reportedly
identified significant releases of TCE at the site, including to soil and groundwater and to indoor
air at site structures. Battleground and their consultant notified the NC DEQ and completed
steps to enter into the NC Dry Cleaning Solvent Cleanup Act (DSCA) program. The DSCA
program investigated in part because of PCE detection potentially attributable to the former dry
cleaner. Beginning in February 2020, DSCA contractors conducted indoor air and sub-slab soil
gas investigations and subsequently installed a sub-slab depressurization system (SSDS) at 3704
Old Battleground Road (Refs. 4, 12).
On March 31, 2021, the US EPA and Battleground Storage, LLC. entered into an
ASAOC for a Time Critical Removal Action at the site. Battleground contractors performed
investigations to 1) evaluate and resolve deficiencies in the SSDS to further mitigate indoor air
TCE concentrations at the structure on 3704 Old Battleground Road; and 2) evaluate potential
human-health exposure risk within 1500 feet from the site. Sampling activity focused primarily
on 3704 Old Battleground Road, where suspected source areas were located and where
subsurface intrusion was identified (Ref. 3).
In early September 2022, AAA Storage Management 27, LLC submitted a Brownfields
Property Application for site redevelopment under the NC DEQ Brownfields program (Ref. 13).
Old Battleground Road TCE Site
NCD 044 513 307Preliminary Assessment
Ms. Bramble
September 27, 2022
Page 3
Previous Investigations:
Environmental Media Investigation:
In January 2020, as part of the Phase II ESA, Battleground contractors conducted direct
push technology (DPT) subsurface explorations at seven exterior locations at 3704 Old
Battleground Road. Groundwater sample results for TCE ranged from 18 to 3,270 micrograms
per liter (µg/L). The highest TCE concentration was in groundwater behind the building, near
the northeast corner of the property, along with trace concentrations of other chlorinated volatile
organic compounds (cVOCs). Limited soil sampling In January 2020 revealed TCE (up to 134
micrograms per kilogram [µg/kg]) (Ref. 12).
In April 2020, DSCA contractors collected four soil gas samples (SG-1 through SG-4)on
the property north of 3704 Old Battleground Road. Samples were trace or non-detect for TCE
and PCE (Ref. 12) (see Figure 3).
In June 2021, under the ASAOC, Battleground contractors conducted soil borings to
characterize the site’s geology and contaminant distribution. Ten monitoring wells were installed
on and directly south of 3704 Old Battleground Road. Groundwater sampling was conducted in
July 2021 to evaluate cVOCs in groundwater, to characterize the groundwater flow regime and
to evaluate effectiveness of natural attenuation as a potential remedy. Detected cVOCs included
TCE (up to 6000 micrograms per liter [µg/L]), PCE (up to 490 µg/L), cis-1,2-dichloroethene
(DCE) (up to 910 µg/L) and 1,1- and 1,2-dichlotoethane (DCA) (16 µg/L and 1.9 µg/L) (Ref. 3).
In July 2021, Battleground contractors used a membrane interface probe/hydraulic
profiling tool (MiHPT) to conduct sixteen subsurface explorations on and directly south of 3704
Old Battleground Road. The purpose of the MiHPT explorations was to locate primary source
areas, evaluate the lateral and vertical extent of cVOCs in soil gas, and evaluate the electrical and
hydraulic characteristics of the unconsolidated overburden Detected soil gas contaminants
included TCE (up to 290,000 micrograms per cubic meter [µg/m3]), PCE (1,400 µg/m3) and cis-
1,2-DCE (up to 9,000 µg/m3) (Ref. 3).
In late July 2021, Battleground contractors installed and sampled five outdoor soil gas
sampling probes on site to evaluate the potential for subsurface intrusion and the lateral extent of
cVOCs in soil gas on and directly south of 3704 Old Battleground Road. Detected cVOCs
included TCE (up to 130,000 µg/m3), PCE (up to 330 µg/m3) and cis-1,2-DCE (6,200 µg/m3).
Results, along with groundwater sampling and MiHPT data, were used to determine whether,
and where, additional off-property media sampling was needed, particularly to the south and
west of the site. Results indicated that contaminant concentrations in the above media were
minimal to non-detect along the southwestern margin of 3704 and 3700 Old Battleground Road,
increasing toward the east, especially near the northeast corner of the 3704 property (Ref. 3).
Old Battleground Road TCE Site
NCD 044 513 307Preliminary Assessment
Ms. Bramble
September 27, 2022
Page 4
In August and September 2021, Battleground contractors conducted iterative surface
water sampling on an unnamed tributary and creek that flowed north through the national
military park northeast of the site. Two out of nine samples contained TCE (up to 65 µg/L) and
cis,1,2-DCE (up to 2.3 µg/L) (Ref. 3).
Battleground contractors conducted a drinking-water well survey within a 1500-foot
radius of 3704 Old Battleground Road. The nearest confirmed historical water-supply well,
located in the military park approximately 1500 feet north-northwest of the site, was inoperative
and no longer use3d as a drinking-water source. The City of Greensboro supplies drinking water
to the park and all developed property within the 1500-foot radius (Ref. 3).
Results of the above investigations indicated that minimal potential for off-site exposure
to site contaminants existed via groundwater and surface water migration (Ref. 3).
Indoor Air Investigation and Mitigation:
In January 2020, Phase II ESA sampling at 3704 Old Battleground Road revealed that
indoor air concentrations of TCE (up to 467 µg/m3) exceeded the NC Division of Waste
Management’s residential and non-residential immediate action levels (IALs) of 2.1 and 8.8
micrograms/cubic meter (µg/m3), respectively. PCE concentrations (up to 18.9 µg/m3), exceeded
only the residential IAL of 8.3 µg/m3. In early February 2020, indoor air sampling by a DSCA
contractor confirmed TCE and PCE concentrations (up to 315 µg/m3 and 9.35 µg/m3) as well as
cis-1,2-dichloroethene (DCE) (up to 6.32 µg/m3), 1,1-DCE and 1,2-dichloroethane (DCA) (both
less than 1 µg/m3). Vinyl chloride was not detected. TCE was the primary driver of calculated
carcinogenic risk that exceeded 1.0E-04 and/or a non-carcinogenic hazard index that exceed 1.0
(Ref. 12).
In mid-February 2020, DSCA contractors conducted their initial sub-slab soil gas
sampling event at 3704 Old Battleground Road to identify potential subsurface cVOC source
areas. Out of 37 boreholes drilled through the foundation slab in the main building, fifteen were
selected for soil gas sampling based on initial photoionization screening results. Sampling was
performed using Summa canisters (Ref. 12) (see Figure 3).
Sub-slab soil gas samples from the main building contained TCE (up to 2,500,000 µg/m3),
PCE (up to 25,000 µg/m3), cis-1,2-DCE (up to 42,000 µg/m3), trans-1,2-DCE (up to 530 µg/m3),
1,1-DCE (up to 5,800 µg/m3), and 1,1-DCA (up to 580 µg/m3). Soil gas sampling results
indicated that highest contaminant concentrations existed primarily beneath storage units in the
eastern portion of the building (Ref. 12).
Old Battleground Road TCE SiteNCD 044 513 307Preliminary Assessment
Ms. Bramble
September 27, 2022
Page 5
In mid-February 2020, DSCA contractors conducted initial temporary mitigation
measures by deploying seven zeolite-carbon air treatment units (ATUs) in the 3704 main
building. The areas mitigated included the graphics company, as well as a moving company
(which occupied the building before the current real estate company) and an (unoccupied)
apartment that existed in the structure at that time. In addition, activated carbon filters were
installed in the main building’s HVAC systems. These initial mitigation measures reduced TCE
concentrations by approximately 60 to 80 percent, but not to levels less than the IALs (Ref. 12).
In mid-to-late February 2020, DSCA contractors pilot-tested a four-point SSDS inside the
main building at 3704 Old Battleground Road. Based on the results, the subsequent SSDS design
consisted of eight indoor 3-inch diameter PVC risers extending through the building foundation
slab and up to suction fans above rooftop level. In addition, DSCA contractors sealed all cracks
and conduit entry points visible in the foundation slab. By late March 2020, indoor air sampling
results indicated a 92 to 96 percent reduction in indoor air TCE concentrations (to a maximum of
7.14 µg/m3) in the three non-self-storage areas of the building. This reduction lowered risk levels
to less than risk based non-residential IALs but did not completely mitigate residential risk in the
(unoccupied) apartment unit. Indoor air TCE concentration (43.1 µg/m3) in the eastern indoor
storage portion of the main building remained above the non-residential IAL (Refs. 3, 12).
Results from the eastern portion of the main building interior indicated that deficiencies
in SSDS performance were attributable to openings in the floor slabs under the storage units
located there, and at interior joints where the foundation slab met load-bearing walls. Under the
ASAOC, targeted repairs were conducted at these locations (Ref. 3).
In late April 2020, DSCA contractors conducted sub-slab soil gas sampling at 5 locations
(SS-16 through SS-20) within a separate self-storage building to the east of the main building at
3704 Old Battleground Road (See Figure 3). Samples contained TCE (up to 54,000 µg/m3), PCE
(up to 820 µg/m3), cis-1,2-DCE (up to 1,300 µg/m3), trans-1,2-DCE (up to 37 µg/m3), 1,1-DCE
(up to 170 µg/m3), 1,1,1-TCA (up to 16 µg/m3) and 1,1-DCA (up to 71 µg/m3). Vinyl chloride
was not detected in any of the samples. Results indicated exceedance of carcinogenic risk and/or
hazard quotient for non-residential use at the east storage building. DSCA contractors noted that
the building was used only for storage and was not continuously occupied by workers, limiting
potential for indoor air exposure at the units. Similarly, the self-storage facility structures to the
south, at 3700 Old Battleground Road, were not evaluated because of their roll-up entrance door
design and minimal intervals of occupancy (Ref. 12).
Old Battleground Road TCE Site
NCD 044 513 307Preliminary Assessment
Ms. Bramble
September 27, 2022
Page 6
In June 2021, under the 2021 ASAOC, Battleground contractors enhanced the conceptual
site model (CSM) by conducting geophysical surveys of the structural foundation, a mass-
capture evaluation of the SSDS system and pressure field extension testing. The work included
obtaining temporary access to storage units that were in use at the time. Evaluation included
sub-slab soil gas and indoor air testing at two previously unevaluated exterior storage units
attached to the south side of the main building at 3704 Old Battleground Road (see Figure 3).
The sub-slab soil gas samples contained TCE (up to 830 µg/m3), PCE (up to 54 µg/m3) and cis-
1,2-DCE (up to 9 µg/m3). TCE (up to 0.3 µg/m3) was the only cVOC detected in the indoor air
samples. Petroleum-based volatile aromatic compounds were also detected, but were attributed
to storage of common household chemical products within the storage units. (Ref. 3).
In July 2021, Battleground contractors conducted indoor sir sampling at three locations
within the indoor storage areas in the eastern portion of the main building at 3704 Old
Battleground Road. Indoor TCE concentrations (maximum 6.5 µg/m3) were below the EPA
Removal Management Level (RML) and NCIAL of 8.8 µg/m3. Results indicated that the
targeted repairs to the floor slab and interior wall joints had improved the efficiency of the SSDS
in mitigating indoor air quality in that portion of the building. Follow up indoor air sampling in
September 2021 demonstrated that TCE concentrations (up to 2.3 µg/m3) in the three non-self-
storage areas of the building remained below the RML and NIAL (Ref. 3)
Groundwater Migration Pathway and Targets:
Guilford County, NC lies within the Piedmont Physiographic Province, and the site
location is within the far northwestern portion of the Carolina Slate Geotectonic Belt. Bedrock
geology in the site vicinity is mapped as granite, bordering on a metamorphosed complex of
felsic intrusive igneous rock. Within the Piedmont, the unconfined groundwater aquifer
comprises the saturated zone of fractured bedrock and overlying weathered saprolite (Refs. 14-
15).
Mapped soil unit beneath the site property is Cecil urban land complex (CfB). The typical
subsurface profile of the soil consists of 6 inches of sandy or silty loam, underlain by 34 inches
of clay, underlain in turn by 40 inches of clay loam and sandy loam. In urban land soils, the
natural soil profile has been disturbed by cutting, filling, grading or paving (Ref. 16).
Old Battleground Road TCE Site
NCD 044 513 307Preliminary Assessment
Ms. Bramble
September 27, 2022
Page 7
Site and local topography indicated the likelihood of a groundwater divide crossing the
site from southeast to northwest, with steeper slopes toward drainage features to the southwest
and northeast of the site properties. However, multiple lines of evidence indicate that a
northeasterly groundwater flow component is dominant beneath 3704 Old Battleground Road.
An approximately 4-foot decrease in groundwater elevation has been measured between the
parcel’s southern and western property lines and the parcel’s northeastern corner. When ten on-
property groundwater monitoring wells were sampled in 2021, TCE concentrations were highest
in groundwater beneath the site structure and in two outdoor monitoring wells to the northeast.
Similarly, TCE concentrations in outdoor soil gas samples, collected from 3704 and northern
3700 Old Battleground Road in July 2021, increased by several order of magnitude from the
western property lines to the northeast and east (Ref. 3).
The site is located within the Greensboro municipal boundary, and local residences and
businesses have access to municipal water. The municipal water source consists of surface water
intakes on Lake Higgins, Lake Brandt and Lake Townsend in northern Guilford County. No
private drinking water wells have been confirmed to operate northeast of the site, within the
anticipated direction of groundwater contaminant migration (Refs. 3, 17). The nearest public/
community groundwater source is located 2.57 miles northwest of the site (Ref. 18). Based on
the absence of proximal groundwater targets, the exposure hazard posed by the site’s
groundwater migration pathway appears to be minimal.
Surface Water Migration Pathway and Targets:
The ground surface in the contaminated portion of the site slopes generally to the
northeast. The probable point of entry (PPE) for site runoff and groundwater is at the beginning
of an unnamed tributary approximately 0.25 mile north-northeast of the site. The tributary flows
northeast for approximately 0.3 mile to join north-flowing Richland Creek. Richland Creek
continues 1.2 miles to become Richland Lake/Lake Jeanette, which in turn flows 1.8 miles to
Lake Townsend. From a 7.5-mile distance from the PPE, Reedy Fork Creek constitutes the
remainder of the 15-mile surface water migration pathway target distance limit (TDL) (Refs. 18,
19).
The nearest surface water intake for public supply is located on Lake Townsend
approximately 7.5 miles downstream from the PPE (Ref. 18). Recreational fishing is likely to
occur on Richland Lake/Lake Jeanette and Lake Townsend, downstream from the site. However,
the unnamed tributary and upper Richland Creek are located within a national military park,
where recreational fishing is unlikely to be permitted (Ref. 3). The nearest mapped wetland
interval is located on Richland Creek, approximately 1.45 miles downstream from the PPE. The
only additional wetland interval within the 15-mile TDL is located below Lake Townsend (Ref.
19).
Old Battleground Road TCE SiteNCD 044 513 307Preliminary Assessment
Ms. Bramble
September 27, 2022
Page 8
In late summer of 2021, TCE (up to 65 µg/L) and cis,1,2-DCE (up to 2.3 µg/L) were
detected in two out of nine surface water samples collected from the unnamed tributary
northwest of the site. The highest TCE concentration exceeded the (5 µg/L) EPA maximum
contaminant level (MCL), the (2.5 µg/L) 15A NCAC2B freshwater supply standard and the (30
µg/L) 15A NCAC2B fish consumption standard for surface water. No cVOCs were detected
farther downstream in Richland Creek, directly below the confluence of the two streams. Based
on this information and on limited surface water pathway targets, the exposure hazard posed by
the site’s surface water migration pathway appears to be minimal.
Soil Exposure and Subsurface Intrusion Pathways:
The site property is partially fenced and is mostly accessible, by vehicle or on foot. Most
of the properties’ land surfaces are covered by buildings or paved driveway/parking areas, except
for maintained lawn along the western edge. The properties to the immediate north and south of
the site are commercial. Open park land lies to the west across Old Battleground Road. The
paved Atlantic & Yadkin Greenway runs directly to the east-northeast, between the two site
parcels and the adjacent cemetery to the east. The closest individual residences are
approximately 500 feet to the south-southwest of Battleground Storage. No schools or day care
facilities exist in proximity to the site (Ref. 5; Figure 2).
Sub-Slab Soil Gas Sampling Results:
In February 2020, DSCA contractors collected sub-slab soil gas samples at fifteen
locations within four sections of the main building at 3704 Old Battleground Road. In April 2020,
DSCA contractors collected five additional sub-slab soil gas samples beneath a separate outdoor
storage building to the east of the main building. In June 2021, Battleground contractors
collected two sub-slab soil gas samples beneath two outdoor storage units attached to the south
side of the main building (Refs. 3, 12).
Soil gas samples from beneath the indoor storage section of the main building contained
TCE (up to 2,500,000 µg/m3), PCE (up to 25,000 µg/m3) and cis-1,2-DCE (up to 4,200 µg/m3).
A soil gas sample from beneath the sign company contained TCE (19,000 µg/m3), PCE (1,400
µg/m3) and cis-1,2-DCE (960 µg/m3). Soil gas samples from beneath the moving company (that
occupied the building at the time) contained TCE (up to 28,000 µg/m3), PCE (up to 5,500 µg/m3)
and cis-1,2-DCE (up to 110 µg/m3). Soil gas samples from beneath the single apartment in the
building contained TCE (700 µg/m3) and PCE (170 µg/m3). Soil gas samples from beneath the
outdoor storage building to the east contained TCE (up to 830 µg/m3), PCE (up to 54 µg/m3) and
cis-1,2-DCE (up to 9 µg/m3). Soil gas samples from beneath the southern outdoor storage units
contained TCE (up to 0.29 µg/m3) and PCE (0.1 µg/m3).
Old Battleground Road TCE SiteNCD 044 513 307
Preliminary Assessment
Ms. Bramble
September 27, 2022
Page 9
Maximum soil gas sample results from the three commercial/storage sections inside the
main building and from the eastern outdoor storage building exceeded the EPA Target Sub-
Slab/Near Source Vapor Intrusion Screening Levels (VISLs) for TCE (29.2 µg/m3) and PCE
(584 µg/m3). Results from the apartment also exceeded the VISL for TCE (Ref. 20).
Indoor Air Sampling Results:
In January 2020, as part of the Phase II ESA, Battleground contractors conducted their
initial indoor air sampling at 3704 Old Battleground Road. During the sampling event, one
sample was collected from each of the four sections of the building interior. The indoor air
sample from the indoor storage section of the building contained TCE (33.2 µg/m3), PCE (2.29
µg/m3) and cis-1,2-DCE (1.02 µg/m3). The indoor air sample from the sign company contained
TCE (467 µg/m3), PCE (5.28 µg/m3) and cis-1,2-DCE (13 µg/m3). The indoor air sample from
the moving company (that occupied the building at the time) contained TCE (246 µg/m3), PCE
(18.9 µg/m3) and cis-1,2-DCE (6.02 µg/m3). The indoor air sample from the single apartment in
the building contained TCE (148 µg/m3), PCE (10.2 µg/m3) and cis-1,2-DCE (3.49 µg/m3) (Ref.
12).
In early February 2020, DSCA contractors conducted the first of four indoor air sampling
events. Although the initial event took place prior to the initiation of indoor air mitigative
measures in the building, TCE, PCE and cis-1,2-DCE concentrations were generally reduced by
as much as half from the Phase II ESA results. The exception was the indoor storage section of
the building, where TCE, PCE and cis-1,2-DCE concentrations increased by up to a factor of ten.
During both sampling events, however, TCE results for all locations exceeded the EPA worker
indoor air regional screening level (RSL) of 3 µg/m3, while PCE results were less than the
worker indoor air RSL of 47 µg/m3 (Ref. 12)
In February and March 2020, during subsequent DSCA sampling events to monitor the
effectiveness of mitigative measures, indoor air cVOC concentrations progressively decreased in
the four sample areas. However, only the sign company indoor air TCE concentration (at 1.31
µg/m3) decreased to less than the worker RSL, and the indoor storage section TCE concentration
remained particularly elevated (at 43.1 µg/m3) (Ref. 12).
Following the additional mitigative measure of sealing floor cracks and wall joints in July
2021, Battleground contractors conducted indoor air sampling at storage units within the main
building. TCE concentrations ranged from 2.4 to 6.5 µg/m3 in the storage units. Battleground
contractors conducted indoor air sampling in the two commercial sections and the vacant
apartment on September 7, 2021. TCE concentrations ranged from 1.0 to 1.4 µg/m3 in the
commercial areas. TCE concentration in the apartment indoor air was 2.3 µg/m3. Three outdoor
air samples, collected directly outside the building on the two sampling dates, contained TCE
(0.68 to 1.8 µg/m3) and PCE (0.086 to 1.8 µg/m3), exceeding the residential(Ref. 3).
Old Battleground Road TCE SiteNCD 044 513 307Preliminary Assessment
Ms. Bramble
September 27, 2022
Page 10
Indoor air TCE concentrations in portions of the storage section continue to exceed the
worker RSL. However, such storage units are unlikely to be inhabited by workers on a regular
basis. Indoor air TCE concentrations in the other sections of the building are below the worker
RSL, but indoor air TCE in the (vacant) apartment continues to exceed the resident ambient air
RSL of 0.48 µg/m3 (Ref. 21).
When evaluated using the EPA Vapor Intrusion Screening Level Calculator, the above
indoor air cVOC results generated commercial carcinogenic risk ranges of 1.32 E-6 to 2.11 E-6,
and commercial non-cancer Hazard Quotients 0.178 to 0.719. The apartment TCE concentration
(2.3 µg/m3) generated a residential carcinogenic risk of 4.81 E-6 and a residential Hazard
Quotient of 1.1 (Ref. 20).
Results of recent historical state and private contractor groundwater, surface water and
soil gas investigations indicate that cVOC-contaminated groundwater beneath the site parcels has
migrated to the northeast, toward a cemetery and national military park with no inhabited
structures. Site investigations have addressed current potential for subsurface intrusion at the
commercial facility located directly north of the site property line, supported by the fact that TCE
has apparently migrated farther to the northeast and intermittently discharged to surface water.
In the main building at 3704 Old Battleground Road, worker occupation at the indoor storage
sections of the building is anticipated to be minimal. The southern site property at 3700 Old
Battleground Road is developed entirely as a self-storage facility. The facility’s business office is
located at the southwest corner of the property, distant from areas of known subsurface
contamination (Refs. 3, 5, 12). Therefore, minimal potential exists for subsurface intrusion to a
regularly inhabited structure on that property.
Based on the above information, the exposure hazard posed by the site via the soil
exposure and subsurface intrusion pathways appears to have been minimalized by mitigative
actions taken to date. Additional measures will likely be undertaken in the event that the site is
redeveloped under the NC Brownfields program.
Air Migration Pathway:
Ambient outdoor air samples were collected along the exterior walls at 3704 Old
Battleground Road as part of site investigation under the 2021 ASAOC. The samples contained
TCE concentrations exceeding the residential RSL (Refs. 3, 21). The detections may have
resulted from multi-point rooftop venting of the SSDS at the single-story building. The area
surrounding the building is commercial or open outdoor space with transient human occupation.
Therefore, the exposure hazard posed by the site via the air migration pathway appears to be
minimal.
Old Battleground Road TCE Site
NCD 044 513 307Preliminary Assessment
Ms. Bramble
September 27, 2022
Page 11
Preliminary Assessment Conclusions:
DSCA and ASAOC final investigative reports were submitted in July 2020 and
November 2021, respectively. The final ASAOC report proposed completion and execution of a
work plan for continued operation and maintenance of the SSDS at 3704 Old Battleground Road,
in support of SSDS performance (Refs. 3, 12).
In early September 2022, as part of purchase of the site properties from Battleground
Storage LLC, AAA Storage Management 27, LLC (unconnected with Battleground) submitted a
Brownfields Property Application (BPA) for site redevelopment under the NC DEQ Brownfields
program, referencing the Battleground-funded ASAOC investigation. The site is currently under
review for Brownfields eligibility, for continued use for office space, storage, retail and parking
(Refs 13, 22). In the event that the site qualifies for Brownfields program oversight, additional
mitigation measures and land use restrictions will likely be required.
Based on current site conditions and (pending) Brownfields status, the Old Battleground
Road TCE site is recommended for No Further Remedial Action Planned (NFRAP) designation
under CERCLA. If you have any questions, please contact me at [e-mail] or
[phone].
Sincerely,
_________________________ _______________________
Stuart F Parker, Hydrogeologist Qu Qi, Head
Federal Remediation Branch Federal Remediation Branch
NC Superfund Section NC Superfund Section
Attachments
cc: File
Janet Macdonald – letter only
Old Battleground Road TCE SiteNCD 044 513 307Preliminary Assessment
Old Battleground Road TCE site
NCD 044 513 307
Preliminary Assessment References:
1)US EPA 40 CFR Part 300, Hazard Ranking System, Final Rule, Federal Register Volume 55,
No. 241 Part II, December 14, 1990.
2)United States Environmental Protection Agency, Superfund Chemical Data Matrix,
Appendix B, Updated July 2022. Query at: https://www.epa.gov/superfund/superfund-
chemical-data-matrix-scdm-query
3)Geosyntec Consultants of NC, PC, Raleigh, NC: Final Report, Old Battleground Road TCE
Site, Greensboro, North Carolina, Docket No. CERCLA-04-2021-2501. November 2021.
4)EPA Region 4 Emergency Response and Removal Branch: “Pollution/Situation Report
(POLREP) No 2 (Final), Old Battleground Road TCE”. March 22, 2022.
5)Google Maps https://www.google.com/
6)Guilford County, NC Geographic Information Service (GIS),
https://gisdv.guilfordcountync.gov/guilford/
7)Strickland, O. W., NC Division of Health Services: Letter to C. E. Smith Company, Inc. re:
Change in RCRA Classification. June 4, 1982.
8)NC Division of Health Services: RCRA Inspection Report, C. E. Smith, Company, Inc. May
27, 1982
9)Edwards, R. J., NC Division of Health Services: Letter to C. E. Smith Company, Inc. re:
Change in RCRA Classification. July 27, 1989.
10)C. E. Smith Company, Inc. : Application for Change in Classification under RCRA. August
28, 1990.
11)Edwards, R. J., NC Department of Environment, Health and Natural Resources: Letter to C.
E. Smith Company, Inc. re: Change in RCRA Classification. August 29, 1990.
12)Hart & Hickman, Inc., Raleigh, NC: Vapor Intrusion Assessment and Mitigation Report, Fox
Cleaners and Laundry, 3704 Old Battlefield Road, Greensboro, Guilford NC. DSCA Site
Identification No. DC410058, H&H Job No. DSO-160. July 10, 2020.
13)Chakravarty, Aditi, NC Department of Environmental Quality: Electronic communication re:
Notification of Application to Brownfields Program. August 24, 2022.
14)Carpenter, P. Albert: Geologic Map of Region G, North Carolina, US Geological Survey
Regional Geology Series 2, 1982.
Old Battleground Road TCE SiteNCD 044 513 307
Preliminary Assessment
15)Heath, Ralph, Basic Elements of Groundwater Hydrology with Reference to Conditions in
North Carolina, Parts I-II, US Geological Survey Water Resources Investigations Open-File
Report 80-44, 1980.
16)US Department of Agriculture Web Soil Survey:
https://websoilsurvey.sc.egov.usda.gov/App/WebSoilSurvey.aspx. September 14, 2022.
17)“City of Greensboro, North Carolina Annual Drinking Water Quality Report, Water System
Number 02-41-010”. 2019.
18)NC DEQ, DWM, Superfund Section, Inactive Hazardous Sites Branch (IHSB) ARC GIS
Map Viewer: https://ncdenr.maps.arcgis.com/apps/webappviewer/index.html
19)US Fish and Wildlife Service National Wetland Inventory on line Wetland Mapper
https://www.fws.gov/wetlands/data/mapper.html Printout Date: September 14, 2022.
20)US EPA Vapor Intrusion Screening Level Calculator Output. September 27, 2022.
https://epa-visl.ornl.gov/cgi-bin/visl_search
21)US EPA Resident and Worker Ambient Air Regional Screening Levels (RSLs):
https://www.epa.gov/risk/regional-screening-levels-rsls-generic-ta
22)Chakravarti, Adidi, NC Brownfields Program: Electronic communication with Stuart Parker,
NC Superfund Program re: Old Battleground TCE site Brownfields Application and attached
Application Form. September 26, 2022.
Old Battleground Road TCE SiteNCD 044 513 307Preliminary Assessment
Old Battleground Road TCE Site
NCD 044 513 307
Greensboro, Guilford County, NCGuilford County
SITE
Fig. 1:
Site Location Plan
Stuart F Parker, NC DEQ
9/16/2022
Fig. 2: Site Plan
Stuart F Parker,
DWM Superfund Section,
9/16/2022.
Base map from Google Earth Pro
Old Battleground
Road TCE Site
NCD 044 513 307
Greensboro,
Guilford County, NC
3704
3700
Commercial
Properties
Commercial
Properties
Residential
Properties
Cemetery/
Parkland
Parkland
IA-2 (MARATHON)
IA-3 (APARTMENT)
IA-1 (SIGN CO.)
IA-5 (STORAGE)
IA-4 (STORAGE)
EXTERIOR
STORAGE UNITS
EXTERIOR
STORAGE UNITS
GATE CITY
SIGNS & GRAPHICS
MARATHON MOVING
COMPANY, INC.
FORMER APARTMENT
(VACANT)
BATTLEGROUND
STORAGE, LLC
SG-1
SG-2
SG-3
SG-4
SS-16
SS-17
SS-18
SS-19
SS-20
SS-12
SS-9
SS-5
SS-10SS-11
SS-15
SS-14
SS-13
SS-8 SS-7 SS-6
SS-4
SS-1
SS-3SS-2
REVISION NO. 0
ATTACHMENT NO. 13
LEGEND
SOURCE PROPERTY BOUNDARY
PARCEL BOUNDARY
WALL BETWEEN TENANT SPACES
INTERIOR TENANT SPACE WALL
INDOOR AIR SAMPLE LOCATION
SOIL GAS MONITORING POINT
SUB-SLAB GAS SAMPLE LOCATION
3921 Sunset Ridge Road, Suite 301
Raleigh, North Carolina 27607
919-847-4241(p) 919-847-4261(f)
License # C-1269 / #C-245 GeologyOLD BATTLEGROUND ROADJOB NO. DS0-160
DATE: 7-9-20
FOX CLEANERS AND LAUNDRY
DSCA ID: DC410058
3704 OLD BATTLEGROUND ROAD
GREENSBORO, NORTH CAROLINA
VAPOR INTRUSION SAMPLE LOCATION MAP
\\HHFS01\MasterFiles\AAA-Master Projects\DSCA - DS0\DS0-160 Fox Cleaners and Laundry\Reports\2020 VI Assess & Mitigation\Figures\DC410058_20200707.dwg, ATT 13, 7/9/2020 12:22:54 PM, SVincentREAL ESTATE SOLUTIONS
(FORMER)
(FORMER)
(FORMER
DRY
CLEANER)Figure 3: Site Detail
BATTLEGROUND STORAGE LLC
3700 OLD BATTLEGROUND ROAD
STORAGE
UNITS
EXTERIOR