Phase I ESAWithersRavenel
Our People. Your Success.
PHASE I
ENVIRONMENTAL SITE ASSESSMENT
S. T. Wooten/Invista Mine Expansion Property
±80.43-Acre Site
US Highway 421
Wilmington, New Hanover County, North Carolina
WR Project No. 02130008.01
Prepared for:
S.T. Wooten Corporation, Inc.
P.O. Box 2408
Wilson, NC 27894
Prepared by:
WithersRavenel
115 Mackenan Drive
Cary, North Carolina 27511
North Carolina Firm License No. C-0832
July 14, 2016
WithersRavenel
Our People. Your Success.
115 MacKenan Drive | Cary, NC 27511
t: 919.469.3340 | f: 919.467.6008 | www.withersravenel.com | License No. C-0832
Cary | Greensboro | Pittsboro | Raleigh | Wilmington
July 14, 2016
Attn: Brian F. Gurganus
Vice President
Reference: Phase I Environmental Site Assessment
S. T. Wooten/Invista Mine Expansion Property
±80.43-Acre Site
US Highway 421
Wilmington, New Hanover County, North Carolina
WR Project No. 02130008.10
Mr. Gurganus:
WithersRavenel (WR) has completed the authorized environmental evaluation at the above referenced
property. The enclosed report presents the findings and recommendations of WR's assessment of existing
and past environmental conditions at the site. If changes in conditions or different conditions from those
detailed in this report are encountered, we request that we be contacted so that the change in conditions
can be properly reviewed and our report amended accordingly.
Sincerely
WithersRavenel
Christopher Fay
Project Geologist – Environmental Professional
R. S. (Butch) Lawter, Jr., P.E.
Director of Environmental Services
S. T . Wooten Corporation, Inc.
P.O. Box 2408
Wilson, NC 27894
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±80.43-acre S. T. Wooten/Invista Mine Expansion Property WR No. 02130008.10
Phase I Environmental Site Assessment May 2016
1
1.INTRODUCTION
1.1. PURPOSE
This Phase I Environmental Site Assessment (ESA) was requested by the S.T. Wooten Corporation, Inc.,
herein referred to as the Client, to identify, to the extent feasible, recognized environmental conditions
(RECs) in connection with the subject property.
1.2. SCOPE OF SERVICES
WithersRavenel (WR) has performed a Phase I ESA for a ±80.43-acre site located approximately one mile
northwest of the intersection of Sutton Lake Road and US Highway 421 in Wilmington, New Hanover
County, North Carolina (Figure 1). According to New Hanover County GIS records, the subject property is
part of a 1,044.68-acre parcel owned by Invista S.A.R.L.
See Section 4.3.1 for information regarding past and present ownership records for the subject property.
WR understands that a Phase I ESA has been authorized as part of a potential property transaction between
Invista and S.T. Wooten Corporation. The land is being acquired by S.T. Wooten Corporation to mine sand
that will be used in the manufacturing of asphalt and concrete, and as beneficial fill for construction
projects..
The Phase I ESA performed by WithersRavenel included a site inspection, historical research, municipal
research, and a database search for the above-referenced site. The Phase I ESA was completed in general
accordance with the guidelines set forth in Standards and Practices for All Appropriate Inquiries (Title 40 of the
Code of Federal Register (CFR), Part 312); Standard Practice for Environmental Site Assessments: Phase I
Environmental Site Assessment Process (American Society for Testing and Materials (ASTM) Standard E-1527-
13); and WithersRavenel’s Standard Contract Conditions for Engineering Services. Distances for vapor
encroachment screening of the site were generally followed in accordance with the guidelines set forth in
ASTM E2600-10 “Standard Guide for Vapor Encroachment Screening on Property involved in Real Estate
Transactions” or the Buonicore Methodology (See Section 8). WithersRavenel has used these guidelines to
serve as a baseline for customary standards of environmental site assessments and to create a, standardized
environmental assessment report.
Non-Scope Considerations
This report represents WithersRavenel’s efforts to document the recognized environmental conditions on
the site and surrounding area that may adversely impact the subject site. However, the ASTM E 1527-13
establish standard practice also identifies environmental issues or conditions at a property that the Client
may wish to assess in connection with the subject property that are outside the scope of this practice (non-
scope considerations). The standard practice states that some substances may be present on a property in
quantities and under conditions that may lead to contamination of the property or nearby properties but are
not included in CERCLA’s definition of hazardous substances or do not present potential CERCLA liability.
Assessment of such non-scope considerations is not required for appropriate inquiry as defined by this
practice. Therefore, the Phase I investigation does not include inspection for items excluded by the ASTM E
1527-13 standards such as asbestos-containing materials, biological agents, cultural and historic resources,
ecological resources, endangered species, health and safety, indoor air quality unrelated to releases of
hazardous substances or petroleum products into the environment, industrial hygiene, lead-based paint,
copper or lead in drinking water, mold, radon, regulatory compliance, wetlands, and high-voltage power
lines. No implication is intended as to the relative importance of inquiry into such non-scope considerations,
and this list is not intended to be all-inclusive. All conclusions made in this report are based upon the
assessment performed by WithersRavenel and are subject to the service constraints presented below.
1.3. LIMITATIONS AND EXCEPTIONS
This report presents the findings of WithersRavenel's assessment of existing and past environmental
conditions at the site. Appropriate inquiry of information was utilized for this Phase I Site Assessment and
included:
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Phase I Environmental Site Assessment May 2016
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A site reconnaissance,
A historical source review that included aerial photographs, city directory search, recorded land
title records, and available fire insurance maps,
A Federal and State records review through EDR, Inc. (Please see the disclaimer on page 1 and
Section 4.1, of this report, for limitations of the EDR Report), and
Interview with an owner representative and individuals familiar with the subject site.
Appropriate inquiry does not mean an exhaustive assessment of the property. At the time of WRs site
reconnaissance all areas of the subject property were accessible.
This environmental site assessment cannot entirely eliminate uncertainty regarding the potential for RECs
in connection with the property. Performance of a Phase I ESA in accordance with ASTM E 1527-13 is
intended to reduce, but not eliminate, uncertainty regarding the potential for RECs in connection with a
property based on information obtained within reasonable limits of time and cost. There is always the
possibility/risk that sources or potential sources of environmental impacts have not been identified due to
discrepancies such as, but not limited to, the inaccuracies of the available records, environmental
incidents/RECs not being disclosed, or the limitations of the survey/assessment. If conditions at the site
change or additional information becomes available which would materially affect the nature of the report,
we request that we be contacted so that any change in conditions can be properly reviewed and our report
amended accordingly.
This Phase I ESA does not, by itself, qualify the purchaser for CERCLA liability protection. The purchaser of
the site may have continuing obligations after the purchase.
1.4. SPECIAL TERMS AND CONDITIONS
Site information and materials were obtained by WR through review of public files. The resulting report is
provided for sole use by S. T. Wooten Corporation on the project for which it was prepared. Use of this
report by any third parties is at the sole risk of S. T. Wooten Corporation, and WR disclaims any such third
party use of the report.
Draft/Preliminary Findings: If the report is stamped “DRAFT” or is identified as preliminary, the following
constraints apply: The Draft Report was prepared by WithersRavenel at the specific request of a client. The
information and findings provided in the Draft Report are not WithersRavenel’s final conclusions and
recommendations, but merely basic information requested by the client upon which the client may draw its
own conclusions. Client agrees that WithersRavenel shall not be liable for any claims, loss, damage, or
expenses incurred by the Client or others arising out of the use of, or reliance on, any information contained
with the Draft Report.
Report Purpose: The purpose of this report is as described in the Introduction of this report. The scope and
level of services provided were determined based on the stated purpose. If the purpose for which the report
is to be used, or the proposed use of the site changes, this report is no longer valid and use of this report by
the Client or others without WithersRavenel’s review and written authorization shall be at the user’s sole
risk. If review of this report is required by WithersRavenel after its date of submission, WithersRavenel
shall be entitled to additional compensation at WithersRavenel’s existing rates or such terms as agreed to
between WithersRavenel and the Client.
Scope of Services: Observations and conclusions provided in this report are based solely on the Scope of
Services between the Client and WithersRavenel and summarized in the Introduction of this report. No
additional observations, investigations, studies, or testing not specifically stated in the Scope of Services
have been performed by WithersRavenel. WithersRavenel shall not be liable for the existence of any
condition, the discovery of which required the performance of services not authorized under the agreement.
Unless specified in the Introduction of this report, WithersRavenel did not evaluate the presence of
asbestos-containing materials, biological agents, cultural and historic resources, ecological resources,
endangered species, health and safety, indoor air quality unrelated to releases of hazardous substances or
petroleum products into the environment, industrial hygiene, lead-based paint, copper or lead in drinking
water, mold, radon, regulatory compliance, wetlands, and high-voltage power lines.
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±80.43-acre S. T. Wooten/Invista Mine Expansion Property WR No. 02130008.10
Phase I Environmental Site Assessment May 2016
3
Time: Technology, economic conditions, site variations, or regulatory provisions may change over time and
render the report inaccurate. If review of this report is required by WithersRavenel after three months
from its date of submission, WithersRavenel shall be entitled to additional compensation at
WithersRavenel’s existing rates or such terms as agreed to between WithersRavenel and the Client.
Conclusions: The conclusions stated in this report are based upon observations of existing physical and/or
economic conditions; WithersRavenel’s interpretation of site history and site usage information;
information provided by the Client; and information and/or analyses provided by independent testing and
information services or laboratories upon which WithersRavenel is entitled to reasonably rely.
WithersRavenel is not authorized and did not attempt to independently verify the accuracy or
completeness of information or materials received from third parties during the performance of the Scope
of Services associated with this report. WithersRavenel shall not be liable for any conditions, information,
or conclusion, the discovery of which required information not available or independent investigation of
information provided to WithersRavenel, unless otherwise indicated. Any site drawing(s) provided within
this report is not meant to be an accurate base plan, but is used to present the general, relative locations of
features on, and surrounding, the site.
1.5. RELIANCE
This report has been prepared exclusively for the Client. Except for S. T. Wooten Corporation, no other
party is entitled to rely on the conclusions, observations, specifications, or data contained therein without
the express written consent of WR. This report has been prepared pursuant an agreement between the
Client and WR. All uses of and reliance upon this report are subject to, and deemed acceptance of, the
conditions and restrictions contained herein.
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±80.43-acre S. T. Wooten/Invista Mine Expansion Property WR No. 02130008.10
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2. SITE DESCRIPTION
2.1. METHODOLOGY AND LIMITING CONDITIONS
On June 27, 2016, WR performed a reconnaissance of the subject property that involved traversing the site
and observing adjacent properties. Photographs taken document features and materials observed during
site reconnaissance activities, where possible. A photographic essay has been included in the Appendix.
See Section 1.3 for a discussion of limitations encountered during the completion of the Phase I ESA site
reconnaissance. The site reconnaissance was performed to the extent possible within the means of time,
cost, and safety.
2.2. SITE OPERATIONS, PROCESSES, AND EQUIPMENT
The subject property is a small portion, approximately 80.43 acres, of a lager 1,044 acre property which is
home to the Invista chemical manufacturing facility (aka Hercofina, Cape Industries, Hoechst Celanese
Polyester Int., KoSa Facility, Wilbara). The 1,044 acre property is divided into sections which include the
plant process area, spray fields, tank farm, sludge lagoon, 001 outfall area, north property, east property,
potable well field, west production field, south production field, and inactive landfill. The plant process area
was built on the northeast portion of the property in the late 1960’s and has an extensive history of point
source contamination to soil and groundwater. The subject property is part of the west production field
which is used for harvesting groundwater for the production plant and is located in the northwest portion of
the property, approximately 1,100 feet from the plant process area.
Category Site Features Observed
Residential
Agricultural
Industrial X
Manufacturing
Commercial
Dry Cleaning
Fueling Systems
Automotive Repair
Paint Booths
Elevators
Waste Water Treatment
Utilities
Heating & Cooling Systems
Municipal Water
Municipal Sewer
Private Water Supply Wells X
Private Septic Systems
Municipal Trash Services
Sumps, Cisterns, Catch Basins
Floor Drains
Pad or pole-mounted transformers X
Other PCB Equipment
Oil & Hazardous Materials
Storage and Use
Underground Storage Tanks (USTs)
Aboveground Storage Tanks (ASTs)
Drums, barrels, and/or containers ≥ 5-gallons
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Category Site Features Observed
Oil/Water Separators
Underground Hydraulic Lifts
Emergency Generators
Releases or Potential Releases
Stressed Vegetation
Stained Soils
Trash, Debris, and/or other waste materials
Dumping or Disposal Area
Construction debris, fill dirt X
Petroleum or Chemical Odors
Site Features
Groundwater Monitoring Wells X
Pits, Ponds, or Lagoons
Storm water Retention Ponds (BMPs)
Utilities
Local utility companies provide electrical services to the subject property. There are no permanent
structures located on the subject property. Six production wells were observed throughout the subject
property; four abandoned and two operating all of which are part of the west production field (see Figure 2).
During historical research of the subject property, it was revealed that the underlying aquifer appears to
exhibit above normal chloride levels. This is documented in a lawsuit filed in the 1980’s between Invista and
the Duke Energy L.V. Sutton Electric Plant (the western adjacent property) regarding the source of the high
chloride levels. During a Phase I ESA completed on the property that was part of the west production field
in 2013 by WR, Invista personnel revealed the water that is harvested from the west production and
potable fields continue to exhibit high chloride levels. WR considers the potential for high chloride levels in the
production wells to be a REC to the subject property and sampling of the underlying aquifer should be conducted.
Mr. Randolph indicated that schematics for the product wells indicate the underground pipe used to
transfer water from the well field to the plant is designated as 921CA, Transite pipe. The Transite Pipe is a
cement/asbestos composite. WR considers the presence of asbestos on the subject property to be an REC
Approximately 15 pole-mounted transformers were observed throughout the subject property. None of
the observed transformers were marked with a blue sticker indicating their contents were free of PCB
containing oils. Additionally, the site manager for Invista, Mr. Jeff Randolph, revealed that all of the
transformers on the subject property were installed prior to 1979, thus, are suspected to contain PCB oil.
However, all the transformers observed were in good condition with no indication of leakage such as
stressed vegetation or staining observed on the transformers or ground surface in the vicinity of the
transformers. WR considers the presence of PCB containing material on the subject property to be an REC.
Releases or Potential Release
Trash and debris was noted in the northwest and the southeast corner of the subject property. The debris in
the northwest corner of the subject property consisted of ply wood and roof shingles. The debris appeared
to have been placed onsite by trespassers and did not appear to have been buried. In the southeast corner
of the property, discarded utility poles were lying in a pile. All items observed were inert and do not appear
to pose an environmental threat to the subject site.
Site Features
Several groundwater wells were also observed on the subject property. The onsite groundwater wells are
part of a groundwater monitoring system related to the groundwater contaminant plume emanating from
the plant production area. Several groundwater assessments performed at the Invista Plant indicated a
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release of three compounds of concern, which include 1,4 dioxane, p-xylene and para-cymene (4-
isopropyltoulene). Mr. Randolph, revealed that historic analytical results have reported the presence of 1,4
dioxane in several of the groundwater monitoring wells on the subject property. WR considers the potential
for the presence of 1,4 dioxane in the groundwater monitoring wells to be a REC to the subject property and
sampling of the underlying aquifer should be conducted.
During the site reconnaissance, WR observed three deep groundwater monitoring wells associated with the
waste injection well network. As part of the initial waste management plan, the facility installed and
attempted to dispose of treated waste water in an injection well system. Initially, the system was made up of
six wells, one injection well and five observation wells. The injection well was installed to a total depth of
1,000 feet BGS (the Cape Fear Aquifer). Four of the observation wells were installed within the injection
zone while one was installed to a depth of 700 feet BGS (the Blackcreek Aquifer). Over a four year period,
the injection well developed leaks approximately 700 feet BGS due to operating the system beyond its
pressure capacity. Therefore, a replacement injection well and observation wells were installed. However,
the injection plan proved to be unsuccessful. Therefore, the use of the injection wells was discontinued in
1972. Since the injection activities ceased, several assessments have been performed. During the most
recent sampling event in 2010, groundwater samples were collected from the 700 and 1000 foot aquifers.
Historical laboratory results showed a significant improvement in water quality; however, waste material
continues to persist in both the 700 foot and 1000 foot aquifers. Based on the future use of the property, WR
does not consider the observations wells that are part of the waste injection well network to be an REC. However,
the wells will need to be properly abandoned.
2.3. DESCRIPTION OF STRUCTURES
At the time of WR’s site visit, no structures were observed on the subject property.
2.4. CURRENT USES OF ADJOINING PROPERTIES
The subject property is located in an industrial setting. The property abuts the Duke Energy L.V. Sutton
Electric Plant Property to the west. The coal ash impoundment ponds are located on the Duke Energy L.V.
Sutton Electric Plant property approximately 1500 feet southwest of the subject property. Immediately to
the south is the S. T. Wooten Facility. A concrete manufacturing plant is on the northern adjacent property.
The eastern adjacent properties are undeveloped woodland that is used as water production fields for
Invista.
The Duke Energy L.V. Sutton Electric Plant is located approximately 4,000 feet to the southwest of the
subject property. Since 1954, the plant has produced electricity for the surrounding area by using
bituminous coal for fuel. As a result, the ash from coal burning is stored in an ash impoundment that is
located on the northern extremes of the property.
As part of the North Carolina Coal Ash Management Act (CAMA), Syn Terra completed a Comprehensive
Site Assessment (CSA) Report in August 2015 related to the Sutton Lake Coal Ash Impoundment. The
report explains that the ash management consisted of three areas, the FADA, the 1971 basin, and the 1984
basin. The assessment activities in these areas involved the sampling of groundwater monitoring wells
installed in the coal ash, hydraulically down-gradient and hydraulically up-gradient from the impoundments.
Data was compared from up-gradient or background to wells installed in the coal ash and hydraulically
down-gradient wells to discern between naturally occurring or background levels of contaminants and
contaminants leaching from the coal ash. Analytical results for groundwater samples collected from the
groundwater monitoring well network identified the following contaminants of concern:
Arsenic
Barium
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Boron
Cobalt
Iron
Manganese
Selenium
Thallium
Vanadium, and
Total dissolved Solids (TDS)
However, in comparison to the background, coal ash, and down-gradient groundwater monitoring wells, Syn
Terra concluded that not all of the identified constituents could be attributed to the presence of the coal
ash. Based on the presence of iron, manganese, and vanadium in background wells, it can reasonably
assumed that the presence of these contaminants in the aquifer system could not be solely attributed to the
coal ash impoundments. Moreover, contaminants cobalt and thallium were not reported in water samples
collected from the coal ash wells and therefore, could be attributed to natural sources. Based on the data
collected during the CSA, Syn Terra observed that boron was present in the coal ash; however, was not
present in the shallow background wells and is present in decreasing concentrations in wells down-gradient
from the ponds. Therefore, the presence of boron is a good indicator of the migratory pattern of the
contaminant plume emanating from the coal ash impoundment. Based on the presence of boron in the
groundwater monitoring well network, it would appear that the contaminant plume has migrated offsite to
the east, on to the S. T. Wooten property. Groundwater investigations reveal a groundwater flow in the
vicinity of the ash ponds to be radial with flow directions towards the northeast, east and southeast.
It should be noted that a remedial strategy has been proposed for the coal ash impoundments. Firstly, Syn
Terra has recommended that the coal ash be excavated and removed from the impoundments. Secondly,
Syn Terra recommended the installation and operation of 12 extraction wells along the eastern property
boundary shared with S. T. Wooten. WR considers the presence of the observed groundwater monitoring wells
and documented concentrations of boron in groundwater on and off the subject property as a REC and sampling of
the underlying aquifer should be conducted.
A CSX railroad and rail car transfer area is located along the eastern property boundary of the subject
property. During the 2013 Phase I ESA competed on the southern adjacent property by WR, Invista
personnel indicated a rail car derailment incident occurred, however, none of the rail car’s contents were
released. Mr. Randolph, the current site manager at Invista, indicated that he was not aware of any
incidents involving releases from rail cars in the railroad car transfer area. In addition, Mr. Pidgen of the
NHC Fire stated he has no recollection of any reported environmental incidents (leaks, spills or dumping of
petroleum liquids or hazardous substances) on the railroad property. However, he is aware small brush fires
that have occurred in the railroad car transfer area due to sparks from the rail cars. However, all of the fire
were on the railroad property and quickly extinguished. WR considers the potential for release from the rail cars
an REC and sampling of the underlying aquifer should be conducted.
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±80.43-acre S. T. Wooten/Invista Mine Expansion Property WR No. 02130008.10
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3. USER-PROVIDED INFORMATION
The following table summarizes information provided to WR by the Client during completion of this report.
User Provided Information Provided Not Provided Discussed Below
Title Records X
Environmental Liens X X
Historical Reports X
Client/Owner Questionnaire X
Purchase Price & Fair Market Value
Questionnaire X
Site Plans X
Environmental Liens And Activity And Use Limitations
At the time of this report, the client’s attorney did not complete a search for environmental liens. However,
WR observed no liens on file in the brief review of available deeds at the New Hanover County offices.
Furthermore, no on site environmental incidents were identified during the records review. As such, WR
does not expect that environmental liens or activity and use limitation controls will be present for this site.
See Sections 6 and 7 for more information and WR’s conclusion on this data gap
The results of a formal lien search should be added to this report when available to formally satisfy the AAI
requirements. This information should be completed along with title work for the property as typically
coordinated by your real estate attorney. If any environmental liens and AULs against the property are
discovered, this information should be provided to WR prior to any transfer of this property so that we may
make a proper review and issue an amended letter accordingly. If no environmental liens or AULs are
discovered, the letter titled “Title and Judicial Records Review for Environmental Liens and Activity and Use
Limitations” provided by WR should be filled out completely and placed inside the cover to accompany this
report as an attachment.
Due to the current condition of the Invista property, land restrictions have been implemented on property
that is sold in the west production field. Firstly, the property cannot be used for residential purposes.
Additionally, no more than 35,000 gallons of groundwater per day can be removed from the property unless
the removal of the groundwater is in connection to sand mining and is returned to the mine pit upon
completion. Additionally, sulfur dioxide emissions will not exceed 27.2 tons per year.
Historical Reports
No Historical reports on the subject property were provided to WR by Invista, the current property owner.
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4. RECORDS REVIEW & HISTORICAL USE INFORMATION
4.1. LOCAL STATE AND FEDERAL ENVIRONMENTAL REGULATORY AUTHORITIES
AND DATABASES
Through Environmental Data Resources, Inc. (EDR), an environmental database search firm, WR reviewed
files and databases of the North Carolina Department of Environment and Natural Resources (NCDENR)
and the United States Environmental Protection Agency (EPA) to determine if either agency has been
involved in any regulatory activities at or in the vicinity of the site. Facilities that treat, store, generate,
transport, or dispose of hazardous substances or petroleum products and any incidents of leaks, spills and
dumping of hazardous substances or petroleum products may be found in one or more government listings.
A portion of the EDR report contains a section titled "Orphan Summary" whereby sites with registered
USTs, leaking USTs, landfills, environmental violations, etc. that have not been properly mapped by EDR are
listed. During completion of the Phase I ESA, WR observed the subject property and immediately adjacent
properties. The subject property and surrounding properties did not match any of the sites listed on the
Orphan Summary. WR did not, however, verify the actual location of each site appearing on the Orphan
Summary or find sites with improper or vague information provided in the Orphan Summary as this was not
considered reasonably ascertainable. In addition, WR cannot verify sites improperly mapped by the
individual government agency outside of the established search radius or beyond the adjacent properties of
the site as this is not considered reasonably ascertainable in the context of time and budget required to
complete the Phase I ESA.
Additional sites listed in the EDR Report and not discussed in the paragraphs below were deemed to be
either located beyond the search distances set forth in the ASTM E-1527-13 standard practice for Phase I
ESAs or to be listed under databases or for issues that do not represent a threat to the environmental
quality of the subject property under ASTM E-1527-13 standard practice. The sites can be viewed in the
EDR report provided in the Appendix. Details of the reported are noted below.
It should be noted that though distances for the identified regulatory sites are provided by EDR, these
distances are estimates based on the approximated locations of the identified sites by EDR’s mapping
software. When necessary and feasible, WR uses site reconnaissance information and online GIS mapping
data typically obtained from local GIS departments to obtain precise locations of the identified regulatory
sites and subsequently, identify more accurate distances of those sites from the subject property.
DATABASE * RADIUS
(MILES)
# OF FACILITIES
IDENTIFIED
TARGET
PROPERTY REC(s)
(Yes/No) (Yes/No)
NPL 1.0 0 No N/A
CERCLIS 0.5 0 No N/A
SEMS-ARCHIVE 0.5 2 No Yes
HSDS 1.0 1 No Yes
SHWS 1.0 1 No Yes
SWF/LF 0.5 0 No N/A
BROWNFIELDS 0.5 0 No N/A
US ENG CONTROLS 0.5 0 No N/A
US INST CONTROL 0.5 0 No N/A
INST CONTROL 0.5 0 No N/A
RCRA-LQG 0.25 2 No No
RCRA-SQG 0.25 2 No No
RCRA-TSDF 0.5 0 No N/A
RCRA-CESQG 0.25 0 No N/A
RCRA-NonGen/NLR 0.25 0 No N/A
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DATABASE * RADIUS
(MILES)
# OF FACILITIES
IDENTIFIED
TARGET
PROPERTY REC(s)
(Yes/No) (Yes/No)
DOD 1.0 0 No N/A
FINDS 0.25 0 No No
IMD 0.5 5 No Yes
HMIRS 0.25 0 No N/A
ERNS 0.25 0 No N/A
LUST 0.5 2 No No
LUST Trust 0.5 0 No N/A
RGA LUST 0.125 0 No N/A
UST ** 0.25 0 No No
AST 0.25 1 No No
LAST 0.5 2 No No
SWF/LF 0.5 0 No N/A
OLI 0.5 0 No N/A
HIST LF 0.5 0 No N/A
SWRCY 0.5 0 No N/A
US MINES 0.25 0 No N/A
NPDES 0.25 0 Yes No
UIC 0.25 0 No N/A
SPILLS 0.125 0 No N/A
Tx. Ind Haz Waste 0.250 1 No No
PA Manifest 0.250 1 No No
NJ Manifest 0.250 1 No No
US Hist Auto 0.25 0 No N/A
US Hist Cleaners 0.25 0 No N/A
ECHO 0.125 0 No N/A
* - For a complete list of databases searched and the definitions of these databases, see pages GR-1 through GR-25 of the EDR
Report in the Appendix.
N/A - Not Applicable; No sites listed in the EDR Report for that particular database.
** - It should be noted that registration with the NCDENR of commercial USTs was not required prior to 1988. Additionally, registration for non-commercial USTs (e.g. residential) less than 1,100 gallons in capacity is not required with the NCDENR.
Therefore, if a UST system was used to store fuel for any heating system on the property, or to support agricultural or other
operations there would be no written public record of its use.
4.1.1. DATABASE FINDINGS
Target Property
Invista
The Invista Chemical plant is located on approximately 1,044 acres of property, which is currently owned by
Invista S.A.R.L.. The property is divided into several sections which include the plant process area, spray
fields, tank farm, sludge lagoon, 001 outfall area, north property, east property, potable well field, west
production field, south production field, and inactive landfill. The plant process area, which occupies 160 of
the 1,044 acres, was built in the late 1960’s and since that time has manufactured dimethyl terephthalate
(DMT) and purified terephthalic acid. In the 1990’s, the plant expanded with the addition of Forton
Industries facility, built in the northeast quadrant of the plant process area, which produced technical
polymer and polyphenylene sulfide.
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Since the early 1990’s, several investigations have been performed at the site. As a result of the
investigations, several sources of contamination have been identified and were attributed to the
manufacturing process and waste management. In addition, data collected from the site assessments have
concluded the chemicals of concern are 1,4 dioxane, para-xylene, and para-cymene (4-isopropyltoulene).
The information below is summarized from a file review completed by WithersRavenel. The pertinent
documents regarding the environmental investigation at the site can be found in the Appendix.
Contamination from the Manufacturing Process
Assessment activities at the facility concluded that the storage and movement of raw material throughout
the plant process area resulted in several inadvertent releases or spills of contaminants into the soil and
groundwater. Throughout the plant’s history, there have been several documented releases. Table 2-4 and
2-5 in the Comprehensive Site Assessment (CSA) dated December 2002, which is found in the Appendix,
summarizes each spill. Spills included DMT slurry, oxidate, xylene, and transfer fluids from the production
area, heat transfer fluids and fuel oil in the utilities area, and diethylene glycol and fuel oil in the Terate™
resin area.
Contamination from Waste Management
The former onsite industrial landfill operated from 1969 to 1977, on approximately 2 acres, located
approximately 1,800 feet south of the process area. The landfill consisted of two distinct cells and each cell
was reported to be, generally, 400 feet long and 100 feet wide, ranging from three to five feet thick, and in
some instances reaching eight feet thick. It was noted that some of the material was placed at depths that
put the waste in contact with the groundwater table. During assessment activities conducted in 1994, the
material in the landfill was identified as non-hazardous. Through a groundwater monitoring well network,
the following contaminants were determined to be leaching from the landfill, benzene, 1,2 dichloroethane,
vinyl chloride, xylene, 4-methylphenol, 2-nitroaniline, p-toluic acid, cobalt, iron, and manganese.
As part of the initial waste management plan, the facility installed and attempted to dispose of treated waste
water in an injection well system. Initially, the system was made up of six wells, one injection well and five
observation wells. The injection well was installed to a total depth of 1,000 feet BGS (the Cape Fear
Aquifer). Four of the observation wells were installed within the injection zone while one was installed to a
depth of 700 feet BGS (the Blackcreek Aquifer). Over a four year period, the injection well developed leaks
approximately 700 feet BGS due to operating the system beyond its pressure capacity. Therefore, a
replacement injection and observation wells were installed. However, the injection plan proved to be
unsuccessful. Therefore, the use of the injection wells was discontinued in 1972. Since the injection
activities ceased, several assessments have been performed. During the most recent sampling event in
2010, groundwater samples were collected from the 700 and 1000 foot aquifers. Historical laboratory
results showed a significant improvement in water quality; however, waste material continues to persist in
both the 700 foot and 1000 foot aquifers.
To replace the failed injection well system, a biological wastewater treatment plant was built onsite in 1972,
to handle the wastewater stream. The wastewater from the process area was carried to the treatment
plant via aboveground and underground pipes. From 1972 till 1980 all of the treated wastewater was
discharged into the Cape Fear River. In 1982, some of the treated wastewater was sprayed on 60 acres of
property located adjacently east of the plant process area. Upgrades to the wastewater treatment plant,
which was completed in 2002, allowed the facility to discharge all of its process water in the Cape Fear
River. Therefore, in 2002, the spraying of treated wastewater ceased. As reported in the 2002 CSA, it was
presumed that low levels of 1,4 dioxane and metals were present in the effluent of the treatment process
which in turn was sprayed on the field. Therefore, residual contaminants in the treated wastewater that was
sprayed on the fields was considered a source of contamination.
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±80.43-acre S. T. Wooten/Invista Mine Expansion Property WR No. 02130008.10
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Conclusions
Since 1990, several site assessments at the Invista Facility have indicated the groundwater was
contaminated through spills within the production area, and waste management, by three constituents of
concern which were 1,4 dioxane, para-cymene (4-isopropyltoulene), and para-xylene. In the most current
groundwater sampling report, dated May 13, 2011, submitted by AECOM, it was concluded from historical
data, the 1,4 dioxane, para-cymene, and xylene plumes were stable or contracting. Groundwater elevation
data collected during the events indicated an overall groundwater flow in a southeast direction (away from
the subject property).
Surrounding Properties
Praxair
Praxair, Inc. addressed as 4832 US Highway 421N is located on the northeastern adjacent property. The
EDR report indicated that the site is listed in the NC LAST and NC IMD databases. According to the EDR
report two incidents are associated with a hydraulic oil release in 1994 and 1997. WR reviewed available
regulatory files from NCDEQ. Based on the historical reports obtained, in 1994, Praxair reported to DENR
a 200 to 300 gallon lubricant oil leak on the property. NCDENR personnel conducted a site visit and
subsequently issued a “Notice of Violation” (NOV) to Praxair. Following the NOV, Praxair immediately took
steps to stop the oil leak. In November 1994, Praxair contracted with Specialize Marine to excavate and
transport impact soils to Cherokee Environmental. According to documents in the file, in a telephone
conversation, NCDENR expressed their satisfaction of the remedial activities conducted in regards to the
incident.
Based on the historical reports obtained, in 1997, Praxair reported to DENR a 100 gallon lubricant oil leak
on the property. Praxair took immediate action and contracted with Specialize Marine to excavate and
treated 48.98 tons of soil onsite. The soil was staged onsite pending analytical results for confirmation
samples taken post treatment. Analytical results for the confirmation samples report TPH at concentrations
below the NC DENR Action Level. The soil was used to backfill the excavation cavity.
In 2014, the NCDENR ranked the site as low. In addition, in a Inspection Report performed by NCDENR
personnel, it was noted there was no indication of soil contamination at the facility. Based on available
information the release appears to have been a localized area of impacted soil with no evidence that
groundwater has been impacted. Therefore, WR does not consider the adjacent Praxair site to represent a
REC in relation to the subject site
Additional Listings
Several additional sites were identified in the EDR report. The identified sites were determined to be
greater than 500 feet away from the subject property, topographically down gradient from the subject site,
or apparent flow was away from the subject property. Therefore based on the distance and topographic
situation of these sites from the subject site, WR does not consider the additional identified sites to be RECs
relative to the subject property.
4.2. PHYSICAL SETTING AND ANALYSIS
WR examined the U.S. Geological Survey 7.5-minute series topographic map of the Castle Hayne, North
Carolina Quadrangle (Figure 1). The subject property is approximately 25 feet above mean sea level
(AMSL) and is located in between the Northeast Cape Fear River located east and the Cape Fear River and
Sutton Lake located west of the subject property. Due to the flat profile of the site and the porous property
of the soil matrix, rainfall would be expected to form puddles and percolate into the subsurface, or
evaporate.
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The boring log for the Hercules Plant (aka Invista property) Injection Well, which was obtained from the
NCDENR-Division of Water Resources (boring log included in the Appendix), showed the area is underlain
by the surficial, Blackcreek, and the Upper and Lower Cape Fear Aquifers. It also states that the Pee Dee
aquifer most likely exists between the Surfical and Blackcreek Aquifer, however, due to insufficient data, the
Pee Dee Aquifer could not be included in the log.
Results from groundwater investigation on the Duke Energy L.V. Sutton Electric Plant and the Invsita
property showed an overall groundwater flow within the surficial aquifer to be in a southeast direction. The
groundwater flow direction is most likely due to a hydraulic influence from Lake Sutton.
The subject property is part of a bigger parcel owned by Wilbara LLC (aka Invista) and is situated in the
southwest corner of the property, within the west production area. In a CSA submitted in 2002, the area
known as the west production well field, it was reported the aquitard between the surficial aquifer and the
Pee Dee Formation is approximately 50 feet to 80 feet BGS. The subject property contains the production
well G, which was reported to produce water at a rate of 88 gallons per minute.
4.3. HISTORICAL USE INFORMATION ON THE PROPERTY
4.3.1. OWNERSHIP REVIEW
Information on the ownership history of the site was obtained by WR through an online review of the New
Hanover County deed records, which are maintained at the New Hanover County Register of Deeds Office
in Wilmington, North Carolina. The ownership history of the property was reviewed for indications of past
owners who may have used, stored, or disposed of hazardous substances or petroleum products on the site.
The information was assembled for informational and historical purposes only for use in this report and
should not be construed as a legal chain-of-title for the site.
Deed Table
Book Page Date Grantor Grantee
5447 1139 10/30/2009 Invista Wilbara
5374 2810 2/3/2009 Invista Wilbara
5374 2818 2/3/2009 Invista Wilbara
5374 2802 2/2/2009 Invista Wilbara
4319 517 5/13/2004 Arteva Specialties2 Invista
2485 978 12/15/1998 HNA Holding, Inc1 Arteva Specialties2
1840 894 12/22/1994 Cape Industries4 Hoechst Celanese Polyester, Int.
1699 1272 9/13/1993 Cape Industries4 City of Wilmington
1293 399 5/1/1985 Hercofina3 Cape Industries
1075 697 10/1/1976 Hercules, Inc. Hercofina3
802* 324 12/15/1966 Royal, A.D et alt Hercules, Inc.
802* 476 12/15/1966 Peixotto, Eloise and husband
Elliot Hercules, Inc.
805 223 12/15/1966 Simpson, Mildred and husband
Guy Hercules, Inc.
805 307 12/15/1966 Powell, Mildred Hercules, Inc.
606* 221 9/26/1957 Royal C.S., et alt. Royal, A.D. et alt
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268 245 12/10/1936 Royal, C.S, et alt North East Land and Timber Co.
268 242 9/12/1927 Royal, C.S., et alt. North East Land and Timber Co.
1 Successor in interest by name change to Hoechst Celanese Corporation, which is successor in interest by
merger to American Hoechst Corporation, which is a successor in interest by merger to Hoechst Fibers
Incorporated, which is a successor in interest by name change to Hystron Fibers, Incorporated. Hoechst
Celanese Polyester Intermediates changed name from Cape Industries on 12/22/1994 (Deed Book 1840,
Page 894).
2 Now known as Invista Corporation.
3 A joint venture consisting of Hercules Incorporated and American Petrofina, Inc.
4 A joint venture consisting of NCT Corporation and American Petrofina, Inc.
* References a 5,000-acre parcel from which the subject site was subdivided.
Review of the deed records for the subject property revealed that prior to 1936 most of the property in the
area was owned by North East Land and Timber Company. From 1936, it up until 1966 individuals owned
the land in the area which was then bought by Hercules, Inc.. After acquiring the land, Hercules built the
chemical manufacturing plant. Since the 1960’s, several companies have owned and operated the plant
which included Hercofina (1976), Cape Industries (1985), Hoechst Celanese Polyester Int. (1994), Invista
(1998), and Wilbara (2009). WR is aware, through interviews with Invista personnel, the manufacturing
structure was built in 1966 on the northeastern portion of the property. The subject property, which is
located in the southwestern portion of the property, has never been developed. Copies of the deeds
obtained by WR from the New Hanover County Register of Deeds website are provided in the Appendix.
4.3.2. AERIAL PHOTOGRAPH REVIEW
WR reviewed aerial photographs covering the subject property from 1949 through 2012. See Section 8.2
for source references for the individual aerial photographs reviewed. Copies of the reviewed aerial
photographs are provided in the Appendix.
WR has included the approximate subject property boundary on each of the aerial photograph copies provided in
the Appendix. Please note that these lines, especially on the older aerial photographs, are approximations, and do
not represent an exact depiction of specific onsite and offsite features.
Aerial
Year Onsite Offsite
1949 The subject property consists entirely of
undeveloped woodlands.
The surrounding area consists of
undeveloped woodlands.
The CSX Railroad is visible.
1966 The subject property is undeveloped
woodlands.
Most of the surrounding area is undeveloped
woodlands.
Highway 421 and the railroad line are visible.
1981
The subject property remains largely
wooded and undeveloped. There are what
appear to be unimproved roads cut on the
perimeter of the western portion of the
subject property.
The Invista Manufacturing Plant is visible,
located northeast of the subject property.
Lake Sutton is visible on the western edge of
the aerial photograph.
1998-
2012 The subject property remains entirely
wooded and undeveloped.
The small surface water bodies located
immediately west of the subject property are
part of Lake Sutton.
Aerial Review Summary:
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Review of the aerial photographs revealed that from at least 1949 until to 2010 the subject property
remained largely wooded and undeveloped with the exception of what appears to be unimproved roads, cut
on the perimeter of the property.
The surrounding properties consists primarily undeveloped woodlands from at least 1949 until 1981. The
Invista Manufacturing Plant is first visible in the 1981 aerial photograph. No apparent evidence of borrow
pits or landfill operations were evident on the subject property on the aerial photographs reviewed by WR.
It should be noted in the 1998 aerial photograph, small surface water bodies are visible immediately
adjacent to the western property boundary of the subject property. While these may be the remnants of
borrow pits operated by adjacent land owners, the origin of the small water bodies is unknown.
4.3.3. SANBORN FIRE INSURANCE MAPS
Sanborn maps originated in the late 1800s and published around 1960. The maps were used by insurance
underwriters to determine the risk involved in insuring individual buildings in urban areas against loss in
fires or other disasters. These historical maps plot building details and provide comments concerning a
building’s former use. The availability of Sanborn Maps is limited to urban areas that historically presented
fire hazards. Sanborn Map coverage was not available for the subject property.
4.3.4. CITY DIRECTORY SEARCH
WR reviewed city directories for the subject property and surrounding vicinity at the New Hanover County
Public Library Main Branch in Wilmington, North Carolina. The city directories were available from the
early 1900’s through 2014, though the directory provided coverage for the area to as far back as 1992. Due
to the subject property never being developed and not having road access, there is no listing in the
directories that identifies the property.
WR reviewed city directories for US Highway 421. The city directory lists several commercial and industrial
businesses in the 3000 and 4000 block of Highway 421 including KoSa (Invista) (4600), Wilmington
Materials (3612), and Waste Industries (3618). The 1992 city directory lists only Waste Industries (3618),
all other aforementioned listings do not appear in the 1992 directory. Prior to 1992, the area was not coved
by the city of directories.
4.3.5. HISTORY OF PROPERTY USE
The subject property is a small portion, approximately 80.43 acres, of a lager 1,044 acre property which is
home to Invista chemical manufacturing facility. The property is divided into sections which include the
plant process area, spray fields, tank farm, sludge lagoon, 001 outfall area, north property, east property,
potable well field, west production field, south production field, and inactive landfill. The plant was built on
the northeast portion of the property in the late 1960’s and has an extensive history of point source
contamination to soil and groundwater. The subject property is part of the west production field which is
used for harvesting groundwater for the production plant and is located in the southwest portion of the
property, approximately 1300 feet from the plant process area. Based on the information obtained by WR
from the deeds, interviews, city directories, and aerial photographs, the subject property remained largely
wooded and undeveloped. There are what appear to be unimproved roads, cut on the perimeter of the
subject property in the 1981 aerial photograph.
4.4. HISTORICAL USE INFORMATION ON ADJOINING PROPERTIES
Historical use of adjoining properties was obtained from a review of available aerial photographs from 1949,
1966, 1981, 1998, 2002, 2006 and 2010, city directories, internet research, and interviews with individuals
familiar with the area. The historical use of the adjoining properties has been provided in the aerial review
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summary of Section 4.3.2 of the report, the city directory review summary in Section 4.3.4, and interviews
presented in Section 5 of the report.
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5.INTERVIEWS
5.1. INTERVIEW WITH MR. JEFF RANDOLPH AND ELIZABETH MEYER – OWNER
REPRESENTATIVE
WR interviewed Mr. Jeff Randolph and Ms. Elizabeth Meyer on June 27 and 28, 2016. Conversation
records are available upon request.
Mr. Jeff Randolph and Ms. Elizabeth Meyer, who have been with Invista for 7 months and 10 year,
respectively, both completed WR’s “Owner” questionnaire regarding their knowledge of the site. The
property has always been undeveloped and historically no structures have been present. Since the time of
plant start-up the subject property has been used as a well field for harvesting groundwater that was used in
the plant production process.
Mr. Randolph and Ms. Meyers do acknowledge several environmental assessments have been done on the
Invista property pertaining to a contaminant plume. Analytical results for groundwater samples collected
from the groundwater monitoring wells on the subject property indicate the presence of 1,4 dioxane in the
groundwater on the subject property.
Mr. Randolph acknowledges the existence of the three observations wells associated with the injection well
network. He indicated that the actual injection well is located on the east side of US Highway 421. He
revealed that one of the observation wells on the subject property did leak and approximately 1,000 gallons
of groundwater was released.
Mr. Randolph acknowledged the presence of PCB containing materials and asbestos on the subject
property. During the site reconnaissance, 15 pole mounted transformers were observed on the subject
property. Mr. Randolph indicated that the all of the transformers were installed prior to 1979 and are
assumed to contain PCB oil. Additionally, the pipe used to transfer the production water from the
production field to the plant is Transite pipe constructed of cement and asbestos.
During the 2013 Phase I ESA competed on the southern adjacent property by WR, Invista personnel
indicated a rail car derailment incident occurred, however, none of the rail car’s contents were released. Mr.
Randolph indicated that he was not aware of any incidents involving releases from rail cars in the rail road
car transfer area.
Mr. Randolph, completed WR’s “Owner” questionnaire regarding his knowledge of the site. The completed
questionnaire indicated that he was not aware of any landfilling or large debris disposal at the site. He
stated that, to the best of his knowledge, no ASTs, USTs, 55-gallon drums, borrow pits, lagoons, batteries or
hazardous chemicals were ever present on the subject property. In addition, he was not aware of any leaks,
or releases of petroleum products or other hazardous substances at the site. Mr. Randolph had not heard of
any spills, liens, or land restrictions associated with the subject property or the adjacent properties.
Furthermore, he had not heard of any violations or lawsuits based on environmental regulations associated
with the subject property or adjacent properties. The completed “Owner” questionnaire can be found in the
Appendix.
5.2. INTERVIEW WITH MR. FRANK PRIDGEN –NHC FIRE DEPARTMENT
WR interviewed Mr. Frank Pridgen during completion of a Phase I ESA on the subject property in June, 27
2016. Conversation records are available upon request.
The New Hanover County fire house is located at the intersection of Sutton Lake Road and US Highway 421.
Mr. Pidgen indicated that he has been with the NHC Fire Department for 18 years and has been at his
current post for at least 10 years. He stated he has no recollection of any reported environmental incidents
(leaks, spills or dumping of petroleum liquids or hazardous substances) on the subject property or
surrounding properties. He is aware small brush fires did occur in the rail road car transfer area due to
sparks from the rail cars. However, all of the fire were on the rail road property and quickly extinguished.
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Mr. Pidgen indicated that to the best of his knowledge, he was not aware of any USTs or ASTs being located
on the property. He stated that there were no landfill or surficial dumping activities ever associated with
the subject site. Mr. Pidgen stated that to his knowledge there were never any 55-gallon drums or other
possible hazardous materials or petroleum products stored or dumped on the subject property. Mr. Pidgen
stated that he was not aware of any known contamination issues, environmental issues, or lawsuits relative
to the subject property.
5.3. INTERVIEWS WITH LOCAL GOVERNMENT OFFICIALS
WR contacted the New Hanover County Fire Marshal’s Office to ascertain if there had been any reported
environmental incidents (leaks, spills or dumping of petroleum liquids or hazardous substances) for the
subject property or surrounding properties. To date, WR has not received a response from New Hanover
County Fire Marshal’s Office.
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6.DATA GAPS
In accordance with the ASTM Standard E-1527-13, data gaps should be identified in the Phase I ESA report.
WithersRavenel identified the following data gaps during Phase I ESA activities:
Client Provided Information
At the time of this report, the Questionnaire addressed as “Title and Judicial Records Review for
Environmental Liens and Activity and Use Limitations” was not completed for this Phase I ESA. See Section
7 for more information.
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7.FINDINGS AND CONCLUSIONS
WithersRavenel has performed a Phase I Environmental Site Assessment for the ±33.58-acre property
described in Section 1.2. The findings contained herein are based on the results of the Phase I ESA
performed by WithersRavenel in general conformance with the scope and limitations of ASTM E-1527-13
and in accordance with WithersRavenel’s Standard Contract Conditions for Engineering Services. All
conclusions made in this report are based upon the assessment performed by WithersRavenel and are
subject to the Special Terms and Conditions outlined in Section 1.4 of this report. Any exceptions to, or
deletions from, this practice are described in the report.
FINDINGS
RECs
RECs were identified in connection with the subject property during the course of this assessment
Controlled RECs (CREC)
No CRECs were identified in connection with the subject property during the course of this assessment.
Historic RECs (HREC)
No HRECs were identified in connection with the subject property during the course of this assessment.
De Minimis Environmental Conditions
No de minimis environmental conditions were identified in connection with the subject property during the
course of this assessment.
CONCLUSIONS
In conclusion, based on WR’s site reconnaissance in conjunction with review of historical information
gathered from an examination of ownership, aerial photographs, historical property uses, and public
records, this assessment has revealed the following recognized environmental conditions (RECs) in connection
with the subject property.
Migrating Groundwater Plume from the Duke Energy L.V. Sutton Electric Plant Coal Ash
Impoundment
The Duke Energy L.V. Sutton Plant is located adjacent to the west of the subject property. Groundwater
assessment at the facility has indicated that several metals have been detected in the groundwater which,
most likely, is leaching from the ash impoundment maintained by Duke Energy. Several metals have been
detected in the groundwater proximal to the coal ash impoundment including; arsenic, barium, boron,
cobalt, iron, manganese, selenium, and thallium.
WR recommends the groundwater be sampled on the western edge of the subject property and be analyzed for the
aforementioned metals and sulfate.
Migrating Groundwater Plume from the Invista Plant
The Invista Chemical Plant is located northeast of the subject property. Assessment activities at the plant
have indicated three compounds of concern that are present in the groundwater, which include 1,4 dioxane,
p-xylene, and para cymene (4-isopropyltoulene). As documented in the Sampling and Monitoring Report
2010 Site-wide Sampling Event dated May 13, 2011, prepared by AECOM, the overall groundwater flow
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from the plant footprint (source area) is to the southeast. However, Mr. Randolph and Ms. Meyers of Invista
do acknowledge analytical results for groundwater samples collected from the groundwater monitoring
wells on the subject property indicate the presence of 1,4 dioxane in the groundwater on the subject
property.
WR recommends the groundwater monitoring wells on the subject property be sampled VOCs, SVOCs, priority
pollutant metals, and sulfate.
Documented Elevated Chloride Levels in the Surficial Aquifer in the West Production Well
Field
During research completed on the Progress Energy L.V. Sutton Electric Plant (the western adjacent
property) and the Invista Plant, it was revealed that, in the 1980’s, the two companies were involved in a
legal dispute regarding the origin of the high chloride levels in the production wells located in the west
potable and west production well fields. During a Phase I ESA completed on the property that was part of
the west production field in 2013 by WR, Invista personnel revealed the water that is harvested from the
west production and potable fields continue to exhibit high chloride levels.
Due to the historical elevation chloride levels, groundwater samples collected on the subject property should also be
sampled for chlorides.
Rail Tanker Car Staging Area
The subject property is bisected by a CSX Railroad. In conversation with the Invista personnel, it was
revealed the rail line is leased by Invista from CSX to stage rail tanker cars on the tracks. There have been
no recorded spills or release on the rail line. Nonetheless, the potential exists for many smaller, non-
reportable spills may have accord over the years. Therefore, WR believes this area should be assessed.
WR recommends the groundwater be sampled adjacent to the railroad that bisects the subject property for VOCs,
SVOCs, priority pollutant metals, and sulfate.
PCB and Asbestos Containing Material
Mr. Randolph did acknowledge the presence of PCB containing materials and asbestos on the subject
property. During the site reconnaissance, 15 pole mounted transformers were observed on the subject
property. Mr. Randolph indicated that the all of the transformers were installed prior to 1979 and are
assumed to contain PCB oil. Additionally, the pipe used to transfer the production water from the
production field to the plant is Transite pipe constructed of a cement/asbestos composite.
WR recommends that all PCB and asbestos containing materials on the subject property be removed prior to
purchase.
Though not considered RECs at this time, the following environmental concerns/Business Environmental
Risks should also be considered.
Waste Injection Well Network
During the site reconnaissance, WR observed three deep groundwater monitoring wells associated with the
waste injection well network. As part of the initial waste management plan, the facility installed and
attempted to dispose of treated waste water in an injection well system.. During the most recent sampling
event in 2010, groundwater samples were collected from the 700 and 1000 foot aquifers. Historical
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laboratory results showed a significant improvement in water quality; however, waste material continues to
persist in both the 700 foot and 1000 foot aquifers.
Based on the future use of the property, WR does not consider the observations wells apart of the waste injection
well network to be an REC. However, the wells will need to be properly abandoned.
Data Gap – Client Provided Information
As of the date of this report, the environmental liens and activity and use limitations (AULs) search has not
been completed by a professional title company or title professional. WR believes that this information
should be completed along with title work for the property as typically coordinated by a real estate
attorney. If any environmental liens and/or AULs filed against the property are discovered, this information
should be provided to WR prior to any transfer of this property so that we may make a proper review and
issue an amended letter accordingly. If no environmental liens or AULs are discovered, the questionnaire
addressed as “Title and Judicial Records Review for Environmental Liens and Activity and Use Limitations”
provided by WR should be filled out completely and placed inside the cover to accompany this report as an
attachment.
Please do not hesitate to contact us at (919) 469-3340 should you have any questions or comments
regarding this investigation.
Sincerely,
WithersRavenel
We declare that, to the best of our professional knowledge and belief, we meet the definition of
Environmental Professional as defined in §312.10 of 40 CFR 312. We have the specific qualifications based
on education, training, and experience to assess a property of the nature, history, and setting of the subject
property. We have developed and performed the all appropriate inquiries in conformance with the
standards and practices set forth in 40 CFR Part 312.
Christopher Fay
Project Geologist
R. S. (Butch) Lawter, Jr., P.E.
Director of Environmental Services
WithersRavenel
Our People. Your Success.
±80.43-acre S. T. Wooten/Invista Mine Expansion Property WR No. 02130008.10
Phase I Environmental Site Assessment May 2016
23
8. REFERENCES
8.1. PERSONS INTERVIEWED
Pridgen, Frank – NHC Fire Department; June 27, 2016.
Randolph, Jeff and Elizabeth Meyer –Owner Representative; June 27-28, 2016.
8.2. RECORDS AND DOCUMENTS REVIEWED
AECOM Environmental. Sampling and Monitoring Report 2010 Site-wide Sampling Event-Invista Facility,
Wilmington, NC, May 13, 2011
Aerial photographs from 1949, 1966, 1981, 1998, 2006, 2010, and 2012 were obtained from New Hanover
County GIS website.
Deeds viewed online through the New Hanover County Register of Deeds Office and maintained at the New
Hanover County Register of Deeds Office in Wilmington, North Carolina.
Earth Tech, Inc. Comprehensive Site Assessment Report-KoSa Facility, Wilmington, North Carolina, December
2002.
Environmental Data Resources, Inc., Southport, Connecticut, regulatory information, April 26, 2016.
Groundwater and Environmental Services, Inc. 2010 Former Injection Well Network Groundwater Sampling
Report, March 2011
SynTerra. Comprehensive Site Assessment Report- Duke Energy L.V. Sutton Energy Complex. August 5, 2015.
United Stated Geological Survey, Wilmington, NC Topographical Quadrangle.
WithersRavenel
Our People. Your Success.
±13.60-acre Carolina Cove, LLC Apartments Property WR No. 02160177.0
Phase I Environmental Site Assessment April 2016
Table of Contents
1. Introduction ........................................................................................................................ 1
1.1. Purpose ............................................................................................................................................................................. 1
1.2. Scope of Services ............................................................................................................................................................ 1
1.3. Limitations and Exceptions ......................................................................................................................................... 1
1.4. Special Terms and Conditions .................................................................................................................................... 2
1.5. Reliance ............................................................................................................................................................................. 3
2. Site Description ................................................................................................................. 4
2.1. Methodology and Limiting Conditions .................................................................................................................... 4
2.2. Site Operations, Processes, and Equipment .......................................................................................................... 4
2.3. Description of Structures ............................................................................................................................................ 6
2.4. Current Uses of Adjoining Properties ...................................................................................................................... 6
3. User-Provided Information ............................................................................................. 8
4. Records Review & Historical Use Information .......................................................... 9
4.1. Local State and Federal Environmental Regulatory Authorities and Databases ....................................... 9
4.1.1. Database Findings ........................................................................................................................................................ 10
4.2. Physical Setting and Analysis .................................................................................................................................. 12
4.3. Historical Use Information on the Property ....................................................................................................... 13
4.3.1. Ownership Review ....................................................................................................................................................... 13
4.3.2. Aerial Photograph Review ........................................................................................................................................ 14
4.3.3. Sanborn Fire Insurance Maps ................................................................................................................................. 15
4.3.4. City Directory Search ................................................................................................................................................. 15
4.3.5. History of Property Use ............................................................................................................................................. 15
4.4. Historical Use Information on Adjoining Properties........................................................................................ 15
5. Interviews ......................................................................................................................... 17
5.1. Interview with Mr. Jeff Randolph And Elizabeth Meyer – Owner Representative ................................ 17
5.2. Interview with Mr. Frank Pridgen –NHC Fire Department ........................................................................... 17
5.3. Interviews with Local Government Officials ...................................................................................................... 18
6. Data Gaps .......................................................................................................................... 19
7. Findings and Conclusions ............................................................................................. 20
8. References ........................................................................................................................ 23
8.1. Persons Interviewed .................................................................................................................................................. 23
8.2. Records and Documents Reviewed ....................................................................................................................... 23
WithersRavenel
Our People. Your Success.
±13.60-acre Carolina Cove, LLC Apartments Property WR No. 02160177.0
Phase I Environmental Site Assessment April 2016
Appendix Included in this Report
A FIGURES ☒Yes ☐No
B ENVIRONMENTAL DATABASE REPORT ☒Yes ☐No
C SANBORN MAP REPORT ☒Yes ☐No
D DEEDS & OWNERSHIP RECORDS ☒Yes ☐No
E CITY DIRECTORIES ☒Yes ☐No
F PHOTOGRAPHIC RECORD ☒Yes ☐No
G AERIAL PHOTOGRAPHS ☒Yes ☐No
H OWNER QUESTIONNAIRES ☒Yes ☐No
I PURCHASE PRICE QUESTIONNAIRE ☒Yes ☐No
J LIEN-AUL QUESTIONNAIRE (Blank) ☐Yes ☒No
K CLIENT/OWNER QUESTIONNAIRE ☒Yes ☐No
L REGULATORY FILE REVIEW INFORMATION ☒Yes ☐No
M HISTORICAL REPORTS ☐Yes ☒No
N OTHER ☐Yes ☒No