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HomeMy WebLinkAbout22058_Erwin Mill_AWP_20190603Brownfields Assessment Work Plan Revision 1 Erwin Mill 200 North 13th Street Erwin, North Carolina Brownfields Project No. 22058-18-043 H&H Job No. BRP-001 June 3, 2019 #C-1269 Engineering #C-245 Geology i \\HHFS01\MasterFiles\AAA-Master Projects\Brooks Pierce\Erwin Mill (BRP.001)\Brownfields Assessment Work Plan\REV 1 to DEQ\Brownfields Assessment Work Plan Rev 1_Erwin Mill_(BPN 22058-18-043).doc Brownfields Assessment Work Plan – Revision 1 Erwin Mill 200 North 13th Street Erwin, North Carolina H&H Job No. BRP-001 Table of Contents 1.0 Introduction .............................................................................................................................1 1.1 Background ............................................................................................................................1 1.2 Previous Assessment Activities .............................................................................................2 1.3 Areas of Concern ...................................................................................................................5 2.0 Brownfields Assessment Scope of Work .............................................................................12 2.1 Brownfields Receptor Survey ..............................................................................................12 2.2 Monitoring Well Installation Activities ...............................................................................12 2.3 Groundwater Sampling Activities .......................................................................................14 2.4 Soil, Debris, and “Tar-Like” Material Assessment Activities .............................................15 2.5 Sub-Slab Gas Assessment Activities ...................................................................................17 2.6 Surface Water and Sediment Assessment Activities ...........................................................19 3.0 Quality Assurance / Quality Control ..................................................................................20 4.0 Investigative Derived Waste .................................................................................................22 5.0 Reporting ...............................................................................................................................23 List of Tables Table 1 Proposed Groundwater Sampling Locations and Analyses Table 2 Proposed Soil and Debris Sampling Locations and Analyses Table 3 Proposed Sub-Slab Gas Sampling Locations and Analyses Table 4 Proposed Surface Water and Sediment Sampling Locations and Analyses ii \\HHFS01\MasterFiles\AAA-Master Projects\Brooks Pierce\Erwin Mill (BRP.001)\Brownfields Assessment Work Plan\REV 1 to DEQ\Brownfields Assessment Work Plan Rev 1_Erwin Mill_(BPN 22058-18-043).doc List of Figures Figure 1 Site Location Map Figure 2 Site Map Figure 3 Proposed Monitoring Well Location Map Figure 4 Proposed Soil Sample Location Map Figure 5 Proposed Sub-Slab Gas Sample Location Map Figure 6 Proposed Surface Water and Sediment Sample Location Map List of Appendices Appendix A Summary of Historical Analytical Data 1 \\HHFS01\MasterFiles\AAA-Master Projects\Brooks Pierce\Erwin Mill (BRP.001)\Brownfields Assessment Work Plan\REV 1 to DEQ\Brownfields Assessment Work Plan Rev 1_Erwin Mill_(BPN 22058-18-043).doc Brownfields Assessment Work Plan – Revision 1 Erwin Mill 200 North 13th Street Erwin, North Carolina H&H Job No. BRP-001 1.0 Introduction On behalf of Erwin Plant, LLC, Hart & Hickman, PC (H&H) is providing this Work Plan to conduct Brownfields assessment activities at the Erwin Mill Brownfields property (Brownfields Project No. 22058-18-043) located at 200 North 13th Street in Erwin, Harnett County, North Carolina (Site). Erwin Mill (Parcel Identification No. [PIN] 0597-54-8405.000) consists of one parcel of land that totals approximately 55.25 acres and is developed with multiple office buildings, warehouse storage buildings, and former textile manufacturing buildings. The Site historically operated as a textile manufacturing facility dating back to the early 1900s. Much of the Site is currently vacant with the exception of several warehouse buildings that have been leased to various tenants. A Site location map is provided as Figure 1, and the Site and surrounding area are shown on Figure 2. Erwin Plant, LLC was approved to work with the Brownfields Program under a “Ready for Reuse” (RFR) Brownfields agreement, in which Erwin Plant, LLC will act as a proxy for a future prospective developer (PD) to assess the Site as needed. This Work Plan has been prepared to address data gaps in previous assessment work, as discussed during the March 7, 2019 Data Gap meeting with the Brownfields Program. 1.1 Background Erwin Mills began operation of a textile manufacturing facility at the Site in 1904. The facility was primarily focused on the production of denim. Burlington Industries purchased the Site in 1962 and continued to operate the facility. Burlington Industries merged with Swift Textiles, Inc. in 1987, and the facility continued to operate through 2000, when the property was purchased by 2 \\HHFS01\MasterFiles\AAA-Master Projects\Brooks Pierce\Erwin Mill (BRP.001)\Brownfields Assessment Work Plan\REV 1 to DEQ\Brownfields Assessment Work Plan Rev 1_Erwin Mill_(BPN 22058-18-043).doc the current owner, Schwarz Auman Properties, LLC. Since 2000, the property has been predominately vacant with the exception of several warehouse buildings that have been leased to various tenants. Current or recent tenants include general small businesses, county offices, warehouse users, and some light manufacturing (rifle assembly, ammunition assembly, and cabinet shop). 1.2 Previous Assessment Activities Prior sampling of soil and/or groundwater was performed at the Site during a 1997 Underground Storage Tank (UST) closure, 1998 fuel oil removal in the area of the dye storage building, and 2001 Phase II Environmental Site Assessment (ESA). In addition, a Phase I ESA was conducted in 2015. A brief discussion of previous assessment activities completed at the Site is provided in the following sections. 1997 UST Closure Activities In May 1997, EarthTech, Inc (EarthTech), oversaw the removal of one 2,000-gallon gasoline UST and one 1,000-gallon diesel UST. Assessment activities completed during the UST removal were documented in a June 9, 1997 GW/UST-12 UST Closure Report. Soil samples were collected from the sidewalls and base of the UST basin following the removal of each UST, as well as from stockpiled soil excavated during UST removal. Total petroleum hydrocarbons (TPH) exceeded the North Carolina Department of Environmental Quality (NCDEQ) Action Levels in soil samples collected from the base of the gasoline and diesel UST pits, as well as the sidewall of the diesel UST pit. No additional assessment activities related to the UST release were documented. The release incident was reported to the NCDEQ UST Fayetteville Regional Office and assigned the incident number 19068. The incident is currently in the response phase. 1998 Fuel Oil Removal Activities In February 1998, Trigon Engineering Consultants, Inc (Trigon) completed fuel oil removal activities at the Site. The fuel oil removal activities were documented in a February 27, 1998 Progress Report of Fuel Oil Removal Activities. According to the report, fuel oil had been 3 \\HHFS01\MasterFiles\AAA-Master Projects\Brooks Pierce\Erwin Mill (BRP.001)\Brownfields Assessment Work Plan\REV 1 to DEQ\Brownfields Assessment Work Plan Rev 1_Erwin Mill_(BPN 22058-18-043).doc observed in monitoring well MW-2, located inside the dye house. The thickness of the fuel oil was three feet prior to removal activities. Over the course of four days, the well was pumped dry repeatedly and then allowed to recharge until the thickness of the fuel oil had been reduced to approximately two inches. Trigon estimated that a total of two gallons of fuel oil and 23 gallons of impacted groundwater were removed from MW-2. Previous assessment activities related to the fuel oil in the dye house area had reportedly been conducted in 1993 and 1994; however, no documents from those assessments were identified or provided. ECS 2001 Phase II ESA In June 2001, ECS, LTD (ECS) completed soil and groundwater assessment activities at the Site. The assessment activities were documented in a September 6, 2001 Phase II ESA. Sampling was conducted to investigate areas of potential environmental concern identified during a site visit and conversations with Swift Denim personnel. As a part of field activities, four existing site monitoring wells downgradient of the dye house (MW-7 through MW-10) were sampled, seven groundwater samples were collected via direct-push technologies (DPT), in areas of concern throughout the Site, and soil samples and wipe samples were collected adjacent to the 16 on-site transformers. Groundwater sample results indicated that chloroform, benzene, and naphthalene were detected in groundwater at concentrations above North Carolina 2L Groundwater Quality Standards (2L Standards) in the southeastern portion of the site near the warehouse storage area and former coal power plant. Chrysene was detected in groundwater above the 2L Standard in the northern portion of the site near the former manufacturing buildings. Lead was detected in groundwater above the 2L Standard in the vicinity of the former dye house. The polychlorinated biphenyl (PCB) Aroclor-1260 and/or Aroclor-1254 were detected in composite soil samples within the vicinity of five PCB-containing electrical transformers. 4 \\HHFS01\MasterFiles\AAA-Master Projects\Brooks Pierce\Erwin Mill (BRP.001)\Brownfields Assessment Work Plan\REV 1 to DEQ\Brownfields Assessment Work Plan Rev 1_Erwin Mill_(BPN 22058-18-043).doc W&R 2015 Phase I ESA Withers & Ravenel, Inc (W&R) conducted a Phase I ESA, dated March 27, 2015. W&R identified the following recognized environmental conditions (RECs) in connection with the Site: • Historical textile manufacturing operations; • Contaminated soils associated with former USTs; • PCB transformers; • Backfilling the reservoir with demolition debris; and • Waste drums remaining on-Site from plant operation. The Site was occupied by a denim textile mill that utilized USTs and ASTs containing diesel, gasoline, dyes, sulfuric acid, ammonia, and other petroleum and solvent based hazardous materials. The mill operated since 1904 and typical processes included dyeing, sanforizing, bleaching, finishing, and cleaning fabrics. Trench drains throughout the facility were piped to an off-Site wastewater treatment facility. A large reservoir was utilized as a waste dye lagoon in the southwestern portion of the Site. Vehicle and equipment maintenance areas were also present at the Site and included activities such as welding. In addition, PCB-containing transformers have been present on the Site throughout mill operations. Subsequent to the termination of textile mill activities, equipment and materials were removed and several buildings were demolished. Building demolition materials have been utilized to backfill the reservoir. W&R concluded that there was significant potential for impact to the Site from historical activities. H&H 2018 Assessment and Waste Disposal Activities In May 2018, H&H conducted soil assessment activities at the Site to evaluate the potential impacts of the former aboveground storage tanks (ASTs) to the south of the reservoir. In July 2018, H&H collected a sample of tar-like material originating from a seam in the concrete slab of the former cotton blending/opening building in the central portion of the Site. In addition, H&H oversaw the characterization and removal of materials in the drum storage area in the northern portion of the Site, as well as paint and related materials abandoned by a tenant operating a paint recycling shop out of a warehouse in the southeastern portion of the Site. These activities were documented in a September 21, 2018 Assessment & Waste Disposal Summary Report. 5 \\HHFS01\MasterFiles\AAA-Master Projects\Brooks Pierce\Erwin Mill (BRP.001)\Brownfields Assessment Work Plan\REV 1 to DEQ\Brownfields Assessment Work Plan Rev 1_Erwin Mill_(BPN 22058-18-043).doc TPH diesel range organics (DRO) were detected at concentrations above the NCDEQ Action Level in soil in the vicinity of the former 1,000,000-gallon heating oil AST and two 150,000-gallon heating oil ASTs. Detected TPH DRO concentrations ranged from 295 mg/kg to 15,500 mg/kg. Two composite samples from the soil stockpile located at the former 1,000,000-gallon fuel oil AST pad indicated concentrations of TPH DRO above the NCDEQ Action Level and chromium above NCDEQ Preliminary Soil Remediation Goals (PRSG). Semi-volatile organic compounds (SVOCs), including benzo[a]anthracene, benzo[a]pyrene, benzo[b]fluoranthene, and indeno[1,2,3-cd]pyrene, were detected above NCDEQ PSRGs in one of the soil stockpile composite samples. In addition, TPH DRO was detected in a sample of tar-like material that was oozing up from a seam in the concrete slab of the former cotton blending building at a concentration of 2,380 mg/kg. 1.3 Areas of Concern Assessment activities, including assessment of groundwater, soil, sub-slab gas, surface water, and sediment, have been developed based upon a review of Site history, prior chemical usage and waste management, and previous assessment activities that have been conducted at the Site. Based on our review of the available information, as well as discussions with the DEQ Brownfields Program during the previously mentioned Data Gap meeting, potential areas of concern (AOCs) were identified for further assessment. Each AOC and the rationale for further assessment is described below. AOC #1: Manufacturing Buildings Operations performed in the manufacturing buildings included spinning, blending, carding, beaming, dyeing, sanforizing, finishing, and inspections. The Phase I ESA also referenced machine shops, welding, a carpenter shop, chemical storage and mixing areas, drum wash areas, research and development lab areas, and shipping/receiving areas in the manufacturing buildings. Chemicals would have been associated with many of these operations. Following shut-down of the manufacturing facility, drums across the facility from various locations were consolidated into a single drum storage area in one of the northernmost manufacturing buildings. Trench-style 6 \\HHFS01\MasterFiles\AAA-Master Projects\Brooks Pierce\Erwin Mill (BRP.001)\Brownfields Assessment Work Plan\REV 1 to DEQ\Brownfields Assessment Work Plan Rev 1_Erwin Mill_(BPN 22058-18-043).doc floor drains are located in several of the buildings, which lead to a WWTP located approximately 0.5 miles southwest of the Site. The WWTP was formerly operated by the textile mill owners, but is currently owned and operated by Harnett County and is not located on the Site property. No assessment has been performed in the interior of the manufacturing buildings, other than collection of wipe samples around two interior PCB transformers (discussed transformer discussion below). Groundwater samples were collected at several locations around the exterior of the manufacturing building during the 2001 Phase II ESA and analyzed for VOCs and SVOCs. The results of the sampling indicated concentrations of 1,1-dichloroethane and chrysene at concentrations exceeding 2L Standards. Due to the potential for releases from chemical use during textile mill operations, additional groundwater, soil, and sub-slab gas assessment is proposed in the manufacturing buildings. AOC #2: Dye House and Former Dye House The dye house contained subsurface stainless-steel vaults to store dyes used in the dyeing process. Subgrade pits, heavily stained with dyes, were observed in the dye house. Drains in the dye house lead to an adjacent reservoir (see reservoir discussion below). One historical 1925 Sanborn map also references a second dye house in the eastern portion of plant which has not been assessed. The second dye house stopped operations prior to 1980. Monitoring wells were installed in the area of the dye house in 1992 and 1993; however, reports documenting the 1992-1993 investigation were not available to H&H. The 1998 Fuel Oil Progress report indicated that free product was present in MW-2, located downgradient of the dye pits. Free product was measured to be 1.2 feet thick in MW-2 during an April 2019 Site visit. However, free product was not observed in wells MW-3 through MW-5. During the 2001 Phase II ESA, samples were collected from the downgradient monitoring wells (MW-7 through MW-10) for analysis of VOCs, SVOCs, and metals. The results of the sampling indicated arsenic, chromium, and lead at concentrations above 2L Standards. These detections may be associated with metals present in the dyes used in the manufacturing operation or natural background conditions. Due to the presence of free product and previous detections of metals 7 \\HHFS01\MasterFiles\AAA-Master Projects\Brooks Pierce\Erwin Mill (BRP.001)\Brownfields Assessment Work Plan\REV 1 to DEQ\Brownfields Assessment Work Plan Rev 1_Erwin Mill_(BPN 22058-18-043).doc downgradient of the dye house, as well as the potential for releases from dying activities in the second dye house, additional groundwater, soil, and sub-slab gas sampling is proposed in the area of the dye houses. AOC #3: Warehouse Buildings Four sets of warehouse buildings are located in the southwestern portion of Site. These warehouses were used primarily for cotton storage, which does not generally represent an environmental concern. However, the warehouses were also used for garage space, dye storage, battery charging locations, truck and equipment maintenance activities, and storage of virgin and waste automobile fluids. Additionally, former train spurs entered the Site in the area of the warehouses, primarily to off-load coal for the coal-fired power plant. Groundwater samples were collected in the area of the warehouse buildings during the 2001 Phase II ESA and analyzed for VOCs and SVOCs. The results of the sampling indicated no exceedances of 2L Standards except for chloroform. The 2L Standard for chloroform has increased since the date of the Phase II ESA and the detections are below the current standard. Based on the potential for releases from historic uses within the warehouse buildings, additional soil and sub-slab gas assessment is proposed within the warehouse storage buildings. AOC #4: Reservoir A reservoir was constructed at the site in approximately 1903. It is reportedly 20 feet deep and lined with concrete. The reservoir was initially used to store water for the fire suppression system, but was converted to waste dye storage. The reservoir was used to control amount of waste dyes released to the WWTP. After the property was purchased by Schwarz Auman, the reservoir was partially filled with building demolition debris. The demolition debris was generated during the demolition of the coal fired power plant, former cotton blending/opening building, a warehouse, and the dye house storage building. The reservoir is located in the same general area as the dye house, so heavy metals detected in the dye house area discussed above may also be present at the reservoir. Placement of building demolition debris in the reservoir also represents a potential concern. If the building demolition debris contained no hazardous materials, then placement of the debris in the reservoir may be acceptable. However, depending 8 \\HHFS01\MasterFiles\AAA-Master Projects\Brooks Pierce\Erwin Mill (BRP.001)\Brownfields Assessment Work Plan\REV 1 to DEQ\Brownfields Assessment Work Plan Rev 1_Erwin Mill_(BPN 22058-18-043).doc on the source for the debris, the potential exists for hazardous substances to be in the debris. Based on the historical use for storing waste dyes and current present of demolition debris, additional surface water, sediment, and demolition debris assessment is proposed within the reservoir. AOC #5: Polychlorinated Biphenyl (PCB) Transformers A total of 33 pad-mounted transformers were present across the Site historically. A total of 16 transformers contained PCB-laden oils, while the remaining 17 transformers utilized PCB-free oils. The current property owner removed four of the PCB transformers, but 12 remain at the Site. An electrical substation is also located at the Site, but the substation is owned by Duke Energy. The remaining transformers were owned by the Site property owner. A total of 14 hand auger borings were advanced adjacent to PCB-containing transformers during the 2001 Phase II ESA. Samples were screened using a PID, which indicated elevated readings (greater than 1,999 parts per million) in several locations. Samples were also submitted for laboratory analysis of PCB Arochlors by EPA Method 8082. Arochlor concentrations exceed the current Residential and Industrial PSRGs in multiple locations. Based on the presence of Arochlors in the area of PCB transformers, soil assessment for PCB congeners is proposed at the PCB transformers with the greatest exceedances. AOC #6: Coal Fired Power Plant A coal fired power plant was located in the central portion of the Site. The coal fired power plant was demolished after the property was purchased by Schwarz Auman. Coal was delivered via a rail spur, then the coal was stored in open coal storage area next to the tracks and two silos next to boiler house. Coal ash was stored in a silo adjacent to the boiler house then hauled to a landfill for disposal. One groundwater sample was collected in the area of the coal storage area during the 2001 Phase II ESA. The sample was analyzed for VOCs and SVOCs; however, the samples were not analyzed for metals, which represent the primary concern for this source area. Based on the potential releases associated with the coal fired power plant and coal storage areas, soil assessment is proposed for the coal fire power plant. 9 \\HHFS01\MasterFiles\AAA-Master Projects\Brooks Pierce\Erwin Mill (BRP.001)\Brownfields Assessment Work Plan\REV 1 to DEQ\Brownfields Assessment Work Plan Rev 1_Erwin Mill_(BPN 22058-18-043).doc AOC #7: Fuel Oil Boiler Building A fuel oil boiler building was located in the central portion of the Site, adjacent to the former coal fired power plant. One caustic soda AST (size unknown) and several smaller ASTs with unknown content (likely fuel oil) were present in the fuel oil boiler building. A portion of the building was demolished after the property was purchased by Schwarz Auman. One groundwater sample was collected in the fuel oil boiler building during the 2001 Phase II ESA. The sample was analyzed for VOCs and SVOCs. Concentrations of benzene and naphthalene were detected above the 2L Standard. Based on the potential for releases from former fuel oil use and the presence of petroleum-related constituents, additional soil and groundwater assessment is proposed for the fuel oil boiler building. AOC #8: Underground Storage Tanks (USTs) One 2,000-gallon gasoline UST and one 1,000-gallon diesel UST were removed from the Site in 1997. Soil samples collected from the sidewalls and base of the UST basin following the removal of each UST, as well as from stockpiled soil excavated during UST removal, indicated exceedances of regulatory standards. The release incident was reported to the NCDEQ UST Fayetteville Regional Office and assigned the incident number 19068. The incident is currently in the response phase. One gasoline AST and one diesel AST (sizes unknown) replaced the USTs. One groundwater sample collected in the vicinity of the ASTs and USTs during the 2001 Phase II ESA indicated no exceedances of 2L Standards for VOCs or SVOCs. Based on the presence of petroleum-related constituents following the UST removal activities and active status of the release incident, additional soil assessment is proposed for the former UST area. AOC #9: Aboveground Storage Tanks (ASTs) A total of 35 ASTs was used at the Site. All of the ASTs have reportedly been removed except for a 450,000-gallon tank used to store water along the northern edge of the Site. Areas where multiple ASTs were located in proximity to each other have been designated as separate AOCs as discussed further below. Note that the ASTs referenced below do not include tanks that are not considered a concern due to non-hazardous or gaseous contents. These ASTs include a 450,000-gallon tank used to store water along the northern edge of the Site, a 10 \\HHFS01\MasterFiles\AAA-Master Projects\Brooks Pierce\Erwin Mill (BRP.001)\Brownfields Assessment Work Plan\REV 1 to DEQ\Brownfields Assessment Work Plan Rev 1_Erwin Mill_(BPN 22058-18-043).doc 100,000-gallon water tank located north of the reservoir, six 30,000-gallon liquid propane tanks located south of the reservoir, one liquid carbon dioxide tank (size unknown) located south of the reservoir, six tanks containing unknown compressed gases (size unknown) located east of the reservoir, and one propane tank located south of the boiler house. AOC #9a: Reservoir Area ASTs - Multiple ASTs were located in the reservoir area, including a 1,000,000-gallon #6 fuel oil tank located south of the reservoir, two 150,000-gallon #6 fuel oil tanks located south of the reservoir, a 100,000-gallon #2 fuel oil tank located north of the reservoir, three indigo dye tanks (size unknown) located north of the reservoir, two brine tanks (size unknown) located north of the reservoir, and three tanks with unknown contents (size unknown) located north of the reservoir. Groundwater samples were collected in the general area of the reservoir during the 2001 Phase II ESA and analyzed for VOCs, SVOCs, and metals. The results of the sampling indicated concentrations of heavy metals above 2L Standards, but no concentrations of VOCs or SVOCs at concentrations above 2L Standards. Soil samples collected in the vicinity of the former #6 fuel oil tanks to the south of the reservoir indicated exceedances of the NCDEQ action levels for TPH DRO. Based on the previous detections of metals and petroleum-related constituents in the area of the reservoir ASTs, additional soil and groundwater assessment is proposed. AOC #9b: Northern ASTs - Two anhydrous ammonia and three ammonium hydroxide tanks (sizes unknown) were located along the northern edge of the Site. No assessment has been performed to evaluate for releases of ammonia from these tanks. Based on the potential for releases from these ASTs, soil assessment is proposed in the vicinity of the ASTs. 11 \\HHFS01\MasterFiles\AAA-Master Projects\Brooks Pierce\Erwin Mill (BRP.001)\Brownfields Assessment Work Plan\REV 1 to DEQ\Brownfields Assessment Work Plan Rev 1_Erwin Mill_(BPN 22058-18-043).doc AOC #10: Downgradient Receptors Several drainage ditches, a potential wetland area, and an intermittent, unnamed tributary to Juniper Creek are located on the Site. These water bodies are downgradient of former mill operations. No surface water or sediment assessment has been performed to evaluate for releases to these areas. Based on the potential for impacts from former mill operations, groundwater, surface water, and sediment assessment are proposed for areas downgradient of potential sources. Our detailed proposed scope of work is outlined in the following sections. 12 \\HHFS01\MasterFiles\AAA-Master Projects\Brooks Pierce\Erwin Mill (BRP.001)\Brownfields Assessment Work Plan\REV 1 to DEQ\Brownfields Assessment Work Plan Rev 1_Erwin Mill_(BPN 22058-18-043).doc 2.0 Brownfields Assessment Scope of Work The proposed assessment activities will be performed in general accordance with the DEQ Inactive Hazardous Sites Branch (IHSB) Guidelines for Assessment and Cleanup (Guidelines) dated October 2015, the DEQ Division of Waste Management (DWM) Vapor Intrusion Guidance (VI Guidance) dated March 2018, and most recent versions of the U.S. Environmental Protection Agency (EPA) Region IV Science and Ecosystem Support (SESD) Field Branches Quality System and Technical Procedures guidance. Prior to conducting the field activities, H&H will contact North Carolina 811, the public utility locator, to mark subsurface utilities located on the Site. H&H will also contract with a private utility locator to screen proposed sample locations for subgrade utilities that may not be marked by the public locator. Lastly, prior to conducting the assessment, H&H will prepare a site-specific Health and Safety Plan in accordance with Occupational Health and Safety Administration (OSHA) requirements. 2.1 Brownfields Receptor Survey H&H will perform a Brownfields receptor survey in accordance with DEQ Brownfields Section guidance. The receptor survey will utilize the Brownfields Property Receptor Survey Form and will include information about land use in the Site area including zoning. H&H will also conduct a field search for water supply wells, basements, utility manways and chases, storm sewers, other underground utilities, drains, and surface water within a 1,500 ft radius of the Brownfields property boundaries. 2.2 Monitoring Well Installation Activities H&H proposes to install ten permanent Type II groundwater monitoring wells to identify any constituents in areas of concern and evaluate current conditions in historically impacted areas. 13 \\HHFS01\MasterFiles\AAA-Master Projects\Brooks Pierce\Erwin Mill (BRP.001)\Brownfields Assessment Work Plan\REV 1 to DEQ\Brownfields Assessment Work Plan Rev 1_Erwin Mill_(BPN 22058-18-043).doc Proposed monitoring well locations are depicted on Figure 3, and described below. Table 1 provides details on sampling rationale and sample analyses. • North of the ammonia finishing building on the northern portion of the Site and in the vicinity of waste water sewer system effluent for the Site; • East of the ammonia storage and compressor area in the northern portion of the Site where previous 1,1-dichloroethane detections were located; • Alongside trench drains located within the finishing building in the central portion of the Site; • Within the fuel oil boiler building where previous benzene and naphthalene detections were located; • Within the former chemical storage area northeast of the reservoir where fuel oil, dyes and unknown chemicals were located and where previous metal detections were located; • Northwest of the reservoir where waste dye was discharged into the waste water sewer system for transport to the off-Site WWTP; • West of the warping building on the western portion of the Site and in the vicinity of the waste water sewer system effluent for the Site; and • Downgradient of the dye house, reservoir, and fuel oil ASTs and upgradient of the unnamed tributary to Juniper Creek. Each monitoring well will be installed utilizing hollow stem auger drilling methods by a licensed NC driller. During drilling, soil samples will be collected and logged for lithologic description and field screened for presence of staining and elevated concentrations of volatile organic vapors using a PID. The monitoring wells will be constructed in accordance with the North Carolina well construction regulations. The monitoring wells will be constructed of 2-inch diameter PVC with 10 ft of well screen set to bracket the water table and 2-inch diameter PVC well casing to the ground surface. All monitoring wells within the fenced or paved areas of the Site will be completed flush with the ground surface within flush mount manholes secured with 2 ft by 2 ft concrete pads. All monitoring wells located in highly vegetated areas outside the fenced 14 \\HHFS01\MasterFiles\AAA-Master Projects\Brooks Pierce\Erwin Mill (BRP.001)\Brownfields Assessment Work Plan\REV 1 to DEQ\Brownfields Assessment Work Plan Rev 1_Erwin Mill_(BPN 22058-18-043).doc areas of the Site will be completed above the ground surface within above ground steel protective covers. Following installation, the new monitoring wells will be developed utilizing bailers and/or pumps by removing a minimum of 3 to 5 well volumes and observing stable field parameters (i.e. pH ± 0.1 SU and conductivity varies no more than 5%). Development water and drill cuttings will be containerized in 55-gallon drums, as discussed in Section 4.0. Following well installation activities, the horizontal and vertical locations for all of the Site monitoring wells will be surveyed by a North Carolina licensed surveyor. 2.3 Groundwater Sampling Activities Following monitoring well installation, groundwater samples will be collected from the newly installed monitoring wells and existing Site monitoring wells MW-2 through MW-5. Prior to groundwater sample collection, each monitoring well will be tested for the presence of free product utilizing a decontaminated oil/water interface meter. If free product is observed within any of the monitoring wells, the thickness of free product will be recorded and a groundwater sample will not be collected. If free product is not observed, a groundwater sample will be collected utilizing low flow/low stress purging techniques using a peristaltic pump and dedicated polyethylene tubing. The intake point of the pump tubing will be placed approximately in the mid-portion of the screened interval of the well and groundwater will be removed at a rate no greater than 200 milliliters per minute. H&H will utilize a water quality meter to measure pH, temperature, dissolved oxygen, oxidation reduction potential, turbidity, and specific conductivity at 3 to 5-minute intervals during purging. Purging will be considered complete when water quality parameters stabilize (i.e. pH ± 0.1 SU, conductivity varies no more than 5%, and turbidity is less than 10 NTUs). 15 \\HHFS01\MasterFiles\AAA-Master Projects\Brooks Pierce\Erwin Mill (BRP.001)\Brownfields Assessment Work Plan\REV 1 to DEQ\Brownfields Assessment Work Plan Rev 1_Erwin Mill_(BPN 22058-18-043).doc Once groundwater parameters stabilize, groundwater samples for VOCs analyses will be collected directly into laboratory supplied sample containers using the “soda straw” method to eliminate the potential for volatile loss through the peristaltic pump head. Samples for SVOCs and metals will be collected directly into the containers through the peristaltic pump. The sample containers will be labeled with the sample identification, date, and requested analysis, and placed in a laboratory supplied cooler and iced. The samples will be delivered to a North Carolina certified laboratory under standard chain of custody protocols for analysis of VOCs by EPA Method 8260B, SVOCs by EPA Method 8270D SIM, and Resource Conservation and Recovery Act (RCRA) metals (arsenic, barium, cadmium, chromium, lead, mercury, selenium, and silver) plus hexavalent chromium by EPA Methods 6020/7471B/7196A. 2.4 Soil, Debris, and “Tar-Like” Material Assessment Activities H&H proposes to conduct soil assessment activities to evaluate current subsurface conditions for potential impacts. H&H will team with a qualified drilling contractor to advance soil borings to depths ranging from approximately 5 to 15 ft bgs. Proposed soil sample locations are depicted on the sample location map, which is presented as Figure 4. Prior to advancing soil borings, the boreholes will be cleared for utilities by hand auger to a depth of 5 ft bgs. The soil borings will be advanced utilizing a track-mounted direct push technology (DPT) drill rig. Continuous soil samples will be collected from the borings using acetate lined macrocore sleeves. Soil samples will be logged for lithological description and field screened for indication of potential impacts by observation for staining, and the presence of organic vapors using a calibrated PID. Up to two soil samples will be collected from each soil boring, unless otherwise stated. The proposed sampling depths of each sample is summarized on Table 2. One sample will be collected at the surficial soil (0-1 ft bgs) interval and one soil sample will be collected from each soil boring from the subsurface (>1 ft bgs) depth interval interpreted most likely to be impacted based on field observations and PID readings. If there are no obvious indications of potential impact based on field screening results, then the subsurface soil sample will not be collected. 16 \\HHFS01\MasterFiles\AAA-Master Projects\Brooks Pierce\Erwin Mill (BRP.001)\Brownfields Assessment Work Plan\REV 1 to DEQ\Brownfields Assessment Work Plan Rev 1_Erwin Mill_(BPN 22058-18-043).doc Following collection, the soil samples will be placed in dedicated laboratory-supplied sample containers, labeled with the sample identification, date, and requested analysis, and placed in a laboratory supplied cooler with ice. Soil samples will be submitted to a North Carolina certified laboratory under standard chain of custody protocols for analyses as referenced in Table 2 and summarized below: • Up to two samples will be collected from 28 borings advanced in the dye houses, shop area, warehouses, research and development lab, former chemical storage area, coal fired power plant, fuel oil boiler building, former UST locations, and the former 1,000,000-gallon and 150,000-gallon fuel oil ASTs. The samples will be submitted for analysis of VOCs by EPA Method 8260B, SVOCs by EPA Method 8270D, and RCRA metals (arsenic, barium, cadmium, chromium, lead, mercury, selenium, and silver) plus hexavalent chromium by EPA Methods 6020/7471B/7196A. • Up to two soil samples will be collected from two soil borings advanced in the ammonia storage/compressor area. Soil samples will be submitted for analysis of ammonia by EPA Method 4500 and nitrate and nitrite by EPA Method 300.0. • Three soil samples will be collected at a depth of 4 ft bgs from soil borings advanced in the vicinity of the three former PCB transformers with the highest concentrations of previous PCB detections. Soil samples will be submitted for analysis of PCB congeners by EPA Method 1668A. • Up to eight soil samples will be collected from background locations at the site. The soil samples will be submitted for analysis of RCRA metals plus hexavalent chromium by EPA Method 6020/7471B/7196A. Following sampling activities, borings will be properly abandoned and the surfaces will be repaired similar to pre-drilling conditions. Additionally, exterior soil sample locations will be estimated using a hand-held global positioning system (GPS) unit and interior sample locations will be estimated by measuring from known benchmarks (e.g. doorways, walls, etc.). 17 \\HHFS01\MasterFiles\AAA-Master Projects\Brooks Pierce\Erwin Mill (BRP.001)\Brownfields Assessment Work Plan\REV 1 to DEQ\Brownfields Assessment Work Plan Rev 1_Erwin Mill_(BPN 22058-18-043).doc In addition, H&H will collect debris samples from two locations inside the reservoir and one sample of the “tar-like” material observed at the seam in the concrete slab of the former cotton blending building. Debris samples will be collected by advancing a decontaminated stainless-steel hand auger into the reservoir material until demolition debris is encountered. A debris sample will be collected and placed in dedicated laboratory-supplied sample containers, labeled with the sample identification, date, and requested analysis, and placed in a laboratory supplied cooler with ice. The “tar-like” material will be collected directly into a dedicated laboratory-supplied container. Debris and “tar-like” material samples will be submitted to a North Carolina certified laboratory under standard chain of custody protocols for analysis of VOCs by EPA Method 8260B, SVOCs by EPA Method 8270D, RCRA metals plus hexavalent chromium by EPA Method 6020/7471B/7196A. The debris samples will also be submitted for analysis of asbestos as bulk material by polarized light microscopy (PLM) by EPA Method 600. 2.5 Sub-Slab Gas Assessment Activities H&H proposes to install and sample temporary sub-slab gas monitoring points to evaluate the potential for vapor intrusion at the Site. A total of 29 sub-slab gas samples will be collected throughout the Site, with a higher sampling density in areas of concern (i.e. machine shop, dye houses, finishing building). If preferential pathways, such as sewer liners, are known to be present within a sample area, the sub-slab monitoring point will be installed adjacent to those pathways. The proposed sub-slab gas sample locations are shown on Figure 5. Sample IDs, locations, rationale and analyses are provided on Table 3. H&H will install a Cox-Colvin Vapor Pin® (vapor pin) at each proposed sub-slab gas sample location. For installation of the vapor pin, a hammer drill with a 5/8-inch diameter bit will be utilized to penetrate the concrete slab with a drilled pilot hole. The vapor pin assembly (sampling point and silicone sleeve) will then be placed into the pilot hole and secured using an installation/extraction tool and a “dead blow” hammer to form an air-tight seal. Once the vapor pin assembly has been secured in the pilot hole, ¼-inch diameter Teflon® sample tubing will be attached to the vapor pin assembly sample port barb. During the vapor pin installation, H&H will document encountered material present immediately beneath the concrete slab, i.e. gravel, sand, clay, etc. 18 \\HHFS01\MasterFiles\AAA-Master Projects\Brooks Pierce\Erwin Mill (BRP.001)\Brownfields Assessment Work Plan\REV 1 to DEQ\Brownfields Assessment Work Plan Rev 1_Erwin Mill_(BPN 22058-18-043).doc After installation of the vapor pins and prior to sample collection, a leak check will be conducted at each sample location by constructing a shroud around the sampling point, sampling fittings, and sampling connections, and flooding the air within the shroud with helium gas. Helium within the shroud will be monitored using a helium gas detector. Using a syringe and a three-way valve, the sample point will be purged. A sub-slab gas sample will then be collected outside of the shroud into a Tedlar® bag and analyzed using the helium gas detector to ensure that helium concentrations are less than 10% of the concentration in the shroud. Following a successful leak check, sub-slab gas samples will be collected in laboratory-supplied 1 liter (or greater volume) stainless steel Summa canisters connected to in-line flow controllers with a laboratory calibrated vacuum gauge. The flow controller will be connected to the sample tubing at each sampling point using a brass nut and ferrule assembly to form an air-tight seal. The flow regulator will be pre-set by the laboratory to regulate the intake rate to approximately 100 milliliters per minute. Once the sample train is assembled, the intake valve on the canister will be fully opened to begin collection of the sub-slab gas sample. Vacuum readings on the Summa canister will be recorded prior to and following the sampling period to ensure adequate sample volume was collected. A vacuum will be maintained within the canisters at the conclusion of the sampling event. To evaluate the reproducibility of the sample results, two duplicate sub-slab gas samples will be collected using a laboratory-supplied T-sampler which allows collection of two samples from a single sample port simultaneously. Upon completion of sample collection, each Summa canister’s valve will be closed and the regulator will be disconnected from the canister. The canisters will be placed in laboratory-supplied shipping containers, properly labeled, and shipped under standard chain-of-custody protocols to a qualified laboratory for analysis of volatile organic compounds (VOCs) by EPA Method TO-15. Upon completion of sampling activities, the sub-slab gas sample points will be abandoned and the surface will be repaired similar to pre-drilling conditions. Each sample location will be estimated by measuring from known benchmarks (e.g. doorways, walls, etc.). 19 \\HHFS01\MasterFiles\AAA-Master Projects\Brooks Pierce\Erwin Mill (BRP.001)\Brownfields Assessment Work Plan\REV 1 to DEQ\Brownfields Assessment Work Plan Rev 1_Erwin Mill_(BPN 22058-18-043).doc 2.6 Surface Water and Sediment Assessment Activities H&H proposes to collect six co-located surface water and sediment samples for laboratory analysis from the reservoir, potential wetland area downgradient of the reservoir, and the downgradient unnamed tributary to Juniper Creek. Co-located surface water and sediment sample locations are shown on Figure 6. If necessary, H&H will utilize a small boat to access the sampling location in the reservoir. H&H will utilize water quality meters to collect measurements of pH, temperature, dissolved oxygen, oxidation reduction potential, turbidity, and specific conductivity of surface water at each sample location. Surface water will be collected directly into laboratory-supplied sample containers. Sediment samples will be collected from the base of the surface water body at each sample location using a decontaminated stainless steel AMS dredge sampler or other suitable method. The sample containers will be labeled with the sample identification, date, and requested analysis, and placed in a laboratory supplied cooler and iced. The surface water and sediment samples will be delivered to a North Carolina certified laboratory under standard chain of custody protocols for analysis of VOCs by EPA Method 8260B, SVOCs by EPA Method 8270D SIM, and RCRA metals plus hexavalent chromium by EPA Methods 6020/7471B/7196A. Upon completion of sampling, the co-located surface water and sediment sample locations will be estimated using a hand-held GPS unit. 20 \\HHFS01\MasterFiles\AAA-Master Projects\Brooks Pierce\Erwin Mill (BRP.001)\Brownfields Assessment Work Plan\REV 1 to DEQ\Brownfields Assessment Work Plan Rev 1_Erwin Mill_(BPN 22058-18-043).doc 3.0 Quality Assurance / Quality Control Laboratory quality assurance/quality control (QA/QC) procedures will be employed to ensure appropriate sample handling and analysis and to aid in the review and validation of the analytical data. QA/QC procedures will be conducted in accordance with DEQ and EPA method protocols and will include regular equipment maintenance, equipment calibrations, and adherence to specific sample custody and data management procedures. In accordance with approved methodologies, samples will be analyzed in conjunction with appropriate blanks, laboratory duplicates, continuing calibration standards, and surrogate standards to monitor both instrument and analyst performance. H&H will request that the laboratory reporting limits for each analyte will be at or below appropriate screening criteria. Additionally, H&H will request that the laboratory include J Flags, which are estimated concentrations for compounds that are detected at levels above the laboratory method detection limits, but below the laboratory reporting limits. The following activities will be conducted by H&H for QA/QC purposes: • non-dedicated equipment and tools will be decontaminated prior to use at each boring or sampling location, or following exposure to soil or groundwater. A rinseate blank will be collected per sample equipment type per matrix during assessment activities; • one duplicate sample will be collected per every 20 samples per sampling media per analytical method during assessment activities; • one MS/MSD sample will be collected per every 20 samples per sampling media per analytical method during assessment activities; and • one trip blank per shipment will accompany groundwater and surface water samples during field and shipping activities. The trip blank will be analyzed for VOCs by EPA Method 8260B. Laboratory analyses for proposed QA/QC sampling is referenced in Table 1. A copy of the laboratory analytical data report and QA package for each group of samples submitted to and analyzed by the subcontracted laboratory will be provided in an appendix to the final report. 21 \\HHFS01\MasterFiles\AAA-Master Projects\Brooks Pierce\Erwin Mill (BRP.001)\Brownfields Assessment Work Plan\REV 1 to DEQ\Brownfields Assessment Work Plan Rev 1_Erwin Mill_(BPN 22058-18-043).doc Laboratory QA data consistent with Level II documentation will be requested for this project. A copy of the completed chain-of-custody record will be appended to the corresponding laboratory analytical report included with the final report. 22 \\HHFS01\MasterFiles\AAA-Master Projects\Brooks Pierce\Erwin Mill (BRP.001)\Brownfields Assessment Work Plan\REV 1 to DEQ\Brownfields Assessment Work Plan Rev 1_Erwin Mill_(BPN 22058-18-043).doc 4.0 Investigative Derived Waste Investigation derived waste (IDW) generated during the assessment activities will be containerized and characterized. The IDW anticipated to be generated during assessment activities includes soil cuttings, purge water, and decontamination water. This IDW will be containerized in 55-gallon drums pending off-Site disposal. A composite soil sample of the IDW soil drums will be collected and submitted for laboratory analysis of toxic characteristic leaching procedure (TCLP) VOCs by EPA Method 8260, TCLP SVOCs by EPA Method 8270, and TCLP RCRA Metals by EPA Method 6010/6020. A composite water sample of the IDW liquid drums will be collected and submitted for laboratory analysis of VOCs by EPA Method 8260, SVOCs by EPA Method 8270, and RCRA metals by EPA Method 6010/6020. The IDW will be properly disposed at an off-Site facility based on the analytical results. 23 \\HHFS01\MasterFiles\AAA-Master Projects\Brooks Pierce\Erwin Mill (BRP.001)\Brownfields Assessment Work Plan\REV 1 to DEQ\Brownfields Assessment Work Plan Rev 1_Erwin Mill_(BPN 22058-18-043).doc 5.0 Reporting Following completion of the assessment activities and receipt of the analytical data, H&H will document our findings in a Brownfields assessment report. The report will include the following: • a narrative description of how assessment activities were conducted, including a discussion of any variances from the Work Plan; • a description of field and laboratory quality control and quality assurance procedures followed; • a description of procedures used to manage investigative derived waste; • a discussion of the analytical data in comparison to regulatory screening levels, evaluation of the sub-slab gas data using the DEQ Risk Calculator, and conclusions and recommendations concerning our activities; • tabulation of analytical results and copies of laboratory reports including quality assurance/quality control documentation; • a figure depicting sample locations, a groundwater potentiometric map, and figures depicting analytical results; and • completed lithology logs and monitoring well records. The Brownfields Assessment Report will be submitted within 60 days following the receipt of all final assessment analytical data. Tables Table 1 (Page 1 of 1) Proposed Groundwater Sampling Locations and Analyses Former Erwin Mill Facility Erwin, North Carolina H&H Job No. BRP-001 \\HHFS01\MasterFiles\AAA-Master Projects\Brooks Pierce\Erwin Mill (BRP.001)\Brownfields Assessment Work Plan\Tables\Tables Table 1 (Page 1 of 1)Hart & Hickman, PC VOCs SVOCs RCRA Metals plus Cr6 8260B 8270D SIM 6020/7471B/7196A MW-2 within dye house presence of free product, potential dye impacts 1 1 1 MW-3 within dye house potential fuel oil and dye impacts 1 1 1 MW-4 within dye house potential fuel oil and dye impacts 1 1 1 MW-5 within dye house potential fuel oil and dye impacts 1 1 1 MW-11 north of ammonia finishing building sewer discharge point - potential preferential pathway for off-Site impacts 1 1 1 MW-12 east of ammonia storage & compressor area previous 1,1-dichloroethane detections 1 1 1 MW-13 within finishing building adjacent to trench drains potential impacts from trench drain leaks 1 1 1 MW-14 within former fuel oil boiler building previous benzene and naphthalene detections 1 1 1 MW-15 within former chemical storage area previous metals detections, potential aboveground storage tank impacts 1 1 1 MW-16 northwest of reservoir potential dye impacts from reservoir discharge to sewer system 1 1 1 MW-17 west of warping building sewer discharge point - potential preferential pathway for off-Site impacts 1 1 1 MW-18 southwest of dye house downgradient of potential source area 1 1 1 MW-19 southwest of reservoir downgradient of potential source area 1 1 1 MW-20 southwest of 1,000,000-gallon and 150,000-gallon ASTs downgradient of potential source area 1 1 1 DUP-GW-1 to be determined QA/QC 1 1 1 MS/MSD to be determined QA/QC 1 1 1 Rinse Blank from WLM QA/QC 1 1 1 Trip Blank N/A QA/QC 118 17 17 Notes: VOCs = volatile organic compounds; SVOCs = semi-volatile organic compounds; RCRA = Resource Conservation and Recovery Act; Cr6 = hexavalent chromium; TBD = to be determined; WLM = water level meter; QA/QC = quality assurance/quality control; N/A = not applicable; DUP = duplicate; MS/MSD = matrix spike/matrix spike duplicate Analyses Sampling RationaleSampling LocationMonitoring Well ID Total Groundwater Samples Existing Monitoring Wells Proposed Monitoring Wells Table 2 (Page 1 of 2) Proposed Soil Sampling Locations and Analyses Former Erwin Mill Facility Erwin, North Carolina H&H Job No. BRP-001 S:\AAA-Master Projects\Brooks Pierce\Erwin Mill (BRP.001)\Brownfields Assessment Work Plan\Tables\Tables Table 2 (Page 1 of 2) Hart & Hickman, PC VOCs SVOCs RCRA Metals plus Cr6 Ammonia Nitrate & Nitrite PCB Congeners PLM Bulk 8260B 8270D 6020/7471B/7196A 4500 300 1668A 600 0-1 1 1 1 TBD TBD TBD TBD 0-1 1 1 1 TBD TBD TBD TBD 0-1 1 1 1 TBD TBD TBD TBD 0-1 1 1 1 TBD TBD TBD TBD 0-1 1 1 1 TBD TBD TBD TBD 0-1 1 1 1 TBD TBD TBD TBD 0-1 1 1 1 TBD TBD TBD TBD 0-1 1 1 1 TBD TBD TBD TBD 0-1 1 1 1 TBD TBD TBD TBD 0-1 1 1 1 TBD TBD TBD TBD 0-1 1 1 1 TBD TBD TBD TBD 0-1 1 1 1 TBD TBD TBD TBD 0-1 1 1 1 TBD TBD TBD TBD 0-1 1 1 1 TBD TBD TBD TBD 0-1 1 1 1 TBD TBD TBD TBD 0-1 1 1 1 TBD TBD TBD TBD 0-1 1 1 1 TBD TBD TBD TBD 0-1 1 1 1 TBD TBD TBD TBD 0-1 1 1 1 TBD TBD TBD TBD 0-1 1 1 1 TBD TBD TBD TBD 0-1 1 1 1 TBD TBD TBD TBD 0-1 1 1 1 TBD TBD TBD TBD 0-1 1 1 1 TBD TBD TBD TBD 0-1 1 1 1 TBD TBD TBD TBDSB-32 former garage/shop potential impacts from repair activities, nearby battery charging SB-30 former dye storage area potential impacts from dye SB-31 former garage/shop potential impacts from repair activities, nearby battery charging SB-28 fuel oil boiler building potential impacts from fuel oil boiler building SB-29 former dye storage area potential impacts from dye SB-26 coal storage area potential impacts from coal, nearby fuel oil boiler building SB-27 former coal fired power plant potential impacts from coal, nearby fuel oil boiler building SB-24 former dye house potential impacts from dye SB-25 former dye house potential impacts from dye SB-22 machine shop potential impacts from machine repair activities SB-23 machine shop potential impacts from machine repair activities SB-20 dye house potential impacts from dye SB-21 dye house potential impacts from dye SB-18 dye house potential impacts from dye and fuel oil SB-19 dye house potential impacts from dye and fuel oil potential impacts from dye, fuel oil, ASTs with unknown contents SB-16 dye house potential impacts from dye SB-17 dye house potential impacts from dye former chemical storage area Analyses Sample RationaleSample LocationSoil Boring ID Sample Depth (ft bgs) former 1,000,000-gallon #6 fuel oil AST location SB-14 SB-15 SB-9 SB-10 SB-11 SB-12 SB-13 previous DRO detections previous DRO detections previous DRO detections previous DRO detections previous DRO detections potential impacts from dye, fuel oil, ASTs with unknown contents former 1,000,000-gallon #6 fuel oil AST location former 1,000,000-gallon #6 fuel oil AST location former 150,000-gallon #6 fuel oil AST location former 150,000-gallon #6 fuel oil AST location former chemical storage area Table 2 (Page 2 of 2) Proposed Soil Sampling Locations and Analyses Former Erwin Mill Facility Erwin, North Carolina H&H Job No. BRP-001 S:\AAA-Master Projects\Brooks Pierce\Erwin Mill (BRP.001)\Brownfields Assessment Work Plan\Tables\Tables Table 2 (Page 2 of 2) Hart & Hickman, PC VOCs SVOCs RCRA Metals plus Cr6 Ammonia Nitrate & Nitrite PCB Congeners PLM Bulk 8260B 8270D 6020/7471B/7196A 4500 300 1668A 600 Analyses Sample RationaleSample LocationSoil Boring ID Sample Depth (ft bgs) 0-1 1 1 1 TBD TBD TBD TBD 0-1 1 1 1 TBD TBD TBD TBD 0-1 1 1 1 TBD TBD TBD TBD 0-1 1 1 1 TBD TBD TBD TBD 0-1 1 1 1 TBD TBD TBD TBD 0-1 1 1 TBD TBD TBD 0-1 1 1 TBD TBD TBD HA-3A 3-4 east of spinning/winding building previous Aroclor-1260 detections 1 HA-26A 3-4 west of ammonia finishing building previous Aroclor-1260 detections 1 HA-27A 3-4 east of warping building previous Aroclor-1260 detections 1 0-1 1 TBD TBD 0-1 1 TBD TBD 0-1 1 TBD TBD 0-1 1 TBD TBD D-1 TBD within reservoir debris potential impacts from demolition debris 1 1 1 1 D-2 TBD within reservoir debris potential impacts from demolition debris 1 1 1 1 OS-2 N/A "tar-like" material at seam in former cotton blending building concrete slab potential hazardous substance 1 1 1 DUP-Soil-1 TBD TBD QA/QC 1 1 1 DUP-Soil-2 TBD TBD QA/QC 1 1 1 MS/MSD-1 TBD TBD QA/QC 1 1 1 MS/MSD-1 TBD TBD QA/QC 1 1 1 Rinse Blank Drill Rods N/A QA/QC 1 1 1 37 37 41 2 2 3 2 66 66 74 4 4 3 2 Notes: VOCs = volatile organic compounds; SVOCs = semi-volatile organic compounds; RCRA = Resource Conservation and Recovery Act; Cr6 = hexavalent chromium; EPH = extractable petroleum hydrocarbons; PCB = polychlorinated biphenyls; PLM = polarized light microscopy; DRO = total petroleum hydrocarbon diesel range organics; AST = aboveground storage tank; TBD = to be determined; QA/QC = quality assurance/quality control; N/A = not applicable; DUP = duplicate; MS/MSD = matrix spike/matrix spike duplicate Minimum Total Soil Samples Maximum Total Soil Samples BG-3 southwest of unnamed tributary establish site-specific background levels for metals BG-4 west of N 17th St establish site-specific background levels for metals BG-1 east of warehouse/office & west of N 13th St establish site-specific background levels for metals BG-2 south of warehouse storage areas & west of parking lot establish site-specific background levels for metals SB-38 west of ammonia storage/compressor area potential impacts from ammonia SB-39 east of ammonia storage/compressor area potential impacts from ammonia SB-36 former UST area previous detections of petroleum-related compounds SB-37 Research & Development lab potential impacts from chemicals used in research and development SB-34 former battery charging area potential impacts from battery charging, nearby auto repairs SB-35 former UST area previous detections of petroleum-related compounds SB-33 former battery charging area potential impacts from battery charging, nearby auto repairs Table 3 (Page 1 of 1) Proposed Sub-Slab Gas Sampling Locations and Analyses Former Erwin Mill Facility Erwin, North Carolina H&H Job No. BRP-001 \\HHFS01\MasterFiles\AAA-Master Projects\Brooks Pierce\Erwin Mill (BRP.001)\Brownfields Assessment Work Plan\Tables\Tables Table 3 (Page 1 of 1) Hart & Hickman, PC Analyses VOCs TO-15 SSG-1 Shipping & Receiving general screening 1 SSG-2 Spinning Area general screening 1 SSG-3 Spinning Area general screening 1 SSG-4 Winding Area general screening 1 SSG-5 Warping Area general screening 1 SSG-6 Beaming Area general screening 1 SSG-7 Machine Shop potential impacts from shop activities 1 SSG-8 Welding Shop potential impacts from shop activities 1 SSG-9 Machine Shop potential impacts from shop activities 1 SSG-10 Wood Shop potential impacts from shop activities 1 SSG-11 Dye House potential impacts from dyeing activities 1 SSG-12 Dye House potential impacts from dyeing activities 1 SSG-13 Dye House potential impacts from dyeing activities 1 SSG-14 Dye House potential impacts from dyeing activities 1 SSG-15 Former Dye Storage Area potential impacts from dye storage leaks 1 SSG-16 Former Garage/Battery Charging Area potential impacts from equipment or battery charging 1 SSG-17 Warehouse Storage Area general screening 1 SSG-18 Warehouse Storage Area general screening 1 SSG-19 Warehouse Storage Area general screening 1 SSG-20 Finishing Building potential impacts from finishing activities 1 SSG-21 Finishing Building potential impacts from finishing activities 1 SSG-22 Eastern Warehouse general screening 1 SSG-23 Eastern Warehouse general screening 1 SSG-24 Brushing/Former Dye House potential impacts from former dyeing activities 1 SSG-25 Brushing/Former Dye House potential impacts from former dyeing activities 1 SSG-26 Ammonia Finishing Are potential impacts from finishing activities 1 SSG-27 Northern Warehouse general screening 1 SSG-28 Northern Offices general screening 1 SSG-29 Research & Development Lab general screening 1 DUP-SSG-1 TBD QA/QC 1 DUP-SSG-2 TBD QA/QC 1 31 Notes:VOCs = volatile organic compounds; TBD = to be determined; DUP = duplicate; QA/QC = quality assurance/quality control; N/A = not applicable; Sub-Slab Gas Sample ID Sample Location Sample Rationale Total Sub-Slab Gas Samples Table 4 (Page 1 of 1) Proposed Surface Water and Sediment Sampling Locations and Analyses Former Erwin Mill Facility Erwin, North Carolina H&H Job No. BRP-001 \\HHFS01\MasterFiles\AAA-Master Projects\Brooks Pierce\Erwin Mill (BRP.001)\Brownfields Assessment Work Plan\Tables\Tables Table 4 (Page 1 of 1) Hart & Hickman, PC VOCs SVOCs RCRA Metals plus Cr6 8260B 8270D 6020/7471B/7196A SW-1/SED-1 reservoir potential dye impacts 1 1 1 SW-2/SED-2 potential wetlands area immediately downgradient of fuel oil ASTs 1 1 1 SW-3/SED-3 unnamed tributary - upstream tributary downgradient of mill; potential impacts from upstream sources 1 1 1 SW-4/SED-4 unnamed tributary - mid-stream before drainage ditch tributary downgradient of mill; potential impacts from mill operations 1 1 1 SW-5/SED-5 unnamed tributary - mid-stream after drainage ditch tributary downgradient of mill; potential impacts from mill operations and upstream/on-Site sources via ditches 1 1 1 SW-6/SED-6 unnamed tributary - downstream tributary downgradient of mill; potential impacts that discharge from Site via stream 1 1 1 DUP-SW/DUP-SED TBD QA/QC 1 1 1 MS/MSD TBD QA/QC 1 1 1 Rinse Blank Sediment Sampling Equipment QA/QC 1 1 1 9 9 9 Notes:VOCs = volatile organic compounds; SVOCs = semi-volatile organic compounds; RCRA = Resource Conservation and Recovery Act; Cr6 = hexavalent chromium; TBD = to be determined; QA/QC = quality assurance/quality control; N/A = not applicable; DUP = duplicate; MS/MSD = matrix spike/matrix spike duplicate Analyses Surface Water/Sediment Sample ID Sampling Location Sampling Rationale Total Surface Water/Sediment Samples Figures TITLE PROJECT SITE LOCATION MAP FORMER ERWIN MILLS FACILITY200 NORTH 13TH STREET ERWIN, NORTH CAROLINA DATE: JOB NO: REVISION NO: FIGURE NO: 4-17-19 0 1BRP-001 0 2000 4000 APPROXIMATE SCALE IN FEETN U.S.G.S. QUADRANGLE MAP QUADRANGLE 7.5 MINUTE SERIES (TOPOGRAPHIC) ERWIN, NORTH CAROLINA 1997 SITE 3921 Sunset Ridge Road, Suite 301 Raleigh, North Carolina 27607 919-847-4241(p) 919-847-4261(f) License # C-1269 / #C-245 Geology W. F STREET E. J STREET N. 16TH STREETN. 17TH STREETW. H STREET N. 13TH STREETCHIEF JOSEPH LANE S. 13TH STREETS. 14TH STREETSPINNING AREA WAREHOUSE/OFFICES WAREHOUSE/OFFICES SPINNING AREA SHOP AREA BEAMING AREA WINDING AREA WARPING AREA DYE HOUSE FORMER COTTON BLENDING BUILDING AREA WAREHOUSE STORAGE AREASRESERVOIR FORMER 1,000,000- GALLON FUEL OIL AST FORMER 150,000- GALLON FUEL OIL ASTs R&D LAB SHIPPING & RECEIVING FINISHING FORMER CHEMICAL STORAGE AREA AMMONIA STORAGE/ COMPRESSOR AREA GARAGE/SHOP DYE STORAGE AREA PARKING LOT PARKING LOT POTENTIAL WETLAND AREA WATER TANK DYE PIT FORMER DYE HOUSE BRUSHING AREA COAL SILOS ELECTRICAL SUBSTATION FORMER COAL POWER PLANTFUEL OIL BOILER BUILDING GRASS MW-4 MW-3 MW-5 MW-2 GRASS BATTERY CHARGING AREA AMMONIA FINISHING REVISION NO. 0 JOB NO. BRP-001 DATE: 4-17-19 FIGURE NO. 2 SITE MAP LEGEND SITE PROPERTY BOUNDARY FORMER BUILDING WATER FEATURE SEWER UTILITY LINE FENCE LINE TRENCH DRAIN DRAINAGE DITCH PAD-MOUNTED TRANSFORMER FORMER UST FLOOR DRAIN PERMANENT MONITORING WELL FORMER ERWIN MILLS FACILITY 200 NORTH 13TH STREET ERWIN, HARNETT COUNTY, NORTH CAROLINA 3921 Sunset Ridge Road, Suite 301 Raleigh, North Carolina 27607 919-847-4241(p) 919-847-4261(f) License # C-1269 / #C-245 Geology MW-1 MW-4 MW-3MW-5 MW-2 NOTES: 1. EXISTING SITE MONITORING WELL LOCATIONS ARE APPROXIMATE.\\HHFS01\MasterFiles\AAA-Master Projects\Brooks Pierce\Erwin Mill (BRP.001)\Brownfields Assessment Work Plan\Figures\Figures_4.17.19.dwg, FIG 2, 4/17/2019 1:21:14 PM,SVincent W. F STREET E. J STREET N. 16TH STREETN. 17TH STREETW. H STREET N. 13TH STREETCHIEF JOSEPH LANE S. 13TH STREETS. 14TH STREETSPINNING AREA WAREHOUSE/OFFICES WAREHOUSE/OFFICES SPINNING AREA SHOP AREA BEAMING AREA WINDING AREA WARPING AREA DYE HOUSE FORMER COTTON BLENDING BUILDING AREA WAREHOUSE STORAGE AREASRESERVOIR FORMER 1,000,000- GALLON FUEL OIL AST FORMER 150,000- GALLON FUEL OIL ASTs R&D LAB SHIPPING & RECEIVING FINISHING FORMER CHEMICAL STORAGE AREA AMMONIA STORAGE/ COMPRESSOR AREA GARAGE/SHOP DYE STORAGE AREA PARKING LOT PARKING LOT POTENTIAL WETLAND AREA WATER TANK DYE PIT FORMER DYE HOUSE BRUSHING AREA COAL SILOS ELECTRICAL SUBSTATION FORMER COAL POWER PLANTFUEL OIL BOILER BUILDING GRASS MW-4 MW-3 MW-5 MW-2 GRASS BATTERY CHARGING AREA AMMONIA FINISHING GP-4 GP-6 GP-7 GP-3 GP-1 GP-2 GP-5 REVISION NO. 0 JOB NO. BRP-001 DATE: 4-17-19 FIGURE NO. 3 PROPOSED MONITORING WELL LOCATION MAP LEGEND SITE PROPERTY BOUNDARY FORMER BUILDING WATER FEATURE SEWER UTILITY LINE FENCE LINE TRENCH DRAIN DRAINAGE DITCH PAD-MOUNTED TRANSFORMER FORMER UST FLOOR DRAIN EXISTING PERMANENT MONITORING WELL PROPOSED MONITORING WELL LOCATION ABANDONED/DESTROYED WELL LOCATION GEOPROBE GROUNDWATER SAMPLE LOCATION FORMER ERWIN MILLS FACILITY 200 NORTH 13TH STREET ERWIN, HARNETT COUNTY, NORTH CAROLINA 3921 Sunset Ridge Road, Suite 301 Raleigh, North Carolina 27607 919-847-4241(p) 919-847-4261(f) License # C-1269 / #C-245 Geology MW-1 MW-9 MW-8 MW-7 MW-10 NOTES: 1. EXISTING SITE MONITORING WELL LOCATIONS ARE APPROXIMATE. 2.ALL EXISTING AND PROPOSED MONITORING WELLS WILL BE SAMPLED FOR VOCs, SVOCs, AND RCRA METALS PLUS HEXAVALENT CHROMIUM. MW-18 MW-19 MW-20 MW-16 MW-15 MW-17 MW-14 MW-13 MW-12 MW-11 \\HHFS01\MasterFiles\AAA-Master Projects\Brooks Pierce\Erwin Mill (BRP.001)\Brownfields Assessment Work Plan\Figures\Figures_4.17.19.dwg, FIG 3, 4/17/2019 1:20:11 PM,SVincentGRASS W. F STREET E. J STREET N. 16TH STREETN. 17TH STREETW. H STREET N. 13TH STREETCHIEF JOSEPH LANE S. 13TH STREETS. 14TH STREETSPINNING AREA WAREHOUSE/OFFICES WAREHOUSE/OFFICES SPINNING AREA SHOP AREA BEAMING AREA WINDING AREA WARPING AREA DYE HOUSE FORMER COTTON BLENDING BUILDING AREA WAREHOUSE STORAGE AREASRESERVOIR FORMER 1,000,000- GALLON FUEL OIL AST FORMER 150,000- GALLON FUEL OIL ASTs R&D LAB SHIPPING & RECEIVING FINISHING FORMER CHEMICAL STORAGE AREA AMMONIA STORAGE/ COMPRESSOR AREA GARAGE/SHOP DYE STORAGE AREA PARKING LOT PARKING LOT POTENTIAL WETLAND AREA WATER TANK DYE PIT FORMER DYE HOUSE BRUSHING AREA COAL SILOS ELECTRICAL SUBSTATION FORMER COAL POWER PLANTFUEL OIL BOILER BUILDING GRASS MW-4 MW-3 MW-5 MW-2 GRASS BATTERY CHARGING AREA AMMONIA FINISHING HA-26 HA-16 HA-23 HA-12 HA-11B HA-11A HA-19 HA-3 HA-4 HA-17 HA-27 HA-7 HA-9AHA-9B REVISION NO. 0 JOB NO. BRP-001 DATE: 6-3-19 FIGURE NO. 4 PROPOSED SOIL SAMPLE LOCATION MAP LEGEND SITE PROPERTY BOUNDARY FORMER BUILDING WATER FEATURE SEWER UTILITY LINE FENCE LINE TRENCH DRAIN DRAINAGE DITCH PAD-MOUNTED TRANSFORMER FORMER UST FLOOR DRAIN SOIL BORING LOCATION - PCB CONGENERS SOIL BORING LOCATION - AMMONIA, NITRITE, NITRATE SOIL BORING LOCATION - VOCs, SVOCs, RCRA METALS DEMOLITION DEBRIS SAMPLE LOCATION - VOCs, SVOCs, RCRA METALS, ASBESTOS BACKGROUND SOIL SAMPLES - RCRA METALS PCB SOIL SAMPLE LOCATION PERMANENT MONITORING WELLS SOIL BORING LOCATION FORMER ERWIN MILLS FACILITY 200 NORTH 13TH STREET ERWIN, HARNETT COUNTY, NORTH CAROLINA FORMER CHEMICAL STORAGE AREA 3921 Sunset Ridge Road, Suite 301 Raleigh, North Carolina 27607 919-847-4241(p) 919-847-4261(f) License # C-1269 / #C-245 Geology SB-2 SB-1 SP-1 SB-5 SB-4 SB-3SP-2 SB-6 SB-7 SB-8 SB-18 SB-19 SB-21 SB-20 SB-17 SB-16 SB-14 SB-15 SB-22 SB-23 SB-30 SB-29 SB-28 SB-27 SB-33 SB-34 SB-31 SB-32 SB-35 SB-36 SB-26 SB-24 SB-25 SB-37 HA-26A SB-39SB-38 HA-3A HA-27A BG-4 SB-13SB-12SB-11 SB-9 SB-10 BG-3 BG-2 BG-1 OS-1 OS-2 \\HHFS01\MasterFiles\AAA-Master Projects\Brooks Pierce\Erwin Mill (BRP.001)\Brownfields Assessment Work Plan\Figures\Figures_4.17.19.dwg, FIG 4, 6/3/2019 10:05:33 AM,SVincent W. F STREET E. J STREET N. 16TH STREETN. 17TH STREETW. H STREET N. 13TH STREETCHIEF JOSEPH LANE S. 13TH STREETS. 14TH STREETSPINNING AREA WAREHOUSE/OFFICES WAREHOUSE/OFFICES SPINNING AREA SHOP AREA BEAMING AREA WINDING AREA WARPING AREA DYE HOUSE FORMER COTTON BLENDING BUILDING AREA WAREHOUSE STORAGE AREASRESERVOIR FORMER 1,000,000- GALLON FUEL OIL AST FORMER 150,000- GALLON FUEL OIL ASTs R&D LAB SHIPPING & RECEIVING FINISHING FORMER CHEMICAL STORAGE AREA AMMONIA STORAGE/ COMPRESSOR AREA GARAGE/SHOP DYE STORAGE AREA PARKING LOT PARKING LOT POTENTIAL WETLAND AREA WATER TANK DYE PIT FORMER DYE HOUSE BRUSHING AREA COAL SILOS ELECTRICAL SUBSTATION FORMER COAL POWER PLANTFUEL OIL BOILER BUILDING GRASS GRASS BATTERY CHARGING AREA AMMONIA FINISHING REVISION NO. 0 JOB NO. BRP-001 DATE: 4-17-19 FIGURE NO. 5 PROPOSED SUB-SLAB GAS SAMPLING LOCATION MAP FORMER ERWIN MILLS FACILITY 200 NORTH 13TH STREET ERWIN, HARNETT COUNTY, NORTH CAROLINA 3921 Sunset Ridge Road, Suite 301 Raleigh, North Carolina 27607 919-847-4241(p) 919-847-4261(f) License # C-1269 / #C-245 Geology LEGEND SITE PROPERTY BOUNDARY FORMER BUILDING WATER FEATURE SEWER UTILITY LINE FENCE LINE TRENCH DRAIN DRAINAGE DITCH PAD-MOUNTED TRANSFORMER FORMER UST FLOOR DRAIN PROPOSED SUB-SLAB GAS SAMPLING LOCATION SSG-29 SSG-28 SSG-27 SSG-26 SSG-1 SSG-2 SSG-3 SSG-6 SSG-4 SSG-7 SSG-8 SSG-10SSG-9 SSG-14 SSG-13SSG-12 SSG-11 SSG-5 SSG-17 SSG-18 SSG-19 SSG-16SSG-15 SSG-20 SSG-22 SSG-23 SSG-21 SSG-25 SSG-24 \\HHFS01\MasterFiles\AAA-Master Projects\Brooks Pierce\Erwin Mill (BRP.001)\Brownfields Assessment Work Plan\Figures\Figures_4.17.19.dwg, FIG 5, 4/17/2019 1:18:53 PM,SVincentGRASS W. F STREET E. J STREET N. 16TH STREETN. 17TH STREETW. H STREET N. 13TH STREETCHIEF JOSEPH LANE S. 13TH STREETS. 14TH STREETSPINNING AREA WAREHOUSE/OFFICES WAREHOUSE/OFFICES SPINNING AREA SHOP AREA BEAMING AREA WINDING AREA WARPING AREA DYE HOUSE FORMER COTTON BLENDING BUILDING AREA WAREHOUSE STORAGE AREASRESERVOIR FORMER 1,000,000- GALLON FUEL OIL AST FORMER 150,000- GALLON FUEL OIL ASTs R&D LAB SHIPPING & RECEIVING FINISHING FORMER CHEMICAL STORAGE AREA AMMONIA STORAGE/ COMPRESSOR AREA GARAGE/SHOP DYE STORAGE AREA PARKING LOT PARKING LOT POTENTIAL WETLAND AREA WATER TANK DYE PIT FORMER DYE HOUSE BRUSHING AREA COAL SILOS ELECTRICAL SUBSTATION FORMER COAL POWER PLANTFUEL OIL BOILER BUILDING GRASS GRASS BATTERY CHARGING AREA AMMONIA FINISHING REVISION NO. 0 JOB NO. BRP-001 DATE: 4-17-19 FIGURE NO. 6 PROPOSED SURFACE WATER & SEDIMENT SAMPLING LOCATION MAP FORMER ERWIN MILLS FACILITY 200 NORTH 13TH STREET ERWIN, HARNETT COUNTY, NORTH CAROLINA 3921 Sunset Ridge Road, Suite 301 Raleigh, North Carolina 27607 919-847-4241(p) 919-847-4261(f) License # C-1269 / #C-245 Geology NOTES: 1.SURFACE WATER AND SEDIMENT SAMPLES WILL BE ANALYZED FOR VOCs, SVOCs, AND RCRA METALS PLUS HEXAVALENT CHROMIUM. LEGEND SITE PROPERTY BOUNDARY FORMER BUILDING WATER FEATURE SEWER UTILITY LINE FENCE LINE TRENCH DRAIN DRAINAGE DITCH PAD-MOUNTED TRANSFORMER FORMER UST FLOOR DRAIN PROPOSED SURFACE WATER/SEDIMENT SAMPLE LOCATION SW-6/SED-6 SW-5/SED-5 SW-4/SED-4 SW-3/SED-3 SW-1/SED-1 SW-2/SED-2 \\HHFS01\MasterFiles\AAA-Master Projects\Brooks Pierce\Erwin Mill (BRP.001)\Brownfields Assessment Work Plan\Figures\Figures_4.17.19.dwg, FIG 6, 4/17/2019 1:19:02 PM,SVincentGRASS Appendix A Summary of Historical Analytical Data Table 1 – Summary of Historical Groundwater Analytical Data Table 2 – Summary of Historical Soil Analytical Data Table 3 – Summary of Historical PCB Analytical Data Table 1 (Page 1 of 1) Summary of Historical Groundwater Analytical Data Former Erwin Mill Facility Erwin, North Carolina H&H Job No. BRP-001 \\HHFS01\MasterFiles\AAA-Master Projects\Brooks Pierce\Erwin Mill (BRP.001)\Brownfields Assessment Work Plan\Tables\Tables Table 1(Page 1 of 3) Hart & Hickman, PC Sample ID GP-1 GP-2 GP-3 GP-4 GP-5 GP-6 GP-7 MW-7 MW-8 MW-9 MW-10 Sample Date 6/28/2001 6/28/2001 6/28/2001 6/29/2001 6/29/2001 6/29/2001 7/2/2001 6/29/2001 12/13/2017 12/13/2017 11/4/2016 VOCs (8260) (µg/L) Benzene 1 <0.5 <0.5 2.0 <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 n-Butylbenzene 70 <0.5 <0.5 11 <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 sec-Butylbenzene 70 <0.5 <0.5 15 <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 Chloroform 70 1.0 2.0 <2.0 <0.5 <0.5 <0.5 <0.5 <0.5 4.0 <0.5 <0.5 1,1-Dichloroethane 6 <0.5 <0.5 <2.0 <0.5 <0.5 7.0 0.5 <0.5 <0.5 <0.5 <0.5 1,1-Dichloroethene 350 <0.5 <0.5 <2.0 <0.5 <0.5 1.0 <0.5 <0.5 <0.5 <0.5 <0.5 Ethylbenzene 600 <0.5 <0.5 11 <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 Isopropylbenzene 70 <0.5 <0.5 12 <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 4-Isopropytoluene 25*<0.5 <0.5 6.0 <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 Methyl tert-butyl ether 20 <0.5 <0.5 <2.0 <0.5 15 <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 Naphthalene 6 <0.5 <0.5 24 <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 n-Propylbenzene 70 <0.5 <0.5 13 <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 Toluene 600 <0.5 0.8 3.0 <0.5 <0.5 0.7 <0.5 <0.5 <0.5 <0.5 <0.5 1,1,1-Trichloroethane 200 <0.5 <0.5 <2.0 <0.5 <0.5 7.0 0.6 <0.5 <0.5 <0.5 <0.5 1,2,4-Trimethylbenzene 400 <0.5 0.9 44 <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 1,3,5-Trimethylbenzene 400 <0.5 <0.5 15 <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 Total xylenes 500 <1.5 1.0 19 <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 SVOCs (8270) (µg/L) Chrysene 5 <10 <10 <10 11 <10 <10 <10 <10 <10 <10 <10 Fluoranthene 300 <10 <10 <10 <10 <10 <10 13 <10 <10 <10 <10 Fluorene 300 <10 <10 18 <10 <10 <10 <10 <10 <10 <10 <10 Naphthalene 6 <10 <10 20 <10 <10 <10 <10 <10 <10 <10 <10 Phenanthrene 200 <10 <10 24 <10 <10 <10 <10 <10 <10 <10 <10 Pyrene 200 <10 <10 <10 <10 <10 <10 13 <10 <10 <10 <10 Metals (6010/7470) (mg/L) Arsenic 0.01 NA NA NA NA NA NA NA <0.0100 <0.0100 0.0150 <0.0100 Barium 0.7 NA NA NA NA NA NA NA <0.100 <0.100 <0.100 0.102 Chromium 0.01 NA NA NA NA NA NA NA <0.0100 <0.0100 0.0194 0.0121 Lead 0.015 NA NA NA NA NA NA NA <0.0100 0.0209 0.0294 0.0162 Mercury 0.001 NA NA NA NA NA NA NA 0.0003 0.0006 0.0009 0.0005 Selenium 0.02 NA NA NA NA NA NA NA <0.0100 0.01 <0.0100 0.0129 Notes: 1. 15A NCAC 02L Groundwater Quality Standards last updated April 1, 2013. EPA Method number follows parameter in parenthesis. Only constituents detected in at least one sample are shown. Bold concentrations exceed the NCAC 2L Groundwater Standard (April 2013) NA = Not analyzed; VOCs = Volatile Organic Compounds; * = Interim Maximum Allowable Concentration NC 2L Groundwater Standard (1) Table 2 (Page 1 of 1) Summary of Historical Soil Analytical Data Former Erwin Mill FacilityErwin, North CarolinaH&H Job No. BRP-001 \\HHFS01\MasterFiles\AAA-Master Projects\Brooks Pierce\Erwin Mill (BRP.001)\Brownfields Assessment Work Plan\Tables\Tables Table 2 (Page 2 of 3)Hart & Hickman, PC Sample ID SP-1 SP-2 SB-1 SB-2 SB-3 SB-4 SB-5 SB-6 SB-7 SB-8 OS-1 Depth (ft)composite composite 0-1 2-3 2-3 2-3 0-1 3 2 1-2 grab Sample Date 5/23/2018 5/23/2018 5/24/2018 5/23/2018 5/24/2018 5/24/2018 5/23/2018 5/24/2018 5/24/2018 5/24/2018 7/12/2018 Diesel Range Organics (8015C) (mg/Kg) C10-C28 ------100 7,700 1,980 295 <6.20 <5.79 7,930 2,650 15,500 14,600 69.7 2,380 VOCs (8260) (mg/Kg)Acetone 12,000 140,000 25 --0.360 0.0768 NA NA NA NA NA NA NA NA NA SVOCs (8270) (mg/Kg)Benzo[a]anthracene 1.1 21 0.35 --5.84 <1.93 NA NA NA NA NA NA NA NA NABenzo[a]pyrene 0.11 2.1 0.12 --5.99 <1.93 NA NA NA NA NA NA NA NA NABenzo[b]fluoranthene 1.1 1.8 1.2 --7.17 <1.93 NA NA NA NA NA NA NA NA NABenzo[g,h,i]perylene NE NE 15,600 --3.80 <1.93 NA NA NA NA NA NA NA NA NABenzo[k]fluoranthene 11 210 12 --2.63 <1.93 NA NA NA NA NA NA NA NA NAChrysene1102,100 36 --6.78 <1.93 NA NA NA NA NA NA NA NA NAFluoranthene4806,000 670 --11.1 <1.93 NA NA NA NA NA NA NA NA NAIndeno[1,2,3-cd]pyrene 1.1 21 3.9 --4.09 <1.93 NA NA NA NA NA NA NA NA NAPhenanthreneNENE134--6.44 <1.93 NA NA NA NA NA NA NA NA NAPyrene3604,500 440 --12.0 <1.93 NA NA NA NA NA NA NA NA NA Metals (6010D/7471B) (mg/Kg) Chromium 0.31*6.5 3.8*--2.71 5.25 NA NA NA NA NA NA NA NA NA Copper 630 9,300 700 --3.19 <2.23 NA NA NA NA NA NA NA NA NALead400800270--10.5 23.7 NA NA NA NA NA NA NA NA NANickel3104,700 130 --3.60 3.12 NA NA NA NA NA NA NA NA NAZinc4,700 70,000 1200 --35.1 34.3 NA NA NA NA NA NA NA NA NABarium3,100 47,000 580 --18.6 5.65 NA NA NA NA NA NA NA NA NA pH --------6.4 6.2 NA NA NA NA NA NA NA NA NA Notes:VOC = Volatile organic compound; SVOC = Semi-volatile organic compound; mg/Kg = Milligrams per Kilogram; NA = Not Analyzed; NE = Not established; * = chromium VI PSRG; ft bgs = feet below ground surface; -- = not applicable.Laboratory analytical methods are shown in parentheses.Only constituents detected in at least one sample are shown.Shading indicates concentration exceeds the NCDEQ Industrial/Commercial Health Preliminary Soil Remediation Goals (PSRGs)(February 2018) or NC DEQ Action Levels.Bolding indicates concentration exceeds the NCDEQ Residential Health Based PSRGs (February 2018)Underlining indicates concentration exceeds the NCDEQ Protection of Groundwater PSRGs (February 2018) Residential Health Based PSRG Protection of Groundwater PSRG NC DEQ Action Levels Industrial/ Commercial Health Based PSRG Table 3 (Page 1 of 1) Summary of Historical PCB Analytical Data Former Erwin Mill Facility Erwin, North CarolinaH&H Job No. BRP-001 \\HHFS01\MasterFiles\AAA-Master Projects\Brooks Pierce\Erwin Mill (BRP.001)\Brownfields Assessment Work Plan\Tables\Tables Table 3(Page 3 of 3) Hart & Hickman, PC Sample ID HA-3 HA-4 HA-7 HA-9A HA-9B HA-11A HA-11B HA-12 HA-16 HA-17 HA-19 HA-23 HA-26 HA-27Depth (ft bgs)4 4 4 4 4 4 4 4 4 4 4 4 4 4Sample Date 6/28/2001 6/28/2001 6/29/2001 6/28/2001 6/28/2001 6/28/2001 6/28/2001 6/28/2001 6/28/2001 6/28/2001 6/28/2001 6/29/2001 6/28/2001 6/28/2001Polychlorinated Biphenyls (8082) (µg/Kg) Aroclor-1260 240 990 240 23,000 360 330 320 1300 <110 1,000 290 150 550 <110 <110 <1,100 <1,100Aroclor-1254 230 970 91 <120 <120 <100 <110 <540 <110 <110 <120 <110 <100 <110 820 2,100 2,300 Field Screening (ppm)VOCs ------3.5 3.0 >1,999 >1,999 >1,999 33.5 8.5 4.5 31.0 6.5 3.0 >1,999 13.5 >1,999 Notes:VOC = Volatile organic compound; µg/Kg = Micrograms per Kilogram; ppm = part per millionft bgs = feet below ground surface; -- = not applicable.Laboratory analytical methods are shown in parentheses.Only constituents detected in at least one sample are shown. Shading indicates concentration exceeds the NCDEQ Industrial/Commercial Health Preliminary Soil Remediation Goals (PSRGs)(February 2018) or NC DEQ Action Levels.Bolding indicates concentration exceeds the NCDEQ Residential Health Based PSRGs (February 2018)Underlining indicates concentration exceeds the NCDEQ Protection of Groundwater PSRGs (February 2018) Residential Health Based PSRG Protection of Groundwater PSRG Industrial/ Commercial Health Based PSRG