20092-16-049_Additional Assessment Response Letter_06.05.2018

State of North Carolina | Environmental Quality | Waste Management
1646 Mail Service Center | 217 West Jones Street | Raleigh, NC 27699-1646
919 707 8200 T

June 5, 2018
Sent Via Email

Mr. John Gallina
Purple Heart Homes, Inc.
P.O. Box 5355
Statesville, NC 28687
[e-mail]

Subject: Assessment Response Letter
Purple Heart Homes
755 Washington Street
Statesville, Iredell County
Brownfields Project Number 20092-16-049

Dear Mr. Gallina:

The North Carolina Department of Environmental Quality (DEQ), Brownfields Program has
reviewed the Additional Assessment Report for the above-referenced property completed by Apex
Companies, LLC on May 10, 2018. Based on a review of this document, data gaps remain.

Additional assessment activities, as outlined below, are required to assist in making risk
management decisions for inclusion in the Brownfields Agreement (BFA). The following areas
of the Brownfields Property will require additional assessment. Prior to conducting field activities,
a work plan should be submitted to DEQ for review and approval. The work plan should include
a description of the sampling and analytical methods to be utilized and a map depicting the
proposed sample locations. The most recent Inactive Hazardous Sites Program Guidelines for
Assessment and Cleanup (http://portal.ncdenr.org/web/wm/sf/ihs/ihsguide) should be followed.
Request Level 2 QA/QC data packages from a N.C. certified environmental laboratory. Collect
one duplicate sample for all analysis per every 20% of samples.

Groundwater Assessment

- Based on a review of topographic maps and previous assessments completed for the
Brownfields Property, it was reported that groundwater flow was most likely to the north
or south of the Brownfields Property. However, based on the most recent site assessment
report, groundwater flow is to the west. Based on the defined groundwater flow, former
operations within the main building, and identified groundwater concentrations of certain
contaminants, install a temporary monitoring well to the west of the main building along
the western property boundary. Further, based on the former varnishing operations within
the southern portion of the building and former UST basin, reinstall TMW-1 to collect a
groundwater sample. Temporary monitoring wells should be sampled for VOCs by EPA
Mr. John Gallina
June 5, 2018
Page 2

Method 8260, SVOCs by EPA Method 8270, and RCRA Metals by EPA Method 6020.
Ensure that the temporary wells are surveyed to determine accurate groundwater flow.
Given that some of the contaminants of concern are metals, of which mercury presents a
vapor intrusion risk, ensure that wells are appropriately developed and that parameters
stabilize prior to collecting a groundwater sample.

Soil Gas Sampling

- Groundwater concentrations of contaminants on the Brownfields Property were evaluated
using the DEQ Division of Waste Management Risk Calculator (September 2017 version).
Based on the results of that evaluation, groundwater concentrations present the potential
for vapor intrusion concerns within the warehouse portion of the site buildings. Install a
minimum of five soil gas samples within the warehouse portions of the main building for
analysis of VOCs and mercury via EPA Method TO-15.

Report and Figures: Upon receipt of analytical data, submit a summary report with a description
of field activities, tabulated data in comparison to applicable screening levels, and the laboratory
data packet with applicable QA/QC documentation, provide a site plan with well locations,
locations of sample points, and current site structures. Provide concentration map(s) for
contaminants detected above applicable standards. Include a detailed description of current
operations since the Brownfields Property application was submitted. Please note, all sample
points may need to be included on the future Brownfields plat. DEQ recommends having sample
locations surveyed at the time of collection for use in preparation of the Brownfields plat.

Please provide the Work Plan for additional assessment activities as soon as you are able. If you
have questions about this correspondence or require additional information, please feel free to
contact me by phone at [phone] or by email at [e-mail].

Sincerely,
Jordan Thompson
Brownfields Project Manager

ec: Tracy Wahl, DEQ
Katie Lippard, Apex Companies, LLC