19012_ThomasvillePlantB_Request for Additional Assessment Letter_06.20.2019

June 20, 2019
W. Kelly Craver
City of Thomasville
10 Salem Street
Thomasville, North Carolina 27360
[e-mail]

Subject: Additional Assessment Request
Thomasville Plant B Site
310 Fisher Ferry Street
Thomasville, Davidson County, NC
Brownfields Project Number 19012-15-029
Dear Mr. Craver,
The North Carolina Department of Environmental Quality (DEQ), Brownfields Program has reviewed the
documents submitted with the Brownfields Property Application for the Thomasville Plant B property
located at 310 Fisher Ferry Street, Davidson County. The following is a summary of the reports reviewed:

Based on our review of these documents and information garnered from adjacent properties, data gaps
were identified. Additional assessment activities, as outlined below, are required to assist in making risk
management decisions for inclusion in the Brownfields Agreement (BFA). 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) and the November 2018 DEQ Brownfields
Assessment Work Plan Checklist (attached) 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. All sample locations are referenced in the attached map.

1) Groundwater Sampling: Install a total of five monitoring wells at the following locations:

 within the footprint of the southeastern most former spraying room (REC-4);
Report Title Author Date
Phase I Environmental Site Assessment Apex Companies, LLC November 26,
2014
Site Specific Quality Assurance Project Plan Apex Companies, LLC June 19, 2015

Thomasville Plant B
June 20, 2019
Page 2

 within the former storage area adjacent to North Hamby Creek near the western border of
the property (REC-7);
 downgradient (south) of the former boiler room/laundry company and Standard Oil
Company filling station on the neighboring properties to the north (see Figure 2 from Apex
SSQAP) (REC-13);
 near the eastern property border south of North Hamby Creek down gradient of historic
auto repair shop and gas tank locations (REC-13); and
 within the former boiler room area located along the eastern border of former site building
(REC-3).

Monitoring wells should be constructed and developed in accordance with the standards presented
in the North Carolina Administrative Code (NCAC) Title 15A Subchapter 2C and surveyed to
determine accurate groundwater flow across the Brownfields Property. Following well
development, monitoring wells should be sampled for Volatile Organic Compounds (VOCs) by
EPA Method 8260, Semi-VOCs (SVOCs) by EPA Method 8270, Resource Conservation and
Recovery Act (RCRA) Metals by EPA Method 6020.

2) Soil Sampling:

a. Collect one surficial soil sample from the 0-2 feet below land surface (ft BLS) depth interval
from each of the monitoring well locations referenced above. If impacted soils below the 0-2
ft BLS interval and above the water table are observed during installation of the five monitoring
wells, collect a representative sample from a two-foot interval based on visual, olfactory, and
Photoionization Detector (PID) readings. Soil samples should be analyzed for VOCs by EPA
Method 8260, SVOCs by EPA Method 8270, and RCRA Metals by EPA Method 6020.

b. Collect surficial (0 - 2 ft BLS) soil samples from the following locations:

 In the vicinity of the location of a possible AST within the former general storage area
located to the east of the former manufacturing facility (REC-7);
 In the vicinity of the large unknown concrete basin in the northeastern portion of the
former manufacturing facility (REC-2);
 In the vicinity of the pipe terminating along the southern bank of North Hamby Creek
downgradient of a possible AST and reported basement staining near the former lunch
room (REC-8);
 In the vicinity of the possible leach field area and historical sump leading to North
Hamby Creek on the western side of the property (REC-6);
 A background sample located in the open space north of North Hamby Creek near the
eastern border of the Brownfields Property (BKG).

Soil samples should be analyzed for VOCs by EPA Method 8260, SVOCs by EPA Method
8270, and RCRA Metals by EPA Method 6020. The background sample should be analyzed
for only RCRA Metals by EPA Method 6020. Collect and have the laboratory hold an
additional sample aliquot for possible analysis of Hexavalent Chromium via EPA Method 7199
depending on results of RCRA Metals analysis.

Thomasville Plant B
June 20, 2019
Page 3

c. Collect composite soil samples comprised of 4 surficial samples in the following locations:

 Each of the 4 Former Spraying Rooms: composite a sample from 4 evenly distributed
locations within each of the 4 former spraying rooms for a total of 4 composite samples
in this area of the property;
 Around the perimeter of the former water tower;
 Along the property border to the east of the former Standard Oil Company.

Composite samples should be analyzed for SVOCs by EPA Method 8270 and RCRA Metals
by EPA Method 6020. A grab sample for VOCs analysis by EPA Method 8260 should be
selected from each composite sample area based on visual, olfactory, and PID screening results
prior to compositing samples.

3) Surface Water/Sediment Sampling: Collect collocated surface water and sediment samples within
North Hamby Creek at the following locations:

 Influent: a sample collected from North Hamby Creek near the eastern border of the
Brownfields Property;
 Near the pipe terminating on the south side of North Hamby Creek immediately
adjacent to the bridge leading to the northern portion of the Brownfields Property
(REC-5);
 Near the reported sump with pipe leading to the south side of North Hamby Creek and
the possible leach field area (REC-6); and
 Effluent: a sample collected from North Hamby Creek near the western border of the
Brownfields Property.

Samples should be collected in accordance with the Operating Procedures established by the US
EPA Region 4 Science and Ecosystem Support Division (SESD) for Surface Water Sampling
(December 16, 2016) and Sediment Sampling (August 21, 2014).

4) Receptor Survey: Complete the enclosed Brownfields Property receptor survey and include as an
attachment to the additional Assessment Report.

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 a potentiometric map for groundwater flow and concentration maps for
contaminants detected above applicable standards. 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.

Thomasville Plant B
June 20, 2019
Page 4

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,
Cody J. Cannon
Brownfields Project Manager

ec: Michael Brandt, AICP, City of Thomasville
Leo Moretz, P.G., and Justin Ballard, P.G., Hart & Hickman, PC
David Putnam and Jesse Day, Piedmont Triad Regional Council
Paul Kron, Foothills Planning + Design, PLLC
Thomasville Plant B
Request for Additional Assessment Map
Legend
Background
Composite Soil Sample
Monitoring Well
Property Boundary
Surface Water/Sediment
Surficial Soil (0-2 ft BLS)
500 ft
N➤➤N