19012_RequestForAdditionalAssessment_LeadDelineation_04.16.2020

From:Cannon, Cody J
To:Justin Ballard; Leo Moretz; Craver, Kelly; [e-mail]; Nolan, Cindy
Cc:Wahl, Tracy
Subject:Thomasville Plant B (19012-15-029) - Brownfields Status Update
Date:Thursday, April 16, 2020 1:36:00 PM
Attachments:AdditionalAssessmentRequest_LeadDelineation_04.16.2020.pdf
Good Afternoon All,

I hope all is well with everyone during this crazy time. As I discussed with Justin yesterday over the
phone, I will be remaining the Brownfields Project Manager for the Thomasville Plant B (19012-15-
029) project. I have received and reviewed the Brownfields Assessment Report you recently
provided Tracy Wahl. After review, all assessment was accomplished in accordance with the
approved work plan and I have no comments on the report. However, DEQ Brownfields would like
to further assess the elevated lead concentrations observed in soil in select samples south of Hamby
Creek. We understand that the redevelopment plans for the property are still in the initial stages,
but that the intended reuse still includes the possibility of public parks/recreational fields. This being
the case, we need to further delineate the lead impacts at the site so that we can appropriately
mitigate the exposure risk in particular areas. This information will also be useful in the event that
impacted soil needs to be excavated and disposed off-site or used as fill in other areas of the
property. As such, I am requesting the following minimally invasive assessment of lead impacts in
soil:

· TCLP Lead analysis of the most elevated surficial samples collected south of Hamby Creek
which fail the 20:1 rule: SB-2 (2,270 mg/kg), SB-4 (838 mg/kg), SB-14 (624 mg/kg), and SB-16
(408 mg/kg). TCLP data will determine if the impacted soil is considered characteristically
hazardous, let us evaluate the susceptibility for lead to leach in the groundwater at the
property, and determine if the elevated lead observed in monitoring well TMW-6
(collocated with SB-16) is a result of on-site lead leaching or potential migration from
upgradient off-site historical leaded gasoline.
· Horizontal Delineation Screening/Sampling: step out samples should be collected in each
cardinal direction from each of the soil sample location mentioned above (SB-2, SB-4, SB-14,
and SB-16) for delineation of lead impacts. To increase efficiency and limit cost, sampling
can be done in conjunction with screening using a portable X-ray fluorescence (XRF)
instrument. Please submit confirmatory samples at a frequency you deem necessary to
provide an adequate correlation between field screening and laboratory analytical results
(Lead by 6020B). Each area should be delineated to a minimum of 400 mg/kg (NCDEQ
Residential PSRG) due to the likelihood of children playing in these areas.
· Collection of 3 grab soil samples for RCRA Metals analysis (EPA 6020B) from the 0 – 2 feet
below land surface (ft BLS) interval from select locations north of Hamby Creek. These areas
were not evaluated as part of the initial assessment but need to be evaluated now due to
the elevated lead observed in other areas of the property.

I’ve provided comments to one of Hart & Hickman’s report figures to show the reference locations
(attached). Once we have addressed these issues, we can move forward with the drafting of a
Brownfields Agreement for this property. Cindy, can this additional work be handled under the
existing approved SSQAPP? Thank you all for your continued work on this project and please reach
out to me with any questions or concerns.

Best,

FORMER
S
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A
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BUILDIN
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(
A
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-
7
)
AREA OF VISIBLE STAININGFROM OVERTURNED 5GALLON BUCKETS (AOC-10)
FORMER HISTORICAL LAUNDRY
COMPANY (1948) AND CHEMICAL
MIXING COMPANY (1963) (AOC-13)
FORMER BOILER ROOM
FORMER LOADING SHED
FORMER PUMP HOUSE
FORMER STANDARD OIL COMPANYFILLING STATION AND MACHINESHOP (1923-1948) (AOC-13)
FORMER KEROSENE TANK15,000 GAL. (AOC-13)
FORMER GASOLINE TANKS15,000 GAL. (AOC-13)
FORMER LUM
B
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SHED AND G
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R
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L
LOCATION O
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F
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VENEER FAC
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I
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Y
FORMER UNKNOWNSTRUCTURE
FORMERLUMBER SHED
FORMER
COOLING
SHEDS
5 FORMER
DRYING KILN
S
LUMBER
FORMER BOILER
ROOM (AOC-3)LOCATION OF HISTORIC GAS
TANK (1930 AND 1948) (AOC-13)
ASPHALT
PARKING
FORMER SCAFFOLDING WITH PIPES LEADINGINTO BUILDING, POSSIBLE AST LOCATION (AOC-8)
FORMER
WOOD
WORKSFORMER
PAINT STOR
A
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BUILDING
WOOD STOR
A
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B
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FORMER
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FORMER
PACKAGING

A
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FINISHING
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(AOC-7)
POSSIBLE

L
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FIELD ARE
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(AOC-6)
AREA OF STRESSED VEGETATION
NEAR CREEK (AOC-9)
SUMP WITH UNDERGROUND
PIPE LEADING TO CREEK(AOC-6)
STAINING IN BASEMENT,POSSIBLE FUEL LINE COMING
INTO BUILDING (AOC-1)
FORMER LUNCH ROOM BUILDING
UNDERGROUND PIPE EXPOSEDON SOUTHERN BANK OFNORTH HAMBY CREEK (AOC-5)
FORMER PLATFORM WITH PIPING,
POSSIBLE AST LOCATION (AOC-8)
2ND FLOOR HAZARDOUS WASTE SATELLITECOLLECTION FOR SPENT SOLVENTS
LOCATION OF HISTORIC GASTANK (1930 AND 1948) (AOC-13)
NORTH H
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C
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K
FOSTE
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S
T
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WAGSTAFF STREETFISHER FE
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RY STRE
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FORMERSTORAGE AREA(AOC-7)
FORMER SPRAY BOOTHAND OFFICES (AOC-4)
BG-1
BG-2
SW/SED-1
SW/SED-2
SW/SED-3
SW/SED-4
SB-4
SB-1
SB-2
SB-3
SB-11
SB-13
SB-16
SB-15
SB-12
SB-14
TMW-4
TMW-1
TMW-3
TMW-6
TMW-2
FORMER GENERALSTORAGE (AOC-7)FISHER FERRY STREETCARMALT STREET
LARGE CONCRETEBASIN (AOC-2)
FORMER 10,000 GALLONWATER TOWER
FORMERSPRAY BOOTH(AOC-4)
SB-9D
SB-10A
SB-6B
SB-7C
SB-8C
SB-9A
SB-9C
SB-9B
SB-5C
SB-5B
SB-5A
SB-5D
SB-7B
SB-7D
SB-7A
SB-8B
SB-8A
SB-8D
SB-6ASB-6C
SB-6D
SB-10B
SB-10C
SB-10D
FORMER SOUTHERNMANUFACTURING BUILDING
TMW-5
VISIBLE PETROLEUM STAININGOBSERVED, POSSIBLE ASTLOCATION (AOC-7)
REVISION NO. 0
JOB NO. PTR-002
DATE: 3-13-20
FIGURE NO. 4
THOMASVILLE PLANT B310 FISHER FERRY STREET
THOMASVILLE, NORTH CAROLINA
SAMPLE LOCATION MAP
LEGEND
BROWNFIELDS PROPERTY BOUNDARY
PARCEL BOUNDARY
NORTH HAMBY CREEK
DIRECTION OF STREAM FLOW
FORMER BUILDING FOOTPRINT
FORMER ELEVATOR
TEMPORARY MONITORING WELL LOCATION
COMPOSITE SOIL SAMPLE LOCATION
SOIL SAMPLE LOCATION
SURFACE WATER/SEDIMENT SAMPLELOCATION
BACKGROUND SOIL SAMPLE LOCATION
3921 Sunset Ridge Road, Suite 301
Raleigh, North Carolina 27607
919-847-4241(p) 919-847-4261(f)
License # C-1269 / #C-245 Geology
S:\AAA-Master Projects\PTRC\PTR002\Thomasville Furniture Plant B Site\Figures\Site Map_20200313.dwg, FIG 4, 3/13/2020 3:36:45 PM, SVincent