22030_Durafiber Brownfields Assessment Work Plan 20200519

Via Email
May 19, 2020
NCDEQ – Division of Waste Management
Brownfields Program
1646 Mail Service Center
Raleigh, NC 27699-1646
Attn: Mr. Bill Schmithorst, PG
Re: Brownfield Assessment Work Plan
Salisbury Investments
Salisbury, North Carolina
Brownfields Project No. 22030-18-080
H&H Project No. FDP-058
Dear Bill:
On behalf of Salisbury Investments I, LLC, please find the enclosed Brownfields Assessment
Work Plan for the Salisbury Investments Brownfields property (Brownfields Project No. 22030-
18-080) located in Salisbury, Rowan County for your review and approval.
Should you have any questions or need additional information, please do not hesitate to contact
me at [phone].
Sincerely,
Hart & Hickman, PC
Haley Martin, PG Ralph McGee, PG
Assistant Project Geologist Project Manager
Enclosure
cc: Ms. MariJon Owens, Forsite Development (Via Email)
Mr. Steve Hart, PG, Hart & Hickman, PC (Via Email)
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Brownfields Assessment Work Plan
Salisbury Investments
Salisbury, North Carolina
Brownfields Project No. 22030-18-080
H&H Job No. FDP-058

Table of Contents

1.0 Introduction .............................................................................................................................1 
1.1 Background Information .......................................................................................................2 
1.2 Previous Assessment Activities .............................................................................................2 
2.0 Brownfields Assessment Activities ........................................................................................7 
2.1 Soil Sampling Activities ........................................................................................................7 
2.2 Groundwater Sampling Activities .........................................................................................9 
2.3 Surface Water Sampling Activities .....................................................................................10 
2.4 Sub-Slab Soil Vapor Sampling Activities ...........................................................................10 
2.5 Quality Assurance – Quality Control ..................................................................................12 
2.6 Investigation Derived Waste ...............................................................................................13 
3.0 Reporting ...............................................................................................................................14 

List of Tables

Table 1 Sample Summary Table

List of Figures

Figure 1 Site Location Map
Figure 2 Site and Surrounding Area Map
Figure 3 Detailed Site Map
Figure 4 Proposed Sample Location Map

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Brownfields Assessment Work Plan
Salisbury Investments
Salisbury, North Carolina
Brownfields Project No. 22030-18-080
H&H Job No. FDP-058

1.0 Introduction

On behalf of Salisbury Investments I, LLC (Prospective Developer or PD), Hart & Hickman, PC
(H&H) has prepared this Brownfields Assessment Work Plan (Work Plan) for the Salisbury
Investments Brownfields property (Brownfields Project No. 22030-18-080) located at 7401
Statesville Boulevard in Salisbury, Rowan County, North Carolina (Site). The Site consists of
five parcels totaling approximately 538 acres of land located approximately six miles west of
downtown Salisbury. A Site location map is provided as Figure 1, and the Site and surrounding
area are shown on Figure 2.

The Site is improved with an approximate two million square foot (sq ft) industrial
manufacturing facility. Remaining portions of the Site consist of undeveloped wooded land.
The industrial manufacturing facility encompasses approximately 60 acres of land in the central
portion of the Site and includes administrative offices, warehouse areas, production areas,
shipping and receiving areas, chemical storage areas, a training building, and a wastewater
treatment plant. Other Site improvements include concrete-paved parking areas, paved and
gravel covered access roads, loading areas, railroad spurs, landscaped areas, and a former
recreational clubhouse building with a pond. A detailed site map is provided as Figure 3.

Proposed redevelopment of the Brownfields property includes adaptive reuse of the existing
warehouses and training areas within the industrial manufacturing facility. In addition, the
wastewater treatment plant will continue operations and may be used to treat third-party
wastewater.
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1.1 Background Information

The Site was comprised of undeveloped vacant land from at least the late 1940s until grading and
construction of the industrial facility began in the mid-1960s. Manufacturing operations began
on the Site by 1966. The facility was historically utilized for manufacturing polymer filament
fibers and polymer chips. The polymer materials were made by combining terephthalic acid and
ethylene glycol into a molten mixture and processing the mixture into filament fibers or chips as
the material cools. Plant operations have historically included manufacturing process units, raw
materials and finished products shipping units, a wastewater treatment plant, chemical recovery
units, a construction debris landfill, and chemical recovery waste landfills.

Polymer manufacturing operations were originally conducted at the Site by Celanese under the
name Fibers Industries, Inc. In the late 1980s, Celanese was purchased by Hoechst and the name
of the facility was changed to Hoechst-Celanese. Site manufacturing operations continued as
Hoechst-Celanese until the late 1990s or early 2000s when it became KoSa. The Site was
purchased by Invista (a subsidiary of Dupont) and operations continued as Invista S.A.R.L (a
subsidiary of Koch Industries) until the early 2010s when Performance Fibers, Inc. operations
began. In 2016, Performance Fibers changed its name to Durafiber Technologies. Durafiber
Technologies operations continued at the Site until September 2017.

The Site buildings are vacant and have been unoccupied since Durafiber Technologies vacated
the Site in 2017. A portion of the Site is leased for exterior storage of tractor trailers. The
wastewater treatment facility remains in operation with limited staff.

1.2 Previous Assessment Activities

Extensive assessment, remediation, and monitoring activities have been conducted at the Site
since the early 1980s. A brief summary of the historical assessment and remedial activities is
provided below.

In the late 1960s, a glycol recovery unit bottoms landfill (GRUB landfill) opened east of the
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manufacturing facility and received waste extracted from glycol recovery operations until the
mid-1970s. In addition, chromate reduction unit (CRU) basins opened east of the facility as part
of the water-cooling system in the early to mid-1970s. The CRU basins received waste until the
mid-1980s. Waste materials disposed in both the GRUB landfill and CRU basins were removed
and transported off-Site and the waste areas were permanently closed in the mid-1980s. The
GRUB landfill was subsequently designated as a solid waste management unit (SWMU) during a
facility investigation in the early 1990s. In 1993, the U.S. Environmental Protection Agency
(EPA) agreed that removal of impacted subsurface soil in the CRU area was not practical and
that groundwater extraction was adequate to remediate impacts in the CRU.

In the early 1990s, during a Resource Conservation and Recovery Act Facility Investigation
(RCRA RFI), the Dowtherm heat transfer area, the heat transfer fluid storage area, and the
wastewater polishing ponds were identified as additional SWMUs. The Dowtherm (a mixture of
1,1-biphenyl and biphenyl ether) heater system was utilized for the production of polyester resins
and fibers used in the manufacturing process. Releases associated with storage, operations, and
maintenance resulted in the SWMU designation for the Dowtherm heat transfer system area.
The polishing ponds received effluent from the plant wastewater treatment system and were
estimated to contain approximately 85,000 cubic yards of sludge material that was identified as a
potential source of groundwater impacts identified east of the manufacturing facility. In 1994
and 1995, sludge was removed from two of the wastewater polishing ponds and was disposed of
off-Site. Subsequently, a sludge dewatering system was installed to minimize the entry of sludge
into the polishing ponds, although Durafiber may not have used the sludge dewatering system.

On April 6, 1990, Hoechst Celanese Corporation entered into a RCRA 3008(h) Administrative
Order on Consent (AOC) with the EPA to complete assessment and remedial activities for
protection of human health and the environment from impacts associated with historical
manufacturing operations at the Site. On October 4, 2000, CNA Holdings, LLC (formerly
Hoechst Celanese Corporation) entered into a Final AOC with the EPA.

Hoechst Celanese Corporation completed voluntary groundwater assessment activities at the Site
to evaluate the potential for impacts associated with manufacturing operations as early as 1981.
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Based on assessment results, several organic and inorganic compounds were identified in Site
groundwater. The GRUB landfill area, the CRU basins, the Dowtherm heat transfer area, and the
wastewater polishing ponds were identified as the primary sources for impacts identified in
groundwater. Free product Dowtherm was also identified in the subsurface in the Dowtherm
SWMU area. By the late 1980s and early 1990s, groundwater extraction systems were installed
in and around these sources areas as well as along the eastern Site boundary to control migration
of impacted groundwater.

As part of the assessment activities in the early to mid-1990s, Hoechst Celanese sampled water
supply wells north and east of the facility on a voluntary basis. Subsequent to the sampling and
analysis of these wells, Hoechst Celanese determined that City of Salisbury water would be
provided to residents east of Second Creek near the Spring Hills subdivision and at specific
locations along Highway 70 north of the plant. Private wells in Spring Hills and ten private
wells along Highway 70 were subsequently abandoned and restrictions against the drilling of
new wells in the area have been implemented.

Historically, 1,4-dioxane has been detected above the North Carolina Department of
Environmental Quality (DEQ) 2B Surface Water Standard (2B Standard) in Second Creek
located along the eastern Site boundary. Concentrations of 1,4-dioxane decreased to levels
below the 2B Standard for a period of time in the 2000s, but increased to levels above the 2B
Standard in the 2010s. The increases in 1,4-dioxane concentrations in the Second Creek were
attributed to Durafiber processes discharging to the wastewater treatment plant polishing ponds
because an increase in concentrations was also observed in the pond effluent during this
timeframe.

The GRUB landfill, CRU basin, and eastern Site boundary groundwater extraction systems
operated until 2004. In 2011, groundwater extraction activities in the Dowtherm SWMU area
were discontinued. Annual groundwater monitoring for natural attenuation and plume stability is
the currently approved action for addressing impacts in Site groundwater. Constituents
monitored in groundwater include chlorobenzene, 1,2-dichlorobenzene, 1,4-dichlorobenzene,
1,1-biphenyl, biphenyl ether, ethylene glycol, and 1,4-dioxane.
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May 2018 Phase I ESA
H&H completed Phase I Environmental Site Assessment (ESA) activities at the Site in May
2018. Results of the Phase I ESA identified residual soil, groundwater, and surface water
impacts associated with historical industrial and manufacturing operations to be environmental
concerns in connection with the Site.

2019 Annual Groundwater Monitoring Report
In September 2019, annual groundwater monitoring activities were completed at the Site by
AECOM on behalf of CAN Holdings. The September 2019 groundwater monitoring data
indicates that target constituents of concern are present at concentrations exceeding the DEQ 2L
Groundwater Standards (2L Standards) in Site groundwater and above the DEQ 2B Standards in
samples collected from Second Creek. During the September 2019 sampling event, no
compounds were detected in groundwater above the Site-specific “trigger levels”, except for
chlorobenzene. However, chlorobenzene concentrations in Site groundwater appear to be
decreasing or stable over time.

The “trigger levels” were determined based on the maximum detected concentrations of
constituents in groundwater during a Risk Assessment performed in 1998. The trigger levels
were established as part of the request to terminate active remedial actions and are levels that, if
exceeded, could trigger additional active remedial actions. The trigger levels have periodically
been exceeded, but not for an extended period of time and no additional active remediation has
been performed since shut down of the groundwater extraction systems. The recent groundwater
and surface water sampling activities are documented in the 2019 Annual Groundwater
Monitoring Report prepared by AECOM dated February 14, 2020.

To address environmental concerns associated with historical Site use, the PD elected to enter
the Site into the DEQ Brownfields Program and received eligibility in a letter dated September
24, 2018. A meeting was held at the Site with DEQ Brownfields personnel in December 2018.
In an email dated April 6, 2020, the DEQ Brownfields Program requested additional assessment
to evaluate current environmental conditions at the Site. Based on subsequent correspondence,
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DEQ Brownfields provided concurrence on the additional assessment in an email dated May 1,
2020. To address DEQ Brownfields requests for additional assessment, H&H has prepared this
Work Plan to conduct Brownfields assessment activities at the Site.

The purpose of the Brownfields assessment activities described herein is to further evaluate the
potential for impacts at the Site for the protection of Site workers during redevelopment and for
future Site occupants. The Brownfields assessment activities discussed in the following sections
include the collection of soil, groundwater, surface water, and sub-slab soil vapor samples. A
summary of the proposed Brownfields assessment activities is provided below and a sample
summary table is provided as Table 1.
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2.0 Brownfields Assessment Activities

The Brownfields assessment activities will be conducted in general accordance with the DEQ
Inactive Hazardous Sites Branch (IHSB) Guidelines for Assessment and Cleanup of
Contaminated Sites (Guidelines) dated January 2020, 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
Division (SESD) Field Branches Quality System and Technical Procedures guidance.

Prior to conducting the proposed assessment 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. Additionally, soil boring locations will be hand
cleared to approximately 5 feet (ft) below the ground surface (bgs) prior to use of mechanical
drilling equipment to further screen the boring locations for the presence of subsurface utilities.

2.1 Soil Sampling Activities

H&H will conduct soil sampling as part of the Brownfields assessment activities. The purpose
of the soil sampling is to evaluate for potential impacts in areas of potential environmental
concern and to establish Site-specific ranges for naturally occurring metals. Soil borings will be
advanced in areas near former fuel oil storage, a cooling tower, and the Dowtherm heating units.
Locations of the proposed soil borings are shown in Figure 4. A tabular summary of proposed
soil sample depths, objectives, and laboratory analyses are summarized in Table 1.

H&H will team with a qualified drilling contractor to advance soil borings at the Site. During
boring advancement, soil will be logged for lithological description and field screened for
indication of potential impacts by observation for obvious staining, unusual odors, and the
presence of volatile organic vapors using a calibrated photoionization detector (PID). Soil
samples will be collected from the depth interval that exhibits the highest potential for impact or
as described below.
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 Three soil borings (SB-1 through SB-3) will be advanced to approximately 15 ft bgs in
the vicinity of previous soil borings DTHA-4, DTHA-5, and DTHA-8 advanced by others
in the mid-1980s adjacent to the Dowtherm systems. Based upon field observations, one
soil sample will be collected from each boring for laboratory analysis from the depth
interval with the highest potential for impacts. If no obvious impacts are observed during
field screening, a sample will be collected from a similar depth interval (3 ft to 8 ft) as
soil samples collected in the mid-1980s.

 Two soil borings (SB-4 and SB-5) will be advanced in the vicinity of the former fuel oil
above ground storage tanks (ASTs) located in the southeastern portion of the
manufacturing facility. Soil borings in the vicinity of the fuel oil storage tanks will be
advanced to 10 ft bgs adjacent to the concrete secondary containment system. Based
upon field observations, one soil sample will be collected from each boring for laboratory
analysis from the depth interval with the highest potential for impacts. If no obvious
impacts are observed during field screening, a sample will be collected from a depth
interval interpreted to be below the base of the concrete secondary containment system.

 Two shallow soil borings (SB-6 and SB-7) will be advanced on the eastern
(downgradient) side of the cooling towers located in the southeastern portion of the
manufacturing facility. Soil borings SB-6 and SB-7 will be advanced to 3 ft bgs and a
soil sample will be collected from the 2 ft to 3 ft depth interval from each soil boring.

The soil samples selected for laboratory analysis 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. The samples will be delivered to a North
Carolina certified laboratory under standard chain of custody protocols for laboratory analysis.
Soil samples SB-1 through SB-5 will be analyzed for volatile organic compounds (VOCs) by
EPA Method 8260, semi-VOCs by EPA Method 8270, RCRA metals by EPA Methods
6020/7471, and hexavalent chromium by EPA Method 7199. Soil samples SB-6 and SB-7 will
be submitted for analysis of total chromium by EPA Method 6020 and hexavalent chromium by
EPA Method 7199.
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In addition to the soil samples described above, H&H will also collect two background soil
samples at the Site (BG-1 and BG-2) to evaluate background levels of naturally occurring
metals. The soil samples will be collected from areas of the Site that appear to be historically
undisturbed by historical uses. The samples will be collected from a depth interval
representative of other samples collected at Site and submitted for laboratory analysis of RCRA
metals by EPA Methods 6020/7471 and hexavalent chromium by EPA Method 7199.

Following sampling activities, the soil borings will be properly abandoned and the surfaces will
be repaired similar to pre-drilling conditions. Additionally, the soil sample locations will be
estimated using a hand held global positioning system (GPS) unit.

2.2 Groundwater Sampling Activities

As described above, annual groundwater monitoring activities are conducted at the Site by others
as part of the October 4, 2000 Final AOC with the EPA and were last completed in September
2019. At the request of DEQ Brownfields, groundwater samples will be collected from eight (8)
existing groundwater monitoring wells (Z-90, GG-43, DD-40, S-58, RR-102, R-30, YY-37, and
TT-34) located downgradient of the manufacturing facility and in the vicinity of the polishing
ponds located in the southeastern portion of the Site. The approximately locations of the eight
groundwater monitoring wells that will be sampled for Brownfields purposes are shown in
Figure 4.

Prior to sampling, a decontaminated electronic water level indicator will be used to measure the
depth to the water table relative to the tops of well casings in each well. Groundwater samples
will be collected utilizing low flow/low stress purging techniques using a peristaltic pump or
bladder pump and dedicated polyethylene tubing. The intake point of the pump tubing will be
placed in the approximate 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 calibrated water
quality meters to collect measurements of pH, temperature, dissolved oxygen, oxidation
reduction potential, turbidity, and specific conductivity at three to five-minute intervals during
the purging process. Purging will be considered complete when field parameters stabilize (pH ±
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0.1 Standard Units, conductivity varies no more than 5%, and turbidity is less than 10
Nephelometric Turbidity Units).

Once groundwater parameters stabilize, groundwater samples for VOC analysis will be collected
directly into laboratory supplied sample containers using the “soda straw” method to eliminate
the potential for volatile compound loss through the pump head. Samples collected for the
remaining analyses will be collected directly into laboratory supplied sample containers from the
dedicated sample tubing discharge. The sample containers will be labeled with the sample
identification, date, and requested analysis, and placed in a laboratory supplied cooler with ice.
The groundwater samples will be delivered to a North Carolina certified laboratory under
standard chain of custody protocols for analyses of VOCs by EPA Method 8260, SVOCs by
EPA Method 8270, RCRA metals by EPA Method 6020/7471, and hexavalent chromium by
EPA Method 7199.

2.3 Surface Water Sampling Activities

H&H proposes to collect two (2) surface water samples from Second Creek. H&H proposes to
collect one upgradient surface water sample (SW-1) near the southeastern property boundary and
one downgradient surface water sample (SW-4) near the northeastern property boundary (Figure
4). Surface water samples will be collected directly into dedicated laboratory supplied sample
containers and labeled with the sample identification, date, time, and requested analysis. The
samples will be place in a laboratory supplied cooler with ice and delivered to a North Carolina
certified laboratory under standard chain of custody protocols for analysis of VOCs by EPA
Method 8260, SVOCs by EPA Method 8270, and RCRA metals plus hexavalent chromium by
EPA Method 6020/7470/7199.

2.4 Sub-Slab Soil Vapor Sampling Activities

To evaluate the potential for structural vapor intrusion, H&H proposes to collect eleven (11) sub-
slab soil vapor samples (SS-1 through SS-11) from the warehouse, utility, and training buildings.
Three sample points (SS-1 through SS-3) will be installed in the eastern portion of the filament
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warehouse, four sample points (SS-4 through SS-7) will be installed in the eastern portion of the
staple warehouse, two samples (SS-8 and SS-9) will be installed in in a utility building located in
the northeastern portion of the manufacturing facility, and two samples (SS-10 and SS-11) will
be installed in the training building located in southern portion of the manufacturing facility.
The proposed sub-slab soil vapor sample locations are shown on Figure 4.

The temporary sampling points will be installed using a rotary hammer drill and 1½-inch
diameter drill bit to advance a pilot hole into the concrete slab to a depth of approximately 1¾
inches below the slab surface. A drill guide will then be placed within the pilot hole, and a
5/8-inch diameter drill bit will be utilized to advance a boring through the concrete slab to
approximately 6 inches into the underlying soil/gravel beneath the slab. Loose concrete cuttings
will be then be removed from each boring, and a Cox-Colvin Vapor Pin™ (vapor pin) assembly
(brass sampling point and silicone sleeve) will be seated in the borehole using an
installation/extraction tool and dead blow hammer.

Following vapor pin installation, Teflon sample tubing will be connected to the barbed end of the
vapor pin. A laboratory supplied batch certified 1-liter or 3-liter stainless steel Summa sample
canister will be connected to an in-line flow controller with a vacuum gauge and the flow
controller will be connected to the sample tubing 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 vapor intake
rate to approximately 100 milliliters per minute.

Prior to collection of the sub-slab soil vapor samples, a leak check will be conducted by
constructing a shroud around the sample train at each sampling point and flooding the air within
the shroud with helium gas. Helium concentrations inside the shroud will be measured using a
calibrated helium gas detector and maintained at concentrations of approximately 20% to 40%
for the duration of the leak check. Using a syringe and three-way valve, the Teflon sample
tubing will be purged and a sample will be collected from the sample tubing outside the shroud
into a Tedlar bag and analyzed using the helium gas detector to ensure that helium
concentrations are less than 10% of the helium concentrations measure within the shroud.
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Following a successful leak check, the intake valve on the Summa canister will be fully opened
to begin collection of the sub-slab soil vapor 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.

After sample collection, the flow controller valve will be closed and 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 VOCs by EPA Method TO-15. The laboratory will be requested to use reporting
limits that are below DEQ DWM Non-Residential Vapor Intrusion Sub-slab and Exterior Soil
Gas Screening Levels.

Following collection of the sub-slab soil vapor samples, the vapor pins will be removed and the
concrete surface will be patched to match the surrounding area. Each sample location will be
estimated by measuring from known benchmarks within the facility (e.g., doors, windows,
exterior walls, etc.).

2.5 Quality Assurance – Quality Control

Non-dedicated equipment and tools will be decontaminated prior to use at each boring or
sampling location or following exposure to soil, groundwater, or surface water. The following
samples will be collected for quality assurance/quality control (QA/QC) purposes:
 One duplicate soil, groundwater, and surface water sample will be collected and analyzed
for the same parameters as the parent samples.
 One trip blank will accompany the groundwater samples during the field activities as well
as during sample shipment. The trip blank will be analyzed for VOCs by EPA Method
8260.
 One duplicate sub-slab vapor sample will be collected using a laboratory supplied
T-fitting which allows for collection of two samples from one sub-slab soil vapor
sampling point simultaneously. The duplicate sub-slab soil vapor sample will be
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submitted for analysis of VOCs by EPA Method TO-15.

Laboratory 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 the method protocols and will include regular equipment
maintenance, equipment calibrations, and adherence to specific sample custody and data
management procedures. Samples will be analyzed in conjunction with appropriate blanks,
laboratory duplicates, continuing calibration standards, surrogate standards, and matrix spiking
standards in accordance with approved methodologies to monitor both instrument and analyst
performance. Laboratory reporting limits for each analyte will be at or below appropriate
screening criteria, where possible. Additionally, H&H will request that the laboratory include
estimated concentrations for compounds that are detected at levels above the laboratory method
detection limit, but below the laboratory reporting limit (J flags).

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.
Laboratory QA data consistent with Level II documentation will be provided for this project. A
copy of the completed chain of custody record and shipping receipt will be appended to the
corresponding laboratory analytical report included with the final report.

2.6 Investigation Derived Waste

Investigation derived waste (IDW) generated during the proposed assessment activities are
expected to be minimal and will be managed in general accordance with DEQ IHSB Guidelines.
IDW soil generated during the assessment activities will be thin spread on-Site. IDW
groundwater will be placed in the wastewater treatment. If significant impacts are suspected
(i.e., elevated PID readings, free-product, etc.) the IDW will be containerized in labeled 55-
gallon drums and staged on-Site pending analytical results of a composite IDW sample. Based
on laboratory analytical results of IDW samples, the drums will be transported off-Site to a
suitable facility for disposal.
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3.0 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 a
description of the sampling activities; a figure depicting sample locations; soil boring logs;
groundwater sampling logs, laboratory analytical data; a discussion of the data in comparison to
regulatory screening levels; and conclusions and recommendations concerning our activities.
For the sub-slab vapor results, H&H will use the NC DEQ risk calculator to further evaluate
potential risks based on the data, if needed.
Table 1Sample Summary TableSalisbury InvestmentsSalisbury, North Carolina Brownfields Project No. 22030-18-080H&H Project No. FDP-058SB-1 through SB-3 Dowtherm Area Evaluation 15 varies 3VOCs (8260), semi-VOCs (8270), RCRA metals (6020/7471), and hexavalent chromium (7199)SB-4 and SB-5 Former Fuel Oil AST Area Evaluation 10 8-10 2VOCs (8260), semi-VOCs (8270), RCRA metals (6020/7471), and hexavalent chromium (7199)SB-6 and SB-7 Cooling Tower Area Evaluation 3 2-3 2 total chromium (6020) and hexavalent chromium (7199)BG-1 and BG-2Establish Site-Specific BackgroundMetal Concentrations32-32RCRA metals (6020/7471) and hexavalent chromium (7199)Z-90, GG-43, DD-40, S-58, RR-102, R-30, YY-37, and TT-34Groundwater Evaluate Groundwater Conditions 8VOCs (8260), semi-VOCs (8270), RCRA metals (6020/7470), and hexavalent chromium (7199)SW-1 and SW-4 Surface Water Evaluate Surface Water Conditions 2VOCs (8260), semi-VOCs (8270), RCRA metals (6020/7470), and hexavalent chromium (7199)SS-1 through SS-11 Sub-Slab Vapor Evaluate Potential VI Risks 11 VOCs (TO-15)SB-DUP Soil15 varies 1VOCs (8260), semi-VOCs (8270), RCRA metals (6020/7471), and hexavalent chromium (7199)GW-DUP Groundwater 1VOCs (8260), semi-VOCs (8270), RCRA metals plus hexavalent chromium (6020/7470/7199)SW-DUP Surface Water1VOCs (8260), semi-VOCs (8270), RCRA metals plus hexavalent chromium (6020/7470/7199)SS-DUP Sub-Slab Soil Vapor1 VOCs (TO-15)Trip Blank Trip Blank1 VOCs (8260)Notes:EPA Method number follows laboratory parameter in parenthesis. VOCs = Volatile Organic Compounds; RCRA = Resource Conservation Recovery Actft = feet; QA/QC = Quality Assurance/ Quality Control; VI = Vapor Intrusion; AST = Above Ground Storage Tank; NA = Not ApplicableNAQA/QCSoilUpgradient and Downgradient Second CreekDowngradient Second CreekvariesvariesBelow SlabBelow SlabSample IDsApproximate Boring Depth (ft)Number of SamplesLaboratory AnalysisSample ObjectiveSample TypeApproximate Sample Depth (ft)S:\AAA-Master Projects\ForSite Development Partners (FDP)\FDP-058 Durafiber Celanese Salisbury\Brownfields\Assessment\Work Plan\Sample Summary Table.xlsxTable 1Hart & Hickman, PC
SITE
0 2000 4000
APPROXIMATE
SCALE IN FEET
N
U.S.G.S. QUADRANGLE MAP
QUADRANGLE
7.5 MINUTE SERIES (TOPOGRAPHIC)
ROWAN MILLS, NORTH CAROLINA 1991
TITLE
PROJECT
SITE LOCATION MAP
SALISBURY INVESTMENTS
7401 STATESVILLE BOULEVARD
SALISBURY, NORTH CAROLINA
DATE:
JOB NO:
REVISION NO:
FIGURE:
5/11/2020 0
1FDP-058
REVISION NO. 0
JOB NO. FDP-058
DATE: 5-11-20
FIGURE NO. 2
SALISBURY INVESTMENTS
7401 STATESVILLE BOULEVARD
SALISBURY, NORTH CAROLINA
SITE MAP
LEGEND
BROWNFIELDS SITE BOUNDARY
SECOND CREEK
2923 South Tryon Street-Suite 100
Charlotte, North Carolina 28203
704-586-0007(p) 704-586-0373(f)
License # C-1269 / #C-245 Geology
STATES
V
I
L
L
E

B
O
U
L
E
V
A
R
D
OL
D

U
.
S
.

H
W
Y

7
0
HWY 801CELANESE DRIVEPARKS ROADNOTE:
1.AERIAL IMAGERY OBTAINED FROM NC ONEMAP,
2019.
ALLISON BROS. RACE CARS
(7920 STATESVILLE BOULEVARD)
RESIDENTIAL
AGRICULTURAL
LAND
AGRICULTURAL
LAND
RURAL
RESIDENTIAL
UNDEVELOPED
WOODED LAND MERIDIAN AUTOMOTIVE SYSTEMS
(6701 STATESVILLE BOULEVARD)
DUKE POWER
SUBSTATION
AGRICULTURAL
LAND
RESIDENTIALUNDEVELOPED
WOODED LANDAGRICULTURAL
LAND
FORMER DURAFIBER
TECHNOLOGIES FACILITY
S:\AAA-Master Projects\ForSite Development Partners (FDP)\FDP-058 Durafiber Celanese Salisbury\Figures\Site Map.dwg, FIG 2, 5/19/2020 10:02:27 AM, sperry
CELANESE DRIVEFORMER WASTE PIT
POLISHING
POND
POLISHING
POND
POLISHING
POND
POLISHING
POND
(2) AERATION BASINS
DIGESTOR
PROCESS
WATER POND
GROUNDWATER
REMEDIATION SYSTEM
ABANDONED AERATION BASIN
PARKING
PARKING
REC CLUBHOUSE
FIBER
LAKE
STAPLE WAREHOUSE
FILAMENT
WAREHOUSE
EQUALIZATION TANKS
CLARIFIER
FUEL OIL STORAGE
GLYCOL RECOVERY UNIT
UTILITIES
POLYMER SPINNING
POLYMER SPINNING
DOW REBOILERS
DOW STORAGE
DOW BOILERS
DOW STORAGE
GLYCOL STORAGE
GLYCOL RECOVERY STORAGE
REVISION NO. 0
JOB NO. FDP-058
DATE: 5-11-20
FIGURE NO. 3
SALISBURY INVESTMENTS
7401 STATESVILLE BOULEVARD
SALISBURY, NORTH CAROLINA
DETAILED SITE MAP
2923 South Tryon Street-Suite 100
Charlotte, North Carolina 28203
704-586-0007(p) 704-586-0373(f)
License # C-1269 / #C-245 Geology
NOTE:
1.AERIAL IMAGERY OBTAINED FROM NC ONEMAP,
2019.
LEGEND
BROWNFIELDS SITE BOUNDARY
SECOND CREEK
RAILROAD SPUR
S:\AAA-Master Projects\ForSite Development Partners (FDP)\FDP-058 Durafiber Celanese Salisbury\Figures\Detailed Site Map.dwg, FIG 3, 5/19/2020 10:05:03 AM, sperry
POLISHING
POND
POLISHING
POND
POLISHING
POND
POLISHING
POND
DIGESTOR
PROCESS
WATER POND
ABANDONED AERATION BASIN
PARKING
FIBER
LAKE
STAPLE WAREHOUSE
FILAMENT
WAREHOUSE
CLARIFIER
FUEL OIL STORAGE
DOW REBOILERS
DOW STORAGE
DOW BOILERS
DOW STORAGE
SB-1
SB-2
SB-3
SB-4 SB-5
SB-6
SB-7
SS-2
SS-5
SS-1
SS-3
SS-4
SS-6
SS-7
SS-8
SS-9
SS-10 SS-11
SW-4
SW-1
Z-90
TT-34
YY-37
R-30
RR-102
S-58DD-40
GG-43
REVISION NO. 0
JOB NO. FDP-058
DATE: 5-11-20
FIGURE NO. 4
SALISBURY INVESTMENTS
7401 STATESVILLE BOULEVARD
SALISBURY, NORTH CAROLINA
PROPOSED SAMPLE LOCATION MAP
2923 South Tryon Street-Suite 100
Charlotte, North Carolina 28203
704-586-0007(p) 704-586-0373(f)
License # C-1269 / #C-245 Geology
NOTE:
1.AERIAL IMAGERY OBTAINED FROM NC ONEMAP,
2019.
LEGEND
BROWNFIELDS SITE BOUNDARY
SECOND CREEK
RAILROAD SPUR
PROPOSED DOWTHERM HEATER
SOIL SAMPLE
PROPOSED FUEL OIL STORAGE
SOIL SAMPLE
PROPOSED COOLING TOWER
SOIL SAMPLE
GROUNDWATER MONITORING
WELL
PROPOSED SURFACE WATER
SAMPLE LOCATION
PROPOSED SUB-SLAB SOIL
VAPOR SAMPLE LOCATION
S:\AAA-Master Projects\ForSite Development Partners (FDP)\FDP-058 Durafiber Celanese Salisbury\Figures\Detailed Site Map.dwg, FIG 4, 5/19/2020 10:06:19 AM, sperry