22058_Erwin Mill_AWPAddRev1_20191029

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Dart ' hickma n
SMARTER ENVIRONMENTAL SOLUTIONS
Via Email
October 29, 2019
North Carolina Department of Environmental Quality
Division of Waste Management — Brownfields Program
1646 Mail Service Center
Raleigh, North Carolina 27699-1646
Attn: Ms. Reina Clark
Re: Brownfields Assessment Work Plan Addendum — Revision 1
Erwin Mill
200 North 131h Street
Erwin, Harnett County, NC
Brownfields Project No. 22058-18-043
H&H Job No. BRP-001
Dear Reina:
1.0 Introduction
On behalf of Erwin Plant, LLC, Hart & Hickman, PC (H&H) has prepared this Work Plan
Addendum to conduct additional Brownfields assessment activities at the Erwin Mill
Brownfields property located at 200 North 131h Street in Erwin, Harnett County, North Carolina
(Site). Erwin Mill (Parcel ID 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. A Site location map is provided as Figure
1, and the Site and surrounding area are shown in Figure 2.
Erwin Mill 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
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Plan Addendum Rev 1 - Erwin Mill (BPN 22058-18-043).doc
SMARTER ENVIRONMENTAL SOLUTIONS

Ms. Reina Clark
October 29, 2019
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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).
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. Areas of concern (AOCs) have been
developed based on a review of Site history, prior chemical usage and waste management, and
previous assessment activities including a 1997 underground storage tank (UST) closure, 1998
fuel oil removal in the area of the dye storage building, 2001 Phase II Environmental Site
Assessment (ESA), and 2015 Phase I ESA. On March 9, 2019, H&H attended a meeting with
DEQ Brownfields personnel to discuss Site history, areas of potential environmental concern,
potential data gaps, and the scope of Brownfields assessment activities to evaluate the Site for
potential impacts. H&H subsequently prepared a Brownfields Assessment Work Plan — Revision
1, which includes previous assessment activities and details for each AOC, outlining proposed
assessment activities which received DEQ Brownfields approval in an email dated June 4, 2019.
In July 2019, H&H completed soil, groundwater, surface water, sediment, soil gas, and
crawlspace air assessment activities at the Site in accordance with the DEQ approved June 2019
Work Plan to evaluated for impacts associated with historical operations in ten AOCs. A
detailed description of each AOC and the Brownfields assessment activities are documented in
our Brownfields Assessment Report dated September 5, 2019. A brief summary of the
Brownfields assessment results and data gaps is provided below. Previous sample locations are
provided on Figure 3.
• VOCs and PAHs were detected at elevated concentrations in surficial soil and sub -slab
gas in the finishing building; however, groundwater in the finishing building did not
contain detectable concentrations of VOCs or SVOCs. Constituents detected in surficial
hart hickman
SAAAA-Master Projects\Brooks Pierce\Erwin Mill (BRP.001)\Brownfields Assessment Work Plan Addendum\Brownfields Work
Plan Addendum Rev 1 - Erwin Mill (BPN 22058-18-043).doc SMARTER ENVIRONMENTAL 5O W TIONS

Ms. Reina Clark
October 29, 2019
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soil do not appear to be leaching into groundwater in this area. The calculated cumulative
vapor intrusion risk levels associated with detected sub -slab gas concentrations in the
exceeded acceptable levels under both residential and non-residential use scenarios. In
addition, calculated cumulative vapor intrusion risk levels exceeded acceptable levels
under a residential use scenario along a connecting sanitary sewer line in eastern
warehouse/offices. The data suggests that impacted soil in the finishing building may be
creating a vapor intrusion risk that has extended from the finishing building along a
preferential pathway from the trench drain in the finishing building along the sanitary
sewer line into the eastern warehouse/office.
• Naphthalene was detected at an elevated concentration in sub -slab gas in the winding
area. The calculated cumulative vapor intrusion risks associated with detected sub -slab
gas concentrations exceeded acceptable levels under a residential use scenario.
Calculated cumulative vapor intrusion risks were acceptable under a non-residential use
scenario. The data suggests that an unknown naphthalene source may be creating a vapor
intrusion risk for future residential use in the winding building; however, there are no
unacceptable risks under current non-residential use.
• PCE was detected at elevated concentrations in sub -slab gas in the former dye house;
however, PCE was not detected in soil samples collected in the area. The calculated
cumulative vapor intrusion risks associated with detected sub -slab gas concentrations
exceeded acceptable levels under a residential use scenario. However, calculated
cumulative vapor intrusion risks were acceptable under a non-residential use scenario.
The data suggests that an unknown PCE source may be creating a vapor intrusion risk for
future residential use; however, there are no unacceptable risks under current non-
residential use. PAH-impacted soils were not contributing significantly to vapor intrusion
risk.
• VOCs and PAHs were detected at elevated concentrations in the "tar -like" material from
the seams near the former support beams of the former cotton blending building. Based
is
hart hickman
SAAAA-Master Projects\Brooks Pierce\Erwin Mill (BRP.001)\Brownfields Assessment Work Plan Addendum\Brownfields Work
Plan Addendum Rev 1 - Erwin Mill (BPN 22058-18-043).doc SMARTER ENVIRONMENTAL 5O W TIONS

Ms. Reina Clark
October 29, 2019
Page 4
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on field observations, the material appears to react to temperature changes and could
potentially impact the underlying soil.
• PCB congeners 77, 105, 114, 118, 123, 156/157, 167, 189, and total non -dioxin like PCB
congeners were detected above PSRGs in soil samples collected in the vicinity of the
three PCB transformers with the highest historical aroclor concentrations at the Site.
Historical data indicated that an additional eight PCB transformers have elevated aroclor
concentrations above Residential and/or Industrial/Commercial PSRGs. These
transformers have not been evaluated for PCB congeners. All Site transformers are
reportedly inactive at this time.
• Elevated concentrations of petroleum -related VOCs were detected sub -surface soil in the
UST basin. Based on the estimated depth to water in the soil borings (14 ft bgs), it is
possible that petroleum -related constituents could migrate to groundwater; however,
historical groundwater assessment downgradient of USTs did not reveal evidence of
impacted groundwater.
Because of the exceedances of acceptable risk levels associated with soil gas concentrations in
the finishing building, eastern warehouse/offices, former dye house, and winding area, the
Brownfields Program requested additional evaluation of vapor intrusion. In addition, Erwin
Plant, LLC, believes additional assessment of impacted soil in the finishing building, former
UST basin, and around PCB -containing transformers will be beneficial for understanding site
risks and possibly enhance site redevelopment. Therefore, H&H has prepared this Work Plan
Addendum to further evaluate the potential for impacts and potential exposure risk to future
occupants.
2.0 Brownfields Assessment Activities
The proposed additional Brownfields assessment activities will be performed in general
accordance with the DEQ Inactive Hazardous Sites Branch (IHSB) Guidelines for Assessment
is
hart hiekman
SAAAA-Master Projects\Brooks Pierce\Erwin Mill (BRP.001)\Brownfields Assessment Work Plan Addendum\Brownfields Work
Plan Addendum Rev 1 - Erwin Mill (BPN 22058-18-043).doc SMARTER ENVIRONMENTAL 5O W TIONS

Ms. Reina Clark
October 29, 2019
Page 5
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and Cleanup (Guidelines) dated October 2015, the DEQ Division of Waste Management (DWM)
Vapor Intrusion Guidance dated March 2018, and the 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 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 review the Site -
specific Health and Safety Plan and ensure safety objectives are met and are in accordance with
Occupational Health and Safety Administration (OSHA) requirements.
2.1 Soil Assessment Activities
H&H proposes to conduct soil assessment activities to delineate naphthalene impacts within the
finishing building, petroleum impacts associated with the former UST basin, and to evaluate
current subsurface conditions for potential impacts from PCB transformers. H&H will team with
a qualified drilling contractor to advance soil borings to depths ranging from approximately 4 to
15 feet below ground surface (ft bgs). Proposed soil sample locations are depicted on the
proposed 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
11
hart hickman
SAAAA-Master Projects\Brooks Pierce\Erwin Mill (BRP.001)\Brownfields Assessment Work Plan Addendum\Brownfields Work
Plan Addendum Rev 1 - Erwin Mill (BPN 22058-18-043).doc SMARTER ENVIRONMENTAL SOLUTIONS

Ms. Reina Clark
October 29, 2019
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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.
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 eight soil samples will be collected from four soil borings advanced in the finishing
building to delineate soil impacts in the vicinity of monitoring well MW-13. In addition,
a soil boring will be advanced adjacent to MW-13 to collect a subsurface soil sample to
vertically delineate soil impacts. The samples will be submitted for analysis of VOCs by
EPA Method 8260D, SVOCs by EPA Method 8270E, and RCRA metals (arsenic,
barium, cadmium, chromium, lead, mercury, selenium, and silver) plus hexavalent
chromium by EPA Methods 6020/7471 B/7196A.
• Up to six soil samples will be collected from three soil borings advances in the vicinity of
the former UST basin to delineate soil impacts. The samples will be submitted for
analysis of VOCs by EPA Method 8260D and SVOCs by EPA Method 8270E.
• Seven soil samples will be collected at a depth of 3-4 ft bgs from soil borings advanced in
the vicinity of seven PCB transformers where soils from approximately 4 ft bgs had
previously exceeded acceptable levels for Aroclor during the 2001 sampling event. Note
that two PCB transformers (HA-16 and HA-19) did not demonstrate Aroclor
concentrations above acceptable limits and therefore will not be sampled. Soil samples
will be submitted for analysis of PCB congeners by EPA Method 1668A.
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hart hiekman
SAAAA-Master Projects\Brooks Pierce\Erwin Mill (BRP.001)\Brownfields Assessment Work Plan Addendum\Brownfields Work
Plan Addendum Rev 1 - Erwin Mill (BPN 22058-18-043).doc SMARTER ENVIRONMENTAL 5O W TIONS

Ms. Reina Clark
October 29, 2019
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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.).
2.2 "Tar -Like" Material Extent Evaluation
H&H proposes to conduct an evaluation of the extent of the "tar -like" material on and beneath
the former cotton blending building slab. During previous assessment activities, the "tar -like"
material has been observed spreading from seams in the concrete pad. Analytical data of the
material indicated that the material is a petroleum -based substance. H&H will team with a
qualified drilling contractor to advance approximately 30 borings in a grid pattern across the
building slab to determine the extent of the "tar -like" material. Each grid boring will be
advanced through the concrete slab to a depth of 4 ft bgs using a hand auger and DPT drill rig.
The drilling cuttings will be evaluated for the presence of the "tar -like" material and observations
recorded. If "tar -like" material is observed near the edge of the building slab, the borings will be
offset to outside the building slab. Following sampling activities, borings will be properly
abandoned and the surfaces will be repaired similar to pre -drilling conditions.
2.3 Indoor Air Assessment Activities
H&H proposes to collect five indoor air samples to evaluate the potential for structural vapor
intrusion into the existing Site buildings. The proposed indoor air sampling locations are
generally based on the sub -slab sampling locations within the finishing building, eastern
warehouse/offices, former dye house, and winding area where risk levels exceeded acceptable
thresholds. Proposed sample locations are depicted on Figure 4. The proposed indoor air
assessment will be performed in general accordance with the DEQ DWM Vapor Intrusion
Guidance dated March 2018 and as described below.
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hart hiekman
SAAAA-Master Projects\Brooks Pierce\Erwin Mill (BRP.001)\Brownfields Assessment Work Plan Addendum\Brownfields Work
Plan Addendum Rev 1 - Erwin Mill (BPN 22058-18-043).doc SMARTER ENVIRONMENTAL 5O W TIONS

Ms. Reina Clark
October 29, 2019
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In order to collect the indoor air samples under conservative conditions, the samples will be
collected with ingress and egress activities minimized. The indoor air samples will be collected
using 6-liter stainless steel Summa sample canisters connected to in -line flow controllers with a
vacuum gauge. The flow controllers will be set so that the samples are collected over an 8-hour
period. A 3-foot long sampling cane will be connected to the flow controller so that the sample
intake point is positioned approximately 5 ft above grade (typical breathing zone height) when
the sample canister is set on its base.
During the sampling activities, indoor/outdoor air pressure differential will be measured near the
start, middle, and end of the 8-hour sampling period using a manometer sensitive to 0.001 inches
of water. In addition, exterior wind speed, exterior wind direction, indoor/outdoor temperature,
and precipitation (if any) will be recorded near the start, middle, and end of the sampling period.
For quality assurance purposes, H&H personnel will be on -Site monitoring the sample canisters
to prevent tampering or damages for the duration of the sampling event. A vacuum will be
maintained within the canisters at the conclusion of the sampling event.
Prior to and after the indoor air samples are collected, vacuum in the canisters will be measured
using a laboratory -supplied vacuum gauge and recorded by sampling personnel. The starting and
ending vacuum in each canister will be recorded on the sample chain -of -custody. The sample
canisters will then be labeled and shipped under standard chain of -custody procedures to a
qualified laboratory for analysis of VOCs by EPA Method TO-15.
2.4 Quality Assurance/Quality Control Samples
Non -dedicated equipment and tools will be decontaminated prior to use at each boring or
sampling location or following exposure to soil. One rinseate blank will be collected during
assessment activities and submitted for analysis of VOCs by EPA Method 8260D and SVOCs by
EPA Method 8270E.
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hart hiekman
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Ms. Reina Clark
October 29, 2019
Page 9
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#C-245 Geology
To evaluate the reproducibility of the sample results, H&H will collect two duplicate soil samples
for analysis of VOCs by EPA Method 8260D and SVOCs by EPA Method 8270E, one duplicate
soil sample for analysis of PCB congeners by EPA Method 1668A, and one duplicate indoor air
sample for analysis of VOCs by EPA Method TO-15. The duplicate samples will be submitted
for the same laboratory analysis as their respective parent samples.
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 (i.e., 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 requested 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.
2.5 Investigation Derived Waste
Investigation derived waste (IDW) generated during the assessment activities will be thin spread
on -Site. However, if significant impacts are suspected (i.e., high PID readings, free -product, etc.)
the soil cuttings will be containerized in 55-gallon drums and staged on -Site pending analytical
11
hart hiekman
SAAAA-Master Projects\Brooks Pierce\Erwin Mill (BRP.001)\Brownfields Assessment Work Plan Addendum\Brownfields Work
Plan Addendum Rev 1 - Erwin Mill (BPN 22058-18-043).doc SMARTER ENVIRONMENTAL 5O W TIONS

Ms. Reina Clark
October 29, 2019
Page 10
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results of composite IDW samples. IDW generated during the proposed assessment activities
will be managed in accordance with DEQ IHSB Guidelines.
3.0 Reporting
Following completion of the additional Brownfields assessment activities, H&H will conduct a
risk assessment for the Site utilizing the latest version of the DEQ Risk Calculator. 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,
laboratory analytical data, a discussion of the data in comparison to regulatory screening levels, a
discussion of the risk assessment, IDW manifests (if applicable), and conclusions and
recommendations concerning our activities.
Please contact me if you have any questions or require additional information.
Sincerely,
Hart & Hickman, PC
p`<0Ax C, MoAily-
Leonard Moretz, PG, RSM
Senior Project Manager
JL N-L
Lisa Nickels, PG
Assistant Project Geologist
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Plan Addendum Rev 1 - Erwin Mill (BPN 22058-18-043).doc
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hart hiekman
SMARTER ENVIRONMENTAL 5OLUTIONS

Table 1 (Page 1 of 1)
Proposed Soil Sampling Locations and Analyses
Erwin Mill
Erwin, North Carolina
H&H Job No. BRP-001
Analyses
Soil Boring ID
Sample Depth
(ft bgs)
Sample Location
Sample Rationale
VOCs
SVOCs
RCRA Metals & Cr6
PCB Congeners
8260D
8270E
6020/7471B/7196A
1668A
SB-40
TBD
finishing building
vertical delineation
1
1
1
SB-41
0 1
finishing building
delineate impacts to north
1
1
1
TBD
TBD
TBD
TBD
SB-42
0 1
finishing building
delineate impacts to east
1
1
1
TBD
TBD
TBD
TBD
SB-43
0 1
finishing building
delineate impacts to south
1
1
1
TBD
TBD
TBD
TBD
SB-44
0 1
finishing building
delineate impacts to west
1
1
1
TBD
TBD
TBD
TBD
SB-45
0-1
former UST basin
delineate impacts to northwest
TBD
TBD
TBD
SB-46
0-1
former UST basin
delineate impacts to southwest
TBD
TBD
TBD
SB-47
0-1
former UST basin
delineate impacts to southeast
TBD
TBD
TBD
HA-4A
3-4
east of winding building
previous Aroclor-1260 detections
1
HA-7A
3-4
southeast of dye house
previous Aroclor-1260 detections
1
HA-9C
3-4
west of fuel oil boiler building
previous Aroclor-1260 detections
1
HA-11 C
3-4
southwest of finishing building
previous Aroclor-1260 detections
1
HA-12A
3-4
west of finishing building
previous Aroclor-1260 detections
1
HA-17A
3-4
east of winding building
previous Aroclor-1260 detections
1
HA-23A
3-4
northwest of finishing building
previous Aroclor-1260 detections
1
DUP-Soil
TBD
TBD
QA/QC
1
1
1
DUP-Soil-PCB
TBD
TBD
QA/QC
1
Rinse Blank
Drill Rods
N/A
QA/QC
1
1
1
Minimum Total Soil Samples
9
9
6
8
Maximum Total Soil Samples
16
16
10
8
Notes:
VOCs = volatile organic compounds; SVOCs = semi -volatile organic compounds; PCB = polychlorinated biphenyls;
TBD = to be determined; UST = underground storage tank; ft bgs = feet below ground surface
QA/QC = quality assurance/quality control; N/A = not applicable; DUP = duplicate
Table 1 (Page 1 of 1)
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Table 2 (Page 1 of 1)
Proposed Indoor Air Sampling Locations and Analyses
Former Erwin Mill Facility
Erwin, North Carolina
H&H Job No. BRP-001
Analyses
Indoor Air
Sample Location
Sample Rationale
VOCs
TO-15
Sample ID
IA-1
finishing building
assess indoor air in the vicinity of sub
1
slab exceedance
IA-2
finishing building
assess indoor air in the vicinity of sub
1
slab exceedance
IA-3
eastern warehouse/offices
assess indoor air in the vicinity of sub
1
slab exceedance
IA-4
former dye house
assess indoor air in the vicinity of sub
1
slab exceedance
IA-5
winding area
assess indoor air in the vicinity of sub
1
slab exceedance
DUP-IA
TBD
QA/QC
1
Total Indoor Air Samples
6
Notes:
VOCs = volatile organic compounds; TBD = to be determined; DUP = duplicate;
QA/QC = quality assurance/quality control; N/A = not applicable;
Table 2 (Page 1 of 1)
S:\AAA-Master Projects\Brooks Pierce\Ervin Mill (BRP.001)\Brownfields Assessment Work Plan Addendum\Tables Hart & Hickman, PC

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ABANDONED/DESTROYED WELL LOCATION
•
SOIL BORING LOCATION
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8
APPROXIMATE
0 200 400
SCALE IN FEET
SAMPLE LOCATION MAP
---- ERWIN MILL FACILITY
200 NORTH 13TH STREET
ERWIN, HARNETT COUNTY, NORTH CAROLINA
hart 1 h i c k m a n Raleigh,
g, N. Ridge Road, Suite 301
Ralei h, North Carolina 27607
. 919-847-4241(p) 919-847-4261(1}
SMARTER ENVIRONMENTAL SOLUTIONS License # C-1269 / #C-245 Geology
DATE: 10-14-19 REVISION NO. 0
JOB NO. BRP-001 FIGURE NO. 3

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PROPOSED SOIL BORING LOCATION - PCB
CONGENERS
PROPOSED "TAR -LIKE" MATERIAL
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PROPOSED INDOOR AIR SAMPLE LOCATION
8
APPROXIMATE
0 200 400
SCALE IN FEET
PROPOSED SAMPLE LOCATION MAP
-_ ERWIN MILL FACILITY
200 NORTH 13TH STREET
ERWIN, HARNETT COUNTY, NORTH CAROLINA
hart 1 h i e k m a n Raleigh,
g, N. Ridge Road, Suite 301
Ralei h, North Carolina 27607
. 919-847-4241(p) 919-847-4261(1}
SMARTER ENVIRONMENTAL SOLUTIONS License # C-1269 / #C-245 Geology
DATE: 10-18-19 REVISION NO. 0
JOB NO. BRP-001 FIGURE NO. 4