22058_Erwin Mill_EPALrePCB_20210325

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March 25, 2021
Mr. Howard F. Auman, Jr.
Manager
Erwin Plant, LLC
200 North 13th Street, Suite 3-A
Erwin, North Carolina 28339
Re: Approval of Polychlorinated Biphenyl (PCB) Cleanup Plan
Erwin Mill, Erwin, North Carolina
Pursuant to 40 CFR § 761.61(a)
Dear Mr. Auman:
Thank you for submitting the February 22, 2021 Self -Implementing PCB Cleanup Notification (2021
PCN) for the property at 200 North 13' Street, Erwin, North Carolina (the Site) to the U. S.
Environmental Protection Agency. The 2021 PCN was submitted on behalf of Erwin Plant, LLC (Site
Owner) by Mr. Leonard Moretz, P.G. and Ms. Lisa Nickels, P.G., Hart & Hickman, PC (H&H), to clean
up polychlorinated biphenyls (PCBs) detected in on -Site soils and concrete pursuant to the federal PCB
regulations promulgated at 40 Code of Federal Regulations (CFR) § 761.61(a).
Site Background
The Site is comprised of one approximately 55.25-acre parcel in Erwin, Harnett County, North Carolina
that currently includes several warehouses, office buildings, a reservoir and multiple parking areas. The
Site was utilized as a textile manufacturing facility starting in 1904, primarily focusing on the
production of denim. In 1962, Burlington Industries purchased the Site and continued the textile
manufacturing operations. In 1987, Burlington Industries and Swift Textiles, Inc. merged and continued
similar operations until 2000, when the current Site Owner (formerly Schwarz Auman Properties, LLC)
purchased the Site. The Site has been predominantly vacant since 2000; however, some of the on -Site
buildings have been leased to various tenants, including a rifle and ammunition assembly business, a
cabinet making business other small businesses.
A total of 35 concrete pad -mounted transformers were situated at multiple locations across the Site.
PCBs were used in 16 of the 35 transformers. These 16 transformers were PCB transformers in that they
contained PCB concentrations greater than 500 mg/kg. In approximately 2009, six of the 16 PCB
transformers were removed from the Site for disposal by the Site owner. During a November 2019
inspection by the EPA to determine Erwin Plant's compliance with the PCB regulations, the EPA

inspector observed the presence of 10 PCB transformers remaining on -Site that appeared to have been
removed from service. On December 12, 2019, the EPA issued a Notice of Opportunity to Show Cause
letter to the Site Owner detailing potential violations of Section 15 of the Toxic Substances Control Act
(TSCA), 15 U.S.C. § 2614, and the PCB regulations (Enclosure 1) pertaining to requirements for storage
and disposal of PCB transformers. In March and April 2020, the Site Owner had the remaining 10 PCB
transformers removed from the Site for disposal. The approximate boundaries of the Site, the Site
features and the approximate locations of the removed 35 transformers are depicted on the enclosed
Figure 2 of the 2021 PCN (Enclosure 2). The origin of the PCBs detected in the on -Site soils in the
locations around the former locations of PCB transformers, and in the concrete PCB transformer pads
appears to have been derived from leaks and/or spills from the PCB transformers.
The Site Owner is currently working with the North Carolina Department of Environmental Quality
(NCDEQ) Brownfields Program in order to clean up and ultimately be in a position to sell the Site. The
Site Owner was approved by the NCDEQ on November 15, 2018 under a "Ready for Reuse"
Brownfields Agreement where the Site Owner would act as a proxy for a future prospective developer
and would conduct additional environmental assessments and cleanup activities prior to selling the Site.
It is the EPA's understanding that the identity of any prospective developer or the specifics of the
planned redevelopment of the Site are not currently known.
2001, 2019 and 2020 Environmental Site Investigations
During a 2001 Phase II Environmental Site Assessment (ESA) conducted by Engineering Consulting
Services, LTD on behalf of the Site Owner, PCBs were detected in 11 of the 12 soil samples collected
adjacent to all exterior concrete PCB transformer pads from a depth of four feet below ground surface
(bgs) as high as 23 milligrams per kilogram (mg/kg). PCBs were also detected as high as 78 micrograms
per 10 square centimeters (µg/10 cm2) from wipe samples collected from concrete flooring adjacent to
the two interior PCB transformers.
As part of the NCDEQ "Ready for Reuse" Brownfields Agreement, additional assessment sampling
activities were conducted by H&H on behalf of the Site Owner in July and November of 2019. PCBs
were detected in all 10 soil samples collected adjacent to 10 of the 12 exterior concrete PCB transformer
pads from a depth between 3 — 4 feet bgs as high as 677 mg/kg. Samples were not collected adjacent to
the two exterior transformer pads where PCB concentrations were reported below the laboratory Method
Detection Limits (MDL) during the 2001 ESA.
In 2020, the EPA requested that additional Site assessment be conducted to address data gaps observed
in the 2019 sampling results. Based on the EPA's request and subsequent meetings between
representatives of Erwin Plant LLC, the EPA and NCDEQ, H&H on behalf of the Site Owner conducted
additional sampling at the Site in November 2020 to fully characterize and delineate PCB contamination
in preparation for PCB cleanup activities. Soil, concrete, a "tar -like" material, groundwater, surface
water and sediment samples were collected as part of the November 2020 sampling activities. The
following sampling results were reported in the 2021 PCN:
• Soils: A total of 16 soil samples were collected in the area of all current and former exterior
concrete PCB transformer pads. Samples were collected from depths ranging from 0 — 6 feet bgs.
PCBs were detected in 11 of the soil samples above 1 mg/kg as high as 160 mg/kg. One soil

sample was also collected from a sub -terrain concrete corridor located north of the reservoir
between the dye house and the warping area from 0.0 — 0.5 feet bgs at 3.8 mg/kg;
Concrete: A total of nine concrete samples were collected from the center of seven of the ten
remaining exterior concrete PCB transformer pads (seven samples), a sub -terrain concrete
corridor (one sample) and the cotton blending building concrete slab (one sample). PCBs were
detected in the concrete samples from the PCB transformer pads as high as 35,000 mg/kg.
Analytical results indicated that PCBs were not present in the sub -terrain concrete corridor or the
cotton blending building concrete pad samples above the laboratory MDL;
• "Tar -like" Material: One sample was collected from the "tar -like" material observed at various
locations atop the cotton blending building slab. Analytical results indicated that PCBs were not
present in the "tar -like" material sample above the laboratory Method Detection Limits (MDL);
Surface Water and Sediment: A total of five co -located surface water and sediment samples were
collected on -Site from the reservoir (one sample), an area labeled as "potential wetland" in the
2021 PCN (one sample) and an unnamed tributary to Juniper Creek (three samples). Analytical
results indicated that PCBs were not present in the surface water samples above the laboratory
MDL; however, PCBs were detected in one sediment sample collected from the potential
wetland area at 0.23 mk/kg; and
Groundwater: A total of four groundwater samples were collected from two wells downgradient
and one well upgradient of the removed PCB transformers and one well near the mid -point of the
Site. Analytical results indicated that PCBs were not present in the groundwater samples above
the laboratory MDL.
The November 2020 sampling locations are depicted on the enclosed Figure 3 of the 2021 PCN
(Enclosure 3).
Summary of Proposed Work
The 2021 PCN proposes the following work at the Site to address PCB contamination:
Demolition and off -site disposal of all remaining concrete PCB transformer pads and the sub -
terrain concrete corridor. To determine the appropriate disposal destination, concrete samples
will be collected from the PCB transformer pads not previously sampled where PCBs were
detected in adjacent soil between 1 mg/kg and 50 mg/kg. The concrete PCB transformer pads
where PCBs were previously detected in adjacent soil greater than 50 mg/kg will not be sampled
as it is presumed the concrete is also impacted at concentrations greater than 50 mg/kg and will
be disposed of accordingly, as noted below;
Additional site characterization to fully delineate the PCB contaminated soil to 1 mg/kg
vertically and horizontally. Delineation will be conducted using the immunoassay field screening
technique on a 5 foot by 5-foot grid pattern extending outwards from known areas of PCB
contamination;

Excavation and off -site disposal of all soil and concrete with PCB concentrations greater than
1 mg/kg. The immunoassay field screening technique will also be used in conjunction with soil
excavation to determine the extent of the areas to excavate. Per Section 3.8 of the 2021 PCN, if
PCBs remain on -site at concentrations greater than NCDEQ's residential Preliminary Soil
Remediation Goals (0.24 mg/kg) but below 1 mg/kg, Land Use Restrictions may be required by
the NCDEQ;
Collection of verification samples following the cleanup to confirm that the PCB cleanup levels
(1 mg/kg) are met; and
• Disposal of all excavated soil and concrete at a TSCA-approved landfill where PCB
concentrations are >_ 50 mg/kg or at a Subtitle D landfill where PCB concentrations are < 50
mg/kg.
The proposed PCB cleanup areas are depicted in Figure 7 of the 2021 PCN (Enclosure 4).
Approved Work and Conditions
The EPA finds that the proposed work described in the 2021 PCN, if performed in accordance with the
plan and the conditions set forth in this Approval, will not pose an unreasonable risk of injury to health
or the environment; therefore, the EPA hereby approves the 2021 PCN pursuant to 40 CFR
§ 761.61(a). The Site Owner and/or its representatives may proceed to implement the work proposed in
the 2021 PCN, subject to the following conditions:
1. This Approval applies to the work to be conducted at the Site, described in the 2021 PCN as 200
North 13th Street, Erwin, North Carolina. The approximate boundaries of the Site are depicted on
the enclosed Figure 2 of the 2021 PCN (Enclosure 2).
2. This Approval does not: 1) waive or compromise the EPA's enforcement and regulatory
authority; 2) release the Site Owner from compliance with any applicable requirements of
federal, state or local law; or, 3) release the Site Owner from liability for, or otherwise resolve
any violations of federal, state or local law, except as may otherwise be resolved through the
EPA's issuance of a Consent Agreement and Final Order pertaining to any alleged violations of
the PCB regulations.
3. Any proposed modification(s) to the 2021 PCN, specifications, or information in the 2021 PCN,
including, but not limited to, its Appendices, must be submitted to the EPA Project Manager
listed in Condition #11 no less than 14 calendar days prior to the proposed implementation of the
changes. The review and approval procedures of 40 CFR § 761.61(a)(3)(ii) will apply.
4. This Approval applies only to the remediation of PCBs and does not supersede any other
Federal, State or Local laws and regulations which have jurisdiction over the management and
disposal of other contaminants with regard to any other prevailing regulations or statutes
applicable to such contaminants.
5. As specified in the 2021 PCN, for all PCB sampling conducted at the Site as required by this
Approval, the laboratory shall use gas chromatography for chemical analysis of PCBs and shall
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follow sampling procedures as outlined in the USEPA SW-846 Method 8082 in order to obtain
representative samples. The approved SW-846 extraction methods are either 3540 C (Soxhlet) or
3550B (ultrasonic). The EPA prefers the use of SW-846 Method 3540C due to the poor sample
extraction efficiency of Method 3550.
6. All PCB waste (regardless of concentration) generated as a result of the activities described in
the 2021 PCN, excluding any decontaminated materials, shall be marked in accordance with 40
CFR § 761.40; stored in a manner prescribed in 40 CFR § 761.65; and disposed of in accordance
with 40 CFR §§ 761.61(a)(5) or 761.62, if applicable, unless otherwise specified below:
a) Decontamination waste and residues shall be managed in accordance with the requirements
of 40 CFR § 761.79(g);
b) Moveable equipment, tools and sampling equipment shall be decontaminated in accordance
with either 40 CFR §§761.79(b)(3)(i)(A), 761.79(b)(3)(ii)(A) or 761.79(c)(2); and
c) PCB -contaminated water generated during decontamination or dewatering shall be
decontaminated in accordance with 40 CFR § 761.79(b)(1) or disposed of under 40 CFR
§ 761.60.
7. This Approval may be suspended or revoked by the EPA at any time when it has reason to
believe that conditions at the Site present an unreasonable risk to health or the environment.
8. The Site Owner shall comply with the record keeping requirements specified at 40 CFR
§ 761.61(a)(9) for activities conducted in accordance with this Approval.
9. The Site Owner shall submit a final report to the EPA within 60 days of completion of the
activities authorized under this Approval. At a minimum, this final report shall include, but not
be limited to: a short narrative of the remedial activities; characterization and confirmation
sampling analytical results, if applicable; copies of the accompanying analytical chains of
custody; field and laboratory quality control/quality assurance checks; copies of manifests; and
copies of certificates of disposal or similar certifications issued by the disposer.
10. Any future reports and documents submitted to the EPA shall contain the certification defined in
40 CFR § 761.3.
11. Required submittals should be emailed to the EPA Project Manager, Peter Johnson, and the EPA
Region 4 PCB Program Coordinator, Terri Crosby -Vega, at the email addresses specified below.
For your consideration is the EPA Principles for Greener Cleanups (Principles), August 27, 2009,
http://www.epa.gov/greenerclegpups/epa-principles-ueener-cleanups. The EPA's Principles provide a
foundation for planning and implementing cleanups which reduce the environmental footprint of
cleanup activities. The Agency recognizes that the process of cleaning up a contaminated site uses
energy, water and other natural or processed material resources and consequently creates an
environmental footprint of its own. The EPA's Principles outline the Agency's policy for considering
the footprint.
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If there are any questions about this Approval, please contact Peter Johnson at [phone] or
[e-mail] or Terri Crosby -Vega at [phone] or [e-mail].
Sincerely,
William C. Denman, P.E.
Chief, Redevelopment and Chemicals Branch
Land, Chemicals and Redevelopment Division
Enclosures
cc: Leonard Moretz, P.G., Hart & Hickman, PC
Lisa Nickels, P.G., Hart & Hickman, PC
Jeff Smith, Lynn, Smith & Webb, PLLC
Joey Ponzi, Brooks Pierce, LLP
Charles Ivey, Ivey, McClellan, Gatton & Siegmond, LLP
Kathleen Markey, NCDEQ Brownfields Program
Sharon Eckard, NCDEQ Brownfields Program
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