06001_Alamac Lumberton_AWP_20240229

NORTH CAROLINA DEQ BROWNFIELDS PROGRAM
WORK PLAN FOR EVALUATION OF A REQUESTED PAUSE
OF THE GROUNDWATER TREATMENT SYSTEM
Alamac American Site
Brownfields No. 06001-02-78
1885 Alamac Road
Lumberton, North Carolina 28358
February 2024
Revision No. 3
Prepared for:
NC Department of Environmental Quality
Division of Waste Management
Brownfields Program
217 West Jones Street
Raleigh, NC 27603
Prepared by:
Verdantas LLC
4 Hemisphere Way
Bedford, Ohio 44146
Prepared on Behalf of:
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Borton Lawson American Engineering, PC NC PE Firm License No. C-4805
Document Number: 15104.0014

February 2024 r verdantas
01
Document Number 15104.0014
TABLE OF CONTENTS
SECTION PAGE
SECTION 1.0 INTRODUCTION..................................................................................................I
SECTION2.0 BACKGROUND...................................................................................................I
SECTION 3.0 SCOPE OF WORK (SOW)...................................................................................3
SECTION 4.0
SAMPLING METHODOLOGY.............................................................................4
4.1
INDOOR AIR SAMPLING...................................................................................4
4.2
SUB -SLAB SOIL VAPOR SAMPLING...................................................................5
4.3
GROUNDWATER GAUGING AND STREAM STAGE MEASUREMENT...............6
4.4
REDEVELOPMENT OF WELLS TO BE SAMPLED.................................................7
4.5
GROUNDWATER SAMPLING............................................................................7
4.6
SURFACE WATER SAMPLING............................................................................8
4.7
SEDIMENT SAMPLING........................................................................................8
SECTION 5.0 LABORATORY ANALYSES...................................................................................8
SECTION 6.0 QUALITY ASSURANCE/QUALITY CONTROL(QA/QC)......................................9
SECTION 7.0 INVESTIGATION DERIVED WASTE (IDW) MANAGEMENT.................................9
SECTION 8.0 RISK EVALUATION...............................................................................................9
TABLES
TABLE 1 Property Summary
TABLE 2 Sampling Summary
TABLE 3 Groundwater Monitoring Wells to be Sampled
FIGURES
FIGURE 1 Site Location Map
FIGURE 2 Proposed Paired Indoor Air/Sub-Slab VAP or Sampling Locations
FIGURE 3 Proposed Groundwater Sampling Locations
FIGURE 4 Proposed Surface Water and Sediment Sampling Locations (Excepting
VSW-6)
FIGURE 5 Location of Proposed Surface Water Sampling Location VSW-6
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February 2024
Document Number 15104.0014
APPENDICES
verdantas
APPENDIX A Diagram of Former Manufacturing Building Showing Leased Areas
APPENDIX B Letter Summarizing November 30, 2022 Sampling of Recovery Wells
APPENDIX C Protocols for PFAS Sampling
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February 2024
Document Number 15104.0014
SECTION 1.0 INTRODUCTION
verdantas
This letter Work Plan Revision No. 3 has been prepared in response to NC DEQ's comments
provided on November 8, 2023, in response to the Work Plan Revision 2 (Verdantas
Document #15104.0014). The property is located at 1885 Alamac Road, Lumberton,
Robeson County, North Carolina (the Subject Property - refer to Figure 1).
SECTION 2.0 BACKGROUND
Phoenix Investors LLC (Phoenix) acquired the 151.79-acre Subject Property, consisting of
Parcel # 101702033 and Parcel # 10170203301, in July 2022. Verdantas reviewed
ownership information maintained by the Robeson County Auditor. Historical Subject
Property ownership is summarized below.
Parcel # 101702033
Date
Grantor
Grantee
5/31/1971
Not provided
West Point-Pepperell Inc.
Not Provided
West Point-Pepperell Inc.
Alamac Knit Fabrics, Inc.
9/28/2001
Alamac Knit Fabrics, Inc.
Alamac Acquisition LLC
9/15/2016
Alamac Acquisition LLC
Alamac Holdings, LLC
3/26/2019
Alamac Holdings, LLC
Lumberton Energy Holdings,
LLC
Parcel # 10170203301
Date
Grantor
Grantee
10/10/1994
Not provided
Alamac Knit Fabrics, Inc.
8/27/1997
Alamac Knit Fabrics, Inc.
Alamac Knit Fabrics Inc.
9/28/2001
Alamac Knit Fabrics Inc.
Alamac Acquisition LLC
9/15/2016
Alamac Acquisition LLC
Alamac Holdings, LLC
3/26/2019
Alamac Holdings, LLC
Lumberton Energy Holdings,
LLC
Table 1 provides a property summary for the subject Property.
Phoenix currently leases a part of the Subject Property to a tenant that occupies only the
western portion of the building. A diagram of the leased area is attached at Appendix
A. Note that the leased area is not within the area that the North Carolina DEQ Brownfield
Program identified in their December 6, 2022, correspondence related to evaluation of
indoor air at the Subject Property.
Tetrachloroethene (PCE) and its daughter products were detected in environmental
media beneath and in the vicinity of a PCE containment pad at the Subject Property in
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February 2024 Verdantas
Document Number 15104.0014
1997. In 1999 and 2000, environmental remedial efforts were conducted under the
direction of S&ME, Inc. (S&ME) to address the contamination, including:
1. removal and disposal of the concrete PCE pad;
2. removal and disposal of underground piping beneath the PCE pad and
between the pad and the manufacturing building;
3. excavation and stockpiling of approximately 582 cubic yards of soil to
depths slightly below the water table [four to five ft. below ground surface
(bgs) in the vicinity of the pad];
4. thermally treating the soil on -site;
5. construction and use of an infiltration gallery to introduce a water -molasses
mixture into contaminated groundwater;
6. installation and operation of three groundwater recovery wells within the
monitored source area (refer to Figure 2);
7. discharge of extracted groundwater to the Subject Property's wastewater
treatment plant (WWTP); and
8. implementation of monitored natural attenuation downgradient of the
monitored source area extending southward to the Jacob Swamp Canal,
where S&ME, through head measurements within monitoring wells near the
canal and heads within the canal, identified a stream recharge boundary,
indicating groundwater north of the canal would not migrate south of the
canal.
Documentation was provided to Verdantas that indicated that S&ME submitted an
injection permit application for direct -push injection of food -grade soybean oil into
groundwater within the Monitored Source Area to enhance biodegradation of PCE and
daughter products.
The groundwater recovery system has operated since November 1999. Between 1999
and June 2004, water was sampled quarterly from the recovery wells, an off -site
production well located at 2237 Alamac Road (designated WSW-1) and selected
monitoring wells. The samples were tested at an analytical laboratory for volatile organic
compounds (VOCs) by U.S. EPA Method 8260B, pursuant to a Water Quality Monitoring
Plan prepared by S&ME and approved by the North Carolina Department of
Environmental and Natural Resources [currently the North Carolina Department of
Environmental Quality (NC DEQ)] on August 16, 1999. Following June 2004, per NC DEQ's
approval, sampling became once per year and testing remained as described above.
On February 24, 2006, Alamac Knits LLC, then owner of the Subject Property, entered into
a Brownfields Agreement with NC DEQ. In September 2008, approval was provided to
sample only the three recovery wells and the off -site production well. The recovery wells
are operating at present.
In February 2022, the NC DEQ sampled surface water from the Jacob Swamp Canal
upstream and downstream of the Subject Property, as well as effluent from the WWTP
outfall, and tested the samples for polyfluoroalkyl substances (PFAS). PFAS compounds
were detected in all samples collected.
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February 2024
Document Number 15104.0014
verdantas
On November 30, 2022, Verdantas collected groundwater samples from recovery wells
RW-1, RW-2 and RW-3 and submitted the samples for analysis of PFAS, VOCs and
inorganic analytes for evaluating alternative treatment options for extracted
groundwater. Sampling and findings are detailed in a December 9 summary letter
(Verdantas Document No. 15104.0016). A copy of that summary letter is attached as
Appendix B.
SECTION 3.0 SCOPE OF WORK (SOW)
Phoenix has asked the Brownfields Program to allow it to pause pumping from the
recovery wells for a period of 90 days. The purpose of this work plan is to provide
information and analysis to assist in:
1. evaluating whether pausing the recovery system for 90 days would result in
an unacceptable increase in risks resulting from potential changes in
movement of groundwater; and
2. evaluating whether pausing the recovery system would affect risks to on -
site commercial/industrial workers from indoor air conditions at the Subject
Property.
Verdantas recommends conducting the following activities to support the risk
evaluations:
Prior to initiating a pause to the system:
a. Perform a Brownfields Property Receptor Survey;
b. Collect and analyze paired sub slab soil vapor and indoor air
samples (SS-1/IA-1A through SS-5/IA-5) in the eastern portion of the
former manufacturing building, adjacent to the Monitored Source
Area as shown on Figure 2 and described on Table 2. Evaluate the
sample results using NC DEQ's Risk Calculator for Non -Residential
Worker Indoor Air (February 2024).
C. Gauge groundwater levels in all accessible monitoring wells located
on the Site to obtain water elevations, as shown on Table 2, locate
production well DW-1 A and document conditions of all the wells.
d. Collect groundwater samples from a subset of the existing
monitoring well network. Groundwater samples will be collected
from monitoring wells RW-1, RW-2, RW-3, MW-4, MW-7, MW-8, MW-12,
MW-13, MW-15, MW-16, MW-17, MW-18, MW-19, MW-20 and MW-21
for laboratory analysis of VOCs in accordance with U.S. EPA Method
8260 and PFAS in accordance with U.S. EPA Method 537.1 Modified.
Samples collected from MW-7, MW-8, MW-19, and MW-20 will also
be tested for nitrate and boron by U.S. EPA Methods 300.1 and 200.7,
respectively. Samples collected from MW-19 and MW-20 will be
analyzed for nitrate and boron to determine potential influences
from septic systems and samples from MW-7 and MW-8 will be
analyzed for nitrate and boron for comparative purposes. Locations
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February 2024
Document Number 15104.0014
verdantas
of the wells to be sampled are shown on Figure 3 and described on
Table 3. Groundwater samples will be collected prior to system
shutdown and 60 days after system shutdown.
e. Collect upstream and downstream surface water samples from
Jacob Swamp Canal, on -Property ponds and on -Property pond
effluent (VSW-1 through VSW-6) for laboratory analysis of VOCs in
accordance with U.S. EPA Method 8260 and PFAS in accordance
with U.S. EPA Method 537.1 Modified. Proposed sampling locations
for surface water locations VSW-1 through VSW-5 are shown on
Figure 4. The proposed sampling location for VSW-6 is shown on
Figure 5.
f. Collect sediment samples from on -Property ponds (VSED-1 through
VSED-3) for laboratory analysis of VOCs in accordance with U.S. EPA
Method 8260 and PFAS in accordance with U.S. EPA Method 537.1
Modified. Proposed sampling locations are shown on Figure 4.
2. Assuming that NC DEQ approves the 90-day pause, at the end of the 90-
day period a complete round of depth to water measurements will be
collected. Paired indoor air samples followed by sub slab soil vapor
sampling (HVP-1 /IA-1 through HVP-5/IA-5) in the eastern portion of the
former manufacturing building, adjacent to the Monitored Source Area
collect and analyzed. Evaluate the sample results using NC DEQ's Risk
Calculator for Non -Residential Worker Indoor Air (February 2024).
SECTION 4.0
4.1 INDOOR AIR SAMPLING
SAMPLING METHODOLOGY
Indoor air samples (IA-1 through IA-5) will be collected within the occupied portions of
the building, biased toward the area of the known groundwater plume. Additionally, an
outdoor ambient air sample (AA-2) will also be collected. The sampling locations are
shown on Figure 2.
At least 24 hours prior to the indoor air sampling activities, a pre -sampling inspection will
be performed to document conditions within the building that could potentially affect
indoor air analytical results. Any materials that could create interferences with sampling
results will be removed from the building and Safety Data Sheets will be provided in an
Appendix to the report.
The owner will communicate with its on -site employees to request that they do not access
the portion of the building to be sampled during the sampling period. The owner will also
maintain typical HVAC operation during the sampling period.
Also prior to sampling, a photoionization detector (PID - equipped with a 11.7 eV bulb)
reading will also be collected prior to sampling from each proposed vapor sample
location.
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February 2024 Verdantas
Document Number 15104.0014
Canisters will be positioned between 3 and 6 feet above the floor within the breathing
zone. Based on the anticipated continued use of the Subject Property for
commercial/industrial purposes, individually laboratory -certified six -liter Summa canisters
for indoor air sampling will be calibrated to fill over an 8-hour sampling period at a flow
rate of approximately 12.5 milliliters per minute. The 8-hour sampling period will replicate
a commercial/industrial worker's exposure. Summa canisters will be placed
approximately 3 to 6 feet above the ground surface to provide representative
concentrations with the commercial/industrial worker breathing zone. The ambient air
sample will also be collected via a Summa canister over an 8-hour period. A final vacuum
reading of at least -5" Hg in each of the canisters will be targeted.
One duplicate indoor air sample will be collected during the sampling period. The
canister for the indoor air duplicate will be set up within two or three lateral feet of the
primary canister.
The laboratory will be requested to report received vacuum for all sampling canisters. If
the sampling canister is evacuated to 0" Hg in the field or if the laboratory notes that the
sampling canister is received at a vacuum of 0" Hg, laboratory analytical results will not
be accepted.
Following completion of the 90-day pause in groundwater extraction, Verdantas will re-
mobilize to the Subject Property to collect additional paired indoor air/soil vapor samples
at the same locations, using the same procedures and presenting the same
documentation described above.
4.2 SUB -SLAB SOIL VAPOR SAMPLING
The proposed locations for paired sub slab soil vapor SS-1 through SS-5 are shown on
Figure 2. After the proposed indoor air samples have been collected, a vapor pin will be
installed at each of the indoor air sampling locations. The vapor pins are proposed to be
installed a minimum of five (5) feet from any walls or cracks in the concrete slab with a
5/8-inch diameter HiltiTM (or equivalent) hammer drill bit to approximately 1-inch below
the concrete slab and a 1 1/2-inch diameter HiltiTM (or equivalent) hammer drill bit to
create a countersink for the placement of a stainless steel flush mount cover. The vapor
pins will then be installed in the pilot holes and following installation, leak testing of the
vapor pin construction will be performed using a helium shroud, helium detector, and
helium tracer gas. Leak testing methodologies will consist of the connection of the vapor
pin to an outlet port on a helium shroud via 1/4-inch or 3/8-inch Teflon® or Teflon® -lined
tubing, the introduction of Grade 5 helium tracer gas via the shroud inlet port, and the
monitoring of the outlet port with a helium detector to ensure helium is not migrating into
the vapor pin. The slab thickness and type of material found under the slab will be
documented for each vapor pin location. At least 30 minutes of stabilization below
capped vapor pins will be required prior to collection of sub slab vapor samples.
In addition to the leak testing of the sub -slab vapor pin to ensure proper construction,
leak testing of the sampling train is proposed to be completed with the helium shroud
apparatus described above. The sampling trains will be leak tested using a helium shroud
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Document Number 15104.0014
to which a Grade 5 helium source will be connected via '/4-inch or 3/8-inch Teflon® or
Teflon® -lined tubing. The sampling train will be connected to the sub -slab vapor pin via
tubing ('/4-inch or 3/8-inch Teflon® or Teflon® -lined tubing), secured with appropriate
fittings and connections to both the Summa Canister (with the valve closed) and to a
tedlar bag equipped with a backflow preventer. Prior to sample collection, purging 3 to
4 system volumes of sub -slab vapor will be completed with a personal air pump at a rate
not to exceed 200 ml/min into a tedlar bag for field screening with a PID meter and a
calibrated helium detector to ensure helium is not entering the sampling train. Detection
of significant amounts of helium during the test will require re -connecting all fittings and
re -testing. A second detection of helium will require replacement of tubing and
connections and possibly re -seating of the vapor pin. Leak testing will be repeated until
no helium is detected.
Based on the anticipated continued use of the Subject Property for commercial/industrial
purposes, individually laboratory -certified six -liter Summa canisters for indoor air sampling
will be calibrated to fill over an 8-hour sampling period at a flow rate of approximately
12.5 milliliters per minute. The 8-hour sampling period will replicate a
commercial/industrial worker's exposure. One duplicate sub slab vapor sample will be
collected during the period of sampling. A three-way valve, or "T" connecter will provide
flow to both the primary and duplicate canisters. A final vacuum reading of at least -5"
Hg in each of the canisters will be targeted.
The laboratory will be requested to report received vacuum for all sampling canisters. If
the sampling canister is evacuated to 0" Hg in the field or if the laboratory notes that the
sampling canister is received at a vacuum of 0" Hg, laboratory analytical results will not
be accepted.
Following sampling, the vapor pins will be secured with sealable caps. Following
completion of the 90-day pause in groundwater extraction, Verdantas will re -mobilize to
the Subject Property to collect additional sub -slab vapor samples at the same locations,
using the same procedures and presenting the same documentation described above.
4.3 GROUNDWATER GAUGING AND STREAM STAGE MEASUREMENT
All accessible groundwater monitoring wells at the Subject Property will be gauged using
an electrical conductivity sonde attached to a graduated tape that will permit
measurement of the well's total depth and the groundwater surface interface to 0.01
inch, using the top of riser for each well as a reference. The condition of the each well
will be documented based on visual observation and/or the presence of obstructions
within the risers. During the gauging event, production well DW-1 A will also be located.
The graduated tape and sonde will be decontaminated by a water/AlconoxTM solution
followed by a distilled water rinse between gauging of each monitoring well.
Stream stage elevations will be measured within the Jacob Swamp Canal at two
locations: near on -site monitoring well MW-12; and near on -site monitoring well MW-13.
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February 2024 Verdantas
Document Number 15104.0014
Tops of risers for the monitoring wells will be used for reference elevations for a survey level
system; a surveyor's rod will be deployed in the surface water.
All monitoring wells and the surface water measurement locations will be located by a
global positioning unit. This will permit the locations to be accurately shown on
Verdantas' base maps.
Groundwater gauging and surface water elevation data will be tabulated and
contoured on the Subject Property base map. Observations on monitoring well
conditions will also be tabulated. Verdantas will evaluate the data and document the
extent to which a stream recharge flow boundary is still present along the southern
property line for the Subject Property.
4.4 REDEVELOPMENT OF WELLS TO BE SAMPLED
All monitoring wells to be sampled (RW-1, RW-2, RW-3, MW-4, MW-7, MW-8, MW-12, MW-
13, MW-15, MW-16, MW-17, MW-18, MW-19, MW-20, and MW-21) will be redeveloped.
Monitoring well redevelopment may be performed using a variety of methods, though a
combination of surging and purging is expected. Redevelopment may be performed
manually with a bailer or surge block or mechanically with a submersible pump. If a
submersible pump is used, the pump will be surged (lowered up and down) within the
well screen while pumping is on -going. A minimum of five well volumes will be removed.
Purged water will be monitored for stability of groundwater indicator parameters
including pH, conductivity, temperature, dissolved oxygen (DO), oxygen/reduction
potential (ORP) and turbidity. Well development will continue until the water quality
parameters have stabilized and the water is visually clear of turbidity or a maximum of 10
well volumes have been removed. If development is implemented using a submersible
pump, the aforementioned groundwater indicator parameters will be collected using a
multi -parameter sonde and flow through cell. If bailers are used during development, the
groundwater indicator parameters will not be collected in a flow through cell.
Extracted groundwater will be containerized in Department of Transportation (DOT)
approved drums, sampled, and characterized, and either disposed within the facility's
water treatment system upon re -activation or sent off -Site to a licensed disposal facility.
4.5 GROUNDWATER SAMPLING
A low -flow sampling pump will be used for sampling the selected monitoring well. Clean
gloves will be worn by each individual handling the sampling equipment. The following
steps will be adhered to during sampling:
1. The pump will not be dropped into the monitoring well, as this may cause
degassing of the water on impact;
2. Groundwater will be transferred from the pump into the proper laboratory
supplied glassware in a manner which will minimize agitation and aeration;
and
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February 2024 Verdantas
Document Number 15104.0014
3. In order to preserve sample quality, the sampling order will be as follows:
volatile organic compounds, non-volatile organic compounds, and in -situ
parameters (e.g., pH, temperature, conductivity, and turbidity).
Additional protocols for sampling PFAS compounds are described in Appendix C. Water
not used for sample make-up will be containerized in a DOT approved drum, sampled,
and characterized, and either disposed within the facility's water treatment system upon
re -activation or sent off -Site to a licensed disposal facility.
4.6 SURFACE WATER SAMPLING
Surface water samples will be collected from banks of surface water bodies shown on
Figure 4 using a decontaminated glass container affixed to a rigid pole. Surface water
samples will be transferred to laboratory -supplied bottles. Clean gloves will be worn by
each individual handling the sampling equipment. Water not used for sample make-up
will be containerized in a DOT approved drum, sampled, and characterized, and either
disposed within the facility's water treatment system upon re -activation or sent off -Site to
a licensed disposal facility.
4.7 SEDIMENT SAMPLING
Sediment samples will be collected from a distance of approximately 4 feet from the
banks of surface water bodies shown on Figure 4 using a decontaminated ponar
sampler. The ponar sampler will be deployed by hand by the Verdantas field personnel.
Sediment samples will be transferred from the ponar sampler to laboratory -supplied
bottles. Clean gloves will be worn by each individual handling the sampling equipment.
SECTION 5.0 LA60RATORY ANALYSES
Summa canister samples of sub slab vapors and indoor air, collected prior to and at the
end of the 90-day pause, will be tested at the ALS Cincinnati, Ohio laboratory for VOCs
in accordance with U.S. EPA Method TO-15 (full analyte list). To the extent feasible,
Method Reporting and Detection Limits will meet all applicable screening levels for
indoor air. Furthermore, ALS will report the vacuum within each summa canister when
received at the laboratory. All J values will be reported by ALS.
Groundwater samples collected prior to and at the end of the 90-day pause, will be
tested at the ALS Cincinnati, Ohio laboratory for VOCs in accordance with U.S. EPA
Method 8260 and PFAS in accordance with U.S. EPA Method 537.1 Modified. Sampled
collected from MW-7, MW-8, MW-19, and MW-20 will also be analyzed for nitrate and
boron for U.S. EPA Methods 300.1 and 200.7, respectively. All J values will be reported by
ALS.
Surface water and sediment samples collected prior to the 90-day pause will be tested
at the ALS Cincinnati, Ohio laboratory for VOCs in accordance with U.S. EPA Method
8260 and PFAS in accordance with U.S. EPA Method 537.1 Modified.
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Document Number 15104.0014
SECTION 6.0 QUALITY ASSURANCE/QUALITY CONTROL (QA/QC)
One duplicate sample will be collected per r per day when collecting indoor air and sub
slab samples. Following sample collection, Summa canisters will be shipped overnight to
ALS laboratory in Cincinnati, Ohio under completed chain -of -custody for log -in and
testing. The ALS laboratory will perform testing under Level II QA/QC protocols.
One duplicate sample will be collected per day during each groundwater sampling
event. A trip blank will accompany all coolers that contain samples for VOC analysis.
Additionally, one field blank and one equipment blank will be collected during each
sampling event. Following sample collection, sample jars will be shipped overnight to ALS
laboratory in Cincinnati, Ohio under completed chain -of -custody for log -in and testing.
The ALS laboratory will perform testing under Level II QA/QC protocols.
One duplicate sample will be collected per 20 surface water samples per day during
each sampling event. A trip blank will accompany all coolers that contain samples for
VOC analysis. Additionally, one field blank and one equipment blank will be collected
during the sampling event. Following sample collection, sample jars will be shipped
overnight to ALS laboratory in Cincinnati, Ohio under completed chain -of -custody for
log -in and testing. The ALS laboratory will perform testing under Level II QA/QC protocols.
A trip blank will accompany all coolers that contain sediment samples for VOC analysis.
Additionally, one field blank and one equipment blank will be collected during the
sediment sampling event. Following sample collection, sample jars will be shipped
overnight to ALS laboratory in Cincinnati, Ohio under completed chain -of -custody for
log -in and testing. The ALS laboratory will perform testing under Level II QA/QC protocols.
SECTION 7.0 INVESTIGATION DERIVED WASTE (IDW) MANAGEMENT
To the extent that IDW is generated, soil cuttings, purged groundwater, and
decontamination water will be drummed and staged on the Subject Property at a
location identified by the Client. Verdantas will segregate soil cuttings and
decontamination water, which are assumed to be classified as non -hazardous, but will
require disposal. Verdantas will arrange for disposal and characterization of this material
(consistent with the NC DEQ's Brownfields Assessment Work Plan Assessment Work Plan
Checklist); however, the Client will be identified as the generator and will be responsible
for signing manifests. Verdantas has included costs for disposal of this material, assuming
that it is classified as non -hazardous.
SECTION 8.0 RISK EVALUATION
Verdantas will perform two risk evaluations as part of this work plan. First, pursuant to
conversations with the Brownfields Program, and based on the collected data and
proposed modeling, it will assess whether pausing the groundwater recovery system for
90-days would pose an unacceptable risk to potable groundwater users south of the
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February 2024 Verdantas
Document Number 15104.0014
Jacob Swamp Canal including the Lumberton River and points east. Second, based on
the findings from the indoor air/soil vapor sampling, it will assess whether pausing the
recovery system affected risks to on -site commercial/industrial workers from indoor air
conditions.
Risk calculations will be generated based on the NC DEQ's Risk Calculator for Non -
Residential Worker Indoor Air (February 2024) and will utilize the maximum concentration
for each compound for each media to generate the most conservative risk. The reporting
limit concentration will be utilized for non -detect compounds.
SECTION 9.0 REPORTING
Upon receiving laboratory analytical reports, Verdantas will transmit them to the DEQ.
Verdantas will prepare an initial summary report that describes groundwater gauging
and the model(s) selected and employed, inputs, simulation results and findings as they
pertain to estimated site conditions over the period of the proposed pause in
groundwater extraction. This summary report will also describe the initial paired sub -slab
vapor/indoor air sampling efforts, groundwater sampling efforts, and findings. Based on
the above, risks will be examined in the context of a pause in groundwater recovery. To
the extent these risks are determined to be acceptable, the report will include a formal
request and schedule for the pause.
At the conclusion of the pause, assuming a pause is completed, a report will be prepared
documenting field efforts and the findings of the second sub -slab vapor/indoor air
sampling event along with an examination of risk as influenced by these findings.
All reporting will be completed under the guidance of a North Carolina Professional
Engineer/Professional Geologist and will be sealed prior to submittal to the agency.
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Document Number 15104.0014
TABLES
verdantas
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NORTH CAROLINA DEQ BROWNFIELDS PROGRAM WORK PLAN FOR EVALUATION OF A REQUESTED PAUSE
OF THE GROUNDWATER TREATMENT SYSTEM
1885 ALAMAC ROAD, LUMBERTON, NORTH CAROLINA
TABLE 1
PROPERTY SUMMARY
Brownfields Project
No.
Parcel No.
Address
Site Acreage
Former/ Current Use
REC
Proposed Use
Monitored Source Area
Textiles
101702033 and
1885 Alamac Road, Lumberton,
(chlorinated volatile
06001 02-78
151.79
Manufacturingpping ou
Commercial/Industrial
10170203301
North Carolina 28358
organic compounds in
sing and Shipping
groundwater)
VERDANTAS LLC
BEDFORD, OHIO
Page 1 of 1
FEBRUARY 2024
15104.0008 Revision No.3

NORTH CAROLINA DEQ BROWNFIELDS PROGRAM WORK PLAN FOR EVALUATION OF A REQUESTED PAUSE
OF THE GROUNDWATER TREATMENT SYSTEM
1885 ALAMAC ROAD, LUMBERTON, NORTH CAROLINA
TABLE 2
SAMPLING SUMMARY
Data Gap
Parcel/Bldg. No.
Sampling Objective
Type of Sample
Number of Samples
Depth of Samples
Analytical Program
Detection range for
TCE
Determine Sub Slab Vapor and
Six Sub Slab Vapor
Several Inches below Slab
Sub Slab Vapor and Indoor Air
101702033/Eastern
Indoor Air Quality and Risk in
Sub Slab Vapor
Samples (including
(depending on slab thickness)
Chemicals of Concern
Portion of Former
of Former Manufacturing
and Indoor
duplicate); Six Indoor Air
for Sub Slab Samples; and
U.S. EPA Method TO-
3
ug/m
Adjacent to Monitored Source
1
ManufacturingPortion
Building Adjacent to Monitored
Air/Outdoor
Samples (includingApproximate
p
Breathing Zone
g
15 full anal to list)1.07
( Y
Area
Building
Source Area
Ambient Air
duplicate); and One
r I
for Indoor Air and Ambient Air
Ambient Air Sample
1 Samples
VERDANTAS LLC FEBRUARY 2024
BEDFORD, OHIO Page 1 of 1 15104.0008 Revision No. 3

NORTH CAROLINA DEQ BROWNFIELDS PROGRAM WORK PLAN FOR EVALUATION OF A REQUESTED PAUSE
OF THE GROUNDWATER TREATMENT SYSTEM
1885 ALAMAC ROAD, LUMBERTON, NORTH CAROLINA
TABLE 3
PROPOSED MONITORING WELLS TO BE SAMPLED
Well ID
Top at asing Elevation
(ft. MSI
Screen Interval
(ft. bgs)
Analyses
RW-1
110.25
10.00 to 20.00
VOCs, U.S. EPA Method 8260
PFAS, U.S. EPA Method 537.1 Modified
RW 2
113.55
10.00 to 20.00
VOCs, U.S. EPA Method 8260
PFAS, U.S. EPA Method 537.1 Modified
RW 3
110.32
10.00 to 20.00
VOCs, U.S. EPA Method 8260
PFAS, U.S. EPA Method 537.1 Modified
MW 4
115.16
8.60 to 18.60
VOCs, U.S. EPA Method 8260PFAS,
U.S. EPA Method 537.1 Modified
MW-7
115.93
5.21 to 20.21
VOCs, U.S. EPA Method 8260
PFAS, U.S. EPA Method 537.1 Modified
Nitrate, U.S. EPA Method 300.1
Boron, U.S. EPA Method 200.7
MW-8
113.86
9.59 to 19.59
VOCs, U.S. EPA Method 8260
PFAS, U.S. EPA Method 537.1 Modified
Nitrate, U.S. EPA Method 300.1
Boron, U.S. EPA Method 200.7
MW-12
113.62
26.00 to 31.00
VOCs, U.S. EPA Method 8260
PFAS, U.S. EPA Method 537.1 Modified
MW-13
116.32
20.50 to 20.50
VOCs, U.S. EPA Method 8260
PFAS, U.S. EPA Method 537.1 Modified
MW-15
113.74
27.50 to 32.50
VOCs, U.S. EPA Method 8260
PFAS, U.S. EPA Method 537.1 Modified
MW-16
114.62
27.50 to 32.50
VOCs, U.S. EPA Method 8260
PFAS, U.S. EPA Method 537.1 Modified
MW-17
113.46
4.00 to 14.00
VOCs, U.S. EPA Method 8260
PFAS, U.S. EPA Method 537.1 Modified
MW-18
112.82
4.00 to 14.00
VOCs, U.S. EPA Method 8260
PFAS, U.S. EPA Method 537.1 Modified
MW-19
109.94
8.00 to 18.00
VOCs, U.S. EPA Method 8260
PFAS, U.S. EPA Method 537.1 Modified
Nitrate, U.S. EPA Method 300.1
Boron, U.S. EPA Method 200.7
MW-20
112.67
11.50 to 21.50
VOCs, U.S. EPA Method 8260
PFAS, U.S. EPA Method 537.1 Modified
Nitrate, U.S. EPA Method 300.1
Boron, U.S. EPA Method 200.7
MW-21
TBD
TBD
I VOCs, PFAS
Note: TBD - To be determined.
VERDANTAS LLC FEBRUARY 2024
BEDFORD, OHIO PAGE 1 OF 1 15104.0009 Revision No. 3

February 2024
Document Number 15104.0014
FIGURES
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1,000 2,000 4'000
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North Carolina exclusive use as a preliminary planning and screening tool and field verification is necessary to confirm
1 Inch =2,000 Feet
these data. This map is reproduced from geospatial information compiled from third -party sources which ^
may change overtime. Areas depicted by the map are approximate and may not be accurate to mapping, Quadrangle: Southwest Lumberton, NC
surveying or engineering standards. Verdantas LLC makes no representation or guarantee as to the
content, accuracy, timeliness or completeness of any information or spatial location depicted on this map.
This map is provided without warranty of any kind, including but not limited to, the implied warranties of
Source: The topographic map was acquired through the USGS
Topographic Map Web Service.
merchantability or fitness for a particular purpose. In no event will Verdantas LLC, its owners, officers,
employees or agents, be liable for damages of any kind arising out of the use of this map by Client or any
other party.
The aerial photo was acquired through the Esri Imagery Web Service.
Aerial photography dated 1/29/2021.
Groundwater Treatment Re -Evaluation Work Plan
Date:
Alamac Road Property
October 2023
Verdantas
Subject Property Location Map
Figure
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1885 ARoad
Lumberton, Robesonn County, North Carolina
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DISCLAIMER
February 2024
Verdantas LLC has furnished this map to the company identified in the title block (Client) for its sole and
Groundwater Treatment Re -Evaluation Work Plan
Figure
exclusive use as a preliminary planning and screening tool and field verification is necessary to confirm
Alamac Road Property
d t
these data. This map is reproduced from eospatial information compile, from third -party sources which
may change over time. Areas depicted by the map are approximate and may not be accurate to mapping,
ve r a n a s
surveying or engineering standards. Verdantas LLC makes no representation or guarantee as to the content,
Proposed Paired Indoor Air/Sub-Slab Vapor
PEOPLE FOCUSED FUTURE
accuracy, timeliness or completeness of any information or spatial location depicted on this map. This map is
provided without warranty of any kind, including but not limited to, the implied warranties of merchantability
Sampling Locations
2
or fitness for a particular purpose. In no event will Verdantas LLC, its owners, officers, employees or agents,
1885 Alamac Road
be liable for damages of any kind arising out of the use of this map by Client or any other party.
Lumberton, Robeson County, North Carolina

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Deep Monitoring Well (20-75 FT BGS) I ter'
AD -Aerial photography dated 1/29/2021.
Shallow Monitoring Well (0-20 FT BGS) DISCLAIMERFebruary ry2024
Y Verdantas LLC has furnished this map to the company identified in the title block (Client) for its sole and Groundwater Treatment Re -Evaluation Work Plan Figure
Property
exclusive use as a preliminary planning and screening tool and field verification is necessary to confirm Alamac Road Pro
Production Well these data. This map is reproduced from geospatial information compiled from third -party sources which p y
may change over time. Areas depicted by the map are approximate and may not be accurate to mapping,
Recovery Well r r ve r d a n t a s surveying or engineering standards. Verdantas LLC makes no representation or guarantee as to the content, Proposed Groundwater
3 r PEOPLE FOCUSED FUTURE accuracy, timeliness or completeness of any information or spatial location depicted on this map. This map is Sampling Locations WSJ
Wells to be Sampled x provided without warranty of any kind, including but not limited to, the implied warranties of merchantability
p w or fitness for a particular purpose. In no event will Verdantas LLC, its owners, officers, employees or agents, 1885 AlamaC Road
be liable for damages of any kind arising out of the use of this map by Client or any other party.
Lumberton, Robeson County, North Carolina

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Aerial photography dated 1/29/2021.
do
DISCLAIMER:
Verdantas LLC has furnished this map to the company identified in the title block (Client) for its sole and
February 2024
Groundwater Treatment Re -Evaluation Work Plan
Figure
exclusive use as a preliminary planning and screening tool and field verification is necessary to confirm
Alamac Road Property
d t
these data. This map is reproduced from ainformation compiled from third -party sources which
may chthe m
ange over time. Areas depicted by the mapp are approximate and may not accurate to mapping,
ve r a n a s
surveying or engineering standards. Verdantas LLC makes no representation or guarantee as to the content,
Proposed Surface Water and Sediment
P E O P L E FOCUSED FUTURE
accuracy, timeliness or completeness of any information or spatial location depicted on this map. This map is
Sampling Locations (Excepting VSW-6)
provided without warranty of any kind, including but not limited to, the implied warranties of merchantability
or fitness for a particular purpose. In no event will Verdantas LLC, its owners, officers, employees or agents,
1885 Alamac Road
be liable for damages of any kind arising out of the use of this map by Client or any other party.
Lumberton, Robeson County, North Carolina

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r
DISCLAIMER: February 2024
Verdantas LLC has furnished this map to the company identified in the title block (Client) for its sole and Groundwater Treatment Re -Evaluation Work Plan Figure
exclusive use as a preliminary planning and screening tool and field verification is necessary to confirm Alamac Road Property
these data. This map is reproduced from geospatial information compiled from third -party sources which may
ve r d a n t a s change over time. Areas depicted er the map are approximate and may not ar accurate to mapping,
surveyingorengineering standards. Verdantas LLC makes no representation or guarantee as map.
content, Location Of Proposed Surface Water
' accuracy, timeliness or completeness of any information or spatial location depicted on this map. This map is Sampling Location USW-6
P E O P L E FOCUSED F U T U R E provided without warranty of any kind, including but not limited to, the implied warranties of merchantability
or fitness for a particular purpose. In no event will Verdantas LLC, its owners, officers, employees or agents,
be liable for damages of any kind arising out of the use of this map by Client or any other party. 1885 Alamac Road
Lumberton, Robeson County, North Carolina

February 2024
Document Number 15104.0014
APPENDIX A
j® verdantas
DIAGRAM OF FORMER MANUFACTURING BUILDING SHOWING LEASED AREAS
4 Hemisphere Way, Bedford, OH 44146 1 verdantas.com

February 2024
Document Number 15104.0014
APPENDIX B
verdantas
LETTER SUMMARIZING NOVEMBER 30, 2022, SAMPLING OF RECOVERY WELLS
4 Hemisphere Way, Bedford, OH 44146 1 verdantas.com

February 2024
Document Number 15104.0014
APPENDIX C
PROTOCOLS FOR PFAS SAMPLING
j® verdantas
4 Hemisphere Way, Bedford, OH 44146 1 verdantas.com