13008_Pilot Mountain_Addl Assmt_20090902

North Carolina Department of Environment and Natural Resources
401 Oberlin Road, Suite 150, Raleigh, North Carolina 27605
1646 Mail Service Center, Raleigh, North Carolina 27699-1646
Phone: [phone] \ FAX: [phone] \ Internet: www.wastenotnc.org
An Equal Opportunity / Affirmative Action Employer - 50 % Recycled \ 10 % Post Consumer Paper

September 2, 2009

Sent Via E-mail and USPS

Blair Knox, MPA
Town of Pilot Mountain
124 West Main Street
Box 1
Pilot Mountain, NC 27041
[e-mail]

Subject: Additional Assessment Requirements
Former Amos & Smith Hosiery Mill
612 East Main Street
Pilot Mountain, Surry County
Brownfields Project Number 13008-09-86

Dear Mr. Knox:

On June 4, 2009, the North Carolina Department of Environment and Natural Resources
(DENR) determined that the project proposed by the Town of Pilot Mountain to redevelop the
former Amos & Smith Hosiery Mill as the Pilot Center, a Surry County college campus and
agricultural center, was eligible for entry into the North Carolina Brownfields Program. As
outlined in the eligibility letter, the next step is to conduct additional assessment to determine
how the site can be made safe for its intended use as a college campus. DENR has reviewed the
currently available site information for the above-referenced site and data gaps have been
identified. Additional information and assessment activities, as outlined below, are required to
assist in making risk management decisions for preparation of the Brownfields Agreement
(BFA).

The Brownfields Application includes a technical environmental report on the subject
property, Phase I Environmental Site Assessment (Withers & Ravenel, Inc., March 23, 2009),
which includes attachments documenting the closure of a 20,000 gallon fuel oil underground
storage tank (UST) at the subject site in 1991, associated soil excavation, and the installation and
sampling of three groundwater monitoring wells at the property. On April 11, 1997, the NC
Department of Environment, Health & Natural Resources, Division of Water Quality,
Groundwater Section issued a determination that this UST was closed in accordance with NCAC
Title 15A Subchapter 2N.

Dexter Matthews, Director Division of Waste Management Beverly Eaves Perdue, Governor
Dee Freeman, Secretary

Mr. Blair Knox
September 2, 2009

2

A careful review of available data indicates that soil contamination associated with the
boiler building in the southwestern portion of the site remains below the building foundation. In
addition, the practical quantification limits (PQLs) for several volatile organic compounds
analyzed for in the groundwater samples are higher than several current NCAC Title 15A
Subchapter 2L water quality standards. Therefore, past groundwater results that indicated non-
detectable concentrations may in fact have had constituents in excess of current standards but
below the PQLs. Also, several potential RECs have not been assessed to date.

As part of Brownfield assessment activities, we request that the PD conduct further
assessment at the site to determine that the site is or can be made safe for its intended reuse.

Assessment

1. Please submit, for DENR review and approval, a sampling plan to address the potential
impact to environmental media from the potential sources identified in the Phase I Report,
including the historic dye house area, trench drains, former boiler room, former equipment repair
area, coal stockpile, and heating oil ASTs at the former residences. Site groundwater should also
be sampled. If their integrity has not been compromised, existing groundwater wells may be
used in the sampling; in lieu of this approach, groundwater samples may be collected with direct
push technology. Include a table in the assessment work plan that summarizes the sampling
objectives of each sample point based on known or suspected historic usage in that particular
area (e.g, dye house trench, coal stockpile), and the proposed analytical program. The data
generated will be used to determine if environmental media such as soil, groundwater, soil vapor,
and potentially indoor air, have been impacted with contaminants of concern above levels that
would make it unsafe for its proposed reuse as a college campus.

2. Due to the potential presence of volatile organic compounds (VOCs) in soil and
groundwater at the property, it may be necessary to evaluate the indoor air vapor intrusion
pathway based on site data collected during the assessment. Include a contingency plan for the
evaluation of the indoor air vapor intrusion pathway from subsurface sources such as
groundwater and soil contaminated with volatile organic compounds, if these are found or
suspected to be present at the site below existing buildings or the footprints of proposed new
construction. Guidelines for evaluating the indoor air vapor intrusion pathway are attached.

3. Assessment activities should follow the most recent Inactive Hazardous Sites Program
Guidelines for Assessment and Cleanup
http://www.wastenotnc.org/sfhome/stateleadguidance.pdf), which is based on EPA's Region 4
Field Branches Quality System and Technical Procedures document (a .pdf version is available
on EPA’s web site at http://www.epa.gov/region4/sesd/fbqstp/.

Laboratory Analyses

4. Environmental samples must be submitted to a NC-certified laboratory for analysis using
EPA SW-846 or Standard Methods. Choose the methods that detect the potential constituents of
concern, and have detection limits below applicable standards. We anticipate analysis of VOCs,
Mr. Blair Knox
September 2, 2009

3

including chlorinated VOCs, semi-volatile organics, and Hazardous Substance List metals of the
soil and groundwater samples. However, if there is reason to believe that other constituents of
concern that are not on these parameter lists may be present at the site, also include analyses for
these constituents. Areas suspected of containing petroleum contamination shall be assessed in
accordance with the current NC DENR UST Section guidance provided in documents found
online at http://www.wastenotnc.org/ust/Guidance.html. Analytical results submitted must
include the complete laboratory reports and associated Level II QA/QC information.

Report and Figures

5. Submit an assessment report with a description of field activities, tabulated data
summaries, laboratory data packet, and information as requested above. The report should
include a map that is an accurate survey of the site indicating well locations, estimated locations
of any previous samples and current site structures. Provide concentration map(s) for
contaminants detected above applicable standards for soil and groundwater. These standards are
used for comparison in BFA tables, and are not to be considered remediation goals. Remediation
goals are determined on a site-specific basis.

Receptor Survey

6. Fundamental to the safe reuse of brownfields properties is the identification and
evaluation of site contamination and associated risks, and of the various pathways of possible
exposure to those contaminants. This evaluation must include the results of a thorough receptor
survey at and in the vicinity of the site. Receptors in this sense include not only wells that supply
people with groundwater for drinking, cooking, bathing and so forth, but also other avenues,
such as basements, utility access ways, storm sewers, other underground utilities, drains, and
surface water flows and seeps, whereby contaminated groundwater or soil or volatiles from
contaminated ground water or soil, can reach people. Based on preliminary redevelopment plans
identify all potential receptors and exposure pathways.

Other

7. Because risk management decisions may vary depending on the nature of the
redevelopment, it will be important that DENR review the locations of the various elements of
your plans in conjunction with the assessment work plan. Please forward any maps or drawings,
as well as grading plans, you may presently have indicating these details, even if only
preliminary or conceptual.

8. As we mentioned in our Letter of Eligibility, we understand the Town of Pilot Mountain
executed an option to contract on the subject property on January 31, 2009, with a planned
closing date of April 9, 2009. Please confirm that the Town of Pilot Mountain actually
purchased the property, and if not, keep us apprised throughout the process of your plans
regarding purchase of the property. If the Prospective Developer does not actually purchase the
property for redevelopment, it may lose eligibility for the Brownfields Program.
Mr. Blair Knox
September 2, 2009

4

I am optimistic that this phase of assessment can substantially close these data gaps so we
can reasonably determine the risk that this site may pose to receptors. We look forward to
working with you to advance this project. If you have any questions regarding this letter or the
brownfields process, please feel free to contact me at 919.508.8425 or by
e-mail at [e-mail].

Sincerely,

Sharon Poissant Eckard, PG
Brownfields Project Manager
Division of Waste Management

cc: Project File
ec: Bruce Nicholson, DENR

Attachment: BFP Vapor Sampling & Analysis Guide August 2009

.