Loading...
HomeMy WebLinkAbout19049_Regal_Mfg_Phase II_ESA_20100601Brownfield Phase II Site Assessment Report Former Regal Manufacturing 212 12th Avenue NE Hickory, North Carolina H&H Job No. HIC-001 June 1, 2010 2923 South Tryon Street Suite 100 Charlotte, NC 28203 704-586-0007 3334 Hillsborough Street Raleigh, NC 27607 919-847-4241 #C-1269 Engineering #C-245 Geology S:\AAA-Master Projects\Hickory HIC\HIC-001 Brownfield Assessment\Sites\Phase IIs\Regal\Report\Regal.doc Hart & Hickman, PC i Brownfield Phase II Site Assessment Activities Former Regal Manufacturing 212 12th Avenue NE Hickory, North Carolina H&H Job No. HIC-001 June 1, 2010 Table of Contents Section Page No. 1.0 Introduction and Background .................................................................................................... 1 1.1 Current Site Use ................................................................................................................... 1 1.2 Former Site Use .................................................................................................................... 1 1.3 Brownfield Phase I Environmental Site Assessment .......................................................... 2 2.0 Sampling Activities ....................................................................................................................... 5 2.1 General Field Practices ......................................................................................................... 5 2.2 Soil Sampling ....................................................................................................................... 6 2.3 Monitoring Well Installation and Sampling ........................................................................ 9 2.4 QA/QC Samples ................................................................................................................. 10 3.0 Results of Assessment ................................................................................................................ 11 3.1 Soil Results ......................................................................................................................... 11 3.2 Ground Water Results ........................................................................................................ 13 3.3 Ground Water Data Screening ........................................................................................... 14 3.4 Receptor Survey ................................................................................................................. 16 4.0 Data Review, Verification and Validation ............................................................................... 18 5.0 Conclusions ................................................................................................................................. 24 S:\AAA-Master Projects\Hickory HIC\HIC-001 Brownfield Assessment\Sites\Phase IIs\Regal\Report\Regal.doc Hart & Hickman, PC ii List of Tables Table 1 Summary of Ground Water Level Data Table 2 Summary of Soil Analytical Data Table 3 Summary of Ground Water Field Parameters Table 4 Summary of Ground Water Analytical Data Table 5 Comparison of Selected Groundwater Analytical Results with Vapor Intrusion Screening Levels List of Figures Figure 1 Site Location Map Figure 2 Site Plan and Sample Locations Map Figure 3 Soil Analytical Results Map Figure 4 Ground Water Potentiometric Map Figure 5 Ground Water Analytical Results Map Figure 6 Water Supply Well Survey Map List of Appendices Appendix A Historical Documents Appendix B Laboratory Analytical Data Appendix C Waste Disposal Manifests Appendix D Boring Logs and Well Construction Records Appendix E Johnson & Ettinger Model - Ground Water Screening Results Appendix F NC Brownfields Area Reconnaissance and Receptor Guidance Form S:\AAA-Master Projects\Hickory HIC\HIC-001 Brownfield Assessment\Sites\Phase IIs\Regal\Report\Regal.doc Hart & Hickman, PC 1 Brownfield Phase II Site Assessment Activities Former Regal Manufacturing 212 12th Avenue NE Hickory, North Carolina H&H Job No. HIC-001 1.0 Introduction and Background Hart & Hickman, PC (H&H) has completed Brownfield site assessment activities at the Former Regal Manufacturing located at 212 12th Avenue NE in Hickory in Hickory, Catawba County, North Carolina (Figure 1). The subject Brownfield site assessment was performed for the City of Hickory under United States Environmental Protection Agency (EPA) Assessment Cooperative Agreement Number 96489707. This report presents findings of assessment activities conducted in accordance with the EPA approved Quality Assurance Project Plan (QAPP) dated October 19, 2009. 1.1 Current Site Use The subject site is located at 212 12th Avenue NE in Hickory, North Carolina (Figure 2). The property is comprised of four parcels totaling approximately 2.64 acres. Three parcels (2.03 acres) are located between 12th Avenue NE and 11th Avenue NE and they are occupied by the former manufacturing area. One parcel contains an approximate 47,000 sq ft vacant building, one parcel contains an asphalt-paved parking area, and one parcel contains an approximate 2,000 sq ft vacant building. The fourth parcel is located south of 11th Avenue NE (306 11th Avenue NE) and it contains an asphalt-paved parking area surrounded by a fence (Figures 1 and 2). 1.2 Former Site Use The subject site was first developed as a hosiery mill in 1956 and was then comprised of the two westernmost buildings (former machine shop and former cotton yarn manufacturing buildings), which are now incorporated into the current manufacturing building (Figure 2). The larger eastern building (former elastic yarn manufacturing warehouse) was added by Regal sometime in the 1960s or early 1970s (Figure 2). The former air compressor building has been present since S:\AAA-Master Projects\Hickory HIC\HIC-001 Brownfield Assessment\Sites\Phase IIs\Regal\Report\Regal.doc Hart & Hickman, PC 2 at least 1961, and it was formerly operated as an automotive repair facility in the 1960s. Various textile companies occupied the manufacturing buildings between the 1950s and 1960s. The companies included the Reaco Hosiery Mills, Madaris Hosiery Mill, The Elastic Corporation, and Realspan Corporation before becoming Regal Manufacturing in the 1960s. Regal used the facility to manufacture hosiery and cover elastic until 1999. The site buildings have been vacant since 1999. 1.3 Brownfield Phase I Environmental Site Assessment GaiaTech, Inc. (GaiaTech) completed a Phase I Environmental Site Assessment (ESA), a focused Phase II Investigation, and a Limited Phase II Site Assessment at the site in November 2001, January 2002, and June 2007, respectively. Copies of pertinent portions of the historical assessment documents are provided in Appendix A. H&H interviewed Regal personnel and conducted a site visit on July 17, 2009 to verify the results of the 2001 Phase I ESA and determine if site conditions had changed since the Phase I ESA preparation. Based on the interviews and site visit, site conditions were judged to be similar to those observed during the 2001 Phase I ESA. The results of historical site assessments, and on- and off-site concerns judged by H&H to potentially impact soil and/or ground water at the subject site are discussed below. • The 2001 Phase I ESA indicated that a former gasoline underground storage tank (UST) was reportedly removed from the western side of the property in the late 1980s. No closure documentation is available for the removal activities. To assess site impacts from the former UST, GaiaTech collected four soil samples in the vicinity of the former UST during the January 2002 focused Phase II Investigation. Soil samples were analyzed for gasoline range total petroleum hydrocarbons (TPH- GRO), volatile organic compounds (VOCs), and lead (no ground water samples were collected). No VOCs or TPH-GRO concentrations were detected in soil samples above the laboratory detection limits, and lead was detected at concentrations within the EPA S:\AAA-Master Projects\Hickory HIC\HIC-001 Brownfield Assessment\Sites\Phase IIs\Regal\Report\Regal.doc Hart & Hickman, PC 3 published background concentration range. Based on the results of GaiaTech’s soil sampling, the potential for site impacts from the gasoline UST is judged to be low; therefore, no soil sampling was conducted by H&H in the vicinity of the former gasoline UST. • The 2001 Phase I ESA identified two adjacent service stations (Servco and Viewmont Exxon) to the west and a former furniture manufacturer (Dunmore Furniture) to the north as potential off-site sources of site impacts. Reports reviewed by H&H indicated that petroleum hydrocarbons, tetrachloroethene (PCE), trichloroethene (TCE) and lead concentrations in ground water have historically been detected above the ground water standards at the adjacent Servco facility. Importantly, substantial PCE and TCE impacts were detected in monitoring wells in the northeastern portion of the Servco property south of the Regal former yarn manufacturing building. Additionally, TCE and PCE concentrations also were detected above the ground water standards in a ground water monitoring well located at the Dunmore Furniture property (Figure 2) in March 2006. • To assess site impacts from potential off-site sources, GaiaTech collected eight soil samples and seven ground water samples at the site as part of the Limited Phase II Site Assessment activities in 2007. No soil impacts were detected in the soil samples. Ground water analytical results indicated PCE concentrations as high as 280 µg/l and TCE concentrations as high as 58 µg/l in the southwestern corner of the property (near the Servco property boundary). No ground water impacts were detected in the ground water samples collected along the northern, western, and eastern property boundaries. The ground water flow direction at the site was determined to be toward the south- southwest. • The 2001 Phase I ESA identified a hydraulic lift located near the northwestern corner of the building. No soil impacts were identified in soil samples collected adjacent to the hydraulic lift during the Limited Phase II Site Assessment activities discussed S:\AAA-Master Projects\Hickory HIC\HIC-001 Brownfield Assessment\Sites\Phase IIs\Regal\Report\Regal.doc Hart & Hickman, PC 4 above; therefore, the potential for site impacts from the hydraulic lift is judged to be low and no soil sampling was conducted near the hydraulic lift. • The historical use of the site as hosiery mill likely included the use of chlorinated solvents, dyes, and oils and grease for machinery lubrication. Staining was only identified on concrete flooring in the former air compressor building. The potential for historical operations to impact the subject site is judged to be moderate to high. S:\AAA-Master Projects\Hickory HIC\HIC-001 Brownfield Assessment\Sites\Phase IIs\Regal\Report\Regal.doc Hart & Hickman, PC 5 2.0 Sampling Activities 2.1 General Field Practices H&H conducted sampling activities at the site on January 19 and 22, 2010, and March 4, 2010. Soil and ground water samples were collected for laboratory analysis. Field activities consisted of the following: • Completion of nine soil borings using either direct push technology (DPT) methods. • Collection of 13 soil samples for laboratory analysis from the above soil borings. • Installation of three temporary monitoring wells using DPT methods. • Collection of ground water samples for laboratory analysis from the above three temporary monitoring wells and from four existing on-site permanent monitoring wells. The approximate locations of soil borings and monitoring wells installed by H&H are depicted on Figure 2. Prism Laboratories, Inc. (Prism) served as the lead subcontract laboratory and performed most laboratory analyses of soil and ground water samples for the project. A chain-of-custody record was completed for samples collected and included the sample designation, date collected, time collected, matrix, sample container information, and requested analyses. The completed chain- of-custody record was signed by H&H sampling personnel prior to placement in an iced cooler for hand delivery to the analytical laboratory. Laboratory analytical data reports and chain-of- custody records are included in Appendix B. Investigation-derived waste (IDW) was contained in 55-gallon UN1A steel drums temporarily stored onsite. A label indicating that the drum(s) are “on hold pending analysis” was affixed to the exterior of the drum(s) and the contents of the drum(s) “investigative derived waste – soils (or ground water)” was annotated along with the generation date(s) on the label. Analyses of the S:\AAA-Master Projects\Hickory HIC\HIC-001 Brownfield Assessment\Sites\Phase IIs\Regal\Report\Regal.doc Hart & Hickman, PC 6 drummed soil and ground water indicated the materials were non-hazardous. The drums were transported and properly disposed at an offsite permitted facility by EVO Corporation on March 31, 2010. Additionally, IDW drums produced from the previous assessment by GaiaTech were analyzed and transported off-site for proper disposal by EVO Corporation that same day. These drums also were determined to be non-hazardous. Copies of the Certificates of Waste Disposal are provided in Appendix C. 2.2 Soil Sampling Nine soil borings were advanced by DPT methods using a Geoprobe 6620DT rig. For each DPT boring, a continuous soil core was collected using a macro-core sampler within new disposable acetate sleeves. H&H field personnel described and classified attributes of the subsurface soils (i.e., color, grain size, moisture content, soil type, etc.), and screened the soils for the presence of staining, unusual odors and organic vapors (see description below). Boring logs are presented in Appendix D. The approximate soil boring locations are depicted on Figure 2. H&H collected 13 soil samples for subsequent laboratory analysis in accordance with the sampling protocol presented in the QAPP, and the revised sampling protocol presented below based on observations in the field. Samples were collected at pre-determined depth intervals and/or were collected from segments of the soil cores suspected to be contaminated based on observations and/or field screening results, whichever was specified in the QAPP. The protocol specifies the use of a photo-ionization detector (PID) to aid in sample selection. Soil cores were field-screened using a Mini-Rae 2000 PID with a 10.6 eV bulb to evaluate the potential presence of organic vapors and to assist in sample selection for subsequent laboratory analysis. Each day the PID was calibrated prior to use in accordance with the manufacturer’s suggested practices. After soil sampling was completed, the borings were abandoned with bentonite, with the exception of SB-4, SB-5 and SB-6 which were advanced below the water table and converted into temporary monitoring wells TMW-1, TMW-2, and TMW-3, respectively (see Section 2.3). S:\AAA-Master Projects\Hickory HIC\HIC-001 Brownfield Assessment\Sites\Phase IIs\Regal\Report\Regal.doc Hart & Hickman, PC 7 The following areas were assessed during the soil sampling activities conducted in January and March 2010 as outlined in the QAPP and depicted on Figure 2: Former Air Compressor Room/Automotive Repair Facility - Soil boring SB-1 was advanced to a depth of approximately 10 ft below ground surface (bgs) using DPT methods. One soil sample (0-2’) was analyzed for VOCs by EPA Method 8260B, semi-VOCs (SVOCs) by EPA Method 8270C, and Hazardous Substance List (HSL) Metals by EPA Method 6010B/7471A. A duplicate sample (DUP-1) was also collected from 0 to 2 ft and analyzed for the same parameters. Visual, olfactory, and field screening results did not indicate the presence of significant soil impacts; therefore, only the 0 to 2 ft sample was submitted for laboratory analyses. Former Machine Shop - Soil borings SB-2 and SB-3 were advanced to a depth of approximately 10 ft bgs each using DPT methods. One soil sample (0-2’) was analyzed from each boring for VOCs by EPA Method 8260B, SVOCs by EPA Method 8270C, and HSL Metals by EPA Method 6010B/7471A. A duplicate sample (DUP-1) was also collected from 0 to 2 ft in boring SB-2 and analyzed for the same parameters. Visual, olfactory, and field screening results did not indicate the presence of significant soil impacts; therefore, only the 0 to 2 ft sample from each boring was submitted for laboratory analyses. It is important to note that during the assessment of the former machine shop building, a suspected heating oil UST was discovered beneath the southwestern building wall (Figure 2). At the request of the property owner, no samples were collected in the vicinity of the UST. Former Elastic Yarn Manufacturing Warehouse - Soil boring SB-4 was advanced to a depth of approximately 30 ft bgs and soil boring SB-5 was advanced to a depth of approximately 35 ft bgs using DPT methods. One soil sample (0-2’) was analyzed from each boring for VOCs by EPA Method 8260B, SVOCs by EPA Method 8270C, and HSL Metals by EPA Method 6010B/7471A. Visual, olfactory, and field screening results did not indicate the presence of significant soil impacts; therefore, only the 0 to 2 ft sample from each boring was submitted for S:\AAA-Master Projects\Hickory HIC\HIC-001 Brownfield Assessment\Sites\Phase IIs\Regal\Report\Regal.doc Hart & Hickman, PC 8 laboratory analyses. Soil borings SB-4 and SB-5 were subsequently converted into temporary monitoring wells as discussed in Section 2.3. During the assessment of the former elastic yarn manufacturing warehouse, H&H observed PVC piping exiting the building into a small alley located between the elastic yarn manufacturing warehouse and the former yarn manufacturing building. Based on topography, the alley drains to the south. H&H personnel traced the piping back to a sink located in a small room between the former elastic yarn manufacturing warehouse and the former machine shop building (Figure 2). The room appeared to be of older construction than the former elastic yarn manufacturing warehouse. To assess potential site impacts from historical use of the sink, H&H advanced three additional soil borings: SB-7, SB-8, and SB-9 in the vicinity of the alley on March 4, 2010. Due to the very small size of the alley, overhead constraints, and numerous electrical lines present, soil borings SB-7 and SB-8 were advanced inside the building adjacent to the alley to a depth of approximately 20 ft bgs using DPT methods. Soil boring SB-9 was advanced at the entrance to the alley to a depth of approximately 10 ft bgs using DPT methods. Based on OVA readings, field judgement, and because a 0-2’ bgs soil sample had been colleceted at nearby SB-4, one soil sample was collected at the interval 14-16’ bgs from SB-7, two soil samples were collected from SB-8 at the intervals 5-7’ bgs and 13-15’ bgs, and two soil samples were collected from SB-9 at the intervals 2-4’ bgs and 8-10’ bgs. The samples collected from SB-7 and SB-8 were analyzed for VOCs by EPA Method 8260B, and the samples collected from SB-9 were analyzed for VOCs by EPA Method 8260B, SVOCs by EPA Method 8270C, and HSL Metals by EPA Method 6010B/7471A. Former Yarn Manufacturing Building/Off-Site Impacts – Soil boring SB-6 was advanced to a depth of approximately 35 ft bgs using DPT methods. One soil sample (0-2’) was analyzed from SB-6 for VOCs by EPA Method 8260B, SVOCs by EPA Method 8270C, and HSL Metals by EPA Method 6010B/7471A. Visual, olfactory, and field screening results did not indicate the presence of significant soil impacts; therefore, only the 0 to 2 ft sample was submitted for S:\AAA-Master Projects\Hickory HIC\HIC-001 Brownfield Assessment\Sites\Phase IIs\Regal\Report\Regal.doc Hart & Hickman, PC 9 laboratory analyses. Soil boring SB-6 was subsequently converted into temporary monitoring wells as discussed in Section 2.3. 2.3 Monitoring Well Installation and Sampling Ground water samples were collected from the four existing monitoring wells installed by GaiaTech during their assessment in June 2007. Additionally, three temporary monitoring wells were installed by a North Carolina-licensed well driller for additional ground water sampling. Boring logs and monitoring well construction records are included in Appendix D. The three temporary monitoring wells were installed in accordance with the QAPP. All wells were installed using DPT methods. Each well was constructed with a 10-ft length of 1.0-inch- diameter, 0.010-slot pre-packed PVC screen and 1.0-inch-diameter PVC riser. Additional sand was placed around and above the pre-packed screen. Prior to well purging, the depth-to-water in each monitoring well was gauged using an electronic water level meter (Table 1). Following depth-to-water measurements, each well was purged using a dedicated, disposable polyethylene bailer. During well purging, measurements of pH, conductivity, temperature, and turbidity were taken. The wells were purged until field parameters stabilized or the well was purged dry. All appropriate efforts were made to obtain low turbidities, but as discussed in Section 4.0, elevated turbidity was present during ground water sampling. Following purging, ground water samples were collected from each well for laboratory analyses. All samples were collected using a dedicated, disposable polyethylene bailer. The following areas of shallow ground water were assessed as outlined in the QAPP: Existing Permanent Monitoring Wells - Ground water samples were collected from existing on-site monitoring wells MW-1, MW-2, MW-3, and MW-4 and analyzed for VOCs by EPA Method 8260B, SVOCs by EPA Method 8270C, and HSL Metals by EPA Method S:\AAA-Master Projects\Hickory HIC\HIC-001 Brownfield Assessment\Sites\Phase IIs\Regal\Report\Regal.doc Hart & Hickman, PC 10 6010B/7471A. A duplicate sample (DUP-1) also was collected from MW-2 and analyzed for the same parameters. Former Elastic Yarn Manufacturing Warehouse - Soil boring SB-4 was advanced to a depth of approximately 45 ft bgs and completed as temporary monitoring well TMW-2. Additionally, soil boring SB-5 was advanced to a depth of approximately 44 ft bgs and completed as temporary monitoring well TMW-2. Ground water samples were collected from each well and analyzed for VOCs, SVOCs, and HSL metals. Former Yarn Manufacturing Building/Off-Site Impacts – Soil boring SB-6 was advanced to approximately 38 ft bgs and completed as temporary monitoring well TMW-1. A ground water sample was collected and analyzed for VOCs. Due to insufficient recharge, SVOCs and HSL metals samples could not be collected from the well. 2.4 QA/QC Samples Duplicate samples were collected as discussed in the previous sections. Matrix spike/matrix spike duplicate samples were collected in accordance with QAPP requirements for laboratory QA (quality assurance)/QC (quality control). One trip blank accompanied each cooler containing ground water VOC sample containers (during the field activities and during delivery to the laboratory). Trip blanks were analyzed for VOCs only. S:\AAA-Master Projects\Hickory HIC\HIC-001 Brownfield Assessment\Sites\Phase IIs\Regal\Report\Regal.doc Hart & Hickman, PC 11 3.0 Results of Assessment 3.1 Soil Results The following section describes the results of analyses on 13 soil samples collected at the subject site. In general, soils at the site were identified as primarily sandy silts. Bedrock was not encountered in the borings. Elevated PID readings were not detected in any of the soil boring soils except for SB-9. Boring logs are included in Appendix D. The results of soil sample analyses are summarized in Table 2, and on Figure 3. The laboratory analytical data reports are provided in Appendix B. Although no firm plans have been generated for site redevelopment, it is anticipated the site will be redeveloped commercial or light industrial. The anticipated future use and development of the site is taken into account when evaluating regulatory screening levels to ensure that site workers or commercial tenants and customers are not unduly exposed to contaminants associated with the site. For unrestricted site use, the NC DENR Brownfields Program utilizes the NCDENR Inactive Hazardous Sites Branch (IHSB) Soil Remediation Goals (SRGs), October 2008; therefore, soil data are compared to these criteria. The IHSB SRGs would likely be included a NC Brownfield’s Agreement when a potential developer moves forward with site redevelopment. Naturally occurring metals in site soil samples were also compared to values presented in Elements in North American Soils, 2005, James Dragun, Ph.D. and Khaled Chekiri, Ph.D. Exceedances of screening criteria are shown in Table 2. Former Air Compressor Room/Automotive Repair Facility - Soil boring SB-1 was advanced through the concrete floor to assess potential soil impacts near surface staining in the former air compressor room/automotive repair facility. Elevated PID readings were not detected at any depth in the soil boring. No VOCs or SVOC compounds were detected above SRGs in soil sample SB-1 (0-2’). Arsenic was detected at a concentration above its SRG in the soil sample. The detected arsenic concentration is within the published NC background concentration range. S:\AAA-Master Projects\Hickory HIC\HIC-001 Brownfield Assessment\Sites\Phase IIs\Regal\Report\Regal.doc Hart & Hickman, PC 12 Former Machine Shop - To assess potential soil impacts associated with the former machine shop, soil boring SB-2 was installed on the southern side of the building, and soil boring SB-3 was installed on the northern side of the building. Elevated PID readings were not observed at any depth in the soil borings. No VOC or SVOC compounds were detected above SRGs in soil samples SB-2 (0-2’) and SB-3 (0-2’). Arsenic was detected at concentrations above its SRG in the soil samples. The detected arsenic concentrations are within the published NC background concentration range. Former Elastic Yarn Manufacturing Warehouse - To assess potential site impacts from historical operations in the former elastic yarn manufacturing warehouse, soil borings SB-4 and SB-5 were installed in the building. To assess potential site impacts from historical use of a sink located in a small room between the former elastic yarn manufacturing warehouse and the former machine shop building, soil borings SB-7, SB-8, and SB-9 were installed in the vicinity of an alley where the sink discharges. SB-7 and SB-8 were advanced inside the former elastic yarn manufacturing warehouse, and SB-9 was advanced outside the warehouse where the alley drains. Elevated PID readings were not observed at any depth in soil borings SB-4, SB-5, SB-7, and SB- 8. However, elevated PID readings were observed at any depth interval of 2-4’ bgs in soil boring SB-9. No target compounds were detected above SRGs in soil samples SB-4 (0-2’), SB-5 (0-2’), SB-7 (14-16’), and SB-8. (13-15’). PCE, TCE, and arsenic were detected at concentrations above SRGs in soil sample SB-9 (2-4’). Arsenic also was detected at a concentration above its SRG in soil sample SB-9 (8-10’). The detected arsenic concentrations are within the published NC background concentration range. Former Yarn Manufacturing Building/Off-Site Impacts - To assess potential soil impacts associated with the former yarn manufacturing building or off-site activities, soil boring SB-6 was installed at the southwestern corner of the building. Elevated PID readings were not observed at any depth in the soil boring. S:\AAA-Master Projects\Hickory HIC\HIC-001 Brownfield Assessment\Sites\Phase IIs\Regal\Report\Regal.doc Hart & Hickman, PC 13 No VOC or SVOC compounds were detected above SRGs in soil sample SB-6 (0-2’). Arsenic was detected at a concentration above its SRG in the soil sample. The detected arsenic concentration is within the published NC background concentration range. 3.2 Ground Water Results Ground water at the site was encountered at depths ranging from approximately 31 ft to 38 ft bgs (Table 1). A water table contour map generated from the ground water elevation data is provided as Figure 4. Consistent with area topography, the map indicates that shallow ground water flow in at the site is to the southwest. Ground water field parameters are summarized in Table 3, and the results of the ground water analyses are summarized in Table 4 and on Figure 5. The analytical laboratory data reports are provided in Appendix B. Ground water analytical results were compared to the North Carolina 2L Water Quality Standards defined by North Carolina Administrative Code (NCAC) Title 15A, Subchapter 2L, Section .0200 (2L Standard). Ground water samples were collected from existing monitoring wells MW-1, MW-2, MW-3 and MW-4, and temporary monitoring wells TMW-2 and TMW-3 and analyzed for VOCs by EPA Method 8260B, SVOCs by EPA Method 8270C, and HSL Metals by EPA Method 6010B/7471A. Due to insufficient recharge, temporary monitoring well TW-1 was sampled for VOCs only. PCE was detected at concentrations above the 2L Standard of 0.70 ug/l in monitoring wells MW-1, MW-2, TW-1, and TW-2. Additionally, TCE was detected at a concentration above the 2L Standard of 3 ug/l in monitoring well MW-2. No VOCs were detected in MW-3, MW-4, and TMW-3. Additionally, SVOCs were not detected in any of the samples analyzed. Manganese was detected above its 2L Standard of 50 ug/l in monitoring wells MW-1 (360 ug/l), MW-2 (52 ug/l), MW-4 (99 ug/l), TW-2 (3,700 ug/l), and TW-3 (210 ug/l). The basis for the 2L Standard is the EPA Secondary Maximum Contaminant Level (MCL) for manganese. Secondary S:\AAA-Master Projects\Hickory HIC\HIC-001 Brownfield Assessment\Sites\Phase IIs\Regal\Report\Regal.doc Hart & Hickman, PC 14 MCLs are based on aesthetic qualities such as color, taste, odor, etc. Apart from well TW-2, the presence of manganese in site monitoring wells is believed to be from naturally occurring sources. It appears the manganese in TW-2 may be from a combination of naturally occurring and anthropogenic sources. 3.3 Ground Water Data Screening Because PCE was the only constituent detected in ground water beneath the former elastic manufacturing building above the 2L Standard, H&H performed a sequential screening evaluation of the site ground water PCE data to determine if ground water PCE concentrations pose a potential indoor air risk. The evaluation included the following three-step process: • Step 1 – Compare ground water PCE concentrations to Table 1 of EPA’s Vapor Intrusion Guidance; • Step 2 – Screen the ground water PCE concentration against the Acceptable Ground water Concentration located in the IHSB Industrial/Commercial Vapor Intrusion Screening Table, January 25, 2010. • Step 3 – Conduct site-specific vapor intrusion modeling using the J&E model (model GW-ADVANCED, Version 3.1 dated February 2004). A summary of the results of the sequential screening evaluation is presented in Table 5 and is detailed below. Screening Step 1 H&H compared PCE to Table 1 of EPA’s Guidance to evaluate the inherent toxicity and volatility of the compound with respect to indoor air risk. As summarized in Table 5, PCE poses a potential indoor air risk and was therefore further evaluated in Step 2. Screening Step 2 IHSB Industrial/Commercial Vapor Intrusion Screening Table was developed to allow screening of available site data using measured ground water and/or soil and indoor air gas concentrations. S:\AAA-Master Projects\Hickory HIC\HIC-001 Brownfield Assessment\Sites\Phase IIs\Regal\Report\Regal.doc Hart & Hickman, PC 15 IHSB’s table is segregated into columns that provide compound specific acceptable ground water, soil gas, and indoor air concentrations calculated using the lifetime incremental cancer risks (LICRs) 10-5, 10-5, and 10-6, respectively, or a hazard quotient 0.2. The highest detected PCE concentration from the monitor wells (610 µg/l) was compared to the Acceptable Ground Water Concentration in the IHSB screening table. The comparison indicates that the PCE concentration is above the Acceptable Ground Water Concentration and was therefore further evaluated in Step 3. Screening Step 3 As a final screening step, H&H conducted site-specific, screening level, vapor intrusion modeling using the J&E model (GW-ADVANCED, Version 3.1 dated February 2004). The assumptions used in the model are generally reasonable yet conservative; therefore, it may over- predict potential risk and/or compound concentrations in indoor air. Inputs to the screening model used in this evaluation were based upon best judgment or site-specific measurements, are presented in the model output in Appendix E, and are summarized below: • Average depth to ground water of 1,067 cm (35 ft) based upon the site-specific measurements from wells near and in the building; • Thickness of concrete floor of 15 cm (0.5 ft); • Average ground water temperature of 18 oC based upon site-specific measurements; • “Sandy loam” soil type based upon site-specific boring logs; • Soil bulk densities, total porosities, and water-filled porosities based upon model default parameters for the soil type; • An averaging time for carcinogens of 70 years; • An averaging time for non-carcinogens of 30 years; • Enclosed space floor length, width, and height of 4,877 cm, 914 cm, and 549 cm, respectively (based on an approximate 160’x30’x18’ room in the warehouse building located above the PCE ground water impacts); • Exposure duration of 25 years for an industrial/commercial worker; S:\AAA-Master Projects\Hickory HIC\HIC-001 Brownfield Assessment\Sites\Phase IIs\Regal\Report\Regal.doc Hart & Hickman, PC 16 • Exposure frequency of 250 days/yr for an industrial/commercial worker; and, • Other parameters based upon conservative model default values. As previously indicated, a PCE concentration of 610 µg/l (concentration at MW-2) was entered in the model, and the potential vapor intrusion risk was calculated by the model. As summarized in Table 5, PCE represents a potential vapor intrusion risk of 2.1 x 10-5 if a building were constructed above MW-2. Subsequently, a site-specific Acceptable Ground Water Concentration for the former elastic yarn manufacturing building was back-calculated to represent a conservative LICR of 1 x 10-5. The iterative back-calculation indicates a PCE concentration of 300 µg/l or lower represents an acceptable vapor intrusion risk. As shown in Figure 5, PCE has not been detected above 300 µg/l in any monitoring wells located inside or immediately outside the site buildings. 3.4 Receptor Survey In anticipation of potentially entering this property into the NC DENR Brownfield Program, a NC DENR Brownfields Area Reconnaissance and Receptor Guidance Form was completed and is provided in Appendix E. Available information indicates the following with regard to potential receptors at the site and in the site vicinity: • Multiple subsurface utilities including buried natural gas, sanitary sewer and storm sewer run adjacent to site property along 11th Avenue NE and 12th Avenue NE. • There are no surface water bodies located at the site. • The closest surface water body is an un-named intermittent tributary of Cripple Creek located approximately 2,700 ft south of the subject site. Cripple Creek is located approximately 1 mile southeast of the site. S:\AAA-Master Projects\Hickory HIC\HIC-001 Brownfield Assessment\Sites\Phase IIs\Regal\Report\Regal.doc Hart & Hickman, PC 17 • Potable water is supplied to the site and surrounding properties by the City of Hickory municipal water system, which obtains water from the Catawba River, located approximately 2 miles northwest of the site. • No public water supply well(s) were identified within 1-mile of the subject property. • No irrigation wells were identified within one half mile of the subject property. • One potential private water supply well was identified approximately 1,750 ft north of the subject property at 313 16th Avenue NE. The use of the well is unknown. A city water meter was also observed at this property. The approximate location of the potential supply well is depicted on Figure 6. • The closest school is Hickory High School located approximately 400 ft northeast of the subject site. S:\AAA-Master Projects\Hickory HIC\HIC-001 Brownfield Assessment\Sites\Phase IIs\Regal\Report\Regal.doc Hart & Hickman, PC 18 4.0 Data Review, Verification and Validation In accordance with the QAPP, the field and laboratory analytical data were subjected to review, verification, and validation to ensure that the quality and validity of the data were acceptable for the stated data quality objectives. The laboratory quality assurance data and explanations are provided in the laboratory analytical report in Appendix B. The field data review was conducted by Stephen Libbey of H&H based upon a review of the field log book. The following is a summary of the data review, verification, and validation: Field Data The following sample intervals were modified from the QAPP-specified location based on field observations. These modifications were made to better identify potential releases and to maintain the data quality objectives for the project. None of these modifications adversely impact the data quality objective of determining if a release poses a risk to future site users. • Three additional soil borings SB-7, SB-8, and SB-9 were added to the sampling plan to assess potential site impacts from historical use of a sink located in a small room between the former elastic yarn manufacturing warehouse and the former machine shop building. • Due to limited accessibility inside the former machine shop, soil boring SB-3 could not be converted into a temporary monitoring well as outlined in the QAPP. A suitable alternative location for the well could not be identified within 20 feet of the soil boring. The proper laboratory analyses were requested for each sample, with the exception of the following: • Due to insufficient recharge, temporary monitoring well TW-1 could not be analyzed for SVOCs and HSL metals. Because the historical impacts at the site are VOCs, the lack of these parameters did not impact the data quality objective. S:\AAA-Master Projects\Hickory HIC\HIC-001 Brownfield Assessment\Sites\Phase IIs\Regal\Report\Regal.doc Hart & Hickman, PC 19 Sample chain-of-custody protocols were properly followed, with the exception of the following: • Prism inadvertently utilized the dissolved metal samples from monitoring well MW-1 for MS/MSD sample. As a result, MW-1 had to be resampled on March 4, 2010 for dissolved metals. The field procedures for sampling, decontamination, calibration, etc. were followed in accordance with the QAPP procedures except as follows: • Due to a water table depth of approximately 31 ft to 38 ft bgs, H&H was unable to purge and sample the existing and temporary monitoring wells using low-flow techniques with a peristaltic pump. High turbidity was observed in the ground water samples. The field team confirmed the turbidity instrument was properly calibrated so the high turbidity was believed to be the result of low recharge and the inability to fully develop the wells. Therefore, H&H submitted ground water samples for total and dissolved HSL Metals analysis to ensure representative metals concentrations in ground water were reported. Dissolved metal analysis (i.e. lab filtered) was held until receipt of total metals results. Analytical results indicated the presence of high metal concentrations; therefore, the dissolved metal analysis was subsequently requested. Laboratory Data • The samples were received at the laboratory in good condition, within the proper temperature range, were properly preserved, and proper sample volumes were available for analysis. • The laboratory analyses were conducted within the method holding times. • The laboratory supplied a trip blank sample to accompany the groundwater samples submitted for the performance of this project. The trip blank sample was analyzed by EPA Method 8260B. Data for trip blank samples associated with this project did not S:\AAA-Master Projects\Hickory HIC\HIC-001 Brownfield Assessment\Sites\Phase IIs\Regal\Report\Regal.doc Hart & Hickman, PC 20 indicate the presence of targeted compounds at levels above the laboratory reporting limit. • No target compounds were reported above reporting limits in the method blanks for the ground water samples. • The analytical results for one soil sample and its respective blind field duplicate was not within the precision goal of 25 percent. However, because of the difficulty in completely homogenizing soil samples, this result is considered acceptable. Accordingly, H&H considers the data useable for its intended purpose. Several data QC qualifiers were noted by the project laboratory for the soil and ground water samples collected at the site. All laboratory QC statements are presented with the analytical data in Appendix B. A summary of the significant QC qualifiers for the soil and ground water samples is presented below. Soil Samples • For laboratory batch ID Q47537; the MS and MSD recoveries are outside the control limits for chlorobenzene. The associated data for soil samples SB-3, SB-4, and SB-5 are biased low because of matrix effects in the sample (LCS recovery is acceptable). Since the exceedance is in the range of 4-5% and no associated compounds are detected, the laboratory advises the data is not adversely affected. • For laboratory batch ID Q47593, the MS and MSD recoveries for antimony, cadmium, lead, manganese (MSD only), and selenium are outside the control limits. The associated data for soil samples SB-2, SB-3, SB-4, and SB-5 should be regarded as biased low because of matrix interference. Apart from manganese in soil samples SB-4 and SB-5, these compounds were reported at 1 to 2 orders of magnitude lower than the SRGs in the soil samples. Manganese was detected well below the SRG in soil samples SB-4 and SB- 5, and the laboratory advises the low-bias (2%) does not significantly affect the S:\AAA-Master Projects\Hickory HIC\HIC-001 Brownfield Assessment\Sites\Phase IIs\Regal\Report\Regal.doc Hart & Hickman, PC 21 manganese result. Consequently, these manganese data are judged to be suitable for their intended use. • For laboratory batch ID Q47653, the MS and MSD recoveries for chromium, copper, nickel, silver (MS only), and zinc are outside the control limits. The associated data for soil sample SB-4 should be regarded as biased low because of matrix interference. These compounds were reported at 1 to 3 orders of magnitude lower than the SRGs in the soil sample. Consequently, these data are judged to be suitable for their intended use. • For laboratory batch ID Q47529, the MS and MSD recoveries for mercury are outside the control limits due to interference. The associated data are biased low because of matrix effects in the sample (LCS recovery is acceptable). Mercury was reported at 1 to 2 orders of magnitude lower than the SRG in soil samples SB-2, SB-3, and SB-5. Consequently, these data are judged to be suitable for their intended use. • For laboratory batch ID Q47498, the MS and MSD recoveries are outside the control limits for benzoic acid. The associated data (sample result, MDL and RL values) for soil samples SB-1 and SB-6 are biased low because of method problems. This compound was not detected in the samples above the reporting limit, which is 4 orders of magnitude lower than the SRG. Consequently, these data are judged to be suitable for their intended use. • For laboratory batch ID Q47736, the MS and MSD recoveries are outside the control limits for benzoic acid. The associated data (sample result, MDL and RL values) for soil samples SB-2, SB-3, SB-4 and SB-5 are biased low because of method problems. This compound was not detected in the samples above the reporting limit, which is 4 orders of magnitude lower than the SRG. Consequently, these data are judged to be suitable for their intended use. • For laboratory batch ID Q48531, naphthalene was detected in the method blank at a level greater than the method detection limit, but less than the reporting limit. Sample SB-9 (2- 4’) contained naphthalene and consequently was flagged with a B. Because of blank S:\AAA-Master Projects\Hickory HIC\HIC-001 Brownfield Assessment\Sites\Phase IIs\Regal\Report\Regal.doc Hart & Hickman, PC 22 contamination, the results could be biased high with the amount equal to that found in the blank. Because the SB-9 naphthalene concentration is below its SRG, the analytical data is judged to be usable for its intended use. • For laboratory batch ID Q48531, sample SB-9 (2-4’) had three compound concentrations flagged as E – estimated concentration greater than the instrument calibration range. The sample was repeated at a 50x dilution, but the compounds were diluted out. According to laboratory personnel, the compounds in the 50x dilution sample were likely “diluted out” due to sample heterogeneity. The results for cis-1,2-dichlorothylene, trichloroethylene and tetrachloroethylene are estimated results with a possible low bias. Cis-1,2- dichlorothylene was reported at 2 orders of magnitude lower than the SRG, and trichloroethylene and tetrachloroethylene were reported above their respective SRGs. Consequently, these data are judged to be suitable for their intended use. • For laboratory batch ID Q48531, MSD recovery is outside the control limits for chlorobenzene. Since the MS recovery is within the control limits and the RPD is acceptable, the laboratory advises the associated data is not adversely affected. • For laboratory batch ID Q48603, benzoic acid recovery is below the control limits in the laboratory control sample. The associated data (sample result, MDL and RL values) for soil samples SB-9 (2-4) and SB-9 (8-10) are biased low because of method problems. This compound was not detected in the samples above the reporting limit, which is 4 orders of magnitude lower than the SRG. Consequently, these data are judged to be suitable for their intended use. • For laboratory batch ID Q48603, MS and MSD recoveries are outside the control limits for 2,4-dinitrophenol, 4,6-dinitromethol phenol, di-n-octylphthalate (MSD only), and benzoic acid (MS only). The sample that was spiked was a non-project sample; therefore, the results are not representative of the project matrix and the laboratory advises the results are not adversely affected. S:\AAA-Master Projects\Hickory HIC\HIC-001 Brownfield Assessment\Sites\Phase IIs\Regal\Report\Regal.doc Hart & Hickman, PC 23 • For laboratory batch ID Q48536, the MSD recoveries for manganese and selenium, and the MS and MSD recoveries for antimony are outside the control limits. The antimony data for soil samples SB-9 (2-4) and SB-9 (8-10) are biased low because of matrix interference, and the manganese and selenium data for these same samples should be regarded as estimated because the sample is not homogeneous. These compounds were reported at 1 to 2 orders of magnitude lower than the SRG in the soil samples. Consequently, these data are judged to be suitable for their intended use. Ground Water Samples • For laboratory batch ID Q47460, the MS recovery for pentachlorophenol and MSD recovery for pyrene are outside the control limits. Since the MSD recovery is within the control limits and the RPD is acceptable and the fact that the compounds were not detected, the laboratory advises the results are not adversely affected. • For laboratory batch ID Q47476, the MS and MSD recoveries are outside the control limits for manganese. The MS/MSD sample concentration is too high for recovery evaluation of manganese; therefore, the laboratory could not determine whether the unfiltered manganese concentrations in MW-1, MW-2, MW-3, MW-4, TW-2, TW-3, and TW-4 were biased low or biased high. These samples were laboratory filtered and re- analyzed for manganese. No MS/MSD anomalies were noted. Consequently, these data are judged to be suitable for their intended use. • For laboratory batch ID Q47521, the MS and MSD recoveries are outside the control limits for benzene. Since the MS/MSD recoveries are within the control limits and the compound was not detected, the laboratory advises the results are not adversely affected. For the reasons noted above, the results of the data review indicate that field and laboratory data generally meet QA objectives and are usable for the intended purpose. S:\AAA-Master Projects\Hickory HIC\HIC-001 Brownfield Assessment\Sites\Phase IIs\Regal\Report\Regal.doc Hart & Hickman, PC 24 5.0 Conclusions Based on the assessment findings, the conclusions noted below should be considered when assessing site risk and evaluating redevelopment plans. Historical Soil and Ground water Assessment Results • To assess site impacts from a former UST reportedly removed from the western side of the property in the late 1980s, GaiaTech collected four soil samples in the vicinity of the former UST during a focused Phase II Investigation in January 2002. No VOCs or TPH- GRO concentrations were detected in soil samples above the laboratory detection limits, and lead was detected at concentrations within the EPA published background concentration range. • Petroleum hydrocarbons, PCE, TCE and lead concentrations in ground water have historically been detected above the ground water standards at the adjacent Servco facility. Importantly, substantial PCE and TCE impacts were detected in monitoring wells in the northeastern portion of the Servco property south of the Regal former yarn manufacturing building. Additionally, TCE and PCE concentrations also were detected above the ground water standards in a ground water monitoring well located at the Dunmore Furniture property in March 2006. • To assess site impacts from potential off-site sources, GaiaTech collected eight soil samples and seven ground water samples at the site as part of the Limited Phase II Site Assessment activities in 2007. No soil impacts were detected in the soil samples. Ground water analytical results indicated PCE concentrations as high as 280 µg/l and TCE concentrations as high as 58 µg/l in the southwestern corner of the property (near the Servco property boundary). No ground water impacts were detected in the ground water samples collected along the northern, western, and eastern property boundaries. S:\AAA-Master Projects\Hickory HIC\HIC-001 Brownfield Assessment\Sites\Phase IIs\Regal\Report\Regal.doc Hart & Hickman, PC 25 2010 Soil and Ground Water Assessment Results • PCE and TCE were detected at concentrations above SRGs in soil sample SB-9 (2-4’). Additionally, no SVOC compounds were detected above SRGs in any of the soil samples. • Arsenic was detected above its SRG in the shallow soil samples (up to 16 mg/kg). The detected arsenic concentrations are within NC’s background concentration range. • No VOCs were detected in MW-3, MW-4, and TW-3. Additionally, SVOCs were not detected in any of the ground water samples analyzed. PCE and TCE were detected at concentrations above the 2L Standards in monitoring well MW-2, and TCE was detected at a concentration above the 2L Standard in monitoring wells MW-1, TW-1, and TW-2. • Manganese was detected above its 2L Standard in monitoring wells MW-1, MW-2, MW- 4, TW-2, and TW-3. The basis for the 2L Standard is the EPA Secondary MCL for manganese. Secondary MCLs are based on aesthetic qualities such as color, taste, odor, etc. The presence of manganese in ground water at the site is believed to be naturally occurring at all well locations with the possible exception of TW-2. • A suspected heating oil UST was discovered beneath the southwestern building wall. At the request of the property owner, no samples were collected in the vicinity of the UST. • Vapor intrusion modeling indicated PCE represents a potential vapor intrusion risk of 2.1 x 10-5 if a building were constructed above monitoring well MW-2. Additionally, a site- specific Acceptable Ground Water Concentration for the former elastic yarn manufacturing building was back-calculated to represent a conservative LICR of 1 x 10-5. The iterative back-calculation indicates a PCE concentration of 300 µg/l or lower represents an acceptable vapor intrusion risk. Recommendations: Current and historical detected VOCs in soil and ground water likely indicate a release of chlorinated solvents south of the former yarn manufacturing building. Spot removal of shallow impacted soils should be considered during site redevelopment south of the S:\AAA-Master Projects\Hickory HIC\HIC-001 Brownfield Assessment\Sites\Phase IIs\Regal\Report\Regal.doc Hart & Hickman, PC 26 former yarn and elastic yarn manufacturing buildings near SB-9. Because SVOC compounds were not detected above SRGs in any of the soil samples, no additional assessment or remedial action is recommended for SVOCs at this time. Additionally, because the arsenic concentrations are likely to be naturally occurring, no additional assessment is recommended for arsenic at this time. H&H recommends that ground water consumption be prohibited at the site via a ground water restriction to address the PCE, TCE, and manganese impacts. Additionally, future building construction in the southern area of the site (near MW-2) should take into account the potential risk of vapor intrusion.