15032_800 Chatham Rd_QAPP Addendum 1 A_20120620

APPENDIX C

Of

GENERIC QUALITY ASSURANCE PROJECT PLAN (QAPP)

For

Chatham Mill Ventures, LLC

Revolving Loan Fund

Site-Specific QAPP Addendum 1.A

Remedial Design and Confirmatory Sampling/Testing

Chatham Mill Property
800 Chatham Street
Winston-Salem, North Carolina

Grant Number BF-96413504

Revision 0

This document and work performed under this Site-Specific QAPP Addendum 1.A is prepared in
accordance with the EPA Region 4 Brownfields Program and the Generic QAPP document for
the Land of Sky Regional Council.

Prepared for:

Chatham Mill Ventures, LLC
4108 Darlington Place
Raleigh, NC 27612

Prepared by:
AMEC Environment & Infrastructure, Inc.
2200 Gateway Centre Blvd, Suite 205
Morrisville, NC 27560

June 20, 2012
Site-Specific QAPP Addendum 1.A Page i
Chatham Mill Property Chatham Mill Ventures, LLC.
800 Chatham Street, Winston-Salem, NC
Revision 0, June 20, 2012
A-1. Title & Approval Page
Site-Specific QAPP Addendum 1.A, June 18, 2012, BF-96413504
Remedial Design and Confirmatory Sampling/Testing
Chatham Mill Property, 800 Chatham Street, Winston-Salem, North Carolina

Site-specific Quality Assurance Project Plan (QAPP) Addendum 1.A is associated with the
Generic QAPP, Revision 0, June 2010 for Chatham Mill Ventures, LLC (Chatham Mill) through
the Land of Sky Regional Council Revolving Loan Fund, BF-96413504. Addendum 1.A is
prepared in accordance with the EPA Region 4 Brownfields Program. Work described in
Addendum 1.A will be performed in accordance with the processes described in the Generic
QAPP. AMEC Environment & Infrastructure, Inc. prepared this Addendum and the Generic
QAPP (formerly known as MACTEC Engineering and Consulting, Inc.), and the grantee is the
Land of Sky Regional Council.

Name: Wanda Jennings

Title: U.S. Environmental Protection Agency, Region 4 Brownfields Project Officer

Signature: Date:

Name: _________________

Title: U.S. Environmental Protection Agency, Region 4 Designated Approving Official (DAO)

Signature: Date:

Name: Lisa Taber

Title: North Carolina Department of Natural Resources, Brownfields Program

Signature: Date:

Name: Jerry Deakle

Title: Member – Chatham Mill Ventures, LLC

Signature: Date:

Site-Specific QAPP Addendum 1.A Page ii
Chatham Mill Property Chatham Mill Ventures, LLC.
800 Chatham Street, Winston-Salem, NC
Revision 0, June 20, 2012

Name: Kate O’Hara

Title: Senior Planner – Brownfields Program Manager, Land of Sky Regional Council

Signature: ___________________________ Date: ___________________

Name: Kathleen Roush, LG

Title: Assessment/Remediation Supervisor, AMEC Environment & Infrastructure, Inc.

Signature: Date: ____ ________

Name: Douglas Lane

Title: Quality Assurance/Quality Control Officer, AMEC Environment & Infrastructure, Inc.

Signature: Date: _________

Site-Specific QAPP Addendum 1.A Page iii
Chatham Mill Property Chatham Mill Ventures, LLC.
800 Chatham Street, Winston-Salem, NC
Revision 0, June 20, 2012
A-2. Table of Contents
SECTION PAGE NO.

A-1. Title & Approval Page .......................................................................................................... i 
A-2. Table of Contents ............................................................................................................... iii 
A-3. Distribution List ................................................................................................................... 1 
A-4. Project - Task Organization ............................................................................................... 3 
A-5. Problem Definition/Background ....................................................................................... 3 
A-6. Project/Task Description/Timeline .................................................................................... 7 
A-7. Special Training Requirements & Special Certifications .............................................. 11 
A-8. Documentation and Records ........................................................................................... 11 
B-1. Sampling Process Design & Site Figures ....................................................................... 11 
B-2. Sampling & Analytical Method Requirements ................................................................ 11 
B-3. Sample Handling & Custody Requirements ................................................................... 14 
B-4. Analytical Methods & Requirements ............................................................................... 14 
B-5. Field Quality Control Requirements ................................................................................ 14 
B-6. Laboratory Quality Control Requirements ..................................................................... 15 
B-7. Field Equipment & Corrective Action .............................................................................. 15 
B-8. Lab Equipment & Corrective Action ................................................................................ 16 
B-9. Analytical Sensitivity & Project Criteria .......................................................................... 16 
B-10. Data Management & Documents ................................................................................... 16 
C-1. Assessments & Response Actions ................................................................................. 16 
C-2. Project Reports ................................................................................................................. 17 
D-1. Field Data Evaluation ........................................................................................................ 17 
D-2. Laboratory Data Evaluation ............................................................................................. 17 
D-3. Data Usability and Project Evaluation ............................................................................. 17 
References ................................................................................................................................. 18 

TABLES

Adjacent Properties ............................................................................................................. Table 1

FIGURES

Site Topographic Map ........................................................................................................ Figure 1
Proposed Sample Location Map ........................................................................................ Figure 2

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Chatham Mill Property Chatham Mill Ventures, LLC.
800 Chatham Street, Winston-Salem, NC
Revision 0, June 20, 2012

APPENDICES

Laboratory Standard Operating Procedures (provided only on a separate CD) ........... Appendix 1

Representative Method Detection, Reporting, & Control Limits
(provided only on a separate CD) ................................................................................. Appendix 2

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800 Chatham Street, Winston-Salem, NC
Revision 0, June 20, 2012
A-3. Distribution List
Site-Specific QAPP Addendum 1.A, June 20, 2012, BF-96413504
Remedial Design and Confirmatory Sampling/Testing
Chatham Mill Property, 800 Chatham Street, Winston-Salem, North Carolina

U.S. Environmental Project Agency (EPA):

Wanda Jennings
US EPA Region 4
Atlanta Federal Center
61 Forsyth Street, SW
Atlanta, Georgia 30303
[e-mail]
Phone: [phone]

North Carolina Department of Environment and Natural Resources

Lisa Taber
North Carolina Department of Environment and Natural Resources
Brownfields Program
Mail Service Center 1646
Raleigh, NC 27699-1646
Phone: [phone]
[e-mail]

Land of Sky Regional Council (Land of Sky)

Kate O’Hara
Senior Planner – Brownfields Program Manager
Land of Sky Regional Council
339 New Leicester Hwy, Suite 140
Asheville, NC 28806
[e-mail]
Phone: [phone]

Chatham Mill Ventures, LLC (Chatham Mill)

Jerry Deakle
Chatham Mill Ventures, LLC
300 Blackwell Street, Suite 101-B
[e-mail]
[phone]

Site-Specific QAPP Addendum 1.A Page 2
Chatham Mill Property Chatham Mill Ventures, LLC.
800 Chatham Street, Winston-Salem, NC
Revision 0, June 20, 2012
AMEC Environment & Infrastructure (AMEC)

2200 Gateway Centre Blvd, Suite 205
Morrisville, NC 27560
[phone]

Kathleen Roush, AMEC Assessment/Remediation Supervisor
[e-mail]

Douglas Lane, AMEC Quality Assurance/Quality Control Officer
[e-mail]

AMEC Field Team Coordinator: John Maas; field team will receive a copy of and will follow this
site-specific QAPP Addendum

Laboratory (subslab and ambient air samples):
Air Toxics Ltd.
180 Blue Ravine Road, Ste.B
Folsom, CA 95630
Phone: [phone]
[e-mail]

Laboratory (ACM and Lead-based paint):
EMSL Analytical, Inc.
706 Gralin Street
Kernersville, NC, 27284
Phone: [phone]

Subcontractor (lead-based paint survey)
ECS Carolinas, LLP
4811 Koger Boulevard
Greensboro, NC 27407
Phone: [phone]
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800 Chatham Street, Winston-Salem, NC
Revision 0, June 20, 2012

A-4. Project - Task Organization

Project organization and responsibilities are the same as those provided in the Generic QAPP,
except the analytical laboratories and other subcontractors are specified in this Addendum. The
laboratory for analysis of samples from asbestos-containing materials (ACM) and lead-based
paint will be EMSL Analytical, Inc. The laboratory for confirmatory subslab and ambient air
sample analyses will be Air Toxics, Inc. Specific organizational responsibilities are provided in
Section A-4 of the Generic QAPP.

A-5. Problem Definition/Background

Chatham Mill Ventures, LLC has purchased and will re-develop the Chatham Mill Property
(Site). The site consists of approximately six acres which was developed in the early 1900s. A
total of 24 buildings have been constructed on the property over the years, such that the
majority of the site is currently occupied by multi-story warehouse and manufacturing buildings.
Several of the structures were subsequently razed. The warehouse and manufacturing spaces
located at the site have been occupied in the past by a variety of commercial and industrial
businesses. During a Phase I Environmental Site Assessment (ESA) of the Site conducted in
May 2007, several recognized environmental conditions (RECs) were identified based on
historical manufacturing operations of textiles, batteries, proximity fuses, and others (MACTEC
2007). To investigate these RECs, a Phase II ESA was conducted at the Former Chatham Mill
Plant in February 2007 (MACTEC 2007). The current scope of work has been developed to
gather data to design active and passive methods to address previously identified vapor
intrusion issues, additional asbestos survey required for ACM removal, and an additional lead-
based paint inspection at this facility as required prior to abatement, and is presented in this
Addendum.

The Site is located at 800 Chatham Road in Winston-Salem, Forsyth County, North Carolina
and is owned by Chatham Mill Ventures, LLC. It occupies 5.96 acres. The plan for the Chatham
Mill Property is to offer a community complete with residential units, commercial/office units,
retail space and recreation space. The Chatham Mill site is currently vacant and is listed on the
National Register of Historic Places. Land of Sky Regional Council was awarded an EPA
Revolving Loan Fund Program Grant and will loan these monies to fund the redevelopment of
the Chatham Mill Property.

Sanborn maps indicate the main manufacturing building (Figure 2, Buildings 2 and 4) and four
additional buildings were present in 1907. The site included a railroad trestle labeled “coal” and
was bordered to the south by a Southern Railroad spur line. The 1912 map indicated the
addition of a small “oil house” and an “electrical house.” The 1917 Sanborn depicted the
Chatham Manufacturing Company’s No. 2 mill, as well as a warehouse with a loading dock
bordering the railroad spur and a reservoir north of the boiler house. The 1950 Sanborn
identified that the site was occupied by the Western Electric Company, Inc. and new buildings
had been constructed. The 1963 map indicated the site was labeled Associated Risk, Western
Electric Company, Manufacturer of Electronic Devices with the addition of several buildings.
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800 Chatham Street, Winston-Salem, NC
Revision 0, June 20, 2012
Site Location:
Figure 1 is a topographic map of the Site and adjacent area. Figure 2 shows proposed
sampling locations at the Site. The current uses of the majority of immediately adjoining
properties are residential, commercial, and light industrial, as listed in Table 1:
Table 1. Adjacent Properties

Direction Property Description
North Peter’s Creek and several commercial and industrial businesses
including Willard Cab Company
East Chatham Road and a Hanes Dye and Finishing plant
South Residence and P&B Distribution commercial business
West Residences and Piedmont Sheet Metal

The United States Geological Survey (USGS) 7.5-Minute Winston Salem West, North Carolina
Topographic Map (1997) indicates the Site is located in a mixed residential/industrial area in the
central portion of Forsyth County, North Carolina. Zoning designations list the property as
General Industrial. The property elevation ranges from approximately 840 feet above mean sea
level in the south to approximately 795 feet above mean sea level to the north. Surface drainage
at the subject property generally flows to the nearest street, where it is collected in stormwater
inlets, or to storm drains located on the site which direct stormwater flow to Peter’s Creek.

Site Geology:

The U.S. Department of Agriculture (USDA) Natural Resources Conservation Service (NRCS)
Web Soil Survey indicates that the dominant soils in this area are identified as ‘Urban Land’ or
Ur (Soil Survey, 2012). ‘Fairview-Urban land complex’ (FfE) is mapped along the northwest and
southeast of the site and the Ur. FfE is described as a saprolite derived from granite and gneiss
and/or schist, which is well drained and has a 10 to 25 percent slope capacity. ‘Codorus Loam’
(CoA) soils are identified along Peters Creek through the center of the site. CoA is found along
streams, is poorly drained and has a 0 to 2 percent slope capacity.

According to the Geologic Map of North Carolina, the former Chatham Mills Property is located
within the Metamorphic sediments of the Milton Belt Physiographic Province of central North
Carolina. The metamorphic rocks range from 500 to 750 million years in age. They include
biotite gneiss and schist that have been intruded by younger granitic rocks.

The soil lithology observed during the Phase II ESA to a depth of approximately 10 feet below
ground surface (bgs) at the Site was as follows: predominantly red brown silty clay, with
occasional sandy clay, overlain by less than one foot of sand or silty sand. Depth to
groundwater ranged from 18.26 to 34.90 feet below the top of casing in three permanent wells
on Site. Groundwater flow at the Site is generally to the northwest toward Peter’s Creek, based
on only one set of water level measurements in the three permanent wells.

Phase I/II ESAs:

AMEC Environment & Infrastructure, Inc. (AMEC) conducted a Phase I ESA of the Site in May
2007. The ESA noted the site was partially occupied (approximately ten percent) by various
businesses for storage at the time of the site visit. RECs identified included the following:
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• Railroad Spur
• Upgradient Manufacturing Facility with Historical Fire
• Former 17,000-Gallon #6 Fuel Oil UST
• Possible UST in Vicinity of Building 5
• Possible UST in Vicinity of Building 18
• Existing #6 Fuel Oil AST
• Existing Pad-Mounted Electrical Transformer North of Building 23
• Guard Shack/Former Garage
• Groundwater Quality

Due to the RECs identified in the Phase I ESA, AMEC conducted a Phase II ESA of the Site in
February 2007 to identify soil and/or groundwater contamination (MACTEC 2007). The Phase II
ESA consisted of the following:

• Installation of nineteen (19) soil borings and four (4) temporary monitoring wells.
• Soil borings were advanced to depths ranging from 3.5 to 15 feet bgs. Four temporary
wells were installed at a maximum depth of 28 feet bgs.
• A total of 16 soil samples were collected for laboratory analysis. Four soil borings were
advanced along the railroad spur. Three soil borings were advanced along the southern
property boundary. Three soil borings were advanced along the approximate center line
of the former 17,000-gallon fuel oil UST. Two soil borings were advanced in each of the
following areas: the suspected UST near Building 5, the possible UST in vicinity of
Building 18, the existing #6 Fuel Oil AST, and the existing pad-mounted electrical
transformer north of Building 23. In the former garage area, one soil boring was
advanced.
• Collection of a groundwater sample from three of the four temporary monitoring wells.
• Soil and groundwater samples were generally analyzed for volatile organic compounds
(VOCs), semi-volatile organic compounds (SVOCs), total petroleum hydrocarbons –
diesel range organics (TPH-DRO), and/or polychlorinated biphenyls (PCBs). Table 3 in
the 2007 MACTEC report presents a summary of the soil sample analytical results.
Table 4 presents a summary of the groundwater sample analytical results from the
Phase II ESA.

The soil analytical results from the Phase II ESA were compared to North Carolina Department
of Environment and Natural Resources (NCDENR) Maximum Soil Contaminant Concentrations
(MSCCs) and groundwater analytical results were compared to NCDENR 2L Groundwater
Standards (2L Standards), as presented in NCDENR Division of Water Quality, Groundwater
Section Guidelines for the Investigation and Remediation of Soil and Groundwater, dated July
2000. As a result of this comparison, the following exceedances were identified in soil samples:

• In soil boring SB-4, TPH-DRO was detected at a concentration of 14.1 milligrams per
kilogram (mg/kg) that exceeded the NCDENR Action Level of 10 mg/kg.
Tetrachloroethene (PCE) was detected at 43.0 mg/kg and Naphthalene at 1.3 mg/kg, both
exceeding their MSCCs.
• PCE was detected at a concentration exceeding its MSCC in soil boring SB-7 and SB-10.
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In groundwater, Trichlorothene (TCE) and PCE were detected in all three groundwater samples
at concentrations exceeding their respective 2L Standards. Cis-1,2-dichlorothene (cis-1,2-DCE)
and Vinyl chloride also exceeded their 2L Standards in temporary well TMW-2.

Additional Soil and Groundwater Assessment Activities:

The Phase II ESA identified contaminated soil and groundwater at the site. Working with the
NCDENR, it was determined that additional samples were necessary in the vicinity of the
railroad spur and that permanent groundwater monitoring wells should be installed to evaluate
the potential source of the groundwater contamination. Therefore, additional soil and
groundwater assessment activities were conducted under the authority of the NCDENR,
Division of Waste Management (DWM), Inactive Hazardous Sites Branch (IHSB).

In September 2008, eight soil borings were advanced in the vicinity of the railroad spur. The soil
borings were advanced to a depth of approximately 10 feet bgs with a track-mounted
Geoprobe® drilling rig. Soils were screened for the presence of VOCs using a photoionization
detector (PID) and submitted to the lab for analysis of VOCs according to USEPA Method 8260
and Resource Conservation and Recovery Act (RCRA) Metals according to USEPA Methods
6010/7470.

Three Type II groundwater monitoring wells (MW-1 through MW-3) were installed using an air
hammer drilling rig. MW-1 and MW-2 were terminated at a depth of 45 feet bgs and MW-3 was
completed at a depth of 35 feet bgs. Three well volumes of water were purged from each well
prior to the collection of groundwater samples. Samples were collected with a disposable
Teflon™ bailer and submitted to the lab for analysis of VOCs according to USEPA Method 8260
and Resource Conservation and Recovery Act (RCRA) Metals according to USEPA Methods
6010/7470.

The soil analytical results from the additional sampling were compared to NCDENR Health-
Based Soil Remediation Goals (SRGs) and groundwater analytical results were compared to 2L
Standards. PCE was detected in four soil borings, but at concentrations below its SRG of 0.48
mg/kg. In groundwater, PCE was detected in two groundwater samples at concentrations
exceeding its 2L Standard. TCE and cis-1,2-DCE exceeded their 2L Standards at MW-2 and
lead was detected above its respective 2L Standard in samples collected from MW-2 and MW-
3. Table 5 included in the 2009 MACTEC report presents a summary of the soil sample
analytical results and Table 6 presents a summary of the groundwater sample analytical results
from the Report of Limited Soil and Groundwater Assessment activities.

Based on the data from the groundwater assessment, it was determined that there is a vapor
intrusion concern for potential redevelopment scenarios being considered at the former
Chatham Mill Site.

Results of ACM Survey:

On May 31, 2010, an asbestos-containing materials (ACM) survey was conducted at the Site.
Samples of suspect ACM were collected and sent to a laboratory accredited by the National
Voluntary Laboratory Accreditation Program (NVLAP). ACM identified at the Site, and its
friability, consisted of the following:
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• Approximately 121,990 square feet of floor tile (non-friable) and associated mastic (non-
friable)
• Approximately 17,537 linear feet of pipe and fitting insulation (friable)
• Approximately 27,750 square feet of cement board siding (non-friable), located under
the vinyl siding.
• Presumed ACM (PACM) tank insulation (friable);

Other Building Materials:

Paint was screened on inside walls of the Site building. Analysis for lead in the paint indicated
the presence of lead in nearly every room (from approximately 0.1 to greater than 9.9 milligrams
per square centimeter (mg/cm2)). Based on the age of the building, lead based paint is
presumed to exist throughout the building.

Constituents of Concern (COCs):

COCs include VOCs related to storage of petroleum in underground storage tanks (USTs) and
from historical dry cleaning and circuit board manufacturing. The following COCs were found
during previous investigations:

Soil: TPH-DRO, PCE, Naphthalene,

Groundwater: PCE, TCE, cis-1,2-DCE, vinyl chloride, and lead

Building Materials: ACM and lead in paint

The primary potential entry routes of identified COCs include (1) for soil: inhalation of
particulates and organic compound vapors, dermal absorption, and ingestion of soil by
construction/utility workers, (2) for groundwater: none (as an environmental covenant will be put
in place to prohibit use of groundwater for drinking or other purposes and potential vapor
intrusion from VOCs is covered under subslab vapor), and (3) subslab vapor: inhalation of VOC
vapors. Cleanup actions will minimize or eliminate these exposure routes.

Field work and investigation-derived waste disposal will be conducted in accordance with AMEC
Standard Operating Procedures (Appendix A of the QAPP) and applicable regulations. Data
from the study will be used to determine current Site conditions and the effectiveness of
remedial actions.

A-6. Project/Task Description/Timeline

Data from the sampling proposed in this Addendum will be used, along with additional sampling
activities, to develop an Assessment of Brownfields Cleanup Alternatives, documenting potential
cleanup alternatives for the Site and design contaminant mitigation systems and strategies for
the redevelopment. Confirmatory lead based paint sampling and potential ACM sampling during
or after abatement of the existing building (to include air clearance sampling) are covered in this
site-specific QAPP. As stated in the last section, in addition to the work proposed herein,
additional sampling will be conducted for the design and installation of a vapor mitigation system
and such other mitigation as may be required under the anticipated Brownfield Agreement. The

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mitigation system and/or engineering controls to be used to address vapor intrusion will be
addressed in a subsequent Site Specific QAPP if RLF funds are used for vapor mitigation
purposes.

ACM Regulatory Requirements
ACM is subject to a variety of regulatory requirements summarized as follows:
• 40 CFR 61 - A National Emissions Standards for Hazardous Air Pollutants
(NESHAPS) requires removal of ACM from buildings prior to renovation or
demolition. This typically requires an intrusive investigation to identify ACM
hidden in floors, wall, ceilings, etc.
• 40 CFR 763 – EPA Asbestos Hazard Emergency Response Act (AHERA)
requires management of asbestos in schools and provides a standard of
care for asbestos surveys. AHERA surveys are typically baseline surveys;
they do not identify several types of NESHAP regulated materials (e.g.
hidden or exterior ACM)
• 29 CFR 1910.1101 - OSHA asbestos regulations require management of
asbestos in buildings to protect workers. AHERA surveys meet the OSHA
requirement to identify ACM in buildings.
• Other Federal, State and Local regulations governing ACM licensure, ACM
removal, permitting, etc.

Current federal, state and local regulations require that property owners, prior to demolition work
on existing properties, conduct surveys to locate and identify ACM (e.g. a “Good Faith” or
NESHAP Survey). A “good faith” NESHAP ACM survey is required to notify bidding contractors
of ACM locations and quantities. A survey of the building has been completed.

Basic ACM Sampling Protocol

A State licensed and/or AHERA certified ACM inspector will determine the need to sample ACM
during abatement in general accordance with NESHAP sampling protocol. ACM samples will
only be collected where the safety of the inspector(s) can be assured. The evaluation for ACM is
limited to the following scope assumptions.

1. Representative bulk samples of homogenous materials, if necessary, will be collected
and analyzed at a designated laboratory by polarized light microscopy (PLM) at standard
turn-around time (TAT) of 10 working days. PLM analysis of some non-friable organically
bound ACM materials (NOB) such as floor tiles, roofing, etc. may be inconclusive for
ACM. Transmission electron microscopy (TEM) analysis provides lower asbestos
detection limits, if needed.

2. ACM samples will be collected to generally categorize homogenous materials. The
entire inventory of collected samples may not require laboratory analysis. Initially, we will
analyze one sample per material. If the first sample contains ACM, remaining samples
will not be analyzed (positive stop protocol). If the first sample is determined not to
contain ACM, the next sample of the like material will be analyzed, and so on until ACM
is either identified (at which point additional analyses will not be performed) or the
material is found to contain no ACM.
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3. ACM may be hidden in walls, ceilings, floors, etc., that are not identified by AHERA
surveys. AHERA surveys also exclude exterior ACM such as roofing and caulking.
Intrusive NESHAP sampling can help identify these materials. For the building at this
Site, safety concerns must be considered before an area is accessed or a sample is
collected.

4. Building materials such as walls, roofing, floor coverings, caulking, etc. may contain
many types or layers of ACM, particularly in older buildings. Under the AHERA protocol,
the inspector presumes the entire area contains ACM based on a minimal number of
positive samples. Additional sampling can further delineate the extent of these
materials, if needed.

5. Air clearance sampling will meet the requirements of OSHA 29 CFR 1926.1101,
Appendices A and B.

6. A report will be prepared to summarize the abatement and any associated sampling.

7. The report will include the following information:

o Building Description
o Abatement Protocols
o Laboratory Analytical Results, if applicable
o Air Clearance Sample Results.

Basic Lead-Based Paint Inspection Protocol

A certified lead-based paint inspector will determine the need to sample during the surface-by-
surface investigation. Paint samples will only be collected where the safety of the inspector(s)
can be assured. The evaluation for lead is limited to the following scope assumptions.

1. An inventory will be comprised of homogenous building areas based on building
components, paint color, type of substrate, application, and component use. One
individual XRF reading will be obtained on each testing combination in each room
equivalent. For walls, at least four readings (one reading on each wall) will be taken in
each room equivalent.
2. Readings above the upper limit of the inconclusive range are considered positive, while
readings below the lower limit of the inconclusive range are considered negative.
Readings within the inconclusive range (including its boundary values) are classified as
inconclusive. In multifamily dwelling inspections, XRF readings are aggregated across
units and room equivalents by component type.
3. The inspector should use the HUD/EPA standard for lead-based paint of 1.0 mg/cm2 or
0.5% by weight. Lead paint amounts will be reported in mg/cm2.
4. Three calibration check readings will be taken before beginning the inspection.
Additional calibration check readings should be made every 4 hours or after inspection
work has been completed for the day.
5. Painted surfaces include any surface coated with paint, shellac, varnish, stain, paint
covered by wallpaper, or any other coating. Wallpaper should be assumed to cover
paint.

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6. Paint-chip samples are collected when the overall results for a component type are
inconclusive. Paint-chip samples should contain all layers of paint (not just peeled
layers) and must always include the bottom layer.
7. A report will be prepared indicating if and where lead-based paint is located in the
development.

Subslab Vapor, Crawl Space, and Indoor Air Sampling Protocol

Presently, multiple buildings exist on the Former Chatham Mill Plant. To develop a design to
address potential vapor intrusion issues within the residential development, additional subslab
and crawl space samples will be acquired for analysis from approximately two locations within
most buildings. The vapor sampling results will be compared to the current IHSB Residential
Vapor Intrusion Screening Levels (IHSB screening levels), and for buildings not to be used for
residential purposes, results will be compared to Industrial/ Commercial levels. Per the IHSB
Supplemental Guidelines for the Evaluation of Structural Vapor Intrusion Potential for Site
Assessments and Remedial Actions Under the Inactive Sites Branch (21 June 2011), samples
will be obtained in the representative “worst-case” locations in the building. Subslab samples will
be collected near the center of the slab to obtain representative concentrations. Due to the
absence of a functioning HVAC system, HVAC system zones will not be taken into
consideration.

The construction of the various buildings varies and some are constructed with slab on grade
construction, while other buildings have an underlying crawl space. Subslab samples will be
collected where no crawl space exists. The proposed work will include collecting 14 subslab
vapor samples at various locations throughout the buildings to be analyzed for the presence of
VOCs. Subslab samples measure the soil vapor concentrations immediately beneath the
building’s slab-on-grade foundation. Eight crawl space samples will be collected.
subslabsubslab

An outdoor air sample (OS-1) will be collected to characterize background ambient air
conditions. The outdoor air sample will be collected concurrently with the crawl space sampling.
The locations of the crawl space and subslab vapor samples are located on Figure 2. The
location of the outdoor ambient air sample will be determined based upon field conditions.

Indoor air sampling will be conducted after the building construction is finalized and a HVAC
system is operational, creating an effective building envelope. The optimum time to collect
indoor air samples is during colder weather. Therefore, waiting for the construction timeline
may provide a better representation of worst-case conditions. Any indoor air samples will be
taken away from window/egress locations, but near subsurface features that penetrate the
building’s foundation.

Timeline

The projected timeline is as follows: (1) site-specific QAPP Addendum review/approval: 15 days
from submittal to EPA, (2) field activities and sampling: one to two weeks from initiation of field
work, (3) laboratory turnaround time: 5-10 business days, and (4) reporting activities to be
completed within 30 days after laboratory results are available.
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A-7. Special Training Requirements & Special Certifications

Only a North Carolina Asbestos Hazard Management Program accredited individual/contractor
will be used to sample for ACM. Accreditation of asbestos professionals is covered by 401 North
Carolina Administrative Code (NCAC), Chapter 10A, Subchapter 41C.0600. Other special
training requirements and special certifications are provided in the generic QAPP.

A-8. Documentation and Records

Documentation and records requirements are discussed in the generic QAPP and in Section A-
8.

B-1. Sampling Process Design & Site Figures

The scope of work for this Site includes the following tasks:

• Conduct ACM sampling before, during, or after abatement, as necessary;
• Conduct Lead-based paint inspection;
• Obtain subslab, crawl space and outdoor air samples; and
• Submit samples for laboratory analyses.

The ACM sampling involves a visual assessment and collecting and analyzing suspect asbestos
containing building materials, if necessary as part of abatement activities. Minimum sample
requirements for the ACM survey are dictated by the regulations and safety precautions
required, as discussed in Section A.6. The deliverables will be a written ACM abatement report
with sample results.

The lead-based paint sampling involves a visual inventory, followed by a field analysis, and
collecting and analyzing suspect lead-based paint. Minimum sample requirements for the lead-
based paint survey are dictated by the regulations and safety precautions required, as
discussed in Section A.6. The deliverables will be a written report with sample results.

Subslab, crawl space, and indoor air samples will be analyzed for VOCs. Figure 2 shows a map
with building and well locations. Sample results will be compared to IHSB Residential Vapor
Intrusion Screening Levels (February 2012). Summary of field activities and analytical results
will be submitted.

It is not anticipated that out of the ordinary communication or instructions will need to occur
between the field staff/contractor and the laboratory.

B-2. Sampling & Analytical Method Requirements

Appendix 1, on a separate CD, provides laboratory standard operating procedures, while
Appendix 2, on a separate CD, contains typical method detection, reporting, and control limits
relevant to the scope of work described in this Addendum.

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ACM Sampling

Asbestos sampling will be performed by an appropriately trained State licensed and/or AHERA
certified ACM inspector. The sampling protocol is modeled after 40 CFR 61, 40 CFR 763.86,
and 29 CFR 1926.1101.

ACM Sample Documentation

For asbestos samples collected during the abatement, a unique identification number will be
employed. Samples will be collected by carefully removing small portions of the suspect
material with a sharp knife or other hand tool suitable for the material being sampled. Each
sample will be placed in a labeled container immediately after collection. Sample containers will
then be transported to the laboratory. Data pertinent to each sample (e.g., date, sample
number, material description, and material category) will be recorded on a field data sheet.

ACM Sample Chain-of-Custody Forms

All sample shipments will be accompanied by a chain-of-custody (COC) record to document
sample collection and shipment to the laboratory for analysis. COC form(s) will be completed
and sent with the samples for each shipment. The COC form will identify the contents of each
shipment and maintain the custodial integrity of the samples. Generally, a sample is considered
to be in someone's custody if it is either in someone's physical possession, in someone's view,
locked up, or kept in a secured area that is restricted to authorized personnel. Until the samples
are delivered to the laboratory, the custody of the samples will be the responsibility of the ACM
survey contractor. The sampling team leader or designee will sign the chain-of-custody form in
the "relinquished by" box and note date and time.

ACM Decontamination Procedures

After each sample is collected the sampling instrument will be wiped with a clean moist cloth to
decontaminate the tool and minimize the potential release of asbestos fibers or contamination of
subsequent samples. A new clean cloth will be used for each decontamination to avoid cross-
contamination.

ACM Laboratory Methods

Asbestos bulk samples, copies of field data sheets, and chains-of-custody will be delivered to a
National Voluntary Laboratory Accreditation Program (NVLAP) accredited laboratory for
asbestos analysis (IATL, NVLAP Lab Code 101165-0). As specified in 40 CFR Chapter I Part
763, Subpart F, Appendix A, each ACM sample will be analyzed using Polarized Light
Microscopy (PLM) with dispersion staining techniques, in accordance with EPA Method 600/R-
93/116. The method involves testing of bulk building materials for asbestos by performing a
visual estimation. This method is the most widely used method for estimating asbestos in bulk
building materials. However, it might require a more detailed method like point counting or TEM
for accurate estimation of asbestos in samples with low asbestos concentration. The method
separates the sample material into various layers based on their morphology and then detects
for the presence of the different asbestos fibers in each of these layers. The detection limit for

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this type of analysis is approximately one percent (by volume). Materials containing more than
one percent asbestos are considered to be ACM. Select samples may be analyzed by point
count methods to further quantify the asbestos contents.

Should they be necessary, air clearance samples will be collected and analyzed per OSHA 29
CFR 1926.1101, Appendices A and B.

The actual number of ACM or air clearance samples to be collected and locations will be
determined in the field. A specific sampling and analysis plan or table is not considered
necessary, since site conditions will dictate sampling requirements. Enough laboratory supplies
will be ordered to accommodate whatever sampling is needed. Such an approach allows
flexibility to meet field requirements, based on assessment results, and is in accordance with
the EPA Triad methodology.

Subslab Vapor Sampling

Subslab vapor samples will be collected from immediately beneath the concrete slabs inside the
building (Figure 2). Samples will be collected using laboratory provided certified summa
canisters and controllers. At each subslab location, a hammer rotary drill will be used to bore
through the concrete slab. A sampling probe, connected to inert 0.170 x 1/4-inch polyethylene
tubing will be installed in the borehole approximately two inches or less below the slab material.
Porous, inert backfill material will be utilized to cover approximately one inch of the probe tip
and sealed in place using continuously-hydrated non-VOC-containing bentonite.

To remove dead air, one to three volumes (the volume of the sample probe and the tube) must
be purged prior to collecting the samples. The number of purge volumes removed will be kept
the same at all sample locations. Using a peristaltic pump, a vacuum will be applied to the soil
at the minimum flow rate necessary to collect the sample. Flow rates for purging and sampling
must not exceed 200 milliliters per minute in order to minimize ambient air intrusion.

Following the removal of the dead air, the tubing will immediately be connected to the 1-liter
summa canister for collection. Each summa canister identification number, its respective
canister sampler identification number, the start time, and the starting summa canister vacuum
must be recorded. Similarly, the end time and the end summa canister vacuum must be
recorded. The samples will be transported under chain-of-custody protocol to the laboratory for
analysis. Following the collection of the subslab vapor samples, each sample location will be
backfilled with bentonite to grade and hydrated to seal the hole. Surfaces will be finished with
concrete.

Indoor Air and Outdoor Ambient Air Sampling

Crawl space samples will be collected within approximately one foot of the soil floor. Indoor air
samples will be collected from the breathing zone, three to five feet above the floor and
immediately adjacent to subslab samples described above, where collected. The sample will be
collected using a 6-liter summa canister with a flow controller. For the indoor air samples, the
flow will be regulated to provide a constant flow rate into the canister over a 24-hour sampling
period.
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Each summa canister identification number, its respective canister sampler identification
number, the start time, and the starting summa canister vacuum will be recorded. Similarly, the
end time and the end summa canister vacuum will be recorded. Personnel will evacuate the
immediate area of the sampling device during sample collection. Indoor and outdoor air
temperature and barometric pressure will be recorded at the beginning, middle, and end of
indoor air sampling. The outdoor air sample will be collected onsite and upwind of the office
building. Wind direction, speed, weather conditions, and indoor ventilation conditions will also be
recorded during the sampling event.

In accordance with the United Sates Environmental Protection Agency Guidelines, a duplicate
sample will be collected alongside one of the indoor air samples to evaluate the repeatability of
indoor air sample collection. At the analytical laboratory, a duplicate sample will be obtained
from the same canister as one of the indoor air samples, to evaluate repeatability of the
laboratory analysis.

Immediately after collection the final pressure will be added to the canister label. The canisters
and regulator apparatus will then be wrapped in bubble wrap or similar padding, placed in boxes
and shipped via Federal Express (FedEx®) to Air Toxics, Ltd., located in Folsom, CA to be
analyzed for VOCs within the 30-day hold time using U.S. EPA Method TO-15.

B-3. Sample Handling & Custody Requirements

Sample handling and custody requirements are provided in the Generic QAPP.

B-4. Analytical Methods & Requirements

Analytical methods specific to this project are given in Section B-2.

B-5. Field Quality Control Requirements

General field quality control requirements are discussed in the Generic QAPP, in appropriate
USEPA and OSHA asbestos regulations, and in US Department of Housing and Urban
Development Guidelines for the Evaluation and Control of Lead-Based Paint Hazards in
Housing. Furthermore, when sampling subslab and/or indoor air, there are a few additional
precautions to take to ensure the quality of the field sample.

To obtain data that is defensible and reproducible, the following quality assurance and quality
control measures will be utilized during the sampling event. A new boring will be advanced for
the collection of each subslab sample to minimize the potential of short-circuiting with ambient
air or cross contamination between soil units. Drill equipment that come in contact with the
sample boring will be decontaminated between sample locations. New nylon tubing will be
utilized at each boring for the collection of a subslab sample. Tubing will not be reused. Field
personnel will don gloves when collecting samples and/or handling sample tubing or fittings and
flow chokes.

At each sample location, a sampling canister will be used to collect the air sample. The fittings
and flow chokes used to fill the canister will be dedicated to that sample and will not be reused
between samples. The laboratory will supply the sampling canisters and fittings. This equipment
will be decontaminated by the laboratory prior to use at the site. The laboratory tests each

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canister and fitting to confirm that the equipment has been properly decontaminated prior to
use, and that fittings and chokes are intact, without leaks. The laboratory maintains laboratory
data confirming that the sampling equipment utilized was properly decontaminated in
accordance with EPA protocol. This data will be provided in the report, along with the sampling
results. In addition, to confirm that the results are both reproducible and representative, one
blind duplicate sample will be collected at a selected location per day for each 20 samples
collected.

In the field, a tracer gas such as helium will be used during the collection of the subslab
samples to confirm that there are no leaks in the sampling apparatus. This will also confirm that
there was no ambient air entering the sample due to the presence of a microannulus that
extends from the sample interval below grade to the ground surface. The sampling apparatus
will be enclosed using a plastic sheet which is sealed at the base using a bentonite slurry. The
background concentrations of volatile compounds surrounding the sampling apparatus and the
nylon tubing that extends down the GeoProbe® boring will be measured using a Flame-
Ionization Detector (FID) or a Photo-Ionization Detector (PID) with a 11.7eV lamp (to detect
chlorinated hydrocarbons). The tracer gas will then be released in the enclosure. While the
nylon tubing is being purged of dead air prior to filling the sampling canister, the dead air will be
tested in the field for the presence of the tracer gas using the FID/PID. Elevated FID/PID
readings from the dead air volume may indicate a leak in the system. If the tracer gas is
detected in the field, the sample tubing will be secured and the seal around the tubing and will
be secured with the addition of more bentonite and/or water at the surface. In addition, the
laboratory will analyze the subslab sample for the tracer gas to determine if the gas is present,
and if a leak occurred when the sample was collected that was not detected using the FID/PID.

To confirm that leakage to the sampling canister did not occur during transport, the vacuum
present in the sampling canister will be measured in the field once the sample has been
collected. The vacuum in the canister will be measured again by the laboratory upon receipt.
The sampling canister will not be filled to capacity in the field so that a minimal amount of
vacuum remains. This will keep the COCs from precipitating onto the interior canister walls.

B-6. Laboratory Quality Control Requirements

Laboratory quality control requirements in general are covered in the Generic QAPP.
Requirements contained in appropriate USEPA and OSHA asbestos regulations will also be
followed. PLM quality assurance/quality control is described in Section 3.0 of EPA 600/R-
93/116. Vapor Intrusion sample quality is addressed in NCDENR IHSB’s Supplemental
Guidelines for the Evaluation of Structural Vapor Intrusion Potential for Site Assessments and
Remedial Actions Under the Inactive Sites Branch. The laboratory’s Standard Operating
Procedures, relevant to this Addendum, are provided on a CD as Appendix 1.

B-7. Field Equipment & Corrective Action

Field equipment and corrective action requirements are covered in the Generic QAPP. Specific
to this Addendum, the following field equipment will be used during the field activities:
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• Asbestos and/or Lead-based paint inspector’s kit:
o Hammer, needle nose pliers, screwdriver, paper towels, spray bottle, sponges,
box cutter, small ax or chisel, spray adhesive, caulk/spackling for patch, duct
tape, ladder
• Decontamination materials (Alconox or equivalent and deionized water)
• 6-liter and 1-liter polished stainless steel SUMMATM canisters (cleaned, batch certified,
and evacuated)
• Air regulator, vacuum gauge, Swagelok® fittings
• Paper towels
• Ziploc bags
• Sharpies
• Field Book
• Nitrile gloves
• Safety glasses
• Hard hat, if required
• Camera
• Tyvek (if needed)
• Packing tape
• Site-specific Health & Safety Plan
• Ice as needed

B-8. Lab Equipment & Corrective Action

Laboratory equipment and corrective action requirements are those provided in the Generic
QAPP and those necessary to be in accordance with EPA Method 600/R-93/116 on PLM
techniques.

B-9. Analytical Sensitivity & Project Criteria

Analytical sensitivity and project criteria are in accordance with EPA Method 600/R-93/116 for
PLM and with the Generic QAPP. The appropriate laboratory method detection, reporting, and
control limits are provided on a separate CD as Appendix 2. These limits should be used only
for reference, since they may change depending on sample or other conditions at the time of
analysis.

B-10. Data Management & Documents

Addendum 1.A provides site-specific information not included in the Generic QAPP, e.g., the
name of the laboratories and other subcontractors to be used, the laboratory SOPs for
confirmatory sampling, method detection, and reporting limits pertinent to this site-specific
QAPP, and a list of field sampling equipment.

C-1. Assessments & Response Actions

Information and protocols on assessments and response actions are provided in the Generic
QAPP and in Section 3.0 of EPA 600/R-93/116 for asbestos sampling/analysis.
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C-2. Project Reports

Upon completion of the project, the following documentation will be submitted in reports for the
vapor intrusion sampling:

1. Discussion of site background;
2. Discussion of field procedures used;
3. Summary of sample results;
4. Tables and figures, as appropriate, showing sample locations and results;
5. Copies of all chain of custody forms; and,
6. Analytical reports

Copies of draft reports will be forwarded to Chatham Mill Ventures, LLC for review. Upon receipt
of comments, AMEC will finalize the reports for submittal to EPA and the appropriate North
Carolina agency. Sampling data for ACM and lead based paint results will follow the same
general format.

The sampling and report information developed from this site-specific QAPP Addendum is a
single occurrence and does not represent modifications or additions that need to be tracked or
incorporated into the generic QAPP.

D-1. Field Data Evaluation

General discussion of field data evaluation is provided in the Generic QAPP. Data from the
confirmatory and ACM sampling at the Site will be tabulated and compared to appropriate state
and federal criteria.

D-2. Laboratory Data Evaluation

General discussion of laboratory data evaluation is provided in the Generic QAPP. Data from
the confirmatory and ACM sampling at the Site will be tabulated and compared to appropriate
state and federal criteria. Generic data qualifiers used by the laboratory in case narrative reports
will be addressed in final reports.

D-3. Data Usability and Project Evaluation

Data evaluation for the confirmatory and ACM sampling at the Site is a single occurrence and
does not represent modifications or additions that need to be tracked or incorporated into the
generic QAPP.

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References

MACTEC Engineering and Consulting, inc., Generic Quality Assurance Project Plan: EPA
Brownfields Activities, Conducted Under EPA Brownfields Cooperative Agreements:
BF95408408, BF95405608, and BF96413504. June 2010.

MACTEC Engineering and Consulting, Inc., Report of Limited Soil and Groundwater
Assessment, Twin City Industrial Center, 800 Chatham Road, Winston-Salem, North Carolina,
January 2009.

MACTEC Engineering and Consulting, Inc., Report of Phase I and II Environmental Site
Assessment, Twin City Industrial Center, 800 Chatham Road, Winston-Salem, North Carolina,
May 2007.

NCDENR, DWM, IHSB. Supplemental Guidelines for the Evaluation of Structural Vapor
Intrusion Potential for Site Assessments and Remedial Actions Under the Inactive Sites Branch.
21 June 2011.

Soil Survey Staff, Natural Resources Conservation Service, United States Department of
Agriculture. Web Soil Survey. Available online at http://websoilsurvey.nrcs.usda.gov/. Accessed
[06/12/2012].

US Department of Housing and Urban Development. Guidelines for the Evaluation and Control
of Lead-Based Paint Hazards in Housing. Chapter 7: Lead-Based Paint Inspection. 1997
Revision.

USEPA, 1993. Method for the Determination of Asbestos in Bulk Building Materials. EPA/600/R-
93/116, July 1993.

USEPA Region 4, Brownfields Quality Assurance Project Plans (QAPPs), Interim Instructions,
Generic QAPP & Site-Specific QAPP Addendum for Brownfields Site Assessments and/or
Cleanups, Revision No. 3, July 13, 2010.

FIGURES