HomeMy WebLinkAbout23045 Acme Spinning Mill Brownfields Assessment Work Plan 20200109
Via Email
January 9, 2020
NCDEQ – Division of Waste Management
Brownfields Program
1646 Mail Service Center
Raleigh, NC 27699-1646
Attn: Mr. Bill Schmithorst, PG
Re: Brownfield Assessment Work Plan
Acme Spinning Mill
Belmont, North Carolina
Brownfields Project No. 23045-19-036
H&H Project No. BMT-001
Dear Bill:
On behalf of Belmont Industrial, LLC, please find the enclosed Brownfields Assessment Work
Plan for the Acme Spinning Mill Brownfields property (Brownfields Project No. 23045-19-036)
located in Belmont, Gaston County for your review and approval.
Should you have any questions or need additional information, please do not hesitate to contact
me at (704) 586-0007.
Sincerely,
Hart & Hickman, PC
Steve Hart, PG Ralph McGee, PG
Principal Hydrogeologist Project Manager
Enclosure
cc: Mr. Scott Bortz, Belmont Industrial, LLC (Via Email)
i
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Brownfields Assessment Work Plan
Acme Spinning Mill
Woodlawn Street and Cason Street
Belmont, North Carolina
H&H Job No. BMT-001
Table of Contents
1.0 Introduction .............................................................................................................................1
1.1 Background ............................................................................................................................1
1.2 Previous Assessment Activities .............................................................................................2
2.0 Brownfields Assessment Activities ........................................................................................5
2.1 Soil Sampling Activities ........................................................................................................5
2.2 Soil Vapor Sampling Activities .............................................................................................6
2.3 Quality Assurance – Quality Control ....................................................................................8
2.4 Investigation Derived Waste .................................................................................................9
2.5 Reporting ...............................................................................................................................9
List of Figures
Figure 1 Site Location Map
Figure 2 Site Map
Figure 3 Proposed Sample Location Map
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Brownfields Assessment Work Plan
Acme Spinning Mill
Woodlawn Street and Cason Street
Belmont, North Carolina
H&H Job No. BMT-001
1.0 Introduction
On behalf of Belmont Industrial, LLC (the Prospective Developer or PD), Hart & Hickman, PC
(H&H) is providing this Brownfields Assessment Work Plan (Work Plan) outlining proposed
soil and soil vapor sampling activities at the Acme Spinning Mill Brownfields property
(Brownfields Project No. 23045-19-036) located at 182 Woodlawn Street and 667 Cason Street
in Belmont, Gaston County, North Carolina (Site). The Site consists of two adjacent parcels
(Parcel Identification Nos. 3585994581 and 3585996351) separated by a north-south trending
railroad corridor. The two Site parcels total approximately 41 acres of undeveloped land and are
located in a mixed residential and commercial use area in North Belmont approximately
one-mile north of Interstate 85. A Site location map is provided as Figure 1, and the Site and
surrounding area are shown in Figure 2.
The PD plans to redevelop the Site with one approximately 395,600 square foot (sq ft) industrial
warehouse building in the western and central portions of the Site and one approximately
188,700 sq ft industrial warehouse building in the eastern portion of the Site. Redevelopment
activities will also include installation of new paved access drives, parking areas, and landscaped
areas. The proposed redevelopment plans are shown in Figure 3.
1.1 Background
By the late 1910s, portions of the Site located west of the railroad corridor were developed with
multiple single-family residences and the Acme Spinning Company cotton textile mill facility.
Acme Spinning Company operated the textile mill from construction until the mid-1980s.
Parkdale Mill occupied the mill facility for yarn spinning operations from the mid-1980s until
approximately 2002. The mill buildings and single-family residences were razed by 2006 and
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the Site has remained undeveloped land since that time. The approximate footprints of the
former residences and mill facility buildings are shown in Figure 2.
Portion of the Site located east of the railroad corridor have historically consisted of undeveloped
land. In 2015, a gravel covered equipment staging and parking area for the railroad was
constructed in the in eastern portion of the Site.
1.2 Previous Assessment Activities
ECS Southeast, LLP (ECS) completed Phase I Environmental Site Assessment (ESA) activities
for the western portion of the Site in September 2014. The results of the Phase I ESA identified
the following environmental concerns in connection with the western portion of the Site:
Historical uses in western portions of Site have included textile mill operations including
Acme Spinning Mill and Parkdale Mills. ECS considered the potential for impact
associated with uses of dyes and solvents as part of historical textile mill operations to
represent an environmental concern for the Site and recommended additional assessment.
A release to soil was discovered at the Site in 1992 (Incident No. 16354) during closure
activities associated with an approximately 10,000-gallon heating oil underground
storage tank (UST). Following completion of assessment activities conducted in 2007,
the North Carolina Department of Environmental Quality (DEQ) issued a No Further
Action (NFA) letter dated October 30, 2007 and closed the incident. Based on the
regulatory closed status of the release incident with no restrictions, ECS identified the
1992 UST incident as a Historical Recognized Environmental Condition and no further
assessment was recommended.
Following Phase I ESA activities, ECS completed limited soil and groundwater assessment
activities at the Site in October 2014. ECS advanced four (4) soil borings (B-1 through B-4)
within the footprint of former mill buildings and collected a soil sample for laboratory analysis
from each boring to evaluate the potential for impacts associated with historical milling
operations. In addition to the soil sampling activities, three temporary groundwater monitoring
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wells were installed within the borings and groundwater samples (B-1GW, B-3GW, and
B-4GW) were collected for laboratory analysis to evaluate subsurface conditions. The soil and
groundwater samples were submitted for analysis of volatile organic compounds (VOCs) and
semi-VOCs (SVOCs). The October 2014 soil and groundwater assessment activities are
documented in ECS’s Limited Soil and Groundwater Assessment report dated October 20, 2014.
The locations of the ECS soil borings are shown in Figure 3, and a brief summary of the
sampling results is provided below.
Laboratory analytical results for soil samples B-1 and B-3 indicated that low levels of
polynuclear aromatic hydrocarbons (PAHs) including benzo(a)anthracene (up to 2.1
milligram per kilogram [mg/kg]), benzo(a)pyrene (up to 1.8 mg/kg),
benzo(b)fluoranthene (up to 2.1 mg/kg) , dibenzo(a,h)anthracene (up to 0.24 J mg/kg),
and indeno(1,2,3-cd)pyrene (up to 1.2 mg/kg) were detected at concentrations exceeding
the DEQ Inactive Hazardous Sites Branch (IHSB) Preliminary Soil Remediation Goals
(PSRGs). No other compounds were detected at concentrations exceed the IHSB PSRGs
in the soil samples.
Groundwater sample results indicated that the chlorinated solvents tetrachloroethylene
(PCE; 250 microgram per liter [µg/L]) and trichloroethylene (TCE; 5.4 µg/L) were
detected in groundwater sample B-4GW at concentrations exceeding the North Carolina
15A NCAC 2L Groundwater Quality Standards (2L Standards) and DEQ Division of
Waste Management (DWM) Non-Residential Vapor Intrusion Groundwater Screening
Levels (GWSLs). No other compounds were detected at concentrations above the 2L
Standards or Non-Residential GWSLs in the groundwater samples.
In December 2014, H&H conducted soil and soil vapor sampling activities at the Site to further
evaluate impacts associated with historical textile milling operations. H&H collected nine (9)
soil samples for laboratory analysis from seven (7) soil borings (HHSB-1 through HHSB-7) in
the vicinity of former mill buildings. The soil samples were submitted for VOC and PAH
analysis. In addition to soil sampling activities, H&H installed four (4) permanent soil vapor
monitoring points (VMP-1 through VMP-4) and collected soil vapor samples for laboratory
analysis to evaluate the potential for structural vapor intrusion into future buildings. The soil
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vapor samples were submitted for laboratory analysis of PCE, TCE, 1,1-dichloroethene (DCE),
and vinyl chloride based on results of the previous groundwater assessment activities. The soil
and soil vapor assessment activities are documented in a Phase II ESA report prepared by H&H
and dated January 19, 2015. The December 2014 soil borings and permanent soil vapor
monitoring points are shown in Figure 3, and a brief summary of the sampling results is provided
below.
Laboratory analytical results for shallow soil samples HHSB-2 (0-2 ft), HHSB-3 (0-2 ft),
and HHSB-7 (2-4 ft) indicated that low levels of PAHs including benzo(a)anthracene (up
to 5.53 mg/kg), benzo(a)pyrene (up to 4.22 mg/kg), benzo(b)fluoranthene (up to 3.81 J
mg/kg), benzo(k)fluoranthene (up to 4.37 mg/kg), and indeno(1,2,3-cd)pyrene (up to 2.25
J mg/kg) were detected at concentrations exceeding IHSB PSRGs. No other compounds
were detected at concentrations above the IHSB PSRGs in the soil samples.
Soil vapor sampling results indicated that low levels of PCE (up to 13 micrograms per
cubic meter [µg/m3]) were detected in each of the four soil vapor samples at
concentrations well below the DWM Non-Residential Vapor Intrusion Sub-Slab and
Exterior Soil Gas Screening Level (SGSL) of 3,500 µg/m3. In addition, trace levels of
TCE (up to 0.40 J µg/m3) were detected in two of the four soil vapor samples at
concentrations well below the Non-Residential SGSL of 180 µg/m3. No other
compounds were detected at concentrations above the laboratory reporting limits in the
soil vapor samples.
To address environmental impacts identified during previous assessment activities, the PD
entered the Site into the DEQ Brownfields Redevelopment Now Program and received eligibility
in a letter dated August 27, 2019. Following review of available environmental assessment
reports and the proposed redevelopment plans for the Site, the DEQ Brownfields Program
requested that additional soil and soil vapor assessment activities be completed at the Site in an
email dated October 16, 2019. This Work Plan has been prepared to address the DEQ
Brownfields Program request for additional assessment. The proposed Brownfields assessment
activities are outlined in the following sections.
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2.0 Brownfields Assessment Activities
H&H proposes to complete additional soil and soil vapor assessment activities at the Site to
further evaluate the potential for impacts and to assist in management of Site media during
proposed redevelopment activities. The proposed assessment activities will be performed in
general accordance with the DEQ IHSB Guidelines for Assessment and Cleanup (Guidelines)
dated October 2015, the DEQ DWM Vapor Intrusion Guidance (VI Guidance) dated March
2018, and most recent versions of the U.S. Environmental Protection Agency (EPA) Region IV
Science and Ecosystem Support Division (SESD) Field Branches Quality System and Technical
Procedures guidance.
Prior to conducting field activities, H&H will contact North Carolina 811, the public utility
locator, to mark subsurface utilities located on the Site. H&H will also contract with a private
utility locator to screen proposed sample locations for subgrade utilities that would not be
marked by the public locator. Additionally, soil boring locations will be hand cleared to
approximately 5 feet (ft) below the ground surface (bgs) prior to use of mechanical drilling
equipment to further screen the boring locations for the presence of subsurface utilities.
2.1 Soil Sampling Activities
H&H proposes to advance four (4) shallow soil borings in the vicinity of previous soil borings
HHSB-2, HHSB-3, HHSB-4, and HHSB-7 and collect soil samples for laboratory analysis from
each boring. In addition, H&H proposes to collect five (5) composite soil samples for laboratory
analysis from twenty-five (25) soil borings advanced in the areas of former residences located in
the northern and western portions of the Site. The proposed soil borings locations are shown in
Figure 3.
H&H will advance soil borings in the areas of previous soil borings HHSB-2, HHSB-3,
HHSB-4, and HHSB-7 to an approximate depth of 5 feet below ground surface (ft bgs) with a
decontaminated stainless-steel hand auger. Continuous soil samples will be collected from each
boring from the center of the hand auger bucket. During boring advancement, soil samples will
be logged for lithological description and field screened for indication of potential impacts by
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observation for staining, unusual odors, and the presence of organic vapors using a calibrated
photoionization detector (PID).
H&H will collect a soil sample from the 2 to 4 ft bgs depth interval from each soil boring. Soil
samples selected for laboratory analysis will be placed directly into dedicated laboratory supplied
sample containers, labeled with the sample identification, date, and requested analysis, and
placed in a laboratory supplied cooler with ice. Soil samples will be submitted to a North
Carolina certified laboratory under standard chain of custody protocols for analysis of Resource
Conservation and Recovery Act (RCRA) metals plus hexavalent chromium by EPA Methods
6020/7471/7199.
Soil samples selected for composite sampling will be collected from the 0 to 1 ft bgs depth
interval. Five aliquot soil samples will be collected at each composite soil sample location to
represent shallow soil conditions near former residences. The aliquot soil samples from each
composite soil sample location will be combined and homogenized to form one composite soil
sample for a total of five (5) composite soil samples. Composite soil samples will then be placed
directly into dedicated laboratory supplied sample containers, labeled with the sample
identification, date, and requested analysis, and placed in a laboratory supplied cooler with ice.
Two (2) of the composite soil samples will be submitted to a North Carolina certified laboratory
under standard chain of custody protocols for analysis of RCRA metals plus hexavalent
chromium by EPA Methods 6020/7471/7199. The remaining three (3) composite soil samples
will be analyzed for lead by EPA Method 6020.
Following soil sampling activities, the soil borings will be properly abandoned and the surfaces
will be repaired similar to pre-drilling conditions. Additionally, the soil sample locations will be
estimated using a global positioning system (GPS) unit.
2.2 Soil Vapor Sampling Activities
H&H proposes to conduct additional soil vapor assessment activities at the Site to further
evaluate the potential for structural vapor intrusion into the proposed industrial buildings. H&H
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will collect a soil vapor sample for laboratory analysis from each of the four existing permanent
soil vapor monitoring points (VMP-1 through VMP-4). In addition, H&H will advance three soil
borings for installation of temporary soil vapor monitoring points in the south-central (TVMP-1)
and eastern (TVMP-2 and TVMP-3) portions of the Site. The existing soil vapor monitoring
points and proposed temporary soil vapor monitoring point locations are shown in Figure 3.
For installation of the temporary soil vapor monitoring points, H&H will contract with a North
Carolina certified drilling subcontractor to advance soil borings to approximately 10 to 15 ft bgs
utilizing a track-mounted direct-push technology (DPT) drill rig. After advancing the soil
borings to depth, a six-inch stainless-steel screen point fitted with ¼-inch diameter Teflon®
tubing will be installed to the base of each borehole. Filter sand will be placed from the base of
the boring to six inches above the screened interval. The sampling points will be completed by
placing hydrated bentonite from the top of the filter sand to the ground surface.
The permanent and temporary soil vapor monitoring points will each be purged by removing
approximately three (3) sample train volumes of air using a syringe with a purge rate no greater
than 200 milliliters per minute (mL/min). The Teflon® sample tubing will then be connected to
laboratory supplied 6-Liter Summa canisters with laboratory supplied airflow regulators using a
brass nut and ferrule assemblies to create an air tight seal. The airflow regulators will be
calibrated by the laboratory to allow the Summa canisters to fill slowly at a rate of approximately
100 mL/min.
Once the sample train is assembled, leak checks will be completed prior to collection of the soil
vapor samples. The leak check will be performed by first placing a shroud over each sample
point including the completed sample train, flooding the shroud with helium gas, and using a
calibrated helium gas detector to measure helium concentrations within the shroud. With helium
concentrations maintained at approximately 30% within the shroud, the sample tubing will be
purged outside of the shroud using a syringe and a three-way valve to collect purged soil vapor
into a Tedlar® bag. The purged vapor will then be analyzed using the helium gas detector to
ensure that helium concentrations from the sample tubing are less than 10% of the helium
concentrations measured within the shroud.
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Following successful leak checks, the intake valve on the sample canister will be fully opened to
begin collection of the soil vapor sample. Vacuum readings on the Summa canister will be
recorded prior to and following the sample period to ensure adequate sample volume was
collected. A vacuum will be maintained within the canisters at the conclusion of the sampling
event.
After completion of sampling, the intake valve will be closed and the regulator will be
disconnected from the sample canister. The starting and ending vacuum in each canister will be
recorded on the chain-of-custody and submitted to the laboratory along with the samples. The
Summa canisters will then be packaged and shipped to the laboratory under standard chain of
custody protocols for analysis of VOCs by EPA Method TO-15. Following sampling activities,
the temporary soil vapor monitoring points will be properly abandoned and the surfaces will be
repaired similar to pre-drilling conditions. Additionally, the temporary soil vapor sample
locations will be estimated using a GPS unit.
2.3 Quality Assurance – Quality Control
Non-dedicated equipment and tools will be decontaminated prior to use at each boring or
sampling location or following exposure to soil. The following samples will be collected for
quality assurance/quality control (QA/QC) purposes:
One duplicate soil sample will be collected and analyzed for the same parameters as the
parent sample.
One duplicate soil vapor sample will be collected using a laboratory supplied T-fitting
which allows for collection of two samples from one soil vapor monitoring point
simultaneously. The duplicate soil vapor sample will be analyzed for VOCs by EPA
Method TO-15.
Laboratory QA/QC procedures will be employed to ensure appropriate sample handling and
analysis and to aid in the review and validation of the analytical data. QA/QC procedures will be
conducted in accordance with the method protocols and will include regular equipment
maintenance, equipment calibrations, and adherence to specific sample custody and data
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management procedures. Samples will be analyzed in conjunction with appropriate blanks,
laboratory duplicates, continuing calibration standards, surrogate standards, and matrix spiking
standards in accordance with approved methodologies to monitor both instrument and analyst
performance. Laboratory reporting limits for each analyte will be at or below appropriate
screening criteria, where possible. Additionally, H&H will request that the laboratory include
estimated concentrations for compounds that are detected at levels above the laboratory method
detection limit, but below the laboratory reporting limit (J flags).
The laboratory analytical data report and QA package for each group of samples submitted to
and analyzed by the subcontracted laboratory will be provided in an appendix to the final report.
Laboratory QA data consistent with Level II documentation will be provided for this project.
A copy of the completed chain-of-custody record and shipping receipt will be appended to the
corresponding laboratory analytical report included with the final report.
2.4 Investigation Derived Waste
Investigation derived waste (IDW) generated during the proposed assessment activities will be
managed in general accordance with DEQ IHSB Guidelines. IDW generated during the
assessment activities will be thin spread on-Site. However, if significant impacts are suspected
(i.e., elevated PID readings, free-product, etc.) soil cuttings will be containerized in 55-gallon
drums and staged on-Site pending analytical results of a composite IDW sample. Based on
laboratory analytical results of IDW samples, the drums will be transported off-Site to a suitable
facility for disposal.
2.5 Reporting
Following completion of the assessment activities and receipt of the analytical data, H&H will
document our findings in a Brownfields assessment report. The report will include a description
of the sampling activities, a figure depicting sample locations, soil boring logs and temporary
soil vapor monitoring point construction details, laboratory analytical data, a discussion of the
data in comparison to regulatory screening levels, and conclusions and recommendations
concerning our activities. DEQ risk calculators may also be used as appropriate.
TITLE
PROJECT
SITE LOCATION MAP
ACME SPINNING MILL
WOODLAWN STREET AND CASON STREET
BELMONT, NORTH CAROLINA
DATE:
JOB NO:
REVISION NO:
FIGURE NO:
11-15-2019 0
1BMT-001
0 2000 4000N
APPROXIMATE
SCALE IN FEET
U.S.G.S. QUADRANGLE MAP
QUADRANGLE
7.5 MINUTE SERIES (TOPOGRAPHIC)
MOUNT HOLLY, NORTH CAROLINA 2013
SITE
REVISION NO. 0
JOB NO. BMT-001
DATE: 11-20-19
FIGURE NO. 2
ACME SPINNING MILL
WOODLAWN STREET & CASON STREET
BELMONT, NORTH CAROLINA
SITE MAP
LEGEND
BROWNFILEDS PROPERTY BOUNDARY
PARCEL BOUNDARY RAILROAD
FORMER BUILDING FOOTPRINT
2923 South Tryon Street-Suite 100
Charlotte, North Carolina 28203
704-586-0007(p) 704-586-0373(f)
License # C-1269 / #C-245 Geology
CENTERVIEW STREET
JADE
C
I
R
C
L
E
ACM
E
R
O
A
D
WOODLAWN STREET CASON STREETOAKS PARKWAYROPER STREET
NOTES:
1. AERIAL IMAGERY OBTAINED FROM NC ONEMAP (2019).
WILBERT PLASTIC
SERVICES, LLC.
(1000 OAKS PARKWAY)
CARUS CORPORATION, INC.
(181 WOODLAWN STREET)
GOSHEN
PRESBYTERIAN CHURCH
(1380 WOODLAWN STREET)
GREENWAY CHEMICAL
SYSTEMS & SERVICES
(2101 ACME ROAD)
CATAWBA HEIGHTS
BAPTIST CHURCH
(311 BELMONT MT HOLLY ROAD)
SOCKS, INC.
(160 WOODLAWN STREET)S:\AAA-Master Projects\Belmont Industrial\Brownfields Assessment WP\Figures\Site Map.dwg, FIG 2, 11/20/2019 1:36:40 PM
VMP-4
VMP-2
VMP-1
VMP-3
HHSB-2
HHSB-6HHSB-5
HHSB-1
HHSB-3
HHSB-4
HHSB-7
B-3
B-4
B-1
B-2
REVISION NO. 0
JOB NO. BMT-001
DATE: 12-12-19
FIGURE NO. 3
ACME SPINNING MILL
WOODLAWN STREET & CASON STREET
BELMONT, NORTH CAROLINA
PROPOSED SAMPLE LOCATION MAP
LEGEND
BROWNFIELDS PROPERTY BOUNDARY
PARCEL BOUNDARY
RAILROAD
SOIL BORING LOCATION (OCTOBER 2014)
SOIL BORING LOCATION (DECEMBER 2014)
PERMANENT SOIL VAPOR MONITORING
LOCATION
PROPOSED SOIL BORING LOCATION
PROPOSED ALIQUOT SOIL SAMPLE
LOCATION
PROPOSED TEMPORARY SOIL VAPOR
MONITORING POINT
2923 South Tryon Street-Suite 100
Charlotte, North Carolina 28203
704-586-0007(p) 704-586-0373(f)
License # C-1269 / #C-245 Geology
CENTERVIEW STREET
JADE
C
I
R
C
L
E
ACM
E
R
O
A
D (
N
E
W
ALI
G
N
M
E
NT)WO
O
D
L
AW
N
S
T
R
E
E
T CASON STREE
T
OAKS PARKWAYROPER ST
REET
NOTES:
1.SOIL BORINGS B-1 THROUGH B-4 WERE ADVANCED BY
ECS IN OCTOBER 2014.
2.SOIL VAPOR MONITORING POINTS VMP-1 THROUGH
VMP-4 WERE INSTALLED AND SAMPLED BY H&H IN
DECEMBER 2014.
3.SOIL SAMPLES HHSB-1 THROUGH HHSB-7 WERE
COLLECTED BY H&H IN DECEMBER 2014.
4.PROPOSED REDEVELOPMENT PLAN WAS PREPARED BY
FRANK CRAIG AND PROVIDED BY THE PROSPECTIVE
DEVELOPER.
TVMP-1
TVMP-3
TVMP-2
COMP-1
COMP-2
COMP-3
COMP-4
COMP-5
S:\AAA-Master Projects\Belmont Industrial\Brownfields Assessment WP\Figures\Site Map.dwg, 12/12/2019 1:26:08 PM, amckenzie