25094_Mock Judson Mill_ AWP_20230425

SAMPLING WORK PLAN
MOCK JUDSON MILL
2610 OAKLAND AVENUE
GREENSBORO, NORTH CAROLINA
Brownfield Project Number: 25094-21-041

Submitted By
Atlantic Shores Environmental Services, Ltd.
License No. C-4767

April 25, 2023
Revision No. 4
Cheryl Moody, PE
Principal Engineer

Developer: MJM Owner, LLC
[e-mail]
919-433-1568
Consultant: Atlantic Shores Environmental Services Ltd.
[e-mail]
910-371-5980

DEQ Project Manager: Claire Sorrell
[e-mail]
919-707-8245
Sampling Work Plan R4 April 25, 2023
Mock Judson Mill
2610 Oakland Avenue
Greensboro, North Carolina
Brownfield project number: 25094-21-041

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TABLE OF CONTENT
1.0 INTRODUCTION ...................................................................................................................................... 1
1.1 ASSESSMENT HISTORY ..................................................................................................................................... 2
1.2 REDEVELOPMENT PLANS .................................................................................................................................. 4
2.0 SCOPE OF WORK ..................................................................................................................................... 4
2.1 SUB SLAB VAPOR SAMPLES ............................................................................................................................... 4
2. 2 – SOIL GAS SAMPLES ............................................................................................................................................... 5
2.3 SOIL SAMPLES ................................................................................................................................................ 5
2.3.1 Interior Trenching .................................................................................................................................. 5
2.3.2 Exterior Trenching ................................................................................................................................. 5
2.3 GROUNDWATER SAMPLES ................................................................................................................................ 5
2.4 PCB IMPACTED SOIL EXCAVATION ...................................................................................................................... 5
2.5 BROWNFIELD RECEPTORS SURVEY ...................................................................................................................... 6
2.6 POTENTIOMETRIC MAP .................................................................................................................................... 6
3.0 SAMPLING METHODOLOGY .................................................................................................................... 6
3.1 SUB SLAB VAPOR SAMPLES ............................................................................................................................... 6
3.1.1 Port Installation ..................................................................................................................................... 6
3.1.2 Helium Tracer Test ................................................................................................................................ 7
3.2 SOIL GAS SAMPLES ............................................................................................................................................. 8
3.2.1 Port Installation ................................................................................................................................ 8
3.2.2 Helium Tracer Test ............................................................................................................................ 8
3.3 SOIL SAMPLES ................................................................................................................................................ 8
3.4 GROUNDWATER SAMPLES ................................................................................................................................ 9
3.5 PCB IMPACTED SOIL EXCAVATION ...................................................................................................................... 9
3.6 POTENTIOMETRIC MAP .................................................................................................................................. 10
4.0 LABORATORY ANALYSES ....................................................................................................................... 10
4.1 SUB SLAB VAPOR AND SOIL GAS SAMPLES ........................................................................................................ 10
4.2 SOIL AND GROUNDWATER .............................................................................................................................. 10
5.0 QA/QC .................................................................................................................................................. 11
6.0 INVESTIGATION DERIVED WASTE (IDW) MANAGEMENT ....................................................................... 11
7.0 REPORTING ........................................................................................................................................... 11

Tables
1 – Property Summary
2 – Sampling Summary
3 – Historical Soil Data
4 – Historical Groundwater Data
5 – Historical Sub Slab Data

Figures
1 – Site Location Map
2 – Proposed Redevelopment
Sampling Work Plan R4 April 25, 2023
Mock Judson Mill
2610 Oakland Avenue
Greensboro, North Carolina
Brownfield project number: 25094-21-041

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3A – Proposed Sample Location Map
3B – Proposed Sample Location Map
3C – Proposed Sample Location Map
3D – Proposed Sample Location Map
3E – Proposed Sample Location Map
4 – Historical Sampling Location Map

Appendix
A - Laboratory Certifications
B - Checklist
Sampling Work Plan R4 April 25, 2023
Mock Judson Mill
2610 Oakland Avenue
Greensboro, North Carolina
Brownfield project number: 25094-21-041

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1.0 INTRODUCTION

Atlantic Shores Environmental Services, Ltd. (ASE) is pleased to provide this work plan summarizing sampling
activities for the Mock Judson Mill Brownfield site. This work plan has been prepared based on the Assessment
Work Plan Checklist, attached as Appendix B. The site encompasses approximately 8.67 acres (Guilford County
tax parcel No. 0219794) and is addressed as 2610 Oakland Avenue, Greensboro, North Carolina (Refer to Figure
1). The central and northern portions of the subject site are being redeveloped into an apartment complex. The
redevelopment is repurposing the main mill building and the power house into apartments with associated paved
parking, dog walking area and a pool. The southern portion of the site is currently not being redeveloped and is
slated for future development.

The assessment proposed in this work plan is not intended for other DEQ programs. The Prospective Developer
(PD) submitted a Brownfield application for this property on November 8, 2021. The Brownfield letter of
eligibility was received on February 9, 2022. The PD initially intended to pursue the standard track but changed
to the Redevelop Now track on February 1, 2022. The site has historically been involved with DEQ REC and
UST programs.

The PD purchased this site with a shovel ready project. Due to the Brownfield Groups workload and staffing
issues, the assignment of a project manager for this project was delayed beyond the go or no go deadline for the
shovel ready project. The PD opted to move forward with the interior of the redevelopment and conduct additional
assessment that was anticipated to be requested by DEQ. It is our understanding that the PD conducted these
activities at their own risk. This work plan includes work that has recently been conducted as well as additional
work that is pending.

• Demolition - Prior to the PD purchasing the site, the previous owner had gutted the buildings and graded
a portion of the site. The PD does not plan on demolishing structures as part of their redevelopment.
However, the replacement of the roofing systems is currently being conducted. Additional asbestos
containing material was identified in the roofing. The ACM has been abated by a North Carolina licensed
abatement contractor.
• Foundation type for the new construction – Not Applicable - The PD will utilize the existing
foundations. The existing foundations consist of slab on grade with the exception of a small basement in
the c. 1928 section of the mill and the partial subgrade foundation of the boiler room building.
• Re-use of existing structures
• Main Mill Building – Renovate into 165 apartments
• Boiler Room Building – Renovate into eight (8) apartments
• Smoke stack – will remain untouched
• Presence of elevators and stairwells – The new construction will have two (2) elevators and four (4)
stairwells. Elevator pits are 7’2” below the finished floor. The floor is 8 inches thick in the area of the
elevators and 6 inches thick in the areas of the stairwells. The site stairwells will be constructed on slab
grade and will not require excavation.
• How the new building configuration/parking areas relate to the location of contamination at the
Brownfields Property – The parking lots will flank the existing buildings to the north and south. There
are low levels of PCBs in one area along the southern side of the main building near monitoring well
MW-6. This area is in a proposed landscaped area and will be excavated and disposed of off-site as
described in the work plan (Section 2.4).
• Proposed and existing building/unit square footage to be addressed – As it relates to the vapor
intrusion mitigation sampling efforts as described in Sections 2.1 and 2.2. The boiler house is
Sampling Work Plan R4 April 25, 2023
Mock Judson Mill
2610 Oakland Avenue
Greensboro, North Carolina
Brownfield project number: 25094-21-041

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approximately 5,358 square-feet and the basement is approximately 680 square-feet. The main mill
building is approximately 74,769 square-feet.
• The proposed use is under evaluation by the Brownfields Redevelopment Section at the time of this
submittal.

1.1 Assessment History

Historical documents indicate that the site was initially developed as a plant nursery in the early 1900’s. The 1925
Sanborn map illustrates a fumigating house on the site. Mock, Judson, Voehringer began occupying the site in
1927. The mill occupied the initial site structure (east side of the building) at this time. The Mock, Judson,
Voehringer Mill, also known as MoJud Mill, was a hosiery production plant. The mill operated until
approximately 1972. However, a small portion of the building fronting Howard Street was used as a the Rolane
Factory Outlet Store until it closed in 1999. The site has been unoccupied since 1999. The property was listed on
the National Register of Historic Places in 2011.

The site structure was formerly heated with coal, and subsequently, fuel oil was stored in USTs adjacent to the
power house. These tanks have been removed from the site. The site also had a Varsol UST formerly located
south of the mill building.

Potential sources of vapor intrusion on the site include former on-site USTs and potential historic use of solvents
in the boiler house. Documented uses of chlorinated solvents on the site have not been identified.

The Phase I ESA dates December 2, 2021 identified the following recognized environmental conditions (RECs):

• Three fuel oil USTs and one Varsol UST have been removed from the site. Approximately 1,200 tons
of fuel oil impacted soil were excavated from the fuel oil tank pits. However, elevated total petroleum
hydrocarbons remain on the site. The fuel oil tanks were located west of the boiler house. The Varsol
tank was located south of the main mill building.
• Results of recent soil sampling conducted by others indicate that DRO, PAHs, PCB, and arsenic
impacts are present on the site. These impacts are located in various areas of the site.
• Elevated total petroleum hydrocarbons were identified in the groundwater along the southern side of
the mill building, toward the western edge of the building. This elevated TPH has been attributed to
the former presence of transformers in the area by previous consultants.

The scope of work of the following assessment was conducted prior to entrance into the Brownfield
Redevelopment Section with the exception of the boiler room water sampling.

Asbestos was abated from the majority of the structures and the structures were gutted by the former site owner.
However, ASE conducted an asbestos survey of the buildings in January 2022 and discovered remnant asbestos
containing material (ACM) (roofing, window glazing, and thermal system insulation (TSI)). This material was
subsequently abated and will be documented under separate cover.

Historic soil and groundwater assessment of the site has included:

Environmental Reports
Report Prepared by Date
Closure Report for Kayser-Roth
Corporation
Four Seasons
Industrial Service, Inc. September 30, 1991
Phase I Environmental Site Assessment Swift Creek March 23, 2017
Sampling Work Plan R4 April 25, 2023
Mock Judson Mill
2610 Oakland Avenue
Greensboro, North Carolina
Brownfield project number: 25094-21-041

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Environmental, Inc.
Subsurface Investigation Report Swift Creek
Environmental, Inc. May 19, 2017
Phase I Environmental Site Assessment Swift Creek
Environmental, Inc.
April 2, 2020
Boiler Room Water Sampling (November
3, 2021)
Atlantic Shores Environmental
Services Ltd. September 20, 2022
Phase I Environmental Site Assessment
Report
Atlantic Shores Environmental
Services Ltd. December 2, 2021
Phase II Environmental
Assessment/Remediation Investigation
Report
Swift Creek
Environmental, Inc. December 6, 2021

The Brownfields Redevelopment Section letter of eligibility was sent to the Developer on February 9, 2022.

September 1991 (UST Removal) - Three fuel oil USTs and one Varsol UST have been removed from the site.
Approximately 1,200 tons of fuel oil impacted soil was excavated from the fuel oil tank pits. However, elevated
oil & grease remain on the site in this area at a depth of 16-17 feet. Testing from beneath the Varsol tank did not
identify impacts.

May 2017 – Six soil borings, four of which were completed as temporary monitoring wells were advanced at the
site. Chromium was identified in one of the three analyzed samples and lead, silver and TPH- ORO were
identified in one of the three soil samples above residential PSRGs. Benzo(a)anthracene and 1-Methylnaphthalene
were also identified in two of the collected soil samples above residential PSRGs.

Barium, chromium and lead were identified in one of the two groundwater samples that were analyzed for metals
above 2L standards.

Two sub slab soil vapor samples were collected within the main building. Results of the analyses did not identify
VOCs above NCDEQ Residential Sub Slab SCLs (Soil Gas Screening Levels).

November 2021: Two samples were collected from the four foot of water located within the boiler room. These
samples were analyzed for VOCs, SVOCs and RCRA 8 metals. Two volatile organic compounds (VOCs) and
one metal were identified in the samples. However, each identified constituent was below their respective
NCDEQ Groundwater Quality Standards (2L).

December 2021: A total of 32 soil borings were advanced on the property at locations of concern identified
during previous assessment activities. Volatile Organic Compounds (VOCs) were detected in soil samples.
Several PAHs, metals, and PCB congeners were detected at concentrations above Residential PSRGs. A risk
assessment was performed by Swift Creek, which indicated that soil concentrations identified at the site do not
pose an unacceptable risk to a residential receptor under the direct contact soil pathway.

Groundwater investigation activities consisted of installation and sampling of 11 groundwater monitoring
wells at the site. The results of the sampling and analyses did not identify exceedances of the 2L Standards.
Swift Creek preformed a NCDEQ risk evaluation of detected constituents which did not indicate unacceptable
risk for direct contact for a residential receptor.

Sub-slab soil vapor samples were collected from eight locations within the main mill building. Swift Creek
reported naphthalene was detected at a concentration above its Residential SGSL in five of the sub-slab soil gas
samples. However, the July 2022 Residential screening levels identified in the Risk Calculator do not identify
Sampling Work Plan R4 April 25, 2023
Mock Judson Mill
2610 Oakland Avenue
Greensboro, North Carolina
Brownfield project number: 25094-21-041

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naphthalene as having a published screening criteria. A risk assessment was completed by Swift Creek
using the sub-slab soil gas data. The results showed that neither the target carcinogenic risk nor the target hazard
index were exceeded. Based on these results, vapor intrusion into the main building is not anticipated to
pose an unacceptable risk to receptors under a residential use scenario. To evaluate vapor intrusion risk in the boiler
room, and as an additional line of evidence for vapor intrusion risk in the main building, VOC groundwater data
was used to evaluate the potential for vapor intrusion risk. The results indicated that the potential for
vapor intrusion in the main building and boiler room is not anticipated to pose an unacceptable risk to
residential receptors.

Cumulative site-wide risk was calculated by summing the risks associated with the soil direct use, groundwater
direct use, and vapor intrusion pathways. The results indicate that site-wide risks are within allowable risk limits
under a residential use scenario.

Refer to Figure 4 for the historical sampling points and Tables 3, 4 and 5 for a summary of historical data.

Data gaps identified in this sampling included the lack of hexavalent chromium soil and groundwater samples
and a lack of SVOC and VOC analysis from three of the on-site wells.

1.2 Redevelopment Plans

The site buildings are being redeveloped into a 173 unit apartment complex. The existing main mill building is
constructed primarily on a slab. However, a small basement is located in northwest corner of the c.1928 portion
of the building. The boiler room is also constructed on a slab foundation. However, this structure is partially sub
grade and is currently flooded with approximately 4 feet of water. This water was sampled in two locations prior
to the site being admitted to the Brownfield Program. Target constituents above unrestricted use were not
identified in the standing water.

The amenities include a swimming pool (deepest excavation in this area is 6 feet), outdoor lawn and grilling area
and a dog park. Paved parking will be located both north and south of the buildings. The deepest excavation will
be a DOT manhole located at the proposed soil sample SS-15. Temporary stormwater practices will include three
3-foot detention basins and two – Baffle systems with gravity fed skimmers. The final stormwater management
is sheet flow to in line storm drains.

At this time, the Assessment Data is not intended for any other DEQ programs in addition to the Brownfield
Redevelopment Program. Please see the attached Figure 1 (Site Location Map), Figure 2 (Site Development
Plans) and Table 1 (Brownfield Property Information).

2.0 SCOPE OF WORK

Due to the delay in being assigned a Brownfield Project Manager and the time constraints of the existing project,
a portion of the following sampling has been conducted in an attempt to be proactive with the pace of the
redevelopment. Table 2 lists a summary of the collected or proposed samples and Figures 3A through 3E illustrate
the collected or proposed sample locations. The collected samples are marked with a “*” in Table 2. ASE proposes
three (3) sub slab vapor samples, two (2) soil gas samples, 27 soil samples, and nine (9) groundwater samples.

2.1 Sub Slab Vapor Samples

Sampling Work Plan R4 April 25, 2023
Mock Judson Mill
2610 Oakland Avenue
Greensboro, North Carolina
Brownfield project number: 25094-21-041

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ASE will collect one (1) sub slab air sample in the basement and two (2) sub slab samples in the boiler house.
Summa canisters will be used to collect soil vapors from the sampling ports. The sampling will be conducted in
according to the NCDEQ sampling protocols for soil vapor sampling. The samples will be analyzed for the
presence of volatile organics by Method TO-15. See Figure 3E for proposed sampling locations.

2. 2 – Soil Gas Samples

ASE will collect two (2) soil gas samples north of the boiler house, in the approximate locations illustrated on
Figure 4.

2.3 Soil Samples

2.3.1 Interior Trenching

Dur to the contractors schedule these soil samples were collected during select slab removal for the interior utility
trenching. Soil samples were collected on July 15 and 22, 2022 along the utility trenching within the existing slab
foundation, just below the slab using a stainless steel spoon1. The samples were analyzed for volatile (VOC) and
semi volatile compounds (SVOC) by EPA Methods 8260 and 8270, respectively. The samples were also analyzed
for the presence of RCRA 8 metals and chromium VI. Hexavalent chromium was analyzed by EPA Method 7199.
The locations of these samples are illustrated on Figure 3A thru 3D. Table 2 lists the sample identifiers and dates
of collection. The purpose of this sampling is to provide soil data from beneath the building slab in the utility
trenches.

2.3.2 Exterior Trenching

Soil samples will be collected along proposed utility lines at the approximate depth of the excavations using a
GeoprobeÒ. ASE estimates that 5 samples and one duplicate will be collected. The samples will be analyzed for
volatile (VOC) and semi volatile compounds (SVOC) by EPA Methods 8260 and 8270 respectively. The samples
will also be analyzed for the presence of RCRA 8 metals and chromium VI. Hexavalent chromium will be
analyzed by EPA Method 7199. The locations of these samples are illustrated on Figure 3E.

2.3 Groundwater Samples

Groundwater samples were collected from existing monitoring wells MW-2, MW-3, MW-6, MW-7 and MW-8
on July 22, 2022. The samples were analyzed for chromium VI by EPA Method 7199. The Samples from MW-
6, MW-7 and MW-8 were also analyzed for volatile (VOC) and semi volatile compounds (SVOC) by EPA
Methods 8260 and 8270 respectively. Table 2 lists the sample identifiers and dates of collection2.

Groundwater samples from MW-1, MW-2 and MW-3 will be analyzed for RCRA 8 metals. The purpose of this
sampling is to fill in data gaps from the previous sampling conducted by Swift Creek. No samples were analyzed
for hexavalent chromium during Swift Creeks assessment.

2.4 PCB impacted Soil Excavation

1 These samples have previously been collected
2 These samples have previously been collected
Sampling Work Plan R4 April 25, 2023
Mock Judson Mill
2610 Oakland Avenue
Greensboro, North Carolina
Brownfield project number: 25094-21-041

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The PCB impacts identified in SS-1, SS-2 and SS-3 collected by Swift Creek was excavated with a mini excavator.
The excavation sidewalls and base were sampled for the presence of PCB congeners. Table 2 lists the sample
identifiers and dates of collection3.

2.5 Brownfield Receptors Survey

A Brownfields Property Receptor Survey will be completed as part of this scope of work.

2.6 Potentiometric Map

A potentiometric surface map will be generated with data collected from the on-site wells.

3.0 SAMPLING METHODOLOGY

Record the type of material found under the slab or in the soil gas borings.

Record slab thickness for sub slab vapor samples and provide soil boring logs for exterior soil gas samples

3.1 Sub Slab Vapor Samples

Sub slab vapor sampling will be conducted in the basement and boiler house. One sub slab sample will be
collected in the basement and two sub slab samples will be collected from the Boiler house. The type of material
found under the slab will be recorded along with the slab thickness. Figure 3 illustrates the location of the sub
slab vapor sample locations.

3.1.1 Port Installation

The temporary sub slab vapor sampling point installation procedure will be in accordance with the attached Vapor
Pin® standard operating procedures summarized below:
• A rotary hammer will be used to drill into the concrete. The installation will require a 5/8 inch masonry
bit and will be advanced until the bit penetrates the entire slab and one inch into the underlying soil. After
the hole is drilled, the concrete dust and debris will be removed by vacuuming.
• A stainless steel Vapor Pin® will be inserted into the hole after addition the Vapor Pin® sleeve. The
Vapor Pin® will be set by using a dead blow hammer.
• A Vapor Pin® Cap will be placed on the Vapor Pin® to prevent vapor loss prior to sampling.
• We will allow at least 20 minutes for the sub-slab soil-gas conditions to re-equilibrate prior to sampling.
• A water dam will used to test the seal between the Vapor Pin® and the slab. A PVC coupling will be
used in conjunction with a homemade play dough made out of baking soda, cornstarch and
water. Water will be placed within the dam, if the water level within the dam does not change, the
seal is tight.
• “Roll a 1-inch diameter ball of modeling clay between your palms to form a “snake” approximately 7
inches long and press it against the end of the water dam. Push the water dam gently against the slab to
form a seal with the concrete. Attach the sample tubing to the top of the Vapor Pin® Sampling Device

3 These samples have previously been collected
Sampling Work Plan R4 April 25, 2023
Mock Judson Mill
2610 Oakland Avenue
Greensboro, North Carolina
Brownfield project number: 25094-21-041

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and pour enough distilled water into the water dam to immerse the base of the Vapor Pin® and the tubing
connection at the top of the Vapor Pin® Sampling Device.”4

3.1.2 Helium Tracer Test

Dedicated tubing will be used for each sampling point. Sampling will be in general accordance with the
attached Vapor Pin® standard operating procedures summarized below.

• Prior to sampling, a helium leak test will be performed on the soil gas probes and fittings of the sampling
train before collecting a soil gas sample. A clear plastic shroud will be placed over the sampling port and
sampling train. The shroud will have several fittings on the box.
• Purge port
• Helium sampling port
• Helium supply port.
• Purge/off/sample three way valve (purge point, sample point and sample)
• Take off the Vapor Pin® Cap and connect the sample tubing to the barb fitting of the Vapor Pin®
Sampling Device.
• Create a connection by using a short piece of Tygon™ tubing to join the Vapor Pin® Sampling Device
with the Nylaflow or other rigid tubing. Put the tubing as close to the Vapor Pin® Sampling Device as
possible to minimize contact between soil gas and Tygon™ tubing.
• Connect the Summa Canister to the tubing.
• Cover the sampling train with the shroud.
• Connect the helium to the shroud. Connect the helium detector. The helium detector will be turned on to
ensure it is reading 20.9% oxygen. Fill the shroud with helium. Lab grade helium will be used for the
leak test. The shroud atmosphere will be enriched with at least 10% helium. The helium concertation
will be maintained at or above 10% throughout the duration of the tracer test and sampling. An Entech
Instruments (or equivalent) helium detector will be used to verify the presence and concentration of tracer
gas.

The purging device (hand vacuum) will be situated outside of the shroud connected to the shroud with Teflon
tubing. The helium control valve will be switched to the shroud position. A minimum of 300 ccs will be evacuated
from the sample point. If the sample train is leak free, the helium level reading will drop below 1%. The shroud
helium concentration and the helium concentration in the purged soil vapor will be documented. The shroud will
be purged three times prior to sampling. The three way valve will be turned to the off position. The sample will
then be collected by turning the sample valve to the sample position.

For the sub slab vapor samples, one purge volume will include the volume of the 0.25-inch macro core
sampling tube and the depth of the boring. Based on a six inch boring, one purge volume is calculated at
approximately 6.82206x10-4 ft3 or approximately 20 cc.

The sampling will be in compliance with the Division of Waste Management Vapor Intrusion Guidance (March
2018) and Brownfields Vapor Intrusion assessment guidance (March 2022). The sample collection will be
conducted following the leak detection testing, if the leak detection testing indicates helium concentrations in the
vapor point are less than or equal to 1 percent. A photograph of the shroud and sampling set-up at each sample
location will be taken. The sample container used for the collection of sub slab vapor samples are laboratory
supplied stainless steel 1.4-Liter summa canisters. The sample flow rate is set by a regulator and will be a
maximum of 200 cc (mL) per minute. The sampling valve will be closed when the vacuum is approximately 6

4 Vapor Pin® SOP Leak Testing the Vapor Pin Sample Devise Via Water Dam
Sampling Work Plan R4 April 25, 2023
Mock Judson Mill
2610 Oakland Avenue
Greensboro, North Carolina
Brownfield project number: 25094-21-041

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inches of Hg and that the sampling canister final vacuum will not be allowed to reach 0 inches Hg. Before
attaching the sample container, the vapor probe will be purged as described above. The sub slab vapor samples
will be submitted to EMSL Analytical in Cinnaminson New Jersey under the chain of custody protocol and will
be analyzed for volatile organic compounds using USEPA Method TO-15 (74 volatile organic compounds). Field
vacuum readings will be recorded on the chain of custody forms. The sample collection time duration will be
recorded. Permanent sampling ports will be installed and caped for potential future sampling requirements.

Mercury has previously been assessed for and detected in soil at concentrations below applicable PSRGs.
However, mercury vapor intrusion concerns are not present.

Duplicate sample(s) will be collected immediately after the initial sample collection. The sampling protocol will
be repeated. One duplicate sample will be collected immediately after the original sample is collected. Sub slab
samples will be compared to Vapor Intrusion Screening Levels (VISLs) dated January 2023. The Summa canisters
will be batch certified.

3.2 Soil Gas Samples

Two soil gas samples will be collected north of the boiler room. The type of material found in the boring will
be recorded and soil boring logs will be generated. Figure 3 illustrates the sample locations.

3.2.1 Port Installation

The vapor point borehole will be created using a 2.25-inch width and 4 ft length Geoprobe macro-core soil
sampling tube. The sample tube can be advanced to the desired depth then removed, therefore, leaving a
void of approximately 2.25 inches in diameter at the desired depth. The boreholes will be advanced to 4.5 feet
for exterior areas. The clean vapor point is connected to a length of 0.25-inch Teflon tubing and inserted into
the borehole and would rest at the termination depth. The bottom of the borehole would then be filled with 6
inches of #2 mesh silica sand. Above the filter pack, the annulus will be sealed with a minimum of two feet
of granular sodium bentonite consisting of 6 inches of dry granular bentonite to prevent the infiltration of
hydrated bentonite followed by one foot of hydrated bentonite. Hydrated granular bentonite will be placed up
to the ground surface to complete the seal. Six inches of dedicated Teflon tubing will extend from the ground
surface to serve as a sampling port for the summa canister or similar sampling device. The ports will be
allowed to equilibrate for twenty-four hours before sampling. Samples will be collected from a depth at
approximately 5 feet provided water is not encountered before this depth. If groundwater is encountered, the
depth of the boring may be modified based on field conditions to be terminated at least six inches above the
observed water table.

3.2.2 Helium Tracer Test

The helium tracer test and sampling will be performed in accordance with Section 3.1.2.

3.3 Soil Samples

The redevelopment is utilizing the existing site structures which is slab on grade with the exception of a small
basement in the main mill portion of the site. This basement will be renovated into usable space. Lowest utility
excavation will be the storm drainage. Lowest point the storm drain system is the Structure 5 which is 13 feet
below current existing grade.

Sampling Work Plan R4 April 25, 2023
Mock Judson Mill
2610 Oakland Avenue
Greensboro, North Carolina
Brownfield project number: 25094-21-041

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Proposed utility excavations will range from approximately 3 feet to 13 feet below existing grade. Soil borings
will be advanced using a GeoprobeÒ. The GeoprobeÒ uses dedicated sampling sleeves. The GeoprobeÒ spoons
will be decontaminated using alconox prior to reuse.

A photoionization detector will be used to field screen soils from the borings. A aliquot of the sample will be
placed in a Ziplock bag and allowed to sit for five (5) minutes prior to collecting a reading by perforating the
plastic back with the PID probe. PID readings and other visual/olfactory observations will be recorded in the soil
boring logs. Soil samples for laboratory analysis will be collected above the observed water table based on field
screening results. If indications of impacts are not noted, soil sample will be collected from the depths identified
in Table 2.

Soil samples for PCBs will be tested for aroclors. If aroclors are detected in any of the samples, then the worst
case PCB aroclor sample will be tested for PCB congeners. Additionally, if no aroclors are detected in the samples
but the detection limit for the aroclor is above the PSRG, then PCB congeners will be tested in the sample. Samples
will be collected between 1 to 5.5 feet in the excavation.

Samples for laboratory analysis will be placed in laboratory prepared containers using new disposable nitrile
gloves. After being filled, the sample containers will be labeled with the project name and number, the time and
date of sample collection, the analyses to be performed, and the absence or presence of preservative. The filled
sample containers will be placed into an ice filled cooler to maintain the samples at approximately 4° Celsius.

Sample collection will be conducted in accordance with the NCDEQ Inactive Hazardous Sites
Program Guidelines for Assessment and Cleanup (July 2021). The samples will be compared to the North
Carolina DEQ Preliminary Soil Remediation Goals (PSRG, dated January 2023).

The soil borings will be abandoned by placing bentonite into the borings.

3.4 Groundwater Samples

Baseline water levels will be recorded and provided in the assessment report. The existing permanent groundwater
wells are constructed with 1 inch diameter PVC. The sampling will be conducted in general accordance with
Region 4 US Environmental Protection Agency Science and Ecosystem Support Division Athens Georgia
operating Procedures for Groundwater Sampling dated April 26, 2017. At least three well volumes (approximately
0.042 gallons per foot of 1-inch well is one well volume) will be purged prior to sampling. Purge water will be
placed in labelled 55-gallon drums. The purging will be completed with low flow peristaltic pump and dedicated
tubing. The NTUs will be recorded after each well volume. In addition to turbidity, conductivity and pH readings
will be monitored at each well volume during purging to document stabilization readings. Purging will continue
until the turbidity readings are 10 NTU or less. If 10 NTUs have not been reached after purging five well volumes,
the development will stop, provided the other parameters have stabilized. The samples will be collected using a
low flow peristaltic pump and dedicated tubing.

3.5 PCB impacted Soil Excavation

The identified PCB impacts were excavated with a mini excavator. The excavated soil was placed in roll off
dumpsters and covered. The excavation limits were estimated based on the data provided by Swift Creeks
sampling presented in their Phase II Environmental Site Assessment/Remedial Investigation Report dated
December 6, 2021. Approximately 26,672 kilograms of soil was excavated. Each sidewall and the base of the
excavation was sampled with a decontaminated stainless steel spoon and dedicated nitrile gloves.

Sampling Work Plan R4 April 25, 2023
Mock Judson Mill
2610 Oakland Avenue
Greensboro, North Carolina
Brownfield project number: 25094-21-041

10

Samples for laboratory analysis were placed in laboratory prepared containers using new disposable nitrile gloves.
After being filled, the sample containers were labeled with the project name and number, the time and date of
sample collection, the analyses to be performed, and the absence or presence of preservative. The filled sample
containers were placed into an ice filled cooler to maintain the samples at approximately 4° Celsius. The samples
were tested for aroclors. Aroclors were not detected in the samples. The detection limit for the aroclors were not
above the respective PSRG.

Sample collection will be conducted in accordance with the NCDEQ Inactive Hazardous Sites
Program Guidelines for Assessment and Cleanup (July 2021). The samples will be compared to the North
Carolina DEQ Preliminary Soil Remediation Goals (PSRG, dated January 2023).

3.6 Potentiometric Map

Depth to water will be collected from the 12 on-site wells, provided they remain intact using a decontaminated
water level probe. The depths will be measured to top of casing. The relative depths will be calculated based
on the elevations measured by Swift Creek Environmental, Inc. on September 14, 2021.
4.0 LABORATORY ANALYSES

4.1 Sub Slab Vapor and Soil Gas Samples

The soil gas samples will be submitted to EMSL Analytical in Pineville, North Carolina, under the chain of
custody protocol and will be analyzed using USEPA Method TO-15. The EPA 72 compound analyte list will be
used for the analysis (see a sample report in Appendix A). This list includes naphthalene and excludes acrolein.
The laboratory is certified by AIHA with the Laboratory ID of LAP-192283. A copy of the certification has been
included in Appendix 3. The Reporting Limits/Method Detection Limits and the Reporting of J-Flags will meet
applicable screening criteria. The hold time for this media is up to 30 days. Based on this hold time requirement,
there is not a concern with hold times. Level II QA/QC will be conducted by the laboratory.

4.2 Soil and Groundwater

The soil and groundwater samples will be submitted to either SGS at 4405 Vineland Road in Orlando, Florida or
Pace Analytical Laboratory located at 9800 Kincey Avenue, Suite 100 in Huntersville, North Carolina under the
chain of custody protocol.

The samples will be laboratory analyzed for the following:
• VOCs by EPA methods 8260. The Reporting Limits/Method Detection Limits and the Reporting of J-
Flags will meet North Carolina residential screening criteria. The hold time for this analysis is up to 7
days. Based on this hold time requirement, there is not a concern with hold times.
• SVOCs by EPA Method 8270. The Reporting Limits/Method Detection Limits and the Reporting of J-
Flags will meet applicable screening criteria. The hold time for this analysis is up to 14 days. Based on
this hold time requirement, there is not a concern with hold times.
• RCRA 8 metals by method 6010 ICP metals and 7471 Mercury (including hexavalent chromium by
method 7199). The Reporting Limits/Method Detection Limits and the Reporting of J-Flags will meet
applicable screening criteria. The soil hold time for these analysis is up to 28 days. Based on this hold
time requirement, there is not a concern with hold times. The groundwater hold time for methods 6010
and 7471 analysis is up to 28 days. Based on this hold time requirement, there is not a concern with hold
Sampling Work Plan R4 April 25, 2023
Mock Judson Mill
2610 Oakland Avenue
Greensboro, North Carolina
Brownfield project number: 25094-21-041

11

times. The groundwater hold time for method 7199 analysis is up to 28 days. Based on this hold time
requirement, there is not a concern with hold times.
• PCB samples by Method 1666. There is no hold time for this analysis. However the analysis must be run
within 40 days of extraction. Based on this hold time requirement, there is not a concern with hold times.

5.0 QA/QC

The samples will be collected in laboratory supplied containers, providing adequate sample volume for the
MS/MSD analysis (level 2). One duplicate sample will be collected for every 20 samples, per media, per method5.
One trip blank for 8260 (groundwater) will accompany each cooler5. The samples, duplicate samples and trip
blanks will be submitted under the chain of custody. The soil and groundwater samples will be submitted to Pace
Analytical Laboratory, SGS Laboratory or EMSL under the chain of custody protocol.

6.0 INVESTIGATION DERIVED WASTE (IDW) MANAGEMENT

Management recommendations for IDW is in accordance with 15A NCAC 02T.1503 and 15A NCAC 02H.
0106. Previous assessment data has not identified Hazardous Waste (listed or characteristic) in the proposed
sampling areas. Therefore, soil generated from the borings that is not collected as a sample will be left and placed
back in the boring (first out/last in).

Groundwater purge water generated on site will be stored in labeled 55 gallon drums currently on-site from prior
assessment activities. The drums will be collected and disposed under manifest.

PCB impacted soil was placed in a roll off container(s) and covered. The waste was hauled to Chemical Waste
Management Inc., Highway 17 North, Mile Marker 163 in Emelle, Alabama for under manifest. Copies of the
manifests will be included in the assessment report.

7.0 REPORTING

ASE will provide an electronic copy of the finished report that will consist of a summary of the project
information, the results obtained, and our conclusions and recommendations. A summary of the disposal of the
drums and PCB soils will also be included. Tables for tabulated analytical data per media sampled and analyzed,
compared against applicable screening levels will be included in the report. Figures will be generated to depict
the actual sample locations and each media depicted in the legend. The figures will have approximate scale and
north arrow depicted. The report will be sealed by a North Carolina Licensed Professional Engineer, by a licensed
firm. The following will be included in the report.

• Groundwater will be compared to 2Ls and groundwater VISLs.
• Non-detectable levels will be reported as less than the applicable reporting limit, noting any
reporting limits that exceed the respective screening level.
• Details on building additions, slab types and sub-grade features such as the locations of crawl
spaces, tunnels, basements, sub-grade walls, and footer walls encountered during assessment.
• Boring log for soil vapor borings will be included.

5 Due to an oversight during sampling, a trip blank and a water sample duplicate were not analyzed.
Sampling Work Plan R4 April 25, 2023
Mock Judson Mill
2610 Oakland Avenue
Greensboro, North Carolina
Brownfield project number: 25094-21-041

FIGURES

FIGURE 1: SITE LOCATION MAP
Source: USGS Greensboro, North Carolina Quadrangle, 2013.
Work Plan
Former Mock Judson Mill
2610 Oakland Avenue
Greensboro, North Carolina
N
Brownfield No.25094-21-041
January 2023
85.39'
LINDELL ROAD HIATT STREETHOWARD
S
T
R
E
E
TOAKLAND AVENUE1T 2S2SSYMBOLL-101L-102L-103L-104L-105L-106L-108L-109L-110L-111L-112L-113L-114L-115L-116L-117L-121L-123LAYOUT SCHEDULE AMENITY AREASYMBOLL-103L-109LAYOUT SCHEDULE POCKET PARKSYMBOLL-120L-122LAYOUT SCHEDULE RAIN GARDENRESIDENTIALRESIDENTIALWWOHPOHPOHPOHPWWOHPDD4''SAN4''SANSSDDDDOHPOHPOHPOHPOHPOHPOHPOHPOHPOHPOHPOHPOHPOHPOHP
OHPOHPOHPOHPOHPOHPOHPOHPOHPOHPSSSSAN SAN SAN SAN SAN SAN SAN SAN SAN
SAN
SAN
SAN
SAN
SAN
SAN
SANSS SSAN SAN SAN SAN SAN SAN SAN SAN SAN
SAN
SAN
SAN
SAN
SAN
SAN
SANSSS
SS8'' W8'' W8'' W8'' W8'' W8'' W8'' W8'' W6'' W 6'' W 6'' W 6'' W 6'' W 6'' W 6'' W 6'' W 8'' W8'' W8'' W8'' W8'' W8'' W8'' W8'' W8'' W8'' W8"8"8"8"
8"
8"
8"
8"
8"8"8"6'' W6'' W6'' W6'' W6'' W6'' W6'' W6'' W6'' W6'' WCENTERLINE RAILROAD TRACKSDDDDDDBRICK BOILER ROOMEXISTING MJVMILL BUILDING(FFE 862.59)ASPHALT: 46,512 sfONSITE SIDEWALK:16,881 sfSYNTHETIC TURF:6,756 sfASPHALT: 29,312 sfHEAVY DUTYCONCRETE: 731 sfHEAVY DUTYCONCRETE: 559 sfONSITE SIDEWALK:1,358 sfONSITE SIDEWALK:1,208 sfONSITE SIDEWALK:3,081 sfONSITE SIDEWALK:1,228 sfPUBLIC SIDEWALK:3,217 sfPUBLIC SIDEWALK:12,612 sfHEAVY DUTYCONCRETE: 583 sfONSITE SIDEWALK:1,261 sfPAVERS: 831 sfNAD 830SCALE 1"=40'80'40'735 Ninth StreetDurham, NC 27705p: 919. 286. 2575 f: 919. 286. 1906www.belkarchitecture.netARCHITECT OF RECORDThe professional services of the architect areundertaken for and are performed in the interestof the client listed below. No contractualobligation is assumed by the architect for thebenefit of any other party.© 2017, Belk ArchitectureSHEET CONTENTCLIENTPERMIT15 AUGUST17-MJV-01ScaleIssued ForDateProject No.Drawn by110/02/12 - Design ProgressionREVISIONSSITE CONSULTANTGENERAL CONTRACTORCAPITAL BROADCASTINGCOMPANY, INC.300 Blackwell Street, Suite 104Durham, NC 27701(919) 433-1566www.americantobacco.comTIMMONS GROUPNC License No. C-16528642 West Market St., Suite 136Greensboro, NC 27409336 . 662 . 0411 p336 . 662 . 0420 fwww.timmons.comSTRUCTURAL CONSULTANT212/07/12 - City Comments305/01/17 - Revised Amenity LayoutPROJECT TITLE & ADDRESSREDEVELOPMENT
2610 Oakland Ave.
Greensboro, NC 27403 KAYDOS-DANIELS ENGINEERS,PLLCAttn: Andrew Warnke400 W. Morgan St.Suite 201Raleigh, NC 27603919 . 600 . 0648 pwww.kaydos-daniels.comMOCK-JUDSON-
VOEHRINGER MILL411/28/18 - City Comments501/21/19 - City E&S Comments607/19/19 - City Comments & Utility Service Updates705/20/21 - City Erosion ControlCommentsC.T. WILSON CONSTRUCTION150 Goldan Drive #200Durham, NC 27705(919) 383-2535www.ctwilson.comPME + FA CONSULTANTMAPLE ENGINEERING, PLLCAttn: Zack L. Tomlin708 Saint Mary's St.P.O. Box 10443Raleigh, NC 27605(919) 341-4247www.maple-eng.com803/25/22 - Revisions Per Updated Amenity LayoutIMPERVIOUS AREAEXHIBITC103.1JAC1" = 40'FIGURE 2 - Proposed Redevelopment
FIGURE 3A: SAMPLE LOCATIONS -C. 1938, 1927 and 1928
Brownfield No.25094-21-041
January 2023
Work Plan
Former Mock Judson Mill
2610 Oakland Avenue
Greensboro, North Carolina
N
SS-11 SS-10
SS-9
SS-8
SS-7
Approximate scale (ft)
0 37
Source: Belk Architecture Site and Utility Plan
SUB-1
KEY:
Soil Sample
Sub Slab Vapor Sample
FIGURE 3B: SAMPLE LOCATIONS -C. 1928 and 1929
Work Plan
Former Mock Judson Mill
2610 Oakland Avenue
Greensboro, North Carolina
N
SS-6
SS-5
SS-2
Approximate scale (ft)
300
Brownfield No.25094-21-041
January 2023
Source: Belk Architecture Site and Utility Plan
KEY:
Soil Sample
FIGURE 3C: SAMPLE LOCATIONS -C. 1929
Work Plan
Former Mock Judson Mill
2610 Oakland Avenue
Greensboro, North Carolina
N
SS-4
SS-3
SS-1
Approximate scale (ft)
0 15
Brownfield No.25094-21-041
January 2023
Source: Belk Architecture Site and Utility Plan
KEY:
Soil Sample
FIGURE 3D: SAMPLE LOCATIONS -C. 1936
Work Plan
Former Mock Judson Mill
2610 Oakland Avenue
Greensboro, North Carolina
N
SS-14
SS-13
SS-12
Approximate scale (ft)
0 28
Brownfield No.25094-21-041
January 2023
Source: Belk Architecture Site and Utility Plan
Approximate
PCB Soil
Impacts
PCB-1 and
1D
PCB-2
PCB-3
PCB-4
PCB-5 PCB-6
KEY:
Soil Sample
PCB-3 –PCB Soil Samples
NSource: Belk Architecture Site and Utility Plan
FIGURE 3E: EXTERIOR SAMPLE LOCATIONS
Work Plan
Former Mock Judson Mill
2610 Oakland Avenue
Greensboro, North Carolina
Brownfield No.25094-21-041
January 2023
MW6
SS-15
MW1
SS-18
MW8
MW2
SS-16
SS-17 SS-19
MW7
MW3
Approximate Scale (Ft)0 110
PCB Soil
Impact Area
KEY:
Monitoring well
Soil Samples
Sub Slab Vapor Samples
Soil Gas Samples
SUB1
SUB2SUB3/3D
SG1 SG2
SS13SS14SS15SS16SS17SS18SS19SS20SS21SS1SS2 SS#SS4SS5SS6SS7SS8SS9SS10SS11SS12Soil Sample LocationAS10AS9AS8AS7AS6AS5AS4BG1AS3Air Sample LocationFigure 4 - Historic Sample Locations
Sampling Work Plan R4 April 25, 2023
Mock Judson Mill
2610 Oakland Avenue
Greensboro, North Carolina
Brownfield project number: 25094-21-041

TABLES

BF Project Parcel No. Address
Site
Acreage Former/Current Uses Proposed use
TABLE 1 - PROPERTY SUMMARY
25094-21-041 Guilford County
Parcel 0219794 8.67
Apartments, with
ammenities on the
central and northern
portion of the site
and future
residential or mixed
use on south side of
the site.
Historical documents indicate that the site was initially developed with a
plant nursery in the early 1900’s. The 1925 Sanborn map illustrates a
fumigating house on the site. Mock, Judson, Voehringer began
occupying the site in 1927 upon construction of the oldest portion of the
site structure (east side of the building). The two story main mill
building was expanded four times between 1928 and 1938, creating the
current footprint of the building. The Mock, Judson, Voehringer Mill,
also known as MoJud Mill, was a hosiery production plant. The mill
operated until approximately 1972. However, a small portion of the
building fronting Howard Street was used as a the Rolane Factory Outlet
Store until its closed in 1999. The site has been unoccupied since 1999.
The property was listed on the National Register of Historic Places in
2011. The property was in the process of redevelopment prior to the PD
purhcasing the property. However, the developer was unable to complete
the project due to financial reasons. The former owner of the property
had conducted asbestos abatment activities (including pumping the water
out of the boiler room and abatment of the ACM contained in the interior
ofthe buildng) demolition of the interioor of the strucutures and had also
conducted some site work. The project retained the approiate permits to
continue the redevelopment at the time of the PD purchase.
2610 Oakland
Avenue (Historical
addresses include
1015 South Lindell
Road and 1000-1010
Howard Street)
MOCK JUDSON MILL
Objective Type of Sample Date
Collected
Numer of
samples Sample ID Depth of Sample Sample Analysis QA/QC
Evaluate the sub slab vapor in basement Sub Slab NA 1 SUB-1 Just below slab TO-15
Evlauate the sub slab vapor in Boiler House Sub Slab NA 3 SUB-2, SUB-3, SUB-3D Just below slab TO-15 Duplicate
Evaluate soil gas north and downgradient of the
boiler House Soil Gas NA 2 SG-1, SG-2 4.5 feet TO-15
Evaluate the soils under the slab in c.1936
building section within the utility trenches 7/22/22 3*SS-12 thru SS-14 Just under slab EPA Methods 8260 and 8270 and Cr VI by
EPA Method 7199.
Evaluation of soils withinthe exterior utility
trenches NA 6 SS-15 thru SS-19 plus SS-19D
At the base of the utility excavation at
each location (SS-15:13 ft, SS-16:12 ft,
SS-17:8 ft, SS-8:3 ft, and SS-19:6 ft)
EPA Methods 8260 and 8270 and RCRA 8
metals (including Chromium VI)Method
6020/7471, and Cr VI by EPA Method 7199.
Duplicate
Post excavation sampling 12/20/22 7*PCB-1, PCB-1D, PCB-2, PCB-
3, PCB-4, PCB-5 and PCB6 1.5-5.5 feet PCB Aroclors/Congeners Duplicate
Filling a data gap for VOCs, SVOCs, and Cr VI 7/22/22 3*MW-6, MW-7 and MW-8 Existing monitporings wells are 1 inch
diameter wells to 20 feet
EPA Methods 8260, 8270 and Cr VI by EPA
Method 7199.
Filling in gap of RCRA 8 NA 4 MW-1, MW-2 and MW-3
Existing monitporings wells are 1 inch
diameter wells to 20, 15 and 20 feet.
Respecively
RCRA 8 Duplicate
* Previously collected at the site
SS-1 thru SS-11
EPA Methods 8260 and 8270 and RCRA 8
metals (including Chromium VI)Method
6020/7471, and Cr VI by EPA Method 7199.
Cr VI by EPA Method 7199.Groundwater
7/15/22
7/22/22
TABLE 2 -SAMPLE SUMMARY
Mock Judson Mill
Soil Samples
Groundwater Samples
Filling a data gap for Cr VI
Just under slab
Evaluate the soils under the slab in c.1927,
c.1928, c.1929, and c.1938 building sections
within the utility trenches
Brownfield Project Number: 25094-21-041
Soil
11*
2*MW-2 and MW-3
Existing monitporings wells are 1 inch
diameter wells to 15 and 20 feet.
Respecively
Soil Vapor and Soil Gas
Sample ID TW-1 TW-2 C-1 MW-6
Depth (Feet)26-30'0-2'0-2'0-1'3-5'0-1'3-5'0-1'3-5'0-1'3-5'7-10'
Date 3/31/17 3/31/17 3/31/17 6/9/21 6/9/21 6/9/21 6/9/21 6/9/21 6/9/21 6/9/21 6/9/21 6/9/21
Benzo(a)anthracene 0.802J 0.656 NA NA NA NA NA NA NA NA NA 0.35 1.1
Benzo(a)pyrene NA NA NA NA NA NA NA NA NA 0.12 0.11
Arsenic 2.13 40.3 3.58 NA NA NA NA NA NA NA NA 5.8 0.68
Chromium 5.98 14.7 0.018 NA NA NA NA NA NA NA NA NE NE
Lead 1,500 NA NA NA NA NA NA NA NA NE 400
Silver 24 NA NA NA NA NA NA NA NA 3.4 78
TPH- GRO 1100 12,000 300 340 7,700 NA NE 50
TPH- ORO 2,710 440 220 NA NE 100
PCB and Congeger
Aroclor 1254 NA NA NA 0.66 0.14 0.062 0.25 0.091 0.23
PCB 126 NA NA NA NA NA 100 NA NA NA NA NA 0.047 0.000036
Non dioxin like confeners NA NA NA NA NA 159,330 NA NA NA NA NA 0.055 0.23
Sample ID MW-7
Depth (Feet)0-1'3-5'0-1'3-5'0-1'3-5'0-1'3-5'8-12'01'3-5'0-1'3-5'
Date 6/9/21 6/9/21 6/9/21 6/9/21 6/9/21 6/9/21 6/9/21 6/9/21 6/9/21 6/9/21 6/9/21 6/9/21 6/9/21
Benzo(a)anthracene NA NA NA NA NA NA NA NA NA NA NA NA NA 0.35 1.1
Benzo(a)pyrene NA NA NA NA NA NA NA NA NA NA NA NA NA 0.12 0.11
Arsenic NA NA NA NA NA NA NA NA 0.9 NA NA NA NA 5.8 0.68
Chromium NA NA NA NA NA NA NA NA NA NA NA NA NE NE
Lead NA NA NA NA NA NA NA NA NA NA NA NA NE 400
Silver NA NA NA NA NA NA NA NA NA NA NA NA 3.4 78
TPH- DRO 62 180 140 140 500 71 NA 1700 1600 160 1800 NE 50
TPH- ORO 240 140 810 110 NA 130 150 120 NE 100
PCB and Congeger
Aroclor 1254 0.091 0.23
PCB 126 NA NA NA NA NA NA NA NA NA NA NA NA 0.047 0.000036
Non dioxin like confeners NA NA NA NA NA NA NA NA NA NA NA NA 0.055 0.23
Sample ID MW-8
Depth (Feet)0-1'3-5'0-1'3-5'6-9'0-1'2-4'0-1'2-4'0-1'2-4'0-1'2-4'
Date 6/9/21 6/9/21 6/9/21 6/9/21 6/9/21 6/9/21 6/9/21 6/9/21 6/9/21 6/9/21 6/9/21 6/9/21 6/9/21
Benzo(a)anthracene NA NA NA NA NA 0.5 0.47 0.38 0.35 1.1
Benzo(a)pyrene NA NA NA NA NA 0.58 0.54 0.45 0.12 0.11
Arsenic NA NA NA NA 1.2 2 2.6 1.5 2.2 3.9 2.2 NA 2.3 5.8 0.68
Chromium NA NA NA NA NE NE
Lead NA NA NA NA NE 400
Silver NA NA NA NA 3.4 78
TPH- DRO 170 4400 480 NA NA NA NA NA NA NA NA NE 50
TPH- ORO or GRO 150 NA NA 312 NA NA NA NA NA NA NE 100
PCB and Congeger
Aroclor 1254 NA NA NA NA NA NA NA NA 0.091 0.23
PCB 126 NA NA NA NA NA NA NA NA NA NA NA NA 0.047 0.000036
Non dioxin like confeners NA NA NA NA NA NA NA NA NA NA NA NA 0.055 0.23
Sample ID MW-1 MW-2 MW-3 MW-4 MW-5 MW-9 MW-10
Depth (Feet)0-1'2-4'0-1'2-4'0-1'2-4'12-15'6-9'15-17'7-10'10-13'19-23'15-17"
Date 6/9/21 6/9/21 6/9/21 6/9/21 6/9/21 6/9/21 6/9/21 6/9/21 6/9/21 6/9/21 6/9/21 6/9/21 6/9/21
Benzo(a)anthracene 0.35 1.1
Benzo(a)pyrene 0.31 0.12 0.11
Arsenic 2.7 1.6 2.4 3.9 1.5 NA NA NA 1.5 5.8 0.68
Chromium NA NA NA NE NE
Lead NA NA NA NE 400
Silver NA NA NA 3.4 78
TPH- DRO NA NA NA NA NA NA NA NA NA NA NA NE 50
TPH- ORO or GRO 312 NA NA NA NA NA NA NA NA NA NA NA NE 100
PCB and Congeger
Aroclor 1254 NA NA NA NA NA NA NA NA NA NA NA NA NA 0.091 0.23
PCB 126 NA NA NA NA NA NA NA NA NA NA NA NA NA 0.047 0.000036
Non dioxin like confeners NA NA NA NA NA NA NA NA NA NA NA NA NA 0.055 0.23
Sample ID MW-11 SS-20 SS-21
Depth (Feet)12-16'9-12'9-12'
Date 6/9/21 6/9/21 6/9/21
Benzo(a)anthracene 0.35 1.1
Benzo(a)pyrene 0.12 0.11
Arsenic NA NA NA 5.8 0.68
Chromium NA NA NA NE NE
Lead NA NA NA NE 400
Silver NA NA NA 3.4 78
TPH- DRO NE 50
TPH- ORO NE 100
PCB and Congeger
Aroclor 1254 NA NA NA 0.091 0.23
PCB 126 NA NA NA 0.047 0.000036
Non dioxin like confeners NA NA NA 0.055 0.23
Red items are exceedances of residential and/or protectection of groundwater PSRGs
Concetration is non detect or below unrestricted use
NA = Not Analyzed
Data compared to NCDEQ PSRGs July 2022
SVOCs (mg/kg)
Metals (mg/kg)
TPH ORO (mg/kg)
Soil toWater
MSCC Residential
TPH ORO (mg/kg)
SS-19
SS-10SS-9SS-8SS-7SS-6
Soil toWater
MSCC Residential
SVOCs (mg/kg)
Metals (mg/kg)
SS-17 SS-18
SS-12 SS-14 SS-15
Soil toWater
MSCC
TPH ORO (mg/kg)
SS-11 SS-13
Metals (mg/kg)
TPH ORO (mg/kg)
SS-16 Soil toWater
MSCC Residential
SVOCs (mg/kg)
Metals (mg/kg)
Residential
SVOCs (mg/kg)
SS-5
TABLE 3 - Historical Soil Sampling Results Above Residential or Protection of Groundwater PSRG
Mock Judson Mill, 2610 Oakland Avenue
Greensboro, North CarolinaBrownfield No. 25094-21-041
TPH ORO (mg/kg)
Soil toWater
PSRG
Residential
PSRG
SVOCs (mg/kg)
Metals (mg/kg)
SS-1 SS-2 SS-3 SS-4
Sample ID TMW-1 TMW-2 TMW-3 TMW-4 MW-1 MW-2 MW-3 MW-4 MW-5 MW-6 MW-7 MW-8 MW-9 MW-10 MW-11
Date 3/31/17 3/31/17 3/31/17 3/31/17 9/14/21 9/14/21 9/14/21 9/14/21 9/14/21 9/15/21 9/15/21 9/15/21 9/15/21 9/14/21 9/14/21
Barium 1,340 NA NA NA NA NA NA NA 700
Chromium (total)18.1 NA NA NA NA NA 10 NA NA 10
Lead 22.1 NA NA NA NA NA NA NA 15
DRO 0.175 0.417 0.0694 0.172 NA NA NA NA NA 2.8 1.5 0.31 NA 260 NA NE
ORO or GRO 0.593 0.261 0.0493 0.0940 NA NA NA NA NA 1.2 0.81 0.37J NA 280J NA NE
PCB-77 3,3’,4,4’-Tetrachlorobiphenyl NA NA NA NA NA NA NA NA NA 0.166 NA NA NA NE
PCB-105 2,3,3’4,4’-Pentachlorobiphenyl NA NA NA NA NA NA NA NA NA 1.77 0.00627 NA NA NA NE
PCB-114 2,3,4,4’,5-Pentachlorobiphenyl NA NA NA NA NA NA NA NA NA 0.099 NA NA NA NE
PCB-118 2,3’,4,4’,5-Pentachlorobiphenyl NA NA NA NA NA NA NA NA NA 3.38 0.00956 NA NA NA NE
PCB-123 2’,3,4,4’,5-Pentachlorobiphenyl NA NA NA NA NA NA NA NA NA 0.161 NA NA NA NE
PCB-126 3,3’,4,4’,5-Pentachlorobiphenyl NA NA NA NA NA NA NA NA NA 0.0363 NA NA NA NE
PCB-156/157 2,3,3’,4,4’,5’-Hexachlorobiphenyl NA NA NA NA NA NA NA NA NA 0.965 0.00392 NA NA NA NE
PCB-167 2,3,4,4’,5,5’-Hexachlorobiphenyl NA NA NA NA NA NA NA NA NA 0.456 NA NA NA NE
PCB-189 2,3,3’,4,4’,5,5’-Heptachlorobiphenyl NA NA NA NA NA NA NA NA NA 0.0511 NA NA NA NE
Sum of Dioxin-Like Congeners NA NA NA NA NA NA NA NA NA 7.0844 0.0198 NA NA NA NE
Non-Dioxin-Like Congeners NA NA NA NA NA NA NA NA NA 52.1 0.0 NA NA NA NE
Shaded areas - Concetration is non detect or below unrestricted use
Red items are exceedances of residential and/or protectection of groundwater PSRGs
NA - Not Analized, NE - Not Established
Bold values exceed the NCAC 2L Groundwater Quality Standards set by the North Carolina Department of Environmental Quality (April 1 2022)
NCDEQ
Groundwater Quality
Standards (2L)
TPH (mg/L)
PCB Congeners (ng/L)
RCRA 8 Metals (ug/L)
TABLE 4 - Historical Groundwater Sampling Results Above 2L Standards
Mock Judson Mill, 2610 Oakland Avenue
Greensboro, North Carolina
Brownfield No. 25094-21-041
Sample ID SC-RM-SS1 SC-RM-SS2 AS3 AS4 AS5 AS6 AS7 AS8 AS9 AS10 BG1
Date 4/5/17 4/5/17 9/22/21 9/22/21 9/22/21 9/22/21 9/22/21 9/23/21 9/23/21 9/23/21 9/23/21
Naphthalene ND ND 3.9J 3.9J 4.2J <3.9 12.3 4.9 <3.7 <3.9 <3.4 NE
TABLE 5 - Historical Sub Slab Sampling Results
Mock Judson Mill, 2610 Oakland Avenue
Greensboro, North Carolina
Brownfield No. 25094-21-041
NCDEQ RVISL*
BG- Background ambient air
* NCDEQ Residential Subslab Vapor Intrusion Screening levels July 2022
VOCs (ug/m3)
NE-Not Established; ND- Not Detected
Sampling Work Plan R4 April 25, 2023
Mock Judson Mill
2610 Oakland Avenue
Greensboro, North Carolina
Brownfield project number: 25094-21-041

APPENDIX A

Laboratory Certifications

AIHA Laboratory Accreditation Programs, LLC
acknowledges thatEMSL Analytical, Inc.
10801 Southern Loop Blvd., Pineville, NC 28134Laboratory ID: LAP-192283
along with all premises from which key activities are performed, as listed above, has fulfilled the requirements of the AIHA Laboratory AccreditationPrograms (AIHA LAP), LLC accreditation to the ISO/IEC 17025:2017 international standard, General Requirements for the Competence of Testingand Calibration Laboratories in the following:
LABORATORY ACCREDITATION PROGRAMS
INDUSTRIAL HYGIENE Accreditation Expires: September 01,2024
ENVIRONMENTAL LEAD Accreditation Expires: September 01,2024
ENVIRONMENTAL MICROBIOLOGY Accreditation Expires: September 01,2024
FOOD Accreditation Expires:
UNIQUE SCOPES Accreditation Expires:
Specific Field(s) of Testing (FoT)/Method(s) within each Accreditation Program for which the above named laboratory maintains accreditationis outlined on the attached Scope of Accreditation. Continued accreditation is contingent upon successful on-going compliance with ISO/IEC17025:2017 and AIHA LAP, LLC requirements. This certificate is not valid without the attached Scope of Accreditation. Please review the AIHA LAP,LLC website (www.aihaaccreditedlabs.org) for the most current Scope.
Revision20: 06/07/2022
_____________________________________
Cheryl O MortonManaging Director, AIHA Laboratory Accreditation Programs, LLC
Date Issued: 09/01/2022
Effective: 06/07/2022Revision: 9.2Page 1 of 2
  AIHA Laboratory Accreditation Programs, LLC
SCOPE OF ACCREDITATION EMSL Analytical, Inc.Laboratory ID: LAP-192283
10801 Southern Loop Blvd., Pineville, NC 28134 Issue Date: 09/01/2022 The laboratory is approved for those specific field(s) of testing/methods listed in the table below. Clients areurged to verify the laboratory's current accreditation status for the particular field(s) of testing/Methods,since these can change due to proficiency status, suspension and/or withdrawal of accreditation. Industrial Hygiene Laboratory Accreditation Program (IHLAP) Initial Accreditation Date: 10/01/2014  
IHLAP Scope Category Field of Testing (FOT)Technology sub-type/Detector
Published ReferenceMethod/Title ofIn-house Method
Component, parameteror characteristic tested
Asbestos/FiberMicroscopy Core Phase ContrastMicroscopy (PCM)-NIOSH 7400 Asbestos/Fibers
Chromatography Core GC/MS -EPA TO-15 Volatile OrganicCompounds
Chromatography Core Gas Chromatography GC/FID NIOSH 1003 HalogenatedHydrocarbons
Chromatography Core Gas Chromatography GC/FID NIOSH 1500 Hydrocarbons
Chromatography Core Gas Chromatography GC/FID NIOSH 1501 Aromatic Hydrocarbons
Chromatography Core Ion Chromatography (IC)-NIOSH 7903 Inorganic Acids
Chromatography Core Ion Chromatography (IC)-OSHA ID-165SG Inorganic Acids
Chromatography Core Liquid Chromatography HPLC/UV NIOSH 2016 Formaldehyde
Miscellaneous Core Gravimetric -NIOSH 0500 Total Dust
Miscellaneous Core Gravimetric -NIOSH 0600 Respirable Dust
Miscellaneous Core Gravimetric -NIOSH 5000 Carbon Black
Spectrometry Core Atomic Absorption CVAA NIOSH 6009 Mercury
Spectrometry Core Atomic Absorption FAA NIOSH 7082 Lead
Spectrometry Core Inductively-Coupled Plasma ICP/AES NIOSH 7300 Metals
Spectrometry Core Inductively-Coupled Plasma ICP/AES NIOSH 7303 Metals
Spectrometry Core Infrared -NIOSH 7602 Silica

Effective: 06/07/2022Revision: 9.2Page 2 of 2
A complete listing of currently accredited IHLAP laboratories is available on the AIHA LAP, LLC website at: http://www.aihaaccreditedlabs.org
Certificate Number:667
Effective Date:1/1/2022
Expiration Date:12/31/2022
Lab Name:Pace Analytical Services LLC - Ormond Beach FL
Address:8 E Tower Circle
Ormond Beach, FL 32174-
North Carolina Wastewater/Groundwater Laboratory Certification
Certified Parameters Listing
Date of Last Amendment:10/31/2022
The above named laboratory, having duly met the requirements of 15A NCAC 2H.0800, is hereby certified for the measurement of the parameters listed below.
CERTIFIED PARAMETERS
INORGANIC
ALKALINITY
SM 2320 B-2011 (Aqueous)
BOD
SM 5210 B-2016 (Aqueous)
BROMIDE
EPA 300.0, Rev. 2.1, 1993 (Aqueous)
SW-846 9056 A (Aqueous)
SW-846 9056 A (Non-Aqueous)
CHLORIDE
EPA 300.0, Rev. 2.1, 1993 (Aqueous)
SW-846 9056 A (Aqueous)
SW-846 9056 A (Non-Aqueous)
COD
EPA 410.4, Rev. 2.0, 1993 (Aqueous)
COLOR, PC
SM 2120 B-2011 (PtCo) (Aqueous)
CONDUCTIVITY
SM 2510 B-2011 (Aqueous)
CYANIDE
EPA 335.4, Rev. 1.0, 1993 (Total) (Aqueous)
SW-846 9012 B (Total) (Aqueous)
SW-846 9012 B (Total) (Non-Aqueous)
FLUORIDE
EPA 300.0, Rev. 2.1, 1993 (Aqueous)
SW-846 9056 A (Aqueous)
SW-846 9056 A (Non-Aqueous)
HARDNESS TOTAL - METALS
SM 2340 B-2011 (Ca EPA 200.7, Rev. 4.4, 1994 + Mg EPA 200.7, Rev. 4.4, 1994) (Aqueous)
MBAS
SM 5540 C-2011 (Aqueous)
NITROGEN, AMMONIA
EPA 350.1, Rev. 2.0, 1993 (Aqueous)
NITROGEN, NITRATE
EPA 300.0, Rev. 2.1, 1993 (Aqueous)
SW-846 9056 A (Aqueous)
SW-846 9056 A (Non-Aqueous)
NITROGEN, NITRITE
EPA 353.2, Rev. 2.0, 1993 (Aqueous)
EPA 300.0, Rev. 2.1, 1993 (Aqueous)
SW-846 9056 A (Aqueous)
SW-846 9056 A (Non-Aqueous)
NITROGEN, NO3 + NO2
EPA 353.2, Rev. 2.0, 1993 (Aqueous)
EPA 300.0, Rev. 2.1, 1993 (Aqueous)
NITROGEN, TOTAL KJELDAHL
EPA 351.2, Rev. 2.0, 1993 (Aqueous)
ORGANIC CARBON, DISSOLVED
SM 5310 B-2014 (Combustion) (Aqueous)
ORGANIC CARBON, TOTAL
SM 5310 B-2014 (Combustion) (Aqueous)
PAINT FILTER LIQUIDS
SW-846 9095B
pH
SM 4500 H+B-2011 (Aqueous)
SW-846 9040 C (Aqueous)
SW-846 9045 D (Non-Aqueous)
PHOSPHATE, ORTHO
EPA 365.1, Rev. 2.0, 1993 (Aqueous)
EPA 300.0, Rev. 2.1, 1993 (Aqueous)
SW-846 9056 A (Aqueous)
SW-846 9056 A (Non-Aqueous)
PHOSPHORUS, TOTAL
EPA 365.3, 1978 (Aqueous)
EPA 365.4, 1974 (Aqueous)
RESIDUE, DISSOLVED 180 C
SM 2540 C-2015 (Aqueous)
RESIDUE, SUSPENDED
This certification requires maintance of an acceptable quality assurance program, use of approved methodology, and satisfactory performance on evaluation samples. Laboratories are subject to civil penalties and/or decertification for infractions as set forth in 15A NCAC 2H.0807.
Certificate Number:667
Effective Date:1/1/2022
Expiration Date:12/31/2022
Lab Name:Pace Analytical Services LLC - Ormond Beach FL
Address:8 E Tower Circle
Ormond Beach, FL 32174-
North Carolina Wastewater/Groundwater Laboratory Certification
Certified Parameters Listing
Date of Last Amendment:10/31/2022
The above named laboratory, having duly met the requirements of 15A NCAC 2H.0800, is hereby certified for the measurement of the parameters listed below.
CERTIFIED PARAMETERS
SM 2540 D-2015 (Aqueous)
RESIDUE, TOTAL
SM 2540 B-2015 (Aqueous)
SILICA - METALS
EPA 200.7, Rev. 4.4, 1994 (Aqueous)
SW-846 6010 D (Aqueous)
SULFATE
EPA 300.0, Rev. 2.1, 1993 (Aqueous)
SW-846 9056 A (Aqueous)
SW-846 9056 A (Non-Aqueous)
SULFIDE
SM 4500 S²ˉ F-2011 (Aqueous)
TURBIDITY
EPA 180.1, Rev. 2.0, 1993 (Aqueous)
METAL
ALUMINUM
EPA 200.7, Rev. 4.4, 1994 (Aqueous)
SW-846 6010 D (Aqueous)
SW-846 6010 D (Non-Aqueous)
EPA 200.8, Rev. 5.4, 1994 (Aqueous)
SW-846 6020 B (Aqueous)
ANTIMONY
EPA 200.7, Rev. 4.4, 1994 (Aqueous)
SW-846 6010 D (Aqueous)
SW-846 6010 D (Non-Aqueous)
EPA 200.8, Rev. 5.4, 1994 (Aqueous)
SW-846 6020 B (Aqueous)
SW-846 6020 B (Non-Aqueous)
ARSENIC
EPA 200.7, Rev. 4.4, 1994 (Aqueous)
SW-846 6010 D (Aqueous)
SW-846 6010 D (Non-Aqueous)
EPA 200.8, Rev. 5.4, 1994 (Aqueous)
SW-846 6020 B (Aqueous)
SW-846 6020 B (Non-Aqueous)
BARIUM
EPA 200.7, Rev. 4.4, 1994 (Aqueous)
SW-846 6010 D (Aqueous)
SW-846 6010 D (Non-Aqueous)
EPA 200.8, Rev. 5.4, 1994 (Aqueous)
SW-846 6020 B (Aqueous)
SW-846 6020 B (Non-Aqueous)
BERYLLIUM
EPA 200.7, Rev. 4.4, 1994 (Aqueous)
SW-846 6010 D (Aqueous)
SW-846 6010 D (Non-Aqueous)
EPA 200.8, Rev. 5.4, 1994 (Aqueous)
SW-846 6020 B (Aqueous)
SW-846 6020 B (Non-Aqueous)
BORON
EPA 200.7, Rev. 4.4, 1994 (Aqueous)
SW-846 6010 D (Aqueous)
SW-846 6010 D (Non-Aqueous)
CADMIUM
EPA 200.7, Rev. 4.4, 1994 (Aqueous)
SW-846 6010 D (Aqueous)
SW-846 6010 D (Non-Aqueous)
EPA 200.8, Rev. 5.4, 1994 (Aqueous)
SW-846 6020 B (Aqueous)
SW-846 6020 B (Non-Aqueous)
CALCIUM
EPA 200.7, Rev. 4.4, 1994 (Aqueous)
SW-846 6010 D (Aqueous)
SW-846 6010 D (Non-Aqueous)
CHROMIUM HEXAVALENT
EPA 218.6, Rev. 3.3, 1994 (Aqueous)
EPA 218.7, Rev. 1.0, 2011 [NCAC .02L Variance] (Aqueous)
CHROMIUM TOTAL
This certification requires maintance of an acceptable quality assurance program, use of approved methodology, and satisfactory performance on evaluation samples. Laboratories are subject to civil penalties and/or decertification for infractions as set forth in 15A NCAC 2H.0807.
Certificate Number:667
Effective Date:1/1/2022
Expiration Date:12/31/2022
Lab Name:Pace Analytical Services LLC - Ormond Beach FL
Address:8 E Tower Circle
Ormond Beach, FL 32174-
North Carolina Wastewater/Groundwater Laboratory Certification
Certified Parameters Listing
Date of Last Amendment:10/31/2022
The above named laboratory, having duly met the requirements of 15A NCAC 2H.0800, is hereby certified for the measurement of the parameters listed below.
CERTIFIED PARAMETERS
EPA 200.7, Rev. 4.4, 1994 (Aqueous)
SW-846 6010 D (Aqueous)
SW-846 6010 D (Non-Aqueous)
EPA 200.8, Rev. 5.4, 1994 (Aqueous)
SW-846 6020 B (Aqueous)
SW-846 6020 B (Non-Aqueous)
COBALT
EPA 200.7, Rev. 4.4, 1994 (Aqueous)
SW-846 6010 D (Aqueous)
SW-846 6010 D (Non-Aqueous)
EPA 200.8, Rev. 5.4, 1994 (Aqueous)
SW-846 6020 B (Aqueous)
SW-846 6020 B (Non-Aqueous)
COPPER
EPA 200.7, Rev. 4.4, 1994 (Aqueous)
SW-846 6010 D (Aqueous)
SW-846 6010 D (Non-Aqueous)
EPA 200.8, Rev. 5.4, 1994 (Aqueous)
SW-846 6020 B (Aqueous)
SW-846 6020 B (Non-Aqueous)
IRON
EPA 200.7, Rev. 4.4, 1994 (Aqueous)
SW-846 6010 D (Aqueous)
SW-846 6010 D (Non-Aqueous)
SW-846 6020 B (Aqueous)
LEAD
EPA 200.7, Rev. 4.4, 1994 (Aqueous)
SW-846 6010 D (Aqueous)
SW-846 6010 D (Non-Aqueous)
EPA 200.8, Rev. 5.4, 1994 (Aqueous)
SW-846 6020 B (Aqueous)
SW-846 6020 B (Non-Aqueous)
MAGNESIUM
EPA 200.7, Rev. 4.4, 1994 (Aqueous)
SW-846 6010 D (Aqueous)
SW-846 6010 D (Non-Aqueous)
MANGANESE
EPA 200.7, Rev. 4.4, 1994 (Aqueous)
SW-846 6010 D (Aqueous)
SW-846 6010 D (Non-Aqueous)
EPA 200.8, Rev. 5.4, 1994 (Aqueous)
SW-846 6020 B (Aqueous)
SW-846 6020 B (Non-Aqueous)
MERCURY
EPA 245.1, Rev. 3.0, 1994 (Aqueous)
SW-846 7470 A (Aqueous)
SW-846 7471 B (Non-Aqueous)
MOLYBDENUM
EPA 200.7, Rev. 4.4, 1994 (Aqueous)
SW-846 6010 D (Aqueous)
SW-846 6010 D (Non-Aqueous)
EPA 200.8, Rev. 5.4, 1994 (Aqueous)
SW-846 6020 B (Aqueous)
NICKEL
EPA 200.7, Rev. 4.4, 1994 (Aqueous)
SW-846 6010 D (Aqueous)
SW-846 6010 D (Non-Aqueous)
EPA 200.8, Rev. 5.4, 1994 (Aqueous)
SW-846 6020 B (Aqueous)
SW-846 6020 B (Non-Aqueous)
POTASSIUM
EPA 200.7, Rev. 4.4, 1994 (Aqueous)
SW-846 6010 D (Aqueous)
SW-846 6010 D (Non-Aqueous)
SELENIUM
EPA 200.7, Rev. 4.4, 1994 (Aqueous)
SW-846 6010 D (Aqueous)
SW-846 6010 D (Non-Aqueous)
This certification requires maintance of an acceptable quality assurance program, use of approved methodology, and satisfactory performance on evaluation samples. Laboratories are subject to civil penalties and/or decertification for infractions as set forth in 15A NCAC 2H.0807.
Certificate Number:667
Effective Date:1/1/2022
Expiration Date:12/31/2022
Lab Name:Pace Analytical Services LLC - Ormond Beach FL
Address:8 E Tower Circle
Ormond Beach, FL 32174-
North Carolina Wastewater/Groundwater Laboratory Certification
Certified Parameters Listing
Date of Last Amendment:10/31/2022
The above named laboratory, having duly met the requirements of 15A NCAC 2H.0800, is hereby certified for the measurement of the parameters listed below.
CERTIFIED PARAMETERS
EPA 200.8, Rev. 5.4, 1994 (Aqueous)
SW-846 6020 B (Aqueous)
SW-846 6020 B (Non-Aqueous)
SILVER
EPA 200.7, Rev. 4.4, 1994 (Aqueous)
SW-846 6010 D (Aqueous)
SW-846 6010 D (Non-Aqueous)
EPA 200.8, Rev. 5.4, 1994 (Aqueous)
SW-846 6020 B (Aqueous)
SODIUM
EPA 200.7, Rev. 4.4, 1994 (Aqueous)
SW-846 6010 D (Aqueous)
SW-846 6010 D (Non-Aqueous)
STRONTIUM
EPA 200.7, Rev. 4.4, 1994 (Aqueous)
SW-846 6010 D (Aqueous)
SW-846 6010 D (Non-Aqueous)
THALLIUM
SW-846 6010 D (Aqueous)
SW-846 6010 D (Non-Aqueous)
EPA 200.8, Rev. 5.4, 1994 (Aqueous)
SW-846 6020 B (Aqueous)
SW-846 6020 B (Non-Aqueous)
TIN
EPA 200.7, Rev. 4.4, 1994 (Aqueous)
SW-846 6010 D (Aqueous)
SW-846 6010 D (Non-Aqueous)
VANADIUM
EPA 200.7, Rev. 4.4, 1994 (Aqueous)
SW-846 6010 D (Aqueous)
SW-846 6010 D (Non-Aqueous)
EPA 200.8, Rev. 5.4, 1994 (Aqueous)
SW-846 6020 B (Aqueous)
SW-846 6020 B (Non-Aqueous)
ZINC
EPA 200.7, Rev. 4.4, 1994 (Aqueous)
SW-846 6010 D (Aqueous)
SW-846 6010 D (Non-Aqueous)
EPA 200.8, Rev. 5.4, 1994 (Aqueous)
SW-846 6020 B (Aqueous)
SW-846 6020 B (Non-Aqueous)
ORGANIC
1,2, DIBROMOETHANE (EDB)
SW-846 8011 (Includes DBCP) (Aqueous)
BASE NEUTRAL/ACID, ORGANICS
SW-846 8270 E (Aqueous)
SW-846 8270 E (Non-Aqueous)
PESTICIDES, ORGANOCHLORINE
SW-846 8081 B (Aqueous)
SW-846 8081 B (Non-Aqueous)
POLYCHLORINATED BIPHENYLS (PCBs)
SW-846 8082 A (Aqueous)
SW-846 8082 A (Non-Aqueous)
SW-846 8082 A (Oil)
PURGEABLE, ORGANICS
SW-846 8260 D (Aqueous)
SW-846 8260 D (Non-Aqueous)
This certification requires maintance of an acceptable quality assurance program, use of approved methodology, and satisfactory performance on evaluation samples. Laboratories are subject to civil penalties and/or decertification for infractions as set forth in 15A NCAC 2H.0807.
TO-15 Analyte
List (1 of 2 pages)
TO-15 Analyte List
(2 of 2 pages)
Sampling Work Plan R4 April 25, 2023
Mock Judson Mill
2610 Oakland Avenue
Greensboro, North Carolina
Brownfield project number: 25094-21-041

APPENDIX B

Checklist

Environmental Site Assessment Work Plan
Minimum Requirements Checklist
NCDEQ Brownfields Program – November 2018
Title Page
The title page should include the following information. Letter style reports are acceptable, as long as this
information is somewhere on the first page.
_____ Title of Work Plan
_____ Brownfields Project Name (not the development name)
_____ Brownfields Project Number
_____ Date (updated with each revision)
_____ Revision Number
_____ Firm PE/PG License Number
_____ Individual PE/PG seal & signature
Section 1 – Introduction
_____ Provide the site location, address, and acreage.
_____ Provide a BRIEF summary of the history of the property and its history in the program. For example:
reiterating RECs from a Phase I ESA, indicate if the scope of work negotiated during a Data Gap
Meeting, etc.
______ Briefly list and describe the data gaps the assessment is attempting to fill
_____ Indicate if the assessment data is intended for use by any other DEQ programs in addition to the
Brownfields Program (i.e. UST, IHSB, etc.)
Section 2 – Scope of Work
_____ Provide a general description of proposed scope of work covered in this plan (i.e. 2 new monitoring
wells, six groundwater samples, 5 soil gas sampling points and 6 soil borings)
_____ Discuss samples to be collected by media and source area/location. Generally, the reasoning for the
sample locations selected.
_____ Describe depths of samples to be collected (Reference Table 1) or how that decision will be made
in the field, if needed.
_____ State for what each sample will be analyzed (briefly). Reference Table 1.
Section 3 – Sampling Methodology
_____ Reference the guidance documents you intend to use. ISHB, EPA SESD, VI Guidance, Well
Construction Rules (NCAC 2C). Note deviations or methodology planned that is not covered by
such guidance (e.g., multi-increment sampling, passive air samplers).
_____ Describe what will be installed (soil boring, temporary well, permanent well, sub slab, soil gas, etc.).
Include construction details.
_____ Discuss installation methodology (Hand Auger, DPT, etc.)
_____ Discuss sample collection procedures. Include the following, at a minimum:
Equipment to be used
Purging methods and volumes
Stabilization parameters for groundwater sampling
Field screening methods
X
X
XX
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
Work Plan Checklist 
Version 1 November 2018 
Page 2 of 3 
Leak check procedures for sub-slab and soil gas samples
Discuss how and when vacuum readings will be collected (for summa cans)
_____ Discuss sample point abandonment
Section 4 – Laboratory Analyses
_____ Discuss the proposed analyses (include method number, preparation method, if there are concerns
with short hold times, etc).
_____ Discuss any proposed limitations on the contaminants of concern, if any, and the reason for such
limitation (sufficient previous data, indoor air interferences, etc).
_____ Discuss laboratory certifications. Please note, NC does not certify labs for air samples. Please
specify what certification the proposed air lab holds.
_____ Indicate the Reporting Limits/Method Detection Limits will meet applicable screening criteria (to
the extent feasible). Include Reporting of J-Flags to meet criteria.
_____ Indicate what Level QA/QC will be reported by the laboratory. Level II QA/QC is typically
acceptable.
Section 5 – QA/QC
_____ Specify the duplicate sample frequency. Minimum requirement: 1 duplicate per 20 samples, per
media, per method.
_____ Discuss Trip Blank. 1 Trip Blank per cooler/shipment of groundwater VOC analyses.
_____ Discuss how the lab will have sufficient sample volume for MS/MSD analyses.
_____ Discuss chain of custody and shipping.
Section 6 – Investigation Derived Waste (IDW) Management
_____ Discuss what IDW will be generated and how it is proposed to be managed. Management
recommendations should be in accordance with 15A NCAC 02T.1503 and 15A NCAC 02H. 0106.
Generally, if the Brownfields Property has not previously been assessed, then all IDW must be
containerized and characterized prior to management. Previous assessment data that indicate no
Hazardous Waste (listed or characteristic) is likely to be encountered in the area of proposed
assessment will be required before thin spreading of IDW on-site is permitted.
Section 7 – Reporting
This section should discuss the components of the assessment report which will be prepared as a result of
the above sample collection. At a minimum, the report shall include:
_____ Reporting/summary of site work conducted for all sections outlined above in this checklist;
_____ Summary of findings and possible recommendations;
_____ All applicable tables and figures outlined below with the addition of:
__ Tables for tabulated analytical data per media sampled and analyzed, compared against
applicable screening levels;
__ Figure depicting actual sample locations collected, with each media depicted in the legend,
graphic scale and north arrow; and
__ Groundwater potentiometric map, with graphic scale and north arrow,
_____ Firm PE/PG License Number
_____ Individual PE/PG seal & signature
X
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X
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XX
Work Plan Checklist 
Version 1 November 2018 
Page 3 of 3 
Attachments
_____ Table 1 – Proposed Sample Locations and Analyses on a Summary Table that includes:
__ Sample ID
__ Sample Objective
__ Proposed Depth(s)
__ Analytical Method(s)
__ QA/QC Samples
__ Background Samples
_____ Figure 1 – Site Location Map
__ Site location on a topographic map base.
__ Graphic scale and north arrow
_____ Figure 2 – Site Map should include the following
__ Buildings
__ Historical sample locations
__ RECs or other areas of concern
__ Proposed sample locations
__ Sample Identification labels
__ Background Samples
__ QA/QC Samples
__ Graphic scale and north arrow
__ High quality aerial suggested as the base map
_____ Figure 3 – Proposed Development (if available)
__ Overlay of historical and proposed sample locations,
__ Graphic scale and north arrow.
_____ Appendix – Summary of Historical Analytical Data (if needed)
X
X
X
X
More than three Figures due to
the size of the site
X
In Tables