18024_Allen Farm Supply_Response to PC FINAL_20160825

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Response to Comments Regarding Brownfields Agreement
Allen’s Farm Supply
511 North 3rd Street, Wilmington, New Hanover County, NC
Project # 18024-14-065
Public Comment Period
June 6, 2013 Through July 5, 2013

One comment was submitted during the draft Brownfields Agreement public comment period for
the Former Allen’s Farm Supply Property in Wilmington, NC. The comment was submitted by
the property owner of adjoining properties and contained concerns on three (3) issues, all of
which concerned potential impacts to the adjoining properties. None of the comments concerned
the development or restrictions being placed on the property subject to the Brownfields
Agreement. However, the commenters properties are situated hydraulically and physically
downgradient of the Brownfields Property. As such, the data and risk were re-evaluated to
ensure the restrictions contained in the Brownfields Agreement are protective of human health
and the environment for the adjoining properties. All comments concerning the draft
Brownfields Agreement were considered during the Brownfields decision process. The response
to comments are provided below. No changes are needed to the Brownfields Agreement as a
result of these comments.
The first issue, or question, raised was concerning whether the contaminants have “already
leached into the surrounding ground water to maximum levels as shown”.
Review of the data provided in Exhibit 2 to the Brownfields Agreement for sample
location MW-1 shows that concentrations of chromium and lead have decreased
significantly over the past two years. This indicated that the maximum impact to
groundwater has occurred.

The second issue concerned the “potential vaporization of contaminants when disturbed
and subsequent release to neighboring areas”.
Soil samples collected during the 2006 and 2008 sampling event were analyzed for
volatile organic compounds (VOCs) and semivolatile organic compounds (SVOCs) using
EPA Methods 8260 and 8270, respectively. No VOCs or SVOCs were detected in any of
the samples above method detection limits. Results for sample S-1 for Oil and Grease
Range Total Petroleum Hydrocarbons (TPH Oil & Grease) indicated the presence of TPH
Oil and Grease above the screening level used by DENR (now DEQ) at that time.
However, the constituent specific analyses, as mentioned above, did not detect any
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compounds at concentrations above the method detection limits. As such, no
vaporization of any contaminants will be possible.
The third issue concerns the possibility of contaminated soil eroding onto the adjoining
property due to the failure of retaining walls. The commenter states “I would also like to
make sure the appropriate retaining walls are put in place before any disturbance of the
ground on the 511 N. 3rd Street site is done, so no further erosion is done to the 518, 524,
and 526 N. 2nd Street sites and they will not continue to be effected by these contaminants.”
As discussed above, no VOCs or SVOCs were detected in the soil above the laboratory
method detection limits. Arsenic was detected in samples S-2, S-6 and S-7 at
concentrations ranging from 1.3 milligrams per kilogram (mg/Kg) to 3.03 mg/Kg. The
residential soil standard for arsenic is 0.68 mg/Kg. However, arsenic is a naturally
occurring metal commonly found in the area at concentrations similar to, or exceeding,
the concentrations found at the Brownfields Property. The arsenic detected at the
Property is considered naturally occurring. As such, any eroding soil from the
Brownfields Property will not pose any environmental risk for down gradient properties.
The issue of failing retaining walls is not within the scope of the Brownfields Program as
erosion or movement of this particular soil by such means does not pose a public health
risk. In addition, information provided by the surveyors who surveyed the site and
produced the plat indicated that the retaining walls were not located on the property
defined as the Brownfields Property. However, the Prospective Developer for the site
will be informed of the concern and asked to contact the commenter for further
discussion.