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HomeMy WebLinkAboutRobbins Mill Phase II Scope of Work-OCRA5. PROBLEM DEFINITION/BACKGROUND/CONCEPTUAL SITE MODEL) The Town of Robbins, North Carolina, has been awarded a Brownfields Assessment Grant from the EPA under Cooperative Agreement Number BF-00D11513-0. Funding from this grant will be utilized to conduct a Phase II ESA at the Mill Site located at 200 S. Kennedy Street in Robbins, North Carolina. The Town is interested in acquiring the Mill property once the required due diligence is fulfilled. Community members have proposed several different ideas and visions for the redevelopment of the Mill. For example, one vision is to develop a soccer field, recreation space, and affordable housing on the 15-acre property, which complements the efforts already underway by the Northern Moore Family Resource Center (NMFRC) to improve the surrounding homes of the mill village. By providing more safe and affordable housing within walking distance around the new soccer fields, the neighborhood will increase in value simply by increasing the desire to live near the recreational amenity. By clarifying the environmental conditions at the Mill via the Phase II ESA, the Town can then develop a plan and secure necessary funding to clean up the property and render it safe for the future planned reuse. This QAPP addendum was developed to meet the requirements of the Brownfield Assessment Grant between the Town and the EPA, to meet the recommendations of the DENR, and to address Recognized Environmental Concerns (RECs) found during Phase I ESAs conducted by Cardno in September 2013. A5.1 Site Location and Description The Mill site consists of an approximately 12-acre parcel of land located at 200 S. Kennedy Street in Robbins, North Carolina. According to the Moore County Tax Assessor’s Office, the Mill property consists of 12.19 calculated acres and 15.71 deeded-acres. A Site Location Map, consisting of the relevant portions of the United States Geological Survey (USGS) topographic maps, Robbins Quadrangle, is included as Figure 2. An aerial photo from 2012 depicting the layout of the site and surrounding properties is provided as Figure 3. The Mill once occupied the subject property; however, a fire in 2008 destroyed the Mill structures and debris remains on-site. A5.2 Site and Regional Characteristics According to the USGS and the North Carolina Geologic Survey (NCGS), the subject property is located in the Piedmont along the Fall Line of North Carolina. The Fall Line along the eastern coast of the United States is an east-facing escarpment where the Piedmont Physiographic Province descends steeply to the Atlantic Coastal Plain. The Fall Line marks the boundary between the hard-metamorphosed terrain of the Piedmont and the sandy, relatively flat outwash plain of the upper Coastal Plain, which consists primarily of Cretaceous and Tertiary sediments. According to the Groundwater Atlas of the United States, the most widespread aquifers in the Piedmont and Blue Ridge Provinces are the crystalline-rock and undifferentiated sedimentary-rock aquifers. Most of the rocks that compose these aquifers are crystalline metamorphic and igneous rocks of many types. The main types of crystalline rocks are coarse-grained gneisses and schists of various mineral composition; however, fine-grained rocks, such as phyllite and metamorphosed volcanic rocks, are common in places. The undifferentiated sedimentary-rock aquifers consist of tightly cemented, predominately clastic rocks, many of which grade into metamorphic rocks. Unconsolidated material called regolith overlies the crystalline-rock and undifferentiated sedimentary-rock aquifers almost everywhere. The regolith consists of saprolite, colluvium, alluvium, and soil. Saprolite is a blanket of decomposed or partially decomposed rock that is usually thick and clayey, and whose texture varies depending on the type of parent bedrock from which the saprolite is derived. Colluvium is weathered rock material that has slumped downward from hillsides. Alluvium consists mostly of water-transported sediment in stream valleys and channels. Because the regolith material varies greatly in thickness, composition, and grain size, its hydraulic properties also vary greatly. Groundwater in the Piedmont physiographic province is typically found in unconfined or semi-confined conditions with a flow that generally mimics the topography. The USGS Topographic Map, Robbins Quadrangle (Figure 2), indicates that groundwater is expected to follow the topography flowing northwest from the subject property. A5.3 Current and Historic Uses of the Subject Property Currently, the property is vacant and abandoned with the rubble from the fire still scattered across the property. The Mill, a former Milliken Textile Plant, was a woolen weaving mill bought from Amerotron. Textile manufacturing is based in the conversion of three types of fiber into yarn, then fabric, then textiles. These are then fabricated into clothes or other artifacts. The Mill was only used for the spinning and fabric-forming stages and was destroyed by fire on August 17, 2008. There is a partial chain linked fence around the property that has been patched together with barbed wire with an access point along Kennedy Street. The site itself has concrete slabs covered in pieces of brick and burned lumber. Vegetation is growing through the concrete in some locations and is growing free in areas not covered by concrete. There is a standing smoke stack on the premises with two above ground storage tanks (ASTs) sitting on the ground beside it. The layout of the subject property is depicted on Figure 3, which includes an aerial photograph of the site and surrounding properties. A5.4 Previous Site Assessments 2013 Phase I ESA: Cardno completed a Phase I ESA of the subject property in September 2013. During the assessment, Cardno identified the following RECs associated with the subject property: • The former Robbins Plant is listed in the Underground Storage Tank (UST)/AST database as a non-geocoded site. Inclusion of the subject property in the UST/AST database constitutes a REC; • The property has historically been used as a textile mill. Activities including weaving and sewing have occurred on this property. The potential for on-site contamination associated with the past use of hazardous substances in conjunction with the former textile manufacturing processes exists; • A smoke stack containing coal residue was observed on the subject property. There is a potential for contamination to exist associated with the use of coal; • Two ASTs were observed on property adjacent to the smokestack one potentially containing fuel oil and the other has unknown contents; • The owner of the property stated that drums of unknown content were stored on site. There is a potential for a release to have occurred from these drums; • The inclusion of the U. Sign Company, Inc. in the Resource Conservation and Recovery Act (RCRA) Generators database and RCRA NonGen database constitutes a REC; • During the site reconnaissance, Cardno did not observe any evidence of the use of polychlorinated biphenyls (PCBs). Trash and debris on-site created a limiting condition on site which made it impossible to determine if a transformer pad was present on the subject property; • Debris located on site created a limiting condition obstructing the view of any potential evidence of floor drains or sumps during the site reconnaissance. The limiting conditions present on the subject property prevent the Environmental Professional (EP) from making a determination as to RECs associated with floor drains and sumps; therefore, pending additional assessment, the likely presence of floor drains and sumps constitutes a REC; and • Due to the age of the structure, professional experience on similar sites, and suspect building materials identified in the debris piles, the presence of Asbestos Containing Materials (ACM) and/or Lead-Based Paint (LBP) is highly likely. The presence of ACM and LBP were not verified by licensed professionals as part of the assessment, however. Cardno recommended that a Phase II ESA be conducted to determine the soil and/or groundwater conditions at the site. A5.5 Chemicals of Concern Operations at the Mill facility were primarily mechanical in nature (carding, spinning, and weaving), and dyeing and finishing processes are not believed to have occurred on-site. Materials that could have been used during the day-to-day operation and maintenance of the plant include numerous substances of environmental concern such as petroleum products, solvents, hydraulic fluids and transformers potentially containing PCBs, paints, etc. In addition, evidence suggests that coal was once stored on the subject property. Additionally, given the construction dates of the plant structures, asbestos is likely to be present in certain building materials. A5.7 Purpose of Assessment The Town of Robbins is interested in acquiring the property and pursuing a cleanup grant to remove all debris and contamination from the subject site. Once the property is cleaned, the Town of Robbins would like to encourage redevelopment of the property to further instigate revitalization in the town. This QAPP has been prepared to support these cleanup and redevelopment efforts. The Phase II ESA will be performed to determine the extent of soil and groundwater contamination that may require remedial actions by fully delineating areas of soil and groundwater contamination within areas discovered during the Phase I ESA (Figure 4). This information will then be used to determine the extent of soils that may require removal and/or if further assessment is necessary. The project-specific DQOs for the subject property are summarized in Table 1. A6. PROJECT/TASK DESCRIPTION AND SCHEDULE The basis for the work scope is the findings of the previous Phase I ESA completed by Cardno with considerations for intended future reuse of the site known at this time. In addition to the collection of soil and groundwater sample collection for laboratory analysis (quantitative data), general observations including soil lithology and general site conditions (qualitative data) will also be made to aid in the decision making process. A6.1 Sampling Plan Soil and groundwater samples will be collected at predetermined locations based on the findings of the September 2013 Phase I ESA, recommendations made by DENR, and the judgment of experienced Cardno personnel. The proposed soil boring and groundwater monitoring well locations are illustrated on Figure 5. Table 2 provides the analysis criteria for each sample including QA/QC samples. The field staff will be provided with a copy of this plan for reference while in the field. All boring and sample collection activities will be conducted in accordance with the EPA Region 4 Science and Ecosystem Support Division (SESD) Field Branches Quality System and Technical Procedures as identified in Table 2. The investigation-derived waste (IDW) generated during the assessment activities will consist of soil cuttings and purged groundwater. All IDW will be containerized in 55-gallon drums and stored on-site pending the results of laboratory analysis. Based on the analytical results, the IDW will be disposed of properly. The following subsections discuss the tasks associated with assessing the various sample media at the subject property. A6.2 Field Measurements Soil borings in the areas of petroleum contaminants will be field screened for organic vapors via headspace analysis using a photoionization detector (PID) and visual and olfactory observations. Groundwater monitoring wells will be installed and sampled on the subject property. After installation and development, groundwater levels in the newly installed monitoring wells will be allowed to recover for a period of at least 24 hours. Upon recovery, the groundwater levels will be gauged with an electric water level meter capable of measuring the depth to the air/liquid interface to within +/- 0.01 foot. Water level measurements will be collected from all site wells within a 24-hour period to ensure that the groundwater flow gradient and direction can be accurately determined. Groundwater elevations will be calculated based on top of casing (TOC) elevations measured during the site survey. Groundwater elevations will be used to prepare a potentiometric surface map illustrating the groundwater flow direction and gradient at the site. Prior to groundwater sample collection, each monitoring well will be purged via the low- flow method using a variable speed peristaltic pump and new dedicated tubing (or with a variable speed, electric submersible pump if groundwater depths prohibit the use of peristaltic pumps) until consistent values (i.e., less than 10% variance between consecutive readings) are obtained for dissolved oxygen, specific conductivity, and temperature, and consecutive pH measurements are within ± 0.2 pH units, or, if drawdown cannot be controlled during low-flow sampling, the monitoring well formation fails to recharge (i.e. the well runs dry). Turbidity will be monitored during purging with a calibrated turbidity meter. These measurements will be collected during the purging process to ensure that representative groundwater samples are obtained. A6.3 Laboratory Testing Based on the known historical uses of the on-site RECs identified, all constituents of concern within the following analytical method categories have been identified for this assessment and include the following: • Target Analyte List (TAL) Metals by EPA Methods 6010 and 7470; • Target Compound List (TCL) Volatile Organic Compounds (VOCs) by EPA Methods 8260B and 5035; • TCL Semi-Volatile Organic Compounds (SVOCs) with low level PAHs by EPA Method 8270D and 8270D SIM; and • PCBs by EPA Method 8082. The Listings of Accredited Analyses, detailing all analytes, are provided in Pace Analytical’s QAM included as Appendix A. A6.4 Soil Samples (Critical) Surface and subsurface soil assessment is planned at the following Areas of Concern (AOCs): Coal Bunker, Oil Boiler, Smoke Stack, and AST (AOC–1): In order to assess soil conditions in and adjacent to the footprint of the former coal bunker, oil boiler, smoke stack and AST, three soil borings (SS-1 through SS-3) will be advanced to an approximate depth of five feet below ground surface (BGS) to facilitate the collection of both a surface soil sample (0-1 foot BGS interval) and subsurface soil sample (collected from a minimum depth of 2 feet BGS). In addition, two soil borings (SS-4 and SS-5) on either side of the AST will be advanced to groundwater to facilitate the collection of both a surface soil sample (0-1 foot BGS interval) and subsurface soil sample (collected from the interval with the highest PID reading or if no OVA readings are detected, then from the 2-4 foot BGS interval). Shipping Warehouse (AOC–2): In order to assess soil conditions in and adjacent to the footprint of the shipping warehouse, four soil borings (SS-6 through SS-9) will be advanced to an approximate depth of five feet BGS to facilitate the collection of both a surface soil sample (0-1 foot BGS interval) and subsurface soil sample (collected from a minimum depth of 2 feet BGS). Spinning Operations and Fire Pump Station (AOC–3): In order to assess soil conditions in and adjacent to the spinning operations and fire pump station, two soil borings (SS-10 and SS-11) will be advanced to an approximate depth of five feet BGS to facilitate the collection of both a surface soil sample (0-1 foot BGS interval) and subsurface soil sample (collected from a minimum depth of 2 feet BGS). Maintenance Shop and Electrical Switch Room (AOC–4): In order to assess soil conditions in and adjacent to the footprint of the maintenance shop and electrical switch room, six soil borings (SS-12 through SS-17) will be advanced to an approximate depth of five feet BGS to facilitate the collection of both a surface soil sample (0-1 foot BGS interval) and subsurface soil sample (collected from a minimum depth of 2 feet BGS). Shop Warehouse and Basement (AOC–5): In order to assess soil conditions in and adjacent to the footprint of the shop warehouse and basement containing chemical storage of Varsol, oil, and cleaning solvents, six soil borings (SS-18 through SS-23) will be advanced to an approximate depth of five feet BGS to facilitate the collection of both a surface soil sample (0-1 foot BGS interval) and subsurface soil sample (collected from a minimum depth of 2 feet BGS). Sub-Basement (AOC–6): In order to assess soil conditions in and adjacent to the footprint of the sub-basement where tires and plastic barrels were stored, two soil borings (SS-24 and SS-25) will be advanced to an approximate depth of five feet BGS to facilitate the collection of both a surface soil sample (0-1 foot BGS interval) and subsurface soil sample (collected from a minimum depth of 2 feet BGS). Preparation Department and Weave Room (AOC–7): In order to assess soil conditions in and adjacent to the footprint of the preparation department and weave room, which potentially housed a large oil compressor, one soil boring (SS-26) will be advanced to an approximate depth of five feet BGS to facilitate the collection of both a surface soil sample (0-1 foot BGS interval) and subsurface soil sample (collected from a minimum depth of 2 feet BGS). Background (AOC–8): In order to supply background data for the soil samples taken at the site, two soil borings will be installed and soil samples collected for analysis. The first soil boring (SS-27), located in the footprint of the previous truck parking will be advanced to an approximate depth of five feet BGS to facilitate the collection of both a surface soil sample (0-1 foot BGS interval) and subsurface soil sample (collected from a minimum depth of 2 feet BGS). The second soil boring (SS-28), located in the small grass area at the corner of Hemp and Pinehurst will be advanced to an approximate depth of five feet BGS to facilitate the collection of both a surface soil sample (0-1 foot BGS interval) and subsurface soil sample (collected from a minimum depth of 2 feet BGS). There are no critical sampling conditions under which the data should be collected. The data will be used to determine the absence or presence of chemicals of concern in site soils and will identify the need for additional assessment and/or remediation. A6.5 Groundwater Sampling (Critical) Nine shallow groundwater monitoring wells are planned to be installed in order to assess groundwater conditions at the site. The monitoring wells will be positioned in order to assess groundwater conditions in areas of concern identified during the Phase I ESA. The permanent groundwater monitoring wells will be installed in the following locations: • A monitoring well (MW-1) will be installed in AOC–1 and collocated with SS-5 to assess for potential petroleum related compounds or hazardous substances associated with coal storage, ASTs, and oil boiler; • A monitoring well (MW-2) will be installed on the northeast property line midway between AOC–2 and AOC-4 to assess for potential petroleum related compounds or hazardous substances possibly leaving the boundaries of the site; • A monitoring well (MW-3) will be installed on the east side of the property near the electrical switch room (AOC–4) to assess for potential petroleum related compounds or hazardous substances; • A monitoring well (MW-7) will be installed at the southeast corner of the building footprint to assess for potential petroleum related compounds or hazardous substances possibly leaving the boundaries of the site; • A monitoring well (MW-4) will be installed in AOC-5 and collocated with SS-20 to assess for potential hazardous substances associated with the chemical storage basement; • A monitoring well (MW-5) will be installed in AOC-6 and collocated with SS-24 to assess for potential petroleum related compounds or hazardous substances associated with tires and plastic barrels stored in the subbasement; • A monitoring well (MW-6) will be installed in AOC-7 and collocated with SS-26 to assess for potential petroleum related compounds or hazardous substances associated with the large oil compressor and other activities in the preparation department and weave room; • Background monitoring wells (MW-8 and MW-9) will be installed in the footprint of the previous parking area and collocated with SS-27, in the small grass area at the corner of Hemp and Pinehurst and collocated with SS-28. There are no critical sampling conditions under which the data should be collected. The information collected from these wells will provide information regarding the groundwater flow direction and gradient as well as the absence or presence of chemicals of concern in groundwater at the site. This data will determine the need for additional assessment and/or remediation. A6.6 Non-Critical Determinations Non-critical determinations made during the soil boring installation/soil sample collection activities will include describing soil characteristics such as lithology. This information will be used to supplement the critical data; it is not needed to make the decision of whether or not remediation is necessary. A6.7 Regulatory Standards Soil data will be compared to the residential criteria for direct soil exposure and the Maximum Contaminant Level (MCL)-Based Soil Screening Level (SSL), as listed in the EPA Regional Screening Levels (RSLs) for Chemical Contaminants at Superfund Sites (November 2013). Groundwater data will be compared to the North Carolina Class GA MCLs set forth in the State Groundwater Quality Standards 15A NCAC 02L.0202 (April 2013). For constituents which do not have a Class GA MCL, groundwater analytical results will be compared to the published EPA MCLs and/or the published EPA Residential Tapwater values (November 2013). A6.8 Data Use Surface soil, subsurface soil, and groundwater samples will be collected to provide analytical data for site characterization. The significance and nature of impacts to the areas of concern will be determined by direct evaluation of the analytical data generated. If analytes are not detected or are detected in the soil samples at concentrations below the EPA residential RSLs, and, if analytes are not detected or are detected in groundwater at concentrations below North Carolina Class GA MCLs, EPA MCLs, and/or EPA Residential Tapwater values, then it can be concluded that the contaminants of concern identified on the Mill site do not pose a significant threat to human health or the environment. If analytes are found above regulatory criteria in the soil or groundwater, then the degree to which these impacts affect redevelopment of the site must be evaluated. Further assessment and/or an ABCA, which may evaluate remedial actions and/or institutional controls, would then be recommended. A6.9 Schedule The anticipated start date for sample collection will be based on the final approval of this Site-Specific QAPP Addendum. The field activities will commence no later than 30 days of the Site-Specific QAPP Addendum approval and within 14 days if the drilling schedule allows for initiation of field activities within 14 days of approval. Sample collection and associated fieldwork should take approximately seven days to complete. Samples will be shipped overnight to the laboratory throughout the duration of the project. Laboratory results will be sent to the Cardno project manager within 14 business days of sample receipt. The draft Phase II ESA report should be completed within 30 days after receipt of the laboratory results. A7. SPECIAL TRAINING REQUIREMENTS/CERTIFICATION Pace Analytical Laboratory’s QAM is provided as Appendix A. All other training requirements and certifications are provided under the Generic QAPP document. A8. DOCUMENTS AND RECORDS Documentation and Records requirements are provided under the Generic QAPP document. B1. SAMPLING DESIGN PROCESS The proposed Phase II ESA will evaluate potential environmental impacts to soil and groundwater in areas of concern identified during previous assessment activities. The sample collection design, as proposed, was based on the findings of the September 2013 Phase I ESA completed by Cardno and the recommendations provided by the DENR. Collection of samples will not be random because they are intended to evaluate/delineate potential releases due to specifically located activities and/or items. Proposed sampling locations may be adjusted in the field based on site conditions and features. A proposed Sample Location Map for the subject property is included as Figure 5. The type and number of samples required, including the rationale, locations, and sample media are provided in Table 2. The following scope of work has been developed by Cardno based on the findings of earlier investigations conducted on the subject property. B1.1 Soil Sample Collection Both surface soil and subsurface soil samples will be collected during the Phase II ESA activities. Continuous soil cores will be collected at eight (8) locations on the subject property via a direct-push technology (DPT) rig using disposable cellulose acetate butyrate (CAB) core barrel liners, a decontaminated stainless steel hand auger to facilitate the collection of surface and subsurface soil samples, or a conventional hollow stem auguring system for areas covered by concrete/asphalt. Soils collected in each sample interval will be homogenized using decontaminated stainless steel bowls and spoons and the sample containers will be filled. Proposed soil boring locations are indicated on Figure 5. Coal Bunker, Oil Boiler, Smoke Stack, and AST (AOC–1): In order to assess soil conditions in and adjacent to the footprint of the former coal bunker, oil boiler, smoke stack and AST, three soil borings (SS-1 through SS-3) will be advanced to an approximate depth of five feet below ground surface (BGS) to facilitate the collection of both a surface soil sample (0-1 foot BGS interval) and subsurface soil sample (collected from a minimum depth of 2 feet BGS). In addition, two soil borings (SS-4 and SS-5) on either side of the AST will be advanced to groundwater to facilitate the collection of both a surface soil sample (0-1 foot BGS interval) and subsurface soil sample (collected from the interval with the highest PID reading or if no OVA readings are detected, then from the 2-4 foot BGS interval). Shipping Warehouse (AOC–2): In order to assess soil conditions in and adjacent to the footprint of the shipping warehouse, four soil borings (SS-6 through SS-9) will be advanced to an approximate depth of five feet BGS to facilitate the collection of both a surface soil sample (0-1 foot BGS interval) and subsurface soil sample (collected from a minimum depth of 2 feet BGS). Spinning Operations and Fire Pump Station (AOC–3): In order to assess soil conditions in and adjacent to the spinning operations and fire pump station, two soil borings (SS-10 and SS-11) will be advanced to an approximate depth of five feet BGS to facilitate the collection of both a surface soil sample (0-1 foot BGS interval) and subsurface soil sample (collected from a minimum depth of 2 feet BGS). Maintenance Shop and Electrical Switch Room (AOC–4): In order to assess soil conditions in and adjacent to the footprint of the maintenance shop and electrical switch room, six soil borings (SS-12 through SS-17) will be advanced to an approximate depth of five feet BGS to facilitate the collection of both a surface soil sample (0-1 foot BGS interval) and subsurface soil sample (collected from a minimum depth of 2 feet BGS). Shop Warehouse and Basement (AOC–5): In order to assess soil conditions in and adjacent to the footprint of the shop warehouse and basement containing chemical storage of Varsol, oil, and cleaning solvents, six soil borings (SS-18 through SS-23) will be advanced to an approximate depth of five feet BGS to facilitate the collection of both a surface soil sample (0-1 foot BGS interval) and subsurface soil sample (collected from a minimum depth of 2 feet BGS). Sub-Basement (AOC–6): In order to assess soil conditions in and adjacent to the footprint of the sub-basement where tires and plastic barrels were stored, two soil borings (SS-24 and SS-25) will be advanced to an approximate depth of five feet BGS to facilitate the collection of both a surface soil sample (0-1 foot BGS interval) and subsurface soil sample (collected from a minimum depth of 2 feet BGS). Preparation Department and Weave Room (AOC–7): In order to assess soil conditions in and adjacent to the footprint of the preparation department and weave room, which potentially housed a large oil compressor, one soil boring (SS-26) will be advanced to an approximate depth of five feet BGS to facilitate the collection of both a surface soil sample (0-1 foot BGS interval) and subsurface soil sample (collected from a minimum depth of 2 feet BGS). Background (AOC–8): In order to supply background data for the soil samples taken at the site, two soil borings will be installed and soil samples collected for analysis. The first soil boring (SS-27), located in the footprint of the previous truck parking will be advanced to an approximate depth of five feet BGS to facilitate the collection of both a surface soil sample (0-1 foot BGS interval) and subsurface soil sample (collected from a minimum depth of 2 feet BGS). The second soil boring (SS-28), located in the small grass area at the corner of Hemp and Pinehurst will be advanced to an approximate depth of five feet BGS to facilitate the collection of both a surface soil sample (0-1 foot BGS interval) and subsurface soil sample (collected from a minimum depth of 2 feet BGS). In order to minimize losses due to volatilization during sample collection, samples for VOC analysis will be obtained directly from the CAB liner or hand auger bucket using a laboratory supplied, disposable sampling device and will not be homogenized prior to placement within the laboratory-prepared sample containers. After the samples for VOC analysis have been collected and placed within the appropriate sample containers, the remainder of the soils in the sample interval will be homogenized using decontaminated stainless steel bowls and spoons and the sample containers for the remaining analytes (metals, SVOCs, PCBs, etc.) will be filled. B1.2 Monitoring Well Installation/Groundwater Sample Collection Nine shallow groundwater monitoring wells are planned to be installed in order to assess groundwater conditions at the site. The monitoring wells will be positioned in order to assess groundwater conditions in areas of concern identified during the Phase I ESA. The permanent groundwater monitoring wells will be installed in the following locations: • A monitoring well (MW-1) will be installed in AOC–1 and collocated with SS-5 to assess for potential petroleum related compounds or hazardous substances associated with coal storage, ASTs, and oil boiler; • A monitoring well (MW-2) will be installed on the northeast property line midway between AOC–2 and AOC-4 to assess for potential petroleum related compounds or hazardous substances possibly leaving the boundaries of the site; • A monitoring well (MW-3) will be installed on the east side of the property near the electrical switch room (AOC–4) to assess for potential petroleum related compounds or hazardous substances; • A monitoring well (MW-7) will be installed at the southeast corner of the building footprint to assess for potential petroleum related compounds or hazardous substances possibly leaving the boundaries of the site; • A monitoring well (MW-4) will be installed in AOC-5 and collocated with SS-20 to assess for potential hazardous substances associated with the chemical storage basement; • A monitoring well (MW-5) will be installed in AOC-6 and collocated with SS-24 to assess for potential petroleum related compounds or hazardous substances associated with tires and plastic barrels stored in the subbasement; • A monitoring well (MW-6) will be installed in AOC-7 and collocated with SS-26 to assess for potential petroleum related compounds or hazardous substances associated with the large oil compressor and other activities in the preparation department and weave room; • Background monitoring wells (MW-8 and MW-9) will be installed in the footprint of the previous parking area and collocated with SS-27, in the small grass area at the corner of Hemp and Pinehurst and collocated with SS-28. The proposed locations of the groundwater monitoring wells are depicted on Figure 5. The groundwater monitoring wells will be installed under the direct supervision of a North Carolina certified well driller and all installation activities will conform to Rule .0108 of the North Carolina Well Construction Standards (October 1, 2009). The monitoring wells will be installed using a DPT rig equipped with auger drilling capabilities or, if necessary due to site conditions, a rotary drill rig advancing 4.25- inch inside diameter hollow-stem augers. If auger refusal is encountered prior to reaching groundwater, an air rotary rig may be utilized for the groundwater well installation. A continuous soil core will be collected at each boring location from the ground surface until the water table is encountered via a DPT rig utilizing a core barrel fitted with disposable CAB liners prior to advancing the hollow-stem augers. Soil core collection will allow Cardno personnel to log the subsurface lithology encountered, will identify the depth to the water table, and in select locations will allow for the collection of soil samples. If site conditions warrant the use of an air rotary rig, the subsurface lithology will be logged via air rotary cuttings. The groundwater monitoring wells will be constructed using a 2-inch diameter, Schedule 40, flush threaded, polyvinyl chloride (PVC) casing fitted with a 2-inch diameter, Schedule 40 PVC, factory milled, 0.01-inch slot size, screened section. The screened section will be 10 feet in length and will be placed at a depth bracketing the water table, with the majority of the screen submerged. After placing the well screen and riser in the borehole, an artificial filter pack will be placed from the terminus of the borehole to approximately two feet above the screened section. The filter pack will be followed by a bentonite plug, which is a minimum of two feet in thickness and hydrated. The borehole will be sealed to a depth of approximately six inches below ground surface using a Portland cement/bentonite grout to allow for the placement of a lockable steel protective casing around the riser and the completion of a six-inch thick, two-foot by two-foot, concrete well pad. The steel protective casing will extend approximately three feet above the well pad/ground surface and will be fitted with a steel well tag providing, at a minimum, the well ID, total depth, screened interval, and date installed. A schematic of a typical shallow groundwater monitoring well is included as Figure 6. As-built construction logs of the groundwater monitoring wells will be generated after installation. Additionally, the well driller shall complete a Well Construction Record (Form GW-1, August 2013) for submittal to the DENR for each monitoring well installed. Post installation, the monitoring wells will be developed by over pumping and the use of a surge block (if warranted by the presence of an excessive amount of fines) until clear, relatively sediment-free water is produced. The horizontal positions of the wells will be determined using a hand held GPS and TOC elevations will be referenced to a local arbitrary datum of 100 feet. The TOC elevations will be used to calculate the groundwater flow direction and hydraulic gradient. Groundwater levels will be gauged with an electric water level meter capable of measuring the depth to the air/liquid interface to within +/- 0.01 foot. Water level measurements will be collected from all site wells within a 24-hour period to ensure that the groundwater flow gradient and direction can be accurately determined. Groundwater elevations will be calculated based on the surveyed TOC elevations and a water-level map will be prepared to illustrate the groundwater flow direction and gradient at the site. Prior to groundwater sample collection, each monitoring well will be purged via the low- flow method using a variable speed peristaltic pump and new dedicated tubing (or with a variable speed, electric submersible pump if groundwater depths prohibit the use of peristaltic pumps) until consistent values (i.e., less than 10% variance between consecutive readings) are obtained for dissolved oxygen, specific conductivity, and temperature, and consecutive pH measurements are within ± 0.2 pH units, or, if drawdown cannot be controlled during low-flow sampling, the monitoring well formation fails to recharge (i.e. the well runs dry). Turbidity will be monitored during purging with a calibrated turbidity meter. These measurements will be collected during the purging process to ensure that representative groundwater samples are obtained. The monitoring wells will be sampled using low-flow techniques with a variable speed peristaltic pump (or with a variable speed, electric submersible pump if groundwater depths prohibit the use of peristaltic pumps). Sample bottles for VOCs will be filled first, followed by bottles for the remaining additional analyses. Sample containers will be supplied by the contract analytical laboratory, Pace Analytical Laboratory, Inc., and will be pre-preserved by the laboratory in accordance with the analytical method to be performed. The laboratory will provide preservation methods for the various analytics. The results of the groundwater-sampling event will determine the need for the installation of additional monitoring wells. B1.2 Quality Assurance/Quality Control Samples QA/QC samples to be submitted for laboratory analysis will include three equipment blanks, three field blanks, two duplicate soil samples, one duplicate water sample, and one temperature blank per sample cooler. The equipment blanks and field blanks will be analyzed for PCBs, TCL SVOCs, TCL VOCs, and TAL Metals. Duplicate sample analyses will mirror the analyses requested for their respective base samples. The quality control samples will be labeled on the sample bottles and chain-of-custody forms, as appropriate. B1.3 Authorizations, Permits, and Clearances On-site activities associated with this project will not commence until the proper authorizations, permits, and clearances are obtained, as applicable. These may include, but are not limited to, the following items. • Cable/Utilities Clearance: Prior to the field activities, North Carolina 811 will be contacted to conduct a utility survey. Where possible, a hand auger or post-hole digger will be used for the first three to four feet prior to initiating drilling in order to minimize the potential for hitting underground utilities. In addition, any site maps available will be reviewed and a geophysical survey will be conducted, if necessary, to locate any underground pipelines, utilities, or structures; • Monitoring Well Approval: The Cardno Project Manager will obtain monitoring well approval from the DENR prior to conducting the field activities. This approval is pursuant to the provisions of Section 15A NCAC 2C.0108 of the North Carolina Administrative Code Title 15A (October 1, 2009); and • Eric Johnson owns the property and has provided access to the Town of Robbins and its consultants for performance of this Phase II ESA. Cardno personnel will oversee the installation of the soil borings; log the subsurface materials encountered during soil boring installation; and collect the soil samples. Upon completion of the sampling effort, Cardno will produce a Phase II ESA report summarizing the field activities. The report will include a narrative of the field event; copies of all field forms generated; and tables and figures summarizing the soil analytical data. Analytical data will be compared to the regulatory standards referenced in Section A6 to identify constituents and areas of concern. B2. SAMPLING AND ANALYTICAL METHODS REQUIREMENTS To ensure that potential chemicals/contaminants of concern (COCs) are identified, the soil samples collected will be analyzed for the parameters as detailed in Section B1. The proposed sample locations for the subject property are depicted on Figure 5. Table 2 provides a summary of sample locations, rationale, laboratory analyses, and required QA/QC samples. Based on conditions observed during implementation of the field activities, adjustments may be required to the sampling plan. Table 2Sampling Locations and Analyses SummaryPhase II ESA Former Robbins Mill Robbins, North Carolina Sample Media Sample Total Sample ID Analyses Rationale Standard Operating Procedure Coal Bunker, Oil Boiler, and Smoke Stack (AOC - 1) Soil Groundwater 5 Surface Soil 5 Subsurface Soil 1 Groundwater SS-1 through SS-5 MW-1 Surface Soil TAL Metals EPA Methods 6010, 7471 TCL VOCs EPA Methods 8260B, 5035 TCL SVOCs EPA Method 8270D, 8270D SIM Asbestos (Polarized Light Microscopy) Subsurface Soil TAL Metals EPA Methods 6010, 7471 TCL VOCs EPA Methods 8260B, 5035 TCL SVOCs EPA Method 8270D, 8270D SIM Groundwater TAL Metals EPA Methods 6010, 7471 TCL VOCs EPA Methods 8260B, 5035 TCL SVOCs EPA Method 8270D, 8270D SIM Assess soils and groundwater for potential petroleum and hazardous contamination associated with Coal and Oil use. SESDPROC-300-R1 Soil Sampling SESDPROC-301-R1 Groundwater Sampling Shipping Warehouse (AOC - 2)Soil 4 Surface Soil 4 Subsurface Soil SS-6 through SS-9 Surface Soil TAL Metals EPA Methods 6010, 7471 TCL VOCs EPA Methods 8260B, 5035 TCL SVOCs EPA Method 8270D, 8270D SIM Asbestos (Polarized Light Microscopy) Subsurface Soil TAL Metals EPA Methods 6010, 7471 TCL VOCs EPA Methods 8260B, 5035 TCL SVOCs EPA Method 8270D, 8270D SIM Assess soils for potential petroleum and hazardous contamination. SESDPROC-300-R1 Soil Sampling Spinning Operations and Fire Pump Station (AOC - 3) Soil 2 Surface Soil 2 Subsurface Soil SS-10 and SS-11 Surface Soil TAL Metals EPA Methods 6010, 7471 TCL VOCs EPA Methods 8260B, 5035 TCL SVOCs EPA Method 8270D, 8270D SIM Asbestos (Polarized Light Microscopy) Subsurface Soil TAL Metals EPA Methods 6010, 7471 TCL VOCs EPA Methods 8260B, 5035 TCL SVOCs EPA Method 8270D, 8270D SIM Assess soils for potential petroleum and hazardous contamination. SESDPROC-300-R1 Soil Sampling Maintenance Shop and Electrical Switch Room (AOC - 4) Soil Groundwater 6 Surface Soil 6 Subsurface Soil 1 Groundwater SS-12 through SS-17 MW-3 Surface Soil TAL Metals EPA Methods 6010, 7471 TCL VOCs EPA Methods 8260B, 5035 TCL SVOCs EPA Method 8270D, 8270D SIM TCL PCBs EPA Method 8082 Asbestos (Polarized Light Microscopy) Subsurface Soil TAL Metals EPA Methods 6010, 7471 TCL VOCs EPA Methods 8260B, 5035 TCL SVOCs EPA Method 8270D, 8270D SIM TCL PCBs EPA Method 8082 Groundwater TAL Metals EPA Methods 6010, 7471 TCL VOCs EPA Methods 8260B, 5035 TCL SVOCs EPA Method 8270D, 8270D SIM TCL PCBs EPA Method 8082 Assess soils and groundwater for potential petroleum and hazardous contamination. SESDPROC-300-R1 Soil Sampling SESDPROC-301-R1 Groundwater Sampling Shop Warehouse and Basement (AOC - 5) Soil Groundwater 6 Surface Soil 6 Subsurface Soil 1 Groundwater SS-18 through SS-23 MW-4 Surface Soil TAL Metals EPA Methods 6010, 7471 TCL VOCs EPA Methods 8260B, 5035 TCL SVOCs EPA Method 8270D, 8270D SIM Asbestos (Polarized Light Microscopy) Subsurface Soil TAL Metals EPA Methods 6010, 7471 TCL VOCs EPA Methods 8260B, 5035 TCL SVOCs EPA Method 8270D, 8270D SIM Groundwater TAL Metals EPA Methods 6010, 7471 TCL VOCs EPA Methods 8260B, 5035 TCL SVOCs EPA Method 8270D, 8270D SIM Assess soils and groundwater for potential petroleum and hazardous contamination. SESDPROC-300-R1 Soil Sampling SESDPROC-301-R1 Groundwater Sampling Sub-Basement (AOC - 6) Soil Groundwater 2 Surface Soil 2 Subsurface Soil 1 Groundwater SS-24 and SS-25 MW-5 Surface Soil TAL Metals EPA Methods 6010, 7471 TCL VOCs EPA Methods 8260B, 5035 TCL SVOCs EPA Method 8270D, 8270D SIM Asbestos (Polarized Light Microscopy) Subsurface Soil TAL Metals EPA Methods 6010, 7471 TCL VOCs EPA Methods 8260B, 5035 TCL SVOCs EPA Method 8270D, 8270D SIM Groundwater TAL Metals EPA Methods 6010, 7471 TCL VOCs EPA Methods 8260B, 5035 TCL SVOCs EPA Method 8270D, 8270D SIM Assess soils and groundwater for potential petroleum and hazardous contamination. SESDPROC-300-R1 Soil Sampling SESDPROC-301-R1 Groundwater Sampling Preparation Department and Weave Room (AOC - 7) Soil Groundwater 1 Surface Soil 1 Subsurface Soil 1 Groundwater SS-26 MW-6 Surface Soil TAL Metals EPA Methods 6010, 7471 TCL VOCs EPA Methods 8260B, 5035 TCL SVOCs EPA Method 8270D, 8270D SIM Asbestos (Polarized Light Microscopy) Subsurface Soil TAL Metals EPA Methods 6010, 7471 TCL VOCs EPA Methods 8260B, 5035 TCL SVOCs EPA Method 8270D, 8270D SIM Groundwater TAL Metals EPA Methods 6010, 7471 TCL VOCs EPA Methods 8260B, 5035 TCL SVOCs EPA Method 8270D, 8270D SIM Assess soils and groundwater for potential petroleum and hazardous contamination. SESDPROC-300-R1 Soil Sampling SESDPROC-301-R1 Groundwater Sampling Areas Not Shown in Phase I ESA Groundwater 2 Groundwater MW-2 and MW-7 Groundwater TAL Metals EPA Methods 6010, 7471 TCL VOCs EPA Methods 8260B, 5035 TCL SVOCs EPA Method 8270D, 8270D SIM Assess groundwater for potential petroleum and hazardous contamination. SESDPROC-301-R1 Groundwater Sampling Background (AOC - 8) Soil Groundwater 2 Surface Soil 2 Subsurface Soil 2 Groundwater SS-27 and SS-28 MW-8 and MW-9 Surface Soil TAL Metals EPA Methods 6010, 7471 TCL VOCs EPA Methods 8260B, 5035 TCL SVOCs EPA Method 8270D, 8270D SIM TCL PCBs EPA Method 8082 Asbestos (Polarized Light Microscopy) Subsurface Soil TAL Metals EPA Methods 6010, 7471 TCL VOCs EPA Methods 8260B, 5035 TCL SVOCs EPA Method 8270D, 8270D SIM TCL PCBs EPA Method 8082 Groundwater TAL Metals EPA Methods 6010, 7471 TCL VOCs EPA Methods 8260B, 5035 TCL SVOCs EPA Method 8270D, 8270D SIM TCL PCBs EPA Method 8082 Assess soils and groundwater for potential petroleum and hazardous contamination. SESDPROC-300-R1 Soil Sampling SESDPROC-301-R1 Groundwater Sampling Blanks Aqueous 3 Equipment Blanks 3 Field Blanks EB-1 through EB-3 FB-1 through FB-3 Groundwater TAL Metals EPA Methods 6010, 7471 TCL VOCs EPA Methods 8260B, 5035 TCL SVOCs EPA Method 8270D, 8270D SIM TCL PCBs EPA Method 8082 Quality Assurance/Quality Control SESDPROC-301-R1 Groundwater Sampling Duplicates Soil Groundwater 2 Surface Soil 2 Subsurface Soil 1 Groundwater Sample ID will mirror base/root ID Analyses will mirror base/root samples Quality Assurance/Quality Control SESDPROC-011-R2 Field Sampling Quality Control Notes: Surface soil samples will be collected from the 0'-1' below ground surface interval. EPA = United States Environmental Protection Agency TAL = Target Analyte List TCL = Target Compound List VOCs = Volatile Organic Compounds SVOCs = Semi-volatile Organic Compounds SESD = Science and Ecosystem Support Division (EPA) PCBs = Polychlorinated Biphenyls Trip Blanks for Quality Assurance/Quality Control are not included on the table. Area of Concern Sample Schedule Subsurface soil samples will be collected from a minimum of 2' below ground surface with the exception of the sample collected from the Coal Storage Area (collected from directly below the maximum depth of coal based on visual delineation from test pits and soil boring).