HomeMy WebLinkAboutRobbins Mill Phase II Scope of Work-OCRA5. PROBLEM DEFINITION/BACKGROUND/CONCEPTUAL SITE
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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).