04004_National Textiles_Additional Indoor Air Assmt Request_2014.04.03

AVA
MCDEMR
North Carolina Department of Environment and Natural Resources
Pat McCrory
Governor
Mr. Stephen R. Berlin
Kilpatrick Townsend
1001 W. Fourth Street
Winston-Salem, NC 27699-1646
April 3, 2014
Re: Former National Textiles Site
Morganton, Burke County, North Carolina
Brownfields Project No. 040004-00-012
Dear Steve:
John E. Skvarla, Ill
Secretary
I am responding to your January 28, 2014 email to me (copying Don Nielsen) about issues
related to the additional indoor air assessment needed at the subject facility. Your email responded
to a January 20, 2014 email from Don Nielsen to me (copying you) and raised a concern about the
chemical inventory conducted at the site. As you know, Mr. Nielsen represents Ferguson Copeland,
the current owner and occupant of the brownfields property.
A primary concern you have expressed over the past many months is that, prior to testing
indoor air, a chemical inventory should be done at the site to ensure that no chemicals or products
used in Ferguson-Copeland's manufacturing processes contain any of the brownfields contaminants
listed in the Brownfields Agreement for the property. The brownfields contaminants listed for the
site are the following chlorinated solvents: tetrachloroethene, trichloroethene, cis-1,2-
dichloroethene, and vinyl chloride. Mr. Nielsen's January 20, 2014 email transmitted a document,
sealed by a licensed professional engineer (PE), which stated that a complete inventory of all
chemicals and products used at the site was conducted and certifying that no brownfields
contaminants are used at the site. I discussed with Matt Bramblett (the PE who did the chemical
inventory) the procedure he used to conduct the chemical survey. I then discussed this matter with
Bruce Nicholson, the manager of the North Carolina Brownfields Program (NCBP). Bruce and I
are satisfied with the PE's methodology for conducting the inventory and with his conclusions.
Another issue that has been raised between National Textiles and Ferguson Copeland is
which volatile chemicals should be analyzed for in the indoor air samples. For the initial vapor
intrusion testing performed for National Textiles, which consisted of sub slab soil gas and indoor air
testing, the samples were analyzed only for chlorinated solvents. Further, the brownfields
contaminants listed in the BF A (see above) represent the only chemicals that have been found in
soil and groundwater at the site in concentrations which exceed risk-based screening levels.
Therefore, the NCBP only requires the indoor air samples to be analyzed for the listed brownfields
contaminants.
1646 Mail Service Center, Raleigh, North Carolina 27699-1646
Phone: [phone] \Internet: http://portal.ncdenr.org/web/wm
An Equal Opportunity I Affirmative Action Employer-Made in part by recycled paper
Mr. Stephen R. Berlin
Page 2
Now that a chemical inventory has been conducted to the NCBP's satisfaction, we need your
client to move forward have the indoor air assessment completed in a timely manner. For years we
were told that the basement/lower level was used primarily for storage and occasional
manufacturing processes. I have now been informed that people may be working in the lower level
where, in addition to having high concentrations detected in soil gas beneath the slab, volatile
chemical vapors have been documented using field instruments to be seeping into indoor air along
the wall. While many parties, including me, have factored into the lengthy response to this situation,
years have passed since National Textiles initially confirmed the potential risks posed by air in the
lower level of the building and we must move forward with assessing, and mitigating as necessary,
this exposure pathway. During that time, increased knowledge and awareness of vapor intrusion
assessment and mitigation methodologies has made solving this issue both more achievable and
more urgent (from a human health standpoint). I have already approved with comments the May
16, 2013 indoor air sampling plan you obtained from ERM. I am requesting that the approved
assessment work take place within 30 days and that a report of findings be provided to me within 45
days of that sampling. I believe this allows ample time to obtain access to the building, schedule
and perform the field work, acquire laboratory results, and prepare a report. I would appreciate
your keeping me in the loop with regard to the work schedule at the site.
Thank you, Steve, and I look forward to hearing from you soon. Please let me know if you wish to
discuss this matter with Bruce Nicholson and me, and I will quickly arrange for a call.
Sincerely,
_/ -----,--r ~~ /a-~L~
Lisa Taber, PG
Brownfields Project Manager
Division of Waste Management, NC DENR'
cc: Bruce Nicholson
Don Nielsen, Bell, Davis & Pitt
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