19054 HD Supply WP Soil Characterization and Approval 20180130

State of North Carolina | Environmental Quality | Waste Management
1646 Mail Service Center | 217 West Jones Street | Raleigh, NC 27699-1646
919 707 8200 T

January 30, 2018

Sent Via E-mail

Nathan O’Leary, CHMM
Hart & Hickman
2923 South Tryon Street, Suite 100 Charlotte, North Carolina 28203

Subject: Soil Characterization Work Plan Approval
HD Supply (aka RailYard)
1414 and 1424 South Tryon Street Charlotte, Mecklenburg County
Brownfields Project No. 19054-15-060

Dear Mr. O’Leary,
On October 23, 2017, the Department of Environmental Quality (DEQ) Brownfields Program received the Soil Characterization Work Plan (Work Plan) for the above referenced Brownfields
Property. DEQ Brownfields reviewed the October 2017 work plan and the scope of work was
acceptable, however I requested revisions to the work plan to further define soil export options
and comparison data. DEQ comments were submitted in email form on October 26, 2017. On January 29, 2018, a revised and final work plan was submitted and all comments were included. DEQ Brownfields approves the revised Work Plan dated January 29, 2018.

Please be advised that this approval from DEQ Brownfields does not waive any applicable
requirement to obtain any necessary permits, licenses or certifications which may be required from other state or local entities. If you have questions about this correspondence or require additional information, please feel free to contact me by phone at 704/661-0330 or by email at
[e-mail].

Sincerely, Carolyn Minnich

Carolyn Minnich Brownfields Project Manager
ec: Matt Lucarelli <[e-mail]>

From:Minnich, Carolyn
To:"Nathan O"Leary"
Cc:Steve Hart
Subject:RE: [External] HD Supply Soil Characterization Work Plan
Date:Wednesday, October 25, 2017 3:21:00 PM
Attachments:HD Supply BF Soil Characterization Work Plan (002) DEQ Comments 20171025.pdfimage002.png
Attached are my comments. Overall the field work is acceptable. My comments were more on what
and how to export the soils. Are you rushing the data? When should I expect it?

Carolyn Minnich
Brownfields Project Manager
Division of Waste Management
Department of Environmental Quality

704 661 0330 office/mobile
[e-mail]

1646 Mail Service Center
Raleigh, NC 27699-1646

Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.

From: Nathan O'Leary [mailto:[e-mail]]
Sent: Monday, October 23, 2017 5:29 PM
To: Minnich, Carolyn <[e-mail]>
Cc: Steve Hart <[e-mail]>
Subject: [External] HD Supply Soil Characterization Work Plan

CAUTION: This email originated from outside of the organization. Do not click links or open attachments unless you
verify that the attachment and content are safe. Send all suspicious email as an attachment to
[e-mail].

Carolyn,

Attached, please find our Soil Characterization Work Plan for the HD Supply Brownfields Site. The
purpose of the work plan is to characterize soil in place to evaluate how to properly manage cut soil
to be removed from the Site. If you have any questions, please let us know.

Have a good night,
Nathan

Via Email

January 29, 2018

NCDEQ
Division of Waste Management
Brownfields Program
1646 Mail Service Center
Raleigh, NC 27699-1646

Attention: Ms. Carolyn Minnich

Subject: Soil Characterization Work Plan, Rev 1
HD Supply
1414 and 1422 South Tryon Street
Charlotte, North Carolina
Brownfields Project ID 19054-15-060
H&H Project No. BCP-064

Dear Carolyn:
1.0 Introduction

On behalf of Beacon MPI, LLC (Beacon), Hart & Hickman, PC (H&H) is submitting this Soil
Characterization Work Plan for the HD Supply Brownfields Site (BF Project No. 19054-15-060)
located at 1414 and 1422 South Tryon Street in Charlotte, Mecklenburg County, North Carolina
(Site or subject Site). A Site location map is included as Figure 1. The purpose of this work plan
is to present methods to characterize potential cut soil that will be removed from the Site as part
of Site grading and redevelopment.

The Site is comprised of one parcel of land that is approximately 3.38 acres. The Site is
improved with one approximately 7,700-square foot (sq ft) multi-use building and one
approximately 36,000-sq ft warehouse building that are in the process of being demolished. A
Site Plan is provided as Figure 2. Current redevelopment plans include demolition of the Site
structures and construction of two office buildings, a parking garage, and a multi-family
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January 29, 2018
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residential structure around three sides of the parking garage.

Historically, the subject Site was developed with multiple residential structures prior to 1911
based on review of historic Sanborn Fire Insurance maps. The southeastern portion of the Site
was redeveloped for commercial purposes in 1946 when the current multi-use building was
constructed. The multi-use building was used as a drycleaner and laundry facility from initial
construction to the late 1960s or early 1970s. Since the early 1970s, the multi-use building has
been used as a furniture showroom, offices, and warehouse storage. The western portion of the
Site was developed with the current warehouse building in 1984 and was occupied by HD Supply
for office space and electrical supply warehousing from 1984 until recent. A Site map is
provided as Figure 2.

Results of previous assessment activities completed at the Site including a Phase I Environmental
Site Assessment (ESA), a Phase II ESA, and the Brownfields assessment activities are detailed in
a Brownfields Assessment Report dated June 19, 2017. The locations of soil borings advanced
during the Phase II ESA and Brownfields assessment activities are provided on Figure 3.

2.0 Soil Cut/Fill

Development activities have begun at the site and the site buildings are currently being
demolished. Once the Site buildings have been removed, Site grading activities will begin.
Based on the most recent cut/fill plan, soil will be cut and removed across the central, northern,
eastern, and southern portions of the Site (approximately 75% of the Site). Soil will be cut to
depths up to approximately 2.5 ft below ground surface (bgs) in those areas of the Site.
Additionally, the top several inches of top soil will be cut and removed across the entire Site to
remove organic material and structurally unsuitable topsoil. The western portion of the Site
along Winnifred Street will be filled with up to approximately 6.75 ft of soil removed from cut
areas. However, it is estimated that approximately 8,000 cubic yards of excess cut soil will be
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January 29, 2018
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removed from the Site. A cut/fill map is provided as Figure 3. The purpose of the soil sampling
proposed herein is to characterize cut soil at the Site so that it ca be properly managed.

3.0 Proposed Soil Characterization Activities

The proposed soil characterization activities detailed in this Work Plan will be performed in
general accordance with DEQ’s Inactive Hazardous Sites Branch (IHSB) Guidelines for
Assessment and Cleanup (Guidelines) dated October 2015 and most recent versions of the U.S.
Environmental Protection Agency (EPA) Region IV Science and Ecosystem Support (SESD)
Field Branches Quality System and Technical Procedures guidance.

Prior to conducting the field activities, H&H will contact North Carolina 811, the public utility
locator, to mark subsurface utilities located on the Site. It should be noted that the Site is
currently being razed and utilities have been disconnected.

3.1 Soil Characterization Purpose and Objectives

To expedite the grading activities and to minimize the need to stockpile and manage large
volumes of soil at the Site, H&H proposes to characterize soil in place before grading activities
begin. To collect a representative number of samples, H&H divided the Site into seven sections
as depicted on Figure 3. Sections 1 through 6 are areas of the Site where impacts to soil are not
anticipated based on Site history and previous assessments. Section 7 is the “Area of Potential
Soil Contamination” as denoted on the Brownfields plat where the former dry-cleaner was
located and previous soil assessment has indicated some soil impacts.

The data collected during the assessment activities detailed below will be used to predetermine
whether soil cut from the different sections of the Site can be transported to a Land Clearing and
Inert Debris (LCID) landfill, a construction and debris (C&D) landfill, a permitted landfill, or
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January 29, 2018
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another Brownfields property (1213 West Morehead Street, Brownfields No. 18057-14-060) to
be used as beneficial fill, and/or another suitable location with DEQ approval. Background metal
data for the West Morehead Street property is included in Appendix A. The proposed scope of
work is detailed below.

3.2 Surface Soil Characterization Activities

As indicated above, surface soil will be removed across the site as part of grading because the
material is not suitable fill. To characterize the surface soil, H&H divided the subject site into
seven sections to collect a representative number of surface soil aliquots across the Site. In each
section, H&H will advance five borings to approximately 6 inches bgs. Upon collection, the soil
aliquots from each boring in a given section will be placed in a decontaminated Pyrex glass bowl
or stainless-steel bowl and will be homogenized to generate one surface soil sample from each of
the six sections for laboratory analysis. It should be noted that samples collected for analysis of
volatile organic compounds (VOCs) will not be homogenized. The sample for VOC analysis
will be collected from the boring location interpreted most likely to be impacted based on field
screening results including visual observations for staining and screening for the presence of
organic vapors with a photoionization detector (PID). If field screening results do not indicate
the likely presence of impacts at the five borings in a given section, then the sample for VOC
analysis will be collected from the central-most boring within a given section.

The surface soil samples from each will be placed into dedicated laboratory-supplied sample
containers and then packed in an iced laboratory supplied cooler. The samples will be
transported under standard chain-of-custody to a certified analytical laboratory for analysis of
VOCs by EPA Method 8260, semi-volatile organic compounds (SVOCs) by EPA Method 8270
and Resource Conservation and Recovery Act (RCRA) metals by EPA Method 6010/7174.

If laboratory analytical results do not indicate the presence of analyzed compounds above
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January 29, 2018
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laboratory reporting limits or naturally occurring levels for metals, the surface soil will be
transported to a LCID landfill with approval from DEQ and the landfill, or will be transported to
the 1213 West Morehead Street Brownfields property is geotechnically suitable (Sections 1
through 6). If analyzed compounds are detected at concentrations above laboratory reporting
limits, the soil may be taken to a C&D landfill, other permitted facility, or other location with
DEQ approval.

3.3 Subsurface Soil Characterization Activities

After surface soil sample collection, soil borings advanced in proposed cut areas will be
advanced to the anticipated cut depth at that location (see Figure 3). In fill areas (blue shading on
Figure 3), no deeper samples will be collected for analysis because only the surface soil will be
removed in those areas.

At the boring locations within proposed soil cut areas, soil aliquots will be collected from 6-
inches bgs to the total depth of the boring. Upon collection, the soil aliquots from each boring in
a given section and will be placed in a decontaminated Pyrex glass bowl or stainless-steel bowl
and will be homogenized to generate one subsurface soil sample from each of the six sections for
laboratory analysis. It should be noted that samples collected for analysis of VOCs will not be
homogenized. The sample for VOC analysis will be collected from the boring location
interpreted most likely to be impacted based on field screening results including visual
observations for staining and screening for the presence of organic vapors with a PID. If field
screening results don’t indicate the likely presence of impacts at the five borings in a given
section, then the sample for VOC analysis will be collected from the central-most boring within a
given section.

The subsurface samples will be placed into dedicated laboratory-supplied sample containers and
then packed in an iced laboratory supplied cooler. The samples will be transported under
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January 29, 2018
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standard chain-of-custody to a certified analytical laboratory for analysis of VOCs by EPA
Method 8260, SVOCs by EPA Method 8270, and RRCRA metals by EPA Method 6010/7174.

If analytical results of the subsurface soil samples indicate the presence of analyzed compounds
at concentrations below the DEQ Inactive Hazardous Sites Branch (IHSB) Preliminary Soil
Remediation Goals (PSRGs) or that compounds present do not represent unacceptable risk based
on the DEQ Risk Calculator using a non-residential land use scenario (with DEQ review and
approval of the Calculator results), H&H proposes that the subsurface soil be transported to the
1213 West Morehead Brownfields property (Brownfields Project No. 18057-14-060) located at
1213 West Morehead Street in Charlotte, North Carolina (with DEQ and property owner
approval). If results of the Risk Calculator indicate that compounds present represent an
unacceptable risk, then soil will be transported to a permitted and lined Subtitle D landfill.

3.4 Area of Potential Soil Contamination Soil Characterization Activities

Impacted soil is known to be present in the area of soil boring SB-4 previously advanced at the
Site in the area denoted as the “Area of Potential Soil Contamination” on the Brownfields plat.
As such, soil excavated in the area of SB-4 will be transported to a permitted Subtitle D landfill
for disposal, or placed on-site below the southern office tower where a vapor mitigation system
will be installed. However, DEQ has raised concern about whether impacted soil is present to
the south and west of SB-4 near previous soil boring SB-5 because of elevated detection limits in
the SB-5 sample. To address DEQ’s concerns and to further evaluate if soil impacts are present,
H&H proposes to advance one soil boring in the area of previous boring SB-5 at the location
depicted on Figure 3. Soil in this area of the Site will be cut to approximately 1.25 ft bgs. As
such, H&H will advance the boring at this location to a similar depth and collect one surface and
one subsurface sample for laboratory analysis using the methodology detailed in Sections 3.2 and
3.3.

Ms. Carolyn Minnich
January 29, 2018
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The collected soil samples will be placed into dedicated laboratory-supplied sample containers
and then packed in an iced laboratory supplied cooler. The samples will be transported under
standard chain-of-custody to a certified analytical laboratory for analysis of VOCs by EPA
Method 8260, SVOCs by EPA Method 8270, and RCRA metals by EPA Method 6010/7174.

Analytical results of the soil samples collected at this location will be used in conjunction with
the analytical results of soil samples previously collected in this area of the Site to evaluate the
approximate extent of soil to be transported to a permitted facility. If analytical results from the
additional boring near SB-5 do not indicate the presence of analyzed compounds at
concentrations above the IHSB Industrial/Commercial PSRGs or that compounds present do not
represent an unacceptable risk based on the DEQ Risk Calculator using a non-residential use
scenario, H&H proposes that the soil be transported to the 1213 West Morehead Site
Brownfields Site (with DEQ and property owner concurrence). If results of the Risk Calculator
indicate that compounds present represent a potentially unacceptable risk, then soil will be
transported to a permitted and lined Subtitle D landfill.

3.5 Quality Assurance/Quality Control

H&H will collect one duplicate soil sample for quality assurance/quality control (QA/QC)
purposes. Sufficient sample will be collected in the field in order to perform the duplicate
analyses from one of the proposed soil borings. The duplicate sample will be analyzed for
VOCs, SVOCs, and RCRA metals similar to the parent sample. Similar to the parent, the sample
for VOC analysis will not be homogenized prior to placement in laboratory containers.

3.6 Investigation Derived Waste

Soil cuttings generated during the characterization activities will be placed adjacent to the
borehole and will be managed along with the rest of the soil cut from that section of the Site.
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However, the soil may be drummed if warranted to assist with tracking and proper management
of the potentially impacted soil.

Ms. Carolyn Minnich
January 29, 2018
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3.7 Reporting

Following completion of the proposed soil characterization activities and receipt of the analytical
data, H&H will document our findings in a Soil Characterization Report. The report will include
a description of the sampling activities, a figure depicting sample locations, soil boring logs, a
discussion of the data in comparison to regulatory screening levels, laboratory analytical data,
and conclusions and recommendations concerning our activities. Additionally, the analytical
results will be evaluated using the DEQ Risk Calculator if warranted based on analytical results.

Please contact us if you have any questions or if you require additional information.

Sincerely,

Hart & Hickman, PC
Nathan O’Leary, CHMM Steve Hart, PG
Project Manager Principal Hydrogeologist

SITE LOCATION MAP
HD SUPPLY BROWNFIELDS SITE
1414 AND 1422 SOUTH TRYON STREET
CHARLOTTE, NORTH CAROLINA
DATE:
JOB NO:
REVISION NO:
FIGURE NO:
05/12/2015 0
1BCP-064
0 2000 4000
APPROXIMATE
SCALE IN FEET
N
U.S.G.S. QUADRANGLE MAP
7.5 MINUTE SERIES (TOPOGRAPHIC)
2923 S. Tryon Street, Suite 100
Charlotte, NC 28203
704.586.0007(p) 704.586.0373(f)
CHARLOTTE EAST, NORTH CAROLINA 1991
SITE
SOUTH TRY
ON ST
RE
ET
WIN
O
N
A

S
T
R
E
E
T
WINNIF
RED ST
REET
B
L
A
N
D

S
T
R
E
E
T
SB-7
SB-1
SB-5
SB-3
SB-2
SB-4
SB-6
SB-8
SB-10
SB-9
LEGEND
SITE PROPERTY BOUNDARY
DENOTES AREA TO BE CUT
DENOTES AREA TO BE FILLED
SECTION NUMBER
SURFACE SOIL ALIQUOT LOCATION
SURFACE & SUBSURFACE SOIL
ALIQUOT LOCATION
SOIL BORING LOCATION
AREA OF POTENTIAL SOIL
CONTAMINATION
REVISION NO. 0DATE: 10-19-17
JOB NO. BCP-064 FIGURE NO. 3
HD SUPPLY BROWNFIELDS SITE
1414 AND 1422 SOUTH TRYON STREET
CHARLOTTE, NORTH CAROLINA
SAMPLE LOCATION MAP
2923 South Tryon Street-Suite 100
Charlotte, North Carolina 28203
704-586-0007(p) 704-586-0373(f)
License # C-1269 / #C-245 Geology
C
F
1
1
3
6
2
4
7
5

Appendix A
1213 West Morehead Street Background Metals Data
Table 2 - DRAFT
Summary of Soil Analytical Data
Morehead Street Brownfields Site
Charlotte, North Carolina
H&H Job No. BCP-064
Location Block 1 Block 2 Block 3
Sample ID SC-1 SC-2 SC-3
Depth (ft bgs)0.25 - 1.5 0.25 - 1.5 0.5 - 2.0 0.25 - 2.0
Sample Date 10/26/2017 10/26/2017 10/26/2017 10/26/2017 Residential Industrial
Units (mg/kg)(mg/kg)(mg/kg)(mg/kg)(mg/kg)(mg/kg)
RCRA Metals (6010/7174)
Arsenic <1.5 <1.5 3.2 ND - 3.2 0.68 3.0
Barium 77 93 82 77 - 93 3,100 47,000
Cadmium 2.5 2.5 2.5 2.5 - 2.5 7.5 110
Chromium*21 25 36 21 - 36 23,000 100,000
Lead 21 27 32 21 - 27 NS NS
Mercury 0.049 0.066 0.1 0.049 - 0.1 2.3 3.1
Selenium <4.8 <5.0 <4.7 ND - ND 78.0 1,200
Silver 1.7 1.6 1.5 1.5 - 1.7 78.0 1,200
Notes:
1) Department of Environmental Quality (DEQ) Inactive Hazardous Sites Branch Preliminary Soil Remedial Goals (October 2017)
Samples were composited from aliquots collected from multiple depth intervals. The maximum depth extent is listed.
Bold indicates concentration exceeds the Inactive Hazardous Sites Branch Protection of Industrial Preliminary Soil Remedial Goal
Only those compounds detected in at least one sample shown above
Method number follows parameter in parenthesis
NA = Not Analyzed; NS = Not Specified; ND = Not Detected
mg/kg = milligrams per kilogram
*Chromium III PSRG used for residential and industrial
Range DEQ Inactive Hazardous Sites
Branch (IHSB) Preliminary Soil
Remediation Goals (PSRGs)1
S:\AAA-Master Projects\Beacon Partners- BEP or BCP\BCP-064 1414 and 1422 S. Tryon\brownfields\Soil Characterization\Tables\Table 1 - HD Supply Data
11/6/2017
Table 1
Hart & Hickman, PC
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Table of Contents
Table of Contents
Sample Summary 3
Case Narrative 4
Sample Results 5
17J1461-01 5
17J1461-02 7
17J1461-03 9
Sample Preparation Information 11
QC Data 12
Metals Analyses (Total) 12
B189826 12
B189827 12
Flag/Qualifier Summary 13
Certifications 14
Chain of Custody/Sample Receipt 15
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