19038 Dunavant WP-Approval Soil Sam 20180227

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

February 27, 2018

Sent Via E-mail

Ralph McGee, PG,
Hart & Hickman, PC
2923 South Tryon Street, Suite 100 Charlotte, NC 28203
[e-mail]

Subject: Work Plan Approval
Dunavant Brownfields Property Charlotte, Mecklenburg County
Brownfields Project No. 19038-15-060

Dear Mr. McGee,
The Department of Environmental Quality (DEQ) Brownfields Program received the Brownfields Soil Assessment Work Plan dated February 2, 2017 (Work Plan) for the above referenced
Brownfields Property. DEQ Brownfields reviewed this document, and determined that comments
made by DEQ Brownfields on February 15, 2018 to previous versions of this work plan have been
incorporated as requested. The Work Plan is approved with one revision. In Section 2.4 Investigated Derived Waste (IDW) is to be containerized and staged on-Site until analytical results are received and reviewed. Based on the results, the soil can be spread thin on site or exported to
a suitable facility for disposal.

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

Via Email

February 26, 2018

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

Attention: Ms. Carolyn Minnich

Re: Brownfields Soil Assessment Work Plan – Revision 1
Dunavant Street
Charlotte, North Carolina
Brownfields Project No. 19038-15-060
H&H Job No. RMR-002

Dear Carolyn:

1.0 Introduction

On behalf of RRPIV 2250 Hawkins JV, LLC, Hart & Hickman, PC (H&H) is pleased to present
this Brownfields Soil Assessment Work Plan (Work Plan) for the Dunavant Street Brownfields
property (Brownfields Project No. 19038-15-060) located at 2250 Hawkins Street in Charlotte,
Mecklenburg County, North Carolina (Site). A Site location map is provided as Figure 1.

The Site is comprised of one approximately 4.36-acre parcel of land located in a mixed
residential and commercial area of South End Charlotte. The Site is currently developed with
light industrial buildings including warehouses, manufacturing buildings, and offices that are
scheduled to be demolished in late March 2018. Current redevelopment plans include
demolition of the Site structures and construction of a mixed use multi-family residential
building with several commercial tenant spaces.

A Brownfields Agreement for the Site was executed on February 11, 2016. Terms of the
Ms. Carolyn Minnich
February 26, 2018
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Brownfields Agreement for the Site indicate that physical redevelopment of the Brownfields
property must be performed in accordance with a North Carolina Department of Environmental
Quality (DEQ) approved Environmental Management Plan (EMP) which will include
information associated with planned import and export soil during proposed redevelopment
activities. The purpose of this Work Plan is to present methods to characterize soil that will be
removed from the Site as part of Site grading and redevelopment.

2.0 Brownfields Soil Assessment Activities

H&H proposes to conduct soil assessment activities to identify areas on the Brownfields property
that do not have compound concentrations in soil above DEQ Inactive Hazardous Site Branch
(IHSB) Protection of Groundwater and Unrestricted Use Preliminary Soil Remediation Goals
(PSRGs) to assist in export of non-impacted soil during grading activities. The proposed
assessment activities will be performed in general accordance with DEQ IHSB Guidelines for
Assessment and Cleanup (Guidelines) dated October 2015 and the 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 soil sampling activities, H&H will contact North Carolina 811 One-Call, the
public utility locator service, to mark subsurface utilities at the Site. H&H will also contract with
a private utility locator to identify and mark locations of sub-grade utilities at the Site that may
not be marked by the public locator. In addition, prior to boring advancement, a decontaminated
stainless steel hand auger will be advanced to a depth of approximately 5 ft below ground surface
(bgs) at the proposed boring locations to further clear for potential subsurface utilities (unless
conditions indicate the further advancement with a hand auger is warranted).
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2.1 Soil Characterization Purpose and Objectives

Results of previous assessment activities completed in undeveloped areas located in the
southeastern portion of the Site indicate that polynuclear aromatic hydrocarbon (PAH)
compounds and arsenic have been identified in shallow soil at concentrations exceeding the
Unrestricted Use PSRGs. Results of vadose zone soil assessment activities conducted in the
northwestern portion of the Site have not identified compounds at concentrations above the
Unrestricted Use PSRGs. Soil sample locations from previous assessments completed at the Site
are depicted on Figure 2. As shown on Figure 2, limited information is available for soil
conditions in northwestern portions of the Site beneath buildings and the beneath the surface
parking lot located between the Site buildings.

Based on recent conversations with the Prospective Developer (PD) and the Site redevelopment
grading contractor, H&H understands that grading activities for the proposed redevelopment will
result in net export of approximately 10,000 cubic yards of soil from the Site. There is limited
space at the Site for stockpiling export soil during redevelopment activities. To expedite the
grading activities and to minimize the need to stockpile and manage large volumes of soil at the
Site, H&H to proposes to conduct soil assessment activities in the northwestern portion of the
Site to characterize soil in situ before grading activities begin.

H&H understands that non-impacted areas (if identified) will be over-excavated and the
excavated soil will be transported off-Site as export material. Each excavation basin will be
backfilled with soil from areas at the Site where compounds have been detected at concentrations
above the Unrestricted Use PSRGs and capped with impervious surfaces and/or a minimum of 2
ft of clean fill. The data collected during the proposed assessment activities outlined in the
following sections will be used to predetermine whether export soil from the proposed
excavations can be transported to a Land Clearing and Inert Debris (LCID) landfill, a
construction and debris (C&D) landfill, a permitted landfill, or another Brownfields property for
use as beneficial fill, and/or another suitable location with DEQ approval.
Ms. Carolyn Minnich
February 26, 2018
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H&H understands that the DEQ Brownfields Program and the DEQ Solid Waste Section will
review results of the proposed soil assessment activities and assist the PD in determining a
suitable facility for the export soil. H&H also understands that the DEQ Solid Waste Section
will issue a letter recommending the type(s) of facilities that could manage the proposed export
soil based on soil characterization laboratory analytical results.

A summary of the proposed soil assessment activities is provided in the following sections.

2.1 Soil Characterization Sampling Activities

H&H proposes to conduct soil assessment activities to evaluate subsurface conditions for
potential impacts in the northwestern portion of the Site where soil samples have not been
previously collected for laboratory analysis. To collect a representative number of samples,
H&H divided the Site into twelve sections (denoted by EX nomenclature) as depicted on
Figure 3. Sections EX-1 through EX-12 are areas of the Site where impacts to soil are not
anticipated based on Site history and results of previous assessments.

H&H will contract with a qualified drilling contractor to advance three (3) soil borings to
approximately 10 ft bgs (the estimated depth of the proposed export soil excavation basins) in
each of the twelve sections utilizing a track-mounted direct push technology (DPT) drill rig
Proposed soil boring locations are shown in Figure 3. During boring advancement, continuous
soil samples will be collected from each boring using acetate lined macrocore sleeves. The soil
samples will be logged for lithologic description and inspected for the presence of visual and
olfactory indication of potential impacts, and screened for the presence of volatile organic vapors
with a calibrated photoionization detector (PID).

Shallow soil sample aliquots will be collected from the top 5 ft bgs at each of the three soil
borings advanced in a section. The shallow soil sample aliquots will be combined and
homogenized to form one composite soil sample representative of shallow soil conditions in each
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section (a total of 12 composite shallow soil samples). Similarly, deeper soil sample aliquots
will be collected from the 5 ft to 10 ft depth interval at each of the three soil borings advanced in
a section. The deeper soil sample aliquots will be combined and homogenized to form one
composite soil sample representative of deeper soil conditions in each section (a total of 12
composite deeper soil samples).

Composite soil samples representing shallow soil for each section and composite soil samples
representing deeper soil for each section will be collected directly into dedicated laboratory-
supplied sample containers and submitted to a North Carolina certified laboratory under standard
chain of custody protocols for analysis of semi volatile organic compounds (SVOCs) by EPA
Method 8270 and Resource Conservation and Recovery Act (RCRA) metals plus hexavalent
chromium by EPA Methods 6020/7471/7196. In addition to the composite soil samples
described above, one shallow grab soil sample and one deeper grab soil sample will be collected
from two of the three soil borings in each section (total of 4 grab samples per section). The grab
soil samples will be collected from undisturbed portions of soil directly into laboratory-supplied
glassware and submitted to a North Carolina certified laboratory under standard chain of custody
protocols for analysis of VOCs by EPA Method 8260.

Following sampling activities, the soil borings will be properly abandoned and the surface will
be repaired similar to pre-drilling conditions. Additionally, the soil boring locations will be
estimated using a hand-held global positioning system (GPS) unit.

2.2 Background Soil Sampling

H&H proposes to advance two (2) soil borings for collection of soil samples from areas at the
Site that do not appear to have been affected by historical uses to evaluate background
concentrations of metals. The proposed locations of the background soil samples have been
determined based upon field observations and review of available historical resources. The
approximate proposed locations for the background soil borings are depicted on Figure 3. If the
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proposed locations shown on Figure 3 are significantly changed based on field observations,
H&H will contact you to discuss the new sample locations.

The background soil borings will be advanced utilizing the track-mounted DPT drill rig to
approximately 10 ft bgs. Continuous soil samples will be collected from each boring using
acetate lined macrocore sleeves. The soil samples will be logged for lithologic description and
inspected for the presence of visual and olfactory indication of potential impacts, and screened
for the presence of volatile organic vapors with a calibrated PID.

Consistent with the soil characterization sample methodology outlined above, shallow soil
sample aliquots will be collected from the top 5 ft bgs at each background soil boring. The
shallow soil sample aliquots will be combined and homogenized to form one composite soil
sample representative of shallow soil conditions in each background sample location. Deeper
soil sample aliquots will be collected from the 5 ft to 10 ft depth interval at each background soil
boring. The deeper soil sample aliquots will be combined and homogenized to form one
composite soil sample representative of deeper soil conditions in each background sample
location.

Following collection, the soil samples will be placed in dedicated laboratory-supplied sample
containers, labeled with the sample identification, date, and requested analysis, and placed in a
laboratory supplied cooler with ice. Soil samples will be submitted to a North Carolina certified
laboratory under standard chain of custody protocols for analysis of RCRA metals plus
hexavalent chromium by EPA Methods 6010/7471/7196.

Following sampling activities, the soil borings will be properly abandoned and the surface will
be repaired similar to pre-drilling conditions. Additionally, the soil sample locations will be
estimated using a hand-held GPS unit.

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2.3 Quality Assurance/Quality Control

For quality assurance and quality control purposes (QA/QC), one trip blank will be submitted for
laboratory analysis of VOCs by EPA Method 8260 for each sample shipment. To evaluate the
reproducibility of the sample results, H&H will collect one duplicate soil sample which will be
submitted for the same laboratory analysis as the parent sample.

Non-dedicated equipment and tools will be decontaminated prior to use at each boring or
sampling location, or following exposure to soil.

Laboratory QA/QC procedures will be employed to ensure appropriate sample handling and
analysis and to aid in the review and validation of the analytical data. QA/QC procedures will be
conducted in accordance with the method protocols and will include regular equipment
maintenance, equipment calibrations, and adherence to specific sample custody and data
management procedures. Samples will be analyzed in conjunction with appropriate blanks,
laboratory duplicates, continuing calibration standards, surrogate standards, and matrix spiking
standards in accordance with approved methodologies to monitor both instrument and analyst
performance. H&H will request that the laboratory reporting limits for each analyte be equal to
or below applicable screening criteria. Additionally, H&H will request that the laboratory
include estimated concentrations for compounds that are detected at levels above the laboratory
method detection limit, but below the laboratory reporting limit (J Flags).

2.4 Investigation Derived Waste

Investigation derived waste (IDW) generated during the assessment activities will be thin spread
on-Site. However, if significant impacts are suspected (i.e., free product), the soil cuttings will
be containerized in 55-gallon drums and staged on-Site pending analytical results of a composite
IDW sample. Based on laboratory analytical results of IDW samples, the drums will be
transported off-Site to a suitable facility for disposal.
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TITLE
PROJECT
SITE LOCATION MAP
DUNAVANT STREET 2250 HAWKINS STREET
CHARLOTTE, NORTH CAROLINA
DATE:
JOB NO:
REVISION NO:
FIGURE:
1-15-2018 0
1RMR-002
SITE
SB-1TMW-1SB-3TMW-2SB-4TMW-3FORMER 12,000 &2,000-GALLONGASOLINE UST BASINFORMER BUILDINGBROOKHILL ROADS. TRYON STREET
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PS-SB-1PS-GW-1SB-1SB-2SB-4PS-SB-2SB-3PS-SB-3PS-GW-3DUNAVANT STREETFUTURE PARKING2F1F1P2115 DUNAVANT STREET2135 DUNAVANT STREET2205 DUNAVANT STREETMW-4MW-1MW-3MW-2BN-1BN-2BN-3DD-2DD-1UST-1UST-2TMW-2 (10-12)ETHYLBENZENE 8.97NAPHTHALENE 9.591,2,4-TMB32.6LEGENDSITE PROPERTY BOUNDARYADJACENT PROPERTY BOUNDARYTEMPORARY MONITORING WELLLOCATION (H&H, 2014 PHASE II ESA)SOIL BORING LOCATION (H&H, 2014PHASE II ESA)PERMANENT MONITORING WELLLOCATION (LAW ENVIRONMENTAL,1993; COOPER ENVIRONMENTAL,1996; MALCOLM PIRNIE, 1997 & 1998)2923 South Tryon Street-Suite 100Charlotte, North Carolina 28203704-586-0007(p) 704-586-0373(f)License # C-1269 / #C-245 GeologyJOB NO. RMR-002REVISION NO. 0DATE: 02-09-18FIGURE NO. 2DUNAVANT STREET 2250 HAWKINS STREET CHARLOTTE, NORTH CAROLINASOIL IMPACTS ABOVE RESIDENTIAL PSRGsTEMPORARY MONITORING WELLLOCATION (ERM, 2006)SOIL BORING LOCATION (ERM, 2006)SOIL BORING LOCATION (H&H, 2014PHASE II ESA)UST SOIL SAMPLE LOCATION(SPATCO, AUGUST 1989)UST SOIL SAMPLE LOCATION(MALCOLM PIRNIE, JULY, 1998)NOTE:1. AERIAL IMAGERY OBTAINED FROM MECKLENBURG COUNTY GIS (2013).2. SPATCO AUGUST 1989, AND MALCOLM PIRNIE JULY, 1998 SAMPLELOCATIONS HAVE BEEN APPROXIMATED BASED ON FIGURES PRESENTED INMALCOLM PIRNIE ENVIRONMENTAL SITE ASSESSMENT REPORT DATEDOCTOBER 1997.3. 1,2,4-TMB = 1,2,4-TRIMETHYLBENZENE4. ONLY COMPOUNDS DETECTED ABOVE RESIDENTIAL PSRGs ARE SHOWN.SOIL SAMPLE LOCATION (MALCOLMPIRNIE, JULY, 1998)CONSTITUENTCONCENTRATION(mg/kg)SAMPLE DEPTH(FT BGS)SAMPLE IDTMW-2 (10-12')ETHYLBENZENE8.97NAPHTHALENE 9.591,2,4-TMB32.6SB-2 (1-2')BENZO(A)PYRENE0.121BENZO(B)FLUORATHENE0.271F5' 8'BENZENE 3.9 12ETHYLBENZENE 21 51TOLUENE 120 120XYLENES 85 210SB-3 (7-8')ARSENIC 4.33SB-4 (4-5')ARSENIC 6.05BN-2 (1')ARSENIC1.0BN-1 (1')ARSENIC 1.2DD-2 (1')ARSENIC 4.0
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LEGEND
SITE PROPERTY BOUNDARY
PROPOSED COMPOSITE SOIL
SAMPLE LOCATION
PROPOSED BACKGROUND SOIL
SAMPLE LOCATION
JOB NO. RMR-002
REVISION NO. 0DATE: 2-21-17
FIGURE NO. 3
DUNAVANT STREET
2250 HAWKINS STREET
CHARLOTTE, NORTH CAROLINA
PROPOSED SOIL SAMPLE LOCATION MAP
NOTE:
AERIAL IMAGERY OBTAINED FROM MECKLENBURG COUNTY GIS (2017).
2923 South Tryon Street-Suite 100
Charlotte, North Carolina 28203
704-586-0007(p) 704-586-0373(f)
License # C-1269 / #C-245 Geology
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