10010 Dixie Trucking Request Add Assess 20060824

North Carolina Department of Environment and Natural Resources
Michael F. Easley, Governor
William G. Ross Jr., Secretary
Dexter R. Matthews, Director Division of Waste Management
1646 Mail Service Center, Raleigh, North Carolina 27699-1646
Phone [phone] \ FAX [phone] \ Internet http://wastenotnc.org
An Equal Opportunity / Affirmative Action Employer – Printed on Dual Purpose Recycled Paper

August 24, 2006

Sent Via E-mail and USPS

M.H.O.C., LLC
c/o Thomas N. Griffin
Parker, Poe, Adams & Bernstein, LLP
Three Wachovia Center
401 South Tryon Street, Suite 3000
Charlotte, NC 28210
[e-mail]

Subject: Further Assessment Requirements
Dixie Trucking
3606 North Graham Street
Charlotte, Mecklenburg County
Brownfields Project Number 10010-06-60

Dear Mr. Griffin:

The North Carolina Department of Environmental and Natural Resources (DENR) has
reviewed the currently available site information for the above referenced site and determined that
data gaps have been identified. Additional assessment activities, as outlined below, are required to
assist in making risk management decisions for inclusion in the brownfields agreement (BFA).

During the evaluation process the following sources were utilized - the letter of intent (LOI),
and the following reports submitted by you or from the DENR files at 401 Oberlin Road in Raleigh:

Title Prepared by Date of Report
Phase I Environmental Site Assessment ATC Associates, Inc. July 24, 2002
Limited Subsurface Assessment ATC Associates, Inc. November 25, 2002
Comprehensive Site Assessment ATC Associates, Inc. October 6, 2003
Comprehensive Site Assessment
Addendum
ATC Associates, Inc. February 18, 2004
Phase I Environmental Site Assessment Envirocorp, Inc. February 2006
Interim Groundwater Assessment Report ATC Associates, Inc. April 10, 2006

After reviewing these documents and visiting the site on August 7, 2006, the following assessment
items need to be addressed to determine that the site is safe for its intended reuse, which is industrial
specifically a trucking transfer yard.

Dixie Trucking Brownfields Site
August 24, 2006
Page 2 of 2

• General: The most recent Inactive Hazardous Sites Program Guidelines for Assessment and
Cleanup (http://www.wastenotnc.org/sfhome/stateleadguidance.pdf ) should be followed, which in
turn relies upon EPA's Environmental Investigations Standard Operating Procedures and Quality
Assurance Manual (a .pdf version is available on their website at
http://www.epa.gov/region4/sesd/eisopqam/eisopqam.html). Request Level 2 QA/QC data packages
from a N.C. certified environmental laboratory.

• Surface Sampling: Use standard operating procedures for collecting grab samples in the
creek. Collect three sampling from the water entering the property, along the property and
downgradient of the property.

• Laboratory Analyses: Submit samples to a NC-certified laboratory. Analyze all surface water
volatile organic compounds (VOCs) by EPA SW-846 Methods 8260. Ensure laboratory method
detection limits are below applicable standards (2L standards or IHSB residential remedial goals for
soil found at http://www.wastenotnc.org/soiltable.pdf .) Provide complete original laboratory reports
and associated laboratory QA/QC documentation in the final report to DENR.

• Report and Figures: Submit an assessment report with a description of field activities,
tabulated data, the laboratory data packet, and information requested in above bullets.

• Receptor Survey: A well receptor survey must be completed for the site. The Phase I
Environmental Site Assessment prepared by Envirocorp, Inc. dated February 2006 did not include a
survey of the surrounding area.

I am optimistic with the additional information requested in this phase of assessment we will
be able to determine the risk this site may pose to receptors. I remain very enthusiastic about this
brownfields project and I look forward to working with you to advance this project. If you have any
questions regarding this letter or the brownfields process, please feel free to contact me at 704/661-
0330, or via e-mail at [e-mail]

Sincerely,

Carolyn Minnich
Carolyn F. Minnich
Brownfields Project Manager
Division of Waste Management

cc: Central Files

ec: Bruce Nicholson, DENR