10010 Dixie Decision Memo GW Sampling 20180302

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

March 2, 2018

Sent Via E-mail

Thomas A, Rowan
MHOC, LLC
PO Box 665 Forest Park, GA 30298

Subject: Annual Sampling Required by Land Use Restriction No. 8
Dixie Trucking
3606 North Graham Street Charlotte, Mecklenburg County
Brownfields Project Number 10010-06-60

Dear Mr. Rowan,
On January 31, 2018, the Department of Environmental Quality (DEQ) Brownfields Program received the Annual Land Use Restriction Update and Monitoring Well Sampling Report for the
above referenced Brownfields Property. DEQ Brownfields reviewed this document and
monitoring report. In the Annual Monitor Well Sampling Report prepared by Hart & Hickman
dated January 26, 2018, the conclusion section requested to reduce the frequency sampling requirement in LUR No. 8 in the Notice of Brownfields Property.
DEQ hereby approves your request to reduce the sampling frequency to bi-annually (every 2
years). Be advised that MHOC, LLC is still required to submit an annual LUR Update. Please
refer to this correspondence in future LUR Updates. If you have questions about this correspondence or require additional information, please feel free to contact me at 704/661-0330, [e-mail].

Sincerely,

Carolyn Minnich
Carolyn Minnich
Brownfields Project Manager

Dixie Trucking Property Decision of Memorandum
Page 1 of 3 March 2, 2018
DECISION MEMORANDUM

FROM: Carolyn Minnich
TO: Bruce Nicholson, David Peacock
Subject: Former Dixie Trucking Site
Charlotte, Mecklenburg County Brownfields Project Number 10010-06-060
COMMENTS: On January 31, 2018, the annual Land Use Restriction Update (LURU) was submitted for the above
reference brownfie4lds agreement. Included in the LURU was the Annual Monitor Well Sampling Report dated January 26, 2018 prepared by Hart and Hickman. The report conclusion was to reduce the sampling frequency requirement in Land Use Restriction No. 8 in the Notice of Brownfields Property.
Please note, this request to reduce sampling was initially made on January 26, 2017, but DEQ did not review and respond in time allow for change in sampling in 2018.

The Notice was recorded on March 3, 2008 by M.H.O.C., LLC. It was recorded at the Mecklenburg Register of Deeds in Book 23454, Page 134 (with the associated plat recorded in Plat Book 49, Page
953).
The Land Use Restriction Number 11 states the following:
8. None of the contaminants known to be present in the environmental media at the Brownfields Property, including those listed in this Notice, may be used or stored at the
Brownfields Property without the prior written approval of DENR, except in de minimis
amounts for cleaning and other routine housekeeping activities; provided, however, that
petroleum products may be stored in the Brownfields Property’s aboveground storage tanks (“ASTs”) denominated as such on the plat component of this Notice, so long as a permanent monitoring well is:

a. installed at a location approved in writing in advance by DENR that
lies between the ASTs and Level I; and
b. sampled during December each year by the owner of the portion of the Brownfields Property containing the well as of each December 1st:
i. in accordance with the most current version of the Guidelines of
the Inactive Hazardous Sites Branch of DENR's Superfund Section;
Dixie Trucking Property Decision of Memorandum
Page 2 of 3 ii. for a set of constituents approved in writing in advance by
DENR prior to the first sampling event (unless the contents of any AST change during a
given year, in which case a new set of constituents must be approved);
iii. then analyzed by EPA Method 8260 or another method approved in writing in advance by DENR; and
iv. the analytical results of which sampling must be submitted to DENR in writing with the Land Use Restrictions Update required by Land Use
Restriction 14 below.
The following email explains the situation well:
From: Steve Hart [mailto:[e-mail]] Sent: Thursday, January 26, 2017 11:06 AM To: Minnich, Carolyn <[e-mail]>
Cc: acm <[e-mail]>; Tom Rowan
<[e-mail]>
Subject: Dixie Trucking Brownfields Site Groundwater Sampling

Carolyn Per our discussion and on behalf of M.H.O.C., LLC, we are requesting modifications to the annual
groundwater monitoring performed for the Dixie Trucking Brownfields site located at 3606 N Graham St in Charlotte (Brownfields ID 10010-06-60). The site is currently occupied by Premier Trucking for
warehouse and distribution activities. The Brownfields agreement includes a provision for installing a well upgradient of the petroleum aboveground storage tanks (ASTs) which are located in the north-central
portion of the property (see attached figure). In accordance with the Brownfields agreement and a subsequently approved work plan, monitor well HHMW-1 was installed upgradient of the ASTs in
December 2008 and was sampled in December 2008 and then annually from December 2010 to December 2015 (note that sampling was not performed in December 2009 because the ASTs were
empty until 2010 and sampling was not required until the use of the ASTs commenced). The location of well HHMW-1 is indicated in the attached figure. Results of the seven sampling events performed on
HHMW-1 have not indicated detectable concentrations of compounds (other than a trace concentration of the common laboratory contaminant acetone in one sampling event).
As we discussed, H&H mobilized to the site on December 29 to perform the annual sampling event and
could not locate well HHMW-1. Subsequent investigation and discussions with Premier personnel indicated that the area of the well was paved with concrete in February 2016 and it appears that the well
was inadvertently covered at that time. Therefore, in accordance with our discussions, we are proposing the following modifications to the Brownfields groundwater sampling for the site:
1. We request to use previously installed well ATC-12 for the sampling events instead of HHMW-
1. The location of ATC-12 is indicated in the attached figure and is located approximately 200 ft upgradient (west-southwest) of well HHMW-1 (groundwater flow lines from data collected by
H&H in 2011 are included on Figure 1 for reference). ATC-12 is also located between the former underground storage tank (UST) area on Level I of the site (where VEW-1 is identified
in the figure) and the petroleum ASTs and therefore will satisfy the intent of the well which is to ensure that potential petroleum-related impacts from Level I can be distinguished from
Dixie Trucking Property Decision of Memorandum
Page 3 of 3 potential impacts from the ASTs. The last time well ATC-12 was sampled in 2006 (see attached report) there were no detectable volatile organic compounds (VOCs).

2. We also request that the sampling frequency for well ATC-12 be reduced from annual to every
two years. We believe that this is supported by the lack of detections in well HHMW-1 during the seven sampling events that have occurred since 2008 and the minimal potential for a
release from the ASTs. The ASTs are located in secondary containment that is designed to contain 110% of the largest tank, the dispensers are located in a covered containment area
that discharges to an oil/water separator, and the facility has a Spill Prevention Countermeasures and Control Plan.
As we discussed, to allow time for your review of this request and to sample the well, we also request an
extension until February 28, 2017 to submit the report of the groundwater monitoring to the DEQ Brownfields Section. Assuming you approve this request, we understand that M.H.O.C., LLC can indicate
on the Land Use Restriction Update due at the end of January 31, 2017 that an extension has been granted for the sampling.
Please let us know if you have any questions or comments. We look forward to your response in the near
future. Thanks.

Steven Hart, PG, Principal Hydrogeologist
Hart & Hickman, PC | 2923 South Tryon Street, Suite 100 | Charlotte, NC 28203 Direct 704-887-4610 | Mobile [phone] | Main 704-586-0007
www.harthickman.com
On January 26, 2017, DEQ BF Program responded that an extension would be granted. The request for reduction in sampling was not completed and an annual groundwater sampling event was completed for
January 2018. The issue is being reviewed and based on the information presented, DEQ has determined that the sampling event frequency can be reduced from annually to bi-annually (every two years).