20026 Kaiser Fluid Env Mng Letter-Approval 20180730

July 30, 2018

Sent Via E-Mail
Matt Ingalls
Hart & Hickman, PC 2923 S. Tryon Street, Suite 100
Charlotte, North Carolina 28203
[e-mail]

Subject: Work Plan Approval Kaiser Fluids Tech II Brownfields Site
530 & 600 East Sugar Creek Road
Charlotte, Mecklenburg County
Brownfields Project No. 20026-16-060
Dear Mr. Ingalls,
The Department of Environmental Quality (DEQ) Brownfields Program received the
Environmental Management of Geotechnical Assessment and Limited Building Renovation Activities dated July 27, 2018 for the above referenced Brownfields Property. DEQ Brownfields reviewed this document, and determined that comments made by DEQ
Brownfields to the previous versions of this work plan (dated July 20) have been incorporated as
requested. Therefore, DEQ Brownfields approves the Work Plan dated July 27, 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 Mininch Brownfields Project Manager

ec: Tony Kuhn [e-mail]
Brett Lawrence [e-mail]

Via Email

July 27, 2018
(Revision 1)

NC Department of Environmental Quality Brownfields Program 1646 Mail Service Center
Raleigh, NC 27699-1646

Attention: Ms. Carolyn Minnich
Re: Environmental Management of
Geotechnical Assessment and
Limited Building Renovation Activities Kaiser Fluids Tech II Brownfields Site 530 and 600 East Sugar Creek Road
Charlotte, North Carolina
Brownfields Project No. 20026-16-060
H&H Job No. AMK-011
Dear Carolyn:
1.0 Introduction

On behalf of Flywheel Group, LLC, Hart & Hickman, PC (H&H) has prepared this letter to present
best management practices and field procedures to address potential unknown environmental
conditions at the former Henkel Chemical Corporation (600 E. Sugar Creek Road) portion of the
Kaiser Fluids Tech II Brownfields property (Site or subject Site). The former Henkel Chemical
Corporation (Henkel) portion of the Brownfields property was developed in 1953 and was utilized
by Henkel (a.k.a. Standard Chemical) to manufacture, store, and distribute textile chemicals until
the early 1990s.

Other Site tenants included: Hedgecock Lumber (1998) who utilized a portion of the warehouse
for storage and distribution of lumber products; Bradco Supply (1998 to 2012) who utilized the
facility for storage and distribution of building materials including roofing, siding, doors,
windows, and other miscellaneous building supplies; and Source Recycling most recently utilized
Ms. Carolyn Minnich
July 27, 2018 Page 2

the Site for consolidating and compaction of aluminum cans and other metal materials (2012 to
2017). Warehouse #1 was developed in 1953 and Warehouse #2 was developed in the 1960s. The
former R&D building was developed in the late 1960s and Warehouse #3 was developed in the
early 1970s. The R&D building and an adjacent storage building were demolished and removed
from the Site in 2012.

H&H is submitting this letter to safely facilitate initial redevelopment activities scheduled to be
performed by contractors prior to final approval of an Environmental Management Plan (EMP) by
the North Carolina Department of Environmental Quality (DEQ) Brownfields Program. The initial
proposed scope of work to be performed by contactors includes the following:

1) advancing five (5) geotechnical soil borings in the north-central portion of the former
Henkel parcel in support of a proposed building expansion; and
2) limited interior building renovation activities to install restrooms and associated subsurface
utility lines in the central portion of Warehouse #1 and in southwest portion of Warehouse
#3 in the Henkel building.

With your approval, contractors under the direction of Flywheel Group, LLC, will initiate the
redevelopment activities listed above the week of August 6-10, 2018 in accordance with the
policies and procedures summarized below.
2.0 Geotechnical Assessment Activities
The proposed geotechnical assessment activities will be conducted by a geotechnical contractor and
will include advancing five (5) geotechnical soil borings in the north-central portion of the Henkel
parcel to an approximate depth of 40 ft below ground surface (bgs) using a drill rig. The proposed
geotechnical boring locations are presented on Figure 1. The geotechnical contractor will advance
hollow-stem, continuous-flight augers in the north-central portion of the Site to collect soil samples
using a split-barrel sampler and perform Standard Penetration Tests (SPTs). Groundwater is
anticipated to be encountered between depths of approximately 20 to 25 ft bgs and prior to the
Ms. Carolyn Minnich
July 27, 2018 Page 3

anticipated boring termination depth (40 ft bgs). Soil cuttings generated from within the water table
will be managed in accordance with the practices and procedures outlined below.

Please note that previous soil assessment activities conducted in July 1999 in the vicinity of the
proposed geotechnical borings indicated the presence of low-level diesel range total petroleum
hydrocarbons (TPH-DRO) at concentrations below DEQ Action Levels in soil at depths of up to 16 ft
bgs. Polychlorinated biphenyls (PCBs), volatile organic compounds (VOCs), and semi-volatile
organic compounds (SVOCs) were not detected in the soil sample collected in the vicinity of the
proposed geotechnical borings at concentrations above laboratory reporting limits. Additionally,
previous groundwater assessment activities conducted in September 2011 in the vicinity of the
proposed geotechnical borings indicated the presence of 1,4-dioxane at a concentration of 16 µg/L
which above the DEQ 2L Groundwater Quality Standard (2L Standard) of 3 µg/L. No other VOCs,
and no SVOCs or PCBs were detected in the groundwater sample collected in the vicinity of the
proposed geotechnical borings at concentrations above laboratory reporting limits. Therefore, the
geotechnical contractor will observe soils for evidence of potentially impacted soil (i.e., distinct
unnatural color, discoloration, or strong odors) during boring advancement. H&H personnel will
be on-site during initial subsurface investigation activities and we will remain on call to provide
assistance on an as-needed basis for the duration of the geotechnical assessment activities.
Historical soil and groundwater analytical data is presented in Appendix A.

Soil cuttings generated during the geotechnical assessment will be stockpiled at a secure location on-
site. Soil management and sampling activities 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 version of the U.S. Environmental Protection
Agency (EPA) Region IV Science and Ecosystem Support (SESD) Field Branches Quality System
and Technical Procedures guidance.

It is anticipated that approximately 10 cubic yards of soil cuttings will be generated during the
geotechnical assessment activities. The soil stockpile will be underlain by and covered with minimum
10-mil plastic sheeting. It is anticipated that soil cuttings generated during geotechnical assessment
Ms. Carolyn Minnich
July 27, 2018 Page 4

activities will be stockpiled on-site for reuse during redevelopment; therefore, H&H will collect
one representative soil sample per 5 cubic yards of soil from the stockpile (total of 2 samples) for
characterization purposes. The soil sample aliquots will be collected utilizing a decontaminated
stainless-steel hand auger. The sample aliquots will be collected from representative locations
within the stockpiled material and field-composited by the sampler using a decontaminated
stainless-steel mixing bowl and spoon. Following sample collection, the composite sample will
be submitted to a North Carolina certified laboratory for analysis of volatile organic compounds
(VOCs) by EPA Method 8260B, semi-VOCs (SVOCs) by EPA Method 8270D, and Resource
Conservation and Recovery Act (RCRA) metals by EPA Methods 6020/7471 plus hexavalent
chromium by EPA Method 7196. In the unlikely event that the results of analysis of the composite
soil samples indicate that the soil could potentially exceed toxicity characteristic hazardous waste
criteria, then H&H will direct the lab to analyze the soil sample for toxicity characteristic leaching
procedure (TCLP) for the appropriate compound(s). H&H will share the soil analytical results
with the Brownfields project manager and obtain approval prior to reuse of the stockpiled soil at
the Site. In the unlikely event that the composite sample data indicates concentrations above TCLP
hazardous waste criteria, then the soil must be transported off-site to a permitted disposal facility
that can accept or treat hazardous waste.

For field and laboratory quality assurance/quality control (QA/QC) purposes, H&H will collect
one duplicate soil sample. Sufficient sample will be collected in the field in order to perform the
duplicate analyses from one of the waste characterization field-composited samples. The duplicate
sample will be analyzed for the same compounds as the parent sample. In addition, H&H will
request a Level II QA/QC data package from the laboratory and the laboratory will report estimated
values to the laboratory-specified method detection limits using J-flags.

Ms. Carolyn Minnich
July 27, 2018 Page 5

3.0 Limited Renovation Activities

The proposed limited renovation activities consist of installing restrooms and subsurface utility lines
within the central portion of Warehouse #1 and in southwest portion of Warehouse #3 of the Henkel
building. The areas to be disturbed during water line installation activities are presented on Figure
1 and the tasks to be performed by the contactor will include:

• cutting through the concrete slab in the central portion of Warehouse #1 and the southwest
portion of Warehouse #3;
• removal of the cut concrete, excavation, and trenching of soil to an estimated depth of up
to two ft below ground surface;
• backfill of the excavated soil implementing “last out, first in” backfill techniques and
replacement of the concrete floor to cap the excavation; and
• disposal of the concrete in an off-site permitted landfill.

Please note that H&H conducted Brownfields assessment activities at the Site in January 2018 that
included collection of concrete slab core samples and sub-slab vapor samples for laboratory analysis
at locations inside the Henkel building. The concrete slab samples were collected in the vicinity of the
water line trenching in Warehouse #1 (CS-3 and CS-4) and Warehouse #3 (CS-2). Results indicated
that VOCs and polychlorinated biphenyls (PCBs) were not detected at concentrations above DEQ
Residential or Commercial Preliminary Soil Remediation Goals (PSRGs) in the concrete slab samples
CS-2 through CS-4 (see Table 1).

Sub-slab vapor samples were also collected in the vicinity of the water line trenching in Warehouse #1
(SSVP-6 and SSVP-7) and Warehouse #3 (SSVP-2) and analyzed for VOCs. Results indicated that
VOCs were not detected at concentrations above DEQ Non-Residential Sub-Slab Screening Levels in
the sub-slab vapor samples (see Table 2).

Based on the January 2018 sample data, the contractor will be directed to inspect soils for evidence of
potential impact (i.e., unnatural color, discoloration, or strong odor). Similar to geotechnical activities,
Ms. Carolyn Minnich
July 27, 2018 Page 6

H&H personnel will be on call to provide assistance on an as-needed basis for the duration of the
renovation activities.

4.0 Contingency Plan

During construction activities, contractors may encounter potential unknown sub-surface
environmental conditions that, if encountered, will require proper management. Potential
unknown environmental conditions could include significantly impacted soils or disposed
materials of concern (i.e. tanks, drums, etc.).

In the event that such conditions are encountered during Site development activities, the tasks
noted below will be used to direct environmental actions to be taken during these activities.

1. During soil disturbance at the Site, the workers or contractors will observe soils for
evidence of impacted soil. Evidence of potential impacted soil includes a distinct unnatural
color, discoloration, strong odor, or observance of filled or previously disposed materials
of concerns (i.e. chemicals, tanks, drums, etc.). Should any of the above be noted during
site work, the contractor will contact H&H to observe the suspect condition. If H&H
confirms that the material may be impacted, then Brownfields will be notified within 24
hours. H&H will remain on call to provide assistance on an as-needed basis.

2. Suspect significantly impacted soil encountered during utility line installation activities
inside the Henkel building may be stockpiled and covered in a secure area on-site to allow
construction to progress. Suspect impacted soil will be underlain by and covered with
minimum 10-mil plastic sheeting. At least one representative sample of the soil will be
collected for analysis of total PCBs by EPA Method 8082A, total VOCs by EPA Method
8260B, SVOCs by EPA Method 8270D, and RCRA metals by EPA Methods 6020/7471
plus hexavalent chromium by EPA Method 7196. If the results of analysis of the sample
indicate that the soil could potentially exceed toxicity characteristic hazardous waste
criteria, then the soil will also be analyzed for TCLP for appropriate compounds. Soil
Ms. Carolyn Minnich
July 27, 2018 Page 8

Attachments: Table 1 Summary of Concrete Slab Analytical Results
Table 2 Summary of Sub-Slab Analytical Results
Table 3 Summary of Risk Assessment Calculator Output

Figure 1 Site Map
Appendix A Historical Soil and Groundwater Analytical Data

Tables
Table 1Summary of Concrete Slab Analytical Results (Former Henkel Building)Kaiser Tech IICharlotte, North CarolinaH&H Job No. AMK-011Area of ConcernFormer Boiler RoomSample IDCS-1 CS-2 CS-3 CS-4 CS-5 CS-6 CS-8Date1/3/2018 1/3/2018 1/3/2018 1/3/2018 1/3/2018 1/3/2018 1/3/2018VOCs (8260) mg/kgAcetone 12,000 100,000 0.068<0.051 <0.051 <0.052 <0.050 <0.051 <0.053 <0.0510.060Chlorobenzene 58 280<0.0052 <0.0051 <0.00510.23 0.0065<0.0051 <0.0053 <0.0051 <0.00561,2-Dichlorobenzene 380 380<0.0052 <0.0051 <0.00510.011 0.10<0.0051 <0.0053 <0.0051 <0.00561,4-Dichlorobenzene 2.8 12<0.0052 <0.0051 <0.00510.061 0.0091<0.0051 <0.0053 <0.0051 <0.00564-Isopropyltoluene NS NS<0.0052 <0.0051 <0.00510.0061<0.0050 <0.0051 <0.0053 <0.0051 <0.0056Naphthalene 4.1 18<0.010 <0.010 <0.0100.025<0.0100.017<0.011 <0.010 <0.011PCBs (8082A) mg/kgAroclor 1248 0.23 0.96<0.052 <0.0520.17 0.10 0.1610<0.0520.052 A 0.071Aroclor 1254 0.23 0.99 0.15<0.052 <0.052 <0.0520.092<0.052 <0.052 <0.052 <0.052Notes:1) North Carolina Department of Environmental Quality (DEQ) Inactive Hazardous Sites Branch (IHSB) Preliminary Soil Remediation Goals (PSRGs) (October 2017) based on hazard quotient of 0.2 for non-carcinogens and lifetime incremental cancer risk of 1.0E-6 for carcinogens.Bold values exceed a Residential PSRG (October 2017)Underlined values exceed an Industrial/Commercial PSRG (October 2017)Concrete sample concentrations are reported in milligrams per kilogram (mg/kg)Laboratory analytical methods are shown in parentheses VOCs = Volatile Organic Compounds; PCBs = Polychlorinated BiphenylsJ = estimated value between the laboratory detection limit and the laboratory reporting limitA = Laboratory review indicates aroclor pattern present on primary instrument column, but could not be confirmed on secondary column.NS = No StandardCS-7 / Duplicate1/3/2018Residential PSRGs (1) (mg/kg)Industrial/Commercial PSRGs (1) (mg/kg)Warehouse #2Warehouse #3 Warehouse #1S:\AAA-Master Projects\Anthony Kuhn - AMK\AMK-011 Henkel-Kaiser BF Site\Tables\Analytical Data Tables2/16/2018Table 1 (Page 1 of 1)Hart & Hickman, PC
Table 2Summary of Sub-Slab Analytical Results (Former Henkel Building)Kaiser Fluids Tech IICharlotte, North CarolinaH&H Job No. AMK-011Acetone2-Butanone (MEK)Carbon Disulfide1,2-DichlorobenzeneDichlorodifluoromethane (Freon 12)1,4-DioxaneEthanolEthyl Acetate2-HexanoneIsopropyl AlcoholMethyl Isobutyl KetonePropyleneTertiary Butyl AlcoholTetrachloroethyleneToluene1,1,1-TrichloroethaneTrichloroethylenem,p-Xyleneo-XyleneXylenes (Total)SSVP-1 1/4/2018114 2.3 J<2.52.7 J 2.0 J 21 78.2<2.9 <3.3125<3.3 <3.41.7 J 12 3.8<4.4 <0.862.0 J<3.52.0 JSSVP-2 1/4/201872.7 4.1 2.6<4.82.2 J 6.5 35.8<2.9 <3.315 2.0 J<3.41.3 J 3.3<3.0 <4.4 <0.863.0 J<3.53.0 JSSVP-3 1/4/2018 Offices1,070 4.1 4.0<7.2 <5.919 415<4.3 <4.91,360<4.9 <5.36.1 8.1 3.8 J<6.5 <1.38.7 2.6 J 11SSVP-4 1/4/2018 Warehouse #1 Storage Room494 38.6 3.4<4.82.6 J 7.9 80.5<2.92.0 J 33.9 2.5 J 2.6 J 4.9<1.11.4 J<4.42.5<3.5 <3.5 <3.5SSVP-5 1/4/2018 Former Boiler Room36.3 2.9 3.4<4.82.4 J<2.9143<2.9 <3.38.4<3.3 <3.41.5 J 1.5 1.4 J<4.41.6<3.5 <3.5 <3.5SSVP-6 1/4/201817 1.4 J<2.5 <4.8 <4.0 <2.921.1<2.9 <3.3 <2.0 <3.31.7 J 1.2 J 168<3.0 <4.412<3.5 <3.5 <3.5SSVP-7 /8.6<2.42.0 J<4.82.2 J<2.98.9<2.9 <3.3 <2.0 <3.31.2 J<2.410<3.0 <4.4 <0.86 <3.5 <3.5 <3.5Duplicate16 2.5 2.0 J<4.82.3 J<2.911 4.7<3.3 <2.0 <3.31.3 J<2.415<3.0 <4.40.91<3.5 <3.5 <3.5SSVP-8 1/4/2018 Warehouse #2112 1.4 J 4.7<4.82.4 J 1.5 J 152<2.9 <3.336.6<3.31.5 J 1.4 J 6.8 1.5 J 3.2 J<0.86 <3.5 <3.5 <3.52,700,000 440,000 61000 18,000 8,800 2,500 NS 6,100 2,600 NS 260,000 260,000 NS 3,500 440,000 440,000 180 8,800 8,800 8,800Notes:1) North Carolina Department of Enviornmental Quality (DEQ) Division of Waste Management (DWM) Non-Residential Sub-slab and Exterior Soil Gas Screening Levels (SGSLs) (October 2017)Only compounds detected in at least one sample shownµg/m3 = micrograms per cubic meter; NS = Not SpecifiedJ = detected concentration is above the laboratory method detection limits, but below the laboratory calibrated reporting limit. Therefore, the reported concentration is an estimated value.Warehouse #1µg/m3Non-Residential Sub-Slab Screening Level (1)Sample IDSampling DateAnalytical MethodTO-151/4/2018Area of ConcernWarehouse #3S:\AAA-Master Projects\Anthony Kuhn - AMK\AMK-011 Henkel-Kaiser BF Site\Tables\Analytical Data Tables2/16/2018Table 2 (Page 1 of 1)Hart & Hickman, PC
Table 3Summary of Risk Assessment Calculator Output(Based on Former Henkel Building Sub-Slab Analytical Results)Kaiser Fluids Tech IICharlotte, North CarolinaH&H Job No. AMK-011Calculated LICR Calculated HISSVP-1 8.8E-08 0.0038 NOSSVP-2 2.7E-08 0.00099 NOSSVP-3 7.9E-08 0.018 NOSSVP-4 4.1E-08 0.0041 NOSSVP-5 5.7E-09 0.0021 NOSSVP-6 7.6E-08 0.023 NOSSVP-7 / 2.1E-09 0.00063 NODuplicate 6.2E-09 0.0021 NOSSVP-8 7.6E-09 0.001 NONotes:1) Based on the North Carolina Department of Environmental Quality (DEQ) Risk Calculator for Non-Residential Use Scenario of the Soil Gas to Indoor Air Exposure Pathway (October 2017 Version)LICR = Lifetime Incremental Cancer Risk HI = Hazard IndexSample IDNon-Residential Worker(1)Risk Exceeded?S:\AAA-Master Projects\Anthony Kuhn - AMK\AMK-011 Henkel-Kaiser BF Site\Tables\Analytical Data Tables2/16/2018Table 3 (Page 1 of 1)Hart & Hickman, PC
Figure
E. SUGAR
CREEK
DR
IVE
BR
IDGE
(UNDER
DEVELOPMENT
)
GRAVEL
RALEIGH STR
E
E
T
VACANT
WAREHOUSE
(3745 N. DAVIDSON STREET)
BLUE RIDGE RECYCLING/
ALLIED PRODUCTS
(3811 N. DAVIDSON STREET)
VACANT
WAREHOUSE
(3801 N. DAVIDSON STREET)
ALL AMERICAN PAWN
(724 E. SUGAR CREEK ROAD)
RIVERSIDE MILLWORK
(4000 RALEIGH STREET)
CONCRETE
HAVEAFIL
(4001 RALEIGH STREET)
FORMER KAISER
FLUID TECHNOLOGIES
(530 E. SUGAR CREEK ROAD)
SUPERIOR DISTRIBUTION
(6001 E. SUGAR CREEK ROAD)
FORMER RESEARCH AND DEVELOPMENT LAB
(REMOVED IN 2012)
TRUCK SCALE
RAMP TO
BASEMENT
WAREHOUSE #3
OFFICES
WAREHOUSE #2
(STORAGE)
WAREHOUSE #1
(FORMER PROCESS AREA)
CATS LYNX L
I
G
H
T
R
A
I
L

L
I
N
E
NORFOLK SO
U
T
H
E
R
N

R
A
I
L
R
O
A
D
RESIDENCES
MW-2
MW-3
MW-4
MW-7
MW-5
MW-6
LOADI
N
G

D
O
C
K
PARKING GARAGE
CATS LYNX LIGHTRAIL
PROPOSED RESTROOM
LOCATION
SSVP-8
SSVP-7
SSVP-6
SSVP-4
SSVP-5
SSVP-3SSVP-2
SSVP-1
CS-8
CS-7
CS-3
CS-5
CS-4
CS-6
CS-2
CS-1
FORMER HENKEL CHEMICAL CORPORATION
CHARLOTTE, NORTH CAROLINA
SITE MAP
LEGEND
SITE PROPERTY BOUNDARY
RAILROAD TRACKS
FORMER RAILROAD SIDING
FENCE LINE
FORMER WASTEWATER
EFFLUENT LINE FROM TRENCH
DRAINS
FLOOR DRAINS
CATCH BASIN
PAD-MOUNTED TRANSFORMER
POLE-MOUNTED TRANSFORMER
MONITORING WELL LOCATION
SUB-SLAB VAPOR SAMPLE
CONCRETE SLAB SAMPLE
2923 South Tryon Street-Suite 100Charlotte, North Carolina 28203704-586-0007(p) 704-586-0373(f)License # C-1269 / #C-245 Geology
S:\AAA-Master Projects\Anthony Kuhn - AMK\AMK-011 Henkel-Kaiser BF Site\Figures\Proposed Sample Location Map.dwg, FIG 2, 2/16/2018 2:31:27 PM, zbarlow1
PROPOSED CONCRETE SAW CUT
PROPOSED GEOTECHNICAL BORING
PROPOSED RESTROOM
LOCATION
Appendix A
Historical Soil and Groundwater Analytical Data
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