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Home My WebLink About18044_LRMF_ P-2918F_Brownfields Update Letter _20190115 Via Email January 15, 2019 NC DEQ Division of Waste Management Brownfields Program 1646 Mail Service Center Raleigh, NC 27699-1646 Attention: Ms. Carolyn Minnich Re: Brownfields Update Brownfields Project 18044-14-060 NC DOT Parcels 31.1/32 Charlotte Locomotive and Railcar Maintenance Facility State Project: P-2918F; WBS Element: 50000.3.1 Charlotte, Mecklenburg County, North Carolina H&H Project No. ROW-510 Dear Carolyn: Please find the attached Brownfields Update Report in PDF format for environmental and redevelopment activities for Brownfields Project No. 18044-14-060 located at the Charlotte Locomotive and Railcar Maintenance Facility in Charlotte, Mecklenburg County, North Carolina. If you have any questions or need additional information, please contact us at (704) 586-0007. Sincerely, Hart & Hickman, PC David Graham, PG Matt Bramblett, PE Senior Project Geologist Principal Attachment cc: Mr. Gordon Box, LG, NC DOT (via Email) Mr. Cyrus Parker, LG, PE, NC DOT (via Email) Mr. Craig Newton, PE, NC DOT (via Email) Ms. Moriah Ellington, PE, STV, Inc. (via Email) Brownfields Update NC DOT Parcel 31.1/32 Charlotte Locomotive and Railcar Maintenance Facility Charlotte, Mecklenburg County North Carolina Brownfields Project 18044-14-060 H&H Job No. ROW-510 State Project P-2918F WBS Element #50000.3.1 January 15, 2019 Via Email January 15, 2019 NC DEQ Division of Waste Management Brownfields Program 1646 Mail Service Center Raleigh, NC 27699-1646 Attention: Ms. Carolyn Minnich Re: Brownfields Update Brownfields Project 18044-14-060 NC DOT Parcels 31.1/32 Charlotte Locomotive and Railcar Maintenance Facility State Project: P-2918F; WBS Element: 50000.3.1 Charlotte, Mecklenburg County, North Carolina H&H Project No. ROW-510 Dear Carolyn: 1.0 Introduction On behalf of the North Carolina Department of Transportation (NC DOT), Hart & Hickman, PC (H&H) is submitting this letter report summarizing activities conducted at the above referenced Brownfields property (NC DOT Parcels 31.1/32) located at 1320 and 1336 S. Graham Street. This site is part of the Charlotte Locomotive and Railcar Maintenance Facility (LRMF) in Charlotte, Mecklenburg County, North Carolina. A site location map is included as Figure 1, and a site map is included as Figure 2. In accordance with the Brownfields Agreement (BFA), within 90 days of each one-year anniversary of the effective date (October 24, 2016) of the BFA during redevelopment for the Brownfields property, and/or at the completion of redevelopment activities, H&H, on behalf of NC DOT, will submit a report to NC DEQ documenting the redevelopment and environmental Ms. Carolyn Minnich January 15, 2019 Page 2 S:\AAA-Master Projects\NC DOT Right-of-Way -ROW\ROW-500s\ROW-510 P-2918F Hazardous Soil & Brownfields\Brownfields Final Report 2019\P- 2918F_Brownfields Update Letter _20190115.doc activities conducted on the Brownfields property for the reporting period. A general summary of activities conducted at the Brownfields property over the past year is provided below. The Brownfields property has been redeveloped as part of the NC DOT LRMF project. Construction activities started on the LRMF project in October 2016. NC DOT’s construction contractor, Zoladz Construction Company, Inc. (Zoladz) has completed final construction activities associated with mass grading, railroad service tracks, service platform, compressor building, landscaping, etc. on the Brownfields property. A summary of environmental reports associated with the site that have recently been submitted to DEQ are provided below. - Environmental Management Plan - Charlotte Locomotive and Railcar Maintenance Facility, May 6, 2016 - Hazardous Soil Treatment and Removal Activities - NC DOT Parcel 32, August 5, 2016 - Brownfields Soil Sampling - NC DOT Parcel 32, June 23, 2016 - Brownfields Soil Berm Sampling - NC DOT Parcel 31.1/32, June 15, 2017 - Brownfields Update - NC DOT Parcel 31.1/32, January 18, 2018 2.0 Environmental and Redevelopment Activities Summary Previous Environmental and Redevelopment Activities Based on historical assessment activities, widespread impacted soil was previously identified on the Brownfields property. The primary contaminants are total petroleum hydrocarbons (TPH), polychlorinated biphenyls (PCBs), and metals (including lead above characteristically hazardous waste thresholds). A portion of the lead impacted soil above hazardous waste thresholds was located in the proposed LRMF cut area on the northern portion of Parcel 32. Prior to construction activities in May 2016, this hazardous soil was treated on-site to stabilize the lead impacts to below hazardous waste thresholds for subsequent disposal at a Subtitle D landfill. Ms. Carolyn Minnich January 15, 2019 Page 3 S:\AAA-Master Projects\NC DOT Right-of-Way -ROW\ROW-500s\ROW-510 P-2918F Hazardous Soil & Brownfields\Brownfields Final Report 2019\P- 2918F_Brownfields Update Letter _20190115.doc The LRMF project also required soil (including low-level non-hazardous impacted soil) to be cut from the northern portion of the Brownfields property Parcel 32. As part of the LRMF construction activities and with NC DEQ approval, Zoladz reused the cut soil from the northern portion of the Brownfields property Parcel 32 in a privacy berm on the Parcel 31.1 portion of the Brownfields property (see Figure 2). Soil that was cut from the northern portion of Parcel 32 was below NC DEQ IHSB Industrial Health-Based Soil Remediation Goals (SRGs). A small stockpile of soil which contained polynuclear aromatic hydrocarbons (PAHs) and PCBs above the Industrial SRGs was placed near the center and at the base of the berm and covered with at least two ft of soil that was not impacted above Industrial SRGs. In April 2017, Zoladz covered the entire berm with 2 ft of fill material that was cut from an area of the LRMF project outside of the Brownfields property boundary. Because the Environmental Management Plan (EMP) indicates that imported fill must be sampled prior to use as fill on the Brownfields property NC DEQ requested that this material be sampled. Analytical results indicated low level detections of PCBs and/or metals below the Industrial SRGs in soil samples collected from the berm cover soil. Because the detected constituents were below Industrial SRGs, the berm soil cover was left in place. The berm was subsequently seeded and mulched by Zoladz using hydroseeding to prevent erosion of the berm. In February 2017, NC DEQ approved Zoladz work plan to allow for temporary use of heavy machinery for crushing rock (blasted and removed from other areas of the LRMF project) and for storage of the crushed rock on the Brownfields property. The work plan addressed preserving and restoring the asphalt parking lot which is serving as a protective cap over an area of impacted soil. The asphalt parking area and former concrete building slab on the Brownfields property were then used to store crushed rock piles, railroad construction materials, and some heavy machinery. The above mentioned activities were previously documented in H&H’s Brownfields Update letter report dated January 18, 2018 and in the historical environmental reports noted above. Ms. Carolyn Minnich January 15, 2019 Page 4 S:\AAA-Master Projects\NC DOT Right-of-Way -ROW\ROW-500s\ROW-510 P-2918F Hazardous Soil & Brownfields\Brownfields Final Report 2019\P- 2918F_Brownfields Update Letter _20190115.doc 2018 Environmental and Redevelopment Activities In March 2018, Zoladz completed removal of the crushed rock, heavy machinery, etc. from the Brownfields property. H&H subsequently met with NC DEQ on site and determined that several areas of the asphalt and concrete cap (former building slab) that cover impacted soil at the site needed to be repaired. On April 5, 2018, Zoladz patched the damaged areas in the asphalt parking area and concrete slab that required repairs as specified by NC DEQ. On May 25, 2018, H&H met with NC DEQ to inspect the repairs made by Zoladz. The patchwork on the asphalt and concrete cap above the impacted soil area was approved in NC DEQ letter dated June 5, 2018. Photographs of asphalt patching repairs are included in Appendix A. In July 2018 H&H personnel observed an electrical trench being installed in the northern portion of the asphalt parking area on Parcel 32. The trench was approximately 2ft x 150 ft long and 3 ft deep (see Figure 2). After the electrical utility installation was completed the soil that was excavated from the trench was used as backfill in the trench in accordance with the EMP. After backfilling was complete a small amount (approximately a dump truck load) of the excavated soil remained and could not be used as backfill. This soil was stockpiled and covered with plastic. H&H sampled the stockpile to determine if the material was suitable for placement in the berm. The sample results are described below. 3.0 Soil Sampling Activities and Analytical Results On July 27, 2018, H&H collected a composite sample (BF Stockpile) from the utility trench soil stockpile using a stainless-steel hand auger. The sample consisted of aliquots of soil collected from the mid-point of three soil borings advanced into the stockpile. Equal amounts of each of the aliquots were placed in an inert container and mixed with a nitrile gloved hand until homogenized. The homogenized sample was then placed into laboratory supplied sample containers, placed in an iced cooler, and submitted to Prism Laboratories (Prism) under chain-of- custody protocol for analysis of semi-volatile organic compounds (SVOCs) by EPA Method 8270, total RCRA metals by EPA Method 6010/7471, toxicity characteristic leaching procedure Ms. Carolyn Minnich January 15, 2019 Page 5 S:\AAA-Master Projects\NC DOT Right-of-Way -ROW\ROW-500s\ROW-510 P-2918F Hazardous Soil & Brownfields\Brownfields Final Report 2019\P- 2918F_Brownfields Update Letter _20190115.doc (TCLP) RCRA metals by EPA Method 6010/7470 and PCBs by EPA Method 8082. Laboratory analytical data sheets and chain-of-custody documentation are included in Appendix B. The analytical results are summarized in Table 1 and discussed below. Because this is a Brownfields site, detected concentrations in the composite soil sample were compared to NC DEQ IHSB Industrial Health-Based SRGs. An elevated concentration of lead (300 mg/kg) was detected in the composite sample slightly above the Protection of Groundwater (POG) SRG of 270 mg/kg but did not exceed the Industrial SRG (800 mg/kg). A concentration of TCLP lead (1.5 mg/L) was detected in the composite sample but did not exceed the characteristic hazardous waste threshold of 5 mg/L. No PCBs or SVOCs were detected in the soil sample. Because analytical results indicated the stockpiled soil was below the Industrial SRGs, the stockpiled soil was subsequently placed in the berm. On October 18, 2018, Zoladz moved the stockpiled soil to the berm. The soil was spread on the eastern end of the berm and covered with seed and straw. Zoladz then patched the utility trench with asphalt (see Photograph in Appendix A). 4.0 Completion Statement Construction activities associated with the LRMF project and redevelopment of Brownfields Parcels 31.1/32 started in late 2016 and were completed in the Fall of 2018. NC DOT’s contractor has completed redevelopment activities associated with construction of the service tracks, service platform, compressor building, landscaping, etc. on the Brownfields property. Recent photographs of the Brownfields property are included in Appendix A. This report is considered to be the final Brownfields report for the construction on the Brownfields property (NC DOT Parcels 31.1/32) located at 1320 and 1336 S. Graham Street Table 1 (Page 1 of 1)Summary of Soil Analytical DataNC DOT Brownfields Property (#18044-14-060)Charlotte, Mecklenburg County, NCH&H Job No. ROW-510Sample IDBF StockpileSample Date7/27/2018PCBs(8082) (mg/kg)BRLSVOCs (8270)(mg/kg)BRLRange (mg/kg) Mean (mg/kg)RCRA Metals (7471/6010) (mg/kg)Arsenic 1.6 1.0-18 4.8Barium 97 50-1,000 356Cadmium 0.65 1.0-10 4.3Chromium 34 7.0-300 65Lead300ND - 50 16Mercury 0.28 0.03-0.52 0.121TCLP RCRA Metals (7470/6010) (mg/L)Lead 1.5Notes:1. NC DEQ IHSB Preliminary Industrial Health-Based Soil Remediation Goals (PSRGs) - February 20182. NC DEQ IHSB Protection of Groundwater (POG) PSRGs - February 20183. Range and Mean background values for North Carolina or Southeast soils taken from Elements in North American Soils by Dragun and Chekiri, 2005EPA Method follows parameter in parentheses; -- = Not Applicable; BRL= Below reporting limitPCBs = polychlorinated biphenyls; SVOCs= semi-volatile organic compounds;TCLP = Toxicity Characteristic Leaching ProcedureBold = exceeds IHSB POG PSRG; mg/kg = milligrams per kilogramIHSB Industrial PSRG1IHSB POG2(mg/kg) (mg/kg)Screening Criteria-- ---- --3.0 5.847,000 5801.03350,000 360,000RCRA Toxicity Characteristic Level (mg/L)5Background Metals in Soil3200800 2709.7S:\AAA‐Master Projects\NC DOT Right‐of‐Way ‐ROW\ROW‐500s\ROW‐510 P‐2918F Hazardous Soil & Brownfields\Brownfields Final Report 2019\BF Stockpile Data Table.xlsTable 1 (Page 1 of 1)Hart & Hickman, PC SITE 0 2000 4000 APPROXIMATE SCALE IN FEET N U.S.G.S. QUADRANGLE MAP QUADRANGLE 7.5 MINUTE SERIES (TOPOGRAPHIC) Charlotte East, NC 1991 TITLE PROJECT SITE LOCATION MAP NC DOT BROWNFIELDS PROPERTY #18044-14-060 1320 & 1336 S. GRAHAM STREET CHARLOTTE, NORTH CAROLINA DATE: JOB NO: REVISION NO: FIGURE: 1-9-19 0 1ROW-510 714715 716716 71771771871 8 719719719720 720 720721 721 721 722722722 723723723 724 724724725 725726726 727728 729 PENMAN S T R E E T S. G R A H A M S T R E E T CONC. BERM LOCATION CONCRETE PAD CONCRETE PAD REVISION NO. 0 FIGURE NO. 2 SITE MAP LEGEND BROWNFIELDS PROPERTY BOUNDARY PARCEL LINE OFF-SITE BUILDING RAILROAD RIGHT-OF-WAY FENCE DRAINAGE DITCH UTILITY TRENCH NC DOT PARCEL NUMBER JOB NO. ROW-510 DATE: 1-14-19 NC DOT - BROWNFIELDS PROPERTY #18044-14-060 1320 & 1336 S. GRAHAM STREET CHARLOTTE, MECKLENBURG COUNTY 2923 South Tryon Street-Suite 100 Charlotte, North Carolina 28203 704-586-0007(p) 704-586-0373(f) License # C-1269 / #C-245 Geology ASPHALT ASPHALT COMPRESSOR BUILDING LOCATION ACCESS ROAD CONCRETE SERVICE PLATFORM RAILROAD SERVICE TRACKS S:\AAA-Master Projects\NC DOT Right-of-Way -ROW\ROW-500s\ROW-510 P-2918F Hazardous Soil & Brownfields\Brownfields Update Report\Site Map.dwg, FIG 2, 1/14/2019 10:34:55 AM, erichardson Appendix A Site Photographs Photograph 2: View of asphalt cap (January 2019).ROW-510BROWNFIELDS PROJECT 18044-14-060 CHARLOTTE, NORTH CAROLINA 2923 S. Tryon Street, Suite 100 Charlotte, NC 28203 704.586.0007(p) 704.586.0373(f) Photograph 1: Northern portion of the Brownfields property (January 2019). Photograph 4: Typical asphalt patch areas on the eastern portion of the Brownfields property.ROW-510BROWNFIELDS PROJECT 18044-14-060 CHARLOTTE, NORTH CAROLINA 2923 S. Tryon Street, Suite 100 Charlotte, NC 28203 704.586.0007(p) 704.586.0373(f) Photograph 3: View of the berm from the northwest (January 2019). Berm ROW-510BROWNFIELDS PROJECT 18044-14-060 CHARLOTTE, NORTH CAROLINA 2923 S. Tryon Street, Suite 100 Charlotte, NC 28203 704.586.0007(p) 704.586.0373(f) Photograph 5: Asphalt cap over utility trench. Appendix B Laboratory Analytical Data Report Page 1 of 16 Page 2 of 16 Page 3 of 16 Page 4 of 16 Page 5 of 16 Page 6 of 16 Page 7 of 16 Page 8 of 16 Page 9 of 16 Page 10 of 16 Page 11 of 16 Page 12 of 16 Page 13 of 16 Page 14 of 16 Page 15 of 16 Page 16 of 16