22008 CLT Aircraft WP- DEQ Approval 20190122

January 22, 2019

Sent Via E-mail
Kaitlyn Rhonehouse Geosyntec Consultants of NC, PC
527 Old MacCumber Station, #117
Wilmington, NC 28405
[e-mail]
Subject: Work Plan Approval
Charlotte Aircraft
Charlotte, Mecklenburg County Brownfields Project No. 22008-18-060
Dear Mrs. Rhonehouse,

On January 22, 2019, the Department of Environmental Quality (DEQ) Brownfields Program received the Work Plan for Brownfields Agreement and Redevelopment: Southern and Eastern Parcel Soil Gas Assessment dated January 22, 2019 (Work Plan) for the above referenced
Brownfields Property. DEQ Brownfields reviewed this document and approves the Work Plan.

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 ec: Amy Kenwell, [e-mail]
Keith Sade, [e-mail]

Geosyntec Consultants of NC, PC
2501 Blue Ridge Road, Suite 430
Raleigh, North Carolina 27607
PH 919.870.0576
www.geosyntec.com

GN6502C/20190122 Harris BLVD WP SG Sampling

22 January 2019
Ms. Carolyn Minnich
Brownfields Project Manager
North Carolina Department of Environmental Quality
1646 Mail Service Center
Raleigh, NC 27699-1646
Subject: Work Plan for Brownfields Agreement and Redevelopment: Southern and
Eastern Parcel Soil Gas Assessment
Site: Former Charlotte Aircraft #3 7705 East WT Harris Boulevard
Charlotte, Mecklenburg County, North Carolina
Mecklenburg County Parcel IDs 10915106 and 10915110
NCDEQ Brownfields Project No 22008-18-060
NCDEQ IHSB Site ID NONCD0001478
Dear Ms. Minnich:
Geosyntec Consultants of NC, PC (Geosyntec), on behalf of our client, K Sade Ventures, LLC
(K Sade or “Client”) has prepared this revised Work Plan for the above-referenced former
Charlotte Aircraft #3 in Charlotte, North Carolina (“Site”). K Sade recently purchased the Site
from the Charlotte Aircraft Corporation (CAC) and plans to redevelop the Site under the North
Carolina Department of Environmental Quality (NCDEQ) Brownfields Program (NCBP) for
multi-family residential use. As such, K Sade submitted a Brownfields Property Application
(BPA) to the NCDEQ on 22 January 2018 as the Site Prospective Developer (PD). The Site (at
the time the Brownfields Property only included Parcel No 10915107) was accepted into the
Program in a 22 February 2018 Letter of Eligibility (LOE). On 8 November 2018, a revised
BPA was submitted to added Parcel No 10915106 and 10915110 to the Brownfields Property.
The Site has undergone environmental assessment and remediation by others, dating back to
March 2000, including soil assessment and remediation, groundwater monitoring, and soil gas
sampling. Additional assessment to establish baseline conditions and address environmental data
gaps were conducted in Fall 2018, including soil gas sampling on the northern parcel. This Work
Plan is intended to collect additional soil gas data in the southern and eastern parcels of the Site,
as requested by the NCDEQ Brownfields Program. We look forward to your review and
approval of this Work Plan.

Sincerely,

Amy Kenwell, PG(NC)
Geologist

Prepared for
K Sade Ventures, LLC
1800 Eastwood Road, Suite 114
Wilmington, North Carolina 28403

WORK PLAN FOR
BROWNFIELDS AGREEMENT AND
REDEVELOPMENT:
SOUTHERN AND EASTERN PARCEL SOIL
GAS ASSESSMENT
FORMER CHARLOTTE AIRCRAFT
CORPORATION, CHARLOTTE, NC
NCDEQ BROWNFIELDS PROJECT No 22008-18-060

Prepared by

Geosyntec Consultants of NC, PC
2501 Blue Ridge Road, Suite 430
Raleigh, North Carolina 27607
Project Number GN6502C
January 2019

TABLE OF CONTENTS
1. INTRODUCTION .................................................................................................1 
2. BACKGROUND ...................................................................................................2 
3. PROPOSED SUPPLEMENTAL ASSESSMENT ................................................4 
4. VI ASSESSMENT PROCEDURES .....................................................................5 
5. PROPOSED PATH FORWARD ..........................................................................7 
6. REFERENCES ......................................................................................................8 

LIST OF FIGURES

Figure 1 Site Location
Figure 2 Site Layout Map
Figure 3 Proposed Soil Gas Sampling Locations
Figure 4 Soil Gas Probe Construction Detail
Figure 5 Soil Gas Sampling Assembly

LIST OF APPENDICES

Appendix A Revised Brownfields Program Application
Appendix B 2017 NCDEQ IHSB Priority Delisting Memorandum

GN6502C/20190122 Harris BLVD WP SG Sampling 1 1/22/2019
1. INTRODUCTION
Geosyntec Consultants of NC, PC (Geosyntec), on behalf of K Sade Ventures, LLC (K
Sade or “Client”), has prepared this Southern and Eastern Parcel Soil Gas Assessment
Work Plan (Work Plan) for the former Charlotte Aircraft #3 facility located at 7705 East
W.T. Harris Boulevard in Charlotte, North Carolina (“Site”) (Figure 1). K Sade recently
purchased the property from the Charlotte Aircraft Corporation (CAC) and plans to
redevelop the Site for multi-family residential use, in the form of apartment buildings. K
Sade intends to redevelop the Site in accordance with, and under the environmental
protections provided by, the North Carolina Department of Environmental Quality
(NCDEQ) Brownfields Program (NCBP). As such, K Sade retained Geosyntec to guide
the environmental efforts to achieve a finalized Brownfields Agreement (BFA) for the
Site.

K Sade submitted a Brownfields Property Application (BPA) for Parcel No. 10915107
(Figure 2) to the NCDEQ on 22 January 2018 as the Site Prospective Developer (PD); the
Site was accepted into the Program in a 22 February 2018 Letter of Eligibility (LOE). On
6 March 2018, Geosyntec, K Sade, and the NCDEQ (Ms. Carolyn Minnich) discussed a
proposed path forward to obtain a BFA. As a result of that discussion, the Work Plan for
Brownfields Agreement and Redevelopment – Revision 1 (May 2018 Work Plan,
Geosyntec, 2018a) was submitted to the NCDEQ on 24 August 2018 and subsequently
approved by NCDEQ. This document presented the results of a Site historical review and
proposed assessment activities to address the remaining Site-related environmental data
gaps and establish baseline environmental conditions for the Site (associated with Parcel
No. 10915107). The implementation and results of these activities were submitted to the
NCDEQ in November 2018 as a Groundwater, Soil, and Soil Gas Assessment Report
(November 2018 Assessment Report, Geosyntec, 2018b).

On 9 November 2018, K Sade submitted a revision to the BPA to include two additional
parcels (Parcel No. 10915106 and 10915110; Figure 2) which are part of the CAC
property but were formerly not included in the original BPA for the Site (the revised BPA
is included as Appendix A). On 24 January 2019, Geosyntec, K Sade, a prospective buyer,
and the NCDEQ (Ms. Carolyn Minnich) discussed that the addition of these parcels to the
BPA property warranted additional soil gas sampling to characterize baseline soil gas
conditions. This Work Plan will support the collection of soil gas data from the Southern
and Eastern parcels.

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2. BACKGROUND
The Charlotte Aircraft Site is located in Mecklenburg County, Charlotte, North Carolina
(Figure 1) and consists of three adjoining properties totaling nearly 27 acres, subdivided
in three parcels as outlined in the inset table below. The Brownfields Site consists of these
three parcels.
Mecklenburg County
Parcel Identification
Areal
Footprint
Description
10915107 8.32 acres
7705 East WT Harris Boulevard; former source contamination
located on this property; northwestern parcel in relation to the
adjoining Site-related parcels.
10915106 12.18 acres Located south of source contamination property; ancillary
property used to support facility operations; referred to as the
Southern Parcel.
10915110 6.45 acres Located east of source contamination property; ancillary
property used to support facility operations; referred to as the
Eastern Parcel.

Each of these three parcels are planned for redevelopment; though the northwestern
parcel located at 7705 East WT Harris Boulevard (i.e., Parcel 10915107) was associated
with former source contamination. The two adjoining Site-associated parcels (i.e., Parcel
10915106 and 10915110) were included in the Site historical review but did not include
soil gas sampling during Fall 2018 assessment. The properties south and east of the
former source area property are referred to herein as the Southern Parcel (Parcel
10915106) and Eastern Parcel (Parcel 10915110), respectively. The Site currently
consists of warehouses, workshops, storage buildings, storage sheds, outdoor storage
racks, and offices. With the exception of paved interior roads, the Site is primarily
unpaved. The Site is currently unused. No supply wells are located at the Site and the
property is connected to a municipal water source. The Site is shown on Figure 2.
The Site is located in a predominantly residential area and is bordered to the south and
east by CAC property, to the west by East W.T. Harris Boulevard, and to the north by
Delta Landing Road. Residential properties are located in each direction in extended off-
Site areas beyond the immediate CAC property and East W.T. Harris Boulevard. Hickory
Grove Christian School is located north of the Site, and north and west of East W.T.
Harris Boulevard.

GN6502C/20190122 Harris BLVD WP SG Sampling 3 1/22/2019
Between July and November 2000, Duke Engineering and Services (Duke Engineering)
submitted multiple reports to NCDEQ to conduct a Site source area soil investigation and
remedy. The Duke Engineering reports (i.e., the 23 July 2000 Source Area Remediation
Report and the 16 November 2000 Groundwater Corrective Action Plan) provide the
basis for much of the Site background presented herein.
The Site formerly operated as an aircraft parts refurbishing facility since the 1950s.
Chlorinated solvents, including trichloroethene (TCE), were used for parts washing and
stripping to support facility operations. Tetrachloroethene (PCE) was not explicitly
identified in historical reports as a chemical used to support the Site cleaning operations;
however, detections of PCE in Site groundwater suggest PCE may also have been used
at the Site. Volatile organic compounds (VOCs) were originally identified in groundwater
as part of a 1995 Initial Limited Site Assessment (LSA); the impacts were reportedly due
to leaks emanating from a washdown pad and sump area on Site. Assessment and
remedial activities were conducted since 1995 on behalf of the CAC. Based on a review
of NCDEQ’s Laserfiche online database, the Site appears to have been associated with
the NCDEQ Inactive Hazardous Sites Branch (IHSB) since at least 2000.
A source area soil excavation was performed in 2000 to remediate free product TCE
impacts in Site soils. A chlorinated VOC groundwater plume emanating from the former
source area is present on-Site and extends to the west of the Site beneath W.T. Harris
Boulevard. Several intrusive groundwater remedial approaches have been proposed for
the Site, though active remedial methods have not been implemented. This is largely a
result of financial hardships for the CAC. The Site underwent passive remediation, in the
form of Monitored Natural Attenuation (MNA), for 10 years between 2001 and 2011.
During that time, groundwater monitoring was conducted semi-annually; groundwater
monitoring has progressed sporadically since, most recently performed in September
2018. In February 2016, the CAC requested assistance from the NCDEQ in funding the
Site investigation, including to support the continued groundwater investigation and soil
gas assessment. Based upon recent groundwater sampling and nearby receptor data, the
Site was removed from the IHSB Priority List as indicated in a 9 March 2017 NCDEQ
memorandum (Appendix B). Historical environmental assessment and remediation
activities along with historical groundwater sampling results were discussed in more
detail in the May 2018 Work Plan (Geosyntec, 2018a) and the November 2018
Assessment Report (Geosyntec, 2018b).

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3. PROPOSED SUPPLEMENTAL ASSESSMENT
Based on a review of readily available historical Site-related documents and discussions
with the NCDEQ Brownfield’s Project Manager, Geosyntec proposes to perform
supplemental assessments to address data gaps in the Southern and Eastern parcels in
support of obtaining a final Brownfields Agreement.
The proposed scope of work has been developed in consideration of potential reuse of the
Site and seeks to:
1. Establish a baseline for pre-existing contamination at the Site;
2. Assess the Site for additional, potential environmental concerns (i.e. “prove the
negative”); and
3. Facilitate reuse.

Generally, this work is planned to consist of soil gas sampling in NCDEQ-selected
locations to assess for the potential for vapor intrusion into future buildings.

A description of the field methodologies and proposed sampling techniques is presented
in Section 4.

Geosyntec will review the data and provide a report to NCDEQ describing the sampling
completed, a tabular summary of validated data, figures depicting sampling locations, and
copies of raw data collected. The report will include recommendations for additional
assessment and, if needed, mitigation measures to minimize human exposure to
contamination.
The Site is planned for redevelopment in the form of multi-family residential occupancy.
Geosyntec proposes to collect discrete soil gas samples co-located with the tentative
residential building layout to evaluate the potential for VI. Figure 3 overlays the
proposed redevelopment building footprint and approximate boundary of the VOC
groundwater plume (i.e., the inferred extent of groundwater impacts above 2L Standards
as reported in historical reports) along with samples collected in Fall 2018. As indicated
in Figure 3, eight proposed building footprints are located in the Southern and Eastern
parcels. Though there is no historical indication of groundwater impacts in these parcels,
as a conservative measure, this Work Plan proposes the collection of four soil gas samples
at four NCDEQ-selected locations beneath four of the proposed building footprints; one
location in each of Buildings 4, 7, 8, and 11.

GN6502C/20190122 Harris BLVD WP SG Sampling 5 1/22/2019
4. VI ASSESSMENT PROCEDURES
Procedures will generally follow the Operating Procedures as outlined by the U.S.
Environmental Protection Agency (USEPA) Region IV and the NCDEQ IHSB.
Additional media specific procedures are discussed further below. Soil cuttings
generated during assessment activities will be drummed and disposed of in accordance
with characterization data generated as part of analytical testing conducted in October
2018. Collected samples will be submitted to a NELAP-accredited fixed-base laboratory
certified in North Carolina for the chemical analyses listed below. Estimated analytical
concentrations (“J” flagged) will be documented and the laboratory method detection
limits, where practical, will not exceed NCDEQ screening criteria. Level II QA/QC will
be requested. Appropriate chain of custody procedures will be followed upon sample
collection, including proper ice packaging, temperature blanks, custody sealing, etc.
Geosyntec proposes to install soil gas probes (SGPs) at four locations at the Site. One
SGP implant will be installed per sampling location. SGPs will be installed at a minimum
depth of 5 ft bgs and a maximum depth of approximately 2-3 feet above the water table,
as observed in the field during SGP installation activities (the water table is expected to
be encountered at approximately 15 ft bgs based on historical reports). Based on existing
Site conditions, the proposed soil gas samples appear to be located in unpaved areas;
therefore, these will not be “sub-slab” soil gas samples. Current on-Site buildings are
planned to be demolished as part of Site redevelopment; therefore, no sub-slab soil gas
or indoor air samples will be collected.
Installation of Soil Gas Probes

Prior to the installation of the SGPs, underground utilities will be located through
notification to a public utility locating service (North Carolina 811). Final sampling
locations will be modified, if necessary, based on utility locations.
SGP boreholes will be drilled by a North Carolina-licensed driller and will be advanced
using GeoprobeTM soil coring technology. Soil samples will be collected, visually
inspected and classified for lithology.
The following SGP design is prescribed in an effort to minimize the potential for sample
dilution due to leakage from the surface. The SGPs will consist of ¼-inch diameter Nyla-
Flow tubing, fitted with a GeoprobeTM stainless steel soil gas sampling implant (6-inch
screen interval). A sand filter-pack will be placed around the soil gas probe screens, to a
height of 6 inches above the screen. Granular bentonite and water will be placed in two,
3-inch lifts above the filter-packs to form a bridge, and a slurry consisting of powdered

GN6502C/20190122 Harris BLVD WP SG Sampling 6 1/22/2019
bentonite and water will be placed above the bridge to within 1 foot of the ground surface.
The backfill slurry will be placed as the GeoprobeTM casing is withdrawn, to help prevent
collapse of geologic materials and potential compromise of the seals. A brass or stainless-
steel compression fitting and valve will be fitted to the top of the probe. The locations of
each SGP will be measured in the field using a global positioning system (GPS) with sub-
meter accuracy. SGPs will be allowed to equilibrate prior to sampling. General SGP
construction details are presented on Figure 4.
Soil Gas Sampling
A soil gas sampling assembly will be setup as shown in general accordance with Figure
5 and will be performed in accordance with the NCDEQ Division of Waste
Management’s March 2018 Vapor Intrusion Guidance. A peristaltic pump may be
substituted for the “lung box”. Prior to sampling, a “shut-in test” will be conducted to
assess the assembly for air leaks. Upon successful completion of the shut-in test, the
assembly will be purged to remove atmospheric air entrained during installation. Field
screening will be conducted during purging activities prior to sample collection. During
field screening a tracer test will be conducted to verify that a significant amount of
atmospheric air does not enter the sample through the annular seal or associated fittings.
A shroud will be placed around the ground surface of each probe and soil gas sampling
assembly prior to sample collection and a tracer gas (e.g., helium) will be added inside
the shroud during the purging process. The concentration of tracer in the shroud and in
the field screening samples will be recorded with a field meter. If field screening indicates
the tracer exceeds 5% of the concentration in the shroud, fittings will be checked and or
the probe will be resealed / replaced as needed to obtain a sample with appropriate
integrity. Nylaflow tubing will be used during soil gas sampling.
Soil vapor samples will be collected using one-liter batch-certified Summa canisters. The
initial vacuum will be measured before use to confirm leaks have not occurred during
shipping. After sample collection, the residual vacuum will also be measured and
recorded. A minimum vacuum of 5 inches Hg will be targeted. Samples will be collected
by connecting the Summa canister directly to the probe through a 200 milliliter per minute
(maximum flow rate) flow controller connected using Swagelok fittings. Three casing
volumes will be purged and samples will be collected as soon as practicable after purging.
Collected soil gas samples will be analyzed for VOCs by EPA Method TO-15.
Additionally, 10% of the samples will be analyzed as duplicate samples. Soil gas samples
will be screened against the NCDEQ Vapor Intrusion Screening Levels (VISLs) for soil
gas.

GN6502C/20190122 Harris BLVD WP SG Sampling 7 1/22/2019
5. PROPOSED PATH FORWARD
Geosyntec has prepared this Work Plan to present details of planned additional
assessment work related to soil gas sampling in the Southern and Eastern parcels of the
Site to obtain a finalized BFA. Obtaining a BFA is a critical step in facilitating the
planned redevelopment. The work proposed herein is intended to collect data to establish
baseline environmental conditions and support the implementation of potential mitigation
measures (e.g., in the form of VI mitigation for future occupied buildings). The baseline
environmental conditions are essential to realize the liability protections offered under
the NCBP. Based upon information gathered during the course of the assessment work
proposed herein, Geosyntec will make follow-up recommendations in a report to be
submitted to NCDEQ.
The overall objective of this project is to comprehensively redevelop the property to
multi-family residential use. The Charlotte City Council approved rezoning the CAC
property for residential use in a 16 April 2018 meeting. The CAC property is idled and
has been underutilized for many years. The existing industrial buildings on-Site are in
stark contrast to the surrounding community, which has flourished through recent
residential development. The property is located in a predominately residential area and
is ideal for continued residential development in the burgeoning City of Charlotte.
We look forward to your review and approval of this Work Plan and your continued
assistance in pursuing a BFA for the Site.

GN6502C/20190122 Harris BLVD WP SG Sampling 8 1/22/2019
6. REFERENCES
Duke Engineering and Services, Inc. Charlotte Aircraft Corporation Source Area
Remediation Report. Charlotte, North Carolina. July 2000.
Duke Engineering and Services, Inc. Charlotte Aircraft Corporation Groundwater
Corrective Action Plan. Charlotte, North Carolina. November 2000.
Geosyntec Consultants of NC, PC. Work Plan for Brownfields Agreement and
Redevelopment: Groundwater, Soil, and Soil Gas Assessment – Revision 1. Charlotte,
North Carolina. May 2018.
Geosyntec Consultants of NC, PC. Groundwater, Soil, and Soil Gas Assessment Report.
Charlotte, North Craolina. November 2018.

FIGURES
±
Parcel Approved for Brownfields Program
CAC Property Boundary
Site Location
7705 East W.T. Harris BoulevardCharlotte, North Carolina
January 2019 1Figure
Raleigh, NC
Notes:1. USGS National Map provided by ESRI online database.2. CAC indicates Charlotte Aircraft Corporation.3. Parcel boundaries provided by Mecklenburg County.X:\GN6502 Harris Boulevard\GIS\MXD\Additional Soil Gas Sampling\Figure 1 - Site Location.mxd ; 2,000 0 2,0001,000 Feet
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@AEast W.T. Harris BlvdDelta Landing RoadHickory Grove Christian School Residential properties
Residentialproperties
Residential propertiesFormer RunwaySite Layout Map7705 East W.T. Harris BoulevardCharlotte, North Carolina
January 2019
250 0 250125Feet
2Figure
Raleigh, NC
Source Area Excavation
Former Gasoline UST Former Aviation Fuel USTs
Main Office
Sales Office
5
CAC Property Boundary
5
4Approximate Source Area Excavation (Year 2000)
Parcel Approved for Brownfields Program
Approximate Former UST Location
Legend
±
$
Approximate Location of Current and Former AST(s)
Estimated Location of Septic System
Approximate Location of Wooden Storage Racks
Approximate Location of OWS and SumpApproximate Location of Electrical Transformers
Approximate Location of Discarded 55-G Drums
Approximate Location of Filled Areas (berms)
Approximate Location of Solid Waste Bins
$&3 &3&3
#*
#*
Building 23 (drum, OWS, sump)
Current/Former ASTs
Drums
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Approximate Location of Monitoring WellsG
Notes:1. Parcel boundaries and IDs provided by Mecklenburg County.2. Site features and building numbers from historical reports, observations, and interview with Site owner.3. Locations are approximate. 4. Reference 23 July 2000 Source Area Remediation Report. Approximately 140 tons of trichloroethene (TCE)-impacted soil were excavated and thermally treated on-Site.5. Per a 1995 UST Leak Reporting Form. The USTs were removed prior to 1996.6. Building descriptions are in reference to a October 1994 Phase I Environmental Site Assessment performed by T.E. Scott Construction.
Parcel ID 10915107
Parcel ID10915106
Parcel ID 10915110
13
6 8 10
71
15
16
9092
14
12
2122
123
3
5
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41 4447
18
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92 Building Number
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SGP-6
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SGP-7
SGP-8SB-7
SB-4 SB-6SB-5
SB-3
SB-2
SB-1
SB-9SB-8
SB-17
SB-16SB-14
SB-13
SB-12
SGP-3SGP-4
SGP-5
SGP-2SGP-1
SB-15
SB-11
SB-10
MW-6
MW-8
MW-9
MW-1
MW-2 MW-3DMW-4
MW-10
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DMW-2
Source: Esri, DigitalGlobe, GeoEye, Earthstar Geographics, CNES/Airbus DS, USDA, USGS,AEX, Getmapping, Aerogrid, IGN, IGP, swisstopo, and the GIS User Community
Proposed Soil Gas Sampling Locations7705 East W.T. Harris BoulevardCharlotte, North Carolina
January 2019 3Figure
Raleigh, NC
100 0 10050FeetNotes:1. Parcel boundaries provided by Mecklenburg County.2. Approximately 140 tons of TCE-impacted soil were excavated and thermally treated on-Site, as referenced in the 23 July 2000 Source Area Remediation Report.3. Groundwater 2L Standards refer to the Title 15A North Carolina Administrative Code 2LGroundwater Quality Standards, amended in April 2013.4. The "Inferred Extent of VOCs above one or more 2L Standards" contour is based onthe most recent sampling event for each well.5. Per a 1995 UST Leak Reporting Form. The USTs were removed prior to 1996.
±
Legend
Proposed Soil Gas Sampling Location
Soil Gas Sample Location
!>Soil Sample Location
@A Monitoring Well Sample Locations
CAC Property Parcels
Approximate Former UST Location
Estimated Location of Septic System
Approximate Source Area Excavation (Year 2000)
Inferred extent of VOCs above one or more 2L Standards
Proposed Building Footprints
5
2
4
(Optional)

APPENDICES