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Home My WebLink About22001 S Graham Tower Final Work Plan 20180910 S&ME, Inc. | 9751 Southern Pine Boulevard | Charlotte, NC 28273 | p 704.523.4726 | www.smeinc.com September 10, 2018 North Carolina Department of Environmental Quality Division of Waste Management, Brownfields Program 217 West Jones Street Raleigh, North Carolina 27605 Attention: Mr. William Schmithorst, P.G. Reference: Work Plan for Additional Environmental Assessment- Revision 1 401 South Graham Tower 401 S. Graham Street Charlotte, Mecklenburg County, North Carolina NCDEQ, Brownfields Project No.: 22001-18-060 S&ME Project No.: 4335-17-154B Dear Mr. Schmithorst: S&ME, Inc. (S&ME) on behalf of our client, Dominion Realty Partners, LLC (DRP), is submitting this Revised Work Plan to conduct additional assessment activities at the above referenced site. This work plan is prepared based on the Letter of Eligibility (LOE) dated February 2, 2018, and a meeting between Mr. William Schmithorst of the North Carolina Department of Environmental Quality, Brownfields Program (NCDEQ, Brownfields); Mr. Robert “Beau” McIntosh and Mr. Mike Reardon of DRP; and Mr. Roger Smith and Mr. Travis O’Quinn of S&ME on July 31, 2018. This Work Plan is also submitted as a revision to an August 31, 2018 Work Plan prepared and submitted by S&ME. The revisions are in accordance with the comments requested by Mr. Schmithorst within a September 7, 2018 email which conditionally approved the Work Plan, provided the comments were incorporated. The additional assessment activities in this work plan is specifically related to the collection and laboratory analysis of soil samples in the areas of the site where excavation and offsite disposal is anticipated. Additionally, this work plan is also prepared to address the collection and laboratory analysis of soil gas samples below the proposed structure. In order to meet the current construction schedule for the site, and based on the above referenced conversations and emails, the field sampling activities associated with the assessment activities discussed below are currently planned to begin one week following the approval of this Work Plan.  Site Description The subject property consist of one Mecklenburg County parcel (parcel ID number: 07312404), which is approximately 0.673 acres and currently consists of an asphalt and gravel covered parking lot. According to the Mecklenburg County GIS Department’s website, the parcel currently owned by 401 South Graham Street LLC. DRP is proposing to redevelop the site as a vertical, mixed-use 29-story tower. A Site Location Map is provided on USGS Topographic Map as Figure 1 and a Site Aerial is provided as Figure 2. Work Plan for Additional Environmental Assessment- Revision 1 401 South Graham Tower Charlotte, Mecklenburg County, North Carolina S&ME Project No.: 4335-17-154A NCDEQ, Brownfields Project No.: 22001-18-060 September 10, 2018 2  Background As part of due diligence activities related to the potential purchase and redevelopment of referenced site, DRP contracted with ECS Southeast, LLP (ECS) to prepare a Phase I Environmental Site Assessment, MLK & Graham Tower (Phase I ESA), dated September 12, 2017, which DRP provided to S&ME. Based on the Phase I ESA report, the following recognized environmental conditions (RECs) were identified by ECS:  “… the historic presence of a “cold storage” building on the south adjoining property identified in the Sanborn Map review with no historic information of potential chemicals used (including ammonia, glycols, Freon, etc.) and/or disposal to be a REC of the subject property.”;  “… the potential for an undocumented release from the historic south adjoining and southeast adjoining auto repair facilities identified in the Sanborn Map review to be a REC of the subject property.”; and  “… the groundwater contamination above the North Carolina 2L Groundwater Quality Standards (2L Standards) at the south adjoining Parking Lot at Mint and 2nd Streets to be a REC of the subject property”. Following review of the Phase I ESA, DPR contracted S&ME to prepare a Limited Phase II Environmental Site Assessment, MLK and Graham Tower (Phase II ESA), dated November 3, 2017 (S&ME Project No. 4335-17-154). The results of the Limited Phase II ESA, identified volatile organic compounds (VOCs) with concentrations of chlorinated solvents (tetrachloroethene or PCE, trichloroethene or TCE, and 1,2-dichloroethane or 1,2-DCA) detected greater than their respective 2L Standards. Additionally, the concentrations of PCE and TCE also are greater than the residential vapor intrusion (VI) screening level, with PCE concentrations in two locations also identified exceeding the non-residential VI screening level. Although the source of the groundwater impacts cannot be positively identified, it is possible that some or all of the contaminants detected in the site groundwater may be from one or more of the RECs identified in the Phase I ESA, or potentially from another source. Following the identification of groundwater impacts from the Limited Phase II ESA, DRP elected to pursue a Brownfields Agreement for the site. DRP contracted S&ME to assist their environmental attorney, Mr. Stephen Earp of Smith Moore Leatherwood, LLP with the preparation and submittal of the Brownfields Property Application (BPA). The BPA (S&ME Project No. 4335-17-154A) was submitted to the NCDEQ, Brownfields on January 5, 2018. On February 2, 2018, the NCDEQ, Brownfields sent a Letter of Eligibility (LOE) for the site, which stated “NCDEQ has determined that this project is eligible for entry into the North Carolina Brownfields Program (NCBP) and for continued evaluation for a Brownfields Agreement (BFA).” It is S&ME’s understanding that after the receipt of the LOE, DRP elected to participate in the Redevelop Now (RN) option within the Brownfields Program in order to expedite the BFA for redevelopment purposes. On August 12, 2018, DRP received a Letter of Eligibility from the NCDEQ stating that the necessary documents were received and the site was eligible to participate in the Redevelop Now program within the NCBP. In order to expedite the BFA process, on July 31, 2018, Mssrs. Roger Smith and Travis O’Quinn of S&ME, along with Mssrs. Beau McIntosh and Mike Reardon of DRP met with the NCDEQ, Brownfields project manager, Mr. Bill Schmithorst. During the meeting, S&ME and DRP discussed the proposed site development and reviewed the environmental activities, data, and results collected at the site. After reviewing, Mr. Schmithorst stated that the NCDEQ, Brownfields was requesting the following additional activities be conducted in preparation of the BFA: Work Plan for Additional Environmental Assessment- Revision 1 401 South Graham Tower Charlotte, Mecklenburg County, North Carolina S&ME Project No.: 4335-17-154A NCDEQ, Brownfields Project No.: 22001-18-060 September 10, 2018 3  Collection and laboratory analysis of soil samples in areas of the proposed excavation activities where the soils will be transported off-site for disposal;  Collection and laboratory analysis of soil gas samples in areas of the proposed structure with human occupancy (i.e., not in proposed parking or drive areas of the site); This Work Plans includes the soil and soil gas sampling requested above.  Work Plan for Additional Assessment In order to further assess the soils and soil gas at the site prior to the NCDEQ required Environmental Management Plan (EMP) and BFA for the site, additional assessment of the soils and soil gas are required. Therefore, S&ME proposes to conduct the following assessment activities. Task 1: Project Management, Health and Safety Plan, and Coordination: Prior to mobilizing to the site to conduct the proposed sampling, S&ME will conduct the following:  Amend/update the previously prepared health and safety plan to comply with currently proposed site activities, in accordance with 29 CFR 1910.120 as required by OSHA;  Coordinate with NC One Call for underground utility locating;  Coordinate with a NC licensed driller for the proposed soil borings and groundwater collection/abandonments;  Coordinate with a North Carolina certified laboratory for the proposed soil and soil gas analyses with Level 2 Quality Assurance/Quality Control (QA/QC) data package. The laboratory selected will be contacted prior to sampling to confirm that reporting limits will be below the applicable NCDEQ media standards and screening levels; and  The proposed assessment activities will be performed in general accordance with the NCDEQ Inactive Hazardous Sites Branch (IHSB) Guidelines for Assessment and Cleanup (Guidelines) dated October 2015, the DEQ Division of Waste Management (DWM) Vapor Intrusion Guidance (VI Guidance) dated March 2018. Task 2: Soil Sampling In order to assess the soils for evidence of impacts and disposal purposes, S&ME proposes to conduct up to eight soil borings in the vicinity of the proposed structure footprint and collect eight soil samples for laboratory analysis. The field activities for the installation of the soil borings and soil sample collection will be generally conducted as follows:  Soil borings will be conducted using a direct push (Geoprobe®) type drilling rig by advancing a macro- core sampler equipped with a new/clean inner clear acetate liner for every four to five foot depth intervals. Work Plan for Additional Environmental Assessment- Revision 1 401 South Graham Tower Charlotte, Mecklenburg County, North Carolina S&ME Project No.: 4335-17-154A NCDEQ, Brownfields Project No.: 22001-18-060 September 10, 2018 4  Soils will be collected continuously from the ground surface to a maximum depth of 17 feet below ground surface (ft bgs).  Upon retrieval of the macro-core sampler, the acetate liner will be removed and opened, and the depths and description of soils will be noted on a bore log.  The soils will be removed and field screened for evidence of apparent impacts such as indications of staining, odors, etc. and also be screened for organic vapors using a photo ionization detector (PID).  The macro-core sampling drill rods will be decontaminated between sampling by removing solids/soils from rods, rinsing with water, scrub the rods using a nylon brush and a mixture of Alconox® or Liquinox® and water, and then rinsed with deionized water.  A total of eight soil borings (B-1 through B-8) will be conducted across the site at locations where excavations for site soil removal are currently planned for the installation of deeper foundations, pile caps, elevator pits, etc. of varying depths within the proposed building footprint. The boring locations were also located as to be representative of site soils across the site. See Figure 3 for proposed boring locations.  The soil sample intervals selected for laboratory analysis will be based on the results of the field screening findings and depth of the proposed excavations. However, below is a table indicating the anticipated depth of each boring and proposed sampling interval of each. Should elevated PID readings be detected, an additional soil sample will also be collected at a depth just below the proposed excavation. Boring ID Planned Excavation Depth (ft. below present grade) Proposed Boring Depth (ft. below present grade) Estimated Sample Depth (ft. below present grade) B-1 12.5 12 8 – 12 B-2 8.33 8 2 – 6 B-3 17.0 17 12 – 16 B-4 16.0 16 8 – 12 B-5 15.0 15 10 - 14 B-6 11.0 11 2 - 6 B-7 17.5 17 12 – 16 B-8 12.0 12 8 – 12  Since the estimated volume of soils to be removed from the site is stated to be approximately 7,000 cubic yards (yds3), a total of eight soil samples (one sample per every approximate 1,000 yds3 + one extra) are anticipated to be collected and submitted to the laboratory for analysis. The samples selected for laboratory analysis will be selected as to represent depth intervals within the expected excavated soils across the site.  One additional soil sample will be collected as a “Duplicate” sample of one of the eight above listed samples to be used for QA/QC purposes.  All soil samples submitted to the laboratory will be appropriately labeled, placed on ice within a secured cooler and delivered to the laboratory under standard chain-of-custody protocols for analysis of VOCs via EPA Method 8260/5035; Semi-Volatile Organic Compounds (SVOCs) via EPA Method 8270; total RCRA Metals using 6010 series/7471 Methods, hexavalent chromium using EPA Method 7196A, and oil and grease using EPA Method 9071 with silica gel clean up. The laboratory will report detection limits to Work Plan for Additional Environmental Assessment- Revision 1 401 South Graham Tower Charlotte, Mecklenburg County, North Carolina S&ME Project No.: 4335-17-154A NCDEQ, Brownfields Project No.: 22001-18-060 September 10, 2018 5 NCDEQ residential preliminary soil remedial goals (PSRGs) where possible and also report estimated concentrations that are greater than the laboratory detection limits, typically listed as “J flags”. Each soil boring will be located using a handheld GPS capable of sub-meter accuracy in an effort to accurately represent those location depicted on Figure 3. However, based on potential site access restrictions, refusal, etc., the final locations may vary from those proposed. Following completion of soil sampling activities the borings will be abandoned by filling with the remaining soils removed during advancement or bentonite to the ground surface. Background Metals Since metals are naturally occurring in soils, additional samples would typically also be collected to assess the perceived naturally occurring metals concentrations for the site will be collected. However, due to the small extent of the site property and the lack of undeveloped or “untouched natural area” of the site, no background samples are proposed for collection. Task 3: Soil Gas Sampling S&ME will use a track-mounted Geoprobe® drill rig with direct push technology to install two soil gas implants (SGIs) for the collection of soil gas samples (SG1 and SG2). The SGIs will be installed at the locations within the footprint of the proposed structure where human occupancy is anticipated, with SG-1 located within the proposed commercial and residential areas and GS-2 located within the area of the proposed elevator pits. S&ME will install the SGIs to a depth of approximately 6 ft-bgs. See Figure 3 for proposed soil gas sampling locations. Once the depth of the SGIs have been selected, the SGIs will be installed as follows: Using the Macro-Core® sampler or 1-inch direct push rods, the SGI sampling tool will be installed in general conformance with Geoprobe’s “Implants Operation” manual. After advancing the boring to depth, a six-inch stainless-steel screen point fitted with ¼-inch diameter Teflon® tubing will be installed within each borehole. Filter sand will be placed from the base of the boring to approximately 6-inches above the screen. The sampling points will be completed by placing hydrated bentonite from the top of the filter sand to the ground surface. Following installation, S&ME will perform a leak test by attaching a brass T-connector to the end of Teflon tubing and connecting a section of Teflon tubing to one part of the T-connector and an additional section of Teflon tubing to a batch-certified one liter summa canister. A plastic shroud will be placed over top of the SGI tubing array and summa canister. The additional section of tubing from the T-connector will be fitted through the shroud and attached to a helium detector. S&ME will then inject helium (tracer) gas into the plastic shroud. Vapor from the sampling array will be purged and sampled outside of the shroud into a Tedlar® bag and screened using the helium gas detector. The sampling array will be considered as passing the leak test, if the tracer gas is detected at a concentrations less than 10% of the concentration measured with the shroud. If leaks are detected, the sampling array will be re-constructed and re-tested for leaks. Work Plan for Additional Environmental Assessment- Revision 1 401 South Graham Tower Charlotte, Mecklenburg County, North Carolina S&ME Project No.: 4335-17-154A NCDEQ, Brownfields Project No.: 22001-18-060 September 10, 2018 6 After successfully passing the leak test, the leak detection shroud will be removed and three volumes of air will be purged from the SGI sampling array using a calibrated low flow pump (similar to a personal air monitoring pump) at a rate of approximately 200 milliliters per minute. After purging the sampling array, the valve to the one-liter summa canister will be opened to allow the collection of a soil gas sample. The sample collection rate will be set with a one-hour regulator. Once the soil gas samples are collected, the samples will be shipped under standard chain-of-custody protocol to a North Carolina certified laboratory for analysis. The samples will be analyzed for VOCs by EPA Method TO-15. The laboratory will report detection limits to the NCDEQ Residential Vapor Intrusion Screening Levels (VISLs) dated February 2018 where possible and report concentrations greater than the laboratory detection limits (J flags). For Quality Assurance/Quality Control (QA/QC) purposes, one co-located (duplicate) sample will be collected during the sampling event. The QA/QC sample will be analyzed for the same constituents as the record samples. After the soil gas samples are collected, S&ME will remove the SGI tubing to approximately one foot below the top of the ground surface, and will fill the top of the boring with soil (note: the bore hole is filled with hydrated Bentonite clay mix). All disturbed surface material (soil, asphalt, grass) will be restored to the condition it was prior to the subsurface probe/drilling. The location of the soil gas probes will be recorded with a mapping grade sub-meter GPS unit. Task 4: Reporting Upon receipt of all final laboratory analysis, the activities, findings, and results will be summarized in a letter report and submitted to the NCDEQ, Brownfields. The soil sample detections will be compared to the NCDEQ Preliminary Soil Remedial Goals for Residential Health and Protection to Groundwater. The soil gas sample detections will be compared to the NCDEQ Residential Vapor Intrusion Screening Levels guidance.  Assumptions The scope and schedule are based on the following assumptions:  S&ME will have free access to the site. However, since the site is currently in use as a parking area, it is estimated that the field work will be conducted during a weekend.  A Geoprobe® drill rig will be sufficient to conduct the soil borings for soil and soil gas sample collection, and refusal will not be encountered.  Groundwater will not be encountered in the borings.  Schedule As previously stated, in order to meet the current construction schedule for the Site, and based on the referenced conversations and emails, the field sampling activities associated with the assessment activities discussed above Attachments Attachment I – Figures ^_ ^_Project Location SCALE: DATE: PROJECT NUMBER FIGURE NO. 11 " = 2,000 ' 8-21-18 4335-17-154B GRAHAM TOWER SITE401 S. GRAHAM STREETCHARLOTTE, MECKLENBURG COUNTY, NORTH CAROLINADrawing Path: Q:\4335\17\154 Graham and MLK Tower\1_vicinityB.mxd plotted by DHomans 08-30-20180 2,000 4,000(FEET) SITE LOCATION MAP ³ REFERENCE: USGS USA TOPO STREAMING DATASETGIS BASE LAYERS WERE OBTAINED FROM THE NATIONAL MAP. THIS MAP IS FORINFORMATIONAL PURPOSES ONLY. ALL FEATURE LOCATIONS DISPLAYED ARE APPROXIMATED.THEY ARE NOT BASED ON CIVIL SURVEY INFORMATION, UNLESS STATED OTHERWISE. Service Layer Credits: USGS The National Map: NationalBoundaries Dataset, National Elevation Dataset,Geographic Names Information System, National W MartinLutherKingJrBv W M artinLutherKingJrBvS Graham StS Graham StS Mint StProposed Occupied Area Project Parcel SCALE: DATE: PROJECT NUMBER FIGURE NO. 21 " = 100 ' 8-27-18 4335-17-154B GRAHAM TOWER SITE401 S. GRAHAM STREETCHARLOTTE, MECKLENBURG COUNTY, NORTH CAROLINADrawing Path: Q:\4335\17\154 Graham and MLK Tower\2_siteaerial.mxd plotted by DHomans 08-27-20180 100 200(FEET) SITE AERIAL ³ REFERENCE: 2017 AERIAL PHOTOGRAPHGIS BASE LAYERS WERE OBTAINED FROM MECKLENBURG COUNTY GIS. THIS MAP IS FORINFORMATIONAL PURPOSES ONLY. ALL FEATURE LOCATIONS DISPLAYED ARE APPROXIMATED.THEY ARE NOT BASED ON CIVIL SURVEY INFORMATION, UNLESS STATED OTHERWISE. Service Layer Credits: meckco !´Ð!´Ð!´ÐÐ"IÐ"IÐ!GÐ!GÐ!GÐ!GÐ!GÐ!GÐ!GÐ!GS Graham StW Martin Luther King Jr Bv TW-1 TW-2 TW-3 SG-1 SG-2 B-7 B-6 B-8 B-4 B-3 B-2 B-1 B-5 Ð"I Proposed Soil Gas Sample Locations Ð!G Proposed Soil Sample Locatons !´Ð Historic Groundwater Sample Lcoations Proposed Occupied Area SCALE: DATE: PROJECT NUMBER FIGURE NO. 31 " = 30 ' 8-30-18 4335-17-154B GRAHAM TOWER SITE401 S. GRAHAM STREETCHARLOTTE, MECKLENBURG COUNTY, NORTH CAROLINADrawing Path: Q:\4335\17\154 Graham and MLK Tower\3_samplelocations.mxd plotted by DHomans 08-30-20180 30 60(FEET) PROPOSED SAMPLE LOCATION MAP ³REFERENCE: 2017 AERIAL PHOTOGRAPHGIS BASE LAYERS WERE OBTAINED FROM MECKLENBURG COUNTY GIS. GROUND LEVEL FLOORPLAN OBTAINED FROM RULE JOY TRAMMELL RUBIO, DATED JULY 27, 2018. THIS MAP IS FORINFORMATIONAL PURPOSES ONLY. ALL FEATURE LOCATIONS DISPLAYED ARE APPROXIMATED.THEY ARE NOT BASED ON CIVIL SURVEY INFORMATION, UNLESS STATED OTHERWISE. Service Layer Credits: