HomeMy WebLinkAboutBrownfields Assessment Work Plan - Former Clorox Facility (NCBP No. 23009-19-060)_rev. 1
Via Email August 15, 2019 North Carolina Department of Environmental Quality
Division of Waste Management – Brownfields Program
1646 Mail Service Center Raleigh, North Carolina 27699-1646 Attention: Mr. Cody Cannon
Subject: Proposed Scope of Work (revision 1) Brownfields Assessment Activities Former Clorox Facility 800 Gesco Street
Charlotte, Mecklenburg County, North Carolina NC Brownfields Project No. 23009-19-060 H&H Job No. BCP-129
Dear Cody:
1.0 Introduction and Background
On behalf of Beacon Development Company, Hart & Hickman, PC (H&H) has prepared this
proposed scope of work to conduct Brownfields assessment activities at the former Clorox
facility located at 800 Gesco Street in Charlotte, Mecklenburg County, North Carolina (Site). A
Site location map is included as Figure 1. The Site consists of three parcels of land (Parcel
Identification Numbers 07108102, 07107801, and 07107805) that total approximately 4.63 acres.
The western portion of the Site is developed with an approximate 53,000-square foot (sq ft)
industrial building that was constructed in 1952 and expanded in 1968. The building is utilized
by Plyler Paper Stock Company to store, sort, bale, and distribute recyclable (primarily paper)
products.
Based on review of historical records, the existing Site building was utilized by Clorox as a
bleach manufacturing facility from the early 1950s until the late 1980s, when Plyler Paper Stock
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Company began using the building for the current recycling operation. The eastern portion of
the Site consists of a truck/trailer parking lot and undeveloped land. A Site map is included as
Figure 2.
During recent Phase I ESA activities conducted on the Site, H&H identified the following
Recognized Environmental Conditions (RECs):
• In March 1990, two soil borings were advanced adjacent to two petroleum aboveground
storage tanks (ASTs; specific contents not reported), a former 5,000-gallon heating oil
underground storage tank (UST), and a former 2,000-gallon UST (presumed to have
contained heating oil) located adjacent to the northeastern corner of the Site building.
Total Petroleum Hydrocarbons-Diesel Range Organics (TPH-DRO) were detected in a
boring identified as Boring 1 (11 ft) at a concentration of 1,600 mg/kg, which exceeds the
current North Carolina Department of Environmental Quality (DEQ) UST Section Action
Level of 100 mg/kg.
A separate heating oil UST release incident was identified in this area in November 1990;
however, the soil data pertaining to the release did not indicate TPH-DRO in soil above
the DEQ Action Level. The UST release incident received regulatory closure in July
1996. The soil impacts identified in Boring 1 (noted above) do not appear to have been
included in DEQ’s evaluation of the UST release and No Further Action determination,
and may be associated with the two ASTs. H&H identified the presence of TPH-DRO in
soil adjacent to the northeastern portion of the Site building at a concentration above the
DEQ Action Level as a REC.
• H&H reviewed a Combined Preliminary Assessment/Site Inspection (September 2005)
and an Expanded Site Inspection (September 2006) prepared by the DEQ Superfund
Section for the former Clorox facility, which included the Site and off-Site properties
located north of the Site along State Street. According to the report, the former Clorox
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facility operated in the northern portion of the Site building from the early 1950s until the
late 1980s.
No samples were collected on the subject Site during the Preliminary Assessment;
however, several soil samples were collected on the Site during the Expanded Site
Inspection. Soil analytical data indicated the presence of cadmium (3.7 mg/kg) and
mercury (48.09 mg/kg) in sample CLX-009-SS (west side of the building near former rail
spur) at concentrations above the Protection of Groundwater Preliminary Soil
Remediation Goal (PSRG) of 3.0 mg/kg for cadmium and the Residential PSRG of 14
mg/kg for mercury. The polynuclear aromatic hydrocarbon (PAH) benzo(a)anthracene
was detected near northeast exterior corner of the building in samples CLX-009-SS (0.83
mg/kg) and CLX-011-SS (1.1 mg/kg) at concentrations above the Protection of
Groundwater PSRG of 0.35 mg/kg in both samples and equal to the Residential PSRG of
1.1 mg/kg in one of the samples. The PAH benzo(a)pyrene was detected in samples
CLX-009-SS (0.57 mg/kg) and CLX-011-SS (0.73 mg/kg) at concentrations above the
Residential PSRG of 0.11 mg/kg. H&H identified the presence of metals and PAHs at
concentrations above PSRGs in soil near the northeastern corner of the building as a
REC.
• Based on review of Sanborn Maps and interviews with Site contacts, Clorox operated a
mixing room that was used to manufacture bleach in the northwestern portion of the Site
building. The Site owner reported that the room contained multiple ASTs when she
purchased the Site in the late 1980s. During Site reconnaissance, H&H observed an
earthen floor and a sump in the former mixing room. Previous reports indicate that the
bleach manufacturing facility may have included the use of a mercury cell, which
produces chlorine-free sodium hydroxide. H&H identified potential environmental
impacts associated with bleach manufacturing at the Site from the early 1950s to the late
1980s as a REC.
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• In 1990, two soil borings (Boring 1 and Boring 2) were advanced adjacent to a concrete
basin located adjacent to a rail spur along the western portion of the Site. Previous
reports indicate that sodium hydroxide and mercury releases may have occurred from the
concrete basin. Analytical data indicated the presence of mercury in a soil sample
collected from Boring 1 (0.5 ft) at a concentration of 2.8 mg/kg, which exceeds the
protection of groundwater PSRG of 1.0 mg/kg. The measured pH levels in samples
collected from Boring 1 and Boring 2 were 13 (2.5 ft) and 13.5 (0.5 ft), respectively,
which are elevated (i.e., alkaline) compared to typical soil pH levels in the area and may
indicate that a release of sodium hydroxide occurred from the concrete basin. H&H
identified the apparent soil impacts in the area of the former concrete basin as a REC.
• Worth Chemical Corp. (818 Tuckaseegee Road) operated a chemical distribution facility
located approximately 250 ft west and topographically upgradient of the subject Site.
H&H reviewed a Site Assessment Work Plan prepared by Arcadis dated December 13,
2010. According to the report, the facility utilized ASTs and USTs for the storage of
petroleum products, chlorinated solvents, and other hazardous materials. Results of
historical soil and groundwater assessment activities conducted at the facility indicated
the presence of soil and groundwater impacts associated with releases from the petroleum
and chlorinated solvent storage tanks. Based on the documented solvent releases,
proximity of the facility to the Site, and area topography, H&H identified the former
Worth Chemical Corp. facility and associated releases as a REC for the Site.
In February 2019, H&H completed Phase II ESA activities which included soil, groundwater, and
exterior soil gas sampling to evaluate potential environmental risks that may affect Site
redevelopment. A summary of the assessment results is provided below.
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Soil
H&H collected nine soil samples for laboratory analysis to evaluate the potential for soil impacts
at the Site. Samples were collected in areas of previously identified RECs and areas of potential
soil disturbance as part of Site redevelopment.
Laboratory analytical results did not indicate the presence of volatile organic compounds (VOCs)
in soil samples at concentrations above the DEQ PSRGs. PAHs were detected at concentrations
exceeding Protection of Groundwater, Residential, and/or Industrial/Commercial PSRGs in a
shallow sample (0-2 ft) collected in the former bleach mixing room. The PAH benzo(a)pyrene was
also detected above the Protection of Groundwater and Residential PSRG in one sample collected at
7-9 ft bgs adjacent to former heating oil USTs/ASTs.
Arsenic was detected at concentrations above the Residential PSRG in the nine soil samples
collected for laboratory analysis and slightly above the Industrial/Commercial PSRG in one sample.
The detected concentrations of arsenic in the samples collected from the developed portion of the
Site are consistent with arsenic concentrations detected in the background samples. Further, the
detected concentrations are below the average published background concentration for North
Carolina soils. As such, the detected arsenic concentrations appear to be naturally occurring.
Hexavalent chromium was detected at estimated concentrations in samples SB-2 (0-2 ft), SB-3
(0-2 ft), SB-6 (0-2 ft), SB-9 (0-2 ft), and SB-11 (0-2 ft) above the Residential PSRG. The
detected concentrations of hexavalent chromium in the samples collected from the developed
portion of the Site are consistent with hexavalent chromium concentrations detected in
background samples. As such, the hexavalent chromium concentrations are likely representative
of background conditions.
Groundwater
H&H installed and sampled one temporary groundwater monitoring well (TMW-2) located
downgradient of the Site building. Concentrations of benzene and vinyl chloride detected in
TMW-2 exceed the North Carolina 2L Groundwater Standards (2L Standards), but are below
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Residential and Non-Residential Vapor Intrusion Groundwater Screening Levels (GWSLs). No
SVOCs were detected in sample TMW-2 above the laboratory method detection limits, and no
metals were detected in sample TMW-2 at concentrations above the 2L Standards.
Exterior Soil Gas
H&H collected two soil gas samples (SG-1 and SG-2) near the western exterior wall of the former
Clorox facility. VOCs were detected in the exterior soil gas samples at concentrations below the
Residential and Non-Residential SGSLs.
The Site received a letter of eligibility for entry into the DEQ Brownfields Program (Brownfields
Project No. 22039-18-060) on March 26, 2019. The Prospective Developer (PD) plans to
perform extensive interior and exterior renovations of the existing structure for use as an office
building. The eastern portion of the Site will be graded and developed into a parking lot.
On July 8, 2019, a kick-off/data gap meeting was held at the Site with the PD, DEQ Brownfields
Program personnel, Parker Poe (PD’s legal counsel), and H&H to discuss Site history, previous
environmental assessment activities, proposed redevelopment plans, data gaps, and the proposed
schedule for completing the Brownfields Agreement. This work plan describes proposed
assessment activities to address data gaps identified during the kick-off meeting. The proposed
receptor survey and groundwater and vapor intrusion assessment activities are summarized in the
following sections.
2.0 Brownfields Assessment Activities
The proposed assessment activities will be performed in general accordance with DEQ’s Inactive
Hazardous Sites Branch (IHSB) Guidelines for Assessment and Cleanup dated October 2015,
DEQ’s Division of Waste Management (DWM) Vapor Intrusion Guidance dated March 2018,
and most recent versions of the U.S. Environmental Protection Agency Region IV Science and
Ecosystem Support Field Branches Quality System and Technical Procedures guidance.
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Prior to conducting field activities, H&H will contact North Carolina 811, the public utility
locator, to mark subsurface utilities at the Site. H&H will also contract a private utility locator to
mark utilities which may not be identified by the public locator. Additionally, each boring
location will be cleared with a decontaminated stainless-steel hand auger to a depth of
approximately 5 feet (ft) below ground surface (bgs) to further screen the boring locations for the
presence of subsurface utilities.
In accordance with Mecklenburg County regulations, H&H will also obtain a Subsurface
Investigation Permit (SIP) from the Mecklenburg County Land Use and Environmental Services
Agency (LUESA) prior to temporary monitoring well installation and sampling. After
completion of the activities, H&H will upload temporary monitoring well records prepared by a
North Carolina licensed driller in order for LUESA to close the SIP.
2.1 Receptor Survey
H&H will perform a Brownfields receptor survey in accordance with DEQ Brownfields Section
guidance. The receptor survey will include information about land use and zoning in the Site
area. In addition, H&H will conduct a field search for water supply wells, basements, utility
manways and chases, storm sewers, other underground utilities, drains, and surface water within
a 1,500 ft radius of the Site. In addition, H&H will review the Mecklenburg County Well
Information System to identify registered water supply wells in the area and, if warranted,
contact the utility companies for information concerning underground utilities in the immediate
area of the Site. The receptor survey will be completed using the most current version of the
Brownfields Property Receptor Survey form.
2.2 Groundwater Assessment Activities
H&H will direct the drilling contractor to install temporary groundwater monitoring wells
(TMWs) at two locations at the Site to evaluate groundwater conditions. Temporary monitoring
wells BF-TMW-1 and BF-TMW-2 will be installed in the western (upgradient) portion of the
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Site in the locations of previous exterior soil gas samples SG-1 and SG-2, respectively. The
locations of the TMWs are shown on Figure 2.
The TMW borings will be advanced with a track-mounted drill rig capable of utilizing hollow-
stem auger drilling techniques. During drilling, soil cuttings will be collected and logged for
lithologic description and field screened for the presence of staining and elevated organic vapors
using a calibrated PID. The temporary monitoring wells will be constructed of 2-inch diameter
PVC with 15 ft well pre-packed well screen set to bracket the water table and 2-inch diameter
PVC well casing to the ground surface. Additional filter sand will be placed from the bottom of
the borings to approximately 2 ft above the top of the well screens. The temporary wells will be
completed by placing a hydrated bentonite seal from the top of the sand filter pack to the ground
surface.
Once the temporary monitoring wells are installed, the wells will be allowed to equilibrate to
static conditions and a decontaminated electronic water level indicator will be used to measure
the depth to the water table relative to the ground surface in each well. The wells will then be
developed until field parameters have stabilized (pH ± 0.1 SU and conductivity varies no more
than 5%) and turbidity is less than 10 NTUs.
After development, a groundwater sample will be collected utilizing low flow/low stress purging
techniques using a peristaltic pump and dedicated polyethylene tubing. The intake point of the
pump tubing will be placed in the approximate mid-portion of the screened interval of the well
and groundwater will be removed at a rate no greater than 200 milliliters per minute. H&H will
utilize water quality meters to collect measurements of pH, temperature, dissolved oxygen,
oxidation reduction potential, turbidity, and specific conductivity at 3- to 5-minute intervals
during the purging process. Purging will be considered complete when the parameters stabilize
(pH ± 0.1 SU, conductivity varies no more than 5%, and turbidity is less than 10 NTUs).
Once groundwater parameters stabilize, the groundwater samples for VOC analysis will be
collected directly into laboratory supplied sample containers using the “soda straw” method to
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minimize volatile loss through the peristaltic pump head. Samples collected for the remaining
analyses will be collected directly into laboratory supplied sample containers from the dedicated
sample tubing through the peristaltic pump head. The sample containers will be labeled with the
sample identification, date, and requested analysis, and placed in an iced laboratory supplied
cooler. The sample will be delivered to a North Carolina certified laboratory under standard
chain of custody protocols for analysis of VOCs by EPA Method 8260, SVOCs by EPA Method
8270, and Resource Conservation and Recovery Act (RCRA) metals by EPA Method 6020/7470.
The groundwater sample locations will be estimated using a hand-held GPS unit. Following
sampling and surveying activities, the temporary monitoring wells will be properly abandoned
by a licensed well driller and the surfaces will be restored to approximately match pre-drilling
conditions.
2.3 Sub-Slab Vapor Assessment Activities
H&H proposes to collect four sub-slab vapor samples (SSV-1 through SSV-4) inside the current
building to evaluate potential vapor intrusion risk. The proposed sub-slab vapor sample
locations are shown on Figure 2.
H&H will drill through the concrete floor at four permanent sub-slab vapor monitoring points
using a rotary hammer drill and 1½-inch diameter drill bit to advance a pilot hole into the
concrete slab to a depth of approximately 1¾ inches below the surface. A drill guide will then be
placed in the pilot hole, and a 5/8-inch diameter drill bit will be utilized to advance the boring
through the concrete slab. Following concrete borehole advancement, loose concrete cuttings
will be removed from the borings, and a Cox-Colvin Vapor Pin™ (vapor pin) assembly (brass
sampling point and silicone sleeve) will be seated in the borehole using an installation/extraction
tool and hammer. The vapor pin will be installed as a flush-mount sample point capable of being
secured with a stainless-steel cover that screws onto the sampling point and is seated within the
pilot hole annulus.
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Following installation and prior to collection of the sub-slab vapor samples, a leak check will be
conducted by constructing a shroud around each sampling point and flooding the air within the
shroud with helium gas. Helium concentrations inside the shroud will be measured using a
helium gas detector. Using a syringe and three-way valve, the Teflon tubing and surrounding
sand pack will be purged of approximately three volumes. Following purging, a sample will be
collected from the sample tubing outside the shroud and analyzed using the helium gas detector
to ensure that helium concentrations are less than 10% of the helium concentrations in the
shroud.
Following a successful leak check, a laboratory-supplied 6-liter stainless steel Summa sample
canister will be connected to an in-line flow controller with a vacuum gauge. The flow
controller will be connected to the sample tubing using a brass nut and ferrule assembly to form
an air-tight seal. The flow regulator will be pre-set by the laboratory to regulate the vapor intake
rate to 6-liters per hour. Once the sample train is assembled, the intake valve on the canister will
be fully opened to begin collection of the sub-slab vapor sample. Vacuum readings on the
Summa canister will be recorded prior to and following the one-hour sampling period to ensure
adequate sample volume was collected. A vacuum will be maintained within the canisters at the
conclusion of the sampling event.
After sample collection, the Summa canister’s valve will be closed, and the regulator will be
disconnected from the canister. The canisters will be placed in laboratory supplied shipping
containers, properly labeled and shipped under standard chain-of-custody protocols to a qualified
laboratory for analysis of VOCs by EPA Method TO-15. The laboratory will be requested to use
reporting limits that are below DEQ DWM Non-Residential SGSLs.
Following the collection of the sub-slab vapor samples, a stainless-steel cover with be screwed
onto the sampling point to protect the sampling point and to allow future access if future sub-slab
vapor testing is warranted based on the analytical results. Each sample location will be estimated
by measuring from known benchmarks (e.g. doorways, walls, etc.).
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2.4 Quality Assurance/Quality Control Samples
The following samples will be collected for quality assurance/quality control (QA/QC) purposes:
• One duplicate groundwater sample will be collected and analyzed for the same
parameters as the parent sample (i.e., VOCs by EPA Method 8260, SVOCs by EPA
Method 8270, and RCRA metals by EPA Method 6020/7470).
• One trip blank will accompany the groundwater samples submitted for VOC analysis
during sampling and shipment. The trip blank will be analyzed for VOCs by EPA
Method 8260.
• H&H will collect one duplicate sub-slab vapor sample using a “T” sample connection
which will allow for the collection of two soil vapor samples from the same location
simultaneously. The duplicate sub-slab vapor sample will be analyzed for VOCs by EPA
Method TO-15.
Non-dedicated equipment and tools will be decontaminated prior to use at each boring or
sampling location, or following exposure to soil or groundwater.
Laboratory QA/QC procedures will be employed to ensure appropriate sample handling and
analysis and to aid in the review and validation of the analytical data. QA/QC procedures will be
conducted in accordance with the method protocols and will include regular equipment
maintenance, equipment calibrations, and adherence to specific sample custody and data
management procedures. Samples will be analyzed in conjunction with appropriate blanks,
laboratory duplicates, continuing calibration standards, surrogate standards, and matrix spiking
standards in accordance with approved methodologies to monitor both instrument and analyst
performance. Laboratory reporting limits for each analyte will be at or below appropriate
screening criteria, where possible. Additionally, H&H will request that the laboratory include
estimated concentrations for compounds that are detected at levels above the laboratory method
detection limit, but below the laboratory reporting limit (J Flags).
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A copy of the laboratory analytical data report and QA package for each group of samples
submitted to and analyzed by the subcontracted laboratory will be provided in an appendix to the
final report. Laboratory QA data consistent with Level II documentation will be requested for
this project. A copy of the completed chain-of-custody record and shipping receipt will be
appended to the corresponding laboratory analytical report included with the final report.
2.5 Investigation Derived Waste
Investigation derived waste (IDW) generated during the assessment activities will be thin spread
on-Site. However, if significant impacts are suspected, the soil cuttings and/or purge water will
be containerized in 55-gallon drums and staged on-Site pending analytical results of a composite
IDW sample. Based on laboratory analytical results of IDW samples, the drums will be
transported off-Site to a suitable facility for disposal.
2.6 Reporting
Following completion of the assessment activities and receipt of the analytical data, H&H will
document our findings in a Brownfields Assessment Report. The report will include a
description of the sampling activities, a figure depicting sample locations, soil boring and well
construction logs, a discussion of the data in comparison to regulatory screening levels,
laboratory analytical data, and conclusions and recommendations concerning our activities.
We appreciate the opportunity to assist with this project. Should you have any questions or need
additional information please do not hesitate to call us at (704) 586-0007.
Sincerely, Hart & Hickman, PC
Bo Cappleman, PG Due Diligence Manager
Attachments
Table 1
Proposed Sample Locations and Analyses
Former Clorox Facility
800 Gesco Street
Charlotte, North Carolina
DEQ Brownfields Project No. 23009-19-060
H&H Job No. BCP-129
BF-TMW-1 assess groundwater quality upgradient of the site building 10-20 ---8260, 8270,
6020/7470
BF-TMW-2 assess groundwater quality upgradient of the site building 10-20 ---8260, 8270,
6020/7470
SSV-1 assess groundwater quality upgradient of the site building ---TO-15 ---
SSV-2 evaluate vapor intrusion risk at the site ---TO-15 ---
SSV-3 evaluate vapor intrusion risk at the site ---TO-15 ---
SSV-4 evaluate vapor intrusion risk at the site ---TO-15 ---
Notes:
One duplicate sub-slab vapor sample and one duplicate groundwater sample will be collected for the laboratory analyses noted above.
ft bgs = feet below ground surface
Sample Objective
Estimated
Screened Interval
(ft bgs)
Groundwater
Analytical
Methods
Sample ID
Sub-Slab Vapor
Analytical
Methods
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8/5/2019
Table 1
Hart & Hickman, PC
0 2000 4000
APPROXIMATE
SCALE IN FEET
N
U.S.G.S. QUADRANGLE MAP
QUADRANGLE
7.5 MINUTE SERIES (TOPOGRAPHIC)
SITE MAP: CHARLOTTE EAST, NC 1991
TITLE
PROJECT
SITE LOCATION MAP
FORMER CLOROX FACILITY
800 GESCO STREET
CHARLOTTE, NORTH CAROLINA
DATE:
JOB NO:
REVISION NO:
FIGURE:
6-28-19 0
1BCP-129
SITE
POWERLINE
RIGHT-OF-WAY
HYDRAULIC
BALER
SORTING AREA
FORMER CLOROX
MIXING ROOM
FORMER HEATING
OIL UST/AST
TRUCK & TRAILER
PARKING
VACANT LAND
(724 GESCO STREET)GESCO STREET
STATE STREET
VACANT
LAND
SOUTHERN CONCRETE
MATERIALS
(715 STATE STREET)
VACANT INDUSTRIAL
BUILDING
(FORMER WORTH CHEMICAL)
(818 TUCKASEEGEE ROAD)
TUCKASEEGEE ROAD
JAY STREETGELBACH DESIGNS INC.
(808 TUCKASEEGEE ROAD)
ACTION GRAPHICS
(720 TUCKASEEGEE ROAD)
CUSTOM POLYMERS
(700 TUCKASEEGEE ROAD)
PLYLER PAPER STOCK
COMPANY
(800 GESCO STREET)
REVISION NO. 0
JOB NO. BCP-129
DATE: 8-6-19
FIGURE NO. 2
FORMER CLOROX FACILITY
800 GESCO STREET
CHARLOTTE, NORTH CAROLINA
PROPOSED SAMPLE LOCATION MAP
LEGEND
SITE PROPERTY BOUNDARY
STEWART CREEK
FORMER RAIL SPURS
PROPOSED TEMPORARY
MONITORING WELL
PROPOSED PERMANENT SUB-
SLAB SOIL VAPOR POINT
2923 South Tryon Street-Suite 100
Charlotte, North Carolina 28203
704-586-0007(p) 704-586-0373(f)
License # C-1269 / #C-245 Geology
SSV-1
SSV-2
SSV-4
SSV-3
BF-TMW-2
BF-TMW-1
S:\AAA-Master Projects\Beacon Partners- BEP or BCP\BCP-129 Gesco Street\Brownfields Assessment\Figures\Phase II Figures_Revised.dwg, FIG 2, 8/6/2019 11:31:07 PM, erichardsonCITY OF CHARLOTTE MAINTENANCE FACILITY
(701 TUCKASEEGEE ROAD)