23037_ElanIndianTrail_Work Plan_Rev1 9-18-19

TABLE OF CONTENTS

A. SITE INFORMATION ..................................................................................................... 1
B. INTRODUCTION ............................................................................................................. 2
C. SCOPE OF WORK .......................................................................................................... 2
D. SAMPLING METHODOLGY ............................................................................................ 4
E LABORATORY ANALYSES ............................................................................................ 5
F. QUALITY ASSURANCE/QUALITY CONTROL ................................................................ 5
G. INVESTIGATIVE DERIVED WASTE MANAGMENT ....................................................... 6
H. REPORTING ................................................................................................................... 6

FIGURES
Figure 1: Site Location Map
Figure 2: Proposed Sampling Locations

TABLE

Table 1: Sample Location and Analyses

APPENDIX

Appendix A: NCDEQ Correspondence

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A. SITE INFORMATION
 Site Name: Elan Indian Trail
 Location: SE Intersection of Chestnut Parkway and W US
Highway 74
Indian Trail, Union County, NC
 Land Use: Former Residential/Undeveloped
 Property Owner: Parcel 07105005D:
Snyder Janice Bivens Lemmond Heirs et al
324 Bubbling Well Road
Matthews, North Carolina 28105

Parcel 07105004:
Kay Lemmond Trustee
844 Cherokee Road
Charlotte, North Carolina 28207

 Prospective Developer: Greystar GP II, LLC
465 Meeting Street
Suite 500
Charleston, South Carolina 29403

 Consultant: Resolve Environmental Services, PLLC (Resolve)
500 Devonport Drive
Matthews, North Carolina 28104
[phone]

 Latitude: 35.084307° North
 Longitude: 80.663714° West

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B. INTRODUCTION
The subject site consists of two (2) contiguous tracts totaling 31.68 acres identified as Union
County Parcel ID 07105004 (21.6-acres) and 07105005D (10.08-acres). The site is located at
the intersection of Chestnut Parkway and W US Highway 74 in Indian Trail, Union County, North
Carolina (Figure 1).

Resolve Environmental Services, PLLC (Resolve) conducted a Phase I Environmental Site
Assessment (ESA) at the site in May 2019. Based upon the historical information obtained and
reviewed, the property was used as farmland with a residence dating back to at least 1938. The
residence was removed circa 1988 and the farm was no longer in operation. Roadside
businesses operated on a small portion of the property along the eastern property boundary
(along Highway 74) in recent decades. Today the property is heavily wooded and the small area
along the eastern property boundary is being utilized by the NCDOT to store roadway supplies
for a US Highway 74 road improvement project. The surrounding area was primarily farmland
and low-density residential through the 1950’s. However, commercial development began as
early as the 1960’s upon the development of Highway 74. The surrounding area remains a mixed
use of commercial and residential areas.

No RECs were identified at the subject site. One PEC, identified as leaking underground storage
tank (LUST) site “Catawba Food Mart #4”, is located on the adjoining property to the
east/southeast. Confirmed ground water contamination, including concentrations of benzene
exceeding the North Carolina Department of Environmental Quality’s (NCDEQ) Gross
Contamination Level (GCL), have been detected at the site as recent as 2017. Ground water flow
is toward the subject site. The LUST was accepted into the UST State Lead Program, active
corrective action is intended to be conducted at the property.
On July 26, 2019 the site was granted eligibility into the NCDEQ’s Brownfields program and
identified as Brownfields Project 23037-19-090. On August 20, 2019, a site meeting was
conducted with representatives from the NCDEQ Brownfields Program, Greystar GP II, LLC,
Parker Poe and Resolve. The purpose of this meeting was to determine the scope of assessment
required at the proposed Elan Indian Trail development prior to preparing a Brownfields
Agreement for the site. Based upon the meeting, surface water, ground water and soil sampling
activities were proposed.
C. SCOPE OF WORK
The following work scope is based upon the NCDEQ’s Additional Assessment Request dated
August 22, 2019. The request detailed the number and type of sampling points requested for the
additional assessment. The referenced correspondence is attached as Appendix A. A Site
Specific Health and Safety Plan will be prepared by Resolve in accordance with 29 CFR 1910.120
(HAZWOPER). All on-site Resolve personnel will be current with HAZWOPER training. The
Health and Safety Plan will be present on site during all field activities. The scope of work for the
additional assessment is detailed below.
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1. Subsequent to obtaining an property access agreement and associated North Carolina
Well Installation Permit from the NCDEQ (if required), Resolve will supervise the
installation of three (3) shallow and one (1) deep North Carolina Type II monitoring wells
at the site. Two (2) shallow and (1) deep Type II monitoring wells will be installed along
the eastern property boundary of parcel 07105004 to determine if the site has been
affected by petroleum contaminants from the adjacent former Catawba Food Mart #4
LUST release (currently Walgreens). One (1) Type II well will be installed in the north
central portion of parcel 07105005D as a background well and to triangulate ground water
flow direction across both parcels. The three (3) shallow Type II monitoring wells will be
completed to depths immediately below the first water bearing fracture encountered in the
underlying meta-argillite. Resolve estimates that these wells will each be completed to a
total depth of 25 feet below grade surface (BGS). The wells will be screened to bracket
the water bearing fracture(s). The deeper Type II well will be completed into bedrock to a
depth of 45 feet BGS. The monitoring wells will be installed by a North Carolina licensed
well driller using auger and/or air drilling techniques. The wells will be installed and
developed in accordance with the North Carolina well drilling standards specified in NCAC
T15A 2C and the US EPA Region 4 Science and Ecosystem Support Division Guidance.
Well development will be conducted by removing a minimum of 5 well volumes. Well
development will be considered complete when the water column in the well is free of
visible sediment, and measurements of temperature, pH, specific conductivity and turbidity
have stabilized .
2. Collect ground water samples from each of the newly installed monitoring wells using low
flow sampling techniques (e.g. variable speed pump, peristaltic pump) to reduce sample
turbidity. The four (4) collected ground water samples will be submitted to a NC certified
laboratory for analyses for volatile organic compounds (VOCs) by SW-846 Method 8260,
for semi-volatile compounds by SW-846 Method 8270 and for 8 RCRA Metals by EPA
Method 6020.
3. Collect two (2) surface water and two (2) streambed sediment samples from the onsite
stream near the influent and effluent stream boundaries on the property. The collected
surface water and sediment samples will be analyzed for VOCs by Method 8260, for
SVOCs by SW-846 Method 8270 and RCRA metals by EPA Method 6020. In addition,
one aliquot from each collected sediment sample will be submitted for laboratory hold and
possible analyses of hexavalent chromium by EPA Method 7199 depending on chromium
concentration results from the RCRA Metals analysis.

4. Collect seven (7) soil samples at various locations on the property including adjacent to
the two (2) existing buildings located at the northeastern portion of the site. The samples
will be collected from soil borings with a sampling interval of 0-2 feet BGS. The borings
will be advanced using a hand auger. The collected soil samples will be analyzed for VOCs
and SVOCs by SW-846 Methods 8260 and 8270, respectively, and for RCRA metals by
EPA Method 6020. In addition, one aliquot from each collected soil sample will be
submitted for laboratory hold and possible analyses of hexavalent chromium by EPA
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Method 7199 depending on chromium concentration results from the RCRA Metals
analysis.

5. Collect three (3) soils samples from along the powerline easement traversing the property
in a southeast/northwest strike. The samples will be collected from soil borings with a
sampling interval of 0-2 feet BGS. The borings will be advanced using a hand auger. The
collected soil samples will be analyzed for organophosphorus pesticides (OPPs) by SW-
846 Method 8141B, organochlorine pesticides (OCPs) by SW-846 Method 8081B for
RCRA metals by EPA Method 6020. In addition, one aliquot from each collected soil
sample will be submitted for laboratory hold and possible analyses of hexavalent
chromium by EPA Method 7199 depending on chromium concentration results from the
RCRA Metals analysis.

6. A receptor survey, covering a 1,500-foot radius from the property boundary of the subject
site (unless otherwise indicated by the NCDEQ Brownfields project manager), will be
conducted, noting property use(s), proposed use(s), construction details of onsite
structures, surrounding property land use, onsite utilities, nearby water supply information
and surface water and wetlands information, etc. A Brownfields Property Receptor Survey
form will be completed and included in the final report.

D. SAMPLING METHODOLGY
Samples will be collected and analyzed in accordance with the NCDEQ, Division of Waste
Management, Inactive Hazardous Sites Program “Guidelines for Assessment and Cleanup”
(October, 2015) and the US EPA Region 4 Science and Ecosystem Support Division Guidance.

Soil Sampling: Soil borings will each be initially advanced to a total depth of 2 feet BGS using a
hand auger. A soil sample will be collected from the 0-2 feet interval in each boring. Soils will be
screened using a photoionization detector (PID). If suspected impacts are observed at or near
the boring terminus (visual, olfactory, or PID), samples will also be collected from deeper intervals
as warranted up to a maximum depth of 5 feet BGS. The aliquot of soil retained for laboratory
analyses will not be the same one used for field screening.

Ground Water Sampling: Subsequent to well development, the newly installed monitoring wells
at the site will be gauged, purged and sampled using low flow sampling techniques with the
appropriate type of pump for the depth to water in each well (e.g. peristatic, variable speed). The
appropriate pump with new tubing will be used to purge and sample each of the site wells. Field
parameters (dissolved oxygen, pH, conductivity, temperature and turbidity) will be measured and
once readings become stable, a ground water sample will be collected. Stabilization will be
defined as three consecutive readings where temperature is within ± 10%, pH is within ± 0.1 SU,
and conductivity is ± 5%. Although not a requirement, efforts will be made to achieve
measurements of <10 NTU turbidity prior to collecting samples. If readings do not stabilize in the
monitoring wells, the wells will be redeveloped prior to repurging and sampling.
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Surface Water Sampling: Influent and effluent stream samples will be collected using a new,
disposable bailer at each sampling location.
Streambed Sediment Sampling: Sediment samples will be collected from the streambed at a
sample interval of 0-1 feet BGS using hand augers.

E. LABORATORY ANALYSES
All samples will be collected and immediately placed into laboratory-supplied glassware, placed
on ice and transported to a North Carolina certified laboratory for analyses. The laboratory will
conduct the analyses using Level II QA/QC with method detection limits at or below the applicable
NCDEQ reporting requirements.
1. Soil and sediment samples will be analyzed for VOCs by SW-846 Method 8260, SVOCs
by SW-846 Method 8270, RCRA Metals by EPA Method 6010 and/or OPPs by SW-846
Method 8141B and OCPs by SW-846 Method 8081B. In addition, one aliquot from each
collected sediment and soil will be submitted for laboratory hold and possible analyses of
hexavalent chromium by EPA Method 7199 depending on chromium concentration results
from the RCRA Metals analysis.

2. Collected ground water and surface water samples will be analyzed for VOCs by SW-846
Method 8260, for SVOCs by SW-846 Method 8270 and for 8 RCRA Metals by EPA Method
6020.

3. Duplicates and Trip Blanks
One (1) duplicate sample from each of the soil, surface water, sediment and ground water
samples will be analyzed for VOCs by SW-846 Method 8260, for SVOCs by SW-846
Method 8270 and for 8 RCRA Metals by EPA Method 6020. One duplicate soil sample will
be analyzed for RCRA Metals by EPA Method 6010, OPPs by SW-846 Method 8141B
and OCPs by SW-846 Method 8081B. One trip blank will be analyzed for VOCs by SW-
846 Method 8260 and for SVOCs by SW-846 Method 8270.
F. QUALITY ASSURANCE/QUALITY CONTROL
1. Soil Boring and Monitoring Well Installation
All down-hole drilling equipment will be pressure washed, scrubbed and rinsed prior to
use and between each soil boring/monitoring well installation location.

2. Monitoring Well Sampling
Monitoring wells will developed using submersible pumps to ensure removal of all
introduced drilling fluids. Monitoring wells will be purged using low flow techniques prior
to sample collection. New nitrile gloves will be worn by field personnel during sampling
activities and changed between sample locations. All field meters will be properly
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calibrated daily and as needed, and will be decontaminated prior to use and between
sampling locations. Collected samples will be placed directly into laboratory-supplied
sample containers and immediately placed on ice in a sample cooler. The samples will
be shipped in sealed coolers to the laboratory. Proper chain of custody procedures will
be maintained at all times. To evaluate laboratory quality control and repeatability, one
duplicate ground water sample will be collected and analyzed for VOCs, SVOCs and
RCRA metals during each sampling event and one trip blank sample (for VOCs) will
accompany the samples during each sampling event.

3. Soil Sampling
Soil samples will be collected using a decontaminated hand auger or drill rig tooling. All
field meters will be properly calibrated daily and as needed, and will be decontaminated
prior to use and between sampling locations. Field personnel will collect each soil sample
using a new pair of nitrile gloves. The samples will be placed directly into laboratory-
supplied sample containers, immediately placed on ice in a sample cooler and transported
to the laboratory in the manner described above. Proper chain of custody procedures will
be maintained at all times. To evaluate laboratory quality control and repeatability, one
duplicate soil sample will be collected and analyzed for VOCs, SVOCs, RCRA metals, one
duplicate sample will be collected and analyzed for RCRA Metals by EPA Method 6010,
OPPs by SW-846 Method 8141B and OCPs by SW-846 Method 8081B. One (1) trip blank
sample will accompany the samples during the sampling event.

4. Duplicates and Trip Blanks
All sampling will follow appropriate quality assurance protocols that will include ground
water, surface water, sediment and soil duplicate samples. One (1) trip blank will also be
included in the sampling.
G. INVESTIGATIVE DERIVED WASTE MANAGEMENT
Soil cuttings from the installation of soil borings and monitoring wells will be field screened and/or
visually inspected. If no indication of impacts are noted, soils will be used to backfill the soil
borings and/or spread onto the ground in the vicinity of the boring. If field screening and/or visual
observations indicate soils are impacted, impacted soils will be placed into labeled 55-gallon
drums and appropriate samples collected to characterize the soils for proper disposal.

Monitoring well development and purge water, as well as equipment decontamination water, will
be field screened and visually inspected. If no obvious impacts are noted, the water will be
discharged onto the ground in the vicinity of the monitoring well being sampled. Discharged water
will not be allowed to enter the creek or run off-site. If field screening or visual inspection indicates
potential impacts, the water will be placed in labeled 55-gallon drums. Once laboratory analytical
results are received, the water will be properly disposed.

H. REPORTING

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All of the results and field data from the assessment activities will be summarized and presented
in an Assessment Report that will include all applicable field data, laboratory analytical results
(including J-flagged or estimated concentrations), tables, figures, conclusions and
recommendations for the site, and will be certified by signature and seal of Professional Geologist
duly licensed in North Carolina.

FIGURES
5632439.8
2016
= 500'

TABLE
Sample ID Objective Depth
(feet)
VOCs
8260
SVOCs
8270
RCRA Metals
6020
Organophosphorus
Pesticides 8141B
Organochlorine
Pesticides 8081B
Hexavalent
Chrome 7199
SB-1 Soil Quality (Site Buildings)2 X X X Potential
SB-2 Soil Quality (Site Buildings)2 X X X Potential
SB-3 Soil Quality (Background)2 X X X Potential
SB-4 Soil Quality 2 X X X Potential
SB-5 Soil Quality 2 X X X Potential
SB-6 Soil Quality 2 X X X Potential
SB-7 Soil Quality 2 X X X Potential
SB-8 Soil Quality 2 X X X Potential
SB-9 Soil Quality 2 X X X Potential
SB-10 Soil Quality 2 X X X Potential
MW-1 Surficial Aquifer (adjacent to LUST property)25 X X X
MW-2 Surficial Aquifer (adjacent to LUST property)25 X X X
MW-3 Surficial Aquifer (Background) 25 X X X
DW-1 Bedrock Aquifer (adjacent to LUST property)45 X X X
SW-Inf Stream (Influent)Surface X X X
SW-Eff Stream (Effluent)Surface X X X
SED-Inf Stream Sediment (Influent)Streambed X X X
SED-Eff Stream Sediment (Effluent)Streambed X X X
Trip Blank Trip Blank X X X
Duplicate A Soil Duplicate 2 X X X
Duplicate B Soil Duplicate 2 X X X
Duplicate C Surface Water Duplicate Surface X X X
Duplicate D Stream Sediment Duplicate Streambed X X X
Duplicate E Ground Water Duplicate X X X
Note: Colors keyed to Figure 2.
TABLE 1
ELAN-INDIAN TRAIL
SAMPLE LOCATIONS AND ANALYSES
BROWNFIELDS PROJECT 23037-19-090

APPENDIX

August 22, 2019
Ben Liebetrau, Vice President
Greystar GP II, LLC
465 Meeting Street, Suite 500
Charleston, SC 29403
[e-mail]

Subject: Additional Assessment Request
Elan Indian Trail
Southeast of the Intersection of Chestnut Parkway and W US Highway 74
Parcels 07105004 and 07105005D
Indian Trail, Union County
Brownfields Project Number 23037-19-090

Dear Mr. Liebetrau,
The North Carolina Department of Environmental Quality (DEQ), Brownfields Program has reviewed the
documents submitted with the Brownfields Property Application for the Elan Indian Trail property located
southeast of the intersection of Chestnut Parkway and W US Highway 74, Union County. The following
is a summary of the reports reviewed:

Based on our review of these documents and information garnered from adjacent properties, data gaps
were identified. Additional assessment activities, as outlined below, are required to assist in making risk
management decisions for inclusion in the Brownfields Agreement (BFA). Prior to conducting field
activities, a work plan should be submitted to DEQ for review and approval. The work plan should
include a description of the sampling and analytical methods to be utilized and a map depicting the proposed
sample locations. The most recent Inactive Hazardous Sites Program Guidelines for Assessment and
Cleanup (http://portal.ncdenr.org/web/wm/sf/ihs/ihsguide) and the November 2018 DEQ Brownfields
Assessment Work Plan Checklist (attached) should be followed. Request Level 2 QA/QC data packages
from a N.C. certified environmental laboratory. Collect one duplicate sample for all analysis per every 5%
of samples. All sample locations are referenced in the attached map.

Report Title Author Date
Phase I Environmental Site Assessment Resolve Environmental
Services, PLLC
May 15, 2019
Phase II Environmental Site Assessment
Recommendation Letter
Resolve Environmental
Services, PLLC
May 23, 2019

Elan Indian Trail
August 22, 2019
Page 2

1) Groundwater Sampling: Install a total of four monitoring wells at the following locations:

a. Three monitoring wells along the southeastern property boundary immediately
downgradient of the former Catawba Food Mart #4 LUST site (currently Walgreens) as
shown in the attached figure. The monitoring well located in the middle of the row of
three wells should be completed within the underlying bedrock to a depth of approximately
45 feet below ground surface (ft BGS) as referenced in the Comprehensive Site Assessment
Report completed by Shield Engineering, Inc. for the Catawba Food Mart #4 dated
February, 2004. The two outside monitoring wells should be completed within the
surficial aquifer with the screened portion of the well straddling the water table.
b. One monitoring well should be completed near the north central portion of the northern
parcel (07105005D) as referenced in the attached figure. This monitoring well should be
completed within the surficial aquifer with the screened portion of the well straddling the
water table.

Monitoring wells should be constructed and developed in accordance with the standards presented
in the North Carolina Administrative Code (NCAC) Title 15A Subchapter 2C and the US EPA
Region 4 Science and Ecosystem Support Division Guidance. Monitoring wells should be
surveyed to determine accurate groundwater flow across the Brownfields Property. Following well
development, monitoring wells should be sampled for Volatile Organic Compounds (VOCs) by
EPA Method 8260, Semi-VOCs (SVOCs) by EPA Method 8270, and Resource Conservation and
Recovery Act (RCRA) Metals by EPA Method 6020.

2) Soil Sampling:

a. Collect one surficial soil sample from the 0-2 ft BGS depth interval from each of the locations
referenced as circles in the attached figure. If impacted soils are observed at 2 ft BGS based
on visual, olfactory, and/or photoionization detector (PID) readings, collect additional samples
as warranted up to a maximum total depth of 5 ft BGS. Soil samples across the property
represented by a yellow circle in the attached figure should be analyzed for VOCs by EPA
Method 8260, SVOCs by EPA Method 8270, and RCRA Metals by EPA Method 6020. Soil
samples located along the transmission line corridor represented by a red circle in the attached
figure should be analyzed for Organophosphorus Pesticides (OPPs) by EPA Method 8141B,
Organochlorine Pesticides (OCPs) by EPA Method 8081B, and RCRA Metals by EPA Method
6020. Collect and have the laboratory hold an additional sample aliquot for possible analysis
of Hexavalent Chromium via EPA Method 7199 depending on results of RCRA Metals
analysis

3) Surface Water/Sediment Sampling: Collect collocated surface water and sediment samples at
locations representing the influent and effluent of the stream running north to south across the
Brownfields Property. Samples should be collected in accordance with the Operating Procedures
established by the US EPA Region 4 Science and Ecosystem Support Division (SESD) for Surface
Water Sampling (December 16, 2016) and Sediment Sampling (August 21, 2014). Samples should
be analyzed for Volatile Organic Compounds (VOCs) by EPA Method 8260, Semi-VOCs
(SVOCs) by EPA Method 8270, and Resource Conservation and Recovery Act (RCRA) Metals
by EPA Method 6020.

Elan Indian Trail
August 22, 2019
Page 3

4) Receptor Survey: Complete the enclosed Brownfields Property receptor survey and include as an
attachment to the additional Assessment Report.

Report and Figures: Upon receipt of analytical data, submit a summary report with a description of field
activities, tabulated data in comparison to applicable screening levels, and the laboratory data packet with
applicable QA/QC documentation, provide a site plan with well locations, locations of sample points, and
current site structures. Provide a potentiometric map for groundwater flow and concentration maps for
contaminants detected above applicable standards. Please note, all sample points may need to be included
on the future Brownfields plat. DEQ recommends having sample locations surveyed at the time of
collection for use in preparation of the Brownfields plat.

Please provide the Work Plan for additional assessment activities as soon as you are able. If you have
questions about this correspondence or require additional information, please feel free to contact me by
phone at [phone] or by email at [e-mail].

Sincerely,
Cody J. Cannon
Brownfields Project Manager

ec: Josh Glover, Greystar Real Estate Partners
Zach Spencer, Greystar Real Estate Partners
Mary Katherine Stukes, Parker Poe Adams & Bernstein
Terry D. Kennedy, P.G., Resolve Environmental Services, PLLC