23031_West Morehead II Work Plan- Approval 20200318

March 18, 2020

Sent Via E-Mail
Bo Cappleman Hart & Hickman 2923 South Tryon Street, Suite 100
Charlotte, North Carolina 28203

Subject: Work Plan Approval- Brownfields Assessment Work Plan West Morehead II Brownfields Property Charlotte, Mecklenburg County Brownfields Project No. 23031-19-060

Dear Mr. Cappleman,
The Department of Environmental Quality (DEQ) Brownfields Program received the Brownfields Assessment Work Plan dated March 4, 2020 for the above referenced Brownfields Property. DEQ Brownfields reviewed this document and the Work Plan is approved.
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: Trent Haston [e-mail]
Ms. Carolyn Minnich March 4, 2020
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showroom, and a stone cutting and finishing facility. The western warehouse is utilized by Wood
Design as a custom furniture and cabinetry shop. An exterior area beneath a canopy located
southeast of the Wood Design facility is used for wooden boat restoration. The Site and surrounding
area are depicted on Figure 2.

H&H prepared a Phase I ESA for the Site dated March 11, 2019. During the Phase I ESA, H&H
identified the following Recognized Environmental Conditions (RECs):

• H&H reviewed a Limited Phase II ESA report dated March 13, 2017 prepared by Summit
Engineering Laboratory & Testing, Inc. (Summit) for the Townhomes at Bryant Park
Brownfields Property located approximately 400 ft east and topographically downgradient of
the Site. According to the report, the chlorinated solvents tetrachloroethene (PCE) and
trichloroethene (TCE) were detected in groundwater at concentrations exceeding the North
Carolina 2L Groundwater Standards (2L Standards). Summit attributed the groundwater
impacts to an upgradient source. Based on area topography and the proximity of
documented groundwater impacts to the Site, H&H identified the potential for on-Site
groundwater impacts as a REC.

• Based on our review of Sanborn Maps and city directories, Wright Cleaning Company (2220
W. Morehead Street) operated as a dry-cleaning facility at an adjacent property to the west
and topographically upgradient of the Site from at least 1953 until 1969. There is the
potential for a dry-cleaning solvent release to have occurred at the Wright Cleaning
Company facility. H&H was unable to locate documentation of previous environmental
assessment conducted at the former drycleaner. Based on the proximity of the former
drycleaner to the Site, area topography, the period of dry-cleaning operations, and the
documented presence of chlorinated solvent impacts to groundwater downgradient of the Site
(noted above), H&H identified the potential for environmental impacts from adjacent dry-
cleaning operations as a REC for the Site.
Ms. Carolyn Minnich March 4, 2020
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On March 28, 2019, H&H performed Phase II ESA groundwater sampling activities to assess the
potential for groundwater impacts at the Site. A summary of the Phase II ESA activities and
analytical data is provided as follows:

• One temporary monitoring well (TMW-1) was installed along the western Site boundary at a
location approximately 100 ft east and topographically downgradient of the former off-Site
drycleaner. Two temporary monitoring wells (TMW-2 and TMW-3) were installed east and
topographically downgradient of the on-Site buildings. TMW-2 was also located
downgradient of the former off-Site drycleaner.

• The chlorinated solvent tetrachloroethene (PCE) was detected in samples TMW-1 (4.4 µg/L)
and TMW-2 (3.9 µg/L) at concentrations above the North Carolina 2L Groundwater
Standard (2L Standard) of 0.7 µg/L. PCE degradation products, trichloroethene (TCE) and
cis-1,2-dichloroethene (cis-1,2-DCE), were also detected in sample TMW-2; however, the
detected concentrations are below the 2L Standards.

• No VOCs were detected in sample TMW-3 (downgradient of 2131 W. Morehead Street
building) at concentrations exceeding laboratory reporting limits.

• The detected concentrations of VOCs in shallow groundwater do not exceed the Residential
or Non-Residential Vapor Intrusion Groundwater Screening Levels (GWSLs). As such,
vapor intrusion does not appear to be a significant concern at the Site.

The Site received a letter of eligibility for entry into the DEQ Brownfields Program (Brownfields
Project No. 23031-19-060) on June 13, 2019. The Prospective Developer (PD), Titan Partners LLC,
plans to demolish the existing buildings and construct an approximate 300-unit apartment building
with ground-level retail, an above grade parking garage, and two office buildings. A preliminary
redevelopment plan is provided as Figure 3.

Ms. Carolyn Minnich March 4, 2020
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On October 10, 2019, a kick-off/data gap meeting was held with the PD, DEQ Brownfields Program
personnel, and H&H to discuss Site history, previous environmental assessment activities at the Site,
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 soil and groundwater 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 (Guidelines) dated October
2015 and most recent versions of the U.S. Environmental Protection Agency (EPA) Region IV
Science and Ecosystem Support (SESD) Field Branches Quality System and Technical Procedures
guidance. The proposed sample locations and analyses are summarized in Table 1, and the proposed
sampling locations are shown on Figure 2.

Prior to conducting the field activities, H&H will contact North Carolina 811, the public utility
locator, to mark subsurface utilities located on the Site. H&H will also contract with a private utility
locator to screen the proposed boring locations for subgrade utilities not marked by the public
locator. Additionally, the soil boring and temporary well locations will be hand cleared to
approximately 5 ft below the ground surface (bgs) to further screen the boring locations for the
presence of subsurface utilities. H&H will obtain a Subsurface Investigation Permit (SIP) from
Mecklenburg County prior to installation of the temporary monitoring wells.

2.1 Soil Assessment Activities

H&H proposes to advance four soil borings (SB-1 through SB-4) to evaluate shallow soil conditions
at the Site. The proposed soil sample locations are depicted on Figure 2 and described as follows:
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• Soil boring SB-1 will be advanced in the western portion of Site near a proposed
retail/apartment building.
• Soil boring SB-2 will be advanced in the southeastern portion of the Site near a proposed
parking deck and where debris was observed during the kick-off meeting.
• Soil boring SB-3 will be advanced in the northeastern portion of the Site near a proposed
commercial building and to evaluate potential impacts from an adjacent, upgradient property
to the north of the Site.
• Soil boring SB-4 will be advanced adjacent to the paint booth in the Wood Design facility.

Each soil boring will be initially advanced to an estimated depth of up to 5 ft bgs using a
decontaminated stainless-steel hand auger and further advanced to beyond the water table using a
direct push technology (DPT) drill rig. Continuous soil samples will be collected from each boring
using acetate-lined macrocore sleeves. The soil samples will be logged for lithologic description
and inspected for the presence of visual and olfactory indication of potential impacts and screened
for the presence of volatile organic vapors with a calibrated photoionization detector (PID). A soil
sample will be collected from 0-2 ft bgs for laboratory analysis from each soil boring unless field
screening indicates obvious soil impacts between the 0-2 ft interval and the capillary fringe, in which
case a soil sample will be collected from the depth interval that exhibits the highest potential for
impacts.

Following collection, the soil samples will be placed in dedicated laboratory-supplied sample
containers, labeled with the sample identification, date, and requested analysis, and placed in a
laboratory supplied cooler with ice. The samples will be delivered to a North Carolina certified
laboratory under standard chain of custody protocols. The soil samples collected from borings SB-1
through SB-3 will 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 Methods 6020/7471. Based on the total chromium analytical results, H&H will
select two soil samples to be analyzed for hexavalent chromium by EPA Method 7199.
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2.2 Groundwater Assessment Activities

H&H proposes to convert each of the four soil borings into temporary groundwater monitoring wells
(TMW-4 through TMW-7). H&H estimates that the temporary wells will be installed at depths of
35 to 40 ft bgs.

The temporary well 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 10 to 15 ft of 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 by
removing a minimum of 3 to 5 well volumes and until field parameters have stabilized (pH ± 0.1 SU
and conductivity varies no more than 5%).

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 three- to five-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).
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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 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 RCRA
metals by EPA Methods 6010/7470.

Following sample collection, H&H will record geographic coordinates for the soil boring/temporary
monitoring well locations using a sub-meter GPS unit. H&H will also utilize surveying techniques
to estimate the top of casing elevation and ground surface elevation at each temporary monitoring
well to develop a groundwater potentiometric surface map for the Site.

Following surveying activities, the soil borings/temporary monitoring wells will be properly
abandoned by a licensed well driller, and the ground surfaces will be restored to match approximate
pre-drilling conditions.

2.3 Quality Assurance/Quality Control Samples

Non-dedicated equipment and tools will be decontaminated prior to use at each boring or sampling
location, or following exposure to soil or water. For quality assurance and quality control purposes
(QA/QC), one trip blank will be submitted for analysis of VOCs by EPA Method 8260. To evaluate
the reproducibility of certain sample results, H&H will collect one duplicate soil sample and one
duplicate groundwater sample to be analyzed for VOCs by EPA Method 8260, SVOCs by EPA
Method 8270, and RCRA metals by EPA Methods 6020/7470/7471. The duplicate soil sample will
also be analyzed for hexavalent chromium by EPA Method 7199 if the laboratory ultimately
analyzes a parent sample for hexavalent chromium based on total chromium data.

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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).

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 will be included with laboratory analytical report.

2.4 Investigation Derived Waste

Based on the prior data, 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 permitted facility for disposal, if needed.

2.5 Brownfields Receptor Survey

H&H will perform a Brownfields receptor survey in accordance with DEQ Brownfields Program
guidance and the Brownfields Program form. The receptor survey will include information about
land use in the Site area including zoning. In addition, H&H will conduct a field search for water
supply wells, basements, utility manways, storm sewers, other underground utilities, drains, and
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surface water within up to a one-mile radius of the Brownfield property boundaries. 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.

2.6 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 the receptor
survey results, a description of the sampling activities, a figure depicting sample locations, soil
boring logs for the soil and temporary well borings, 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 look forward to your approval of this work plan. Should you have any questions or need
additional information please do not hesitate to call me at [phone].

Sincerely,
Hart & Hickman, PC
Bo Cappleman, PG Due Diligence Manager
cc: Mr. Trent Haston, Titan Partners LLC (via email)
Attachments
Table 1
Proposed Sample Locations and Analyses
West Morehead II Brownfields Property
2131, 2211, and 2233 W. Morehead Street
Charlotte, North Carolina
DEQ Brownfields Project No. 23031-19-060
H&H Job No. ANR-004
SB-1/TMW-4
Assess surficial soil conditions and groundwater conditions in
the western portion of Site near proposed retail/apartment
building
0-2
8260, 8270,
6020/7471,
7199 on hold
8260, 8270,
6020/7470
SB-2/TMW-5
Assess surficial soil conditions and groundwater conditions in
the southeastern portion of the Site near a proposed parking
deck
0-2
8260, 8270,
6020/7471,
7199 on hold
8260, 8270,
6020/7470
SB-3/TMW-6
Assess surficial soil conditions and groundwater conditions in
the northeastern portion of the Site near a proposed
commercial building; evaluate potential impacts from an
adjacent, upgradient property to the north
0-2
8260, 8270,
6020/7471,
7199 on hold
8260, 8270,
6020/7470
SB-4/TMW-7
Assess surficial soil conditions and groundwater conditions in
the southwestern portion of the Site near the paint booth in the
Wood Design facility
0-2
8260, 8270,
6020/7471,
7199 on hold
8260, 8270,
6020/7470
Notes:One duplicate soil sample and one duplicate groundwater sample will be collected for the laboratory analyses noted above.
Hexavalent chromium analysis by EPA Method 7199 will be placed on hold pending total chromium results. Based on the results, two soil
samples will be selected for hexavalent chromium analysis.
VOCs = volatile organic compounds
SVOCs = semi-VOCs
RCRA = Resource Conservation and Recovery Actft bgs = feet below ground surface
Sample Objective(s)Soil Sample
Depth (ft bgs)
Groundwater
Analytical
Methods
Sample ID Soil Analytical
Methods
S:\AAA-Master Projects\Roby Realty (ANR)\ANR-004 - W Morehead Street\Brownfields\Brownfields Assessment Work Plan\Proposed Sample Summary Table
3/4/2020
Table 1
Hart & Hickman, PC
0 2000 4000
APPROXIMATE
SCALE IN FEETN
U.S.G.S. QUADRANGLE MAP
QUADRANGLE
7.5 MINUTE SERIES (TOPOGRAPHIC)
CHARLOTTE EAST, NORTH CAROLINA 1991
TITLE
PROJECT
SITE LOCATION MAP
WEST MOREHEAD II BROWNFIELDS PROPERTY
2131, 2211, AND 2233 W. MOREHEAD STREETCHARLOTTE, NORTH CAROLINA
DATE:
JOB NO:
REVISION NO:
FIGURE:
1-21-20 0
1ANR-004
SITE
REVISION NO. 0
JOB NO. ANR-004
DATE: 1-22-20
FIGURE NO. 2
WEST MOREHEAD II BROWNFIELDS PROPERTY
2131, 2211 AND 2233 W. MOREHEAD STREET
CHARLOTTE, NORTH CAROLINA
PROPOSED SAMPLE LOCATION MAP
LEGEND
SITE PROPERTY BOUNDARY
PARCEL BOUNDARY
TRENCH DRAIN
POLE-MOUNTED TRANSFORMER
DUMPSTER
AIR COMPRESSOR
PROPOSED SOIL BORING/
TEMPORARY MONITORING WELL
2923 South Tryon Street-Suite 100
Charlotte, North Carolina 28203
704-586-0007(p) 704-586-0373(f)
License # C-1269 / #C-245 Geology
TABERNACLE GOD
APOSTOLIC CHURCH
(2208 W. MOREHEAD
STREET)
EAGLE LEAGUE TATTOO
(2206 W. MOREHEAD
STREET)
JOY MART/FORMER
WRIGHT CLEANING CO.
(2210-2216 W. MOREHEAD
STREET)
WIMS, INC.
(2132 W.
MOREHEAD
STREET)
BURGESS SALE & SUPPLY
(2121 W. MOREHEAD STREET)
PAINT
BOOTH
COLONY PARK WEST
(2301 W. MOREHEAD
STREET)
PRECISION WALLS
(2198 WILKINSON BOULEVARD)
TOWNHOMES AT BRYANT PARK
(2022-2024 WILKINSON BOULEVARD)
UNDEVELOPED
LAND
SANITARY SEWER
LIFT STATION
SEDIMENT TRAP
(2131)
FORMER WESTINGHOUSE
DISTRIBUTION CENTER
(2001 W. MOREHEAD STREET)
W. MO
RE
HEAD ST
REET
MORT
O
N

S
T
R
E
E
T
GREENLAND
AVENUE
BOAT
RESTORATION
RESIDENTIAL
RESIDENTIAL
THE MARBLE & STONE SHOP
(WAREHOUSE/FABRICATION SHOP)
(2131 W. MOREHEAD STREET)
WOOD DESIGN
(2233 W. MOREHEAD STREET)
THE MARBLE & STONE SHOP (OFFICES)
(2211 W. MOREHEAD STREET)
VACANT
(2200 W. MOREHEAD STREET)
SB-3 / TMW-6
SB-2 / TMW-5
SB-1 / TMW-4
S:\AAA-Master Projects\Roby Realty (ANR)\ANR-004 - W Morehead Street\Brownfields\Brownfields Assessment Work Plan\Figures\Figures.dwg, FIG 2, 1/22/2020 10:55:22 PM, sperrySB-4 / TMW-7