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Via Email
February 12, 2018
NCDEQ
Division of Waste Management
Brownfields Program
1646 Mail Service Center
Raleigh, NC 27699-1646
Attn: Mr. David Peacock
Re: 2017 Annual Redevelopment Update Report
HD Supply
1414 and 1422 South Tryon Street
Charlotte, North Carolina
Brownfields Project ID 19054-15-060
H&H Project No. BCP-064
Dear David:
1.0 Introduction
On behalf of Beacon MPI, LLC (Beacon), Hart & Hickman, PC (H&H) has prepared this annual
redevelopment update report to document environmental related activities conducted in 2017 at
the HD Supply Brownfields Site (BF Project No. 19054-15-060) located at 1414 and 1422 South
Tryon Street in Charlotte, Mecklenburg County, North Carolina (Site, subject Site, or the
RailYard). A Site location map is provided as Figure 1. This report has been prepared in
accordance with Land Use Restriction (LUR) 11 in the executed Brownfields Agreement for the
Site.
Mr. David Peacock
February 12, 2018
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2.0 Brownfields Assessment Activities
In accordance with the Brownfields Assessment Work Plan dated October 14, 2016, H&H
completed additional Brownfields assessment activities at the site in February 2017. During the
assessment activities, H&H collected seven soil gas samples within the footprint of the proposed
northern office building and the footprint of the proposed residential apartment building.
Additionally, H&H advanced five soil borings to assess the vertical and horizontal extent of
impacted soil in the vicinity of the former drycleaner. Soil boring and soil gas sample locations
are provided on Figure 2. Details of the assessment activities are provided in the Brownfields
Assessment Report dated June 19, 2017 and the conclusions are summarized below.
• Soil with compound concentrations above Residential and/or Industrial Preliminary Soil
Remediation Goals (PSRGs) are present in shallow soil in the area of soil samples SB-4
and SB-6 advanced near the former dry-cleaning equipment in the multi-use building.
Analytical results of a soil sample collected from SB-6 for analysis of volatile organic
compounds (VOCs) by toxicity characteristic leaching procedure (TCLP) indicated that
soil in the vicinity of the former dry-cleaner is not a characteristically hazardous waste.
• Results of the soil gas sampling indicate that concentrations of tetrachloroethene (PCE)
and 1,2,4-trimethylbenzene were detected above Residential Vapor Intrusion Screening
Levels (VISLs) in the sample from SG-6 located below the southwestern portion of the
proposed residential apartments. Results of cumulative risk calculations indicate that
cumulative risks for this sample did not exceed the acceptable lifetime incremental cancer
risk (LICR) range of 1 x 10-4 to 1 x 10-6 for potential carcinogenic risks or the threshold
HI of 1 for potential non-carcinogenic risks, although the calculated HI was 0.91 and
close to 1. No other soil gas samples in the area of the proposed apartments contained
compound concentrations above Residential VISLs and no soil gas samples in the area of
Mr. David Peacock
February 12, 2018
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the proposed office building contained compound concentrations above Non-Residential
VISLs.
3.0 Asbestos Survey and Building Demolition
On July 14, 2017, H&H completed an asbestos survey of the on-site structures. The asbestos
survey was conducted in general accordance with the North Carolina Health Hazards Control
Unit (HHCU) and Mecklenburg County Air Quality (MCAQ) guidelines for asbestos building
inspections. During the asbestos survey activities, H&H identified and collected 68 samples
from 28 suspect homogeneous suspect materials.
The results of laboratory analysis indicate that the following suspect ACM sampled during the
survey contains asbestos at a concentration >1%. By EPA’s definition, the following material is
an ACM:
• black roof adhesive (approximately 300 square ft) identified coating the base of stickups
on the 36,010-square ft warehouse building roof system contains 5% Chrysotile asbestos
(Sample 004).
The roof adhesive was evaluated as Category I non-friable ACM in good condition. Asbestos
was not detected in the remaining suspect materials collected by H&H and analyzed by the
laboratory.
The final Brownfields Agreement (BFA) was signed and recorded on October 6, 2017.
Demolition of the existing site buildings including the approximately 7,700 square foot (sq ft)
multi-purpose office building and the approximately 36,000 sq ft warehouse began on October
16, 2017. Demolition of the site building completed on November 13, 2017.
Mr. David Peacock
February 12, 2018
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4.0 Soil Characterization
To expedite the grading activities and to minimize the need to stockpile and manage large
volumes of soil at the Site, H&H conducted soil characterization activities at the site on October
25 and 26, 2017 in accordance with the North Carolina Department of Environmental Quality
(DEQ) approved work plan. To collect a representative number of samples, H&H divided the
Site into seven sections as depicted on Figure 2. Sections 1 through 6 are areas of the Site where
impacts to soil were not anticipated based on Site history and previous assessments. Section 7 is
the “Area of Potential Soil Contamination” as denoted on the Brownfields plat where the former
dry-cleaner was located and previous soil assessment has indicated some soil impacts.
As summarized in the soil characterization email dated November 6, 2017, five soil borings were
advanced in each of Sections 1 through 6 and one soil boring was advanced in Section 7. Two
soil samples were collected in each section, one shallow sample (ground surface to 6 inches bgs)
and one deeper sample was collected from 6 inches bgs to the bottom of the boring based on the
depth of the soil cut in that area. Soil collected from the shallow interval from each of the five
borings in a given section was homogenized and submitted for laboratory analysis of semi-
volatile organic compounds (SVOCs) and Resource Conservation and Recovery Act (RCRA)
metals. Soil collected from the deeper interval from each of the five borings in a given section
was homogenized and submitted for laboratory analysis of SVOCs and RCRA metals. One
sample was collected from both the shallow and deeper interval from each section for VOCs
analysis based on field screening results. If field screening results did not indicate the likely
presence of impacts in a given section, then the sample for VOCs analysis was collected from the
central most boring in a given section. Samples submitted for VOC analysis were not
homogenized.
Analytical results did not indicate the presence of VOCs, SVOCs, or RCRA metals in the
shallow or deep samples collected from Sections 1, 2, 3, or 4 at concentrations above Residential
Mr. David Peacock
February 12, 2018
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or Commercial/Industrial PSRGs. The shallow soil sample collected from section 5 indicated the
presence of several SVOCs above laboratory reporting limits and benzo(a)pyrene,
benzo(b)fluoranthene, and dibenzo(a,h)anthracene at concentrations above the Residential
PSRGs, but below the Commercial/Industrial PSRGs. Additionally, arsenic was detected above
Residential and Commercial/Residential PSRGs and above background levels at the Morehead
Street Brownfields property (Brownfields No. 18057-14-060). The deeper sample collected from
Section 6 did not indicate the presence of VOCs or SVOCs at concentrations above Residential
or Commercial/Industrial PSRGs. Arsenic was detected at 1.8 J mg/kg in the deeper sample
from section 5 which is above the Residential PSRG, but is below the Commercial/Industrial
PSRG and below background arsenic concentrations at the Morehead Street Brownfields
property (up to 3 mg/kg).
The shallow soil sample collected from section 5 indicated the presence of PCE at a
concentration of 0.0024 mg/kg which is below Residential and Commercial/Industrial PSRGs.
Additionally, arsenic was detected at a concentration of 2.2 J mg/kg which is above the
Residential PSRG, but below the Commercial/Industrial PSRG. No other VOCs, SVOCs, or
RCRA metals were detected in the shallow or deeper soil samples collected from section 6 at
concentrations above Residential or Commercial PSRGs. Analytical results indicate the presence
of PCE and TCE at low concentrations below the Residential and Commercial/Industrial PSRGs
in the shallow and deeper samples collected from section 7. No SVOCs or RCRA metals were
detected above Residential or Commercial PSRGs in the soil samples collected from section 7.
Based on the results of the soil characterization activities, DEQ approved soil to be managed as
detailed below in an email dated November 16, 2017:
• Shallow soil from sections 1, 2, 3, 4, or 6, found suitable as fill material could be used at
the subject site for beneficial fill material.
Mr. David Peacock
February 12, 2018
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• Shallow soil from sections 1, 3, and 4 could be transferred to the Morehead Street Brownfields
property for beneficial fill material.
• Shallow soil from Section 5 should be transported to a permitted landfill and not be used
as beneficial fill at the subject site or Morehead Street Brownfields property.
• Shallow and deep soil in section 7 should be placed under the southern office building
where a vapor mitigation system will be installed or be transported to a Subtitle D
landfill.
• If shallow soil at the site is found to not be suitable structural fill for use at the subject site
or the Morehead Street Brownfields property, shallow soil from sections 1, 3, and 4 could
be transferred to a Land Clearing and Inert Debris (LCID) landfill or construction and
debris (C&D) landfill.
• Based on the presence of SVOCs in shallow samples from sections 2 and 5 and the low
concentration of PCE in the shallow sample collected from sections 6 and 7, shallow soil
from these sections should be transferred to a Subtitle D landfill if this soil cannot be
used as beneficial fill at the subject site.
• Because no VOCs or SVOCs were detected above Residential or Commercial/Industrial
PSRGs and because RCRA metals were detected below Commercial/Industrial PSRGs
and within range of background concentrations at the Morehead Street Brownfields
property, soil cut at the subject site below 6 inches bgs from sections 1 through 6 can be
transferred to the Morehead Street Brownfields property for use as beneficial fill material.
Mr. David Peacock
February 12, 2018
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5.0 Site Grading and Soil Transfer
Upon completion of the building demolition and soil characterization activities, site grading
activities began on November 16, 2017. Soil generated during site grading and soil cutting
activities was transferred from the subject site to the Morehead Street Brownfields property.
Between November 2017 and mid-January 2018, approximately 4,175 cubic yards (yd3) of soil
from sections 1 through 6 (only deep soil below 6 inches bgs from sections 2, 5 and 6) have been
removed from the subject site and transferred to the Morehead Street Brownfields property for
use as beneficial. Additionally, approximately 350 yd3 of shallow soil cut from sections 5 and 6
were transported to the Republic Subtitle D Landfill in Concord, North Carolina for proper
disposal. Manifests for soil transported to the Morehead Street Brownfields property are
provided in Appendix A. Manifests for soil transported to the Republic landfill are provided in
Appendix B.
On November 21, 2017, approximately 250 yd3 of impacted soil were excavated from the
Potential Area of Soil Contamination in section 7. Soil was excavated from ground surface to a
depth of approximately 1.25 ft bgs which was the final cut depth to achieve final grade in this
area of the site. Soil was transferred to section 6 and was placed in a containment cell at depths
from 1 ft to 4 ft bgs. Non-impacted soil from section 6 was then placed on top of the soil from
section 7 to achieve final grade. The containment cell is located below the footprint of the future
southern office building where a vapor mitigation system will be installed. The location of the
containment cell is depicted on Figure 2.
6.0 Summary
During 2017, development of the former HD Supply Brownfields Site (currently known as the
RailYard) began. Throughout the year, several Brownfields and development activities were
conducted at the site including:
Mr. David Peacock
February 12, 2018
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• Completion of soil assessment activities in February 2017 to evaluate the extent of
impacts to soil in the vicinity of the former dry-cleaner in the multi-use office building.
Impacts to soil were found to be limited to a small area near the former dry-cleaner
referred to as the Potential Area of Soil Contamination on the Brownfields plat.
• Completion of vapor intrusion assessment activities in February 2017. Results of the
assessment activities indicated the need for vapor mitigation measures for the future
southern office building and the southern portion of the proposed residential building.
• Completion of an asbestos survey in July 2017 which identified approximately 300 sq ft
of Category I non-friable roofing mastic on the warehouse building.
• Demolition of the warehouse building and multi-use buildings in October and November
2017.
• Completion of soil characterization activities across the site prior to the start of grading
activities including the advancement of 31 soil borings and collection of 14 soil samples
for laboratory analysis. Results of the soil characterization activities were used to
develop a soil transfer plan as detailed above.
• Completion of grading and soil movement activities to achieve final site elevations.
During the grading activities, approximately 4,175 yd3 of soil from sections 1 through 6
(only deep soil below 6 inches bgs from sections 2, 5, and 6) and approximately 350 yd3
of shallow soil cut from section 5 was transported to the Republic Subtitle D Landfill in
Concord, North Carolina for proper disposal. Additionally, approximately 250 yd3 of
impacted soil were excavated from the Potential Area of Soil Contamination in section 7
and were placed in a containment cell in section 6 where a vapor mitigation system will
be installed below the future southern office building.
Mr. David Peacock
February 12, 2018
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Development activities at the Brownfields property are ongoing and are being conducted in
accordance with the approved Environmental Management Plan.
Should you have any questions or need additional information, please do not hesitate to call us at
(704) 586-0007.
Very truly yours,
Hart & Hickman, PC
Nick Hotzelt Nathan O’Leary, CHMM
Assistance Project Engineer Project Manager
cc: Matt Lucarelli, Beacon Partners (1 copy via email);
Ms. Carolyn Minnich, North Carolina Department of Environmental Quality,
Brownfields Program (1copy via email)
SITE LOCATION MAP
HD SUPPLY BROWNFIELDS SITE
1414 AND 1422 SOUTH TRYON STREET
CHARLOTTE, NORTH CAROLINA
DATE:
JOB NO:
REVISION NO:
FIGURE NO:
05/12/2015 0
1BCP-064
0 2000 4000
APPROXIMATE
SCALE IN FEET
N
U.S.G.S. QUADRANGLE MAP
7.5 MINUTE SERIES (TOPOGRAPHIC)
2923 S. Tryon Street, Suite 100
Charlotte, NC 28203
704.586.0007(p) 704.586.0373(f)
CHARLOTTE EAST, NORTH CAROLINA 1991
SITE
SOUTH T
RYO
N STREETWIN
O
N
A
S
T
R
E
E
T
WINNIF
RED ST
REET
B
L
A
N
D
S
T
R
E
E
T
SB-7
SB-1
SB-5
SB-3
SB-2
SB-4
SB-6
SB-8
SB-10
SB-9
SC-5B
SC-5A
SC-5E
SC-5D SC-5C
SC-6A
SC-6B
SC-6E
SC-6CSC-6D
SC-4B
SC-4A
SC-4B
SC-4E
SC-4D
SC-3B
SC-3E
SC-3D SC-3C
SC-3A
SC-1B
SC-1A
SC-1C
SC-1E
SC-1D
SC-2B
SC-2A
SC-2C
SC-2E
SC-2D
SG-1
SG-2
SG-3 SG-4
SG-5
SG-6
SG-7
LEGEND
SITE PROPERTY BOUNDARY
DENOTES AREA TO BE CUT
DENOTES AREA TO BE FILLED
SECTION NUMBER
SURFACE SOIL ALIQUOT LOCATION
SURFACE & SUBSURFACE SOIL
ALIQUOT LOCATION
SOIL BORING LOCATION
SOIL GAS SAMPLE LOCATION
AREA OF POTENTIAL SOIL
CONTAMINATION
LOCATION OF BURIED IMPACTED SOIL
REVISION NO. 0DATE: 1-30-18
JOB NO. BCP-064 FIGURE NO. 2
HD SUPPLY BROWNFIELDS SITE
1414 AND 1422 SOUTH TRYON STREET
CHARLOTTE, NORTH CAROLINA
CUT/FILL AND SAMPLE LOCATION MAP
2923 South Tryon Street-Suite 100Charlotte, North Carolina 28203704-586-0007(p) 704-586-0373(f)License # C-1269 / #C-245 Geology
C
F
1
1
3
6
2
4
7
5
Appendix A
Soil Disposal Manifests – Morehead Street Brownfields Site
Appendix B
Soil Disposal Manifests – Republic Landfill