06016_Rad Spec_EAP Phase II Redvelopment 20070806

Environmental Action Plan
Phase 2 Redevelopment Area
Bryant Park at
1900 Wilkinson Boulevard
Charlotte, North Carolina
H&H Job No. BTP-001
August 6, 2007
Rev 0
ti Hart & Hickman
'�)' ; South 7Yyon Street
Suite 100
Charlotte. NC 29203
704-596-(N)07
8601 Sir Forks Road
Suite 400
Raleigh, NC 27615
919-847-4241

Environmental Action Plan
Phase 2 Redevelopment Area
Bryant Park at 1900 Wilkinson Boulevard
Charlotte, North Carolina
Revision 0 August 6, 2007
Table of Contents
INTRODUCTION......................................................................................................... 1
PHASE 2 ENVIRONMENTAL ACTION OBJECTIVES .......................................... l
SITECONDITIONS..................................................................................................... 2
Assessment Activities................................................................................................ 3
Results of Assessment at the Phase 2 Redevelopment Area.....................................4
Summaryof Redevelopment Considerations...........................................................5
PHASE 2 AREA ENVIRONMENTAL GOALS.........................................................6
Soil............................................................................................................................. 6
GroundWater...........................................................................................................8
PHASE 2 AREA ENVIRONMENTAL ACTIONS ..................................................... 8
Environmental Action Criteria.................................................................................9
Actions at Specific Phase II Redevelopment Areas ................................................ 12
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List of Appendices
Appendix A Phase I & 2 Redevelopment Area Map
Appendix B Figures 9, 10, and 11 excerpted from
2002 Results of Site Assessment Activities, Hart & Hickman, PC
Appendix C Updated Soil Data Screening Level Tables excerpted from
2002 Results of Site Assessment Activities, Hart & Hickman, PC
Appendix D Tables 1, 2, and 3, and Figures 2 and 3 excerpted from
2007 Supplemental Assessment Activities Report, Hart & Hickman, PC
Appendix E Tables 12 and 13, and Figure 5 excerpted from
2002 Results of Site Assessment Activities, Hart & Hickman, PC
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Environmental Action Plan
Phase 2 Redevelopment Area
Bryant Park
1900 Wilkinson Boulevard
Charlotte, North Carolina
Revision 0 August 6, 2007
INTRODUCTION
This Environmental Action Plan presents actions which may be necessary for the Phase 2
redevelopment area at the Bryant Park property located at 1900 Wilkinson Boulevard in
Charlotte, North Carolina.
It is assumed these actions will be completed under a DENR Brownfields Agreement by
the prospective developer, Suttle Avenue LLC, at the time that redevelopment occurs.
The Brownfields Agreement is expected to include a former industrial operation located
at 1900 Wilkinson Boulevard and two adjacent tracts of land.
A two-phase redevelopment plan for the site has been prepared the 1900 Wilkinson
Boulevard portion of the property. The Phase 1 and Phase 2 redevelopment areas are
depicted in the map provided in Appendix A of this Plan. Phase 1 redevelopment
involves constructing a building to be used for educational and commercial office
purposes in the southwestern portion of the property. Phase 2 redevelopment involves
constructing a surface parking lot in the central portion of the property where former
industrial facilities were located (which may be converted to a parking deck at a later
date), and building either a commercial office or residential structure in the northwest
portion of the Phase 2 redevelopment area (also depicted on the map in Appendix A).
PHASE 2 AREA ENVIRONMENTAL ACTION OBJECTIVES
As part of the Brownfields Agreement to be prepared for the Bryant Park property, it is
envisioned that land use will be restricted to commercial and office use, including use by
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an educational institution, with the possible exception of residential use in the northwest
comer of the Phase 2 redevelopment area. Actions described in this Plan account for a
range of site conditions that may arise during redevelopment and may be modified by
Suttle Avenue LLC and DENR as the project progresses to accommodate the final site
design and field conditions.
Actions described in this Plan are intended to provide conditions at the Phase 2
redevelopment area which are adequately protective of future site users and site
construction / utility workers, with regard to the following potential exposure risks:
• Exposure to contaminated soil — dermal contact; ingestion; inhalation of
contaminated dust; or vapor intrusion from VOCs in soil; and
• Exposure to contaminated ground water — dermal contact; ingestion; or vapor
intrusion of VOCs in ground water.
SITE CONDITIONS
Originally developed in 1897 as a cotton mill, the subject property was acquired in 1937
to commence manufacturing operations. The portion of the property corresponding to the
Phase 2 redevelopment area was used until 2006 for manufacturing automotive
chemicals, as well as various hardware, plumbing, and traffic safety products. Office and
warehouse operations supporting these manufacturing operations also occurred at the
property and those operations will continue until the end of 2007. Phase 2 redevelopment
areas of interest include former material storage areas, material unloading and shipping
areas, product mixing areas, boiler areas, above ground storage tank areas, and drum
storage areas.
Environmental conditions at the site are established by data presented in the Results of
Site Assessment Activities prepared by Hart & Hickman, PC (August 19, 2002), and
subsequent sampling conducted at DENR's Brownfields Program's request in 2007 as
presented in letter report Supplemental Assessment Activities (Hart & Hickman, PC,
February 2007). No additional assessment is judged to be necessary in the Phase 2
redevelopment area for the conditions as currently understood, except for possible UST-
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related activities as noted in this Plan. Additional assessment may be warranted if
previously unidentified releases are discovered during redevelopment and, if such an
instance occurs, DENR's Brownfields Program will be notified.
Assessment Activities
Areas of potential concern at the property were identified for the 2002 assessment based
on site inspections, discussions with former manufacturing employees, review of site
records, review of historical aerial photos, environmental database searches, and review
of DENR files. The 2002 assessment work was conducted in two phases (which phases
do not correspond geographically to the Phase 1 and Phase 2 redevelopment area
designations used in this Plan).
Initial assessment was conducted in areas of highest probability of impact to determine
the nature and magnitude of soil impacts, if any. Based on results from the initial phase
of soil sampling, the second phase of assessment was performed to delineate identified
soil impacts in selected areas, to determine if impacts occurred in other areas of the site,
to assess ground water conditions at the site, and to assess surface water and sediment
conditions in the creeks at the eastern boundary of the site. In addition, a receptor survey
was performed to identify potential receptors in the vicinity of the site.
Soils were sampled at 137 locations as part of the two-phase assessment, and 168 soil
samples were analyzed. In addition, 6 ground water samples, 3 surface water samples,
and 3 sediment samples were collected and analyzed. Laboratory analyses included
volatile organic compounds (VOCs), semi -volatile organic compounds (SVOCs), metals,
and polychlorinated biphenyls (PCBs), depending on the nature of historical operations in
the selected areas.
Supplemental assessment activities were initially requested by DENR's Brownfields
Program in June 19, 2003. This supplemental sampling scope was finalized in early 2007
and included the following:
• Soil Sampling —Collect soil samples from the soils in the vicinity of the Building
8 drainage outfalls; at storm drainage outfalls; and at the former pond area;
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• Ground Water Sampling — Collect water level measurements and ground water
samples from site monitoring wells; and
• Historical Research — Determine the historical usage of Building 7 and adjacent
western building to ensure no supplemental investigation is necessary in these
areas.
Results of Assessment at the Phase 2 Redevelopment Area
The 2002 assessment indicated impacts above screening levels have occurred in limited
areas of the property. Soil boring locations are depicted in Appendix B of this Plan
(Figures 9, 10, and 11 excerpted from the 2002 assessment report). Screening levels
referred to below are discussed later in this Plan under the heading Environmental Action
Goals,for the Phase 2 Redevelopment Area. Key 2002 results are summarized below:
• Exceedances in soil have occurred in specific limited Phase 2 redevelopment
areas as a result of manufacturing operations. Exceedances include selected
VOCs, SVOCs, and PCBs.
• Exceedances in soil for metals are limited to a detection of lead at one location.
• No target compounds were detected in the creek surface water and no target
compounds were detected in creek sediment at the site boundary above screening
levels.
• Modest exceedances of ground water standards for selected VOCs are present in
shallow ground water at the downgradient, eastern boundary and in a limited
central portion of the Phase 2 redevelopment area.
• The receptor study confirms that there are no ground water exposure pathways in
the vicinity of the site
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• Underground storage tanks (USTs) were used historically at the facility within the
Phase 2 redevelopment area.
Key results presented in the 2007 Supplemental Assessment Activities Report are
summarized below:
• No soil exceedances were identified in the former pond in front of Building 1, and
at the northern Building 8 drainage outfall.
• Bis(2-ethylexyl)phthalate (BEHP) was detected in soil at a concentration
exceeding screening levels in the 0 to 3 ft soil sample collected from a second
Building 8 drainage outfall, located northeast of Building 9.
• Modest exceedances of ground water standards for selected VOCs are present in
shallow ground water at the downgradient, eastern boundary and in a limited
central portion of the Phase 2 redevelopment area.
• A 1,000 gallon gasoline UST was located east of Building 7 and was removed in
the late-1980s.
Summary of Redevelopment Considerations
Based on the 2002 and 2007 assessment findings, the following key conditions at the
Phase 2 redevelopment area are considered in this Plan:
• VOCs, SVOCs, and PCBs are present in soils at specific locations as a result of
historic operations;
• Elevated lead is present in soil at one location;
• Elevated BEHP is present in soil at the Building 8 outfall northeast of Building 9;
• VOCs are present in ground water at the eastern, downgradient boundary and in a
limited central area;
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• Natural attenuation of VOCs is occurring in ground water at the eastern,
downgradient boundary;
• There are no identified potential ground water receptors in the vicinity of the
Bryant Park property; and
PHASE 2 AREA ENVIRONMENTAL GOALS
Soil
The 2002 assessment laboratory results for soil have been compared to published
regulatory screening levels for the compounds detected. Soil screening levels for this
Plan were selected from among the following references:
• NC DENR's Inactive Hazardous Sites Program - Guidelines for Assessment and
Cleanup (August 2006);
• EPA Region 9 Preliminary Remediation Goals — (October 2004); and
• EPA Region 3 Preliminary Remediation Goals— (April 2007).
• DENR-specified PCB screening levels noted below and referenced to proposed
final grade elevation:
• Commercial/industrial: 0-5 feet below proposed final grade: 83
mg/kg; below 5 feet: 830 mg/kg; in each case to a maximum depth of 14
ft below proposed final grade
• Residential: 0-5 feet below proposed final grade: 2 mg/kg; below 5
feet: 20 mg/kg; in each case to a maximum depth of 14 ft below proposed
final grade
As noted earlier in this Plan, the Phase 1 and Phase 2 redevelopment areas are being
redeveloped for commercial and office use, including use by an educational institution,
with the exception of the northern portion of the Phase 2 redevelopment area which may
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be used for residential purposes (refer to the site map provided in Appendix A).
Accordingly, assessment data from the commercial and office portions of the Phase 2
redevelopment area will be compared to commercial/industrial screening levels, and
assessment data from the residential portion of the Phase 2 area will be compared to
residential screening levels.
Because DENR's Inactive Hazardous Sites Program does not have published screening
levels for commercial/industrial settings, the Bryant Park commercial/industrial remedial
action objectives rely primarily on EPA Region 9 published industrial Preliminary
Remedial Goals (PRGs). If a compound of interest is not present on the Region 9 list,
EPA Region 3 commercial/industrial screening levels will be used. In instances where
the Region 9 or Region 3 commercial/industrial screening level is more stringent than
DENR's residential screening level, the DENR residential value will be used as the
screening level.
Because the screening levels have been revised since the original issuance of the 2002
assessment report, Appendix C of this Plan presents an updated version of the 2002
screening level comparison tables for soil samples collected in 2002 at the Phase 1 and
Phase 2 redevelopment areas (refer to figures in Appendix B for corresponding sample
locations). For easy reference, Appendix D of this Plan presents Tables 1, 2, and 3, as
well as Figures 2 and 3 excerpted from the 2007 Supplemental Assessment Activities
Report.
In summary, environmental action is described in the Phase 2 Area Environmental
Actions section of this Plan for soil where the existing assessment data indicates
constituent concentrations exceed the numerical goals described above.
The published regulatory screening levels used in this Plan are premised on highly
conservative exposure assumptions for a hypothetically representative site. Accordingly,
Suttle Avenue LLC wishes to maintain the option to conduct a site -specific risk
assessment in areas if published screening levels impose an overly conservative
redevelopment constraint. If conducted, site -specific risk assessment would be used to
determine the most appropriate action necessary to provide the necessary level of
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protection for the future site user. Such an assessment would be discussed with DENR in
advance and submitted for approval.
Ground Water
Ground water detections from the 2002 and 2007 assessment activities were compared to
North Carolina Administrative Code 21, ground water standards. Metals results were
compared to 2L standards and two times the maximum observed background
concentration, which ever is greater. Ground water exceedances are present in the central
and eastern portion of the Phase 2 redevelopment area. Phase 2 redevelopment in the
area of the ground water impact is comprised of surface parking, with plans to build a
parking deck at a later time.
There are no identified ground water receptors in the site area. The possible Phase 2
residential redevelopment area is located upgradient of the ground water impacts.
Consequently, ground water impacts at the site do not pose a receptor risk and do not
pose a vapor intrusion risk. Accordingly, environmental action is not specified for
ground water beyond restrictions on the use of ground water at the Bryant Park property.
Underground Storage Tanks (USTs)
Given the long operating history of the facility, the possibility exists that USTs may be
encountered during Phase 2 redevelopment. USTs remaining at the site, if any, will be
addressed as required by DENR's Brownfields and UST Sections. Suttle Avenue LLC
will keep DENR's Brownfields project manager apprised of progress with UST efforts.
PHASE 2 AREA ENVIRONMENTAL ACTIONS
Phase 2 redevelopment at Bryant Park is generally comprised of demolition of site
buildings; installation of infrastructure drainage lines and utilities; earthwork to achieve
the desired final grade; construction of the surface parking lots with a parking deck
planned at a later time; landscaping; and possible construction of a residential building in
the northwest portion of the Phase 2 redevelopment area (refer to map in Appendix A).
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The criteria noted below will be used to direct environmental actions in the Phase 2
redevelopment area at the time that redevelopment occurs.
Environmental Action Criteria
1. Land use will be restricted to commercial and office use, except for the northwest
portion of the Phase 2 redevelopment area which may be redeveloped as residential.
2. Use of ground water will be restricted at the site.
3. Contaminated soil above action levels will be identified based on existing site data.
4. If contamination is discovered at the site during redevelopment that is not similar in
nature to identified site impacts, Suttle Avenue LLC will contact DENR's
Brownfields Program to discuss the appropriate course of action. Such soil may be
set aside in a secure area while awaiting a determination. The soil will be placed on,
and covered with, plastic sheeting to prevent runoff during a storm event. The top
sheet will be anchored with blocks or other suitable weighted items and hay bales will
be placed on the downhill sides of the staged soil pile for supplemental run-off
control.
5. Corrective actions will ensure there is a barrier between future site occupants/workers
and soil above industrial ingestion risk levels. The barrier may be a building, paving,
hardscape surface, or clean fill / landscaping. The clean fill / landscaped areas within
industrial / commercial portions of the property will be filled with a minimum of 5 ft
of clean fill where trees are planted, and 2 ft in grassed and bush -planted areas. The
depth of clean fill required for residential redevelopment at the property, planned for
later stages of the project, will be discussed further with DENR's Brownfields
Program.
6. In preparing the site grading plan and performing site grading, the following will be
considered:
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a) If soil at the site is contaminated above the corresponding action level and can
be left in place, it will be covered as described in Item #5 above.
b) With DENR's approval, contaminated soil above the corresponding action
level can be moved to an alternate on -site location provided the soil is placed
under a barrier as described in Item #5 above. Where requested by DENR's
Brownfields Program existing data or supplemental analyses will be used to
confirm the soil to be moved is not characteristically hazardous.
c) If soil from an impacted area must be transported offsite, it will be profiled
based on existing site data and other analyses as may be required by the
disposal facility, and transported to a permitted facility.
6. If a sump or pit is encountered during redevelopment and does not require removal
for geotechnical or construction purposes, it will be filled with soil or suitable fill and
construction will proceed. Where appropriate, the sump bottom may be penetrated
before back filling to prevent fluid accumulation. If the sump has waste in it, the
waste may be set aside in a secure area and will be sampled as required by DENR's
Brownfields Program and disposed off -site. If the sump or pit must be removed and
the observed waste characteristics indicate the concrete may potentially be
contaminated to a significant degree, the concrete will be sampled and analyzed by
methods specified by the disposal facility and approved by DENR's Brownfields
Program.
7. If buried process piping is encountered and must be removed to allow redevelopment
to proceed, the contractor will inspect the pipe for fluids, collect and sample fluids
where appropriate, and look for signs of a release using field methods. If a release is
suspected, DENR will be contacted to discuss the appropriate course of action.
8. New buried utility lines (water, natural gas, electrical), storm water drainage lines,
sanitary sewer lines, roof drains, and other constructed subsurface features may be
installed in areas of contaminated soil. Suttle Avenue LLC anticipates back filling
the trenches with clean fill. Suttle Ave LLC may elect to backfill trench excavations
with contaminated soil from the site provided the fill is below the industrial standards
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specified in this Plan and provided trench fill within 25 It of an occupied building has
no VOCs present.
9. If a newly identified release indicates volatile constituents may be present in soil or
ground water that may pose indoor air concerns, DENR's Brownfields Program will
be notified. Corrective action for this scenario may involve moving the soil away
from the proposed building, installing passive vapor barrier and ventilation systems
consistent with building code requirements, modifying the building design, or
modifying the site layout.
10. If an underground tank is discovered during redevelopment, it will be discussed and
addressed per DENR instructions. If a petroleum UST release is discovered and the
release is commingled with impacts from facility operations, it may be necessary to
discuss distinguishing the UST impact from the non -UST impacts to prevent
excessive soil removal or ground water action as may be dictated by UST regulations.
11. If surface water run-off gathers in an excavation within an area of known soil
impacts, it will be allowed to evaporate, used for dust control in areas of known
contamination, or tested and disposed off -site.
12. If ground water accumulates in an open excavation within an area of known soil
impacts, it will be allowed to evaporate, tested and used for dust control in areas of
known contamination, tested and disposed off -site, or discharged to the City sewer
where approved by the City.
13. Demolition debris and materials accumulated at the site will be segregated as needed,
and disposed or recycled at an approved facility.
14. Potentially contaminated dirt will be shaken off of land clearing debris to the degree
practical with land clearing equipment, and the land clearing debris disposed off -site
at an approved LCID (land clearing and inert debris) landfill.
15. Contractors will be required to participate in site safety briefings to protect site
workers from exposure to contaminated soils and to advise of necessary precautions
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when moving contaminated soils around the Property. Boundaries of impacted soils
exceeding pertinent screening levels will be flagged on the Property to alert workers
to the need for precautions when moving fill material.
Actions at Specific Phase H Redevelopment Areas
Re -Placement of Soils Beneath Paving: Phase II grading plans indicate areas will be
built up in some areas, and cut in others areas to achieve the desired final grade. Using
the criteria noted above, Suttle Avenue LLC proposes to cut impacted soil from future
parking areas where needed and re -place the soil into asphalt paved parking areas or
beneath building footprints that require fill. Such movement would be discussed with
DENR's Brownfields Program in advance.
Stormwater Detention Pond: Suttle Avenue LLC must construct a stormwater detention
pond at the eastern edge of the property as part of redevelopment construction efforts.
Portions of this pond coincide with the location of assessment soil borings where 2002
detections of VOCs and SVOCs were reported. Soils exceeding residential screening
levels in the detention pond area will be removed. Such soils may be placed as fill on the
industrial/commercial portion of the Property as specified in this Plan.
Raginate Tank: To prepare for site grading, Suttle Ave LLC will remove a closed -in -
place Raffinate tank in the former truck loading area situated within the future
commercial/office portion of the property. Raffinate is a fluid derived from the coking
process in steel manufacturing and is therefore not a petroleum UST issue. Because the
tank is located in the area where PCBs were detected, existing delineation data will be
supplemented by pre -excavation sampling. These combined data will be used to identify
soil requiring excavation to meet the PCB screening levels noted in this Plan. Samples
will be analyzed for VOCs by EPA 8260, and SVOCs by EPA 8270, as well as PCBs and
RCRA metals. The existing and supplemental analytical results will be compared to the
industrial soil screening levels as described in this Plan. The tank will then be removed
and excavated soils will be segregated based on the sample data. To expedite actions in
this area, Suttle Ave LLC may elect to also remove impacted soil beyond the tank as
needed to reach the final desired grade. Data and field findings will be forwarded to
DENR's Brownfields Program as work progresses.
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