17038_Goodyear_WP&Approval Occupancy Sampling 2021.04.19 rev

April 19, 2021 Sent Via E-mail Chris Orrell
ECS Southeast, LLP 1812 Center Park Drive, Suite D Charlotte, NC 28217 Chris Orrell, P.G. <[e-mail]>
Subject: Work Plan Approval - Revised Indoor Air and Sub-Slab Soil Gas Sampling Plan Rev1 Goodyear Service Center Charlotte, Mecklenburg County Brownfields Project No. 17038-13-060
Dear Mr. Orrell : The North Carolina Department of Environmental Quality (DEQ) Brownfields Program received the Indoor Air and Sub Slab Soil Gas Sampling Plan_Rev I dated April 9, 2021 (Work Plan). DEQ
Brownfield comments to previous revisions dated March 24, 2021 of this Work Plan has been addressed. As we discussed on Friday, April 16, 2021, the indoor air samples shall be collected a minimum of 7 days after the completion of the pilot testing. In addition, please include a statement in the summary report that the timeframe between pilot testing and vapor sampling was a sufficient time for static conditions to return within the building. 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 any questions, please feel free to contact me at 704-661-0330, or via e-mail at [e-mail].
Sincerely,
Carolyn F Minnich Brownfields Project Manager ec: Roger A Smith, P.G. [e-mail]
William Brooks Burleson [e-mail] Eric Stone [e-mail]

INDOOR AIR AND SUB-SLAB SOIL GAS SAMPLING PLAN_REV1 FORMER GOODYEAR SERVICE CENTER
100 & 122 EAST STONEWALL STREET, 600 SOUTH COLLEGE
STREET, AND 615 SOUTH TRYON STREET
CHARLOTTE, MECKLENBURG COUNTY, NORTH CAROLINA
BROWNFIELDS PROJECT NO. 17038-13-060

ECS SOUTHEAST, LLP
PROJECT 49-5350-D

PREPARED FOR:
MARLOTTE HOTEL, LLC & CRESCENT SOUTH TRYON, LLC
APRIL 9, 2021
Former Goodyear Service Center – Indoor Air and Sub-Slab Soil Gas Sampling Plan_Rev1
100 & 122 East Stonewall Street, 600 South College Street, and 615 South Tryon Street
Charlotte, Mecklenburg County, North Carolina
Brownfields Project Number 17038-13-060
ECS Project No. 49-5350-D
April 9, 2021

TABLE OF CONTENTS
1.0 INTRODUCTION ................................................................................................................. 1
2.0 SCOPE OF WORK ............................................................................................................. 1
3.0 SAMPLING METHODOLOGY .............................................................................................. 2
4.0 LABORATORY ANALYSES ................................................................................................. 3
5.0 QA/QC ................................................................................................................................. 4
6.0 REPORTING ........................................................................................................................ 4

FIGURES Figure 1 – Site Location Map Figure 2 – Site Development Plan Figure 3 – Proposed Indoor Air and Sub-Slab Soil Gas Sample Location Map TABLES Table 1 – Proposed Sample Locations & Analysis
Former Goodyear Service Center – Indoor Air and Sub-Slab Soil Gas Sampling Plan_Rev1
100 & 122 East Stonewall Street, 600 South College Street, and 615 South Tryon Street
Charlotte, Mecklenburg County, North Carolina
Brownfields Project Number 17038-13-060
ECS Project No. 49-5350-D
April 9, 2021

1
1.0 INTRODUCTION
The Site is currently comprised of two parcels identified as Mecklenburg County Parcel ID Nos. 12512106 and 12512107 located in Charlotte, Mecklenburg County, North Carolina. The two
parcels together total approximately 3.5 acres and are all owned by Crescent South Tryon, LLC and Marlotte Hotel, LLC, respectively. The site was formerly developed with a parking lot and three buildings: the Former Goodyear Service Center, a 27,000 square foot office building, and a
45,000 square foot office building. These improvements have been demolished in connection with the redevelopment of the property. The location of the Site is show on Figure 1: Site Topographic Location Map. The size of the basement floor of the hotel is approximately 17,841 square feet. Based on historical sampling activities at the site, it was determined that a vapor intrusion mitigation system (VIMS) would be required for the hotel portion of the redevelopment for the safe reuse of the site (Figure 2: Site Development Plan). The VIMS was installed in accordance with the Vapor Intrusion Mitigation Design (VIMD) – Tryon Place dated August 26, 2019. The VIMS installation report prepared by EAI (the VIMD engineer) was submitted to the Brownfields Program on March 24, 2021. In accordance with the VIMD, and at the request of the North
Carolina Brownfields Program (NCBP), this Work Plan was developed to evaluate sub-slab soil gas and indoor air quality pre and post occupancy. 2.0 SCOPE OF WORK The objective of this sampling work plan is to collect indoor air samples, and sub-slab soil gas
samples within the hotel portion of the site (mitigated areas) following the installation of the VIMS and prior to occupancy to assess for VI. Indoor air and sub-slab soil gas sampling will be conducted concurrently to determine if VI concerns exist in the building. The indoor air and sub-slab soil gas sampling will be conducted in general accordance with the North Carolina Division of Waste Management’s (NCDWM) Vapor Intrusion Guidance document (March 2018, Version 2). Figure 3 shows the locations of the permanent sub-slab soil gas monitoring points installed during the VIMS installation activities (approved in the VIMD – Tryon Place dated August 26, 2019), and the proposed indoor air sample locations. NCBP will be notified when the indoor air, sub-slab soil gas sampling event has been scheduled. A walk-through of the building will be completed a minimum of 24-hours prior to sampling with chemicals and products documented by field notes and photographs. Safety data sheets (SDS)
for each product provided to ECS will be included in an Appendix to the report or submitted digitally. If feasible, products containing volatile organic compounds (VOCs) will be removed a minimum of 24-hours in advance of the sampling activities. An Indoor Air Building Survey and
Sampling Form will be completed for each mobilization. 2.1 Indoor Air Sampling
As shown on Figure 3, five indoor air samples will be collected (IA-1 through IA-5). The proposed locations were selected based on accessibility and within rooms that can be easily sealed off during the sampling event. ECS anticipates using individually certified Summa canisters with flow
Former Goodyear Service Center – Indoor Air and Sub-Slab Soil Gas Sampling Plan_Rev1
100 & 122 East Stonewall Street, 600 South College Street, and 615 South Tryon Street
Charlotte, Mecklenburg County, North Carolina
Brownfields Project Number 17038-13-060
ECS Project No. 49-5350-D
April 9, 2021

2
restrictors such that samples are collected over an 8-hour period. The samples will be analyzed
for full-list VOCs by EPA Method TO-15. The HVAC system will be operational during the sampling event.
Concurrently with the indoor air sampling, an exterior (ambient) air sample will be collected upwind for laboratory analysis of full-list VOCs by EPA Method TO-15. If multiple mobilizations are needed, an ambient air sample will be collected per mobilization. The weather conditions
(temperature, wind direction/speed, barometric pressure, and pressure differential (using a handheld barometer and/or differential magnehelic gauge between indoors and the exterior of the building) will be recorded at the time of sampling (using the National Weather Service). 2.2 Sub-Slab Soil Gas Sampling ECS will collect ten sub-slab soil gas samples (MP-1 though MP-10) from previously installed sub-slab monitoring points installed by EAI Specialty Contracting (VIMD/VIMS engineer) as shown on Figure 3. ECS anticipates using batch certified Summa canisters with flow restrictors such that samples are collected over a 30-minute period. Each sample will be analyzed for full-list VOCs by EPA Method TO-15. If the sub-slab samples collected detect an exceedance of the risk-based calculator, additional indoor air samples will be required.
2.3 Schedule & Pressure Monitoring The first sampling event will be conducted subsequent to the approval of the work plan by the
NCBP and prior to occupancy. Based on the results of the initial sampling event, additional sampling events may be required prior to occupancy.
After occupancy has been granted, monthly pressure monitoring of the permanent monitoring points will be conducted over the first year of occupancy, the results of which will be submitted to the Brownfields Project Manager on the quarterly basis. With approval of the Brownfields Program, the frequency of pressure monitoring and reporting may be reduced based on the results of the monthly monitoring events. Additionally, sub-slab soil gas samples will be collected from the monitoring points on an annual basis for a minimum of three years to determine if increasing concentration trends are present that may result in transitioning the system to active. At the completion of the third annual sampling event, a request to terminate the future annual sampling may be submitted to the NCDEQ should the data support the recommendation. 3.0 SAMPLING METHODOLOGY
3.1 Indoor Air Sampling ECS anticipates using individually certified 6-liter Summa canisters with flow restrictors such that samples are collected over an 8-hour period. ECS anticipates placing each Summa canister at a
height of approximately 5 feet above the floor during sampling. In order for the building to remain closed and to minimize disturbance of the canisters, ECS anticipates collecting the samples when construction crews are not working in the area where samples are being collected. In addition,
when possible, doorways will be closed and/or sealed to further minimize disturbance of the canisters during the sampling event. Additionally, windows will be shut and the HVAC will be running and operational prior to and during each sampling event. Prior to collection of air samples,
Former Goodyear Service Center – Indoor Air and Sub-Slab Soil Gas Sampling Plan_Rev1
100 & 122 East Stonewall Street, 600 South College Street, and 615 South Tryon Street
Charlotte, Mecklenburg County, North Carolina
Brownfields Project Number 17038-13-060
ECS Project No. 49-5350-D
April 9, 2021

3
the sub-slab monitoring points, which are closed with the exception of pressure monitoring or
sampling, will remain closed for a minimum of 8-hours. In addition, ECS will collect and submit one duplicate indoor air sample (side by side canisters) and one ambient air sample per mobilization event for laboratory analysis of full-list VOCs by EPA Method TO-15.
3.2 Sub-Slab Soil Gas Sampling Subsequent to the indoor air sampling, ECS will collect the sub-slab soil gas samples from the
previously installed permanent monitoring points. Prior to collecting the vapor samples, laboratory grade helium gas will be used as a quality assurance/quality control (QA/QC) measure to assess the integrity of the probe seal. A plastic cylinder will be placed and sealed over the sampling point and sample train and purged with laboratory grade helium. The probe point tubing and tracer gas tubing will be placed through the cylinder wall via rubber grommets and a shroud will be placed over the sample point and sample train leading to the purge valves and sample port. The cylinder will be placed on a 4-inch diameter rubber gasket and held securely to the slab with a heavy weight. During the purging stage, the cylinder will be flooded with laboratory grade helium via the hose placed through the cylinder wall. A Model MGD-2002 Multi-Gas Leak detector or similar device will be connected to the probe
tube and the air stream being purged with at least 3 volumes (volume to include total sampling train as well as the constructed point). Helium readings will be collected from each volume, recorded in field notes, and included as part of final report. A helium concentration of less than
five percent helium will be considered acceptable. If concentrations greater than five percent helium are measured, the probe tube seal will be reseated and the leak detection process will be repeated.
ECS anticipates that the sub-slab soil gas samples will be collected in batch certified 6-liter Summa canisters at a rate of approximately 0.2 L/minute over an approximate 30-minute period. A flow restrictor will be utilized to achieve the approximate 0.2 L/minute flow rate. ECS will collect and submit one duplicate sub-slab soil gas sample for laboratory analysis of full-list VOCs by EPA Method TO-15. The duplicate sample will be collected utilizing a splitter concurrently with the sampling of the other primary sample or immediately after sampling the other primary sample using a 4-way valve to maintain sample train integrity. In the event that the laboratory is unable to provide a sufficient number of 6-liter Summa canisters for sub-slab soil gas sampling, ECS may utilize batch certified 1-liter or batch certified 3-liter
Summa canisters at an approximate flow rate of 0.2 L/minute to collect soil gas samples over a 5-minute period or 15-minute period, respectively. 4.0 LABORATORY ANALYSES ECS anticipates using Con-Test Analytical Laboratory (Con-Test) for laboratory services.
Samples will be submitted for analyses for full-list VOCs by EPA Method TO-15. Since North Carolina does not certify laboratories for analyses of air samples, ECS will request that the laboratory analyze air samples for the most current and applicable standards from the National Environmental Laboratory Accreditation Program (NELAP). Laboratory results will be compared to the NCDWM non-residential (industrial/commercial) Vapor Intrusion Screening Levels (VISL). A Level II QA/QC package will be requested from the laboratory and J-flags will be reported.
Former Goodyear Service Center – Indoor Air and Sub-Slab Soil Gas Sampling Plan_Rev1
100 & 122 East Stonewall Street, 600 South College Street, and 615 South Tryon Street
Charlotte, Mecklenburg County, North Carolina
Brownfields Project Number 17038-13-060
ECS Project No. 49-5350-D
April 9, 2021

4
Reporting limits and method detection limits will meet the applicable screening criteria (to the
extent feasible). 5.0 QA/QC
The Summa canisters will be batch certified for the sub-slab soil gas samples and individually certified for indoor air samples.
The sampler will verify the canister’s initial vacuum prior to collecting the samples. If the initial vacuum prior to sampling is more than 10% below the vacuum documented by the laboratory upon shipment, the canister will not be used. For soil gas sampling, a helium concentration of less than five percent helium (detected within the shroud) will be considered acceptable. If concentrations greater than five percent helium are measured, the probe tube seal will be reseated and the leak detection process will be repeated. During the sampling process, the primary valve in the sampling train will be closed and sampling terminated when the vacuum drops below 5” Hg and before it drops below 4” Hg. The canister
vacuums will be recorded by field personnel during sample collection as well as by the laboratory prior to analysis. If the canister vacuum reaches 0” Hg, the results will not be accepted by the NCDEQ which will require re-sampling.
6.0 REPORTING
The analytical data will be provided to the NCBP within five to seven business days of receipt and validation of the data. The NCBP will be provided with the tabulated laboratory data with comparison to the most recent risk assessment standards, associated laboratory reports, chain-of-custody forms, field notes, and sample locations maps. Indoor air and soil gas sample results will be compared to determine if the same chemicals of concern are identified in both sample results and compared to the NCDWM non-residential VISL. Post indoor air and sub-slab soil gas sampling, vacuum influence readings will be collected from the permanent monitoring points and newly installed sub-slab sampling points. These readings will be included within the sampling report and can be used as a round of monthly system measurements. A report of the results of the sampling outlined in this sampling work plan will be issued within three weeks of receipt of laboratory results and will be submitted to the NCBP, on behalf of the client. If unidentified and unexpected conditions are encountered during the sampling event, the NCBP and the client will be notified immediately.
The report will also include:
• VIMS readings recorded at the time of sample collection including sub-slab vacuum readings at each permanent monitoring point.
• Table comparing all compounds detected to their respective non-residential vapor intrusion screening level or laboratory reporting limit for compounds not detected;
• Field notes and photographs of chemicals and products documented during the walk-through of the buildings prior to sampling;
Former Goodyear Service Center – Indoor Air and Sub-Slab Soil Gas Sampling Plan_Rev1
100 & 122 East Stonewall Street, 600 South College Street, and 615 South Tryon Street
Charlotte, Mecklenburg County, North Carolina
Brownfields Project Number 17038-13-060
ECS Project No. 49-5350-D
April 9, 2021

5
• Photographs of each indoor air and sub-slab soil gas sampling point (set up with helium shroud and full sampling train) along with field logs in the Appendix to the report (the field logs will also indicate if the doors and windows were shut, if the fans were running, if the
HVAC system is functional/operating prior to and during each sampling event, and will include the monthly VIMS readings recorded during the sampling event);
• Safety data sheets (SDS) for each product used in the building and provided to ECS, specifically products present in the buildings during the walk-through (24-hours prior to/during sampling) will be included in the appendix to the report or submitted digitally; and
• A certification page signed/sealed by a North Carolina licensed Professional Geologist (PG) or Professional Engineer (PE).

FIGURES
FIGURE 1
SITE LOCATION MAP
INDOOR AIR AND SUB-SLAB SOIL GAS
SAMPLING PLANFORMER GOODYEAR SERVICE CENTERBROWNFIELDS PROJECT No. 17038-13-060CHARLOTTE, MECKLENBURG COUNTY,
NORTH CAROLINA
ECS PROJECT NO. 49-5350-D
SOURCE:
USGS TOPOGRAPHIC MAP:
CHARLOTTE EAST, DATED 1967PHOTOREVISED 1988 NORTH CAROLINA QUADRANGLE
SCALE: 1” = 2,000’
SITE
SOURCE:
OWNER SITE DEVELOPMENT PLAN
FIGURE 2SITE DEVELOPMENT PLAN
INDOOR AIR AND SUB-SLAB SOIL GAS SAMPLING PLANFORMER GOODYEAR SERVICE CENTERBROWNFIELDS PROJECT No. 17038-13-060
CHARLOTTE, MECKLENBURG COUNTY,
NORTH CAROLINAECS PROJECT NO. 49-5350-D
APPROXIMATE
VMS LOCATION(SEE FIGURE 3
FOR EXTENTS)
PROPOSED INDOOR
AIR AND SUB-SLAB
SOIL GAS SAMPLE
LOCATION MAP
FIGURE 3
Client:
Project:
Title:
Approved By:
FORMER GOODYEAR
SERVICE CENTER
CHARLOTTE, NC
BFID # 17038-13-060
Drawn By:Checked By:
Date:
CDO RAS
RAS 4/8/2021
ECS Project No.
49: 5350-D
MARLOTTE HOTEL,
LLC & CRESCENT
SOUTH TRYON, LLC
SUB-SLAB SOIL GAS SAMPLING LOCATIONS
INDOOR AIR SAMPLING LOCATION
LEGEND
NORTH ARROW
IA-1
IA-2MP-1
MP-2
MP-3
MP-4
MP-5
MP-6
MP-7
MP-8
MP-9
MP-10
MITGATED AREA
IA-3
IA-4
IA-5

TABLES

Laboratory Analysis & Analytical Method
VOCs
Sub-Slab Soil Gas Samples
MP-1 TO-15
MP-2 TO-15
MP-3 TO-15
MP-4 TO-15
MP-5 TO-15
MP-6 TO-15
MP-7 TO-15
MP-8 TO-15
MP-9 TO-15
MP-10 TO-15
DUP-1 TO-15
IA-1 TO-15
IA-2 TO-15
IA-3 TO-15
IA-4 TO-15
IA-5 TO-15
DUP-2 TO-15
AA-1 TO-15
Notes:
VOCs = Volatile Organic Compounds
TABLE 1 - PROPOSED SAMPLE LOCATIONS & ANALYSIS
FORMER GOODYEAR SERVICE CENTER
BROWNFIELDS PROJECT NO.: 17038-13-060
Sample Media
Indoor Air Samples
ECS PROJECT NO. 49-5350-D