24014_Southern Resource_Source Investigation Work Plan_20211112

Geosyntec Consultants of NC, P.C.
1300 South Mint St, Suite 300
Charlotte, North Carolina 28203
PH 704.227.0840 www.geosyntec.com
CAR210216

12 November 2021

Mr. Peter Doorn
Brownfields Project Manager
North Carolina Department of Environmental Quality
1646 Mail Service Center
Raleigh, NC 27699-1646
Subject: Work Plan for Source Area, Soil, Groundwater, and Ambient Air
Assessment
Site: Southern Resources Scrap Metal, 3826 Raleigh Street
Charlotte, Mecklenburg County, North Carolina
Mecklenburg County Parcel IDs: 09107201 and 09107201E
NCBP Project No. 24014-20-060

Dear Mr. Doorn:
Geosyntec Consultants of NC, P.C. (Geosyntec), on behalf of our client, 3826 Raleigh Street, LLC
(“PD”), has prepared this Work Plan for Source Area, Soil, Groundwater, and Ambient Air
Assessment (Work Plan) at the former Southern Resources Scrap Metal facility addressed as 3826
Raleigh Street, Charlotte, North Carolina (“Site”). A Brownfields Property Application (BPA) was
submitted to the North Carolina Department of Environmental Quality (NCDEQ) Brownfields
Program (NCBP) in early 2020 on behalf of Sugar Creek Ventures, LLC. The Site received
eligibility into the NCBP in a 27 March 2020 Letter of Eligibility (LOE) from the NCDEQ. An
affiliate of Sugar Creek Ventures, 3826 Raleigh Street, LLC, subsequently purchased the property
on 7 January 2021 and submitted a revised BPA on 15 January 2021 requesting that a new LOE
be issued to reflect that 3826 Raleigh Street, LLC would be the Prospective Developer (PD) for
the Property. The revised LOE was received from NCDEQ on 5 February 2021.
On 27 July 2021, a teleconference was conducted with Geosyntec, the PD, and NCBP
representatives (Peter Doorn, Tracy Wahl, and Bruce Nicholson) to discuss a proposed path
forward to obtain a Brownfields Agreement (BFA). On 28 September 2021, NCDEQ submitted
an email requesting a Contamination Source Area Investigation Work Plan by 29 October 2021.
In a follow-up discussion on 14 October 2021, NCBP specified that they were requesting three
ambient air samples, soil samples for metals, and MiniRAE photoionization detector (PID)
screening with select soil samples for volatile organic compounds (VOCs), specifically
tetrachloroethene (PCE) and trichloroethene (TCE). Email correspondence from Peter Doorn of
NCBP on 3 November 2021 additionally requested groundwater sampling in the areas of highest
soil gas concentrations and extended the deadline for submittal of the Work Plan to 12 November
2021. This Work Plan is intended to collect additional data to address the environmental data gaps
Mr. Peter Doorn
12 November 2021
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identified by the NCBP to further evaluate risk to proposed redevelopment and off-site properties.
In combination with the Work Plan for Brownfields Agreement and Redevelopment: Soil and Soil
Gas Assessment (February Work Plan; Geosyntec) which was previously submitted to the NCBP
in February 2021, this Work Plan generally complies with the NCBP Minimum Requirement
Checklist (November 2018).
Scope of Work
Based on conversations with NCBP, Geosyntec proposes to perform supplemental assessments to
address data gaps to further evaluate risk to proposed redevelopment and off-site properties in
support of obtaining a final Brownfields Agreement. The proposed scope of work has been
developed in consideration of potential reuse of the Site and seeks to investigate the Site for a
potential VOC source area as well as assess the Site for potential environmental concerns related
to metals in soils or VOCs in ambient air. This Work Plan consists of soil and groundwater
sampling for source area investigation, soil sampling for metals, and ambient air sampling.
Groundwater flow direction has been established in a Brownfields Assessment Report for the
nearby Metromont Concrete Facility (Attachment A). In this report, Hart & Hickman, PC
estimates groundwater flow direction to the north-northwest based on data from nine temporary
monitoring wells. The Metromont Concrete Facility is located less than 100 feet northeast of the
Site; therefore, this Work Plan does not include collection of groundwater elevation data.
Sampling methodology, utility location, and decontamination will be conducted as described in
Section 3.1 of the February Work Plan.
Soil and Groundwater Sampling – Source Area Investigation
Geosyntec proposes to conduct a soil and groundwater source area investigation using direct push
technology (DPT) in an attempt to locate and/or evaluate the extent of a potential source area on-
site. Proposed locations of DPT borings are presented in Figure 1. Soil boring locations may be
adjusted in the field using adaptive location selection based on real-time PID headspace results to
optimize collection of useful data. Additional borings may be added as time allows based on 1.5
days of drilling for source area investigation. Soil borings will be advanced through concrete
surface by a North Carolina-licensed driller. Borings will extend up to 5 feet into the observed
water table at the time of drilling (anticipated to be 7 to 20 ft below ground surface [bgs]), and no
more than 25 ft bgs or refusal, whichever is encountered first. Boring depths may be adjusted in
the field based on the PID results or other field conditions (e.g., utilities). During implementation
of the DPT investigation, Geosyntec will evaluate PID headspace by wrapping each core in tinfoil
and inserting the PID through the foil to measure VOC concentrations. PID readings will be
recorded, and subsequent locations and depths chosen based on the results available at that time.
Select samples (up to 8) will be placed into laboratory supplied bottleware and submitted under
chain of custody for analysis of VOCs using U.S. Environmental Protection Agency (EPA)
Mr. Peter Doorn
12 November 2021
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CAR210216
Method 8260 by a National Environmental Laboratory Accreditation Program (NELAP)-certified
laboratory. Samples may be collected from the vadose (i.e., unsaturated) zone or from saturated
soil samples. Soil sample results will be compared to NCDEQ Residential Health Based
Preliminary Soil Remediation Goals (PSRGs). Data will also be analyzed using the NCDEQ Risk
Calculator (June 2021 or current version).
Four locations with elevated soil gas concentrations and/or PID response will be selected for
groundwater sampling. Temporary monitoring wells will be constructed by inserting a 1-inch
diameter Schedule-40 polyvinyl chloride (PVC) pipe with a 5-foot long 0.01-inch slotted screen
into the boring and filling the annular space with 20/30 silica sand. Grab samples will be collected
from the temporary wells using a peristaltic pump and collected directly into laboratory-provided
vials for analysis of VOCs using EPA Method 8260 by a NELAP-certified laboratory.
Groundwater sample results will be compared to the Title 15A North Carolina Administrative
Code (NCAC) Subchapter 2L.0202 groundwater quality standards (2L Standards) and NCDEQ
Residential Vapor Intrusion Screening Level (VISL) Ground Water Screening Levels (VISL
Screening Levels).
Following sampling, borings will be abandoned by removing the PVC and filling each boring with
bentonite chips to surface.
Soil Sampling – Metals Analysis
In addition to the source area investigation, Geosyntec proposes to use DPT to collect four
composite samples, each comprised of soil from the 2-foot bgs interval in 3 to 4 borings. No more
than 16 borings total will be advanced as part of this effort. Soil borings will be advanced through
the concrete surface by a North Carolina-licensed driller and surficial soil samples will be collected
using GeoprobeTM soil coring technology. Aliquots will be composited together in decontaminated
stainless-steel bowls. Samples will be submitted under chain of custody to a NELAP-certified
laboratory for analysis of select metals requested by the NCBP (antimony, beryllium, cobalt,
copper, nickel, thallium, and vanadium) by U.S. EPA Methods 6010 and 7000. The scope of this
Work Plan does not include analysis for hexavalent chromium which has already been speciated
at the Site. Soil sample results will be compared to NCDEQ Residential Health Based Preliminary
Soil Remediation Goals (PSRGs). Data will also be analyzed using the NCDEQ Risk Calculator
(June 2021 or current version).
Ambient Air Sampling
Three ambient air samples will be collected at the Site in upwind, on-site, and downwind locations
as shown on Figure 1 based on predominant wind flow direction. Locations may be adjusted in
the field based on wind direction as measured at the Charlotte Douglas International Airport on
the day of sample collection. A 6-liter summa canister will be deployed at each location prior to
disturbing the concrete cap. The summa canisters will be equipped with a 24-hour flow controller
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12 November 2021
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CAR210216
and will be deployed within the fenced area of the Site. The initial and final vacuum in the Summa
canisters will be recorded. No less than 5 inches of mercury will remain in the canisters. Following
a 24-hour period of sample collection, ambient air samples will be shipped under chain of custody
to a NAICS-certified laboratory and analyzed for VOCs using U.S. EPA Method TO-15. Level II
Quality Assurance and Quality Control reports will be requested from the laboratory. The results
of ambient air samples will be compared to NCDEQ Residential VISL Indoor Air Screening
Levels. Data will also be analyzed using the NCDEQ Risk Calculator (June or current 2021
version).
Quality Assurance and Quality Control
One duplicate soil sample designated for VOC analysis will be collected during the source area
investigation. Additionally, a trip blank, included in coolers with soil samples for VOC analysis,
will be evaluated for quality assurance and quality control (QA/QC) purposes. No duplicates will
be collected for soil samples being evaluated for metals or ambient air samples. Other QA/QC
procedures including chain of custody procedures are described in Section 5 of the February Work
Plan.
Investigation Derived Waste (IDW) Management
Soil drill cuttings will be placed in labeled, 55-gallon steel drums. Drums will be placed in a secure
location on-site for waste characterization and disposal. Under this scope, Geosyntec will collect
a composite toxicity characteristic leaching procedure (TCLP) sample from the drums for VOCs,
semi-volatile organic compounds (SVOCs), and Resource Conservation and Recovery Act
(RCRA) metals. IDW will be disposed of in general accordance with nonhazardous or hazardous
waste regulations, as appropriate.
Reporting
Upon receipt of analytical results, Geosyntec will prepare a written report summarizing the
investigation as described in Section 7 of the February Work Plan.
Closure
Should you have any questions or need additional information please do not hesitate to contact
Amy Kenwell ([e-mail]) at 704.227.0843 or Kaitlyn Rhonehouse
([e-mail]) at 910.372.6402. We look forward to your review and approval of
this Work Plan.

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Proposed Sample Locations3826 Raleigh Street, Charlotte, Mecklenburg County, North Carolina (Mecklenburg County Parcel Nos: 09107201 and 09107201E)Path: (Charlotte-01\) P:\GIS\Projects\S\Southern Resources\MXD\Source Options\F1_FormerSampleLocations.mxd 08 November 2021 AKenwell³
Figure
1Charlotte, NC November 2021
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Triple Crown LLC(Former Tarmac Virginia)
Former Abernathy Lumber
Former Celanese
Concrete Supply(Former Exposiac)
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NC Railroad Company
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Proposed Building Footprint
Site Boundary
Notes:1. The number and location of direct push technology (DPT) borings will beadjusted in the field based on interpretation of photoionization detector (PID)results.2. Proposed composite soil samples will consist of 3-4 aliquots of soils from 0-2feet below ground surface.3. Proposed ambient air locations will be adjusted in the field based on winddirection.4. Parcel boundary information obtained from Mecklenburg County, NConline GIS database.5. Estimated groundwater flow direction from Hart & Hickman, 2019 for nearbyMetromont Concrete Facility.6. World Imagery source: Esri, DigitalGlobe, GeoEye, Earthstar Geographics,CNES/Airbus DS, USDA, USGS, AeroGRID, IGN, and the GIS UserCommunity.
Estimated Groundwater Flow Direction