23068_Sir Walter Gun Club_RAP_20210115

609
PREPARED FOR:
Merritt - MW1, LLC
2066 Lord Baltimore Drive
Baltimore, Maryland 21244-2501
PREPAREF
S&ME, Inc.
3201 Spring Forest Road
Raleigh, NC 27616
Corporate Registration for Licensing of NC Geologists No. C-145
NC Engineering Firm No. F-0176
January 15, 2021

-a
January 15, 2021
North Carolina Department of Environmental Quality
Division of Waste Management, Brownfields Program
217 West Jones Street
Raleigh, North Carolina 27605
Attention: Mr. Brad Atkinson
Brownfields Project Manager
Reference: Remedial Action Plan
Hinton Oaks Blvd., Knightdale, North Carolina
Brownfields Project Name: Sir Walter Gun Club
Brownfields Project No.: 23068-19-092
S&ME Project No. 4305-19-213
Dear Mr. Atkinson:
via email: [e-mail]
S&ME, Inc. (S&ME), on behalf of the project developer Merritt — MW1, LLC, is submitting this Remedial Action Plan
to address lead impacted soil handling prior to site development activities for five flex space buildings, along with
associated parking lots, access drives and two stormwater ponds. Site development is anticipated to begin March
1, 2020. If you have any questions about the EMP for the proposed site redevelopment, please contact the
undersigned.
Sincerely,
5&ME, Inc.
Thomas P. Raymond, P.E.
Senior Engineer
[e-mail]
Enclosure: Remedial Action Plan, dated January 15, 2021
Samuel P. Watts, PG
Senior Project Manager
[e-mail]
S&ME, Inc. 13201 Spring Forest Road I Raleigh, NC 27616 1 p 919.872.2660 1 www.smeinc.com

Remedial Action Plan
Hinton Oaks Blvd., Knightdale, North Carolina
Brownfields Project Name: Sir Walter Gun Club
Brownfields Project No.: 23068-19-092
S&ME Project No. 4305-19-213
CERTIFICATION
Remedial Action Plan
Hinton Oaks Blvd., Knightdale, North Carolina
Brownfields Project Name: Sir Walter Gun Club
Brownfields Project No.: 23068-19-092
S&ME Project No. 4305-19-213
I, Thomas P. Raymond, a Professional Engineer for S&ME, Inc., do hereby certify this Remedial Action Plan was
prepared by me or under my direct supervision. CrAsr,�'��®�'
,e C............
SEAL
18760
•
F'
P. Raymond, P.E., P.M.P
Senior Engineer
,ed Engineer No. 18760
S&ME, Inc. is licensed to practice engineering in North Carolina. The firm's license number is C-145.
S&ME, Inc. is licensed to practice geology in North Carolina. The firm's license number is F-0176.
January 15, 2021

Remedial Action Plan
Hinton Oaks Blvd., Knightdale, North Carolina
Brownfields Project Name: Sir Walter Gun Club 111
Brownfields Project No.: 23068-19-092 E
S&ME Project No. 4305-19-213
Table of Contents
CERTIFICATION........................................................................................................................................................ ii
1.0 Introduction.......................................................................................................................1
2.0 Scope of Work....................................................................................................................1
3.0 Soil Treatment Product - EnviroBlend®......................................................................2
4.0 Soil Treatment Process with EnviroBlend®................................................................2
5.0 Handling & Processing Soils Above Residential Lead PSRG.................................3
6.0 Confirmation Soil Sampling...........................................................................................3
6.1 Soil Treated with EnviroBlend®.......................................................................................................3
6.2 Bottoms of Excavated Areas...............................................................................................................4
7.0 Deliverable...................................................................... Error! Bookmark not defined.
Appendices
Appendix I — Figures
Figure Al — Soil Treatment & Placement Exhibit
Figure A2 — Preliminary Site Development Plan with Soil Treatment & Placement Areas
Appendix II — Premier—EnviroBlend Application and Handling Information
January 15, 2021

Remedial Action Plan
Hinton Oaks Blvd., Knightdale, North Carolina •
Brownfields Project Name: Sir Walter Gun Club 111
Brownfields Project No.: 23068-19-092 E
S&ME Project No. 4305-19-213
1.0 Introduction
S&ME, Inc. (S&ME) on behalf of project developer Merritt — MW1, LLC (Merritt) has prepared this Remedial Action
Plan for the former Sir Walter Gun Club (Brownfields Project No. 23068-19-092). The purpose of this Remedial
Action Plan is to provide the process for handling and treating soils impacted with lead at levels above 5
milligrams per liter (mg/L) for soils analyzed by the Toxicity Characteristic Leaching Procedure (TCLP). This
Appendix II also provides procedures for confirming adequate treatment of soils, and confirmation soil sampling
for the removal of lead impacted soils above 5 mg/L by TCLP from treated soil areas, and handling and placement
of lead impacted soil above NCDEQ's Residential Preliminary Soil Remediation Goal (PSRG) for lead of 400
milligrams per kilogram (mg/kg). Where applicable, the procedures in EMP Appendix II were prepared in general
accordance with the NCDEQ, Division of Waste Management (DWM), Inactive Hazardous Sites Branch (IHSB),
Guidelines for Assessment and Cleanup of Contaminated Sites, January 2020, Version 2 (Guidelines).
Prior to preparing this Remedial Action Plan, S&ME reviewed the findings of previous assessments, conducted at
the subject site, and documented in by the following reports.
Memorandum — Sir Walter Gun Club, dated January 31, 1989, prepared by Stan Atwood, North Carolina
Department of Environmental and Natural Resources, Division of Waste Management, Superfund Branch
Removal of Lead Contaminants from the Soil on the Silver Plantations, dated March 10, 1992, prepared by
Paragon Environmental Group
Reconnaissance Investigation Results, Former Sir Walter Gun Club Site, Knightdale North Carolina, dated
February 14, 2013, prepared by AMEC Environment & Infrastructure, Inc.
Findings of Limited Soil Assessment - Abandoned Rifle Range Berms, dated November 18, 2010, prepared by
S&ME, Inc.
Additional Soil Testing - Abandoned Rifle Range Berms, dated January 4, 2011, prepared by S&ME, Inc.
Phase I Environmental Site Assessment, Multiple Parcels- Intersection of Hinton Oaks Blvd. and Knightdale Blvd.,
dated November 1, 2019, prepared by S&ME, Inc.
♦ Sediment, Surface Water, and Groundwater Assessment, dated February 26, 2020, prepared by S&ME, Inc.
♦ Limited Soil Assessment, dated August 4, 2020, prepared by S&ME, Inc.
♦ Additional Soil Assessment Report, dated December 11, 2020, prepared by S&ME, Inc.
2.0 Soil Areas Requiring Treatment
2.1 Soil Exceeding 5 mg/L by TCLP
Lead impacted soils exceeding 5 mg/L by TCLP have been identified at the following on -site locations (Figure All):
• 100-Yard Impact Berm
• 200-Yard Impact Berm and soil in front of the berm in the area of soil boring HA-31
• Side Berm
• Area of soil boring HA-46
The estimated total volume from these four areas is approximately 1,100 cubic yards (CY).
January 15, 2021

Remedial Action Plan
Hinton Oaks Blvd., Knightdale, North Carolina
Brownfields Project Name: Sir Walter Gun Club 111
Brownfields Project No.: 23068-19-092 E
S&ME Project No. 4305-19-213
2.2 Soil Exceeding Residential Lead PSRG
The areas impacted with lead exceeding the Residential PSRG level of 400 mg/kg are depicted on Figure Al. This
soil volume ranges from approximately 2,300 CY to 3,400 CY. The variability of volume is based upon whether one
foot of soil is removed, or 1.5 feet of soil is removed from over the affected areas. The final excavation depth in
these areas will be determined by confirmation soil sampling, as described in Section 6.0.
3.0 Soil Treatment Product - EnviroBlend°
EnviroBlend will be used to stabilize lead impacted soils above 5 mg/L by TCLP. EnviroBlend, a phosphate
stabilizing reagent, is manufactured by Premier Magnesia, LLC (Premier) of Wayne, PA
(https://www.enviroblend.com/Default.as-xx). EnviroBlend stabilizes metals regulating pH, forming insoluble
compounds that will not leach into the environment. EnviroBlend is delivered to the site in bulk or in 2,000-pound
super sacks. See the attached application and handling information from Premier.
4.0 Soil Treatment Process with EnviroBlend®
Prior to on -site soil excavation and treatment, the environmental engineer, or representative, will collect soil
samples from lead impacted soils above 5 mg/L by TCLP and send to Premier's laboratory for treatability testing
with EnviroBlend. The lab will conduct testing for lead by TCLP before and after treatment. Premier will provide a
report with a recommended mix ratio of EnviroBlend with soil to achieve and maintain lead in soils at levels well
below 5 mg/L TCLP. Typical mix ratios of EnviroBlend with soil range from 2% to 4% by weight. For example, 2 to
4 tons of EnviroBlend will be mixed with 100 tons of soil to achieve proper treatment.
The environmental engineer, or representative, will mark out the locations of the lead impacted soils above 5
mg/L by TCLP with flags or stakes. A contractor will conduct the following on -site soil treatment process:
• Soil with lead impacted above 5 mg/L by TCLP (approx. 1,100 CY) will incrementally be excavated and
treated in place with EnviroBlend and/or relocated to the on -site treatment and placement area (see
Figure Al).
• As needed, objects greater than 6-inches diameter may be removed before treatment. These removed
objects may be rocks, large vegetation or debris that will be properly disposed or recycled at off -site
facilities.
• As soil is brought to the treatment area, or treatment is conducted in the current soil locations, soil will be
treated in batches to ensure the proper mix ratio is achieved (2% to 4% EnviroBlend with soil) and is
thoroughly mixed. The contractor may use an agricultural spreader, disc tiller, auger, excavation
equipment or other mixing equipment.
• Before final placement and compaction, the environmental engineer will conduct testing to document
proper treatment of lead impacted soil. This testing procedure is presented below.
January 15, 2021

Remedial Action Plan
Hinton Oaks Blvd., Knightdale, North Carolina
Brownfields Project Name: Sir Walter Gun Club I I I
Brownfields Project No.: 23068-19-092
S&ME Project No. 4305-19-213
• Following approval by the environmental engineer, the contractor will place and compact the approved
treated soil in lifts and compact in accordance with project compaction specifications in the placement
area designated by the environmental engineer. This area will be covered with engineered backfill and
compacted per specifications with installation of a paved parking lot at the surface.
If laboratory TCLP results show treated soil at greater than 1 mg/L TCLP for lead, that batch of treated soil
will be treated again and retested by the environmental engineer. This cycle will be performed until the
soil batch produces TCLP results less than or equal to 1 mg/L TCLP for lead. After documentation of
proper treatment, the soil will be placed and compacted as presented above.
5.0 Handling & Processing Soils Exceeding Residential Lead PSRG
Figure Al shows the areas impacted with lead exceeding the Residential PSRG level of 400 mg/kg. This soil
volume ranges from approximately 2,300 CY to 3,400 CY. The variability of volume is based upon whether one
foot of soil is removed, or 1.5 feet of soil is removed from over the affected areas. The environmental engineer, or
representative, will mark out the locations of the lead impacted soils above 400 mg/kg with flags or stakes. A
contractor will conduct the following on -site soil treatment process:
Soil with lead impacted above 400 mg/kg (approx. 2,300 CY to 3,400 CY) will be excavated, relocated,
placed and compacted in the selected on -site placement area (see Figures Al and A2). This area will be
covered with a geotextile and covered with engineered backfill, compacted per specifications, and
covered with a paved parking lot at the surface.
• The excavation bottoms from where soil was removed will be sampled by the environmental engineer, or
representative, to confirm whether lead impacted soil above 400 mg/kg has been removed. Up to one
foot of soil will be removed initially from most of the impacted areas, and the excavation bottoms
sampled for lead. Some areas will be excavated to 1.5 feet, where previous sampling data showed lead
above 400 mg/kg. If excavation bottom soil samples show lead results above 400 mg/kg, additional soil
will be excavated and removed and the soil bottom resampled. This process will continue until excavation
bottom soil samples produce results below 400 mg/kg for lead. See below for excavation bottom soil
sampling procedures.
6.0 Confirmation Soil Sampling
6.1 Soil Treated with EnviroBlend°
Soils with lead at levels above 5 mg/L TCLP that have been treated with EnviroBlend will be sampled and analyzed
by a NC certified laboratory for concentrations of lead by the TCLP extraction EPA Method 1311 and SW-846
Method 6010C. The treated soil sampling procedure is as follows:
Treated soil will be segmented into approximate 50 CY piles or areas. Each segment will be dimensionally
flagged in the field and named (e.g. "Pile 1").
January 15, 2021

Remedial Action Plan
Hinton Oaks Blvd., Knightdale, North Carolina
Brownfields Project Name: Sir Walter Gun Club I I I
Brownfields Project No.: 23068-19-092
S&ME Project No. 4305-19-213
• Two composited samples will be collected from each segmented soil volume. Each composite sample will
be collected with a decontaminated sampling tool (e.g. hand auger or trowel). Each composite sample will
be comprised from the collection of at least four samples within one-half of the segmented soil volume
evenly spread across the area and from within the depth of the treated soil volume. Two individual
composited soil samples, each from four discreet sample locations (total of eight soil aliquots) will be
submitted for laboratory analysis. The soil samples will be named according to the soil segment name
(e.g. "Pile 1 S1", "Pile 1 S2").
• If laboratory TCLP results show treated soil at greater than 1 mg/L TCLP for lead, that batch of treated soil
will be treated again, resampled and retested per the procedure presented above. This cycle will be
performed until the soil batch produces TCLP results less than or equal to 1 mg/L TCLP for lead. After
documentation of proper treatment, the soil will be placed and compacted as presented above.
6.2 Bottoms of Excavated Areas
Soil samples will be collected from the bottoms of excavated areas and analyzed for total lead by SW-846 Method
6010C. Soil sampling procedures are as follows:
Design a surface sampling grid over the excavated area(s). Sampling grids should be no more than 25
feet by 25 feet. Soil samples will be collected from 0 to 6-inches from ground surface from excavation
bottom areas. Five individual evenly distributed samples will be collected with a decontaminated
sampling tool (e.g. hand auger or trowel) and formed into one composite soil sample representing the 25
feet by 25 feet area. Each area will be dimensionally flagged in the field and named (e.g. "Area 1A"). The
soil samples will be named according to the soil area name (e.g. "Area 1A SV, "Area 1A S2").
If laboratory results show lead in soil at greater than 400 mg/kg, that area will be excavated up to 6-
inches deeper and resampled in accordance with the procedure above. This cycle will be performed until
the excavated bottom soil samples produce total lead results less than or equal to 400 mg/kg.
6.3 Lateral Extent
Post -excavation soil sampling and analyses will be needed to demonstrate compliance with remediation goals.
Confirmation sampling will be conducted to demonstrate that the lateral extent of contaminants to meet
applicable remedial goals or acceptable risk for the desired land use. Confirmation samples should be analyzed
for total lead by SW-846 Method 6010C. Soil sampling procedures are as follows:
Sidewalls of the lateral extent of the excavation will be sampled. If there are several excavations, then a
separate set of samples is required from each excavation. At minimum, one sample shall be collected
from each sidewall of a four-sided excavation. For larger excavations, five individual evenly distributed
samples will be collected for every 25 linear feet of excavation sidewall. Samples will be collected with a
decontaminated sampling tool (e.g. hand auger or trowel) and formed into one composite soil sample
representing the 25 linear feet of sidewall. At each sample location, collect a sample from 0-3 inches into
the base or sidewall. Each linear segment will be flagged in the field and named (e.g. "Segment 1A"). The
soil samples will be named according to the soil segment name (e.g. "Segment 1A S1", "Segment 1A S2").
January 15, 2021 4

Remedial Action Plan
Hinton Oaks Blvd., Knightdale, North Carolina
Brownfields Project Name: Sir Walter Gun Club I I I
Brownfields Project No.: 23068-19-092
S&ME Project No. 4305-19-213
• If laboratory results show lead in soil at greater than 400 mg/kg, that area will be excavated laterally and
resampled in accordance with the procedure above. This cycle will be performed until the excavated
bottom soil samples produce total lead results less than or equal to 400 mg/kg.
7.0 Reporting
Documentation of compliance with the EMP and soil treatment, handling and confirmation sampling will be
provided following completion of the above scope of work. Documentation will be a letter report including the
flowing information:
• Description of excavation procedures noting the condition of the soil encountered and the
dimensions of the excavation(s).
• Documentation of the volume of soil excavated.
• Details of the treated soil process.
• The excavation and placement procedures documenting the final placement area of lead impacted
soil.
• The field and laboratory methods used for the treated soil and excavation bottom and lateral
confirmation sampling.
• Documentation of confirmation soil sampling, including location and laboratory analysis of
confirmation soil samples. Tabulation of the laboratory analytical results compared to applicable
screening levels and regulatory standards, with figures showing sample locations and analytical
results.
• Appendices: field logs, photographic logs and laboratory analytical reports and chains -of -custody.
January 15, 2021

Appendices

Appendix I - Figures

[ l
.. .. i.
..
U
MW-1
m
- ar impactBerm
-
Samples 5-4 C-1, 5-4 C-2, 5-4 C-3, 5-4 C-4,
S-6 C-1, S-6 C-2, S-6 C-3, S-6-C4 were
collected from this berm.
I `tlA�,
-
Depictedarea of fillp acemen
assumes fill u+ill be nlaGe l
foot thick layer. Specific area and
depth of fill will be determined after
DEVELOPER DOES NOT
IAITFNr) To rSF11Fl ()P
LOT 3A
i
final sit development dasign. — all n : W-Ilk I
m Q
HA=10 .
d►, �~? Stockpiled Clay �� -. ", �" �i p
- - - Target Debrisr� ... z
HA-14 jW 0 H
Soil in the soil treatment location shall 1��, , . - ` ' �`� HA 12 HA_13 HA 44 1.O- ° t a a� = z
e stockpiled In accordance with a
I�aF3z
r�, s
Hi h House
g
MW-3
field -located after initial site clearing.
s
yr' HA-1�7
HA-T8
FIA 45
7a 1 '''wry
HA-23
FIA=24 rtw=�r
Trap House
+'
3 100-Yard Impact Berm (2010)
HA-22
HA-35
-
HA 30
Samples S-1 C-1, S-1 C-2, 5-1 C-3, S-1 C-4, 2�
HA-Y1
FA-34
S-2 C-1, S-2 C-2, S-2 C-3, 5-2 C-4, r.
x S-3 C-1, S-3 C-2, S-3 C-3, S-3-C4 were
_
TM1 collected from this berm.
HA-39
❑w
Ouse
Soil Sample (June 2020 & Oct 2020)
Stream
HA 51
1 " = 200
In Less than PSRGs Full Project Site
AREA 2 Side Berm ,ee. Plond
■
RL
,
xcee s s
DATE:
_ HA-2S
l
Not Anal zed
1�JRange
- - 20
REFERENCE:
Rifle Range
,
+
_ Soil With Lead � 5 mglL TCLP
Skeet and Trap Field
__?
^�
PROJECT NUMBER
GIS BASE LAYERS WERE E)RTWNED FReM T-1 IE: 2017 Ne8NEIVAP AERIAL eRTI 18
LAYER. STREAM AND POND LOCATIONS PROVIDED BY WITHERS RAVE NEL ON 3/2;ffl.
,
Soil Exceeding PSRGs
—
4305-19-213
.�
;Proposed Fill
REPORT FROM S. & ME DATED JAN.4, 2011. THIS MAP 15 FOR INFORMATIONAL PURPOSES
`•
—
S&ME Sample Location (Nov. 2019)
-----' Placement Location
FIGURE Np.
ONLY. ALL FEATURE LOCATIONS DISPLAYED ARE APPROXIMATED. THEY ARE NOT BASED -
-+
ON CIVIL SURVEY INFORMATION, UNLESS STATED OTHERWISE. b y 200
400 ..
Monitoring Well SampleAl
n
* ,.1$F
Sedimenv Surface Water Sample

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'IJJ- �\- ,,; s '- PROPOSED SOIL PROPOSED FILL
'I� ; y--'' TREATMENT LOCATION PLACEMENT LOCATION
----------------------------
�Ex wETL,wosTo sE lM`Ac1Eo
Soil in the soil treatment location shall be Depicted area of fill placement assumes fill will be
stockpiled in accordance with the approved placed in a 5 foot thick layer. Speck area and
Brownfields Environmental Management depth of fill placement will be determined after final
\ EMP . Plan \
PExact location shall be field- ( ) site development design. cRnRNlcscALE FIGURE
\ located after initial site clearing.
mch -100 FG A2

Appendix II - Premier-EnviroBlend Application and Handling
Information

EnviroBlend
Metal Waste Treatment by Premier Magnesia, LLC
EnviroBlend° Application and Handling
EnviroBlend° Application
EnviroBlend® is a dry granular or milled material that can be purchased in 2000# Supersacks or
bulk. The single consideration with treatment is making sure product is homogeneously
mixed within the matrix (soil, waste, etc.). There is no preferred method for mixing.
Generally, clients utilize excavators, track hoes, backhoes, rotary -head mixers, pug -mills, or
agricultural tillers.
If not using a batch plant or pug mill, it is advisable to parcel out soil if not already residing in
cells or piles. This will allow for more careful metering of amendment. This is an example of the
steps for batch -mixing:
1. Excavate a pile of contaminated waste/soil of a set amount — for example 100 tons, etc.
2. Add the EnviroBlend at the required dosage. For example, if a 2% dosage rate of
EnviroBlend has been determined to be needed, it would necessitate that you add 2
tons of EnviroBlend per each 100 tons of soil.
3. Mix soil/EnviroBlend pile thoroughly with any of the previously mentioned equipment
so that it becomes a homogenous mix.
4. Once complete, you can sample immediately for TCLP. There no cure time and no
additives (e.g. water) or activator(s) need be mixed with the product for treatment
Some products are offered in slurry form, for these products please see Slurry Application.
EnviroBlend° Handling and Shelf Life
Store product in a dry, protected place. Do not allow water to penetrate impoundment, silo, or
Supersack. Significant or repeated exposure to precipitation may cause the product to clump or
form a crust.
With bulk piles of product, ground and top coverage tarps are recommended to keep product
dry from precipitation and from wicking moisture from the ground. For Supersacks, even
though sacks are water resistant and shrink-wrapped to pallets, tarping or covered storage of
Supersacks is recommended to prevent product exposure to precipitation or ponded water —
on the ground or on the sack — especially for prolonged (months) product staging time.

Note that there is no specific shelf life, but if EnviroBlend is kept completely dry with no
moisture exposure, it could last up to 6 months. However, any hydration could compromise
chemical effectiveness, so it is best to purchase product as needed, and not for long term
storage.
For additional information about EnviroBlend products for environmental treatment
applications, please contact Charis Gehret at [e-mail].
EnviroBlend® Application Guidelines and Storage and Handling - 2019