24014_SouthernResources_Source Area Removal Work Plan_20220721

Geosyntec Consultants of NC, P.C.
1300 South Mint St, Suite 300
Charlotte, North Carolina 28203
PH 704.227.0840
www.geosyntec.com
CAR220076
21 July 2022
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 Removal
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 Removal (Work Plan) at the former
Southern Resources Scrap Metal facility addressed as 3826 Raleigh Street, Charlotte, North
Carolina (“Site”) shown in Figure 1. 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.
Following soil, groundwater, and soil gas data collection at the Site, NCDEQ submitted an
email requesting a Contamination Source Area Investigation Work Plan on 28 September 2021.
Geosyntec submitted the requested document and performed a source area investigation in
January 2022 using photoionization detector (PID) readings and select confirmation soil
samples to find an approximate source area for volatile organic compounds (VOCs),
specifically trichloroethene (TCE) as the compound of most concern to future occupant risk.
The TCE source area and groundwater plume appear to follow a narrow path through the center
of the site flowing northwest as shown in Figures 2 and 3. The vapor plume, which is less
Geosyntec Consultants of NC, P.C.
1300 South Mint St, Suite 300
Charlotte, North Carolina 28203
PH 704.227.0840
www.geosyntec.com
CAR220076
controlled by gradient, also extends laterally from these soil and groundwater impacts. A “no-
build zone” was designated over the area with PID readings over 500 parts per million (ppm)
to leave this area open for potential remediation by NCDEQ (Figure 4). During a call on 25
April 2022, the PD indicated to Geosyntec of their intention to remediate the soil source area
through excavation and off-site disposal. The goal of this source removal action is to preclude
the need for NCDEQ to perform future excavation and to move forward with the current
redevelopment plans including construction in the “no-build zone”. The PD understands that a
vapor intrusion mitigation system (VIMS) will still be required in enclosed spaces of the
building such as elevators and stairwells and the buildings will be podium construction. This
Work Plan is intended to describe the objective and procedures for implementing an excavation
remedy to remove soil grossly impacted with TCE in the Area of Concern (AOC) shown on
Figure 4.
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.
Sincerely,
Amy Kenwell, PG (NC,SC)Kaitlyn Rhonehouse, PE (NC, VA, FL)
Project Geologist Principal
Prepared for
3826 Raleigh Street, LLC.
3826 Raleigh St
Charlotte, North Carolina 28206
WORK PLAN FOR BROWNFIELDS
SOURCE AREA REMOVAL
SOUTHERN RESOURCES
SCRAP METAL
CHARLOTTE, NC
BROWNFIELDS PROJECT #24014-20-060
Prepared by
Geosyntec Consultants of NC, P.C.
1300 South Mint St, Suite 300
Charlotte, North Carolina 28203
Project Number GC7573
July 2022
Geosyntec Consultants of NC, P.C.
1300 South Mint St, Suite 300
Charlotte, North Carolina 28203
PH 704.227.0840 www.geosyntec.com
CAR220076
TABLE OF CONTENTS
1.INTRODUCTION ..................................................................................................................... 3
1.1 Background ..............................................................................................................4
1.2 Environmental Site History ............................................................................................4
1.3 Site-Specific Soil Remediation Goals ............................................................................5
2.SCOPE OF WORK .................................................................................................................... 6
3.EXCAVATION AND SAMPLING METHODOLOGY .......................................................... 7
3.1 Source Area Removal ....................................................................................................7
3.2 Confirmation Sampling ..................................................................................................7
3.3 Optional Amendment Considerations ............................................................................8
3.3.1 Option 1 – Infiltration Gallery ....................................................................... 8
3.3.1 Option 2 – Amendment Application ............................................................. 9
3.4 Restoration .....................................................................................................................9
4.LABORATORY ANALYSIS ................................................................................................... 9
4.1 Laboratory Analysis .......................................................................................................9
4.2 Laboratory Reporting .....................................................................................................9
5. QUALITY ASSURANCE AND QUALITY CONTROL ........................................................ 10
5.1. Field and Laboratory Procedure QA/QC ...............................................................10
5.2. Chain of Custody QA/QC ......................................................................................10
6. INVESTIGATION DERIVED WASTE (IDW) MANAGEMENT ......................................... 10
7. REPORTING ............................................................................................................................ 11
8. REFERENCES ......................................................................................................................... 11
LIST OF TABLES
Table 1 Historical Soil Analytical Results for VOCs
LIST OF FIGURES
Figure 1 Site Location
Figure 2 Source Area Investigation PID Responses
Figure 3 Source Area Investigation TCE Concentrations in Groundwater
Figure 4 Proposed Excavation Area
LIST OF APPENDICES
Appendix A Risk Calculator Output
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1.INTRODUCTION
Geosyntec Consultants of NC, P.C. (Geosyntec), on behalf of 3826 Raleigh Street, LLC (“Client”),
has prepared this Work Plan for Source Area Removal (Work Plan) for the former Southern
Resources Scrap Metal facility located at 3826 Raleigh Street in Charlotte, North Carolina (“Site”)
as shown in Figure 1. The Site is assumed to include Mecklenburg County Parcels 09107201 and
09107201E which encompass approximately 4.8 acres. 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.
Following soil, groundwater, and soil gas data collection at the Site, NCDEQ submitted an email
requesting a Contamination Source Area Investigation Work Plan on 28 September 2021. The
intention of the work was to attempt to locate a potential source of identified volatile organic
compounds (VOCs) in the subsurface, specifically focused on trichloroethene (TCE). Geosyntec
submitted the requested document and performed a source area investigation in January 2022 using
photoionization detector (PID) readings and select soil and groundwater samples to find an
approximate source area. The TCE source area and groundwater plume appear to follow a narrow
path through the center of the Site flowing northwest as shown in Figures 2 and 3. The area of
subsurface vapor impacts, which is less controlled by gradient, also extends laterally from these
soil and groundwater impacts. A “no-build zone” was designated over the area with PID readings
over 500 parts per million (ppm) to leave this area open for potential remediation by NCDEQ
(Figure 4). During a call on 25 April 2022, the PD indicated to Geosyntec of their intention to
remediate the soil source area through excavation and off-site disposal of TCE-impacted soil. The
goal of this source removal action is to preclude the need for NCDEQ to perform future excavation
and to move forward with the current redevelopment plans including construction in the “no-build
zone”. The PD understands that a vapor intrusion mitigation system (VIMS) will still be required
in enclosed spaces of the building such as elevators and stairwells and the buildings will be podium
construction.
Thus, this Work Plan presents a summary of the previous soil VOC environmental assessment and
activities at the Site as well as a proposed excavation area to address the TCE source material. The
completion of the work presented herein is intended to support issuance of a finalized Brownfields
Agreement (BFA) without a “no-build zone” designation or intention of future soil removal by
NCDEQ and facilitate Site redevelopment according to current redevelopment plans.
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1.1 Background
The Site is located in Mecklenburg County, Charlotte, North Carolina (Figure 1) and consists of
two adjoining parcels (identified as Mecklenburg County parcel IDs 09107201 and 09107201E)
totaling approximately 4.8 acres. The current property land use is listed as industrial, and the PD
intends to redevelop the property for residential apartments with podium-style construction and
open-air parking on the ground level. The Site is primarily paved with concrete or asphalt, though
soils are exposed in some areas. The Site was used for scrap metal recycling, with the exception
of the eastern portion of the Site, which is unpaved and undeveloped. No supply wells are located
at the Site and the property is connected to a municipal water source.
The Site is located in a predominantly industrial area, though a multi-family residential complex
was recently constructed to the west, across East Craighead Road on the former Abernathy Lumber
property (Figure 2). The former Exposiac property to the North, across Raleigh Street, has been
owned and operated by Concrete Supply Company, LLC. since 1992. East of the Site is the former
Tarmac Virginia property owned by Triple Crown, LLC since 1999. Groundwater flow is
estimated to be to the northwest based on a study at the Metromont Corporation Facility less than
a quarter mile away and data collected during a source area investigation (Geosyntec, 2022).
The Site has operated as a scrap metal recycling facility since it was purchased from Rainbow
Properties, LLC in 2000. Historical records show that the Site operated as a metal scrapyard since
at least 1979, with construction-related companies operating the Site prior to that, since the 1950s
(Hart & Hickman, 2019). At the time of a 2019 Phase I Environmental Site Assessment (ESA),
three buildings were located on the Site: two warehouses of approximately 20,000 square feet (sq
ft) and 17,000 sq ft, and a former equipment maintenance building of approximately 2,200 sq ft
(Hart & Hickman, 2019). The remainder of the Site contained a weighing platform near the front
entrance, piles of scrap metal, and bins of household appliances. A railroad track crossed through
the eastern portion of the Site and extends to the Concrete Supply Company, LLC property to the
north. Southern Resources ceased scrap metal operations in 2020 and most scrap metal storage has
been removed from the Site though select buildings and permanent features remain at the time of
this Work Plan. The Site is currently used as a parking area for semi-trucks.
1.2 Environmental Site History
This section provides a brief summary of previous soil VOC assessment activities conducted at
the Site. A comprehensive summary which includes testing of other media including soil gas and
groundwater was included in the recent “Source Area, Soil, Groundwater, and Ambient Air
Assessment Report” (Geosyntec, 2022). Because this Work Plan is focused on addressing soil
impacts at the Site, a discussion of prior assessments and identified impacts as they pertain to other
media is not included.
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A Phase I ESA was performed by Hart and Hickman (H&H) in June 2019. This assessment
identified the former use of tetrachloroethene (PCE), TCE, and petroleum-based solvents at the
Site in the 1980s and 1990s.
A Phase II ESA was performed by Geosyntec in September 2020, focused on addressing the
findings of H&H’s Phase I ESA. Soil samples were distributed across the property including near
drum storage, near former transformers, and near the Site entrance/delivery area, as well as one
location in the undeveloped eastern portion of the Site (to serve as a background soil sample).
Phase II ESA sampling conducted at the Site revealed VOC, semi-volatile organic compound
(SVOC), and Resource Conservation and Recovery Act (RCRA) metal impacts to Site soil. One
deeper (collected at 9 feet below ground surface [ft bgs]) soil sample location (DPT-5 and DPT-
5A) revealed several petroleum and solvent-related detections. No other VOC or SVOC detections
were above the North Carolina Industrial Preliminary Soil Remediation Goals (PSRGs) in soil
samples. Arsenic and total chromium were detected in soil samples throughout the Site at
concentrations above PSRGs. The results of the Phase II ESA soil testing were evaluating using
the NCDEQ Risk Calculator (RC); excluding the DPT-5 area, RC results indicated no risk to
residents, recreators/trespassers, non-residential workers, or construction workers from Site soils.
A Source Area Investigation was performed in January 2022 per NCDEQ request to supplement
the data gathered from a Brownfields Soil and Soil Gas Site Assessment in March 2021
(Geosyntec, 2021). The goal of the source investigation was to find the source of elevated TCE
concentrations in groundwater and potentially attributing to observed elevated TCE concentrations
in soil gas during the March 2021 investigation. Throughout the investigations, PID readings were
collected at 36 locations from either soil cores or soil gas probes and these were used by NCBP to
develop the “no-build zone” which reflects a vapor plume of PID readings above 500 ppm (please
note, there is limited soil data to evaluate/verify if the no-build zone area represents the extent of
highly contaminated soil). Based on PID readings and confirmation samples during the soil and
groundwater investigation, DPT-11/TMW-4 and DPT-16/TMW-7 were the locations with the
highest concentrations of VOCs, particularly TCE, and number of exceedances of the PSRGs and
15A NCAC 02L Groundwater Standards (2L Standards). The TCE source area and groundwater
plume appears to follow a narrow path through the center of the Site extending northwest from
DPT-11/TMW-4 as shown in Figure 3. The extent of subsurface vapor impacts, which is less
controlled by gradient, also extends laterally from these soil and groundwater impacts. Based on
these results and the location of DPT-11/TMW-4 alongside a former building wall next to a ramp
entrance, the vicinity of DPT-11/TMW-4 is anticipated to be the TCE source area and is considered
the Area of Concern (AOC) for source removal (Figure 4).
1.3 Site-Specific Soil Remediation Goals
A Site-Specific Soil Remedial Goal (SSRG) was developed for TCE based on the NCDEQ RC.
Results of soil sampling to date were evaluated using the January 2022 version of the RC. Risk
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calculator summaries and outputs are included in Appendix A. Exposure factors and target risks
from EPA Regional Screening Level default values were used. For this evaluation, only risk from
TCE to a commercial/industrial receptor through soil combined pathways was taken into account
because the SSRG aims to remove gross TCE contamination, particularly in deeper soils, not bring
overall risk below acceptable levels. Based on the NCDEQ RC, a TCE concentration of 26
milligrams per kilogram (mg/kg) in soils is within acceptable risk for a commercial/industrial
receptor with a carcinogenic risk of 3.1E-06 and hazard index of 0.99.
One soil sampling location (DPT-11) has documented concentrations above 26 mg/kg. This Work
Plan presents the path forward for removal of materials in the vicinity of DPT-11 which will target
areas above the SSRG of 26 mg/kg as shown in Figure 4. This Work Plan is not intended to require
the PD to remediate TCE to the SSRG but rather to document the voluntary procedures that the
PD plans to undertake.
2. SCOPE OF WORK
Based on the voluntary intention of the PD to address soil source materials in the AOC, Geosyntec
proposes to plan and oversee excavation activities for the TCE source area removal in order to
support current redevelopment plans and obtain a final BFA without a “no-build zone” designation
or intention of future soil removal by NCDEQ. This Work Plan consists of source area removal
activities, confirmation sampling, and restoration.
The proposed scope of work has been developed in consideration of potential redevelopment of
the Site and seeks to:
1. Excavate the TCE source area to the extent of SSRGs defined in Section 1.3 or a voluntary
endpoint
2. Characterize excavated materials and dispose off-site or re-use on-site in accordance with
hazardous or non-hazardous waste regulations or NCBP concurrence, as appropriate
3. The PD may decide to install an infiltration gallery for future amendment application by
NCDEQ, if desired, to accelerate remediation of groundwater and/or amend the subsurface
with zero valent iron (ZVI) to chemically mediate reduction of chlorinated solvents
4. Support current redevelopment plans and the establishment of a BFA without a “no-build
zone” designation or intention of future soil removal by NCDEQ.
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3.EXCAVATION AND SAMPLING METHODOLOGY
3.1 Source Area Removal
Prior to excavation activities, underground utilities will be located through notification to a public
utility locating service (North Carolina 811). A private utility locator may also be subcontracted
to perform a geophysical survey to locate and mark subsurface utilities at the proposed area of
excavation. A remediation contractor (“Contractor”) will be retained to perform the excavation.
The Contractor will remove the asphalt and/or concrete cap above the excavation area, initially
defined as the vicinity of DPT-11/TMW-4. Throughout excavation activities, removed soils will
be screened for VOCs using a PID to preliminarily gage appropriate waste designation. Geosyntec
will evaluate PID headspace by containerizing a soil sample in a mason jar covered in tinfoil and
inserting the PID through the foil to measure VOC concentrations. Materials with elevated PID
readings (anticipated to be over 5,000 ppm but that number may be adjusted as we obtain
laboratory data and field observations) or visual signs of impacts will be segregated into roll-offs
from materials with lower PID readings which will be stockpiled on plastic. Stockpiles will also
be segregated by relative PID readings. Excavated materials will be containerized/stockpiled and
characterized as described in Section 6. If the excavation encounters free product, a buried tank or
drum, or the water table, the crew will stop work.
Note that the building adjacent to the AOC has been demolished down to the concrete slab,
therefore no provisions are included in this scope for stabilization of the excavation.
Source area removal is anticipated to reach a depth of 15 to 20 feet below ground surface (ft bgs)
based on PID readings at DPT-11/TMW-4. However, the total depth may change based on field
conditions such as PID screening, groundwater, or utilities. The depth to water is anticipated
between 17 and 22 ft bgs. The total area of removal will depend on PID screening and confirmation
sampling from base and sidewall samples to compare to the SSRG. Geosyntec anticipates the
initial excavation to begin at DPT-11/TMW-4 and extend towards DPT-16/TMW-7. Actual
volume and tonnage will depend on field conditions. When visual and olfactory (PID) observations
suggest that the extent of impacts above the SSRG has been excavated, soil samples will be
collected from each sidewall and the base of the excavation.
3.2 Confirmation Sampling
Sidewall confirmation samples will be collected from the mid-point of the four walls of the
excavated area with a sample for every 30 feet of wall length. Vertical confirmation sampling from
the base of the removal area will be conducted following material removal with a sample for every
250 sq ft of base. Rather than evenly space samples through the excavation, Geosyntec will use a
PID to help guide the confirmation sample collection. For each designated area of base or sidewall,
Geosyntec will collect 5 to 10 sub-samples to be screened with a PID. Geosyntec will then collect
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an analytical sample from the location with the highest PID reading for each base or sidewall
section.
Confirmation samples will be placed into laboratory supplied bottleware and submitted under
chain of custody for analysis of chlorinated VOCs using U.S. Environmental Protection Agency
(EPA) Method 8260 by a North Carolina-certified laboratory under expedited one-day turnaround
time. Soil sample results will be compared to the SSRG for TCE described in Section 1.3. In the
event that soil data indicate TCE concentrations greater than the SSRG in the lateral confirmation
samples, a set of step-out samples will be collected, and the soil and materials will be excavated
in the manner previously described. This process will be repeated until lateral extent confirmation
sample concentrations below the SSRG are achieved. If TCE concentrations greater than the SSRG
are detected in the vertical extent confirmation samples, the area represented by that sample will
be over-excavated unless the water table is encountered. A new vertical extent confirmation
sample will be collected from the bottom of the over-excavation area. This process will continue
until vertical extent confirmation samples indicating soil TCE concentrations below the SSRG are
obtained or the PD decides to end the voluntary removal.
Sampling equipment will be decontaminated prior to each sample location using distilled water
and Liquinox (LSASD, June 2020a). Locations of each sidewall confirmation sample and the
lateral extents of the excavation will be measured in the field using a global positioning system
(GPS) with sub-meter accuracy.
3.3 Optional Amendment Considerations
NCDEQ has expressed interest in application of a biological or chemical amendment to mediate
chemical reduction of the chlorinated solvents that could potentially be deeper in the subsurface
and groundwater. These amendments are typically most effective if the water table is reached
during excavation. If the water table is not reached, a dense mobile amendment could be selected
to migrate through the subsurface. Due to the uncertainty in the extent of the voluntary excavation,
and the design element of amendment application, the PD is considering the following options for
amendment.
3.3.1 Option 1 – Infiltration Gallery
The PD may voluntary construct an approximately 100-square foot infiltration gallery at the base
of the excavation in the vicinity of DPT-11/TMW-4. The infiltration gallery will be constructed
with 6 inches of gravel at the base of the excavation. Four 2-inch polyvinyl chloride (PVC)
injection points with 0.5-foot 0.01-inch slotted screens will be installed with screened intervals in
the gravel. Flush-mount covers will be installed over the PVC at ground surface to provide access
to the injection points should NCDEQ decide to implement an amendment in future. No design or
calculations, other than those presented here, will be done for construction of the infiltration
gallery.
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3.3.2 Option 2 – Amendment Application
The PD may voluntarily amend a portion of the source area (100-square feet) with 1,000 kilograms
of granular reducing agent zero valent iron (ZVI) to chemically mediate chemical reduction of the
chlorinated solvents that could potentially be deeper in the subsurface. This amendment would
only likely be effective if the water table is reached during excavation. Reducing agent ZVI will
be deployed at the bottom of the excavation pit and mixed with the fill material during Site
restoration. No design or calculations, other than those presented here, will be done for application
of the ZVI amendment.
3.4 Restoration
The cut/fill requirements for Site development are not yet known, therefore, the excavated area
will be backfilled to surrounding grade. Backfill characterization sampling for VOCs, SVOCs,
RCRA metals, and hexavalent chromium will be conducted by collecting one sample of proposed
backfill from a nearby quarry to test for environmental and geotechnical suitability. The results of
the backfill chemical testing will be provided to NCBP for approval prior to bringing imported fill
on-site. The Contractor will compact the backfill in 6-inch lifts and fill the excavation to existing
grade. Geotechnical testing of the compaction will not be required. Asphalt and/or concrete
removed for excavation activities will not be replaced under this Work Plan.
4. LABORATORY ANALYSIS
4.1 Laboratory Analysis
Collected soil samples will be placed in laboratory-provided sample containers with sufficient
volume, stored on ice and submitted to a North Carolina-certified environmental laboratory under
chain of custody procedures (Section 5.2). Confirmation soil samples will be analyzed by the
laboratory for VOCs by EPA Method 8260. The backfill sample will be analyzed by the laboratory
for VOCs by EPA Method 8260, SVOCs by EPA Method 8270, RCRA Metals by EPA Methods
6020 and 7471, and hexavalent chromium by EPA Method 7199 or 7196. Waste characterization
samples will be analyzed for Toxicity Characteristic Leaching Procedure (TCLP) or total VOCs,
SVOCs, RCRA Metals, and hexavalent chromium using the same methods as the backfill
sample, as described in Section 6.
4.2 Laboratory Reporting
Laboratory reporting limits (RLs) and method detection limits (MDLs) used by the selected North
Carolina-certified laboratory for methods will meet respective NCDEQ Division of Waste
Management (DWM), Inactive Hazardous Sites Branch (IHSB) protection of groundwater or
Residential PSRGs, whichever is lowest (January 2022) to the extent feasible. Concentrations
detected between the RL and MDL will be reported as estimated values and flagged in the
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laboratory analytical report with a “J”. Level II QA/QC will be reported in the analytical report
deliverables. The lab will be provided sufficient sample volume for Matrix Spike/Matrix Spike
Duplicate (MS/MSD) analysis.
5. QUALITY ASSURANCE AND QUALITY CONTROL
5.1. Field and Laboratory Procedure QA/QC
One blind duplicate confirmation soil sample per 20 samples will be collected and submitted
for laboratory analysis. QA/QC will also include one trip blank and one temperature blank (if
provided) in each cooler shipped to the laboratory.
5.2. Chain of Custody QA/QC
Geosyntec will initiate chain of custodies for soil samples in the field documenting sample
collection information including but not limited to:
The Sample Collector’s Name;
Project Information and Location;
Geosyntec Project Manager Contact Information;
Sample Identification Number;
Date and Time of Sample Collection;
Type of Analysis; and
Type and number of containers and associated preservative, if applicable.
Samples will remain in the custody of Geosyntec until they are ready for shipment. Geosyntec will
relinquish the samples and chain of custodies (noting date and time of relinquishment) to the
laboratory courier who will sign the chain of custody as receiver (noting date and time again)
unless samples are shipped directly to the laboratory, in which case sample coolers and the chain
of custodies will be sealed in an appropriate shipping container/box and sent to the address of the
selected laboratory.
A representative from the selected laboratory’s sample receiving will sign respective chains of
custody verifying receipt of the samples by each respective laboratory location. A copy of fully
executed chains of custody will be provided in the final laboratory analytical report deliverable.
6. INVESTIGATION DERIVED WASTE (IDW) MANAGEMENT
Excavated concrete, asphalt, and metal are expected to be eligible for disposal at a municipal waste
landfill. Excavated soils will be divided into lined roll off containers or lined and covered
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stockpiles based on field evidence of impacts (roughly segregated by PID response or visual signs
of impacts). Geosyntec will collect aliquots for composite TCLP EPA Method 1311 samples
from each roll off for VOCs, SVOCs, and RCRA metals as well as total hexavalent
chromium. From each stockpile, Geosyntec will collect aliquots for total VOCs by EPA
Method 8260, SVOCs by EPA Method 8270, RCRA Metals by EPA Methods 6020 and 7471,
and hexavalent chromium by EPA Method 7199. In each case, the aliquot with the highest PID
reading will be selected for the VOC analysis. Aliquots will be composited together by the
laboratory. Results will be compared to the Maximum Concentrations of Contaminants
leachate criteria for the Toxicity Characteristic compounds listed in Table 1 of Title 40 Code
of Federal Regulations (CFR) Part 261.24 using the direct results from TCLP analysis or the 20
times rule from totals analysis to evaluate if soils characterize as hazardous or nonhazardous
waste. Stockpile results will also be evaluated for potential on-site reuse using the NCDEQ
Risk Calculator, subject to NCBP approval.
If unsuitable for on-site reuse, IDW will be disposed of in general accordance with
nonhazardous or hazardous waste regulations, as appropriate. Soils which characterize as non-
hazardous will be loaded into trucks and disposed off-site at a Subtitle D non-hazardous waste
landfill. Soils which characterize as hazardous will be transported in lined, covered roll-offs and
disposed off-site at a hazardous waste landfill. Signed waste manifests will be provided to
NCBP.
7. REPORTING
Upon completion of the source area removal, Geosyntec will provide a written report that will
include a summary of the removal activities and confirmation sampling results, a figure
showing the boundaries of removal, a figure showing confirmation sampling locations, a table of
associated analytical data, and a table of material removal including tonnage and final
destination. Confirmation samples will be evaluated using the SSRG. Attachments to the
report will include the daily field reports (DFRs), waste manifests, and analytical reports.
Geosyntec will submit the results of the source area excavation to NCBP to support the
proposed redevelopment plans and the establishment of a BFA.
8. REFERENCES
Division of Waste Management, North Carolina Department of Environmental Quality (NC DEQ).
Vapor Intrusion Guidance, Version 2. March 2018.
Geosyntec. Phase II Environmental Assessment Report, Subject Site: Southern Resources, 3826
Raleigh Street, Charlotte, NC. September 2020.
Geosyntec. Brownfields Soil and Soil Gas Site Assessment Report: Southern Resources, 3826
Raleigh Street, Charlotte, NC. May 2021.
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Geosyntec. Source Area, Soil, Groundwater, and Ambient Air Assessment Report:Southern
Resources, 3826 Raleigh Street, Charlotte, NC. March 2022.
Hart and Hickman. Phase I ESA Industrial Property, Charlotte, North Carolina. June 2019.
Laboratory Services and Applied Science Division (LSASD), U.S. EPA. Field Equipment
Cleaning and Decontamination, LSASDPROC-205-R4. June 2020a.
Laboratory Services and Applied Science Division (LSASD), U.S. EPA. Soil Sampling,
LSASDPROC-300-R4. June 2020b.
TABLE
Table 1 - Historic Soil Analytical Data Summary - VOCsSouthern Resources 3826 Raleigh StCharlotte, North CarolinaDPT-1-6 DPT-2-3 DPT-3-9 DPT-4-1 DPT-5-8 DPT-5A-9 DPT-6-7 DPT-7-2 SS-01 SS-02 DPT-10 DPT-11 DPT-12 DPT-13 DPT-166391697222 18-18.5 8.5-9 10.5-11 21-21.5 7.5-810/3/2019 10/3/2019 10/3/2019 10/3/2019 10/3/2019 10/3/2019 10/3/2019 10/3/2019 3/24/2021 3/24/2021 1/18/2022 1/18/2022 1/18/2022 1/18/2022 1/21/2022AnalyteNCDEQ Residential Health Based PSRG (mg/kg) UnitsVolatile Organic Compounds (VOCs) by EPA Method 8260D1,1,1-trichloroethane1,700mg/kg 0.0012 U 0.0012 U 0.0012 U 0.0011 U 0.66 U 0.53 U 0.0012 U 0.001 U0.0016U0.0013U0.00065U 0.062U 0.001U 0.00066U0.0101,1,2,2-tetrachloroethane0.64mg/kg 0.0012 U 0.0012 U 0.0012 U 0.0011 U 0.66 U 0.53 U 0.0012 U 0.001 U0.0035U0.003U0.0018U0.30J0.0028U 0.0018U 0.0021U1,1,2-trichloroethane0.32mg/kg 0.0012 U 0.0012 U 0.0012 U 0.0011 U 0.66 U 0.53 U 0.0012 U 0.001 U0.0035U0.003U0.0014U 0.14U 0.0022U 0.0014U0.0101,1-dichloroethane3.8mg/kg 0.0021 U 0.0021 U 0.0022 U 0.002 U 1.2 U 0.94 U 0.0021 U 0.0018 U0.0012U0.00099U0.0012U 0.12U 0.0019U 0.0012U0.0034J1,1-dichloroethene48mg/kg 0.0012 U 0.0012 U 0.0012 U 0.0011 U 0.66 U 0.53 U 0.0012 U 0.001 U0.0035U0.003U0.0016U 0.16U 0.0026U 0.0017U0.0291,2,4 Trimethylbenzene63mg/kg 0.0012 U 0.0012 U 0.0012 U 0.0011 U115 85.100.0012 U 0.0010 UNA NA NA NA NA NA NA1,3,5 Trimethylbenzene56mg/kg 0.0012 U 0.0012 U 0.0012 U 0.0011 U58 44.000.0012 U 0.0010 UNA NA NA NA NA NA NAAcetone12,000mg/kg 0.12 U 0.12 U 0.12 U 0.11 U 66 U 53 U 0.12 U 0.1 U0.024J0.050.012U 1.2U0.160.012U0.031JBenzene1.2mg/kg 0.0015 U 0.0015 U 0.0015 U 0.0014 U16.1 0.89 J0.0015 U 0.0013 U0.0024J0.0008U0.0008U0.99 0.011 0.150.19Ucis-1,2-dichloroethene31mg/kg 0.0017 U 0.0017 U1.54 0.0016 U 0.91 U 0.73 U0.16800.0014 U0.0250.0025J0.11 8.3 0.056 0.56 1.2JEthylbenzene6.1mg/kg 0.0012 U 0.0012 U 0.0012 U 0.0011 U60.2 22.300.0012 U 0.0010 U0.00760.00073U0.0014U120.0022U0.031 1.7Isopropylbenzene410mg/kg 0.0012 U 0.0012 U 0.0012 U 0.0011 U17.9 8.07 0.0012 U 0.0010 U0.0021J0.00081U0.0021U2.60.0033U0.0026J 0.2m&pXylene120mg/kg 0.0013 U 0.0013 U 0.0014 U 0.0013 U134 69.000.0013 U 0.0011 UNA NA NA NA NA NA NANaphthalene2.1mg/kg 0.0024 U 0.0024 U 0.0025 U 0.0023 U17,300 11,400 0.0039 J0.0021 UNA NA NA NA NA NA NAn-Butylbenzene780mg/kg 0.0012 U 0.0012 U 0.0012 U 0.0011 U 0.66 U1.87 J0.0012 U 0.0010 UNA NA NA NA NA NA NAn-Propylbenzene780mg/kg 0.0012 U 0.0012 U 0.0012 U 0.0011 U4.65 2.86 0.0012 U 0.0010 UNA NA NA NA NA NA NAo Xylene140mg/kg 0.0012 U 0.0012 U 0.0012 U 0.0011 U58.3 29.800.0012 U 0.0010 UNA NA NA NA NA NA NAp-IsopropyltolueneNCmg/kg 0.0012 U 0.0012 U 0.0012 U 0.0011 U6.43 4.75 0.0012 U 0.0010 UNA NA NA NA NA NA NAsec-Butylbenzene1,600mg/kg 0.0012 U 0.0012 U 0.0012 U 0.0011 U2.6 J 1.90 J0.0012 U 0.0010 UNA NA NA NA NA NA NAStyrene1,248mg/kg 0.0012 U 0.0012 U 0.0012 U 0.0011 U18.8 13.600.0012 U 0.0010 U0.0014U0.0012U0.001U 0.098U 0.0016U 0.001U 0.0012UTetrachloroethene17mg/kg 0.0015 U 0.0015 U0.0021 J0.0015 U 0.84 U 0.68 U 0.0015 U 0.0013 U0.0035U0.003U0.0041J0.2U 0.0033U 0.0021U0.029Toluene990mg/kg 0.012 U 0.012 U 0.012 U 0.011 U37.8 12.2 0.012 U 0.01 U0.0039J0.0012U 0.00092U9.8 0.0039J 0.13 1.3trans-1,2-dichloroethene15mg/kg 0.0012 U 0.0012 U0.0271 0.0011 U 0.66 U 0.53 U 0.0012 U 0.0010 U0.0035U0.003U0.00069U 0.066U 0.0011U 0.0007U0.042Trichloroethene0.87mg/kg0.0636 0.0012 J 0.309 J0.0011 U 0.66 U9.68 0.0091 0.0010 U0.012 0.084 0.89 150J 0.15 0.0084 14Vinyl chloride0.061mg/kg 0.0012 U0.0018 J 0.0142 0.0033 J0.66 U 0.53 U0.0017 J0.0010 U 0.0035U 0.003U0.0016U0.16U0.0026U0.038 0.014Xylene Total120mg/kg 0.0025 U 0.0025 U 0.0026 U 0.0024 U193 98.800.0025 U 0.0022 U0.011J0.0023U0.0012U47J 0.0021J 0.13 8.8Notes:3. Bold concentrations are detected above the laboratory Method Detection Limit (MDL).4. Italicized values indicate that the RL is greater than the Residential PSRG.5. Concentrations highlighted in yellow indicate detected exceedances of the Residential PSRGs.7. mg/kg indicates milligrams per kilogram.8. ft bgs indicates feet below ground surface.10. U indicates analyte not detected above the MDL with the RL indicated.11. NA indicates the compound was not analyzed.12. NC indicates there is no applicable PSRG.1. Residential health based preliminary soil remediation goals (PSRGs) from North Carolina Department of Environmental Quality (NCDEQ), 2021.2. Only constituents that were detected above the Method Detection Limit (MDL) in at least one soil sample or who's Reporting Limit (RL) is above screening criteria are included in this table.9. J indicates estimated concentration above the laboratory MDL and below the RL or analyzed outside Soil Sample IDSample Depth (ft bgs)Sample DateGeosyntec Consultants of NC, PC Page 1 of 1July 2022
FIGURES
Sources: Esri, HERE, Garmin, Intermap, increment P Corp., GEBCO,USGS, FAO, NPS, NRCAN, GeoBase, IGN, Kadaster NL, OrdnanceSurvey, Esri Japan, METI, Esri China (Hong Kong), (c) OpenStreetMap
Site Location
3826 Raleigh StreetCharlotte, Mecklenburg County, North Carolina (Mecklenburg County Parcel No: 09107201)Path: (Charlotte-01\) P:\GIS\Projects\S\Southern Resources\MXD\Source Area Removal\F1_Site Location.mxd 09 May 2022 AMcLane³
Figure
1
Notes:1. Basemap imagery provided by ArcMap10.5, ESRI2. Parcel boundary information obtained from Mecklenburg County,NC online GIS database
Legend
Site Boundary
0 2,000 4,000Feet
Approximate Site Location
Charlotte, NC July 2022
!(
!(
!(
!(
!(
!(
!(
!(
!(DPT-6[134.0]
SG-12[1,550]
DPT-11/TMW-4[846.3]
DPT-13/TMW-5[66.9]
DPT-15/TMW-6[12.9]
DPT-9[99.4]
DPT-17[163.6]
DPT-12[545.4]
DPT-14[0.6]
DPT-10[692.2]
DPT-16/TMW-7[14,783]
PZ-1[0.0]
PZ-2[2.3]
PZ-3[0.0]
SG-01[19]
SG-02[34]
SG-04[10]
SG-03[15]
SG-06[370]
SG-05[125]SG-07[7.6]
SG-09[45]SG-08[800]
SG-11[720]
SG-10[1,100]
SG-13[38]
SG-14[6.5]
SG-16[2.65]
SG-17[3.1]
DPT-4[1.8]
DPT-8[0.7]DPT-7[1.0]
DPT-5/5A[284.6]
DPT-2/TW-2[4.4]DPT-3/TW-3[5.8]
DPT-1/TW-1[112.3]
Source Area Investigation PID Responses3826 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 Area Investigation\F3_PID Results_r2.mxd 21 June 2022 AKenwell³
Figure
0 150 300Feet
Triple Crown LLC(Former Tarmac Virginia)
Former Abernathy Lumber
Former Celanese
Concrete Supply(Former Exposiac)
Former Exposiac
NC Railroad Company
E

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Legend
PID Readings
!(<50 ppm
!(50-100 ppm
!(100-500 ppm
!(500-1,000 ppm
!(>1,000 ppm
Proposed No-Build Zone
Proposed Building Footprint
Site Boundary
Notes:1. Locations shown on figure are approximate.2. Parcel boundary information obtained from Mecklenburg County, NConline GIS database.3. Photoionization detector (PID) response values are in units of parts permillion (ppm).4. World Imagery source: Esri, DigitalGlobe, GeoEye, Earthstar Geographics,CNES/Airbus DS, USDA, USGS, AeroGRID, IGN, and the GIS UserCommunity.
Estimated Groundwater Flow Direction
Charlotte, NC July 2022 2
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DPT-11/TMW-49,700
DPT-13/TMW-50.4 JDPT-15/TMW-693
DPT-16/TMW-73,000
DPT-2/TW-252 DPT-3/TW-3422
DPT-1/TW-119,400
Source: Esri, DigitalGlobe, GeoEye, Earthstar Geographics,CNES/Airbus DS, USDA, USGS, AeroGRID, IGN, and the GIS User
TCE Concentrations in Groundwater3826 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 Area Investigation\F4_GW Results.mxd 24 February 2022 AKenwell³
Figure
3Charlotte, NC July 2022
0 150 300Feet
Triple Crown LLC(Former Tarmac Virginia)
Former Abernathy Lumber
Former Celanese
Concrete Supply(Former Exposiac)
Former Exposiac
NC Railroad Company
E

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Legend
#V Jan 2022 Ambient Air
ED Jan 2022 Composite Soil Sample
ED Jan 2022 Grab Soil Sample
&<Jan 2022 Temporary Well
@A Mar 21 Soil Gas Sample
&>Mar 21 Piezometer
@A Oct 2019 Temporary Well
ED Oct 2019 Grab Soil Sample
Proposed Building Footprint
Site Boundary
Notes:1. Locations shown on figure are approximate.2. Parcel boundary information obtained from Mecklenburg County, NConline GIS database.3. J indicates estiamted concentration detected above the method detectionlimit but below the reporting limit.4. Trichloroethene (TCE) concentrations shown are in micrograms per liter(µg/L).5. World Imagery source: Esri, DigitalGlobe, GeoEye, Earthstar Geographics,CNES/Airbus DS, USDA, USGS, AeroGRID, IGN, and the GIS User
Estimated Groundwater Flow Direction
Source: Esri, DigitalGlobe, GeoEye, Earthstar Geographics,GIS User
Proposed Excavation Area3826 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 Area Removal\F4_ExcavationZone.mxd 07 June 2022 AKenwell³
Figure
4
0 150 300Feet
Triple Crown LLC(Former Tarmac Virginia)
Former Abernathy Lumber
Former Celanese
Concrete Supply(Former Exposiac)
Former Exposiac
NC Railroad Company
E

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Legend
No Build Zone
Proposed Excavation Area
Proposed Building Footprint
Site Boundary
Notes:1. Locations shown on figure are approximate.2. Parcel boundary information obtained from Mecklenburg County, NC onlineGIS database.3. World Imagery source: Esri, DigitalGlobe, GeoEye, Earthstar Geographics,CNES/Airbus DS, USDA, USGS, AeroGRID, IGN, and the GIS UserCommunity.
Estimated Groundwater Flow Direction
Charlotte, NC July 2022
APPENDIX A - NCDEQ
RISK CALCULATOR
Version Date:
Basis:
Site Name:
Site Address:
DEQ Section:
Site ID:
Exposure Unit ID:
Submittal Date:
Reviewed By:
Prepared By:Amy Kenwell
Theoretical TCE
North Carolina Department of Environmental Quality
Risk Calculator
Former Southern Resources Scrap Metal
3826 Raleigh St, Charlotte, NC
Brownfields
24014-20-060
January 2022
November 2021 EPA RSL Table
North Carolina DEQ Risk Calculator
Exposure Point ConcentrationsVersion Date: January 2022Basis: November 2021 EPA RSL TableSite ID: 24014-20-060Exposure Unit ID: Theoretical TCENOTE: If the chemical list is changed from a prior calculator run, remember to select "See All Chemicals" on the data output sheet or newly added chemicals will not be included in risk calculationsExposure Point Concentration (mg/kg)Notes:CAS NumberChemicalFor the chemicals highlighted in blue, data entry notes are provided in the PSRG Table link on the Main MenuMinimum Concentration (Qualifier)Maximum Concentration (Qualifier)UnitsLocation of Maximum ConcentrationDetection FrequencyRange of Detection LimitsConcentration Used for ScreeningBackground ValueScreening Toxicity Value (Screening Level) (n/c)Potential ARAR/TBC ValuePotential ARAR/TBC SourceCOPC Flag (Y/N)Rationale for Selection or Deletion2679-01-6Trichloroethylenemg/kgInput Form 2ASoil Exposure Point Concentration TableDescription of Exposure Point Concentration Selection:North Carolina DEQ Risk Calculator
Risk for Individual Pathways Output Form 1A
Version Date: January 2022
Basis: November 2021 EPA RSL Table
Site ID: 24014-20-060
Exposure Unit ID: Theoretical TCE
Receptor Pathway Carcinogenic
Risk Hazard Index Risk exceeded?
Soil NC NC NC
Groundwater Use*NC NC NC
Soil 3.1E-06 9.9E-01 NO
Groundwater Use*NC NC NC
Construction Worker Soil NC NC NC
Soil NC NC NC
Surface Water*NC NC NC
Receptor Pathway Carcinogenic
Risk Hazard Index Risk exceeded?
Groundwater to Indoor Air NC NC NC
Soil Gas to Indoor Air NC NC NC
Indoor Air NC NC NC
Groundwater to Indoor Air NC NC NC
Soil Gas to Indoor Air NC NC NC
Indoor Air NC NC NC
Pathway Source
Source Soil NC
Source Groundwater NC
Source Soil NC
Source Groundwater NC
3. NM = Not Modeled
4. NC = Pathway not calculated
DIRECT CONTACT SOIL AND WATER CALCULATORS
Resident
Non-Residential Worker
Recreator/Trespasser
2. * = If concentrations in groundwater exceed the NC 2L Standards or IMAC, or concentrations in surface water exceed the
NC 2B Standards, appropriate remediation and/or institutional control measures will be necessary to be eligible for a risk-based
closure.
Surface Water Exceedence of 2B at Receptor?
Exceedence of 2B at Receptor?
VAPOR INTRUSION CALCULATORS
Resident
Non-Residential Worker
CONTAMINANT MIGRATION CALCULATORS
Target Receptor Concentrations Exceeded?
Groundwater Exceedence of 2L at Receptor?
Exceedence of 2L at Receptor?
1. If lead concentrations were entered in the exposure point concentration tables, see the individual calculator sheets for lead
concentrations in comparison to screening levels. Note that lead is not included in cumulative risk calculations.
Notes:
North Carolina DEQ Risk Calculator
DEQ Risk Calculator - Direct Contact - Non-Residential Worker Soil
Version Date: January 2022
Basis: November 2021 EPA RSL Table
Site ID: 24014-20-060
Exposure Unit ID: Theoretical TCE
* - Note that inhalation on this calculator refers to outdoor inhalation of volatiles and particulates, not indoor inhalation associated with vapor intrusion.
CAS #Chemical Name:
Ingestion
Concentration
(mg/kg)
Dermal
Concentration
(mg/kg)
Inhalation
Concentration
(mg/kg)*
Ingestion
Carcinogenic
Risk
Dermal
Carcinogenic
Risk
Inhalation
Carcinogenic
Risk
Calculated
Carcinogenic
Risk
Ingestion
Hazard
Quotient
Dermal
Hazard
Quotient
Inhalation
Hazard
Quotient
Calculated
Non-
Carcinogenic
Hazard
Quotient
79-01-6 Trichloroethylene 26 26 26 3.7E-07 2.8E-06 3.1E-06 4.5E-02 9.4E-01 9.9E-01
Cumulative:3.1E-06 9.9E-01
Output Form 2C
** - Note that the EPA has no consensus on reference dose or cancer slope factor values for lead, therefore it is not possible to calculate cancer risk or hazard quotient. Lead concentrations are compared to the EPA screening level of 800
mg/kg for commercial/industrial soil.
North Carolina DEQ Risk Calculator