23080_Almont Shipping II_AWPSoil_20220713

Geosyntec
consultants
Geosyntec Consultants of NC, PC
Ms. Kathleen Markey
Brownfield Program Project Manager
North Carolina Department of Environmental Quality
1646 Mail Service Center
Raleigh, North Carolina 27699-1646
Subject: Work Plan for Adjacent Property Soil Sampling
Geosyntec Consultants of NC, P.C.
314 Walnut Street, Suite 200
Wilmington, NC 28401
PH 910.372.6402
www.geosyntec.com
13 July 2022
Site: Almont Shipping II
19 & 41 Harnett Street, Wilmington, North Carolina (New Hanover County
Parcels No. R04716-001-026-000 & R04712-002-001-000)
NCBP No. 23080-19-065
Dear Ms. Markey:
On behalf of Wilmington Riverfront Holding Company, LLC (new/current ownership entity),
formerly Wilmington Waterfront Property Owner, LLC (the Prospective Developer [PD]),
Geosyntec Consultants of NC, P.C. (Geosyntec) has prepared this Work Plan associated with the
above -referenced North Carolina Brownfields Program (NCBP) property located at 19 and 41
Harnett Street, Wilmington, NC (the "Site"). The North Carolina Department of Environmental
Quality (NCDEQ) approved Wilmington Waterfront Property Owner, LLC's 7 January 2020
Brownfields Property Application (BPA) in an 18 February Letter of Eligibility (LOE). During
redevelopment activities, on 10 February 2022, soil from the Site was exported and relocated to a
neighboring property (New Hanover County Parcel No. R04712-003-001-000; "PPD Property").
The soil movement was not authorized by the PD or the adjacent property owner, PPD, Inc (PPD).
The Site soils have been previously sampled and deemed suitable for residential use by NC13P.
The exported soil was subsequently removed and returned to the Site. NCBP was notified and
subsequently requested sampling be performed to evaluate how this soil transfer may have
impacted the PPD Property. This Work Plan presents proposed soil sampling to assess current
conditions at the PPD Property and to evaluate if the unauthorized import of Site soils affected the
risk at the PPD Property. We look forward to your review and approval of this Work Plan. Please
do not hesitate to contact Abigail (Abby) Wesley (910.372.6407 or [e-mail])
if you have any questions.
Sincerely, k
Abigail Wesley Kaitlyn Rhonehouse, PE (NC, VA, FL)
Senior Staff Professional Principal
Copies to: William Edwards, Sean Curtin — Kettler Enterprises, Inc.
Mary Katherine Stukes — Moore & VanAllen
Dave Waters — PPD, Inc.
Scott Werley — ECS Southeast, LLP

Prepared for
Wilmington Riverfront Property Owner, LLC
8255 Greensboro Drive, Suite 200
McLean, Virginia 22102
WORK PLAN FOR
ADJACENT PROPERTY SOIL SAMPLING
New Hanover County Parcel No. R04716-001-026-000
& R04712-002-001-000
19 & 41 Harnett Street, Wilmington, North Carolina
Brownfields Project: Almont Shipping II
NCBP No. 23080-19-065
Prepared by
Geosynteccl
consultants
Geosyntec Consultants of NC, P.C.
Geosyntec Consultants of NC, P.C.
314 Walnut Street, Suite 200
Wilmington, North Carolina 28401
Project Number GN7035
July 2022

PROFESSIONAL ENGINEER SIGNATURE
I, Kaitl n Rlionehouse, a Licensed Engineer for Geosyntec Consultants of NC, P.C., do certify
that the information in this report is correct and accurate to the best of my knowledge.
Geosyntec Consultants of NC_ P.C. is licensed to practice engineering in North Carolina. The
certification number (Firm's License Number) is C-3500.
Geosyntec Consultants of NC P.C. is licensed to practice geology in North Carolina. The
certification number (Firm's License Number) is C-295.
Kaitlyn Rhonehouse, PE
Principal
North Carolina P.E. License No. 043548
Expiration Date: 31 December 2022
Geosyntec Consultants of NC, PC
314 Walnut Street, Suite 200
Wilmington, NC 28401
Telephone: [phone]

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Geosyntec Consultants of NC, P.C.
TABLE OF CONTENTS
1. INTRODUCTION................................................................................................................... I
1.1. Site Environmental History.............................................................................................. 1
1.2. Work Plan Objectives....................................................................................................... 2
2. SCOPE OF WORK................................................................................................................. 2
3. SAMPLING METHODOLOGY............................................................................................. 3
3.1. Health and Safety Planning.............................................................................................. 3
3.2. Soil Sampling................................................................................................................... 3
3.3. Decontamination.............................................................................................................. 4
3.4. Soil Sample Locating....................................................................................................... 4
4. LABORATORY ANALYSIS................................................................................................. 4
4.1. Laboratory Analysis......................................................................................................... 4
4.2. Laboratory Reporting....................................................................................................... 4
5. QUALITY ASSURANCE/QUALITY CONTROL................................................................ 4
5.1. Field and Laboratory Procedure QA/QC......................................................................... 4
5.2. Chain of Custody QA/QC................................................................................................ 5
6. INVESTIGATION -DERIVED WASTE (IDW) MANAGEMENT ....................................... 5
7. REPORTING...........................................................................................................................5
LIST OF TABLES
Table 1 Proposed Sampling Plan
LIST OF FIGURES
Figure 1 Proposed Soil Sampling Locations
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1. INTRODUCTION
Geosyntec Consultants of NC, P.C. (Geosyntec), on behalf of Wilmington Riverfront Holding
Company, LLC (new/current ownership entity), formerly Wilmington Waterfront Property Owner,
LLC (the Prospective Developer [PD]), prepared this Work Plan for Adjacent Property Soil
Sampling (the "Work Plan") for the parcel (New Hanover County Parcel ID: R04712-003-001-
000; "PPD Property") owned by PPD, Inc. (PPD) adjacent to the Site. The Site is located at 19 and
41 Harnett Street (New Hanover County Parcel IDs: R04716-001-026-000 and R04712-002-001,
respectively), Wilmington, North Carolina (these two parcels are collectively referred to herein as
the "Site" and the "Almont Shipping II" Brownfields Property (Figure 1).
The North Carolina Department of Environmental Quality (NCDEQ) approved Wilmington
Waterfront Property Owner, LLC's 7 January 2020 Brownfields Property Application (BPA) in a
18 February 2020 Letter of Eligibility (LOE; NCBP No. 23080-19-065). During redevelopment
activities, soil was exported from the Site and placed on the PPD Property on 10 February 2022
and spread across a portion of the PPD Property. Neither the PD, PPD, nor Geosyntec were aware
of, or authorized, the soil movement before it occurred. The Site soils have been previously
sampled and deemed suitable for residential use by NCBP. The unauthorized imported soil was
subsequently removed from the PPD Property and returned to the Site. Due to the nature of soil
relocation and the soil spreading conducted, we understand it was not considered feasible to
confirm the removal of all of the Site soils from the PPD Property without undercutting. Therefore,
on 6 May 2022, NCBP requested additional soil sampling on the PPD Property to evaluate
potential impacts of the unauthorized soil transfer to the PPD Property in its current condition.
Geosyntec has therefore prepared this Work Plan to propose soil sampling at the PPD Property.
1.1. Site Environmental History
The Site and surrounding area operated as the former Almont Shipping terminal from 1870 until
2005. A BFA was executed between the NCBP and Riverfront Holdings II, LLC on 23 June 2008
for the Almont Shipping Brownfields Property (NCBP No. 10040-06-065; the 19 Harnett Street
parcel and northwestern of portion of the 41 Harnett St. parcel are included in the Almont Shipping
BFA until a new BFA is executed for the Site). The BFA was amended in 2014 to include an
additional land tract owned by CSX. The Site received eligibility for entry into the NCBP on 18
February 2020 to establish a new, stand-alone BFA for only the two Harnett Street parcels.
Multiple environmental assessments have been conducted at the Site prior to and during the
Brownfields Program process. During these assessments, Site soils were sampled, screened against
NCDEQ Residential Preliminary Soil Remediation Goals and evaluated through a risk assessment
using the NCDEQ Risk Calculator. The on -site soil (in addition to imported fill used during Site
redevelopment) was determined to be suitable for residential use by NCBP. Redevelopment
GN7035 1 July 2022

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activities, under the approved Environmental Management Plan (EMP), began in September 2021
and continue to date. To aid in the redevelopment process, the PD negotiated a license agreement
with PPD for temporary access to use portions of the PPD Property for equipment laydown and a
work trailer. The license to use the PPD Property was subject to certain restrictions, including
explicit prohibitions against: (i) excavation of any sort on the PPD Property; (ii) disturbance of the
soil on the PPD Property; and (iii) use of any groundwater on the PPD Property. As this space was
being prepared for use, the PD's contractor, without PD's, PPD's, or Geosyntec's knowledge or
consent, moved approximately 300 cubic yards of soil from the Brownfields Site to the PPD
Property on 10 February 2022, intending to use the material to correct the grade required for heavy
construction equipment. Once the PD and PPD were aware that Site soils had been exported to the
PPD Property, the exported soil was removed to the best of the contractor's ability and returned to
the Site on 14 February 2022.
The returned soil was stockpiled at the Site and sampled (one grab sample) and analyzed for
volatile organic compounds (VOCs), semi -volatile organic compounds (SVOCs), and the eight
Resource Conservation and Recovery Act (RCRA) metals. A risk assessment was performed for
the soil sample results using NCDEQ's Risk Calculator (NCDEQ, 2022). Based on the soil sample
concentrations, the calculated carcinogenic and hazard indices were below the thresholds for
residential use and consistent with prior on -site sampling of soil and imported fill to the Site. The
remainder of this Work Plan provides a proposed scope of work to complete soil sampling at the
PPD Property as requested by NCBP.
1.2. Work Plan Objectives
The scope of work described herein was prepared to meet the following objectives:
• Obtain soil data to establish background soil concentrations at the PPD Property
• Obtain soil data to assess if the Site soils have affected the PPD Property soil and/or altered
the risk
This Work Plan was prepared in general accordance with the NCBP Environmental Site
Assessment Work Plan Minimum Requirements Checklist (November 2018).
2. SCOPE OF WORK
The scope of work includes the collection of ten composite soil samples as shown on Figure 1.
Composite soil samples (comprised of five aliquots) will be collected from six zones
(approximately 5,000 square feet each) on the PPD Property; four (Z1-Z4) that comprise the area
where Site soils were located and two (Z5-Z6) which are located outside of the former laydown
area (Figure 1) and intended to serve as background soil samples. Two samples, one from 0-0.5
feet below ground surface (ft bgs) and one from 0.5-2 ft bgs, will be obtained from each of the
GN7035 2 July 2022

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zones in the Site soil area. The shallower sample is anticipated to be representative of the residual
Site soils (if present) and the deeper sample should be representative of pre-existing PPD Property
site conditions in the zone. Composite soil samples will also be collected from the zone outside of
the area where Site soils were placed in order to further establish pre-existing background
conditions on the PPD Property.
Results from the three groups (shallow samples in zones Z 1-Z4, deeper samples in zones Z 1-Z4,
and samples from zones Z5-Z6) will be compared to evaluate potential impacts from the soil
transfer to the PPD property. Risk assessments for each of the three groups of samples will also be
performed to determine if potentially remaining Site soils have affected the risk at the PPD
property in its current condition. Soil sample results and/or calculated risk for the samples
representative of potentially remaining Site soils (shallow Z1-Z4 samples) that is comparable to,
or less than, the risk for the samples representative of PPD property background conditions (deeper
Z1-Z4 samples and Z5-Z6 samples) would theoretically indicate that the PPD property, in its
current condition, was not environmentally impacted by the Site soil transfer.
3. SAMPLING METHODOLOGY
Sampling procedures will generally follow U.S. Environmental Protection Agency (USEPA)
Region IV Science and Ecosystem Support Division (SESD) Operating Procedures. Additional
media specific procedures are discussed further below.
3.1. Health and Safety Planning
Prior to the start of work, Geosyntec will prepare a site -specific Health and Safety Task Hazard
Analysis in general accordance with the Occupation Safety and Health Administration (OSHA)
rules (29 CFR 1910.120). To address potential underground utilities, Geosyntec will contact the
North Carolina 811 one -call system a minimum of 72 business hours before beginning the
assessment to notify member utilities of the subsurface work.
3.2. Soil Sampling
Thirty (30) borings (located in Z1-Z6) will be advanced to 2 ft bgs using a hand auger to allow for
the collection of 10 composite soil samples comprised of five aliquots within each zone (Figure
1). Soil from each boring will be collected, visually inspected, screened with a photoionization
detector (PID) and classified for lithology. Aliquots will be homogenized (by zone) in a
decontaminated stainless -steel bowl. One discrete grab sample will be collected for VOC analysis
from the soil boring within each zone with the highest field screening results. The discrete grab
samples for VOC analysis will not be collected from composited soil.
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Collected samples will be submitted under chain of custody to a North Carolina -certified
laboratory for analysis of VOCs by EPA Method 8260, SVOCs by EPA Method 8270, and eight
RCRA metals plus hexavalent chromium by EPA Method 6010/7471 or 6020/7471 and 7199.One
laboratory blind duplicate sample will be collected. Soil samples (II total) will be shipped
overnight under chain of custody and analyzed under a standard 10-day turnaround time.
3.3. Decontamination
Disposable equipment will be used as practical. However, as needed, equipment will be
decontaminated using an initial municipal water rinse followed by cleaning with Alconox® (or
equivalent) and final rinse of distilled water.
3.4. Soil Sample Locating
A handheld GPS unit and field measurements will be used to collect the approximate coordinates
of the soil sample locations within each zone.
4. LABORATORY ANALYSIS
4.1. Laboratory Analysis
Following collection, soil sample containers will be sealed and submitted to a fixed -base North
Carolina -certified laboratory following chain of custody procedures (Section 5.2).
4.2. Laboratory Reporting
Laboratory reporting limits (RLs) and method detection limits (MDLs) used by the selected
NELAP-certified laboratory for methods will meet respective NCDEQ Preliminary Soil
Remediation Goals (PSRGs) to the extent feasible. Concentrations detected between the RL and
MDL will be reported as estimated values and flagged in the laboratory analytical report with a
"J". Level II Quality Assurance (QA)/Quality Control (QC) will be reported in the analytical
report deliverable.
5. QUALITY ASSURANCE/QUALITY CONTROL
5.1. Field and Laboratory Procedure QA/QC
One duplicate composite soil sample and one discrete VOC sample will be collected and submitted
for laboratory analysis as indicated in the sections above.
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5.2. Chain of Custody QA/QC
Geosyntec will initiate chain of custodies for 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.
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).
Geosyntec will retain a copy of the chain of custodies signed by the courier.
Sample shipments and 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
IDW will be screened at each hand -augured soil boring with a PID. Soil staining and/or odors will
be recorded in the field. If visible soil staining and/or odors are detected, IDW will be containerized
in labeled 55-gallon steel drums and stored in a designated area of the Site pending disposal based
on laboratory results. If no staining and/or odors are observed, IDW will be redistributed on PPD
Property.
7. REPORTING
Upon receipt of laboratory results, Geosyntec will prepare a written report summarizing: (i) the
scope of work executed, and sampling methodologies performed, (ii) soil sample laboratory
analytical results; (iii) recommended IDW management procedures; and (iv) findings, conclusions
and recommendations. Tabulated soil sample results compared to NCDEQ PSRGs (January 2022)
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and figures depicting the final sample locations will be included to the report. Analytical results
will be evaluated using the January 2022 (or most recent) version of the NCDEQ Risk Calculator
as appropriate. As indicated above, three data sets will be compared: the surficial soil in the
unauthorized import area (Z 1-Z4), the deeper soil in the unauthorized import area (Z 1-Z4), and
soil from the undisturbed (i.e., background) areas (Z5-Z6). The report will include Geosyntec'
Corporate Professional Engineer (PE)/Professional Geology (PG) License Numbers and will be
sealed and signed by the licensed PE or PG who oversaw the work.
GN7035 6 July 2022

FIGURE

/ 1
a Z5 , Z6
r i
L
r ,op O
A ['
i
Z4
t. V-1i
Ae
Harnett Street
-
Legend Notes:
1. Service Layer Credits: Source: Esri, Maxar, GeoEye, Earthstar Proposed Soil Sampling Locations
O Proposed Composite Soil Sample Aliquot Locations Geographics, CNES/Airbus IDS, USDA, USGS, AeroGRID, IGN, and the N
GIs User Community Harnett Street
Almont Shipping 11 Boundary PPD 2. The locations of the former contractor Iaydown area and area of Wilmington, NC
exported soil were provided by ECS Southeast, LLP.
Parcel Boundary 3. The exported soil was removed by 14 February 2022. GeOSiCeC Figure
4. The portion of the PPD Parcel illustrated is New Hanover County Parcel g
Area of Potentially Remaining Exported Soil Number R0071 2-003-001 -000. Consultants
Geoswtx C—W— of NC, Y.C.
r Former Contractor Laydown Area ° 10Feet GN7035 I July 2022
N:\K\Kettler\GN7035 Kettler Harnett St\7.0 GIS\MXD\F1 2022 PPD Sampling Plan.mxd 6/6/2022 2:18:41 PM

TABLE

Table 1
Proposed Sampling Plan
Almont Shipping II
Wilmington, NC
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Boring Total
Number
Proposed
Zone
Depth
of
Sample
Proposed Samples
Sample Analyses
iq
(ft bgs)
Samples
Location IDs
Z1-0-0.5
One sample from the 0-0.5 ft bgs
VOCs, SVOCs, and 8 RCRA metals plus hexavalent
Z1
2
2
Z1-0.5-2
interval and one sample fron the
chromium via EPA Methods 8260, 8270, 6010/7471 or
0.5-2.0 ft bgs interval
6020/7471, and 7199 (respectively)
Z2-0-0..0
One sample from the 0-0.5 ft bgs
VOCs, SVOCs, and 8 RCRA metals plus hexavalent
Z2
2
2
Z2-0.5-2
interval and one sample fron the
chromium via EPA Methods 8260, 8270, 6010/7471 or
0.5-2.0 ft bgs interval
6020/7471, and 7199 (respectively)
Z3-0-0.5
One sample from the 0-0.5 ft bgs
VOCs, SVOCs, and 8 RCRA metals plus hexavalent
Z3
2
2
Z3-0.5-2.0
interval and one sample fron the
chromium via EPA Methods 8260, 8270, 6010/7471 or
0.5-2.0 ft bgs interval
6020/7471, and 7199 (respectively)
One duplicate sample from the 0.5-
VOCs, SVOCs, and 8 RCRA metals plus hexavalent
Z3
2
1
DUP
2.0 ft bgs interval within Z3
chromium via EPA Methods 8260, 8270, 6010/7471 or
6020/7471, and 7199 (respectively)
Z4-0-0.5
One sample from the 0-0.5 ft bgs
VOCs, SVOCs, and 8 RCRA metals plus hexavalent
Z4
2
2
Z4-0.5-2.0
interval and one sample fron the
chromium via EPA Methods 8260, 8270, 6010/7471 or
0.5-2.0 ft bgs interval
6020/7471, and 7199 (respectively)
One sample from the 0-2.0 ft bgs
VOCs, SVOCs, and 8 RCRA metals plus hexavalent
Z5
2
1
Z5-0-2.0
interval
chromium via EPA Methods 8260, 8270, 6010/7471 or
6020/7471, and 7199 (respectively)
One sample from the 0-2.0 ft bgs
VOCs, SVOCs, and 8 RCRA metals plus hexavalent
Z6
2
1
Z6-0-2.0
interval
chromium via EPA Methods 8260, 8270, 6010/7471 or
6020/7471, and 7199 (respectively)
Total Number of Samples
11
Notes:
1) "ft bgs" inidcates feet below ground surface
2) VOCs indicates volatile organic compounds
3) SVOCs indicates semi -volatile organic compounds
4) RCRA indicates Resource Conservation and Recovery Act
5) EPA indicates U.S. Environmental Protection Agency
6) Each sample will be comprised of five aliquots, except for VOC samples which will be discrete samples
7) Proposed zones and aliquot locations are illustrated on Figure 1
1 of 1