19054_HD Supply Soil North Tower 20230314

Ms. Carolyn Minnich
March 13, 2023
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Upon learning of the soil transfer, H&H and Cousins contacted DEQ via video call on February
9, 2023 to provide notification of the soil transfer and to discuss remedial options. Based on the
discussion with DEQ, it was decided that the HD Supply soil would be excavated from the
receiving property and be transferred to Republic Services Charlotte Motor Speedway landfill in
Concord, North Carolina. Additional details of the soil excavation and transfer activities are
provided in the following sections.

2.0 Soil Transfer and Disposal Activities

Prior to completing the excavation and soil transfer activities, H&H spoke with representatives
of EDS to obtain additional details of the soil transfer. A representative of EDS indicated that
the receiving property is a large, primarily wooded tract of land used for construction equipment
storage, hunting, and residence. Approximately three tons of HD Supply soil was transferred to
the property and was reportedly used to fill a low area where a new storage building or barn is to
be constructed. The HD Supply soil was placed on top of existing gravel in an approximately 10
ft by 8 ft area. The HD Supply soil was then covered with several inches of gravel. The soil
removal and disposal activities are summarized below.

On February 16, 2023, H&H mobilized to the receiving property to oversee the soil excavation
and transfer activities. Photographs of the excavation activities are provided in Attachment 1.
Prior to the start of the soil excavation and transfer activities, the overlaying gravel was removed
from the HD supply soils and placed in a stockpile. The HD Supply soils were then field
screened for indication of potential impacts including visual observation for staining, olfactory
observations, and the presence of organic vapors using a calibrated photoionization detector
(PID). Field screening results did not indicate the likely presence of obvious impacts to soil.

Following field screening activities, the HD supply soil and the underlying layer of gravel were
excavated to native soil and placed in a dump trailer and covered for future transport. As a
conservative measure, the new gravel layer was removed over an approximate area of 20 ft by 50
ft area to evaluate whether soil was present between the new gravel layer and the existing gravel
Ms. Carolyn Minnich
March 13, 2023
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layer which would indicate the likely presence of the HD Supply soil. Following the soil
excavation activities and removal of gravel from the expanded area, H&H observed the area
where the HD Supply soil was previously located to evaluate the completeness of the soil
removal. Based on our observations, it appears that the soil from the HD Supply Brownfields
property was adequately removed. Additionally, H&H did not observe staining or other
indications of potential impacts to the ground surface below or in the vicinity of the former HD
Supply soil placement area. Photographs of soil removal activities are provided in Attachment 1.

Upon approval of the waste profile by Republic Services, the excavated soil was transferred to
the Charlotte Motor Speedway landfill in Concord, North Carolina on February 24, 2023.
Approximately 7.8 tons of soil were removed from the receiving property and transferred to the
landfill. The completed waste manifest provided by Republic Services is provided in
Attachment 2.

3.0 Summary and Recommendations

Approximately three tons of soil were removed from the HD Supply Brownfields property and
transferred to a property located in Chester, South Carolina. To remedy the non-approved soil
transfer, H&H oversaw the removal of the HD Supply soil from the receiving property and
transfer to the Charlotte Motor Speedway Landfill. To minimize the potential for HD Supply
soil to remain at the receiving property, the area was over-excavated and approximately 7.8 tons
of soil were transferred to the landfill. Field screening results did not indicate the likely presence
of impacts to the excavated soil or to the underlaying soil.

Based on the transfer of the HD Supply soil from the receiving property to the landfill and field
screening results not indicating the likely presence of impacts, H&H does not recommend
additional remedial activities be completed. Additionally, H&H is requesting concurrence from
DEQ that the HD Supply Brownfields property is in compliance with the Brownfields
Agreement.

Ms. Carolyn Minnich
March 13, 2023
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Please contact us if you have any questions or if you require additional information.

Sincerely,

Hart & Hickman, PC

Andrew Besu Nathan O’Leary, PG, CHMM
Environmental Redevelopment Manager Project Manager

Cc: Mr. Steven Hallmark, Cousins Properties

Attachment 1
Photographs
2923 S. Tryon Street, Suite 100
Charlotte, NC 28203704.586.0007(p) 704.586.0373(f)
Photograph 1: View of HD Supply soil prior to transport to the residence (provided by contractor).
CO
U
-00
1 HD Supply
1414 and 1422 South Tryon Street
Charlotte, North Carolina
Photograph 3: General overview of the removed soil and existing driveway to native soil.
2923 S. Tryon Street, Suite 100
Charlotte, NC 28203704.586.0007(p) 704.586.0373(f)
Photograph 2: General overview of new gravel removal.
CO
U
-00
1 HD Supply
1414 and 1422 South Tryon Street
Charlotte, North Carolina
Photograph 4: General overview of the removed soil and existing driveway in the dump trailer.
2923 S. Tryon Street, Suite 100
Charlotte, NC 28203704.586.0007(p) 704.586.0373(f)CO
U
-00
1 HD Supply
1414 and 1422 South Tryon Street
Charlotte, North Carolina

Attachment 2
Republic Services Non-Hazardous Waste Manifests

March 14, 2023 Sent Via E-mail Nathan O'Leary, PG Hart & Hickman 2923 South Tryon Street, Suite 100 Charlotte, North Carolina 28203
[e-mail] Subject: Notice of Brownfields Property-Compliance Review
1414 & 1422 South Tryon Street HD Supply Brownfields Property Charlotte, Mecklenburg County
Brownfields Project No. 19054-15-060 Dear Mr. O’Leary, The North Carolina Department of Environmental Quality (DEQ) Brownfields Redevelopment Section received and reviewed the Soil Excavation and Transfer Letter Report dated March 13, 2023. The letter report documents soil generated from utility work in the Northern Tower and movement from an unapproved location to final disposal at Republic Services Charlotte Motor Speedway landfill in Concord, NC. DEQ Brownfields has determined that this work is in compliance with Land Use Restrictions in the recorded Notice of Brownfields Property.
Please be advised that this approval from DEQ Brownfields does not waive any applicable requirement to obtain any necessary permits, licenses, or certifications which may be required from other state or local entities. If you have any questions, please feel free to contact me at 704-661-0330, or via e-mail at
[e-mail]. Sincerely,
Carolyn Minnich Project Manager Brownfields Redevelopment Section ec: Hallmark, Steve [e-mail] Albright, Amy [e-mail]