25032_Domestic Laundry_Stockpile Sampling Work Plan Area A and BRS Approval_20230124

January 24, 2023
Sent Via E-mail
Bennett Thompson & Steven Garrett The Charlotte-Mecklenburg Hospital Authority
P.O. Box 32861
Charlotte, NC 28232-2861 [e-mail] [e-mail]
Subject: Approval of Work Plan for Area A Stockpile Sampling
Domestic Laundry Brownfields Project (# 25032-21-060) Charlotte, Mecklenburg County Dear Mr. Thompson and Mr. Garrett,

The North Carolina Department of Environmental Quality (DEQ) reviewed the Work Plan for Area A
Stockpile Sampling dated January 23, 2023, submitted on your behalf by Geosyntec Consultants of NC for the above referenced site. Based on our review, the Work Plan for Area A Stockpile Sampling is approved with the conditions that (i) if samples are collected for waste characterization to meet the disposal facility
requirements, VOCs will be collected from a grab sample and not from a sample composited in the field;
and (ii) the laboratory be asked to report J (estimated) values in the analytical report. Documentation including manifests, photographs, inspections, analytical results, field notes, and communications are to be reported to DEQ Brownfields either in a separate report, or in the
Redevelopment Summary Report due by January 31 of each year that development activities are
underway in accordance with the Environmental Management Plan approved August 8, 2022. Be advised that this approval from the Brownfields Redevelopment Section does not waive any applicable requirement to obtain any necessary permits, licenses, or certifications for the above referenced activities
nor does it waive any requirement to comply with applicable law for such activities. If you have any
questions, please feel free to contact me at [phone], or by e-mail at [e-mail]. Sincerely,
Peter L. Doorn Brownfields Project Manager ec: Amy Kenwell, Jeff Tyburzski, and Jeff Ahrens, Geosyntec Consultants of NC
McKenzie Publicover, and Ryan Lewis, Kimley Horn & Associates Richard Concepcion, DEQ Hazardous Waste Section Tracy Wahl, DEQ Brownfields Redevelopment Section
Geosyntec Consultants of NC, P.C.
1300 South Mint St, Suite 300
Charlotte, North Carolina 28203
PH 704.227.0840 www.geosyntec.com
CAR230015
23 January 2023
North Carolina Brownfields Redevelopment Section
Attention: Mr. Peter Doorn
Division of Waste Management
1646 Mail Service Center
Raleigh, North Carolina 27699-1646
Subject: Work Plan for Area A Stockpile Sampling
Site: Former Domestic Laundry - Vicinity of South McDowell Street at
Baxter Street
Charlotte, Mecklenburg County, North Carolina
Brownfields Project ID: 25032-21-060
Dear Mr. Doorn:
Geosyntec Consultants of NC, P.C. (Geosyntec) has prepared this Area A Stockpile Sampling Work
Plan (“Work Plan”) that provides procedures for the sampling of stockpiled Area A soils at the
Former Domestic Laundry Brownfields Property in Charlotte, North Carolina (herein referred to as
the “Site”). The portion of the Site included in this Work Plan includes 801 South McDowell Street,
which is represented by Mecklenburg County Parcel ID 12520155 (“Subject Property”). Although
redevelopment plans are still underway, the Prospective Developer (PD) currently has plans to
redevelop the Site as an educational tower and research/education facility, multi-family residential
apartment building, hotel, commercial office space, and parking garages.
In-situ pre-characterization of Area A soils was conducted in July 2022 to support the development
of a soil management plan per the Area A Pre-Characterization Work Plan (“Work Plan-AA”) dated
30 June 2022. Results of the pre-characterization were submitted in an Area A Soil Management
and Disposal Plan (SMDP) dated 27 September 2022, which was approved by North Carolina
Department of Environmental Quality (NCDEQ) Brownfields Redevelopment Section (BRS) on
29 September 2022. Samples from this effort extended between 1 and 9 feet below ground surface
(ft bgs) and were based on plans for rough grading. These soils were removed from the Site in
general accordance with the Area A SMDP. Due to requirements for foundation installation
equipment, additional excavation of soils to a depth of up to an additional 13 feet below the final
depth of pre-characterization assessment activities (below the current grade) will need to be
conducted as shown in Figure 1. Based on overlays of grading plans, Area A pre-characterization
sampling, and proposed elevations, Geosyntec has estimated up to 2,300 cubic yards (cy) of
additional soils will need to be managed. In an email on 13 January 2023, BRS agreed that these
soils could be managed by stockpiling excavated soils following protocols described in Section 8.2
of the Area A SMDP. BRS requires a stockpile sample frequency of one sample per 75 cy and
Mr. Peter Doorn
23 January 2023
Page 2
requested the submittal of a stockpile sampling work plan within 30 days of the 13 January 2023
email. This Work Plan was developed to meet that requirement.
SCOPE OF WORK
Remaining Area A soils which need to be excavated to meet foundation pad grade will be
stockpiled by the construction contractor under the observation of an Environmental Professional
(EP) from Geosyntec and in general accordance with Section 8.2 of the Area A SMDP. The scope
of work presented in this Work Plan includes sampling the stockpiles to support soil management
and develop options for offsite disposal or reuse in connection with the Environmental
Management Plan (EMP) prepared for the Early Grading and Demolition phase of work (EMP-1,
approved 8 August 2022).
Stockpile Soil Sampling
Geosyntec will conduct stockpile sampling to characterize materials for off-Site disposal and/or
reuse on the Brownfields Property. Work will include tracking the approximate volume excavated
based on the number of truckloads and a 14 cy truck bed during each phase of Area A excavation
and calculating the number of samples required for each stockpile based on a 1 sample per 75 cy
ratio. As previously discussed, Geosyntec estimates up to 2,300 cy of soils will be excavated from
Area A that will need to be managed (Figure 1). Note that the actual depths may be more or less
than this estimate and the construction team will focus on meeting the required grade, not on
reaching the depths in this figure.
During excavation Geosyntec will screen soils with a photo-ionization detector (PID) and visually
observe materials for staining. If the field team observes evidence of dry-cleaning related
contamination based on visual, olfactory, or PID evidence (over 100 parts per million) during
excavation activities, soils will not be stockpiled, rather, they will be containerized in
Department of Transportation (DOT)-approved 55-gallon drums or lined roll-off containers and
managed in accordance with the Soil and Water Management Plan (Geosyntec, April 2022).
Based on the estimated volume of soil, Geosyntec anticipates up to 35 soil stockpile samples
(including duplicates) will be collected. The number of samples may be adjusted in the field based
on actual volume generated in the field. Stockpiles will be subdivided into sample grids based
on the estimated volume of the stockpile. An example of how this grid may be developed is
shown in Figure 2. The example is based on a 600 cy stockpile, though it is noted that the
size of the stockpiles may vary. Geosyntec will advance a decontaminated shovel or single-use
sample shovel to approximately 6-inches below stockpile surface at each grid location. An
excavator may be used to gain access to grid sections of the stockpile. Geosyntec does not
propose screening each sub-sample with a PID due to the frequency of sample collection and
the PID screening conducted
CAR230015
Mr. Peter Doorn
23 January 2023
Page 3
CAR230015
during EMP-1 implementation before stockpiling soils. Soils will be visually inspected for
observed ambiguities of lithology and staining. Observations will be recorded in field notes.
If schedule allows, Geosyntec may alternatively collect samples directly from the excavator bucket
during excavation rather than the stockpile itself. In this situation, Geosyntec would use the volume
of the bucket to calculate frequency of sample collection.
Soil samples will be placed into laboratory supplied bottle ware and submitted on ice under chain
of custody to a North Carolina-certified laboratory. Samples will be analyzed using United States
Environmental Protection Agency (USEPA) Method 8260 for Volatile Organic Compounds
(VOCs). Only select VOCs related to dry-cleaning releases will be reported, namely
tetrachloroethene, trichloroethene, cis-1,2-dichloroethene, trans-1,2-dichloroethene, and vinyl
chloride. These VOC samples every 75 cy are to meet the Contained-In Policy requirements to
classify the soils for off-Site disposal or on-Site reuse. Waste disposal characterization is discussed
below.
Dependent on visual observations and PID readings during excavation, the existing non-hazardous
waste profile for Republic Services’ Charlotte Motor Speedway Landfill in Concord, NC may be
appropriate for additional Area A soils. If materials are encountered that are not consistent with
the pre-characterization investigation, composite samples will be collected, as needed, for waste
characterization to meet disposal facility requirements. Landfill waste characterization samples
would include Toxicity Characteristic Leaching Procedure (TCLP) USEPA Method 1311 for
VOCs, semi-volatile organic compounds (SVOCs), and Resource Conservation and Recovery Act
(RCRA) Metals and total hexavalent chromium by USEPA Method 7196.
Non-dedicated equipment will be decontaminated between samples. Decontamination water will
be spread onto the stockpiles in the vicinity of sample collection. As such, no investigation derived
waste (IDW) is anticipated to be generated during this sampling event.
QUALITY ASSURANCE AND QUALITY CONTROL
One blind duplicate soil sample for every 20 samples will be collected for quality assurance and
quality control (QA/QC) purposes. If provided by the laboratory, a temperature blank will be
included in each cooler. Other QA/QC procedures including chain of custody procedures are
described in Section 5 of the Work Plan for Limited Environmental Site Assessment – Part II
(Geosyntec, May 2022).
REPORTING
Upon receipt of analytical results, Geosyntec will prepare a summary report in either email or
memorandum format, dependent on the complexity of the results (for example, if all soils will be
disposed off-Site, an email is anticipated to be sufficient). The report will summarize the
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Source: Esri, Maxar, Earthstar Geographics, and the GIS User Community
\\charlotte-01\Data\GIS\Projects\K\Kimley Horn\Lookout\MXD\CAR230015 Stockpile Sample Plan\Figure X_Locations_AdditionalDepth_r1.mxd 1/19/2023 2:39:17 PM
Legend
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Pre-characterization SampleLocation (with additional neededdepth in feet)Subject Property Boundaries Notes:1. Property boundaries and existing stream from Mecklenburg County GIS.2. Locations are approximate due to close spacing of sampling locations and the scaleof the Figure.3. Locations are labeled with proposed additional depth of grading.³Former Domestic Laundry Brownfields ProjectBF# 25032-21-060Charlotte, North Carolina
Additional Depths for Area A Grading
Figure
1Charlotte, NC January 2023S McDowell StB
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Area to be Graded Deeper
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Boring with impacts above Contained In Policy Unrestricted Use at one or more depths
Boring with no impacts above Contained In Policy Unrestricted Use
ESTIMATED - ACTUAL DEPTHS WILL MEET CONSTRUCTION REQUIREMENTS
Example Stockpile Sample LayoutFigure1January2023Charlotte, NCFormer Domestic Laundry Brownfields ProjectBF# 25032‐21‐060Charlotte, North CarolinaSTOCKPILED SOILS –ESTIMATED 600 CYNotes:1. cy indicates cubic yards2. For a 1:75 cy ratio, 8 samples would be required for 600 cy3. One sample will be collected from each approximately 75 cy grid cell4. Samples will be analyzed for select volatile organic compounds (VOCS) byUnited States Environmental Protection Agency (USEPA) Method 8260 andcompared to the Contained‐In Policy Criteria\\raleigh‐01\PRJ\K\Kimley Horn ‐Project Beacon\GC7466 Project BeaconLookout\3.0 Analysis and Deliverables\3.2 Reports\Work Plans\CAR230015 ‐Stockpile Sampling Work Plan