26061 - Brownfields Assessment Work Plan R1_Piedmont Plating

Via Email
April 13, 2023

NCDEQ – Division of Waste Management
Brownfields Redevelopment Section
1646 Mail Service Center
Raleigh, North Carolina 27699-1646

Attn: Ms. Carolyn Minnich

Re: Brownfields Assessment Work Plan – Revision 1
Piedmont Plating & Anodizing Company
Distribution Street & Dunavant Street
Charlotte, North Carolina
Brownfields Project No. 26061-22-060
H&H Project No. H&A-002

Dear Carolyn:

On behalf of Hoffman & Associates, please find the enclosed Brownfields Assessment Work Plan
prepared for the Piedmont Plating & Anodizing Brownfields property which has been revised to address
your comments provided on April 12, 2023. Should you have questions or need additional information,
please do not hesitate to contact us.

Sincerely,
Hart & Hickman, PC
Loryn Smith Ralph McGee, PG
Project Environmental Scientist Senior Project Manager

Enclosures:

cc: Mr. Christopher Kirchner, Hoffman & Associates (Via Email)
Mr. David Roberts, Hoffman & Associates (Via Email)

Work Plan and Report Checklist
Version 3 March 2023

Minimum Requirements Checklist
Site Assessment Work Plans and Reports
NCDEQ Brownfields Redevelopment Section– March 2023

Instructional Page
All references to Prospective Developers include follow-on owners who may be conducting
work in accordance with the Brownfields Property Management Branch.
To increase predictability and most efficiently assess Brownfields Properties and the redevelopment
timing requirements of Prospective Developers or follow-on owners, the Brownfields
Redevelopment Section has standardized the format for Site Assessments. This format has been
generated in the form of a checklist to allow for ease in submission by the prospective developer’s
consultant and for the Brownfields Redevelopment Section’s completeness review. This checklist
outlines the minimum requirements and submittal format under the Brownfields Redevelopment
Section for Assessment Requirements and Reporting. All Assessment Work Plans and Report
submissions to the Brownfields Redevelopment Section must include this completed checklist in the
outlined format.
These requirements allow DEQ to reduce review time for the Assessment Work Plan and Report
and increase process predictability for prospective developers. This checklist will also provide
reliable data for risk-based decisions and further expedite the project timeline. Any divergence from
these requirements will lengthen the process of assessing risks on the site, may necessitate
reprioritization of a project manager’s queue towards projects that meet these requirements.
Therefore, delaying production of the brownfields agreement and/or environmental management
plan. Any alterations to the checklist on a site-specific basis must be reviewed and approved by the
Section prior to implementation. However, in order to respect the schedule of all projects in house
and keep the Section’s entire project pipeline moving, we strongly recommend against seeking
changes to the checklist.
Based on a review of environmental and risk data from our project inventory, please note
there are some new points of emphasis that are included herein:
1. For ALL residential reuses; sub-slab vapor assessment (full list EPA TO-15) is required,
regardless if existing structures will be removed. If no structures or slabs exist on the
Brownfields Property, exterior soil gas assessment is required within all proposed structure
footprints.
2. ALL properties require groundwater data (VOCs, SVOCs and RCRA Metals) from a
minimum of three sample locations, depth to groundwater and a resulting potentiometric
map.
3. Soil shall be assessed based on areas of concern and redevelopment plans and across the
depth interval of the cut/grading.

Work Plan and Report Checklist
Version 3 March 2023

Environmental Site Assessment
Work Plan Checklist
Reviewed and checked by (Name): _____Carolyn Minnich________

Title Page
The title page should include the following information. Letter style reports are acceptable, as long as this
information is somewhere on the first page.
☒ Title of Work Plan
☒ Brownfields Project Name (not the development name)
☒ Brownfields Project Number
☒ Date (updated with each revision)
☐ Revision Number
☒ Firm PE/PG License Number
☒ Individual PE/PG seal & signature

Section 1 – Introduction
☒ Provide the site location, address, and acreage.
☒ Provide a BRIEF summary of the history of the property and its history in the Section. For example:
reiterate RECs from a Phase I ESA, indicate if the scope of work was negotiated during a Data Gap
Meeting, etc.
☒ Briefly list and describe the data gaps the assessment is attempting to fill
☐ Indicate if the assessment data is for the use of any other DEQ programs in addition to the Brownfields
Redevelopment Section (i.e. the site is a regulated UST, IHSB, etc. property)
Section 2 – Scope of Work
☒ Provide a general description of proposed scope of work covered in this plan (i.e. 2 new monitoring
wells, 6 groundwater samples, 5 exterior soil gas sampling points and 6 soil borings)
☒ Discuss samples to be collected by media and source area/location. Generally, the reasoning for the
sample locations selected.
☒ Describe depths of samples to be collected (Reference Table 1) or how that decision will be made in
the field, if needed.
☒ State for what each sample will be analyzed (briefly). Reference Table 1.

Note: For all residential reuses, sub slab vapor is required, if no slabs exist, exterior soil gas is required
within all proposed footprints.
Section 3 – Sampling Methodology
☒ Reference the guidance documents you intend to use. IHSB, EPA SESD, VI Guidance, Well
Construction Rules (NCAC 2C). Note deviations or methodology planned that is not covered by
such guidance (e.g., multi-increment sampling, passive air samplers, mobile labs, Hapsite,
simultaneous indoor/outdoor radon, high-volume sub-slab vapor testing, PFAS sampling).
☒ Describe what will be installed (soil boring, temporary well, permanent well, sub-slab vapor, exterior soil
gas, etc.). Include construction details.
☒ Discuss installation methodology (Hand Auger, DPT, etc.)
Discuss Equilibration Times
Work Plan and Report Checklist
Version 3 March 2023

• Monitoring wells (equilibration time prior to development and equilibration post well
development should be 24 hours, per EPA standard protocols).
• Vapor:
a. Sub slab vapor with minimally invasive points (e.g. Vapor Pins): Manufacturer’s
guidelines generally suggest 20 minutes may be sufficient with an airtight cap installed; or
b. Sub slab vapor points (other than minimally invasive points) or exterior soil gas points:
at least 24 hours (to be purged at installation and at time of sampling with an air-tight cap
in place in the interim).

☒ Discuss sample collection procedures. Include the following, at a minimum:
• Equipment to be used
• Purging methods and volumes
• Stabilization parameters for groundwater sampling
• Field screening methods
• Leak check procedures for sub-slab vapor and exterior soil gas samples (Note this is
required)
• Discuss how and when vacuum readings will be collected (for summa cans)
• Submission of the samples to the laboratory within 48 hours of collection and/or written
documentation of temperature maintenance if the situation requires extension beyond 48
hours prior to lab submittal
☒ Discuss sample point abandonment

Section 4 – Laboratory Analyses
☒ Discuss the proposed analyses (include method number, preparation method, if there are concerns
with short hold times, etc).
☒ Discuss any proposed limitations on the contaminants of concern, if any, and the reason for such
limitation (sufficient previous data, indoor air interferences, etc).
☒ Discuss laboratory certifications. Please note, NC does not certify labs for air samples. Please specify
what certification the proposed air lab holds.
☒ Indicate that the Reporting Limits/Method Detection Limits will meet applicable screening criteria
(to the extent feasible). Include reporting of J-Flags to meet criteria.
☒ Indicate what Level QA/QC will be reported by the laboratory. Level II QA/QC is typically
acceptable.

Section 5 – QA/QC
☒ Specify the duplicate sample frequency. Minimum requirement: 1 duplicate per 20 samples, per
media, per method.
☒ Discuss Trip Blank. 1 Trip Blank per cooler/shipment of groundwater VOC analyses is required.
☒ Discuss how the lab will have sufficient sample volume for MS/MSD analyses.
☒ Discuss chain of custody and shipping.

Section 6 – Investigation Derived Waste (IDW) Management
☒ Discuss what IDW will be generated and how it is proposed to be managed. Management
recommendations should be in accordance with 15A NCAC 02T.1503 and 15A NCAC 02H. 0106.
Generally, if the Brownfields Property has not previously been assessed, then all IDW must be
containerized and characterized prior to management. Previous assessment data that indicate no
Hazardous Waste (listed or characteristic) is likely to be encountered in the area of proposed
Work Plan and Report Checklist
Version 3 March 2023

assessment will be required before thin spreading of IDW on-site is permitted.
Section 7 – Reporting
This section should discuss the components of the assessment report which will be prepared as a result of
the above sample collection. At a minimum, the report shall include:

☒ Title Page that is consistent with the requirements listed above.
☒ Reporting/summary of site work conducted for all sections outlined above in this checklist;
☒ Summary of findings and possible recommendations;
☒ All applicable tables and figures (shall include at a minimum the items below)
☐ Tables for tabulated analytical data per media sampled and analyzed, compared against
applicable screening levels, sample depths and depth to groundwater;
☐ Figure depicting actual sample locations collected, with each media depicted in the legend,
graphic scale and north arrow; and
☐ Groundwater potentiometric map, with graphic scale and north arrow.
☒ Appendices shall include (as applicable):
☐ Copies of field notes
☐ Boring logs for all soil borings, newly constructed monitoring wells, and exterior soil gas
locations
☐ Well construction and abandonment records

Work Plan Approval Signature Page (see Attachment 1). The Consultant shall complete and
submit the Approval Signature Page with the work plan submittal for DEQ signature.

Work Plan and Report Checklist
Version 3 March 2023

Attachments
☒ Attachment 1 – Work Plan Approval Signature Page
☒ Table 1 – Proposed Sample Locations and Analyses on a Summary Table that includes:
☐ Sample ID
☐ Sample Objective
☐ Proposed Depth(s)
☐ Analytical Method(s)
☐ QA/QC Samples
☐ Background Samples

☒ Figure 1 – Site Location Map
☐ Site location on a topographic map base
☐ Graphic scale and north arrow

☒ Figure 2 – Site Map should include the following
☐ Buildings
☐ Historical sample locations
☐ RECs or other areas of concern
☐ Proposed sample locations
☐ Sample identification labels
☐ Background samples
☐ QA/QC samples
☐ Graphic scale and north arrow
☐ High quality aerial suggested as the base map

NA Figure 3 – Site Potentiometric Map that includes the following
☐ Buildings
☐ Groundwater sample identification labels
☐ Arrow noting direction of groundwater flow
☐ Graphic scale and north arrow

NA Figure 4 – Site Plume Maps (groundwater, soil vapor, etc.)

☒ Figure 5 – Proposed Development (if available)
☐ Overlay of historical and proposed sample locations
☐ Graphic scale and north arrow

☒ Appendix – Summary of Historical Analytical Data (if needed) – to include tables and figures only.
04/13/2023
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Brownfields Assessment Work Plan
Piedmont Plating & Anodizing Company
Charlotte, North Carolina
Brownfields Project No. 26061-22-060
H&H Job No. H&A-002

Table of Contents

1.0 Introduction .............................................................................................................................1 
1.1 Background Information .......................................................................................................2 
1.2 Previous Assessment Activities .............................................................................................3 
2.0 Brownfields Assessment Activities ......................................................................................10 
2.1 Receptor Survey ..................................................................................................................10 
2.2 Soil Sampling Activities ......................................................................................................11 
2.3 Groundwater Sampling Activities .......................................................................................14 
2.4 Soil Gas Sampling Activities ...............................................................................................16 
2.5 Quality Assurance – Quality Control ..................................................................................18 
2.6 Investigation Derived Waste ...............................................................................................19 
3.0 Reporting ...............................................................................................................................20 

List of Tables

Table 1 Sample Summary Table

List of Figures

Figure 1 Site Location Map
Figure 2 Site Map
Figure 3 Historical Operations and Sample Location Map
Figure 4 Proposed Sample Location Map

List of Appendices

Appendix A Historical Analytical Data
Appendix B Brownfields Property Receptor Survey Template Form
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Brownfields Assessment Work Plan
Piedmont Plating & Anodizing Company
Charlotte, North Carolina
Brownfields Project No. 26061-22-060
H&H Job No. H&A-002

1.0 Introduction

Hart & Hickman, PC (H&H) has prepared this Brownfields Assessment Work Plan (Work Plan)
for the Piedmont Plating & Anodizing Company Brownfields property (Brownfields Project No.
26061-22-060) located at 2401 Distribution Street and 2322, 2400, 2402, 2404, and 2406
Dunavant Street in Charlotte, Mecklenburg County, North Carolina (Site). The Site consists of
four adjoining parcels (Mecklenburg County Parcel Identification Nos. [PIN] 12104204,
12104244, 12104216, and 12104215) that collectively total approximately 2.6 acres of land
located in a rapidly densifying area of the South End neighborhood approximately 2.5 miles
southwest of uptown Charlotte. A Site location map is provided as Figure 1, and the Site and
surrounding area are shown in Figure 2.

The Site is developed with one approximate 25,800 square foot (sq ft) warehouse building
constructed in 1961 (2401 Distribution Street), one approximate 18,500 sq ft multi-tenant
warehouse building constructed in 1961 (2322 Dunavant Street), one approximately 3,600 sq ft
warehouse building constructed in 1961 (2400 Dunavant Street), and one approximately 11,400
sq ft multi-tenant warehouse building constructed in 1961 (2402/2406 Dunavant Street).
Remaining portions of the Site are improved with asphalt-paved access drives, parking areas, and
landscaping. The Site buildings are occupied as follows:

 The 2401 Distribution Street Site building is currently vacant.

 The 2322 Dunavant Street Site building is currently occupied by The Dunavant
Restaurant, Barton Malow Construction, and a vacant tenant space.

 The 2400 Dunavant Street Site building is currently vacant, and the adjoining 2402-2406
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Dunavant Street Site building consists of a vacant tenant space (2402 Dunavant Street)
and SL Laser (a laser equipment supplier; 2406 Dunavant Street).

Proposed redevelopment of the Brownfields property includes razing the existing Site buildings
for construction of multi-story high density residential apartment building over a podium-style
parking deck with limited retail and amenities spaces at ground level. No residential units are
currently planned for ground level components of the proposed apartment building.

1.1 Background Information

As early as the 1930s, the Site consisted of undeveloped vegetated land. The Site was cleared
and graded in the 1950s, but remained undeveloped vacant land until the current warehouse
buildings were constructed in the early 1960s. The Site buildings were historically occupied as
follows:

 The 2401 Distribution Street Site building was occupied by Colora Knits Inc. (hosiery
manufacturers) and Gold Seal Manufacturing Company Inc. in the early 1960s and
Mielco Industries (auto parts manufacturing) in the mid-1980s until the early 1990s. The
2401 Distribution Street Site building was then occupied by various distribution, retail,
and commercial office tenants from the 1990s until the late 2010s.

 The 2322 Dunavant Street Site building was occupied by Piedmont Plating & Anodizing
Company from the early 1960s until the early to mid-1970s, when Southern Aluminum
Finishing Company acquired the property and continued plating and anodizing operations
until 2014. The warehouse building was renovated for commercial uses and has been
operated as a restaurant since 2018.

 The 2400 and 2402/2406 Dunavant Street Site building was occupied by a dairy
equipment manufacturer in 1961 until the 1990s, and a lithographic printer from 1983
until 2016. The Site buildings have since been renovated for commercial uses and have
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been occupied by a retail home furnishings business and a laser equipment supplier since
2017/2018.

Historical operations at the Site have consisted of hosiery manufacturing, auto parts
manufacturing, metal plating and anodizing, equipment manufacturing, and lithographic printing.
In more recent years, the Site buildings have been occupied by various retail and commercial
tenants. Historical operations are shown in Figure 3.

1.2 Previous Assessment Activities

H&H reviewed several reports prepared by others to obtain additional information associated
with previous environmental assessments completed for each Site parcel. A brief summary of
the previous environmental reports is provided below, and copies of historical data tables and
sample location maps are included in Appendix A.

2401 Distribution Street
Partner Engineering North Carolina, PLLC (Partner) conducted a Phase I ESA for the 2401
Distribution Street Site parcel in April 2021. According to information provided in the report,
the Site consisted of one parcel of land which was developed with one approximately 25,800 sq
ft commercial and industrial building. At the time of the report, the Site was occupied by Parker
Medical Associates for the manufacture of athletic protective guards and other resin/fiberglass-
based products, Dance Style Studios for custom dancewear design, and Friendship Trays for
food preparation and distribution. Historically, the Site building was occupied Colora Knits Inc.
for hosiery manufacturing and Gold Seal Manufacturing Company Inc., Boise Cascade Office
Supply Overflow, Mielco Industries Auto Parts Manufacturing (1984-1991), and Parker Medical
Products and a commercial kitchen (1991-2020s).

Results of groundwater assessments completed at the north-northeast adjacent Crayton Printing
Brownfields property identified tetrachloroethylene (PCE), trichloroethylene (TCE), and vinyl
chloride at concentrations above the North Carolina Department of Environmental Quality
(DEQ) 2L Groundwater Quality Standards (2L Standards) in the samples collected in close
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proximity and topographically upgradient of the 2401 Distribution Street Site parcel. Results of
the Phase I ESA identified the potential for impact to the Site from historical on-Site operations
and from known impacts in groundwater identified on the north-northeast adjacent Crayton
Printing Brownfields property to be environmental concerns in connection with the Site.

Following the completion of the Phase I ESA for 2401 Distribution Street, Partner completed a
Phase II Subsurface Investigation in May 2021 which the collection of one groundwater sample
and three exterior near slab soil gas samples for laboratory analysis. Each sample was collected
adjacent to the northern and topographically upgradient side of the 2401 Distribution Street Site
building. The May 2021 Phase II sample locations are shown in Figure 3.

Soil sample laboratory analytical results indicated that TCE (up to 3.4 micrograms per liter
[µg/L]) at concentrations slightly above the DEQ 2L Standard of 3.0 µg/L and the DEQ
Residential Vapor Intrusion Groundwater Screening Level (GWSL) of 1.0 µg/L. In addition,
low levels of PCE (up to 6.2 micrograms per cubic meter [µg/m3]), TCE (3.6 µg/m3), and vinyl
chloride (0.59 µg/m3) were detected in soil gas at concentrations above the laboratory method
detection limits, but below their respective DEQ Residential and Non-Residential Vapor
Intrusion Sub-slab and Exterior Soil Gas Screening Levels (SGSLs).

2322 Dunavant Street
In November 2021, Partner conducted a Phase I ESA for the 2322 Dunavant Street Site parcels
(Parcels 12104216 and 12104244). According to information provided in the report, the Site was
developed with one approximately 18,505 sq ft commercial retail/offices building. At the time
of the report, the Site was occupied by Barton Marlow for office space, The Dunavant
(restaurant), and a vacant tenant space. Historically, the Site was occupied by Piedmont Plating
& Anodizing Company from 1961 until 1973, when the Southern Aluminum Finishing Company
reportedly acquired the Site for similar operations until 2014.

According to information provided in the Partner Phase I ESA report, operations at the Site
consisted of anodizing aluminum, which is generally described as an electrochemical oxidation
process that consists of immersing metal into multiple chemical baths (primarily sulfuric acid) to
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convert the metal surface into a decorative, durable, and corrosive-resistance product. Limited
information was available pertaining to chemical use and hazardous waste generation, storage,
and handling procedures.

Partner also reviewed a prior Phase I ESA prepared by ERM and dated October 2007. At the
time of the ERM report, the 2322 Dunavant Street Site building was occupied by the Southern
Aluminum Finishing facility. During the Site reconnaissance, the Site contact stated that plating
process wastewater generated during the anodizing processes is treated on-Site prior to
discharging to the municipal sanitary sewer system. During the pretreatment process, a caustic
solution was added to neutralize the wastewater pH levels, and a flocculating agent was added to
promote solids to settle within wastewater clarifying tanks. The wastewater would then cycle
through three 500-gallon process tanks prior to being discharged. Sludge collected from the
clarifier was pumped into a filter press and dried prior to disposal into an on-Site dumpster.

ERM also identified numerous aboveground storage tanks (ASTs) at the facility which contained
the wastewater pretreatment system, clarifier, backup tank for the wastewater pretreatment
system, hydrochloric acid, and electrolytic coloring solutions. Four to five dip tanks associated
with the anodizing process were also identified within the Site building. ERM did not identify
other ASTs, USTs, or other items of environmental concern at the Site. Based on this
information, ERM did not recommend additional assessment activities. However, results of the
Partner Phase I ESA identified on-Site historical aluminum plating and anodizing Site operations
as an environmental concern in connection with the 2322 Dunavant Street Site parcels. Partner
also identified the known chlorinated solvent impacts in groundwater identified at the adjacent
Crayton Brownfields Property (discussed above) as an environmental concern.

Following the completion of the Phase I ESA for 2322 Dunavant Street, Partner completed a
Phase II Subsurface Investigation in November 2021 which included the collection of three soil
samples and two exterior soil gas samples for laboratory analysis. Partner attempted to install
temporary groundwater monitoring wells for the collection of groundwater samples, but drilling
refusal was encountered prior to reaching the water table and no groundwater samples were
collected. The November 2021 Phase II sample locations are shown in Figure 3.
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Results of the soil sampling activities did not identify compounds at concentrations above the
laboratory method detection limits. Results of the exterior soil gas sampling activities indicated
the presence of 1,3-butadiene (24.8 µg/m3) and benzene (22.8 µg/m3) at concentrations above
their respective DEQ Residential Vapor Intrusion SGSLs, but below the DEQ Non-Residential
Vapor Intrusion SGSLs.

2400 Dunavant Street
In April 2022, Partner conducted a Phase I ESA for the 2400 Dunavant Street Site parcel.
According to information provided in the report, the Site consisted of one parcel of land which
was developed with one approximately 11,400 sq ft warehouse building and one 3,600 sq ft
multi-tenant warehouse building. At the time of the report, the Site was occupied by Mrs.
Howard Fine Furnishings and Interiors (home goods storage), SL-Laser Systems (laser
equipment calibration), and vacant tenant space. Historically, the Site was occupied by a dairy
equipment manufacturer in the 1960s, an outwear manufacturer (knitting) in the early 1970s, a
lithographic printer from at least 1983 until 2016, and other various office and warehouse
occupants. Results of the Phase I ESA identified the potential for impacts from an
undocumented release associated with historical Site operations as an environmental concern in
connection with the Site.

Following the completion of the Phase I ESA for 2400 Dunavant Street, Partner completed a
Phase II Subsurface Investigation in May 2022 which included the collection of three soil
samples and two sub-slab soil gas samples for laboratory analysis. The two sub-slab soil gas
samples were collected within the former lithographic printer tenant space. Partner attempted to
install temporary groundwater monitoring wells for the collection of groundwater samples, but
drilling refusal was encountered prior to reaching the water table and no groundwater samples
were collected. The May 2022 Phase II sample locations are shown in Figure 3.

Soil sample results did not identify compounds at concentrations above the DEQ PSRGs or
background levels in the case of metals. Results of sub-slab soil gas sampling completed within
the tenant space for the former printing operations identified benzene (up to 21.8 µg/m3) and
1,1,2,2-trichloroethane (4.24 µg/m3) at concentrations above their respective DEQ Residential
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Vapor Intrusion SGSLs but below the DEQ Non-Residential Vapor Intrusion SGSLs in the sub-
slab soil gas samples collected at the Site.

2023 Phase I ESA
In March 2023, H&H completed a Phase I ESA for the Site. Results of the Phase I ESA
identified the following environmental concerns:

 The 2401 Distribution Street Site building was historically occupied by the Colora Knits
Inc. (hosiery manufacturers) and Gold Seal Manufacturing as early as the 1960s and
Mielco Industries (auto parts manufacturing) from the mid-1980s until the early 1990s.
Operations such as hosiery and auto parts manufacturing may have included use of dyes,
solvents, an/or petroleum products.

The 2322 Dunavant Street Site building was occupied by Piedmont Plating & Anodizing
Company from the early 1960s until the early to mid-1970s, when the Southern
Aluminum Finishing Company acquired the Site building and continued similar metal
plating and anodizing operations. Metal plating and anodizing operations may have
included the use of various chemicals and solvents.

The 2400 Dunavant Street Site building was occupied by a dairy equipment manufacturer
in the 1960s, an outwear manufacturer (knitting) in the early 1970s, a lithographic printer
from at least 1983 until 2016, and other various office and warehouse occupants.
Manufacturing operations such as dairy equipment and knitting as well as printing
operations commonly use dyes, solvents, and/or petroleum products.

Limited information is available pertaining to the use of potentially hazardous materials
or generation, storage, and management practices associated with hazardous waste for the
historical on-Site manufacturing, metal plating and anodizing, and printing operations.
As noted above, it is common for former Site operations to use various petroleum
products, solvents, and other potentially hazardous materials that can persist in the
environment if released or spilled. The Site buildings have recently been renovated and
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there is no obvious evidence of environmentally sensitive systems remaining at the Site
(tanks, separators, drains, sumps, storage areas, etc.). However, based on the types and
duration of historical operations conducted within the Site buildings, the potential for
impact from undocumented releases represents an environmental concern that warrants
further evaluation.

As discussed above, Partner completed Limited Phase II Investigations for each Site
parcel in May 2021, November 2021, and May 2022. Phase II assessments completed at
the Site included the collection of soil, groundwater, and soil gas samples for laboratory
analysis to evaluate subsurface conditions for potential impacts associated with historical
on-Site and nearby off-Site uses. A low level of TCE (3.4 µg/L) was detected in a
groundwater sample collected in the northern and upgradient portion of the Site at a
concentration exceeding the 2L Standard (and DEQ Residential Vapor Intrusion GWSL).
H&H considers the presence of TCE in groundwater at concentrations above the 2L
Standard to be an environmental concern in connection with the Site.

 The Site is located in a historically industrial and commercial use area of Charlotte.
Operations on nearby properties have included dry cleaning facilities, photofinishing, a
printing facility, and other manufacturing and industrial uses. In addition, several release
incidents are listed in the environmental databases for multiple nearby off-Site properties.
Results of groundwater assessment activities previously completed for the adjacent
property to the north have identified PCE, TCE, and vinyl chloride at concentrations
above the 2L Standards in monitoring wells located approximately 60 to 330 ft north-
northeast and cross-gradient to upgradient to the subject Site. The potential for impact to
the Site from documented and undocumented releases associated with historical
operations on nearby off-Site properties was identified as an environmental concern in
connection with the Site.

To address environmental concerns associated with historical on-Site and off-Site operations, 6
Summit Capital, LLC elected to enter the Site into the DEQ Brownfields Redevelopment Section
on August 29, 2022, and received a letter of eligibility on February 7, 2023. Hoffman &
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Associates is under contract to acquire the Site from 6 Summit Capital, LLC and intends to
submit an updated Brownfields Property Application to be identified as the Prospective
Developer and complete the Brownfields agreement process. A kick-off/data gap meeting with
the DEQ Brownfields Redevelopment Section, 6 Summit Capital, LLC, Hoffman & Associates,
and H&H was held on April 12, 2023, and DEQ provided comments to the Brownfields
Assessment Work Plan (Work Plan) initially submitted for review on April 4, 2023. This Work
Plan has been revised to address DEQ comments.

Due to time constraints associated with the property transaction process and issuance of an
amended eligibility letter for the new applicant, H&H has prepared this Work Plan on behalf of
Hoffman & Associates to conduct Brownfields assessment activities at the Site to address data
gaps and further evaluate potential risks associated with the proposed residential development.

The purpose of the Brownfields assessment activities described herein is to further evaluate the
potential for impacts at the Site and assist with the management of Site media during proposed
redevelopment of the Site. The Brownfields assessment activities discussed in the following
sections focus on the collection of soil, groundwater, and soil gas samples for laboratory
analysis. In addition to the sampling activities, a receptor survey will be conducted to obtain
information associated with land use, potable water supply, and potential sensitive receptors in
the area surrounding the Site.

A summary of the proposed Brownfields assessment activities is provided in the following
sections.
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2.0 Brownfields Assessment Activities

The Brownfields assessment activities will be conducted in general accordance with the DEQ
Inactive Hazardous Sites Branch (IHSB) Guidelines for Assessment and Cleanup of
Contaminated Sites (Guidelines) dated September 2022, the DEQ Division of Waste
Management (DWM) Vapor Intrusion Guidance (VI Guidance) dated September 2022, the most
recent versions of the U.S. Environmental Protection Agency (EPA) Region IV Laboratory
Services and Applies Science Division (LSASD) Field Branches Quality System and Technical
Procedures guidance, and the DEQ Brownfields Program Environmental Site Assessment Work
Plan Minimum Requirements Checklist dated March 2023.

Prior to conducting the proposed assessment field activities, H&H will contact North Carolina
811, the public utility locator, to mark subsurface utilities located on the Site. H&H will also
contract with a private utility locator to screen proposed sample locations for subgrade utilities
that may not be marked by the public locator. Additionally, soil boring locations will be hand
cleared to approximately 5 feet below ground surface (ft bgs) prior to use of mechanical drilling
equipment to further screen the boring locations for the presence of subsurface utilities.

In accordance with Mecklenburg County rules, H&H will also obtain a Subsurface Investigation
Permit (SIP) from Mecklenburg County prior to temporary monitoring well installation and
sampling. After completion of the activities, H&H will update the SIP on the Mecklenburg
County Well Information database with temporary monitoring well abandonment records
provided by a North Carolina licensed driller.

2.1 Receptor Survey

H&H will perform a receptor survey in accordance with DEQ Brownfields protocols. The
receptor survey will include information about land use in the Site area including zoning. H&H
will also conduct a field search for water supply wells, basements, utility manways and chases,
storm sewers, other underground utilities, drains, and surface water within a 1,500 ft radius of
the Brownfields property boundary. In addition, H&H will review the online Mecklenburg
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County Well Information System for potential water supply wells in the area and, if warranted,
contact utility companies for information concerning underground utilities in the immediate area
of the Site. The receptor survey will be completed using the most current version of the
Brownfields Property Receptor Survey template form. A copy of the Brownfields Property
Receptor Survey template form is provided in Appendix B.

2.2 Soil Sampling Activities

H&H will conduct soil sampling as part of the Brownfields assessment activities. The purpose
of the soil sampling is to evaluate the potential for impacts in areas of potential environmental
concern and to evaluate potential impacts in areas that may be disturbed during planned
redevelopment and grading activities.

Soil borings will be advanced adjacent to the former railroad spurs and loading dock areas
located in the central portion of the Site, near former ASTs associated with a historical metal
plating operations on the eastern portion of the Site, and within the 2322 Dunavant Street Site
building in the former metal plating process area and the former wastewater treatment system
area associated with the Piedmont Plating & Anodizing and Southern Aluminum Finishing
operations. To evaluate soil conditions in these areas, H&H will collect eleven (11) soil samples
for laboratory analysis from eleven (11) soil borings. Locations of the proposed soil borings are
shown in Figure 4, and a tabular summary of proposed sample depths, objectives, and laboratory
analyses is provided in Table 1.

H&H will team with a qualified drilling contractor to advance eleven soil borings (BF-SB-1
through BF-SB-11) at the Site utilizing a decontaminated stainless steel hand auger and a track-
mounted drill rig capable of direct push technology (DPT) drilling methods where accessible.
Continuous soil samples will be collected from the center of the hand auger bucket or acetate
lined macrocore sleeves at each boring. The soil samples will be logged for lithological
description and observed for obvious evidence of staining and unusual odors, and field screened
for the presence of volatile organic vapors using a calibrated photoionization detector (PID).
Soil samples for laboratory analysis will be collected as described below.
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 To evaluate background conditions in areas that appear to not be affected by historical
Site uses, two soil boring (BF-SB-1 and BF-SB-11) will be advanced along Distribution
Street and Dunavant Street to approximately 5 ft bgs. Soil samples for laboratory
analysis will be collected from the depth interval exhibiting the highest likelihood for
impact based on field screening results. If field screening results indicate that there is no
obvious evidence of impacts in a discrete depth interval, the soil samples will be
collected from a shallow depth interval (i.e., no greater than 7 ft bgs) to evaluate
background levels of compounds at the Site. The soil samples will be analyzed for
volatile organic compounds (VOCs) by EPA Method 8260, semi-VOCs (SVOCs) by
EPA Method 8270, Resource Conservation and Recovery Act (RCRA) metals plus
hexavalent chromium, copper, aluminum, nickel, and zinc by EPA Methods
6020/7471/7199, and cyanide by EPA Method 4500.

 One soil sample (BF-SB-2) will be advanced along Distribution Street to evaluate soil
conditions along the northern Site boundary. The soil boring will be advanced to
approximately 5 ft bgs and the sample will be collected from the depth interval exhibiting
the highest likelihood for impact based on field screening results. If field screening
results indicate that there is no obvious evidence of impacts in a discrete depth interval,
the soil sample will be collected from shallow soils (e.g., 0-2 ft bgs) to evaluate soil that
may be disturbed during future redevelopment activities. The soil sample will be
analyzed for VOCs by EPA Method 8260, SVOCs by EPA Method 8270, and RCRA
metals plus hexavalent chromium by EPA Methods 6020/7471/7199.

 Four shallow soil borings (BF-SB-3 and BF-SB-6) will be advanced between former
loading docks and the former railroad spurs located in the central portion of the Site. The
borings will be advanced to approximately 5 feet (ft) below ground surface (bgs) and
samples will be collected from the depth interval exhibiting the highest likelihood for
impact based on field screening results. If field screening results indicate that there is no
obvious evidence of impacts in a discrete depth interval, the soil sample will be collected
from shallow soils (e.g., 0-2 ft bgs) to evaluate soil that may be disturbed during future
redevelopment activities. The soil sample will be analyzed for VOCs by EPA Method
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8260, SVOCs by EPA Method 8270, and RCRA metals plus hexavalent chromium by
EPA Methods 6020/7471/7199.

 Two soil borings (BF-SB-7 and BF-SB-8) will be advanced on the eastern corner of the
2322 Dunavant Street Site building, where former metal plating related ASTs were
staged. The borings will be advanced to approximately 8 ft bgs and samples will be
collected from the depth interval exhibiting the highest likelihood for impact based on
field screening results. If field screening results indicate that there is no obvious
evidence of impacts in a discrete depth interval, the soil sample will be collected from
shallow soils (e.g., 0-2 ft bgs) to evaluate soil that may be disturbed during future
redevelopment activities. The soil samples will be analyzed for VOCs by EPA Method
8260, SVOCs by EPA Method 8270, RCRA metals plus hexavalent chromium, copper,
aluminum, nickel, and zinc by EPA Methods 6020/7471/7199, and cyanide by EPA
Method 4500.

 Two soil borings (BF-SB-9 and BF-SB-10) will be advanced within the 2322 Dunavant
Street Site building in the former plating and anodizing process area and in the area of the
former wastewater treatment system. The borings will be advanced to approximately 8 ft
bgs and samples will be collected from the depth interval exhibiting the highest
likelihood for impact based on field screening results. If field screening results indicate
that there is no obvious evidence of impacts in a discrete depth interval, the soil sample
will be collected from shallow soil to evaluate soil conditions directly below the building
slab. The soil samples will be analyzed for VOCs by EPA Method 8260, SVOCs by EPA
Method 8270, RCRA metals plus hexavalent chromium, copper, aluminum, nickel, and
zinc by EPA Methods 6020/7471/7199 and cyanide by EPA Method 4500 .

The soil samples selected for laboratory analysis will be placed in dedicated laboratory supplied
sample containers, labeled with the sample identification, date, and requested analysis, and
placed in a laboratory supplied cooler with ice. The samples will be delivered to a North
Carolina certified laboratory under standard chain of custody protocols for laboratory analysis.
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Following sampling activities, the soil borings will either be permanently abandoned and the
surfaces repaired similar to pre-drilling conditions, or the boring will be converted into
temporary monitoring wells as described below. Additionally, the soil sample locations will be
estimated using a hand-held global positioning system (GPS) unit for exterior locations and
measured from known benchmarks (e.g., windows, walls, doors, etc.) for interior locations.

2.3 Groundwater Sampling Activities

H&H will contract a qualified drilling contractor to advance borings for installation of eight (8)
temporary groundwater monitoring wells at the Site. The purpose of the temporary groundwater
monitoring wells will be to evaluate current groundwater conditions in areas where previous
assessment activities have not been completed. The locations of the proposed temporary
monitoring wells are shown in Figure 4, and are described further below:

 Two temporary monitoring wells (BF-TMW-1 and BF-TMW-2) will be installed in the
western and downgradient portion of the Site;
 Three temporary monitoring wells (BF-TMW-3, BF-TMW-4, and BF-TMW-6) will be
installed in upgradient portions of the Site, along the northern Site boundary and
downgradient of historical off-Site operations;
 One temporary monitoring well (BF-TMW-5) will be installed in the central portion of
the Site;
 One temporary monitoring well (BF-TWM-7) will be installed in the eastern portion of
the Site, near the former metal plating wastewater AST staging area; and
 One temporary monitoring well (BF-TMW-8) will be installed in the southern portion of
the Site.

The temporary groundwater monitoring well borings will be advanced with a track-mounted drill
rig capable of utilizing hollow-stem auger and/or air rotary drilling techniques. During drilling,
soil cuttings will be collected and logged for lithologic description and field screened for the
presence of obvious staining, unusual odors, and elevated volatile organic vapors using a
calibrated PID. Should obvious evidence of impacts be observed based on field screening
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results, a soil sample will be collected for laboratory analysis using the methodologies described
in Section 2.2 above.

The temporary groundwater monitoring wells will be constructed of 1 or 2-inch diameter PVC
with a 10 to 15 ft section of pre-pack well screen set to bracket the water table and 1 or 2-inch
diameter PVC well casing to the ground surface. A sand filter pack will be placed from the
bottom of the borings to approximately 2 ft above the top of the well screens. The temporary
wells will be completed by placing a minimum of an approximately 2 ft thick hydrated bentonite
seal above the sand filter pack.

Once the temporary monitoring wells are installed, the wells will be allowed to stabilize and
equilibrate to static conditions for approximately 24 hours following installation, and a
decontaminated electronic water level indicator will be used to measure the depth to the water
table relative to the ground surface and tops of well casings in each well. The wells will then be
developed by removing a minimum of 3 to 5 volumes and until field parameters have stabilized
(pH± 0.1 Standard Units [SU] and conductivity varies no more than 5%). The ground surface
and top of well casings at each temporary monitoring well location will be surveyed by H&H
relative to a known elevation benchmark at the Site to calculate groundwater elevations and
estimate groundwater flow direction at the Site.

After development, groundwater samples will be collected utilizing low flow/low stress purging
techniques using a peristaltic pump or bladder pump and dedicated polyethylene tubing. The
intake point of the pump tubing will be placed in the approximate mid-portion of the screened
interval of the well, and groundwater will be removed at a rate no greater than 200 milliliters per
minute. H&H will utilize calibrated water quality meters to collect measurements of pH,
temperature, dissolved oxygen, oxidation reduction potential, turbidity, and specific conductivity
at three to five-minute intervals during the purging process. Purging will be considered complete
when the field parameters stabilize (pH ± 0.1 SU, conductivity varies no more than 5%, and
turbidity is less than 10 Nephelometric Turbidity Units [NTUs]).

Once groundwater parameters stabilize, groundwater samples for VOC analysis will be collected
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directly into laboratory supplied sample containers using the “soda straw” method to minimize
the potential for volatile compound loss through the peristaltic pump head. Samples collected
for the remaining analyses will be collected directly into laboratory supplied sample containers
from the dedicated sample tubing discharge. The sample containers will be labeled with the
sample identification, date, time, and requested analysis, and placed in a laboratory supplied
cooler with ice. Groundwater samples BF-TMW-1 through BF-TMW-6 will be delivered to a
North Carolina certified laboratory under standard chain of custody protocols for analyses of
VOCs by EPA Method 8260, SVOCs by EPA Method 8270, and RCRA metals by EPA Method
6020/7470. Groundwater samples BF-TMW-7 and BF-TMW-8 will be delivered to a North
Carolina certified laboratory under standard chain of custody protocols for analyses of VOCs by
EPA Method 8260, SVOCs by EPA Method 8270, RCRA metals plus copper, aluminum, nickel,
and zinc by EPA Method 6020/7470, and cyanide by EPA Method 4500.

The groundwater sample locations will be estimated using a hand-held GPS unit. Following
sampling activities, the temporary monitoring wells will be permanently abandoned by a licensed
well driller and the surfaces will be repaired similar to pre-drilling conditions.

2.4 Soil Gas Sampling Activities

To evaluate the potential for structural vapor intrusion into the proposed buildings and to
establish baseline soil gas concentrations beneath the existing Site buildings, H&H will install
and sample eleven (11) temporary sub-slab soil gas sampling points. Note that the sub-slab soil
gas points may be adjusted due to access limitations and to minimize damage to the floor or floor
coverings. The proposed sub-slab soil gas sampling point locations are shown in Figure 4, and
the sampling activities are described below.

H&H proposes to install sub-slab soil gas sample points (BF-SSV-1 through BF-SSV-11) for the
collection of soil gas samples beneath the existing Site buildings. The sampling points will be
installed using a rotary hammer drill and 1½-inch diameter drill bit to advance a pilot hole into
the concrete slab to a depth of approximately 1¾ inches below the surface. A drill guide will
then be placed in the pilot hole, and a 5/8-inch diameter drill bit will be utilized to advance the
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drill bit through the concrete slab and into the underlying soil. Following concrete borehole
advancement, loose concrete cuttings will be removed from each boring, and a Cox-Colvin
Vapor Pin™ (vapor pin) assembly (brass sampling point and silicone sleeve) will be seated in the
borehole using an installation/extraction tool and hammer to form an airtight seal. After
installation, the sub-slab soil gas points will be allowed to equilibrate for approximately 20
minutes before sampling activities begin.

The sub-slab soil gas samples will be collected utilizing laboratory supplied batch certified
Summa® canisters (1 or 3-liter canisters depending on laboratory availability) connected to an
air-flow regulator calibrated by the laboratory to collect the soil gas sample at a rate of
approximately 100 mL/min. Prior to collection of the soil gas samples, a “shut-in” test will be
conducted on the sampling train and helium leak checks will be conducted at each soil gas
sampling point. The purpose of the shut-in test and helium leak check is to ensure short
circuiting with ambient air does not occur during sampling. A description of the shut-in test and
helium leak testing procedures is provided below.

The shut-in test will be conducted by connecting the flow regulator with the vacuum gauge to the
Summa® canister and sealing the flow regulator with the laboratory provided brass cap. Once
the sampling train is “closed”, the sample valve on the Summa® canister will be opened and the
reading on the vacuum gauge will be recorded. The Summa® canister sample valve will then be
closed and the vacuum gauge will be observed to ensure no vacuum loss occurs. If the vacuum
reading remains the same, the shut-in test will be considered successful. If vacuum loss occurs,
the flow regulator and/or brass cap will be reseated, and the shut-in test will be repeated until the
vacuum reading remains stable.

Following the shut-in test, the Summa® canister will be connected to the sample point via
Teflon® sample tubing using a brass nut and ferrule assembly to create an airtight seal and the
leak check will be performed. The leak check will be performed by constructing a shroud over
the entire sampling train and flooding the shroud with helium gas. A calibrated helium gas
detector will be utilized to measure helium concentrations within the shroud. Once helium
concentrations stabilize within the shroud, the sample tubing will be purged of a minimum of
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three sample train volumes outside of the shroud using a syringe and a three-way valve and a soil
gas sample will then be collected into a Tedlar® bag. The purged soil gas will then be analyzed
using the helium gas detector to ensure that helium concentrations in the soil gas point are less
than 10% of the helium concentrations measured within the shroud.

Following successful leak checks, the sample valves on the Summa® canisters will be opened
and the soil gas samples will be collected. Vacuum readings on the Summa® canisters will be
recorded prior to and following the sampling period to ensure adequate sample volume was
collected. A vacuum of approximately 5 inches of mercury or more will be maintained within
the canisters at the conclusion of the sampling event in accordance with DEQ DWM Vapor
Intrusion Guidance. Following sample collection, the Summa® canisters will be shipped to a
laboratory under standard chain-of-custody protocols for analysis of VOCs by EPA Method TO-
15. The laboratory will be requested to use reporting limits that are below DEQ Residential
Vapor Intrusion SGSLs.

After sampling is complete, the sample locations will be estimated by measuring from known
benchmarks within the buildings (e.g., doors, windows, etc.), and the sample locations will be
abandoned with surfaces repaired similar to pre-drilling conditions.

2.5 Quality Assurance – Quality Control

Non-dedicated equipment and tools will be decontaminated prior to use at each boring or
sampling location or following exposure to soil or groundwater. The following samples will be
collected for quality assurance/quality control (QA/QC) purposes:

 One duplicate soil and groundwater sample will be collected and analyzed for the same
parameters as the parent samples per field day.
 One trip blank will accompany the groundwater samples during the field activities as well
as during sample shipment and will be analyzed for VOCs by EPA Method 8260.
 One duplicate sub-slab soil gas sample will be collected using a laboratory supplied “t-
fitting” which allows for two sub-slab soil gas samples to be collected from one sampling
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point simultaneously. The duplicate soil gas sample will be submitted for analysis of
VOCs by EPA Method TO-15.

Laboratory QA/QC procedures will be employed to ensure appropriate sample handling and
analysis and to aid in the review and validation of the analytical data. QA/QC procedures will be
conducted in accordance with the method protocols and will include regular equipment
maintenance, equipment calibrations, and adherence to specific sample custody and data
management procedures. Samples will be analyzed in conjunction with appropriate blanks,
laboratory duplicates, continuing calibration standards, surrogate standards, and matrix spiking
standards in accordance with approved methodologies to monitor both instrument and analyst
performance. Laboratory reporting limits for each analyte will be at or below appropriate
screening criteria, where possible. Additionally, H&H will request that the laboratory include
estimated concentrations for compounds that are detected at levels above the laboratory method
detection limit, but below the laboratory reporting limit (J flags).

The laboratory analytical data report and QA package for each group of samples submitted to
and analyzed by the subcontracted laboratory will be provided in an appendix to the final report.
Laboratory QA data consistent with Level II documentation will be provided for this project.
A copy of the completed chain of custody record and shipping receipt will be appended to the
corresponding laboratory analytical report included with the final report.

2.6 Investigation Derived Waste

Soil investigation derived waste (IDW) generated at the Site will be containerized and staged on-
Site. Analytical results of the assessment activities will be used to characterize the waste for
disposal. IDW generated during the proposed assessment activities will be managed in
accordance with 15A NCAC 02T.1503 and 15A NCAC 02H.0106.
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3.0 Reporting

Following completion of the assessment activities and receipt of the analytical data, H&H will
document our findings in a Brownfields Assessment Report. The report will include a
description of the sampling activities; a figure depicting sample locations; a figure showing the
potentiometric surface and estimated groundwater flow direction, boring logs for the soil borings
and temporary well borings, temporary well construction logs; field forms and sampling logs;
laboratory analytical data; a discussion of the data in comparison to regulatory screening levels;
and conclusions and recommendations concerning our activities. H&H will also use the most
recent version of the DEQ risk calculator to further evaluate potential risks based on the data, if
warranted. The Brownfields Assessment Report will include the firm PE/PG license numbers
and individual PE/PG seal and signature.

Table 1Sample Summary TablePiedmont Plating & AnodizingCharlotte, North Carolina Brownfields Project No. 26061-22-060H&H Project No. H&A-002Sample IDs Sample Type Sample ObjectiveApproximate Boring Depth (ft)Approximate Sample Depth (ft)Number of Samples Laboratory AnalysisBF-SB-1 and BF-SB-11Evaluate background soil conditions 8 TBD 2VOCs (8260), SVOCs (8270), and RCRA metals plus hexavalent chromium, copper, aluminum, nickel, and zinc (6020/7471/7199), and cyanide (4500)BF-SB-2 through BF-SB-6Evaluate soil near rail spur/loading areas 5 TBD 5VOCs (8260), SVOCs (8270), and RCRA metals plus hexavalent chromium (6020/7471/7199)BF-SB-7 through BF-SB-10Evaluate soil in plating areas 8 TBD 4VOCs (8260), SVOCs (8270), and RCRA metals plus hexavalent chromium, copper, aluminum, nickel, and zinc (6020/7471/7199), and cyanide (4500)BF-TMW-1 through BF-TMW-6Evaluate groundwater conditions 20-35 varies 6VOCs (8260), SVOCs (8270), and RCRA metals (6020/7470)BF-TMW-7Evaluate groundwater conditions in plating area 20-35 varies 1VOCs (8260), SVOCs (8270), RCRA metals plus copper, aluminum, copper, nickel, and zinc (6020/7470), and cyanide (4500)BF-TMW-8Evaluate background groundwater conditions 20-36 varies 1VOCs (8260), SVOCs (8270), RCRA metals plus copper, aluminum, copper, nickel, and zinc (6020/7470), and cyanide (4500)BF-SSV-1 through BF-SSV-11 Sub-Slab Soil Gas Evaluate potential VI risks below the slab below the slab 11 VOCs (TO-15)BF-SB-DUP Soilvaries varies 1VOCs (8260), SVOCs (8270), and RCRA metals plus hexavalent chromium, copper, aluminum, nickel, and zinc (6020/7471/7199), and cyanide (4500)BF-GW-DUP Groundwater varies varies 1VOCs (8260), SVOCs (8270), RCRA metals plus copper, aluminum, copper, nickel, and zinc (6020/7470), and cyanide (4500)BF-SG-DUP Soil Gasvaries varies 1 VOCs (TO-15)Trip Blank Trip BlankNA NA 1 VOCs (8260)Notes:EPA method number follows the laboratory parameter in parenthesis. VOCs = volatile organic compounds; SVOCs = semi-volatile organic compounds; RCRA = Resource Conservation Recovery Actft = feet; QA/QC = quality assurance/ quality control; VI = vapor intrusion; NA = not applicableTBD = to be determined based on field screening resultsSoil QA/QCGroundwaterhttps://harthick.sharepoint.com/sites/MasterFiles‐1/Shared Documents/AAA‐Master Projects/Hoffman & Associates/H&A‐002 2401 Distribution St/Brownfields Assessment/Work Plan/Tables & Figures/Sample Summary TableTable 1 (Page 1 of 1)Hart & Hickman, PC
USGS The National Map: National Boundaries Dataset, 3DEP ElevationProgram, Geographic Names Information System, National HydrographyDataset, National Land Cover Database, National Structures Dataset,and National Transportation Dataset; USGS Global Ecosystems; U.S.Census Bureau TIGER/Line data; USFS Road Data; Natural Earth Data;U.S. Department of State Humanitarian Information Unit; and NOAANational Centers for Environmental Information, U.S. Coastal ReliefModel. Data refreshed June, 2022.
SITE LOCATION MAP
PIEDMONT PLATING & ANODIZING COMPANYDISTRIBUTION STREET & DUNAVANT STREETCHARLOTTE, NORTH CAROLINA
DATE: 3-9-23
JOB NO: H&A-002
REVISION NO: 0
FIGURE NO: 1
2923 South Tryon Street - Suite 100Charlotte, North Carolina 28203704-586-0007 (p) 704-586-0373 (f)License # C-1269 / # C-245 Geology
TITLE
PROJECT02,000 4,000
SCALE IN FEET
SITE
Path: C:\Users\sperry\OneDrive - Hart & Hickman\My Documents\ArcGIS\PROJECTS\H&A-002\H&A-002 Figure-1.mxdN
U.S.G.S. QUADRANGLE MAP
CHARLOTTE EAST, NORTH CAROLINA 2022
QUADRANGLE7.5 MINUTE SERIES (TOPOGRAPHIC)
REVISION NO. 0
JOB NO. H&A-002
DATE: 3-17-23
FIGURE NO. 2
PIEDMONT PLATING & ANODIZING COMPANY
DISTRIBUTION STREET & DUNAVANT STREET
CHARLOTTE, NORTH CAROLINA
SITE MAP
LEGEND
SITE AND BROWNFIELDS PROPERTY
BOUNDARY
PARCEL LINE
POLE-MOUNTED TRANSFORMER
DUMPSTER
GREASE TRAP
NOTES:
1.AERIAL IMAGERY AND BASE DATA OBTAINED FROM
MECKLENBURG COUNTY GIS, 2023.
2.BPN: BROWNFIELDS PROPERTY NUMBER
2923 South Tryon Street-Suite 100
Charlotte, North Carolina 28203
704-586-0007(p) 704-586-0373(f)
License # C-1269 / #C-245 GeologyDUNAVANT STREETDISTRIBUTION STREETPARKER MEDICAL ASSOCIATES
(2400 DISTRIBUTION STREET)
B&G LIEBERMAN
(2412-2420 DISTRIBUTION STREET)
GRIER INTERIORS
(2326-2328 DISTRIBUTION STREET)
UNDER CONSTRUCTION
(CRAYTON PRINTING
BROWNFIELDS PROPERTY
[BPN:24025-20-060])
JUNCTION 1504 LUXURY
APARTMENT COMPLEX
(1504 MAINLINE BOULEVARD)
(SOUTH END TRANSIT
BROWNFIELDS PROPERTY
[BPN: 10036-06-060]
COXSCHEPP CONSTRUCTION
(2408-2410 DUNAVANT STREET)
PARKING LOT
(2401 DISTRIBUTION STREET)
(2322 DUNAVANT STREET)
(2400 DUNAVANT STREET)
(2402-2406 DUNAVANT STREET)S:\AAA-Master Projects\Hoffman & Associates\H&A-002 2401 Distribution St\Phase I ESA\Figures\H&A-002-PH-I_SITE.dwg, FIG 2, 3/17/2023 6:36:49 AM, tmarbuery
REVISION NO. 0
JOB NO. H&A-002
DATE: 3-20-23
FIGURE NO. 3
PIEDMONT PLATING & ANODIZING COMPANY
DISTRIBUTION STREET & DUNAVANT STREET
CHARLOTTE, NORTH CAROLINA
HISTORICAL OPERATIONS AND
SAMPLE LOCATION MAP
LEGEND
SITE PROPERTY BOUNDARY
PARCEL LINE
POLE-MOUNTED TRANSFORMER
DUMPSTER
GREASE TRAP
PERMANENT MONITORING WELL
TEMPORARY MONITORING WELL
PRIOR TEMPORARY MONITORING
WELL LOCATION
PRIOR SOIL BORING LOCATION
PRIOR SOIL GAS SAMPLE LOCATION
FORMER ABOVE GROUND STORAGE
TANK LOCATIONS
NOTES:
1. AERIAL IMAGERY AND BASE DATA OBTAINED FROM
MECKLENBURG COUNTY GIS, 2023.
2. MW-4, MW-5, AND TMW-3 SAMPLE LOCATIONS OBTAINED
FROM ADDITIONAL BROWNFIELDS ASSESSMENT REPORT
PREPARED BY H&H DATED DECEMBER 2020.
3. HISTORICAL SITE FEATURES OBTAINED FROM PHASE 1
ESA PREPARED BY ERM DATED OCTOBER 2007.
2923 South Tryon Street-Suite 100
Charlotte, North Carolina 28203
704-586-0007(p) 704-586-0373(f)
License # C-1269 / #C-245 GeologyDUNAVANT STREETDISTRIBUTION STREETPARKING LOT
FORMER
STORAGE
AREA
MW-4
MW-5
TMW-1
B-1
B-2
B-3*
TMW-3
FORMER
PROCESS
AREA
FORMER
OFFICE
AREA
FORMER
WASTEWATER
PRETREATMENT
FO
R
M
E
R

L
I
T
H
O
G
R
A
P
H
I
C
PRI
N
T
I
N
G

O
P
E
R
A
T
I
O
N
S
FORMER PIEDMONT
PLATING & ANODIZING
COMPANY
FORMER COLORA KNITS
MANUFACTURING AND GOLD
SEAL MANUFACTURING
FORMER CRAYTON PRINTING
FORMER QUALITY
MARBLE & GRANITE AND
FORMER GELBACH DESIGN
SG-1SG-2
SG-1
SG-2
SG-3 B-1
SG-1
SG-2
FORMER SIFCO SELECTIVE
PRINTING AND OTHER VARIOUS
COMMERCIAL, RETAIL, AND
DISTRIBUTION USES
FORMER VARIOUS
COMMERCIAL, RETAIL,
AND DISTRIBUTION USES
FO
R
M
E
R

D
A
I
R
Y
EQ
U
I
P
M
E
N
T
MA
N
U
F
A
C
T
U
R
I
N
G
FORMER KINGS CRANKSHAFT CO.
(CUSTOM CRANKS ASSEMBLY AND REPAIR)
AND OTHER VARIOUS COMMERCIAL,
RETAIL, AND DISTRIBUTION USES
FORMER RAILROAD SPURS
S:\AAA-Master Projects\Hoffman & Associates\H&A-002 2401 Distribution St\Phase I ESA\Figures\H&A-002-PH-I_SITE.dwg, FIG 3 (2), 3/20/2023 3:04:37 PM, tmarbuery
REVISION NO. 0
JOB NO. H&A-002
DATE: 4-13-23
FIGURE NO. 4
PIEDMONT PLATING & ANODIZING COMPANY
DISTRIBUTION STREET & DUNAVANT STREET
CHARLOTTE, NORTH CAROLINA
PROPOSED SAMPLE LOCATION MAP
LEGEND
BROWNFIELDS PROPERTY BOUNDARY
PARCEL LINE
PROPOSED RETAIL SPACE
PROPOSED LOBBY SPACE
PROPOSED UTILITY SPACE
PROPOSED PARKING AREA
PRIOR TEMPORARY MONITORING
WELL LOCATION
PRIOR SOIL BORING LOCATION
PRIOR SOIL GAS SAMPLE LOCATION
PROPOSED TEMPORARY MONITORING
WELL LOCATION
PROPOSED CO-LOCATED TEMPORARY
MONITORING WELL AND SOIL BORING
LOCATION
PROPOSED SUB-SLAB GAS SAMPLE
LOCATION
PROPOSED SOIL BORING LOCATION
NOTES:
1.AERIAL IMAGERY AND BASE DATA OBTAINED
FROM MECKLENBURG COUNTY GIS, 2022.
2.PRIOR SAMPLE LOCATIONS OBTAINED FROM
PHASE II SUBSURFACE INVESTIGATION REPORTS
PREPARED BY PARTNER ENGINEERING DATED
MAY 2021, DECEMBER 2021, AND MAY 2022.
3.*GROUNDWATER SAMPLE NOT COLLECTED DUE
TO DRILL RIG REFUSAL PRIOR TO ENCOUNTERING
THE GROUNDWATER SAMPLE.
2923 South Tryon Street-Suite 100
Charlotte, North Carolina 28203
704-586-0007(p) 704-586-0373(f)
License # C-1269 / #C-245 GeologyDUNAVANT STREETDISTRIBUTION STREETSG-1SG-2
SG-1
SG-2
SG-3 B-1
SG-1
SG-2
TMW-1*
B-1*
B-2*
B-3*
BF-SSV-1
BF-SSV-2
BF-SSV-8
BF-TWM-1/SB-1
BF-TMW-3/SB-2
BF-TMW-4
BF-SB-10
BF-SB-8BF-SB-9
BF-SSV-7
BF-SSV-9
BF-SSV-10
BF-SSV-11
BF-SSV-6
BF-SSV-5
BF-SB-3
BF-SB-5
BF-SB-4
BF-SB-6
BF-SSV-4
BF-SSV-3
BF-TMW-6
BF-TMW-7/BF-SB-7
BF-TWM-2
FORMER RAILROAD SPURS
BF-TMW-5
BF-TMW-8/SB-11
S:\AAA-Master Projects\Hoffman & Associates\H&A-002 2401 Distribution St\Figures\H&A-002-PH-I_SAMPLE.dwg, FIG 4, 4/13/2023 12:08:33 PM, tmarbuery

Appendix A

Historical Analytical Data

Table 1: Summary of Investigation Scope
2322 Dunavant Street
Charlotte, North Carolina 28203
Partner Project Number 21-342779.2
November 27, 2021
Boring
Identification REC/Issue Location
Terminal
Depth
(feet bgs)
Matrix
Sampled
Sampling
Depths
(feet bgs)
Target Analytes
Notes:
PAH = Polycyclic Aromatic Hydrocarbons
REC = Recognized Environmental Condition
VOCs = Volatile Organic Compounds
bgs = below ground surface
*Drilling refusal encountered at terminal depth
VOCs, PAHsSoil8
VOCs
B-1
Historical On-site Use and
Identified groundwater
impacts on the northeast-
adjacent property
Exterior east side of on-site building
within grassed area 8*VOCs, PAHs
Soil Gas 5
Soil 8
SG-2
Historical On-Site Use and
Identified groundwater
impacts on the northeast-
adjacent property
Exterior northwest side of existing on-
site building within asphalt-paved
area
B-3
Historical On-Site Use and
Identified groundwater
impacts on the northeast-
adjacent property
Exterior northwest side of existing on-
site building within asphalt-paved
area
8*
B-2
Historical On-Site Use and
Identified groundwater
impacts on the northeast-
adjacent property
Exterior northeast side of existing on-
site building within asphalt-paved
area
12*Soil 12 VOCs, PAHs
VOCsSG-1
Exterior northeast side of existing on-
site building within asphalt-paved
area
5
Historical On-Site Use and
Identified groundwater
impacts on the northeast-
adjacent property
Soil Gas 5
5
Table 2: Soil Gas Sample Laboratory Analysis Results
2322 Dunavant Street
Charlotte, North Carolina 28203
Partner Project Number 21-342779.2
November 27, 2021
Acetone 220,000 2,700,000 373 56.1
Benzene 12.0 160 22.8 8.56
1,3-Butadiene 3.1 41.0 24.8 <0.90
2-Butanone 35,000 440,000 88.2 3.30
Carbon Disulfide 4,900 61,000 22.7 <1.27
Chloromethane 630 7,900 <3.43 0.861
Cyclohexane 42,000 530,000 <5.71 1.49
Dichlorodifluoromethane 700 8,800 <8.21 2.24
Ethyl Alcohol NE NE 104 <19.2
Ethylbenzene 37.0 490 13.9 6.69
n-Hexane 4,900 61,000 23.5 9.37
2-Hexanone 210 2,600 20.5 <1.67
Heptane 2,800 35,000 12.3 5.66
Propylene 21,000 260,000 540 2.38
1,2,4-Trimethylbenzene 420 5,300 23.2 6.10
2,2,4-Trimethylpentane NE NE 9.01 10.5
4-Methyl-2-pentanone 21,000 260,000 100 <4.18
Toluene 35,000 440,000 56.9 55.0
Xylenes (Total)700 8,800 67.3 36.1
Other VOCs Various Various <MDL <MDL
Notes:
EPA = United States Environmental Protection Agency
NCDEQ = North Carolina Department of Environmental Quality
SGSLs = Soil Gas Screening Levels (January 2021)
TCR = Target Cancer Risk
THQ = Target Hazardous Quotient
VOCs = Volatile Organic Compounds
µg/m3 = micrograms per cubic meter
< = not detected above indicated laboratory method detection limit (MDL)
<MDL = not detected above the laboratory MDL
Values inboldexceed laboratory MDLs
Chlorinated VOCs via EPA Method TO-15 (µg/m3)
SG-1Analyte SG-2
NCDEQ ResidentialSub-Slab and Exterior
SGSLs(TCR=1E-06 or
THQ=0.2)
NCDEQ Non-Residential Sub-Slab
and Exterior SGSLs(TCR=1E-06 or
THQ=0.2)
Table 3: Soil Sample Laboratory Analysis Results
2322 Dunavant Street
Charlotte, North Carolina 28203
Partner Project Number 21-342779.2
November 27, 2021
Chemical of Concern
NCDEQ Industrial/
Commercial
PSRGs
NCDEQ
Protection of
Groundwater
PSRGs
B-1(8')B-2(12')B-3(8')
VOCs Various Various <MDL <MDL <MDL
PAHs Various Various <MDL <MDL <MDL
Notes:
EPA = United States Environmental Protection Agency
PAHs = Polycyclic Aromatic Hydrocarbons
PSRGs = Preliminary Soil Remediation Goals (January 2021)
NCDEQ = North Carolina Department of Environmental Quality
VOCs = Volatile Organic Compounds
mg/kg = milligram per kilogram
<MDL = not detected above the laboratory method detection limit (MDL)
VOCs via EPA Method 8260D (mg/kg)
PAHs via EPA Method 8270E (mg/kg)
Legend
Figure DatePrepared By8720 Red Oak Boulevard, Suite 528
Charlotte, North Carolina 28217
Project Number: 21-342779.2
Site Vicinity Map
1
2322 Dunavant Street
Charlotte, North Carolina 28203
WKJ Dec 2021
Subject PropertyN
Scale
1” = 250’
Cox Schepp
Construction
(2408 Dunavant
Street)
Graded Land/
Under Construction
Residential
Multi--Family
Multi-Family
Residential
Multi-Family
Residential
Graded Land/
Under Construction
Commercial
Under Construction
Graded Land/
Project Number: 21-342779.2
Topographic Map
2
2223 Dunavant Street
Charlotte, North Carolina 28203
Dec 2021WKJN
Legend
Subject Property
Charlotte East, North Carolina Topographic
Quadrangle
Figure DatePrepared By8720 Red Oak Boulevard, Suite 528
Charlotte, North Carolina 28217
Legend
Figure Date
Approximate Scale: 1” = 80’
Prepared By8720 Red Oak Boulevard, Suite 528
Charlotte, North Carolina 28217
Project Number: 21-342779.2
Monitoring Well Location Map
3
2322 Dunavant Street
Charlotte North Carolina 28203
WKJ Dec 2021
0 804040 20
N Subject Property
SV-2
Asphalt
Concrete
MW-2
Grass
Asphalt-Paved
Parking Area
Grass
Concrete
Asphalt-Paved
Parking Area
Graded Land/
Under Construction
Asphalt-Paved
Parking Area
Grass
Grass MW-1
SG-1
Soil Gas Probe
Soil Boring
SG-2
B-1
B-2
B-3
Graded Land/
Under Construction
Grass
Grass
Asphalt
2322
Construction
Cox Schepp
(2408 Dunavant
Street)
Multi-Family
Residential
Wall
Retaining
Table 1: Summary of Investigation Scope
2400 Dunavant Street
Charlotte, North Carolina 28203
Partner Project Number 22-363859.3
May 12, 2022
Boring
Identification REC/Issue Location
Terminal
Depth
(feet bgs)
Matrix
Sampled
Sampling
Depths
(feet bgs)
Target Analytes
TMW-1 Former Printing
Operations
Southeast exterior of the
2402 Dunavant Street tenant
space
10*Soil 4 to 6 VOCs, SVOCs,
RCRA 8 Metals
Soil 4 to 5 VOCs, SVOCs,
RCRA 8 Metals
Soil Gas 5 VOCs
Soil 4 to 5 VOCs, SVOCs,
RCRA 8 Metals
Soil Gas 5 VOCs
Notes:
Former Printing
Operations
Former Printing
Operations
RCRA = Resource Conservation and Recovery Act
*Drilling refusal encountered at terminal depth.
SVOCs = semi-volatile organic compounds
VOCs = volatile organic compounds
SG-1 Southeast interior of the 2402
Dunavant Street tenant space 5
SG-2
Northwest interior of the
2402 Dunavant Street tenant
space
5
REC = recognized environmental condition
Table 2: Soil Sample Laboratory Results
2400 Dunavant Street
Charlotte, North Carolina 28203
Partner Project Number 22-363859.3
May 12, 2022
Analyte
Protection of
Groundwater
PSRG
Residential
Health Based
PSRG
Commercial/
Industrial Health
Based PSRG
TMW-1 SG-1 SG-2
All Analyzed VOCs Varies Varies Varies <MDL <MDL <MDL
All Analyzed SVOCs Varies Varies Varies <MDL <MDL <MDL
Arsenic (As)5.8 0.68 3.0 <0.599 <0.728 <0.709
Barium (Ba)1 580 3,100 47,000 32.7 80.0 49.3
Cadmium (Cd)3.0 1.4 20 <0.0544 <0.0662 <0.0645
Chromium (Cr)3.8/24,000**0.31/350,000**6.5/360,000**52.7 163 46.5
Lead (Pb)270 400 h! I'm sorry I misread that 6.38 8.30 7.55
Mercury (Hg)NE 4.7 70 0.0068 0.046 0.047
Selenium (Se)1 2.1 78 1,200 <0.883 3.55 <1.05
Silver (Ag)3.4 78 1,200 <0.147 <0.179 <0.174
Notes:
EPA = United States Environmental Protection Agency
mg/kg = milligrams per kilogram
<MDL = not detected above the laboratory method detection limit
SVOCs = semi-volatile organic compounds
RCRA = Resource Conservation and Recovery Act
< = not detected above the indicated laboratory MDL
NE = not established
Concentrations in bold detected above the laboratory MDL
Highlighted concentrations exceed one or more regulatory standard
PSRG = Preliminary Soil Remediation Goal (January 2022)
VOCs = volatile organic compounds
Background
Concentrations*
**First regulatory standard is for Hexavalent Chromium, second regulatory standard is for Trivalent Chromium
*From Elements of North American Soils, Second Edition, Dragun, J. and Chekiri, K, Amherst Scientific Publishers, Amherst, Massachusetts, 2005.
VOCs via EPA Method 8260D (mg/kg)
N/A
SVOCs via EPA Method 8270E (mg/kg)
RCRA 8 Metals via EPA Methods 6010D and 7471 (mg/kg)
N/A
1.0-18
50-1,000
0.02-10
7.5-300
0-50
0.03-52
<0.1-0.8
0.-5.0
Table 3: Soil Gas Sample VOCs Laboratory Results
2400 Dunavant Street
Charlotte, North Carolina 28203
Partner Project Number 22-363859.3
May 12, 2022
Analyte Residential SGSL Commercial/
Industrial SGSL SG-1 SG-2
Acetone NE NE 42.5 25.7
Benzene 12.0 160 21.8 14.3
Carbon disulfide 4,900 61,000 2.01 21.5
Chloromethane 630 7,900 1.14 1.03
Cyclohexane 42,000 530,000 <0.689 5.82
Ethanol NE NE 16.1 J3 16.3 J3
Ethylbenzene 37.0 490 26.2 17.4
4-Ethyltoluene NE NE 22.2 15.8
Trichlorofluoromethane NE NE 1.60 1.53
Dichlorodifluoromethane 700 8,800 2.43 2.38
Heptane 2,800 35,000 11.9 9.61
n-Hexane 4,900 61,000 22.7 38.1
Methyl Butyl Ketone 210 2,600 <5.11 5.69
2-Butanone 35,000 440,000 5.04 3.98
2-Propanol 1,400 18,000 <3.07 3.29
1,1,2,2-Tetrachloroethane 1.6 21.0 <1.37 4.24
Toluene 35,000 440,000 149 93.8
Trichloroethylene 14.0 180 <1.07 11.7
1,2,4-Trimethylbenzene 420 5,300 24.2 16.9
1,3,5-Trimethylbenzene 420 5,300 6.38 4.52
2,2,4-Trimethylpentane NE NE 44.3 40.8
Total Xylenes 700 8,800 138.3 86.4
Other Analyzed VOCs Varies Varies <RDL <RDL
Notes:
SGSL = Soil Gas Screening Level
VOCs = volatile organic compounds
EPA = United States Environmental Protection Agency
mg/m3 = micrograms per liter
NE = not estabished
< = not detected above indicated laboratory reported detection limit (RDL)
J3 = The associated batch QC was outside the established quality control range for precision.
<RDL = not detected above the laboratory RDLs
Concentrations in bold detected above the laboratory RDL
Highlighted values exceed the Residential SGSL
VOCs via EPA Method TO-15 (µg/m3)
DUNAVANT STREETThe Dunavant and
Barton Marlow
Junction 1504 Luxury
Apartments
Cap Rock and
CoxSchepp
Construction
Condominiums
Vacant Building
Vac
a
n
t

S
u
i
t
eMr
s.
H
o
w
a
r
ds

F
i
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e

Fu
r
n
i
s
h
i
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g
s

&

I
n
t
erio
r
s
SL
-
L
a
s
e
r

S
ys
t
e
m
s
2154 Torrance Boulevard, Suite 200
Torrance, California 90501
Legend
Figure Prepared By Date
Approximate Scale: 1” = 60’
Project Number: 22-363859.3
Site Vicinity Map
1 V. LarsonN
2400 Dunavant Street
Charlotte, North Carolina 28203
May 2022
Subject Property
0 60303015
Project Number: 22-363859.4
Topographic Map
2
2400 Dunavant Street
Charlotte, North Carolina 28203
May 2022
USGS Charlotte East, North Carolina
Quadrangle, 7.5 Minute Series
Version: 2019
V. LarsonN
Subject
Property
Subject
Property
Figure DatePrepared By
2154 Torrance Boulevard, Suite 200
Torrance, California 90501
Notes:
-ADD NOTES FOR ACRONYMS
The Dunavant and
Barton Malow
Vac
a
n
t

S
u
i
t
e
Mr
s
.

H
o
w
a
r
d

F
i
n
e

F
u
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n
i
s
h
i
n
g
s

&

I
n
t
e
r
i
o
r
s

S
tor
a
g
e
SL
-
L
a
s
e
r

S
yst
e
m
CapRock and
CoxSchepp
ConstructionRear Loading DockPl
a
n
t
e
r
Wooded Land
Paved
Parking
Paved
Parking
Paved
Parking
Temporary Monitoring Well
Soil Boring/Soil Gas Probe
SG-1
SG-2
TMW-1
Legend
Figure Date
Approximate Scale: 1” = 25’
Prepared By
2154 Torrance Boulevard, Suite 200
Torrance, California 90501
Project Number: 22-363859.3
Sample Location Map
3
2400 Dunavant Street
Charlotte, North Carolina 28203
V. Larson May 2022
Subject Property
0 2512.512.5
N
Table 1: Summary of Investigation Scope
2401 Distribution Street
Charlotte, North Carolina 28203
Partner Project Number 21-315565.3
May 14, 2021
Boring
Identification REC/Issue Location
Terminal
Depth
(feet bgs)
Matrix
Sampled
Sampling
Depths
(feet bgs)
Target Analytes
Notes:
REC = Recognized Environmental Condition
bgs = below ground surface
VOCs = Volatile Organic Compounds
*Drilling refusal encountered at terminal depth
VOCsGroundwater7.93
Chlorinated
VOCs
SG-3
Identified
groundwater
impacts on the
north adjacent
property
Northeast exterior of the subject
property building within the asphalt-
paved parking area
3 Chlorinated
VOCs
Soil Gas 3
Soil Gas 3
SG-2
Identified
groundwater
impacts on the
north adjacent
property
North-central exterior of the subject
property building within the asphalt-
paved parking area
3
B-1
Identified
groundwater
impacts on the
north adjacent
property
Northeast property boundary within
asphalt-paved parking area 12*
Chlorinated
VOCsSG-1
Northwest exterior of the subject
property building within the asphalt-
paved parking area
3
Identified
groundwater
impacts on the
north adjacent
property
Soil Gas 3
Table 2: Soil Gas Sample Laboratory Analysis Results
Distribution Street Site
2401 Distribution Street
Charlotte, North Carolina 28203
Partner Project Number 21-315565.3
May 14, 2021
Tetrachloroethylene 280 3,500 1.6 2.6 6.2
Trichloroethylene 14 180 <0.33 <0.33 3.6
Vinyl chloride 5.6 280 <0.15 0.59 <0.15
Other VOCs Various Various <MDL <MDL <MDL
Notes:
NCDEQ = North Carolina Department of Environmental Quality
SGSLs = Soil Gas Screening Levels (January 2021)
TCR = Target Cancer Risk
THQ = Target Hazardous Quotient
VOCs = Volatile Organic Compounds
EPA = United States Environmental Protection Agency
µg/m3 = micrograms per cubic meter
< = not detected above indicated laboratory method detection limit (MDL)
<MDL = not detected above the laboratory MDL
Values in bold exceed laboratory MDLs
Chlorinated VOCs via EPA Method TO-15 (µg/m3 )
SG-1Analyte SG-3
NCDEQ Residential
Sub-Slab and Exterior
SGSLs
(TCR=1E-06 or
THQ=0.2)
NCDEQ Non-
Residential Sub-Slab
and Exterior SGSLs
(TCR=1E-06 or
THQ=0.2)
SG-2
Table 3: Groundwater Sample Laboratory Analysis Results
Distribution Street Site
2401 Distribution Street
Charlotte, North Carolina 28203
Partner Project Number 21-315565.3
May 14, 2021
Chemical of Concern 2L Standard
NCDEQ Residential
GWSLs
(TCR=1E-06 or
THQ=0.2)
NCDEQ Non-
Residential GWSLs
(TCR=1E-06 or
THQ=0.2)
B-1GW
Trichloroethylene 3.0 1.0 4.4 3.4 (D6)
Other VOCs Various Various Various <MDL
Notes:
2L = 15A North Carolina Administrative Code (NCAC) 2L Groundwater Standards
NCDEQ = North Carolina Department of Environmental Quality
GWSLs = Groundwater Screening Levels (January 2021)
TCR = Target Cancer Risk
THQ = Target Hazardous Quotient
VOCs = Volatile Organic Compounds
EPA = United States Environmental Protection Agency
µg/L = micrograms per liter
D6 = the precision between the sample and sample duplicate exceeded laboratory control limits
<MDL = not detected above the laboratory method detection limit (MDL)
Values in bold exceed laboratory MDLs
Values highlighted in yellow exceed one or more regulatory criteria
Chlorinated VOCs via EPA Method 8260D (µg/L)
Legend
Figure Date
Approximate Scale: 1” = 80’
Prepared By
8720 Red Oak Boulevard, Suite 528
Charlotte, North Carolina 28217
Project Number: 21-315565.3
Site Vicinity Map
1
2401 Distribution Street
Charlotte, North Carolina 28203
M. Helou May 2021
Subject Property
0 80404020
N
Timely Filter Supply
2327 Distribution Street
Distribution StreetThe Dunavant
2322 Dunavant Street
SL Laser Systems
2406 Dunavant Street
Cox Schepp Construction
2408 Dunavant Street
Multi-Family Residences
Queen City Stone & Tile
2503 Distribution Street
Alchemy Restaurant
2517 Distribution Street
B&G Lieberman Co.
2412 Distribution
Street
Rogue Farms Urban
Hydroponics
2503 Distribution
Street
Grier Interiors
2326 Distribution
Street
Charlotte Grill Co. &
Pet Wants
2324 Distribution
Street
Bahmuller Technologies
2321 Distribution Street
Dunavant Street2401 Distribution
Street
Project Number: 21-315565.3
Topographic Map
2
2401 Distribution Street
Charlotte, North Carolina 28203
May 2021
USGS Charlotte East, North Carolina
Quadrangle, 7.5-Minute Series
Version: 2013
M. HelouN
Subject
Property
Subject
Property
Figure DatePrepared By
8720 Red Oak Boulevard, Suite 528
Charlotte, North Carolina 28217

Project Number: 21-315565.3
Sample Location Map
3
2401 Distribution Street
Charlotte, North Carolina 28203
M. Helou May 2021
Subject Property
0 502525
N
Legend
Figure Date
Approximate Scale: 1” = 50’
Prepared By
8720 Red Oak Boulevard, Suite 528
Charlotte, North Carolina 28217
As
p
h
a
l
t
-
P
ave
d

P
ark
i
n
g

A
r
e
a
Asphalt-Paved Parking AreaAs
p
h
a
l
t
-
P
av
e
d

D
r
i
v
e
w
a
yAsphalt-Paved Parking AreaSG-1
SG-2
SG-3 B-1
TreesTreesTreesCrayton Printing
Brownfields Property
Par
k

M
e
d
i
c
a
l

A
s
s
o
c
i
a
t
es
Da
n
c
e

S
tyl
e
s
Frie
n
d
s
h
i
p

T
ra
y
s
As
p
h
a
l
t
-
P
av
e
d

P
ark
i
n
g

A
r
e
aDistribution StreetBuilding
Building
Building
Building
BuildingMonitoring Well
Boring Location

Appendix B

Brownfields Property Receptor Survey Template Form

North Carolina Department of Environmental Quality
Division of Waste Management
Brownfields Program
Site:
Address:
City:
County:
Brownfields Project Number:
Date
Property and Building Characteristics
a. Provide occupancy and use information.
c. Describe the foundation construction. Include details on type, floor construction, and depth below grade.
e. Are any subslab ventilation systems or moisture barriers in place? If so, please provide details.
NASize of Property (acres)
% of property that is wooded/brush
d. Describe the HVAC system in the building. Include available details on type, equipment location, source of air
return, and design considerations (e.g. positive pressure?).
BROWNFIELDS PROPERTY RECEPTOR SURVEY
This form was created to clarify and simplify preparing a receptor survey for a brownfield site. Please provide the
information requested below. Distances are measured from the site property boundary unless otherwise indicated
by the DEQ Brownfield’s Project Manager (PM).
Current Usage Proposed UsageSurface Conditions
% of property that is grassed areas
% of property that is agricultural crops
% of property that is paved
If an existing building is on-site, please respond to the following. Information can be provided on additional sheets
as needed. If numerous buildings are on-site, consult with your PM as only information on specific buildings may be
needed.
b. Describe the construction of the builidng including materials (e.g. wood frame, block), type and size of openings
(e.g. windows, bay doors), and height (number of stories).
% of property that is covered by buildings
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North Carolina Department of Environmental Quality
Division of Waste Management
Brownfields Program
Surrounding Property Land Use
North
South
East
West
Utilities
Is there a septic system on-site? (Y or N) _________
Please provide the utility providers for the subject property
a. Natural Gas ___________________________
b. Sewer ___________________________
c. Electricity ___________________________
d. Other __________________________
For surrounding properties, please complete the following table with available information.
Zoning/Land Use Proposed Usage Current Use/Occupant
DirectionDistance
(ft)Address
Please provide information on the following land uses in the vicinity of the subject site, including a map of the
surrounding areas. If specific receptors are present, please provide addresses of the facilities.
For the subject property, please provide a map of known buried utilites. If available, include depth to top,
construction material, and diameter of the utilities. In addition, please provide the following information on utilty
providers. If additional assessment is required, the public utility locators should be contacted. This information can
then be added to a site map.
Y/N *
Is a school or daycare center within 1,000 ft of the Property?
Specific Land Uses of Interest Y/N *
* If numerous facilities of interest are present, their locations can be placed on a map in lieu of providing specific
addresses.
Distance
(ft)
* If yes, please provide a map or detailed information (distance, direction, depth) of the utility in correlation with
the subject property.
Is a water line main within 100 ft of Property boundary?
Is a natural gas line main within 100 ft of the Property boundary?
Is a buried telephone/ cable main within 100 ft of the Property boundary?
Is a septic system leach field within 500 ft of the Property boundary?
Direction
Is there a basement within 1,000 ft of the Property
Is there a residence within 1,000 ft of the Property?
Utility/Potential Receptor
Is a buried electrical cable main within 100 ft of Property boundary?
Is a storm water pipe within 100 ft of the Property boundary?
Is a sanitary sewer within 100 ft of the Property boundary?
Rev. 09/2015 Page 2 of 3
North Carolina Department of Environmental Quality
Division of Waste Management
Brownfields Program
Water Supply
What is the potable water supply for the property? Public ______ Private ______
Surface Water & Wetlands
Are there surface water features on the
property? (If yes, please complete a. to d.)
Provide Information regarding Surface Water
and Wetlands
Distance
(ft)Direction Address
a. Is the water body naturally developed or
man-made?
Y/NWater Supply Wells
Please provide the following information regarding water supply wells in the vicinity of the Property. At a
minimum, a windshield survey within 1,500 ft of the property boundaries should be completed to determine if
water supply or irrigation wells may be present. Information from applicable databases can and should be utilized;
however, should not be utilized in lieu of the windshield survey. If multiple wells are present within the requested
radius, please provide a map of the well locations. If needed, please attach a separate table to list all wells. Please
note, the PM may opt for a more extensive water supply well survey if needed.
If Private, please provide details of the water supply source (i.e. well location, well construction, etc). If public,
please include the water providers name.
The purpose of this section is to provide information on the water supply for the site and surrounding areas.
Is a public water supply well within 1 mile of the Property boundary?
Is a private water supply well within 1,500 ft of the Property
bd?Is an irrigation well within 1,500 ft of the Property boundary?
Response/Comments
The purpose of this section is to provide information on the presence of surface waters and/or wetlands on, or in the
vicinity of the Property.
b. List the uses of the water body.
c. What is the source of the water for the
water body?
d. What is the nature of the bottom of the
water body (e.g., rocky or concrete bottom,
drainage ways or impoundments)
If no on-site surface water features, what is the
nearest surface water body?
Are there any wetlands present on the property?
If no wetlands on-site, are wetlands suspected
on adjoining properties?
Rev. 09/2015 Page 3 of 3