25052_450 Polo Road_Brownfields Assessment Work Plan and Approval_20221021

October 21, 2022
Sent via Email
Jeffrey Koon450 Polo, LLC675 Seminole Ave. NE, Suite B1
Atlanta, GA 30307
[e-mail]
Subject: Assessment Work Plan Approval 450 Polo Road Property450 Polo RoadWinston-Salem, Forsyth County
Brownfields Project Number 25052-21-034
Dear Mr. Koon:
The North Carolina Department of Environmental Quality (DEQ) Brownfields Program received
and reviewed the Assessment Work Plan Proposal- July 29, 2022 (Revised October 19,
2022) (Work Plan) for environmental assessment activities submitted by Engineering and Surveying Professionals, Inc. (EAS) for the above referenced site,
which incorporated previous comments made by DEQ. Based on our review, the revised Work
Plan is approved.
Be advised that this approval from the Brownfields Program does not waive any applicable
requirement to obtain any necessary permits, licenses, or certifications for the above listed
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 336-776-9742, or via e-mail at
[e-mail].
Sincerely,
Seth Titley
Project Manager
Brownfields Program
ec: Tracy Wahl, DEQ Brownfields Derek Ross, EAS

ASSESSMENT WORK PLAN PROPOSAL
FOR
450 POLO ROAD PROPERTY
WINSTON-SALEM, NORTH CAROLINA

EAS PROJECT NO. 225234
OCTOBER 19, 2022

PREPARED FOR:

450 POLO, LLC
675 SEMINOLE AVENUE, NE, SUITE B1
ATLANTA, GA 29601

PREPARED BY:

EAS PROFESSIONALS, INC.
9 PILGRIM ROAD
GREENVILLE, SC 29607

Geotechnical, Environmental, Construction Materials and Forensic Engineering
Construction Materials Testing | Laboratory Testing | Land Surveying | Specialty Inspections

October 19, 2022

NCDEQ – Division of Waste Management
Brownfields Program
1646 Mail Service Center
Raleigh, NC 27699-1646

Attention: Mr. Seth A. Titley

Reference: Assessment Work Plan Proposal
450 Polo Road Property
Winston-Salem, Forsyth County, North Carolina
Brownfield Project No. 25052-21-034
EAS Project No.: 225234

Dear Mr. Titley:

Engineering and Surveying Professionals Inc. (EAS) is pleased to provide this
Assessment Work Plan (AWP) for the 450 Polo Road Property located in Winston-
Salem, Forsyth County, North Carolina.

This AWP has been prepared in accordance with Brownfields Letter of Eligibility (LOE)
Brownfields Project No. 25052-21-034. If you have any questions regarding this report
do not hesitate to contact Derek M. Ross at 828.382.8319.

Respectfully Submitted,

EAS PROFESSIONALS, INC.

Derek M. Ross J. Ashley Brown, PE
Environmental Services Manager Senior Environmental Engineer
NC License Number 023160

Assessment Work Plan PAGE i EAS No. 22-5234
450 Polo road Winston Salem, NC October 19, 2022

ASSESSMENT WORK PLAN PROPOSAL

450 Polo Road Property
Winston-Salem, Forsyth County, North Carolina
Brownfield Project No. 25052-21-034
October 19, 2022

DISTRIBUTION LIST

NCDEQ EAS Professionals Inc.
Brownfields Program 9 Pilgrim Road
217 West Jones Street Greenville, SC 29607
Raleigh, NC 27699-1646
Phone: [phone] Phone: [phone]
Contact: Ms. Tracy Wahl Contact: Derek M. Ross
Email: [e-mail] Email: [e-mail]

NCDEQ
Brownfields Program
450 West Hanes Mill Road
Suite 300
Winston Salem, NC 27105

Phone: [phone] office
Contact: Mr. Seth A. Titley
Email: [e-mail]

450 Polo, LLC c/o Jeff Koon
675 Seminole Avenue NE, Suite B1
Atlanta, GA 30307

Phone: [phone]
Contact: Mr. Jeff Koon
Email: [e-mail]

Roberts & Stevens, P.A.
City Centre Building
301 College Street, Suite 400
Asheville, NC 28801

Phone: [phone]
Contact: Mr. William Clarke
Email: [e-mail]

Assessment Work Plan PAGE ii EAS No. 22-5234
450 Polo road Winston Salem, NC October 19, 2022

450 Polo Road
Winston-Salem, Forsyth County, North Carolina
Brownfield Project No. 25052-21-034
October 19, 2022

Certification:

I, J. Ashley Brown, a Professional Engineer for EAS, Inc., do certify that the information
contained in this report is correct and accurate to the best of my knowledge. EAS, Inc. is
licensed to practice engineering in North Carolina. The certification number of the
company is C-3066.

J. Ashley Brown, P.E.
Senior Environmental Engineer
NC License No. 023160

10/6/22

Assessment Work Plan PAGE iii EAS No. 22-5234
450 Polo road Winston Salem, NC October 19, 2022

TABLE OF CONTENTS

1.0 INTRODUCTION ............................................................................................................... 1
1.1 BACKGROUND ................................................................................................................ 1
1.2 PROPERTY AND SURROUNDING AREA DESCRIPTION ............................................. 3
1.3 REGULATORY BACKGROUND ....................................................................................... 4
2.0 SCOPE OF WORK ........................................................................................................... 5
2.1 PROJECT ORGANIZATION ............................................................................................. 5
2.2 SPECIAL TRAINING REQUIREMENTS AND CERTIFICATION ...................................... 6
2.3 SAMPLE PROCEDURES, MEDIA, LOCATIONS AND ANALYTICAL PARAMETERS .... 6
2.4 SAMPLE LOCATIONS PROCEDURES, AND ANALYTICAL PARAMETERS ............... 12
2.4.1 General Sampling Procedures ........................................................................... 12
2.4.2 Soil Sampling Procedures ................................................................................. 13
2.4.3 Groundwater Sampling Procedures ................................................................... 13
2.4.4 Soil Gas Sampling Procedures .......................................................................... 15
2.4.5 Documentation ................................................................................................... 17
3.0 QUALITY ASSURANCE PROJECT PLAN .................................................................... 19
3.1 INTRODUCTION ............................................................................................................. 19
3.2 DATA QUALITY OBJECTIVES (DQOS) ......................................................................... 20
3.3 DATA QUALITY OBJECTIVES – SEVEN STEP PROCESS .......................................... 20
4.0 MANAGEMENT OF INVESTIGATION DERIVED WASTES .......................................... 22
5.0 REPORTS ....................................................................................................................... 23
5.1 SITE ASSESSMENT REPORT ......................................................................................... 23

Attachment A Figures

Figure 1: Proposed Sample Location Map
Figure 2: Site Location Map
Figure 3: Groundwater Potentiometric Map
Figure 4: Cut/Fill Analysis and proposed soil sampling

Attachment B: Site Plat Showing Oil/Water Separator provided by Stratus Development Group

Assessment Work Plan PAGE 1 EAS No. 22-5234
450 Polo road Winston Salem, NC October 19, 2022

PROPOSAL FOR ASSESSMENT WORK PLAN FOR 450 POLO ROAD

1.0 INTRODUCTION

1.1 Background

The 450 Polo Road Property is located at 450 Polo Road, Winston-Salem, Forsyth
County, North Carolina (the Property). It is identified by Forsyth County as Parcel
Identification Number (PIN) 6827-72-3724.000. The Property includes approximately
3.95-acres and is bounded generally to the north by Polo Road, with the NCDOT
Location and Surveys Unit to the northwest, the NCDOT Roadside Environmental Unit
to the north, and a commercial building occupied by La Oficina, Alexa & Jonathan Hair
Designers, La Loteria (Mexican convenience store), L&C Appliances, La Victoria
(Mexican grocery store), and Polo Laundry to the northeast. The property is bounded to
the east by Calvary Chapel Fellowship (church), beyond which lies residential
development, and to the south by McCanless Street with residential development, with
additional residential development further south. Adjacent to the west is cleared land,
with commercial development and wooded land further west.

The subject site is in the northwestern area of the city of Winston Salem, approximately
300 feet southeast of the intersection of Polo Road and N. Cherry Street. The
surrounding area is generally occupied by wooded land and commercial and residential
development.

Environmental Corporation of America (ECA) completed Phase I Environmental Site
Assessment (ESA) of the Property dated January 8, 2021. According to the Phase I
ESA, the Property was formerly cleared and/or agricultural land from at least 1940 until
sometime between 1950 and 1961, when the present-day parking area on its northern
end was constructed. The Property has consisted of wooded land and a parking area
from at least 1961 until the present day. The Gwyn Commercial Property (Salem
Uniform Service) facility addressed as 4015 North Cherry Street and adjoining the
Property to the west was identified on the SHWS (EPAID NONCD0002438), LUST,
INST CONTROL, VCP, BROWNFIELDS (Project ID 07011-03-34), IMD, UST, and
RCRA- QG databases. This facility was formerly utilized as a drycleaner. According to
EDR, an 8,000-gallon fuel oil UST was reported as temporarily closed. A 1,000-gallon
gasoline UST and a 2,000-gallon gasoline UST were reportedly removed from the
ground in 1994. A release associated with these USTs was reported in 1994 which
impacted both soil and groundwater and the case is listed as closed in 2019.

According to a plat provided by Mr. Jeff Koon of Stratus Development Group, LLC, the
1,000-gallon and 2,000-gallon closed USTs at the Salem Uniform Service property were
formerly located approximately 90 feet from the Property. The plat also depicts a former
oil-water separator on the southern portion of the Salem Uniform Service property. This
plat is included as Attachment 1.

Assessment Work Plan PAGE 2 EAS No. 22-5234
450 Polo road Winston Salem, NC October 19, 2022

ECA’s review of a Limited Site Assessment Report of the Salem Uniform Service
property conducted by ENSR Consulting and Engineering, Inc. (ENSR) and dated June
2003 identified tetrachloroethylene (PCE) in two of the three samples collected at
concentrations (27.5 mg/kg and 0.903 mg/kg) exceeding the US EPA soil-to-
groundwater maximum soil contaminant concentration (MSCC) of 0.0007 mg/kg.

Ethylbenzene, 1,3,5-trimethylbenzene, PCE, trichloroethene (TCE), and cis-1,2-
dichloroethene were detected in the groundwater sample collected at concentrations of
exceeding these compounds’ respective 15A North Carolina Administrative Code
(NCAC) 2L Groundwater Quality Standards. PCE was also detected above the gross
contaminant level (GCL) of 0.7 mg/L. A copy of this report will be submitted to NCDEQ,
separately.

ECA also reviewed a Notice of Brownfields Property for the Salem Uniform Service
property dated August 11, 2006, which restricted the use of the property to
warehousing, retail, office, or parking purposes. The use of surface water, groundwater,
and soil, and the construction of a new structure was also prohibited without written
notice to NCDENR.

ECA’s review of a Groundwater and Air Monitoring Report for the April 2019 Sampling
Event of the Salem Uniform Service property dated August 2019 conducted by AECOM
Technical Services of North Carolina, Inc. (AECOM) identified PCE at concentrations
above the 2L Standard in 22 monitoring well samples. TCE was detected at
concentrations above the 2L Standard in 10 monitoring well samples. Additionally, the
PCE breakdown products cis-1,2-Dichloroethylene (DCE), and vinyl chloride as well as
benzene and 1,2-Dichloroethane (DCA, a tetrachloroethane breakdown product) were
detected at concentrations above the 2L Standard in several samples. Per the AECOM
report historical trends reportedly show that PCE in most site monitoring wells have
generally either decreased or remained stable since 2004 with the exception of
fluctuations observed in most intermediate-depth onsite monitoring wells. ECA was also
provided with groundwater isoconcentration maps that indicate that shallow
groundwater beneath the western portion of the Property has been adversely impacted
by the PCE contamination plume migrating from the Salem Uniform property. This
report was submitted to the NCDEQ, separately.

Based on the information reviewed, along with the previous Phase I and Phase II
Environmental Site Assessments discussed in section 5.4.7 of this previous Phase I
ESA, ECA considered the PCE groundwater contamination associated with the Salem
Uniform Service property to represent a recognized environmental condition (REC) for
the Property.

ECA was also provided with a previous Phase I Environmental Site Assessment (ESA)
of the Property conducted by Terraquest Environmental Consultants, P.C. (Terraquest)
and dated July 8, 2016. Terraquest identified the Property as undeveloped with the
exception of the construction of the asphalt paved parking lot prior to 1951. Terraquest
identified one historical recognized environmental condition in association with the

Assessment Work Plan PAGE 3 EAS No. 22-5234
450 Polo road Winston Salem, NC October 19, 2022

former Pilot Freight Carriers (JSGO) facility located at 4103 Cherry Street immediately
north of the Property. According to Terraquest, a release was reported during the
closure of USTs, “T1” and “T2” but soils were remediated to below North Carolina
Department of Environmental Quality (NCDEQ) Department of Waste Management
(DWM)-UST soil and groundwater cleanup standards, so this off-site release was not
considered a recognized environmental condition by Terraquest. A copy of this report
will be submitted to the NCDEQ, separately.

Terraquest also identified two offsite facilities that in their opinion constituted RECs
during the course of their 2016 Phase I ESA of the Property, which included a
chlorinated solvent release from the upgradient western adjoining property, Salem
Uniform Services Facility/Gwyn Commercial Property, and a former upgradient gasoline
station release at Pace Gas & Car Wash addressed as 335 Polo Road, identified to the
northeast during the city directory review and site reconnaissance.

Additionally, Terraquest discussed a release from a 1,000-gallon and a 2,000-gallon
steel gasoline USTs on the Salem Uniform Services Facility but determined this release
was not a recognized environmental condition, since it was identified as low risk by the
NCDEQ based on analytical results of the ongoing assessments at this facility showing
no elevated petroleum-related contamination in the monitoring wells sampled.

ECA was also provided with a previous Phase II ESA conducted on the Property by
Terraquest and dated January 24, 2017 as a result of the findings in their earlier Phase I
ESA. The Phase II ESA included both soil and groundwater sampling. Soil
contaminants detected did not exceed the NCDWM soil to groundwater MSCCs.
Groundwater analytical results of the northwestern groundwater sample (Well TQMW1)
indicated the presence of benzene and PCE at levels that exceeded the 2L Standard
which were likely associated with the petroleum and chlorinated solvent releases that
occurred on the adjoining former Salem Uniform Services facility. Analysis of the
northeastern groundwater sample (Well TQMW2) revealed numerous petroleum-based
contaminant concentrations in excess of the 2L Standard along with a detection of PCE
exceeding the 2L Standard. Terraquest noted that the petroleum contamination present
in the sample from Well TQMW2 was likely from the Pace Gas & Car Wash facility and
the PCE potentially migrated from the Polo Laundry facility located at 325 Polo Road to
the northeast of the Property. Based on this information, the petroleum and solvent
releases identified in the groundwater at the Property were considered a REC in the
January 8, 2021, ECA Phase I ESA Report.

Based on the information summarized above, this assessment is attempting to fill data
gaps with respect to potential soil, groundwater and soil vapor impacts beneath areas of
the Property not assessed in previous investigations.

1.2 Property and Surrounding Area Description

The 450 Polo Road Property is adjoined to the north by Polo Road, with the NCDOT
Location and Surveys Unit to the northwest, the NCDOT Roadside Environmental Unit

Assessment Work Plan PAGE 4 EAS No. 22-5234
450 Polo road Winston Salem, NC October 19, 2022

to the north, and a commercial building occupied by La Oficina, Alexa & Jonathan Hair
Designers, La Loteria (Mexican convenience store), L&C Appliances, La Victoria
(Mexican grocery store), and Polo Laundry to the northeast. The property is bounded to
the east by Calvary Chapel Fellowship (church), beyond which lies residential
development, and to the south by McCanless Street with residential development, with
additional residential development further south. Adjacent to the west is cleared land,
with commercial development and wooded land further west. The surrounding area is
generally occupied by wooded land and commercial and residential development. The
Property includes approximately 3.95-acres and is bounded generally to the north by
Polo Road.

1.3 Regulatory Background

Based on the findings of ECA’s Phase I ESA dated January 8, 2021, the Limited Site
Assessment Report conducted by ENSR dated June 2003, the Notice of Brownfields
Property dated August 11, 2006, the Brownfields Site Inspection Report dated August
13, 2008, the Groundwater and Air Monitoring Report for the April 2019 Sampling Event
dated August 2019 conducted by AECOM, the Phase I Environmental Site Assessment
(ESA) conducted by Terraquest dated July 8, 2016, and the Phase II Environmental Site
Assessment conducted by Terraquest dated January 24, 2017, it was recommended by
the NCDEQ, that Stratus Development Group, LLC be entered into a Brownfields
Agreement (25052-21-034) for the Property identified by Forsyth County as PIN 6827-
72-3724.000, herein referred to as the Property. As a result, Stratus Development
Group, LLC, on behalf of 450 Polo LLC submitted to NC DEQ Brownfields Program an
application as a Prospective Developer seeking a Brownfields Agreement.

Subsequently, a Letter of Eligibility (LOE) for the property was awarded on December 3,
2021. Per the language in LOE prepared by NCDEQ, “The North Carolina Department
of Environmental Quality (DEQ) has received and reviewed your July 14, 2021
Brownfields Property Application (BPA) and revised application and affidavit (received
November 15, 2021) submitted on behalf of 450 Polo, LLC as a Prospective Developer
seeking a Brownfields Agreement regarding the Brownfields Property. Upon review of
the BPA with respect to the requirements of the Brownfields Property Reuse Act of
1997, DEQ has determined that this project is eligible for entry into the North Carolina
Brownfields Program (NCBP) and for continued evaluation for a Brownfields Agreement
(BFA).”

This AWP document has been prepared to meet the requirements prescribed in THE
MINIMUM REQUIREMENTS CHECKLIST FOR SITE ASSESSMENT WORK PLANS
AND REPORTS dated February 2022. This document will also serve as the QA/QC
document for all soil and groundwater assessment activities to be conducted at this
specific site. This assessment is being performed to identify and determine the source,
nature and extent of contamination in specific areas of the Property that has not been
previously assessed.

This AWP sets forth field and laboratory methods used to collect and analyze soil, soil

Assessment Work Plan PAGE 5 EAS No. 22-5234
450 Polo road Winston Salem, NC October 19, 2022

vapor, and groundwater samples to allow characterization of environmental impacts on
the site and establishes field and laboratory quality control procedures employed to
ensure that the data are reliable and defensible. The AWP includes information such as
sample locations, analytical parameters, standard procedures for sample collection,
sample container and preservation requirements, equipment decontamination
procedures, documentation requirements, and the number and types of field and
laboratory quality control samples to be used.

It is EAS’s understanding that the assessment data gathered during the course of the
AWP will not be utilized for any other NCDEQ programs and is solely for the utilization of
the Brownfields Program.

2.0 SCOPE OF WORK

2.1 Project Organization

The Project Manager (PM) for this project is Mr. Derek M. Ross. Decisions regarding
project scope, sampling locations, collection equipment, or other project related issues
will be made by the PM in consultation with team members and the NCDEQ Project
Manager. Mr. J. Ashley Brown, P.E. will act as the project Field Operations Manager
(FOM) for the project and in this role will implement the scope of work and make field
sampling decisions.

The EAS Senior Reviewer for the project is Mr. J. Ashley Brown, P.E. Mr. Brown has
over 36 years’ experience in multi-faceted environmental engineering projects. His
broad base of experience in technical, management and regulatory matters will direct
and help ensure project quality.

The Subcontract Laboratory Manager is the point of contact for all laboratory-related
issues for this project. This individual will review all requests for laboratory analyses,
containers, accelerated turnarounds and will communicate with EAS any special
requirements for sample collection, preservation, shipping or other issues. The
subcontract Laboratory Manager will conduct a second-tier review of all analytical data
prior to submission to EAS and will communicate with the EAS Project Manager during
this review.

Ms. Heather J. Wagner with Pace Analytical will be the Subcontract Laboratory
Manager for this project. She will communicate with the EAS Project Manager directly
during the course of this investigation.

Pace Analytical National Center for Testing & Innovation
12065 Lebanon Rd.
Mt. Juliet, TN 37122
615-773-9686

Assessment Work Plan PAGE 6 EAS No. 22-5234
450 Polo road Winston Salem, NC October 19, 2022

2.2 Special Training Requirements and Certification

All on-site field sampling personnel will possess an adequate level of experience in the
collection, preservation and management of environmental samples as judged by the
FOM. The FOM will have more than 36 years’ experience in the overseeing and
managing environmental sampling plans.

All site personnel for the project will have completed the Occupational Safety and
Health Administration (OSHA) basic 40-hour health and safety training course,
Hazardous Waste Operations and Emergency Response (HAZWOPER), including
annual refreshers. EAS also holds weekly safety meetings and provides staff online
training courses available via live webcasts, recorded webcasts, and self-paced online
options. During the weekly safety meetings personnel will describe circumstances they
may have encountered during field data collection, how the situation was evaluated and
resolved and any “lessons learned” as a result of that experience.

All drilling will be performed by a licensed North Carolina Well Drilling Contractor, per
NCDEQ requirements, who is experienced in the collection of soil and groundwater
samples. Drilling activities will be supervised by a North Carolina registered
Professional Engineer (P.E.). All soil borings and groundwater monitoring wells will be
installed and abandoned by a North Carolina licensed well driller in accordance with
15A NCAC 2C .0108. Standards of Construction: Wells Other Than Water Supply.

2.3 Sample Procedures, Media, Locations and Analytical Parameters

Laboratory clean sampling containers appropriate for the analytical methods to be used
will be obtained along with clean storage containers capable of holding the sample
containers and ice necessary to appropriately preserve the samples collected. Those
collecting the samples will have training appropriate to the task, including an awareness
of the need to avoid cross contamination of samples through measures such as the use
of clean gloves for the collection of each sample. Any required sampling implements
such scoops, hand augers etc. will be laboratory clean stainless steel. In addition, the
following additional sampling protocols must be followed:

Samples will be collected, properly labeled, secured, and immediately preserved by
placing them on ice. Each sample container will be tightly sealed and placed in a clean
zip lock bag. A laboratory Chain of Custody (COC) Form will be completed that will
include relevant information for all samples including unique identification codes for
each sample, date of collection, time of collection, and a description of the container
sizes and types. After the collection of all samples the completed COC form will be
placed in a waterproof container (zip lock bag) with the samples and shipped overnight
to the State of North Carolina-approved laboratory (Pace) for the analyses specified in
Table 1. The shipping containers should have signed and dated custody seals and
enough ice to properly preserve the samples during transit.

Soils – There are plans to construct eight (8) buildings on eight (8) building pads on the
Property. Six (6) of these buildings will be constructed on or in the vicinity of the

Assessment Work Plan PAGE 7 EAS No. 22-5234
450 Polo road Winston Salem, NC October 19, 2022

documented groundwater impacts. Consequently, EAS is recommending the collection
up to thirty-one (31) soil samples in the vicinity of the proposed eight (8) building
footprints and associated improvements as shown in Figures 1 and 4. In each soil
boring for the proposed structures one “surface” sample will be collected from 0-1’
below ground surface (bgs) i.e. SS-1 and one “subsurface” sample i.e. SS-1-a will be
collected from 4-5’ below existing grade from each of the eight (8) locations. Four (4) of
these soil samples will be collected in the area of two proposed building footprints in the
southwestern portion of the Property (SS-1, SS-1-a, SS-2, and SS-2-a). Four (4) soil
samples will be collected in the vicinity of the two proposed building footprints in the
northwestern portion of the Property (SS-3, SS-3-a, SS-4 and SS-4-a). Four (4) soil
samples will be collected in the vicinity of two proposed building footprints in the
northeastern portion of the Property (SS-5, SS-5-a, SS-6 and SS-6-a) and four (4) soil
samples will be collected in the vicinity of the proposed two building footprints in the
southeastern area of the Property (SS-7, SS-7-a, SS-8 and SS-8-a).

In addition to the structure sampling, NCDEQ has indicated it will be necessary to
sample and analyze soil samples from grading “cut” areas on site to determine if those
cut soils will be suitable for use as onsite fill, or in the case of soils from proposed utility
trench cuts, if soils in the areas of those cuts will need to be taken out before site
grading begins. The site grading plan suggests one mass grading cut area of two (2)
feet in depth in the southeastern corner of the site. Across the remainder of the site, site
grading will involve fills ranging from less than one foot to nine (9) feet in depth. Seven
(7) utility trench cut samples (CS-1 through CS-7) will be collected from the areas
shown on Figure 4 from the depths indicated in Table 1 (due to proposed utility depths,
samples at two (2) intervals are proposed for the three (3) deeper samples). One soil
sample from one (1) to two (2) feet bgs is proposed in the single cut area in the
southeastern corner of the site (CS-8 on Figure 4). The proposed sampling locations,
depth intervals, source areas and proposed analyses are summarized in Table 1.

In addition to the soil samples described above consistent with NCDEQ requirements,
one duplicate sample will be collected for at least every 20 samples collected, with a
minimum of two duplicate soil samples to be collected. Four (4) duplicate samples will
be collected (one at each depth at two building pad locations). All of the soil samples
will be analyzed for volatile organic compounds (VOCs) by Environmental Protection
Agency (EPA) Method 8260, semi-volatile organic compounds (SVOCs) by EPA
Method 8270 and RCRA Metals by EPA Method 6020. See Table 1 Soil Sample
Summary below.

A large volume of soil is not anticipated from utility trenching operations, likely less than
ten (10) cubic yards. If testing of the proposed utility trench soils indicates contaminants
in excess of NCDWM Preliminary Soil Remediation Goals (PSRGs), prior to grading,
residual cut soils in areas that exceeded limits will be properly managed. As part of this
soil management, a risk evaluation of impacted cut soils will be performed to determine
its potential suitability for use on site for fill in roadways or other areas with a low
potential for future exposure. If testing of cut soils indicates target analytes at
concentrations less than PSRGs or in the case of metals, less than background, these

Assessment Work Plan PAGE 8 EAS No. 22-5234
450 Polo road Winston Salem, NC October 19, 2022

soils may be used for utility trench backfill contingent on NCDEQ’s approval.

At this time the source of site fill soils is not known. When a suitable source of fill soil is
located, NCDEQ will be notified of its location and other pertinent information. All Fill
soil will we reviewed and approved by NCDEQ prior to use on site. If following
NCDEQ’s review, sampling of the proposed fill soil is required by the NCDEQ, soil
sampling will be conducted in accordance with their directives.

See the attached Figures 1 and 4 for the proposed, approximate soil sample locations
and Table 1 below for a breakdown of the number of samples and proposed collection
depths.

Table 1
Soil Sampling Summary

Property
Location/Potential
Source
Soil Sample ID Soil Sample Depth
(Feet bgs) Analyses
Building 1 SS-1 0-1’
VOCs 8260,
SVOCs 8270,
RCRA Metals
6020
Building 1 SS-1-a 4-5’
VOCs 8260,
SVOCs 8270,
RCRA Metals
6020
Building 2 SS-2 0-1’
VOCs 8260,
SVOCs 8270,
RCRA Metals
6020
Building 2 SS-2-a 4-5’
VOCs 8260,
SVOCs 8270,
RCRA Metals
6020
Building 3 SS-3 0-1’
VOCs 8260,
SVOCs 8270,
RCRA Metals
6020
Building 3 SS-3-a 4-5’
VOCs 8260,
SVOCs 8270,
RCRA Metals
6020

Assessment Work Plan PAGE 9 EAS No. 22-5234
450 Polo road Winston Salem, NC October 19, 2022

Property
Location/Potential
Source
Soil Sample ID Soil Sample Depth
(Feet bgs) Analyses
Building 4 SS-4 0-1’
VOCs 8260,
SVOCs 8270,
RCRA Metals
6020
Building 4 SS-4-a 4-5’
VOCs 8260,
SVOCs 8270,
RCRA Metals
6020
Building 5 SS-5 0-1’
VOCs 8260,
SVOCs 8270,
RCRA Metals
6020
Building 5 SS-5-a 4-5’
VOCs 8260,
SVOCs 8270,
RCRA Metals
6020
Building 6 SS-6 0-1’
VOCs 8260,
SVOCs 8270,
RCRA Metals
6020
Building 6 SS-6-a 4-5’
VOCs 8260,
SVOCs 8270,
RCRA Metals
6020
Building 7 SS-7 0-1’
VOCs 8260,
SVOCs 8270,
RCRA Metals
6020
Building 7 SS-7-a 4-5’
VOCs 8260,
SVOCs 8270,
RCRA Metals
6020
Building 8 SS-8 0-1’
VOCs 8260,
SVOCs 8270,
RCRA Metals
6020

Assessment Work Plan PAGE 10 EAS No. 22-5234
450 Polo road Winston Salem, NC October 19, 2022

Building 8 SS-8-a 4-5’
VOCs 8260,
SVOCs 8270,
RCRA Metals
6020
Building 2 SS-2 (DUP) 0-1’
VOCs 8260,
SVOCs 8270,
RCRA Metals
6020
Building 2 SS-2-a (DUP) 4-5’
VOCs 8260,
SVOCs 8270,
RCRA Metals
6020
Building 3 SS-3 (DUP) 0-1’
VOCs 8260,
SVOCs 8270,
RCRA Metals
6020
Building 3 SS-3-a (DUP) 4-5’
VOCs 8260,
SVOCs 8270,
RCRA Metals
6020
Two (2) Foot Deep
Utility Trenching
East of Building 1
CS-1 0-2’
VOCs 8260,
SVOCs 8270,
RCRA Metals
6020
Two (2) Foot Deep
Utility Trenching
North of Building 2
CS-2 0-2’
VOCs 8260,
SVOCs 8270,
RCRA Metals
6020
Two (2) Foot Deep
Utility Trenching
South of Buildings 3
& 4
CS-3 0-2’
VOCs 8260,
SVOCs 8270,
RCRA Metals
6020
Seven (7) Foot Deep
Utility Trenching
East of Building 4
CS-4-a 2-3’ VOCs 8260,
SVOCs 8270,
RCRA Metals
6020 CS-4-b 6-7’
Six (6) Foot Deep
Utility Trenching
South of Building 5
CS-5-a 1-3’ VOCs 8260,
SVOCs 8270,
RCRA Metals
6020 CS-5-b 5-6’

Assessment Work Plan PAGE 11 EAS No. 22-5234
450 Polo road Winston Salem, NC October 19, 2022

Seven (7) Foot Deep
Utility Trenching
South of Building 6
CS-6-a 2-3’ VOCs 8260,
SVOCs 8270,
RCRA Metals
6020 CS-6-b 6-7’
Two (2) Foot Deep
Utility Trenching
West of Building 7
CS-7 0-2’
VOCs 8260,
SVOCs 8270,
RCRA Metals
6020
Two (2) Foot Deep
Mass Grading Cut
East of Building 8
CS-8 0-2’
VOCs 8260,
SVOCs 8270,
RCRA Metals
6020
TOTAL 31

Soil Gas – In accordance with the NC Brownfields program, soil gas samples will be
collected for this site, which includes proposed residential development. Based on the
degraded condition of the asphalt-paved area in the northern part of the site it will not
be possible to collect sub-slab soil gas samples. Exterior soil gas samples (SG-1
through SG-8) will be collected at a depth of approximately five (5) feet bgs within the
footprints of the proposed building pads. Exterior soil gas samples SG-9 and SG-10 will
be collected at a depth of approximately five (5) feet bgs along the western property
boundary. See the attached Figure 1 for the proposed, approximate soil gas sample
locations.

Surface Water – Surface water features are not currently present on the Property and
surface water samples will not be collected during the course of this assessment.

Groundwater – An elevated PCE concentration (above the 2L Standard) was identified
in the groundwater beneath the southwestern portion of the Property; elevated benzene
and PCE concentrations were detected beneath the northwestern portion of the
Property; and elevated benzene, toluene, ethylbenzene, xylenes (BTEX), naphthalene,
1,2-dibromoethane (EDB), 1, 2-dichloroethane (DCA), 1,2,4-trimethylbenzene, 2-
hexanone and PCE concentrations were detected beneath the northeastern portion of
the Property. However, groundwater assessment activities have not been conducted on
the southeastern portion of the Property. Based on this information coupled with the
proposed building locations on these areas of the Property, groundwater will be
evaluated by advancing six monitoring wells (MWs) with 25’ of 2” diameter PVC riser
attached to 15 feet of 2” diameter PVC screen with a 0.010” slot size for a total depth of
40’ feet bgs. The wells will be installed in the vicinities of the proposed eight (8) building
footprints as follows: one (1) in between buildings 1 and 2, one (1) between buildings 3
and 4, one (1) between buildings 5 and 6, one (1) in the building 7 footprint one (1) in
the building 8 footprint and one (1) on the western property boundary adjacent to the
west of the proposed building 2. See the attached Figure 1 for the proposed,

Assessment Work Plan PAGE 12 EAS No. 22-5234
450 Polo road Winston Salem, NC October 19, 2022

approximate monitoring well locations.

2.4 Sample Locations Procedures, and Analytical Parameters

2.4.1 General Sampling Procedures

Laboratory clean sampling containers appropriate for the analytical methods to be used
will be obtained along with clean storage containers capable of holding the sample
containers and ice necessary to appropriately preserve the samples collected. Those
collecting the samples will have training appropriate to the task, including an awareness
of the need to avoid cross contamination of samples through measures such as the use
of clean gloves for the collection of each sample. Any required sampling implements
such scoops, hand augers etc. will be laboratory clean stainless steel. In addition, the
following additional sampling protocols must be followed:

Soil and groundwater samples will be collected, properly labeled, secured, and
immediately preserved by placing them on ice. Each sample container will be tightly
sealed and placed in a clean zip lock bag. A laboratory Chain of Custody (COC) Form
will be completed that will include relevant information for all samples including unique
identification codes for each sample, date of collection, time of collection, and a
description of the container sizes and types. After the collection of all samples the
completed COC form will be placed in a waterproof container (zip lock bag) with the
samples and shipped overnight to the State of North Carolina-approved, National
Voluntary Laboratory Accreditation Program (NVLAP) laboratory (Pace) for the analyses
specified in this AWP in Tables 2 and 3 below. The shipping containers should have
signed and dated custody seals and enough ice to properly preserve the samples
during transit.

Soil gas samples will be collected using laboratory clean Summa Canisters and
regulators. Following sample collection Summa cannisters containing the soil gas
samples will be appropriately labeled with a unique identifier and dated, and COC forms
will be completed for all samples, which will include beginning, final and lab-received
vacuum/pressure readings. The Summa cannisters will be shipped overnight to H&P
Mobile Geochemistry in Carlsbad, California for analysis of the full list of US EPA
Method TO-15 VOCs. H&P has the following accreditations:

• United States Department of Defense, Environmental Laboratory Accreditation
Program (ISO/IEC 17025:2005 and DoD-ELAP)
- PJLA Accreditation No. 69070 (Methods: H&P 8260SV; EPA 8260B; EPA
TO15)
- TNI National Environmental Field Activities Program (NEFAP)

• California Department of Public Health, Environmental Laboratory Accreditation
Program, (ELAP) Certificate No. 2741; and Mobile Laboratory Certificate No.
2740

Assessment Work Plan PAGE 13 EAS No. 22-5234
450 Polo road Winston Salem, NC October 19, 2022

• National Environmental Laboratory Accreditation Program (NELAP) through the
State of Louisiana, Department of Environmental Quality, Certificate No. 04138

2.4.2 Soil Sampling Procedures

EAS will collect a total of approximately thirty-one (31) soil samples from eight (8)
structures and other locations (2 at each building footprint, 4 associated duplicate
samples and an assumed 8 cut soil samples). Samples will be collected using either an
appropriately decontaminated direct push drilling rig Macrocore Soil Sampler or
stainless-steel hand augers. Soil samples designated “Surface” will be collected from
surface to approximately one foot below grade (0-1’). Soil samples designated
“Subsurface” will be collected from four feet (4) to approximately five (5) feet below
projected finished grade (4-5’) post development. Soil samples will be screened at one-
foot intervals with a 10.6 eV MiniRAE photoionization detector (PID) and will also be
screened for visual and olfactory indicators. All sampling equipment will be thoroughly
cleaned between sampling locations using an Alconox solution for wash, followed by a
clean water rinse and a final deionized water rinse. Samplers will use clean nitrile or
latex gloves between each sampling location.

The proposed sampling locations, depth intervals, source areas and proposed analyses
are summarized in Table 1. In addition, one duplicate sample will be collected for at
least every 20 samples collected, with a minimum of two duplicate soil samples to be
collected. As duplicate samples will be collected at two separate structure locations,
and samples are to be collected at two depths at each structure, four duplicates are
anticipated. Each duplicate sample will be analyzed for volatile organic compounds
(VOCs) by Environmental Protection Agency (EPA) Method 8260, semi-volatile organic
compounds (SVOCs) by EPA Method 8270 and RCRA Metals by EPA Method 6020. All
soil cut samples will be analyzed for these same parameters. All laboratory analytical
detections will be compared to the most recent (July 2022) NCDEQ Preliminary Soil
Remediation Goals (PSRGs).

2.4.3 Groundwater Sampling Procedures

Earlier groundwater investigations conducted on the site and adjacent properties have
indicated monitoring wells were set at a total depth of approximately 40 feet below
grade. Therefore, six (6), two-inch, Type II Monitoring wells will be installed using an
appropriately decontaminated hollow solid-stem auger drilling rig at the locations
described above. The wells will be installed with approximately 25 feet of 2” diameter
PVC riser attached to approximately 15 feet of 2” diameter PVC screen with a 0.010”
slot size at a depth where the groundwater level will be approximately in the middle of
the. All wells will include appropriate sand pack, screened interval isolation seal and
grout to the surface.

Following installation of the wells, the water levels in them will be allowed to stabilize for
48-hours and their water levels measured relative to the top of the well casings. They
will then be developed by surging and pumping to reduce turbidity to the greatest extent

Assessment Work Plan PAGE 14 EAS No. 22-5234
450 Polo road Winston Salem, NC October 19, 2022

possible. All purge water will be collected in appropriately labeled 55-gallon drums and
properly disposed following receipt of laboratory analytical results.

Prior to collecting samples from the wells, during the later phases of the well purging
process, EAS will measure the following parameters with appropriately calibrated field
meters: temperature, pH, turbidity, and specific conductance. When all parameters have
stabilized to within 5% of the previous reading, the well will be considered ready to
sample.

Groundwater samples from each well will be analyzed for VOCs by EPA Method 8260,
SVOCs by EPA Method 8270, and RCRA metals by EPA Method 6020, unfiltered. In
addition, the following quality control samples will also be submitted and analyzed for
VOCs: one trip blank, one field blank, and at least one duplicate sample per sampling
round (VOCs, SVOCs and RCRA metals, unfiltered.)

All field instruments and sampling equipment will be decontaminated between wells by
use of an Alconox soap solution, clean water rinse, followed by a deionized water rinse.
All field data will be recorded in field logs and Well Development Forms. EAS field
technicians will measure water levels in each well relative to the top of casing at least
24 hours after sampling is complete and elevations of each top of casing will be
determined by surveying methods. These water level and top of casing measurements
will be used to develop a groundwater potentiometric surface map with a graphic scale
and north arrow.

All groundwater sample analytical results will be compared to the 15A North Carolina
Administrative Code (NCAC) 02L.0202 Groundwater Standards (2L Standards) dated
April 1, 2022.

Groundwater sampling methodology will be conducted in accordance with the EPA
Region 4 Science and Ecosystem Support Division (SESD) Groundwater Sampling
Operating Procedure documented dated April 20, 2017.

Table 2
Groundwater Sample Analytical Procedures.

Property
Location/Potential
Source
Sample ID Analyses
Between Buildings
1 and 2 MW-1 VOCs 8260, SVOCs 8270, RCRA Metals
6020, Unfiltered
Between Buildings
2 and 3 MW-2 VOCs 8260, SVOCs 8270, RCRA Metals
6020, Unfiltered

Assessment Work Plan PAGE 15 EAS No. 22-5234
450 Polo road Winston Salem, NC October 19, 2022

Between Buildings
5 and 6 MW-3 VOCs 8260, SVOCs 8270, RCRA Metals
6020, Unfiltered
Building 7 MW-4 VOCs 8260, SVOCs 8270, RCRA Metals
6020, Unfiltered
Building 8 MW-5 VOCs 8260, SVOCs 8270, RCRA Metals
6020, Unfiltered
Western Property
Boundary MW-6 VOCs 8260, SVOCs 8270, RCRA Metals
6020, Unfiltered
Duplicate Sample Dup-1 VOCs 8260, SVOCs 8270, RCRA Metals
6020, Unfiltered

2.4.4 Soil Gas Sampling Procedures

Soil gas samples will be collected at each proposed structure location and at two
locations along the western boundary of the property where historical data suggest
possible migration of subsurface impacts from the former Salem Uniform facility. This
will include eight (8) buildings, two (2) locations along the western boundary, as well as
one (1) duplicate sample for a total of eleven (11) soil gas samples as summarized in
Table 3. As almost the entire site will be filled from depths of two (2) to nine (9) feet, all
soil vapor samples will be collected from a depth of five (5) feet below existing grade.
See Figure 4 for approximate cut and fill depths across the site and proposed sample
locations. Soil vapor samples will be collected using a vapor point implant system set
within a sand pack within the sampling interval which will be isolated by hydrated
bentonite seal. Soil gas sampling will follow modified US EPA Region 4 Laboratory
Services and Applied Science Division (LSASD) Procedure 307-R4. The steps are
summarized as follows.

1. An appropriately sized sampling hole will be drilled at each sampling location
using either a Geoprobe® drilling rig or a clean stainless steel hand auger.
Sampling depths will be five (5) feet from existing grade. After the hole has been
created the work area will be covered with a sheet of clean plastic sheeting. The
sampler(s) will don a pair of clean powder free rubber gloves.

2. Tooling will then be extracted to facilitate installation in the open borehole.

3. A properly decontaminated water level sounder will be used to verify
groundwater is not present in the bottom of the boring.

4. A 2-inch lift of clean sand will be placed at the terminus of the borehole.

5. A new single-use vapor implant will be connected to sample tubing and implant
will be lowered down the borehole to the top of sand via the sample tubing.

Assessment Work Plan PAGE 16 EAS No. 22-5234
450 Polo road Winston Salem, NC October 19, 2022

6. Clean sand will be slowly introduced into the boring until there are approximately
six inches of sand above the soil vapor implant. Care will be taken to ensure no
bridging of the sand.

7. The remaining borehole will be backfilled with bentonite crumbles to the ground
surface. Potable water will be used to hydrate the bentonite in intervals after the
first 6-inches of bentonite have been placed.

8. After installation, the system will be purged and a leak check performed. Purging
will be performed using a peristaltic pump and three-way valve to evacuate air
from the annular space below the sample point and sample tubing.

9. A leak check will be conducted by placing a shroud over the sample point and
saturating the air within the shroud with helium gas to a concentration between
approximately 70% and 80%. A helium gas detector will be used to determine the
concentration of helium within the shroud. Once concentrations in the shroud
have reached an acceptable level, the sample point will be purged into a Tedlar®
bag. The helium detector will then be used to screen the contents of the Tedlar®
bag to confirm it does not contain a helium concentration greater than 5% of that
detected in the shroud. Sample points will have to successfully pass the leak
check criteria prior to sampling. The leak check will be documented on the
sampling QA/QC field form.

10. Following a successful leak check, laboratory-supplied, individually certified 1-
liter Summa canisters will be connected to each of the sampling points via the
Teflon® tubing. Flow regulators on the Summa canisters will be set to collect the
samples at a flow rate of approximately 100 mL/min. After the samples are
collected, the canisters will be immediately shipped under chain-of-custody
protocol to H&P Mobile Geochemistry in Carlsbad, California for analysis of the
full list of US EPA Method TO-15 VOCs including Naphthalene. The Chain of
custody forms for soil gas samples will include the beginning, final, and
laboratory-received vacuum pressure readings.

Assessment Work Plan PAGE 17 EAS No. 22-5234
450 Polo road Winston Salem, NC October 19, 2022

Table 3
Soil Gas Samples

Sample ID Location Depth at Existing
Grade (feet) Analysis*
SG-1 Building 1 5’ Full TO-15 VOCs
SG-2 Building 2 5’ Full TO-15 VOCs
SG-3 Building 3 5’ Full TO-15 VOCs
SG-4 Building 4 5’ Full TO-15 VOCs
SG-5 Building 5 5’ Full TO-15 VOCs
SG-6 Building 6 5’ Full TO-15 VOCs
SG-7 Building 7 5’ Full TO-15 VOCs
SG-8 Building 8 5’ Full TO-15 VOCs
SG-9 Western property
boundary
5’ Full TO-15 VOCs
SG-10 Western property
boundary
5’ Full TO-15 VOCs
SG-Duplicate From SG-1 – SG-10 5’ Full TO-15 VOCs
* Analysis will be the TO-15 Extended 8260 list which includes Naphthalene and other
compounds

2.4.5 Documentation

Sample Labeling
After samples have been collected, they will be placed into certified laboratory clean
containers supplied by the laboratory. Each sample container will have a sample label
generated by the sampling personnel. Each sample container label will have, at a
minimum, the following information:
• Sample identification.
• Analysis requested.
• Project Number.
• Date and Time of Collection.

Soil and Groundwater Sample Packaging and Shipping
After the sample labels have been placed on each sample container, the outside of each
container will then be wiped clean. If necessary, a strip of clear tape will be applied on
the label to ensure the ink does not smear. Each sample will then be packaged and
shipped in the following manner:
• Check lid/cap to ensure proper closure to eliminate leaks.
• Check to ensure label is intact and legible.
• Place the labeled sample container in a sealed clear plastic zip bag.
• Place the samples in a clean waterproof shipping container (i.e. a cooler).
• Place a temperature blank (40 ml vial filled with water) in the container with the
samples.
• Label and place the trip blank in the container with the samples.
• Pack the shipping container with noncombustible packing material such as bubble

Assessment Work Plan PAGE 18 EAS No. 22-5234
450 Polo road Winston Salem, NC October 19, 2022

wrap to prevent container breakage.
• Enclose a copy of the chain-of-custody in a clear plastic bag and tape to the
underside of the shipping container lid.
• Tape the cooler shut using strapping tape over the hinges.
• Place custody seals that have been signed and dated across the top and sides of
the cooler so that they will be broken at the signature section of the seal when the
shipping container is opened.
• Place return address label clearly on the outside of the shipping container.
• If more than one shipping container is being sent to a laboratory, mark shipping
containers as 1 of 2, 2 of 2, etc.
• Ship by overnight delivery through a commercial carrier.
• Fill out an air bill for the laboratory so as to be received the next calendar day.
Address the recipient as “sample custodian.”

Soil Vapor Summa Canisters Shipping
Summa cannisters containing soil vapor samples will be checked to ensure they are
tightly secured, and dust caps attached as applicable. Labels will then be verified, and
they will be shipped in laboratory supplied protective containers, overnight under proper
chain of custody to the laboratory. Shipping containers will be sealed with Custody
Seals.

Custody Seals
Each sample shipping container will be sealed with strapping tape and with at least two
custody seals. The custody seals will be placed so that they will be broken at the
signature section of the seal when the shipping chest is opened. Each custody seal
shall include the following information:
• Date of sample shipment (release of custody).
• Signature of individual releasing custody.

Chain-of-Custody (COC)
COC forms will accompany the samples collected. The COC form sent to the laboratory
shall include the following information:
• Printed name and signature of sampler.
• Date and time relinquished.
• Project number.
• Sample numbers or identifications.
• Sample matrix (i.e. soil, groundwater).
• Type of sample (all should be discrete or grab).
• Analyses requested/turnaround time.
• Preservative information.
• Date and time of sample collection.
• Designation of laboratory QC samples.
• Date shipped/method of shipment/air bill number/laboratory address.

Each chain-of-custody form will be distributed as follows:

Assessment Work Plan PAGE 19 EAS No. 22-5234
450 Polo road Winston Salem, NC October 19, 2022

• The original laboratory copy will be placed in a zip lock bag, which will be sealed
and placed into the shipping container and shipped with the samples to the
laboratory
• A copy will be placed in the Job Folder

Field Documentation
The FOM will be responsible for maintaining a logbook and sample sheets that
document field activities. Criteria for the documentation include:
• Bound logbook.
• Indelible ink used for entries.
• Entries should be factual, detailed, and objective.
• Date and time of all entries.

Information to be recorded either in the field logbook or sample sheets will include as
applicable:
• Date and time of entry.
• Purpose of sampling.
• Name and affiliation of personnel performing sampling.
• Type of sample, e.g.: soil, groundwater.
• Description of samples (color, texture, etc.).
• Analysis requested.
• Description and location of the sampling point.
• Date and time of sample collection.
• Difficulties experienced in obtaining sample if applicable.
• Visual references, such as maps or photographs of the sampling site.
• Field observation, such as weather conditions during sampling periods.
• Whether chain-of-custody forms have been filled out for the samples.
• Laboratory name, address, and date shipped.

3.0 QUALITY ASSURANCE PROJECT PLAN

3.1 Introduction

The AWP was developed in accordance with the technical intent of the National
Contingency Plan. All drilling, soil and groundwater sampling, well installation, and
decontamination activities will be performed in accordance with the US EPA Region 4
Field Branches Quality System and Technical Procedures.

The AWP is designed to characterize potentially impacted soil, soil gas and groundwater
on the 450 Polo Road Property with regard to possible exposure risks to those impacted
media under residential land use. The primary objective of this AWP is to collect soil,
soil gas and groundwater samples that will allow measurement of chemical properties of
these media that are both accurate and precise. If the measured values are found to be
sufficiently accurate and precise, they will be considered reliable measurements of the
chemical properties of the sampled soil, soil gas and groundwater.

Assessment Work Plan PAGE 20 EAS No. 22-5234
450 Polo road Winston Salem, NC October 19, 2022

3.2 Data Quality Objectives (DQOs)

Data collected from suspect soils during the field sampling activities will be of a
quality such that it can be screened and compared to the NCDEQ-PSRGs. Soil gas
samples will be screened and compared to the NCDEQ-Residential Vapor Intrusion
Screening Levels. In the case of groundwater samples, laboratory analytical results will
be compared to the 15A NCAC 2L Standards. If an analyte is not listed in these
documents, it will be compared to their respective EPA Regional Screening levels
(RSLs). All laboratory data will be reported under a minimum of Level II QA/QC
protocols. Laboratory analysis will include the sample method detection limits meeting
applicable screening values and J-Flags will be reported for respective media.

All soil and groundwater samples will be analyzed by a State of North Carolina-certified
and NV L AP certif ied laboratory using promulgated US EPA methodology such
as those listed in Test Methods for Evaluating Solid Waste, Physical/Chemical
Methods, SW-846, 3rd Edition (SW- 846). The laboratory that will be performing
the TO-15 analysis in accordance with SW-846 has the certifications listed
in Section 2.5.2 above. These methodologies specify Quality Assurance and Quality
Control (QA/QC) procedures at are to be implemented by the approved laboratory
performing the analyses. The methods also provide guidelines regarding detection
capabilities and limits of sample quantification. If for any reason the sample quantitation
limit cannot meet the de minimis standard given in the guidance cited above, either due
to technological limitations of the method or sample matrix interference, the sample
method detection limit and J-Flags will be reported.

3.3 Data Quality Objectives – Seven Step Process

This DQO process was developed within the framework of the Guidance on Systematic
Planning Using the Data Quality Objectives Process EPA QA/G-4, and Section 3 of
Quality Assurance Guidance for Conducting Brownfields Site Assessment. DQOs for
this project are outlined in the following seven steps:

1: State the Problem
A Groundwater and Air Monitoring Report for an April 2019 Sampling Event dated
August 2019 conducted by AECOM detected PCE in groundwater at concentrations
above the 2L Standard of 0.7 ug/L in 22 monitoring well samples. Detected
concentrations of PCE exceeding the 2L Standard ranged from an estimated
concentration of 0.703 ug/L to 50,100 ug/L. Trichloroethene (TCE) was detected at
concentrations above the 2L Standard of 3 ug/L in 10 monitoring well samples.
Detected concentrations of TCE exceeding the 2L Standard ranged from an estimated
concentration of 3.68 ug/L to 684 ug/L. Additionally, cis-1,2-Dichloroethylene (DCE),
1,2-Dichloroethane (DCA), benzene, and vinyl chloride were detected at concentrations
above the 2L Standard in several samples. Groundwater isoconcentration maps
indicated that shallow groundwater beneath the western portion of the Property has
been adversely impacted by the PCE contamination plume migrating from this facility.

Assessment Work Plan PAGE 21 EAS No. 22-5234
450 Polo road Winston Salem, NC October 19, 2022

A previous Phase II Environmental Site Assessment conducted by Terraquest and
dated January 24, 2017 identified groundwater impacted with benzene and PCE at
levels that exceeded the 2L Standard benzene beneath the northwestern portion of the
Property; and elevated benzene, toluene, ethylbenzene, xylenes (BTEX), naphthalene,
1,2-dibromoethane (EDB), 1, 2-dichloroethane (DCA), 1,2,4-trimethylbenzene, 2-
hexanone and PCE concentrations were detected beneath the northeastern portion of
the Property.

Soil gas was not assessed and the extent of the impacts in soil and groundwater
throughout the areas of the Property proposed to be improved were not defined. A more
comprehensive study is needed to better assess potential risks to human health and the
environment with regard to the future residential land use on the Property.

2: Identify the Goals of the Study
The goals of this study are to determine if impacts exist in other areas of the Property
where they were not identified in the previous assessments, and to determine the extent
of environmental impacts where they were found to exist in this earlier study. Additional
goals of the study will be to determine what risks any measured impacts may pose to
human health and if additional assessment and/or remediation of the site is needed.

3: Identify Information Inputs
Soil, soil vapor and groundwater samples will be collected and analyzed from suspect
areas of the Property. Data obtained from these analyses will be used to characterize
the extent of environmental impacts on the Property, what, if any, risks these impacts
may pose to human health and the environment, and if any additional assessment may
be necessary. Soil and Groundwater samples will be collected and analyzed as
described in Section 2.4 of this AWP.

4: Define the Boundaries of the Study
The proposed study described in this AWP is limited to the geographic boundaries of
the 450 Polo Road Property. Regarding temporal limits, no regulatory time limits have
been indicated. It is, however, the goal of the owners of the 450 Polo Road
Property to have all work required in this first phase of the Brownfields project
complete, a report of findings of the study to NCDEQ, and response received
from NCDEQ as soon as possible.

5: Develop the Analytical Approach
Parameters of interest in this study have been indicated by information obtained during
the aforementioned previous assessments. If the findings of this study indicate
significant exceedances of the regulatory standards given in section 3.2 of this AWP,
additional assessment, and possibly remediation may be necessary.

Assessment Work Plan PAGE 22 EAS No. 22-5234
450 Polo road Winston Salem, NC October 19, 2022

6: Specify Performance or Acceptance Criteria
Laboratory analytical data obtained in the course of this study will be used to determine
if contaminants exist on the Property in excess of the criteria given in Section 3.2 of this
AWP. Historical research, earlier sampling data from the Property and the NCDEQ
AWP Checklist have helped guide the analytical parameters and sample locations
chosen. In the case of many of the sampling locations chosen for this study, there is no
strong evidence to suggest impacts may exist there, so at these locations analytical
data should serve to demonstrate an absence of the targeted constituents. EPA-
mandated laboratory procedures and protocols should help ensure performance criteria
are met. Some of these procedures and protocols include the use of equipment and
various sample blanks, duplicate samples, and evaluation of analyte recoveries. If one
or more of these protocols do not meet acceptance criteria, the data will be evaluated in
detail and if necessary, re-analysis or re-sampling conducted.

7: Develop the Plan for Obtaining Data

Design optimization to meet project goals within the project boundaries has been the
guiding force in the development of this AWP. In the course of evaluating the history of
potential source areas and exposure pathways, sampling locations and parameters
have been refined and adjusted. Analytical parameters and spatial distribution of
sampling locations have been developed to identify and characterize a wide range of
potential impacts across the entire Property, even at locations where available historical
information suggests a low probability of impacts. If additional information becomes
available or if site observations indicate the need to adjust or add sampling locations
while in the field, EAS will do this in consultation with the NCDEQ Brownfields project
manager.

4.0 MANAGEMENT OF INVESTIGATION DERIVED WASTES
The investigation derived wastes (IDW) associated with the performance of this
sampling plan will be containerized and characterized in accordance with 15A NCAC
02T.1503 (https://deq.nc.gov/media/14220/download) and 15A NCAC 02H. 0106
(https://files.nc.gov/ncdeq/DENR/documents/HPAI/Appendix%202%20Decontamination
.pdf) and will include the following:

• Drilling cuttings from the construction of monitoring wells
• Soils remaining from soil and soil vapor sample collection
• Monitoring well purge waters
• Wash waters derived from decontamination of equipment

All drilling cuttings obtained from the construction of monitoring wells, as well as any
soils remaining from the collection of soil and soil vapor samples, will be collected in
sealed in 55-gallon drums and stored in a secure location. Laboratory analytical data for
soil samples collected and analyzed during this investigation will be used to
characterize these soils for disposal. Following waste profiling these soils will be
properly disposed and documentation of their disposal obtained.

Assessment Work Plan PAGE 23 EAS No. 22-5234
450 Polo road Winston Salem, NC October 19, 2022

All monitoring well purge waters and wash waters derived from equipment
decontamination will be profiled for disposal using soil and groundwater data obtained
from this investigation. These wastewaters will be properly disposed as appropriate
based on this analytical data and documentation of their disposal will be obtained.

5.0 REPORTS
5.1 Site Assessment Report
Following completion of all field sampling activities, receipt of laboratory analytical
results, data review and validation and internal review, EAS will prepare a Site
Assessment Report. This report will describe all field activities, site observations and
findings of laboratory analytical results, and will include findings and conclusions
regarding any detections in soil, soil gas, and groundwater samples relative to the
action levels given in Section 3.2 along with sampling figures depicting sample locations
geolocated to sub-meter accuracy, sample depths, legends, graphic scales, north
arrows as well as groundwater contour and if applicable groundwater contamination
isoconcentration maps. The report will also boring logs, well construction and
abandonment records, FIRM PE license number and individual PE license number, seal
and signature.

Assessment Work Plan PAGE 24 EAS No. 22-5234
450 Polo road Winston Salem, NC October 19, 2022

ATTACHMENT A
FIGURES

Figure 1: Proposed Sample Location Map
Figure 2: Site Location Map
Figure 3: Potentiometric Map
Figure 4: Cut/Fill Analysis and proposed soil sampling
Proposed Sample Location Map
Project:450 Polo Road Property
Location:450 Polo Road Winston Salem, NC
EAS Project No.:225234
Source:Stimmel
Date:October 2022
Scale: NTS Figure 1
Project Site
Proposed Monitoring Well (MW) Locations
SS-1/SS-1-a/SG-1
SS-2/SS-2-a/SG-2
SS-3/SS-3-a/SG-3 SS-4/SS-4-a/SG-4
SS-5/SS-5-a/SG-5
SS-6/SS-6-a/SG-6
SS-7/SS-7-a/SG-7
SS-8/SS-8-a/SG-8
SG-9
SG-10
MW-1
MW-2
MW-3
MW-4
MW-5
MW-6
North
Building 1
Building 2
Building 3
Building 4
Building 5
Building 6
Building 7
Building 8
Proposed Soil Sample (SS) and Soil Gas (SG) Sampling Locations
Site Location Map North
Project:450 Polo Road Property
Location:450 Polo Road Winston Salem, NC
EAS Project No.:225234
Source:USGS Rural Hall, NC 2022
Date:October 2022
Scale: As Shown Figure 2
Groundwater Potentiometric Map North
Project:450 Polo Road Property
Location:450 Polo Road Winston Salem, NC
EAS Project No.:225234
Source:TBD
Date:October 2022
Scale: As Shown Figure 3
Cut Soil Sample Location Map North
Project:450 Polo Road Property
Location:450 Polo Road Winston Salem, NC
EAS Project No.:225234
Source:Stimmel 2020
Date:October 2022
Scale: As Shown Figure 4
0.0
Trench Utility Cuts Depths Variable ~2-8 feet into undisturbed soil
0.0
0.0
+2.5
0.0
0.0
0.0
+2.0
+2.5
+2.0
+2.0
+2.0
+2.0
+2.0
+2.0
+4.0
+5.0
+3.0
+3.0
+1.0
+4.0
0.0
+1.0 -2.0
+6.0
+6.5
+6.5
+6.0
+2.0
+7.5
+7.5
+7.5
+9.0 0.0
Projected Cut/Fill Depths; + values fill, -values cut
+6.0
CS-1
CS-2
CS-4/CS-4-a
CS-3
CS-5/CS-5-a’
CS-6/SC-6-a
CS-7
CS-8
Cut Soil (CS) Sample

Assessment Work Plan PAGE 25 EAS No. 22-5234
450 Polo road Winston Salem, NC October 19, 2022

ATTACHMENT B
Site Plat Showing Oil/Water Separator provided by Stratus Development Group