27003_Winston_Container_BF_Assessment_WP Rev1_signed_20231023

October 23, 2023
Ms. Carolyn Minnich, Brownfields Project Manager North Carolina Department of Environmental Quality
Division of Waste Management, Brownfield Redevelopment Section
Mail Service Center 1646 Raleigh, North Carolina 27699-1646

Subject: Brownfields Assessment Work Plan – Revision 1
Former Winston Container
4901 Winston Container Road, Charlotte, North Carolina
Mid-Atlantic Project #H1712.00
Brownfields Project #27003-23-060

Dear Carolyn:

On behalf of Industrial Development Partners, LLC (the Prospective Developer or PD),
Mid-Atlantic Associates, Inc. (Mid-Atlantic) has prepared this Brownfields Assessment
Work Plan (Work Plan) for the Former Winston Container Brownfields property
(Brownfields Project #27003-23-060) for your review, comment, and approval. The
Brownfields property is located at 4901 Winston Container Road, Mecklenburg County,
North Carolina (subject site). The subject site consists of two (2) contiguous parcels of
land (Parcel ID #11510201 and 11510203) totaling approximately 15.5 acres in a
predominantly industrial area east of the Charlotte Douglas International Airport. A
topographic site map is included as Drawing 1.

This Work Plan has been prepared and submitted to satisfy the requirements identified
during a recent data gap conference call with North Carolina Department of
Environmental Quality (NCDEQ), Mid-Atlantic, and Industrial Development Partners, LLC
personnel concerning proposed future redevelopment and the PD’s pursuit of a
Brownfields Agreement (BFA).

1.0 INTRODUCTION & BACKGROUND

The subject site is comprised of two (2) contiguous parcels of land that is zoned for
industrial use and is located less than a half-mile east of the Charlotte Douglas
International Airport. The subject site is developed with two (2) approximate 5,800 square
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NCDEQ Brownfield Project #27003-23-060
Mid-Atlantic Project #H1712.00

foot single-story warehouse structures that were constructed in 1946. Remaining portions
of the subject site consist of overgrown vegetative areas, portions of former building slabs,
and minor debris piles. A portion of Taggart Creek cuts through the northern portion of
the subject site and also borders the western and southern property boundaries. A
detailed site layout map is provided in Drawing 2.

The PD plans to redevelop the Brownfields property as primarily a surface storage and
lay-down yard (equipment, vehicles, containers, etc.). No new structures are currently
planned, and the existing warehouse structures will likely be re-purposed. Prior to the
submittal of an Environmental Management Plan (EMP) for the planned redevelopment,
NCDEQ requested that assessment activities be conducted on the Brownfields property
to address certain gaps for redevelopment activities.

Based on data gap discussions with Ms. Carolyn Minnich of the Brownfields
Redevelopment Section (BRS), Mid-Atlantic proposes to 1) collect surface water and
sediment samples within the on-site sections of Taggart Creek, 2) collect soil samples in
the vicinity of areas of concern from historical site operations, 3) collect groundwater
samples from the existing permanent monitoring wells to determine the current
groundwater conditions, and 4) collect interior soil vapor samples to determine potential
vapor intrusion risks for future development. Mid-Atlantic also proposes to conduct a
receptor survey for the site and surrounding area. The subject site background and
proposed scope of work is provided below.

2.0 BACKGROUND

The subject site was originally developed at the Winston Container Company (WCC) in
the late 1950’s as a drum reconditioning facility. Operations continued until approximately
2006 when the site was vacated. Drum reconditioning activities included the use of
several underground storage tanks (USTs) during the operational timeline at the facility:
one 10,000-gallon diesel tank (Tank #1), one 4,000-gallon methyl-ethyl ketone (MEK)
tank (Tank #2), and one 6,000-gallon #2 fuel oil tank (Tank #3). Additionally, several
wastewater aboveground storage tanks (ASTs) were utilized in central portions of the
subject site. Former on-site structures that have since been demolished were utilized as
a garage, drum conditioning plant, wastewater treatment station, and a drum cutting and
incineration area. Debris piles consisting of concrete, tires, and plastic drums have been
observed along the northernmost portions of Taggart Creek. Drum debris and other
historical facility waste have also been identified along the southernmost portions of
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Taggart Creek, which borders the subject site to the west and south and flows through
the northcentral portion of the subject site. Historical site features are depicted on
Drawing 2. Pertinent tables and figures from historical assessment activities are included
as Appendix A.

In November 1992, Tank #1 and Tank #2 were reportedly emptied and closed in place
via inert concrete slurry. Assessment activities were conducted between November 1992
and February 1993 in relation to the UST closure activities. Results of the assessment
were documented in a UST Closure Report dated July 7, 1993 and described below:

• Four (4) soil samples (WC-6 through WC-9) were collected at the base of the
4,000-gallon MEK tank (Tank #2). Laboratory results indicated that concentrations
were below method detection limits for MEK.
• Four (4) soil samples (WC-1, WC-2, WC-4, and WC-5) were collected at the base
of the 10,000-gallon diesel tank (Tank #1). A fifth soil sample (WC-3) was collected
from beneath the product piping. Laboratory results indicated that concentrations
were below method detection limits for total petroleum hydrocarbons (TPH) diesel
range organics (DRO) in the samples collected from the base of Tank #1.
However, TPH DRO was detected at 486 milligrams per kilogram (mg/kg) in
product piping sample WC-3.
• Between December 1992 and February 1993, additional samples were collected
from underneath the product pump (UP), product line (UL), and end of tank (ET)
to delineate the vertical extent of soil impacts from Tank #1. Laboratory results
from initial samples collected from beneath the pump (UP-5’) and line (UL-5’)
indicated that TPH DRO was detected at concentrations of 17,154 mg/kg and
13,214 mg/kg, respectively.
• Impacted soils were excavated and subsequent sampling was conducted at the
base of the excavation of soils beneath the product pump and lines. Confirmation
sampling of the product line (UL2) indicated that TPH DRO was not detected above
method detection limits. However, samples collected beneath the product pump
(UP2 through UP4) indicated that TPH DRO was detected between 34 mg/kg and
657 mg/kg.
• Based on the analytical results, it was concluded that the likely source of soil
impacts around Tank #1 were the result of a leak from the pump. In total,
approximately 30 cubic yards of impacted soils were removed from the vicinity of
Tank #1 and place in the central portion of the subject site for future on-site
treatment via minimum rate landfarming.
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An Initial Site Assessment was reportedly conducted in 2006 for the North Carolina
Department of Environment and Natural Resources (NCDENR, currently NCDEQ)
Aquifer Protection Section (APS). Assessment activities included the installation of four
(4) groundwater monitoring wells (MW-1 through MW-4). Additionally, Initial Abatement
Action activities were conducted in 2008 in relation to the 6,000-gallon #2 fuel oil tank
(Tank #3) which included the installation of two (2) monitoring wells (MW-5 and MW-6).
These two reports were not available to Mid-Atlantic and are not included in the historical
data tables and figures in Appendix A.

In February 2009, assessment and closure activities were conducted in relation to Tank
#3. Tank #3 was historically utilized for heating purposes and was installed in the 1970’s.
WCC stopped using Tank #3 sometime in the 1980’s due to the availability of natural gas
and remained in place. The tank remained in place due to its location beneath the plant
building, which was constructed as an addition after the tank was installed. Following the
cessation of site activities in 2006, WCC opted to remove Tank #3 ahead of potential
redevelopment of the property. Results of the assessment and UST closure activities
were documented in a Limited Site Assessment Report for T03 – UST Closure dated June
29, 2009 and described below:

• On January 25, 2008, Hill Enterprises emptied Tank #3 which consisted of remnant
a mixture of fuel oil and water. The basin around Tank #3 was subsequently
excavated and the tank was removed.
• Two (2) soil samples (W1 and W2) were collected at the base of Tank #3.
Laboratory results indicated that concentrations of TPH DRO and TPH gasoline
range organics (GRO) exceeded NCDENR UST Action Levels.
• Four (4) additional confirmation soil samples (E, N, W, and S) were collected
around the extent of the excavation to determine the horizontal extend of soil
impacts. Laboratory results indicated that concentrations of TPH DRO exceeded
UST Action Levels. Additional sample volume was included for risk-based
analyses including volatile organic compounds (VOCs), volatile petroleum
hydrocarbons (VPH), and extractable petroleum and hydrocarbons (EPH).
Laboratory results of the risk-based analyses did not indicate that concentrations
were present above UST Action Levels and Soil-to-Water Maximum Soil
Contaminant Concentrations (MSCCs).
• Monitoring wells installed during Initial Abatement Action activities (MW-5 and MW-
6) were sampled to determine if groundwater impacts from the apparent UST
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Mid-Atlantic Project #H1712.00

release were present. MW-5 was installed upgradient of the former Tank #3
location and MW-6 was installed in the backfilled basin of Tank #3.
• Laboratory results indicated that concentrations were below method detection
limits for VOCs and VPH in the groundwater samples for MW-5 and MW-6.

On January 14, 2010, Shield Engineering, Inc. (Shield) was notified by the Mecklenburg
County Land Use and Environmental Services (LUESA) of potential drum remnants being
present on the subject site. Subsequent site reconnaissance was conducted along
Taggart Creek in the southwestern portion of the WWC property by Shield, LUESA, the
Environmental Protection Agency (EPA) Emergency Response personnel, and Tetra
Tech. Drum remnants, construction debris, plastics, and other household debris were
observed to be present from the surface to depths of approximately 6 feet below ground
surface (ft bgs). Tetra Tech collected four (4) soil samples for lead (ICD-SS-1 through
ICD-SS-4) and three (3) samples for paint waste (ICD-WS-1 through ICD-WS-3). Lead
results indicated concentrations ranged from 52 parts per million (ppm) to 55,400 ppm.
Following initial soil assessment activities, remedial actions were conducted by Shield
and the findings are documented in an Assessment and Remedial Activities Report dated
May 12, 2010. A summary of the results is below:

• Shield oversaw the excavation of two (2) test pits identified as Excavation 1 and
Excavation 2. The excavations were in the vicinity of the buried waste identified
along Taggart Creek and previous soil samples collected by Tetra Tech.
Excavation 1 extended to 10 ft bgs and included drum debris, tires, concrete, and
other suspect debris. Excavation 2 extended to approximately 8 ft bgs and was
observed to primarily contain household debris and automotive parts. No
remnant drums were observed in Excavation 2.
• During the excavation activities, a silver/gray paint substance was observed in
Excavation 1 at a depth of approximately 6 ft bgs. Shield submitted a sample
(WC-1) of the material for laboratory analysis . Analytical results indicated the
presence of several VOCs, SVOCs and toxicity characteristic and leaching
procedure (TCLP) concentrations metals concentrations exceeding regulatory
screening levels.
• Shield collected two (2) soil samples from the base of the excavations (EX-1 Bot
and EX-2 Bot) for laboratory analysis of lead. Analytical results indicated that
lead was detected in EX-1 (219 mg/kg) and EX-2 (6.7 mg/kg) at concentrations
below the Soil-to-Water MSCC of 270 mg/kg.
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• Between January 20 and 28, 2010, Shamrock Environmental Corporation
(Shamrock) conducted additional excavation, bank stabilization, and stream
protection activities along Taggart Creek. A total of approximately 1,227 tons of
contaminated soil and debris were disposed off-site to a Subtitle D landfill.
• Over-excavation during remediation activities resulted in lead concentrations in
residual soils ranging from 4.4 ppm to 8.4 ppm which are below the Soil-to-Water
MSCC. Low-level detections of the VOCs acetone, chlorobenzene, 1,3,-
dichlorobenzene, 1,4-dichlorobenzene, isopropyltoluene, naphthalene, 1,2,4-
trimethylbenzene, and xylenes were also present in residual soil but below their
respective MSCCs.

As part of environmental due diligence activities for the Charlotte Douglas International
Airport, Amec Foster Wheeler (Amec) conducted a Phase I Environmental Site
Assessment (ESA) at the WCC property in December 2015 and identified the following
recognized environmental conditions (RECs) in connection with the subject site:

• The soil and groundwater contamination documented on the subject site and the
facility status in the Inactive Hazardous Sites Branch (IHSB) established by the
NCDEQ was considered to be a REC.
• The previous uses of the subject site as a drum reconditioning facility over an
approximate 50-year period and the former storage of hazardous materials was
considered a REC.
• Previous reports indicated the presence of a potable water supply well on the
subject site. The property owner informed Amec that two (2) water supply wells
were abandoned on May 12, 2007. As such, Amec did not consider the water
supply wells to constitute a REC.

Following Phase I ESA activities, Amec conducted groundwater assessment activities at
the subject site to determine the location of the potentially impacted groundwater relative
to Taggart Creek. Results of the assessment were submitted to the Charlotte Douglas
International Airport in a Report of Phase II ESA dated May 26, 2016. A summary of the
environmental findings is summarized below:

• On April 4, 2016, Amec oversaw the installation of five (5) temporary monitoring
wells (TW-1 through TW-5). Temporary monitoring wells TW-1 and TW-2 were
installed in the vicinity of the observed drum debris area from 2010, TW-3 and TW-
4 were installed between outfall pipes to Taggart Creek in the southwestern portion
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of the subject site, and TW-5 was installed near the eastern property boundary and
permanent monitoring well MW-2.
• Groundwater was calculated to flow from the eastern portion of the property near
the former Winston Container building to the west and south toward Taggart Creek.
• Between April 13 and 14, 2016, Amec collected groundwater samples from four
(4) existing permanent monitoring wells (MW-1 through MW-4) and the five (5)
newly installed temporary monitoring wells.
• Laboratory analytical results of the groundwater samples collected indicated the
presence of several VOCs above method detection limits. Concentrations of
benzene, 1,1-dichloroethane, 1,2-dichloropropane, 1,2-dichlorobenzene, 1,4-
dichlorobenzene, naphthalene, tetrachloroethylene (PCE), toluene, xylenes, and
vinyl chloride were detected above North Carolina 15A NCAC 02L .0202
Groundwater Quality Standards (2L Standards).
• With the exception of PCE (MW-2 and MW-4), benzene (TW-3), and 1,4-
dichlorobenzene (TW-3), 2L Standard exceedances were mostly observed in
temporary wells installed in the vicinity of the drum debris area (TW-1 and TW-2).

The PD petitioned the property into the BRS (Brownfields Project #27003-23-060) and
received a Letter of Eligibility (LOE) on July 14, 2023. Ms. Carolyn Minnich, the PD, and
Mid-Atlantic personnel had a data gap meeting on August 30, 2023 that outlined specific
data gaps for the Brownfields property. Data gaps included assessment activities to
evaluate site soil, surface water, sediment, groundwater, and soil vapor in order to
evaluate the risk for future mixed-use development. Also included in the assessment
request was the completion of a receptor survey for the site and surrounding area. The
following Work Plan documents proposed assessment activities to satisfy the data gap
requirements ahead of planned redevelopment of the Brownfields property.

3.0 RECEPTOR SURVEY

Mid-Atlantic will perform a Brownfields receptor survey in accordance with NCDEQ
Brownfields guidance. The receptor survey will include information about land use in the
near vicinity including zoning and identify water supply wells, basements, utility manways
and chases, storm sewers, other underground utilities, drains, and surface water within a
1,500-foot radius of the Brownfield property boundary. Additionally, Mid-Atlantic will
review applicable resources for potential wells in the area and, if warranted, contact utility
companies for information concerning underground utilities in the immediate area of the
Brownfields property.
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4.0 PROPOSED BROWNFIELDS ASSESSMENT ACTIVITIES

This Work Plan has been prepared to satisfy data gaps identified during discussions with
the NCDEQ BRS. The assessment activities requested in this Work Plan were to be
conducted prior to approval of an EMP for the proposed redevelopment at the Brownfields
property.

Prior to assessment activities, Mid-Atlantic will contact the North Carolina public utility
locating company (North Carolina 811) and contract with a private utility locator to mark
utilities at the proposed sample locations. Additionally, proposed sample locations will be
hand cleared utilizing a hand auger to a depth of 5 ft bgs to further screen the boring
locations for the presence of subsurface utilities. Soil borings, surface water/sediment
samples, existing permanent monitoring wells, and soil vapor sampling locations will be
documented in the field using a hand-held global position system (GPS) unit. Coordinates
will be documented in the field notes and transferred to site drawings for sampling location
documentation and subsequent reporting.

The proposed assessment activities will be performed in general accordance with the
NCDEQ Inactive Hazardous Sites Branch (IHSB) Guidelines for Assessment and
Cleanup dated July 2021, NCDEQ Division of Waste Management (DWM) Vapor
Intrusion Guidance dated March 2018, NCDEQ Brownfields Methane Assessment
Protocol dated December 2020, and most recent versions of the USEPA Region IV
Science and Ecosystem Support Division (SESD) Field Branches Quality System and
Technical Procedures guidelines. Mid-Atlantic proposes to conduct the following
assessment activities at the Brownfields property:

• Three (3) co-located surface water and sediment samples will be collected within
the on-site portions of Taggart Creek to determine if historical site operations have
impacted the creek and/or potential contaminants coming from upgradient
sources.
• Nine (9) soil samples (SB-1 through SB-9) will be collected in potential areas of
concern.
• If located and deemed to be in good condition, up to four (4) existing permanent
monitoring wells (MW-1 through MW-4) will sampled to characterize the current
groundwater conditions.
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• Four (4) interior sub-slab soil vapor samples (SSV-1 through SSV-4) will be
collected beneath the existing structures to determine potential vapor intrusion
risks for future redevelopment.

The sampling locations are depicted on Drawing 2. The proposed Brownfields
assessment methodology is described in the sections below.

4.1 Surface Water and Sediment Assessment Activities

Mid-Atlantic will collect up to three (3) co-located surface water and sediment samples
(SW-1/SED-1 through SW-3/SED-3) from portions of Taggart Creek that run through the
subject site. The co-located surface water and sediment samples will be collected from
the approximate mid-point of the tributary using a decontaminated swing sampler and a
disposable polyethylene container. Mid-Atlantic will collect the samples from downstream
to upstream locations in order to minimize the disturbance of sediment and cross-
contamination by sampling personnel. Following sample collection in the swing sampler,
samples will be transferred into laboratory-supplied glassware and placed on ice for
delivery under chain-of-custody protocol within 24 hours of collection to a North Carolina
accredited laboratory. Surface water and sediment samples collected will be analyzed for
VOCs by EPA Method 8260, semi-VOCs (SVOCs) by EPA Method 8270, and Resource
Conservation and Recovery Act (RCRA) metals by EPA Methods 6020/7471. The
sediment samples will also be analyzed for hexavalent chromium by EPA Method 7199.
A table summarizing surface water and sediment sampling details is provided in Table 1
and Table 2, respectively.

4.2 Soil Assessment Activities

Mid-Atlantic will collect up to nine (9) soil samples (SB-1 through SB-9) in potential areas
of concern from historical operations. The soil borings will be advanced using a track-
mounted Geoprobe® drill rig to depths up to approximately 10 feet below ground surface
(ft bgs) via direct-push technology (DPT) drilling methods. Mid-Atlantic will instruct the
drilling subcontractor to collect continuous soil samples from each boring using acetate
lined macrocore sleeves. Soil samples from soil boring advancement will be logged for
lithological description and field screened for indication of potential impacts by
observation for staining, unusual odors, and the presence of organic vapors using a
calibrated photoionization detector (PID). Based on future redevelopment plans including
surficial grading, Mid-Atlantic will collect one (1) soil sample from each boring from a
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shallow depth (i.e., 0 to 2 ft bgs). If field screening results indicate the presence of
potential impacts that are than 2 ft bgs, Mid-Atlantic will collect an additional soil sample
from a deeper depth interval.

The soil samples will be collected into laboratory-supplied glassware and placed on ice
for delivery under chain-of-custody protocol within 24 hours of collection to a North
Carolina accredited laboratory. Soil samples collected will be analyzed for VOCs by EPA
Method 8260, semi-VOCs (SVOCs) by EPA Method 8270, and RCRA metals plus
hexavalent chromium by EPA Methods 6020/7471/7199. A table summarizing soil water
sampling details is provided as Table 3.

4.3 Groundwater Assessment Activities

Four (4) existing permanent monitoring wells (MW-1 through MW-4) are present on the
subject site. Mid-Atlantic will attempt to locate all four (4) monitoring wells and, if in good
condition, collect a groundwater sample utilizing low flow/low stress purging techniques
with a peristaltic 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
purged at a rate no greater than 200 milliliters per minute (mL/min). Mid-Atlantic will utilize
a water quality meter 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. Pre-sampling 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]). Groundwater samples
will be collected directly into laboratory supplied sample containers using the “soda straw”
method to minimize the potential for volatile compound loss through the peristaltic pump
head. The groundwater samples will be collected into laboratory-supplied glassware and
placed on ice for delivery under chain-of-custody protocol within 24 hours of collection to
a North Carolina accredited laboratory. The groundwater samples collected will be
analyzed for VOCs by EPA Method 8260, SVOCs by EPA Method 8270, and RCRA
metals by EPA Methods 6020/7471.

4.4 Soil Vapor Assessment Activities

Mid-Atlantic will mobilize to the subject site to install four (4) permanent sub-slab vapor
pins (SSV-1 through SSV-4) beneath footprint of the existing building structures. Prior to
vapor pin installation, Mid-Atlantic will document the existing condition of the concrete
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slab and note the presence of any cracks and/or other areas of settlement. Building and
slab conditions will be documented in the final Brownfields Assessment Report.

The sub-slab vapor implants will be installed using Cox Colvin Vapor Pins™ that will be
advanced with a hammer drill equipped with a 5/8-inch diameter drill bit though the
concrete slab and approximately 6-inches into the underlying soil. Following borehole
advancement, loose cuttings will be removed with a shop-vac prior to installation of the
Vapor Pins™. The Vapor Pin™ assembly, which is comprised of a brass sampling point
and silicone sleeve, was then placed into the drilled hole by tapping the assembly using
an installation/extraction tool and a dead blow hammer to form an airtight seal. Following
installation of the Vapor Pin™ assembly, dedicated 1/4-inch Teflon sample tubing will be
connected to the barbed end of the vapor implant. Following installation of the vapor pins,
Mid-Atlantic will allow the sample points to equilibrate for at least 30 minutes prior to
conducting a shut-in test, leak check, and collecting the vapor samples.

Mid-Atlantic will conduct leak checks at each vapor sampling location by utilizing helium
as the tracer compound, which will be introduced through a shroud over the probe and
sampling train. Helium will be introduced into the shroud, which will encompass the entire
sampling train, to a minimum concentration of 50% as measured using a LandTech
Gem™ 5000 helium detector. With the canister valve closed, Mid-Atlantic will conduct a
leak check sample using a LandTech Gem™ 5000 helium detector to check for the
presence of helium from air collected in the Tedlar® bag using the specified helium
detector. Using a 60-milliliter syringe and 3-way valve connected to the tubing, Mid-
Atlantic will collect three (3) purge volumes from each sampling implant into the Tedlar®
bag and field screen each Tedlar® bag for integrity (absence of Helium) prior to opening
the sampling train to the Summa canister. Purge volume will take into account both the
tubing volume and sampling train void space. The leak check will be considered
successful if the helium concentration measured in the Tedlar® bag is less than 10% of
the concentration measured within the shroud. Helium concentrations in the shroud, along
with concentrations from each purge volume will be recorded in the field notes. A shut-in
test will also be conducted on the sampling process lines to ensure an air-tight connection
by applying vacuum pressure to the lines and observing for vacuum pressure loss.

Following successful shut-in tests/leak checks to verify sample integrity and prior to
sample collection, the vapor samples will be purged at a maximum rate of 200 millimeters
per minute (200 mL/min) to clear stagnant air from the sub-slab vapor implant screen and
sampling train. The vapor samples will be collected using batch-certified/laboratory-
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supplied 1-Liter Summa canisters with calibrated flow regulators set to 100 mL/min to
avoid sample short circuiting and to further ensure sample integrity. Samples that have
lost greater than 10% volume from the initial lab recorded volumes will not be used. Prior
to sampling, vacuum readings, Summa identification and flow controller identification for
each sample will be recorded in the field notes. Once the field documentation is complete,
the sample train will be opened to the Summa flow controller and the Summa canister will
be opened to allow collection of sub-slab vapor volume. Sampling will be deemed
complete when the flow controller exhibits no more than -5 inches of mercury. Following
sample collection, the Summa canisters will be closed, and the final vacuum reading and
sampling time intervals will be recorded on the canister tag and on the laboratory chain-
of-custody form. Following soil vapor sample collection, stainless-steel caps will be
screwed onto the permanent sub-slab vapor implants for future sampling (if necessary).
Samples will be delivered under chain-of-custody protocol to Pace Analytical (formerly
Con-Test) for analysis by VOCs by EPA Method TO-15 plus naphthalene. Pace’s air
laboratory holds National Environmental Laboratory Accreditation (NELAC), AIHA
Laboratory Accreditation, and ISO/IEC 17025 certifications. Pace will provide final
Summa canister vacuum readings upon receipt. A table summarizing vapor sampling
details is provided in Table 4.

5.0 LABORATORY QA/QC

For quality assurance and quality control purposes (QA/QC), Mid-Atlantic will collect one
(1) duplicate surface water sample, one (1) duplicate sediment sample, one (1) duplicate
soil sample, one (1) duplicate groundwater sample, and one (1) duplicate soil vapor
sample. The duplicate soil vapor sample will be collected simultaneously as the parent
sample via a laboratory-supplied “T-connector.” Duplicate samples will be submitted for
the same laboratory analysis as the parent samples. Additionally, Mid-Atlantic will request
that the laboratory include a groundwater trip blank for VOC analysis to ensure no cross-
contamination was encountered during field handling and shipping of the samples.
Samples submitted for laboratory analysis will include an adequate sample volume for
laboratory matrix spike (MS) and matrix spike duplicate (MSD) analysis. Nondedicated
equipment and tools will be decontaminated prior to use at each soil boring and temporary
monitoring well location. 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.

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Samples will be picked up by a laboratory courier under chain-of-custody protocol. Mid-
Atlantic 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.

6.0 INVESTIGATIVE DERIVED WASTE MANAGEMENT

Investigative derived waste (IDW) generated during the proposed Brownfields
assessment activities will be managed in general accordance with NCDEQ IHSB
Guidelines for Assessment and Cleanup. Soil collected from soil boring advancement will
be temporarily staged in 55-gallon drum(s) pending laboratory results. If necessary, soil
drum(s) will be disposed off-site to an NCDEQ-approved facility. If analytical results do
not indicate the soil needs to be disposed off-site, Mid-Atlantic will thin spread soil on-
site. Future soil encountered during redevelopment activities will be handled in
accordance with an Environmental Management Plan that will be submitted under
separate cover for NCDEQ approval.

7.0 REPORTING

Based on driller availability, Mid-Atlantic anticipates conducting the assessment activities
in November 2023. Mid-Atlantic anticipates receipt of laboratory analytical data within ten
(10) days of sampling upon receipt of laboratory analysis, Mid-Atlantic will prepare a
written Brownfields Assessment Report summarizing our field procedures and findings,
including copies of the laboratory documentation, field forms, boring logs, driller logs,
supporting tables and figures, and risk calculator forms. The Brownfields Assessment
Report is anticipated to be submitted to NCDEQ within two (2) weeks of laboratory
analytical results. The report will be sealed by a North Carolina Licensed Geologist or
Professional Engineer.

Mid-Atlantic appreciates the opportunity to provide this Work Plan for consideration.
Please contact the undersigned if there are questions concerning our proposed approach.

Brownfields Assessment Work Plan (Rev 1) October 23, 2023 Former Winston Container – Charlotte, NC Page 14
NCDEQ Brownfield Project #27003-23-060
Mid-Atlantic Project #H1712.00

With best regards,

MID-ATLANTIC ASSOCIATES, INC.

Greg D. Icenhour, P.G., MBA Shane Sisco, P.G.
Principal Geologist Project Hydrogeologist

Attachments: Assessment Work Plan Approval Signature Page

Tables
Table 1 – Proposed Surface Water Sampling Matrix
Table 2 – Proposed Sediment Sampling Matrix
Table 3 – Proposed Soil Sampling Matrix
Table 4 – Proposed Groundwater Sampling Matrix
Table 5 – Proposed Soil Vapor Sampling Matrix

Drawings
Drawing 1 – Topographic Site Map
Drawing 2 – Site and Sample Location Map

Appendix
Appendix A – Historical Tables and Figures

Mid-Atlantic is authorized to practice engineering by the North Carolina Board of Examiners for Engineers
and Surveyors, License F-0967 and Geology under the North Carolina Board for Licensing of Geologists,
License C-186.

ATTACHMENT 1 DEQ Brownfields Redevelopment Section Assessment Work Plan Approval Signature Page
To be completed by Development Team and returned to DEQ Brownfields for review & signature. Brownfields Project Name: Former Winston Container Brownfields Project Number: 27003-23-060 Work Plan Title: Brownfields Assessment Work Plan
Date: 10/23/2023 Revision Number: 1 Be advised that this approval from DEQ Brownfields 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.
Prospective Developer (PD): Industrial Development Partners, LLC Contact Person: Christian Samartino Phone Numbers: Office: [phone] Mobile: Click or tap here to enter text. Email: [e-mail] Property Owner (if different from above): Click or tap here to enter text. Contact Person: Click or tap here to enter text. Phone Numbers: Office: Click or tap here to enter text. Mobile: Click or tap here to enter text. Email: Click or tap here to enter text.
Environmental Consultant: Mid-Atlantic Associates, Inc. Contact Person: Shane Sisco, P.G. Phone Numbers: Office: [phone] Mobile: [phone] Email: [e-mail] Signature:

Brownfields Project Manager: Carolyn Minnich Phone Numbers: Office: Click or tap here to enter text. Mobile: [phone] Email: [e-mail] Signature:

Consultant: Mid-Atlantic Associates, Inc. Date 10/23/2023
Printed Name/Title/Company: Shane Sisco, P.G. / Project Manager
Brownfields Project Manager:Click or tap here to enter text. Date Click or tap to enter a date.
10/23/2023

TABLES

VOCs SVOCs RCRA Metals
SW-1 Grab x x x --
SW-2 Grab x x x DUP-1
SW-3 Grab x x x --
4 4 4 --
Notes:
1) Surface water samples will co-located with sediment samples.
2) Samples will be collected from downstream to upstream locations to minimize potential for migration of sediment.
VOCs = volatile organic compounds by EPA Method 8260
SVOCs = semi-VOCs by EPA Method 8270
RCRA = Resource Conservation and Recovery Act metals by EPA Methods 6020/7471
Totals
On-site Tributary to Taggart Creek
Sample Type Analytical Method QA/QA
SamplesSample ID Sample Location
TABLE 1
Proposed Surface Water Sampling Matrix
Former Winston Container
4901 Winston Container Road, Charlotte, Mecklenburg County, North Carolina
NCDEQ Brownfield Project #27003-23-060
Mid-Atlantic Project #H1712.00
VOCs SVOCs RCRA Metals
SED-1 Grab x x x --
SED-2 Grab x x x DUP-2
SED-3 Grab x x x --
4 4 4 --
Notes:
1) Sediment samples will be collected from the approximate midpoint of the streambed at each location and co-located with surface water samples.
2) Samples will be collected from downstream to upstream locations to minimize potential for migration of sediment.
VOCs = volatile organic compounds by EPA Method 8260
SVOCs = semi-VOCs by EPA Method 8270
RCRA = Resource Conservation and Recovery Act metals plus hexavalent chromium by EPA Methods 6020/7471/7199
Totals
On-site Tributary to Taggart Creek
Sample ID Sample Location Sample Type Analytical Method QA/QA
Samples
TABLE 2
Proposed Sediment Sampling Matrix
Former Winston Container
4901 Winston Container Road, Charlotte, Mecklenburg County, North Carolina
NCDEQ Brownfield Project #27003-23-060
Mid-Atlantic Project #H1712.00
VOCs SVOCs RCRA Metals
SB-1 Contaminated Soil Application / Landfarm Area 10 feet Grab x x x --
SB-2 Former OWS / 250-gallon Diesel AST 10 feet Grab x x x --
SB-3 Former 10,000-gallon Diesel UST 10 feet Grab x x x --
SB-4 Former Wastewater ASTs 10 feet Grab x x x --
SB-5 Former 4,000-gallon MEK UST 10 feet Grab x x x --
SB-6 Former 6,000-gallon #2 Fuel Oil UST 10 feet Grab x x x --
SB-7 Former Wastewater Treatment Station 10 feet Grab x x x DUP-3
SB-8 10 feet Grab x x x --
SB-9 10 feet Grab x x x --
SB-10 10 feet Grab x x x --
SB-11 10 feet Grab x x x --
12 (1)12 (1)12 (1)--
Notes:
1) One surficial (i.e., 0 to 2 ft bgs) sample will be collected from each soil boring. One additional sample may be collected based on field screening results.
VOCs = volatile organic compounds by EPA Method 8260
SVOCs = semi-VOCs by EPA Method 8270
RCRA = Resource Conservation and Recovery Act metals plus hexavalent chromium by EPA Methods 6020/7471/7199
OWS = Oil / Water Separator
MEK = Methyl ethyl ketone
QA/QA
SamplesSample Type Analytical Method
UST = Underground Storage Tank
Sample ID Proposed DepthSample Location
Totals
AST = Aboveground Storage Tank
Former Excavation Pits
Debris Piles
TABLE 3
Proposed Soil Sampling Matrix
Former Winston Container
NCDEQ Brownfield Project #27003-23-060
Mid-Atlantic Project #H1712.00
4901 Winston Container Road, Charlotte, Mecklenburg County, North Carolina
VOCs SVOCs RCRA Metals
MW-1 Western Portion of Site Grab x x x --
MW-2 Eastern Portion of Site Grab x x x DUP-4
MW-3 Southern Portion of Site Grab x x x --
MW-4 Former Drum Cutting /
Incineration Area Grab x x x --
5 5 5 --
Notes:
1) Existing permanent monitoring wells may not be able to be located and/or sampled if not in good condition.
VOCs = volatile organic compounds by EPA Method 8260
SVOCs = semi-VOCs by EPA Method 8270
RCRA = Resource Conservation and Recovery Act metals by EPA Methods 6020/7471
Totals
Sample ID Sample Location Sample Type Analytical Method QA/QA
Samples
TABLE 4
Proposed Groundwater Sampling Matrix
Former Winston Container
4901 Winston Container Road, Charlotte, Mecklenburg County, North Carolina
NCDEQ Brownfield Project #27003-23-060
Mid-Atlantic Project #H1712.00
Analytical Method
VOCs
SSV-1 Sub-Slab x --
SSV-2 Sub-Slab x DUP-5
SSV-3 Sub-Slab x --
SSV-4 Sub-Slab x --
5 --
Notes:
VOCs = volatile organic compounds by EPA Method TO-15 plus naphthalene
Mid-Atlantic Project #H1712.00
TABLE 5
Proposed Vapor Sampling Matrix
Former Winston Container
4901 Winston Container Road, Charlotte, Mecklenburg County, North Carolina
NCDEQ Brownfield Project #27003-23-060
Sample ID Sample Location QA/QA
Samples
Totals
Proposed Depth
Western Warehouse
Eastern Warehouse / Office
DRAWINGS
DRAWN BY: DATE:
ENG. CHECK:
JOB NO:DRAFTCHECK: GIS NO:
SITE
´
1:10,000SCALE =
York
Gaston Mecklenburg
Union
Lincoln
Cabarrus
Rowan
§¨¦I77
§¨¦I485
§¨¦U321
§¨¦U321 F
§¨¦U521 §¨¦I277 F
0 850 1,700425Feet
REFERENCES:1. CHARLOTTE WEST, NC DIGITAL RASTER GRAPHICS, USGS, SCANNED FROM 1:24,000-SCALE MECKLENBURG COUNTY, NC TOPOGRAPHIC MAPS, PUBLISHED 2022, USGS.2. PROPERTY BOUNDARY FROM MECKLENBURG COUNTY GIS.3. INSET MAP DATA DOWNLOADED FROM ARCGIS ONLINE.
AREA SHOWN WITHINMECKLENBURG COUNTY, N.C.
TOPOGRAPHIC SITE MAPFORMER WINSTON CONTAINER4901 WINSTON CONTAINER ROADCHARLOTTE, NORTH CAROLINA APPROVAL:
OCTOBER 2023
DWG NO: 1
CONTOUR INTERVAL = 10 FEET
GDI 07G-H1712.00-01
MSS H1712.00
!(
!(
!(
!(
!(
!(
!(
!(
!(
!(
!(
@A
@A
@A
@A
&,
&,&,
&,
)""OWS
&>
&>
&>
××ÍWWTMi
n
u
t
e
ma
n
Wy Bi
l
ly Graham PyAirport DrAirport Center PyJosh Birmingham RaMorris Field DrJosh Birmingham Py
Winston Container Rd
SITE AND SAMPLE LOCATION MAPFORMER WINSTON CONTAINER4901 WINSTON CONTAINER ROADCHARLOTTE, NORTH CAROLINA
DRAWN BY:DATE:
ENG. CHECK:
JOB NO:
APPROVAL:
DRAFTCHECK:GIS NO:
DWG NO: 2
OCTOBER 2023
H1712.00
REFERENCES: 1. 2023 AERIAL IMAGERY FROM NC ONEMAP. 2. MECKLENBURG COUNTY GIS.
´LEGEND
Subject Property
Parcel Boundaries
Former Area ofExcavation
Former Debris Pile
Former AbovegroundStorage Tank Farm
Former UndergroundStorage Tank
Creeks/Streams
Streets
)""OWS Historic Oil-WaterSeparator
××ÍWWT Former WastewaterTreatment Station
@A Existing Monitoring Well
&>
Proposed Co-locatedSurface Water &Sediment SampleLocations
&,Proposed Sub-SlabVapor Sample Location
!(Proposed Soil SampleLocation
0 400 800200Feet
1:2,400SCALE =
MSS
GDI
07G-H1712.00-02Taggar
t Cr
e
ek
T agga rt C re e kSW/SED-1
SW/SED-2
SW/SED-3
SB-10
SB-2
SB-3
SB-4
SB-5
SB-6
SB-7
SB-8
SB-9
MW-2
SSV-1
SSV-2
SSV-3SSV-4
Former PlantLocation Former Drum Cutting/Incineration Area
Contaminated SoilApplication Area
FormerGarage
SB-1
SB-11
MW-1
MW-3
MW-4

APPENDIX A

Historical Tables and Figures

Well ID Well TOC -
Elevation
Depth of
Groundwater
Below TOC
Groundwater
Elevation
10.10 626.94
10.19 626.85
3.80 633.28
3.76 633.32
10.83 626.23
10.95 626.11
10.60 627.25
10.62 627.23
11.20 633.31
11.64 632.87
10.55 628.47
NM NM
7.80 633.33
NM NM
4.63 631.17
NM NM
Notes:
TOC=Top of Casing
4/14/2016
4/14/2016
4/14/2016
4/14/2016
4/14/2016
4/26/2026
4/14/2016
4/14/2016
4/14/2016
TW-5 4/26/2026
Table 1: Groundwater Elevation Data
Former Winston Container Company
Charlotte, North Carolina
Amec Foster Wheeler Project: 6228-15-0284
4/26/2026TW-1
TW-2 4/26/2026
637.04
637.08
Date Measured
635.80
Top of casing elevations established relative to the TOC elevation for well MW-4
(635.80 feet above mean sea level) from previous data.
637.06
637.85
644.51
639.02
641.13
MW-1 4/26/2026
4/26/2026MW-2
MW-4 4/26/2026
TW-3
TW-4 4/26/2026
MW-1 MW-2 MW-4 TW-1 TW-2 TW-3 TW-4 TW-5
NC 2L
Standards
Benzene <0.5 <0.5 <0.5 14.6 36.6 7.2 <0.5 <0.5 1.0
1,1- Dichloroethane <0.5 <0.5 <0.5 <0.5 52.1 <0.5 <0.5 <0.5 61,2- Dichloropropane <0.5 <0.5 <0.5 <0.5 13.8 <0.5 <0.5 <0.5 0.6
1,2,4- Trichlorobenzene <2.0 <2.0 <2.0 <2.0 10.4 <2.0 <2.0 <2.0 70
1,2,4-Trimethylbenzene <0.5 <0.5 <0.5 3.0 71.5 1.9 <0.5 <0.5 400
1,2-Dichlorobenzene <0.5 <0.5 0.69 0.84 142 1.3 <0.5 <0.5 201,3- Dichlorobenzene <0.5 <0.5 0.58 0.72 30.1 1.3 <0.5 <0.5 200
1,3,5-Trimethylbenzene <0.5 <0.5 <0.5 0.76 25.6 0.75 <0.5 <0.5 400
1,4-Dichlorobenzene <0.5 <0.5 0.91 2.0 196 9.3 <0.5 <0.5 6
4-Chlorotoluene <0.5 <0.5 <0.5 0.67 41.2 <0.5 <0.5 <0.5 NSLCarbon tetrachloride <0.5 <0.5 <0.5 <0.5 <2.5 <0.5 <0.5 <0.5 0.3
Chlorobenzene <0.5 <0.5 <0.5 23.2 34.4 26.2 1.4 <0.5 50
Chloroethane <1.0 <1.0 <1.0 2.1 <5.0 1.1 <1.0 <1.0 3000Chloroform<0.5 <0.5 <0.5 <0.5 <2.5 <0.5 <0.5 <0.5 70
cis - 1,2-DCA <0.5 0.51 3.9 1.3 16.7 <0.5 <0.5 <0.5 70
Ethylbenzene <0.5 <0.5 <0.5 1.1 284 2.5 <0.5 <0.5 600Isopropylbenzene <0.5 <0.5 <0.5 1.4 6.3 1.1 <0.5 <0.5 70
Naphthalene <2.0 <2.0 <2.0 3.9 14.4 <2.0 <2.0 <2.0 6
n-Propylbenzene <0.5 <0.5 <0.5 0.81 10.8 <0.5 <0.5 <0.5 70
sec-Butylbenzene <0.5 <0.5 <0.5 0.60 <2.5 <0.5 <0.5 <0.5 70
Styrene <0.5 <0.5 <0.5 <0.5 8.1 <0.5 <0.5 <0.5 70
Tetrachloroethene <0.5 2.2 8.8 <0.5 <2.5 <0.5 <0.5 <0.5 0.7
Toluene <0.5 <0.5 <0.5 7.2 895 4.2 <0.5 <0.5 600
Total Xylenes <1.5 <1.5 <1.5 10.9 993 17.8 <1.5 <1.5 500trans-1,2 Dichloroethene <0.5 <0.5 <0.5 <0.5 4.0 <0.5 <0.5 <0.5 100
Trichloroethene <0.5 <0.5 2.0 <0.5 <2.5 <0.5 <0.5 <0.5 3
Vinyl Chloride <1.0 <1.0 <1.0 1.1 12.2 <1.0 <1.0 <1.0 0.03
Notes:
µg/L: Micrograms per liter
Table 2: Summary of Groundwater Analytical Results - VOCs
Former Winston Container Company
Charlotte, North CarolinaAmec Foster Wheeler Project: 6228-15-0284
Volatile Organic
Compounds, µg/L
Sampling Locations
Constituent concentrations that exceeded NC2L standards are identified inBold font.Prepared By:LMM 4/22/16NSL=No Standard Listed Checked By:YGS 4/22/16
Note: Orinigal Well MW-3 was not sampled because it was inaccessable
&<
&<
&<&<&<
&<
&<&<&<
MW-4
TW-4
TW-1TW-2TW-3
MW-3
TW-5MW-2MW-1
NC OneMap, NC Center for Geographic Information and Analysis, NC 911Board
Document Path: F:\AMEC_Projects\2015\6228-15-0284 Winston Container Property\GIS\MXDs\TrimblePoints.mxd0 150 30075Feet
±
PREPARED BY: MS DATE: 4/27/2016 CHECKED BY: RF
MONITORING WELL LOCATIONSFormer Winston Container Property4901 Winston Container RoadCharlotte, North Carolina
PROJECT NO: 6228-15-0284 FIGURE NO: 1DATE: 4/27/2016
&<Monitoring Well Site Boundary
&<
&<
&<&<
&<
&<
&<&<&<
MW-4(631.17)
TW-4(627.25)
TW-1 (626.94)TW-2(633.28)
TW-3(626.23)
MW-3
TW-5 (633.31)MW-2(633.33)MW-1(628.47)
633
632
626
631630
629
627
628
NC OneMap, NC Center for Geographic Information and Analysis, NC 911 Board
Document Path: F:\AMEC_Projects\2015\6228-15-0284 Winston Container Property\GIS\MXDs\GroundwaterContours.mxd±
2PROJECT NO:FIGURE NO:6228-15-0284NOTE: Data from well TW-2 was not used to develop groundwater contours
LEGENDGroundwater Flow DirectionGroundwater Contour (feet msl)&<Monitoring WellSite Boundary
GROUNDWATER CONTOUR MAPFORMER WINSTON CONTAINER COMPANY4901 WINSTON CONTAINER ROADCHARLOTTE, NORTH CAROLINA
0 200100Feet
(631.17) Groundwater elevation in feet msl (April 14, 2016)