23061_Carausta Work Plan_20200729

01675-001/00215831
Terracon Consultants, Inc. 2701 Westport Road Charlotte, North Carolina 28208
P [704] 509 1777 F [704] 509 1888 terracon.com

March 19, 2020
Revised: July 29, 2020

North Carolina Department of Environmental Quality
Division of Waste Management – Brownfields Program
1646 Mail Service Center
Raleigh, North Carolina 27699-1646

Attn: Mr. William Schmithorst, PG
P: [phone]
E: [e-mail]

Re: Work Plan for Data Gap Assessment
Caraustar and Savona Mills
South Turner Avenue at Chamberlain Avenue
Charlotte, Mecklenburg County, North Carolina
NCBP #23061-19-060
Terracon Project No. 71167021

Dear Mr. Schmithorst:

On behalf of Savona II, LLC, Terracon Consultants, Inc. (Terracon) is pleased to submit this
Work Plan to conduct additional sampling at the above-referenced Caraustar and Savona
Mills property (the “site”) in Charlotte, North Carolina. The site was accepted into the North
Carolina Brownfields Program (NCBP) as Project No. 23061-19-060. The intent of the
additional sampling is to evaluate data gaps identified during an on-site meeting on
February 7, 2020 including representatives from Savona II, LLC, Terracon, Alexander Ricks,
PLLC and the North Carolina Brownfields Program. This Work Plan has been revised to
reflect changes to the proposed redevelopment plans and requests made by the NCBP.

Terracon Consultants, Inc. is licensed to practice geology and engineering in North Carolina.
The certification numbers of the Corporation are C-367 and F-0869, respectively.

A. PROJECT INFORMATION

The site consists of nine contiguous tax parcels totaling approximately 30.4 acres located on
both sides of South Turner Avenue and Chamberlain Avenue in Charlotte, North Carolina
(Figure 1). The southwestern portion of the site (Tax Parcel 071-114-12), located west of
South Turner Avenue and south of Chamberlain Avenue, is developed with two warehouses
and an office building associated with the former Savona Mill, Caraustar Industries and Old
Dominion Box Company operations. The southeastern portion of the site (Tax Parcels 071-
114-17, 071-105-01, 071-105-02, 071-105-03, 071-105-51 and 071-105-52), located along
both sides of South Turner Avenue, consists of the former Savona Mill facility, a small
community garden and shed, paved parking lots, vacant grass-covered land, a residence
Work Plan for Data Gap Assessment
Caraustar and Savona Mills ■ Charlotte, North Carolina
March 19, 2020; Revised July 29, 2020 ■ Terracon Project No. 71167021

01675-001/00215831
Responsive ■ Resourceful ■ Reliable 2

and Blue Blaze Brewery located within a metal auxiliary building, south of the main mill
building. The northern portion of the site (Tax Parcel 071-112-09), located north of
Chamberlain Avenue, is developed as a warehouse that presently contains a couple of
trolley cars and a small woodworking shop. The warehouse was previously occupied by
Caraustar Industries (Figure 2). Parcel 071-114-03 located in the northeastern corner of the
property is currently wooded and undeveloped. Terracon understands the site will be
redeveloped for mixed use, including planned multi-family buildings.

The site is bound to the south and southwest by Stewart Creek and wooded land and to the
south by State Street, residences and an automotive mechanics shop. Currently, adjoining
properties to the north and east consist predominantly of residences; however, the former
Flint Ink and Wikoff Color facilities were previously located adjacent to the site.

Terracon previously conducted a soil and groundwater assessment at the site in 2016 as
well as additional soil sampling in 2018. A total of 32 soil samples from depths ranging from
0 to 5 feet below land surface (bls) and five groundwater samples were collected in the
western portion of the site (Figure 2) and analyzed for volatile organic compounds (VOCs),
semi-volatile organic compounds (SVOCs), and Resource Conservation and Recovery Act
(RCRA) 8 Metals. The 2016 and 2018 investigations did not assess the property on which
the main Savona Mill building is located (Tax Parcel 071-114-17) or the five parcels located
east of South Turner Avenue (Tax Parcel 071-105-01, 071-105-02, 071-105-03, 071-105-51,
and 071-105-52).

B. SUMMARY OF DATA GAPS

While Terracon has obtained relatively comprehensive analytical data coverage across most
of the site, sampling either has not been conducted, or historical data warrants additional
characterization, in the following areas of the site:

◼ At the existing Savona Mill building;

◼ At the former Caraustar Warehouse building;

◼ On the tax parcels located east of South Turner Avenue;

◼ Within the wooded area located southwest of the intersection of South Turner
Avenue and Chamberlain Avenue; and

◼ Various areas of the site in which multi-family development is proposed and for which
soil vapor data has not been collected.

Terracon proposes to conduct limited sampling at the site focusing on these areas to
evaluate potential impacts from the former on-site mill operations, the adjacent former Flint
Work Plan for Data Gap Assessment
Caraustar and Savona Mills ■ Charlotte, North Carolina
March 19, 2020; Revised July 29, 2020 ■ Terracon Project No. 71167021

01675-001/00215831
Responsive ■ Resourceful ■ Reliable 3

Ink facility, and possible dumping activities within wooded areas of the site. Samples
collected at the rear of the former Caraustar Warehouse are intended to further characterize
environmental media near the previously identified (2018 sampling) elevated concentrations
of arsenic and benzo(a)pyrene within soil. Soil sample data will provide information that
may be used to determine proper management of soils in these areas during construction.
A summary of the proposed sampling plan is provided in Table 1 and the proposed sample
locations are depicted on Figure 2.

C. ADDITIONAL SAMPLING

Pre-Task Planning and Utility Locating
Terracon has a 100% commitment to the safety of all its employees. As such, and in
accordance with our Incident and Injury Free® safety culture, Terracon will develop a safety
plan to be used by our personnel during field services. Prior to commencement of on-site
activities, Terracon will hold a meeting to review health and safety needs for this specific
project. At this time, we anticipate performing fieldwork in a USEPA Level D work uniform
consisting of a hard hat, safety glasses, safety vest, protective gloves, and steel-toed boots.
It may become necessary to upgrade this level of protection while sampling activities are
being conducted should contaminants be encountered in soils or groundwater that present
an increased risk for personal exposure.

Prior to drilling activities, Terracon will contact NC-One Call, a public utility locating company,
to locate on-site underground utilities. In addition, Terracon will engage a private utility
locator to identify underground utilities that could be present at the boring locations.

Soil Sampling

Terracon will advance nine (9) soil borings (2020-SB-01 through 2020-SB-09) at selected
areas of the site. Soil samples will be obtained from the borings utilizing a Geoprobe® or a
similar direct-push drilling technology (DPT) and Macro-Core® samplers. Soil type, relative
moisture content, and other lithologic characteristics will be documented in the field.
Terracon will screen the soils in the field using a photo-ionization detector (PID) that detects
vapors from volatile organic compounds (VOCs). Soil samples will be collected from the
boring interval with the highest PID readings or if no significant evidence of an impact is
noted from the screening, the samples will be collected from the 0 to 5 ft. depth interval. One
blind duplicate sample will be collected in the field and submitted for analysis to assess
laboratory precision. Based on previous sampling activities at the site, investigative derived
wastes (soils) will be spread on the ground.

The soil samples will be placed in laboratory-prepared glass containers, labeled with
pertinent sample information and stored in an ice-packed cooler pending submittal to a
North Carolina certified laboratory for analysis of VOCs by EPA Method 8260, semi-volatile
Work Plan for Data Gap Assessment
Caraustar and Savona Mills ■ Charlotte, North Carolina
March 19, 2020; Revised July 29, 2020 ■ Terracon Project No. 71167021

01675-001/00215831
Responsive ■ Resourceful ■ Reliable 4

organic compounds (SVOCs) by EPA Method 8270 and the eight RCRA metals by EPA
Method 6010/6020/7471 in accordance with requirements by the NCBP. Speciated
chromium sample analysis will be conducted to distinguish between hexavalent and trivalent
chromium via EPA Method 7199. Chain of custody documentation will accompany the
samples to the laboratory.

Groundwater Sampling

Three of the soil borings will be advanced to the water table using a direct push technology
(DPT) drilling rig (2020-GW-01 through 2020-GW-03). Prior to advancing each boring, the
drill tooling will be cleaned to prevent cross-contamination of samples. Temporary 1-inch
diameter PVC well casing and a 10-foot section of 1-inch diameter 20-slot PVC well screen
will be inserted into each borehole. The screened interval will be placed in the boring to
intersect the water table since we expect only petroleum contaminants in the groundwater.
Sand and hydrated bentonite will be used to fill the annulus of the temporary wells. After
allowing sufficient time for equilibration, depth to groundwater measurements will be
obtained using an electronic water level meter. Terracon will obtain a Subsurface
Investigation Permit (SIP) from Mecklenburg County prior to installing the wells.

The top of the well casing elevation relative to a site-specific datum will be determined by
Terracon personnel using surveying instruments and a hand-held GPS unit. After surveying
and sampling activities are completed, the temporary wells will be abandoned in accordance
with NCAC Subchapter 2C regulations.

If depth to groundwater conditions allow, a peristaltic pump will be used for sample
collection. Samples will be collecting using low-flow techniques. Terracon will purge the
temporary monitoring wells until the groundwater quality parameters (e.g. pH, specific
conductance, oxidation-reduction potential and turbidity) have stabilized. Samples to be
submitted for metals analysis will not be collected until groundwater is below 10 NTUs.
Groundwater samples will be collected and placed in laboratory provided containers,
labeled, and placed on ice in a cooler which will be secured with a custody seal. The
samples will be submitted to a North Carolina certified laboratory for analysis of VOCs by
EPA Method 8260, SVOCs by EPA Method 8270 and RCRA metals by EPA Methods
6010/6020/7470 including hexavalent chromium by EPA Method 7196A. Due to the short
hold time for hexavalent chromium analysis, Terracon will utilize Pace Analytical of
Huntersville, North Carolina as the analytical laboratory.

A field/equipment blank for quality assurance/quality control (QA/QC) purposes will be
included as part of this investigation and will be sampled for VOCs only. One trip blank will
be submitted to the laboratory per cooler shipped. Due to a lack of detected constituents
(only naphthalene above the 2L standard) in previously sampled groundwater, purge water
will be poured onto the ground.
Work Plan for Data Gap Assessment
Caraustar and Savona Mills ■ Charlotte, North Carolina
March 19, 2020; Revised July 29, 2020 ■ Terracon Project No. 71167021

01675-001/00215831
Responsive ■ Resourceful ■ Reliable 5

Soil Vapor Sampling

Technical approaches and methods outlined in this proposed soil vapor investigation are in
general accordance with the Interstate Technical and Regulatory Council’s Vapor Intrusion:
A Practical Guideline (2007) and Vapor Intrusion Pathway: Investigative Approaches for
Typical Scenarios (2007), as well as the North Carolina Division of Waste Management
(DWM) Vapor Intrusion Guidance (2018).

Since the main Savona Mill building will be re-used as part of the redevelopment,
groundwater samples cannot be obtained within its footprint. Terracon will conduct a soil
vapor investigation designed to evaluate subsurface impacts and potential vapor intrusion
concerns in the building. Terracon will install four temporary sub-slab soil vapor sample
points (2020-SV-01 through 2020-SV-04) using a hammer drill. The points will be
constructed using a Vapor Pin™ installed within the 5/8-inch diameter hole. A pre-cut
silicone sleeve around the Vapor Pin™ will be hammered into the hole to create a
competent seal with the concrete floor slab. The Vapor Pin™ will be capped and the soil
gas point will be allowed to equilibrate for at least two hours before sampling.

In areas of proposed multi-family development, Terracon will install five shallow exterior soil
vapor sample points (2020-SV-05 through 2020-SV-09). Exterior soil vapor points will be
installed within DPT boreholes advanced to approximately 7 feet bgs. If shallow groundwater
is encountered, the total depth of the boring will be adjusted accordingly. The points will be
constructed by placing a six-inch stainless-steel screen implant at the base of the boring
within a one-foot thick layer of sand. A one-fit thick layer of dry granular bentonite will be
placed above the sand pack. Hydrated bentonite will be used to complete the borehole to
the surface. Teflon-lined tubing will extend from the implant to the surface, where it will be
capped, and the point allowed to equilibrate for at least two hours before sampling.

To test the integrity of the vapor sampling point seals, a shut-in test and a helium tracer test
will be conducted at each sample point. The tracer gas serves as a QA/QC method to verify
the integrity of the soil vapor probe seal. A field instrument capable of detecting helium will
be used to verify the presence and concentration of the tracer gas. The protocol for using a
tracer gas is to enclose the tubing and ground interface with a shroud and enrich the shroud
atmosphere with helium. Three volumes of the vapor point annulus and attached Teflon®
lined tubing will be purged. Purge samples will be field-screened for helium to assess the
presence of leaks in the seal and fittings and using a PID to detect volatile vapors. Sample
collection will begin if the tracer testing indicates helium concentrations in the vapor point
are less than 10 percent of the helium concentration in the shroud, indicating a sealed vapor
point annulus. The interior volume of each sample point will be purged to ensure the
conditions inside the point reflect soil vapor conditions. After purging, soil vapor samples will
be collected in a laboratory supplied, batch-certified 1-liter Summa® canister with a flow
controller set for to draw air at less than 200 milliliters per minute (mL/min). The vacuum
Work Plan for Data Gap Assessment
Caraustar and Savona Mills ■ Charlotte, North Carolina
March 19, 2020; Revised July 29, 2020 ■ Terracon Project No. 71167021

01675-001/00215831
Responsive ■ Resourceful ■ Reliable 6

pressure of the sample canister will be monitored and recorded at regular intervals
throughout the sampling period. Terracon will cease sample collection prior to the vacuum
pressure reaching 0 mmHg. One blind duplicate sample will be collected in the field and
submitted for analysis to assess laboratory precision.

Following completion of the field activities, the Summa® canisters, along with chain-of-
custody documentation, will be shipped to Con-Test Analytical Laboratory in East
Longmeadow, Massachusetts for laboratory analysis of volatile organic compounds (VOCs)
by EPA Method TO-15. North Carolina does not certify laboratories for air analysis;
however, Con-Test is certified to perform air analyses in the following States: Florida
(#E871027 NELAP); Virginia (#1381); New Jersey (#MA007 NELAP) and Maine
(#2011028). Con-Test will be contacted in advance of the soil vapor sampling event to
ensure that the method detection limits will be lower than the applicable screening level
concentrations. Terracon will note estimated concentrations between the laboratory
reporting limits and method detection limits (“J-flagged” concentrations), if any, in the report.
In addition, Terracon will request Con-Test record the sample canister vacuums on the
chain-of-custody documentation upon their receipt. As an additional QA/QC measure, one of
the soil vapor samples will be analyzed for helium via ASTM-1946 or EPA Method 3C. A
level 2 QA/QC data package will be requested for the gas samples.

Brownfields Receptor Survey

A Brownfields Receptor Survey will be completed as part of the assessment of the site. The
“Brownfields Receptor Survey” form will be used to conduct the field and office-based
portions of the survey. The completed form and a summary of findings will be included in
the Brownfields Assessment Report.

D. BROWNFIELDS ASSESSMENT REPORT

Upon completion of soil, groundwater and possibly vapor sampling activities and receipt of
the laboratory analytical results, a report will be prepared that will include the following
items:

◼ Documentation of field activities;
◼ Site plan showing pertinent site features;
◼ Soil boring logs;
◼ Receptor survey findings;
◼ Laboratory analytical results;
◼ Data evaluation and presentation of findings including comparison of soil data to
applicable regulatory standards; and,
◼ Recommendations concerning further action, if necessary

Work Plan for Data Gap Assessment
Caraustar and Savona Mills ■ Charlotte, North Carolina
March 19, 2020; Revised July 29, 2020 ■ Terracon Project No. 71167021

01675-001/00215831
Responsive ■ Resourceful ■ Reliable 7

The report will be completed in a format suitable for submittal to the North Carolina
Brownfields Program. Work associated with this scope of services will be performed under
the direction of a Licensed Geologist registered in the State of North Carolina.

E. GEOTECHNICAL EVALUATION

While not part of this Brownfields Work Plan, the Prospective Developer plans to conduct an
additional geotechnical evaluation of the Brownfields Property. The geotechnical work is
anticipated to consist of soil borings and test pits. Soils excavated from the test pits will be
placed into the corresponding excavation.

We appreciate the opportunity to provide this proposal and look forward to working with you
on this project. If you have any questions or comments regarding this proposal or require
additional services, please contact us at [phone].

Sincerely,
TERRACON CONSULTANTS, INC.

William O. Frazier, P.G. Christopher L. Corbitt, P.G.
Project Geologist Senior Geologist

Attachments: Figure 1 – Topographic Map
Figure 2 – Proposed Sample Locations
Table 1 – Proposed Sample and Analysis Plan

NC Brownfields Data Gap AssessmentCaraustar and Savona MillsNCBP# 23061-19-060500 South Turner AvenueCharlotte, Mecklenburg County, North Carolina
Copyright:© 2013 National Geographic Society, i-cubed
USGS TOPOGRAPHIC MAPCHARLOTTE EAST, NORTH CAROLINA QUADRANGLE (1988)
0 2,000 4,000 6,000 8,000 10,0001,000 Feet
CONTOUR INTERVAL: 10FT
FIGURENO.
Filename:
Date:
PM:
Drawn By:
Checked By:
Approved By:
Project No.
Scale:
1
2701 Westport Road Charlotte, North Carolina 28208
Phone: [phone] Fax: [phone]
1:24,000
July 2020
Topographic Map
Site
1 inch = 2,000 feet
³
WOF 71167021
WOF
CLC
CLC
P71207090_1.mxd
Proposed Sample Locations FIGURENO.
#*
#*
#*
#*
#*
#*
#*
#*
#*
@A@A
@A
&>
&>
&>
&>
&>
&>
NC Center for Geographic Information & Analysis
Legend
Site BoundaryTax Parcels
&>Historical Soil SampleProposed Multi-Family Buildings
@A Historical Groundwater Sample
&>Proposed Soil Sample
@A Proposed Groundwater and Soil Sample
#*Proposed Soil Vapor Sample
NC Brownfields Data Gap AssessmentCaraustar and Savona MillsNCBP# 23061-19-060500 South Turner AvenueCharlotte, Mecklenburg County, North Carolina2701 Westport Road Charlotte, North Carolina 28208Phone: [phone] Fax: [phone]
³
0 400 800200Feet
PM:
Drawn By:
Checked By:
Approved By:
WOF
WOF
CLC
CLC
Project No:
Scale:
Filename:
Date:July 2020
71167021_Ex2
1 inch = 400 feet
71167021
2South Turner AvenueChamberlain Avenue
2020SB-03 / GW-03
2020-SB-09
2020SB-01 / GW-01
2020SB-02 / GW-02
2020-SB-04
2020-SB-05
2020-SB-06
2020-SB-08
2020-SB-07
2020-SV-01
2020-SV-02
2020-SV-03
2020-SV-04
S t a t e S t r e e t
Former Flint Ink
Former CaraustarWarehouse
Savona MillsBuilding
Rozzelles Ferry Road
2020-SV-05
2020-SV-06
2020-SV-09
2020-SV-08
2020-SV-07
VOCs - 8260SVOCs - 8270RCRA 8 Metals - 6010VOCs - TO-15Helium (3C)Direct PushTemporary Monitoring WellSumma Canister0-5 2020-SB-01 soil X X X X
0-5 SB-DUP*soil X X X X
10-20 2020-GW-01 GW X X X X
10-20 GW-DUP*GW X X X X
sub-slab 2020-SV-01 SV X X X
sub-slab 2020-SV-02 SV X X
sub-slab 2020-SV-03 SV X X
sub-slab 2020-SV-04 SV X X
sub-slab SV-DUP*SV X X
0-5 2020-SB-02 soil X X X X
10-20 2020-GW-02 GW X X X X
0-5 2020-SB-04 soil X X X X
0-5 2020-SB-05 soil X X X X
0-5 2020-SB-06 soil X X X X
10-20 2020-GW-03 GW X X X X
4.5-5 2020-SV-05 SV X X
4.5-5 2020-SV-06 SV X X
4.5-5 2020-SV-07 SV X X
4.5-5 2020-SV-08 SV X X
4.5-5 2020-SV-09 SV X X
0-5 2020-SB-07 soil X X X X
0-5 2020 SB-08 soil X X X X
0-5 2020-SB-09 soil X X X X
Abbreviations:
VOCs - volatile organic compounds
SVOCs - semi-volatile organic compounds
RCRA 8 Metals - Resource Conservation and Recovery Act Metals
GW - groundwater
ft bls - feet below land surface
Sample depths reflect a composite range for soil samples and a propsed screen interval for groundwater samples
*The duplicate QA/QC samples are listed within this Area of Concern for reference only; duplicate sample locations will be selected
at random in the field and may be collected from other areas of concern.
Proposed Multi-Family
Housing
Collection MethodAnalysis
Southeastern Parcels /
Former Flint Ink
Former Caraustar
Warehouse
Site Area /
Area of Concern
Depth
(ft bls)ID #Matrix
Table 1
Proposed Sample and Analysis Plan
NC Brownfields Data Gap Assessment
Caraustar and Savona Mills (NCBP# 23061-19-060)
500 South Turner Avenue, Charlotte, North Carolina
Savona Mills Building
Terracon Project No. 71167021