25044 - George Fern Co - Brownfields Assessment Work Plan - 20221228

Via Email
December 28, 2022

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

Attn: Mr. Seth Titley

Re: Brownfields Assessment Work Plan
George Fern Company
2310 Old Steele Creek Road
Charlotte, North Carolina
Brownfields Project No. 25044-21-060
H&H Project No. FDI-001

Dear Seth:

On behalf of Furniture Distributors, Inc., please find the enclosed Brownfields Assessment Work
Plan prepared for the George Fern Company Brownfields property for your review and approval.
Should you have any questions or need additional information, please do not hesitate to contact
us at [phone].

Sincerely,

Hart & Hickman, PC
Haley Martin, PG Ralph McGee, PG
Senior Project Geologist Project Manager

Enclosure:

cc: Mr. Ken Corley and Mr. Michael O’Loughlin, Furniture Distributors, Inc. (Via Email)

Minimum Requirements Checklist
for
Site Assessment
Work Plans and Reports
NCDEQ Brownfields Program – February 2022
Instructional Page
All references to Prospective Developers includes follow-on owners who may be conducting
work in accordance with the Brownfields Property Management Unit.
To increase predictability and most efficiently assess Brownfields Properties and the
redevelopment timing requirements of Prospective Developers or follow-on owners, the
Brownfields Program has standardized the format for Site Assessments. This format has been
generated in the form of a checklist to allow for ease in submission by the prospective developer’s
consultant and for the Brownfields Program’s completeness review. This checklist outlines the
minimum requirements and submittal format under the Brownfields Program for Assessment
Requirements and Reporting. All Assessment Work Plans and Reporting submissions to the
Brownfields Program must include this completed checklist in the outlined format.
These requirements allow DEQ to reduce review time for the Assessment Work Plan and Report
and increase process predictability for prospective developers. This checklist will also provide
reliable data for risk-based decisions and further expedite the project timeline. Any divergence
from these requirements will lengthen the process of assessing risks on the site, may necessitate
reprioritization of a project manager’s queue towards projects that meet these requirements.
Therefore, delaying production of the brownfields agreement and/or environmental management
plan. Any alterations to the checklist on a site- specific basis must be reviewed and approved by
the Program prior to implementation. However, in order to respect the schedule of all projects in
house and keep the program’s entire project pipeline moving, we strongly recommend against
seeking changes to the checklist.
Based on a review of environmental and risk data from our project inventory, please note
there are some new points of emphasis that are included herein:
1. For ALL residential reuses; sub-slab vapor assessment (full list EPA TO-15) is required,
regardless if existing structures will be removed. If no structures or slabs exist on the
Brownfields Property, exterior soil gas assessment is required within all proposed
structure footprints. 
2. ALL properties require groundwater data (VOCs, SVOCs and RCRA Metals) from a
minimum of three sample locations, depth to groundwater and a resulting potentiometric
map. 
3. Soil shall be assessed based on areas of concern and redevelopment plans and across the
depth interval of the cut/grading.
Environmental Site Assessment
Work Plan Checklist
Completed by: Haley Martin – Hart & Hickman, PC
Reviewed by: Seth Titley - NCDEQ Brownfields Program

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

Section 1 – Introduction
X Provide the site location, address, and acreage.
X Provide a BRIEF summary of the history of the property and its history in the program. For example:
reiterate RECs from a Phase I ESA, indicate if the scope of work was negotiated during a Data
Gap Meeting, etc.
X Briefly list and describe the data gaps the assessment is attempting to fill
NA Indicate if the assessment data is for the use of any other DEQ programs in addition to the
Brownfields Program (i.e. the site is a regulated UST, IHSB, etc. property)
Section 2 – Scope of Work
X Provide a general description of proposed scope of work covered in this plan (i.e. 2 new
monitoring wells, six groundwater samples, 5 exterior soil gas sampling points and 6 soil
borings)
X Discuss samples to be collected by media and source area/location. Generally, the reasoning for
the sample locations selected.
X Describe depths of samples to be collected (Reference Table 1) or how that decision will be
made in the field, if needed.
X State for what each sample will be analyzed (briefly). Reference Table 1.
- For all residential reuses, sub slab vapor is required, if no slabs exist, exterior soil gas is required
within all proposed footprints.
Section 3 – Sampling Methodology
X Reference the guidance documents you intend to use. IHSB, EPA SESD, VI Guidance, Well
Construction Rules (NCAC 2C). Note deviations or methodology planned that is not covered by
such guidance (e.g., multi-increment sampling, passive air samplers, mobile labs, Hapsite,
simultaneous indoor/outdoor radon, high-volume subslab vapor testing, PFAS sampling).
X Describe what will be installed (soil boring, temporary well, permanent well, sub slab vapor,
exterior soil gas, etc.). Include construction details.
X Discuss installation methodology (Hand Auger, DPT, etc.)
X Discuss sample collection procedures. Include the following, at a minimum:
 Equipment to be used
 Purging methods and volumes
 Stabilization parameters for groundwater sampling
 Field screening methods
 Leak check procedures for sub-slab vapor and exterior soil gas samples (Note this is
required)
 Discuss how and when vacuum readings will be collected (for summa cans)
X Discuss sample point abandonment

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

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

Section 6 – Investigation Derived Waste (IDW) Management
X Discuss what IDW will be generated and how it is proposed to be managed. Management
recommendations should be in accordance with 15A NCAC 02T.1503 and 15A NCAC 02H.
0106. Generally, if the Brownfields Property has not previously been assessed, then all IDW
must be containerized and characterized prior to management. Previous assessment data that
indicate no Hazardous Waste (listed or characteristic) is likely to be encountered in the area of
proposed assessment will be required before thin spreading of IDW on-site is permitted.
Section 7 – Reporting
This section should discuss the components of the assessment report which will be prepared as a result
of the above sample collection. At a minimum, the report shall include:
X Reporting/summary of site work conducted for all sections outlined above in this checklist;
X Summary of findings and possible recommendations;
X All applicable tables and figures outlined below with the addition of:
Tables for tabulated analytical data per media sampled and analyzed, compared against
applicable screening levels, sample depths and depth to groundwater;
Figure depicting actual sample locations collected, with each media depicted in the
legend, graphic scale and north arrow; and
Groundwater potentiometric map, with graphic scale and north arrow.
‐ Boring logs for all soil borings, newly constructed monitoring wells, and exterior soil gas
locations 
‐ Well construction and abandonment records, if applicable
X Firm PE/PG License Number
X Individual PE/PG seal & signature

Attachments
X Table 1 – Proposed Sample Locations and Analyses on a Summary Table that includes:
Sample ID
Sample Objective
Proposed Depth(s)
Analytical Method(s)
QA/QC Samples
Background Samples

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

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

X_ Figure 3 – Site Potentiometric Map
- Buildings
- Groundwater sample identification labels
- Graphic scale and north arrow

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

NA Figure 5 – Proposed Development (if available)
Overlay of historical and proposed sample locations
Graphic scale and north arrow
NA Appendix – Summary of Historical Analytical Data
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Brownfields Assessment Work Plan
George Fern Company
2310 Old Steele Creek Road
Charlotte, North Carolina
Brownfields Project No. 25044-21-060
H&H Job No. FDI-001

Table of Contents

1.0 Introduction .............................................................................................................................1 
1.1 Background Information .......................................................................................................1 
1.2 Previous Assessment Activities .............................................................................................2 
2.0 Brownfields Assessment Activities ........................................................................................6 
2.1 Receptor Survey ....................................................................................................................6 
2.2 Soil Sampling Activities ........................................................................................................7 
2.3 Groundwater Sampling Activities .........................................................................................9 
2.4 Sub-Slab Soil Gas Sampling Activities ...............................................................................10 
2.5 Quality Assurance – Quality Control ..................................................................................12 
2.6 Investigation Derived Waste ...............................................................................................13 
2.7 Reporting .............................................................................................................................13 

List of Tables

Table 1 Sample Summary Table

List of Figures

Figure 1 Site Location Map
Figure 2 Site Map
Figure 3 Proposed Sample Location Map

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Project Contacts

Mr. Mike O’Loughlin
Furniture Distributors, Inc.
4524 South Boulevard, Suite C
Charlotte, NC 28209
704-523-3424 (office)
[e-mail]

Ms. Haley Martin, PG
Hart & Hickman, PC
2923 South Tryon Street, Suite 100
Charlotte, NC 28203
[phone] (office)
[phone] (cell)
[e-mail]

Mr. Seth Titley
Division of Waste Management – Brownfields Program
450 West Hanes Mill Road, Suite 300
Winston Salem, NC 27105
336-776-9742 (direct)
[e-mail]

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Brownfields Assessment Work Plan
George Fern Company
2310 Old Steele Creek Road
Charlotte, North Carolina
Brownfields Project No. 25044-21-060
H&H Job No. FDI-001

1.0 Introduction

On behalf of Furniture Distributors, Inc (Prospective Developer or PD), Hart & Hickman, PC
(H&H) has prepared this Brownfields Assessment Work Plan (Work Plan) for the George Fern
Company Brownfields property (Brownfields Project No. [BPN] 25044-21-060) located at 2310
Old Steele Creek Road in Charlotte, Mecklenburg County, North Carolina (Site). A Site location
map is provided as Figure 1, and the Site and surrounding area are shown on Figure 2.

The Site consists of one parcel (Mecklenburg County Parcel Identification No. 11710302) that
totals approximately 9.6 acres of land. The Site is improved with one approximate 60,000 square
feet (sq ft) industrial warehouse building that is currently occupied by Kimbrell’s Furniture. The
Site building was previously occupied by a trade show and rental company for conference and
exhibition equipment. A small communications facility operated by a third-party
communications company is located in the north-central portion of the Site and is enclosed
within a chain-link security fence. The remaining portions of the Site consist of asphalt-paved
vehicle access and parking areas, concrete loading areas, and landscaped and vegetated areas.

To address environmental concerns associated with on-Site impacts attributable to historical off-
Site operations, the Site was entered into the North Carolina Department of Environmental
Quality (DEQ) Brownfields Program and received eligibility in a letter dated November 22,
2021.

1.1 Background Information

As early as 1938, the Site consisted predominately of undeveloped land used for agricultural
purposes (e.g., hay fields, pastures, row crops, etc.) and wooded areas. By the early 1950s,
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agricultural areas at the Site transitioned to undeveloped wooded land and remained undeveloped
until the mid-1960s, when the northern portion of the Site was partially cleared and graded. By
the mid-1990s, a small communications facility was constructed in the north-central portion of
the Site. The current Site building was constructed in the southern portion of the Site in 2004.
From 2004 to 2020, the Site was occupied by the George Fern Company for rental of trade show,
convention, and exhibition equipment.

1.2 Previous Assessment Activities

To obtain additional information, H&H reviewed several environmental reports prepared to
document previous environmental assessment completed at the Site and nearby off-Site facilities.
A brief summary of information provided in the environmental reports is provided below.

Dupont Charlotte Transportation Terminal
According to information provided in environmental documents, DuPont began leasing the
northern adjoining property (2246 Old Steele Creek Road) in October 1955 and used the
property for temporary storage of old equipment for resale at auction. Additional development at
the former DuPont facility (office and support building construction, rail spur replacement, UST
installation and closure) occurred in several phases between 1955 and 1997. Operations in the
mid to late 1990s involved unloading hydrogen peroxide from railroad cars into aboveground
storage tanks (ASTs), blending raw hydrogen peroxide with water, testing the hydrogen peroxide
with chemicals (i.e., sulfuric acid and potassium permanganate), and loading mixed product into
truck trailers for delivery. Limited storage and mixing of dyes were also conducted at the
facility. DuPont ceased operations at the facility and vacated the property in 1998.

During assessment activities completed at the former DuPont facility in the 1990s, several
chlorinated solvents including the volatile organic compounds (VOCs) tetrachloroethylene
(PCE) and trichloroethene (TCE) were detected in groundwater at concentrations above the
North Carolina Administrative Code (NCAC) 15A 2L Groundwater Standards (2L Standards).
In 2006, the facility was referred to the DEQ Inactive Hazardous Sites Branch (IHSB) for
additional investigation.
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DuPont subsequently entered into an Administrative Agreement (AA) with DEQ for voluntary
assessment and remediation in accordance with the IHSB Registered Environmental Consultant
(REC) program. In the AA, the former DuPont facility is identified as the DuPont Charlotte
Transportation Terminal (IHSB Project No. NCD981861214). Extensive soil and groundwater
assessment activities conducted at the former DuPont facility as part of the REC program
activities indicate the presence of several chlorinated solvents including PCE, TCE, cis-1,2-
dichlorothene (cis-1,2-DCE), and vinyl chloride at low concentrations in groundwater at the
former DuPont facility located on the northern adjoining property (2300 Old Steele Creek Road),
and the subject Site (George E. Fern facility).

During remedial investigation activities completed in 2012, groundwater monitoring wells were
installed on the subject Site (see Figure 2) and downgradient of the subject Site along Primrose
Avenue to further evaluate the extent of the chlorinated solvents in groundwater downgradient of
the former DuPont facility. The 2012 remedial investigation also included collecting
groundwater samples from monitoring wells located upgradient and downgradient of the former
Dupont facility for compound specific isotope analysis (CSIA). Results of the CSIA indicated
several potential and documented sources of PCE and TCE present in the area including a source
at the former DuPont facility, a drycleaners property which is managed through the DEQ
Drycleaning Solvent Cleanup Act (DSCA) Program, and a Brownfields property located to the
northwest.

The remedial investigation also indicated that there is separate source of PCE near monitoring
well OFF-MW-5 (Figure 2) which is located along the southern Site boundary and southwest of
the Site building. DEQ subsequently identified the contamination south of the Site as the
Primrose Avenue PCE Contamination release. The source of the Primrose Avenue PCE
Contamination release is unknown.

DEQ subsequently performed additional assessment of the Primrose Avenue PCE Contamination
release to verify lack of impact to potential receptors from vapor intrusion at the subject Site
building and residences located south of the Site. As part of additional assessment activities
performed in 2012 and 2013, DEQ performed soil gas and crawlspace sampling at residences
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located south of the Site. In 2013, DEQ also collected sub-slab soil gas samples for laboratory
analysis from one location in the southwest portion of the building in January and February
2013.

The sub-slab soil gas sample analytical results of the two samples identified PCE (up to 23
micrograms per cubic meter {µg/m3}) at concentrations well below the DEQ Non-Residential
Vapor Intrusion Sub-Slab and Exterior Soil Gas Screening Level (SGSL) of 3,500 µg/m3. Based
on results of the sampling activities completed in 2013, DEQ indicated in a letter dated March 7,
2013, that evaluation for potential structural vapor intrusion into the Site building had been
completed in accordance with DEQ guidelines and that no further vapor intrusion sampling was
warranted.

The selected remedial alternative for groundwater impacts associated with the former DuPont
facility is monitored natural attenuation (MNA). As part of the MNA remedy, DuPont (now
Chemours) collects groundwater samples from monitoring wells installed at the Site and the
northern adjacent properties. Results of recent groundwater monitoring activities performed in
May 2019 indicate PCE and TCE were detected in Site groundwater at concentrations up to 6.2
micrograms per liter (µg/L) and 32 µg/L, respectively. In general, review of the monitoring data
indicates that concentrations of compounds in the Site and adjacent property monitor wells have
decreased with time.

As noted above, the Site was entered into the DEQ Brownfields Program to address
environmental concerns associated with historical off-Site operations and received a Letter of
Eligibility on November 22, 2021. Upon eligibility into the Brownfields Program, the PD
elected to participate in the Brownfields Program Redevelopment Now option. As part of this
process, a kick-off/data gap meeting with the PD, H&H, and DEQ Brownfields personnel was
held on October 6, 2022 to discuss prior Site history, proposed redevelopment plans, data gaps,
and the proposed schedule for completing the Brownfields Agreement. H&H has prepared this
Work Plan to address DEQ Brownfields identified data gaps and requests for additional
assessment.
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The purpose of the Brownfields assessment activities described herein is to further evaluate the
potential for impacts at the Site for the protection of Site workers. The Brownfields assessment
activities discussed in the following sections focus on collection of soil, groundwater, and sub-
slab soil gas samples. In addition to the sampling activities, a receptor survey will be conducted
to obtain current information associated with land use, potable water supply, and potential
sensitive receptors in the area surrounding the Site.

A summary of the proposed Brownfields assessment activities is provided below.
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2.0 Brownfields Assessment Activities

The Brownfields assessment activities will be conducted in general accordance with the DEQ
IHSB Guidelines for Assessment and Cleanup of Contaminated Sites (Guidelines) dated
September 2022, the DEQ Division of Waste Management (DWM) Vapor Intrusion Guidance
(VI Guidance) dated March 2018, most recent versions of the U.S. Environmental Protection
Agency (EPA) Region IV Laboratory Services and Applied Science Division (LSASD)
guidance, and the enclosed DEQ Brownfields Program Minimum Requirements Checklist for Site
Assessment dated February 2022.

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

2.1 Receptor Survey

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

H&H will conduct soil sampling as part of the Brownfields assessment activities. The purpose
of the soil sampling is to evaluate potential risks to Site workers from the soil direct exposure
pathway in unpaved areas of the Site. H&H will collect two (2) composite soil samples from ten
(10) shallow soil borings advanced in unpaved and landscaped areas of the Site. In addition,
H&H will collect four (4) soil samples from two (2) soil borings advanced in the gravel parking
area located west of the existing Site building. The locations of the proposed soil borings are
shown in Figure 2. A tabular summary of proposed soil sample depths, objectives, and
laboratory analysis are summarized in Table 1. A description of the soil sampling activities for
each evaluation area is provided below.

Gravel Parking Area
H&H will advance two (2) soil borings (BF-SB-01 and BF-SB-02) to approximately 5 ft bgs in
the gravel covered parking area located west of the existing Site building. During boring
advancement, continuous soil samples will be collected and logged for lithological description.
The soil samples will be observed for obvious indication of staining and unusual odors, and field
screened for the presence of volatile organic vapors using a calibrated photoionization detector
(PID). Based upon field observations, one soil sample will be collected for laboratory analysis
from a shallow (i.e., no greater than 2 ft bgs) depth interval from each boring. Based on field
observations, a second sample will be collected from a deeper depth interval (i.e., greater than 2
ft bgs) exhibiting the highest potential for impacts for a total of two (2) samples from each soil
boring.

The soil samples selected for laboratory analysis will be placed in dedicated laboratory supplied
sample containers, labeled with the sample identification, date, and requested analysis, and
placed in a laboratory supplied cooler with ice. The samples will be delivered to a North
Carolina certified laboratory under standard chain of custody protocols for laboratory analysis of
VOCs by EPA Method 8260, semi-VOCs (SVOCs) by EPA Method 8270, Resource
Conservation and Recovery Act (RCRA) metals by EPA Methods 6020/7471, and hexavalent
chromium by EPA Method 7199.
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Composite Soil Samples
H&H will advance ten (10) soil borings for collection of composite soil samples representative
of shallow soil in landscaped areas at the Site (COMP-1 and COMP-2). Aliquot soil borings will
be advanced to approximately 5 ft below ground surface (bgs) using a decontaminated stainless-
steel hand auger. During boring advancement, continuous soil samples will be collected from
each boring and described for lithologic purposes. The soil samples will be observed for obvious
indication of staining and unusual odors, and field screened for the presence of volatile organic
vapors using a calibrated PID.

Remaining portions of the aliquot soil samples that were not used for field screening will be
combined and homogenized to form a composite soil sample for a total of two (2) composite soil
samples. The soil samples selected for laboratory analysis will be placed in dedicated laboratory
supplied sample containers, labeled with the sample identification, date, and requested analysis,
and placed in a laboratory supplied cooler with ice. The samples will be delivered to a North
Carolina certified laboratory under standard chain of custody protocols for laboratory analysis of
SVOCs by EPA Method 8270, RCRA metals by EPA Methods 6020/7471, and hexavalent
chromium by EPA Method 7199. In addition, one grab sample will be collected from an
undisturbed portion of an aliquot soil sample collected in each evaluation area for a total of two
(2) grab samples that will be submitted for analysis of VOCs by EPA Method 8260.

In addition to the soil samples described above, H&H will also collect two background soil
samples at the Site (BF-BG-1 and BF-BG-2) to establish Site-specific levels for naturally
occurring metals. The soil samples will be collected from the northern and western portions of
the Site in areas that appear to be undisturbed by historical uses. The samples will be collected
from a depth interval representative of other samples collected at Site and submitted for
laboratory analysis of RCRA metals by EPA Methods 6020/7471 and hexavalent chromium by
EPA Method 7199.

Following sampling activities, the soil borings will be properly abandoned, and the surfaces will
be repaired. Additionally, the soil sample locations will be estimated using a hand-held global
positioning system (GPS) unit.
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2.3 Groundwater Sampling Activities

H&H will collect groundwater samples from six (6) existing permanent groundwater monitoring
wells (OFF-MW-1, OFF-MW-5, OFF-MW-6, OFF-MW-7, OFF-MW-8, and MW-11S) located
at the Site to evaluate current subsurface conditions for potential impacts associated with nearby
off-Site operations. The locations of the monitoring wells are shown in Figure 3.

Groundwater samples will be collected utilizing low flow/low stress purging techniques using a
peristaltic pump or bladder pump and dedicated polyethylene tubing. The intake point of the
pump tubing will be placed in the approximate mid-portion of the screened interval of the well,
and groundwater will be removed at a rate no greater than 200 milliliters per minute (mL/min).
H&H will utilize a calibrated 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. Purging will be considered complete when the
field parameters stabilize (pH ± 0.1 Standard Units [SU], conductivity varies no more than 5%,
and turbidity is less than 10 Nephelometric Turbidity Units [NTUs]). If turbidity of less than 10
NTUs cannot be achieved, H&H will filter the groundwater sample in the field using a 0.45-
micron filter and submit an unfiltered and filtered groundwater sample for laboratory analysis to
evaluate concentrations of dissolved metals in Site groundwater (see below for groundwater
sample analyses).

Once groundwater parameters stabilize, groundwater samples for VOC analysis will be collected
directly into laboratory supplied sample containers using the “soda straw” method to reduce the
potential for volatile compound loss through the pump head. Samples collected for the
remaining analyses will be collected directly into laboratory supplied sample containers from the
dedicated sample tubing discharge. The sample containers will be labeled with the sample
identification, date, time, and requested analysis, and placed in a laboratory supplied cooler with
ice. The groundwater samples will be delivered to a North Carolina certified laboratory under
standard chain of custody protocols for analyses of VOCs by EPA Method 8260, SVOCs by
EPA Method 8270, and RCRA metals by EPA Method 6020/7470.
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2.4 Sub-Slab Soil Gas Sampling Activities

H&H will install and sample twelve (12) temporary sub-slab soil gas sampling points (BF-SSV-1
through BF-SSV-12) within the existing Site building to evaluate current conditions beneath the
slab and the potential for vapor intrusion at unacceptable levels. The proposed sub-slab soil gas
sampling point locations are shown in Figure 3, and the sampling activities are described below.

The sampling points will be installed using a rotary hammer drill and a 1½-inch diameter drill bit
to advance a pilot hole into the concrete slab to a depth of approximately 1¾ inches below the
surface. A drill guide will then be placed in the pilot hole, and a 5/8-inch diameter drill bit will
be utilized to advance the boring through the concrete slab. Following concrete borehole
advancement, loose concrete cuttings will be removed from each boring, and a Cox-Colvin
Vapor Pin™ (vapor pin) assembly (brass sampling point and silicone sleeve) will be seated in the
borehole using an installation/extraction tool and hammer to form an airtight seal.

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

The shut-in test will be conducted by connecting the flow regulator with the vacuum gauge to the
Summa® canister and sealing the flow regulator with the laboratory-provided brass cap. Once
the sampling train is “closed”, the sample valve on the Summa® canister will be opened and the
reading on the vacuum gauge will be recorded. The Summa® canister sample valve will then be
closed, and the vacuum gauge will be observed to ensure no vacuum loss occurs. If the vacuum
reading remains the same, the shut-in test will be considered successful. If vacuum loss occurs,
the flow regulator, flow regulator fittings, and/or brass cap will be reseated and the shut-in test
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will be repeated until the vacuum reading remains stable. Summa® canisters that have greater
than 10% vacuum loss upon receipt from the laboratory will not be used and a replacement
Summa® canister will be obtained prior to sampling activities.

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

Following successful leak checks, the valve on the flow regulator will be fully opened to allow
collection of the sub-slab soil gas samples. Vacuum readings on the Summa® canister will be
recorded prior to and following the sampling period to ensure adequate sample volume was
collected. A vacuum of approximately 5 inches of mercury or more will be maintained within
the canisters at the conclusion of the sampling event in accordance with DEQ DWM guidance.
Following sample collection, the Summa® canisters will be shipped to a certified laboratory
under standard chain of custody protocols for analysis of VOCs by EPA Method TO-15
including naphthalene. The laboratory will be requested to use reporting limits that are below
DEQ Non-Residential Vapor Intrusion Soil Gas Screening Levels (SGSLs).

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

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

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

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

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

2.6 Investigation Derived Waste

Investigation derived waste (IDW) generated during the proposed assessment activities will be
managed in general accordance with DEQ IHSB Guidelines and will be thin spread on-Site.
However, if significant impacts are suspected (i.e., free-product) the soil cuttings will be
containerized in labeled 55-gallon drums and staged on-Site pending analytical results of a
composite IDW sample. Based on laboratory analytical results of IDW samples, the drums will
be transported off-Site to a suitable facility for disposal.

2.7 Reporting

Following completion of the assessment activities and receipt of the analytical data, H&H will
document our findings in a Brownfields Assessment Report. The report will include a
description of field activities, field screening results, a tabular summary of the analytical results
in comparison to the PSRGs, risk calculations, boring logs (will include boring IDs, field
screening/PID results, and lithologic descriptions), sub-slab soil gas and groundwater sampling
forms, figures depicting the sample locations, a shallow groundwater potentiometric map,
laboratory analytical reports and chain of custody records, a discussion of QA/QC data, and
conclusions based upon our assessment activities. The report will be sealed by a North Carolina
Professional Engineer (PE), or Professional Geologist (PG) and the firm PE/PG numbers will be
provided.
Table 1Sample Summary TableGeorge Fern CompanyCharlotte, North Carolina Brownfields Project No. 25044-21-060H&H Project No. FDI-001COMP-1COMP-20-2 2varies 2BF-BG-1 and BF-BG-2Establish Site-Specific Background Levels for Metalsvaries 2RCRA metals plus hexavalent chromium (6020/7471/7199)OFF-MW-1, OFF-MW-5, OFF-MW-6, OFF-MW-7, OFF-MW-8, and MW-11SGroundwater Evaluate Groundwater Conditions 25 10 to 25 6VOCs (8260), SVOCs (8270), and RCRA metals (6020/7470)BF-SSV-1 through BF-SSV-12 Soil Gas Evaluate Potential VI Risks 12 VOCs (TO-15)BF-SB-DUP Soil5 varies 1VOCs (8260), SVOCs (8270), and RCRA metals plus hexavalent chromium (6020/7471/6199)GW-DUP Groundwater 25 10 to 25 1VOCs (8260), SVOCs (8270), and RCRA metals (6020/7470)BF-SSV-DUP Soil Gas1 VOCs (TO-15)Trip Blank Trip Blank NA NA 1 VOCs (8260)Notes:EPA method number follows the laboratory parameter in parenthesis. VOCs = Volatile Organic Compounds; SVOCs = Semi-Volatile Organic Compounds; RCRA = Resource Conservation Recovery Actft = Feet; QA/QC = Quality Assurance/ Quality Control; VI = Vapor Intrusion; NA = Not ApplicableSoil5Laboratory AnalysisSample ObjectiveSample TypeApproximate Sample Depth (ft)Grab Samples - VOCs (8260), Composite Samples - SVOCs (8270) and RCRA metals plus hexavalent chromium (6020/7471/7199)2variesEvaluate Soil Conditions VOCs (8260), SVOCs (8270), and RCRA metals plus hexavalent chromium (6020/7471/7199)QA/QCSample IDsApproximate Boring Depth (ft)Number of Samplesbelow the slab below the slab BF-SB-01 and BF-SB-02https://harthick.sharepoint.com/sites/MasterFiles‐1/Shared Documents/AAA‐Master Projects/Furniture Distributors, Inc. (FDI)/FDI‐001/Brownfields/BF Assessment/Work Plan/Sample Summary TableTable 1 (Page 1 of 1)Hart & Hickman, PC
USGS The National Map: National Boundaries Dataset, 3DEP ElevationProgram, Geographic Names Information System, National HydrographyDataset, National Land Cover Database, National Structures Dataset, andNational Transportation Dataset; USGS Global Ecosystems; U.S. CensusBureau TIGER/Line data; USFS Road Data; Natural Earth Data; U.S.Department of State Humanitarian Information Unit; and NOAA NationalCenters for Environmental Information, U.S. Coastal Relief Model. Datarefreshed June, 2022.
SITE LOCATION MAP
GEORGE FERN COMPANY2310 OLD STEELE CREEK ROADCHARLOTTE, NORTH CAROLINA
DATE: 10-24-22
JOB NO: FDI-001
REVISION NO: 1
FIGURE NO: 1
2923 South Tryon Street - Suite 100Charlotte, North Carolina 28203704-586-0007 (p) 704-586-0373 (f)License # C-1269 / # C-245 Geology
TITLE
PROJECT
0 2,000 4,000
SCALE IN FEET
SITE
Path: S:\AAA-Master Projects\Furniture Distributors, Inc. (FDI)\FDI-001\Phase I ESA\Figures\Figure-1.mxdN
U.S.G.S. QUADRANGLE MAP
CHARLOTTE WEST, NORTH CAROLINA 2019
QUADRANGLE7.5 MINUTE SERIES (TOPOGRAPHIC)
OLD STEELE CREEK ROADOFF-MW-3
OFF-MW-8
MW-15D
MW-14D
MW-10S
OFF-MW-4
MW-13D
MW-10D
MW-12D
OFF-MW-9D
BMW-1
MW-1
MW-2
MW-13S
MW-12S
OFF-MW-9S
MW-11D
PRI
M
R
O
S
E

A
V
E
N
U
E
WIL
L
O
W

S
T
R
E
E
T
FABER STREETOFFICE
TOLLESON + SAUL DESIGN
(2300 OLD STEEL CREEK ROAD)
CAROLINA GOLF CLUB
(2415 OLD STEELE CREEK ROAD)
PATRIOT TRANSPORT, INC.
(22466 OLD STEELE CREEK ROAD)
WOODED LAND/
RESIDENCES
VACANT LAND
(3600 PRIMROSE AVENUE)
MW-3R
MW-4
TELECOMMUNICATIONS
COMPOUND WITH GENERATOR
STORMWATER DETENTION POND
REVISION NO. 0
LEGEND
BROWNFIELDS PROPERTY BOUNDARY
PARCEL LINE
RAILROAD
SHALLOW MONITORING WELL
DEEP MONITORING WELL
BEDROCK MONITORING WELL
ABANDONED SHALLOW MONITORING WELL
NOTES:
1.AERIAL IMAGERY OBTAINED FROM MECKLENBURG
COUNTY GIS, DATED 2019.
2.BASE DATA OBTAINED FROM MECKLENBURG COUNTY
GIS (2021).
3.MONITORING WELLS MW-1 THROUGH MW-4 INSTALLED
BY ERM IN 1997.
4.MONITORING WELLS OFF-MW-1 THROUGH OFF-MW-3
INSTALLED BY S&ME, INC. IN 2005. MONITORING WELLS
OFF-MW-4 THROUGH OFF-MW-6 INSTALLED BY PARSONS
IN 2008. MONITORING WELLS OFF-MW-7 THROUGH
OFF-MW-9D WERE INSTALLED IN 2010.
5.MONITORING WELLS MW-10S/D AND MW-11S/D WERE
INSTALLED IN 2012.
6.MONITORING WELLS MW-12S/D, MW-13S/D, MW-14D, AND
MW-15D WERE INSTALLED IN 2011.
JOB NO. FDI-001
DATE: 12-16-22
FIGURE NO. 2
SITE MAP
2923 South Tryon Street-Suite 100
Charlotte, North Carolina 28203
704-586-0007(p) 704-586-0373(f)
License # C-1269 / #C-245 Geology
GEORGE FERN COMPANY
2310 OLD STEELE CREEK ROAD
CHARLOTTE, NORTH CAROLINA
OFF-MW-6
OFF-MW-5
MW-11S
OFF-MW-7
OFF-MW-1
S:\AAA-Master Projects\Furniture Distributors, Inc. (FDI)\FDI-001\Brownfields\BF Assessment\Work Plan\Figures\Figures 20210510.dwg, FIG2, 12/16/2022 11:02:59 AM, tmarbuery
OLD STEELE CREEK ROADOFF-MW-8
MW-15D
MW-14D
MW-10S
OFF-MW-4
MW-13D
MW-10D
MW-12D
OFF-MW-9D
BMW-1
MW-1
MW-2
MW-13S
MW-12S
OFF-MW-9S
MW-11D
PRI
M
R
O
S
E

A
V
E
N
U
E
WIL
L
O
W

S
T
R
E
E
T
FABER STREETTOLLESON + SAUL DESIGN
(2300 OLD STEEL CREEK ROAD)
CAROLINA GOLF CLUB
(2415 OLD STEELE CREEK ROAD)
PATRIOT TRANSPORT, INC.
(22466 OLD STEELE CREEK ROAD)
WOODED LAND/
RESIDENCES
VACANT LAND
(3600 PRIMROSE AVENUE)
MW-3R
MW-4
TELECOMMUNICATIONS
COMPOUND WITH GENERATOR
STORMWATER DETENTION POND
REVISION NO. 0
LEGEND
BROWNFIELDS PROPERTY BOUNDARY
PARCEL LINE
RAILROAD
EXISTING MONITORING WELL
PROPOSED SUB-SLAB VAPOR POINT
PROPOSED SOIL BORING
PROPOSED ALIQUOT SOIL BORING
NOTES:
1. AERIAL IMAGERY OBTAINED FROM MECKLENBURG
COUNTY GIS, DATED 2019.
2. BASE DATA OBTAINED FROM MECKLENBURG COUNTY
GIS (2021).
3. MONITORING WELLS MW-1 THROUGH MW-4 INSTALLED
BY ERM IN 1997.
4. MONITORING WELLS OFF-MW-1 INSTALLED BY S&ME, INC.
IN 2005. MONITORING WELLS OFF-MW-5 THROUGH
OFF-MW-6 INSTALLED BY PARSONS IN 2008. MONITORING
WELLS OFF-MW-7 WERE INSTALLED IN 2010.
OFF-MW-6
OFF-MW-5
OFF-MW-7
JOB NO. FDI-001
DATE: 12-16-22
FIGURE NO. 3
GEORGE FERN COMPANY
2310 OLD STEELE CREEK ROAD
CHARLOTTE, NORTH CAROLINA
MW-11S
OFF-MW-1
PROPOSED SAMPLE LOCATION MAP
2923 South Tryon Street-Suite 100
Charlotte, North Carolina 28203
704-586-0007(p) 704-586-0373(f)
License # C-1269 / #C-245 Geology
BF-SSV-1
BF-SSV-3
BF-BG-1
BF-BG-2
COMP-1
COMP-2
BF-SSV-4
BF-SSV-7
BF-SSV-12
BF-SSV-2
BF-SSV-5
BF-SSV-8
BF-SSV-11BF-SSV-6
BF-SSV-9
BF-SSV-10
BF-SB-01
BF-SB-02 OFFICE
S:\AAA-Master Projects\Furniture Distributors, Inc. (FDI)\FDI-001\Brownfields\BF Assessment\Work Plan\Figures\Figures 20210510.dwg, FIG3, 12/16/2022 10:12:52 AM, tmarbuery