20058_Southern_Loop Soil Workplan 2016_09_01

Via Email

September 1, 2016

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

Attn: Ms. Carolyn Minnich

Re: Work Plan
Soil Assessment – Former PARA USA LLC Facility
10620 Southern Loop Blvd.
Pineville, North Carolina
H&H Job No. SOL-001

Dear Carolyn:

1.0 Introduction

On behalf of Southern Loop, LLC, Hart & Hickman, PC (H&H) is submitting this work plan for
soil assessment activities at the property located at 10620 Southern Loop Boulevard in Pineville,
NC (the Site). The Site is comprised of one approximately 1.71 acre parcel and contains an
approximately 27,000 sq ft building.

In May 2016, H&H completed groundwater assessment activities on both the 10620 and 10710
Southern Loop Blvd. properties to evaluate the potential for groundwater impacts on the Site from
the adjacent former Universal Stainless facility. Additionally, indoor air samples were collected
to evaluate the potential for vapor intrusion into the buildings from groundwater impacts. Results
of the assessment activities indicated that tetrachloroethene (PCE) and trichloroethene (TCE) were
detected in groundwater at concentrations exceeding groundwater standards in samples collected
on the 10710 Southern Loop parcel, but not on the 10620 Southern Loop parcel. Additionally,
there does not appear to be a vapor intrusion concern for either building based on indoor air
Ms. Carolyn Minnich
September 1, 2016
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assessment results. The May 2016 assessment results are documented in our Groundwater and
Indoor Air Assessment Report dated June 9, 2016.

Based on results of the May 2016 assessment activities, Southern Loop LLC submitted a
Brownfields Property Application for the 10620 and 10710 Southern Loop properties to obtain
eligibility into the Brownfields Program. The Brownfields Program issued a Letter of Response
dated August 22, 2016 indicating that Site was not eligible for entry into the Brownfields Program
at this time because of concerns associated with the previous tenant PARA USA LLC which
manufactured guns at the property during Southern Loop’s ownership. According to the Letter of
Response, DEQ requested additional assessment activities on the 10620 Southern Loop parcel to
establish that the previous tenant PARA USA LLC did not contribute to contamination at the Site.

Based on information provided in the Letter of Response and our subsequent conversations, H&H
proposes to conduct soil assessment activities in five areas of concern to assess the potential for
impact to the Site. The scope of work for proposed soil assessment activities is outlined in the
following sections.

2.0 Soil Assessment Scope of Work

Prior to boring advancement, H&H will contact the public utility locator to mark public
underground utilities at the Site. H&H will also contract with a private utility locator to screen the
boring locations for potential private subsurface utilities.

H&H proposes to advance one soil boring in the approximate locations of each of the following
areas of concern identified in the Brownfields Letter of Response:
 hazardous waste storage area
 blast booth room
 sonic bath area
 fire test range area
Ms. Carolyn Minnich
September 1, 2016
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 paint booth area

The borings will be advanced through a cored concrete hole to depths of approximately 5 ft below
ground surface using a decontaminated stainless steel hand auger. During boring advancement,
continuous soil samples will be collected from the center of the hand auger bucket. Soil samples
will be inspected for the presence of visual indications of impact and screened for the presence of
volatile organic vapors with a calibrated photoionization detector (PID). Based upon field
screening, one soil sample will be collected from each boring for laboratory analysis. If no obvious
indication of impacts are identified during fields screening, a sample will be collected from shallow
soils just beneath the slab of the building. Following completion of the soil sampling, the borings
will be grouted and the surface pavement in each area will be patched with cement.

The soil samples will be submitted to a North Carolina certified laboratory for analysis of volatile
organic compounds (VOCs) by EPA Method 8260 and Hazardous Site List metals (plus hexavalent
chromium) by EPA Method 6010/7471/7196.

Because metals are naturally occurring, H&H will collect two additional soil samples from areas
on the property that do not appear to be affected by previous Site use to establish Site-specific
background concentrations for metals. The background soil samples will be collected from
shallow borings advanced with a decontaminated stainless steel hand auger and submitted for
laboratory analysis of Hazardous Site List metals by EPA Method 6010/7471.

Investigation derived waste (IDW) generated during the assessment activities will be thin spread
on-Site. However, if significant impacts are suspected (i.e., free product), the soil cuttings will be
containerized in 55-gallon drums and staged on-Site pending analytical results of a composite IDW
sample.
4.0 Reporting

Ms. Carolyn Minnich
September 1, 2016
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Following completion of the proposed assessment activities and receipt of the analytical data,
H&H will document our findings in a brief letter report. The report will include a description of
the sampling activities, a figure depicting sample locations, soil boring logs, a discussion of the
data in comparison to regulatory screening levels, laboratory analytical data, and conclusions and
recommendations concerning our activities.

We are scheduled to conduct these proposed assessment activities on September 7, 2016. It would
be very much appreciated if we could have your response to this work plan prior to conducting the
field activities.

Please contact us if you have any questions or if you require additional information.

Very truly yours,

Hart & Hickman, PC
Ralph McGee, PG Steven C. Hart, PG
Project Geologist Principal Hydrogeologist

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