13001_ Kolortex WP& approval 20130909

1646 Mail Service Center, Raleigh, North Carolina 27699-1646
Phone: [phone] \ Internet: http://portal.ncdenr.org/web/wm
An Equal Opportunity \ Affirmative Action Employer – 50% Recycled \ 10% Post Consumer Paper

North Carolina Department of Environment and Natural Resources
Division of Waste Management
Pat McCrory Dexter R. Matthews
Governor Director
John E. Skvarla, III
Secretary

September 26, 2013

Sent Via E-mail

Bryan Hartnett
Carolina Realty Holding, LLC
2634 Idlewood Circle
Charlotte, NC 28209
[e-mail]

Subject: Work Plan Approval
Kolortex Facility
2810, 2900, 2910 Horseshoe Lane
Charlotte, Mecklenburg County
Brownfields Project Number 13011-09-60

Dear Mr. Hartnett:

The North Carolina Brownfields Program, (NCBP) has received and reviewed the
Brownfields Assessment Work Plan dated September 24, 2013 prepared by Hart & Hickman.
The work plan was based on the request for additional assessment letter dated September 14,
2009. NCBP approves the work plan.

Be advised that this approval from the Brownfields Program does not waive any
applicable requirement to obtain any necessary permits, licenses or certifications for the above
listed activities nor does it waive any requirement to comply with applicable law for such
activities. If you have any questions or comments, please contact me at 704/661-0330.

Sincerely,

Carolyn Minnich
Carolyn Minnich
Brownfields Project Manager
Division of Waste Management

ec: Bruce Nicholson, NCDENR
Steve Hart, Hart & Hickman, [e-mail]

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Brownfields Assessment Work Plan
Kolortex Site

2900 Horseshoe Ln.
Charlotte, North Carolina
Brownfields Project ID 13011-09-60

September 9, 2013
H&H Job No. CRH-001

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Brownfields Assessment Work Plan
Kolortex Site
2900 Horseshoe Ln.
Charlotte, North Carolina
H&H Job CRH-001

Table of Contents

Section Page No.

1.0 Introduction and Background ........................................................................................... 1 
1.1 Brief Site History .................................................................................................................. 1 
1.2 Previous Assessment and Remedial Activities ..................................................................... 1 

2.0 Scope of Work ..................................................................................................................... 5 
2.1 Groundwater Assessment ..................................................................................................... 5 
2.2 Subslab Soil Vapor Assessment ........................................................................................... 6 
2.3 Indoor Air Sampling (if warranted) ...................................................................................... 7 
2.4 Reporting .............................................................................................................................. 9 

Figures
Figure 1 Site Location Map
Figure 2 Site Plan and Proposed Sample Locations

Appendices

Appendix A Post-Excavation Stormwater Outfall Soil Sample Data

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Brownfields Assessment Work Plan
Kolortex Site
2900 Horseshoe Ln.
Charlotte, North Carolina
H&H Job CRH-001

1.0 Introduction and Background

Hart & Hickman, PC (H&H) has prepared this Brownfields Assessment Work Plan for the
former Kolortex Brownfields site located at 2900 Horseshoe Ln. in Charlotte, North Carolina. A
site location map is provided as Figure 1. The subject property contains approximately 11 acres
that are improved with an approximate 110,000-sq ft office and warehouse building, associated
asphalt parking areas, and a former concrete wastewater basin. The primary site building was
constructed in 1978.

1.1 Brief Site History

Kolortex/Callaghan Textiles operated at the site from 1978 until 1996 and conducted textile
dyeing and finishing. The facility was vacant until 1998 when it was leased to Vibrachem.
Vibrachem conducted cleaning of metal parts using vibration, cleaning solutions, and ceramic
media. Vibrachem leased the property until August 2003 when it vacated the property due to
breach of lease. The facility has been used for limited warehousing and distribution operations
since that time.

1.2 Previous Assessment and Remedial Activities

In October 2004, the North Carolina Department of Environment and Natural Resources
(DENR) Hazardous Waste Section conducted an inspection at the facility and identified
approximately 75 abandoned containers stored on the property. The containers had been
abandoned by the former site tenant Vibrachem. In 2003, the then property owner Salvista
Trading, LLC terminated Vibrachem’s lease agreement due to breach of the lease agreement.

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In a letter dated October 13, 2004, DENR issued a Notice of Violation (NOV) to Salvista
Trading requiring that the containers be removed, sludge from the concrete wastewater basin be
removed, and a site assessment be conducted. In August 2005, LandAmerica Assessment
Corporation and A&W Professional Services, PLLC (collectively LAC/A&W) conducted
sampling activities at potential areas of concern in response to the DENR NOV. LAC/A&W
collected 12 samples from the following five areas of concern (these areas are referenced in
Figure 2):
 Drum Storage Area #1;
 Drum Storage Area #2;
 Near a stormwater catch basin in the eastern portion of the site;
 Near the outfall of a stormwater pipe in southeastern portion of the site; and
 The concrete temporary wastewater holding basin.

Seven soil samples were collected from Drum Storage Area #1, two soil samples were collected
in Drum Storage Area #2, two soil samples were collected at the Eastern Stormwater Catch
Basin, and one soil sample was collected at the Stormwater Outfall. In addition, LAC/A&W
collected a water sample and solid sample from the concrete temporary wastewater holding
basin. Of the 12 soil samples submitted for laboratory analysis, seven soil samples contained
concentrations of oil and grease (O&G) above the DENR Underground Storage Tank (UST)
Section cleanup level at the time of 250 mg/kg. The concentrations above the DENR screening
level ranged from 360 mg/kg to 28,000 mg/kg. Five of the elevated O&G samples were
collected from Drum Storage Area #1, and the remaining two were collected from Drum Storage
Area #2 and the Eastern Stormwater Catch Basin.

The soil sample collected from the outfall of the stormwater pipe in the southeastern portion of
the site contained three polynuclear aromatic hydrocarbons (PAHs) above screening levels. In
addition, one soil sample collected from Drum Storage Area #1 contained tetrachloroethene
(PCE; 0.011 mg/kg). The laboratory results for the surface water and sludge samples did not
indicate compound concentrations above toxicity characteristic hazardous waste levels.

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In a letter dated January 19, 2006, DENR requested that Salvista Trading remove the materials
from the concrete basin and identified soil impacts from the Stormwater Outfall, Eastern
Stormwater Catch Basin, Drum Storage Area #1, and Drum Storage Area #2. A Corrective
Action Work Plan was submitted to DENR in October 2007 for these activities. However, the
work plan activities were never implemented by Salvista Trading. In 2008, the current property
owner Carolina Realty Holdings (CRH) obtained title to the property by foreclosure of a security
interest it held. Because CRH obtained the property through foreclosure, it is not considered a
responsible party with regard to the RCRA activities.

Although CRH did not have responsibility for cleanup of the identified impacts, in February and
March 2009, CRH requested that H&H remove soil in the areas of concern and clean out the
concrete basin. A total of approximately 431 tons of impacted soil was removed from the
Stormwater Outfall, Eastern Stormwater Catch Basin, Drum Storage Area #1, and Drum Storage
Area #2. Analytical results of post-excavation confirmation samples indicated that soil impacts
in these areas have been adequately removed except for the presence of PAHs in the area of the
stormwater outfall. A summary of post-excavation sampling in the stormwater outfall area is
provided in Appendix A. In addition, H&H removed the water and sludge from the concrete
basin, pressure washed the basin, and disposed of the water and sludge off-site.

In April 2009, to assess the potential for impact from the former use of the site for textile dyeing,
H&H collected soil samples from six borings in the area of several covered trenches in the
building. The locations of the soil borings, labeled HA-7 through HA-12, are depicted in Figure
2. Results of analysis of the soil samples indicated the presence of tetrachloroethene (PCE) and
its daughter products in soil samples below the site building. The detected PCE concentrations
exceeded DENR soil to ground water leaching screening levels but did not exceed residential or
industrial direct contact preliminary soil remediation goals (SRGs). A summary of the analytical
results of soil samples collected from below the building is provided as Table 1.

In May 2009, CRH submitted a Brownfields Property Application for the site, and DENR issued
a Letter of Eligibility for the Brownfields program in July 2009. In a letter dated September 14,

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2009, DENR requested additional assessment as part of the Brownfields process. Specifically,
DENR requested groundwater sampling and sub-slab soil vapor sampling. The following section
provides a work plan for the additional assessment activities.

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2.0 Scope of Work
2.1 Groundwater Assessment

H&H proposes to install two downgradient temporary monitor wells at the site. The
approximate locations of the temporary monitor wells are provided in Figure 2. One will be
located on the east side of the building and the other will be located on the south side of the
building. Prior to drilling, the public utility locator will be contacted and we will also contract a
private utility locator to screen the boring locations for potential subsurface utilities. The
temporary wells will be installed with a direct push technology (DPT) rig. We have assumed
that the wells will be approximately 35 ft deep, and we will encounter groundwater before DPT
refusal at bedrock.

Following installation and development, samples from the temporary wells will be analyzed for
volatile organic compounds (VOCs) by EPA Method 8260, semi-VOCs by EPA Method 8270,
and the hazardous substance list (HSL) metals. Field measurements of pH, conductivity,
temperature, turbidity, and dissolved oxygen will also be collected from the wells at the time of
sampling. Monitor well installation and sampling will be conducted in accordance with DENR
Inactive Hazardous Sites Branch and EPA Region 4 guidance.

Following sampling, the temporary wells will be abandoned. As required by Mecklenburg
County, a Subsurface Investigation Permit will be obtained for the wells prior to the groundwater
sampling and the temporary wells will be registered with the County after the completion of field
activities.

Water generated during the sampling event will be containerized and left on-site pending the
results of the sample analyses. The sample analyses will be used to determine an appropriate
disposition for the water. The disposition of the water will be included in the Brownfields
Assessment Report.

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2.2 Subslab Soil Vapor Assessment

To assess the potential for vapor intrusion into the site building from underlying soil and/or
groundwater impacts, H&H proposes to collect six sub-slab soil vapor samples at the site. The
proposed sub-slab soil vapor sample locations are indicated in Figure 2 and include the
following:
 One near the offices in the western portion of the building;
 Two in the northern portion of the warehouse where the dyeing activities were
conducted;
 One in the northeastern section of the warehouse; and
 Two in the southern portions of the warehouse.

At each sample location, H&H will drill through the concrete floor utilizing a concrete hammer
drill and an approximate 1.5-inch diameter bit. Through each of the drilled holes, H&H will
install an approximate 0.625-inch diameter stainless steel probe with approximate 2-inch long
bottom screen point. The probes will be installed through the gravel beneath the concrete slab
and seated in the underlying soil so that the soil gas probe screen is present in both the soil and
overlying gravel. If no gravel is present beneath the slab at a sample location, the probe will be
advanced no more than 6 inches below the bottom of the slab into soil.

After pushing the screen point to the desired depth, the stainless steel screen of the point will be
opened. Each point will then be sealed at the surface of the concrete slab using hydrated
bentonite. The soil gas probes will be completed at the surface using a sample valve and Teflon
tubing. Prior to sampling, a field leak check will be conducted at each vapor monitoring point
by constructing a shroud around the sampling point and saturating the air within the shroud with
helium gas. Using a syringe, a sample will be collected from the gas in the shroud into a Tedlar®
bag and analyzed for helium concentrations using a helium gas detector. Vapor from the vapor
monitoring point will be purged and sampled outside of the shroud into a separate Tedlar® bag

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and analyzed using the helium gas detector to ensure that helium concentrations are less than 5%
of the helium concentrations in the shroud.

Following a successful field leak check, vapor samples will be collected into six-liter Summa
canisters for laboratory analysis. The Summa canisters will be allowed to fill slowly using an
airflow regulator over a period of approximately one hour per point. During sampling at each
location, a helium tracer gas atmosphere will be maintained at the surface of each soil vapor
point to demonstrate that there was not short circuiting to the surface during the test. The helium
gas atmosphere will be created by saturating the air within the shroud at the sample location with
helium gas. To ensure a sufficient helium atmosphere was maintained during sampling, H&H
will monitor helium levels within the shroud and add helium as needed to maintain an 80 to 90%
helium atmosphere. A record of helium shroud measurements taken during the sampling
activities will be maintained.

As part of the testing, H&H will collect measurements of ambient temperature at the beginning,
middle, and end of the sampling day. Precipitation, if any, will also be noted.

Once the soil vapor samples are collected, the canisters will be shipped to a qualified laboratory
and analyzed for VOCs by EPA Method TO-15 and for helium by EPA Method 3C. For VOC
analysis, the laboratory will be asked to attain detection limits which are less than the DENR
IHSB industrial/commercial indoor air screening levels for these compounds at a lifetime
incremental cancer risk (LICR) of 1 x 10-6 for potential carcinogens and hazard index (HI) of 0.2
for non-carcinogens.

After collection, each of the points will be abandoned and the surface will be patched.

2.3 Indoor Air Sampling (if warranted)

Following collection and receipt of the subslab soil vapor sampling data, H&H will summarize
the sample data in a table and provide it to DENR for review. If subslab soil sample
concentrations are less than the DENR IHSB Commercial/Industrial screening levels, then

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indoor air sampling will not be warranted. However, if concentrations of compounds are
detected significantly above screening levels, H&H will propose to DENR the locations and
numbers of indoor air samples and the proposed analytes for review and approval.

The indoor air samples will be collected with 6-liter Summa canisters. The Summa canister will
be connected to an airflow regulator and a 3 ft long sampling cane in warehouse/open areas. The
typical height of a Summa canister with an attached airflow regulator is approximately 2 ft above
grade and, with the additional 3-foot long sampling cane, the sample intake point is
approximately 5 ft above grade (typical breathing zone height). Sample heights in office areas
will be approximately 3 ft above grade.

Prior to sample collection, H&H will measure the wind direction and select an exterior
background location which is located upgradient of the site building. The location of the
background sample will be determined the day of the sampling based upon the wind direction.
The background location Summa canister will also be fitted with a regulator and sampling cane
so that the sample height is approximately 5 ft above ground level.

Following set-up of the background sample canister, the indoor and background sample valves
will be opened and the samples will be collected over an approximate 8-hour period (the
regulator will be pre-set to collect samples over the 8-hour period). As part of the sampling
effort, H&H will measure the air pressure differential between outside air and the interior sample
locations near the start, middle, and end of the 8-hour sampling period. The pressure
measurements will be made using a manometer sensitive to 0.01 inches water. In addition,
exterior wind speed, exterior wind direction, and indoor/outdoor temperature will be recorded
near the start, middle, and end of the sampling period. Precipitation will also be noted prior to
and during the sampling event.

The samples will be analyzed by EPA Method TO-15 (for the DENR agreed upon analytes based
upon the soil vapor sampling), and the laboratory will be asked to attain detection limits which
are less than the DENR IHSB industrial/commercial indoor air screening levels for these

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compounds at a lifetime incremental cancer risk (LICR) of 1 x 10-6 for potential carcinogens and
hazard index (HI) of 0.2 for non-carcinogens.

2.4 Reporting

Following completion of the activities, H&H will prepare a report which describes the methods
and results of the sampling activities. The report will include the methods and results of the
groundwater sampling, subslab soil vapor sampling, indoor air sampling (if performed), the
locations of the samples, tabular summaries of the data in comparison to regulatory screening
levels, boring logs, laboratory analytical reports, and conclusions concerning the activities.
Table 1
Sub-Slab Soil Analytical Results
Warehouse Building
2900 Horseshoe Lane
Charlotte, NC
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Page 1 of 1 2900 Horseshoe Lane
Charlotte, NC
Hart & Hickman Job No. CRH-001
Sample Location Beneath Warehouse Building
Sample ID HA-7 HA-8 HA-9 HA-10 HA-11 HA-12
Depth Interval (ft)1.5-2 1.5-2 1-1.5 1-1.5 3-3.5 1.5-2
Collect Date 4/1/09 4/1/09 4/1/09 4/1/09 4/1/09 4/1/09VOCs by 8260 (mg/kg)
Acetone <0.052 <0.053 0.072 <0.047 0.21 <0.059 12,000 100,000
cis-1,2-Dichloroethene <0.0052 0.012 <0.0051 <0.0047 <0.0050 <0.0059 32 400
Tetrachloroethene <0.0052 0.16 0.034 0.013 0.0081 <0.0059 17 82Trichloroethene<0.0052 0.012 0.013 <0.0047 <0.0050 <0.0059 0.88 4
Notes:
Only those compounds detected in at least one sample shown above.
DENR Inactive Hazardous Sites Branch (IHSB) Preliminary Soil Remediation Goals (July 2012 version)
Depths measured from top of slab
DENR IHSB
Residential
PSRG
DENR IHSB
Industrial
PSRG
TITLE
PROJECT
SITE LOCATION MAP

2900 HORSESHOE LANE
CHARLOTTE, NORTH CAROLINA
DATE:
JOB NO:
REVISION NO:
FIGURE NO:
9-3-13

0
1 CRH-001
0 2000 4000
APPROXIMATE
SCALE IN FEET N
U.S.G.S. QUADRANGLE MAP
QUADRANGLE
7.5 MINUTE SERIES (TOPOGRAPHIC)
Charlotte West, NC 1993
SITE

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Appendix A

Post-Excavation Stormwater Outfall Soil Sample Data
Post-Excavation
Retention Basin Soil Analytical Results
2900 Horseshoe Lane
Charlotte, NC
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2900 Horseshoe Lane
Charlotte, NCHart & Hickman Job No. CRH-001
Sample Location
Sample ID NSW ESW SSW WSW Base HA-1 HA-1 HA-2 HA-2 HA-3 HA-3 HA-4 HA-4 HA-5 HA-5 HA-6
Depth Interval (ft)1 1 1 1 2.5 1-2 3-4 0-1 3-4 1-2 3-4 1-2 3-4 0-1 3-4 1-2
Collect Date 2/19/09 2/19/09 2/19/09 2/19/09 2/19/09 4/1/09 4/1/09 4/1/09 4/1/09 4/1/09 4/1/09 4/1/09 4/1/09 4/1/09 4/1/09 4/1/09PAHs by 8270 (mg/kg)
Benzo(a)anthracene 0.75 4.5 3.6 4.5 3.6 <0.42 <0.43 0.84H <0.41 3.6 1.5H <0.46 <0.46 <0.41 <0.39 10 0.15 2.1Benzo(a)pyrene 0.88 5.1 4.3 5.5 3.8 <0.42 <0.43 1.1H <0.41 5.3H 1.8H <0.46 <0.46 <0.41 <0.39 9.2H 0.015 0.21
Benzo(b)fluoranthene 1.3 8.7 7.6 10 7.0 <0.42 <0.43 2.2H <0.41 8.3H 3.6H <0.46 <0.46 <0.41 <0.39 18H 0.15 2.1Benzo(g,h,i)perylene 0.58 4.6 3.0 4.8 2.9 <0.42 <0.43 0.97H <0.41 6.7H 1.7H <0.46 <0.46 <0.41 <0.39 6.4H NS NS
Benzo(k)fluoranthene 0.63 3.3 3.1 4.1 2.9 <0.42 <0.43 0.73H <0.41 2.8H 1.2H <0.46 <0.46 <0.41 <0.39 5.1H 1.5 21Chrysene0.98 7.3 5.9 8.1 5.7 <0.42 <0.43 1.4H <0.41 5.4 2.4H <0.46 <0.46 <0.41 <0.39 13 15 210
Dibenz(a,h,)anthracene <0.29 <0.86 <0.68 <0.74 0.72 <0.42 <0.43 <0.46 <0.41 <2.3 <0.47H <0.46 <0.46 <0.41 <0.39 <4.1 0.015 0.21Fluoranthene1.7 9.5 7.2 11 7.9 <0.42 <0.43 1.6 <0.41 7.5 2.7 <0.46 <0.46 <0.41 <0.39 26 460 4,400Indeno(1,2,3-cd)pyrene 0.62 5.0 3.7 5.8 3.5 <0.42 <0.43 1.2H <0.41 7.5H 2.0 <0.46 <0.46 <0.41 <0.39 8.4H 0.15 2.1
Phenanthrene <0.29 1.8 1.4 2.4 1.9 <0.42 <0.43 <0.46 <0.41 2.7 0.54 <0.46 <0.46 <0.41 <0.39 8.7 NS NSPyrene1.6 11 9.4 14 10 <0.42 <0.43 2.5H <0.41 11 4.0H <0.46 <0.46 <0.41 <0.39 29 340 3,400
Notes:Only those compounds detected in at least one sample shown above.
DENR Inactive Hazardous Sites Branch (IHSB) Preliminary Soil Remediation Goals (July 2012) Bold and yellow highlighted indicates detection above Residential PSRG
Bold and green highlighted indicates detection above Industrial PSRG
H - Surrogate recovery outside of control limits. Matrix interference suspected. Concentration reported with a possible high biasNS - Not Specified
Depths measured from current ground surface at sample location
Post-Excavation Samples Additional Assessment Samples DENR IHSB
Residential PSRG
DENR IHSB
Industrial PSRG