20026 Kaiser Approval& WP Henkel 20180103

From:Minnich, Carolyn
To:"Matt Ingalls"
Cc:Brett Lawrence
Subject:RE: [External] FW: Kaiser Fluids Tech II (Henkel Site) Work Plan
Date:Wednesday, January 03, 2018 9:41:00 AM
Attachments:Work Plan_Kaiser Fluids Tech II cfm 20180103.pdfimage001.png
Thank you for the reminder email. The work plan is approved. However, I am concerned about the
wording in Section 2.3. The results from sub slab sampling report will be reviewed and inputted into
the current DEQ DWM Risk Calculator. Not just against IHSB Non- VISLs. DEQ Brownfields must give
final approval if additional assessment is necessary for vapor assessment. More forward with the
field work and assessment. We can discuss data review once the analytical report is available.

I also had a comment on future construction over the former Research Development Lab or former
storage building. If so, we will need to review need for vapor assessment again.

Call if you have questions or want to discuss something more.

Carolyn Minnich
Brownfields Project Manager
Division of Waste Management
Department of Environmental Quality

704 661 0330 office/mobile
[e-mail]

1646 Mail Service Center
Raleigh, NC 27699-1646

Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.

From: Matt Ingalls [mailto:[e-mail]]
Sent: Tuesday, January 02, 2018 1:31 PM
To: Minnich, Carolyn <[e-mail]>
Cc: Brett Lawrence <[e-mail]>
Subject: [External] FW: Kaiser Fluids Tech II (Henkel Site) Work Plan

CAUTION: External email. Do not click links or open attachments unless verified. Send all suspicious email as an
attachment to [e-mail].

Hi Carolyn – I hope you were able to take some time off with your family. I wanted to follow up on
the attached Work Plan that includes out scope to collect (8) subslab vapor samples, (8) concrete
floor material samples, and if needed indoor air samples within the Kaiser Bldg. Our strategy is to
Ms. Carolyn Minnich
December 13, 2017
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the 530 E. Sugar Creek Road property from 1956 until 2003. The Kaiser building was razed in
November and December 2017, while the concrete slab remains in-place. Henkel previously
manufactured, stored, and distributed textile chemicals at the 600 E. Sugar Creek Road property
from 1953 until the early 1990s. Currently, the Henkel building is predominantly vacant with
limited portions of Warehouse #1 and the attached office building being utilized for equipment
storage and office space. Flywheel Group, LLC intends to lease Warehouse #3 and portions of
the attached office building in February 2018.
The Site received a letter of eligibility for entry into the North Carolina Department of
Environmental Quality (DEQ) Brownfields Program on June 28, 2017 (Brownfields Project No.
20026-16-060). Preliminary Site redevelopment plans indicate that the Site will be a mixed-use
transit oriented development and the existing Henkel Site building will be renovated to include
multi-tenant commercial and retail businesses. On November 30, 2017, a kick-off meeting was
held with the DEQ Brownfields project manager, Ms. Carolyn Minnich, at H&H’s office in
Charlotte, NC to discuss historical uses at the Site, previous assessment activities, and data gaps
associated with current conditions at the Site in preparation for the proposed occupancy and
redevelopment.
This work plan describes proposed assessment activities to address data gaps identified during
the November 2017 kick-off meeting and focuses on assessing the Henkel Site building prior to
proposed occupancy in February 2018. Additional sampling activities to address remaining data
gaps identified during the kick-off meeting will be addressed through another work plan
submitted under separate cover. The proposed scope of work for assessment presented in Section
2.0 is based upon discussions during the kick-off meeting.
2.0 Brownfields Assessment Scope of Work
The proposed assessment activities will be performed in general accordance with DEQ’s Inactive
Hazardous Sites Branch (IHSB) Guidelines for Assessment and Cleanup (Guidelines) dated
Ms. Carolyn Minnich
December 13, 2017
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October 2015 and most recent version of the U.S. Environmental Protection Agency (EPA)
Region IV Science and Ecosystem Support (SESD) Field Branches Quality System and
Technical Procedures guidance.
Based upon the previous assessment activities, Site history, current redevelopment plans, and
DEQ requests, H&H prepared a scope of work for additional assessment to evaluate potential
risks associated with future Site occupancy. Our proposed scope of work is presented in the
following sections.
2.1 Utility Clearance
Prior to conducting Brownfields assessment activities, H&H will contact North Carolina One-
Call, the public utility locator to mark subsurface utilities located on the Site. H&H will also hire
a private utility locator to screen proposed sample locations for subgrade utilities that may not be
marked by the public locator. The private utility locator will use ground penetrating radar (GPR)
and electromagnetic survey methods to attempt to locate subgrade utilities inside the Site
building.
Additionally, H&H will attempt to locate permanent monitoring wells MW-5 through MW-7
using a metal detector and probe rod.
2.2 Sub-Slab Vapor Sampling
To evaluate the potential for vapor intrusion associated with the existing Site building, H&H
proposes to install and sample eight sub-slab vapor monitoring points (SSVPs) at the Site. The
proposed SSVP sample locations are presented on Figure 2. The SSVPs will be installed by
utilizing a hammer drill and 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
Ms. Carolyn Minnich
December 13, 2017
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the concrete slab. Following concrete borehole advancement, loose concrete cuttings will be
removed from the boring using a bottlebrush and high efficiency particulate air (HEPA) vacuum.
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. The vapor pins will
be installed as flush-mount sample points capable of being secured with a stainless-steel cover
that screws onto the sampling point and is seated within the pilot hole annulus.
Prior to sampling, a leak check will be conducted at each SSVP by constructing a shroud around
the sampling point and flooding 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 monitoring point will be purged and
sampled outside of the shroud into a separate Tedlar® bag and analyzed using the helium gas
detector to ensure that helium concentrations are less than 10% of the concentration measured
within the shroud. If the concentration is greater than 10%, sampling personnel will attempt to
identify and seal the leak source(s) and additional leak check testing will be performed at that
location or the SSVP will be reinstalled at a nearby location and leak tested. Additionally, prior
to sub-slab vapor sample collection, H&H will conduct a five-minute system shut in test for each
sample to verify an airtight seal between the Summa canister and airflow regulator.
Following a successful leak check and shut in test, a laboratory-supplied 6-liter Summa canister
connected to an airflow regulator will be connected to the tubing of the point using a ferrule to
form an air-tight seal. The Summa canister’s airflow regulator will be pre-set by the laboratory
to restrict air flow into the canister to approximately 200 millileters per minute (ml/min). The
canister’s intake valve will then be opened to collect a vapor sample over an approximately 30-
minute period. During sample collection, vacuum measured in the sample line will be
periodically observed and recorded and sample collection stopped when vacuum in the canister
reaches approximately three to five inches of mercury (in/Hg). The vacuum will not reach a
residual pressure of zero in/Hg and the initial and final pressures will be recorded on the
laboratory chain of custody form. Upon completion of sample collection, the air flow regulator
Ms. Carolyn Minnich
December 13, 2017
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will be removed from the Summa canister and the samples will be packaged and shipped to the
laboratory for analysis of volatile organic compounds (VOCs) by EPA Method TO-15.
After sample collection, each vapor pin will be sealed with a dedicated cap and secured with a
flush-mount stainless steel cover. Sub-slab vapor sample locations will be estimated by
measuring distances to the sample locations from known benchmarks (i.e. building walls,
doorways, etc.).
2.3 Indoor Air Sampling (if warranted)
Following collection and receipt of the sub-slab vapor sampling data, H&H will summarize the
sample data in a table and provide it to DEQ for review. If sub-slab vapor sample concentrations
are less than the DEQ Inactive Hazardous Sites Branch (IHSB) Non-Residential vapor intrusion
screening levels, then indoor air sampling will not be warranted. However, if concentrations of
compounds are detected above screening levels, H&H will propose to DEQ 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 three ft long sampling cane in warehouse/open areas.
The typical height of a Summa canister with an attached airflow regulator is approximately two ft
above grade and, with the additional three ft long sampling cane, the sample intake point is
approximately five ft above grade (typical breathing zone height).
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 five ft above ground level.
Ms. Carolyn Minnich
December 13, 2017
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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 of 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 DEQ agreed upon analytes based
upon the sub-slab vapor sampling), and the laboratory will be asked to attain detection limits
which are less than the DEQ IHSB Non-Residential indoor air screening levels for these
compounds at a lifetime incremental cancer risk (LICR) of 1 x 10-6 for potential carcinogens and
a non-carcinogenic hazard index of 0.2.
Prior to issuance of the laboratory analytical report documenting results of the proposed vapor
intrusion assessment activities, the laboratory will be instructed to review laboratory analytical
results for the sub-slab vapor samples and identify compounds detected above the laboratory
reporting limits. To evaluate the potential for a completed vapor intrusion pathway into the Site
building, only those compounds detected above laboratory reporting limits in sub-slab vapor will
be reported for the indoor air samples.
2.4 Building Material Sampling
To evaluate potential risks associated with future occupancy at the Site, H&H proposes to
conduct building material sampling. The building material sampling will consist of collecting
eight concrete slab core samples for laboratory analysis. The concrete core locations will be
selected based on floor drain locations (where fluids would have likely pooled) and observed
Ms. Carolyn Minnich
December 13, 2017
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concrete conditions such as heavy staining or pitting. The proposed concrete sample locations
are presented on Figure 2. At each sample location, H&H will utilize a standing core drill (which
requires wet methods) equipped with a 1 ½-inch diameter core barrel. The sample core will be
collected through the entire thickness of the concrete slab. Following coring, each core sample
will be wiped with a paper towel in order to remove water and potential metal shavings left by
the core barrel. The sample will then be wrapped in 6-mil plastic liner and placed into plastic
Ziploc bags. While wrapped in plastic and bagged and as required by the laboratory, the core
samples will be broken into pea-sized pieces using a decontaminated engineer’s hammer. After
sample collection, the core holes will be patched with concrete and the sample locations will be
estimated by measuring distances to the sample locations from known benchmarks (i.e. building
walls, doorways, etc.).
Upon collection and preparation, the concrete samples will be placed directly into 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 shipped to a
North Carolina-certified laboratory, under chain-of-custody protocol for analysis of VOCs by
EPA Method 8260 and by total polychlorinated biphenyl (PCB) aroclors by EPA Method 8082.
Additional sample material will be collected for PCB congener-specific analysis by EPA Method
8270M. The laboratory will be instructed to hold the PCB congener-specific samples pending
results of the total PCB aroclors analysis.
2.5 Quality Assurance – Quality Control
H&H will utilize standard quality assurance/quality control (QA/QC) processes during the
Brownfields assessment activities. Non-dedicated sampling equipment will be decontaminated
using Liquinox® detergent and deionized water prior to and between each sampling location.
H&H will wear nitrile gloves while handling samples, and the sub-slab monitoring points will be
installed utilizing dedicated brass sampling points and silicone sleeves. Concrete samples will be
collected in laboratory-provided containers and placed on ice immediately after collection.
Ms. Carolyn Minnich
December 13, 2017
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For field and laboratory quality QA/QC purposes, H&H will collect one duplicate sub-slab vapor
sample and one duplicate concrete sample. The duplicate samples will be analyzed for the same
compounds as the parent sample.
3.0 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 the sampling activities, a figure depicting sample locations, a discussion of the data in
comparison to regulatory screening levels, laboratory analytical data, and conclusions and
recommendations concerning our activities.
We appreciate the opportunity to assist with this project. Should you have any questions or need
additional information please do not hesitate to call us at [phone].
Sincerely,
Hart & Hickman, PC
John Reuscher, PG, RSM Brett Lawrence, PG
Project Manager Project Geologist
Attachment
0 2000 4000
APPROXIMATE
SCALE IN FEET
N
U.S.G.S. QUADRANGLE MAPS
QUADRANGLE
7.5 MINUTE SERIES (TOPOGRAPHIC)
TITLE
PROJECT
SITE LOCATION MAP
KAISER TECH II
530 and 600 E. SUGAR CREEK ROADCHARLOTTE, NORTH CAROLINA
DATE:
JOB NO:
REVISION NO:
FIGURE:
12-13-17 0
1AMK-011
Derita, NC 1993
530 E. Sugar Creek Road
2923 S. Tryon Street, Suite 100Charlotte, NC 28203
704.586.0007(p) 704.586.0373(f)
600 E. Sugar Creek Road
FORMER HENKEL
CHEMICAL
CORPORATION
E. SUGAR
CREEK
DR
IVE
BR
IDGE
(UNDER
DEVELOPMENT
)
GRAVEL
RALEIGH STR
E
E
T
VACANT
WAREHOUSE
(3745 N. DAVIDSON STREET)
BLUE RIDGE RECYCLING/
ALLIED PRODUCTS
(3811 N. DAVIDSON STREET)
VACANT
WAREHOUSE
(3801 N. DAVIDSON STREET)
ALL AMERICAN PAWN
(724 E. SUGAR CREEK ROAD)
RIVERSIDE MILLWORK
(4000 RALEIGH STREET)
REC #10 - FORMER STORAGE BUILDING
(FORMER PCB STORAGE)
(REMOVED IN 2012)
CONCRETE
HAVEAFIL
(4001 RALEIGH STREET)
FORMER KAISER
FLUID TECHNOLOGIES
(530 E. SUGAR CREEK ROAD)
SUPERIOR DISTRIBUTION
(6001 E. SUGAR CREEK ROAD)FORMER RESEARCH AND DEVELOPMENT LAB
(REMOVED IN 2012)
FORMER BOILER
ROOMS (REC #2)
TRUCK SCALE
RAMP TO
BASEMENT
WAREHOUSE #3
SANITARY SEWER
MANHOLE
OFFICES
WAREHOUSE #2
(STORAGE)
WAREHOUSE #1
(FORMER PROCESS AREA)
REC #2 - FORMER BOILER ROOM
AND PCB HOT OIL SYSTEM
REC #4 - FORMER TANK
CAR PUMP STATION
REC #6 - FORMER SOUTH
TANK CAR PUMP STATION
CATS LYNX L
I
G
H
T
R
A
I
L

L
I
N
E
NORFOLK SO
U
T
H
E
R
N

R
A
I
L
R
O
A
D
RESIDENCES
REC #3 - FORMER #5
FUEL OIL UST
REC #12 - FORMER
MAINTENANCE SHOP
REC #8 - FORMER
ISOPROPYLALCOHOL UST
DEBRIS
MW-2
MW-3
MW-4
MW-7
MW-5
MW-6
REC #5 - FORMER
AST AREA
REC #7 - OPEN
FLOOR DRAIN
REC #11 - OPEN
FLOOR DRAINS
REC #1 - CONCRETE
FILLED DRAINS
REC #9 - 8,000 GALLON
BUTYL STEARATE SPILL
LOADI
N
G

D
O
C
K
(2) HYDRAULIC OIL DRUMS
1,000-GAL. DIELSEL AST
CONCRETE-LINED
PIT
PARKING GARAGE
CATS LYNX LIGHTRAIL
PROPOSED RESTROOM
LOCATION
FORMER HENKEL CHEMICAL CORPORATION
CHARLOTTE, NORTH CAROLINA
PROPOSED SAMPLE LOCATION MAP
LEGEND
SITE PROPERTY BOUNDARY
RAILROAD TRACKS
FORMER RAILROAD SIDING
FENCE LINE
FORMER WASTEWATER
EFFLUENT LINE FROM TRENCH
DRAINS
55-GALLON DRUM
FLOOR DRAINS
CATCH BASIN
PAD-MOUNTED TRANSFORMER
POLE-MOUNTED TRANSFORMER
MONITORING WELL LOCATION
PROPOSED SUB-SLAB VAPOR
SAMPLE
PROPOSED CONCRETE SLAB
SAMPLE
2923 South Tryon Street-Suite 100
Charlotte, North Carolina 28203
704-586-0007(p) 704-586-0373(f)
License # C-1269 / #C-245 Geology
S:\AAA-Master Projects\Anthony Kuhn - AMK\AMK-011 Henkel-Kaiser BF Site\Figures\Proposed Sample Location Map.dwg, FIG 2, 12/13/2017 4:09:20 PM, zbarlow
conduct the initial sampling prior to the Charlotte Arts League occupying a portion of the building in
February. To meet this schedule, we have scheduled field activities this week pending your
approval. Thanks, and please contact us with questions or comments.

Matt Ingalls, Project Manager
Hart & Hickman, PC | 2923 South Tryon Street, Suite 100 | Charlotte, NC 28203
Direct 704-887-4617 | Mobile [phone] | Main 704-586-0007
www.harthickman.com

From: Brett Lawrence
Sent: Wednesday, December 13, 2017 4:38 PM
To: Minnich, Carolyn <[e-mail]>
Cc: Matt Ingalls <[e-mail]>; Tony Kuhn <[e-mail]>
Subject: Kaiser Fluids Tech II (Henkel Site) Work Plan

Good afternoon Carolyn,

Please find the attached work plan for the above-referenced project for your review. As we
discussed, this work plan prioritizes sampling of the Henkel building in advance of planned
occupancy in February. Please let us know if you have any questions or want to discuss further.

Thanks,

Brett Lawrence, PG, Project Geologist
Hart & Hickman, PC | 2923 South Tryon Street, Suite 100 | Charlotte, NC 28203
Direct 704-887-4601 | Mobile [phone] | Main 704-586-0007
www.harthickman.com