09048_Universal Stainless_Req Add Assessment 20091230

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December 30, 2009

Sent Via E-mail

Amanda K. Short
C/O ADH Properties
McGuireWoods LLP
201 N. Tryon St.
Charlotte, NC 28202
[e-mail]

Subject: Request for Additional Assessment
Former Universal Stainless Facility
10801 Nations Ford Road
Charlotte, Mecklenburg County
Brownfields Project Number 09048-05-60

Dear Mr. Hartnett:

The North Carolina Department of Environmental and Natural Resources (DENR) has reviewed
the currently available information for the above referenced site and determined that data gaps have been
identified. Additional assessment activities, as outlined below, are required to assist in making risk
management decisions for inclusion in the brownfields agreement (BFA).

• General: The most recent Inactive Hazardous Sites Program Guidelines for Assessment and
Cleanup (http://www.wastenotnc.org/sfhome/stateleadguidance.pdf ) should be followed, which in turn
relies upon EPA's Environmental Investigations Standard Operating Procedures and Quality Assurance
Manual (a .pdf version is available on their website at
http://www.epa.gov/region4/sesd/eisopqam/eisopqam.html). Request Level 2 QA/QC data packages from
a N.C. certified environmental laboratory. Submit a work plan for review prior to conducting field work
for approval by DENR to ensure all aspects of the requirements are covered.

• Sampling Activities: Collect groundwater samples from existing site monitoring wells. Record
depth of static groundwater in each well prior to purging activities, and field parameters (e.g., temperature,
dissolved oxygen, pH, turbidity, and conductivity) prior to sampling activities for summary report.
Contain purge water for analysis prior to disposal following approval by DENR. In lieu of sampling the
containers, the consultant may rely on sample analysis for disposal options. The ultimate disposal
information must be included in the report.

North Carolina Department of Environment and Natural Resources
Dexter Matthews, Director Division of Waste Management Beverly Eaves Perdue, Governor
Dee Freeman, Secretary

Ms. Short
December 30, 2009
Page 2 of 2

• Soil-Gas: Collect soil-gas samples or sub-slab soil-gas samples. Submit a work plan to
brownfields program for review and approval prior to schedule the field work. For sub-slab and near slab
soil vapor sampling, methods should be used that are consistent with the following guidelines and
information:

9 EPA Compendium Method TO-15 (EPA/625/R-96-010b). (8- 24 hour sample duration).
9 Section 3.0 of the “Assessment of Vapor Intrusion in Homes Near the Raymark Superfund Site
Using Basement and Sub-Slab Air Samples”.
9 Appendix E of “OSWER Draft Guidance for Evaluating the Vapor Intrusion to Indoor Air
Pathway from Groundwater and Soils (Subsurface Vapor Intrusion Guidance)”.
9 Vapor Intrusion Sampling Draft Guidance, NCDENR Brownfields Program 8/18/2009

• Laboratory Analyses: Submit samples to a NC-certified laboratory. Analyze all groundwater
volatile organic compounds (VOCs) by EPA Methods 8260, semi-volatile organic compounds (SVOCs)
by EPA Method 8270, and oil and grease by EPA Method 9071. Analyze all soil-gas samples by TO-15
Method. Ensure laboratory method detection limits are below applicable standards. Provide complete
original laboratory reports and associated laboratory QA/QC documentation in the final report to DENR.

• Report and Figures: Submit an assessment report with a description of field activities, tabulated
data (including historical data), the laboratory data packet, and information requested in above bullets.
Provide a site plan with temporary well locations, estimated locations of previous soil boring, and current
site structures. Provide concentration map(s) for contaminants detected above applicable standards.
Provide summary analytical table for contaminate detected by the laboratory versus the state standard and
include historical data, if available.

Please have your environmental consultant contact me to discuss this work plan. Once these
activities are complete, we will determine if any additional information is needed to complete our
evaluation of site risks and preparation of the draft Brownfields Agreement.

Sincerely,
Carolyn Minnich
Carolyn F. Minnich
Brownfields Project Manager
Division of Waste Management

cc: Project File

ec: Bruce Nicholson, DENR