HomeMy WebLinkAbout18044_LRMF_ P-2918F_Brownfields Update Letter _20190115
Via Email
January 15, 2019
NC DEQ
Division of Waste Management
Brownfields Program
1646 Mail Service Center
Raleigh, NC 27699-1646
Attention: Ms. Carolyn Minnich
Re: Brownfields Update
Brownfields Project 18044-14-060
NC DOT Parcels 31.1/32
Charlotte Locomotive and Railcar Maintenance Facility
State Project: P-2918F; WBS Element: 50000.3.1
Charlotte, Mecklenburg County, North Carolina
H&H Project No. ROW-510
Dear Carolyn:
Please find the attached Brownfields Update Report in PDF format for environmental and
redevelopment activities for Brownfields Project No. 18044-14-060 located at the Charlotte
Locomotive and Railcar Maintenance Facility in Charlotte, Mecklenburg County, North
Carolina. If you have any questions or need additional information, please contact us at (704)
586-0007.
Sincerely,
Hart & Hickman, PC
David Graham, PG Matt Bramblett, PE
Senior Project Geologist Principal
Attachment
cc: Mr. Gordon Box, LG, NC DOT (via Email)
Mr. Cyrus Parker, LG, PE, NC DOT (via Email)
Mr. Craig Newton, PE, NC DOT (via Email)
Ms. Moriah Ellington, PE, STV, Inc. (via Email)
Brownfields Update
NC DOT Parcel 31.1/32
Charlotte Locomotive and Railcar
Maintenance Facility
Charlotte, Mecklenburg County
North Carolina
Brownfields Project 18044-14-060
H&H Job No. ROW-510
State Project P-2918F
WBS Element #50000.3.1
January 15, 2019
Via Email
January 15, 2019
NC DEQ
Division of Waste Management
Brownfields Program
1646 Mail Service Center
Raleigh, NC 27699-1646
Attention: Ms. Carolyn Minnich
Re: Brownfields Update
Brownfields Project 18044-14-060
NC DOT Parcels 31.1/32
Charlotte Locomotive and Railcar Maintenance Facility
State Project: P-2918F; WBS Element: 50000.3.1
Charlotte, Mecklenburg County, North Carolina
H&H Project No. ROW-510
Dear Carolyn:
1.0 Introduction
On behalf of the North Carolina Department of Transportation (NC DOT), Hart & Hickman, PC
(H&H) is submitting this letter report summarizing activities conducted at the above referenced
Brownfields property (NC DOT Parcels 31.1/32) located at 1320 and 1336 S. Graham Street. This
site is part of the Charlotte Locomotive and Railcar Maintenance Facility (LRMF) in Charlotte,
Mecklenburg County, North Carolina. A site location map is included as Figure 1, and a site map is
included as Figure 2.
In accordance with the Brownfields Agreement (BFA), within 90 days of each one-year
anniversary of the effective date (October 24, 2016) of the BFA during redevelopment for the
Brownfields property, and/or at the completion of redevelopment activities, H&H, on behalf of
NC DOT, will submit a report to NC DEQ documenting the redevelopment and environmental
Ms. Carolyn Minnich
January 15, 2019
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2918F_Brownfields Update Letter _20190115.doc
activities conducted on the Brownfields property for the reporting period. A general summary of
activities conducted at the Brownfields property over the past year is provided below.
The Brownfields property has been redeveloped as part of the NC DOT LRMF project.
Construction activities started on the LRMF project in October 2016. NC DOT’s construction
contractor, Zoladz Construction Company, Inc. (Zoladz) has completed final construction
activities associated with mass grading, railroad service tracks, service platform, compressor
building, landscaping, etc. on the Brownfields property.
A summary of environmental reports associated with the site that have recently been submitted to
DEQ are provided below.
- Environmental Management Plan - Charlotte Locomotive and Railcar Maintenance Facility,
May 6, 2016
- Hazardous Soil Treatment and Removal Activities - NC DOT Parcel 32, August 5, 2016
- Brownfields Soil Sampling - NC DOT Parcel 32, June 23, 2016
- Brownfields Soil Berm Sampling - NC DOT Parcel 31.1/32, June 15, 2017
- Brownfields Update - NC DOT Parcel 31.1/32, January 18, 2018
2.0 Environmental and Redevelopment Activities Summary
Previous Environmental and Redevelopment Activities
Based on historical assessment activities, widespread impacted soil was previously identified on
the Brownfields property. The primary contaminants are total petroleum hydrocarbons (TPH),
polychlorinated biphenyls (PCBs), and metals (including lead above characteristically hazardous
waste thresholds). A portion of the lead impacted soil above hazardous waste thresholds was
located in the proposed LRMF cut area on the northern portion of Parcel 32. Prior to
construction activities in May 2016, this hazardous soil was treated on-site to stabilize the lead
impacts to below hazardous waste thresholds for subsequent disposal at a Subtitle D landfill.
Ms. Carolyn Minnich
January 15, 2019
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2918F_Brownfields Update Letter _20190115.doc
The LRMF project also required soil (including low-level non-hazardous impacted soil) to be cut
from the northern portion of the Brownfields property Parcel 32. As part of the LRMF
construction activities and with NC DEQ approval, Zoladz reused the cut soil from the northern
portion of the Brownfields property Parcel 32 in a privacy berm on the Parcel 31.1 portion of the
Brownfields property (see Figure 2). Soil that was cut from the northern portion of Parcel 32
was below NC DEQ IHSB Industrial Health-Based Soil Remediation Goals (SRGs). A small
stockpile of soil which contained polynuclear aromatic hydrocarbons (PAHs) and PCBs above
the Industrial SRGs was placed near the center and at the base of the berm and covered with at
least two ft of soil that was not impacted above Industrial SRGs.
In April 2017, Zoladz covered the entire berm with 2 ft of fill material that was cut from an area
of the LRMF project outside of the Brownfields property boundary. Because the Environmental
Management Plan (EMP) indicates that imported fill must be sampled prior to use as fill on the
Brownfields property NC DEQ requested that this material be sampled. Analytical results
indicated low level detections of PCBs and/or metals below the Industrial SRGs in soil samples
collected from the berm cover soil. Because the detected constituents were below Industrial
SRGs, the berm soil cover was left in place. The berm was subsequently seeded and mulched by
Zoladz using hydroseeding to prevent erosion of the berm.
In February 2017, NC DEQ approved Zoladz work plan to allow for temporary use of heavy
machinery for crushing rock (blasted and removed from other areas of the LRMF project) and
for storage of the crushed rock on the Brownfields property. The work plan addressed preserving
and restoring the asphalt parking lot which is serving as a protective cap over an area of
impacted soil. The asphalt parking area and former concrete building slab on the Brownfields
property were then used to store crushed rock piles, railroad construction materials, and some
heavy machinery. The above mentioned activities were previously documented in H&H’s
Brownfields Update letter report dated January 18, 2018 and in the historical environmental reports
noted above.
Ms. Carolyn Minnich
January 15, 2019
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2918F_Brownfields Update Letter _20190115.doc
2018 Environmental and Redevelopment Activities
In March 2018, Zoladz completed removal of the crushed rock, heavy machinery, etc. from the
Brownfields property. H&H subsequently met with NC DEQ on site and determined that several
areas of the asphalt and concrete cap (former building slab) that cover impacted soil at the site
needed to be repaired. On April 5, 2018, Zoladz patched the damaged areas in the asphalt
parking area and concrete slab that required repairs as specified by NC DEQ. On May 25, 2018,
H&H met with NC DEQ to inspect the repairs made by Zoladz. The patchwork on the asphalt
and concrete cap above the impacted soil area was approved in NC DEQ letter dated June 5,
2018. Photographs of asphalt patching repairs are included in Appendix A.
In July 2018 H&H personnel observed an electrical trench being installed in the northern portion
of the asphalt parking area on Parcel 32. The trench was approximately 2ft x 150 ft long and 3 ft
deep (see Figure 2). After the electrical utility installation was completed the soil that was
excavated from the trench was used as backfill in the trench in accordance with the EMP. After
backfilling was complete a small amount (approximately a dump truck load) of the excavated
soil remained and could not be used as backfill. This soil was stockpiled and covered with
plastic. H&H sampled the stockpile to determine if the material was suitable for placement in
the berm. The sample results are described below.
3.0 Soil Sampling Activities and Analytical Results
On July 27, 2018, H&H collected a composite sample (BF Stockpile) from the utility trench soil
stockpile using a stainless-steel hand auger. The sample consisted of aliquots of soil collected
from the mid-point of three soil borings advanced into the stockpile. Equal amounts of each of
the aliquots were placed in an inert container and mixed with a nitrile gloved hand until
homogenized. The homogenized sample was then placed into laboratory supplied sample
containers, placed in an iced cooler, and submitted to Prism Laboratories (Prism) under chain-of-
custody protocol for analysis of semi-volatile organic compounds (SVOCs) by EPA Method
8270, total RCRA metals by EPA Method 6010/7471, toxicity characteristic leaching procedure
Ms. Carolyn Minnich
January 15, 2019
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(TCLP) RCRA metals by EPA Method 6010/7470 and PCBs by EPA Method 8082. Laboratory
analytical data sheets and chain-of-custody documentation are included in Appendix B. The
analytical results are summarized in Table 1 and discussed below.
Because this is a Brownfields site, detected concentrations in the composite soil sample were
compared to NC DEQ IHSB Industrial Health-Based SRGs. An elevated concentration of lead
(300 mg/kg) was detected in the composite sample slightly above the Protection of Groundwater
(POG) SRG of 270 mg/kg but did not exceed the Industrial SRG (800 mg/kg). A concentration
of TCLP lead (1.5 mg/L) was detected in the composite sample but did not exceed the
characteristic hazardous waste threshold of 5 mg/L. No PCBs or SVOCs were detected in the
soil sample.
Because analytical results indicated the stockpiled soil was below the Industrial SRGs, the
stockpiled soil was subsequently placed in the berm. On October 18, 2018, Zoladz moved the
stockpiled soil to the berm. The soil was spread on the eastern end of the berm and covered with
seed and straw. Zoladz then patched the utility trench with asphalt (see Photograph in Appendix
A).
4.0 Completion Statement
Construction activities associated with the LRMF project and redevelopment of Brownfields
Parcels 31.1/32 started in late 2016 and were completed in the Fall of 2018. NC DOT’s
contractor has completed redevelopment activities associated with construction of the service
tracks, service platform, compressor building, landscaping, etc. on the Brownfields property.
Recent photographs of the Brownfields property are included in Appendix A.
This report is considered to be the final Brownfields report for the construction on the
Brownfields property (NC DOT Parcels 31.1/32) located at 1320 and 1336 S. Graham Street
Table 1 (Page 1 of 1)Summary of Soil Analytical DataNC DOT Brownfields Property (#18044-14-060)Charlotte, Mecklenburg County, NCH&H Job No. ROW-510Sample IDBF StockpileSample Date7/27/2018PCBs(8082) (mg/kg)BRLSVOCs (8270)(mg/kg)BRLRange (mg/kg) Mean (mg/kg)RCRA Metals (7471/6010) (mg/kg)Arsenic 1.6 1.0-18 4.8Barium 97 50-1,000 356Cadmium 0.65 1.0-10 4.3Chromium 34 7.0-300 65Lead300ND - 50 16Mercury 0.28 0.03-0.52 0.121TCLP RCRA Metals (7470/6010) (mg/L)Lead 1.5Notes:1. NC DEQ IHSB Preliminary Industrial Health-Based Soil Remediation Goals (PSRGs) - February 20182. NC DEQ IHSB Protection of Groundwater (POG) PSRGs - February 20183. Range and Mean background values for North Carolina or Southeast soils taken from Elements in North American Soils by Dragun and Chekiri, 2005EPA Method follows parameter in parentheses; -- = Not Applicable; BRL= Below reporting limitPCBs = polychlorinated biphenyls; SVOCs= semi-volatile organic compounds;TCLP = Toxicity Characteristic Leaching ProcedureBold = exceeds IHSB POG PSRG; mg/kg = milligrams per kilogramIHSB Industrial PSRG1IHSB POG2(mg/kg) (mg/kg)Screening Criteria-- ---- --3.0 5.847,000 5801.03350,000 360,000RCRA Toxicity Characteristic Level (mg/L)5Background Metals in Soil3200800 2709.7S:\AAA‐Master Projects\NC DOT Right‐of‐Way ‐ROW\ROW‐500s\ROW‐510 P‐2918F Hazardous Soil & Brownfields\Brownfields Final Report 2019\BF Stockpile Data Table.xlsTable 1 (Page 1 of 1)Hart & Hickman, PC
SITE
0 2000 4000
APPROXIMATE
SCALE IN FEET
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U.S.G.S. QUADRANGLE MAP
QUADRANGLE
7.5 MINUTE SERIES (TOPOGRAPHIC)
Charlotte East, NC 1991
TITLE
PROJECT
SITE LOCATION MAP
NC DOT BROWNFIELDS PROPERTY #18044-14-060
1320 & 1336 S. GRAHAM STREET
CHARLOTTE, NORTH CAROLINA
DATE:
JOB NO:
REVISION NO:
FIGURE:
1-9-19 0
1ROW-510
714715 716716 71771771871
8 719719719720
720
720721
721
721 722722722 723723723
724 724724725
725726726 727728
729 PENMAN
S
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T
S. G
R
A
H
A
M
S
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CONC.
BERM LOCATION
CONCRETE PAD
CONCRETE PAD
REVISION NO. 0
FIGURE NO. 2
SITE MAP
LEGEND
BROWNFIELDS PROPERTY BOUNDARY
PARCEL LINE
OFF-SITE BUILDING
RAILROAD RIGHT-OF-WAY
FENCE
DRAINAGE DITCH
UTILITY TRENCH
NC DOT PARCEL NUMBER
JOB NO. ROW-510
DATE: 1-14-19
NC DOT - BROWNFIELDS PROPERTY #18044-14-060
1320 & 1336 S. GRAHAM STREET
CHARLOTTE, MECKLENBURG COUNTY
2923 South Tryon Street-Suite 100
Charlotte, North Carolina 28203
704-586-0007(p) 704-586-0373(f)
License # C-1269 / #C-245 Geology
ASPHALT
ASPHALT
COMPRESSOR BUILDING LOCATION
ACCESS ROAD
CONCRETE SERVICE PLATFORM
RAILROAD SERVICE TRACKS
S:\AAA-Master Projects\NC DOT Right-of-Way -ROW\ROW-500s\ROW-510 P-2918F Hazardous Soil & Brownfields\Brownfields Update Report\Site Map.dwg, FIG 2, 1/14/2019 10:34:55 AM, erichardson
Appendix A
Site Photographs
Photograph 2: View of asphalt cap (January 2019).ROW-510BROWNFIELDS PROJECT 18044-14-060
CHARLOTTE, NORTH CAROLINA
2923 S. Tryon Street, Suite 100
Charlotte, NC 28203
704.586.0007(p) 704.586.0373(f)
Photograph 1: Northern portion of the Brownfields property (January 2019).
Photograph 4: Typical asphalt patch areas on the eastern portion of the Brownfields property.ROW-510BROWNFIELDS PROJECT 18044-14-060
CHARLOTTE, NORTH CAROLINA
2923 S. Tryon Street, Suite 100
Charlotte, NC 28203
704.586.0007(p) 704.586.0373(f)
Photograph 3: View of the berm from the northwest (January 2019).
Berm
ROW-510BROWNFIELDS PROJECT 18044-14-060
CHARLOTTE, NORTH CAROLINA
2923 S. Tryon Street, Suite 100
Charlotte, NC 28203
704.586.0007(p) 704.586.0373(f)
Photograph 5: Asphalt cap over utility trench.
Appendix B
Laboratory Analytical Data Report
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