17047 REEP Work Plan 20180207

Via Email
February 7, 2018

North Carolina Department of Environmental Quality –
Brownfields Program
1646 Mail Service Center
Raleigh, NC 27699-1646

Attention: Mr. William Schmithorst, PG

Subject: Work Plan for Additional Waste Disposal Assessment
Revision 1
REEP-LRC Project 1 (Proposed New Building)
Charlotte, North Carolina
Brownfields Project ID# 17047-13-60
H&H Project No. LRC-006

Dear William:
1.0 Introduction

Per your request, Hart & Hickman, PC (H&H) is providing this revised Work Plan for Additional
Waste Disposal Assessment at the REEP-LRC Project 1 undeveloped property located at 1900
Continental Boulevard (previously referred to as 1700 Continental Blvd) in Charlotte,
Mecklenburg County, North Carolina (Site or subject Site). The Site is comprised of
approximately 27 acres of undeveloped wooded land (Figure 1). Current redevelopment plans
include clearing the wooded area, removing concrete foundations and other remnants of former
Site operations, grading the Site; and construction of an approximate 360,000 square foot (sq ft)
warehouse, parking area, and a stormwater retention pond.

As you know, during pre-development activities, H&H observed surface waste materials at this
Site. In that regard, the North Carolina Department of Environmental Quality (DEQ) requested
additional assessment in a letter dated December 21, 2017. On January 30, 2018, H&H provided
a Work Plan for Additional Waste Disposal Assessment to the Brownfields Program. On
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February 7, 2018
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February 1, 2018 the Brownfields Program provided comments and requested revisions to the
work plan via email. The following revised work plan incorporates the comments and requests
made in the February 1, 2018 email from the Brownfields Program.

2.0 Scope of Work

Waste Disposal Area
As indicated in H&H’s September 28, 2017 Waste, Drums, and ACM Removal Report, at least
one drum remained following excavation activities conducted in the southern portion of the Site.
H&H will excavate in the vicinity of the known drum to recover and dispose of the drum. Due to
the wooded and uneven terrain, the drum will be direct loaded into a lined front-end loader and
transported to a lined roll-off container staged in a paved area of the Site.

To attempt to better understand the extent of buried waste in the southeastern portion of the Site,
H&H reviewed high resolution aerial photographs and subcontracted for a ground penetrating
radar (GPR) survey. The 1970 aerial photograph showed a potential disposal area (possible dug
pit) where waste drums were excavated in the southeastern portion of the Site. The result of the
GPR survey indicated the presence of an approximate 1,400 sq ft area of disturbed soil consistent
with reworking and backfilling activities in the southeastern portion of the Site. In addition, the
GPR survey indicated one anomaly in the northern portion of the disturbed soil area which may
indicate the presence of an additional buried drum. The extent of the area of disturbed soil and
the location of the GPR anomaly are shown on Figure 2. The results of the GPR survey were
provided to the Brownfields Program in the GPR Survey Report dated December 6, 2017.

Based on the GPR Survey Report, H&H will also excavate in the vicinity of the potential drum
anomaly to evaluate if an additional drum or additional waste materials are present in the waste
disposal area. Excavation of the drum known to be present in the former excavation sidewall and
the test excavation at the GPR anomaly will provide the opportunity to observe this area for
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additional buried drums. If additional buried drums are encountered, they will also be removed
or H&H will contact DEQ to discuss the findings should a number of drums be encountered.
Although the goal of this action is to remove buried drums, waste materials and significantly
impacted soil (based on odor, staining, or elevated PID readings) will also be placed in the lined
roll-off container via the lined front-end loader, if encountered during removal of the drums. The
excavations will not be extended to remove waste solids or contaminated soil. If residual fluid
are observed to leak from drum(s) during removal, the affected soil will also be removed.
Photographs will be taken during the excavation activities for inclusion in the Additional Waste
Disposal Assessment Report discussed in Section 5.0.

Following excavation of the drum(s), waste material, and/or significantly impacted soil, a soil
sample will be collected from the base of the excavations to determine if residual soil impacts are
present. In addition, H&H will collect one sidewall sample of waste or soil at the location judged
to have the highest potential for impacts based on field screening. H&H anticipates collecting at
least three soil samples during this field work. The soil samples will be submitted in an iced
cooler under standard chain of custody protocols to a North Carolina certified laboratory for
analysis of volatile organic compounds (VOCs) by EPA Method 8260B, semi-VOCs (SVOCS)
by EPA method 8270D, and hazardous substance list (HSL) metals by EPA Methods
6020/7470/7441. H&H will request laboratory detection limits at or below ISHB screening
criteria, when possible. Metal detections in soil will be compared to published naturally
occurring metal concentrations in soil and previously collected soil metals data for this Site.

Following excavation activities, H&H will sample the roll-off box materials for hazardous waste
characterization purposes. The sample will be submitted for laboratory analysis of toxicity
characteristic leaching procedure (TCLP) VOCs, TCLP SVOCs, and TCLP RCRA metals. If
intact drums containing liquid are recovered from the excavation they will be sampled separately
via TCLP methods for waste characterization purposes. The soil and waste in the roll-off box
will be disposed in accordance with applicable regulations and copies of the disposal manifests
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will be provided to DEQ.

At the request of the Brownfields Program, H&H will collect groundwater samples in the vicinity
of the disposal area and also in the vicinity of previous subsurface soil boring SB-8 to evaluate
for the presence of groundwater impacts from historical disposal activities. The groundwater
samples will be collected by installing a temporary monitoring well at each location using a track
mounted direct push technology (DPT) rig. The locations of the proposed temporary monitoring
wells are shown on Figure 2. Prior to installing the temporary wells, H&H will obtain a
Subsurface Investigation Permit (SIP) from Mecklenburg County. The depth to groundwater in
each temporary well will be measured relative to the local grade.

The temporary monitoring wells will be constructed of 1-inch diameter PVC with 10 to 15 ft of
well prepack screen set to bracket the water table and 1-inch diameter PVC well casing to the
ground surface. After the temporary monitoring wells are installed, the wells will be allowed to
equilibrate to static conditions, and the wells will be developed by removing a minimum of 3 to 5
well volumes and until field parameters (pH ± 0.1 SU and conductivity varies no more than 5%)
have stabilized.

After well development, groundwater samples will be collected utilizing low flow/low stress
purging techniques using a peristaltic pump and dedicated polyethylene tubing. The intake point
of the pump tubing will be placed in the approximate mid-portion of the screened interval of the
well and groundwater will be removed at a rate no greater than 200 milliliters per minute. H&H
will utilize a water quality meter to collect measurements of pH, temperature, dissolved oxygen,
oxidation reduction potential, turbidity, and specific conductivity during the purging process.
Purging will be considered complete when the parameters stabilize (pH ± 0.1 SU and
conductivity varies no more than 5%).

Mr. William Schmithorst, PG
February 7, 2018
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Once groundwater parameters stabilize, a groundwater sample will be collected directly into
laboratory supplied sample containers (using the “soda straw” method for VOC sample vials).
The sample containers will be labeled with the sample identification, date, and requested
analysis, and placed in a laboratory supplied cooler and iced. The groundwater samples will be
delivered to a North Carolina certified laboratory under standard chain of custody protocols for
analysis of VOCs by EPA Method 8260B. H&H will request laboratory detection limits at or
below ISHB screening criteria, when possible. Following sample collection, the monitoring
wells will be properly abandoned by a licensed well driller and the SIP will be closed out with
Mecklenburg County.

Former ACM Area
As you requested, H&H will collect soil samples in the asbestos containing material (ACM)
removal areas located in the northern and central portions of the Site to determine if asbestos
impacts are present in soil. The soil samples will be collected from 0 to 1 ft below ground
surface (bgs) utilizing a stainless-steel hand auger or trowel. A total of three soil samples will be
collected. One soil sample will be collected from each of the northern ACM removal areas, and
one sample will be collected from the central ACM removal area. The locations of the proposed
soil samples are shown on Figure 2. The soil samples will be submitted to an analytical
laboratory using chain of custody procedures for analysis of asbestos using the 400 count EPA
600 Method.

3.0 Quality Assurance – Quality Control

This assessment work will be completed in general accordance with NC DEQ Inactive
Hazardous Sites Branch (IHSB) Guidance (October 2015) and US EPA Region IV Science and
Ecosystem Support Division (SESD) protocols. Non-dedicated equipment and tools will be
decontaminated prior to use at each boring or sampling location, or following exposure to soil or
groundwater. For quality assurance and quality control (QA/QC) purposes, one trip blank will be
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submitted for analysis of VOCs by EPA Method 8260 for each sample shipment. To evaluate the
reproducibility of the sample results, H&H will collect one duplicate soil sample and one
duplicate groundwater sample. The duplicate soil sample will be submitted for laboratory
analysis of VOCs by EPA Method 8260B, SVOCs by EPA Method 8270D, and HSL metals by
EPA Methods 6020/7470/7441. The duplicate groundwater sample will be submitted for
laboratory analysis of VOCs by EPA Method 8260B.

4.0 Investigation Derived Waste

Investigation derived waste (IDW) generated during the assessment activities will be disposed in
accordance with the October 2015 Inactive Hazardous Sites Branch (IHSB) Guidelines for
Assessment and Clean Up. Based on previous assessment conducted at the Site, it is anticipated
the IDW will be disposed on-Site. However, if significant impacts are suspected, the soil cuttings
and/or purge water will be containerized in 55-gallon drums and staged on-Site pending
analytical results of a composite IDW sample. Based on laboratory analytical results of the IDW
samples (if needed), the drums will be transported off-Site to a suitable facility for disposal.

5.0 Reporting

Following completion of the sampling activities and receipt of the analytical data, H&H will
document our findings in an Additional Waste Disposal Assessment Report. The report will
include a description of the excavation, disposal, and sampling activities, a figure depicting
sample locations, a discussion of the data in comparison to applicable screening levels,
laboratory analytical data, photographs, disposal manifests, and conclusions and
recommendations concerning our activities.

SITE
0 2000 4000
APPROXIMATE
SCALE IN FEET
N
U.S.G.S. QUADRANGLE MAP
QUADRANGLE
7.5 MINUTE SERIES (TOPOGRAPHIC)
CHARLOTTE WEST, NORTH CAROLINA 1996
TITLE
PROJECT
SITE LOCATION MAP
REEP-LRC PROJECT 1
1900 CONTINENTAL BOULEVARDCHARLOTTE, NORTH CAROLINA
DATE:
JOB NO:
REVISION NO:
FIGURE:
2-7-18 0
1LRC-006
SB-9
APPROXIMATE AREA OF ASBESTOS
TRANSITE DEBRIS (REMOVED)
APPROXIMATE AREA OF ASBESTOS
ROOFING DEBRIS (REMOVED)
JOB NO. LRC-006
REVISION NO. 0DATE: 2-7-18
FIGURE NO. 2
UNDEVELOPED PARCEL
1900 CONTINENTAL BOULEVARD
CHARLOTTE, NORTH CAROLINA
PROPOSED SAMPLE LOCATION MAP
2923 South Tryon Street-Suite 100
Charlotte, North Carolina 28203
704-586-0007(p) 704-586-0373(f)
License # C-1269 / #C-245 Geology
LEGEND
SITE PROPERTY BOUNDARY
RAILROAD SPURS
PROPOSED BUILDING FOOTPRINT
APPROXIMATE EXTENT OF
POTENTIAL WASTE DISPOSAL BASED
ON HISTORICAL AERIAL REVIEW
PREVIOUS EXCAVATION AREA
HIGH-DENSITY ANOMALY
(POSSIBLE DRUM)
PREVIOUS SOIL SAMPLE LOCATION
PROPOSED SOIL SAMPLE LOCATION
PROPOSED TEMPORARY
MONITORING LOCATION NOTES:
1.BASE MAP OBTAINED FROM MECKLENBURG CO. GIS
(2017).
2.H&H CONDUCTED ASSESSMENT ON ACTIVITIES ON
OCTOBER 13, 14, 17, & 20 2016.
APPROXIMATE EXTENT OF
SOIL DISTURBANCE
BASED ON GPR SURVEY
APPROXIMATE LOCATION OF
KNOWN REMAINING DRUM
S:\AAA-Master Projects\LRC Patriot (LRC)\LRC-006 New Building Waste Assessment\Figures\Proposed Sample Location Map.dwg, FIG 2, 2/7/2018 9:22:48 AM, zbarlow