21015-17-090_DEQ Request for Additional Assessment_Correspondence_06.28.2019_Five Points

From:Cannon, Cody J
To:Brian Borne; Stukes, Mary Katherine H.; [e-mail]; Scott Ball
Cc:Minnich, Carolyn; Wahl, Tracy
Subject:Five Points (21015-17-090) Brownfields Property Meeting Follow Up
Date:Friday, June 28, 2019 12:54:00 PM
Attachments:image001.pngAdditionalAssessment-Map_06.28.2019.tifBrownfields Property Receptor Survey 20190204.pdf21015_Five Points_BPA_20170314.pdf
Good Morning All,

Thanks for meeting with Carolyn and I on Tuesday afternoon. I want to provide quick recap of some
of the items we discussed and some additional information I gleaned from a further review of the
Phase II ESA:

·         We spoke of being able to limit the Land Use Restriction (LUR) for a potential vapor
intrusion assessment to the 320 E Franklin St parcel because we believed the groundwater
results from the 2 monitoring wells on the 322 E Franklin St parcel showed no impacts for
volatile organic compounds (VOCs). After further review, it appears that monitoring well
TMW-4 was not sampled as part of the Phase II ESA and the sample collected from
monitoring well TMW-5 was only analyzed for metals. Because of this, we do not have
adequate control to limit the vapor intrusion restriction. To reconcile this issue, I present
the following two options:
1.       Include a site-wide LUR for vapor intrusion in the Brownfields Agreement (BFA)
pertaining to building construction on either parcel.
2.       Prepare a work plan for additional assessment to demonstrate that vapor intrusion
is not an issue on a portion of the property. This would include re-installing
monitoring wells TMW-4 and TMW-5 and installing a 3rd monitoring well between
wells TMW-4 and TMW-5 and the impacted wells on the 320 E Franklin St parcel
(see attached figure) to be sampled for VOCs and SVOCs by EPA Methods 8260 and
8270. Monitoring wells should be installed and developed in accordance with the US
EPA Region 4 SESD Guidance Document for the Design and Installation of
Monitoring Wells (Jan, 2013) and sampled in accordance with the most recent NC
DEQ IHSB Guidelines for Assessment and Cleanup. This would potentially allow us
to issue a compliance letter that a vapor assessment for building construction to a
specified area of the property is not necessary. See the attached example letter.
·         Carolyn and I reviewed the Environmental Management Plan dated 10/25/2018 and the
new data from the Soil Sampling Report dated 5/15/2019 and have confirmed that the EMP
will not need to be updated to manage for soil management at the site;
Land Use Definitions in the Brownfields Agreement will include: office, parking,
governmental, institutional, restaurant, retail, hotel, industrial, open space and, with prior written
DEQ approval, other commercial uses.
·         Update Survey Plat. The Plat included in the Brownfields Property Application dated
3/14/2017 (attached) shows only the boundary for the 320 E Franklin St parcel although a
legal description was provided for both parcels;
·         A Brownfields Receptor Survey referenced in the EMP will need to be completed. Has it
been completed yet? I have attached a blank one in case it is needed.

I will begin drafting the Brownfields Agreement and associated documents soon. Please let me know
if you have any questions or concerns.

Best,