24034_CullmanAveProperties_Request for Additional Assessment Letter_10.05.2020

October 5, 2020
Clarke Allen
Clarke Allen Properties 3144 Cullman Avenue Charlotte, NC 28206 [e-mail]

Subject: Additional Assessment Request
Cullman Avenue Properties 3144 & 3162 Cullman Avenue Charlotte, Mecklenburg County Brownfields Project Number 24034-20-060
Dear Mr. Allen, The North Carolina Department of Environmental Quality (DEQ) Brownfields Program has reviewed the documents submitted with the Brownfields Property Application for the Cullman Avenue property located
at 3144 and 3162 Cullman Avenue in Charlotte, Mecklenburg County. The following is a summary of the reports reviewed:
Report Title Author Date
Addendum to DRAFT Phase II RCRA Facility
Investigation Interim Report - Detrex Facility
Amec Environment &
Infrastructure, Inc.
April 5, 2013
Phase III RCRA Facility Investigation Report Withers & Ravenel, Inc. November 12,
2015
Results of Follow Up Indoor Air and Outdoor
Ambient Air Analyses & Additional Soil and Cinder Block Analyses
Withers & Ravenel, Inc. February 29, 2016
Results of May 2016 Indoor and Outdoor Air Analyses Withers & Ravenel, Inc. June 3, 2016
Results of August 2016 Indoor and Outdoor Air
Analyses
Withers & Ravenel, Inc. September 16,
2016
Results of February 2017 Indoor and Outdoor
Air Analyses
Withers & Ravenel, Inc. February 23, 2017
Results of February 2019 Indoor and Outdoor
Air Analyses
Withers & Ravenel, Inc. February 22, 2019
Results of July 2019 Indoor and Outdoor Air
Analyses
Withers & Ravenel, Inc August 15, 2019

Cullman Avenue Properties October 5, 2020 Page 2

Phase I Environmental Site Assessment –
Cullman Avenue Properties (3144 & 3162)
ECS Southeast, LLP November 18,
2019
Results of January 2020 Indoor and Outdoor Air
Analyses
Withers & Ravenel, Inc. February 11, 2020
Results of September 2020 Indoor and Outdoor
Air Analyses
Withers & Ravenel, Inc. September 17,
2020

Based on our review of these documents and information garnered from adjacent properties and other
DEQ programs, data gaps were identified. Additional assessment activities, as outlined below, are required to assist in making risk management decisions for inclusion in the Brownfields Agreement (BFA).
The following areas of the Brownfields Property will require additional assessment. Prior to conducting field activities, a work plan should be submitted to DEQ for review and approval. The work plan should include a description of the sampling and analytical methods to be utilized and a map depicting the proposed
sample locations. The November 2018 DEQ Brownfields Assessment Work Plan Checklist (attached), the most recent Inactive Hazardous Sites Program (IHSB) Guidelines for Assessment and Cleanup (http://portal.ncdenr.org/web/wm/sf/ihs/ihsguide), and the DEQ DWM Vapor Intrusion Guidance (https://deq.nc.gov/about/divisions/waste-management/waste-management-permit-guidance/dwm-vapor-intrusion-guidance) should be followed. Request Level 2 QA/QC data packages from a N.C. certified
environmental laboratory. Collect one duplicate sample for all analysis per every 5% of samples for each environmental media sampled. 1) Groundwater Sampling: Install a total of two groundwater monitoring wells in the southern and
northern portions of the property located at 3162 Cullman Avenue as depicted in the attached figure. Monitoring wells should be constructed and developed in accordance with the US EPA Region 4 Science and Ecosystem Support Division (SESD) Guidance for the Design and Installation of Monitoring Wells (January, 2013). Following well development, monitoring wells should be sampled
for VOCs by EPA Method 8260, SVOCs by EPA Method 8270, and Resource Conservation and Recovery Act (RCRA) Metals by EPA Method 6020. 2) Sub-Slab/Soil-Gas Sampling: Collect a minimum of five sub-slab soil gas samples from within the site building at 3162 Cullman Avenue at the locations outlined on the attached figure. Analyze all sub-slab
soil-gas samples for VOCs by EPA Method TO-15. 3) Soil Sampling:

a. 3144 Cullman Ave.: In order to assess the soil impacts from the contamination associated with the neighboring Detrex Facility (DEQ Hazardous Waste Project: NCD049773245), collect six surficial soil samples from the 0-2 feet below ground
surface (ft BGS) depth interval at the locations presented in the following figure. Samples should be analyzed for VOCs by EPA Method 8260, SVOCs by EPA Method
8270, and Resource Conservation and Recovery Act (RCRA) Metals by EPA Method 6020. An additional sample aliquot should be held by the laboratory for potential hexavalent chromium analysis via EPA method 7199.
b. 3162 Cullman Ave.: Collect one surficial soil sample (0-2 ft BGS) from each of the two
monitoring well locations referenced above. If impacts are observed within deeper intervals based on visual, olfactory, or PID observations, collect additional samples as
needed from the impacted intervals. Samples should be analyzed for VOCs by EPA Method 8260, SVOCs by EPA Method 8270, and Resource Conservation and Recovery

Cullman Avenue Properties October 5, 2020 Page 3

Act (RCRA) Metals by EPA Method 6020. An additional sample aliquot should be held by the laboratory for potential hexavalent chromium analysis via EPA method 7199.
4) Receptor Survey: Complete the enclosed Brownfields Property receptor survey and include as an attachment to the additional Assessment Report.
Report and Figures: Upon receipt of analytical data, submit a summary report with a description of field activities, tabulated data in comparison to applicable screening levels, and the laboratory data packet with applicable QA/QC documentation, provide a site plan with well locations, locations of sample points, and current site structures. Provide concentration maps for contaminants detected above applicable standards. Include a detailed description of current operations since the Brownfields Property application was
submitted. Please note, all sample points may need to be included on the future Brownfields plat. DEQ recommends having sample locations surveyed at the time of collection for use in preparation of the Brownfields plat.
Please provide the Work Plan for additional assessment activities as soon as you are able. If you have questions about this correspondence or require additional information, please feel free to contact me by email at [e-mail].
Sincerely,
Cody J. Cannon, P.G.
Brownfields Project Manager ec: Chris Walker, Alexander Ricks Laura Truesdale, Alexander Ricks Bo Cappleman, P.G., Hart & Hickman, PC
Tracy Wahl, DEQ
SITE LAYOUT WITH CROSS SECTION LINESDETREX - CULLMAN AVENUECHARLOTTE, NORTH CAROLINA0100200300400Feet
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±Source: USGS High Resolution Orthoimagery for the Charlotte, NC Urban Area, dated February, 2012.
PREPAREDBY DATE CHECKEDBY DATE JOB NUMBER FIGURE 26228-07-4329SJMAMC3/6/13 3/6/13
Project Site
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