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HomeMy WebLinkAbout24052 Doggett St Brownfield Work Plan Revised Final 20210611 P R O F E S S I O N A L | P R A C T I C A L | P R O V E N 714 Minuet Lane, Suite D, Charlotte, North Carolina 28273 NOVA North Carolina License No: C -2807 t. 980.321.4100 / f. 980.321.4099 / usanova.com June 11, 2021 NORTH CAROLINA DEPARTMENT OF ENVIRONMENTAL QUALITY DIVISION OF WASTE MANAGEMENT - BROWNFIELDS PROGRAM Mail Services Center 1646 Raleigh, North Carolina 27699-1646 Attention: Mr. William Schmithorst Project Manager, DWM Brownfields Program Subject: Environmental Site Assessment Work Plan DOGGETT STREET & WEST TREMONT AVENUE SITE Charlotte, North Carolina NOVA Project Number 3021011.1 Dear Mr. Schmithorst: NOVA Engineering and Environmental, Inc. (NOVA) has completed the Environmental Site Assessment Work Plan (Work Plan) for the Doggett Street & West Tremont Avenue Site Brownfield Property located in Charlotte, Mecklenburg County, North Carolina. This Work Plan was developed using the Environmental Site Assessment Work Plan Minimum Requirements Checklist from the North Carolina Department of Environmental Quality (NCDEQ) Brownfields Program dated November 2018. This Work Plan presents our understanding of the project information, a description of the environmental services proposed by NOVA, and our understanding of directives from NCDEQ. If you have any questions, or if we may be of further assistance, please do not hesitate to contact us. Sincerely, NOVA Engineering and Environmental, Inc. Steven M Aldis, RSM, PG Keith Rice Project Manager Senior Geologist TABLE OF CONTENTS 1.0 INTRODUCTION ................................................................................................................... 1 1.1 SITE AND PROJECT INFORMATION .............................................................................................. 1 1.2 HISTORICAL SUMMARY OF SITE ACTIVITIES................................................................................ 2 1.3 DATA GAPS .................................................................................................................................... 9 2.0 SCOPE OF WORK .............................................................................................................. 10 2.1 SOIL SAMPLING ......................................................................................................................... 10 2.2 GROUNDWATER SAMPLING ...................................................................................................... 11 2.3 SOIL GAS AND SUB-SLAB SAMPLING ....................................................................................... 11 3.0 SAMPLING METHODOLOGY ............................................................................................. 13 3.1 SOIL SAMPLING ......................................................................................................................... 13 3.2 GROUNDWATER SAMPLING ...................................................................................................... 13 3.3 SOIL GAS AND SUB-SLAB SOIL VAPOR SAMPLING .................................................................. 14 4.0 LABORATORY ANALYSIS .................................................................................................. 15 4.1 SOIL ANALYSIS........................................................................................................................... 15 4.2 GROUNDWATER ANALYSIS ....................................................................................................... 15 4.3 SOIL GAS AND SUB-SLAB ANALYSIS ......................................................................................... 15 5.0 QUALITY ASURANCE / QUALITY CONTROL ...................................................................... 16 6.0 INVESTIGATION DERIVED WASTE (IDW) MANAGEMENT ............................................... 17 7.0 RECEPTOR SURVEY .......................................................................................................... 18 8.0 REPORTING....................................................................................................................... 19 ATTACHMENTS FIGURE 1 – SITE LOCATION MAP FIGURE 2 – SITE MAP FIGURE 3 – PROPOSED DEVELOPMENT NC BROWNFIELDS RECEPTOR SURVEY FORM Environmental Site Assessment Work Plan June 11, 2021 Doggett Street/West Tremont Avenue Site NOVA Project Number 3021011.1 Page 1 1.0 INTRODUCTION NOVA Engineering and Environmental, Inc. (NOVA) was retained by Cousins Tremont Doggett, LP (Client) to complete an Environmental Site Assessment Work Plan (Work Plan) on the Doggett Street & West Tremont Avenue Site located in Charlotte, Mecklenburg County, North Carolina (Subject Property). A site location map is included as Figure 1 in the Attachments. 1.1 SITE AND PROJECT INFORMATION The Subject Property is located at 305 Doggett Street and 242/306 West Tremont Avenue in Charlotte, Mecklenburg County, North Carolina. According to the Mecklenburg County Geographic Information System (GIS) database, the Subject Property measures approximately 2.441-acres and contains three (3) tax parcels identified by Parcel Numbers 12103314 (305 Doggett Street), 12103307 (242 West Tremont Avenue) and 12103306 (306 West Tremont Avenue). The Subject Property is bordered by Doggett Street on the north, West Tremont Avenue on the south, an unnamed alley on the west, and by other developed properties to the east. A Site Map including an aerial photograph is included as Figures 2 in the Attachments. The Subject Property is currently developed with following structures: 305 Doggett Street – This address contains three (3) buildings according to property tax records. • Building 1: 1-story warehouse building including 10,200 total square feet, built in 1954; • Building 2: 2-story light-manufacturing building including 27,024 total square feet, built in 1963; and, • Building 3: 1-story warehouse building including 600 total square feet, built in 1981. 306 West Tremont Ave – This address contains one (1) 2-story warehouse building including 11,644 total square feet, built in 1964. The structure is attached to a 2-story office building with canopy structures located between and is referred to as the “accounting” building. 242 West Tremont Ave – This address contains one (1) 1-story light manufacturing building including 10,370 total square feet, built in 1950. This building is referred to as the “Dilworth” building and is divided into the air heater production line with two loading bays in the western portion with warehouse storage in the eastern portion. The Subject Property contains associated asphalt-paved parking to the north, east and south of the office and manufacturing structures. The site also contains greenspace including trees, grass, and low-growing vegetation. Environmental Site Assessment Work Plan June 11, 2021 Doggett Street/West Tremont Avenue Site NOVA Project Number 3021011.1 Page 2 1.2 HISTORICAL SUMMARY OF SITE ACTIVITIES The Subject Property is located on the southwest side of Charlotte, North Carolina. The area was historically agricultural and residential prior to converting into a commercial and industrial area. NOVA has reviewed most readily available historical documents which indicate that the Subject Property was first developed with commercial and industrial facilities in the late 1940s. Prior to the current buildings the Subject Property was primarily vacant between the 1890s and 1940s. A review of Sanborn® maps indicates the Subject Property was utilized for tobacco curing and mattress manufacturing in 1953 and 1963. A Phase I Limited Site Assessment Report, conducted by Altura Environmental, Inc. (Altura), on Gas-Fired Products, Inc., at 306 West Tremont Avenue, Charlotte, North Carolina was conducted on October 6, 2003. The document indicated that the Phase I Limited Site Assessment (LSA) was performed in accordance with NCDENR (Former name for NCDEQ) guidance. Additional site history was provided in the LSA and stated that “the subject property was formerly occupied by J.B. Thomas and Sons, a general contracting firm, in the late 1940’s and early 1950’s. It is believed that the former UST was installed by J.B. Thomas and Sons, and the last use of the UST was during that time. There are no other USTs reported to be present on the subject site.” On August 22, 2003, Altura was onsite to drill one (1) soil boring, collect soil samples, install one (1) groundwater monitoring well and collect a groundwater sample from said well. Soil samples were collected at depths of -13’, -17’ and -22’ below ground surface (bgs) from the soil boring drilled within the UST source area. Partially weathered rock was encountered at -24’ below ground surface. The soil samples were analyzed for Volatile Organic Constituents (VOCs), Methyl tert-Butyl Ether (MTBE), Isopropyl Ether (IPE), Semi-VOCs (SVOCs), volatile petroleum hydrocarbons and extractable petroleum hydrocarbons in accordance with NCDENR guidelines. The analytical results of soil samples collected in the source area during the Phase I LSA indicated that no petroleum constituents were detected at concentrations in excess of NCDENR soil to groundwater maximum soil contaminant concentrations, which are the most stringent limits established by NCDENR. A groundwater monitoring well was installed with slotted screening from 19 to 24 feet bgs as groundwater was recorded at approximately 18.5 feet. The groundwater sample was analyzed in accordance with NCDENR guidelines for heating oil and included EPA Method 602 plus xylenes, EPA Method 625, and volatile petroleum and extractable petroleum hydrocarbons by MADEP VPH and EPH, respectively. The groundwater laboratory analysis indicated that several petroleum constituents were detected in the groundwater at concentrations in excess of the 2L or interim Standard and in excess of 10x the 2L or Interim standard. However, none of the concentrations were detected in excess of the listed Gross Contaminant Levels (GCLs). Environmental Site Assessment Work Plan June 11, 2021 Doggett Street/West Tremont Avenue Site NOVA Project Number 3021011.1 Page 3 Based on the findings of the LSA, Altura recommended that “based on the land use information provided in this report for the subject site and surrounding properties, it is the opinion of Altura that the property be designated an industrial/commercial property. All petroleum constituents identified in the soil samples collected from the source area boring were detected at concentrations below the NCDENR soil to groundwater maximum soil concentrations values. In addition, the analytical results of the groundwater sample collected from monitoring well MW-1 indicate that none of the required parameters were detected at concentrations in excess of the listed GCLs. As a results, a Notice of Residual Petroleum (NRP) has been completed for the subject site and recorded at the Mecklenburg County Register of Deeds Office…Altura requests that the NCDENR issue a “No Further Action” letter for the subject site.” A UST Closure and Assessment Report was conducted by Altura for Gas-Fired Products, Inc., dated December 8, 2003. The UST closure report indicated that NCDENR provided closure for UST release incident pending recordation of a Notice of Residual Petroleum (NRP) at the Mecklenburg County Register of Deeds Office. The NRP placed a perpetual land use restriction on the property. Due to the soil impact above the residential MSCCs, the perpetual land use restriction states that, “the site shall be used for industrial/commercial use only. The perpetual land use restriction, as it pertains to the groundwater, states that, “groundwater from the site is prohibited from use as a water supply. Water supply wells of any kind shall not be installed or operated on the site.” Altura stated that, based on conversations with NCDENR, if impacted soils are removed from the site such that confirmatory soil sampling indicated petroleum concentrations are below the residential MSCCs, then the perpetual land use restriction pertaining to the site soils can be removed from the deed restriction. In Altura’s opinion “if the site building was razed providing easy access to subsurface soils, that the impacted soils could be removed from the former UST area, confirmatory soil samples could be collected (showing results that are below the residential MSCCs), and the soil restriction could be removed from the property deed. Hart & Hickman, PC (H&H) performed soil vapor assessment activities documented in a Subslab Soil Vapor Sampling Report for Gas Fired Products Facility dated February 18, 2013. The subslab soil vapor sampling was conducted to evaluate the potential for vapor intrusion into site buildings consistent with Brownfields program requirements should the site enter the Brownfields program in the future. On November 8, 2012, H&H conducted subslab soil vapor sampling from six (6) locations within the manufacturing, office and warehouse areas of the Subject Property. H&H utilized six-liter Summa canisters to collect the vapor samples as they were submitted for laboratory analysis for volatile organic compounds (VOCs) by EPA Method TO-15 and for helium by EPA Method 3C. Environmental Site Assessment Work Plan June 11, 2021 Doggett Street/West Tremont Avenue Site NOVA Project Number 3021011.1 Page 4 H&H stated “Low concentrations of multiple VOCs were detected in the six samples collected. The concentrations were compared to NCDENR Inactive Hazardous Sites Branch (IHSB) Industrial/Commercial Soil Vapor Screening Levels. The ISHB screening levels are based upon conservative assumptions. None of the detected compound concentrations exceeded their IHSB Industrial/Commercial Soil Vapor Screening Levels. In accordance with DENR Brownfields program guidance and H&H’s professional experience with the Brownfields program, because the subslab soil vapor samples concentrations were less than the applicable screening levels, H&H does not recommend further evaluation of the vapor intrusion pathway such as indoor air sampling or indoor air mitigation.” H&H performed a Phase I ESA Report for Dilworth Mattress Factory, 242 West Tremont Avenue, Charlotte North Carolina, dated June 29, 2016. The Phase I ESA indicated that the 0.43-acre land parcel was occupied by Dilworth Mattress Factory, a mattress manufacturer, at the time of the Phase I ESA. The site was developed with the eastern portion of the current site building in 1950 as the western portion of the site building was developed in 1984. The site has reportedly operated as a mattress manufacturer since it was constructed in 1950. H&H identified the following off-site issues resulting in Recognized Environmental Conditions (RECs) in connection with the Subject Property: • “Virginia Carolina Chemical (VCC) Charlotte (249 Tremont Avenue) is located adjacent to the south and southwest across Tremont Avenue and upgradient to cross-gradient from the site. According to reports reviewed, this facility formerly operated as a phosphate fertilizer plant from at least the 1890s until the 1930s. An adjacent plant to the east also operated as a cottonseed oil plant. The facility occupied the property until 1974 at which time the current commercial and light industrial buildings were developed. Soil at the facility is impacted by arsenic and lead as a result of the former activities and ExxonMobil is identified as the responsible party for the cleanup. ExxonMobil has removed source area soil from feasible locations at the facility and currently maintains a cap on the property. Results of soil assessment indicated that metals were not detected above screening levels in the samples located closest to the subject site and therefore the potential for soil impact to the site from the VCC facility appears low. Recent groundwater sampling events indicate the presence of low levels of lead, arsenic, tetrachloroethene (PCE), and trichloroethene (TCE) in groundwater at this facility above NC groundwater standards in monitoring wells located close to the site. Concentrations of PCE (0.91 micrograms per liter (μg/l) versus standard of 0.7 μg/l) and TCE (4.2 μg/l versus standard of 3 μg/l) were detected in the wells closest to the site.” Environmental Site Assessment Work Plan June 11, 2021 Doggett Street/West Tremont Avenue Site NOVA Project Number 3021011.1 Page 5 • “South Boulevard Properties, Inc./Atherton Mill Property/Flakt Inc. Bahnson/Parks- Cramer Company (2000-2140 South Boulevard) is located approximately 1,200 feet to the east and topographically upgradient of the site. According to records reviewed, in 1962, the Parks-Cramer facility began to operate a vapor degreasing unit for cleaning and preparation of metal parts prior to paint application in the main Parks-Cramer building north of the site. Initially trichloroethene (TCE) was used as the solvent in the degreasing process, which was replaced with 1,1,1,- trichloroethane (1,1,1-TCA) from 1976 to 1988. Releases of solvents occurred beneath the vapor degreaser and discharged through a stormwater system to the adjacent Norfolk Southern railroad tracks west of the parent parcel. Releases of volatile organic compounds also occurred through spraying of waste solvents for weed control along an earthen embankment from 1962 to 1979. Results of groundwater assessment indicate that groundwater impacts (TCE was detected as high as 200,000 μg/l at this property) have migrated to the west-northwest toward downgradient properties including the subject site. Results of analysis of groundwater samples collected approximately 400 ft southeast and upgradient of the site indicated the presence of TCE at greater than 5,000 μg/l. Interim soil remediation was conducted in the late 1980s, and groundwater remediation using a pump and treat system occurred from 1990 to 2001. The North Carolina Department of Environmental Quality (DEQ) Hazardous Waste Section (HWS) formerly regulated the Parks-Cramer release incident. On January 19, 2006, the HWS ceased regulation pursuant to a risk assessment and technical impracticability determination. The determination was primarily based on: 1) the inability to continue groundwater extraction due to a county-wide moratorium on discharge of treated groundwater to the sanitary system, 2) the inadequacy of available technologies to address removal or in situ destruction of chlorinated volatile organic compounds present as dense non-aqueous phase liquids in bedrock, 3) the adoption of a county-wide well ordinance to ensure receptor protection, 4) the lack of predicted impact to the ultimate surface water receptors, and 5) the costs associated with continuation of remedial efforts. This facility is cited as the source area for chlorinated solvent impacts to the groundwater in the area near the site. In addition, according to groundwater model predictions of the chlorinated solvent groundwater contamination plume, the subject site is predicted to be impacted from the release at this facility.” • “2000 Hawkins Street (2000 Hawkins Street) is located approximately 350 feet to the east and topographically cross-gradient of the site. According to the reports reviewed, the groundwater samples collected from the wells on the property indicated the presence of chlorinated solvent compounds, phthalates, methyl-tert- butyl ether (MTBE), and benzene in groundwater above North Carolina groundwater standards. The highest compound concentrations were detected in the upgradient sample in the eastern portion of the facility which had a concentration of the Environmental Site Assessment Work Plan June 11, 2021 Doggett Street/West Tremont Avenue Site NOVA Project Number 3021011.1 Page 6 chlorinated solvent TCE at 6,200 μg/l (versus the NC groundwater standard of 3 μg/l). The sample collected closest to the subject site contained TCE at a concentration of 41 μg/l.” H&H identified a potential environmental concern in connection with the Subject Property as a heating oil AST was observed on the northern exterior wall of the western portion of the site building. The AST is no longer utilized. No indications of releases were observed in associate with the AST. H&H did not consider it to be evidence of a REC. No recommendations were noted in the Phase I ESA. NOVA Engineering & Environmental, Inc. performed a Phase I ESA for the Doggett Street & West Tremont Avenue Site dated September 17, 2020. NOVA identified the following on-site issue resulting in Recognized Environmental Conditions (RECs) in connection with the Subject Property: • The impacts to soil and groundwater identified above applicable regulatory thresholds during NOVA’s 2020 Limited Phase II ESA. Additionally, NOVA identified the following on-site and off-site issues resulting in Controlled Recognized Environmental Conditions (CRECs) in connection with the Subject Property: ON-SITE • The former presence of a 300-gallon heating oil UST and associated residual petroleum at the Subject Property. OFF-SITE • The Carolina Foundry facility located adjoining to the east and south of the Subject Property. • The Kale Bindex, Inc/2000 Hawkins Street facility located adjoining to the east of the Subject Property. • The Virginia Carolina Chemical (VCC)/ExxonMobil Oil Corp 99CLT facility located adjoining to the south of the Subject Property. NOVA Engineering & Environmental, Inc. performed a Limited Phase II ESA for the Doggett Street & West Tremont Avenue Site dated September 17, 2020. The following is a summary of the findings of NOVA’s Limited Phase II ESA: Environmental Site Assessment Work Plan June 11, 2021 Doggett Street/West Tremont Avenue Site NOVA Project Number 3021011.1 Page 7 VOC CONSTITUENTS IN SOIL Bromomethane, Chloromethane, and Naphthalene were detected in a soil sample collected on the northeastern portion of the Subject Property (S-2) at concentrations above their NC DEQ Protection of Groundwater PSRGs. Naphthalene was detected in soil sample S-2 at a concentration above its residential PSRG. The remaining VOC constituents detected in soil were at concentrations below NC DEQ Preliminary Soil Remediation Goals (PSRGs). SVOC CONSTITUENTS IN SOIL 1-Methylnaphthalene, 2-Methylnaphthalene, Benzo(a)anthracene, Benzo(a)pyrene, Benzo(b)fluoranthene, Dibenzo(a,h)anthracene, Indeno(1,2,3-cd)pyrene, and Naphthalene were detected in soil sample S-2 at concentrations above their NC DEQ Protection of Groundwater PSRGs. Benzo(a)anthracene, Benzo(a)pyrene, Benzo(b)fluoranthene, Dibenzo(a,h)anthracene, Indeno(1,2,3-cd)pyrene, and Naphthalene were detected in soil sample S-2 at concentrations above their residential PSRGs. Benzo(a)pyrene was detected in soil sample S-2 at a concentration above its industrial/commercial PSRG. The remaining SVOC constituents detected in soil were at concentrations below NC DEQ PSRGs. METALS CONSTITUENTS IN SOIL Arsenic was detected in the five (5) soil samples collected on the northeastern portion of the Subject Property (S-1 through S-5) at concentrations above the NC DEQ residential PSRG of 0.68 mg/kg and the NC DEQ industrial/commercial PSRG of 3.0 mg/kg. However, the detected concentrations of Arsenic are below the mean concentration reported to be naturally occurring in the eastern conterminous United States based on the observed background concentrations in Element Concentrations in Soils and Other Surface Materials of the Conterminous United States, Hansford T. Shacklette and Josephine G. Boerngen, United States Geological Survey, 1984. Total Chromium was detected in soil samples S-1 through S-5 at concentrations above the most stringent NC DEQ PSRGs for Hexavalent Chromium. However, there have been no known or suspected historical source of Hexavalent Chromium at the Subject Property. Consequently, the less stringent Trivalent Chromium PSRGs have been used for the purposes of this report. Environmental Site Assessment Work Plan June 11, 2021 Doggett Street/West Tremont Avenue Site NOVA Project Number 3021011.1 Page 8 The remaining detections of metals in soil were at concentrations below the NC DEQ PRSGs. VOC CONSTITUENTS IN GROUNDWATER Naphthalene, Tetrachloroethylene (PCE) and Trichloroethylene (TCE) were detected in a groundwater sample collected on the northeastern portion of the Subject Property (S-2) above their NC DEQ 15A NCAC 02L .0202 Groundwater Standards. The remaining VOC constituents detected in groundwater were at concentrations below NC DEQ 15A NCAC 02L .0202 Groundwater Standards. SVOC CONSTITUENTS IN GROUNDWATER The SVOC constituents detected in groundwater were at concentrations below NC DEQ 15A NCAC 02L .0202 Groundwater Standards. METALS CONSTTIUENTS IN GROUNDWATER The Chromium detected in groundwater sample collected on the southwestern portion of the Subject Property (S-4) was at a concentration above its NC DEQ 15A NCAC 02L .0202 Groundwater Standard. The remaining metals constituents detected in groundwater were at concentrations below NC DEQ 15A NCAC 02L .0202 Groundwater Standards. Chromium occur naturally in Piedmont geology soils. Consequently, NOVA believes that the concentrations of metals detected in the groundwater are likely associated with excess sediment/background concentrations in the collected groundwater and are not due to the historic operations on the Subject Property. Based on the findings of the previous assessments and NOVA’s Phase I and Limited Phase II ESAs, the Subject Property was entered into the NC DEQ Brownfields Programs via a Brownfields Property Application dated September 17, 2020 and an amended Brownfields Property Application dated January 18, 2021. As part of the Brownfields Application process, Hart & Hickman, PC (H&H), on behalf of the seller of the Subject Property, Gas-Fired Products, Inc., submitted a Site Operations Plan (SOP)-Revision 1 dated December 10, 2020 to the NCDEQ Brownfields Program. In the SOP, H&H provided details of the chemicals used at the Subject Property. Gas Fired Products, Inc. is continuing operations at the Subject Property after Cousins Tremont Doggett, LP take possession of the Subject Property. As such, the NC DEQ Environmental Site Assessment Work Plan June 11, 2021 Doggett Street/West Tremont Avenue Site NOVA Project Number 3021011.1 Page 9 Brownfield Program has indicated that chemical usage by Gas Fired Products, Inc. will need to be discontinued and no storage of chemicals is to be allowed at the Subject Property. The NC DEQ has requested that Compliance Audits be completed on a quarterly basis to assess Gas Fired Products, Inc’s adherence to the SOP. NOVA understands that NC DEQ has requested additional assessment of soil, groundwater and soil gas at the Subject Property. 1.3 DATA GAPS NOVA’s Work Plan is designed to assess the current conditions at the Subject Property. Currently, NOVA and NC DEQ has identified three (3) main areas of concern, including the former underground storage tank (UST) area, the former paint shed/booth area and groundwater impacts. Additionally, the Work Plan intends to assess the subsurface conditions at the Subject Property in relation to the planned mixed use redevelopment, including commercial, retail, and residential space. NOVA has developed this Work Plan to assess soil, groundwater, and soil gas conditions at the Subject Property in previously unassessed areas. NOVA will collect soil and groundwater from the former UST location, around the location of the former paint shed/booth and groundwater from the northeastern portion of the Subject Property. NOVA will also collect soil gas samples for VOC analysis from around the property, including at locations with potential source materials as well as in locations where future occupied surface level tenant space could be located. The soil gas data can be used to assess the potential for vapor intrusion to impact future tenants and residents at the Subject Property. Environmental Site Assessment Work Plan June 11, 2021 Doggett Street/West Tremont Avenue Site NOVA Project Number 3021011.1 Page 10 2.0 SCOPE OF WORK Prior to beginning field activities, NOVA will contact the State Utility Protection Center, as required by law. Due to the tight site conditions, potential for unmarked utilities and the various ages/unknown construction history of the Subject Property, NOVA will arrange for a private utility locate service to mark the utilities at the specific boring locations. Please note that marking utilities across the entire site is not included in NOVA’s work scope. The Client is ultimately responsible for utility location, clearance and damage, if incurred. With the introduction of smaller and non-metallic subsurface utilities, utility location is becoming increasingly difficult. NOVA will attempt to identify and clear utilities prior to advancing borings. NOVA will be completing site activities throughout the Subject Property. Soil and/or groundwater sampling activities will be conducted within three (3) primary locations: the former UST location, the former paint shed/booth location, and the northwestern portion of the Subject Property. Soil gas sampling will be located throughout the Subject Property generally within the foot print for the proposed development buildings. A Site Map is provided as Figure 2 in the Attachments identifying the sampling locations. 2.1 SOIL SAMPLING Based on information collected during previous assessments, NOVA proposes collecting soil samples from four (4) soil borings (S-6 through S-9) at the Subject Property to assess subsurface conditions. Three (3) soil borings will be located in the area of the former UST. One (1) soil boring will be located in the area of the former paint shed/booth. A Site Map is provided as Figure 2 in the Attachments. Soil samples will be collected at a depth of two (2) feet and then at five-foot intervals to a maximum depth of forty (40) feet bgs from each of the four (4) soil. Soil will be sampled for classification and will be field screened for organic vapors using a Photo-Ionization Detector (PID). Soil samples will be submitted for analysis based on field screening and/or visual observations that indicate impacted soil. If field screening and/or visual observations do not indicate impacted soil, one (1) soil sample from the deepest portion of the unsaturated zone of each boring will be submitted to an appropriately accredited laboratory for the following analyses: • Volatile Organic Compounds (VOCs) by United States Environmental Protection Agency (US EPA) Solid Waste (SW)-846 Method 8260, • Semi-Volatile Organic Compounds (SVOCs) by USEPA SW-846 Method 8270, and • Resource Conservation and Recovery Act (RCRA) Metals by USEPA SW-846 Method 6010 and 7473. Environmental Site Assessment Work Plan June 11, 2021 Doggett Street/West Tremont Avenue Site NOVA Project Number 3021011.1 Page 11 2.2 GROUNDWATER SAMPLING Four (4) temporary groundwater monitoring wells will be installed at the Subject Property. The temporary groundwater monitoring wells will be installed using either a direct push or auger technology drill rig to the desired depth. The temporary groundwater monitoring wells will be installed by a North Carolina certified well driller. One (1) temporary groundwater monitoring well will be located in the area of the former UST, one (1) temporary groundwater monitoring well will be located in the area of the former paint shed/booth, one (1) temporary groundwater monitoring well will be located on the northeast side of the Subject Property, and one (1) temporary groundwater monitoring well will be located in the northwestern portion of the Subject Property. The temporary groundwater monitoring wells will be installed and abandoned in accordance with local and state governmental requirements. A Site Map is provided as Figure 2 in the Attachments. Prior to conducting groundwater sampling activities, NOVA will develop the four (4) newly constructed temporary groundwater monitoring wells. The wells will be developed by purging approximately three (3) to five (5) well volumes or until turbidity is reduced below 10 NTUs. NOVA will collect groundwater quality parameters (pH, temperature, ORP, DO, turbidity and conductivity) after each purge volume. Once water is allowed to recharge, groundwater samples will be obtained for the following laboratory analyses: • VOCs by USEPA SW-846 Method 8260, • SVOCs by USEPA SW-846 Method 8270, and • RCRA Metals by SW-846 Methods 6010/7470. 2.3 SOIL GAS AND SUB-SLAB SAMPLING Six (6) soil gas monitoring points and one (1) sub-slab soil gas monitoring point (SV-1 through SV-7) will be constructed on the Subject Property. The soil gas monitoring points will be hand augured to a minimum depth of greater than five (5) feet bgs. Following the advancement of each soil gas sampling point, a length of 0.250-inch Interior Diameter (ID) flexible nylon tubing equipped with a particulate filter will be inserted into the sampling point. The soil gas monitoring points will then filled with approximately four (4) inches of industrial quartz sand. The remaining portion of the sampling points will be filled with granular bentonite in three (3) inch increments and hydrated with water to create an airtight seal between the sampling point and the atmosphere. The sub-slab soil gas monitoring point will be advanced six (6) inches below the building slab. The sub-slab monitoring point will then filled with approximately three (3) Environmental Site Assessment Work Plan June 11, 2021 Doggett Street/West Tremont Avenue Site NOVA Project Number 3021011.1 Page 12 inches of industrial quartz sand. The remaining portion of the sampling points will be filled with granular bentonite for three (3) inch and hydrated with water to create an airtight seal between the sampling point and the atmosphere. Collected soil gas and sub-slab soil gas samples will be submitted to an appropriately accredited laboratory for the following analyses: • Volatile Organic Compounds (VOCs) by United States Environmental Protection Agency (US EPA) Method TO-15. Environmental Site Assessment Work Plan June 11, 2021 Doggett Street/West Tremont Avenue Site NOVA Project Number 3021011.1 Page 13 3.0 SAMPLING METHODOLOGY Field procedures and protocols used during this assessment will be performed in general accordance with those prescribed in ASTM International (ASTM) Standard Practice for Environmental Site Assessments: Phase II Environmental Site Assessment Process, Designation: E1903-19, USEPA Region IV Science and Ecosystem Support Division (SESD) guideline document LSASDPROC-300-R4 dated June 11, 2020 for soil sampling, guideline document SESDPROC-301-R4 dated April 26, 2017 for groundwater sampling, the North Carolina Division of Waste Management (DWM) Inactive Hazardous Sites Branch (IHSB) Program’s Guidelines for Assessment and Cleanup of Contaminated Sites dated January 2020 Version 2, and the North Carolina Department of Environmental Quality (NC DEQ) Division of Waste Management (DWM) Vapor Intrusion Guidance document dated March 2018 for soil vapor sampling. 3.1 SOIL SAMPLING Soil samples will be collected utilizing direct push or auger technology at a depth of two (2) feet and then at five-foot intervals to a maximum depth of thirty (30) feet bgs from each of the four (4) soil borings (S-6 through S-9). The soils will be collected using either a 1.5-inch dual tube sampling liner or a 2-inch split spoon sampler. Soil will be sampled for classification and will be field screened for organic vapors using a Photo-Ionization Detector (PID). Soil samples will be submitted for analysis based on field screening and/or visual observations that indicate impacted soil. If field screening and/or visual observations do not indicate impacted soil, one (1) soil sample from the deepest portion of the unsaturated zone of each boring will be submitted to an appropriately accredited laboratory for analysis. During soil collection activities either new 1.5-inch dual tube sampling liner will be used for each sampling interval or 2-inch split spoon samplers will be thoroughly decontaminated between each sampling interval using a non-environmentally impacting detergent, deionized water and isopropyl alcohol. Soil samples will be collected in laboratory-provided sampling containers and placed on ice for transport to the laboratory. The samples will be kept on ice for transport to an accredited laboratory under proper chain-of-custody procedures. Soil borings will be abandoned by filling with bentonite. 3.2 GROUNDWATER SAMPLING During groundwater sampling activities, groundwater elevations shall be collected prior to the beginning of sample collection with a properly decontaminated groundwater level meter. The top of casing elevations relative to an on-site benchmark will be measured to provide site groundwater flow direction data. New polyethylene tubing will be lowered into the temporary monitoring wells and they will be purged of three (3) to five (5) volumes using a peristaltic pump. Once water is allowed to recharge, groundwater samples will be Environmental Site Assessment Work Plan June 11, 2021 Doggett Street/West Tremont Avenue Site NOVA Project Number 3021011.1 Page 14 obtained for laboratory analysis. During the well development, NOVA will collect groundwater quality parameters (pH, temperature, ORP, DO, turbidity and conductivity) after each purge volume. The temporary groundwater monitoring wells will be constructed as temporary piezometers, with temporary caps. Once the groundwater samples have been collected, the temporary wells will be properly abandoned. Groundwater samples will be collected into laboratory-provided sampling containers and placed on ice for transport to the laboratory. The samples will be kept on ice for transport to an accredited laboratory under proper chain-of-custody procedures. 3.3 SOIL GAS AND SUB-SLAB SOIL VAPOR SAMPLING Prior to conducting soil gas sampling activities, the soil gas monitoring points will be allowed to equilibrate with the surrounding conditions for 24-hours prior to sampling. Sub-slab soil gas sampling will be conducted approximately 2-hours after completion of the sub-slab point. During the sampling event, each sample point will be subjected to the following two (2) quality control tests: • A Helium Leak Test, to confirm an airtight seal between the nylon tubing and the ground and within the sampling apparatus. The leak test will be conducted using a shroud covering the monitoring point which is filled with laboratory grade helium to a minimum of two (2) percent. Approximately 300 ml of soil gas will be purged then an additional 300 ml will be collected into a tedlar bag and screened for helium. Helium levels in the tedlar bag will need to be less than ten (10) percent the lowest levels within the shroud to constitute a good seal; and • A Shut-in Test, to confirm an airtight seal in the components of the test apparatus. The Shut-in Test will be conducted once the pieces of the sampling apparatus are assembled, and the summa canister is connected to the monitoring point. The monitoring point will be closed to the environment then the summa canister will be opened. The pressure gauge on the summa canister will be monitored to see that pressure within the system is stable and no leaks are occurring. After each sample point passes the quality control tests within acceptable limits, the test apparatus and nylon tubing will purged of approximately three (3) volumes of air. The soil gas samples will be collected using one (1) 200 milliliter (ml) laboratory-provided summa canisters and delivered to accredited laboratory under proper chain-of-custody procedures. The summa canister will be provided with a regulator which allows for the collection of the soil gas at a rate of between 100 and 200 ml per minute. Vacuum readings on the summa canisters will be monitored continuously during sample collection. The beginning and end times for the sample collection as well as the pressure readings will be collected during the sampling event. The summa canister will be filled leaving a slight vacuum within the canister. Environmental Site Assessment Work Plan June 11, 2021 Doggett Street/West Tremont Avenue Site NOVA Project Number 3021011.1 Page 15 4.0 LABORATORY ANALYSIS NOVA will work with a National Environmental Laboratory Accreditation Program (NELAP)-accredited laboratory with laboratory reporting limits/method detection limits that meet applicable regulatory thresholds. Laboratory data will be reported under Level II quality assurance/quality control (QA/QC) criteria. In addition, method detection limits (MDL) and j-flags (estimated concentrations between the method detection limits and the laboratory detection limit) will be included in the laboratory reporting. 4.1 SOIL ANALYSIS Soil samples will be submitted to a North Carolina certified laboratory for the following analyses: • Volatile Organic Compounds (VOCs) by United States Environmental Protection Agency (US EPA) Solid Waste (SW)-846 Method 8260, • Semi-Volatile Organic Compounds (SVOCs) by USEPA SW-846 Method 8270, and • Resource Conservation and Recovery Act (RCRA) Metals by USEPA SW-846 Method 6010 and 7473, including hexavalent chromium. The collected samples will be kept on ice for transport to an accredited laboratory under proper chain-of-custody procedures. 4.2 GROUNDWATER ANALYSIS Groundwater samples will be submitted to an North Carolina certified laboratory for the following analyses: • VOCs by US EPA SW-846 Method 8260, • SVOCs by USEPA SW-846 Method 8270, and • RCRA Metals by SW-846 Methods 6010/7473. The collected samples will be kept on ice for transport to an accredited laboratory under proper chain-of-custody procedures. 4.3 SOIL GAS AND SUB-SLAB ANALYSIS Soil gas and sub-slab samples will be submitted to a National Environmental Laboratory Accreditation Program (NELAP) accredited laboratory for the following analysis: • VOC Target Compound List (TCL) by USEPA Method TO-15. The collected samples will be transported to an accredited laboratory under proper chain-of-custody procedures. Environmental Site Assessment Work Plan June 11, 2021 Doggett Street/West Tremont Avenue Site NOVA Project Number 3021011.1 Page 16 5.0 QUALITY ASURANCE / QUALITY CONTROL Samples will be labeled with a distinct sample identification number, the sampler’s initials and the date of collection. Each sample container will be properly sealed, labeled, and placed in an ice chest (with ice) for same-day transport to an accredited laboratory (AES) which used USEPA SW-846 protocols. A properly completed chain-of-custody form was initiated in the field and accompanied the samples when submitted to the laboratory for analyses. During soil sampling activities, NOVA will collect one (1) duplicate sample of soil for QA/QC purposes. The duplicate sample will be analyzed for the same parameters and by the same methods as the soil samples collected for assessment. During groundwater sampling activities, NOVA will collect one (1) duplicate sample of groundwater for QA/QC purposes. The duplicate sample will be analyzed for the same parameters and by the same methods as the groundwater samples collected for assessment. One (1) trip blank will be analyzed per sampling event and will accompany the groundwater samples for QA/QC purposes. The trip blank samples will be analyzed for VOC by US EPA SW-846 Method 8260. During soil gas sampling activities, NOVA will collect one (1) duplicate sample of soil gas for QA/QC purposes. The duplicate sample will be analyzed for the same parameters and by the same methods as the soil gas samples collected for assessment. NOVA will collect a sufficient amount of sample for the laboratory to run Matrix Spike (MS) and Matrix Spike Duplicate (MSD) analyses. The collected samples will be transported to an accredited laboratory under proper chain-of-custody procedures. Environmental Site Assessment Work Plan June 11, 2021 Doggett Street/West Tremont Avenue Site NOVA Project Number 3021011.1 Page 17 6.0 INVESTIGATION DERIVED WASTE (IDW) MANAGEMENT Investigation derived waste (IDW) generated from the construction, development and sampling of monitoring wells (i.e. soil cutting, development water and purge water) will be managed in general accordance with NCDEQ-DWM-IHSB Program Guidelines for Assessment and Cleanup (Revised January 2020). IDW will be containerized in DOT approved 55-gallon drums pending analytical results. NOVA will use the analytical data collected during the soil and groundwater assessment for waste characterization purposes. If analytical data indicates soils cannot be spread on site, NOVA will engage a subcontractor to properly dispose the soils off-site. Environmental Site Assessment Work Plan June 11, 2021 Doggett Street/West Tremont Avenue Site NOVA Project Number 3021011.1 Page 18 7.0 RECEPTOR SURVEY NOVA will conduct a receptor survey for the Subject Property. The receptor survey will be conducted in general accordance of NC Brownfields protocols and completed using the NC Brownfields receptor survey form. A blank copy of the NC Brownfields receptor survey form is provided in the attachments. Environmental Site Assessment Work Plan June 11, 2021 Doggett Street/West Tremont Avenue Site NOVA Project Number 3021011.1 Page 19 8.0 REPORTING Following the completion of the aforementioned assessment, NOVA will produce a Limited Environmental Site Assessment (ESA) report. The Limited ESA will document the field activities performed, work practices, provide the analytical results for samples collected, provide a receptor survey, and present possible recommendations. In addition, laboratory analytical results not meeting QA/QC objectives will be identified. The Limited ESA will also be used to evaluate future site restrictions and activities needed to comply with the NCDEQ Brownfields Agreement. FIGURE 1 SITE LOCATION MAP FIGURE 1 SITE LOCATION MAP SOURCE: EDR 7.5-Minute Series Topographic Quadrangles (2) 2013, Charlotte East and West, North Carolina SCALE: 1:24,000 COUSINS TREMONT DOGGETT, LP Doggett Street/West Tremont Ave Site Charlotte, North Carolina NOVA Project Number 3021011.1 Subject Property FIGURE 2 SITE MAP FIGURE 2 SITE MAP SOURCE: www.google.com SCALE: As Shown COUSINS TREMONT DOGGETT. LP Doggett Street/West Tremont Avenue Charlotte, Mecklenburg County, North Carolina NOVA Project Number 3021011.1 Approximate Subject Property Boundary Proposed Soil Boring and Sampling Location Approximate Location of Former Heating Oil UST S-8 S-6 S-7 S-9 Proposed Soil Vapor Monitoring Point SV-1 SV-2 SV-3 SV-4 SV-5 Groundwater Monitoring Point MW-1 MW-2 MW-3 Previous Soil Boring and Sampling Location S-1 S-2 S-3 S-4 S-5 Previous Soil Vapor Monitoring Point VMP-2 VMP-1 VMP-3 VMP-4 VMP-5 VMP-6 MW-4 Proposed SubSlab Vapor Monitoring Point SV-7 SV-6 FIGURE 3 PROPOSED DEVELOPMENT FIGURE 3 PROPOSED DEVELOPMENT SOURCE: Cousins Tremont Doggett, LP SCALE: 1”=60’ COUSINS TREMONT DOGGETT, LP Doggett Street/West Tremont Avenue Charlotte, Mecklenburg County, North Carolina NOVA Project Number 3021011.1 Approximate Subject Property Boundary ATTACHMENT BROWNFIELDS PROPERTY RECEPTOR SURVEY North Carolina Department of Environmental Quality Division of Waste Management Brownfields Program Site: Address: City: County: Brownfields Project Number: Date Property and Building Characteristics a. Provide occupancy and use information. c. Describe the foundation construction. Include details on type, floor construction, and depth below grade. e. Are any subslab ventilation systems or moisture barriers in place? If so, please provide details. NASize of Property (acres) % of property that is wooded/brush d. Describe the HVAC system in the building. Include available details on type, equipment location, source of air return, and design considerations (e.g. positive pressure?). BROWNFIELDS PROPERTY RECEPTOR SURVEY This form was created to clarify and simplify preparing a receptor survey for a brownfield site. Please provide the information requested below. Distances are measured from the site property boundary unless otherwise indicated by the DEQ Brownfield’s Project Manager (PM). Current Usage Proposed UsageSurface Conditions % of property that is grassed areas % of property that is agricultural crops % of property that is paved If an existing building is on-site, please respond to the following. Information can be provided on additional sheets as needed. If numerous buildings are on-site, consult with your PM as only information on specific buildings may be needed. b. Describe the construction of the builidng including materials (e.g. wood frame, block), type and size of openings (e.g. windows, bay doors), and height (number of stories). % of property that is covered by buildings Rev. 09/2015 Page 1 of 3 North Carolina Department of Environmental Quality Division of Waste Management Brownfields Program Surrounding Property Land Use North South East West Utilities Is there a septic system on-site? (Y or N) _________ Please provide the utility providers for the subject property a. Natural Gas ___________________________ b. Sewer ___________________________ c. Electricity ___________________________ d. Other __________________________ For surrounding properties, please complete the following table with available information. Zoning/Land Use Proposed Usage Current Use/Occupant DirectionDistance (ft)Address Please provide information on the following land uses in the vicinity of the subject site, including a map of the surrounding areas. If specific receptors are present, please provide addresses of the facilities. For the subject property, please provide a map of known buried utilites. If available, include depth to top, construction material, and diameter of the utilities. In addition, please provide the following information on utilty providers. If additional assessment is required, the public utility locators should be contacted. This information can then be added to a site map. Y/N * Is a school or daycare center within 1,000 ft of the Property? Specific Land Uses of Interest Y/N * * If numerous facilities of interest are present, their locations can be placed on a map in lieu of providing specific addresses. Distance (ft) * If yes, please provide a map or detailed information (distance, direction, depth) of the utility in correlation with the subject property. Is a water line main within 100 ft of Property boundary? Is a natural gas line main within 100 ft of the Property boundary? Is a buried telephone/ cable main within 100 ft of the Property boundary? Is a septic system leach field within 500 ft of the Property boundary? Direction Is there a basement within 1,000 ft of the Property Is there a residence within 1,000 ft of the Property? Utility/Potential Receptor Is a buried electrical cable main within 100 ft of Property boundary? Is a storm water pipe within 100 ft of the Property boundary? Is a sanitary sewer within 100 ft of the Property boundary? Rev. 09/2015 Page 2 of 3 North Carolina Department of Environmental Quality Division of Waste Management Brownfields Program Water Supply What is the potable water supply for the property? Public ______ Private ______ Surface Water & Wetlands Are there surface water features on the property? (If yes, please complete a. to d.) Provide Information regarding Surface Water and Wetlands Distance (ft)Direction Address a. Is the water body naturally developed or man-made? Y/NWater Supply Wells Please provide the following information regarding water supply wells in the vicinity of the Property. At a minimum, a windshield survey within 1,500 ft of the property boundaries should be completed to determine if water supply or irrigation wells may be present. Information from applicable databases can and should be utilized; however, should not be utilized in lieu of the windshield survey. If multiple wells are present within the requested radius, please provide a map of the well locations. If needed, please attach a separate table to list all wells. Please note, the PM may opt for a more extensive water supply well survey if needed. If Private, please provide details of the water supply source (i.e. well location, well construction, etc). If public, please include the water providers name. Is a public water supply well within 1 mile of the Property boundary? Is a private water supply well within 1,500 ft of the Property boundary?Is an irrigation well within 1,500 ft of the Property boundary? Response/Comments The purpose of this section is to provide information on the presence of surface waters and/or wetlands on, or in the vicinity of the Property. The purpose of this section is to provide information on the water supply for the site and surrounding areas. b. List the uses of the water body. c. What is the source of the water for the water body? d. What is the nature of the bottom of the water body (e.g., rocky or concrete bottom, drainage ways or impoundments) If no on-site surface water features, what is the nearest surface water body? Are there any wetlands present on the property? If no wetlands on-site, are wetlands suspected on adjoining properties? Rev. 09/2015 Page 3 of 3