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.
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Doggett Street/West Tremont Avenue Site NOVA Project Number 3021011.1
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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).
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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.
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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.”
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• “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
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Doggett Street/West Tremont Avenue Site NOVA Project Number 3021011.1
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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:
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Doggett Street/West Tremont Avenue Site NOVA Project Number 3021011.1
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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.
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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
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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.
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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.
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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)
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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.
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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
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Doggett Street/West Tremont Avenue Site NOVA Project Number 3021011.1
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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.
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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.
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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.
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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.
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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.
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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