25032_Domestic Laundry_Topsoil Sampling Work Plan and Approval_20220914

September 14, 2022
Sent Via E-mail
Bennett Thompson & Steven Garrett The Charlotte-Mecklenburg Hospital Authority P.O. Box 32861 Charlotte, NC 28232-2861 [e-mail]
[e-mail] Subject: Approval of Topsoil Sampling Work Plan Domestic Laundry Brownfields Project Charlotte, Mecklenburg County
Brownfields Project Number 25032-21-060 Dear Mr. Thompson and Mr. Garrett, The North Carolina Department of Environmental Quality (DEQ) Brownfields Program received
and reviewed the Topsoil Sampling Work Plan dated September 13, 2022, submitted on your behalf by Geosyntec Consultants of NC for the above referenced site. Based on our review, the Topsoil Sampling Work Plan is approved. Be advised that this approval from the Brownfields Program does not waive any applicable
requirement to obtain any necessary permits, licenses, or certifications for the above referenced activities nor does it waive any requirement to comply with applicable law for such activities. If you have any questions, please feel free to contact me via e-mail at [e-mail].
Sincerely,
Peter L. Doorn Brownfields Project Manager

ec: Amy Kenwell, Geosyntec Consultants of NC Jeff Tyburzski, Geosyntec Consultants of NC Jeff Ahrens, Geosyntec Consultants of NC McKenzie Publicover, Kimley Horn & Associates
Ryan Lewis, Kimley-Horn & Associates
Tracy Wahl, DEQ Brownfields Program
Geosyntec Consultants of NC, P.C.
1300 South Mint St, Suite 300
Charlotte, North Carolina 28203
PH 704.227.0840 www.geosyntec.com
CAR210159

13 September 2022
North Carolina Brownfields Program
Attention: Mr. Peter Doorn
Division of Waste Management
1646 Mail Service Center
Raleigh, North Carolina 27699-1646

Subject: Letter Work Plan for Topsoil Sampling
Site: Former Domestic Laundry - Vicinity of South McDowell Street at
Baxter Street
Charlotte, Mecklenburg County, North Carolina
Brownfields Project ID: 25032-21-060

Dear Mr. Doorn:
Geosyntec Consultants of NC, P.C. (Geosyntec) has prepared this Topsoil Sampling Work Plan
(“Work Plan-TS”) that provides procedures for the sampling of topsoil (assumed to be the top six-
inches of vegetated material and organic soil) located on select portions of the Former Domestic
Laundry Brownfields Property in Charlotte, North Carolina (herein referred to as the “Site”). The
portion of the Site included in this Work Plan-TS includes 801 South McDowell Street, 801 Baxter
Street, 900 Baxter Street, 928 Baxter Street, and 943 Baxter Street which are represented by
Mecklenburg County Parcel IDs 12520155, 12517303, 12520150, 12520158, and 12520154,
respectively (“Subject Property”). Although redevelopment plans are still underway, the
Prospective Developer (PD) currently has plans to redevelop the Site as an educational tower and
research/education facility, multi-family residential apartment building, hotel, commercial office
space, and parking garages.
On 22 April 2021, the PD submitted a Brownfields Property Application (BPA) to the North
Carolina Department of Environmental Quality (NCDEQ) Brownfields Program (NCBP) for a
portion of the Site including 801 South McDowell Street; 900, 928, and 943 Baxter Street; and
1001, 1017, 1043, and 1051 East Morehead Street. A Letter of Eligibility (LOE) was received on
18 October 2021 for the first BPA. On 1 September 2022, an Amended LOE was received which
approved the addition of 801 and 810 Baxter Street to the Brownfields Property.

Mr. Peter Doorn
13 September 2022
Page 2

CAR210159
SCOPE OF WORK
The PD intends to redevelop most of the property with impervious surfaces and is not planning to
reuse topsoil during redevelopment due to the structural instability and the organic nature of this
soil. NCDEQ has requested the sampling of topsoil (0-6 inches) from vegetated areas throughout
the Subject Property prior to soil being transported offsite for disposal and/or reuse on another
construction site or Brownfields property. This scope of work includes topsoil sampling to support
soil management during grading and development of options for offsite disposal or reuse in
connection with the Environmental Management Plan (EMP) prepared for this Early Grading and
Demolition phase of work (EMP-1, approved 8 August 2022). Soil sample results will be
compared to NCDEQ Preliminary Soil Remediation Goals (PSRGs) and the sample with highest
concentrations will be characterized as hazardous or non-hazardous by comparison to the Toxicity
Characteristic Leaching Procedure (TCLP) criteria as defined in the Code of Federal Regulations
(CFR); 40 CFR Part 261.24. Sample results will also be evaluated using the July 2022 version of
the NCDEQ Risk Calculator (as applicable).
Soil Sampling
Geosyntec proposes to conduct topsoil sampling to characterize materials for off-Site disposal
and/or reuse on another construction site or Brownfields Property. Based on conversations with
the PD, approximately 4,500 cubic yards (cy) of topsoil (0-6 inches) are reportedly present that
will need to be managed during construction. Geosyntec proposes to collect one sample for every
1,000 cy of topsoil using a grab/composite sampling strategy. The proposed sample locations are
shown in Figure 1.
Based on the reported volume of topsoil, there are five (5) proposed sample areas (TS-1 through
TS-5), each with five aliquot sample locations to be composited by the laboratory. At each location,
Geosyntec will advance a decontaminated hand auger or shovel to approximately 6-inches below
ground surface at each proposed sample location. Soil will be visually inspected for staining and
placed in a plastic bag to be screened with a photo-ionization detector (PID). Due to the shallow
depth of samples and anticipated classification as topsoil, soils will not be classified for lithology
by the field staff but observed ambiguities of lithology will be noted in field notes.
Samples will be placed into laboratory supplied bottleware and submitted on ice under chain of
custody to a North Carolina-certified laboratory. For each sample, the aliquot with the greatest
field indications of contamination will be selected as a grab sample for Volatile Organic
Compound (VOC) analysis and will be analyzed by United States Environmental Protection
Agency (USEPA) Method 8260. The remaining volume from this aliquot as well as the additional
four aliquots for each of the five samples will be composited by the laboratory and analyzed for
semi-volatile organic compounds (SVOCs) by USEPA Method 8270, Resource Conservation and
Recovery Act (RCRA) Metals by USEPA Methods 6020 and 7471, and total hexavalent chromium
Mr. Peter Doorn
13 September 2022
Page 3

CAR210159
by USEPA Method 7199 (or Method 7196 if off-site disposal is selected by the PD). In-situ soil
samples will be submitted under a standard 2-week turnaround time (TAT) or expedited TAT.
Additional sample volume will be placed on hold pending analytical results. The sample with the
highest concentration will be selected for TCLP analysis for VOCs, SVOCs, and RCRA metals
for disposal characterization.
Sample locations will be measured using a sub-meter accuracy Global Positioning System (GPS).
Based on soil samples collected to date from the Brownfields Property, it is anticipated that the
topsoil is unlikely to be grossly contaminated. Due to the ongoing construction activities and
shallow depth of sample collection, borings will be abandoned by filling each hole with removed
soil and vegetation following sample collection. Decontamination water will be spread in the
vicinity of sample borings. As such, no investigation derived waste (IDW) is anticipated to be
generated during this sampling event. If the field team observes evidence of contamination, soils
will be containerized in Department of Transportation (DOT)-approved 55-gallon drums and
managed in accordance with the Soil and Water Management Plan (Geosyntec, April 2022).
QUALITY ASSURANCE AND QUALITY CONTROL
One duplicate soil sample will be collected for quality assurance and quality control (QA/QC)
purposes. A temperature blank will be included in each cooler, if provided by the laboratory. Other
QA/QC procedures including chain of custody procedures are described in Section 5 of the Work
Plan for Limited Environmental Site Assessment – Part II (Geosyntec, May 2022).
REPORTING
Upon receipt of analytical results, Geosyntec will prepare a written report summarizing the
investigation as generally described in Section 7 of the Work Plan for Limited Environmental Site
Assessment – Part II (Geosyntec, May 2022). Sample results will be compared to NCDEQ PSRGs
and TCLP criteria. Results will also be evaluated using the NCDEQ Risk Calculator (as
applicable). If the PD finds another construction or Brownfields property to transport the topsoil
to, additional evaluation will be conducted to evaluate the conditions of that property and receive
approval from NCDEQ prior to transporting soils. Topsoil will not be transported off-site for reuse
or disposal without prior approval from NCDEQ.

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ED EDSouth McDowell StreetEast M
orehead Street
John Belk Freeway/277
B
axter Street
TS-1
TS-5
TS-4
TS-3TS-2
801 BAXTER ST12517303
900 BAXTER ST12520150
801 SMCDOWELL ST12520155
943 BAXTER ST12520154
928 BAXTER ST12520158
\\charlotte-01\data\GIS\Projects\K\Kimley Horn\Lookout\MXD\CAR220159 Topsoil Sampling\Figure 1 - Sampling Locations.mxd 9/8/2022 9:40:09 AM
Former Domestic Laundry Brownfields ProjectBF# 25032-21-060Charlotte, North Carolina
Proposed Topsoil Sampling Locations
Figure
1Charlotte, NC September 2022
Legend
ED Proposed Sampling Location (colored by composite group)Existing Culverted StreamBrownfields Properties (with Parcel ID for Subject Properties)
150 0 15075 Feet
³Notes:1. Property boundaries and existing stream from Mecklenburg County GIS.2. Sample areas each consist of five aliquot locations to be composited at a North Carolina-Certified Laboratory.3. Prior to compositing, the aliquot with the greatest field indicatios of contamination will be selected as a grabsample for volatile organic compound (VOC) analysis.
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