26002_Commerical Equip_WP+Approval 20230320

03/20/2023

Via Email

March 13, 2023

NCDEQ – Division of Waste Management
Brownfields Program
1646 Mail Service Center
Raleigh, North Carolina 27699-1646

Attn: Ms. Carolyn Minnich

Re: Brownfields Assessment Work Plan
Commercial Equipment Company
Charlotte, North Carolina
Brownfields Project No. 26002-22-060
H&H Project No. ABS-003

Dear Carolyn:

On behalf of Abacus Acquisitions, LLC, please find the enclosed Brownfields Assessment Work
Plan (Work Plan) prepared in response to the North Carolina Department of Environmental Quality
(DEQ) Brownfields Program request for additional assessment at the Commercial Equipment
Company Brownfields property. The enclosed Work Plan has been revised based on comments
provided by DEQ on February 7, 2023.

Should you have questions or need additional information, please do not hesitate to contact us at
[phone].

Sincerely,
Hart & Hickman, PC
Haley Martin, PG Ralph McGee, PG
Senior Project Geologist Project Manager

Ms. Carolyn Minnich
March 13, 2023
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Enclosures:

cc: Mr. Mason Ellerbe, Abacus Capital (via email)
Mr. John Grantham, Abacus Capital (via email)
Ms. Mary Katherine Stukes, Moore & Van Allen, PLLC (via email)
Ms. Laura Truesdale, Moore & Van Allen, PLLC (via email)

Attachments:

Completed Environmental Site Assessment Work Plan Minimum Requirements Checklist
Brownfields Assessment Work Plan
Minimum Requirements Checklist
for
Site Assessment
Work Plans and Reports
NCDEQ Brownfields Program – February 2022
Instructional Page
All references to Prospective Developers includes follow-on owners who may be conducting
work in accordance with the Brownfields Property Management Unit.
To increase predictability and most efficiently assess Brownfields Properties and the
redevelopment timing requirements of Prospective Developers or follow-on owners, the
Brownfields Program has standardized the format for Site Assessments. This format has been
generated in the form of a checklist to allow for ease in submission by the prospective developer’s
consultant and for the Brownfields Program’s completeness review. This checklist outlines the
minimum requirements and submittal format under the Brownfields Program for Assessment
Requirements and Reporting. All Assessment Work Plans and Reporting submissions to the
Brownfields Program must include this completed checklist in the outlined format.
These requirements allow DEQ to reduce review time for the Assessment Work Plan and Report
and increase process predictability for prospective developers. This checklist will also provide
reliable data for risk-based decisions and further expedite the project timeline. Any divergence
from these requirements will lengthen the process of assessing risks on the site, may necessitate
reprioritization of a project manager’s queue towards projects that meet these requirements.
Therefore, delaying production of the brownfields agreement and/or environmental management
plan. Any alterations to the checklist on a site- specific basis must be reviewed and approved by
the Program prior to implementation. However, in order to respect the schedule of all projects in
house and keep the program’s entire project pipeline moving, we strongly recommend against
seeking changes to the checklist.
Based on a review of environmental and risk data from our project inventory, please note
there are some new points of emphasis that are included herein:
1. For ALL residential reuses; sub-slab vapor assessment (full list EPA TO-15) is required,
regardless if existing structures will be removed. If no structures or slabs exist on the
Brownfields Property, exterior soil gas assessment is required within all proposed
structure footprints. 
2. ALL properties require groundwater data (VOCs, SVOCs and RCRA Metals) from a
minimum of three sample locations, depth to groundwater and a resulting potentiometric
map. 
3. Soil shall be assessed based on areas of concern and redevelopment plans and across the
depth interval of the cut/grading.
Environmental Site Assessment
Work Plan Checklist
Reviewed and checked by (Name ): Carolyn Minnich
Brownfields Redevelopment Section
Title Page
The title page should include the following information. Letter style reports are acceptable, as long as
this information is somewhere on the first page.
X Title of Work Plan
X Brownfields Project Name (not the development name)
X Brownfields Project Number
X Date (updated with each revision)
NA Revision Number
X Firm PE/PG License Number
X Individual PE/PG seal & signature
X Contact information for Developer, Consultant, and Project Manager

Section 1 – Introduction
X Provide the site location, address, and acreage.
X Provide a BRIEF summary of the history of the property and its history in the program. For example:
reiterate RECs from a Phase I ESA, indicate if the scope of work was negotiated during a Data
Gap Meeting, etc.
X Briefly list and describe the data gaps the assessment is attempting to fill
NA Indicate if the assessment data is for the use of any other DEQ programs in addition to the
Brownfields Program (i.e. the site is a regulated UST, IHSB, etc. property)
Section 2 – Scope of Work
X Provide a general description of proposed scope of work covered in this plan (i.e. 2 new
monitoring wells, six groundwater samples, 5 exterior soil gas sampling points and 6 soil
borings)
X Discuss samples to be collected by media and source area/location. Generally, the reasoning for
the sample locations selected.
X Describe depths of samples to be collected (Reference Table 1) or how that decision will be
made in the field, if needed.
X State for what each sample will be analyzed (briefly). Reference Table 1.
- For all residential reuses, sub slab vapor is required, if no slabs exist, exterior soil gas is required
within all proposed footprints.
Section 3 – Sampling Methodology
X Reference the guidance documents you intend to use. IHSB, EPA SESD, VI Guidance, Well
Construction Rules (NCAC 2C). Note deviations or methodology planned that is not covered by
such guidance (e.g., multi-increment sampling, passive air samplers, mobile labs, Hapsite,
simultaneous indoor/outdoor radon, high-volume subslab vapor testing, PFAS sampling).
X Describe what will be installed (soil boring, temporary well, permanent well, sub slab vapor,
exterior soil gas, etc.). Include construction details.
X Discuss installation methodology (Hand Auger, DPT, etc.)
X Discuss sample collection procedures. Include the following, at a minimum:
 Equipment to be used
 Purging methods and volumes
 Stabilization parameters for groundwater sampling
 Field screening methods
 Leak check procedures for sub-slab vapor and exterior soil gas samples (Note this is
required)
 Discuss how and when vacuum readings will be collected (for summa cans)
X Discuss sample point abandonment

Section 4 – Laboratory Analyses
X Discuss the proposed analyses (include method number, preparation method, if there are
concerns with short hold times, etc).
NA Discuss any proposed limitations on the contaminants of concern, if any, and the reason for
such limitation (sufficient previous data, indoor air interferences, etc).
X Discuss laboratory certifications. Please note, NC does not certify labs for air samples. Please
specify what certification the proposed air lab holds.
X Indicate that the Reporting Limits/Method Detection Limits will meet applicable screening
criteria (to the extent feasible). Include Reporting of J-Flags to meet criteria.
X Indicate what Level QA/QC will be reported by the laboratory. Level II QA/QC is typically
acceptable.

Section 5 – QA/QC
X Specify the duplicate sample frequency. Minimum requirement: 1 duplicate per 20 samples, per
media, per method.
NA Discuss Trip Blank. 1 Trip Blank per cooler/shipment of groundwater VOC analyses is required.
NA Discuss how the lab will have sufficient sample volume for MS/MSD analyses.
X Discuss chain of custody and shipping.

Section 6 – Investigation Derived Waste (IDW) Management
X Discuss what IDW will be generated and how it is proposed to be managed. Management
recommendations should be in accordance with 15A NCAC 02T.1503 and 15A NCAC 02H.
0106. Generally, if the Brownfields Property has not previously been assessed, then all IDW
must be containerized and characterized prior to management. Previous assessment data that
indicate no Hazardous Waste (listed or characteristic) is likely to be encountered in the area of
proposed assessment will be required before thin spreading of IDW on-site is permitted.
Section 7 – Reporting
This section should discuss the components of the assessment report which will be prepared as a result
of the above sample collection. At a minimum, the report shall include:
X Reporting/summary of site work conducted for all sections outlined above in this checklist;
X Summary of findings and possible recommendations;
X All applicable tables and figures outlined below with the addition of:
Tables for tabulated analytical data per media sampled and analyzed, compared against
applicable screening levels, sample depths and depth to groundwater;
Figure depicting actual sample locations collected, with each media depicted in the
legend, graphic scale and north arrow; and
Groundwater potentiometric map, with graphic scale and north arrow.
‐ Boring logs for all soil borings, newly constructed monitoring wells, and exterior soil gas
locations 
‐ Well construction and abandonment records, if applicable
X Firm PE/PG License Number
X Individual PE/PG seal & signature

Attachments
X Table 1 – Proposed Sample Locations and Analyses on a Summary Table that includes:
Sample ID
Sample Objective
Proposed Depth(s)
Analytical Method(s)
QA/QC Samples
Background Samples

X Figure 1 – Site Location Map
Site location on a topographic map base
Graphic scale and north arrow

X Figure 2 – Site Map should include the following
Buildings
Historical sample locations
RECs or other areas of concern
Proposed sample locations
Sample identification labels
Background samples
QA/QC samples
Graphic scale and north arrow
High quality aerial suggested as the base map

NA_ Figure 3 – Site Potentiometric Map
- Buildings
- Groundwater sample identification labels
- Graphic scale and north arrow

NA__ Figure 4 – Site Plume Maps (groundwater, soil vapor, etc.)

X Figure 5 – Proposed Development (if available)
Overlay of historical and proposed sample locations
Graphic scale and north arrow
X Appendix – Summary of Historical Analytical Data (if needed) – to include tables and figures
only.
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Brownfields Assessment Work Plan
Commercial Equipment Company
N. Graham Street and W. 28th Street
Charlotte, North Carolina
H&H Job No. ABS-003

Table of Contents

1.0 Introduction .............................................................................................................................1 
1.1 Background Information .......................................................................................................2 
1.2 Previous Assessment Activities .............................................................................................3 
1.3 Brownfields Activities ...........................................................................................................9 
2.0 Brownfields Assessment Activities ......................................................................................11 
2.1 Soil Sampling Activities ......................................................................................................12 
2.2 Sub-Slab and Exterior Soil Gas Sampling Activities ..........................................................14 
2.3 Methane and Pressure Measurements .................................................................................17 
2.4 Quality Assurance – Quality Control ..................................................................................19 
2.5 Investigation Derived Waste Management ..........................................................................20 
2.6 Reporting .............................................................................................................................20 

List of Tables

Table 1 Sample Summary Table

List of Figures

Figure 1 Site Location Map
Figure 2 Site Map
Figure 3 Proposed Sample Location Map

List of Appendices

Appendix A Previous Assessment Summaries
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Project Contacts

Mr. Mason Ellerbe
Abacus Acquisitions, LLC
1200 E. Morehead Street, Suite 280
Charlotte, NC 28204
704-995-0290 (cell)
[e-mail]

Ms. Haley Martin, PG
Hart & Hickman, PC
2923 South Tryon Street, Suite 100
Charlotte, NC 28203
[phone] (office)
[phone] (cell)
[e-mail]

Ms. Carolyn Minnich
Division of Waste Management – Brownfields Redevelopment Section
1646 Mail Service Center
Raleigh, NC 27699
[phone] (cell)
[e-mail]

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Brownfields Assessment Work Plan
Commercial Equipment Company
N. Graham Street and W. 28th Street
Charlotte, North Carolina
H&H Job No. ABS-003

1.0 Introduction

On behalf of Abacus Acquisitions, LLC (Prospective Developer or PD), Hart & Hickman, PC
(H&H) has prepared this Brownfields Assessment Work Plan (Work Plan) for the Commercial
Equipment Company Brownfields property (Brownfields Project No. 26002-22-060) located
southeast of the N. Graham Street and W. 28th Street intersection in Charlotte, Mecklenburg
County, North Carolina (Site). A Site location map is provided as Figure 1.

The subject Site is comprised of four contiguous parcels (Mecklenburg County Parcel
Identification Nos. 07907911, 07907910, 07907908, and 07907909) that collectively total
approximately 7.5 acres of land. The northwestern portion of the Site (2402/2426 N. Graham
Street) is developed with an approximately 4,500-square foot (sq ft) office building with an
approximate 1,800-sq ft basement constructed in 1945, and the southern portion of the Site (609
W. 28th Street) is developed with an approximately 7,350 sq ft service garage constructed in
1969. The parcels located in the southeastern portion of the Site (2409 and 2415 Grimes Street)
are developed with single-family residences that were constructed in 1949. The Site and
surrounding area are shown in Figure 2.

Proposed redevelopment of the Site includes construction of residential for-rent townhome-style
buildings and residential apartment buildings with associated parking and amenities areas. Note
that construction of the for-rent townhome buildings includes ground-level parking garages that
are not connected to upper-level occupiable spaces except for a small landing and staircase at the
entrance to each unit. An overlay of the preliminary Site redevelopment plan including locations
of proposed buildings is provided as Figure 3.

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This Work Plan has been prepared to address North Carolina Department of Environmental
Quality (DEQ) Brownfields Redevelopment Section requests for additional sampling to further
evaluate risks associated with redevelopment of the Site.

A summary of background information and previous assessment activities conducted at the Site
is provided below.

1.1 Background Information

Prior to the late 1930s, the Site consisted predominately of undeveloped land used for
agricultural purposes (e.g., hay fields or pastures) and a rural access road. By the late 1940s, the
western portion of the Site was developed with three commercial buildings associated with a
motor freight station and auto repair facility. By the late 1950s, the southern portion of the Site
was developed with five single-family residences. In the early 1970s, the auto repair shop in the
central portion of the Site was razed and a portion of the current 609 W. 28th Street building was
constructed in the southern portion of the Site. In the 1980s and 1990s, all but two residences in
the southern portion of the Site were razed and additions to the 609 W. 28th Street building were
completed. The Site was occupied by Starnes Pallet from the early 2000s to the early 2020s.

Starnes Pallet operations included salvage of used wooden and plastic pallets. The pallets were
transported to the Site and disassembled prior to transport off-Site for recycling/reuse. In
addition, Starnes Pallet allowed customers to stage used totes and drums at the Site prior to
transport off-Site for recycling. The totes and drums were reportedly emptied and cleaned prior
to arrival at the Site.

The office building in the northwestern portion of the Site is currently unoccupied but is used for
storage of personal items by the current property owner (Starnes Commercial Properties LLC).
The service garage building is occupied by a tractor trailer truck leasing and rental business. The
service garage in the southern portion of the Site is used for routine maintenance and repair of
the tractor trailer fleet. Remaining portions of the Site consist of asphalt-paved and gravel-
covered parking and storage areas. Materials stored at the Site include wooden and plastic
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pallets, empty totes and drums, and construction materials including lumber, steel beams, toilets,
sinks, hot water heaters, and other debris. The two single-family residences along Grimes Street
are occupied by residential tenants.

1.2 Previous Assessment Activities

H&H completed Phase I ESA activities at the Site in December 2021 and identified the
following environmental concerns associated with historical on-Site and nearby off-Site
operations:

 The Site was formerly utilized by Commercial Equipment Co. from the early 1970s until
the late 1990s. According to information provided in available environmental documents
prepared for the Site, Commercial Equipment Co. utilized one 500-gallon gasoline
underground storage tank (UST) as part of Site operations. According to the Site contact
and information provided in available environmental documents, the gasoline UST has
not been used in over 30 years but remains at the Site. H&H did not observe
aboveground evidence (e.g., vent pipes, fill ports, etc.) associated with the reported 500-
gallon tank during Site reconnaissance activities. Results of the Phase I ESA identified
the potential for an undocumented release associated with the gasoline UST and the
potential for additional unidentified USTs at the Site was as a Recognized Environmental
Condition (REC).

 Review of available environmental documents indicates that a freight depot/motor line
company and an auto repair facility with a paint booth operated in the western and central
portions of the Site in the 1950s and 1960s. The Site is not listed in the environmental
databases as a generator of hazardous wastes and there are no release incidents reported
in the environmental databases associated with hazardous wastes or historical automotive
repair operations at the Site. However, auto repair operations often include use of various
petroleum-related products and solvents for degreasing. Additional information
regarding former auto repair and freight operations was not available. Results of the
Phase I ESA identified the potential for an undocumented release or releases associated
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with decades of historical on-Site auto repair and trucking operations as a REC in
connection with the Site.

 Based on information provided in available environmental documents, the 609 W. 28th
Street Site building utilized an oil/water separator (OWS) system and/or waste oil UST
until the 1990s. A steel pipe was observed at the ground surface near the southern corner
of the 609 W. 28th Street Site building and two floor drains were observed in the former
wash bay and washdown concrete pad located along the eastern side of the 609 W. 28th
Street building. Standing fluids with an oily sheen were observed within the floor drains
located in the wash bay and concrete wash pad. The pipe and drains are suspected to be
associated with the reported OWS and/or waste oil tank.

There are no release incidents associated with the OWS drain system and/or waste oil
tank and no available documentation related to routine maintenance and emptying of sub-
grade components of the systems. Based on the age of the drains and OWS system/waste
oil UST and the observed conditions of the drains, results of the Phase I ESA identified
the potential for impact to the Site from an undocumented release associated with the
floor drain and OWS system/waste oil UST system as a REC.

 Information provided in the environmental databases indicates that approximately 50-
gallons of diesel were released to the ground surface and contained using absorbent pads.
Additional information pertaining to the surface release (Incident No. 85418) was not
available in the database report or in DEQ UST Section records. According to
information provided by DEQ UST Section personnel, files associated with the release
incident are designated as lost and the petroleum release incident remains open. The Site
contact was unaware of the reported spill and was therefore unable to provide additional
details related to the remedial effort or subsequent sampling confirming the spill was
adequately addressed to levels below applicable screening criteria. Based on the lack of
details associated with the remedial effort and sampling information, and the open status
of the release incident, the reported on-Site surface spill was identified as a REC in the
Phase I ESA.
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A Historical Recognized Environmental Condition (HREC) is defined as a REC which involves
a past release of hazardous substances or petroleum products that has been addressed to the
satisfaction of the applicable regulatory authority and is not subject to activity and/or use
limitations. Results of the Phase I ESA identified the following HREC in connection with the
Site:

 Commercial Equipment Co. installed two 12,000-gallon diesel USTs near the southern
exterior wall of the 609 W. 28th Street Site building in March 1980. Petroleum impacted
soil was discovered during closure of the two diesel USTs in March 1998, and
approximately 270 cubic yards of impacted soil was removed from the tank basin and
stockpiled on-Site (LUST Incident No. 18731). Soil samples were collected for
laboratory analysis beneath the former diesel USTs (T1-E, T2-E, T1-W, and T2-W),
along product lines (PL-1, PL-4, and PL-5), and adjacent to dispensers (D-1, D-2, and D-
3). According to information provided in the environmental documents, the product
piping and dispensers were not removed during closure activities in March 1998.

Laboratory analytical results for soil samples collected from the UST basin indicated that
total petroleum hydrocarbons as diesel range organics (TPH-DRO; up to 6,700
milligrams per kilogram {mg/kg}) and as gasoline range organics (TPH-GRO; up to 500
mg/kg) were detected at concentrations above the DEQ UST Section Residential
Maximum Soil Contaminant Concentrations (MSCCs) established at the time. Note that
there are no current MSCCs for TPH and the current DEQ UST Section Action Levels
for TPH-DRO and TPH-GRO are 100 mg/kg and 50 mg/kg, respectively. In addition to
TPH, UST basin soil sample results identified the presence of several additional
petroleum-related compounds including n-butylbenzene, sec-butylbenzene, naphthalene,
1,2,4-trimethylbenzene, 1,3,5-trimethylbenzene, isopropyl benzene, total xylenes, and 2-
methylnaphthalene at concentrations above the DEQ UST Section Soil-to-Water MSCCs.

Product line soil sample results indicated that naphthalene and 2-methylnaphthalene were
detected in one sample at concentrations exceeding the Soil-to-Water MSCCs.
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Laboratory analytical results for soil samples collected in the area near the dispensers did
not identify organic compounds at concentrations above the DEQ UST Section MSCCs.

In June 1998, one monitoring well (MW-1) was installed and sampled in the area of the
former diesel UST basin. Soil samples collected from the monitoring well boring did not
indicate the presence of compounds at concentrations above the DEQ UST Section
MSCCs with the exception of C9-C10 aromatics hydrocarbon fractions which were
detected at a concentration slightly above the Soil-to-Water MSCC. Laboratory
analytical results for the groundwater sample collected from the monitoring well
indicated the presence of benzene, naphthalene, and C9-C22 aromatics at concentrations
above the DEQ 2L Groundwater Quality Standards (2L Standards), but below the DEQ
UST Section Gross Contamination Levels (GCLs).

Information provided in a Limited Site Assessment (LSA) report prepared for the Site by
Altura Environmental on October 23, 1998, indicates that three additional shallow
monitoring wells (MW-2, MW-3, MW-4) were installed south of the former diesel UST
basin, adjacent to the product piping, and topographically downgradient of the former
diesel USTs, respectively. In addition, one deeper monitoring well (MW-1A) was
installed near existing well MW-1. Groundwater samples were collected for laboratory
analysis from each monitoring well (MW-1 through MW-4 and MW-1A). Laboratory
analytical results for groundwater samples collected from monitoring well MW-1
identified benzene, naphthalene, C9-C-22 aromatics, and ethylbenzene at concentrations
above the 2L Standards. The compounds naphthalene and 2-methylnaphthalene were
detected at concentrations above the 2L Standards in deeper well MW-1A. Petroleum-
related compounds were not detected at concentrations above the laboratory reporting
limits in samples collected from the remaining monitoring wells.

Based on results of assessment activities and risk evaluations, the DEQ UST Section
assigned a low-risk designation to the incident. On November 6, 1998, the DEQ UST
Section issued a No Further Action (NFA) letter providing regulatory closure for the
release. Information provided in the NFA letter indicates contaminated groundwater has
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not been remediated to levels below the 2L Standards and is not a suitable water supply
source. However, a Notice of Residual Petroleum (NORP) restricting groundwater use or
other activity use limitations was not recorded on the property deed. Based on regulatory
closure of the release incident without activity or land use restrictions recorded on the
property deed, the release incident associated with the former diesel USTs represents an
HREC in connection with the Site.

2022 Phase II ESA
In February 2022, H&H performed Phase II ESA activities at the Site to evaluate the potential
for impacts and assist in the management of Site media during planned redevelopment activities.
Assessment activities included the advancement of seven (7) soil borings near areas of concern
(i.e., drains, former and suspect USTs, former dispenser islands, and an OWS/waste oil UST
system), and five (5) composite soil samples were collected from shallow soil that will likely be
disturbed during future redevelopment. Assessment activities also included groundwater sample
collection from five (5) temporary monitoring wells installed in upgradient areas of the Site to
evaluate the potential for impact from nearby off-Site properties, areas of potential concern, and
in areas downgradient of the existing Site buildings. Additionally, eight (8) exterior soil gas
samples and two (2) sub-slab soil gas samples were collected for laboratory analysis within or
near the footprint of proposed for-rent apartment buildings to evaluate the potential for structural
vapor intrusion. Although there is no known historical landfilling, dumping, waste disposal, or
other operations that would result in a subsurface source of methane at the Site, subsurface
methane and differential pressure measurements were collected from each exterior soil gas and
sub-slab soil gas monitoring point location to minimize the potential for data gaps associated
with the redevelopment of a Brownfields property for residential use.

Soil, groundwater, and soil gas sample locations from the February 2022 Phase II ESA are
depicted in Figure 3, and summaries of the analytical results are provided in Appendix A.

Results of soil sampling activities completed in areas planned for disturbance during future
grading and redevelopment on the Site did not identify organic compounds at concentrations
above the DEQ Preliminary Soil Remediation Goals (PSRGs). Results of the soil assessment
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activities completed in the areas near the former USTs, dispenser islands, wash bay, and
OWS/waste oil UST system did not identify compounds at concentrations above the DEQ
PSRGs or background concentrations in the case of metals. Concentrations of arsenic (COMP-1)
and lead (COMP-3) were detected at concentrations above the DEQ Residential PSRGs and
regional background concentrations for metals in shallow soil that may be disturbed during
redevelopment. Remaining metal concentrations detected in soil samples collected at the Site are
consistent with published and established naturally occurring levels.

Results of the groundwater sampling identified several organic compounds above 2L Standards
and/or DEQ Residential and/or Non-Residential Vapor Intrusion Groundwater Screening Levels
(GWSLs), including: carbon tetrachloride, chloroform, 1,2-dichloroethane, 1-methylnaphthalene,
naphthalene, tetrachloroethene (PCE), and trichloroethene (TCE). Total chromium was detected
above the 2L Standard in TMW-3.

Results of the soil gas assessment activities identified several compounds at concentrations
above the DEQ Residential Vapor Intrusion Sub-slab and Exterior Soil Gas Screening Levels
(SGSLs). The chlorinated solvents PCE and TCE were not detected at a concentration above the
DEQ Vapor Intrusion SGSLs in soil gas samples collected at the Site.

Risk calculator results using compound concentrations detected in the soil gas samples indicate
that the Site-wide worst-case calculated cumulative lifetime incremental carcinogenic risk
(LICR) is less than the acceptable risk level of 1 x 10-4. However, the cumulative
noncarcinogenic hazard index (HI) exceeds the DEQ and Environmental Protection Agency
(EPA) acceptable threshold and 1.0. Risk calculator results using the compound concentrations
detected in the sub-slab soil gas samples collected within the existing Site buildings did not
exceed unacceptable risk thresholds under a residential use scenario.

Results of the methane gas measurements identified the presence of methane up to 7.0% by
volume air (bv) in the southeastern portion of the Site (SG-5/SG-DUP), which is above the lower
explosive limit (LEL) of 5% bv for methane. However, the presence of methane in the
subsurface is not present at concentrations above the DEQ Brownfields Program 30% bv
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residential use threshold. Methane concentrations were not detected above the LEL in remaining
soil gas sample locations at the Site. Pressure measurements collected at the Site are within the
accuracy limits for the instrument and are not present at levels that would allow for subsurface
methane to migrate vertically to the surface at potentially explosive concentrations.

1.3 Brownfields Activities

To address potential environmental concerns associated with historical on-Site and off-Site
operations, the Site was entered into the DEQ Brownfields Redevelopment Section and received
eligibility in a letter dated May 24, 2022. In the Brownfields Redevelopment Section, the
Prospective Developer (as defined by the Brownfields statutes) of a property and DEQ enter into
an agreement which provides for State liability protection for cleanup of identified soil,
groundwater, or other impacts in exchange for making the Site safe for its future intended use.
Making the Site safe for its intended use is typically accomplished by implementing land use
restrictions (i.e., restriction on groundwater usage) and engineering controls (such as capping
impacted soil or installing vapor intrusion mitigation systems) and not through remediation.

Provided that the Site is developed in accordance with the Brownfields Agreement, the
developer receives State liability protection for impacts identified at the Site. This liability
protection also applies to future owners of the property, occupants of the facility, a successor or
assign, and lenders or fiduciary (provided they are not otherwise potentially responsible
parties).

The PD elected to participate in the Brownfields Redevelopment Section Redevelopment Now
option. As part of this process, a kick-off/data gap meeting with the PD, environmental counsel
for the PD, DEQ Brownfields personnel, and H&H was held on September 15, 2022 to discuss
prior Site history, proposed redevelopment plans, previous sampling data, and the proposed
schedule for completing the Brownfields Agreement.

Based on results of previous assessment activities and discussions during the data gap/kick-off
meeting, in an email dated November 16, 2022, DEQ Brownfields requested collection of
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additional soil samples and sub-slab soil gas samples. In addition, DEQ Brownfields
Redevelopment Section requested collection of subsurface methane readings to further evaluate
the extent of measurable subsurface methane . This Work Plan has been prepared to address
DEQ requests for additional assessment.

A summary of the proposed Brownfields assessment activities is provided below.
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2.0 Brownfields Assessment Activities

Brownfields assessment activities will include collection of soil samples in the northern, central,
and eastern portions of the Site where organic compound or metals were detected during
assessment activities completed during February 2022 Phase II ESA activities. Based on the size
of the 609 W. 28th Street Site building (approximately 7,350 sq ft) one additional sub-slab soil
gas sample will be collected as part of Brownfields assessment activities. Based on the proposed
redevelopment plan, four (4) additional exterior soil gas samples will be collected within the
footprint of proposed townhome-style apartment buildings. In addition, subsurface methane and
differential pressure measurements will be collected from up to nine (9) soil gas monitoring
points installed in the southern portion of the Site where measurable levels of methane above the
LEL were identified during February 2022 Phase II ESA activities.

The assessment activities be performed in general accordance with the DEQ Inactive Hazardous
Sites Branch (IHSB) Guidelines for Assessment and Cleanup of Contaminated Sites (Guidelines)
dated September 2022, the DEQ Division of Waste Management (DWM) Vapor Intrusion
Guidance (VI Guidance) dated March 2018, the NCDEQ Brownfields Program Methane
Assessment Protocol revised December 2020, most recent versions of the U.S. EPA Region IV
Laboratory Services and Applied Science Division (LSASD) Field Branches Quality System and
Technical Procedures guidance, and the Brownfields Program Environmental Site Assessment
Minimum Requirements Checklist dated February 2022.

Prior to conducting the proposed assessment field activities, H&H will contact North Carolina
811, the public utility locator, to mark subsurface utilities located on the Site. H&H will also
contract with a private utility locator to screen proposed sample locations for subgrade utilities
that may not be marked by the public locator. Additionally, soil boring locations will be hand
cleared to approximately 5 feet (ft) below ground surface (bgs) prior to use of mechanical
drilling equipment to further screen the boring locations for the presence of subsurface utilities.
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2.1 Soil Sampling Activities

H&H will conduct soil sampling as part of the Brownfields assessment activities. The purpose
of the soil sampling is to evaluate the potential for soil impacts in areas of the Site where field
screening identified photoionization detector (PID) readings above background levels during
Phase II ESA activities. Locations of the proposed soil borings are shown in Figure 3. A tabular
summary of proposed soil sample depths, objectives, and laboratory analyses are summarized in
Table 1.

H&H will team with a qualified drilling contractor to advance soil borings at the Site utilizing a
decontaminated stainless-steel hand auger and direct push technology (DPT) drilling techniques.
During boring advancement, continuous soil samples will be collected from each boring and
logged for lithological description. The soil samples will be field screened for indication of
potential impacts by observation for obvious staining, unusual odors, and the presence of volatile
organic vapors using a calibrated PID. Soil samples will be collected for laboratory analysis as
described below.

 Two soil borings (BF-SB-01 and BF-SB-02) will be advanced in the northern corner of
the Site in the area of previous borings SG-1 and TMW-1. Soil borings will be advanced
to approximately 10 ft bgs. Based upon field observations, one soil sample will be
collected for laboratory analysis from the boring and depth interval with the highest
potential for impacts based on results of field screening. If no obvious impacts are
observed during field screening, a sample will be collected from one boring from the 5-7
ft bgs depth interval to evaluate the potential for impact at a depth greater than 2 ft bgs as
requested by the DEQ Brownfields Redevelopment Section.

 One soil boring (BF-SB-03) will be advanced in the central portion of the Site in the area
of previous boring SG-6. The soil boring will be advanced to approximately 10 ft bgs. If
no obvious impacts are observed during field screening, a sample will be collected from
the 4-5 ft bgs depth interval to evaluate the potential for impact at a depth greater than 2
ft bgs as requested by the DEQ Brownfields Redevelopment Section.
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 Two soil borings (BF-SB-04 and BF-SB-05) will be advanced in the eastern portion of
the Site in the area of previous borings SG-2 and SG-3. Soil borings will be advanced to
approximately 10 ft bgs. Based upon field observations, one soil sample will be collected
for laboratory analysis from each boring from the depth interval with the highest potential
for impacts. If no obvious impacts are observed during field screening, a sample will be
collected from each boring from the 2-4 ft bgs depth interval to evaluate the potential for
impact at a depth greater than 2 ft bgs as requested by the DEQ Brownfields
Redevelopment Section.

Soil samples selected for laboratory analysis will be placed in dedicated laboratory supplied
sample containers, labeled with the sample identification, date, and requested analysis, and
placed in a laboratory supplied cooler with ice. The sample will be delivered to a North Carolina
certified laboratory under standard chain of custody protocols for laboratory analysis of VOCs
by EPA Method 8260, semi-VOCs (SVOCs) by EPA Method 8270, Resource Conservation and
Recovery Act (RCRA) metals by EPA Methods 6020/7471, and hexavalent chromium by EPA
Method 7199.

Central Shallow Soil
In addition to the soil sampling described for the northern, central, and eastern portions of the
Site above, six (6) shallow soil borings will also be advanced for the collection of soil samples in
the central portion of the Site to further evaluate soil conditions near the Phase II ESA composite
soil sample COMP-3 aliquot soil borings. The proposed soil boring locations (identified as
COMP-3A through COMP-3F) are shown in Figure 3.

The drilling contractor will advance each soil boring with a decontaminated stainless steel hand
auger and collect continuous soil samples from each boring from the center of the hand auger
bucket. The soil samples will be logged for lithologic description, inspected for the presence of
visual and olfactory indication of potential impacts, and screened for the presence of volatile
organic vapors with a calibrated PID.

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Soil samples for laboratory analysis will be collected from the surface to approximately 2 ft bgs
at each boring location. The soil samples will be collected directly into laboratory-supplied
glassware, labeled with the date, time, and sample identification, and placed in a laboratory
supplied sample cooler with ice. The samples will be submitted to a North Carolina certified
laboratory under standard chain of custody protocols for analysis of lead by EPA Method 6020.
A sample summary table is included as Table 1. In addition, portions of each sample will be
submitted for analysis of Toxicity Characteristic Leaching Potential (TCLP) and will be placed
on hold pending receipt of the total lead concentrations. If total lead concentrations exceed
characteristically hazardous waste levels, then TCLP analysis will be conducted.

Following completion of the confirmation soil sampling activities, the soil borings will be
properly abandoned and the surface will be repaired similar to pre-drilling conditions. In
addition, soil boring locations will be estimated using a hand-held global positioning system
(GPS) unit.

2.2 Sub-Slab and Exterior Soil Gas Sampling Activities

Although no compounds were detected in the SSV-2 sub-slab soil gas sample at concentrations
above the DEQ Vapor Intrusion SGSLs, H&H proposes to collect one (1) sub-slab soil gas
sample (SSV-3) in the office area of the existing 609 W. 28th Street Site building to address
DEQ’s request. The sub-slab soil gas sample location may be adjusted to 1) minimize damage to
floors or floor coverings, and 2) to analyze sub-slab conditions in areas separated by building
footers if indications of building footers are observed during field sample location selection. In
addition, H&H proposes to install and sample four (4) temporary exterior soil gas monitoring
points (SG-9 through SG-12) within the footprint of proposed for-rent townhome style apartment
buildings to further evaluate the potential for structural vapor intrusion. The approximate
locations of the proposed sub-slab and exterior soil gas sampling points are shown on Figure 3.

The sub-slab soil gas sampling point will be installed using a rotary hammer drill and 1½-inch
diameter drill bit to advance a pilot hole into the concrete slab to a depth of approximately 1¾
inches below the slab surface. A drill guide will then be placed within the pilot hole, and a 5/8-
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inch diameter drill bit will be utilized to advance a boring through the concrete slab and
approximately 6-inches into the underlying soil. Following borehole advancement, loose
concrete cuttings will be removed from each boring, and a Cox-Colvin Vapor PinTM (vapor pin)
assembly (brass sampling point and silicone sleeve) will be seated in the borehole using an
installation/extraction tool and dead blow hammer to form an airtight seal.

The exterior soil gas sampling points will be installed to a depth of approximately 5 ft above the
water table and no shallower than 5 ft bgs. Soil gas sampling point borings will be advanced at
each proposed location using a decontaminated stainless-steel decontaminated hand auger and
DPT drilling techniques to approximately 7 ft bgs. An approximate 6-inch stainless steel vapor
implant screen attached to Teflon® sample tubing will then be placed at the base of the borehole.
Annular space around the vapor implant screen will be filled with filter sand to approximately 6-
inches above the vapor implant screened interval. Following installation of sand, hydrated
bentonite will be installed in the boring from the top of the sand to near the ground surface. Soil
gas sampling points will be allowed to equilibrate after installation and prior to sample
collection.

The sub-slab and exterior soil gas samples will be collected utilizing a laboratory supplied batch
certified stainless-steel Summa® canister (1-liter or 3-liter canisters depending on laboratory
availability) connected to an air-flow regulator calibrated by the laboratory to collect the soil gas
sample at a rate of approximately 100 milliliters per minute. Prior to sample collection, a “shut-
in” test will be conducted on the sampling train and helium leak checks will be conducted at each
sampling point. The purpose of the shut-in test and helium leak check is to ensure short
circuiting with ambient air does not occur during sampling. A description of the shut-in test and
helium leak testing procedures is provided below.

The shut-in test will be conducted by connecting the flow regulator with the vacuum gauge to the
Summa® canister and sealing the flow regulator with the laboratory provided brass cap. Once
the sampling train is “closed”, the sample valve on the Summa® canister will be opened and the
reading on the vacuum gauge will be recorded. The Summa® canister sample valve will then be
closed, and the vacuum gauge will be observed to ensure no vacuum loss occurs. If the vacuum
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reading remains the same, the shut-in test will be considered successful. If vacuum loss occurs,
the flow regulator and/or brass cap will be reseated, and the shut-in test will be repeated until the
vacuum reading remains stable.

Following the shut-in test, the Summa® canister will be connected to the sample point via
Teflon® sample tubing using a brass nut and ferrule assembly to create an airtight seal and the
leak check will be performed. The leak check will be performed by constructing a shroud over
the sample train at each sampling point and flooding the air with helium gas. Helium
concentrations inside the shroud will be measured using a calibrated helium gas detector and
maintained at concentrations of approximately 10% to 20% for the duration of the leak check.
Once helium concentrations stabilize within the shroud, the sample tubing will be purged outside
of the shroud using a syringe and a three-way valve to collect purged soil gas into a Tedlar® bag.
The purged soil gas will then be analyzed using the helium gas detector to ensure that helium
concentrations in the sampling train are less than 10% of the helium concentrations measured
within the shroud.

Following a successful leak check, the intake valve on the Summa® canister will be fully opened
to begin collection of the sub-slab soil gas sample. Vacuum readings on the Summa® canister
will be recorded prior to and following the sampling period to ensure adequate sample volume
was collected. A vacuum of approximately 5 inches of mercury or more will be maintained
within the canisters at the conclusion of the sampling event in accordance with DEQ DWM
guidance.

Following sample collection, the Summa® canisters will be placed in laboratory supplied shipping
containers, properly labeled, and shipped under standard chain-of-custody protocols to a qualified
laboratory for analysis of VOCs by EPA Method TO-15. The laboratory will be requested to use
reporting limits that are below DEQ Residential Vapor Intrusion SGSLs.

After sample collection, the sample location will be estimated using a hand-held GPS unit or by
measuring from known benchmarks within the building (e.g., doors, windows, exterior walls,
etc.), abandoned, and surfaces repaired similar to pre-drilling conditions.
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2.3 Methane and Pressure Measurements

Results of subsurface methane measurements collected from Phase II ESA soil gas monitoring
point SG-5 detected concentrations of methane up to 7.0% bv, which exceeds the LEL for
methane but is below the DEQ Brownfields Program Threshold Criteria for Methane Site
Development threshold value for residential use of 30% bv. H&H proposes to re-install soil gas
monitoring point SG-5, located in the southern portion of the Site (Figure 3) and collect
confirmation subsurface methane and pressure measurements to validate the February 2022
subsurface methane measurements.

In addition, to address DEQ Brownfields Redevelopment Section requests for additional
assessment, up to eight (8) soil gas monitoring points (MP-A through MP-H) will be installed
approximately 15 ft in each direction to further evaluate the extent of measurable methane in
soil gas and pressure differential at the Site. Additional monitoring point locations MP-A
through MP-H will be installed to ensure a methane mitigation determination can be made based
on DEQ Brownfields Redevelopment Section feedback and to further delineate potential
localized areas of impact. The approximate locations of the monitoring points are shown on
Figure 3, and a sample summary table is included as Table 1.

The soil gas monitoring points will be installed to a depth greater than 5 ft bgs and above the
capillary fringe of the water table. Based on the previous Site assessment activities, it is
anticipated that the monitoring points will be installed to a depth of approximately 7 ft bgs.
Monitoring point borings will be advanced at each proposed location using a stainless-steel
decontaminated hand auger and DPT drilling techniques. An approximate 6-inch stainless steel
vapor implant screen attached to Teflon® sample tubing will then be placed at the base of the
borehole. The annular space around the vapor implant screen will be filled with filter sand to a
depth of approximately 6-inches above the vapor screen. Following installation of the sand,
hydrated bentonite will be installed in the boring from the top of the sand to near the ground
surface.

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The sample tubing for each exterior soil gas sampling point will be capped using an airtight
petcock valve immediately following installation to allow subsurface conditions to equilibrate.
Each point will be allowed to equilibrate for a minimum of 24-hours after installation and prior
to collection of field measurements.

After allowing for subsurface equilibration, H&H will collect both static and differential pressure
readings from each monitoring point. The pressure readings will be collected using a Landtec
Gem 5000® and will be collected prior to performing helium leak checks (described in Section
2.2 above).

Following collection of the pressure readings, leaks checks described in Section 2.2 will be
completed at each monitoring point. Following subsurface equilibration and successful leak
checks, a Landtec Gem 5000® or equivalent device will be connected to the sample tubing and
field measurements of oxygen, carbon dioxide, carbon monoxide, hydrogen sulfide, and methane
(percent by volume and percent lower explosive limit) will be collected and recorded by
sampling personnel. After completion of the first round of measurements, H&H will cap the
points with an airtight valve for a minimum of 24-hours prior to collection of a second round of
methane and pressure measurements.

Following a minimum of 24-hours, H&H will collect one additional oxygen, carbon dioxide,
carbon monoxide, hydrogen sulfide, and methane, and pressure measurement from each
monitoring point. To the extent possible, H&H will collect the second round of measurements at
a varying time of the day from the time at which the first sample was collected (i.e., day one
measurements will be collected in the morning and day two measurements will be collected in
the afternoon). A total of two pressure and gas measurements will be collected from each
monitoring point. At the request of the DEQ Brownfields Redevelopment Section, if results of
additional methane and pressure measurements from soil gas monitoring points do not identify
methane at concentrations greater than 1.25 % bv, additional methane and pressure
measurements will be collected from the soil gas monitoring points approximately two weeks
after initial measurements are collected.

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If results of additional methane and pressure measurements from soil gas monitoring points
identify subsurface methane at concentrations greater than 1.25% bv, then additional soil gas
monitoring points will be installed in 15 ft increments to further evaluate the extent of
measurable methane in soil gas and pressure differential at the Site. If the results of additional
methane and pressure measurements from soil gas monitoring points do not identify subsurface
methane at concentrations above 1.25% bv, further methane assessment will not be warranted as
part of Brownfields assessment activities.

Following completion of the sampling activities, the monitoring point borings will be estimated
using a hand-held GPS unit.

2.4 Quality Assurance – Quality Control

To evaluate the reproducibility of the sample results, H&H will collect one duplicate soil sample
which will be submitted for the same laboratory analysis as the parent sample. H&H will collect
a duplicate sub-slab soil gas sample for VOC analysis using a laboratory supplied “T-sampler”
which allows for collection of two samples from the same location simultaneously.

H&H will also collect a confirmation methane and pressure measurement at one sample location.
The confirmation methane and pressure measurements will be collected approximately 10
minutes after collection of the parent measurements. Without an extensive sub-surface
investigation to monitor subsurface pressure changes over time, H&H cannot definitively
calculate or model decreases in soil gas concentrations and pressure over a 10-minute time
interval following collection of the parent measurement. The measurement collection process
does not include removal of significant volumes of air. Therefore, the confirmation sample
results are expected to be adequate for validation of the parent sample results.

Laboratory QA/QC procedures will be employed to ensure appropriate sample handling and
analysis and to aid in the review and validation of the analytical data. QA/QC procedures will be
conducted in accordance with the method protocols and will include regular equipment
maintenance, equipment calibrations, and adherence to specific sample custody and data
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management procedures. Samples will be analyzed in conjunction with appropriate blanks,
laboratory duplicates, continuing calibration standards, surrogate standards, and matrix spiking
standards in accordance with approved methodologies to monitor both instrument and analyst
performance. Laboratory reporting limits for each analyte will be at or below appropriate
screening criteria, where possible. Additionally, H&H will request that the laboratory include
estimated concentrations for compounds that are detected at levels above the laboratory method
detection limit, but below the laboratory reporting limit (J flags).

The laboratory analytical data report and QA package submitted to and analyzed by the
subcontracted laboratory will be provided in an appendix to the final report. Laboratory QA data
consistent with Level II documentation will be provided for this project. A copy of the
completed chain of custody record and shipping receipt will be appended to the corresponding
laboratory analytical report included with the final report.

2.5 Investigation Derived Waste Management

Investigation derived waste (IDW) generated during the proposed assessment activities is
expected to be minimal and will be placed back in the holes or thin spread on-Site. However, if
significant impacts are suspected (i.e., free-product) the soil cuttings will be containerized in
labeled 55-gallon drums and staged on-Site pending analytical results of a composite IDW
sample. Based on laboratory analytical results of IDW samples, the drums will be transported
off-Site to a suitable facility.

2.6 Reporting

Following completion of the assessment activities and receipt of the analytical data, H&H will
document our findings in a Brownfields Assessment Report. The report will include a
description of Site activities, rationale for potential deviations from the work plan (if warranted),
a figure depicting sample locations, tabular summaries of the data, laboratory analytical data, a
discussion of the data in comparison to regulatory screening levels, completed risk calculators as
applicable, conclusions and recommendations concerning our activities, and appendices
including field notes, boring logs, and well construction and abandonment records.
Table 1Sample Summary TableCommercial Equipment Company Charlotte, North Carolina Brownfields Project No. 26002-22-060H&H Project No. ABS-003BF-SB-01 and BF-SB-0210 5-7 1BF-SB-03 10 4-5 1BF-SB-04 and BF-SB-0510 2-4 2COMP-3A through COMP-3F Evaluate soil conditions in shallow soils 2 2 6Lead (6020) (1)SSV-3 Sub-Slab Soil Gas below the slab below the slab 1 VOCs (TO-15)SG-9 through SG-12 Exterior Soil Gas 7 6.5-7 4 VOCs (TO-15)SG-5 and MP-A through MP-H Soil Gas 7 6.5-7 9Methane, CO2, H2S, O2, and static and differential pressure (Gem 5000)BF-SB-DUP Soil varies varies 1VOCs (8260), semi-VOCs (8270), RCRA metals (6020/7471), and hexavalent chromium (7199)SG-DUP-2 Sub-Slab Soil Gas below the slab below the slab 1 VOCs (TO-15)MP-DUP Soil Gas 7 6.5-7 1Methane, CO2, H2S, O2, and static and differential pressure (Gem 5000)Notes:1) Portions of each sample will be submitted for analysis of Toxicity Characteristic Leaching Potential (TCLP) and will be placed on hold pending receipt of total lead concentrations. EPA Method follows laboratory parameter in parenthesis. VOCs = volatile organic compounds; SVOCs = semi-volatile organic compounds; RCRA = Resource Conservation Recovery Actft = feet; QA/QC = Quality Assurance/ Quality Control; VI = Vapor IntrusionSample TypeApproximate Sample Depth (ft)SoilQA/QCSample IDsApproximate Boring Depth (ft)Evaluate potential VI risksVOCs (8260), semi-VOCs (8270), RCRA metals (6020/7471), and hexavalent chromium (7199)Evaluate soil conditions near previously advance Phase II ESA boring locations Number of SamplesLaboratory AnalysisSample Objectivehttps://harthick.sharepoint.com/sites/MasterFiles-1/Shared Documents/AAA-Master Projects/Abacus Capital (ABS)/W. 28th and N.Graham Assembly/Brownfields/Assessment WP/Sample Summary TableTable 1 (Page 1 of 1) Hart & Hickman, PC
USGS The National Map: National Boundaries Dataset, 3DEP ElevationProgram, Geographic Names Information System, National HydrographyDataset, National Land Cover Database, National Structures Dataset, andNational Transportation Dataset; USGS Global Ecosystems; U.S. CensusBureau TIGER/Line data; USFS Road Data; Natural Earth Data; U.S.Department of State Humanitarian Information Unit; and NOAA NationalCenters for Environmental Information, U.S. Coastal Relief Model. Datarefreshed June, 2022.
SITE LOCATION MAP
COMMERCIAL EQUIPMENT CO.N. GRAHAM STREET AND W. 28TH STREETCHARLOTTE, NORTH CAROLINA
DATE: 2-23-23
JOB NO: ABS-003
REVISION NO: 0
FIGURE. 1
2923 South Tryon Street - Suite 100Charlotte, North Carolina 28203704-586-0007 (p) 704-586-0373 (f)License # C-1269 / # C-245 Geology
TITLE
PROJECT
0 2,000 4,000
SCALE IN FEET
Path: S:\AAA-Master Projects\Abacus Capital (ABS)\W. 28th and N.Graham Assembly\Phase II ESA\Figures\Figure 1.mxdN
U.S.G.S. QUADRANGLE MAP
CHARLOTTE EAST, NORTH CAROLINA 2022DERITA, NORTH CAROLINA 2022
QUADRANGLE7.5 MINUTE SERIES (TOPOGRAPHIC)
SITE
BANCROFT STREETRESIDENTIAL
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REVISION NO. 0
JOB NO. ABS-003
DATE: 2-23-23
FIGURE NO. 2
COMMERCIAL EQUIPMENT COMPANY
N. GRAHAM STREET AND W. 28TH STREET
CHARLOTTE, NORTH CAROLINA
SITE MAP
LEGEND
BROWNFIELDS PROPERTY BOUNDARY
PARCEL BOUNDARY
POLE-MOUNTED TRANSFORMER
PAD-MOUNTED TRANSFORMER
ELEVATOR
DUMPSTER
POTENTIAL GASOLINE UST
POTENTIAL OIL/WATER SEPARATOR/
WASTE OIL UST
FORMER DIESEL UST
AIR COMPRESSOR
VENT PIPE
FLOOR DRAIN
2923 South Tryon Street-Suite 100
Charlotte, North Carolina 28203
704-586-0007(p) 704-586-0373(f)
License # C-1269 / #C-245 Geology
NOTES:
1.PARCEL DATA AND AERIAL IMAGERY OBTAINED FROM
MECKLENBURG COUNTY GIS, 2022.
2.UST = UNDERGROUND STORAGE TANK
PEP BOYS DISTRIBUTION CENTER
(700 W. 28TH STREET)
FIRE STATION NO. 11 & FIRE
DEPARTMENT MAINTENANCE SHOP
(620 W. 28TH STREET)
EASY BUILDING SUPPLIES
(600 W. 28TH STREET)
ASHLEY SLING, INC.
(2401 N. GRAHAM STREET)
MCGRANT TAX & BOOKING
(2336 N. GRAHAM STREET)
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TN. GRAHAM STREETGRIMES STREETBANCROFT STREETBANCROFT STREETSTORAGE
(2402/2426 N. GRAHAM STREET)
RESIDENCE
(2415 GRIMES STREET)
OFFICES
(609 W. 28TH STREET)
EQUIPMENT
STORAGE
PALLET AND
CONSTRUCTION
MATERIALS
STORAGE
PALLET AND
PLASTIC TOTE
STORAGE
TRUCK/TRAILER
PARKING
TRUCK/TRAILER
PARKING
FORMER
DISPENSER ISLAND
TRUCK REPAIR
RESIDENTIAL
FORMER
WASH BAY
RESIDENCE
(2409 GRIMES STREET)S:\AAA-Master Projects\Abacus Capital (ABS)\W. 28th and N.Graham Assembly\Brownfields\Assessment WP\Figures\ABS-003 Site Map.dwg, FIG 2, 2/23/2023 2:08:34 PM, kmckinney
BANCROFT STREETRESIDENTIAL
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SSV-2
SG-8
SG-7
SG-1
SG-2
SG-3
SG-4SG-5
SG-6
SB-1
SB-3
SB-5
SB-6 BF-SB-5
BF-SB-4
BF-SB-3
BF-SB-2
BF-SB-1
SSV-3
COMP-3A
COMP-3B
COMP-3C
COMP-3D
COMP-3E
COMP-2
COMP-1
COMP-5
COMP-4
COMP-3
SB-4
TMW-1
COMP-3F
TMW-2
TMW-3
TMW-5
TMW-4
TMW-6/SB-7
SSV-1
A
B
C
D
E
A
A
A
A
B
B
B
B
C
C
C
C
D
D
D
D
E
E
E
E
F
SB-2
SG-12
SG-10
SG-9
SG-11
SB-6E
MP-C
MP-H
MP-E
MP-B
MP-A
MP-D
MP-G
MP-F
SB-5
SG-5B
SG-5
COMP-4
TMW-5
TMW-6/SB-7
B
C
D
MP-C
MP-B
MP-A
MP-D
MP-E
MP-H
MP-G
MP-F
REVISION NO. 0
JOB NO. ABS-003
DATE: 2-23-23
FIGURE NO. 3
PROPOSED SAMPLE LOCATION MAP
LEGEND
BROWNFIELDS PROPERTY BOUNDARY
PARCEL BOUNDARY
POTENTIAL GASOLINE UST
POTENTIAL OIL/WATER SEPARATOR/
WASTE OIL UST
FORMER DIESEL UST
VENT PIPE
FLOOR DRAIN
EXISTING BUILDING
PROPOSED RESIDENTIAL BUILDING
PROPOSED TOWNHOME STYLE
APARTMENT
TEMPORARY MONITORING WELL
SOIL BORING
CO-LOCATED TEMPORARY MONITORING
WELL/SOIL BORING
ALIQUOT SOIL BORING
SOIL GAS POINT
SUB-SLAB SOIL GAS POINT
PROPOSED SOIL BORING LOCATION
PROPOSED SUB-SLAB SOIL GAS POINT
PROPOSED SOIL GAS POINT
PROPOSED SUBSURFACE METHANE
MONITORING POINT
2923 South Tryon Street-Suite 100
Charlotte, North Carolina 28203
704-586-0007(p) 704-586-0373(f)
License # C-1269 / #C-245 Geology
NOTES:
1. PARCEL DATA OBTAINED FROM MECKLENBURG COUNTY
GIS, 2022.
2. UST = UNDERGROUND STORAGE TANK
3. GREY SAMPLE LOCATIONS WERE COLLECTED DURING
PHASE II ESA ACTIVITIES COMPLETED BY H&H IN
FEBRUARY 2022.
PEP BOYS DISTRIBUTION CENTER
(700 W. 28TH STREET)
FIRE STATION NO. 11 & FIRE
DEPARTMENT MAINTENANCE SHOP
(620 W. 28TH STREET)
EASY BUILDING SUPPLIES
(600 W. 28TH STREET)
ASHLEY SLING, INC.
(2401 N. GRAHAM STREET)
MCGRANT TAX & BOOKING
(2336 N. GRAHAM STREET)
W.

2
8
T
H

S
T
R
E
E
TN. GRAHAM STREETGRIMES STREETBANCROFT STREETSTORAGE
(2402/2426 N. GRAHAM STREET)
RESIDENCE
(2415 GRIMES STREET)
OFFICES
(609 W. 28TH STREET)
FORMER
DISPENSER ISLAND
TRUCK REPAIR
FORMER
WASH BAY
RESIDENCE
(2409 GRIMES STREET)
COMMERCIAL EQUIPMENT COMPANY
N. GRAHAM STREET AND W. 28TH STREET
CHARLOTTE, NORTH CAROLINA
PROPOSED AMENITY AREA
S:\AAA-Master Projects\Abacus Capital (ABS)\W. 28th and N.Graham Assembly\Brownfields\Assessment WP\Figures\ABS-003 Site Map.dwg, FIG 3, 2/24/2023 11:50:05 AM, kmckinney

Appendix A

Previous Assessment Summaries
Table 1 Summary of Soil Analytical DataCommercial Equipment CompanyCharlotte, North CarolinaH&H Job No. ABS-003Evaluation AreaPotential USTSample IDCOMP-1 COMP-2 COMP-3 COMP-5 SB-1 SB-2 SB-3Date2/7/20222/9/2022Depth (ft bgs)0-2 0-2 0-2 0-2 0-2 0-2 0-2 10-12 8-10Sample Type Range Mean Range Mean UnitsVOCs (8260D)Acetone<0.0510 <0.0423 <0.0555 <0.0970 <0.0796 <0.0503 <0.0401 <0.0561 <0.049914,000 210,000-- -- -- -- --n-Butylbenzene<0.0038 <0.0031 <0.0041 <0.0071 <0.0059 <0.0037 <0.0029 <0.0041 <0.0037780 12,000-- -- -- -- --sec-Butylbenzene<0.0035 <0.0029 <0.0038 <0.0066 <0.0055 <0.0034 <0.0027 <0.0038 <0.00341600 23,000-- -- -- -- --2-Chlorotoluene<0.0028 <0.0023 <0.0031 <0.0053 <0.0044 <0.0028 <0.0022 <0.0031 <0.0028310 4,700-- -- -- -- --Ethylbenzene 0.0111 0.0041 J 0.0053 J<0.0070 <0.00580.0043 J<0.0029 <0.0041 <0.00366.1 27-- -- -- -- --Isopropylbenzene (cumene)<0.0027 <0.0022 <0.0029 <0.0051 <0.0042 <0.0027 <0.0021 <0.0030 <0.0026410 2,100-- -- -- -- --Methylene chloride 0.0528<0.0181 <0.0237 <0.0414 <0.0340 <0.0214 <0.0171 <0.0239 <0.021358 650-- -- -- -- --Naphthalene<0.0042 <0.0035 <0.0045 <0.0079 <0.0065 <0.0041 <0.0033 <0.0046 <0.00412.1 8.8-- -- -- -- --n-Propylbenzene<0.0028 <0.0023 <0.0031 <0.0054 <0.0044 <0.0028 <0.0022 <0.0031 <0.0028780 5,100-- -- -- -- --Tetrachloroethene<0.0025 <0.0021 <0.0027 <0.0048 <0.0039 <0.00285 <0.0020 <0.0028 <0.002517 82-- -- -- -- --Toluene 0.0087<0.0019 <0.0025 <0.0043 <0.0035 <0.0022 <0.0018 <0.0025 <0.0022990 9,700-- -- -- -- --1,2,4-Trimethylbenzene 0.0095<0.0018 <0.0024 <0.0041 <0.0034 <0.0021 <0.0017 <0.0024 <0.002163 370-- -- -- -- --m&p-Xylene 0.0423 0.0088 J<0.0059 <0.0103 <0.0085 <0.0054 <0.0043 <0.0060 <0.0053120 520-- -- -- -- --o-Xylene 0.0108<0.0029 <0.0038 <0.0067 <0.0055 <0.0035 <0.0028 <0.0039 <0.0034140 590-- -- -- -- --Xylene (Total) 0.0530 0.0088 J<0.0049 <0.0086 <0.0071 <0.0045 <0.0036 <0.0050 <0.0044120 530SVOCs (8270E)Benzo(b)fluoranthene<0.147<0.128<0.1440.216 J<0.151 <0.140 <0.128 <0.151 <0.1461.1 21-- -- -- -- --Chrysene<0.160<0.140<0.1580.174 J<0.165 <0.152 <0.140 <0.165 <0.159110 2,100-- -- -- -- --bis(2-Ethylhexyl)phthalate<0.171<0.149<0.168 <0.179 <0.176 <0.163 <0.149 <0.176 <0.17039 160-- -- -- -- --Fluoranthene<0.151<0.132<01480.245 J<0.155 <0.144 <0.132 <0.155 <0.150480 6,000-- -- -- -- --1-Methylnaphthalene<0.155<0.135<0.152 <0.162 <0.159 <0.147 <0.135 <0.159 <0.15418 73-- -- -- -- --2-Methylnaphthalene<0.176<0.157<0.173 <0.184 <0.181 <0.168 <0.154 <0.181 <0.17548 600-- -- -- -- --Phenanthrene<0.144<0.126<0.142 <0.151 <0.148 <0.137 <0.126 <0.148 <0.143NE NE-- -- -- -- --Pyrene<0.179<0.156<0.1760.245 J<0.184 <0.170 <0.156 <0.184 <0.178360 4,500-- -- -- -- --Metals (6020B/7471B/7199)Arsenic242.92.6 3.4 4.2 1.9 2.6 1.2 1.60.68 3.0--1.0 - 18 4.8 1.1 - 3.0 2.3Barium18070 MS-11590 64 54 14 100 14 283,100 47,000--50 - 1,000 356 38 - 110 74Cadmium 0.16 J0.15 J1.8<0.062 <0.0610.22 J 0.13 J<0.0630.14 J1.4 20--1.0 - 10 4.3 ND - 0.36 J 0.13Chromium (total)7737 MS-1140 53 67 55 56 13 33NE NE--7.0 - 300 65 14 - 45 31.3Chromium (VI)0.42 J0.09 J0.24 J 0.36 J 0.35 J 0.17 J 0.29 J 0.35 J 0.660.31 6.5--NS NS 0.34 J - 0.98 J 0.62Chromium (III)76.5836.9139.71 52.64 66.65 54.83 55.71 12.65 32.3423,000 350,000--NS NS 13.7 - 44.0 30.7Lead682599025 19 6.9 16 12 9.1400 800--ND - 50 16 11 - 36 20.7Mercury0.0340.0340.082 0.051 0.037 0.13 0.034 J 0.019 J 0.029 J4.7 70--0.03 - 0.52 0.121 0.024 J - 0.097 0.074Selenium 0.49 J 0.53 J 0.60 J 0.45 J 0.44 0.55 J 0.60 J<0.350.62 J78 1,200--<0.1 - 0.8 0.42 ND NDSilver 0.13 0.045 R-04, J 0.50 0.098 J 0.11<0.0180.045 J<0.018 <0.01878 1,200--ND - 5.0 NS 0.033 J - 0.60 0.60Metals (6010D TCLP)ChromiumNA NA NA NA NA NA NA NA NA-- --5 mg/L-- -- -- --LeadNA NA <0.19 mg/L NA NA NA NA NA NA-- --5 mg/L-- -- -- --Notes:1) North Carolina Department of Environmental Quality (DEQ) Preliminary Soil Remediation Goals (PSRGs) dated July 2022.2) Environmental Protection Agency (EPA) Maximum Concentrations of Contaminants for Toxicity Characteristics Leaching Procedure (TCLP) regulatory level dated November 2004. 3) Range and mean values of background metals for North Carolina soils taken from Elements in North American Soils by Dragun and Chekiri, 2005; Cd and Ag concentrations were taken from Southeastern and Conterminous U.S. Soils.4) Background metals data collected from Cotton Warehouse Brownfields property (Brownfields Project No. 24013-20-060). Soil concentrations are reported in milligrams per kilogram (mg/kg) unless otherwise noted.Compound concentrations are reported to the laboratory method detection limits.Laboratory analytical methods are shown in parentheses.With the exception of metals, only constituents detected in at least one sample are shown in the table above.Composite soil samples that were analyzed for VOCs were collected from undisturbed portions of soil and placed directly into laboratory supplied glassware.Bold values exceed the Residential PSRGs and background levels in the case of metals. Underlined values exceed the Industrial/Commercial PSRGs and background levels in the case of metals.VOCs = volatile organic compounds; SVOCs = semi-volatile organic compounds; UST = underground storage tank; ft bgs= feet below ground surface; mg/L= milligrams per liter; NS = not specified; NE = not established; -- = not applicable MS-11 = Matrix spike recovery outside of control limits. Possibility of sample matrix effects that lead to a high bias for reported result or non-homogeneous sample aliquots cannot be eliminated.R-04 = Duplicate relative percent difference is less useful indicator of sample precision for sample results that are <5 times the reporting limit.J = Compound was detected above the laboratory method detection limit, but below the laboratory reporting limit resulting in a laboratory estimated concentration. mg/kgCOMP-4/COMP-DUPResidential PSRGs (1)Industrial/ Commercial PSRGs (1)Maximum Concentration for TCLP (2)Background Metals in Nearby Brownfield Properties (4)CompositeGrab2/10/2022Western Portion of the Site Eastern Portion of the Site Former Dispenser IslandScreening Criteria2/7/2022 2/10/2022Regional Background Metals in Soil (3)https://harthick.sharepoint.com/sites/MasterFiles‐1/Shared Documents/AAA‐Master Projects/Abacus Capital (ABS)/W. 28th and N.Graham Assembly/Phase II ESA/Tables/Data Tables.xlsxTable 1 (Page 1 of 2)Hart & Hickman, PC
Table 1 Summary of Soil Analytical DataCommercial Equipment CompanyCharlotte, North CarolinaH&H Job No. ABS-003Evaluation AreaOWSSample IDSB-5 SB-6DateDepth (ft bgs)12-14 12-14Sample Type Range Mean Range Mean UnitsVOCs (8260D)Acetone<0.504 <0.0581 <0.0560 <0.06340.0676 J 0.0714 J 14,000 210,000-- -- -- -- --n-Butylbenzene<0.0037 <0.0043 <0.0041 <0.00470.0166 0.0728 780 12,000-- -- -- -- --sec-Butylbenzene<0.0035 <0.0040 <0.0038 <0.00430.0118 0.0555 1600 23,000-- -- -- -- --2-Chlorotoluene<0.0028 <0.0032 <0.00310.0056 J<0.00360.0071 J 310 4,700-- -- -- -- --Ethylbenzene<0.0037 <0.0042 <0.0041 <0.00460.0159 0.0324 6.1 27-- -- -- -- --Isopropylbenzene (cumene)<0.0027 <0.0031 <0.0030 <0.00340.0059 J 0.0217 410 2,100-- -- -- -- --Methylene chloride<0.0215 <0.0248 <0.0239 <0.02710.0452<0.029658 650-- -- -- -- --Naphthalene<0.0041 <0.0048 <0.0046 <0.00520.111 0.390 2.1 8.8-- -- -- -- --n-Propylbenzene<0.0028 <0.0032 <0.0031 <0.00350.011 0.0462 780 5,100-- -- -- -- --Tetrachloroethene<0.0025 <0.00290.0177<0.00310.0179 0.0835 17 82-- -- -- -- --Toluene<0.0022 <0.0026 <0.0025 <0.00280.0082 J<0.0031990 9,700-- -- -- -- --1,2,4-Trimethylbenzene<0.0021 <0.0025 <0.0024 <0.00270.0231 0.116 63 370-- -- -- -- --m&p-Xylene<0.0054 <0.0062 <0.0060 <0.0068 <0.0070 <0.0074120 520-- -- -- -- --o-Xylene<0.0035 <0.0040 <0.0039 <0.0044 <0.0045 <0.0048140 590-- -- -- -- --Xylene (Total)<0.0045 <0.0052 <0.0050 <0.0056 <0.0059 <0.0062120 530-- -- --SVOCs (8270E)Benzo(b)fluoranthene<0.144 <0.143 <0.155 <0.167 <0.161 <0.1711.1 21-- -- -- -- --Chrysene<0.157 <0.156 <0.169 <0.182 <0.175 <0.187110 2,100-- -- -- -- --bis(2-Ethylhexyl)phthalate<0.167 <0.166 <0.1810.243 J<0.1870.314 J39 160-- -- -- -- --Fluoranthene<0.148 <0.147 <0.159 <0.172 <0.165 <0.176480 6,000-- -- -- -- --1-Methylnaphthalene<0.152 <0.151 <0.164 <0.176 <0.1700.230 J18 73-- -- -- -- --2-Methylnaphthalene<0.173 <0.171 <0.186 <0.2010.220 J 0.370 J48 600-- -- -- -- --Phenanthrene<0.141 <0.140 <0.1520.173 J<0.158 <0.168NE NE-- -- -- -- --Pyrene<0.175 <0.174 <0.189 <0.204 <0.196 <0.208360 4,500-- -- -- -- --Metals (6020B/7471B/7199)Arsenic2.4 2.8 1.6 1.6 1.7 2.20.68 3.0--1.0 - 18 4.8 1.1 - 3.0 2.3Barium11 11 56 27 67 483,100 47,000--50 - 1,000 356 38 - 110 74Cadmium 0.15 J 0.14 J 0.10 J 0.20 J 1.4 0.811.4 20--1.0 - 10 4.3 ND - 0.36 J 0.13Chromium (total)140 150 46 38 74 91NE NE--7.0 - 300 65 14 - 45 31.3Chromium (VI)0.38 J 0.38 J 0.86 0.18 J 0.57 J 0.17 J0.31 6.5--NS NS 0.34 J - 0.98 J 0.62Chromium (III)139.62 149.62 45.14 37.82 73.43 90.8323,000 350,000--NS NS 13.7 - 44.0 30.7Lead8.3 8.7 38 6.6 10 16400 800--ND - 50 16 11 - 36 20.7Mercury0.053 0.055 0.019 J 0.031 J 0.062 0.030 J4.7 70--0.03 - 0.52 0.121 0.024 J - 0.097 0.074Selenium 0.83 J 1.1 J 0.48 J0.66 J 0.51 J 1.1 J78 1,200--<0.1 - 0.8 0.42 ND NDSilver 0.026 J 0.028 J 0.024 J 0.020 J 0.028 J 0.034 J 78 1,200--ND - 5.0 NS 0.033 J - 0.60 0.60Metals (6010D TCLP)Chromium<0.036 mg/L <0.036 mg/L NA NA NA NA-- --5 mg/L-- -- -- --LeadNA NA NA NA NA NA-- --5 mg/L-- -- -- --Notes:1) North Carolina Department of Environmental Quality (DEQ) Preliminary Soil Remediation Goals (PSRGs) dated July 2022.2) Environmental Protection Agency (EPA) Maximum Concentrations of Contaminants for Toxicity Characteristics Leaching Procedure (TCLP) regulatory level dated November 2004. 3) Range and mean values of background metals for North Carolina soils taken from Elements in North American Soils by Dragun and Chekiri, 2005; Cd and Ag concentrations were taken from Southeastern and Conterminous U.S. Soils.4) Background metals data collected from Cotton Warehouse Brownfields property (Brownfields Project No. 24013-20-060). Soil concentrations are reported in milligrams per kilogram (mg/kg) unless otherwise noted.Compound concentrations are reported to the laboratory method detection limits.Laboratory analytical methods are shown in parentheses.With the exception of metals, only constituents detected in at least one sample are shown in the table above.Composite soil samples that were analyzed for VOCs were collected from undisturbed portions of soil and placed directly into laboratory supplied glassware.Bold values exceed the Residential PSRGs and background levels in the case of metals. Underlined values exceed the Industrial/Commercial PSRGs and background levels in the case of metals.VOCs = volatile organic compounds; SVOCs = semi-volatile organic compounds; UST = underground storage tank; ft bgs= feet below ground surface; mg/L= milligrams per liter; NS = not specified; NE = not established; -- = not applicable MS-11 = Matrix spike recovery outside of control limits. Possibility of sample matrix effects that lead to a high bias for reported result or non-homogeneous sample aliquots cannot be eliminated.R-04 = Duplicate relative percent difference is less useful indicator of sample precision for sample results that are <5 times the reporting limit.J = Compound was detected above the laboratory method detection limit, but below the laboratory reporting limit resulting in a laboratory estimated concentration. Maximum Concentration for TCLP (2)Screening Criteriamg/kgGrabRegional Background Metals in Soil (3)Background Metals in Nearby Brownfield Properties (4)SB-4/SB-DUP-3Floor Drains Former USTSB-7/SB-DUP-2Residential PSRGs (1)Industrial/ Commercial PSRGs (1)2/10/2022 2/9/20222-414-16https://harthick.sharepoint.com/sites/MasterFiles‐1/Shared Documents/AAA‐Master Projects/Abacus Capital (ABS)/W. 28th and N.Graham Assembly/Phase II ESA/Tables/Data Tables.xlsxTable 1 (Page 2 of 2)Hart & Hickman, PC
Table 2Summary of Well Construction and Groundwater Depth DataCommercial Equipment CompanyCharlotte, North CarolinaH&H Job No. ABS-003Well IDTotal Depth (ft bgs)Screen Length (ft)Screen Interval (ft bgs)Depth to Groundwater (ft bgs)TOC Elevation (ft above msl)Groundwater Elevation (ft above msl)TMW-1 22 15 7-22 13.68 749.05 735.37TMW-2 25 15 10-25 19.70 748.58 728.88TMW-330 15 15-30 18.72 746.45 727.73TMW-425 15 10-25 13.56 748.56 735.00TMW-525 15 10-25 14.99 744.54 729.55TMW-625 15 10-25 17.81 747.45 729.64 Notes:Depth to groundwater measurements were collected by H&H on February 10, 2022. Temporary monitoring wells TMW-1 through TMW-6 were surveyed by H&H relative to known benchmarks on February 14, 2022. Benchmark elevations estalished by McAdams on October 14, 2021. TOC = top of casing; ft bgs = feet below ground surface; msl = mean sea levelhttps://harthick.sharepoint.com/sites/MasterFiles-1/Shared Documents/AAA-Master Projects/Abacus Capital (ABS)/W. 28th and N.Graham Assembly/Phase II ESA/Tables/Data Tables.xlsx9/12/2022Table 2 (Page 1 of 1)Hart & Hickman, PC
Table 3 Summary of Groundwater Analytical DataCommercial Equipment CompanyCharlotte, North CarolinaH&H Job No. ABS-003Evaluation Area Upgradient Upgradient Sample IDTMW-1 TMW-2 TMW-3 TMW-4DateUnitsVOCs (8260D)Benzene <0.34 <0.34 <0.34 <0.34 <0.34 <0.340.89 J 0.90 J11.66.9Carbon tetrachloride<0.330.86 J<0.33 <0.33 <0.33 <0.33 <0.33 <0.330.3 0.411.8Chloroform <0.431.1<0.43 <0.43 <0.43 <0.43 <0.43 <0.4370 0.81 3.62-Chlorotoluene<0.32 <0.32 <0.32 <0.32 <0.32 <0.327.0 7.2100 NENEDi-Isopropyl Ether <0.310.96 J<0.31 <0.31 <0.31 <0.31 <0.31 <0.3170 1,4005,9001,2-Dichloroethane <0.322.8<0.32 <0.32 <0.32 <0.32 <0.32 <0.320.4 2.29.8cis-1,2-Dichloroethene<0.38 <0.38 <0.38 <0.38 <0.38 <0.388.7 8.470 NENEEthylbenzene <0.30 <0.30 <0.30 <0.30 <0.30 <0.301.6 1.6600 3.5152-Hexanone<0.48 <0.48 <0.48 <0.48 <0.480.50 J<0.48 <0.48NE 1,600 6,900Naphthalene <0.64 <0.64 <0.64 <0.64 <0.64 <0.6423.624.064.620Tetrachloroethene <0.29 <0.29 <0.29 <0.29 <0.29 <0.295.3 5.10.7 12 48Trichloroethene<0.38 <0.38 <0.38 <0.38 <0.38 <0.381.61.531.04.4Trichlorofluoromethane 0.39 J<0.30 <0.30 <0.30 <0.30 <0.30 <0.30 <0.302,000 NE NEo-Xylene<0.34 <0.34 <0.34 <0.34 <0.34 <0.340.91 J 0.99 J500 98 410Xylenes (total) <0.34 <0.34 <0.34 <0.34 <0.34 <0.340.91 J 0.99 J500 77 320SVOCs (8270E)1-Methylnaphthalene<1.7 <1.7 <1.8 <1.8 <1.7 <1.810.9 16.51NENE2-Methylnaphthalene<1.6 <1.6 <1.7 <1.7 <1.6 <1.714.3 22.2 30 NE NENaphthalene<1.7 <1.7 <1.9 <1.9 <1.7 <1.911.115.664.620Metals (6020B/7470A)Arsenic<0.31 <0.31 <0.31 <0.31 <0.31 <0.31 <0.31 <0.3110 NE NEBarium 57 89 60 35 36 35 32 31 700 NE NECadmium<0.0300.061 J 0.041 R-04, J<0.0300.067 J 0.067 J 0.063 J 0.066 J 2 NE NEChromium (Total) 2.2 1.7112.5 3.1 2.6 1.8 1.5 10 NE NELead<0.13 <0.130.21 J 0.30 J<0.13 <0.13 <0.13 <0.1315 NE NEMercury<0.000040 <0.000040 <0.000040 <0.000040 <0.000040 <0.000040 <0.000040 <0.0000401 0.18 0.75Selenium<0.95 <0.95 <0.95 <0.95 <0.95 <0.95 <0.95 <0.9520 NE NESilver<0.027 <0.027 <0.027 <0.027 <0.027 <0.027 <0.027 <0.02720 NE NENotes:1) North Carolina Department of Environmental Quality (DEQ) 15A NCAC 02L.0202 Groundwater Standards (2L Standards) dated April 2022.2) DEQ Division of Waste Management (DWM) Vapor Intrusion Groundwater Screening Levels (GWSLs) dated July 2022. Concentrations are reported in micrograms per liter (µg/L).Compound concentrations are reported to the laboratory method detection limits.Laboratory analytical methods are shown in parentheses.With the exception of metals, only constituents detected in at least one sample are shown in the table above.Bold values exceed the 2L Standard.Underlined values exceed the DWM Residential Vapor Intrusion GWSLs. Shaded values exceed the DWM Non-Residential Vapor Intrusion GWSLs. VOCs = volatile organic compounds; SVOCs = semi-volatile organic compounds; UST = underground storage tank; NE = not establishedR-04 = Duplicate relative percent difference is a less useful indicator of sample precision for sample results that are <5 times the reporting limit.J = Compound was detected above the laboratory method detection limit, but below the laboratory reporting limit resulting in a laboratory estimated concentration. µg/LScreening Criteria 2L Standards (1) Residential GWSLs (2)Non-Residential GWSLs (2)TMW-5/TMW-DUP-2 TMW-6/TMW-DUP-12/10/20222/11/2022Former USTsDowngradient Downgradient https://harthick.sharepoint.com/sites/MasterFiles‐1/Shared Documents/AAA‐Master Projects/Abacus Capital (ABS)/W. 28th and N.Graham Assembly/Phase II ESA/Tables/Data Tables.xlsx9/12/2022Table 3 (Page 1 of 1)Hart & Hickman, PC
Table 4Summary of Soil Gas Analytical DataCommercial Equipment CompanyCharlotte, North CarolinaH&H Job No. ABS-003Evaluation Area2426 N. Graham Street609 W. 28th StreetSample IDSSV-1 SSV-2 SG-1 SG-2 SG-3 SG-4Sample Date2/11/2022 2/14/2022 2/11/2022 2/14/2022Sample Type UnitsVOCs (TO-15)Acetone 59.4 8.52 24.2 9.37 38.9 19.3 NE NEBenzene 0.626 J 0.367 J25.2 21.8 26.04.73 12 160Benzyl chloride<0.148 <0.148 <0.148 <0.1484.83 J<0.1481.9 25Bromodichloromethane<0.150 <0.150 <0.150 <0.1500.570 J<0.1502.5 331,3-Butadiene<0.328 <0.32834.51.89<0.328 <0.3283.1 41Carbon Disulfide 13.3 B 0.514 JB 45.5 77.2 11.9 B 4.12 JB 4,900 61,000Carbon Tetrachloride<0.155 <0.155 <0.1551.11 J 0.705 J<0.15516 200Chlorobenzene<0.107 <0.107 <0.1072.86 0.663 J<0.107350 4,400Chloroform<0.0864 <0.0864 <0.08646.891.70 J11.14.1 53Chloromethane<0.0673 <0.0673 <0.0673 <0.0673 <0.0673 <0.0673630 7,900Cyclohexane<0.161 <0.16166.8 13.5 4.36 7.22 42,000 530,000Dichlorodifluoromethane 3.09 3.33<0.1343.85 3.54 3.28 700 8,8001,2-Dichloropropane<0.205 <0.2051.21 J<0.205 <0.205 <0.20525 330Ethylbenzene 0.812 J 0.404 J56.433.055.14.05 37 4904-Ethyltoluene<0.128 <0.12822.6 4.38 12.5 0.600 J NE NE1,1,2-Trichlorotrifluoroethane 0.667 J 33.1 9.67 2.41 J<0.5610.713 J 35,000 440,000n-Heptane 0.443 J 0.451 J 166 191 107 2.52 2,800 35,000n-Hexane 0.518 J 0.430 J 49.7 28.8 5.92 1.06 J 4,900 61,0002-Hexanone 4.15 4.06<0.285 <0.2858.27<0.285210 2,600Isopropyl Alcohol 6.87 B<0.1393.65 JB<0.1394.20 JB<0.1391,400 18,0002-Butanone (MEK) 1.89 1.12 J 8.09 4.85 5.57 2.15 35,000 440,0004-Methyl-2-pentanone (MIBK) 0.705 J<0.1214.36<0.1214.35 0.594 J 21,000 260,000Methylene Chloride 1.21 J 1.04 J<0.4891.36 J 1.32 J 0.952 J 3,400 54,000Naphthalene4.51<0.18310.24.225.294.192.8 36Propylene<0.242 <0.242319<0.2423.10<0.24221,000 260,000Styrene<0.124 <0.124 <0.124 <0.1244.47<0.1247000 88,0001,1,2,2-Tetrachloroethane<0.104 <0.104 <0.104 <0.1041.78 J<0.10413 21Tetrachloroethene 14.1 59.1 3.83 2.07 J 2.31 J 0.590 J 280 3,500Tetrahydrofuran 0.478 J<0.1071.06 J 0.596 J 0.855 J<0.10714,000 180,000Toluene 3.77 1.60 J 312 272 390 58.5 35,000 440,000Trichlorofluoromethane 1.83 J 1.87 J 1,870 2.44 J 2.25 J 3.55 NE NE1,2,4-Trimethylbenzene 1.45 J 1.03 J 132 8.24 36.5 2.08 J 420 5,3001,3,5-Trimethylbenzene 0.590 J<0.23667.6 2.37 J 11.7 0.693 J 420 5,300o-Xylene 1.31 J 0.638 J 98.2 27.0 62.6 5.70 700 8,800m&p-Xylene 3.24 J 1.54 J 201 90.0 187 12.0 700 8,800Xylene (total) 4.55 J 2.18 J 299 117 250 17.7 700 8,800Notes:1) North Carolina Department of Environmental Quality (DEQ) Division of Waste Management (DWM) Vapor Intrusion Sub-Slab & Exterior Soil Gas Screening Levels (SGSLs) dated July 2022.Concentrations are reported in micrograms per cubic meter (µg/m3).Compound concentrations are reported to the laboratory method detection limits.Laboratory analytical method is shown in parentheses. Only compounds detected in at least one sample are shown in the above table.Bold values exceed the DWM Residential Vapor Intrusion SGSL. VOCs = volatile organic compounds; NE = not establishedB = Analyte detected in blank.J = Compound was detected above the laboratory method detection limit, but below the laboratory reporting limit resulting in a laboratory estimated concentration.µg/m3Proposed Residential Building2/14/2022Exterior Soil Gas Sub-Slab Soil GasScreening CriteriaResidential SGSLs (1)Non-Residential SGSLs (1)https://harthick.sharepoint.com/sites/MasterFiles‐1/Shared Documents/AAA‐Master Projects/Abacus Capital (ABS)/W. 28th and N.Graham Assembly/Phase II ESA/Tables/Data Tables.xlsx9/12/2022Table 4 (Page 1 of 2)Hart & Hickman, PC
Table 4Summary of Soil Gas Analytical DataCommercial Equipment CompanyCharlotte, North CarolinaH&H Job No. ABS-003Evaluation AreaSample IDSG-6 SG-7 SG-8Sample DateSample Type UnitsVOCs (TO-15)Acetone 29.2 24.952.281.9 101 NE NEBenzene25.2 27.0 87.8 15.33.02 12 160Benzyl chloride<0.148 <0.148<0.148<0.148 <0.1481.9 25Bromodichloromethane<0.150 <0.150<0.150<0.150 <0.1502.5 331,3-Butadiene5.90 6.27 8.21<0.328 <0.3283.1 41Carbon disulfide 22.3 23.666.78.82 B 1.98 JB 4,900 61,000Carbon tetrachloride 1.07 J 1.20 J<0.155<0.155 <0.15516 200Chlorobenzene<0.107 <0.107<0.107<0.107 <0.107350 4,400Chloroform<0.0864 <0.0864<0.08642.40 J<0.08644.1 53Chloromethane<0.0673 <0.06732.57<0.0673 <0.0673630 7,900Cyclohexane 7.86 8.2225.311.9<0.16142,000 530,000Dichlorodifluoromethane 4.31<0.1343.683.18 3.32 700 8,8001,2-Dichloropropane<0.205 <0.205<0.205<0.205 <0.20525 330Ethylbenzene51.3 54.313.726.6 3.10 37 4904-Ethyltoluene 9.23 9.603.797.27 0.909 J NE NE1,1,2-Trichlorotrifluoroethane 1.14 J 1.71 J1.13 J0.874 J<0.56135,000 440,000n-Heptane 143 15211788.4 11.0 2,800 35,000n-Hexane 49.0 50.874.39.55 2.60 4,900 61,0002-Hexanone<0.285 <0.285<0.285<0.285 <0.285210 2,600Isopropyl Alcohol 3.93 JB 3.59 JB<0.1394.05 JB 4.05 JB 1,400 18,0002-Butanone (MEK) 5.00 5.429.115.90 5.04 35,000 440,0004-Methyl-2-pentanone (MIBK) 2.27 2.616.905.80 5.55 21,000 260,000Methylene Chloride<0.489 <0.489<0.4891.58 J 0.674 J 3,400 54,000Naphthalene5.26 5.46 7.85 4.85 5.692.8 36Propylene 168 156329<0.242 <0.24221,000 260,000Styrene<0.124 <0.124<0.124<0.1244.47 7000 88,0001,1,2,2-Tetrachloroethane<0.104 <0.104<0.104<0.104 <0.10413 21Tetrachloroethene 1.63 J 1.81 J0.705 J2.74 J 1.07 J 280 3,500Tetrahydrofuran 0.805 J<0.1071.510.876 J 0.696 J 14,000 180,000Toluene 442 410186188 35.2 35,000 440,000Trichlorofluoromethane 83.2 86.3<0.1303.96 1.83 J NE NE1,2,4-Trimethylbenzene 25.927.1 33.7 21.8 4.84420 5,3001,3,5-Trimethylbenzene 8.769.48 19.6 6.32 0.988 J420 5,300o-Xylene 57.5 61.024.230.2 4.09 700 8,800m&p-Xylene 174 18241.988.6 10.4 700 8,800Xylene (total) 232 24366.1119 14.5 700 8,800Notes:1) North Carolina Department of Environmental Quality (DEQ) Division of Waste Management (DWM) Vapor Intrusion Sub-Slab & Exterior Soil Gas Screening Levels (SGSLs) dated July 2022.Concentrations are reported in micrograms per cubic meter (µg/m3).Compound concentrations are reported to the laboratory method detection limits.Laboratory analytical method is shown in parentheses. Only compounds detected in at least one sample are shown in the above table.Bold values exceed the DWM Residential Vapor Intrusion SGSL. VOCs = volatile organic compounds; NE = not establishedB = Analyte detected in blank.J = Compound was detected above the laboratory method detection limit, but below the laboratory reporting limit resulting in a laboratory estimated concentration.µg/m3Exterior Soil GasProposed Residential BuildingSG-5/SG-DUPResidential SGSLs (1)Non-Residential SGSLs (1)Screening Criteria2/11/2022https://harthick.sharepoint.com/sites/MasterFiles‐1/Shared Documents/AAA‐Master Projects/Abacus Capital (ABS)/W. 28th and N.Graham Assembly/Phase II ESA/Tables/Data Tables.xlsx9/12/2022Table 4 (Page 2 of 2)Hart & Hickman, PC
Table 5Summary of Subsurface Methane Gas MeasurementsCommercial Equipment CompanyCharlotte, North CarolinaH&H Job No. ABS-003% % LELBarometric (in. Hg)Static (in. H₂O)2/14/2022 9:32 0.3 0.7 0.0001 0.0 0.1 2.0 29.39 0.062/15/2022 13:59 0.4 0.9 0.0 0.0 0.0 0.0 29.76 -0.072/14/2022 8:37 20.0 1.3 0.0 0.0 0.0 0.0 29.39 -0.062/15/2022 12:48 19.0 1.2 0.0 0.0 0.0 0.0 29.78 0.042/14/2022 10:30 20.0 1.3 0.0 0.0 0.0 0.0 29.40 -0.092/15/2022 12:55 19.2 1.3 0.0 0.0 0.0 0.0 29.77 -0.012/14/2022 7:57 14.3 3.6 0.0 0.0 0.1 2.0 29.42 -0.042/15/2022 12:39 14.0 1.5 0.0 0.0 0.0 0.0 29.72 0.072/14/2022 10:37 1.0 0.3 0.0002 0.07.0>100 29.48 0.022/15/2022 13:03 0.9 0.3 0.0001 0.06.7>100 29.79 0.092/14/2022 10:47 0.9 0.3 0.0001 0.06.8>100 29.46 0.062/15/2022 13:15 0.9 0.3 0.0 0.06.5>100 29.79 0.102/14/2022 9:54 15.0 0.8 0.0013 0.0 0.0 0.0 29.40 0.062/15/2022 13:23 13.5 0.8 0.0014 0.0 0.0 0.0 29.78 -0.042/14/2022 9:48 18.6 2.1 0.0 0.0 0.0 0.0 29.42 0.042/15/2022 13:45 18.2 2.0 0.0 0.0 0.0 0.0 29.77 0.002/14/2022 9:40 11.3 3.3 0.0 0.0 0.0 0.0 29.39 -0.092/15/2022 13:52 11.1 2.6 0.0001 0.0 0.0 0.0 29.76 0.012/14/2022 9:10 18.3 1.5 0.0 0.0 0.0 0.0 29.40 0.002/15/2022 14:06 17.8 1.3 0.0 0.0 0.0 0.0 29.76 -0.032/14/2022 10:07 18.1 2.2 0.0001 0.0 0.0 0.0 29.42 -0.052/15/2022 13:34 17.5 2.1 0.0 0.0 0.0 0.0 29.76 0.11Notes:Measurements were collected by H&H using a calibrated Landtec GEM 5000. Positive static pressure values indicate that subsurface pressure is greater than ambient air pressure. Bold values indicates methane concentration exceeds Atmospheric Lower Explosive Limit (LEL) of 5.0 % by volume of air. O2= Oxygen; CO2 = Carbon Dioxide; CO = Carbon Monoxide; H2S = Hydrogen Sulfide; in H₂O = Inches of Water; % = Percent By Volume of AirSG-1H2S (%)SG-DUPSG-6CO2 (%)SG-7SG-8SSV-1SSV-2SG-2SG-4SG-5SG-3Methane PressureSample ID Sample Date CO (%)O2 (%)Sample Timehttps://harthick.sharepoint.com/sites/MasterFiles-1/Shared Documents/AAA-Master Projects/Abacus Capital (ABS)/W. 28th and N.Graham Assembly/Phase II ESA/Tables/Methane_Tables.xlsx9/12/2022Table 5 (Page 1 of 1)Hart & Hickman, PC
SSV-2
SG-8
SG-7
SG-1
SG-2
SG-3
SG-4SG-5
SG-6
SB-1
SB-2
SB-3
SB-5
SB-6
COMP-2
COMP-1
COMP-5
COMP-4
COMP-3
SB-4
TMW-1
TMW-2
TMW-3
TMW-5
TMW-4
TMW-6/SB-7
SSV-1
A
B
C
D
E
A
A
A
A
B
B
B
B
C
C
C
C
D
D
D
D
E
E
E
E
F
REVISION NO. 0
JOB NO. ABS-003
DATE: 10-7-22
FIGURE NO. 3
SAMPLE LOCATION MAP
LEGEND
FROWNFIELDS PROPERTY BOUNDARY
PARCEL BOUNDARY
POTENTIAL GASOLINE UST
POTENTIAL OIL/WATER SEPARATOR/
WASTE OIL UST
FORMER DIESEL UST
VENT PIPE
FLOOR DRAIN
TEMPORARY MONITORING WELL
SOIL BORING
CO-LOCATED TEMPORARY MONITORING
WELL/SOIL BORING
ALIQUOT SOIL BORING
SOIL GAS POINT
SUB-SLAB SOIL GAS POINT
EXISTING BUILDING
PROPOSED BUILDING
2923 South Tryon Street-Suite 100
Charlotte, North Carolina 28203
704-586-0007(p) 704-586-0373(f)
License # C-1269 / #C-245 Geology
NOTES:
1.PARCEL DATA AND AERIAL IMAGERY OBTAINED FROM
MECKLENBURG COUNTY GIS, 2021.
2.UST = UNDERGROUND STORAGE TANK
PEP BOYS DISTRIBUTION CENTER
(700 W. 28TH STREET)
FIRE STATION NO. 11 & FIRE
DEPARTMENT MAINTENANCE SHOP
(620 W. 28TH STREET)
EASY BUILDING SUPPLIES
(600 W. 28TH STREET)
ASHLEY SLING, INC.
(2401 N. GRAHAM STREET)
MCGRANT TAX & BOOKING
(2336 N. GRAHAM STREET)
FR
A
N
K
L
I
N

A
V
E
N
U
E
W.

2
8
T
H

S
T
R
E
E
TN. GRAHAM STREETGRIMES STREETBANCROFT STREETBANCROFT STREETSTORAGE
(2402/2426 N. GRAHAM STREET)
RESIDENCE
(2415 GRIMES STREET)
OFFICES
(609 W. 28TH STREET)
FORMER
DISPENSER ISLAND
TRUCK REPAIR
RESIDENTIAL
FORMER
WASH BAY
RESIDENCE
(2409 GRIMES STREET)
COMMERCIAL EQUIPMENT CO.
N. GRAHAM STREET AND W. 28TH STREET
CHARLOTTE, NORTH CAROLINA
PROPOSED AMENITY AREA
S:\AAA-Master Projects\Abacus Capital (ABS)\W. 28th and N.Graham Assembly\Phase II ESA\Figures\Site Map.dwg, FIG 3, 11/9/2022 12:33:05 PM, sperry