HomeMy WebLinkAbout23074_Bookers Garage_ RSR&FGS WP_2023032814
hart; hickman
SMARTER ENVIRONMENTAL SOLUTIONS
Via Email
March 28, 2023
NCDEQ — Division of Waste Management
Brownfields Program
1646 Mail Service Center
Raleigh, North Carolina 27699-1646
Attention: Ms. Sharon Eckard
Re: Redevelopment Summary and Final Grade Soil Assessment Work Plan - Revised
Bookers Garage
Charlotte, North Carolina
Brownfields Project No. 23074-19-060
H&H Job No. SCF-001
Dear Sharon:
1.0 Introduction
On behalf of 1115 Seigle LLC (Prospective Developer or PD), Hart & Hickman, PC (H&H) has
prepared this letter to outline proposed final grade soil assessment activities and to provide a
brief summary of annual environment -related activities associated with redevelopment of the
Bookers Garage Brownfields property (Brownfields Project No. 23074-19-060). The Bookers
Garage Brownfields property is located west of the intersection of Seigle Avenue and E. 15t1i
Street at 1113-1121 Seigle Avenue and 820 E. 151h Street in Charlotte, Mecklenburg County,
North Carolina (Site or subject Site). The Site consists of three contiguous parcels (Parcel ID
Nos. 08109913, 08109914, and 08109921) that collectively total approximately 0.53 acres. A
Site location map is provided as Figure 1.
Pursuant to the North Carolina Department of Environmental Quality (DEQ) Brownfields
Program approved Environmental Management Plan (EMP) dated February 25, 2021, a report of
environment -related activities will be prepared each year for as long as physical redevelopment
of the Brownfields property continues. Redevelopment activities at the Site began in June 2021
2923 South Tryon Street, Suite 100 3921 Sunset Ridge Rd, Suite 301
Charlotte, NC 28203 Raleigh, NC 27607 www.harthickman.com
704.586.0007 main 919.847.4241 main
Ms. Sharon Eckard
March 28, 2023
Page 2
#C-1269 Engineering
#C-245 Geology
and are expected to be completed in March 2023. This report has been prepared in accordance
with the DEQ-approved EMP for the Site.
The DEQ-approved EMP also includes a requirement for the collection of final grade soil
samples in areas of the Site that are not covered with buildings, sidewalks, concrete or asphaltic
paved (hardscape) surfaces, or a minimum of two feet of demonstrably clean fill soil. H&H
proposes to complete final grade soil sampling activities to evaluate the potential for impacts in
shallow soil within unpaved areas where final grade elevations have been achieved at the Site.
Therefore, this letter also includes a Work Plan to complete final grade soil assessment activities.
A brief summary of redevelopment completion activities is provided in Section 2.0 and the
final grade soil assessment work plan is provided in Section 3.0.
2.0 Redevelopment Activities
Redevelopment activities at the Site have been conducted in accordance with the DEQ-approved
EMP dated February 25, 2021. Redevelopment at the Site in 2022 included the vertical
construction and completion of the multi -family apartment complex and associated parking
garage. No soil import or export was required for the redevelopment in 2022, and no potentially
impacted media requiring management was discovered at the Site during redevelopment
activities completed in 2022. However, the PD has successfully completed the installation of a
vapor intrusion mitigation system (VIMS) for the new building. The general redevelopment
layout is depicted in Figure 2 and a brief summary of the VIMS completion activities is provided
below.
Vapor Mitigation System Completion
During construction of the multi -family apartment complex, the VIMS was installed in
accordance with the DEQ-approved Vapor Intrusion Mitigation Plan (VIMP) dated August 4,
2021. H&H completed inspection activities during various phases of VIMS installation to
confirm that the system was installed in accordance with the DEQ-approved VIMP. The
inspections were completed by, or under the direction of the VIMS design engineer. VIMS
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SMARTER ENVIRONMENTAL SOLUTIONS
Ms. Sharon Eckard
March 28, 2023
Page 3
#C-1269 Engineering
#C-245 Geology
installation inspections and efficacy sampling details were included in a VIMS Installation
Completion Report that was submitted to the DEQ Brownfields Program on December 19, 2022.
In summary, redevelopment activities at the Site are nearing completion and occupancy is
planned in the near future. As noted above, a VIMS Installation Completion Report dated
December 19, 2022, was submitted to the DEQ Brownfields Program for review and occupancy
approval. In addition to the VIMS installation and system efficacy testing, H&H proposes to
collect final grade soil samples prior to occupancy of the apartment building in accordance with
the DEQ-approved EMP. The proposed final grade soil assessment activities are provided in the
following sections.
3.0 Proposed Final Grade Soil Assessment Activities
Final grade soil sampling activities will be conducted at the Site to evaluate potential direct
exposure risks to future Site occupants and workers from shallow soil in landscaped areas. The
soil sampling activities will be conducted in general accordance with the DEQ Inactive
Hazardous Sites Branch (IHSB) Guidelines for Assessment and Cleanup (Guidelines) dated
September 2022, the most recent versions of U.S. Environmental Protection Agency (EPA)
Region IV Laboratory Services and Applied Science Division (LSASD) Field Branches Quality
System and Technical Procedures guidance, and the DEQ Brownfields Program Minimum
Requirements Checklists for Site Assessments dated February 2022. A copy of the completed
Environmental Site Assessment Work Plan Checklist is provided in Appendix A.
On January 18, 2023, H&H completed a Site visit and observed the Site to be predominately
covered with hardscape surfaces including sidewalks, the parking garage, and building pads,
except for landscaped and/or grassy lawn areas along the four sides of the Site, along the Site
boundaries. An overlay of the Site development with landscaped areas shown in green shading
is provided in Figure 3. A photographic log of landscaping conditions observed during the
January 2023 Site visit is included as Appendix B.
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SMARTER ENVIRONMENTAL SOLUTIONS
Ms. Sharon Eckard #C-1269 Engineering
March 28, 2023 #C-245 Geology
Page 4
3.1 Final Grade Soil Sampling Activities
Based on review of the Site Plan and observations at the Site, landscaped areas in the
northwestern, northeastern, southwestern, and southeastern portions of the Site have been
divided into four (4) final grade evaluation areas (FG-1 through FG-4). Five shallow soil borings
will be advanced within each final grade evaluation area for collection of aliquot soil samples
from each shallow soil boring. Soil sample aliquots collected from each evaluation area will be
homogenized to form one composite soil sample to represent shallow soil conditions in that
evaluation area. The final grade evaluation areas and approximate locations of the aliquot soil
borings are shown in Figure 3.
Aliquot soil borings will be advanced from the surface to approximately two feet below the
ground surface (ft bgs) using a decontaminated stainless -steel hand auger. During boring
advancement, continuous soil samples will be collected from the center of the hand auger bucket.
Soil samples will be described for lithologic purposes and observed for obvious evidence of
staining and unusual odors. A portion of the soil sample will be allowed to volatilize and will be
field screened for the presence of volatile organic vapors using a calibrated photoionization
detector (PID).
Remaining portions of the aliquot soil samples will be homogenized to form a composite soil
sample representative of each evaluation area for a total of four (4) composite final grade soil
samples. Soil samples selected for laboratory analysis will be collected directly into laboratory
supplied glassware, labeled with the sample identification, date, and requested analysis, and
placed in a laboratory supplied cooler with ice. The samples will be delivered to a North
Carolina certified laboratory under standard chain of custody protocols for the analyses outlined
below.
Composite soil samples will be submitted for laboratory analysis of semi -volatile organic
compounds (SVOCs) by EPA Method 8270, Resource Conservation and Recovery Act (RCRA)
metals plus hexavalent chromium by EPA Methods 6020/7471/7199. In addition, one grab
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SMARTER ENVIRONMENTAL SOLUTIONS
Ms. Sharon Eckard
March 28, 2023
Page 5
#C-1269 Engineering
#C-245 Geology
sample will be collected from an undisturbed portion of an aliquot soil sample from each
evaluation area for a total of four (4) grab soil samples that will be submitted for analysis of
volatile organic compounds (VOCs) by EPA Method 8260. A final grade soil sample summary
table is provided as Table 1.
The grab samples collected for VOC analysis will be selected based on the results of field
screening and collected from the boring and depth interval exhibiting the highest likelihood for
impact in each final grade evaluation area. If field screening results do not identify the obvious
presence of impacts in an aliquot soil sample, the final grade evaluation area grab samples will
be collected from the 1 to 2 ft bgs sample interval from a randomly selected aliquot soil boring in
each evaluation area.
3.2 Quality Assurance/Quality Control
Non -dedicated equipment and tools will be decontaminated prior to use at each boring location.
To evaluate the reproducibility of the sample results, H&H will collect one duplicate soil sample
that will be submitted for the same analyses as the parent soil sample.
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 calibration, and adherence to specific sample custody and data
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. H&H will
request that laboratory method detection limits for each analyte be at or below the DEQ
Residential Preliminary Soil Remediation Goals (PSRGs), where possible. Additionally, H&H
will request that the laboratory include estimated concentrations for compounds that are detected
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SMARTER ENVIRONMENTAL SOLUTIONS
Ms. Sharon Eckard
March 28, 2023
Page 6
#C-1269 Engineering
#C-245 Geology
at levels above the laboratory method detection limit, but below the laboratory reporting limit.
The laboratory analytical data report and QA package for the final grade soil samples 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 requested 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.
3.3 Investigation Derived Waste
Results of previous assessment activities did not identify the presence of compounds at
concentrations above the hazardous waste characteristic or the Rule of 20 for potential
exceedance of hazardous waste characteristics, investigation derived waste (IDW) generated
during the assessment activities will be thin spread on -Site. However, if significant impacts are
suspected (i.e., elevated PID readings), the soil cuttings from that boring will be containerized
and staged on -Site pending analytical results of a composite IDW sample. Based on laboratory
analytical results of IDW samples, the containers will be transported off -Site to a suitable facility
for disposal. IDW generated during the proposed assessment activities will be managed in
accordance with 15A NCAC 02T.1503 and 15A NCAC 02H.0106.
3.4 Reporting
Following completion of the soil assessment activities in each completed area of the Site and
receipt of the analytical data for samples collected in that area, H&H will prepare a report
describing the methods and results of the final grade soil sampling activities for submittal to
DEQ. The report will include a description of field activities, field screening results, a tabular
summary of the analytical results in comparison to the PSRGs, figures depicting the sample
locations, laboratory analytical reports and chain of custody records, a discussion of QA/QC
data, completed risk calculators, and conclusions based upon our assessment activities. The
report will be sealed by a North Carolina Professional Engineer (PE) or Licensed Geologist (LG)
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SMARTER ENVIRONMENTAL SOLUTIONS
Ms. Sharon Eckard #C-1269 Engineering
March 28, 2023 4C-245 Geology
Page 7
and the firm PE/LG numbers will be provided.
Should you have questions or need additional information, please do not hesitate to call us at
(704) 586-0007.
Very truly yours,
Hart & Hickman, PC
01111,
SEAL ;
' 052740
�n
Alexis McKenzie, PE
Senior Project Engineer
Enclosures
cc: Ms. Anna Coltrane, Spacecraft (Via Email)
Mr. Chris Walker, Alexander Ricks (Via Email)
Attachments:
Project Contact Information
Table 1 Final Grade Soil Sample Summary
ok,oJA-6--
Ralph McGee, PG
Project Manager
Figure 1 Site Location Map
Figure 2 Site Map
Figure 3 Proposed Final Grade Soil Sample Location Map
Appendix A Environmental Site Assessment Work Plan Checklist
Appendix B Photographic Log
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garage/redevelopment report/2023/23074 - bookers garage final rsr & fg soil assessment wp doe
SMARTER ENVIRONMENTAL SOLUTIONS
Project Contact Information
Ms. Anna Coltrane
Space Craft
436 E. 36th Street
Charlotte, NC 28205
336-202-6219 (cell)
anna&spacecraft. citX
Ms. Alexis McKenzie, PE
Hart & Hickman, PC
2923 South Tryon Street, Suite 100
Charlotte, NC 28203
(720) 982-9699 (cell)
amckenzie&harthickman. com
Ms. Sharon Eckard
Division of Waste Management — Brownfields Program
1646 Mail Service Center
Raleigh, NC 27699
(919) 609-2617 (cell)
Sharon. eckard&ncdenr. gov
Table
Table 1
Final Grade Soil Sample Summary
Bookers Garage
Charlotte, North Carolina
Brownfields Project No. 23074-19-060
H&H Job No. SCF-001
Evaluation
Aliquot Soil
Borings per
Aliquot
Number of Grab
Number of Composite
Number of Composite
Sample Objective
Area
Evaluation
Boring Depth
VOC Samples
SVOC Samples
RCRA Metal Samples
Area
(ft bgs)
(8260)
(8270)
(6020/7471/7199)
Shallow Soil Exposure Risk
FG-1 through
5 (see Figure
2
4
4
4
Evaluation
FG-4
3
QA/QC
Duplicate
1
1
1
Notes:
U.S. Environmental Protection Agency analytical method is shown in parentheses.
VOCs = Volatile Organic Compounds; SVOCs = Semi-VOCs; RCRA = Resource Conservation and Recovery Act
ft bgs = feet below ground surface; QA/QC = Quality Assurance/Quality Control; -- = not applicable
Duplicate sample will be collected concurrently with parent sample. Duplicate sample location will be selected in the field
40
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Appendix A
Environmental Site Assessment Work Plan Checklist
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): Sharon Eckard - NCDEQ Brownfields Program
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.
NA 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 o£
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
NA Appendix — Summary of Historical Analytical Data (if needed) — to include tables and figures
only.
Appendix B
Photographic Log
0
0
U-
U
co
Photograph No. 1: Representative photograph along E. 15th Street on the northeastern Site
boundary.
Photograph No. 2: Representative photograph along Seigle Avenue on the southeastern
Site boundary.
Tryon Street, Suite 100 BOOKERS GARAGE
2923 S. T
rY 1113 AND 1121 SEIGLE AVENUE AND
hart hickman Charlotte, NC 28203 820 E. 15TH STREET
704.586.0007(p) 704.586.0373(f) CHARLOTTE, NORTH CAROLINA
0
0
LL
U
U
Photograph No. 3: Representative photograph along the northwestern Site boundary.
Photograph No. 4: Representative photograph along the southwestern Site boundary.
14 2923 S. Tryon Street, Suite 100 BOOKERS GARAGE
1113 AND 1121 SEIGLE AVENUE AND
hart hickman Charlotte, NC 28203 820 E. 15TH STREET
704.586.0007(p) 704.586.0373(f) CHARLOTTE, NORTH CAROLINA