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HomeMy WebLinkAbout27024_CLT Supply_BAR Work Plan_R1_20240606 Via Email June 6, 2024 NCDEQ – Division of Waste Management Brownfields Program 1646 Mail Service Center Raleigh, NC 27699-1646 Attn: Ms. Carolyn Minnich Re: Brownfield Assessment Work Plan (Revision 1) Charlotte Supply Co. 410 S. Mint Street Charlotte, North Carolina Brownfields Project No. 27024-23-060 H&H Project No. AGI.003 Dear Ms. Minnich: On behalf of 410 S Mint Street NC, LLC, enclosed please find a copy of the Brownfields Assessment Work Plan (Revision 1) prepared for the Charlotte Supply Co. Brownfields property. The Assessment Work Plan Approval Signature Page and Minimum Requirements Checklist are attached with the work plan. Should you have questions or need additional information, please do not hesitate to contact us at (704) 586-0007. Sincerely, Hart & Hickman, PC Matt Bramblett, PE Robert Sorgel Principal Sr. Project Geologist Attachments: cc: Mr. Alex Hay, Mr. Max Cookes, and Mr. Wenhao Zhang, ANiMAL Group (Via Email) Ms. Laura Truesdale, Moore & Van Allen (Via Email) i https://harthick.sharepoint.com/sites/MasterFiles-1/Shared Documents/AAA-Master Projects/Animal Group (AGI)/AGI.003 Mint St/BF Assessment/Work Plan/Revision 1/Brownfields Assessment Work Plan_CLT Supply Co..doc Brownfields Assessment Work Plan (Revision 1) Charlotte Supply Co. 410 S. Mint Street Charlotte, North Carolina Brownfields Project No. 27024-23-060 H&H Job No. AGI.003 Table of Contents 1.0 Introduction .............................................................................................................................1 1.1 Background Information .......................................................................................................1 1.2 Previous Assessment Activities .............................................................................................2 2.0 Brownfields Assessment Activities ........................................................................................5 2.1 Receptor Survey ....................................................................................................................5 2.2 Soil Sampling Activities ........................................................................................................6 2.3 Groundwater Sampling Activities .........................................................................................7 2.4 Soil Gas Sampling Activities .................................................................................................9 2.5 Sub-Slab Vapor Sampling Activities ...................................................................................12 2.6 Quality Assurance – Quality Control ..................................................................................13 2.7 Investigation Derived Waste ...............................................................................................14 3.0 Reporting ...............................................................................................................................15 List of Attachments Attachment 1 Work Plan Approval Signature Page List of Tables Table 1 Proposed Sample Summary Table List of Figures Figure 1 Site Location Map Figure 2 Site Map Figure 3 Proposed Sample Location Map 1 https://harthick.sharepoint.com/sites/MasterFiles-1/Shared Documents/AAA-Master Projects/Animal Group (AGI)/AGI.003 Mint St/BF Assessment/Work Plan/Revision 1/Brownfields Assessment Work Plan_CLT Supply Co..doc Brownfields Assessment Work Plan (Revision 1) Charlotte Supply Co. 410 S. Mint Street Charlotte, North Carolina Brownfields Project No. 27024-23-060 H&H Job No. AGI.003 1.0 Introduction On behalf of 410 S Mint Street NC, LLC (Prospective Developer or PD), Hart & Hickman, PC (H&H) has prepared this Brownfields Assessment Work Plan (Work Plan) for the Charlotte Supply Co. Brownfields property (Brownfields Project No. [BPN] 27024-23-060) located at 410 S. Mint Street in Charlotte, Mecklenburg County, North Carolina (subject Site or Site). The Site consists of one parcel of land (Mecklenburg County Parcel No. 07312411) that is approximately 4.78 acres and is located in Uptown Charlotte. The Site is currently developed with an open air parking deck. A Site location map is provided as Figure 1, and the Site and surrounding area are shown in Figure 2. Proposed redevelopment of the Brownfields property includes the construction of a retail building and two residential towers to the south of the existing parking deck. The existing open air parking deck will remain at the Site. An overlay map depicting the preliminary proposed redevelopment plans at the Site is provided as Figure 3. 1.1 Background Information The southern portion of the Site was formerly occupied by a residential structure from at least 1900 through the 1960s. The majority of the Site was developed as a light industrial property containing railroad tracks, an auto repair shop, cold storage facilities, and support buildings beginning circa 1929. One of the buildings was occupied by the Charlotte Supply Co. Light industrial uses continued until the late 1970s or early 1980s. The Site appeared to be used for light commercial activities and as a parking lot from the early 1980s through early 1990s. In 1995, the Site was redeveloped with the current parking structure. 2 https://harthick.sharepoint.com/sites/MasterFiles-1/Shared Documents/AAA-Master Projects/Animal Group (AGI)/AGI.003 Mint St/BF Assessment/Work Plan/Revision 1/Brownfields Assessment Work Plan_CLT Supply Co..doc 1.2 Previous Assessment Activities 2021 Phase I Environmental Site Assessment In September 2021, a Phase I Environmental Site Assessment (ESA) was conducted at the Site by S&ME, Inc. (S&ME). The results of the Phase I ESA identified Recognized Environmental Conditions (RECs) associated with the following: 1) Historical use of the Site for commercial operations, including the presence of a coal yard, cold storage facilities, and automotive repair facilities. 2) Identified chlorinated solvent impacts to groundwater on an adjacent property to the north of the Site. 2022 Phase II Environmental Site Assessment From June to August 2022, S&ME conducted Phase II ESA activities at the Site. The Phase II ESA activities included the collection of four (4) soil samples and two (2) groundwater samples. The soil samples were submitted to a laboratory for analysis of volatile organic compounds (VOCs), semi-VOCs (SVOCs), and Resource Conservation and Recovery Act (RCRA) metals plus hexavalent chromium. The groundwater samples were submitted to a laboratory for analysis of VOCs, SVOCs, and RCRA metals. It should be noted that two (2) additional groundwater samples were attempted to be collected at the Site, but drill rig refusal was encountered above the water table at these locations. Results of Phase II ESA soil assessment activities indicated the presence of the SVOCs benzo(a)anthracene, benzo(a)pyrene, benzo(b)fluoranthene, dibenz(a,h)anthracene, indeno(1,2,3- cd)pyrene, and 1-methylnaphthalene in the SB-1 soil sample collected from the southern portion of the Site at concentrations above Protection of Groundwater, Residential, and/or Industrial/Commercial Preliminary Soil Remediation Goals (PSRGs). Additionally, the metals arsenic and/or hexavalent chromium were detected in the SB-1, SB-2, and/or SB-3 soil samples collected from the southern, southeastern, and northern portions of the Site, respectively, at concentrations above Residential and/or Industrial/Commercial PSRGs. 3 https://harthick.sharepoint.com/sites/MasterFiles-1/Shared Documents/AAA-Master Projects/Animal Group (AGI)/AGI.003 Mint St/BF Assessment/Work Plan/Revision 1/Brownfields Assessment Work Plan_CLT Supply Co..doc Results of Phase II ESA groundwater assessment activities indicated the presence of the chlorinated VOCs tetrachloroethylene (PCE) and trichloroethylene (TCE) and the metal chromium in the GW-3 groundwater sample collected from the northern portion of the Site at concentrations above North Carolina Department of Environmental Quality (DEQ) 2L Groundwater Standards (2L Standards). No VOCs, SVOCs, or metals were detected in the GW- 2 groundwater sample collected from the southeastern portion of the Site at concentrations above 2L Standards. 2023 Phase I Environmental Site Assessment In February 2023, a Phase I ESA was conducted at the Site by S&ME. The results of the Phase I ESA identified RECs associated with the following: 1) Historical use of the Site for commercial operations, including the presence of a coal yard, cold storage facilities, automotive repair facilities, and railroad activities. 2) Identified chlorinated solvent impacts to groundwater at the Site and at an adjacent property to the north. 3) Identified petroleum impacts to groundwater at an adjacent property to the east. To address potential environmental concerns associated with historical on-Site and off-site operations, the Site was entered into the North Carolina DEQ Brownfields Program and received eligibility in a letter dated August 25, 2023. The PD elected to participate in the Brownfields Program Redevelopment Now option. As part of this process, a kick-off/data gap meeting with the PD, DEQ Brownfields personnel, and H&H was held on October 24, 2023, to discuss Site history, proposed redevelopment plans, data gaps, and the proposed schedule for completing the Brownfields Agreement. To address data gaps and DEQ Brownfields requests for additional assessment, H&H has prepared this Work Plan to conduct Brownfields assessment activities at the Site. The purpose of the Brownfields assessment activities described herein is to further evaluate the potential for impacts at the Site for the protection of Site workers during redevelopment and for 4 https://harthick.sharepoint.com/sites/MasterFiles-1/Shared Documents/AAA-Master Projects/Animal Group (AGI)/AGI.003 Mint St/BF Assessment/Work Plan/Revision 1/Brownfields Assessment Work Plan_CLT Supply Co..doc future Site occupants. The Brownfields assessment activities discussed in the following sections include the collection of soil, groundwater, sub-slab vapor, and soil gas samples. In addition to the soil, groundwater, sub-slab vapor, and soil gas assessment activities, a Brownfields receptor survey will be conducted to obtain information associated with land use, water supply well use, and potential sensitive receptors in the area surrounding the Site. A summary of the proposed Brownfields assessment activities is provided below. 5 https://harthick.sharepoint.com/sites/MasterFiles-1/Shared Documents/AAA-Master Projects/Animal Group (AGI)/AGI.003 Mint St/BF Assessment/Work Plan/Revision 1/Brownfields Assessment Work Plan_CLT Supply Co..doc 2.0 Brownfields Assessment Activities The Brownfields assessment activities will be conducted in general accordance with the DEQ Inactive Hazardous Sites Branch (IHSB) Guidelines for Assessment and Cleanup of Contaminated Sites (Guidelines) dated September 2023, the DEQ Division of Waste Management (DWM) Vapor Intrusion Guidance (VI Guidance) dated March 2018, most recent versions of the 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 Minimum Requirements Checklist for Site Assessment Work Plans and Reports dated March 2023. 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. Additionally, H&H will contract with a private utility locator to screen proposed sample locations for subgrade utilities that may not be marked by the public locator. The private utility locator will utilize electromagnetic and ground-penetrating radar (GPR) methods to locate and demark subsurface anomalies in the vicinity of the proposed boring locations. Additionally, soil boring locations will be hand cleared to approximately 5 feet below ground surface (ft bgs) prior to use of mechanical drilling equipment to further screen the boring locations for the presence of subsurface utilities. In accordance with Mecklenburg County regulations, H&H will also obtain a Subsurface Investigation Permit (SIP) from Mecklenburg County prior to temporary monitoring well installation and sampling. After completion of the activities, H&H will update the SIP and provide the County with temporary monitoring well abandonment records provided by a North Carolina licensed driller. 2.1 Receptor Survey H&H will perform a Brownfields receptor survey in accordance with DEQ Brownfields Section guidance. The receptor survey will include information about land use in the Site area, including 6 https://harthick.sharepoint.com/sites/MasterFiles-1/Shared Documents/AAA-Master Projects/Animal Group (AGI)/AGI.003 Mint St/BF Assessment/Work Plan/Revision 1/Brownfields Assessment Work Plan_CLT Supply Co..doc zoning. H&H will also conduct a field search for water supply wells, basements, utility manways and chases, storm sewers, other underground utilities, drains, and surface water within a 1,500 ft radius of the Brownfield property boundary. In addition, H&H will review the online Mecklenburg County Well Information System for potential wells in the area and, if warranted, contact utility companies for information concerning underground utilities in the immediate area of the Site. The receptor survey will be completed using the most current version of the Brownfields Property Receptor Survey template form. 2.2 Soil Sampling Activities H&H will conduct soil sampling as part of the Brownfields assessment activities. The purpose of the soil sampling will be to evaluate potential impacts in areas that may be disturbed during planned redevelopment and grading activities and to further evaluate general Site conditions. As requested by the DEQ Brownfields Redevelopment Section during the October 24, 2023 kick- off/data gap meeting, a soil sample (HHSB-3) will be collected near the location of prior soil sample SB-1. Locations of the proposed soil borings are shown in Figure 3; and the soil sample depths, objectives, and laboratory analyses are summarized in Table 1. H&H will team with a qualified drilling contractor to advance five (5) soil borings (HHSB-1 through HHSB-5) in the southern portion of the Site and one (1) soil boring (HHSB-6) in the northern portion of the Site for the purpose of soil sample collection. The soil borings will be advanced to a depth of approximately 5 ft bgs using a decontaminated stainless-steel hand auger. Additionally, a concrete core drill or drill rig capable of direct push technology (DPT) will be used to initially penetrate concrete at certain soil boring locations. During boring advancement, soil will be logged for lithological description and field screened for indications of potential impacts by observation for obvious staining, unusually odors, and the presence of volatile organic vapors using a calibrated photoionization detector (PID). Soil samples will be collected from the depth interval that exhibits the highest potential for impact. If significant impact is not expected based on the results of field screening, the soil samples will be collected from the surficial depth interval (i.e., 0-2 ft bgs) due to the likelihood of disturbance during future redevelopment and grading. 7 https://harthick.sharepoint.com/sites/MasterFiles-1/Shared Documents/AAA-Master Projects/Animal Group (AGI)/AGI.003 Mint St/BF Assessment/Work Plan/Revision 1/Brownfields Assessment Work Plan_CLT Supply Co..doc The soil samples selected for laboratory analysis will be placed directly into dedicated laboratory supplied sample containers, labeled with the sample identification, date, and requested analysis, and placed in a laboratory supplied cooler with ice. Soil samples will be submitted to a North Carolina certified laboratory under standard chain of custody protocols for analysis of VOCs by EPA Method 8260, SVOCs by EPA Method 8270, RCRA metals by EPA Methods 6020/7471, and hexavalent chromium by EPA Method 7199. Metal concentrations will be compared to background concentrations reported in literature and at other nearby Brownfields properties, if available. Following sampling activities, the soil borings will be properly abandoned and surfaces will be patched similar to pre-drilling conditions. Additionally, the soil sample locations will be estimated using a hand-held global positioning system (GPS) unit. In the event that the GPS unit cannot achieve sub-meter accuracy (i.e., due to multipath errors or other signal obstruction), the soil sample locations will be estimated by measuring from known benchmarks. 2.3 Groundwater Sampling Activities H&H will contract a qualified drilling contractor to further advance three (3) of the soil borings located at the Site for installation of three (3) temporary groundwater monitoring wells (HHTMW-1 through HHTMW-3). The purpose of the temporary groundwater monitoring wells will be to further evaluate groundwater conditions and to prepare a groundwater potentiometric map for the Site. Locations of the proposed temporary monitoring wells are shown in Figure 3; and anticipated well depths, objectives, and laboratory analyses are summarized in Table 1. The temporary groundwater monitoring well borings will be advanced to approximate depths of 20 to 25 ft bgs or until drill rig refusal is encountered using a decontaminated stainless-steel hand auger and a track-mounted drill rig capable of DPT and hollow-stem auger drilling techniques. As discussed during the October 24, 2023 kick-off/data gap meeting, additional groundwater analytical data is not critical for this Site. Therefore, in the event that drill rig refusal is encountered above the water table using DPT and hollow-stem auger drilling methods, 8 https://harthick.sharepoint.com/sites/MasterFiles-1/Shared Documents/AAA-Master Projects/Animal Group (AGI)/AGI.003 Mint St/BF Assessment/Work Plan/Revision 1/Brownfields Assessment Work Plan_CLT Supply Co..doc groundwater samples will not be collected from these locations. During drilling, soil cuttings will be collected and logged for lithologic description and field screened for the presence of obvious staining, unusual odors, and elevated volatile organic vapors using a calibrated PID. Should obvious evidence of vadose zone soil impacts be observed based on field screening results, a soil sample will be collected for laboratory analysis using the aforementioned parameters. The temporary groundwater monitoring wells will be constructed with 15 ft sections of pre- packed well screen set to bracket the water table and 2-inch diameter polyvinyl chloride (PVC) well casing to the ground surface. A sand filter pack will be placed from the bottom of the borings to approximately 2 ft above the top of the well screens. The temporary wells will be completed by placing a minimum of an approximately 2 ft thick hydrated bentonite seal above the sand filter pack. Once the temporary monitoring wells are installed, the groundwater within the wells will be allowed to equilibrate to static condition, and a decontaminated electronic water level indicator will be used to measure the depth to the water table relative to the ground surface and tops of well casings in each well. The wells will then be developed by removing a minimum of 3 volumes and until field parameters have stabilized (pH± 0.1 Standard Units [SU] and conductivity varies no more than 5%). After development, the temporary monitoring wells will be allowed to equilibrate to static condition for a minimum of 24 hours prior to collection of groundwater samples. Groundwater samples will be collected utilizing low flow/low stress purging techniques using a peristaltic pump and dedicated polyethylene tubing. The intake point of the pump tubing will be placed in the approximate mid-portion of the screened interval of the groundwater column, and groundwater will be removed at a rate no greater than 200 milliliters per minute (mL/min). H&H will utilize a calibrated water quality meter to collect measurements of pH, temperature, dissolved oxygen, oxidation reduction potential, turbidity, and specific conductivity at three to five-minute intervals during the purging process. Purging will be considered complete when the 9 https://harthick.sharepoint.com/sites/MasterFiles-1/Shared Documents/AAA-Master Projects/Animal Group (AGI)/AGI.003 Mint St/BF Assessment/Work Plan/Revision 1/Brownfields Assessment Work Plan_CLT Supply Co..doc field parameters stabilize (pH ± 0.1 SU, conductivity varies no more than 5%, and turbidity is less than 10 Nephelometric Turbidity Units [NTUs]), if practical. Once groundwater parameters stabilize, groundwater samples for VOC analysis will be collected directly into laboratory supplied sample containers using the “soda straw” method to eliminate the potential for volatile compound loss through the pump head. Samples for the remaining analyses will be collected directly into laboratory supplied sample containers from the dedicated sample tubing discharge. The sample containers will be labeled with the sample identification, date, time, and requested analysis, and placed in a laboratory supplied cooler with ice. The groundwater samples will be delivered to a North Carolina certified laboratory under standard chain of custody protocols for analysis of VOCs by EPA Method 8260, SVOCs by EPA Method 8270, and RCRA metals by EPA Methods 6020/7471. If groundwater is encountered in each of the three (3) temporary monitoring wells, H&H will utilize surveying techniques to estimate the top of casing elevation and ground surface elevation at each temporary monitoring well. H&H will use the measured depths to groundwater and relative top of casing elevations to estimate the potentiometric surface and groundwater flow direction at the Site. In addition, the groundwater sample locations will be estimated using a hand-held GPS unit. If groundwater is not encountered in one or more of the temporary monitoring wells, development of a potentiometric map will not be possible, and H&H will infer the direction of groundwater flow at the Site based on available historical data for the Site area and topographic considerations. Following sampling and estimating groundwater elevations, the temporary monitoring wells will be properly abandoned by a licensed well driller and the surfaces will be patched similar to pre-drilling conditions. 2.4 Soil Gas Sampling Activities To evaluate the potential for structural vapor intrusion into the proposed future buildings in the southern portion of the site, H&H will install and sample five (5) temporary soil gas monitoring points at the Site (HHSG-1 through HHSG-5). Additionally, H&H will install and sample one (1) temporary soil gas monitoring point (HHSG-6) in the northern portion of the Site to evaluate 10 https://harthick.sharepoint.com/sites/MasterFiles-1/Shared Documents/AAA-Master Projects/Animal Group (AGI)/AGI.003 Mint St/BF Assessment/Work Plan/Revision 1/Brownfields Assessment Work Plan_CLT Supply Co..doc soil gas conditions in the vicinity of previously identified chlorinated solvents in groundwater. Locations of the proposed temporary soil gas monitoring points are shown in Figure 3; and the sample depths, objectives, and laboratory analyses are summarized in Table 1. The temporary soil gas monitoring points will be installed at depths of approximately 6 ft bgs using a decontaminated stainless-steel hand auger. During boring advancement, soil cuttings will be collected and logged for lithologic description and field screened for the presence of obvious staining, unusual odors, and elevated volatile organic vapors using a calibrated PID. Should obvious evidence of vadose zone soil impacts be observed based on field screening results, a soil sample will be collected for laboratory analysis using the aforementioned parameters. The temporary soil gas monitoring points will be installed by placing an approximate 6-inch stainless steel vapor implant screen attached to Teflon® sample tubing at the base of each borehole. Annular space around the vapor implant screens 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. An airtight cap will then be placed on the end of the Teflon® sample tubing and the temporary soil gas monitoring points will be allowed to equilibrate for a minimum of 24 hours after installation prior to sample collection. The soil gas samples will be collected utilizing laboratory supplied Summa® canisters (1 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 mL/min. Prior to collection of the soil gas samples, a “shut-in” test will be conducted on the sampling train and helium leak checks will be conducted at each soil gas sampling point. The shut-in test and helium leak check are conducted to check that 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 11 https://harthick.sharepoint.com/sites/MasterFiles-1/Shared Documents/AAA-Master Projects/Animal Group (AGI)/AGI.003 Mint St/BF Assessment/Work Plan/Revision 1/Brownfields Assessment Work Plan_CLT Supply Co..doc 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 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 sampling train, including the canister, and flooding the shroud with helium gas. A calibrated helium gas detector will be utilized to measure helium concentrations within the shroud. 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 soil gas point are less than 10% of the helium concentrations measured within the shroud. Following successful leak checks, the soil gas samples will be collected. Vacuum readings on the Summa® canisters will be recorded prior to and following the sampling period to ensure adequate sample volume was collected. In accordance with DEQ DWM Vapor Intrusion guidance, a vacuum of approximately 5 inches of mercury will be maintained within the canisters at the conclusion of the sampling event. 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 DWM Residential Soil Gas Screening Levels (SGSLs). The sample locations will be estimated using a hand-held GPS unit and the soil gas monitoring points will be abandoned and the surfaces will be patched similar to pre-drilling conditions. 12 https://harthick.sharepoint.com/sites/MasterFiles-1/Shared Documents/AAA-Master Projects/Animal Group (AGI)/AGI.003 Mint St/BF Assessment/Work Plan/Revision 1/Brownfields Assessment Work Plan_CLT Supply Co..doc 2.5 Sub-Slab Vapor Sampling Activities To further evaluate the potential for structural vapor intrusion into the proposed future buildings, H&H will also collect one sub-slab vapor sample (HHSSV-1) in the parking office located on the ground floor of the existing parking garage. The location of the proposed sub-slab vapor sample is shown in Figure 3; and the objectives and laboratory analyses are summarized in Table 1. The sub-slab vapor 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 ⅝- 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 the boring, and a Cox-Colvin Vapor Pin™ (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. An airtight cap will then be placed on the vapor pin. The sub-slab vapor sampling point will be allowed to equilibrate for a minimum of 2 hours after installation prior to sample collection. The sub-slab vapor sample will be collected utilizing a laboratory supplied Summa® canister (1 or 3-Liter canister depending on laboratory availability) connected to an air-flow regulator calibrated by the laboratory to collect the sub-slab vapor sample at a rate of approximately 100 mL/min. Prior to collection of the sub-slab vapor sample, a “shut-in” test will be conducted on the sampling train and a helium leak check will be conducted at the sub-slab vapor sampling point. The shut-in test and helium leak check will be conducted in accordance with the procedures described in Section 2.4. Following a successful leak check, the sub-slab vapor sample will be collected. Vacuum readings on the Summa® canister will be recorded prior to and following the sampling period to ensure adequate sample volume was collected. In accordance with DEQ DWM Vapor Intrusion guidance, a vacuum of approximately 5 inches of mercury will be maintained within the canister 13 https://harthick.sharepoint.com/sites/MasterFiles-1/Shared Documents/AAA-Master Projects/Animal Group (AGI)/AGI.003 Mint St/BF Assessment/Work Plan/Revision 1/Brownfields Assessment Work Plan_CLT Supply Co..doc at the conclusion of the sampling event. Following sample collection, the Summa® canister will be placed in a laboratory supplied shipping container, 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 DWM Residential SGSLs. After sample collection, the vapor pin will be removed from the building slab and the surface will be patched similar to pre-drilling conditions. The sample location will be estimated using a hand-held GPS unit. If the sub-slab vapor sample location cannot be estimated using a GPS unit (i.e., due to signal interference associated with existing structures), H&H will estimate the sample location by measuring from known benchmarks. 2.6 Quality Assurance – Quality Control Non-dedicated equipment and tools will be decontaminated prior to use at each boring or sampling location or following exposure to soil or groundwater. The following samples will be collected for quality assurance/quality control (QA/QC) purposes: • one duplicate soil sample and one duplicate groundwater sample will be collected and analyzed for the same parameters as the parent samples; • one trip blank will accompany the groundwater samples during the field activities as well as during sample shipment and will be analyzed for VOCs by EPA Method 8260; and • one duplicate soil gas or sub-slab vapor sample will be collected for analysis of VOCs by EPA Method TO-15 using a laboratory supplied “t-fitting” which allows for two samples to be collected from one sampling point simultaneously. Laboratory QA/QC procedures will be employed for 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 14 https://harthick.sharepoint.com/sites/MasterFiles-1/Shared Documents/AAA-Master Projects/Animal Group (AGI)/AGI.003 Mint St/BF Assessment/Work Plan/Revision 1/Brownfields Assessment Work Plan_CLT Supply Co..doc 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 for each group of 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 provided for this project. A copy of the completed chain of custody record will be appended to the corresponding laboratory analytical report included with the final report. 2.7 Investigation Derived Waste IDW generated during the proposed assessment activities will be managed in general accordance with DEQ IHSB Guidelines, including 15A NCAC 02T.1503 and 15A NCAC 02H.0106. Based on the results of previous Phase II ESA activities conducted at the Site, hazardous waste is not likely to be encountered during the assessment activities. Therefore, IDW generated during the assessment activities will be thin spread on-Site. However, if significant impacts are suspected (i.e., free-product), the impacted media 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 would then be transported off-Site to a suitable facility for disposal. 15 https://harthick.sharepoint.com/sites/MasterFiles-1/Shared Documents/AAA-Master Projects/Animal Group (AGI)/AGI.003 Mint St/BF Assessment/Work Plan/Revision 1/Brownfields Assessment Work Plan_CLT Supply Co..doc 3.0 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 the sampling activities; a figure depicting sample locations; boring logs for the soil borings, temporary monitoring well borings, and soil gas monitoring points; temporary monitoring well and temporary soil gas monitoring point construction logs; groundwater sampling logs; laboratory analytical data; a discussion of the data in comparison to regulatory screening levels; and conclusions and recommendations concerning our activities. For the soil gas and sub-slab vapor results, H&H will use the most recent version of the NC DEQ risk calculator to further evaluate potential risks based on the data, if needed. The report will also include the firm’s professional license numbers and an individual professional seal and signature. 06/07/2024 Table Table 1 Proposed Sample Summary Table Charlotte Supply Co. 410 S. Mint Street Charlotte, North Carolina Brownfields Project No. 27024-23-060 H&H Project No. AGI.003 HHSB-1 through HHSB-6 Soil Evaluate Soil Conditions 5 varies 6 VOCs (8260), SVOCs (8270), RCRA Metals (6020/7471), and hexavalent chromium (7199) HHTMW-1 through HHTMW-3 Groundwater Temporary Wells to Evaluate Groundwater Conditions 25 10-25 3 VOCs (8260), SVOCs (8270), and RCRA Metals (6020/7471) HHSG-1 through HHSG-6 Soil Gas Evaluate Potential VI Risks 6 5.5-6 6 VOCs (TO-15) - Batch Certified Canisters HHSSV-1 Sub-Slab Vapor Evaluate Potential VI Risks vapor pin vapor pin 1 VOCs (TO-15) - Batch Certified Canister SB-DUP Duplicate Soil Sample Quality Control Check Duplicate Duplicate 1 VOCs (8260), SVOCs (8270), RCRA Metals (6020/7471), and hexavalent chromium (7199) GW-DUP Duplicate Groundwater Sample Quality Control Check Duplicate Duplicate 1 VOCs (8260), SVOCs (8270), and RCRA Metals (6020/7471) SG-DUP or SSV-DUP Duplicate Soil Gas or Sub-Slab Vapor Sample Quality Control Check Duplicate Duplicate 1 VOCs (TO-15) - Batch Certified Canister Trip Blank Trip Blank Quality Control Check NA NA 1 VOCs (8260) Notes: The EPA method number follows the laboratory parameter in parentheses in the table above. VOCs = Volatile Organic Compounds; SVOCs = Semi-VOCs; RCRA = Resource Conservation and Recovery Act ft = feet; QA/QC = Quality Assurance/ Quality Control; VI = Vapor Intrusion; NA = not applicable Laboratory AnalysisSample IDs Sample Type Sample Objective Approximate Boring Depth (ft) Approximate Sample Depth (ft) Number of Samples https://harthick.sharepoint.com/sites/MasterFiles‐1/Shared Documents/AAA‐Master Projects/Animal Group (AGI)/AGI.003 Mint St/BF Assessment/Work Plan/Table/Table 1 ‐ Sample Summary Table Table 1 (Page 1 of 1) Hart & Hickman, PC Figures SITE LOCATION MAP CHARLOTTE SUPPLY CO.410 S. MINT STREET CHARLOTTE, NORTH CAROLINA DATE: 10-16-23 JOB NO: AGI-003 REVISION NO: 0 FIGURE. 1 2923 South Tryon Street - Suite 100 Charlotte, North Carolina 28203 704-586-0007 (p) 704-586-0373 (f) License # C-1269 / # C-245 Geology TITLE PROJECT 0 2,000 4,000 SCALE IN FEET Pa t h : S : \ A A A - M a s t e r P r o j e c t s \ A n i m a l G r o u p \ A G I . 0 0 3 M i n t S t \ F i g u r es \ A G I . 0 0 3 _ F i g u r e 1 . a p r x N U.S.G.S. QUADRANGLE MAP CHARLOTTE EAST, NORTH CAROLINA 2022 QUADRANGLE 7.5 MINUTE SERIES (TOPOGRAPHIC) SITE SOU T H M I N T S T R E E T S G R A H A M S T R E E T W M A R T I N L U T H E R K I N G J R B L V D W 1S T S T R E E T REVISION NO. 0 JOB NO. AGI-003 DATE: 10-16-23 FIGURE NO. 2 CHARLOTTE SUPPLY CO.410 S. MINT STREET CHARLOTTE, NORTH CAROLINA SITE MAP LEGEND SITE PROPERTY BOUNDARY PARCEL LINE EXISTING PARKING OFFICE AREA SOIL BORING LOCATION (S&ME; 2022) CO-LOCATED SOIL BORING AND TEMPORARY MONITORING WELL LOCATION (S&ME; 2022) NOTES: 1. AERIAL IMAGERY AND BASE DATA OBTAINED FROM MECKLENBURG COUNTY GIS, 2023. 2923 South Tryon Street-Suite 100 Charlotte, North Carolina 28203 704-586-0007(p) 704-586-0373(f) License # C-1269 / #C-245 Geology SB-1 SB-2\GW-2 SB-4 SB-3\GW-3 S: \ A A A - M a s t e r P r o j e c t s \ A n i m a l G r o u p \ A G I . 0 0 3 M i n t S t \ F i g u r e s \ A G I . 0 0 3 _ 2 0 2 3 1 0 1 6 . d w g , F I G 2 , 1 0 / 1 8 / 2 0 2 3 9 : 4 3 : 5 4 A M , s h a y n e s SOU T H M I N T S T R E E T S G R A H A M S T R E E T W M A R T I N L U T H E R K I N G J R B L V D W 1S T S T R E E T REVISION NO. 0 JOB NO. AGI-003 DATE: 11-1-23 FIGURE NO. 3 CHARLOTTE SUPPLY CO. 410 S. MINT STREET CHARLOTTE, NORTH CAROLINA PROPOSED SAMPLE LOCATION MAP LEGEND SITE PROPERTY BOUNDARY PARCEL LINE EXISTING PARKING OFFICE AREA SOIL BORING LOCATION (S&ME; 2022) CO-LOCATED SOIL BORING AND TEMPORARY MONITORING WELL LOCATION (S&ME; 2022) PROPOSED CO-LOCATED SOIL SAMPLE AND TEMPORARY MONITORING WELL LOCATION PROPOSED SHALLOW SOIL SAMPLE PROPOSED SOIL GAS OR SUB-SLAB VAPOR SAMPLE LOCATION PROPOSED RETAIL - GROUND FLOOR PROPOSED RESIDENTIAL TOWER 1 - GROUND FLOOR PROPOSED RESIDENTIAL TOWER 2 - GROUND FLOOR NOTES: 1. AERIAL IMAGERY AND BASE DATA OBTAINED FROM MECKLENBURG COUNTY GIS, 2023. 2923 South Tryon Street-Suite 100 Charlotte, North Carolina 28203 704-586-0007(p) 704-586-0373(f) License # C-1269 / #C-245 Geology SB-1 SB-2\GW-2 SB-4 SB-3\GW-3 PROPOSED LOBBY (AT GRADE) PROPOSED NEW ELEVATORSHHSG-1 HHTMW-1 HHSB-1 HHSB-2 HHSG-2 HHSB-3 HHSG-3 HHTMW-2/ HHSB-4 HHSB-5 HHSG-4 HHSG-5 HHSSV-1 S:\ A A A - M a s t e r P r o j e c t s \ A n i m a l G r o u p \ A G I . 0 0 3 M i n t S t \ F i g u r e s \ A G I . 0 0 3 _ 2 0 2 3 1 0 1 6 . d w g , F I G 3 , 1 1 / 1 / 2 0 2 3 1 2 : 3 0 : 1 7 P M , t m a r b u e r y HHSG-6 HHTMW-3 HHSB-6 Work Plan and Report Checklist Version 3 March 2023 Minimum Requirements Checklist Site Assessment Work Plans and Reports NCDEQ Brownfields Redevelopment Section– March 2023 Instructional Page All references to Prospective Developers include follow-on owners who may be conducting work in accordance with the Brownfields Property Management Branch. To increase predictability and most efficiently assess Brownfields Properties and the redevelopment timing requirements of Prospective Developers or follow-on owners, the Brownfields Redevelopment Section 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 Redevelopment Section’s completeness review. This checklist outlines the minimum requirements and submittal format under the Brownfields Redevelopment Section for Assessment Requirements and Reporting. All Assessment Work Plans and Report submissions to the Brownfields Redevelopment Section 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 Section prior to implementation. However, in order to respect the schedule of all projects in house and keep the Section’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. Work Plan and Report Checklist Version 3 March 2023 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. ☒ Title of Work Plan ☒ Brownfields Project Name (not the development name) ☒ Brownfields Project Number ☒ Date (updated with each revision) ☒ Revision Number ☒ Firm PE/PG License Number ☒ Individual PE/PG seal & signature Section 1 – Introduction ☒ Provide the site location, address, and acreage. ☒ Provide a BRIEF summary of the history of the property and its history in the Section. For example: reiterate RECs from a Phase I ESA, indicate if the scope of work was negotiated during a Data Gap Meeting, etc. ☒ Briefly list and describe the data gaps the assessment is attempting to fill ☒ Indicate if the assessment data is for the use of any other DEQ programs in addition to the Brownfields Redevelopment Section (i.e. the site is a regulated UST, IHSB, etc. property) Section 2 – Scope of Work ☒ Provide a general description of proposed scope of work covered in this plan (i.e. 2 new monitoring wells, 6 groundwater samples, 5 exterior soil gas sampling points and 6 soil borings) ☒ Discuss samples to be collected by media and source area/location. Generally, the reasoning for the sample locations selected. ☒ Describe depths of samples to be collected (Reference Table 1) or how that decision will be made in the field, if needed. ☒ State for what each sample will be analyzed (briefly). Reference Table 1. Note: 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 ☒ 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 Work Plan and Report Checklist Version 3 March 2023 such guidance (e.g., multi-increment sampling, passive air samplers, mobile labs, Hapsite, simultaneous indoor/outdoor radon, high-volume sub-slab vapor testing, PFAS sampling). ☒ Describe what will be installed (soil boring, temporary well, permanent well, sub-slab vapor, exterior soil gas, etc.). Include construction details. ☒ Discuss installation methodology (Hand Auger, DPT, etc.) Discuss Equilibration Times • Monitoring wells (equilibration time prior to development and equilibration post well development should be 24 hours, per EPA standard protocols). • Vapor: a. Sub slab vapor with minimally invasive points (e.g. Vapor Pins): Manufacturer’s guidelines generally suggest 20 minutes may be sufficient with an airtight cap installed; or b. Sub slab vapor points (other than minimally invasive points) or exterior soil gas points: at least 24 hours (to be purged at installation and at time of sampling with an air-tight cap in place in the interim). ☒ 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) • Submission of the samples to the laboratory within 48 hours of collection and/or written documentation of temperature maintenance if the situation requires extension beyond 48 hours prior to lab submittal ☒ Discuss sample point abandonment Section 4 – Laboratory Analyses ☒ Discuss the proposed analyses (include method number, preparation method, if there are concerns with short hold times, etc). ☒ Discuss any proposed limitations on the contaminants of concern, if any, and the reason for such limitation (sufficient previous data, indoor air interferences, etc). ☒ Discuss laboratory certifications. Please note, NC does not certify labs for air samples. Please specify what certification the proposed air lab holds. ☒ 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. ☒ Indicate what Level QA/QC will be reported by the laboratory. Level II QA/QC is typically acceptable. Section 5 – QA/QC ☒ Specify the duplicate sample frequency. Minimum requirement: 1 duplicate per 20 samples, per media, per method. ☒ Discuss Trip Blank. 1 Trip Blank per cooler/shipment of groundwater VOC analyses is required. ☒ Discuss how the lab will have sufficient sample volume for MS/MSD analyses. Work Plan and Report Checklist Version 3 March 2023 ☒ Discuss chain of custody and shipping. Section 6 – Investigation Derived Waste (IDW) Management ☒ 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: ☒ Title Page that is consistent with the requirements listed above. ☒ Reporting/summary of site work conducted for all sections outlined above in this checklist; ☒ Summary of findings and possible recommendations; ☒ All applicable tables and figures (shall include at a minimum the items below) ☒ 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. ☒ Appendices shall include (as applicable): ☒ Copies of field notes ☒ Boring logs for all soil borings, newly constructed monitoring wells, and exterior soil gas locations ☒ Well construction and abandonment records Work Plan Approval Signature Page (see Attachment 1). The Consultant shall complete and submit the Approval Signature Page with the work plan submittal for DEQ signature. Work Plan and Report Checklist Version 3 March 2023 Attachments ☒ Attachment 1 – Work Plan Approval Signature Page ☒ 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 ☒ Figure 1 – Site Location Map ☒ Site location on a topographic map base ☒ Graphic scale and north arrow ☒ 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 ☐ Figure 3 – Site Potentiometric Map that includes the following ☐ Buildings ☐ Groundwater sample identification labels ☐ Arrow noting direction of groundwater flow ☐ Graphic scale and north arrow ☐ Figure 4 – Site Plume Maps (groundwater, soil vapor, etc.) ☒ Figure 5 – Proposed Development (if available) ☒ Overlay of historical and proposed sample locations ☒ Graphic scale and north arrow ☐ Appendix – Summary of Historical Analytical Data (if needed) – to include tables and figures only.