15031_WPDA_Borrow Soil WP_Approval_20200515

May 19, 2020
Sent Via E-mail
Scott M. Werley, P.G.
ECS Southeast, LLP
[e-mail] [phone]
Subject: Work Plan Approval WPDA Area 1 (RJR-Whitaker Park)
1125 Reynolds Blvd.
Winston-Salem, Forsyth County Brownfields Project No. 15031-11-034
Dear Mr. Werley:
The North Carolina Department of Environmental Quality (DEQ) Brownfields Program received the Import Soil Sampling Work Plan Rev. 1.0 – WDPA, Inc – Area 1 dated May 15, 2020 (Work Plan). DEQ Brownfield comments to previous revisions of this Work Plan have been addressed; therefore, the Work Plan is approved.
Please be advised that this approval from DEQ Brownfields does not waive any applicable requirement to obtain any necessary permits, licenses or certifications which may be required from other state or local entities. If you have any questions, please feel free to contact me at 919-707-8382, or via e-mail at [e-mail].
Sincerely,
Sarah Hardison Young
Project Manager Brownfields Property Management Unit
ec: Joselyn Harriger, DEQ Brownfields Program
Bryan Griswold, Cook Winston-Salem, LLC

May 15, 2020 Ms. Sarah Hardison-Young Brownfields Project Manager NC Department of Environmental Quality Division of Waste Management Brownfields Program Winston Salem Regional Office c/o [e-mail] Reference: Import Soil Sampling Work Plan Rev. 1.0 – WDPA, Inc – Area 1 Building 601-1, Reynolds Boulevard Winston-Salem, Forsyth County, North Carolina 28401 ECS Project No. 49:7968-E North Carolina Brownfield Project No. 15031-11-034 Dear Ms. Hardison-Young: ECS Southeast, LLP (ECS) has prepared the attached Import Soil Sampling Work Plan for your review and approval. Please review the Work Plan, and provide return correspondence indicating NC Brownfields Program approval. ECS greatly appreciates the opportunity to work with your Program. If there are questions regarding the attached, or a need for further information, please contact us. Respectfully submitted, ECS SOUTHEAST, LLP
Scott M. Werley, P.G.
Environmental Principal
[e-mail]
[phone]

Colby T. Jones
Environmental Staff Project Manager
[e-mail]
[phone]

Cc: Cook Winston-Salem, LLC, Bryan Griswold, c/o [e-mail]

TABLE OF CONTENTS

1.0 INTRODUCTION ................................................................................................................ 1
1.1 Project Information ........................................................................................................ 1
1.2 Proposed Development ............................................................................................ 1
2.0 SCOPE OF WORK ............................................................................................................. 1
2.1 Sample Collection .......................................................................................................... 1
2.2 Sample Locations .......................................................................................................... 2
2.3 Deviation from Approved Plan ..................................................................................... 2
3.0 SAMPLING METHODOLOGY ................................................................................................ 2
3.1 Sampling Methodology ................................................................................................. 2
4.0 LABORATORY ANALYSIS ............................................................................................... 3
4.1 Soil Analytical ................................................................................................................. 3
5.0 QA/QC ................................................................................................................................ 3
6.0 INVESTIGATION DERIVED WASTE (IDW) MANAGEMENT ........................................... 3

FIGURES

Figure 1 Site Topographic Location Map
Figure 2 Proposed Borrow Source Sample Location Map

APPENDICIES

Appendix A Environmental Site Assessment Work Plan Minimum Requirements
Checklist, NCDEQ Brownfields Program – V. Nov. 2018

Imported Soil Sampling Work Plan - Rev 1.0
WDPA, Inc. – Area 1
Brownfields Project Number 15031-11-034
ECS Project No. 49.7968-E
May 15, 2020

1

1.0 INTRODUCTION

1.1 Project Information

The subject brownfields site (Brownfields Project Number 15031-11-034), known as WDPA, Inc.
– Area 1, is located on Reynolds Boulevard in Winston-Salem, Forsyth County, North Carolina.
The subject site includes Building 601-1 and is being redeveloped under an existing Brownfields
Agreement for WPDA, Inc. by Cook Winston-Salem, LLC (Cook). Building 601-1 is located in
Area-1 of Whitaker Park and is illustrated on the included Figure 1: Site Topographic
Location Map.

According to the Forsyth County Tax Parcel Viewer the site is identified by Parcel Identification
Number (PIN) 6827-80-0980 and owned by WPDA, Inc. The subject property includes a 37.43±
acre parcel with an approximately 791,000 square-foot multi-story industrial building and
associated parking lots. Municipal water and sanitary sewer, cable, natural gas and electricity
are available within the vicinity of the site.

1.2 Proposed Development

The property is currently planned to be redeveloped by Cook with a commercial structure that
manufactures medical supplies/equipment. In order to support redevelopment and accomplish
landscape initiatives, it has been estimated that the brownfields site will require 400 to 420 cubic
yards (CY) of imported fill that will support plantings within the proposed landscape area.

An Environmental Management Plan (EMP), prepared by ECS and dated March 8, 2020 has
been approved by the North Carolina Department of Environmental Quality (NCDEQ)
Brownfields Program. Receiving borrow fill from a facility not listed on the NC Division of
Energy, Mines, and Land Resources (DEMLR) permitted mines list suggests a sampling
frequency of one sample set for every approximate 500 CY of soil to be imported. As such one
sample set will be sufficient to import the estimated 400 to 420 cubic yards of soil to the project
site. The sample is to be collected as a representative sample of the soil being imported to the
project site. A work plan for the imported soil sampling will be required to be approved by the
Brownfields Project Manager prior to its implementation. The data collected during this
assessment is intended for use only by Brownfields and not by other NCDEQ programs.

2.0 SCOPE OF WORK
2.1 Sample Collection

Soil sampling will occur from representative areas of the borrow source. The soil will be
stockpiled at the borrow source site prior to mobilization by ECS to perform the sampling. The
composite sample will be comprised of five individual grab soil samples collected in duplicate re-
sealable bags from various locations of the borrow source’s stockpiled soil to be imported to the
project site. Soil samples will be collected from one to two feet below the surface of the source
stockpile. Each individual sample will be screened using a photoionization detector (PID) for
volatile vapors. The individual grab soil sample with the highest PID reading will be
Imported Soil Sampling Work Plan - Rev 1.0
WDPA, Inc. – Area 1
Brownfields Project Number 15031-11-034
ECS Project No. 49.7968-E
May 15, 2020

2

appropriately packaged from its duplicate re-sealable bag, and submitted to a North Carolina
certified laboratory to be analyzed for volatile organic compounds (VOCs) using EPA Method
8260. Subsequently, each of the other grab soil samples will be gently mixed together and one
composite soil sample per approximately every 500 cubic yards of soil to be imported will be
submitted for analysis by EPA Method 8270 for Semi-Volatile Organic Compounds (SVOCs),
total RCRA 8-metals using EPA Method 6010, and for hexavalent chromium by EPA Method
7199 (see Table 1).

2.2 Sample Locations

The areas to be sampled are illustrated on the attached figure. The borrow source is known as:

Lowder Mulch & Topsoil
2810 Griffith Road
Winston-Salem, North Carolina 27103
Phone: [phone]

2.3 Deviation from Approved Plan

This work plan is intended to be dynamic and to be adapted to specific and actual site
conditions. Accordingly, should such conditions warrant a change either by addition, deletion or
modification of a procedure, such may be accomplished with agreement between Cook’s
representative and ECS after consultation with, and subject to approval by the Brownfields
Program. Such changes will comply with applicable local, State and Federal rules and
regulations. A written amendment shall be prepared and submitted to the Brownfields Program
for approval prior to implementation. Amendments must have the approval of the Brownfields
Program prior to implementation.

3.0 SAMPLING METHODOLOGY

3.1 Sampling Methodology

Per Cook’s approved EMP, testing is to be conducted for VOCs by EPA Method 8260, SVOCs
by EPA Method 8270, RCRA 8-Metals by EPA Method 6010, and for hexavalent chromium by
EPA Method 7199. A total of one representative soil sample will be collected from the area of
the stockpile where soil will be loaded for import to the site. That volume of soil to be imported
will remain undisturbed and held specifically for import to the Brownfields property until ECS
receives laboratory results and Brownfields approval. Soil samples will be collected from one to
two feet below the surface of the stockpile with the use of a hand auger. Each individual sample
will be screened using a PID for volatile vapors. The individual grab soil sample with the highest
PID reading will be appropriately packaged from its duplicate re-sealable bag, and submitted to
a North Carolina certified laboratory to be analyzed for VOCs. Subsequently, each of the other
grab soil samples will be gently mixed together and one composite soil sample per
approximately every 500 cubic yards of soil to be imported will be submitted for analysis for
SVOCs, total RCRA 8-metals, and for hexavalent chromium. Laboratory results of the soil
Imported Soil Sampling Work Plan - Rev 1.0
WDPA, Inc. – Area 1
Brownfields Project Number 15031-11-034
ECS Project No. 49.7968-E
May 15, 2020

3

samples will be compared to the most current version of the NCDEQ Residential Preliminary
Soil Remediation Goals (PSRGs) and Industrial/Commercial PSRGs.

The objective of this work plan is to maintain the liability protections offered by the brownfields
program by characterizing the soil quality prior to it being delivered to the brownfields site. The
specific area of the borrow source to be sampled has been depicted on the attached Figure 2:
Proposed Borrow Source Sample Location Map which illustrates recent aerial photography
of the facility.

4.0 LABORATORY ANALYSIS

4.1 Soil Analytical

Following sample collection, the sample containers will be labeled and maintained under chain-
of-custody until delivered to Pace a North Carolina certified laboratory located in Huntersville,
North Carolina. Pace currently holds NC Lab Certification #12. A Chain-of-Custody document
will be utilized throughout the collection and transportation of the samples. The soil quality
sample collected will be analyzed for VOCs by EPA Method 8260, SVOCs by EPA Method
8270, RCRA 8-metals by EPA Methods 6010/7471 and Cr VI by EPA Method 7199.

Field screening will be conducted with a PID or similar. The ECS environmental professional will
observe and document the soil, note the color and texture of the soil, and note if the soil exhibits
staining or exudes distinguishable odors. The volume of soil collected will be sufficient for the
laboratory to complete MS/MSD analysis.

5.0 QA/QC

The laboratory’s Reporting Limits (RLs) and/or Method Detection Limits (MDLs) will be reported
at or below Industrial/Commercial Preliminary Soil Remediation Goals (PSRGs) (to the extent
feasible) and J Flags (laboratory estimated concentrations) will be reported. A Level II QA/QC
package will be reported by the laboratory.

6.0 INVESTIGATION DERIVED WASTE (IDW) MANAGEMENT

No investigation derived waste is expected to be generated during the activities described in this
work plan.

7.0 REPORTING

ECS will prepare a written report documenting the field activities, sampling procedures,
laboratory analytical results, applicable figures and tables, conclusions, and recommendations
for submission to the Program. Only upon receipt of the Program’s review of the soil data can
the mobilization of the soil take place. If unidentified and unexpected conditions are
encountered during the assessment, Cook will be notified. The final report will include ECS’
registered Geologist Firm number and bare the seal of the certifying NC Licensed Geologist.
Imported Soil Sampling Work Plan - Rev 1.0
WDPA, Inc. – Area 1
Brownfields Project Number 15031-11-034
ECS Project No. 49.7968-E
May 15, 2020

4

The responsibility of notifying the NCDEQ and other external parties lies solely with Cook
and/or with ECS acting on their behalf.

The NCDEQ Brownfields Program contact is:
Ms. Sarah Hardison Young, Brownfields Project Manager
[e-mail]
NCDEQ, DWM, NC Brownfields Program
Phone: [phone]

FIGURE(S)

SOURCE:
USGS TOPOGRAPHIC MAP
RURAL HALL, DATED 1969 AND REVISED
1997
FIGURE 1
SITE TOPOGRAPHIC LOCATION MAP
RJR WHITAKER PARK –AREA 1
REYNOLDS BOULEVARD
WINSTON-SALEM, FORSYTH COUNTY, NC
BROWNFIELDS PROJECT NO. 15031-11-034
ECS PROJECT NO. 49:7968-E
APPROXIMATE SITE BOUNDARY
2,000’
Area 1
SOURCE:
GOOGLE EARTH
IMAGERY DATED 2020
APPROXIMATE SCALE:
SITE PARCEL BOUNDARY
PROPOSED BORROW PIT SAMPLE LOCATION
(to be composited for SVOCs & RCRA-8)
(highest PID reading grabbed for VOCs)
190 FT.
LOWDER MULCH & TOPSOIL
2810 Griffith Road
Winston-Salem, NC
B-1
B-2
B-3B-4
B-5
FIGURE 2
PROPOSED BORROW SOURCE SAMPLE
LOCATION MAP
RJR WHITAKER PARK –AREA 1
REYNOLDS BOULEVARD
WINSTON-SALEM, FORSYTH COUNTY, NC
BROWNFIELDS PROJECT NO. 15031-11-034
ECS PROJECT NO. 49:7968-E

TABLE

BORING ID PROPOSED PARCEL ADDRESS & PIN SAMPLING OBJECTIVE DEPTH OF ANALYTICAL METHOD
Table 1: Brownfields Program Checklist For Proposed Sample Locations
Borrow Pit Sampling Work Plan – Cook Medical
Brownfields Program Site No. 15031-11-034
Building 601-1 Reynolds Blvd., Winston-Salem, North Carolina
ECS Project No. 49:7968-E
Assess soil quality, characterize soil,
and analyze contents. To determine if
the borrow source soil is suitable for
importing to the Cook Medical site.
VOCs by EPA Method 8260; SVOCs by
EPA Method 8270; RCRA 8-metals by
EPA Method 6010; and Cr VI by EPA
Method 7199.
1 to 2 feet bgsB-1, B-2, B-3,
B-4, B-5
Refer to Figure 2 for proposed sample locations
2810 Griffith Rd., Winston-
Salem, NC
6827-80-0980
SS-1
Notes:
VOCs will be collected as a grab sample from the boring within the composite with the highest PID reading
SVOCs, Metals, and Cr VI will be collected as composite samples

APPENDIX A

NOVEMBER 2018 BROWNFIELDS WORK PLAN CHECKLIST