Dilworth Mattress LOE Response

August 25, 2016 NC DEQ Brownfields Section 1646 Mail Service Center 217 West Jones St.
Raleigh, NC 27699-1646

Attn: Mr. Bruce Nicholson

Re: Brownfields Eligibility Response
Dilworth Mattress Property
242 West Tremont Ave.
Charlotte, North Carolina
DEQ Brownfields Project No. 20053-16-60
H&H Job No. GFP-005

Dear Bruce:
On behalf of The Horne Company Partners, LLC, Hart & Hickman, PC (H&H) is providing this
response to your letter dated August 12, 2016 concerning the Brownfields Property Application for
the Dilworth Mattress Property located at 242 West Tremont Ave. in Charlotte (site). In this letter,
the Department of Environmental Quality (DEQ) Brownfields Section indicates that the project is
not eligible at this time because of the potential that impacts associated with a former 300-gallon
fuel oil underground storage tank (UST) on the Gas Fired Products facility located on the adjacent
property to the west at 306 West Tremont Ave. (which has received a no further action from DEQ
UST Section) may have impacted the site. You assert that this UST was located upgradient of the
site.

However, based upon our review of information, we believe that your conclusion that the UST was
located upgradient of the site is incorrect. The location of the UST in relation to the site is indicated
in Figure 2. As shown in Figure 2, the UST was located approximately 60 ft west of the site. A
Mr. Bruce Nicholson August 25, 2016 Page 2
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review of the topographic map in Figure 1 indicates that the topographic gradient in the area of the
site is to the west-northwest toward Sugar Creek. As such, the UST is located topographically
downgradient of the site. This is further confirmed by groundwater elevation data from the adjacent
property to the south which is the former Virginia Carolina Chemicals facility. A groundwater
elevation contour map from data collected in 2012 by Arcadis confirms that groundwater flow in the
area of the site is to the northwest and that the UST at 306 West Tremont is located downgradient of
the site. The groundwater flow map is provided as Figure 3 along the approximate locations of 306
West Tremont Ave. and the site.

H&H also reviewed the data for the UST release at the 306 West Tremont Ave. property. The
groundwater sample collected from the area of the UST in 2003 indicated that the compounds
detected above NC groundwater standards were naphthalene (620 µg/l), phenanthrene (370 µg/l),
and xylenes (620 µg/l). The data do not indicate the presence of free product or high compound
concentrations (see Appendix A) in association with the UST release which, although very unlikely,
could be associated with upgradient migration or diffusion.

In summary, based upon topographic gradient, confirmed groundwater flow direction, lack of free
product or high concentrations, and distance from the site, we conclude that there is no reasonable
potential for impact to the site from the closed UST release incident at the Gas Fired Products
facility at 306 West Tremont Ave. As such, we respectfully request that you reconsider the position
in your August 12, 2016 letter and find The Horne Company Partners, LLC eligible for the
Brownfields program for the site.

Mr. Bruce Nicholson August 25, 2016 Page 3
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Please feel free to contact me or Ms. Mary Katherine Stukes with Parker Poe if you have any
questions or require additional information.

Very truly yours,

Hart & Hickman, PC
Steve Hart, PG
Principal

Attachments cc: Ms. Carolyn Minnich Mr. Frank Horne Ms. Mary Katherine Stukes
SITE LOCATION MAP
DILWORTH MATTRESS FACTORY242 WEST TREMONT AVENUECHARLOTTE, NORTH CAROLINA
DATE:
JOB NO:
REVISION NO:
FIGURE NO:
05-16-16 0
1GFP-075
0 1150 2300
APPROXIMATE
SCALE IN FEET
N
U.S.G.S. QUADRANGLE MAP7.5 MINUTE SERIES (TOPOGRAPHIC)
2923 S. Tryon Street, Suite 100Charlotte, NC 28203704.586.0007(p) 704.586.0373(f)
CHARLOTTE EAST, NORTH CAROLINA 1991
SITE
JOB NO. GFP-005
REVISION NO. 0DATE: 7-6-16
FIGURE NO. 2
LEGEND
SITE PROPERTY BOUNDARY
FLOOR DRAIN
STORMWATER DRAIN
AIR COMPRESSOR
HEATING OIL ABOVEGROUND
STORAGE TANK
DILWORTH MATTRESS FACTORY
242 WEST TREMONT AVENUE
CHARLOTTE, NORTH CAROLINA
SITE MAP
2923 South Tryon Street-Suite 100
Charlotte, North Carolina 28203
704-586-0007(p) 704-586-0373(f)
License # C-1269 / #C-245 Geology
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Appendix A 306 West Tremont Ave. UST Report