20038_Auto Top Mfgr_Additional Assessment Letter_20170119

State of North Carolina | Environmental Quality | Waste Management
1646 Mail Service Center | 217 West Jones Street | Raleigh, NC 27699-1646
919 707 8200 T

January 19, 2017

Sent Via E-Mail

Mr. Kenneth Manell
Dimensional Fund Advisors, LP
1299 Ocean Boulevard
Santa Monica, CA 90401
[e-mail]

Subject: Additional Assessment
Former Auto Top Manufacturing
1524, 1532, 1538, 1544, 1546, 1550 S. Tryon St
Charlotte, Mecklenburg County
Brownfields Project Number: 20038-16-60

Dear Mr. Manell:

The North Carolina Department of Environmental Quality (DEQ) Brownfields Program has
reviewed the documents submitted with the Brownfields Property Application, as well as files
available through the DEQ Inactive Hazardous Sites Branch (IHSB). The following is a summary
of the reports reviewed:

 Phase I Environmental Site Assessment - ECS Carolinas, LLP (May 2016)
 Phase II ESA - ECS Carolinas, LLP (May 2016)

Based on our review of these documents, data gaps were identified. Additional assessment
activities, as outlined below, are required to assist in making risk management decisions for
inclusion in the brownfields agreement (BFA). Prior to conducting field activities, a work plan
should be submitted to DEQ for review and approval. The work plan should include a description
of the sampling and analytical methods to be utilized and a map depicting the proposed sample
locations. The most recent Inactive Hazardous Sites Program Guidelines for Assessment and
Cleanup (http://deq.nc.gov/about/divisions/waste-management) should be followed. Ensure that
laboratory method detection limits are below applicable standards, request Level 2 QA/QC data
packages from a N.C. certified environmental laboratory, and collect at least one duplicate sample
for all analysis collected.

1. Groundwater Sampling: Install one temporary monitoring well to the northeast and
downgradient of the Site building to assess potential groundwater impacts from the Site
operations, which were identified as a Recognized Environmental Condition (REC) in the
May 2016 Phase I ESA. The groundwater sample should be analyzed for Volatile Organic
Mr. Kenneth Manell
January 19, 2017
Page 2

State of North Carolina | Environmental Quality | Waste Management
1646 Mail Service Center | 217 West Jones Street | Raleigh, NC 27699-1646
919 707 8200 T

Compounds by EPA Method 8260 and Semi-VOCs (SVOCs) by EPA Method 8270. Soils
shall be screened using a Photo Ionization Detector (PID) during installation of the
temporary monitoring well. If evidence of impacts are detected, a soil sample shall be
collected from the depth interval exhibiting the highest evidence of impacts and analyzed
for VOCs by EPA Method 8260 and SVOCs by EPA Method 8270.

2. Receptor Survey: Complete the enclosed Brownfields Property receptor survey and
include as an attachment to the Additional Assessment Report.

3. Report and Figures: Upon receipt of analytical data, submit a summary report with a
description of field activities, tabulated data in comparison to applicable screening levels,
and the laboratory data packet with applicable QA/QC documentation, provide a site plan
with well locations, locations of sample points, and current site structures. Provide
concentration map(s) for contaminants detected above applicable standards. Include a
detailed description of current operations since the brownfields property application was
submitted in 2014. Please note, all sample points may need to be included on the future
Brownfields plat. DEQ recommends having sample locations surveyed at the time of
collection for use in preparation of the Brownfields plat.

Please note that depending on redevelopment plans for the Brownfields Property, additional
assessment may be required prior to redevelopment activities. An Environmental Management
Plan (EMP) must be submitted for DEQ’s approval prior to all redevelopment activities that will
disturb site soils, including grading and erosion and sediment control measures.

Please provide the Work Plan for additional assessment activities as soon as you are able. If you
have questions about this correspondence or require additional information, please feel free to
contact me by phone at 704-235-2166 or by email at [e-mail].

Sincerely,
Jordan Thompson
Brownfields Project Manager

ec: Tracy Wahl, DEQ