20050 Rite Aid UST WP-Approval 20180301

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

March 1, 2018

Sent Via E-mail

Matt Ingalls
Hart & Hickman, PC
2923 South Tryon Street, Suite 100 Charlotte, NC 28203
[e-mail]

Subject: Work Plan Approval
Rite Aid Brownfields Property Charlotte, Mecklenburg County
Brownfields Project No. 20050-16-060

Dear Mr. Ingalls,
The Department of Environmental Quality (DEQ) Brownfields Program received the UST Removal Activities Work Plan dated February 28, 2017 (Work Plan) for the above referenced
Brownfields Property. DEQ Brownfields reviewed this document, and determined that comments
made by DEQ Brownfields on February 20, 2018 to previous versions of this work plan have been
incorporated as requested. DEQ Brownfields approves the Work Plan dated February 28, 2018. 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 questions about this correspondence or require additional
information, please feel free to contact me by phone at 704/661-0330 or by email at [e-mail].
Sincerely,

Carolyn Minnich
Carolyn Minnich
Brownfields Project Manager

Via Email
February 28, 2018

NC DEQ Brownfields Program Mail Service Center 1646
Raleigh, North Carolina 27699-1646

Attention: Ms. Carolyn Minnich Re: Work Plan (revised 2-28-18)
UST Removal Activities - Brownfields
Rite Aid Brownfields Property
1776 Statesville Avenue Charlotte, North Carolina DEQ Brownfields Project No.: 20050-16-060
H&H Project No. ATL-001

Dear Carolyn:
1.0 Introduction

On behalf of CAMP Landowner, LP (a.k.a. CAMP North End), Hart & Hickman, PC (H&H) is
presenting this work plan to remove eight (8) underground storage tanks (USTs) identified at the
Rite Aid Brownfields property (Brownfields Project No. 20050-16-060) located at 1776
Statesville Avenue in Charlotte, Mecklenburg County, North Carolina (see Figure 1). CAMP
North End has requested removal of the USTs prior to proposed development in this portion of
the site.

During Phase II Environmental Site Assessment (ESA) sampling activities conducted in 2016,
the eight (8) USTs were identified utilizing ground penetrating radar (GPR) survey techniques
west of Building 48 and below former Building 9 that was reportedly demolished in the early
1970s. The tanks are depicted on a figure provided by Hoffman Engineering located within a
concrete basin below the floor of the former building and appear to range in size between 6,000
Ms. Carolyn Minnich
February 28, 2018
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and 8,000-gallons. It appears that the USTs contained fuel oil used in a former boiler unit staged
within an adjacent building. It is our understanding that the fuel oil USTs were not previously
used by Rite Aid or CAMP North End (the current property owner).

In 2016, H&H collected soil samples and a groundwater sample in the vicinity of the suspected
USTs. Volatile organic compounds (VOCs) were detected in the soil samples at concentrations
above the North Carolina Department of Environmental Quality (DEQ) soil-to-groundwater
maximum soil contaminant concentrations (MSCCs). Additionally, benzene was detected above
its groundwater standard in a temporary monitoring well installed adjacent to the USTs.

A summary of our proposed UST removal activities in this area is provided in the following
sections.

2.0 Scope of Work

2.1 UST Removal
H&H will contact the public utility locator to mark utilities in the UST area and will also hire a
private utility locator to demark locations for subgrade utilities and to identify the approximate
boundary of the UST basin.

Please note that the Mecklenburg County Fire Marshal’s office now requires a permit and a fee
to remove tanks in Mecklenburg County. H&H and/or the tank removal contractor will obtain
the permit and request an inspection by the Mecklenburg County Fire Marshal prior to removal
of the USTs.

Initial excavation activities will include removing the overlying asphalt/concrete and soil to
locate the fill port and checking the tanks for residual fluids. It is anticipated that up to 3,000 ft2
of asphalt/concrete will be removed to access and remove the USTs and associated piping. In
accordance with Mecklenburg County requirements, the insides of the USTs will then be cleaned
with a pressure washer and all wash-water will be removed with a vacuum truck. We have
Ms. Carolyn Minnich
February 28, 2018
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assumed that washing the eight (8) USTs will generated approximately 800 gallons of washwater
(100 gallons/tank) that will require disposal.

After cleaning the interior of the tanks, dry ice (carbon dioxide) will be added to purge potential
explosive vapors from the tanks. A lower explosion level (LEL) meter will be utilized to
monitor for explosive atmospheres in and near the tanks during the purging process. Tank
purging will continue until readings within the tanks are less than 10% of the LEL.

Following purging, the tanks and associated piping (if encountered during excavation) will be
removed from the ground and samples will be collected. Please note that recent GPR survey
results did not identify obvious evidence of product piping associated with the USTs near the
tank basin. Based on recent GPR survey information, it appears that the eight (8) USTs are
located in a single tank basin that measures approximately 30 ft x 30 ft. Therefore, H&H
anticipates that the horizontal extent of the excavation may measure approximately 35 ft x 35 ft.
The actual horizontal and the vertical extent of the excavation will be determined based on soil
screening and sample data collected during tank removal activities.

During excavation, soil overlying the tank will be screened for the presence of soil impacts using
sensory methods (i.e., visual and olfactory evaluation) as well as for the presence of organic
vapors using a field photoionization detector (PID). Soil will be stockpiled for later use as
backfill and will be replaced back into the UST basin implementing “last soil out first soil in”
methodology. Following removal, the exterior of the tanks will be cleaned of soil and loaded
onto a trailer for off-site cut up for scrap metal.

Please note that if free product laden soils are identified in the UST basin, or if CAMP North
End elects to remove petroleum-impacted soil from the UST excavation in an attempt to obtain a
No Further Action (NFA) from the DEQ Division of Waste Management UST Section, H&H
will direct the excavation contractor to remove petroleum-impacted soils for transport and
disposal at an off-site permitted treatment/disposal facility.

Ms. Carolyn Minnich
February 28, 2018
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UST Basin Soil Sampling
Following removal of the tanks from the ground, H&H will collect shallow soil samples from the
excavation selecting one of the options below.

Option 1: If CAMP North End elects to obtain a NFA form the DEQ DWM UST Section, H&H
will direct the contractor to remove the petroleum-impacted soil from the UST basin and sample
the sidewalls and base of the excavation (up to 8 samples total) to document residual levels of
compounds remaining in soil. H&H will also collect soil samples at locations below the UST
product lines if encountered during UST removal activities (one [1] sample/ten [10] linear ft of
product line). These soil samples will be analyzed for VOCs by EPA Method 5035/8260B, semi-
volatile organic compounds (semi-VOCs) by EPA method 8270C, volatile petroleum
hydrocarbons (VPH) and extractable petroleum hydrocarbons (EPH) by the Massachusetts
Department of Environmental Protection (MADEP) Method.

Option 2: If CAMP North End elects to manage petroleum-impacted in place via the existing
DEQ Brownfields Agreement, H&H will direct the contractor to leave the petroleum-impacted
soil in place and will collect four (4) samples from the excavation base to characterize soil
remaining in the tank basin. H&H will also collect soil samples at locations below the UST
product lines if encountered during UST removal activities (one [1] sample/ten [10] linear ft of
product line). The soil samples will be analyzed for VOCs by EPA Method 5035/8260B,
SVOCs by EPA Method 8270C, and EPA Priority Pollutant List (PPL) metals including arsenic,
beryllium, cadmium, chromium, hexavalent chromium, copper, mercury, nickel, lead, antimony,
selenium, silver, thallium and zinc by EPA Method 6020B, 7471B (mercury only), and 7196A
(hexavalent chromium only). H&H will request that the laboratory attain a 0.3 milligrams per
kilogram (mg/kg) reporting limit for hexavalent chromium.

The excavation will be backfilled with soil removed from the excavation implementing “last soil
out first soil in” methodology. Additional soil needed to bring the excavation to grade will be
obtained from either another location on the former Rite Aid Brownfields site or from a local
quarry/borrow pit, which will require collection of a soil sample for DEQ Brownfields approval
TITLE
PROJECT
SITE LOCATION MAP
RITE AID BROWNFIELDS PROPERTY
1776 STATESVILLE AVENUE
CHARLOTTE, NORTH CAROLINA
DATE:
JOB NO:
REVISION NO:
FIGURE NO:
12-15-16 0
1ATL-001
0 2000 4000
APPROXIMATE
SCALE IN FEETN
U.S.G.S. QUADRANGLE MAP
QUADRANGLE
7.5 MINUTE SERIES (TOPOGRAPHIC)
CHARLOTTE EAST, NC 1967
REVISED/INSPECTED 1988
AND
DERITA, NC 1993
SITE
UST BASIN SOIL SAMPLE LOCATION MAP
RITE AID BROWNFIELDS PROPERTY
1776 STATESVILLE AVENUE
CHARLOTTE, NORTH CAROLINA
DATE:
JOB NO:
REVISION NO:
FIGURE NO:
2/28/18 1
2ATL-001050100
APPROXIMATE SCALE IN FEETN 2923 S. Tryon Street, Suite 100Charlotte, NC 28203704.586.0007(p) 704.586.0373(f)
Proposed Soil Sample Location for UST Closure
–DEQ DWM UST Section
UST Basin Location
Proposed Soil Sample Location–DEQ Brownfields