20042_Pugh Tire_DM_20200522

DECISION MEMORANDUM
DATE: May 22, 2020
FROM: Tony Duque
TO: BF Assessment File
RE: Pugh's Tire and Service Center
400 S. Green Street
Greenville, Pitt County
Brownfields Project No. 20042-16-074
Based on the following information, it has been determined that the above referenced
site, whose intended use is for no uses other than high -density residential and retail uses
with associated parking, can be made suitable for such uses.
Introduction:
The Brownfields Property comprises one parcel totaling 2.05 acres and occupies the city
block bounded by W. 4th St. on the north, S. Greene St. on the east, W. 5th St. on the
south and S. Pitt St. on the west. The Brownfields Property is located on the western
margins of Greenville's central business district and is bounded on the north by a parking
lot, on the south by Greenville Fire and Police Departments, on the east by Greenville
City Hall and Greenville Utilities Commission, and on the west by a parking lot and
single family residences beyond and to the northwest.
The Brownfields Property was first developed in the late 1800s for residential use.
Commercial development first occurred in the mid- 1940s and included a bus station, a
gasoline service station and an auto tire/service facility known as Pugh Tire and Service
Center. The Prospective Developer has completed the redevelopment of the site into a
five -story residential apartment facility. Soil and groundwater are impacted at the
Brownfields Property from historic onsite use as a gas station and an auto servicing shop.
The Prospective Developer, RDC Gather Uptown, LLC is a member -managed Delaware
Limited Liability Company formed on August 10, 2016 and registered to do business in
North Carolina. RDC Gather Uptown, LLC is a subsidiary of Raelcorp, which specializes
in high -end apartment developments. The Prospective Developer is also the owner of the
Brownfields Property, having purchased it in September 2016.
Redevelopment Plans:
The Brownfields Property has been redeveloped with a new five -story residential
apartment building known locally as Gather Uptown. Although the facility offers an up-
scale apartment living experience, most of the residents are students as the apartment
building is located five blocks of the East Carolina University campus. The facility is
believed to be fully leased.

Site History:
The Brownfields Property was in single family residential use prior to the late 1800s. In
the mid- 1940s, a bus station and a gas station were developed in the south-central and
southeastern portions of the site, respectively. Trailways and/or Greyhound operated the
bus terminal continuously from the mid- 1940s until 2008. The vacated bus terminal
building was razed in in 2016 in preparation for the redevelopment of the site.
The first gas station operated as Pugh Shell Station at the southeast corner of the site from
the mid-1940s until 1970 when the station building was razed and the dispenser islands
were removed. The USTs associated with the first station were removed in 1980 at the
time the tire center office building was constructed, although the number and size of the
USTs associated with the first gas station is unknown.
In 1980, a second gas station was constructed in close proximity to the first station and
included the installation of three new USTs. That second station operated until 1999 at
which time these USTs, product lines and dispenser islands were removed in January
1999. The release incident associated with those USTs (UST Incident #197440) was first
reported in February 1999 and was closed by the UST Section in 2000 with known
groundwater impacts in excess of 2L standards but with no reported soil impacts
exceeding residential MSCCs.
Between the early 1960s and the 1980s, the Pugh family, operators of the gas stations,
had acquired the remainder of the site from previous residential owners and had razed all
the residences. The Pughs began construction of the Pugh Tire and Service Center in the
east central portion of the site in 1964, and the facility was expanded in 1965 and 1971 to
include additional service bays, in -ground hydraulic lifts and an auto wash bay.
Operations at the tire store ceased in 2016, and it remained dormant thereafter. UST
Incident #38616 was opened as a result of assessment activities conducted in association
with the planned redevelopment of the site. A Notice of Residual Petroleum prohibiting
the use of site groundwater as a water supply, was recorded on September 23, 2016, and
the UST incident was closed on September 30, 2016.
Prospective Developer purchased the Brownfields Property on September 12, 2016 from
the various members of the Pugh family.
Potential Receptors:
Potential receptors are: construction workers, on -site workers, future residents, visitors,
and trespassers.
Contaminated Media:
DEQ has evaluated data collected from the following media at the subject property: soil,
groundwater, and soil vapor. DEQ relies on the following data to base its conclusions
regarding the subject property and its suitability for its intended reuse.
A geophysical investigation, consisting of metal detection and ground penetrating radar,
was conducted at the site in September 2015. The results of the survey confirmed 1) the
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removal of former USTs, 2) the location of two heating oil USTs for the second gas
station, 3) the drainage route of the wash bay at the tire center, 4) the removal of the two
hydraulic lifts at the tire center, and 5) the location of, and product line path for, the
heating oil UST at the former bus station.
Soil cleanup and soil and groundwater assessment activities were conducted at the site on
three occasions: a first round of assessment and cleanup activities conducted in 1999
following the removal of the three USTs, dispenser island and associated piping in use
with the second gas station that operated at the site; a second round of assessment and
cleanup activities conducted in light of the results of the August 2015 Phase I
Environmental Site Assessment (ESA) and the Recognized Environmental Conditions
identified in the ESA; and a third round of assessment and cleanup activities conducted in
June and July 2016 following the discovery of two orphaned heating oil USTs early
during the site's redevelopment.
Soil gas sampling activities were conducted in October 2016, in accordance with the
Environmental Management Plan in effect for the site, to evaluate the potential for vapor
intrusion at the site.
Soil
Extensive soil sampling was conducted at the Brownfields Property. Soil assessment was
related to the assessments of UST incidents and was in response to the results of the
Phase I ESA conducted at the site in August 2015 in conjunction with the planned
redevelopment of the property.
Twenty-three soil samples were collected in conjunction with the closure of the three gas
station USTs. TPH 3050 (targeting gasoline) results from the tank graves indicated only
one of the three UST had caused a release. Results of samples collected from beneath the
pump island and product lines also indicated releases had occurred. The results of post -
excavation sampling indicated minor exceedances of the 10 mg/kg action limit in three of
the nine excavation sidewall samples. Excavations were backfilled with native soil form a
local borrow pit. There is no record of sampling of the borrow pit soil. A total of 130.9
tons of non -hazardous petroleum contaminated soil was excavated and transported to
G&S Land Company in Williamston, NC for disposal.
In addition to the sampling conducted in relation to the closure of the USTs in 1999, soil
sampling was also conducted in the following locations at the site: the heating oil UST at
the former bus station; in the location of the USTs and dispenser islands and piping at the
second gas station; in the former tire center at 1) the wash bay drains, 2) the air
compressor shed, 3) the waste oil AST and drum storage area, 5) floor drains, and 5) the
hydraulic lifts.
Results of soil sampling indicated the presence of TPH (GRO & DRO) concentrations in
excess of the UST action limit of 10 mg/kg in the following areas: the waste oil AST, the
air compressor shed, the heating oil UST at the former bus station, the wash bay drain
and the hydraulic lift #9. Several petroleum contaminants were detected above their soil-

to -groundwater MSCCs in one of the samples from the gas station UST area. And some
of the petroleum contaminant concentrations exceeded their Residential MSCCs in that
same sample. It is significant to note that chlorinated solvents were not detected in the
soil samples.
In response to the results of soil sampling, petroleum contaminated soil was excavated
from the following areas: from the vicinity of the 1,000-gallon heating oil UST at the
former bus station; from the dispenser island area at the former gas station; and from the
wash bay and waste oil AST areas at the tire center. Following the demolition of all
former site buildings, additional petroleum contaminated soil was excavated from the
area of the bus station heating oil UST, from the waste oil AST area, and from the area in
the vicinity of hydraulic life #9. During the excavation of impacted soil from the bus
station heating oil UST, an orphan heating oil UST was discovered. After removal of the
orphan tank, there was no visual or olfactory indication that a release had occurred, and
the results of a soil sample collected from beneath the tank confirmed that to be the case.
from the tank. A total of 641.65 tons of petroleum contaminated soil were excavated
during the above -described cleanup activities. The soil was transported to Greenwood
Landfarm in Windsor, NC for disposal.
Groundwater
In July 2016, the top of groundwater at the Brownfields Property ranged in depth from 10
feet bgs in the east central portion of the site (possibly perched) to 22 feet bgs in both the
northeast and southeast corners of the site. The direction of groundwater flow at the site
was determined to be to the north-northwest.
A type II groundwater monitoring well was installed following the removal of the USTs
at the gas station in March 1999. Analytical results of the groundwater sample indicated
concentrations of petroleum compounds exceeding the 2L groundwater standards. In light
of those results, in June 1999, four additional monitoring wells were installed in locations
that surrounded the source area UST. No free product was detected in any of the wells.
Analytical results of sampling indicated the presence of a plume of petroleum
contaminated groundwater existed at the site, but the results for the two downgradient
wells suggested that the contaminant plume had not likely migrated off of the property. It
is worth mentioning that analytical results did not disclose the presence of chlorinated
solvents in any of these five groundwater samples. A receptor survey was conducted at
the time and did not disclose the presence of any sensitive receptors or water supply wells
within 1,500 feet of the site.
In October 2015, five groundwater samples, GW1-GW5, were collected across the site.
Three samples were collected using direct push technology and two samples were
collected from temporary monitoring wells installed in solid stem auger borings. Samples
were collected from the following locations: GW1, northeast corner of the site, adjacent
to offsite former dry cleaners and a gas station; GW2, in the tire store garage near the
hydraulic lifts; GW3, in the tire store garage near the waste oil AST and the drum
storage; GW4, in the gas station UST basin near the initial groundwater monitoring well
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described above; and GW5, near the southern property line adjacent to a former offsite
gas station to the south.
Analytical results of groundwater samples collected during the October 2015 sampling
event (samples GW1-GW5) indicated the presence of petroleum contaminants in both
GW 1 and GW5 in concentrations that exceeded 2L Standards, and petroleum
contaminants in GW2, GW3 and GW4 above method detection limits but below 2L
Standards. Since no use of petroleum products on the site is known to have occurred
anywhere near the northeast corner of the property, the detection of petroleum
compounds in GW 1 is believed to be from the documented release from Bill's Fast Food
gas station formerly located offsite, on the southeast corner of the adjacent property to the
north. The other detections of petroleum compounds in GW2, GW4 and GW5 are
thought to be related to the release from the former Pugh's Shell gas station UST, and
from the use of petroleum products in the tire store.
Tetrachloroethene (PCE) was detected at an estimated (J-flagged) concentration of 0.31
µg/L, below the 2L Standard of 0.7 µg/L, in groundwater sample GW3, near the waste oil
AST and drum storage area. It was, and is still speculated that the detection of PCE in
this one groundwater sample could be linked to the use of the solvent as a degreaser in
the tire store garage.
Soil excavations in the former bus station heating oil UST and the gas station dispenser
island area progressed to the water table. At that time soils were saturated at 11 feet
below ground surface (bgs) and standing water was observed at 13 feet bgs. In July 2016,
to further investigate previous detection of groundwater impacts, four additional
monitoring wells were installed at the site at the following locations: MW1, in the
northeast corner of the property, to confirm detections seen in GW 1; MW2 near the
location of GW3, near the waste oil AST, but closer to the former tire center building;
MW3 near the UST tank graves at the gas station and the orphan heating oil UST; and
MW4 near the former heating oil UST at the former bus station.
Analytical results of groundwater samples collected during the 2016 groundwater
monitoring event detected petroleum contaminants in excess of the 2L Standard in
monitoring wells MW1, MW3 and MW4. Petroleum compounds exceeding 2L include
Benzene, Naphthalene and Isopropylbenzene. No petroleum contaminants were detected
in MW2, located near the waste oil AST and near 2015's groundwater sample GW3.
However, PCE was detected at an estimated (again J-flagged) 0.42 µg/L, again below the
2L Standard.
PCE has been detected in two groundwater samples located very near each other, but has
not been detected in any other soil or groundwater samples at the site. The highest
concentration of PCE detected in groundwater (0.42 µg/L) does not exceed the 2L
Standard (0.7 µg/L) or DWM's Residential Groundwater Vapor Intrusion Screening
Level (VISL) (12 µg/L) and is thus not among the contaminants that might pose a vapor
intrusion (VI) risk at the site.
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However, some of the petroleum compounds were detected in groundwater in
concentrations that exceed the Residential Groundwater VISL, including Benzene,
Ethylbenzene, Naphthalene, Xylene, 1,2,4-Trimethylbenzene and 1,2,5-
Trimethylbenzene. These compounds factor into the results of the risk calculator, as is
discussed below.
Surface Water
Surface water is not located on the site.
Soil Gas
In October 2016, soil gas samples were collected at the only two locations at the site
where groundwater contaminants were detected in concentrations exceeding DWM's
Residential VISLs: soil gas sample MW 1 located next to groundwater sample MW 1 in
the northeast corner of the site with the sample point at 10 feet bgs; and soil gas sample
MW3 located next to groundwater sample MW3 in the south east corner of the property
with the sample point at 6 feet bgs. Soil gas samples were collected in accordance with
DWM soil gas sampling protocols and utilized laboratory -certified clean 1-Liter Summa
canisters over a half-hour sampling period. Soil gas samples were shipped to a North
Carolina -certified laboratory and were analyzed for volatile organic compounds using
EPA Method TO-15.
Analytical results of the soil gas samples indicated detections of petroleum compounds in
both MW1 and MW3 soil gas samples, but none of the detections were in concentrations
exceeding established DWM Residential Soil Gas Screening Levels (SGSLs).
Sub -Slab Vapor
Given the results of soil vapor sampling, no sub -slab vapor sampling was warranted for
or has been conducted at the site.
Indoor Air
Given the results of soil vapor sampling, no indoor air sampling was warranted for or has
been conducted at the site.
Risk Calculations
The DEQ Risk Calculator was developed to evaluate the risk of multiple contaminants
and multiple exposure routes associated with contaminated environmental media at a site.
The risk evaluation procedures, equations, and default parameters used to create the
calculator follow the current USEPA risk assessment guidance. The DEQ Risk Calculator
dated May 2019 was used to evaluate the following.
The Brownfields Property was evaluated as a whole utilizing the highest groundwater and
soil gas concentrations presented in the environmental reports.
Soil data was not included as risk calculator input parameters because >95% of the
property is covered by slab -on -grade construction, sidewalks, walkways and parking
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surfaces leaving almost no soil exposed at the site, and because most of the soil impacts
were removed during soil excavation activities conducted at the site.
The risk calculations indicated the following based on available data, including the
following media: groundwater and soil gas:
DIRECT
CONTACT SOIL AND
WATER CALCULATORS
Receptor
Pathway
Carcinogenic
Risk (LICR)
Hazard
Index (HI)
Risk
exceeded.
Soil
NC
NC
NC
Resident
Groundwater Use*
2.2E-03
5.3E+01
YES
Non -Residential
Soil
NC
NC
NC
Worker
Groundwater Use*
5.2E-04
1.2E+01
YES
Construction
Worker
Soil
NC
NC
NC
Recreator/
Soil
NC
NC
NC
Trespasser
Surface Water*
NC
NC
NC
VAPOR INTRUSION CALCULATORS
Receptor
Pathway
Carcinogenic
Risk (LICR)
Hazard
Index
Risk
exceeded.
Groundwater to Indoor Air
3.1E-04
5.5E+00
YES
Resident
Soil Gas to Indoor Air
7.9E-06
7.9E-02
NO
Indoor Air
NC
NC
NC
Groundwater to Indoor Air
7.0E-05
1.3E+00
YES
Non -Residential
Worker
Soil Gas to Indoor Air
6.0E-07
6.3E-03
NO
Indoor Air
NC
NC
NC
Red shading LICR> 1 E-04 or HI> 1.
LICR = Lifetime Incremental Cancer Risk
HI = Hazard Index
Groundwater use is restricted via the NORP recorded in 2016 and will be further
restricted via the land use restrictions in the Brownfields Agreement. The restrictions
included in the recorded NORP and the land use restrictions in the Brownfields
Agreement are not in conflict.
The risk of vapor intrusion from groundwater is above both the Carcinogenic Risk and
the Non -Carcinogenic Hazard Index in the risk calculations. However, the only
groundwater contaminants that are driving that calculated risk are Benzene and
Naphthalene, both of which were detected in relatively low concentrations and will
continue to degrade naturally. In addition, based on the October 2016 soil vapor
assessment results, soil vapor -to -indoor air calculated values are well below unacceptable
risk levels.
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Required Land Use Restrictions:
Based on the site -specific data provided to the Brownfield program, the Brownfields
Property is suitable for the uses approved in the BFA as long as the agreed upon land use
restrictions included therein are abided by:
- No child/adult care centers
- No groundwater use/exposure
- No soil disturbance except under an approved EMP
- No soil removed or brought onto the property without DEQ approval
- No building construction without VI consideration
- Demolition must take place in accordance with all legal requirements including
lead and asbestos
- No redevelopment without an approved EMP in place
- DEQ access to the property
- Deed notice requirement
- No use of known contaminants on the property
- LURU including rental language