20050_ Rite Aid_Phase I LSA_IAA_20090922

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B. Site History and Characterization
1. UST Owner and Operator Information:
UST ID Number 0-017072 Incident ID Number N/A
Name of Owner Dates of Ownership
Greif Bros. Corporation 1976-1978
Street Address
Unknown
City State Zip Telephone Number
Unknown
Name of Operator Dates of Operation
Greif Bros. Corporation 1976-1978
Street Address
Unknown
City State Zip Telephone Number
Unknown

3

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2. UST/AST Information:
UST ID
Number
Current/Last
Contents
Previous
Contents
Capacity
(gallons)
Construction
Details
Tank
Dimensions
Description of
Associated
Piping and Pumps
Date Tank
Installed
Status of
UST
Was release
associated
with the UST System?
UST-1 Fuel Oil None 10,000 Steel Unknown
Steel line from building to
former tank
basin
4/26/1976 Removed
1/12/1978 Yes

AST ID
Number
Current/Last
Contents
Previous
Contents
Capacity
(gallons)
Construction
Details
Tank
Dimensions
Description of
Associated
Piping and Pumps
Date Tank
Installed
Status of
AST
Was release
associated
with the
AST System?
None Water-Based Glue None known Unknown Steel Unknown Aboveground Unknown Empty No

4

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3. Non-UST spills at the site:
No non-UST spills are known to have occurred at the subject site.
4. Description of release: One 10,000-fuel oil UST was formerly located adjacent to the southeast side of
the site warehouse building. The location of the former UST is indicated in the
site plan in Figure 2. Environmental database information indicates that the
UST was owned by Greif Bros. Corporation, installed on April 26, 1978, and was removed on January 12, 1978.
In October 2008, as part of pre-purchase due diligence activities, H&H
advanced three soil borings in the area of the UST. Two soil borings (SB-11
and SB-12) were advanced in the former UST basin, and SB-13 was advanced along the product line. The locations of the former UST basin and product line were identified by having a private utility locator trace the existing vent line and
the product line from the sides of the building to the UST basin. The
approximate location of the former UST basin and the lines are indicated in
Figure 3. Soil samples from SB-11 and SB-12 were submitted for laboratory analysis of
diesel range total petroleum hydrocarbons (TPH-DRO) and gasoline range TPH
(TPH-GRO). No soil sample was submitted from SB-13 as there was no field
evidence of impact. The results of analysis of the soil sample from SB-12 (3-5 ft) indicated the presence of TPH-DRO at a concentration of 30 mg/kg which exceeds the North Carolina Department of Environment and Natural Resources
(DENR) UST Section action level of 10 mg/kg. TPH-GRO was not detected in
the sample from SB-12, and TPH-GRO and TPH-DRO were not detected in
sample SB-11 (8-10 ft). The soil analytical results are summarized in Table 1. Based on the results of the soil samples, H&H performed a Phase I Limited Site
Assessment (LSA) in November 2008. A summary of the Phase I LSA
activities is provided in Section F. In addition, based on the results of the Phase
I LSA, an Initial Abatement Action (IAA) was performed in January 2008 which included the removal of soil. A description of the IAA is provided in Section H.

5. Site characteristics:
The site consists of approximately 12.5 acres of commercial land located at 1701 and 1703 N. Graham St. in Charlotte, Mecklenburg County, North Carolina. A site location map is provided as Figure 1. Reportedly, the property
has been used for warehousing and manufacturing since the construction of the
building in the 1940s. Initially the building was used by the US Army for a
quartermaster depot and then for missile production from the 1950s to late 1960s when it was part of the Charlotte Army Missile Plant (CAMP). Most of the former CAMP is located west of the subject site. Following use by the

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army, Greif Bros. Corporation utilized the property for the manufacture of
corrugated containers. Currently, the northern portion of the building is used by
Custom Pallet for the manufacture and distribution of wooden paletts, and the
southern portion of the building is used by Pax Industries for the storage and distribution of plastic pellets.

The site is located in the Piedmont Physiographic Province of North Carolina.
In the site area, underlying bedrock is composed of granite and metamorphosed
quartz diorite. The land surface of the area is generally characterized as gently sloping, which may become moderately steep where intersected by streams.

In the Piedmont, the bedrock is overlain by a mantle of weathered rock termed
saprolite or residuum. The saprolite consists of unconsolidated clay, silt, and
sand with lesser amounts of rock fragments. Due to the range of parent rock types and their variable susceptibility to weathering, the saprolite ranges widely
in color, texture, and thickness. Generally, the saprolite is thickest near
interstream divides and thins toward streambeds. In profile, the saprolite
normally grades from clayey soils near the land surface to highly weathered
rock above the competent bedrock.
The occurrence and movement of ground water in the Piedmont is typically
within two separate but interconnected water-bearing zones. A shallow water-
bearing zone occurs within the saprolite, and a deeper water-bearing zone
occurs within the underlying bedrock.
Ground water in the shallow saprolite zone occurs in the interstitial pore spaces
between the grains comprising the saprolite soils. Ground water in this zone is
typically under water table or unconfined conditions. Ground water movement
is generally lateral from recharge areas to small streams that serve as localized discharge points.

The occurrence and movement of ground water in the underlying water-bearing
zone within the crystalline bedrock is controlled by secondary joints, fractures,
faults, and dikes within the bedrock. On a regional scale, the direction of ground water flow is typically from uplands to major streams and ground water
sinks. The saprolite has a higher porosity than the bedrock and serves as a
reservoir that supplies water to a network of fractures in the bedrock.

According to the United States Geological Survey (USGS) 7.5-minute Charlotte East, NC topographic quadrangle map dated 1967 (Figure 1), the site is located
at an approximate elevation of approximately 750 ft above mean sea level. The
site is located near a topographic high and the site topography is generally flat.
Area topography generally slopes to the northwest and southeast.
Based on the boring logs for soil borings advanced at the site, the soil in the area
of the former UST basin consists predominantly of reddish orange clayey silt.

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Ground water was encountered at approximately 21 ft below existing grade.
Boring logs and well construction records are provided in Appendix A.

6. Initial abatement actions, assessment activities, and corrective actions performed to date: A discussion of initial abatement actions is provided in Section H.

C. Site Check Report
Not applicable
D. UST Closure Report following UST-12 format and Site Investigation Report for Permanent Closure or Change in Service of UST (UST-2 Form).

1. Preparations for closure including the steps taken to notify authorities, permits obtained and the steps taken to clean and purge tanks: The UST was reportedly removed in 1978. No specific information is known
concerning the UST removal.

2. Closure Procedures: See D.1. above.

3. Note the amount of residual material pumped from the tank and describe the
storage, sampling and disposal of the residual material and the disposal of
the tank, pumps and piping: See D.1. above.

4. Initial response actions and initial abatement actions:
No initial response or abatement actions are known to have occurred when the
tanks were removed in 1978.
5. Soil excavation activities: No soil excavation was reported to have occurred when the tanks were removed
in 1978.
E. Free Product Investigation and Recovery Report No free product has been encountered in association with the USTs.

F. Phase I LSA Soil and Ground Water Investigation
Based on the results of the initial due diligence activities and in accordance with DENR guidance, H&H conducted Phase I Limited Site Assessment (LSA) soil
and ground water sampling at the site on November 7, 2008.

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The following soil borings were advanced as part of the Phase I LSA:

• Soil boring SB-12/TW-4 was advanced adjacent to previous soil boring SB-12, which was the tank basin soil boring with the highest TPH
concentration.

• Soil boring SB-13 was advanced along the former product line.
The locations of the LSA borings are depicted on Figure 3. The soil borings were
advanced with a direct push technology (DPT) rig. At SB-12/TW-4, soil and
ground water samples were collected for laboratory analysis. At SB-13, only a shallow soil sample was collected for analysis.
At SB-12/TW-4, soil samples were collected from 3-5 ft, 10-12 ft, and 17-19 ft
below ground surface. At SB-13, one shallow soil sample was collected from 3-5
ft below ground surface. The soil samples were collected in laboratory provided jars and placed in a chilled cooler with ice for transport under chain-of-custody to Test America, Inc. of Nashville, TN. The soil samples were analyzed for volatile
organic compounds (VOCs) by EPA Method 8260B, semi-VOCs (SVOCs) by
EPA Method 8270, and extractable petroleum hydrocarbons (EPH) and volatile
petroleum hydrocarbons (VPH) by the Massachusetts Department of Environmental Protection (MADEP) methods.
Boring SB-12 was advanced below the water table and completed as temporary
monitoring well TW-4. TW-4 was installed via DPT to a depth of approximately
35 ft and ground water was encountered at approximately 21 ft. The well was completed with one-inch diameter PVC with a 15-ft bottom section of screen. Well boring logs are provided in Appendix A.

The well was purged with a new polyethylene bailer until field parameters (pH,
specific conductivity, and temperature) were stable. Then, a ground water sample was collected into laboratory supplied containers and placed in a chilled cooler with ice for transport to Test America, Inc. of Nashville, TN under chain-of-
custody. The ground water sample was analyzed for VOCs by EPA Method
6210D, SVOCs by EPA Method 625, and EPH and VPH by the MADEP method.
Following sampling, the temporary monitor well was abandoned. The well abandonment record is provided in Appendix A.
The results of the Phase I LSA soil samples are summarized in Table 1, and the
analytical data sheets are provided in Appendix B. The results of the soil sample
analyses indicated that of the three soil samples collected from boring SB-12 for analysis, only the sample collected from SB-12 (3-5 ft) contained compound concentrations above DENR maximum soil contaminant concentrations
(MSCCs). In this sample, benzo(a)pyrene (0.551 mg/kg) was detected above its
residential and soil to ground water MSCC, and benzo(a)anthracene 0.660 mg/kg

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was detected above its soil to ground water MSCC. No compound concentrations
exceeded commercial/industrial MSCCs. No compounds were detected in sample
SB-13 (3-5 ft).
The results of the ground water analyses are summarized in Table 2, and the
laboratory analyses are provided in Appendix B. As indicated in Table 2, no
compounds were detected in the ground water sample.

Based on the presence of soil impacts above the residential MSCC in soil boring SB-12, and because the future use of the site could potentially include residences,
an Initial Abatement Action was conducted in January 2009. The IAA is
discussed in Section H.

G. Receptor Information and Risk Characterization As part of the Phase I LSA, H&H performed a site land use and risk
characterization survey. The LSA Risk Classification and Land Use Form is
provided in Appendix C. A discussion of potential receptors and land use is
provided below.
1. Water Supply Wells H&H conducted a water supply well survey for the area within a 1,500-ft radius
of the former UST basin. The survey was conducted by performing area
reconnaissance, checking for municipal water connections, and performing door-
to-door interviews with available property owners located within the survey area.
No water supply wells were identified within a 1,500-ft radius of the former UST
basin. Based on Charlotte-Mecklenburg Utilities records, municipal water is
provided to the site and is available to all properties within a 1,500-ft radius of the
site. In addition, H&H observed evidence of municipal water availability (i.e., water meters and fire hydrants) in the survey area. Available property
owners/occupants in the surrounding area confirmed that municipal water is used
in the site area. Water supply information survey forms for the surrounding
properties are provided in Appendix D.
2. Surface Water H&H conducted a survey for surface water bodies in the area. The closest surface
water body is an unnamed intermittent stream approximately 800 ft east of the
former UST system. Review of maps and site reconnaissance did not reveal any
additional surface water bodies near the subject site.
3. Subsurface Structures Visual observations were made for potential subsurface contamination conduits in
the immediate vicinity of the former UST. Based upon our review, there are no
anticipated subsurface contamination conduits of concern in the area of the former UST.

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4. Property Owners and Land Use
The site contains an approximate 170,000 square ft warehouse building that is
currently utilized by Pax Industries and Custom Pallets. The zoning of the site is I-2 (general industrial).

Surrounding properties are primarily zoned I-2, O-2 (office district), and B-1/B-2
(business). The closest residential area is located approximately 500 ft east of the
former UST system. Adjacent property owner information is presented in Table 3 and adjacent properties are shown on Figure 4.

5. Wellhead Protection Areas
Based on our review of the DENR Public Water Supply Section website (http://wse20.deh.ehnr.state.nc.us/swap_app/viewer.htm), the site is not located in
a wellhead protection area. According to the website, no wellhead protection
areas are located within Mecklenburg County.

6. Risk and Land Use Characterization Based upon the receptor survey results, as well as the soil and ground water
analytical data presented in this report, the site qualifies for a low risk
designation. In addition, based upon the industrial zoning of the site and
predominantly commercial properties in the surrounding area, the site qualifies
for a current commercial land use classification. However, it is possible that the site could be used for residential purposes in the future if the site is redeveloped.

H. Initial Abatement Activities
The results of the Phase I LSA indicated the presence of soil impacts above
residential MSCCs. Because the site may be used for residential purposes in the future, the current property owner MV Graham, LLC decided to remove soil
impacts above residential MSCCs in the UST basin.

On January 13, 2009, H&H directed the removal of approximately 53 tons of
petroleum-impacted soil from the former fuel oil UST basin. Evo Corporation of Winston-Salem, North Carolina performed the remedial excavation activities.
The soil was loaded directly into trucks for transport to the Evo facility in
Winston-Salem, North Carolina.

During excavation, the soil was screened for organic vapors using a photoionization detector to determine when adequate soil had been removed. The
final size of the excavation was approximately 18 ft long by 12 ft wide by 8 ft
deep. Figure 3 depicts the location and size of the remedial excavation. Soil
disposal manifests are included in Appendix E.
After the remedial excavation, confirmation soil samples were collected from the
excavation base (Base-1) and sidewalls (SW-1 through SW-4). The sidewall

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samples were collected from approximately 5-6 ft below grade, and the base
sample was collected at a depth of 8 ft. The approximate locations of the samples
are depicted on Figure 3.
The soil samples were collected using the trackhoe bucket, placed into laboratory-
supplied containers, and placed in a chilled cooler with ice for transport to Test
America, Inc. of Nashville, TN under chain-of-custody. The samples were
analyzed for VOCs by EPA Method 8260B, SVOCs by EPA Method 8270C, and
VPH and EPH by the MADEP methods.
Following soil removal, the excavation was backfilled to grade with clean fill
material. The backfill material was tamped with the track-hoe bucket to provide
compaction.
The results of the post-excavation soil sample analytical results are summarized in
Table 1, and the laboratory analyses are provided in Appendix B. As indicated in
Table 1, no compound concentrations were detected in the post-excavation soil
samples above MSCCs. Based upon the results of the post-excavation soil sample
data, impacted soil in the area of the former fuel oil UST has been adequately removed.

I. Conclusions
Results of a Phase II ESA indicated the presence of soil impacts in the basin
where a former fuel oil UST was located at the site. Based on the results of the Phase II ESA, H&H performed Phase I LSA and Initial Abatement Action
activities at the site.

Results of the Phase I LSA indicated the presence of compounds in soil in one
soil boring in the former UST basin that exceeded residential and soil to ground water MSCCs. No compound concentrations exceeded commercial/industrial
MSCCs. Results of the Phase I LSA ground water sampling indicated that no
compounds were detected in ground water below the former UST basin. The
results of the LSA receptor survey indicated no receptors in the area of the site
and that the site and surrounding area are zoned for industrial and commercial purposes. However, it is possible that future redevelopment of the site could
include residences.

Because compound concentrations in the former UST basin exceeded residential
MSCCs, H&H conducted an Initial Abatement Action. During the abatement action, approximately 53 tons of petroleum impacted soil were removed from the
area of the former UST basin. Results of analysis of post-excavation samples
indicated no compound concentrations above MSCCs. Based upon the results of
the post-excavation soil sample data, impacted soil in the area of the former fuel
oil UST has been adequately removed.

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Because post-excavation soil sample concentrations do not exceed MSCCs, and
there are no ground water impacts below the former UST, H&H recommends that
DENR issue a No Further Action (NFA) determination for the UST incident.

File: Tables 1 and 2, SOIL
Date: 9/30/2009
5030/
8015M
3550/
8015M
MADEP
VPH
MADEP
VPH
MADEP
EPH
MADEP
VPH/EPH
MADEP
EPH
MADEP
VPH
MADEP
EPH
MADEP
EPH/VPH 8260B 8270C 8270C 8270C 8270C 8270C 8270C 8270C 8270C 8270C
Sample ID
Date
Collected
Source
Area
Sample
Depth (ft)
Incident
Phase
SB-11 10/11/08 UST 8-10 DD <6.59 <7.08 NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA
SB-12 10/11/08 UST 3-5 DD <5.86 30.0 NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA
SB-12 11/07/08 UST 3-5 LSA NA NA <4.79 <4.79 <11.9 ND 35.8 <4.79 <11.9 ND 0.134 0.456 0.660 0.551 0.560 0.496 0.665 1.52 1.45 1.23
SB-12 11/07/08 UST 10-12 LSA NA NA <5.32 <5.32 <12.5 ND 63.4 <5.32 <12.5 ND 0.238 <0.436 <0.436 <0.436 <0.436 <0.436 <0.436 <0.436 <0.436 <0.436
SB-12 11/07/08 UST 17-19 LSA NA NA <6.29 <6.29 <14.3 ND <14.3 <6.29 <14.3 ND <0.0657 <0.488 <0.488 <0.488 <0.488 <0.488 <0.488 <0.488 <0.488 <0.488
SB-13 10/24/07 PL 3-5 LSA NA NA <5.18 <5.18 <12.3 ND <12.3 <5.18 <12.3 ND <0.0540 <0.440 <0.440 <0.440 <0.440 <0.440 <0.440 <0.440 <0.440 <0.440
SW-1 01/13/09 UST 5-6 IA NA NA <5.95 <5.95 <13.0 ND <13.0 <5.95 <13.0 ND 0.0767 <0.440 <0.440 <0.440 <0.440 <0.440 <0.440 <0.440 <0.440 <0.440
SW-2 01/13/09 UST 5-6 IA NA NA <5.44 <5.44 <12.8 ND <12.8 <5.44 <12.8 ND 0.0665 <0.422 <0.422 <0.422 <0.422 <0.422 <0.422 <0.422 <0.422 <0.422
SW-3 01/13/09 UST 5-6 IA NA NA <5.54 <5.54 <12.9 ND <12.9 <5.54 <12.9 ND <0.0513 <0.447 <0.447 <0.447 <0.447 <0.447 <0.447 <0.447 <0.447 <0.447
SW-4 01/13/09 UST 5-6 IA NA NA <4.52 <4.52 <10.7 ND <10.7 <4.52 <10.7 ND 0.0827 <0.366 <0.366 <0.366 <0.366 <0.366 <0.366 <0.366 <0.366 <0.366
BASE-1 01/13/09 UST 8 IA NA NA <5.79 <5.79 <13.3 ND <13.3 <5.79 <13.3 ND 0.132 <0.453 <0.453 <0.453 <0.453 <0.453 <0.453 <0.453 <0.453 <0.453
10 10 NS NS NS NS NS NS NS NS NS NS NS NS NS NS NS NS NS NS
NA NA 72 NS NS 3,300 Immobile NS NS 34 2.8 1,000 0.34 0.091 1.2 12 38 280 60 290
NA NA 939 NS NS 9,386 93,860 NS NS 469 1,564 4,600 0.88 0.088 0.88 9 88 620 469 469
NA NA 24,528 NS NS 245,280 >100%NS NS 12,264 40,880 122,000 8 0.78 8 78 780 16,400 12,264 12,264
Notes:
Apart from VPH and EPH, only those compounds detected are shown.
Bold indicates concentration exceeds Action Level or Soil to Groundwater MSCC
Yellow highlighting indicates that concentration exceeds the Residential MSCC
Be
n
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o
(
a
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Be
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(
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Be
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(
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Be
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(
k
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DD = Property Transfer Due Diligence; UST = Underground Storage Tank; PL = Product Line; LSA = Limited Site Assessment; IA = Initial Abatement; MADEP = Massachusetts
Department of Environmental Protection; VPH = Volatile Petroleum Hydrocarbon; EPH = Extractable Petroleum Hydrocarbon; NA = Not Analyzed; ND = Not Detected; NS = No
Standard; mg/kg = milligrams per kilograms; TPH = Total Petroleum Hydrocarbons; DRO = Diesel Range Organics; GRO = Gasoline Range Organics; MSCC = Maximum Soil
EP
H

C
1
9
-
C
3
6

Al
i
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a
t
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c
s

VP
H

C
9
-
C
1
0

A
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VP
H

C
9
-
C
1
2

A
l
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a
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s

VP
H

C
5
-
C
8

A
l
i
p
h
a
t
i
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s

Industrial/Commercial MSCC (mg/kg)
EP
H

C
1
1
-
C
2
2

Ar
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m
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s

To
t
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C
9
-
C
2
2

A
r
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s
Residential MSCC (mg/kg)
TP
H
-
D
R
O

(
m
g
/
k
g
)
Analytical Method
Ac
e
t
o
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e
Action Level (mg/kg)
Soil to Ground Water MSCC (mg/kg)
EP
H

C
9
-
C
1
8

A
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t
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s

To
t
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C
9
-
C
1
8

A
l
i
p
h
a
t
i
c
s
Contaminant of Concern
TP
H
-
G
R
O

(
m
g
/
k
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)
An
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h
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a
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Fl
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a
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Py
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Table 1
Summary of Soil Sample Analytical Results
Warehouse Property
Charlotte, North Carolina
H&H Job No. VBG-002
1701 N. Graham Street
Ch
r
y
s
e
n
e
File: Tables 1 and 2, GW
Date: 9/30/2009
MADEP
VPH
MADEP
VPH
MADEP
EPH
MADEP
VPH/EPH
MADEP
EPH
MADEP
VPH
MADEP
EPH
MADEP
VPH/EPH 6210D 625
Sample ID
Date
Collected
Incident
Phase
TW-4 11/07/08 LSA <100 <100 <100 ND <100 <100 <100 ND
420 NS NS 4,200 42,000 NS NS 210
NS NS NS NS NS NS NS NS
Notes:
Apart from VPH and EPH, only those compounds detected are shown.
2L Standard = NCAC 2L ground water quality standard;
GCL (µg/l)
Contaminant of Concern
2L Standard (µg/l)
EP
H

C
1
1
-
C
2
2

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To
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C
2
2

A
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Al
l

N
D
Table 2
Summary of Ground Water Sample Analytical Results
Warehouse Property
Charlotte, North Carolina
1701 N. Graham St.
MADEP = Massachusetts Department of Environmental Protection; VPH = Volatile Petroleum Hydrocarbon; EPH = Extractable Petroleum Hydrocarbon;
NS = No Standard; ND = Not Detected; GCL = Gross Contaminant Level
Al
l

N
D
Analytical Method
H&H Job No. VBG-002
EP
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9
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To
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1
8

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EP
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1
9
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C
3
6

A
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VP
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C
9
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C
1
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VP
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i
c
s

VP
H

C
5
-
C
8

A
l
i
p
h
a
t
i
c
s

TITLE
PROJECT
SITE LOCATION MAP
WAREHOUSE PROPERTY
CHARLOTTE, NORTH CAROLINA
DATE:
JOB NO:
REVISION NO:
FIGURE NO:
11-20-08 0
1VBG-002
0 2000 4000
APPROXIMATE
SCALE IN FEETN
U.S.G.S. QUADRANGLE MAP
QUADRANGLE
7.5 MINUTE SERIES (TOPOGRAPHIC)
CHARLOTTE, NC 1967 (Photo-revised 1988)
SITE
TITLE
PROJECT
ADJACENT PROPERTY MAP
WAREHOUSE PROPERTY
CHARLOTTE, NORTH CAROLINA
DATE:
JOB NO:
REVISION NO:
FIGURE NO:
8-7-09 0
4VBG-002
A
B
C
D
E
F
G
H
I
JK
L
M
NOP
Q
R
A
Notes:
Information based on Mecklenburg County
GIS database; adjacent property information
is presented in Table 3.
SUBJECT PROPERTY BOUNDARY
ADJACENT PROPERTY MAP ID
FORMER UST LOCATION
0 450 900
APPROXIMATE
SCALE IN FEETN
500’ RADIUS