16041_Flem_Labs EAP_2013_10

Via E-Mail
October 23, 2013
NC DENR Brownfields Section
Division of Waste Management
1646 Mail Service Center
Raleigh, NC 27699-1646
Attention: Mr. Tony Duque
Brownfields Project Manager

Re: Environmental Action Plan - Final
Fleming Laboratories Charlotte, North Carolina
Brownfields Project #16041-12-060
H&H Project No. FMG-001
Dear Tony:

On behalf of Fleming Laboratories, Hart & Hickman, PC is providing the attached
Environmental Action Plan for a Ready for Re-use project in Charlotte, Mecklenburg County,
North Carolina. As we discussed, H&H increased the sampling requirements for each borrow fill source to be a minimum of two samples. Should you have any questions or need additional
information, please do not hesitate to contact me at [phone].

Sincerely,
Hart & Hickman, PC
Matt Bramblett, PE
Principal
Attachment
cc: Mr. George Fleming, Fleming Labs (via email and 2 copies via US Mail)
Ms. Amanda Short, HMW (via email)

Environmental Action Plan
Fleming Laboratories
Brownfields Project No. 16041-12-060

2205, 2009, and 2215 Thrift Road
Charlotte, North Carolina

H&H Job No. FMG-001
October 23, 2013

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Environmental Action Plan Fleming Laboratories
2205, 2209, and 2215 Thrift Road
Charlotte, North Carolina H&H Job No. FMG-001 Table of Contents

Section Page
1.0 Introduction & Intent .............................................................................................................1
2.0 Environmental Action Objectives .........................................................................................3
3.0 Site Conditions ........................................................................................................................4
3.1 Historical Site Operations .................................................................................................4
3.2 Nature of Suspected Environmental Conditions ...............................................................4
3.3 Summary of Redevelopment Considerations ....................................................................7
4.0 Brownfields Screening Levels ..............................................................................................10
4.1 Screening Levels for Soil ................................................................................................10
4.2 Screening Levels for Groundwater .................................................................................10
4.3 Underground Storage Tanks (USTs) ...............................................................................10
5.0 Proposed Environmental Actions ........................................................................................11
5.1 General Actions ...............................................................................................................11
5.2 Management of Building Materials.................................................................................12
5.3 Underground Utilities ......................................................................................................13
5.4 Discovery of Potential Environmental Conditions..........................................................13
5.5 Water Management .........................................................................................................15
5.6 Imported Fill ....................................................................................................................16
5.7 Dust Control ....................................................................................................................16
5.8 TCLP Hazardous Soil Management ................................................................................16
5.9 Movement of Impacted Soil to Basement .......................................................................18
5.10 Post Construction Requirements .....................................................................................18
6.0 Project Contacts ....................................................................................................................19

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List of Figures
Figure 1 Site Location Map
Figure 2 Vicinity Map
Figure 3 Site Map
Figure 4 Shallow Soil Arsenic Concentration Map
Figure 5 Highest Detected Soil Arsenic Concentration Map

List of Appendices
Appendix A Arsenic Assessment Reports
Appendix B Health and Safety Plan

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Environmental Action Plan Fleming Laboratories
2205, 2209, and 2215 Thrift Road
Charlotte, North Carolina H&H Job No. FMG-001
1.0 Introduction & Intent

This Environmental Action Plan (EAP) presents actions for the redevelopment of the former
Fleming Laboratories (Fleming) properties located at 2205, 2209, and 2215 Thrift Road in
Charlotte, North Carolina. A site location map is included as Figure 1. A map identifying the
site parcels and surrounding properties is included as Figure 2. The properties subject to this
EAP will be parcels 07105112 (2205 and 2209 Thrift Road) and 07105113 (2215 Thrift Road).
These properties total approximately 1.57-acres and will be redeveloped using the
North Carolina Department of Environment and Natural Resources (DENR) Ready for
Reuse Brownfield Program. The Brownfields Program project number is 16041-12-060. As
such, a prospective developer has yet to be identified. However, the property owner is planning
the demolition and grading of the parcel at 2205 and 2209 Thrift Road in order to create a
parking lot or equipment laydown/storage area with select landscaped areas to improve the
property for sale. For ease of reference, the area to be graded and improved is often referred to
as simply a parking lot herein. A site map showing the current layout of this parcel is included
as Figure 3.

The intent of this EAP, in combination with the appended Health & Safety Plan (HSP), is to
identify measures to be taken to reduce potential contaminant exposure for site workers during
redevelopment activities, including the currently proposed parking lot construction, and to
describe features to be incorporated into the site which are protective of future site users,
occupants, and workers after redevelopment is completed. It is assumed the actions described in
this EAP will be completed under a Draft North Carolina Department of Environment and
Natural Resources (DENR) Brownfield Agreement by the current property owner,
Fleming Laboratories, Inc.

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This EAP is considered a living document and can be amended if needed should conditions arise
that were not anticipated. However, it is anticipated that this EAP can adequately address most
issues in relation to potential contamination that may be encountered during site redevelopment
activities.

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2.0 Environmental Action Objectives
As part of the Brownfield Agreement to be prepared for the Fleming Laboratories property, it is
envisioned that land use will be restricted to commercial or industrial use, and groundwater use
will be prohibited. Actions described in this plan account for a range of site conditions that may
arise during redevelopment and may be modified by Fleming Laboratories and DENR as the
project progresses to accommodate the final site design and field conditions. Currently, the
redevelopment plans for the parcel at 2205 and 2209 Thrift Road include the demolition of site
buildings, grading of the property, and creating a parking lot/outside storage area. The
northeastern and southeastern sides of the property will be landscaped, and a fence will be
installed at an approximately 25 ft setback from the property boundary.

Actions described in this Plan are intended to redevelop the Fleming Laboratories property in a
way to mitigate exposure to future site users and site construction/utility workers including:

• Exposure to contaminated soil - dermal contact, ingestion, or inhalation of contaminated
dust from arsenic impacted soil

• Exposure to contaminated building materials (i.e. concrete building foundations/slabs) -
dermal contact, ingestion, or inhalation of contaminated dust from arsenic impacted
building materials

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3.0 Site Conditions
3.1 Historical Site Operations

Fleming Laboratories commenced operations in 1956 as a manufacturer of bulk drugs for both
the human and animal pharmaceutical markets. All of Fleming’s production activities
(manufacturing areas, warehousing, offices, etc.) were conducted at the plant site with the
address range of 2205 to 2215 Thrift Road. This EAP is applicable to the entire site with certain
specificity to parcel 07105112 (2205 and 2209 Thrift Road). This is the parcel proposed to be
redeveloped at this time. Currently, the buildings on the 2205 and 2209 Thrift Road parcel are
vacant, and the 2215 Thrift building is actively used for animal health product formulation and
packaging.

Among the products that Fleming has produced over the years, an important one for the company
was arsanilic acid (“AA”). AA is an organic form of arsenic that has been used in animal feeds
in the United States since the 1940s to improve the growth and health of chickens, turkeys, and
swine. While AA is an organic form of arsenic, AA was made from arsenic acid (80%), an
inorganic form of arsenic.

During the years of making AA, arsenic-containing compounds were spilled at the site with
spills in 1984 and 1999, as described below. These spills were either of arsenic acid (80%) or of
aqueous in-process solutions associated with the AA production. These process solutions
contained AA, arsenic acid, or a combination of both. Both of these spills occurred on the
2205 and 2209 Thrift Road parcel.

3.2 Nature of Suspected Environmental Conditions

The property has undergone several assessments and some limited remediation since the 1980s,
predominately in response to identified releases at the site. Based on the known releases at
2205 and 2209 Thrift Road and the proposed redevelopment of that parcel, H&H began to
investigate the current arsenic concentrations at the 2205 and 2209 Thrift Road property in 2011.

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A summary of the site’s environmental history is provided below. Based on this information, the
primary contaminant of concern at the site is arsenic.

1984 Arsenic Acid Release
When unloading a tank truck of arsenic acid (80%) at the Fleming site on November 14, 1984, a
faulty unloading valve failed on the delivery tank trailer resulting in the loss of an estimated
5 gallons at the location identified in Figure 3. The spill was mostly on the asphalt parking lot
where the unloading took place. In addition to the pavement, the exterior walls and a shrub
landscape area were impacted. Absorbent material was immediately deployed. The absorbent
material and surface soil was contained in 55-gallon drums for off-site disposal.

In 1992, National Environmental Technologies (NET) collected 107 soil samples from the 1984
release area to assess the extent of arsenic impacts. In August and September 1993,
approximately 121 tons of arsenic-impacted soil and asphalt were excavated for off-site disposal.
Following confirmatory sampling, the site was deemed adequately remediated by the oversight
contractor based on an arsenic cleanup standard of 63 mg/kg. The published default current
DENR cleanup standards for arsenic are below this value.

Hazardous Substance USTs Removed in 1990
Four former hazardous substance USTs were previously located on the southern side of the
subject property. The tanks contained organic compounds including aniline, methanol, and
xylenes. The tanks were removed in April 1990. Following UST removal, soil and groundwater
impacts were identified beneath and downgradient of the USTs. Impacts associated with those
former USTs will not be disturbed by site redevelopment plans.

1999 AA Release
On February 19, 1999, approximately 1,000 gallons of an AA in-process solution (arsanilic acid
rinsate) was released due to operator error (see Figure 3). The released solution affected soil
beneath a nearby wooden platform and in the drainage area between buildings C and D. In
March, April, and May of 1999, S&ME collected 63 soil samples to assess areas potentially
affected by the release, but no remediation was conducted for those soils.

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H&H Environmental Assessment
During sampling events conducted in November 2011 and March 2012, H&H assessed soil and
building floors at Fleming Laboratories for arsenic using XRF and laboratory analytical methods.
A copy of the text, tables, and figures of this assessment report is included in Appendix A.

Soil borings were installed near the 1984 spill area, 1999 spill area, adjacent to a former arsanilic
acid aboveground storage tank (AST), adjacent to a former arsenic acid AST, and at other areas
across the 2205 and 2209 Thrift Road Parcel. H&H installed 51 soil borings using direct push
technology (DPT) or a decontaminated stainless steel hand auger. A brief summary of the results
is as follows:

• Widespread elevated arsenic was detected in soils at the subject property. There are a
few areas of soil that appear to be free from arsenic contamination including the northeast
portion of Building B and northeast portion of the 2205 and 2209 Thrift Road parcel.

• The arsenic impacted soil extends to depths up to 24 ft, which is near the water table.

• The areas of highest arsenic impact are associated with a former arsanilic acid AST,
arsenic acid AST, and 1999 arsanilic acid spill. Detected arsenic concentrations ranged
up to 22,100 mg/kg.

• Site-specific naturally occurring arsenic concentrations were evaluated by collecting
10 samples in the upgradient portion of the adjacent 2215 Thrift Road property.
Naturally occurring arsenic concentrations ranged from <0.62 mg/kg to 2.9 mg/kg based
on laboratory results. According to Elements in North American Soils, arsenic
concentrations in North Carolina range from 1 to 18 mg/kg.

Prior to sampling the building floors, they were dry vacuumed using HEPA filters by an
environmental contractor. Following the dry dust vacuuming, composite floor samples were
collected from the floor in each of the buildings to characterize the material for disposal if plans

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to demolish the buildings were to be carried out. It is assumed that the building floors are
locations where there is a potential for elevated arsenic from liquid spills or entrapped dust. A
brief summary of the results is as follows:

• The composite building floor samples contained RCRA metals. However, arsenic was the
only metal that was detected at definitively elevated concentrations. The initial composite
samples collected from Building C (lower level) and Building D contained TCLP arsenic at
concentrations of 9.7 mg/L and 22 mg/L. Based on these results, a more thorough building
floor assessment was conducted in October 2012. During the more thorough sampling event,
a plan was implemented to obtain more accurate composite samples. Based on these results,
the lower level floor of Building C does not contain arsenic levels above the hazardous waste
characteristic level when sampled using the more representative compositing method.
Portions of the upper level floor of Building C and the floor of Building D contain TCLP
arsenic (up to 20 mg/l) above the hazardous waste characteristic level of 5 mg/l.
Approximately 50% of the upper floor of Building C and approximately 75% of the floor in
Building D will be hazardous waste upon demolition based on TCLP arsenic results
(Appendix A).

3.3 Summary of Redevelopment Considerations

The following specific redevelopment considerations are based on the premise that the 2205 and
2209 Thrift property will be converted to a parking lot as its end use, and that the use of
2215 Thrift will remain industrial. The property uses will likely include parking, outside
equipment laydown, and/or outside material storage. In order to complete the proposed end use,
Buildings B, C, D, and E will need to be demolished, and areas of the property which are built up
will require grading to create a level surface. The built up areas of soil may contain elevated
levels of arsenic and will need to be appropriately managed. Previous assessment findings
indicate the following conditions pertinent to the soil management activities and redevelopment
at the property:

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• Elevated arsenic concentrations (considered to be soils with detectable arsenic using a
field XRF instrument with a detection limit of 5 mg/kg or lower) are present across the
site (Figure 4), with the exception of the portions beneath Building B and northern
portions of Building E. The elevated concentrations of arsenic in soil may pose
ingestion, dermal contact, or dust inhalation concerns for construction workers during
redevelopment activities. Appropriate worker safety and work zone demarcation
measures should be taken to mitigate worker contact with contaminated soils.

• Areas of significant soil impact (arsenic concentrations exceeding 1,000 mg/kg) have
been identified in three distinct areas of the site (Figure 5). These areas in particular may
pose ingestion, dermal contact, or a dust inhalation concern for construction workers
during redevelopment activities.

o The first area, located in the south-central portion of the site, appears to be related
to the location of a 1999 arsanilic acid process solution release and/or a former
AST storage area.
o The second area, located on the western border of the property, appears to be
related to a former arsanilic acid AST. This area of impact abuts the wall of the
basement associated with Building C.
o The third area, located on the northwestern corner of the 2205 to
2209 Thrift Road parcel, appears to be related to a former arsenic acid AST.

• As groundwater is estimated to occur at a depth of 20 ft or greater below ground surface,
it is not expected that construction workers or future site users will encounter
groundwater during redevelopment activities.

• Four former hazardous substance USTs were previously located on the southern side of
the subject property. The tanks contained organic compounds including aniline,
methanol, and xylenes. Impacts associated with those former USTs will not be disturbed
by site redevelopment plans.

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• One existing UST is present beneath a covered wood platform on the southeastern side of
Building E. This UST is suspected to have previously contained heating oil and is likely
a relatively small UST (estimated at 500-gallons). This UST will be closed in place. If
other USTs are encountered during redevelopment, they will be properly managed.

• By virtue of the presence of environmental impacts at the property, work conducted
within areas of known impacts should take into consideration the health and safety
precautions necessary for safe execution of excavation activities. The chosen contractor
will be required to us Hazwoper trained workers (per 29 CFR 1910.120) and to provide a
Health & Safety Plan to inform and ensure the safety of workers in areas of potential
impacts. A Health and Safety Plan, similar to what will be used by the environmental
consultant overseeing the work, is provided in Appendix B.

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4.0 Brownfields Screening Levels
4.1 Screening Levels for Soil

In general, the Brownfields screening levels for soil will be the NC DENR Inactive Hazardous
Sites Branch Preliminary Industrial Health-Based Soil Remediation Goals (SRGs). Actions will
be taken to mitigate the potential for exposure to impacts above industrial SRGs during and
following redevelopment. Metal concentrations detected in soil samples will also be compared
to published naturally-occurring values and/or site-specific background values.

4.2 Screening Levels for Groundwater
If suspected contaminated groundwater is encountered during redevelopment activities that
requires contact with or removal, samples will be collected and compared to North Carolina
Administrative Code 2L groundwater standards. If the water is impacted, it will be properly
managed. As mentioned previously, the depth to groundwater is over 20 ft, and no groundwater
is expected to be encountered during redevelopment activities.

Municipal water is available in the site area, and groundwater is not proposed to be utilized in the
future. Accordingly, environmental action is not specified for groundwater beyond restrictions
on the use of groundwater at the site.

4.3 Underground Storage Tanks (USTs)

Petroleum USTs identified at the site during redevelopment activities, if any, will be addressed
using the DENR UST Section guidance because such USTs are not covered under the
Brownfield Program. The screening levels for petroleum USTs will be based on the UST
Section guidance.

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5.0 Proposed Environmental Actions
Redevelopment of the Fleming Laboratory property will include demolition of selected site
buildings and foundations; grading work to achieve the desired final grade; and construction of a
parking lot with surrounding landscaping and fence. Although most of the grading work will use
imported fill, it is likely that impacted soil will be encountered during these redevelopment
activities. The criteria noted below will be used to direct environmental actions.

5.1 General Actions

1. Land use will be restricted to commercial and/or industrial use.

2. Corrective actions will ensure there is a barrier between future site occupants/workers and
soil that remains in place at concentrations above the health-based industrial screening levels
(Section 4.1). The barrier may be (a) building; paving; hardscape surface; polyethylene or
other liner (i.e. Geotextile Fabric Barrier) and one ft of clean soil; or (b) a minimum of 2 ft of
clean soil or landscaping materials.

3. In preparing the site grading plan and performing site grading or construction activities, the
following will be considered:
a) If soil at the site is contaminated above the corresponding screening level and can be
left in place, it will be covered as described in Item #2 above.
b) With DENR’s approval of this EAP, contaminated soil above the corresponding
screening level can be moved to an alternate on-site location provided the soil is
placed under a barrier as described in Item #2 above. Existing data or supplemental
analyses will be used to confirm the soil to be moved does not qualify as
characteristically hazardous waste. Details regarding anticipated movement of soil
into the lower level of Building C are described further in Section 5.9.
c) If soil from an impacted area must be transported off-site, it will be profiled based on
existing site data and other analyses as may be required by the disposal facility, and
transported to a permitted disposal facility.

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4. If a sub-grade feature or pit is encountered during redevelopment and does not require
removal for geotechnical or construction purposes, it will be filled with soil or suitable fill
and construction will proceed. Where appropriate, the bottom may be penetrated before
back filling to prevent fluid accumulation. If the pit has waste in it, the waste will be set
aside in a secure area and characterized for off-site disposal at a permitted disposal facility.
If the pit must be removed and the observed waste characteristics indicate the concrete may
potentially be contaminated to a significant degree, the concrete will be sampled and
analyzed by methods specified by the disposal facility.

5. If buried piping is encountered and must be removed to allow redevelopment to proceed, the
contractor will inspect the pipe for fluids, collect and sample fluids where appropriate, and
look for signs of a release using field methods. If a release is suspected, DENR will be
contacted to discuss the appropriate course of action.

6. In the event that impacted soil encountered during construction activities, the excavation will
proceed only as far as needed to facilitate the necessary grading and construction activities.

7. Dust generation will be monitored visually during construction and if observed, dust control
measures such as wetting the soils will be implemented. In addition, dust monitoring with a
hand held dust meter will conducted. Dust control is discussed further in Section 5.7.

5.2 Management of Building Materials

As noted previously, some of the floors (wooden and/or concrete) at the site have been identified
as containing arsenic at levels that could qualify them as characteristically hazardous waste.
Building materials found to be characteristically hazardous waste will be appropriately profiled
and disposed off-site at a RCRA permitted facility.

Demolition debris that is not characteristically hazardous waste will be segregated as needed;
disposed or recycled at an approved facility; or reused on site if it qualifies as beneficial fill in
accordance with DENR Solid Waste regulations.

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Potentially contaminated dirt will be shaken off of land clearing debris, including building
foundations and footers, to the degree practical using conventional earth moving equipment.

Asbestos and other regulated building materials will be managed in accordance with regulations.

5.3 Underground Utilities

Current redevelopment activities include the demolition of site buildings and grading of the
2205 and 2209 Thrift Road parcel. As the future use of this parcel is a parking lot, most utility
lines to the property will be appropriately disconnected and capped at the street as needed. The
parking lot may include light poles, which could require the installation of new electrical lines.
Management of utilities may also be necessary during grading or demolition activities.

If a new release is identified during utility work, it will be managed as discussed in Section 5.4.
In the event that new buried utility lines (water, natural gas, electrical), stormwater drainage
lines, sanitary sewer lines, roof drains, and other constructed subsurface features are installed in
areas of contaminated soil, the utility trenches will be backfilled with clean fill or excavated
material generated during construction of the utility trench. By electing to backfill the trench
excavations with clean fill, the prospective developer will eliminate the need for notification
during post-development utility work in these trenches. Should the excavated material be placed
back into the trench, post-development utility work will require DENR notification and approval.

5.4 Discovery of Potential Environmental Conditions

The following steps will be taken to identify and manage potential environmental conditions
discovered during site redevelopment which have not been previously characterized.

1. During soil movement at the site, the workers or contractors will observe soils for
changes that make the soil unlike surrounding material. Evidence of potential
environmental impacts could include a change in color, change in odor, or observance of
filled or previously disposed material (i.e. scrap metal, chemicals, drums etc.). Should
any of the above be noted during site work for soil not previously characterized, the soils

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or previously disposed materials would be preliminarily screened using appropriate field
screening methods based on the suspected type of impact (i.e., using a photoionization
detector or field XRF). If evidence of impact is observed using these preliminary
screening methods, samples for laboratory analysis will be collected as needed.

2. If contamination is discovered at the site during redevelopment that is not similar in
nature to impacts identified during initial assessment activities, Fleming Laboratories will
contact DENR to discuss the appropriate course of action. Such soil may be stockpiled in
a secure area on plastic sheeting and covered while awaiting characterization. A
composite sample from the stockpiles may be required for every 500 cubic yards.
Stockpiles will be covered with plastic sheeting, configured to minimize contact with
surface flow, and stored in a manner to prevent erosion.

3. Based on the planned industrial re-use of the site and covering of impacted soil per
Section 5.1, Item #2, no confirmation samples will be collected from excavated areas.

4. If a release newly identified during construction indicates volatile constituents may be
present in soil or groundwater that may pose indoor air concerns, DENR will be notified.
As the proposed re-use of the 2205 and 2209 Thrift Road parcel is for a parking lot, the
potential for vapor intrusion is absent. However, should the proposed reuse include an
occupied structure, a vapor intrusion evaluation will be conducted. If corrective action
for vapor intrusion is determined to be necessary, solutions may involve moving the soil
away from the proposed building, installing passive vapor barrier and/or active
ventilation systems consistent with building code requirements, modifying the building
design, or modifying the site layout.

5. If a petroleum underground storage tank (UST) is discovered during redevelopment, it
will be discussed and addressed per DENR UST guidance.

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5.5 Water Management
Groundwater is estimated to be 20 or more ft bgs and is unlikely to be encountered during
redevelopment activities. However, it is possible that stormwater will be encountered during the
redevelopment project. The following describes how water will be managed during site grading
activities.

1. Excavations will be bermed or covered to minimize run-off in the event of substantial
rainfall. If surface water run-off or groundwater accumulates in an excavation within an
area of known soil impacts, appropriate worker safety measures will be undertaken. The
accumulated run-off will be allowed to infiltrate/evaporate, tested, and used for dust
control in areas of known contamination if it is determined to be non-hazardous.
Alternatively, the water may be tested and disposed off-site at a permitted facility.

2. In the event that impacted soil and/or water within an excavation cannot be dried
adequately for construction purposes using the methods described above, the soil may be
amended, covered, or replaced with clean soil, aggregate, drying agents, and/or
stabilizing agents to achieve the desired geotechnical qualities. The removed wet soil
will be managed in one of the following ways:
a. Allowed to remain in place with an appropriate cover as described in Section 5.1.
b. Moved to an appropriate on-site location to be covered as discussed in
Sections 5.1 and 5.8.
c. Characterized and removed for off-site disposal at a permitted facility.

3. It is likely that silt fencing will be utilized for sediment and erosion control during
grading activities. Should sediment from the site accumulate at these barriers, the
sediment will be removed and stockpiled. This sediment will be managed as described in
Item #2 above.

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5.6 Imported Fill
Imported fill may be required to achieve desired grades. Such fill will be obtained from a
reputable source. As noted below in Section 5.10, should imported fill be a final site cover per
redevelopment plans, at least two samples of the fill material from each separate borrow source
will be tested for VOCs, semi-VOCs, and Hazardous Substance List (HSL) metals in lieu of
conducting post redevelopment soil sampling at the property.

5.7 Dust Control

Preventing exposure to airborne contaminants is of primary concern during site activities. As
such, H&H and the selected contractors shall take precautions to reduce the airborne exposure
potential to site contaminants for both on-site personnel and the public. This will be
accomplished by using the dust control measures described below.

Dust will be controlled by keeping site access roads and active work areas damp and by watering
or misting as necessary prior to and during foundation removal and soil movement activities. As
such, a water truck and/or appropriate water misting equipment will be available if needed at the
site during those work activities that may produce dust. In addition, the subcontractor may
utilize polyethylene sheeting to protect exposed soils and mitigate the potential for dust.

If operations generate sustained visible dust at levels exceeding those specified in the HASP
(Appendix B), site workers will don full-face respirators and re-apply a water mist to reduce dust
generation. If the mist is not effective in reducing dust generation, work will stop until the
conditions abate or appropriate additional protective procedures are established.

5.8 TCLP Hazardous Soil Management

Prior to grading activities, soils to be graded and identified as characteristically hazardous waste
by TCLP will be excavated and treated to remove the characteristic, or removed/disposed at a
permitted hazardous waste disposal facility. During 2011 assessment activities, the TCLP
sample collected from HH-SB-20 (0-0.5 ft) was found to contain concentrations of arsenic at

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37 mg/L, an exceedance of the hazardous waste characteristic threshold of 5 mg/L. In addition,
the soil is built up near sample location HH-SB-20. Therefore, the area around this sample is
proposed for excavation. The area proposed to be excavated includes an approximate 28 ft by
12 ft area to the estimated cut depth of approximately 4 ft below existing grade (figure 5). The
final depth will be consistent with grading plans, but also allowing space for a barrier described
in Section 5.1, Item #2.

This soil may be stabilized on-site to reduce leaching with EnviroBlend or equivalent to render
the soil non-hazardous. Consistent with DENR Division of Waste Management procedures, a
composite sample of the treated soil will be tested using the Multiple Extraction Procedure
(MEP) to confirm that it is non-hazardous. If a total of five extractions do not indicate leaching
above the hazardous waste threshold, the soil will be considered to be non-hazardous. After
confirmation of treatment, the soil will be reused on-site as impacted fill soil, or it will be
disposed off-site at a permitted facility.

Before moving soil adjacent to the excavation surrounding boring HH-SB-20, confirmation
sampling will be conducted to demonstrate the soils remaining in the vicinity of the excavation
are non-hazardous. It is anticipated that composite samples will be collected from each sidewall
and the base of the excavation. The confirmation samples will be analyzed for TCLP arsenic by
a certified environmental laboratory.

In the event soil excavated from other areas of the site cannot be placed back on-site at an
approved location, the soil may need to be removed from the site. In this case, the soils will be
profiled based on information obtained during the assessment activities and with additional
sampling as may be required by the disposal facility. Impacted soils that are removed from the
site will be disposed at a permitted facility.

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5.9 Movement of Impacted Soil to Basement
Based on current grading plans, it is important that soils beneath Building B that are impacted
above applicable screening criteria (Section 4.1, Industrial SRGs), be allowed to be placed within
the lower level of Building C after removal of the concrete floor and foundations. Soil under
Building B is built up above surrounding grade. The lower level or basement area of Building C
is approximately 6 ft below grade, and will need to be filled to grade prior to completing
redevelopment as a parking lot. Based on cut and fill calculations, the impacted built up soil
beneath Building B to be cut will fit into the void left after demolition of the basement of
Building C. Grading in the area of Building B will be completed to a depth consistent with
grading plans, but also allowing space for a barrier as described in Section 5.1. Because the
areas of Buildings B and C, along with the rest of the 2205 to 2209 Thrift Road parcel, are
proposed to be covered as described in Section 5.1, Item #2, no confirmation soil sampling is
proposed other than that described in Section 5.8.

5.10 Post Construction Requirements

To minimize post construction sampling requirements, backfill from off-site will be analyzed
prior to placement on the subject site as discussed in Section 5.6. It is anticipated that no impacts
will be present on the imported fill. However, as long as no constituents in the backfill exceed
industrial SRGs, then areas covered by this clean backfill will not be subject to post construction
sampling and analysis.

Fleming Laboratories will prepare a brief post-development report which documents actions
taken during site redevelopment. The report will document soil grading activities, sampling
activities, and management of impacted soils and regulated building materials. Areas where
impacted soil was reused and areas where impacted soil was left in place will be depicted on a
site map.

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6.0 Project Contacts
Mr. George Fleming Fleming Laboratories, Inc. 2215 Thrift Rd.
Charlotte, NC 28208
[phone]
[e-mail] Mr. Tony Duque NC Brownfields Program
1646 Mail Service Center
Raleigh, NC 27699-1646 [phone] [e-mail]

Mr. Matt Bramblett, PE
Hart & Hickman, PC 2923 South Tryon Street Suite 100
Charlotte, NC 28203
[phone]
[e-mail]
SITE
0 2000 4000
APPROXIMATE
SCALE IN FEET
N
U.S.G.S. QUADRANGLE MAPS
QUADRANGLE
7.5 MINUTE SERIES (TOPOGRAPHIC)
TITLE
PROJECT
SITE LOCATION MAP
FLEMING LABORATORIES CHARLOTTE, NORTH CAROLINA
DATE:
JOB NO:
REVISION NO:
FIGURE:
8-30-12 0
1 FMG-001
Charlotte East, North Carolina, 1988

S:\AAA-Master Projects\Fleming Labs (FMG)\FMG-001 Arsenic\Brownfields\Environmental Action Plan\Figure 2 Vicinity Map

0 100 200 APPROXIMATE
SCALE IN FEET
N TITLE
PROJECT
VICINITY MAP

FLEMING LABORATORIES CHARLOTTE, NORTH CAROLINA
DATE:
JOB NO:
REVISION NO:
FIGURE:
8-31-2012

0
2 FMG-001
2923 S. Tryon Street, Suite 100 Charlotte, NC 28203 704.586.0007(p) 704.586.0373(f)
Approximate Property Boundaries Fleming Laboratories; Pharmaceutical Manufacturer
Baker Mitchell Co; Wholesale Plumbing Supply Charlotte Tank Trucks, Inc; Tanker Truck Manufacturing, Repair, and Maintenance
Current Office and Manufacturing Area (2215 Thrift Rd)
Vacant (2205 & 2209 Thrift Rd)

Railroad Tracks
Freedom
Summerhour Lamps; Light Fixture Retailer B&H Foods; Food Manufacturer Ace Plastics; Plastic Manufacturing Company
Wesley Village
Fleming (Operating)
Summerhouse Lamps
B&H
Foods
Ace Plastics
Fleming (Vacant)
Baker Mitchell
Charlotte Tank

Appendix A
Arsenic Assessment Reports

• July 10, 2012 Arsenic Assessment (Text, Tables, and Figures Only)
• December 19, 2012 Refined Building Floor Assessment

Arsenic Assessment
2205 and 2009 Thrift Road

Fleming Laboratories
Charlotte, North Carolina

H&H Job No. FMG-001
July 10, 2012

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Arsenic Assessment
Fleming Laboratories
2205 and 2209 Thrift Road
Charlotte, North Carolina
H&H Job No. FMG-001

Table of Contents
Section Page
1.0 Introduction ............................................................................................................................ 1
2.0 Soil Assessment Activities ...................................................................................................... 3
2.1 Sample Collection Procedure ............................................................................................. 3
2.2 Naturally Occurring Arsenic .............................................................................................. 3
2.3 XRF Analytical Methods ................................................................................................... 4
2.4 XRF Results ....................................................................................................................... 4
2.5 TCLP Soil Sampling .......................................................................................................... 5
2.6 TCLP Soil Results.............................................................................................................. 5
2.7 XRF Quality Control .......................................................................................................... 6
2.8 Investigation Derived Waste and Soil Drums .................................................................... 6
2.9 VOC Soil Screening Results .............................................................................................. 7
3.0 Dry Dust Vacuuming ............................................................................................................. 8
3.1 Cleaning Procedures .......................................................................................................... 8
3.2 Dust Sampling .................................................................................................................... 8
4.0 Building Material Assessment .............................................................................................. 9
4.1 Sample Collection Procedure ............................................................................................. 9
4.2 Analytical Results .............................................................................................................. 9
5.0 Summary and Recommendations ....................................................................................... 11

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List of Tables

Table 1 XRF Analysis Arsenic Concentrations
Table 2 Site Specific Background Arsenic Concentrations
Table 3 Laboratory Analysis of Total Arsenic and TCLP Arsenic in Soil
Table 4 Comparison of XRF and Laboratory Analysis for Arsenic
Table 5 Generated Waste Characterization Data
Table 6 Building Material Waste Characterization Data

List of Figures

Figure 1 Site Location
Figure 2 Vicinity Map
Figure 3 Shallow Soil Arsenic Concentration Map
Figure 4 Highest Detected Soil Arsenic Concentration Map
Figure 5 TCLP and Total Metal Concentrations for Site Soils
Figure 6 Building Floor Composite Sample Analytical Results

List of Appendices

Appendix A Boring Logs
Appendix B Laboratory Analytical Reports
Appendix C Dry Vacuuming Photos
Appendix D Waste Disposal Documentation

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Arsenic Assessment
Fleming Laboratories
2205 and 2209 Thrift Road
Charlotte, North Carolina
H&H Job No. FMG-001

1.0 Introduction

In accordance with our authorized scope of work, Hart & Hickman, PC (H&H) has conducted
arsenic assessment activities at the Fleming Laboratories, Inc. (Fleming) property (Figures 1 and
2). H&H assessed the vacant portion of the Fleming site at 2205 and 2209 Thrift Road, which is
located on a single tax parcel. The active portion of the Fleming site is located at 2215 Thrift
Road which is a parcel adjacent to and north of the target property. This assessment was
conducted to determine current soil arsenic concentrations and to characterize certain building
materials for future demolition purposes. Prior to the building material sampling, H&H
contracted with Contaminant Control, Inc (CCI) to remove potential arsenic containing dust via
dry vacuuming methods.

Fleming Laboratories (Fleming) commenced operations in 1956 as a manufacturer of bulk drugs
for both the human and animal pharmaceutical markets. All of Fleming’s production activities
(manufacturing areas, warehousing, offices, etc) were conducted at the plant site with the address
range of 2205 to 2215 Thrift Road.

Among the products that Fleming has produced over the years, an important one for the company
was arsanilic acid (“AA”). AA is an organic form of arsenic that has been used in animal feeds
in the US since the 1940’s to improve the growth and health of chickens, turkeys, and swine.
While AA is an organic form of arsenic, AA was made from arsenic acid (80%), an inorganic
form of arsenic.

During the years of making AA, arsenic-containing compounds were spilled at the site with spills
in 1984 and 1999, as described below. These spills were either of arsenic acid (80%) or of

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aqueous in-process solutions associated with the AA production. These process solutions
contained AA, arsenic acid, or a combination of both.

When unloading a tank truck of arsenic acid (80%) at the Fleming site on November 14, 1984, a
faulty unloading valve failed on the delivery tank trailer resulting in the loss of an estimated 5
gallons (see Figure 4). The spill was mostly on the asphalt parking lot where the unloading took
place. In addition to the pavement, the exterior walls and a shrub landscape area were impacted.
Absorbent material was immediately deployed. The absorbent material and surface soil was
contained in 55-gallon drums for off-site disposal.

In 1992, National Environmental Technologies (NET) collected 107 soil samples from the 1984
release area to assess the extent of arsenic impacts. In August and September 1993,
approximately 121 tons of arsenic-impacted soil and asphalt were excavated for off-site disposal.
Following confirmatory sampling, the site was deemed adequately remediated by the oversight
contractor based on an arsenic cleanup standard of 63 mg/kg. The published default current
North Carolina Department of Environment and Natural Resources (DENR) cleanup standards
for arsenic are below this value.

On February 19, 1999, approximately 1,000 gallons of an AA in-process solution (arsanilic acid
rinsate) was released due to operator error (see Figure 4). The released solution affected soil
beneath a nearby wooden platform and in the drainage area between buildings C and D. In
March, April, and May of 1999, S&ME collected 63 soil samples to assess areas potentially
affected by the release, but no remediation was conducted for those soils.

H&H began to provide environmental consulting services on this site in 2011 to determine
current arsenic concentrations and expand previous assessment work. The methods and results
of our assessment activities are provided below.

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2.0 Soil Assessment Activities

2.1 Sample Collection Procedure

Soil borings were installed near the 1984 spill area, 1999 spill area, adjacent to a former arsanilic
acid above-ground storage tank (AST), and adjacent to a former arsenic acid AST. H&H
installed 51 soil borings using a direct push technology (DPT) cart mounted rig (Groprobe 420M
rig), or using a decontaminated stainless steel hand auger. The cart rig and hand auger boring
methods were used due to limited accessibility into the site structures for drilling equipment. At
soil boring locations where the cart rig was used, samples were collected in continuous 3 or 4 ft
intervals. At boring locations that required the use of a hang auger, samples were collected from
the auger bucket. Non-disposable sampling equipment was decontaminated between borings
using Alconox and a distilled water rinse. Following collection, soil descriptions were recorded
and samples were screened for the presence of odors, staining, and elevated photo-ionization
detector (PID) readings. PID readings were collected to screen soil for organic compounds.
Sample locations are provided on Figures 2 through 4. Boring logs, along with PID readings are
provided in Appendix A.

Once soil descriptions and PID reading were recorded, soils from target depths in each soil
boring were homogenized and analyzed for arsenic using a handheld X-Ray Florescence analyzer
(XRF) by H&H personnel. XRF field analysis was selected as the primary analytical tool such
that numerous samples could be quickly analyzed for delineation purposes. In general, four to
eight samples were collected from each boring location from various depth intervals. Results for
the XRF analysis can be found on Table 1. Total boring depth was determined by accessibility,
estimated depth to the water table, or by vertical delineation of arsenic impacts.

2.2 Naturally Occurring Arsenic

Arsenic is naturally occurring in Piedmont soils. Therefore, samples were collected to determine
site-specific naturally occurring (or background) arsenic levels. Two background borings were

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installed to collect site-specific samples for laboratory analysis. The background borings were
placed in the northeast corner of the Fleming property at 2215 Thrift Road which is in the
upgradient portion of the site (Figure 2). A total of ten soil samples were collected from these
boring locations and submitted to a Prism Laboratories, Inc., a North Carolina certified
laboratory, for arsenic analysis by EPA Method 6010C. Background arsenic concentrations
ranged from <0.62 mg/kg to 2.9 mg/kg. Results for the background samples are provided in
Table 2, and the laboratory report is included in Appendix B.

2.3 XRF Analytical Methods

The soil samples were analyzed in the field using a NITON XL300 XRF unit. Soil samples were
thoroughly homogenized prior to analysis. The homogenized soil was then placed in the test
stand in front of the analyzer window. The analyzer was activated remotely using a laptop
computer, and samples were screened for 60 to 90 seconds, as needed for the reading to stabilize.
Screening results for each sample along with a unique sample ID were stored electronically
within the XRF device and recorded in a field notebook. Raw data from the XRF device was
downloaded onto a computer immediately following field activities.

2.4 XRF Results

A total of 225 unique soil samples were analyzed via XRF during two sampling events. The
arsenic concentrations ranged from <3 mg/kg to 22,100 mg/kg. Sample locations are included on
Figures 3 and 4, and XRF arsenic concentrations are included on Table 1. A summary of shallow
(<2 ft bgs) arsenic concentrations for each boring is included in Figure 3, and a summary of the
highest detected concentration in each boring is included as Figure 4. Sample results were
compared to background levels and North Carolina Department of Environment and Natural
Resources Inactive Hazardous Sites Branch Soil Remedial Goals (SRGs). The protection of
groundwater SRG for arsenic is 5.8 mg/kg, and the residential/industrial SRGs are 0.39/1.6
mg/kg, respectively.

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Arsenic impacts are widespread and cover most of the vacant portion of the Fleming site. Soil
impacts extend to the property boundaries in certain locations, and the impacts potentially extend
off-site. The areas of highest arsenic impact are associated with the former arsanilic acid AST
and arsenic acid AST in the west and northwest portions of the site, respectively, and near and
downgradient of the 1999 spill area (Figure 4). The impacted soil is not limited to shallow
depths. Impacts extend to depths up to 24 ft, which is near the water table. There are a few areas
that appear to be free from arsenic contamination including the northeast portion of Building B,
southwest portion of Building C, and northeast portion of the 2205 to 2209 Thrift Road parcel
(Figures 3 and 4).

2.5 TCLP Soil Sampling

Soils that contain characteristically hazardous waste are more difficult and expensive to manage
if excavated. To evaluate if impacted soil would be characteristically hazardous waste (if
excavated), H&H collected samples for analysis of Toxicity Characteristic Leaching Procedure
(TCLP) metals and total RCRA metals by EPA Method 6010C/7470A. H&H collected soil
samples in March 2012 from locations determined to be impacted with arsenic during the initial
site assessment in November 2011. H&H also analyzed the TCLP samples for total arsenic to
determine if there is a correlation between total and TCLP results. The samples were collected
directly from DPT sampling sleeves into laboratory supplied sampling containers and submitted
to Prism Laboratories. The results of the analysis are discussed below.

2.6 TCLP Soil Results

Four soil samples were analyzed for total arsenic and TCLP RCRA metals. The samples were
collected from HH-SB-5A, HH-SB-7A, HH-SB-20A, and HH-SB-24A. The total arsenic results
indicated levels of arsenic ranging from 1,700 to 2,400 mg/kg. The sample (HH-SB-20A) with
the highest total arsenic concentration (2,400 mg/kg) contained a TCLP concentration of 37
mg/L, which exceeds the RCRA hazardous waste threshold of 5 mg/L for arsenic. The other
TCLP arsenic concentrations ranged from <0.05 to 3.5 mg/L, which are below the arsenic RCRA

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hazardous waste threshold. Results are provided in Table 3 and shown on Figure 5. The
laboratory report with chain of custody is included in Appendix B.

2.7 XRF Quality Control

For quality control purposes and to ensure the XRF was reading with reasonable accuracy, H&H
used the XRF analyzer to test at least one sample at the beginning of each day with a known
(spiked) arsenic concentration and a clean or blank sample. H&H also ran five duplicate samples
in the field via XRF during each field event. In addition, H&H submitted 11 of the XRF analyzed
samples from the November 2011 field event and eight XRF analyzed samples from the March
2012 field event to Prism Laboratories for arsenic analysis by EPA Method 6010C to compare
with the field XRF sample results. Laboratory results for the XRF and laboratory comparative
samples are presented in Table 4, and laboratory reports are provided in Appendix B.

Based on the five field duplicate samples (Table 1), the XRF instrument performed with good
precision and produced similar results among the duplicate samples. In addition, the XRF data
compare reasonably well with laboratory results with two exceptions (Table 4). The XRF and
laboratory results for samples HH-SB-5 and HH-SB-14 did not compare favorably. Even though
the data for HH-SB-5 and HH-SB-14 did not compare favorably, both the laboratory and XRF
arsenic results exceed SRGs.

2.8 Investigation Derived Waste and Soil Drums

During our assessment activities, investigation derived waste (IDW) was generated. Soil cuttings
generated during the November 2011 and March 2012 assessments were contained in 55-gallon
steel drums. Following each event, a composite soil sample was taken from the soil drum and
submitted to Prism Laboratories for analysis of TCLP metals by EPA Method 6010C/7470A for
waste characterization. Results from soil generated during the November 2011 sampling event
indicated TCLP arsenic concentration of 0.70 mg/L. This arsenic concentration is below the
RCRA hazardous waste threshold of 5.0 mg/L. The disposal documentation for the non-

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hazardous IDW generated in November 2011 is provided in Appendix D. No TCLP metals were
detected in the soil drum generated during the March 2012 event. This drum remains on site.

Equipment decontamination water was also drummed during the November 2011 and March
2012 field events. Low levels of RCRA metals were detected in the decontamination water in
each drum. The detected metal concentrations were below the RCRA hazardous waste
thresholds. The disposal documentation for the non-hazardous IDW water drum generated in
November 2011 is provided in Appendix D. No TCLP metals were detected in the water drum
generated during the March 2012 event. This decontamination water drum remains on site.

In addition, four 30-gallon blue plastic drums of soil were generated by Fleming personnel when
a dock was rebuilt in June 2007. The dock was rebuilt at the location of the 1999 arsanilic acid
spill. H&H collected a composite sample from those four soil drums for analysis of TCLP
metals. Low level metal impacts were present in the soil, but the concentrations do not exceed
RCRA hazardous waste thresholds. These four soil drums remain on-site.

Sampling results for the IDW and soil drums are summarized in Table 5. Laboratory reports are
provided in Appendix B.

2.9 VOC Soil Screening Results

As noted above, H&H screened soil cuttings for indications of organic compounds using a PID.
Soil from one boring (HH-SB-17) indicated the potential presence of organic compound impacts
based on a potential chemical-like odor and elevated PID readings up to 21.7 ppm. No samples
were collected for laboratory analysis for volatile organic compounds (VOCs) or semi-VOCs.
No other soil samples indicated a likelihood of organic chemicals based on field screening.

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3.0 Dry Dust Vacuuming

3.1 Cleaning Procedures

As noted below in Section 4.0, floor samples were collected for waste disposal characterization
in the case of future building demolition. Prior to sampling, Contaminant Control, Inc (CCI), an
environmental contractor, removed dust from the floor and horizontal surfaces (shelves, window
sills, etc.) in Buildings B, C, D, and E. CCI utilized HEPA Vac Portable Vacuum Units as a dry
method of dust removal. H&H personnel were onsite prior to the start of vacuuming activities
and returned to the site upon completion of activities to check the quality of service. CCI
personnel worked through each building with the HEPA Vac Portable Vacuum Units in such a
way as to not track through already clean areas, thereby avoiding cross contamination. Dust
collected during vacuuming was collected in HEPA Vac Portable Vacuums Unit bags. Once
bags reached capacity they were removed from the unit and stored in onsite 55-gallon drums in
locked fenced in location, and a new bag was placed in the unit. The buildings were cleaned
until they were visually free of obvious loose dust based on observations by CCI and H&H
personnel. Photographs showing before and after images are included in Appendix C.

3.2 Dust Sampling

Once vacuuming activities were completed, H&H personnel collected a composite sample from
the three dust drums in order to characterize the dust for disposal. Sample aliquots were
collected from the upper, middle, and lower portions of each of the drums. The sample aliquots
were homogenized and collected into a laboratory supplied sample container. The dust was
analyzed for TCLP metals by EPA Method 6010C/7470A. TCLP arsenic was detected in the
dust at a concentration of 16 mg/L which exceeds the RCRA hazardous waste threshold of 5
mg/L (Table 5). The laboratory report along with chain-of-custody is included in Appendix B.
The dust drums were disposed as characteristically hazardous waste, and the documentation is
provided in Appendix D.

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4.0 Building Material Assessment

4.1 Sample Collection Procedure

Following the dry dust vacuuming, composite floor samples were collected from the floor in each
of the buildings to characterize the material for disposal if plans to demolish the buildings were
to be carried out. It is assumed that the building floors are where there is a potential for elevated
arsenic from liquid spills or entrapped dust. Sample aliquots were collected from representative
areas in Buildings B, C, D, and E. Each building was characterized separately. Building C has
two levels, but only the lower level of Building C was characterized during this work. Chisels
were used to remove representative sample aliquots from the concrete floor in Buildings B and C
and the wood floor in Buildings D and E. To obtain samples representative of the entire floor
thickness, the chisels were used to chip down into the concrete or wood. To facilitate collection
of chips from the lower portion of the slab, several of the composite sample aliquots were
collected by chipping the inside of core holes made by the DPT equipment.

Sample aliquots from each building were placed in laboratory supplied containers and delivered
to Prism Laboratories for analysis of TCLP RCRA Metals by EPA Method 6010C/7470A and
Total RCRA metals by EPA Method 6010C/7471B.

4.2 Analytical Results

The composite floor samples contained RCRA metals including arsenic, barium, cadmium,
chromium, lead, mercury, and selenium. However, arsenic was the only metal that was detected
at definitively elevated concentrations. The composite samples collected from Building C (lower
level) and Building D (samples C-1 and D-1) contained TCLP arsenic at concentrations of 9.7
mg/L and 22 mg/L. Results of the TCLP analyses were compared to the RCRA hazardous waste
thresholds for each compound. Based on these results, the floors of Buildings C (lower level)
and D contain TCLP arsenic above the RCRA hazardous waste threshold. It is not known if only

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portions of these floors resulted in the arsenic above hazardous waste thresholds. Although
below the RCRA hazardous waste thresholds, the floors in Buildings B and E are also impacted
with arsenic. Results are included as Table 6. A map outlining the sample aliquot locations and
sample results is included as Figure 6. The laboratory report along with chain-of-custody is
included in Appendix B.

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5.0 Summary and Recommendations

H&H assessed soil and building floors at 2205 and 2209 Thrift Road for arsenic using XRF and
laboratory analytical methods. Prior to sampling the building floors, they were dry vacuumed
using HEPA filters by an environmental contractor. Sampling events were conducted in
November 2011 and March 2012. A brief summary of the results is as follows:

• Widespread elevated arsenic was detected in soils at 2205 and 2209 Thrift Road. Soil
impacts extend to the property boundaries in certain locations, and the impacts potentially
extend off-site. There are a few areas of soil that appear to be free from arsenic
contamination including the northeast portion of Building B, southwest portion of Building
C, and northeast portion of the 2205 to 2209 Thrift Road parcel.

• The arsenic impacted soil is not limited to shallow depths. Impacts extend to depths up to 24
ft, which is near the water table.

• The areas of highest arsenic impact are associated with the former arsanilic acid AST and
arsenic acid AST in the west and northwest portions of the site, respectively, and the location
of the 1999 arsanilic acid spill. Arsenic concentrations ranged up to 22,100 mg/kg. Site-
specific naturally occurring arsenic concentrations were evaluated by collecting 10 samples in
the upgradient portion of the adjacent 2215 Thrift Road property. Naturally occurring arsenic
concentrations ranged from <0.62 mg/kg to 2.9 mg/kg based on laboratory results.

• The composite building floor samples contained RCRA metals. However, arsenic was the
only metal that was detected at definitively elevated concentrations. The composite samples
collected from Building C (lower level) and Building D contained TCLP arsenic at
concentrations of 9.7 mg/L and 22 mg/L. Based on these results, the floors of Buildings C
(lower level) and D contain TCLP arsenic above the RCRA hazardous waste threshold of 5
mg/L. It is not known if only portions of these floors resulted in the arsenic above hazardous
waste thresholds.

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H&H recommends proper disposal of building material if demolition is to be carried out.
Additional samples may be warranted to further characterize building materials. For example,
the upper level of Building C should be tested and additional samples should be considered to
determine if portions of the floors in the lower level of Building C and in Building D may be
non-hazardous. Depending on the owner’s plans for the future use or sale of this property, the
North Carolina Department of Environment and Natural Resources (DENR) Ready for Reuse
Brownfields program may be a good option.

Table 1 (Page 1 of 2)
XRF Analysis Arsenic Concentrations
Fleming Laboratories
Charlotte, North Carolina
H&H Project No. FMG-001
S:\AAA-Master Projects\Fleming Labs (FMG)\FMG-001 Arsenic\XRF data\Data Tables
7/10/2012
Table 1 (Page 1 of 2)
Hart & Hickman, PC
Depth As Error Depth As Error Depth As Error
(ft)(ppm or mg/kg)(+/-)(ft)(ppm or mg/kg)(+/-)(ft)(ppm or mg/kg)(+/-)
0-0.5 489 11 0-0.5 1,137 18 0-0.5 <4 4
1.5-2 470 11 1.5-2 2,693 26 1.5-2 <4 4
4.5-5 978 16 4.5-5 2,660 36 4.5-5 <4 49.5-10 891 15 9.5-10 1,368 27 9.5-10 <4 411.5-12 27 3 11.5-12 1,505 28 14.5-15 <4 4
0-0.5 9 3 14.5-15 1,372 18 0-0.5 4,175 34
1.5-2 <4 4 17.5-18 578 11 1.5-2 1,389 19
4.5-5 <4 4 19.5-20 126 7 4.5-5 18 4
9.5-10 <4 4 22.5-23 <3 3 9.5-10 95 5
0-0.5 138 6 0-0.5 40 4 11.5-12 93 61.5-2 221 8 1.5-2 32 4 14.5-15 147 7
4.5-5 <4 4 4.5-5 665 13 0-0.5 1,681 21
9.5-10 30 4 DUP 4.5-5 613 12 1.5-2 1,054 20
11.5-12 <4 4 7.5-8 4 3 4.5-5 310 11
0-0.5 134 8 9.5-10 <4 4 9.5-10 20,700 90
1.5-2 1,086 19 0-0.5 59 5 DUP 9.5-10 22,100 100 4.5-5 278 9 1.5-2 13 3 11.5-12 2,845 31
11.5-12 9 3 4.5-5 266 9 14.5-15 1,076 16
14.5-15 19 3 7.5-8 <4 4 19.5-20 1,201 17
0-0.5 1,638 24 9.5-10 <4 4 20.5-21 1,188 18
1.5-2 235 9 0-0.5 975 17 23.5-24 397 11
4.5-5 1,449 20 1.5-2 499 12 0-0.5 6 3 9.5-10 <4 4 4.5-5 <4 4 1.5-2 <5 5 11.5-12 <4 4 9.5-10 <4 4 4.5-5 <4 4
14.5-15 <4 4 0-0.5 287 9 9.5-10 <4 4
0-0.5 618 13 1.5-2 105 6 11.5-12 <4 4
1.5-2 171 7 4.5-5 <4 4 0-0.5 3,066 40
4.5-5 151 7 9.5-10 <4 4 1.5-2 408 16 9.5-10 <3 3 0-0.5 103 8 4.5-5 17 6 11.5-12 <16.4 16 1.5-2 25 4 9.5-10 8 3
14.5-15 <3 3 DUP 1.5-2 21 4 0-0.5 3,252 31
19.5-20 <4 4 4.5-5 30 4 1.5-2 2,804 29
0-0.5 1,035 20 9.5-10 4 3 4.5-5 1,132 16
1.5-2 146 8 0-0.5 101 6 0-0.5 <4 4DUP 1.5-2 159 7 1.5-2 16 3 1.5-2 <5 5 4.5-5 97 6 4.5-5 <4 4 4.5-5 <4 4
9.5-10 <3 3 0-0.5 2,733 28 0-0.5 552 20
11.5-12 43 4 1-1.5 3,437 30 1.5-2 769 24
14.5-15 <3 3 1.5-2 813 14 4.5-5 177 7
19.5-20 <3 3 2.5-3 25 4 9.5-10 174 7
DUP 19.5-20 <3 3 3.5-4 338 10 0-0.5 32 4 0-0.5 1,830 25 0-0.5 <5 5 1.5-2 64 5
1.5-2 1,959 24 1.5-2 <5 5 4.5-5 12 3
4.5-5 2,722 29 4.5-5 <5 5
9.5-10 5 3 9.5-10 <4 4
7.5-8 <4 4 14.5-15 <5 5
11.5-12 80 5 0-0.5 <5 5 14.5-15 <4 4 1.5-2 <4 4 19.5-20 <4 4 4.5-5 <4 4
Notes: 9.5-10 <4 4
1) Soil analysis completed by XRF analysis using a NITON XL300
2) Error value represents the 2 sigma value as determined by the XRF device
3) DUP- Duplicate samples4) Site specific background concentraions ranged from <0.62 mg/kg to 2.9 mg/kg5) The DENR Inactive Hazardous Sites Branch (IHSB) Residential and Industrial Soil Remiedial Goals (SRGs) for arsenic are 0.39 mg/kg and 1.6 mg/kg. (February 2012)
6) The DENR IHSB Protection of Groundwater SRG for arsenic is 5.8 mg/kg (February 2012)
HH-SB-21 11/17/2011
HH-SB-27 11/17/2011
HH-SB-26 11/17/2011
HH-SB-22 11/17/2011
HH-SB-25 11/17/2011
HH-SB-12 11/17/2011
HH-SB-8 11/15/2011
HH-SB-17 11/17/2011
HH-SB-18 11/16/2011
HH-SB-23 11/17/2011
HH-SB-24 11/17/2011
HH-SB-15 11/15/2011
HH-SB-6 11/16/2011
HH-SB-13 11/16/2011
HH-SB-14 11/15/2011
HH-SB-7 11/16/2011
HH-SB-16 11/17/2011
HH-SB-3 11/16/2011 HH-SB-10 11/16/2011
HH-SB-4 11/16/2011
HH-SB-11 11/16/2011
HH-SB-5 11/16/2011
HH-SB-19 11/17/2011
HH-SB-2 11/16/2011
HH-SB-20 11/17/2011
HH-SB-1 11/16/2011
HH-SB-9 11/15/2011
Sample ID Date CollectedSample ID Date Collected Sample ID Date Collected
Table 1 (Page 2 of 2)
XRF Analysis Arsenic Concentrations
Fleming Laboratories
Charlotte, North Carolina
H&H Project No. FMG-001
S:\AAA-Master Projects\Fleming Labs (FMG)\FMG-001 Arsenic\XRF data\Data Tables
7/10/2012
Table 1 (Page 2 of 2)
Hart & Hickman, PC
Depth As Error Depth As Error
(ft)(ppm or mg/kg)(+/-)(ft)(ppm or mg/kg)(+/-)
0-0.5 16 5 0-0.5 7 4
1.5-2 9 5 1.5-2 9 6
4.5-5 <5 5 4.5-5 46 5 9.5-10 <5 5 DUP 4.5-5 57 5 0-0.5 955 20 9.5-10 7 4
1.5-2 16 4 11.5-12 6 4
DUP 1.5-2 10 3 14.5-15 <6 6
4.5-5 17 3 0-0.5 <5 5
9.5-10 <4 4 1.5-2 <7 7
0-0.5 1,100 19 4.5-5 <4 41.5-2 744 15 9.5-10 <4 4
4.5-5 <4 4 14.5-15 <5 5
9.5-10 5 3 0-0.5 <6 6
0-0.5 8 4 1.5-2 <6 6
1.5-2 <5 5 4.5-5 <5 5
4.5-5 <2 2 DUP 4.5-5 <5 59.5-10 <5 5 9.5-10 <5 5
0-0.5 <6 6 11.5-12 <5 5
1.5-2 9 4 14.5-15 4 3
4.5-5 <5 5 0-0.5 <6 6
9.5-10 <5 5 1.5-2 <6 6
0-0.5 5 4 4.5-5 <6 61.5-2 <6 6 9.5-10 <4 4
4.5-5 <5 5 14.5-15 <3 3
0-0.5 <5 5 0-0.5 <6 6
1.5-2 <4 4 1.5-2 <6 6
4.5-5 <5 5 4.5-5 9 5
0-0.5 <5 5 9.5-10 32 61.5-2 <5 5 11.5-12 16 44.5-5 <5 5 14.5-15 6 4
0-0.5 20 4 0-0.25 283 19
1.5-2 7 3 0.25-0.5 18 4
4.5-5 7 3 1.5-2 <5 5
0-0.5 59 5 4.5-5 7 4
1.5-2 <7 7 0-0.5 404 154.5-5 12 3 0.5-1.0 229 12
9.5-10 <4 4 1-1.5 21 6
DUP 9.5-10 <4 4 1.5-2 <6 6
0-0.5 166 9 HH-SB-47 3/15/2012 0-0.5 27 6
DUP 0-0.5 162 8 HH-SB-48 3/15/2012 0-0.25 42 6
1.5-2 192 7 HH-SB-49 3/15/2012 0-0.25 41 174.5-5 48 5 HH-SB-50 3/15/2012 0-0.25 18 6
9.5-10 <5 5 0-0.25 <5 5
11.5-12 18 6 0.25-0.5 <5 5
0-0.5 <5 5 1.5-2 7 4
1.5-2 5 2
4.5-5 39 58.5-9 <5 5Notes:
1) Soil analysis completed by XRF analysis using a NITON XL300
2) Error value represents the 2 sigma value as determined by the XRF device
3) DUP- Duplicate samples
4) Site specific background concentraions ranged from <0.62 mg/kg to 2.9 mg/kg5) The DENR Inactive Hazardous Sites Branch (IHSB) Residential and Industrial Soil Remiedial Goals (SRGs) for arsenic are 0.39 mg/kg and 1.6 mg/kg. (February 2012)6) The DENR IHSB Protection of Groundwater SRG for arsenic is 5.8 mg/kg (February 2012)
Date Collected
3/13/2012
HH-SB-45
Sample IDSample ID
HH-SB-29
HH-SB-30
HH-SB-28
3/13/2012
3/13/2012
HH-SB-41 3/14/2012
3/13/2012
3/13/2012
HH-SB-39
HH-SB-37
HH-SB-38
HH-SB-35
HH-SB-36
3/14/2012HH-SB-43
HH-SB-33
HH-SB-31
HH-SB-32
HH-SB-34
HH-SB-44
3/13/2012
3/13/2012
3/14/2012
3/13/2012
3/13/2012
3/14/2012
3/14/2012
3/13/2012
3/15/2012HH-SB-51
3/15/2012HH-SB-46
Date Collected
3/14/2012HH-SB-40
3/14/2012HH-SB-42
3/15/2012
Table 2 (Page 1 of 1)
Site Specific Background Arsenic Concentrations
Fleming Laboratories
Charlotte, North Carolina
H&H Job No. FMG-001
S:\AAA-Master Projects\Fleming Labs (FMG)\FMG-001 Arsenic\XRF data\Data Tables
7/10/2012
Table 2 (Page 1 of 1)
Hart & Hickman, PC
Depth Date Arsenic
Sample ID ft Collected ppm or mg/kg
0-0.5 2.8
1.5-2 <0.64
4.5-5 <0.63
7.5-8 <0.62
9.5-10 <0.65
0-0.5 2.9
1.5-2 2.2
4.5-5 <0.64
7.5-8 <0.63
9.5-10 <0.62
Notes:
1) Arsenic values based on laboratory data from NC Certified Prism Laboratories
2) Arsenic by EPA Method 6010C
HH-BG-2 11/15/2011
11/15/2011HH-BG-1
Table 3 (Page 1 of 1)
Laboratory Analysis of Total Arsenic and TCLP Arsenic in Soil
Fleming Laboratories
Charlotte, North Carolina
H&H Job No. FMG-001
S:\AAA-Master Projects\Fleming Labs (FMG)\FMG-001 Arsenic\XRF data\Data Tables
7/10/2012
Table 3 (Page1 of 1)
Hart & Hickman, PC
Sample ID Depth Date Total As TCLP As
HH-SB-5A 0-0.5 03/13/12 1,700 1.6
HH-SB-7A 0-0.5 03/13/12 2,300 <0.050
HH-SB-20A 0-0.5 03/14/12 2,400 37
HH-SB-24A 0-0.5 03/13/12 1,900 3.5
Notes:
1) Bold exceeds arsenic hazardous waste characteristic threshold of 5 mg/L
for Arsenic
2) Total levels are reported in mg/kg; TCLP levels are reported in mg/L
3) Lab analysis received from NC Certified Prism Laboratories
4) TCLP- Toxicity characteristic leaching procedure by EPA Method 6010C/7470A
5) Total- Total Metals by EPA Method 6010C/7471B
Table 4 (Page 1 of 1)
Comparison of XRF and Laboratory Anaylsis for Arsenic
Fleming Laboratories
Charlotte, North Carolina
H&H Project No. FMG-001
S:\AAA-Master Projects\Fleming Labs (FMG)\FMG-001 Arsenic\XRF data\Data Tables
7/10/2012
Table 4 (Page 1 of 1)
Hart & Hickman, PC
XRF Analysis Lab Analysis
Sample ID Depth (ft)
HH-SB-2 4.5-5 11/16/2011 <4 <0.66
HH-SB-5 4.5-5 11/16/2011 1,449 23
HH-SB-6 0-0.5 11/16/2011 618 760
HH-SB-7 9.5-10 11/16/2011 <3 <0.66
HH-SB-9 4.5-5 11/15/2011 2,660 3,300
HH-SB-9 11.5-12 11/15/2011 1,505 2,200
HH-SB-14 4.5-5 11/15/2011 30 13
HH-SB-18 4.5-5 11/16/2011 <4 0.95
HH-SB-19 4.5-5 11/17/2011 <4 1.4
HH-SB-21 9.5-10 11/17/2011 22,100 23,000
HH-SB-22 11.5-12 11/17/2011 <4 3.4
HH-SB-30 0-0.5 3/13/2012 1,100 1,400
HH-SB-35 0-0.5 3/13/2012 <5 4.4
HH-SB-36 1.5-2 3/13/2012 7 8.9
HH-SB-38 0-0.5 3/14/2012 162 120
HH-SB-40 4.5-5 3/14/2012 46 57
HH-SB-41 9.5-10 3/14/2012 <4 2.0
HH-SB-43 9.5-10 3/14/2012 <4 1.8
HH-SB-44 9.5-10 3/14/2012 32 25
Notes:
1) Arsenic values from lab analysis received from NC Certified Prism Laboratories
2) Arsenic by EPA Method 6010C
Arsenic
ppm or mg/kg
Date
Analyzed/Collected
Table 5 (Page 1 of 1)
Generated Waste Characterization Data
Fleming Laboratories
Charlotte, North Carolina
H&H Job No. FMG-001
S:\AAA-Master Projects\Fleming Labs (FMG)\FMG-001 Arsenic\XRF data\Data Tables
7/10/2012
Table 5 (Page 1 of 1)
Hart & Hickman, PC
Sample ID Date Generating Activity Type Mercury As Cadmium
HH-Soil-1 11/17/11 Arsenic Assessment; Phase I Solid <0.010 0.70 <0.025
Soil-2 03/14/12 Arsenic Assessment; Phase II Solid <0.010 <0.050 <0.025
Soil Drum Comp-1 03/13/12 Fleming Excavation Soil Solid <0.010 2.5 0.037
Dust Drum-1 03/14/12 Fleming Facility Cleaning Solid 0.05 16 0.092
Decon-2 03/14/12 Arsenic Assessment; Phase II Liquid <0.010 0.064 <0.025
RCRA Hazardous Waste Threshold 0.2 5.0 1.0
Sample ID Date Generating Activity Type Mercury Arsenic Barium Chromium Lead
HH-Decon-1 11/17/11 Arsenic Assessment Phase I Liquid 0.00037 0.86 0.14 0.13 0.022
RCRA Hazardous Waste Threshold 0.2 5.0 100.0 5.0 5.0
Notes:
1) Bold indicates exccedance of RCRA Hazardous Waste Threshold
2) TCLP- Toxicity characteristic leaching procedure by EPA Method 6010C/7470A
TCLP Metals (mg/L)
Total RCRA Metals (mg/L)
Table 6 (Page 1 of 1)
Building Material Waste Characterization Data
Fleming Laboratories
Charlotte, North Carolina
H&H Project No. FMG-001
S:\AAA-Master Projects\Fleming Labs (FMG)\FMG-001 Arsenic\XRF data\Data Tables
7/10/2012
Table 6 (Page 1 of 1)
Hart & Hickman, PC
Sample ID Date Collected Material Type TCLP Total TCLP Total TCLP Total TCLP Total TCLP Total TCLP Total TCLP Total
B-1 03/14/12 concrete 0.42 2.1 <5.0 17 <0.025 <0.25 <0.25 6.4 <0.050 2.1 <0.010 <0.021 <0.10 <0.50
C-1 03/14/12 concrete 9.7 1,500 <5.0 25 <0.025 <0.25 <0.25 9.7 <0.050 10 <0.010 <0.021 <0.10 <0.50
D-1 03/14/12 wood 22 1,400 <5.0 23 0.16 10 <0.25 9.4 0.079 46 <0.010 0.15 <0.10 0.61
E-1 03/14/12 wood 2.8 38 <5.0 9.3 <0.025 0.85 <0.25 1.4 <0.050 7.5 <0.010 0.022 <0.10 0.56
RCRA Hazardous Waste Threshold 5.0 NA 100.0 NA 1.0 NA 5.0 NA 5.0 NA 0.2 NA 1.0 NA
Notes:
1) Bold indicates exceedance of RCRA Hazardous Waste treshold
2) Only constituents detected in at least one sample shown
3) TCLP- Toxicity characteristic leaching procedure by EPA Method 6010C/7470A (mg/L)
4) Total- Total Metals by EPA Method 6010C/7471B (mg/kg)
NA = Not Applicable
Arsenic SeleniumMercuryLeadChromium CadmiumBarium
SITE
0 2000 4000
APPROXIMATE
SCALE IN FEET
N
U.S.G.S. QUADRANGLE MAPS
QUADRANGLE
7.5 MINUTE SERIES (TOPOGRAPHIC)
TITLE
PROJECT
SITE LOCATION MAP
FLEMING LABORATORIESCHARLOTTE, NORTH CAROLINA
DATE:
JOB NO:
REVISION NO:
FIGURE:
5-29-12 0
1FMG-001
Charlotte East, North Carolina, 1988
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Refined Building Floor Assessment

Fleming Laboratories Property
2205-2209 Thrift Road
Charlotte, North Carolina

H&H Job No. FMG-001
December 19, 2012

Via E-Mail

December 19, 2012
Fleming Laboratories, Inc.
2215 Thrift Road
Charlotte, NC 28208 Attention: Mr. George Fleming, Jr.

Re: Refined Building Floor Assessment
Fleming Laboratories Property 2205-2209 Thrift Road Charlotte, North Carolina
H&H Job No. FMG-001

Dear Mr. Fleming:

1.0 Introduction and Background

With regard to the above-referenced site, Hart & Hickman, PC (H&H) is pleased to provide this
letter report documenting the results of refined building material sampling conducted on
October 1, 2012. This follows an earlier building material sampling event that occurred on
March 14, 2012. The purpose of this additional assessment was to provide a more detailed
evaluation of arsenic detections previously identified in building floor materials at the site.

As described in the Arsenic Assessment Report dated July 10, 2012, composite samples collected
on March 14, 2012 from Building C (lower level) and Building D contained leachable arsenic
concentrations of 9.7 mg/L and 22 mg/L, exceeding the RCRA characteristically hazardous
waste threshold of 5.0 mg/L for arsenic. Floor composite samples collected from Building B and
Building E also contained leachable concentrations of arsenic, but at levels below the RCRA
hazardous waste threshold.

Mr. George Fleming, Jr.
December 19, 2012
Page 2
S:\AAA-Master Projects\Fleming Labs (FMG)\FMG-001 Arsenic\Building Material Assessment\Building Material Sampling Report.doc
The arsenic concentrations in the floors were detected after an environmental contractor
vacuumed the floors using a HEPA Vacuum. Based on the presence of elevated arsenic in the
floors, it appears that liquid arsenic solutions have penetrated certain floor materials.

The initial composite samples collected on March 14, 2012 were slightly biased towards the top
surface of the building materials. Due to the conservative nature of the March 2012 dataset, it
was unnecessary to resample Buildings B and E, which tested as non-hazardous. H&H returned
to Fleming Laboratories on October 1, 2012 to conduct a refined sampling of Building C (lower
level) and Building D, and the initial sampling of Building C (upper level). The sampling
procedure and results of the sampling event are described below.

2.0 Sampling Procedure

Sampling methodology was adapted from the US EPA Science and Ecosystem Support Division
(SESD) Operating Procedure for Waste Sampling dated November 1, 2007. The Waste
Sampling procedure was selected because the buildings will be demolished, and this sampling is
part of determining how the landfill waste will be disposed. Section 4.5 Miscellaneous
Contaminated Materials, Section 5.0 Waste Sample Handling Procedures, and Section 6.0
Particle Size Reduction are most applicable to the assessment activities. H&H’s specific
sampling plans were outlined in the Building Material Sampling Plan dated September 10, 2012.

2.1 Sample Quadrants and Compositing

As noted previously, the lower and upper levels of Building C and the floor of Building D were
sampled as part of this evaluation. Prior to sampling, each sampled building floor was divided
into four quadrants of similar size. Three sample aliquots were then collected from each of the
quadrants and composited into one quadrant sample. Portions of the four quadrant samples were
then composited to create one overall floor sample. Sample aliquot locations and quadrant
outlines are shown on Figure 1.

Mr. George Fleming, Jr.
December 19, 2012
Page 3
S:\AAA-Master Projects\Fleming Labs (FMG)\FMG-001 Arsenic\Building Material Assessment\Building Material Sampling Report.doc
2.2 Sample Collection Methods

Two types of flooring materials were sampled including a concrete slab on both floors of
Building C and the wood floor in Building D. To sample the concrete slab floor in Building C,
H&H utilized a standing core drill (which requires wet methods) equipped with a 1 ½ inch
diameter core barrel. The sample core was collected through the entire thickness of the concrete
slab. Following coring, each core sample was wiped with a paper towel in order to remove water
and potential metal shavings left by the core barrel. The sample was then wrapped in 6 mil
plastic liner and placed into plastic Ziploc bags. While wrapped in plastic and bagged, the core
was broken into pea-sized pieces using a decontaminated engineer’s hammer.

To sample the wood floor in Building D, an electric drill equipped with a titanium drill bit was
used to generate wood cuttings. Due to the thickness of the wood floor and the mass required by
the laboratory for sampling, several holes were required at each aliquot location in order to
generate enough sample material. The drill cuttings were then collected into Ziploc baggies and
labeled. After sample collection, the core holes in the concrete floors were patched with
concrete and holes in the wood floor were patched using construction adhesive/wood filler.

Prior to compositing the quadrant and overall floor samples discussed above, samples were
thoroughly homogenized while remaining in the dedicated baggie. Following homogenization
and compositing, samples were transferred into laboratory provided sampling jars and placed on
ice for submittal to the analytical laboratory under chain-of-custody procedure for analysis of
Toxicity Characteristic Leaching Procedure (TCLP) RCRA Metals by EPA Method
6010C/7470A. A copy of the laboratory reports along with the chain of custody is included in
Appendix A.

The lab was instructed to initially run the overall building floor composite samples. If any of the
overall building floor composite samples contained RCRA metals above the RCRA hazardous
waste threshold for arsenic or other metals, the lab was instructed to run the respective quadrant
samples.
Mr. George Fleming, Jr.
December 19, 2012
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S:\AAA-Master Projects\Fleming Labs (FMG)\FMG-001 Arsenic\Building Material Assessment\Building Material Sampling Report.doc
3.0 Results

The overall building composite samples collected from the first floor of Building C (C-1-Comp),
second floor of Building C (C-2-Comp), and first floor of Building D (D-1-Comp) contained
detectable concentrations of arsenic via TCLP analysis. TCLP arsenic concentrations in sample
C-2-Comp (7.9 mg/L) and sample D-1-Comp (16 mg/L) exceeded the RCRA hazardous waste
threshold of 5.0 mg/L for arsenic. Sample C-1-Comp contained a TCLP arsenic concentration of
0.50 mg/L, which is below the RCRA hazardous waste threshold. In addition, the leechate
derived from sample D-1-Comp also contained concentrations of cadmium (0.052 mg/L),
chromium (0.44 mg/L), and lead (0.079), but these TCLP metal concentrations are below their
respective RCRA hazardous waste thresholds. A summary of the results of the overall building
floor composite samples are provided on Table 1.

Based on the data above and the procedure outlined in H&H’s Building Material Sampling Plan,
H&H instructed the laboratory to analyze the quadrant samples associated with samples C-2-
Comp (C-2-Quad 1-Comp, C-2-Quad 2-Comp, C-2-Quad 3-Comp, and C-2-Quad 4-Comp) and
D-1-Comp (D-1-Quad 1-Comp, D-1-Quad 2-Comp, D-1-Quad 3-Comp, and D-1-Quad 4-
Comp). Quadrant samples C-2-Quad 1-Comp and C-2-Quad 2-Comp contained TCLP arsenic
concentrations of 12 mg/L and 5.9 mg/L, respectively, exceeding the RCRA hazardous waste
threshold. TCLP arsenic was also detected in quadrant samples C-2-Quad 3-Comp (2.0 mg/L)
and C-2-Quad 4-Comp (0.80 mg/L), but at levels below the RCRA hazardous waste threshold for
arsenic.

TCLP arsenic concentrations detected in wood floor samples D-1-Quad 1-Comp (15 mg/L), D-1
Quad 2-Comp (20 mg/L), and D-1 Quad 3-Comp (12 mg/L) exceeded the RCRA hazardous
waste threshold for arsenic. The remaining quadrant sample in Building D (D-1-Quad 4-Comp)
contained a TCLP arsenic concentration of 4.6 mg/L, which is slightly below the RCRA
hazardous waste threshold of 5.0 mg/L for arsenic. A low TCLP lead concentrations (0.26
mg/L) was also detected in this sample at a level below its hazardous waste threshold of 5 mg/L.
Mr. George Fleming, Jr.
December 19, 2012
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TCLP chromium concentrations were also detected in samples D-1-Quad 2-Comp (0.75 mg/L)
and D-1-Quad 3-Comp (0.61 mg/L), but at levels below the RCRA hazardous waste threshold of
5.0 mg/L for chromium. Quadrant sample D-1-Quad 2-Comp also contained TCLP cadmium
(0.062 mg/L), but at a level below its RCRA hazardous waste threshold of 1.0 mg/L.

Based on the above data, Quadrants 1 and 2 of the second floor of Building C and Quadrants 1,
2, and 3 of the floor of Building D would be classified as hazardous waste based on leachable
concentrations of arsenic if building demolition is carried out. Quadrant locations and the
estimated floor areas containing TCLP arsenic concentrations above characteristically hazardous
waste thresholds are shown on Figure 1.

4.0 Summary

On October 1, 2012, H&H conducted refined building floor material sampling at Fleming
Laboratories located at 2205-2209 Thrift Rd in Charlotte North Carolina. The first and second
floor of Building C and Building D were each divided into four approximately equal quadrants
(12 total quadrants). Three sample aliquots were collected from each quadrant to form a
quadrant composite sample, and the quadrant samples of each building floor were composited to
form an overall composite sample (3 overall composite samples). Samples from the second floor
of Building C (C-2-Comp) and the first floor of Building D (D-1-Comp) contained TCLP arsenic
concentrations exceeding the RCRA hazardous waste threshold. Following receipt of the overall
composite sample data, the lab was instructed to analyze quadrant composite samples C-2-Comp
and D-1-Comp as a way to isolate which specific quadrants of the buildings were impacted
above the RCRA hazardous waste threshold. TCLP arsenic concentrations in quadrants 1 and 2
of the second floor of Building C and quadrants 1, 2, and 3 of Building D were reported above
the RCRA hazardous waste threshold for arsenic and should be treated as hazardous waste if
demolition is carried out. Other floor areas are considered nonhazardous metal impacted floors
for the purpose of demolition and disposal.

Mr. George Fleming, Jr.
December 19, 2012
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We appreciate the opportunity to provide environmental consulting services. Should you have
any questions or need any additional information, please feel free to contact us.

Sincerely,
Hart & Hickman, PC
Matt Bramblett, PE
Principal
John Lopez
Staff Geologist

Attachments
Table 1 (Page 1 of 1)
Building Floor Characterization Data
Fleming Laboratories
Charlotte, North Carolina
H&H Project No. FMG-001
S:\AAA-Master Projects\Fleming Labs (FMG)\FMG-001 Arsenic\Building Material Assessment\Data Tables
12/19/2012
Table 1 (Page 1 of 1)
Hart & Hickman, PC
Arsenic Cadmium Chromium Lead
Sample ID Date Collected Material Type Building; Floor mg/L mg/L mg/L mg/L
B-1 03/14/12 Concrete Building B; Floor 1 0.42 <0.025 <0.25 <0.050
C-1-Comp 10/01/12 Concrete Building C; Floor 1 0.50 <0.025 <0.25 <0.050
C-2-Comp 10/01/12 Concrete Building C; Floor 2 7.9 <0.025 <0.25 <0.050
D-1-Comp 10/01/12 Concrete Building D; Floor 1 16 0.052 0.44 0.079
E-1 03/14/12 Wood Building E; Floor 1 2.8 <0.025 <0.25 <0.050
C-2-Quad 1-Comp 10/01/12 Concrete Building C; Floor 2 12 <0.025 <0.25 <0.050
C-2-Quad 2-Comp 10/01/12 Concrete Building C; Floor 2 5.9 <0.025 <0.25 <0.050
C-2-Quad 3-Comp 10/01/12 Concrete Building C; Floor 2 2.0 <0.025 <0.25 <0.050
C-2-Quad 4-Comp 10/01/12 Concrete Building C; Floor 2 0.80 <0.025 <0.25 <0.050
D-1-Quad 1-Comp 10/01/12 Wood Building D; Floor 1 15 <0.025 <0.25 <0.050
D-1-Quad 2-Comp 10/01/12 Wood Building D; Floor 1 20 0.062 0.75 <0.050
D-1-Quad 3-Comp 10/01/12 Wood Building D; Floor 1 12 <0.025 0.61 <0.050
D-1-Quad 4-Comp 10/01/12 Wood Building D; Floor 1 4.6 <0.025 <0.25 0.26
RCRA Hazardous Waste Threshold 5.0 1.0 5.0 5.0
Notes:
1) Bold indicates exceedance of RCRA hazardous waste threshold
2) Only constituents detected in at least one sample shown
3) Quadrant samples were analyzed following reported exceedance of respective composite sample
3) TCLP- Toxicity characteristic leaching procedure by EPA Method 6010C/7470A (mg/L)
Quadrant Composite Samples
Overall Composite Samples
APPENDIX A
ANALYTICAL LABORATORY REPORTS
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Appendix B

Health and Safety Plan
Directions to 2001 Vail Ave, Charlotte,NC 28207
3.9 mi – about 12 mins
©2012 Google - Map data ©2012 Google -
Page 1 of 22215 Thrift Rd, Charlotte, NC 28208 to 2001 Vail Ave, Charlotte, NC 28207 - Google M...
9/24/2012https://maps.google.com/maps?f=d&source=s_d&saddr=2215+Thrift+Road,+Charlotte,+N...
These directions are for planning purposes only. You may find that construction projects, traffic, weather, or other events may cause conditions to differ from the map results, and you should plan your route accordingly. You must obey all signs or notices regarding your route.
Map data ©2012 Google
Directions weren't right? Please find your route on maps.google.com and click "Report a problem" at the bottom left.
2215 Thrift Rd, Charlotte, NC 28208
1.Head southeast on Thrift Rd toward Towering Pine Way go 0.2 mi
total 0.2 mi
2.Take the 2nd left onto Rushing Creek Ln go 387 fttotal 0.3 mi
4. Turn left onto Freedom DrAbout 2 mins go 0.2 mitotal 0.6 mi
3. Turn right onto Wesley Village Rd go 443 fttotal 0.4 mi
6.Take the ramp on the left to I-277 N go 0.2 mitotal 1.8 mi
7.Keep left at the fork, follow signs for Bobcats Arena and merge onto I-277 NAbout 50 secs go 0.6 mitotal 2.4 mi
5. Turn left onto W Morehead St
About 3 mins
go 1.0 mi
total 1.6 mi
8. Take the exit toward N Carolina 16 S/E 3rd St go 410 fttotal 2.5 mi
9. Keep left at the fork, follow signs for N Carolina 16 S/Kenilworth Ave/Third St/Fourth St/North Carolina 16 S/Third Street/Fourth Street go 0.4 mitotal 2.9 mi
10.Turn right onto N Carolina 16 S/E 3rd St
About 2 mins
go 0.7 mi
total 3.6 mi
11.Turn left onto S Caswell RdAbout 2 mins go 0.2 mitotal 3.8 mi
12.Slight right onto Vail AveDestination will be on the left go 0.1 mitotal 3.9 mi
2001 Vail Ave, Charlotte, NC 28207
Page 2 of 22215 Thrift Rd, Charlotte, NC 28208 to 2001 Vail Ave, Charlotte, NC 28207 - Google M...
9/24/2012https://maps.google.com/maps?f=d&source=s_d&saddr=2215+Thrift+Road,+Charlotte,+N...