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INITIAL ABATEMENT ACTION REPORT TODDVILLE GARAGE 610 TODDVILLE ROAD CHARLOTTE, MECKLENBURG COUNTY, NORTH CAROLINA 28214 PREPARED FOR: Duke Energy Carolinas, LLC PREPARED BY: WSP USA ENVIRONMENT & INFRASTRUCTURE, INC. 2801 YORKMONT ROAD, SUITE 100 CHARLOTTE, NORTH CAROLINA 28208 June 12, 2023 WSP PROJECT: 7818‐23‐0114 Initial Abatement Action Report – Toddville Garage June 12, 2023 610 Toddville Road, Charlotte, Mecklenburg County, North Carolina 28214 WSP Project: 7818‐23‐0114 i A. SITE INFORMATION 1. Site Identification Date of Report: June 12, 2023 Facility I.D.: Not Applicable UST Incident Number: 48925 Site Risk: Pending Site Name: Toddville Garage Street Address: 610 Toddville Road City: Charlotte Zip Code: 28214 County: Mecklenburg Description of Geographical Data Point: Location of Potential Discharge Location Method: Google Earth Latitude: 35.27735" N Longitude: ‐80.91998" W 2. Information about Contacts Associated with the UST System UST Owner: Duke Energy Carolinas, LLC Address: 525 South Tryon Street, Charlotte, North Carolina 28202 Telephone: 980‐373‐7900 UST Operator: Duke Energy Carolinas, LLC – Toddville Garage (TV01A) Address: P.O. Box 1244, Charlotte, North Carolina 28201 Telephone: 704‐382‐0437 Property Owner: Duke Energy Carolinas, LLC Address: 525 South Tryon Street, Charlotte, North Carolina 28202 Telephone: 800‐653‐5307 Property Occupant: Duke Energy Carolinas, LLC Address: 525 South Tryon Street, Charlotte, North Carolina 28202 Telephone: 800‐653‐5307 Consultant: WSP USA Environment & Infrastructure, Inc. Address: 2801 Yorkmont Road, Suite 100, Charlotte, North Carolina 28208 Telephone: 704‐357‐8600 Analytical Laboratory: NA State Certification No.: NA Address: NA Telephone: NA 3. Information about Release Date Discovered: March 7, 2023 Estimated Quantity of Release: Unknown Cause of Release: Unknown Source of Release: Underground piping Sizes and Contents of Tanks or Other Containment from which Release Occurred: Used motor oil Initial Abatement Action Report – Toddville Garage June 12, 2023 610 Toddville Road, Charlotte, Mecklenburg County, North Carolina 28214 WSP Project: 7818‐23‐0114 3 B. EXECUTIVE SUMMARY The Toddville Garage (the Garage) is on a portion of a 115‐acre site, Mecklenburg County Tax Parcel 057‐15‐109, (the Site) and is located in a mixed‐use area of Charlotte, North Carolina. The Site is occupied by various buildings, including the Garage, and staging areas of various materials and equipment. On March 7, 2023, what appeared to be used motor oil was observed leaking from the ground into an oil‐change pit within the Garage. Duke submitted the 24‐ Hour Notification of Discharge Form UST‐62 to Mooresville District office of the North Carolina Department of Environmental Quality (NCDEQ), Underground Storage Tank (UST) Section on March 7, 2023. Initial abatement response activities conducted in March 2023 included an inspection of the existing oil disposal system which consists of below ground piping from the Garage to a 1,000 gallon UST for used oil containment and inspection of the former (no longer in use) underground oil water separator (OWS) located to the east of the Garage, between the in‐use used oil UST (used oil UST) and the Garage. The OWS was found to contain used oil and water. On March 9, 2023, some used oil and water was vacuumed from the OWS, and the service drains located inside the Garage were inspected for continuity to the used oil UST. One drain, that was believed to lead to the used oil UST, did not have observable continuity to the used oil UST and was closed off with a plug and covered with a floor plate. On May 22 and 23, 2023, WSP USA Environment & Infrastructure, Inc. (WSP) conducted preliminary investigation activities to evaluate the source of used oil in the subsurface. WSP contracted with HAZMAT Environmental Services (HAZMAT) to perform vacuum extraction and cleaning of the OWS and Glenn Industrial to conduct a camera survey of the OWS. On May 22, 2023, approximately 370 gallons of used oil and water were removed from the OWS. On May 23, 2023, the OWS was visually inspected via remote operated vehicle outfitted with a camera. Three separate cells were observed as was the piping into the OWS and the piping from cell to cell within the OWS. Continuity amongst various site drains and pipes and the OWS or the used oil UST was also evaluated on May 23, 2023. Continuity from an exterior pipe cleanout was confirmed to cell one of the OWS. Continuity was not confirmed to either the OWS, the exterior pipe cleanout, or the used oil UST from the covered and plugged interior floor drain. It is presumed that the floor drain, from which continuity could not be confirmed, the exterior pipe cleanout, and the OWS were historically connected. However, based on field observations, discussions with site personnel, and review of limited construction drawings, it is suspected that the buried pipe between the floor drain and the pipe cleanout and OWS became disconnected (or deteriorated) below the ground surface. It is presumed that this floor drain remained in service after the buried pipe became damaged and the buried pipe, which is damaged, is the source of the used oil in the subsurface. Based on the site observations, and the Site use, size, and location, WSP recommends installation of one groundwater monitoring well down gradient of the area of potential impacts, to the east/southeast of the Garage, between the OWS and the suspect floor drain to assess the static water level and potential petroleum free product accumulation on the water table. Further it is recommended to sample the groundwater, if petroleum free product Initial Abatement Action Report – Toddville Garage June 12, 2023 610 Toddville Road, Charlotte, Mecklenburg County, North Carolina 28214 WSP Project: 7818‐23‐0114 4 is not present, to determine the risk level of the Site and to sample the soil in this location during the monitoring well installation activities. The findings of the soil and groundwater assessment activities will be submitted to NCDEQ in a Limited Site Assessment Report by July 31, 2023. Initial Abatement Action Report – Toddville Garage June 12, 2023 610 Toddville Road, Charlotte, Mecklenburg County, North Carolina 28214 WSP Project: 7818‐23‐0114 5 C. TABLE OF CONTENTS A. SITE INFORMATION ............................................................................................................... i 1. Site Identification .............................................................................................................................................. i 2. Information about Contacts Associated with the UST System ........................................................................ i 3. Information about Release ............................................................................................................................... i 4. Certification ...................................................................................................................................................... ii B. EXECUTIVE SUMMARY .......................................................................................................... 3 C. TABLE OF CONTENTS ............................................................................................................. 5 D. SITE HISTORY AND CHARACTERIZATION ................................................................................. 6 1. Owner/Operator Information .......................................................................................................................... 6 2. Description of the Release ............................................................................................................................... 6 3. Description of Site Characteristics ................................................................................................................... 6 E. INITIAL RESPONSE AND ABATEMENT ACTION ......................................................................... 8 1. Oil Waste Removal and Cleaning ..................................................................................................................... 8 F. CONCLUSIONS AND RECOMMENDATIONS ........................................................................... 10 FIGURES Figure 1 Site Topographic Map Figure 2 Site Features Figure 3 Well Survey Map Figure 4 Oil Water Separator Plan View Figure 5 Oil Water Separator Profile View TABLE Table 1 Site History – System Owner/Operator and Other Responsible Party Information APPENDICES Appendix A Disposal Manifest Appendix B Photographs of Investigation Activities Initial Abatement Action Report – Toddville Garage June 12, 2023 610 Toddville Road, Charlotte, Mecklenburg County, North Carolina 28214 WSP Project: 7818‐23‐0114 6 D. SITE HISTORY AND CHARACTERIZATION 1. Owner/Operator Information Ownership and operator information is provided in Table 1. At the time of this report, and the presumed time of the discharge, Duke Energy Carolinas, LLC (Duke Energy) was the Site owner. 2. Description of the Release On March 7, 2023, Duke Energy observed, what appeared to be used oil leaking from the ground in an oil‐change pit within the Toddville Garage (the Garage). 3. Description of Site Characteristics The Garage is on a portion of a 115‐acre site, Mecklenburg County Tax Parcel 057‐15‐109, and is located in a mixed‐use area of Charlotte, North Carolina. The Site is occupied by various buildings, including the Garage, gravel parking lots and staging areas for various materials and equipment. A Topographic Map is included as Figure 1 and a Site map depicting the site overview is shown on Figure 2. The oil‐change pit, where the oil was observed seeping along the wall at the base, is a subsurface pit located in the northern portion of the Garage. Approximately 40 feet to the southeast of the oil‐change pit and exteriorly adjacent to the Garage is a subsurface OWS that is in place, but no longer in use (retired). The date of retirement is unknown. Immediately to the east of the OWS is the in‐use used oil UST. Used oil generated during servicing of fleet vehicles at the Garage is currently discharged through buried piping connected to the 1,000‐gallon used oil UST. The Site is located within the Charlotte Belt of the Piedmont Physiographic Province consisting of low rounded hills and long rolling northeast to the southwest trending ridges with incised creek channels. Based on a review of the North Carolina Geologic Map, the Site is underlain mostly by massive well foliated quartzite rock while the southeastern corner of the Site is underlain by metamorphosed quart diorite. The United States Department of Agriculture (USDA) ‐ Natural Resources Conservation Service (NRCS) Web Soil Survey and Soil Survey of Mecklenburg County indicates the soils beneath the Site are mapped mostly as Urban Land (Ur) with some minor Monacan loam (MO) and lesser amounts of the Cecil sandy clay loam (CeB2, CeD2), and Helena sandy loam (EnD) mostly around the perimeter of the Site. Urban land is classified as impervious layers over human transported material while the Monacan loam (mapped near the creek) is a floodplain deposit that is comprised of loamy alluvium derived from igneous and metamorphic rock and is somewhat poorly draining. WSP examined the 7.5‐minute Mountain Island Lake, North Carolina, United States Geological Survey (USGS) quadrangle, published in 2019. Review of the available topographic data indicates that the Site ranges from approximately 740 to 810 feet above mean sea level (msl), with the elevation at the location of the UST at about Initial Abatement Action Report – Toddville Garage June 12, 2023 610 Toddville Road, Charlotte, Mecklenburg County, North Carolina 28214 WSP Project: 7818‐23‐0114 7 780 feet msl. The topography of the subject property is generally sloping toward the south‐southwest and west towards an unnamed tributary to Paw Creek. Groundwater monitoring wells were previously installed at the Site between 1991 and 2017 to assess petroleum groundwater impacts related to a petroleum release incident (#24555). The general direction of groundwater flow can be inferred from groundwater monitoring well data obtained from those previously installed monitoring wells located 150 to 700 feet to the west and southwest of the Garage. Based on the review of this data the groundwater flow direction appears to be generally to the south/southwest. A Notice of Residual Petroleum was executed for the Toddville Garage Site on June 25, 2018 in association with incident #24555 and the groundwater monitoring wells have been abandoned. WSP reviewed the Mecklenburg County Well Information System 4.0 for water‐supply wells located in the area surrounding the Site. Figure 3 presents the results of the desktop well survey. Reportedly, an active private supply well is located at 6518 Craig Street and is approximately 1,450‐feet up gradient to the northeast of the area of presumed discharge. No other active water‐supply wells were identified within a 1,500‐foot radius of the Garage. Initial Abatement Action Report – Toddville Garage June 12, 2023 610 Toddville Road, Charlotte, Mecklenburg County, North Carolina 28214 WSP Project: 7818‐23‐0114 8 E. INITIAL RESPONSE AND ABATEMENT ACTION Initial abatement response activities conducted in March 2023 included an inspection of the existing oil disposal system which consists of below ground piping from the Garage to a 1,000 gallon UST for used oil containment and inspection of the retired underground OWS located to the east of the Garage, between the in‐use used oil UST and the Garage. The OWS was found to contain used oil and water. On March 9, 2023, some used oil and water was vacuumed from the OWS, and the service drains located inside the Garage were inspected for continuity to the used oil UST. One floor drain located along the eastern wall of the Garage (Figure 2), that was believed to connect to the used oil UST, did not have observable continuity to the used oil UST and was closed off with a plug and covered with a floor plate. On May 22 and 23, 2023, WSP mobilized to the Site to conducted preliminary investigation activities to evaluate the source of the used oil in the subsurface. WSP contracted with HAZMAT to perform vacuum extraction and cleaning of the OWS and Glenn Industrial to conduct camera survey of the OWS. 1. Oil Waste Removal and Cleaning On May 22, 2023, HAZMAT and WSP personnel mobilized to the Site to observe the OWS, to remove the used oil and water, and to clean the interior of the OWS. The manhole covers were removed from each of the OWS entry points and used oil and water was observed in each of the three OWS cells. Starting with the northern cell and progressing south, the used oil and water mixture was extracted with a vacuum truck. Each cell was then power washed, and the wash water was extracted via vacuum truck. Approximately 370 gallons of used oil and water (i.e., petroleum contact water) were removed from the OWS, including the power washing water. The used oil and petroleum contact water was subsequently transported to HAZMAT’s disposal facility located at 210 Dalton Avenue in Charlotte North Carolina, 28206. Disposal manifests are included as Appendix A. 2. OWS Observations and Continuity Investigation On May 23, 2023, the OWS was visually inspected via remote operated vehicle outfitted with a camera. As shown on Figures 4 and Figure 5, the OWS consists of three cells that are approximately 70 to 92 inches below ground, and each is accessed by a 44‐inch‐wide manhole structure. The first, or northern, cell is approximately cube‐ shaped and is about 48 inches by 48 inches and 51 inches tall. A baffle was observed in the middle of the northern cell that is approximately 30 inches tall and cuts the cell into a northern and southern half. Two pipes were observed penetrating through the northern wall of the northern cell. The first is an inlet pipe located in the upper northwest corner that was not plugged, and the second is a pipe observed entering through the middle of the wall that was plugged. Continuity between the first pipe and a pipe clean out was confirmed. The second pipe is presumed to be an oil skimmer pipe constructed with two upturned inlets on either side of the baffle (see Figure 4 and Figure 5). Both inlets were found to be capped. The second cell, or middle cell, is also approximately 48 inches by 48 inches and is approximately 34 inches tall. An outlet pipe was observed at the base of the second cell leading to the third or southern cell. The southern cell consists of a 44‐inch‐wide manhole structure that terminated approximately 92 inches below grade and an 18‐inch diameter and 29‐inch deep sump was located at the base. A Initial Abatement Action Report – Toddville Garage June 12, 2023 610 Toddville Road, Charlotte, Mecklenburg County, North Carolina 28214 WSP Project: 7818‐23‐0114 9 vent pipe was observed at the top of the western wall of the southern cell. A non‐functional pump was observed in the sump. Continuity amongst various drains and cleanouts at the Garage and the OWS or the used oil UST was evaluated. An exterior pipe clean out was observed to the north of the OWS, the cleanout cover was removed and approximately 10 gallons of water was sprayed into the cleanout. The water was observed discharging into the northern cell of the OWS through the inlet pipe located in the upper northwest corner (the northern cell inlet pipe that was not plugged). To further evaluate continuity, the plug was removed from the floor drain located along the eastern wall of the Garage, that was closed off with a plug and covered with a floor plate. Approximately 25 gallons of water was sprayed into the interior floor drain. Continuity between it and an adjacent exterior pipe clean out, the OWS, or used oil UST could not be confirmed as the water was not observed at any of these structures. After the continuity was tested the pipe clean out cover and the floor drain plug and floor plate were replaced. Appendix B includes a photo log of Site features observed during the investigation activities. Initial Abatement Action Report – Toddville Garage June 12, 2023 610 Toddville Road, Charlotte, Mecklenburg County, North Carolina 28214 WSP Project: 7818‐23‐0114 10 F. CONCLUSIONS AND RECOMMENDATIONS On May 22 and 23, 2023, WSP conducted preliminary investigation activities to evaluate the source of used oil in the subsurface. Used oil and water were extracted from the OWS, then power washed before visually inspecting it via remote operated vehicle outfitted with a camera. Three separate cells were observed as was the piping into the OWS and the piping from cell to cell. Finally, continuity amongst various drains and cleanouts and the OWS or the used oil UST was evaluated. Continuity from an exterior pipe cleanout to the OWS was confirmed. Continuity was not confirmed to either the pipe cleanout, the OWS, or the used oil UST from the floor drain located along the eastern wall of the Garage, that was closed off with a plug and covered with a floor plate. It is presumed that the floor drain, from which continuity could not be confirmed, the exterior pipe cleanout, and the OWS were historically connected. However, based on field observations, discussions with site personnel, and review of limited construction drawings, it is suspected that the buried pipe between the floor drain and the pipe cleanout and OWS became disconnected (or deteriorated) below the ground surface. It is presumed that this floor drain remained in service after the buried pipe became damaged and the buried pipe, which is damaged, is the source of the used oil in the subsurface. Based on the site observations and the Site use, size, and location, WSP recommends installation of one groundwater monitoring well down gradient of the area of potential impacts, to the east southeast of the Garage, between the OWS and the suspect floor drain, in the approximate location shown on Figure 2. This monitoring well will be used to assess the static water level and potential petroleum free product accumulation on the water table. Further it is recommended to sample the groundwater, if petroleum free product is not present, to determine the risk level of the site and to sample the soil in this location during the monitoring well installation activities. The findings of the soil and groundwater assessment activities will be submitted to NCDEQ in a Limited Site Assessment Report by July 31, 2023. FIGURES PREPARED BY: DATE: CHECKED BY: DATE:Document Path: \\clt1-fs1\projects\7818 Duke EEOC\Projects\2023\7818-23-0114- Toddville Garage\13 GIS\Working_Data\Toddville_Garage\Toddville_Garage.aprxPROJECT NO:7818-23-0114 KNS 6/6/2023 CC 6/6/2023 FIGURE: 1WSP USAEnvironment & Infrastructure Inc. Copyright:© 2013 National Geographic Society, i-cubed0 1,000 2,000Feet ¯ Legend Subject Property The Garage SITE TOPOGRAPHIC MAP Toddville Garage 610 Toddville Road Charlotte, North Carolina ¯ 0 4020 Feet Note: This map is for reference only. Features depicted are approximations. Legend Title:Date: Project No: Drawn by: KNS - Checked by: CC - Date: 6/7/2023 Projection:WSP USA Environment & Infrastructure Inc. 2801 Yorkmont Road, Suite 100 Charlotte, NC 28208 (704) 357-8600 Maxar, Microsoft, Copyright:© 2013 National Geographic Society, i-cubed, NC CGIA, Maxar, Microsoft 2021 Manhole Interior Floor Drain Exterior Pipe Clean Out !A Proposed Monitoring Well Location Oil Change Pit Oil-Water Separator Underground Storage Tank File: Figure:6/7/2023 7818-23-0114 2NC State Plane (NAD83, feet) H:\7818 Duke EEOC\Projects\2023\7818-23-0114- ToddvilleGarage\13 GIS\Working_Data\Toddville_Garage\Toddville_Garage.aprx SITE FEATURES Toddville Garage 610 Toddville Road Charlotte, North Carolina !A ¯ 0 500250 Feet Note: This map is for reference only. Features depicted are approximations. Groundwater flow direction obtained from historical assessment report (Incident #24555) Title:Date: Project No: Drawn by: KNS - Checked by: CC - Date: 6/7/2023 Projection:WSP USA Environment & Infrastructure Inc. 2801 Yorkmont Road, Suite 100 Charlotte, NC 28208 (704) 357-8600 Esri, HERE, Garmin, FAO, NOAA, USGS, EPA, Maxar 2021 Legend ?Active Private Well ?Inactive Private Well 500 ft Buffer 1,000 ft Buffer 1,500 ft Buffer Garage Subject Property Parcels Groundwater Flow Direction File: Figure:6/7/2023 7818-23-0114 3NC State Plane (NAD83, feet) H:\7818 Duke EEOC\Projects\2023\7818-23-0114- ToddvilleGarage\13 GIS\Working_Data\Toddville_Garage\Toddville_Garage.aprx WELL SURVEY MAP Toddville Garage 610 Toddville Road Charlotte, North Carolina???????????????????????????????????????????????????????????????????????????1 2 3 4 1.310 GLENHAVEN DRIVE PARCEL ID 057-16-301 2.300 GLENHAVEN DRIVE PARCEL ID 057-16-302 3.6620 CRAIG STREET PARCEL ID 057-16-208 4.6518 CRAIG STREET PARCEL ID 057-16-116 WATER SUPPLY WELLS WITHIN 1,500 FT SEARCH RADIUS REVIEWED BY: SCALE: HORIZONTAL DATUM: VERTICAL DATUM: DRAWN BY:C. Case NA NA CLIENT LOGO: Not to Scale NOTES: PROJECT No:04FIGURE No.: 7818-23-0114 06/02/2023 DATE: NOT TO SCALE Duke Energy of the CarolinasToddville Garage- Oil Water SeparatorPlan View 610 Toddville RoadCharlotte, NC 28214S. Damasceno REVIEWED BY: SCALE: HORIZONTAL DATUM: VERTICAL DATUM: DRAWN BY: S. Damasceno C. Case NA NA CLIENT LOGO:Duke Energy of the Carolinas Toddville Garage- Oil Water SeparatorProfile View610 Toddville Road Charlotte, NC 28214 Not to Scale NOTES:NOT TO SCALE PROJECT No:05FIGURE No.: 7818-23-0114 06/02/2023 DATE: TABLE Table 1: Site History –System Owner/Operator and Other Responsible Party Information UST ID Number N/A Facility ID Number N/A Name of Property Owner Dates of Ownership Duke Energy Carolinas, LLC 1954 to present Street Address 610 Toddville Road City State Zip Telephone Number Charlotte NC 28214 800‐653‐5307 Name of UST Owner/Operator Dates of Operation Duke Energy Carolinas, LLC Unknown Street Address 525 South Tryon Street City State Zip Telephone Number Charlotte NC 28202 704‐382‐0437 Incident Number 48925 APPENDIX A Disposal Manifest APPENDIX B Photographs of Investigation Activities Toddville Garage Investigation Activitites Photograph Log Date Photographs Taken: May 22 and 23, 2023 Photograph 1 Oil Water Separator (OWS) Manhole Covers Photograph 2 North Cell of OWS Toddville Garage Investigation Activitites Photograph Log Date Photographs Taken: May 22 and 23, 2023 Photograph 3 Middle Cell of OWS Photograph 4: Southern Cell of OWS Toddville Garage Investigation Activitites Photograph Log Date Photographs Taken: May 22 and 23, 2023 Photograph 5: Interior Floor Drain‐ Capped and Plugged Photograph 6: Vent lines that lead to cell three of the OWS Toddville Garage Investigation Activitites Photograph Log Date Photographs Taken: May 22 and 23, 2023 Photograph 7: Oil change pit and current oil disposal piping connected to the used oil UST.