20050 Rite Aid Dec Memo 20170821

DECISION MEMORANDUM
DATE: August 21, 2017
FROM: Carolyn Minnich, Caroline Goodwin

TO: Tracy Wahl, Sandra Mort

RE: Rite Aid (RN) 1776 Statesville Ave (Rite Aid)
1701-1795 North Graham Street (MV Graham)
Charlotte, Mecklenburg County
BF # 20050-16-060
Based on the following information, it has been determined that the above referenced site, whose intended use
is for no uses other than redevelop the Brownfields Property for office, industrial, retail, high-density residential,
restaurant, parking, entertainment, hotel, primary or secondary educational space, storage unit, amenity space,
recreation, institutional, transit and subject to DEQ’s prior written approval, other commercial uses, can be made
suitable for such uses. The plat map has approved areas for high density residential use. The remaining areas would require DEQ approval.

Introduction:

The Brownfields Property is approximately 47.87 acres and includes three (3) parcels: 1776 Statesville Ave and 1701-1795 North Graham Street (Mecklenburg County Tax Parcel Identification Numbers “PIN” 07903102,
07903105, and 07903103). This project is adjacent to the Hercules Industrial property (the subject of NC
Brownfields Project Number 11044-07-060, BF Project Name CAMP)

Historical uses on the Brownfields Property include manufacturing of Model T Ford, storage depot for United States Government for the production of Hercules missiles also known as the Charlotte Army Missile Plant
(“CAMP”). Most recently, the Brownfields Property was used by Eckerd/Rite Aid for warehousing and
distribution of commercial/retail items and by Greif Bros. Corporation, a manufacturer of corrugated paper
containers, for storage by various entities including Pax Industries, a shipping/transportation operation, and by a
wood pallet manufacturer. The Brownfields Property is surrounded by land in commerical and industrial use. Soil and groundwater are contaminated at the Brownfields Property due to historical operations and activities.
The US Army Corps of Engineers (“COE”) on behalf of the United States Department of Defense (“DOD”) is
working with DEQ to address impacts related to CAMP operations and use of the Brownfields Property.

Redevelopment Plans: This project is located in an urban setting within the city limits of Charlotte. The list of allowable uses is long,
but given the size and location of the Brownfield Property, the Prospective Developer (“PD”) stated it was
necessary. Redevelopment includes: office, commercial, industrial, retail, high-density residential, restaurant,
parking, entertainment, hotel, primary or secondary educational space, storage unit, amenity space, recreation,
institutional, transit.
The PD also owns the adjacent Hercules Industrial Business Park (aka CAMP BF Property). Per conversations
with PD and the draft EMP, the commercial zones will be in the central portions of the Brownfields Property and
the residential will be in the NE and SW portions of the Brownfields Property. PD is also petitioning the City of
Charlotte for additional roadways and Norfolk Southern for crossing on railroad to allow for better connectivity. The following is overview of the entire Brownfields Property with development plans. Note, redevelopment
plans include both Rite Aid and CAMP Brownfields Projects.
Figure 1

Site History:
1776 Statesville Avenue parcel is known as the “Rite Aid” property and is approximately 37 acres (PINs
07903105 & 07903102) This property was initially developed in 1924 and has been used for industiral use since
then. Prior operations included manufacture of Model T Fords until approximately the 1930s. In the early-1940s to the mid-1950s, the Brownfields Property was used as a storage depot for the United States
Government. In the mid-1950s to the late-1960, began the production of Hercules missiles. The missile
production facility was refered to as CAMP and include adjacent parcels not included in this Agreement. Since
the late 1960s, the Rite Aid property has been used by Eckerd/Rite Aid for warehousing and distribution of
commercial/retail items. In 2016, Rite Aid vacated the property.
The Brownfields Property is developed with nine buildings. They are slab on grade construction, except for the
Boiler House Buildling which has a walk out basement.
Building Size (~sq ft) Former Use
Building 1 241,212 Rite Aid warehouse for storage, shipping offices CAMP die casting, metal plating, and cleaning
Building 2 193,862 Rite Aid warehouse for storage, shipping, offices CAMP machine shop and process plant
Buliding 3 144,658 Rite Aid storage and shipping
CAMP storage and offices
Building 48 17,154 Rite Aid storage of shelving and equipment
CAMP garage for emergency response vehicles
and for automotive maintenance
Building 50 3,280 Rite Aid vacant
CAMP chemical storage and solvent receiving and distribution
Boiler House 4,347 Rite Aid vacant, no known use CAMP, boiler house for generation of steam
Regional Training/
Office Building
12,917 Rite Aid office spaceand training rooms
T-26 4,846 Rite Aid office space
Warehouse Building 170,000 Warehouse storage, wooden pallets, plastic pellets
CAMP warehouse storage

1701-1795 North Graham Street Parcel is known as the “MV Graham” property and is approximately 12.5 acres
(PIN 07903103). Historical uses include storage by the US Army beginning in the 1940s. From the 1950s to
the late 1960s, the property was part of the CAMP which manufactured missile components for the Department of Defense. Since the 1960s. the MV Graham property was occupied by Greif Bros. Corporation (a manufacturer of corrugated paper containers), for storage by various entities including Pax Industries
(shipping/transportation), and by a wood pallet manufacturer. The MV Graham property is currently vacant.

Remedial Actions associated with the project. DEQ UST LUST Facility ID 0-013231, 20520, 7617 Eckerd Charlotte Distribution. EPA RCRA SQS EPA ID NCD986177608, Rite Aid Distribution
EPA FINDS 110054366155 and 110004041377
EPA FUDS Site 104NC04585
Potential Receptors:
Potential receptors are: construction workers, on-site workers, future residences, visitors, animals (personal
pets), and trespassers.

Contaminated Media:
In 1996, the COE requested access to the Brownfields Property to investigate and begin certain remedial
activities on behalf of the DOD. Groundwater and soil impacts were identified due to operations during
ownership of the government. DEQ Superfund Program has been working with COE during the assessment phases.
DEQ Brownfields Program has evaluated data collected from the following media at the subject property:
groundwater, soil, and vapor. DEQ relies on the following data to base its conclusions regarding the subject
property and its suitability for its intended reuse.

Soil
The plat map will have restriction soil areas denoted as “Area of Potential Soil Contamination”. These areas are
based on the following impacted areas:

Building 1 and 2, Former Chrome Plating Operations (Rite Aid Property) – hexavalent chromium and total
chromium were discovered adjacent to a former plating pit located in Building 1 in concentrations that exceed
the S-2 cleanup level of 2,000 mg/kg in which DEQ has established in draft guidance to address
industrial/commercial exposures. In 2005, soil samples collected from the base of access to the former piping
pit of the electroplating process in the western portion of Building 1 reported hexavalent chromium (7949 mg/kg) and total chromium (80,000 mg/kg). Subsequent Toxicity Characteristic Leaching Procedure (TCLP)
testing determined the samples to be a hazardous waste. Historical plating and degreasing activities have also
occurred in Building 2.
On May 6, 2016, ten (10) soil borings were advanced within the vicinity of the former electroplating and
degreasing pits in Building 1 and 9 soil borings within the vicinity of the former electroplating and degreasing pits in Building 2 to evaluate subsurface conditions for a release of solvent or chromic acid. In Building 1, ten
(10) soil borings (SB-22 through 31) were advanced approximately 15 ft below the ground surface. In Building
2, nine (9) soil borings (SB-1 through SB-9) were advanced approximately 15 ft below the ground surface. In
Building 1, analytical results from the soil sampling indicated that hexavalent chromium and TCE impacts in
the soil were present above Inactive Hazardous Site Branch (IHSB) industrial Preliminary Soil Remediation Goals (PSRGs). In Building 2, analytical results indicated that TCE impacts in the soil were present above
industrial PSRGs. No hexavalent chromium was identified in the soil borings collected from Building 2.
West of Building 1 (Rite Aid Property) – On March 24, 2016, a soil boring (SB-8) was advanced west of the
former electroplating pit in Building 1 in a grassy area outside of the building. The soil boring was advanced to
approximately 10 ft below ground surface. Field screening detected elevated Photo Ionization Detector (PID) readings of 367 ppm and visual staining and mild petroleum odor was observed in the 8’ to 10’ interval.
Analytical results determined that semi-volatile organic compound (SVOC) impacts were detected above the
IHSB residential screening criteria for benzo(a)pyrene (0.571 mg/kg) and benzo(b)fluoranthene (0.216 mg/kg).
IHSB protection of groundwater (POG) exceedances included 1-methylnaphthalene (2.81 mg/kg), 2-
methylnaphthalene (4.41 mg/kg), and naphthalene (0.755 mg/kg). The source of the contamination has not been identified.
Historical Automotive Maintenance Building 48 (Rite Aid Property) – a former in-ground hydraulic lift and oil
change pit in Building 48 that was depicted on an original construction drawing provided by Rite Aid. The in-
ground lift and oil change pit have been abandoned by filling the voids with concrete and fill material. Four (4)
soil borings (SB-10 through SB-13) were advanced to approximately 15 ft below ground surface within the vicinity of the former in-ground lift and oil change pit to evaluate subsurface conditions for a release of
hydraulic oil and other petroleum products. Analytical results indicate TCE impacts above IHSB POG and the
soil to water Maximum Soil Contaminant Concentration (MSCC) in the soil sample SB-10 collected adjacent to
the former oil change pit.
UST Basin West of Building 48 (Rite Aid Property) – a previously unknown underground storage tank (UST)
basin containing eight (8) unregistered USTs presumed to have contained fuel oil was discovered during a
subsurface investigation utilizing ground penetrating radar (GPR). The USTs were identified adjacent to the
southwestern corner of Building 48. The presence of fuel oil or other petroleum products remaining in the USTs could not be confirmed due to a lack of accessible fill ports.
On May, 2016, eight (8) soil borings (SB-14 through SB-21) were advanced to approximately 15 ft below
ground surface within the vicinity of the UST basin to evaluate subsurface conditions for a release of petroleum
products. SB-18 was converted into a temporary monitor well (TMW-1) and a groundwater sample was
collected to determine if a petroleum release from the USTs has infiltrated the downgradient shallow aquafer. Analytical results indicated that soil impacts for volatile organic compounds (VOCs) were detected above
residential PSRGs and DEQ MSCC standards. A groundwater sample collected from TMW-1 indicated that
benzene was detected above the DEQ 2L Standard.
Background Soil Samples (MV Graham and Rite Aid Properties) -Concentrations of poly-nuclear aromatic
hydrocarbons (PAHs) and the metals arsenic and thallium were detected above Residential PSRGs but are consistent with typical background levels in six (6) shallow soil samples collected at the MV Graham portion of
the BF property and five shallow soil samples at the Rite Aid portion of the BF property at depths of 0 to 2 ft
bgs. Concentrations of hexavalent chromium and lead were detected above Residential PSRGs and background
levels in sample SSB-10 located east of the Boiler House and near the water tower. In addition, hexavalent
chromium was detected above the Residential PSRG in sample SSB-1 located south of the MV Graham building, but hexavalent chromium was not detected in the duplicate of this sample. The hexavalent chromium
and lead concentrations in these samples did not exceed Industrial/Commercial PSRGs.

Groundwater
Solvent Impacts in Groundwater (Rite Aid Property) - The COE concluded that groundwater contamination from the chlorinated solvent trichloroethylene (TCE) and its degradation products originated from historical
governmental operations conducted at the site. The primary source area for groundwater impacts has been
determined to originate on the eastern end of Building 2. Electroplating and degreasing operations were
situated in the eastern end of Building 2. In the most recent sampling conducted in 2012, the highest
concentration of TCE was 14,000 µg/l was detected off the east side of Building 2 versus the DEQ 15A NCAC 02L.0202 Groundwater Standard (2L Standard) of 3 µg/l. The approximate extent of groundwater impacts on
the Rite Aid property currently extends beneath Buildings 1, 2, 48, and T-26. In 2005 and 2006 the COE
preformed pilot tests for a planned chemical oxidation injection. The COE is in the process of addressing DEQ
and stakeholder comments associated with the planned remediation activities.
The site storm drain network has an under-drain system that depresses the water table which allows TCE to enter the storm drain system. Based on groundwater elevations collected during remedial investigations of the
site, it appears that portions of the storm drain piping are well below the water table. Samples collected from
the storm drain outfall located near Statesville Ave and Woodward Ave that indicated sustained levels of TCE
below the state TCE criteria of 120 µg/L established in 15 NCAC 02b. Stormwater exiting the outfall was
likely diluted from additional water entering the system and cited a previous sampling event where a stormwater sample collected from the manhole cover (MH 26) on the Rite Aid site contained TCE at a concentration of 310
µg/L.

Surface Water
Surface water is not located on the site.

Soil Vapor
Due to high concentrations of chlorinated solvents in groundwater, the potential for vapor intrusion was
investigated with soil gas, sub-slab and indoor air sampling on the Brownfields Property.

Sub-Slab Vapor
In April 2016, twelve (12) sub-slab soil vapor sampling points (SSV-1 through SSV-12) to evaluate the
possibility for vapor intrusion based on the previously delineated extent of TCE groundwater impacts.
Analytical results from the sub-slab soil vapor testing indicate that TCE was detected above were NC DWM Vapor Intrusion Screening Criteria (DWM VISL) for both non-residential and residential screening criteria in
Buildings 1, and 2 and above residential screening criteria in Building 48. Chloroform was detected in Building
1 above DWM VISL for both non-residential and residential screening criteria and PCE was detected above
residential screening criteria.
Sub-slab Sampling (MV Graham Property) - Four (4) sub-slab vapor samples (MVSSV-1 through MVSSV-4) were collected from within the MV Graham property building, and one soil gas sample (MVSSV-5) was
collected outside and north of this building. Acrolein was detected above the Residential SGSLs but below the
Non-Residential SGSL in the sub-slab samples collected below the MV Graham property building. Results of
cumulative risk calculations indicate that an HI of 1 was exceeded for the residential exposure scenario. A
second round of sub-slab samples is schedule for Summer of 2017.
Indoor Air
The results of the analysis of the indoor air samples collected in 2008 indicated compound concentrations above
current Department of Waste Management (DMW) Indoor Air Screening Levels (IASLs) in samples collected
in January 2008 from Building 1 and Building 48. The compounds detected above IASLs were TCE and
tetrachloroethylene (PCE). PCE and TCE were not detected above IASLs in indoor air samples collected in September of 2008.

Indoor Air (IA) Sampling (Rite Aid Property) - In June, September and December 2016, IA sampling events
were conducted to evaluate the potential for vapor intrusion in Buildings 1, 2, 48, and the former Boiler House
due to the presence of chlorinated solvent groundwater impacts at the Rite Aid Facility. The data indicates that samples collected from the central and northern portions of Building 1 contained concentrations of TCE above
the DEQ residential and non-residential IASLs. TCE was not detected above the residential IASL in the
southern portion of Building 1, or in Buildings 2, 48, and the former Boiler House.
In January 2008, acrolein was included in the list of detected compounds during vapor sampling. It was detected
above DMW IASL in the building and background samples in 21 of the 23 samples. Then in the March 2009 Indoor Air Quality Assessment Report prepared by AMEC, they stated the following “Acrolein is a ubiquitous
contaminant of indoor and outdoor air due to its presence in combustion emission of all sorts, including
cigarette smoke, vehicle emissions, power plant emissions, and emission from home heating and cooking
sources. Accordingly, the acrolein is not a site related constituent.” The Brownfields Property is in an urban,
industrial area of Charlotte. Acrolein was not detected in groundwater, soil, or soil vapor on the Rite Aid Property. Acrolein was detected with J flags on the MV Graham property in November 2016. A second round
of sampling is scheduled for Summer of 2017.

The following is background on acrolein.
Acrolein (systematic name: propenal) is the simplest unsaturated aldehyde. It is a colourless liquid with a piercing,
disagreeable, acrid smell. The smell of burnt fat (as when cooking oil is heated to its smoke point) is caused
by glycerol in the burning fat breaking down into acrolein. It is produced industrially from propylene and mainly used as a biocide and a building block to other chemical compounds, such as the amino acid methionine.
Health Risks: Acrolein is toxic and is a strong irritant for the skin, eyes, and nasal passages.[4] The main metabolic
pathway for acrolein is the alkylation of glutathione. The WHO suggests a "tolerable oral acrolein intake" of
7.5 μg/day per kilogram of body weight. Although acrolein occurs in French fries, the levels are only a few
micrograms per kilogram.[8] In response to occupational exposures to acrolein, the US Occupational Safety and
Health Administration has set a permissible exposure limit at 0.1 ppm (0.25 mg/m3) at an eight-hour time-weighted
average.[9]
Acrolein was not included in the risk calculators. It is not considered an environmental impact from historical operations on the Brownfields Property.
The following is a summary of correspondence on this issue most recent at the top:

-----Original Message-----
From: Livermore, Raymond R CIV USARMY CESAW (US) [mailto:[e-mail]]
Sent: Monday, March 27, 2017 3:55 PM
To: Rumford, Doug <[e-mail]>; Minnich, Carolyn <[e-mail]>
Cc: Thompson, Dena B CIV USARMY CESAS (US) <[e-mail]>; Cerio, Frank J II CIV (US)
<[e-mail]>
Subject: RE: Charlotte Army Missile Plant FUDS: 20050 Rite Aid Brownfields Site- acrolein

Carolyn/Doug,
To my knowledge, acrolein was never identified as a site related constituent for the Charlotte Army Missile Plant FUDS.
Therefore, acrolein was not a constituent sampled for during USACE investigations.
Ray

-----Original Message-----
From: Rumford, Doug [mailto:[e-mail]]
Sent: Monday, March 27, 2017 10:40 AM
To: Minnich, Carolyn <[e-mail]>
Cc: Livermore, Raymond R CIV USARMY CESAW (US) <[e-mail]>
Subject: [Non-DoD Source] RE: 20050 Rite Aid Brownfields Site- acrolein

Morning Carolyn,
I did a quick review of 3 random reports, 2007 Site wide Groundwater Sampling Report for Future Remedial Design,
2003 Letter Report for the FS/RD, and the 2000 Final Phase II Remedial Investigation Report.
None of these reports indicate Acrolein was a concern or even sampled for. In fact, Table 5-1 of the Phase II RI indicates
the TCL VOC's for the site and Acrolein is not included.

Based on my very basic review of site history, I would say it is not a site related constituent but I will defer to Ray on that
point.

Regards,
Doug

Good day. I am still moving forward with the brownfields agreement on Rite Aid, former Charlotte Army Missile Plant at
1776 Statesville Ave in Charlotte. I am looking back through the documents, trying to find the history of acrolein. In
January 2008, Hoffman Engineering collected 5 indoor air samples and acrolein was included. I can not seem to find a
summary report of the sampling event, but I do have the Indoor Air Quality Assessment prepared by AMEC dated March
26, 2009. They did some additional sampling and site work. In the AMEC report it states the following "Acrolein is a
ubiquitous contaminant of indoor and outdoor air due to its presence in combustion emission of all sorts, including
cigarette smoke, vehicle emissions, power plat emissions, and emission from home heating and cooking sources.
Accordingly, the acrolein is not a site related constituent. With acrolein excluded, noncarcinogenic risks for Rite Aid
workers ranged from HI of 0.09 in Building 48 to 0.5 in Building 2 in January 2008."

My question to you is did DEQ agree with the statement that "acrolein is not a site related constituent"? We have
continued to include acrolein in the soil vapor, indoor air, and sub slab samples and it's above screening levels. Do you
have any information or file notes on acrolein for this project?

We have continued to collected data on this site and acrolein remains detected in the indoor air, background air
samples, and sub slab. I am trying to better understand if this may be a site contaminant or just in the area.

I appreciate your feedback.

Thank you.
Carolyn Minnich

Risk Calculations
Risk Calculations were performed using Excel worksheets provided by Sandy Mort, NCDEQ Brownfields Toxicologist. For the purposes of looking at the site spatially, the site was divided into 10 areas. The risk
calculations indicated the following based on available data, including the following media: groundwater,
residual soil (based on confirmatory soil data), soil gas, indoor air, and fill soil samples:

The initial area for redevelopment is RA BLDG 48. Soil exposure will be restricted in this zone and denoted on
the plat map as “Area of Potential Soil Contamination” and “Area of Known Soil Contamination”

The following is for Rite Aid UST Area WT. Soil exposure will be restricted in this zone and denoted on the plat map as “Area of Potential Soil Contamination” and “Area of Known Soil Contamination”

In Building 1, the owner erected a temporary wall in the building to restrict air flow between the north and
south portions of the structure. Rite Aid Building 1 North cannot be occupied until vapor mitigation installed
per LUR 15.h (Land Use Restriction No. 8)

Rite Aid Building 1 South, can be occupied without additional assessment.

Rite Aid Building 2
Initially divided into 2 sections, that was revised based on the building design and future air flow. Soil
exposure will be restricted in this zone and denoted on the plat map as “Area of Potential Soil Contamination”

Rite Aid Building 3
Rite Aid Area C is the donut hole between Building 1, Building 48, Building 2. This area will have soil and
vapor restrictions.

Rite Aid Area 5, includes two structures. The Regional Training office/former cafeteria and T-26 former
offices. The highest detections for both structures was included in the risk calculator.

Rite Aid Area E, parking area that extends to Statesville Ave, no known impacts in this area. The elevated
levels of manganese in soil samples raised the risk levels.

MV Graham Property exceeds residential use due to acrolein detected in SSV.
Additional assessment is planned for August 2017.

The following email correspondence was from Sandra Mort on this project:

From: Mort, Sandra L Sent: Friday, June 09, 2017 1:46 PM
To: Minnich, Carolyn <[e-mail]>
Subject: Rite Aid-CAMP risk review

Carolyn- The following summarizes our discussion yesterday of the risk analysis of the Rite Air-CAMP site.
• The following risk concerns are indicated relative to the receptors and risk estimates calculated by the
BFP project manager and provided to the BFP Toxicologist for review on 5/10/2017 for the Rite Aid-CAMP BFP site in Charlotte NC. Risk estimates were calculated for individual areas of the Rite Aid-CAMP site using the DWM Risk Calculator (May 2016 RSL version). In the following areas unacceptable
levels of risk are indicated for the default construction worker exposure scenario and appropriate PPE is
recommended to prevent/limit dermal contact with the soils and inhalation and ingestion of the soils, as
would be provided by a respirator or fine-pore size "dust mask", such as an N-95 type mask: Area C, Area E, UST-WT, Bldg 1-N, Bldg 2, Bldg 2-E.
• Unacceptable levels of risk to the default residential receptor is indicated for the soils in the following
areas: UST-WT, Bldg-2W.
• Unacceptable levels of inhalation risks are indicated for the vapor intrusion pathway for a residential
and non-residential exposure scenario in the following areas: Bldg 1-N
• In addition, it is assumed there will be an LUR that prevent use or access to the GW across the site.
• The concentration of lead in the soils of the UST-WT area are greater than the concentration allowed
for a residential receptor.
• Additional investigation of the ambient air acrolein concentrations in the area of the site and the
hypothesis that the acrolein is attributable to typical urban background levels is recommended. Ambient (outdoor) air sample collection and analysis near the MV Graham location and other locations on the BF site, away from the MV Graham bldg location are recommended to be collected in the near future. This is recommended to provide additional ambient air data to address the subsurface acrolein detections
reported in the Nov 2016 MV Graham bldg sub-slab soil gas samples.

SL Mort, PhD BFP Environmental Toxicologist
________________________________________
Sandy Mort
Environmental Toxicologist / Risk Assessor
Division of Waste Management – Hazardous Waste & Brownfields NC Department of Environmental Quality
[phone] - Direct Line & Fax
[e-mail]
1646 Mail Service Center Raleigh, NC 27699-1646

On July 18, 2017, after a meeting with DEQ and PD, it was decided to add 2 approved High Density Zones to
be depicted on the plat map. The plat map will have the following defined area “Area of Potential High Density
Residential Use.” Based on the current redevelopment plans, not additional assessment is needed in these areas
for high density residential uses. See figure for area.
HD Zone 1 includes: RA Area E, RA Building 3, and RA Bldg 1 South. A summary risk calculator was run
with data for these regions. The following is the output.

HD Zone 2 includes RA Area C, and a portion of MV Graham. A summary risk calculator was run with data
for these regions. The following is the output.

Thallium concentrations were detected in soil boring SSB-8 above residential screening levels at a
concentration of 2.7 mg/kg. Evaluated concentrations are common when analyzing with Method 6010D. The preferred analysis will be method 6020 as this is quantitative versus colorimetric. Additional sampling will be
required in this area for residential development in the EMP plus post development sampling prior to
occupancy.

Required Land Use Restrictions:
Based on the site-specific data provided to the Brownfield program, the site reuse is suitable for the site as long
as the agreed upon land use restrictions in the BFA are abided by.

Soil: 1. Environmental Management Plan required, the document was reviewed and pending approved based on
soil restriction zones.
2. Plat map denotes “Area of Potential Soil Contamination” and “Area of Known Soil Contamination”
3. Notification prior to development activities.
Groundwater: Standard use restrictions

Vapor:
1. Plat map denotes “Area of Vapor Intrusion Requirement” for existing structures and new construction.
All standard LURs have been included such as access, notification, leases, etc. They can be found in the Notice
of Brownfields Property.