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Home My WebLink About21002-Eagle Island_IRWP_20170526 1 26 May 2017 Mr. Samuel P. Watson, P.G. Division of Waste Management – Brownfields North Carolina Department of Environmental Quality 127 Cardinal Drive Ext. Wilmington, NC 28405 Subject: Interim Removal Action Work Plan Subject Site: Parcel No. 0390000901, 03900008, and 03900011 located on Battle Ship Road NE, Eagle Island, Leland, North Carolina Brownfields Project Number: 21002-17-010 Dear Mr. Watson: Geosyntec Consultants of NC, PC (Geosyntec) is pleased to submit this Interim Removal Action Work Plan (Work Plan) on behalf of our client, Burgess Group Consolidated, LLC (Burgess; the Prospective Developer [PD] for the above-referenced Brownfields Site). Geosyntec is working on behalf of Burgess to achieve a finalized Brownfields Agreement (BFA) for the multi parcel property located on Battleship Road, Leland, NC (Brunswick County Parcel numbers 0390000901, 03900008, and 0390000901) (“Site”). The North Carolina Department of Environmental Quality (NCDEQ) approved Burgess’s 25 January 2017 Brownfields Property Application (BPA) in a 3 April 2017 Letter of Eligibility (LOE). On 17 May 2017, Geosyntec submitted a Phase II Environmental Site Assessment (ESA) to NCDEQ summarizing the results of soil and groundwater testing and excavation test pitting completed at the Site in 2017. This Work Plan presents a proposed interim removal action for impacted soils identified during the Phase II ESA activities. The work presented herein is proposed to help facilitate future Site reuse and support issuance of a finalized BFA. BACKGROUND The Site consists of three contiguous parcels (Brunswick County Parcel No. 0390000901, 03900008, and 03900011) totaling approximately 23 acres located on Battle Ship Rd NE on Eagle Island in Leland, North Carolina. Site Parcels 0390000901 and 03900011 are each divided into two properties by Battle Ship Road NE; portions of each parcel are located east and west of the road. The Site is largely surrounded by unoccupied or undeveloped land in a formerly primarily commercial/industrial area, with the exception of an electrical substation located adjacent to the south of the Site. The Site location is shown on Figure 1. The Site layout with pertinent Site features is provided on Figure 2. 2 In 2016, Geosyntec performed a Phase I Environmental Site Assessment (ESA) in support of Burgess’ purchase of the Site; this work was summarized in a 3 January 2017 Phase I ESA Report (“January 2017 Phase I ESA”) and submitted to the NCDEQ as part of Burgess’ 16 February 2017 BPA. Geosyntec was retained by Burgess to guide the environmental efforts to achieve a finalized Brownfields Agreement for the Site. At the direction of NCDEQ, in 2017, Geosyntec completed Phase II ESA work at the Site largely to address the Recognized Environmental Conditions (RECs), as defined by the ASTM E1527-13 Standard, identified in the January 2017 Phase I ESA. The work performed as part of this Phase II ESA consisted of test pitting, soil sampling, and a groundwater quality assessment. On 17 May 2017, Geosyntec submitted a Phase II Environmental Site Assessment (Phase II ESA) report to NCDEQ to provide the results of Phase II ESA work at the Site in 2017. As discussed in Geosyntec’s Phase II ESA Report, a tar or resin was observed during test pitting activities in one area of the Site in proximity to a stick-up pipe and winch near the Site shoreline on Parcel 0390000901. In addition, elevated polynuclear aromatic hydrocarbon (PAH) and metals concentrations above both residential and commercial/industrial NCDEQ Inactive Hazardous Sites Branch (IHSB) Preliminary Soil Remediation Goals (PSRGs) were identified in soils in this area. Analytical results for soil samples collected within this Site area are shown on Figure 3. In anticipation of Site redevelopment and reuse, Geosyntec is proposing impacted soil excavation and off-Site disposal as an interim remedy for these observed soil impacts and to reduce elevated concentrations of observed constituents. The remainder of this report outlines the proposed interim removal action to address this area of the Site, which consists of: i) site preparation and debris removal; ii) soil excavation; iii) confirmation soil sampling; and iv) backfilling. PROPOSED INTERIM REMOVAL ACTION Site Preparation and Debris Removal Prior to excavation activities, existing structures and debris will be removed along a proposed access route (shown in Figure 4) from Battleship Rd NE to the excavation area, and within the vicinity of the excavation area. Removal will include, but may not be limited to, a deteriorated winch, building debris, and portions of a concrete pad. Currently, a monitoring well (MW-5; installed during Phase II ESA activities) is located within the proposed excavation area. This well will be abandoned in place by tremie grouting before beginning debris removal, in accordance with NCDEQ guidance. In preparation for soil excavation and hauling, the access route will be improved using Site brush obtained during debris removal and imported fabric and gravel to allow access for vehicles. The Site access route will largely follow the on-Site utility right of way and will avoid impacts to Site wetlands. 3 Soil Excavation Proposed soil removal areas are depicted on Figure 5. Soil removal will be performed in two phases. Tar/resin-impacted soil will be excavated to the groundwater table (observed to be approximately 3 feet below ground surface) in an approximate 15 ft by 15 ft area at the previous Phase II test pit. Soil will be removed to the water table until no visible tar/resin is observed in the excavation. In addition, surficial soil (top 1 foot) will be removed in a larger area (approximately 75 cubic yards; shown in yellow on Figure 5) in proximity to the Phase II ESA test pit, stick-up pipe, and winch where metal and PAH impacts above background concentrations were identified. As shown on Figure 5, the proposed excavation area will extend to the limits of the onsite wetlands; wetland areas are not proposed to be excavated. Excavated soil will be stockpiled on visqueen onsite and covered pending the results of confirmation and waste characterization sampling. One stockpile of tar/resin-impacted soil and two stockpiles of surficial soil will be made. Composite waste characterization samples will be collected from the stockpiles and analyzed for metals by EPA 6020 or the toxicity characterization leaching procedure (TCLP) to evaluate hazardous versus non-hazardous waste disposal options. Confirmation Soil Sampling Following excavation and stockpiling, confirmation soil samples will be collected at the four excavation sidewalls and at the edges of the surficial removal zone. Confirmation samples will be analyzed for metals and PAHs. Stockpiled soils will remain covered on-Site until receipt of confirmation sample results. Excavated soil will be disposed of off-site at an approved disposal facility in accordance with the results of the waste characterization sampling. If the confirmation sample results are above NCDEQ screening levels or background concentrations, Geosyntec will coordinate with Burgess and NCDEQ on a path forward. Backfilling Following receipt of acceptable confirmation sample results, the excavation to groundwater will be backfilled with imported #57 gravel stone and the remaining surface excavation footprint will be covered with imported sand. Up to three sources of potential backfill material will be sampled and submitted for analytical testing and approval by the NCDEQ Brownfield Program project manager prior to use onsite. Backfill samples will be analyzed for volatile organic compounds (VOCs) by EPA Method 8260, semi-volatile organic compounds (SVOCs) by EPA Method 8270, and IHSB HSL metals by EPA Method 6010 or 6020. 4 CLOSING We look forward to your review and approval of this Interim Removal Action Work Plan. Please feel free to contact the undersigned with any questions or comments. Sincerely, Kaitlyn S. Rhonehouse, P.E. Eric Nesbit, P.E. Senior Engineer Senior Principal FIGURES Site Location Map Figure 1 Raleigh, NC May 2017 Legend Subject Site Boundary ³ Notes: 1. 2013 topographic map obtained from USGS The National Boundaries Dataset. 2. Site is within the Wilmington Quadrangle. 3. Site Boundary was estimated based on information provided by Brunswick County, North Carolina GIS Website. 0 1,000 2,000 Feet 0390000901 03900011 03900008 Subject Site: Parcel No. 0390000901, 03900011, and 03900008 Battle Ship Road NE Eagle Island, North Carolina N:\GN6146 Burgess Eagle Island\GIS\MXD\Phase I ESA\Figure 1.mxd Muddy Waters (Former Marine Railway)Cape FearRiverCape Fear Memorial BridgeBattleship RoadSubstationMetal Buildingwith Tank B WinchBoatWinchWood Shed D Metal DockAreaConcrete Slab and Concrete BlockBuilding A Remnants of Metal/Wood Building/Roof C Concrete I-BeamsConcrete BarricadesConcrete Foundation, Metal Mounting Structures, Electrical Box, and Stick Up PipesSubject Site: Parcel No. 0390000901, 03900011, and 03900008 Battle Ship Road NEEagle Island, North CarolinaRaleigh, NCMay 2017Figure20 140 280FeetConcrete I-Beam on55 Gallon DrumsElectrical Box Owned by Adjacent Substation Present on Subject PropertyCarolina Christian Radio N:\GN6146 Burgess Eagle Island\GIS\MXD\Phase I ESA\Figure 2.mxd³Notes:1. Site Boundary was provided by Brunswick County Property Apprasier.2. 2013 Aerial Map was provided by ESRI Online Database.3. Refer to Geosyntec's 13 January 2017 Phase I ESA Report for A B C D description and Findings descriptions.LegendSubject Site BoundaryStick Up PipeSite Layout MapTest Pit LocationTest Pit LocationTest Pit Location LegendGrab DPT Soil SampleGrab Hand Auger Soil SampleSubject Site BoundaryApproximate Wetlands³Soil Sampling Results forTest Pit AreaFigure3Raleigh, North CarolinaMay 20170 40 80FeetNotes:1. Discrete hand auger soil samples were collected by hand augering from approximately 0-1 foot below ground surface.2. Discrete DPT soil samples were collected at the following depths below ground surface: SS-MW5 = 1-2 3. All results are in milligrams per kilogram (mg/kg).4. PSRG indicates preliminary soil remediation goal5. PSRG values provided by the North Carolina Department of Environmental Quality, amended October 20166. Detections are identified in bold.7. Results with method detection limits exceeding PSRGs are identified in bold italics.8. DPT indicates direct push technology.9. J indicates estimated value.10. < indicates analyte was not detected above method detection limit.11. Highlighting corresponds to the following: yellow = exceedance of Residential PSRG, orange = exceedance of Commercial / Industrial PSRG.12. Only analytes exceeding one or more PSRG in one or more discrete or composite soil samples are display on figure.13. Wetland delineation based on survey completed by Southern Environmental Group, Inc. in March 2017.Arsenic9.33Copper1240Lead1660Manganese202Mercury7.40Thallium<0.265Benzo[a]anthracene<0.201Benzo[a]pyrene<0.181Benzo[b]fluoranthene<0.187Dibenz(a,h)anthracene<0.214Indeno[1,2,3-cd]pyrene<0.194Sampled on 3/8/17MetalsPS5SVOCsArsenic3.47Copper42.6Lead3,390Manganese53.9Mercury2.30Thallium <0.0524Benzo[a]anthracene0.131Benzo[a]pyrene0.148Benzo[b]fluoranthene0.175Dibenz(a,h)anthracene<0.0393Indeno[1,2,3-cd]pyrene0.0791 JMetalsSS-MW5Sampled on 3/23/17SVOCsConstituentResidential PSRG (mg/kg)Industrial / Commercial PSRG (mg/kg)Arsenic 0.680 3.00Copper 620 9400Lead 400 800Manganese 360 5200Mercury 2.20 3.13Thallium 0.156 2.40Benzo[a]anthracene 0.160 2.90Benzo[a]pyrene 0.0160 0.290Benzo[b]fluoranthene 0.160 2.90Dibenz(a,h)anthracene 0.0160 0.290Indeno[1,2,3-cd]pyrene 0.160 2.90N:\GN6353 Eagle Island Interim Measure\GIS\MXD\Figure 3.mxdSubject Site: Parcel No. 0390000901, 03900011, and 03900008 Battle Ship Road NEEagle Island, North CarolinaArsenic21.1Copper993Lead2860Manganese417Mercury7.55Thallium<0.291Benzo[a]anthracene0.259Benzo[a]pyrene0.317Benzo[b]fluoranthene0.399Dibenz(a,h)anthracene0.0788 JIndeno[1,2,3-cd]pyrene0.369SVOCsSampled on 3/8/17MetalsPS3WinchStick Up PipeTest Pit Location