HomeMy WebLinkAbout24030_General Baptist SC_BF Assessment Work Plan_20200813Via Email
August 13, 2020
North Carolina Department of Environmental Quality
Division of Waste Management — Brownfields Program
1646 Mail Service Center
Raleigh, North Carolina 27699-1646
Attn: Mr. Tony Duque
Re: Brownfields Assessment Work Plan
General Baptist State Convention Property
603 South Wilmington Street and
112 and 114 East Lenoir Street
Raleigh, Wake County, North Carolina
Brownfields Project No. 24030-20-092
H&H Job No. NAP-001
Dear Tony:
1.0 Introduction
14
Dart ' hikman
SMAKTER ENVIRONMENTAL SOLUTIONS
On behalf of Narsi Development Raleigh, LLC (the Prospective Developer or PD), Hart &
Hickman, PC (H&H) has prepared this Work Plan to conduct Brownfields assessment activities
at the General Baptist State Convention property (Brownfields Project No. 24030-20-092)
located at 603 South Wilmington Street and 112 and 114 East Lenoir Street in Raleigh, Wake
County, North Carolina (subject Site or Site). The Site is comprised of three contiguous parcels
of land that total approximately 0.51 acres in size. The Site is located in the southern portion of
downtown Raleigh. A Site location map is provided as Figure 1, and the Site and surrounding
area are shown in Figure 2.
H&H reviewed available resources to obtain information regarding historical uses of the Site and
identify areas of potential environmental concern for proposed Brownfields assessment
activities. A brief summary of our review is provided in the following section.
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SMA 1111 ENVIRONMENTAL SOLUTIONS
Mr. Tony Duque
August 13, 2020
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2.0 Site Background
The Site was developed as residential land at an unknown point in time prior to 1903. Based on
review of the earliest known records, four residences were present at the Site and associated with
addresses 603 South Wilmington Street and 110, 112, and 114 East Lenoir Street. An
automotive repair shop was present on the 603 South Wilmington Street parcel from as early as
1914 until the parcel was redeveloped with a commercial office building in 1953. The office
building has been occupied by General Baptist State Convention and affiliated organizations
since that time. The General Baptist State Convention utilized an on -Site underground storage
tank (UST) located in the vicinity of the boiler room. The heating system was converted from
heating oil to natural gas at an unknown time and no knowledge of any actions to remove, drain,
and/or fill -in -place the heating oil UST was identified. In addition, H&H was unable to identify
any documentation of UST closure and/or abandonment procedures.
The residence associated with the former 110 East Lenoir Street address was demolished in the
early 1960s and the land was converted to a parking lot for the General Baptist State Convention
facility. The residences associated with the 112 and 114 East Lenoir Street parcels were
demolished in 2017 and the properties were converted into a gravel parking lot for general
downtown Raleigh parking. A Site map referencing key features is included as Figure 2.
In May 2020, H&H completed Phase I Environmental Site Assessment (ESA) activities at the
Site. The results of the ESA identified the following potential areas of environmental concerns
in connection with the Site:
• Potential release from on -Site heating oil UST associated with the 603 South Wilmington
Street parcel;
• Potential release from historical automotive repair activities conducted for an unknown
period of time between 1914 and 1938; and
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• Off -Site groundwater impacts associated with the Charter Square facility, Peerless Master
Cleaners and Dryers, and former petroleum distribution and automotive repair facilities
located to the northwest and west of the Site.
• UST release incident #33572 at the 114 East Lenoir Street parcel associated with
petroleum from an unregulated non-commercial UST. The incident was considered to be
a low risk and the North Carolina Department of Environmental Quality (DEQ) issued an
"No Further Action" letter for the release incident in September 2008. A Notice of
Residual Petroleum was not identified in connection with the UST release.
The Site received eligibility into the DEQ Brownfields Program via a Letter of Eligibility dated
July 2, 2020. On August 4, 2020, H&H and the PD participated in a conference call with DEQ
Brownfields personnel to discuss Site history, areas of potential environmental concern,
proposed redevelopment plans, potential data gaps, and the scope of Brownfields assessment
activities needed to address the data gaps. To address DEQ requests for additional assessment at
the Site, H&H proposes to conduct soil, groundwater, and vapor intrusion assessment activities
to further evaluate potential impacts at the Site. Proposed Brownfields assessment activities are
outlined in the following sections.
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August 13, 2020
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3.0 Brownfields Assessment Activities
The proposed Brownfields assessment activities will be performed in general accordance with
the DEQ Inactive Hazardous Sites Branch (IHSB) Guidelines for Assessment and Cleanup
(Guidelines) dated January 2020, the DEQ Division of Waste Management (DWM) Vapor
Intrusion Guidance dated March 2018, and the most recent versions of the U.S. Environmental
Protection Agency (EPA) Region IV Science and Ecosystem Support Division (SESD) Field
Branches Quality System and Technical Procedures guidance.
Prior to conducting field activities, H&H will contact North Carolina 811 One -Call, the public
utility locator service, to mark subsurface utilities at the Site. H&H will also team with a private
utility locator to identify and mark locations of sub -grade utilities at the Site that may not be
marked by the public locator. In addition, the private utility locator will perform a geophysical
assessment in the outdoor portions of the Site property to determine if underground storage tanks
(USTs) are present. The geophysical assessment will utilize ground penetrating radar (GPR) and
information obtained during the assessment will be recorded in the field using a hand-held
Global Positioning System (GPS) unit.
3.1 Receptor Survey
H&H will perform a Brownfields receptor survey in accordance with DEQ Brownfields Section
guidance. The receptor survey will utilize the Brownfields Property Receptor Survey Form and
will include information about land use in the Site area including zoning. H&H will also
conduct a field search for water supply wells, basements, utility manways and chases, storm
sewers, other underground utilities, drains, and surface water within a 1,500 ft radius of the
Brownfields property boundaries.
3.2 Soil Sampling Activities
H&H proposes to advance three soil borings to further evaluate potential impacts to soil from
historical operations and to assess background conditions at the Site. The approximate locations
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August 13, 2020
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of the proposed soil borings are shown on the sample location map, which is presented as Figure
3, and are described below:
• in the former automotive shop footprint;
• on the 114 East Lenoir Street parcel associated with former UST release incident #33572;
and
• in the southeastern portion of the Site to evaluate background conditions.
H&H will team with a qualified drilling contractor to advance two soil borings to the water table
(approximately 20 to 30 feet below ground surface [ft bgs]) utilizing a direct -push technology
(DPT) drill rig. Continuous soil samples will be collected from the borings using acetate lined
macrocore sleeves. Soil samples will be logged for lithological description and field screened
for indication of potential impacts by observation for staining, unusual odors, and the presence of
volatile organic vapors using a calibrated PID. One sample will be collected from each soil
boring at a depth interval interpreted most likely to be impacted based on field observations and
PID readings. If evidence of impacts is not observed, a surficial soil sample (approximately 1-2
ft bgs) will be collected. The background soil sample will be collected from the 1-2 ft bgs
interval.
Soil samples will be placed in dedicated laboratory -supplied sample containers, labeled with the
sample identification, date, and requested analysis, and placed in a laboratory -supplied cooler
with ice. Soil samples will then be submitted to a North Carolina certified laboratory under
standard chain of custody protocols for analysis of volatile organic compounds (VOCs) by EPA
Method 8260, semi-VOCs (SVOCs) by EPA Method 8270, and Resource Conservation and
Recovery Act (RCRA) metals by EPA Methods 6020/7471. The background soil sample will be
submitted for RCRA metals by EPA Methods 6020/7471 only.
Following sampling activities, the soil borings will be properly abandoned and the surface will
be repaired similar to pre -sampling conditions. Additionally, the soil sample locations will be
estimated using a hand-held GPS unit.
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August 13, 2020
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3.3 Groundwater Assessment Activities
H&H proposes to subcontract with a North Carolina licensed drilling contractor to covert two
borings into temporary monitoring wells. The approximate locations of the proposed temporary
monitoring wells are shown on Figure 3 and described below:
• in the former automotive shop footprint; and
• on the 114 East Lenoir Street parcel associated with former UST release incident #33572.
The temporary monitoring wells will be constructed of 1-inch diameter PVC with 10 or 15 ft of
pre -pack well screen (due to sampling for metals) set to bracket the water table (estimated at
between approximately 20 to 30 ft bgs) and 1-inch diameter PVC well casing to the ground
surface. A sand filter pack will extend from below the base to approximately 2 ft above the top
of the pre -packed well screens followed by at least 2 ft of hydrated bentonite.
The temporary monitoring wells will be developed by removing a minimum of 3 to 5 well
volumes and observing stable field parameters (i.e. pH ± 0.1 SU and conductivity varies no more
than 5%). After development, depth to groundwater information will be collected and a
groundwater sample will be collected utilizing low flow/low stress purging techniques using a
peristaltic pump and disposable polyethylene tubing. The intake point of the pump tubing will
be placed approximately in the mid -portion of the screened interval of the well and groundwater
will be removed at a rate no greater than 200 milliliters per minute. H&H will utilize a water
quality meter to measure pH, temperature, dissolved oxygen, oxidation reduction potential,
turbidity, and specific conductivity at 3 to 5-minute intervals during purging. Purging will be
considered complete when water quality parameters stabilize (i.e. pH ± 0.1 SU, conductivity
varies no more than 5%, and turbidity is less than 10 NTUs).
Once groundwater parameters stabilize, groundwater samples from the two temporary
monitoring wells will be collected directly into laboratory supplied sample containers. VOC
samples will be collected using the "soda straw" method to minimize volatile loss through the
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peristaltic pump head. The sample containers will be labeled with the sample identification,
date, and requested analysis, and then placed in a laboratory supplied cooler and iced. The
samples will be delivered to a North Carolina certified laboratory under standard chain of
custody protocols for analysis of VOCs by EPA Method 8260, SVOCs by EPA Method 8270,
and RCRA metals by EPA Methods 6020/7470.
Upon completion of groundwater sampling activities, the two temporary monitoring wells will
be properly abandoned by a licensed well driller and surfaces will be repaired to generally match
pre -drilling conditions. Groundwater sample locations will be recorded in the field using a hand-
held GPS unit.
3.4 Vapor Intrusion Assessment Activities
H&H proposes to conduct vapor intrusion assessment activities to evaluate the potential for
structural vapor intrusion into the existing and future buildings. To complete the assessment,
two sub -slab gas samples will be collected from within the basement of the existing General
Baptist State Convention building. In addition, three soil gas samples will be collected in the
vicinity of former automotive repair shop and in the northern and southern areas of the 112 and
114 East Lenoir Street parcels. Sample locations are depicted on Figure 3. The proposed sub -
slab gas and soil gas assessment will be performed in general accordance with the DEQ DWM
Vapor Intrusion Guidance dated March 2018 and as described below.
Each sub -slab gas point will be installed by utilizing a hammer drill and 5/8-inch diameter drill
bit to advance the boring through the concrete slab of the building basement (approximately 12
feet below grade). Following concrete borehole advancement, loose concrete cuttings will be
removed from the boring using a bottlebrush and vacuum with a high efficiency particulate air
(HEPA) filter. A Cox -Colvin Vapor PinTM (vapor pin) assembly (brass sampling point and
silicone sleeve) will be seated in the borehole using an installation/extraction tool and hammer.
The vapor pins will be installed as temporary sub -slab gas points.
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Each soil gas point will be installed to depths of approximately 5 to 7 ft bgs using a hand auger.
The soil gas points will each be installed with a 6-inch 0.010-inch stainless steel screen set at the
base of the boring connected to the surface with 1/4-inch Teflon® tubing. The annular space will
be filled with filter sand followed by a bentonite seal to prevent short-circuiting of air from the
surface.
Prior to sampling the soil gas and sub -slab gas points, a leak check will be conducted at each
location by constructing a shroud around the monitoring point and flooding the air within the
shroud with helium gas. Using a syringe, a sample will be collected from the gas in the shroud
into a Tedlar® bag and analyzed for helium concentrations using a helium gas detector. Vapor
from the monitoring points will be purged and sampled outside of the shroud into a separate
Tedlar® bag and analyzed using the helium gas detector to ensure that helium concentrations are
less than 10% of the concentration measured within the shroud.
Following a successful field leak check, the soil gas and sub -slab gas samples will be collected
into one -liter Summa canisters for laboratory analysis by connecting the Teflon® sample tubing
to an airflow regulator using a brass nut and ferrule assembly to create an air tight seal. Shut-in
leak tests will be performed on each Summa canister and sampling train prior to sampling. The
airflow regulator will be calibrated by the laboratory to allow the Summa canisters to fill slowly
at a rate not greater than 200 milliliters per minute. The vacuum pressure in each Summa
canister upon completion of the sampling event will be between three and six inches of mercury.
Upon completion of sample collection, the air flow regulator will be removed from the Summa
canister and the samples will be submitted to a nationally accredited laboratory under standard
chain of custody protocols for analysis of VOCs by EPA Method TO-15. Upon receipt of the
samples, the laboratory will record the final received vacuum pressure for each Summa canister.
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3.5 Quality Assurance/Quality Control Samples
Non -dedicated equipment and tools will be decontaminated prior to use at each boring or
sampling location or following exposure to soil, soil gas, or groundwater samples. For quality
assurance and quality control purposes (QA/QC), one trip blank will be submitted for analysis of
VOCs by EPA Method 8260 for each shipment that contains groundwater samples for VOC
analysis. To evaluate the reproducibility of the sample results, H&H will collect one duplicate
soil sample, one duplicate groundwater sample, and one duplicate soil vapor sample. The
duplicate samples will be submitted for the same laboratory analysis as their respective parent
samples.
Laboratory QA/QC procedures will be employed to ensure appropriate sample handling and
analysis and to aid in the review and validation of the analytical data. QA/QC procedures will be
conducted in accordance with the method protocols and will include regular equipment
maintenance, equipment calibrations, and adherence to specific sample custody and data
management procedures. Samples will be analyzed in conjunction with appropriate blanks,
laboratory duplicates, continuing calibration standards, surrogate standards, and matrix spiking
standards in accordance with approved methodologies to monitor both instrument and analyst
performance. Laboratory reporting limits for each analyte will be at or below appropriate
screening criteria, where possible. Additionally, H&H will request that the laboratory include
estimated concentrations for compounds that are detected at levels above the laboratory method
detection limit, but below the laboratory reporting limit (i.e., J flags).
The laboratory analytical data report and QA package for each group of samples submitted to
and analyzed by the subcontracted laboratory will be provided in an appendix to the final report.
Laboratory QA data consistent with Level Il documentation will be requested for this project. A
copy of the completed chain -of -custody record and shipping receipt will be appended to the
corresponding laboratory analytical report included with the final report.
Following sampling activities, the sub -slab gas and soil gas sample locations will be properly
abandoned and the surface will be repaired similar to pre -sampling conditions. Additionally, the
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sub -slab gas and soil gas sample locations will be estimated using a hand-held GPS unit or by
measuring from known benchmarks (e.g. doorways, walls, etc).
3.6 Investigation Derived Waste
Investigation derived waste (IDW) generated during the assessment activities will be thin spread
on -Site. However, if significant impacts are suspected (i.e., high PID readings, free -product,
etc.) the soil cuttings and/or generated groundwater will be containerized in 55-gallon drums and
staged on -Site pending analytical results of composite IDW samples. IDW generated during the
proposed assessment activities will be managed in accordance with DEQ IHSB Guidelines.
3.7 Reporting
Following completion of the assessment activities and receipt of the analytical data, H&H will
document our findings in a Brownfields Assessment Report. The report will include a
description of the sampling activities, figures depicting sample locations, sample data, soil
boring logs, laboratory analytical data, a discussion of the data in comparison to regulatory
screening levels, risk calculations, Brownfields receptor survey results, IDW manifests (if
applicable), and conclusions and recommendations concerning our activities.
Please contact me if you have any questions or require additional information.
Sincerely,
Hart & Hickman, PC
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Attachments
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