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HomeMy WebLinkAbout23080_Almont Shipping II_AWP_20210915Geosy te& consultants Geosyn tee Consultants of NC, PC Ms. Kathleen Markey Brownfield Program Project Manager North Carolina Department of Environmental Quality 1646 Mail Service Center Raleigh, North Carolina 27699-1646 Geosyntec Consultants of NC, P.C. 314 Walnut Street, Suite 200 Wilmington, NC 28401 PH 910.372.6402 www.geosyntec.com 15 September 2021 Subject: Work Plan for Supplemental Soil Gas Sampling Site: Almont Shipping II 19 & 41 Harnett Street, Wilmington, North Carolina (New Hanover County Parcels No. R04716-001-026-000 & R04712-002-001-000) NCBP No. 23080-19-065 Dear Ms. Markey: On behalf of Wilmington Riverfront Holding Company, LLC (new/current ownership entity), formerly Wilmington Waterfront Property Owner, LLC (the Prospective Developer [PD]), Geosyntec Consultants of NC, P.C. (Geosyntec) has prepared this Work Plan for the above - referenced North Carolina Brownfields Program (NCBP) property located at 19 and 41 Harnett Street, Wilmington, NC (the "Site"). The North Carolina Department of Environmental Quality (NCDEQ) approved Wilmington Waterfront Property Owner, LLC's 7 January 2020 Brownfields Property Application (BPA) in an 18 February Letter of Eligibility (LOE). This Work Plan presents the planned supplemental soil gas assessment activities to support the issuance of a Brownfields Agreement (BFA) for the Site. We look forward to your review and approval of this Work Plan. Please do not hesitate to contact Kaitlyn Rhonehouse (910.372.6402 or krhonehouseggeosyntec.com) if you have any questions. Sincerely, Brandon Peach, PG (Nc, sc) Kaitlyn Rhonehouse, PE (NC, VA, FL) Senior Staff Scientist Principal Copies to: Luke Davis, Graham Tyrrell, William Edwards — Kettler Enterprises, Inc. Mary Katherine Stukes — Moore & VanAllen Prepared for Wilmington Waterfront Property Owner, LLC 8255 Greensboro Drive, Suite 200 McLean, Virginia 22102 WORK PLAN FOR SUPPLEMENTAL SOIL GAS SAMPLING New Hanover County Parcel No. R04716-001-026-000 & R04712-002-001-000 19 & 41 Harnett Street, Wilmington, North Carolina Brownfields Project: Almont Shipping II NCBP No. 23080-19-065 Prepared by GeosyntecO' consultants Geosyntec Consultants of NC, P.C. Geosyntec Consultants of NC, P.C. 314 Walnut Street, Suite 200 Wilmington, North Carolina 28401 Project Number GN7035 September 2021 PROFESSIONAL ENGINEER SIGNATURE I, Kaitlyn Rhonehouse, a Licensed Engineer for Geosyntec Consultants of NC, P.C., do certify that the information in this report is correct and accurate to the best of my knowledge. Geosyntec Consultants of NC P.C. is licensed to practice engineering in North Carolina. The certification number (Firm's License Number) is C-3500. Geosyntec Consultants of NC P.C. is licensed to practice geology in North Carolina. The certification number (Firm's License Number) is C-295. X� C A III, '4 SEAL 04354$ Kaitlyn Rhonehouse, PE Principal North Carolina P.E. License No. 043548 Expiration Date: 31 December 2021 Geosyntec Consultants of NC, PC 314 Walnut Street, Suite 200 Wilmington, NC 28401 Telephone: 910.372.6402 Geosyntec {` consultants Geosyntec Consultants of NC, Y.C. TABLE OF CONTENTS 1. INTRODUCTION.....................................................................................................................................1 1.1. Site Environmental History...........................................................................................................1 1.2. Work Plan Objectives....................................................................................................................2 2. SCOPE OF WORK...................................................................................................................................2 3. SAMPLING METHODOLOGY..................................................................................................................3 3.1. Health and Safety Planning and Utility Clearing...........................................................................3 3.2. Soil Vapor Probe Installation and Soil Gas Sampling....................................................................3 3.3. Decontamination..........................................................................................................................5 3.4. Soil Vapor Probe Locating.............................................................................................................5 3.5. Soil Vapor Probe Abandonment...................................................................................................5 4. LABORATORY ANALYSIS........................................................................................................................5 4.1. Laboratory Analysis.......................................................................................................................5 4.2. Laboratory Reporting....................................................................................................................5 5. QUALITY ASSURANCE/QUALITY CONTROL............................................................................................6 5.1. Field and Laboratory Procedure QA/QC.......................................................................................6 5.2. Chain of Custody QA/QC...............................................................................................................6 6. INVESTIGATION DERIVED WASTE (IDW) MANAGEMENT.....................................................................6 7. REPORTING...........................................................................................................................................7 LIST OF TABLES Table 1 Proposed Soil Gas Sampling Locations and Analysis LIST OF FIGURES Figure 1 Site Location Figure 2 Site Layout Figure 3 Proposed Soil Gas Sampling Locations GN7035/CAR210179 i September 2021 Geosyntec{` consultants Geosyntec Consultants of NC, P.C. 1. INTRODUCTION Geosyntec Consultants of NC, P.C. (Geosyntec), on behalf of Wilmington Riverfront Holding Company, LLC (new/current ownership entity), formerly Wilmington Waterfront Property Owner, LLC (the Prospective Developer [PD]), prepared this Work Plan for Supplemental Soil Gas Sampling (the "Work Plan") for two parcels located at 19 and 41 Harnett Street (New Hanover County parcel IDs: R04716-001-026-000 and R04712-002-001, respectively), Wilmington, North Carolina (these two parcels are collectively referred to herein as the "Site" and the "Almont Shipping II" Brownfields Property and are shown on Figure 1 and Figure 2). The total acreage of the 19 Harnett Street parcel is approximately 2.02 acres and the total acreage of the 41 Harnett Street parcel is approximately 0.95 acres, totaling the combined acreage to 2.97 acres. The 19 Harnett Street parcel and the northwestern portion of 41 Harnett Street parcel and surrounding area comprised the "Almont Shipping Brownfields Property" (North Carolina Brownfields Program [NCBP] No. 10040-06-065; referred to herein as the "Almont Shipping Brownfields Property"). Figure 2 shows the location of the Site and the Almont Shipping Brownfields Property. The North Carolina Department of Environmental Quality (NCDEQ) approved Wilmington Waterfront Property Owner, LLC's 7 January 2020 Brownfields Property Application (BPA) in a 18 February 2020 Letter of Eligibility (LOE; NCBP No. 23080-19-065). Geosyntec has been retained by Wilmington Waterfront Property Owner, LLC to guide the environmental efforts to produce a stand-alone Brownfields agreement (BFA) for both 19 and 41 Harnett Street parcels that will supersede the existing BFA for Site portion of the Almont Shipping Brownfields Property BFA only. Geosyntec previously conducted soil and soil gas assessment activities at the property, which were presented to DEQ in a report dated August 11, 2021. Following discussions with DEQ about those sampling results, Geosyntec has prepared this Work Plan to present proposed supplemental soil gas sampling activities at the Site. This will further establish pre-existing environmental Site conditions and support issuance for the new BFA. 1.1. Site Environmental History The Site and surrounding area operated as the former Almont Shipping terminal from 1870 until 2005. A BFA was executed between the NCBP and Riverfront Holdings II, LLC on 23 June 2008 for the Almont Shipping Brownfields Property (NCBP No. 10040-06-065; the 19 Harnett Street parcel and northwestern of portion of the 41 Harnett St. parcel are included in the Almont Shipping BFA until a new BFA is executed for the Site). The BFA was amended in 2014 to include an additional land tract owned by CSX. The Site received eligibility for entry into the NCBP on 18 February 2020 to establish a new, stand-alone BFA for only the two Harnett Street parcels. The Site is planned to be developed for multi -family apartments, retail space, and an associated parking garage. Geosyntec performed soil and groundwater sampling at the Site in 2020; the results GN7035/CAR210179 1 September 2021 Geosyntec {` consultants Geosyntec Consultants of NC, P.C. of the sampling were summarized in a 13 July 2020 NCDEQ Brownfields Site Assessment Report. In May 2021, NCDEQ subsequently requested that soil gas sampling be performed to evaluate for the potential for vapor intrusion risk at the Site. The soil gas sampling scope of work was described in the Work Plan for Soil Gas Sampling dated 11 May 2021 (Work Plan) and approved by NCDEQ on 11 May 2021. Eight (8) temporary soil gas probes were installed and sampled in May 2021 to evaluate potential vapor intrusion exposures at the Site. The results of this sampling indicated elevated concentrations of volatile organic compounds (VOCs) and methane. The source of VOCs was not identified, however, the source of methane appeared to be localized buried debris in the eastern portion of the Site identified during subsequent test pitting activities. Following removal and replacement of debris in several areas during test pitting, re -screening of select soil gas probes did not reveal positive methane readings. May 2021 soil gas testing results and testing pitting were summarized in an 11 August 2021 Soil and Soil Gas Sampling Report to NCBP. Removal and off -site disposal of debris and organic material is planned to be completed during Site grading activities in September 2021 under the approved Environmental Management Plan (EMP) for the Site, which we expect to largely remove the source of methane. This Work Plan was prepared to outline additional planned VOC and methane testing under final representative site conditions (post -removal of stockpile and after grading activities are completed). The remainder of this Work Plan provides a proposed scope of work to complete additional soil gas sampling at the Site as requested by DEQ following its review of the May 2021 assessment results. 1.2. Work Plan Objectives The scope of work described herein was prepared to meet the following objectives: • Obtain soil gas data to evaluate potential VOC and methane risks associated with future structures This Work Plan was prepared following the NCBP Environmental Site Assessment Work Plan Minimum Requirements Checklist (November 2018), and is generally consistent with the NCDEQ Brownfields Program Methane Assessment Protocol (Methane Assessment Protocol) (December 2020) and Preliminary NCDEQ Brownfields Program Guidance: Vapor Intrusion Assessment Work Plan & Report Checklist (July 2021). 2. SCOPE OF WORK The site soil gas assessment includes the advancement of ten (10) temporary soil vapor probes across the two Site parcels depicted on Figure 3 and detailed on Table 1. Eight of the soil gas probes will be generally collocated with previously sampled locations, and the remaining two will be located below former stockpiles, which were previously inaccessible areas. Samples will be collected after removal of stockpile and after grading activities have been completed, prior to vertical construction activities. Groundwater depth is expected to be approximately 6 to 12 feet GN7035/CAR210179 2 September 2021 Geosyntec{` consultants Geosyntec Consultants of NC, P.C. below ground surface (ft bgs); therefore, soil vapor probes will be installed to a depth of 5 to 9 ft bgs, as described in Section 3.2. 3. SAMPLING METHODOLOGY 3.1. Health and Safety Planning and Utility Clearing Prior to the start of work, Geosyntec will prepare a site -specific Health and Safety Task Hazard Analysis in general accordance with the Occupation Safety and Health Administration (OSHA) rules (29 CFR 1910.120). To address potential underground utilities, Geosyntec will contact the North Carolina 811 one -call system a minimum of 72 business hours before beginning the assessment to notify member utilities of the subsurface work. Procedures will generally follow the Operating Procedures as determined by the U.S. Environmental Protection Agency (USEPA) Region IV Science and Ecosystem Support Division (SESD). The most current versions of these operating procedures can be downloaded at: https://www.epa.gov/quality/quality-system-and- technical-procedures-sesd-field-branches. Additional media specific procedures are discussed further below. 3.2. Soil Vapor Probe Installation and Soil Gas Sampling Ten (10) soil vapor probes (SGP-lB through SGP-8B, SGP-9, and SGP-10) are proposed for the collection of soil gas samples. Eight (8) soil vapor probes will be co -located with historical locations SGP-1 through SGP-8, and two additional probes will be installed in the location of the former stockpiles. Proposed soil vapor probe locations are shown in Table 1 and Figure 3. Soil vapor probes will be installed approximately 1 to 2 feet above the groundwater, at depths ranging of between 5 and 9 feet below ground surface (bgs) based on the previously observed water table. Each soil vapor probe will consist of/4-inch diameter Nylaflow® tubing connected with a compression fitting to a 1/4-inch-diameter stainless steel sampling probe. Geosyntec will supply both new Nylaflow tubing and soil vapor probes. Probes will be installed inside the borehole and a sand filter pack will be placed in the annulus to a height of approximately 6 inches above the top of the soil gas implant. Granular bentonite will then be placed in two lifts of approximately 3 inches above the filter pack and hydrated with a small amount of distilled water after each lift. A thick slurry of powdered bentonite and water will be added to seal the remainder of the borehole annulus to ground surface. The top of the probe will be fitted with a compression -fit brass ball valve to maintain an air -tight seal between installation and sampling. The soil vapor probes will then be allowed to equilibrate 48 hours prior to sampling. GN7035/CAR210179 3 September 2021 Geosyntec {` consultants Geosyntec Consultants of NC, P.C. Given the historical presence of methane in Site soil gas, static subsurface pressure (i.e., subsurface gas pressure relative to atmospheric pressure) will be recorded from each soil gas probe prior to purging in general accordance with the NCBP Methane Assessment Protocol. The static pressure data will be collected using a Landfill GEM 5000 (or equivalent multi -gas meter) and a manometer for redundancy. Prior to sampling, a shut-in test will be performed by closing the sample train valves and generating a vacuum in the sample train using a lung box or equivalent. If the vacuum does not dissipate after at least 30 seconds, the shut-in test will be considered successful. Following a successful shut-in leak test, soil vapor will be purged of at least three times the soil gas probe and sample train volume and screened for the presence of VOCs using a photoionization detector (PID) and carbon dioxide, methane, and oxygen using a Landfill GEM 5000 (or equivalent multi - gas meter). A helium shroud will be used initially during sampling as a tracer leak test to evaluate potential outdoor air entrainment into the samples. However, commonly used helium meters (e.g., MGD- 2002) indicate in the operator manual that the presence of methane will interfere with the helium meter screening results. This could indicate a false positive screening of helium in the sample train, when the meter is actually detecting methane. In this event, multiple lines of evidence will be used to evaluate the integrity of the soil gas probe and sample train seal: 1) a shut-in leak test will be performed initially as discussed previously and 2) during the soil gas purging, the presence of methane and carbon dioxide above atmospheric levels, in combination with decreased oxygen concentration relative to atmospheric conditions, will be used as a surrogate measurement for the integrity of the surface seal. Atmospheric levels of oxygen are expected in the field screening samples if there is a significant source of atmospheric air entering the sample train. If methane is not present in field screening samples, helium will be used as a seal test. Soil vapor samples will be collected in pre -evacuated, batch certified -clean 1-L Summa CanistersTM equipped with 200 milliliters per minute (mL/min) flow controllers. An initial vacuum will be recorded from each canister prior to sampling; if the initial canister vacuum decreases by more than 10% from the vacuum as measured by the analytical laboratory, the canister will not be used for sampling. The targeted final vacuum for sample collection will be 5 inches of mercury (in Hg) and final canister vacuums as measured by the laboratory will be provided in analytical reports. After sample collection, the canisters will be transported via Fed Ex to a National Environmental Laboratory Accreditation Program (NELAP)-certified laboratory for VOC analysis by Environmental Protection Agency (EPA) Method TO-15 and methane analysis by American Society for Testing and Materials (ASTM) D-1946. One quality control (QC) duplicate soil gas sample will be collected. A minimum of 24-hours following the soil gas purging and analytical sampling, one additional round of soil gas screening will be performed, as follows. Static and differential pressure measurements will be collected from each soil gas probe, and oxygen, carbon dioxide, and methane GN7035/CAR210179 4 September 2021 Geosyntec {` consultants Geosyntec Consultants of NC, P.C. will also be screened while purging soil gas from the subsurface using the equipment mentioned previously. Stabilized concentrations of field screening data will be provided to NCBP. 3.3. Decontamination Disposable equipment will be used as practical. However, as needed, equipment will be decontaminated using an initial water rinse followed by cleaning with Alconox® (or equivalent) and final rinse of distilled water. 3.4. Soil Vapor Probe Locating A handheld GPS unit and field measurements will be used to collect the approximate coordinates of the soil vapor probes. 3.5. Soil Vapor Probe Abandonment Following sample collection, soil vapor probes will be temporarily kept in place awaiting analytical results. Upon receipt of analytical data and pending anticipated discussions with NCBP, soil gas probes will eventually be removed from the subsurface and backfilled with excess Site soils and/or bentonite. 4. LABORATORY ANALYSIS 4.1. Laboratory Analysis Following collection, soil gas samples will be sealed and submitted to a NELAP-certified laboratory following chain of custody procedures (Section 5.2). 4.2. Laboratory Reporting Laboratory reporting limits (RLs) and MDLs used by the selected NELAP-certified laboratory for methods will meet respective NCDEQ Division of Waste Management (DWM) VISLs (May 2020) to the extent feasible. Acrolein will not be reported per NCDEQ guidance (July 2021). Concentrations detected between the RL and MDL will be reported as estimated values and flagged in the laboratory analytical report with a "J". Level II Quality Assurance (QA)/Quality Control (QC) will be reported in the analytical report deliverable. GN7035/CAR210179 5 September 2021 Geosyntec{` consultants Geosyntec Consultants of NC, P.C. 5. QUALITY ASSURANCE/QUALITY CONTROL 5.1. Field and Laboratory Procedure QA/QC One duplicate soil gas sample will be collected and submitted for laboratory analysis as indicated in the sections above. 5.2. Chain of Custody QA/QC Geosyntec will initiate chain of custodies for soil gas samples in the field documenting sample collection information including but not limited to: • The Sample Collector's Name • Project Information and Location • Geosyntec Project Manager Contact Information • Sample Identification Number • Date and Time of Sample Collection • Type of Analysis; and • Type and number of containers. Samples will remain in the custody of Geosyntec until they are ready for shipment. Geosyntec will relinquish the samples and chain of custodies (noting date and time of relinquishment) to the laboratory courier who will sign the chain of custody as receiver (noting date and time again). Geosyntec will retain a copy of the chain of custodies signed by the courier. Sample shipments and chain of custodies will be sealed in an appropriate shipping container/box and sent to the address of the selected laboratory. A representative from the selected laboratory's sample receiving will sign respective chains of custody verifying receipt of the samples by each respective laboratory location. A copy of fully executed chains of custody will be provided in the final laboratory analytical report deliverable. 6. INVESTIGATION DERIVED WASTE (IDW) MANAGEMENT IDW (soil cuttings) will be screened at each soil vapor probe boring with a PID. Soil staining and/or odors will be recorded in the field. If visible soil staining and/or odors are detected, IDW will be containerized in 55-gallon steel drums and stored in a designated area of the Site pending disposal based on laboratory results. If no staining and/ or odors are observed, IDW will be distributed on -site. GN7035/CAR210179 6 September 2021 Geosyntec {` consultants Geosyntec Consultants of NC, P.C. 7. REPORTING The results of the soil gas sampling will be summarized in a report to be submitted to the NCBP. The report will include the laboratory analytical data report, tabulated summary analytical data compared to applicable screening criteria and the results will be input into the NCDEQ Risk Calculator for screening purposes. A figure showing final sampling locations and results in relation to the proposed redevelopment, and soil gas screening logs will be provided. The final report will be signed and sealed by a Professional Engineer or Professional Geologist licensed to practice in North Carolina and will include Geosyntec's Professional Engineer and Professional Geologist license numbers. GN7035/CAR210179 7 September 2021 FIGURES Fo re N I, / Vctorg Dr I k Dr I' f BrA �1 I °OD Oc 1 II -, Hightsville r` t Northeast Cape Fear River I Division Dr' I I / I / 17f / l � r / k4rtrn r• thaon i Compton st \\(O\\Ov �rFus 1;'r Pw.1rt i - - - - - - - - �/ y tsape/k 9/ ii Bess St /2h y /J tt7 r z v Nixon St _ I N Swann St / � 8 tia rnetl St Z Oakdale Cemetery 2 �o N / / Br,:rswick St Fanning Sr c _ Pine Fon C.—Wry / l 7- Flanover Sty Z Be O ? ❑ Ce Cympcell Sf E2 c _ - \ \ c o 3 a g Red Cross St Z Rankin St \ E o Walnut St \ \ i Z z Grar.¢ z z = m - (~ z S ^� S1 Cn¢sinUt N N = N N S 1111cl 51 ;-l7 Alligator \ U5-17.BKS U5.17-BRN Creek \ \ GN h�rrket St Wilmington Meadow Sl Book S1 fi S Noith Carolirc+ Rd m a '-Andrew-Jackson-HwY Orange st = 1 N £ Ann St c _ N N N = 2,000 1,000 0 2,000 Feet p,I ligd/ _ c c 17 Site Parcels Notes: I. Aerial imagery provided by ArcMap10.5, ESRI 2. Parcel Boundary obtained from New Hanover County, NC online GIS database. -31 Site Location 19 and 41 Harnett Street New Hanover, NC Geosyntec° consultants Figure G }ranee Coruulronts of Nl�PG. Raleigh, NC August 2021 1 Area of Potential Vapor Concern Parcels Brownfields Boundary Site Parcels Notes: 1. Aerial imagery provided by ArcMap10.5, ESRI 2. Parcel Boundary obtained from New Hanover County, NC online GIS database. - 1 R0471�2-002-001-000 41 Harnett Street Z ,-'Harnetf St. CO ram- 1 t *jy , I M Bladen St- 1 44" 16-000ON z Brunswick St. Cf)� a � I + ! R04716-005.001-000 ��Hanover St. ,t oir n' I 290 145 0 290 Feet Site Layout 19 and 41 Harnett Street New Hanover, NC Geosyntec consultants Figure Raleigh, NC P P August 2021 2 �JE -OA' i s _ - SGP-9 f F 1' SGP-3B c� -MW-2 - �' SGP 4BL OP rI TM 1+1 ,-,+, SGP-5113,* SGP-3B SGP-8B Ok m ' Ia 1 4 Legend Notes: L 3Site Boundary 1. Service Layer Credits: Source: Proposed Soil Gas Sampling Locations = Residential Units Esri, Maxar, GeoEye, Earthstar Geographics, CNES/Airbus IDS, N =Amenities USDA, USGS, AeroGRID, IGN, and 19 and 41 Harnett Street = Retail the GIS User Community Wilmington, NC Q Elevator Shaft 2. Proposed soil gas sampling locations are subject to change Geosyntec U re FI I_ (Approximate Extent of Stockpile pending field conditions at time of g Existing Monitoring Wells field effort. consultants 6eosynrec ConsWcants of nC, Y.C. • Proposed Soil Gas Sampling 0 80 Locations Feet GN7035 September 2021 \\Raleigh-01\PRJ\K\Kettler\GN7035 Kettler Harnett St\7.0 GIS\MXD\F3 Proposed Soil Gas Locations.mxd 9/3/2021 4:14:15 PM TABLES TABLE 1 PROPOSED SOIL GAS ANALYSIS 19 and 41 Harnett Street, Wilmington, North Carolina 28401 Brownfields Project: Almont Shipping II: NCBP No. 23080-19-065 Sample ID Type Analytical Method Sample Objective Grab samples analyzed for VOCs by EPA Obtain soil gas data to evaluate soil gas SGP-113 Soil Gas Method TO-15; field screening samples for conditions below proposed elevator shaft methane Grab samples analyzed for VOCs by EPA Obtain soil gas data to evaluate soil gas SGP-213 Soil Gas Method TO-15; field screening samples for conditions below proposed building methane Grab samples analyzed for VOCs by EPA Obtain soil gas data to evaluate soil gas SGP-3B Soil Gas Method TO-15; field screening samples for conditions below proposed elevator shaft methane Grab samples analyzed for VOCs by EPA Obtain soil gas data to evaluate soil gas SGP-4B Soil Gas Method TO-15; field screening samples for conditions below proposed building methane Grab samples analyzed for VOCs by EPA Obtain soil gas data to evaluate soil gas SGP-5B Soil Gas Method TO-15; field screening samples for conditions below proposed building methane Grab samples analyzed for VOCs by EPA Obtain soil gas data to evaluate soil gas SGP-613 Soil Gas Method TO-15; field screening samples for conditions below proposed building methane Grab samples analyzed for VOCs by EPA Obtain soil gas data to evaluate soil gas SGP-713 Soil Gas Method TO-15; field screening samples for conditions below proposed building methane Grab samples analyzed for VOCs by EPA Obtain soil gas data to evaluate soil gas SGP-8B Soil Gas Method TO-15; field screening samples for conditions below proposed building methane Grab samples analyzed for VOCs by EPA Obtain soil gas data to evaluate soil gas SGP-9 Soil Gas Method TO-15; field screening samples for conditions below proposed building methane Grab samples analyzed for VOCs by EPA Obtain soil gas data to evaluate soil gas SGP-10 Soil Gas Method TO-15; field screening samples for conditions below proposed building methane Grab samples analyzed for VOCs by EPA SGP-DUP Soil Gas Method TO-15; field screening samples for QA/QC methane Notes: EPA indicates Environmental Protection Agency QA/QC indicates Quality Assurance/Quality Control VOCs indicates Volatile Organic Compounds All soil gas probes will be installed between 5 and 9 feet below ground surface Page 1 of 1