HomeMy WebLinkAboutFinal SMWP Southside East Redevelopment - Final 5-30-12
May 30, 2012
Mr. Brad Atkinson, Brownfields Project Manager
N.C. Brownfields Program Division of Waste Management
N.C. Department of Environment and Natural Resources
401 Oberlin Rd, Suite 150
Raleigh, NC 27605-1350
Subject: SOILS MANAGEMENT WORK PLAN SOUTHSIDE EAST
REDEVELOPMENT (FORMER ROLLING HILLS SITE)
DURHAM, NORTH CAROLINA
BROWNFIELDS PROJECT #: TBD
URS – NORTH CAROLINA PROJECT NO. 38854599
Dear Mr. Atkinson:
URS Corporation – North Carolina is providing this revised Soils Management Work Plan for
your review. It has been edited to remove the specification of using any known contaminated soil
and construction debris buried on-site as geotechnically engineered fill on the south side of the
site. As an alternative, all soil debris that needs to be removed from the northeastern portion of
the site will be managed and disposed of off-site as asbestos-containing waste.
Additional information typically requested by regulatory oversight (such as the Contractor
Health and Safety Plan, identification of receiving facilities, etc.) will be available upon
Contractor receipt of authorization-to-proceed. If additional information not in the attached Soils
Management Work Plan is required, just let me know.
As you are aware time is of the essence regarding the implementation of this plan. All parties
involved would be greatly appreciative if this plan could be finalized in an expedited manner. If
you have any questions, please contact me at 704-522-0330.
Sincerely,
URS Corporation – North Carolina
Michael Fulkerson, Environmental Scientist
CC: Richard Valzonis
Karl Schlachter
Randy Rhoads
Richard Lesser / Leonard Slosky
Enclosure: Soils Management Work Plan with one Figure
Attachment 1, Witness Barrier Tech Spec Sheet
Addendum A, Asbestos Design
Page 1
SOILS MANAGEMENT WORK PLAN
SOUTHSIDE EAST REDEVELOPMENT PROJECT
(FORMER ROLLING HILLS SITE)
BROWNFIELDS PROJECT #: TBD
URS – NORTH CAROLINA PROJECT NO. 38854599
May 30, 2012
Background Summary
The Southside East Redevelopment property (Site or Subject Property) was historically used for
residential purposes dating back to at least 1913. Until recently the Site consisted of eighty-six
separate former residential parcels sited on approximately twenty acres of land in the former
Rolling Hills Subdivision in Durham, Durham County, North Carolina. The City of Durham is
currently working to redevelop the property with high-quality, mixed-income and market-rate
housing. With these objectives, the Rolling Hills subdivision was acquired in total by the City of
Durham in 2011.
According to public records review on the Durham County Geographic Information System, the
City of Durham is listed as the current owner of the property. The Site is described more fully
as:
“Approximate 20-acre parcel south of the Intersection of South Roxboro Street and
East Lakewood Avenue. Bordered on the west by S. Roxboro Street, the south by
Piedmont Street, and the north by East Lakewood Avenue. On the east, the site is
bordered by a shopping center.”
McCormack Baron Salazar (MBS) contracted AECOM Technical Services, Inc. to conduct a
Phase I Environmental Site Assessment (ESA) and subsequent Phase II ESA. The result of the
Phase II indicated soil and groundwater contamination onsite above NC DENR Inactive
Hazardous Sites Branch (IHSB) Residential Soil Remediation Goals (SRG) and IHSB Protection
of Groundwater SRG for lead and polycyclic aromatic hydrocarbons (PAHs). Almost all of this
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soil contamination above North Carolina standards is restricted to soils interstitial to buried
building debris - apparently used to backfill a former ravine on the northeast portion of the
property. Two smaller areas (~ 150 cubic yards each) of contaminated soils are also present
onsite, and are not associated with a significant amount of building debris. AECOM utilized the
August 2011 IHSB Residential and Protection of Groundwater SRGs in their Phase II report. The
IHSB provides a semi-annual update to the SRG table. URS reviewed and compared the August
2011 SRGs to the most current February 2012 SRG to ascertain any applicable differences in
previously reported contaminants on site. No changes in SRGs for lead or PAHs were observed
in the February 2012 SRG guidance table.
Within the former ravine, based on review of chromatograms, North Carolina DENR has agreed
that the soils interstitial to building debris are not impacted by total petroleum hydrocarbons; the
PAH’s likely originated from burning of the debris prior to final grading on the site. Most of the
debris consists largely of concrete, brick, and asphalt fragments, as well as tile, glass, wood, and
gravel. Asbestos Containing Materials (ACMs) are also present in the debris, but were restricted
to two exploratory trenches within the ravine. No regulated levels of asbestos were observed in
the interstitial soils. Nevertheless, soils interstitial to debris from the former ravine will be
considered ACM contaminated and disposed of as asbestos containing waste.
The two additional contaminated areas that have been observed, both without a significant
proportion of debris, are:
~ 150 cubic yards of soils adjacent to the former ravine is contaminated with PAHs, and
~ 150 cubic yards of soils in the center of the site is impacted by Total Petroleum
Hydrocarbons (TPH). However, constituents of petroleum (such as benzene or PAHs) in
this area were not observed to exceed relevant action levels.
Groundwater impacts were observed at two locations: Benzene at 1.3 micrograms per liter
(μg/L) at the property perimeter which is believed to be derived from an offsite source to the
southeast and naphthalene at 9.8 μg/L in an area more central to the site. The naphthalene-
impacted groundwater is co-located with the area of soils impacted by petroleum hydrocarbons,
even though naphthalene above North Carolina standards was not observed in this area’s soils.
MBS, acting as agent for the City of Durham, plans to redevelop the site with new residential
housing. This Soil Management Work Plan (SMWP) describes the remediation approach for the
onsite impacted soils and associated construction debris.
It is estimated that 26,700 cubic yards (yds3) of soils, contaminated soils, construction debris,
and ACMs were placed in the former ravine. Of this volume, 9,600 yds3 must be removed to
allow for site utilities (such as stormwater drainages) and geotechnically suitable building
foundations. The following table provides a reference name, general location on site, and
estimated quantity of all known ACM, contaminated soils, and debris impacted above relevant
North Carolina residential standards.
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Table I
Area Name Location Estimated
Area
Estimated Soil /
Debris Volume To
Be Managed
Known
Constituent
Impacts
Former ravine Northeast corner 1.9 acres 9,600 yds3 PAHs, ACM,
Lead1
SS-10/TW-1 Central/West Negligible 150 yds3 TPH
TP-22 NE corner,
immediately
adjacent west to
former ravine
Negligible 150 yds3 PAHs
Figure 1 (attached) depicts the areas of contamination referenced in Table I above.
MBS proposes to transport, for off-site disposal at a properly permitted facility, all contaminated
soils and construction debris that will be displaced during construction, with oversight by the
North Carolina Brownfields Program. This SMWP identifies the engineering and administrative
controls appropriate for management of the contaminated soils and debris. Because the potential
also exists for additional areas of soil contamination not already identified in the extensive Phase
II assessment conducted onsite, appropriate engineering and administrative controls are also
specified in this SMWP for these areas. Because construction is not expected to intersect the
groundwater table, groundwater remediation is not addressed in this SMWP. However, this
SMWP does provide specifics for additional groundwater monitoring, where warranted to
facilitate overall site development and refine the extent of impacts to these environmental media.
Surface water runoff, which is expected to accumulate during excavation of the former ravine,
will be subject to appropriate engineering controls, as described below.
All soils remaining onsite that exceed North Carolina residential action levels will be covered
with a brightly-colored, permeable witness barrier and at least two feet of a clean soil cap.
Importantly, much of this clean soil cap will extend beneath the site’s future hardscape
improvements. Based on the need for sufficient subsurface structural support requirements
beneath the site hardscape, the thickness of the clean soil cap that overlies contaminated
materials will typically exceed four to six feet. Importantly, all utility trenches will be placed in
clean fill, so that future utility maintenance need not be concerned with management of
contaminated materials. Importantly, wherever utility trenches are placed over known
contaminated materials, the trenches will be lined with the permeable witness barrier, to help
1 Materials proved to be non‐hazardous waste
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future workers distinguish between environmentally clean versus environmentally contaminated
media.
This SMWP may need to be amended as the design/build process continues at the site.
Amendments for DENR review and comment may include, but not be limited to:
Segregation techniques to assure that if ACMs prove to be substantially less than
currently expected, these materials can be excavated for alternative disposal options, as
allowed by Department of Health and Human Services (DHHS).
Soil-vapor barriers, if warranted, where groundwater contamination may be derived from
an off-site source.
As to prevent confusion within this SMWP, until alternative disposal options present a viable
consideration for the design/build process they will not be addressed. If in the future alternative
disposal options appear to be viable, discussions with DENR will be engaged, and an addendum
to this SWMP will be submitted for approval prior to the implementation of disposal options not
contained within this SMWP.
Soil Management Work Plan Requirements
General
Contaminated soils and ACMs that are displaced during construction activities will be subject to
the provisions of this SMWP.
The contractor is responsible for visually inspecting all soils and construction debris excavated
from the former ravine and removing items classifiable as universal wastes and/or PCB bulk
product wastes such as, but not limited to, electrical ballasts, thermostats, and fluorescent lights.
Importantly, universal wastes or bulk product wastes were not observed in any of the exploratory
trenches previously advanced onsite. Universal wastes and bulk product wastes will be removed
and temporarily stored onsite for subsequent management offsite at a properly permitted RCRA
Subtitle C or TSCA permitted facility. Discovery of environmentally sensitive materials that
were not encountered during site characterization activities, such as buried drums, will trigger a
contractor stand-down and immediate assessment by a qualified environmental professional.
DENR will be notified, and an appropriate course of action will be collaboratively determined
with the City of Durham, MBS, and DENR.
Whenever soils outside of the former ravine are to be graded or managed, a daily surveillance by
a North Carolina accredited inspector will be performed, and a daily report prepared to document
the inspection, results, and any needs for corrective actions. Whereas the former ravine has been
observed to contain mixed soil/debris with a percentage of debris between 40% to 55% in the
middle of the former ravine, with less debris present on the flanks of the former ravine, if
additional areas of possible contamination and/or debris are encountered based on substantial
visual or olfactory evidence of contamination, with particular attention to building materials that
are suspect for ACM, such discoveries will trigger, within 24 hours, subsequent notification to
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the DENR contact in the Brownfield Section or other appropriate agency contacts. All newly-
discovered areas of contamination, if similar in nature to known contamination, will be subject to
the identical engineering and administrative controls that apply to the former ravine area, unless
consultation with DENR prompts modified controls.
Throughout this SWMP, the term “Environmental Representative” is used to refer to an
individual with the proper expertise, training, and licensure as required to perform the necessary
task. Accredited personnel will be used in instances decisions regarding asbestos are
required. At other times, the Environmental Representative may be an individual familiar with
the scope of the task being performed.
Definitions and Description of Materials
Overall, soils and debris excavated during construction activities can be grouped into five major
categories:
1. Former Ravine Soils and Debris with Asbestos, Suspect Asbestos, Requiring
Removal to Facilitate Construction
Defined as all soils and construction debris to be excavated from the 1.9 acres constituting the
former ravine, as shown in Figure 1. These soils may be contaminated with asbestos, PAHs,
and/or lead. All debris and interstitial soils removed from this area will be disposed of through a
direct load process into lined containers (either trailer, dumpster, or alternate Department of
Transportation-approved containers for over-the-road transport) for disposal at an approved
asbestos facility.
Trucks and construction vehicles such as excavators in contact with soils and construction debris
from the former ravine area will be decontaminated using a low-pressure water wash prior to
exiting the work area. Brooming concurrent with the low-pressure wash may be performed to
remove sticky soils, if present.
2. Former Ravine Soils and Debris that Do Not Require Removal to Facilitate
Construction
Materials from the 1.9 acre former ravine that need not be removed to facilitate installation of
utilities or building foundations will be covered with a permeable witness barrier, specified as
MIRAFI HP570 Geotextile. A technical specification sheet for this product is included as
Attachment 1 to this SMWP.
3. PAH Impacted Soils (TP-22)
Defined as approximately 150 yds3 of soils contaminated by PAHs near TP-22, as shown on
Figure 1. Debris does not constitute more than 10% of the materials in this area. Soils and
debris removed from this area will be disposed of through a direct load process into lined
containers (either trailer or dumpster) for disposal (or use as daily cover) at a properly permitted
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facility.
After all visually and olfactory impacted PAH impacted soils are removed from this area,
confirmation sampling for PAHs will be performed.
4. Petroleum Impacted Soils (SS-10)
Defined as approximately 150 cubic yards of soils contaminated by petroleum hydrocarbons near
SS-10, as shown on Figure 1. Debris does not constitute more than 10% of the materials in this
area. Soils and debris removed from this area will be disposed of through a direct load process
into lined containers (either trailer or dumpster) for disposal (or use as daily cover) at a properly
permitted facility.
After all visually and olfactory impacted petroleum impacted soils are removed from this area,
confirmation sampling for TPH, VOCs, and PAHs will be performed. If contaminant
exceedances of North Carolina residential standards are observed, additional excavation will be
performed followed by testing until remaining materials are demonstrably safe for residential
land uses.
5. Non-Impacted Soils (Remaining Soil Onsite)
Defined as soils deemed to be uncontaminated based on
previous site geotechnical and environmental work, and
confirmed during site grading by field screening by PID, visual, and olfactory review by
a North Carolina accredited asbestos inspector, and
not located within the former ravine,
nor located near areas SS-10 and TP-22.
Soils deemed “non-impacted” will be used onsite in accordance with the site plan specifications,
or shipped offsite for re-use as clean fill or as daily cover at an accepting landfill. Surplus “non-
impacted” soil may be stockpiled on the southern portion of the site for future re-use as clean fill
or as daily cover at an accepting landfill.
Execution - Engineering and Administrative Controls
Former Ravine Area
As detailed in Addendum A to this SMWP, a North Carolina-accredited Air Monitor will
generate three series of air tests during work in the former ravine area: 1) employee personnel
exposures, 2) at the exclusion zone perimeter, and 3) at the property perimeter. The North
Carolina-accredited Air Monitor will collect excavator / operator personal initial air samples for
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both lead and asbestos exposure. Ambient air samples will also be collected upwind and
downwind of the excavation/work area, and also at the site perimeter, for analysis of asbestos
and lead. The personal air sample and excavation/work area results will be compared to the
OSHA PELs for lead, and if an OSHA Negative Exposure Assessment is confirmed, sampling
for lead will be terminated. Personal air monitors, exclusion zone monitoring, and property
perimeter monitoring for asbestos will continue throughout excavation in the former ravine area.
Should downwind measurements show concentration excursions, the Environmental
Representative will review the situation to determine if changes in operating procedures,
increased working distances or enhanced dust control methods are needed to suppress dust
release.
The Environmental Representative shall provide oversight for the removal of materials that
present a puncture or tear hazard to the lining of the trailer/dumpster. Materials such as metal
rebar, glass, and/or ceramic tile may need to be separated by accredited personnel from the
remaining soil and debris so as to prevent accidental discharge to the atmosphere while the
material is in transit. Alternatively, this material can be direct-loaded into the center of the truck,
so that contact with the enveloping Visqueen is prevented.
Isolated Areas (SS-12 & TP-22)
Contaminated soils and debris in the two isolated areas in the vicinity of SS-12 and TP-22 will
be excavated and transported offsite for disposal or use as daily cover. It is expected that the
soils from these two areas will be directly loaded into trailers/dumpsters and removed from the
site in a timely manner.
If complete excavation cannot be accomplished in one day, any stockpiled contaminated soil will
be covered with plastic sheeting to reduce the potential for releases due to ambient winds and/or
precipitation.
Confirmatory samples will be collected from the two locations of previously impacted soil (SS-
12 and TP-12). The Environmental Representative will collect four sidewall and one bottom soil
samples. Additional samples will be collected if the excavated volume exceeds 150 yds3, at a
proportionate frequency to the original design. Samples will be analyzed for constituents
previously detected above action levels at these locations.
Non-Impacted Soils (Remaining Soil Onsite)
The non-impacted soils make up the remaining soils at the site. The name “non-impacted” is not
an assurance that unknown impacts are not located in this area. However, based on the extensive
sampling that has occurred on site it is unlikely unknown soil impacts will be encountered. To
manage this small, but non-zero risk, whenever soils outside of the former ravine are to be
graded or managed, a daily surveillance by a North Carolina accredited inspector will be
performed, and a daily report prepared to document the inspection, results, and any needs for
corrective actions. Soils deemed “non-impacted” will be used onsite in accordance with the site
plan specifications. In the event a surplus of soil is located at the site, these soils may be sent
offsite.
Page 8
If during excavation in the non-impacted soil area, materials are discovered that resemble soil
and debris from the former ravine area, the contractor should temporarily cease work, and notify
the Environmental Representative for further direction.
Additional Considerations
Contaminated Stockpiled Soils
Although not currently anticipated, in the event that contaminated soils need be stockpiled on
site prior to final disposition, stockpiles will be placed onto and covered with polyethylene
(Visqueen) sheeting, which will be secured using hay bales or similar methods to maintain
integrity. The soils will be stockpiled in a manner to prevent water and/or sediment from the
impacted surrounding soils and from entering the site’s storm water system or from flowing
offsite. The stockpile and containment will be constructed in a manner consistent with
documentation found in the NCDENR IHSB Guidelines for Assessment and Cleanup guidance
documents. The site contractor will minimize the necessity of stockpiling soils on the site.
Dewatering Effluent Treatment & Discharge Plan Requirements
At this time construction activities are not planned that will intersect groundwater to the point of
requiring dewatering. If the water table is intersected and dewatering is required, a Dewatering
Effluent Treatment & Discharge Plan will be prepared which identifies the means, methods, and
procedures for temporary storage, removal of solids, and discharge/disposal of dewatering
effluent generated during the project.
Site Safety and Health – Special Considerations
Work at the site will comply with the Occupational Safety & Health Administration (OSHA)
rules for trenching and excavation as defined in 29 CFR 1926.651 and .652. A Health and Safety
Plan will be prepared after receipt of notification-to-proceed.
If work onsite encounters newly discovered conditions that could create a hazard addressed
under 29 CFR 1910.120, the contractor’s Health and Safety Plan requirements for such
conditions will be invoked. General safety and health procedures will be implemented to account
for the handling of contaminated or potentially contaminated materials and verify that conditions
associated with the potentially contaminated soils, surface water runoff, or groundwater do not
pose a hazard to onsite workers.
Site workers in the vicinity of active excavation of contaminated materials will follow industry-
standard health and safety procedures, including but not limited to, half-face respirators, steel-toe
rubber boots, and disposable nitrile gloves, as warranted or as directed by the onsite
Environmental Representative, North Carolina-accredited Asbestos Inspector, Designer, Air
Monitor, or the site Health and Safety Officer.
Page 9
Additional Site Characterization
Prior to start of construction in the ravine area, MBS proposes to assess whether the historically
infilled ravine has leached contaminants into site groundwater, and affirm whether an historic
off-site source may have impacted groundwaters on-site. To accomplish this task, four (4)
groundwater monitoring wells will be advanced at the locations indicated on Figure 1. Three
wells will be positioned in the former ravine, to assess whether known contaminants, in
particular VOCs, may be impacting groundwater in this area. One well will be positioned to
assess whether a narrow plume of contaminants may be originating from southwest of the site.
Specific well locations will be surveyed in prior to drilling, so that the wells in the former ravine
are located beneath proposed building slabs. Relative stickup elevations of all wells will also be
established, to refine the groundwater flow direction in the former ravine and immediately
upgradient. Sampling will be performed for volatile organic contaminants by 8260 and
polyaromatic hydrocarbons by 8270SIM. If use of a hollow-stem auger rig cannot penetrate
through the buried debris, close coordination with NCDENR can identify alternative locations
that can meet the performance objectives. The three wells in the ravine will be plugged and
abandoned after confirmation of receipt of samples by the laboratory. The well on the property
boundary will be abandoned only upon consultation with NCDENR.
Additional Considerations
Figure 1 shows that contaminated materials will remain both beneath buildings, as well as
beneath a future Durham street Right-of-Way. An appropriate deed encumbrance or title
restriction will be entered for these areas.
Bibliography on CD
February 2012, Phase I Environmental Site Assessment, Rolling Hills Development Site,
Durham, Durham County, North Carolina, prepared by AECOM, Raleigh, NC
March 2012, Phase II Environmental Site Assessment, Southside East Redevelopment (formerly
Rolling Hills Redevelopment), Durham, Durham County, North Carolina, prepared by AECOM,
Raleigh, NC
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TenCate Mirafi HP570
Page 12
Page 13
Asbestos-specific Addendum A to the
Soils Management Work Plan
Page 14
A. Overview
1. The former ravine in the northeast area of the site contains mixed soil/debris with a percentage of
debris up to 40% to 55 % in the middle of the former ravine, with less debris present on the flanks
of the former ravine. Because asbestos building materials were not separated and disposed of as
asbestos waste all of the excavated material that contains debris will be treated as ACM waste.
This debris removal will be performed under the oversight of a North Carolina accredited
asbestos air monitor. These excavated mixed materials will be transported in lined containers for
off-site disposal as asbestos waste.
2. The work will be conducted during daylight hours Monday through Saturday.
3. Two conditions will determine the completion of ACM mixed waste removal from the ravine site.
a. All of the foreign material defined by the colored areas on Figure 1 from AECOM 2012
Phase II Report has been removed, or
b. The depth of the excavation reliably passes the depth that will be disturbed during full
project activity.
4. There are no other known pockets of ACM mixed debris on the site. To confirm this there will be
daily observations by an accredited asbestos inspector, with a daily record to confirm the absence
of suspect materials or, if noted, the resolution to these discoveries.
B. Project Procedures
1. Excavation.
a. D. H. Griffin Inc. will conduct excavation in the ravine. Three to four air conditioned
enclosed cab excavators will be in service in the ravine. The excavator operators, all
North Carolina accredited personnel, will be in PPE that includes half face HEPA
filtration respiratory protection or greater if the Initial Exposure Assessment and/or if the
site-specific personnel monitoring for both lead and asbestos require it.
Page 15
b. Dust control will be by spray wetting of the material as it is extracted from the ravine, to
the rolloff container or truck, and during loading into the rolloff.
2. Waste.
a. Excavated materials will be directly loaded into poly lined rolloff containers or trucks.
When full they will be covered with poly before being moved off site. The employees
installing the poly will be North Carolina accredited. Their PPE will include half face
HEPA filtration respiratory protection or greater if the Initial Exposure Assessment
and/or if the site-specific personnel monitoring for both lead and asbestos require it.
There will be an estimated ten loads per day.
b. Materials such as metal rebar, glass, and/or ceramic tile may need to be separated from
the mixed soil and debris so as to prevent accidental tearing of the liner of the waste
containers. The Environmental Representative shall determine on a case by case basis
whether the protection of the environment is better served by decontaminating these
items at the wash station or by direct-loading them into the center of the waste container.
c. Universal wastes and/or PCB bulk products will be segregated, decontaminated and
temporarily stored onsite for subsequent management offsite at a properly permitted
RCRA Subtitle C or TSCA permitted facility.
d. The trucks that handle the ACM waste will be washed down at an on-site wash station.
The drainage from the wash station will go into the excavation and will contribute to the
dust mitigation during excavation. The ACM mixed waste will be transported to an
approved landfill that will acknowledge acceptance of the waste as ACM material.
Sequentially numbered North Carolina Asbestos Waste Shipment Records must be
provided for every load of ACM waste.
3. Monitoring
a. Ravine area. A North Carolina-accredited Air Monitor will collect excavator operator
personal initial air samples for both lead and asbestos exposure. Ambient air samples
will be collected upwind and downwind of the excavation work area for analysis of
asbestos and lead. The personal air sample and excavation work area results will be
compared to the OSHA PELs. For lead, if an OSHA Negative Exposure Assessment is
confirmed the sampling for lead will be terminated. For asbestos, operator personal
exposure and the upwind/downwind sampling for asbestos will continue in the former
ravine area as long as the excavated materials are treated as ACM waste. Should
downwind measurements show concentration excursions the Environmental
Representative will review the situation to determine if changes in operating procedures,
increased working distances or enhanced dust control methods are needed to suppress
dust release.
Page 16
b. Project perimeter. From the time that ravine excavation begins to as long as the excavated
materials are treated as ACM there will be daily air monitoring at the property perimeter.
The samples will be analyzed for both asbestos and lead.
C. Ravine ACM completion.
1. The precise depths of the excavation in the ravine will be determined during the work. In
cooperation with the excavator operators the accredited Air Monitor will confirm when the
excavation has entered native soil.
2. The ravine will be the routing for the development’s new storm water system. The elevation of
this routing is known. If the ravine’s debris excavation extends to more than two feet below this
routing the excavation will be terminated at this depth. The remaining debris will be covered with
a brightly colored, permeable witness barrier and at least two feet of a clean soil cap so that future
utility maintenance need not be concerned with disturbance of remaining debris-containing
materials.
3. When both of these criteria are met the asbestos portion of the ravine work will have been
completed.
D. Outside the Ravine Area
1. The testing conducted during the Phase II Environmental Assessment for this site did not identify
ACM beyond the ravine area. The possibility exists that there may be unexpected pockets of
building debris that are uncovered during site grading to finish elevations.
2. An accredited asbestos inspector will be on site at all times during this grading work. A daily
report will state the following:
a. that no suspect ACM was seen, or
b. that trivial amounts of non-friable suspect ACM were picked up and bagged by North
Carolina accredited personnel for disposal as ACM waste, or
c. that a quantity of suspect ACM was observed which deemed that grading be halted at this
location, and that the accredited project designer will review the situation and recommend a
course of action.
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Page 17
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