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HomeMy WebLinkAbout20092_Purple Heart Homes_Additional Assessment Package_20170222 State of North Carolina | Environmental Quality | Waste Management 1646 Mail Service Center | 217 West Jones Street | Raleigh, NC 27699-1646 919 707 8200 T February 22, 2017 Sent Via Email Mr. John Gallina Purple Heart Homes P.O. Box 5355 Statesville, NC 28687. jgallina@phhusa.org Subject: Additional Assessment for Select Occupancy Purple Heart Homes 755 Washington Avenue Statesville, Iredell County, North Carolina 28677 Brownfields Project Number 20092-16-049 Dear Mr. Gallina: The North Carolina Department of Environmental Quality (DEQ), Brownfields Program has reviewed the Request for Temporary Occupancy letter dated February 21, 2017 for the Purple Heart Homes facility located at 775 Washington Avenue in Statesville, Iredell County submitted by Mr. Howard Goldberg. Based on our review of the available assessment documentation for the Brownfields Property, additional assessment activities as outlined below are required to assist in making risk management decisions for occupancy of the select office areas outlined on the attached Figure 1. Based on the potential for suspected soil and groundwater impacts at the Brownfields Property to have created a vapor intrusion concern within the Site buildings, indoor air and sub-slab soil gas sampling will be required prior to occupancy of the office areas as outlined on the attached Figure 1. Prior to conducting field activities, a work plan should be submitted to DEQ for review and approval. The work plan should include a description of the sampling and analytical methods to be utilized and a map depicting the proposed sample locations. The most recent vapor sampling methods consistent with Division of Waste Management Vapor Intrusion Guidance and Inactive Hazardous Sites Program Guidelines for Assessment and Cleanup should be followed. Guidelines can be found at http://portal.ncdenr.org/web/wm/sf/ihs/ihsguide. Request Level 2 QA/QC data packages from a N.C. certified environmental laboratory and ensure that laboratory method detection limits are below applicable standards. Indoor Air Sampling: Collect a minimum of: one indoor air sample within Building 1; three indoor air samples within Building 2 (two within the basement, and one on the upper level); one indoor Mr. John Gallina February 22, 2017 Page 2 air sample within Building 3; and one indoor air sample within Building 4. Collect one duplicate sample for all analysis per every 10% of samples and include a background sample at an exterior, upwind location to the sample points. Analyze all indoor air samples for VOCs by EPA Method TO-15 using 8-hour sample collection times. Sub-Slab/Soil-Gas Sampling: Collect one sub-slab soil gas sample within the basement of Building 2 as identified on the attached Figure 1. Analyze the soil-gas sample for VOCs by EPA Method TO-15. Include a helium leak check prior to sampling. Report and Figures: Upon receipt of analytical data, submit a summary report with a description of field activities, tabulated data in comparison to applicable screening levels, and the laboratory data packet with applicable QA/QC documentation, provide a site plan with locations of sample points, and current site structures. Provide concentration map(s) for contaminants detected above applicable standards. Include a detailed description of current operations since the brownfields property application was submitted. Please note, all sample points may need to be included on the future Brownfields plat. DEQ recommends having sample locations surveyed at the time of collection for use in preparation of the Brownfields plat. Upon review of your request for occupancy of the warehouse areas for storage of construction materials and with the understanding that the warehouse areas will not be occupied by workers for longer than for purposes of loading and off-loading materials, DEQ Brownfields will not require indoor air sampling of the warehouse areas as outlined on Figure 1 at this time. Please note: DEQ Brownfields will be submitting a separate request for Additional Assessment to assist in making risk management decisions for inclusion in the brownfields agreement (BFA) and this letter is associated with occupancy of the areas outlined in Figure 1 only. Additional assessment requests may include soil, groundwater, and additional vapor intrusion sampling. Please provide the Work Plan for additional assessment activities as soon as you are able. If you have questions about this correspondence or require additional information, please feel free to contact me by phone at 704-235-2166 or by email at jordan.thompson@ncdenr.gov. Sincerely, Jordan Thompson Brownfields Project Manager ec: Howard Goldberg, Purple Heart Homes Jerry Deakle, Jerry Deakle & Associates, Inc. Tracy Wahl, DEQ Apex Companies, LLC  10610 Metromont Parkway, Suite 206  Charlotte, NC 28269  T 704.799.6390  F 704.799.6395  apexcos.com Work Plan for Indoor Air and Sub-Slab Vapor Sampling Purple Heart Homes 755 Washington Avenue Statesville, North Carolina Brownfields Project No. 20092-16-049 Revision No. 1 Prepared For: Mr. Howard Goldberg Asst. Secretary, Chief Real Estate Officer Purple Heart Homes PO Box 5535 Statesville, NC 28687 Prepared By: Apex Companies, LLC 10610 Metromont Parkway, Suite 206 Charlotte, NC 28269 March 2017 Prepared by: Reviewed by: Katie Lippard Kathleen Roush, P.G. Senior Project Manager Division Manager – North Carolina Work Plan for Indoor Air and Sub-Slab Vapor Sampling March 16, 2017 Purple Heart Homes, Statesville, NC Page i TABLE OF CONTENTS Section Page 1.0 INTRODUCTION ............................................................................................................. 1 2.0 SCOPE OF WORK .......................................................................................................... 1 2.1 Current Site Conditions ........................................................................................ 1 2.2 Indoor Air Vapor Assessment............................................................................... 1 2.2.1 Indoor Air Sampling and Analysis ........................................................... 1 2.2.2 Sub-Slab Vapor Sampling and Analysis .................................................... 2 2.3 Reporting ............................................................................................................. 3 3.0 QUALITY ASSURANCE AND QUALITY CONTROL MEASURES ................................. 3 4.0 SCHEDULE..................................................................................................................... 3 5.0 HEALTH AND SAFETY .................................................................................................. 4 FIGURES Figure 1 Site Location Map Figure 2 Proposed Sampling Locations Work Plan for Indoor Air and Sub-Slab Vapor Sampling March 16, 2017 Purple Heart Homes, Statesville, NC Page 1 1.0 INTRODUCTION The subject site consists of the Purple Heart Homes property (the Site) located at 755 Washington Avenue, Statesville, Iredell County, North Carolina (Figure 1). Purple Heart Homes submitted a Request for Temporary Occupancy letter to the North Carolina Department of Environmental Quality (NCDEQ) on February 21, 2017. The NCDEQ responded in a letter dated February 22, 2017, requesting that additional assessment be conducted to assist in making risk management decisions for occupancy of the select office areas. 2.0 SCOPE OF WORK The proposed work tasks outlined below were designed to verify that possible soil and groundwater impacts have not created a vapor intrusion concern within the office buildings at the Site and to provide the necessary data to obtain the approvals for site occupancy. 2.1 Current Site Conditions The Site consists of two main level warehouse areas, one basement level warehouse area, and four office areas (Figure 2). Based on the Site’s classification as a Brownfields Property, the NCDEQ requested additional assessment activities at the four office areas to be occupied. It is assumed the warehouse areas will not be occupied by workers for long periods of time; therefore, NCDEQ Brownfields does not require indoor air sampling in those areas at this time. 2.2 Indoor Air Vapor Assessment 2.2.1 Indoor Air Sampling and Analysis In an effort to help identify if vapor intrusion from impacted soil and groundwater originating from the Site is impacting the site buildings, Apex will collect six indoor air samples; one sample from Building 1; three samples from Building 2 (two within the basement, and one on the upper level); one sample from Building 3; and one sample from Building 4. The proposed sample locations are shown on Figure 2. The indoor air samples will be collected in accordance with procedures outlined in the June 2015 USEPA OSWER Technical Guide For Assessing and Mitigating the Vapor Intrusion Pathway from Subsurface Vapor Sources to Indoor Air, the October 2016 NCDEQ Division of Waste Management (DWM) Inactive Hazardous Sites Branch (IHSB) Steps in Conducting Structural Vapor Intrusion Potential Evaluations Under Inactive Hazardous Sites Branch, and in the April 2014 NCDEQ DWM Vapor Intrusion Guidance. Prior to collecting the indoor air samples, the field team will conduct a survey of the buildings using a calibrated ppb RAE to identify background sources that could impact the air samples and points of vapor entry. All background sources will be recorded in the field notes and if possible, removed from the basement or sample level prior to collecting indoor air samples. Each sample will be collected in a 6-liter Summa canister equipped with a critical orifice flow regulation device to allow an air sample to be collected over an 8-hour period. Each Summa canister and pressure gauge will be “Batch certified”. Appropriate tubing and Swagelok-type fittings will be obtained from the laboratory with the Summa canisters. Work Plan for Indoor Air and Sub-Slab Vapor Sampling March 16, 2017 Purple Heart Homes, Statesville, NC Page 2 The canister vacuum will be measured using a vacuum gauge supplied by the laboratory before and after sample collection. Vacuum measurements and sample collection start and stop times will be recorded in the field notes. Other data recorded will include temperatures at the start and end of the sample period, equipment serial numbers, sampler name, and any comments, as well as relevant meteorological data that can influence indoor air concentration patterns at the time of sampling, such as wind speed, snow or ice cover, significant recent precipitation, and changes in barometric pressure. The critical orifice flow controller will be installed on the canister and the canister will be fully opened at the start of the sample collection period. The canister valve will be fully closed at the end of the sample period and the canister vacuum will be measured and recorded immediately after canister retrieval. Any samples where the canister reached atmospheric pressure will be rejected. The sample will be submitted to a North Carolina-certified environmental laboratory for analysis of volatile organic compounds (VOCs) by Environmental Protection Agency (EPA) Method TO- 15. 2.2.2 Sub-Slab Vapor Sampling and Analysis Apex will install and sample one temporary sub-slab vapor point within the basement of Building 2. Apex will avoid cracks and joints in the slab. Weather conditions will be recorded before, during and following sampling activities and will include temperature, barometric pressure, wind speed, and humidity. The sub-slab sample will also be collected in accordance with procedures outlined in the guidance documents outlined above. At the sampling location, a hammer drill will be utilized to drill a 5/8-inch diameter hole through the concrete/asphalt material. A Vapor Pin, consisting of a two inch, barbed, brass tube with a silicone sleeve measuring ¾-inch in diameter will be hammered into each drilled hole. The vapor point will be purged with a low flow air pump to remove any air introduced to the sub-slab airspace during installation, as well as the ambient air within the sample tubing. In order to minimize ambient air intrusion, an air flow rate less than 200 milliliters per minute will be maintained during purging and sampling. While purging, the sample point will be covered with either a plastic bag or bucket and filled with helium to test for leaks in the sample point construction. A 1-Liter Tedlar bag will be connected to the sample point tubing and filled with some of the purged air to test using a helium detector. If a detection is noted then the sample point will be reconstructed prior to sampling, as necessary. A supplemental leak detection test will be performed following point installation using a water dam around the surface of the boring. After purging, a representative sample of sub-slab soil gas will be collected from the sampling point over a half-hour period using laboratory supplied 1-Liter batch-certified Summa canister equipped with a properly regulated flow controller and fittings. The sample will be collected by attaching the sample point tubing to the 1-Liter summa canister and then opening the canister valve. The time and initial pressure of the summa canister will be recorded for each sample collected. Actual collection durations may vary slightly during sampling due to variations within the soil matrix where each sample is collected. The canister vacuum will be allowed to drop to approximately -5” Hg, then the canister valve will be closed and the sample collection completion time and final canister pressure will be recorded. The canister and flow controller identification numbers will also be recorded for each sample location. The sample will be submitted to a North Carolina-certified environmental laboratory for analysis of VOCs by EPA Method TO- 15. Work Plan for Indoor Air and Sub-Slab Vapor Sampling March 16, 2017 Purple Heart Homes, Statesville, NC Page 3 2.3 Reporting Upon receipt of the analytical data, a letter report will be prepared which summarizes the results of the indoor air and sub-slab vapor assessment activities. The report will be submitted to the client within three weeks of receipt of the analytical results for review. Apex will then submit the report to the NCDEQ for approval. The report will be sealed by a North Carolina Licensed Geologist and will include results from the activities described above. 3.0 QUALITY ASSURANCE AND QUALITY CONTROL MEASURES In order to verify the precision of laboratory analytical techniques, Apex will collect a blind duplicate sample indoor air sample. A total of seven indoor air vapor samples will therefore be collected during the sampling. An ambient background sample will also be collected from an upwind location on the property. The ambient sample will be used to confirm that if any constituents are detected, they are not originating from an upwind source. In accordance with the letter dated February 22, 2017 from NCDEQ, a helium leak check will be conducted prior to collecting the sub-slab sample to insure that proper sub-slab installation procedures were followed and no leaks were identified prior to sampling. The helium leak check will be conducted in lieu of a duplicate sample. The following quality assurance and quality control measures will be utilized during the air sampling event. Laboratory supplied teflon tubing will be utilized at the location, and tubing will not be reused. Field personnel will don gloves when collecting samples and/or handling sample tubing or fittings and flow chokes. At each sample location, a summa canister will be used to collect the air sample. The fittings and flow chokes used to fill the canister will be dedicated to that sample and will not be reused between samples. The laboratory will supply the individually certified summa canisters and fittings. This equipment will be decontaminated by the laboratory prior to use at the site. The laboratory tests each canister and fitting to confirm that the equipment has been properly decontaminated prior to use, and that fittings and chokes are intact, without leaks. The laboratory maintains laboratory data confirming that the sampling equipment utilized was properly decontaminated in accordance with EPA protocol. To confirm that leakage to the summa canister did not occur during transport, the vacuum present in the summa canister will be recorded in the field once the sample has been collected. The vacuum in the canister will be measured again by the laboratory upon receipt. The summa canister will not be filled to capacity in the field so that a minimal amount of vacuum remains. This will keep the COCs from precipitating onto the interior canister walls. 4.0 SCHEDULE Apex will begin work on the project immediately following receipt of written authorization to proceed. We anticipate that the field work can be completed within two to three weeks of work plan authorization, depending upon site access and availability. Laboratory data will be available approximately three weeks after the field work is complete. Apex will give verbal results within one week of receipt of the final laboratory analytical data. Work Plan for Indoor Air and Sub-Slab Vapor Sampling March 16, 2017 Purple Heart Homes, Statesville, NC Page 4 5.0 HEALTH AND SAFETY A health and safety plan (HASP) will be prepared for the scope of work outlined above. The HASP will address the health and safety concerns of workers and a copy will be maintained on-site during field activities. A tailgate safety meeting will be held each morning prior to starting field activities, when a new person joins the work group, when activities change from those planned, and at the beginning of each work day to review the scope of work and review safety concerns. FIGURES ")!? !? !? !? !?!? W A S H I N G T O N A V E NC OneMap, NC Center for Geographic Information and Analysis, NC 911Board CHECK BY: KS DRAWN BY: SP DATE: 03/07/17 SCALE: AS SHOWN CAD NO.: 510477-002 PRJ NO.: 510477-002 FIGURE PROPOSED SAMPLE LOCATIONS PURPLE HEART HOMES755 WASHINGTON AVENUESTATESVILLE, NORTH CAROLINA ³ 0 40 80 Feet 2 !?MAIN LEVEL INDOOR AIR SAMPLE !?BASEMENT INDOOR AIR SAMPLE ")BASEMENT SUB-SLAB VAPOR SAMPLE OFFICE AREAS TO BE OCCUPPIED WAREHOUSE AREA TO BE OCCUPPIED - MAIN LEVEL WAREHOUSE AREA TO BE OCCUPPIED - BASEMENT LEVEL 1 2 3 4 Sent Via Email March 17, 2017 Mr. Howard Goldberg Purple Heart Homes, Inc. P.O. Box 5355 Statesville, NC 28687 hgoldberg@phhusa.org Subject: Work Plan Approval Purple Heart Homes 755 Washington Street Statesville, Iredell County, North Carolina 28687 Brownfields Project Number 20092-16-049 Dear Mr. Goldberg: The North Carolina Department of Environmental Quality (DEQ) Brownfields Program received and reviewed the Work Plan for Indoor Air and Sub-Slab Vapor Sampling dated March 8, 2017 and provided comments by e-mail on March 13, 2017. A revised Work Plan for Indoor Air and Sub-Slab Vapor Sampling dated March 16, 2017 was received and subsequently reviewed by DEQ. All comments have been incorporated; therefore, the revised Work Plan for Indoor Air and Sub- Slab Vapor Sampling is approved. Be advised that this approval from the Brownfields Program does not waive any applicable requirement to obtain any necessary permits, licenses, or certifications for the above listed activities nor does it waive any requirement to comply with applicable law for such activities. If you have any questions, please feel free to contact me at 704-235-2166, or via e-mail at jordan.thompson@ncdenr.gov. Sincerely, Jordan Thompson Brownfields Project Manager ec: Katie Lippard, Apex John Gallina, Purple Heart Homes, Inc. Tracy Wahl, DEQ