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HomeMy WebLinkAbout07020 Rusak WP-DEQ Approval 20190731 July 31, 2019 Sent Via E-Mail Robert C. Foster, LG Wood Environmental & Infrastructure Solutions, Inc. 2801 Yorkmont Road, Suite 100 Charlotte, North Carolina 28208 rob.foster@woodplc.com Subject: Brownfields Work Plan Approval-Indoor Air Sampling Rusak Brownfields Property Charlotte, Mecklenburg County Brownfields Project No. 07020-03-060 Dear Mr. Foster, The Department of Environmental Quality (DEQ) Brownfields Program received the Revised Work Plan for Indoor Air Sampling and Analysis dated July 30, 2019 for the above referenced Brownfields Property. DEQ Brownfields reviewed this document, and determined that comments made by DEQ Brownfields to the previous versions of this work plan (dated July 16) have been incorporated as requested. Therefore, DEQ Brownfields approves the Work Plan dated July 30, 2019. Please be advised that this approval does not waive any applicable requirement to obtain any necessary permits, licenses or certifications which may be required from other state or local entities. If you have questions about this correspondence or require additional information, please feel free to contact me 704-235-2195 or by email at joselyn.harriger@ncdenr.gov. Sincerely, Joselyn Harriger Supervisor Brownfields Property Management Unit ec: Mitchell, Jeffery G. jefferyg.mitchell@cms.k12.nc.us Carolyn Minnich, carolyn.minnich@ncdenr.gov Wood Environment & Infrastructure Solutions, Inc. 2801 Yorkmont Road, Suite 100 Charlotte, North Carolina 28208 Licensures: NC Engineering F-1253, Geology C-247 T: 704-357-8600 www.woodplc.com ‘Wood’ is a trading name for John Wood Group PLC and its subsidiaries July 30,2019 Ms.Joselyn Harriger,Supervisor,Brownfields Property Management Unit North Carolina Department of Environmental Quality Division of Waste Management, Brownfields Program 217 West Jones Street Raleigh, North Carolina 27699-1646 Subject:Revised Work Plan for Indoor Air Sampling and Analysis Former Rusak Property Marie G. Davis School 3331 Griffith Street and 3004 Bank Street Charlotte, North Carolina Brownfields Project Number 07020-03-60 Wood Project No: 6228-18-0486 Dear Ms.Harriger: Wood Environment & Infrastructure Solutions, Inc. (Wood)is pleased to submit this revised Work Plan outlining assessment activities proposed for the above-referenced site.Included in this Work Plan is an outline of our understanding of the project information, our proposed scope of services and schedule. Project Information The subject property encompasses approximately 0.24 acres and was formerly occupied by a metal-plating business.In 2004, the Charlotte Mecklenburg Board of Education (CMBE) demolished the old structures on the property and Wood, then MACTEC Engineering and Consulting, Inc. (MACTEC), performed soil remediation at the site. CMBE redeveloped the property as an open, grass covered lawn associated with a new school on the adjacent property (Figure 1). In accordance with the Agreement, upon completion of the new building and prior to the occupation of the new school building, a permanent groundwater monitoring well (MW-1) was Revised Work Plan for Indoor Air Sampling and Analysis July 30,2019Former Rusak PropertyCharlotte,North Carolina 2 installed in June 2008 downgradient (southwest) of the excavation area. The monitoring well was screened across the water table, and sampled for Volatile Organic Compounds (VOCs), by EPA Method 8260, every other year through 2016. Wood collected and analyzed three soil-gas samples at the subject property at the request of the North Carolina Department of Environmental Quality (NCDEQ), Division of Waste Management (DWM), Brownfields Programs (BFP)in April 2019 and submitted a Soil-Gas Sampling and Analysis Report (dated May 23, 2019)to our client and the BFP for review. Following review of the report, Ms. Harriger issued a letter (dated June 28, 2019) requesting indoor air testing at the subject property. The proposed assessment activities will be performed in general accordance with the most recent Inactive Hazardous Sites Branch (IHSB)Program Guidelines for Assessment and Cleanup (http://portal.ncdenr.org/web/wm/sf/ihs/ihsguide),dated October 2015 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. Task 1 –Indoor Air Testing Wood proposes to collect five indoor air quality (IAQ)samples to obtain preliminary data on the indoor air quality.The IAQ sampling will be performed in general accordance with the NCDEQ DWM Vapor Intrusion Guidance, (dated March 2018)(https://deq.nc.gov/about/ divisions/ waste-management/waste-management-permitguidance/dwm-vapor-intrusion-guidance). The locations of the proposed IAQ are shown on the attached Figure 2.They include five locations (electrical and mechanical rooms, conference room, faculty lounge/break room and student services)from within the portion of Marie G. Davis Middle School located immediately downgradient of the former contaminant source area. Upon receipt of the 6-liter Summa®canisters from the laboratory, Wood will perform an inspection that the canisters are suitable for use.If the initial vacuum prior to sampling is in excess of 10% lower than the vacuum documented by the laboratory upon shipment, the canister will not be used.Each canister will have a dedicated pressure gauge and flow controller and will be individually certified.Prior to the collection of the IAQ samples, a building survey and pre-sampling evaluation will be completed using the “DWM Indoor Air Building Survey and Sampling Form” attached in the DWM Vapor Intrusion Guidance. Revised Work Plan for Indoor Air Sampling and Analysis July 30,2019Former Rusak PropertyCharlotte,North Carolina 3 Following the completion of the survey and pre-sample evaluation,five primary IAQ samples will be collected from inside the building.One duplicate QA/QC IAQ sample will be collected at one of these locations.In addition, one background ambient air sample will be collected outside the building (in the upwind direction)during the sampling event.The canisters for the interior and exterior samples will be placed at an approximate height of 3 to 5 feet above the floor/ground surface. In addition, the canisters for the interior sample locations will be placed at a minimum of 5 feet from exterior walls. The IAQ and background samples will be collected over a 24-hour sample period at an approximate flow rate of 4.17 milliliters per minute (mL/min). The vacuum reading of each canister will be recorded prior to, during and after sample collection.Sampling will be considered complete following the 24-hour sample period and when a residual vacuum of between -2 and -5 inches of mercury is present in the canister.Weather conditions (relative humidity, temperature, atmospheric pressure, and wind speed/direction) will be recorded during the 24-hour sampling period from a nearby, public weather station. Following the sample collection, the canisters will be delivered under chain-of-custody protocol via courier to an American Industrial Hygiene Association (AIHA)–Laboratory Accreditation Programs (LAP), LLC certified laboratory for analysis of volatile organic compounds (VOCs) via EPA Compendium Method TO-15. The samples will be analyzed for VOCs of concern (Table 1) identified during the previous soil-gas sampling event conducted at the subject property.The laboratory method detection limits will meet or will be below the applicable residential standards and J-flags will be reported by the laboratory. In addition, the laboratory will include Level II QA/QC in the analytical report. Task 2 –Reporting Wood will prepare a written report relative to the work scope described in Task 1. This report will include a description of field activities, tabulated data in comparison to applicable screening levels, and the laboratory data packet with applicable QA/QC documentation with “J-flags” reported. A site plan with locations of sample points, and concentration map(s)for contaminants detected above applicable standards will be provided.The report will include information including whether or not the HVAC was operational, if windows/doors were open or closed during the assessment, any information on chemicals in the room prior to sampling, Table 1: Summary of Previously Detected VOCs of Concern Former Rusak Property Marie G. Davis School Charlotte, North Carolina Brownfields Project No.: 07020-03-060 Wood Project: 6228-18-0486 Acetone Benzene 1,3-Butadiene 2-Butanone (MEK) Carbon Tetrachloride Chloroform Cyclohexane 1,3-Dichlorobenzene Dichlorodifluoromethane (Freon 12) trans-1,2-Dichloroethylene Ethylbenzene 4-Ethyltoluene Heptane Hexane 2-Hexanone (MBK) Methylene Chloride 4-Methyl-2-pentanone (MIBK) Naphthalene Propene Styrene Tetrachloroethylene Tetrahydrofuran Toluene 1,1,1-Trichloroethane Trichloroethylene Trichlorofluoromethane (Freon 11) 1,2,4-Trimethylbenzene 1,3,5-Trimethylbenzene Vinyl Chloride Xylenes Notes: 1. Constituents detected during April 2019 soil-gas sampling event 2.Bold font means identified concentration exceeded DWM Residential SGSLs Constituent USGS The National Map: National Boundaries Dataset, National ElevationDataset, Geographic Names Information System, National HydrographyDataset, National Land Cover Database, National Structures Dataset, andNational Transportation Dataset; U.S. Census Bureau - TIGER/Line; HERERoad Data. Data Refreshed July, 2017. PREPARED BY: LMM DATE: 4/11/2019 DATE: 4/11/2019CHECKED BY: RCFDocument Path: F:\AMEC_Projects\2018\6228-18-0486\MXD\SiteLocation.mxd¯ PROJECT NO: 6228-18-0486 FIGURE NO: 1 SITE LOCATION MAPFormer Rusak PropertyMarie G. Davis School3331 Griffith Street and 3004 Bank StreetCharlotte, North CarolinaBrownfields Project No.: 07020-03-60 0 1,000 2,000500Feet Site Boundary P P P !!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!! !!! !!!!!!!!!!!!!!!!!!!!!!!!!PREPARED BY: LMM DATE: 7/30/2019 DATE: 7/30/2019CHECKED BY: RCFDocument Path: F:\AMEC_Projects\2018\6228-18-0486\MXD\buildinglayout2.mxd¯PROJECT NO: 6228-18-0486 FIGURE NO: 2 BUILDING LAYOUTFormer Rusak PropertyMarie G. Davis School3331 Griffith Street and 3004 Bank StreetCharlotte, North CarolinaBrownfields Project No.: 07020-03-60 0 30 6015Feet !A MW-1 SG-1 SG-2 SG-3 Reference: Key Plan for Marie G. Davis Middle School By Shook Kelley Dated 10/2/2006 Mechanical Room Electrical Room Closet #* #* #* #* 4 4 4 4 4 32 5A 5B 6 7 2 2 8 1 9 1= Student Records/Files, 2=Conference Room, 3=Principal Office, 4=Office, 5A=Reception Area-Staff, 5B Reception Area-Visitors, 6=Health/Nurse, 7=Teacher Work Room, 8=Faculty Lounge/Break Room, 9=Student Services P Previous Soil-Gas Sample Location Denotes Property Included in Brownfield Agreement Approximate building layout #*Proposed Indoor Air Sample Location #* Storm Drain Storm Drain Inlet