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