20077_Crown HondaII_RevEMPAdd_20180702

'J MCADAMS ENVIRONMENTAL MANAGEMENT PLAN > ADDENDUM
July 2, 2018
Mr. Kelly Johnson
North Carolina Department of Environmental Quality
Division of Waste Management — Brownfields Section
217 West Jones Street
Raleigh, NC 27603
RE: Revised Environmental Management Plan Addendum
Soil Export, Soil Stockpiling, and Asphalt Reuse Plan
Former Crown Honda Property
Chapel Hill, North Carolina
Brownfields Project Number 20077-16-068
McAdams Project Number LCG-16010
Dear Mr. Johnson,
At the request of LG Crown Volvo, LLC, the John R. McAdams Company, Inc. (McAdams) has developed the following
Soil Export and Asphalt Reuse Plan for the Former Crown Honda Property located at 1730 Fordham Boulevard in
Chapel Hill, Orange County, North Carolina, (herein referred to as the "subject site" or "site"). The objective of this
plan is to 1) develop criteria for North Carolina Brownfields Program (NCBP) approval to export soils to the nearby
Performance Auto Mall Brownfields Property (NCBP Project No. 20078-16-68) 2) establish acceptable locations for
reuse of the soils on the Performance Brownfields site 3) establish acceptable locations for the temporary
stockpiling of soils on the Performance Brownfields site. Under this scenario these soils will eventually be
transported back to the Crown Honda Property and 4) specify criteria for asphalt millings from former parking areas
to be reused under the proposed road and parking areas. This plan is being submitted as an addendum to the
existing Environmental Management Plan (EMP) for the project that was approved by you on December 12, 2017.
1.0 SITE BACKGROUND
The subject site is identified as "Crown Honda II" by the North Carolina Brownfields Program (NCBP) under Project ID
20077-16-74 and is located at 1730 Fordham Boulevard in Chapel Hill, Orange County, North Carolina. The subject
site is identified under Property Identification Numbers (PINS) 9799-36-6631 (Tract 1), 9799-36-7662 (Tract 2), and
9799-46-1235 (Tract 3) under Orange County records.
The subject site has historically consisted of the Hendrick Automotive Group car dealership dating back to 1980.
From 1980 until 2016, the site was utilized for automotive sales, service, auto body repair, and car washing/detailing
activities. Historical environmental assessments have identified petroleum and chlorinated solvent (from
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degreasers) impacts to soil and groundwater at the site from the historical use as a car dealership. Low levels of
petroleum constituents and chlorinated solvents tetrachloroethylene (PCE) and trichloroethylene (TCE) remain in
soil and groundwater under the general footprint of the current building and proposed residential building. No
evidence of gross pollution has been observed on the Crown property.
The "Performance Auto Mall" site is identified by the NCBP under Project ID 20077-16-74. In January 2017, the
subject site was acquired from Hendrick Automotive by LG1810 Fordham Blvd, LLC for redevelopment. Under
Hendrick Automotive (and predecessors) ownership, several leaking underground storage tanks (LUST) and leaking
above ground storage tank (LAST) events were reported. Identical to the Crown Honda II site, past environmental
assessments have identified petroleum and chlorinated solvent (from degreasers) as Contaminants of Concern
(COCs) at the site from the historical use as a car dealership. Procedures to handle impacted soil and water during
construction are included in the approved EMP.
2.0 SOIL SCREENING CATEGORIES
This soil export plan is an addendum to the approved EMP. Based on current construction planning, soils will be
generated at the site through surface grading and installation of foundations and subsurface utilities. Available
information indicates that construction activities will not encounter the water table. As such, the activities described
in this plan are for unsaturated soils generated during construction that are intended to be exported to the nearby
Performance site as previously described.
Prior to the mass grading, utility and foundation work, spot excavation of known/potentially impacted soil will occur
in the area of former vehicle maintenance operations during demolition of the building and removal of adjacent
paved surfaces. Additionally, debris/debris piles in the back portion of the site will also be removed prior to the start
of major earthwork at the site. Impacted soils will be transported to a permitted facility for disposal. An
Environmental Professional (EP) will screen and sample soils as necessary to document that impacted soil that could
potentially be encountered during construction have been removed. After areas of contamination have been
removed, remaining soils will be managed under the approved EMP. Soils designated to be exported for reuse at
the Performance Auto Mall property will be handled under the procedures described in this plan.
Soils generated at the site as a result of construction activities are grouped into the three categories described
below based on historic sampling and assessment data. Area 1 includes soils below the current building where
historic automotive repair has occurred. Area 2 includes the estimated extent of buried debris around the former
residence. Area 3 includes all soils outside of both the current building footprint and the area of buried debris where
no evidence of soil impacts were observed. These three areas are depicted on Drawing 1. The following sections
outline screening and sampling procedures for each area based on the potential for remaining soil impacts to be
present after initial excavation activities have been conducted during the demolition phase of the project as
describe above. All soil screening and sampling will occur on the Crown Property prior to any export of soil.
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'J MCADAMS ENVIRONMENTAL MANAGEMENT PLAN > ADDENDUM
2.1 Area 1 Soils
Area 1 includes soils below the current building where historic automotive repair has occurred as shown by the red
hatch in Drawing 1. These soils are considered to have the greatest chance of having potential residual impacts after
initial demolition phase excavation of soils are conducted and will require the highest level of screening. Following
spot excavation activities during building demolition, screening within Area 1 will initially be conducted by an
Environmental Professional (EP) under the supervision of a North Carolina licensed engineer or geologist who has
experience managing operations at sites regulated by NCDEQ.
Based on initial screening results, and the opinion of the EP, primary oversight and screening of soils can be
transferred to the General Contractor (GC). Field evidence of impacts includes visual evidence of chemical staining
or other indications of potential impacts. The EP will be on standby and will be notified if any potentially impacted
soils are identified. The EP will make periodic site visits while on standby and the GC will report their findings to the
EP on a weekly basis through field reports.
2.2 Area 2 Soils
Area 2 includes the estimated extent of buried debris designated by the yellow hatch pattern shown in Drawing 2.
Based on electromagnetic geophysical survey data and test pitting conducted during a March 2018 Phase II
Assessment, the debris in this area consist primarily of tires and construction debris, including asphalt, concrete and
bricks. As with Area 1, initial excavation activities will be conducted to removed debris and impacted soil from this
area. After these initial activities are conducted, soils from this area that are free from debris and evidence of
staining/discoloration will be considered non -impacted. Under the direction of the EP, primary oversight and
screening of soils can be conducted by the GC. The EP will be on standby and will be notified if any potentially
impacted soils are identified.
2.3 Area 3 Soils
Area 3 includes all soils outside of both the current building footprint and the area of buried debris where no
evidence of known or potential soil impacts have previously been identified. This area is designated with a green
hatch pattern in Drawing 1. Based on historic land use and previous soil assessment data, soils in this area are
assumed to not be impacted. Under the direction of the EP, primary oversight and screening of soils can be
conducted by the GC. The EP will be on standby and will be notified if any potentially impacted soils are identified.
3.0 SOIL MANAGEMENT OPTIONS
Based on field screening, the following soil export options are available:
Option 1— Direct Export: If no field evidence of impacts are observed, soils may be directly loaded into trucks
without sampling and transported to the Performance Auto Mall Property for use as fill material under the future
asphalt parking surface highlighted in green on Drawing 2. The soil may also be temporarily stockpiled in the two
red -hashed areas shown in Drawing 2 as long as the soil will be used under the green highlights parking area in the
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ENVIRONMENTAL MANAGEMENT PLAN > ADDENDUM
future. Option 2 will need to be used if the soils are designated for use as fill under the yellow highlighted future
parking lot.
Option 2 — Stockpile Sampling Before Export: Stockpiling and sampling of soil on the Crown site prior to export to
the Performance site will need to be conducted in accordance with the EMP under the following conditions:
• Condition 1— Evidence of Impacts: If soils exhibit field evidence of potential impacts.
• Condition 2 — Use of Fill Adjacent to Residential Area: If exported of soils are designated for use as fill under
the yellow -highlighted parking area adjacent to the residential neighborhood, regardless of evidence of field
impacts.
Based on the lab results for Option 2 sampling, the Reuse Options provided below are available at the Performance
site.
• Reuse Option 1: If analytical results do not indicate the presence of any target analytes above laboratory
detection limits, then the soil may be used as fill under the green and yellow -highlighted parking areas or
placed in either of the two designated stockpile areas.
• Reuse Option 2: If analytical results indicate concentrations of target analytes below commercial PSRGs but
above the lowest of Residential/Protection of Groundwater PSRGs, and detected COCs are generally the
same as those detected at the Performance site, then soils may be used under the green -highlighted future
parking lot or in Stockpile Area 1. Soils with COCs above any PSRGs may not be used as fill in the yellow -
highlighted future parking area or Stockpile Area 2.
• Reuse Option 3: If analytical results indicate COCs below unrestricted standards (i.e. below the lowest of
Residential/Protection of Groundwater PSRGs), then the soil may be used as fill under the yellow -highlighted
parking area as well as the green -highlighted parking area.
No export of soils for reuse at the Performance site will be allowed if soils are impacted with target analytes
above Commercial PSRGs. If soils are impacted above Commercial PSRGs, then they will need to be transported off -
site to a permitted disposal facility per the requirements of the approved EMP.
Soils deemed acceptable for reuse as described above will be will be placed under the designated impervious paved
surfaces and at least 2 feet above the seasonably high water table. No exported soils will be placed under the
footprint of the future building. The potential stockpile locations and areas eligible for placement of fill are shown
on Drawing 2.
4.0 TEMPORARY STOCKPILING OF SOIL
The PD also requests approval to transport approximately 5,000 cubic yards of non -impacted soil (i.e. based on
screening procedures from the approved EMP) from the Crown Honda Property for temporary stockpiling on the
Performance Brownfields site. The compact conditions of the Crown Honda Property limit the management of soil
during redevelopment activities. Only soils from Area 2 and Area 3 will be designated for temporary stockpiling using
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ENVIRONMENTAL MANAGEMENT PLAN > ADDENDUM
soil screening criteria as discussed in Section 3.0. The GC has confirmed that no soil will be cut from Area 1 and that
the only soil designated for temporary stockpiling will be from the eastern portion of the site, along Legion Road.
Construction personnel will monitor soil export activities to ensure that no soil from Area 1 is transported to the
Performance site. Once transported to the Performance site, the soil may be temporarily stockpiled in the two red -
hashed areas shown in Drawing 2. Brownfields will be provided with written documentation of approval for the
temporary stockpiling of soil from each of the property owners of the Crown site and the Performance site a
minimum of five days before soil transport activities are to begin.
As a precaution soils will be stockpiled in accordance with NCDEQ Guidelines for Ex -Situ Petroleum Contaminated
Soil Remediation soil stockpile procedures. Additionally, three soil samples will be collected from the stockpile
temporarily stored on the Performance Auto site as confirmation of field screening activities. Samples will be
submitted for analyses of Volatile Organic Compounds (VOC) by EPA Method 8260, Semi -Volatile Organic
Compounds (SVOC) by EPA Method 8270, and the eight Resource Conservation and Recovery Act (RCRA) metals by
Methods 6010D and 7471A. Compositing of VOCs will be performed by the analytical laboratory.
5.0 USE AS FILL MATERIAL BY NCDOT
The North Carolina Department of Transportation (DOT) has requested fill material for use in the East End Connector
Project in Durham, North Carolina. They have agreed to accept soils from North Carolina Brownfields Projects if they
are managed under an approved EMP. These soils will be used by DOT as fill material below the planned roadway.
Only soils from Area 2 and Area 3 will be designated for transport to the NCDOT site using soil screening criteria as
discussed in Section 3.0. An environmental professional will ensure that no soil showing field evidence of impacts
from COCs is transported to the DOT site for use as fill. Brownfields will be provided with written documentation
from DOT that they accept the soils and are aware that they have been exported from a North Carolina Brownfields
site.
6.0 REUSE OF ASPHALT
The PD also requests approval to reuse asphalt millings from the former on -site parking lot for use under the
proposed road and parking areas. All material immediately downgradient from former service areas as well as
asphalt exhibiting staining has been transported off site for disposal at a permitted facility. The remaining asphalt
will be crushed to DOT specifications for reuse under the proposed paved impervious surfaces. Asphalt will be will
be placed under the designated areas at least 2 feet above the seasonably high water table. No asphalt material will
be placed under the footprint of the future building.
North Carolina General Statute 130A-294 (m) for "Solid waste management program" states that "demolition debris
consisting of used asphalt or used asphalt mixed with dirt, sand, gravel, rock, concrete or similar non -hazardous
material may be used as fill and need not be disposed of in a permitted landfill or solid waste disposal facility. Such
demolition debris may not be placed in the waters of the State or as or below the seasonal high water table." This
information indicates that reuse of non -impacted asphalt below paved surfaces and above the seasonal high water
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ENVIRONMENTAL MANAGEMENT PLAN > ADDENDUM
table would be acceptable for NCBP approval if there is an overlying impervious surface to limit rainfall infiltration
and potential leaching of petroleum constituents in the asphalt. The location and areas eligible for placement of
asphalt millings are shown on Drawing 3.
A summary of soil export and asphalt reuse activities will be prepared and included in the full EMP Reports for the
Crown Honda II and Performance properties. Photographs of temporary stockpile activities and from bimonthly
inspections will be included with the final EMP Reports for both the Crown Honda II property and the Performance
property.
Sincerely,
MCADAMS
Jeffrey Tyburski, RSM, PG
Director, Environmental
JT/lk
Attachments
Eric Ho and
Staff Geologist
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