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HomeMy WebLinkAbout16045_Ligget Apt_EMP_2013May02ENVIRONMENTAL MANAGEMENT PLAN LIGGET APARTMENTS AT WEST VILLAGE BROWNFIELDS PROJECT #: 16045-12-032 MID-ATLANTIC PROJECT NO. 000R2384.00 MAY 2, 2013 Summary The Liggett Apartments at West Village Brownfields Property (Brownfields Project No. 16045- 12-032, herein referred to as Liggett) consists of approximately 1.8 acres located at 601 West Morgan Street in Durham, Durham County, North Carolina. The Owner intends to develop the property with an apartment structure consisting of one level of parking at grade, four residential units on the ground floor, and five floors of apartments (approximately 156 units). The property will be subject to a Brownfields Agreement with the North Carolina Department of Environment and Natural Resources (NCDENR). The site formerly contained buildings and/or operations that supported the adjacent Liggett Myers tobacco facility up until at least 1979. Numerous rail spurs and lines traversed on and adjacent to the site to support these operations. Historical adjacent property uses include tobacco warehousing, tobacco research, cigarette manufacturing, automobile repair and a manufacturer's power house. Laboratory results from recently collected soil and groundwater samples are included in Mid- Atlantic’s Report of Environmental Services, Soil and Groundwater Sampling Activities, dated April 10, 2013. Vapor Intrusion testing results were submitted in Mid-Atlantic’s Vapor Intrusion Testing Report, dated November 20, 2012. To date, contaminant concentrations at the site have not been detected at or above the North Carolina Department of Environment and Natural Resources (NCDENR) Superfund Section’s Inactive Hazardous Sites Branch (IHSB) Residential Vapor Intrusion Screening Tables, July 2012 version (for soil gas); the IHSB Preliminary Soil Remediation Goals (PSRG) Table, July 2012 version (for soils), or the unrestricted use standards contained in Title 15A of the North Carolina Administrative Code, Subchapter 2L, Rule .0202, January 2010 Version (for groundwater). However, based on the age and historic use of the site and surrounding area, the potential exists for areas of contamination to be encountered during construction activities. The Owner proposes to address contaminated soil that is displaced during construction through the Brownfields Program in accordance with the Brownfields Agreement and the provisions of this Environmental Management Plan (EMP). Environmental Management Plan May 2, 2013 Liggett Apartments at West Village Page 2 Durham, North Carolina Site construction activities that may encounter subsurface contamination include the following: • Site utility work: Will involve the abandonment and installation of subsurface utilities including sanitary sewer, storm water, electric, water and natural gas. Most utility work is expected to be within the top three to eight feet of land surface. • Site grading and excavation: Site grading and excavation will involve the disturbance of soil up to eight feet below land surface on the southern parcel. • Building foundations: The proposed building will be supported primarily by shallow foundation systems consisting of spread footings. In some areas, rammed aggregate piers may be necessary. It is unlikely that these activities will cause groundwater to surge out of the boring onto the land surface creating the potential need for dewatering and the temporary containerization and characterization of displaced groundwater. Environmental Management Plan Requirements A) General Encountering soil or groundwater contamination requires special considerations when disturbing and handling these materials during construction. Potentially contaminated soils that are displaced during construction activities or future site activities (construction, renovation, utility repair, landscaping, etc.) will be subject to the provisions of this EMP. Potentially Contaminated Soils are defined as soils that have visual, olfactory or other evidence of contamination. For future site activities, Potentially Contaminated Soils include soils in areas of known historic contamination (discovered during initial construction or during previous site activities) and soils that have visual, olfactory or other evidence of contamination. Initial estimates indicate that site development activities will result in net volume of soil that will be transported off site. Soils that do not meet the definition of potentially contaminated soil may be re-used on site or disposed of as clean material. For potentially contaminated soil, this EMP will utilize an initial on-site re-use criterion based on the Preliminary Residential Health-Based Soil Remediation Goals (SRGs) contained in the most current version at the time the work occurs of the IHSB Preliminary Soil Remediation Goals (PSRG) Table. Potentially contaminated soils where contaminants have been detected at concentrations below these PSRGs will be acceptable for on-site re-use as backfill and as otherwise appropriate. Potentially contaminated soils exceeding the on-site re-use criterion will be disposed at an off-site facility properly permitted to accept such soils for disposal. Environmental Management Plan May 2, 2013 Liggett Apartments at West Village Page 3 Durham, North Carolina B) Execution – Categories and Management of Soil A net volume of soils for off-site disposal is expected on this project. Therefore, some materials will need to be shipped off-site regardless of contamination status. Overall, soils excavated during construction activities can be grouped into three major categories and managed as follows: 1. Category 1 –Soils that are disturbed and deemed to be uncontaminated based on field screening and visual and olfactory review can be re-used on site or removed from the site and used as non-contaminated fill material or disposed of in a construction/debris landfill. The destination of all soils removed from the site for use as non-contaminated fill must be documented and the soil sampled. One grab sample will be collected for every estimated 150 cubic yards (an estimated 225 tons) and analyzed for volatile and semi- volatile organic compounds using EPA Methods 8260 and 8270, respectively. If analytical data indicates that these soils exhibit concentrations in excess of the SRGs established in Paragraph A above, the soils will be retrieved and disposed of at a permitted receiving facility. 2. Category 2 - Potentially Contaminated Soils that are disturbed and deemed to be likely contaminated based on visual and olfactory review or laboratory analyses. The identification of Category 2 soils will require notification of the NCDENR contact listed in the Brownfields Agreement. Category 2 soils will be transported off site for disposal or treatment at an approved facility. 3. Construction Debris - Excavated construction debris consisting of boulders, brick, concrete, wood and other material with no notable chemical odor or staining which are substantially free of soil will be considered uncontaminated materials under Category 1 above. This material can be disposed of at a construction debris landfill or be used for off-site fill material. Construction debris with signs of chemical odor and staining will be segregated for off-site disposal at a facility permitted to accept this type of waste. Additional testing and laboratory analysis may be required to satisfy specific requirements of the disposal facility. Any demolition, clearing or grubbing not substantially disturbing soils is not subject to the provisions of this EMP. C) Execution - Soil Monitoring, Segregation, Handling, and Sampling Whenever potentially contaminated soils are encountered, an Environmental Representative (i.e. environmental personnel trained in the identification, field screening, and sampling of contaminated materials), will mobilize to the site to observe, monitor (using both a continuously- reading Photoionization Detection (PID) Instrument and Flame Ionization Detection Instrument (FID) and the headspace method for screening soils), and document the condition of these soils as they are excavated, including identification of potential contamination, and identification of saturated and unsaturated soils (herein referred to as field screening). The FID and PID will be calibrated at least daily and/or in accordance with manufacture’s specifications and calibration Environmental Management Plan May 2, 2013 Liggett Apartments at West Village Page 4 Durham, North Carolina readings will be recorded in field notes. At the owner’s discretion, the Environmental Representative may be asked to conduct field screening of soils periodically throughout the project. Based on field screening and visual and olfactory review by the Environmental Representative, the Potentially Contaminated Soils (Category 2 soils) will be segregated. The Environmental Representative will sample soils as described below: 1. Stockpile Sampling and Handling – One composite sample will be collected for every estimated 100 cubic yards (an estimated 150 tons) in accordance with Inactive Hazardous Sites Program Guidelines for Assessment and Cleanup (August 2011). Stockpiled soils will be placed onto and covered with polyethylene sheeting, which will be secured using hay bales or similar methods. The soils will be stockpiled in a manner to prevent water and/or sediment from the impacted soils from entering the site’s storm water system or from flowing off-site. An example of the stockpile construction technique, based on NCDENR guidance documents, is included in Attachment C. The Contractor (i.e. the contractor in charge of all site construction activities) will identify appropriate locations for stockpiles, which will not impede the construction progress, assuming that some of the stockpiles of contaminated or suspect material may have to remain on site for extended periods. It will be the responsibility of the Contractor to properly maintain stockpiled soils while they are stockpiled on site. 2. Direct Loading of Soil – Potentially contaminated soils can be directly loaded into trucks for off-site disposal at a permitted receiving facility if, based on the opinion of the Environmental Representative and upon approval by the Owner, the type of contamination is consistent with field screening and laboratory test data from previously characterized areas of the site. D) Execution - Laboratory Analysis At a minimum, the following laboratory analyses will be used. Additional analyses may be required based upon requirements of the disposal facility/destination: Category 2 Soils – Soil will be analyzed for volatile and semi-volatile organic compounds using EPA Methods 8260 and 8270, respectively. Additional analyses may be required by the disposal facility based upon initial findings. If laboratory test results do not detect contaminants at or above laboratory detection limits, the location for the off-site disposal of these soils should still be carefully considered. Environmental Management Plan May 2, 2013 Liggett Apartments at West Village Page 5 Durham, North Carolina Dewatering Effluent Treatment & Discharge Plan Requirements General Dewatering is not expected to occur during construction activities. In the event dewatering is necessary, the Owner currently plans to discharge the water directly to surface waters as permitted by rule under 15A NCAC .0106 (f)(7). Prior to discharge, the water will be containerized and sampled for volatile and semi-volatile organic compounds using EPA Methods 8260 and 8270, respectively. Water generated and discharged during construction will be sampled weekly to demonstrate compliance with 15A NCAC .0106(f)(7). In the event sampling results indicate that extracted groundwater exhibits concentrations in excess of applicable water quality standards, the water will be containerized and disposed of at a permitted receiving facility or treated on site until periodic testing shows it can be discharged in compliance with 15A NCAC .0106 (f)(7). Site Health and Safety – Special Considerations Historical assessment data indicates the potential presence of soil and groundwater contaminants at concentrations that will likely allow the handling of impacted soil to be conducted by construction workers without special training. General safety and health procedures will be documented in a Site Specific Health and Safety Plan (SSHSP) and will be implemented to account for the handling of contaminated or potentially contaminated materials and verify that conditions associated with the potentially contaminated soils or groundwater do not pose a hazard to on-site workers. If monitoring activities indicate elevated concentrations of constituents that could create hazardous site conditions for Category 2 soils, then the SSHSP will be modified in compliance with 29 CFR 1910.120 and a copy provided to the Brownfields Program. The presence of potentially hazardous conditions may require the use of trained workers as specified in 29 CFR 1910.120. E) Execution – Reporting Upon completion of construction, the Brownfields Program will be provided with a report summarizing activities associated with the excavation, field screening, segregation, analysis, transportation, disposal and final disposition of excavated soil (and potentially groundwater) at the site