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).
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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.
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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
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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.
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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