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HomeMy WebLinkAbout23072_Kener Village Vapor Screening Work Plan final 20200626 Atlanta, GA • Jacksonville, FL June 26, 2020 Mr. Bill Schmithorst Project Manager DWM Brownfields Program North Carolina Department of Environmental Quality 217 West Jones Street Raleigh, North Carolina 27603 RE: Vapor Intrusion and Soil Sampling Work Plan Revision 2 Kerner Village Shopping Center 813-835 South Main Street Kernersville, North Carolina Brownfields Project Name: Kerner Village Brownfields Brownfields Project Number: BF#23072-19-034 Dear Mr. Schmithorst: Trammco Environmental Solutions, LLC (Trammco) and Blue Ridge Geological Services, Inc. (BRGS) have prepared this proposed work plan based on communication with staff in North Carolina Department of Environmental Quality (NC DEQ) Brownfields Program. The scope of work will specifically address the comments provided by Mr. Bill Schmithorst in emails dated April 17, 2020 and June 1, 2020. A copy of Mr. Schmithorst’s emails are attached to this work plan. The work will be conducted under the supervision of Mr. Jeff Gerlock a registered North Carolina Professional Geologist (NC PG No. 1141) with BRGS. BRGS is a registered North Carolina firm (NC Firm No. C-305). SECTION 1 - INTRODUCTION Trammco and BRGS are prepared to mobilize to the referenced site and conduct the scope of work outlined in this proposed work plan upon NC DEQ’s approval. The referenced site is currently developed with an active shopping center known as Kerner Village Shopping Center and consists of one parcel (6876-91-1024) totaling approximately 14.94 acres. Several environmental investigations have been conducted on the site including Phase I ESAs, Phase II ESAs, and Vapor Intrusion Screening. The investigations have been focused on assessment of impacts from the off-site dry cleaner (Camelot Cleaners) located to the north of the referenced site and the current on site dry cleaner operation ($2.75 Cleaners). A Phase II ESA conducted in 2007 by ECS and Trammco’s Phase I ESA, Phase II ESA, and Vapor Intrusion Screening conducted in 2019 focused on the on-site cleaners. The results of the soil, groundwater, and vapor sampling in the vicinity of the on-site dry cleaner are not indicative of a localized release. Investigations Vapor Intrusion Work Plan Kerner Village Shopping Center Kernersville, NC June 26, 2020 Page 2 conducted on the referenced site by AECOM as part of the State’s dry cleaner program have identified dry cleaning related chemicals in the groundwater beneath the site. The groundwater contamination was detected at concentrations exceeding applicable NC DEQ thresholds and is predominantly located on the northern and western portions of the referenced site. The Brownfields assessment activities outlined in this proposals will be conducted in accordance with the DEQ Inactive Hazardous Sites Branch (IHSB) Guidelines for Assessment and Cleanup of Contaminated Sites (Guidelines) dated January 2020, and the DEQ Division of Waste Management (DWM) Vapor Intrusion Guidance (VI Guidance) dated March 2018.. The purpose of the work plan is to provide NC DEQ with supplemental vapor data and to identify any trends in the data. The data generated by this work plan is being prepared for NC DEQ’s Brownfields program. SECTION 2 - SCOPE OF WORK The proposed scope of work includes the collection of sub-slab soil vapor samples from four areas on the referenced site and the collection of soil samples from the area beneath the on site cleaners and on site soil piles (eastern portion of the site): Sub-Slab Soil Vapor Sample Locations Leased space adjacent east of the on-site dry cleaner (two samples) Leased space adjacent west of the on-site dry cleaner (two samples) Adjacent to SS-5 (one sample) Adjacent to SS-7 (one sample) The select areas and number of samples per area were outlined in Mr. Schmithorst’s April 17, 2020 email. The number/location of samples was negotiated verbally thereafter. During Trammco’s conference call with DEQ, it was determined that the two sample locations near the on-site bank (PNC) and the two sample locations within the on-site dry cleaner were not necessary. The samples will be collected from a depth immediately below the concrete slab of the sampled areas. The sub-slab samples will be collected in batch certified 400-mL summa canisters provided by H&P Mobile Geochemistry for analysis for volatile organic compounds (VOCs) by EPA Method TO-15. The 400-mL summa canisters will be outfitted with 200 mL/min flow controllers. Vapor Intrusion Work Plan Kerner Village Shopping Center Kernersville, NC June 26, 2020 Page 3 Soil Sample Locations Collect two subsurface soil samples from a depth of approximately 3-4 feet below ground surface in the dry cleaner near the dry cleaning machine and chemical storage areas. Collect two five-point composite soil samples from the soil piles located on the eastern portion of the Site. The select areas and number of soil samples per area were outlined in Mr. Schmithorst’s June 1, 2020 email. SECTION 3 - SAMPLING METHODLOGY Sub-Slab Soil Vapor Sampling At each of the proposed sample locations, a boring will be drilled using a hammer drill and 0.75- inch concrete bit to a depth of approximately 2 inches below the bottom of the concrete slab. Sub- slab implants, consisting of an air stone connected to nylon tubing, will be placed in the bottom of the open borehole, and a sand pack, consisting of quartz sand will cover the entire length of the air stone. The remainder (entire thickness of the concrete slab) will be sealed with bentonite. A helium leak test will be conducted to ensure the integrity of the implant seal. To conduct the test, a shroud will be placed over the implant and filled with helium, a helium meter will be used to document the beginning and ending helium concentration within the shroud. The implant will be extended out of the shroud, a disposable syringe will be used to collect approximately 200 ml of soil gas into a tedlar bag. The helium meter will be removed from the shroud and attached to the tedlar bag. If the meter readings are less than 10% of the helium concentration within the shroud, the seal will be considered competent, and sampling activities will continue. If the meter readings exceed 10% of the should concentrations, the implant will be resealed or replaced and retested. Prior to collecting a soil gas sample, three volumes of air from the boring and tubing will be purged at a purge rate not to exceed 200-mL per minute. A syringe, connected to a flow controller, will be connected to the sample tubing via a tee connection and a swage lock fitting. Once the appropriate volume of air has been purged, a 400-mL laboratory supplied SUMMA canister will be connected to the implant tubing. The canister will be equipped with a 200-mL per minute flow controller to control the intake time of the sample. Canister vacuum readings will be documented prior to sample collection and every few minutes during sample collection. Once the vacuum reading has dropped to around 5 inches of mercury, the canister will be closed and disconnected from the tubing. Samples will be documented under standard chain-of-custody procedures and delivered to H&P Mobile Geochemistry in California for analysis of volatile organic compounds (VOCs) by EPA Method TO-15. QA/QC information, as well as additional site and sample specific information will be recorded in a field data report. Vapor Intrusion Work Plan Kerner Village Shopping Center Kernersville, NC June 26, 2020 Page 4 Once the samples are collected, each boring location will be sealed with quick setting concrete so it is flush with the surrounding grade. Soil Sampling Discrete soil samples will be collected using a stainless steel hand auger from two locations beneath the on-site dry cleaner (one sample near the dry cleaning machine and one sample near the chemical storage area) at an approximate depth of 3-4 feet below ground surface (bgs). The soil samples will be transferred directly from the hand auger to the dedicated laboratory supplied sample containers by field staff wear appropriate PPE (nitrile gloves), labeled with the sample identification, date, and requested analysis, and placed in a laboratory supplied cooler with ice. The soil samples will be submitted to a North Carolina certified laboratory under standard chain of custody protocols for analysis of Semi-volatile organic compounds (SVOCs) and RCRA metals plus hexavalent chromium by EPA Methods 8270 and 6020/7471/7199. Once the soil samples are collected from each boring, soil cuttings will be placed back in each boring. A cement mix will be placed in each borings to fill the boring to surrounding grade and seal the boring. Composite soil samples will be collected from the soil piles located on the eastern portion of the Site at approximate depths of 0 to 1 ft bgs depth interval. Five aliquot soil samples will be collected at each composite soil sample location. The aliquot soil samples from each composite soil sample location will be combined and homogenized to form one composite soil sample for a total of two (2) composite soil samples. Composite soil samples will then be placed directly into dedicated laboratory supplied sample containers, labeled with the sample identification, date, and requested analysis, and placed in a laboratory supplied cooler with ice. The composite soil samples will be submitted to a North Carolina certified laboratory under standard chain of custody protocols for analysis of RCRA metals plus hexavalent chromium by EPA Methods 6020/7471/7199. SECTION 4 - LABORATORY ANALYSIS The sub-slab samples will be collected in batch certified 400-mL laboratory supplied SUMMA canisters provided by H&P Mobile Geochemistry for analysis for volatile organic compounds (VOCs) by EPA method TO-15. EPA Method TO-15 will provide reporting limits that are capable of meeting EPA and NC DEQ’s VI reporting requirements for vapor intrusion. The samples will be shipped to H&P Mobile Geochemistry Inc. (H&P) of Carlsbad, California for analysis. H&P is certified under the National Environmental Laboratory Accreditation Conference (NELAC). H&P will include a Level II QA/QC with its final report. Vapor Intrusion Work Plan Kerner Village Shopping Center Kernersville, NC June 26, 2020 Page 5 The soil samples will be submitted to a North Carolina certified laboratory under standard chain of custody protocols for analysis of SVOCs and RCRA metals plus hexavalent chromium by EPA Methods 8270 and 6020/7471/7199. Laboratory reporting limits for each analyte will be at or below appropriate screening criteria, where possible. Additionally, the laboratory will include estimated concentrations for compounds that are detected at levels above the laboratory method detection limit, but below the laboratory reporting limit (J flags). SECTION 5 – QA/QC As mentioned in Section 3 above, field QA/QC procedures (i.e. helium leak test, secondary leak test, a purge of ambient air, etc.) will be performed to ensure the competency of the samples. No duplicate samples will be collected as part of this work plan. Laboratory supplied SUMMA canisters will be shipped to H&P the same day they are collected using a next day delivery service. The canisters will be placed within lab supplied cardboard boxes and will be accompanied by a completed chain of custody form. The laboratory will perform internal QA/QC procedures / analyses. A stainless steel hand auger will be utilized to advance the borings associated with soil sampling activities and will be deconned between sampling locations using distilled water and Liquinox detergent. Field staff will utilize nitrile gloves that are changed out between both sampling and decon activities. SECTION 6 - INVESTIGATION DERIVED WASTE (IDW) MANAGEMENT No investigation derived waste (IDW) will be generated during the proposed work. SECTION 7 - REPORTING A report summarizing the site work conducted, analytical results, and conclusions and recommendations will be provided to NC DEQ. The summary report will include data summary tables per media, and properly formatted figures illustrating the location of the samples and analytical reports. The report will include the registered North Carolina firm’s information and a North Carolina PG seal and signature. Vapor Intrusion Work Plan Kerner Village Shopping Center Kernersville, NC June 26, 2020 Page 6 If you have any questions or require additional information, please do not hesitate to contact me at (404) 788-8606 or matt@trammco.com. Sincerely, Matthew Trammell Project Manager Attachment: Figure - Proposed Sample Locations NC DEQ’s 4/27/20 Scope of Work Email Figures Appendix Source: Esri, DigitalGlobe, GeoEye, Earthstar Geographics, CNES/ Airbus DS, USDA, USGS, AeroGRID, IGN, and the GIS User Community 0 15075Feet Kerner Village Shopping Center Soil Gas Sample Location Sub-Slab Soil Vapor Sample URS Soil Gas Sample (6/14/12) Vapor Intrusion Sample Locations Kerner Village Shopping Center 813-835 South Main St. Kernersville, NC 27284 PCE ND SS-1 PCE ND SS-2 PCE ND SS-3 PCE ND SS-4PCE8.5 SS-5 PCE ND SS-6 PCE ND SS-7 PCE ND SS-8 PCE ND SS-9 PCE 25 SS-10 PCE 17 SS-11 PCE 15 SS-12 PCE 12 SS-13 PCE 30 SS-14 PCE 13 SV-1 PCE 13 SV-2 PCE ND SV-3 PCE 21 SG-13 PCE 5.6 SG-14 PCE 52 SG-1 PCE 31.7 SG-2 PCE 23.1 SG-3 Tetrachloroethene ug/m3 Sample ID &&&&&&&& &&&&&&&&& &&&&&NDNon Detect NC DEQ Emails April 17, 2020 & June 1, 2020 1 Matt Trammell From:Short, Amanda Kitchen <AShort@mcguirewoods.com> Sent:Wednesday, April 29, 2020 12:15 PM To:Schmithorst, William L Cc:Matt Klump (mk@seafordcapital.com); Wahl, Tracy; Matt Trammell Subject:RE: Kerner Village Brownfields Assessment Request BF#23072-19-034 Attachments:Vapor Intrustion Sample Locations 4-27-20.pdf Bill and Tracy, Do you have time tomorrow or Friday for a conference call to discuss what has been done in terms of sampling and the additional sampling requirements you listed below? If so, please provide some times that work for you. I have attached an updated figure showing all of the sampling that has been done to date. Thanks, Amanda Amanda Kitchen Short McGuireWoods LLP 201 North Tryon Street Suite 3000 Charlotte, NC 28202-2146 T: +1 704 343 2359 M: +1 704 975 4190 F: +1 704 444 8861 ashort@mcguirewoods.com Bio | VCard | www.mcguirewoods.com To help protect your priv acy, Microsoft Office prevented automatic download of this picture from the Internet.McGuireWoods LLP From: Schmithorst, William L <William.Schmithorst@ncdenr.gov> Sent: Friday, April 17, 2020 3:53 PM To: Short, Amanda Kitchen <AShort@mcguirewoods.com> Cc: Matt Klump (mk@seafordcapital.com) <mk@seafordcapital.com>; Wahl, Tracy <tracy.wahl@ncdenr.gov> Subject: Kerner Village Brownfields Assessment Request BF#23072-19-034 **EXTERNAL EMAIL; use caution with links and attachments** Amanda, DEQ Brownfields has reviewed the data provided from previous site assessment activities at the Kerner Village Brownfields Property. Based on review of the sampling data provided, the DEQ is requesting the following additional assessment activities be completed to verify that volatile compounds are below DEQ risk screening levels. A figure is attached with notes indicating the general sample locations.  Collect 2 sub-slab soil vapor samples from the on-site dry cleaner location adjacent to former sample locations SG-1 and SG-3 from the July 2019 assessment. 2  Collect 2 sub-slab soil vapor samples from the adjacent leased space to the east of the on-site dry cleaner.  Collect 2 sub-slab soil vapor samples from the adjacent leased space to the west of the on-site dry cleaner.  Collect 1 sub-slab soil vapor sample adjacent to former sub-slab sample SS-5 (November 2019 assessment).  Collect 1 sub-slab soil vapor sample adjacent to former sub-slab sample SS-7 (November 2019 assessment).  Per earlier discussions, access was not granted to the Prospective Developer to the on-site bank building for sub- slab vapor sampling; therefore, DEQ is requesting 1 permanent soil gas sampling point be installed adjacent to the building. The DEQ will require annual sampling for two years to verify volatile organic compounds in groundwater originating from the off-site Camelot Cleaners are not present at unacceptable levels. If there are timing issues with access to install the soil gas sampling point, DEQ Brownfields would be open to including the requirement in the Brownfields Agreement for installing the sampling point at a later date.  Submit an Environmental Site Assessment Work Plan for DEQ approval prior to conducting the assessment work following the March 2018 NCDEQ Vapor Intrusion Guidance Document (see attached Work Plan Checklist and Guidance Document for reference). Please contact me if you have questions. Regards, This e-mail from McGuireWoods may contain confidential or privileged information. If you are not the intended recipient, please advise by return e-mail and delete immediately without reading or forwarding to others. 1 Matt Trammell From:Short, Amanda Kitchen <AShort@mcguirewoods.com> Sent:Monday, June 1, 2020 5:11 PM To:Matt Trammell; Matt Klump Subject:FW: FW: DEQ Work Plan Additional VI Samples - Kerner Village - DEQ Comments (BF# 23072-19-034) Can you both discuss tomorrow? Sent from my Verizon, Samsung Galaxy smartphone -------- Original message -------- From: "Schmithorst, William L" <William.Schmithorst@ncdenr.gov> Date: 6/1/20 4:34 PM (GMT-05:00) To: "Short, Amanda Kitchen" <AShort@mcguirewoods.com> Subject: RE: FW: DEQ Work Plan Additional VI Samples - Kerner Village - DEQ Comments (BF#23072-19-034) **EXTERNAL EMAIL; use caution with links and attachments** Amanda, The NCDEQ Brownfields Program has reviewed the Vapor Intrusion Work Plan Revision 1 (May 27, 2020) prepared by Trammco Environmental Solutions and has the following comments and requests for additional soil sampling: Soil Sampling  The Brownfields Agreement is currently being drafted and it has been identified from data provided that no environmental samples collected at the property have been analyzed for semi-volatile compounds (SVOCs) or metals (with the exception of two soil pile samples analyzed for semi-volatile compounds). At a minimum, the Brownfields Program typically requires analysis for volatile organic compounds (VOCs), SVOCs and RCRA metals to evaluate site conditions for environmental risk and to document site conditions at the time of the brownfields agreement. NCDEQ is requesting the following: o Collect two subsurface soil samples from a depth of approximately 3-4 feet below ground surface in the dry cleaner near the dry cleaning machine and chemical storage areas. Analyze the samples for SVOCs, RCRA metals and hexavalent chromium. o Collect two five-point composite soil samples from the soil piles for the analysis of RCRA metals and hexavalent chromium. Work Plan Comments  Please include the following details requested in the previously provided work plan checklist for the sub-slab soil gas samples. o Discuss sample collection procedures. Include the following, at a minimum:  Equipment to be used  Purging methods and volumes  Leak check procedures for sub-slab soil gas samples  Discuss how and when vacuum readings will be collected (for summa cans) 2  The Brownfields assessment activities will be conducted in accordance with the DEQ Inactive Hazardous Sites Branch (IHSB) Guidelines for Assessment and Cleanup of Contaminated Sites (Guidelines) dated January 2020, and the DEQ Division of Waste Management (DWM) Vapor Intrusion Guidance (VI Guidance) dated March 2018.  Laboratory reporting limits for each analyte will be at or below appropriate screening criteria, where possible. Additionally, the laboratory will include estimated concentrations for compounds that are detected at levels above the laboratory method detection limit, but below the laboratory reporting limit (J flags). Please submit a revised work plan addressing the information requested above. Let me know if you have any questions. Regards, From: Short, Amanda Kitchen [mailto:AShort@mcguirewoods.com] Sent: Wednesday, May 27, 2020 10:52 AM To: Schmithorst, William L <William.Schmithorst@ncdenr.gov>; Wahl, Tracy <tracy.wahl@ncdenr.gov> Subject: [External] FW: DEQ Work Plan Additional VI Samples - Kerner Village CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to report.spam@nc.gov Bill and Tracy, Please see attached and note from Matt. Please let us know if you have any comments or questions. Thanks! Amanda Amanda Kitchen Short McGuireWoods LLP 201 North Tryon Street Suite 3000 Charlotte, NC 28202-2146 T: +1 704 343 2359 M: +1 704 975 4190 F: +1 704 444 8861 ashort@mcguirewoods.com Bio [mcguirewoods.com] | VCard [vcards.mcguirewoods.com] | www.mcguirewoods.com [mcguirewoods.com] This e-mail from McGuireWoods may contain confidential or privileged information. If you are not the intended recipient, please advise by return e-mail and delete immediately without reading or forwarding to others.