HomeMy WebLinkAbout20026 Kaiser Fluids II_PCB Soil Notice April 20221
Minnich, Carolyn
From:Matt Ingalls <MIngalls@harthickman.com>
Sent:Wednesday, April 20, 2022 10:53 AM
To:Minnich, Carolyn
Cc:Brett Lawrence; Chris Walker; Hank Farmer
Subject:[External] FW: Update - Kaiser Fluids Tech II Brownfields Property (#20026 16-060)
PCB-Impacted Soil and Concrete Removal Activities
Attachments:PCB Tables and Figures.pdf
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Hi Carolyn – we wanted to give you an update on pending redevelopment activities proposed at the former Henkel
(southern) portion of the former Kaiser Fluids Tech II Brownfields property located at 530 E. Sugar Creek Road/4100
Raleigh Street in Charlotte. The results of previous assessment and recent soil characterization activities requested by
Trailhead 4100 Owner, LLC c/o Third & Urban, indicated the presence of PCBs in soil in two distinct areas of the Site
(northwestern and southeastern “hot spot” areas), and in concrete building slab in a former boiler room area at
concentrations above the U.S. Environmental Protection Agency’s (EPA’s) Toxic Substances Control Act (TSCA) cleanup
level of 1 part per million (ppm) established in 40 CFR Part 761 (see attached PCB Tables and Figures). To address the
PCB‐impacted soil and concrete, Trailhead 4100 Owner, LLC c/o Third & Urban has requested cleanup of PCB‐impacted
soil and concrete in accordance with procedures established under 40 CFR 761.61(b) for a “performance‐based” cleanup
option, which: 1) does not require EPA oversight, 2) requires removal of all soil/concrete identified w/ PCBs > 1 ppm, 3)
requires disposal of the PCB‐impacted soil/concrete at an approved TSCA disposal facility, and 4) collection of
confirmation soil samples for PCBs by EPA Method 8082. Note, per the EMP, select confirmation soil samples will also
be collected for possible analysis of PCB congeners according to EPA 1668 based on the results of the 8082
analysis. Please note, we have notified EPA per our submittal of EPA Form 7710‐53 Notification of PCB Activity, which is
required for disposal purposes.
Details regarding the approximate volume of PCB‐impacts identified in each area are provided below.
Area Identification Estimated Volume of Bulk
Remediation Waste (1) Media and Removal Method Estimated Work Area Dimensions
Northwest PCB Area
(NW PCB Area)
71.5 cubic yards Soil – Excavation 250‐sqaure feet excavation area; removal depths
up to 12 feet
Southeast PCB Area
(SE PCB Area)
107.5 cubic yards Soil – Excavation 250‐sqaure feet excavation area; removal depths
up to 10 feet
Boiler Room 154 cubic feet (2) Concrete Slab – Saw Cut and
Concrete Breaker
192.5‐square feet slab area; anticipated slab
thickness of 0.8 feet
Tentative plans include initiating PCB‐impacted soil and removal activities on May 9, 2022. Soil and concrete removal
activities will be completed in accordance with the DEQ‐approved EMP prepared for the Site and the Minimum
Subcontractor Requirements, Site Preparation and Controls, and Scope of Services included in a Request for Cost
Proposal sent to the bidding sub‐contractors and outlined below. Also, H&H will prepare a report documenting PCB‐
impacted soil removal/disposal activities for submittal to the EPA upon request in accordance with the “performance
based” option and can also provide a copy of this report to DEQ Brownfields for your records.
Minimum Subcontractor Requirements
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Subcontractor employees must have appropriate training [i.e., either a 40‐hour or 24‐hour Occupational Safety and
Health Administration (OSHA)‐required (29 CFR 1910.120) health and safety (H&S) course for hazardous waste work,
or certified equivalent training].
Personnel working at hazardous waste facilities must have had an annual physical (or physician's waiver for biennial
physical) and be certified "fit for duty" and "fit for respirator use," if necessary, by a qualified physician.
Proof of both training and a physical will be provided before Site work may begin.
Subcontractor personnel must have appropriate personal protective equipment (PPE) for the specific job. Minimum
PPE for Site personnel shall include hardhat, safety shoes, high visibility clothing or vest, gloves, safety glasses, hearing
protection (if appropriate), and respiratory protection (if appropriate and with fit test). PPE for subcontractor
personnel, including clothing and gloves, will be provided by the subcontractor.
Heavy equipment and field operations must meet applicable safety standards and be in good working
condition. Unsafe equipment or operations that cause excessive dust will necessitate shut down of the job at a cost
to the subcontractor.
Before field activities begin, the subcontractor must develop a H&S plan. H&H will provide a copy of its H&S Plan
(HASP), but this is not a substitute for an independent plan by the subcontractor. If the subcontractor has not
developed a Site‐specific HASP, H&H will assist the subcontractor in preparing its own separate, Site‐specific HASP for
implementation by the subcontractor. The subcontractor must agree to comply with at least the minimum
requirements of its own Site‐specific HASP and be responsible for the H&S of its own employees. The subcontractor
also must agree that it will take any additional measures it deems necessary to meet at least minimum applicable H&S
standards if unforeseen circumstances arise.
Each subcontractor is requested to designate a Subcontractor's Safety Representative (SSR), who is the subcontractor
supervisor. The SSR is responsible for the safe and healthful performance of work by his work force and
subcontractors. During the subcontractor's activities on‐Site, the SSR will perform continuing work area inspections,
and conduct safety meetings and safety orientations for all new employees.
Site Preparation and Controls
All work will be performed on the property owned by Trailhead 4100 Owner, LLC c/o Third & Urban, and access
agreements will not be required.
All work performed on the Site will be conducted in accordance with the DEQ‐approved Environmental Management
Plan.
Because of the anticipated concentrations of PCBs, work/exclusion zones or waste areas will be designated.
Only authorized remediation personnel will be allowed access to the work areas during the cleanup activities. While
working on the Site, the work traffic in support of cleanup activities will be routed from Raleigh Street. Access points
will be sufficiently maintained to prevent cross‐contamination through the work areas and/or off the Site and non‐
worker access.
Barricades and barricade tape should be used to delineate a work zone for safety purposes around the work area. The
barriers shall be set in a 25‐foot radius (as practical) around the work area to provide sufficient maneuvering space
for personnel and equipment.
Site erosion and sediment controls will be implemented during excavation activities. Operational and engineering
controls will be used to prevent rainwater from entering into active excavation areas and to prevent off‐Site loss of
sediment. Rainfall or groundwater that accumulates in the excavation areas will be managed in accordance with local,
state, and federal requirements, and the Environmental Management Plan. All erosion and sediment control
measures will be checked daily during the excavation and re‐grading process. Inspections will also occur after each
significant rainfall.
All tools and equipment will be cleaned prior to use at the Site. All personnel, tools, equipment, and vehicles that
come into contact with contaminated media will be decontaminated prior to leaving the exclusion zone to prevent
cross‐contamination. A decontamination area for equipment and tools will be established near each work area and
will be constructed to capture all decontamination fluids. All liquids used for decontamination will be contained and
tested to ensure proper characterization, management, and disposal will be completed. Polyethylene plastic sheeting
may be placed in loading areas to catch spills and to reduce the potential for soil to come in contact with truck
tires. Loose soil and debris will be brushed from the exterior of truck and/or container bodies prior to their exit from
a loading area. Loose soil that is brushed from the trucks and/or containers and that has been removed from the
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plastic sheeting will be transported for off‐Site disposal. Each roll‐off container or truck will be securely covered with
polyethylene sheeting at the end of the workday or in anticipation of heavy precipitation events. The subcontractor
will provide a wheel wash or similar means to reduce the potential for haul trucks tracking soil onto the public
roads. No tracking of mud or soil will be permitted beyond the designated work areas. Any such impacts will be
addressed immediately by the subcontractor.
Scope of Services
The primary activities to be performed by Site subcontractors include the following:
construction of Site controls and decontamination measures (discussed above);
operation of heavy equipment during excavation activities and waste handling activities;
excavation of PCB‐impacted soils as directed by H&H;
cut and removal of PCB‐impacted concrete slab as directed by H&H;
assist H&H personnel with collection of post soil excavation verification sampling; and
transport and disposal of bulk PCB remediation waste (soil and concrete slab) to a generator pre‐approved TSCA
landfill.
Note that bulk PCB remediation waste may be live‐loaded into trucks or placed within lined roll‐offs for disposal to a TSCA
landfill. Because active construction activities at the Site are ongoing and roll‐off staging space will be limited, the live‐
loading of trucks is preferred.
Note that excavation backfill, compaction, and surface restoration activities will be conducted by the General Contractor
(Gay Construction Company) and are considered outside the remedial scope of work. All backfill materials will be acquired
from an approved source or approved in advance by the DEQ Brownfields Program and Owners.
Please contact us with questions or comments regarding the proposed PCB removal activities.
Matt Ingalls, Sr. Project Manager
Hart & Hickman, PC
2923 S Tryon Street, Suite 100 ꞏ Charlotte, NC 28203
Direct: 704-887-4617 ꞏ Mobile: 704-560-5767
www.harthickman.com