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Home My WebLink AboutWS-4084_13568_CA_IAR_20170112UST Closure and Initial Abatement Action Report Spray Exxon Progress Project No. 1017005.001 January 12, 2017 i TABLE OF CONTENTS A. SITE IDENTIFICATION .................................................................................................................... 1 B. SITE HISTORY AND CHARACTERIZATION ................................................................................ 2 C. SITE CHECK ....................................................................................................................................... 2 D. UST CLOSURE RESULTS ................................................................................................................. 2 E. INITIAL RESPONSE AND ABATEMENT ACTION ....................................................................... 4 F. EXCAVATION OF CONTAMINATED SOIL ................................................................................... 4 G. LABORATORY ANALYTICAL RESULTS ...................................................................................... 4 H. GROUNDWATER AND SURFACE WATER INVESTIGATION ................................................... 4 I. FREE PRODUCT INVESTIGATION AND RECOVERY REPORT ................................................ 4 J. CONCLUSIONS .................................................................................................................................. 4 K. RECOMMENDATIONS ..................................................................................................................... 5 L. QUALIFICATIONS OF REPORT ...................................................................................................... 5 FIGURES Figure 1 – Topographic Site Map Figure 2 – Site Plan Figure 3 – Soil Sample Locations Map TABLES Table B-1 – Site History, UST/AST System Information Table B-2 – Site History, UST Owner/Operator Information Table B-3 – Summary of Soil Analytical Results APPENDIX Site Photographs UST-2 and UST-3 Forms Certificates of Waste Liquids Disposal Tank Disposal Manifest Laboratory Data Sheets and Chain-of-Custody Record UST Closure and Initial Abatement Action Report Spray Exxon Progress Project 1017005.001 January 12, 2017 2 B. SITE HISTORY AND CHARACTERIZATION Progress Environmental, Inc. (Progress) was contracted by Eden Oil Company to conduct underground storage tank (UST) closure activities at the Spray Exxon located at 103 Boone Road in Eden, Rockingham County, North Carolina (Figure 1). The site consists of an active automotive maintenance shop, which stores gasoline and diesel fuel formerly for retail sale in four underground storage tanks (USTs). The site is depicted on Figure 2. The USTs have been in temporary closure since 2015. A 4,000-gallon diesel UST was removed by G & H Oil Equipment, Inc. of Greensboro, North Carolina in July 1990. The diesel UST was replaced with the existing 3,000-gallon diesel UST. Legacy Environmental Services, Inc. (Legacy) submitted an UST Closure Report in December 1998 describing the closure activities that occurred in 1990 as well as additional activities which occurred in 1998. Apex Environmental, Inc. previously completed a Corrective Action Plan, dated October 15, 2003 with respect to the release. Information regarding the on-site USTs is presented below: Table B-1 Site History, UST/AST System Information Tank No. Installation Date Capacity (gallons) Construction Materials Dimensions (inches) Removal Date Previous Contents 1 1985 8,000 Steel 256” x 96” 12/14/16 Gasoline 2 1985 8,000 Steel 256” x 96” 10/15/15 Gasoline 3 1985 8,000 Steel 256” x 96” 12/15/16 Gasoline 4 1990 3,000 Steel 216” x 46” 12/15/16 Diesel 5 1985 1,000 Steel 60” x 144” 12/14/16 Kerosene 6 Unknown 1,000 Steel 60” x 144” 12/14/16 Waste Oil Table B-2 Site History, UST Owner/Operator Information Owner’s Name Address Phone Number Dates of Ownership Eden Oil Company P.O. Box 1375, Reidsville, NC 27323 (336) 349-8228 Unknown-Present C. SITE CHECK A site check has not been completed in regards to the UST system. D. UST CLOSURE RESULTS On December 14 through December 15, 2016 RABCO, Inc. (RABCO) excavated the overburden soil from the vicinity of the USTs using a trackhoe. Progress personnel provided oversight during excavation UST Closure and Initial Abatement Action Report Spray Exxon Progress Project 1017005.001 January 12, 2017 3 Zebra Environmental and Industrial Services evacuated a total of 479 gallons via a vacuum truck and tanker prior to the removal of the USTs. Upon removal, Progress observed the condition of the USTs. Progress did not note significant corrosion or perforations on the USTs; however, areas of corrosion were noted. The USTs were removed and loaded onto a flatbed trailer and transported to the RABCO facility located in Reidsville, North Carolina for preparation for recycling. The excavation for the USTs was generally 35 feet by 48 feet by 12 feet deep. Slight petroleum odors were noted in the vicinity of the USTs, fuel lines, and dispensers. A total of 27 soil samples were obtained from the bucket of the trackhoe for analysis for total petroleum hydrocarbons as gasoline (TPH-G) including: two soil samples (S-1 and S-2) collected beneath the 1,000- gallon kerosene UST; nine soil samples collected beneath the gasoline USTs (S-3 through S-5, and S-15 through S-20); six soil samples collected beneath the product piping located beneath the canopy (S-12 through S-14, S-23, and S-24), two soil samples collected beneath the 3,000-gallon diesel fuel UST (S-21 and S-22), two soil samples collected beneath the waste oil UST; and, one soil sample was collected beneath the kerosene dispenser (S-27). Additionally, Progress collected a soil sample from approximately three feet below the base of the gasoline UST in the area of soil sample S-3 (S-3 deep) and one from approximately three feet below the soil sample S-6 (S-6 deep) for analysis for TPH-G. The purpose of the soil samples from below the former system was to determine the soil conditions beneath the site that may have been adversely affected by a previous UST system. Soil samples S-1, S-2, S-10, S-12, S-13, S-14, S-21, S-22, S-23, S-24, and S-27 were also analyzed for diesel range total petroleum hydrocarbons (TPH-D) using EPA Method 3550. The soil samples collected beneath the waste oil tank (S-25 and S-26) were analyzed for volatile organic compounds (VOCs) using EPA Method 8260, semi-volatile organic compounds (SVOCs) using EPA Method 8270, volatile and extractable petroleum hydrocarbons (VPH and EPH) using the Massachusetts Department of Environmental Protection (MADEP) Methods, and for lead and chromium. The locations of the soil samples collected during UST closure are shown on Figure 3. After obtaining each soil sample, the soil samples were transferred to laboratory-prepared containers and immediately placed on ice. A label with the facility name, soil sample number, date and time of sampling, and parameter to be analyzed was affixed to each container for identification. New disposable latex gloves were used to maintain sample integrity during the sampling process. Proper preservation methods and chain-of-custody procedures were followed throughout the sampling process. Analytical results were compared to the TPH-G Action Level of 50 milligrams per kilogram (mg/Kg) as presented in the NCDEQ Underground Storage Tank Section Guidelines for Site Checks, Tank Closure, and Initial Response and Abatement dated December 1, 2013. Laboratory analysis of soil samples S-1 UST Closure and Initial Abatement Action Report Spray Exxon Progress Project 1017005.001 January 12, 2017 4 through S-5, S-8, S-11, and S-6 Deep detected TPH-G at concentrations that exceed the North Carolina Action Level of 50 mg/Kg. Laboratory analysis of soil samples S-10 and S-24 detected TPH-D at concentrations that exceed the North Carolina Action Level of 100 mg/Kg. E. INITIAL RESPONSE AND ABATEMENT ACTION On December 14 through December 15, 2016, three 8,000-gallon gasoline USTs, one 3,000-gallon diesel fuel UST, one 1,000-gallon kerosene UST, and one 1,000-gallon waste oil UST (partially filled concrete), were removed from the site. Note that the excavation activities extended to the approximate depth of 12 feet below land surface (bls) and groundwater was not encountered. F. EXCAVATION OF CONTAMINATED SOIL Contaminated soil was not excavated as part of the initial abatement action activities. G. LABORATORY ANALYTICAL RESULTS Laboratory analysis of soil samples S-5, S-8, S-11, and S-6 Deep detected TPH-G at concentrations that exceed the North Carolina Action Level of 50 mg/Kg. Laboratory analysis of soil samples S-10 and S-24 detected TPH-D at concentrations that exceed the North Carolina Action Level of 100 mg/Kg. Based on field observations, Progress collected and tested soil samples S-5 and S-15 for VOCs using EPA Method 8260 and for VPH using the MADEP Method. Soil sample S-5 detected targeted compounds above their respective Soil-to-Groundwater Maximum Soil Contaminant Concentrations (MSCCs). None of the detected compounds exceeded their respective Residential Soil Cleanup Levels. The concentration of chromium detected in soil samples S-25 and S-26 exceed its Soil-to-Groundwater MSCC; however, the concentrations of chromium are reported as total chromium. Based on the absence of petroleum-related compounds detected in soil samples S-25 and S-26, Progress does not consider the concentrations of total chromium to represent evidence of a release. The concentrations likely represent naturally occurring concentrations of total chromium at the site. Please note, Progress did not complete an analysis to determine the concentration of trivalent versus hexavalent chromium in the soil samples and have not been A summary of the laboratory analytical results is included in Table B-3. Copies of the laboratory data sheets and chain-of-custody record are included in the Appendix. H. GROUNDWATER AND SURFACE WATER INVESTIGATION Groundwater was not encountered during the UST removal activities. UST Closure and Initial Abatement Action Report Spray Exxon Progress Project 1017005.001 January 12, 2017 5 I. FREE PRODUCT INVESTIGATION AND RECOVERY REPORT Apparent free product was not observed during the UST removal activities. J. CONCLUSIONS Following the completion of the initial abatement activities, Progress concludes the following: • Progress supervised the removal of three 8,000-gallon gasoline USTs, one 3,000-gallon diesel fuel UST, one 1,000-gallon kerosene UST, and one 1,000-gallon waste oil UST partially filled with concrete from the subject site. • Progress collected a total of 29 soil samples (S-1 through S-27, S-3 Deep, and S-6 Deep) from the vicinity of the USTs, fuel distribution lines, and beneath the dispensers for analysis for TPH-G and/or TPH-D. Laboratory analysis of soil samples S-5, S-8, S-10, S-11, S-24, and S-6 Deep detected TPH- G and/or TPH-D above their respective North Carolina Action Levels. • Laboratory analysis of risk-based soil sample S-5 detected targeted compounds above their respective Soil-to-Groundwater MSCCs. None of the detected compounds exceed their respective Residential Soil Cleanup Levels. • Laboratory analysis of soil sample S-25 and S-26 detected chromium above its Soil-to-Groundwater MSCC of 5.4 mg/Kg. None of the concentrations exceeded its Residential Soil Cleanup Level. K. RECOMMENDATIONS Progress recommends submitting a copy of this report to the Winston-Salem Regional Office of the NCDEQ. L. QUALIFICATIONS OF REPORT The activities and evaluative approaches used in this assessment are consistent with those normally employed in projects of this type. Our evaluation of site conditions has been based on our understanding of the site project information and the data obtained during our field activities. FIGURES Figure 1 Topographic Site Map Spray Exxon 103 Boone Road Eden, Rockingham County, North Carolina P.O. Box 5884 Winston-Salem, NC 27113 Telephone: (336) 722-9999 Fax: (336) 722-9998 www.progressenvironmental.com United States Department of the Interior USGS 7.5 Minute Series Topographic Map Contour Interval: 10 feet Scale: 1”=2000’ Northwest Eden, NC-VA Date: 1965, Photorevised 1978 Southwest Eden, NC Date: 1971, Revised 1994 Southeast Eden, NC Date: 1971, Revised 1994 Northeast Eden, NC-VA Date: 1965, Photorevised 1983 Project: Spray Exxon Client: Eden Oil Company Progress Job #: 1017005.001 Date: January 2017 SITE Site TABLES 5035 35508270Chromium LeadDate Collected (m/dd/yy)Sample Depth (ft BLS)S-1 12/14/2016 7 BQL BQLS-2 12/14/2016 7 BQL BQLS-3 12/14/2016 12 BQLS-4 12/14/2016 1211S-5 12/14/2016 12616BQL BQL BQL BQL BQL191 123 217S-6 12/14/2016 3 BQLS-7 12/14/2016 3 BQLS-8 12/14/2016 3120S-9 12/14/2016 315.2S-10 12/14/2016 3 BQL1,750S-11 12/14/2016 365.7S-12 12/14/2016 338.3 44.8S-13 12/14/2016 331.8 65.2S-14 12/14/2016 3 BQL BQLS-15 12/15/2016 12 BQL0.026 0.008 0.020 0.006 0.016BQL12.2 19.6S-16 12/15/2016 12 BQLS-17 12/15/2016 12 BQLS-18 12/15/2016 12 BQLS-19 12/15/2016 12 BQLS-20 12/15/2016 12 BQLS-21 12/15/2016 9 BQL BQLS-22 12/15/2016 9 BQL BQLS-23 12/15/2016 3 BQL13.7S-24 12/15/2016 2 BQL106S-25 12/15/2016 7BQL BQL BQL BQL BQL BQL BQL BQL BQL BQL BQL BQL10 2.9S-26 12/15/2016 7BQL BQL BQL BQL BQL BQL BQL BQL BQL BQL BQL BQL38.3 31.7S-27 12/15/2016 215.9 65.8S-6 Deep 12/14/2016 5128S-3 Deep 12/14/2016 1440.350 100 N/A N/A N/A N/A N/A NE N/ANE NE NEN/A N/A0.16 4.3 8.5 8.3 4.6 NE 68# 5.4 270N/A N/A313 1,200 782 782 3,129 NE 93931,000 47 400N/A N/A8,176 32,000 20,440 20,440 81,760 NE 24,528810,000 1,226 400NOTES:= Concentration exceeds Soil-to-Groundwater MSCC or NC Action Level for TPH= Concentration exceeds Residential Soil Cleanup LevelsBQL = Below Quantitation LimitsVPH and EPH = Volatile and Extractable Petroleum Hydrocarbon-Massachusetts Department of Environmental ProtectionMSCC = maximum soil contaminant concentrationft. BLS = feet below land surfacemg/kg =milligrams per kilogramNE = Not EstablishedN/A = Not ApplicableNot analyzed for this parameterNC Action Level (mg/kg)Industrial/Commercial Soil Cleanup Levels (mg/kg)Contaminant of ConcernSample IDSoil-to-Groundwater MSCCs (mg/kg)Residential Soil Cleanup Levels (mg/kg)GRONaphthaleneTolueneDROAll SVOCsC5-C8 AliphaticsChromiumAnalytical MethodVPH & EPHTable B-3Spray Exxon1,2,4-TrimethylbenzeneC9-C10 Aromatics1,3,5-TrimethylbenzeneTotal Xylenes1,500C19-C36 AliphaticsC11-C22 AromaticsC9-C12 AliphaticsN/AC9-C18 AliphaticsSummary of Soil Analytical Results UST Closure and Initial Abatement Action Report NCDENR Incident No. 13586Lead40,000N/A3146912,264540 APPENDIX