HomeMy WebLinkAbout17022_PSNC_Assessment Work Plan and Approval_201610
PAT MCCRORY
Governor
DONALD R. VAN DER VAART
Secretary
LINDA CULPEPPER
Director
State of North Carolina | Environmental Quality | Waste Management
1646 Mail Service Center | 217 West Jones Street | Raleigh, NC 27699-1646
919 707 8200 T
January 13, 2016
Sent Via Email
Mr. Carl Stewart
Prolific Properties, LLC
443 Blake Street
Statesville, North Carolina
cstewart@actionservicecompany.com
Subject: Additional Assessment
Former PSNC
443 Drake Street
Statesville, Iredell County
Brownfields Project Number 17022-13-49
Dear Mr. Stewart:
The North Carolina Department of Environmental Quality (DEQ), Brownfields Program has
reviewed the documents submitted with the Brownfields Property Application, as well as files
available through the DEQ Inactive Hazardous Sites Branch (IHSB). The following is a summary
of the reports reviewed:
Site Cleanup Questionnaire, S&ME (June 21, 2010)
Report of Monitoring Well Sampling, Shield Engineering, Inc. (September 25, 2008)
Site Closure Report, HAZ-MAT Transportation and Disposal (May 9, 2007)
Limited Site Assessment Report Addendum, TBE Group, Inc. (August 2004)
Limited Site Assessment Report, TBE Group, Inc. (July 2003)
Phase I Environmental Site Assessment (ESA), TBE Group, Inc. (July 2000)
Based on our review of these documents, data gaps were identified. Additional assessment
activities, as outlined below, are required to assist in making risk management decisions for
inclusion in the brownfields agreement (BFA).
1) Provide additional information regarding the former sump removed in 2007. The Site Closure
Report does not depict the location of the former sump on the property. Also, please provide
photographs of the site area and a description of the condition/type of cover over this area (i.e.
gravel, concrete, etc.).
Mr. Carl Stewart
January 13, 2016
Page 2
2) In the Phase I ESA, an oil-water separator was reported. Please provide information on the
oil-water separator, including location on a site plan, type of cover, and its current status (in
use, out of service, removed, etc.).
3) Additional Assessment Activities: The following areas of the site will require additional
assessment. Prior to conducting field activities, a work plan should be submitted to DEQ for
review and approval. The work plan should include a description of the sampling and
analytical methods to be utilized and a map depicting the proposed sample locations. The most
recent Inactive Hazardous Sites Program Guidelines for Assessment and Cleanup
(http://portal.ncdenr.org/web/wm/sf/ihs/ihsguide) should be followed. Request Level 2
QA/QC data packages from a N.C. certified environmental laboratory.
a) Underground Storage Tank (UST) System: Collect sufficient soil samples to evaluate if a
release has occurred from the UST system. At least three (2) borings should include a
shallow (0-2 ft) sample to evaluate for the potential of surface spills in addition to samples
collected from the interval which exhibits the most potential for impact based on field
screening. If no impacts, collect samples at the estimated base of the UST or product lines.
Soil samples should be analyzed for volatile organic compounds (VOCs) and polycyclic
aromatic hydrocarbons (PAHs).
Please note, because this assessment is to determine if a release has occurred from the UST
system it is not intended to meet DEQ UST Section closure requirements. However, if the
USTs will be removed or closed in the near future through the UST Section, we can accept
some of the closure sampling results in lieu of some, if not all, of the above assessment
sampling requirements.
b) Repair Shop: Install one soil boring on the northwest exterior corner of the repair shop
building where stained soils were previously reported. In addition, install a minimum of
two soil borings inside the repair shop. These should be biased toward suspected source
areas (drains, oil water separator, sump, etc.). At a minimum collect surficial samples (0-
2 ft) from each boring and one sample between the three borings at the interval (below 0-
2 ft) suspected of having the greatest impact based on field screening.
Each of the soil samples will be analyzed for VOCs, semi-volatile organic compounds
(SVOCs), Resource Conservation and Recovery Act (RCRA) metals plus hexavalent
chromium, and polychlorinated biphenyls (PCBs).
c) Utility Lines: Install one soil boring adjacent to the stormwater and/or sewer line on the
northern corner of the property (near MW-3). Collect at least one surficial sample and then
sample at the depth of anticipated base of utility line, or interval with the greatest potential
for impact based on field screening. Each of the soil samples from utility line evaluation
will be analyzed for only VOCs.
d) Loading Dock: Install one soil boring in the loading dock area of the warehouse/office
building. Collect one surficial sample at a minimum. However, if impacts are suspected
Mr. Carl Stewart
January 13, 2016
Page 3
based on field screening an additional sample should be collected. The sample(s) should
be analyzed for VOCs, SVOCs, RCRA Metals plus hexavalent chromium, and PCBs.
e) Groundwater Sampling: Collect groundwater samples from each of the on-site monitoring
wells for analysis of VOCs by EPA Methods 8260.
4) Receptor Survey: Complete the enclosed receptor survey and include as an attachment to the
Additional Assessment report.
5) Report and Figures: Upon receipt of analytical data, submit a summary report with a
description of field activities, tabulated data in comparison to applicable screening levels, and
the laboratory data packet with applicable QA/QC documentation, provide a site plan with well
locations, locations of sample points, and current site structures. Provide concentration map(s)
for contaminants detected above applicable standards. Include a detailed description of current
operations since the brownfields property application was submitted. Please note, all sample
points may need to be included on the future Brownfields plat. DEQ recommends having
sample locations surveyed at the time of collection for use in preparation of the Brownfields
plat.
Please provide the Work Plan for additional assessment activities as soon as you are able. If you
have questions about this correspondence or require additional information, please feel free to
contact me by phone at 704-235-2195 or by email at joselyn.harriger@ncdenr.gov.
Sincerely,
Joselyn Harriger, PG
Brownfields Project Manager
cc: Billy Clarke, Roberts & Stevens, P.A.
Tracy Wahl, DEQ
EXPERIENCED CUSTOMER FOCUSED INNOVATIVE
MAAONLINE.COM
October 21, 2016
Ms. Jordan Thompson, Project Manager
North Carolina Department of Environmental Quality
Brownfields Program
610 E. Center Avenue, Suite 301
Mooresville, NC 28115
Subject: Revised Work Plan for Additional Brownfield Assessment
Former PSNC Facility, 443 Drake Street, Statesville, NC
Mid-Atlantic Proposal: 000H1086.00
Dear Ms. Thompson:
Mid-Atlantic Associates, Inc. (Mid-Atlantic) submits for your approval our Work Plan for
additional assessment for the above property. Our work plan is based on the
requirements outlined in your letter to Prolific Properties dated January 13, 2016.
BACKGROUND
Prolific Properties purchased the property at 443 Drake Street from PSNC Energy in
2004. Subsequent to the purchase, contamination from previous PSNC activities was
discovered on site and several phases of assessment have been completed. Based on
conversations with PSNC, an agreement was reached to procure a North Carolina
Brownfield Agreement. A letter dated January 13, 2016 sets forth additional assessment
activities requested by the North Carolina Department of Environmental Quality (NCDEQ)
in order to address identified data gaps identified by NCDEQ based on their review of
available site data.
WORK PLAN
Based on our understanding of the requirements outlined by NCDEQ, we propose the
following tasks be included in our Work Plan:
1125 E. Morehead Street, Suite 104
Charlotte, NC 28204-2849
office 980. 585.1271
facsimile 980. 585.1272
Revised Additional Assessment Work Plan 443 Drake Street, Statesville, North Carolina October 21, 2016
Prolific Properties, LLC Page 2
1. Preliminary Assessment Planning – Prior to conducting any subsurface activities,
Mid-Atlantic will complete the following activities:
a. Develop a Site Health & Safety Plan
b. Contact NC One Call for location of public utilities
c. Contract with a private utility location company to located on-site utilities in
the areas of planned operations and to clear specific boring locations.
2. Soil Sampling – Mid-Atlantic will subcontract with a GeoProbe® contractor to
advance 9 soil borings and collect up to 13 soil samples as outlined by NCDEQ.
All borings will be field screened with a photoionization detector (PID) or similar
field screening device. Borings will be advanced to 10 feet below grade with the
exception of one boring around the USTs, which will be advanced to 15 feet below
grade, below the estimated invert of the 10,000 gallon UST. Proposed soil borings
are depicted on the attached Drawing 1.2.
Mid-Atlantic will follow the Inactive Hazardous Sites Program Guidelines for
Assessment and Cleanup, October 2015 as appropriate. Per Mid-Atlantic protocol,
each soil sample will be collected using new nitrile gloves, placed in laboratory-
supplied glassware, given a unique identifier, documented in our field notes and
chain-of-custody, placed on ice and delivered to a North Carolina accredited
laboratory for analyses by the methods specified. A level 2 QA/QC package will be
provided for the laboratory data.
Note: we have omitted laboratory analysis for polychlorinated biphenyls (PCBs).
Based on available information and conversations with the property owner, the
former repair shop was used for vehicular maintenance and fueling (adjacent UST
system). We have found no evidence of historical use or storage of equipment
and/or transformers that would have contained PCB oils.
UST System – Three (3) soil borings will be installed around the UST system.
Two (2) shallow (0’-2’) soil samples will be collected from borings near the product
lines and dispensers and one (1) soil sample will be collected near the base of the
UST invert at approximately 15 feet below grade. These samples will be field
screened using a PID or similar field screening device. The soil sample with the
highest field screening reading will be collected for laboratory analysis and
analyzed for Volatile Organic Compounds (VOCs) by EPA Method 8260B and for
polycyclic aromatic compounds (PAHs) by EPA Method 8270D.
Revised Additional Assessment Work Plan 443 Drake Street, Statesville, North Carolina October 21, 2016
Prolific Properties, LLC Page 3
Repair Shop – Four (4) borings will be installed around the repair shop (two interior
and two exterior); Five (5) total soil samples will be collected from these borings.
Each boring will have one sample collected between 0-2 feet below grade with one
additional deeper sample collected from the boring exhibiting the highest field
screening reading. Each soil sample will be analyzed for VOCs by EPA Method
8260B, for Semi-Volatile Organic Compounds (SVOCs) by EPA Method 8270D,
for Resource Conservation and Recovery Act (RCRA) metals by EPA Method
6010C and Hexavalent Chromium by EPA Method 7196A.
Utility Lines – One (1) soil boring will be installed near the location of the
sewer/storm water line near the northern corner of the property in the vicinity of
MW-3. Two (2) soil samples will be collected; one between 0-2 feet below grade
and one collected at the depth of highest field screening reading. These samples
will be analyzed for VOCs by EPA Method 8260B.
Loading Dock – One (1) soil boring will installed at the corner of the loading dock.
One (1) soil sample will be collected between 0-2 feet below grade. If field
screening indicates a potential for impact, a deeper sample will also be collected.
Sample(s) will be analyzed for VOCs by EPA Method 8260B, for SVOCs by EPA
Method 8270D, for RCRA metals by EPA Method 6010C and Hexavalent
Chromium by EPA Method 7196A.
3. Groundwater Sampling – Nine on-site groundwater monitoring wells (MW-1
through MW-6, MW-12, MW-13 and MW-14) will be sampled and analyzed for
VOCs by EPA Method 8260B. One trip blank for QA/QC purposes will also be
provided.
4. Quality Assurance/Quality Control (QA/QC) – Mid-Atlantic will collect one soil
sample and one groundwater sample, in addition to the groundwater trip blank, for
QA/QC purposes. The samples will be assigned a “blind” identifier and logged into
Mid-Atlantic’s field records with the corresponding sample location, which will not
be identified to the laboratory. The QA/QC soil sample will be analyzed by VOCs
by EPA Method 8260B, for SVOCs, including PAHs by EPA Method 8270D, for
RCRA metals by EPA Method 6010C and Hexavalent Chromium by EPA Method
7196A. Similarly, one “blind” QA/QC groundwater sample will be collected in
similar fashion and analyzed for VOCs by EPA Method 8260B.
Revised Additional Assessment Work Plan 443 Drake Street, Statesville, North Carolina October 21, 2016
Prolific Properties, LLC Page 4
5. Receptor Survey – Mid-Atlantic will complete the Brownfields Property Receptor
Survey to identify potential sensitive receptors.
6. Site Survey – in preparation for preparing the brownfield plat, sampling locations
and site features will be surveyed by a North Carolina-licensed Professional Land
Surveyor (PLS). Sampling locations and site features will be added to the
brownfield plat, once prepared and will serve as the basis for figures prepared for
the Phase II report.
7. Report – upon completion of field activities and receipt of laboratory analytical
data, Mid-Atlantic will prepare a written report summarizing our activities and
results in a NCDEQ-acceptable format. This report will include appropriate figures,
tables and copies of laboratory data sheets.
Our report will also include clarification of the oil/water separator, which was also
referenced as the “sump”. Based on our field reconnaissance, these are one and
the same. The location of the oil/water separator will be identified on report figures
with photographs of the site and pertinent site features provided in a photographic
log.
SCHEDULE
Mid-Atlantic is prepared to mobilize to the subject site upon approval of the Work Plan by
NCDEQ. Field activities will require 3.5-4 days to complete. Laboratory analysis is
typically available within 10 days and our report and receptor survey can be prepared
within 2 weeks of receipt of laboratory data. We recommend a time line of 30 days to
complete the scope of work proposed. We may be reached any time at (980) 585-1271.
With best regards,
MID-ATLANTIC ASSOCIATES, INC.
Greg D. Icenhour, P.G., MBA
Principal Geologist
Attachment: Drawing 1.2 – Site, Proposed Soil Boring and Monitoring Well Location Map
JI
E
PAT MCCRORY
Governor
DONALD R. VAN DER VAART
Secretary
MICHAEL SCOTT
Director
State of North Carolina | Environmental Quality | Waste Management
1646 Mail Service Center | 217 West Jones Street | Raleigh, NC 27699-1646
919 707 8200 T
October 26, 2016
Sent Via E-mail
Mr. Greg Icenhour, PG MBA
Mid-Atlantic Associates, Inc.
1125 E. Morehead Street, Suite 104
Charlotte, North Carolina 28204
GIcenhour@maaonline.com
Subject: Work Plan Approval
Former PSNC Facility
443 Drake Street
Statesville, Iredell County
Brownfields Project No. 17022-13-049
Dear Mr. Icenhour:
The North Carolina Department of Environmental Quality (DEQ) Brownfields Program reviewed
the Work Plan for Additional Brownfield Assessment dated August 1, 2016 and provided
comments by e-mail on October 20, 2016. A Revised Work Plan for Additional Brownfield
Assessment dated October 21, 2016 was received and subsequently reviewed by DEQ. All
comments have been incorporated; therefore, the Revised Work Plan for Additional Brownfield
Assessment is approved.
Be advised that this approval from the Brownfields Program does not waive any applicable
requirement to obtain any necessary permits, licenses, or certifications for the above listed
activities nor does it waive any requirement to comply with applicable law for such activities. If
you have any questions, please feel free to contact me at 704-235-2166, or via e-mail at
jordan.thompson@ncdenr.gov.
Sincerely,
Jordan Thompson
Brownfields Project Manager
ec: Mr. Carl Stewart, Prolific Properties, LLC
Mr. William Clarke, Roberts & Stevens, P.A.