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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.