20064_Simpson Gas_Work Plan for Limited Soil and Groundwater Assessment_20170411

Work Plan for Limited Soil and Groundwater Assessment
Former Simpson Gas and Oil Company
Franklin, Macon County, North Carolina
S&ME Project No. 4341-17-002
Prepared for:
Mainspring Conservation Trust
557 East Main Street
Franklin, North Carolina 28734
Prepared by:
S&ME, Inc.
44 Buck Shoals Road, Ste C-3
Arden, NC 28704
April 11, 2017
Work Plan for Limited Soil and Groundwater Assessment
Former Simpson Gas and Oil Company
Franklin, Macon County, North Carolina
S&ME Project No. 4341-17-002
April 11, 2017 ii
Table of Contents
1.0 Introduction ............................................................................................................ 1
1.1 Purpose .............................................................................................................................. 1
1.2 Project Information ........................................................................................................... 1
1.2.1 Project Location ................................................................................................................... 1
1.2.2 Project Background ............................................................................................................. 1
1.2.2.1 Comprehensive Site Assessment (1999) ........................................................................ 2
1.2.2.2 UST Closure Testing (1999) ............................................................................................. 2
1.2.2.3 Sewer Line Installation (2010) ......................................................................................... 2
1.2.2.4 Soil and Groundwater Assessment (2015) .................................................................... 2
1.2.2.5 Brownfields Assessment .................................................................................................. 3
2.0 Proposed Assessment Activities ......................................................................... 4
2.1 Monitoring Well Construction Procedure..................................................................... 4
2.2 Sample Collection Procedures ........................................................................................ 5
2.2.1 Groundwater Sampling ....................................................................................................... 5
2.2.2 Soil Sampling ...................................................................................................................... 6
2.2.2.1 Near-Surface Soil Sampling ............................................................................................ 6
2.2.2.2 Sub-Surface Soil Samples ................................................................................................. 6
2.2.2.3 Heating Oil UST ................................................................................................................ 6
2.3 Investigative Derived Waste (IDW) Management ....................................................... 7
2.4 Quality Assurance /Quality Control .............................................................................. 7
2.4.1 Sampling Equipment ........................................................................................................... 7
2.4.2 Quality Assurance / Quality Control Samples ................................................................... 7
2.4.3 Sample Custody ................................................................................................................... 8
2.4.4 Laboratory Report ................................................................................................................ 8
3.0 Preparation of Assessment Report ..................................................................... 8
4.0 References ............................................................................................................... 8
Appendices
Appendix I – Figures
Work Plan for Limited Soil and Groundwater Assessment
Former Simpson Gas and Oil Company
Franklin, Macon County, North Carolina
S&ME Project No. 4341-17-002
April 11, 2017 1
1.0 Introduction
1.1 Purpose
This Work Plan has been prepared to detail the proposed limited soil and groundwater assessment
activities at the subject property. The purpose of the assessment activities is to obtain additional site data
to further characterize the soil and groundwater quality to work towards redevelopment of the subject
property under a North Carolina Brownfields Agreement (BFA).
1.2 Project Information
1.2.1 Project Location
The subject property is located at the intersection of Northeast Main Street and Big Bear Lane on the
property addressed 544 East Main Street in Franklin, Macon County, North Carolina. Based on a review of
the Macon County Geographical Information System (GIS) website, the subject property consists of
parcels 6595318254 and 6595317214, totaling 0.67-acres in size. The property is developed with a vacant
single story structure formerly used as a fuel station. The vicinity of the subject property is mainly
commercial properties with a greenway to the north. A map depicting the location of the parcels is
included in Figure 1. An aerial photograph of the subject property is presented as Figure 2.
1.2.2 Project Background
The subject property historically has been developed as a fuel station since the 1950s; selling kerosene,
fuel oil, gasoline, and diesel. One fuel dispenser was located adjacent to the northeastern corner of the
building on the subject property, two dispensers were located near East Main Street, and heating oil and
kerosene was distributed via the overhead product lines connected to the former fueling rack on the
southwestern portion of the building. Based on an interview between Mr. Bob Simpson, the current
property owner, and S&ME, four 30,000-gallon ASTs were located on the subject property. Based on a
review of aerial photographs, the four 30,000-gallon ASTs were located on the subject property from the
1950s through 2005. According to the North Carolina Department of Environmental Quality (NCDEQ)
Underground Storage Tank (UST) Registered Tank Database, one 2,000-gallon gasoline UST was installed
on February 26, 1981 and one 550-gallon diesel UST was installed on February 26, 1984. The USTs were
permanently closed by removal in April 1994. The property is currently vacant and no longer operated as
a fuel station.
The subject property has been accepted into the North Carolina Brownfields Program. Mainspring.
Conservation Trust (Mainspring) was able to execute a contract with an option to purchase the subject
property and is moving forward with additional effort to obtain a BFA that would allow the property to be
used as greenspace.
Previous assessment activities are summarized in the following sections:
Work Plan for Limited Soil and Groundwater Assessment
Former Simpson Gas and Oil Company
Franklin, Macon County, North Carolina
S&ME Project No. 4341-17-002
April 11, 2017 2
1.2.2.1 Comprehensive Site Assessment (1999)
In response to a Notice of Violation issued by NCDEQ in October 1998, Alpha Environmental Science, Inc.
(Alpha) was contracted by Mr. Doug Simpson (father of the current owner), the property owner and
former operator of Simpson Gas and Oil, to complete a Comprehensive Site Assessment (CSA) for the
subject property. The CSA activities included the collection of 11 groundwater samples from the shallow,
unconfined aquifer, three soil samples adjacent to the former AST area, and two soil samples at the
approximate depth of the former UST tank excavation. Based on a review of the analytical results
presented on Figure 2 of the 1999 Alpha CSA, groundwater contamination was detected in the vicinity of
the ASTs and dispensers. Soil contamination was detected in the samples collected near the ASTs and
former USTs. It should be noted that a groundwater sample was not collected near the former USTs.
1.2.2.2 UST Closure Testing (1999)
According the NCDEQ UST Registered Tank Database and the UST-2 forms found in Appendix B of the
Underground Storage Tank Closure Report written by Alpha and dated March 1999, the 2,000-gallon and
550-gallon USTs located on the Simpson Oil property were permanently closed in April 1994. To provide
proper UST closure sampling, Alpha collected two soil samples from beneath the former UST tank basin in
November 1998 and two in February 1999. Alpha summarized the analytical results by stating, “Based on
the analytical results reported, it appears that a release of petroleum has occurred from the USTs”. It is
documented in the UST-2 form of the March 1999 Alpha report that the 2,000-gallon UST was converted
to an AST and the 550-gallon UST was transferred to a farmers possession to be used as an AST.
1.2.2.3 Sewer Line Installation (2010)
Petroleum-impacted soil was encountered during installation of sewer line on the west side of the subject
property adjacent to NE Main Street. Approximately, 30 to 45 tons of petroleum-impacted soil was
excavated and transported off-site for disposal during installation of the sewer line.
1.2.2.4 Soil and Groundwater Assessment (2015)
S&ME performed soil and groundwater assessment activities on the subject property in July 2015 for the
NCDEQ Inactive Hazardous Site Branch (IHS) and in February 2017 for Mainspring. At the time of the
2015 assessment activities, the Land Trust for the Little Tennessee (now known as Mainspring
Conservation Trust) was in the process of obtaining a contract with an option to purchase the subject
property with tentative plans to redevelop the subject property as green space under a BFA. The North
Carolina Brownfields Program received a grant from the United States Environmental Protection Agency
(USEPA) to be used for assessment activities to move the subject property along in the BFA process. The
NCDEQ IHS was tasked with contracting the assessment activities for completion.
In July 2015, S&ME installed eight temporary monitoring wells and collected groundwater samples for
analyses of volatile organic compounds (VOCs) by Method 8260LL and semi-volatile organic compounds
(SVOCs) by EPA Method 8270D. Target analytes were detected in two of the groundwater samples at
concentrations that exceed the respective GCLs. Target analytes were detected in the groundwater
samples collected from monitoring wells TMW-1 through TMW-8 at concentrations that exceed the
respective North Carolina Groundwater Quality Standards (15A NCAC 2L .0202), herein identified as the 2L
Standards. Target analytes were detected in seven of the groundwater samples at concentration that
Work Plan for Limited Soil and Groundwater Assessment
Former Simpson Gas and Oil Company
Franklin, Macon County, North Carolina
S&ME Project No. 4341-17-002
April 11, 2017 3
exceeded the respective NCDEQ Division of Waste Management (DWM) Vapor Intrusion Non-Residential
Groundwater Screening Levels (GWSLs).
S&ME completed 20 soil borings ranging in depths from 10 to 20 feet below ground surface (ft-bgs) and
collected soil samples ranging in depths from 4 to 10 ft-bgs for analyses of VOCs by 8260B and SVOCs by
EPA Method 8270D. Target analytes were detected at concentrations in two of the soil samples that
exceeded the respective Industrial PSRGs, in three of the soil samples that exceeded the respective
Residential PSRGs, and eight of the soil samples that exceeded the respective Protection of Groundwater
PSRGs. Based on the groundwater elevation figure, the groundwater flows east towards the Little
Tennessee River. During the assessment groundwater was encountered approximately 9 to 14 ft-bgs.
The findings of the assessment activities were provided in the Report of Environmental Services dated
September 4, 2015. The report concluded that it appears that a release of petroleum has occurred either
from the former aboveground storage tanks (ASTs) or underground (USTs) located on the eastern side of
the retail store.
1.2.2.5 Brownfields Assessment
In general accordance with S&ME Proposal No. 43-1600872 dated November 7, 2016, S&ME completed a
Phase I Environmental Site Assessment (ESA) in association with the subject property. The February 2017
Phase I ESA revealed the following recognized environmental conditions in connection with the subject
property:
♦The subject property historically operated as a fuel station with ASTs and USTs. Petroleum
contaminated soil and groundwater has been documented on the subject property.
♦A heating oil UST was observed on the subject property, adjacent to and north of the northern
most structure located on the southwestern adjoining property.
♦The former fuel station operation on the southwestern adjoining property addressed 522 East
Main Street.
On March 27, 2017, Mr. Bradley Keyse and Mr. Loftis, both with S&ME, attended a meeting with the
following individuals to present the historical assessment information related to the subject property and
make recommendations for additional assessment activities to address data gaps identified by S&ME:
♦Ms. Sharon Taylor, Executive Director of Mainspring,
♦Mr. Jordan Smith, Land Conservation Manager with Mainspring,
♦Mr. Laseter, Associate Director with Mainspring,
♦Mr. Ken Murphy, member of the Mainspring Board of Directors,
♦Mr. Ken Fromknecht, attorney representing Mainspring in the context of the real estate
transaction, and
♦Ms. Jordan Thompson and Ms. Tracy Wahl, both with Division of Waste Management (DWM)
Brownfields Program.
The proposed additional assessment activities presented herein are a reflection of S&ME’s understanding
as to what was agreed upon by S&ME, Mainspring, and NCDEQ during the March 27, 2017 meeting.
Work Plan for Limited Soil and Groundwater Assessment
Former Simpson Gas and Oil Company
Franklin, Macon County, North Carolina
S&ME Project No. 4341-17-002
April 11, 2017 4
2.0 Proposed Assessment Activities
The following section provides the details of the proposed assessment activities associated with the soil
and shallow groundwater at the site. The assessment activities will be performed in general accordance
with the NCDEQ Inactive Hazardous Sites Program Guidelines for Assessment and Cleanup dated October
2015 unless otherwise noted. In summary, S&ME proposed the following scope of work:
♦Install one permanent monitoring well on the northeastern portion of the subject property near
former temporary monitoring well TMW-4 installed during the July 2015 assessment;
♦Collect a groundwater sample from the newly installed monitoring well;
♦Perform six soil borings in the vicinity of the former heating oil and kerosene fueling rack on the
southwestern portion of the building,
♦Perform nine soil borings in the vicinity of the former ASTs, product line, former USTs, and
dispensers;
♦Perform three soil borings near the northwestern portion of the property by Northeast Main
Street;
♦Perform three soil borings in the vicinity of the suspected “truck washing area” just north of the
building on the subject property; and
♦Perform two soil samples near the existing heating oil UST located north of the southwestern
adjoining property.
Prior to mobilization to the site, S&ME will notify the public utility location service (NC One Call) and
retain the services of a private utility locator to clear the locations of underground utilities at the
properties where subsurface assessment activities will take place. S&ME’s field services will be conducted
under a site specific Health and Safety Plan (HASP) to comply with 29 CFR 1910.120, hazardous waste
operations and emergency response.
2.1 Monitoring Well Construction Procedure
The well will be installed using rotary auger techniques to an approximate depth up to 20 feet below
ground surface (bgs).1 Prior to completing the soil boring for the monitoring well, S&ME will collect soil
profiles in 5-foot intervals using direct push techniques with a macro-core sampler. The collected soil
profiles will be field screened for concentrations of VOCs utilizing a calibrated MiniRAE 3000
photoionization detector (PID). S&ME will also record the lithology of the soil as observed in the
collected samples.
Following the collection of the soil samples using direct push techniques, S&ME will perform a
subsequent boring using a 4.25-inch inside diameter (ID) hollow stem augers. The subsequent boring will
be completed as a means to install the shallow monitoring well. The well will consist of 2-inch diameter,
flush-thread, PVC pipe inserted into an approximate 8.5-inch diameter hole. The lower portion of the pipe
will consist of manufactured well screen with 0.010-inch slots. The length of the well screen pipe will be
1 During the 2015 assessment activities, S&ME measured the depth to water in temporary monitoring well
TMW-4 to be approximately 13 ft-bgs.
Work Plan for Limited Soil and Groundwater Assessment
Former Simpson Gas and Oil Company
Franklin, Macon County, North Carolina
S&ME Project No. 4341-17-002
April 11, 2017 5
determined based the depth of the apparent water table. (Note: The well screen length and depth will be
situated so the top of the water table intersects the well at the well screen.)
Medium-to-fine grained, washed sand will be placed in the annular space of the well to a level
approximately one foot above the top of the well screen, with an approximate one foot thick bentonite
seal positioned on top of the sand pack. The annular space above the bentonite seal will be grouted with
Portland cement to the ground surface. A flush-mount protective metal cover will be installed over the
well head. The wells will be secured by a padlocked expansion plug. Following the installation of
monitoring wells, the wells will be developed using an electric submersible pump until the well is free of
visible fines.
The final well locations will be recorded using a Trimble GeoXT Global Positioning System (GPS) and/or a
measuring wheel and tape measure from existing benchmarks, i.e. structures, edge of pavement, curbing,
etc.
2.2 Sample Collection Procedures
2.2.1 Groundwater Sampling
A groundwater sample will be collected from the newly installed monitoring well, no sooner than 24 hours
following the competition of the monitoring well construction. The monitoring well will be purged for
sampling using an electric peristaltic pump. The purge water will be monitored for temperature, dissolved
oxygen, pH, oxidation/reduction potential, turbidity, and conductivity using a flow-through multi-meter.
The well will be considered sufficiently purged when the temperature, dissolved oxygen, pH, and
conductivity of the ground water have stabilized and the turbidity has either stabilized or is below 10
Nephelometric Turbidity Units (NTUs). Ten NTUs is the goal for most groundwater sampling objectives.
Stabilization occurs when dissolved oxygen, pH, conductivity, and turbidity vary no more than 10% and
the temperature is constant for three consecutive readings. If the dissolved oxygen concentration is less
than 1 milligram per liter, the dissolved oxygen concentration will be deemed stabilized if the subsequent
changes in concentrations are less than 0.1 milligram per liter. The stabilized field parameters will be
recorded.
Once the well has been sufficiently purged, a groundwater sample will be collected using a disposable
bailer and immediately placed in laboratory prepared containers. The containers will be placed in a
laboratory supplied cooler containing ice, to keep the cooler temperature at 4 degrees Celsius (ºC) or less.
All samples will be handled and shipped to a North Carolina certified laboratory for analysis under chain-
of-custody procedures.
The collected groundwater sample will be analyzed for VOCs by EPA Method 8260B, SVOCs by EPA
Method 8270D, and lead by EPA Method 6020.
Work Plan for Limited Soil and Groundwater Assessment
Former Simpson Gas and Oil Company
Franklin, Macon County, North Carolina
S&ME Project No. 4341-17-002
April 11, 2017 6
2.2.2 Soil Sampling
2.2.2.1 Near-Surface Soil Sampling
To identify areas of potential exposure from near surface soil contamination, S&ME will conduct up to 21
shallow, near-surface soil borings on the subject property using a stainless steel hand auger or direct push
techniques. The soil boring locations are described as follows:
♦Six of the soil borings will be completed in the general vicinity the former heating oil and
kerosene fueling rack on the southwestern portion of the building,
♦Nine soil borings will be completed in the vicinity of the former ASTs, product line, former USTs,
and dispensers,
♦Three soil borings bill be completed near the northwestern portion by Northeast Main Street,
♦Three soil borings will be completed just north of the building located on the subject property in
the vicinity of the suspected “truck washing area”.
The proposed soil boring locations are depicted on Figure 2. At each soil boring performed, S&ME will
collect a near-surface (0 to 2 feet bgs) soil sample. The collected soil samples will be submitted to a North
Carolina certified laboratory for analysis for VOCs by EPA Method 8260B, SVOCs by EPA Method 8270D,
and lead by EPA Method 6020. For each sample, a portion of the collected soil sample will be field
screened for concentrations of VOCs utilizing a calibrated MiniRAE 3000 PID. S&ME will also record the
lithology of the soil as observed in the collected samples. Regarding the six soil samples proposed to be
collected from within the fuel rack area, only the three samples exhibiting the highest PID field screening
values will be submitted for laboratory analysis.
2.2.2.2 Sub-Surface Soil Samples
In addition to the near-surface soil samples, S&ME will collect soil samples within two feet from the
bottom of the apparent former UST excavation, the existing product line, and the former dispensers. The
collected soil samples will be submitted to a North Carolina certified laboratory for analysis for VOCs by
EPA Method 8260B, SVOCs by EPA Method 8270D, and lead by EPA Method 6020. For each sample, a
portion of the soil sample will be field screened for concentrations of VOCs utilizing a calibrated MiniRAE
3000 PID. S&ME will also record the lithology of the soil as observed in the collected samples. Regarding
the two soil borings proposed to be completed near the existing product line, only the soil sample
exhibiting the highest field screening value from the sub-surface will be submitted for laboratory analysis.
2.2.2.3 Heating Oil UST
Two soil borings will be completed using a stainless steel hand auger – one on each end of the heating oil
UST on the subject property, adjacent to and north of the northern most structure located on the
southwestern adjoining property. One soil sample will be collected from each soil boring at a depth
within two feet below the bottom elevation of the UST, placed in laboratory-prepared sample containers
and delivered to a North Carolina certified laboratory for analysis. The collected soil samples will be
submitted to a North Carolina certified laboratory for analysis of VOCs by EPA Method 8260B, SVOCs by
EPA Method 8270D, and lead by EPA Method 6020. For each sample, a portion of the soil sample will be
field screened for concentrations of VOCs utilizing a calibrated MiniRAE 3000 PID. S&ME will also record
the lithology of the soil as observed in the collected samples.
Work Plan for Limited Soil and Groundwater Assessment
Former Simpson Gas and Oil Company
Franklin, Macon County, North Carolina
S&ME Project No. 4341-17-002
April 11, 2017 7
The proposed soil boring locations are depicted on Figure 2. The depth of the UST will be approximated
by accessing the UST via the fill port. Soil samples will not be collected below the apparent water table;
therefore, if the bottom of the UST is below the apparent water table, S&ME will not collect a soil sample
from the UST soil borings unless field screening data suggests that impacts to the near surface soils exist
as a result of UST overfills.
2.3 Investigative Derived Waste (IDW) Management
Based on our research of the site, the contaminants of concern at the subject property are petroleum
compounds. Investigative derived waste (IDW) water generated during well development,
decontamination procedures, and purging of the existing monitoring wells will be disposed of according
to the following guidelines:
♦Guidelines for Initial Response and Abatement, Assessment, and Corrective Action for Non-UST
Petroleum Releases developed by the NCDENR-DWM UST Section, effective July 1, 2012.
♦Guidelines for Assessment and Corrective Action for UST Releases developed by the NCDENR-DWM
UST Section, Change 3, effective December 1, 2013.
According to the guidelines, the IDW water can be placed on the ground near the well in manner that will
prevent surface runoff, if hazardous waste is not likely present in the groundwater and if the uppermost
aquifer below land surface is contaminated with equal or higher concentrations than the waste water
being disposed. Historically solvents have not been detected during assessment activities on the subject
property.
Soil cuttings generated during the installation of monitoring wells will be spread onsite in accordance with
the guidelines reference above.
2.4 Quality Assurance /Quality Control
2.4.1 Sampling Equipment
A new PVC sleeve will be inserted in the direct push rods prior to collection of the soil sample. New
silicone tubing (at the pump head) and polyethylene tubing (downwell) will be used with the peristaltic
pump for well purging. The groundwater sample will be collected using a new disposable bailer and new
twine.
2.4.2 Quality Assurance / Quality Control Samples
Field blanks, equipment blanks, and duplicate samples will be collected and analyzed as necessary to
provide quality control during assessment activities. In accordance with the NCDEQ Inactive Hazardous
Sites (IHS) program’s Guidelines for Assessment and Cleanup document dated October 2015, S&ME will
collected one duplicate sample per medium, per container type, per field day. During shipment to the
laboratory, a trip blank will be placed in the cooler with the groundwater samples to determine if cross
contamination occurred during the shipment process.
Work Plan for Limited Soil and Groundwater Assessment
Former Simpson Gas and Oil Company
Franklin, Macon County, North Carolina
S&ME Project No. 4341-17-002
April 11, 2017 8
2.4.3 Sample Custody
The sampler will complete a chain-of-custody (COC) form provided by the laboratory. The sampler will
sign where indicated and record the site identification, sample number, date and time of sampling, matrix
code, sample type, bottle/preservative type, and the analyses requested. When the custody of samples is
transferred, the persons relinquishing and receiving custody will sign, date, and record the time of transfer
on the COC. If the samples are shipped using a commercial courier, the bill of lading will become part of
the COC and will serve as the signature of the person receiving the samples. Upon receipt of the samples
at the laboratory, a sample custodian will accept custody of the sample and verify that the COC is still
intact. The laboratory shall maintain the COC throughout the analytical and reporting processes.
2.4.4 Laboratory Report
It is anticipated that routine analytical services will be provided by Prism Laboratories, Inc. for this project.
The laboratory will provide Level II analyses for this project, including the reporting of target analytes at
concentrations between the laboratory method detection limits and the laboratory reporting limits;
otherwise known as “J values”.
3.0 Preparation of Assessment Report
Upon receipt of analytical results, a report summarizing the collected data will be prepared. The
completed report will be submitted to Ms. Jordan Thompson with NCDEQ and Mainspring.
4.0 References
Comprehensive Site Assessment for the Release of Petroleum Product at the Simpson Soil Company Facility.
Alpha Environmental Sciences, Inc. January 26, 1999.
Guidelines for Assessment and Cleanup. NCDEQ Inactive Hazardous Sites Program. October 2015.
Guidelines for Initial Response and Abatement, Assessment, and Corrective Action for Non-UST Petroleum
Releases. NCDENR-DWM UST Section. July 1, 2012.
Guidelines for Assessment and Corrective Action for UST Releases. NCDENR-DWM UST Section. December
1, 2013.
Macon County Sewer – Hydrocarbon Contaminated Soil. McGill & Associates. September 1, 2010.
Notice of Violation. North Carolina Department of Environment and Natural Resources. October 22, 1998.
Phase I Environmental Site Assessment. S&ME, Inc. February 13, 2017.
Report of Environmental Services, S&ME, Inc. September 4, 2015.
Underground Storage Tank Closure Report for Simpson Oil Company. Alpha Environmental Sciences, Inc.
March 1999.
Appendices
Appendix I – Figures
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- PROPOSED NEAR-SURFACE SOIL SAMPLES
- PROPOSED NEAR-SURFACE AND SUB-SURFACE SOIL SAMPLES
- PROPOSED SOIL SAMPLES ADJACENT TO THE HEATING OIL UST
- PROPOSED MONITORING WELL LOCATIONS
- PROPOSED NEAR-SURFACE SOIL SAMPLES (3 HIGHEST PID RESULTS)