The URL can be used to link to this page

Home My WebLink About11031_CRS Facility Req for Asessment 20071016 North Carolina Department of Environment and Natural Resources Dexter R. Matthews, Director Division of Waste Management Michael F. Easley, Governor William G. Ross Jr., Secretary 1646 Mail Service Center, Raleigh, North Carolina 27699-1646 Phone 919-508-8400 \ FAX 919-715-4061 \ Internet http://wastenotnc.org An Equal Opportunity / Affirmative Action Employer – Printed on Dual Purpose Recycled Paper October 16, 2007 Sent Via E-mail and USPS David A. Franchina, Esq. Kennedy Covington Lobdell & Hickman, LLP Hearst Tower, 47th Floor 214 N. Tryon Street Charlotte, NC 28202 dfranchina@kennedycovington.com Subject: Additional Site Assessment Activities CRS Facility 1224 Isley Drive Gastonia, Gaston County Brownfields Project Number 11031-07-60 Dear Mr. Franchina: The North Carolina Department of Environmental and Natural Resources (DENR) has reviewed the currently available site information for the above referenced site and determined that data gaps have been identified. Additional assessment activities, as outlined below, are required to assist in making risk management decisions for inclusion in the brownfields agreement (BFA). During the evaluation process the following sources were utilized, brownfields property application (BPA), and the following reports submitted by you from the DENR Moorseville Regional Office: Title Prepared by Date of Report Response Action Report Environmental Strategies Corporation, PC September 4, 2002 Response Action Report Update Environmental Strategies Corporation, PC September 9, 2004 Summary of Sump Release Investigation Activities Environmental Strategies Corporation, PC December 7, 2007 Report of Phase I Environmental Site Assessment MACTEC May 10, 2007 After reviewing these documents, the following assessment items need to be addressed to determine that the site is safe for its intended reuse, which is office, light and heavy industrial use. Additional Assessment October 16, 2007 • General: The most recent Inactive Hazardous Sites Program Guidelines for Assessment and Cleanup (http://www.wastenotnc.org/sfhome/stateleadguidance.pdf ) should be followed, which in turn relies upon EPA's Environmental Investigations Standard Operating Procedures and Quality Assurance Manual (a .pdf version is available on their website at http://www.epa.gov/region4/sesd/eisopqam/eisopqam.html). Request Level 2 QA/QC data packages from a N.C. certified environmental laboratory. Submit a work plan for review prior to conducting field work for approval by DENR to ensure all aspects of the requirements are covered. • Groundwater Sampling: Collect groundwater samples from the all the site monitoring wells. Record depth of static groundwater in each well prior to purging activities, and field parameters (e.g., temperature, dissolved oxygen, pH, turbidity, and conductivity) prior to sampling activities for summary report. Contain purge water for analysis prior to disposal following approval by DENR. In lieu of sampling the containers, the consultant may rely on sample analysis for disposal options. The ultimate disposal information must be included in the report. • Soil-Gas: collect soil-gas samples or sub-slab soil-gas samples around or in the building, near Bay 3 sump pump release (source area), along the building where impacted soils could not be removed, and former tank farm. Guidance for preparing a soil-gas work plan is available at http://www.handpmg.com/articles.htm and http://www.itrcweb.org/gd_VI.asp. Submit a work plan to brownfields program for review and approval prior to schedule the field work. • Laboratory Analyses: Submit samples to a NC-certified laboratory. Analyze all groundwater volatile organic compounds (VOCs) by EPA Methods 8260, semi-volatile organic compounds (SVOCs) by EPA Method 8270, oil and grease by EPA Method 9071, and 13 hazardous substance list metals (see section A.7.1.2 of the Inactive Hazardous Sites Guidance referenced above). Analyze all soil-gas samples by TO-15 Method. Ensure laboratory method detection limits are below applicable standards. Provide complete original laboratory reports and associated laboratory QA/QC documentation in the final report to DENR. • Risk Assessment (Optional): If you all desire, you may perform a tiered risk assessment. This would allow site specific screening levels versus EPA guidance documents. First, identify potential receptors and constituents of concern on the property and media contaminant concentrations are screened using unrestricted use screening levels such as the Inactive Hazardous Sites Program’s soil and groundwater remediation goals. When volatile contaminants are detected in the soil and groundwater within 100 feet of a building (or proposed structure), the indoor air pathway must be screened as well using the EPA Vapor Instruction Guidance. Second, determine soil and groundwater remediation goals that would be protective of all receptors on the property including indoor air receptors. If risks are identified, address how these risks will be remediated or mitigated on the property so that is can be safe for current and future receptors. Recommended risk assessment guidance includes: Inactive Hazardous Sites Program’s Guidelines for Assessment and Cleanup http://www.wastenotnc.org/sfhome/ihsbrnch.htm http://www.wastenotnc.org/sfhome/stateleadguidance.pdf EPA OSWER Draft Guidance for Evaluating the Vapor Intrusion to Indoor Air Pathway from Groundwater and Soils (Subsurface Vapor Intrusion Guidance) http://www.epa.gov/epaoswer/hazwaste/ca/eis/vapor.htm EPA Risk Assessment Guidance for Superfund (RAGS) http://www.epa.gov/oswer/riskassessment/risk_superfund.htm http://www.epa.gov/oswer/riskassessment/ragsa/index.htm Additional Assessment October 16, 2007 • Building layout/Redevelopment: Provide layout of building with details in Bay areas such as ceiling height, floor material and condition, current heating and ventilation system, overhead fan locations and overhead bay doors, if used, and other relevant information for redevelopment. • Report and Figures: Submit an assessment report with a description of field activities, tabulated data (including historical data), the laboratory data packet, and information requested in above bullets. If preformed include risk assessment data, model methodology, model results. Provide groundwater elevation map and concentration map(s) for contaminants detected above applicable standards for groundwater. Include groundwater iso-concentration lines above state standards. Provide summary analytical table for contaminate detected by the laboratory versus the state standard and include historical data, if available. I am optimistic that with the additional information requested in this phase of assessment we will be able to determine the risk this site may pose to receptors. I remain very enthusiastic about this brownfields project and I look forward to working with you to advance this project. If you have any questions regarding this letter or the brownfields process, please feel free to contact me at 704/661-0330, or via e-mail at carolyn.minnich@ncmail.net Sincerely, Carolyn Minnich Carolyn F. Minnich Brownfields Project Manager Division of Waste Management cc: Central Files ec: Bruce Nicholson, DENR Thomas McKittrick