Andale_Env Monitoring Prg-Site Dev Activities-OCR

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1.1
Introduction
Background
Environmental Monitoring Program
Site Development Activities -Forest City, NC
Andale, LLC
Historical and more recent environmental site assessments conducted on one or more
parcels comprising the former Burlington Industries and Mako Marine building (the
"site") located at 1181 Old Caroleen Road in Forest City, NC, indicate that, while some
impacts to the soil and groundwater at the site have been identified, the known impacts
appear to be extremely limited in both nature (i.e., relative toxicity) and extent (area and
volume). Specifically:
• The inorganic constituents detected in the soil at the property appear to be within
the ranges representative of naturally occurring conditions, and no evidence of a
release of such constituents has been identified; and,
• Groundwater has historically been encountered at depths greater than 30 feet
below ground surface throughout the site.
This program described herein is not intended to be a substitute for a health and safety
plan (or other reasonable instrument) with respect to worker safety, and should not be
relied on as such by the General Contractor, its subcontractors, or any other entity or
person .
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2 Scope and Purpose
Environmental Monitoring Program
Site Development Activities -Forest City, NC
Andale, LLC
The purpose of this Environmental Monitoring Program (EMP) is to identify and address
environmental conditions that could potentially impact the Andale Project. The EMP
describes monitoring activities to be conducted and coordinated by all site personnel
during construction and construction-related activities.
The primary focus of the monitoring activities is to identify and respond to conditions
that, if and when identified, could be reasonably associated with environmental impacts.
Such environmental impacts include, but are not limited to:
• Unusual smells or odors in soil;
• Visual observations of staining or liquid "pools" in soil;
• Exposed groundwater (intrusion) in trenched or excavated areas; and,
• Chemical or oil spills.
2.1 Roles and Responsibilities
Each party involved in the implementation of this Environmental Monitoring Program is
responsible for providing a collaborative and working atmosphere to ensure that
environmental issues are addressed in a timely and efficient manner and without
incurring damage to the environment or project. The roles and responsibilities of each
party are discussed in the subsections below.
2.1.1 Project Owner/Site Developer
The Project Owner (PO) is responsible for the overall compliance with this EMP and
applicable environmental rules and regulations pertaining to site development. In
addition, Andale shall:
• Communicate and coordinate environmental site efforts and mitigation strategies.
• Support General Contractor (GC) and Environmental Consultant (EC) efforts to
address the program elements as described.
• Direct all appropriate environmental and project site efforts.
2.1.2 General Construction Contractor
The GC is responsible for managing and coordinating the site development in
accordance with the contract documents and the approved plans and permit provided
by the North Carolina Department of Environment and Natural Resources. This work
includes cooperating with the onsite monitoring and testing company relative to
environmental impacts and possible remediation activity. In addition, the GC is
responsible for notifying the PO and the EC of any potential or suspected environmental
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Environmental Monitoring Program
Site Development Activities -Forest City, NC
Andale LLC
impacts that it can reasonably identify through the normal course of construction, to soil,
groundwater, or other sensitive receptors (e.g., wetlands, conservation areas, etc.).
Furthermore, the GC shall:
• Coordinate with the PO and make reasonable adjustments to construction
activities and scheduling related to suspected environmental impacts.
• Communicate program requirements to site personnel.
• Provide construction assistance to support such activities as staging and
stockpiling potentially impacted or suspect materials for further analysis.
• Assist the EC (as requested) with the removal of materials that have been
identified as requiring disposal. If removal activities are necessary, such actions
should be taken in consultation with the PO and the EC and in accordance with
company procedures and applicable laws for transporting and disposing at
landfill, including completing appropriate manifest and paperwork as the waste
generator.
2.1.3 Environmental Consultant
The EC is responsible for notifying the PO and the GC of potential impacts to soil,
groundwater, or other sensitive receptors (e.g., wetlands, conservation areas, etc). In
addition, the EC shall:
• Monitor compliance with this program on behalf of the PO.
• Perform field screening, sampling and analysis of soil, identification of exposed
groundwater or potentially contaminated soil and/or materials requiring
management, removal, and/or off-site management.
• Conduct the necessary characterization, management, and removal of materials
that have been identified as requiring such handling and ensure compliance with
applicable regulations.
• Participate in daily construction meetings
• Coordinate with a remediation contractor to store, transport, and dispose
potentially-impacted or suspect materials.
• Maintain a daily log of monitoring activities and results .
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Environmental Monitoring Program
Site Development Activities -Forest City, NC
Andale, LLC
Notification and Incident Handling Procedures
Upon the identification of a suspected impact by the GC (or its subcontractors) or the
EC, the PO and the EC shall be notified immediately. ,
• The PO will evaluate the impact and coordinate the appropriate response
actions.
• In the event that the PO cannot be reached, the EC will initiate response actions
as described in this program, until the PO can be contacted.
• In the event of a significant environmental impact, the PO will consult with the EC
and the GC to develop a contingency plan to reschedule any affected
construction work activities.
Response procedures for specific impacts are discussed in more detail in the following
subsections.
3.1 Discovery of Suspected Environmental Impacts -Soil
The steps presented below should be followed in the event that a potential or suspected
impact to the soil is encountered by the GC (or its subcontractors) or the EC:
1. Suspect materials and/or conditions of interest that are identified must be
evaluated by the EC.
2. The PO will coordinate with the GC's onsite Superintendant and the EC so that
personnel can be provided appropriate instructions regarding activities in that
area.
3. Once at the location of interest, the EC personnel will visually observe the
situation and screen the air and soil with a photo-ionization detector (PIO) and X-
Ray Fluorescence (XRF) spectrometer (exposed groundwater will identified and
recorded). At this point, the EC will initiate a log of the incident using the Incident
Reporting Form (including date, time, location, screening results, and general
weather conditions).
4. Unless the PIO provides a reading of greater than 50 ppm or an XRF reading of
greater than 150 ppm for a specific inorganic compound, the area will not require
further screening at that time.
5. If either of the screening tools provides a reading in excess of the values
provided above, or a liquid pool is observed, or groundwater is encountered in an
area which has no historic data associated with it or where historic
concentrations exceeded regulatory criteria, then work shall cease at that
location until the EC, the GC, and the PO develop and approve a strategy to
address the situation.
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Environmental Monitoring Program
Site Development Activities -Forest City, NC
Andale, LLC
6. Depending on the nature of the observation, and the ensuing discussion (which
may include involving NCDENR), follow-on activities may include resuming work,
sampling and laboratory analysis of the suspect material and ceasing work in the
area until the results are received, and removing and sequestering the suspect
material (e.g., covering or placing soil in a roll-off container) for further evaluation
and management.
7. Upon closure of an incident, the EC will finalize an Incident Report for delivery to
the PO.
3.1.1 Initial Screening and PID/XRF Screening
The demolition, excavation, and grading activities will be monitored by the EC for visual,
olfactory, or other signs of environmental impacts.
• Monitoring observations and measurements shall include odor, color, texture,
and the presence of suspect materials.
• Visual monitoring will be continued throughout site activities involving the
disturbance of soil and construction-related activities.
• Soil suspected of potential contamination will be evaluated visually by the EC,
and using a PID and XRF.
3.1.2 Secondary Screening and Confirmation Sampling
If the initial screening provides results greater than the criteria identified in Reporting
Procedure #4, at least one sample will be collected and submitted for laboratory
analysis from the most visibly contaminated or otherwise impacted location and horizon
in each area of concern.
• The samples will be collected and analyzed in accordance with procedures
specified in the Guidelines for Assessment and Cleanup, August 2010, Inactive
Hazardous Sites Program, North Carolina Department of Environment and
Natural Resources (NCDENR Guidelines).
• Soil will be sampled at a minimum frequency of one sample per 100 cubic yards
(approximately) in a pile or one sample per every 200 square feet if still in-place.
• Soil samples collected for all constituents except volatile organic compounds
(VOCs) will be collected from 0 to 6 inches below ground surface at each grid
node. Samples collected for voe analysis should be collected at a depth of 6 to
12 inches below ground surface.
Once the analytical results are available, the situation and material will be handled per
the Disposal and Handling Guidelines identified below .
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3.2
Environmental Monitoring Program
Site Development Activities -Forest City, NC
Andale, LLC
Discovery of Suspected Environmental Impacts -Groundwater
Groundwater discovered in trenched or excavated areas will be addressed as a
potential environmental impact. The steps below should be followed in the event of
suspected impacts to the groundwater.
1. If determined necessary by the EC and the PO (based on historical data and the
location of the exposed groundwater), a minimum of two groundwater samples
will be collected from representative areas of exposed groundwater.
2. Localized and impacted water may be sequestered temporarily by pumping into
storage totes or a frac tank to be supplied by the EC (with the assistance of the
GC if needed).
3. All samples will be analyzed by the laboratory on a 24-hour turnaround time.
4. Upon receipt of the laboratory results, the EC will evaluate the data against
federal MCLs or North Carolina groundwater standards (15A NCAC 2L .0202).
5. The EC, in consultation with the PO, will coordinate appropriate disposal efforts if
it is determined that the groundwater is impacted.
6. For non-detect results, groundwater may be disposed of by the general
construction contractor in accordance with their health and safety protocols and
best management practices as well as local and federal regulations.
7. Upon closure of the groundwater incident, the EC will finalize an Incident Report
for delivery to the PO.
3.3 Discovery of Suspected Environmental Impacts -Chemical I Oil Spill
Incident
All spills should be reported to the PO by the GC and the EC immediately. In addition,
Site personnel should follow company procedures specified in the Hazard
Communication Program. In the case of an emergency, Site personnel should call 911.
The following steps should be followed in the event of a chemical or oil spill incident:
1. The EC will immediately go to the location of interest, visually note and document
the nature and amount of material that was spilled.
2. The EC will coordinate with the GC to initiate any necessary excavation and
sequestration of the impacted materials.
3. The EC will coordinate the removal of impacted materials. Soil and groundwater
may be sequestered as appropriate until appropriate characterization/testing can
be completed .
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Environmental Monitoring Program
Site Development Activities -Forest City, NC
Andale, LLC
4. Following the excavation and removal of impacted soil, the EC will sample the
ground surface at a minimum frequency of one sample per 200 square feet.
5. Samples will be collected and submitted to the laboratory for appropriate analysis
of constituents based on the nature of the impact (e.g., Total Petroleum
Hydrocarbons -Gasoline and/or Diesel Range Organics, metals, VOCs, semi-
volatile organic compounds, polynuclear aromatic hydrocarbons).
6. The area will remain secured until the PO can make an "all clear" determination.
7. Excavation and sampling results should be "non-detect" or as close as
reasonably possible. The PO may request additional remediation to achieve
cleanup.
8. Upon closure of the spill incident, the EC will finalize an Incident Report for
delivery to the PO.
3.4 Other Environmental Incidents
Any potential or suspect environmental incident not addressed above shall be
immediately reported to the PO and the EC, who will then respond in accordance with
this Program. Site personnel should continue to follow procedures identified in this
Environmental Monitoring Program and the Hazard Communication Program.
3.5 Disposal and Handling
The proper handling and disposal of contaminated and/or potentially impacted soil and
other related materials that may be generated during site development are discussed
below. The general classifications of materials anticipated to be handled and disposed
of in accordance with this Program include:
1. Native soil that exceeds the default North Carolina Preliminary Health-Based Soil
Remediation Goals and background concentrations for VOCs and/or metals;
2. Undifferentiated urban fill soil with constituent concentrations greater than the
North Carolina Preliminary Health-Based Remediation Goals and background
concentrations (which soils contain non-soil components such as brick, wood,
metal scrap, and other demolition debris that are impracticable to separate on
site);
3. Petroleum-impacted soil with stains or other visible signs of free product or
petroleum impacts. Environmental monitoring will be conducted during the
construction work covered by this program, such that any other classifications of
materials encountered will be identified, and this program will be modified to
address the proper handling and disposal of other classifications of materials if
encountered; and,
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Environmental Monitoring Program
Site Development Activities -Forest City, NC
Andale, LLC
4. Groundwater that exceeds federal MCLs or North Carolina groundwater
standards (15A NCAC 2L .0202) for VOCs.
5. Other liquids identified during construction and/or demolition activities
3.5.1 Soil Management
Areas to be excavated and the limits of the excavation(s) will be determined by field
screening data, analytical results from confirmation sampling, and/or visual identification
of a petroleum release.
It is anticipated that the soil that is excavated will be loaded either by shovel into 55-
gallon drums or using a backhoe or similar earthmoving equipment into approximately
30 cubic yard, polyethylene-lined rolloffs that will be staged onsite in a construction and
demolition-free zone in order to eliminate the need to stockpile soil on site. The drums
will be sealed and the rolloffs covered when not in use to prevent the loss of material
while on site. In the event that large quantities (e.g., greater than 60 cubic yards) of soil
need to be removed from the site, excavated soil will be directly loaded onto haul trucks.
These trucks will have the necessary covers, liners, or other control measures to
prevent the loss of material either while on site or during transportation to the landfill.
Prior to being removed from the site, the soil will be characterized for disposal
purposes. The preferred off-site disposal alternative will be a Subtitle D (i.e., non-
hazardous) landfill. Therefore, for landfill acceptance purposes, soil samples will be
analyzed for toxicity characteristic leaching procedure (TCLP) for the applicable
constituents at a frequency based on the requirements of the landfill operator. If the
sample fails the TCLP criterion the soil will be disposed of offsite at a Subtitle C (i.e.,
hazardous) landfill. Prior to site activities, Subtitle D (non-hazardous) and Subtitle C
(hazardous) landfills will be identified and pre-certified to receive non-hazardous soil.
Prior to leaving the site, the soil transport vehicles will be subject to tire washing and
decontamination to prevent spreading of soil and dust to external areas. Shipments of
waste from the site will be documented in the form of a bill of lading or waste tracking
sheet, describing the type and amount of waste and the receiving facility or, as
necessary, with a hazardous waste manifest. All such documentation will be stored in a
searchable format and maintained by the EC.
Soil confirmation sampling will be performed to verify that soil concentrations of metals
and/or VOCs are less than the North Carolina Preliminary Health-Based Remediation
Goals and that diesel and gasoline-range total petroleum hydrocarbons )TPH-DRO and
TPH-GRO) respectively are less than 10 parts per million. The samples will be
collected in a manner consistent with NCDENR and/or USEPA methods and will be
submitted to a certified analytical laboratory. Quality assurance/quality control (QA/QC)
• samples may be collected at a minimum frequency of 10 percent (i.e., 1 for every 10
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Environmental Monitoring Program
Site Development Activities -Forest City, NC
Andale, LLC
samples that are collected). Depending on the results of the confirmation samples, the
excavation will either be enlarged or backfilled with soil from other areas of the site or
with borrow material from an approved offsite source. Any off-site soil used for backfill
will be pre-qualified for acceptance as uncontaminated fill material using environmental
criteria. Specifically, the procedures for environmental prequalification will consist of
collection and analysis of one sample for voes, SVOCs, pesticides, and inorganic
constituents.
3.5.2 Liquid Management
Liquids, including water, that have been potentially impacted by spills or other historical
releases will be pumped as necessary into 55-gallon drums or 275-gallon totes using a
sump pump or similar equipment. Prior to being removed from the site, contents of the
storage containers will be sampled and characterized for disposal purposes. The
preferred off-site disposal alternative will be solidification followed by disposal at a
Subtitle D (i.e., non-hazardous) landfill.
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Environmental Monitoring Program
Site Development Activities -Forest City, NC
Andale, LLC
4 Concrete Slab Removal -Former Mako Building
Upon completion of subsurface soil and soil vapor sampling at the former Mako
Building, the building will be demolished and the concrete slab removed. Due to the
potential for underground utilities and historical process lines to be encountered during
the slab removal, the EC will monitor all concrete removal activities for visual or
olfactory signs of contamination. Such signs may include identification of sub-slab
process pipes, standing pools of liquid, chemical or petroleum odors.
As a most conservative approach, the EC will periodically screen the soil beneath the
slab using a PID and XRF to assess the potential for voe impacts or significant metals
concentrations. Screening guidelines will follow the procedures outlined in Sections
3.1.1 and 3.1.2 above. If either of the screening tools provides a reading in excess of
the values identified above, or a liquid pool is observed, then work shall cease at that
location until the EC, the GC, and the PO develop and approve a strategy to address
the situation. Depending on the nature of the observation, and the ensuing discussion
(which may include involving NCDENR), follow-on activities may include resuming work,
sampling and laboratory analysis of the suspect material and ceasing work in the area
until the results are received, and removing and sequestering the suspect material (e.g.,
covering or placing soil in a roll-off container) for further evaluation and management.
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5 Training and Communication
Environmental Monitoring Program
Site Development Activities -Forest City, NC
Andale, LLC
The PO will rely on both the GC and the EC, as well as other personnel (either
employed directly by the GC or employed by a subcontractor), to assist with the
identification of any suspected environmental impact and coordination of any related
efforts as described in this Program.
The EC and the GC should ensure that all of their onsite employees are fully briefed
with respect to this Environmental Monitoring Program, are knowingly responsible for
assisting in its implementation, and are empowered to insist that the subcontractor
personnel are equally briefed and understand their responsibilities. For those purposes,
the EC will brief the GC on the contents of this Program, and the GC will cover incident
identification and reporting in their worker site safety and orientation meetings.
5.1 Recordkeeping
The EC will keep a record of daily field activities in bound field notebooks. Entries into
field notebooks will be legibly written and will provide a clear record of activities. Entries
will be made in waterproof ink and in language that is objective and factual. Drawing a
single line through the text will indicate errors, such that the text in error remains legible.
Each page will be signed, numbered, and dated, and each day's work will identify the
date, time, location on-site, field personnel present, and weather conditions observed.
• All field screen measurements will be recorded in the field notebook and will
include the location, date and time of screen, and the resultant values.
• Additionally, standardized separate incident forms will be completed for any
condition of interest that is reported to or observed by the EC.
• These incident forms will include language pertaining to the date, time, location,
observations, field screen results (if any), and resolution of the situation
(including response activities, if any) for the occurrence .
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