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HomeMy WebLinkAbout17038 Goodyear SMP 20171129 State of North Carolina | Environmental Quality | Waste Management 1646 Mail Service Center | 217 West Jones Street | Raleigh, NC 27699-1646 919 707 8200 T November 30, 2017 Sent Via Email (JStewart1@ecslimited.com John M Stewart ECS Southeast LLP 4811 Koger Boulevard Greensboro, NC 27407 Subject: Brownfields Site Status Letter Goodyear Service Center Amendment 615 South Tryon Street Charlotte, Mecklenburg County Brownfields Project Number 17038-13-060 Dear Mr. Stewart: On November 29, 2017, the North Carolina Brownfields Program (NCBP) received a revised Soil Management Plan (SMP) for the above referenced brownfields site. This work plan is the for the Area of Known Soil Contamination defined on the Brownfields Plat Map. The work plan is approved. Be advised that this approval from NCBP 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 or comments, please contact me at 704/661-0330. Sincerely, Carolyn Minnich Brownfields Project Manager Division of Waste Management ec: Central Files, DEQ Dave Franchina, dave.franchina@klgates.com Elizabeth McMillan, emcmillan@crescentcommunities.com November 29, 2017 Ms. Elizabeth A. McMillan Crescent South Tryon, LLC 227 West Trade Street, Suite 1000 Charlotte, North Carolina 28202 Reference: Soil Management Plan Former Goodyear Service Center 100 and 122 East Stonewall Street & 615 South Tryon Street Charlotte, Mecklenburg County, North Carolina ECS Project No. 49-5350 Dear Ms. McMillan: ECS Southeast, LLP (ECS) has prepared a Soil Management Plan to manage the excavation, handling and disposal of soil from the Area of Known Contamination, as defined in the Brownfields Agreement for the referenced property. This plan has been developed at the request of the North Carolina Division of Waste Management (NCDWM) - Brownfields Group. ECS appreciates the opportunity to provide our environmental consulting services to you on this project. If you have any questions concerning this report or this project, please contact us. Sincerely, ECS SOUTHEAST, LLP John M. Stewart, P.G. Principal Geologist Jstewart1@ecslimited.com John S. Lair Principal Geologist jlair@ecslimited.com cc: Ms. Carolyn Minnich – NCDENR Brownfields Project Manager Dave Franchina Attachments Figures Table 1 Exhibit B and C Soil Management Plan Former Goodyear Service Center 100 and 122 East Stonewall Street & 615 South Tryon Street Charlotte, Mecklenburg County, North Carolina ECS Project No. 49-5350 November 29, 2017 2 1.0 INTRODUCTION Paragraph 14 in the Notice of Brownfields Property Exhibit A (the Brownfields Agreement for the site) requires Crescent South Tryon, LLC to remove soils exceeding unrestricted use standards from the area shown on the Brownfields Plat as “Area of Known Soil Contamination”: As reflected on the plat, soils in this area contain modest concentrations of constituents that exceed unrestricted use standards. The Brownfields Agreement further requires that Crescent South Tryon prepare a Soil Management Plan for approval by Brownfields that details how these soils will be removed, including a schedule for their removal, how the removal will be implemented, collection of confirmation samples, and how confirmation sampling will be conducted. 1.1 Site Background The Brownfields Site is currently comprised of three parcels identified as Mecklenburg Parcel ID Nos. 12512105, 12512103, 12512102 and Parcel 12512101, which is currently being added to the Site through application to the NC Brownfields Program. Parcels 12512103 and 12512102 are currently owned by Crescent Communities LLC. Parcel 12512105 is owned by CLT Development LLC, and Parcel 12512101 is owned by Asana Partners Fund I TRS LLC. The four parcels together total approximately 3.5 acres. The Area of Known Soil Contamination is located on Parcel 12512103 and faces East Stonewall Street on the southeast corner with South Tryon Street in Charlotte, Mecklenburg County, North Carolina (Figures 1 and 2 and Exhibit B). The site was occupied by a Goodyear Auto Center. The former Goodyear building has since been demolished and only the slab remains. 2.0 PREVIOUS ENVIRONMENTAL ACTIVITIES On October 22, 2013, soil samples were collected from four soil boring drilled inside the interior of the building using a Geoprobe® drill rig. Borings ranged in depth from 8 feet to 12 feet below ground surface (bgs). Soil samples collected during the drilling process were screened in the field for relative levels of volatile organic vapors using a flame ionization detector (FID) or Rae Systems MinRae 2000 Photo ionization detector (PID) and soil samples were collected at locations where FID or PID readings above ambient background concentrations were identified or from the deepest point of the boring above rock. FID or PID readings above background were identified in borings GP-9 through GP-12. Petroleum odors were also observed in borings GP-9 through GP-12 Laboratory analysis of the soil samples detected arsenic above the Inactive Hazardous Sites Branch’s Industrial Health-Based Preliminary Soil Remediation Goals (PSRGs) in two borings located in the area of known soil contamination as shown on the Brownfields plat (attached) and in Exhibit C of the Brownfields Agreement (attached). A number of petroleum related hydrocarbons were detected in the samples but at concentrations below the unrestricted use PSRGs where available. A number of compounds do not currently have PSRGs. It is ECS opinion the arsenic is naturally occurring. Soil Management Plan Former Goodyear Service Center 100 and 122 East Stonewall Street & 615 South Tryon Street Charlotte, Mecklenburg County, North Carolina ECS Project No. 49-5350 November 29, 2017 3 3.0 OBJECTIVE OF THE SOIL MANAGEMENT PLAN The objective of the soil management plan is to describe the procedures to be followed during the disturbance (excavation and placement of fill) of impacted soil in the Area of Known Soil Contamination. The reason for the soil disturbance is to install utilities and prepare the site for construction activities for planned redevelopment of the site. At the completion of redevelopment activities, the site will include office, a hotel, ground floor retail, a courtyard, multi-level parking deck, and potentially multi-family residential. 4.0 SCOPE OF WORK 1. Monitor soil as it is being excavated for organic odors and vapors. 2. Soils excavated will either be temporality stockpiled onsite and then removed or direct loaded and taken to Republic Landfill. 3. If the soil is placed in a stockpile, the soil will be placed on and covered with 10 millimeter (mil) thick plastic sheeting, and secured with sandbags or other weights. A berm consisting of hay bales will be placed around the stockpile to prevent rain water exposure. 4. Submit Project Completion Report within 30 days of completing field activities. 5.0 SOIL MANAGEMENT PROCEDURE 5.1 Site Preparation The areas to be excavated in the Area of Known Soil Contamination are covered by asphalt or concrete. Prior to excavation, the asphalt or concrete will be removed taken offsite for disposal. Excavation areas will be monitored for visible dust and petroleum vapors, and will be sprayed with water if dust is visible or if petroleum vapors are noticeable during excavation, or handling of contaminated materials. 5.2 Soil Excavation The excavation will be approximately 18 feet deep (or excavator refusal) by 60 feet long by 35 feet wide or approximately 1,000 yards of soil. The approximate area to be excavated is shown on Figure 2 and Exhibit B. The excavation will extend horizontally to the extent of the Area of Known Soil Contamination. Excavation operations to be performed in the area will likely be performed using a trac hoe. 5.2.1 Soils Suitable for Use as Structural Fill Soils to be excavated will not be reused onsite. 5.3 Waste Characterization Following removal of the soil, confirmation soil samples will be collected from the excavation sidewalls using the trac hoe bucket. ECS personnel will collect the sample from the center of the bucket making sure the soil has not touched the sides of the bucket. The sampler wearing a new pair of disposables gloves for each sidewall sample will collect the sample and place it into Soil Management Plan Former Goodyear Service Center 100 and 122 East Stonewall Street & 615 South Tryon Street Charlotte, Mecklenburg County, North Carolina ECS Project No. 49-5350 November 29, 2017 4 laboratory supplied bottles. Each sample will be analyzed for volatile and semi-volatile organic compounds using EPA Methods 8260 and 8270, respectively and total RCRA metals by EPA Method 6020. 6.0 SOIL TRANSPORTATION PLAN The contractor will provide transportation for the excavated soil. The soil will be transported to the Republic Services Landfill in Concord, North Carolina. Each dump truck to be used has a capacity of approximately 10 to 12 cubic yards and is equipped with covers. The total quantity of excavated soil is approximately 1,000 cubic yards or 1,500 tons. Truck drivers will carry a signed non-hazardous waste manifest while en route to the disposal facility. 7.0 PERMIT AND NOTICES An excavation or grading permit from the City of Charlotte or Mecklenburg County may be required and will be obtained prior to beginning the grading operations. In keeping with municipal permitting guidelines, notices and construction permits will be posted at visible areas of the site. 8.0 IMPLEMENTATION REPORT At the completion of field activities, a Soil Management Summary report will be submitted to the North Carolina Brownfields Group within 30 days. 9.0 SCHEDULE The implementation of the approved Soil Management Plan will begin within a week after receiving approval from the Brownfields Group, and all other authorization necessary to legally proceed with field activities. An anticipated schedule is listed below. The final schedule will be dependent on permit acquisition and weather. ECS will notify the Brownfields Group seven days prior to excavation activities. • Anticipated required permits to begin soil excavation will be obtained by the grading contractor (under way). • While processing the necessary permits for soil excavation, site preparatory activities, such as mobilization of equipment will commence. The activities will require two to three days for completion. • Removal of asphalt or concrete cement pavement, and off-site disposal by a competent contractor will require one to two working days for completion. • Soil excavation and backfill will require three to five working days for completion. Soil to backfill the excavation will come from the soil which cannot be returned to the utility trench to be excavated across the parking lot of the Goodyear property (approved by Carolyn Minnich, Brownfields Project Manager) and clean fill from either the Martin Soil Management Plan Former Goodyear Service Center 100 and 122 East Stonewall Street & 615 South Tryon Street Charlotte, Mecklenburg County, North Carolina ECS Project No. 49-5350 November 29, 2017 5 Marietta Quarry located at 4551 Beatties Ford Road or Vulcan Materials Quarry located at 10256 Old Nations Ford Rd in Charlotte, North Carolina. The soil form the utility trench will be placed in the excavation and then capped with a minimum of two feet of clean fill. The area will ultimately be capped with concrete or a similar impervious surface associated with an outdoor plaza. FIGURE 1 SITE LOCATION MAP GOODYEAR AUTO BUILDING EAST STONEWALL STREET CHARLOTTE, MECKLENBURG COUNTY, NORTH CAROLINA ECS PROJECT NO. 08-9333 SOURCE: USGS TOPOGRAPHIC MAP: CHARLOTTE EAST, DATED 1967 PHOTOREVISED 1988 NORTH CAROLINA QUADRANGLE SCALE: 1” = 2,000’ SITE SOURCE: Mecklenburg County Polaris GIS (via the Internet) Scale as Shown FIGURE 2 SAMPLE LOCATION PLAN Goodyear Auto Building East Stonewall Street, Charlotte, Mecklenburg County, North Carolina ECS Project No. 08-9333 Legend Soil Sample (No Lab Detections) / Groundwater Sample Soil Sample (No Lab Detections) Soil Sample with Metal contamination only Soil Sample with VOC and/or BN contamination and/or metals Office Existing Monitoring Well TW-1 TW-2 GP-1 GP-2 GP-3 GP-4 GP-1 GP-3 GP-2 GP-4 GP-8 GP-5 GP-6 GP-7 GP-12 GP-11 GP-10 GP-9 GP-13 GP-14 SUMMARY OF SOIL ANALYTICAL RESULTS Tryon Place East Stonewall Street, Charlotte, North Carolina Parameter Sample ID GP-9 GP-10 GP-11 GP-12 Collection Depth (feet bgs)8 8 12 12 Collection Date Total Metals Arsenic 2.0 3.3 2.2 3.2 0.68 3.0 Barium 49 88 42 57 3,000 44,000 Cadmium <0.29 <0.29 <0.29 <0.29 14.2 196 Chromium 40 73 280 84 24,000 100,000 Chromium VI <0.287 <0.293 <0.28 <0.283 0.3 6.3 Lead 6.5 18 3.1 33 400 800 Mercury <0.023 0.030 0.068 0.54 2.2 3.13 Semivolatile Organic Compounds 1-Methylnaphthalene 0.12 J 3.4 1.0 <0.38 NS NS 2-Methylnaphthalene <0.38 6.1 1.6 0.21 J NS NS Anthracene <0.38 0.20 J BRL BRL 3,600 46,000 Benzo(g,h,i)perylene <0.38 <0.38 0.23 J <0.38 NS NS Bis(2-Ethylhexyl)phthalate <0.38 <0.38 0.44 <0.38 39 160 Fluoranthene <0.38 0.22 J <0.38 <0.38 480 6,000 Fluorene <0.38 0.21 J 0.098 J <0.38 480 6,000 Naphthalene <0.38 3.9 0.77 0.17 J 3.8 17 Phenanthrene <0.38 0.73 0.26 J 0.15 J NS NS Pyrene <0.38 1.5 0.49 <0.38 360 4,600 Comparison Criteria Unrestricted Use Health Base- Based PSRG Industrial Health-Based PSRG Goodyear Interior ANALYTICAL RESULTS 10/22/13 SUMMARY OF SOIL ANALYTICAL RESULTS Tryon Place East Stonewall Street, Charlotte, North Carolina Parameter Sample ID GP-9 GP-10 GP-11 GP-12 Collection Depth (feet bgs)8 8 12 12 Collection Date Comparison Criteria Unrestricted Use Health Base- Based PSRG Industrial Health-Based PSRG Goodyear Interior ANALYTICAL RESULTS 10/22/13 Volatile Organic Compounds 1,2,4-Trichlorobenzene 0.18 <0.37 0.28 <0.43 11.6 52 1,2,4-Trimethylbenzene 2.5 1.9 5.3 <0.22 11.6 48 1,2-Dichlorobenzene 0.075 J <0.19 0.13 J <0.22 360 376 1,3,5-Trimethylbenzene 0.84 0.55 1.8 <0.22 156 182 4-Isopropyltoluene 0.35 <0.19 0.38 <0.22 NS NS Ethylbenzene <0.18 0.22 0.25 0.20 5.8 25 Isopropylbenzene (Cumene)<0.18 <0.19 0.10 J <0.22 268 268 m,p-Xylenes 0.093 J 0.64 0.77 0.11 110 388 Naphthalene 0.84 1.0 3.0 <0.22 3.8 17 n-Butylbenzene 0.58 0.19 0.56 0.15 NS NS n-Propylbenzene 0.21 0.21 0.44 0.21 264 264 o-Xylene 0.12 J 0.090 J 0.46 0.20 130 434 sec-Butylbenzene 0.60 0.13 J 0.42 <0.22 NS NS tert-Butylbenzene 0.22 <0.19 0.12 J <0.22 NS NS Notes: Results presented in milligrams per kilogram (mg/kg), analogous to parts per million (ppm) Feet bgs = Feet below ground surface Bold denotes concentration exceeds the unrestricted PSRG J = Estimated concentration, below calibration range and above Method Detection Limit The standard for trivalent chromium used for total chromium, as recent sampling determined that the chromium present was trivalent, not 17038-13-060/Goodyear 2016-07-25 1 Exhibit C The most recent environmental sampling at the Property reported in the Environmental Reports occurred in August 2014.The following tables set forth, for contaminants present at the Property above unrestricted use standards or screening levels, the concentration found at each sample location, and the applicable standard or screening level. Screening levels and groundwater standards are shown for reference only and are not set forth as cleanup levels for purposes of this Agreement. GROUNDWATER Groundwater contaminants in micrograms per liter (the equivalent of parts per billion), the standards or screening levels for which are contained in Title 15A of the North Carolina Administrative Code, Subchapter 2L (2L), Rule .0202, (April 1 2013 version); or the 2L Groundwater Interim Maximum Allowable Concentrations (“IMACs”, October 1, 2010 version): Groundwater Contaminant Sample Location Date of Sampling Concentration Exceeding Screening Level (µg/L) 2L Standard (µg/L) Tetrachloroethylene TW-2 11/2/2013 3.4 0.7 Notes: 1. Screening limits displayed for non-carcinogens are for a hazard quotient equal to 0.2. Screening levels displayed for carcinogens are for a 1.0E-5 lifetime incremental cancer risk (LICR). SOIL Soil contaminants in milligrams per kilogram (the equivalent of parts per million), the screening levels for which are derived from the Preliminary Industrial Health- Based Soil Remediation Goals of the Inactive Hazardous Sites Branch of DEQ’s Superfund Section (April 2016 version): Soil Contaminant Sample Location Depth (ft) Date of Sampling Concentration Exceeding Screening Level (mg/kg) Industrial Screening Level1 (mg/kg) Arsenic SB2 4-8 04/29/2006 4.3 3 Arsenic SB3 8-12 04/29/2006 7.1 3 Arsenic GP-1* 8-10 10/26/2013 6.7 3 Arsenic GP-2* 17-18 10/26/2013 5.5 3 Arsenic GP-3* 13-14 10/26/2013 7.3 3 Arsenic GP-4* 12-13 10/26/2013 4.5 3 Arsenic GP-1 12 10/22/2013 4.4 3 Arsenic GP-5 8 10/22/2013 4.0 3 Arsenic GP-6 8 10/22/2013 11 3 17038-13-060/Goodyear 2016-07-25 2 Soil Contaminant Sample Location Depth (ft) Date of Sampling Concentration Exceeding Screening Level (mg/kg) Industrial Screening Level1 (mg/kg) Arsenic GP-7 16 10/22/2013 5.7 3 Arsenic GP-8 12 10/22/2013 3.7 3 Arsenic GP-10 8 10/22/2013 3.3 3 Arsenic GP-12 12 10/22/2013 3.2 3 Arsenic GP-13 8 10/22/2013 7.6 3 Arsenic GP-14 8 10/22/2013 4.3 3 Arsenic SB-01 2-4 03/13/2014 6.1 3 Arsenic SB-02 2-4 03/13/2014 5.75 3 Arsenic SB-03 2-4 03/13/2014 11.7 3 Arsenic SB-04 10-12 03/13/2014 6.04 3 Arsenic SB-05 10-12 03/13/2014 4.4 3 Arsenic SB-06 2-4 03/14/2014 3.75 3 Arsenic SB-07 2-4 03/13/2014 6.18 3 Arsenic SB-08 2-4 03/13/2014 7.39 3 Arsenic SB-09 2-4 03/13/2014 6.53 3 Arsenic SB-10 10-12 03/13/2014 4.28 3 Chromium VI GP-2 8 10/22/2013 6.87 6.3 Benzo(a)anthracene GP-6 8 10/22/2013 3.7 2.9 Benzo(a)anthracene GP-13 8 10/22/2013 5.0 2.9 Benzo(a)pyrene GP-6 8 10/22/2013 3.7 0.29 Benzo(a)pyrene GP-13 8 10/22/2013 5.6 0.29 Benzo(b)fluoranthene GP-6 8 10/22/2013 4.2 2.9 Benzo(b)fluoranthene GP-13 8 10/22/2013 6.4 2.9 Dibenzo(a,h)anthracene GP-6 8 10/22/2013 0.98 0.29 Dibenzo(a,h)anthracene GP-13 8 10/22/2013 0.97 0.29 Indeno(1,2,3-cd)pyrene GP-6 8 10/22/2013 3.1 2.9 Indeno(1,2,3-cd)pyrene GP-13 8 10/22/2013 4.8 2.9 1Screening levels displayed for non-carcinogens are for a hazard quotient equal to 0.2. Screening levels displayed for carcinogens are for a 1.0E-6 lifetime incremental cancer risk. *Boring locations on Goodyear Property installed by ECS Carolinas