SOIL MANAGEMENT PLAN AND UST REMOVAL - Hine...

SOIL MANAGEMENT PLAN AND UST REMOVAL PLAN

Former Hine School

Washington, District of Columbia

2/12/2013

DRAFT

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Soil Management Plan and UST Removal Plan

Former Hine School

2/12/2013

Client

Stanton-Eastbanc LLC

Consultant

David Sarr 11190 Sunrise Valley Drive Suite 300 Reston, Virginia 20191 USA Tel: 7037096500 Fax: 7037098505 www.wspenvironmental.com/usa

Registered Address

WSP Environment & Energy

WSP Contacts

David Sarr

Project number: 36877/2 Dated: 2/12/2013 ii Revised:

Table of Contents 1 Introduction ............................................................................... 1

1.1 Purpose ................................................................................. 1

1.2 Summary of Proposed Remediation Activities ....................... 2

2 Background Information ............................................................ 3 2.1 Site Description ..................................................................... 3 2.2 Adjacent Properties ............................................................... 3 2.3 Geology and Hydrogeology ................................................... 3

3 Previous Site Investigations ...................................................... 5

3.1 Phase I Environmental Site Assessment – March 2010 ........ 5

3.2 Phase II Subsurface Investigations – June 2010 and September 2012 ............................................................................. 5

3.2.1 Soil Investigation Results ................................................. 5 3.2.2 Groundwater Investigation Results .................................. 6

4 Current Extent of Contamination ............................................... 7 4.1 Soil ........................................................................................ 7

4.2 Groundwater .......................................................................... 8

5 UST Removal ............................................................................ 9

6 Soil Management Plan ............................................................ 11

6.1 Proposed Remediation – Soil .............................................. 11

6.1.1 Soil Confirmation Samples ............................................ 12

6.2 Proposed Remediation – Groundwater................................ 12 6.2.1 Groundwater Confirmation Samples .............................. 13

7 Engineering Controls in Completed Building ........................... 14

8 Quality Assurance/Quality Control .......................................... 15

9 Health and Safety.................................................................... 16

9.1 Organic Vapor Monitoring .................................................... 16

10 Project Schedule ..................................................................... 17

11 Conclusions ............................................................................ 18

Acronym List .................................................................................... 19

Figures

Figure 1 – Site Location

Figure 2 – Site Plan

Figure 3 – Boring Location and Soil Classification Map

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Tables

Table 1 – Subsurface Soil Sample Analytical Results

Table 2 – Groundwater Sample Analytical Results

Appendix A – District of Columbia DDOE, Standard Permitting Procedures for Removal of UST’s

Appendix B – WSP’s Standard Operating Procedures

Appendix C – Dust and Odor Control Plan

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1 Introduction

1.1 Purpose

On behalf of Stanton-Eastbanc LLC, WSP Environment & Energy, now part of WSP USA Corp. (WSP) has prepared this Soil Management Plan and Underground Storage Tank Removal Plan (Work Plan) to be implemented during construction and excavation at the former Hine Junior High School located at 335 8

th Street SE

in Washington, District of Columbia. Stanton-Eastbanc-LLC is planning to construct a Planned Unit Development (PUD) consisting of mixed-use residential, office and retail space on the subject property. The new building will include an underground parking garage. The existing buildings will be razed during the re-development. Previous investigations have identified an underground storage tank (UST) and petroleum-contaminated soil on the property. The UST will be removed and affected soil will be excavated and removed from the subject property during construction. This Work Plan specifies procedures for removing the UST and the contaminated soil.

The subject property is owned by the District of Columbia and is referenced in the District real estate records as Lot 801 in Square 901. The former school consists of three interconnected buildings located in the southern portion of the property covering approximately 70,000 square feet of space. The southernmost building contains the auditorium; the northern building contains the cafeteria, classrooms, locker rooms, and gymnasium; and the western building contains a basement boiler room and utility area, and four stories of classrooms that surround a central courtyard. Asphalt-paved surfaces are located north of the buildings. The subject property also contains a vacant, temporary building that was previously the location of an extension of the Eastern Market, which is located to the west of the property. The property location is shown in Figure 1 and a site plan is provided as Figure 2.

In March 2010, WSP conducted a Phase I Environmental Site Assessment of the subject property. The site visit and a review of historical records showed evidence of a UST located in the central-western portion of the property, north of the classroom building. The tank was located near the boiler room, which was located in the basement of the adjacent classroom building. According to the Environmental Data Resources (EDR) database report reviewed during the Phase I, the UST database identifies the site as the location of a 20,000-gallon heating oil tank, registered to the District of Columbia Office of Public Education. It was unknown whether any oil currently remains in the tank. No information was available on the installation date of the tank, or construction details on the tank and piping system. The ground surface above the tank is an asphalt-paved parking area.

In June 2010, WSP conducted a Phase II investigation to evaluate the soil and groundwater around the UST. Sampling conducted within approximately 20 feet of the UST identified petroleum-related compounds in the soil and groundwater below the base of the tank. The subsurface investigations identified soil containing benzene, ethylbenzene, xylene, naphthalene, total petroleum hydrocarbons (TPH) – diesel range organics (TPH-DRO), and TPH – gasoline range organics (GRO) concentrations greater than District of Columbia risk-based screening levels.

In September 2012, Schnabel Engineering Consults, Inc. (Schnabel) conducted a Phase II investigation of the subject property. Sixteen soil borings were installed along the perimeter of and the center of the subject property. Borings were installed at least 50 feet from the UST location. One soil sample collected north of the UST contained TPH-DRO concentrations greater than disposal criteria at a below ground surface (bgs) depth of 7 feet to 9 feet. The Phase II investigation did not delineate whether the detected contamination migrated from the UST area.

The subject property is currently unoccupied. The quantity of heating oil present in the UST and location of the heating oil supply and UST vent lines are unknown.

Project number: 36877/2 Dated: 2/12/2013 2 Revised:

1.2 Summary of Proposed Remediation Activities

Subsurface investigations have identified soil containing benzene, ethylbenzene, xylene, naphthalene, TPH -DRO, and TPH-GRO concentrations greater than District of Columbia risk-based screening levels within the proposed limits of the underground garage excavation. The UST and contaminated soil located within the limits of excavation will be removed during the planned building construction. Confirmation samples will be collected from the base of the excavation to confirm that risk based screening levels have been met.

If soil samples collected from the base of the building/garage excavation do not meet District of Columbia residential risk based screening levels (as defined in the June 2011 DDOE Risk Based Corrective Action (RBCA) guidance ), then additional contaminated soil below the building subgrade elevation may be removed. However, depending on the nature and extent of contaminated soil present, a Tier II evaluation may be conducted in accordance with DC RBCA guidance. If additional soil is removed, clean backfill will be placed in the excavation as necessary to proceed with building construction.

The soil excavated during building construction will be tested and disposed of in accordance with applicable federal, District of Columbia, and other applicable state and local regulations. Groundwater removed during construction will be discharged to a combined sewer under a temporary discharge authorization from the District of Columbia Water and Sewer Authority (DC Water), or to a separate storm sewer under authorization from the District Department of the Environment (DDOE). The water will be treated as necessary to meet discharge standards. The remediation-related excavation will only go beyond the scope of construction as far as necessary to obtain a no further action decision from DDOE.

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2 Background Information

2.1 Site Description

The former Hine Junior High School property is located at 335 8th Street SE in Washington, D.C. (Figure 1). The subject property is a 3.16-acre parcel located on the north side of Pennsylvania Avenue, between 7th and 8th Streets, in the Capitol Hill neighborhood of Washington, D.C. The property contains three interconnected buildings that were the location of the Hine Junior High School, a District of Columbia public school that closed in late 2008. No operations are currently being performed at the property, and the school is vacant. The subject property also contains a vacant, temporary building that was previously the location of an extension of the Eastern Market, which is located to the west of the property.

The subject property is owned by the District of Columbia and is referenced in the District real estate records as Lot 801 in Square 901. The school consists of three interconnected buildings located in the southern portion of the property covering approximately 70,000 square feet of space (Figure 2). The southernmost building contains the auditorium; the northern building contains the cafeteria, classrooms, locker rooms, and gymnasium; and the western building contains a basement boiler room and utility area, and four stories of classrooms that surround a central courtyard. Asphalt-paved surfaces are located north of the buildings. The subject property also contains a vacant, temporary building that was previously the location of an extension of the Eastern market located to the west of the property. No additional structures are present on the property.

According to a Phase I report (WSP, 2010) the subject property was originally developed as a public school in the mid-1800s. The current buildings onsite were constructed in 1965, and was operated as the Hine Junior High School until late 2008. The building has been vacant since early 2009.

2.2 Adjacent Properties

The subject property is located in the Capital Hill district in southeast Washington, D.C. and is bordered to the west by 7th Street and a mix of commercial, retail and residential properties, including the Eastern Market to the northwest of the property. The subject property is bordered to the north by commercial buildings; to the east by 8th Street and residential buildings; and to the south by Pennsylvania Avenue and a mix of commercial, retail, and residential buildings. Residences are located adjacent to the property across 8th Street to the east and 7th Street to the west.

The Phase I report identified 11 leaking underground storage tank (LUST) sites located within 0.5-mile of the subject property, based on the Phase I EDR environmental data base review. Of the 11 LUST sites, three are located in the area up gradient of the subject property. The status of all three sites is listed as closed.

Nine sites in the vicinity are identified with registered USTs, and only one is located in the area considered up gradient. The site at 232 11th Street (name unknown) has a registered UST that is permanently out of use and is not identified as a LUST site.

The EDR database for historical Dry Cleaners identified two historic dry cleaners in the vicinity of the property. Neither of these sites were identified as having a release.

2.3 Geology and Hydrogeology

According to the U.S. Geological Survey‘s Washington, D.C. East, quadrangle (7.5-minute series) map, the ground elevation of the subject property is approximately 80 feet above mean sea level. The site is located in an urban area, and the property slopes slightly to the south.


No information was available from the U. S. Department of Agriculture Soil Conservation Service regarding the classification of the soils at the subject property. The bedrock strata underlying the property consist of rocks from the Mesozoic, Lower Cretaceous Rock Series. Based on the soils observed during the installation of direct push borings on the subject property, the underlying soil is composed primarily of surficial fill materials, underlain by silty, gravelly, and clayey sand, interbedded clay.

No water bodies are present on the subject property. The nearest water body, the Anacostia River, is approximately one mile southeast of the site. Based on the topography and the location of the Anacostia River, groundwater flow is presumed to be to the southeast.

Depth to groundwater beneath the subject property ranges from 15 feet below ground surface (bgs) to 27 feet bgs, based on encountered groundwater in the direct push borings installed during the Schnabel Phase II investigation on the subject property in September 2012. Groundwater level measurements collected by Schnabel from the soil borings up to approximately 3 days after completion of drilling groundwater indicated depths of approximately 25 feet and 26 feet bgs.

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3 Previous Site Investigations This section describes previous environmental assessments and investigations of the property. Analytical data for soil samples collected during the investigations are summarized in Table 1 and analytical data for groundwater samples collected during the investigations are summarized in Table 2.

3.1 Phase I Environmental Site Assessment – March 2010

In March 2010, WSP conducted a Phase I Environmental Site Assessment of the subject property. The site visit and a review of historical records showed evidence of a UST located in the central-western portion of the property to the north of the classroom building housing the boiler room. The ground surface above the tank is an asphalt-paved parking area. According to the EDR database report reviewed during the Phase I, the UST database identifies the site as the location of a 20,000-gallon heating oil tank, registered to the DC Office of Public Education. WSP recommended additional investigation, including soil and groundwater sampling, to determine whether releases from the UST may have impacted soil or groundwater at the subject property.

3.2 Phase II Subsurface Investigations – June 2010 and September 2012

In June 2010, WSP conducted a subsurface investigation consisting of eight direct push borings installed adjacent to the UST. Soil samples were collected from all eight borings, and groundwater samples were collected from two borings. In September 2012, Schnabel installed 16 direct push borings throughout the property to (1) delineate the vertical and horizontal extent of affected soil located near the UST, (2) investigate the possible presence of offsite contamination that may have migrated on to the subject property, and (3) evaluate groundwater quality conditions that could affect the building design or indicate a need for groundwater treatment during construction dewatering or permanent dewatering. In September 2012, soil samples were collected from ten borings, and groundwater samples were collected from five borings.

3.2.1 Soil Investigation Results

Based on the tank capacity, the bottom of the tank was anticipated to be approximately 15 feet bgs and soil borings were extended to a depth of at least 18 feet bgs, at least three feet below the expected bottom of the tank. WSP advanced 8 direct push borings (SB-1 through SB-8) and at each boring location, continuous soil samples were collected from the ground surface to 20 feet bgs in borings SB-1, SB-3, SB-5, SB-6, SB-7, and SB-8. Soil borings SB-2 and SB-4 were extended to 30 feet bgs and 35 feet bgs. The samples were analyzed for petroleum-related Chemicals of Concern (COCs) - benzene, toluene, ethylbenzene, xylenes (BTEX), methyl-tertiary-butyl-ether (MTBE), and naphthalene. Samples were also analyzed for TPH-GRO and DRO. The TPH-DRO sample concentrations exceed the DC Tier 1 risk-based screening levels (RBSLs) in borings, SB-1, SB-2, SB-6, SB-7 and SB-8. TPH-DRO was detected under the RBSL in boring SB-5 at 545 milligrams/kilograms (mg/kg). Benzene sample concentrations exceed the DC Tier 1 RBSLs in borings SB-1, SB-2, SB-7, and SB-8 and TPH-GRO sample concentration exceed the DC Tier 1 RBSLs in boring SB-1. The unsaturated soil samples were collected from the interval below the bottom of the tank at each soil boring location. Sample depth ranged from 16 feet to 20 feet below ground surface and all samples were collected from a 2 feet interval. Elevated PID readings and olfactory evidence of petroleum contamination was first encountered at approximately 12 feet bgs, indicating that the UST or connecting piping was the most likely source of contamination.

In September 2012, Schnabel installed 16 direct push soil borings along the perimeter and distributed in the center of the subject property. Soil samples from boring locations GP-1, GP-2, GP-3, GP-6, GP-8, GP-9, GP-10, GP-12, GP-13, and GP-15 were analyzed for BTEX, MTBE, TPH-GRO, and TPH-DRO. At the listed boring locations, analytes were not detected above the laboratory reporting limit with the exception of TPH-DRO at boring location GP-2. Boring location GP-2 is located approximately 50 feet north of the UST. The GP-2 soil sample collected


from 7 feet to 9 feet bgs contained TPH-DRO concentrations greater than the disposal criteria for contaminated soil, but less than the DC risk-based screening level. Because the TPH-DRO detected in the sample from GP-2 was present at a higher elevation than the petroleum contamination detected near the UST, it appears that the TPH-DRO at GP-2 originates from a separate source.

The September 2012 Phase II investigation did not detect evidence of the contamination in the UST area migrating into borings installed near the UST (i.e. GP-1, GP-2, GP-3, GP-4 or GP-16).

3.2.2 Groundwater Investigation Results

During the WSP Phase II investigation groundwater samples were collected from borings SB-2 and SB-4. Soil borings SB-2 and SB-4 were extended to 30 feet bgs and 35 feet bgs, respectively, to collect groundwater samples. Groundwater samples were analyzed for petroleum related COCs. Benzene was detected in the groundwater sample from SB-2 at a concentration of was 4 micrograms per liter (µg/L), which is less than the DC Tier 1 RBSLs for benzene of 5 µg/L. All laboratory detected concentrations were below the DC Tier 1 RBSLs.

Groundwater samples were collected from borings GP-4, GP-9, GP-11, GP-14, and GP-16 during the Schnabel Phase II investigation. These borings were located near the center (GP-4) and the four corners of the property. Groundwater samples were analyzed for petroleum related volatile organic compounds (VOCs) by Method 8260, and TPH-GRO and TPH-DRO by Method 8015. In addition, the groundwater sample collected from boring GP-16 was analyzed for Resource Conservation and Recovery Act (RCRA) metals, (VOCs), semi-volatile organic compounds (SVOCs), and polychlorinated biphenyl (PCBs), and a full list of VOCs. Petroleum-related VOCs, TPH-DRO, TPH-GRO, SVOCs and PCBs were not detected in the groundwater samples collected from the site. Chloroform was the only VOC detected in the groundwater sample from GP-16. The detected concentrations for RCRA metals and chloroform were below the DC Tier 1 RBSLs.

Groundwater level measurements collected by Schnabel from the soil borings up to approximately 3 days after completion of drilling groundwater indicated depths of approximately 25 feet and 26 feet bgs.

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4 Current Extent of Contamination

4.1 Soil

Soil sample data collected during the two soil investigations on the subject property is compiled in Table 1. Seven soil samples collected on the subject property contained TPH-DRO concentrations greater than the District reporting limit of 100 mg/kg and the disposal criteria of 10 mg/kg TPH-DRO. Five soil samples contained benzene, ethylbenzene, xylene, naphthalene, TPH-DRO or TPH-GRO concentrations greater than the Tier I risk-based screening levels (RBSLs) for residential land use (DDOE, 2011). The screening levels are also listed in Table 1.

The maximum TPH-DRO concentration detected was 29,900 mg/kg. The investigations determined that the majority of the petroleum impacts are present in soil near the UST. The impacted soil near the UST begins at a depth of approximately 12 feet bgs. Soil samples were not collected further to the south of the UST because the existing building is present. Petroleum contaminated soil may extend underneath the building.

The soil sample collected at boring GP-2 indicates TPH-DRO contamination begins at 7 feet bgs and extends up to 12 feet bgs. Based on the recorded PID readings, TPH-DRO contamination is likely to decrease with depth.

For the purposes of offsite characterization and disposal, soil excavated from the subject property will be classified into one of five categories:

■ Class 1: This soil contains less than 10 mg/kg TPH and less than 10 mg/kg total benzene, toluene, ethylbenzene and xylene, and therefore meets the definition of clean fill in Maryland and Virginia. Testing has also demonstrated that the soil meets the Environmental Protection Agency (EPA) Region 3 risk–based concentrations (RBCs) for residential land use, with the exception of arsenic. This soil may contain arsenic concentrations greater than industrial RBCs, but the arsenic is naturally occurring and is present at concentrations representative of background conditions. This soil may be used as fill in Maryland or Virginia, subject to compliance with local and state regulations.

■ Class 2: This soil also meets the definition of clean fill in Maryland or Virginia. However, the soil contains one or more constituents at concentrations greater than residential RBCs, but less than commercial or industrial criteria RBCs. This soil may contain arsenic concentrations greater than commercial or industrial RBCs, but the arsenic is naturally occurring and is present at concentrations representative of background conditions. This soil may be used as fill on commercial or industrial properties in Maryland or Virginia, subject to compliance with local and state regulations.

■ Class 3: Petroleum-contaminated soil that must be disposed of in a regulated disposal facility, such as a landfill or soil treatment facility. Testing or field screening has demonstrated that the soil contains TPH concentrations greater than 10 mg/kg. Soil that contains polynuclear aromatic hydrocarbon (PAH) concentrations greater than industrial RBCs will also be considered Class 3 soil because facilities permitted to accept petroleum-contaminated soil can also accept soils containing PAH concentrations greater than industrial RBCs.

■ Class 4: Solid waste or contaminated soil that contains some constituent at concentrations greater than industrial or commercial RBCs. Soil must be disposed of in a regulated solid waste disposal facility, such as a landfill. Soil that contains PAH concentrations greater than industrial or commercial RBCs will be considered Class 3 soil, as described above.

■ Class 5: Uncontaminated concrete and debris that is suitable for disposal in a construction and demolition debris landfill.

Based on the sampling and analysis conducted on the subject property to date, two types of material are known to be present on the property: Class 1 (clean soil), and Class 3 (petroleum-contaminated soil). The existing data was used to generate the soil classification diagrams discussed in Section 5.1. All excavated petroleum contaminated soil will be removed and disposed of in accordance with applicable federal, District of Columbia, and other


applicable state and local regulations. Contaminated soils stored on-site must be placed upon and covered by plastic.

4.2 Groundwater

Groundwater sample data collected during the investigations is compiled in Table 2. Based on the available groundwater sample data, groundwater contamination has not been identified on the subject property.

Groundwater level measurements collected by Schnabel from the soil borings up to approximately 3 days after completion of drilling groundwater indicated depths of approximately 25 feet and 26 feet bgs. Perched groundwater was observed during Schnabel Phase II investigation in the unsaturated zone at depths of 14 feet to 17 feet.

Groundwater withdrawn by construction dewatering shall be managed as described in Section 6.2.

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5 UST Removal In March 2010, WSP conducted a Phase I Environmental Site Assessment of the subject property. The site visit and a review of historical records showed evidence of an UST located in the central-western portion of the property to the north of the classroom building housing the boiler room. According to the EDR database report reviewed during the Phase I, the UST database identifies the site as the location of a 20,000-gallon heating oil tank, registered to the DC Office of Public Education. The estimated UST location is provided on Figure 2.

The UST and associated piping will be removed and remediated during the building excavation. All UST removal activities shall be performed in accordance with federal, District of Columbia, and other applicable state and local regulations, including the District of Columbia DDOE Standard Permitting Procedures for Removal of Underground Storage Tanks in Appendix A. The Contractor removing the UST and associated piping shall conduct all activities in accordance District of Columbia DDOE procedures and requirements. The contractor is responsible for preparing their own detailed work plan, health and safety plan, and conducting all necessary air monitoring during the UST removal process. The UST removal contractor’s notification and permit responsibilities include, but are not limited to, the following:

■ Provide the owner and WSP with necessary documentation to notify the DDOE UST program office two weeks in advance of performing any removal activities.

■ Complete a standard construction permit form and Building Permit Application Supplemental form from the DCRA Permit Processing Division. The permit forms and site diagram must be approved by DDOE before obtain a construction permit.

■ Before beginning UST removal excavation actives, provide 48 hours advance notice to the D.C. Fire Marshal’s (DCFM) Technical Inspections Plans and Permits Branch, Hazardous Materials Section, and the DDOE UST Branch, to arrange for representatives of the DCFM and DDOE to be on-site. Contact information is provided on the Standard Permitting Procedures for Removal of Underground Storage Tanks document included in Appendix A.

■ Obtain certification from the DDOE UST Branch prior to performing any UST activities.

The content of the UST is assumed to be heating-oil which was used to supply the school’s boilers. The quantity of heating oil remaining in the UST is known. The contractor is responsible for access and disposing of the UST contents. The contractor will be required to identify the disposal facilities for the UST contents, any generated drummed waste, and the metal recycler accepting the UST prior to extracting the contents of the UST. The interior of the UST must be cleaned by the UST removal contractor prior to removal in accordance with Occupational Safety Health Administration (OSHA) permit-required confined space entry protocols. During excavation the UST removal contractor responsibilities include, but are not limited to, the following:

■ Comply with Section II, On-Site Closure Practices of the DDOE Standard Permitting Procedures for Removal of Underground Storage Tanks. The contractor will not be responsible for collection of soil samples. However, contractor may need to dig appropriate test pits for the onsite technician to collect confirmation samples.

■ Contaminated soils stored on-site must be placed upon and covered by plastic and designed to stop any leachate from migrating from the soil pile.

■ Dispose of the tank in accordance with the applicable solid waste regulations.

■ Contaminated soils taken from the excavation zone must be transferred offsite to a DDOE approved treatment/disposal facility within 30 days.

In addition to the UST removal, the UST removal contractor is responsible for removal, cleaning, and disposal of heating-oil supply and vent line that are assumed to be connected to the UST.

Upon completion of the UST removal activities, a UST Closure Assessment report will be prepared and submitted to the DDOE UST Branch. The report will include the results of soil confirmation samples collected as described in Section 6.1.1.


Groundwater is not expected to be encountered during the UST removal. If groundwater is encountered the UST removal contractor shall be responsible for managing onsite treatment, or off-site disposal as necessary.

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6 Soil Management Plan The finished floor elevation of the building is 53 feet above mean sea level (amsl). At the start of building construction, the subject property will be excavated to the building subgrade elevation of approximately 52 feet amsl, 1 foot below the finished floor elevation. In addition, the 20,000 gallon UST will be removed. This will remove some petroleum-contaminated soil, but possible not remove all soil containing TPH concentrations greater than Tier I criteria for residential land use (i.e., 960 mg/kg TPH-DRO and 814 mg/kg TPH-GRO).

The final limits of excavation will not be based solely on previous soil sampling results, but will be confirmed by field testing and soil confirmation samples collected at the subgrade elevation. After the excavation reaches the subgrade elevation, additional soil samples will be collected and analyzed for TPH-DRO, TPH-GRO, and BTEX as described in Section 5.1.1. Any additional soil that contains TPH concentrations above Tier I risk based screening levels for residential properties will be excavated and hauled offsite for disposal. Therefore, up to 2 feet of soil may be removed below the subgrade elevation beneath the UST. If soil remaining below 50 feet amsl contains TPH concentrations above Tier I risk based screening levels, additional soil will be excavated below 50 feet amsl, or a vapor barrier will be installed below the concrete slab.

Groundwater generated by construction dewatering will be discharged to the DC Water combined sewer or the separate storm sewer in accordance with a permit obtained as described in Section 6.2. Groundwater discharge will be sampled and tested as required by the discharge permit. If necessary to meet permit criteria, the water will be treated before being discharged.

Because the subject property contains soil impacted with TPH and benzene, appropriate measures will be taken to ensure the health and safety of workers and the public during excavation activities. These precautions are described in Section 9.0.

6.1 Proposed Remediation – Soil

Before excavation begins, the excavation contractor or general contractor shall identify the disposal facilities and fill sites that will receive soil and construction debris from the excavation on the subject property. The excavation contractor or general contractor shall be responsible for submitting soil analytical data and waste profiles to the proposed disposal facilities and fill sites as necessary to obtain disposal facility approval. The excavation contractor or general contractor shall obtain written confirmation from the disposal facilities that they can accept soil from the subject property, and that they are in compliance with state and local requirements regarding receipt of soil and construction debris.

The location of petroleum-contaminated soil (Class 3 soil) within the planned building excavation is shown on Figure 3. The extent of Class 3 (contaminated) soil shown on Figure 3 is based on meeting the 10 mg/kg TPH criteria for disposal of soil in Maryland. At the UST location, TPH contaminated soil was encountered below elevation 68 feet amsl and is projected to extend to the base of the excavation in this area (approximate elevation 51 feet amsl). At the boring GP-2 location, TPH contaminated soil was encountered at the GP-2 at 73 feet amsl to 68 feet amsl.

Field screening will be conducted at the base of the excavation in the UST area to evaluate whether any additional soil could exceed Tier I residential standards, and whether additional soil will be excavated. The field screening will be conducted by WSP or other Stanton-Eastbanc representative. Soil verification samples will then be collected as described in Section 5.1.1. Field screening will also be conducted at the horizontal limits of the Class 3 soil shown in Figure 3 to evaluate whether any additional soil should be managed as petroleum-contaminated soil. This includes the area that is currently under the existing building.

Soil that is not classified as Class 3 will be managed as Class 1. The soil classification will be confirmed in the field using field screening techniques. Additional laboratory analysis may also be conducted to confirm soil classification.


The excavation contractor shall place excavated materials, including contaminated soil, into trucks and transport the materials to the appropriate disposal facility or fill site. The excavated soil will be managed, transported, and disposed of in accordance with federal, District of Columbia, and other applicable state and local regulations. Class 1 soil may be transported to Maryland or Virginia and used as fill in accordance with federal regulations and the state and local regulations applicable to the disposal facility or fill site. Class 2 soil, if encountered, may be transported to Maryland or Virginia and used as fill on a commercial or industrial property in accordance with federal regulations and the state and local regulations applicable to the disposal facility or fill site. Class 3 soil will be transported to a regulated disposal or treatment facility authorized to accept soil containing more than 10 mg/kg TPH. A nonhazardous waste manifest will be completed for each load of Class 3 soil.

It is possible that some soils will not match the disposal classification designated in Figure 3. Variance materials will be defined as soils that exhibit evidence of contamination not corresponding to their designated disposal classification. For example, if soils in a Class 1 area exhibit a petroleum odor or show evidence of petroleum staining, they will be considered variance materials. Field screening and/or additional sampling will be conducted as necessary to characterize variance materials. An environmental technician will inspect any variance materials and screen the soil with a PID and a flame ionization detector (FID).

If the screening indicates that the soil contains a higher concentration of TPH than was identified in the analytical results, the soil in the area will be reclassified (i.e., Class 1 soil could become Class 3 soil based on PID, FID, or test kit readings greater than 10 ppm).

If field screening and observation of areas of Class 3 soil indicates that TPH contamination is not present, the soil may be temporarily stockpiled on-site for characterization sampling. Soil will be placed in on-site stockpiles of approximately 1,000 cubic yards. One composite sample will be collected from the stockpile and submitted for laboratory analysis for TPH-GRO, TPH-DRO, and BTEX. Laboratory analysis will be completed within 48 hours of sampling. The analytical results for the composite sample will be used to determine the final soil classification of the soil in that stockpile. Stockpiles will be covered after the composite sample is collected, and will remain covered until the soil is removed from the stockpile for final disposition.

If nuisance odors are encountered during the excavation activities, field personnel will screen the breathing zone to determine the level of organic vapors present as described in Section 9. If the level of organic vapors present in the breathing zone exceeds 0.5 ppm, work will stop and colorimetric analysis for benzene will be performed as described in Section 9. If the action levels in Section 9 are exceeded, then additional ventilation, dust suppression, or an upgrade in personal protection will be required.

6.1.1 Soil Confirmation Samples

After excavation reaches the subgrade elevation, soil confirmation samples will be collected to determine if TPH and VOC concentrations in soil at the subgrade elevation meet Tier I risk-based screening levels. Four soil samples will be collect at the base of the UST area and one soil sample at the base of the excavation beneath the Class 3 soil at boring GP-2. The five samples will be collected by either a hand auger or test pits. The samples will be analyzed for TPH-DRO and TPH-GRO by Method 8015, and VOCs by Method 8260. If the concentration of any constituent exceeds Tier I criteria, then additional soil may be excavated for off-site disposal, as described above.

If additional soil is removed below the subgrade elevation, soil confirmation samples will be collected from the base of the new excavation. One confirmation sample will be collected for each previous confirmation soil sample that did not meet Tier I criteria. Each confirmation sample will be analyzed for TPH-DRO, TPH-GRO, and VOCs. If any subgrade soil sample contains a VOC at concentrations above Tier I criteria. The results will be included in the site closure report.

6.2 Proposed Remediation – Groundwater

Investigations conducted at the site have not identified contaminated groundwater, and there are no specific requirements for groundwater remediation at the site. However, any groundwater withdrawn during construction

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must be managed and discharged in accordance with DDOE and DC Water requirements. Subject to DC Water approval, groundwater withdrawn by construction dewatering may be discharged to the combined sewer under a temporary discharge authorization from DC Water. Based on existing information, groundwater on the site is believed to meet DC Water discharge criteria:

■ pH greater than 5 and less than 10

■ benzene concentrations less than 140 μg/l

■ TPH oil and grease concentrations less than 100 mg/l

It may also be possible to discharge groundwater to a storm sewer under a General Permit for Stormwater from Construction Activity (which allows the discharge of uncontaminated groundwater). However, if contaminated groundwater is determined to be present, then a Multi-Sector General Permit for treated groundwater discharge will be required in order to discharge groundwater to the storm sewer.

The excavation contractor or general contractor will be responsible for obtaining a groundwater discharge permit, and conducting monitoring as required by the permit. If the collected groundwater samples do not meet discharge criteria, the excavation contractor or general contractor will be responsible for installing and operating groundwater treatment equipment as necessary to meet discharge criteria. This is expected to consist of treatment using a combination of particle filtration and activated carbon filtration before discharge.

6.2.1 Groundwater Confirmation Samples

Because excavation will remove petroleum-contaminated soil, and construction dewatering will remove any poten-tial petroleum hydrocarbons from groundwater, no long-term groundwater management or treatment is expected to be necessary. Groundwater samples collected to date have not exceeded DC Tier 1 RBSLs. Therefore, no groundwater confirmation samples are scheduled.


7 Engineering Controls in Completed Building This work plan proposes to remove soil that does not meet DDOE risk-based screening levels based on residential land use, including screening levels based on potential vapor intrusion. The VOC and TPH concentrations in soil and groundwater after construction are expected to be less than risk-based screening levels based on vapor intrusion. Therefore, the data indicates that a vapor barrier or other engineering control is not required to protect human health in the completed building. However, a vapor barrier may still be installed in the below grade portion of the building as part of the building waterproofing.

15

8 Quality Assurance/Quality Control All Class 3 soil removed during construction activities shall be transported to a disposal facility permitted to accept petroleum-contaminated soil. The disposal facility shall approve receipt of the Class 3 soil before receiving any soil, and all Class 3 soil will be transported with a non-hazardous waste manifest.

All sampling activities conducted under this Work Plan will be conducted in accordance with the Standard Operating Procedures in Appendix B, or equivalent.

Groundwater samples collected during construction dewatering in order to monitor permit compliance will be analyzed using EPA-approved methods.


9 Health and Safety During UST and contaminated soil removal, air monitoring will be conducted to provide real time warning of excessive exposure to contaminants and also to characterize personnel exposure to contaminants during the work. Air quality monitoring will be conducted by trained personnel, and air quality monitoring data will be provided to other companies working on the site upon request. Contractors and subcontractors will be responsible for conducting air quality monitoring for their employees. A comprehensive Dust and Odor Control Plan is provided in Appendix C.

9.1 Organic Vapor Monitoring

Organic vapor monitoring will be conducted during UST and contaminated soil removal on the property. A MiniRae 2000, UltraRae, or equivalent PID will be used. Because benzene has been detected in soil and groundwater, a 10.6 electron-volt lamp will be used. The PID will be calibrated in accordance with the manufacturer’s instructions before use.

Trained technical staff under contract to Stanton-Eastbanc LLC will be responsible for performing ambient air quality monitoring with the PID. The PID action level is based on potential exposure to benzene and vinyl chloride, which were detected in soil samples from the subject site. Benzene has an OSHA permissible exposure limit (PEL) of 1 ppm, based on a time-weighted average. The PID action level for benzene will be one half the PEL, or 0.5 ppm.

Before beginning UST removal or contaminated soil excavation, the areas will be screened with a PID to determine background VOC levels in the air at ground level and in the breathing zone. The site health and safety officer or his/her designated representative will then scan the breathing zone with a PID to monitor levels of organic vapors during excavation work. Level D personal protection will be used when the PID measures organic vapor levels below 0.5 ppm. Additional monitoring will be implemented if a sustained PID reading greater than 0.5 ppm is measured in the breathing zone for more than 15 minutes. The work will stop, and compound-specific colorimetric tube monitoring will be performed. A colorimetric tube with benzene detection limits of less than 1 ppm will be used to assess potential airborne benzene exposure. If colorimetric tube measurements are greater than 1 ppm, then additional ventilation, dust suppression, or an upgrade in personal protection will be required.

If colorimetric tube measurements are less than 1 ppm benzene, then no additional measures will be required. However, additional compound-specific monitoring will be implemented if a sustained PID reading greater than 5 ppm above background is measured in the breathing zone. This action level is one half of the 10 ppm OSHA PEL for naphthalene. The work will stop, and compound-specific colorimetric tube monitoring will be performed. A Gastec tube with a naphthalene detection limit less than 10 ppm will be used to assess potential airborne naphthalene exposure. If the naphthalene colorimetric tube measurements are greater than 10 ppm, then additional ventilation, dust suppression, or an upgrade in personal protection will be required. If naphthalene colorimetric tube measurements are less than 10 ppm, no additional measures will be required.

An UltraRae PID equipped with a compound-specific separation tube may be used instead of Gastec tubes.

If nuisance odors are encountered during the excavation activities, field personnel will screen the breathing zone to determine the level of organic vapors present. If the instantaneous level of organic vapors present in the breathing zone exceeds 10 ppm, colorimetric analysis will be performed as described above to determine whether benzene or naphthalene are present. If organic vapors are not present above 10 ppm, a water spray will be applied to the area until nuisance odors are no longer present.

17

10 Project Schedule Contaminated soil excavation and UST removal are expected to take approximately 60 days. Dewatering will be conducted during construction activities as necessary. The project closure report and request for a No Further Action determination will be submitted to the DDOE UST Division approximately 90 days after soil removal is completed and final confirmation sample data is received.


11 Conclusions Soil in the vicinity of UST at the subject property has been affected by a petroleum release. Analytical results indicate that soil contains benzene, ethylbenzene, xylene, naphthalene, TPH-DRO and TPH-GRO concentrations above Tier I RBSLs for both residential and commercial properties and above soil disposal criteria. Analytical results indicate that soil in at least one other area of the property contains TPH-DRO concentrations greater than soil disposal criteria.

The construction of the new building will remove the UST and affected soil within the limits of excavation from the property to a depth necessary to receive a letter of no further action. This work plan will be followed to ensure that all excavated soil is properly characterized and disposed of. Dewatering activities will include measures to monitor and discharge groundwater generated during construction and, if necessary, to treat groundwater as necessary to comply with a discharge permit.

Upon completion of soil excavation and soil and groundwater confirmation sampling, Stanton-Eastbanc will prepare a report documenting the removal of the UST and contaminated soil from the site. Stanton-Eastbanc will submit the report to DDOE and request a No Further Action determination for the subject property.

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Acronym List amsl above mean sea level

bgs below ground surface

BTEX benzene, toluene, ethylbenzene and xylene

COCs Chemicals of Concern

DCFM D.C. Fire Marshal’s

DDOE District of Columbia Department of Environment

DRO diesel-range organics

EDR Environmental Data Resources

EPA U.S. Environmental Protection Agency

FID flame ionization detector

GRO gasoline-range organics

LUST leaking underground storage tank

µg/kg micrograms per kilogram

µg/l micrograms per liter

mg/kg milligrams per kilogram

mg/l milligrams per liter

MTBE methyl-tertiary-butyl-ether

PAH polynuclear aromatic hydrocarbon

PEL permissible exposure limit

PID photoionization detector

PUD Planned Unit Development

RBC risk-based concentrations

RBCA Risk Based Corrective Action

RBSL risk-based screening levels

RCRA Resource Conservation and Recovery Act

SVOCs semi-volatile organic compounds

TPH total petroleum hydrocarbons

UST underground storage tank

VOC volatile organic compound

DC Water District of Columbia Water and Sewer Authority

Figures

WSP USA Corp. 11190 Sunrise Valley Drive, Suite 300

Reston, Virginia 20191 (703) 709-6500

REFERENCE: 7.5 MINUTE SERIES TOPOGRAPHIC QUADRANGLE WASHINGTON EAST, WASHINGTON, D.C. PHOTOREVISED 1979 SCALE 1:24,000

FORMER HINE JUNIOR HIGH SCHOOL

WASHINGTON, D.C.

STANTON - EASTBANC, LLC WASHINGTON, D.C.

Site Location

USJE01047

Callout

label Approx. UST location

Project number: 36877/2 Dated: 2/12/2013 Revised:

Tables

Table 1

Phase II Soil Sample ResultsFormer Hine Junior High School

Washington D.C. (a)

Sample Location: SB-1 (17-19) SB-2 (17-19) SB-3 (16-18) SB-4 (16-18) SB-5 (18-20) SB-6 (18-20) SB-7 (17-19) SB-8 (17-19) GP-1* GP-2* GP-3* GP-3a* GP-6* GP-8* GP-9* GP-10* GP-12* GP-13* GP-15*Sample Date: 6/28/2010 6/29/2010 6/29/2010 6/29/2010 6/28/2010 6/28/2010 6/28/2010 6/28/2010 9/20/2012 9/21/2012 9/19/2012 9/19/2012 9/20/2012 9/19/2012 9/19/2012 9/21/2012 9/20/2012 9/20/2012 9/20/2012

VOCs (ug/kg)DDOE Tier 1 Screening Levels for Residential

Use (b)Methyl-t-Butyl Ether 1,440,000 ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND NDBenzene 5 737 379 ND ND ND ND 300 404 ND ND ND ND ND ND ND ND ND ND NDToluene 100,000 9,380 ND ND ND ND ND 428 ND ND ND ND ND ND ND ND ND ND ND NDEthylbenzene 40.8 6,480 3,310 ND ND ND 3,480 4,040 2,440 ND ND ND ND ND ND ND ND ND ND NDXylene (total) 3,860 3,200 4,930 ND ND ND ND 8,800 7,960 ND ND ND ND ND ND ND ND ND ND NDNaphthalene 706,000 32,600 24,500 ND ND ND 21,000 18,600 18,900 ND 1.8 ND ND ND ND ND ND ND ND ND

Petroleum Hydrocarbons (mg/kg)

TPH-DRO 2,120 28,900 15,200 ND ND 545 20,700 18,000 6,850 ND 1,000 ND ND ND ND ND ND ND ND NDTPH-GRO 54 848 295 ND ND 12 459 463 273 ND 5.2 ND ND ND ND ND ND ND ND ND

a/ ND = not detected above laboratory reporting limits; ug/kg = micrograms per kilogram; mg/kg = milligrams per kilogram; bold values are above Tier 1 screening level. *Schnabel 2012 Phase II boringsb/ DC Risk-Based Corrective Action

WSP Environment & EnergyK:\EASTBANC\Hine Junior High School\Eastbanc_Hine Junior High School\Task #4 Soil Delineation and Dewatering Evaluation\6_Reporting\Reports\Soil Management Plan\Tables\Table 1 and 2 Hine School SMP

Page 1 of 1Revised: 2/12/2013

Table 2

Phase II Groundwater Sample ResultsFormer Hine Junior High School

Washington D.C. (a)

Sample Location: SB-2 SB-4 GP-4* GP-9* GP-11* GP-14* GP-16*Sample Date: 6/29/2010 6/29/2010 9/19/2012 9/19/2012 9/19/2012 9/20/2012 9/20/2012

VOCs (ug/l)DDOE Tier 1

Screening Levels Methyl-t-Butyl Ether 20 ND ND ND ND ND ND NDBenzene 5 4 ND ND ND ND ND NDToluene 1,000 4 ND ND ND ND ND NDEthylbenzene 700 5 ND ND ND ND ND NDXylene (total) 10,000 15 ND ND ND ND ND NDNaphthalene 730 25 ND ND ND ND ND ND

Petroleum Hydrocarbons (mg/L)

TPH-DRO 3,570 1 ND ND ND ND ND NDTPH-GRO 7,300 ND ND ND ND ND ND ND

a/ ND = not detected above laboratory reporting limits; ug/kg = micrograms per kilogram; mg/kg = milligrams per kilogram; bold values are above Tier 1 screening level *Schnable 2012 Phase II borings

WSP Environment & EnergyK:\EASTBANC\Hine Junior High School\Eastbanc_Hine Junior High School\Task #4 Soil Delineation and Dewatering Evaluation\6_Reporting\Reports\Soil Management Plan\Tables\Table 1 and 2 Hine School SMP

Page 1 of 1Revised:2/12/2013

Appendix A – District of Columbia DDOE, Standard Permitting Procedures for Removal of UST’s

Updated May 2012

1 of 2

DISTRICT OF COLUMBIA DISTRICT DEPARTMENT OF THE ENVIRONMENT (DDOE)

STANDARD PERMITTING PROCEDURES FOR

REMOVAL OF UNDERGROUND STORAGE TANKS

I. NOTIFICATION/PERTMITTING PROCEDURES

Pursuant to 20 DCMR §§ 5603.1, the UST owner/operator must notify the District

Department of the Environment (DDOE), Underground Storage Tank (UST) Program

office two (2) weeks in advance of performing work either in writing or by

completing the UST/LUST Activity Notification form on our website. DDOE does

not currently charge a fee for tank removal. However, a $200 fee is required for UST

installation and abandonment-in-place.

The owner/operator must obtain and complete a standard construction permit form

and Building Permit Application Supplemental for from the DCRA Permit Processing

Division, Located at 1100 4th Street SW (Waterfront), they can be reached at (202)

727-7047. These forms and a site diagram must be taken to DDOE for sign-off at

1200 First Street, N.E., 5th

Floor – UST Branch.

Pursuant to 20 DCMR §5603.2, forty-eight (48) hours in advance of the excavation

activity, the owner/operator must notify the D.C. Fire Marshal’s (DCFM) Technical

Inspections Plans and Permits Branch, Hazardous Materials Section on 202-727-

1614, and the UST Branch , on 202-535-2600 to arrange for representatives of the

DCFM and DDOE to be on-site.

UST Contractors/Technicians/Closure Specialist, etc. must obtain certification from

the UST Branch, DDOE prior to performing any UST activities in DC. Failure to

obtain this is a violation. Certification can be issued to individuals or firms valid for 1

to 2 years.

II. ON-SITE CLOSURE PRACTICES

The contractor must follow 20 DCMR § 6101, and standard tank removal safety

practices as contained in the American Petroleum Institute Publication 1604, the D.C.

Fire Code, or equivalent DDOE approved standard.

An Official from the DCFM and DDOE must be present upon tank

removal for tank and excavation area assessment.

Updated May 2012

2 of 2

A minimum of two (2) soil samples from under each tank will be required.

Additional samples may be requested by the UST Inspector. Based on the results of

the initial soil sampling, the owner/operator may be requested to perform a

comprehensive site assessment (the CSA protocol is on our website).

III. ADDITIONAL ACTIVITIES

Contaminated soils stored on-site must be placed upon and covered by plastic and

designed to stop any leachate from migrating from the soil pile.

Tank disposal is the responsibility of the owner/operator and must be performed in

accordance with the applicable solid waste regulations.

Contaminated soils taken from the excavation zone must be transferred to a DDOE

approved treatment/disposal facility within thirty (30) days.

Within thirty (30) days after removal, the owner/operator must submit a DDOE UST

Notification form and a UST Closure Assessment report to the UST Branch. DDOE

will review this report to determine if the site is above our soil standards, if so a

LUST case will be opened for site remediation by the responsible party for the

petroleum contamination.

Please refer to DDOE’s UST Closure Assessment Protocol 2011 for future guidance.

For Additional Information or Clarifications please contact:

District of Columbia Department of the Environment

Toxic Substances Division

Underground Storage Tank Branch

Attention: Branch Chief

1200 First Street, NE, 5th Floor, Washington, DC 20002.

Tel: (202) 535-2600 Fax: (202) 535-1383

Website: www.green.dc.gov, Email: [email protected]

http://www.green.dc.gov/

Project number: 36877/2 Dated: 2/12/2013 Revised:

Appendix B – WSP’s Standard Operating Procedures

Appendix C – Dust and Odor Control Plan

DUST AND ODOR CONTROL PLAN

Former Hine School Redevelopment

Washington, D.C.

2/12/2013

i

Dust and Odor Control Plan

Former Hine School Redevelopment

2/12/2013

Client

Stanton-Eastbanc

Consultant

David Sarr 11190 Sunrise Valley Drive Suite 300 Reston, Virginia 20191 USA Tel: 7037096500 Fax: 7037098505 www.wspenvironmental.com/usa

Registered Address

WSP Environment & Energy

WSP Contacts

David Sarr

Project number: 36877/2 Dated: 2/12/2013 ii Revised:

Table of Contents 1 Introduction ............................................................................... 1

2 Air Monitoring Program ............................................................. 2

2.1 Particulate Monitoring ............................................................ 2 2.2 Organic Vapor Monitoring ...................................................... 2

2.2.1 Laboratory Testing of Air Samples .................................. 3

1

1 Introduction On behalf of Stanton-Eastbanc LLC, WSP Environment & Energy, now part of WSP USA Corp. (WSP) has prepared this Dust and Odor Control Plan to be implemented during demolition and excavation at the former Hine Junior High School located at 335 8th Street SE in Washington, District of Columbia. Stanton-Eastbanc-LLC is planning to construct a Planned Unit Development (PUD) consisting of mixed-use residential, office and retail space on the subject property. The existing buildings will be razed before the new buildings are constructed.

Previous investigations have identified an underground storage tank (UST) and petroleum-contaminated soil on the property. The UST will be removed and affected soil will be excavated and removed from the subject property during construction. UST removal and soil excavation may cause volatile organic compounds (VOCs) and associated odors to be present on the job site. Demolition and excavation work will generate dust. This Dust and Odor Control Plan describes procedures that will be used to monitor and control dust and odor during demolition, excavation, and removal of the UST and contaminated soil.

The General Contractor shall implement a dust control program to minimize wind-blown dust and debris in accordance with the Construction Management Agreement signed by the Advisory Neighborhood Commission 6B and Stanton Eastbanc on August 13, 2012. The General Contractor shall use water trucks on the site and surrounding streets as needed to minimize dust impacts on adjacent streets, sidewalks and buildings. The General Contractor shall increase the use and frequency of dust control measures and street cleaning during demolition and excavation stages of the project as directed by Stanton-Eastbanc.

Air monitoring will be conducted during removal of an underground storage tank and petroleum-contaminated soil from the property to provide real time warning of potential personnel exposure or offsite migration of VOCs. Dust monitoring will be conducted during demolition and excavation work to monitor and prevent offsite migration of dust.

Air quality monitoring will be conducted by Stanton-Eastbanc or their designated representative. Contractors and subcontractors will be responsible for conducting air quality monitoring for their employees. WSP will provide air quality monitoring data to other companies working on the site upon request. Monitoring will be conducted in the work area to monitor potential worker exposure. Monitoring will be conducted at the fence line and property boundary to monitor potential exposure to the general public outside the work area.

Organic vapor monitoring will be conducted during underground storage tank removal and petroleum contaminated soil excavation activities on the property. A MiniRae 2000, MiniRae 3000, UltraRae, or equivalent photo ionization detector (PID) will be used to monitor organic vapors. Since benzene is the main volatile chemical of concern at the site, a 10.6 electron-volt lamp will be used. The PID will be calibrated in accordance with the manufacturer’s instructions before each work day or at the end of the work in preparation for the next work day.

Dust monitoring will be conducted during demolition and excavation using a personal DataRAM pDR1000AN real time monitor or equivalent. The DataRAM will be calibrated in accordance with the manufacturer’s instructions at the start of the project.


2 Air Monitoring Program Air monitoring for particulates will be conducted in the work area and at the fence line during the demolition and excavation work. Air monitoring for VOCs will be conducted in the work area and at the fence line during the UST removal and excavation of petroleum-contaminated soil.

The dust monitoring program described in Section 2.1 will be implemented to determine if additional dust suppression is required. Additional dust suppression will be required if dust concentrations in the work area or excavation are greater than an action level of 2.5 milligrams per cubic meter (mg/m3), which is one half of the Occupational Safety Health Administration (OSHA) dust standard of 5 mg/m3.

Additional dust suppression will also be required if dust concentrations at the fence line are greater than an action level of 150 micrograms per cubic meter (ug/ m3). This is the National Ambient Air Quality Standard for particulate matter less than 10 microns in diameter (PM-10).

2.1 Particulate Monitoring

Particulate monitoring will be performed using a DataRAM pDR1000AN (Mini-RAM) real time monitor or equivalent. The total suspended particulate measured by the Mini-RAM will be used as surrogate readings of PM10. The airborne particulate detection limit for the Mini-RAM is less than the lowest action level (150 ug/m3 at the property boundary).

The action level will be based on the total respirable dust permissible exposure limit (PEL) of 5.0 milligrams per cubic meter (mg/m3). No additional action will be required when the aerosol particulate monitor measures dust concentrations below half of this level (2.5 mg/m3). Engineering controls, such as water spray dust suppression will be implemented when a sustained reading of greater than half the PEL is measured for a period of 5 minutes. If engineering controls cannot reduce the amount of particulate below 2.5 mg/m3, Contractor personnel may be required to upgrade to Level C respiratory protection, which includes the donning of a full-face, tight-fitting air purifying respirator equipped with the appropriate high efficiency particulate air (HEPA) filter cartridge.

Particulate dust readings will be collected at least twice daily from an upwind and downwind location of the active work area or excavation. The Mini-RAM location will be changed daily, based on wind direction. If the average particulate concentrations at the fence line or property boundary during a 15-minute period exceed 150 ug/m3 above the upwind level, or if visible airborne dust is observed leaving the work area, then the excavation contractor will be required to implement dust suppression techniques. Dust sources will be evaluated and suppression will be targeted to the dust-producing activities. Work activities may resume, with dust suppression techniques, provided that particulate concentrations at the fence line or property boundary do not exceed 150 ug/m3 above the upwind concentration and provided that no visible dust is migrating from the work area.

If particulate concentrations at the fence line or property boundary are still greater than 150 ug/m3 above the upwind concentration after implementing dust suppression, work must be stopped and construction activities re-evaluated. The work can resume once changed work practices or controls reduce downwind particulate concentrations to less than above the upwind concentrations and prevent visible dust migration offsite.

All measurements will be recorded and made available for Contractor review upon request.

2.2 Organic Vapor Monitoring

During UST removal and contaminated soil excavation, ambient air quality monitoring with the PID will be conducted at least twice daily, in both upwind and downwind locations. The PID action level is based on potential exposure to benzene, which was detected in soil and groundwater samples from the subject site. Benzene has an OSHApermissible exposure limit (PEL) of 1 part per million (ppm), based on a time-weighted average. The PID action level for benzene will be one half the PEL, or 0.5 ppm.

3

Before beginning excavation, the areas will be screened with a PID to document background volatile organic compounds (VOC) levels in the air at ground level and in the breathing zone. The site health and safety officer or his/her designated representative will then scan the breathing zone with a PID to monitor levels of organic vapors during excavation work. Level D personal protection will be used when the PID measures organic vapor levels below 0.5 ppm. Additional monitoring will be implemented if a sustained PID reading greater than 0.5 ppm is measured in the breathing zone for more than 15 minutes. The work will stop, and compound-specific colorimetric tube monitoring will be performed. Gastec tubes with benzene detection limits of less than 1 ppm will be used to assess potential airborne benzene exposure. If colorimetric tube measurements are greater than 1 ppm, then additional ventilation, dust suppression, or an upgrade in personal protection will be required.

If colorimetric tube measurements are less than 1 ppm, then no additional measurements will be required. However, additional compound-specific monitoring will be implemented if a sustained PID reading greater than 5 ppm above background is measured in the breathing zone. This action level is one half of the 10 ppm OSHA PEL for naphthalene. The work will stop, and compound-specific colorimetric tube monitoring will be performed. A Gastec tube with a naphthalene detection limit less than 10 ppm will be used to assess potential airborne naphthalene exposure. If the naphthalene colorimetric tube measurements are greater than 10 ppm, then additional ventilation, dust suppression, or an upgrade in personal protection will be required.

If naphthalene colorimetric tube measurements are less than 10 ppm, then no additional measures will be required. Additional compound-specific monitoring will be implemented if a sustained PID reading greater than 50 ppm above background is measured in the breathing zone. This action level is one half of the 100 ppm OSHA PEL for ethylbenzene and xylene. The work will stop, and compound-specific colorimetric tube monitoring will be performed. Individual Gastec tubes with detection limits less than 100 ppm will be used to assess potential airborne ethylbenzene and xylene exposure. If any colorimetric tube measurement is greater than the 100 ppm PEL, then additional ventilation, dust suppression, or an upgrade in personal protection will be required. If all colorimetric tube measurements are less than 100 ppm, then no additional measures will be required.

An UltraRAE PID equipped with a compound-specific separation tube may be used instead of Gastec tubes.

If nuisance odors are encountered during the excavation activities, field personnel will screen the breathing zone to determine the level of organic vapors present. If the instantaneous level of organic vapors present in the breathing zone exceeds 10 ppm, colorimetric analysis will be performed as described above to determine whether benzene, or naphthalene are present. If organic vapors are not present above 10 ppm, a water spray will be applied to the area until nuisance odors are no longer present.

2.2.1 Laboratory Testing of Air Samples

As an alternate method of evaluating air quality at the perimeter of the job site, Stanton-Eastbanc may elect to collect air samples for laboratory analysis in accordance with EPA guidance using 6-example, this type of sampling could be conducted if there are reports of noticeable odor on adjacent properties, but field screening does not detect any off-site impacts. If laboratory analysis is conducted, samples will be collected on both upwind and downwind sides of the property.

A batch or lot of the SUMMA™ canisters used for the sampling activities will be certified-clean by the analytical laboratory. This certification involves analyzing the ambient air inside one clean canister by EPA Method TO-15 in SIM mode. If no target compounds are detected at concentrations above the reporting limits, then the canister is evacuated again and all canisters from that lot are available for sampling. If target compounds are detected at concentrations above the reporting limits, then all canisters from that lot must be re-cleaned and a single canister is reanalyzed for the target compounds.

The sampling point will be positioned 5-feet above the ground surface to be representative of the breathing zone. Physical and visual barriers will be placed around the canisters, if necessary, so that they are not disturbed during sample collection. The flow regulators will be pre-set by the laboratory to collect the samples over a 12-hour period. The flow regulator will be connected to the canister and the valve will be opened to initiate sample collection. After 12 hours, the valve on the canister will be closed and the canister will be labeled with the sample


name, location, time and date of sample collection, and the analytical method to be used. The samples will be transported to the laboratory under strict chain-of-custody procedures. All samples will be analyzed for BTEX compounds, by US EPA Method TO-15, as these petroleum-related compounds have been detected in soil samples collected on site. The analytical results will be compared to the EPA Region 3 Regional Screening Levels.

WSP Environment & Energy 11190 Sunrise Valley Drive Suite 300 Reston, Virginia 20191 USA Tel: 7037096500 Fax: 7037098505 www.wspenvironmental.com/usa

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