Phase II Environmental Site Assessment

Virginia Environmental Professionals, LLC (VEP) has completed a Phase II Environmental Site Assessment (ESA) for a former asphalt paving company equipment yard located in Richmond, Virginia. The scope of work was completed in general accordance with the American Society for Testing and Materials (ASTM) Standard Practice for Environmental Site Assessments: Phase II Environmental Site Assessment Process (E1903-19).

 

The purpose of the Phase 2 ESA was to evaluate whether soil and/or groundwater at the site has been impacted by the historical use of the property as an asphalt paving company equipment yard and maintenance facility.  

The scope of work for the Phase 2 Environmental Assessment included the following tasks:

• Contacting the Virginia 811 One-Call utilities protection center to locate underground utilities around the site and completing a ground penetrating radar (GPR) survey to minimize the potential for damage to underground utilities

• A total of nine soil borings were advanced at the site using a Geoprobe drill rig with direct-push sampling methods to collect soil samples for field screening and laboratory analysis;

• Soil samples were collected continuously from borings to auger refusal on bedrock and to 5-10 feet below ground surface (BGS) from the remaining soil borings. Soil samples were collected for physical description and field screening for volatile organic compounds (VOCs) using a photo-ionization detector (PID) and the headspace method;

• Ten soil samples were selected based on field screening results and sample depths and submitted to a certified laboratory for analysis.  Soil samples were analyzed for VOCs by EPA Method 8260D, polycyclic aromatic hydrocarbons (PAHs) by EPA Method 8270D, and RCRA 8 Metals by EPA Methods 610D and 7471B (mercury);

• ​A Phase 2 Environmental Site Assessment Report was prepared to document VEPs findings and offer recommendations for further action to address site conditions.

The site consisted of a parcel that was to be developed into a residential neighborhood in Richmond, VA. The majority of the property was vacant wooded land with a residence and a construction equipment yard that was formerly used for an asphalt paving business. The paving business occupied approximately four acres in area and contained four buildings that were formerly used for heavy equipment repair and maintenance.

According to historical information from the Phase 1 Environmental Site Assessment Report, the property has been vacant wooded and grassed land with several structures. A construction yard and additional residence was constructed on the property sometime between 1985 and 1994. Historical aerial photographs show heavy equipment and significant staining on the ground.

VEP prepared an Environmental Desktop Review for the property prior to the Phase II ESA. Based on observations and information gathered, VEP identified the presence of the following recognized environmental condition (REC) on the property:

• Historical aerial photographs show significant staining on the ground in areas of equipment repair and storage at the equipment yard on the property. Asphalt paving operations and paving equipment maintenance and repair are known to use regulated chemicals, solvents, and fuels, and when coupled with the staining observed in the aerial photographs, represent a recognized environmental condition for the subject property.

Based on the results of the Environmental Desktop Review, VEP recommended completion of a Phase II Environmental Site Assessment on the former asphalt paving company equipment yard portion of the property.

Based on the results of the Phase 1 ESA Report, the Phase 2 ESA was completed as follows.  A track-mounted Geoprobe drill rig was used to advance 2.25-inch diameter soil borings using direct push soil sampling methods at nine locations on the property. All borings were advanced in selected locations on the southern portion of the site where former equipment repair and maintenance activities and staining was observed in historical aerial photographs. Continuous soil samples were collected from each Geoprobe soil boring from ground surface to depths ranging from 5 to 33 feet below ground surface (BGS). Probe refusal on bedrock was encountered at 23 and 33 feet BGS in the first two borings drilled. Groundwater was not encountered in any of the borings.

Continuous soil samples were collected from ground surface to the total soil boring depth for physical description and chemical analysis. Soil samples were collected using a 5-foot macro-core sampler with single-use, disposable polyvinyl chloride liners. Samples were collected from the disposable liners and placed into laboratory provided sample containers. Soil samples were collected at depth intervals of five feet and were screened for VOCs using a MINIRAE photo-ionization detector (PID) and the headspace method. Soil samples were submitted for laboratory analysis based on PID readings, location, and depth. Soil samples were placed into laboratory-provided containers, sealed, labeled, packed on ice, and hand delivered to Pace Laboratories in Richmond, Virginia under standard chain-of-custody procedures.

Soil samples were analyzed for VOCs by EPA Method 8260D, PAHs by EPA Method 8270D, and RCRA 8 Metals by EPA Methods 6010D and 7471B (mercury). 

Following completion of soil sampling activities, soil borings were backfilled with bentonite hole plug to the original ground surface and hydrated with tap water. Non-disposable down-hole sampling equipment was cleaned between soil boring locations in accordance with applicable

Laboratory analytical data indicated that no VOC constituents, six (6) PAH constituents (phenanthrene, fluoranthene, pyrene, chrysene, benzo(b)fluoranthene, and benzo(a)pyrene), and four of the 8 RCRA metals (barium, chromium, lead, and mercury) were detected in in the soil samples submitted for analysis.

Of the detected constituents, only one PAH compound (benzo(a)pyrene) was detected in excess of the USEPA Regional Screening Levels (RSLs) for resident soil.

Based on the results of the Phase 2 ESA tasks, the following conclusions were presented:

• No VOC compounds were detected in any of the soil samples submitted for laboratory analysis.

• The PAH compounds phenanthrene, fluoranthene, pyrene, chrysene, benzo(b)fluoranthene, and benzo(a)pyrene were detected at low concentrations in soil sample SB-2 (0-5’). PAH compounds were not detected in any of the other soil samples submitted for laboratory analysis. PAHs are a class of chemicals that occur in coal, crude oil, petroleum fuels, and asphalt tar. They also are produced when coal, petroleum fuels, wood, garbage, and other items are burned.

• The PAH benzo(a)pyrene was detected in SB-2 at a concentration of 0.470 mg/kg, which exceeded the USEPA RSL for resident soil of 0.11 mg/kg. An additional soil sample was collected from SB-2 at a depth of 5-10 feet BGS and did not contain any detectable PAH compounds. This finding, combined with the observed black staining, wet soil, and odor observed in the top 2-feet of this boring, indicate that the vertical extent of PAH contamination at this location is limited to the top 2-feet of soil. Additional soil samples in the vicinity of SB-2, collected from SB-4 (0-5’) and SB-9 (0-5’), did not contain any detectable PAH compounds. This finding indicates that the horizontal extent of PAH contamination is limited to the immediate area surrounding SB-2.

• Four of the 8 RCRA metals (barium, chromium, lead, and mercury) were detected in each of the soil samples submitted for laboratory analysis. Since there is no known historical source of chromium VI at the site, chromium analysis was not analyzed for its valent states, and it can be assumed that the total chromium detected consists of naturally occurring elemental chromium. None of the metals concentrations exceeded the USEPA RSLs for resident soil and the detected metals are known to occur naturally in soils of the area. Based on these observations, and the consistent detection and concentration in every sample analyzed, it can be concluded that the metals detected are natural occurring at the concentrations detected.

• Due to the observation of stained soil areas in historical aerial photographs, and the assumed grading and mixing of soils after the asphalt paving company ceased operations, there is the potential for other sporadic and low concentration areas of contamination on the property. This is noted as a potential concern, but is of low risk due to the sampling locations for this investigation being in worst case locations and of sufficient quantity to identify a significant issue in soils, and the property being graded after the asphalt company ceased operations and any surficial staining and/or contamination would have been mixed with clean soil, further reducing any potential areas of contamination that may exceed applicable clean-up standards.

• Applicable clean-up standards are the USEPA Regional Screening Levels (RSLs) for resident soil. The risk-based and drinking water-based Soil Screening Levels (SSLs) for the protection of groundwater were not used because the vertical extent of contamination has been defined within 5-feet BGS at the one location of detected contamination, groundwater was not encountered within 33-feet BGS, and no other contaminants or soil vapors were detected in any of the other soil borings at the site.

• If the purchaser meets the requirements of a Bona Fide Prospective Purchaser (BFPP) under the Virginia DEQ Brownfields Program, the purchaser and lender would have a limitation of liability for the contamination detected. The Virginia Brownfields Restoration and Land Renewal Act provides liability defense for prospective purchasers and other entities should they meet the requirements of the statute. These protections are self-implementing, insofar as DEQ is not required to confer protections to a prospective purchaser and the purchaser can make the enabled defense as long as the requirements of the statute are met.

Virginia Code § 10.1-1234. states:

“A bona fide prospective purchaser shall not be held liable for a containment or cleanup that may be required at a brownfield site pursuant to the Virginia Waste Management Act (§ 10.1-1400 et seq.), the State Water Control Law (§ 62.1-44.2 et seq.), or the State Air Pollution Control Law (§ 10.1-1300 et seq.) if (i) the person did not cause, contribute, or consent to the release or threatened release, (ii) the person is not liable or potentially liable through any direct or indirect familial relationship or any contractual, corporate, or financial relationship or is not the result of a reorganization of a business entity that was potentially liable, (iii) the person exercises appropriate care with respect to hazardous substances found at the facility by taking reasonable steps to stop any continuing release, prevent any threatened future release, and prevent or limit human, environmental, or natural resource exposure to any previously released hazardous substances, and (iv) the person does not impede the performance of any response action. These provisions shall not apply to sites subject to the Resource Conservation and Recovery Act (42 U.S.C. § 6901 et seq.).

The recommendations listed below are intended to satisfy the appropriate care requirement in item (iii) listed in the statute.

Based on the results of the Phase II ESA and the proposed purpose to construct a residential subdivision on the property, VEP recommends the following potential options to address the contamination detected:

Option 1: Excavate and remove contaminated soils in the area of SB-2 to a depth of approximately 3-feet BGS. Excavated soils should be stockpiled and covered in plastic sheeting or placed in a roll-off box for disposal characterization or taken to the owner’s asphalt plant for use in asphalt mix. If stockpiled for disposal, soil characterization should consist of collection of composite soil samples for VOC and PAH compounds. Results of the disposal characterization sampling can be used to determine if the excavated should be transported off-site for disposal at a local landfill or if the soil can be spread on-site. During excavation, a confirmatory soil sample should be collected from the bottom of the excavated area to confirm contaminated soil has been removed.

Excavation contractors should be made aware of the potential for other unidentified and sporadic areas of contamination on the property. If found, contractors should excavate, segregate, and stockpile any obviously stained or odor containing soils, and then characterize and dispose of the stockpile as discussed above.

Option 2: Conduct a risk assessment to calculate site-specific soil clean-up levels. The USEPA RSLs are very conservative and generic screening levels used for a variety of scenarios, property types, and soil conditions. Due to the low concentrations of PAHs detected, a site-specific risk assessment may possibly find that the conditions at this property will allow calculation of a higher clean-up standard, which would in turn allow the low concentration contaminants to remain in place and not be of risk to human or ecological receptors.

Option 3: If the purchaser or lender requires regulatory concurrence that the prospective purchaser qualifies for the BFPP defense, then complete and submit an application to the DEQ Brownfield Program for a “comfort letter”. A “comfort letter” is not required for the liability protection, it is simply a concurrence that the prospective purchaser may make an affirmative defense under the BFPP statute.

 

Please call us if you need a Phase 2 Environmental Site Assessment in Richmond or anywhere in Virginia.