Coordinating an Off-site Vapor Investigation & Removal
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1 Coordinating an Off-site Vapor Investigation & Removal Sterling Dry Cleaners, Appleton, WI Jennifer Borski, WDNR Oshkosh Wisconsin s s Vapor Intrusion Guidance FET March 2011
2 304 W Wisconsin Ave, Appleton
3 Basic Site Information WDNR Site Name: So s s Dry Cleaners (former) WDNR BRRTS #: Current operation: Sterling Dry Cleaners Soil clay Water table 3-55 ft bgs Flow direction variable Gradient approx ft/ft
4 Site Chronology Dry cleaning facility from prior to 1995 to present (active) Jan 1998 facility fire (arson) May 1999 Phase II ESA (not reported) shows CVOCs & PVOCs in soil & gw June 1999 Sherriff's Auction & Spill June 2008 Owner contacts DNR re: DERP sunset date (8/30/08)
5 Step 1 Gather Information DNR staff involved in 1999 spill Property owner in 1999 Current property owner US Oil responder in 1999 Appleton Fire Department Local consultant County Register of Deeds & Treasurer County GIS
6 How It Looked June 2008
7 How It Looked June 2008
8 Jan Appleton Fire Dept Photos
9 Jan Appleton Fire Dept Photos
10 May 1999 Environmental Site Assessment (ESA) Phase II Map
11 1999 Spill File Incident 55 gal drum spilled (20-30 gal), found AM by construction contractor hired to renovate building Cleanup method excavation by US Oil & ONYX FRONT Soil sample (no depth) PCE = 15,000,000 µg/kg SIDE Soil sample (no depth) PCE = 5,300,000 µg/kg
12 DERP / Enforcement / EPA RP (owner) accepted into DERP - 8/08 RP selected consultant for SI - 9/08 RP submitted three denials for funding - 5/09 DNR filed an enforcement affidavit - 7/09 DNR requested EPA assistance for SI & possible Removal 1/10 EPA approved request same day EPA Action Memo eventually approved
13 Step 2 Develop Your Team(*) & Identify the Stake-holders *EPA On-Scene Coordinator DNR *RR Supervisor *State-EPA Removals Liaison Regional DERP Team member State DERP Team Leader Regional Public Outreach State-EPA Outreach Liaison *DHS
14 Team(*) & Stake-holders continued *Local Health Department (& DPW) Alderperson Local Fire Department (road closing) Mortgage Holder Responsible Party (property owner) Outagamie County Emergency Management
15 Step 3 Prepare Your Approach How much of the neighborhood should be contacted? How will you distribute information? Is proactive media outreach necessary? What are the best and worst-case scenarios? Plan for safety
16 Environmental Study (ES) Phase 1
17 Step 4 ES1 Approach Residents First mobilization 2 homes 1 owner occupied 1 tenant occupied owner in Black Creek Landlord/owners, tenants, attorneys Meet at their home or other location? Access agreement needed? (EPA in this case)
18 Step 5 ES1 Prepare Residents & Neighbors March 2010 Intermittents letters Access to locations Utility markers Info flyer Sub-slab vapor point installation
19 ES1 Interferrents And WD-40
20 Utility / Access Concerns
21 Step 6 ES1 Collect Data
22 ES1 Collect Data
23 ES1 Collect Data Photo by K. Clayton, EPA
24 ES1 Collect Data Photo by K. Clayton, EPA
25 ES1 Collect Data Photo by K. Clayton, EPA
26 ES1 Collect Data Photo by K. Clayton, EPA
27 ES1 Soil & GW Locations
28 ES1 Soil Results PCE = 228,000 µg/kg TCE = 155,000 µg/kg Cis,1-2 2 DCE = 7,180 µg/kg
29 ES1 Groundwater Results PCE = 36,600 µg/l TCE = 17,400 µg/l Cis-1,2 1,2-DCE = 26,900 µg/l
30 ES1 Air Locations
31 ES1 Air Results Unit st floor floor - PCE = 15.1/15.7 µg/m 3 (exceeds WDNR Vapor Action Level of 4.1 µg/m 3 ) Basement Basement PCE = 24.1 µg/m 3 (exceeds WDNR VAL) sub-slab slab - water in sample port (gw > ES adj. to home) Ambient PCE = 7.05 µg/m 3
32 ES1 Air Locations
33 ES1 Air Results *Sampled by DHS & analyzed at State Lab of Hygiene Unit 004 inconclusive ambient higher than IA no sub-slab slab - need full column *1 st floor PCE = 5.4 ppbv (exceeds WDNR VAL of ppbv ) *Basement PCE = 5.3 ppbv (exceeds WDNR VAL) sub-slab slab - Not Sampled (no on-site soil or gw data) Soil gas PCE = ppbv (below WDNR Screening Level of 60.3 ppbv) *Ambient PCE = 29 ppbv (higher than IA)
34 Step 7 ES1 Communicate Results DNR, DHS & AHD team Source property owner Owner-occupied (face-to to-face) Tenant-occupied (letter to owner only) Other stake-holders ( ) Decision: 4/12/10 DNR requested additional EPA Assessment, Removal Action & Sub-slab Depressurization System Install (SSDS)
35 Step 8 - Expand & Repeat Select homes Re-visit approach What are new best and worst-case scenarios?
36 Environmental Study (ES) Phase 2
37 Step 4R ES2 Approach Residents Second mobilization 10 homes, 2 businesses 9 owner-occupied occupied (4( 4 homes agreed) 1 tenant-occupied (Unit 004) 2 commercial tenant business-occupied Landlord/owners, tenants, attorneys Initial letter, public meeting, follow-up letter & door-to to-door Access agreements needed?
38 Step 5R ES2 Prepare Residents & Neighbors August 2010 Intermittents letters Access to locations (incl. road closure) Utility markers Info flyer Sub-slab vapor point installation
39 Step 6R - ES2 Field Work
40 ES2 Soil Gas Results Utility in road adjacent to dry cleaner PCE ranged µg/m 3 (south (south-north) (below WDNR Screening Level of 410 µg/m 3) Soil gas on properties PCE ranged µg/m g/m 3 (south-north)
41 ES2 Air Results (8/10) Unit 005 inconclusive - 1 st floor higher than basement - need resampling of full column 1 st floor PCE = 43.6 µg/m 3 (exceeds WDNR Vapor Action Level of 4.1 µg/m 3) Basement PCE = 2.41 µg/m 3 sub-slab slab - PCE = 9.16 µg/m 3 (WDNR sub-slab slab SL of 41 µg/m 3 not exceeded) Ambient PCE < µg/m 3 Units 006, 007 & 008 low impact
42 ES2 Resampling Air Results (9/10) Unit 005 inconclusive 1 st floor still higher than basement & water in sub-slab slab port - need resampling of full column 1 st floor PCE = 2.82 µg/m 3 (WDNR VAL of 4.1 µg/m 3 not exceeded ) Basement (on stool) PCE = 1.41 µg/m 3 Basement (on floor) PCE = 1.40 µg/m 3 sub-slab slab - water in sample port
43 Step 7R ES2 Communicate Results DNR, DHS & AHD team Source property owner Owner-occupied w/ exceedance (face-to to-face) Owner-occupied w/o exceedance (letter only) Update Alderperson & DPW
44 Step 9 Coordinate Removal Assist EPA OSC Note site restrictions: fence, overhead lines, utilities, ingress & egress Access agreements Road closure Utilities Pathway for haz waste transport Coordinate space (excavation, roll-offs, offs, equipment, backfill, customers, etc)
45 Step 10 Prepare for Removal and Vapor Mitigation Sept 2010 Informational flyer for distribution Clear space Road closure
46 Removal Preparations - Utilities
47 Removal Preparations - Utilities
48 Removal Preparations - Utilities
49 Removal Preparations - Utilities
50 Removal Preparations Road Closure / Parking Restrictions
51 Step 11 - Removal Excavation
52 Removal Excavation
53 ES-Phase 1 Field Work Active gas line not marked!!
54 Removal Excavation
55 Removal Excavation
56 Removal Hydrogen Releasing Compound (HRC)-Extended(X)
57 Removal HRC-X
58 Post-Removal Soil Results
59 Vapor Mitigation Install Sub-Slab Slab Depressurization System (SSDS)
60 Vapor Mitigation Install SSDS
61 Vapor Mitigation Install SSDS
62 Step 12 Identify Future Actions Continue full-column sampling at inconclusive residence (Unit 005) Vapor mitigation performance sampling at 30-days & 90-days at home with SSDS (Unit 002) EPA soil performance sampling in spring 2011 DNR monitoring well installation in spring 2011 EPA Possible re-application of HRC-X X or other in- situ treatment DNR Eventual off-site soil delineation at Unit 004 & Long-Term Monitoring (LTM)
63 30-Day Vapor Mitigation Performance Sampling Unit 002 (11/10) 1 st floor floor - PCE = 9.22/9.29 µg/m 3 (exceeds WDNR Vapor Action Level of 4.1 µg/m 3 ) Basement Basement PCE = 9.16 µg/m 3 (exceeds WDNR VAL) sub-slab slab - water in sample port (gw > ES adj. to home) Ambient PCE = 2.49 µg/m 3
64 90-Day Vapor Mitigation Performance Sampling Unit 002 (2/11) 1 st floor - PCE = 6.58/6.73 µg/m 3 (exceeds WDNR Vapor Action Level of 4.1 µg/m 3 ) Basement PCE = 6.61 µg/m 3 (exceeds WDNR VAL) sub-slab slab - water in sample port (gw > ES adj. to home) Ambient PCE < µg/m 3 Next event scheduled for May 2011
65 Resampling Unit 005 Air Results (2/11) 1 st floor PCE = µg/m 3 (WDNR VAL of 4.1 µg/m 3 not exceeded ) Basement (on stool) PCE = µg/m 3 Basement (on floor) PCE = µg/m 3 sub-slab slab - water in sample port Ambient PCE < µg/m 3 No further sampling planned
66 Points of Interest for Study, Removal & Mitigation Off-site participation of air study voluntary in this scenario Off-site exemption does not apply to air Plan for best & worst-case contingencies early in process (i.e. no sub-slab slab data) Local stake-holders involvement critical
67 Summary of Coordination 1. Gather information 2. Develop your team & identify stakeholders 3. Prepare your approach 4. Approach residents 5. Prepare site, residents & neighbors 6. Collect data 7. Communicate results 8. Expand and repeat process if necessary 9. Coordinate Removal and/or Vapor Mitigation 10. Prepare site, residents & neighbors 11. Perform Removal and/or Vapor Mitigation 12. Identify future actions
68 Questions?
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