11231 Richmond Avenue Suite D104 Houston, TX 77082 Tel (832) 916-3690 October 16, 2017 Project No. 4020 Mr. Rodney Bryant VCP-CA Section, MC-221 Remediation Division Texas Commission on Environmental Quality P. O. Box 13087 Austin, Texas 78711-3087 SUBJECT: VOLUNTARY CLEANUP PROGRAM (VCP) CES GRIGGS ROAD VCP SITE 4900 GRIGGS ROAD, 4904 GRIGGS ROAD, AND 5910 WAYLAND STREET (VCP No. 2751; CN604824904; RN108370644) RESPONSE TO JUNE 16, 2017 COMMENTS ON REVISED APAR – COMMENT 4 ADDITIONAL GROUNDWATER ASSESSMENT Dear Mr. Bryant: Pastor, Behling & Wheeler, LLC (PBW), on behalf of the CES Griggs Road PRP Group (the “Group”), has prepared this response to Comment 4 on the revised Affected Property Assessment Report (APAR). The APAR summarized the environmental assessment of the CES Griggs Road VCP Site (the “Site”) pursuant to the requirements of VCP Agreement No. 2751. The VCP Agreement was executed between the Group and the Texas Commission on Environmental Quality (TCEQ) on June 10, 2015. The revised APAR was submitted to TCEQ on April 17, 2017. Comments were provided to the Group by the TCEQ on June 16, 2017. As quoted below, TCEQ requested an additional assessment of the second sand (approximately 40-60 feet below ground surface (bgs)) in Comment 4. “In addition, the TCEQ understands that cone penetrometer tests (CPT) were conducted to identify the presence of a laterally continuous clay layer that could possibly separate the upper groundwater bearing unit (GWBU) from a second sand unit. The TCEQ notes that the data located in the boring logs for the CPT test do no indicate a continuous clay layer. The 20’ [foot] thick clay layer identified contains numerous intermittent sands and clayey sands which may allow for vertical migration of contamination and connection of the first and second sands. Additional assessment of this second sand (approximately 40-60’ bgs) should be conducted to determine whether the contamination identified in the shallow sand is also present in the second sand.” In response to TCEQ’s comment, the Group conducted CPT sampling with a piezocone on October 10, 2017 to assess if chlorinated volatile organic compounds (cVOCs) detected in the on-Site upper GWBU had migrated vertically into the second GWBU. The CPT location, CPT-7-2, was advanced in the presumed source area between MW-1 and MW-5. A groundwater sample was collected after the second zone was identified by CPT. Figure 1 presents the sample location. The first GWBU was encountered at approximately 13 feet bgs in CPT-7-2. The top of the confining clay underlying the first GWBU was encountered approximately 27 feet bgs with a thickness of approximately 16
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11231 Richmond Avenue
Suite D104 Houston, TX 77082 Tel (832) 916-3690
October 16, 2017
Project No. 4020
Mr. Rodney Bryant
VCP-CA Section, MC-221
Remediation Division
Texas Commission on Environmental Quality
P. O. Box 13087
Austin, Texas 78711-3087
SUBJECT: VOLUNTARY CLEANUP PROGRAM (VCP)
CES GRIGGS ROAD VCP SITE
4900 GRIGGS ROAD, 4904 GRIGGS ROAD, AND 5910 WAYLAND STREET
(VCP No. 2751; CN604824904; RN108370644)
RESPONSE TO JUNE 16, 2017 COMMENTS ON REVISED APAR – COMMENT 4
ADDITIONAL GROUNDWATER ASSESSMENT
Dear Mr. Bryant:
Pastor, Behling & Wheeler, LLC (PBW), on behalf of the CES Griggs Road PRP Group (the “Group”), has
prepared this response to Comment 4 on the revised Affected Property Assessment Report (APAR). The
APAR summarized the environmental assessment of the CES Griggs Road VCP Site (the “Site”) pursuant to
the requirements of VCP Agreement No. 2751. The VCP Agreement was executed between the Group and
the Texas Commission on Environmental Quality (TCEQ) on June 10, 2015.
The revised APAR was submitted to TCEQ on April 17, 2017. Comments were provided to the Group by the
TCEQ on June 16, 2017. As quoted below, TCEQ requested an additional assessment of the second sand
(approximately 40-60 feet below ground surface (bgs)) in Comment 4.
“In addition, the TCEQ understands that cone penetrometer tests (CPT) were conducted to identify
the presence of a laterally continuous clay layer that could possibly separate the upper groundwater
bearing unit (GWBU) from a second sand unit. The TCEQ notes that the data located in the boring
logs for the CPT test do no indicate a continuous clay layer. The 20’ [foot] thick clay layer
identified contains numerous intermittent sands and clayey sands which may allow for vertical
migration of contamination and connection of the first and second sands. Additional assessment of
this second sand (approximately 40-60’ bgs) should be conducted to determine whether the
contamination identified in the shallow sand is also present in the second sand.”
In response to TCEQ’s comment, the Group conducted CPT sampling with a piezocone on October 10, 2017
to assess if chlorinated volatile organic compounds (cVOCs) detected in the on-Site upper GWBU had
migrated vertically into the second GWBU. The CPT location, CPT-7-2, was advanced in the presumed
source area between MW-1 and MW-5. A groundwater sample was collected after the second zone was
identified by CPT. Figure 1 presents the sample location.
The first GWBU was encountered at approximately 13 feet bgs in CPT-7-2. The top of the confining clay
underlying the first GWBU was encountered approximately 27 feet bgs with a thickness of approximately 16
Mr. Rodney Bryant
October 16, 2017
Page 2 of 2
feet. These depths are consistent with the shallow GWBU depths observed from previous investigations. The
second GWBU was encountered at approximately 43 feet bgs. This depth is consistent with the previous CPT
investigation. The CPT was advanced to approximately 55 feet bgs to ensure the groundwater sample was
collected within the second sand zone (see CPT log in the Attachments). A groundwater sample and a
duplicate were collected (see the Photolog in the Attachments). The following table provides the results:
As shown in this table, all targeted cVOCs were below the limits of detection. The laboratory report is
provided in the Attachments.
Based on these results, the Group requests agency concurrence that the data presented in this letter report
demonstrate that additional assessment of the second sand zone at the CES Site has been completed.
With this letter report, coupled with the previous Group submittals dated September 21 and October 11, 2017,
the Group has submitted complete responses to all agency comments as provided by the TCEQ comment
letter dated June 16, 2017. Consequently, the Group requests agency approval of the revised APAR in order
to proceed with preparation of the Response Action Plan.
If you have any questions or comments, please call (832) 916-3691 or email [email protected].
Sincerely,
PASTOR, BEHLING & WHEELER, LLC
Brenda P. Basile, Ph.D.
Senior Consulting Scientist
cc: CES Griggs Road PRP Group
Attachments: Figure 1 On-Site Property Map
CPT Log
Photolog
Laboratory Report
Mr. Rodney Bryant October 16, 2017
FIGURE
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29A
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03A
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04A
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MW-02
MW-04
MW-03
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05
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MW-01
MW-05
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32
MW-08
MW-06
MW-07
CPT-05
CPT-06
CPT-04
CPT-01
CPT-03
CPT-02
HA-02
HA-01
HA-04
HA-05
HA-03
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4900 Griggs Rd.
4904 Griggs Rd.
5910 Wayland St.
120600
Scale in Feet
DATE:
PROJECT:
PASTOR, BEHLING & WHEELER, LLC
CONSULTING ENGINEERS AND SCIENTISTS
REVISIONS
CHECKED:
BY:
Figure 1
AJD
BBJULY, 2017
4020
Source:
Imagery taken from Google Earth, photography dated July 31, 2015.
Approx. Property Boundary
PBW Sample Location
PBW Sample Location (Jan. 2017)
PBW Monitoring Well Location
PBW Monitoring Well Location (Jan. 2017)
CPT Location
Hand Auger Location
CES GRIGGS ROAD VCP SITE
HOUSTON, TEXAS
Office Building
Training Center/Locker Room (2008)/
Administrative (2010)
Industrial Waste Processing & Storage (2008)/
Main Processing (2010)
Old Cleaning Rack (1996)/
Tank Trucking Cleaning (2008)/Safe Wash (2010)
Equipment Cleaning (2008)/
Drum Cleaning (2010)
New Shop (1996)/Truck Maintenance (2008)
Cleaning Rack (1996)/Tank Truck Cleaning (2008)/
Equipment & Fleet Maintenance (2015)
Oil/Water Separating Tanks (2010)/
North Tank Farm (2015)
Oil/Water Separating Tanks (2010)/
South Tank Farm (2015)
Welding Shop
Fuel Storage Shed
WMU 126-128 (Frac Tanks)
Former Mechanic Shop (2010)/Field Services (2015)
1
2
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4
5
6
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8
9
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12
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Hot Oil Heat System (2008)/
Drum-Tote Storage (2015)
10
Approximate Location Second Zone Groundwater Sample
AutoCAD SHX Text
N
AutoCAD SHX Text
ON-SITE PROPERTY MAP
AutoCAD SHX Text
%%uEXPLANATION
brenda basile
Oval
brenda basile
Oval
brenda.basile
Text Box
CPT-7-2
Mr. Rodney Bryant October 16, 2017
CPT LOG
0
10
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Job Number: Operator: Location:
CPT Number:Date:Elevation:
Coordinates:Cone Number:
04.19170065Bobby BrandtHouston, TX
CPT-7-210-Oct-20170.00
29.69850 -95.34361CP15-CF75PB7SN2-P1E1 1629
Page 1 of 1
Sleeve Friction Fs (TSF) Cone Resistance qc (TSF) Pore Pressure U2 (TSF) Friction Ratio Rf (%)Soil Behavior
Type
(1) sensitive fine grained (OL-CH)
(2) organic material (OL-OH)
(3) clay (CH)
(4) silty clay to clay (CL-CH)
(5) clayey silt to silty clay (MH-CL)
(6) sandy silt to clayey silt (ML-MH)
(7) silty sand to sandy silt (SM-ML)
(8) sand to silty sand (SM-SP)
(9) sand (SW-SP)
(10) gravel to gravelly sand (SW-GW)
(11) very stiff fine grained* (CH-CL)
(12) sand to clayey sand* (SC-SM)
Robertson et al. 1986 *Overconsolidated or Cemented
0 4 0 300 -3 0 12 0 10 0 12
Mr. Rodney Bryant October 16, 2017
PHOTOLOG
PHOTOGRAPHIC LOG
Client Name: CES Griggs Road PRP Group
Site Location: CES Environmental Services, 4904 Griggs Road, Houston, Texas
Project No. 4020
Photo No.
1 Date:
10/09/17 Looking northwest at the location of CPT-7-2. The red arrow points to the location of the second zone groundwater sampling point. The orange cone is sitting on top of MW-5.
Photo No.
2 Date:
10/10/17
View of the screen used during groundwater sampling at CPT-7-2.
Mr. Rodney Bryant October 16, 2017
LABORATORY REPORT
Data Usability Summary
To: Tony Saturni, CES PRP Group Date: October 13, 2017
From: Brenda Basile, Ph.D. File: CES APAR SECOND ZONE DUS.doc
RE: Second Zone Groundwater for 4904 Griggs CC:
Pastor, Behling & Wheeler, LLC (PBW) reviewed one laboratory report for the analyses of groundwater samples collected by PBW (Houston, Texas) at the CES Griggs Road VCP Site on October 10, 2017. The report was reviewed for conformance to the requirements of SW-846 Test Methods for Evaluating Solid Waste Physical/Chemical Methods (SW-846) and the Texas Commission on Environmental Quality (TCEQ) guidance document Review and Reporting of COC Concentration Data (RG-366/TRRP-13). The purpose of this sample event was to provide second zone groundwater data for the Affected Property Assessment Report (APAR).
Samples were analyzed using SW-846 8260B - Volatile Organic Compounds by Gas Chromatography-Mass Spectrometry (GC/MS). Quality control (QC) data were reviewed as described in RG-366/TRRP-13 and the results of the review are discussed in this data usability summary (DUS).
Introduction
The August 2017 samples were analyzed for chlorinated VOCs. Table 1 lists the sample identifications cross-referenced to laboratory identifications and the analyses performed for each sample. No data were qualified due to exceedances of QC criteria.
QC Results
ACCREDITATION
ALS Environmental is accredited under Texas certificate T104704231-17-19 for the matrices, methods and analytes discussed in this DUS.
PRESERVATION AND HOLDING TIMES
Samples were received at the laboratory at temperatures less than 6C. Samples were prepared and
analyzed within method holding times.
BLANKS
No analytes were detected in field or laboratory quality control.
SURROGATE RECOVERIES
Surrogate recoveries were within the RG-366/TRRP-13 acceptance criteria of 60-140 percent recovery (%R) for VOCs.
INTERNAL STANDARD RECOVERIES
According to the LRC, internal standard recoveries were within the method acceptance criteria.
LABORATORY CONTROL SAMPLES
Laboratory control sample (LCS) recoveries (%R) were within the acceptance criteria of 60-140% criteria for VOCs.
CES APAR Second Zone DUS.Doc 2
October 13, 2017
MATRIX SPIKE/MATRIX SPIKE DUPLICATE
Batch or non-project sample data were not evaluated. No project samples were spiked.
FIELD PRECISION
Analytes were not detected in the field duplicate samples so precision was not calculated. Field duplicate data are acceptable.
SUMMARY
Analytical data are usable for determining concentrations in second zone groundwater samples collected at the CES Griggs Road VCP Site.
Table 1 Cross-Reference Field Sample Identifications and Laboratory Identifications
Field Identification Laboratory Identification VOCs Comment
Trip Blank 171010 HS17100583-01 X Trip Blank
CPT-7-2 171010 HS17100583-02 X
CPT-7-2 171010 Dup HS17100583-03 X Field duplicate of CPT-7-2 171010
The analytical data provided relates directly to the samples received by ALS Environmental and for only the analyses requested. Results are expressed as "as received" unless otherwise noted.
QC sample results for this data met EPA or laboratory specifications except as noted in the Case Narrative or as noted with qualifiers in the QC batch information. Should this laboratory report need to be reproduced, it should be reproduced in full unless written approval has been obtained by ALS Environmental. Samples will be disposed in 30 days unless storage arrangements are made.
If you have any questions regarding this report, please feel free to call me.
Sincerely,
ALS Environmental received 3 sample(s) on Oct 10, 2017 for the analysis presented in the following report.
Laboratory Results for: CES Griggs Rd Quarterly GW
This data package consists of all or some of the following as applicable:
This signature page, the laboratory review checklist, and the following reportable data:
R1 Field chain-of-custody documentation;
R2 Sample identification cross-reference;
R3 Test reports (analytical data sheets) for each environmental sample that includes:a) Items consistent with NELAC Chapter 5, b) dilution factors, c) preparation methods, d) cleanup methods, and e) if required for the project, tentatively identified compounds (TICs).
R4 Surrogate recovery data including:a) Calculated recovery (%R), and b) The laboratory’s surrogate QC limits.
R5 Test reports/summary forms for blank samples;
R6 Test reports/summary forms for laboratory control samples (LCSs) including:a) LCS spiking amounts, b) Calculated %R for each analyte, and c)The laboratory’s LCS QC limits.
R7 Test reports for project matrix spike/matrix spike duplicates (MS/MSDs) including:a) Samples associated with the MS/MSD clearly identified, b) MS/MSD spiking amounts, c) Concentration of each MS/MSD analyte measured in the parent and spiked samples, d) Calculated %Rs and relative percent differences (RPDs), and e) The laboratory’s MS/MSD QC limits.
R8 Laboratory analytical duplicate (if applicable) recovery and precision:a) the amount of analyte measured in the duplicate, b) the calculated RPD, and c) the laboratory’s QC limits for analytical duplicates.
R9 List of method quantitation limits (MQLs) and detectability check sample results for eachanalyte for each method and matrix.
R10 Other problems or anomalies. The Exception Report for each “No” or “Not Reviewed (NR)” item in Laboratory Review Checklist andfor each analyte, matrix, and method for which the laboratory does not hold NELAC accreditation underthe Texas Laboratory Accreditation Program.
ALS Group USA, Corp Date: 13-Oct-17
Page 2 of 18
Client:TRRP Laboratory Data Package Cover PageProject:
Release Statement: I am responsible for the release of this laboratory data package. This laboratory isNELAC accredited under the Texas Laboratory Accreditation Program for all the methods, analytes andmatrices reported in this data package except as noted in the Exception Reports. The data have beenreviewed and are technically compliant with the requirements of the methods used, except where noted bythe laboratory in the attached exception reports. By my signature below, I affirm to the best of myknowledge, all problems/anomalies, observed by the laboratory have been identified by the laboratory inthe Laboratory Review Checklist, and no information affecting the quality of the data has been knowinglywithheld.
Check, if applicable: [NA] This laboratory meets an exception under 30 TAC §25.6 and was last inspectedby [ ] TCEQ or [ ] ______________ on (enter date of last inspection). Any findings affecting the data inthis laboratory data package are noted in the Exception Reports herein. The official signing the cover pageof the report in which these data are used is responsible for releasing this data package and is by signatureaffirming the above release statement is true.
ALS Group USA, Corp Date: 13-Oct-17
Page 3 of 18
Laboratory Review Checklist: Reportable Data
Laboratory Name: ALS Laboratory Group LRC Date: 10/13/2017
Reviewer Name: Dane Wacasey Prep Batch Number(s): R303310 #1 A2 Description Yes No NA3 NR4 ER#5
S1 OI Initial calibration (ICAL)
Were response factors and/or relative response factors for each analyte within QC
limits? X
Were percent RSDs or correlation coefficient criteria met? X
Was the number of standards recommended in the method used for all analytes? X
Were all points generated between the lowest and highest standard used to
calculate the curve? X
Are ICAL data available for all instruments used? X
Has the initial calibration curve been verified using an appropriate second source
standard? X
S2 OI Initial and continuing calibration verification (ICCV and CCV) and
continuing calibration blank (CCB)
Was the CCV analyzed at the method-required frequency? X
Were percent differences for each analyte within the method-required QC limits? X
Was the ICAL curve verified for each analyte? X
Was the absolute value of the analyte concentration in the inorganic CCB < MDL? X
S3 O Mass spectral tuning:
Was the appropriate compound for the method used for tuning? X
Were ion abundance data within the method-required QC limits? X
S4 O Internal standards (IS):
Were IS area counts and retention times within the method-required QC limits? X
S5 OI
Raw data (NELAC section 1 appendix A glossary, and section 5.12 or ISO/IEC
17025 section
Were the raw data (for example, chromatograms, spectral data) reviewed by an
analyst? X
Were data associated with manual integrations flagged on the raw data? X
S6 O Dual column confirmation
Did dual column confirmation results meet the method-required QC? X
S7 O Tentatively identified compounds (TICs):
If TICs were requested, were the mass spectra and TIC data subject to appropriate
checks? X
S8 I Interference Check Sample (ICS) results:
Were percent recoveries within method QC limits? X
S9 I Serial dilutions, post digestion spikes, and method of standard additions
Were percent differences, recoveries, and the linearity within the QC limits
specified in the method? X
S10 OI Method detection limit (MDL) studies
Was a MDL study performed for each reported analyte? X
Is the MDL either adjusted or supported by the analysis of DCSs? X
S11 OI Proficiency test reports:
Was the laboratory's performance acceptable on the applicable proficiency tests or
evaluation studies? X
S12 OI Standards documentation
Are all standards used in the analyses NIST-traceable or obtained from other
appropriate sources? X
S13 OI Compound/analyte identification procedures
Are the procedures for compound/analyte identification documented? X
S14 OI Demonstration of analyst competency (DOC)
Was DOC conducted consistent with NELAC Chapter 5C or ISO/IEC 4? X
Is documentation of the analyst’s competency up-to-date and on file? X
S15 OI
Verification/validation documentation for methods (NELAC Chap 5 or
ISO/IEC 17025 Section 5)
Are all the methods used to generate the data documented, verified, and validated,
where applicable? X
S16 OI Laboratory standard operating procedures (SOPs):
Are laboratory SOPs current and on file for each method performed? X Items identified by the letter “R” must be included in the laboratory data package submitted in the TRRP-required report(s). Items identified by the letter “S” should be retained and made available upon request for the appropriate retention period. O = Organic Analyses; I = Inorganic Analyses (and general chemistry, when applicable); NA = Not Applicable; NR = Not Reviewed; R# = Exception Report identification number (an Exception Report should be completed for an item if “NR” or “No” is checked).
Page 5 of 18
Laboratory Review Checklist: Exception Reports
Laboratory Name: ALS Laboratory Group LRC Date: 10/13/2017
Reviewer Name: Dane Wacasey Prep Batch Number(s): R303310
ER#5 Description
No Exceptions
Items identified by the letter “R” must be included in the laboratory data package submitted in the TRRP-required report(s). Items identified by the letter “S” should be retained and made available upon request for the appropriate retention period. O = Organic Analyses; I = Inorganic Analyses (and general chemistry, when applicable); NA = Not Applicable; NR = Not Reviewed; R# = Exception Report identification number (an Exception Report should be completed for an item if “NR” or “No” is checked).
Page 6 of 18
Client: Pastor, Behling & Wheeler, LLC
Work Order: HS17100583Project: CES Griggs Rd Quarterly GW SAMPLE SUMMARY
Lab Samp ID Client Sample ID Collection DateMatrix TagNo Date Received Hold