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http://www.epa.gov/oswer/vaporintrusion/documents/PVI-Guide-Final.pdf, http://www.epa.gov/oswer/vaporintrusion/documents/OSWER-Vapor-

Intrusion-Technical-Guide-Final.pdf

Challenges of Conducting Large Scale, High Profile Vapor Intrusion

Projects

Jim Fineis P.G.Atlas Geo-Sampling Company

[email protected]

www.atlas-geo.com

2016 South Eastern States Vapor Intrusion Symposium April 28th and 29th 2016

Crown Plaza Hotel Atlanta, Atlanta Georgia

http://www.epa.gov/oswer/vaporintrusion/documents/PVI-Guide-Final.pdf

http://www.epa.gov/oswer/vaporintrusion/documents/OSWER-Vapor-Intrusion-Technical-Guide-Final.pdf








Projects

Case Studies:

1. VI Investigation Conducted On Base and Off Base at the Former Fort Gillem Army Base

2. Environmental Justice VI Investigation in Central Mississippi3. Pending Environmental Justice Investigation in North Central

Mississippi4. Bank Portfolio Purchase in Wisconsin










Projects

Challenges/Discussion Topics:

Shear size and duration of projects Communication challenges (residents, media, regulators and

client) Samples storage/security issues Sample receiving and shipping challenges Laboratory capacity issues Geographic challenges









VI Investigation Conducted On Base and Off Base at the Former Fort

Gillem Army BaseChallenges Overview

Shear size and duration of projects• Project schedule required an 18 month commitment of resources• Hundreds of 6 liter and 1 liter summa canisters were required• Hundreds of trips to individual homes was necessary• Additional scope items (removal of household chemical products) was

added half way thru the project• Chemical product removal added a third day to each house that was

sampled (33% more time)• Poor weather conditions caused numerous scheduling changes• Changing security protocols on the base provided access challenges• Documenting, tracking and securing the necessary paperwork and

electronic documents was very challenging











Very High Profile• Intense local media coverage (ABC, CBS, Fox and NBC)• Daily updates being sent to the pentagon in Washington

DC• Non EPD interest within the State of Georgia government

Geographic Challenges• Two separate groundwater plumes potentially impacting

homes on the north side and the south side of the base boundary

• Due to homeowner availability, houses were not able to be scheduled in geographic blocks which resulted in numerous trips between the north and south side of the base.











Summa Canister Availability• The availability of enough summa canisters from the laboratory

occasionally impacted the sampling schedule• Scheduling of pickup and delivery of summa canisters added to

the scheduling challenges• Quality of the laboratory hardware varied depending on which

air laboratory within the large laboratory chain of labs provided the summa canisters

Summa Canister Security and Sample Handling• Finding a location to house, secure and process up to 100 6 liter

summa canisters at any one time• Transporting the summa canisters to the houses• Ensuring that the summa canisters were kept under the proper

chain of custody for the length of the project










ProjectsChallenges #1:

Shear size and duration of projects• All the following number are approximate estimates of the work performed

• 102 total houses sampled (83 sampled twice and 19 sampled once)• 115 separate mobilizations occurred to complete the project• 375 helium leak test were performed• 400 6 liter summa canisters were deployed for indoor air / ambient

air collection• 175 6 liter summa canisters were deployed for crawl space sample

collection• 50 sub-slab vapor implants were installed• 290 1 liter summa canisters were deployed for soil gas collection• 650 shut in tests were performed on the summa canisters and

sampling system










ProjectsShear size and duration of projects










Projects:Shear size and duration of projects










ProjectsShear size and duration of projects

SolutionYou must have a schedule and a plan

• Organization is MANDATORY• Consistent personnel is MANDATORY• Relationship with residents is critical










Projects


ProjectsSolution

You must have a schedule and a plan










Projects


ProjectsYou must have a schedule and a plan










Projects


ProjectsSolution:

You must have a schedule and a plan










Gillem Army BaseChallenge #2:

Summa Canister Availability• The availability of enough summa canisters from the laboratory

occasionally impacted the sampling schedule• Scheduling of pickup and delivery of summa canisters added to the

scheduling challenges• Quality of the laboratory hardware varied depending on which air

laboratory within the large laboratory chain of labs provided the summa canisters

Summa Canister Security and Sample Handling• Finding a location to house, secure and process up to 100 6 liter summa

canisters• Transporting the summa canisters to the houses• Ensuring that the summa canisters were kept under the proper chain of

custody for the length of the project










Projects


ProjectsChallenge #2:

Proper management of summa canisters• 865 total summa canisters were used for this project• All indoor air and ambient air samples were 6 liter summa

canisters• Soil gas summa canisters were 1 liter in volume










Projects


Projects

Solution:You must have a secure location to manage your equipment

Challenge #2:Proper management of summa canisters










Projects


ProjectsSolution:

You must have a secure place to store you equipment










Gillem Army BaseVery High Profile

• Intense local media coverage (ABC, CBS, Fox and NBC)• Daily updates being sent to the pentagon in Washington











Gillem Army BaseVery High Profile

• Intense local media coverage (ABC, CBS, Fox and NBC)• Daily updates being sent to the pentagon in Washington


Governor

Deal










Gillem Army BaseSolution:

Communication• USEPA Occupied Dwelling Questionnaire

• Access Agreement











Communication• Community Outreach encompasses many different avenues of

communication and is vital to getting your project off the ground, and subsequently keeping the participants updated with clear and open lines of communication.

• Newspaper announcements

• Neighborhood mailers or Fact Sheets

• Social Media

• Email

• Hotline Phone

• Door Knocking











Communication

• Once your study has begun and residents and homeowners have consented to indoor sampling of their homes, maintaining their trust with an open line of communication and project transparency is fundamental to continuation and completion of the project.

• In-home one-on-one meetings

• Direct phone communication

• Community Meetings

• Neighborhood mailers

• Social Media

• Direct Emails/Mass Emails











Communication

• Timely distribution of results demonstrates a sense of urgency and care to the participating residents of the study.

• Verbal notification of result receipt (telephone)

• Individual results provided to each participant (certified mail, or hand deliver)

• Community Meetings to discuss “big picture” results of study as a whole

• Library Repositories










Gillem Army BaseChallenge #4

Geographic Challenges• Two separate groundwater plumes potentially impacting

homes on the north side and the south side of the base boundary

• Due to homeowner availability, houses were not able to be scheduled in geographic blocks which resulted in numerous trips between the north and south side of the base.










Gillem Army BaseChallenges:#4

Geographic Challenges

Solution:Communication, Flexibility and Patience











Communication, Flexibility and Patience

Approximately 60 miles driven between

houses











Communication, Flexibility and Patience

Multiple daily updates given to office staff in order to change the schedule as needed










Gillem Army BaseConclusions:

1. Teamwork between consultant, regulators, responsible party and contractors is MANDATORY

2. Flexibility in allowing field staff to make adjustments to the schedule is key

3. Patience, Patience Patience….......









VI Investigation – Middle Mississippi on a Confidential Site

Challenges/Discussion Topics:

Three concerned parties involved – responsible party (RP), Attorney group (my client) and EPA

Communication challenges Quality control issues Laboratory capacity issues










xxxx

x










Site History

• History of spills and leaks on the plant property since the 1970’s

• Suspected dumping of hazardous material throughout the neighborhood and surrounding areas

• Documented releases chlorinated solvents and petroleum solvents in the soil and groundwater

• Barrier wall installed during the 1980’s to protect surface water

• No fishing or swimming signs posted in nearby creeks and streams

• 80+ homes adjacent to the plant property• Depth to groundwater is <5’










Site History• 8 houses have been tested multiple times• Indoor air, sub-slab air and ambient air have had

exceedances during the investigation• Large scale soil gas / sub-slab investigation planned for

the summer months










Challenge #1 Three concerned parties involved – responsible party (RP),

Attorney group (my client), EPA and MDEQ

• Different objectives• RP – limit investigation area, limit chemicals of concern, slow down the

pace of investigation and keep the RP as a client• Attorney group – expand the area of investigation to gain more clients for a

potential law suit, expand the chemicals of concern, investigate quickly so the money can be recouped and residents can be get a settlement

• EPA/MDEQ – Can only approve submitted work plans but can’t direct the investigation as long as the RP is paying the bill, is initiating their own investigation is battling a bad perception by the residents (not forcing any action for 20 + years).

Solution:None really found yet










Challenge #1 Three concerned parties involved – responsible party (RP),

Attorney group (my client), EPA and MDEQ

• Problems encountered• RP’s work plans never received in time to prep for field

work• Different methods of collecting sub-slab data• Not allowing true duplicate samples to be collected• Questionable QA/QC procedures in the field• EPA has not ability to force the RP to “play nice” in the

fieldSolution:

None really found yet










Challenge #2 Communication challenges

• Problems encountered• Homeowners have been in the dark about possible VI

issues for 20 years• Over 150 residents attended a recent “open” house

regarding the upcoming VI investigation• Work plans not being submitted and approved in time for

field work to be planned• Work plans not being consistent with EPA guidance• Residents are VERY suspicious of EPA and RP personnel

– no trust Solution:None really found yet










Challenge #3 & #4 Quality control issues Laboratory capacity issues

• Problems encountered• No agreement of the level of QA/QC needed for the

project due to inadequate detail in the work plans• Work plans not approved far enough in advance to give

the laboratory advance notice of the work planned• Not following industry standards when conducting the

scope of workSolution:

Documentation of QA/QC lapses, begging the laboratory of enough individually certified summa

canisters to complete the project









Pending VI Investigation in North Central Mississippi

Challenges:• Very large chlorinated solvent plume that underlays thousands of acres of

land• Potential VI receptors include a hospital, jail, school, day care and senior

citizen home• Groundwater plume is poorly defined, groundwater is <6’ bgs• RP does not seem to be very well versed in conducting VI investigations• Property values have been diminished(Walmart backed out of a deal)• Local government and residents are scared of the potential health effects

from VI• Gaining access to all the necessary property (fortunately the local

government is on board with the VI investigation and owns a larges part of the land. Six other landowners account for over 80% of the remaining land

Solution• Conduct a systematic vapor intrusion investigation working from the

groundwater up to the structure and then inside the structure if necessary• Develop relationships with local land owners and government officials.









Bank Portfolio Purchase in Wisconsin

Challenges:• 10 branch locations located across the entire state of

Wisconsin• Work had to be completed in one week• Project cost was a concern• Only allowed to work “bankers hours”, 9 am to 5 pm• Sub-slab implants need to equilibrate a minimum of 2 hours

(Wisconsin guideline) to 8 hours (EPA ORD research suggest)• Due to equilibration time, sites could not be drilled and

samples in the same day, this caused major logistical issues• Client decided to collect slab specific attenuation factor data

from each site so samples had to be shipped out each day for overnight delivery










Site Locations










Statics:• 1300 + miles in 6 days• 10 sites sampled and installed in 6 days• 28 sub-slab samples and 40 slab attenuation samples

shipped










Solutions:• The client did a great job of communicating with all bank branches• My client had a representative with with me at all times to facilitate access, etc.• The laboratory provided numerous shipping boxes, chain of custodies and pre-

paid shipping labels• Slab attenuation lab worked around the project schedule and was flexible with

sample receiving• Although work could only be performed during “banking hours”, drive time

before or after “banking hours” was used to get between locations

Challenges:• 10 branch locations located across the entire state of Wisconsin• Work had to be completed in one week• Only allowed to work “bankers hours”, 9 am to 5 pm• Due to equilibration time, sites could not be drilled and samples in the same day,

this caused major logistical issues










Projects

Jim Fineis P.G.Atlas Geo-Sampling Company

[email protected]

www.atlas-geo.com

Questions ?????



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