HomeMy WebLinkAboutSupporting Documentation - 04/02/2025
NATIONAL INSPECTION SERVICES
Commercial and Environmental Due Diligence
PO Box 270774 | Fort Collins, CO 80527 | (970) 482-1976 | e-mail: info@nationalinspection.net | www.nationalinspection.net
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DRAFT Materials Management Plan for the Former Lyric Building
300 East Mountain Avenue, Fort Collins, Colorado
1.0 Introduction National Inspection Services (NIS) has prepared this Materials Management Plan (MMP) on behalf of Mountain 300, LLC for use during redevelopment activities at the former Lyric Building located at 300 East Mountain Avenue in Fort Collins, Colorado (Site). The Site is located in the City of Fort Collins to the east of the intersection of East Mountain Avenue and Chestnut Street (Figure 1). The MMP describes the procedures for the handling, transport, and disposal of environmentally-regulated materials reasonably expected to be encountered during construction activities at the Site. The new building planned for the Site will consist of a two-story structure with a basement and will be utilized for commercial purposes. The first floor and basement levels will be integrated into the renovations of the adjacent Armory music theater, located at 314 East Mountain Avenue. The basement area will generally be configured for storage. The first floor of the building will consist of a bar, restrooms, offices, a green room and a core and shell build out potentially for a radio station. There are no current tenant plans for the second story of the building. The new building will have a basement floor that consists of an 18” thick mat slab foundation which will be poured at approximately 13.5’ below ground surface (bgs). The total depth to excavation is anticipated at 14 feet with a 17-foot excavation for the elevator pit area. Based on the geotechnical report (Terracon, 2024) it is anticipated that the building foundation will be within the groundwater table; groundwater was found at about 12 feet bgs during historical studies. The building is being designed to account for the groundwater elevations and includes engineering controls to prevent the infiltration of water into the basement. The engineering controls include a robust membrane that has been specified for the building; the membrane is specifically designed to reduce vapor intrusion from chemicals of concern including the dry cleaning solvents tetrachloroethene (PCE) and trichloroethene (TCE). Full specs for the vapor barrier are discussed in Section3.1. Environmental contamination, namely chlorinated volatile organic compounds (VOCs) existing at the Site is currently managed through the Colorado Department of Public Health and Environment (CDPHE) Corrective Action Program.
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1.1 Site Background According to Sanborn Fire Insurance Maps obtained for the Site, the former Lyric Building was constructed after 1891, at which point it was most likely occupied by a delivery service from around 1895 until the early 1900’s. An automotive service garage operated on the Site from approximately 1909 until 1943 before becoming part of the Paramont Laundry and Cleaners facility, which operated in the east-adjacent 314 E. Mountain Avenue building. The Paramont Laundry and Cleaners facility previously operated at 300-314 E. Mountain Avenue from approximately 1930 through 1994. The historical use of the two buildings included separate operations and purposes up to the combined use as Paramont Cleaners and had separate uses once the Paramont Cleaners ceased operations. The Lyric Building was attached on the west side of the Armory Building and was formerly part of Paramont Cleaners. Once the Paramont Cleaners ceased operations, the building was used as a cinema café beginning in 2007 until the cinema moved to a new location in 2017. This building consisted of 3,669 SF and was constructed in 1905 with a reported remodel in 2007. The Lyric Building was demolished in September 2024, and the Armory Building is currently utilized as a theater and music venue. The former Lyric Building property is the subject of this MMP, and redevelopment of the Lyric Building property is scheduled to begin in 2025. According to the 1909 Sanborn Fire Insurance Map, the Lyric Building operated as a garage and the Armory Building operated as an armory. The 1917 Sanborn Fire Insurance Map depicts an underground tank outside the southern portion of the buildings. Paramont reportedly first opened in the basement of the Armory Building in 1930 and the 1943-1961 Sanborn Fire Insurance Map depicts the Armory Building as “steam laundry”. A review of historical city directories identify the Lyric Building as Paramont Laundry from 1964 to 1992. A number of activities have occurred at the Site over the last year with respect to the investigation and cleanup of the Site. The methods and findings of these reports are discussed in detail in the Corrective Action Plan (NIS 2024a) and the Site Characterization Report (NIS 2024b). These activities include, but are not limited to, a Pre-CERCLA screening of the Site by CDPHE in 2021, a Phase II Environmental Site Assessment (ESA) conducted by NIS, indoor air testing at the Site and off-Site buildings, development and implementation of a Corrective Action Plan by NIS, an indoor air Risk Assessment completed by TRC Companies, Inc., demolition of the former Lyric Building, and completion of a site characterization by NIS. A Vapor Mitigation System (VMS) design was approved by the CDPHE for the Armory building on November 15, 2024, and is scheduled to be installed in the spring of 2025. A VMS design is currently being developed for the Site.
2.0 Purpose of the MMP The purpose of this MMP is to provide comprehensive procedures for managing the removal, relocation, and/or disposal of materials that are reasonably expected to be encountered during the redevelopment of the Site due to its historic use as a drycleaning facility and automotive repair shop. This MMP is being prepared for submittal to and approval by CDPHE within the CAP to obtain regulatory concurrence on the
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_______________________________________________________________________________________________________________________________ principal methods for soil management during redevelopment of the Site prior to commencing the project. This MMP will be provided to contractors involved with the redevelopment to be reviewed as part of the Site orientation prior to commencing soil disturbing activities. Based on the results of soil samples collected during the site characterization, soils that will be removed from the Site may be disposed of as hazardous waste or may be classified as non-hazardous waste through a contained-out determination made by CDPHE based on sampling results collected prior to and/or during soil excavation. Groundwater at the Site contains dry cleaning solvents at concentrations above hazardous waste criteria and will, therefore, be managed as hazardous waste until appropriately treated to acceptable concentrations. Because of the potential that the construction activities will encounter soils or materials that may pose an environmental concern, it is the responsibility of personnel conducting intrusive activities on the Site to adhere to this MMP in the event of the discovery of regulated waste. The personnel conducting intrusive activities will also follow applicable regulations, obtain proper permits, and work with the trained field personnel to identify potentially-impacted soil conditions. Based on the Site history, environmental concerns known to exist or reasonably expected to exist and discussed in this MMP include the following:
• Hazardous soils,
• Non-hazardous soils (as determined by CDPHE through a contained-out),
• Coal-based fill,
• Petroleum-contaminated soils (PCS),
• Underground Storage Tanks (USTs), and
• Regulated Asbestos-Contaminated Soil (RACS) Waste Each of these are discussed later in the document. The following section provides a brief synopsis of the known environmental conditions on the Site.
3.0 Existing Environmental Conditions Environmental assessments of soil, groundwater, soil vapor, and indoor air at the Site have been conducted by NIS in 2023 through 2025. Affected environmental media identified during the assessments is summarized below. Soil The footprint of the Site is approximately 3,935 square feet, or about one tenth of an acre. In an effort to characterize the soil that would be excavated during redevelopment, NIS advanced 11 soil borings to a depth of approximately 14 feet within the building footprint and collected photo-ionization detector (PID) data and soil samples for laboratory analytical testing. While the number of borings seems excessive, the goal of this investigation was to predetermine which soils can be managed a non-hazardous and which soils require management as hazardous. Soil samples in each of the borings were collected generally from three depth increments, 5 feet, 10 feet, and 14 feet below ground surface (bgs). PID readings were generally low, but
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_______________________________________________________________________________________________________________________________ there was a PID reading of 175.8 ppm in the lower portion of boring BH-12; a soil sample from this location did not indicate that soils were highly impacted, and this may be a result of groundwater influence at this location. Soils were sampled and tested for VOCs, including the dry cleaning solvent PCE. The results of soil sampling for each of the intervals that were sampled ranged from non-detect to 1.67 milligrams per kilogram (mg/kg) and are shown on Figure 2. These results are below the Environmental Protection Agency (EPA) Regional Screening Levels (RSLs) for residential (0.94 mg/kg) and industrial/commercial land use (6 mg/kg). The average PCE concentration for each depth interval is as follows:
• 5-foot interval – average of 11 samples was less than 0.05 mg/kg PCE
• 10-foot interval –average of 10 samples was less than 0.2 mg/kg
• 14-foot interval – average of 11 samples was less than 0.3 mg/kg Groundwater NIS installed five off-Site permanent groundwater monitoring wells and three temporary monitoring wells on-Site. As part of the site characterization, NIS conducted one groundwater monitoring event, during which samples were collected from each of these wells for analysis of VOCs. The groundwater results indicated that each of the wells, with the exception of upgradient well PMW-1R, was impacted with concentrations of PCE ranging from 92 micrograms per liter (µg/L) to as high as 467395 µg/L, above the Colorado Groundwater Standard (CGS) of 17 µg/L. Soil Vapor and Indoor Air Prior to building demolition, NIS collected three sub-slab soil vapor samples and analyzed the samples for VOCs. The soil vapor samples detected concentrations of PCE, TCE, and chloroform above EPA Residential RSLs. Benzene, ethylbenzene, and methylene chloride were detected at concentrations above the EPA Residential and Industrial RSLs. An indoor air sample collected within the building prior to demolition detected PCE at a concentration above the EPA Residential RSL. Coal-Based Fill An area of coal-based fill was identified below the building during the Phase II ESA; the fill appears to be contained in a sub-slab area with a concrete floor. The coal-based fill has been sampled a number of times and analyzed for VOCs, toxicity characteristic leaching procedure (TCLP) semi-volatile organic compounds (SVOCs), and TCLP Resource Conservation and Recovery Act (RCRA) TCLP metals. Analytical results of the coal-based fill detected concentrations of PCE above the EPA Residential RSL. SVOCs and RCRA 8 metals were not detected in the TCLP analyses above laboratory reporting limits.
4.0 Key Parties and Responsibilities It will be the responsibility of Mountain 300, LLC and their contractors to provide personnel qualified to follow and implement this MMP including, but not limited to, material sampling, selection of analytical
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_______________________________________________________________________________________________________________________________ parameters, data evaluation, and decisions regarding final disposition of displaced material. The oversight personnel outlined in Section 4.1 below are recommended to be involved when all intrusive activities (see 4.1) are conducted on the Property.
4.1 Oversight Personnel Mountain 300, LLC will provide trained Oversight Personnel (OP) during the planned construction project. An OP will be present for all intrusive activities such as the installation of piers/caissons, the installation of utilities, and excavations for the building foundation and slab. Once this initial construction has been accomplished, the OP will not perform oversight of follow-up intrusive activities such as the installation of curbs and gutters, certain landscaping elements, and lighting unless the OP determines that such activities require oversight. The OP will also provide training to the excavation contractors on the correct implementation of the MMP (awareness training) and will be on call (prepared to be at the Site) if any environmental or unusual conditions are encountered during construction activities that do not require oversight. The intention of these activities by the OP is to ensure that environmental discoveries will be managed in accordance with this MMP. Qualifications for the OP include:
• Trained in proper sample collection methods and experience in identifying, characterizing, and managing regulated and hazardous waste;
• Completed the 40 hour Hazardous Waste Operations and Emergency Response (HAZWOPER), and eight-hour Occupational Safety and Health Administration (OSHA) Supervisory training;
• Be a Certified Asbestos Building Inspector (CABI) trained and certified in accordance with CDPHE Air Quality Control Commission (AQCC) Regulation 8 (5 CCR 1001-10, Part B) (CDPHE, 2008) and having a minimum of 40 verifiable hours of on the job "asbestos in soils" experience on a minimum of three different 'asbestos in soils' projects, conducted under either AQCC Regulation No. 8 or Section 5.5 of the Regulations Pertaining to Solid Waste Sites and Facilities (6 CCR 1007-2, Part 1) (CDPHE, 2021). If a CABI is not present, the trained personnel may be a Qualified Project Monitor as defined by the Solid Waste Regulation, Section 5.5: Asbestos Contaminated Soil (6 CCR 1007-2 Part 1 - Regulation Pertaining to Solid Waste Sites and Facilities). The OP's responsibilities include:
• Performing field screening of soils in adherence to this MMP;
• Completing necessary sample collection to characterize potential contaminants of concern;
• Completing daily logs, when on-site, thoroughly detailing site activities;
• Tracking the types of wastes and contaminated soils encountered; and
• Verifying and documenting adherence to this MMP.
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5.0 Surface Water Control Depending on the planned area of disturbance, storm water permits and a Storm Water Management Plan (SWMP) may be required in accordance with the Colorado Discharge Permit System (CDPS) permit for storm water discharges associated with construction, and City of Fort Collins or Larimer County construction storm water permitting requirements prior to the initiation of surface disturbing activities. It is the responsibility of the Contractor to verify if the scope of the project requires storm water permits or development of a SWMP. Although not all projects will require a storm water permit or SWMP, the following guidelines and best management practices shall be followed during all surface, subsurface, and construction activities minimize cross-contamination by placing excavated wastes/soil on impermeable liner.
• Cover temporarily stockpiled materials with plastic sheeting or liner to prevent contact by precipitation;
• Establish run-on controls to divert storm water from contacting stockpiled waste materials or entering open excavations;
• Provide run-off controls to minimize the spread of contamination from stockpiled waste materials;
• Segregate potentially-impacted storm water from un-impacted storm water; and, characterize and properly dispose of storm water that has been contaminated with chemicals of concern (COCs) above regulatory standards. In addition, the Contractor using the MMP should be aware of and implement the requirements of the Drainage and Erosion Control Report for the Site.
6.0 Materials Management During Intrusive Activities Based on the Site history and environmental assessments, environmental concerns known to exist or reasonably expected to exist and discussed in this MMP include the following:
• Hazardous soils,
• Non-hazardous soils (as determined by CDPHE through a contained-out),
• Coal-based fill,
• Petroleum-contaminated soils (PCS),
• Underground Storage Tanks (USTs),
• Other hazardous wastes, and
• Regulated Asbestos-Contaminated Soil (RACS) Waste
6.1 Construction Dewatering During redevelopment of the Site, dewatering of the building excavation may be required to place the sub-slab fill and the basement floor slab and elevator shaft. It is anticipated that the dewatering system will effectively remove water from the bedrock within the building envelope and will capture some groundwater that is outside of the building excavation. The water that is collected will be treated prior to discharge and monitored in accordance with a discharge permit that will be obtained from the Colorado Discharge Permit System (CDPS).
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6.2 Fugitive Dust Fugitive dust generation is expected to be minimal during redevelopment due to the small size of the Site and minimal transport of soil during Site redevelopment activities. The Contractor will be responsible for controlling dust and particulate matter originating from winds, vehicular traffic, and operational equipment. Chemical dust suppressants, water or both may be used as appropriate to minimize the amount of dust generated and to maintain visible fugitive dust levels below 20% opacity in compliance with 5 CCR 1001-3, AQCC Regulations (CDPHE, 2012B). Dust control practices that may be used to control air emissions and provide dust suppression at the Site include the following: • Cover inactive exposed faces of material with geomembrane or soil, • Seal the exposed soil by moisture conditioning and compacting, • Minimize the distance waste will be moved in connection with excavation and loading, • Minimize drop heights when dumping or transferring materials, • Treat surfaces with water spray, foam spray, hydro-mulch spray, or crusting agents, • Reduce vehicle speeds, and • Install additional fencing or other engineering controls to block wind. Operations will be suspended during high wind events, defined as sustained winds of forty miles per hour (40 MPH) or greater, or gusts of fifty-five miles per hour (55 MPH) or greater, expected to persist for one hour or longer, as defined by the National Weather Service. When the conditions meet any of the shutdown requirements, the Order for shutdown will be executed. Earth moving activities may resume as criteria are met. Under Colorado air quality regulations, land development refers to all land clearing activities, including but not limited to land preparation such as excavating or grading, for residential, commercial, or industrial development, or O&G exploration and production. Land development activities release fugitive dust, a pollutant regulated by the Air Pollution Control Division at CDPHE. Small land development activities (land development activities that are less than 25 contiguous acres and less than 6 months in duration) are not subject to the same reporting and permitting requirements as large land development activities and do not need to report air emissions to the CDPHE Air Pollution Control Division. For these projects, operators must use appropriate control measures to minimize the release of fugitive dust from the Site (CDPHE, 2014B).
6.3 Air Monitoring Air quality monitoring will be conducted to assess the potential for VOCs during subsurface disturbance activities, specifically within the breathing zone of the immediate work area and on the downgradient wind direction from the intrusive activity. Based on previous sub-slab soil vapor and indoor air sampling, PCE, TCE, cis-1,2-DCE, benzene, ethylbenzene, chloroform, and methylene chloride have been detected above the residential and/or industrial EPA RSLs for these VOC constituents in soil vapor and indoor air samples at the Site.
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_______________________________________________________________________________________________________________________________ Real-time air quality monitoring with a portable photo-ionization detector (PID) during the intrusive activity will provide important air quality information to determine if COCs are present at harmful concentrations in the work area. Action levels for concentrations of VOCs within the work area are provided in the project Health & Safety Plan (HASP). The results of air monitoring should be evaluated to assess if the PPE worn by site workers is adequate to prevent exposures to COCs.
6.4 Equipment Decontamination Prior to demobilization from the Site, equipment used for intrusive activities and material handling of impacted soil will be decontaminated at a decontamination area constructed by the Contractor. Decontamination will be conducted in accordance with a CDPHE-approved decontamination plan. At a minimum, the decontamination plan or procedures should address the following: • Methods to minimize the spread of contamination, • Types of decontamination wastes and affected equipment, • Decontamination station locations and supplies used, • Methods for collecting, containing, characterizing, and disposing of decontamination wastes, and • PPE worn by workers
6.5 Soil Excavation Soil excavation will occur during redevelopment to the Site boundaries and to estimated depths of 14 to 17 feet bgs. Protocols for managing environmental contaminants located in the excavated soil are described below.
6.5.1 Solvent-Contaminated Soil Soil impacted by chlorinated solvents, namely PCE and TCE, has been documented at the Site. Based on environmental assessments, PCE concentrations in subsurface soil are below EPA Residential and Industrial RSLs and Land Disposal Restrictions (LDRs) and may be disposed of as non-hazardous waste if a contained-out determination is approved by CDPHE. Areas of solvent-impacted soil at hazardous concentrations may be encountered, particularly at the base of the unconsolidated soil and in bedrock. During subsurface excavation, the OP will collect headspace field screening samples to assess for elevated solvent concentrations in excavated soil at a minimum rate of one per every 100 cubic yards. In the headspace technique, soil will be placed in a “zip-lock” bag, which is sealed and placed in a warm area to promote volatilization. After a period of time, the PID is inserted into the headspace of the bag, and a reading is obtained. Soil exhibiting VOC concentrations greater than 50 parts per million (ppm) will be segregated onto polyethylene sheeting for analytical disposal confirmation sampling. It is expected that a total of about 4000 cubic yards of soil will be excavated. One 5-point composite sample will be collected per every 200 cubic yards of segregated soil and will be submitted to a laboratory for analysis of:
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• TCLP VOCs by EPA Method 8260 TCLP soil samples exhibiting concentrations of solvents above their respective toxicity characteristic (0.7 mg/L for PCE, 0.5 mg/L for TCE, and 0.2 mg/L for vinyl chloride) will be disposed of as hazardous waste at a Subtitle C landfill. The segregated soil stockpile will be covered with polyethylene sheeting and bermed along the sides to prevent contact with stormwater or placed in 40 CY lined roll-off containers. A contained-out determination will be requested from CDPHE for disposal of soil exhibiting concentrations of chlorinated solvents below their respective toxicity characteristics. If a contained-out determination is approved by CDPHE, the soil may be disposed of as a non-hazardous waste at a Subtitle D landfill facility.
6.5.2 Petroleum-Contaminated Soil Petroleum-contaminated soil (PCS) may be present due to the past use of the Site as an automotive repair shop. Identification of PCS during construction activities will be determined through field screening (staining, odors and/or elevated PID readings). To characterize any PCS waste, one 5-point composite sample will be collected and analyzed for VOCs, RCRA 8 metals-TCLP, and polychlorinated biphenyls (PCBs) for up to 500 cubic yards (or as dictated by the landfill facility). Subsequent samples will be collected for each 100 cubic yards of PCS excavated. If the waste is determined to be hazardous based on analytical results, refer to Section 6.7 - Hazardous Waste. PCS shall be managed in accordance with the CDPHE Solid Waste regulations. These regulations allow PCS to be managed by several methods including: • Disposal at an approved landfill, • Recycling by incorporation into an asphalt batch plant or thermal treatment, • On-site treatment and reuse, or • Off-site reuse. Site-specific guidance for incorporation into an asphalt batch plant, thermal treatment, or other proposed management methods may be received by contacting the CDPHE HMWMD.
6.6 Coal-Based Fill Analytical results for the contained coal-based fill identified below the building slab will be analyzed to determine if the material meets LDRs. The coal-based fill will be removed from the containment using a vacuum truck or alternative method. If the analytical results for the coal-based fill indicate that it is a hazardous waste, the material will be disposed of at a licensed Subtitle C facility in accordance with the hazardous waste regulations. If the analytical results for the coal-based fill are below the hazardous
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_______________________________________________________________________________________________________________________________ waste criteria, a contained-out request will be made to CDPHE for disposal of the material as a solid waste at a Subtitle D landfill facility.
6.7 Underground Storage Tanks Underground storage tanks (USTs) are potentially located at and in the vicinity of the Site based on the historical use of the Site as an automotive service from approximately 1909 until 1943 and a 1917 Sanborn Fire Insurance Map depicting an underground tank outside the southern portion of the Site. USTs regulated by OPS are not present at the Site, and the historical use and contents of potential USTs that may be located during soil disturbing activities is unknown. Due to the unknown contents of USTs identified at or in the vicinity of the Site, UST contents will be characterized using the following analyses:
• VOCs by EPA Method 8260,
• RCRA 8 metals-TCLP by EPA Method 6010, and
• PCBs by EPA Method 8082 If encountered, USTs will be removed in accordance with Colorado Department of Labor and Employment, Oil and Public Safety (OPS) Storage Tank Regulations (7 C.C.R. 1101-14). If analysis of the UST contents indicates that the contents include a hazardous waste, waste will be handled in accordance with the CDPHE Hazardous Waste Regulations (6 CCR 1007-3) as defined in Section 5.7.
6.7 Hazardous Waste Hazardous waste will be handled in accordance with the CDPHE Hazardous Waste Regulations (6 CCR 1007-3). F001 and F002 listed hazardous wastes (dry cleaning solvents) have been identified in Site soil and groundwater and are being managed under a CDPHE CAP. If additional unanticipated suspect hazardous waste is identified during intrusive activities, the project manager will be notified immediately. If a determination is made that the waste may be hazardous, the hazardous waste will be segregated, overpacked, and staged on-Site, unless deemed unsafe to do so. Following staging of the waste, a characterization and management plan must be submitted to CDPHE for approval. The characterization and management plan shall provide a description of the waste and clarify the type and frequency of representative characterization samples to be collected, the estimated volume of material present, and other pertinent information for determining proper handling of the waste. Hazardous wastes will be characterized, profiled, and transported off-site to a licensed Subtitle C facility. In Colorado, the Clean Harbors Deer Trail Hazardous Waste Facility near Last Chance, Colorado accepts certain types of hazardous wastes. Table 1 provides details for the packaging, transportation, and disposal of waste streams. Hazard categorization (hazcat) kits may be used to pre-screen waste for hazardous characteristics. The type of hazcat kit, standard operating procedures, and
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_______________________________________________________________________________________________________________________________ qualifications of personnel using the kit must first be approved through the CDPHE project manager prior to use. Solid wastes are considered nonhazardous unless they exhibit a hazardous "characteristic" (toxicity, reactivity, ignitability, or corrosivity), or have been specifically listed as hazardous waste by the USEPA (known as a "listed waste"), as provided in Table 2. Regulatory criteria for hazardous waste based on TCLP concentrations are detailed in Table 3. Listed wastes are specific wastes, or are mixtures or wastes derived from those listed wastes. These materials may be from nonspecific sources such as spent solvents or may be wastes from specific sources or wastes from discarded chemical products. If hazardous wastes are discovered at the Site, these materials will be packaged, manifested, characterized, transported, and disposed of in compliance with Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA)/RCRA and DOT regulations. All hazardous waste shipped from the Site must be packaged in accordance with DOT regulations per 49 CFR Part 173, 49 CFR Part 178 (DOT, 2015), 49 CFR Part 179 (DOT, 2011), and 6 CCR 1007-3, Sections 262.30 through 262.33 (CDPHE, 2016B); hazardous waste accumulation containers will be labeled as "Hazardous Waste." Regulations concerning hazardous waste containers are provided in 6 CCR 1007-3, Section 265 Subpart I. In accordance with 6 CCR 1007-3, Section 262, hazardous waste manifests must note the USEPA ID number of the generator, all transporters of the waste, and the ultimate disposal facility. Regulations require generators to test the waste, or use process knowledge of the waste, to determine if the waste is restricted from land disposal, and certify that the wastes meet the treatment standards described in 6 CCR 1007-3, Section 268, Subpart D. RCRA-permitted hazardous waste disposal facilities located in the region include: • Clean Harbors Environmental Services, Inc. Incinerator in Kimball, Nebraska (308-235-4012) – This hazardous waste storage and treatment facility includes a thermal oxidation incinerator and an on-site incinerator ash monofill. • Clean Harbors Deer Trail, LLC, (also known as, Highway 36 Landfill). Adams County, Colorado (970-386-2293) -This hazardous waste treatment, storage, and disposal facility has container storage, tank storage, a treatment building, and seven double-lined disposal cells.
6.8 Regulated Asbestos-Contaminated Soil Regulated asbestos-contaminated soil (RACS) has not been identified at the Site. If identified, a “Notification of regulated asbestos contaminated soil (RACS) disturbance” form will be submitted to CDPHE within 24 hours of RACS confirmation to: Briant.long@state.co.us RACS management should be handled in accordance with Section 5.5.7 of the CDPHE Regulations Pertaining to Solid Waste Sites and Facilities (6 CCR 1007-2, Part 1).
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7.0 Summary and Conclusions This MMP has been developed to detail procedures to be followed for managing environmental conditions that may be encountered during redevelopment of the Site. It is expected that the majority of environmental conditions will be associated with the removal of impacted soils and groundwater from the Site during soil excavation, dewatering, and the installation of caissons as part of the building structural support. This MMP requires that environmental oversight and testing be implemented during all of the intrusive activities at the Site, and that soil and groundwater that is environmentally impacted be managed and disposed of in accordance with the applicable regulations and industry practices. Mountain 300, LLC and their subcontractors will provide the necessary efforts and personnel to fully implement this MMP. If you have any questions or concerns, please contact us at (970) 482-1976 or noah@nationalinspection.net. Sincerely, Noah M. D’Antonio, President National Inspection Services Attachments: Attachment 1 – Figures Figure 1 – Site Location Figure 2 – Soil Sample Results Figure 3 – Groundwater Sample Results Attachment 2 – Tables Table 1 – Regulatory and Waste Profiling Requirements for Waste Categories Table 2 – Listed and Characteristic Hazardous Wastes Table 3 – TCLP Regulatory Concentrations for Hazardous Waste
Figure 1 – Site Location Map SCALE: 1” ~ 75 FEET
Former Lyric Building
300 E Mountain Ave.
Fort Collins, CO
National Inspection Services POB 270774 Fort Collins, CO 80527 Phone 970.482.1976
www.nationalinspection.net
Analyte Depth (ft) Analyte 5 5 10 Tetrachloroethene 9 14 14
Soil Characterization Map
Former Paramont Cleaners
300-314 East Mountain Avenue, Fort Collins, CO
Analyte Depth (ft)
4
Tetrachloroethene 10
14
BH13
Analyte Depth (ft)
5
Tetrachloroethene 10
5
10
13
0
Result
<0.01 mg/kg
<0.01 mg/kg •
0.558 mg/kg
Scale = 1 :480
40
Result
Result
80 ft
0 Soil Boring
6, Temporary Piezometer D Site Boundary*
Notes:
mg/kg • milligrams per kilogram
ND • No Detections
*Site boundary is approximate
t N
Disclaimer: Not a surveyed map. Every effort was made to ensure the
accuracy of the data provided and displayed. This map is intended ror
reference purposes only and should not be used as a survey instrument.
Figure 2
Datum: NAD83
Projection: StatePlane CO North
Created: Nov 24, 2024
Author: C VanWyngarden
Sources:
Google Earth Imagery (042323)
�
�� •r. ... .,. ...
Groundwater Detections Summary Scale = 1 :600
Former Paramont Cleaners 0 50 100 ft
300-314 East Mountain Avenue, Fort Collins, CO
•Groundwater Monitoring
Well6 Temporary Piezometer D Site Boundary*
Notes:
1,19/L • micrograms per liter
ND • Non-Detect
Bolded vaules indicate result was
detected above regulatory standards.
*Site boundary is approximate
t N
Disclaimer: Not a surveyed map. Every effort was made to ensure the
accuracy of the data provided and displayed. This map is intended ror
reference purposes only and should not be used as a survey instrument.
Figure 3
Datum: NAD83
Projection: StatePlane CO North
Created: Nov 24, 2024
Author: C VanWyngarden
Sources:
Google Earth Imagery (042323)
�
�� • .. ,.r ... .-•
Table 1 REGULATORY AND WASTE PROFILING REQUIREMENTS FOR WASTE CATEGORIES
Waste Category Packaging/Handling Labeling Transportation Waste Profiling Disposal
Friable Asbestos
Waste
Specific packaging is
required to minimize the risk
of releasing airborne fibers,
as detailed in Section 5.2.3.
The outermost layer of
any containers holding
friable asbestos must
be labeled as described
in Section 5.2.3.
DOT regulates friable
asbestos waste that
meets or exceeds the
reportable quantity of one
pound in one package
(see Section 5.2.3)
Certify that free liquids
and hazardous wastes
ere not present
Three Denver-area
landfills are authorized
to accept friable
asbestos waste
Nonfriable Asbestos
Waste
Prospective disposal
facilities should be
contacted prior to disposal
for any local/facility
requirements
Prospective disposal
facilities should be
contacted prior to
disposal for any
local/facility
requirements
DOT does not regulate
transportation of
nonfriable asbestos
waste
Certify that flee liquids
and hazardous wastes
are not present
Contact the MSW
landfill operator prior to
disposal
Nonhazardous
Liquid Waste
There are no special
packing/handling
requirements
Specific labeling is not
required for non-
hazardous liquid waste
Transportation
equipment must prevent
leakage and spillage
Certify that hazardous
waste regulatory levels
are not exceeded
There is presently only
one solid waste disposal
facility in Colorado
authorized to take liquid
waste or waste
containing free liquid
Infectious Waste
(See Note 1)
Common industry practice is
to use red bags for disposal
Receptacles containing
infectious must be
labeled with biohazard
symbol or with the
words “Infectious
Waste” at least one inch
high
Transportation of
infectious waste is
regulated by DOT (see
Section 5.4)
Certify that hazardous
wastes are not present
Properly labeled and
packaged infectious
waste may be disposed
of in a permitted solid
waste disposal facility
without treatment.
However, landfills must
be approved by their
local governing authority
and the CDPHE to
accept this type of
waste
Hazardous Waste In accordance with 49 CFR
Parts 173, 178, and 179;
and 6 CCR 1007-3,
Sections 262.30-262.33 and
Section 265 Subpart I;
containers in good condition
and compatible with waste
Hazardous waste
manifests must note the
USEPA ID number of
the generator, all
transporters of the
waste, and the disposal
facility (6 CCR 1007-3,
Section 262); label
containers as
hazardous waste
Transportation of
hazardous waste is
regulated by DOT per 49
CFR Parts 173, 178, and
179
Test the waste as
required to certify that
the waste meets the land
disposal standards
described in 6 CCR
1007-3, section 268,
Subpart D
Regional RCRA
hazardous waste
disposal facilities are
located in NE and OK
Waste Category Packaging/Handling Labeling Transportation Waste Profiling Disposal
PCB Waste Liquids and solids
containing >50 ppm PCBs
must be containerized,
stored, and transported
based on TSCA
requirements
Liquids and solids
containing >50 ppm
PCBs must be
containerized, stored,
and transported based
on TSCA requirements
Transportation of
hazardous waste is
regulated by DOT per 49
CFR Parts 173, 178, and
179
Test the waste as
required to certify that
the waste meets the land
disposal standards
described in 6 CCR
1007-3, Section 268,
Subpart D
Regional RCRA
hazardous waste
disposal facilities are
located in NE and OK
Petroleum
Contaminated Soil
MEW or hazardous waste
requirements apply,
depending on whether
TCLP lead and benzene
concentrations exceed
RCRA regulatory levels
MSW or hazardous
waste requirements
apply, depending on
whether TCLP lead and
benzene concentrations
exceed RCRA
regulatory levels
MSW or hazardous
waste requirements
apply, depending on
whether TCLP lead and
benzene concentrations
do not exceed RCRA
regulatory levels
Certify that free liquids
are not present and
verify that TCLP lead and
benzene concentrations
do not exceed RCRA
hazardous waste
regulatory levels
Dispose as a hazardous
waste if TCLP lead and
benzene concentrations
exceed RCRA
regulatory levels;
otherwise, dispose at
the facility approved for
PCS disposal
Notes: I. Unless there is some indication that infectious substances ere present, bandages and other medical wastes that are excavated from the landfills will be treated as MSW.
Table 2 LISTED AND CHARACTERISTIC HAZARDOUS WASTES
Listed Wastes (6 CCR 1007-3, Section 261, subpart D)
Hazardous Waste Type Waste Description
F Listed Wastes from non-specific sources such as spent solvents or wastewater
treatment sludges from electroplating.
K Listed Wastes from a specific source, for example, an untreated wastewater from a
specific industrial process listed in the regulations such as K002 which is
wastewater treatment sludge from the production of chrome yellow and orange
pigments.
P and U Listed Off-specification or discarded commercial chemical products or,
•any residue remaining in a container that held commercial chemical
products in the P or U listing or,
•any residue or contaminated media resulting from the cleanup of a spill
of a commercial chemical product in the P or U listing.
Listed Wastes (6 CCR 1007-3, Section 261, subpart C)
Hazardous Waste
Type
Waste Description
Ignitable EPA hazardous waste number D001
•It is easily combustible or flammable,
•It is a liquid with a flash point less than 140°F,
•It is not a liquid but is capable of causing a fire that bums so vigorously that it
creates a hazard,
•It is an ignitable compressed gas or,
•It is an oxidizer as defined by the United States Department of Transportation.
Corrosive
EPA hazardous waste number D002
•It is a liquid and dissolves steel or,
•It is a liquid and has a pH less than 2 or greater than 12.5.
Reactive EPA hazardous waste number D003
•It is unstable,
•It is explosive,
•It undergoes rapid or violent chemical reaction,
•It produces toxic gases when mixed with water or other materials or,
•It is a cyanide or sulfide bearing waste which, when exposed to pH conditions
between 2 and 12.5, can generate toxic gases, vapors or fumes. Waste meets
this definition if it:
o Contains a releasable sulfide concentration of 500 mg H2S/kg or,
o A releasable cyanide concentration of 250 mg HCN/kg.
Toxic (see Table 4) EPA hazardous waste number D004 through D043
•It is a metal, pesticide, herbicide, or organic chemical at high enough
concentrations that it could be harmful or toxic if released into groundwater.
Reference: CDPHE, 2001
Table 3 TCLP REGULATORY CONCENTRATIONS FOR HAZARDOUS WASTE
D004 Arsenic 5.0
D005 Barium 100.0
D006 Cadmium 1.0
D007 Chromium 5.0
D008 Lead 5.0
D009 Mercury 0.2
D010 Selenium 1.0
Metals
D011 Silver 5.0
D012 Endrin 0.02
D013 Lindane 0.4
D014 Methoxychlor 10.0
D015 Toxaphene 0.5
D016 2,4-D 10.0
D017 2,4,5-TP (Silvex) 1.0
D020 Chlordane 0.03
Pesticides/Herbicides
D031 Heptachlor 0.008
D018 Benzene 0.5
D019 Carbon tetrachloride 0.5
D021 Chlorobanzene 100.0
D022 Chloroform 6.0
D028 1,2-Dichloroethane 0.5
D029 I, 1-Dichloroethylene 0.7
D035 Methylethylketone 200.0
D039 Tetrachloroethylene 0.7
D040 Trichloroethylene 0.5
Volatile Organic
Compounds
D043 Vinyl chloride 0.2
D027 1,4-Dichlorobenzene 7.5
D030 2,4-Dinitrotoluene 0.13
D032 Hexachlorobenzenc 0.13
D033 Hexachlorobutadiene 0.5
D034 Hexachloroethane 3.0
D036 Nitrobenzene 2.0
Base Neutrals
D038 Pyridine 5.0
D023 o-Cresol 200.0
D024 m-Cresol 200.0
D025 p-Cresol 200.0
D037 Pentachlorophenol 100.0
D041 2,4,5 -
Trichlorophenol
400.0
Acids
D042 2,4,6-Trichlorophenol 2.0
Reference: 6 CCR 1007-3, Section 261, Subpart C