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  • CES Environmental Services

    Voluntary Cleanup Program Application

    Project No. 4006 May 2015

    Attachment 5 Phase II Environmental Site Assessment Holiday Place Townhome Lots (2011)

  • Phase II Environmental Site Assessment Holiday Place Townhome Lots

    East of Calhoun Road and South of Griggs Road Houston, Harris County, Texas

    Wells Fargo Ref. No.: WF-HOU-10-011959-02-1 TGE Project No.: R10114.01

    Prepared For:

    Wells Fargo RETECHS c/o Ms. Jennifer Farley 123 N. Wacker Drive

    Chicago, Illinois 60606

    Prepared By:

    TGE Resources, Inc. 6120 West by Northwest Boulevard, Suite 100

    Houston, Texas 77040

    Phone: 713-744-5800 Fax 713-744-5888

    January 4, 2011

  • R10114.01 Phase II ESA Holiday Place Townhome Lots

    TABLE OF CONTENTS EXECUTIVE SUMMARY .................................................................................................................................... i 1.0 INTRODUCTION ......................................................................................................................................... 1 2.0 SUBSURFACE CONDITIONS ................................................................................................................... 3 3.0 SOIL BORING AND WELL SCREEN INSTALLATION ............................................................................. 4 4.0 SAMPLING AND LABORATORY ANALYSIS .......................................................................................... 5

    4.1 Cleanup Goals ............................................................................................................................... 54.2 Soil Sample Collection and Analysis .......................................................................................... 64.3 Groundwater Sample Collection and Analysis .......................................................................... 74.4 Project Deviations ......................................................................................................................... 84.5 Laboratory Data Validation .......................................................................................................... 9

    5.0 WATER GAUGING AND POTENTIOMETRIC SURFACE DATA ........................................................... 10 6.0 FINDINGS ................................................................................................................................................. 11

    6.1 Findings ....................................................................................................................................... 116.2 Recommendations ...................................................................................................................... 12

    7.0 QUALIFICATIONS ............................................................................................................................... 13 8.0 REFERENCES .......................................................................................................................................... 14 FIGURES

    Figure 1 - Site Location Map Figure 2 - Site Map Figure 3 - Groundwater Potentiometric Surface Map

    TABLES

    Table 1 - Soil Analytical Results Table 2 - Groundwater Analytical Results Table 3 - Groundwater Elevation Data

    APPENDICES Appendix A - Photographic Documentation Appendix B - Soil Boring Logs Appendix C - Laboratory Analytical Report

  • i R10114.01 Phase II ESA Holiday Place Townhome Lots

    EXECUTIVE SUMMARY TGE Resources, Inc., (TGE) has completed a Limited Phase II Environmental Site Assessment (ESA) at the Holiday Place Townhome Lots located east of Calhoun Road and south of Griggs Road in Houston, Harris County, Texas, hereinafter referred to as the "Site" or subject property, in general compliance with American Society of Testing Materials (ASTM) Standard Guide for Environmental Site Assessments: Phase II Site Assessment Process (E 1903-97), Re-approved 2002. This assessment was performed in an effort to preliminarily characterize Site soil and groundwater in the presence of recognized environmental conditions (RECs) associated with the subject property consistent with ASTM guidance. It is TGEs understanding that Wells Fargo RETECHS requires knowledge of the environmental status of the subject property prior to pending property foreclosure. According to an October 2010, Phase I ESA prepared by Ninyo & Moore for the benefit of Wells Fargo Bank, the subject property is comprised of approximately 6.40 acres of land. The subject property was residentially developed and platted with 120 lots. Per the Ninyo & Moore Phase I ESA, review of historical resources indicated that Site was used as a storage area from as early as 1944 to approximately 1979. Between 1989 to 2006 the site was graded and a parking lot was developed on the eastern portion of the site. By 2010, the site was vacant, graded, residential lots within the Holiday Place Townhomes subdivision. Residential development commenced east and west of the site in approximately 1944. Commercial development commenced north of the site as early as 1944, south of the site in approximately 1953, and east of the site in approximately 1973. According to the Ninyo & Moore Phase I ESA, adjoining property east, which is occupied by CES Environmental Services, Inc. (CES), has operated as a hazardous, non-hazardous, recyclable, municipal and universal material removal and transport company since at least 1973. According to regulatory database information, CES is listed as a Comprehensive Environmental Response, Compensation and Liability Information System (CERCLIS), a RCRA-Large Quantity Generator (LQG) and an underground petroleum storage tanks (PSTs) facility. Per the October, 2010 Ninyo & Moore Phase I ESA, CES was considered an off-Site REC due to an August 2009 explosion incident that resulted in a possible release of methanol or other hazardous materials stored at the facility, as well as historical use and the presence of PSTs in close proximity to the Site. Ninyo & Moore reported that a 1950 Sanborn Fire Insurance Map, reviewed for the Phase I ESA, depicted the subject property as occupied by a piping yard. The referenced Sanborn Fire Insurance Map and/or historical aerial photographs were not provided within the Phase I ESA. However, TGE obtained aerial photographs dated 1953, 1969, 1978 and 1989 from the Texas Natural Resource Information System (TNRIS), a division of the Texas Water Development Board (TWDB) Historical Aerial Photograph Database. Based on review of historical aerial photographs, it appears that the subject property was part of a larger tract of land (adjoining property east, currently occupied by CES) that operated as a trucking/transport facility from at least 1940 through 2000. Based upon Findings from the October, 2010 Phase I ESA of the Site prepared by Ninyo & Moore, the following REC was identified in connection with the subject property:

    "The property located at 4904 Griggs Road, adjacent to the eastern boundary of the site, is considered an off-Site REC. Ninyo & Moore considers it possible that methanol or other hazardous materials stored at this facility may have been released to the subsurface during the aforementioned explosion incident, or in the past prior to this explosion incident and Ninyo & Moore considers it possible the historical activities conducted at this adjacent property have impacted the environmental integrity of the site. Additionally, based on the lack of information regarding the USTs at this adjacent property and on the close proximity of the USTs at this facility to the site, Ninyo & Moore considers these USTs a REC for the site.

  • ii R10114.01 Phase II ESA Holiday Place Townhome Lots

    Based upon Clients desire to preliminarily characterize Site soil and groundwater prior to pending property foreclosure, TGE installed three temporary screened boreholes (TSB-1 through TSB-3) at the site. The three temporary screened boreholes were completed within the limits of the subject property to depths of 36 feet below grade (fbg). Temporary screened borehole locations were advanced/installed at the Site at the following locations, given associated rational:

    TSB-1 centrally located within the limits of the subject property near an on-Site material storage area (as per historical aerial photographs);

    TSB-2 and TSB-3 along the eastern perimeter of the subject property proximal of CES (to assess for potential impact from off-Site property).

    Following TGEs assessment efforts, and related sample analyses, analytical data was obtained from soil and groundwater samples pursuant to this investigation. Likewise, TGE determined at the time of this investigation that depths to static groundwater beneath the Site ranged from 23.90 fbg to 25.11 fbg; the calculated groundwater flow direction at the time of groundwater sampling was toward the east. The following summary of material results/findings is presented below for Client review. A full reporting and account of specific project efforts and findings are provided in detail within the attached document.

    Soil samples collected from boreholes TSB-1 through TSB-3 were reported by the analytical laboratory to not contain volatile organic compounds (VOCs) or total petroleum hydrocarbons (TPH) in excess of laboratory detection limits, or if detected, concentrations were below their respective TCEQ residential assessment levels.

    Soil samples collected from boreholes TSB-1 through TSB-3 were reported by the analytical laboratory to not contain RCRA-8 metals in excess of limits of laboratory quantitation, or if detected, concentrations were below their respective TCEQ residential assessment levels with the exception of lead. Soil samples collected from TSB-1 through TSB-3 were reported to contain lead at concentrations ranging from 23.7 milligrams per kilogram (mg/kg) to 61.2 mg/kg, which slightly exceed the Texas Specific Background Concentration (TSBC) of 15.0 mg/kg. However, such concentrations are well below the TCEQ Texas Risk Reduction Program (TRRP) Protective Concentration Level (PCL) of 500 mg/kg for exposure to lead in surface soils. Given exceedances of the residential assessment level for lead, TGE referred to the TRRP PCL equation for the soil-to-groundwater pathway (GWSoilIng). An equation was used to calculate Site-specific levels for lead in soil that is considered protective of groundwater in lieu of the TSBC or TRRP Tier 1 PCL.

    Based on Site-specific conditions, a Tier 2 GWSoilIng PCL of 274.725 mg/kg for lead can be established in soil at the Site. The previously detected maximum concentration of 61.2 mg/kg for lead in soil sample TSB-1 (2-3) is well below the calculated Tier 2 PCL for the Site. As such, the reported lead value is not believed representative of an environmental condition in connection with the Site and may be screened from further response actions.

    Groundwater samples collected from boreholes TSB-1 through TSB-3 were reported by the analytical laboratory to not contain VOCs or TPH in excess of laboratory detection limits, or if detected, concentrations were below their respective TCEQ residential assessment levels.

  • iii R10114.01 Phase II ESA Holiday Place Townhome Lots

    Groundwater analytical results from temporary screened boreholes TSB-1 through TSB-3 were reported by the analytical laboratory to not contain RCRA-8 metals in excess of laboratory detection limits, or if detected, concentrations were below their respective TCEQ residential assessment levels with the exception of lead and chromium. Groundwater samples collected from TSB-2 were found to contain lead at a concentration of 0.025 milligrams per liter (mg/L), which is above the TRRP residential assessment level (based on the Tier 1 Residential PCL) of 0.015 mg/L. Additionally, the groundwater sample collected from TSB-2 was found to contain chromium at a concentration of 0.116 mg/L which is slightly above the TRRP residential assessment level of 0.10 mg/L. Due to exceedance of TCEQ assessment levels for lead and chromium, the potential of such elevated values being a result of high naturally occurring suspended sediment in unfiltered groundwater samples was believed of issue. However, due to the very limited availability of groundwater recovered from the borehole, TSB-2, no filtered groundwater sample could be collected for confirmation analyses.

    It should be noted that while soil sample analyses reported concentrations of RCRA-8 metals lead and chromium in excess of current TRRP residential assessment levels, per TRRP guidance document TRRP-10, titled Selecting Target Chemicals of Concern, professional judgment may be used to advance a position that further consideration (and assessment) of these analytes with respect to the subject investigation is not indicated. Specifically, based on findings provided within the foregoing Phase I ESA, lead and chromium are not interpreted as target COCs with respect to current/historic Site use as a retail gasoline station. Additionally, groundwater gradient was determined to be toward (and not from) the property of concern (CES) located adjacent east. Furthermore, lead and chromium concentrations detected within groundwater collected from boring TSB-2 are more likely than not the result of naturally present, high suspended sediment in the limited groundwater available in the first water bearing unit at the time of this investigation. Given that groundwater collected from borings TSB-1 and TSB-3 were below their respective TCEQ residential assessment levels for RCRA-8 metals, detections of the RCRA-8 metals lead and chromium within boring TSB-2 are considered representative of naturally-occurring conditions, and not indicated per Site knowledge to have resulted from human activity at the project location. As such, these metals may be screened from further consideration for purposes of TRRP, per 30 TAC 350.71(k)(2)(E). Such screening of COCs should be considered internally to determine whether further corrective action activity (or follow-up characterization assessment) at the Site would be warranted. However, agency response would require preparation and submittal of a complete Affected Property Assessment Report (APAR), as specified in 30 TAC 350.51 to solicit state agency concurrence with this professional opinion.

    Recommendation Based on results of this Site characterization effort, and within stated project limitations and qualifications made part of this work, TGE does not provide recommendations for further soil or groundwater assessment at the subject property. However, the following suggested courses of action may be advised.

    Drummed investigation-derived soil and groundwater from the current subsurface investigation, which is currently stored at the Site in two (2) 55-gallon drums (one containing soil and one containing groundwater) are not cons...

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