Green Environmental LLC Review of Phase I&II Methane and Arsenic Reports
Hull's Creek Current Development Layout (23 homes)
Hull's Creek Development Proposed layout (44 homes)
Detroit Park Appraisal Report
Green Environments, LLC 1 Web: http://www.greenenvironments.web.officelive.com
712 High Street
Portsmouth, Virginia 23704
(757) 397-8783
greenenvi@earthlink.net
FAX (757) 399-2276
Green
Environments, LLC
November 4, 2010
Port Norfolk Civic League Green Environments Project # 9229
Attention Ms. Amy O’Donnell
459 Douglas Avenue
Portsmouth, Virginia 23707
Reference: Limited Surface Soil and Debris Sampling in open field
(now or formerly know as Detroit Park)
located near 3101 Detroit Street Portsmouth VA 23707.
Dear Ms. O’Donnel:
On behalf of the Port Norfolk Civic League and concerned neighbors of the open green space (known by
residents as “Detroit Park”) Green Environments, LLC (GE) is pleased to present the attached analytical results
for the limited surface soil sampling we conducted on October 20, 2010 for the referenced property (the
“Project”). The Project is referred to as being at or near 3101 Detroit Street Portsmouth, VA and encompassing
approximately 4.28 Acres to 5.38 acres depending on the report referenced. The site is bordered by Hamilton
Avenue, Detroit Street and Douglas Ave. It should be noted that the primary source of historical information
and historical activities referred to in this letter come from the Phase I and Phase II Environmental Site
Assessments prepared for the City of Portsmouth and Hull Creek Properties, LLC, by Stokes Environmental
Associates, Ltd. (Stokes) dated August 12, 2010, and posted on the city of Portsmouth website. The reader is
also referred to other documents on the City of Portsmouth Economic Development website including the
Arsenic Evaluation Report and Preliminary Methane Assessment for this site, also prepared by Stokes.
This limited soil sampling event was requested after subsurface excavation activities reportedly conducted on
Columbus Day (October 11, 2010) uncovered suspected fill materials related to old uncontrolled and
unregulated landfill activities at the site. The landfill operations reportedly occurred during the 1950s prior to
construction of a school and included materials such as fly ash, dredge spoils and possibly some municipal
waste. The school was reportedly removed down to the ground surface in 2005-2006 with numerous subsurface
foundation structures remaining as well as pre school construction fill material associated with 1950’s era
infilling of the headwaters of Hull Creek as depicted in the 1953 Aerial Photograph presented by Stokes.
Currently, the Project site is open green space land used as a park by the surrounding neighborhood, vacant, and
identified as “Detroit Park” on some maps (Figure 1).
An estimated eight excavation locations were observed to have been disturbed in the October 11 digging, as
reported by neighbors. GE collected three surface soil samples from three different disturbed soil locations as
highlighted in the attached photographs and site maps (Figures 1, 2 and 3). Each grab sample was placed in a
clean, pre-labeled 4 ounce glass jar with screw on lid. Samples were placed in a dedicated cooler and
transported to Metropolitan Laboratories, Inc. of Portsmouth, Virginia.
Additionally, during the soil sampling, loose fibrous construction debris was noted on the ground surface in the
vicinity of sample DS-3. (See Photographs). A single sample of the material was collected for analysis by
polarized light microscopy (PLM). The Chain of Custody documentation is attached along with the analytical
results. The soil samples were analyzed for Total Metal component content by EPA method 3050B/ EPA
7000B. It was noted by the laboratory that detection limits are the same as for TCLP RCRA 8 metals. Please
refer to EPAs website for additional information and definitions of terms. Analytical results confirmed the
presence of Lead, Cadmium, Chromium, Arsenic, Selenium, Barium, and Silver. Mercury was not detected in
any of the three samples. Asbestos was confirmed in the one sample submitted for analysis.
Green Environments, LLC 2 Phone: 757-397-8783 Fax
757-399-2276 Web: http://www.greenenvironments.web.officelive.com
Cadmium and Arsenic were each detected in one sample at a concentration above the Virginia Department of
Environmental Quality (VDEQ) Regional Residential Screening levels linked on the VDEQ website.
DISCUSSION:
Cadmium was detected in sample DS-2 at levels that may (if this material was to be disposed of) classify the soil
as a hazardous waste. Although the hazardous waste characterization generally is performed by TCLP analysis,
a general comparison of total metals results vs. TCLP results can be achieved by taking the total value divided
by 20 to arrive at the TCLP comparable Limit, per EPA website links and standard industry practice. In this
scenario, sample DS-2 could be considered a hazardous waste, since the value for cadmium of 85 mg/kg (parts
per million) is more than 20 times greater than the limit of 1 part per million established by the EPA. The
important point to note here is that the EPA Residential Screening Level (RSL) for total cadmium in Soil of 71
parts per million was exceeded in sample DS-2, which yielded a total cadmium concentration of 85 parts per
million. Despite the comparison here, it is important to note that further testing is necessary to actually
determine weather the surface soils on site are hazardous, as these are isolated data points.
Arsenic was detected in one sample at the EPA Residential Screening Level (RSL) for Total Arsenic in Soil of
39 parts per million (Sample DS-3). Arsenic was also detected in one sample above the RSL at a level of 73
mg/kg. Additionally, and perhaps more significantly, the Arsenic values of 73 and 39 parts per million (samples
DS-1 and DS-3 respectively) are at levels significantly higher than sample data presented by Stokes
Environmental in the Arsenic evaluation report date August 13, 2010. Arsenic was detected in two of the three
collected samples higher than any of the background levels referenced for the Portsmouth and Chesapeake areas
in the same report, and higher than the maximum nationwide background level for Arsenic of 50 parts per
million as reported by Stokes.
As the GE sampling event was limited to three samples of surface soils from three of the observed eight
disturbed soil locations in the field, GE recommends referring to the results of this sampling report as initial
screening values for further consideration. Uncertainty exists with respect to the depth from which the surface
soils were excavated and the soil materials original source. Based on site history documented in the Stokes
reports, and by 1st hand accounts by neighbors the underlying fill materials contain a combination of fly ash,
dredge spoils, construction debris and possibly municipal waste. GE recommends providing this data to the city
of Portsmouth and to VDEQ for further consideration.
Analytical results confirm that three bare surface soils locations on the recently excavated areas on the project
site contain elevated RCRA regulated metals. Arsenic and Cadmium were detected above Soil Screening Levels
(SSL) concentrations established by EPA. Also, asbestos containing construction debris material is present on
the surface soil. As was recommended in the GE review letter dated September 27, 2010 “care should be taken
during any disturbance”. Prudent care does not appear to have been exercised in the most recent digging.
From the EPA website: “The EPA Soil Screening Guidance (SSG) presents a framework for developing riskbased
SSLs for protection of human health. The framework provides a flexible, tiered approach to site
evaluation and screening level development. The SSG focuses on a simple methodology for developing sitespecific
screening levels, but also includes detailed models and generic SSLs to be used where site conditions
warrant. Screening levels are not national cleanup levels; instead, they are intended to be used to streamline the
evaluation and cleanup of site soils by helping site managers eliminate areas, pathways and/or chemicals of
concern at National Priority List sites.” Although the project site may or may not be regulated under Superfund
and CERCLA, this and other guidance documents may be useful for further discussion in assessing appropriate
response actions. The Virginia Solid Waste Interpretive Guidance Statement (SWIGS) (revised: 03/2003) also
may be a good reference for further discussion.
Green Environments, LLC 3 Phone: 757-397-8783 Fax
757-399-2276 Web: http://www.greenenvironments.web.officelive.com
The 2002, "Supplemental Guidance for Developing Soil Screening Levels for Superfund Sites," is a companion
guidance to the 1996 SSG. It builds upon the soil screening framework for residential land use scenarios
established in the original guidance, adding new scenarios for soil screening evaluations. It also updates the
residential scenario in the 1996 SSG, adding exposure pathways and incorporating new modeling data.”
Additionally, as per VDEQ guidance documents regarding landfills, Virginia’s Solid Waste Management
Regulations (VSWMR, 9 VAC 20-80-10 et seq.) require disposal facilities to perform post-closure care
following closure of the facility for up to 30 years. Solid waste disposal facilities are required to perform postclosure
care in order to ensure environmental and public health safety after closure. Disposal facilities include,
but are not limited to sanitary landfills, CDD landfills, and industrial landfills. Post-closure requirements
include groundwater monitoring, gas monitoring, leachate collection, stormwater management, and maintenance
of any final cover. Particularly, construction activities on a closed landfill may result in an amendment to the
post closure care and may be subject to the requirements for a major amendment under VSWMR 9 VAC 20-80-
10. GE recommends the client contact VDEQ for a determination on the applicability of these regulations in
light of the activities and exposure concerns at this site.
In Conclusion, Uncontrolled construction activities on an old landfill (that until now was well
covered) and tended as a childrens’ play area, are not a good mix, especially when hazardous
materials present in the subsurface soils are dug up and brought to the surface and left there.
GE recommends that the client:
1) Coordinate with the property owner(s) and the VDEQ to determine the applicable regulatory body and
applicable Virginia and city codes affecting the management of this landfill site both as a park and as a potential
residential construction development;
2) Implement Interim Control Measures (such as mulch or clean top soil cover) with the guidance of a
environmental professional and/ or appropriate governing authority to keep playful children and pets from
being exposed to potentially hazardous bare soil and debris.
3) Develop a Health and Safety Plan to be implemented for management of the site for any future activities as part
of a total community involvement plan. Any site activities involving digging into the old fill area should be
planned and coordinated with potential site visitors in mind, and should be performed by personnel properly
trained and capable of performing the work, while maintaining landfill materials in a safe and secure manner.
4) Plan for the future: Since it does not appear that surface soil sampling was performed previously, a site
characterization & risk assessment should be performed to evaluate the site surface soil contaminants, as well as
surface & ground water exposure pathways, to contribute to a total site management plan, prior to any further
construction (digging). Once this is done, building on work performed by Stokes, a site management plan should
be prepared to complement any site development that is fully protective of human health and the environment.
The conclusions are based on the findings of this limited assessment and limited scope of work completed by
GE. Ultimately the use of the site information and the sample data is the responsibility of the Port Norfolk Civic
League. No other warranty is expressed or implied, and GE will accept no responsibility for damages or
claims resulting from a past or future release or subsequent remediation. Response actions are the responsibility
of the client and should be conducted in accordance with local, state, and/or federal requirements, and should be
performed by appropriately trained personnel, as warranted. If you should have any questions or comments, or
require additional information, please do not hesitate to contact me at (757) 397-8783.
Respectfully,
Jefferson H. Ghent, P.G.
Senior Geologist,
Virginia licensed Lead Risk Assessor, and Asbestos Inspector.
Encl. Photographs, Chains of Custody, Laboratory results, Site maps