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  United States
  Environmental Protection
  Agency
        Grand Plaza Site Investigation Using
        the Triad Approach and Evaluation
        of Vapor Intrusion
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                                             EPA/540/R-07/002
                                              September 2006
Grand Plaza Site Investigation Using the Triad
           Approach and Evaluation of
                  Vapor Intrusion
            National Risk Management Research Laboratory
                Office of Research and Development
               U.S. Environmental Protection Agency
                     Cincinnati, Ohio 45268

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                                              Notice
The information in this document has been funded by the U.S. Environmental Protection Agency (USEPA) under
Contract Number 68-C-00-186 to Environmental Quality Management (EQM), Inc. and EQM's subcontractor, URS
Corporation. It has  been subjected to the Agency's peer and administrative  review and has been approved for
publication as an EPA document.  Mention of trade names or commercial products does not constitute endorsement
or recommendation for use.
                                                 11

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                                               Foreword

The U.S. Environmental Protection Agency (EPA) is charged by Congress with protecting the Nation's land, air,
and water resources.   Under a mandate of national environmental laws, the Agency  strives to formulate and
implement actions leading to a compatible balance between human activities and the ability to natural systems to
support and nurture life. To meet this mandate, EPA's research program is providing data and technical support for
solving environmental problems today and building a science knowledge base necessary to manage our ecological
resources wisely, understand how pollutants affect our health, and prevent or reduce environmental risks in the
future.

The  Natural  Risk Management Research Laboratory  (NRMRL)  is the Agency's center  for investigation  of
technological and management approaches for preventing and reducing risks from pollution that threaten human
health and  the environment.   The focus  of the Laboratory's research program is  on methods  and their cost-
effectiveness for prevention and control of pollution to air, land, water, and subsurface resources; protection of water
quality in public water systems; remediation of contaminated sites, sediments and ground water; prevention and
control of indoor air pollution; and restoration of ecosystems.  NRMRI collaborates with both public and private
sector partners to foster technologies that reduce the cost of compliance and to anticipate emerging problems.
NRMRL's research provides solutions to environmental problems by developing and promoting technologies that
protect and improve the environment; advancing scientific and engineering information to support regulatory and
policy decisions; and  providing the  technical support  and  information transfer to ensure  implementation  of
environmental regulations and strategies at the national, state, and community levels.

This publication has been produced as part of the Laboratory's strategic long-term research plan. It is published and
made available by EPA's Office of Research and Development to assist the user community and to link researchers
with their clients.
                                                            Sally C. Gutierrez, Director
                                                            National Risk Management Research Laboratory
                                                   ill

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                                               Abstract


This document provides a detailed report about a field study conducted by EQM/URS on behalf of EPA/NRMRL to
characterize the subsurface contamination of volatile organic compounds (VOCs) at a Brownfield commercial site.
The TRIAD approach was implemented to characterize the extent of soil, groundwater, and soil gas contamination.
These data were used to assess impact on indoor air due to vapor intrusion.  Seventy-seven soil samples, twenty-
eight groundwater samples, and ten soil-gas samples were collected from Geoprobe™ borings and analyzed on-site
by USEPA Method SW-846 8265 direct sampling ion trap mass spectrometry (DSTIMS).  Additional SW-8260b
and  TO-15  analyses  were  performed  on  approximately  10% of the  samples  by   off-site  laboratories.
Tetrachloroethylene (PCE), trichloroethylene (TCE) and cis-l,2-dichloroethylene (DCE) were detected in all media
with PCE as the prevalent compound.

The on-site analyses for PCE were 22% higher than the off-site analyses for methanol  extracts from soil samples.
For the shallow soil-gas samples, the on-site results for PCE agreed with the off-site analyses  within about one order
of magnitude for the sample pairs where PCE was present at concentrations  >10 ppbv.  The off-site results for the
sub-slab soil-gas samples were several orders of magnitude higher than the on-site results, perhaps due to limitations
in the on-site sampling and analytical approach at these high concentrations.  The geology  was interpreted from the
boreholes and logs from previously drilled groundwater monitoring wells.  All data indicated that there was a small
PCE hot spot that was roughly 40 ft by 40 ft (12m by 12m). The hot spot was shallow (less than 10 feet [3m] below
ground surface [bgs]) on top of a low permeability clay under the southwestern edge  of the building where a
drycleaner was once located.

Canister samples of indoor air were collected in April and August of 2005.  The results were compared with shallow
soil-gas and  sub-slab soil-gas results  to  assess  the impact of this  contamination  on the indoor air.  PCE
concentrations in the five indoor air samples ranged from 3.7 to 16 ppbv, with four of five results between 10 and 16
ppbv.  For comparison, the ambient air contained 0.11 ppbv.  The six samples of shallow  soil-gas collected at a
depth of 5 feet (1.5m) bgs directly within or near the building had from 3 9 to 780 ppbv of PCE.  The highest of the
three sub-slab soil-gas samples had 2,600,000 ppbv of PCE. The time-averaged indoor air  concentration of 12 ppbv
corresponds to a cancer risk of 2E-05  based on an inhalation unit  risk  (IUR)  of 3.0E-06 per |J.g/m3  and  an
occupational exposure scenario of 8 hr/day, 5 day/week, 50 week/yr for 25 years.

The productivity of the  aquifer was evaluated at  several monitoring wells  using two  methods:  slug test and a
constant discharge  test.  The results of both types of tests demonstrate that site well yields are significantly greater
than the  150 gallons per day  criterion used  by the  Texas Commission on  Environmental Quality (TCEQ) to
differentiate between Class 2 (potential) and Class 3 (non-potential) groundwater resources.  Therefore, the shallow
groundwater zone at this site is designated a Class 2 groundwater resource.
                                                   IV

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                                               Contents
Notice  	ii
Foreword	iii
Abstract	iv
Acronyms, Abbreviations, and Symbols	ix
Acknowledgements	xii

        Executive Summary	ES-1

1.0     Introduction	1

2.0     Site Description	2
        2.1      Site History	2
        2.2      Previous Site Investigations	2
        2.3      Site Geology and Hydrogeology	6

3.0     Technical Approach	8
        3.1      Schedule of Field Activities	8
        3.2      Study Design	8
                3.2.1    Site Characterization	8
                3.2.2    Second Round of Air Monitoring	11
                3.2.3    Installation of Groundwater Monitoring Wells	11
                3.2.4    Slug Tests	11
                3.2.5    Design of Control System	11
        3.3      Sampling Procedures	12
                3.3.1    Sample Collection for On-Site Analyses	12
                3.3.2    Sample Collection for Off-Site Analyses	14
        3.4      Analytical Procedures	15
        3.5      Sample Handling and Chain of Custody Procedures	16

4.0     Results	17
        4.1      On-Site Analytical Results  for Site Characterization	17
                4.1.1    Groundwater	17
                4.1.2    Soil	17
                4.1.3    On-Site Soil Gas	17
        4.2      Results of Off-Site Analysis of Groundwater	17
        4.3      Results of Slug Tests	20
        4.4      Evaluation of Vapor Intrusion	20
                4.4.1    Off-Site Analysis of Soil Gas	20
                4.4.2    Off-Site Analysis of Indoor and Ambient Air Samples	20
                4.4.3    Design of Control System	20
        4.5      Health and Safety	20
        4.6      Waste Disposal	20
        4.7      Results of Quality Control (QC) Checks	20

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5.0
7.0
                                      Contents (continued)
Discussion Results	37
        5.1     Site Characterization	37
               5.1.1    Groundwater	37
               5.1.2    Soil	42
               5.1.3    On-Site Soil-Gas	55
        5.2     Evaluation of Vapor Intrusion	55
               5.2.1    Off-Site Analysis of Soil-Gas	55
               5.2.2    Off-Site Analysis of Indoor and Ambient Air Samples	56
               5.2.3    Tracer Gas Tests	56
               5.2.4    Evaluation of Vapor Intrusion	57

6.0     Specifications for Control System for Grand Plaza Site	60
        6.1     Location	60
        6.2     Site Specific Conditions	60
        6.3     Active Soil Depressurization System	60
               6.3.1    Depressurization Fan	61
               6.3.2    Pipe and Fittings	61
               6.3.3    Suction Point	62
               6.3.4    Sealing	62
               6.3.5    Asbestos Containing Materials	62
               6.3.6    Excavation and Rapair	62
               6.3.7    Painting	63
               6.3.8    Labeling Requirements	63
        6.4     Figures and Details	63
References	78
Appendix A    Drilling Logs for Ten Groundwater Monitoring Wells
Appendix B    Field Data Sheets for Groundwater Monitoring
Appendix C    Field Data Sheets for Soil-Gas Sampling
Appendix D    Analytical Report from Kemron for Groundwater Samples from October 2005
Appendix E    Analytical Report from Kemron for Groundwater Samples from December 2005
Appendix F    Results of Slug Tests for Groundwater Monitoring Wells
Appendix G    Analytical Report from Air Toxics for Soil-Gas Samples
Appendix H    Analytical Report from Air Toxics for Air Samples Collected in April 2005
Appendix I     Analytical Report from Air Toxics for Air Samples Collected in August 2005
Appendix J    Site Inspection Report for Design of Control System
Appendix K    Analytical Report from Kemron for Soil Extract Samples
                                                VI

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                                              Tables
3-1     Schedule of Field Activities	10
3-2     Primary Compounds of Interest	10
3-3     Summary of Sampling Methods	12
3-4     Canister Samples for Off-Site Analysis During April Sampling Event	14
3-5     Summary of Sampling and Analytical Methods for VOCs	16

4-1     Results of On-Site Analysis of Groundwater Samples	21
4-2     Results of On-Site Analysis of Soil Samples	22
4-3     Results of On-Site Analysis of Soil-Gas Samples	26
4-4     Results of Off-Site Analysis of Groundwater Samples Collected in October 2005	27
4-5     Results of Off-Site Analysis of Groundwater Samples Collected in December 2005	28
4-6     Results of On-Site Monitoring of Groundwater Samples Collected in October 2005	29
4-7     Results of Off-Site Monitoring of Groundwater Samples for MNA Parameters	30
4-8     Results of Off-Site Monitoring of MW-9 Sample for Selected Parameters	30
4-9     Results of Off-Site Analysis of Soil-Gas Samples Collected in April 2005	31
4-10    Comparison of Results for Shallow and Sub-Slab Soil-Gas Samples Collected in April 2005	31
4-11    Results of Off-Site VOC Analysis of Indoor Air and Ambient Air Samples
        for April 2005	32
4-12    Results of Off-Site VOC Analysis of Indoor Air Samples for August 2005	32
4-13    Results of Off-Site Tracer Gas Analysis of Indoor Air Samples for August 2005	33
4-14    Results of On-Site Duplicate Analysis of Groundwater Sample	33
4-15    Results of On-Site Duplicate Analysis of Soil Samples	34
4-16    Comparison of On-Site and Off-Site Analysis of Soil Samples	34
4-17    Comparison of On-Site and Off-Site Analysis of Soil-Gas Samples	35
4-18    Results of Off-Site VOC Analysis of Groundwater QC Samples	36
4-19    Results of Off-Site Analysis of Groundwater QC Samples for MNA Parameters	36

5-1     PCE and TCE in Groundwater Over Time	41
                                                Vll

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                                               Figures


ES-1    3-D Plot of Subsurface PCE Contamination in Soil	ES-2

2-1     Front View of Former Dry Cleaning Facility	3
2-2     Back View of Former Dry Cleaning Facility	3
2-3     Front Room of Former Dry Cleaning Facility	4
2-4     Dining Area Adjacent to Former Dry Cleaning Facility	4
2-5     Fry Room at Former Dry Cleaning Facility	5
2-6     Back Room at Former Dry Cleaning Facility	5

3-1     Sample Location Map	9
3-2     Large Direct-Push Rig	8
3-3     Dolly Rig	11
3-4     Sub-Slab and Indoor Air Sampling Locations	13

4-1     Depth to Bedrock	18
4-2     Geologic Cross-Section A-A'	19

5-1     Groundwater Isoconcentration Contour (PCE ug/L)	38
5-2     Groundwater Isoconcentration Contour (TCE ug/L)	39
5-3     Groundwater Isoconcentration Contour (DCE  ug/L)	40
5-4     Soil Isoconcentration Contours (PCE ug/kg 0-1 ft)	43
5-5     Soil Isoconcentration Contours (PCE ug/kg 1-10 ft)	44
5-6     Soil Isoconcentration Contours (PCE ug/kg >10 ft)	45
5-7     Soil Isoconcentration Contours (TCE ug/kg 0-1 ft)	46
5-8     Soil Isoconcentration Contours (TCE ug/kg 1-10 ft)	47
5-9     Soil Isoconcentration Contours (TCE ug/kg >10 ft)	48
5-10    Soil Isoconcentration Contours (DCE ug/kg 0-1 ft)	49
5-11    Soil Isoconcentration Contours (DCE ug/kg 1-10 ft)	50
5-12    Soil Isoconcentration Contours (DCE ug/kg >10 ft)	51
5-13    3-D PCE Plume Based on Soil Data	52
5-14    3-D TCE Plume Based on Soil Data	53
5-15    3-D DCE Plume Based on Soil Data	54

6-1     Installation Schematic	64
6-2     Location of Suction Points	65
6-3     Pictorial Indication of System Locations and Details	66
6-4     Detail 1  Suction Pif	67
6-5     Detail 2 Vent Discharge	68
                                                 Vlll

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                           Acronyms, Abbreviations, and Symbols
a
ACH
bgs
BSA
°C
cfm
cm
CVC
DCB
DCE
Dec
DL
DSITMS
dup
BCD
EPA
ESA
ft
ft2
g
GC
gpd
gpm
He
Hg
H20
hr
HVAC
in.
IUR
Kg
Alpha (attenuation factor)
Alpha based on soil-gas data
Air changes per hour (hr"1)
Below ground surface
Brownfields Site Assessment
Degrees Celsius
Cubic feet per minute
Centimeter
Colorado Vintage Companies
Dichlorobenzene
Dichloroethylene
December
Detection limit
Direct sampling ion trap mass spectrometry
Duplicate
Electron capture detector
Environmental Protection Agency
Environmental site assessment
Feet
Square feet
Gram
Gas chromatography
Gallons per day
Gallons per minute
Helium
Mercury
Water
Hour
Heating, ventilation, and air conditioning
Inches
Inhalation unit risk
Kilogram
                                                IX

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                      Acronyms, Abbreviations, and Symbols (continued)
L                Liter
m               Meter
m2               Square meters
m3               Cubic meters
MCL            Maximum contaminant level
min              Minute
mL              Milliliters
MNA            Monitored natural attenuation
MPS             Multi-probe system
MSD            Municipal Setting Designation
mV              Millivolt
MW             Monitoring well
ND              Not detected
NIST            National Institute of Standards and Technology
O2               Oxygen
Oct              October
ORP             Oxidation reduction potential
OSHA           Occupational Safety and Health Administration
AP               Pressure differential
pa               Pascal (unit of pressure)
PCE             Tetrachloroethylene
PCL             Protective concentration levels
PID              Photo-ionization detector
ppbv             Part-per-billion on a volume basis
ppm             Part-per-million
PRT             Post-run tubing
PVC             Polyvinyl chloride
Qeidg             Ventilation air flow rate for building
QC              Quality control
QSoii              Vapor intrusion flow rate into building
RPD             Relative percent difference
|j,S/cm           Micro-siemens per centimeter
SB               Soil boring
SF6              Sulfur hexafluoride
SIM             Selective ion mode

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                     Acronyms, Abbreviations, and Symbols (continued)
SVOCs           Semi-volatile organic compounds
TCE             Trichloroethylene
TCEQ            Texas Commission on Environmental Quality
TDS             Total dissolved solids
TO              Toxic organic
TRRP            Texas risk reduction program
TX              Texas
|j,g               Micrograms
|j,g/m3            Micrograms per cubic meter
US              United States
V               Volt
VC              Vinyl chloride
VI               Vapor intrusion
VOCs            Volatile organic compounds
XBidg             Tracer gas concentration in indoor air
Xtrace,.            Tracer gas concentration at source
YSI              Yellow Springs Instrument
                                               XI

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                                        Acknowledgments
This report was prepared under the direction of Dr. Michelle Simon, the U.S. Environmental Protection Agency
(EPA)  Superfund Innovative Technology Evaluation (SITE) project manager at the National Risk Management
Research Laboratory  (NRMRL) in  Cincinnati, Ohio.   The work was performed under Field Evaluation and
Technical  Support  (FEATS)  Contract No.  68-C-00-186.   The prime contractor was Environmental Quality
Management (EQM);  Mr. Robb Amick served as the Program Manager.  This report was prepared by Mr. Bart
Eklund, Mr. Robert Schafer, and Mr. Derek Peacock of URS Corporation under subcontract to EQM.  Mr. Doug
Kladder of Colorado Vintage Companies prepared Section 6 of the report.

The fieldwork was performed by the following individuals.  From URS, Messers. Bart Eklund (Project Manager),
Eric  Anderson (Chemist), Derek Peacock (Engineer), Robert Schafer (Geologist), Robert Smith (Geologist), and
Mark Sollman (Geologist).  From Tri-Corders, Dr. William Davis (Chemist). From Colorado Vintage Companies,
Mr. Doug Kladder (Engineer).

The cooperation and participation of the following people are gratefully acknowledged: Ms. Ann Grimes of the City
of Dallas, Office of Economic  Development, Brownfields Program; Mr. Mark Obeso, Assistant Director, City of
Dallas  Housing Department; and Mr.  Mike Frew, Texas Commission on Environmental  Quality, Brownfields
Coordinator.
                                                xil

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                                       Executive Summary
The  U.S. Environmental  Protection Agency (U.S.
EPA) undertook a project  to characterize subsurface
contamination and evaluate  the potential for vapor
intrusion (VI) at the Grand Plaza Shopping Center in
Dallas, Texas. There is subsurface contamination of
chlorinated solvents beneath the southwest end of the
building, where a dry cleaning was once located. In
recent years, a series of restaurants have occupied the
space.

The   site  investigation built  upon  several   past
Brownfield  Site Assessments (BSAs)  previously
completed at the site. Based on the past work, it was
known  that groundwater  and shallow  soil in  the
vicinity of the former dry cleaner is  impacted by
tetrachloroethylene (PCE), trichloroethylene (TCE),
and    cis-l,2-dichlorothylene    (DCE).        The
concentrations of metals and SVOCs were below the
applicable  regulatory   levels   in  both  soil  and
groundwater samples and  therefore were no longer
considered chemicals of concern for the property.

First, an intensive site characterization effort  was
performed.  A Triad approach was used; i.e., real-
time or rapid response analytical data were used on-
site to reach decisions.  The general approach for site
characterization was to  collect soil, groundwater, and
soil-gas samples using direct-push equipment - from
both inside and outside of the building - and analyze
the samples on-site using  EPA Method 8265, direct
sampling  ion trap  mass  spectrometry  (DSITMS).
Analytical run times of approximately three minutes
per  sample  allowed   low  ppb-level  data to  be
generated at a rapid rate.  Approximately 10% of all
samples were also analyzed by off-site laboratories.

Drilling logs from the study area generally record the
presence of silty clay deposits from 0 to 20 ft (0 to
6m)  bgs, and fine- to  coarse-grained sand deposits
from 20 ft (6m) bgs to bedrock, the depth to which is
highly variable within the area.  The depth to bedrock
varies from  less than 20  ft  (6m)  bgs  in   the
northeastern portion of the  study area, to greater  than
70 ft (30m) bgs in the northwestern portion of the
study  area.    Within  the  study  area,  shallow
groundwater is present at a depth of approximately
30  ft (9m)  bgs within the sandy  deposits of the
terrace alluvium.

The site characterization effort indicated  that the
subsurface contamination was  largely  confined to a
small area beneath the former dry cleaning business.
All soil samples from outside the building were <0.4
ppm for all compounds.  Contamination was detected
in all borings down to a depth of 20 ft (6m) bgs. Soil
samples from underneath the building contained up to
3.4 ppm of PCE, 2.3 ppm of TCE,  and 6.4 ppm of
DCE.   The soil data for PCE are plotted in Figure
ES-1.  All groundwater concentrations  outside the
building  were  <0.1  ppm and all   groundwater
concentrations beneath the building  were <0.4 ppm.
The groundwater and soil data sets  suggest that the
PCE has undergone substantial degradation to TCE
and DCE.  No vinyl chloride  (VC), however, was
detected. In addition, benzene and toluene were not
detected.

Aquifer production tests  conducted at MW-7, MW-9,
and MW-10 demonstrated well yields of  1,400 to
20,000 gpd (5,300 to 75,700 L/day) that are greater
than the  150 gpd (570 L/day)  criterion.  Therefore,
the groundwater at this  site is designated Class 2
according to Texas regulatory guidance.

Shallow  soil-gas  samples  were collected at  six
locations at a depth of 5 ft (1.5m) bgs and three sub-
slab soil-gas samples also were  collected. PCE in the
shallow soil gas ranged from  0.039 to  0.71 ppmv.
TCE  concentrations  were similar  to  the  PCE
concentrations, whereas DCE tended to be higher (up
to 29 ppmv).  The presence of TCE, DCE, and VC is
additional evidence that the PCE has been degraded.

Soil-gas data at the site  indicate a surprisingly large
degree   of   spatial  variability.  The  gas-phase
subsurface contamination was  found to exist in one
relatively small "hot spot".  The data suggest that the
contamination  has largely remained in place under
the slab near its  release point with only limited
vertical and lateral transport.
                                                 ES-1

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to

                                  l«atna
   V
URS
                                  to M9*g PCE isoe«x«nlr*(ioo
                                                                           Grand Avenue Plaza
                                                                           3103 Grand Avenue
   Figure ES-1
  3-D PCE Plums
Based on April 2005
    Soil Data

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In  conjunction  with  the  site   characterization,
additional fieldwork was performed to evaluate vapor
intrusion at the site.   PCE was detected in multiple
indoor air samples at about 12  ppbv (83  |J.g/m3).
Ambient air contained only 0.11  ppbv of PCE and
does not appear to have been a significant source of
this  compound  in  the  indoor air.   The  building
ventilation rate was  determined using  a  tracer gas.
The  measured values of 1 to 2 ACH  at the Grand
Plaza site appear to be relatively low for a restaurant,
but are much higher  than the default value of 0.25
ACH in  the US EPA November 2002  guidance,
which is  based on  the  10th  percentile  for single
residence buildings.

The  ratio  of indoor air to soil-gas concentrations is
often evaluated in vapor intrusion studies.  This ratio
typically  is  called  the  attenuation  factor  or  a.
Published values of aSG tend to be O.001. The EPA
default aSG value for  screening  purposes currently is
0.1,  but is expected  to decrease  to 0.02  when  the
2002 EPA guidance is revised sometime in 2007.

The three sub-slab soil-gas samples had 18,000,000;
26,000; and 59,000 |ag/m3 of PCE.  The three indoor
air samples had 85, 68, and 96  |J.g/m3, for a mean of
83  |J.g/m3.   Therefore, aSG = 5.3xlO"6 using  the
maximum values  and  aSG =  1.4xlO"5  using  the
average  values.   The values  of  aSG  for  other
compounds detected in the sub-slab soil-gas are also
in the 10"6 range using the maximum values.
The  risk  from inhalation of PCE  at  this  site  is
conservatively estimated to be 2xlO"5, based on an
inhalation unit risk for PCE  of 3.0xlO"6 per |J.g/m3
and a 25-year occupational exposure scenario.  The
estimated  risk falls within the IxlO"4 to  IxlO"6 risk
management  range and there is no requirement for
mitigation of vapor intrusion at this site based on
State standards.  A control system was designed as
part of this study but ultimately was deemed to be not
necessary.  Future steps to achieve site closure are
expected to  involve  seeking a Municipal Setting
Designation (MSD) or a deed restriction for the site.

The results for this site have several implications for
the standard regulatory approach for evaluating vapor
intrusion.   One,  field  investigations at sites  with
surface  releases  should  include measurements in
surface soil layers. Groundwater,  soil, and soil-gas
measurements  at   depth  may  not  identify   the
maximum concentrations present at the site.  The
study illustrates the extreme spatial variability that is
sometimes found  in the  subsurface at contaminated
sites.   Two,  the  use of mean values  instead of
maximum values may still be very conservative when
soil-gas measurements are used to estimate indoor air
concentrations using an aSG of 0.1 or 0.02.  Three,
the U.S. EPA defaults for parameters such as Qsoii,
Qeidg, and AP may be very conservative for a given
site.    Site-specific  measurements  can  readily be
performed to provide  more  accurate estimates for
these parameters instead of relying on default values.
                                                  ES-3

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                                            SECTION 1
                                        INTRODUCTION
The  U.S. Environmental  Protection Agency (U.S.
EPA) undertook a project  to characterize subsurface
contamination and evaluate  the potential for vapor
intrusion (VI) at the Grand Plaza Shopping Center in
Dallas, Texas. There is subsurface contamination of
chlorinated solvents beneath the southwest end of the
building, where  a dry  cleaning business was once
located.  URS Corporation (URS), under contract to
EQM, directed the on-site activities.

The work was performed in two phases during 2005.
During Phase I of the project, soil, groundwater, soil-
gas,   and indoor  air  samples were  collected to
characterize the extent of subsurface contamination at
the site and evaluate the potential for vapors to enter
the  structure.    The  majority  of  analyses were
performed  on site using a mobile laboratory, with
additional analyses performed off site to confirm and
complement the  on-site data.  During Phase II of the
project,   additional indoor air  measurements were
performed and  a  system to control the vapors was
designed.

The goals for the project were to:

1.   Characterize the three-dimensional aspects of the
    chlorinated  soil,  groundwater,  and  soil-gas
    plume;
2.   Determine the productivity of the local shallow
    aquifer;
3.   Collect sub-slab soil-gas and indoor air data and
    use these data to evaluate vapor intrusion at the
    site; and
4.   Design an active control system to limit vapor
    intrusion at the site.

The  site characterization work was more thorough
than is often  the  case at vapor  intrusion sites.
Therefore, the study provides a useful case study for
this type of work.

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                                            SECTION 2
                                     SITE DESCRIPTION
The site history is summarized below followed by a
summary of previous site investigations and a short
description of the geology and hydrology in the local
area.

2.1     Site History

The area that  was studied  lies within a 26,189  ft2
(2,433  m2)  single-story retail facility  (strip  mall)
constructed in 1966  and its adjoining  parking lot.
The site is  located at 3103 Grand Avenue in Dallas,
Texas.  It is in the South Dallas/Fair Park community
about one mile south of the Texas Fairgrounds and
the Cotton  Bowl. The neighborhood is low income
and economically underdeveloped.

The strip mall has spaces for nine to ten tenants.  A
combined  Laundromat and dry cleaning  business
originally occupied the southwestern-most portion of
the strip mall in a space that was roughly 30 ft by 70
ft  (9m by 21m).  The front and back views of the
former dry cleaning business are shown in Figures 2-
1 and 2-2.

Only  limited  information  is  available about  the
former dry  cleaning business.   The certificate  of
occupancy  for Baccus Cleaners is dated October 3,
1966.  The application to  operate  a dry  cleaning
establishment is  dated April 8, 1970.  The facility
was categorized as a Class IV dry cleaning plant and
authorized  to  store up  to  50 gallons  (190 L)  of
inflammable volatiles.  A building permit for  June
25, 1971  indicates that the  site  housed a  coin-
operated laundry with 30 washing machines and  15
dryers. An undated building plan indicates that two
dry cleaning machines  were located near the front,
right corner of the business.   A sump  was located
near the back of the business about 6 ft (2m) in from
the back wall.  The dry cleaning operation is believed
to have operated from 1970 through 1986.

A series of restaurants later occupied the space that
once housed the dry cleaning business.  In recent
years,  a  restaurant  occupied  both  the  former
drycleaner  space and  the  adjacent  space, with  a
combined area  of roughly 60 ft by 70 ft (18m by
21m).   The  two halves were  connected via two
French doors along an internal wall near the front of
the building.  The two spaces are shown in Figures 2-
3 and 2-4 (a schematic is given in Section 3, Figure
3-4).  At the time of the first phase of this study,
neither space was occupied  and the  doors between
them were open, allowing air to move freely between
the two spaces.  At the time of the second phase of
this study, a new restaurant was operating in the 30 ft
by 70 ft (9m by 21m) space that once housed the dry
cleaning  business  and  the adjacent space  was
unoccupied and closed off from the restaurant.  The
former dry cleaning facility currently is divided into
three main rooms.  The front room shown in Figure
2-3 provides  public access  to restaurant customers.
The middle room or "fry room" has a large exhaust
hood where food is  prepared. The back room has a
walk-in refrigerator  and is used for dishwashing and
storage. The back room also contains a small office
partitioned off from the rest of the space.  The fry
room  is shown in Figure 2-5 and the back room is
shown in Figure 2-6.

2.2     Previous  Site Investigations

The Grand Plaza Shopping Center was purchased in
1989  by a non-profit  organization.   The  City  of
Dallas Brownfields Program provided  a Phase  I
Environmental   Site Assessment  (ESA)  for  the
property  in 2001 as part of the process to secure
funding  for  building  improvements.  The   ESA
identified several environmental concerns:

•   On-site dry  cleaning business in operation until
    1986;
•   Lumber treating plant in the 1950's in operation
    adjacent to the property; and
•   Underground gasoline storage tank at the lumber
    yard that occupied the  adjacent property in the
    1950's.

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Figure 2-1. Front View of Former Dry Cleaning Facility
Figure 2-2. Back View of Former Dry Cleaning Facility

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    Figure 2-3. Front Room of Former Dry Cleaning Facility
Figure 2-4.  Dining Area Adjacent to Former Dry Cleaning Facility

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 Figure 2-5. Fry Room at Former Dry Cleaning Facility
Figure 2-6.  Back Room at Former Dry Cleaning Facility

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A  Brownfields   Site  Assessment  (BSA)  was
conducted by Leigh Engineering in April 2002 under
the Voluntary Cleanup Program (VCP) of the Texas
Commission  on  Environmental  Quality  (TCEQ).
Based  on the initial findings, a  second BSA was
conducted by Leigh Engineering in August 2002.

During the first BSA, four groundwater monitoring
wells were  installed and 22  soil  samples were
collected  from seven  soil boring  locations (well
locations  are shown in  Section  3,  Figure 3-1).
Samples  were analyzed  for metals, volatile organic
compounds   (VOCs),  and   semi-volatile  organic
compounds (SVOCs).  During the  second BSA,  a
fifth downgradient monitoring well (MW-5) was
installed.   Subsequently, all  five monitoring wells
were  sampled, a soil-gas  sample was  collected
beneath the slab  of  the former dry cleaner,  and  a
database  search was conducted to identify any water
wells within a 1/2-mile (800m) radius of the site.

The first four  monitoring wells  were installed to
depths of roughly 35 ft to 60 ft (10.7m to  18.3m)
below  ground  surface   (bgs).     The  depth  to
groundwater was  determined  to be between  28  and
35  ft (8.5 to  10.7m) bgs with an apparent gradient
sloping from west to east across  the  site.  The
bedrock elevations were between 73 and 68 ft (22.2
and 30.7m) bgs.

Analytical  results from  four of the groundwater
monitoring wells  (i.e.,  MW-1, -2,  -4,  and  -5)
indicated that the  groundwater in the vicinity of the
former    dry    cleaner   was    impacted   by
tetrachloroethylene (PCE), trichloroethylene  (TCE),
and/or       cis-l,2-dichlorothylene       (DCE).1
Contaminants were not  detected in the  monitoring
well farthest away  from the former  dry  cleaner
(MW-3).

Soil borings 1 through 4 were  advanced to 14.5 to 15
feet (4.4 to 4.6m) through the concrete  slab  in the
former  dry  cleaning  facility  using direct push
technology.  Soil borings 5 through 7 were advanced
east and  south of  the dry cleaning facility to  15 feet
(4.6m) using  a hollow stem auger drilling. Shallow
soil samples collected from the four borings beneath
the floor of the former dry cleaner at depths of 2 feet
(0.6m) and 4.5-6.5 ft (1.4 to  2.0m)  contained PCE,
1 Compared with Texas Risk Reduction Program (TRRP)
Tier 1 Protective Concentration Levels (PCLs) for a 0.5-
acre source area, commercial setting, and drinking water
scenario.
TCE, and/or DCE. The highest concentrations were
in the vicinity of SB-2 between 2.5 and 4.5 ft (0.76
and 1.4m).

Soil   samples  were   also  collected  during  the
installation of the on-site monitoring  wells.   The
samples were mostly non-detect, but PCE, TCE, and
DCE were detected  at  low  ppm-levels in shallow
soils at some locations.

The concentrations of metals and SVOCs were below
the applicable regulatory levels  in  both  soil and
groundwater   samples   and  therefore  were  not
considered chemicals of concern at the property.  No
water wells were located within a 1/2-mile (800m)
radius of the site according to the database report.

Samples  were collected  from  the five  existing
groundwater  monitoring wells  in July 2003 and
analyzed for  VOCs.  Three  additional  groundwater
monitoring wells (MW-6 through -8) were installed
by URS in April 2004 and groundwater samples were
collected at all eight wells in May 2004 and analyzed
for VOCs.  The 2004  results were  similar to  the
results obtained in 2003 for  the five  existing  wells.
PCE, TCE, and cis-l,2-DCE were  detected in  the
three new wells at concentrations slightly above the
residential Protective Concentration Levels (PCLs).

2.3     Site Geology and Hydrogeology

During the Cretaceous period of the Mesozoic era,
transgression  and regression of the sea across north-
central Texas  deposited sediments on top of flat-lying
Paleozoic age strata.  Near the end of the Cretaceous
period, regional  uplift tilted  the  layers  of sediment
toward the east as seas withdrew toward the Gulf of
Mexico.  Subsequent transgression and regression of
the  sea  deposited  sediments  of  Tertiary  and
Quaternary age further to the east, as streams eroded
the exposed land to  the west and deposited terrace
and alluvial sediments there (Nordstrom, 1982).

At the Grand  Plaza Shopping Center, Quaternary age
terrace alluvium  (or soils formed therein) is exposed
at ground surface,  or lies beneath  pavement and
backfill material in this urban area. Regionally, these
sediments  are  comprised  of  heterogeneous   or
interbedded gravel,  sand, silt,  and  clay mixtures.
Thickness of the alluvium is highly variable,  but
deposits  are  usually less than 75  ft  (23m)  thick
(Nordstrom, 1982). Drilling logs from the study area
generally record the  presence of silty clay  deposits

-------
from 0 to 20 ft (0 to 6m) bgs, and fine- to coarse-
grained sand deposits from 20 ft (6m) bgs to bedrock,
the depth to which is highly variable within the area.

The  competent bedrock,  which  is unconformably
overlain  by   the  terrace   alluvium,  consists  of
Cretaceous age Austin Group deposits.  Regionally,
the Austin Group is comprised of chalk, limestone,
marl, clay, and sand deposits. Sometimes referred to
collectively as the Austin chalk,  the  Austin Group
deposits  can  be  up  to   700  ft   (200m)  thick
(Nordstrom, 1982).   Drilling within the  study area
has penetrated only the first few inches of bedrock,
so the nature of the Austin Group deposits there has
not been defined in detail.  However, one drilling log
from the area describes the bedrock surface as light
gray clayey silt, presumably weathered limestone or
marl,   that   is   calcareous  (evidenced   by   its
effervescence in hydrochloric acid), dry to damp, and
hard.  The depth to bedrock varies from less than 20
ft  (6m) bgs in the northeastern portion of the study
area,  to  approximately  75  ft (23m) bgs in the
northwestern portion of the study area.
The terrace alluvium and Austin Group deposits are
known regionally to produce only small quantities of
groundwater.  The important aquifers of the region
are the  Woodbine Group and the Twin  Mountains
Formation of the Trinity Group  (Nordstrom, 1982).
Like the Austin Group, both of these aquifers are
Cretaceous  in   age.     Other  Cretaceous  age
stratagraphic units separate the Austin Group from
the deeper  aquifers,  and  the  aquifers  from one
another.  Beneath the  study  area, the depth to the
Woodbine  Group  is approximately  850  ft  (260m)
bgs, and the depth to the Twin Mountains Formation
is  approximately 2,550 ft (780m) bgs (Nordstrom,
1982).

Within the study area, shallow groundwater is present
at  a depth of approximately 30 ft (9m) bgs within the
sandy deposits of the terrace alluvium.  The bedrock
beneath the alluvium presumably forms a hydrologic
barrier beneath the study area, but its influence on
local groundwater flow has  yet  to be determined.
The bedrock surface forms a trough that slopes to the
northwest and west, but the  apparent direction of
groundwater flow, based on groundwater  monitoring
wells in the area, is to the east.

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                                           SECTION 3
                                TECHNICAL APPROACH
This section contains a description of the technical
approach that was employed during the study.  The
schedule  of field activities and study  design are
presented below, followed by brief summaries of the
sampling,    analytical,    and    sample   handling
procedures.
3.1
Schedule of Field Activities
The chronology of on-site events is shown in Table
3-1.  All field activities were performed in the year
2005.

3.2     Study Design

The general sampling strategies employed during the
initial  site  characterization work  and  the  second
round of indoor air sampling are  described below.
The  approach  used  to  install   two  additional
groundwater monitoring  wells, perform  slug tests,
and design a control system also are described.

3.2.1    Site Characterization

Target  compounds were  selected based on  existing
soil, groundwater, and soil-gas data collected in past
site characterization efforts undertaken by TCEQ.
The on-site monitoring addressed the six compounds
shown  in Table 3-2.  PCE is a commonly used dry
cleaning fluid and it is  the  primary compound of
interest at this site.  TCE,  DCE, and vinyl chloride
(VC) are thought to  be  present at the site  due to
anaerobic  degradation of  PCE.   For the  off-site
analyses, the  applicable  standard target analyte list
for each analytical method  was employed, which
included additional compounds beyond  those shown
in Table 3-2.

A sampling array was established over  the site with
spacing outside the building of roughly 33 ft by 33 ft
(10m by 10m) and spacing  inside the building of
roughly 10 ft by  10 ft (3m by 3m). The sampling
array is shown in Figure 3-1.  The sampling array
included eight rows of sampling points: A through H.
Row "A" was behind the back of the building and
Row "H" was along  Grand Avenue.  The potential
sampling locations on each row were numbered from
low to high in the southwest  to northeast direction
(i.e., sampling locations Al, Bl, Cl, etc. were along
the southwest property boundary).   Additional rows
of potential  sampling  locations  were  established
inside the building (e.g.,  Rows "M" through  "S").
The sampling array included more potential locations
than were actually sampled.

Direct-push drill rigs were used to collect samples.  A
66DT unit  mounted  on a flat-bed  truck was used
outside the building  and a dolly  probe was used
                                                    Figure 3-2. Large Direct-Push Rig

                                              indoors.  The two rigs are shown in Figures 3-2 and
                                              3-3.  Drilling  was performed  by ESN  South of
                                              Corpus  Christi, Texas under the supervision of two
                                              URS  geologists.  The drillers decontaminated non-
                                              dedicated sample equipment with soap and water and
                                              used high-pressure washers  for large equipment. A
                                              Triad approach was used (USEPA, 2003a)(ITRC,

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+      *
*'      «
                 -f      -*•
+        +       +
MW*
* * l*sa> *
"' K ° ^A " . ""









A
•
Soil BonaQ LKB&m
DPT Sample Location
Modiiunns i'rtjll LpMl^in

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                               Table 3-1.  Schedule of Field Activities
Date
April 11 -15
August 29
August 29 - 30
August 3 1
October 11
October 20 -21
December 13-14
December 13-14
Activity
Collect soil, groundwater, and soil-gas sampling and use on-site analysis to
characterize site. Collect indoor air and soil-gas samples for off-site analysis.
Install groundwater monitoring well MW-9.
Perform second round of indoor air sampling.
Inspect site for design of control system.
Install groundwater monitoring well MW-10.
Collect groundwater samples from 9 o f 10 monitoring wells (no sample
be obtained from MW-2).
could
Collect groundwater samples from MW-2, -9, and -10.
Perform slug tests at MW-7, -9, and -10.
                            Table 3-2.  Primary Compounds of Interest
Compound
Tetrachloroethylene
Trichloroethylene
1 ,2-Dichloroethylene
Vinyl Chloride
Benzene
Toluene
CAS#
127-18-4
79-01-6
156-59-2
156-60-5
75-01-4
71-43-2
108-88-3
Synonyms
PCE, Perk,
perchloroethylene
TCE
cis-l,2-DCE
trans-l,2-DCE
VC, chloroethene
~
~
Molecular
Weight
165.8
131.4
96.9
62.5
78.1
92.1
Conversion Factor
for Air Samples
1 ppb = 6.78 |ag/m3
1 ppb = 5.37 |ag/m3
1 ppb = 3.97 |ag/m3
1 ppb = 2.56 |ag/m3
lppb = 3.19|ag/m3
1 ppb = 3.77 |ag/m3
2003).  In this approach, real-time or rapid response
analytical data is used on-site to reach decisions. The
intent  is  to  characterize  the  site  with  as  few
mobilizations  as possible,  so  the  on-site analytical
capabilities are very important to the success of the
approach. In this study, soil, groundwater, and soil-
gas  samples  were  collected  using   direct-push
equipment and the samples were  analyzed on-site.
Analytical results  were plotted  at the site as  they
  The US EPA TRIAD approach is described at the
following websites:
  http://www.epa.gov/tio/triad/
  http://www.clu-in.org/download/char/2004triadfactsheeta.pdf
became available and used to make decisions about
where to collect additional samples.

The  depth to bedrock was obtained at 33  locations
where  probes were  pushed,  plus at  eight  existing
monitoring wells near the building.   Groundwater
samples were obtained from five locations beneath
the building and 23 locations outside the building. A
total of 77 discrete soil samples were collected from
15 locations: 20 samples from four locations outside
the building and 57 samples from 11 locations within
the building. All soil samples were collected within
or very near the building.  Soil gas  sampling was
attempted at 24 locations. The general approach for
evaluating vapor  intrusion  was to  collect  time-
integrated soil-gas and indoor air  samples in
                                                    10

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            Figure 3-3. Dolly Rig

evacuated, stainless-steel canisters for off-site TO-15
analyses.

3.2.2   Second Round of Air Monitoring

Based   on   the   results  of   the  initial   site
characterization, additional samples were collected to
evaluate the potential for vapor intrusion. Indoor air
samples were  collected at two  locations during the
first round of sampling and at one location during the
second  round  of  sampling.   The  analyses  were
performed off-site.

Tracer gas tests were performed in conjunction with
the second round of indoor air sampling.  Pure sulfur
hexafluoride (SF6) was introduced into the sub-slab
to verify that  vapor intrusion was occurring.   Pure
helium was  released within the building  to measure
the air exchange rate for the building. Measurement
of helium inside the structure was performed to allow
calculation of the  ventilation  air flowrate (Qsidg)
using  the  ratio  technique.     Under  steady-state
conditions, the dilution of the tracer  gas  is equal to
the ratio of the building ventilation and the tracer gas
release rate:
                    : V
                     ^Mracer
(Eq. 3-1)
Where:
    Qsidg  = ventilation air flowrate,
    XBidg  = tracer gas concentration in indoor air,
    Qtracer  = tracer gas release rate, and
    Xtracer  = tracer gas concentration at source.

Qtracer and Xtiace!: were known, and XBidg was measured
in the field.

3.2.3    Installation of Groundwater
         Monitoring Wells

Two  groundwater  monitoring wells  (MW-9 and
MW-10) were installed in addition to the eight wells
that already were present at the site.   Hollow-stem
auger  drilling was  used to advance boreholes and
install threaded  2-in. (5 cm)  diameter schedule-40
PVC  casing,  0.010-in. (0.025 cm) factory-slotted
PVC  screen,  and a threaded end  cap.  The  annulus
space around each well screen was filled with 20 x
40 mesh silica filter sand to a minimum of 2 ft (0.6m)
above  the top of the screen.   The sand pack was
sealed  from  the   overlying  annulus  space with
hydrated 3/8-in.  (1 cm) bentonite  pellets  installed to
just below ground surface.  Wells were completed at
ground surface with a flush-mounted 8-in. (20 cm)
diameter manway housed within a concrete pad.

The  drilling   was   performed  by   Groundwater
Monitoring  of  Grand  Prairie,  Texas  under  the
supervision of a URS geologist. One well (MW-10)
was   installed  down-gradient  of   the   former
drycleaning  facility along Medill Street near  its
intersection with Grand Avenue.  This location was
selected to help delineate the existing groundwater
plume and was expected to be free of contamination.
The second well (MW-9) was installed  adjacent to
the existing monitoring well, MW-8.   The depth to
bedrock in this area is approximately 76 ft (23m) bgs
whereas MW-8  extends to only about 50 ft (15m)
bgs. MW-9 was installed to extend to the top of the
bedrock. Drilling logs for all ten monitoring wells are
given in Appendix A.

3.2.4    Slug Tests

Slug tests were performed at MW-5, MW-7, and
MW-9 using  four  and six ft (1.2  and  1.8m) long
slugs  constructed of  1-in.  (2.5 cm) diameter PVC
pipe filled with  clean gravel and  sealed with water-
tight caps. The rise and fall of the water level during
each test was measured using  a pressure transducer.
The slug test data was used to calculate approximate
                                                   11

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hydraulic conductivity values, which were converted
into  approximate well yield values using  TCEQ
Regulatory  Guidance  document  RG-366/TRRP-8
(TCEQ, 2003).  In addition to the TCEQ guidance,
the methodology for slug testing presented in Butler,
et al. (1996) was consulted for designing, conducting,
and evaluating the tests. The data were plotted using
AQTESOLV™  software.

The tests were conducted  to determine if the aquifer
production rate  was above or below  150  gallons per
day  (gpd)(570  L/day),  which  is  the  regulatory
boundary between Class  2 and Class  3  aquifers  in
Texas (TCEQ, 2003).

3.2.5   Design of Control System

A building inspection was  performed  by  Doug
Kladder of Colorado Vintage  Companies (CVC).
The  concrete  slab was  checked for subterranean
beams or other barriers to  gas flow via a sound check
using a rubber mallet. Holes were drilled through the
slab at various locations and the differential pressure
between the building and the soil was measured using
an  Infiltec  DMI  model  digital  micromanometer
(http://www.infiltec.com).    To  determine the  gas
permeability of the sub-slab  fill material, a vacuum
was  applied  at a central  hole and  the  pressure
differential was  measured at various lateral distances.

3.3     Sampling Procedures

The  sampling  methods  used  in  this  study  are
summarized in  Table 3-3.  Field data sheets for the
roundwater sampling for off-site analysis are given as
Appendix B.  Field data sheets for soil-gas sampling
for both on-site and off-site  analysis  are given as
Appendix C.   Sub-slab  and indoor  air sampling
locations are shown in Figure 3-4.
3.3.1   Sample   Collection   for
        Analyses
On-Site
Groundwater, soil, and shallow soil-gas samples were
collected for on-site analyses and used to characterize
the subsurface contamination at the site.

Groundwater
One-inch (2.5 cm) PVC was driven to depth and
groundwater recovered by applying suction to YA in.
(0.64 cm)  polyethylene tubing.   All groundwater
samples were unfiltered, grab samples.

Soil Samples
Soil  samples were collected with 2 in. by 3 ft (0.05
by  0.9m)  split  spoon  samplers  lined  with clear
acetate.   Soil cores were visually examined  and
screened using a portable photo-ionization detector
(PID).  The meters were calibrated daily according to
manufacturer's instructions.   All soil samples were
grab samples of approximately  5g collected from
cores at discrete  depths using  disposable EnCore
samplers and placed  in laboratory-supplied vials.
Sampling was intentionally biased towards soils with
relatively high levels  of  VOCs based on  visual
observation    and    the    PID   measurements.
                           Table 3-3.  Summary of Sampling Methods
Analysis
Location
On-Site
Off-Site
Medium
Groundwater
Soil
Soil-Gas
Groundwater
Soil
Sub-Slab and Shallow Soil-Gas
Indoor and Ambient Air
Sampling Method
Direct Push / Grab
Direct Push /Grab
Direct Push /Sorbent Trap
Low flow / Micropurge
Direct Push /Grab
Canister
Canister
                                                  12

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                Exhaust
                 Hood
                   20.9m
                  Fry
                 Room
    SS-4
       X
     • R-2

Back Room
                                         • A
                                   ,0-1
                                           xSS-3
                                      ®IA-3
IA-1

Front Room

         X
        SS-1
                                                          P4     IA-2
                                                       N-4,
                                                                SS-2
                                                                          Continuation
                                                                          of Strip Mall
                                                D3
                                                                 D4
                                                                      Dining
                                                                       Area
                                  Ambient air sample
                 Key
                 • - Soil-gas sampling location
                 X - Sub-slab soil-gas sampling location
                 ®- Air sampling location
                 A.- Helium tracer release point
                 • - Pressure-differential measurement location

                   Figure 3-4.  Sub-Slab and Indoor Air Sampling Locations
Soil Gas
Soil-gas samples were collected at a depth of five ft
(1.5m) below ground surface  [bgs] using Geoprobe
Post Run Tubing (PRT).  The probe was driven to the
desired  depth and the  rod pulled  back from the
disposable drive tip.  A  ten ft (3m)  length of YA in.
(0.64  cm) polyethylene  tubing was fed down the
middle of the rod and turned counter-clockwise until
the PRT adapter screwed into  the point holder.  The
probes were  left in place for a minimum of 30
minutes and the lines purged  of three void volumes
before the start of sample collection. The soil-gas
                   samples generally were collected by drawing sample
                   air through a sorbent tube for 15 minutes at a flow
                   rate of 1.0 L/min.

                   Rotometers were used to control  the flow  rate of
                   sample  air during collection of soil-gas samples using
                   sorbent tubes.   The multipoint  calibrations of the
                   rotometers  using NIST-traceable flow devices  were
                   completed  at the URS  Austin laboratory,  prior to
                   deployment to the field.  Using these calibration data,
                   sample  flows were calculated.
                                                  13

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Soil gas sampling was attempted at 24 locations, but
samples were obtained at only  10 of these locations.
The remaining  14 locations had high resistance to
soil-gas flow  and no  sample  could be obtained.
Sample collection was  not attempted at  locations
where there was no detectable  reduction in pressure
over a 15-minute period after inducing a vacuum of
15 in.  (38 cm) Hg.

3.3.2   Sample   Collection   for   Off-Site
        Analyses

Groundwater, soil, shallow soil-gas samples, indoor
air, and ambient air samples were collected for off-
site analyses. The canister samples collected during
the first sampling event are summarized in Table 3-4.
All canister samples were two-hour time-integrated
samples collected  in 6-L evacuated,  stainless-steel
canisters.

Groundwater
Samples were  collected  from the  10 permanent
groundwater monitoring wells  at the  site.  The two
new wells were developed prior to sampling.  Wells
were purged and groundwater samples were collected
from each well using a  12V submersible pump and
the low-flow  sampling  (micropurge)  technique.
Water   quality   parameters   collected   included
temperature,  pH,  specific conductivity, turbidity,
oxidation-reduction potential, and dissolved oxygen.
Stabilization  of all water  quality  parameters  was
achieved and documented prior to sample collection.
During sample collection, groundwater was  pumped
directly into pre-preserved sample containers.  Field
personnel  donned  a  new pair  of disposable  nitrile
gloves prior to collecting each  sample. Immediately
following sample collection, sample containers were
stored on ice in coolers.  All sample containers were
repacked on fresh ice prior to being shipped.
Pumps and tubing were decontaminated in a plastic
tub filled with a mixture of Liquinox soap and water,
and rinsed in a plastic tub of clean water.  The pump
was operated within each tub to ensure the circulation
of soap and water inside of the pump housing and
tubing during the cleaning process.

Soil Samples
Extracts from three soil samples analyzed on-site
were sent off-site for confirmatory analysis. Extracts
were used rather than soil to minimize the variability
in the starting material used by analysts at each
location.

Soil Gas
Soil-gas  samples  were  collected  at two depths.
Shallow  soil-gas  samples  were   collected  at  six
locations at a depth of 5 ft (1.5m) below the ground
surface (bgs): four locations inside the building  and
two locations just outside the building. At the inside
locations,  sub-slab  soil-gas  samples  also  were
collected by drilling through the floor and collecting
soil gas from immediately beneath the concrete slab.

The shallow soil-gas samples were collected using
the Geoprobe Post Run Tubing (PRT) system
described above. Canister samples were collected
after the collection of sorbent tube samples.

The sub-slab soil-gas probes consisted of a 1A in.
(0.64 cm) swagelok union connected to a 4 in. (10
cm) length of stainless steel tubing that extended to
near the bottom of the slab A 2 in. (5 cm) deep
starter hole was drilled using a hammer drill and a
7/8 in. (2.2 cm) bit. The hole was continued down
through the slab using a 5/16 in. (0.79 cm) bit. The
probes were sealed using quick-dry, expanding
cement. The probes were left in place for a minimum
of 30 minutes and lines purged of three void volumes
before the start of sample collection. A 2 ft (0.6m)
length polyethylene of tubing was used to connect the
canister to the sub-slab probe.
       Table 3-4. Canister Samples for Off-Site Analysis During April Sampling Event
Type
Indoor Air
Sub-Slab Soil-Gas
Soil-Gas
Ambient Air
Locations
2
4
4
1
Comments
2-hr integrated samples collected at breathing zone height
Samples collected from immediately beneath the building slab
Samples collected from 5 ft (1.5m) depth near sub-slab
sampling locations
For comparison with indoor air results
                                                   14

-------
Differential pressure  measurements  were made at
each  soil-gas  sampling location  using a  Dwyer
magnehelic   gauge   (http://www.dwyer-inst.com)
capable of reading to the nearest 0.005 in. H2O (1
Pa).3

Indoor Air
Two rounds of indoor air samples were collected: the
first round in April 2005 and the second in August
2005.   During the April sampling  event,  samples
were collected at two locations: one location within
the former dry  cleaner business  and one  location
within  the  adjacent  "dining  room" area  that is
connected  to  the former dry cleaner business (see
Figures 2-3 and 2-4).  Samples  were collected at
breathing zone height: four to five ft (1.2 to 1.5m)
above floor level.  The building HVAC system was
not in use, nor had it been used in the days before
sampling.  External building doors were kept closed
during sampling; the building  has no windows that
can be opened. An ambient air sample was collected
just outside the building, concurrent with the indoor
air samples.

During the August sampling event,  indoor air was
collected at breathing zone height within the middle
section of the restaurant (i.e., "fry room").  The
building HVAC system was operational and in use at
that time.  External building doors were kept closed
during sampling.

Tracer gas tests were performed in conjunction with
the second round of indoor air sampling. Pure sulfur
hexafluoride (SF6) was introduced into the sub-slab at
a rate  of 0.0025 L/min for about 24 hours prior to
sampling to verify that vapor intrusion was occurring.
No attempt was made to measure the average sub-
slab concentration of SF6.  Pure helium was released
within the building at a rate of 3 L/min for about 24
hours prior to sampling to measure the air exchange
rate  for the building.   During the  tracer tests,  air
mixing within the building space was enhanced using
two  box fans.  Rotometers were  used during the
August sampling event to control the rate of tracer
gas releases.   The  multipoint calibrations  of the
rotometers using NIST-traceable flow devices were
completed  at  the URS  Austin laboratory,  prior to
deployment to the field.  Using these calibration data,
gas flows were calculated.
A grab sample was collected prior to the release of
any tracer gases  to document the background levels
of SF6 and He within the building. A two-hour time-
integrated   indoor   air   sample   was   collected
approximately 24 hours after the tracer releases were
started. Three additional grab samples were collected
at hourly intervals after the time-integrated sample
was   collected   to  look  at  short-term  temporal
variability.

3.4     Analytical Procedures

The  analytical   methods  used in  this  study  are
summarized in Table 3-5.  During the first phase of
work, groundwater, soil, and soil-gas samples were
analyzed on-site  using  EPA Method  8265, direct
sampling ion trap mass spectrometry (DSITMS)(US
EPA, 2002). The on-site analyses were performed by
Dr. William Davis of Tri-Corders  (http://www.tri-
corders.com/).

Groundwater, confirmatory soil samples,  and waste
samples were analyzed for VOCs by SW-846 Method
8260 at Kemron's analytical laboratory in Marietta,
Ohio.   In  addition,  groundwater  samples were
analyzed  by  Kemron   for  monitored   natural
attenuation  (MNA)  parameters:  chloride,  nitrate,
sulfate, ferrous ion, and methane, ethane, and ethene.
Field personnel  measured dissolved oxygen, redox
potential, etc. of groundwater samples in the field
using an YSI 55 MPS instrument or equivalent.

Soil gas and air samples were analyzed off-site at Air
Toxics Ltd's analytical  laboratory in Folsom, CA.
VOCs were  determined by US EPA Method TO-15
(US EPA, 1999).  Soil-gas samples were analyzed in
full-scan mode.   The  indoor air  and ambient air
samples were analyzed by Selective Ion Mode (SIM)
to achieve better analytical sensitivity.  The primary
compound of interest was PCE, which is a widely-
used dry cleaning solvent.  The common degradation
products  of PCE  also  were  included  as  target
analytes:  TCE, DCE, and VC.

Helium was  analyzed by ASTM Method D-1946; the
reporting limit was approximately 0.01%.   SF6 was
analyzed by gas chromatography with an  electron
capture detector  (GC-ECD).  The reporting limit for
SF6 was approximately 0.2 ppbv.
  One atmosphere (atm) = 1013 millibars (mbar) = 101,300
Pascals (Pa) = 29.9 inches of mercury (in. Hg) = 1033
centimeters of water (cm H2O) = 760 Torr. One Pa = 10
g/cm-sec2 = 0.010 cm H2O = 0.0040 in. H2O.
                                                   15

-------
3.5     Sample  Handling  and  Chain  of
        Custody Procedures

Similar handling procedures were employed for both
the liquid and indoor air samples.  Upon completion
of the collection of each field sample, the samples
were labeled with the following information:

    •   ID number;
    •   Project name
    •   Sampling location;
    •   Sampler; and
    •   Date & time of sample collection.

The samples were logged into a field notebook.  At
the end of the sampling  effort, the samples were
packed  and  shipped  to  the  off-site  analytical
laboratory.  All samples submitted to the laboratory
were documented on a chain-of-custody form that
accompanied the shipment of samples from the field
to  the  lab.     The   samples   and  other  field
documentation  records were shipped  by  FedEx
overnight service.

Groundwater and Soil Extract Samples
Sample  containers  were  completely  filled with
minimal air-filled  headspace.  Samples were stored
and shipped at approximately 4°C.
Air Samples
Canister pressures were checked in the field prior to
sampling.   Post-sampling   pressures  also  were
checked.   Canister  samples   do   not  require
refrigeration or  any  special  handling techniques
during shipping, but the canister valves must be
securely closed  (finger-tight only), Swagelok plugs
firmly attached,  and the canisters packed in shipping
crates provided by the laboratory.

Sample identification for canister samples followed
this general protocol:

GP-IAX-MMDDYY-R-001
Where:
    GP

    XXX
    MMDDYY =
    R
    001
identifies  the   project  as  the
Grand Plaza site;
identifies the sampling location
(e.g., IA-1);
Month, Day, Year;
Sample type—R for routine; and
Sequential sample number.
             Table 3-5.  Summary of Sampling and Analytical Methods for VOCs
Medium
Groundwater
Soil
Soil-Gas
Air
Analysis
Location
On-Site
Off-Site
On-Site
Off-Site
On-Site
Off-Site
Off-Site
Analyte
VOCs
VOCs
Chloride
Nitrate
Sulfate
Ferrous Ion
Methane, Ethane, Ethene
VOCs
VOCs
VOCs
VOCs
VOCs
SF6 (Tracer Gas)
Helium (Tracer Gas)
Analytical Method
EPA Method 8265 (DSITMS)
EPA Method 8260
SW846 Method 9056
SW846 Method 9056
SW846 Method 9056
SMS 500
RSK175
EPA Method 8265
EPA Method 8260
EPA Method 8265
EPA TO- 15 full-scan
EPATO-15SIMs
GC-ECD
ASTMD-1946
                                                 16

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                                           SECTION 4
                                            RESULTS
The   on-site   analytical   data   for  the   site
characterization effort are presented below, followed
by the data for the groundwater sampling,  the slug
tests, and the vapor intrusion study.  A summary of
results  for   the   health  &  safety  and  waste
characterization & disposal efforts also is given.

4.1     On-Site Analytical Results for Site
        Characterization

4.1.1   Groundwater

The results of the on-site analysis of groundwater
samples are shown in Table 4-1 (all tables are given
at the  end of the section).   The  applicable  State
standards are included  in the table for comparison
purposes.  Groundwater samples were collected at 28
locations.  Five samples were collected from within
the building, four of which were collected adjacent to
soil  boring  ("SB")  locations from a previous
investigation.  Twenty-three samples were collected
from the sampling array outside the building.  Sample
collection was attempted at five additional locations
where  bedrock  was relatively  shallow,  but  no
groundwater could be  obtained at these locations.
The  depth to  bedrock was measured  at  all  33
locations where probes were pushed and at the eight
existing monitoring wells.  The depth to  bedrock is
plotted in Figure 4-1.

4.1.2   Soil

The results of the on-site analysis of soil samples are
shown in Table 4-2.  The applicable State standards
are included in the table for comparison purposes. A
total of 77 samples were collected from 15 locations
within or very near the building. Fifty-seven samples
were collected from 11  locations within the building
and 20 samples were collected from  four locations
outside the building.  The results are shown in Table
4-2. The samples marked "SB" were collected at the
four locations where soil  borings  were collected
during previous studies at the site. A cross-section of
the site showing sub-surface geological  features is
shown in Figure 4-2.

4.1.3   On-Site Soil Gas

The results of the on-site analysis of soil-gas samples
are shown in Table 4-3.  Sampling was attempted at
24 locations, but samples were obtained at only 10 of
these locations. The remaining 14 locations had high
resistance  to soil-gas flow and no sample could be
obtained.  Presumably, this was due to  the clayey
nature of the surface soils. In addition to the soil-gas
samples at 5 ft (1.5m) depth, soil-gas samples were
collected  at the four  sub-slab  soil-gas sampling
locations.  These data also are shown in Table 4-3.

4.2     Results  of   Off-Site   Analysis  of
        Groundwater

Groundwater samples were collected from nine of the
ten wells on October 20-21, 2005. No sample could
be obtained from MW-2 due to insufficient water
volume within the well.  The samples were analyzed
off-site by EPA Method 8260 for a list of 66 target
compounds.    The  full  analytical  reports for  the
October VOC groundwater samples are given in
Appendix  D. Eight VOCs  were detected in one or
more of the samples; these results are summarized in
Table  4-4.   The  applicable  State  standards  are
included in the table for comparison purposes.

Samples were collected again for VOCs from three of
the groundwater monitoring wells on December 13-
14, 2005.   The full   analytical reports for  the
December VOC  groundwater samples are given in
Appendix  E.  Eleven VOCs were detected in one or
more of the samples; these results are summarized in
Table 4-5.
                                                  17

-------
00

-------
Grand Plaza Stopping Cenief
    3103 Grand Av*nue
       Dallas. T

-------
The groundwater was monitored in the field for pH,
conductivity,  and various other parameters.  These
results are given in Table  4-6.   The groundwater
samples collected in October also were analyzed for
monitored  natural attenuation (MNA) parameters.
The  MNA results  are given  in Appendix D and
summarized in Table 4-7.

The groundwater sample  collected  in October from
MW-9 was analyzed for various elements and for
semi-volatile  organic compounds (SVOCs).  These
results are given in Appendix D and summarized in
Table 4-8.

4.3     Results of Slug Tests

Tests  were performed at three wells (MW-7, MW-9,
and MW-10) to estimate hydraulic conductivity. The
results are given in Appendix F.

4.4     Evaluation of Vapor Intrusion

4.4.1   Off-Site Analysis of Soil-Gas

Shallow soil-gas samples were collected from a depth
of 5 ft (1.5m) bgs at six locations: two locations just
outside the building and four locations beneath the
building. Sub-slab soil-gas samples were collected at
three  locations. Sampling was attempted at a fourth
sub-slab  location  (SSI),  but no  sample could be
obtained.    A  duplicate  sample  (i.e.,  sequential
duplicate) was collected at location SS3.

The  results for selected  compounds are  shown in
Table 4-9.  The full analytical reports for the off-site
analysis of soil-gas samples are given as Appendix G.
Each   sub-slab  sample  was  collected  in  close
proximity  to  a  shallow  soil-gas  sample.   The
comparison of the shallow and sub-slab soil-gas data
is shown in Table 4-10.

4.4.2  Off-Site  Analysis  of  Indoor  and
        Ambient Air Samples

Two indoor air samples and one outdoor ambient air
sample were  collected during April 2005.  The full
analytical reports for the off-site analysis of these air
samples are given as Appendix H.  The results for
these   samples  are  summarized  in  Table  4-11.
Additional indoor air samples were collected during
August 2005 to further evaluate vapor intrusion. The
full analytical reports for the off-site analysis of these
air samples are given as Appendix I. The results for
these  samples are summarized in Tables 4-12 and
4-13.   Sample GP-101  was collected prior to the
release of any tracer gas to determine the background
levels of the tracer gases in the indoor air.  The
remaining samples  were collected after  the  tracer
gases had been continuously released for the previous
24 hours.

4.4.3   Design of Control System

The site inspection report from the design engineer is
given as Appendix J.   The  specifications for the
control system are given in Section 6.0.

4.5     Health & Safety

There were  no OSHA recordable injuries  for this
project.   There were no  reports of near misses  or
minor injuries requiring First Aid.  There were  no
incidents where drilling breached underground utility
lines.

4.6     Waste Disposal

Samples of waste liquid and soil were collected  by
URS personnel and analyzed by  the same off-site
laboratory  that  analyzed  groundwater  and soil
samples.   All  materials  were found to be  non-
hazardous.  Wastes were transported and disposed of
by Environmental Industries, LP of Piano, Texas.

4.7     Results  of Quality  Control  (QC)
        Checks

Duplicate groundwater samples from seven locations
were analyzed on-site.  These  results are shown in
Table 4-14.

Duplicate soil samples for two depths at one location
were analyzed on-site.  These  results are shown in
Table 4-15.  Aliquots of the water extracts for three
soil samples were analyzed by the off-site laboratory
for confirmatory purposes. The full analytical report
for these analyses is included as Appendix K. The
comparison  of the  on-site and off-site  analytical
results is shown in Table 4-16.

Soil gas samples from seven locations were analyzed
both on-site and off-site.   The comparison of the
analytical results for PCE is shown in Table 4-17.

The results  for  QC samples  for the groundwater
sampling are given in Tables 4-18 and 4-19.  The full
analytical reports for these samples may be found in
Appendices D and E.
                                                  20

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                               Table 4-1.  Results of On-Site Analysis of Groundwater Samples
Sampling Location
Concentration (ng/L)
PCE
TCE
DCE
Vinyl Chloride
Benzene
Toluene
Sampling Array Outside the Building
A2
A3
A4
A5
A9
Bl
C2
Dl
D2
D5
E4
F3
F7
G2
G4
G5
H2
H3
H4
H5
H7
H9
Hll
1.4
7.5
62
<5.4
<5.4
<2.9
89.5
<2.9
67.2
<2.8
135
40
<5.4
2.9
15.3
68.3
<5.4
37.9
2
2.8
<2.8
9.9
1.1
<3.9
1.4
12
<3.9
<3.9
<1.5
32.7
<1.5
13
<2.9
19.3
0.8
<3.9
<2.9
<1.5
7.6
<3.9
4
<1.5
<3.9
<2.9
1.6
1
3.9
4.2
85.3
<2
<2
<4.4
146
<4.4
30.6
<3.9
87.2
3.6
<2
<3.9
<4.4
40.2
<2
15.1
<4.4
3.2
<3.9
7.3
<3.9
<2
<4
<4
<2
<2
<4.4
<4
<4.4
<4
<4
<4.4
<4.4
<2
<4
<4.4
<4.4
<2
<4
<4.4
<2
<4
<2
<4
<2.7
<2.7
<2.7
<2.7
<2.7
<3.1
<2.7
<3.1
<2.7
<2.7
<3.1
<3.1
<2.7
<2.7
<3.1
<3.1
<2.7
<2.7
<3.1
<2.7
<2.7
<2.7
<2.7
<3.1
<3.6
<3.6
<3.1
<3.1
<3.1
<3.6
<3.1
<3.6
<3.6
<3.1
<3.1
<3.1
<3.6
<3.1
<3.1
<3.1
<3.6
<3.1
<3.1
<3.6
<3.1
<3.6
Additional Locations Within Building
03
SB01
SB02
SB03
SB04
155
8.9
15.8
130
15.3
37.6
2.9
5.3
21.7
1
364
124
176
119
19.2
<4.4
<2
<2
<2
<4
<3.1
<2.7
<2.7
<2.7
<2.7
<3.1
<3.1
<3.1
<3.1
<3.6
Regulatory Standards"
TCEQ PCLs
550,000
270,000
14,000,000 (cis)
6,100
85,000
11,000,000
a Texas Risk Reduction Program (TRRP) Tier 1 Protective Concentration Levels (PCLs) for the inhalation pathway at a 0.5-acre source area, commercial
setting (AirGWinh_v).

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                                      Table 4-2. Results of On-Site Analysis of Soil Samples
Sampling Location
Concentration (|o,g/Kg)
PCE
TCE
DCE
Vinyl Chloride
Benzene
Toluene
Sampling Array Outside the Building
B2 - 1 ft
B2 - 5 ft
B2 - 10 ft
B2 - 15 ft
B2 - 20 ft

D2 - 1 ft
D2 - 5 ft
D2 - 10 ft
D2 - 15 ft
D2 - 20 ft

D3 - 5 ft
D3 - 10 ft
D3 - 15 ft
D3 - 17 ft
D3 - 20 ft

D4 - 1 ft
D4 - 5 ft
D4 - 10 ft
D4 - 15 ft
D4 - 20 ft
<10.8
<10.8
29.9
37.4
14.5

<11.9
0.0
95.9
122
102

<10.8
10.7
316
14.4
160

<10.8
<10.8
170
46.7
88.1
<11.2
<11.2
<11.2
5.5
<11.2

<6.2
6.7
22.9
10.8
<6.2

<11.2
34.4
52.8
0.0
14.9

<11.2
<11.2
15.6
22.8
7.6
<14.7
<14.7
<14.7
<14.7
<14.7

<17.6
81.7
45.8
50.2
<17.6

130
52.3
0.0
0.0
45.3

<14.7
<14.7
<14.7
<14.7
<14.7
<15.2
<15.2
<15.2
<15.2
<15.2

<17.9
<17.9
<17.9
<17.9
<17.9

<15.2
<15.2
<15.2
<15.2
<15.2

<15.2
<15.2
<15.2
<15.2
<15.2
<10.4
<10.4
<10.4
<10.4
<10.4

<12.4
<12.4
<12.4
<12.4
<12.4

<10.4
<10.4
<10.4
<10.4
<10.4

<10.4
<10.4
<10.4
<10.4
<10.4
<13.7
<13.7
<13.7
<13.7
<13.7

<12.6
<12.6
<12.6
<12.6
<12.6

<13.7
<13.7
<13.7
<13.7
<13.7

<13.7
<13.7
<13.7
<13.7
<13.7
to
to

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                                 Table 4-2.  Results of On-Site Analysis of Soil Samples (continued)
Sampling Location
Concentration (|o,g/Kg)
PCE
TCE
DCE
Vinyl Chloride
Benzene
Toluene
Sampling Locations Within the Building
M3 - 6 ft
M3 - 10 ft
M3 - 13 ft

N2 - 1 ft
N2 - 4 ft
N2 - 9 ft
N2 - 12 ft
N2 - 16 ft
N2 - 23 ft
N2 - 28 ft

N6 - 0.5 ft
N6 - 3 ft
N6 - 6 ft
N6 - 13 ft

O3 - 0.5 ft
O3-3.5ft
03 - 7 ft
O3 - 10 ft
O3 - 16 ft
O3-21ft
O3 - 27.5 ft
O3 -33.5ft
O3 - 38 ft
18.6
122
164

3,440
878
1,200
1,290
603
461
522

<11.9
<11.9
<11.9
52.0

1,770
<10.8
140
291
204
342
114
130
51.6
<6.2
<6.2
2.0

249
77.4
263
220
62.3
28.9
40.7

<6.2
<6.2
<6.2
<6.2

100
<11.2
102
70.6
32.4
38.5
16.4
18.6
<11.2
155
261
223

2,670
6,390
2,090
1,630
654
429
449

<17.6
<17.6
<17.6
18.3

<14.7
275
818
509
285
318
161
190
26.9
<17.9
<17.9
<17.9

<17.9
<17.9
<17.9
<17.9
<17.9
<17.9
<17.9

<17.9
<17.9
<17.9
<17.9

<15.2
<15.2
<15.2
<15.2
<15.2
<15.2
<15.2
<15.2
<15.2
<12.4
<12.4
<12.4

<12.4
<12.4
<12.4
<12.4
<12.4
<12.4
<12.4

<12.4
<12.4
<12.4
<12.4

<10.4
<10.4
<10.4
<10.4
<10.4
<10.4
<10.4
<10.4
<10.4
<12.6
<12.6
<12.6

<12.6
<12.6
<12.6
<12.6
<12.6
<12.6
<12.6

<12.6
<12.6
<12.6
<12.6

<13.7
<13.7
<13.7
<13.7
<13.7
<13.7
<13.7
<13.7
<13.7
to

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                                 Table 4-2.  Results of On-Site Analysis of Soil Samples (continued)
Sampling Location
Concentration (|o,g/Kg)
PCE
TCE
DCE
Vinyl Chloride
Benzene
Toluene
Sampling Locations Within the Building (contd.)
PI - 0.5 ft
PI - 1 ft
PI -4 ft
PI - 7.5 ft
PI -10.5 ft

P4 - 0.5 ft
P4-1.2ft
P4 - 6 ft
P4 - 12.5 ft
P4 - 17.5 ft
P4 - 20.5 ft

Ql - 3 ft
Ql - 9 ft
Ql - 12.5 ft
Ql -18.5ft
Ql-22ft
Ql-25ft
Ql - 27.5 ft

Rl - 0.5 ft
Rl-3.5ft
Rl - 6.5 ft
Rl - 10 ft
Rl - 15 ft
1,540
69.4
219
511
543

387
90.0
38.1
129
174
126

1,100
785
500
336
<11.9
90.2
158

75.6
<11.9
<11.9
<11.9
24.1
190
10.2
30.2
68.0
60.6

24.3
19.5
<11.2
18.2
23.0
14.2

2,320
513
206
73.3
<6.2
<6.2
3.7

<6.2
<6.2
<6.2
<6.2
<6.2
<17.6
269
250
499
524

146
39.4
<14.7
99.9
177
119

1,340
899
659
313
<17.6
59.6
83.7

<17.6
<17.6
<17.6
<17.6
<17.6
<17.9
<17.9
<17.9
<17.9
<17.9

<15.2
<15.2
<15.2
<15.2
<15.2
<15.2

<17.9
<17.9
<17.9
<17.9
<17.9
<17.9
<17.9

<17.9
<17.9
<17.9
<17.9
<17.9
<12.4
<12.4
<12.4
<12.4
<12.4

<10.4
<10.4
<10.4
<10.4
<10.4
<10.4

<12.4
<12.4
<12.4
<12.4
<12.4
<12.4
<12.4

<12.4
<12.4
<12.4
<12.4
<12.4
<12.6
<12.6
<12.6
<12.6
<12.6

<13.7
<13.7
<13.7
<13.7
<13.7
<13.7

<12.6
<12.6
<12.6
<12.6
<12.6
<12.6
<12.6

<12.6
<12.6
<12.6
<12.6
<12.6
to

-------
                                     Table 4-2.  Results of On-Site Analysis of Soil Samples (continued)
Sampling Location
Concentration (|o,g/Kg)
PCE
TCE
DCE
Vinyl Chloride
Benzene
Toluene
Sampling Locations Within the Building (contd.)
R2 - 0.5 ft
R2 - 3 ft
R2 - 9 ft
R2 - 15.5 ft
R2 - 20.5 ft
R2 - 22.5 ft

R5 - 1 ft
R5 - 6 ft

SB3 - 3 ft
SB3 - 6 ft
SB3 - 10 ft
870
<10.8
37.7
255
51.8
39.2

<11.9
17.7

<11.9
58.1
71.9
134
<11.2
<11.2
33.8
9.6
6.5

<6.2
9.5

<6.2
3.5
6.6
<14.7
<14.7
63.7
142
44.1
28.6

<17.6
13.0

<17.6
19.5
26.7
<15.2
<15.2
<15.2
<15.2
<15.2
<15.2

<17.9
<17.9

<17.9
<17.9
<17.9
<10.4
<10.4
<10.4
<10.4
<10.4
<10.4

<12.4
<12.4

<12.4
<12.4
<12.4
<13.7
<13.7
<13.7
<13.7
<13.7
<13.7

<12.6
<12.6

<12.6
<12.6
<12.6
Regulatory Standards"
TCEQ PCLs
1,000,000
350,000
17,000,000
68,000
77,000
110,000,000
to
       a Texas Risk Reduction Program (TRRP) Tier 1 Protective Concentration Levels (PCLs) for the inhalation pathway at a 0.5-acre source area, commercial
       setting (

-------
                                         Table 4-3. Results of On-Site Analysis of Soil-Gas Samples
Sampling Location
Concentration (ppbv)
PCE
TCE
DCE
Vinyl Chloride
Benzene
Toluene
Soil-Gas Samples at 5 ft bgsa
C-2
D-3
D-4
D-8
M-3
P-4
Q-l
R-l
R-2
<0.3
<0.4
0.2
<0.3
11
3.8
60
<1
160
<0.4
<0.6
0.2
0.4
0.6
O.4
O.4
<1
0.4
O.5
O.8
0.2
0.5
0.8
O.5
O.5
<2
0.5
O.8
<1
0.4
0.8
<1
O.8
O.8
<3
0.8
O.6
O.9
0.3
0.6
0.9
O.6
O.6
<2
0.6
O.5
O.8
0.3
0.5
0.8
O.5
O.5
<2
0.5
Sub-Slab Soil-Gas Samples'1
SS-1
SS-1BC
SS-3
SS-3 dup
SS-3 dup
SS-3 dup
SS-4
3,700
4,200
140
120
88
100
35
0.6
O.4
O.4
O.4
0.4
0.4
0.2
0.8
O.5
O.5
O.5
0.5
0.5
0.2
<1
O.8
O.8
O.8
0.8
0.8
0.4
0.9
O.6
O.6
O.6
0.6
0.6
0.3
0.8
O.5
O.5
O.5
0.5
0.5
0.3
to
       a No sample was obtained at the following locations due to high vacuum/no flow in the sampling system:  B2, D2, D5, D6, E8, F3, H8, Ml, N4, N6, O3, P6,
         Q3, andR5.

       b No sample was obtained at location SS-2 due to high vacuum/no flow in the sampling system.

       c Location SS-1B was 2 ft from location SS-1

-------
                        Table 4-4.  Results of Off-Site Analysis of Groundwater Samples Collected in October 2005
Sampling
Location
MW-1
MW-2
MW-3
MW-4
MW-5
MW-6
MW-7
MW-8
MW-9
MW-10
Measured Concentration (|4.g/L)
PCE
184
~
4.64
105
25.4
83.3
9.57
12.8
1.15
16.0
TCE
22.2
~
2.16
11.5
3.61
25.0
1.77
1.80
4.42
4.49
Cis-l,2-DCE
140
~
1.29
59.0
1.51
45.7
0.271
0.588
0.344
2.81
Trans-1,2-
DCE
ND
~
ND
0.511
ND
0.54
ND
ND
ND
ND
Chloroform
0.95
~
ND
1.20
0.738
0.267
0.889
1.20
0.501
0.505
Methylene
Chloride
ND
~
ND
ND
ND
ND
ND
ND
0.367
ND
1,4-DCB
ND
~
0.374
0.357
0.457
0.229
0.318
0.487
0.659
0.224
Freon 11
ND
~
ND
0.828
0.877
0.385
1.03
0.626
12.5
0.511
Regulatory Standards"
TCEQ PCLs
550,000
270,000
23,000,000
14,000,000
33,000
2,100,000
37,000,000
5,700,000
to
       DCB = Dichlorobenzene
       DCE = Dichloroethylene
       ND = Not Detected
       a Texas Risk Reduction Program (TRRP) Tier 1 Protective Concentration Levels (PCLs) for the inhalation pathway at a 0.5-acre source area, commercial
       setting (AirGWinh.v).

-------
                       Table 4-5.  Results of Off-Site Analysis of Groundwater Samples Collected in December 2005
Sampling
Location
MW-2
MW-9
MW-10
Measured Concentration (|ig/L)
PCE
408
0.513
21.9
TCE
60.3
3.99
5.18
Cis-l,2-DCE
133
0.421
3.11
Trans-1,2-
DCE
1.04
ND
ND
Chloroform
0.939
0.433
0.524
Methylene
Chloride
ND
ND
ND
1,4-DCB
0.442
0.158
ND
Freon 11
0.389
8.62
0.412
Regulatory Standards1
TCEQ PCLs
550,000
270,000
23,000,000
14,000,000
33,000
2,100,000
37,000,000
5,700,000
to
oo
Sampling
Location
MW-2
MW-9
MW-10
Measured Concentration (ng/L)
Benzene
0.181
ND
ND
Toluene
0.329
ND
ND
1,2-DCA
ND
0.370
ND
Acetone
8.48
ND
ND
Regulatory Standards"
TCEQ PCLs
85,000
110,000,000
55,000
350,000,000
       DCA = Dichloroethane
       DCB = Dichlorobenzene
       DCE = Dichloroethylene
       ND = Not Detected
       a Texas Risk Reduction Program (TRRP) Tier 1 Protective Concentration Levels (PCLs) for the inhalation pathway at a 0.5-acre source area, commercial
       setting (AirGWinh_v).

-------
                     Table 4-6.  Results of On-Site Monitoring of Groundwater Samples Collected in October 2005
Sampling
Location
MW-1
MW-2
MW-3
MW-4
MW-5
MW-6
MW-7
MW-8
MW-9
MW-10
Last Reading in Series Take at Each Well
pH
6.9
~
7.0
6.9
6.9
7.0
6.9
6.9
7.2
7.0
Temperature
(°C)
24
~
26
22
26
24
25
22
22
25
Conductivity
(US/cm)
12
-
11
12
12
11
11
12
10
11
Dissolved O2
(mg/L)
1.0
~
0.3
0.7
0.6
0.2
2.1
0.5
0.2
0.3
ORP
(mV)
47
~
149
52
160
-138
75
77
-83
-149
TDS
(g/L)
7.7
~
7.3
7.6
7.7
7.0
7.3
7.5
6.4
7.5
Depth to Water
(ft)
28.9
~
31.7
29.2
33.1
33.9
32.2
30.6
31.0
33.7
to
VO
O2 = Oxygen

ORP = Oxidation reduction potential

TDS = Total dissolved solids

-------
Table 4-7. Results of Off-Site Monitoring of Groundwater Samples for MNA Parameters
Sampling
Location
MW-1
MW-2
MW-3
MW-1
MW-5
MW-6
MW-7
MW-8
MW-9
MW-10
Chloride
(mg/L)
50.5
~
44.9
50.8
45.3
47.2
51.4
52.2
49.3
50.5
Nitrate
(mg/L)
5.46
~
3.02
5.28
5.30
1.40
5.73
5.06
3.10
3.89
Sulfate
(mg/L)
103
~
94.6
104
105
90.4
98.6
103
60.8
95.5
Iron
(mg/L)
0.0273
-
0.205
0.0434
0.0365
0.194
0.04
0.02
3.10
0.071
Methane
(Hg/L)
1.22
~
159
0.482
396
89.4
0.707
0.458
70.4
19.8
Ethane
(Hg/L)
0.25
~
0.25
0.25
O.25
O.25
O.25
0.25
0.25
0.25
Ethene
(Hg/L)
0.25
~
0.519
0.25
1.94
0.492
O.25
0.25
1.90
0.25
  Table 4-8. Results of Off-Site Monitoring of MW-9 Sample for Selected Parameters
Analyte
Silver
Arsenic
Barium
Cadmium
Chromium
Copper
Lead
Selenium
Zinc
Mercury

SVOCs
MW-9 Result
(mg/L)
O.005
0.0405
0.311
0.0025
0.0182
0.00522
0.00983
O.005
0.0243
0.0001

ND
U.S. EPA MCL
(mg/L)
0.10
0.010
2
0.005
0.1
1.3
0.015
0.05
5
0.002

-
Comment
No EPA MCL. Value shown is secondary standard.
Measured value exceeds the MCL for drinking water






No EPA MCL. Value shown is secondary standard.


Non-detect for all 65 target compounds. Typical DL was 2.6 |J.g/L.

-------
         Table 4-9. Results of Off-Site Analysis of Soil-Gas Samples Collected in April 2005
Sampling Location
Concentration (ppbv)
PCE
TCE
Cis-l,2-DCE
Vinyl Chloride
Benzene
Toluene
Shallow Soil-Gas
D3 - 5 ft
D4 - 5 ft
N4 - 5 ft
P4 - 5 ft
Ql - 5 ft
R2 - 5 ft
39
50
<130
180
780
710
27
18
<130
20
670
100
520
45
29,000
170
1,400
1,200
13
3.8
10,000
69
98
1,500
<4.5
3.0
<130
1.2
<4.3
<7.8
13
5.5
<130
4.6
<4.3
<7.8
Sub-Slab Soil-Gas
SS-2
SS-3
SS-3 dup
SS-4
3,900
2,600,000
2,200,000
8,600
530
170,000
140,000
1,100
860
340,000
290,000
310
<18
<1 1,000
<9,800
<41
<18
<1 1,000
<9,800
<41
<18
<1 1,000
<9,800
500
Table 4-10. Comparison of Results for Shallow and Sub-Slab Soil-Gas Samples Collected in April 2005
Sampling Location
N4 - 5 ft
SS-2

Ql - 5 ft
SS-3

R2 - 5 ft
SS-4
Concentration (ppbv)
PCE
<130
3,900

780
2,600,000

710
8,600
TCE
<130
530

670
170,000

100
1,100
Cis-l,2-DCE
29,000
860

1,400
340,000

1,200
310
Vinyl Chloride
10,000
<18

98
<1 1,000

1,500
<41
Benzene
<130
<18

<4.3
<1 1,000

<7.8
<41
Toluene
<130
<18

<4.3
<1 1,000

<7.8
500

-------
                 Table 4-11. Results of Off-Site VOC Analysis of Indoor Air and Ambient Air Samples for April 2005
Sampling Location
Indoor - 1
(Restaurant)
Indoor - 2 (Dining
Area)

Ambient Air
Concentration (ppbv)
PCE
13
10

0.11
TCE
0.65
0.52

0.036
Cis-l,2-DCE
1.6
1.1

0.036
Vinyl Chloride
O.019
O.018

0.018
Trans-l,2-DCE
O.019
O.018

0.018
1,1-DCE
O.019
O.018

0.018
      Note: All samples were two-hour integrated samples.
                         Table 4-12.  Results of Off-Site VOC Analysis of Indoor Air Samples for August 2005
Sample ID
GP-104
GP-105
GP-106
Concentration (ppbv)
PCE
3.7
16
14
TCE
0.16
0.67
0.64
Cis-l,2-DCE
0.26
1.2
1.1
Vinyl Chloride
O.014
O.014
O.020
Trans-l,2-DCE
O.014
O.014
O.020
1,1-DCE
O.014
O.014
O.020
oo
to

-------
Table 4-13. Results of Off-Site Tracer Gas Analysis of Indoor Air Samples for August 2005
Sample ID
GP-101
GP-102
GP-103
GP-104
GP-105
GP-106
Sampling Date
Aug29
AugSO
AugSO
AugSO
AugSO
AugSO
Sampling Time
0815-0816
0829-0830
0827- 1027
1129- 1130
1255- 1256
1405 - 1408
Helium
(%)
<0.014
0.057
<0.020
<0.014
0.033
0.033
SF6
(ppbv)
<0.27
0.78
0.57
0.55
1.3
2.4
       Table 4-14. Results of On-Site Duplicate Analysis of Groundwater Samples
Sampling Location
A2
A2Dup
A3
A3Dup
G5
G5Dup
H9
H9Dup
SB01
SB01 Dup
SB03
SB03 Dup
SB04
SB04 Dup
Concentration (u.g/L)
PCE
1.4
<5.4
7.5
7.2
68.3
81.1
9.9
5.5
8.9
7.5
130
114
15.3
12.3
TCE
<3.9
<3.9
1.4
2
7.6
10.7
1.6
<3.9
2.9
4.2
21.7
20.5
1
1.5
DCE
3.9
2.5
4.2
4.3
40.2
49.9
7.3
3.6
124
143
119
105
19.2
18.7
Vinyl Chloride
<2
<2
<4
<4
<4.4
<4.4
<2
<2
<2
<2
<2
<2
<4
<4
Benzene
<2.7
<2.7
<2.7
<2.7
<3.1
<3.1
<2.7
<2.7
<2.7
<2.7
<2.7
<2.7
<2.7
<2.7
Toluene
<3.1
<3.1
<3.6
<3.6
<3.1
<3.1
<3.1
<3.1
<3.1
<3.1
<3.1
<3.1
<3.6
<3.6

-------
   Table 4-15. Results of On-Site Duplicate Analysis of Soil Samples
Sampling Location
Rl - 0.5 ft
Rl-0.5ftdup

Rl - 15 ft
Rl-15ftdup
Concentration (jag/Kg)
PCE
75.6
47.6

24.1
40.8
TCE
<6.2
<6.2

<6.2
<6.2
DCE
<17.6
<17.6

<17.6
<17.6
Vinyl Chloride
<17.9
<17.9

<17.9
<17.9
Benzene
<12.4
<12.4

<12.4
<12.4
Toluene
<12.6
<12.6

<12.6
<12.6
Table 4-16. Comparison of On-Site and Off-Site Analysis of Soil Samples
Sampling
Location
SB3 - 10 ft
SB3 - 10 ft
SB3 - 10 ft dup


R5 - 1 ft
R5 - 1 ft

Rl-0.5ft
Rl- 0.5 ft dup
Rl-0.5ft

Laboratory
On-site
Off-site
Off-site
RPD

On-site
Off-site

On-site
On-site
Off-site
RPD
Concentration (jig/Kg)
PCE
71.9
58.8
59.5
-22.4%

<11.9
<11

75.6
47.6
50.6
-21.7%
TCE
6.6
10.8
<11
39.1%

<6.2
<11

<6.2
<6.2
<11

DCE
26.7
13.8
10.0
-93.6%

<17.6
<11

<17.6
<17.6
<11

Vinyl Chloride
<17.9
<11
<11


<17.9
<11

<17.9
<17.9
<11

Benzene
<12.4
<5
<5


<12.4
<5

<12.4
<12.4
<5

Toluene
<12.6
<11
<11


<12.6
<11

<12.6
<12.6
<11


-------
                    Table 4-17. Comparison of On-Site and Off-Site Analysis of Soil-Gas Samples
Sampling
Location
D3 - 5 ft
D3 - 5 ft


D4 - 5 ft
D4 - 5 ft


P4 - 5 ft
P4 - 5 ft


Ql - 5 ft
Ql - 5 ft


R2-5ft
R2 - 5 ft


SS3 - subslab
SS3 - subslab


SS4 - subslab
SS4 - subslab

Laboratory
On-site
Off-site
RPD

On-site
Off-site
RPD

On-site
Off-site
RPD

On-site
Off-site
RPD

On-site
Off-site
RPD

On-site
Off-site
RPD

On-site
Off-site
RPD
Concentration (|o,g/m3)
PCE
<0.4
39
NC

O.2
50
NC

3.8
180
99%

60
780
92%

160
710
77%

140
2,600,000
100%

35
8,600
100%
TCE
0.6
27
NC

O.2
18
NC

0.4
20
NC

0.4
670
NC

O.4
100
NC

0.4
170,000
NC

0.2
1,100
NC
DCE
0.8
520
NC

O.2
45
NC

0.5
170
NC

0.5
1,400
NC

O.5
1,200
NC

0.5
340,000
NC

0.2
310
NC
Vinyl Chloride
<1
13
NC

O.4
3.8
NC

0.8
69
NC

0.8
98
NC

O.8
1,500
NC

0.8
<1 1,000
NC

0.4
<41
NC
Benzene
0.9
<4.5
NC

O.3
3.0
NC

0.6
1.2
NC

0.6
<4.3
NC

O.6
<7.8
NC

0.6
<1 1,000
NC

0.3
<41
NC
Toluene
0.8
13
NC

O.3
5.5
NC

0.5
4.6
NC

0.5
<4.3
NC

O.5
<7.8
NC

0.5
<1 1,000
NC

0.3
500
NC
NC = Not calculated

-------
                        Table 4-18. Results of Off-Site VOC Analysis of Groundwater QC Samples
Sampling
Location
Measured Concentration (|4.g/L)
PCE
TCE
Cis-l,2-DCE
Trans-1,2-
DCE
Chloroform
Methylene
Chloride
1,4-DCB
Freon 11
October 2005 Sampling Event
MW-4
MW-4 dup
Trip Blank
Equipment
Blank3
105
101
ND
0.68
11.5
10.9
ND
0.292
59.0
55.7
ND
ND
0.511
0.415
ND
ND
1.20
1.19
ND
ND
ND
ND
ND
ND
0.357
0.358
ND
ND
0.828
0.868
ND
ND
December 2005 Sampling Event
MW-9b
MW-9 dupb
Trip Blank
0.513
0.475
ND
3.99
3.82
ND
0.421
0.468
ND
ND
ND
ND
0.433
0.468
ND
ND
ND
0.346
0.158
0.209
ND
8.62
7.90
ND
DCB = Dichlorobenzene
DCE = Dichloroethylene
ND = Not Detected
a Carbon disulfide also was detected in the equipment blank at 0.917 |ag/L.
b Samples also contained 1,2-dichloroethane at 0.370 and 0.404 (dup) M-g/L.
                Table 4-19. Results of Off-Site Analysis of Groundwater QC Samples for MNA Parameters
Sampling
Location
MW-4
MW-4 dup
Chloride
(mg/L)
50.8
51.2
Nitrate
(mg/L)
5.28
5.08
Sulfate
(mg/L)
104
103
Iron
(mg/L)
0.0434
0.0342
Methane
(Hg/L)
0.482
0.565
Ethane
(Kig/L)
O.25
<0.25
Ethene
(Kig/L)
O.25
O.25

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                                            SECTION 5
                                DISCUSSION OF RESULTS
Site  characterization results  are  discussed  below,
followed by an evaluation of vapor intrusion for this
site.  Review of the analytical data sets indicates that
the systems were within control and that the internal
quality control checks performed by each laboratory
generally were acceptable.  The data are considered
to be valid  and  defensible,  with  the possible
exception of the on-site soil-gas data, as discussed
later in this section.

5.1     Site Characterization

Groundwater,  soil,  and  soil-gas  samples  were
collected  to  characterize  the  current  levels  of
contamination at the site.  These results are discussed
below.

The  depth  to  bedrock was obtained for  all  33
locations where probes were  pushed plus the eight
existing monitoring wells. The results are depicted in
Figure 4-1. The depth to bedrock drops from roughly
35 ft (llm) bgs along Grand Avenue to >70 ft (21m)
bgs behind the building.  No depths greater than 70 ft
(21m) could be obtained using  the available direct-
push  equipment  and  this limited the  ability  to
delineate the bedrock for most of Row "A."

5.1.1   Groundwater

The  on-site  analytical results for groundwater data
are plotted for PCE,  TCE, and DCE in Figures 5-1,
5-2,  and  5-3,  respectively.  The  on-site  analytical
method could  not distinguish between the cis- and
trans- forms of DCE. The plots show that the highest
concentrations  of the target VOCs lie directly beneath
the 60 ft by 70 ft (18 by 21m) southwest  end of the
strip  mall,  where  the  dry  cleaner facility  once
operated.  Some contamination has migrated towards
Grand Avenue (e.g., locations G5  and H2).  There
also  is some evidence  of contamination behind the
building (see data for location A4).
All VOC concentrations beneath the building are
<0.4  ppm,  while all concentrations  outside  the
building  are  <0.1  ppm.    All measured  VOC
concentrations  are  far   below  applicable   state
standards.   The  data indicate that the PCE  has
undergone substantial degradation to TCE and DCE,
but no vinyl chloride was detected.   In addition,
benzene and  toluene were not detected.  Duplicate
samples were analyzed on-site for seven locations.
The results generally  are within +25% and are almost
always within a factor of 2x.

The results for PCE and TCE for the last four rounds
of  groundwater   monitoring   (i.e.,  July  2003-
December 2005) are shown in Table 5-1.  The results
indicate that  the groundwater concentrations at the
site generally are stable.  Seven of the wells had very
similar  concentrations  from  sampling  event  to
sampling event. The highest variability in sequential
results occurred  at MW-4,  where  TCE and  PCE
concentrations varied by as much  as  an order of
magnitude.   MW-6 and  MW-7  also  exhibited
variability  to  some  extent.     PCE  and   TCE
concentrations showed a gradual  increase over three
sampling events at MW-1.

The productivity of the shallow groundwater zone at
Grand Plaza was evaluated at site monitoring wells
using two methods:   slug tests  and  a constant
discharge  test.  Data from slug  tests at two wells
(MW-7 and MW-9) were used to estimate hydraulic
conductivity  values,  which  were  subsequently
converted into well yield values expressed in gallons
per  day  (gpd).     The   constant  discharge   test
(conducted at MW-10) allowed a direct measurement
of minimum well  yield, which was compared to the
slug test results.

The tests  were performed in accordance with state
regulatory guidance (TCEQ, 2003),  and duplicating
select methodologies described by Butler, et. al.
                                                  37

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oo

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VO

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                             Table 5-1. PCE and TCE in Groundwater Over Time
Sampling
Location
MW-1
MW-2
MW-3
MW-4
MW-5
MW-6
MW-7
MW-8
MW-9
MW-10
Tetrachloroethylene (|J.g/L)
Dec 2005
~
408
~
~
~
~
~
~
0.513
21.9
Oct 2005
184
~
4.64
105
25.4
83.3
9.57
12.8
1.15
16.0
May 2004
160
710
4.4
430
28
15
6.0
6.30
~
-
July 2003
144
767
4.22
35.5
26.3
~
~
~
~
-
Trichloroethylene (|J.g/L)
Dec 2005
~
60.3
~
~
~
~
~
~
3.99
5.18
Oct 2005
22.2
~
2.16
11.5
3.61
25.0
1.77
1.80
4.42
4.49
May 2004
18
72
2.1
35
3.2
5.1
1.6
1.5
~
-
July 2003
14.8
76.9
2.37
3.96
3.32
~
~
~
~
-
-" = No sample collected

-------
(1996).   Slug tests were performed as many as six
times  at each well  in  order  to  evaluate  the
reproducibility of the data.  It was noted, particularly
at MW-7, that "skin effects" within  the well  sand
filter pack may have evolved during repeated testing,
diminishing well recharge over time.  The  first two
tests conducted at MW-7 yielded calculated hydraulic
conductivities of approximately  140 and 200 ft/day
(43 and 61 m/day), corresponding to calculated well
yields of approximately 11,000  and 15,000 gal/day
(42,000 and 57,000 L/day).  The fifth and  final test
yielded  a significantly lower  calculated hydraulic
conductivity of approximately 6.8 ft/day (2.1 m/day),
corresponding  to   a  calculated   well  yield   of
approximately  660  gpd  (2,500  L/day).    These
presumed  skin effects  apparently  were   not  as
significant at MW-9. The first two tests conducted at
MW-9 yielded calculated hydraulic conductivities of
approximately  2.6  and 3.3  ft/day (0.80  and  1.0
m/day)  corresponding  to  calculated well yields  of
approximately  16,000  and 20,000  gpd (61,000 and
76,000 L/day).  The  sixth and  final  test yielded a
slightly  lower  calculated  hydraulic conductivity  of
approximately 2.0  ft/day (0.6 m/day),  corresponding
to a calculated well yield of approximately 13,000
gpd (49,000 L/day).  Note that calculated well yields
are similar  for both wells even though calculated
hydraulic conductivity at MW-7 is two orders  of
magnitude  greater than at MW-9.  This occurs  in
calculation as a result of the saturated thickness of the
aquifer at each location.   The saturated thickness at
MW-7 is approximately 5 ft (1.5m), versus  44 ft
(13m) at MW-9.

A constant discharge test was conducted at MW-10,
allowing a  direct  measurement of minimum  well
yield.   During the test,  an  electronic  water level
indicator was used to measure the water level  in
MW-10 while a 12V submersible pump was operated
at  its   maximum  pumping   rate,   which   was
approximately  1  gallon  per  minute (3.8  L/min).
Upon activation of the pump, 0.3  ft  (9  cm)  of
drawdown    occurred    almost   instantaneously.
Thereafter, the  water level remained constant as the
pump discharged continuously for approximately 18
minutes, until the test was terminated.  Extrapolated,
the rate  of discharge corresponds to a minimum well
yield of approximately  1,400 gpd (5,300 L/day).

The results of both types of tests demonstrate that site
well yields  are significantly  greater  than  150 gpd
(570 L/day), which is the threshold for  Class 2 / Class
3  groundwater designation  according  to TCEQ
Guidance  Document  RG-366/TRRP-8  (TCEQ,
2003).  Therefore, the shallow groundwater zone at
Grand Plaza is designated Class 2.

5.1.2   Soil

The on-site analytical results for soils are plotted for
PCE in Figures 5-4, 5-5, and 5-6 for depths of 0-1 ft,
1-10  ft,  and  >10  ft  (0-0.3,  0.3-3,  and  >3m),
respectively.  Similar plots are shown in Figures 5-7
through 5-9 for TCE and in Figures 5-10 through
5-12 for DCE.   As previously  noted, the  on-site
analytical method could not distinguish between the
cis- and trans- forms of DCE. The plots indicate that
the areas of  higher contamination are  relatively
limited in size.  Three-dimensional representations of
the data are shown in Figures 5-13, 5-14, and 5-15
for PCE, TCE, and DCE, respectively.

All samples from outside the building were <0.4 ppm
for all VOCs.   Contamination was detected in  all
borings down to a depth of 20 ft  (6m) bgs.  Soil
samples   collected  from  beneath  the   building
contained up to 3.4 ppm of PCE, 2.3 ppm of TCE,
and  6.4  ppm  of  DCE.   All   measured VOC
concentrations   are  far  below  applicable  state
standards. As with the groundwater  samples, the data
suggest that degradation of the  PCE has occurred.
Vinyl  chloride, benzene, and  toluene were   not
detected in any of the soil samples.

The highest  concentrations of target VOCs generally
occur near the surface and the concentrations tend to
decrease  below  12  ft   (3.7m)  bgs.     However,
concentrations >0.1 ppm were detected down to 20 ft
(6m) at some  locations (e.g., N2, PI, P4, and Ql).
Contamination levels above  1  ppm for individual
compounds  are  present to depths of at least 12 ft
(3.7m) and contamination levels above 0.5 ppm are
present to depths of at least 28 ft (8.5m)(see data for
N2).

Duplicate samples were analyzed for two depths at
one  location.    Only PCE  was  detected  in these
samples and the results for the  duplicates agree to
within a factor of 2x.

Aliquots of  water extracts from three  soil samples
were   analyzed  by  an  off-site   laboratory   for
confirmatory purposes. For the four data pairs where
the compounds were detected in both the on-site and
off-site   analyses,  the  average  relative  percent
difference (RPD) was 44% (based on the absolute
values of the individual RPDs).
                                                   42

-------
Legend

II  Bysldmg

[1^1)  Paved Ar&a
 ND  N0E Delected
Soil Soring Location

DPT Sample Location

Monitoring Well Location
      URS
      GWC/AUS
                                                                              G^and Plaza Shopping Center
                                                                                  3103 Grand Avenue
                                                                                 	P.ailas...Texas	
                                      Figure 5-4
                              Soil Isoconcentratson Contours.
                                   (PCE pg/kg 0-1 ft)
                                Based on April 2005 Data
43

-------
Legend

I   1 Building

I   | Paved Area

 NO Nol Detected
 MS Nol Sampled
Soil Boring Location

DPT Sample Location

Monitoring Well Location
                                                 URS
WOO Amoergten BIWj
Auslm TX 78T29
PFione (512)454-4797
Fax 1512)419-5474
                                                  GWC/AUS
                                                                        Grand Plaza Shopping Center
                                                                           3103 Grand Avenue
       Figure 5-5
Soil Isoconcenlralion Contours
    (PCEug/kg1-10fl)
  Based on April 2005 Dala
                                            44

-------
;
-.-
      Leoertd

      F  1 Building
      [   | Paved Area
       NO  Not Delected
       NS  No) Sampled
Soil Boring Location

DPT Sample Location

Monitoring Well Location
                                                              URS
94QO Ambprg*n Blvd
Ausim TX 78729
Prione (51?) 454-4797
                                                               GWC/AUS
                                                             Grand Plaza Shopping Center
                                                                 3103 Grand Avenue
                                                                    Dallas. Texas
        Figure 5-6
Soil IsQconcentration Contours
     {PCE Mg/kg>10ft)
  Based on April 2005 Data
                                                        45

-------
    >
Legend

I   I  Building

I   I  Paved Area
 NO  Nol Delected
 NS  Nol Sampled
Soil Boring Location

DPT Sample Localion

Monitoring Well Location
                                                        URS
9400 Ambergfen Btvd
Aosln TX 78729
Phon* (S1J|*54U797
Fax {512)419-5474
                                                         GWC/AUS
                                                             Grand Plaza Shopping Center
                                                                 3103 Grand Avenue
                                                            	Dallas Texas	
        Figure 5-7
Soil Isoconcentration Contours
     (TCE ug*g 0-1 ft)
  Based on April 2005 Data
                                                  46

-------
Legend

I   I  Building       A  Soil Bonng Location

I   I  Paved Area    Jg  DPT Sample Localion
 NO  No! Delected
 NS  Noi Sampled
•V  Monitormg Well Location
                                                        URS
                                        9400 Am&ergten SW
                                        Auslm TX 78729
                                        Phone )51?|4&4J79
                                        F»X (512)419-5474
                                                         GWC/AUS
                                                                 Grand Plaza Shopping Center
                                                                     3103 Grand Avenue
                                                                             Texas
        Figure 5-8
Soil Isoconcentralion Contours
     (TCEpg/kg 1-10ft)
  Based on April 2005 Data
                                                  47

-------
Legend

I   I  Budding       A  Son Bonng Location
I   I  Paved Area    Jg  DPT Sample Location
 NO  Not Delected   ^  .
                 V  Monitoring Well Location
 NS  Not Sampled
      URS
       9400 Am&ergten SW
       Auslm TX 78729
       Phone )51?|4&4J79
       F« (512)419-5474
       GWC/AUS
Grand Plaza Shopping Center
    3103 Grand Avenue
       Dallas. Texas
        Figure 5-9
Soil laDconcentralion Contours
     (TCE M9/kg>10ft)
  Based on April 2005 Data
48

-------
Legend

I   I  Building
I   I  Paved Ares
 NO  Not Dsleeled
 US  Nol Sampled
Soil Bonng Location

DPT Sample Localion

Monitoring Well Location
                                                        URS
          Bfvd
AuBlm. TX 78729
Phone (512)454-4797
Fax (512|416-S474
                                                         GWC/AUS
                                                                nd Plaza Shopping Ce
                                                                 3101 Grand Avn-r
                                                                    Dallas. Texas
        Figure 5-10
Soil IsoconcentraKon Contours
     (DCE pg/kg 0-1 ft)
  Based on April 2005 Data
                                                  49

-------
Legend

I   I  Building
I   I  Paved Ares
 NO  Not Dsleeled
 US  Nol Sampled
Soil Bonng Location

DPT Sample Localion

Monitoring Well Location
                                                        URS
3400 Ambergien E. -1
AuBlm. TX 78729
Phone (512)454-4797
Fax (512)419-5474
                                                         GWC/AUS
                                                                nd Plaza Shopping Ce
                                                                  3101 Grand Avn-r
                                                                    Dallas. Texas
        Figure 5-11
Soil tsoconcenlralion Contours
    (DCEug/kg1-10ft)
  Based on April 2005 Data
                                                   50

-------
Legend

I   I  Building
I   I  Paved Ares
 NO  Not Dsleeled
 US  Nol Sampled
Soil Bonng Location

DPT Sample Localion

Monitoring Well Location
                                                        URS
          Bfvd
AuBlm. TX 78729
Phone (512)454-4797
Fax (512|416-S474
                                                         GWC/AUS
                                                                nd Plaza Shopping
                                                                 3101 Grand Avn-r
                                                                    Dallas. Texas
        Figure 5-12
Soil tsoconcentration Contours
     (DCEug/kg>10ft)
  Based on April 2005 Data
                                                  51

-------
to

                          100 po^O PCE Isooonoenlratioo
             ims
Grand Avenue Plaza
31 CO Grand Avenue
   : i •:• ' •• -
  Figure 5-13
 3d PCE Plume
Based on April 2005
   Soil Data

-------

\
Ltatnd
100 ugtojTCE l»c«n««ntia(iflo
'0 ug&o ICE teoc«K«*ation
URS
LflB CfvinBttn
HO) Ajre«^«ri fl?.d
Aunn T.mt JS7JO
Grand Avenue Plaza
31 DO Grand Avenue
: . •:- ' •• -
WTr: S»? ?7, JD06 |nff*h: | J J_[j[ jirra.ii*^
^FlgureTlT
3-D TCE Plume
Based on April 2005
Soil Data
1

-------

\
Ltatnd



1000 ugrttg DCE tnxttK*rtrtt>»



100 M9*9DCE (soMoeentralion
URS
LflB CfvinBttn
HO) Ajre«^«ri Ri.d
Aunn T.mt JS7JO
Grand Avenue Plaza
31 DO Grand Avenue
: . •:- ' •• -
WTr: S»? ?7, JD06 |nff*h: | J J_[j[ jirra.ii*^
^FlgureTl^^
3-D DCE Plume
Based on April 2005
Soil Data
1

-------
5.1.3   On-Site Soil-Gas

Soil-gas samples  were obtained  at a depth of 5 ft
(1.5m) bgs from  10 locations and analyzed on-site.
In addition to the shallow soil-gas samples, soil-gas
samples were collected at the four sub-slab soil-gas
sampling locations.  Only PCE was detected in the
soil-gas samples  at  5 ft (1.5m) depth;  all  other
compounds were  non-detect (ND).   No PCE was
detected in the soil-gas samples collected outside the
building or in two of the  six soil-gas samples at 5 ft
(1.5m)  bgs  under   the building.  The  highest
concentration was 1,110 |J.g/m3 (7.5 ppmv) at location
R2.

The on-site analysis of the sub-slab soil-gas samples
showed relatively high concentrations of PCE at all
four locations  where  samples  were obtained.   All
other  compounds   were   ND.  The   measured
concentrations for PCE were:

    •   SSI = 25,300 |ag/m3 (172 ppmv);
    •   SS1B = 28,200 |ag/m3 (191 ppmv);
    •   SS3 = 920 |ag/m3 (6.2 ppmv); and
    •   SS4 = 239 |ag/m3 (1.6 ppmv).

The sub-slab sampling locations are shown in Figure
3-4.  On the sampling array, Location SSI was near
N3, in the area where the dry cleaning machines once
were located. Location SS1B was two ft from SSI
and was  used after SSI  became resistant to flow.
Location   SS2  was between N4 and  N5 on the
sampling array shown in  Figure  3-1.  Location SS3
was between P2 and Q2, and Location SS4 was near
S2.

Samples SSI and SS1B  were  collected  sufficiently
close  together to  be considered  duplicate samples.
The  RPD  for  this  sample pair is  11%.    Four
sequential samples were collected at location SS3 (a
regular sample and three replicates).  The replicate
samples showed somewhat lower  concentrations than
the regular sample: -8%, -35%, and -23%.

Given the  high concentrations that were detected, the
on-site analysis  could have relied upon a  direct
injection  approach rather than the  use  of sorbent
tubes.  The on-site soil-gas data exhibit a consistent
low bias compared with the off-site analytical results.
One possibility is  that the sorbent material may have
become saturated with VOCs.  Overall,  the on-site
soil-gas data are believed  to be  less accurate than the
on-site groundwater and soil data.
5.2     Evaluation of Vapor Intrusion
The off-site analytical results for soil-gas, indoor air
samples, and tracer gas tests are discussed below,
followed by a discussion of the  potential for vapor
intrusion at this site.

5.2.1   Off-Site Analysis of Soil Gas

Shallow soil-gas  samples were collected at at a depth
of 5 ft (1.5m) bgs from six locations and three sub-
slab soil-gas samples were collected.  The PCE in the
shallow soil gas ranged from 0.039  to 0.71 ppmv.
The TCE concentrations were similar to  the  PCE
concentrations, whereas the DCE  tended to be higher
(up to  29 ppmv).  The presence  of TCE, DCE, and
VC is additional  evidence that the PCE has degraded
in the past.

In addition to the compounds  shown in Table 4-9,
one or more of the samples contained hexane, trans-
1,2-DCE, m/p-xylene,  or  2,2,4-trimethylpentane.
The amount of trans-l,2-DCE was generally <10% of
the amount of cis-l,2-DCE.  The concentration of
2,2,4-trimethylpentane (iso-octane) ranged from 0.14
to  1.7  ppmv in the  shallow   soil-gas  samples.
Gasoline releases are the most likely source of this
compound.    Some  samples  also  showed  traces of
compounds thought to be laboratory  artifacts  (i.e.,
ethanol, acetone,  or methyl-ethyl ketone [MEK]).

The  sub-slab  soil-gas  data  exhibited  considerable
spatial variability. For example, two of the three sub-
slab   soil-gas samples had  PCE   concentrations
between 3 and 9  ppmv, whereas the third sample had
2,600  ppmv  of  PCE  (0.26%)(18,000,000  |ag/m3).
This sample  was collected  from the middle of the
restaurant and also had significant concentrations of
TCE and cis-l,2-DCE.  The off-site data for PCE are
consistently higher than the on-site analytical results
for the same  location.  The off-site data should be
considered more  representative of site conditions.

The sub-slab samples were each collected adjacent to
a shallow soil-gas sample.  The  comparison of the
shallow and sub-slab soil-gas data is shown in Table
4-10.  The comparison generally shows that the  PCE
concentrations are highest immediately beneath the
slab.   The  maximum measured  values for shallow
soil-gas  and  sub-slab soil-gas  did  not  coincide
spatially.

No physical barriers to vapor transport were found in
the examination  of the building  slab based on the
sound  checks.   Pressure differential measurements
                                                  55

-------
made under induced vacuum indicated that the fill
directly underneath the slab  is amenable to vapor
flow.  While drilling holes in the slab it was found
that  the slab is  only  about 4 in. (10 cm) thick in
places.  Tile floor covering  precluded  a thorough
examination of the slab for cracks.
Soil  gas  data  at the site indicate that chemical
concentrations vary spatially, decreasing significantly
with distance from a  small "hot spot".   The data
suggest that the  contamination has largely remained
in place under the slab near its release point with only
limited vertical and lateral transport.  The lack of gas-
phase  lateral  migration  within  the  fill  material
directly beneath  the  slab  is  somewhat  surprising,
given the decades of time that the contamination has
been in place and the expected rates of diffusion in
the air-filled pore spaces beneath the slab.
conditions between the two  sampling events.   As
previously  discussed,  during  the  first round  of
sampling, the space was unoccupied and the HVAC
system was not in use during the sampling event nor
during the preceding days.  During the second round
of sampling, the HVAC system was in regular use.
As shown in Table 4-12, a grab sample was collected
about 24 hours prior to the second round of sampling
at a time when the building HVAC system had been
operating at a high rate overnight.  This sample had
only about 25% of the  PCE, TCE, and cis-DCE of the
samples  detected  in  the  time-integrated  samples
collected the following day. This suggests that there
can be significant  short-term temporal variability in
indoor VOC concentrations at this site.

5.2.3   Tracer Gas Tests
5.2.2   Off-Site Analysis of Indoor and
        Ambient Air Samples

Two indoor air samples and one outdoor ambient air
sample  were  collected during the first  round of
sampling.   PCE was detected  in the  indoor  air
samples at concentrations of 10 to 13 ppbv. TCE was
detected at 0.52 to 0.65 ppbv  and cis-l,2-DCE was
detected at 1.1 to 1.6 ppbv. The ambient air sample
had low levels of PCE (0.11 ppbv), but the ambient
air does not appear to be a significant source of the
compounds detected in the indoor air samples.

The  measured indoor air  concentrations may have
been biased high due to two factors.  One, the drilling
through the floor in the days preceding air sampling
likely created a pathway  for  subsurface vapors to
enter the building.  The exposed  soil cores in the
room also may have been an emissions source.  Two,
the HVAC system was not operating for at least 12
hours prior to the start of the indoor air sampling, so
dilution of any emissions would have been minimal.

Based   on  the   results   of   the   initial   site
characterization, additional samples were collected to
evaluate the potential for vapor intrusion.  As shown
in Tables 4-11 and 4-12,  indoor air  samples were
collected at two locations  during the  first round of
sampling and at one location during the second round
of sampling.    The results for the two  rounds of
sampling  showed  similar  levels  of VOCs in the
indoor air.

Overall, PCE was detected in the indoor air at about
12 ppbv (83  |J.g/m3).   The agreement among the
indoor air samples is good, despite the difference in
Neither helium nor SF6 was detected in the indoor air
prior to the tracer gas releases.  The time-integrated
sample collected 24 hours later had <0.020% helium.
Using equation 3-1 and the helium release rate of
0.18 m3 hr"1, the ventilation rate within the restaurant
portion of the building (QBidg) is estimated to be >900
m3 hr"1.  The restaurant area has a footprint of 184 m2
and a volume of 481 m3.  Therefore, the building air
exchange rate is estimated to be >1.9 air changes per
hour (ACH).

Four grab samples also were collected after the tracer
gas release was initiated and helium was detected in
three of the four samples, with values ranging from
<0.014% to 0.057%.  The variability may be due to
incomplete mixing  in the  indoor air space as
evidenced by the variability between the helium and
SF6 concentrations.  The variability also is thought to
reflect  changes in  the  actual ventilation rate as the
HVAC system and fry-station exhaust hood turned on
and off.  The experimental design did  not address
measurements  of  the building  ventilation  as  a
function    of   exhaust    hood   use.   Real-time
measurements of  helium concentration should be
included in any future, similar studies.  The average
helium concentration was  0.031%  if the detection
limit is  substituted for the  non-detect values.  This
yields a ventilation rate of 573 m3 hr"1 and 1.2 ACH.

The time-integrated measurement of SF6 was 0.57
ppbv and two grab samples  collected during  the same
time frame had similar results.   The detection of SF6
within the building confirms that vapor intrusion is
occurring. Two additional measurements of  SF6 were
made after use began of the fry-station exhaust hood.
The hood increased the pressure differential between
                                                   56

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the building and soil and thereby is believed to have
increased the rate of QSOii.  The threefold increase in
concentration reflects an increase in QsoU of >3, if the
exhaust hood increased the building ventilation rate.

Pressure differential measurements  were made  to
confirm the effect of the fry-station exhaust hood.
Two holes were drilled through the slab 15 to 30 ft (5
to 10m) from  the  exhaust hood  and the building
pressure differential  was measured with the  exhaust
hood off and again with the exhaust hood on.  The
measurement locations  are shown in Figure 3-4. The
use  of the exhaust hood changed  the building
pressure differential from +0.002 to -0.003 in. H2O at
one  location and from +0.001 to -0.006 in. H2O at
the second location.  The positive  sign indicates that
air flow is from the interior space into the  subsoil,
whereas a negative sign indicates that air flow is from
the subsurface.  So, the effect of the exhaust fan was
to switch the soil-gas flow from positive to negative.
The  magnitude of this effect was about 1.5 Pa. For
comparison,  the US  EPA  guidance assumes  a
continuous building pressure differential (AP) of 4 Pa
(EPA, November 2002).

The measurements of pressure differential at the three
sub-slab sampling locations during April 2005 were
all non-detect (<0.005 in. H2O). As previously noted,
the HVAC system and  exhaust  hood were not in
regular use at the time.

5.2.4   Evaluation  of Vapor Intrusion

Vapor  intrusion (VI) is the migration of gas-phase
chemicals from the subsurface  into buildings  or other
structures.  It is only in the last few years that vapor
intrusion of VOCs  has become a general issue for
sites with subsurface contamination due to petroleum
fuels or chlorinated  solvents.  Federal guidance has
been published (US EPA, November 2002), as well
as guidance by various State Agencies (Eklund, et al.,
2006).

Vapor intrusion studies typically address the potential
risk   from  chronic   exposure   to  very  low
concentrations of potential  carcinogens.  It is  the
incremental increase in indoor air  concentration that
is the  issue, not the absolute concentration itself.
Given  the  typical background levels  of VOCs  in
houses and office  buildings, it often is difficult or
impossible  to measure vapor intrusion directly using
indoor  air  measurements.   Therefore,  alternative
evaluation  approaches  are often employed.    A
standard modeling approach is available (Johnson and
Ettinger,  1991)(US  EPA,  2003b),  but  there  are
concerns that the model may be too conservative for
some scenarios  or that the  model can be misused.
Most current guidance emphasizes evaluating vapor
intrusion using soil-gas measurements made near the
buildings of interest.

The  ratio  of indoor air to soil-gas concentrations is
often evaluated in vapor intrusion studies.  This ratio
typically  is  called  the attenuation factor  or  a.
Published values of a tend  to be <0.001.  In other
words, the soil gas is diluted by a factor  of  > 1,000
inside a building.  The EPA  default a  value for
screening purposes currently is 0.1, but is expected to
decrease to 0.02 when the  2002 EPA  guidance is
revised sometime in 2007.

It is  typical practice to use the maximum subsurface
value rather than the mean or median value when
calculating a  for a given site.  The three sub-slab
soil-gas samples had  18,000,000; 26,000; and 59,000
|ag/m3 of PCE. The three indoor air samples had 85,
68,  and  96   |J.g/m3,  for a mean  of 83  |J.g/m3.
Therefore,  a  = 5.3xlO"6  using the maximum values
and  a =  1.4xlO"5 using the average values.  The
values of a for other compounds detected in the sub-
slab  soil-gas  are also in the  10"6 range  using the
maximum  values.      These   results    are   not
unreasonable.  In another study, one of the authors
has  measured  attenuation coefficients  of roughly
IxlO"5 in multiple buildings with decades-old  surface
spills   and   localized  high   concentrations   of
chlorinated solvents in the sub-slab soil gas (Rehage,
et al., 2006).

The   sub-slab  monitoring  locations were  biased
towards areas of suspected  contamination.  So, the
average value  calculated from the  three sub-slab
measurements is thought to be biased high from the
"true" value.    Given  the very  high  degree  of
subsurface spatial variability in the concentration of
PCE and other VOCs, the average value is essentially
equal the maximum value divided by the number of
measurements («).  Increasing n would likely  lead to
a linear decrease in a calculated from average values,
unless a 2nd "hot spot" were found.

The  concentration of VOCs in the subsurface should
be   relatively   stable,   whereas  the  indoor  air
concentration was found  to vary by about a factor of
4x over a one-day period.  Given that a is a simple
ratio  of the two, it  also would vary by  this same
factor of 4x.  This short-term temporal variability is
thought  to be  due  to  changes  in the  pressure
                                                    57

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differential between the building and the subsurface.
When the exhaust fan in the restaurant is off, there is
little or no pressure-driven airflow of vapors into the
building.   When the exhaust fan is on, there is  a
driving force for vapor intrusion.

The US EPA and others are compiling data, but there
are relatively few published values for a in the open
literature.     Fischer,  et  al.   (1996)  measured
hydrocarbons found in gasoline in ambient air, indoor
air,  and  soil  gas  at  two depths.   They  report
attenuation  coefficients from 4.0xlO~4  to  1.9xlO~3.
They also used  an SF6 tracer gas  and reported an
attenuation  coefficient  of 2.5xlO~4 with no forced
pressurization.  Olson and Corsi (2001) used an SF6
tracer  at  two  houses in  New Jersey  and reported
attenuation  coefficients ranging  from 5.52xlO"5  to
1.7xlO"4.  Johnson, et al. (1999) suggested an upper
limit  of about IxlO"3 for a.   Elsewhere, Johnson
(2002) suggested a reasonable range for a of  IxlO"4
to IxlO"2 for screening  purposes.  Our  data show  a
lower  a than of these published values.   This is
significant given that the gas-phase  contamination
was present immediately  beneath the building slab
and the building  slab is relatively thin and old.

The absolute concentrations of PCE measured in this
study  are  high  relative  to  typical   indoor  air
concentrations in  houses  and  offices,  which  are
reported to be  0.14 and 0.47  ppbv,  respectively
(Hodgson and Levin, 2003).  The  measured values
are not high, however, compared with measurements
made in apartments or condominiums located in the
same building as dry cleaners.   PCE  values  up  to
197,000  |J.g/m3  have been reported,  with median
values well above 1,000 |ag/m3 in several studies (US
EPA, 1998).

The air exchange  rate  for buildings varies widely.
The US EPA (1997) evaluated  data  from several
thousand houses and found a geometric mean of 0.46
ACH with  a  90th percentile  value of 1.26  ACH.
Office buildings typically are designed to have 15
cfin per person of ventilation, which results in a value
of about 1 ACH.  The US EPA (Persily and Gorfain,
2004)  measured ventilation at 369 office buildings
and found a median of 0.98 ACH.  Slightly higher
ventilation rates per person are recommended for
restaurants, which yields design values of roughly  5
ACH  given  the  higher  density  of  persons  in
restaurants compared with offices.  Measurement
data for restaurants are relatively limited. One study
of nine Florida restaurants reported an average of 3.8
ACH (Cummings, et al., 1997). The measured values
of 1 to 2 ACH at the Grand Plaza site appear to be
relatively low for a restaurant, but are much higher
than the default value of 0.25 ACH  in the US  EPA
November 2002 guidance, which is based on the 10th
percentile for single residence buildings.

Assuming a steady-state mass balance, the emission
rate of PCE into the building was 0.086 g/hr based on
a ventilation rate of 1.9 ACH and the concurrent
indoor air measurement.  QsoU = 0.082 L/min based
on the "hot spot" PCE concentration of 0.26%.   The
total  volume  of soil gas  entering the building is
almost  certainly  higher than  this  value,  which
represents only the rate of contaminated soil gas
entering the building.  EPA's default value for soil-
gas infiltration is 5 L/min for a residential structure
with a 100m2 footprint.  Normalizing the Grand Plaza
value to  this  footprint  yields QsoU = 0.044  L/min,
which is 0.9% of the EPA default value.

The  inhalation unit risk (IUR)  for PCE  is usually
given as 3.0E-06 per ug/m3.  For a  IxlO"5 risk, the
resulting  concentration  is  0.00001/3.OxlO"6 =  3.33
M-g/m3.   This  number  reflects  a  continuous 70-yr
exposure and  is  then  adjusted  for the  assumed
exposure scenario.     If  the  usual  occupational
exposure scenario of  8 hr/day,  5  day/week,  50
week/yr for 25 years is assumed, the IxlO"5 risk  level
is 41 |ag/m3.   Therefore, average measured value of
PCE  at this site yields  an estimated risk  of 2xlO"5.
Risks   above   IxlO"4   generally   are   considered
unacceptable and risks below IxlO"6 are considered
to be insignificant. The assumed exposure scenario is
conservative  for  this  site  given the  turnover of
businesses at this location.

The installation of a sub-slab depressurization system
for this  site  was considered  and  a  design   was
prepared.    There  is,   however,  no   regulatory
requirement for such a system.  Representatives  from
the City of Dallas, with input from TCEQ, elected not
to install a system at this time.  It is recognized that
controls  would  be   required  in   some  other
jurisdictions based on the measured concentrations of
VOCs,  such as PCE, in the indoor air and/or in the
sub-slab soil gas.

The results for this site have several implications for
the standard regulatory approach for evaluating vapor
intrusion.  One, field  investigations at  sites  with
surface  releases  should  include  measurements in
surface soil layers. Groundwater, soil,  and soil-gas
measurements  at  depth  may  not  identify  the
maximum concentrations present  at the site.   This
                                                    58

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study  illustrates   the  extreme   spatial  variability
sometimes found in the subsurface at contaminated
sites.   Two,  the  use  of  mean  values  instead  of
maximum values may still be very conservative when
soil-gas measurements are used to estimate indoor air
concentrations using an a of 0.1 or 0.02.  Three, the
US EPA defaults for parameters such as  Qsoii, QBidg,
and AP may be very conservative for a given site.
Site-specific measurements  can readily be performed
to  provide  more   accurate  estimates  for  these
parameters instead of relying on default values.
                                                   59

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                                            SECTION 6
                    SPECIFICATIONS FOR CONTROL SYSTEM
                                 FOR GRAND PLAZA SITE
6.1     Location

These specifications are for the installation of an
active soil depressurization systems at the Grand
Plaza site. As discussed elsewhere in this report, it
was ultimately decided not to install the system at
this time.

6.2     Site Specific Conditions

These specifications are based upon a limited
investigation of the site and therefore certain
installation details will need to be verified by the
installer at the time of bid or installation, as follows:

•   The discharge of the system is to be at least 10
    feet (3m) from any air intakes or openings into to
    the building, including those which are mounted
    on the roof (roof access was not available during
    inspection).  If the locations  indicated  for the
    systems does not allow for this  separation, the
    discharge points may be rerouted  to allow for
    such a separation.
•   The suction  point locations may be within plus
    or minus 2  feet (0.6 m)  from the locations
    indicated  on  the   drawings  to  allow  for
    interference avoidance.
•   Underground and underslab utility lines were not
    definitively    located   during   investigation.
    Contractor to request such locates by the local
    utility company, with specific attention to the
    potential location of a gas line near the location
    of the chicken fryer.
•   Contractor to prime and paint all exterior and
    exposed components of the system using a
    primer and paint color acceptable to the client.
•   Installation to be done in a manner that does not
    interfere with the operation of the business
    within the unit that these systems are to be
    installed upon.
•   Two active soil depressurizations are called out.
    Each system is to be independent of the other. At
    the option of the client, these systems may be
    installed concurrently or sequentially as dictated
    within the request for bid documentation.
•   System to be installed in accordance with US
    EPA Radon mitigation Standards EPA 402-R-
    93-078, October 1993 (Revised April 1994)
    available at
    http://www.epa.gov/radon/pubs/mitstds.html.
•   These specifications are provided as guidance for
    installation. Where  there is a conflict  between
    these specifications and local building codes, the
    local building codes shall prevail. Furthermore,
    the competency of the contractor is one of the
    basis for  selection and therefore it is expected
    that if the contractor will identify interferences or
    more optimal approaches and make appropriate
    suggestions to the client  in a manner that does
    not conflict with the intent of the system.
•   It is assumed that any building permits shall be
    obtained by the contractor as needed for this
    work in accordance with local regulations.
•   It is also assumed that any air pollution permits
    that may be needed for this system(s) shall be the
    responsibility of the  client, rather than the
    contractor.
•   Fan location and enclosures: It is suggested that
    the fans and their enclosures be located as close
    to  the roofline as possible to avoid impact of
    exterior  parking  space.  Consequently, it is
    suggested that the fan enclosures be inverted to
    allow for vent piping to be as close to the wall as
    possible.
•   Where asphalt must be removed for installation
    of suction points, the asphalt shall be repaired.

6.3.    Active Soil Depressurization
        System

The  systems  to be installed  shall  be designed to
extract soil gases from  beneath the foundation and
exhaust them to a location above the roofline of the.
                                                   60

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structure and at a location where soil gases will not
re-enter the building

6.3.1   Depressurization Fan

Fans to be capable of delivering a minimum of 190
cubic feet per minute (5.4 nrVmin) at 1.0 inches (2.5
cm) of water column differential pressure. Fans to be
rated for exterior use in a hot, humid climate, as will
as conveyance of moist, non-combustible air.
    Fan  systems to be: PDS  MI  220  system as
    manufactured by professional Discount  Supply
    (www.pdsradon.com) matched with Fantech HP-
    220 fan, or approved equivalent.
    Fans casings to have 6-inch (15 cm)  intake and
    discharges
    Power: 120 volt, 60 Hz, 150 watt
    Fan to be matched with performance indicator to
    provide indication of current draw as a means to
    indicate continued fan operation.
    Number required: two (2)
Fan Power Supply
Electrical power is to be routed to the indicator panel
and fan in accordance with the local electrical codes
and  in conformance with  the  existing  electrical
service within the  subject building.

Power for the system indicator is to be supplied from
the same circuit that supplies power for the fan.

Existing circuits may be utilized, if the addition of
the system  in  addition to current use would  not
exceed 80% of the circuit capacity.

Fan Orientation and Connection
•   Fan shall be positioned in the vent pipe system in
    a vertical manner.
•   Fan is to be secured to the vent pipe system on
    both inlet and outlet  connections with flexible
    connectors secured by stainless steel hose clamps
    to facilitate removal.
•   Fans shall not be glued or otherwise permanently
    attached to the pipe system.

Fan Enclosure
The fan is to be housed in an enclosure designed to
protect it from wind and physical abuse. Enclosure is
to consist of a wall  mounted base plate and cover.
Material of construction is to be water-resistant ABS
plastic.  Fan enclosure to be FH-89 fan housing as
manufactured by RCI, 511 Industrial Drive,  Carmel
Indiana (317)  846-7486  or approved  equivalent.
Enclosure is to be primed and painted with two coats
of cover in a color to match the exterior color scheme
as is reasonably achievable.

System Performance Indicator
•   Each  system will have a performance indicator
    mounted as indicated in the Figures.
•   Indicator to be as specified in Section 6.3.1.
•   Electrical power for the system indicator is to be
    supplied from  the same  circuit that  supplies
    power for  the fan.  Power  to be  routed in
    compliance with local electrical codes.
•   Affixed to  the power indicator shall  be a label
    detailing the system ID number (i.e., SP-1, SP-2,
    etc.).  The  number  of  the   circuit  breaker
    providing  power  to  the  ASD  system  and the
    panel ID   # is to  be written on  inside  of
    performance indicator box.
•   Indicator to be adjusted to "Green" zone after fan
    has been  activated and  system installation is
    complete.  Power  draw is also  to be measured
    (current x  voltage)  and  provided to client at
    conclusion of work.

6.3.2   Pipe and Fittings

Vent pipe  to be as follows:
Construction
Size
Schedule:
Primed and painted?
Fittings
PVC or ABS ASTMD-1785
4-inch nominal
80
Yes
Solvent welded (except mechanical
connection to fan
Routing
In addition to normal practices for running plumbing
lines as though it were soil vents, the pipe shall not
be configured such that there would be any
accumulation of moisture within pipe. Pipe to have a
positive slope back to the suction point of no less
than 1/8 - inch per foot (0.3 cm per 30 cm).

Pipe Supports
Pipe supports shall be  used to secure the piping
system. At a minimum pipe supports shall be applied
every 2 meters in vertical runs and every 1.5-meter in
horizontal runs.  Pipe  supports are  to be applied as
noted  on  the drawings with  a  minimum of pipe
supports near the suction point and at the discharge,
with the fan being  independently supported within
the enclosure.
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All pipe supports  are to be made of non-corrosive
material  such as stainless steel or galvanized steel.
Pipe supports to be a channel and clamp system such
as Unistrut or approved equivalent.

Vent Discharge

Location
The discharge of the system shall be oriented either
vertically or at a 45-degree angle away from the
building and in a location where the discharged
gasses may not enter any building or adjacent
building openings.  In addition to this, the discharge
shall be:

•   At least 10 feet (3 m) above exterior grade
•   At least 10 feet (3 m) away from  a passive
    opening into the building that is less than 2 feet
    or 60 cm below the exhaust point as measured on
    a horizontal plane, and 25  feet (7.6 m) away
    from active air intakes for building mechanical
    systems.
•   At least 10 feet (3 m) from any opening into an
    adjacent building or public access or easement.

Note that the distance requirements from the point of
discharge to the  building opening  or mechanical
system  intake  is  to be  measured  either  directly
between  the  two  points  or  to  be  the sum of
measurements made  around  intervening  obstacles
such as building corners.

Discharge Screen
A screen constructed of stainless steel or galvanized
metal shall be installed in the discharge after the
system has been activated for at least five minutes to
clear any residual debris. See Figures.

A UV and weather resistant label shall be affixed to
the discharge pipe  reading:  CA UTION Soil Gas Vent
- Do not tamper or disturb.

6.3.3   Suction  Point
The suction point is to be installed as depicted in the
Figures, with the following additional comments:

•   Prior to coring holes through concrete surfaces, a
    rebar locator for ferrous materials is to be used to
    locate a pathway where rebar will  not be cut or
    there will be a minimal impact. Where re-bar is
    nicked or cut, the exposed portion of the re-bar is
    to be protected by a material designed to prevent
    corrosion of  rebar, such as  3M  Scotchkote
    413/215/PC or approved equivalent.
•   A minimum of 1.5 cubic feet (42 L) of soil is to
    be dug out from suction point, beneath the slab.
    Excavation should be upwards to the bottom of
    the slab  to preclude of soil from falling into
    suction point.
•   Suction point piping to be well sealed to inside
    of concrete core as indicated in the figure to
    assure an airtight seal.
•   A rigid pipe support is to be installed as close to
    the suction point as possible to maintain the
    integrity of the seal.

6.3.4   Sealing

Backer Rod and Sealing of Suction Point
Where suction piping  penetrates  a  wall, a positive
seal is to be made that is also flexible. A minimum of
2 wraps of closed cell backer rod, is to be used and of
sufficient  diameter to  provide  a  compression  fit
between the inside of the core and the outside  of the
pipe.  External portion of  connection to  have  an
elastomeric polyurethane  caulk, such as Sonolastic
NP-I, Geocel21OO or approved equivalent and is to
be applied to a minimum depth of 1-inch.

Caulking Concrete
Efforts shall be made to identify leak  points where
either interior or exterior air is being drawn down to
the sub-grade  due to the negative pressures created
by the ASD system. This can be identified by non-
thermal smoke. Said openings are to be caulked using
an elastomeric polyurethane  such as Sonolastic NP-1,
Geocel 2100 or approved equivalent.

6.3.5   Asbestos Containing Materials

Contractor is to take  appropriate precautions  when
drilling  through  building materials  that  may  be
suspected  of containing  asbestos. If any  suspected
asbestos containing materials are encountered, the
material is not be disturbed and  the client is  to  be
notified, prior  to continuing  work that would disturb
suspected  asbestos containing material.

6.3.6   Excavation and Repair

Where excavation and or demolition is required the
area is to be secured and appropriate safety measures
are to be taken both during and after hours to protect
the public.

Where  excavation  or   demolition   of   concrete
sidewalks, planters, tile, etc. is required, said area is
                                                   62

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to be restored as close as reasonably possible to its
original condition.

6.3.7   Painting

All pipe, fan  shroud  covers,  conduit, etc. shall be
painted to match exterior  color  scheme.  Plastic
components are to be primed with an appropriate
primer for the  base  material to  be painted.  A
sufficient  number of  surface coatings  are  to be
applied to  fully  cover the  component. All  system
components will be painted in accordance with client
specifications.

6.3.8   Labeling Requirements

Labels listed below are to be of suitable material for
environment  they will be  located.  Labels located
outdoors  are  to  be  resistant  to UV and weather
damage.

ASD System
At least one label shall be affixed to the  mitigation
system in all  locations where vent  pipe  is visible.
Label is to read:  CAUTION Soil Gas Vent - Do not
tamper or disturb.
Circuit breaker
The  circuit within the building  power panel from
which the ASD fan power supply is obtained is to be
labeled "Soil Vent System".
Performance Indicator
The number of the circuit breaker providing power to
the ASD system is to be labeled on inside of each
performance indicator box.

6.4     Figures and Details

The  following  non-scaled  figures  and  details  are
provided as guidances for installation:

Figure 6-1:   Installation Schematic
Figure 6-2:   Location of Suction Points
Figure 6-3:   Pictorial Indication of System Locations
            & Details
Figure 6-4:   Detail 1 Suction Pit
Figure 6-5:   Detail 2 Vent Discharge
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Stand-off bracket for discharge

     Roof
Unistrut channel, or
equivalent, pipe support
anchored to wall.
     Terminate discharge a minimum of 12
     inches above roof line.
     Locate at least 10 feet from any
     mechanical  air intake on roof
     Install screen on discharge See Detail 2
                                            Mount fan within Rt I enclosure.
                                            Enclosure comes with transition box.

                                            Mount fan in enclosure near roof line.
                                            Invert cover to allow suction piping to be
                                                 to wall.

                                            Slot cover at  top to allow it to slip around
                                            discharge pipe.
Piping and fittings to be 4-inch schedule 80,
PVC both below and above the fan.
ASTM D-l785.  Joints to be solvent welded.
All exposed components, including piping to
be primed and pointed to match existing
building exterior color scheme.
                                                  Buck 111 I  and compact excavation
                                                   Repair asphalt uhere disturbed
                                                        Suction Point
                                                        See Detail I
 Excavate pit up to bottom of floor slab
 Remove minimum of 3 cu. ft. of soil from behind
 foundation wall.
                    Figure 6-1.  Installation Schematic
                                        64

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                           Side
                  SP-1
SP-2
         -22 feet
o
                                             -22 feet
                                                          .it:
                                                           o

                                                          CD
                    Other Units
                                          Feet
                                      D    8    12
            Figure 6-2. Location of Suction Points
                             65

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                                              SP-1

     Locate fan systems up hiyh i-n building.
     Piping to be schedule 80 PVC for durability.
     Horizontal cores through foundation wall.
     Asphalt to be cut to allow access for core rigs and replaced.
     Pipe and shroud lo tv primed and painted.
     Suction point locations can be moved 2 feet either direction from point noted to
     avoid obstructions.
     Discharge points to Ix 10 feet from rooftop air intakes.	

                                           •  (.'ore hori/onkillv through
                                              foundation wall,
                                           •  Avoid re-bar-patch if nicked or
                                              damaged
                                           •  Patch asphalt, if disturbed.
                                           •  Location can be -+• 2 feet from
                                              specified location
                                               Locale performance indicators on
                                               wall adjacent to circuit panel.
                                               Utilize existing circuit if not
                                               overloaded, otherwise install new
                                               circuit (fans rated for 150 watts
                                               each).
                                              System Performance Indicator
                                              One per fan
                                              Could be mounted externally i
                                              desired.
                                              Matched to fan
                                              See specifications
Figure 6-3. Pictorial Indication of System Locations and Details
                                    66

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                                                                    Compact every 6 in
                                                                    •.'.Ik-ii l •,!•. k !'il I n r.-
                                  Figure 6-4.  Detail 1  Suction Pit
Notes:
•   Location of core should be such that upper edge of hole is as close as possible to the bottom of the slab.
    Excavate if necessary.
•   Locate in accordance with general location shown on plan drawing, avoiding
•   sub grade utilities (call for utility locates and applicable digging permits)
•   Use core bit to cut hole - Do not chip out. Core 6-inch diameter hole through concrete wall.
•   Use re-bar locator to avoid rebar where possible. REPAIR KNICKED OR DAMAGED REBAR with 3M
    Scothkote 413/215 PC or equivalent.
•   Excavate out a minimum of 1.5 cu. ft. of soil. Soil must be removed up to underside of slab.
•   Insert vent pipe through hole extending at least 2 inches into excavated pit.
•   Seal pipe to inside of core with a minimum of two wraps of 1 -inch backer rod. Seal outer portion of pipe to wall
    with polyurethane caulk with a minimum depth of linch.
•   Back fill hole, stopping at 6 in depths to compact soil.
•   Replace asphalt where it was removed to facilitate coring of wall.
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                        4-inch  \ 4-incl
                       1 i- inch slainless
                       sleel screen
                       1'il in heiween pipe
                       and inlornul should
Figure 6-5. Detail 2 Vent Discharge
                 68

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                                           SECTION 7
                                        REFERENCES
Butler Jr., J.J., C.D. McElwee, and W. Liu.  Improving the Quality of Parameter Estimates Obtained from Slug
        Tests. Groundwater, Vol. 34, No. 3, pp480-490.  May-June 1996.

Cummings, J.B., C.R. Withers, and D.B. Shirey. Controlling Ventilation and Space Depressurization in Restaurants
        in Hot and Humid Climates.  Proceedings of the 18th Annual  AIVC Conference, Volume 1, pp!53-161,
        Athens, Greece.  September 1997.

Eklund, B., D. Folkes, J. Kabel, and S. Lock. What Fresh Hell is This? - Understanding Different State Approaches
        to VI.  In: Proceedings  of Vapor Intrusion: The Next Great Environmental Challenge - An Update,
        Sponsored by the Air & Waste Management Association (AWMA).  Los Angeles, CA.  September 13-15,
        2006.

Fischer,  M.L., A.J. Bentley, K.A.  Dunkin, A.T. Hodgson, W.M.  Nazaroff, R.G. Sextro, and J.M. Daisey.  Factors
        Affecting Indoor Air Concentrations  of Volatile Organic Compounds at a Site of Subsurface Gasoline
        Contamination. Environ. Sci. Technol., Vol. 30, No. 10, pp2948-2957. 1996.

Hodgson, A.T. and H. Levin. Volatile Organic  Compounds in Indoor Air: A Review of
Concentrations Measured in North America Since 1990.  Lawrence Berkeley National Laboratory, Berkeley, CA.
        LBNL-51715. April 21, 2003.

Interstate Technology & Regulatory Council (ITRC).  Technical and Regulatory Guidance for the Triad Approach:
        A New  Paradigm for Environmental Project  Management.   ITRC,  Sampling, Characterization  and
        Monitoring Team. December 2003.

Johnson, P.C. and R.A. Ettinger.   "Heuristic Model for Predicting the Intrusion Rate of Contaminant Vapors into
        Buildings," Environ. Sci. Technol., Vol. 25, No. 8, pp!445-1452. 1991.

Johnson, P.C., M.W. Kemblowski, and R.L. Johnson. Assessing the Significance of Subsurface Contaminant Vapor
        Migration to Enclosed Spaces: Site-Specific Alternatives to Generic Estimates. J. of Soil  Contamination,
        Vol.  8, No. 3, pp389-421. 1999.

Johnson, P.   Identification of Critical Parameters for the Johnson and Ettinger (1991)  Vapor Intrusion Model.
        American Petroleum Institute, Washington, DC.  API Soil and Groundwater Technical Task Force Bulletin
        No. 17. May 2002.

Olson, D.A. and R.L. Corsi.  Characterizing  Exposure  to Chemicals  from Soil Vapor Intrusion Using a Two-
        Compartment Model. Atmospheric Environment, Vol. 35, pp4201-4209.  2001.

Nordstrom, Phillip L. Occurrence, Availability, and Chemical Quality of Ground Water in the Cretaceous Aquifers
        of North-Central Texas, Volume 1. Texas Department of Water Resources Report 269. 1982.
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Persily, A. and J. Gorfain. Analysis of Ventilation Data from the U.S. Environmental Protection Agency Building
        Assessment Survey and Evaluation (BASE)  Study.  National Institute of Standards and Technology,
        NISTIR7145. December 2004.

Rehage, J., B. Eklund, S. Brown, S. Fain, J. Blake, and W. Harris.  Vapor Intrusion Assessment of Commercial
        Buildings at the Former Chanute Air Force Base. In: Proceedings of the Fifth International Conference on
        Remediation of Chlorinated and Recalcitrant Compounds, Sponsored by Battelle.  Monterey, CA. May 22-
        25, 2006.

TCEQ. Groundwater Classification.  TCEQ Regulatory Guidance, Remediation Division, RG-366/TRRP-8.  March
        2003.  Available at:
        http://www.tceq.state.tx.us/commexec/forms_pubs/pubs/rg/rg-366  trrp 08.html

US EPA.   Exposure Factors Handbook,  Volume  III - Activity Factors, Chapter  17  -  Residential Building
        Characteristics.    U.S.  EPA,  ORD.    EPA/600/P-95/002Fa.    August  1997.      Available  at:
        http://www.epa.gov/NCEA/pdfs/efh/sectl7.pdf

US EPA.  Cleaner Technologies Substitutes Assessment: Professional Fabricare Processes. US EPA, OPPTEETD,
        Washington, DC.  EPA744-B-98-001. June 1998.

US EPA. Compendium Method TO-15, Determination of Volatile Organic Compounds (VOCs) in Air Collected in
        Specially-Prepared Canisters and Analyzed by Gas Chromatography/Mass Spectrometry  (GC/MS).  In:
        Compendium of Methods  for the  Determination  of Toxic  Organic  Compounds in Ambient Air, 2nd
        Edition.  EPA/625/R-96-010b. January 1999.

US EPA.  SW-846.  Method 8265,  Volatile Organic Compounds in Water, Soil, Soil  Gas and Air by Direct
        Sampling   Ion  Trap   Mass    Spectrometry   (DSITMS).      March   2002.      Available   at:
        http://www.epa.gov/epaoswer/hazwaste/test/new-meth. htm#8265

US EPA.  Draft Guidance for Evaluating the Vapor Intrusion to Indoor Air Pathway from Groundwater and Soils
        (Subsurface Vapor Intrusion Guidance)," Federal Register, Vol. 67, No,.230, pp71169-71172. November
        29, 2002.

US EPA (2003a). Using the Triad Approach to Streamline Brownfields Site Assessment and Cleanup. Brownfields
        Technology Primer Series, EPA/OSWER, Washington, DC. June 2003.

US EPA (2003b).  User's Guide for Evaluating Subsurface Vapor Intrusion Into Buildings. US EPA, OEER. June
        19,2003. Available at: http://www.epa.gov/superfund/programs/risk/airmodel/iohnson ettinger.htm
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