16041_FlemingLabs_EMP_20190325

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EMP Version 2, June 2018
NORTH CAROLINA BROWNFIELDS PROGRAM
ENVIRONMENTAL MANAGEMENT PLAN
This form is to be used to prepare an Environmental Management Plan (EMP) for projects in
the North Carolina Brownfields Program at the direction of a Brownfields project manager.
The EMP is a typical requirement of a Brownfields Agreement (BFA). Its purpose is to clarify
actions to be taken during the demolition and construction at Brownfields properties in an
effort to avoid delays in the event of the discovery of new contamination sources or other
environmental conditions. The EMP provides a means to document redevelopment plans and
environmental data for each applicable environmental medium to inform regulatory-compliant
decision-making at the site. As much detail as possible should be included in the EMP,
including contingency planning for unknowns. Consult your project manager if you have
questions.
Prospective Developers and/or their consultants must complete and submit this form and all
pertinent attachments, see checklist below, to their Brownfields project manager prior to any
earthmoving or other development-related activities that have the potential to disturb soil at
the Brownfields Property, including demolition. For the resultant EMP to be valid for use, it
must be completed, reviewed by the program, signed by all parties working on the project,
and approved by the Brownfields project manager. Failure to comply with the requirements of
the EMP could jeopardize project eligibility, or in the event of a completed agreement, be
cause for a reopener
So that the EMP provides value in protecting brownfields eligibility and public health, the
preparer shall ensure that the following steps have been completed prior to submitting the
EMP for review.Any EMP prepared without completing these steps is premature.
☒Site sampling and assessment that meets Brownfields’ objectives is complete and has
been reviewed and approved by the Brownfields Project Manager.
☒ Specific redevelopment plans, even if conceptual, have been developed for the project,
submitted and reviewed by the Brownfields Project Manager.
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Please submit, along with the completed EMP form, the following attachments, as relevant
and applicable to the proposed redevelopment:
☒A set of redevelopment plans, including architectural/engineering plans, if available; if
not conceptual plans may suffice if updated when detailed plans are drafted.
☐A figure overlaying redevelopment plans on a map of the extent of contamination for
each media.
☒Site grading plans that include a cut and fill analysis.
☐A figure showing the proposed location and depth of impacted soil that would remain
on site after construction grading.
☐Any necessary permits for redevelopment (i.e. demolition, etc.).
☐A detailed construction schedule that includes timing and phases of construction.
☒Tabulated data summaries for each impacted media (i.e. soil, groundwater, soil gas,
etc.) applicable to the proposed redevelopment.
☒Figures with the sampling locations and contamination extents for each impacted media
applicable to the proposed redevelopment.
☐A full final grade sampling and analysis plan, if the redevelopment plan is final.
☐If known, information about each proposed potential borrow soil source, such as aerial
photos, historic site maps, historic Sanborn maps, a site history, necessary for
brownfields approval.
☐Information and, analytical data if required, for quarries, or other borrow sources,
detailing the type of material proposed for importation to the Brownfields Property.
☐A work plan for the sampling and analysis of soil to be brought onto the Brownfields
Property. Refer to Issue Resolution 15 in Brownfields Program Guidelines.
☐A map of the Brownfields Property showing the location of soils proposed for export
and sampling data from those areas.
☒If a Vapor Mitigation System is required by the Brownfields Program, the Vapor
Intrusion Mitigation System (VIMS) plan will be signed and sealed by a NC Professional
Engineer. The VIMS Plan may also be submitted under separate cover.
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GENERAL INFORMATION
Date:3/6/2019 Revision Date (if applicable):Click or tap to enter a date.
Brownfields Assigned Project Name:Fleming Laboratories
Brownfields Project Number: 16041-12-060
Brownfields Property Address: 2205, 2209 and 2215 Thrift Road, Charlotte, NC
Brownfields Property Area (acres):1.557 acres
Is Brownfields Property Subject to RCRA Permit?.......................☐ Yes ☒ No
If yes enter Permit No.:Click or tap here to enter text.
Is Brownfields Property Subject to a Solid Waste Permit….……..☐ Yes ☒ No
If yes, enter Permit No.:Click or tap here to enter text.
COMMUNICATIONS
A copy of this EMP shall be distributed to all the parties below as well as any contractors or site workers
that may be exposed to site vapors, soil, groundwater, and/or surface water. Additionally, a copy of the
EMP shall be maintained at the Brownfields Property during redevelopment activities. NOTE, THE EMP
DOES NOT TAKE THE PLACE OF A SITE-SPECIFIC HEALTH AND SAFETY PLAN.
Prospective Developer (PD):Summit Avenue Thrift Road, LLC
Contact Person:Matthew Browder
Phone Numbers: Office:N/A Mobile:[phone]
Email:[e-mail]
Contractor for PD:Doerre Construction Co, LLC
Contact Person:James Marion
Phone Numbers: Office:N/A Mobile:[phone]
Email:[e-mail]
Environmental Consultant:Terracon Consultants, Inc.
Contact Person:Christopher Corbitt
Phone Numbers: Office:704-509-1777 Mobile:[phone]
Email:[e-mail]
Brownfields Program Project Manager:Ms. Carolyn F. Minnich
Phone Numbers: Office:704-661-0330 Mobile:[phone]
Email:[e-mail]
Other DEQ Program Contacts (if applicable, i.e., UST Section, Inactive Hazardous Site Branch,
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Hazardous Waste, Solid Waste):
Inactive Hazardous Waste Branch
Contact Person:Cathy Jacobs
Phone Number:336-776-9677
Email:[e-mail]
NOTIFICATIONS TO THE BROWNFIELDS PROGRAM
Written advance Notification Times to Brownfields Project Manager: Check each box to accept
minimum advance notice periods (in calendar days) for each type of onsite task:
On-site assessment or remedial activities:……………………………………….……10 days Prior ☒
Construction or grading start:……………………………………….……………………….10 days Prior ☒
Discovery of stained soil, odors, USTs, buried drums or waste, landfill, or other signs of previously
unknown contamination: ……………………………….…………………………………….Within 48 hours ☒
Implementation of emergency actions (e.g. dewatering, flood or soil erosion control measures in
area of contamination, ventilation of work zones):…………….……….………Within 48 hours ☒
Installation of mitigation systems:………………………….………………….……….. 10 days Prior ☒
Other notifications as required by local, state or federal agencies to implement redevelopment
activities: (as applicable): ……………………….…………………………………………..…Within 30 days ☒
REDEVELOPMENT PLANS
1)Type of Redevelopment (check all that apply):
☐Residential ☒Recreational ☒Institutional ☒Commercial ☒Office ☒Retail ☒Industrial
☐Other specify:
Phase I of PD’s redevelopment plans include developing a new parking area and renovating the
existing on-site building for occupancy by multiple tenants and a deck/patio area along the
southern extent of the building.
2)Check the following activities that will be conducted prior to commencing earth-moving activities
at the site:
☒ Review of historic maps (Sanborn Maps, facility maps)
☐ Conducting geophysical surveys to evaluate the location of suspect UST, fuel lines, utility
lines, etc.
☒ Interviews with employees/former employees/facility managers/neighbors
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3)Summary of Redevelopment Plans (MANDATORY: attach detailed plans or conceptual plans, if
detailed plans are not available. EMP review without such information would be premature):
Provide brief summary of redevelopment plans, including demolition, removal of building
slabs/pavement, grading plans and planned construction of new structures:
PD anticipates the southern and northern portions of the site will be utilized as asphalt-paved
parking areas. The existing building will be renovated for occupancy by multiple retail tenants.
Redevelopment plans include raising the grade of the existing gravel-covered lot with gravel,
asphalt paving, stripping limited topsoil, and development of a deck/patio along the southern
extent of the building. A liner or marker will be installed between the base layer of material and
soils added beneath the deck/patio in the southern portion of the site. The general contractor
and tenants will be made aware of the sub-slab depressurization system prior to renovations.
Proposed redevelopment plans are included as Figure 3.
4)Do plans include demolition of structure(s)?:
☐Yes ☒No ☐Unknown
☐If yes, please check here to confirm that demolition will be conducted in accordance with
applicable legal requirements, including without limitation those related to lead and asbestos
abatement that are administered by the Health Hazards Control Unit within the Division of Public
Health of the North Carolina Department of Health and Human Services. If available, please
provide a copy of your demolition permit.
5)Are sediment and erosion control measures required by federal, state, or local regulations?
☒Yes ☐No ☐Unknown
☒If yes, please check here to confirm that demolition will be conducted in accordance with
applicable legal requirements. If soil disturbance is necessary to install sediment and erosion
control measures, they may not begin until this EMP is approved.
6)Which category of risk-based screening level is used or is anticipated to be specified in the
Brownfields Agreement?Note: If children frequent the property, residential screening levels shall
be cited in the Brownfields Agreement for comparison purposes.
☐Residential ☒Non-Residential or Industrial/Commercial
7)Schedule for Redevelopment (attach construction schedule):
a)Construction start date:4/1/2019
b)Anticipated duration (specify activities during each phase):
13 weeks
c)Additional phases planned?☐ Yes ☐No
If yes,specify the start date and/or activities if known:
Start Date:Click or tap to enter a date.
Planned Activity:
Click or tap here to enter text.
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Start Date:Click or tap to enter a date.
Planned Activity:
Click or tap here to enter text.
Start Date:Click or tap to enter a date.
Planned Activity:
Click or tap here to enter text.
d)Provide the planned date of occupancy for new buildings:8/1/2019
CONTAMINATED MEDIA
1)Contaminated Media on the Brownfields Property
Part 1. Soil:……………………………………….…………….☒ Yes ☐ No ☐ Suspected
Part 2. Groundwater:.……………………….……..…….☒ Yes ☐ No ☐ Suspected
Part 3. Surface Water:.……………...……..……………☐ Yes ☒ No ☐ Suspected
Part 4. Sediment:.……………...……..……………………☒ Yes ☐ No ☐ Suspected
Part 5. Soil Vapor:…..…………...……..………………….☐ Yes ☐ No ☒ Suspected
Part 6. Sub-Slab Soil Vapor:……...……..……………..☒ Yes ☐ No ☐ Suspected
Part 7. Indoor Air:...……..………………………………….☒ Yes ☐ No ☐ Suspected
2)For the Area of Proposed Redevelopment on the Brownfields Property, attach tabulated data
summaries for each impacted media and figure(s) with sample locations.
PART 1. Soil – Please fill out the information below, using detailed site plans, if available, or estimate
using known areas of contaminated soil and a conceptual redevelopment plan. Provide a figure
overlaying new construction onto figure showing contaminated soil and groundwater locations.
1)Known or suspected contaminants in soil (list general groups of contaminants):
Soil analytical results are included as Tables 1A through 1E and are shown on Figures 4A, 4B and
4C.
VOCs:
Confirmation samples from an April 1990 UST closure near the southwestern corner of the
existing building identified residual contamination in soils. The detected concentrations from
1990 do not exceed the 2018 PSRGs. Contaminants included benzene, ethylbenzene and total
xylenes. During a 2011/2012 site assessment, Hart and Hickman (H&H) screened 51 soil borings
at the site using a PID for the presence of VOCs. Since the highest PID reading was 21.7 parts per
million (ppm), H&H did not analyze the samples for VOCs.
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SVOCs:
During the removal of four on-site USTs in April 1990, residual contamination was identified
beneath the former aniline/xylenes USTs. According to the analytical report, aniline was
detected above its 2018 Non-Residential PSRG in multiple sidewall confirmation samples. Bis(2-
ethylhexyl) phthalate was also detected in certain confirmation samples but the concentrations
did not exceed its 2018 PSRG.
Metals:
A total of 51 soil samples and two background soil samples were also collected for metals during
the 2011/2012 H&H site assessment. Certain soil samples were analyzed for arsenic by EPA
6010C and TCLP by EPA Method 6010C. The analytical results from the 2011/2012 sampling
event are summarized in Tables 1A, 1B, 1C and 1D. One sample located near the former arsanilic
acid AST (HH-2B-20A) exceeded the RCRA hazardous waste threshold of 5 milligrams per liter
(mg/L) for arsenic by TCLP. According to the H&H Brownfields Redevelopment Report, dated
September 24, 2014, approximately 53 tons of characteristic waste were removed to a depth of
about 4 feet below ground surface (bgs) from the site during grading activities. According to
excavation sidewall and bottom samples collected after excavation, a limited amount of
characteristic waste remains in the southern portion of the site. Following the completion of
grading activities conducted in 2014, a geotextile fabric layer was installed over the entire
southern portion of the site and clean fill material was imported and placed over the geotextile
fabric barrier as a cap. The two background samples (HHBG-1 and HHBG-2) were collected in the
northern portion of the site from various depth intervals ranging from 0 to 10 feet below ground
surface (bgs). Analytical results for the two background samples did not identify arsenic
concentrations above the established Industrial PSRG. Detected concentrations in the
background samples included 2.2 mg/kg in the 1.5-2 foot interval in HHBG-2, 2.8 mg/kg in the 0-
0.5 foot interval of HHBG-1 and 2.9 mg/kg in the 0-0.5 foot interval of HHBG-1. Arsenic
concentrations were not detected above laboratory reporting limits in depth intervals below 0.5
feet bgs in sample HHBG-1 or below 2 feet bgs in sample HHBG-2.
2)Depth of known or suspected contaminants (feet):
Soils with arsenic concentrations detected above its non-residential PSRG in the southern
portion of the site are located below the geotextile fabric barrier (approximately 1 foot below
current grade) to depths of approximately 12 feet bgs. Confirmation soil samples collected from
the characteristic waste excavation indicate residual characteristic waste is located within the
southwestern portion of the site from approximately 2 feet bgs to at least 4 feet bgs near the
western wall of the former on-site building (demolished). The areas of characteristic waste
excavation are shown on Figure 4B.
3)Area of soil disturbed by redevelopment (square feet):
According to drawings provided by the civil engineer, the total area of the site disturbed by
redevelopment activities, including a narrow strip of land in the northern portion of the site, is
approximately 36,000 square feet.
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4)Depths of soil to be excavated (feet):
Based on discussions with the civil engineer, grading activities in the northern portion of the site
will be limited to a depth of 5 feet bgs. The proposed parking area in the southern portion of the
site will not require excavation.
5)Estimated volume of soil (cubic yards) to be excavated (attach grading plan):
According to the civil engineer, to balance the site, approximately 1,200 cubic yards of imported
fill materials consisting of ABC stone and asphalt will be used to raise the grade of the proposed
parking area (southern portion of site). The northern portion of the site will generate
approximately 150 cubic yards of cut soils. Based on conversations with the PD and civil
engineer, the cut soils from the northern portion of the site are anticipated to be used as fill in
the deck/patio area along the southern exterior wall of the on-site building. The proposed
grading plan is included as Figure 3.
6)Estimated volume of excavated soil (cubic yards) anticipated to be impacted by contaminants:
Not applicable. No soils will be excavated in the area with known contaminants located in the
southern portion of the site. The grade in this area will be raised for a proposed parking area.
According to the background soil samples collected in the northern portion of the site where
limited excavation will occur, arsenic concentrations are within published naturally occurring
arsenic values for the site area. Arsenic concentrations in the northern portion of the site are
also consistent with soil samples collected on the northern adjacent Brownfields property (Berry
Hill Thrift Road #21061-17-060). Concentrations on the northern adjacent property ranged from
below laboratory detection limits to 23 mg/kg.
7)Estimated volume of contaminated soil expected to be disposed of offsite, if applicable:
No off-site disposal of contaminated soil is anticipated at this time based on the grading plan
provided by the civil engineer.
Part 1.A. MANAGING ONSITE SOIL
If soil is anticipated to be excavated from the Brownfield Property, relocated on the Brownfields
Property, or otherwise disturbed during site grading or other redevelopment activities, please
provide a grading plan that clearly illustrates areas of cut and fill (approximate areas & volumes are
acceptable, if only preliminary data available).
1)HAZARDOUS WASTE DETERMINATION:
a)Does the soil contain a LISTED WASTE as defined in the North Carolina Hazardous
Waste Section under 40 CFR Part 261.31-261.35?.......................................☐Yes ☒No
☐ If yes,explain why below, including the level of knowledge regarding processes
generating the waste (include pertinent analytical results as needed).
Click or tap here to enter text.
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☐If yes,do the soils exceed the “Contained-Out” levels in Attachment 1 of the
North Carolina Contained-In Policy?.................................................☐ Yes ☐ No
b)NOTE: IF SOIL MEETS THE DEFINITION OF A LISTED HAZARDOUS WASTE AND EXCEEDS
THE CONTAINED-OUT LEVELS IN ATTACHMENT 1 TO THE NORTH CAROLINA
CONTAINED-IN POLICY THE SOIL MAY NOT BE RE-USED ON SITE AND MUST BE
DISPOSED OF IN ACCORDANCE WITH DEQ HAZARDOUS WASTE SECTION RULES AND
REGULATIONS.
c) Does the soil contain a CHARACTERISTIC WASTE?....................................☒ Yes ☐ No
☒ If yes, mark reason(s) why below (and include pertinent analytical results).
☐ Ignitability Click or tap here to enter text.
☐ Corrosivity Click or tap here to enter text.
☐ Reactivity Click or tap here to enter text.
☐ Toxicity Click or tap here to enter text.
☒ TCLP results In November 2011 and March 2012, H&H advanced 51 soil
borings in the southern portion of the site to determine the extent of arsenic
contamination. Hart & Hickman also utilized a handheld X-Ray Florescence
analyzer to determine arsenic concentrations. H&H analyzed selected soil
samples for total arsenic and TCLP RCRA metals. One sample located near the
former arsanilic acid AST (HH-2B-20A) exceeded the RCRA hazardous waste
threshold of 5 mg/L for arsenic by TCLP. According to the H&H Brownfields
Redevelopment Report, dated September 24, 2014, approximately 53 tons of
characteristic waste were removed to a depth of about 4 feet bgs from the
site during grading activities. According to excavation sidewall and bottom
samples collected after excavation, a limited amount of characteristic waste
remains in the southern portion of the site. Following completion of grading
activities, a geotextile fabric layer was installed over the entire southern
portion of the site and clean fill material was imported and placed over the
geotextile fabric barrier as a cap. The southern perimeter of the site consists
of a geotextile fabric barrier overlain by 1 foot of clean fill. The south-central
area of the site consists of 6 inches of clean soil overlain by 6 inches of ABC
stone. A rendering of the grading plan is included in the appendix . Based on
the preliminary site plans, the southern portion of the site is anticipated to be
an asphalt paved parking lot. PD’s redevelopment plans do not include
excavation that will affect the geofabric, so it is not anticipated that
characteristic hazardous waste will be encountered during site work. If
impacted soils are discovered during grading, procedures for screening and
sampling the soils will be implemented as described above (field screening of
soils) and in Part 9 (Contingency Plan).
☐ Rule of 20 results (20 times total analytical results for an individual
hazardous constituent on TCLP list cannot, by test method, exceed regulatory
TCLP standard)
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Click or tap here to enter text.
☐ If no,explain rationale:
Click or tap here to enter text.
d)NOTE: IF SOIL MEETS THE DEFINITION OF A CHARACTERISTIC HAZARDOUS WASTE, THE
SOIL MAY NOT BE RE-USED ON SITE AND MUST BE DISPOSED OF IN ACCORDANCE
WITH DEQ HAZARDOUS WASTE SECTION RULES AND REGULATIONS.
2)Screening criteria by which soil disposition decisions will be made (e.g., left in place, capped in
place with low permeability barrier, removed to onsite location and capped, removed offsite):
☐ Preliminary Health-Based Residential SRGs
☒ Preliminary Health-Based Industrial/Commercial SRGs
☒ Division of Waste Management Risk Calculator (For Brownfields Properties Only)
☐ Site-specific risk-based cleanup level. Please provide details of methods used for
determination/explanation.
Click or tap here to enter text.
Additional comments:
Click or tap here to enter text.
3)If known impacted soil is proposed to be reused within the Brownfields Property Boundary,
please check the measures that will be utilized to ensure safe placement and documentation of
same. Please attach a proposed location diagram/site map.
☒ Provide documentation of analytical report(s) to Brownfields Project Manager
☒ Provide documentation of final location, thickness and depth of relocated soil on site map
to Brownfields Project Manager once known
☒ Geotextile to mark depth of fill material.
Provide description of material:
Following completion of grading activities conducted in 2014, a
geotextile fabric layer was installed over the entire southern
portion of the site and clean fill material was imported and placed
over the geotextile fabric barrier as a cap. The southern perimeter
of the site consists of geotextile fabric barrier overlain by 1 foot of
clean fill. The south-central area of the site consists of 6 inches of
clean soil overlain by 6 inches of ABC stone. A rendering of the
grading plan is included in the appendix . Based on the preliminary
site plans, the southern portion of the site is anticipated to be an
asphalt paved parking lot. PD’s redevelopment plans do not
include excavation that will affect the geofabric, so it is not
anticipated that characteristic waste will be encountered during
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site work. If impacted soils are discovered during grading,
procedures for screening and sampling the soils will be
implemented as described above (field screening of soils) and in
Part 9 (Contingency Plan).
☐
☒ Manage soil under impervious cap ☒ or clean fill ☒
☒ Describe cap or fill:
To be determined - Based on conversations with the civil engineer, proposed areas of cut
are limited to the northern portion of the site and are not in areas of known contamination.
Potentially impacted soils will likely be placed as fill under the deck/patio area along the
southern exterior wall of the on-site building.
☒ Confer with NC BF Project Manager if Brownfield Plat must be revised (or re-recorded if
actions are Post-Recordation).
☐ GPS the location and provide site map with final location.
☐ Other. Please provide a description of the measure:
4)Please describe the following action(s) to be taken during and following excavation and
management of site soils:
Management of fugitive dust from site
☒ Yes, describe the method will include:
Soils that are dry and have the potential to migrate through air from the site will be
managed in accordance with typical construction practices.The grading contractor will take
into account conditions such as wind speed, wind direction, and moisture content of soil
during soil grading and stockpiling activities to minimize dust generation. In the unlikely
event that contaminated soil is encountered during Site redevelopment that requires
excavation, particular attention will be paid by contractors to implement dust control
measures as needed based on Site and atmospheric conditions (i.e. by controlled water
application, hydro-seeding, and/or mulch, stone, or plastic cover). Potentially impacted soil
will be managed as described below.
☐ No, explain rationale:
Click or tap here to enter text.
Field Screening of site soil
☒ Yes, describe the field screening method, frequency of field screening, person conducting
field screening:
During soil disturbance activities, soils will be observed for discoloration, odor, or other
evidence of potential contamination. Should evidence of impacted soils be noted during
site work, the contractor will contact the project environmental professional to observe
the suspect condition. If the project environmental professional confirms that the material
Click or tap here to enter text.
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may be impacted (by observations or by screening with a PID or organic vapor analyzer
[OVA]), then the procedures in Part 9 (Contingency Plan) will be implemented. In addition,
the NCDEQ Brownfields Project Manager will be contacted within 48 hours to advise them
of the condition.
☐ No, explain rationale:
Click or tap here to enter text.
Soil Sample Collection
☒ Yes, describe the sampling method (e.g., in-situ grab, composite, stockpile, etc.):
See “Final Grade Sampling” section on page 12. Based on previous site assessment
activities and grading plans, it is unlikely that significant soil impacts will be encountered
during redevelopment activities. No additional soil sampling (other than final grade
sampling) is warranted unless unexpected soil impacts are encountered. If impacted soils
are discovered, procedures for screening and sampling the soils will be implemented as
described above (field screening of soils) and in Part 9 (Contingency Plan).
☐ No, explain rationale:
Click or tap here to enter text.
If soil samples are collected for analysis, please check the applicable chemical analytes:
☒ Volatile organic compounds (VOCs) by EPA Method 8260
☒ Semi-volatile organic compounds (SVOCs) by EPA Method 8270
☒ Metals RCRA List (8)(arsenic, barium, cadmium, chromium, mercury,lead, selenium
and silver): Specify Analytical Method Number(s):
Soils will be analyzed by EPA Method 6010/7471.
☐ Pesticides:Specify Analytical Method Number(s):Click or tap here to enter text.
☐ PCBs:Specify Analytical Method Number(s):Click or tap here to enter text.
☐ Other Constituents & Respective Analytical Method(s) (i.e. Hexavalent Chromium,Herbicides, etc.): Specify Analytical Method Number(s):Click or tap here to enter text.
☒ Check to confirm that stockpiling of known or suspected impacted soils will be conducted
in accordance with Figure 1 of this EMP. Stockpile methodology should provide erosion
control, prohibiting contact between surface water/precipitation and contaminated soil,
and preventing contaminated runoff. Explain any variances or provide additional details as
needed:
If or when impacted soils are encountered, they may be direct loaded into trucks or stockpiled on the
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☒ Final grade sampling of exposed native soil (i.e., soil that will not be under buildings or
permanent hardscape).Select chemical analyses for final grade samples with check boxes
below (Check all that apply):
☒ Volatile organic compounds (VOCs) by EPA Method 8260
☒ Semi-volatile organic compounds (SVOCs) by EPA Method 8270
☒ Metals RCRA List (8) (arsenic, barium, cadmium, chromium, mercury,lead,selenium and silver): Specify Analytical Method Number(s):Soil samples will be analyzed by EPA Method 6010/7471.
☐ Pesticides: Specify Analytical Method Number(s):Click or tap here to enter text.
☐ PCBs: Specify Analytical Method Number(s):Click or tap here to enter text.
☐ Other Constituents & Respective Analytical Method(s)(i.e. HexavalentChromium, Herbicides, etc.):Click or tap here to enter text.
Please provide a scope of work for final grade sampling, including a diagram of soil
sampling locations, number of samples to be collected, and brief sampling methodology.
Samples should be collected from 0-2 ft below ground surface, with the exception of VOCs
which should be taken from 1-2 ft below ground surface. Alternatively, a work plan for
final grade sampling may be submitted under separate cover.
A work plan for final grade sampling within the landscaped areas and/or other exposed
soils will be submitted to the NCDEQ Brownfields Program for review and approval under
separate cover.
☐If final grade sampling was NOT selected please explain rationale:
Click or tap here to enter text.
Part 1.B. IMPORTED FILL SOIL
NO SOIL MAY BE BROUGHT ONTO THE BROWNFIELDS PROPERTY WITHOUT PRIOR APPROVAL
FROM THE BROWNFIELDS PROGRAM. According to the Brownfields IR 15, “Documenting
imported soil (by sampling, analysis, and reporting in accordance with review and written
approval in advance by the Brownfields Program), will safeguard the liability protections provided
by the brownfields agreement and is in the best interest of the prospective developer/property
owner.”
Requirements for importing fill:
BF Property.
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1)Will fill soil be imported to the site?................................................ ☒Yes ☐No ☐Unknown
2)If yes, what is the estimated volume of fill soil to be imported?
According to the civil engineer, approximately 1,200 cubic yards of soil will need to be imported
to the site.
3)If yes, what is the anticipated depth that fill soil will be placed at the property? (If a range
of depths, please list the range.)
According to the proposed cut/fill report from the civil engineer, imported soils will be placed
from 0 to 2 feet at the property.
4)Provide the source of fill, including: location, site history, nearby environmental concerns,
etc. Attach aerial photos, maps, historic Sanborn maps and a borrow source site history:
The source of the fill material is to be determined.
5)PRIOR TO ITS PLACEMENT AT THE BROWNFIELDS PROPERTY, provide a plan to analyze fill
soil to demonstrate that it meets acceptable standards applicable to the site and can be
approved for use at the Brownfields property.
Prior to placement of fill material, import soils will be obtained from a facility pre-approved by
DEQ based on existing analytical data and historical information of the source material. If PD
cannot import soil from a DEQ-approved site, it will submit a plan to analyze fill soils (or existing
data) for approval from the NCDEQ Brownfields Program.
6)Please check the applicable chemical analytes for fill soil samples. (Check all that apply):
☒ Volatile organic compounds (VOCs) by EPA Method 8260
☒ Semi-volatile organic compounds (SVOCs) by EPA Method 8270
☒ Metals RCRA List (8) (arsenic, barium, cadmium, chromium, mercury,lead,
selenium and silver): Specify Analytical Method Number(s):
Soil samples will be analyzed by EPA Method 6010/7471.
☐ Pesticides: Specify Analytical Method Number(s):
Click or tap here to enter text.
☐ PCBs: Specify Analytical Method Number(s):
Click or tap here to enter text.
☐ Other Constituents & Respective Analytical Method(s)(i.e. Hexavalent
Chromium, Herbicides, etc.):
Click or tap here to enter text.
7)The scope of work for import fill sampling may be provided below or in a Work Plan
submitted separately for DEQ review and approval. Attach specific location maps for in-situ
borrow sites. If using a quarry, provide information on the type of material to be brought
onto the Brownfields Property.
According to the civil engineer, the grade for the proposed parking area will be raised. The
materials used to raise the grade will consist of approximately 1,200 cubic yards of fill material, 6
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inches of ABC stone, three inches of asphalt as pavement. The approximate 150 cubic yards of cut
soils from the northern portion of the site are planned for placement under the proposed
deck/patio along the southern exterior wall of the on-site building. The import will be obtained
from a facility pre-approved by DEQ based on existing analytical data and historical information of
the source material. If PD cannot import soil from a DEQ-approved site, it will submit a plan to
analyze fill soils (or existing data) for approval by the NC Brownfields Program.
Part 1.C. EXPORTED SOIL
NO SOIL MAY LEAVE THE BROWNFIELDS PROPERTY WITHOUT APPROVAL FROM THE
BROWNFIELDS PROGRAM. FAILURE TO OBTAIN APPROVAL MAY VIOLATE A BROWNFIELDS
AGREEMENT CAUSING A REOPENER OR JEOPARDIZING ELIGIBILITY IN THE PROGRAM,
ENDANGERING LIABILITY PROTECTIONS AND MAKING SAID ACTION POSSIBLY SUBJECT TO
ENFORCEMENT. JUSTIFICATIONS PROVIDED BELOW MUST BE APPROVED BY THE PROGRAM IN
WRITING PRIOR TO COMPLETING TRANSPORT ACTIVITIES. Please refer to Brownfields IR 15 for
additional details.
1)If export from a Brownfields Property is anticipated, please provide details regarding the
proposed export actions. Volume of exported soil, depths, location from which soil will
be excavated on site, related sampling results, etc. Provide a site map with locations of
export and sampling results included.
Export of soils from the site is not anticipated based on the grading plan.
2)To what type of facility will the export Brownfields soil be sent?
☒ Subtitle D/Municipal Solid Waste Landfill (analytical program to be determined by
landfill)
☐ Permitted but Unlined Landfill (i.e. LCID, C&D, etc.) Analytical program to be
determined by the accepting Landfill;
☐ Landfarm or other treatment facility
☒ Use as fill at another suitable Brownfields Property –determination that a
site is suitable will require, at a minimum, that similar concentrations of the same or
similar contaminants already exist at both sites, use of impacted soil will not increase
the potential for risk to human health and the environment at the receiving Brownfields
property, and that a record of the acceptance of such soil from the property owner of
the receiving site is provided to Brownfields. Please provide additional details below.
☐ Use as Beneficial Fill off-site at a non-Brownfields Property -Please provide
documentation of approval from the property owner for receipt of fill material. This will
also require approval by the DEQ Solid Waste Section. Additional information is
provided in IR 15. Please provide additional details below.
3)Additional Details: (if transfer of soil to another property is requested above, please provide
details related to the proposed plans).
Off-site disposal of soil is not anticipated based on the grading plan. The PD anticipates cut soils
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in the northern portion of the site will remain on the site. The soils are planned for placement
under the proposed deck/patio along the southern exterior wall of the on-site building. If
grading specifications are not met, the PD will provide a work plan to the Brownfields Program
regarding soil export for approval under separate cover.
Part 1.D. MANAGEMENT OF UTILITY TRENCHES
☐ Install liner between native impacted soils and base of utility trench before filling with clean fill
(Preferred)
☒ Last out, first in principle for impacted soils (if soil can safely be reused onsite and is not a
hazardous waste), i.e., impacted soils are placed back at approximately the depths they
were removed from such that impacted soil is not placed at a greater depth than the original
depth from which it was excavated.
☒ Evaluate whether necessary to install barriers in conduits to prevent soil vapor transport,
and/or degradation of conduit materials due to direct impact with contaminants?
☐ If yes, provide specifications on barrier materials:
During renovations associated with tenant uplifts within the on-site building, the sub-slab
depressurization system will be monitored so that renovations do not interfere with the existing
system. See the Vapor Mitigation Section for further explanation.
☒ If no, include rationale here:
VOCs, including chlorinated compounds, have been identified in the groundwater and soil vapor
at the site. A sub-slab depressurization (SSD) system was installed at the site from June to August
2017 by Hart & Hickman. Indoor air samples collected after the SSD system was installed and
had started operation did not identify VOCs above their respective Residential or Non-Residential
IASLs. Based on the 2018 indoor air sample analytical results and current operation of the SSD
system, soil vapor transport is not anticipated to be a concern within the on-site building. If soil
vapors are detected during grading or construction activities involving excavation of subsurface
utility trenches or sub-grade structures, Terracon will be notified to assess the presence of the
vapors with a PID. If vapors do not readily dissipate, soil samples may be obtained and analyzed
for VOCs and SVOCs to evaluate the source of the vapors and appropriate worker safety
measures will be employed (such as fans) to allow the workers to safely complete their work.
Other comments regarding managing impacted soil in utility trenches:
Concerns and methods for environmental handling of soils do not preclude nor modify any of the
Occupational Safety and Health Administration (OSHA) requirements for worker safety incumbent
upon contractors for regular site safety and trenching/excavation activities. OSHA requirements will
dictate adjustments of the soil management methods where necessary regarding OSHA construction
safety. If contaminated soils are encountered during utility trench installation, the screening and
management will be conducted as described above for managing on-site soils.
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PART 2. GROUNDWATER – Please fill out the information below.
1)What is the depth to groundwater at the Brownfields Property?
During assessment activities in April 2016, depth to groundwater ranged from 19.65 ft bgs in
the northern portion of the site to 24.08 ft bgs in the central portion of the site.
2)Is groundwater known to be contaminated by ☐onsite ☐offsite ☒both or ☐unknown
sources? Describe source(s):
The on-site groundwater samples collected during 2016 assessment activities contained various
VOCs above their respective Residential and Non-Residential GWSLs and NCAC 2L Standards.
SVOCs and metals concentrations were not analyzed during the 2016 sampling event.
The Berryhill-Thrift Road Brownfields site (NCBP #21061-17-060) located on the adjacent up-
gradient property to the north of the site has documented groundwater and soil impacts.
Additionally, the former General Electric facility (2328 Thrift Road) is also located on an adjacent
and up-gradient property. The former General Electric facility has reportedly removed impacted
soils (chlorinated compounds and PCBs) from the facility; however, the contaminant plume in
the groundwater extends from the GE site to the south and southeast. According to regulatory
information, light non-aqueous phase liquids (LNAPLs), dissolved phase chlorinated compounds,
and PCBs remain in the groundwater above their respective NCAC 2L standards.Analytical results
from the 2016 groundwater sampling event indicated well TMW-1 located in the northern
portion of the site may have been impacted by off-site sources suggesting potential co-mingling
with on-site sources.
3)What is the direction of groundwater flow at the Brownfields Property?
Groundwater in the surficial aquifer appears to be flowing towards the south-southeast.
Groundwater appears to flow towards an unnamed tributary of Stewart Creek.
4)Will groundwater likely be encountered during planned redevelopment activities?
☐Yes ☒No
If yes, describe these activities:
According to the civil engineer, planned redevelopment activities at the site will be limited to 0-5
feet below ground surface. Based on the measurements obtained during 2003 and 2016
assessments, shallow groundwater was encountered below 20 feet bgs; therefore, groundwater
is not anticipated to be encountered during redevelopment.
Regardless of the answer; in the event that contaminated groundwater is encounteredduring redevelopment activities (even if no is checked above), list activities for contingentmanagement of groundwater (e.g., dewatering of groundwater from excavations orfoundations, containerizing, offsite disposal, discharge to sanitary sewer, NPDES permit, orsampling procedures).
It is not anticipated that contaminated groundwater will be encountered during redevelopment
based on prior groundwater sampling activities. If groundwater is encountered during
redevelopment activities, appropriate worker safety measures will be undertaken and
groundwater will be allowed to re-infiltrate for approximately 24 hours (if it does not affect the
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construction schedule). No soil will be added to the excavation during that time period. If
accumulated water remains in an excavation after allowing time to re-infiltrate, samples of the
accumulated water will be collected and analyzed for VOCs by EPA Method 8260, SVOCs by EPA
Method 8270, and RCRA metals by EPA Method 6010/7470 to determine if contaminants are
present. Accumulated water that contains contaminants above NCAC 2B Surface Water
Standards will be containerized and disposed at an off-site permitted facility. Accumulated
water that does not contain contaminants above NCAC 2B Surface Water Standards will be
managed on the site or discharged to surface water or the storm sewer in accordance with
municipal, state and federal requirements.
5)Are monitoring wells currently present on the Brownfields Property?.................☐Yes ☒No
If yes, are any monitoring wells routinely monitored through DEQ or other
agencies?..................................................................................................................☐Yes ☐No
6)Please check methods to be utilized in the management of known and previously
unidentified wells.
☒ Abandonment of site monitoring wells in accordance with all applicable regulations. It
is the Brownfields Program’s intent to allow proper abandonment of well(s) as
specified in the Brownfields Agreement, except if required for active monitoring
through another section of DEQ or the EPA.
☐ Location of existing monitoring wells marked
☐ Existing monitoring wells protected from disturbance
☒ Newly identified monitoring wells will be marked and protected from further
disturbance until notification to DEQ Brownfields can be made and approval for
abandonment is given.
7)Please provide additional details as needed:
Please note, disturbance of existing site monitoring wells without approval by DEQ is not
permissible. If monitoring wells are damaged and/or destroyed, DEQ may require that the PD
be responsible for replacement of the well.
PART 3. SURFACE WATER -Please fill out the information below.
1)Is surface water present at the property?☐ Yes ☒ No
2)Attach a map showing the location of surface water at the Brownfields Property.
3)Is surface water at the property known to be contaminated?☐ Yes ☒ No
During a January 2019 site reconnaissance, existing monitoring wells on the Brownfields property
were observed to be abandoned and/or destroyed. If additional monitoring wells are discovered
during redevelopment, the wells will be left intact. If wells are within the redevelopment area, the PD
will seek approval for abandonment from IHSB prior to abandonment activities.
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4)Will workers or the public be in contact with surface water during planned redevelopment
activities?☐ Yes ☒ No
5)In the event that contaminated surface water is encountered during redevelopment
activities, or clean surface water enters open excavations, list activities for management of
such events (e.g. flooding, contaminated surface water run-off, stormwater impacts):
Encountering contaminated surface water is not anticipated based on current redevelopment
plans. Excavations and trenches in areas where potentially impacted soils could be encountered
and near property boundaries shall be graded, bermed, or provided with an equivalent barrier,
where necessary, to help prevent stormwater from entering excavations and stormwater run-off
from leaving the site boundaries. If stormwater or water from an unidentified source collects in
excavation areas, appropriate worker safety measures will be undertaken and water will be
allowed to infiltrate for approximately 24 hours (if it does not affect the construction schedule).
If accumulated water remains in an exaction after allowing time to infiltrate, samples of the
accumulated water will be collected and analyzed for VOCs (EPA Method 8260), SVOCs (EPA
Method 8270, and RCRA Metals (EPA Method 6010/7470). Accumulated water that contains
contaminants above NCAC 2B Surface Water Standards will be containerized and disposed at an
off-site permitted facility. Accumulated water that does not contain contaminants above NCAC
2B Surface Water Standards will be managed on the Site or discharged to surface water or the
storm sewer in accordance with municipal, state and federal requirements.
PART 4. SEDIMENT – Please fill out the information below.
1)Are sediment sources present on the property?☒ Yes ☐ No
2)If yes, is sediment at the property known to be contaminated:☒ Yes ☐ No
3)Will workers or the public be in contact with sediment during planned redevelopment
activities?☐ Yes ☒ No
4)Attach a map showing location of known contaminated sediment at the property.
5)In the event that contaminated sediment is encountered during redevelopment activities, list
activities for management of such events (stream bed disturbance):
While historical samples indicated contaminated sediment, this section is not applicable because
there is no natural drainage on the site.
PART 5. SOIL VAPOR – Please fill out the information below.
1)Do concentrations of volatile organic compounds at the Brownfields property exceed the
following vapor intrusion screening levels (current version) in the following media:
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IHSB Residential Screening Levels:
Soil Vapor:………..☒ Yes ☐ No ☐ Unknown
Groundwater:.….☒ Yes ☐ No ☐ Unknown
IHSB Industrial/Commercial Screening Levels:
Soil Vapor:………..☒ Yes ☐ No ☐ Unknown
Groundwater:…..☒ Yes ☐ No ☐ Unknown
2)Attach a map showing the locations of soil vapor contaminants that exceed site
screening levels.
3)If applicable, at what depth(s) is soil vapor known to be contaminated?
4)Will workers encounter contaminated soil vapor during planned redevelopment activities?
☐ Yes ☐ No ☒ Unknown
5)In the event that contaminated soil vapor is encountered during redevelopment activities
(trenches,manways, basements or other subsurface work,) list activities for management
of such contact:
VOCs, including chlorinated compounds, have been identified in the groundwater beneath the
site. During interior renovations, bay doors will be left open and fans will be utilized to allow
proper ventilation through the building. If contaminated soil vapors are detected during grading
or construction activities involving excavation of subsurface utility trenches or basement
structures, Terracon will be notified to assess the presence of the vapors with a PID. If vapors do
not readily dissipate, soil samples may be obtained and analyzed for VOCs and SVOCs to evaluate
the source of the vapors and appropriate worker safety measures will be employed (such as fans)
to allow the workers to safely complete their work.
PART 6. SUB-SLAB SOIL VAPOR – Please fill out the information below if existing buildings or
foundations will be retained in the redevelopment.
1)Are sub-slab soil vapor data available for the Brownfields Property?☒ Yes ☐ No ☐ Unknown
2)If data indicate that sub-slab soil vapor concentrations exceed screening levels, attach a map
showing the location of these exceedances.
3)At what depth(s) is sub-slab soil vapor known to be contaminated?☒0-6 inches ☐Other, please
describe:
In July 2016, sub-slab soil gas samples were collected within the first six inches below the
concrete slab of the existing on-site building. Various chlorinated compounds were detected
Volatile organic compounds (VOCs), including chlorinated compounds, have been identified in
groundwater and sub-slab soil gas samples at the site. In July 2016, sub-slab soil gas samples were
collected within the first six inches below the concrete slab of the existing on-site building. As a result
of various chlorinated compounds detected above their respective Non-Residential SGSLs, a sub-slab
depressurization (SSD) system was installed at the on-site building from June to August 2017.
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above their respective Non-Residential SGSLs resulting in the installation of a sub-slab
depressurization (SSD) system at the building from June to August 2017.
4)Will workers encounter contaminated sub-slab soil vapor during planned redevelopment
activities?☐ Yes ☐ No ☒ Unknown
5)In the event that contaminated soil vapor is encountered during redevelopment activities, list
activities for management of such contact
Volatile organic compounds (VOCs), including chlorinated compounds, have been identified in
the groundwater and soil gas beneath the site. During interior renovations, bay doors will be left
open and fans will be utilized to allow proper ventilation through the building. Vapors will be
evaluated, as discussed in Part 5. If contaminated soil vapors are detected during grading or
construction activities involving excavation of subsurface utility trenches or sub-grade structures,
Terracon will be notified to assess the presence of the vapors with a PID. If vapors do not readily
dissipate, soil samples may be obtained and analyzed for VOCs and SVOCs to evaluate the source
of the vapors and appropriate worker safety measures will be employed (such as fans) to allow
the workers to safely complete their work.
PART 7. INDOOR AIR – Please fill out the information below.
1)Are indoor air data available for the Brownfields Property?☒ Yes ☐ No ☐ Unknown
2)Attach a map showing the location(s) where indoor air contaminants exceed site screening levels.
3)If the structures where indoor air has been documented to exceed risk-based screening levels will
not be demolished as part of redevelopment activities, will workers encounter contaminated
indoor air during planned redevelopment activities?☐ Yes ☒ No ☐ Unknown
4)In the event that contaminated indoor air is encountered during redevelopment activities, list
activities for management of such contact:
VAPOR INTRUSION MITIGATION SYSTEM –Please fill out the information below.
Is a vapor intrusion mitigation system (VIMS) proposed for this Brownfields Property?
☒ Yes ☐ No ☐ Unknown
If yes,☐ VIMS Plan Attached or ☐ VIMS Plan to be submitted separately
Although not anticipated, in the event contaminated indoor air is encountered during redevelopment
activities, the work area will be evacuated and appropriate safety screening of the vapors will be
performed. If results indicate further action is warranted, appropriate engineering controls (such as
use of industrial fans) will be implemented.
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If submitted separately provide date:
The site is equipped with a Sub-Slab Depressurization (SSD) system installed by Hart & Hickman
in November 2017. The SSD work plan was submitted for NCDEQ approval on April 26, 2017 and
was approved by the NCDEQ on May 18, 2017.
During utility renovations within the on-site building, the SSD system will be monitored to ensure
the system functions properly after all renovations are complete. After renovations are
complete, two air samples will be collected within the building. Sampling methodology will be
included in a work plan that will be submitted to the NCDEQ for approval. In addition to air
sampling, the SSD system will be monitored by collecting vacuum measurements after
renovations are complete to ensure the system functions as designed.
VIMS Plan shall be signed and sealed by a NC Professional Engineer
If no, please provide a brief rationale as to why no vapor mitigation plan is warranted:
Click or tap here to enter text.
CONTINGENCY PLAN – encountering unknown tanks,drums,or other waste materials
In this section please provide actions that will be taken to identify or manage unknown
potential new sources of contamination. During redevelopment activities, it is not uncommon
that unknown tanks, drums, fuel lines, landfills, or other waste materials are encountered.
Notification to DEQ Brownfields Project Manager, UST Section, Fire Department, and/or other
officials, as necessary and appropriate, is required when new potential source(s) of
contamination are discovered. These Notification Requirements were outlined on Page 1 of this
EMP.
Should potentially impacted materials be identified that are inconsistent with known site
impacts, the DEQ Brownfields Project Manager will be notified and a sampling plan will be
prepared based on the EMP requirements and site-specific factors. Samples will generally be
collected to document the location of the potential impacts.
Check the following chemical analysis that are to be conducted on newly identified releases:
☒ Volatile organic compounds (VOCs) by EPA Method 8260
☒ Semi-volatile organic compounds (SVOCs) by EPA Method 8270
☒ Metals RCRA List (8)(arsenic, barium, cadmium, chromium, mercury,lead, selenium and
silver)
Click or tap here to enter text.
☐ Pesticides:Specify Analytical Method Number(s):
Click or tap here to enter text.
☐ PCBs:Specify Analytical Method Number(s):
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Click or tap here to enter text.
☐ Other Constituents & Analytical Method(s)(i.e. Hexavalent Chromium, Herbicides, etc.)
Please note, if field observations indicate the need for additional analyses, they should
be conducted, even if not listed here.
Click or tap here to enter text.
Please provide details on the proposed methods of managing the following commonly
encountered issues during redevelopment of Brownfields Properties.
There is a possibility that materials of unknown type (tanks, drums or impacted soils) could be
present on the site. The worker and contractor must be able to recognize when conditions change
at the site so conditions can be properly managed. In the event such conditions are encountered
during site redevelopment activities, the environmental actions noted below will be taken.
Underground Storage Tanks:
If USTs are discovered during construction activities and impacts uniquely associated with a UST
release are identified, the UST and petroleum-impacted soil will be addressed as required by either
the NCDEQ Brownfields Program or the NCDEQ UST Section. In the event of discovery of an unknown
UST, the UST will either (i) be removed and confirmation soil samples will be collected from the four
sidewalls and the excavation floor; or (ii) otherwise addressed in accordance with legal requirements
and in consultation with the Brownfields Program. Before proceeding with either of these choices,
we will communicate this choice with the Brownfields Program. Any samples collected will be
analyzed for VOCs using EPA Method 8260, SVOCs using EPA Method 8270 and RCRA metals by EPA
Method 6010/7471. A written report regarding the UST will be submitted to the NCBP within 30
days after UST removal unless otherwise approved by the NCBP. The report shall include a location
map, a description of the UST, a figure depicting any sampling locations, photographs, any analytical
reports and disposal destination.
Sub-Grade Feature/Pit:
If a sub-grade feature, structure, or pit is encountered during construction, it will be inspected for
the presence of waste fluids. If waste fluids are present, they will be removed, profiled and disposed
at a permitted facility by the contractor. If the structure does not require removal for construction
purposes, it will be filled with soil or suitable fill and construction will proceed. Where appropriate,
the bottom may be penetrated before backfilling to prevent rainwater accumulation after evaluation
of soils beneath the sub-grade structure has been completed. If waste is present, the waste will be
set aside in a secure area, sampled as required by the NCDEQ and disposed at an off-site location. If
a concrete structure must be removed and the observed waste characteristics indicate the concrete
may contain hazardous constituents, the concrete will be sampled and analyzed by methods
specified by the disposal facility. A written draft assessment plan will be prepared and submitted to
the NCBP prior to the initiation of assessment activities.
Buried Waste Material:
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If a drum is encountered during construction, the contents will be identified by the contractor, and
if appropriate, the contents of the drum profiled and disposed at a permitted facility. The protocols
noted above for soils will be followed for areas near any drums that are encountered.
If buried piping is encountered and must be removed to allow construction to proceed, the
contractor will inspect the piping for fluids, collect and sample fluids where appropriate, and look
for evidence of a release using field screening methods (visual and olfactory). If a release is
suspected, NCDEQ will be contacted to discuss the appropriate course of action.
If landfilled material is encountered at the site during construction activities, the nature and extent
of the buried material will be evaluated (e.g., by test pits) and NCDEQ will be notified to discuss the
appropriate course of action. Site debris will be segregated as needed, and disposed or recycled at
an approved facility, or reused on the site as beneficial fill. The NCBP will be notified after discovery
of buried materials and before initiation of additional excavation and disposal activities.
Re-Use of Impacted Soils On-Site:
During soil disturbance, workers and contractors will observe soils for evidence of potential impacts.
Evidence of potential impacts include odors, soil discoloration, or discovery of a tank, drums, a drain
field, or buried debris. Should any of the above be noted during site work, the contractor will contact
the project environmental professional to observe the suspect condition. If the project
environmental professional confirms that the material may be impacted, then the procedures below
will be implemented. In addition, the NCDEQ Brownfields project manager will be contacted within
48 hours of discovery.
If evidence of potential soil impacts is encountered during grading and/or the installation or removal
of utilities, excavation will proceed only as far as needed to allow grading and/or construction of the
utility to continue and/or only as far as needed to allow alternate corrective measures to be taken.
Suspect soil excavated during grading and/or utility installation or removal may be stockpiled and
covered in a secure area on the site to allow construction to continue. Suspect soil may also be
directly loaded into trucks. Suspect soil will be underlain by and covered with minimum 10-mil plastic
sheeting. At least one representative sample of the soil will be collected for analysis of VOCs by EPA
Method 8260B, SVOCs by EPA Method 8270D, and RCRA metals by EPA Method 6010/7471.
Soil sampled in accordance with the preceding paragraph will be managed in the manner described
below based on laboratory analyses:
1.If detectable levels of compounds are found that do not exceed DEQ IHSB Non-Residential
PSRGs (or, for metals, levels that are consistent with published or site-specific naturally
occurring concentrations) and the TCLP concentrations (if applicable) are less than
hazardous waste criteria, then the soil may be used as fill on the site without conditions.
2.If detectable levels of compounds are found that exceed NCDEQ IHSB Non-Residential PSRGs
(or, for metals, levels that are consistent with published or site-specific naturally occurring
concentrations) and the TCLP concentrations (if applicable) are less than hazardous waste
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criteria, then the soil, with NCDEQ’s written approval, may be used as fill on the site below
an impervious surface or two feet of clean fill.
3.Soil may be transported to a permitted facility such as a landfill provided that the soil is
accepted at the disposal facility that has been approved by Brownfields.
4.If excavation of impacted soil occurs, confirmation sampling will be conducted for purposes
of recording areas of impacts remaining at the site. It is anticipated that confirmation
samples will be collected at regular intervals along the base and sidewalls of a given
excavation. The confirmation samples will be analyzed for VOCs, SVOCs, and RCRA metals.
If unknown, impacted soil is identified on-site, management on-site can be considered after the
project team provides the necessary information, outlined in Part 1.A. Item 11, for Brownfields
Project Manager approval prior to final placement on-site.
If other potential contingency plans are pertinent, please provide other details or scenarios as
needed below:
Click or tap here to enter text.
POST-REDEVELOPMENT REPORTING
☒ Check this box to acknowledge that a Redevelopment Summary Report will be required for the
project. If the project duration is longer than one year, an annual update is required and will be
due by January 31 of each year, or 30 days after each one-year anniversary of the effective date of
this EMP (as agreed upon with the Project Manager). These reports will be required for as long as
physical redevelopment of the Brownfields Property continues, except that the final
Redevelopment Summary Report will be submitted within 90 days after completion of
redevelopment. Based on the estimated construction schedule, the first Redevelopment Summary
Report is anticipated to be submitted on 1/31/2020
The Redevelopment Summary Report shall include environment-related activities since the last
report, with a summary and drawings, that describes:
1.actions taken on the Brownfields Property;
2.soil grading and cut and fill actions;
3.methodology(ies) employed for field screening, sampling and laboratory analysis of
environmental media;
4.stockpiling, containerizing, decontaminating, treating, handling, laboratory analysis and
ultimate disposition of any soil, groundwater or other materials suspected or confirmed
to be contaminated with regulated substances; and
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5.removal of any contaminated soil, water or other contaminated materials (for example,
concrete, demolition debris) from the Brownfields Property (copies of all legally required
manifests shall be included).
☒ Check box to acknowledge consent to provide a NC licensed P.G. or P.E. sealed, Redevelopment
Summary Report in compliance with the site’s Brownfields Agreement.
I APPROVAL SIGNATURES
Brownfields Project Number: 16041-12-060
Brownfields Project Name: Fleming Laboratories
Printed Name/Title/Company: Mr. Matthew Browder I Owner
Consultant: Terracon Consultants, Inc.
Printed Name/Title/Company: Mr. Christopher Corbitt, PG /
Senior Geologist
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I
Date Click or tap to enter a date.
Date Click or tap to enter a date.
Date Cl ick or tap to ente r a date
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Attachments
Figures
Figure 1 – Topographic Map
Figure 2 – Site Plan and Background Soil Sample Locations
Figure 3 – Preliminary Site Plan (Redevelopment)
Figures 4A, 4B and 4C – Soil Sample Location Maps
Figure 4A – Shallow Soil Arsenic Concentration Map
Figure 4B – Characteristically Hazardous Soil Excavation Map
Figure 4C – UST Closure Soil Sample Location Map
Figure 5 – Groundwater Sample Locations
Figure 6 – Sub-Slab Sample Location Map
Figures 7A and 7B – Indoor Air Sample Location Maps
Figure 7A – Indoor Air Sample Location Map – Pre-SSD System Install
Figure 7B – Indoor Air Sample Location Map – Post-SSD System Install
Tables
Tables 1A, 1B, 1C, 1D, 1E, and 1F – Soil Analytical Results
Table 1A – XRF Analysis Arsenic Concentrations
Table 1B – Site Specific Background Arsenic Concentrations
Table 1C – Laboratory Analysis of Total Arsenic and TCLP Arsenic in Soil
Table 1D – Comparison of XRF and Laboratory Analysis for Arsenic
Table 1E - Post-Excavation Soil Sample Results
Table 1F – UST Closure Soil Analytical Results
Table 2 – Groundwater Analytical Results
Table 3 – Sub-Slab Analytical Results
Tables 4A and 4B – Indoor Air Analytical Results
Table 4A – Summary of Indoor Air Analytical Data – Pre-SSD System Install
Table 4B – Indoor Air Sample Results – Post SSD System Install

TOPOGRAPHIC MAP
Fleming Laboratories
2205, 2209 and 2215 Thrift Road
Charlotte, NC
TOPOGRAPHIC MAP IMAGE COURTESY OF THE U.S. GEOLOGICAL SURVEY
QUADRANGLES INCLUDE: MOUNTAIN ISLAND LAKE, NC (1/1/1997), DERITA, NC (1/1/1993), CHARLOTTE WEST, NC (1/1/1993) and CHARLOTTE EAST, NC (1/1/1988).
2701 Westport Rd
Charlotte, NC 28208-3608
71187236
Project Manager:
Drawn by:
Checked by:
Approved by:
AEK
CLC
CLC
1”=2,000’
71187236.1
Dec. 2018
Project No.
Scale:
File Name:
Date: 1
FIGURE SAC
APPROXIMATE
SITE BOUNDARY
IA Locations
SITE PLAN AND BACKGROUND SOIL SAMPLE LOCATIONS
Fleming Laboratories
2205, 2209 and 2215 Thrift Road
Charlotte, Mecklenburg County, North Carolina
2701 Westport Road
Charlotte, NC
71187236
HEH
CLC
CLC
N.T.S.
Dec. 2018
Scale:
2
FigureProject Manager:
Drawn by:
Checked by:
Approved by:
Project No.
File Name:
Date:
SAC
Warehouse
LEGEND
Approximate site boundary
Gravel Parking
HHBG-1
HHBG-2
Approximate location of a
background soil sample
THRIFT ROAD
(60' PUBLIC R/W - CDOT MAINTAINED)LOADINGSCALE: 1" = 20'
2923 SouthTryon Sm:~[·Suitl:100
Charlotte,NOM Carolina.28203
7?+S86-OOO7(p)704.5S6-0373(f)
License #C·1269/#C 2'-G•:l CQlogy
REVISION NO,0
FIGURE NO.3
~
SITE PROPERTYBOUNDARY
RAILROADTRACKS
BASEMAP FROM ZOUTEWEllE
BOUNDARYSURVEY DATED 5/19/97.
2.~IGHEST ARSENIC CONCENTRATION
ESS THAN 1ftDEPTH SHOWN.
3.~~~~~~~~ET~TED USING FIELD XRF
SHALLOW SOIL ARSENIC
CONCENTRATION MAP
1.
IIIIII1
HH-SB-1.SOIL BORING
(64:1.5-2')ARSENICCONCENTRATION
(mg!kg)AND SAMPLE DEPTH(FT)
_-<5-__ISOCONCENTRATION CONTOUR
r-__...,(NO ARSENIC DETECTED BY XRF)
~__-J GONTAMINTED AREA(ARSENIC)
FLEMING LABS
CHARLonE,NORTH CAROLINA
s
0
APPROXIMATE
30 60
SCAlE IN FEET
h ..."art ~hickman
SMAHTER ENVIRONMENTAL soumoNS
JOB NO.FMG-001
DATE:6-22-12
\
,,
\
\
,
H~1h5O
•HH-S~:'8'""~'25')
(41 :0-0.251 '+ol ~
•HH-$8-48 '+ol ......
(42'0-0.2")\\
,1-
SUSPECTED HEATING
OIL UST
·HH.S8-"\:(16:0-0.5')•HH-SB-47~(27:0-0.5')'l:
•HH-SB-46(404 :'0-0.5')
•HH-SB-45
(283 :0-0.25')
•Ht-hSB-37 .,'"
(59:0-0.5')'
HH-SB-29 /'(955:~S)
ASPHALT
PARKING
.HH-SB-27(32:0-0.5')
•Ht-hSB-51
(<5:0-<I2S)
.HH-SB-13(267 :0-0.5')
1-STORYWOOD FRAMED
INDUSTRIAL BUILDING~D"
,,
,/
HH-s8-26 /'
(552:0-0./
/',
.HH-SB-5 /./(1,638 :0-0.5')
.HH-§~)134 :0-0.5')
•HH-SB-34
«5:0-0.5')
HH-sB-<;
•(618:0-0.5')
OILER
ROOM
"CLEAN"
SHALLOW....--"'/'
I 'I '•HH-SB-36 '1·STORY METAL
\(20:0-0.5')""OUSTRIAL BUILDING"E"
\'\'","\•HH-SS-35 ,5_".,..",HH-S6-33 •,«5:0-0.51 -(5:0-0.5')
,FORMER
\ASTs
FLEMING LABS BUILDING-N
AND OFFICES
•HH-8B-41«5:0-0.5;)
1·$TORY CONCRETE ~
BLOCK BUILDING ~B~\1;11;1-86-30 •,(1,\00'0-0.,,)
,\~",,,,vi-
HH-S 22 ...."'$OOQ
(6:0-0.5i •.....,HH-S6-19'~(<4.0-0.5')•'ttH-SB-9y ·H 8-12......(2.693:i~2').975:0-0.5')
FORMER ....HH-s8-'5-'.HH-sB-l1
ARSANILIC .HI<-S8-2O',1<5,'.5-Z).(59,"".51HH-s8-8
ACID AST 'HH-SB-17 .(1.830 :0-0 5')
\...1<5'"".5')1 ./'
\H
"0;;'IHH-S.H...H-SB-7.
•
~O 8-1 1035'''''51
\.(7:0-0',51 (48,9:0-0.5')'\'\.~.
HH-$B-21.(1,681 :0-0:5')~HH-SB-f~.HH-sB-
•«5:0-0.5'),\(2733'1~HH-S ~,.0-0.51
(166 ~yli \HH-SB-2 •~.....2-STORY~~""'1
\"MANUFACT ING
BUILDING ~\b·\'
\
G,'P.;HH-58-44 t-.,.HH-SB-3 •~'\(<6:0-0.5')\.(138:0-0.51
"CLEAN",\.H';,\SB-39\SHALLOW (<5 .~.s)
FORMER )c,('\'
USTs ~\
\
FORMER
ASTs
~~~~~,~"'"-'~.-
ACIDAST @21~
\(3.066:~5')•HH·SB-42.\'«6:0-0.5')
10~"CLEAN"
/.HH-S8-43 SHALLOW«6:0-0.5')
IA Locations
GROUNDWATER SAMPLE LOCATIONS
Fleming Laboratories
2205, 2209 and 2215 Thrift Road
Charlotte, Mecklenburg County, North Carolina
2701 Westport Road
Charlotte, NC
71187236
HEH
CLC
CLC
N.T.S.
Dec. 2018
Scale:
5
FigureProject Manager:
Drawn by:
Checked by:
Approved by:
Project No.
File Name:
Date:
SAC
TMW-1
TMW-2
LEGEND
Approximate site boundary
Approximate location of a
temporary monitoring well
or former monitoring well
Warehouse
MW-5
MW-1
THRI
FT
ROAD
JAY S
T
R
E
E
T
GRAVEL
PARKING
SS-4
SS-3
SS-2
SS-1
FLEMING
(OPERATING)
JOB NO. 71187236
DATE: 10-10-16 REVISION NO. 0
FIGURE NO. 6
LEGEND
SUBJECT PROPERTY BOUNDARY
SUB-SLAB VAPOR SAMPLE
LOCATION
SUB-SLAB VAPOR SAMPLE LOCATION MAP
FLEMING LABORATORIES
2215 THRIFT ROAD
CHARLOTTE, NORTH CAROLINA
2923 South Tryon Street-Suite 100
Charlotte, North Carolina 28203
704-586-0007(p) 704-586-0373(f)
License # C-1269 / #C-245 Geology
THRI
FT
ROAD
JAY S
T
R
E
E
T
GRAVEL
PARKING
IAS-5
IAS-4
IAS-3
IAS-2
IAS-1
BS-1
JOB NO. FMG-004
REVISION NO. 0DATE: 9-26-16
FIGURE NO. 7A
LEGEND
SUBJECT PROPERTY BOUNDARY
INDOOR AIR SAMPLE LOCATION
AMBIENT AIR SAMPLE LOCATION
FLEMING LABORATORIES
2215 THRIFT ROAD
CHARLOTTE, NORTH CAROLINA
INDOOR AIR SAMPLE LOCATION MAP
2923 South Tryon Street-Suite 100
Charlotte, North Carolina 28203
704-586-0007(p) 704-586-0373(f)
License # C-1269 / #C-245 Geology
FLEMING
(OPERATING)
PACKING ROOM
WAREHOUSE
OFFICE AREA
IA Locations
INDOOR AIR SAMPLE LOCATION MAP –
POST SSD INSTALLATION
Fleming Laboratories
2205, 2209 and 2215 Thrift Road
Charlotte, Mecklenburg County, North Carolina
2701 Westport Road
Charlotte, NC
71187236
HEH
CLC
CLC
N.T.S.
Dec. 2018
Scale:
7B
FigureProject Manager:
Drawn by:
Checked by:
Approved by:
Project No.
File Name:
Date:
SAC
IA-01
IA-02
LEGEND
Approximate site boundary
Approximate location of an
indoor air sample
Approximate extent of
former office area
Table 1 (Page 1 of 2)
XRF Analysis Arsenic Concentrations
Fleming Laboratories
Charlotte,North Carolina
H&H Project No.FMG-001
Sample ID Date Collected DeDth As Error
Iftl Ilppm Dr maiko:+1-)
0-0.5 <4 4
1.5-2 <4 4
HH-SB-19 11/1712011 4.5-5 <4 4
9.5-10 <4 4
14.5-15 <4 4
0-0.5 4,175 34
1.5-2 1,389 19
HH-SB-20 11/1712011 4.5-5 18 4
9.5-10 95 5
11.5-12 93 6
14.5-15 147 7
0-0.5 1,681 21
1.5-2 1,054 20
4.5-5 310 11
9.5-10 20,700 90
HH-SB-21 11117/2011 DUP 9.5-10 22,100 100
11.5-12 2,845 31
14.5-15 1,076 16
19.5-20 1,201 17
20.5-21 1,188 18
23.E.-24 397 11
0-0.5 6 3
1.5-2 <5 5
HH-SB-22 11/1712011 4.5-5 <4 4
9.5..10 <4 4
11.5-12 <4 4
0-0.5 3,066 40
HH-SB-23 11/1712011 1.5-2 408 16
4.5-5 17 6
9.5-10 8 3
0-0.5 3,252 31
HH-SB-24 11/1712011 1.5-2 2,804 29
4.5-5 1,132 16
0-0.5 <4 4
HH-SB-25 11/1712011 1.5-2 <5 5
4.5-5 <4 4
0-0.5 552 20
HH-SB-26 11/1712011 1.5-2 769 24
4.5-5 177 7
9.5..10 174 7
0-0.5 32 4
HH-SB-27 11117/2011 1.5-2 64 5
4.5-5 12 3
SamplelD Date Collected DeDth As Error
Iftl (oom or ma/ka:(+1.)
0-0.5 1,137 18
1.5-2 2,693 26
4.5-5 2,660 36
9.5-10 1,368 27
HH-SB-9 11115/2011 11.5-12 1,505 28
14.5-15 1,372 18
17.5-18 578 11
19.5-20 126 7
22.5-23 <3 3
0-0.5 40 4
1.5-2 32 4
HH-SB-l0 11116/2011 4.5-5 665 13
DUP 4.5-5 613 12
7.5-8 4 3
9.5-10 <4 4
0-0.5 59 5
1.5-2 13 3
HH-SB-ll 11/16/2011 4.5-5 266 9
7.5-8 <4 4
9.5-10 <4 4
0-0.5 975 17
HH-SB-12 11/17/2011 1.5-2 499 12
4.5-5 <4 4
9.5-10 <4 4
0-0.5 267 9
HH-SB-13 11/16/2011 1.5-2 105 6
4.5-5 <4 4
9.5-10 <4 4
0-0.5 103 8
1.5-2 25 4
HH-SB-14 11/15/2011 DUP 1.5-2 21 4
4.5-5 30 4
9.5-10 4 3
0-0.5 101 6
HH-SB-15 11/15/2011 1.5-2 16 3
4.5-5 <4 4
0-0.5 2,733 28
1-1.5 3,437 30
HH-SB-16 11/17/2011 1.5-2 813 14
2.5-3 25 4
3.5-4 338 10
0-0.5 <5 5
1.5-2 <5 5
HH-SB-17 1111712011 4.5-5 <5 5
9.5-10 <4 4
14.5-15 <5 5
0-0.5 <5 5
HH-SB-18 1111612011 1.5-2 <4 4
4.5-5 <4 4
9.5-10 <4 4Notes.
1)Soil analysis completed by XRF analysis using a NITON XL300
2)Error value represents the 2 sigma value as determined by the XRF device
3)DUP-Duplicate samples
4)Site specific background concentraions ranged from <0.62 mg/kg to 2.9 mg/kg
5)The DENR Inactive Hazardous Sites Branch (IHSB)Residential and Industrial Soil Remiedial Goals (SRGs)for arsenic are 0.39 mg/kg and 1.6 mg/kg.(February 2012)
6)The DENR IHSB Protection of Groundwater SRG for arsenic is 5.8 mg/kg (February 2012)
Sample ID Date Collected Depth As Error
Iftl IDDm Dr ma/kal 1+1-1
0-0.5 489 11
1.5-2 470 11
HH-SB-l 11116/2011 4.5-5 978 16
9.5-10 891 15
11.5-12 27 3
0-0.5 9 3
HH-SB-2 1111612011 1.5-2 <4 4
4.5-5 <4 4
9.5-10 <4 4
0-0.5 138 6
1.5-2 221 8
HH-SB-3 11116/2011 4.5-5 <4 4
9.5-10 30 4
11.5-12 <4 4
0-0.5 134 8
1.5-2 1,086 19
HH-SB-4 11/16/2011 4.5-5 278 9
11.5-12 9 3
14.5-15 19 3
0-0.5 1,638 24
1.5-2 235 9
HH-SB-5 11116/2011 4.5-5 1,449 20
9.5-10 <4 4
11.5-12 <4 4
14.5-15 <4 4
0-0.5 618 13
1.5-2 171 7
4.5-5 151 7
HH-SB-6 1111612011 9.5-10 <3 3
11.5-12 <16.4 16
14.5-15 <3 3
19.5-20 <4 4
0-0.5 1,035 20
1.5-2 146 8
DUP 1.5-2 159 7
4.5-5 97 6
HH-SB-7 11116/2011 9.5-10 <3 3
11.5-12 43 4
14.5-15 <3 3
19.5-20 <3 3
DUP 19.5-20 <3 3
0-0.5 1,830 25
1.5-2 1,959 24
4.5-5 2,722 29
HH-SB-8 1111512011 9.5-10 5 3
7.5-8 <4 4
11.5-12 80 5
14.5-15 <4 4
19.5-20 <4 4
S:\Al\A-MasteJ Pro;..ctsIFJemirY,j Labs (FMGJIFMG-OOl ArsericlXRF data\DataTables
1110/2012
Table 1 (Page 1 of 2)
Hart &Hickman,PC
Table 1 (Page 2 of 2)
XRF Analysis Arsenic Concentrations
Fleming Laboratories
Charlotte,North Carolina
H&H Project No.FMG-001
Sample 10 Date Collected Deeth As Error
(ft Ilppm or m Ikal 1+/.\
0-0.5 16 5
HH-SB-28 3113/2012 1.5-2 9 5
4.5-5 <5 5
9.5-10 <5 5
0-0.5 955 20
1.5-2 16 4
HH-SB-29 3/13/2012 OUP 1.5-2 10 3
4.5-5 17 3
9.5-10 <4 4
0-0.5 1,100 19
HH-SB-30 3/1312012 1.5-2 744 15
4.5-5 <4 4
9.5-10 5 3
0-D.5 8 4
HH-SB-31 3/1312012 1.5-2 <5 5
4.5-5 <2 2
9.5-10 <5 5
0-0.5 <6 6
HH-SB-32 3/1312012 1.5-2 9 4
4.5-5 <5 5
9.5-10 <5 5
0-D.5 5 4
HH-SB-33 3/13/2012 1.5-2 <6 6
4.5-5 <5 5
0-0.5 <5 5
HH-SB-34 3/13/2012 1.5-2 <4 4
4.5-5 <5 5
0-0.5 <5 5
HH-SB-35 3/13/2012 1.5-2 <5 5
4.5-5 <5 5
0-0.5 20 4
HH-SB-36 3/1312012 1.5-2 7 3
4.5-5 7 3
0-0.5 59 5
1.5-2 <7 7
HH-SB-37 3/13/2012 4.5-5 12 3
9.5-10 <4 4
OUP 9.5-10 <4 4
0-0.5 166 9
OUP 0-0.5 162 8
HH-SB-38 3/14/2012 1.5-2 192 7
4.5-5 48 5
9.5-10 <5 5
11.5-12 18 6
0-0.5 <5 5
HH-SB-39 3/14/2012 1.5-2 5 2
4.5-5 39 5
8.5-9 <5 5
Sample10 Date Collected Deeth As Error
fftl foom or rna/kg)(+1-)
0-0.5 7 4
1.5-2 9 6
4.5-5 46 5
HH-SB-40 3114/2012 OUP 4.5-5 57 5
9.5-10 7 4
11.5-12 6 4
14.5-15 <6 6
0-0.5 <5 5
1.5-2 <7 7
HH-SB-41 3114/2012 4.5-5 <4 4
9.5-10 <4 4
14.5-15 <5 5
0-0.5 <6 6
1.5-2 <6 6
4.5-5 <5 5
HH-SB-42 3/14/2012 OUP 4.5-5 <5 5
9.5-10 <5 5
11.5-12 <5 5
14.5-15 4 3
0-0.5 <6 6
1.5-2 <6 6
HH-SB-43 3/14/2012 4.5-5 <6 6
9.5-10 <4 4
14.5-15 <3 3
0-0.5 <6 6
1.5-2 <6 6
HH-SB-44 3/1412012 4.5-5 9 5
9.5-10 32 6
11.5-12 16 4
14.5-15 6 4
0-0.25 283 19
HH-SB-45 3/1512012 0.25-0.5 18 4
1.5-2 <5 5
4.5-5 7 4
0-0.5 404 15
HH-SB-46 3/15/2012 0.5-1.0 229 12
1-1.5 21 6
1.5-2 <6 6
HH-SB-47 3/15/2012 0-D.5 27 6
HH-SB-48 3/15/2012 0-0.25 42 6
HH-SB-49 3/15/2012 0-0.25 41 17
HH-SB-50 3/15/2012 0-0.25 18 6
0-0.25 <5 5
HH-SB-51 3115/2012 0.25-0.5 <5 5
1.5-2 7 4
Notes.
1)Soil analysis completed by XRF analysis using a NITON XL300
2)Error value represents the 2 sigma value as determined by the XRF device
3)DUP-Duplicate samples
4)Site specific background concentraions ranged from <0.62 mg/kg to 2.9 mg/kg
5)The DENR Inactive Hazardous Sites Branch (IHSB)Residential and Industrial Soil Remiedial Goals (SRGs)for arsenic are 0.39 mg/kg and 1.6 mg/kg.(February 2012)
6)The DENR IHSB Protection of Groundwater SRG for arsenic is 5.8 mg/kg (February 2012)
5:lAAA-Maste.ProjeclslFlemirYilLabs(FMG)IFMG_OO1 AmencIXRFd~talData Tables
7I10.r2012
Table 1 (Page 2 of2)
Hart &Hickman,PC
Table 2 (Page 1 of 1)
Site Specific Background Arsenic Concentrations
Fleming Laboratories
Charlotte,North Carolina
H&H Job No.FMG-001
Depth Date Arsenic
Sample 10 ft Collected ppm or mg/kg
0-0.5 2.8
15-2 <0.64
HH-BG-1 45-5 11/15/2011 <0.63
7.5-8 <0.62
9.5-10 <0.65
0-0.5 2.9
1.5-2 2.2
HH-BG-2 4.5-5 11/15/2011 <0.64
7.5-8 <0.63
9.5-10 <0.62
Notes:
1)Arsenic values based on laboratory data from NC Certified Prism Laboratories
2)Arsenic by EPA Method 6010C
S:\A.AA-Master Projects\Fleming labs (FMG)\FMG-001 Arsenic\XRF data\Oata Tables
711012012
Table 2 (Page 1 of 1)
Hart &Hickman,PC
Table 3 (Page 1 of 1)
Laboratory Analysis of Total Arsenic and TCLP Arsenic in Soil
Fleming Laboratories
Charlotte,North Carolina
H&H Job No.FMG-001
SamDle 10 Depth Date Total As TCLPAs
HH-SB-5A 0-0.5 03/13/12 1,700 1.6
HH-SB-7A 0-05 03/13/12 2,300 <0.050
HH-SB-20A 0-0.5 03/14/12 2,400 37
HH-SB-24A 0-0.5 03/13/12 1,900 3.5
Notes:
1)Bold exceeds arsenic hazardous waste characteristic threshold of 5 mg/L
for Arsenic
2)Total levels are reported in mg/kg;TCLP levels are reported in mg/L
3)Lab analysis received from NC Certified Prism Laboratories
4)TCLP-Toxicity characteristic leaching procedure by EPA Method 6010C/7470A
5)Total-Total Metals by EPA Method 6010C/7471 B
S:WA-MasterProjects\Fleming Labs (FMG}\FMG-001 Arsenic\XRF data\Data TI'lbles
711012012
Table 3 (Page1 of 1)
Hart &Hickman,PC
Table 4 (Page 1 of 1)
Comparison of XRF and Laboratory Anaylsis for Arsenic
Fleming Laboratories
Charlotte,North Carolina
H&H Project No.FMG-001
Arsenic
Date XRF Analysis Lab Analysis
Sample 10 Depth (ft)Analvzed/Collected ppm or mg/kg
HH-SB-2 4.5-5 11116/2011 <4 <0.66
HH-SB-5 4.5-5 11/16/2011 1,449 23
HH-SB-6 0-0.5 11/16/2011 618 760
HH-SB-7 9.5-10 11116/2011 <3 <0.66
HH-SB-9 4.5-5 11115/2011 2,660 3,300
HH-SB-9 11.5-12 11/15/2011 1,505 2,200
HH-SB-14 4.5-5 11/15/2011 30 13
HH-SB-18 4.5-5 11/16/2011 <4 0.95
HH-SB-19 4.5-5 11/17/2011 <4 1.4
HH-SB-21 9.5-10 11/17/2011 22,100 23,000
HH-SB-22 11.5-12 11/17/2011 <4 3.4
HH-SB-30 0-0.5 3/13/2012 1,100 1,400
HH-SB-35 0-0.5 3/13/2012 <5 4.4
HH-SB-36 1.5-2 3/13/2012 7 8.9
HH-SB-38 0-0.5 3/14/2012 162 120
HH-SB-40 45-5 3/14/2012 46 57
HH-SB-41 9.5-10 3/14/2012 <4 2.0
HH-SB-43 9.5-10 3/14/2012 <4 1.8
HH-SB-44 9.5-10 3/14/2012 32 25
Notes:
1)Arsenic values from lab analysis received from NC Certified Prism Laboratories
2)Arsenic by EPA Method 6010C
S:\AAA-MssterProjects\Fleming Labs (FMG)\FMG-OOl Arsenic\XRF dala\Data Tables
7/10/2012
Table 4 (Page 1 of 1)
Hart &Hickman,PC
Table 1E
Post-Excavation Soil Sample Results
Fleming Laboratories
Charlotte, North Carolina
H&H Job No. FMG.003
S:\AAA-Master Projects\Fleming Labs (FMG)\FMG-003 Demo Phase\Post Development Report\Tables
Table 2 (Page 1 of 1)Hart & Hickman, PC
Screening Criteria
Sample ID SW-1 B-1 SW-1B SW-2 SW-3
Depth from Original Grade (ft)2 to 3 4 2 to 3 2 to 3 1
Sample Date 5/6/2014 5/6/2014 5/14/2014 5/6/2014 5/6/2014
TCLP Metals (6010)
Arsenic 42 35 <0.050 <0.050 0.10 5
Notes:
Units reported in mg/kg
1. Resource Recovery Conservation Act Characteristic Hazardous Waste Level
EPA Method follows parameter in parenthesis
RCRA Characteristic
Hazardous Level1
Table 2
Groundwater Sample Results
Fleming Laboratories
2205, 2209 and 2215 Thrift Road
Charlotte, Mecklenburg County, NC
Terracon Project No. 71187236
Sample ID:TMW-12 TMW-22 MW-11
Sample Date:04/22/16 04/22/16 01/30/03
Benzene 16 69 1 <0.048 <0.048 2.1
Carbon Tetrachloride <0.11 1.1 NA NA
Chlorobenzene 82 340 50 <0.062 <0.062 1
Chloroethane NS NS 3,000 <0.22 <0.22 2.7
Chloroform 8.1 36 70 <0.076 7.8 ND
2-Chlorotoluene NS NS 100 <0.066 <0.066 2.9 ND
1,1-Dichloroethane 76 330 6 <0.083 7.3 93
1,2-Dichloroethane 22 98 0.4 <0.066 <0.051 1.1
1,1 Dichloroethene 39 160 350 0.5 16 1.1
cis-1,2-Dichloroethene NS NS 70 19 54 1.3 ND
1,2-Dichloropropane 7.2 30 0.6 <0.11 3 6.3 ND
Ethylbenzene 35 150 600 <0.061 <0.061 1.6
Methylene Chloride 940 4,000 5 <0.083 <0.083 1.4 ND
Tetrachloroethene 12 48 0.7 7 71 ND ND
1,1,1-Trichloroethane 15,000 62,000 200 <0.061 <0.11 ND ND
Trichloroethene 1 4.4 3 4 27 ND ND
Vinyl Chloride 1.5 25 0.03 <0.097 <0.097 18 ND
O-Xylene 98 410 500 <0.044 <0.044 2.4 ND
Notes:
Concentrations are reported in micrograms per cubic meter (μg/L).
Only reported compounds are shown.
ND - Not Detected
NA - Not Analyzed
1 - Concentrations taken from Groundwater Sampling Report completed by S&ME, Inc., dated March 19, 2003.
2 - Concentrations provided by Hart & Hickman April 2016 sampling event.
DMW - North Carolina Department of Environmental Quality, Division of Waste Management
GWSL - DMW Groundwater Screening Level, updated Febraury 2018
Concentrations hgihlighted in blue exceed their 15A NCAC 2L Groundwater Quality Standards.
Concentrations highlighted in grey exceed their respective Residential SGSLs.
Concentrations highlighted in yellow exceed their respective Non-Residential SGSLs.
ND
Analyte Residential
GWSL
Non-
Residential
GWSL
MW-51
01/30/03
Northern Portion of
the Site
Southern extent of
On-site Building
NCAC 2L GWQS
Location:Southern Corner of
the Property
Southern Corner of
On-site Building
Volatile Organic Compounds (EPA Method TO-15)
ND
ND
ND
ND
ND
ND
1.3
Table 3
Sub-Slab Sample Results
Fleming Laboratories
2205, 2209 and 2215 Thrift Road
Charlotte, Mecklenburg County, NC
Terracon Project No. 71187236
Sample ID:SS-1 SS-3 SS-4
Sample Date:07/07/16 07/07/16 07/07/16
Type:Sub-Slab Sub-Slab Sub-Slab
Location:Warehouse Area Warehouse Area Warehouse Area
Carbon Tetrachloride 160 2,000 <1300 0.48J 160
Chloroform 41 530 16,000 <0.98 0.66J
1,1-Dichloroethane 580 7,700 22,000 <0.81 <0.81
1,1-Dichloroethylene 1,400 18,000 84,000 <0.79 <0.79
cis-1,2-Dichloroethylene NS NS 190,000 <0.79 <0.79
trans-1,2-dichloroethylene NS NS 1,300 <0.79 <0.79
1,2-Dichloropropane 28 350 13,000 <0.92 <0.92
Tetrachloroethylene (PCE)280 3,500 130,000 7,900 870
Trichloroethylene (TCE)14 180 380,000 3.2 <1.1
Notes:
Concentrations are reported in micrograms per cubic meter (μg/m3).
Only reported compounds are shown.
J - The reported value is an estimate between the method detection limit and the reporting limit.
Concentrations are reported from Contest Analytical Data Report, dated August 12, 2016. Samples collected by Hart & Hickman on July 7, 2016.
DMW - North Carolina Department of Environmental Quality, Division of Waste Management
SGSL - DMW Sub-slab and Exterior Soil Gas Screening Level, updated Febraury 2018
Concentrations highlighted in grey exceed their respective Residential SGSLs.
Concentrations highlighted in yellow exceed their respective Non-Residential SGSLs.
33
43
130,000
3,300
Residential
SGSL
Non-
Residential
SGSL
Volatile Organic Compounds (EPA Method TO-15)
<13
1,300
1,300
2,400
290
SS-2
07/07/16
Sub-Slab
Warehouse Area
Analyte
Table 4A
Summary of Indoor Air Analytical Data
Fleming Laboratories
Charlotte, North Carolina
H&H Job No. FMG-004
Sample ID IAS-1 IAS-2 IAS-3 IAS-4 IAS-5 BS-1
Sample Date 9/13/2016 9/13/2016 9/13/2016 9/13/2016 9/13/2016 9/13/2016
Units (ug/m3) (ug/m
3) (ug/m
3) (ug/m
3) (ug/m
3) (ug/m
3) (ug/m
3)
VOCs (TO-15)
Carbon Tetrachloride 0.41 0.42 0.44 0.44 0.46 0.41 2.04
Chloroform 0.82 2.3 0.66 0.56 0.57 0.12 J 0.53
1,1-Dichloroethane 0.21 0.16 0.24 0.16 0.16 <0.14 7.67
1,2-Dichloroethane 0.14 J 0.062 J 0.045 J <0.14 <0.14 <0.14 0.472
1,1-Dichloroethylene 2.4 1.6 2.2 1.5 1.6 <0.14 175
cis-1,2-Dichloroethylene 3.2 1.9 2.9 2.0 2.1 <0.14 NS
trans-1,2-Dichloroethylene <0.14 <0.14 <0.14 <0.14 <0.14 <0.14 NS
1,2-Dichloropropane 0.45 0.34 0.49 0.33 0.35 <0.16 1.23
Tetrachloroethylene 100 45 60 46 46 0.20 J 35.0
Trichloroethylene 13 6.7 9.2 6.8 6.8 <0.19 1.75
Vinyl Chloride <0.090 <0.090 <0.090 <0.090 <0.090 <0.090 2.79
Notes:
VOCs = volatile organic compounds
J = denotes that the concentration detected is above the method detection limit, but below the reporting limit; therefore,
the value is estimated.
NS = screening criteria not specified; µg/m3 = micro grams per cubic meter
DWM Non-
Residential
IASL1
1) NC Department of Environmental Quality (DEQ) Divison of Waste Management Non-Residential Indoor Air Screening
Levels at 1*10-6 (March 2016)
Bold values indicate exceedances of DWM Non-Residential IASL
\\hhfs01.harthickman.local\masterfiles\AAA-Master Projects\Fleming Labs (FMG)\FMG-004 Brownfields Agreement\VI Report\Vapor Data.xls
9/26/2016
Table 1 (Page 1 of 1)
Hart & Hickman, PC
Table 4B
Indoor Air Sample Results
Fleming Laboratories
2205, 2209 and 2215 Thrift Road
Charlotte, Mecklenburg County, NC
Terracon Project No. 71187236
Volatile Organic Compounds (EPA Method TO-15)IASL Residential
IASL Non-
Residential
Tetrachloroethylene (PCE)8.3 35
Trichloroethylene (TCE)0.42 1.8
Notes:
Concentrations are reported in micrograms per cubic meter (μg/m3).
Only reported compounds are shown.
J - The reported value is an estimate.
0.11J
1.31.3
0.35
Analyte
IA-01
07/19/18
Office Area
IA-02
07/19/18
Indoor Air
Warehouse Area
Indoor Air
Sample ID:
Sample Date:
Type:
Location: