19016_G&BOil_SignedEMP_20161110

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 project manager for the program.
Prospective Developers and/or their consultants must complete and submit this form and all
pertinent attachments to their project manager prior to any site earthmoving or other
development related activities. For the resultant EMP to be valid for use, it must be completed,
reviewed by the program, and signed by all signers at the bottom. Consult your project
manager if you have questions.
GENERAL INFORMATION
Date: September 8, 2016
Brownfields Assigned Project Name: G&B Oil
Brownfields Project Number: 19016-15-095
Brownfields Property Address: 190 and 208 Poplar Grove Road and 178 South Water Street; Boone,
Watauga County (Figure 1)
Brownfields Property Area (acres): approximately 2.7
Is Brownfields Property Subject to RCRA Permit? ❑ Yes N No
If yes enter Permit No.: Not Applicable
Is Brownfields Property Subject to a Solid Waste Permit? ❑ Yes N No
If yes, enter Permit No.: Not Applicable
COMMUNICATIONS
Prospective Developer (PD): Harrod/AP, LLC
Phone Numbers: Office: [phone] Mobile: [phone]
Email: [e-mail]
Primary PD Contact: Mr. Glenn Weaver
Phone Numbers: Office: [phone] Mobile: [phone]
Email: [e-mail]
Environmental Consultant: Mr. Stephen C. Brown at The El Group
Phone Numbers: Office: [phone] Mobile: [phone]
Email: [e-mail]
Brownfields Program Project Manager: Ms. Sharon Eckard
Office: [phone]
Email: [e-mail]
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Other DENR Program Contacts (if applicable, i.e., UST Section, Inactive Hazardous Site Branch,
Hazardous Waste, Solid Waste): Ms. Carin Kromm - UST Section, Office: [phone],
[e-mail]
NOTIFICATIONS TO THE BROWNFIELDS PROGRAM
Advance Notification Times to Brownfields Project Manager: Check each box to accept minimum
notice periods (in calendar days) for each type of on -site task:
On -site assessment or remedial activities: Within 10 days
Construction or grading start: Within 10 days CK
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, venting of explosive environments):
Within 48 hours
Installation of Mitigation systems: Within 10 days
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: Open Space, Greenway
2) Summary of Redevelopment Plans (attach conceptual or detailed plans as available): See
Appendix A
a) Do plans include demolition of structure(s)?: ® Yes ❑ No ❑ Unknown
b) Do plans include removal of building foundation slab(s) or pavement:
® Yes ❑ No ❑ Unknown
c) Provide brief summary of redevelopment plans, including demolition, removal of building
slabs/pavement and other structures: The site is comprised of three contiguous parcels that
are presently occupied by a vintage retail building, a wood -framed storage building and a
greenhouse (178 South Water Street) a commercial building (190 Poplar Grove Road), a
warehouse/shop building and an office building (208 Poplar Grove Road). The buildings are
currently vacant. Remaining portions of the site consist of open gravel -covered areas used for
parking and grassed areas. The buildings and floor slabs will be demolished and the site graded
for redevelopment. Planned construction of the new development is scheduled to begin in the
in third quarter of 2016. The development will be a multi -story, mixed retail/office and 145-unit
apartment complex that will include a single building consisting of several interconnecting, step-
down sections totaling approximately 206,154 square feet. The projected footprint of the
building including the footprint of the garage is approximately 58,584 sf. Of which 28,185 sf. is
exclusively the footprint of the garage. Residential units are planned above the southern
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portion of the parking deck. The northern portion of the deck will be open. Amenities include a
pool and green space with a walking trail along Boone Creek.
3) Which category of risk -based screening level is used or is anticipated to be specified in the
Brownfields Agreement?
® Residential ❑Non-residential or Industrial/Commercial
Note: If children frequent the property, residential screening levels shall be cited in the Brownfields
Agreement for comparison purposes.
4) Schedule for Redevelopment (attach construction schedule): Actual schedule has not yet been
finalized. We will provide the schedule as it becomes available.
a) Phase I start date and anticipated duration (specify activities during each phase): 10/1/2016
Based on current planning, the anticipated start of construction activities will be the third quarter of
2016 following approval of this EMP. A generalized redevelopment schedule includes the following:
Relocation of utilities and demolition of the existing site buildings is planned to begin in October
2016. General site grading is anticipated to begin between October 2016 and March 2017. All
grading activities will be conducted in accordance with trout stream buffer requirements. Building
construction will begin immediately following site grading activities. Projected construction
schedule to opening of complex is approximately 16 months. A copy of the construction schedule
will be forwarded to the NCBP once it is finalized.
b) If applicable, Phase 2 start date and anticipated duration (specify activities during each
phase): Not Applicable
c) Additional phases planned? If yes, specify activities if known: The Greenway development
may take place in multiple stages; however, Prospective Developer is not currently certain
when such development will take place.
Yes ❑ Not in the foreseeable future ❑
Decision pending❑X ❑
d) Provide the planned date of occupancy for new buildings: 8/1/2018
CONTAMINATED MEDIA
Contaminated Media (attach tabulated data summaries for each impacted media and figure(s) with
sample locations): Tabulated data and figures are provided in Appendix B.
Part 1. Soil:
Part 2. Groundwater:
Part 3. Surface Water:
Part 4. Sediment:
Part 5. Soil Vapor:
Part 6. Sub -Slab Soil Vapor:
Part 7. Indoor Air:
® Yes ❑ No ❑ Suspected
® Yes ❑ No ❑ Suspected
❑ Yes ® No ❑ Suspected
❑ Yes ® No ❑ Suspected
❑ Yes ® No ❑ Suspected
❑ Yes ® No ❑ Suspected
❑ Yes ® No ❑ Suspected
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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 specific compounds): Past uses of the site as a bulk
heating oil facility have impacted soils at the site with petroleum. Contaminants identified at the
site in soils from 2000 - 2015 include: aluminum, arsenic, benzene, cobalt, ethylbenzene, iron,
manganese, naphthalene, p-isopropyltoluene, 1,2,4-trimethylbenzene, and xylenes at
concentrations that exceeded residential standards. TCLP analysis of soil samples did not detect the
presence of VOC or SVOC concentrations. TPH-DRO and TPH-GRO have also been detected in soils
at the property. While past remedial activities may have removed some of these constituents
detected in the 2000 and 2012 assessments, residual levels of these detected constituents may be
encountered in subsurface soils during planned demolition of the former G&B Oil buildings, grading
activities and removal of subsurface structures (utilities). Soil sampling results and sample locations
are provided in Appendix B.
2) Depth of known or suspected contaminants (feet): Based on previous assessment activities at the
site, soil samples obtained for chemical analysis were collected at depths ranging from 1.5 to 10 feet
below ground surface (bgs). Historical groundwater levels at the site indicate that some soil samples
may have been collected within the "Smear Zone" or the interval where groundwater levels
fluctuate due to seasonal variations.
3) Area of soil disturbed by redevelopment (square feet): Approximately 22,500 square feet. Note
there are interstitial areas of clean soils; however, all soils below the former G&B bulk fuel facility
will be considered "impacted" and are included within the area of disturbance.
4) Depths of soil to be excavated (feet): Varies from 3 feet to 8 feet below existing ground surface
(bgs).
5) Estimated volume of soil (cubic yards) to be excavated (attach grading plan): Based on the
preliminary grading plan, we anticipate a cut of approximately 5,900 cubic yards (cy). This volume
includes an estimated 4,600 cy of impacted soils. The PD intends to manage the impacted soils at
designated areas of the site in the unsaturated zone below impervious surfaces.
6) Estimated volume of excavated soil (cubic yards) anticipated to be impacted by contaminants:
While there are interstitial areas of clean soils, all soils below the former G&B bulk fuel facility will
be considered "impacted" and the volume is estimated to be as much as 4,600 cy.
7) Estimated volume of contaminated soil expected to be disposed offsite, if applicable: Disposal of
impacted soils at off -site locations is not anticipated at this time; however, if impacted soils are
encountered that require disposal at an off -site location; these activities will be initiated in
accordance with disposal facility requirements and NCDEQ regulations.
IMPORTED FILL SOIL
1) Will fill soil be imported to the site? ❑X Yes ❑ No ❑ Unknown
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2) If yes, what is the estimated volume of fill soil to be imported? Initial grading projections
anticipate the need for importing approximately 5,400 cy of fill soils. The PD intends to import the
material from a nearby Maymead, Inc. quarry.
3) If yes, what is the depth of fill soil to be used at the property? Estimate from 1 to 6.5 feet.
If a range of depths, please list the range.
4) PRIOR TO ITS PLACEMENT AT THE BROWNFIELDS PROPERTY. Provide plan to analyze fill soil to
demonstrate that it meets acceptable standards and can be considered clean for use at the
Brownfields property (Check all that apply), or attach existing data: Not Applicable
® 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 (speciated), mercury, lead,
selenium and silver)
❑ Metals — Hazardous Substance List -14 (antimony, arsenic, beryllium, cadmium, chromium
(speciated according to IHSB protocol), copper, lead, manganese, mercury, nickel, selenium,
silver, thallium, and zinc)
❑ Metals — EPA Priority Pollutant List — 13 (arsenic, beryllium, cadmium, chromium (speciated
according to IHSB protocol), copper, mercury, nickel, lead, antimony, selenium, silver,
thallium, and zinc)
❑ Other Constituents and Analytical Method: Click here to enter text.
❑ Known borrow material (DESCRIBE SOURCE AND ATTACH SAMPLING PROFILE): Click here
to enter text.
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1) If soil in known or suspected areas of contamination 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 and volumes are acceptable, if only preliminary data
available). The PD intends to manage the impacted soils at designated areas of the site in the
unsaturated zone below impervious surfaces.
2) HAZARDOUS WASTE DETERMINATION — 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). Not Applicable
If yes, do the soils exceed the "Contained -Out" levels in Attachment 1 of the North Carolina
Contained -In Policy? ❑ Yes ❑ No Not Applicable
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
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SOIL MAY NOT BE RE -USED ON SITE AND MUST BE DISPOSED OF IN ACCORDANCE WITH DENR
HAZARDOUS WASTE SECTION RULES AND REGULATIONS.
3) ❑ Hazardous Waste Determination — Does the soil contain a CHARACTERISTIC WASTE?
❑ Yes ® No
If yes, mark reason(s) why below (and include pertinent analytical results). If no, explain rationale:
Historical analytical results from the site did not identify soils that were considered to be a hazardous
waste. Past soil sampling activities at the site did not detect constituents of concern that are deemed
hazardous by characteristic using the Rule of 20.
❑ Ignitability
❑ Corrosivity
❑ Reactivity
❑ Toxicity
❑ TCLP results
❑ 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)
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 DENR HAZARDOUS WASTE
SECTION RULES AND REGULATIONS.
4) Screening criteria by which soil disposition decisions will be made (e.g., left in place, capped in
place with low permeability barrier, removed to on -site location and capped, removed offsite):
® Preliminary Health -Based Residential SRGs dated April 2016
❑ Preliminary Health -Based Industrial/Commercial SRGs SERT DAl
❑ Site -specific risk -based cleanup level, or acceptable concentrations determined via
calculated cumulative risk. Enter details of methods used for determination/explanation:
DICK nere io enter tex�
5) Check the following action(s) to betaken during excavation and management of said soils:
❑ Manage fugitive dust from site:
❑ Yes ® No
If yes, describe method; If no, explain rationale: Monitoring of fugitive dust for constituents
of concern (VOCs and SVOCs) will not be conducted at the site. These types of constituents of concern
typically do not adhere to airborne particulate matter. Unlike metals, VOCs and SVOCs will generally
vaporize into the air. Soils that are dry and have the potential to migrate through air from the site will
be managed in accordance with typical construction practices that may include a light application of
water periodically to moisten soils and reduce airborne dust.
❑ Field Screening:
® Yes ❑No
If yes, describe method; If no, explain rationale: When chemical odors are detected during
grading/excavation activities at the site, the soils will be screened with a photo -ionization detector (PID)
to identify relative concentrations and evaluate the need for sampling and laboratory analysis.
❑ Soil Sample Collection:
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® Yes ❑ No
If yes, describe method (e.g., in -situ grab, composite, stockpile, etc.); If no, explain rationale:
If during grading, impacted soils are discovered, procedures for screening and sampling the soils
will be implemented as described in Part 9 "Contingency for encountering unknown tanks,
drums, or other waste materials".
❑ Stockpile impacted soil in accordance with NCDENR IHSB protocol in the current version of
the "Guidelines for Assessment and Cleanup", and providing erosion control, prohibiting
contact between surface water/precipitation and contaminated soil, and preventing
contaminated runoff. Explain any variances:
Click here to enter text.
® Analyze potentially impacted soil for the following 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 (speciated), mercury,
lead, selenium and silver)
❑ Metals —Hazardous Substance List -14 (antimony, arsenic, beryllium, cadmium,
chromium (speciated according to IHSB protocol), copper, lead, manganese, mercury,
nickel, selenium, silver, thallium, and zinc)
❑ Metals — EPA Priority Pollutant List —13 (arsenic, beryllium, cadmium, chromium
(speciated according to IHSB protocol), copper, mercury, nickel, lead, antimony,
selenium, silver, thallium, and zinc)
® Other Constituent(s) and Analytical Method(s): If a change in condition is identified
in the area of the former Southern States operation, soils will also be evaluated for pesticides and
herbicides.
® Proposed Measures to Obtain Pre -Approval for Reuse of Impacted Soil within the
Brownfields Property Boundary
® 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
® Use geotextile to mark depth of fill material (provide description of material)
® Manage soil under impervious cap ® or clean fill
Describe cap or fill: Impacted soils will be covered by geotextile fabric to delineate the
top of the impacted material, followed either by a minimum of 2 feet of clean soil or by
a cap consisting of impervious pavements (asphalt or concrete) or buildings containing a
vapor barrier system approved by the NCBP (provide location diagram).
® Confer with NC BF Project Manager if Brownfield Plat must be revised (or re-
recorded if actions are Post -Recordation).
❑ Other: Click here to enter text
® Final grade sampling of exposed soil (i.e., soil that will not be under buildings or permanent
hardscape): [if not checked provide rationale for not needing] Based on initial development
plans for the site, exposed soils (not under structures or hardscapes) will be mostly limited to
landscaped areas along the perimeter of the site where impacted soils are not anticipated. If
contaminated soils are encountered in areas of exposed soils, these soils will be managed in
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accordance with contingency procedures discussed in Part 9 of this EMP. If exposed soils cannot
be documented to be "clean," then final grade sampling will be proposed to Brownfields.
Provide diagram of soil sampling locations, number of samples, and denote Chemical
Analytical Program 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 (speciated), mercury,
lead, selenium and silver)
❑ Metals —Hazardous Substance List -14 (antimony, arsenic, beryllium, cadmium,
chromium (speciated according to IHSB protocol), copper, lead, manganese, mercury,
nickel, selenium, silver, thallium, and zinc)
❑ Metals — EPA Priority Pollutant List — 13 (arsenic, beryllium, cadmium, chromium
(speciated according to IHSB protocol), copper, mercury, nickel, lead, antimony,
selenium, silver, thallium, and zinc)
❑ Pesticides
❑ PCBs
❑ Other Constituents & Analytical Method: Click here to enter text.
OFF -SITE TRANSPORT & DISPOSITION OF EXCAVATED SOIL
NOTE: Unless soil will be transported offsite for disposal in a permitted facility under applicable
regulations, no contaminated or potentially contaminated soil may leave the site without approval
from the brownfields program. Failure to obtain approval may violate a brownfields agreement,
endangering liability protections and making said action subject to enforcement. Justifications
provided below must be approved by the Program in writing prior to completing transport activities.
❑x Transport and dispose of impacted soil offsite (documentation of final disposition must be sent to
Brownfields Project Manager)
® Landfill — analytical program determined by landfill: Off -site disposal of impacted soils is
not anticipated at this time; however, if grading specifications are not met, off -site disposal
options will be considered.
® Landfarm or other treatment facility: Off -site disposal of impacted soils is not anticipated at
this time; however, if grading specifications are not met, off -site disposal options will be
considered.
❑ Use as Beneficial Fill Offsite — provide justification: Cline horn tn ontor to-,
❑ Use as Beneficial Fill at another Suitable Brownfields Site — (Note: a determination that a
site is a "Suitable Brownfields site will require, at a minimum, that similar concentrations of the same
or similar contaminants already exist at both sites, use of impacted soil as beneficial soil will not
increase the potential for risk to human health and the environment at that site, and that notarized
documentation of the acceptance of such soil from the property owner of the receiving site is
provided to Brownfields. Provide justification: ,gyre io enter
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
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removed from such that impacted soil is not placed at a greater depth than the original depth from
which it was excavated.
During initial site grading activities, certain uncapped areas of the site and soils beneath areas capped by
existing concrete building pads are assumed to be impacted by COCs (based on known contaminants
and concentrations); thus, workers should use appropriate safety apparel. Soils will at times need to be
disturbed for the construction of utilities or other structures. With respect to subsurface utility
construction at the site, the general rule will be to remove and stockpile soils so that a "last out, first in"
process occurs. During excavation, soils in the upper 2 feet should be stockpiled and segregated as the
first materials removed. These soils/fill materials are the last returned to the excavation during
backfilling.
Soils will typically "bulk" or expand in volume when disturbed by excavation. The contractor will
compact these materials into place according to the compaction requirements of the construction
design. If no specifications for compacted fill exist, the contractor will tamp the materials in place using
the mechanical excavator or equivalent. Utilities or structures will replace a certain volume of soils in
these areas, resulting in excess soils as excavation spoils. The contractor will always replace the upper 2
feet with clean soil/fill material to grade elevation.
Excess spoils from excavations below the upper 2 feet of original grade will be moved to a designated
soil management area, under an approved engineered barrier (if necessary).
After the initial grading of the site, the worker and contractor should plan from onset of construction to
maintain a cap comprised of either clean fill or other barrier approved by the NCDEQ for areas that will
not be capped with a building, asphalt, or concrete surface. If soils/fill leave their original locations or
the site, the on -site conditions which allow control of exposures and risk management may no longer
apply. If excess contaminant impacted soils/fill are produced from excavation as spoils which cannot be
restored to original depths through the process of "first out, last in", they must be handled with special
care. The worker or contractor will work with the Brownfields Project Manager to ensure that, if the
soils are contaminated, they are either properly re -used on -site or disposed of off -site.
❑ 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? Result: Yes ❑ No ❑
If no, include rationale here. To be determined based on future development plans.
If yes, provide specifications on barrier materials
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.
PART 2. GROUNDWATER — Please fill out the information below and attach figure showing
distribution of groundwater contaminants at site
What is the depth to groundwater at the Brownfields Property? Depth to groundwater on the site
varies from approximately 2.5 feet bgs (near Boone Creek) to approximately 4.5 feet bgs (south portion
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of G&B Oil tract near Poplar Grove Road. Groundwater was also measured at approximately 0.5 feet bgs
in the southwestern corner of the site in the former tank farm area where impacted soils were
reportedly removed.
Is groundwater known to be contaminated by ® onsite ❑ offsite ❑ both ❑ or unknown
sources? Describe source(s): Groundwater has been impacted by petroleum constituents originating
from the former G&B Oil bulk fuel oil operations at the site. Based on the findings of El's groundwater
assessment activities in 2015, petroleum constituents were detected in groundwater at the site at
concentrations above their respective North Carolina 2L water quality standards, including: benzene,
naphthalene, 1-methylnaphthalene and 2-methyl naphthalene. Previous assessments also detected
regulatory exceedances of the following additional constituents in groundwater: acenaphthene, n-
butylbenzene; sec -butyl benzene; tert-butylbenzene; 1,2-dichloroethane; 1,2-dichloropropane;
ethylbenzene; fluorene; isopropyl benzene; methyl tertiary butyl ether; phenanthrene; n-propylbenzene;
pyrene; 1,1,2,2-tetrachloroethane; toluene; 1,1,2-trichloroethane; 1,2,4-trimethylbenzene; 1,3,5-
tri methyl benzene and xylenes. Groundwater analytical data and sampling locations are provided in
Appendix B.
What is the direction of groundwater flow at the Brownfields Property? Generally to the northeast
based on topography.
Will groundwater likely be encountered during planned redevelopment activities? ® Yes ❑ No
If yes, describe these activities: Based on previously measured levels, planned redevelopment activities
will likely encounter groundwater in some areas of the site.
In the event that contaminated groundwater is encountered during redevelopment activities (even if
no is checked above), list activities for contingent management of groundwater (e.g., dewatering of
groundwater from excavations or foundations, containerizing, offsite disposal, discharge to sanitary
sewer, or sampling procedures): Excavations in areas where groundwater is encountered should be
allowed to re -infiltrate for approximately 24 hours (if it does not affect the construction schedule) or
remove the groundwater so that construction activities may proceed. The retrieved water will be
containerized so that the water can be sampled for disposal characterization before it is allowed to leave
the site. Based on the types of contaminants documented on the site, water samples will be analyzed
for VOCs and SVOCs, as well as any other analysis required for disposal. If containerized water is
determined to be above regulatory standards, the Brownfields Project Manager will be contacted and
the water will be disposed in accordance with regulatory requirements.
PART 3. SURFACE WATER — Please fill out the information below.
Attach a map showing the location of surface water at the Brownfields Property. Boone Creek
traverses the easternmost portion of the site. In addition, redevelopment of the property will include a
stormwater management plan (designed by the civil engineer for the project) to control the
accumulation of stormwater on the construction site. Erosion control methods will be implemented in
accordance with an erosion control plan to prevent stormwater from leaving the site.
Is surface water at the property known to be contaminated: ❑ Yes ® No
Will workers or the public be in contact with surface water during planned redevelopment activities?
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® Yes ❑ No Potentially, stormwater can accumulate in excavations and utility trenches during
construction activities following precipitation events. In the event stormwater management is required,
the applicable excavation activities will cease pending removal and characterization of the water.
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): 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. Stormwater or water
from an unidentified source that collects in excavation areas will be removed so that construction
activities may proceed. The retrieved water will be containerized or diverted to an on -site stormwater
management basin where the water will be sampled for disposal characterization before it is allowed to
leave the site. Based on the types of contaminants documented on the site, water samples will be
analyzed for VOCs and SVOCs, as well as any other analysis required for disposal. If containerized water
is determined to be above regulatory standards, the Brownfields Project Manager will be contacted and
the water will be disposed in accordance with regulatory requirements.
PART 4. SEDIMENT — Please fill out the information below.
Is sediment at the property known to be contaminated: ❑ Yes ® No
Will workers or the public be in contact with sediment during planned redevelopment activities?
❑ Yes ® No
If yes, attach a map showing location of known contaminated sediment at the property.
In the event that contaminated sediment is encountered during redevelopment activities, list
activities for management of such events (stream bed disturbance): Not Applicable. While portions of
Boone Creek traverse the property, no development activities are planned in or near the stream bed.
PART 5. SOIL VAPOR — Please fill out the information below.
Do concentrations of volatile organic compounds at the Brownfields property exceed the following
vapor intrusion screening levels in the following media:
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
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Attach a map (Appendix C) showing the location of soil vapor contaminants exceeding site screening
levels.
If applicable, at what depth(s) is soil vapor known to be contaminated?
Will workers encounter contaminated soil vapor during planned redevelopment activities?
❑ Yes ❑ No ® Unknown
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:
Petroleum -related volatile organic compounds (VOCs) have been identified in localized areas within soils
and the groundwater beneath the site. Soil Vapor Intrusion Barriers (SVIBs) will be installed during
construction to prevent VOCs or gases from collecting beneath and in the on -site buildings. The SVIB
will serve as an engineered barrier to mitigate the potential inhalation exposure pathway. The
anticipated SVIB design and construction specifications have not been prepared at this time. El will
review and provide comments pertaining to the design and specifications prior to installation of the
vapor barrier. El will also monitor the installation and testing of the SVIB to provide assurance that the
system has been installed in accordance with the design and specifications.
PART 6. SUB -SLAB SOIL VAPOR -please fill out the information below if existing buildings or
foundations will be retained in the redevelopment.
Are sub -slab soil vapor data available for the Brownfields Property? ® Yes ❑ No ❑ Unknown
If data indicate that sub -slab soil vapor concentrations exceed screening levels, attach a map
(Appendix C) showing the location of these exceedances.
At what depth(s) is sub -slab soil vapor known to be contaminated? ❑ 0-6 inches ❑ Other, If other
describe: Sub -slab vapor samples will be collected prior to demolishing the existing buildings.
Will workers encounter contaminated sub -slab soil vapor during planned redevelopment activities?
❑ Yes ® No ❑ Unknown
In the event that contaminated soil vapor is encountered during redevelopment activities, list
activities for management of such contact: Petroleum -related volatile organic compounds (VOCs) have
been identified in localized areas within soils and the groundwater beneath the site. Soil Vapor
Intrusion Barriers (SVIBs) will be installed during construction to prevent VOCs or gases from collecting
beneath and in the on -site buildings. The SVIB will serve as an engineered barrier to mitigate the
potential inhalation exposure pathway. The anticipated SVIB design and construction specifications
have not been prepared at this time. El will review and provide comments pertaining to the design and
specifications prior to installation of the vapor barrier. El will also monitor the installation and testing of
the SVIB to provide assurance that the system has been installed in accordance with the design and
specifications. The vapor barrier installer shall conduct the installation of the SVIB in accordance with
Occupational Safety and Health Administration (OSHA) requirements for worker safety incumbent upon
contractor's site safety plan.
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PART 7. INDOOR AIR — Please fill out the information below.
Are indoor air data available for the Brownfields Property? ❑ Yes ® No ❑ Unknown
If yes, attach a map showing the location where indoor air contaminants exceed site screening levels.
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
In the event that contaminated indoor air is encountered during redevelopment activities, list
activities for management of such contact: Not Applicable
PART 8. Vapor Mitigation System — Please fill out the information below.
Is a vapor intrusion mitigation system proposed for this Brownfields Property?
® Yes ❑ No ❑ Unknown
If yes, provide the date the plan was submitted to the Brownfields Program.
Vapor mitigation plan is in the initial stages of being developed.
Attach the plan.
Has the vapor mitigation plan been approved by the NC Brownfields Program?
❑ Yes ® No ❑ Unknown
Has the vapor mitigation plan been signed and sealed by a North Carolina professional engineer?
❑ Yes ® No The anticipated SVIB design and construction specifications have not been prepared at
this time. El will review and provide comments pertaining to the design and specifications prior to
installation of the vapor barrier. El will also monitor the installation and testing of the SVIB to provide
assurance that the system has been installed in accordance with the design and specifications.
What are the components of the vapor intrusion mitigation system?
❑ Sub -slab depressurization system
❑ Sub -membrane depressurization system
❑ Block -wall depressurization system
❑ Drain tile depressurization system
❑ Passive mitigation methods
® Vapor barriers
® Perforated piping vented to exterior
❑ Other method: UIcK nere to enter text.
PART 9. CONTINGENCY FOR ENCOUNTERING UNKNOWN TANKS, DRUMS, OR OTHER WASTE
MATERIALS
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Please provide a contingency plan in the event unknown tanks, drums, fuel lines, landfills, or other
waste materials are encountered during site activities.
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.
Field staff must be able to identify if a new discovery of changed chemical conditions has occurred, and
if so, if it is significant. If there is a question of the significance of a new discovery or changed condition,
the environmental manager (Stephen Brown) or equivalent qualified environmental professional should
make the determination. The worker or contractor should be alert during earthwork for the following
indications that will trigger the possible identification of a new condition not addressed by previous
investigations and evaluation.
1) During soil disturbance, the worker or contractor should observe soils for unique color changes
that are unlike surrounding soils. The soils identified during previous environmental
investigations were reportedly varied in color and composition, ranging from brown and orange,
brown to tan, and yellow brown. When observing soils, some may be more saturated than
others depending on recent rainfall and the depth of soil disturbance (near the water table).
Moist soils tend to appear darker. The worker or contractor should closely observe dark, moist
soils for evidence of saturation by fluids other than water. Although no free phase petroleum
products or other chemicals were noted in prior site investigation reports, oddly colored soils or
soils saturated by apparent petroleum products or other chemicals are indicative of a changed
condition.
2) Secondly, soils impacted by petroleum constituents as noted during prior site investigations
could produce chemical or "petroleum" odors associated with on -site impacts. Soils may often
have a "musty" or "rotting" odor if found mixed with vegetation or dark organic soils. Strong
fuel or chemical odors in soils are indicative of a changed condition.
3) Prior assessment reports indicated that known tanks have been removed from the site;
however, there are indications of subsurface structures (piping and sumps) at the site. Although
we do not anticipate encountering drums, underground storage tanks, or other debris, the
worker and contractor should be cognizant of man-made containers or remnants of containers
of any material. The presence of whole or crushed drums or containers in excess of one gallon
in the soils in combination with odor or unique color changes may be indicative of a changed
condition.
If a changed condition is noted at the site, the suspect soils should be isolated as soon as possible from
contact and disturbance by rain and wind until screening identification can be made. Construction
flagging tape attached to stakes will be used to prevent accidental movement of the soils by earthwork
operations. The soils will be covered with plastic sheeting and weight to keep such sheeting in place,
including covering with planks, sandbags, or equivalent. In light of site history, the soils will be screened
for volatile and semi -volatile organic compounds. The screening will be provided by the on -site
environmental manager or other qualified environmental professional. The owner or contractor may
alternatively go directly to laboratory testing for identification purposes.
Screening tests can be conducted on the site and can produce preliminary results quickly. The field test
does not produce a precise measurement of the amount of contaminant found in the soils, but indicates
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that contaminants are likely present and as such warrant further caution and actual measurement. If
preliminary screening activities indicate a changed condition may be present, laboratory testing will be
conducted to determine if contaminants present in the soil actually pose a significant risk. Laboratory
testing requires time that varies depending on the type of test needed. In general, laboratory testing for
petroleum hydrocarbons can take on the order of 5 to 7 business days unless special arrangements are
made with the laboratory for more expensive "RUSH" results. During this time, the impacted soils shall
remain isolated from worker and public exposure. Special handling and care must be taken in sampling
and transporting soils for the laboratory tests to be accurate. The workers in physical contact with
suspect impacted soil should have training consistent with 29 OSHA 1910.120.
Several methods can be utilized for soil management pending receipt of analytical results respecting a
changed condition. First, as noted above, soils can be stockpiled under secured a cover in a secure
location. Second, for small volumes, the soil can be placed temporarily in steel open -top drums with
bolt -on lids. After sealing, the drum should be clearly labeled with pertinent information such as "Do
Not Disturb", sample number, date, and name of sampler. The drums should be placed in an on -site
area protected from general traffic. As an alternative to stockpiling larger volumes, it can be effective to
place the soils into commercial roll -off dumpsters which have been previously washed and cleaned of
residues or soils can be stockpiled on plastic sheeting. The containers will not have free -draining
bottoms and stockpiles shall be graded, bermed, or provided with an equivalent barrier where necessary
to help prevent water run-off. The tops of the containers or stockpiles will then be covered with plastic
sheeting and secured against wind and rain. The commercial containers or stockpiles should be
placarded with information similar to the notation on drums.
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)
❑ Conduct geophysical surveys to evaluate the location of suspect UST, fuel lines, utility lines, etc.
❑ Interviews with employees/former employees/facility managers/neighbors
Notification to State 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. See Notification Section on Page 1 for notification requirements.
POST -REDEVELOPMENT REPORTING
In accordance with the site's Brownfield Agreement, provide a report within the designated schedule
to the State Brownfields Project Manager.
® Check box to acknowledge consent to provide a redevelopment summary report in compliance
with the site's Brownfields Agreement.
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APPROVAL SIGNATURES
Glenn Weaver/Manager of Academic Privatization, LLC, the Managing Member of Harrod/AP, LLC
9-21-2016
Consultant Date
Stephen C. Brown/Project Geologist/The El Group
Brownfields Project Manager
Sharon P. Eckard/NC Brownfields Program
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Date

APPROVAL SIGNATURES
Glenn Weaver/Manager of Academic Privatization, LLC, the Managing Member of Harrod/AP, LLC
9-21-2016
Consultant Date
Stephen C. Brown/Project Geologist/The El Group
Brownfields Project Manager
Sharon P. Eckard/NC Brownfields Program
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