23053 Former Cotton Seed Oil Mill EMP 20200110

Environmental Management Plan

Former Cotton Seed Oil Mill
Brownfields Project ID: 23053-19-060

300 Rampart Street
Charlotte, North Carolina

January 10, 2020 H&H Job No. JMC-009

#C-1269 Engineering
#C-245 Geology

CONTENTS
Completed EMP Form

Tables
Table 1 Summary of Groundwater Analytical Results
Table 2 Summary of Soil Analytical Results
Table 3 Summary of Sub-Slab Vapor and Soil Gas Analytical Results
Table 4 Summary of DEQ Risk Assessment Results for Sub-Slab Vapor and Soil Gas

Figures
Figure 1 Site Location Map
Figure 2 Sample Location Map

Appendices
Appendix A Site Plans – Phase I Development
Appendix B Construction Schedule

1
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.

2
EMP Version 2, June 2018
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.

3
EMP Version 2, June 2018
GENERAL INFORMATION

Date: 1/10/2020 Revision Date (if applicable):

Brownfields Assigned Project Name: Cotton Seed Oil Mill

Brownfields Project Number: 23053-19-060

Brownfields Property Address: 300 Rampart Street Charlotte, North Carolina

Brownfields Property Area (acres): The Site consists of one approximate 2.4-acre parcel.
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): 300 Rampart Owner, LLC
Contact Person: Chris Deppoliti
Phone Numbers: Office: [phone] Mobile:
Email: [e-mail]

Contractor for PD: To be determined
Contact Person:
Phone Numbers: Office: Mobile:
Email:

Environmental Consultant: Hart & Hickman, PC
Contact Person: Matt Bramblett
Phone Numbers: Office: [phone] Mobile:
Email: [e-mail]

Brownfields Program Project Manager: William Schmithorst
Phone Numbers: Office: [phone] Mobile:
Email: [e-mail]

Other DEQ Program Contacts (if applicable, i.e., UST Section, Inactive Hazardous Site Branch,

4
EMP Version 2, June 2018
Hazardous Waste, Solid Waste):
David Mattison, NC DEQ VCC Project Manager [phone]

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:
The Site is planned to be redeveloped in multiple phases. The current phase of construction
(identified as Phase 1) involves adaptive reuse of the central and eastern warehouse buildings for
commercial office and retail use. During Phase 1 of redevelopment, partial demolition of the
western warehouse building (building slab to remain in-place) will occur for additional parking
space. Future phases of construction may include the potential future vertical build-out for multi-
occupant residential development. A preliminary Site Plan for Phase 1 is included in Appendix A.

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
5
EMP Version 2, June 2018
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:
Current redevelopment plans include the partial demolition of the approximate 14,600-square foot
(sq ft) western warehouse building and an approximate 550-sq ft built-out addition to the eastern
portion of the eastern warehouse building. The western warehouse building walls will be
demolished to 4 ft above finished floor. The current building slab in this area will remain and will
be utilized for parking. A ramp will be constructed to access this parking area from Rampart Street.
Additionally, rip rap will be removed from the rear of the building and this area will be paved with
asphalt and a newly installed ramp to access the new parking area from the rear. A 16 ft wide
sidewalk with tree pits will be installed from the existing edge of the pavement along Rampart
Street inward towards the building. Existing asphalt between the sidewalk and front of the building
will be removed. According to the preliminary grading plans, a balanced Site is expected with a
potential of approximately 332 cubic yards of soil to be stockpiled or reused on-Site. A preliminary
Site plan which includes current and proposed grades is included as Appendix A.
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: 1/16/2020
b)Anticipated duration (specify activities during each phase):

6
EMP Version 2, June 2018
Demolition of interior partitions are anticipated to begin in January 2020. Additional
demolition activities and the installation of sediment and erosion control measures are
anticipated to begin on June 9, 2020, followed structural repairs and sub-grade utility
installation (July 2020), roof and window installation and mechanical, electrical, and plumbing
trim out (August 2020), grading, sitework, and painting (September 2020), landscaping
(October 2020), and inspections (November 2020). Note that these construction milestones
are subject to change.

c) Additional phases planned? ☐ Yes ☐ No
If yes, specify the start date and/or activities if known:
Start Date: To be determined
Planned Activity:
A 2nd development phase with vertical development is anticipated for the Site (identified as
Phase 2). Construction plans for Phase 2 have not been developed.

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: 12/3/2020

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.

7
EMP Version 2, June 2018
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):
H&H completed Phase I and II ESA activities at the Site in September 2019. The results of Phase I
and II ESA indicate that a portion of the Site was historically occupied by a portion of the former
Virginia Carolina Chemical (VCC), Charlotte Facility. This facility formerly operated as a phosphate
fertilizer plant from at least the 1890s until the 1930s. Soil at the Site is impacted with elevated
levels of arsenic and lead as a result of the former activities, and ExxonMobil is identified as the
responsible party for the cleanup. ExxonMobil has removed source area soils from feasible
locations on the Site to Site-Specific Target Levels for arsenic (27 mg/kg) and lead (270 mg/kg), but
impacts remain under the building and near building foundations.

A brief summary of the Phase II ESA soil assessment results is provided below:

VOCs
Analytical results indicate that no VOCs were detected in the soil samples at concentrations
exceeding DEQ Inactive Hazardous Sites Branch (IHSB) Residential or Industrial/Commercial
Preliminary Soil Remediation Goals (PSRGs).

SVOCs
Analytical results indicate that no SVOCs were detected in the soil samples at concentrations
exceeding DEQ IHSB Residential or Industrial/Commercial PSRGs.

Metals
The results of the metals analyses indicate that elevated levels of arsenic (up to 156 milligrams per
kilogram – mg/kg) are present in the western portion of the Site at concentrations exceeding NC
DEQ Residential and Industrial/Commercial PSRGs. Additionally, potentially elevated levels of
chromium and hexavalent chromium were detected in soil samples collected beneath the building
slab. Hexavalent chromium was detected in several shallow soil samples at concentrations
exceeding Residential PSRGs, but below Industrial/Commercial PSRGs.

Laboratory analytical results of the soil samples collected at the Site during previous assessment
activities are summarized in Table 2. Sample locations are presented on Figure 2.
2) Depth of known or suspected contaminants (feet):
Arsenic was detected above PSRGs at depths ranging from zero to 7 ft bgs in the western portion of
the Site. Potentially elevated levels of hexavalent chromium were detected above PSRGs at depths
ranging from zero to 7 ft bgs in the western portion of the Site and at depths ranging from zero to 2
ft bgs in the central and eastern portions of the Site. 3) Area of soil disturbed by redevelopment (square feet):

8
EMP Version 2, June 2018
Approximately 30,000 sq ft is estimated to be disturbed during Phase 1 of Site redevelopment.
Grading activities will be conducted in accordance with applicable local, state, and federal
regulations. The grading contractor will utilize grading equipment (i.e., backhoes, front end
loaders, bull dozers, etc.) and will implement best management practices (i.e., installation of silt
fencing) to manage soil on-Site during Site redevelopment activities.

During Phase 2 of Site redevelopment, the entire Site would be expected to be disturbed.

4) Depths of soil to be excavated (feet):
Soil in the southwestern portion of the Site will be excavated to depths up to 4 ft bgs. Soils in
additional areas of the Site will generally be excavated to shallow depths (up to 2 ft bgs) for the
installation of utility trenches or for grading purposes. Additional soil disturbance areas will be
generally shallow due to removal of asphalt or concrete. Significant changes to Site grade are not
anticipated.

5) Estimated volume of soil (cubic yards) to be excavated (attach grading plan):
N/A – A balanced Site is anticipated.

6) Estimated volume of excavated soil (cubic yards) anticipated to be impacted by contaminants:
N/A

7) Estimated volume of contaminated soil expected to be disposed of offsite, if applicable:
No soil is planned to be disposed off-Site at this time. Rip rap will be removed from the northern
portion of the Site. Efforts will be made to remove rip rap while maintaining underlying soil in-
place. Should soil or buried debris need to be exported from the Brownfields property during
redevelopment, a sampling plan will be developed and submitted to DEQ Brownfields for review
and approval once the volume of soil for export is known.

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).

☐ If yes, do the soils exceed the “Contained-Out” levels in Attachment 1 of the

9
EMP Version 2, June 2018
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
☐ 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)
Click or tap here to enter
text.

☒ If no, explain rationale:
Soil analytical data does not indicate exceedances of TCLP criteria based on soil
analytical data collected during previous Phase II ESA activities. TCLP analytical
results are provided in Table 2.

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.

10
EMP Version 2, June 2018

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:
Click or tap here to enter text.
☒ Manage soil under impervious cap ☒ or clean fill ☒
☒ Describe cap or fill:
Should potentially impacted soil or fill materials be encountered during redevelopment that
do not require removal for geotechnical or construction purposes and meets the definition of
beneficial fill as outlined in the Beneficial Fill rule (15A NCAC 13B.0562), the potentially
impacted soil or fill materials may be placed beneath impervious surfaces (asphalt pavement,
sidewalks, access roads, buildings, etc.) or a minimum of 2 ft of clean fill.

☒ 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:
The grading contractor will consider 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
Click or tap here to enter
text.

11
EMP Version 2, June 2018
☒ Yes, describe the field screening method, frequency of field screening, person conducting
field screening:
During soil disturbance at the Site, the workers or contractors will observe soils for evidence
of potential significantly impacted soil. Evidence of potential significantly impacted soil
includes a distinct unnatural color, strong odor, or filled or previously disposed materials of
concerns (i.e. chemicals, tanks, drums, etc.). Should the above be noted during sitework, the
contractor will contact the environmental professional to observe the suspect condition. If
the environmental professional confirms that the material may be impacted, then the
procedures below will be implemented. In addition, the environmental professional will
contact the DEQ Brownfields project manager within two business days to advise that person
of the condition.

☐ No, explain rationale:

Soil Sample Collection
☐ Yes, describe the sampling method (e.g., in-situ grab, composite, stockpile, etc.):
Click or tap here to enter
text.

☒ No, explain rationale:
Collection of additional soil samples is not anticipated based on results of previous Site
assessment activities and the fact that this is a balanced Site. Beneficial fill, if any, will be
tested prior to placement at the Site. If significant soil impact is encountered during grading
and/or 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 described below. Suspect significantly impacted soil or
other buried fill materials excavated during grading and/or utility line installation or removal
may be stockpiled and covered in a secure area to allow construction to progress. Suspect
significantly impacted soil or other buried fill materials will be underlain by and covered with
minimum 10-mil plastic sheeting. At least one representative sample of the soil will be
collected per 1,000 cubic yards of material for analysis of total VOCs, SVOCs, and RCRA
metals plus hexavalent chromium. If the results of analysis of the sample indicate that the
soil could potentially exceed toxicity characteristic hazardous waste criteria, then the soil
will also be analyzed by TCLP for those compounds that could exceed the toxicity
characteristic hazardous waste criteria. Impacted soil will be handled in the manner
described below based upon the laboratory analyses:

i. If no organic compounds are detected in a sample (other than which are attributable
to sampling or laboratory artifacts) and metals are below Residential PSRGs or are

12
EMP Version 2, June 2018
consistent with Site-specific background levels, then the soil will be deemed suitable for use
as on-Site fill or as off-Site fill. The proposed location(s) for off-Site placement of soil (other
than a permitted facility) along with the receiving facility’s written approval for acceptance
of the soil will be provided to DEQ for approval prior to taking the soil off-Site.
ii. If detectable levels of compounds are found which do not exceed the Residential
PSRGs (other than which are attributable to sampling or laboratory artifacts or which are
consistent with background levels for metals) and the TCLP concentrations are below
hazardous waste criteria, then the soil may be used on-Site as fill without conditions.
iii. If detectable levels of compounds are found which exceed the Residential PSRGs
(other than which are attributable to sampling or laboratory artifacts or which are
consistent with background levels for metals) and the TCLP concentrations are below
hazardous waste criteria, then the soil, with DEQ’s written approval, may be used on-Site as
fill below an impervious surface (i.e. parking lot or building foundation), or at least 2 ft of
compacted clean soil. If the impacted soil with concentrations above Residential PSRGs is
moved to an on-Site location, its location and depth will be documented, and its location will
be provided to DEQ in an updated survey plat.
iv. Impacted soil may be transported to a permitted facility such as a landfill provided
that the soil is accepted at the disposal facility. If soil is transported to a permitted facility,
the permitted facility’s written approval to dispose of soil from the Site will be included with
the final EMP report. In the unlikely event that the sample data indicate concentrations
above TCLP hazardous waste criteria, then the soil must be transported off-Site to a
permitted disposal facility that can accept or treat hazardous waste.

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): EPA Methods 6020/7471
☐ 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): Hexavalent chromium by EPA Method 7196 (assuming appropriate method detection limits can be met by the laboratory) or 7199

☒ 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

13
EMP Version 2, June 2018
control, prohibiting contact between surface water/precipitation and contaminated soil,
and preventing contaminated runoff. Explain any variances or provide additional details as
needed:

☒ 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): EPA Methods 6020/7471
☐ 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.): Hexavalent chromium by EPA Method 7199

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.
Following completion of soil disturbance for any future Site development (i.e. after grading
and utility construction), an environmental professional will be contracted to assess the Site
for areas that are not covered with a minimum of 2 ft of clean fill soil or topsoil from a
landscaping company, building foundations, sidewalks, or asphalt or concrete parking areas,
driveways or other impervious surfaces. If such areas exist, a Work Plan will be prepared for
final grade sampling for DEQ review and approval. If no such areas exist, documentation will
be provided to DEQ.

☐ If final grade sampling was NOT selected please explain rationale:
Click or tap here to enter
text.

Part 1.B. IMPORTED FILL SOIL

14
EMP Version 2, June 2018
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:

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?
Based on preliminary grading plans, fill soil will not need to be imported to the Site. However, the
PD may import limited amounts of organic rich topsoil from a commercial landscape material vendor
for use in proposed landscaped areas.

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.)

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:
As noted above, fill soil is not anticipated to be imported to the Site. However, if future activities
indicate the need for fill, the procedures outlined below will be followed.

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.
To demonstrate that imported soil (if required) is suitable for use at this property, the fill soil will be
sampled and approved by DEQ Brownfields prior to being brought to the Site. A sampling plan will
be developed and submitted for DEQ Brownfields review under separate cover. DEQ approval of
the sampling plan and analytical results is required prior to bringing soil on Site. Soil will be
considered suitable for use at the Site if it does not contain compound concentrations above
Residential PSRGs or background levels for metals.

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): EPA Methods 6020/7471
☐ Pesticides: Specify Analytical Method Number(s): Click or tap here to enter text.

15
EMP Version 2, June 2018
☐ PCBs: Specify Analytical Method Number(s):
☒ Other Constituents & Respective Analytical Method(s) (i.e. Hexavalent Chromium, Herbicides, etc.): Hexavalent chromium by EPA Method 7199

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.
Based on preliminary grading plans, import fill will not be required at the Site. However, if future
activities indicate the need for import fill, the PD will follow the procedures outlined below.

If the PD plans to import fill material from the Vulcan Materials Company quarry located near
Pineville, NC or from the Martin Marietta quarry located on Beatties Ford Road in Charlotte, NC, and
given that the material is virgin cut soil from said quarry, no samples of the import material will be
collected. Adequate analytical data are available in the DEQ Brownfields database to demonstrate
material from these facilities is suitable for use as fill at a Brownfields property.

If fill soil is obtained from an off-Site property that is not a known permitted quarry, a sampling plan
will be developed and submitted for DEQ review. DEQ approval of the sampling plan and analytical
results will be obtained prior to transporting import soil to the Site. The specific sampling rate will be
outlined in the aforementioned sampling plan. However, if the proposed borrow source has not
been previously developed (i.e., virgin land), soil samples will be collected for laboratory analyses
indicated above at a general rate of one per 1,000 cubic yards. If the borrow source property has
been previously developed, soil samples will be collected for laboratory analyses indicated above at
a general rate of approximately one per 500 cubic yards. Fill soil will be considered suitable for use
at the Site if it does not contain compound concentrations above DEQ IHSB Residential PSRGs or
typical metals concentrations which are consistent with background levels.

The PD does not plan to collect samples of landscaping materials prior to placement at the Site.

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

16
EMP Version 2, June 2018
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.
Based on review of the proposed grading plan, export soil is not anticipated at this time. Should soil
need to be exported from the Brownfields property during redevelopment, a sampling plan will be
developed and submitted to DEQ Brownfields for review and approval once the volume of soil for
export is known. Generally, soil samples will be collected from export soil at a rate of 1 sample per
every 500 cubic yards of export.

DEQ approval of the sampling plan and analytical results will be obtained prior to transporting
export soil from the Site. Based on analytical results of soil samples collected from the export soil,
the soil will be transported off-Site to a suitable location. The PD will notify DEQ Brownfields of the
location receiving the export soil. If not a permitted facility, DEQ Brownfields approval and written
approval from the receiving facility will be obtained prior to transporting the soil off-Site.

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).
The environmental professional will contact DEQ Brownfields to obtain DEQ Brownfields and DEQ
Solid Waste approval prior to exporting soil off-Site.

Part 1.D. MANAGEMENT OF UTILITY TRENCHES

☐ Install liner between native impacted soils and base of utility trench before filling with clean fill
(Preferred)

17
EMP Version 2, June 2018
☒ 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:
Click or tap here to enter
text.

☒ If no, include rationale here:
Results of risk calculators conducted for the Site did not indicate the presence of a vapor intrusion
concern.

Other comments regarding managing impacted soil in utility trenches:
In the event contaminated soil and/or vapors are encountered in utility trenches during redevelopment
activities, the trench will be evacuated, and appropriate safety screening of the vapors will be
performed to protect workers. If results indicate further action is warranted in response to vapors to
protect workers, appropriate engineering controls (such as use of industrial fans) will be implemented.

The contractor and workers will observe soil for potential impacts during utility installation activities.
Evidence of potential significant impacted soil includes a distinct unnatural color, strong odor, or filled or
previously disposed materials of concerns (i.e. chemicals, tanks, drums, etc.). Should the above be
noted during utility work, the contractor will contact the environmental professional to observe the
suspect condition and screen the soil using a calibrated photo-ionization detector (PID) or similar vapor
field screening instrument. If the environmental professional confirms that the material may be
impacted, then the procedures outlined in Part 1.A. Managing On-Site Soil above will be implemented.
In addition, the environmental professional will contact the DEQ Brownfields project manager within
two business days to advise that person of the condition.

PART 2. GROUNDWATER – Please fill out the information below.
1) What is the depth to groundwater at the Brownfields Property?
During previous Phase II ESA activities conducted at the Site in August, 2019, depth to
groundwater was identified to be between approximately 17 ft bgs in the southwestern portion of
the Site and approximately 20 ft bgs in the northeastern portion of the Site.
2) Is groundwater known to be contaminated by ☐onsite ☐offsite ☐both or ☐unknown
sources? Describe source(s):
Previous groundwater assessment activities did not indicate the presence of VOCs, SVOCs, or
metals in Site groundwater at concentrations above 2L Standards or the Residential and Non-

18
EMP Version 2, June 2018
Residential Vapor Intrusion Groundwater Screening Levels (GWSLs). Groundwater laboratory
analytical results are summarized in Table 1. Groundwater sample locations are presented on
Figure 2.

3) What is the direction of groundwater flow at the Brownfields Property?
Groundwater in the northern portion of the Site is expected to generally flow to the west towards a
tributary of Irwin Creek.
4) Will groundwater likely be encountered during planned redevelopment activities?
☐Yes ☒No
If yes, describe these activities:
Click or tap here to enter
text. Regardless of the answer; 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, NPDES permit, or sampling procedures).
Although not anticipated, if groundwater suspected to be impacted (based on strong odor,
unnatural color, sheen, etc.) is encountered during Site work, the contractor will contact the
environmental professional to observe the suspect condition. If the environmental professional
determines that the excavation likely contains impacted groundwater, then appropriate worker
safety measures will be undertaken to manage groundwater that gathers in an open excavation
within an area determined to be impacted during construction activities. The accumulated water
will be allowed to evaporate (if feasible), tested and disposed off-Site (if impacted), tested and
discharged to the storm sewer (if not impacted above DEQ surface water standards) in accordance
with applicable municipal and State regulations for erosion control and construction stormwater
control, or used for dust control at the Site (with Brownfields prior approval). In addition, the
environmental professional will contact the DEQ Brownfields project manager within 48 hours
regarding the condition.

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

19
EMP Version 2, June 2018
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
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):
As noted above, surface water is not present at the
Site.

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):
As noted above, sediment sources are not present on the Site
property.

No existing monitoring wells are present at the
Site.

20
EMP Version 2, June 2018

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:
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:
As noted above, we do not anticipate workers will encounter contaminated soil vapor during
planned redevelopment activities. However, the environmental professional will remain on call on
an as-needed-basis during redevelopment activities at the Site. If contaminated soil vapors are
suspected during redevelopment activities (based on unusual odors, headaches, dizziness, nausea,
etc.), the excavation area will immediately be evacuated, and the environmental professional will
be called to perform appropriate safety screening of the vapors. Safety screening activities include
monitoring the worker breathing zone with a calibrated multi-gas monitor (or similar instrument[s]
capable of detecting VOCs and combustible gases) for VOCs, methane, oxygen, carbon dioxide,
and/or hydrogen sulfide photoionization detector. If results indicate further action is warranted,
appropriate engineering controls (such as use of industrial fans) will be implemented. In addition,
the environmental professional will contact the DEQ Brownfields project manager within 48 hours
regarding the condition.

As noted above, volatile organic compounds have not been detected at the Site at concentrations
exceeding IHSB Residential or Industrial/Commercial Screening Levels. Sub-slab vapors were sampled
twice during different times of the year. Sub-slab vapor and soil gas analytical results are provided in
Table 3. Sub-slab vapor and soil gas sample locations are presented on Figure 2.

21
EMP Version 2, June 2018
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:
Based on two prior assessment events, contaminated sub-slab vapor is not anticipated to be present
at the Site.

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
Although contaminated sub-slab vapor is not anticipated to be present at the Site, in the event
that contaminated soil vapors are encountered during future redevelopment
activities, the 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.

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:

Indoor air samples have not been collected at the Site. However, based on sub-slab vapor analytical
results, contaminated indoor air is not anticipated to be present at the Site.

In the unlikely event there is evidence of potential indoor air issues (i.e. unusual odors) during future
redevelopment activities, the area will be evacuated, and appropriate safety screening of the indoor air
will be performed. If warranted, safety screening procedures will include periodically screening indoor
air for volatile organic vapors with a calibrated photoionization detector. If results indicate further
action is warranted, appropriate engineering controls (i.e. use of industrial fans) will be implemented.

22
EMP Version 2, June 2018

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
If submitted separately provide date:
A VIMS is not proposed for this
Site. 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:
H&H has conducted soil, groundwater, sub-slab vapor, and soil gas sampling at the Site. Results of
risk calculators prepared for the Site do not indicate the presence of a vapor intrusion concern.

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)
EPA Methods 6020/7471

☐ Pesticides: Specify Analytical Method Number(s):
Click or tap here to enter text.

23
EMP Version 2, June 2018
☐ PCBs: Specify Analytical Method Number(s):

☒ 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.
Hexavalent chromium by EPA Method 7199 Please provide details on the proposed methods of managing the following commonly
encountered issues during redevelopment of Brownfields Properties.
During construction activities, contractors may encounter unknown sub-surface environmental
conditions (i.e. tanks, drums, or waste materials) that if encountered, will require proper
management. Prior to beginning Site work, H&H will attend a pre-construction kick-off meeting with
the PD and the redevelopment contractors to discuss the DEQ approved EMP and various scenarios
when it would be appropriate and necessary to notify H&H of the discovery of unknown subsurface
features or potentially impacted media at the Site. In the event that such conditions are encountered
during Site redevelopment activities, the environmental actions noted below will be used to direct
environmental actions to be taken during these activities and sampling data for potentially impacted
soil and the disposition of impacted soil will be provided to DEQ when the data are available.

Underground Storage Tanks:
In the event a previously unidentified UST or impacts associated with a UST release are discovered at
the Site during redevelopment activities, the UST and/or UST related impacts will be addressed
through the Brownfields Program. However, UST removals will be conducted in general accordance
with NC DEQ UST Section guidance.

If the UST contains residual fluids, the fluids will be removed, sampled for VOCs, SVOCs, and RCRA
metals, and transported off-Site for disposal at a suitable facility based on the laboratory analytical
results. Impacted soil will be managed in accordance with Part 1.A. above.

Sub-Grade Feature/Pit:
If a sub-grade feature or pit is encountered and does not require removal for geotechnical or
construction purposes, it will be filled with soil or suitable fill and construction will proceed. Where
appropriate, the bottom may be penetrated before back filling to prevent fluid accumulation. If the
pit has waste in it, the waste will be set aside in a secure area and will be sampled for waste disposal
purposes for TCLP VOCs, SVOCs, and metals and disposed off-Site at a permitted facility or the waste
will be managed in accordance with Part 1.A. above, whichever is most applicable based on the type
of waste present. If the pit must be removed and the observed waste characteristics indicate the
concrete may potentially be contaminated to a significant degree, the concrete will be sampled and
analyzed by methods specified by the disposal facility.

Buried Waste Material:
If excavation activities result in removal of buried wastes, significantly impacted soils, or significantly

24
EMP Version 2, June 2018
impacted unconsolidated fill material (concrete, lime, bricks, etc.), the contractor will be directed to
stop work at that location and notify the environmental professional. The environmental professional
will review the soil/materials and collect samples if warranted. If the buried materials or soil do not
require removal for geotechnical or construction purposes, meets the definition of beneficial fill as
outlined in the Beneficial Fill rule (15A NCAC 13B.0562), and based on the sample results (as discussed
in Part 1.A. above), they will remain in-place and construction will proceed. If the fill material is to be
removed, confirmation sampling will be conducted at representative locations in the base and the
sidewalls of the excavation after the waste or significantly impacted media is removed. The
confirmation samples will be analyzed for VOCs, SVOCs, and RCRA metals plus hexavalent chromium.
Areas of suspected contaminated soil that remain at the Site after excavation is complete above the
Residential PSRGs will be managed pursuant to this plan and incorporated into the final Brownfields
plat.

Re-Use of Impacted Soils On-Site:
Please refer to Part 1.A.
above.

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:

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 1/31/2021

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;

25
EMP Version 2, June 2018
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
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.

27
EMP Version 2, June 2018

28
EMP Version 2, June 2018

Tables
Table 1Summary of Groundwater Analytical ResultsCharlotte Salvage CompanyCharlotte, North CarolinaH&H Job No. JMC-007Sample IDTMW-1TMW-2Trip BlankDate8/30/20198/30/20198/30/20198/30/20198/30/2019Location DescriptionNorthwestern portion of SiteSouthwestern (downgradient) portion of Site--UnitsVOCs (8260B)Acetone26.8<6.2 <6.2 <6.2 <6.26,000 4,500,000 19,000,000SVOCs (8270D)NANA------RCRA Metals (6020A-B, 7470A)ArsenicNA <0.2500.323J 0.298JNA10-- --BariumNA78.8 81.5 81.7NA700-- --CadmiumNA0.698J<0.160 <0.160 NA2-- --ChromiumNA0.756J 5.91 3.75NA10-- --LeadNA0.244J 0.263J 0.283JNA15-- --MercuryNA <0.0490 <0.0490 <0.0490 NA1 0.18 0.75SeleniumNA0.400J 0.684J 0.742JNA20-- --SilverNA<0.310<0.310<0.310NA20----Turbidity (NTU)>1,0003.988.418.41--------Notes:1) North Carolina Department of Environmental Quality (DEQ) 15A NCAC 02L.0202 Groundwater Standards (2L Standards) (April 2013)2) NC DEQ Division of Waste Management (DWM) Residential Vapor Intrusion Groundwater Screening Level (GWSLs) (February 2018)3) NC DEQ DWM Non-Residential Vapor Intrusion GWSLs (February 2018)With the exception of metals, only constituents detected in at least one sample are shownCompound concentrations are reported to the laboratory method detection limits (MDLs)VOCs = Volatile Organic Compounds; SVOCs = Semi-Volatile Organic Compounds; NTU = Nephelometric Turbidity UnitsNA = Not Analyzed for specified constituent; -- = Not ApplicableJ = estimated value between the laboratory method detection limit and the laboratory reporting limitAll Below MDLsµg/Lµg/LNon-Residential GWSL(3)NC 2L Groundwater Standards (1) Residential GWSL(2)TMW-3 / TMW-DUPNortheastern (upgradient) portion of SiteS:\AAA-Master Projects\JMC Holdings\JMC.007 300 Rampart ESA\Tables\JMC-007 Data Tables9/17/2019Table 1(Page 1 of 1) Hart & Hickman, PC
Table 2Summary of Soil Analytical ResultsCharlotte Salvage CompanyCharlotte, North CarolinaH&H Job No. JMC-007Sample IDWASTE CHARDate 8/30/2019 8/29/2019 8/29/2019 8/29/2019 8/29/2019 8/30/2019 8/30/2019 8/30/2019 8/30/2019 8/30/2019 8/30/2019 8/30/2019 8/30/20198/29/2019 8/30/2019Area of Potential ConcernSoil drumsDepth (ft bgs)1-2 5-7 7-10 0-2 2-5 0-2 3-5 0-2 3-5 0-2 3-5 0-2 3-53-5--Range MeanUnitsVOCs (8260B)AcetoneNA <0.00830.018J<0.0072 <0.00740.044J 0.013J 0.0086J<0.00990.012J 0.015J<0.0083 <0.00840.012J<0.00790.019JNA12,000 140,000 25-- ----SVOCs (8270D)FluorantheneNA0.13J<0.15 <0.59 <0.58 <0.13 <0.14 <0.11 <0.14 <0.13 <0.13 <0.13 <0.13 <0.12 <0.12 <0.12 NA480 6,000 670-- ----PyreneNA0.15J<0.14 <0.54 <0.53 <0.11 <0.13 <0.10 <0.13 <0.12 <0.11 <0.12 <0.12 <0.11 <0.11 <0.11 NA360 4,500 440-- ----Metals (6020B/7471B/7199)Arsenic0.8851563.366.906.063.60 1.87 3.07 2.150 4.11 1.62 3.40 2.07 1.43 1.41 1.31NA0.68 3.0 5.81.0 - 18 4.8--Barium184 69.7 41.9 85.5 84.4 42.7 15.5 42.2 93.5 38.8 21.8 18.4 12.9 23.7 17.4 21.0NA3,100 47,000 58050 - 1,000 356--Cadmium<0.113 <0.101 <0.1110.116J 0.106J<0.101 <0.111 <0.1010.423J<0.104 <0.103 <0.106 <0.102 <0.0963 <0.0975 <0.0940 NA14 200 3.01.0 - 10 (3)4.3 (3)--Chromium (total)11.1 41.3 73.3 37.9 44.5 51.0 72.8 30.4 129 301 198 72.5 72.2 18.7 21.7 25.1NANS NS NS7.0 - 300 65--Hexavalent Chromium<0.359<0.323NA <0.308 NA0.528JNA0.601JNA1.43NA <0.338NA <0.307 <0.311NANA0.31 6.53.8NSNS--Trivalent Chromium10.74 40.98NA37.59NA50.47NA29.80NA299.6NA72.16NA18.39 21.39NANA23,000 350,000 360,000NSNS--Lead8.25 122 15 44.5 41.8 15.4 9.58 18.0 7.33 12.2 6.38 8.75 9.28 8.24 3.46 4.46NA400 800270ND - 50 16--Mercury0.0104J 0.0208J 0.0478 0.110 0.104 0.132 0.0312 0.0173J 0.0454 0.543 0.0467 0.104 0.0518 0.0187J 0.0195J 0.0191JNA2.3 9.7 1.00.03 - 0.52 0.12--Selenium0.423J 0.853 0.604J 0.881 0.847 0.789 1.14 0.913 1.41 1.38 0.867 0.764 1.030.409J 0.544J 0.393JNA78 1,200 2.1<0.1 - 0.8 0.42--Silver<0.2180.250J<0.215 <0.187 <0.185 <0.196 <0.215 <0.195 <0.205 <0.202 <0.199 <0.0205 <0.198 <0.187 <0.189 <0.182 NA78 1,200 3.4ND - 5.0 (3)NS--TCLP RCRA Metals (6010/7470)ArsenicNA <0.0047 NA0.0050JNA <0.0047 NA <0.0047 NA <0.0047 NA <0.0047 NA <0.00470.010JNA <0.0047-- -- -- -- --5.0BariumNA0.63NA0.45NA0.26NA0.29NA0.21JNA0.12JNA0.20J 0.22JNA0.17J-- -- -- -- --100CadmiumNA <0.00040 NA <0.00040 NA0.0010JNA0.00067JNA <0.00040 NA <0.00040 NA <0.000400.00069JNA0.00062J-- -- -- -- --1.0Chromium (total)NA0.0084JNA <0.0010 NA0.0032JNA0.0022JNA <0.0010 NA <0.0010 NA0.0015J<0.0010 NA0.0013J-- -- -- -- --5.0LeadNA0.010JNA0.016JNA0.010JNA0.036NA0.0064JNA0.0038JNA0.0035J 0.0075JNA0.017J-- -- -- -- --5.0MercuryNA <0.00010 NA <0.00010 NA <0.00010 NA <0.00010 NA <0.00010 NA <0.00010 NA <0.00010 <0.00010 NA <0.00010-- -- -- -- --0.2SeleniumNA <0.0047 NA <0.0047 NA <0.0047 NA <0.0047 NA <0.0047 NA <0.0047 NA <0.0047 <0.0047 NA <0.0047----------1.0SilverNA <0.0025 NA <0.0025 NA <0.0025 NA <0.0025 NA <0.0025 NA <0.0025 NA <0.0025 <0.0025 NA <0.0025----------5.0Notes:1) North Carolina Department of Environmental Quality (DEQ) Inactive Hazardous Sites Branch (IHSB) Preliminary Soil Remediation Goals (PSRGs) (May 2019)2) Range and mean values of background metals for North Carolina soils taken from Elements in North American Soils by Dragun and Chekiri, 20053) Background values reported for soils of the southeastern United States4) Obtained from Chapter Seven of the Environmental Protection Agency (EPA) SW-846 Compendium: Introductory and Regulatory Definitions Pertaining to Hazardous Waste Characteristics (2004)With the exception of metals, only constituents detected in at least one sample are shownCompound concentrations are reported to the laboratory method detection limitsBold indicates concentration exceeds DEQ IHSB Protection of Groundwater (POG) PSRG and above the mean background metals in North Carolina soils for metals as preliminary comparison Underlined indicates concentration exceeds DEQ IHSB Residential PSRGs and above the mean background metals in North Carolina soils for metals as preliminary comparisonGray shading indicates concentration exceeds DEQ IHSB Industrial/Commercial PSRGs and above the mean background metals in North Carolina soils for metals as preliminary comparisonTrivalent chromium calculated as total chromium minus hexavalent chromiumVOCs = Volatile Organic Compounds; SVOCs = Semi-Volatile Organic Compounds; TCLP RCRA Metals = Toxicity Characteristic Leaching Procedure Resource Conservation and Recovery Act Metalsft bgs= feet below ground surface; NA = Not Analyzed for specified constituent; -- = Not Applicable; NS = Not SpecifiedJ = estimated value between the laboratory method detection limit and the laboratory reporting limitPublished Background Metals Concentrations for North Carolina Soils (2)SB-1mg/kg (8260B, 8270D, 6020B/7471B/7199) ; mg/L (TCLP)Maximum Concentration of Contaminants for Toxicity Characteristic (4)mg/kg (8260B, 8270D, 6020B/7471B/7199) ; mg/L (TCLP)Residential PSRGs (1)Industrial/ Commercial PSRGs (1)Protection of Groundwater PSRGs (1)SB-7 / SOIL-DUPSB-2 SB-3 SB-4 SB-5 SB-60-28/29/2019Northwestern portion of western warehouseSouthwestern portion of SiteNorthwestern portion of eastern warehouse and near potential former paint mixing areaNortheastern portion of eastern warehouseEastern floor drain in eastern warehouseNortheastern portion of SiteWestern floor drain in eastern warehouseS:\AAA-Master Projects\JMC Holdings\JMC.007 300 Rampart ESA\Tables\JMC-007 Data Tables9/17/2019Table 2 (Page 1 of 1)Hart & Hickman, PC
Table 3
Summary of Sub-Slab Vapor and Soil Gas Analytical Results
Charlotte Salvage Company
Charlotte, North Carolina
H&H Job No. JMC-007
Sample IDSample LocationSlab Thickness (in)Screen Depth (ft bgs)Sample DateAnalytical MethodAcetoneBenzeneBromomethane2-Butanone (MEK)Carbon DisulfideChloroformChloromethaneCyclohexane1,3-Dichlorobenzene1,4-DichlorobenzeneDichlorodifluoromethane (Freon 12)1,1-Dichloroethane1,1-Dichloroethylenecis-1,2-DichloroethyleneEthyl AcetateEthylbenzene4-EthyltolueneHeptaneHexane8/29/2019 114 1.1 <0.44 30.4 5.5 <0.38 <0.30 1.9J 4.1 <1.9 2.2 <0.44 <0.53 <0.42 2.0 2.7 1.9J 2.9 4.2
12/3/2019 57.2 0.41 J <0.44 5.0 J 1.2 J <0.38 <0.30 0.72 J <1.1 <1.9 3.2 <0.44 <0.53 <0.42 <0.37 <0.59 <1.1 <0.74 9.5
8/29/2019 100 0.84 <0.46 13.6 1.5 <0.40 <0.32 <0.71 6.0 <2.0 2.2 <0.45 <0.55 <0.44 <0.38 3.4 2.7J <0.77 4.1
12/3/2019 64.5 1.9 <0.44 4.1 J 0.74 J <0.38 0.38 J 1.7 J <1.1 <1.9 3.3 <0.44 <0.53 <0.42 1.3 J <0.59 <1.1 <0.74 7.8
8/29/2019 158 1.2 <0.46 19.9 7.4 <0.40 2.1 <0.71 3.9 <2.0 2.3 9.0 <0.55 14.1 <0.38 3.0 1.9J <0.77 4.6
12/3/2019 136 0.66 <0.44 9.9 <0.42 <0.38 0.73 J 1.4 J <1.1 3.1 J 3.6 <0.44 <0.53 <0.42 <0.37 <0.59 <1.1 1.5 J 5.9
SSV-4 Can 2255 67.6 <0.30 <0.44 5.9 0.63 J <0.38 0.45 J <0.68 <1.1 <1.9 2.4 <0.44 <0.53 <0.42 1.1 J <0.59 <1.1 0.90 J 4.1
SSV-DUP 71.5 <0.30 <0.44 5.0 J <0.42 <0.38 <0.30 <0.68 <1.1 <1.9 2.2 <0.44 <0.53 <0.42 <0.37 <0.59 <1.1 <0.74 4.1
SSV-5 Can 1023 Southern portion of eastern warehouse 6.0 --12/3/2019 116 <0.31 0.50 J 8.3 <0.44 0.44 J 1.1 <0.71 <1.2 <2.0 2.7 <0.45 <0.55 <0.44 <0.38 <0.62 <1.2 0.92 J 8.7
SG-1 Northeastern (upgradient) portion of
Site 6.0 10.0 8/30/2019 57.9 36.9 <0.46 <0.75 55.5 11.0 10.6 34.3 45.3 <2.0 2.2 <0.45 6.5 <0.44 <0.38 9.0 3.4J 24.8 53.8
220,000 120 35 35,000 4,900 41 630 42,000 NS 85 700 580 1,400 NS 490 370 NS 2,800 4,900
2,700,000 1,600 440 440,000 61,000 530 7,900 530,000 NS 1,100 8,800 7,700 18,000 NS 6,100 4,900 NS 35,000 61,000
Notes:
1) North Carolina Department of Environment Quality (DEQ) Division of Waste Management (DWM) Residential Sub-slab and Exterior Soil Gas
Screening Levels (SGSLs) (February 2018)2) North Carolina DWM Non-Residential SGSLs (February 2018)Only constituents detected in at least one sample are shownCompound concentrations and SGSLs are reported in micrograms per cubic meter (µg/m3)
Compound concentrations are reported to the laboratory detection limits
Bold indicates concentration exceeds Residential SGSL
Bold and Underlined indicates concentration exceeds Non-Residential SGSL
Gray and underlined values are method detection limits that exceed Residential SGSL or both the Residential SGSL and Non-Residential SGSL.ft bgs = feet below ground surface; NS = Not Specified; -- = Not ApplicableJ = estimated value between the laboratory method detection limit and the laboratory reporting limit
--
--12/3/2019
DWM Non-Residential SGSL (2)DWM Residential SGSL (1)
TO-15
Central portion of western warehouseSSV-1
Western portion of eastern warehouseSSV-2
Eastern portion of eastern
warehouseSSV-3
Northern portion of eastern
warehouse
6.0 --
6.0
6.0
6.0
--
\\HARTHICKMAN.LOCAL\Shares\MasterFiles\AAA-Master Projects\JMC Holdings\JMC.007 300 Rampart ESA\Tables\JMC-007 Data Tables
12/17/2019
Table 3
(Page 1 of 2)
Hart & Hickman, PC
Table 3
Summary of Sub-Slab Vapor and Soil Gas Analytical Results
Charlotte Salvage Company
Charlotte, North Carolina
H&H Job No. JMC-007
Sample IDSample LocationSlab Thickness (in)Screen Depth (ft bgs)Sample DateAnalytical Method8/29/2019
12/3/2019
8/29/2019
12/3/2019
8/29/2019
12/3/2019
SSV-4 Can 2255
SSV-DUP
SSV-5 Can 1023 Southern portion of eastern warehouse 6.0 --12/3/2019
SG-1 Northeastern (upgradient) portion of
Site 6.0 10.0 8/30/2019
--
--12/3/2019
DWM Non-Residential SGSL (2)DWM Residential SGSL (1)
TO-15
Central portion of western warehouseSSV-1
Western portion of eastern warehouseSSV-2
Eastern portion of eastern
warehouseSSV-3
Northern portion of eastern
warehouse
6.0 --
6.0
6.0
6.0
--2-Hexanone (MBK)Methylene Chloride4-Methyl-2-pentanone (MIBK)NaphthalenePropeneStyreneTetrachloroethyleneTetrahydrofuranToluene1,1,1-TrichloroethaneTrichloroethyleneTrichlorofluoromethane (Freon 11)1,2,4-Trimethylbenzene1,3,5-TrimethylbenzeneVinyl AcetateVinyl Chloridem&p-Xyleneo-Xylene1.7J 6.8J <1.0 5.1J 4.4 1.5J <0.61 3.2 8.2 <0.60 2.5 <0.71 8.8 1.9J <0.52 <0.24 10.5 5.0
2.1 J 96.5 <1.0 4.2 J 3.6 1.6 J 1.2 J 0.60 J 1.8 <0.60 <0.49 1.8 J <0.88 <0.77 3.2 <0.24 <1.4 <0.67
1.6J 11.7 <1.0 5.5 0.91 1.6J 1.7 3.7 8.2 <0.62 <0.52 <0.74 12.2 2.6 <0.55 <0.25 13.4 6.6
<1.4 81.7 <1.0 <2.5 3.8 <0.67 0.63 J <0.51 2.6 <0.60 <0.49 2.8 <0.88 <0.77 <0.52 <0.24 <1.4 0.76 J
2.4J 13.5 3.5J 4.3J 2.1 1.4J 9.5 3.7 11.4 0.80J 3.6 <0.74 9.3 2.1 <0.55 <0.25 11.6 5.3
4.6 J 37.2 1.1 J 2.9 J 5.4 <0.67 13.9 <0.51 2.1 0.64 J <0.49 5.9 0.89 J <0.77 <0.52 <0.24 <1.4 0.69 J
<1.4 31.7 <1.0 <2.5 <0.27 1.1 J 1.6 <0.51 2.3 <0.60 <0.49 2.0 J <0.88 <0.77 <0.52 <0.24 <1.4 <0.67
<1.4 31.5 <1.0 <2.5 <0.27 1.1 J 0.70 J <0.51 0.89 J <0.60 <0.49 2.0 J <0.88 <0.77 <0.52 <0.24 <1.4 <0.67
<1.5 82.1 1.4 J <2.6 <0.28 <0.69 3.2 <0.53 1.4 J 8.2 <0.51 3.3 <0.91 <0.81 <0.55 <0.25 <1.4 <0.69
<1.5 7.4 4.6J 6.0 439 11.0 1.4 <0.53 26.0 <0.62 <0.52 3.7 12.4 3.5 <0.55 3.4 16.7 6.7
210 4,200 21,000 21 21,000 7,000 280 14,000 35,000 35,000 14 NS 420 420 1,400 56 700 700
2,600 53,000 260,000 260 260,000 88,000 3,500 180,000 440,000 440,000 180 NS 5,300 5,300 18,000 2,800 8,800 8,800
Notes:
1) North Carolina Department of Environment Quality (DEQ) Division of Waste Management (DWM) Residential Sub-slab and Exterior Soil Gas
Screening Levels (SGSLs) (February 2018)2) North Carolina DWM Non-Residential SGSLs (February 2018)Only constituents detected in at least one sample are shown.Compound concentrations and SGSLs are reported in micrograms per cubic meter (µg/m3).
Compound concentrations are reported to the laboratory detection limits.
Bold indicates concentration exceeds Residential SGSL
Bold and Underlined indicates concentration exceeds Non-Residential SGSL
Gray and underlined values are method detection limits that exceed Residential SGSL or both the Residential SGSL and Non-Residential SGSL.ft bgs = feet below ground surface; NS = Not Specified; -- = Not Applicable; NM = Not MeasuredJ = estimated value between the laboratory method detection limit and the laboratory reporting limit
\\HARTHICKMAN.LOCAL\Shares\MasterFiles\AAA-Master Projects\JMC Holdings\JMC.007 300 Rampart ESA\Tables\JMC-007 Data Tables
12/17/2019
Table 3
(Page 2 of 2)
Hart & Hickman, PC
Table 4
Summary of DEQ Risk Assessement Results for Sub-Slab Vapor and Soil Gas
Charlotte Salvage Company
Charlotte, North Carolina
H&H Job No. JMC-007
Calculated LICR Calculated HI Calculated LICR Calculated HI
Worst Case 8-29-19 9.2E-06 0.19 NO 6.6E-07 0.015 NO
Worst Case 12-3-19 2.2E-06 0.07 NO 1.7E-07 0.005 NO
Notes:
1) Based on the North Carolina Department of Environmental Quality (DEQ) Risk Calculator
for Residential Use Scenario of the Soil Gas to Indoor Air Exposure Pathway (Version May 2019)
2) Based on the DEQ Risk Calculator for Non-Residential Use Scenario of the Soil Gas
to Indoor Air Exposure Pathway (Version May 2019)
LICR = Lifetime Incremental Cancer Risk
HI = Non-Carcinogenic Hazard Index
Sample ID Resident (1)Risk Exceeded?Non-Residential Worker (2)Risk Exceeded?
File: \\HARTHICKMAN.LOCAL\Shares\MasterFiles\AAA-Master Projects\JMC Holdings\JMC.007 300 Rampart ESA\Tables\JMC-007 Data TablesJMC-007 Data TablesDate: 12/17/2019
Table 4
Hart & Hickman, PC

Figures
0 2000 4000
APPROXIMATE
SCALE IN FEETN
U.S.G.S. QUADRANGLE MAP
QUADRANGLE
7.5 MINUTE SERIES (TOPOGRAPHIC)
CHARLOTTE EAST, NORTH CAROLINA 1991
TITLE
PROJECT
SITE LOCATION MAP
CHARLOTTE SALVAGE COMPANY300 RAMPART STREET CHARLOTTE, NORTH CAROLINA
DATE:
JOB NO:
REVISION NO:
FIGURE:
8-23-2019 0
1JMC-007
SITE
REVISION NO. 0
JOB NO. JMC-009
DATE: 12-10-19
FIGURE NO. 2
CHARLOTTE SALVAGE COMPANY
300 RAMPART STREET
CHARLOTTE, NORTH CAROLINA
SAMPLE LOCATION MAP
LEGEND
SITE PROPERTY BOUNDARY
PARCEL BOUNDARY
TEMPORARY MONITORING WELL AND SOIL
BORING LOCATION
SOIL BORING LOCATION (H&H; 2019)
SOIL BORING LOCATION (ARCADIS; 2012)
SUB-SLAB VAPOR SAMPLE LOCATION
SOIL GAS SAMPLE LOCATION
FLOOR DRAIN
DUMPSTER
POLE-MOUNTED TRANSFORMER
2923 South Tryon Street-Suite 100
Charlotte, North Carolina 28203
704-586-0007(p) 704-586-0373(f)
License # C-1269 / #C-245 Geology
RAMPART ST
R
E
E
T
RAMPART S
T
R
E
E
T
HAW
KI
N
S
S
T
R
E
E
T
HAW
KI
N
S
S
T
R
E
E
TS. TRYON STREETS.TRYON STREETTHE PENROSE APARTMENTS / FORMER
VCC CHARLOTTE (349 W. TREMONT AVENUE)
THE PENROSE APARTMENTS / FORMER
VCC CHARLOTTE (349 W. TREMONT AVENUE)
VACANT
(2129 S. TRYON STREET)
VACANT
(2129 S. TRYON STREET)
K9 PLAYLAND
(2139 S. TRYON STREET)
K9 PLAYLAND
(2139 S. TRYON STREET)
MUTLI-TENANT COMMERCIAL BUILDINGS
(2204-2228 HAWKINS STREET)
MUTLI-TENANT COMMERCIAL BUILDINGS
(2204-2228 HAWKINS STREET)
KEG N CUE
(2131 S. TRYON STREET)
KEG N CUE
(2131 S. TRYON STREET)
MAACO FLEET SOLUTIONS
(2217 S. TRYON STREET)
MAACO FLEET SOLUTIONS
(2217 S. TRYON STREET)
NOTES:
1. AERIAL IMAGERY OBTAINED FROM MECKLENBURG
COUNTY GIS (2019).
GMI
(222 RAMPART STREET)
GMI
(222 RAMPART STREET)
APPROXIMATE LOCATION
OF INK SPILL
SGP-1
TMW-3/SB-7
SB-6
SSV-3
SB-5
SB-4
SSV-2
SB-3
SSV-1
TMW-1
SB-1
TMW-2/SB-2
APPROXIMATE LOCATION
OF PAINT SPLATTER
SB-8
CH-SB-97
CH-SB-98
CH-SB-90
CH-SB-91
CH-SB-92
CH-SB-93
CH-SB-94
CH-SB-95
SSV-4
SSV-5
S:\AAA-Master Projects\JMC Holdings\JMC.007 300 Rampart ESA\Figures\Site Map.dwg, FIG 2 121019, 12/10/2019 8:49:30 AM, sperry

Appendix A
Site Plans – Phase I Development

Appendix B Construction Schedule
IDTask ModeTask NameDuration Start Finish1MILESTONES177 daysFri 3/27/20Fri 12/4/202Obtain Site Development Permit1 dayFri 3/27/20Fri 3/27/203Record Brownfield Agreement1 dayThu 5/14/20Thu 5/14/204Obtain Building Permits1 dayMon 6/8/20Mon 6/8/205Substantial Completion1 dayFri 12/4/20Fri 12/4/206BROWNFIELDS APPLICATION PROCESS155 daysFri 10/4/19Thu 5/14/207Receive Letter of Eligibility1 dayFri 10/4/19Fri 10/4/198Issue Brownfields Assessment Report1 dayMon 10/7/19Mon 10/7/199DEQ Kick-Off Meeting12 daysTue 10/8/19Wed 10/23/1910DEQ Request for Additional Assessment9 daysThu 10/24/19Tue 11/5/1911Prepare Brownfields Additional Assessment Work Plan7 daysWed 11/6/19Thu 11/14/1912DEQ Review & Approval of Add'l Assessment Work Plan2 daysFri 11/15/19Mon 11/18/1913Perform Additional Testing & Submit Report to DEQ35 daysTue 11/19/19Mon 1/13/2014DEQ Review of Additional Assessment Testing15 daysTue 1/14/20Mon 2/3/2015DEQ Preparation of Brownfields Agreement20 daysTue 2/4/20Mon 3/2/2016Brownfields Agreement Negotiation20 daysTue 3/3/20Mon 3/30/2017Finalize Plat Map According to Agreement5 daysTue 3/31/20Mon 4/6/2018Receive Written Approval from DEQ to Proceed w/ Public Notice& Pay Final Fee1 dayTue 4/7/20Tue 4/7/201930 Day Public Comment Period22 daysWed 4/8/20Thu 5/7/2020Execute and Record Final Platt & Agreement5 daysFri 5/8/20Thu 5/14/2021Complete EMP20 daysTue 12/3/19Thu 1/2/2022DEQ Review & Approval of EMP15 daysFri 1/3/20Thu 1/23/2023CIVIL DESIGN / PERMIT97 daysThu 11/7/19Fri 3/27/2024Complete Topographic Survey1 dayThu 11/7/19Thu 11/7/1925Complete 50% Drawings20 daysFri 11/8/19Mon 12/9/1926Review & Pricing10 daysFri 11/15/19Mon 12/2/1927Complete Permit Drawings30 daysTue 12/3/19Thu 1/16/2028Submit for Permit20 daysFri 1/17/20Thu 2/13/2029Respond to First Round Comments5 daysFri 2/14/20Thu 2/20/2030Resubmit for Permit20 daysFri 2/21/20Thu 3/19/2031Respond to Second Round Comments5 daysFri 3/20/20Thu 3/26/2032Obtain Permit1 dayFri 3/27/20Fri 3/27/2033BUILDING DESIGN & PERMIT150 daysMon 11/4/19Mon 6/8/2034Complete As-Built & Model15 daysMon 11/4/19Fri 11/22/1935Complete 50% Drawings30 daysTue 12/3/19Thu 1/16/2036Owner Review / Contractor Pricing10 daysFri 1/17/20Thu 1/30/2037Complete 90% Drawings20 daysFri 1/31/20Thu 2/27/2038Owner Review / Contractor Pricing10 daysFri 2/28/20Thu 3/12/2039Complete Construction Drawings10 daysFri 3/13/20Thu 3/26/2040Submit for Permit20 daysFri 3/27/20Thu 4/23/2041Respond to First Round Comments5 daysFri 4/24/20Thu 4/30/2042Resubmit for Permit20 daysFri 5/1/20Fri 5/29/2043Respond to Second Round Comments5 daysMon 6/1/20Fri 6/5/2044Obtain Permit1 dayMon 6/8/20Mon 6/8/2045CONSTRUCTION229 daysTue 1/14/20Thu 12/3/2046Interior Demolition5 daysTue 1/14/20Mon 1/20/2047Exterior Demolition20 daysTue 6/9/20Mon 7/6/2048Structural Repairs20 daysTue 7/7/20Mon 8/3/2049Install Sub Grade Utilities20 daysTue 7/7/20Mon 8/3/2050Install New Roof15 daysTue 8/4/20Mon 8/24/2051Install Windows20 daysTue 8/4/20Mon 8/31/2052Site Work40 daysTue 9/1/20Tue 10/27/2053Landscaping5 daysWed 10/28/20Tue 11/3/2054Paint10 daysTue 9/1/20Tue 9/15/2055MEP Trim Out20 daysTue 8/25/20Tue 9/22/2056Inspections20 daysWed 11/4/20Thu 12/3/2012/44/711/712/91/16JulAugSepOctNovDecJanFebMarAprMayJunJulAugSepOctNovDec2020TaskSplitMilestoneSummaryProject SummaryInactive TaskInactive MilestoneInactive SummaryManual TaskDuration-onlyManual Summary RollupManual SummaryStart-onlyFinish-onlyExternal TasksExternal MilestoneDeadlineCriticalCritical SplitProgressManual Progress300 RampartUPDATED Fri 1/10/20 Page 1