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HomeMy WebLinkAbout23056 Affordable Custom Iron EMP Ver 2 202009021 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: 11/14/2019 Revision Date (if applicable): 09/02/2020 Brownfields Assigned Project Name: Affordable Custom Iron (RN) Brownfields Project Number: 23056-19-060 Brownfields Property Address: EMP is for Parcel 2A as described on Exhibit A to the Brownfields Property Application, located within Mecklenburg County Parcel No. 14901239 3804 South Boulevard, Charlotte, Mecklenburg County, North Carolina Brownfields Property Area (acres): 3.872 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): CC LoSo Station, LLC Contact Person: Michael Tubridy Phone Numbers: Office: 980-321-6247 Mobile: Click or tap here to enter text. Email: mtubridy@crescentcommunities.com Contractor for PD: Crescent Communities Contact Person: Shep Reynolds Phone Numbers: Office: : 980-321-6238 Mobile: 704-621-2660 Email: sreynolds@crescentcommunities.com Environmental Consultant: ECS Southeast, LLP Contact Person: Joseph P. Nestor Phone Numbers: Office: 704-525-5152 Mobile: 704-280-7422 Email: jnestor@ecslimited.com Brownfields Program Project Manager: William L. Schmithorst Phone Numbers: Office: 919-707-8159 Mobile: Click or tap here to enter text. Email: William.Schmithorst@ncdenr.gov 4 EMP Version 2, June 2018 Other DEQ Program Contacts (if applicable, i.e., UST Section, Inactive Hazardous Site Branch, Hazardous Waste, Solid Waste): David Ramey - Inactive Hazardous Site Branch Joselyn Harriger, Brownfields Program, Property Management Unit, joselyn.harriger@ncdenr.gov 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: Parking. Open space for public parks. 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 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): 5 EMP Version 2, June 2018 Provide brief summary of redevelopment plans, including demolition, removal of building slabs/pavement, grading plans and planned construction of new structures: The project site is located just off the Scaleybark Station of the Lynx Blue Line, the parcel of land is part of the LoSo Station Development. Two type IIIA construction, R-2 multi-family buildings consisting of a 343 residential units and a Type IA precast parking garage with 900+ parking spaces. Due to the need to commence construction on the parking deck portion of the Brownfields Property promptly after approval of the EMP to meet construction deadlines, preparation and approval of sampling proposals and results will need to be closely coordinated among the PD, the EP, and the Brownfields Program. PD proposes submitting one or more work plans prior to commencing construction activities on any portion of the property for review and approval by the Brownfields Project Manager. Upon approval, PD may implement the sampling contemplated by such plans, and report the results of sampling to the Brownfields Project Manager. In order to avoid conflicts with the construction schedule, the EP may submit tabulated data and figures to the Brownfields Project Manager to solicit the Project Manager's approval, to be followed up by a complete report. Construction may not begin in the area covered by a work plan until the Brownfields Project Manager has reviewed and approved the results of sampling. A complete set of plans may be accessed from the following link: Click to download 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 6 EMP Version 2, June 2018 7)Schedule for Redevelopment (attach construction schedule): a)Construction start date: 1/1/2020 b)Anticipated duration (specify activities during each phase): Construction of the parking garage portion of the development will be initiated in January 2020, with a goal of completion in July 2021. The remaining construction will be initiated as resources allow. All site work is anticipated to take approximately 23 months. c)Additional phases planned? ☐☐☐☐ Yes ☐☐☐☐ No If yes, specify the start date and/or activities if known: Start Date: Click or tap to enter a date. Planned Activity: Click or tap here to enter text. 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: Temporary Certificate of Occupancy anticipated Spring 2021 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): Updated 09-02-2020 Metals: Arsenic was detected in a sample collected from boring SS-3 on January 23, 2006 at 42 milligrams per kilogram (mg/kg) at 0.5 feet below ground surface (bgs) and from boring SS-3B at 6.5 mg/kg at 2 feet bgs. Samples were collected from soil borings SB-1 through SB-10 on March 20, 2020 as part of the Brownfields Assessment indicated the presence of arsenic at concentrations ranging from 1.3 to 52.7 mg/kg. With the exception of the sample from boring SB-9 at 4 feet bgs, the concentrations appeared to be within the expected range of naturally-occurring arsenic for this area. The arsenic concentration associated with boring SB-9 was 52.7 mg/kg. The next highest detection of arsenic for the samples collected on March 20, 2020 was 5.4 mg/kg and was associated with a sample collected from soil boring SB-5 at 3-5 feet bgs. The cadmium concentration detected in a sample collected on March 20, 2020 from boring SB-9 at a depth of 4 feet bgs was 54.6 mg/kg. The selenium concentration detected in a sample collected on March 20, 2020 from boring SB-9 at a depth of 4 feet bgs was 49.5 mg/kg. Hexavalent chromium was detected in soil samples collected over the depth interval 3-5 feet bgs on March 20, 2020. The soil borings from which these samples were collected and the detected concentration of hexavalent chromium are as follows: SB-3 (0.374 mg/kg), SB-7 (0.414 mg/kg), and SB-8 (0.423 mg/kg). The laboratory reported that hexavalent chromium was not detected above the method detection limit (MDL) in in soil samples collected over the depth interval 3-5 feet bgs from soil borings SB-1, SB-2, SB-4,, SB-5, or SB-6; a soil sample collected at a depth of 4 feet from soil boring SB-9; or a soil sample collected at a depth of 2 feet from soil boring SB-10. The MDL ranged from 1.15 to 1.36 mg/kg and exceeded the residential PSRG of 0.31 mg/kg. SVOCs: Benzo(a)pyrene and dibenzo(a,h)anthracene were reported above remediation goals at 12 feet bgs in TP-1 The soil showing these impacts were reported to be excavated and confirmation samples did not indicate exceedences. VOCs: Carbon Tetrachloride was detected from boring SS-3 at 2,200 mg/kg at 0.5 feet bgs in 2006. The soil showing these impacts were reported to be excavated in 2007 and confirmation samples also collected in 2007 did not indicate exceedences. 8 EMP Version 2, June 2018 2)Depth of known or suspected contaminants (feet): Updated 09-02-2020 Between 0.5 feet, 2 feet, 4 feet, 3-5 feet, and 12 feet bgs near the former Affordable Custom Iron property. 3)Area of soil disturbed by redevelopment (square feet): Approximately 170,000 square feet 4)Depths of soil to be excavated (feet): Generally less than two (2) feet, however, foundation work may extend to greater depths in some areas. 5)Estimated volume of soil (cubic yards) to be excavated (attach grading plan): Updated 09-02-2020 This is a balanced site in terms of net import/export for site grading. Grading plans for the South, Central and North portions of the Brownfields site are attached. Some soil may be excavated during installation of utilities and the construction of foundation systems. The quantity of soil to be excavated is estimated to be less than 2,000 cubic yards. Soil which was placed around walls for subsurface portion of parking deck were determined to be unsuitable from a geotechnical perspective. Up to 11,000 cubic yards of such soil may be generated. Spoils from the installation of foundation piers may produce material which is unsuitable from a geotechnical perspective. Up to 1,000 cubic yards may be produced from the installation of these piers. Soil from excavation foundation footers may be unsuitable from a geotechnical perspective. Up to 2,000 cubic yards of such soil may be generated. 6)Estimated volume of excavated soil (cubic yards) anticipated to be impacted by contaminants: Zero (0) cubic yards. There is no data indicating soil contamination remains. 7)Estimated volume of contaminated soil expected to be disposed of offsite, if applicable: There is no data indicating soil contamination remains so this section is not applicable. 9 EMP Version 2, June 2018 Part 1.A. MANAGING ONSITE SOIL If soil is anticipated to be excavated from the Brownfield Property, relocated on the Brownfields Property, or otherwise disturbed during site grading or other redevelopment activities, please provide a grading plan that clearly illustrates areas of cut and fill (approximate areas & volumes are acceptable, if only preliminary data available). 1) HAZARDOUS WASTE DETERMINATION: a) Does the soil contain a LISTED WASTE as defined in the North Carolina Hazardous Waste Section under 40 CFR Part 261.31-261.35?....................................... ☐☐☐☐Yes ☒☒☒☒No ☐☐☐☐ If yes, explain why below, including the level of knowledge regarding processes generating the waste (include pertinent analytical results as needed). Click or tap here to enter text. ☐☐☐☐ If yes, do the soils exceed the “Contained-Out” levels in Attachment 1 of the North Carolina Contained-In Policy?................................................. ☐☐☐☐ Yes ☒☒☒☒ No b) NOTE: IF SOIL MEETS THE DEFINITION OF A LISTED HAZARDOUS WASTE AND EXCEEDS THE CONTAINED-OUT LEVELS IN ATTACHMENT 1 TO THE NORTH CAROLINA CONTAINED-IN POLICY THE SOIL MAY NOT BE RE-USED ON SITE AND MUST BE DISPOSED OF IN ACCORDANCE WITH DEQ HAZARDOUS WASTE SECTION RULES AND REGULATIONS. c) Does the soil contain a CHARACTERISTIC WASTE?.................................... ☐☐☐☐ Yes ☒☒☒☒ No ☐☐☐☐ If yes, mark reason(s) why below (and include pertinent analytical results). ☐☐☐☐ Ignitability Click or tap here to enter text. ☐☐☐☐ Corrosivity Click or tap here to enter text. ☐☐☐☐ Reactivity Click or tap here to enter text. ☐☐☐☐ Toxicity Click or tap here to enter text. ☐☐☐☐ TCLP results Click or tap here to enter text. ☐☐☐☐ 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: Rule of 20 Results for VOCs, SVOCs, and metals and professional judgment for ignitability, corrosivity, reactivity, and toxicity. 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. 10 EMP Version 2, June 2018 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: If field observations suggest contamination which was not previously noted, samples will be collected and analyzed and screening criteria will be applied. 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: Hardscaping or two (2) feet of clean fill will be placed over areas of known surficial contamination. ☒☒☒☒ 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: Click or tap here to enter text. 11 EMP Version 2, June 2018 PD will use typical construction measures involving a water truck spray as necessary to address visible dust. ☐☐☐☐ No, explain rationale: Click or tap here to enter text. Field Screening of site soil ☒☒☒☒ Yes, describe the field screening method, frequency of field screening, person conducting field screening: Soil will be monitored via human sensory observations including visual observations of staining, debris, or indications of fill and olafactory observations for unusual odors. These observations can be augmented with photoionization detector (PID) to evaluate VOC presence as needed during soil excavation activities at the site. The contractor will be instructed to contact ECS should field observations suggest the presence of impacts. Field instrument screening of excavated soils will occur on an as needed basis while excavation is occurring and will be more frequent in areas of suspected impacts. ☐☐☐☐ No, explain rationale: Click or tap here to enter text. Soil Sample Collection ☒☒☒☒ Yes, describe the sampling method (e.g., in-situ grab, composite, stockpile, etc.): Due to the need to commence construction on the parking deck portion of the Brownfields Property promptly after approval of the EMP to meet construction deadlines, preparation and approval of sampling proposals and results will need to be closely coordinated among the PD, the EP, and the Brownfields Program. PD proposes submitting one or more work plans prior to commencing construction activities on any portion of the property for review and approval by the Brownfields Project Manager. Upon approval, PD may implement the sampling contemplated by such plans, and report the results of sampling to the Brownfields Project Manager. In order to avoid conflicts with the construction schedule, the EP may submit tabulated data and figures to the Brownfields Project Manager to solicit the Project Manager's approval, to be followed up by a complete report. Construction may not begin in the area covered by a work plan until the Brownfields Project Manager has reviewed and approved the results of sampling. ☐☐☐☐ No, explain rationale: Click or tap here to enter text. If soil samples are collected for analysis, please check the applicable chemical analytes: ☒☒☒☒ Volatile organic compounds (VOCs) by EPA Method 8260 ☒☒☒☒ Semi-volatile organic compounds (SVOCs) by EPA Method 8270 12 EMP Version 2, June 2018 ☒☒☒☒ Metals RCRA List (8) (arsenic, barium, cadmium, chromium, mercury, lead, selenium and silver): Specify Analytical Method Number(s): Click or tap here to enter text. ☐☐☐☐ Pesticides: Specify Analytical Method Number(s): Click or tap here to enter text. ☐☐☐☐ PCBs: Specify Analytical Method Number(s): Click or tap here to enter text. ☐☐☐☐ Other Constituents & Respective Analytical Method(s) (i.e. Hexavalent Chromium, Herbicides, etc.): Specify Analytical Method Number(s): Click or tap here to enter text. ☒☒☒☒ Check to confirm that stockpiling of known or suspected impacted soils will be conducted in accordance with Figure 1 of this EMP. Stockpile methodology should provide erosion control, prohibiting contact between surface water/precipitation and contaminated soil, and preventing contaminated runoff. Explain any variances or provide additional details as needed: ☒☒☒☒ 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 Method 6020 ☐☐☐☐ 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.): Updated 09-02-2020 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. Click or tap here to enter text. 13 EMP Version 2, June 2018 Work plan to be submitted under separate cover. ☐☐☐☐ If final grade sampling was NOT selected please explain rationale: Click or tap here to enter text. Part 1.B. IMPORTED FILL SOIL NO SOIL MAY BE BROUGHT ONTO THE BROWNFIELDS PROPERTY WITHOUT PRIOR APPROVAL FROM THE BROWNFIELDS PROGRAM. According to the Brownfields IR 15, “Documenting imported soil (by sampling, analysis, and reporting in accordance with review and written approval in advance by the Brownfields Program), will safeguard the liability protections provided by the brownfields agreement and is in the best interest of the prospective developer/property owner.” Requirements for importing fill: 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? Updated 09-02-2020 PD Anticipates up to 7,000 cubic yards of fill soil will be imported to site. 3)If yes, what is the anticipated depth that fill soil will be placed at the property? (If a range of depths, please list the range.) Updated 09-02-2020 0 to 12 feet bgs 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: Updated 09-02-2020 Fill soil will be imported from other Brownfield sites, barrow sources, or Martin Marietta quarry on Beatties Ford Road in Charlotte, North Carolina and/or the Vulcan Materials quarry in Pineville, Carolina. 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. Updated 09-02-2020 If soil is to be imported from another Brownfields site, samples will be collected from the source at that site at a frequency of at least one sample per each 1,000 cubic yard lot of soil to be imported. Samples will be analyzed for VOCs by EPA Method 8260, SVOCs by EPA Method 8270, RCRA metals by EPA Method 6010/7471, hexavalent chromium by EPA Method 7199, and 14 EMP Version 2, June 2018 possibly other parameters depending upon contaminants previously detected at the particular Brownfields site. Composite samples comprised of 3 to 5 individual samples will be analyzed for SVOCs, RCRA metals, and hexavalent chromium. Grab samples corresponding to the highest PID reading for the individual samples will be selected for VOC analysis for each lot. A summary of sample collection methods, locations of samples, and results will be provided to NCBP with a request to approve the transfer of soil. Soil will be transferred after NCBP approval is received. If soil is to be imported from a barrow source, a sampling work plan will be prepared and submitted to NCBP. A history of the barrow source will be provided in the work plan. The work plan will stipulate that samples will be collected from the barrow source at a frequency of at least one sample per each 1,000 cubic yard lot of soil to be imported. The locations, depths, and methods of sample collection will be specified in the work plan. Samples will be analyzed for VOCs by EPA Method 8260, SVOCs by EPA Method 8270, RCRA metals by EPA Method 6010/7471, hexavalent chromium by EPA Method 7199, and possibly other parameters depending upon the history of the barrow source. The work plan will be implemented upon approval by NCBP. Following receipt of analytical results, a summary report including sample collection methods, locations of samples, and results will be provided to NCBP with a request to approve the transfer of soil. Soil will be transferred after NCBP approval is received. If fill material is imported from either Martin Marietta quarry on Beatties Ford Road in Charlotte, North Carolina or the Vulcan Materials quarry in Pineville, Carolina, the soil to be imported will be virgin material and not part of a recycling program at either quarry. Virgin materials from these two quarries have been pre-approved by NCBP as sources of fill soil. Since material to be imported from these two quarries has been pre-approved by NCBP and it will not be necessary to prepare a sampling work plan.. 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): Click or tap here to enter text. ☐☐☐☐ Pesticides: Specify Analytical Method Number(s): Click or tap here to enter text. ☐☐☐☐ PCBs: Specify Analytical Method Number(s): 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 7) The scope of work for import fill sampling may be provided below or in a Work Plan 15 EMP Version 2, June 2018 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. Updated 09-02-2020 If soil is to be imported from another Brownfields site, samples will be collected from the source at that site at a frequency of at least one sample per each 1,000 cubic yard lot of soil to be imported. Samples will be analyzed for VOCs by EPA Method 8260, SVOCs by EPA Method 8270, RCRA metals by EPA Method 6010/7471, hexavalent chromium by EPA Method 7199, and possibly other parameters depending upon contaminants previously detected at the particular Brownfields site. Composite samples comprised of 3 to 5 individual samples will be analyzed for SVOCs, RCRA metals, and hexavalent chromium. Grab samples corresponding to the highest PID reading for the individual samples will be selected for VOC analysis for each lot. A summary of sample collection methods, locations of samples, and results will be provided to NCBP with a request to approve the transfer of soil. Soil will be transferred after NCBP approval is received. If soil is to be imported from barrow source, a sampling work plan will be prepared and submitted to NCBP. A history of the a barrow source will be provided in the work plan. The work plan will stipulate that samples will be collected from the barrow source at a frequency of at least one sample per each 1,000 cubic yard lot of soil to be imported. The locations, depths, and methods of sample collection will be specified in the work plan. Samples will be analyzed for VOCs by EPA Method 8260, SVOCs by EPA Method 8270, RCRA metals by EPA Method 6010/7471, hexavalent chromium by EPA Method 7199, and possibly other parameters depending upon the history of the barrow source. The work plan will be implemented upon approval by NCBP. Following receipt of analytical results, a summary report including sample collection methods, locations of samples, and results will be provided to NCBP with a request to approve the transfer of soil. Soil will be transferred after NCBP approval is received. If fill material is imported from either Martin Marietta quarry on Beatties Ford Road in Charlotte, North Carolina or the Vulcan Materials quarry in Pineville, Carolina, the soil to be imported will be virgin material and not part of a recycling program at either quarry. Virgin materials from these two quarries have been pre-approved by NCBP as sources of fill soil. Since material to be imported from these two quarries has been pre-approved by NCBP and it will not be necessary to prepare a sampling work plan.. 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 16 EMP Version 2, June 2018 additional details. 1) If export from a Brownfields Property is anticipated, please provide details regarding the proposed export actions. Volume of exported soil, depths, location from which soil will be excavated on site, related sampling results, etc. Provide a site map with locations of export and sampling results included. Excavated soil will be reused to the extent reasonably possible on the site; however, some of this excavated soil may not be suitable for reuse due to geotechnical properties and may be exported from the site. Revised 09-02-2020 PD estimates that up to 2,000 15,000 cubic yards of soil may be exported from the site. PD does not anticipate export of contaminated soil from the site, although Sampling pursuant to work plans approved by the Brownfields Program will determine the destination of any necessary exported soil.If soil is taken to a Subtitle D landfill, pre-approval from the NCBP will not be obtained. If soil is taken to other destinations, pre-approval from NCBP will be obtained. 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). Click or tap here to enter text. Part 1.D. MANAGEMENT OF UTILITY TRENCHES ☐☐☐☐ Install liner between native impacted soils and base of utility trench before filling with clean fill 17 EMP Version 2, June 2018 (Preferred) ☒☒☒☒ Last out, first in principle for impacted soils (if soil can safely be reused onsite and is not a hazardous waste), i.e., impacted soils are placed back at approximately the depths they were removed from such that impacted soil is not placed at a greater depth than the original depth from which it was excavated. ☐☐☐☐ Evaluate whether necessary to install barriers in conduits to prevent soil vapor transport, and/or degradation of conduit materials due to direct impact with contaminants? ☐☐☐☐ If yes, provide specifications on barrier materials: Click or tap here to enter text. ☐☐☐☐ If no, include rationale here: Click or tap here to enter text. Other comments regarding managing impacted soil in utility trenches: Click or tap here to enter text. PART 2. GROUNDWATER – Please fill out the information below. 1) What is the depth to groundwater at the Brownfields Property? Estimated at approximately 15 feet. 2) Is groundwater known to be contaminated by ☐☐☐☐onsite ☐☐☐☐offsite ☐☐☐☐both or ☒☒☒☒unknown sources? Describe source(s): Click or tap here to enter text. 3) What is the direction of groundwater flow at the Brownfields Property? The presumed groundwater flow is towards the northwest into Irwin Creek watershed. 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). In the event that groundwater is encountered, it would likely be limited to relatively small quantities and deep utilities. If encountered, water would be displaced in the excavation and/or pumped into a tanker truck, frac tank or other container approved by the EP. Sampling and analysis would be conducted as needed to characterize the water for disposal purposes based on the requirements of the disposal facility. 18 EMP Version 2, June 2018 5)Are monitoring wells currently present on the Brownfields Property?.................☐Yes ☒☒☒☒No If yes, are any monitoring wells routinely monitored through DEQ or other agencies?..................................................................................................................☐Yes ☒☒☒☒No 6)Please check methods to be utilized in the management of known and previously unidentified wells. ☐☐☐☐ Abandonment of site monitoring wells in accordance with all applicable regulations. It is the Brownfields Program’s intent to allow proper abandonment of well(s) as specified in the Brownfields Agreement, except if required for active monitoring through another section of DEQ or the EPA. ☐☐☐☐ Location of existing monitoring wells marked ☐☐☐☐ Existing monitoring wells protected from disturbance ☒☒☒☒ Newly identified monitoring wells will be marked and protected from further disturbance until notification to DEQ Brownfields can be made and approval for abandonment is given. 7) Please provide additional details as needed: Please note, disturbance of existing site monitoring wells without approval by DEQ is not permissible. If monitoring wells are damaged and/or destroyed, DEQ may require that the PD be responsible for replacement of the well. PART 3. SURFACE WATER -Please fill out the information below. 1)Is surface water present at the property?☐☐☐☐ Yes ☒☒☒☒ No 2)Attach a map showing the location of surface water at the Brownfields Property. 3)Is surface water at the property known to be contaminated?☐☐☐☐ Yes ☒☒☒☒ No 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): In the event that contaminated surface water is encountered during redevelopment activities, or clean surface water enters open excavations, it will be allowed to infiltrate into the ground and/or containerized and managed in accordance with local, state, and federal regulations. Click or tap here to enter text. 19 EMP Version 2, June 2018 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): Not applicable 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: The contractor will be instructed that in the event contaminated soil vapors are encountered during redevelopment activities, the area will be evacuated and appropriate safety screening of the vapors will be performed. If results indicate further action is required, appropriate engineering controls will be implemented. Three (3) feet at one sample point. 20 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: Not Applicable 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 The contractor will be instructed that in the event contaminated soil vapors are encountered during redevelopment activities, the area will be evacuated and appropriate safety screening of the vapors will be performed. If results indicate further action is required, appropriate engineering controls 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: 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: Click or tap here to enter text. Click or tap here to enter text. 21 EMP Version 2, June 2018 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: A comprehensive soil gas assessment was performed at the site in September 2019 (Reported in Report dated October 10, 2019 by Draper Aden Associates). Soil gas samples were collected for 37 sample points across the site. One exceedance above residential PSRGs was noted (27.8 µg/m3 naphthalene at PSG-27 above residential PSRG of 21 µg/m3). When data was input into the NCDEQ risk calculator, unacceptable risks were not indicated. It should be noted that conservative data was used as input (highest concentration of each analyte detected and the method detection limit as inputs for daughter products of tetrachlorethene and carbon tetrachloride [although such daughter products were not detected]). 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 Method 6020 ☐☐☐☐ 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 & Analytical Method(s) (i.e. Hexavalent Chromium, Herbicides, etc.) Please note, if field observations indicate the need for additional analyses, they should 22 EMP Version 2, June 2018 be conducted, even if not listed here. Click or tap here to enter text. Please provide details on the proposed methods of managing the following commonly encountered issues during redevelopment of Brownfields Properties. Click or tap here to enter text. Underground Storage Tanks: If encountered, the contents of the UST will be evaluated, and based on the contents; the UST will be removed or closed in place. Brownfields Project Manager approval will be obtained before closing in place. If UST is removed, soil samples will be collected (one per 10 feet length of UST) from the base of the UST excavation and submitted for laboratory analysis of VOCs, SVOCS, and RCRA Metals. Sub-Grade Feature/Pit: If encountered, the contents of the pit and the pit itself will be removed. Soil samples will be collected from the base of the pit excavation and submitted for laboratory analysis of VOCs, SVOCs, and RCRA Metals. Buried Waste Material: If encountered, the waste will be removed, characterized, and disposed of off-site. Soil samples will be collected from the base and side-walls (one for every 10 feet of base/side-wall) of the excavated material and submitted for laboratory analysis of VOCs, SVOCs, and RCRA Metals. Re-Use of Impacted Soils On-Site: If impacted soil is encountered during redevelopment activities and is able to be reused onsite based on geotechnical characteristics, the soil will remain in place and the plat will be updated to include the location and depth of impacted soil. If unknown, impacted soil is identified on-site, management on-site can be considered after the project team provides the necessary information, outlined in Part 1.A. Item 11, for Brownfields Project Manager approval prior to final placement on-site. If other potential contingency plans are pertinent, please provide other details or scenarios as needed below: Click or tap here to enter text. POST-REDEVELOPMENT REPORTING ☒☒☒☒ Check this box to acknowledge that a Redevelopment Summary Report will be required for the project. If the project duration is longer than one year, an annual update is required and will be due by January 31 of each year, or 30 days after each one-year anniversary of the effective date of 23 EMP Version 2, June 2018 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; 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. 25 EMP Version 2, June 2018 SELECTED EXCERPTS FROM CONSTRUCTION PLANS PRELIMINARY – SUBJECT TO CHANGE PENDING REVIEW BY CHARLOTTE- MECKLENBURG PLAN REVIEW PRELIMINARY – SUBJECT TO CHANGE PENDING REVIEW BY CHARLOTTE- MECKLENBURG PLAN REVIEW PRELIMINARY – SUBJECT TO CHANGE PENDING REVIEW BY CHARLOTTE- MECKLENBURG PLAN REVIEW PRELIMINARY – SUBJECT TO CHANGE PENDING REVIEW BY CHARLOTTE- MECKLENBURG PLAN REVIEW PRELIMINARY – SUBJECT TO CHANGE PENDING REVIEW BY CHARLOTTE- MECKLENBURG PLAN REVIEW PRELIMINARY – SUBJECT TO CHANGEPENDING REVIEW BY CHARLOTTE- MECKLENBURG PLAN REVIEW PRELIMINARY – SUBJECT TO CHANGEPENDING REVIEW BY CHARLOTTE- MECKLENBURG PLAN REVIEW TABLES FROM PREVIOUS ENVIRONMENTAL CONSULTING REPORTS sKƐďLJWDĞƚŚŽĚϴϮϲϬ^sKƐďLJWDĞƚŚŽĚϴϮϳϬZZDĞƚĂůƐďLJWDĞƚŚŽĚϲϬϭϬͬϳϰϳϭͬϳϭϵϵĐĞƚŽŶĞůůŽŵƉŽƵŶĚƐƌƐĞŶŝĐĂƌŝƵŵĂĚŵŝƵŵdƌŝǀĂůĞŶƚŚƌŽŵŝƵŵ,ĞdžĂǀĂůĞŶƚŚƌŽŵŝƵŵ>ĞĂĚDĞƌĐƵƌLJ^ĞůĞŶŝƵŵ^ŝůǀĞƌWƌŽƚĞĐƚŝŽŶŽĨ'ƌŽƵŶĚǁĂƚĞƌW^Z'ϮϱsĂƌŝŽƵƐ ϱ͘ϴ ϱϴϬ ϯ͘Ϭ ϯϲϬ͕ϬϬϬ ϯ͘ϴ ϮϳϬ ϭ͘ϬϮ͘ϭϯ͘ϰZĞƐŝĚĞŶƚŝĂůW^Z'ϭϮ͕ϬϬϬsĂƌŝŽƵƐ Ϭ͘ϲϴ ϯ͕ϭϬϬ ϭϰ Ϯϯ͕ϬϬϬ Ϭ͘ϯϭ E Ϯ͘ϯ ϳϴ ϳϴ/ŶĚƵƐƚƌŝĂůͬŽŵŵĞƌĐŝĂůW^Z'ϭϰϬ͕ϬϬϬsĂƌŝŽƵƐ ϯ͘Ϭ ϰϳ͕ϬϬϬ ϮϬϬ ϯϱϬ͕ϬϬϬ ϲ͘ϱ E ϵ͘ϳ ϭ͕ϮϬϬ ϭ͕ϮϬϬ^Ͳϭ ϬϯͬϮϬͬϮϬ ϯͲϱ Ϭ͘ϬϮϯ:ůůZ> ϭ͘ϯϳϲ͘ϳ Ϭ͘ϬϴϬ ϱϲ͘ϴфϭ͘ϭϳϭ͘ϮфϬ͘ϬϬϯϵ фϬ͘ϲϮ фϬ͘ϯϭ^ͲϮ ϬϯͬϮϬͬϮϬ ϯͲϱ Ϭ͘ϬϮϰ: ůůZ> Ϯ͘ϮϭϯϮ Ϭ͘ϭϰ ϰϱ͘Ϭфϭ͘ϮϲϮ͘ϭфϬ͘ϬϬϯϮ фϭ͘ϭ фϬ͘ϱϱ^Ͳϯ ϬϯͬϮϬͬϮϬ ϯͲϱ Ϭ͘ϬϱϬ: ůůZ>ϯ͘ϲϱϱ͘ϭфϬ͘ϭϬϮϭ͘Ϭ Ϭ͘ϯϳϰ:ϱ͘ϴ Ϭ͘ϬϱϬфϭ͘Ϭ фϬ͘ϱϭ^Ͳϰ ϬϯͬϮϬͬϮϬ ϯͲϱ Ϭ͘Ϭϭϳ: ůůZ> ϭ͘ϵϭϬϲ Ϭ͘Ϭϴϱ ϱϭ͘ϵфϭ͘ϭϴϳ͘ϴфϬ͘ϬϬϯϲ фϬ͘ϳϬ фϬ͘ϯϱ^Ͳϱ ϬϯͬϮϬͬϮϬ ϯͲϱ Ϭ͘Ϭϭϵ: ůůZ>ϱ͘ϰϰϭ͘ϱ Ϭ͘ϭϯ ϱϴ͘ϭфϭ͘Ϯϴϲ͘ϳ Ϭ͘ϭϳфϭ͘ϭ фϬ͘ϱϲ^Ͳϲ ϬϯͬϮϬͬϮϬ ϯͲϱ Ϭ͘ϬϮϱ: ůůZ>ϰ͘ϲϮϲ͘ϱ Ϭ͘Ϭϴϵ ϰϱ͘ϯфϭ͘ϯϲϳ͘ϰ Ϭ͘ϬϲϱфϬ͘ϳϱ фϬ͘ϯϳ^Ͳϳ ϬϯͬϮϬͬϮϬ ϯͲϱ Ϭ͘Ϭϭϴ: ůůZ>ϯ͘ϴϮϴ͘ϳ Ϭ͘Ϭϵϱ ϮϮ͘Ϯ Ϭ͘ϰϭϱ:ϭϴ͘ϳ Ϭ͘ϬϲϱфϬ͘ϳϰϬ͘ϵϬ^Ͳϴ ϬϯͬϮϬͬϮϬ ϯͲϱ Ϭ͘Ϭϲϴ: ůůZ> Ϯ͘ϭϱϰ͘Ϭ Ϭ͘ϭϮ ϰϭ͘ϲ Ϭ͘ϰϮϯ:Ϯ͘ϴ Ϭ͘ϬϭϰфϬ͘ϴϮ фϬ͘ϰϭ^Ͳϵ ϬϯͬϮϬͬϮϬ ϰ Ϭ͘ϬϱϮ: ůůZ>ϱϮ͘ϳϭϴϬϱϰ͘ϲϭϮϵфϭ͘ϭϱϱϯ͘ϭ Ϭ͘Ϭϭϯϰϵ͘ϱE^ͲϭϬ ϬϯͬϮϬͬϮϬ Ϯ Ϭ͘ϭϮ ůůZ>ϰ͘ϱϮϵ͘Ϯ Ϭ͘ϭϱ ϰϭ͘ϰфϭ͘ϭϵϳ͘ϲ Ϭ͘ϬϱϳфϬ͘ϵϮϬ͘ϱϴ^ͲhW ϬϯͬϮϬͬϮϬ ϯͲϱ Ϭ͘ϬϯϮ: ůůZ>ϯ͘ϴϯϴ͘ϱ Ϭ͘ϭϰ Ϯϰ͘Ϭ Ϭ͘ϱϬϲ:ϭϬ͘ϭ Ϭ͘Ϭϰϭ ϭ͘ϭ Ϭ͘ϲϲEŽƚĞƐ͗ůůƌĞƐƵůƚƐƉƌĞƐĞŶƚĞĚŝŶŵŝůůŝŐƌĂŵƐƉĞƌŬŝůŽŐƌĂŵƐ;ŵŐͬŬŐͿKŶůLJsKƐŽƌ^sKƐĚĞƚĞĐƚĞĚĂƌĞƐŚŽǁŶsKƐсsŽůĂƚŝůĞKƌŐĂŶŝĐŽŵƉŽƵŶĚƐ^sKƐс^ĞŵŝͲsŽůĂƚŝůĞKƌŐĂŶŝĐŽŵƉŽƵŶĚƐW^Z'сWƌĞůŝŵŝŶĂƌLJ^ŝƚĞZĞŵĞĚŝĂƚŝŽŶ'ŽĂůEсEŽƐƚĂŶĚĂƌĚĞƐƚĂďůŝƐŚĞĚZ>сĞůŽǁZĞƉŽƌƚŝŶŐ>ŝŵŝƚƐďŐƐсĞůŽǁ'ƌŽƵŶĚ^ƵƌĨĂĐĞ^ͲhWŝƐĂĚƵƉůŝĐĂƚĞƐĂŵƉůĞŽĨƐĂŵƉůĞ^Ͳϯ:сƐƚŝŵĂƚĞĚĐŽŶĐĞŶƚƌĂƚŝŽŶƐĚĞƚĞĐƚĞĚďĞƚǁĞĞŶůĂďŽƌĂƚŽƌLJŵĞƚŚŽĚƌĞƉŽƌƚŝŶŐůŝŵŝƚĂŶĚĚĞƚĞĐƚŝŽŶůŝŵŝƚs>h сĐŽŶĐĞŶƚƌĂƚŝŽŶŐƌĞĂƚĞƌƚŚĂŶůĂďŽƌĂƚŽƌLJŵĞƚŚŽĚƌĞƉŽƌƚŝŶŐůŝŵŝƚs>hсĐŽŶĐĞŶƚƌĂƚŝŽŶŐƌĞĂƚĞƌƚŚĂŶWƌŽƚĞĐƚŝŽŶŽĨ'ƌŽƵŶĚǁĂƚĞƌW^Z's>hсĐŽŶĐĞŶƚƌĂƚŝŽŶŐƌĞĂƚĞƌƚŚĂŶZĞƐŝĚĞŶƚŝĂůW^Z's>hсĐŽŶĐĞŶƚƌĂƚŝŽŶŐƌĞĂƚĞƌƚŚĂŶ/ŶĚƵƐƚƌŝĂůͬŽŵŵĞƌĐŝĂůW^Z'^ĂŵƉůĞĂƚĞ^ĂŵƉůĞ/dƌŝǀĂůĞŶƚŚƌŽŵŝƵŵĐŽŶĐĞŶƚƌĂƚŝŽŶĐĂůĐƵůĂƚĞĚďLJ΀dŽƚĂůŚƌŽŵŝƵŵĐŽŶĐĞŶƚƌĂƚŝŽŶͲ,ĞdžĂǀĂůĞŶƚŚƌŽŵŝƵŵĐŽŶĐĞŶƚƌĂƚŝŽŶ΁͖ǁŚĞƌĞ,ĞdžĂǀĂůĞŶƚŚƌŽŵŝƵŵǁĂƐŶŽƚĚĞƚĞĐƚĞĚĂďŽǀĞůĂďŽƌĂƚŽƌLJŵĞƚŚŽĚƌĞƉŽƌƚŝŶŐůŝŵŝƚ͕dŽƚĂůŚƌŽŵŝƵŵĐŽŶĐĞŶƚƌĂƚŝŽŶƉƌĞƐĞŶƚĞĚĂƐdƌŝǀĂůĞŶƚŚƌŽŵŝƵŵĞƉƚŚ/ŶƚĞƌǀĂů;ĨĞĞƚďŐƐͿUpdated 09-02-2020Table fromReport of Environmental Assessment April 29, 2020Prepared by ECS Southeast, LLP for CC Loso Station, LLC FIGURES FROM PREVIOUS ENVIRONMENTAL CONSULTING REPORTS FIGURE 3 SAMPLE LOCATION MAP Affordable Custom Iron North Carolina Brownfields No. 23056-19-060 CC LoSo Station 3804 South Boulevard Charlotte, Mecklenburg County, North Carolina ECS Project Number 49:10479-A SOURCE: Soil Gas Assessment Report October 10, 2019 Prepared by: Draper Aden Associates SG-1 SG-1 SG-3 SG-2 SG-4 SB-1 SB-2 SB-3 SB-4 SB-5 SB-6 SB-7 SB-8 SB-10 MW-1 MW-2 MW-3 Approximate Area of Excavation Reported in S&ME 2007 Closure Report SB-1 Soil Sampling Point from Boring Advanced to 5 Feet Below Grade with Sample Collected from 3 to 5 Feet Below Grade SB-9 Soil Sampling Point from Boring Advanced to 10 Feet Below Grade with Sample Collected from 2- Foot Interval Selected on the Basis of Filed Screening MW-1 Monitoring Well SB-9 Note: Locations of soil borings SB-1 , SB-6, and SB-5 were shifted northward relative to what was indicated in approved work plan. Location of soil boring SB-4 was shifted eastward relative to what was indicated in approved work plan. Location of soil boring SB-3 was shifted northeastward relative to what was indicated in approved work plan. The shifting of proposed locations was done to target soil which was being imported to site. Soil Gas Sampling Point Updated 09-02-2020 Figure from Report of Environmental Assessment April 29, 2020 Prepared by ECS Southeast, LLP for CC Loso Station, LLC