12033N Tryon EMP 20221012 Rev 1

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EMP Version 2, January 2021
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.

The EMP is valid only for the scope of work described herein and must be updated to be
applicable for new phases of redevelopment or after significant changes in applicable
regulatory guidance.

Voluntary Metrics Tab
The NC Brownfields Program updates estimated capital investment (from the Brownfields
Property Application) and estimated jobs created (from the Brownfields Agreement) whenever
possible. As a voluntary measure, you may opt to complete the below information for capital
investment and jobs created as estimated by your final redevelopment plans for the Brownfields
Property:

1. Estimated capital investment in redevelopment project: NA
2. Estimated jobs created:
a. Construction Jobs: NA
b. Full Time Post-Redevelopment Jobs: NA

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Table of Contents
NORTH CAROLINA BROWNFIELDS PROGRAM ENVIRONMENTAL MANAGEMENT PLAN ........................... 1
GENERAL INFORMATION ........................................................................................................................ 4
COMMUNICATIONS ................................................................................................................................ 4
NOTIFICATIONS TO THE BROWNFIELDS PROGRAM ............................................................................... 5
REDEVELOPMENT PLANS ........................................................................................................................ 5
CONTAMINATED MEDIA ......................................................................................................................... 7
PART 1. Soil ......................................................................................................................................... 7
PART 2. GROUNDWATER ................................................................................................................. 15
PART 3. SURFACE WATER .................................................................................................................. 17
PART 4. SEDIMENT ............................................................................................................................ 17
PART 5. SOIL VAPOR ......................................................................................................................... 17
PART 6. SUB‐SLAB SOIL VAPOR ........................................................................................................ 18
PART 7. INDOOR AIR ......................................................................................................................... 19
VAPOR INTRUSION MITIGATION SYSTEM ............................................................................................. 19
CONTINGENCY PLAN – encountering unknown tanks, drums, or other waste materials ..................... 20
POST‐REDEVELOPMENT REPORTING..................................................................................................... 21
APPROVAL SIGNATURES ....................................................................................................................... 23

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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.

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.

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☐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.
GENERAL INFORMATION
Date: 9/9/2022 Revision Date (if applicable): 10/12/2022
Brownfields Assigned Project Name: North Tryon Commercial
Brownfields Project Number: 12033-08-060
Brownfields Property Address: 2205-2221 and 2229 North Tyron Street, Charlotte, NC
Brownfields Property Area (acres): 5.03
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.: NA
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): Duke Energy
Contact Person: Don Lefler
Phone Numbers: Office: 336-341-6370 Mobile: Click or tap here to enter text.
Email: [e-mail]
Contractor for PD: Duke Construction and Materials
Contact Person: Blanton William
Phone Numbers: Office: 704-604-9880 Mobile: Click or tap here to enter text.
Email: [e-mail]

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Environmental Consultant: Pike
Contact Person: JC Weaver
Phone Numbers: Office: 704.345.2230 Mobile: [phone]
Email: [e-mail]

Brownfields Program Project Manager: Carolyn Minnich
Phone Numbers: Office: 704-661-0330 Mobile: [phone]
Email: [e-mail]

Other DEQ Program Contacts (if applicable, i.e., UST Section, Inactive Hazardous Site Branch,
Hazardous Waste, Solid Waste):
NA

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 proposed project consists of removal and replacement of two electrical distribution poles. The
proposed project (site) is located at 2229 and 2205 North Tryon Street, Charlotte NC, 28206. The
site is identified on the Mecklenburg County GIS website as Parcel numbers 07909304 and
07909301 and is currently owned by Summit Avenue Northend LLC. The site is located adjacent

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and to the west of the Summit Avenue Northend LLC Brownfields site (12033-08-060) and owned
by Summit Avenue Northend LLC.

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):
Provide brief summary of redevelopment plans, including demolition, removal of building
slabs/pavement, grading plans and planned construction of new structures:
See attached.

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: 9/22/2022

b) Anticipated duration (specify activities during each phase):
1-2 days

c) Additional phases planned? ☐ Yes ☒ No

If yes, specify the start date and/or activities if known:

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Start Date: Click or tap to enter a date.
Planned Activity:
NA

Start Date: Click or tap to enter a date.
Planned Activity:
NA

Start Date: Click or tap to enter a date.
Planned Activity:
NA

d) Provide the planned date of occupancy for new buildings: NA

CONTAMINATED MEDIA
Please fill out the sections 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) Contaminated Media on the Brownfields Property
Part 1. Soil:……………………………………….……………. ☒ Yes ☐ No ☐ Suspected ☐ Unknown
Part 2. Groundwater:.……………………….……..……. ☐ Yes ☐ No ☒ Suspected ☐ Unknown
Part 3. Surface Water:.……………...……..…………… ☐ Yes ☐ No ☐ Suspected ☒ Unknown
Part 4. Sediment:.……………...……..…………………… ☐ Yes ☐ No ☐ Suspected ☒ Unknown
Part 5. Soil Vapor:…..…………...……..…………………. ☐ Yes ☐ No ☒ Suspected ☐ Unknown
Part 6. Sub‐Slab Soil Vapor:……...……..…………….. ☐ Yes ☐ No ☒ Suspected ☐ Unknown
Part 7. Indoor Air:...……..…………………………………. ☐ Yes ☐ No ☐ Suspected ☒ Unknown

2) For the Area of Proposed Redevelopment on the Brownfields Property, attach tabulated data
summaries for each impacted media and figure(s) with sample locations.

PART 1. Soil
1) Known or suspected contaminants in soil (list general groups of contaminants):
According to the Hart Hickman 2008 Phase 2 report, VOCs and PAHs did not exceed DEQ
screening levels in collected soils samples. Chromium was detected above the EPA Soil
Screening Levels but within naturally occurring Chromium background levels. Work from
the proposed project would be conducted in an “area of potential soil contamination” as
denoted on the plat map. However, exposure to VOCs, PAHs, or other soil contamination
is considered minimal due to the shallow nature of the proposed excavation.

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2) Depth of known or suspected contaminants (feet):
Based on Hart Hickman and Terracons Annual Groundwater Monitoring Report field notes,
historical groundwater levels range between 22-14 feet Below Ground Surface, total well depth is
30 feet bgs. Chlorinated solvents were detected in groundwater samples above the 2L standards
and residential and nonresidential groundwater screening levels in MW-1.

3) Area of soil disturbed by redevelopment (square feet):
Approximately 10 square feet.

4) Depths of soil to be excavated (feet):
Approximately 4-5 feet below ground surface.

5) Estimated volume of soil (cubic yards) to be excavated (attach grading plan):
9.08 cubic yards

6) Estimated volume of excavated soil (cubic yards) anticipated to be impacted by contaminants:
The total amount of soil to be excavated is expected to be minimal, the excavated soil will be used
as backfill for the foundation of the replacement poles.

7) Estimated volume of contaminated soil expected to be disposed of offsite, if applicable:
The total amount of soil to be excavated is expected to be minimal, the excavated soil will be used
as backfill within the foundation of replacement poles. Remaining soil will be raked to the level of
the existing grade and seeded and strawed.

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).
NA

☐ 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

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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:
According to the Hart Hickman 2008 Phase 2 report, VOCs and PAHs did not
exceed DEQ screening levels in collected soils samples. Chromium was detected
above the EPA Soil Screening Levels but within naturally occurring Chromium
background levels. Work from the proposed project would be conducted in an
“area of potential soil contamination” as denoted on the plat map. However,
exposure to VOCs, PAHs, or other soil contamination is considered minimal due
to the shallow nature of the proposed excavation.

d) NOTE: IF SOIL MEETS THE DEFINITION OF A CHARACTERISTIC HAZARDOUS WASTE, THE
SOIL MAY NOT BE RE‐USED ON SITE AND MUST BE DISPOSED OF IN ACCORDANCE
WITH DEQ HAZARDOUS WASTE SECTION RULES AND REGULATIONS.

2) Screening criteria by which soil disposition decisions will be made (e.g., left in place, capped in
place with low permeability barrier, removed to onsite location and capped, removed offsite):
☐ Preliminary Health‐Based Residential SRGs
☒ Preliminary Health‐Based Industrial/Commercial SRGs
☐ Division of Waste Management Risk Calculator (For Brownfields Properties Only)
☐ Site‐specific risk‐based cleanup level. Please provide details of methods used for
determination/explanation.
Click or tap here to enter text.

Additional comments:
Click or tap here to enter text.

3) If known impacted soil is proposed to be reused within the Brownfields Property Boundary,
please check the measures that will be utilized to ensure safe placement and documentation of
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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:
Click or tap here to enter text.
☐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:
Two approaches to dust control will be utilized on the proposed project: proactive work
strategies to minimize fugitive dust generation and reactive engineered controls to mitigate
dust generation and/or capture fugitive dust. Because a variety of activities have the
potential to generate fugitive dust at a given site, there is no unique response to dust
prevention and control. Proactive measures would consist of the utilization of plastic
sheeting to cover excavated soils (spoil) from mobilization during wet weather events,
sediment socks or filter fabric surrounding spoil piles and stormwater inlet filters to prevent
mobilized sediment from entering storm drains. The immediate seed and strawing of the
excavated areas. Reactive controls would be vacuum trucks to remove any mobilized
sediments. As the volume of soil to be excavated is less than 10 cubic yards, fugitive dust is
not anticipated. Should an issue arise, contractors contact the project environmental
professional. If the project environmental professional confirms that fugitive dust has
become an issue, the DEQ Brownfields project manager will be contacted within 48 hours to
advise of the condition.
☐No, explain rationale:
Click or tap here to enter text.
Field Screening of site soil
The total amount of soil to be excavated is expected to be minimal, the excavated soil will be used as
backfill within the foundation of replacement poles. Remaining soil will be raked to the level of the
existing grade and seeded and strawed.
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☒Yes, describe the field screening method, frequency of field screening, person conducting
field screening:
During soil disturbance at the proposed pole locations, workers or contractors will observe
the soils for evidence of potential impacts. Soils excavated from the proposed pole
foundations will be screened at two (2’) foot intervals.
Evidence of potentially impacted soil includes distinct unnatural color, strong odor, or
filled with pr previously disposed materials or concerns (chemicals, tanks, or drums)
Should the above be noted during site work, the contractor will contact the project
environmental professional to observe the system condition. If the
project environmental professional confirms that the excavated soils maybe impacted, the
DEQ Brownfields project manager will be contacted within 48 hours to advise of the
condition.
☐No, explain rationale:
Soil Sample Collection
☒Yes, describe the sampling method (e.g., in‐situ grab, composite, stockpile, etc.):
Soils excavated from the proposed pole foundations will be screened at two (2’) foot
intervals. Soils from each boring will be placed into two separate sealed plastic bags. The
soils in one bag will be allowed to volatilize for approximately five (5) minutes prior to
screening for volatile vapors, while the second bag is immediately placed on ice to prevent
volatilization until collection of the sample for submittal to the laboratory. Headspace
screening of soil samples will be conducted utilizing a calibrated photoionization detector
(PID) equipped with a 11.7 electron-volt (eV) ultraviolet lamp source, which provides
measurements of total volatile organic vapors in parts per million (ppm) isobutylene
equivalents. Sampling personnel will wear disposable nitrile gloves to minimize the
potential for sample contamination. Soils will be evaluated for the presence of odor,
staining, and elevated photoionization detector (PID) readings. An aliquot with the highest
PID reading will be collected for the below listed analysis.
☐No, explain rationale:
If soils are disposed at Municipal Solid Waste Landfill (subtitle D) no sampling is required for NC
Brownfields Program. The disposal facility will determine what is needed.
If soil samples are collected for analysis, please check the applicable chemical analytes:
☒Volatile organic compounds (VOCs) by EPA Method 8260
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☒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.): 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):
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.):
Click or tap here to enter text.
Please provide a scope of work for final grade sampling, including a diagram of soil
sampling locations, number of samples to be collected, and brief sampling methodology.
Samples should be collected from 0-2 ft below ground surface, with the exception of VOCs
which should be taken from 1-2 ft below ground surface. Alternatively, indicate if a work
NA

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plan for final grade sampling may be submitted under separate cover.
NA

☒ If final grade sampling was NOT selected, please explain rationale:
According to the Hart Hickman 2008 Phase 2 report, VOCs and PAHs did not exceed DEQ
screening levels in collected soils samples. Contamination impacted soils are not
anticipated based on the Hart Hickman Phase 2 report. If field screening indicates
impacted soils, they will be tested as stated below. No exposed soils will be present once
work is complete and the excavated areas will be covered with hay and grass seed.

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?
NA

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.)
NA

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:
NA

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.
NA

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):
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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.):
Click or tap here to enter text.
7)The scope of work for import fill sampling may be provided below or in a Work Plan
submitted separately for DEQ review and approval. Attach specific location maps for in-situ
borrow sites. If using a quarry, provide information on the type of material to be brought
onto the Brownfields Property.
NA
Part 1.C. EXPORTED SOIL
NO SOIL MAY LEAVE THE BROWNFIELDS PROPERTY WITHOUT APPROVAL FROM THE
BROWNFIELDS PROGRAM. FAILURE TO OBTAIN APPROVAL MAY VIOLATE A BROWNFIELDS
AGREEMENT CAUSING A REOPENER OR JEOPARDIZING ELIGIBILITY IN THE PROGRAM,
ENDANGERING LIABILITY PROTECTIONS AND MAKING SAID ACTION POSSIBLY SUBJECT TO
ENFORCEMENT. JUSTIFICATIONS PROVIDED BELOW MUST BE APPROVED BY THE PROGRAM IN
WRITING PRIOR TO COMPLETING TRANSPORT ACTIVITIES. Please refer to Brownfields IR 15 for
additional details.
1)If export from a Brownfields Property is anticipated, please provide details regarding the
proposed export actions. Volume of exported soil, depths, location from which soil will
be excavated on site, related sampling results, etc. Provide a site map with locations of
export and sampling results included.
Limited amounts of soil are expected. Concrete will have excess soils shaken and removed
prior to disposal offsite. It will be inspected for pitting and chemical damage. If none, it can be
disposed of property at C&D landfill or MSWLF. Soils can be contained and disposed of at
MWSLF or as approved by NC Brownfields Program.
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
for concrete only

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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).
NA

Part 1.D. MANAGEMENT OF UTILITY TRENCHES

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

☐ Last out, first in principle for impacted soils (if soil can safely be reused onsite and is not a
hazardous waste), i.e., impacted soils are placed back at approximately the depths they
were removed from such that impacted soil is not placed at a greater depth than the original
depth from which it was excavated.

☐ Evaluate whether necessary to install barriers in conduits to prevent soil vapor transport,
and/or degradation of conduit materials due to direct impact with contaminants?
☐ If yes, provide specifications on barrier materials or provide the results of this evaluation in the
Vapor Mitigation Plan. Note that if vapor mitigation is planned for site buildings, utility
corridors will need to be evaluated as part of mitigation designs:
Click or tap here to enter text.

☐ If no, include rationale here:
There are no utility trenches associated with the proposed project.

☐ Unknown, details to be provided in the Vapor Mitigation Plan for site buildings

Other comments regarding managing impacted soil in utility trenches:
NA

PART 2. GROUNDWATER

1) What is the depth to groundwater at the Brownfields Property?
Based on Hart Hickman and Terracons Annual Groundwater Monitoring Report field notes,
historical groundwater levels range between 22-14 feet below ground surface.

2) Is groundwater known to be contaminated by ☒onsite ☐offsite ☐both or ☐unknown

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sources? Describe source(s):
Based on Hart Hickman and Terracons Annual Groundwater Monitoring Report, chlorinated
solvents were detected in groundwater samples above the 2L standards and residential and
nonresidential groundwater screening levels in MW-1.

3) What is the direction of groundwater flow at the Brownfields Property?
East.

4) Will groundwater likely be encountered during planned redevelopment activities?
☐Yes ☒No
If yes, describe these activities:
NA

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).
Should groundwater be encountered during pole removal or installation, contaminated activities
would include; construction of a dike to contain groundwater, placement of excavated soil into
groundwater discharge area to serve as a plug, use of a trash pump to dewater excavation, use
of totes to capture discharged groundwater, the calling of Pike’s environmental scientist to assist
in groundwater containment and soil and ground water characterization and disposal.

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.
NA

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PART 3. SURFACE WATER
1) Is surface water present at the property? ☐ Yes ☒ No ☐ Unknown
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 is encountered during pole removal or installation,
containment actions would include the creation of a berm or dike for diversion/capture, potential
tarping of the excavation, use of a trash pump to dewater excavation, use of totes to capture
discharged groundwater, the calling of Pike’s environmental scientist to assist in soil and water
characterization.

PART 4. SEDIMENT

1) Are sediment sources present on the property? ☐ Yes ☒ No

2) If yes, is sediment at the property known to be contaminated: ☐ Yes ☒ No ☐ Unknown

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):
In the event that contaminated sediment is encountered during pole removal or installation,
containment actions would include stock piling the contaminated soil on plastic and covering
stockpile with plastic, the calling of Pike’s environmental scientist to assist in containment and soil
characterization.

PART 5. SOIL VAPOR

1) Do concentrations of volatile organic compounds at the Brownfields property exceed the

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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 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:
In the event that contaminated soil vapor is encountered, a stop work order would be issued,
further subsurface investigation would be initiated, and the calling of Pike’s environmental
scientist to assist in soil vapor assessments.

PART 6. SUB‐SLAB SOIL VAPOR
1) Do concentrations of volatile organic compounds at the Brownfields property exceed the
following vapor intrusion screening levels (current version) in sub-slab soil vapor:
IHSB Residential Screening Levels:
Soil Vapor:………..☐ Yes ☒ No ☐ Unknown
Groundwater:.….☐ Yes ☐ No ☒ Unknown
IHSB Industrial/Commercial Screening Levels:
Soil Vapor:………..☐ Yes ☐ No ☒ Unknown
2) Groundwater:…..☐ Yes ☒ No ☐ Unknown 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:
Subslab vapor sampling has not been conducted within the proposed project excavation locations,
in addition, the proposed project will not occur within subslab areas. Based on previous
consultants site investigations, it is assumed that soil vapor is contaminated. However, the
proposed project will not involve sub-slab disturbance, therefore, sub-slab gas is not anticipated.

4) Will workers encounter contaminated sub‐slab soil vapor during planned redevelopment
activities? ☐ Yes ☒ No ☐ Unknown
NA

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☐ If no, include rationale here:
The proposed project area will not disturb nearby building footprints nor take place within
subslab areas; in addition, subslab vapor sampling has not been conducted within the proposed
project excavation locations.
5) In the event that contaminated soil vapor is encountered during redevelopment activities, list
activities for management of such contact
In the event that contaminated subslab soil vapor is encountered, a stop work order would be
issued, further subsurface investigation would be initiated, and the calling of Pike’s
environmental scientist to assist in subslab vapor assessments.

PART 7. INDOOR AIR

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

☐ If no, include rationale here:
The proposed project does not involve work within the interior of onsite buildings.
4) In the event that contaminated indoor air is encountered during redevelopment activities, list
activities for management of such contact:

VAPOR INTRUSION MITIGATION SYSTEM
Is a vapor intrusion mitigation system (VIMS) proposed for this Brownfields Property?
☐ Yes ☐ No ☒ Unknown

☐ If no or unknown, include rationale here as well as plans for pre-occupancy sampling, as
necessary:
The proposed project does not involve work within the interior of onsite buildings.

If yes, ☐ VIMS Plan Attached or ☐ VIMS Plan to be submitted separately
If submitted separately provide date:
In the event that contaminated indoor air encountered, a stop work order would be issued, and the
calling of Pike’s environmental scientist to assist in indoor air assessment.

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NA

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:
The proposed project does not involve work within the interior of onsite buildings.

Note that approval of this EMP does not imply approval with any vapor intrusion mitigation land
use restrictions or requirements of the recorded or draft Brownfields Agreement and that
separate approval of mitigation measures will be required.

CONTINGENCY PLAN – encountering unknown tanks, drums, or other waste materials

In this section please provide actions that will be taken to identify or manage unknown
potential new sources of contamination. During redevelopment activities, it is not uncommon
that unknown tanks, drums, fuel lines, landfills, or other waste materials are encountered.
Notification to DEQ Brownfields Project Manager, UST Section, Fire Department, and/or other
officials, as necessary and appropriate, is required when new potential source(s) of
contamination are discovered. These Notification Requirements were outlined on Page 1 of this
EMP.

Should potentially impacted materials be identified that are inconsistent with known site
impacts, the DEQ Brownfields Project Manager will be notified and a sampling plan will be
prepared based on the EMP requirements and site-specific factors. Samples will generally be
collected to document the location of the potential impacts.

Check the following chemical analysis that are to be conducted on newly identified releases:
☒ Volatile organic compounds (VOCs) by EPA Method 8260
☒ Semi‐volatile organic compounds (SVOCs) by EPA Method 8270
☒ Metals RCRA List (8) (arsenic, barium, cadmium, chromium, mercury, lead, selenium and
silver)
Click or tap here to enter text.

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

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

☐ Other Constituents & Analytical Method(s) (i.e. Hexavalent Chromium, Herbicides, etc.)
Please note, if field observations indicate the need for additional analyses, they should
be conducted, even if not listed here.
Click or tap here to enter text.

Please provide details on the proposed methods of managing the following commonly
encountered issues during redevelopment of Brownfields Properties.

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Click or tap here to enter text.

Underground Storage Tanks:
UST sampling would be consistent with that of NC DEQ UST sampling regulations.

Sub-Grade Feature/Pit:
Soil characterization sampling would be conducted in the event of visual or olfactory observations,
as well as additional geophysical assessment to delineate the subgrade/pit feature.

Buried Waste Material – Note that if buried waste, non-native fill, or any obviously filled materials
is encountered, the DEQ Brownfields Program must be notified to determine if investigation of
landfill gases is required:
In the event that buried material is encountered, Pike would stop work and contact the sites
Brownfields manager.

Re-Use of Impacted Soils On-Site:
Impacted soils are not expected given the shallow nature of the excavation, excavated soils will be
returned to the excavation during pole installation or spread on site and leveled with the existing
grade.

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:
NA

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 Click or tap to enter a date.

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;

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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.

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APPROVAL SIGNATURES

Brownfields Project Number: 12033-08-060

Brownfields Project Name: North Tryon Commercial

Prospective Developer: Duke Date Click or tap to enter a date.
Printed Name/Title/Company: Don Lefler
Consultant: JC Weaver Date 9/9/2022
Printed Name/Title/Company: Environmental Scientist/Pike
Brownfields Project Manager: Carolyn Minnich Date Click or tap to enter a date.

JC WEaver
09/12/2022
09/12/2022
10/12/2022
This map is for graphical purposes
only and does not represent a legal
survey. IT is strictly for use with
Pike Engineering (Pike) project,
Job No. 22-35024-000-00600. Pike
assumes no liability, direct or
indirect, whatsoever for any such
third party unintended use.
LEGEND
P12 Pole identification number.
FIGURE 2
Pole Replacement Map
Job No. 22-35024-000-00600
Right of Way.
N
Proposed Replacement Poles
Date: 8/12/2022
JC Weaver
71177699.2
Groundwater Analytical Results (January 2021)
North Tryon Site
2229 North Tryon Street
Charlotte, Mecklenburg County, NC
2701 Westport Road
Charlotte, NC
711777699
WOF
CLC
CLC
N.T.S.
January 2021
Scale:
2
FigureProject Manager:
Drawn by:
Checked by:
Approved by:
Project No.
File Name:
Date:
WOF
denotes approximate site boundary
approximate location of groundwater
monitoring well
GRAVEL
MW-1
Sample ID: MW-1
Groundwater Sample
8260 –cis-1,2-Dichloroethene: 15.9 µg/L
Tetrachloroethene: 569 µg/L
Trichloroethene: 12.9 µg/L
*Values above 2L Standards and non-
residential GWSL are in bold.
Table 1
Groundwater Analytical Results
North Tryon Site
Brownfields ID: 12033-08-060
2229 North Tryon Street
Charlotte, Mecklenburg County, North Carolina
Terracon Project No. 71177699
Sample ID:
Screen Interval
(ft bgs):
Sample Date: 12/10/2013*12/18/2014*7/11/2016*01/23/2019 1/27/2021
Chloroform 70 8.1 36 ND <1 <5 <11.7 <9.4
cis-1,2-Dichloroethene 70 NS NS 141 82.1 52 30.5 15.9
trans-1,2-Dichloroethene 100 NS NS <1.0 <1.0 20 <5 <1.0
Tetrachloroethene 0.7 12 48 2,280 1,190 1,500 766 569
Toluene 600 3,800 16,000 ND <1 <5 2.9J <0.98
Trichloroethene 3 1 4.4 87.3 48.2 37 16.7 12.9
Notes:
Only detected compounds are shown.
Concentrations are reported in micrograms per liter (μg/L).
* = Labortory data obtained from Hart & Hickman Groundwater Monitoring Reports
2L Standard - North Carolina Administrative Code Subchapter 2L Groundwater Quality Standards (April 1, 2013).
Concentrations highlighted in gray exceed their respective 2L Standard
Concentrations highlighted in orange exceed their respective Non-Residential GWSL.
ND - Not Detected
NS - No Standard
GWSL - NCDEQ Division of Waste Management Vapor Intrusion Groundwater Screening Levels - Health-Based Ground Water Screening Levels, updated February 2018
<1<5
<1.0
Semi-Volatile Organic Compounds (EPA Method 8270)
Volatile Organic Compounds (EPA Method 8260)
33.3
596
17.8
<5 <1.3
<5
1,380
22.3
<2.3
27.4
No contaminants detected above the laboratory reporting limit or NCAC 2L GWQS
Analyte 2L Standard
01/05/2018
Residential
GWSL
Non-Residential
GWSL
12/14/2016
<5
34.5
570
20.1
0.77J
MW-1
25-30
01/27/2020