REVISED FINAL 1054-10-288C Erwin Square Brownfields Soil Management Plan - 2011-12-5

BROWNFIELDS SOIL MANAGMENT PLAN
Erwin Square / Former Burlington Industries Site
749 Ninth Street
Durham, North Carolina
S&ME Project No. 1054-10-288C

Prepared for:

Crescent Ninth Street Venture I, LLC
227 West Trade Street, Suite 1000
Charlotte, NC 28202

Prepared by:

S&ME, Inc.
3201 Spring Forest Road
Raleigh, North Carolina 27616

December 5, 2011
Brownfield Soil Management Plan S&ME Project No. 1054-10-288C
Erwin Square / Former Burlington Industries Site, Durham, NC December 5, 2011

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TABLE OF CONTENTS
1.0 PROJECT INFORMATION.................................................................................... 1
1.1 Purpose ............................................................................................................ 1
1.2 Background ...................................................................................................... 1
2.0 PROPOSED DEVELOPMENT .............................................................................. 2
3.0 PROJECT NOTIFICATIONS AND CONTENT PROCEDURES ............................ 3
3.1 NCDENR Notification ........................................................................................ 3
3.2 Areas with Identified Soil Impacts ..................................................................... 3
3.3 Previously Unidentified or Unforeseen Conditions ............................................ 3
3.4 Project Contact List ........................................................................................... 4
3.5 Reporting .......................................................................................................... 4
3.6 Deviation from Approved Plan .......................................................................... 5
4.0 HEALTH & SAFETY CONSIDERATIONS ............................................................ 6
5.0 PROVISIONS FOR HANDLING POTENTIALLY REGULATED SOIL .................. 7
5.1 Applicable Areas ............................................................................................... 7
5.2 Evaluation and Excavation ................................................................................ 7
5.3 Recyclable Material from Demolition ................................................................. 9
5.4 Nuisance Dust Abatement .............................................................................. 10
5.5 Fill Material ..................................................................................................... 10
6.0 PROVISIONS FOR HANDLING POTENTIALLY-REGULATED WATER ............ 11
6.1 Groundwater ................................................................................................... 11
6.2 Stormwater ..................................................................................................... 11
7.0 DECONTAMINATION PROCEDURES ............................................................... 12
8.0 POST CONSTRUCTION CONFIRMATION SAMPLING ..................................... 13
9.0 REFERENCES .................................................................................................... 14
10.0 CERTIFICATION OF SITE PERSONNEL ........................................................... 15

Figures
Figure 1: Vicinity Map
Figure 2: Site Map
Figure 3: Soil Sample Location Map

Tables
Table 1: Soil Analytical Results Summary

Appendices
Appendix I: Selected Construction Drawings – John R. McAdams Company, Inc.
Appendix II: Certification of Site Personnel
Appendix III: Amendments to Brownfields Soil Management Plan
Brownfield Soil Management Plan S&ME Project No. 1054-10-288C
Erwin Square / Former Burlington Industries Site, Durham, NC December 5, 2011

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1.0 PROJECT INFORMATION
1.1 Purpose
The Prospective Developer, Crescent Ninth Street Venture I, LLC, intends to develop the former
Burlington Industries Erwin Mills Site located at 749 Ninth Street in Durham, North Carolina (the
Site), under a Brownfield Agreement with the North Carolina Brownfields Program (NCBP),
administered by the North Carolina Department of Environmental and Natural Resources
(NCDENR). The purpose of this Soil Management Plan is to provide details regarding soil
management measures that will be put in place to satisfactorily complete the development under the
terms of the Brownfields Agreement (BFA).

1.2 Background
The Site is 6.38 acres in area and is the central portion of a 14.272-acre parent property that extends
from Hillsborough Road to Main Street. The proposed development will have a street address of
749 Ninth Street. The Site is located in an urban area of western downtown Durham, consisting
primarily of commercial and residential areas, as shown on Figure 1. The Site is currently a mostly
undeveloped, grassed lawn area, as shown on Figure 2. The Site was once part of the former
Burlington Industries Erwin Mills textile plant, which occupied the Site and surrounding area from
the 1890s until the late 1980s. The former industrial facilities of the site were demolished between
1987 and 1989. One of the mill buildings remains present adjacent to the east of the site, and is
currently used for office space and residential purposes. Site soils are contaminated with polycyclic
aromatic hydrocarbons (PAHs). An off-site release of chlorinated solvents to groundwater (Incident
Management Database Incident No. 20604) has migrated onto the Site.

Refer to Figure 3, Soil Sample Location Map, for the soil boring locations conducted by S&ME
on March 31, 2011 and designated as SB-1 to SB-9, presented as an overlay of an aerial photograph
dated March 3, 1977 that shows the structures present at that time. Two soil samples were selected
for laboratory analysis from each boring based on field screening results. The soil samples were
designated by the boring number followed by the depth interval. The soil sample analytical results
were compared to the NCDENR, Division of Waste Management (DWM), Inactive Hazardous Sites
Branch (IHSB), Preliminary Soil Remediation Goals (PSRGs) and to the NCDENR, DWM,
Underground Storage Tanks Section, Maximum Soil Contaminant Concentration (MSCC). The
IHSB has two PSRGs: 1) a “health-based” remediation goal for total concentrations of
contaminants, and 2) a “protection of groundwater” remediation goal for leachable concentrations
of contaminants. A summary of the parameters that were detected during the soil sample analysis
and a comparison to the NCDENR standards are summarized in Table 1, Soil Analytical Results
Summary.

Brownfield Soil Management Plan S&ME Project No. 1054-10-288C
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2.0 PROPOSED DEVELOPMENT
Crescent Ninth Street Venture I, LLC, is planning to redevelop the Site with a multi-story
residential development and a parking deck (Appendix I). In addition to the residential units and
parking deck, the development will include a clubhouse, a gym, four courtyard areas, and associated
landscaping, sidewalk, infrastructure improvements, and other uses approved by NCDENR.

Based on the presence of a known groundwater contaminant plume, the proposed structures at the
site will be constructed with a means of preventing vapor migration into the building, such as a
vapor barrier. Based on 2005 groundwater elevation data provided in the LUST/IMD incident files,
the depth to groundwater ranges from approximately 6.5 feet below the ground surface (bgs) to 11.5
feet bgs. Excavation into the groundwater table is not anticipated for the proposed development,
and no groundwater usage is planned.

This Plan has been prepared to define the procedures required for excavation and management of
defined areas of contamination not meeting the soil concentrations acceptable for this Site, and to
prepare for post-construction sampling.

Site civil preparation activities within the scope of the Plan are defined to comprise:

 the mass civil cut and subsequent soil balancing to achieve final elevation;
 the excavation of soil for the installation of the footers;
 the removal of subsurface footers/foundations; and
 the excavation of soil for subsurface utility chase corridors.
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3.0 PROJECT NOTIFICATIONS AND CONTENT PROCEDURES
3.1 NCDENR Notification
This Soil Management Plan constitutes the advance written notice required by the BFA for the
following activities.

 Per paragraph 13.d. of the BFA, soil on the Property may not be disturbed until any
sampling DENR requires has been conducted, and any actions DENR requires based on the
sampling results have been taken, to ensure the Property is suitable for high-density
residential purposes, and to ensure that public health and the environment are fully
protected. Such actions may include the capping or treatment of soil in situ and/or disposal
of soil off-site.

3.2 Areas with Identified Soil Impacts
A shallow soil sampling program has been completed at the Property, as described in the S&ME
report Revised Brownfields Assessment and Receptor Survey, dated July 18, 2011. The sampling
program was performed to indicate the presence or absence of target analytes in soil at specific
locations where past use or storage of hazardous materials or petroleum products was suspected
based on our review of historical records. The laboratory analytical results of the soil samples
indicated that certain contaminant concentrations exceeded their respective NCDENR standards.
The soil sample locations are presented on Figure 3, Soil Sample Location Map, and the analytical
data from our previous soil sampling are summarized on Table 1, Soil Analytical Results
Summary.

The former Burlington Industries above-grade structures, paved areas and the railroad spur have all
been demolished and removed from the Property, and the site was likely graded after demolition.
Based on the findings of the Revised Brownfields Assessment and Receptor Survey, the long-term
and varying past industrial uses of portions of the site, and the likelihood that the soil on-site has
been graded or disturbed, it is possible that sporadic shallow soil contamination may be present
across portions of the Property.

3.3 Previously Unidentified or Unforeseen Conditions
Previously unidentified or unforeseen conditions are defined to mean the discovery of potentially-
regulated (i.e., by NCDENR) soil or groundwater that presents, through normal and routine field
observations, field detection instruments or laboratory analyses, characteristics different from other
non-affected media in the area being worked. These characteristics are typically expected to be
triggered by visual and odor indications.

If previously unidentified or unforeseen conditions are encountered during site development, it is
each worker’s obligation to report such conditions to their immediate supervisor who will, in-turn,
notify the Construction Representative identified on the Project Contact List in the following
section. The Project Superintendent will then notify the Site Environmental Representative. The
Protocol presented herein will then be implemented by Crescent Ninth Street Venture I, LLC, as
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applicable and appropriate, to manage the proper resolution of unidentified or unforeseen
conditions.

3.4 Project Contact List
Contact for implementation of this Plan should be made directly with the Project Superintendent or,
in his absence, the Site Environmental Representative. Back-up contacts are (contact in the order
listed):

On-Site Contacts:
Construction Representative:
James L. Donaldson
Building State Group
4417 Old Charlotte Highway
Monroe, NC 28111
Ph: 704-289-6400
Mobile: [phone]

Site Environmental Representative:
Mr. Chris Hamblet, CHMM
[e-mail]
S&ME, Inc.
3201 Spring Forest Road
Raleigh, NC 27616
Ph: 919-872-2660
Fax: [phone]
Mobile: [phone]

Off-Site Contacts:
Developer Representative:
Brian T. Nicholson
Development Manager
[e-mail]
Crescent Ninth Street Venture I, LLC
227 W. Trade St, Suite 1000
Charlotte, NC 28202
Ph: 980-321-6237
Fax: [phone]
Mobile [phone]

Environmental Representative:
Mr. Samuel P. Watts, P.G.
[e-mail]
S&ME, Inc.
3201 Spring Forest Road
Raleigh, NC 27616
Ph: 919-872-2660
Fax: [phone]

3.5 Reporting
Should unidentified and unexpected conditions be encountered, all contractors and sub-contractors
must report those conditions immediately to the Project Superintendent or, in his absence, to the
Site Environmental Representative. The responsibility of notification to NCDENR and other
external parties lies solely with Crescent Ninth Street Venture I, LLC or, at direction from Crescent
Ninth Street Venture I, LLC, with S&ME acting on its behalf.

The NCDENR / NC Brownfields Program (NCBP) contact is:
Dr. Joe Ghiold, Brownfields Project Manager
[e-mail]
NCDENR, DWM, NC Brownfields Program
217 W. Jones Street
Raleigh, NC 27603-6100
Ph: [phone]
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3.6 Deviation from Approved Plan
This Plan is intended to be dynamic and to be adapted to specific and actual Site conditions.
Accordingly, should such conditions warrant a change either by addition, deletion or modification
of a procedure, such may be accomplished with agreement between the Project Superintendent and
the Site Environmental Representative after consultation with the NCBP contact. Such changes will
comply with applicable local, State and Federal rules and regulations. The NCBP will be notified
promptly should such a change be implemented. A written amendment shall be prepared and
submitted to NCBP for approval (the use of e-mail correspondence shall suffice for approval,
followed by a hard copy or electronic copy provided on Compact Disk or similar media).
Amendments must have the concurrence of both Crescent Ninth Street Venture I, LLC and the
NCBP prior to implementation of each amendment. Approved Amendments shall be included in
Appendix III of this Brownfields Soil Management Plan.

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4.0 HEALTH & SAFETY CONSIDERATIONS
Because this is a Brownfield Site, work by each site contractor and site sub-contractor must be
accomplished within the framework of an appropriate Site-Specific Health and Safety Plan (HASP).

Crescent Ninth Street Venture I, LLC specifies that Level D Personal Protect Equipment (PPE),
which includes hard-hats, steel-toed safety boots, safety glasses with side-shields and high-visibility
safety vests, as the minimum level of PPE to be used for all site work. All truck drivers who exit
their trucks on-site will be subject to the health and safety requirements established for the Property.

Crescent Ninth Street Venture I, LLC via S&ME will make available to contractors and sub-
contractors, upon request from the contractors and sub-contractors for provision, the due diligence
data so that informed and responsible decisions can be made by those contractors and sub-
contractors regarding the health and safety of their employees. Copies of the HASP used for the
environmental and geotechnical investigations are available for information purposes only upon
request.

Each site contractor and site sub-contractor performing work related to soil handling must prepare
its own Site-Specific HASP. Each HASP shall demonstrate that their work activities will not cause
adverse exposures to their employees or the surrounding public areas.

Each contractor and sub-contractor is specifically and wholly responsible for the safety of
their workers, including any PPE and training, as may be warranted or required by law and
regulations. Crescent Ninth Street Venture I, LLC, and S&ME, Inc., are responsible only for
the safety of their respective employees.
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5.0 PROVISIONS FOR HANDLING POTENTIALLY REGULATED SOIL
5.1 Applicable Areas
The topsoil across the site will be stockpiled, sampled and removed from the site for proper
disposal. The topsoil is defined as the surficial soil containing organic material from the existing
ground surface to a depth of approximately six inches below grade. The shallow subsoil across the
Property will be cut or filled to achieve the desired final site elevation grades (Appendix I –
Drawing C-5). The installation of footers and subsurface utilities (i.e., cable, telephone, electrical,
natural gas, water, sewer, stormwater, etc.) will require the excavation of trenches. The Site
Environmental Representative, or his designee, shall be on-site during activities that disturb existing
soils at the site to observe and document the soil grading, excavation and stockpiling activities. In
the event that previously unidentified or unforeseen conditions are encountered, the Site
Environmental Representative will be available on-call at other times when grading activities are
occurring on-site (this would include placing lifts of clean fill material or soil compaction).
5.2 Evaluation and Excavation
Topsoil collected from the site will be stockpiled, sampled and removed from the site for proper
disposal. Based on previous environmental assessment activities conducted at the Property, soil
contaminant concentrations detected above regulatory limits are at concentrations that are below the
detection levels of typical field screening devices, such as a Photo-Ionization Detector (PID) or
Organic Vapor Analyzer (OVA). Due to the potential presence of residual contamination in the
soil, composite samples representative of the stockpiled topsoil will be collected. In general
accordance with typical stockpile sampling protocols, such as those provided in NCDENR Division
of Waste Management’s Guidelines for Sampling, the composite samples will consist of six
subsamples, and will be collected at a frequency of approximately one sample per 200 cubic yards.
The topsoil samples will be submitted for the following laboratory analyses:

Parameter Analytical Method
Volatile Organic Compounds + 10 TICs EPA Method 8260B
Semi-Volatile Organic Compounds + 10 TICs EPA Method 8270C
8 RCRA Metals EPA Method 6010/7470
PCBs EPA Method 8082

If soil sample results are found to be above applicable regulatory limits and/or action levels for
unregulated disposal, they will be manifested and transported off-site for proper disposal as
described in Section 5.3.

Due to the presence of unsuitable organic material and debris in the subsoil, the shallow soils
beneath the topsoil across the site will be excavated to depths ranging from about 2 feet to 12 feet
below ground surface (see Cut-to-Fill Map in Appendix I). These soils will be stockpiled, screened,
amended with new fill, and replaced onsite as compacted fill. Areas where amended soil has been
placed will either be capped with at least 24 inches of new fill or covered by a non-pervious surface
such as a structure or pavement. The Site Environmental Representative, or his designee, shall be
on-site to observe and document the soil removal and the placement of shallow fill (0’ to 2’ below
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final grade elevation). The Site Environmental Representative will periodically field screen soils as
necessary. In the event that previously unidentified contaminant conditions are suspected, soil
samples will be collected and submitted for the laboratory analyses listed above.

The unsuitable organic material and debris removed from the subsoil during the amendment process
will be segregated and stockpiled on-site. Composite samples representative of the stockpiled
unsuitable organic material and debris will be collected at a minimum frequency of approximately
one sample per 200 cubic yards and submitted for the laboratory analyses listed above.

Soil excavation shall follow these procedures:

 Based on previous environmental assessment activities conducted at the Property, it is not
anticipated that soil handling will require a work stoppage or an upgrade from Level D PPE
to Level C. However, in the event of the discovery of a previously unknown area of
potential soil contamination, the Site Environmental Representative will be responsible for
evaluating whether a work stoppage or a PPE upgrade is appropriate. In the event of work
stoppage, the Site Environmental Representative will inform the NCBP Representative.
 The number of samples to be collected from the excavated soil will depend upon the
quantity of soil generated and the specific conditions at hand. In the case of potentially-
affected soil encountered during site grading, a sampling protocol will be performed in a
manner consistent with and approved by the NC Brownfields Program.
 The parametric coverage to be selected for soil sample analysis will depend upon the
specific conditions at hand and will rely upon existing soil sampling data and visual
observation to assist in parametric selection. Typical parameters that may be reasonably
expected to occur include SVOCs and PAHs.
 Excavated areas will be managed as practicably as possible to prevent accumulation of
rainwater. Whenever possible, excavation to remove contaminated soil will be performed
when prevailing and incipient weather conditions are favorable. Plastic sheeting and
temporary backfilling with non-contaminated soil may be used to reduce/preclude the
accumulation of storm water in the excavated areas.
 The potentially-affected area will be marked with yellow caution tape. Safety precautions
will not be limited to only caution tape. Safety precautions will be adjusted, as appropriate,
based on the circumstances. For instance, high visibility snow fencing, safety cones,
temporary signage and/or temporary hard-fencing may be used as needed to best suit the
specific condition at-hand.

Staging/Stockpiling
Areas used for soil staging will be clearly marked both in the field and on sketch outlines.

 Stockpiling of soil for several days prior to loading may be performed, pending laboratory
analysis results.
 If soil is stockpiled, appropriate erosion and sediment control measures, such as hay bales
and/or silt fencing, will be implemented.
 If stockpiled, potentially affected soil and soil exceeding PSRGs will be stored on a liner
and will be covered with secured plastic sheeting while not being worked and at the end of
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each day. Appropriate erosion and sediment controls, such as hay bales and/or silt fencing,
will also be implemented for this soil.
 Potentially affected soil will be kept segregated from the soil that has laboratory data
indicating that constituents exceed their respective PSRGs.

Transport and Disposal of Contaminated Soil
Contaminated soil scheduled for off-site disposal will be properly characterized for disposal,
manifested, transported and disposed of in compliance with applicable laws. A record of each truck
dispatched from the Site for off-Site disposal will be paired with the associated manifest and weight
ticket report received from the landfill. Based on previous environmental assessment activities
conducted at the Property, off-site disposal of soil is expected to be characterized as non-hazardous
solid waste.

 Care will be given to the transport truck tires to prevent cross-contamination of soil from the
excavation to the remainder of the Site.
 Truck loads will be covered prior to leaving the Site.
 During bulk transport of non-hazardous soils, applicable marking requirements will be used
to display the appropriate DOT placards on the trailer.
 Proper Class 9 placards will be used if hazardous soil/material is being transported off-Site
for disposal, although this is not anticipated.
 Proper documentation required for the shipment of contaminated waste off-site will be
managed in the field. A record of each truck dispatched from the Property for off-site
disposal will be paired with the associated manifest and weight ticket report received from
the landfill or disposal facility.
 Crescent Ninth Street Venture I, LLC, will retain responsibility for signatory execution of all
waste profiles and manifests as the generator.
 Soil will be disposed of in accordance with applicable state and local regulations at an
appropriate disposal facility approved by Crescent Ninth Street Venture I, LLC.
 A copy of the approved profile and acceptance from the selected off-site waste disposal
facility will be provided to the NCBP Project Manager.

5.3 Recyclable Material from Demolition
Aggregate materials that may be encountered on the Site may be re-used whenever feasible for
beneficial fill. Materials that cannot be used as beneficial fill will be disposed of in an appropriate
off-Site C&D landfill.

Concrete, Masonry Block, Brick and Asphalt – Acceptable
 Concrete, masonry block, brick and asphalt material will be inspected visibly for distinct
oily staining.
 If no such staining is observed, the concrete, masonry block, brick or asphalt will be
considered clean and will be prepared for re-cycling, as in routine demolition projects.
 Large pieces of concrete, masonry block, brick and asphalt encountered may be broken into
smaller pieces by an on-Site pulverizer to meet the specification of 2-inch dimensions or
less.
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 The steel reinforcement bars (rebar) used in the concrete may be extracted during crushing.
 The crushed concrete, block, brick and asphalt may then be stockpiled on-Site for use as
beneficial fill during Site preparation.
 The rebar may be sent off-Site as scrap to be re-cycled.

Concrete, Masonry Block, Brick and Asphalt – Not Acceptable
 If oily staining is observed, this concrete, masonry, block, brick or asphalt will be
considered affected.
 This material will be stockpiled in a designated area and disposed of in an appropriate off-
Site C&D landfill.
 Masonry block and brick that presents lead-based paint greater than the regulatory trigger
will be segregated from the other block and brick; not crushed; and, disposed of at an
appropriate off-site C&D landfill.
 The rebar may be extracted from this concrete and sent off-site as scrap to be recycled.

No asphalt material will be placed in direct contact with groundwater.

5.4 Nuisance Dust Abatement
Appropriate dust control measures will be implemented as needed during management of
unidentified or unforeseen conditions to minimize dust emissions from intrusive activities.

 Dust levels will be visually monitored by Crescent Ninth Street Venture I, LLC and/or their
designee to ensure compliance with OSHA. If dusty conditions are observed or anticipated,
appropriate measures will be taken to reduce dust levels, such as wetting the exposed soil
areas.

5.5 Fill Material
To achieve the proposed site grade, portions of the Site will require fill material.

 Fill may be composed of soil cut from other areas of the Site, crushed concrete obtained
from Site foundation slab demolition, or from off-site, non-contaminated soil. Fill
material brought to the site from off-site sources will be stockpiled prior to placing as
lifts or used for soil amendment. Composite soil samples will be collected from the
stockpiled fill material. In general accordance with typical stockpile sampling protocols,
the composite samples will consist of six subsamples, and will be collected at a
frequency of approximately one sample per 200 cubic yards. The samples will be
submitted for analysis for Volatile Organic Compounds (EPA Method 8260) and for
Semi-Volatile Organic Compounds (EPA Method 8270) at a frequency of approximately
one sample per 200 cubic yards. The source of fill material brought in from off-site
sources shall be documented and submitted to NCDENR.
 The amount of staged backfill will be minimized by placing soil directly into the excavated
areas when possible, thereby minimizing multiple and inefficient handling of the soil.

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6.0 PROVISIONS FOR HANDLING POTENTIALLY-REGULATED WATER
6.1 Groundwater
Contaminated groundwater has been identified in the north and northwest portions of the Site.
However, because contaminated groundwater is spread over such a large portion of the site, and
because groundwater has the ability to be easily mobilized by site de-watering activities, any
groundwater encountered at the site should be considered contaminated and contact with
groundwater should be avoided. Groundwater is not anticipated to be encountered based on the
planned grading/filling activities and the known depth to groundwater (Appendix I – Drawing C-
5). In the event groundwater is encountered, the applicable excavation activities should terminate
until the groundwater is characterized. The following procedures should be followed to address
groundwater.

 Groundwater encountered during the site work, or management of unidentified water that
must be removed and disposed of for work to proceed (after allowing the water to
percolate), will be containerized for characterization by analytical data. Groundwater
samples will be analyzed for VOCs by EPA Method 8260B and for SVOCs for poly-cyclic
aromatics (PAHs) only by EPA Method 8270D. If contained groundwater is determined to
be above regulatory limits, the NCBP contact will be consulted to determine appropriate
action.

6.2 Stormwater
 Storm water will be managed in compliance with the approved E&SC Plan and
corresponding NPDES Permit.
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7.0 DECONTAMINATION PROCEDURES
 Equipment working within areas of known contamination will be required to be evaluated
for decontamination prior to demobilizing from the site.
 Evaluation as to whether personnel or vehicle decontamination will be required will be made
by the Site Environmental Representative on a case-by-case basis considering the nature and
concentration of the contamination encountered.
 Dry decontamination procedures for vehicles are likely to include, but may not be limited to,
brushing or scraping of tires, treads, undercarriages and buckets of vehicles and equipment
that may have come in contact with contaminated materials.
 Such dry decontamination will occur in designated area constructed to contain and collect
the recovered solids and liquids.
 Wet decontamination procedures for vehicles are likely to include, but may not be limited
to, pressure washing tires, treads, undercarriages and buckets of vehicles and equipment that
may have come in contact with contaminated materials.
 Such wet decontamination will occur in designated area constructed to contain and collect
the recovered solids and liquids.
 Personnel decontamination procedures will comply with those specified in each
contractor’s/sub-contractor’s Site-Specific HASP for their respective workers.

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8.0 POST CONSTRUCTION CONFIRMATION SAMPLING

Following the conclusion of construction-related soil disturbance, but prior to non-construction
worker occupation of the site, surficial soils shall be sampled by the Site Environmental
Representative under a sampling and analysis plan approved by NCDENR in all areas not covered
by at least two feet of clean fill and/or capped by impervious surfaces or buildings placed on the
property. Such sampling and analysis plan may include confirmation that any such fill has no
constituent above residential SRGs. This post-construction sampling may be completed in stages,
as each phase of the development project is completed.

The specific sampling protocol will be established consistent with NCDENR guidelines and
submitted for approval by the NCDENR Brownfields Program. The parametric coverage to be
selected will depend upon the specific conditions at hand and will rely upon existing soil sampling
data and visual observation to assist in parametric selection. Typical parameters that may be
reasonably expected to occur include semi-volatile organic compounds (SVOCs) and PAHs.
Surficial soils determined by such sampling to be in excess of the applicable soil remediation goals
(“SRGs”) of NCDENR’s Inactive Hazardous Sites Branch shall either (a) be removed to at least two
feet below grade and covered with clean fill, (b) capped with at least two feet of clean fill or
impervious surface, or (c) addressed in another manner approved in writing by NCDENR. The Site
Environmental Representative shall document in writing the sampling and any follow-up activity
undertaken under this Section 8.0 as each phase of the development project is completed and
sampled.

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9.0 REFERENCES

 Phase I Environmental Site Assessment, 14.27-Acre Erwin Square Parcel (the parent
property for the Site), prepared by S&ME, Inc., dated March 29, 2007
 Phase I Environmental Site Assessment, prepared by S&ME, Inc., dated October 7, 2010
 Brownfields Assessment and Receptor Survey, prepared by S&ME, Inc., dated May 17, 2011
 Revised Brownfields Assessment and Receptor Survey, prepared by S&ME, Inc., dated July 18,
2011
 Groundwater Monitoring Report, Erwin Square Site, (Former Burlington Industries Textile
Mill), 2200 West Main Street, Durham, North Carolina, prepared by Mid-Atlantic
Associates, Inc., dated July 19, 2011
Brownfield Soil Management Plan S&ME Project No. 1054-10-288C
Erwin Square / Former Burlington Industries Site, Durham, NC December 5, 2011

15
10.0 CERTIFICATION OF SITE PERSONNEL

Contractors and subcontractors working at the site shall acknowledge that they have read and
understand the preceding Brownfields Soil Management Plan and commit to complete Site-related
work activities and those Site-related work activities for employees and subcontractors under their
supervision in accordance with its provisions and procedures. Acknowledgement shall be
documented by signing the site certification in Appendix II.

FIGURES

TABLES

APPENDIX I

Selected Construction Drawings – John R. McAdams Company
CIRCLE NINTH STREET
CUT-TO-FILL MAP
12.02.11

APPENDIX II

Certification of Site Personnel
Brownfield Soil Management Plan S&ME Project No. 1054-10-288C
Erwin Square / Former Burlington Industries Site, Durham, NC December 5, 2011

APPENDIX II CERTIFICATION OF SITE PERSONNEL

By signing below, I certify that I have read this Brownfields Soil Management Plan and am
familiar with its provisions and my own proposed activities and responsibilities on site.

NAME (Signed) COMPANY DATE

APPENDIX III

Amendments to Brownfields Soil Management Plan

Brownfield Soil Management Plan S&ME Project No. 1054-10-288C
Erwin Square / Former Burlington Industries Site, Durham, NC December 5, 2011

APPENDIX III

AMENDMENTS TO BROWNFIELDS SOIL MANAGEMENT PLAN

Amendments must have the concurrence of both Crescent Ninth Street Venture I, LLC and
the NCDENR Brownfields Program prior to implementation of each amendment.

AMENDMENT EFFECTIVE SUBJECT
NUMBER DATE