20018_Storage_Max_EMP_2106-1005

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EMP Form ver.1, October 23, 2014
NORTH CAROLINA BROWNFIELDS PROGRAM
ENVIRONMENTAL MANAGEMENT PLAN

This form is to be used to prepare an Environmental Management Plan (EMP) for projects in the
North Carolina Brownfields Program at the direction of a project manager for the program.
Prospective Developers and/or their consultants must complete and submit this form and all
pertinent attachments to their project manager prior to any site earthmoving or other
development related activities. For the resultant EMP to be valid for use, it must be completed,
reviewed by the program, and signed by all signers at the bottom. Consult your project
manager if you have questions.

GENERAL INFORMATION

Date: 10/5/2016

Brownfields Assigned Project Name: Storage Max VI

Brownfields Project Number: 20018-16-092

Brownfields Property Address: 1936 Wake Forest Rd

Brownfields Property Area (acres): 1.39

Is Brownfields Property Subject to RCRA Permit? ☐ Yes ☒ No
If yes enter Permit No.: Click here to enter text.

Is Brownfields Property Subject to a Solid Waste Permit? ☐ Yes ☒ No
If yes, enter Permit No.: Click here to enter text.

COMMUNICATIONS

Prospective Developer (PD): Storage Max VI
Phone Numbers: Office: …..Mobile: [phone]
Email: Allen Massey [e-mail]
Primary PD Contact: Janet Conner ([e-mail])
Phone Numbers: Office: Mobile: [phone]
Email:
Environmental Consultant: John Gallagher
Phone Numbers: Office: …..Mobile: [phone]
Email: [e-mail]
Brownfields Program Project Manager: Geof Little
Office: Raleigh
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EMP Form ver.1, October 23, 2014
Email: [e-mail]

Other DENR Program Contacts (if applicable, i.e., UST Section, Inactive Hazardous Site Branch,
Hazardous Waste, Solid Waste): Click here to enter text.

NOTIFICATIONS TO THE BROWNFIELDS PROGRAM

Advance Notification Times to Brownfields Project Manager: Check each box to accept minimum
notice periods (in calendar days) for each type of onsite task:
On-site assessment or remedial activities: Within 10 days ☒
Construction or grading start: Within 10 days ☒
Discovery of stained soil, odors, USTs, buried drums or waste, landfill, or other signs of previously
unknown contamination: Within 48 hours ☒
Implementation of emergency actions (e.g. dewatering, flood, or soil erosion control
measures in area of contamination, venting of explosive environments):
Within 48 hours ☒
Installation of mitigation systems: Within 10 days ☒
Other notifications as required by local, state or federal agencies to implement
redevelopment activities: (as applicable): Within 30 days ☒

REDEVELOPMENT PLANS

1) Type of Redevelopment (check all that apply):
☐ Residential ☐ Recreational ☐ Institutional ☒ Commercial ☒ Office ☐Retail ☐ Industrial
☒ Other specify: Self-Storage Facility with a sales/admin office

2) Summary of Redevelopment Plans (attach conceptual or detailed plans as available):
a) Do plans include demolition of structure(s)?: ☐ Yes ☒ No ☐ Unknown
b) Do plans include removal of building foundation slab(s) or pavement:
☐ Yes ☒ No ☐ Unknown
c) Provide brief summary of redevelopment plans, including demolition, removal of building
slabs/pavement and other structures: Use of an existing building to serve as an office for a self
storage facility and development of a new limited occupancy self-storage facility.

3) Which category of risk-based screening level is used or is anticipated to be specified in the
Brownfields Agreement?
☐ Residential ☒ Non-residential or Industrial/Commercial

Note: If children frequent the property, residential screening levels shall be cited in the Brownfields
Agreement for comparison purposes.
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EMP Form ver.1, October 23, 2014

4) Schedule for Redevelopment (attach construction schedule):
a) Phase I start date and anticipated duration (specify activities during each phase):
10/15/2016
Some site preparation work has been completed and construction is planned to be started on or
about October 15, 2016.

b) If applicable, Phase 2 start date and anticipated duration (specify activities during each
phase): Click here to enter a date.

c) Additional phases planned? If yes, specify activities if known:
☐ Yes ☒ No ☐ Not in the foreseeable future ☐Decision pending
d) Provide the planned date of occupancy for new buildings: 3/15/2017

CONTAMINATED MEDIA
Contaminated Media (attach tabulated data summaries for each impacted media and figure(s) with
sample locations):
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

PART 1. SOIL – Please fill out the information below, using detailed site plans, if available, or estimate
using known areas of contaminated soil and a conceptual redevelopment plan. Provide a figure
overlaying new construction onto figure showing contaminated soil and groundwater locations.

1) Known or suspected contaminants in soil (list specific compounds): No evidence of releases or
evidence of contamination has been identified in soil. No TPH DRO or GRO was measured above the
10 mg/kg DEQ action level in soil.
2) Depth of known or suspected contaminants (feet): NA
3) Area of soil disturbed by redevelopment (square feet): 40,000 sq ft or about 0.9 of an acre
4) Depths of soil to be excavated (feet): Variable as needed for grading – up to about 8 -10 ft
5) Estimated volume of soil (cubic yards) to be excavated (attach grading plan): About 2000 yds of
near-surface soil may be excavated and moved within the site for grading purposes. No impacted
contaminated soil or fill is expected to be encountered, and no excess soil is expected to be
generated – we intend to have a balanced site with no soil export and potentially some minimal
import.
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EMP Form ver.1, October 23, 2014
6) Estimated volume of excavated soil (cubic yards) anticipated to be impacted by contaminants: 0
yds – we do not expect to disturb impacted soil
7) Estimated volume of contaminated soil expected to be disposed of offsite, if applicable: 0 yds
IMPORTED FILL SOIL

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? 100 yds
3) If yes, what is the depth of fill soil to be used at the property? A small amount of fill material,
stone and other construction materials may be used
If a range of depths, please list the range.

4) PRIOR TO ITS PLACEMENT AT THE BROWNFIELDS PROPERTY, provide plan to analyze fill soil to
demonstrate that it meets acceptable standards and can be considered clean for use at the
Brownfields property (Check all that apply):
☒ Volatile organic compounds (VOCs) by EPA Method 8260
☒ Semi-volatile organic compounds (SVOCs) by EPA Method 8270
☒ Metals RCRA List (8) (arsenic, barium, cadmium, chromium (speciated), mercury, lead,
selenium and silver)
☐ Metals –Hazardous Substance List -14 (antimony, arsenic, beryllium, cadmium, chromium
(speciated according to IHSB protocol), copper, lead, manganese, mercury, nickel, selenium, silver,
thallium, and zinc)
☐ Metals – EPA Priority Pollutant List – 13 (arsenic, beryllium, cadmium, chromium (speciated
according to IHSB protocol), copper, mercury, nickel, lead, antimony, selenium, silver, thallium, and
zinc)
☐ Other Constituents & Analytical Method: Click here to enter text.
☒ Known borrow material (DESCRIBE SOURCE AND ATTACH SAMPLING PROFILE): Relatively
modest amounts of stone and other materials necessary for construction may be utilized. But
significant amounts of fill material will not be used. All material will be from known sourses and
reputable commercial suppliers. We will either have the borrow material supplier(s) provide analyses
results to demonstrate that imported fill meets acceptable standards, or we will sample and analyze
the borrow material if prior test results are not available.

MANAGING ONSITE SOIL

1) If soil in known or suspected areas of contamination is anticipated to be excavated from the
Brownfield Property, relocated on the Brownfields Property,or otherwise disturbed during site
grading or other redevelopment activities, please provide a grading plan that clearly illustrates
areas of cut and fill (approximate areas & volumes are acceptable, if only preliminary data
available).

2) HAZARDOUS WASTE DETERMINATION – Does the soil contain a LISTED WASTE as defined in the
North Carolina Hazardous Waste Section under 40 CFR Part 261.31-261.35? ☐ Yes ☒ No

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EMP Form ver.1, October 23, 2014
If yes, explain why below, including the level of knowledge regarding processes generating the
waste( include pertinent analytical results as needed). Click 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

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 DENR
HAZARDOUS WASTE SECTION RULES AND REGULATIONS.

3) HAZARDOUS WASTE DETERMINATION – Does the soil contain a CHARACTERISTIC WASTE?:
☐ Yes ☒ No
If yes, mark reason(s) why below (and include pertinent analytical results).

☐ Ignitability
☐ Corrosivity
☐ Reactivity
☐ Toxicity
☐ TCLP results
☐ Rule of 20 results (20 times total analytical results for an individual hazardous
constituent on TCLP list cannot, by test method, exceed regulatory TCLP standard)

If no, explain rationale: We may encounter and have to manage a relatively small volume of soil
associated with spoils from our foundation borings.

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

4) Screening criteria by which soil disposition decisions will be made (e.g., left in place, capped in
place with low permeability barrier, removed to onsite location and capped, removed offsite):
☐ Preliminary Health-Based Residential SRGs Click here to enter a date.
☒ Preliminary Health-Based Industrial/Commercial SRGs Click here to enter a date.
☐ Site-specific risk-based cleanup level, or acceptable concentrations determined via
calculated cumulative risk. Enter details of methods used for determination/explanation:
Click here to enter text.

5) Check the following action(s) to be taken during excavation and management of said soils:

☒ Manage fugitive dust from site:
☒ Yes ☐ No
If yes, describe method; If no, explain rationale: In accordance with general construction
standards.

☒ Field Screening:
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EMP Form ver.1, October 23, 2014
☒ Yes ☐ No
If yes, describe method; If no, explain rationale: During grading and when other subsurface
construction activities occur, field screening will be conducted periodically to check for evidence of
contamination. As needed, field screening will include the following: • Visual observations of
construction work practices that have potential to encounter areas of contamination • Visual inspection
of spoils and other soils for evidence of contamination • Use of a Multi-RAE IR Plus Gas Monitor or
equivalent instrumentation equipped with a photoionization detector (PID – equipped with a 10.6ev
lamp) that is capable of reading total volatile and lighter semi-volatile organic compounds
(VOCs/SVOCs), oxygen, carbon monoxide, hydrogen sulfide and combustible gas (0 to 100% of lower
explosive limit or LEL) concentrations. If field evidence of contamination in soils is encountered, the soil
will either be loaded out for disposal at a pre-approved licensed disposal/treatment facility or safely
stockpiled in accordance with IHSB protocol and sampled to determine if contamination exists and to
meet disposal facilty(s) requirements.

☒ Soil Sample Collection:
☒ Yes ☐ No
If yes, describe method (e.g., in-situ grab, composite, stockpile, etc.); If no, explain rationale:
On a contingent basis, if needed to arrange for off-site soil management, sample collection and
analysis will be conducted in accordance with IHSB protocol. In addition, sampling and the type of
analysis we conduct, which could include a full testing of the analytes listed below, will be informed
by the requirements of the disposal facility(s) we may utilize. However, at this time, we do not expect
to have to conduct further soil sampling and analysis.
☒ Stockpile impacted soil in accordance with NCDENR IHSB protocol in the current version of
the “Guidelines for Assessment and Cleanup”, and providing erosion control, prohibiting
contact between surface water/precipitation and contaminated soil, and preventing
contaminated runoff. Explain any variances:
Click here to enter text.
☒ Analyze potentially impacted soil for the following chemical analytes:
☒ Volatile organic compounds (VOCs) by EPA Method 8260
☒ Semi-volatile organic compounds (SVOCs) by EPA Method 8270
☒ Metals RCRA List (8) (arsenic, barium, cadmium, chromium (speciated), mercury,
lead, selenium and silver)
☐ Metals –Hazardous Substance List -14 (antimony, arsenic, beryllium, cadmium,
chromium (speciated according to IHSB protocol), copper, lead, manganese, mercury, nickel,
selenium, silver, thallium, and zinc)
☐ Metals – EPA Priority Pollutant List – 13 (arsenic, beryllium, cadmium, chromium
(speciated according to IHSB protocol), copper, mercury, nickel, lead, antimony, selenium, silver,
thallium, and zinc)
☒ Other Constituent(s) & Analytical Method(s): If required for disposal approvals.

☐ Proposed Measures to Obtain Pre-Approval for Reuse of Impacted Soil within the
Brownfields Property Boundary
☐ Provide documentation of analytical report(s) to Brownfields Project Manager
☐ Provide documentation of final location, thickness and depth of relocated soil on
site map to Brownfields Project Manager once known
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EMP Form ver.1, October 23, 2014
☐ Use geotextile to mark depth of fill material (provide description of material)
☐ Manage soil under impervious cap ☐ or clean fill ☐
Describe cap or fill: Click here to enter text. (provide location diagram)
☐ Confer with NC BF Project Manager if Brownfield Plat must be revised (or re-
recorded if actions are Post-Recordation).
☒ Other: We do not anticipate encountering impacted soils and we have no plans for
to reuse of impacted soils on-site, if present.

☐ Final grade sampling of exposed soil (i.e., soil that will not be under buildings or permanent
hardscape): [if not checked provide rationale for not needing]
Provide diagram of soil sampling locations, number of samples, and denote Chemical
Analytical Program with check boxes below (Check all that apply):
☐ Volatile organic compounds (VOCs) by EPA Method 8260
☐ Semi-volatile organic compounds (SVOCs) by EPA Method 8270
☐ Metals RCRA List (8) (arsenic, barium, cadmium, chromium (speciated), mercury,
lead, selenium and silver)
☐ Metals –Hazardous Substance List -14 (antimony, arsenic, beryllium, cadmium,
chromium (speciated according to IHSB protocol), copper, lead, manganese, mercury, nickel,
selenium, silver, thallium, and zinc)
☐ Metals – EPA Priority Pollutant List – 13 (arsenic, beryllium, cadmium, chromium
(speciated according to IHSB protocol), copper, mercury, nickel, lead, antimony, selenium, silver,
thallium, and zinc)
☐ Pesticides
☐ PCBs
☐ Other Constituents & Analytical Method: Click here to enter text.
OFFSITE TRANSPORT & DISPOSITION OF EXCAVATED SOIL
NOTE: Unless soil will be transported offsite for disposal in a permitted facility under applicable
regulations, no contaminated or potentially contaminated soil may leave the site without approval
from the brownfields program. Failure to obtain approval may violate a brownfields agreement,
endangering liability protections and making said action subject to enforcement. Justifications
provided below must be approved by the Program in writing prior to completing transport activities.
☒ Transport and dispose of impacted soil offsite (documentation of final disposition must be sent to
Brownfields Project Manager)
☒ Landfill – analytical program determined by landfill
☒ Landfarm or other treatment facility TBD
☐ Use as Beneficial Fill Offsite – provide justification: Click here to enter text.
☐ Use as Beneficial Fill at another Suitable Brownfields Site – (Note: a determination that a
site is a “Suitable Brownfields” site will require, at a minimum, that similar concentrations of the same
or similar contaminants already exist at both sites, use of impacted soil as beneficial soil will not
increase the potential for risk to human health and the environment at that site, and that notarized
documentation of the acceptance of such soil from the property owner of the receiving site is
provided to Brownfields. Provide justification: Click here to enter text.

MANAGEMENT OF UTILITY TRENCHES
☐ Install liner between native impacted soils and base of utility trench before filling with clean fill
(Preferred)
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EMP Form ver.1, October 23, 2014

☐ 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? Result: Yes □ No □
If no, include rationale here. Our VI assessment indicates no unacceptable VI risk exists –
therefore, no mitigation or barrier system is planned
If yes, provide specifications on barrier materials

Other comments regarding managing impacted soil in utility trenches: Our utility trenches are
expected to be installed in clean fill material. If there is the potential for contamination, the
management of impacted material shall be conducted in accordance with this plan.

PART 2. GROUNDWATER – Please fill out the information below and attach figure showing
distribution of groundwater contaminants at site

What is the depth to groundwater at the Brownfields Property? 36-51 feet BLS in native saprolitic
soil.

Is groundwater known to be contaminated by ☒onsite ☐ offsite ☐ both ☐ or unknown
sources? Describe source(s): We believe on-site groundwater is contaminated from the abutting BP
gas station.

What is the direction of groundwater flow at the Brownfields Property? Anticipated to be to the
east/southeast according to our site assessment findings by Hart & Hickman

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

In the event that contaminated groundwater is encountered during redevelopment activities (even if
no is checked above), list activities for contingent management of groundwater (e.g., dewatering of
groundwater from excavations or foundations, containerizing, offsite disposal, discharge to sanitary
sewer, or sampling procedures): No dewatering is expected. If groundwater will be encountered, this
plan would be amended to manage groundwater.

PART 3. SURFACE WATER – Please fill out the information below.
Attach a map showing the location of surface water at the Brownfields Property.

Is surface water at the property known to be contaminated: ☐ Yes ☒ No

Will workers or the public be in contact with surface water during planned redevelopment activities?
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EMP Form ver.1, October 23, 2014
☐ Yes ☒ No

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): NA

PART 4. SEDIMENT – Please fill out the information below.
Is sediment at the property known to be contaminated: ☐ Yes ☒ No

Will workers or the public be in contact with sediment during planned redevelopment activities?
☐ Yes ☒ No

If yes, attach a map showing location of known contaminated sediment at the property.

In the event that contaminated sediment is encountered during redevelopment activities, list
activities for management of such events (stream bed disturbance): Click here to enter text.

PART 5. SOIL VAPOR – Please fill out the information below.
Do concentrations of volatile organic compounds at the Brownfields property exceed the following
vapor intrusion screening levels in the following media:

IHSB Residential Screening Levels:
Soil Vapor: ☒ Yes ☐ No ☐ Unknown
Groundwater: ☒ Yes ☐ No ☐ Unknown

IHSB Industrial/Commercial Screening Levels:
Soil Vapor: ☒ Yes ☐ No ☐ Unknown
Groundwater: ☒ Yes ☐ No ☐ Unknown

Attach a map showing the location of soil vapor contaminants that exceed site screening levels.

If applicable, at what depth(s) is soil vapor known to be contaminated? Please refer to the attach VI
assessment report

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:

PART 6. SUB-SLAB SOIL VAPOR -please fill out the information below if existing buildings or
foundations will be retained in the redevelopment.

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EMP Form ver.1, October 23, 2014
Are sub-slab soil vapor data available for the Brownfields Property? ☒ Yes ☐ No ☐ Unknown

If data indicate that sub-slab soil vapor concentrations exceed screening levels, attach a map showing
the location of these exceedances.

At what depth(s) is sub-slab soil vapor known to be contaminated? ☐ 0-6 inches ☒ Other, If other
describe: Please see the attached VI report

Will workers encounter contaminated sub-slab soil vapor during planned redevelopment activities?
☐ Yes ☒ No ☐ Unknown

In the event that contaminated soil vapor is encountered during redevelopment activities, list
activities for management of such contact: We have no evidence that an unacceptable VI risk exists.

PART 7. INDOOR AIR – Please fill out the information below .

Are indoor air data available for the Brownfields Property? ☐ Yes ☒ No ☐ Unknown

If yes, attach a map showing the location where indoor air contaminants exceed site screening levels.

If the structures where indoor air has been documented to exceed risk-based screening levels will not
be demolished as part of redevelopment activities, will workers encounter contaminated indoor air
during planned redevelopment activities?
☐ Yes ☒ No ☐ Unknown

In the event that contaminated indoor air is encountered during redevelopment activities, list
activities for management of such contact: N/A

PART 8 – Vapor Mitigation System – Please fill out the information below .

Is a vapor intrusion mitigation system proposed for this Brownfields Property?
☐ Yes ☒ No ☐ Unknown

If yes, provide the date the plan was submitted to the Brownfields Program.
We have no evidence that an unacceptable VI risk exists. Please refer to the attached VI
assessment report.
Attach the plan.

Has the vapor mitigation plan been approved by the NC Brownfields Program?
☐ Yes ☒ No ☐ Unknown
Has the vapor mitigation plan been signed and sealed by a North Carolina professional engineer?
☐ Yes ☒ No

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EMP Form ver.1, October 23, 2014
What are the components of the vapor intrusion mitigation system?
☐ Sub-slab depressurization system
☐ Sub-membrane depressurization system
☐ Block-wall depressurization system
☐ Drain tile depressurization system
☐ Passive mitigation methods
☐ Vapor barriers
☐ Perforated piping vented to exterior
☐ Other method: N/A

PART 9. CONTINGENCY FOR ENCOUNTERING UNKNOWN TANKS, DRUMS, OR OTHER WASTE
MATERIALS

Please provide a contingency plan in the event unknown tanks, drums, fuel lines, landfills, or other
waste materials are encountered during site activities.

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

Notification to State Brownfields Project Manager, UST Section, Fire Department, and/or other
officials, as necessary and appropriate, is required when new potential source(s) of contamination are
discovered. See Notification Section on Page 1 for notification requirements.

POST-REDEVELOPMENT REPORTING
In accordance with the site’s Brownfield Agreement, provide a report within the designated schedule
to the State Brownfields Project Manager.

☒ Check box to acknowledge consent to provide a redevelopment summary report in compliance
with the site’s Brownfields Agreement.