20070_Scottish Rite Temple_EMP_20170217

#C-1269 Engineering
#-245 Geology

Environmental Management Plan

Scottish Rite Temple Site
4640 and 4740 Randolph Road
Charlotte, North Carolina

Brownfields Project ID: 20070-16-060

February 18, 2017
H&H Job No. GSL-002

CONTENTS

Completed EMP Template Form

Tables
Table 1 Summary of Groundwater Analytical Data
Table 2 Summary of Soil Analytical Data
Table 3 Summary of Hydraulic Oil Analytical Data

Figures
Figure 1 Site Location Map
Figure 2 Site Map
Appendices
Appendix A Preliminary Redevelopment Plan
Appendix B Cut/Fill Analysis
Appendix C Site Contingency Plan

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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: 2/18/2017

Brownfields Assigned Project Name: Scottish Rite Temple Site

Brownfields Project Number: 20070-16-060

Brownfields Property Address: 4640 & 4740 Randolph Road, Charlotte, NC 28211

Brownfields Property Area (acres): 6.1

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): CRP-GREP Overture Cotswold Owner, LLC
Phone Numbers: Office: [phone]…..Mobile: NA
Email: [e-mail]
Primary PD Contact: Josh Glover, Vice President
Phone Numbers: Office: [phone] Mobile: NA
Email:
Environmental Consultant: Hart & Hickman, PC – Matt Ingalls
Phone Numbers: Office: [phone]…..Mobile: [phone]
Email: [e-mail]
Brownfields Program Project Manager: Hayley Irick
Office: [phone]
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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:

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: Redevelopment plans include demolition of site
structures (Scottish Rite Temple and the former Jamgotch residence), building slabs, paved
driveways and parking lots for disposal at a C&D landfill. Greystar GP II, LLC plans to
redevelop the subject site with a luxury “active adult” – style senior housing community
featuring three three-story residential units, an approximate 8,500 sq ft clubhouse building,
asphalt-paved parking areas, greenspace, and landscaping. A preliminary Site Layout Plan is
included in Appendix A.

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EMP Form ver.1, October 23, 2014
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.

4) Schedule for Redevelopment (attach construction schedule):
a) Phase I start date and anticipated duration (specify activities during each phase):
3/1/2017
The final schedule for site development is not yet defined but phased construction is not
anticipated. Demolition is anticipated to begin in March 2017. Grading and foundation work are
anticipated to begin in March 2017. Construction activities are antipicipated to begin in May
2017.

b) If applicable, Phase 2 start date and anticipated duration (specify activities during each
phase): N/A

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: 6/1/2018

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 VOCs or SVOCs have been
detected in soil at concentrations exceeding Residential PSRGs. It is H&H’s opinion that detected
metals concentrations are consistent with naturally occurring background levels. The metals
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EMP Form ver.1, October 23, 2014
arsenic, barium, cadmium, chromium, lead, mercury, and selenium were detected in soil samples
collected at the site in concentrations below the Residential PSRG. Arsenic concentrations detected
in five soil samples exceeded the Residential PSRG of 0.68 mg/kg and the Industrial PSRG of 3.0
mg/kg.
2) Depth of known or suspected contaminants (feet): 0-4 ft
3) Area of soil disturbed by redevelopment (square feet): Approximately 237,250 square feet will
be graded and redistributed to level the property prior to importing fill and to implement
positive drainage flow across the property. Grading activities will be conducted in
accordance with applicable local, state, and federal regulations including submittal of an
erosion control plan to Mecklenburg County. The grading contractor will utilize grading
equipment (i.e. backhoes, front end loaders, bull dozers etc.) and the site development
contractor will implement best management practices (i.e. implementation of silt fencing
and berming) to manage soil on-site during site redevelopment activities. Any land
disturbance beyond 1 acre requires an approved sedimentation and erosion control
4) Depths of soil to be excavated (feet): Approximately 1,700 cubic yards will be cut and redistributed
on-site to depths of up to 3 ft in the southwestern and central-eastern portions of the site.
5) Estimated volume of soil (cubic yards) to be excavated (attach grading plan): Approximately
1,700 cubic yards will be cut and redistributed on-site. A site cut/fill analysis is included in Appendix
B.
6) Estimated volume of excavated soil (cubic yards) anticipated to be impacted by contaminants:
None expected.
7) Estimated volume of contaminated soil expected to be disposed of offsite, if applicable: N/A – All
site soil will be reused on-site; no soil is anticipated to be removed from the site. Although not
anticipated, if contaminated soil is identified during site development activities that requires off-site
disposal, an amendment EMP will be submitted to DEQ for approval prior to transport of
contaminated soil off-site.
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? 27,384 cubic yards
3) If yes, what is the depth of fill soil to be used at the property? Fill soil will be used to raise the
western portion of the site up to 7.5 ft. above current grade.
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)
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EMP Form ver.1, October 23, 2014
☐ 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:
☐ Known borrow material (DESCRIBE SOURCE AND ATTACH SAMPLING PROFILE): To verify
that impacted soil will not be imported on site, imported fill soil will be sampled and analyzed for the
EPA Hazardous Substance List metals, VOCs, and SVOCs before it is transported to the site. These data
will be provided to the Brownfields Program for their review and approval prior to the soil being
transported to the site. Fill soil will be considered suitable for use at the site if sample results do not
exceed the IHSB Residential PSRGs and/or published background concentrations for metals.

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

If yes, explain why below, including the level of knowledge regarding processes generating the
waste( include pertinent analytical results as needed).

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

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EMP Form ver.1, October 23, 2014
If no, explain rationale: Soil analytical data does not indicate detections that will exceed TCLP
criteria using the Rule of 20.

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 10/1/2016
☐ 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: Typical construction dust control
measures will be utilized such as wetting with water trucks or hoses to manage nuisance dust
levels.

☒ Field Screening:
☒ Yes ☐ No
If yes, describe method; If no, explain rationale: During soil disturbance at the site, the
workers or contractors will observe soils for evidence of a distinct unnatural color, strong odor,
or observance of filled or previously disposed materials of concerns (i.e. chemicals, tanks,
drums, etc). Should contamination be identified during site work, the contractor will contact the
project environmental engineer to observe the suspect condition. If the project environmental
engineer confirms that the soil may be impacted, then the procedures outlined in Appendix C
will be implemented. In addition, the environmental engineer will contact the DEQ Brownfields
project manager within two business days to advise that person of the condition.
A project environmental engineer will be present at the site during removal/closure of the
hydraulic elevator in-ground pistons and during excavation of the the empty UST located on the
Scottish Rite Temple property. Soil in the area of the hydraulic elevator in-ground pistons and
within the excavation of the empty UST located on the Scottish Rite Temple property will be
visually screened and screened using a photo-ionization detector (PID) for evidence of a
hydraulic oil or fuel oil release. If the project environmental engineer confirms that the soil may
be impacted, then the procedures outlined in Appendix C will be implemented. In addition, the
environmental engineer will contact the DEQ Browfields project manager within two business
days to advise that person of the condition.

☒ Soil Sample Collection:
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EMP Form ver.1, October 23, 2014
☒ Yes ☐ No
If yes, describe method (e.g., in-situ grab, composite, stockpile, etc.); If no, explain rationale:
Limited additional soil sampling in connection with removal of a known UST is expected based
on previous site assessment results and the historical site use (residential/institutional). If
obvious evidence of petroleum-impacted soil is identified during grading activities around the
hydraulic elevator in-ground pistons, one soil sample from each hydraulic elevator excavation
will be submitted to the laboratory for analysis of SVOCs by EPA Method 8270D, extractable
petroleum hydrocarbons (EPH) by the Massachusetts Department of Environmental Protection
(MADEP) Method, and polychlorinated biphenyls (PCBs) by EPA Method 8082A. If obvious
evidence of petroleum-impacted soil is identified during removal of the known UST, two soil
samples from the tank excavation will be submitted to the laboratory for analysis of VOCs by
EPA Method 8260B, SVOCs by EPA Method 8270D, and volatile petroleum hydrocarbons
(VPH) and EPH by the MADEP Method.
☒ 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): See above for analytical methods to
be used (if required based on field screening results) in the areas of the hydraulic elevator in-ground
pistons and the empty UST.

☒ 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
☐ Use geotextile to mark depth of fill material (provide description of material)
☒ Manage soil under impervious cap ☒ or clean fill ☒
Describe cap or fill: No such placement is currently anticipated. However, a majority of
the site grade will be raised with clean fill (below IHSB Residential PSRGs and/or background
concentrations for metals). If contaminated soil is encountered, placement will be discussed
with DEQ in advance of placement. (provide location diagram)
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EMP Form ver.1, October 23, 2014
☐ Confer with NC BF Project Manager if Brownfield Plat must be revised (or re-
recorded if actions are Post-Recordation).
☐ Other: Click here to enter text.

☒ 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: Due to the proposed residential use of
the site, shallow soil samples will be collected in “green space” areas that are not covered by a
building or parking area.
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 Click here to enter text.
☐ 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: N/A

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. Click here to enter text.
If yes, provide specifications on barrier materials

Other comments regarding managing impacted soil in utility trenches: No soil impacts were
identified during assessment activities above IHSB Residential PSRGs for VOCs/SVOCs, and/or
published background concentrations for metals at the site; therefore, no special management of
utility trench soils appears warranted. Although not anticipated, in the event contaminated soil
and/or vapors are encountered in the utility trenches during redevelopment activities, the trench will
be evacuated and appropriate safety screening of the vapors will be performed to protect workers. If
results indicate further action is warranted in response to vapors to protect workers, appropriate
engineering controls (such as use of industrial fans) will be implemented.

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? Groundwater was measured at
approximately 28 ft bgs ina temporary monitoring well advanced in the northern portion of the
site during the December 2016 Brownfields assessment.

Is groundwater known to be contaminated by ☐onsite ☐ offsite ☐ both ☒ or unknown
sources? Describe source(s): According to information obtained during our review of environmental
reports, methyl tert-butyl ether (MTBE) was detected in a groundwater sample collected from the former
water supply well located adjacent to the Jamgotch residence in January 2002. The depth of the water
supply well could not be located; however, the depth of water supply wells in the area reportedly range
from 300 to 400 ft below the ground surface (bgs). The Mecklenburg County Division of Water Quality
(DWQ) subsequently collected groundwater samples from the Jamgotch well between January 2002 and
April 2006. 1,2-dichloropropane (1,2-DCP) was identified in groundwater samples collected from the
water supply well at concentrations (1.3 to 2.7 µg/L) above the current 2L Standard of 0.6 µg/L. The
VOCs 1,1-dichloroethene (1,1-DCE, <0.25 to 0.41 µg/L) and chloroform (<0.25 to 0.34 µg/L) were also
detected in groundwater samples collected from the Jamgotch well, but at concentrations below their
current 2L Standard. MTBE was not detected above laboratory detection limits in groundwater samples
collected from the Jamgotch well after April 2002. During the recent December 2016 Brownfields assessment, VOCs, SVOCs, and metals were not detected above DEQ 2L groundwater standards in a groundwater sample collected from a shallow temporary monitoring well (TMW-1) installed adjacent to
the Jamgotch residential water supply well. TMW-1 was installed to a depth of 35 ft bgs and in a
different hydrogeologic regime than that of the deeper former Jamgotch water supply well.

What is the direction of groundwater flow at the Brownfields Property? Groundwater at the site is
expected to mimic topographic gradient and flow to the west-southwest.

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EMP Form ver.1, October 23, 2014
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): Based on the anticipated depth to groundwater, groundwater is
not anticipated to be encountered during any redevelopment activities. Although not anticipated,
if groundwater is encountered and suspected to be impacted (based on strong odor, unnatural
color, sheen, etc.), the contractor will contact the project environmental engineer to observe the
suspect condition. If the environmental engineer determines that the excavation likely contains
impacted groundwater, then appropriate worker safety measures will be undertaken to manage
groundwater that gathers in an open excavation within an area determined to be impacted during
construction activities. Surface water and accumulation of small amounts of groundwater will be
allowed to evaporate, tested and disposed off-site (if impacted); tested and discharged to the
storm sewer (if not impacted above DEQ surface water standards) per 2H .0106; or used for dust
control at the site. Discharge to the storm sewer will be in accordance with the site’s sediment
and erosion control plan. In addition, the environmental engineer will contact the DEQ
Brownfields project manager within 48 hours regarding the condition.

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?
☐ 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): If impacted surface water run-
off gathers in an open excavation determined during construction to be impacted, appropriate
worker safety measures will be undertaken. The accumulated water will be allowed to evaporate
(for surficial surface water only), tested and disposed off-site (if impacted), or tested and
discharged to the storm sewer (if not impacted above DEQ surface water standards) in
accordance with regulations. Discharge to the storm sewer will be in accordance with the site’s
sediment and erosion control plan. It may also be used on-site for dust control.

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

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EMP Form ver.1, October 23, 2014
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): The current on-site stormwater
retention basin will be filled during site grading activities.

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? Historically, 1,2-DCP has
been detected in the former Jamgotch water supply well above 2L Standards. However,
analytical results from the December 2016 Brownfields assessment indicate no VOCs or SVOCs
were detected in groundwater at the site at concentrations above 2L Standards. Therefore vapor
intrusion is not a concern for the redevelopment activities.

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
unlikely event contaminated soil vapors are encountered during redevelopment activities, the
excavation area will be evacuated and appropriate safety screening of the vapors will be
performed. If results indicate further action is warranted, appropriate engineering controls (such
as use of industrial fans) will be implemented. If a VI concern is identified, the potential need
for building vapor mitigation will be considered at that time.

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

Are sub-slab soil vapor data available for the Brownfields Property? ☐ Yes ☒ No ☐ Unknown