14024_ Edwards EMP final 20170626

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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: 6/23/2017

Brownfields Assigned Project Name: Edwards Property

Brownfields Project Number: 14024-10-60

Brownfields Property Address: 10211-10311 Rozzelle’s Ferry Road, Charlotte, Mecklenburg County, NC

Brownfields Property Area (acres): 2.511

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): Laurence Development, Inc.
Phone Numbers: Office: …..Mobile: [phone]
Email: [e-mail]
Primary PD Contact: Larry Bearden
Phone Numbers: Office: Click here to enter text. Mobile: [phone]
Email:
Environmental Consultant: Mid-Atlantic Associates, Inc./Greg D. Icenhour, PG
Phone Numbers: Office: [phone]…..Mobile: [phone]
Email: [e-mail]
Brownfields Program Project Manager: Carolyn Minnich
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: Click here to enter text.

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 includes abandonment of 3 existing
groundwater monitoring wells, surface vegetation and the placement of structural fill to
construct a single story, slab on grade, metal building with an exterior finishing insulation
system (EFIS) front façade, commercial structure encompassing approximately 7,225 square
feet. Development will include construction of associated asphalt entry ways, drive ways and
parking space. The site grading plan is included as an attachment.

3) Which category of risk-based screening level is used or is anticipated to be specified in the
Brownfields Agreement?
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EMP Form ver.1, October 23, 2014
☐ 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):
8/1/2017

b) If applicable, Phase 2 start date and anticipated duration (specify activities during each
phase):
Phase II (construction) beginning immediately following completion of Phase I (site
preparation) with the project completed before 12/30/2017.

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: 12/30/2017

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): Metals have been detected in
soil at the Property. They include lead, arsenic, antimony, cobalt, iron, manganese, thallium and
vanadium; however, only lead and arsenic exceed the industrial/commercial screening limits.
Specifically, arsenic levels are considered naturally occurring and not included in the brownfields
agreement. The IHSB’s tabulated generic unrestricted use preliminary remediation goal
(“remediation goal” or “screening level”) for arsenic is 4.4 mg/kg. However, the IHSB generic
preliminary remediation goal conservatively assumes the presence of additional soil contaminants
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EMP Form ver.1, October 23, 2014
that have the same health effects, a factor not present at this site. The IHSB guidelines also allow for
the development of site-specific remediation goals when appropriate. The impacted soils are within
the “Area of Potential Soil Contamination” delineated on the plat map, a copy of which is included
as an attachment.
2) Depth of known or suspected contaminants (feet): 0’-12’
3) Area of soil disturbed by redevelopment (square feet): 0
4) Depths of soil to be excavated (feet): 0
5) Estimated volume of soil (cubic yards) to be excavated (attach grading plan): 0
6) Estimated volume of excavated soil (cubic yards) anticipated to be impacted by contaminants: 0
7) Estimated volume of contaminated soil expected to be disposed of offsite, if applicable: 0
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? Approx. 5,000 cy
3) If yes, what is the depth of fill soil to be used at the property? Between 4’-11’ above existing
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)
☐ 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): The borrow
source(s) are currently being evaluated. The source site will be identified and a sampling plan will be
sent to NCDEQ prior to placement of any off-site fill on the Brownfields Property.

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
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EMP Form ver.1, October 23, 2014
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). Previous TCLP results > 5 mg/kg

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: Click here to enter text.

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:
No soil below 18-inches will be affected. Grading contractor estimates that removal of the
upper 8” of residual soil will be sufficient to remove the organic matter and root mat. Pursuant to the
existing Brownfields Agreement, soils within the upper 18” can be disturbed.

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EMP Form ver.1, October 23, 2014
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: The grading contractor will take into
account conditions such as wind speed, wind direction, and moisture content of soil during grading
activities to minimize dust generation. As necessary, dust suppression will be achieved by a water-
mist application from containerized water to be located on site.

☐ Field Screening:
☒ Yes ☐ No
If yes, describe method; If no, explain rationale: During soil disturbance at the Site, the
workers or contractors will observe the soils for evidence of potential impacted soil with unnatural
color or strong odor. During Site work, the contractor will contact the project environmental manager
to observe the suspect condition. If the project environmental manager confirms that the material
may be impacted, then DEQ will be contacted within 2 business days to advise on how it was handled.

☐ Soil Sample Collection:
☒ Yes ☐ No
If yes, describe method (e.g., in-situ grab, composite, stockpile, etc.); If no, explain rationale:
Imported soil are being sampled prior to being placed on the Brownfields Property.
☒ 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:
The only impacted soil anticipated to be generated is from the root balls of
existing small capiler trees which penetrate into the restricted soil zone.
Only one tree has been identified within the footprint of the planned
construction activities. The root ball from this tree, when removed, will be
containerized and disposed of at a Subtitle D landfill facility. Disposal
records will be provided to NCDEQ.
☐ 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): Click here to enter text.
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EMP Form ver.1, October 23, 2014

☐ 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: 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: 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: The clean structural fill material brought
onto the site from an off-site source will be sampled prior to its placement on the Brownfields
Property.
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
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EMP Form ver.1, October 23, 2014
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)

☐ 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. Vapor barriers will be installed relative to standard building practices
for moisture control; however, these will be installed between the clean structural fill material and
the building slab.
If yes, provide specifications on barrier materials

Other comments regarding managing impacted soil in utility trenches: Given the amount of
structural fill material necessary to bring the building up to an acceptable grade, all utilities will be
installed in the clean structural fill material and not in the exisiting soil.

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? 5’ – 10’ below exsiting grade

Is groundwater known to be contaminated by ☒onsite ☐ offsite ☐ both ☐ or unknown
sources? Describe source(s): Groundwater samples have indicated metal concentrations including
chromium, lead, iron and manganese. Groundwater contaminants are shown on the attached Exhibit
2 from the Brownfields Agreement.

What is the direction of groundwater flow at the Brownfields Property? Based on previous
investigations conducted by others, groundwater flow direction is to the west-southwest.

Will groundwater likely be encountered during planned redevelopment activities? ☐ Yes ☒ No
If yes, describe these activities: Click here to enter text.

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): Collect characteristic groundwater sample from the excavation;
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EMP Form ver.1, October 23, 2014
dewater collection area using a vac-truck and dispose of water off-site at the appropriate facility
pending analytical results.

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): No surface water at site

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): No sediment located at site

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? NA

Will workers encounter contaminated soil vapor during planned redevelopment activities?
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EMP Form ver.1, October 23, 2014
☐ 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:
Contaminant at site is lead, no volatiles to be encountered

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

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: Click here to enter text.

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: Click here to enter text.

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: Click here to enter text.

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

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EMP Form ver.1, October 23, 2014
If yes, provide the date the plan was submitted to the Brownfields Program.
Click here to enter a date.
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

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: Click here to enter text.

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.

VICINITY MAP
ANNE ROZZELLE EDWARDS
RECOMBINATION SURVEY FOR:
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SOUTHERN PIEDMONT, INC.
SKETCH GRADING PLAN
Mecklenburg County North Carolina
O'REILLY AUTO PARTS
SKETCH GRADING PLAN
Mecklenburg County North Carolina
O'REILLY AUTO PARTS
G:\Larry Bearden\1147-002-Mt Holly\dwgs\survey.dwg, 4/26/2017 10:06:28 AM, For Pricing Only Not for Construction