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HomeMy WebLinkAbout21015 Five Point EMP_Revised 2018.10.251 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: 10/25/2018 Brownfields Assigned Project Name: Five Points Gateway Redevelopment Brownfields Project Number: 21015-17-090 Brownfields Property Address: 320-322 E. Franklin Street, Monroe NC 28112 Brownfields Property Area (acres): Approx. 1.8 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): City of Monroe, a North Carolina Municipal Corporation Phone Numbers: Office: 704-2921705 X6040…..Mobile: Email: bborne@monroenc.org Primary PD Contact: Brian Borne Phone Numbers: Office: 704-2921705 X6040 Mobile: Click here to enter text. Email: Environmental Consultant: Resolve Environmental Services, PLLC Phone Numbers: Office: 704-289-5881…..Mobile: 704-617-1730 Email: resolve@carolina.rr.com Brownfields Program Project Manager: Carolyn Minnich Office: 704-661-0330 2 EMP Form ver.1, October 23, 2014 Email: Carolyn.Minnich@ncdenr.gov Other DENR Program Contacts (if applicable, i.e., UST Section, Inactive Hazardous Site Branch, Hazardous Waste, Solid Waste): UST Section: Edward Leach 704-235-2171 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: Final redevelopment plans have not been finalized. At this time, the City of Monroe plans to demolish both existing buildings on the property (located 320 and 322 E. Franklin St) prior to any future property development. The City will maintain the concrete and/or asphalt cap on the property until further development of the property. In the meantime, the capped property may be utilized as a parking lot. Any demolition and/or renovation of any or all buildings on the Brownfields Property shall be in accordance with applicable legal requirements, including without limitation those related to lead and asbestos abatement that are administered by the Health Hazards Control Unit within the Division of Public Health of the North Carolina Department of Health and Human Services. 3 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): 7/3/2017 The building at 320 E. Franklin St. will be demolished, including the building slab, without prior soil sampling. The building at 322 E. Franklin St. will be demolished without prior soil sampling, but the slab will be left intact until soil sampling has taken place at the site as described herein. Three coreholes will be drilled through the 322 E. Franklin St. building slab and subslab soil samples will be collected at a depth of approximately 0.5 feet below grade surface. Three additional samples will be collected from a depth of 0.5 feet below the removed slab at 322 E. Franklin St. Soil sampling will be limited to 6 soil samples for VOCs by EPA Method 8260, SVOCs by EPA Method 8270 and eight (8) RCRA metals including trivalent and hexavalent chromium. A 1,500-foot radius receptor survey will also be completed. b) If applicable, Phase 2 start date and anticipated duration (specify activities during each phase): Unknown. No Phase 2 investigation is planned at this time. 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: Unknown. No new buildings are planned at this time. 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 4 EMP Form ver.1, October 23, 2014 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): TCE (known) and petroleum compounds (suspected) 2) Depth of known or suspected contaminants (feet): 8 feet 3) Area of soil disturbed by redevelopment (square feet): None at this time. Current plans are to demolish the existing buildings as described herein and maintain the concrete and/or asphalt cap at the property until the property is further developed. Final property development plans have yet to be determined. 4) Depths of soil to be excavated (feet): Likely less than 1 foot during initial demo work. 5) Estimated volume of soil (cubic yards) to be excavated (attach grading plan): Less than 10 yards. During foundation removal at 322 E Franklin Street, soil will be shaken off, scraped off, knocked off or otherwise removed from the debris leaving the Brownfields site. No soils will be exported from the site. 6) Estimated volume of excavated soil (cubic yards) anticipated to be impacted by contaminants: None 7) Estimated volume of contaminated soil expected to be disposed of offsite, if applicable: None 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? Proposed demoliton of the buildings does not include any disturbance to the soils at the site. Only soils that may adhere to foundation materials will be removed. Once the vertical structure at 320 E. Franklin Street is removed, the basement of the structure will be backfilled with clean fill material to grade level. The fill material will be sampled at the borrow pit to ensure that no contamination is present. 3) If yes, what is the depth of fill soil to be used at the property? The depth of the fill soil will be the floor of the basement at 320 E. Franklin Street which is estimated at a depth of 10 feet below grade level. 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) 5 EMP Form ver.1, October 23, 2014 ☒ Other Constituents & Analytical Method: Chromium (Tri & Hex) ☒ Known borrow material (DESCRIBE SOURCE AND ATTACH SAMPLING PROFILE): The source of the borrow material will be determined by the chosen demolition contractor. A sampling profile will be submitted prior to the import of the soil. 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). 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: The known concentration of TCE does not exceed the NCDEQ’s Unrestricted Use Health Based PSRG. 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. 6 EMP Form ver.1, October 23, 2014 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 1/1/2020 ☒ Preliminary Health-Based Industrial/Commercial SRGs 1/1/2020 ☐ Site-specific risk-based cleanup level, or acceptable concentrations determined via calculated cumulative risk. Enter details of methods used for determination/explanation: Final development plans for the site may include recreational area(s. Screening using the residential RSGs will be conducted in these areas.) 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: Current data for soil contamination at the site , including the depth of the contamination does not warrant fugitive dust management. Significant areas of contaminated soil are not expected to be encountered or disturbed during future Site redevelopment activities based upon previous Phase I Assessment. The demolition contractor will take into account conditions such as wind speed, wind direction, to minimize dust generation. In the unlikely event that contaminated soil is encountered during Site redevelopment that requires excavation, particular attention will be paid by contractors to implement dust control measures as needed based on Site and atmospheric conditions (i.e. by controlled water application, hydro-seeding, and/or mulch, stone, or plastic cover). Potentially impacted soil will be managed as described below. ☐ Field Screening: ☐ Yes ☒ No If yes, describe method; If no, explain rationale: All excavated soils will be stockpiled and sampled. During soil disturbance at the Brownfields Property, the workers or contractors will observe soils for evidence of potential significantly impacted soil that may not be suitable to leave in place in exposed areas at an industrial/commercial use Site. Evidence of potential significant impacted soil includes a distinct unnatural color, staining, strong odor, or filled or previously disposed materials of concerns (i.e. chemicals, tanks, drums, etc.). Should the above be noted during Site work, the contractor will contact the project environmental engineer to observe the suspect condition. If the project environmental engineer confirms that the material may be impacted, the environmental engineer will contact the DEQ Brownfields project manager within two business days to advise that person of the condition. ☒ Soil Sample Collection: ☒ Yes ☐ No If yes, describe method (e.g., in-situ grab, composite, stockpile, etc.); If no, explain rationale: All excavated soils, if any, will be stockpiled and sampled prior to reuse or disposal. ☒ 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: 7 EMP Form ver.1, October 23, 2014 Soils may be loaded directly onto trucks and transported to a permitted disposal facility. if appropriate. ☒ 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. ☐ 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: Current plans are to demolish the existing buildings as described herein and maintain the concrete and/or asphalt cap at the property until the property is further developed. Final property development plans have yet to be determined. (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 8 EMP Form ver.1, October 23, 2014 ☐ 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 Id allowable concentruions of contaminats of concern do not exceed the landfarm’s permit requirements. ☐ Use as Beneficial Fill Offsite – provide justification: All unrestricted end use soils may be reutilized on-site. ☐ 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) ☒ 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: Click here to enter text. 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? Approximately 10-15 feet Is groundwater known to be contaminated by ☒onsite ☐ offsite ☐ both ☒ or unknown sources? Describe source(s): on-site and potential off-site sources 9 EMP Form ver.1, October 23, 2014 What is the direction of groundwater flow at the Brownfields Property? Unknown Will groundwater likely be encountered during planned redevelopment activities? ☐ Yes ☒ No If yes, describe these activities: Ground water is not anticipated to be encountered during demolition of the buildings as described herein. Final property development plans have yet to be determined. 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): Any ground water requiring removal will be placed in a frac tank and transported to a permitted disposal facility. 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): N/A 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 surface water located on 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 10 EMP Form ver.1, October 23, 2014 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? 8’-15’ 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: All current redevelopment activities (i.e., demolition of existing buildings) will be conducted outdoors which will limit potential exposure. 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: Unknown. 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: All current redevelopment activities (i.e., demolition of existing buildings) will be conducted outdoors which will limit potential exposure. 11 EMP Form ver.1, October 23, 2014 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: All current redevelopment activities (i.e., demolition of existing buildings) will be conducted outdoors which will limit potential exposure. 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. 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 c Brownfields Project 13 EMP Form ver.1, October 23, 2014 Date :11/10/16 8260B Sample ID Date Collected Sample Depth (in feet) TMW-1-10'10 <0.10 6.5 39.0 TMW-2-10'10 <0.0019 10.4 15.9 TMW-4-8'8 0.138 5.7 29.7 TMW-5-5'5 NR 12.2 20.0 0.019 NE 5.4 4.6 NE 47 0.018 0.67 0.30 • NE: Not established. • J: Estimated concentration. • NR: Analysis not requested. • <: Less than the method detection specified in the laboratory report.ArsenicChromiumIHSB PSRGs (mg/kg) • IHSB PSRG: Inactive Hazardous Sites Branch Preliminary Soils Remediation Goals (September 2014 addition). • Results reported in mg/kg. • MSCC: Maximum soil contaminant concentrations. TABLE 1 SUMMARY OF SOIL SAMPLE ANALYTICAL RESULTS 320-322 E. FRANKLIN STREET Analytical Method  Contaminant of Concern Trichloroethylene6010D • Concentrations in bold face type exceeded the MSCCs and/or the IHSB PSRGs. 10/27/16 NCDEQ Soil-to-Groundwater MSCCs (mg/kg) NCDEQ Residential MSCCs (mg/kg) Notes: 7470A Sample ID Date Collected (m/dd/yy) TMW-1 1,570 301 369 2,530 1,150 213 65.1 362 83.1 380 3,230 977 172 111 237 419 1,030 3,090 5.0 TMW-2 <0.20 <0.20 <0.25 <0.56 <1.0 <0.43 <0.28 <0.33 <0.28 <0.20 <0.20 <0.20 <0.31 <0.44 <0.44 <500 1,280 1,650 2.7 TMW-3 1,740 2,180 986 5,350 1,520 80.5 <5.7 277 91.7 392 1,510 984 <6.3 204 436 216 569 1,710 1.5 TMW-5 NR NR NR NR NR NR NR NR NR NR NR NR NR NR NR 23.0 37.3 29.7 <0.50 1 600 600 500 6 70 0.4 70 25 70 400 400 0.03 1 30 10 10 15 1 5,000 260,000 84,500 85,500 6,000 6,900 400 25,000 11,700 30,000 28,500 25,000 30 1,000 12,500 NE 10,000 15,000 NE 15.9 3,840 34.9 76.9 34.8 NE 22.4 NE NE NE 5.80 NE 2.03 NE NE NE NE NE 0.178 Notes: • MAC: Maximum allowable concentration specified in T15A NCAC 2L .0202. • GCL: Gross contamination level. • GWSL: Ground water screening level specified in the Division of Waste Management Residential Vapor Instrusion Screening Concentrations (March 2016). • < : Less than the method detection limit specified in the laboratory report. • Concentrations in boldface exceed the 2L Standard. • A concentration of acetone was reported in TMW-3; however, the concentration does not exceed the 2L Standard. • NR: Analysis not requested. 1,3,5-TrimethylbenzeneVinyl Chloride2-Methylnaphthalene1-Methylnaphthalene8260B 8270D NaphthaleneTolueneEthylbenzeneXylenes1,2,4-Trimethylbenzene1,2-DichloroethaneIsopropylbenzenep-Isopropyltoluenen-Propylbenzene10/27/2016 6010C GCL (µg/L) Contaminant of Concern BenzeneChromiumLeadn-ButylbenzeneGWSL (µg/L)Mercury2L Standard (MAC) (mg/L) • NE: Not established. • Results reported in ug/L (micrograms per Liter). TABLE 2 SUMMARY OF GROUND WATER SAMPLING RESULTS 320-322 E. FRANKLIN STREET ArsenicAnalytical Method  Page 2 of 2