22059 - GSK - Approved Revised EMP 9.2.2020

Environmental Management Plan
GlaxoSmith Kline, LLC
Brownfields Project No. 22059-18-032
3029 E. Cornwallis Road
Durham, North Carolina
H&H Job No. TKC-005
Revised September 2, 2020
hart 19 hickman
SMARTER ENVIRONMENTAL SOLUTIONS
#C-1269 Engineering
#C-245 Geoloav
2923 South Tryon Street, Suite 100 3921 Sunset Ridge Rd, Suite 301
Charlotte, NC 28203 Raleigh, INC 27607 www.harthickman.com
704.586.0007 main 919.847.4241 main

Completed EMP Template Form
CONTENTS
Figures
Figure 1 NCBP Diagram for Temporary Containment of Impacted or Potentially
Impacted Soil
Figure 2 Site Location Map
Figure 3 Site Map
Figure 4 Abandoned Well Location Map
Appendices
Appendix A Phase I Redevelopment Grading Plan and Cut -Fill Analysis
Appendix B RCRA Corrective Action Figures
Appendix C Regulatory Correspondence
hart hickman
SMARTER ENVIRONMENTAL SOLUTIONS

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 Brownfields project manager.
The EMP is a typical requirement of a Brownfields Agreement (BFA). Its purpose is to clarify
actions to be taken during the demolition and construction at Brownfields properties in an
effort to avoid delays in the event of the discovery of new contamination sources or other
environmental conditions. The EMP provides a means to document redevelopment plans and
environmental data for each applicable environmental medium to inform regulatory -compliant
decision -making at the site. As much detail as possible should be included in the EMP,
including contingency planning for unknowns. Consult your project manager if you have
questions.
Prospective Developers and/or their consultants must complete and submit this form and all
pertinent attachments, see checklist below, to their Brownfields project manager prior to any
earthmoving or other development -related activities that have the potential to disturb soil at
the Brownfields Property, including demolition. For the resultant EMP to be valid for use, it
must be completed, reviewed by the program, signed by all parties working on the project,
and approved by the Brownfields project manager. Failure to comply with the requirements of
the EMP could jeopardize project eligibility, or in the event of a completed agreement, be
cause for a reopener
So that the EMP provides value in protecting brownfields eligibility and public health, the
preparer shall ensure that the following steps have been completed prior to submitting the
EMP for review. Any EMP prepared without completing these steps is premature.
® Site sampling and assessment that meets Brownfields' objectives is complete and has
been reviewed and approved by the Brownfields Project Manager.
® Specific redevelopment plans, even if conceptual, have been developed for the project,
submitted and reviewed by the Brownfields Project Manager.
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Please submit, along with the completed EMP form, the following attachments, as relevant
and applicable to the proposed redevelopment:
® A set of redevelopment plans, including architectural/engineering plans, if available; if
not conceptual plans may suffice if updated when detailed plans are drafted.
® A figure overlaying redevelopment plans on a map of the extent of contamination for
each media.
® Site grading plans that include a cut and fill analysis.
❑ A figure showing the proposed location and depth of impacted soil that would remain
on site after construction grading.
❑ Any necessary permits for redevelopment (i.e. demolition, etc.).
❑ A detailed construction schedule that includes timing and phases of construction.
❑ Tabulated data summaries for each impacted media (i.e. soil, groundwater, soil gas,
etc.) applicable to the proposed redevelopment.
® Figures with the sampling locations and contamination extents for each impacted media
applicable to the proposed redevelopment.
❑ A full final grade sampling and analysis plan, if the redevelopment plan is final.
❑ If known, information about each proposed potential borrow soil source, such as aerial
photos, historic site maps, historic Sanborn maps, a site history, necessary for
brownfields approval.
❑ Information and, analytical data if required, for quarries, or other borrow sources,
detailing the type of material proposed for importation to the Brownfields Property.
❑ A work plan for the sampling and analysis of soil to be brought onto the Brownfields
Property. Refer to Issue Resolution 15 in Brownfields Program Guidelines.
❑ A map of the Brownfields Property showing the location of soils proposed for export
and sampling data from those areas.
❑ If a Vapor Mitigation System is required by the Brownfields Program, the Vapor
Intrusion Mitigation System (VIMS) plan will be signed and sealed by a NC Professional
Engineer. The VIMS Plan may also be submitted under separate cover.
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Date: 5/31/2019
GENERAL INFORMATION
Revision Date (if applicable): 9/2/2020
Brownfields Assigned Project Name: GlaxoSmithKline, LLC
Brownfields Project Number: 22059-18-032
Brownfields Property Address: 3029 East Cornwallis Road, Durham, Durham County, North Carolina
(Figure 2)
Brownfields Property Area (acres): 104.64 acres
Is Brownfields Property Subject to RCRA Permit? ....................... ® Yes ❑ No
If yes enter Permit No.: NCD052547635
Is Brownfields Property Subject to a Solid Waste Permit ............ ❑ Yes ® No
If yes, enter Permit No.: Click or tap here to enter text.
COMMUNICATIONS
A copy of this EMP shall be distributed to all the parties below as well as any contractors or site workers
that may be exposed to site vapors, soil, groundwater, and/or surface water. Additionally, a copy of the
EMP shall be maintained at the Brownfields Property during redevelopment activities. NOTE, THE EMP
DOES NOT TAKE THE PLACE OF A SITE -SPECIFIC HEALTH AND SAFETY PLAN.
Prospective Developer (PD): TKC — 3029 Holdings, LLC
Contact Person: James F. Harrell
Phone Numbers: Office: [phone]
Email: [e-mail]
Contractor for PD: Choate Construction
Contact Person: Brent Long
Phone Numbers: Office: [phone]
Email: [e-mail]
Environmental Consultant: Hart & Hickman, PC
Contact Person: Justin Ballard
Phone Numbers: Office: [phone]
Email: [e-mail]
Brownfields Program Project Manager: Brad Atkinson
Phone Numbers: Office: [phone]
Email: [e-mail]
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Mobile: [phone]
Mobile: Click or tap here to enter text.
Mobile: [phone]
Mobile: _lick or tap here to enter text.

Other DEQ Program Contacts (if applicable, i.e., UST Section, Inactive Hazardous Site Branch,
Hazardous Waste, Solid Waste):
Carl Utterback— Hazardous Waste ([e-mail]; 919-707-8212)
Rob McDaniel — Hazardous Waste ([e-mail]; 919-707-8215)
Michael Rogers — Division of Water Resources ([e-mail]; 919-707-3668)
NOTIFICATIONS TO THE BROWNFIELDS PROGRAM
Written advance Notification Times to Brownfields Project Manager: Check each box to accept
minimum advance notice periods (in calendar days) for each type of onsitetask:
On -site assessment or remedial activities: .................................................... 10 days Prior
Construction or grading start: .......................................................................... 10 days Prior
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, ventilation of work zones): ................................... Within 48 hours
Installation of mitigation systems: ................................................................ 10 days Prior ❑
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:
The Site will be improved with mixed -use built -to -suit development. Although specifics
regarding exact uses are unknown at this time, it is expected that future uses will consist of
office, laboratory research and development, and/or light research manufacturing.
2) 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
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3) Summary of Redevelopment Plans (MANDATORY: attach detailed plans or conceptual plans, if
detailed plans are not available. EMP review without such information would be premature):
Provide brief summary of redevelopment plans, including demolition, removal of building
slabs/pavement, grading plans and planned construction of new structures:
Redevelopment plans for the Site include construction of up to approximately 680,000 square
feet (sq ft) of building footprint and approximately 680,000 to 1,500,000 sq ft of vertical building
square footage. Current redevelopment plans are for a phased approach with Phase I
redevelopment (proposed four buildings) generally occurring in the northeastern, eastern, and
southeastern portions of the Brownfields property, and Phase II redevelopment (proposed four
buildings) occurring in the northwestern, western, and southwestern portions of the Brownfields
property (Figure 3). Phase I redevelopment plans include demolition of existing parking areas, a
fire suppression system pump house in the southwestern portion of the Site property, and an
approximately 12,600 sq ft building (known as Warehouse B) in the north -central portion of the
Site property (Figure 3). Cementitious material derived from demolition activities will be re -used
on -Site as beneficial fill during grading activities. Development for both phases include plans to
improve the Brownfields property with parking areas, access roads, and open spaces. Phase II
Redevelopment plans will be provided in a future update to this EMP. Copies of the current
Phase I redevelopment grading plan and cut/fill analysis are included in Appendix A.
4) Do plans include demolition of structure(s)?:
® Yes ❑ No ❑ Unknown
® If yes, please check here to confirm that demolition will be conducted 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. If available, please
provide a copy of your demolition permit.
5) Are sediment and erosion control measures required by federal, state, or local regulations?
® Yes ❑ No ❑ Unknown
® If yes, please check here to confirm that demolition will be conducted in accordance with
applicable legal requirements. If soil disturbance is necessary to install sediment and erosion
control measures, they may not begin until this EMP is approved.
6) Which category of risk -based screening level is used or is anticipated to be specified in the
Brownfields Agreement? Note: If children frequent the property, residential screening levels shall
be cited in the Brownfields Agreement for comparison purposes.
❑ Residential ® Non -Residential or Industrial/Commercial
7) Schedule for Redevelopment (attach construction schedule):
a) Construction start date: 9/1/2019
b) Anticipated duration (specify activities during each phase):
Redevelopment activities for Phase I are expected to occur for approximately two to three
years.
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c) Additional phases planned? ❑ Yes ❑ No
If yes, specify the start date and/or activities if known:
Start Date: To be determined
Planned Activity:
Current Phase II redevelopment activities will include construction of buildings, parking areas,
access roads, and open spaces.
Start Date: ELK UI Ldp LU enter a date.
Planned Activity:
"ick or tar, nere to enter text.
Start Date: Click or tap to enter a date.
Planned Activity:
Click or tap here to enter text.
d) Provide the planned date of occupancy for new buildings: To Be Determined
CONTAMINATED MEDIA
1) Contaminated Media on the Brownfields Property
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
2) For the Area of Proposed Redevelopment on the Brownfields Property, attach tabulated data
summaries for each impacted media and figure(s) with sample locations.
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 general groups of contaminants):
Since the mid-1980s, Site investigations have been completed at the Brownfields property as
part of corrective action activities under Resource Conservation and Recovery Act (RCRA) Permit
NCD052547635. The RCRA Permit is currently held by GlaxoSmithKline (GSK). Corrective action
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activities have identified multiple Solid Waste Management Units (SWMUs) and Areas of
Concern (AOC). In general, the SWMUs and AOCs represent areas where manufacturing
processes, chemical storage, surface impounding, landfilling, stormwater management, and
wastewater treatment were performed.
Historical soil assessment activities conducted at the Brownfields property have identified the
presence of polychlorinated biphenyls (PCBs) and volatile organic compounds (VOCs) in the
SWMUs and AOCs. PCBs were also identified in areas outside of the SWMUs and AOCs as a
potential result of termite and dust management practices performed historically in the northern
portion of the Brownfields property. Specifically, PCBs detected during historical soil assessment
activities have included Aroclors 1232, 1242, 1248, 1254, and 1260. According to the September
2015 Construction Completion Report — Soil Excavation for PCB Remediation and RCRA Corrective
Action (Construction Completion Report) prepared by Golder Associates NC, Inc. (Golder), PCB
assessment and remediation activities were managed in accordance with United States
Environmental Protection (EPA) guidance under the Toxic Substances Control Act (TSCA).
The Construction Completion Report documented soil excavation activities completed at 13
SWMUs and AOCs and areas outside of the SWMUs and AOCs where PCBs were detected at or
above the TSCA High Occupancy Standard (HOS) of 1 milligram per kilogram (mg/kg). In general,
excavations were performed at depths ranging from approximately 1 foot below ground surface
(ft bgs) to 13 ft bgs. Results of post -excavation sampling indicated PCBs in soil had been
remediated to below the HOS in 11 SWMUs and AOCs, as well as the previously identified areas
outside of the SWMUs and AOCs. In addition, results of pre -and post -excavation sampling
indicated PCBs in soil are below the July 2020 North Carolina Department of Environmental
Quality (DEQ) Inactive Hazardous Sites Branch (IHSB) Industrial/Commercial Preliminary Soil
Remediation Goals (PSRGs) from sampled areas within the Phase I Limits of Disturbance shown
on Figure 3 and Figure 1 from the Construction Completion Report, which is included in Appendix
B.
PCBs in soil at SWMU-12 and SWMU-13 were remediated to >1 mg/kg and <_ 10 mg/kg, the TSCA
High Occupancy Area cleanup level for areas with an appropriate soil cover. As such, these areas
are covered with an 18-inch soil cover (SWMU-12) and a 24-inch soil cover (SWMU-13) that must
be maintained as part of TSCA requirements under land use restrictions recorded with the
property deed. Note that redevelopment activities are not proposed for the SWMU-12 and
SWMU-13 areas at this time, however, should redevelopment activities be proposed for these
areas in the future, DEQ Brownfields, DEQ Hazardous Waste, and EPA Region 4 will be notified in
advance for DEQ and EPA approval. The locations of deed restricted areas SWMU-12 and
SWMU-13 are shown on Figure 3. The deed restricted areas and areas remediated to below the
TSCA HOS are shown on Figure 1 from the Construction Completion Report, which is included in
Appendix B. Areas previously investigated and excavated for PCBs are shown on Figure 2 from
the September 14, 2011 Soil Excavation and PCB Remediation Work Plan prepared by Golder,
which is included in Appendix B.
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In addition to investigation of PCBs, historical soil assessment activities conducted at the
Brownfields property have also identified the presence of VOCs, specifically in SWMU-13,
SWMU-15, and SWMU-16. According to the February 2004 Corrective Measures Study prepared
by Golder, VOCs identified as compounds of concern (COCs) in these areas have included
tetrachloroethylene (PCE), tetrachloroethane (PCA), trichloroethylene (TCE), 1,1,2-
trichloroethane, cis-1,2-dichloroethene, 1,1-dichloroethene (1,1-DCE), 1,2-dichloroethane (1,2-
DCA), carbon tetrachloride, chloroform, methylene chloride, vinyl chloride, bromoform, ethylene
dibromide, benzene, toluene, xylene, ethylbenzene, and 2-butanone.
In addition to PCB confirmation sampling activities described in the Construction Completion
Report, post -excavation samples were also collected for VOCs from all excavations except
SWMU-13. Remediation of VOCs in soil at SWMU-13 is currently being conducted by soil vapor
extraction. Results of post -excavation sampling from the remaining SWMUs and AOCs indicated
that VOCs in soil had been remediated to below the January 2014 DEQ IHSB Residential and
Industrial/Commercial PSRGs. Additionally, an April 22, 2016 letter from the DEQ Hazardous
Waste Section stated that VOCs in soil had been remediated to No Further Action (NFA) status in
all SWMUs and ADCs with the exception of SWMU-13 (Appendix C). As noted above,
redevelopment in the SWMU-13 area is not proposed at this time.
In addition to remediation of PCBs and VOCs in soil described above, the Brownfields property
has also undergone assessment and corrective action for two former 30,000-gallon fuel oil
underground storage tanks (USTs). The USTs were installed to an approximate depth of 15 ft
bgs and are located near SWMU-15. In 2003, the USTs were closed in -place by removing residual
petroleum sludge followed by placement of foam and concrete in the USTs. The UST fill port
structures, vent pipes, and metal pump pit were then removed and disposed of off -Site. In 2014,
the former UST fuel oil return line was removed during RCRA corrective action activities. Post -
UST closure soil sampling results did not indicate exceedances of DEQ UST Section Maximum Soil
Contaminant Concentrations (MSCCs). As such, a Notice of No Further Action was granted for
the petroleum release (Incident No. 26415) on March 5, 2015. The approximate location of the
closed -in -place USTs is shown on Figure 3.
2) Depth of known or suspected contaminants (feet):
As mentioned above, soil impacted with PCBs and VOCs above applicable regulatory screening
criteria were excavated to depths of up to approximately 13 ft bgs during RCRA corrective action
activities. Excavations completed for SWMU-15 and SWMU-16 were terminated at bedrock and
additional impacts may potentially exist at the base of those excavations and/or in bedrock
below the excavations. As such, zero valent iron (ZVI) was placed at the base of the SWMU-15
and SWMU-16 excavations at a thickness of approximately 1 foot to aid in the remediation of
VOCs in underlying weathered bedrock and groundwater. The ZVI was mixed with sand followed
by approximately two 2-foot lifts of 3 to 4-inch ballast stone.
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PCB impacted soils are present in deed restricted areas SWMU-12 and SWMU-13 at
concentrations >1 mg/kg and <_ 10 mg/kg. These areas are currently covered with soil covers
that are inspected on an annual basis as part of TSCA requirements under land use restrictions
recorded with the property deed.
According to the Construction Completion Report, known PCB and VOC impacted soils have been
remediated to below applicable regulatory screening criteria. In addition, results of pre -and
post -excavation sampling indicated PCBs in soil are below the July 2020 DEQ IHSB
Industrial/Commercial PSRGs from sampled areas within the Phase I Limits of Disturbance (Figure
3).
3) Area of soil disturbed by redevelopment (square feet):
Based on cut -fill analysis (Appendix A), an approximate area of 2,011,755 sq ft is expected to be
disturbed during redevelopment activities.
4) Depths of soil to be excavated (feet):
Proposed grading activities are expected to include excavations of up to approximately 20 ft bgs
in the north -central and east -central portions of the Brownfields property for installation of
stormwater management infrastructure. In general, remaining excavations are proposed at
depths of up to approximately 12 ft bgs.
5) Estimated volume of soil (cubic yards) to be excavated (attach grading plan):
Up to approximately 270,000 cubic yards of soil are planned to be excavated and re -used on -Site
as beneficial fill during grading activities. Areas of cut are shown on Figure 3.
6) Estimated volume of excavated soil (cubic yards) anticipated to be impacted by contaminants:
Excavation of impacted soil is not anticipated.
7) Estimated volume of contaminated soil expected to be disposed of offsite, if applicable:
Export of impacted soil is not anticipated.
Part 1.A. MANAGING ONSITE SOIL
If soil is anticipated to be excavated fromthe 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 preliminarydata available).
1) HAZARDOUS WASTE DETERMINATION:
a) 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).
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According to the 2015 Construction Completion Report, historical releases were
not associated with a release of listed hazardous waste.
❑ If yes, do the soils exceed the "Contained -Out" levels in Attachment 1 of the
North Carolina Contained -In Policy? ................................................. ❑ Yes ❑ No
b) 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 POLICYTHE SOIL MAY NOT BE RE -USED ON SITE AND MUST BE
DISPOSED OF IN ACCORDANCE WITH DEQ HAZARDOUS WASTE SECTION RULES AND
REGULATIONS.
c) Does the soil contain a CHARACTERISTIC WASTE? .................................... ❑ Yes ® No
❑ If yes, mark reason(s) why below (and include pertinent analytical results).
❑ Ignitability Click or tap here to enter text.
❑ Corrosivity Click or tap here to enter text.
❑ Reactivity Click or tap here to enter text.
❑ Toxicity ick or tap here to enter text.
❑ TCLP results Click or tap here to enter text.
❑ 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)
Click or tap here to enter text.
© If no, explain rationale:
According to the Construction Completion Report, toxicity characteristic leaching
procedure (TCLP) waste characterization samples were collected in March 2013
from borings advanced in SWMU-15 and SWMU-16. Based on the sampling
results, soil excavated at the Brownfields property during RCRA corrective action
activities did not exceed toxicity characteristic levels.
d) NOTE: IF SOIL MEETS THE DEFINITION OF A CHARACTERISTIC HAZARDOUS WASTE, THE
SOIL MAYNOT BE RE -USED ON SITE AND MUST BE DISPOSED OF IN ACCORDANCE
WITH DEQ HAZARDOUS WASTE SECTION RULES AND REGULATIONS.
2) 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
® Preliminary Health -Based Industrial/Commercial SRGs
© Division of Waste Management Risk Calculator (For Brownfields Properties Only)
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❑ Site -specific risk -based cleanup level. Please provide details of methods used for
determination/explanation.
Click or tap here to enter LL_ .
Additional comments:
jr tap he
3) If known impacted soil is proposed to be reused within the Brownfields Property Boundary,
please check the measures that will be utilized to ensure safe placement and documentation of
same. Please attach a proposed location diagram/site map.
© 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
❑ Geotextile to mark depth of fill material.
Provide description of material:
Click or tap here to enter text.
© Manage soil under impervious cap ® or clean fill FXKI
® Describe cap or fill:
Should impacted soil be encountered during redevelopment, the potentially impacted soil
will be placed beneath impervious surfaces (asphalt pavement, sidewalks, access roads,
buildings, etc.) or a minimum of 2 ft of clean fill.
© Confer with NC BF Project Manager if Brownfield Plat must be revised (or re -recorded if
actions are Post -Recordation).
® GPS the location and provide site map with final location.
❑ Other. Please provide a description of the measure:
Click or tap here to enter text.
4) Please describe the following action(s) to be taken during and following excavation and
management of site soils:
Management of fugitive dust from site
® Yes, describe the method will include:
Significant areas of contaminated soil are not expected to be encountered or disturbed
during Site redevelopment activities based upon soil sampling data. The grading contractor
will consider conditions such as wind speed, wind direction, and moisture content of soil
during soil grading and stockpiling activities 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). As such, a water truck
and/or appropriate water misting equipment will be available if needed at the Site during
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work activities that may produce dust. If operations generate sustained visible dust, dust
monitoring equipment will be utilized. If dust levels exceed 3.0 milligrams per cubic meter
(mg/m3), the American Conference of Governmental Industrial Hygienists level for
Particulates (insoluble or poorly soluble) Not Otherwise Specified (PNOS), grading activities
will cease and additional safety measures and/or water control methods may be
implemented. Potentially impacted soil will be managed as described below.
❑ No, explain rationale:
Click or tap here to enter text.
Field Screening of site soil
® Yes, describe the field screening method, frequency of field screening, person conducting
field screening:
During soil disturbance, workers or contractors will observe soils for evidence of a distinct
unnatural color, strong odor, sheen, or fill disposed materials of concerns (i.e., dried
sludge, chemicals, tanks, drums, subsurface piping, etc.). In addition, workers or
contractors will also observe excavations in the areas of SWMU-15 and SWMU-16 for
evidence of ZVI and/or ballast stone. Should the above be noted during site work, the
contractor will contact the project environmental professional to observe the suspect
condition. If the project environmental professional confirms that the material may be
impacted (using field observations, screening with a photo -ionization detector [PID], and
historical assessment information [if applicable]), then the soils will be managed in
accordance with this EMP and the Brownfields Program Project Manager will be contacted
within two business days to advise that person of the condition. If the project
environmental professional confirms the presence of ZVI and/or ballast stone in the
SWMU-15 or SWMU-16 areas, the Brownfields Program Project Manager, the RCRA Permit
holder (GSK), and DEQ Hazardous Waste will be contacted to discuss the condition. During
soil disturbance, field screening using visual observations will be performed periodically by
the project environmental professional in areas where there is an increased potential of
encountering impacted media. These areas include SWMU-15 and SWMU-16, which are
currently undergoing RCRA corrective action activities for the remediation of groundwater.
SWMU-15 and SWMU-16 are generally in the north -central portion of the Brownfields
property and are shown on Figure 3.
❑ No, explain rationale:
Click or tap here to enter text.
Soil Sample Collection
❑ Yes, describe the sampling method (e.g., in -situ grab, composite, stockpile, etc.):
Click or tap here to enter text.
® No, explain rationale:
Collection of additional soil samples is not anticipated based on results of previous Site
assessment activities. If significant soil impact is encountered during grading and/or
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installation or removal of utilities, excavation will proceed only as far as needed to allow
grading and/or construction of the utility to continue and/or only as far as needed to
allow alternate corrective measures described below. Suspect significantly impacted soil
excavated during grading and/or utility line installation or removal may be stockpiled and
covered in a secure area to allow construction to progress. Suspect impacted soil will be
underlain by and covered with minimum 10-mil plastic sheeting. At least one
representative sample of the soil will be collected for analysis of VOCs, SVOCs, RCRA
metals plus hexavalent chromium, and PCBs. If the results of analysis of the sample
indicate that the soil could potentially exceed toxicity characteristic hazardous waste
criteria, then the soil will also be analyzed by TCLP for those compounds that could
exceed the toxicity characteristic hazardous waste criteria. Impacted soil will be handled
in the manner described below based upon the laboratory analyses:
If no organic compounds are detected in a sample (other than which are
attributable to sampling or laboratory artifacts) and metals are below Residential PSRGs
or are consistent with published background ranges for North Carolina soils, then the soil
will be deemed suitable for use as on -Site fill or as off -Site fill. The proposed location(s)
for off -Site placement of soil (other than a permitted facility) along with the receiving
facility's written approval for acceptance of the soil will be provided to DEQ for approval
prior to taking the soil off -site.
ii. If detectable levels of compounds are found which do not exceed the DEQ IHSB
Industrial/Commercial PSRGs (other than which are attributable to sampling or laboratory
artifacts or which are consistent with published background ranges for metals in North
Carolina soils) and the TCLP concentrations are below hazardous waste criteria, then the
soil may be used on -Site as fill without conditions.
iii. If detectable levels of compounds are found which exceed the DEQ IHSB
Industrial/Commercial PSRGs (other than which are attributable to sampling or laboratory
artifacts or which are consistent with published background ranges for metals in North
Carolina soils) and the TCLP concentrations are below hazardous waste criteria, then the
soil, with DEQ's written approval, may be used on -Site as fill below an impervious surface,
or at least 2 ft of compacted clean soil. If the impacted soil with concentrations above
Industrial/Commercial PSRGs is moved to an on -Site location, its location and depth will
be documented, covered with a geotextile fabric so that its location can be identified if
encountered in the future, and its location will be provided to DEQ.
iv. Impacted soil may be transported to a permitted facility such as a landfill provided
that the soil is accepted at the disposal facility. If soil is transported to a permitted
facility, the permitted facility's written approval to dispose of soil from the Site will be
included with the final EMP report. In the unlikely event that the sample data indicates
concentrations above TCLP hazardous waste criteria, then the soil must be transported
off -site to a permitted disposal facility that can accept or treat hazardous waste.
*Please note that should the PD elect to transport export soil to a permitted facility or to
a DEQ Brownfields pre -approved receiving facility, soil will be direct loaded onto trucks
for transport off -Site.
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If soil samples are collected for analysis, please check the applicable 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, mercury, lead, selenium
and silver): Specify Analytical Method Number(s):
EPA Methods 6020/7471
❑ Pesticides: Specify Analytical Method Number(s):
f lirl, nr tnn here t0 pntor fov'
© PCBs: Specify Analytical Method Number(s):
EPA SW-846 Method 8082A. A sample will also be collected for possible analysis
of PCB congeners by EPA Method 1668A based on the results of the 8082A
analysis.
® Other Constituents & Respective Analytical Method(s) (i.e. Hexavalent Chromium,
Herbicides, etc.): Specify Analytical Method Number(s):
Soil samples will be collected for hexavalent chromium and put on hold for
potential analysis by EPA Method 7199. The laboratory will be directed to hold all
hexavalent chromium analyses pending the results of the total chromium analyses
If total chromium is detected in any of the soil samples above the current
hexavalent chromium Industrial/Commercial PSRG, the sample exhibiting the
highest total chromium concentration will be analyzed for hexavalent chromium.
If hexavalent chromium is detected in that sample above the current hexavalent
chromium Industrial/Commercial PSRG, the remaining soil samples may be
analyzed for hexavalent chromium subject to approval by DEQ Brownfields.
® Check to confirm that stockpiling of known or suspected impacted soils will be conducted
in accordance with Figure 1 of this EMP. Stockpile methodology should provide erosion
control, prohibiting contact between surface water/precipitation and contaminated soil,
and preventing contaminated runoff. Explain any variances or provide additional details as
needed:
Click or tap here to enter t,
® Final grade sampling of exposed native soil (i.e., soil that will not be under buildings or
permanent hardscape). Select chemical analyses for final grade samples with check boxes
below (Check all thatapply):
® 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, mercury, lead,
selenium and silver): Specify Analytical Method Number(s):
EPA Methods 6020/7471
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❑ Pesticides: Specify Analytical Method Number(s):
® PCBs: Specify Analytical Method Number(s):
EPA SW-846 Method 8082A. A sample will also be collected for possible
analysis of PCB congeners by EPA Method 1668A based on the results of the
8082A analysis.
® Other Constituents & Respective Analytical Method(s) (i.e. Hexavalent
Chromium, Herbicides, etc.):
Soil samples will be collected for hexavalent chromium and put on hold for
potential analysis by EPA Method 7199. The laboratory will be directed to hold
all hexavalent chromium analyses pending the results of the total chromium
analyses. If total chromium is detected in any of the soil samples above the
current hexavalent chromium Industrial/Commercial PSRG, the sample
exhibiting the highest total chromium concentration will be analyzed for
hexavalent chromium. If hexavalent chromium is detected in that sample
above the current hexavalent chromium Industrial/Commercial PSRG, the
remaining soil samples may be analyzed for hexavalent chromium subject to
approval by DEQ Brownfields.
Please provide a scope of work for final grade sampling, including a diagram of soil
sampling locations, number of samples to be collected, and brief sampling methodology.
Samples should be collected from 0-2 ft below ground surface, with the exception of VOCs
which should be taken from 1-2 ft below ground surface. Alternatively, a work plan for
final grade sampling may be submitted under separate cover.
Following completion of soil disturbance for any discrete future Site development (i.e.,
after grading and utility construction), an environmental professional will be contracted
to assess the development area for areas that are not covered with a minimum of 2 ft of
clean fill soil or topsoil, building foundations, sidewalks, asphalt or concrete parking areas,
driveways or other impervious surfaces. If such areas exist, a Work Plan will be prepared
for final grade sampling for DEQ review and approval. If no such areas exist,
documentation will be provided to DEQ.
❑ If final grade sampling was NOT selected please explain rationale:
Click or tap here to enter text
Part 1.6. IMPORTED FILL SOIL
NO SOIL MAY BE BROUGHT ONTO THE BROWNFIELDS PROPERTY WITHOUT PRIOR APPROVAL
FROM THE BROWNFIELDS PROGRAM. According to the Brownfields IR 15, "Documenting
imported soil (by sampling, analysis, and reporting in accordance with review and written
approval in advance by the Brownfields Program), will safeguard the liability protections provided
by the brownfields agreement and is in the best interest of the prospective developer/property
owner."
Requirements for importing fill:
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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?
The need for off -Site import of fill soil is not anticipated at this time; however, should off -site
import of fill soil be warranted, see No. 7 below for details outlining the proposed plan to
demonstrate import soil meets acceptable standards to the Site.
3) If yes, what is the anticipated depth that fill soil will be placed at the property? (If a range
of depths, please list the range.)
UICK or tap nere to enter text.
4) Provide the source of fill, including: location, site history, nearby environmental concerns,
etc. Attach aerial photos, maps, historic Sanborn maps and a borrow source site history:
r Iirll nr ton horn to ontor tovt
5) PRIOR TO ITS PLACEMENT AT THE BROWNFIELDS PROPERTY, provide a plan to analyze fill
soil to demonstrate that it meets acceptable standards applicable to the site and can be
approved for use atthe Brownfields property.
The need for off -Site import of topsoil is not anticipated at this time. Should off -Site import of
topsoil be warranted, DEQ Brownfields will be notified of the volume of landscaping material
needed and the proposed source of the material prior to placement in proposed landscaping
areas. See No. 7 below for details outlining the proposed plan to demonstrate import soil meets
acceptable standards applicable to the Brownfields property.
6) Please check the applicable chemical analytes for fill soil samples. (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, mercury, lead,
selenium and silver): Specify Analytical Method Number(s):
6020/7471
© Pesticides: Specify Analytical Method Number(s):
Organochlorine pesticides (OCPs) by EPA Method 8081
® PCBs: Specify Analytical Method Number(s):
EPA SW-846 Method 8082A. A sample will also be collected for possible
analysis of PCB congeners by EPA Method 1668A based on the results of the
8082A analysis.
® Other Constituents & Respective Analytical Method(s) (i.e. Hexavalent
Chromium, Herbicides, etc.):
Hexavalent Chromium by EPA Method 7199
7) The scope of work for import fill sampling may be provided below or in a Work Plan
submitted separately for DEQ review and approval. Attach specific location maps for in -situ
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borrow sites. If using a quarry, provide information on the type of material to be brought
onto the Brownfields Property.
The PD will follow the procedures outlined below to demonstrate import soil meets acceptable
criteria for Site use.
If the PD plans to import virgin fill material from a DEQ Brownfields pre -approved borrow source
(such as the Wake Stone Corporation quarry located in Knightdale, North Carolina), no samples of
the import material will be collected because adequate analytical data is available in the DEQ
Brownfields database to demonstrate material from these facilities is suitable for use as structural
fill at a Brownfields property.
If fill soil (other than topsoil) is obtained from an off -Site property that is not a known permitted
quarry or is recycled material from a DEQ Brownfields pre -approved borrow source, the borrow
source will be sampled in general accordance with the most recent versions of the U.S.
Environmental Protection Agency (EPA) Region IV Science and Ecosystem Support Division (SESD)
Field Branches Quality System and Technical Procedures guidance. If the proposed borrow source
is a permitted quarry, one soil sample will be collected for laboratory analysis. If the proposed
borrow source has not been previously developed (i.e., virgin land), soil samples will be collected
for laboratory analysis at a general rate of approximately one per 1,000 cubic yards. If the borrow
source property has been previously developed, soil samples will be collected for laboratory
analysis at a general rate of approximately one per S00 cubic yards.
Specifically, composite soil samples for any of the above scenarios will be collected using a hand
auger. Each composite sample will be comprised of soil from four grab sample locations (i.e.,
aliquots). The composite soil samples will be collected directly into dedicated laboratory -supplied
sample containers and submitted to a North Carolina certified laboratory under standard chain of
custody protocols for laboratory analysis SVOCs by EPA Method 8270 and RCRA metals plus
hexavalent chromium by EPA Methods 6020/7471/7199, OCPs by EPA Method 8081, and PCBs by
EPA Method 8082A. In addition to the composite soil samples described above, one
representative grab soil sample will also be collected. The grab soil samples will be collected from
undisturbed portions of soil directly into laboratory -supplied glassware and for laboratory analysis
of VOCs by EPA Method 8260.
The DEQ Brownfields project manager will be contacted should an alternate sampling frequency
be sought for either type of borrow source property.
Fill soil will be considered suitable for use at the Site if it does not contain compound
concentrations above DEQ Industrial/Commercial PSRGs, DWM Risk Calculator risk thresholds, or
typical metals concentrations which are consistent with published background ranges for metals
in regional soils. DEQ approval of the analytical results will be obtained prior to transporting
import soil to the Site.
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Part I.C. EXPORTED SOIL
NO SOIL MAY LEAVE THE BROWNFIELDS PROPERTY WITHOUT APPROVAL FROM THE
BROWNFIELDS PROGRAM. FAILURE TO OBTAIN APPROVAL MAY VIOLATE A BROWNFIELDS
AGREEMENT CAUSING A REOPENER OR JEOPARDIZING ELIGIBILITY IN THE PROGRAM,
ENDANGERING LIABILITY PROTECTIONS AND MAKING SAID ACTION POSSIBLY SUBJECT TO
ENFORCEMENT. JUSTIFICATIONS PROVIDED BELOW MUST BE APPROVED BY THE PROGRAM IN
WRITING PRIOR TO COMPLETING TRANSPORT ACTIVITIES. Please refer to Brownfields IR 15 for
additional details.
1) If export from a Brownfields Property is anticipated, please provide details regarding the
proposed export actions. Volume of exported soil, depths, location from which soil will
be excavated on site, related sampling results, etc. Provide a site map with locations of
export and sampling results included.
Export soil is not anticipated at this time. However, should soil need to be exported from the
Brownfields property during redevelopment, soil will be sampled in general accordance with the
most recent versions of the EPA Region IV SESD Field Branches Quality System and Technical
Procedures guidance.
Samples will be collected from export soil at a rate of 1 sample per every approximately 1,000
cubic yards of export for laboratory analysis of VOCs by EPA Method 8260, SVOCs by EPA
Method 8270, RCRA metals by EPA Methods 6020/7471, and PCBs by EPA Method 8082A.
SVOCs, metals, and PCBs will be collected as composite samples using a decontaminated
stainless -steel hand auger. Soil samples will also be collected for hexavalent chromium and put
on hold for potential analysis by EPA Method 7199. The laboratory will be directed to hold all
hexavalent chromium analyses pending the results of the total chromium analyses. If total
chromium is detected in any of the soil samples above the current hexavalent chromium
Industrial/Commercial PSRG, the sample exhibiting the highest total chromium concentration
will be analyzed for hexavalent chromium. If hexavalent chromium is detected in that sample
above the current hexavalent chromium Industrial/Commercial PSRG, the remaining soil samples
may be analyzed for hexavalent chromium subject to approval by DEQ Brownfields.
The composite samples will consist of three sample aliquots that are combined to form one
sample for laboratory analysis. Each aliquot will be field screened for the presence of VOCs using
a calibrated photoionization detector (PID). VOC samples will be collected as grab samples using
a decontaminated stainless -steel hand auger from the general area of the aliquot which exhibits
the highest indication of impact during field screening. The soil samples will be placed in
dedicated laboratory -supplied sample containers, covered with ice, and shipped to a North
Carolina -certified laboratory under standard chain of custody protocols.
DEQ approval of the analytical results will be obtained prior to transporting export soil from the
Site. Based on analytical results of soil samples collected from the export soil, the soil will be
transported off -Site to a suitable location. The PD will notify DEQ Brownfields of the location
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receiving the export soil. If not a permitted facility, DEQ Brownfields approval and written
approval from the receiving facility will be obtained prior to transporting the soil off -Site.
2) To what type of facility will the export Brownfields soil be sent?
® Subtitle D/Municipal Solid Waste Landfill (analytical program to be determined by
landfill)
® Permitted but Unlined Landfill (i.e. LCID, C&D, etc.) Analytical program to be
determined by the accepting Landfill;
® Landfarm or other treatment facility
® Use as fill at another suitable Brownfields Property — determination that a
site is suitable will require, at a minimum, that similar concentrations of the same or
similar contaminants already exist at both sites, use of impacted soil will not increase
the potential for risk to human health and the environment at the receiving Brownfields
property, and thata record of the acceptance of such soil from the property owner of
the receiving site is provided to Brownfields. Please provide additional details below.
® Use as Beneficial Fill off -site at a non-Brownfields Property - Please provide
documentation of approval from the property owner for receipt of fill material. This will
also require approval by the DEQ Solid Waste Section. Additional information is
provided in IR 15. Please provide additional details below.
3) Additional Details: (if transfer of soil to another property is requested above, please provide
details related to the proposed plans).
The environmental engineer will contact DEQ Brownfields to obtain DEQ Brownfields, DEQ
Hazardous Waste, and DEQ Solid Waste approval prior to exporting soil to a non-Brownfields,
non -permitted facility property.
Part 1.D. 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?
❑ Ifyes, provide specifications on barrier materials:
Click or tap here to enter text.
❑ If no, include rationale here:
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Other comments regarding managing impacted soil in utility trenches:
According to the 2015 Construction Completion Report, known PCB and VOC impacted soils have been
remediated to below applicable regulatory screening criteria. Although not anticipated, in the event
contaminated soil and/or vapors are encountered in 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. If
results indicate further action may be warranted to prevent soil vapor transport, and/or degradation
of conduit materials, the contractor will contact the project environmental engineer to evaluate the
suspect condition.
The contractor and workers will observe soil for potential impacts during utility installation activities.
Evidence of potential significant impacted soil includes a distinct unnatural color, strong odor, or filled
or previously disposed materials of concerns (i.e. chemicals, tanks, drums, utilities, etc.). Should the
above be noted during utility 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, then the procedures outlined in Managing On -Site Soil above will be implemented. In
addition, the environmental professional or PD will contact the DEQ Brownfields project manager
within two business days to advise that person of the condition.
PART 2. GROUNDWATER — Please fill out the information below.
1) What is the depth to groundwater at the Brownfields Property?
The depth to groundwater at the Brownfields property is highly variable. Based on information
provided in Golder's August 30, 2019 Fifth Annual Assessment Report (Assessment Report),
depth to groundwater in areas of proposed excavation (i.e., cut) ranges from approximately 10
ft bgs to 33 ft bgs in the central to north -central portions of the Brownfields property (near
SWMU-15 and SWMU-16) to approximately 32 ft bgs in the northeastern portion of the
Brownfields property (near SWMU-13).
2) Is groundwater known to be contaminated by ®onsite ❑offsite ❑both or ❑unknown
sources? Describe source(s):
Historical groundwater assessment activities conducted at the Brownfields property have
identified the presence of chlorinated VOCs (cVOCs) at concentrations above the DEQ 2L
Groundwater Quality Standards (2L Standards). Based on information provided in the
Assessment Report, cVOCs detected in groundwater above 2L Standards include, but are not
limited to, TCE and associated degradation compounds cis-1,2-dichloroethene and vinyl chloride.
Additionally, non -chlorinated VOCs such as benzene have been detected at concentrations above
the 2L Standard. As part of RCRA correction action activities, ongoing groundwater remediation
is currently being performed in areas associated with SWMU-13, SWMU-15, and SWMU-16 and
AOC W-1 and AOC GW-6. Groundwater remediation areas and groundwater analytical results
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(above 2L Standards) from the April 2019 sampling event are shown on Figure 2 from the
Assessment Report, which is included in Appendix B.
3) What is the direction of groundwater flow at the Brownfields Property?
Groundwater flow direction at the Brownfields property is highly variable but is generally
expected to mimic topography and flow radially away from a southwest to northeast trending
ridge that is located in the central portion of the Site.
4) Will groundwater likely be encountered during planned redevelopment activities?
❑Yes ®No
If yes, describe these activities:
Click or tap here to enter text.
Regardless of the answer; in the event that contaminated groundwater is encountered
during redevelopment activities (evenif no is checked above), list activities for contingent
management of groundwater (e.g., dewateringof groundwater from excavations or
foundations, containerizing, offsite disposal, discharge to sanitary sewer, NPDES permit, or
sampling procedures).
Although not anticipated at this time, appropriate worker safety measures will be undertaken if
groundwater gathers in an open excavation within an area determined to be impacted during
construction activities. The accumulated water will be allowed to evaporate/infiltrate to the
extent time for dissipation does not disrupt the construction schedule. Should the time needed
for natural dissipation of accumulated water be deemed inadequate, the water will be 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 applicable municipal and
State regulations for erosion control and construction stormwater control. If warranted,
proposed laboratory analyses (i.e., PCBs, etc.) will be submitted to DEQ Brownfields and DEQ
Hazardous Waste for approval prior to sample collection.
5) Are monitoring wells currently present on the Brownfields Property?.................❑XYes ❑No
If yes, are any monitoring wells routinely monitored through DEQ or other
agencies?.................................................................................................................. ❑X Yes ❑ No
6) Please check methods to be utilized in the management of known and previously
unidentified wells.
® Abandonment of site monitoring wells in accordance with all applicable regulations. It
is the Brownfields Program's intent to allow proper abandonment of well(s) as
specified in the Brownfields Agreement, except if required for active monitoring
through another section of DEQ or the EPA.
® Location of existing monitoring wells marked
® Existing monitoring wells protected from disturbance
® Newly identified monitoring wells will be marked and protected from further
disturbance until notification to DEQ Brownfields can be made and approval for
abandonment is given.
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7) Please provide additional details as needed:
Potential well abandonment activities are currently being evaluated by the PD and GSK, the RCRA
Permit holder. Updates on these discussions will be provided to DEQ Brownfields and DEQ Hazardous
Waste on an as -needed basis. If warranted, well abandonment activities will be conducted in
accordance with local and state regulations. Existing monitoring well locations are shown on Figure 3.
Previously abandoned monitoring well locations are shown on Figure 4.
Please note, disturbance of existing site monitoring wells without approval by DEQ is not
permissible. If monitoring wells are damaged and/or destroyed, DEQ may require that the PD
be responsible for replacement of the well.
PART 3. SURFACE WATER -Please fill out the information below.
1) Is surface water present at the property? ® Yes ❑ No
2) Attach a map showing the location of surface water at the Brownfields Property.
3) Is surface water at the property known to be contaminated? ❑ Yes ® No
4) Will workers or the public be in contact with surface water during planned redevelopment
activities? ❑ Yes ® No
5) 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 surface water run-off gathers in an open excavation within an area determined to be impacted
during construction activities, appropriate worker safety measures will be undertaken. The
accumulated water will be allowed to evaporate/infiltrate to the extent time for dissipation does
not disrupt the construction schedule. Should the time needed for natural dissipation of
accumulated water be deemed inadequate, the water will be 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 applicable municipal and State regulations for erosion
control and construction stormwater control. If warranted, proposed laboratory analyses (i.e.,
PCBs, etc.) will be submitted to DEQ Brownfields and DEQ Hazardous Waste for approval prior to
sample collection.
PART 4. SEDIMENT — Please fill out the information below.
1) Are sediment sources present on the property? ® Yes ❑ No
2) If yes, is sediment at the property known to be contaminated: ❑ Yes ® No
3) Will workers or the public be in contact with sediment during planned redevelopment
activities? ❑ Yes ® No
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4) Attach a map showing location of known contaminated sediment at the property.
5) In the event that contaminated sediment is encountered during redevelopment activities, list
activities for management of such events (stream bed disturbance):
Not applicable.
PART 5. SOIL VAPOR — Please fill out the information below.
1) Do concentrations of volatile organic compounds at the Brownfields property exceed the
following vapor intrusion screening levels (current version) 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
2) Attach a map showing the locations of soil vapor contaminants that exceed site
screening levels.
3) If applicable, at what depth(s) is soil vapor known to be contaminated?
Not applicable
4) Will workers encounter contaminated soil vapor during planned redevelopment activities?
❑ Yes ❑ No ® Unknown
5) 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 future redevelopment
activities, the 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.
PART 6. SUB -SLAB SOIL VAPOR — Please fill out the information below if existing buildings or
foundations will be retained in the redevelopment.
1) Are sub -slab soil vapor data available for the Brownfields Property? ❑ Yes © No ❑ Unknown
2) If data indicate that sub -slab soil vapor concentrations exceed screening levels, attach a map
showing the location of these exceedances.
3) At what depth(s) is sub -slab soil vapor known to be contaminated? El 0-6 inches ❑Other, please
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describe:
Click or tap here to enter text.
4) Will workers encounter contaminated sub -slab soil vapor during planned redevelopment
activities? ❑ Yes ❑ No © Unknown
5) In the event that contaminated soil vapor is encountered during redevelopment activities, list
activities for management of such contact
In the unlikely event impacted soil vapors are encountered during future redevelopment
activities, worker breathing zone will be monitored using a calibrated photoionization detector. If
results indicate further action is warranted, appropriate engineering controls (such as use of
industrial fans) will be implemented.
PART 7. INDOOR AIR — Please fill out the information below.
1) Are indoor air data available for the Brownfields Property? ❑ Yes ® No ❑ Unknown
2) Attach a map showing the location(s) where indoor air contaminants exceed site screening levels.
3) 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
4) In the event that contaminated indoor air is encountered during redevelopment activities, list
activities for management of such contact:
In the unlikely event there is evidence of potential indoor air issues (i.e. unusual odors) during future
redevelopment activities, the area will be evacuated and appropriate safety screening of the indoor
air will be performed. If warranted, safety screening procedures will include periodically screening
indoor air for volatile organic vapors with a calibrated photoionization detector. If results indicate
further action is warranted, appropriate engineering controls (such as use of industrial fans) will be
implemented.
VAPOR INTRUSION MITIGATION SYSTEM — Please fill out the information below.
Is a vapor intrusion mitigation system (VIMS) proposed for this BrownfieldsProperty?
❑ Yes ❑ No © Unknown
If yes, ❑ VIMS Plan Attached or ❑ VIMS Plan to be submitted separately
If submitted separately provide date:
ck or tap here to enter tr
VIMS Plan shall be signed and sealed by a NC Professional Engineer
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If no, please provide a brief rationale as to why no vapor mitigation plan is warranted:
The potential for structural vapor intrusion into proposed buildings will be evaluated during
future assessment activities conducted under purview of DEQ Brownfields.
CONTINGENCY PLAN — encountering unknown tanks, drums, or other waste materials
In this section please provide actions that will be taken to identify or manage unknown
potential new sources of contamination. During redevelopment activities, it is not uncommon
that unknown tanks, drums, fuel lines, landfills, orother waste materials are encountered.
Notification to DEQ 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. These Notification Requirements were outlined on Page 1 of this
EMP.
Should potentially impacted materials be identified that are inconsistent with known site
impacts, the DEQ Brownfields Project Manager will be notified and a sampling plan will be
prepared based on the EMP requirements and site -specific factors. Samples will generally be
collected to document the location of the potential impacts.
Check the following chemical analysis that are to be conducted on newly identified releases:
® 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, mercury, lead, selenium and
silver)
EPA Methods 6020/7471
❑ Pesticides: Specify Analytical Method Number(s):
Click or tap here to enter text
® PCBs: Specify Analytical Method Number(s):
EPA SW-846 Method 8082A. A sample will also be collected for possible analysis of
PCB congeners by EPA Method 1668A based on the results of the 8082A analysis.
® Other Constituents & Analytical Method(s) (i.e. Hexavalent Chromium, Herbicides, etc.)
Please note, if field observations indicate the need for additional analyses, they should
be conducted, even if not listed here.
Soil samples will be collected for hexavalent chromium and put on hold for potential
analysis by EPA Method 7199. The laboratory will be directed to hold all hexavalent
chromium analyses pending the results of the total chromium analyses. If total
chromium is detected in any of the soil samples above the current hexavalent
chromium Industrial/Commercial PSRG, the sample exhibiting the highest total
chromium concentration will be analyzed for hexavalent chromium. If hexavalent
chromium is detected in that sample above the current hexavalent chromium
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Industrial/Commercial PSRG, the remaining soil samples may be analyzed for
hexavalent chromium subject to approval by DEQ Brownfields.
Please provide details on the proposed methods of managing the following commonly
encountered issues during redevelopment of Brownfields Properties.
During construction activities, contractors may encounter unknown sub -surface environmental
conditions (i.e. tanks, drums, utilities, or waste materials) that if encountered, will require proper
management. Prior to beginning Site work, the environmental professional will attend a pre -
construction kick-off meeting with the PD and the redevelopment contractors to discuss the DEQ
approved EMP and various scenarios when it would be appropriate and necessary to notify the
environmental professional of the discovery of unknown subsurface features or potentially
impacted media at the Site.
In the event that such conditions are encountered during site development activities, the
environmental actions noted below will be used to direct environmental actions to be taken during
these activities and sampling data for potentially impacted soil and the disposition of impacted soil
will be provided to DEQ when the data becomes available.
Underground Storage Tanks:
As noted in the Contaminated Media section, two former 301000-gallon fuel oil USTs were closed in -
place in 2003. The closed USTs are located near SWMU-15 and are shown on Figure 2.
In the event a previously unidentified UST or impacts associated with a UST release are discovered
at the Site during redevelopment activities, the UST and/or UST related impacts will be addressed
through the Brownfields Program.
If a previously unidentified UST is encountered, the UST will be removed and transported off -Site
for disposal at a suitable facility. If the UST contains residual fluids, the fluids will be sampled for
VOCs, SVOCs, RCRA metals plus hexavalent chromium, and PCBs, and transported off -Site for
disposal at a suitable facility based on the laboratory analytical results prior to removing the UST
from the ground. If a UST is encountered that cannot be removed or does not require removal for
geotechnical or construction purposes, with DEQ prior approval it will be abandoned in -place and
construction will proceed. Impacted soil in the vicinity of the UST will be managed in accordance
with the Managing On -Site Soil section outlined above in the EMP. If a UST will be left in -place, DEQ
Brownfields will be notified.
Sub -Grade Feature/Pit:
If a sub -grade feature or pit is encountered and does not require removal for geotechnical or
construction purposes, it will be filled with soil or suitable fill and construction will proceed. Where
appropriate, the bottom may be penetrated before back filling to prevent fluid accumulation. If the
pit has waste in it, the waste may be set aside in a secure area and will be sampled for waste
disposal purposes for PCBs, TCLP VOCs, TCLP SVOCs, and TCLP metals and disposed off -Site at a
permitted facility or the waste will be managed in accordance with the Managing On -Site Soil
26
EMP Version 2, June 2018

section outlined above in the EMP, whichever is most applicable based on the type of waste
present. If the pit must be removed and the observed waste characteristics indicate the concrete
may potentially be contaminated to a significant degree, the concrete will be sampled and analyzed
by methods specified by the disposal facility.
Buried Waste Material:
If excavation into buried wastes or significantly impacted soils occurs, the contractor is instructed to
stop work in that location and notify the environmental consultant. The environmental
professional will review the materials and collect samples if warranted. In this event, confirmation
sampling will be conducted at representative locations in the base and the sidewalls of the
excavation after the waste or significantly impacted soil is removed. The confirmation samples will
be analyzed for VOCs, SVOCs, RCRA metals plus hexavalent chromium, and PCBs. Areas of
suspected contaminated soil that remain at the Site after excavation is complete above the DEQ
IHSB Industrial/Commercial PSRGs will be managed pursuant to this plan.
Re -Use of Impacted Soils On -Site:
Please refer to description outlined in the Managing On -Site Soil section of the EMP above.
If unknown, impacted soil is identified on -site, management on -site can be considered after the
project team provides the necessary information, outlined in Part I.A. Item 11, for Brownfields
Project Manager approval prior to final placement on -site.
If other potential contingency plans are pertinent, please provide other details or scenarios as
needed below:
Click or tap here to enter text.
POST -REDEVELOPMENT REPORTING
® Check this box to acknowledge that a Redevelopment Summary Report will be required for the
project. If the project duration is longer than one year, an annual update is required and will be
due by January 31 of each year, or 30 days after each one-year anniversary of the effective date of
this EMP (as agreed upon with the Project Manager). These reports will be required for as long as
physical redevelopment of the Brownfields Property continues, except that the final
Redevelopment Summary Report will be submitted within 90 days after completion of
redevelopment. Based on the estimated construction schedule, the first Redevelopment Summary
Report is anticipated to be submitted on To Be Determined
The Redevelopment Summary Report shall include environment -related activities since the last
report, with a summary and drawings, that describes:
1. actions taken on the Brownfields Property;
2. soil grading and cut and fill actions;
27
EMP Version 2, June 2018

3. methodology(ies) employed for field screening, sampling and laboratory analysis of
environmental media;
4. stockpiling, containerizing, decontaminating, treating, handling, laboratory analysis and
ultimate disposition of any soil, groundwater or other materials suspected or confirmed
to be contaminated with regulated substances; and
5. removal of any contaminated soil, water or other contaminated materials (for example,
concrete, demolition debris) from the Brownfields Property (copies of all legally required
manifests shall be included).
X❑ Check box to acknowledge consent to provide a NC licensed P.G. or P.E. sealed, Redevelopment
Summary Report in compliance with the site's Brownfields Agreement.
28
EMP Version 2, June 2018

APPROVAL SIGNATURES
Brownfields Project Number: 220S9-18-032
Brownfields Project Name: GlaxoSmithl(line, LLC
::�— 4t2��" 9/2/2020
Prospective Developer: TKC — 3029 Holdings, LLC Date: September 2, 2020
Printed Name/Title/Company: Mr. James. F. Harrell/Managing
Member/The Keith Corporation
9/2/2020
ant: Hart & Hickman, PC Date Click or tap to enter a date.
Printed Name/Title/Company: Mr. Justin Ballard, P.G./Project
Manager/Hart & Hickman, PC
Brownfields Project Manager:Brad Atkinson
29
EMP Version 2, June 2018
9/2/2020
Date Click or tap to enter a date.

Figure 1
NCBP Diagram for Temporary.
Containment of Impacted or Potentially
Impacted Soil
Cross -Section View
Top Plastic Cover Sheeting: Linderliner: 1 layer, minimum of 16
(1 Layer, minimum: 10 mil thick)
mil thick plastic
Berm
(Straw bales, Weight
composted earth, etc.) of plastic
cover used)
Land
Surface Contaminated Soils
1
Straw Bale Berm
Map View
■ � � � Ll`ci�t
■� r ("ontaminatcd Soils Z
❑ Plastic
_ Sheeting
Note Adapted from NC DEQ LIST Section "Guidelines for Ex Situ Petroleum Contaminated Soil Remediation" dated December, 1, 2013
30
EMP Version 2, June 2018

.
IdLr
I
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r
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:k
+
■
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fr
.. - .. �
JC�7'.e�i�l►�1�riG�i'
�f
ia��.
APPROXIMATE
N 0 2000 4000
SCALE IN FEET
U.S.G.S. QUADRANGLE MAP
DURHAM, NORTH CAROLINA 2019
QUADRANGLE
7.5 MINUTE SERIES (TOPOGRAPHIC)

WETLAND
WETLAND A II 1
GW-20S
GW-15S
GW-225# ' {
G;-41 GW-41D
GW BNP-2
EW-2 EW-3 II
BIV BNP-4 •IW6
It' �
EW-1 •BNP-1/IW-17
IW-18 •� IW-14
P-5 I(WW�-12D1
�2!j IW
IW-11 BR-3
MW-23S IW-10D dh ...,
c
\,,�7-24S
STORMWATER
ME
';AR-5
STREAM
WETLAND E
I W-06D
BUILDING 6
(100,125 SF) `
BUILDING 8
(118,000 SF)
MW-491
GW-39S
4GW-4OS
TER
B
LDING 7
,150 SF)
we
FRFF�q y/Nc'4 .
LEGEND
BROWNFIELDS PROPERTY BOUNDARY
PARCELBOUNDARY
GROUNDWATER MONITORING WELL
MONITORING WELL
• PHASE II NZVI INJECTION WELL - 5L
■ NZVI INJECTION WELL - CLASS 5L
FRACTURED BEDROCK SVE WELL ALSO USED
AS NZVI INJECTION WELL
♦ EXTRACTION WELL INCLUDED IN MONITORING
NETWORK
RMWATER CONTROL
♦ EXISTING WELLS FOR COMPLIANCE
kSURE "C"
MONITORING
♦ EXTRACTION WELL
LZIWETLANDS AREA
- DEED RESTRICTED AREA
/
TREE COVERAGE AREA
/
AREA OF NC 2L EXCEEDANCE
i
AREA OF CUT
BUILDING 4 /
LIMITS OF DISTURBANCE
i
(100,000 SF)
/
— — — DEMARCATION LINE
/ BUILDING 3
— — — — — LOT LINE
/ (90,300 SF)
i
AMW-6107
Y
/
NOTES:
i
i
1. LOCATIONS OF SOLID WASTE MANAGEMENT UNITS
i
(SWMUs), MONITORING WELLS, REMEDIATION WELLS,
AND NC 2L GROUNDWATER EXCEEDANCES ARE
OBTAINED FROM JULY 30, 2019 FIFTH ANNUAL
ASSESSMENT PREPARED BY GOLDER
ASSOCIATES NC, NC.T
BUILDING
(50,250 SF))
6 STORMWATER CONTROL
"D"
MW-B110
MEASURE
4�
W-5
�OPO
APPROXIMATE
0 250 500
' GW 33S
SCALE IN FEET
yMW-11
T
�� v
�P
SITE MAP
W-33 IW-34 N I
GW.61 IW-35
-GW-6
I- IFCT
GLAXOSMITHKLINE, LLC
3029 E. CORNWALLIS ROAD
DURHAM, DURHAM COUNTY, NORTH CAROLINA
GW 8
3921 Sunset Ridge Road, Suite 301
hart h i c k m a n Raleigh, North Carolina 27607
. 919-847-4241(p) 919-847-4261(1}
GW-7
SMARTER ENVIRONMENTAL SOLUTIONS License # C-1269 / #C-245 Geology
4,JDS-MW-4
DATE: 8-27-20 REVISION NO. 0
JOB NO. TKC-005 FIGURE NO. 3

WETLAND A
STORMWATER
ME
STREAM
WETLAND E
WETLAND
WETLAND
FRFF�q A/c.
.
*(A3
(ABANDONED)
ED (ABA DO
U _JNED) W(gggNDONED)
RFI-4-822* GW-8SB
I OCATED) �(gggNDONED)
�� RFI4-B20
�yy} (ABANDONED)
�CRF-4-B21
NOT LOCATED)
BUILDING 6
(100,125 SF) \
\ i
\ BUILDING 5 /
\ (115,000 SF) i
SWMU-13
(DEED RESTRICTED AREA)
\ j
CENTRAL PARK
GW-43S (ABANDONED` APPR IXO MATE LOCATION OF
a (ABANDONED)�Mw-s / //TWO CLOSED -IN -PLACE LISTs
/ wn
BUILDING 8
(118,000 SF)
TER
B
BUILDING 2
(40,150 SF)
BUILDING 7
(40,150 SF)
we
BUILDING 1
(50,250 SF)
ABANDONED)
NG 3
) SF)
LEGEND
BROWNFIELDS PROPERTY BOUNDARY
PARCELBOUNDARY
4 ABANDONED GROUNDWATER
MONITORING WELL
WETLANDS AREA
DEED RESTRICTED AREA
MTREE COVERAGE AREA
AREA OF NC 2L EXCEEDANCE
AREA OF CUT
LIMITS OF DISTURBANCE
— — — DEMARCATION LINE
— — — — — LOT LINE
NOTES:
1. LOCATIONS OF SOLID WASTE MANAGEMENT UNITS
(SWMUs), MONITORING WELLS, REMEDIATION WELLS,
AND NC 2L GROUNDWATER EXCEEDANCES ARE
OBTAINED FROM JULY 30, 2019 FIFTH ANNUAL
ASSESSMENT REPORT PREPARED BY GOLDER
ASSOCIATES NC, INC.
o STORMWATER CONTROL'
MEASURE "D"
P0�
�O,
APPROXIMATE
0 250 500
77
SCALE IN FEET
ABANDONED WELL LOCATION MAP
I- IFC.T GLAXOSMITHKLINE, LLC
3029 E. CORNWALLIS ROAD
DURHAM, DURHAM COUNTY, NORTH CAROLINA
1121 Sunset Ridge Road, Suite 301
hart ^• h i e k m a n Raleigh, North Carolina 27607
. 919-847-4241(p) 919-847-4261(1}
SMARTER ENVIRONMENTAL SOLUTIONS License # C-1269 / #C-245 Geology
DATE: 8-27-20 REVISION NO. 0
JOB NO. TKC-005 FIGURE NO. 4

Appendix A
Phase I Redevelopment Grading Plan and
Cut -Fill Analysis
hart ` hickman
SMARTER ENVIRONMENTAL SOLUTIONS

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ISWMU 131
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Grad
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Lot 6/pond cut/fill
18,658cy
Lot 6 waste at 3
16,320cy
)t 6 waste at 4
69,274cy
0
'SWMU-121
ot 5/pond cut/fill
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_ot 5 waste at 4
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)t 4 cut/fill
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borrow from 5
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borrow from 6
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grow from Road
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J cut/fill
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from Road
19cy
from Lot 6
Mell�, AGTEK
16,320cy

Appendix B
RCRA Corrective Action Figures
• Figure 1, Construction Completion Report —Soil Excavation for PCB
Remediation and RCRA Corrective Action, Golder Associates NC, Inc.,
September 2015
• Figure 2, Soil Excavation and PCB Remediation Work Plan, Golder Associates
NC, Inc., September 2014
• Figure 2, Fifth Annual Assessment Report, Golder Associates NC, Inc.,
August 2019
10
hart hickman
SMARTER EN VI RON M E NTAI SOLUMNS

N
AGC Stormwater Channel
Area WS-9
(SWMU-1 5)
(Area Behind Former
Hazardous Waste Storage Area) -
Drain Line Excavation
(Area West of WS-9)
i
R
Area WS-1 o ;.
e PL'} Pole I '- (Light o .�;
r
(Including WS-1 o Extension) I
dNL
M"
�r
Area WS 1-2 i
(ANP-P-B64D)i
See Note 3
Area WS 6-2
Warehouse B (Sinkhole) �
(See Note 1) �
Area WS-6
(AOC North Parking Lot)
Temporary WS-8 Stockpile Area
(MSW Stockpile)
i
el Gated TSCA Stockpile
(So r moved from SWMU-13)
r
Water Main Vault
(Punched In and Backfilled)
Temporary Drain Line Stockpile Area
wtiwr � s •
(MSW Stockpile)
a
` Area WS-8
(GW-41 S Location)
w
Water Line Repairs
Area WS-11 Line ,
(AOC Fermentation Building)
UST Area Excavation
Fermentation Building J -
(Soil Boring SB 25)
t*4k,+ '
f *A*? s
i1aI r
I
Pump House,
(See Note 1)
y
Area WS
(SWM 5)
Mechanical Room A
(Former North Building Drain Line Excavations)
(Corridor 150011444)
f
Mechanical oom B
(Former North Building D in Line Excavations)
(Corridor 1 4011409
r4t
I
1 i
�._.._.._ i
Area WS-1
(Light Pole C)
Area WS-2
/-(Light Pole B)
1
X
W -12
X ed Restr' ion Implemented)
igh Occup y Standard with Soil Cover)
x
SWMU-13
x-` (Deed Restriction Implemented)
(TSCA High Occupancy Standard
with Soil Cover)
emporary TSCA Storage Area
(Soils removed from SWMU-13)
Area WS-12
(ANP-P-B93-D)
(Met 1 mg/kg TSCA High
Occupancy Standard;
...._.._.._.._.._.._.._....................................... ..... EPA Approved)
i
Gas o ine Storage Tank Vault' TSCA Stockpile Area
(Pun hed In and Backfilled) I >�
1
1 !
Aria WS-3
Nt Pole A)
I
SWMU-4
Area WS-5 _
(Painting Project)
Initial TSCA Stockpile
Material contained in Roll -Offs)
.._.._.._.._.._.._.._.
i Fd
li
GlaxoSmithKline
CONTRACTOR FIRM ID
G.1der
Associates
Golder Associates NC, Inc.
5B Oak Branch Drive
Greensboro, NC 27407
[phone]
Firm License No. C-2862
CONTRACTOR PROJECT No.: 073-96115.001
Designed By: BS❑
Drawn By: BS❑
Checked By: RPL
Project Manager: Brian Fichlin, P.E.
GSK PROJECT INFORMATION
GSK Project No.: RTP 10-0614
Project Name: PCB Remediation
GSK Project Mgr.: Tom Hilliard, RE
EHS Contact: Lindsey Walata, P.G.
09/11 /2015
CONSTRUCTION COMPLETION REPORT
SOIL EXCAVATION
SWMU-5
(Sanitar astewater Treatment Basin)
(Removed Sedimen Cleaned, and Punched In/Backfilled)
Area WS-4 Drain Line MSW Stockpil
(North Parking Lot Stairs) .� (MSW Soil Staging Area
J
Temporary Drain Line
MSW Stockpile Area I
I
......... .........................
- - -.._........ ....................... - .............................
J19
R
Exterior Drain Lines
•(Former North Buildin Drain Line Excavations)
l
•
(Corridor
1500/1400)
Interior Lines
(Former North Building Drain Line Excavations)
(Corridor 150011400)
qr
1
Mechanical Room C
(Former North Building Drain Line Excavations'
(Corridor 1500/ 1400)
Q 50 100
NOTES
1.) Aerial photograph from 2011. All structures with
the exception of Warehouse B and the Pump House
have been removed.
-
REFERENCES
1.) Coordinate System: NAD 1983 StatePlane North
Carolina FIPS 3200 Feet
Projection: Lambert Conformal Conic
2-) Infrastructure obtained from existing GSK
Drawings and are the same as those presented in the
PCB Work Plan.
3.) Excavation extents shown are based on survey
data provided by Talyor, Wiseman, an Taylor
In some areas complete survey data was not
available. In this case the excavation extents shown
are based on the available TWT survey data and the
excavation field sketches (that included field
measurements). Field notes indicate that WS 6-2
does not connect to WS 1-2.
4.) Service Layer Credits: Source: Esri, DigitalGlobe,
GeoEye, i-cubed, USDA, USGS, AEX, Getmapping,
Aerogrid, IGN, IGP, swisstopo, and the GIS User
Community
CRITICAL DRAWING APPROVALS
t
DEPARTMENT APPROVAL DATE
QA
Engineering
Validation
140
LEGEND
Areas Excavated and Remediated to <1 mg/kg
(High Occupancy Standard for total PCBs)
GSK Property Line (Approximate)
XX—X—
��� �x-x-x
Fenced Area at SWMU-13
, , / / Soil Cover Areas (with concentrations >1 mg/kg
Feet �`�'-' but < 14 mg/kg of total PCBs)
0 FINAL TO EPA 09111 /15
No. REVISION Date
sidg operation'
IPmiecWgr'
GIS: BS❑
Site: GSK S. CAMPUS, N. COMPLEX
Scale: 1" = 50' (E-SIZE)
Title:
SUMMARY OF NORTH SITE PCB REMEDIATION
AND RC RA CORRECTIVE ACTION SOIL
EXCAVATION ACTIVITIES
Drawing Number:
Rev:
FIGURE 1
Q

SITE BOUNDARY
O I
IP-BULL LNG
I
AOCST AOC OF
O/? PARK G
MWgTFR �
i
c if is
W A
REPAIRS
AOC-W-1 LIGHT POLE FIRE
_..
gpCFF PL-1 V
RMFHT FORMER
gr"OH FERMENTATION
eUQOIHG BUILDING L:
FIRE LINE
SES MENT
/ LIGHT POLE
ASSESSMENT
J�
/ NORTH COMPLEX
ROADWAY REPAVING
TEMPORARY ROAD
ASSESSMENT
r
FIRE LINE
ASSESSMENT
OG/
Q
SWMU-13
APPROXIMATE LOCATION
OF FORMER TRENCHES
I
APPROXIMATE LIMITS OF /
WASTE WATER TREATMENT
ACTIVITIES
-i Li ��
\\ SWMU-4
7
LOCATION OF
HISTORICAL
AND EXISTING
STRUCTURES
I�
TENNIS i OURTS
PAINTING PRO T
5 T IRWEL -
L IN TALLA UTILITY
PROJECT CONDUITI
i
ROOF DRAIN ASSESSMENT
�,�e
NT
O
SWI
a
LEGEND
❑ AREA(S) WHERE PCB CONCENTRATIONS POTENTIALLY EXCEED 1 RPM
® INVESTIGATED AREA(S) WHERE PCB CONCENTRATIONS ARE NON —DETECT
/
■ INVESTIGATED AREA(S) WHERE PCB CONCENTRATIONS ARE BELOW 1 PPM
/
❑ AREAS PREVIOUSLY EXCAVATED
APPROXIMATE LIMITS OF EXISTING BUILDING(S)
/
APPROXIMATE LOCATION OF HISTORICAL STORMWATER SWALE
- — — — — — -
/
NOTE
1.) THE LOCATIONS AND DIMENSIONS OF AREAS OF INVESTIGATION AND/OR
EXCAVATION ARE APPROXIMATE.
2.) BASED ON HISTORICAL AREAS OF DISTURBANCE.
/
REFERENCES
/
1.) ALL BASE CADD FILES USED DURING DRAWING PROTOTYPE CONSTRUCTION WERE
TAKEN FROM COMPACT DISK SUPPLIED BY GSK.
2.) COORDINATE SYSTEM SHOWN IN NORTH CAROLINA STATE PLANE NAD27.
/
100 0 100 200
SCALE FEET
Lt
l4b, -.axoSmithl(in
CONTRACTOR FIRM ID
(PA=kries
GREENSBORO, NO
CONTRACTOR PRO' No: 073-96115
Designed By: JAD
Drawn By: RG
Checked By: BJE
Project Manager: BRIAN EICHUN, P.E.
GSK PROJECT INFORMATION
GSK PROJECT NO: RE10614
PROJECT NAME: RCRA CORRECTIVE MEASURES
GSK PROJECT MGR: TOM HILLIARD, P.E.
ENS CONTACT: UNDSEY WALATA, P.G.
PCB WORK PLAN
CRITICAL DRAWING APPROVALS
DEPARTMENT APPROVAL DATE
OA
Engineering
Validation
No
Revision
Date
mes aarasea./
Roha1
CAD: RG
Site: GSK S. CAMPUS, N. COMPLEX
Scale: AS SHOWN
Title:
SUMMARY OF FACILITY WIDE
PCB INVESTIGATION
AND REMEDIATION
FIGURE: 2
Drawing Number:
TBD
Rev:
0

LEGEND
$GW-44S GRCLL—EN MONITORING WELL
+GW-38S MONITORING WELL (NOTE 5) GI2XOSmIthKllne
+MW-9 EXISTING WELLS FOR COMPUANCE MONITORING
1>4-1Re=; Vr1='!=E=aLt7x w na m
— "l• "1• Dritl= :'=rCCi` xt �' •: :ids / r BR3 NJ�ECTUONDWELDROCR SVE WELL PLSO USED AS NI T
'•• nyKy�t LfJI D I IW-03 PHASE II NNI INJECTION WELL -CUSS 5L G O L D E R
YT"---=-rrr "I- T s L; I IW-31 NNI INJECTION WELL -CUSS 51
] T
A EW-1 EXTRACTION WELL
P \ �A °� I ♦ Ew-a0 E%TRACTION WELL FOR COMPLIANCE MONITORING
—11
�— lw :� ':F x; 1 • :Rjl i FOR INJECTION WELLS "D" DENOTE DEEP WELLS OTHER INJECTION WELLS ARE gnm R' 9L 961
'N• -¢ N THE SHALLOW ZONE; FOR MONITORING WELLS "S" DENOTE SHALLOW AND "I a.n K
1N11��•) INTERMEDNTE WELLS OTHER MONITORING WELLS ARE IN THE DEEP ZONE. mrm W' %x
1.�1.�iY__.•_
ICI :cl •: ! - PROPERtt BOUNDARY _
r i �•-� ADJACENT PROPERTY BOUNDARY CS% CO FxIHKT x0'. 119U5
zi fur �y r MNA MONITORING LOCATIONS RCR4 CORRFCME MEASURE
4Vr•Po�,AMIN
I ACT'. UNOSEY WAUi0. PC.
NOTES FIFTH ANNUAL REPORT
- - - . CURRENT AND FORMER BUILDING STRUCTURES ARE SHOWN,
2. GLAXOSoTHKLINE CONTRACTED A NORTH CAROLINA UCENSED LAND
• '+ SURVEYOR TO LOCATE WELLS AT THE SOUTH CAMPUS, NORTH COMPLEX
-r - : .~ : _�-�•�-•�•'�'• •'�_' • r ___--_ —•-_-_ �..�---_— - WELLSTMON THEIN RHAM, NO PROPERIY. TOE PHE URVEYOREXIEUNSEIVES SULLY EARCHO INT W0109
NG
" ..a� .�. .i -. •. " . ). :.:r. �" r.:L _a, - ,�• rxI - E"-�ww SURVEYING THE LOCATIONS ANDSA SEARCH OF THE AREA USINGCGftOUND
�• �".o� �¢x-.s �pRO �r PENETRATING RADAR, FOUR WELLS (MW-4. RFI-4-B21, RFI-4-B22, AND
-: :e : e� 1u.naa, pERttBO RFI-16-B11) COULD NOT BE LOCATED.
uxo "-" - -- a - --, •. .M .'. ARY� 3. MARCH 9-10, 2016 MONITORING WELLS GW-858, GW10-S, GW37-S,
+: r .• �� @�-1° MW-J, RFI-4-B18, RFl-4-B19, AND W-J WERE ABANpONED. AUGUST 16
•. ^I-: •'•_ 2017 MONITORING WELLS GW-33S AND W-4 WERE ABANDONED.
^ INJECTION WELLS IW-04R, IW-OJ, IW-0J5, IW-09, IW-13, AND IW-15
- - �^: - - r. WERE INSTALLED IN NONEMBER 2018,
-- L 1 _ y _ ♦�_u i 5. NOT SAMPLED AS PART OF RCRA CORRECTNE MEASURES DURING OR SINCE
THE BASEUNE SAMPLING EVENT.
REFERENCES
PA GROUNDWATER MONITORING WELLS TAKEN FROM CADD FILE TITLED
54/OWAN-DG-FIG5-15", DATED 06/22/00.
2. 121/10ETRIC FEATURES TAKEN FROM TEDD FILE TITLED "S&ME", DATED
r_W / / cu-xs0'� .s II •� P cx-ras 11/ IMETRI ALL FEATURES WERE SHIFTED 208.)1 FEET AND
R Fl� T••-x 223D35'39.423• TO ALIGN WITH GROUNDWATER MONITORING WELLS.
3. ALL BASE CPDD FILES USED DURING DRAWING PROTOME CONSTRUCTION
- -� _ WERE TAKEN FROM COMPACT DISK SUPPLIED BY GSK.
I ezx
v 4. SNP-1 AND GW-S WERE SURVEYED IN NOVEMBER 2008 BY STANTEC
•.\ / O 6, s w_- - I_.�p q I CONSULTNG.
,\ ��_.� •�<� c- - �m-es 5. COORDINATE SYSTEM SHOWN IS NORTH CAROLINA STATE PLANE NAD27.
•,\ "'a A 6 - BNP-3, BNP-4, GW-47S, G -485 ANO W-2 WEE U D
09Y11/02 AND GW-49I AND GW-501WWERE SURVEYED CN R11/15/02 BY N
/ TA LOR WISEMAN AND TAYLOR,
). MONITORING WELL LOCATIONS FROM JOHN R. MCADAMS COMPANY, INC. MAY
PA PA/ 012 DATED MAY 2, 2D12 (2012-05-02) ABB LOCATIDN.DWG)
8. ONSITE WELLS WERE RESURVEYED IN NOVEMBER 2015 BY TAYLOR WISEMAN
TAYLOR,
INJECTION WELLS IW-04R, IW-07, IW-07S. IW-09. IW-13, AND IW-15
WERE SURVEY BY TAYLOR, WISEMAN, TAYLOR IN DECEMBER 2018. wem
PO e �� A
FA oa \FA
i
o ; pNl—
aw�A psGKKS CAMPUS.
_ss % -1 I-INY
v ) '\ 'un-eroz % GROOUONDRKATER MONITORING W
FIGURE
ppFA
PA � N1 ,,\,,� KOrawlna xumeer.NUFT
Reo
�Jm-Mx-t

Appendix C
Regulatory Correspondence

Waste Management
ENVIRONMENTAL QUALJ7 e
April 22, 2016
Lindsey Walata
Shared Service Environmental Manager
GlaxoSmithKhne
5 Moore Drive
Post office Box 13398
Research Triangle Park, North Carolina 27709-3398
PAT MCCRORY
Cowrmor
DONALD R. VAN DER VAART
&-vary
MICHAEL 5COTT
A ctiug ❑ireeav
Re: Construction Completion Report — Soil Remediation for PCB Remediation and
RCRA Corrective Action
G1axoSmithKhne South Campus
NCD 052 547 635
Dear Ms. W aiata:
The North Carolina Hazardous Waste Section has completed its review of the RCRA corrective action
portion of G1axoSmithKline's Construction Completion Report — Soil Remediation for PCB Remediation
and RCRA Corrective Action dated September, 2015. The RCRA corrective action portion of this report
is found to be acceptable at this time.
It is our understanding from the report that the volatile organic compound soil remediation was
successfully performed in thirteen of the fourteen areas addressed in the report. With the exception of
SWMU 13 — Former Landfill, the Hazardous Waste Section agrees that the soils in the areas have reached
a status of No Further Action for the volatile organic compound (VOC) impacted soils at this time (see
attached table).
Also note since VOC contamination remains at SWMU 13 —Former Landfill, remediation conducted
under the corrective measures remedy, which includes a soil vapor extraction system and in -situ
groundwater remediation, will continue.
If you have any questions, please contact Carl Utterback at [phone] or Rob McDaniel at (9I9)
707-8215,
Sincerely,
Carl Utterback, Environmental Engineer
Division of Waste Management, NC DENR
cc: Ken Feely, US EPA, Region 4
Philip Orozc❑
Harold A. McCarty
Carl Utterback
Robert C. McDaniel
State of North Camlina I Environmental Quality I Write Management
1646 Mail Scrriee Ccntcr Zi 7 West ]ones Surd italeigia_ NC 27699-1646
919 707 END T

GlaxoSrnith.Kline
Research Triangle Park, North Carolina
NCD 452 547 635
Construction Completion Report — Soil Remediation for PCB Remediation and
RCRA Corrective Action
AREA
NAME
DETERMINATION
Drain Line and SWMU 12
Fonner Surface impoundment
No Further Action Required
SWMU 13
Former Landfill
VOC remediation being
conducted under the CMS
remedy.
Area WS-1
UlghtFole C
No Further Action Required
Area WS 1-2
ANP-B64-D
No Further Action R uired
Area WS-2
Light Pole B
No Further Action Required
Area WS-3
Light Pole A
No Further Action Required
Area WS-4
North Parking Lot Ste s
No Further Action Required
Area WS-5
Painting Project
No Further Action R uired
Area WS-6
AOC North Parking Lot
No Further Action Required
Area WS-6-2
Sinkhole Location
No Further Action Required
Area WS-7
SWMU 15 Former Gravel/Burn
Pit
No Further Action Required
Area WS-8
SWMU 16 Monitoring Well GW-
411Storm Water Pipe Repair Area
No Further Action Required
Area WS-9
SWMU 16 - Area Behind Former
Hazardous Waste Storage
No Further Action Required
Area WS-14
Light Pole PL-1
No Further Action Required