22061-18-092_NCDOT-CC Mangum_Approved EMP_20210608

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PREPARED FOk.
Rogers Lane Partners, LLC
1201 Edwards Mill Road
Raleigh, North Carolina 27605
PREPARED BY:
S&ME, Inc.
3201 Spring Forest Road
Raleigh, NC 27605
Corporate Registration for Licensing of NC Geologists No. C-145
NC Engineering Firm No. F-0176
May 26, 2021

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May 26, 2021
Anthony Property Group
1201 Edwards Mill Road
Raleigh, North Carolina 27607
Attention: Mr. Jason Clough via email: [e-mail]
Project Manager / Development
Reference: Environmental Management Plan (EMP) for Site Development
5000 Raleigh Beach Rd., 2901, 2905, and 2909 Sunrise Valley PI., 1840 and 1900 Southall Rd.
Raleigh, Wake County, North Carolina 27610
Brownfields Project Name: NCDOT-CC Mangum-US64E
Brownfields Project No. 22061-18-092
S&ME Project No. 4305-18-216A
Dear Jason:
Please find the enclosed Environmental Management Plan (EMP) to address site development activities for the
site. This draft EMP is provided for review and comment, prior to submittal to the North Carolina Brownfield
Program (NCBP). Our services were performed in general accordance with S&ME's proposal number 4305-18-
216A-CO4, dated December 11, 2019.
Sincerely,
S&ME, Inc.
Michael W. Pfei fer
Senior Project Manager
[e-mail]
cc: Wayne Hightower ([e-mail])
c�'V--
Samuel P. Watts, PG
Senior Consultant
[e-mail]
Enclosure: Environmental Management Plan for Site Development, dated May 26, 2021
S&ME, Inc. 13201 Spring Forest Road I Raleigh, NC 27616 1 p 919.872.2660 1 www.smeinc.com

Table of Contents
North Carolina Brownfields Program Environmental Management Plan
ChecklistForm.....................................................................................................................1
GeneralInformation...........................................................................................................3
Communications...................................................................................................................3
Notifications to the Brownfields Program.......................................................................4
RedevelopmentPlans..........................................................................................................4
ContaminatedMedia...........................................................................................................6
Part1. Soil...................................................................................................................................................6
Part2. Groundwater................................................................................................................................15
Part3. Surface Water................................................................................................................................17
Part4. Sediment........................................................................................................................................17
Part5. Soil Vapor.....................................................................................................................................18
Part6. Sub -Slab Soil Vapor.....................................................................................................................19
Part7. Indoor Air......................................................................................................................................19
Vapor Intrusion Mitigation System................................................................................20
ContingencyPlan................................................................................................................20
PostRedevelopment Reporting.......................................................................................23
ApprovalSignatures..........................................................................................................24
S&ME, Inc. 13201 Spring Forest Road I Raleigh, NC 276161 p 919.872.2660 1 www.smeinc.com

Environmental Management Plan (EMP) for Site Development
Brownfields Project Name: NCDOT-CC Mangum-US64E
Brownfields Project No. 22061-18-092
S&ME Project No. 4305-18-216A
Table of Contents (cont'd)
List of Figures
Figure 1 — NCBP Diagram for Temporary Containment of Impacted or Potentially Impacted Soil
Figure 2 — Preliminary Development Exhibit
Figure 3 — Maximum Contaminant Concentration Exhibit
Figure 4 — Preliminary Development Exhibit with Maximum Contaminant Concentrations
Figure 5 — Preliminary Grading Plan
List of Appendices
Appendix I — Amendments to Brownfields Redevelopment and Environmental Plan
Appendix II — Summary of Soil Gas Analytical Results and Figure, December 6, 2019 Soil Gas, Soil, and
Groundwater Assessment Report
May 26, 2021

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.
EMP Version 2, June 2018

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.
EMP Version 2, June 2018

Date: 5/18/2021
GENERAL INFORMATION
Revision Date (if applicable): Click or tap to enter a date.
Brownfields Assigned Project Name: NCDOT-CC Mangum-LIS64E
Brownfields Project Number: 22061-18-092
Brownfields Property Address: 5000 Raleigh Beach Rd., 2901, 2905, 2908, and 2909 Sunrise Valley PI.,
1840, 1800, and 1900 Southall Rd. 1135 North Rogers Lane and 5655 New Bern Ave., Raleigh, NC
Brownfields Property Area (acres): approx. 62 acres
Is Brownfields Property Subject to RCRA Permit? ....................... ❑ Yes ® No
If yes enter Permit No.: Click or tap here to enter text.
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): Rogers Lane Partners, LLC
Contact Person: Jason Clough
Phone Numbers: Office: 919-582-3122
Email: [e-mail]
Contractor for PD: To be determined.
Contact Person: Click or tap here to enter text.
Phone Numbers: Office: Click or tap hereto enter text
Email: Click or tap here to enter text.
Environmental Consultant: S&ME, Inc.
Contact Person: Sam Watts
Phone Numbers: Office: 919-872-2660
Email: [e-mail]
Brownfields Program Project Manager: Brad Atkinson
Phone Numbers: Office: 919-707-8748
Email: [e-mail]
EMP Version 2, June 2018
Mobile: Click or tap here to enter text.
Mobile: Click or tap here to enter text.
Mobile: [phone]
Mobile: Click or tap here to enter text.

Other DEQ Program Contacts (if applicable, i.e., UST Section, Inactive Hazardous Site Branch,
Hazardous Waste, Solid Waste):
_iicK or iap nere io enter iexi.
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
El Other specify:
Click or tap here to enter text.
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
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:
EMP Version 2, June 2018

Preliminary development plans for the site are included in this EMP. The latest iteration of
development plans includes construction of a retail grocery store, and retail outparcels, on the
western portion of the site (Phase 2). The central and eastern portions of the site (Phase 1 and
Phase 3) will be developed with a mix of apartments, retail, and office buildings. The conceptual
site plan is included as Figure 2.
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 ves, 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: 10/1/2021
b) Anticipated duration (specify activities during each phase):
Q4 2021. Begin with rough grading of entire site and installation of streets and utilities. Will
continue with construction of stormwater control measures (SCMs) and filling the existing
SCM.
Q2 2022. Begin construction of residential multifamily apartment buildings in Phase 1.
c) Additional phases planned? ❑ Yes ❑ No
If yes, specify the start date and/or activities if known:
Start Date: To be determined. The year 2023 or later.
Planned Activity:
Development of structures on Phases 2, 3, and 4.
Start Date: Click or tap to enter a date.
Planned Activity:
Click or tap here to enter text.
S
EMP Version 2, June 2018

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: 4/1/2023
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):
Laboratory analysis of soil samples, collected from the site, detected arsenic at a concentration
greater than its Preliminary Health Based Soil Remediation Goal (PSRG). It should be noted that
arsenic is a naturally occurring element that is often present in soil at a concentration greater
than its respective PSRG.
Laboratory analysis of soil samples, collected following the excavation of petroleum -impacted
soil at the aboveground storage tank (AST) farm in October 2004, detected Oil and Grease and
Total Petroleum Hydrocarbons (TPH) — Diesel Range Organics (DRO) at concentrations above
their respective UST Section Action Levels.
2) Depth of known or suspected contaminants (feet):
Arsenic was detected, at concentrations similar to naturally occurring levels in the area, from the
ground surface to 12 feet below the subsurface.
Oil and Grease and TPH-DRO were detected above their respective UST Action Levels at depths
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ranging from 2 feet below the ground surface to 15 feet below the ground surface.
3) Area of soil disturbed by redevelopment (square feet):
Preliminary development plans are included in this EMP. It is anticipated that the entire site will
be disturbed for redevelopment, except for the tree -save areas that have already been
designated on the site. The western portion of the site encompasses an area of approximately
742,000 square feet. The central and eastern portions of the site encompass an area of
approximately 1,200,000 square feet.
4) Depths of soil to be excavated (feet):
It is estimated that soils may be excavated from 0 to 16 feet below ground surface. Exact depths
of soils to be excavated have not yet been determined.
5) Estimated volume of soil (cubic yards) to be excavated (attach grading plan):
The estimated volume of soil to be excavated is approximately 208,196 cubic yards. A
preliminary site development plan is attached as Figure 2, and a preliminary grading plan is
attached as Figure S.
6) Estimated volume of excavated soil (cubic yards) anticipated to be impacted by contaminants:
The estimated volume of soil to be excavated is approximately 208,196 cubic yards, of which
86,880 cubic yards is expected to be disposed offsite. It should be assumed that soil across the
site will contain naturally occurring arsenic at a concentration greater than its respective PSRG.
Soil containing Oil and Grease and TPH-DRO at concentrations greater than their respective UST
Action Levels is assumed to be confined to the area of the former AST Farm.
7) Estimated volume of contaminated soil expected to be disposed of offsite, if applicable:
The estimated volume of soil to be excavated and disposed offsite is approximately 86,880 cubic
yards. It should be assumed that soil across the site will contain naturally occurring arsenic at a
concentration greater than its respective PSRG. Soil containing Oil and Grease and TPH-DRO at
concentrations greater than their respective UST Action Levels is assumed to be confined to the
area of the former AST Farm. To minimize the amount of soil transported off -site, and minimize
the amount of soil brought on -site, soil excavated to achieve the desired grade in areas of cut
should be used for backfilling in areas that require fill.
Part 1.A. MANAGING ONSITE SOIL
If soil 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 preliminarydata available).
1) HAZARDOUS WASTE DETERMINATION:
a) Does the soil contain a LISTED WASTE as defined in the North Carolina Hazardous
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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 or tap 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
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 Click 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:
Laboratory analysis of soil samples, collected from the site, detected arsenic at a
concentration greater than its Preliminary Health Based Soil Remediation Goal
(PSRG). It should be noted that arsenic is a naturally occurring element that is
often present in soil at a concentration greater its respective PSRG.
Soil containing Oil and Grease and TPH-DRO at concentrations greater than their
respective UST Action Levels is assumed to be confined to the area of the former
AST Farm.
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
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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)
® Site -specific risk -based cleanup level. Please provide details of methods used for
determination/explanation.
For those metals that are naturally occurring at concentrations greater than PSRGs, a
comparison will be made to background concentrations.
Additional comments:
_iiu< or tap here to enter text.
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 ❑
® Describe cap or fill:
Soils will be capped with buildings and paved surfaces over a majority of the site. Soils that
are not under these areas will be covered with vegetation. A minimum amount of exposed
soil is anticipated upon completion of final site development.
® 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:
-k or tap here to ent-- +_
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:
* Minimize the number of times the contaminated or stockpiled soil is handled;
* Material handling will be conducted in the controlled exclusion zone outside the
EMP Version 2, June 2018

excavation area.
* If fugitive dust becomes a problem for the workers or looks like it may leave the site,
fugitive dust emissions will be controlled as needed to by wetting, using water obtained
from clean sources.
* Care shall be taken not to over -wet excavated soil.
❑ No, explain rationale:
Field Screening of site soil
® Yes, describe the field screening method, frequency of field screening, person conducting
field screening:
A qualified environmental professional from S&ME will utilize a photoionization detector
(PID) to screen the excavated soils in the area of the former AST Farm near the former
asphalt plant, where Oil and Grease and TPH-DRO were detected above their respective
UST Action Levels.
® No, explain rationale:
Analytical results of the environmental assessment indicate arsenic was the only
constituent detected above its respective PSRG across the remainder of the site. Arsenic is
naturally occurring in this area at a concentration that exceeds the PSRG. Detections of
other constituents were below their respective PSRGs. Therefore, field screening of site
soil will not occur unless an unknown area of concern is encountered.
If an unknown area of concern is encountered, redevelopment activities in the area will be
suspended. The construction company will immediately notify S&ME and the PD. A
qualified environmental professional from S&ME will assess the area, evaluate the waste
materials and/or impacted media in the area, if present, and determine the proper means
for managing these materials. Within 24 hours, S&ME will inform NCBP of the findings and
subsequent actions to be taken for managing these materials.
Soil Sample Collection
® Yes, describe the sampling method (e.g., in -situ grab, composite, stockpile, etc.):
There is a potential for petroleum -impacted soil in the area of the former AST Farm near
the former asphalt plant. If field screening of soils in this area indicates the presence of
significant contamination, and if these soils need to be disposed of offsite, a soil sampling
plan will be developed, in coordination with the NCBP Project Manager, following the
Inactive Hazardous Sites Branch (IHSB), Guidelines for Assessment and Cleanup of
Contaminated Sites, January 2020 (or most recent version). Additionally, if the soils are
going to be disposed at a licensed disposal facility, and the facility will not accept the
historic data as sufficient, then soil samples may need to be collected, for laboratory
analysis.
® No, explain rationale:
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An approved environmental assessment was conducted for the site which was used to
screen on -site soils and determine if contamination was present. Composite samples
were submitted for SVOC and metals analysis and grab samples were submitted for VOC
analysis. Results of the environmental assessment indicated that arsenic was present
above its PSRG, but it is also naturally occurring in this area at a concentration above its
PSRG. No other constituents were detected above their respective PSRGs. Additional soil
sample collection is not anticipated at this time.
If an unknown area of concern is encountered, redevelopment activities in the area will
be suspended. The construction company will immediately notify S&ME and the PD. A
qualified environmental profession from S&ME will assess the area, evaluate the waste
materials and/or impacted media in the area, if present, and determine the proper means
for managing these materials. If impacted media is present, an S&ME representative will
collect soil samples for laboratory analysis. Within 24 hours of receiving analytical results,
S&ME will inform NCBP of the findings and subsequent actions to be taken for managing
these materials
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):
Click or tap here to enter text.
❑ Pesticides: Specify Analytical Method Number(s):
Click or tap here to enter text.
❑ PCBs: Specify Analytical Method Number(s):
Click or tap here to enter text.
❑ Other Constituents & Respective Analytical Method(s) (i.e. Hexavalent Chromium,
Herbicides, etc.): Specify Analytical Method Number(s):
Click or tap here to enter t.
® 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 text.
® Final grade sampling of exposed native soil (i.e., soil that will not be under buildings or
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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):
Click or tap here to enter text.
❑ Pesticides: Specify Analytical Method Number(s):
❑ PCBs: Specify Analytical Method Number(s):
UICK or tap nere to enter text
❑ Other Constituents & Respective Analytical Method(s) (i.e. Hexavalent
Chromium, Herbicides, etc.):
Click or tap here to enter text.
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.
If VOCs are detected near the asphalt plant area and those soils are exposed (or moved on -
site), then final sample locations will be coordinated with NCBP Project Manager prior to
occupancy of relevant buildings near the exposed soil.
® If final grade sampling was NOT selected please explain rationale:
Arsenic was the only constituent detected at a concentration greater than its Preliminary
Health Based Soil Remediation Goal (PSRG). However, arsenic is a naturally occurring
element that is often present in soil at a concentration greater its respective PSRG in this
area of the State.
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?
Estimated volume of fill soil to be imported to the site has not yet been determined.
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.)
Estimated depths of fill to be placed at the property have not yet been determined.
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:
Wake Stone Corporation
6811 Knightdale Blvd.
Knightdale, NC 27545
Phone — 919-266-9266
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.
Fill soil from Wake Stone Corporation has been pre -approved by the NCBP by analytical testing
for use on other Brownfields projects. The Wake Stone Knightdale Quarry is a secure facility
surrounded by fencing, and has been a crushed stone mining operation since approximately
1970. Through the crushed stone manufacturing processes (blasting, mining, crushing, and
screening), "fines" (stone not otherwise classified by size, intended use, or other criteria) are
produced which, in turn, are routinely used for compaction fill.
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):
ri;rL nr +nn here to Pam+ f
❑ Pesticides: Specify Analytical Method Number(s):
I.IIUK VI ldp IICIC lV CIIICI lCh
❑ PCBs: Specify Analytical Method Number(s):
Click or tap here to enter text
❑ Other Constituents & Respective Analytical Method(s) (i.e. Hexavalent
Chromium, Herbicides, etc.):
Click or tap here to enter tex'
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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EMP Version 2, June 2018

borrow sites. If using a quarry, provide information on the type of material to be brought
onto the Brownfields Property.
Fill materials will be brought on site from the Wake Stone Corporation. Wake Stone has been pre -
approved by the NCBP by analytical testing for use on other Brownfields projects.
Part 1.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.
It is estimated that soil may be excavated from depths ranging from 0 to 16 feet below ground
surface (ft-bgs). Approximately 86,880 cubic yards will be exported offsite. The exported soil is
contaminated with arsenic. To minimize the amount of soil disposed of off -site, and minimize
the amount of soil brought on -site, soil excavated to achieve the working elevation in areas of
cut should be stockpiled on -site and then used for backfilling and site restoration.
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
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EMP Version 2, June 2018

details related to the proposed plans).
Exported soil from the Brownfield site may be transported to the closed Wilder's Grove MSW
Landfill owned by the City of Raleigh, which is across from the City of Raleigh Yard Waste Center
located at 900 New Hope Rd., Raleigh, NC. The City will use the soil for maintenance to fill
landfill subsidence which occurs over time. The soil will still be regulated under a closure
permit. Excess fill from Brownfields sites have previously been used in this manner (NCPB
#20031-16-092 and #2206-18-092 and #22043-18-092)
City of Raleigh contact - Mr. John Ennis - 919-250-2728
For other disposal destinations that have not yet been identified, the contact info will be
amended to this EMP and will be provided to the NCBP, once the final destination is
determined.
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
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 I � 1«1
❑ If no, include rationale here:
CIir-'- -. tap here — PntPr taxt
Other comments regarding managing impacted soil in utility trenches:
Click or tap here to enter text.
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 ranges from 10 to 55 feet below the
ground surface.
2) Is groundwater known to be contaminated by ®onsite ❑offsite ❑both or ❑unknown
sources? Describe source(s):
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The main source of groundwater contamination at the site is from solvents related to the former
operation of an asphalt plant at the site.
3) What is the direction of groundwater flow at the Brownfields Property?
East toward the Neuse River.
4) Will groundwater likely be encountered during planned redevelopment activities?
®Yes ❑No
If yes, describe these activities:
Some areas are expected to be cut to depths up to 16 ft-bgs. Groundwater may be encountered
in these areas. During the shallow groundwater assessment conducted in November 2018,
analytical results of the samples indicated that none of the target constituents were detected
above the laboratory's method detection limits. S&ME concluded that historic groundwater
contamination as a result from the site's former operation of an asphalt plant is no longer
present in the shallow aquifer. Therefore, contaminated groundwater is not expected to be
encountered during development activities.
Regardless of the answer; 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., dewateringof groundwater from excavations or
foundations, containerizing, offsite disposal, discharge to sanitary sewer, NPDES permit, or
sampling procedures).
If contaminated groundwater is encountered that will inhibit the progress of site development,
the contaminated groundwater will be pumped from the excavation, contained, sampled, and
properly disposed at a licensed facility if needed.
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?.................................................................................................................. ❑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.
7) Please provide additional details as needed:
All known, existing monitor wells will be properly abandoned in accordance with applicable State and
local regulations.
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EMP Version 2, June 2018

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):
S&ME collected environmental samples of sediment and surface water from the pond on
October 7, 2019 for analysis of VOCs by 8260, SVOCs (PAHs only) by 8270, 8 RCRA Metals, and
Hexavalent Chromium. Laboratory analysis of the surface water indicated all constituents were
less than Surface Water (213) Standards.
On November 6, 2019 the dam of the on -site pond was breached, and the pond was drained,
following an Environmental Management Plan (EMP) approved by the NCBP, and following
Division of Water Quality (DWQ) guidance for draining ponds. A small spring/stream has formed
on -site in the location of the former pond.
In the event that contaminated surface water is encountered that will inhibit the progress of site
development, the contaminated surface water will be contained, sampled, and properly
disposed at a licensed facility if needed
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
4) Attach a map showing location of known contaminated sediment at the property.
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EMP Version 2, June 2018

5) In the event that contaminated sediment is encountered during redevelopment activities, list
activities for management of such events (stream bed disturbance):
On November 6, 2019 the dam of the on -site pond was breached, and the pond was drained,
following an Environmental Management Plan (EMP) approved by the NCBP, and following
Division of Water Quality (DWQ) guidance for draining ponds. There are no other on -site
locations where sediments might be encountered.
In the event that contaminated sediment is observed through visual or olfactory observations, the
contaminated sediment will be stockpiled as shown in the attached Figure 1. S&ME will collect a
sample from the stockpiled material for analysis. The stockpiled sediment will be re -used on site,
or disposed at a licensed disposal facility pending analytical results.
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:..... El 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?
Soil vapor samples were collected across the site up to depths of 10 ft-bgs. A summary table with the
soil vapor concentrations and accompanying Figure with sample locations are included in Appendix II.
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:
The laboratory analytical results from the soil gas assessment conducted at the site in October
2019 indicate 1,3-butadiene was detected in several of the samples at concentrations exceeding
its respective Residential Soil Gas Screening Level (SGSL). S&ME utilized the NCDEQ Risk
Calculator to evaluate the vapor intrusion risk of 1,3-butadiene and the cumulative risk of other
VOC detections in the soil gas across the site. The results of the NCDEQ Risk Calculator indicated
that 1,3-butadiene potentially exceed the residential vapor intrusion risk. Prior to site
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EMP Version 2, June 2018

development, soil gas samples shall be collected beneath the footprint of the proposed
residential structures on the property and if the results indicate a vapor intrusion risk, vapor
mitigation systems will be installed beneath the residential structures. The planned commercial
and residential structures are shown on Figures 2 and 4.
If contaminated vapors are encountered during redevelopment activities, which might inhibit the
safe work practices of the construction personnel, a temporary ventilation system should be
installed to divert contaminated vapors away from the breathing zone of the site workers and
the public.
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
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
If contaminated sub -slab vapors are encountered during redevelopment activities that will
inhibit the safe work practices of the construction personnel, a temporary ventilation system will
be installed to divert contaminated vapors away from the breathing zone of the site workers and
the public.
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:
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EMP Version 2, June 2018

If contaminated indoor air is encountered during redevelopment activities that will inhibit the safe
work practices of the construction personnel, a temporary ventilation system will be installed to
divert contaminated vapors away from the breathing zone of the site workers and the public.
VAPOR INTRUSION MITIGATION SYSTEM — Please fill out the information below.
Is a vapor intrusion mitigation system (VIMS) proposed for this Brownfields Property?
® Yes ❑ No ❑ Unknown
If yes, ❑ VIMS Plan Attached or ® VIMS Plan to be submitted separately
If submitted separately provide date:
To be determined
VIMS Plan shall be signed and sealed by a NC Professional Engineer
If no, please provide a brief rationale as to why no vapor mitigation plan is warranted:
Prior to site development, soil gas samples shall be collected beneath footprint of the proposed
residential structures on the property and if the results indicate a vapor intrusion risk, vapor
mitigation systems will be installed beneath the residential structures. See Figures 2 and 4 for
locations of the planned commercial and residential structures.
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
20
EMP Version 2, June 2018

silver)
Click or tap here to enter text.
❑ Pesticides: Specify Analytical Method Number(s):
Click or tap here to enter text.
❑ PCBs: Specify Analytical Method Number(s):
Click or tap here to enter text.
❑ 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.
Please provide details on the proposed methods of managing the following commonly
encountered issues during redevelopment of Brownfields Properties.
This EMP has been prepared to address site development. Analytical results of the sediment and
soil indicate arsenic was the only constituent detected above its respective PSRG. Arsenic is
naturally occurring in this area at concentrations that exceed its PSRG. Detections of other
constituents were below their respective PSRGs.
Laboratory analysis of soil samples, collected following the excavation of petroleum -impacted soil at
the aboveground storage tank (AST) farm in October 2004, detected Oil and Grease and Total
Petroleum Hydrocarbons (TPH) — Diesel Range Organics (DRO) at concentrations above their
respective UST Section Action Levels. So there is a potential for petroleum -impacted soil to be
encountered in this area.
In areas of suspected petroleum/VOC contamination, a qualified environmental professional from
S&ME will utilize a photoionization detector (PID) to screen the excavated soils. If field screening of
excavated soils indicates the presence of significant contamination, the suspected contaminated soil
will be stockpiled as shown in the attached Figure 1. A soil sampling plan will be developed, for the
excavated soils, in coordination with the NCBP Project Manager, considering the final disposal
location of the excavated soil (e.g., on -site or off -site), and generally following the Inactive
Hazardous Sites Branch (IHSB), Guidelines for Assessment and Cleanup of Contaminated Sites,
January 2020 (or most recent version).
Analytical results of the surface water and groundwater indicate that none of the target
constituents were detected at concentrations above their respective 2B Surface Water standards or
2L Groundwater standards.
Underground Storage Tanks:
If a UST is encountered,
• Redevelopment activities in the area will be suspended. The construction company will
immediately notify S&ME and the PD.
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EMP Version 2, June 2018

S&ME will assess the area, evaluate the waste materials and/or impacted media in the area, if
present, and determine the proper means for managing these materials.
Within 24 hours, S&ME will inform NCBP of the findings and subsequent actions to be taken
for managing these materials.
If a UST is uncovered, confirmatory samples will be collected from the tank basin, four
sidewalls, and along any associated product lines not to exceed 10-foot intervals. Samples
collected from the newly discovered contaminant source area(s) will be submitted to a North
Carolina certified laboratory for analysis. Analytical methods to be employed for these samples
may include one or more of the following: VOCs, by Method 8260; SVOCs, by Method 8270;
VPH by MADEP; EPH by MADEP; RCRA Metals, by Methods 6010/7471; Pesticides, by Method
8081; Herbicides, by Method 8151; Polychlorinated biphenyls (PCBs), by Method 8082;
Corrosivity, by Method 1110A; Reactivity, by Method 9012; and/or, Flashpoint, by Method
1010.
An environmental waste management company will be contracted for removal of contents of
the UST, and to clean up any hazardous substances that may have been released.
Redevelopment activities will not resume until after released hazardous substances have been
removed, and any explosive or dangerous atmospheric conditions have been mitigated.
Sub -Grade Feature/Pit:
* If previously undiscovered buried features or pits are encountered, invasive activities in the area
will be suspended.
* The construction company shall immediately notify S&ME and the PD.
* S&ME will assess the area and if impacted media is present, S&ME will direct management of the
impacted media in the same manner as described above for Underground Storage Tanks.
* Within 24 hours, S&ME will inform NCBP of the findings and subsequent actions taken for
managing these materials.
* If field screening of excavated soils indicates the presence of significant contamination, the
suspected contaminated soil will be stockpiled as shown in the attached Figure 1.
* A soil sampling plan will be developed, for the excavated soils, in coordination with the NCBP
Project Manager, considering the final disposal plans for the excavated soil (e.g., on -site or off -site)
and generally following the IHSB Guidelines for Assessment and Cleanup of Contaminated Sites,
January 2020 (or most recent version).
Buried Waste Material:
* If buried waste material is encountered, invasive activities in the area will be suspended.
* The construction company shall immediately notify S&ME and the PD.
* S&ME will assess the area and if impacted media is present, S&ME will direct management of the
impacted media in the same manner as described above for Underground Storage Tanks.
* Within 24 hours, S&ME will notify the NCBP of the findings and subsequent actions taken for
managing these materials.
Re -Use of Impacted Soils On -Site:
Arsenic is the only constituent which has been detected above its respective PSRG. Arsenic is
22
EMP Version 2, June 2018

naturally occurring in this area of North Carolina at concentrations that exceed its PSRG. On -site
soil impacted with arsenic may be re -used on -site without any restrictions. Various anthropogenic
constituents were detected in the on -site soil below their respective PSRGs. These soils may also be
re -used on -site without any restrictions. If other previously unidentified, impacted soil is identified
on -site, the impacted soils will only be re -used onsite following approval by the NCBP Project
Manager.
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:
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 Date is unknow at this time. PD will provide date when
known.
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;
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).
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EMP Version 2, June 2018

❑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.
24
EMP Version 2, June 2018

APPROVAL SIGNATURES
Brownfields Project Number: 22061-18-092
Brownfields Project Name. NCDOT-CC Mangum-US64E
rospe i Developer: Rogers Lane Partners, LLC
Printed ame/Title/Company: Wayne Hightower /President
Date C_i€r_:1 _'I E.a , ,, w(ei o (1x�.
Consultant: S&ME, Inc. Date 5/26/2021
Printed Name/Title/Company: Sam Watts, PG/Senior Project Mgr
Brownfields Project Manager:Brad Atkinson
25
EMP Version 2, June 2018
6/8/2021
Date .

Environmental Management Plan (EMP) for Site Development
Brownfields Project Name: NCDOT-CC Mangum-US64E
Brownfields Project No. 22061-18-092
FIGURES
S&ME Project No. 4305-18-216A
May 26, 2021

Figure 1
NCBP Diagram for Temporary
Containment of Impacted or Potentially
Impacted Soil
Cross -Section View
Top Plastic Cover Sheeting: Underliner: 1 layer, minimum of 10
(1 Layer, minimum: 10 mil thick) mil thick plastic
Berm
(Straw bales, Weight
composted earth, etc.) (If plastic
cover used)
Land Contaminated Soils
Surface
\ x
Map View
Straw Bale Berm
Weight
O
f
■ L Contaminated Soils { ■
u
■
o Plastic
Sheeting
Note: Adapted from NC DEQ UST Section "Guidelines for Ex Situ Petroleum Contaminated Soil Remediation" dated December, 1, 2013
26
EMP Version 2, June 2018

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Q Sediment Sample CAROLINA, PRELIMINARY SITE MAP DATED 9/2/2020. THIS MAP IS FOR INFORMATIONAL >��'.�
' PURPOSES ONLY. ALL FEATURE LOCATIONS DISPLAYED ARE APPROXIMATED. THEY ARE =
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• NOT BASED ON CIVIL SURVEY INFORMATION, UNLESS STATED OTHERWISE.
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Contaminant
Sample
Location
Date of
Sampling
Concentration
Exceeding Standard
2L Standard
(µg(L)
1,1-dichlorcethene
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3/28/1990
33
7
1,2-dichlorcethane
S&MEMW-1
3/28/1990
19
0.4
trichloroethylene
S&MEMW-1
3/28/1990
780
3
S&ME MW-3
10/18/1999
80
S&ME MW-4
6/23/1997
6
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6/5/2001
22
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10/20/1999
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6/8/2001
64
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4/28/2005
4.7
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4/29/2005
64
CLP MW 5
4/29/2005
4.2
CLP MW-8
4/28/2005
63
CLP MW-12
4/29/2005
7
CLPMW-13
4/28/2005
16
WSW-T
4/29/2005
5.3
tetrachloroeth lene
S&MEMW-1
7/8/2003
1.2
0.7
chromium
S&MEMW-9
9/21/2004
45.5
10
Soil Gas
Contaminant
Sample
Location
Date of
Sampling
Concentration
Exceeding SGSL
( ms)
Residential
a
SGSL (µghn)
1,3-butadiene
SG-4
10/15/2019
34
14
SG-5
31
sG6
16
SG-724
SG9
23
SG-10
40
SG-13
15
SG14
18
Sediment
Contaminant
azsenic
Sample
Location
SED-1
Date of
Sampling
10/7/2019
Concentration
Exceeding PSRG
/r�
(mg/Kg)
3.6
Residential
PSRG (mg/Kg)
0.68
SED-2
1.9
SED 3
0.95
Soil Contaminant
Sample
Location
Date of
Sampling
Concentration
Exceeding PSRG
(mgg)
Residential
PSRG (mg/Kg)V
arsenic
SS-1
10/15/2019
1.9
0.68
SS-2
1.4
SS-3
2.3
33-4
1.2
SS-5
1
SS-6
1
Oil and Grease
SW-1
10/27/2004
310
250*
SW-2
380
SW-3
250
SW-5
270
SW-6
320
SW-7
400
SW-8
450
SW-11
390
SCALE:
1 300 '
' =
SW-13
850
29
FL-2
0
DATE:
4-15-21
FL-4
250
FL-5
1,300
FL-6
3,300
PROJECT NUMBER
4305-18-216A
FL-8
4,800
FL-9
270
FL-10
280
FIGURE NO.
Total Petroleum
Hydrocazbons-Diesel
FL-5
10/27/2004
220
100*
FL-8
3,800
"UST Section Action Lewl

Concentration
Groundwater Sample Date of 2L Standard
Exceeding Standard
Contaminant Location Sampling (11gL)
U
o (JAgIL)
s,Dr
etlaq
SW-1 -(�-SW-11 3 1,1-dichloroethene SWE MW-1 3/28/1990 33 7
L ti OE 1,2-dichloroethane SWE MW-1 3/28/1990 19 0.4
r
1 -rl ' SWE MW-1 3/28/1990 780
T.;Lrr (D FIL
`Z
FL-2 SWE MW-3 10/18/1999 80
FL-4
SG-7 SW-2 -(:j> @ SW-1.1- SWE MW-4 6/23/1997 6
.7 0 L T 7 1.1.� '�L'
S&ME MW-10 6/5/2001 22
7 ZA,
I e i g 13713-e5�c FL
FL-8 S&ME MW-11 10/20/1999 4.8
SW-3 V
S&ME MW-12 6/8/2001 64
--------- -�;I % trichloroethylene CLP MW-2 4/28/2005 4.7 3
-6 eavwi jp'.P. SCM FT
FL-6 FC:9,'
CLP MW-3 4/29/2005 64
SW-4 (D
CLP MW-5 4/29/2005 4.2
FrI
CLP MW-8 4/28/2005 63
Y" F7,1 0 -
ol
1A 4 -60
- , :: —4. -� 5 CLP MW-12 4/29/2005 7
SW
e
CLP MW-13 4/28/2005 16
U
S 6 Sw-7 WSW-T 4/29/2005 5.3
W-
0.7
tetrachloroethylene S&ME MW-1 7/8/2003 1.2
"A0 chromium S&ME MW-9 9/21/2004 45.5 10
ssis".
—14
h/ Concentration
Soil Gas Sample Date of Residential
fr s iri h r f ss ��t I" ' r 4 ^y -a• LEIExceeding SGSL
Contaminant Location Sampling SGSL (Rg/I
Q; 9
55-3 If /fMAI w/I
S -s 4
SG-4 34
SS-4
e;
S&ME MW-9
— ... 6F . % SC-5 31
SG-6 16
A,
24
4
1,3-butadiene 10/15/2019 14
-X
SG-9 23
S -10 IG 40
;rI 4. CILP MW-5 4s&MF'MW 4. M K E.. SG-13 15
SG-14 18
S�' 1 r ):CLP M.
-'ni :M Prop. SCM Concentration
Y W-jj ClLiO
�ED-2
• a -SE 3i. Sediment Sample Date of Residential
Contaminant Location Sampling Exceeding PSRG PSRG (mg/Kg)
USG-. �ED-11
EX SCM &ME MW- (-g/Kg)
S, SED-1 3.6
ff S EMW 12
arsenic SED-2 10/7/2019 1.9 0.68
SG-13 -�X SED-3 0.95
:]SEE INSET, TO
P RIGHJTZ,,
'171 L 71
A
Concentration
ey
A-
SRG (mgtKg)
Soil Contantin
Sample Date of Residential
ILL.-
-rr-1 IT 1 11 Exceeding PSRG
'r5. ant Location amplin S P
(mg/Kg)
9
*z
ff
SG,10I,---z� r SS-1 1.9
SS-2 1.4
7
C? SS-3 2.3
arsenic 10/15/2019 0.68
33-4 1.2
N Prop SCM SS-5
."z/ ti Ilk "e $S-6 1
F;
-1 310
T. 2 'T 11� SW-2 380
L SW-1
F
SW-3 250
;ti0
Ij
LL
SW-5 270
4,
Z SW-6 320
SW-7 400
IllIlk
SW-8 450
390
d
W-1 371 SW_ 11.
SW-1 1
Oil and Grease SW-13 10/27/2004 850 250*
FLA 290
Sample Locations 0 Proposed Residential Structures FL-2 300
Monitor Well Proposed Commercial Structures 0 300 600 FL-4 FL-5 1,3250
I.00
Water Supply Well (FEET) FL-6 3,300
1 (D Soil Boring Construction Phase -8 4800
Passive Soil Gas Sampling Location
Sediment Sample
Surface Water Sample
FL-9 270
FL-10 280
Total Petroleum FL-5 10/27/2004 220 100*
Hydrocarbons - Diesel, FL-8 3,800
*UST Section Action Level
R
00
I? <
00 z
_j
0
ko
0
r\j
U
LU
0 z
<
—j 0
V) Z
—j LU
LU 0
LL. 0 z
z ::)
0
U
0oC LU
0
Z
3f
L<L. (D
V) LU
Of —i
LU <
0 Of
OfOf
SCALE:
1 = 300
DATE:
4-15-21
PROJECT NUMBER
4305-18-216A
FIGURE NO
4

=0
Environmental Management Plan (EMP) for Site Development
Brownfields Project Name: NCDOT-CC Mangum-US64E
Brownfields Project No. 22061-18-092
APPENDIX I
S&ME Project No. 4305-18-216A
Amendments to Brownfields Environmental Management Plan
May 26, 2021 4

Environmental Management Plan (EMP) for Site Development
Brownfields Project Name: NCDOT-CC Mangum-US64E
Brownfields Project No. 22061-18-092
S&ME Project No. 4305-18-216A
-_19:2 4►1DJK:,1LTA 14►17LTA 14Zk&1kt0l1:T01TAi!Ia144�724zLTJI:Z81ZIiTi14►►L14LTA /_1►/_[cl4 LTA14 1!k29W_1►�
Amendments must have the concurrence of both the Prospective Developer (Anthony Property Group) and the North
Carolina Brownfields Program prior to implementation of each amendment.
AMENDMENT EFFECTIVE SUBJECT
NUMBER DATE
May 26, 2021

Environmental Management Plan (EMP) for Site Development
r Brownfields Project Name: NCDOT-CC Mangum-US64E
III Brownfields Project No. 22061-18-092
S&ME Project No. 4305-18-216A
APPENDIX II
Summary of Soil Gas Analytical Results and Figure - December 2019
May 26, 2021

s © Table 5
Summary of Soil Gas Analytical Data
f I I Rogers Farm (BF ID No. 22061-18-082)
fRaleigh, Wake County, North Carolina
S&ME Project No. 4305-18-216A
Analytical Method
Volatile Organic Compounds by EPA TO-15 (µ ims)
Analyte
?L
m
�
e
e
Sample ID
Date Collected
v"
m
V
0
N
m
L
SG-4
10/15/2019
59
33
34
11 J
4.3 J
<1.3
4.7
7.9 J
15
12
11
31
<0.82
<20
<6.9
66
2.5 Z-01
400
12
<1.4
180
<1.1
<11
<4.5
13
3.8
62
SG-5
10/15/2019
130
17
31
22 J
<6.2
<1.3
<0.98
<15
17
16
14
<28
<0.82
20
<6.9
67
<1
210
<0.85
0.9 J
250
<1.5
<l.l
<4.5
17
5.3
84
SG-6
10/15/2019
45
16
16
12 J
<6.2
0.45 J
<0.98
<15
11
8.8
13
<28
<0.82
<20
<6.9
82
1.6 Z-Ol
<14
1.9
<1.4
170
<l.l
<l.l
<4.5
6.2
2.5
51
SG-7
10/15/2019
160
29
24
51
<6.2
<1.3
<0.98
<15
2.9
<0.98
<0.82
<28
<0.82
<20
<6.9
59
1.9 Z-01
600
<0.85
<1.4
12
<1.1
<11
<4.5
2.3
<0.98
3.8
SG-8
10/15/2019
57
4.1
<0.44
2.7
<28
5.3 V-05
<20
<6.9
14 J
<6.2
<1.3
<0.98
<15
<0.87
<0.98
12
<1
<14
<0.85
2.4
6.2
1.3
<l.l
<4.5
1.2
<0.98
2.3
SG-9
10/15/2019
58
5.4
23
2.7
<28
6.6 V-05
3.8 J
0.99 J
11 J
<6.2
<1.3
<0.98
<15
<0.87
<0.98
10
1.3 Z-01
<14
1.4
1.8
11
<1.1
1.3
1.3 J
2.2
<0.98
5.7
SG-9 DUP
10/15/2019
59
5.9
25
3
<28
6.7 V-05
4.2 J
<6.9
11 J
<6.2
<1.3
<0.98
<15
<0.87
<0.98
13
1.8 Z-01
160
1.5
1.7
12
1 <1.1
<1.1
1.3 J
<0.98
<0.98
6.5
SG-10
10/15/2019
160
12
40
26
<6.2
<1.3
<0.98
<15
<0.87
<0.98
9
<28
<0.82
6.4 J
<6.9
13
1.3 Z-01
390
4.6
<1.4
14
<1.1
<l.l
1 1.2 J
4.4
<0.98
<2.57
SC-11
10/15/2019
54
4.3
<0.44
1.9
<28
6.5 V-05
<20
<6.9
8 J
<6.2
<1.3
1.5
9.8 J
<0.87
<0.98
8
<1
<14
2.4
0.98 J
3.7
<1.1
<1.1
1.4 J
<0.98
<0.98
2
SG-12
10/15/2019
140
2.4
<0.44
29
<6.2
0.45 J
<0.98
38
1.1
<0.98
1.7
<28
<0.82
9.2 J
<6.9
14
<1
<14
<0.85
0.87 J
4.1
<1.1
<1.1
1.4 J
<0.98
<0.98
4.5
SG-13
10/15/2019
180
6.7
15
40
12
<1.3
<0.98
35
2.2
<0.98
<0.82
<28
<0.82
17 J
<6.9
13
<1
170
<0.85
<1.4
9.7
<1.1
2.8
4.2 J
1.8
<0.98
7.3
SG-14
10/15/2019
120
6.8
18
21 J
<6.2
<1.3
<0.98
13 J
<0.87
<0.98
4.7
<28
<0.82
6.5 J
<6.9
8
<1
<14
<0.85
3.1
7.2
<1.1
<1.1
<4.5
2.2
<14
72.57
SG-15
10/15/2019
87
12
<0.44
21 J
<6.2
<1.3
<0.98
11 J
2.8
3.8
4.6
128
<0.82
2.8 J
16.9
18
2.9 Z-01
<14
3
<1.4
13
<1.1
<1.1
<4.5
5
1.3
11.9
SG-16
10/15/2019
25
1.5
<0.44
4.9 J
<6.2
<1.3
<0.98
<15
<0.87
<0.98
0.66 J
<28
<20
<20
<6.9
100
2.1 Z-01
<14
<0.85
5.2
2.3
<1.1
<11
1.4 J
<0.98
<0.98
1.3 J
Residential SGSL
220'000
120
14
35,000
4,900
160
41
NE
370
NE
2,800
4,900
210
1'400
4,200
21,000
21
3,130"
7,000
280
35,000
35,000
14
NE
420
420
700
Non -Residential SGSL
2,700,000
1 1,600
1 180
1 440,0001
61,000
1 2,000
1 530
1 NE
1 4,900
1 NE
1 35,000
1 61,000
1 2,600
1 18,000
1 53,000
260,000
260
13,10V
88,000
3,500
440,000
1,700
180
NE
5,300
5,300
8,800
Notes:
Soil gas samples concentrations are reported in µg/m3.
pg/m' - micrograms per cubic meter
SGSL - Soil Gas Screening Levels - Sub Slab & Exterior Division of Waste Management (February 2018).
Concentrations shown in BOLD exceed the laboratory detection limits.
Concentrations shown in BOLD and highlighted fields exceed the Residential Soil Gas Screening Levels.
J - Estimated concentration
V-05 - Continuing calibration verification did not meet method specifications and was biased on the low side.
Z-01 - Compound failed the method requirement recovery, for the LCS. Is classified by the laboratory as difficult compound and passes in teh house limits of 50 -150%.
NE - Screening level not established for the compound and could not be calculated due to lack of volatility or toxicological information.
. - SGSL for propene was calculated using the EPA Vapor Intrusion Screening Level Calculator, which assumed a Toxic Hazard Quotient (THQ) of 1.
Z:18haredZME1Ops1ENVlProjeote12018W305-18-218A Rogers Fan B-afields Gonsuftiig 8erimsMorking_Dawment EMP - Re DeWopmemuQ-20 EMRTables for Addtl Assessment - 10-19.Asx

V '
1; �Z
SG-4 ag/m3 SS-6 10
4
= • SS 5'�
1,3-BUTADIENE 34
m ,�
0* _
1,3-BUTADIENE 31 �O� , :.'•
SS 4/SG-5 SG=a6. . •+
o MW-9
ra, , SG-6 �9/m3
'�' 1,3-BUTADIENE 16 4y SG-9 Pg/m3
f s:
i= EE_ � � '
r t:- y �. 1,3-BUTADIENE 23
yto SG-9-DUP W9/m3
"1
4 4"' z• ,► • SG 1b ,'`" 1,3-BUTADIENE 25
iTk
Wg3
13 BUTADIENE 24
�FGL SG-7
F • ,ByI
ti. !►
C SG-10 Ig/m3
" ' 1,3-BUTADIENE 40
w ♦ SG-10
/Qo o f IV
ON
R >!z
i.
ONLY CONSTITUENTS WHICH EXCEED THEIR RESPECTIVE REGULATORY STANDARDS ARE SHOWN.
MICROGRAMS PER CUBIC METER.
ARSENIC WAS DETECTED IN SOIL AND SEDIMENT SAMPLES EXCEEDING THE REGULATORY STANDARD s
AT CONCENTRATIONS SIMILAR TO BACKGROUND LEVELS.
r
Y REFERENCE:
a GIS BASE LAYERS WERE OBTAINED FROM 2017 NCONEMAP.COM ORTHOIMAGERY BASE LAYER. THIS
± MAP IS FOR INFORMATIONAL PURPOSES ONLY. ALL FEATURE LOCATIONS DISPLAYED ARE
APPROXIMATED. THEY ARE NOT BASED ON CIVIL SURVEY INFORMATION, UNLESS STATED 0 2OO 400 r �r
6 •
OTHERWISE. (FEET)
j
•
JV-IV 4.11{/I
1,3-BUTADIENE 18
",
1,3-BUTADIENE 15
"I. W.,
N
00
O Q
Co O
o Q
N U
LU
O Q re
pV)O
� w
w 0 z
z O
0 w
m O �
z <
LL l7
N w
J
w <
O
af
SCALE:
TCE Contour (1999)
1 " = 200 '
Groundwater Sample (MW) Collected 10/7/2019
DATE:
11-7-19
�w
Soil Gas (SG) Collected 10/14/2019 and 10/15/2019
PROJECT NUMBER
Soil Sample (SS) Collected 10/15/2019
4305-18-216A
_-•.
Sediment Sample (SED) Collected 10/7/2019
FIGURE NO.
® Surface Water (SW) and Sediment Sample (SED) Collected 10/7/2019
3
4 °
Q Subject Parcel Boundary