26093_Dynamic Auto II_Foundry_Final EMP_01122024 no app

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EMP Version 3, March 2023
I. NORTH CAROLINA BROWNFIELDS REDEVELOPMENT SECTION
II. ENVIRONMENTAL MANAGEMENT PLAN

This form is to be used to prepare an Environmental Management Plan (EMP) for projects in
the North Carolina Brownfields Redevelopment Section at the direction of a Brownfields
project manager.

The EMP is a standard requirement of a Brownfields Agreement (BFA). Its purpose is to clarify
actions to be taken during 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 EMP to be valid for use, it must be
completed, reviewed by the Section, 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 recorded agreement, be cause for
a reopener.

The EMP is valid only for the scope of work described herein and must be updated to be
applicable for new phases of redevelopment or after significant changes in applicable
regulatory guidance. Risk characterization of a Brownfields Property to DEQ’s written
satisfaction is required prior to EMP approval.

Voluntary Metrics Tab The NC Brownfields Redevelopment Section updates estimated capital investment (from the Brownfields Property Application) and estimated jobs created (from the Brownfields Agreement) whenever possible. As a voluntary measure, you may opt to complete the below information for capital investment and jobs created as estimated by your final redevelopment
plans for the Brownfields Property:
1. Estimated capital investment in redevelopment project: $174 million
2. Estimated jobs created:
a. Construction Jobs: 1,000
b. Full Time Post-Redevelopment Jobs: 200

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III. Table of Contents
NORTH CAROLINA BROWNFIELDS REDEVELOPMENT SECTION .................................................................. 1
ENVIRONMENTAL MANAGEMENT PLAN .................................................................................................... 1
GENERAL INFORMATION ........................................................................................................................ 4
COMMUNICATIONS ................................................................................................................................ 4
NOTIFICATIONS TO THE BROWNFIELDS REDEVELOPMENT SECTION ..................................................... 5
REDEVELOPMENT PLANS ........................................................................................................................ 6
CONTAMINATED MEDIA ......................................................................................................................... 8
PART 1. SOIL ........................................................................................................................................ 8
PART 2. GROUNDWATER .................................................................................................................. 22
PART 3. SURFACE WATER .................................................................................................................. 24
PART 4. SEDIMENT ............................................................................................................................ 25
PART 5. SOIL VAPOR ......................................................................................................................... 25
PART 6. INDOOR AIR ......................................................................................................................... 26
VAPOR INTRUSION MITIGATION SYSTEM ............................................................................................. 27
CONTINGENCY PLAN ............................................................................................................................. 28
POST-REDEVELOPMENT REPORTING..................................................................................................... 30
APPROVAL SIGNATURES ....................................................................................................................... 31

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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 all of the following is premature and may
be returned without comment.

☒ 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.

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. (Att. 1.0)

☒ A figure overlaying redevelopment plans on a map of the extent of contamination for
each media. (Att. 2.0, 2.1, 2.3, 2.4, 2.5, and 2.6)

☒ Site grading plans that include a cut and fill analysis. (Att. 3.0 and 3.1)

☐ A figure showing the proposed location and depth of impacted soil that would remain
onsite after construction grading.

☒ Any necessary permits for redevelopment (i.e. demolition, etc.). (Att. 4.0)

☒ A detailed construction schedule that includes timing and phases of construction. (Att.
5.0)

☒ Tabulated data summaries for each impacted media (i.e. soil, groundwater, soil gas,
etc.) applicable to the proposed redevelopment. (Att. 2.2, 6.0, 6.1, 6.2, 6.3, 6.4, and 7.0)

☒ Figures with the sampling locations and contamination extents for each impacted media
applicable to the proposed redevelopment. (Att. 2.0, 2.1, 2.3, 2.4, 2.5, and 2.6)

☐ 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,

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detailing the type of material proposed for import 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 Redevelopment Section
Guidelines.

☒ A map of the Brownfields Property showing the location of soils proposed for export
and sampling data from those areas. (Att. 2.0, 2.2, and 6.0)

☒ If a Vapor Intrusion Mitigation System (VIMS) is required by the Brownfields
Redevelopment Section, the VIMS plan will be signed and sealed by a NC Professional
Engineer. The VIMS Plan may also be submitted under separate cover.

GENERAL INFORMATION

Date: 10/16/2023 Revision Date (if applicable): 12/21/2023

Brownfields Assigned Project Name: Dynamic Auto Works II (primary redevelopment) and Foundry

Brownfields Project Number: 26093-22-060 (primary redevelopment) and 17021-13-060

Brownfields Property Address: 600 Eldridge Street, Charlotte, NC 28202, a portion of Parcel 07318201,
and “Stonewall Alley” (primary redevelopment) and Foundry (619 & 623 S Cedar Street)

Brownfields Property Area (acres): The Dynamic Auto Works II property is approximately 1.5 acres
and the proposed development is anticipated to disturb approximately 0.9 acres. The Foundry
property is an adjoining parcel of approximately 3.5 acres and the Dynamic Auto Works II
development is anticipated to encroach on approximately 1.6 acres. The redevelopment will span
both properties. Combined, this EMP has been prepared for both Dynamic Auto Works II and Foundry
properties. A site map is provided in Attachment 2.0.
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 in an area that is prominently accessible to site workers. NOTE, THE EMP DOES NOT TAKE THE PLACE OF A SITE-SPECIFIC
HEALTH AND SAFETY PLAN.
Prospective Developer (PD): AP Foundry, LP

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Contact Person: Welch Liles
Phone Numbers: Office: 704-423-1660 Mobile: Click or tap here to enter text.
Email: [e-mail]

Contractor for PD: Mill Creek Residential
Contact Person: Justin Houston
Phone Numbers: Office: 704-565-0835 Mobile: Click or tap here to enter text.
Email: [e-mail]

Environmental Consultant: ONE Environmental Group of Carolina, PLLC
Contact Person: Jenny Tang
Phone Numbers: Office: 301-787-2690 Mobile: Click or tap here to enter text.
Email: [e-mail]
Brownfields Redevelopment Section Project Manager: Carolyn Minnich
Phone Numbers: Office: 704-661-0330 Mobile: Click or tap here to enter text.
Email: [e-mail]

Other DEQ Program Contacts (if applicable, i.e., UST Section, Inactive Hazardous Site Branch,
Hazardous Waste, Solid Waste):
Click or tap here to enter text.

NOTIFICATIONS TO THE BROWNFIELDS REDEVELOPMENT SECTION

Written advance Notification Times to Brownfields project manager: Check each box to accept minimum advance notice periods (in calendar days) for each type of onsite task:

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 ☒

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REDEVELOPMENT PLANS

1) Type of Redevelopment (check all that apply):
☒Residential ☐Townhomes (Prior written DEQ approval REQUIRED regardless of ownership
structure) ☐Recreational ☐Institutional ☒Commercial ☐Office ☒Retail ☐Industrial
☐Other specify:
Proposed redevelopment plans include razing a portion of the existing site buildings and
constructing a new multi-tenant commercial retail building with an associated parking deck and
high-density residences above. The redevelopment plans are provided as Attachment 1.0. The
structures located at 623 S Cedar Street and 600 Eldridge Street will be demolished. The
structures located at 601 and 619 S Cedar Street will continue to be used in their present state.

The redevelopment will include a ground-level 2-story commercial retail space, located plan
west, with 3 stories of residential apartments above. Adjoining this structure due plan south will
be a ground-level 2-story space to include a leasing office, clubhouse, residential lobby, storage,
mechanical/utility rooms, commercial retail space, and retail lobby. Residential apartments and
portions of the parking deck will be located on levels 3-5 above the retail space and residential
amenity areas. A 5-story parking deck will be a part of this structure located along the plan south
of the redevelopment. Two (2) additional multi-family residential buildings will begin on level 6,
constructed above the parking deck & retail/amenity space (levels 1-2), and residential space
(levels 3-5).

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:
A copy of the most recent redevelopment plans is included in Attachment 1.0. Copies of the cut-
fill analysis and grading plan are included in Attachments 3.0 and 3.1. Redevelopment plans
include razing a portion of the existing site buildings and constructing a new multi-tenant
commercial retail building with an associated parking deck and high-density residences above.
The structures located at 623 S Cedar Street and 600 Eldridge Street will be demolished. The
structures located at 601 and 619 S Cedar Street will continue to be used in their present state.
Redevelopment activities also include the construction of access drives and landscaped areas.

The building located along plan west of the redevelopment consists of a ground-level 2-story

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commercial retail space. Soil from zones EX-0 through EX-2 will be excavated to construct the
foundations of this structure. Multi-family residential will start on level 3 and extend up to level
5. All ground contact space is two stories in height. A cumulative total of 20,000 sq ft of
occupiable space is located on the ground floor. The space will consist of open retail space and
service corridors.

An open-air, mechanically vented parking deck is located along the plan south of the
redevelopment. Adjoining the parking deck will be a cumulative 18,800 sq ft of occupiable space
on the ground floor located along the plan north of the parking deck. Soil from zones EX-3
through EX-13 will be excavated to construct the foundations of this structure. The occupiable
space will consist of a leasing office, clubhouse, residential lobby, storage, mechanical/utility
rooms, commercial retail space, and retail lobby. All ground contact space is two stories in
height. Residential units and portions of the parking deck will be located on levels 3-5 above the
retail space and residential amenity areas. Two (2) additional buildings will begin on level 6,
constructed above the parking deck & retail/amenity space (levels 1-2), and residential space
(levels 3-5). The space will consist of multi-family residential.

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?
S&EC requirements can be found at: https://deq.nc.gov/about/divisions/energy-mineral-and-land-
resources/erosion-and-sediment-control/erosion-and-sediment-control-laws-and-rules
☒ Yes ☐ No ☐ Unknown
☒ If yes, please check here to confirm that earth-work 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: 1/1/2024

b) Anticipated duration (specify activities during each phase):

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Site work and demolition of the existing site buildings are projected to begin in January 2024.
The redevelopment is expected to be completed and structures occupied in November 2026.
A copy of the preliminary construction schedule is provided in Attachment 5.0.

c) Additional phases planned? ☐ Yes ☒ No

If yes, specify the start date and/or activities if known:
Start Date: Click or tap to enter a date.
Planned Activity:
Click or tap here to enter text.

Start Date: Click or tap to enter a date.
Planned Activity:
Click or tap here 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: 11/1/2026

CONTAMINATED MEDIA
Please fill out the sections 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) Contaminated Media on the Brownfields Property
Part 1. Soil: ☒ Yes ☐ No ☐ Suspected ☐ Unknown
Part 2. Groundwater: .................................... ☒ Yes ☐ No ☐ Suspected ☐ Unknown
Part 3. Surface Water: ☐ Yes ☒ No ☐ Suspected ☐ Unknown ☐ N/A
Part 4. Sediment: .......................................... ☐ Yes ☒ No ☐ Suspected ☐ Unknown ☐ N/A
Part 5. Soil Vapor: ......................................... ☒ Yes ☐ No ☐ Suspected ☐ Unknown
Part 6. Sub-Slab Soil Vapor: .......................... ☒ Yes ☐ No ☐ Suspected ☐ Unknown
Part 7. Indoor Air: ......................................... ☐ Yes ☐ No ☐ Suspected ☒ Unknown

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
1) Known or suspected contaminants in soil (list general groups of contaminants):
ONE conducted soil assessment activities in April 2023 to characterize site soils and to

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determine proper soil disposal procedures before grading activities begin. ONE divided the site
into fourteen (14) in situ soil characterization sections (EX-0 through EX-13) based on the
proposed excavation depths and anticipated bedrock. In each soil characterization section, a set
of three (3) (A through C) or five (5) (A through E) soil borings were advanced to pre-determined
excavation depths or until drill rig refusal. Additionally, two (2) soil borings (SB-1 and SB-2) were
advanced to a depth of approximately 2 ft bgs in the interior and exterior of the former Dynamic
Auto Works building to evaluate for shallow impacts by the former auto repair facility. In total,
53 soil samples were submitted for laboratory analysis. In situ soil characterization sections EX-
0, EX-1, EX-2, EX-3, EX-9, and EX-10 were located on the Foundry property. All other in situ soil
characterization sections were located on the Dynamic Auto Works II property. A Sample
Location Map is included in Attachment 2.0. It should be noted that excavation zone EX-0 is
depicted on the sample location map; however, no soil samples were collected based on the
available soil analytical data from 2013 as further discussed below.

Soil analytical results were compared to the North Carolina Department of Environmental
Quality (NCDEQ) Preliminary Soil Remediation Goals (PSRGs) and Protection of Groundwater
(POG) standards dated January 2023. Additionally, metal concentrations were compared to The
Rule of 20 Values derived from the United States Environmental Protection Agency (USEPA)
Toxicity Characteristic Leaching Procedure (TCLP) Maximum Concentration of Contaminants for
Toxicity Characteristic, dated November 2004, metals concentrations of Tarmac Virginia
Brownfields Property (Tarmac Virginia) (Brownfields Project No. 26067-22-060), and background
ranges established for Old 27 Land Clearing and Inert Debris (LCID) and Griffin Farms LCID
landfills to assist in off-site disposal. A tabular summary of the soil sample analytical data is
included in Attachment 6.0. Soil sample locations and characterization sections are included in
Attachment 2.0. A summary of the soil assessment results is provided below:

Volatile Organic Compounds (VOCs)
Laboratory analytical results reported low detections of VOCs across the site and at estimated
laboratory values denoted by a “J”. All detections were below Residential and POG PSRGs. It
should be noted that acetone was detected in all samples; however, is a common laboratory
contaminant and not a constituent of concern at the site.

Semi-Volatile Organic Compounds (SVOCs)
Laboratory analytical results reported low detections of SVOCs across the site,
predominantly in the shallow 0-2’ intervals and at estimated laboratory values denoted by a “J”.
Benzo(a)pyrene was detected in zones EX-8, EX-9, EX-10, and EX-11 at concentrations up to
0.612 milligrams per kilogram (mg/kg) which exceeds the Residential PSRG of 0.11 mg/kg and the
Protection of Groundwater (POG) PSRG of 0.12 mg/kg. Detections of 1-methylnaphthalene and
naphthalene were also reported above the POG PSRG in zone EX-8 with concentrations of 0.419
mg/kg and 0.489 mg/kg, respectively. Benzo(a)anthracene was detected in zone EX-10 at 0.578
mg/kg which is above the POG PSRG of 0.35 mg/kg. No other volatile compounds were detected
above a screening criterion.

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Environmental Assessments & Consulting, Inc. (EAC) conducted soil assessment activities in April
2013. Soil sample GP-2 was collected within the footprint of the newly proposed development
and is denoted by a pink-colored circle in zone EX-0 of Attachment 2.0. A historical sample
location map is included in Attachment 2.1 for reference. Petroleum compounds were detected
in the soil sample at estimated laboratory values denoted by a “J”. A tabular summary of
historical soil sample analytical data is included in Attachment 6.1. Benzo(a)anthracene was
detected at concentrations up to 3.2 mg/kg, which exceeds the POG PSRG and Residential PSRG
of 0.35 mg/kg and 1.1 mg/kg, respectively. Benzo(b)fluoranthene was detected at
concentrations up to 5.1 mg/kg, which exceeds the POG PSRG and Residential PSRG of 1.2 mg/kg
and 1.1 mg/kg, respectively. Indeno(123-cd)pyrene was detected at concentrations up to 3.6
mg/kg, which exceeds the Residential PSRG of 1.1 mg/kg. No other volatile compounds were
detected above a screening criterion.

Metals
RCRA metals arsenic, chromium, hexavalent chromium, mercury, and selenium were detected at
concentrations ranging above the POG, Residential, and/or Industrial/Commercial PSRGs.
- Arsenic was detected in all samples collected at the site. 36 samples reported
concentrations above the Residential PSRG of 0.68 mg/kg. Seven (7) samples reported
concentrations above the Industrial/Commercial PSRG of 3.0 mg/kg. One (1) sample
reported a concentration above the POG PSRG of 5.8 mg/kg. Concentrations ranged
between 0.326 mg/kg to 21.7 mg/kg which is consistent with published background
concentrations of the area and did not warrant additional TCLP analysis.
- Mercury was detected sporadically across the site in 28 samples. Two (2) samples
reported concentrations above the Residential PSRG of 2.3 mg/kg and POG PSRG of 1.0
mg/kg in zones EX-5 and EX-11. Most mercury detections at the site ranged between
0.0286 mg/kg to 0.145 mg/kg which is consistent with the published background
concentrations of the area. Eight (8) samples reported concentrations that were above
background concentrations ranging from 0.207 mg/kg to 2.79 mg/kg. The mercury
concentrations did not warrant additional TCLP analysis.
- Selenium was detected in all samples collected at the site. Two (2) samples from zones
EX-2 and EX-4 reported concentrations above the POG PSRG of 2.1 mg/kg. Most
selenium detections at the site ranged between 0.259 mg/kg to 1.61 mg/kg which is
consistent with the published background concentrations of the area. One (1) sample
reported a concentration that was above background concentrations at 5.4 mg/kg.
Additional TCLP analysis was not warranted.
- Hexavalent chromium was detected sporadically across the site in 21 samples. One (1)
sample in zone EX-2 reported a concentration above the POG PSRG of 3.8 mg/kg.
Hexavalent chromium concentrations detected at the site ranged between 0.211 mg/kg
to 3.95 mg/kg.
- Total chromium was detected in all samples collected at the site. Most total chromium
detections at the site ranged between 4.54 mg/kg to 78.6 mg/kg which is consistent with

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published background concentrations of the area. Three (3) samples reported
concentrations that were above background concentrations in Zone EX-6 and SB-2.
These samples were resubmitted for TCLP analysis and returned with total chromium
concentrations below the TCLP regulatory screening value of 5.0 mg/L.
- Trivalent chromium was calculated to be detected in all samples collected at the site by
subtracting hexavalent chromium from total chromium. Most trivalent chromium
detections at the site ranged between 4.54 mg/kg to 77.5 mg/kg which is consistent with
published background concentrations of the area. Three (3) samples reported
concentrations that were above background concentrations in Zone EX-6 and SB-2.
These samples were resubmitted for TCLP analysis and returned with total chromium
concentrations below the TCLP regulatory screening value of 5.0 mg/L.
- Lead was detected in all samples collected at the site. No concentration exceeded the
PSRGs. Most lead concentrations detected at the site ranged between 2.85 mg/kg to
38.1 mg/kg which is consistent with published background concentrations. Four (4)
samples reported concentrations that were above background concentrations but below
the Rule of 20 Value ranging from 65.5 mg/kg to 99.9 mg/kg. Six (6) samples reported
concentrations that were above background concentrations and the Rule of 20 Value of
100 mg/kg in zones EX-5, EX-8, EX-9, EX-10, and EX-11. These samples were resubmitted
for TCLP analysis and returned with lead concentrations below the TCLP regulatory
screening value of 5.0 mg/L. Through inadvertence, TCLP analysis was not performed for
one (1) sample, EX-9 (0-2’). Considering that the total lead concentration for EX-9 (0-2’)
was 106 mg/kg and only slightly above the Rule of 20 Value of 100 mg/kg, the sample
result was discussed with the laboratory, Brownfields, and Republic. The highest lead
concentration detected at the site was 197 mg/kg with a TCLP analysis result of 0.041
mg/L. Based on the results of the remaining TCLP analyses demonstrating
concentrations significantly below the TCLP regulatory screening level, this sample does
not exhibit a risk of significant hazardous toxicity.
2) Depth of known or suspected contaminants (feet):
The soil assessment activities conducted by EAC in April 2013 detected petroleum compounds in
soil sample GP-2 at depths up to 6 ft bgs. Benzo(a)anthracene and benzo(b)fluoranthene were
detected above the Residential PSRG and POG PSRG. Indeno(123-cd)pyrene was detected above
the Residential PSRG.

During soil assessment activities conducted by ONE in April 2023, benzo(a)pyrene was detected
above the Residential and POG PSRG in four (4) in situ soil characterization sections, EX-8
through EX-11, at depths up to 10 ft bgs.

Benzo(a)anthracene was detected above the POG PSRG in situ soil characterization section EX-10
at 2 to 5 ft bgs.

1-methylnaphthalene and naphthalene were detected above the POG PSRG in situ soil

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characterization section EX-8 at 0 to 2 ft bgs.

RCRA metals were detected above Residential, Industrial/Commercial, and POG PSRGs and
across the site, predominantly in the shallow 0-2’ and 2-5’ intervals. Arsenic, hexavalent
chromium, and selenium were detected above PSRGs at depths up to 20 ft bgs.
3) Area of soil disturbed by redevelopment (square feet):
Approximately 152,000 square feet of soil will be disturbed for clearing and leveling. A copy of
the cut-fill analysis and grading plan are included in Attachment 3.0 and 3.1.

4) Depths of soil to be excavated (feet):
Cut depths range from less than 1 ft bgs to approximately 20 ft bgs. Bedrock is anticipated to be
encountered at depths beyond 20 ft bgs.

5) Estimated volume of soil (cubic yards) to be excavated (attach grading plan):
Based on the grading plans and cut and fill analysis, approximately 51,700 cubic yards of soil will
be excavated from the site during the proposed grading and redevelopment activities
(Attachments 3.0 and 3.1).

6) Estimated volume of excavated soil (cubic yards) anticipated to be impacted by contaminants:
Based on the results of in situ soil characterization assessment activities, approximately 11,050
cubic yards of soil contain compounds reported at concentrations above PSRGs or background
metals concentrations of Old 27 and Griffin Farms.

7) Estimated volume of contaminated soil expected to be disposed of offsite, if applicable:
Soil expected to be disposed of offsite will be transported to the following preapproved sites. If
an alternative receiving site is required, prior DEQ written approval will be obtained.
- Griffin Farms LCID landfill (Griffin Farms) located at 4242 Morgan Mill Road in Unionville,
North Carolina,
- Old 27 LCID landfill (Old 27) located at 120 Tate Street in Mount Holly, North Carolina,
- Tarmac Virginia Brownfields Property (Tarmac Virginia) (Brownfields Project No. 26067-
22-060) located at 3934 Raleigh Street in Charlotte, North Carolina,
- Republic Services RCRA Subtitle D Landfill (Republic) located at 5105 A Morehead Road in
Concord, North Carolina.

Approximately 31,900 cubic yards of soil with compounds within acceptable metals background
ranges will be transported to Griffin Farms, Old 27, Tarmac Virginia, or Republic. Approximately
8,750 cubic yards of soil contain compounds reported at concentrations above the acceptable
metals background range of Griffin Farms. This volume of soil will be transported to Old 27,
Tarmac Virginia, or Republic. Approximately 9,850 cubic yards of soil contain compounds
reported at concentrations above the acceptable metals background range of Griffin Farms and
Old 27. This volume of soil will be transported to Tarmac Virginia or Republic. Approximately
1,200 cubic yards of soil contain SVOC compounds reported at concentrations above the

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Residential PSRG and/or POG PSRG. This volume of soil will be transported to Republic.

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 preliminary data 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).
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 POLICY, THE SOIL MAY NOT BE RE-USED ONSITE 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:
Lead was detected in select samples at concentrations greater than the Rule of
20 value of 100 mg/kg. These samples were resubmitted for TCLP analysis and

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returned with lead concentrations below the TCLP regulatory screening value of
5.0 mg/L. Based on the results of soil assessment activities and TCLP analysis, no
compounds have been identified at characteristically hazardous levels.
d) NOTE: IF SOIL MEETS THE DEFINITION OF A CHARACTERISTIC HAZARDOUS WASTE, THE
SOIL MAY NOT BE RE-USED ONSITE 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)
☐ Site-specific risk-based cleanup level. Please provide details of methods used for
determination/explanation.
Click or tap here to enter text.
Additional comments:
Click 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 onsite 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:
Documented impacted soils will be covered with an impervious surface (asphalt pavement,
sidewalks, buildings, etc.) or covered with a minimum of 2 ft of demonstrably clean fill
material.
☒ 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.

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4) Please describe the following action(s) to be taken during and following excavation and
management of site soils:
☒ Check to confirm that management of fugitive dust from site activities will be handled in
accordance with applicable local, state, and federal requirements.
Field screening of site soil
At a minimum, contractors shall be made aware of protocols should impacted soils (e.g. staining,
unusual odors, fill materials) be identified.

Describe the field screening method, frequency of field screening, person conducting field
screening:
During all soil disturbance at the site (excavation and trenching), workers and contractors
will observe soil for evidence of potential impacts. Evidence of potentially impacted soil
includes a distinct unnatural color, strong odor, or filled or previously disposed materials of
potential environmental concern (i.e., chemicals, tanks, drums, etc.). Should the above be
observed during site work, the contractor shall stop all work and contact ONE to assess the
suspect condition. If ONE confirms that the material may be impacted, then the
procedures below will be implemented. In addition, the DEQ Brownfields project manager
will be contacted within 48 hours to advise of the condition.
Soil sample collection
☐ Yes

☒ Not anticipated - In order to avoid delays in construction, a plan shall be in place for sampling
of suspect soils should they be encountered during redevelopment. If soil sample collection is
not anticipated but the need to do so is identified during redevelopment, notify the Brownfields
project manager of the anticipated sample and report dates for scheduling purposes.

Describe the sampling method (e.g., in-situ grab, composite, stockpile, etc.) and confirm that all
procedures outlined in applicable DEQ guidance for assessment shall be followed Typically, at
least one representative sample (per 500 yd3 for residential and 1,000 yd3 for commercial)
consisting of a 3 to 5-point composite sample with grab sample for VOCs based on the highest PID
reading is required to determine soil management options:

The collection of additional soil samples is not anticipated based on the completed soil
characterization activities to date. If impacted soil is encountered during grading and/or
installation or removal of utilities, excavation will proceed only as far as needed to allow
grading or other construction-related activity to continue and/or only as far as needed to
allow alternate corrective measures as described below.

Suspect-impacted soil excavated during redevelopment activities that have not been
previously characterized may be stockpiled and covered in a secure area to allow
construction to progress. Suspect impacted soil will be underlain and covered with a
minimum of 10-mil plastic sheeting, following the NCBP Diagram for Temporary

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Containment of Impacted or Potentially Impacted Soil. At least one representative soil
sample (no less than three aliquot soil samples) at a sample ratio of one soil sample per
approximately 1,000 cubic yards of soil will be collected for analyses selected below (i.e.,
total VOCs, SVOCs, RCRA metals, and hexavalent chromium). The VOC sample will be a
grab sample from the aliquot exhibiting the highest PID field screen reading. If the soil
sample laboratory analytical results indicate that the soil could potentially exceed the
hazardous characteristic criteria based on the Rule of 20, then the soil will also be
analyzed by TCLP methods for the compounds that could exceed the hazardous
characteristic criteria.

Soil will be managed in accordance with the table below. If impacted soil with
concentrations above Residential or POG PSRGs is moved to an on-site location, the
location and depth will be documented and provided to DEQ.

Check applicable chemical analytes for soil samples:
☒ Minimum Sample Requirements: Volatile organic compounds (VOCs) by EPA Method
8260; Semi-volatile organic compounds (SVOCs) by EPA Method 8270; and Metals RCRA
List + Hexavalent Chromium by EPA Method 6020/7199
☐ 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) (e.g. Herbicides): Click or tap here to enter text.

☒ Check to confirm that by the owner’s signature and the North Carolina Professional
Engineer/Geologist sealing this EMP the consultant understands that no work plan for suspect
soil sample collection will be submitted beyond this EMP, and that it is the responsibility of the
sealing professional and property owner to ensure that all applicable guidelines and
methodologies are followed and reported to DEQ for determination and approval of soil
placement prior to final relocation.

If impacted soils above applicable PSRGs and/or site specific risk thresholds are proposed to be
relocated on-site, prior to final placement on-site, the following shall be submitted for DEQ
review/approval
- Analytical data that has been sampled in accordance with the above referenced frequency and
following procedures outlined in the most recent Brownfields Redevelopment Section
Environmental Site Assessment Work Plan Minimum Requirements Checklist (Checklist) and in
accordance with DEQ IHSB Guidelines for Assessment and Cleanup of Contaminated Sites
(Guidelines)
- Figure outlining planned soil placement and any future site features including
buildings/hardscape/open areas
- A North Carolina PE/PG recommendation of placement

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Impacts
Options
Onsite Placement without
conditions
Onsite placement under 2 ft
of cap or clean fill1, 2
All Constituents below applicable
PSRGs X
Constituents3 below applicable
PSRGs; Metals below background
but above PSRGs X
Constituents3 below applicable
PSRGs; Metals above Background
/PSRGs X
Constituents above Applicable
PSRGs X

1: Requires Prior Written DEQ Approval
2: VOC impacted soils above applicable PSRGs shall not be placed directly beneath building footprints
without prior written DEQ approval.
3: Constituents indicate any samples evaluated for other than metals.

☒ 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:

☒ 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 that apply):
☒ Minimum Sample Requirements: Volatile organic compounds (VOCs) by EPA Method
8260; Semi-volatile organic compounds (SVOCs) by EPA Method 8270; and Metals RCRA
List + Hexavalent Chromium by EPA Method 6020/7199

☐ 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) (e.g. Herbicides): 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, indicate if a work
Click or tap here to enter text.

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plan for final grade sampling may be submitted under separate cover.
Following completion of soil disturbance for future site development (i.e., after grading
and utility construction), ONE will evaluate the site for disturbed areas that will not be
covered upon completion of the redevelopment with a minimum of 2 ft of demonstrably
clean fill material, landscaping materials, building foundations, sidewalks, asphalt or
concrete parking areas, driveways, or other impervious areas (e.g., tightly spaced pavers or
bricks). If uncovered disturbed areas with suspected impact exist, a Work Plan will be
prepared for final grade sampling for DEQ Brownfields review and approval.

☐ If final grade sampling was NOT selected, please explain rationale:
Click or tap here to enter text.

PART 1.B. IMPORTED FILL SOIL

NO SOIL MAY BE BROUGHT ONTO THE BROWNFIELDS PROPERTY WITHOUT PRIOR APPROVAL FROM
THE BROWNFIELDS REDEVELOPMENT SECTION. 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 Redevelopment Section), 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:
☒ Check to confirm that the import volumes outlined below have been confirmed based on
geotechnical evaluations.

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?

3) If yes, what is the anticipated depth that fill soil will be placed at the property? (If a range
of depths, list the range.)
Click or tap here to enter text.

PRIOR TO SOIL PLACEMENT AT THE BROWNFIELDS PROPERTY, a Soil Import Request must be
submitted for DEQ Brownfields review and approval. The request shall consist of a data
package that details:

- Fill source location/history (Phase I if available, current aerials, etc.)
- Analytical data that has been sampled in accordance with the below frequency and
following procedures outlined in the most recent Brownfields Redevelopment Section
Environmental Site Assessment Work Plan Minimum Requirements Checklist (Checklist)
and in accordance with DEQ IHSB Guidelines for Assessment and Cleanup of
Contaminated Sites (Guidelines)
- A table comparing the import soil to existing site concentrations

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- A PE/PG recommendation of import
- All relevant attachments listed in the Checklist

Soil Import Sampling Requirements:
Source Sample Frequency Sample Analysis
Virgin Material from DEQ
Brownfields Pre-
approved Quarry
None (Contact Brownfields project manager for list of pre-
approved Quarries
DEQ Permitted Quarry
(Not Brownfields Pre-
approved)
At least one
representative sample
from area of planned
import
VOCs, SVOCs, RCRA
Metals, any site specific
COCs (e.g. pesticides,
PCBs, etc.)
Other NC DEQ
Brownfields Property
At least one
representative sample
per 1,000 yd3 consisting
of a 3-point composite
sample with grab sample
for VOCs based on the
highest PID reading
VOCs, SVOCs, RCRA
Metals, any site specific
COCs (e.g. pesticides,
PCBs, etc.)
Off-site
unpermitted/regulated
property
Bulk Landscape Material
from Commercial Vendor
(i.e. topsoil)
No Sampling Required

If other special considerations apply, discuss:
Click or tap here to enter text.

☒ Check to confirm that by the owner’s signature and the North Carolina Professional
Engineer/Geologist sealing this EMP the consultant understands that no work plan for suspect soil
sample collection will be submitted beyond this EMP, and that it is the responsibility of the sealing
professional and property owner to ensure that all applicable guidelines are followed and reported in
the Soil Import Request for DEQ approval. Failure to meet these requirements could result in
resampling and/or failure to approve import.

PART 1.C. SOIL EXPORT

NO SOIL MAY LEAVE THE BROWNFIELDS PROPERTY WITHOUT APPROVAL FROM THE
BROWNFIELDS REDEVELOPMENT SECTION. Failure to obtain approval may violate a brownfields
agreement causing a reopener or jeopardizing eligibility in the Section, endangering liability
protections and making said action possibly subject to enforcement. Justifications provided
below must be approved by the Section in writing prior to completing transport activities. Refer
to Brownfields IR 15 for additional details.

1) If export from the Brownfields Property is anticipated, export soil must be sampled at a
frequency of one sample per 1,000 yd3 consisting of a 3-point composite sample with a
grab sample for VOCs based on the highest PID reading. Samples shall be analyzed at a
minimum for VOCs, SVOCs, and RCRA metals plus any site specific COCs.

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PRIOR TO EXPORT FROM THE BROWNFIELDS PROPERTY, a Soil Export Request must be
submitted for DEQ Brownfields review and approval. The request shall consist of a Data
Package that details:

- Proposed Receiving Facility
- Analytical data that has been sampled in accordance with the above referenced
frequency and following procedures outlined in the most recent Brownfields
Redevelopment Section Environmental Site Assessment Work Plan Minimum
Requirements Checklist (Checklist) and in accordance with DEQ IHSB Guidelines for
Assessment and Cleanup of Contaminated Sites (Guidelines)
- A table comparing the export soil to concentrations on the receiving site concentrations
including risk comparison (Note that calculated risk cannot be increased on the receiving
site)
- A North Carolina PE/PG recommendation of export
- Written approval from the receiving site property owner representative for export
- All relevant attachments listed in the Checklist

Soil Export Options
Impacts
Options
Use as
Beneficial Fill
Off-site disposal at
other Brownfields
Property2,6,7
Off-site disposal
at LCID/CD
Landfill1, 3
Off-site disposal at Subtitle
D MSW/Permitted
Landfarm4
All Constituents below
applicable PSRGs X X X X
Constituents5 below
applicable PSRGs; Metals
below background but
above PSRGs
X X X
Constituents5 below
applicable PSRGs; Metals
above Background /PSRGs
X X X
Constituents above
Applicable PSRGs X X
1: Requires Prior Written DEQ Approval
2: VOC impacted soils above applicable PSRGs shall not be placed directly beneath building footprints
without prior written DEQ approval.
3: Requires comparison to site specific metals concentrations.
4: Facility to determine if they can accept soil within their permit.
5: Constituents indicate any samples evaluated for other than metals.
6: Requires written approval from receiving site property owner representative.
7. Site COCs must be in comparable concentrations to receiving site and not significantly raise risk of
the receiving site.

☒ Check to confirm that by the owner’s signature and the North Carolina Professional
Engineer/Geologist sealing this EMP the consultant understands that no work plan for suspect soil
sample collection will be submitted beyond this EMP, and that it is the responsibility of the sealing
professional and property owner to ensure that all applicable guidelines are followed and reported in

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the Soil Export Request for DEQ approval. Failure to meet these requirements could result in
resampling and/or failure to approve export.

If other special considerations apply, discuss:
In situ soil characterization assessment activities were completed at the site in April 2023. Based
on the results of the assessment activities, approximately 40,650 cubic yards of excess soil that do
not contain compound concentrations above the PSRGs (or background levels in the case of
metals) will be directly loaded onto trucks and transported off-site to an LCID landfill, other
Brownfields property, Subtitle D Landfill, or other locations with DEQ prior approval.
Approximately 9,850 cubic yards of excess soil that contains compound concentrations above the
PSRGs (or background levels in the case of metals) will be transported off-site for disposal at
another Brownfields property, a Subtitle D Landfill, or other location with DEQ prior approval.
Approximately 1,200 cubic yards of excess soil that contains compound concentrations above the
PSRGs will be transported off-site for disposal at a Subtitle D Landfill or other location with DEQ
prior approval. Additional information is provided under Contaminated Media, Part 1. Soil,
Subsection 7. A summary of in situ soil characterization export options is provided in Attachment
2.2.

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.
☒ If yes, provide specifications on barrier materials or provide the results of this evaluation in the
Vapor Mitigation Plan. Note that if vapor mitigation is planned for site buildings, utility corridors
will need to be evaluated as part of mitigation designs:
The PD plans to install a vapor barrier and passive-to-active vapor intrusion mitigation system
(VIMS) during construction. As part of the VIMS design, the locations of sub-grade utilities will
be evaluated to confirm that the proposed VIMS will effectively minimize potential vapor
intrusion from lateral migration of vapors through utility trenches. The Vapor Intrusion
Mitigation Plan will be submitted under separate cover.

☐ If no, include rationale here:
Click or tap here to enter text.

☒ Unknown, details to be provided in the Vapor Mitigation Plan for site buildings

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Other comments regarding managing impacted soil in utility trenches:
During utility installation activities, workers and contractors will observe soil for evidence of
potential impacts. Evidence of potentially impacted soil includes a distinct unnatural color,
strong odor, or filled or previously disposed materials of potential environmental concern (i.e.,
chemicals, tanks, drums, etc.). Should the above be observed during site work, the contractor
will stop all work and contact ONE to assess the suspect condition. If ONE confirms that the
material may be impacted, then the procedures outlined in Part 1.A. Managing Onsite Soil above
will be implemented. In addition, the DEQ Brownfields project manager will be contacted within
48 hours to advise of the condition.

Should impacted soil be discovered during utility installation activities, appropriate safety
screening of the vapors will be performed to protect workers. Appropriate safety screening
activities include monitoring the breathing zone with a calibrated photoionization detector or
similar instrument. If results indicate further action is warranted to protect workers from vapors,
appropriate engineering controls (such as the use of industrial fans) will be implemented.
PART 2. GROUNDWATER

1) What is the depth to groundwater at the Brownfields Property?
Depth to groundwater was measured ranging from approximately 15 ft bgs in the low-lying
western portion of the site to approximately 27 ft bgs in the higher-elevated southeastern
portion of the site. A site potentiometric map is included as Attachment 2.6. Monitoring well
locations are also shown in Attachment 2.0. A tabular summary of groundwater elevations is
included in Attachment 7.0.

2) What is the maximum depth of soil disturbance onsite?
Cut depths extend to approximately 20 ft bgs. Bedrock is anticipated to be encountered at
depths beyond 20 ft bgs.
3) Is groundwater known to be contaminated by ☐onsite ☒offsite ☐both or ☐unknown
sources? Describe source(s):
ONE collected groundwater samples from preexisting monitoring wells during assessment
activities conducted in April 2023. As shown in Attachment 2.0, MW-1 through MW-3 were
located on the Dynamic Auto Works II property. MW-4 was located on the Foundry property.
Groundwater is known to be impacted by TCE as a result of an offsite release from the former
H.M. Wade Furniture/textile chemical facility located adjacent and topographically up-gradient
of the property. A summary of the most recent groundwater assessment results is provided
below:

Volatile Organic Compounds (VOCs)
Laboratory analytical results reported low detections of VOCs across the site and at estimated
laboratory values denoted by a “J”. Only trichloroethene (TCE) was detected at concentrations
above the 15A NCAC 02L .0202 Groundwater Quality Standards (2L GWQS) in two (2) sample
locations and the consequent investigation derived waste (IDW). Samples MW-2, MW-3, and the
IDW reported TCE concentrations of 71.5 μg/L, 83.4 μg/L, and 45.2 μg/L, respectively.

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Semi-Volatile Organic Compounds (SVOCs)
Laboratory analytical results reported low detections of SVOCs in one sample at estimated
laboratory values analyzed outside of sample hold time denoted by a “J” and “H.” Sample MW-
01 reported detections of diethyl phthalate (0.868 JH μg/L) and dimethyl phthalate (3.81 JH μg/L)
at concentrations below the 2L GWQS and GCL. No other SVOCs were detected.

Metals
Laboratory analytical results reported low detections of several metals across the site, including
barium (up to 90.2 μg/L), total chromium (up to 3.74 μg/L), lead (up to 0.561 J μg/L), and
selenium (up to 1.51 μg/L). No metal concentrations were reported above the 2L GWQS or GCL.

A tabular summary of groundwater sample analytical results is included in Attachment 6.2.
Sample MW-4 reported no exceedances of 2L GWQS or GCLs. A map depicting groundwater
sample locations with 2L GWQS analytical exceedances is shown in Attachment 2.3.

4) What is the direction of groundwater flow at the Brownfields Property?
The direction of groundwater flow is expected to be northwest toward Irwin Creek as shown in
figure 2.6. This is consistent with surface topography, as shown in Attachments 3.0 and 3.1.
5) Will groundwater likely be encountered during planned redevelopment activities (e.g.
footer/utility construction or helical pilings?)
☒Yes ☐No
If yes, describe these activities:
Groundwater may be encountered during redevelopment activities including excavations for
deeper foundational components associated with the proposed building. If groundwater is
encountered during redevelopment activities, the procedures outlined below will be
implemented.
In the event that groundwater is encountered during redevelopment activities (even if no is checked above), list activities for contingent management of groundwater (e.g., dewatering of groundwater from excavations or foundations, containerizing, offsite disposal, discharge to sanitary sewer, NPDES permit, or sampling procedures).
If groundwater is encountered during redevelopment activities and gathers in an open
excavation, appropriate worker safety measures will be undertaken. The contractor will contact
ONE to assess the area of accumulation. The accumulated water will be allowed to
evaporate/infiltrate to the extent that dissipation does not disrupt the construction schedule.
Should the time needed for the natural dissipation of accumulated water be deemed
inadequate, the water will be pumped into a holding container, sampled for the presence of
VOCs, SVOCs, and RCRA metals, and disposed of at an appropriate off-site facility. Accumulated
water that does not contain constituents above 2L Standards and the NCDEQ Surface Water
Standards will be managed on-site by being discharged to the stormwater system following
consultation with local stormwater officials and in accordance with applicable municipal and
State regulations for erosion control and construction stormwater control. In accordance with
15A North Carolina Administrative Code (NCAC) 2H .0106 (f)(7), groundwaters generated by
well construction or other construction activities are deemed to be permitted pursuant to G.S.

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143-215.1(c) provided that no water quality standards are contravened, or expected to be
contravened.

6) Are monitoring wells currently present on the Brownfields Property?.................☒Yes ☐No
If yes, are any monitoring wells routinely monitored through DEQ or other
agencies?..................................................................................................................☐Yes ☒No

7) 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 Redevelopment Section’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.

8) Please provide additional details as needed:

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
1) Is surface water present at the property? ☒ Yes ☐ No
2) If yes, 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 ☐ Unknown
4) Will workers or the public be in contact with surface water during planned redevelopment
activities or as part of the final redevelopment? ☒ 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):
All surface water activities will be performed in compliance with United States Army Corps of
Engineers (USACE) Nationwide Permit 29, Residential Developments (Attachment 4.0). There are
no known impacts to surface water on site. In the unlikely event suspected contaminated
surface water is encountered during redevelopment activities, the contractor will contact ONE to
assess the area(s) suspected to be impacted. If surface water run-off gathers in an open
DEQ will be notified if newly identified monitoring wells are discovered on site.

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excavation within an area suspected to be impacted during construction activities, appropriate
worker safety and groundwater management measures will be undertaken. The accumulated
water will be allowed to evaporate/infiltrate to the extent that dissipation does not disrupt the
construction schedule. Should the time needed for the natural dissipation of accumulated water
be deemed inadequate, the water will be pumped into a holding container, sampled for the
presence of VOCs, SVOCs, and RCRA metals, and disposed of at an appropriate off-site facility.
Accumulated water that does not contain constituents above 2L Standards and the NCDEQ
Surface Water Standards will be managed on-site by being discharged to the stormwater system
following consultation with local stormwater officials and in accordance with applicable
municipal and State regulations for erosion control and construction stormwater control.

PART 4. SEDIMENT
1) Are sediment sources present on the property? ☒ Yes ☐ No
2) If yes, is sediment at the property known to be contaminated? ☐ Yes ☒ No ☐ Unknown
3) Will workers or the public be in contact with sediment during planned redevelopment
activities? ☒ Yes ☐ N
4) Attach a map showing the 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):
All sediment activities will be performed in accordance with USACE Nationwide Permit 29,
Residential Developments (Attachment 4.0). During redevelopment activities, workers and
contractors will observe sediment for evidence of potential impacts. Evidence of potentially
impacted sediment includes a distinct unnatural color, strong odor, or filled or previously
disposed materials of potential environmental concern (i.e., chemicals, tanks, drums, etc.).
Should the above be observed during site work, the contractor will stop all work and contact ONE
to assess the suspect condition. If ONE confirms that the material may be impacted, then the
procedures outlined in Nationwide Permit 29 and Part 1.A. Managing Onsite Soil above will be
implemented. In addition, the DEQ Brownfields project manager will be contacted within 48
hours to advise of the condition.
Should impacted sediment be discovered during box culvert bypass installation activities,
appropriate safety screening of the vapors will be performed to protect workers. Appropriate
safety screening activities include monitoring the breathing zone with a calibrated
photoionization detector or similar instrument. If results indicate further action is warranted to
protect workers from vapors, appropriate engineering controls (such as the use of industrial fans)
will be implemented.

PART 5. SOIL VAPOR
1) Do concentrations of volatile organic compounds at the Brownfields property exceed the vapor intrusion screening levels (current version) in the following media:

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Groundwater Exterior Soil Vapor Sub-Slab Soil Vapor
Residential ☒ Yes ☐ No
☐ Unknown
☒ Yes ☐ No
☐ Unknown ☒ Yes ☐ No
☐ Unknown
Commercial ☒ Yes ☐ No
☐ Unknown ☒ Yes ☐ No
☐ Unknown ☒ Yes ☐ No
☐ Unknown
2) Attach a map showing the locations of all soil vapor samples including any soil vapor
contaminants that exceeds screening levels and overlays planned site development features.
3) If applicable, at what depth(s) is exterior soil vapor known to be contaminated?

4) If applicable, at what depth(s) is sub-slab soil vapor known to be contaminated?
☐0-6 inches ☒Other, please describe:
ONE conducted soil gas assessment activities in April 2023 that included the collection of four (4)
sub-slab soil gas samples. Tetrachloroethene (PCE) was detected at concentrations above the
non-residential DEQ Vapor Intrusion SGSLs. Sample collection depth ranged from nine (9) to 11
inches bgs. Locations of sub-slab soil gas samples and compound concentrations above the DEQ
Vapor Intrusion SGSLs are shown in Attachment 2.4. A tabular summary of the sub-slab soil gas
analytical data is included in Attachment 6.3.
5) Will workers encounter contaminated exterior or sub-slab soil vapor during planned
redevelopment activities? ☐ Yes ☐ No ☒ Unknown
In the event that apparent contaminated soil vapor is encountered (based on elevated PID
readings, unusual odors, etc.) during redevelopment activities (trenches, manways, basements or
other subsurface work,) list activities for management of such contact, INCLUDING notification to
DEQ within 48 hours of identification of the issue for determination of additional requirements:
If impacted soil vapors are encountered during redevelopment activities, appropriate safety
screening of the vapors will be performed to protect workers. Appropriate safety screening
activities include monitoring the breathing zone with a calibrated photoionization detector or
similar instrument. If results indicate further action is warranted to protect workers from vapors,
appropriate engineering controls (such as the use of industrial fans) will be implemented. In
addition, the DEQ Brownfields project manager will be contacted within 48 hours to advise of the
condition.

PART 6. INDOOR AIR
1) Are indoor air data available for the Brownfields Property? ☒ Yes ☐ No
ONE conducted soil gas assessment activities in April 2023 that included the collection of 17 exterior
soil gas samples. Compounds 1,3-butadiene and trichloroethene (TCE) were detected at
concentrations above the non-residential DEQ Vapor Intrusion Soil Gas Screening Levels (SGSLs).
Sample collection depths ranged from six (6) to 15 ft bgs. Locations of the exterior soil gas samples
and compound concentrations above the DEQ Vapor Intrusion SGSLs are shown in Attachment 2.4. A
tabular summary of the soil gas analytical data is included in Attachment 6.3.

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2) If applicable, 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 ☒ N/A

☒ If no, include rationale here:
Indoor air samples were collected at 601 and 619 S Cedar Street in June 2014. A historical
sample location map is included in Attachment 2.5. Laboratory analytical results reported no
detections of EPA Method TO-15 constituents. A tabular summary of historical indoor air
analytical data is included in Attachment 6.4. No indoor air samples have been collected within
the footprint of the proposed redevelopment. Existing buildings within the footprint of the
proposed redevelopment will be razed.
4) In the event that contaminated indoor air is encountered during redevelopment activities, list
activities for management of such contact:

VAPOR INTRUSION MITIGATION SYSTEM
1) Is a vapor intrusion mitigation system (VIMS) proposed for this Brownfields Property?
☒ Yes ☐ No ☐ Unknown

☐ If no or unknown, include rationale here as well as plans for pre-occupancy sampling, as
necessary:
Click or tap here to enter text.

If yes, ☐ VIMS Plan Attached or ☒ VIMS Plan to be submitted separately
If submitted separately provide date:
The PD intends to install a DEQ-approved passive-to-active vapor intrusion mitigation system
designed by a North Carolina licensed Professional Engineer. The vapor intrusion mitigation plan
will be submitted under separate cover. VIMS Plan shall be signed and sealed by a NC Professional Engineer and follow the DEQ Brownfields Redevelopment Section’s Vapor Intrusion Mitigation System Design Submittal Requirements.
Note that approval of this EMP does not imply approval with any vapor intrusion mitigation land
In the unlikely event there is evidence of potential indoor air issues (i.e., unusual odors) during
redevelopment activities, the area will be evacuated, and appropriate safety screening of the indoor
air will be performed. Appropriate safety screening activities include monitoring the breathing zone
with a calibrated photoionization detector or similar instrument. If results indicate further action is
warranted to protect workers from vapors, appropriate engineering controls (such as the use of
industrial fans) will be implemented and DEQ Brownfields will be notified within 48 hours.

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use restrictions or requirements of the recorded or draft Brownfields Agreement and that
separate approval of mitigation measures will be required.

CONTINGENCY PLAN

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, or other 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:
☒ Minimum Sample Requirements: Volatile organic compounds (VOCs) by EPA Method 8260;
Semi-volatile organic compounds (SVOCs) by EPA Method 8270; and Metals RCRA List +
Hexavalent Chromium by EPA Method 6020/7199

☐ 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) (e.g. Herbicides)
Please note, if field observations indicate the need for additional analyses, they should
be conducted, even if not listed here.
Click or tap here to enter text. Please provide details on the proposed methods of managing the following commonly
encountered issues during redevelopment of Brownfields Properties.

Underground Storage Tanks – Note that UST Section guidelines must be followed for sample
frequency during UST closure. Unless damage to onsite structures to remain as part of
redevelopment would occur, USTs shall be removed from the Brownfields Property:
In the event a UST or impacts associated with a UST release are discovered on-site during
redevelopment activities, the UST and/or associated impacts will be addressed through DEQ
Brownfields. DEQ Brownfields will be notified within 48 hours of discovery.

If a UST is encountered, residual fluids (if present) will be removed, sampled for VOCs, SVOCs, and
RCRA metals, and transported off-site for disposal at an approved facility. The tank will be assessed

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for closure and removal and soil sampling will be performed following DEQ UST Section guidelines.
Soil samples will be analyzed for VOCs, SVOCs, RCRA metals, and hexavalent chromium. Impacted
soil will be managed under Part 1 A. Managing Onsite Soil.

If the UST cannot be removed, DEQ will be notified for approval of in-place closure and soil
sampling will be performed following DEQ UST Section guidelines. If present, residual fluids will be
removed, sampled for VOCs, SVOCs, and RCRA metals, and transported off-site for disposal at an
approved facility. The bottom of the UST may be penetrated to prevent fluid accumulation.
Impacted soil will be managed under Part 1.A. Managing Onsite Soil.

Sub-Grade Feature/Pit:
If a sub-grade feature or pit is encountered and does not require removal, it will be backfilled with
demonstrably clean fill material and construction will proceed. Where appropriate, the bottom may
be penetrated before backfilling to prevent fluid accumulation. If the pit is observed to contain
waste, the waste will be relocated to a secure area and will be sampled for TCLP VOCs, TCLP SVOCs,
and TCLP metals. Based on laboratory analytical results, the waste will be disposed of offsite at an
approved facility or managed under Part 1.A. Managing Onsite Soil, whichever is most applicable
based on the type of waste present.
Buried Waste Material – Note that if buried waste, non-native fill, or any obviously filled materials
is encountered, the DEQ Brownfields Redevelopment Section must be notified to determine if
investigation of landfill gases is required:
If excavation into buried wastes or impacted soils occurs, the contractor will cease work in that
location and notify ONE. ONE will assess the suspect area and collect samples if warranted. In this
event, confirmation sampling will be conducted at representative locations in the base and
sidewalls of the excavation after waste or impacted soil is removed. The samples will be analyzed
for VOCs, SVOCs, RCRA metals, hexavalent chromium, and any other analyses deemed appropriate
based on the type of waste material. If buried debris is encountered, DEQ Brownfields will be
notified to determine if methane sampling is required. DEQ Brownfields will be informed regarding
the permitted facility used for disposal of the waste and/or impacted soil. Areas of suspected
contaminated soil that remain at the site after excavation is complete will be managed under Part 1.
A. Managing Onsite Soil.

Re-Use of Impacted Soils Onsite:
Please refer to the procedures outlined in Part 1.A. Managing Onsite Soil.

If unknown, impacted soil is identified onsite, management onsite can be considered after the
project team provides the necessary information, outlined in Part 1.A. Item 11, for Brownfields
project manager approval prior to final placement onsite.
If other potential contingency plans are pertinent, please provide other details or scenarios as
needed below:
Click or tap here to enter text.

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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 1/31/2025

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).

☒ 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.

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A. APPROVAL SIGNATURES

Brownfields Project Number: 17021-13-060 (primary redevelopment) and 26093-22-060

Brownfields Project Name: Dynamic Auto Works II (primary redevelopment) and Foundry

PE/PG Professional License #: 051886
Firm PE/PG License #: P-0771

Insert PE/PG Seal Above

Prospective Developer: AP Foundry, LP Date 1/11/2024
Printed Name/Title/Company: Mr. Welch Liles / Managing
Director / AP Foundry, LP

Consultant: ONE Environmental Group of Carolina, PLLC Date 1/8/2024
Printed Name/Title/Company: Hillary Goodell / Operations
Manager / ONE Environmental Group of Carolina, PLLC

Brownfields Project Manager: Carolyn Minnich Date Click or tap to enter a date.

__________________________________________________
1/12/2024

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