26063_A&A Truck and Auto_EMP_ 20240228

NORTH CAROLINA BROWNFIELDS REDEVELOPMENT SECTION
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: Previously submitted with
the Brownfields Application as a confidential exhibit
2. Estimated jobs created:
a. Construction Jobs: 200
b. Full Time Post -Redevelopment Jobs: 5
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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........................................................................................................................
5
CONTAMINATED MEDIA.........................................................................................................................
7
PART1. SOIL........................................................................................................................................
8
PART 2. GROUNDWATER..................................................................................................................
18
PART 3. SURFACE WATER..................................................................................................................
20
PART 4. SEDIMENT............................................................................................................................20
PARTS. SOIL VAPOR.........................................................................................................................
20
PART6. INDOOR AIR.........................................................................................................................
21
VAPOR INTRUSION MITIGATION SYSTEM.............................................................................................
22
CONTINGENCYPLAN.............................................................................................................................
23
POST -REDEVELOPMENT REPORTING.....................................................................................................
25
APPROVAL SIGNATURES.......................................................................................................................
26
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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:
M A set of redevelopment plans, including architectural/engineering plans, if available; if
not, conceptual plans may suffice if updated when detailed plans are drafted.
M 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
onsite 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 import to the Brownfields Property.
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❑ 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.
® 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: 11/30/2023 Revision Date (if applicable): 2/28/2024
Brownfields Assigned Project Name: A&A Truck & Auto (A.K.A. Ltd. West Charlotte)
Brownfields Project Number: 26063-22-060
Brownfields Property Address: 8501 Wilkinson Boulevard and 3900, 3940, and 4000 Sam Wilson Road,
Charlotte, NC 28214
Brownfields Property Area (acres): 15.92
Is Brownfields Property Subject to RCRA Permit? ....................... ❑ Yes M 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): Greystar Development East LLC
Contact Person: Josh Glover
Phone Numbers: Office: 704-379-1868 Mobile: Click or tap here to enter text.
Email: [e-mail]
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Contractor for PD: Greystar Development East LLC
Contact Person: Michael Henry
Phone Numbers: Office: Click or tap hereto enter text
Email: [e-mail]
Environmental Consultant: Froehling & Robertson, Inc.
Contact Person: Brian T. Olin, PG
Phone Numbers: Office: 704.409.7243
Email: [e-mail]
Mobile: [phone]
Mobile: Click or tap here to enter text.
Brownfields Redevelopment Section Project Manager: Ms. Stephanie Graham
Phone Numbers: Office: 704-235-2195 Mobile: [phone]
Email: [e-mail]
Other DEQ Program Contacts (if applicable, i.e., UST Section, Inactive Hazardous Site Branch,
Hazardous Waste, Solid Waste):
N/A
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 onsitetask:
On -site assessment or remedial activities:
Construction or grading start: ......................
............................................... 10 days Prior
............................................... 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 ❑Townhomes (Prior written DEQ approval REQUIRED regardless of ownership
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structure) ❑Recreational ❑Institutional ❑Commercial ❑Office ❑Retail ❑ Industrial
❑Other specify:
Proposed redevelopment with nine three-story residential apartment buildings, a clubhouse, and
a pool.
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
(Completed with Phase I ESA)
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:
The existing buildings and concrete and asphalt paving will be demolished and disposed of in
accordance with applicable regulations. Demolition permits will be obtained prior to demolition
of the structures. Some grading will be conducted and nine three-story apartment buildings and
a one-story office/maintenance building with above grade parking will be constructed as shown
on the attached plans. The development will include a pool and clubhouse, paved sidewalks and
access ways, and landscaped areas. The buildings will consist of slab on grade construction with
no basements or crawl spaces. Ground floor uses will include leasing office and clubhouse
facilities for the apartments, residential apartment units, and common areas. The sediment basin
for erosion control during construction will be converted to a stormwater detention basin after
construction.
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://deg.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.
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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: 4/15/2024
b) Anticipated duration (specify activities during each phase):
27 Months Total Duration from Ground Breaking
April/May 2024 — Demolition of Buildings
May 2024 - Begin Grading and Construction
June 2026 - Complete Construction and Planned Occupancy of New Buildings
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.
Ctart rlata-
Planned Activity:
Click or tap here to enter text.
Start Date:
Planned Activity:
Click or tap here to enter text.
d) Provide the planned date of occupancy for new buildings: 1/2/2026
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
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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):
TPH-DRO: B-7, B-11, B-12 (435 to 3,490 mg/kg)
RCRA-8 Metals: Iron - SB-1, SB-2, SB-3, SB4, SB-5 (Below Regulatory Screening Level to 77,400
mg/kg); Lead - DL-1 (324 mg/kg); Arsenic - SB-1 through SB-5 DUP, and SB-7 (0.71 to 2.61 mg/kg
(Likely background)
See attached tables and Contaminant Maps for detailed concentrations and locations
2) Depth of known or suspected contaminants (feet):
0-10
3) Area of soil disturbed by redevelopment (square feet):
673,290 scl ft
4) Depths of soil to be excavated (feet):
10 feet - maximum proposed cut depth (including the pool are), except for the detention basin
which will be 27 feet bgs. The deeper soils excavated are planned to be reused on site under
impermeable surface cover.
5) Estimated volume of soil (cubic yards) to be excavated (attach grading plan):
-1,000 cubic yards
6) Estimated volume of excavated soil (cubic yards) anticipated to be impacted by contaminants:
-200 cubic yards
7) Estimated volume of contaminated soil expected to be disposed of offsite, if applicable:
-200 cubic yards
PART 1.A. MANAGING ONSITE SOIL
If soil is anticipated to be excavated fromthe Brownfield Property, relocated on the Brownfields
Property, or otherwise disturbed during site grading or other redevelopment activities, please
provide a grading plan that clearly illustrates areas of cut and fill (approximate areas & volumes are
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acceptable, if only preliminarydata available).
1) HAZARDOUS WASTE DETERMINATION:
a) Does the soil contain a LISTED WASTE as defined inthe 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:
Concentrations of RCRA-8 Metals arsenic were detected in soil at concentrations
above the respective NCDEQ Residential Health Based PSRG in soil samples SB-1
through SB-5 DUP and SB-7. Published soil metals concentrations data for the
project area suggest that the reported arsenic concentrations are likely
attributable to naturally occurring metal concentrations typical of the surficial
soils existing at the Property. Naturally occurring background metals are typically
not subject to regulatory action. Concentrations of RCRA-8 Metals iron were
detected in soil at concentrations above their respective NCDEQ Residential
Health Based PSRG in soil samples SB-1 through SB-5 DUP. Concentrations of lead
were detected in soil above the respective NCDEQ Protection of Groundwater
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PSRG in the roof drip line sample DL-1, but the concentration did not exceed the
Residential PSRG. The TCLP lead concentration was 0.0850 J mg/kg which is
below the Protection of Groundwater PSRG and the impacts are not
characteristically hazardous, therefore further assessment or remediation
related to lead concentrations around the former residential building is not
warranted.
d) NOTE: IF SOIL MEETS THE DEFINITION OF A CHARACTERISTIC HAZARDOUS WASTE, THE
SOIL MAYNOT 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.
'- - - or t
Additional comments:
Where possible, soils are proposed to be left in place under buildings or other hardscape cap
(such as buildings, paved areas, concrete, etc.), or 2 feet of clean fill soils.
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:
® Manage soil under impervious cap ® or clean fill
® Describe cap or fill:
Cap or fill may consist of buildings, concrete, or asphalt pavement. Approximately 80
to 90 % of the site will be under hardscape. Impacted areas that do not have
hardscape will be covered with either 2 feet of demonstrably clean fill (based on one
sample per 1,000 cubic yards of soils) from an approved borrow site if borrow
materials is deemed to be suitable to be used as backfill and cover. The soil sampling
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results will be submitted to the NC Brownfields Section for review and approval prior
to utilizing soil as demonstrably clean fill.
® Confer with NC BF project manager if Brownfield Plat must be revised (or re -recorded if
actions are Post -Recordation).
® GPS the location and provide site map with final location.
❑ Other. Please provide a description of the measure:
C' , - —
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:
Based on existing soil data, safety protocols should be taken by construction
workers in the onsite areas at and/or in the vicinity of areas known to be impacted
by TPH-DRO and RCRA-8 Metals. The contractor should implement a Health and
Safety Plan to instruct workers on safe work practices in these areas. If stained soils
are observed or odors noted during excavation work, the excavation will be paused
and the environmental consultant will be notified to screen the soils with a PID, and
collect a sample if warranted based on field observations and PID readings, and the
NCDEQ will be notified within 48 hours.
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 yd3for 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:
If potentially impacted soil is encountered a minimum of 1 composite soil sample will be
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collected for every 500 yards of material for SVOCs, and RCRA metals, plus a grab sample
for VOCs from the aliquot with the highest PID reading.
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):
® Other Constituents & Respective Analytical Method(s) (e.g. Herbicides):
Off -site soil transport is not anticipated; however, parameters may be added such
as TPH or other parameters if required by receiving sites or facilities if a need
arises to transport soil off -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 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
Options
Onsite Placement without
Onsite placement under 2 ft
Impacts
conditions
of cap or clean fills, 2
All Constituents below applicable
X
PSRGs
Constituents' below applicable
PSRGs; Metals below background
X
but above PSRGs
Constituents3 below applicable
PSRGs; Metals above Background
x
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/PSRGs
Constituents above Applicable X
PSRGs
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:
Soil stockpiling is not proposed, and any soils disturbed are proposed to be reused at the
Brownfields Property unless they are found to be geotechnically unsuitable. Any soil that are
stockpiled will be properly placed on plastic and handled in accordance with Figure 1 until they
are returned to the place they were excavated or disposed off -site in accordance with the table
above and/or approved by the NCDEQ if field screening identifies soil conditions not consistent
with previously documented soils or if determined to be geotechnically unsuitable.
Previously unknown impacted soils if encountered and/or geotechnically unsuitable or excess
soils that need to be disposed of off -site will be submitted for the analysis selected above. A
separate work plan will not be submitted for this sampling. For these soils, if they are proposed
to be left onsite, one sample per 1,000 cubic yards will be analyzed for SVOCs, RCRA 8 Metals,
and hexavalent chromium. This sample will be collected of 3 to 5 aliquots for each 1,000 cubic
yard sample. The composite will be collected use a dedicated or decontaminated sample scoop
and the samples will be composited in a decontaminated stainless steel bowl. The soils will be
mixed and placed into dedicated laboratory provided containers. A grab sample of the soil
aliquot containing the most apparent evidence of impacts (if present) based on PID readings,
staining, odors, etc. will be collected and analyzed for VOCs. These soil sampling results will be
submitted to the NC Brownfields Section for review and approval prior to the soil being re -used
onsite. The soil will be handled in accordance with the Re -Use of Impacted Soils Onsite
Contingency Section.
® Final grade sampling of exposed native soil (i.e., soil that will not be under buildings or
permanent hardscape). Select chemical analyses for final grade samples with check boxes below
(Check all thatapply):
® 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.
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❑ PCBs: Specify Analytical Method Number(s):
'-lick or tap here to
❑ Other Constituents & Respective Analytical Method(s) (e.g. Herbicides):
l,ncK or tap nere to enter iex.
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
plan for final grade sampling may be submitted under separate cover.
2-3 composite soil samples will be collected from the 0-2 foot interval (1-2 feet for VOCs)
after construction and grading is complete from areas impacted during development and
not under hardscape. Samples will not be collected from undisturbed vegetated areas.
Each sample will be collected as a composite sample consisting of 4 to 5 aliquots. The
composite will be collected use a dedicated or decontaminated sample scoop and the
samples will be composited in a decontaminated stainless steel bowl. The soils will be
mixed and placed into dedicated laboratory provided containers. Two to three grab
samples will be collected and analyzed for VOCs. The grab samples will be collected from
the 1-2 foot interval by collecting the soils in the laboratory provided sampler and
transferring directly into the laboratory provided preserved jars.
❑ If final grade sampling was NOT selected, please explain rationale:
Click or tap here to enter text
PART I.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?
20,000 cubic yards
3) If yes, what is the anticipated depth that fill soil will be placed at the property? (If a range
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of depths, list the range.)
0-10 feet
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
- A PE/PG recommendation of import
- All relevant attachments listed in the Checklist
Soil Import Sampling Requirements:
Source
Sample Frequency
I Sample Analysis
Virgin Material from DEQ
None (Contact Brownfields project manager for list of pre-
Brownfields Pre -
approved Quarries
approved Quarry
DEQ Permitted Quarry
At least one
VOCs, SVOCs, RCRA
(Not Brownfields Pre-
representative sample
Metals, any site specific
approved)
from area of planned
COCs (e.g. pesticides,
import
PCBs, etc.)
Other NC DEQ
At least one
Brownfields Property
representative sample
VOCs, SVOCs, RCRA
per 1,000 yd3 consisting
Metals, any site specific
Off -site
of a 3-point composite
COCs (e.g. pesticides,
unpermitted/regulated
sample with grab sample
PCBs, etc.)
property
for VOCs based on the
highest PID reading
Bulk Landscape Material
from Commercial Vendor
No Sampling Required
(i.e. topsoil)
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.
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EMP Version 3, March 2023

PART I.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 yd' 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.
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
Options
Use as
Off -site disposal at
Off -site disposal
Off -site disposal at Subtitle
Impacts
other Brownfields
at LCID/CD
D MSW/Permitted
Beneficial Fill
Property2,6,'
Landfill', I
Landfarm4
All Constituents below
applicable PSRGs
X
X
X
X
Constituents' below
applicable PSRGs; Metals
below background but
X
X
X
X
above PSRGs
Constituents' below
applicable PSRGs; Metals
X
X
X
X
above Background /PSRGs
Constituents above
Applicable PSRGs
X
X
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EMP Version 3, March 2023

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
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:
Click or tap here to enter text.
PART I.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 theywere
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:
Results of soil gas assessment activities completed within the proposed building footprint
indicated concentrations of benzene above the NCDEQ Residential Soil Gas Screening Limits
in soil gas samples SG-4, SG-9, SG-16, SG-17, and SG-18. Concentrations of 2-hexanone were
detected above the NCDEQ Residential Soil Gas Screening Limits in soil gas samples SG-6,
SG-9, and SG-12 through SG-17. Based on the detected compounds, the NCDEQ risk
calculator indicates that the calculated vapor intrusion risk output associated with the
exterior soil gas data exceeds the Hazard Index (HI) of 1.4, which in turn exceeds the
residential soil gas to indoor air exposure pathway of 1.0. Based on the exceeded HI, the
Brownfields Program will require vapor mitigation for this Brownfields site. Utility trenches
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EMP Version 3, March 2023

should be evaluated during construction for odors or elevated PID readings, and in
accordance with the Vapor Intrusion Management Plan to determine if vapor barriers
should be installed in utility trenches to prevent movement of vapors into the buildings.
❑ If no, include rationale here:
❑ Unknown, details to be provided in the Vapor Mitigation Plan for site buildings
Other comments regarding managing impacted soil in utility trenches:
If stained soils are observed or odors noted during excavation work, the excavation will be
paused and the environmental consultant will be notified to screen the soils. If impacted
soils are identified based on field screening, staining, presence of odors, or other evidence
of impact, the area will be vacated, samples will be collected, and it will not be returned to
the utility trench excavation without NCDEQ approval and the NCDEQ will be notified. A
sample will collected from the base of the excavation/sidewalls every 6 feet of impacted
soil. If impacted soils are encountered requiring disposal demonstrably clean fill will be
utilized to backfill the trench as needed after approval from the NCDEQ. The impacted soil
will be disposed of off -site as discussed in Part 1.0 above.
PART 2. GROUNDWATER
1) What is the depth to groundwater at the Brownfields Property?
During the Brownfields Assessment groundwater was encountered during drilling activities at
depths ranging from approximately 11 feet below ground surface (ft bgs) to 44.9 ft bgs.
Following installation of temporary monitoring wells (TMWs), depth to groundwater was
measured from the top of well casing (TOWC) from approximately 3.3 ft bgs to 39.3 ft bgs.
The sediment basin will be installed with a clay liner to prevent mixing with the groundwater.
2) What is the maximum depth of soil disturbance onsite?
—10 feet bgs, except for the detention basin which will be —27 feet bgs
3) Is groundwater known to be contaminated by ❑onsite ❑offsite ®both or ❑unknown
sources? Describe source(s):
Concentrations of barium, cadmium, chromium, lead, and selenium were detected in the
groundwater samples above the 15A NCAC 02L GWQS. Iron, and manganese were previously
identified in the groundwater from the adjacent upgradient DyStar incident.
4) What is the direction of groundwater flow at the Brownfields Property?
South-southwest
5) Will groundwater likely be encountered during planned redevelopment activities (e.g.
footer/utility construction or helical pilings?)
❑Yes NNo
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If yes, describe these activities:
Click or tap here to enter text.
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).
The preference is to allow surface or groundwater to naturally evaporate or dissipate.
If groundwater is encountered that does not naturally dissipate and interrupts th e
construction schedule and needs to be removed from excavations in low points such as
for footings, the parking lot, or the swimming pool, and it does not contain
constituents above 2L Standards and the NCDEQ Surface Water Standards (based on
laboratory analysis), it will be managed on -site by being discharged to the municipal
sanitary sewer system via the sediment basin at the site in accordance with applicable
municipal and State regulations for erosion control and construction stormwater
control and the sites erosion and sediment control permits and as discussed below.
In accordance with 15A North Carolina Administrative Code (NCAC) 2H .0106 (f)(7),
once excavation begins, any dewatering of footers/foundation work and any
groundwaters generated by well construction or other construction activities will be
discharged to the sediment basin and skimmer in accordance with the Charlotte -
Mecklenburg Stormwater Services indicating this method is acceptable. Such
discharges are deemed to be permitted pursuant to G.S. 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? ................. Eyes ®No
If yes, are any monitoring wells routinely monitored through DEQ or other
agencies?.................................................................................................................. Eyes ❑ 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:
Click or tap here to enter text.
Please note, disturbance of existing site monitoring wells without approval by DEQ is not
19
EMP Version 3, March 2023

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):
No work is planned by the stream present on the Brownfields Property. If surface water run-off
gathers in an open excavation within an area determined to be impacted during construction
activities, appropriate worker safety measures will be undertaken. The accumulated water will
be allowed to evaporate/infiltrate to the extent time for dissipation does not disrupt the
construction schedule. Should the time needed for natural dissipation of accumulated water be
deemed inadequate, the water will be tested for the presence of VOCs (8260), SVOCs (8270),
and RCRA metals (6020/7471) and will be properly managed if impacted. Options for water
disposal include 1. containerizing, characterizing and disposing of the water at a permitted
treatment facility; 2. discharging in accordance with an Individual NPDES permit; 3. discharging
to the storm sewer if below surface water standards and after appropriate sediment control in
accordance with the sedimentation and erosion control permit; and 4. using for on -Site dust
control if no significant VOC, SVOC, or RCRA Metal concentrations are present.
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 ® No
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):
A stream is present on the western boundary of the Brownfields property. No work is planned by
the stream present on the Brownfields Property.
PART 5. SOIL VAPOR
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EMP Version 3, March 2023

1) Do concentrations of volatile organic compounds at the Brownfields property exceed the
vapor intrusion screening levels (current version) in the following media:
Groundwater
Exterior Soil Vapor
Sub -Slab Soil Vapor
Residential
® Yes ❑ No
® Yes ❑ No
❑ Yes ® No
❑ Unknown
❑ Unknown
❑ Unknown
Commercial
❑ Yes ❑ No
❑ Yes ® No
❑ Yes ® No
❑ Unknown
❑ Unknown
❑ 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?
10 ft bgs
4) If applicable, at what depth(s) is sub -slab soil vapor known to be contaminated?
❑0-6 inches ❑Other, please describe:
N/A
5) Will workers encounter contaminated exterior or sub -slab soil vapor during planned
redevelopment activities? ❑ Yes ❑X 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:
The contractor will check any utility trench for vapors prior to contractors entering trenches. If
unusual odors or stained soils are encountered, the environmental consultant will be
contacted to screen for vapors in the work area. If vapors are encountered in the trenches, the
DEQ will be notified to determine if additional assessment and mitigation is warranted with
regard to the utilities potentially acting as a vapor mitigation pathway to planned buildings.
Work in the area will be halted until the NC Brownfields Section has determined that no
further mitigation or assessment is warranted. The trench will be ventilated prior to workers
entering the trench if vapors are encountered.
PART 6. INDOOR AIR
1) Are indoor air data available for the Brownfields Property? ❑ Yes ® No
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
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EMP Version 3, March 2023

❑ If no, include rationale here:
Click or tap here co enter text.
4) In the event that contaminated indoor air is encountered during redevelopment activities, list
activities for management of such contact:
In the unlikely event there is evidence of potential indoor air issues (i.e. unusual odors) during
redevelopment activities, the area will be evacuated and appropriate safety screening of the indoor
air will be performed by the environmental consultant. If warranted, safety screening procedures will
include periodically screening of indoor air for volatile organic compound (VOC) vapors utilizing a
calibrated PID when workers are present in the Site buildings. If results of the field screening indicate
further action is warranted, appropriate engineering controls (such as the use of industrial fans) will
be implemented. Note that the site buildings are slated for demolition as part of the redevelopment
activities.
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:
Results of soil gas assessment activities completed within the proposed building footprint
indicated concentrations of benzene above the NCDEQ Residential Soil Gas Screening Limits in
soil gas samples SG-4, SG-9, SG-16, SG-17, and SG-18. Concentrations of 2-hexanone were
detected above the NCDEQ Residential Soil Gas Screening Limits in soil gas samples SG-6, SG-9,
and SG-12 through SG-17. Based on the detected compounds, the NCDEQ risk calculator
indicates that the calculated vapor intrusion risk output associated with the exterior soil gas data
exceeds the Hazard Index (HI) of 1.4, which in turn exceeds the residential soil gas to indoor air
exposure pathway of 1.0. Based on the exceeded HI, the Brownfields Program will require
installation of a vapor intrusion mitigation system (VIMS) for this Brownfields site in accordance
with the DWM Minimum Mitigation and Sampling Requirements for Reuse date February 2023.
If yes, ❑ VIMS Plan Attached or ® VIMS Plan to be submitted separately
If submitted separately provide date:
Pending (To be Determined- March/April 2024
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
use restrictions or requirements of the recorded or draft Brownfields Agreement and that
22
EMP Version 3, March 2023

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, 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:
® 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.
l.I It - I% VI LCIP IICIC lV CA IICI LCA.
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:
No USTs are anticipated to be present on the Property. Should unanticipated USTs be encountered
work will cease in that area until the area can be assessed by the environmental consultant. Should
assessment confirm the presence of a UST or UST impacts, the NCDEQ Brownfields Manager will be
notified within 48 hours and consulted as to potential further sampling, reporting, and mitigation.
USTs if encountered will be removed (or if appropriate emptied and closed in place) in accordance
with NCDEQ and local regulations. Impacted soils in the vicinity of the USTs will be managed in
23
EMP Version 3, March 2023

accordance with the Part 1A: Managing On -Site Soils section of this EMP.
Sub -Grade Feature/Pit:
Should subgrade features or pits be encountered work will cease in that area until the area can be
assessed by the environmental consultant. Should assessment confirm the presence of a subgrade
feature or pit, and associated impacts, the NCDEQ Brownfields Manager will be notified within 48
hours and consulted as to potential further sampling, reporting, and mitigation. The sub -grade
feature will be removed if feasible. If the feature contains waste the waste will be characterized for
disposal for TCLP VOCs, TCLP SVOCs, and TCLP metals prior to removal of the waste for transport
and off -site disposal at a permitted facility, or the waste will be managed per the Managing On -Site
Soil section of this EMP —whichever is most appropriate based on the waste material. If the feature
is concrete and the waste characteristics indicate that the concrete is impacted to a significant
degree, the concrete will be analyzed by methods specified by disposal facility.
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:
Should buried waste materials be encountered work will cease in the portion of the site where the
waste material is encountered until the area can be assessed by the environmental consultant.
Should assessment confirm the presence of a waste material or impacts, the NCDEQ Brownfields
Manager will be notified within 48 hours and consulted as to potential further sampling, reporting,
and mitigation. In general, buried wastes will be evaluated by the environmental consultant and
samples collected for analysis as needed. Waste will be set aside in a secure area and sampled for
disposal purposes. Confirmation sampling will be conducted at representative locations in the based
and sidewalls of the excavation after the waste and significantly impacted soil is removed.
Confirmation samples will be analyzed for VOCs, SVOCs RCRA Metals (or other analyses deemed
appropriate based on the waste material).
Re -Use of Impacted Soils Onsite:
Impacted soils will be sampled in accordance with Part LA (or a work plan approved by the NC
Brownfields Section prior to sampling). The NC Brownfields Section will be notified within 48 hours
of discovery of new areas of impacted soil. Soils to be re -used on site will be managed in accordance
with Part I.A. If levels are not suitable for re -use, the NC Brownfields Section will be notified, and
soils will be disposed of off -site in accordance with Part 1.0 and the soils replaced in accordance
with Part 1.13.
If unknown, impacted soil is identified onsite, management onsite 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 onsite.
If other potential contingency plans are pertinent, please provide other details or scenarios as
needed below:
If evidence of previously unknown impacted soils or vapors are identified during site work the
NCDEQ will be consulted regarding the necessity and scope for additional assessment and
mitigation.
24
EMP Version 3, March 2023

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 the date set forth in the recorded Brownfields Agreement.
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).
❑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.
25
EMP Version 3, March 2023

APPROVAL SIGNATURES '
Brownfields Project Number: 26063-22-060
Brownfields Project Name: A&A Truck & Auto
Prospective Developer: Greystar Development East, LLC
Printed Name/Title/Company: Josh Glover/Authorized
Representative/Greystar
Consultant: Froehling & Robertson, Inc.
Printed Name/Title/Company: Brian T. Olin, P.G. /
GeoEnvironmental Practice Leader / F&R
PE/PG Professional License #: PG - 2229
Firm PE/PG License #: C-124
Project M
: Stephanie Graham
26
EMP Version 3, March 2023
2/28/2024
Date Click or tap to enter a date.
02/28/2042
Date Click or tap to enter a date.
Insert PE/PG Seal Above
2/29/2024
Date

Figure 1
NC"BP Diagram for Temporary
Containment of Impacted or Potentially
Impacted Suil
Cross -Section View
Top Plastic Covu Shccting:
Nlap Vie►,
Straw &IQ Berm
Undcrlill a: l lav4,T minimtun of 10
4V'cighl
Plastic
Sheeting
Ante: Adapted from 11C DEQ UST Sertiun "Cuidelines for Ex Situ Petroleum Containitiated Soil Rein ediotion" dated Ueceinber, L 2013
27
EMP Version 3, March 2023

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Project Number:
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SB-1
l
a. y 3..''�►� n r7Q r7 DyStar
^ - ; 4 Carolina
Chemical
`[ SB-6 xx }
;[
A ` � a ,, ., �• . � ,� f l 1
O Soil Boring '* x
® Soil Boring & Temporary
GW Point
�-
Soil Sample Location Map —August 2023
Client: Gre star Development East
Froehling & Robertson, Inc. Project: A&A Truck &Auto
3015 Dumbarton Road Location: Charlotte, North Carolina
VVV"`I� Richmond, Virginia 23228 Project Number: 59A-0290Data Source: Goo le Earth FIGURE S
T 804.264.2701 Date: October 2023 A roximate Scale: As Shown No.:

{ i Al Powder -
Coating
F• „.1 s Y
- o
7 vv
56-2 {
Iran 62,500 mg/kg
....._
Mobii
5B-1 f
SB-4 �!
Iron 77,400 mg/kg �?_ lry ----� h
Iron 57,000 mg/kg
-5 Iron 71,600 mg/kg
SB-3 �101 SB-5 DUP Iron 58,500 mg/kg
Iron 66,900 mg/kg
k
DyStar 11,
Carolina —.
Chemical i
.41
• yl: 'r ' �+`�'yy' -�x fir - , �— ,
�.•� `��'��t} �Iki 513-6 BRSL-f w•,
V 4 I CB-7 '
�_ �. Hex Chromium 2.81 1 `
+1yati • 5.. r.
O Soil Boring , {.
® Soil Boring & Temporary {
GW Point:
BRSL = Below Regulatory Screening
Levels
Soil Sample Results Map —August 2023
Froehling & Robertson, Inc.
3015 Dumbarton Road
VVV"`I� Richmond, Virginia 23228
. T 804.264.2701
Client:
Gre star Development East
Project:
A&A Truck &Auto
Location:
Charlotte, North Carolina
Project Number:
59A-0290Data
Goo le Earth
October 2023 A roximate Scale: As Shown
FIGURE 6
NO.:
Source:
Date:

46;'
D L-1
Lead 324 mg/kg '.
`# TCLP Lead 0.0850 J
5 D L-4
DL-2 Lead 39.6 mg/kg
f. Lead 102 mg/kg '
�'F- DL-3
... r '
Lead 115 mg/kg
1P4.
+
{ + /
} i Y At
'
k '7 r F
Roof Drip Line Sample .t
de .
AN "FilFes` 41 *• ' -
Roof Drip Line Sample Locations and Results Map —August 2023
Client: Gre star Development East
Froehling & Robertson, Inc. Project: A&A Truck &Auto
3015 Dumbarton Road Location: Charlotte, North Carolina
VVV"`I� Richmond, Virginia 23228 Project Number: 59A-0290Data source: Goo le Earth FIGURE 7
T 804.264.2701 Date: October 2023 A roximate Scale: As Shown No.:

Al Powder
Coating
aif I -
Abandoned Well,
i' Mobil
G_W.S
GW-4
.r GW-3 :t
ar
Carolina
Chemical
GW-1
G W-2 7' , It •� ° .+.
0
® Soil Boring & Temporary '•� q
r
GW Point
{ Temporary Well
Groundwater Sample Location Map —August 2023
Client: Gre star Development East
Froehling & Robertson, Inc. Project: A&A Truck &Auto
3015 Dumbarton Road Location: Charlotte, North Carolina
VVV"`I� Richmond, Virginia 23228 Project Number: 59A-0290Data Source: Goo le Earth FIGURE 9
T 804.264.2701 Date: October 2023 —Approximate Scale: As Shown NO.:

Temp. Well ID
Well Height in
Depth to Water
Groundwater
Al POWder
Elevation (feet)
(from top of
Elevation (feet)
Coating
casing)
GW-1*
i
633.0
3.30
629.70
- p (Not Included)
GW-2
1
636.0
39.30
596.70
GW-3
644.0
30.83
613.17
r
GW-4
646.0
31.60
614.40
GW-5
650.0
35.70
614.30
'
■�ti • r'`1
GW-6
656.0
35.16
620.84
<L
_
Abandoned Well
GW-6 620,84' �
620' Iy�---
4 Mobil_
GW-5 514-Ur --
615'
GW-4 614.40' � i• r=
GW-3 613.17'
III'
rY
DyStar � -
_�:` Carolina,
AFC
605' V�,. Chemical N.
s 4 GW-1 629.70'
i - r
GW-2 596,70'
600 l
N
IT
� + 7
® Soil Boring & Temporary
.. ,gip. �• � �.
GW Point
Temporary Well
}2.7
Groundwater Flow Direction Map
Client: Gre star Development East
�(� n Froehling & Robertson, Inc. Project: A&A Truck &Auto
]4 �[ 3015 Dumbarton Road Location: Charlotte North Carolina
V�}\ Richmond, Virginia 23228 Project Number: 59A-0290
i FIGURE
Data Source: Goo le Earth 10
T 804.264.2701 r% ... .,-._kw ­'. C-..i,.. cF....... No.:

Al Powder
Coating
aif I -
.� s
�' �
Gw-5
Chromium 52.4 µg/L M1
I
Mobil
GW-5
GW-4 Chromium 39 µg�L
Chromium 19.8 µg/L ;�
GW-3
y 4 sc
Barium 6,300 µglL
Chromium 830 2 L
GW-3 DUP f µg�
:, "1• 4 .0 r�'w ; Lead 60.3 µg/L DyStar
' ;�► '� Chromium 102 µg/L
Selenium 21.5 µg/L Carolina
JAA1* -I_ - ; Chemical �L
GW-2
it 4 Chromium 10.4 µg/L
a Barium 5,420 µg/L {{ I r4 k
Chromium S88 µg/L f ;,
Lead 139 Ng/L
Oki
® Soil Boring & Temporary
GW Point
Temporary Well `� '� ' s i ' ..�i
Groundwater Sample Results Map —August 2023
Client: Gre star Development East
Froehling & Robertson, Inc. Project: A&A Truck &Auto
3015 Dumbarton Road Location: Charlotte, North Carolina
VVV"`I� Richmond, Virginia 23228 Project Number: 59A-0290FIGURE
Data Source: Goo le Earth 11
T 804.264.2701 Date: August 2023 Approximate Scale: As Shown NO.:

SG-2
` 1 ' Mobil
M1 I
1 SG-3
SG-1
Naphthalene 4.19
Naphthalene 23.9
s.
• �, � � ; 17 � WfY "� ;�► t } .� �} I ''. DyStar
Carolina y
_�c•'�� � � t �-- � Chemical '_ s
. tih`'tiy', its �' -- � ,, .I
AT
' SG-4 �'
1
♦ • �a F- r r� � 1 7
QSoil Gas Sample
Prior Soil Gas Sample Location Map —April 2022
Client: Gre star Development East
Froehling & Robertson, Inc. Project: A&A Truck &Auto
3015 Dumbarton Road Location: Charlotte, North Carolina
VVV"`I� Richmond, Virginia 23228 Project Number: 59A-0290Data Source: Goo le Earth FIGURE 12
T 804.264.2701 Date: October 2023 A roximate Scale: As Shown NO.:

Al Powder
Coating
aif I -
SG-10
* � i -- • - f_ _ ._ _ Mobil
SG-9
�- l • _r � `r 1
SG-4 SG-7
— SG-8
„ ;; ^,�► _ a _ " SG-15 '�' i wry DyStar
SG-12 Carolina,
-fir , Chemical
SS
G-14
SG-18 cI SS-4
— SG-13 ` k
t= s
17
S6-3
Sub -slab Sample
(in existing building)r.a
QSoil Gas
x„ x' +. a
Sub -Slab and Soil Gas Sample Location Map —August 2023
Client: Gre star Development East
Froehling & Robertson, Inc. Project: A&A Truck &Auto
3015 Dumbarton Road Location: Charlotte, North Carolina
VVV"`I� Richmond, Virginia 23228 Project Number: 59A-0290Data Source: Goo le Earth FIGURE 13
T 804.264.2701 Date: October 2023 A roximate Scale: As Shown NO.:

NEW­_M
Al Powder
Coating
i
5G-1 BIR SG-11 BRSL a
5G-10 BR5L
* SG-3 BRSL Mobil -
�� r SG-9
,4 ■ Benzene 13.2 µg/m3
SG-2 BRSL 2-Hexanone 324 µg/m3
SG-4 SG-7 BRSL
Benzene 14 µg/m3 r SG 8 BRSL • _ ?
SG 15 SG-5 BRSL `' SG-5
Chlprpform 18.9 µg/m3 2-Hexanone 255 µg/m3 1
2-Hexanone 344 pg/m3
r SG-12 DyStar Carolina
SG-16 �. 2-Hexanone 300 µg/m3 Chemical 5
.�
Benzene 18.9 µg/m 3 l SS-1 BRSL SG-14
SS-2 BRSL
2-Hexanone 333 µg/m3
SG-18
Benzene 65.1 µg/m3 � A.
i ..� ❑ SSA BRSL .r r
}l
s SG-17 .1,A �� I'y SG-13
Y•
Benzene 21.2 µg/m3 2-Hexanone 2g6 µg/m3
SS-3 BRSL
Sub -slab Sample
(in existing building)
QSoil Gas Sample
BRSL = Below Regulatory
Screening Levels '...
Sub -Slab and Soil Gas Sample Results Map —August 2023
Client: Gre star Development East
n Froehling & Robertson, Inc. Project: A&A Truck &Auto
j[ 3015 Dumbarton Road Location: Charlotte North Carolina
I Richmond, Virginia 23228 Project Number: 59A-0290Data Source: Goo le Earth FIGURE 14
T 804.264.2701 Date: October 2023 A roximate Scale: As Shown No.:

INSON BLVD
'.. ._
r � �
Approximate location of
177'mmo
2.9
samples SW-2, SED-21
and SW-DUP
74
I
i
or
I
T
ll
I
Cal
, I
i
A! 4F
Approximate location of
samples SW-1, SED-1,
and SED-DUPl
• Sediment Sample
I
IT
• Surface Water Sample
BRSL = Below Regulatory
Screening
Levels
}
Bou aries Wapproximate
Stream and Sediment Sample Locations Map —January 2024
Froehling & Robertson, Inc.
Client:
Gre star Development East, I.I.C.
Project:
A&A Truck and Auto
Location:
8501 Wilkinson Boulevard and 4000 Sam Wilson Road, Charlotte, North Carolina
Q3015 Dumbarton Road
F Richmond, Virginia 23228
Project Number:
59A-0290
FIGURE
Data Source:
T 804.264.2701
Goo le Earth
Februar 2024
Scale: Not To Scale
15
No.:
Date:

INSON BLVD
�.. ._
r � �
SED-2 Arsenic 1.03 mg/kg
22.9
SW-2 BRSL
SW-DUP BRSL
I
74
i
or
I
T
II
I
Cal
, I
i
SED-1 Arsenic 1.68 mg/kg
SED-DUP Arsenic 1.82 mg/kg Lif
SW-1 BRSL
.�
• Sediment Sample
` '
`
• Surface Water Sample
BRSL = Below Regulatory
Screening
Levels
}
Boundayies e,-approxlmate
Stream and Sediment
Sample Results Map —January 2024
Froehling & Robertson, Inc.
Client:
Gre star Development East, U.C.
Project:
A&A Truck and Auto
Location:
8501 Wilkinson Boulevard and 4000 Sam Wilson Road, Charlotte, North Carolina
Q3015 Dumbarton Road
F Richmond, Virginia 23228
Project Number:
59A-0290
FIGURE
Data Source:
T 804.264.2701
Goo le Earth
Februar 2024
Scale: Not To Scale
16
No .:
Date:

22
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Table 3 - Summary of Soil Analytical Results - Roof Line Samples
Wilkinson Boulevard
8501 Wilkinson Blvd, Sam Wilson Rd, Charlotte, North Carolina 28214
Project No.: 59A-0290
Sample ID
Date
Lead
TCLP Lead
(Depth)
Collected
DL-1 (0-6")
8/30/2023
324
0.0850 J
DL-2 (0-6")
102
NA
DL-3 (0-6")
115
NA
DL-4 (0-6")
39.6
NA
Residential Health Based
400
NSE
PSRG
Commercial Health Based
800
NSE
PSRG
Protection of
Groundwater PSRG
270
270
Concentrations reported in mg/kg
Bolded results exceed their respective Residential or Commercial Regulatory Standard (July 2023)
Compounds not listed were not detected above the laboratory method detection limits.
NA = Not Analyzed
J = Estimated value
NSE = No Standard Exists

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