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Home My WebLink About20046_Sidewalk Greenville_Revised EMP Final_201702221 EMP Form ver.1, October 23, 2014 NORTH CAROLINA BROWNFIELDS PROGRAM ENVIRONMENTAL MANAGEMENT PLAN This form is to be used to prepare an Environmental Management Plan (EMP) for projects in the North Carolina Brownfields Program at the direction of a project manager for the program. Prospective Developers and/or their consultants must complete and submit this form and all pertinent attachments to their project manager prior to any site earthmoving or other development related activities. For the resultant EMP to be valid for use, it must be completed, reviewed by the program, and signed by all signers at the bottom. Consult your project manager if you have questions. GENERAL INFORMATION Date: 2/22/2017 Brownfields Assigned Project Name: Sidewalk Greenville (Harris and Rogers Tobacco Sales) Brownfields Project Number: BF# 20046‐16‐074 Brownfields Property Address: 513, 519 and 523 South Pitt Street, Greenville, Pitt County Brownfields Property Area (acres): 2.39 acres per current parcel configuration; 2.167 acres per combined parcels on plat map. Will be recombined into one parcel prior to recordation of BF plat. Is Brownfields Property Subject to RCRA Permit? ☐ Yes ☒ No If yes enter Permit No.: Is Brownfields Property Subject to a Solid Waste Permit? ☐ Yes ☒ No If yes, enter Permit No.: COMMUNICATIONS Prospective Developer (PD): Sidewalk Greenville, LLC Phone Numbers: Office: 614‐883‐1123 …..Mobile: Email: rkirk@hccliving.com Primary PD Contact: Gus Cook Phone Numbers: Office: 614-883-1123 Mobile: 614-402-3452 Email: Environmental Consultant: Solutions‐IES, Inc. (Daphne Jones) /Terracon Consultants, Inc. (Allen McColl) Phone Numbers: Office: 919‐873‐1060 X139 (Daphne) /252‐347‐0743 (Allen) …..Mobile: 919‐271‐3251 (Daphne)/910‐474‐6081 (Allen) Email: djones@daa.com / allen.mccoll@terracon.com Brownfields Program Project Manager: Kelly Johnson 2 EMP Form ver.1, October 23, 2014 Office: 919-707-8279 Email: kelly.johnson@ncdenr.gov Other DENR Program Contacts (if applicable, i.e., UST Section, Inactive Hazardous Site Branch, Hazardous Waste, Solid Waste): N/A NOTIFICATIONS TO THE BROWNFIELDS PROGRAM Advance Notification Times to Brownfields Project Manager: Check each box to accept minimum notice periods (in calendar days) for each type of onsite task: On‐site assessment or remedial activities: Within 10 days ☒ Construction or grading start: Within 10 days ☒ Discovery of stained soil, odors, USTs, buried drums or waste, landfill, or other signs of previously unknown contamination: Within 48 hours ☒ Implementation of emergency actions (e.g. dewatering, flood, or soil erosion control measures in area of contamination, venting of explosive environments): Within 48 hours ☒ Installation of mitigation systems: Within 10 days ☒ Other notifications as required by local, state or federal agencies to implement redevelopment activities: (as applicable): Within 30 days ☒ REDEVELOPMENT PLANS 1) Type of Redevelopment (check all that apply): ☒ Residential ☐ Recreational ☐ Institutional ☒ Commercial ☒ Office ☒Retail ☐ Industrial ☒ Other specify: Parking areas 2) Summary of Redevelopment Plans (attach conceptual or detailed plans as available): a) Do plans include demolition of structure(s)?: ☒ Yes ☐ No ☐ Unknown b) Do plans include removal of building foundation slab(s) or pavement: ☒ Yes ☐ No ☐ Unknown c) Provide brief summary of redevelopment plans, including demolition, removal of building slabs/pavement and other structures: The church located on the 519 S. South Pitt Street parcel, built with a slab-on-grade foundation, will be demolished and disposed in a C&D landfill. Based on the results from asbestos-containing material (ASM) testing, necessary ACM abatement activities will be performed prior to demolition. The asphalt from the City parking lot (513 and 523 S. Pitt Street) and the lot adjacent to the church will be removed and sent offsite at for recycling or disposal. The (church) concrete slab and curb and gutter will also be removed and sent offsite for recycling or disposal. General Contractor (GC) will keep documentation of where materials were sent and provide Environmental Consultant (EC) with information that will be included in post-development reporting required by the brownfields agreement (BFA). The ground level of 3 EMP Form ver.1, October 23, 2014 the planned redevelopment is partially open-air parking, with 20,000 SF enclosed commercial development (office/retail/clubhouse) with residences located on the 2nd through 5th floors. The first-floor commercial space will be built with a slab-on-grade foundation. The 2nd-5th floors will be supported by a post-tension elevated slab that is separate from the first-floor construction. For the elevated slab, geopiers are created by augering #57 stone down into the soil; concrete footings are poured above the geopiers to support the elevated slab. Unless there is soil that is not structurally competent, excess material is not expected on this site. 3) Which category of risk‐based screening level is used or is anticipated to be specified in the Brownfields Agreement? ☒ Residential ☐ Non‐residential or Industrial/Commercial Note: If children frequent the property, residential screening levels shall be cited in the Brownfields Agreement for comparison purposes. 4) Schedule for Redevelopment (attach construction schedule): a) Phase I start date and anticipated duration (specify activities during each phase): 4/3/2017 Utility disconnects will be confirmed and the church demolition and parking lot removal will commence on 4/3/2017. Additional assessment activities and the start of utility emplacement both are scheduled to begin the week of 4/10/2017. Utility work will take 30 days. Various site work will continue over several months, dependent upon DOT project timing (street improvements) and other factors affecting the sequence of construction. All construction will be completed by summer, 2018. b) If applicable, Phase 2 start date and anticipated duration (specify activities during each phase): N/A c) Additional phases planned? If yes, specify activities if known: ☐ Yes ☒ No ☐ Not in the foreseeable future ☐Decision pending d) Provide the planned date of occupancy for new buildings: 8/1/2018 CONTAMINATED MEDIA Contaminated Media (attach tabulated data summaries for each impacted media and figure(s) with sample locations): Part 1. Soil: ☒ Yes ☐ No ☐ Suspected Part 2. Groundwater: ☒ Yes ☐ No ☐ Suspected Part 3. Surface Water: ☐ Yes ☒ No ☐ Suspected Part 4. Sediment: ☐ Yes ☒ No ☐ Suspected Part 5. Soil Vapor: ☐ Yes ☐ No ☒ Suspected Part 6. Sub‐Slab Soil Vapor: ☐ Yes ☒ No ☐ Suspected Part 7. Indoor Air: ☐ Yes ☒ No ☐ Suspected 4 EMP Form ver.1, October 23, 2014 PART 1. SOIL – Please fill out the information below, using detailed site plans, if available, or estimate using known areas of contaminated soil and a conceptual redevelopment plan. Provide a figure overlaying new construction onto figure showing contaminated soil and groundwater locations. 1) Known or suspected contaminants in soil (list specific compounds): Soil was screened for VOCs from the six borings advanced from the surface to the water table during Terracon’s 2016 Limited Site Investigation and sampled at depths of 15 - 17.5 feet below ground surface (bgs). The laboratory detected petroleum petroleum constituents in one soil sample at concentrations below residential PSRGs (Table 1, Appendix B). 2) Depth of known or suspected contaminants (feet): 15 - 17.5 feet below ground surface. 3) Area of soil disturbed by redevelopment (square feet): Entire site (approximately 94,000 square feet) 4) Depths of soil to be excavated (feet): Except for the pool, the anticipated maximum depths of disturbance at the site is approximately four feet bgs. See attached Utility Plan and details (Appendix A: Sheets C3.1, C4.1 and C5.1). The depth of disturbance below the pool area is expected to be between 7‐8 feet bgs. 5) Estimated volume of soil (cubic yards) to be excavated (attach grading plan): The grading plan is not yet finalized; we will forward it as soon as it is available. 6) Estimated volume of excavated soil (cubic yards) anticipated to be impacted by contaminants: Unknown, but based on the soil field screening and lab data and groundwater contaminant concentrations from the initial site investigation, soil is not expected to be significantly impacted by contaminants. 7) Estimated volume of contaminated soil expected to be disposed of offsite, if applicable: Unknown. Unless soil is geotechnically unsuitable or shows signs of contamination, at this time PD does not anticipate the need to remove soil from site. Soil from footers, the pool excavation and grading activities will be able to be placed beneath hardscapes – the slab or paved parking areas. IMPORTED FILL SOIL 1) Will fill soil be imported to the site? ☒ Yes ☐ No ☐ Unknown 2) If yes, what is the estimated volume of fill soil to be imported? Unknown. The only fill material anticipated will be topsoil used in the landscaped areas. 3) If yes, what is the depth of fill soil to be used at the property? 0‐1 feet depth, emplaced over a demarcation layer. If a range of depths, please list the range. 4) PRIOR TO ITS PLACEMENT AT THE BROWNFIELDS PROPERTY, provide plan to analyze fill soil to demonstrate that it meets acceptable standards and can be considered clean for use at the Brownfields property (Check all that apply): ☒ Volatile organic compounds (VOCs) by EPA Method 8260 ☒ Semi‐volatile organic compounds (SVOCs) by EPA Method 8270 ☒ Metals RCRA List (8) (arsenic, barium, cadmium, chromium (speciated), mercury, lead, selenium and silver) ☐ Metals –Hazardous Substance List ‐14 (antimony, arsenic, beryllium, cadmium, chromium (speciated according to IHSB protocol), copper, lead, manganese, mercury, nickel, selenium, silver, thallium, and zinc) 5 EMP Form ver.1, October 23, 2014 ☐ Metals – EPA Priority Pollutant List – 13 (arsenic, beryllium, cadmium, chromium (speciated according to IHSB protocol), copper, mercury, nickel, lead, antimony, selenium, silver, thallium, and zinc) ☐ Other Constituents & Analytical Method: ☐ Known borrow material (DESCRIBE SOURCE AND ATTACH SAMPLING PROFILE): MANAGING ONSITE SOIL 1) If soil in known or suspected areas of contamination is anticipated to be excavated from the Brownfield Property, relocated on the Brownfields Property,or otherwise disturbed during site grading or other redevelopment activities, please provide a grading plan that clearly illustrates areas of cut and fill (approximate areas & volumes are acceptable, if only preliminary data available). 2) HAZARDOUS WASTE DETERMINATION – Does the soil contain a LISTED WASTE as defined in the North Carolina Hazardous Waste Section under 40 CFR Part 261.31‐261.35? ☐ Yes ☒ No If yes, explain why below, including the level of knowledge regarding processes generating the waste( include pertinent analytical results as needed). If yes, do the soils exceed the “Contained‐Out” levels in Attachment 1 of the North Carolina Contained‐In Policy? ☐ Yes ☒ No NOTE: IF SOIL MEETS THE DEFINITION OF A LISTED HAZARDOUS WASTE AND EXCEEDS THE CONTAINED‐OUT LEVELS IN ATTACHMENT 1 TO THE NORTH CAROLINA CONTAINED‐IN POLICY THE SOIL MAY NOT BE RE‐USED ON SITE AND MUST BE DISPOSED OF IN ACCORDANCE WITH DENR HAZARDOUS WASTE SECTION RULES AND REGULATIONS. 3) HAZARDOUS WASTE DETERMINATION – Does the soil contain a CHARACTERISTIC WASTE?: ☐ Yes ☒ No If yes, mark reason(s) why below (and include pertinent analytical results). ☐ Ignitability ☐ Corrosivity ☐ Reactivity ☐ Toxicity ☐ TCLP results ☐ Rule of 20 results (20 times total analytical results for an individual hazardous constituent on TCLP list cannot, by test method, exceed regulatory TCLP standard) If no, explain rationale: The lowest TCE and PCE concentrations in soil that could possibly leach to a concentration that would exceed the D-listed waste by toxicity characteristic threshold is 10,000 and 14,000 μg/kg (20x the TCLP regulatory level). The highest concentrations of TCE and PCE in groundwater is approximately 24 and 15 μg/L (Table 2, Appendix B). Dividing the PGW PSRG by their respective 2L Standards gives a factor of approximately 6x for TCE and 7x for PCE, so the lowest concentration of these constituents in soil that could be responsible for the 2016 groundwater concentrations is 144 and 105 μg/mg/kg respectively for TCE/PCE. The approximate concentrations in 6 EMP Form ver.1, October 23, 2014 soil associated that would leach to the concentrations detected in groundwater are between 70 and 130 times lower than the minimum concentrations that would yield a D-listed waste. Therefore the soil would not be characteristic waste. NOTE: IF SOIL MEETS THE DEFINITION OF A CHARACTERISTIC HAZARDOUS WASTE, THE SOIL MAY NOT BE RE‐USED ON SITE AND MUST BE DISPOSED OF IN ACCORDANCE WITH DENR HAZARDOUS WASTE SECTION RULES AND REGULATIONS. 4) Screening criteria by which soil disposition decisions will be made (e.g., left in place, capped in place with low permeability barrier, removed to onsite location and capped, removed offsite): ☒ Preliminary Health‐Based Residential SRGs A few landscaped areas of the site will remain uncapped by hard surfaces. PD will test clean fill to bring onsite in these areas. Soil excavated from footers and pool area, as long as structurally competent, and not visibily contaminated by staining or having an odor, will be regraded into the site under areas capped by hardscape - the building slab or paved parking areas. Any soil leaving the site will be tested and and its disposal documented. ☐ Preliminary Health‐Based Industrial/Commercial SRGs ☒ Site‐specific risk‐based cleanup level, or acceptable concentrations determined via calculated cumulative risk. Enter details of methods used for determination/explanation: Fill that will be exposed at final grade soil will first be compared to Residential PSRGs. If any of the PSRGs are exceeded, the highest concentration of each constituent detected will be used to calculate cumulative risk. 5) Check the following action(s) to be taken during excavation and management of said soils: ☒ Manage fugitive dust from site: ☐ Yes ☐ No If yes, describe method; If no, explain rationale: This redevelopment project is in an urban area (downtown Greenville). The GC will ensure no fugitive dust leaves the site. If conditions are dry and grading or slab removal/demolition activities produce dust, GC will use City-supplied water to lightly mist construction area(s) as often as necessary to control dust without saturating the soil so that it becomes muddy. ☒ Field Screening: ☐ Yes ☒ No If yes, describe method; If no, explain rationale: Soil samples from six borings were screened for volatile contaminants in the 2016 Limited Site Investigation in the areas deemed most likely to be contaminated, based on the Phase I ESA. The soil borings beneath the planned swimming pool will also be screened in the upcoming additional assessment work. No screening during construction is planned unless the GC notices soil that is stained or has an odor. If so, work will stop in that area until EC, located in Greenville, can mobilize to the site. EC will determine what further actions including field screening may be required, and will provide the NCBP with notification within 48 hours. ☒ Soil Sample Collection: ☒ Yes ☐ No If yes, describe method (e.g., in‐situ grab, composite, stockpile, etc.); If no, explain rationale: EC will only sample soil if GC encounters a previously undiscovered contaminant source, structurally‐ unsuitable or other excess soil to be moved offsite. Soil from a previously undiscovered contaminant 7 EMP Form ver.1, October 23, 2014 source will be tested in situ, prior to excavation/removal. Soil to be removed for structural reasons will be stockpiled and sampled to determine whether soil will be disposed off‐site as special waste under manifest to a Subtitle‐D landfill or to a DEQ‐permitted landfarm for petroleum contaminated soil. The same procedures outlined for testing fill material brought onsite from a construction or grading site, as described in Item 2, Appendix C, will be used to test soil to be removed from the site ☒ Stockpile impacted soil in accordance with NCDENR IHSB protocol in the current version of the “Guidelines for Assessment and Cleanup”, and providing erosion control, prohibiting contact between surface water/precipitation and contaminated soil, and preventing contaminated runoff. Explain any variances: ☒ Analyze potentially impacted soil for the following chemical analytes: ☒ Volatile organic compounds (VOCs) by EPA Method 8260 ☒ Semi‐volatile organic compounds (SVOCs) by EPA Method 8270 ☒ Metals RCRA List (8) (arsenic, barium, cadmium, chromium (speciated), mercury, lead, selenium and silver) ☐ Metals –Hazardous Substance List ‐14 (antimony, arsenic, beryllium, cadmium, chromium (speciated according to IHSB protocol), copper, lead, manganese, mercury, nickel, selenium, silver, thallium, and zinc) ☐ Metals – EPA Priority Pollutant List – 13 (arsenic, beryllium, cadmium, chromium (speciated according to IHSB protocol), copper, mercury, nickel, lead, antimony, selenium, silver, thallium, and zinc) ☒ Other Constituent(s) & Analytical Method(s): Sulfate and sulfur ☒ Proposed Measures to Obtain Pre‐Approval for Reuse of Impacted Soil within the Brownfields Property Boundary ☐ Provide documentation of analytical report(s) to Brownfields Project Manager ☐ Provide documentation of final location, thickness and depth of relocated soil on site map to Brownfields Project Manager once known ☐ Use geotextile to mark depth of fill material (provide description of material) ☒ Manage soil under impervious cap ☐ or clean fill ☐ Describe cap or fill: Most of the site will be covered with hardscape. See attached Site Plan, Appendix A, Sheet C1.1. (provide location diagram) ☐ Confer with NC BF Project Manager if Brownfield Plat must be revised (or re‐ recorded if actions are Post‐Recordation). ☒ Other: Soil that is excavated for footings is not expected to exceed industrial PSRGs that are protective of construction workers. GC will manage soil under hardscape areas at the site unless structurally unsuitable. ☐ Final grade sampling of exposed soil (i.e., soil that will not be under buildings or permanent hardscape): [if not checked provide rationale for not needing] Provide diagram of soil sampling locations, number of samples, and denote Chemical Analytical Program with check boxes below (Check all that apply): ☐ Volatile organic compounds (VOCs) by EPA Method 8260 ☐ Semi‐volatile organic compounds (SVOCs) by EPA Method 8270 8 EMP Form ver.1, October 23, 2014 ☐ Metals RCRA List (8) (arsenic, barium, cadmium, chromium (speciated), mercury, lead, selenium and silver) ☐ Metals –Hazardous Substance List ‐14 (antimony, arsenic, beryllium, cadmium, chromium (speciated according to IHSB protocol), copper, lead, manganese, mercury, nickel, selenium, silver, thallium, and zinc) ☐ Metals – EPA Priority Pollutant List – 13 (arsenic, beryllium, cadmium, chromium (speciated according to IHSB protocol), copper, mercury, nickel, lead, antimony, selenium, silver, thallium, and zinc) ☐ Pesticides ☐ PCBs ☐ Other Constituents & Analytical Method: OFFSITE TRANSPORT & DISPOSITION OF EXCAVATED SOIL NOTE: Unless soil will be transported offsite for disposal in a permitted facility under applicable regulations, no contaminated or potentially contaminated soil may leave the site without approval from the brownfields program. Failure to obtain approval may violate a brownfields agreement, endangering liability protections and making said action subject to enforcement. Justifications provided below must be approved by the Program in writing prior to completing transport activities. ☒ Transport and dispose of impacted soil offsite (documentation of final disposition must be sent to Brownfields Project Manager) ☒ Landfill – analytical program determined by landfill ☒ Landfarm or other treatment facility ☐ Use as Beneficial Fill Offsite – provide justification: ☐ Use as Beneficial Fill at another Suitable Brownfields Site – (Note: a determination that a site is a “Suitable Brownfields” site will require, at a minimum, that similar concentrations of the same or similar contaminants already exist at both sites, use of impacted soil as beneficial soil will not increase the potential for risk to human health and the environment at that site, and that notarized documentation of the acceptance of such soil from the property owner of the receiving site is provided to Brownfields. Provide justification: MANAGEMENT OF UTILITY TRENCHES ☐ Install liner between native impacted soils and base of utility trench before filling with clean fill (Preferred) ☒ Last out, first in principle for impacted soils (if soil can safely be reused onsite and is not a hazardous waste), i.e., impacted soils are placed back at approximately the depths they were removed from such that impacted soil is not placed at a greater depth than the original depth from which it was excavated. ☐ Evaluate whether necessary to install barriers in conduits to prevent soil vapor transport, and/or degradation of conduit materials due to direct impact with contaminants? Result: Yes □ No □ If no, include rationale here. If yes, provide specifications on barrier materials Other comments regarding managing impacted soil in utility trenches: 9 EMP Form ver.1, October 23, 2014 PART 2. GROUNDWATER – Please fill out the information below and attach figure showing distribution of groundwater contaminants at site What is the depth to groundwater at the Brownfields Property? Approximately 18 feet below ground surface. Is groundwater known to be contaminated by ☐onsite ☐ offsite ☐ both ☒ or unknown sources? Describe source(s): Source is unknown. The groundwater contamination may be sourced by the former auto repair shop onsite, or may have migrated onto the property from offsite. What is the direction of groundwater flow at the Brownfields Property? Based on topography to the north-northwest. Will groundwater likely be encountered during planned redevelopment activities? ☐ Yes ☒ No If yes, describe these activities: In the event that contaminated groundwater is encountered during redevelopment activities (even if no is checked above), list activities for contingent management of groundwater (e.g., dewatering of groundwater from excavations or foundations, containerizing, offsite disposal, discharge to sanitary sewer, or sampling procedures): Groundwater will be containerized pending laboratory analysis and subsequent offsite disposal. PART 3. SURFACE WATER – Please fill out the information below. Attach a map showing the location of surface water at the Brownfields Property. Is surface water at the property known to be contaminated: ☐ Yes ☒ No Will workers or the public be in contact with surface water during planned redevelopment activities? ☐ Yes ☒ No In the event that contaminated surface water is encountered during redevelopment activities, or clean surface water enters open excavations, list activities for management of such events (e.g. flooding, contaminated surface water run‐off, stormwater impacts): No surface water bodies exist on site. Erosion and sedimentation controls are presented in Sheet C2.1, Appendix A. PART 4. SEDIMENT – Please fill out the information below. Is sediment at the property known to be contaminated: ☐ Yes ☒ No Will workers or the public be in contact with sediment during planned redevelopment activities? ☐ Yes ☒ No If yes, attach a map showing location of known contaminated sediment at the property. 10 EMP Form ver.1, October 23, 2014 In the event that contaminated sediment is encountered during redevelopment activities, list activities for management of such events (stream bed disturbance): No surface water bodies are at or near the site; therefore, no associated sediment exists. PART 5. SOIL VAPOR – Please fill out the information below. Do concentrations of volatile organic compounds at the Brownfields property exceed the following vapor intrusion screening levels in the following media: IHSB Residential Screening Levels: Soil Vapor: ☐ Yes ☐ No ☒ Unknown Groundwater: ☒ Yes ☐ No ☐ Unknown IHSB Industrial/Commercial Screening Levels: Soil Vapor: ☐ Yes ☐ No ☒ Unknown Groundwater: ☒ Yes ☐ No ☐ Unknown Attach a map showing the location of soil vapor contaminants that exceed site screening levels. If applicable, at what depth(s) is soil vapor known to be contaminated? EC will conduct soil gas sampling mid‐April, 2017 at five locations beneath the first‐floor commercial areas at a depth of approximately five feet. Although the TCE groundwater concentrations from two locations exceeded the Non‐Residential groundwater screening levels (GWSLs), the concentrations are less than an order of magnitude greater than the screening levels with the water table around 18 feet, so exceedances of the non‐residential soil gas screening levels (SGSLs) are not anticipated. Non‐residential SGSLs are applicable to the first‐floor enclosed commercial space. Residential SGSLss should not be applicable at this site because of the separate podium (elevated slab) that will support the residential wood‐frame construction for floors 2‐5. However, because of possible air exchange between the commercial‐use ground floor and upper residential floors through the use of elevators and stairwells, if the soil gas test results exceed residential SGSLs, EC must contact the NCBP and discuss options to eliminate possible vapor intrusion into the residential floors. Will workers encounter contaminated soil vapor during planned redevelopment activities? ☐ Yes ☒ No ☐ Unknown In the event that contaminated soil vapor is encountered during redevelopment activities (trenches, manways, basements or other subsurface work, list activities for management of such contact: Based on the groundwater concentrations and VOC screening of soil from six borings, we do not expect contaminated soil vapor to be encountered during redevelopment activities. However, should excavations uncover soil exhibiting odors or staining during redevelopment, work in that area will be discontinued until the EC can determine if removal of the potentially contaminated soil is necessary and/or if engineering controls such as commercial fans should be used PART 6. SUB‐SLAB SOIL VAPOR ‐please fill out the information below if existing buildings or foundations will be retained in the redevelopment. 11 EMP Form ver.1, October 23, 2014 Are sub‐slab soil vapor data available for the Brownfields Property? ☐ Yes ☒ No ☐ Unknown If data indicate that sub‐slab soil vapor concentrations exceed screening levels, attach a map showing the location of these exceedances. At what depth(s) is sub‐slab soil vapor known to be contaminated? ☐ 0‐6 inches ☐ Other, If other describe: Will workers encounter contaminated sub‐slab soil vapor during planned redevelopment activities? ☐ Yes ☒ No ☐ Unknown In the event that contaminated soil vapor is encountered during redevelopment activities, list activities for management of such contact: PART 7. INDOOR AIR – Please fill out the information below . Are indoor air data available for the Brownfields Property? ☐ Yes ☒ No ☐ Unknown If yes, attach a map showing the location where indoor air contaminants exceed site screening levels. If the structures where indoor air has been documented to exceed risk‐based screening levels will not be demolished as part of redevelopment activities, will workers encounter contaminated indoor air during planned redevelopment activities? ☐ Yes ☒ No ☐ Unknown In the event that contaminated indoor air is encountered during redevelopment activities, list activities for management of such contact: Pre‐existing structure (church) will be demolished. PD has a sub‐slab venting construction contingency planned for areas beneath first floor commercial areas dependent on the results of the soil vapor sampling. PART 8 – Vapor Mitigation System – Please fill out the information below . Is a vapor intrusion mitigation system proposed for this Brownfields Property? ☐ Yes ☐ No ☒ Unknown If yes, provide the date the plan was submitted to the Brownfields Program. Based on the results of the soil gas sampling data, PD will determine whether implement the contingency to construct a sub-slab venting system. The plan will be submitted if the system is necessary. Attach the plan. Has the vapor mitigation plan been approved by the NC Brownfields Program? ☐ Yes ☒ No ☐ Unknown Has the vapor mitigation plan been signed and sealed by a North Carolina professional engineer? ☐ Yes ☒ No 12 EMP Form ver.1, October 23, 2014 What are the components of the vapor intrusion mitigation system? ☐ Sub‐slab depressurization system ☐ Sub‐membrane depressurization system ☐ Block‐wall depressurization system ☐ Drain tile depressurization system ☒ Passive mitigation methods ☒ Vapor barriers ☒ Perforated piping vented to exterior ☐ Other method: If required, a passive sub-slab venting system is planned, which could be converted to an active system if required. PART 9. CONTINGENCY FOR ENCOUNTERING UNKNOWN TANKS, DRUMS, OR OTHER WASTE MATERIALS Please provide a contingency plan in the event unknown tanks, drums, fuel lines, landfills, or other waste materials are encountered during site activities. 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 Notification to State 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. See Notification Section on Page 1 for notification requirements. POST‐REDEVELOPMENT REPORTING In accordance with the site’s Brownfield Agreement, provide a report within the designated schedule to the State Brownfields Project Manager. ☒ Check box to acknowledge consent to provide a redevelopment summary report in compliance with the site’s Brownfields Agreement. APPENDIX A APPENDIX B APPENDIX C APPENDIX C ADDENDUM TO ENVIRONMENTAL MANAGEMENT PLAN EVALUATION OF SOIL FROM OFF‐SITE SOURCES AND TESTING SOIL FOR OFFSITE DISPOSAL HARRIS AND ROGERS TOBACCO SALES (SIDEWALK GREENVILLE) BROWNFIELDS PROPERTY GREENVILLE, NORTH CAROLINA SIES PROJECT NO: 2016.0047.SIDE The North Carolina Brownfields Program (NCBP) requires analysis of fill soil to demonstrate that it meets acceptable screening levels and can be considered clean for use at a brownfields property. The testing of backfill material is not required in the Department of Environmental Quality (DEQ) regulatory programs other than to state that clean backfill will be utilized. The NCBP, a redevelopment program, requires analytical testing to ensure that potentially contaminated soil from an off-site source will not be used for redevelopment of a brownfields property. The scenarios outlined below will be implemented to ensure the backfill material meets the intent of this NCBP requirement. 1.0 Fill Material from Borrow Pit Use of screened fines as backfill material obtained from a commercial borrow pit or quarry is not planned for the Sidewalk Greenville redevelopment site. 2.0 Sampling of Fill Material from Construction/Grading Sites For soil that is obtained from off-site construction or grading sites or sources other than a borrow pit/quarry, Environmental Contractor (EC) will collect samples of topsoil or fill material to be tested by a laboratory for volatile organic compounds (VOCs), semivolatile organic compounds (SVOCs) and RCRA metals. The soil will be tested according the following procedures. EC will consult with the Brownfields Program regarding quantity of fill material and number of samples before collecting representative soil samples from one or more areas of available material. More than one set of samples should be collected if soil is either known or suspected to be sourced from different locations. The soil samples selected for laboratory analysis will be submitted to a DEQ‐certified analytical laboratory for analysis for SVOCs according to SW-846 Method 8270, VOCs according to Method 8260 and the RCRA metals according to SW-846 Methods 6010 and 7471. EC will contact the laboratory to obtain their reporting or method detection limits in soil for all constituents of concern (VOCs, SVOCs and RCRA metals) that are calculated based on dry weight, using an average moisture content of 20%. To the extent possible, detection limits should not exceed residential preliminary soil remediation goals (PSRGs). Within a stockpiled area of soil, EC will first collect two grab samples for VOC testing from two of four sample locations where they will collect aliquots approximately equal in size. The EC will collect grab samples for VOC testing prior to homogenizing these two aliquots and aliquots from two other locations into a composite sample for SVOCs and RCRA metals testing. The two grab samples and one composite soil sample will comprise a representative soil sample. One or two sets of representative soil samples will be collected from each construction or grading site used for backfill depending on the apparent variability of fill material available. The locations of the four aliquots will be randomly selected within a stockpiled area and the soil samples will be collected using a hand auger from different depths and locations within the area being tested. Aliquots used for VOC grab samples will be collected at least 12 inches below the stockpile surface. After the VOC samples are collected, the EC will then create a composite sample by homogenizing the four aliquots in a pre-cleaned Pyrex dish with a stainless-steel spoon. The composite sample will be transferred to the appropriate containers supplied by the laboratory. All samples will be placed immediately on ice and then submitted to the laboratory under chain-of-custody. The hand auger and homogenization equipment will be decontaminated between samples. Appendix C to Environmental Management Plan Evaluation of Soil from Off‐Site Sources and Testing Soil for Offsite Disposal Harris and Rogers Tobacco Sales (Sidewalk Greenville) Brownfields Property SIES Project No: 2016.0049.SIDE Page 2 of 2 The EC will provide documentation to the NCBP, including all analytical data, when soil from construction/grading sources are utilized at the site. If the soil test results have detectable concentrations of organic constituents, or concentrations of metals that exceed residential soil screening levels, the EC will submit the laboratory data and cumulative risk calculator results to the NCBP for review prior to moving the backfill to the Sidewalk redevelopment site. 3.0 Testing for Offsite Disposal or Landfarming of Soil The same procedures outlined in Section 2 will be used for testing soil prior to its removal from the site. Most Subtitle D landfill disposal facility require that sulfate by Method 9056 or equivalent and sulfur (Method 6010) be tested in addition to VOCs, SVOCs and RCRA metals. After reviewing the analytical results, if the only organic constituents present are petroleum-related, EC may wish to contact a DEQ- permitted facility to determine whether they will accept the soil to be remediated by landfarming. In order to meet standard brownfields agreement (BFA) reporting requirements, PD/EC will save copies of the manifests or acceptance documents for each shipment of soil sent offsite for disposal or landfarming. The BFA will require report(s) during the physical redevelopment of the property with documentation that describes: i. actions taken in accordance with this environmental management plan; ii. soil grading and cut and fill actions greater than 12 inches in depth; iii. methodology(ies) employed for field screening, sampling and laboratory analysis of environmental media; iv. 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 v. removal of any contaminated soil, water or other contaminated materials (for example, concrete, demolition debris) from the Property (copies of all legally required manifests shall be included). 4.0 Emplacement of Clean Fill Layer Instead of testing the soil once final grade is met, Prospective Developer (PD) will “cap” areas are not covered with impervious surfaces with 12 inches of soil after testing results demonstrate the soil is suitable for a residential use scenario. EC will contact the NCBP with soil sampling results to obtain final approval for use of the clean fill prior to emplacement. Prior to emplacement of the soil, a demarcation layer such as a geotextile fabric or orange polyethylene construction fencing will be pinned into native soil at base of the excavation to be filled. If the area will be bounded by poured concrete curb and gutter, the edge of the demarcation layer will be placed beneath the curb and gutter area before the concrete is poured so that concrete will form the lateral boundary for the clean soil layer. If no curb and guttering is planned in an area, the demarcation layer will still be pinned to the base of the excavation prior to adding the fill material. EC or GC will take photographs to document this process has been implemented to be included in the final report after construction is complete. APPENDIX D APPENDIX D ADDENDUM TO ENVIRONMENTAL MANAGEMENT PLAN CONTINGENCY PLAN TO ADDRESS NEWLY DISCOVERED CONTAMINANT SOURCES HARRIS AND ROGERS TOBACCO SALES (SIDEWALK GREENVILLE) GREENVILLE, PITT COUNTY, NORTH CAROLINA During site-redevelopment activities, previously undiscovered contaminant sources may be encountered. If the general contractor (GC) encounters a contaminant source, the prospective developer (PD) or the environmental consultant (EC) will notify the applicable agencies within the North Carolina Department of Environmental Quality (DEQ) within 48 hours of discovery, if only by email. These sources may include, but are not necessarily limited to: underground storage tanks (USTs) and fuel lines, buried drums or containers of unknown materials, and areas of buried waste materials/landfills. If the GC encounters previously undiscovered contaminant sources during redevelopment work, the GC will temporarily suspend activities in the area. The GC will immediately notify the EC and the PD. The EC will investigate the area, evaluate the waste materials and/or contaminated media in the area, and determine the proper means to manage these materials. The EC will contact the North Carolina Brownfields Program (NCBP) and provide documentation of the finding and subsequent actions taken to manage these materials. Depending upon site conditions, confirmatory samples may be collected by the EC from the newly discovered contaminant source area(s) for laboratory analysis. All samples will be submitted to a DEQ‐certified analytical laboratory for analysis. Analytical methods to be employed for these samples may include one or more of the following:  VOCs by Method 8260;  SVOCs by Method 8270; PAHs by Method 8270 SIM;  RCRA Metals by Methods 6010/7471;  Total Petroleum Hydrocarbons (TPH) Gasoline Range Organics (GRO) and Diesel Range Organics (DRO) by Method 8015*;  Volatile Petroleum Hydrocarbons (VPH) by the MADEP Method*;  Extractable Petroleum Hydrocarbons (EPH) by the MADEP Method*;  Pesticides by Method 8081;  Herbicides by Method 8151;  Polychlorinated biphenyls (PCBs) by Method 8082;  Corrosivity by Method 1110A;  Reactivity by Method 9012; and/or  Flashpoint, by Method 1010. *TPH and MADEP Methods are not used by the NCBP. These methods can be utilized if the PD wishes to pursue a “no further action” determination from the UST Section in lieu of closure through the NCBP for USTs. 1.0 USTs During the 2016 Limited Site Investigation Services, EC used a ground-penetrating radar subcontractor to scan the southern portion of the site for orphan USTs associated with the former filling station. One area in the vicinity of the former filling station appeared to be an area of less dense soil, a possible indication of a former UST basin. Boring SB-3 was advanced in this area. No other anomalies were found. There are no known USTs on any of the three parcels covered by this EMP. However, if previously unknown UST or fuel lines are encountered during excavation, the PD will manage the tank(s) or piping as required under the guidelines of the UST Section of DEQ. The EC will notify the City of Greenville Fire Department to ascertain the necessary permits to remove the UST(s). The PD or the EC will also notify the NCBP of a UST discovery within 48 hours, if only by email. Appendix D to Environmental Management Plan Contingency Plan to Address Newly Discovered Contaminant Sources Harris and Rogers Tobacco Sales (Sidewalk Greenville) Brownfields Property SIES Project No: 2016.0049.SIDE Page 2 of 2 The PD can use either UST or NCBP requirements to close out an orphan tank. If closure is conducted through the UST Section, PD will submit copies of all reports and correspondence relating to such closure to the NCBP. 2.0 Buried Drums If the GC discovers buried drums of unknown materials at the Property, the PD or the EC will notify DEQ within 48 hours of discovery, if only by email. The EC will evaluate the drums for contents and obvious integrity issues, labeling, etc. Once the EC determines the condition of the drums, they will either be removed immediately for proper offsite disposal or removed from the area and temporarily relocated to a staging area in a designated location of the Property with proper secondary containment for sampling, and proper disposal. The EC will evaluate the soil that surrounds buried drums for stains, odor, organic vapor or other evidence of contamination. Based on field observations, the EC will collect representative post‐ excavation confirmation samples from areas where potentially contaminated soil was excavated for laboratory analysis by the analytical parameters presented above. The EC will provide the PD and the NCBP copies of field-monitoring and analytical data, with recommendations to address contaminated soil, should it be present. 3.0 Buried Waste Materials If buried waste materials are discovered at the Property, the PD or the EC will notify DEQ within 48 hours of discovery, if only by email. The EC will evaluate the material to characterize the nature of the waste material. If buried wastes are encountered, the EC will evaluate the soil that surrounds these features for stains, odor, organic vapor or other evidence of contamination. Based on field observations, the EC will collect representative post‐excavation confirmation samples from areas where potentially-contaminated soil was excavated for laboratory analysis by the analytical parameters presented above. The EC will provide the PD, its contractor, and the NCBP copies of field-monitoring and analytical data, with recommendations to address contaminated soil as applicable.