January 31, 2018

Daniel Graham Hydrogeologist North Carolina Department of Environmental Quality Mooresville Regional Office 610 East Center Avenue Mooresville, North Carolina 28115

RE: Initial Site Assessment Report

Howard Property (Former Howard’s Phillips 66 Service Station) Incident No.: N/A

2435 N NC Highway 16 Business Denver, Lincoln County, North Carolina 28037 Dear Mr. Graham: CES Group Engineers, LLP (CES), on behalf of North State Howard, LLC (North State Howard), is submitting this Initial Site Assessment Report to the North Carolina Department of Environmental Quality (NCDEQ) for the aforementioned property. A hard copy of the report, as well as an electronic copy on a CD, have been enclosed for your records. Should you have any questions in regards to this submittal, please do not hesitate to contact me at (704) 489-1500 x1008. Regards,

Gregory Hans, PMP Environmental Division Manager Enclosures: Initial Site Assessment Report Cc: Shane Seagle, Managing Partner, North State Howard, LLC. David Dupree, Managing Partner, North State Howard, LLC.

274 N HWY 16 BUSINESS, SUITE 300

DENVER, NC 28037

T 704.489.1500

www.ces-group.net

CES Group Engineers, LLP

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CES Project No. 7002.1117ED January 31, 2018

INITIAL SITE ASSESSMENT REPORT

HOWARD PROPERTY (FORMER HOWARD’S PHILLIPS 66)

2435 N NC HIGHWAY 16 BUSINESS

DENVER, NC 28037

Prepared for:

North State Howard, LLC.

16930 West Catawba Avenue, Suite 205

Cornelius, NC 28031

Prepared by:

CES Group Engineers, LLP

274 N NC Highway 16 Business, Suite 300

Denver, NC 28037

January 31, 2018

CES Project No. 7002.1117ED January 31, 2018

TABLE OF CONTENTS Page

1.0 SITE INFORMATION ...................................................................................................... 1

1.1 Site Identification ................................................................................................. 1 1.2 Contact Information ............................................................................................. 1 1.3 Release Information ............................................................................................ 2 1.4 Certification ......................................................................................................... 2

2.0 EXECUTIVE SUMMARY ................................................................................................ 3

3.0 SITE HISTORY AND CHARACTERIZATION ................................................................ 4

3.1 Responsible Party Information ............................................................................ 4 3.2 UST Information .................................................................................................. 5 3.3 Release Description ............................................................................................ 5 3.4 Site Characteristics ............................................................................................. 5 3.5 Receptor Information .......................................................................................... 6

4.0 INITIAL RESPONSE AND ABATEMENT ACTION ........................................................ 7

4.1 Initial Response and Abatement Action .............................................................. 7

5.0 EXCAVATION OF CONTAMINATED SOIL ................................................................... 9

5.1 Source and Estimated Extent of Soil Contamination.......................................... 9 5.2 Contaminated Soil Excavation and Removal ..................................................... 9 5.3 Post-Excavation Soil Sampling and Laboratory Analysis ................................. 10 5.4 Disposal of Contaminated Soil .......................................................................... 11 5.5 Conclusions ....................................................................................................... 11

6.0 CONCLUSIONS ............................................................................................................ 13

6.1 Conclusions ....................................................................................................... 13

CES Project No. 7002.1117ED January 31, 2018

FIGURES

FIGURE 1 1500’ RADIUS AND POTENTIAL RECEPTOR MAP

FIGURE 2 SOIL EXCAVATION AND SAMPLING MAP

TABLES

TABLE B-1 SITE HISTORY – UST/AST SYSTEM AND OTHER RELEASE INFORMATION

TABLE B-2 SITE HISTORY – UST/AST OWNER/OPERATOR AND OTHER RESPONSIBLE PARTY INFORMATION

TABLE B-3 SUMMARY OF SOIL ANALYTICAL RESULTS

APPENDICES

APPENDIX A SITE SPECIFIC HEALTH AND SAFETY PLAN

APPENDIX B PHOTOGRAPHS OF SITE EXCAVATION ACTIVITIES

APPENDIX C SOIL LABORATORY REPORTS AND CHAIN-OF-CUSTODY RECORDS

APPENDIX D SOIL DISPOSAL MANIFESTS

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1.0 SITE INFORMATION

1.1 Site Identification

Date of Report: January 31, 2018 Facility ID: 0-029291 Incident Number: N/A Site Risk: N/A Site Name: Howard Property (Former Howard’s Phillips 66) Site Address: 2435 N NC Highway 16 Business, Denver, NC 28037 Geographical Data Point: Approximate Former Wash Pit Location Method: GIS Address Matching Latitude: 35.506872 Longitude: -81.002876

1.2 Contact Information

UST Owner/Operator: Howard’s 66 Address: 2510 NC Highway 16 North, Denver, NC 28037 Phone: N/A Other Person Associated With Release: North State Howard, LLC (North State)

Address: 16930 West Catawba Avenue, Suite 205, Cornelius, NC 28031

Phone: 704-582-1460 Current Property Owner: North State Howard, LLC (North State)

Address: 16930 West Catawba Avenue, Suite 205, Cornelius, NC 28031

Phone: 704-582-1460 Site Occupant: N/A (Vacant) Address: N/A (Vacant) Phone: N/A (Vacant) Consultant: CES Group Engineers, LLP (CES) Address: 274 N NC Highway 16 Business, Suite 300, Denver, NC 28037 Phone: 704-489-1500 Analytical Laboratory: Prism Laboratories, Inc. (Prism) Address: 449 Springbrook Road, Charlotte, NC 28217 Phone: 704-529-6364 State Certification: NC Certification No. 402 Excavation Contractor: Moore & Seagle Construction, Inc. (Moore & Seagle) Address: 2110 Arney Street, Lincolnton, NC 28092 Phone: 704-735-0037

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1.3 Release Information

Date Discovered: December 1, 2017 Estimated Quantity of Release: Unknown Cause of Release: Unknown Source of Release: Wash Pit UST System(s): None Prior UST System(s): Removed in 1999

1.4 Certification

CES Group Engineers, LLP (CES) is licensed to practice engineering in North Carolina. The firm license number is F-1240. I, Charles D. Heleine, a North Carolina Licensed Professional Engineer employed by CES, do hereby certify that the information contained in this report is accurate, to the best of my knowledge.

Charles D. Heleine, NC PE No. 27196

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2.0 EXECUTIVE SUMMARY

This Initial Site Assessment Report summarizes the initial response and abatement of petroleum hydrocarbons and metal impacts in soil for the suspected historical release from a wash basin (wash pit) at the Howard Property (Former Howard’s Phillips 66 Service Station), located at 2435 N NC Highway 16 Business, Denver, North Carolina (Site). CES Group Engineers, LLP (CES) has been authorized to perform initial response and abatement activities by North State Howard, LLC (North State Howard), represented by David Dupree and Shane Seagle, Managing Members. On November 22, 2017, during demolition related activities associated with the removal of one (1) hydraulic lift and one (1) wash pit located within the service bays of a former gasoline service station, soil samples were screened in the field with a MiniRAE 2000 photoionization detector (PID) and subsequently analyzed for selected petroleum hydrocarbon and metal constituents. Petroleum hydrocarbons, total petroleum hydrocarbon (TPH) diesel range organics (DRO), and metals, lead and chromium, were reported above the North Carolina Department of Environmental Quality (NCDEQ) Initial Action Level for Contamination and the Soil-to-Water Maximum Contaminant Concentration (MSCC), respectively. Upon receipt of laboratory analytical reports indicating that a TPH-DRO concentration of 4,200 milligrams per kilograms (mg/kg) was reported from a soil sample (WP-1) collected from immediately below the removed wash pit, at a depth of approximately one-foot (1) below grade, on November 22, 2017, a series of excavation and removal events were conducted until January 4, 2018, when laboratory analysis of post-excavation soil samples for TPH-DRO and lead were reported below their respective soil standards. As further discussed in Section 4.2 of this report, reported concentrations of chromium from excavated areas were consistent with concentration levels reported from an onsite test pit, located approximately 45 feet from the excavation area. During the series of soil excavation and removal events conducted between November 22, 2017 and January 4, 2018, a total of twenty (20) soil samples were screened in the field with a PID, a total of eighteen (18) soil samples, including one (1) soil sample from the test pit, were collected and submitted for laboratory analysis, and a total of approximately 299.32-tons of soils were transported under non-hazardous waste manifests to CMS Landfill, Concord, NC for landfill disposal. PID readings ranged from non-detect (ND) to 113.0 parts per million per volume (ppmv). Maximum soil concentration levels were reported at 4,200 mg/kg for TPH-DRO, 420 mg/kg for lead, and 61 mg/kg for chromium. Tables B-3 summarizes soil laboratory analytical results. Groundwater, bedrock, and/or free product was not encountered during soil excavation and removal activities, which were completed to a maximum depth of approximate nine (9) feet below grade. No active water supply wells were identified within 1,500 feet of the Site. Figure 1 depicts the 1,500-feet radius and potential receptor map. Based on post-excavation soil sample concentration levels for TPH-DRO and lead reported below their respective soil standards, chromium concentrations reported consistent with background levels, and since groundwater, bedrock and/or free product was not encountered within the excavated area, it is recommended that no further remedial actions are required at this time. This report provides data necessary to fulfill an Initial Site Assessment Report, in accordance with, and formatted in conformance with Appendix A of the Guidelines for Initial Response and Abatement, Assessment, and Corrective Action for Non-UST Releases of Petroleum, effective July 1, 2012.

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3.0 SITE HISTORY AND CHARACTERIZATION

The subject site consists of one (1) parcel, identified as Lincoln County Parcel Identification No. 34124, situated along the west line of N NC Highway 16 Business, as shown on Figure 2. A retail petroleum service station building (identified as Howard’s Phillips 66) with two (2) automotive service bays, that sold gasoline, kerosene and diesel fuel, and reportedly performed automotive service and repairs, was located on the eastern central portion of the subject property, from approximately 1965 until November 2017. One (1) underground hydraulic lift and one (1) underground wash basin (wash pit) were located inside the two (2) automotive service bays. A single family residential structure, reportedly constructed in 1935, and located on the southwestern portion of the subject property, currently remains in place. The retail sale of gasoline, kerosene and diesel fuel were reportedly conducted at the site from approximately 1964 until December 1999. The gasoline, kerosene, and diesel fuel underground storage tank (UST) systems, reportedly consisting of three (3) 6,000-gallon gasoline USTs, one (1) 3,000-gallon kerosene UST, and one (1) 10,000-gallon diesel UST and associated dispensers, were removed from the site in early December 1999. On January 19, 2000, the North Carolina Department of Environment and Natural Resources (NCDENR), issued a letter to Howard’s 66 indicating that based on laboratory analysis from seventeen (17) soil samples collected during the closure of five underground storage tank systems, no further action is required at this time. In July 2017, the subject property was sold in a property transaction from Harold A. Howard, Jr., of Denver, NC, to North State Howard, LLC (North State), of Cornelius, NC. In November 2017, as part of initial site redevelopment activities being performed by North State, the retail petroleum service station building and restrooms were demolished, and the underground hydraulic lift and wash pit were subsequently removed from the subsurface. The former retail petroleum service station building, restrooms, and the existing single-family residential structure were reportedly served by the Lincoln County public water distribution system and sanitary sewer system.

3.1 Responsible Party Information

UST Owner/Operator: Howard’s Phillips 66 Address: 2510 NC Highway 16 North, Denver, NC 28037 Phone: N/A

Other Person Associated With Release: North State Howard, LLC (North State)

Address: 16930 West Catawba Avenue, Suite 205, Cornelius, NC 28031 Phone: 704-582-1460

Current Property Owner: North State Howard, LLC (North State) Address: 16930 West Catawba Avenue, Suite 205, Cornelius, NC 28031 Phone: 704-582-1460 Additional responsible party information is provided in Table B-2, and above in Section 1.2.

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3.2 UST Information

The retail sale of gasoline, kerosene and diesel fuel were reportedly conducted at the site from approximately 1964 until December 1999. The gasoline, kerosene, and diesel fuel UST systems, reportedly consisting of three (3) 6,000-gallon gasoline USTs, one (1) 3,000-gallon kerosene UST, and one (1) 10,000-gallon diesel UST and associated dispensers, were removed from the site in early December 1999. Procedural details of the 1999 closure were summarized to the NCDENR in a January 13, 2000 tank closure report. On January 19, 2000, NCDENR issued a letter to Howard’s 66 indicating that based on laboratory analysis from seventeen (17) soil samples collected during the closure of five underground storage tank systems, no further action is required at this time. Approximate orientation of the former USTs, as derived from other sources, are depicted on Figure 2. Currently available information concerning the previously removed USTs at the site is summarized in Tables B-1 and B-2.

3.3 Release Description

Soil contamination was discovered during demolition related activities associated with the removal of the underground hydraulic lift and wash pit located inside the former automotive service bays. Following receipt of laboratory analytical data for collected soil samples on November 22, 2017, indicating TPH levels equal to or greater than the Initial Action Level for Contamination of one-hundred (100) mg/kg, a release was reported to Mr. Daniel Graham, NCDEQ, on December 4, 2017. Specifically, a soil sample (WP-1) collected from immediately below the former wash pit, at a depth of approximately one (1) foot below grade, reported a TPH - DRO concentration of 4,200 mg/kg. Procedural details on the removal of the underground hydraulic lift and wash pit, field screening and laboratory analysis of collected soil samples, and subsequent over-excavation and removal of contaminated soils for offsite disposal are further discussed in Sections 4.0 and 5.0 of this report.

3.4 Site Characteristics

The subject real property, zoned for PD-R (Planned Development Residential) use, includes one parcel, with Lincoln County Parcel Identification Number 34124, occupying a total area of approximately ninety-one hundredths (0.91) acre. Prior to demolition and removal in November 2017, site improvements included an approximately two-thousand two-hundred and eighty-four (2,284) square feet, single story, slab-on-grade building housing the retail petroleum service station and automotive repair facility, built in 1965, and a forty (40) square feet restroom structure built in 1985, with asphalt paving, gravel-surfaced drives and parking areas, and appurtenances. Additionally, an approximately eight-hundred and sixty-eight (868) square foot single-family residential structure, built in 1935, currently remains on the western portion of the site. The retail petroleum service station building and automotive repair facility was formerly utilized by the previous property owner(s), members of the Howard family, until approximately December 1999, and the entire site is currently unoccupied and planned for future residential development. The site is situated in an unincorporated area of Lincoln County, situated along the west line of N NC Highway 16 Business, a two (2)-lane, asphalt surfaced, rural section roadway. The subject site

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is served by electrical and natural gas public utilities, as well as water distribution and sanitary sewer services provided by Lincoln County. The subject site is situated in an area of mixed commercial, agricultural and residential land use. Adjacent down-gradient land to the west of the site is an approximately fifty (50) acre tract that is currently undeveloped, with planned residential development in the future. The site location in relation to area land use is illustrated in Figures 1 and 2.

3.5 Receptor Information

Water Supply Wells: No active drinking water supply wells were identified within 1,000 feet of the subject site.

Public Water Supplies: No public water supplies were identified within 1,500 feet of the subject site. The Lincoln County public water distribution system is available at the site.

Surface Water: No surface water bodies were identified within 500 feet of the site.

Wellhead Protection Areas: Per the NCDEQ website, no wellhead protection areas are in Lincoln County.

Deep Aquifers in the Coastal Plain Physiographic Region: Not Applicable to the subject site.

Subsurface Structures: Underground utilities have been identified at and adjacent to the subject site. During the excavation and removal activities associated with the former hydraulic lift and wash pit, no underground utilities were identified within the excavated areas. Groundwater was not measured during this initial assessment and abatement action, with the exception of measuring groundwater from a presumably old monitoring well, located on the northeastern portion of the subject property, between the excavated area and N NC Highway 16 Business. On November 27, 2017, a depth to groundwater measurement from this well was recorded at 5.10 feet below ground surface. However, since construction details of this presumably old monitoring well were not available, and the well did not contain a locking j-plug on top of the PVC riser nor a protective cover, it is unknown if this measurement is representative of actual subsurface groundwater depths. As referenced in Section 2.0 of this report, groundwater was not encountered during soil excavation and removal activities, completed to a maximum depth of approximately nine (9) feet below grade. With the exception of the removed hydraulic lift, wash pit, and concrete structure, no other subsurface structures have been identified at the site.

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4.0 INITIAL RESPONSE AND ABATEMENT ACTION

4.1 Initial Response and Abatement Action

During demolition related activities associated with the removal of the underground hydraulic lift and wash pit located inside the former automotive service bays on November 22, 2017, a PID reading of 113.0 ppmv was recorded from a soil sample (WP-1) collected from immediately below the removed wash pit, at a depth of approximately one (1) foot below grade. Based on this PID result, it was determined that activities associated with the over-excavation and removal of a limited amount of soils from the general vicinity of the former wash pit were warranted in an attempt to remove potentially contaminated soils from the subsurface. On November 22, 2017, soils from the area surrounding the former wash pit, an area approximately fifteen (15) feet by fifteen (15) feet to an approximate depth of four and a half (4.5) feet, were excavated, temporarily stockpiled onsite, and returned to the excavated area awaiting future offsite disposal, and a total of six (6) post-excavation soil samples were collected and submitted to Prism Laboratories, Inc. (Prism), of Charlotte, NC for laboratory analysis of TPH-DRO and TPH-gasoline range organics (GRO) by EPA Method 8105C, and lead and chromium by EPA Method 6010D. Prior to laboratory submittal, soil samples were screened in the field with a PID, which recorded readings ranging from ND to 113.0 ppmv, collected from soil sample WP-1. Additionally, on November 22, 2017, the hydraulic lift, located approximately seventeen (17) feet to the south of the former wash pit, was excavated and removed from the subsurface. During the removal of the hydraulic lift, the dimensions from the excavated area of the wash pit were temporarily extended to the hydraulic lift area, to a depth of approximately nine (9) feet below grade, and one (1) post-excavation soil sample was collected from immediately below the base of the hydraulic lift, and submitted to Prism for laboratory analysis of TPH-DRO. Prior to laboratory submittal, the one (1) soil sample was screened in the field with a PID and recorded a reading of ND. During soil excavation and removal activities on November 22, 2017, a drain pipe from immediately below the former wash pit was observed to extend approximately twenty (20) feet to the northeast where a subsurface concrete structure was observed. Due to time restraints on November 22, 2017, the extent of soil excavation was terminated on the southern side of this concrete structure, which extended the overall excavated area by approximately twelve (12) feet by six (6) feet, and it was determined that further exploration of this concrete structure would occur the week of November 27, 2017. Further evaluation of the drain pipe and concrete structure reported the drain pipe extending from the north side of the concrete structure towards, and underneath, N NC Highway 16 Business. Following receipt of laboratory analytical data for collected soil samples on November 22, 2017, indicating TPH levels equal to or greater than the Initial Action Level for Contamination of one-hundred (100) mg/kg, a release notification was reported to Mr. Daniel Graham, NCDEQ, on December 4, 2017. At this time, additional soil sampling and laboratory analysis requirements, and the planned continuation of over-excavation activities at the site, including the excavation of a test pit outside the area of concern, due to reported concentrations of lead and chromium, were discussed with Mr. Graham. Further procedural details of subsequent field screening, laboratory analysis, and over-excavation activities are further discussed in Section 5.0 of this report.

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Based on the recorded PID readings, visual and olfactory observations, no free product observed, and no occupied structures in the immediate vicinity of the site, no fire, explosive and/or vapor hazards were determined to be present.

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5.0 EXCAVATION OF CONTAMINATED SOIL

5.1 Source and Estimated Extent of Soil Contamination

The source of soil contamination encountered during activities conducted from November 22, 2017 through January 4, 2018 at the site, is believed to be related to the former wash pit located inside the service bay of the former retail petroleum and automotive repair facility. Based on laboratory analysis from post-excavation soil samples, as further discussed in Sections 5.2 and 5.3, the extent of soil contamination in relation to the former wash pit is estimated to be limited to the extents of the final excavated area.

5.2 Contaminated Soil Excavation and Removal

As previously discussed in Section 4.1, upon discovery of the wash pit drain pipe extending approximately twenty (20) feet to the northeast where a subsurface concrete structure was observed, and following receipt of laboratory analytical results from soil samples collected on November 22, and 27, 2017, reporting concentrations of TPH-DRO, lead and chromium above their applicable soil standards, the continuation of soil over-excavation activities were planned and communicated to Mr. Graham at NCDEQ on December 4, 2017. Moore & Seagle Construction, Inc. (Moore & Seagle) were contracted by North State to perform the soil excavation and removal activities. CES was contracted by North State to perform soil field screening, sampling for laboratory analysis, and required regulatory agency reporting during the soil excavation and removal activities. On December 19, and 21, 2017, the horizontal and vertical extents of the previous excavated areas were extended to an approximate area of twenty-five (25) feet by forty-five (45) feet to a depth of approximately seven (7) feet below grade, minus the northwest corner which encompassed an area of approximately eleven (11) feet by thirteen (13) feet, to facilitate the collection of additional soil samples for PID screening and laboratory analysis, and approximately 237.25-tons of soils from within this excavated area were live loaded onto trucks and transported under non-hazardous waste manifests to the CMS Landfill, in Concord, NC for landfill disposal. Additionally, on December 21, 2017, a small test pit was excavated to a depth of approximately three and a half (3.5) feet below grade, located approximately forty-five (45) feet to the southwest of the wash pit excavation area, to compare concentration levels of lead and chromium reported from outside the area of concern to concentration levels reported from the wash pit excavation area. Excavated soils from this test pit area were returned to the subsurface upon sample collection. On January 4, 2018, the horizontal and vertical extents of the eastern sidewall were extended by approximately ten (10) feet by fifteen (15) feet to an approximate depth of seven (7) feet below grade, to facilitate the collection of additional soil samples for PID screening and laboratory analysis, and approximately 62.07-tons of soil from within this additional excavated area were live loaded onto trucks and transported under non-hazardous waste manifests to the CMS Landfill, in Concord, NC for landfill disposal. During the soil excavation and removal events, soils were classified as a light-medium brown, fine- medium coarse silt with some clay. Groundwater, bedrock, and/or free product was not encountered within the excavated area, to a maximum depth of approximately nine (9) feet below grade. A copy of the Site-Specific Health and Safety Plan (HASP), utilized by CES and CES subcontracted

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personnel while onsite, is attached as Appendix A. Photographic documentation of the soil excavation and removal events are included in Appendix B. Figure 2 depicts the final excavated area, an irregular area approximately twenty-five (25) feet by forty-five (45) feet to a depth of approximately seven (7) feet below grade, with an extension of approximately ten (10) feet by fifteen (15) feet area on the eastern sidewall, minus the northwest corner which encompassed an area of approximately eleven (11) feet by thirteen (13) feet.

5.3 Post-Excavation Soil Sampling and Laboratory Analysis

During soil excavation and removal events conducted between November 22, 2017 and January 4, 2018, a total of eighteen (18) post-excavation soil samples were collected and submitted to Prism for laboratory analysis of TPH-DRO, TPH-GRO, lead and/or chromium. Additional soil samples were collected and analyzed for disposal facility parameters, including benzene, toluene, ethylbenzene and xylenes (BTEX), RCRA Metals and TCLP Lead. On November 22, 2017, a total of seven (7) post-excavation soil samples were collected and submitted to Prism for laboratory analysis of TPH-DRO, TPH-GRO, lead and/or chromium. A review of soil analytical results from soil samples collected on November 22, 2017 reported the following concentrations above applicable soil standards:

• TPH-DRO from a soil sample collected from WP-1, with a concentration of 4,200 mg/kg, was reported above the Initial Action Level for Contamination; and

• Chromium from soil samples collected from WP-1 and WP-2, with a maximum concentration of 30 mg/kg, were reported above the MSCC.

A review of soil laboratory analytical results from the soil sample (Hyd-1) collected on November 22, 2017, from the base of the removed hydraulic lift, reported TPH-DRO concentrations below laboratory detection limits (BDL). On November 27, 2017, a total of two (2) post-excavation soil samples were collected and submitted to Prism for laboratory analysis of TPH-DRO, TPH-GRO, lead and/or chromium. A review of soil analytical results from soil samples collected on November 27, 2017 reported the following concentrations above applicable soil standards:

• TPH-DRO from a soil sample collected from WP-10, with a concentration of 630 mg/kg, was reported above the Initial Action Level for Contamination;

• Lead from a soil sample collected from WP-9, with a concentration of 420 mg/kg, was reported above the MSCC; and

• Chromium from a soil sample collected from WP-9, with a concentration of 35 mg/kg, was reported above the MSCC.

On December 19, 2017, a total of three (3) post-excavation soil samples were collected and submitted to Prism for laboratory analysis of TPH-DRO, lead and/or chromium. A review of soil analytical results from soil samples collected on December 19, 2017 reported the following concentrations above applicable soil standards:

• Chromium from soil samples collected from WP-8A, WP-9A, and WP-10A, with a maximum concentration of 30 mg/kg, were reported above the MSCC.

On December 21, 2017, a total of five (5) post-excavation soil samples were collected and submitted

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to Prism for laboratory analysis of TPH-DRO, lead and/or chromium. A review of soil analytical results from soil samples collected on December 21, 2017 reported the following concentrations above applicable soil standards:

• TPH-DRO from a soil sample collected from WP-5A, with a concentration of 180 mg/kg, was reported above the Initial Action Level for Contamination; and

• Chromium from soil samples collected from WP-2A, WP-3A, WP-5A, WP-7A, and TP-1, with a maximum concentration of 61 mg/kg, were reported above the MSCC.

On January 4, 2018, one (1) post-excavation soil samples was collected from the over-excavated area near WP-5A, and submitted to Prism for laboratory analysis of TPH-DRO. A review of soil analytical results from the soil sample collected January 4, 2018 reported TPH-DRO concentrations below the Initial Action Level for Contamination. As previously reported, a small test pit was excavated to a depth of approximately three and a half (3.5) feet below grade, located approximately forty-five (45) feet to the southwest of the wash pit excavation area, to compare concentration levels of lead and chromium reported from outside the area of concern to concentration levels reported from the wash pit excavation area. A review of laboratory analytical reports indicated that a concentration of 53 mg/kg was reported from the soil sample (TP-1) collected from the test pit. Based on reported chromium concentrations from the wash pit excavation area, ranging from 22 mg/kg to 61 mg/kg, the concentrations of chromium from within the excavated area are consistent with the concentration reported from outside the excavated area. As such, similar concentration levels of chromium in soils would be expected to be encountered throughout the subject property and in the general area, and therefore, are deemed to be consistent with background levels, and not associated with an apparent release from the wash pit. It should be noted that during site related activities associated with the removal of the hydraulic lift and wash pit, and subsequent soil excavation and removal activities with soil field screening and sampling for laboratory analysis, representatives of ATC Group Services, LLC were onsite on behalf of a third party, in an agreement between the current property owner, North State, and the said third party, and collected soil samples for field screening and laboratory analysis from similar locations as discussed in this section. A summary of soil analytical results are included in Table B-3. Soil laboratory analytical reports and chain-of-custodies are attached as Appendix C.

5.4 Disposal of Contaminated Soil

On December 19 and 21, 2017, and January 4, 2018, the onsite excavation contractor, Moore & Seagle, in their contractual agreement with North State, coordinated the transportation and disposal of approximately 299.32-tons of soils to the CMS Landfill of Concord, NC for landfill disposal under non-hazardous waste manifests. Copies of soil disposal manifests are included in Appendix D.

5.5 Conclusions

During a series of soil excavation and removal events conducted between November 22, 2017 and January 4, 2018, a total of twenty (20) soil samples were screened in the field with a PID, a total of eighteen (18) soil samples, including one (1) soil sample from the excavated test pit, were collected

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and submitted for laboratory analysis, and a total of approximately 299.32-tons of soils were transported under non-hazardous waste manifests to the CMS Landfill of Concord, NC for landfill disposal. A review of final post-excavation soil laboratory analytical indicated that collected soil samples for TPH-DRO and lead were reported below their respective soil standards, and that chromium concentrations were reported consistent with background levels. During the soil excavation and removal events, to a maximum depth of approximately nine (9) feet below grade, groundwater, bedrock, and/or free product were not encountered.

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6.0 CONCLUSIONS

6.1 Conclusions

Based on final post-excavation soil sample concentration levels for TPH-DRO and lead reported below the NCDEQ Initial Action Limit for Contamination, and the MSCC, respectively, chromium concentrations reported consistent with background levels, and since groundwater, bedrock and/or free product was not encountered within the excavated area, it is recommended that no further remedial actions are necessary at this time.

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TABLES

2 Gasoline Unknown 6,000 Unknown Unknown Unknown 1964

Removed in

December

1999

No

(Assumed)

3 Gasoline Unknown 6,000 Unknown Unknown Unknown 1964

Removed in

December

1999

No

(Assumed)

4 Kerosene Unknown 3,000 Unknown Unknown Unknown 1964

Removed in

December

1999

No

(Assumed)

Incident

Number

Material

ReleasedDate of Release

N/A Petroleum Unknown

* Gasoline (unleaded or leaded), diesel, used oil, waste oil, aviation fuel, etc., or pesticides, non-halogenated or halogenated solvents, etc.

** Fiberglass (single- or double-walled), steel (single- or double-walled), steel with FRP (single- or double-walled), steel with liner, other, unknown.

*** Currently operational, not in use or temporarily closed (specify date), permanently closed in place (specify date), permanently closed by removal (specify date)

Table B-1

Site History - UST/AST System and Other Release Information

Howard Property (Former Howard's Phillips 66)

2435 N NC Highway 16 Business

Denver, NC 28037

Tank Dimensions

Description of

Associated Piping

and Pumps

Date Tank

Installed

Status of AST

***

Was release

associated with

the AST

System?

Description of Release

Release is expected to have occurred during operational use of the wash pit, for an unknown period of

time

AST ID

Number

Current/Last

Contents *

Previous

Contents *

Capacity (in

gallons)

Construction

Details **

Unknown 1964

Removed in

December

1999

No

(Assumed)

5 Diesel Unknown 10,000 Unknown Unknown Unknown 1964

Removed in

December

1999

No

(Assumed)

Description of

Associated Piping

and Pumps

Date Tank

Installed

Status of UST

***

Was release

associated with

the UST

System?

1 Gasoline Unknown 6,000 Unknown Unknown

UST ID

Number

Current/Last

Contents *

Previous

Contents *

Capacity (in

gallons)

Construction

Details **Tank Dimensions

2

3

4

State Zip

NC 28037

State Zip

NC 28037

State Zip

NC 28031

*: Based on information obtained during environmental assessments, it is believed that the USTs

were owned and operated by members of the Howard family and Harold A. Howard, Jr.

has owned the property for approximately 20 years, and may not of been

listed as the registered tank owner/operator during periods of operation

16930 West Catawba Avenue, Suite 205

City Telephone Number

Cornelius 704-582-1460

Name of Other Responsible PartyDates of Release(s)

(mm/dd/yy to mm/dd/yy)

North State Howard, LLC. Unknown

Street Address

Denver N/A

Incident

Number N/A

Harold A. Howard, Jr. 1964 to 1999

Street Address

2510 NC Highway 16 North

City Telephone Number

2510 NC Highway 16 North

City Telephone Number

Denver N/A

Name of Operator*Dates of Operation

(mm/dd/yy to mm/dd/yy)

Name of Owner*Dates of Operation

(mm/dd/yy to mm/dd/yy)

Harold A. Howard, Jr. 1964 to 1999

Street Address

Table B-2

Site History - UST/AST Owner/Operator and Other Responsible Party Information

Howard Property (Former Howard's Phillips 66)

2435 N NC Highway 16 Business

Denver, NC 28037

UST ID

Number

1

Facility ID Number 0-029291

5

8015C 8015C 6010D 6010DDisposal

(7471B)

Disposal

(6010D)

Disposal

(6010D)

Disposal

(6010D)

Disposal

(6010D)

Disposal

(6010D)

Disposal

(6010D)

Disposal

(6010D)

Disposal

(8260B)

Disposal

(8260B)

Disposal

(8260B)

Disposal

(8260B)

Disposal

(8260B)

Sample ID

Date

Collected

(m/dd/yy)

Source Area

(eg. Wash

pit)

Sample

Depth (feet

BGS)

PID

(ppmv)

WP-1 11/22/17 Wash pit 1' 113.0 4200 33 71 30 0.051 11 87 BDL 30 71 BDL BDL BDL BDL BDL BDL BDL

WP-2 11/22/17 Wash pit 4.5' 0.0 BDL BDL 35 22 NA NA NA NA NA NA NA NA NA NA NA NA NA

WP-2A 12/21/17 Wash pit 7' 6.0 BDL NA 35 25 NA NA NA NA NA NA NA NA NA NA NA NA NA

WP-3 11/22/17 Wash pit 3.5' 0.0 BDL BDL NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA

WP-3A 12/21/17 Wash pit 6' 13.6 60 NA 140 33 NA NA NA NA NA NA NA NA NA NA NA NA NA

WP-4 11/22/17 Wash pit 2' 18.2 NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA

WP-5 11/22/17 Wash pit 3' 0.0 BDL BDL NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA

WP-5A 12/21/17 Wash pit 6' 9.98 180 NA 35 24 NA NA NA NA NA NA NA NA NA NA NA NA NA

WP-5B 1/4/18 Wash pit 7' 0.0 BDL NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA

WP-6 11/22/17 Wash pit 3' 0.0 NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA

Hyd-1 11/22/17 Hyd lift 9' 0.0 BDL NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA

WP-7 11/22/17 Wash pit 4' 3.0 60 BDL NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA

WP-7A 12/21/17 Wash pit 6' 9.0 BDL NA 55 61 NA NA NA NA NA NA NA NA NA NA NA NA NA

WP-8 11/22/17 Wash pit 4' 24.6 21 BDL NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA

WP-8A 12/19/17 Wash pit 6' 3.7 BDL NA 32 30 NA NA NA NA NA NA NA NA NA NA NA NA NA

WP-9 11/27/17Add'l

structure5' 0.0 79 BDL 420 35 NA NA NA NA NA NA NA NA NA NA NA NA NA

WP-9A 12/19/17Add'l

structure6' 4.7 BDL NA 38 28 NA NA NA NA NA NA NA NA NA NA NA NA NA

WP-10 11/27/17Add'l

structure3' 0.0 630 BDL NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA

WP-10A 12/19/17Add'l

structure6' 0.9 BDL NA 43 28 NA NA NA NA NA NA NA NA NA NA NA NA NA

WP-11 1/4/18 Wash pit 7' 0.0 NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA

WP-12 1/4/18 Wash pit 7' 0.0 NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA

TP-1 12/21/17 Background 3.5' NA NA NA 47 53 NA NA NA NA NA NA NA NA NA NA NA NA NA

100 50 NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA

NA NA 270 5.4 NA NA 290 NA 5.4 270 NA NA 0.0056 4.9 4.6 4.6 4.3

NA NA 400 47 NA NA 3100 NA 47 400 NA NA 18 1560 3129 3129 1200

Initial Action Levels for Contamination (mg/kg): Table 1 - Guidelines for Initial Response and Abatement, Assessment, and Corrective

Action for Non-UST Releases of Petroleum (July 1, 2012)

Soil-to-Water Maximum Contaminant Concentration (mg/kg): Table 1 - Guidelines for Initial Response and Abatement, Assessment, and Corrective

Action for Non-UST Releases of Petroleum (July 1, 2012)

Residential Soil Cleanup Levels (mg/kg): Table 1 - Guidelines for Initial Response and Abatement, Assessment, and Corrective

Action for Non-UST Releases of Petroleum (July 1, 2012)

Feet BGS = feet below ground surface

mg/kg =milligrams per kilogram

ppmv: parts per million per volume as detected by MiniRAE2000 photoionization detector (PID)

BDL = Below Laboratory Detection Limit

NA = Not applicable

Bold = Values exceeding the Initial Action Level for Contamination and/or Soil-to-Water MCC

Soil sample locations WP-4, WP-6, WP-11 and WP-12 were field screened only with a PID, and not submitted for laboratory analysis

Yellow Highlighted Lines = Soils in designated soil sample area were over-excavated and transported for offsite disposal on 12/19/17, 12/21/17 and 1/4/18

Analytical Method (e.g., TPH - DRO by EPA 8015C)

Contaminant of Concern (mg/kg)

TP

H -

DR

O

TP

H -

GR

O

Mer

cury

To

tal

Ch

rom

ium

Ben

zen

e

Eth

ylb

enze

ne

m.p

-Xy

len

es

o-X

yle

ne

To

luen

e

Sil

ver

Soil-to-Water Maximum Contaminant Concentration

(mg/kg)

Residential Soil Cleanup Levels (mg/kg)

Lea

d

Ars

enic

Initial Action Level for Contamination (mg/kg)

Bar

ium

Cad

miu

m

Ch

rom

ium

Lea

d

Sel

eniu

m

Table B-3

Summary of Soil Analytical Results

Howard Property (Former Howard's Phillips 66)

2435 N NC Highway 16 Business

Denver, NC 28037

APPENDIX A

ENVIRONMENTAL MANAGEMENT AND HEALTH AND SAFETY

PLAN

Howard Property

2435 N NC Highway 16 Business

Denver, NC

Prepared by:

CES GROUP ENGINEERS, LLP

274 N. Hwy. 16, Suite 300

Denver, NC 28037

November 17, 2017

TABLE OF CONTENTS

Page

1.0 INTRODUCTION 1

1.1 PURPOSE/OBJECTIVE 1

1.2 RESPONSIBILITIES FOR HEALTH AND SAFETY 2

1.3 SUBCONTRACTOR’S RESPONSIBILITY 2

2.0 ASSIGNMENT OF RESPONSIBILITY 3

2.1 SITE SAFETY OFFICER 3

2.2 PROJECT MANAGER 4

3.0 BACKGROUND AND HAZARD EVALUATION 5

3.1 PROJECT DESCRIPTION 5

3.2 HAZARD EVALUATION 7

3.3 SAFETY DATA SHEETS (SDS) 7

4.0 AIR MONITORING 8

4.1 MONITORING EQUIPMENT 8

4.2 TYPES AND FREQUENCY OF MONITORING 9

4.2.1 Breathing Zone Monitoring 9

4.2.2 Explosive Gas Source Monitoring 9

4.2.3 Work Area Monitoring 9

4.2.4 Dust Monitoring 9

4.3 ACTION LEVELS 10

5.0 PERSONAL PROTECTIVE EQUIPMENT AND PROCEDURES 10

5.1 RESPIRATORY PROTECTION 10

5.2 PROTECTIVE CLOTHING 11

5.3 LEVELS OF PROTECTION 12

5.3.1 Modified Level D 12

5.3.2 Level D Protection 12

5.3.3 Level C Protection 13

5.3.4 Level B Protection 13

6.0 SITE CONTROL 14

6.1 REGULATED AREAS 14

6.2 ACCESS/SITE SECURITY 15

6.3 POSTING/BARRICADES 15

i

Page

7.0 POLICIES 16

7.1 GENERAL WORK PRACTICES 16

7.2 HEAVY EQUIPMENT OPERATION 17

7.3 SANITATION 18

8.0 DECONTAMINATION 19

8.1 PERSONAL DECONTAMINATION 20

8.2 EQUIPMENT DECONTAMINATION 22

9.0 TRAINING 22

9.1 BASIC TRAINING 22

9.2 SITE-SPECIFIC TRAINING 22

10.0 HEALTH MONITORING 23

10.1 PHYSICAL EXAMINATION 23

10.2 HEAT STRESS 23

10.3 SELF MONITORING 25

11.0 SITE STANDARD OPERATING PROCEDURES 25

11.1 WORK PRACTICES 25

11.2 COMMUNICATION PROCEDURES 27

12.0 EMERGENCY PROCEDURES 28

12.1 GENERAL 28

12.2 RESPONSIBILITIES 28

12.3 EMERGENCY CONTACT LIST 29

12.4 PERSONNEL INJURY IN THE EXCLUSION ZONE 30

12.5 PERSONNEL INJURY IN THE SUPPORT ZONE 30

12.6 FIRE OR EXPLOSION 30

12.7 PERSONAL PROTECTIVE EQUIPMENT FAILURE 30

12.8 POLLUTANT DISCHARGES/SPILLS 31

APPENDIX A Safety Data Sheet (Benzene)

APPENDIX B Emergency Phone Numbers

APPENDIX C Route to Hospital

ii

ENVIRONMENTAL MANAGEMENT AND HEALTH AND SAFETY PLAN (EMP)

Howard Property

2435 N NC Highway 16 Business

Denver, NC

1.0 INTRODUCTION

This Environmental Management and Health and Safety Plan (EMP), additionally referred to as

the ‘plan”, has been developed for CES Group Engineers, LLP (CES), for application to work

completed at the Howard Property, located at 2435 N NC Highway 16 Business, Denver, North

Carolina. Additionally, this plan should also be utilized for any work completed at surrounding

properties where groundwater monitoring wells may be located. For the purpose of this plan,

the term “excavation” will include, but is not limited to, soil excavation, drilling soil boring,

monitoring wells and/or remedial recovery wells, trenching and injections. The plan addresses

health and safety procedures and information relevant to both land surveying services and

environmental services by CES personnel, and/or subcontracted personnel. The health and

safety portion of the plan provides procedures to minimize: (1) the potential for accidents from

physical hazards, and (2) the potential for exposure to chemical contaminants during activities

which disturb the subsurface materials in the event that contamination of soil or groundwater by

special wastes is encountered. The Project Manager, assisted by the assigned Site Safety

officer, will ensure that all on-site subcontractor personnel, and site visitors, comply with the

specified health and safety requirements. At least one copy of this EMP will be maintained at

the local office of CES, as well as one copy will be maintained onsite by CES, and/or

subcontracted personnel.

1.1 PURPOSE / OBJECTIVE

The protection of workers and environmental safety and health are major concerns during this

project and cannot be understated. The objective of the EMP is to document procedures and

precautions to be implemented during site assessment, monitoring and/or remediation activities

associated with the demolition and removal of an underground hydraulic lift and wash pit, in

order to provide for and promote safe working conditions at the site during field activities,

specifically at locations where contamination of soil and groundwater has been documented

and/or is expected to be encountered. The safety organization and procedures have been

established based on a previous analysis of potential hazards at the site. Personal protection

measures have been selected in response to these potential hazards.

This EMP and HASP has also been developed based upon review of the requirements

described in the U.S. Environmental Protection Agency (USEPA) Standard Operating Safety

Guide and the U.S. Department of Labor OSHA standards 29 CFR Part 1910. Reasonable

precautions will be taken by the contractor’s representative and its subcontractors to provide for

and promote the

1

safety and health of workers and the general public. Subcontractors will be given copies and

will be required to follow this EMP.

1.2 RESPONSIBILITIES FOR HEALTH AND SAFETY

All site activities which have the potential to expose personnel to site contamination or a related

injury are subject to this EMP. Personnel will be responsible for adherence to the safety

procedures during the performance of the work. In no case may work be performed in a

manner that conflicts with the intent of, or the inherent safety and environmental cautions

expressed in, these procedures. Following due warning(s), personnel who violate safety

procedures will be dismissed from the site, and may be terminated. In the event that

contamination is encountered during regular construction operations, personnel will be

exclusively employed in the affected area of the project site, who have been properly trained in

health and safety regulations associated with handling hazardous materials or special wastes

as specified in the training section (Section 9.0) of this EMP.

The requirements provided herein may be modified as the work progresses to accommodate

changing conditions, but a reduction or increase in the health and safety requirements will not

be made without prior approval by the assigned Site Safety Officer (SSO). The prevention of

adverse health effects and injuries to site workers is totally dependent on the contribution of all

project participants. Open communication among workers, supervisors, and management

concerning safety at the site is an essential element of this EMP.

1.3 SUBCONTRACTOR’S RESPONSIBILITY

The Subcontractor is solely responsible for the health, safety, and protection of their own on-

site personnel during the performance of the survey and/or environmental services work scope.

The Subcontractor will perform the work specified in the contract documents in accordance

with the HEALTH AND SAFETY REQUIREMENTS specified herein, and federal, OSHA, state,

and local health and safety regulations. It will be the responsibility of the Subcontractor to be

familiar with the required health and safety regulations in the performance of this work. The

Subcontractor will designate a Site Safety officer to implement and monitor activities related to

this EMP.

2

Should any unforeseen or site-specific safety-related factor, hazard, or condition become

evident during the performance of the work, the Subcontractor will take immediate and prudent

action to establish and maintain safe working conditions and to safeguard site personnel, the

public, and the environment.

2.0 ASSIGNMENT OF RESPONSIBILITY

All site activities which have the potential to expose CES personnel to site contamination or

related injury are subject to this EMP. As previously discussed, all site personnel are

responsible for adherence to the safety procedures during performance of the work. Specific

oversight responsibilities are assigned to various personnel as discussed in the paragraphs to

follow.

2.1 SITE SAFETY OFFICER

The SSO will be assigned to monitor the daily activities to assure that all health and safety

procedures/policies are being followed by CES personnel. This includes communicating the

specific requirements to all personnel, including subcontractors, implementing the EMP,

conducting site inspections to monitor compliance with EMP, providing or coordinating training

as required, coordinating the medical monitoring program, coordinating respirator fit tests as

required, coordinating the acquisition, calibration and maintenance of air monitoring equipment,

respirators and other safety equipment, directing on-site health and safety activities, and

reporting safety related incidents or accidents to the Project Manager.

The SSO for this project is: Greg Hans, PMP

CES Group Engineers, LLP

274 N. Hwy. 16 Business, Suite 300

Denver, NC 28037

704.489.1500

3

2.2 PROJECT MANAGER(s)

The project manager is ultimately responsible for ensuring that all project participants abide by

the requirements set forth in this plan. Any and all changes in the scope of health and safety

requirements or site characterization will be communicated from the Project Manager to the

SSO.

Survey Project Manager: Kent Hudson, PLS

CES Group Engineers, LLP

274 N. Hwy. 16 Business, Suite 300

Denver, NC 28037

704.489.1500

Environmental Project Manager: Greg Hans, PMP

CES Group Engineers, LLP

274 N. Hwy. 16 Business, Suite 300

Denver, NC 28037

704.489.1500

4

3.0 BACKGROUND AND HAZARD EVALUATION

3.1 PROJECT DESCRIPTION

This project, involves the assessment, monitoring and remediation of soil during the demolition

of a subsurface hydraulic lift and wash pit. Future activities at the site may include, but are not

limited to soil and groundwater sampling, installation of monitoring and/or recovery wells,

surveying, pilot and slug testing, soil excavation and removal, trenching, installation of

subsurface piping and remedial system components, installation of mechanical remedial system

housed in an onsite trailer, shed or other structure, and injection of in-situ chemical oxidation

materials. During the completion of the aforementioned activities, heavy equipment and

machinery, such as drilling rigs, excavators, back-hoes, dump trucks, etc may be utilized and

present onsite.

5

3.2 HAZARD EVALUATION

Constant attention will be given to physical hazards encountered during work day activities,

particularly those activities associated with heavy equipment such as drilling, trenching and

earthmoving equipment. An evaluation of the potential hazards associated with site activities

has been completed utilizing site history. The following potential exposure pathways have been

identified:

· Dermal contact, inhalation and ingestion of contaminated soils and

groundwater;

· Inhalation and ingestion of contaminated vapors and particles;

· Ingestion of waste solids (accidental/poor hygiene);

· Dermal contact with waste solids.

Given the scope of work and the physical properties of the contaminants present at the site,

there is a potential respiratory hazard. There is also a contact hazard from volatile organic

compounds (VOCs). A respiratory hazard from dust and contaminated dust particles may also

exist during drilling, excavation and trenching activities.

It is recognized that site hazard evaluation is a dynamic and on-going process that changes on

a daily basis during progression of the work. However, significant deviation from the prescribed

site characterization will necessitate re-evaluation and possible EMP revision. Communication

from the SSO will initiate the re-evaluation process by the Project Manager.

3.3 SAFETY DATA SHEETS (SDS)

Consistent with 29 CFS 1910.1200, (Hazard Communication Standard) applicable Safety Data

Sheets (or equivalent) will be kept on-site, in each vehicle, and with the Project Manager. All

subcontractors must ensure that their employees are informed of their rights and responsibilities

under the OSHA Hazard Communication Standard. Subcontractors will provide SDS sheets for

items which they bring on the site, as applicable. Due to the presence of VOCs, a SDS for

benzene (prepared by Total Petrochemicals & refining USA, Inc, dated 4/28/2015), as the

potential maximum VOC concentration encountered onsite, has been included as Appendix A.

6

4.0 AIR MONITORING

The purpose of air monitoring during construction is to identify and quantify airborne

contaminants to determine the level of protection needed. Air monitoring with direct reading

instruments will be conducted during all intrusive activities. Four categories of air monitoring

will be conducted as follows:

· Breathing Zone Monitoring;

· Explosive Gas Source Monitoring;

· Work Area Monitoring; and

· Dust Monitoring.

Equipment to be used in conducting air monitoring activities, along with a description of the type

and frequency of monitoring and associated action levels are discussed in the paragraphs to

follow.

4.1 MONITORING EQUIPMENT

The breathing zone will be monitored using a MiniRAE portable VOC monitor. These

instruments use a photoionization detector that is designed to measure trace quantities of

VOCs with a parts-per-million (ppm) sensitivity range. It does not detect methane. The survey

instrument will be calibrated using an appropriate standard according to manufacturer’s

instructions. The VOC monitor will be calibrated prior to each use if the instrument is used

infrequently, or daily when in constant use.

If the MiniRAE portable VOC monitor detects elevated levels of VOC concentrations (> 50

ppmv), in ambient air at the site, a Gastech 02 /explosion/H2S meter will be used to measure

oxygen concentrations, explosion potential, and hydrogen sulfide (H2S) concentration. The

instrument will be calibrated with methane and H2S according to the manufacturer’s

instructions.

Air monitoring equipment will be certified intrinsically safe and operated by personnel trained in

the use of the specific equipment provided.

7

4.2 TYPES AND FREQUENCY OF MONITORING

4.2.1 Breathing Zone Monitoring

The breathing zone of a representative employee suspected of greatest exposure for each job

category engaged in work with potentially hazardous substances will be monitored as follows:

· For excavation operations, monitor the breathing zone of the

equipment operator and laborers with an OVM when the waste

material is initially exposed. The results of the monitoring, the

employee’s name, and the work activity will be recorded in the

daily log.

4.2.2 Explosive Gas Source Monitoring

During all operations identified as having a fire/explosion hazard, a combustible gas meter set

to measure the lower explosive level (LEL) will be used to continuously monitor the top of the

trench or excavation.

4.2.3 Work Area Monitoring

Each work area associated with hazardous waste spills and/or contamination will be monitored

at least one time each day with an OVM to determine the concentration of contaminants being

released into the general area.

4.2.4 Dust Monitoring

Chemical exposure via inhalation will be mitigated through the evaluation of wind velocity, and

common sense. Personal protective equipment will be utilized as necessary (based on specific

action levels) to prevent chemical exposure in excess of the exposure limits.

When possible, personnel should be situated upwind of work activity when working at the site.

Excavated areas should be allowed to vent for one to two minutes prior to investigative activities

to allow any vapors, dusts, or gases to dissipate. Liquids and solids should never be smelled to

confirm the presence or absence of chemicals.

The SSO will screen the site for dusty conditions to prevent inhalation of chemicals in

particulate form (e.g. residue on soil grains). If dusty conditions are observed, all workers will

wear appropriate respiratory protection designed for dusts. Extremely dusty conditions may

require dust suppression via water mist or spray prior to returning to work.

8

4.3 ACTION LEVELS

The action levels as prescribed by the National Institute for Occupational Safety and Health

(NIOSH) will be used to initiate protective actions including, but not limited to, use of personal

protective devices, shut down of specific work activities, and site evacuation. A current volume

of the NIOSH Pocket Guide to Chemical hazards will be utilized as an on-site referenced by the

SSO.

5.0 PERSONAL PROTECTIVE EQUIPMENT AND PROCEDURES

5.1 RESPIRATORY PROTECTION

During excavation or construction activities in an area where special wastes are expected or

have been encountered, the use of respiratory protection equipment may be required.

Respiratory protection is of primary importance as inhalation is one of the major routes of

exposure to chemical toxicants. Respiratory protective devices include air purifying respirators,

air-line respirators, and self-contained breathing apparatus.

The following respiratory protection practices will be observed by all workers at the Site when

conditions warrant respiratory protection:

· The respiratory protection utilized on-site will be in accordance

with OSHA, 29 CFR 1910.134.

· Only properly cleaned, maintained, NIOSH/MSHA-approved,

respirators will be used on-site (if required).

· Selection of respirators, as well as any decisions regarding

upgrading or downgrading of respiratory protection, will be made

by the SSO.

· Air-purifying cartridges will be replaced on a regular basis (at

least once per day) as determined by the SSO.

· No employee will be assigned to tasks requiring the use of

respirators if, based upon the most recent examination, a

physician determines that the employee will be unable to

function normally wearing a respirator or that the safety or health

of the employee or other employees will be compromised by use

of a respirator.

9

· Persons required to wear full-face respirators must not have

beards or moustaches that interfere with proper respirator seal.

All personnel wearing full-face respirators or personnel working

in the exclusion zone will be required to be clean-shaven prior to

each day’s shift. This will be strictly enforced by the SSO.

· All personnel required to use APRs must be properly fit tested

prior to engaging in field activities in accordance with OSHA

standards (29 CFR 1910.1025).

5.2 PROTECTIVE CLOTHING

To protect workers against dermal contact with contaminants, the following apparel must be

worn during site-specific work activities depending on the level of protection specified for those

activities (Section 5.3 of this EMP):

· Disposable Tyvek coveralls;

· PVC-coated or equivalent coveralls for splash protection;

· Nitrile gloves or equivalent;

· Inner gloves - latex or vinyl;

· Outer disposable boots:

· Hard hat;

· Chemical-resistant boots (Neoprene, PVC, or equivalent);

· Hearing protection (as applicable);

· Steel-toed safety shoes;

· Goggles or safety glasses will be worn at all times in the work area;

· Sleeves taped to gloves and cuffs taped to boots;

· Face shield attachments for use with hard hats; and

· Disposable, chemical-resistant outer boots.

Upgrading or downgrading selected protective equipment will be the decision of the SSO based

on assessment of exposure potential during specific tasks.

10

5.3 LEVELS OF PROTECTION

The levels of protection to be utilized at the site, and the activities to which they apply, are

described in the following paragraphs. The SSO will select the appropriate level of PPE based

on air monitoring results.

5.3.1 Modified Level D

This is the minimum level of protective clothing to be worn at the site during construction

activities. All workers, supervisors, and visitors will be required to don the following clothing

prior to entering the project site. Based on the anticipated activities to be performed at the site,

it is anticipated that Modified Level D will provide adequate protection coverage.

· Work clothes;

· Hard hat;

· Safety shoes; and

· Work gloves.

5.3.2 Level D Protection Level D protection includes chemical resistant gloves and will be used for site work whenever contact with contaminated equipment or materials is possible. The following clothing will be required for Level D:

· Disposable, chemical-resistant outer boots;

· Coveralls (work uniform);

· Hard hat;

· Eye protection (safety glasses, goggles, or face-shield)*;

· Safety shoes;

· Nitrile gloves*; and

* Optional, as determined by SSO

Dust masks shall be used to reduce employee exposure to fugitive dust, an optional Level D

device. The absence of dusty conditions at the site will be justification for the SSO to permit

personnel to remove their masks.

11

5.3.3 Level C Protection

Level C will be used for site work when the inhalation and dermal contact hazard is elevated.

When conditions for Level C protection are appropriate, the following equipment will be

required: Tyvek coveralls/chemical-resistant protective coverall;

· Gloves (inner latex gloves and outer nitrile gloves);

· Hard hat;

· Safety shoes;

· Full-face or half-face air purifying respirator with organic vapor

cartridge (or other proper type cartridge for the intended use, as

determined by the SSO);

· Chemical-resistant outer boots;

· Tape gloves and boots to coveralls to prevent leakage; and

· Hearing protection (as determined by SSO)

5.3.4 Level B Protection

Level B will be used for site work when inhalation and dermal contact hazard are elevated to the

point that a positive pressure, supplied air source is needed.

· Saranex coveralls/chemical-resistant clothing

· Gloves (inner latex gloves and outer nitrile gloves);

· Hard hat;

· Self-contained breathing apparatus (SCBA), or Supplied Air-Line

Respirator (SAR);

· Chemical-resistant safety boots; and

· Gloves and boots taped to prevent leakage.

12

6.0 SITE CONTROL

The purpose of site control is to minimize potential contamination of workers and to protect the

surrounding area from hazards found at the site. The project site is not secured by fencing or

other suitable site control means and is not routinely patrolled by police or other independent

security personnel; thus, certain procedures must be followed to ensure suitable site control

and limitation of access so that those persons who may be unaware of site conditions are not

exposed to hazards.

All excavations left open and unattended by site personnel will be appropriately barricaded and

visibly posted with “No Trespassing” or other appropriate signage. All heavy machinery and

equipment shall be locked or chained each evening upon completion of daily activities. All

potentially contaminated media, such as soil, will be covered with plastic prior to leaving the

site. These procedures, and other relevant procedures referenced in this document, will be

communicated to the onsite excavation contractor, who has been contracted directly by the

Client, North State Howard, LLC, and not by CES.

6.1 REGULATED AREAS

As appropriate to the task conducted, the site vicinity will be divided into three zones to allow

control of worker exposures. These zones are described as follows:

· Exclusion Zone. This zone includes the actual area of

contamination and localized work area where specific

investigative and/or construction equipment is operating. This

zone has the highest inhalation exposure potential, and/or

presents a high probability of skin contact with cutaneous

percutaneous - affecting chemicals. New exclusion zones may

exist during certain site-specific activities. This will be defined by

the SSO and access by individuals not necessary to operation

will be limited. (Level D is minimum)

· Contamination Reduction Zone. This zone includes the areas

immediately surrounding the Exclusion Zone. All personnel and

equipment leaving the Exclusion Zone shall be decontaminated

in this zone.

13

· Support Zone. This zone covers all areas outside of the

Contamination Reduction Zone. Administrative activities are

conducted in the Support zone, as well as equipment supply and

first aid supply. It is essential that contamination be kept out of

this zone.

6.2 ACCESS/SITE SECURITY

Access to contaminated work areas (Exclusion and Contamination Reduction Zones) will be

regulated and limited to authorized persons. Such persons include the Contractor’s

employees, designated equipment operators, and designated union representatives, as

applicable. The SSO will enforce access limitations during work hours.

6.3 POSTING/BARRICADES

Warning signs will be posted and hung, as applicable, in readily visible locations in or near

contaminated work areas. Barricades or barricade tape will be utilized to prevent access to

various work areas as indicated above.

14

7.0 POLICIES

7.1 GENERAL WORK PRACTICES

General work practices to be employed on-site are as follows:

· At least one copy of this EMP will be available at the work site.

· No food or beverages will be present or consumed in the

exclusion or contamination reduction zones. No tobacco

products will be present or used, and cosmetics will not be

applied in the exclusion or contamination reduction zones.

· No matches or lighters are permitted in the exclusion or

contamination reduction zones.

· During operations within an area of contamination, all employees

will be required to wash their hands and face before eating,

drinking, smoking, or applying cosmetics.

· Field personnel must observe each other for signs of exposure.

Indications of adverse effects include, but are not limited to, the

following:

- Changes in complexion and skin

discoloration;

- Changes in coordination;

- Changes in demeanor;

- Excessive salivation and pupillary

response; and

- Changes in speech pattern.

15

Field personnel will be cautioned to inform the SSO of non-

visible effects of exposure such as the following:

- Headaches;

- Dizziness;

- Nausea;

- Blurred vision

- Cramps; and

- Irritation of eyes, skin, or respiratory tract.

·

7.2 HEAVY EQUIPMENT OPERATION

Extra attention should be paid to the following information regarding work around heavy

equipment (excavators, front end/backhoe loaders, drilling rigs, etc.).

· Use common sense.

· Follow OSHA requirements found in 29 CFR 1910 and 29 CFR

1926.

· Wear hard hats, hearing protection, and safety glasses at all

times (when not prohibited by the use of air purifying

respirators). Wear other protective gear as specified in the

Health and Safety Plan.

· A closed cab or cage will be required for equipment used at the

site.

· Pay attention at all times

· Maintain visual contact at all times.

16

· Establish hand signal communication when verbal

communication is difficult. Select one person per work group to

be the one to give hand signals to equipment operators.

· Be aware of footing at all times.

· Be sure that all heavy equipment has a backup alarm.

· Be sure that only qualified people operate heavy equipment.

· Use chains, hoists, straps, and other equipment to safely move

heavy materials.

· Use proper personal lifting techniques. (Use your legs, not your

back).

· Never walk directly in back of, or to the side of, heavy equipment

without the operator’s knowledge.

· Never use a piece of equipment unless you are familiar with its

operation. This applies to heavy as well as light equipment (for

example, chain saws).

· Make sure all precautions have been taken before moving pipe

sections and other materials to be utilized during this project as

they are extremely heavy. Let the equipment, not your body, do

the moving.

· Be sure that no underground or overhead power lines, sewer

lines, gas lines, or telephone lines will present a hazard in the

work area.

17

7.3 SANITATION

Onsite sanitation facilities (e.g., wash stations, etc.) may be provided for use by field personnel

assigned to the work if work activities involve the direct handling of contaminated soils and

groundwater.

8.0 DECONTAMINATION

The process of removing or neutralizing contaminants that have accumulated on personnel and

equipment is critical to personnel protection. Decontamination protects workers from

hazardous substances that may contaminate and eventually permeate the protective clothing,

respiratory equipment, tools, vehicles, and other equipment used on site. Decontamination

protects site personnel in the following ways: minimizing the transfer of harmful materials into

clean areas; preventing the mixing of incompatible chemicals; and protecting the community by

preventing uncontrolled transportation of contaminants from the site.

General – Each time an employee enters the Contamination Reduction Zone from the

Exclusion Zone, he/she just make a thorough self-examination. Equipment must be removed

without exposure to the wearer. Hands and face must be scrubbed before eating or use of

tobacco or cosmetic products to avoid accidental ingestion of wastes. Footwear must be

changed prior to leaving the Contamination Reduction Zone to avoid “tracking” of contaminants

outside the area.

Clothing – The Contractor will provide all required protective clothing. Protective clothes will be

left in the change facility. No clothing (including boots) is to be worn or carried away from the

site. Soiled clothing is to be disposed of as appropriate.

Respirators – All required respirators will be provided and maintained by the Contractor and will

be cleaned daily. Cleaning and maintenance will be performed in accordance with the

appropriate OSHA standard (29 CFR 1910.134).

Packaging of Waste Items – All disposable clothing and other contaminated material will be

placed in containers for storage on-site. Personnel will make a conscious effort to minimize the

volume of contaminated materials. Legible and understandable precautionary labels will be

18

affixed prominently to containers of contaminated scrap, waste, debris, and clothing.

Containers will be disposed with other solids in an EPA-approved manner.

8.1 PERSONAL DECONTAMINATION

Minimum measures to be undertaken for decontamination are outlined below. These measures

are to be followed, as applicable, unless the SSO specifies that a higher level of

decontamination is warranted, and accordingly, sets forth upgraded decontamination

procedures.

MINIMUM MEASURES FOR DECONTAMINATION

STATION PROCEDURES

1. Equipment Drop 1. Deposit equipment used on site (tools, sampling devices

and containers, monitoring instruments, radios, clipboards,

etc.) on plastic drop cloths or in different containers with

plastic liners. During hot weather operations, a cool down

station may be set up within this area.

2. Outer Garment, Boots and

Gloves Wash and Rinse

2. Scrub outer boots, outer gloves and fully encapsulating

suit with decon solution or detergent and water. Rinse off

using copious amounts of water.

3. Outer Boot and Glove

Removal

3. Remove outer boots and gloves. Deposit in container with

plastic liner.

4. Tank Change 4. If worker leaves Exclusion Zone to change air tanks, this is

the last step in the decontamination procedure. Worker’s air

tank is exchanged, new outer gloves and boot covers

donned, joints taped, and worker returns to duty.

5. Boot, Gloves and Outer

Garment Removal

5. Boots, fully-encapsulated suit, inner gloves removed and

deposited in separate containers lined with plastic.

6. SCBA Removal 6. SCBA backpack and facepiece is removed (avoid

touching face with fingers). SCBA deposited on plastic

sheets.

7. Field Wash 7. Hands and face are thoroughly washed. Shower as soon

as possible.

19

EQUIPMENT NEEDED TO PERFORM MINIMUM DECONTAMINATION MEASURES

STATION EQUIPMENT

1 A. Various Size Containers

B. Plastic Liners

C. Plastic Drop Cloths

2 A. Container (20-30 Gallons)

B. Decon. Solution or Detergent Water

C. Rinse Water

D. 2-3 Long-Handled, Soft Bristled Scrub

Brushes

3 A. Container (20-30 Gallons)

B. Plastic Liners

C. Bench or Stools

4 A. Air Tanks or Masks and Cartridges,

depending Upon Level.

B. Tape

C. Boot Covers

D. Gloves

5 A. Containers (20-30 Gallons)

B. Plastic Liners

C. Bench or Stools

6 A. Plastic Sheets

B. Basin or Bucket

C. Soap and Towels

D. Bench or Stools

20

8.2 EQUIPMENT DECONTAMINATION

Any items taken into the Exclusion Zone will be assumed to be contaminated. In general,

vehicles, equipment, and materials brought into the Exclusion Zone will remain in the Exclusion

Zone until no longer necessary to the project.

All contaminated vehicles and equipment will be decontaminated before they are taken off-site.

The Contractor will provide and maintain the following facilities for equipment decontamination:

- equipment decontamination pad

- contaminated water collection system

- high-pressure water or steam cleaners

- trisodium phospate detergent

- wire brushes and scrapers

21

9.0 TRAINING

9.1 BASIC TRAINING

All employees who will perform work at the site must have completed environmental and safety

training as approved and/or provided by the General Contractor.

9.2 SITE-SPECIFIC TRAINING

Employees assigned to the site may, as needed, be given site-specific training and field

experience to include the following topics:

- Acute and chronic effects of the toxic chemicals found at the site

- Routes of potential exposure and field activities which could result in such

exposure

- Need for personal protection, types of protection, fit effectiveness and

limitations

- Medical surveillance program

- Work zones established at the site

- Prohibited activities in the Exclusion and Contamination Reduction Zones

- Engineering controls and safe work practices associated with each

employee’s work assignment, including dust control measures

- Personal and equipment decontamination procedures

- Emergency response procedures

- Basic operational safety, emphasizing hazards expected on-site

- Drum handling procedures

- Spill control

- Sampling procedures

- Site communication procedures

22

10.0 HEALTH MONITORING

10.1 PHYSICAL EXAMINATION

The Contractor shall require all of its field workers to pass a pre-employment medical

examination prior to working at the site. The examination shall include a complete medical and

occupational history, and an evaluation from the attending physician as to whether the

employee is qualified to work in areas where exposure to chemicals or physical stress is

possible, and is physically able to use protective equipment, including respirators.

10.2 HEAT STRESS

It is anticipated that the work activities associated with this project may be conducted during the

late spring, summer or early fall seasons. Accordingly, high temperatures during these time

periods put extra physical stress on the body. Long periods of exposure to heat may cause

illness, particularly if the employee is not accustomed to working in hot areas. Also, heat builds

up inside protective clothing, so there is a risk of heat stress even if outside temperatures are

moderate.

The signs, symptoms and treatment of heat stress are outlined below. All individuals

participating in work in the Exclusion Zone and Contamination Reduction Zones should be

monitored regularly for heat stress symptoms.

Heat Cramps

Symptoms: painful muscle spasms

Cause: profuse sweating and drinking large amounts of water

Treatment: provide liquids with electrolytes (sodium, potassium) like diluted Gatorade

Heat Exhaustion

Symptoms: weakness, fatigue, dizziness; pale, cool, moist skin; heavy sweating;

Headache; nausea; and fainting

23

Cause: reduced blood volume resulting from dehydration from profuse sweating

And insufficient replacement of water and salts.

Treatment: If worker is conscious, rest in cool place; replace water and electrolytes

lost in sweat; if unconscious, get medical help immediately. DO NOT

give liquids if person is unconscious.

Heat Stroke

Symptoms: very dry, hot skin with red mottled or bluish appearance; confusion;

Convulsions; unconsciousness; rapidly rising temperature

Cause: body becomes overheated because the worker does not sweat.

Can be fatal.

Treatment: call for medical help immediately; move person to cool place;

remove PPE; use wet towels or water and fan to cool while waiting

for help.

10.3 SELF MONITORING

While at the site, CES employees and sub-contractors will be required to monitor their own

health and that of their co-workers. Visual observations include:

- behavioral changes

- change in appetite

- coordination losses

- gum and lip discoloration

- increased salivation

- pupil dilation

- sensation losses

- skin rashes

- slurred speech

24

Any abnormalities or changes are to be reported to the physician and investigated immediately.

Such aspects could be symptoms of toxic exposure and must not be allowed to persist without

medical attention. In addition, all accidents and injuries, no matter how small, are to be

reported to the SSO and investigated.

11.0 SITE STANDARD OPERATING PROCEDURES

11.1 WORK PRACTICES

The need to exercise caution in the performance of specific work tasks is made more acute

due to weather conditions, restricted mobility, and reduced peripheral vision caused by the

protective gear itself, the need to maintain the integrity of the protective gear, and the

increased difficulty in communicating caused by respirators. Work at the site will be

conducted according to established procedures and guidelines for the safety and health of

all involved. Among the most important of these principles for working at the site are:

- In any unknown situation, always assume the worst conditions and plan

accordingly.

- Establish and maintain communication

- Minimize contact with excavated or contaminated materials. Plan work

work areas, decontamination areas, and procedures to accomplish this.

Do not place equipment on drums or on the ground. Do not sit or stand

on drums or other materials.

- Employ disposable items when possible to minimize risks during

decontamination and possible cross-contamination during sampling/handling.

This will require a common-sense approach to potential risks and costs.

- Smoking, eating, or drinking after entering the work zone and before

decontamination will not be allowed. Oral ingestion of contaminants from

your hands is a likely means of introduction of the toxic substances into the

body.

25

- Avoid heat and other work stresses relating to wearing the protective gear.

Work breaks and proper tracking are planned to prevent stress-related

accidents or fatigue.

- Maintain monitoring systems. Conditions can change quickly if sub-surface

areas of contamination are penetrated.

- Be observant of not only your own immediate surroundings but also that of

others. It is a team effort to notice and warn of impending dangerous

situations. Extra precautions are necessary when working near heavy

equipment while utilizing personal protective gear, as vision, hearing, and

communication may be restricted by the protective gear.

- Be aware that chemical contaminants may aggravate or worsen symptoms

of other illnesses or intoxication. Avoid use of alcohol and working when ill.

11.2 COMMUNICATION PROCEDURES

Personnel in the Exclusion Zone shall remain within sight of other project personnel, and should

work in conjunction with another individual. Since it is not anticipated that the project area will

encompass a large area at any given time, radio communication will not be required. The

following standard hand signals will be used in the event that communication is required

amongst workers in and/or between the Exclusion Zone and Contamination Reduction Zone.

Hand gripping throat Out of air, cannot breathe

Grip partner’s wrist, or both Leave area immediately

Hands around partner’s waist

Rotating hands above the head Need assistance

Right hand thumb up OK, I’m all right, I understand

26

Right hand thumb down No, negative

12.0 EMERGENCY PROCEDURES

12.1 GENERAL

A comprehensive emergency response plan has been developed to handle all on-site

emergencies. A list of site conditions which might require implementation of the plan includes

but is not limited to:

- Fire or explosion on-site

- Serious employee injury

- Accumulation of combustible gases or vapors at concentrations greater than

background

- Oxygen concentration below 19.5%

- Unsafe working conditions, such as inclement weather or hazardous material

releases

- Major release of toxic materials for which appropriate PPE is not being worn by

workers

12.2 RESPONSIBILITIES

The emergency coordinator is the SSO (Greg Hans) or assigned contractor working onsite; the

alternate or back-up is the Senior Engineer (Chuck Heleine). The emergency coordinator is

responsible for:

- Assessing the situation and determining whether an emergency exists which

requires activating the plan.

- Directing all efforts in the area, including evacuating personnel and minimizing

property loss.

- Ensuring that outside emergency services such as fire departments, police,

ambulance, and hospitals are notified when necessary.

- Directing the shut-down of site operations when necessary.

- Notifying regulatory agencies as necessary.

27

12.3 EMERGENCY CONTACT LIST

Emergency Contact Phone Number

Environmental PM: Greg Hans, PMP 617.828.9948

CES Group Engineers, LLP 704.489.1500

Back-up PM Chuck Heleine 704.308.7916

CES Group Engineers, LLP 704.489.1500

Police: North Carolina Highway Patrol 911

Hospital: Carolina HealthCare System 980.212.7000

275 N NC Highway 16 Business Suite 104

Denver, NC

Fire: Local Fire Department(s) 911

Doctor: Carolina HealthCare System 980.212.7000

Ambulance 911

NCDENR (Mooresville Region) 704.663.1699

Directions to the nearest hospital: Carolina HealthCare System

Refer to Appendix C.

29

12.4 PERSONNEL INJURY IN THE EXCLUSION ZONE

When there is an injury in the Exclusion Zone, a continuous horn blast will be sounded as an

emergency signal (as applicable). Upon the sounding of the emergency signal, all site

personnel shall assemble in the personnel decontamination area. Rescue personnel will enter

the Exclusion Zone (if required) to remove the injured person. The SSO will evaluate the nature

of the injury and call for an ambulance (if needed), and the affected person will be

decontaminated to the extent possible prior to movement to the Support Zone. The appropriate

first aid will be administered. No persons shall re-enter the Exclusion Zone until the cause of

the injury or symptom is determined.

12.5 PERSONAL INJURY IN THE SUPPORT ZONE

Upon notification of an injury in the Support Zone, the SSO will assess the nature of the injury.

If the injury or absence of the injured person does not affect the performance of site personnel,

operations may continue while appropriate first aid and follow-up is initiated. If the injury

increases the risk to others, the designated emergency signal (continuous horn blast) shall be

sounded, and all site personnel shall move to the decontamination line for further instructions.

Activities on-site will stop until the added risk is removed or minimized.

12.6 FIRE OR EXPLOSION

Upon notification of a fire or explosion on-site, a continuous horn blast will be sounded, and all

site personnel will assemble at the decontamination area. The fire department must be alerted

and all personnel moved as soon as possible to a safe distance.

30

12.7 PERSONAL PROTECTIVE EQUIPMENT FAILURE

If any site worker experiences a failure or alteration of protective equipment which may alter the

protection factor, that person and his/her work partner must immediately leave the Exclusion

Zone. Re-entry shall not be permitted until the equipment has been appropriately repaired or

replaced.

12.8 POLLUTANT DISCHARGES/SPILLS

In the event of an unauthorized discharge of pollutants or contaminants into the soil, sewers, or

ambient air, the person first finding such an incident should immediately notify the Project

Manager and/or the SSO.

The SSO will immediately notify Greg Hans or Chuck Heleine at 704.489.1500 as well as the

local Emergency Management Agency (Bill Summers, Lincoln County Emergency Management

Director) at 704.736.8660.

31

APPENDIX B

EMERGENCY PHONE NUMBERS

Emergency Contact Phone Number

Environmental PM: Greg Hans, PMP 617.828.9948

CES Group Engineers, LLP 704.489.1500

Back-up PM Chuck Heleine 704.308.7916

CES Group Engineers, LLP 704.489.1500

Police: North Carolina Highway Patrol 911

Hospital: Carolina HealthCare System 980.212.7000

275 N NC Highway 16 Business Suite 104

Denver, NC

Fire: Local Fire Department(s) 911

Doctor: Carolina HealthCare System 980.212.7000

Ambulance 911

NCDENR (Mooresville Region) 704.663.1699

Directions to the nearest hospital: Novant Health Huntersville Medical Center

Refer to Appendix C.

32

APPENDIX C

ROUTE TO HOSPITAL

Head South on N NC Highway 16 Business for 4.0 miles

Carolina HealthCare System will be on the Right

33

APPENDIX B

11/20/17: Wash Basin (Wash Pit) prior to excavation and removal activities

11/20/17: Hydraulic Lift prior to excavation and removal activities

11/22/17: Removal of Wash Pit from the subsurface

11/22/17: Removal of Hydraulic Lift from the subsurface

11/22/17: Soil excavation and removal activities extending from the Wash Pit area

11/27/17: Additional concrete structure northeast of the Wash Pit

12/21/17: Looking west towards the excavated area

12/21/17: Looking north towards the excavated area with drain pipe observed on northeastern (upper)

corner of excavated area

1/4/18: Looking northeast towards the excavated area (prior to over-excavation of the eastern sidewall)

1/4/18: Looking northeast towards the excavated area (after over-excavation of the eastern sidewall)

1/4/18: Looking south towards the excavated area upon completion of over-excavation activities

APPENDIX C

This data package contains the analytical results for the project identified above and includes a Case Narrative, Sample

Results and Chain of Custody. Unless otherwise noted, all samples were received in acceptable condition and processed

according to the referenced methods.

Data qualifiers are flagged individually on each sample. A key reference for the data qualifiers appears at the end of this case

narrative.

NC Certification No. 402

NC Drinking Water Cert No. 37735

SC Certification No. 99012

Case Narrative

12/01/2017

CES Group Engineers, LLP

Greg Hans

274 N. Hwy 16, Ste 300

Denver, NC 28037

Project: Howard Property

Project No.: Howard Property

Lab Submittal Date: 11/27/2017

Prism Work Order: 7110471

Please call if you have any questions relating to this analytical report.

Respectfully,

PRISM LABORATORIES, INC.

VP Laboratory Services

Reviewed ByAngela D. Overcash Angela D. Overcash

VP Laboratory Services

Data Qualifiers Key Reference:

A Surrogate recovery below range due to sample matrix. Matrix interference suspected.

DO Surrogates diluted out.

RLM Sample container suspected to have low methanol content. Results possibly biased high.

SR Surrogate recovery outside the QC limits.

Method Detection LimitMDL

Below Reporting LimitBRL

Relative Percent DifferenceRPD

* Results reported to the reporting limit. All other results are reported to the MDL with values between MDL and

reporting limit indicated with a J.

This report should not be reproduced, except in its entirety, without the written consent of Prism Laboratories, Inc.

449 Springbrook Road - P.O. Box 240543 - Charlotte, NC 28224-0543

Phone: 704/529-6364 - Toll Free Number: 1-800/529-6364 - Fax: 704/525-0409 Page 1 of 18

Sample Receipt Summary12/01/2017

Prism Work Order: 7110471

Client Sample ID MatrixLab Sample ID Date Sampled Date Received

7110471-01 11/22/17WP-1 11/27/17Solid

7110471-02 11/22/17WP-2 11/27/17Solid

7110471-03 11/22/17WP-3 11/27/17Solid

7110471-04 11/22/17WP-5 11/27/17Solid

7110471-05 11/22/17Hyd-1 11/27/17Solid

7110471-06 11/22/17WP-7 11/27/17Solid

7110471-07 11/22/17WP-8 11/27/17Solid

Samples were received in good condition at 3.8 degrees C unless otherwise noted.

This report should not be reproduced, except in its entirety, without the written consent of Prism Laboratories, Inc.

449 Springbrook Road - P.O. Box 240543 - Charlotte, NC 28224-0543

Phone: 704/529-6364 - Toll Free Number: 1-800/529-6364 - Fax: 704/525-0409 Page 2 of 18

Client ID ResultParameter Method UnitsPrism ID

Prism Work Order: 7110471

12/01/2017

Summary of Detections

4200 mg/kg dry7110471-01 WP-1 Diesel Range Organics *8015C

33 mg/kg dry7110471-01 WP-1 Gasoline Range Organics *8015C

0.052 mg/kg dry7110471-01 WP-1 Mercury *7471B

11 mg/kg dry7110471-01 WP-1 Arsenic *6010D

87 mg/kg dry7110471-01 WP-1 Barium *6010D

30 mg/kg dry7110471-01 WP-1 Chromium *6010D

71 mg/kg dry7110471-01 WP-1 Lead *6010D

22 mg/kg dry7110471-02 WP-2 Chromium *6010D

35 mg/kg dry7110471-02 WP-2 Lead *6010D

60 mg/kg dry7110471-06 WP-7 Diesel Range Organics *8015C

21 mg/kg dry7110471-07 WP-8 Diesel Range Organics *8015C

This report should not be reproduced, except in its entirety, without the written consent of Prism Laboratories, Inc.

449 Springbrook Road - P.O. Box 240543 - Charlotte, NC 28224-0543

Phone: 704/529-6364 - Toll Free Number: 1-800/529-6364 - Fax: 704/525-0409 Page 3 of 18

Laboratory Report12/01/2017

ResultParameter Batch

IDReport

Limit

Analysis

Date/Time

MethodDilution

FactorUnits MDL Analyst

274 N. Hwy 16, Ste 300 Project No.:

Project: Howard PropertyCES Group Engineers, LLP

Denver, NC 28037

Attn: Greg Hans

Sample Matrix: Solid

Client Sample ID: WP-1

Prism Sample ID: 7110471-01

Prism Work Order: 7110471

Time Collected: 11/22/17 10:35

Time Submitted: 11/27/17 08:55

Howard Property

Diesel Range Organics by GC/FID

4200 *8015C P7K049050460 11/30/17 13:31 ZRCmg/kg dry 180Diesel Range Organics

Surrogate Recovery Control Limits

49-1240 %o-Terphenyl DO

Gasoline Range Organics by GC/FID

33 *8015C P7K0505506.7 11/28/17 18:01 ANGmg/kg dry 1.4Gasoline Range Organics

Surrogate Recovery Control Limits

50-13774 %a,a,a-Trifluorotoluene

General Chemistry Parameters

75.5 *SM2540 G P7K055010.100 11/29/17 16:00 JLB% by

Weight

0.100% Solids

Total Metals

0.052 *7471B P7K054910.026 11/30/17 12:07 JABmg/kg dry 0.0025Mercury

11 *6010D P7K051710.34 11/30/17 17:36 JABmg/kg dry 0.041Arsenic

87 *6010D P7K051710.68 11/30/17 17:36 JABmg/kg dry 0.099Barium

BRL *6010D P7K051710.34 11/30/17 17:36 JABmg/kg dry 0.0091Cadmium

30 *6010D P7K051710.34 11/30/17 17:36 JABmg/kg dry 0.057Chromium

71 *6010D P7K051710.34 11/30/17 17:36 JABmg/kg dry 0.063Lead

BRL *6010D P7K051710.68 11/30/17 17:36 JABmg/kg dry 0.16Selenium

BRL *6010D P7K051710.34 11/30/17 17:36 JABmg/kg dry 0.0084Silver

Volatile Organic Compounds by GC/MS

BRL 8260B P7K049910.0042 11/28/17 22:01 ANGmg/kg dry 0.00041Benzene

BRL 8260B P7K049910.0070 11/28/17 22:01 ANGmg/kg dry 0.00027Ethylbenzene

BRL 8260B P7K049910.014 11/28/17 22:01 ANGmg/kg dry 0.00065m,p-Xylenes

BRL 8260B P7K049910.0070 11/28/17 22:01 ANGmg/kg dry 0.00029o-Xylene

BRL 8260B P7K049910.0070 11/28/17 22:01 ANGmg/kg dry 0.00040Toluene

Surrogate Recovery Control Limits

84-123106 %Dibromofluoromethane

76-12991 %Toluene-d8

This report should not be reproduced, except in its entirety, without the written consent of Prism Laboratories, Inc.

449 Springbrook Road - P.O. Box 240543 - Charlotte, NC 28224-0543

Phone: 704/529-6364 - Toll Free Number: 1-800/529-6364 - Fax: 704/525-0409 Page 4 of 18

Laboratory Report12/01/2017

ResultParameter Batch

IDReport

Limit

Analysis

Date/Time

MethodDilution

FactorUnits MDL Analyst

274 N. Hwy 16, Ste 300 Project No.:

Project: Howard PropertyCES Group Engineers, LLP

Denver, NC 28037

Attn: Greg Hans

Sample Matrix: Solid

Client Sample ID: WP-2

Prism Sample ID: 7110471-02

Prism Work Order: 7110471

Time Collected: 11/22/17 11:50

Time Submitted: 11/27/17 08:55

Howard Property

Diesel Range Organics by GC/FID

BRL *8015C P7K049018.7 11/29/17 20:57 ZRCmg/kg dry 3.4Diesel Range Organics

Surrogate Recovery Control Limits

49-12455 %o-Terphenyl

Gasoline Range Organics by GC/FID RLM

BRL *8015C P7K0505503.2 11/28/17 18:28 ANGmg/kg dry 0.69Gasoline Range Organics

Surrogate Recovery Control Limits

50-137139 %a,a,a-Trifluorotoluene SR

General Chemistry Parameters

80.0 *SM2540 G P7K055010.100 11/29/17 16:00 JLB% by

Weight

0.100% Solids

Total Metals

22 *6010D P7K048510.31 11/28/17 22:51 JABmg/kg dry 0.052Chromium

35 *6010D P7K048510.31 11/28/17 22:51 JABmg/kg dry 0.058Lead

This report should not be reproduced, except in its entirety, without the written consent of Prism Laboratories, Inc.

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Laboratory Report12/01/2017

ResultParameter Batch

IDReport

Limit

Analysis

Date/Time

MethodDilution

FactorUnits MDL Analyst

274 N. Hwy 16, Ste 300 Project No.:

Project: Howard PropertyCES Group Engineers, LLP

Denver, NC 28037

Attn: Greg Hans

Sample Matrix: Solid

Client Sample ID: WP-3

Prism Sample ID: 7110471-03

Prism Work Order: 7110471

Time Collected: 11/22/17 12:00

Time Submitted: 11/27/17 08:55

Howard Property

Diesel Range Organics by GC/FID

BRL *8015C P7K049018.7 11/29/17 21:33 ZRCmg/kg dry 3.4Diesel Range Organics

Surrogate Recovery Control Limits

49-12451 %o-Terphenyl

Gasoline Range Organics by GC/FID

BRL *8015C P7K0505504.3 11/28/17 18:56 ANGmg/kg dry 0.92Gasoline Range Organics

Surrogate Recovery Control Limits

50-137104 %a,a,a-Trifluorotoluene

General Chemistry Parameters

80.2 *SM2540 G P7K055010.100 11/29/17 16:00 JLB% by

Weight

0.100% Solids

This report should not be reproduced, except in its entirety, without the written consent of Prism Laboratories, Inc.

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Phone: 704/529-6364 - Toll Free Number: 1-800/529-6364 - Fax: 704/525-0409 Page 6 of 18

Laboratory Report12/01/2017

ResultParameter Batch

IDReport

Limit

Analysis

Date/Time

MethodDilution

FactorUnits MDL Analyst

274 N. Hwy 16, Ste 300 Project No.:

Project: Howard PropertyCES Group Engineers, LLP

Denver, NC 28037

Attn: Greg Hans

Sample Matrix: Solid

Client Sample ID: WP-5

Prism Sample ID: 7110471-04

Prism Work Order: 7110471

Time Collected: 11/22/17 13:15

Time Submitted: 11/27/17 08:55

Howard Property

Diesel Range Organics by GC/FID

BRL *8015C P7K049018.7 11/29/17 22:10 ZRCmg/kg dry 3.4Diesel Range Organics

Surrogate Recovery Control Limits

49-12476 %o-Terphenyl

Gasoline Range Organics by GC/FID

BRL *8015C P7K0505503.5 11/28/17 19:24 ANGmg/kg dry 0.75Gasoline Range Organics

Surrogate Recovery Control Limits

50-137122 %a,a,a-Trifluorotoluene

General Chemistry Parameters

80.8 *SM2540 G P7K055010.100 11/29/17 16:00 JLB% by

Weight

0.100% Solids

This report should not be reproduced, except in its entirety, without the written consent of Prism Laboratories, Inc.

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Laboratory Report12/01/2017

ResultParameter Batch

IDReport

Limit

Analysis

Date/Time

MethodDilution

FactorUnits MDL Analyst

274 N. Hwy 16, Ste 300 Project No.:

Project: Howard PropertyCES Group Engineers, LLP

Denver, NC 28037

Attn: Greg Hans

Sample Matrix: Solid

Client Sample ID: Hyd-1

Prism Sample ID: 7110471-05

Prism Work Order: 7110471

Time Collected: 11/22/17 14:30

Time Submitted: 11/27/17 08:55

Howard Property

Diesel Range Organics by GC/FID

BRL *8015C P7K049019.2 11/30/17 3:05 ZRCmg/kg dry 3.6Diesel Range Organics

Surrogate Recovery Control Limits

49-12460 %o-Terphenyl

General Chemistry Parameters

75.7 *SM2540 G P7K055010.100 11/29/17 16:00 JLB% by

Weight

0.100% Solids

This report should not be reproduced, except in its entirety, without the written consent of Prism Laboratories, Inc.

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Phone: 704/529-6364 - Toll Free Number: 1-800/529-6364 - Fax: 704/525-0409 Page 8 of 18

Laboratory Report12/01/2017

ResultParameter Batch

IDReport

Limit

Analysis

Date/Time

MethodDilution

FactorUnits MDL Analyst

274 N. Hwy 16, Ste 300 Project No.:

Project: Howard PropertyCES Group Engineers, LLP

Denver, NC 28037

Attn: Greg Hans

Sample Matrix: Solid

Client Sample ID: WP-7

Prism Sample ID: 7110471-06

Prism Work Order: 7110471

Time Collected: 11/22/17 14:40

Time Submitted: 11/27/17 08:55

Howard Property

Diesel Range Organics by GC/FID

60 *8015C P7K049018.6 11/30/17 3:42 ZRCmg/kg dry 3.4Diesel Range Organics

Surrogate Recovery Control Limits

49-12448 %o-Terphenyl A

Gasoline Range Organics by GC/FID

BRL *8015C P7K0505504.5 11/28/17 19:52 ANGmg/kg dry 0.96Gasoline Range Organics

Surrogate Recovery Control Limits

50-137119 %a,a,a-Trifluorotoluene

General Chemistry Parameters

81.1 *SM2540 G P7K055010.100 11/29/17 16:00 JLB% by

Weight

0.100% Solids

This report should not be reproduced, except in its entirety, without the written consent of Prism Laboratories, Inc.

449 Springbrook Road - P.O. Box 240543 - Charlotte, NC 28224-0543

Phone: 704/529-6364 - Toll Free Number: 1-800/529-6364 - Fax: 704/525-0409 Page 9 of 18

Laboratory Report12/01/2017

ResultParameter Batch

IDReport

Limit

Analysis

Date/Time

MethodDilution

FactorUnits MDL Analyst

274 N. Hwy 16, Ste 300 Project No.:

Project: Howard PropertyCES Group Engineers, LLP

Denver, NC 28037

Attn: Greg Hans

Sample Matrix: Solid

Client Sample ID: WP-8

Prism Sample ID: 7110471-07

Prism Work Order: 7110471

Time Collected: 11/22/17 15:15

Time Submitted: 11/27/17 08:55

Howard Property

Diesel Range Organics by GC/FID

21 *8015C P7K049018.5 11/29/17 0:38 ZRCmg/kg dry 3.3Diesel Range Organics

Surrogate Recovery Control Limits

49-12444 %o-Terphenyl A

Gasoline Range Organics by GC/FID

BRL *8015C P7K0505504.8 11/28/17 20:20 ANGmg/kg dry 1.0Gasoline Range Organics

Surrogate Recovery Control Limits

50-137111 %a,a,a-Trifluorotoluene

General Chemistry Parameters

82.5 *SM2540 G P7K055010.100 11/29/17 16:00 JLB% by

Weight

0.100% Solids

This report should not be reproduced, except in its entirety, without the written consent of Prism Laboratories, Inc.

449 Springbrook Road - P.O. Box 240543 - Charlotte, NC 28224-0543

Phone: 704/529-6364 - Toll Free Number: 1-800/529-6364 - Fax: 704/525-0409 Page 10 of 18

12/1/17

Level II QC Report

274 N. Hwy 16, Ste 300 Project No: Howard Property

Project: Howard PropertyCES Group Engineers, LLP

Denver, NC 28037

Attn: Greg Hans

Prism Work Order: 7110471

Time Submitted: 11/27/2017 8:55:00AM

Result Limit

Reporting

Units Level

Spike

Result

Source

%REC

%REC

Limits RPD

RPD

Limit Notes Analyte

Volatile Organic Compounds by GC/MS - Quality Control

Batch P7K0499 - 5035

Blank (P7K0499-BLK1) Prepared & Analyzed: 11/28/17

Benzene mg/kg wetBRL 0.0030

Ethylbenzene mg/kg wetBRL 0.0050

m,p-Xylenes mg/kg wetBRL 0.010

o-Xylene mg/kg wetBRL 0.0050

Toluene mg/kg wetBRL 0.0050

ug/L 50.00 84-123Surrogate: Dibromofluoromethane 9849.2

ug/L 50.00 76-129Surrogate: Toluene-d8 9044.8

LCS (P7K0499-BS1) Prepared & Analyzed: 11/28/17

1,1-Dichloroethylene mg/kg wet0.0520 0.0050 0.05000 67-149104

Benzene mg/kg wet0.0493 0.0030 0.05000 74-12799

Chlorobenzene mg/kg wet0.0446 0.0050 0.05000 74-11889

Toluene mg/kg wet0.0502 0.0050 0.05000 71-129100

Trichloroethylene mg/kg wet0.0508 0.0050 0.05000 75-133102

ug/L 50.00 70-130Surrogate: 4-Bromofluorobenzene 9849.1

ug/L 50.00 84-123Surrogate: Dibromofluoromethane 9849.1

ug/L 50.00 76-129Surrogate: Toluene-d8 9145.5

LCS Dup (P7K0499-BSD1) Prepared & Analyzed: 11/28/17

1,1-Dichloroethylene mg/kg wet0.0468 0.0050 0.05000 2067-14994 10

Benzene mg/kg wet0.0465 0.0030 0.05000 2074-12793 6

Chlorobenzene mg/kg wet0.0428 0.0050 0.05000 2074-11886 4

Toluene mg/kg wet0.0462 0.0050 0.05000 2071-12992 8

Trichloroethylene mg/kg wet0.0469 0.0050 0.05000 2075-13394 8

ug/L 50.00 70-130Surrogate: 4-Bromofluorobenzene 9848.9

ug/L 50.00 84-123Surrogate: Dibromofluoromethane 10150.3

ug/L 50.00 76-129Surrogate: Toluene-d8 9246.1

This report should not be reproduced, except in its entirety, without the written consent of Prism Laboratories, Inc.

449 Springbrook Road - P.O. Box 240543 - Charlotte, NC 28224-0543

Phone: 704/529-6364 - Toll Free Number: 1-800/529-6364 - Fax: 704/525-0409 Page 11 of 18

12/1/17

Level II QC Report

274 N. Hwy 16, Ste 300 Project No: Howard Property

Project: Howard PropertyCES Group Engineers, LLP

Denver, NC 28037

Attn: Greg Hans

Prism Work Order: 7110471

Time Submitted: 11/27/2017 8:55:00AM

Result Limit

Reporting

Units Level

Spike

Result

Source

%REC

%REC

Limits RPD

RPD

Limit Notes Analyte

Gasoline Range Organics by GC/FID - Quality Control

Batch P7K0505 - 5035

Blank (P7K0505-BLK1) Prepared & Analyzed: 11/28/17

Gasoline Range Organics mg/kg wetBRL 5.0

mg/kg 5.000 50-137Surrogate: a,a,a-Trifluorotoluene 834.15

LCS (P7K0505-BS1) Prepared & Analyzed: 11/28/17

Gasoline Range Organics mg/kg wet45.2 5.0 50.00 41-13890

mg/kg 5.000 50-137Surrogate: a,a,a-Trifluorotoluene 733.65

LCS Dup (P7K0505-BSD1) Prepared & Analyzed: 11/28/17

Gasoline Range Organics mg/kg wet49.6 5.0 50.00 2041-13899 9

mg/kg 5.000 50-137Surrogate: a,a,a-Trifluorotoluene 793.95

Matrix Spike (P7K0505-MS1) Prepared & Analyzed: 11/28/17 Source: 7110471-01

Gasoline Range Organics mg/kg dry70.0 6.6 65.94 33.5 41-13855

mg/kg 5.000 50-137Surrogate: a,a,a-Trifluorotoluene 864.30

Matrix Spike Dup (P7K0505-MSD1) Prepared & Analyzed: 11/28/17 Source: 7110471-01

Gasoline Range Organics mg/kg dry72.4 6.6 65.67 33.5 3441-13859 3

mg/kg 5.000 50-137Surrogate: a,a,a-Trifluorotoluene 964.80

This report should not be reproduced, except in its entirety, without the written consent of Prism Laboratories, Inc.

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Phone: 704/529-6364 - Toll Free Number: 1-800/529-6364 - Fax: 704/525-0409 Page 12 of 18

12/1/17

Level II QC Report

274 N. Hwy 16, Ste 300 Project No: Howard Property

Project: Howard PropertyCES Group Engineers, LLP

Denver, NC 28037

Attn: Greg Hans

Prism Work Order: 7110471

Time Submitted: 11/27/2017 8:55:00AM

Result Limit

Reporting

Units Level

Spike

Result

Source

%REC

%REC

Limits RPD

RPD

Limit Notes Analyte

Diesel Range Organics by GC/FID - Quality Control

Batch P7K0490 - 3546

Blank (P7K0490-BLK1) Prepared: 11/27/17 Analyzed: 11/29/17

Diesel Range Organics mg/kg wetBRL 7.0

mg/kg wet 1.333 49-124Surrogate: o-Terphenyl 1201.60

LCS (P7K0490-BS1) Prepared: 11/27/17 Analyzed: 11/29/17

Diesel Range Organics mg/kg wet62.5 7.0 66.67 55-10994

mg/kg wet 1.333 49-124Surrogate: o-Terphenyl 1181.57

LCS Dup (P7K0490-BSD1) Prepared: 11/27/17 Analyzed: 11/29/17

Diesel Range Organics mg/kg wet64.9 7.0 66.67 2055-10997 4

mg/kg wet 1.333 49-124Surrogate: o-Terphenyl 1151.53

This report should not be reproduced, except in its entirety, without the written consent of Prism Laboratories, Inc.

449 Springbrook Road - P.O. Box 240543 - Charlotte, NC 28224-0543

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12/1/17

Level II QC Report

274 N. Hwy 16, Ste 300 Project No: Howard Property

Project: Howard PropertyCES Group Engineers, LLP

Denver, NC 28037

Attn: Greg Hans

Prism Work Order: 7110471

Time Submitted: 11/27/2017 8:55:00AM

Result Limit

Reporting

Units Level

Spike

Result

Source

%REC

%REC

Limits RPD

RPD

Limit Notes Analyte

Total Metals - Quality Control

Batch P7K0485 - 3050B

Blank (P7K0485-BLK1) Prepared & Analyzed: 11/28/17

Chromium mg/kg wetBRL 0.25

Lead mg/kg wetBRL 0.25

LCS (P7K0485-BS1) Prepared & Analyzed: 11/28/17

Chromium mg/kg wet25.2 0.25 25.00 80-120101

Lead mg/kg wet25.4 0.25 25.00 80-120102

Batch P7K0517 - 3050B

Blank (P7K0517-BLK1) Prepared: 11/29/17 Analyzed: 11/30/17

Arsenic mg/kg wetBRL 0.25

Barium mg/kg wetBRL 0.50

Cadmium mg/kg wetBRL 0.25

Chromium mg/kg wetBRL 0.25

Lead mg/kg wetBRL 0.25

Selenium mg/kg wetBRL 0.50

Silver mg/kg wetBRL 0.25

LCS (P7K0517-BS1) Prepared: 11/29/17 Analyzed: 11/30/17

Arsenic mg/kg wet22.2 0.25 25.00 80-12089

Barium mg/kg wet23.6 0.50 25.00 80-12094

Cadmium mg/kg wet23.1 0.25 25.00 80-12092

Chromium mg/kg wet23.3 0.25 25.00 80-12093

Lead mg/kg wet23.2 0.25 25.00 80-12093

Selenium mg/kg wet21.1 0.50 25.00 80-12084

Silver mg/kg wet9.14 0.25 10.00 80-12091

This report should not be reproduced, except in its entirety, without the written consent of Prism Laboratories, Inc.

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Phone: 704/529-6364 - Toll Free Number: 1-800/529-6364 - Fax: 704/525-0409 Page 14 of 18

12/1/17

Level II QC Report

274 N. Hwy 16, Ste 300 Project No: Howard Property

Project: Howard PropertyCES Group Engineers, LLP

Denver, NC 28037

Attn: Greg Hans

Prism Work Order: 7110471

Time Submitted: 11/27/2017 8:55:00AM

Result Limit

Reporting

Units Level

Spike

Result

Source

%REC

%REC

Limits RPD

RPD

Limit Notes Analyte

Total Metals - Quality Control

Batch P7K0517 - 3050B

Matrix Spike (P7K0517-MS1) Prepared: 11/29/17 Analyzed: 11/30/17 Source: 7110471-01

Arsenic mg/kg dry39.7 0.34 33.61 11.2 75-12585

Barium mg/kg dry3.36E10 0.67 33.60 87.2 75-125NR

Cadmium mg/kg dry25.1 0.34 33.60 BRL 75-12575

Chromium mg/kg dry62.4 0.34 33.61 30.2 75-12596

Lead mg/kg dry113 0.34 33.61 70.8 75-125126

Selenium mg/kg dry24.5 0.67 33.60 BRL 75-12573

Silver mg/kg dry10.6 0.34 13.44 BRL 75-12579

Batch P7K0549 - 7471B

Blank (P7K0549-BLK1) Prepared & Analyzed: 11/30/17

Mercury mg/kg wetBRL 0.020

LCS (P7K0549-BS1) Prepared & Analyzed: 11/30/17

Mercury mg/kg wet0.456 0.020 0.4167 80-120109

Matrix Spike (P7K0549-MS1) Prepared & Analyzed: 11/30/17 Source: 7110471-01

Mercury mg/kg dry0.624 0.026 0.5426 0.0525 80-120105

Matrix Spike Dup (P7K0549-MSD1) Prepared & Analyzed: 11/30/17 Source: 7110471-01

Mercury mg/kg dry0.623 0.026 0.5426 0.0525 2080-120105 0.2

This report should not be reproduced, except in its entirety, without the written consent of Prism Laboratories, Inc.

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12/1/17

Level II QC Report

274 N. Hwy 16, Ste 300 Project No: Howard Property

Project: Howard PropertyCES Group Engineers, LLP

Denver, NC 28037

Attn: Greg Hans

Prism Work Order: 7110471

Time Submitted: 11/27/2017 8:55:00AM

Result Limit

Reporting

Units Level

Spike

Result

Source

%REC

%REC

Limits RPD

RPD

Limit Notes Analyte

General Chemistry Parameters - Quality Control

Batch P7K0550 - Solids, Dry Weight

Duplicate (P7K0550-DUP1) Prepared & Analyzed: 11/29/17 Source: 7110471-02

% Solids % by Weight82.0 0.100 80.0 202

This report should not be reproduced, except in its entirety, without the written consent of Prism Laboratories, Inc.

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Sample Extraction Data

Prep Method: 3546

Lab Number Batch Date/TimeInitial Final

P7K04907110471-01 11/28/17 13:3030.03 1g mL

P7K04907110471-02 11/28/17 13:3030.1 1g mL

P7K04907110471-03 11/28/17 13:3030.05 1g mL

P7K04907110471-04 11/28/17 13:3030.01 1g mL

P7K04907110471-05 11/28/17 13:3030.01 1g mL

P7K04907110471-06 11/28/17 13:3030.09 1g mL

P7K04907110471-07 11/28/17 13:3030.05 1g mL

Prep Method: 5035

Lab Number Batch Date/TimeInitial Final

P7K05057110471-01 11/28/17 14:014.96 5g mL

P7K05057110471-02 11/28/17 14:019.68 5g mL

P7K05057110471-03 11/28/17 14:017.26 5g mL

P7K05057110471-04 11/28/17 14:018.79 5g mL

P7K05057110471-06 11/28/17 14:016.86 5g mL

P7K05057110471-07 11/28/17 14:016.28 5g mL

Prep Method: Solids, Dry Weight

Lab Number Batch Date/TimeInitial Final

P7K05507110471-01 11/29/17 16:0030 30g g

P7K05507110471-02 11/29/17 16:0030 30g g

P7K05507110471-03 11/29/17 16:0030 30g g

P7K05507110471-04 11/29/17 16:0030 30g g

P7K05507110471-05 11/29/17 16:0030 30g g

P7K05507110471-06 11/29/17 16:0030 30g g

P7K05507110471-07 11/29/17 16:0030 30g g

Prep Method: 3050B

Lab Number Batch Date/TimeInitial Final

P7K05177110471-01 11/29/17 8:451.95 50g mL

P7K04857110471-02 11/28/17 8:202 50g mL

Prep Method: 7471B

Lab Number Batch Date/TimeInitial Final

P7K05497110471-01 11/30/17 9:100.6 50g mL

Prep Method: 5035

Lab Number Batch Date/TimeInitial Final

P7K04997110471-01 11/28/17 8:474.7 5g mL

This report should not be reproduced, except in its entirety, without the written consent of Prism Laboratories, Inc.

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Phone: 704/529-6364 - Toll Free Number: 1-800/529-6364 - Fax: 704/525-0409 Page 17 of 18

Page 18 of 18

This data package contains the analytical results for the project identified above and includes a Case Narrative, Sample

Results and Chain of Custody. Unless otherwise noted, all samples were received in acceptable condition and processed

according to the referenced methods.

Data qualifiers are flagged individually on each sample. A key reference for the data qualifiers appears at the end of this case

narrative.

NC Certification No. 402

NC Drinking Water Cert No. 37735

SC Certification No. 99012

Case Narrative

12/04/2017

CES Group Engineers, LLP

Greg Hans

274 N. Hwy 16, Ste 300

Denver, NC 28037

Project: Howard Property

Project No.: Howard Property

Lab Submittal Date: 11/27/2017

Prism Work Order: 7110483

Please call if you have any questions relating to this analytical report.

Respectfully,

PRISM LABORATORIES, INC.

VP Laboratory Services

Reviewed ByAngela D. Overcash Terri W. Cole For Angela D. Overcash

Project Manager

Data Qualifiers Key Reference:

Method Detection LimitMDL

Below Reporting LimitBRL

Relative Percent DifferenceRPD

* Results reported to the reporting limit. All other results are reported to the MDL with values between MDL and

reporting limit indicated with a J.

This report should not be reproduced, except in its entirety, without the written consent of Prism Laboratories, Inc.

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Sample Receipt Summary12/04/2017

Prism Work Order: 7110483

Client Sample ID MatrixLab Sample ID Date Sampled Date Received

7110483-02 11/22/17WP-9 11/27/17Solid

7110483-03 11/22/17WP-10 11/27/17Solid

Samples were received at 8.8 degrees C. See case narrative for further information.

This report should not be reproduced, except in its entirety, without the written consent of Prism Laboratories, Inc.

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Laboratory Report12/04/2017

ResultParameter Batch

IDReport

Limit

Analysis

Date/Time

MethodDilution

FactorUnits MDL Analyst

274 N. Hwy 16, Ste 300 Project No.:

Project: Howard PropertyCES Group Engineers, LLP

Denver, NC 28037

Attn: Greg Hans

Sample Matrix: Solid

Client Sample ID:

Prism Sample ID: 7110483-02

Prism Work Order: 7110483

Time Collected: 11/22/17 10:45

Time Submitted: 11/27/17 13:45

WP-9

Howard Property

Diesel Range Organics by GC/FID

79 *8015C P7K056019.1 12/1/17 9:36 ZRCmg/kg dry 3.6Diesel Range Organics

Surrogate Recovery Control Limits

49-12454 %o-Terphenyl

Gasoline Range Organics by GC/FID

BRL *8015C P7K0535505.9 11/29/17 18:57 ANGmg/kg dry 1.3Gasoline Range Organics

Surrogate Recovery Control Limits

50-13794 %a,a,a-Trifluorotoluene

General Chemistry Parameters

76.4 *SM2540 G P7K055010.100 11/29/17 16:00 JLB% by

Weight

0.100% Solids

Total Metals

35 *6010D P7K051710.32 11/30/17 18:04 JABmg/kg dry 0.054Chromium

420 *6010D P7K0517103.2 12/1/17 13:59 JABmg/kg dry 0.60Lead

This report should not be reproduced, except in its entirety, without the written consent of Prism Laboratories, Inc.

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Phone: 704/529-6364 - Toll Free Number: 1-800/529-6364 - Fax: 704/525-0409 Page 3 of 9

Laboratory Report12/04/2017

ResultParameter Batch

IDReport

Limit

Analysis

Date/Time

MethodDilution

FactorUnits MDL Analyst

274 N. Hwy 16, Ste 300 Project No.:

Project: Howard PropertyCES Group Engineers, LLP

Denver, NC 28037

Attn: Greg Hans

Sample Matrix: Solid

Client Sample ID:

Prism Sample ID: 7110483-03

Prism Work Order: 7110483

Time Collected: 11/22/17 10:45

Time Submitted: 11/27/17 13:45

WP-10

Howard Property

Diesel Range Organics by GC/FID

630 *8015C P7K05601091 12/1/17 10:50 ZRCmg/kg dry 35Diesel Range Organics

Surrogate Recovery Control Limits

49-12454 %o-Terphenyl

Gasoline Range Organics by GC/FID

BRL *8015C P7K0535504.6 11/29/17 19:25 ANGmg/kg dry 0.99Gasoline Range Organics

Surrogate Recovery Control Limits

50-13792 %a,a,a-Trifluorotoluene

General Chemistry Parameters

77.1 *SM2540 G P7K055010.100 11/29/17 16:00 JLB% by

Weight

0.100% Solids

This report should not be reproduced, except in its entirety, without the written consent of Prism Laboratories, Inc.

449 Springbrook Road - P.O. Box 240543 - Charlotte, NC 28224-0543

Phone: 704/529-6364 - Toll Free Number: 1-800/529-6364 - Fax: 704/525-0409 Page 4 of 9

12/4/17

Level II QC Report

274 N. Hwy 16, Ste 300 Project No: Howard Property

Project: Howard PropertyCES Group Engineers, LLP

Denver, NC 28037

Attn: Greg Hans

Prism Work Order: 7110483

Time Submitted: 11/27/2017 1:45:00PM

Result Limit

Reporting

Units Level

Spike

Result

Source

%REC

%REC

Limits RPD

RPD

Limit Notes Analyte

Gasoline Range Organics by GC/FID - Quality Control

Batch P7K0535 - 5035

Blank (P7K0535-BLK1) Prepared & Analyzed: 11/29/17

Gasoline Range Organics mg/kg wetBRL 5.0

mg/kg 5.000 50-137Surrogate: a,a,a-Trifluorotoluene 834.15

LCS (P7K0535-BS1) Prepared & Analyzed: 11/29/17

Gasoline Range Organics mg/kg wet47.6 5.0 50.00 41-13895

mg/kg 5.000 50-137Surrogate: a,a,a-Trifluorotoluene 783.90

LCS Dup (P7K0535-BSD1) Prepared & Analyzed: 11/29/17

Gasoline Range Organics mg/kg wet49.9 5.0 50.00 2041-138100 5

mg/kg 5.000 50-137Surrogate: a,a,a-Trifluorotoluene 834.15

This report should not be reproduced, except in its entirety, without the written consent of Prism Laboratories, Inc.

449 Springbrook Road - P.O. Box 240543 - Charlotte, NC 28224-0543

Phone: 704/529-6364 - Toll Free Number: 1-800/529-6364 - Fax: 704/525-0409 Page 5 of 9

12/4/17

Level II QC Report

274 N. Hwy 16, Ste 300 Project No: Howard Property

Project: Howard PropertyCES Group Engineers, LLP

Denver, NC 28037

Attn: Greg Hans

Prism Work Order: 7110483

Time Submitted: 11/27/2017 1:45:00PM

Result Limit

Reporting

Units Level

Spike

Result

Source

%REC

%REC

Limits RPD

RPD

Limit Notes Analyte

Diesel Range Organics by GC/FID - Quality Control

Batch P7K0560 - 3546

Blank (P7K0560-BLK1) Prepared & Analyzed: 11/30/17

Diesel Range Organics mg/kg wetBRL 7.0

mg/kg wet 1.333 49-124Surrogate: o-Terphenyl 781.04

LCS (P7K0560-BS1) Prepared & Analyzed: 11/30/17

Diesel Range Organics mg/kg wet60.7 7.0 66.67 55-10991

mg/kg wet 1.333 49-124Surrogate: o-Terphenyl 951.27

LCS Dup (P7K0560-BSD1) Prepared & Analyzed: 11/30/17

Diesel Range Organics mg/kg wet57.7 7.0 66.67 2055-10987 5

mg/kg wet 1.333 49-124Surrogate: o-Terphenyl 911.21

This report should not be reproduced, except in its entirety, without the written consent of Prism Laboratories, Inc.

449 Springbrook Road - P.O. Box 240543 - Charlotte, NC 28224-0543

Phone: 704/529-6364 - Toll Free Number: 1-800/529-6364 - Fax: 704/525-0409 Page 6 of 9

12/4/17

Level II QC Report

274 N. Hwy 16, Ste 300 Project No: Howard Property

Project: Howard PropertyCES Group Engineers, LLP

Denver, NC 28037

Attn: Greg Hans

Prism Work Order: 7110483

Time Submitted: 11/27/2017 1:45:00PM

Result Limit

Reporting

Units Level

Spike

Result

Source

%REC

%REC

Limits RPD

RPD

Limit Notes Analyte

Total Metals - Quality Control

Batch P7K0517 - 3050B

Blank (P7K0517-BLK1) Prepared: 11/29/17 Analyzed: 11/30/17

Chromium mg/kg wetBRL 0.25

Lead mg/kg wetBRL 0.25

LCS (P7K0517-BS1) Prepared: 11/29/17 Analyzed: 11/30/17

Chromium mg/kg wet23.3 0.25 25.00 80-12093

Lead mg/kg wet23.2 0.25 25.00 80-12093

This report should not be reproduced, except in its entirety, without the written consent of Prism Laboratories, Inc.

449 Springbrook Road - P.O. Box 240543 - Charlotte, NC 28224-0543

Phone: 704/529-6364 - Toll Free Number: 1-800/529-6364 - Fax: 704/525-0409 Page 7 of 9

12/4/17

Level II QC Report

274 N. Hwy 16, Ste 300 Project No: Howard Property

Project: Howard PropertyCES Group Engineers, LLP

Denver, NC 28037

Attn: Greg Hans

Prism Work Order: 7110483

Time Submitted: 11/27/2017 1:45:00PM

Result Limit

Reporting

Units Level

Spike

Result

Source

%REC

%REC

Limits RPD

RPD

Limit Notes Analyte

General Chemistry Parameters - Quality Control

Batch P7K0550 - Solids, Dry Weight

Duplicate (P7K0550-DUP3) Prepared & Analyzed: 11/29/17 Source: 7110483-02

% Solids % by Weight76.1 0.100 76.4 200.4

Sample Extraction Data

Prep Method: 3546

Lab Number Batch Date/TimeInitial Final

P7K05607110483-02 11/30/17 12:0030.08 1g mL

P7K05607110483-03 11/30/17 12:0030.05 1g mL

Prep Method: 5035

Lab Number Batch Date/TimeInitial Final

P7K05357110483-02 11/29/17 15:115.58 5g mL

P7K05357110483-03 11/29/17 15:116.99 5g mL

Prep Method: Solids, Dry Weight

Lab Number Batch Date/TimeInitial Final

P7K05507110483-02 11/29/17 16:0030 30g g

P7K05507110483-03 11/29/17 16:0030 30g g

Prep Method: 3050B

Lab Number Batch Date/TimeInitial Final

P7K05177110483-02 11/29/17 8:452.02 50g mL

P7K05177110483-02 11/29/17 8:452.02 50g mL

This report should not be reproduced, except in its entirety, without the written consent of Prism Laboratories, Inc.

449 Springbrook Road - P.O. Box 240543 - Charlotte, NC 28224-0543

Phone: 704/529-6364 - Toll Free Number: 1-800/529-6364 - Fax: 704/525-0409 Page 8 of 9

Page 9 of 9

This data package contains the analytical results for the project identified above and includes a Case Narrative, Sample

Results and Chain of Custody. Unless otherwise noted, all samples were received in acceptable condition and processed

according to the referenced methods.

Data qualifiers are flagged individually on each sample. A key reference for the data qualifiers appears at the end of this case

narrative.

NC Certification No. 402

NC Drinking Water Cert No. 37735

SC Certification No. 99012

Case Narrative

12/11/2017

CES Group Engineers, LLP

Greg Hans

274 N. Hwy 16, Ste 300

Denver, NC 28037

Project: Howard Property

Project No.: Howard Property

Lab Submittal Date: 11/27/2017

Prism Work Order: 7110483

Please call if you have any questions relating to this analytical report.

Respectfully,

PRISM LABORATORIES, INC.

VP Laboratory Services

Reviewed ByAngela D. Overcash Angela D. Overcash

VP Laboratory Services

Data Qualifiers Key Reference:

Method Detection LimitMDL

Below Reporting LimitBRL

Relative Percent DifferenceRPD

* Results reported to the reporting limit. All other results are reported to the MDL with values between MDL and

reporting limit indicated with a J.

This report should not be reproduced, except in its entirety, without the written consent of Prism Laboratories, Inc.

449 Springbrook Road - P.O. Box 240543 - Charlotte, NC 28224-0543

Phone: 704/529-6364 - Toll Free Number: 1-800/529-6364 - Fax: 704/525-0409 Page 1 of 11

Sample Receipt Summary12/11/2017

Prism Work Order: 7110483

Client Sample ID MatrixLab Sample ID Date Sampled Date Received

7110483-02 11/22/17WP-9 11/27/17Solid

7110483-03 11/22/17WP-10 11/27/17Solid

Samples were received at 8.8 degrees C. See case narrative for further information.

This report should not be reproduced, except in its entirety, without the written consent of Prism Laboratories, Inc.

449 Springbrook Road - P.O. Box 240543 - Charlotte, NC 28224-0543

Phone: 704/529-6364 - Toll Free Number: 1-800/529-6364 - Fax: 704/525-0409 Page 2 of 11

Client ID ResultParameter Method UnitsPrism ID

Prism Work Order: 7110483

12/11/2017

Summary of Detections

General Method

79 mg/kg dry7110483-02 WP-9 Diesel Range Organics *8015CDiesel Range Organics by GC/FID

0.21 mg/L7110483-02 WP-9 Lead *6010DTCLP Metals

35 mg/kg dry7110483-02 WP-9 Chromium *6010DTotal Metals

420 mg/kg dry7110483-02 WP-9 Lead *6010DTotal Metals

630 mg/kg dry7110483-03 WP-10 Diesel Range Organics *8015CDiesel Range Organics by GC/FID

This report should not be reproduced, except in its entirety, without the written consent of Prism Laboratories, Inc.

449 Springbrook Road - P.O. Box 240543 - Charlotte, NC 28224-0543

Phone: 704/529-6364 - Toll Free Number: 1-800/529-6364 - Fax: 704/525-0409 Page 3 of 11

Laboratory Report12/11/2017

ResultParameter Batch

IDReport

Limit

Analysis

Date/Time

MethodDilution

FactorUnits MDL Analyst

274 N. Hwy 16, Ste 300 Project No.:

Project: Howard PropertyCES Group Engineers, LLP

Denver, NC 28037

Attn: Greg Hans

Sample Matrix: Solid

Client Sample ID: WP-9

Prism Sample ID: 7110483-02

Prism Work Order: 7110483

Time Collected: 11/22/17 10:45

Time Submitted: 11/27/17 13:45

Howard Property

Diesel Range Organics by GC/FID

79 *8015C P7K056019.1 12/1/17 9:36 ZRCmg/kg dry 3.6Diesel Range Organics

Surrogate Recovery Control Limits

49-12454 %o-Terphenyl

Gasoline Range Organics by GC/FID

BRL *8015C P7K0535505.9 11/29/17 18:57 ANGmg/kg dry 1.3Gasoline Range Organics

Surrogate Recovery Control Limits

50-13794 %a,a,a-Trifluorotoluene

General Chemistry Parameters

76.4 *SM2540 G P7K055010.100 11/29/17 16:00 JLB% by

Weight

0.100% Solids

TCLP Extraction by EPA 1311

Complete *1311 P7L01141 12/7/17 7:30 JABN/ATCLP Extraction

TCLP Metals

0.21 *6010D P7L011310.050 12/7/17 14:48 JABmg/L 0.0040Lead

Total Metals

35 *6010D P7K051710.32 11/30/17 18:04 JABmg/kg dry 0.054Chromium

420 *6010D P7K0517103.2 12/1/17 13:59 JABmg/kg dry 0.60Lead

This report should not be reproduced, except in its entirety, without the written consent of Prism Laboratories, Inc.

449 Springbrook Road - P.O. Box 240543 - Charlotte, NC 28224-0543

Phone: 704/529-6364 - Toll Free Number: 1-800/529-6364 - Fax: 704/525-0409 Page 4 of 11

Laboratory Report12/11/2017

ResultParameter Batch

IDReport

Limit

Analysis

Date/Time

MethodDilution

FactorUnits MDL Analyst

274 N. Hwy 16, Ste 300 Project No.:

Project: Howard PropertyCES Group Engineers, LLP

Denver, NC 28037

Attn: Greg Hans

Sample Matrix: Solid

Client Sample ID: WP-10

Prism Sample ID: 7110483-03

Prism Work Order: 7110483

Time Collected: 11/22/17 10:45

Time Submitted: 11/27/17 13:45

Howard Property

Diesel Range Organics by GC/FID

630 *8015C P7K05601091 12/1/17 10:50 ZRCmg/kg dry 35Diesel Range Organics

Surrogate Recovery Control Limits

49-12454 %o-Terphenyl

Gasoline Range Organics by GC/FID

BRL *8015C P7K0535504.6 11/29/17 19:25 ANGmg/kg dry 0.99Gasoline Range Organics

Surrogate Recovery Control Limits

50-13792 %a,a,a-Trifluorotoluene

General Chemistry Parameters

77.1 *SM2540 G P7K055010.100 11/29/17 16:00 JLB% by

Weight

0.100% Solids

This report should not be reproduced, except in its entirety, without the written consent of Prism Laboratories, Inc.

449 Springbrook Road - P.O. Box 240543 - Charlotte, NC 28224-0543

Phone: 704/529-6364 - Toll Free Number: 1-800/529-6364 - Fax: 704/525-0409 Page 5 of 11

12/11/17

Level II QC Report

274 N. Hwy 16, Ste 300 Project No: Howard Property

Project: Howard PropertyCES Group Engineers, LLP

Denver, NC 28037

Attn: Greg Hans

Prism Work Order: 7110483

Time Submitted: 11/27/2017 1:45:00PM

Result Limit

Reporting

Units Level

Spike

Result

Source

%REC

%REC

Limits RPD

RPD

Limit Notes Analyte

Gasoline Range Organics by GC/FID - Quality Control

Batch P7K0535 - 5035

Blank (P7K0535-BLK1) Prepared & Analyzed: 11/29/17

Gasoline Range Organics mg/kg wetBRL 5.0

mg/kg 5.000 50-137Surrogate: a,a,a-Trifluorotoluene 834.15

LCS (P7K0535-BS1) Prepared & Analyzed: 11/29/17

Gasoline Range Organics mg/kg wet47.6 5.0 50.00 41-13895

mg/kg 5.000 50-137Surrogate: a,a,a-Trifluorotoluene 783.90

LCS Dup (P7K0535-BSD1) Prepared & Analyzed: 11/29/17

Gasoline Range Organics mg/kg wet49.9 5.0 50.00 2041-138100 5

mg/kg 5.000 50-137Surrogate: a,a,a-Trifluorotoluene 834.15

This report should not be reproduced, except in its entirety, without the written consent of Prism Laboratories, Inc.

449 Springbrook Road - P.O. Box 240543 - Charlotte, NC 28224-0543

Phone: 704/529-6364 - Toll Free Number: 1-800/529-6364 - Fax: 704/525-0409 Page 6 of 11

12/11/17

Level II QC Report

274 N. Hwy 16, Ste 300 Project No: Howard Property

Project: Howard PropertyCES Group Engineers, LLP

Denver, NC 28037

Attn: Greg Hans

Prism Work Order: 7110483

Time Submitted: 11/27/2017 1:45:00PM

Result Limit

Reporting

Units Level

Spike

Result

Source

%REC

%REC

Limits RPD

RPD

Limit Notes Analyte

Diesel Range Organics by GC/FID - Quality Control

Batch P7K0560 - 3546

Blank (P7K0560-BLK1) Prepared & Analyzed: 11/30/17

Diesel Range Organics mg/kg wetBRL 7.0

mg/kg wet 1.333 49-124Surrogate: o-Terphenyl 781.04

LCS (P7K0560-BS1) Prepared & Analyzed: 11/30/17

Diesel Range Organics mg/kg wet60.7 7.0 66.67 55-10991

mg/kg wet 1.333 49-124Surrogate: o-Terphenyl 951.27

LCS Dup (P7K0560-BSD1) Prepared & Analyzed: 11/30/17

Diesel Range Organics mg/kg wet57.7 7.0 66.67 2055-10987 5

mg/kg wet 1.333 49-124Surrogate: o-Terphenyl 911.21

This report should not be reproduced, except in its entirety, without the written consent of Prism Laboratories, Inc.

449 Springbrook Road - P.O. Box 240543 - Charlotte, NC 28224-0543

Phone: 704/529-6364 - Toll Free Number: 1-800/529-6364 - Fax: 704/525-0409 Page 7 of 11

12/11/17

Level II QC Report

274 N. Hwy 16, Ste 300 Project No: Howard Property

Project: Howard PropertyCES Group Engineers, LLP

Denver, NC 28037

Attn: Greg Hans

Prism Work Order: 7110483

Time Submitted: 11/27/2017 1:45:00PM

Result Limit

Reporting

Units Level

Spike

Result

Source

%REC

%REC

Limits RPD

RPD

Limit Notes Analyte

Total Metals - Quality Control

Batch P7K0517 - 3050B

Blank (P7K0517-BLK1) Prepared: 11/29/17 Analyzed: 11/30/17

Chromium mg/kg wetBRL 0.25

Lead mg/kg wetBRL 0.25

LCS (P7K0517-BS1) Prepared: 11/29/17 Analyzed: 11/30/17

Chromium mg/kg wet23.3 0.25 25.00 80-12093

Lead mg/kg wet23.2 0.25 25.00 80-12093

This report should not be reproduced, except in its entirety, without the written consent of Prism Laboratories, Inc.

449 Springbrook Road - P.O. Box 240543 - Charlotte, NC 28224-0543

Phone: 704/529-6364 - Toll Free Number: 1-800/529-6364 - Fax: 704/525-0409 Page 8 of 11

12/11/17

Level II QC Report

274 N. Hwy 16, Ste 300 Project No: Howard Property

Project: Howard PropertyCES Group Engineers, LLP

Denver, NC 28037

Attn: Greg Hans

Prism Work Order: 7110483

Time Submitted: 11/27/2017 1:45:00PM

Result Limit

Reporting

Units Level

Spike

Result

Source

%REC

%REC

Limits RPD

RPD

Limit Notes Analyte

TCLP Metals - Quality Control

Batch P7L0113 - 3010A

Blank (P7L0113-BLK1) Prepared & Analyzed: 12/07/17

Lead mg/LBRL 0.050

LCS (P7L0113-BS1) Prepared & Analyzed: 12/07/17

Lead mg/L1.23 0.050 1.250 80-12099

Matrix Spike (P7L0113-MS1) Prepared & Analyzed: 12/07/17 Source: 7110483-02

Lead mg/L1.40 0.050 1.250 0.206 75-12596

Matrix Spike Dup (P7L0113-MSD1) Prepared & Analyzed: 12/07/17 Source: 7110483-02

Lead mg/L1.45 0.050 1.250 0.206 2075-12599 3

This report should not be reproduced, except in its entirety, without the written consent of Prism Laboratories, Inc.

449 Springbrook Road - P.O. Box 240543 - Charlotte, NC 28224-0543

Phone: 704/529-6364 - Toll Free Number: 1-800/529-6364 - Fax: 704/525-0409 Page 9 of 11

12/11/17

Level II QC Report

274 N. Hwy 16, Ste 300 Project No: Howard Property

Project: Howard PropertyCES Group Engineers, LLP

Denver, NC 28037

Attn: Greg Hans

Prism Work Order: 7110483

Time Submitted: 11/27/2017 1:45:00PM

Result Limit

Reporting

Units Level

Spike

Result

Source

%REC

%REC

Limits RPD

RPD

Limit Notes Analyte

General Chemistry Parameters - Quality Control

Batch P7K0550 - Solids, Dry Weight

Duplicate (P7K0550-DUP3) Prepared & Analyzed: 11/29/17 Source: 7110483-02

% Solids % by Weight76.1 0.100 76.4 200.4

Sample Extraction Data

Prep Method: 3546

Lab Number Batch Date/TimeInitial Final

P7K05607110483-02 11/30/17 12:0030.08 1g mL

P7K05607110483-03 11/30/17 12:0030.05 1g mL

Prep Method: 5035

Lab Number Batch Date/TimeInitial Final

P7K05357110483-02 11/29/17 15:115.58 5g mL

P7K05357110483-03 11/29/17 15:116.99 5g mL

Prep Method: Solids, Dry Weight

Lab Number Batch Date/TimeInitial Final

P7K05507110483-02 11/29/17 16:0030 30g g

P7K05507110483-03 11/29/17 16:0030 30g g

Prep Method: 1311

Lab Number Batch Date/TimeInitial Final

P7L01147110483-02 12/06/17 14:45100 2000g mL

Prep Method: 3010A

Lab Number Batch Date/TimeInitial Final

P7L01137110483-02 12/07/17 11:0010 50mL mL

Prep Method: 3050B

Lab Number Batch Date/TimeInitial Final

P7K05177110483-02 11/29/17 8:452.02 50g mL

P7K05177110483-02 11/29/17 8:452.02 50g mL

This report should not be reproduced, except in its entirety, without the written consent of Prism Laboratories, Inc.

449 Springbrook Road - P.O. Box 240543 - Charlotte, NC 28224-0543

Phone: 704/529-6364 - Toll Free Number: 1-800/529-6364 - Fax: 704/525-0409 Page 10 of 11

Page 11 of 11

This data package contains the analytical results for the project identified above and includes a Case Narrative, Sample

Results and Chain of Custody. Unless otherwise noted, all samples were received in acceptable condition and processed

according to the referenced methods.

Data qualifiers are flagged individually on each sample. A key reference for the data qualifiers appears at the end of this case

narrative.

NC Certification No. 402

NC Drinking Water Cert No. 37735

SC Certification No. 99012

Case Narrative

12/28/2017

CES Group Engineers, LLP

Greg Hans

274 N. Hwy 16, Ste 300

Denver, NC 28037

Project: Howard Property

Project No.: Howard Property

Lab Submittal Date: 12/21/2017

Prism Work Order: 7120388

Please call if you have any questions relating to this analytical report.

Respectfully,

PRISM LABORATORIES, INC.

VP Laboratory Services

Reviewed ByAngela D. Overcash Angela D. Overcash

VP Laboratory Services

Data Qualifiers Key Reference:

A Matrix interference suspected.

MI Matrix spike outside of the control limits. Matrix interference suspected.

Method Detection LimitMDL

Below Reporting LimitBRL

Relative Percent DifferenceRPD

* Results reported to the reporting limit. All other results are reported to the MDL with values between MDL and

reporting limit indicated with a J.

This report should not be reproduced, except in its entirety, without the written consent of Prism Laboratories, Inc.

449 Springbrook Road - P.O. Box 240543 - Charlotte, NC 28224-0543

Phone: 704/529-6364 - Toll Free Number: 1-800/529-6364 - Fax: 704/525-0409 Page 1 of 11

Sample Receipt Summary12/28/2017

Prism Work Order: 7120388

Client Sample ID MatrixLab Sample ID Date Sampled Date Received

7120388-01 12/21/17TP-1 12/21/17Solid

7120388-02 12/21/17WP-2A@7' 12/21/17Solid

7120388-03 12/21/17WP-3A@6' 12/21/17Solid

7120388-04 12/21/17WP-5A@6' 12/21/17Solid

7120388-05 12/21/17WP-7A@6' 12/21/17Solid

Samples were received in good condition at 2.7 degrees C unless otherwise noted.

This report should not be reproduced, except in its entirety, without the written consent of Prism Laboratories, Inc.

449 Springbrook Road - P.O. Box 240543 - Charlotte, NC 28224-0543

Phone: 704/529-6364 - Toll Free Number: 1-800/529-6364 - Fax: 704/525-0409 Page 2 of 11

Client ID ResultParameter Method UnitsPrism ID

Prism Work Order: 7120388

12/28/2017

Summary of Detections

53 mg/kg dry7120388-01 TP-1 Chromium *6010D

47 mg/kg dry7120388-01 TP-1 Lead *6010D

25 mg/kg dry7120388-02 WP-2A@7' Chromium *6010D

35 mg/kg dry7120388-02 WP-2A@7' Lead *6010D

60 mg/kg dry7120388-03 WP-3A@6' Diesel Range Organics *8015C

33 mg/kg dry7120388-03 WP-3A@6' Chromium *6010D

140 mg/kg dry7120388-03 WP-3A@6' Lead *6010D

180 mg/kg dry7120388-04 WP-5A@6' Diesel Range Organics *8015C

24 mg/kg dry7120388-04 WP-5A@6' Chromium *6010D

35 mg/kg dry7120388-04 WP-5A@6' Lead *6010D

61 mg/kg dry7120388-05 WP-7A@6' Chromium *6010D

55 mg/kg dry7120388-05 WP-7A@6' Lead *6010D

This report should not be reproduced, except in its entirety, without the written consent of Prism Laboratories, Inc.

449 Springbrook Road - P.O. Box 240543 - Charlotte, NC 28224-0543

Phone: 704/529-6364 - Toll Free Number: 1-800/529-6364 - Fax: 704/525-0409 Page 3 of 11

Laboratory Report12/28/2017

ResultParameter Batch

IDReport

Limit

Analysis

Date/Time

MethodDilution

FactorUnits MDL Analyst

274 N. Hwy 16, Ste 300 Project No.:

Project: Howard PropertyCES Group Engineers, LLP

Denver, NC 28037

Attn: Greg Hans

Sample Matrix: Solid

Client Sample ID: TP-1

Prism Sample ID: 7120388-01

Prism Work Order: 7120388

Time Collected: 12/21/17 08:30

Time Submitted: 12/21/17 14:43

Howard Property

General Chemistry Parameters

84.4 *SM2540 G P7L042610.100 12/27/17 16:30 BJC% by

Weight

0.100% Solids

Total Metals

53 *6010D P7L038210.30 12/22/17 17:13 JABmg/kg dry 0.050Chromium

47 *6010D P7L038210.30 12/22/17 17:13 JABmg/kg dry 0.055Lead

This report should not be reproduced, except in its entirety, without the written consent of Prism Laboratories, Inc.

449 Springbrook Road - P.O. Box 240543 - Charlotte, NC 28224-0543

Phone: 704/529-6364 - Toll Free Number: 1-800/529-6364 - Fax: 704/525-0409 Page 4 of 11

Laboratory Report12/28/2017

ResultParameter Batch

IDReport

Limit

Analysis

Date/Time

MethodDilution

FactorUnits MDL Analyst

274 N. Hwy 16, Ste 300 Project No.:

Project: Howard PropertyCES Group Engineers, LLP

Denver, NC 28037

Attn: Greg Hans

Sample Matrix: Solid

Client Sample ID: WP-2A@7'

Prism Sample ID: 7120388-02

Prism Work Order: 7120388

Time Collected: 12/21/17 11:25

Time Submitted: 12/21/17 14:43

Howard Property

Diesel Range Organics by GC/FID

BRL *8015C P7L038718.9 12/27/17 16:24 ZRCmg/kg dry 3.5Diesel Range Organics

Surrogate Recovery Control Limits

49-12455 %o-Terphenyl

General Chemistry Parameters

78.4 *SM2540 G P7L042610.100 12/27/17 16:30 BJC% by

Weight

0.100% Solids

Total Metals

25 *6010D P7L038210.31 12/22/17 17:45 JABmg/kg dry 0.052Chromium

35 *6010D P7L038210.31 12/22/17 17:45 JABmg/kg dry 0.058Lead

This report should not be reproduced, except in its entirety, without the written consent of Prism Laboratories, Inc.

449 Springbrook Road - P.O. Box 240543 - Charlotte, NC 28224-0543

Phone: 704/529-6364 - Toll Free Number: 1-800/529-6364 - Fax: 704/525-0409 Page 5 of 11

Laboratory Report12/28/2017

ResultParameter Batch

IDReport

Limit

Analysis

Date/Time

MethodDilution

FactorUnits MDL Analyst

274 N. Hwy 16, Ste 300 Project No.:

Project: Howard PropertyCES Group Engineers, LLP

Denver, NC 28037

Attn: Greg Hans

Sample Matrix: Solid

Client Sample ID: WP-3A@6'

Prism Sample ID: 7120388-03

Prism Work Order: 7120388

Time Collected: 12/21/17 11:35

Time Submitted: 12/21/17 14:43

Howard Property

Diesel Range Organics by GC/FID

60 *8015C P7L038718.7 12/27/17 21:18 ZRCmg/kg dry 3.4Diesel Range Organics

Surrogate Recovery Control Limits

49-12454 %o-Terphenyl

General Chemistry Parameters

80.5 *SM2540 G P7L042610.100 12/27/17 16:30 BJC% by

Weight

0.100% Solids

Total Metals

33 *6010D P7L038210.31 12/22/17 17:56 JABmg/kg dry 0.052Chromium

140 *6010D P7L038210.31 12/22/17 17:56 JABmg/kg dry 0.058Lead

This report should not be reproduced, except in its entirety, without the written consent of Prism Laboratories, Inc.

449 Springbrook Road - P.O. Box 240543 - Charlotte, NC 28224-0543

Phone: 704/529-6364 - Toll Free Number: 1-800/529-6364 - Fax: 704/525-0409 Page 6 of 11

Laboratory Report12/28/2017

ResultParameter Batch

IDReport

Limit

Analysis

Date/Time

MethodDilution

FactorUnits MDL Analyst

274 N. Hwy 16, Ste 300 Project No.:

Project: Howard PropertyCES Group Engineers, LLP

Denver, NC 28037

Attn: Greg Hans

Sample Matrix: Solid

Client Sample ID: WP-5A@6'

Prism Sample ID: 7120388-04

Prism Work Order: 7120388

Time Collected: 12/21/17 11:45

Time Submitted: 12/21/17 14:43

Howard Property

Diesel Range Organics by GC/FID

180 *8015C P7L038718.9 12/27/17 23:44 ZRCmg/kg dry 3.5Diesel Range Organics

Surrogate Recovery Control Limits

49-12456 %o-Terphenyl

General Chemistry Parameters

78.8 *SM2540 G P7L042610.100 12/27/17 16:30 BJC% by

Weight

0.100% Solids

Total Metals

24 *6010D P7L038210.32 12/22/17 18:07 JABmg/kg dry 0.054Chromium

35 *6010D P7L038210.32 12/22/17 18:07 JABmg/kg dry 0.060Lead

This report should not be reproduced, except in its entirety, without the written consent of Prism Laboratories, Inc.

449 Springbrook Road - P.O. Box 240543 - Charlotte, NC 28224-0543

Phone: 704/529-6364 - Toll Free Number: 1-800/529-6364 - Fax: 704/525-0409 Page 7 of 11

Laboratory Report12/28/2017

ResultParameter Batch

IDReport

Limit

Analysis

Date/Time

MethodDilution

FactorUnits MDL Analyst

274 N. Hwy 16, Ste 300 Project No.:

Project: Howard PropertyCES Group Engineers, LLP

Denver, NC 28037

Attn: Greg Hans

Sample Matrix: Solid

Client Sample ID: WP-7A@6'

Prism Sample ID: 7120388-05

Prism Work Order: 7120388

Time Collected: 12/21/17 13:30

Time Submitted: 12/21/17 14:43

Howard Property

Diesel Range Organics by GC/FID

BRL *8015C P7L0387112 12/27/17 17:01 ZRCmg/kg dry 4.7Diesel Range Organics

Surrogate Recovery Control Limits

49-12455 %o-Terphenyl

General Chemistry Parameters

58.5 *SM2540 G P7L042610.100 12/27/17 16:30 BJC% by

Weight

0.100% Solids

Total Metals

61 *6010D P7L038210.42 12/22/17 18:17 JABmg/kg dry 0.070Chromium

55 *6010D P7L038210.42 12/22/17 18:17 JABmg/kg dry 0.078Lead

This report should not be reproduced, except in its entirety, without the written consent of Prism Laboratories, Inc.

449 Springbrook Road - P.O. Box 240543 - Charlotte, NC 28224-0543

Phone: 704/529-6364 - Toll Free Number: 1-800/529-6364 - Fax: 704/525-0409 Page 8 of 11

12/28/17

Level II QC Report

274 N. Hwy 16, Ste 300 Project No: Howard Property

Project: Howard PropertyCES Group Engineers, LLP

Denver, NC 28037

Attn: Greg Hans

Prism Work Order: 7120388

Time Submitted: 12/21/2017 2:43:00PM

Result Limit

Reporting

Units Level

Spike

Result

Source

%REC

%REC

Limits RPD

RPD

Limit Notes Analyte

Diesel Range Organics by GC/FID - Quality Control

Batch P7L0387 - 3546

Blank (P7L0387-BLK1) Prepared: 12/22/17 Analyzed: 12/27/17

Diesel Range Organics mg/kg wetBRL 7.0

mg/kg wet 1.333 49-124Surrogate: o-Terphenyl 520.697

LCS (P7L0387-BS1) Prepared: 12/22/17 Analyzed: 12/27/17

Diesel Range Organics mg/kg wet38.9 7.0 66.67 55-10958

mg/kg wet 1.333 49-124Surrogate: o-Terphenyl 560.747

LCS Dup (P7L0387-BSD1) Prepared: 12/22/17 Analyzed: 12/27/17

Diesel Range Organics mg/kg wet45.7 7.0 66.67 2055-10969 16

mg/kg wet 1.333 49-124Surrogate: o-Terphenyl 630.836

This report should not be reproduced, except in its entirety, without the written consent of Prism Laboratories, Inc.

449 Springbrook Road - P.O. Box 240543 - Charlotte, NC 28224-0543

Phone: 704/529-6364 - Toll Free Number: 1-800/529-6364 - Fax: 704/525-0409 Page 9 of 11

12/28/17

Level II QC Report

274 N. Hwy 16, Ste 300 Project No: Howard Property

Project: Howard PropertyCES Group Engineers, LLP

Denver, NC 28037

Attn: Greg Hans

Prism Work Order: 7120388

Time Submitted: 12/21/2017 2:43:00PM

Result Limit

Reporting

Units Level

Spike

Result

Source

%REC

%REC

Limits RPD

RPD

Limit Notes Analyte

Total Metals - Quality Control

Batch P7L0382 - 3050B

Blank (P7L0382-BLK1) Prepared & Analyzed: 12/22/17

Chromium mg/kg wetBRL 0.25

Lead mg/kg wetBRL 0.25

LCS (P7L0382-BS1) Prepared & Analyzed: 12/22/17

Chromium mg/kg wet25.8 0.25 25.00 80-120103

Lead mg/kg wet25.3 0.25 25.00 80-120101

Matrix Spike (P7L0382-MS1) Prepared & Analyzed: 12/22/17 Source: 7120388-01

Chromium mg/kg dry75.3 0.30 30.07 53.1 MI75-12574

Lead mg/kg dry69.6 0.30 30.07 47.3 MI75-12574

Matrix Spike Dup (P7L0382-MSD1) Prepared & Analyzed: 12/22/17 Source: 7120388-01

Chromium mg/kg dry92.5 0.30 30.38 53.1 20 MI75-125130 20

Lead mg/kg dry60.8 0.30 30.38 47.3 20 MI75-12544 14

Post Spike (P7L0382-PS1) Prepared & Analyzed: 12/22/17 Source: 7120388-01

Chromium mg/L2.53 1.000 1.79 A80-12074

Lead mg/L2.25 1.000 1.60 A80-12065

Sample Extraction Data

Prep Method: 3546

Lab Number Batch Date/TimeInitial Final

P7L03877120388-02 12/22/17 11:3730.01 1g mL

P7L03877120388-03 12/22/17 11:3730.01 1g mL

P7L03877120388-04 12/22/17 11:3730.03 1g mL

P7L03877120388-05 12/22/17 11:3730.02 1g mL

Prep Method: Solids, Dry Weight

Lab Number Batch Date/TimeInitial Final

P7L04267120388-01 12/27/17 16:3030 30g g

P7L04267120388-02 12/27/17 16:3030 30g g

P7L04267120388-03 12/27/17 16:3030 30g g

P7L04267120388-04 12/27/17 16:3030 30g g

P7L04267120388-05 12/27/17 16:3030 30g g

Prep Method: 3050B

Lab Number Batch Date/TimeInitial Final

P7L03827120388-01 12/22/17 9:451.99 50g mL

P7L03827120388-02 12/22/17 9:452.05 50g mL

P7L03827120388-03 12/22/17 9:452 50g mL

P7L03827120388-04 12/22/17 9:451.97 50g mL

P7L03827120388-05 12/22/17 9:452.05 50g mL

This report should not be reproduced, except in its entirety, without the written consent of Prism Laboratories, Inc.

449 Springbrook Road - P.O. Box 240543 - Charlotte, NC 28224-0543

Phone: 704/529-6364 - Toll Free Number: 1-800/529-6364 - Fax: 704/525-0409 Page 10 of 11

Page 11 of 11

This data package contains the analytical results for the project identified above and includes a Case Narrative, Sample

Results and Chain of Custody. Unless otherwise noted, all samples were received in acceptable condition and processed

according to the referenced methods.

Data qualifiers are flagged individually on each sample. A key reference for the data qualifiers appears at the end of this case

narrative.

NC Certification No. 402

NC Drinking Water Cert No. 37735

SC Certification No. 99012

Case Narrative

12/28/2017

CES Group Engineers, LLP

Greg Hans

274 N. Hwy 16, Ste 300

Denver, NC 28037

Project: Howard Property

Project No.: Howard Property

Lab Submittal Date: 12/20/2017

Prism Work Order: 7120327

Please call if you have any questions relating to this analytical report.

Respectfully,

PRISM LABORATORIES, INC.

VP Laboratory Services

Reviewed ByAngela D. Overcash Angela D. Overcash

VP Laboratory Services

Data Qualifiers Key Reference:

MI Matrix spike outside of the control limits. Matrix interference suspected.

Method Detection LimitMDL

Below Reporting LimitBRL

Relative Percent DifferenceRPD

* Results reported to the reporting limit. All other results are reported to the MDL with values between MDL and

reporting limit indicated with a J.

This report should not be reproduced, except in its entirety, without the written consent of Prism Laboratories, Inc.

449 Springbrook Road - P.O. Box 240543 - Charlotte, NC 28224-0543

Phone: 704/529-6364 - Toll Free Number: 1-800/529-6364 - Fax: 704/525-0409 Page 1 of 9

Sample Receipt Summary12/28/2017

Prism Work Order: 7120327

Client Sample ID MatrixLab Sample ID Date Sampled Date Received

7120327-01 12/19/17WP-8A@6' 12/20/17Solid

7120327-02 12/19/17WP-9A@6' 12/20/17Solid

7120327-03 12/19/17WP-10A@6' 12/20/17Solid

Samples were received in good condition at 5.5 degrees C unless otherwise noted.

This report should not be reproduced, except in its entirety, without the written consent of Prism Laboratories, Inc.

449 Springbrook Road - P.O. Box 240543 - Charlotte, NC 28224-0543

Phone: 704/529-6364 - Toll Free Number: 1-800/529-6364 - Fax: 704/525-0409 Page 2 of 9

Client ID ResultParameter Method UnitsPrism ID

Prism Work Order: 7120327

12/28/2017

Summary of Detections

30 mg/kg dry7120327-01 WP-8A@6' Chromium *6010D

32 mg/kg dry7120327-01 WP-8A@6' Lead *6010D

28 mg/kg dry7120327-02 WP-9A@6' Chromium *6010D

38 mg/kg dry7120327-02 WP-9A@6' Lead *6010D

28 mg/kg dry7120327-03 WP-10A@6' Chromium *6010D

43 mg/kg dry7120327-03 WP-10A@6' Lead *6010D

This report should not be reproduced, except in its entirety, without the written consent of Prism Laboratories, Inc.

449 Springbrook Road - P.O. Box 240543 - Charlotte, NC 28224-0543

Phone: 704/529-6364 - Toll Free Number: 1-800/529-6364 - Fax: 704/525-0409 Page 3 of 9

Laboratory Report12/28/2017

ResultParameter Batch

IDReport

Limit

Analysis

Date/Time

MethodDilution

FactorUnits MDL Analyst

274 N. Hwy 16, Ste 300 Project No.:

Project: Howard PropertyCES Group Engineers, LLP

Denver, NC 28037

Attn: Greg Hans

Sample Matrix: Solid

Client Sample ID: WP-8A@6'

Prism Sample ID: 7120327-01

Prism Work Order: 7120327

Time Collected: 12/19/17 14:55

Time Submitted: 12/20/17 07:50

Howard Property

Diesel Range Organics by GC/FID

BRL *8015C P7L034618.7 12/21/17 20:40 ZRCmg/kg dry 3.4Diesel Range Organics

Surrogate Recovery Control Limits

49-12463 %o-Terphenyl

General Chemistry Parameters

80.8 *SM2540 G P7L038610.100 12/21/17 16:00 JLB% by

Weight

0.100% Solids

Total Metals

30 *6010D P7L035410.31 12/27/17 20:26 JABmg/kg dry 0.052Chromium

32 *6010D P7L035410.31 12/27/17 20:26 JABmg/kg dry 0.058Lead

This report should not be reproduced, except in its entirety, without the written consent of Prism Laboratories, Inc.

449 Springbrook Road - P.O. Box 240543 - Charlotte, NC 28224-0543

Phone: 704/529-6364 - Toll Free Number: 1-800/529-6364 - Fax: 704/525-0409 Page 4 of 9

Laboratory Report12/28/2017

ResultParameter Batch

IDReport

Limit

Analysis

Date/Time

MethodDilution

FactorUnits MDL Analyst

274 N. Hwy 16, Ste 300 Project No.:

Project: Howard PropertyCES Group Engineers, LLP

Denver, NC 28037

Attn: Greg Hans

Sample Matrix: Solid

Client Sample ID: WP-9A@6'

Prism Sample ID: 7120327-02

Prism Work Order: 7120327

Time Collected: 12/19/17 14:57

Time Submitted: 12/20/17 07:50

Howard Property

Diesel Range Organics by GC/FID

BRL *8015C P7L034618.5 12/21/17 21:16 ZRCmg/kg dry 3.3Diesel Range Organics

Surrogate Recovery Control Limits

49-12466 %o-Terphenyl

General Chemistry Parameters

82.0 *SM2540 G P7L038610.100 12/21/17 16:00 JLB% by

Weight

0.100% Solids

Total Metals

28 *6010D P7L035410.31 12/27/17 20:57 JABmg/kg dry 0.052Chromium

38 *6010D P7L035410.31 12/27/17 20:57 JABmg/kg dry 0.057Lead

This report should not be reproduced, except in its entirety, without the written consent of Prism Laboratories, Inc.

449 Springbrook Road - P.O. Box 240543 - Charlotte, NC 28224-0543

Phone: 704/529-6364 - Toll Free Number: 1-800/529-6364 - Fax: 704/525-0409 Page 5 of 9

Laboratory Report12/28/2017

ResultParameter Batch

IDReport

Limit

Analysis

Date/Time

MethodDilution

FactorUnits MDL Analyst

274 N. Hwy 16, Ste 300 Project No.:

Project: Howard PropertyCES Group Engineers, LLP

Denver, NC 28037

Attn: Greg Hans

Sample Matrix: Solid

Client Sample ID: WP-10A@6'

Prism Sample ID: 7120327-03

Prism Work Order: 7120327

Time Collected: 12/19/17 14:59

Time Submitted: 12/20/17 07:50

Howard Property

Diesel Range Organics by GC/FID

BRL *8015C P7L034618.6 12/21/17 21:53 ZRCmg/kg dry 3.4Diesel Range Organics

Surrogate Recovery Control Limits

49-12456 %o-Terphenyl

General Chemistry Parameters

80.7 *SM2540 G P7L038610.100 12/21/17 16:00 JLB% by

Weight

0.100% Solids

Total Metals

28 *6010D P7L035410.32 12/27/17 21:07 JABmg/kg dry 0.053Chromium

43 *6010D P7L035410.32 12/27/17 21:07 JABmg/kg dry 0.059Lead

This report should not be reproduced, except in its entirety, without the written consent of Prism Laboratories, Inc.

449 Springbrook Road - P.O. Box 240543 - Charlotte, NC 28224-0543

Phone: 704/529-6364 - Toll Free Number: 1-800/529-6364 - Fax: 704/525-0409 Page 6 of 9

12/28/17

Level II QC Report

274 N. Hwy 16, Ste 300 Project No: Howard Property

Project: Howard PropertyCES Group Engineers, LLP

Denver, NC 28037

Attn: Greg Hans

Prism Work Order: 7120327

Time Submitted: 12/20/2017 7:50:00AM

Result Limit

Reporting

Units Level

Spike

Result

Source

%REC

%REC

Limits RPD

RPD

Limit Notes Analyte

Diesel Range Organics by GC/FID - Quality Control

Batch P7L0346 - 3546

Blank (P7L0346-BLK1) Prepared: 12/20/17 Analyzed: 12/21/17

Diesel Range Organics mg/kg wetBRL 7.0

mg/kg wet 1.333 49-124Surrogate: o-Terphenyl 680.911

LCS (P7L0346-BS1) Prepared: 12/20/17 Analyzed: 12/21/17

Diesel Range Organics mg/kg wet50.3 7.0 66.67 55-10975

mg/kg wet 1.333 49-124Surrogate: o-Terphenyl 670.899

LCS Dup (P7L0346-BSD1) Prepared: 12/20/17 Analyzed: 12/21/17

Diesel Range Organics mg/kg wet54.5 7.0 66.67 2055-10982 8

mg/kg wet 1.333 49-124Surrogate: o-Terphenyl 720.960

Matrix Spike (P7L0346-MS1) Prepared: 12/20/17 Analyzed: 12/21/17 Source: 7120327-03

Diesel Range Organics mg/kg dry55.5 8.7 82.49 BRL 50-11767

mg/kg dry 1.650 49-124Surrogate: o-Terphenyl 580.955

Matrix Spike Dup (P7L0346-MSD1) Prepared: 12/20/17 Analyzed: 12/21/17 Source: 7120327-03

Diesel Range Organics mg/kg dry62.7 8.7 82.46 BRL 2450-11776 12

mg/kg dry 1.649 49-124Surrogate: o-Terphenyl 661.08

This report should not be reproduced, except in its entirety, without the written consent of Prism Laboratories, Inc.

449 Springbrook Road - P.O. Box 240543 - Charlotte, NC 28224-0543

Phone: 704/529-6364 - Toll Free Number: 1-800/529-6364 - Fax: 704/525-0409 Page 7 of 9

12/28/17

Level II QC Report

274 N. Hwy 16, Ste 300 Project No: Howard Property

Project: Howard PropertyCES Group Engineers, LLP

Denver, NC 28037

Attn: Greg Hans

Prism Work Order: 7120327

Time Submitted: 12/20/2017 7:50:00AM

Result Limit

Reporting

Units Level

Spike

Result

Source

%REC

%REC

Limits RPD

RPD

Limit Notes Analyte

Total Metals - Quality Control

Batch P7L0354 - 3050B

Blank (P7L0354-BLK1) Prepared: 12/21/17 Analyzed: 12/27/17

Chromium mg/kg wetBRL 0.25

Lead mg/kg wetBRL 0.25

LCS (P7L0354-BS1) Prepared: 12/21/17 Analyzed: 12/27/17

Chromium mg/kg wet25.6 0.25 25.00 80-120102

Lead mg/kg wet25.0 0.25 25.00 80-120100

Matrix Spike (P7L0354-MS1) Prepared: 12/21/17 Analyzed: 12/27/17 Source: 7120327-01

Chromium mg/kg dry53.4 0.31 31.43 30.0 75-12575

Lead mg/kg dry62.0 0.31 31.43 32.2 75-12595

Matrix Spike Dup (P7L0354-MSD1) Prepared: 12/21/17 Analyzed: 12/27/17 Source: 7120327-01

Chromium mg/kg dry55.3 0.32 31.59 30.0 2075-12580 4

Lead mg/kg dry59.9 0.32 31.59 32.2 2075-12588 4

Post Spike (P7L0354-PS1) Prepared: 12/21/17 Analyzed: 12/27/17 Source: 7120327-01

Chromium mg/L1.67 1.000 0.968 MI80-12070

Lead mg/L1.70 1.000 1.04 MI80-12066

Sample Extraction Data

Prep Method: 3546

Lab Number Batch Date/TimeInitial Final

P7L03467120327-01 12/20/17 15:3530.01 1g mL

P7L03467120327-02 12/20/17 15:3530.04 1g mL

P7L03467120327-03 12/20/17 15:3530.09 1g mL

Prep Method: Solids, Dry Weight

Lab Number Batch Date/TimeInitial Final

P7L03867120327-01 12/21/17 16:0030 30g g

P7L03867120327-02 12/21/17 16:0030 30g g

P7L03867120327-03 12/21/17 16:0030 30g g

Prep Method: 3050B

Lab Number Batch Date/TimeInitial Final

P7L03547120327-01 12/21/17 8:351.98 50g mL

P7L03547120327-02 12/21/17 8:351.98 50g mL

P7L03547120327-03 12/21/17 8:351.95 50g mL

This report should not be reproduced, except in its entirety, without the written consent of Prism Laboratories, Inc.

449 Springbrook Road - P.O. Box 240543 - Charlotte, NC 28224-0543

Phone: 704/529-6364 - Toll Free Number: 1-800/529-6364 - Fax: 704/525-0409 Page 8 of 9

Page 9 of 9

This data package contains the analytical results for the project identified above and includes a Case Narrative, Sample

Results and Chain of Custody. Unless otherwise noted, all samples were received in acceptable condition and processed

according to the referenced methods.

Data qualifiers are flagged individually on each sample. A key reference for the data qualifiers appears at the end of this case

narrative.

NC Certification No. 402

NC Drinking Water Cert No. 37735

SC Certification No. 99012

Case Narrative

01/09/2018

CES Group Engineers, LLP

Greg Hans

274 N. Hwy 16, Ste 300

Denver, NC 28037

Project: Howard Property

Lab Submittal Date: 01/04/2018

Prism Work Order: 8010037

Please call if you have any questions relating to this analytical report.

Respectfully,

PRISM LABORATORIES, INC.

VP Laboratory Services

Reviewed ByAngela D. Overcash Angela D. Overcash

VP Laboratory Services

Data Qualifiers Key Reference:

Method Detection LimitMDL

Below Reporting LimitBRL

Relative Percent DifferenceRPD

* Results reported to the reporting limit. All other results are reported to the MDL with values between MDL and

reporting limit indicated with a J.

This report should not be reproduced, except in its entirety, without the written consent of Prism Laboratories, Inc.

449 Springbrook Road - P.O. Box 240543 - Charlotte, NC 28224-0543

Phone: 704/529-6364 - Toll Free Number: 1-800/529-6364 - Fax: 704/525-0409 Page 1 of 6

Sample Receipt Summary01/09/2018

Prism Work Order: 8010037

Client Sample ID MatrixLab Sample ID Date Sampled Date Received

8010037-01 01/04/18WP-5B 01/04/18Solid

Samples were received in good condition at 4.3 degrees C unless otherwise noted.

This report should not be reproduced, except in its entirety, without the written consent of Prism Laboratories, Inc.

449 Springbrook Road - P.O. Box 240543 - Charlotte, NC 28224-0543

Phone: 704/529-6364 - Toll Free Number: 1-800/529-6364 - Fax: 704/525-0409 Page 2 of 6

Laboratory Report01/09/2018

ResultParameter Batch

IDReport

Limit

Analysis

Date/Time

MethodDilution

FactorUnits MDL Analyst

274 N. Hwy 16, Ste 300

Project: Howard PropertyCES Group Engineers, LLP

Denver, NC 28037

Attn: Greg Hans

Sample Matrix: Solid

Client Sample ID:

Prism Sample ID: 8010037-01

Prism Work Order: 8010037

Time Collected: 01/04/18 09:25

Time Submitted: 01/04/18 12:50

WP-5B

Diesel Range Organics by GC/FID

BRL *8015C P8A006018.7 1/8/18 16:40 ZRCmg/kg dry 3.4Diesel Range Organics

Surrogate Recovery Control Limits

49-12458 %o-Terphenyl

General Chemistry Parameters

80.1 *SM2540 G P8A008510.100 1/8/18 15:40 BJC% by

Weight

0.100% Solids

This report should not be reproduced, except in its entirety, without the written consent of Prism Laboratories, Inc.

449 Springbrook Road - P.O. Box 240543 - Charlotte, NC 28224-0543

Phone: 704/529-6364 - Toll Free Number: 1-800/529-6364 - Fax: 704/525-0409 Page 3 of 6

1/9/18

Level II QC Report

274 N. Hwy 16, Ste 300

Project: Howard PropertyCES Group Engineers, LLP

Denver, NC 28037

Attn: Greg Hans

Prism Work Order: 8010037

Time Submitted: 1/4/2018 12:50:00PM

Result Limit

Reporting

Units Level

Spike

Result

Source

%REC

%REC

Limits RPD

RPD

Limit Notes Analyte

Diesel Range Organics by GC/FID - Quality Control

Batch P8A0060 - 3546

Blank (P8A0060-BLK1) Prepared: 01/05/18 Analyzed: 01/08/18

Diesel Range Organics mg/kg wetBRL 7.0

mg/kg wet 1.333 49-124Surrogate: o-Terphenyl 791.05

LCS (P8A0060-BS1) Prepared: 01/05/18 Analyzed: 01/08/18

Diesel Range Organics mg/kg wet40.8 7.0 66.67 55-10961

mg/kg wet 1.333 49-124Surrogate: o-Terphenyl 550.732

LCS Dup (P8A0060-BSD1) Prepared: 01/05/18 Analyzed: 01/08/18

Diesel Range Organics mg/kg wet47.1 7.0 66.67 2055-10971 14

mg/kg wet 1.333 49-124Surrogate: o-Terphenyl 640.851

Matrix Spike (P8A0060-MS1) Prepared: 01/05/18 Analyzed: 01/09/18 Source: 8010037-01

Diesel Range Organics mg/kg dry58.1 8.7 83.17 BRL 50-11770

mg/kg dry 1.663 49-124Surrogate: o-Terphenyl 631.05

Matrix Spike Dup (P8A0060-MSD1) Prepared: 01/05/18 Analyzed: 01/09/18 Source: 8010037-01

Diesel Range Organics mg/kg dry48.0 8.7 83.22 BRL 2450-11758 19

mg/kg dry 1.664 49-124Surrogate: o-Terphenyl 530.882

This report should not be reproduced, except in its entirety, without the written consent of Prism Laboratories, Inc.

449 Springbrook Road - P.O. Box 240543 - Charlotte, NC 28224-0543

Phone: 704/529-6364 - Toll Free Number: 1-800/529-6364 - Fax: 704/525-0409 Page 4 of 6

1/9/18

Level II QC Report

274 N. Hwy 16, Ste 300

Project: Howard PropertyCES Group Engineers, LLP

Denver, NC 28037

Attn: Greg Hans

Prism Work Order: 8010037

Time Submitted: 1/4/2018 12:50:00PM

Result Limit

Reporting

Units Level

Spike

Result

Source

%REC

%REC

Limits RPD

RPD

Limit Notes Analyte

General Chemistry Parameters - Quality Control

Batch P8A0085 - Solids, Dry Weight

Duplicate (P8A0085-DUP1) Prepared & Analyzed: 01/08/18 Source: 8010037-01

% Solids % by Weight80.4 0.100 80.1 200.4

Sample Extraction Data

Prep Method: 3546

Lab Number Batch Date/TimeInitial Final

P8A00608010037-01 01/05/18 10:1930.05 1g mL

Prep Method: Solids, Dry Weight

Lab Number Batch Date/TimeInitial Final

P8A00858010037-01 01/08/18 15:4030 30g g

This report should not be reproduced, except in its entirety, without the written consent of Prism Laboratories, Inc.

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APPENDIX D