A prior Phase II Brownfields Assessment (Phase II) performed by the Maryland Department of the Environment (MDE) identified metals and polycyclic aromatic hydrocarbon (PAH) impacts in the soils of the subject property. The MDE subsequently issued a No Further Requirements Determination (NFRD) that included the restrictions on future soil excavation and disposal requirements in 2001. Future development of the subject property required the excavation and removal of some of the impacted material from the subject property. Therefore, GTA prepared a Phase II ESA, which further characterized soil conditions. Based on the results of the Phase II ESA, GTA prepared an Environmental Management Plan (EMP) to manage environmental issues in accordance with the NFRD. The EMP was approved by the MDE and was implemented. The subject property historically was undeveloped until the 1920s, when it was used for steel polishing, metal fabrication/works, and production until 2009. Warehouse structures, office space, loading areas, machining areas, a railroad spur, and various storage structures have been located on the subject property. Historical aerials and maps indicate portions of the building’s floor were earth and concrete at various times during its use as metal fabrication and polishing operations. Laboratory analysis of samples collected from the site reported elevated concentrations of metals (arsenic, lead, and mercury) and PAHs in soil. In addition, one diesel UST was discovered at the subject property. The UST was removed during site development and property closed through the MDE’s Oil Control Program (OCP). The proposed remedy included removal of metals and PAH-impacted soil, soil-vapor monitoring, UST removal, and excavation restrictions enforced by the project manager. GTA monitored and documented these activities and this documentation was provided to Maryland’s Voluntary Cleanup Program (VCP) and the MDE subsequently issued a new NFRD.