23035 Theron Soil Export Letter 20220620

June 20, 2022

Sent Via Email

Will Smith
CUSA NC Holdings, LP
c/o Camden
1420 Spring Hill Road, Suite 200
McLean, VA 22102
[e-mail]

Subject: Brownfields Soil Management Options Updated
Chadbourn Mill and Theron Properties Brownfields Properties
Charlotte, Mecklenburg County
Brownfields Project Nos 20086-16-060 and 23035-19-060

Dear Mr. Smith:

The North Carolina Department of Environmental Quality (DEQ) Brownfields Program received
and reviewed a request to export an approximately 3,000 cubic yards of soils from Chadbourn Mill
(20086-16-060) and Theron Properties (23035-19-060) Brownfields Properties. This request was
submitted on your behalf by Ms. Christine Schaefer of Hart & Hickman PC (H&H). DEQ
understands the redevelopment on these brownfields properties will be done jointly under the
DEQ-approved Environmental Management Plan (EMP) dated January 27, 2020.

DEQ Brownfields reviewed the soil analytical data provided in the Supplemental Brownfields
Assessment Report dated October 30, 2019 and EMP referenced above, both documents were
prepared by H&H. Based on our review of the data, DEQ Brownfield’s agree that these soils may
be exported as outlined in the table below. Other Beneficial Fill and Land Clearing & Inert Debris
Landfill (LCID) options may be available; however, DEQ requires that the receiving facility be
identified and approved prior to export. The receiving facility should have metals concentrations
which are consistent with those from the Brownfields Property. Upon determination of the
receiving facility, please contact us and we will assist you in determining if additional sampling is
needed for the receiving facility.

Stockpile Area Disposal Options Volume
EX-6, EX-15, EX-16 Old 27, CDLF, MSWLF Approximately 1,000 cu yds
EX-7, EX-8, EX-10 Old 27, CDLF, MSWLF Approximately 2,000 cu yds
Old 27 = Old 27 Landfill at 114 Tate Street, Mount Holly, NC
CDLF = Construction & Demolition landfill
MSWLF = Municipal Solid Waste landfill facility

Chadbourn Mills/Theron Properties
June 20, 2022
Page 2

All soil export must be conducted under the DEQ Brownfields approved EMP. Per the Chadbourn
Mill and Theron Properties EMP, the soils will be field screened during excavation prior to export
from the property. If unanticipated impacts are identified during excavation, please refer to the
EMP for further actions and cease transfer until appropriate characterization can be completed. In
addition, in accordance with the approved EMP, annual Redevelopment Summary Reports will be
submitted to DEQ Brownfields. Details related to the disposition of this soil including but not
limited to, total volume, general description of field screening efforts, etc. should be included with
each Property’s Redevelopment Summary Report.

Please be advised that this approval does not waive any applicable requirement to obtain any
necessary permits, licenses or certifications which may be required from other state or local
entities. If you have questions about this correspondence or require additional information, please
feel free to contact me by phone at 704-661-0330 or by email at [e-mail].

Sincerely,

Carolyn Minnich
Brownfields Project Manager

ec: Brownfields Property Management Unit
Christine Schaefer [e-mail]
Craik, Charles <[e-mail]>
Ralph McGee <[e-mail]>