19039_Oneida Mill_EMP_20160114

INERAL
PRINGS
envlronment.a~ p.c.
4600 Mineral Springs Lane
Raleigh, NC 27616
January 14, 2016
Mr. Lebeed Kady
North Carolina Brownfields Program
1646 Mail Service Center
Raleigh, North Carolina 27699-1646
Subject: Environmental Management Plan
Oneida Mills/Former Kayser Roth Facility
219 Hardin Street
Graham, North Carolina
MSEJob838
Dear Mr. Kady:
Please find attached the completed Brownfields Program Environmental Management Plan. Also
included is the requested Contingency Plan.
If you have any questions, please contact me at [phone].
Sincerely,
Mineral Springs Environmental PC
Kirk B. Pollard, L.G.
Senior Geologist
MINERAL SPRINGS ENVIRONMENTAL, P.C.
4600 MINERAL SPRINGS LANE
RALEIGH, NORTH CAROLINA, 27616
919.261.8186

ENVIRONMENTAL
MANAGEMENT PLAN

ONEIDA MILLS FACILITY
219 WEST HARDEN STREET
GRAHAM, ALAMANCE COUNTY,
NORTH CAROLINA
JANUARY 12, 2016
MSE JOB NO. 838

Prepared For:
MR. RICHARD ANGINO
PUMPKIN HILL MILL, LLC
463 1/2 CAROLINA CIRCLE
WINSTON-SALEM, NORTH CAROLINA, 27104
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EMP Form ver.1, October 23, 2014
NORTH CAROLINA BROWNFIELDS PROGRAM
ENVIRONMENTAL MANAGEMENT PLAN

This form is to be used to prepare an Environmental Management Plan (EMP) for projects in the
North Carolina Brownfields Program at the direction of a project manager for the program.
Prospective Developers and/or their consultants must complete and submit this form and all
pertinent attachments to their project manager prior to any site earthmoving or other
development related activities. For the resultant EMP to be valid for use, it must be completed,
reviewed by the program, and signed by all signers at the bottom. Consult your project
manager if you have questions.

GENERAL INFORMATION

Date: 12/4/2015

Brownfields Assigned Project Name: Oneida Mill Lofts

Brownfields Project Number: 19039-15-060

Brownfields Property Address: 219 Harden Street, Graham, NC 27523

Brownfields Property Area (acres): 7 acres

Is Brownfields Property Subject to RCRA Permit? ฀ Yes x No
If yes enter Permit No.: Click here to enter text.

Is Brownfields Property Subject to a Solid Waste Permit? ฀ Yes x No
If yes, enter Permit No.: Click here to enter text.

COMMUNICATIONS

Prospective Developer (PD): Pumpkin Hill Mill LLC
Phone Numbers: Office: 336-499-1963…..Mobile: [phone]
Email: [e-mail]
Primary PD Contact: Richard Angino
Phone Numbers: Office: 336-499-1963 Mobile: [phone]
[e-mail]
Email:
Environmental Consultant: Mineral Springs
Phone Numbers: Office: 919-261-9186…..Mobile: [phone]
Email: [e-mail]
Brownfields Program Project Manager: Lebeed Kady
Office: 919-707-8378
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EMP Form ver.1, October 23, 2014
Email: [e-mail]

Other DENR Program Contacts (if applicable, i.e., UST Section, Inactive Hazardous Site Branch,
Hazardous Waste, Solid Waste): Click here to enter text.

NOTIFICATIONS TO THE BROWNFIELDS PROGRAM

Advance Notification Times to Brownfields Project Manager: Check each box to accept minimum
notice periods (in calendar days) for each type of onsite task:
On-site assessment or remedial activities: Within 10 days ฀
Construction or grading start: Within 10 days ฀
Discovery of stained soil, odors, USTs, buried drums or waste, landfill, or other signs of previously
unknown contamination: Within 48 hours ฀
Implementation of emergency actions (e.g. dewatering, flood, or soil erosion control
measures in area of contamination, venting of explosive environments):
Within 48 hours ฀
Installation of mitigation systems: Within 10 days ฀
Other notifications as required by local, state or federal agencies to implement
redevelopment activities: (as applicable): Within 30 days ฀

REDEVELOPMENT PLANS

1) Type of Redevelopment (check all that apply):
x Residential ฀ Recreational ฀ Institutional ฀ Commercial ฀ Office ฀Retail ฀ Industrial
฀ Other specify: Click here to enter text.

2) Summary of Redevelopment Plans (attach conceptual or detailed plans as available):
a) Do plans include demolition of structure(s)?: x Yes ฀ No ฀ Unknown
b) Do plans include removal of building foundation slab(s) or pavement:
x Yes ฀ No ฀ Unknown
c) Provide brief summary of redevelopment plans, including demolition, removal of building
slabs/pavement and other structures: The mill is being redeveloped under the Park Service’s
historic tax credit program and as such, some additions from 1960 are being removed leaving
the pre-1960’s mill for loft apartments. This includes the cooling tower and various small
bathroom additions. On the south-west corner of the property exists some freestanding walls
and slabs from warehouse buildings which no longer existing. These will be removed as part
of the redevelopment of the site.

3) Which category of risk-based screening level is used or is anticipated to be specified in the
Brownfields Agreement?
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EMP Form ver.1, October 23, 2014
x Residential ฀ Non-residential or Industrial/Commercial

Note: If children frequent the property, residential screening levels shall be cited in the Brownfields
Agreement for comparison purposes.

4) Schedule for Redevelopment (attach construction schedule):
a) Phase I start date and anticipated duration (specify activities during each phase):
12/1/2015
Construction will take place over the next 14 months with a majority of the constructions
complete in 2016.

b) If applicable, Phase 2 start date and anticipated duration (specify activities during each
phase): Click here to enter a date.
NA

c) Additional phases planned? If yes, specify activities if known:
฀ Yes x No ฀ Not in the foreseeable future ฀Decision pending
d) Provide the planned date of occupancy for new buildings: 1/1/2017

CONTAMINATED MEDIA
Contaminated Media (attach tabulated data summaries for each impacted media and figure(s) with
sample locations):
Part 1. Soil: x Yes ฀ No ฀ Suspected
Part 2. Groundwater: x Yes ฀ No ฀ Suspected
Part 3. Surface Water: ฀ Yes x No ฀ Suspected
Part 4. Sediment: ฀ Yes x No ฀ Suspected
Part 5. Soil Vapor: ฀ Yes x No ฀ Suspected
Part 6. Sub-Slab Soil Vapor: ฀ Yes x No ฀ Suspected
Part 7. Indoor Air: ฀ Yes x No ฀ Suspected

PART 1. SOIL – Please fill out the information below, using detailed site plans, if available, or estimate
using known areas of contaminated soil and a conceptual redevelopment plan. Provide a figure
overlaying new construction onto figure showing contaminated soil and groundwater locations.

1) Known or suspected contaminants in soil (list specific compounds): arsenic, PAH compound
2) Depth of known or suspected contaminants (feet): 0-3 feet
3) Area of soil disturbed by redevelopment (square feet): 500 square feet
4) Depths of soil to be excavated (feet): 4 feet
5) Estimated volume of soil (cubic yards) to be excavated (attach grading plan): 1,000 cubic yards
6) Estimated volume of excavated soil (cubic yards) anticipated to be impacted by contaminants:
500 yards
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EMP Form ver.1, October 23, 2014
7) Estimated volume of contaminated soil expected to be disposed of offsite, if applicable: 0
IMPORTED FILL SOIL

1) Will fill soil be imported to the site? ฀ Yes x No ฀ Unknown
2) If yes, what is the estimated volume of fill soil to be imported? Click here to enter text.
3) If yes, what is the depth of fill soil to be used at the property? Click here to enter text.
If a range of depths, please list the range.

4) PRIOR TO ITS PLACEMENT AT THE BROWNFIELDS PROPERTY, provide plan to analyze fill soil to
demonstrate that it meets acceptable standards and can be considered clean for use at the
Brownfields property (Check all that apply):
฀ Volatile organic compounds (VOCs) by EPA Method 8260
฀ Semi-volatile organic compounds (SVOCs) by EPA Method 8270
฀ Metals RCRA List (8) (arsenic, barium, cadmium, chromium (speciated), mercury, lead,
selenium and silver)
฀ Metals –Hazardous Substance List -14 (antimony, arsenic, beryllium, cadmium, chromium
(speciated according to IHSB protocol), copper, lead, manganese, mercury, nickel, selenium, silver,
thallium, and zinc)
฀ Metals – EPA Priority Pollutant List – 13 (arsenic, beryllium, cadmium, chromium (speciated
according to IHSB protocol), copper, mercury, nickel, lead, antimony, selenium, silver, thallium, and
zinc)
฀ Other Constituents & Analytical Method: Click here to enter text.
฀ Known borrow material (DESCRIBE SOURCE AND ATTACH SAMPLING PROFILE): Click here
to enter text.

MANAGING ONSITE SOIL

1) If soil in known or suspected areas of contamination is anticipated to be excavated from the
Brownfield Property, relocated on the Brownfields Property,or otherwise disturbed during site
grading or other redevelopment activities, please provide a grading plan that clearly illustrates
areas of cut and fill (approximate areas & volumes are acceptable, if only preliminary data
available).

2) HAZARDOUS WASTE DETERMINATION – Does the soil contain a LISTED WASTE as defined in the
North Carolina Hazardous Waste Section under 40 CFR Part 261.31-261.35? ฀ Yes x No

If yes, explain why below, including the level of knowledge regarding processes generating the
waste( include pertinent analytical results as needed). Click here to enter text.

If yes, do the soils exceed the “Contained-Out” levels in Attachment 1 of the North Carolina
Contained-In Policy? ฀ Yes ฀ No

NOTE: IF SOIL MEETS THE DEFINITION OF A LISTED HAZARDOUS WASTE AND EXCEEDS THE
CONTAINED-OUT LEVELS IN ATTACHMENT 1 TO THE NORTH CAROLINA CONTAINED-IN POLICY THE
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EMP Form ver.1, October 23, 2014
SOIL MAY NOT BE RE-USED ON SITE AND MUST BE DISPOSED OF IN ACCORDANCE WITH DENR
HAZARDOUS WASTE SECTION RULES AND REGULATIONS.

3) HAZARDOUS WASTE DETERMINATION – Does the soil contain a CHARACTERISTIC WASTE?:
฀ Yes x No
If yes, mark reason(s) why below (and include pertinent analytical results).

฀ Ignitability
฀ Corrosivity
฀ Reactivity
฀ Toxicity
฀ TCLP results
฀ Rule of 20 results (20 times total analytical results for an individual hazardous
constituent on TCLP list cannot, by test method, exceed regulatory TCLP standard)

If no, explain rationale: Click here to enter text.

NOTE: IF SOIL MEETS THE DEFINITION OF A CHARACTERISTIC HAZARDOUS WASTE, THE SOIL MAY NOT
BE RE-USED ON SITE AND MUST BE DISPOSED OF IN ACCORDANCE WITH DENR HAZARDOUS WASTE
SECTION RULES AND REGULATIONS.

4) Screening criteria by which soil disposition decisions will be made (e.g., left in place, capped in
place with low permeability barrier, removed to onsite location and capped, removed offsite):
฀ Preliminary Health-Based Residential SRGs Click here to enter a date.
฀ Preliminary Health-Based Industrial/Commercial SRGs Click here to enter a date.
฀ Site-specific risk-based cleanup level, or acceptable concentrations determined via
calculated cumulative risk. Enter details of methods used for determination/explanation:
N/a

5) Check the following action(s) to be taken during excavation and management of said soils:

฀ Manage fugitive dust from site:
฀ Yes x No
If yes, describe method; If no, explain rationale: Click here to enter text.

฀ Field Screening:
฀ Yes ฀ No
If yes, describe method; If no, explain rationale: Click here to enter text.

฀ Soil Sample Collection:
฀ Yes ฀ No
If yes, describe method (e.g., in-situ grab, composite, stockpile, etc.); If no, explain rationale:
Click here to enter text.
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EMP Form ver.1, October 23, 2014
฀ Stockpile impacted soil in accordance with NCDENR IHSB protocol in the current version of
the “Guidelines for Assessment and Cleanup”, and providing erosion control, prohibiting
contact between surface water/precipitation and contaminated soil, and preventing
contaminated runoff. Explain any variances:
Click here to enter text.
฀ Analyze potentially impacted soil for the following chemical analytes:
฀ Volatile organic compounds (VOCs) by EPA Method 8260
฀ Semi-volatile organic compounds (SVOCs) by EPA Method 8270
฀ Metals RCRA List (8) (arsenic, barium, cadmium, chromium (speciated), mercury,
lead, selenium and silver)
฀ Metals –Hazardous Substance List -14 (antimony, arsenic, beryllium, cadmium,
chromium (speciated according to IHSB protocol), copper, lead, manganese, mercury, nickel,
selenium, silver, thallium, and zinc)
฀ Metals – EPA Priority Pollutant List – 13 (arsenic, beryllium, cadmium, chromium
(speciated according to IHSB protocol), copper, mercury, nickel, lead, antimony, selenium, silver,
thallium, and zinc)
฀ Other Constituent(s) & Analytical Method(s): Click here to enter text.

฀ Proposed Measures to Obtain Pre-Approval for Reuse of Impacted Soil within the
Brownfields Property Boundary
฀ Provide documentation of analytical report(s) to Brownfields Project Manager
฀ Provide documentation of final location, thickness and depth of relocated soil on
site map to Brownfields Project Manager once known
฀ Use geotextile to mark depth of fill material (provide description of material)
฀ Manage soil under impervious cap ฀ or clean fill ฀
Describe cap or fill: Click here to enter text. (provide location diagram)
฀ Confer with NC BF Project Manager if Brownfield Plat must be revised (or re-
recorded if actions are Post-Recordation).
฀ Other: Click here to enter text.

฀ Final grade sampling of exposed soil (i.e., soil that will not be under buildings or permanent
hardscape): [if not checked provide rationale for not needing]
Provide diagram of soil sampling locations, number of samples, and denote Chemical
Analytical Program with check boxes below (Check all that apply):
฀ Volatile organic compounds (VOCs) by EPA Method 8260
฀ Semi-volatile organic compounds (SVOCs) by EPA Method 8270
฀ Metals RCRA List (8) (arsenic, barium, cadmium, chromium (speciated), mercury,
lead, selenium and silver)
฀ Metals –Hazardous Substance List -14 (antimony, arsenic, beryllium, cadmium,
chromium (speciated according to IHSB protocol), copper, lead, manganese, mercury, nickel,
selenium, silver, thallium, and zinc)
฀ Metals – EPA Priority Pollutant List – 13 (arsenic, beryllium, cadmium, chromium
(speciated according to IHSB protocol), copper, mercury, nickel, lead, antimony, selenium, silver,
thallium, and zinc)
฀ Pesticides
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EMP Form ver.1, October 23, 2014
฀ PCBs
฀ Other Constituents & Analytical Method: Click here to enter text.
OFFSITE TRANSPORT & DISPOSITION OF EXCAVATED SOIL
NOTE: Unless soil will be transported offsite for disposal in a permitted facility under applicable
regulations, no contaminated or potentially contaminated soil may leave the site without approval
from the brownfields program. Failure to obtain approval may violate a brownfields agreement,
endangering liability protections and making said action subject to enforcement. Justifications
provided below must be approved by the Program in writing prior to completing transport activities.
฀ Transport and dispose of impacted soil offsite (documentation of final disposition must be sent to
Brownfields Project Manager)
฀ Landfill – analytical program determined by landfill
฀ Landfarm or other treatment facility Click here to enter text.
฀ Use as Beneficial Fill Offsite – provide justification: Click here to enter text.
฀ Use as Beneficial Fill at another Suitable Brownfields Site – (Note: a determination that a
site is a “Suitable Brownfields” site will require, at a minimum, that similar concentrations of the same
or similar contaminants already exist at both sites, use of impacted soil as beneficial soil will not
increase the potential for risk to human health and the environment at that site, and that notarized
documentation of the acceptance of such soil from the property owner of the receiving site is
provided to Brownfields. Provide justification: Click here to enter text.

MANAGEMENT OF UTILITY TRENCHES
฀ Install liner between native impacted soils and base of utility trench before filling with clean fill
(Preferred)

฀ Last out, first in principle for impacted soils (if soil can safely be reused onsite and is not a
hazardous waste), i.e., impacted soils are placed back at approximately the depths they were
removed from such that impacted soil is not placed at a greater depth than the original depth from
which it was excavated.

฀ Evaluate whether necessary to install barriers in conduits to prevent soil vapor transport, and/or
degradation of conduit materials due to direct impact with contaminants? Result: Yes □ No □
If no, include rationale here. Click here to enter text.
If yes, provide specifications on barrier materials

Other comments regarding managing impacted soil in utility trenches: Click here to enter text.

PART 2. GROUNDWATER – Please fill out the information below and attach figure showing
distribution of groundwater contaminants at site

What is the depth to groundwater at the Brownfields Property? 20 feet

Is groundwater known to be contaminated by ฀onsite x offsite ฀ both ฀ or unknown sources?
Describe source(s): Dry cleaner

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EMP Form ver.1, October 23, 2014
What is the direction of groundwater flow at the Brownfields Property? To the west

Will groundwater likely be encountered during planned redevelopment activities? ฀ Yes x No
If yes, describe these activities: Click here to enter text.

In the event that contaminated groundwater is encountered during redevelopment activities (even if
no is checked above), list activities for contingent management of groundwater (e.g., dewatering of
groundwater from excavations or foundations, containerizing, offsite disposal, discharge to sanitary
sewer, or sampling procedures): Groundwater way too deep to encounter during construction which
is contained within the existing buildings

PART 3. SURFACE WATER – Please fill out the information below.
Attach a map showing the location of surface water at the Brownfields Property.

Is surface water at the property known to be contaminated: ฀ Yes x No

Will workers or the public be in contact with surface water during planned redevelopment activities?
฀ Yes x No

In the event that contaminated surface water is encountered during redevelopment activities, or
clean surface water enters open excavations, list activities for management of such events (e.g.
flooding, contaminated surface water run-off, stormwater impacts): Click here to enter text.

PART 4. SEDIMENT – Please fill out the information below.
Is sediment at the property known to be contaminated: ฀ Yes x No

Will workers or the public be in contact with sediment during planned redevelopment activities?
฀ Yes ฀ No

If yes, attach a map showing location of known contaminated sediment at the property.

In the event that contaminated sediment is encountered during redevelopment activities, list
activities for management of such events (stream bed disturbance): Click here to enter text.

PART 5. SOIL VAPOR – Please fill out the information below.
Do concentrations of volatile organic compounds at the Brownfields property exceed the following
vapor intrusion screening levels in the following media:

IHSB Residential Screening Levels:
Soil Vapor: ฀ Yes x No ฀ Unknown
Groundwater: x Yes ฀ No ฀ Unknown

IHSB Industrial/Commercial Screening Levels:
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EMP Form ver.1, October 23, 2014
Soil Vapor: ฀ Yes ฀ No ฀ Unknown
Groundwater: ฀ Yes ฀ No ฀ Unknown

Attach a map showing the location of soil vapor contaminants that exceed site screening levels.

If applicable, at what depth(s) is soil vapor known to be contaminated? Click here to enter text.

Will workers encounter contaminated soil vapor during planned redevelopment activities?
฀ Yes x No ฀ Unknown

In the event that contaminated soil vapor is encountered during redevelopment activities (trenches,
manways, basements or other subsurface work, list activities for management of such contact: Click
here to enter text.

PART 6. SUB-SLAB SOIL VAPOR -please fill out the information below if existing buildings or
foundations will be retained in the redevelopment.

Are sub-slab soil vapor data available for the Brownfields Property? x Yes ฀ No ฀ Unknown

If data indicate that sub-slab soil vapor concentrations exceed screening levels, attach a map showing
the location of these exceedances.

At what depth(s) is sub-slab soil vapor known to be contaminated? ฀ 0-6 inches ฀ Other, If other
describe: not present

Will workers encounter contaminated sub-slab soil vapor during planned redevelopment activities?
฀ Yes x No ฀ Unknown

In the event that contaminated soil vapor is encountered during redevelopment activities, list
activities for management of such contact: Click here to enter text.

PART 7. INDOOR AIR – Please fill out the information below .

Are indoor air data available for the Brownfields Property? X Yes ฀ No ฀ Unknown

If yes, attach a map showing the location where indoor air contaminants exceed site screening levels.

If the structures where indoor air has been documented to exceed risk-based screening levels will not
be demolished as part of redevelopment activities, will workers encounter contaminated indoor air
during planned redevelopment activities?
฀ Yes x No ฀ Unknown

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EMP Form ver.1, October 23, 2014
In the event that contaminated indoor air is encountered during redevelopment activities, list
activities for management of such contact: please see phase II which was included in the Brownfields
application

PART 8 – Vapor Mitigation System – Please fill out the information below .

Is a vapor intrusion mitigation system proposed for this Brownfields Property?
x Yes ฀ No ฀ Unknown

If yes, provide the date the plan was submitted to the Brownfields Program.
12/2/2015
Attach the plan.

Has the vapor mitigation plan been approved by the NC Brownfields Program?
฀ Yes x No ฀ Unknown
Has the vapor mitigation plan been signed and sealed by a North Carolina professional engineer? x
Yes ฀ No

What are the components of the vapor intrusion mitigation system?
฀ Sub-slab depressurization system
฀ Sub-membrane depressurization system
฀ Block-wall depressurization system
฀ Drain tile depressurization system
฀ Passive mitigation methods
฀ Vapor barriers
฀ Perforated piping vented to exterior
x Other method: Craw Spaces in buildings 2 and 4 – pvc pipe system to be placed horizontally on the
ground within the craw space and covered with vapor barrier. This system will be vented to the roof.
Slab spaces in buildings 2 and 3 – existing slab will be cut and open pipe will be installed and then
sealed under the slab. These pipes will then be actively vented to the roof.

PART 9. CONTINGENCY FOR ENCOUNTERING UNKNOWN TANKS, DRUMS, OR OTHER WASTE
MATERIALS

Please provide a contingency plan in the event unknown tanks, drums, fuel lines, landfills, or other
waste materials are encountered during site activities.

Check the following activities that will be conducted prior to commencing earth-moving activities at
the site:
฀ Review of historic maps (Sanborn Maps, facility maps)
฀ Conducting geophysical surveys to evaluate the location of suspect UST, fuel lines, utility lines, etc.
฀ Interviews with employees/former employees/facility managers/neighbors

I
I
discovered. See Notification Section on Page 1 for notification requirements.
POST-REDEVELOPMENT REPORTING
In accordance with the site's Brownfield Agreement, provide a report within the designated schedule
to the State Brownfields Project Manager.
D Check box to acknowledge consent to provide a redevelopment summary report In compliance
with the site's Brownfields Agreement.
APPROVAL SIGNATURES
I -II --lO I (7
I
I
Prospective Devel er
Printed Name/ntie/Company
Date 'f<.o~c~.JJ C. f:M?i.,o/mM"'-stw/Pv.,..,k,.,#.vM,JI LLC
Brownfields Project Manager Date
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EMP Form ver.l, October 23, 2014
INERAL
PRINGS
environmental, p.c.
4600 Mineral Springs Lana
Raleigh, NC 27616
January 141 2016
Mr. Lebeed Kady
North Carolina Brownfields Program
1646 Mail Service Center
Raleigh/ North Carolina 27699-1646
Subject: Contingency Plan for Encountering Unknown Tanks,
Drums and Other Waste Materials
Oneida Mills/Former Kayser Roth Facility
219 Hardin Street
Graham, North Carolina
MSElob838
Dear Mr. Kady:
Mineral Springs Environmental (MSE) has prepared the following Contingency Plan Encountering
Unknown Tanks1 Drums and Other Waste Materials for your review. The plan details the methods
to be used in the event any of the above are encountered during construction activities associated
with the above mentioned property.
If you have any questions/ please contact me at [phone].
CONTINGENCY PLAN FOR UNKNOWN TANKS,
DRUMS AND OTHER WASTE MATERIALS
ONEIDA MILLS/FORMER KAYSER ROTH FACILITY
BROWN FIELDS PROJECT#: 19039-15-060
219 Harden Street
Graham, Alamance County, North Carolina
January 14, 2016
1 INTRODUCTION
1.1 Site Information
The subject site is located at 219 Harden Street in Graham, North Carolina (see Drawing 1).
Pumpkin Hill Mill, LLC (Pumpkin Hill) intends to redevelop the property for affordable housing
use. The development will include retrofitting for building with condominium units. The
redevelopment is being conducted under the oversight of the North Carolina Brownfields
Program (NCBP) as NCBP Project# 19039-15-060. The property is approximately 7 acres in size
and occupied with several structures. During construction some demolition activities will occur.
Limited earth work is anticipated and no off site disposal of materials will occur. Large portions
of the property not occupied with buildings will consisted of paved parking.
The site currently has two (2) closed environmental incidents according to North Carolina
Department of Environment and Natural Resources, Division of Waste Management files.
An 11,000 gallon gasoline UST was removed from the site in 1989. A review of the
NCDENR-DWM file (WS-1228) indicates that this was a "clean closure".
A 12,000 gallon fuel oil AST and a 7,500 gallon fuel oil AST were removed from the site
in 1993. Petroleum impacted soil was excavated and removed from the site for
disposal. According to reports prepared for Kayser-Roth, this incident received a closure
letter from NCDENR dated July 25, 1994.
The site currently has one (1) open environmental incident according to North Carolina
Department of Environment and Natural Resources, Division of Waste Management files.
Incident #21742 has been assigned by the Inactive Hazardous Waste Branch (IHSB)
due to the presence of chlorinated compounds in the soil and groundwater at the site.
It should be noted that similar compounds have been identified at a former dry cleaners
across Harden Street and could be the cause of the impact. The presence of chlorinated
solvents is most-likely the result of operations conducted at the dry cleaners across
Harden Street and to the south.
1.2 Purpose
It should be noted that the NCBP is requiring that a Contingency Plan (CP) be prepared and
implemented during all construction phases of this project. The purpose of the CP is to provide
methods and procedures to be used to manage should unknown tanks, drums or other waste
materials be encountered during development activities.
2.0 Contingency Plan Activities
This contingency plan is designed to establish protocols to be implemented should tanks, drums
and other materials be identified during construction activities. The plan will involve a host of
regulatory and private entities and must be followed to avoid unwarranted issues and costly
delays.
Initial Steps to Manage Impacted Soil
Prior to beginning construction work at the site a meeting should be arrange to review the CP
and its implementation. A list of project-related environmental professionals should be
generated and available for all contractors involved in construction. The list should include the
contact person(s) and contact information for Pumpkin Hill, the NCBP, the environmental
consultant and site contractors.
Identification of Tanks. Drums and Other Materials
Should the contractor encounter a potential tank, buried drums, buried trash and debris, or
noxious chemical or petroleum odors all work in that area will stop. The contractor will notify
the environmental consultant. At that point the consultant will notify the NCBP contact and the
appropriate regulatory agency. A course of action will then be established to manage the
identified regulatory issue.
Identified tanks will be removed or closed in-place under the jurisdiction of the North Carolina
Underground Storage Tank Section. Soil samples will be obtained to document the soil quality
adjacent to the tank. Steps will then be discussed with the NCBP regarding the need for further
soil remediation based on construction needs.
Encountered buried drums will be managed under the jurisdiction of the North Carolina
Hazardous Waste Section. An assessment will be performed to determine the chemical nature
of drum contents if present. The drums will then be excavated, staged and segregated based
on content. The drums will be segregated into roll-off containers awaiting profiling and disposal
acceptance. The soils in the area of the drums will then be sampled to determine the chemical
quality. The results will be supplied to the NCBP and a determination will be made as to the
need for further assessment or remediation.
Should solid waste and/or debris be encountered, steps will be taken to remove the area of
solid waste materials. The material will be managed under the jurisdiction of the North Carolina
Solid Waste Section. Prior to any work activities a thorough assessment of the trash will be
conducted. The waste will then be profiled and accepted into a landfill. If warranted, steps will
then be taken to excavate and properly dispose of the trash. Steps will then be taken to sample
the adjacent soils for chemical quality. The analytical data will then be submitted to the NCBP
for review in order to determine the next course of action.
Contingency Plan
Oneida Mills Site
MINERAL SPRINGS ENVIRONMENTAL PC
January 14, 2016
Page2
If during construction noxious odors are encountered, steps will be taken to collect soil samples
to determine the chemical quality. The analytical data will then be submitted to the NCBP for
review in order to determine the next course of action.
Reporting
At the conclusion of the construction activities for the building, a report will be submitted to the
NCBP documenting the areas of the site requiring additional assessment and/or remediation.
3.0 Imoacted Groundwater
As indicated above, the groundwater beneath the site has been impacted with chlorinated
solvents. As such, if during construction it is determined that groundwater must be removed
from the subsurface steps must be taken to properly containerize and properly dispose of the
liquid. Any such containerized groundwater shall be sampled and analyzed for the purpose of
evaluating disposal options, with approval from the local publicly owned treatment works
(POTW), the groundwater may be discharged to the POTW. In the alternative and based on the
analytical results, the containerized groundwater may be placed in tanker trucks and
transported to a facility licensed to accept wastewater for disposal. The soil disposal report
referenced above shall include a section on the disposal of impacted groundwater, if any.
Contingency Plan
Oneida Mills Site
MINERAL SPRINGS ENVIRONMENTAL PC
January 14, 2016
Page3
DRAWINGS
DRAWING NO. 1

TOPOGRAPHIC SITE MAP
ONEIDA MILLS SITE
GRAHAM, NORTH CAROLINA
Date: September 2015
Job No.: MSE 838
File: 838/Drawing 1
By: KP
SITE