21020_Maxton Feed_EMP_20170413

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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: 4/13/2017

Brownfields Assigned Project Name: Maxton Feed Mill

Brownfields Project Number: BF #

Brownfields Property Address: Airport Road, Scotland County; 214 West Rockingham Road, Maxton,
Robeson County, NC

Brownfields Property Area (acres): 351.36

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

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

COMMUNICATIONS

Prospective Developer (PD): Mountaire Farms Inc.
Phone Numbers: Office: [phone]…..Mobile: Click here to enter text.
Email: Click here to enter text.
Primary PD Contact: John Wren
Phone Numbers: Office: [phone] Mobile: [phone]
Email:
Environmental Consultant: Josh Hanks (Duncklee & Dunham)
Phone Numbers: Office: [phone]…..Mobile: [phone]
Email: [e-mail]
Brownfields Program Project Manager:
Office: Raleigh, NC
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EMP Form ver.1, October 23, 2014
Email: @ncdenr.gov; Phone Number: Office:

Other DENR Program Contacts (if applicable, i.e., UST Section, Inactive Hazardous Site Branch,
Hazardous Waste, Solid Waste): None

NOTIFICATIONS TO THE BROWNFIELDS PROGRAM

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

REDEVELOPMENT PLANS

1) Type of Redevelopment (check all that apply):
☐ Residential ☐ Recreational ☐ Institutional ☐ Commercial ☒ Office ☐Retail ☒ Industrial
☐ Other specify: 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)?: ☐ Yes ☒ No ☐ Unknown
b) Do plans include removal of building foundation slab(s) or pavement:
☐ Yes ☒ No ☐ Unknown
c) Provide brief summary of redevelopment plans, including demolition, removal of building
slabs/pavement and other structures: The property does not currently have any structures to
remove. Redevelopment will include the construction of approximately 109,140 square feet of
structures including a new concrete feed mill, feed-mill silo, ancillary building, and a scale house.
Construction of a rail unloading system with associated feed processing and feed delivery
vehicles are also included in the redevelopment plan.

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

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): TBD
The property does not currently have any structures to remove. Redevelopment will include the
construction of approximately 109,140 square feet of structures including a new concrete feed mill,
feed-mill silo, ancillary building, and a scale house. Construction of a rail unloading system with
associated feed processing and feed delivery vehicles are also included in the redevelopment plan.

b) If applicable, Phase 2 start date and anticipated duration (specify activities during each
phase): TBD

c) Additional phases planned? If yes, specify activities if known:
☐ Yes ☐ No ☒ Not in the foreseeable future ☐ Decision pending
d) Provide the planned date of occupancy for new buildings: TBD

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

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): 1) The presence of
unexploded ordnance was suspected on the airport-owned parcel that once was used as a bazooka
range for the Laurinburg-Maxton Army Air Base. Zapata Engineering conducted two
reconnasissance surveys with geophysical methods and did not identify UXO, but potential UXO may
remain at the site. The base also maintained an ammunition magazine and practice grenade court.
2) Sludge was excavated from the base of a process-water pond formerly used by an adjacent
industrial faciltiy, and confirmation samples collected after excavation exhibited oil and grease at
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EMP Form ver.1, October 23, 2014
concentrations up to 32 mg/kg, which did not exceed the cleanup level of 1,650 mg/kg. 3) Soil
samples collected as part of a field investigation at an unpermitted landfill exhibited chromium at
concentrations that exceeded the Industrial Preliminary Soil Remediation Goal (PSRG) for hexavalent
chromium, and exhibited lead at concentrations that did not exceed the Industrial PSRG. Soil sample
locations are shown in Appendix A; tabulated laboratory test results are provided in Appendix A.
2) Depth of known or suspected contaminants (feet): 0-7’
3) Area of soil disturbed by redevelopment (square feet): TBD
4) Depths of soil to be excavated (feet): TBD
5) Estimated volume of soil (cubic yards) to be excavated (attach grading plan): TBD, preliminary
grading plan is provided in Appendix B
6) Estimated volume of excavated soil (cubic yards) anticipated to be impacted by contaminants:
TBD
7) Estimated volume of contaminated soil expected to be disposed of offsite, if applicable: TBD
IMPORTED FILL SOIL

1) Will fill soil be imported to the site? ☐ Yes ☐ No ☒ Unknown
2) If yes, what is the estimated volume of fill soil to be imported? TBD, will be provided when
available.
3) If yes, what is the depth of fill soil to be used at the property? TBD, will be provided when
available.
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): See
Appendix B for information regarding valuation of soil from off-site sources.

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
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EMP Form ver.1, October 23, 2014
areas of cut and fill (approximate areas & volumes are acceptable, if only preliminary data
available).

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

If yes, explain why below, including the level of knowledge regarding processes generating the
waste( include pertinent analytical results as needed). 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
SOIL MAY NOT BE RE-USED ON SITE AND MUST BE DISPOSED OF IN ACCORDANCE WITH DENR
HAZARDOUS WASTE SECTION RULES AND REGULATIONS.

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

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

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

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EMP Form ver.1, October 23, 2014
5) Check the following action(s) to be taken during excavation and management of said soils:

☒ Manage fugitive dust from site:
☒ Yes ☐ No
If yes, describe method; If no, explain rationale: Minimize the number of times the
contaminated or stockpiled soil is handled; all material handling will be conducted in the controlled
exclusion zone outside the excavation area. Fugitive dust emissions will be controlled as needed to
include water sprinkling, using water obtained from clean sources. If fugitive dust becomes a problem
for the workers or looks like it may leave the site, contractors will use a water truck to spray the
excavation areas as needed to keep the dust under control without making it muddy and inaccessible.

☐ Field Screening:
☐ Yes ☒ No
If yes, describe method; If no, explain rationale: No known areas of petroleum or chlorinated
solvent soil contamination. No field screening of soil will be required unless a newly discovered
contaminant source is identified during redevelopment. Refer to Appendix C, “Contingency Plan to
Address Newy Discovered contaminant Sources” for additional details. Personnel performing earth-
moving activities in areas where unexploded ordnance (UXO) were suspected will need to refer to
Appendix D, “Contingency Plan to Address Unexploded Ordnance”.

☒ Soil Sample Collection:
☒ Yes ☐ No
If yes, describe method (e.g., in-situ grab, composite, stockpile, etc.); If no, explain rationale:
Refer to Appendix E, “Evaluation of Soil from Off-site Sources” and Appendix C, “Contingency Plan to
Address newly Discovered Contaminant Sources”.
☒ 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:
If impacted soil is required to be removed from the site the landfill may accept the waste
determination based on in situ data so that direct loading of trucks can be used. If not,
stockpiled areas will be in accordance with the IHSB protocal.
☒ 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.
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EMP Form ver.1, October 23, 2014

☒ 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: We will provide documentation as to where this material is placed at the
site and understand that this may require revision to the BF plat map once the movement of soil has
been completed.

☐ 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
☐ PCBs
☐ Other Constituents & Analytical Method: If this soil is not managed under an
impervious cap or clean fill, we will conduct final grade sampling where this material presents a shallow
soil exposure risk.
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.
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EMP Form ver.1, October 23, 2014
☐ 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? Depth to groundwater ranges from
approximately 7 to 10 feet below land surface

Is groundwater known to be contaminated by ☒onsite ☐ offsite ☐ both ☒ or unknown
sources? Describe source(s): Ten groundwater samples were collected onsite. Four samples were
collected from previously-constructed permanent monitoring wells around an unpermitted landfill, five
samples were collected from temporary monitoring wells (TMWs), and one sample was collected from
groundwater that accumulated in the pit after excavation of the landfill debris. The laboratory tested all
ten groundwater samples for VOCs and SVOCs and tested for Priority Pollutant Metals from samples
collected from the four permanent wells around the landfill and two temporary wells near the former
location of the process-water pond. The sample from TMW-1 exhibited selenium and the sample from
ONL-3 exhibited chromium at concentrations that exceed the 2L standards. The samples from ONL-4
and TMW-5 exhibited benzene at concentrations that exceed the 2L standard. The groundwater that
entered the pit exhibited benzene, toluene, and phenol at concentrations that exceed the respective 2L
standards. Monitoring well locations are shown in Appendix F; tabulated laboratory test results are
provided in Appendix F.

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EMP Form ver.1, October 23, 2014
What is the direction of groundwater flow at the Brownfields Property? Based on a review of the
topographic map, we expect groundwater in the surficial aquifer beneath the site flows towards the
south.

Will groundwater likely be encountered during planned redevelopment activities? ☒ Yes ☐ No
If yes, describe these activities: Groundwater may be encountered when the foundation of the
feed mill and silos are installed.

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): If groundwater is encountered during construction in the vicinity of
the former process water pond or landfill, it will be containerized, tested for VOCs/SVOCs/PP Metals,
and disposed of either to the Laurinburg-Maxton Airport Commission’s (LMAC’s) POTW in accordance
with a permit, or other permitted treatment facility.

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

Is surface water at the property known to be contaminated: ☐ Yes ☒ No

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

In the event that contaminated surface water is encountered during redevelopment activities, or
clean surface water enters open excavations, list activities for management of such events (e.g.
flooding, contaminated surface water run-off, stormwater impacts): Two large ponds are located at
the southern side of the site. Several drainage ditches and depressions, some filled with water, were
observed across the site. Potential excavations in known contaminated areas will not be left open
during significant rain events, or will be bermed to prevent surface water run-off from entering. If
required, water from the pit may be containerized, tested for VOCs, and disposed of either to LMAC’s
POTW in accordance with a permit, or as groundwater investigation-derived waste.

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

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

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

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

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EMP Form ver.1, October 23, 2014
PART 5. SOIL VAPOR – Please fill out the information below.
Do concentrations of volatile organic compounds at the Brownfields property exceed the following
vapor intrusion screening levels in the following media:

IHSB Residential Screening Levels:
Soil Vapor: ☐ Yes ☐ No ☒ Unknown
Groundwater: ☒ Yes ☐ No ☐ Unknown

IHSB Industrial/Commercial Screening Levels:
Soil Vapor: ☐ Yes ☐ No ☒ Unknown
Groundwater: ☒ Yes ☐ No ☐ Unknown

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

If applicable, at what depth(s) is soil vapor known to be contaminated?

Will workers encounter contaminated soil vapor during planned redevelopment activities?
☐ Yes ☐ No ☒ Unknown

In the event that contaminated soil vapor is encountered during redevelopment activities (trenches,
manways, basements or other subsurface work, list activities for management of such contact: TBD;
IHSB Groundwater Screening exceedances were detected from samples collected from the pit water and
TMW-5 located near the landfill. The proposed feed mill and silos are located approximately 900 feet
from the landfill and do not anticipate soil vapor to be encountered during redevelopment. Proposed
feed mill and silo locations are shown on figures in Appendix B and F. Location of the landfill and
groundwater samples are shown on figures in Appendix F.

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? ☐ Yes ☒ No ☐ Unknown

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

At what depth(s) is sub-slab soil vapor known to be contaminated? ☐ 0-6 inches ☐ Other, If other
describe:

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

In the event that contaminated soil vapor is encountered during redevelopment activities, list
activities for management of such contact: TBD

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

Are indoor air data available for the Brownfields Property? ☐ Yes ☒ No ☐ Unknown

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

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

In the event that contaminated indoor air is encountered during redevelopment activities, list
activities for management of such contact: TBD

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

Is a vapor intrusion mitigation system proposed for this Brownfields Property?
☐ Yes ☒ No ☐ Unknown

If yes, provide the date the plan was submitted to the Brownfields Program.
Click here to enter a date.
Attach the plan.

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

What are the components of the vapor intrusion mitigation system?
☐ Sub-slab depressurization system
☐ Sub-membrane depressurization system
☐ Block-wall depressurization system
☐ Drain tile depressurization system
☐ Passive mitigation methods
☐ Vapor barriers
☐ Perforated piping vented to exterior
☐ Other method: Click here to enter text.

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

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

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

Notification to State Brownfields Project Manager, UST Section, Fire Department, and/or other
officials, as necessary and appropriate, is required when new potential source(s) of contamination are
discovered. See Notification Section on Page 1 for notification requirements.

POST-REDEVELOPMENT REPORTING
In accordance with the site’s Brownfield Agreement, provide a report within the designated schedule
to the State Brownfields Project Manager.

☒ Check box to acknowledge consent to provide a redevelopment summary report in compliance
with the site’s Brownfields Agreement.

APPROVAL SIGNATURES

Prospective Developer Date
Printed Name/Title/Company

Consultant Date
Printed Name/Title/Company

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Brownfields Project Manager Date

Appendix A

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Appendix C
Appendix D
Environmental Management Plan
Contingency Plan to Address Newly Discovered Contaminant Sources
Mountaire Scotland County Feed Mill
Scotland County, North Carolina

During site-development activities, previously undiscovered contaminant sources may be encountered. If
the general contractor (GC) encounters a contaminant source, the prospective developer (PD) or the
environmental consultant (EC) will notify the applicable agencies of the North Carolina Department of
Environmental Quality (DEQ) within 48 hours of discovery, verbally or by email. These sources may
include, but are not necessarily limited to: underground storage tanks (USTs) and fuel lines, buried drums
or containers of unknown materials, and areas of buried waste materials/landfills.

If the GC encounters previously undiscovered contaminant sources during construction, the GC will
temporarily suspend activities in the area. The GC will immediately notify the EC and the PD. The EC
will investigate the area, evaluate the waste materials and/or contaminated media in the area, and
determine the proper means to manage these materials. The EC will contact the NCBP and provide
documentation of the finding and subsequent actions taken to manage these materials. Depending upon
site conditions, confirmatory samples may be collected by the EC from the newly-discovered contaminant
source area(s) for laboratory analysis. All samples will be submitted to a DEQ‐certified analytical
laboratory for analysis. Analytical methods to be employed for these samples may include one or more of
the following:

• VOCs by Method 8260;
• SVOCs by Method 8270; PAHs by Method 8270 SIM
• RCRA Metals by Methods 6010/7471;
• Total Petroleum Hydrocarbons (TPH) Gasoline Range Organics (GRO) and Diesel Range
Organics (DRO) by Method 8015;
• Volatile Petroleum Hydrocarbons (VPH) by the MADEP Method;
• Extractable Petroleum Hydrocarbons (EPH) by the MADEP Method;
• Pesticides by Method 8081;
• Herbicides by Method 8151;
• Polychlorinated biphenyls (PCBs) by Method 8082;
• Corrosivity by Method 1110A;
• Reactivity by Method 9012; and/or
• Flashpoint by Method 1010.

1.0 USTs

There are no known USTs at the site. If fuel lines or USTs are encountered during excavation, the PD
will manage the tank(s) or piping as required under the guidelines of the UST Section of DEQ. Although
the costs for assessment and remediation of contamination from USTs discovered during remedial
activities will not be eligible for reimbursement under the UST Trust Fund, the PD will address historical
UST issues by following the guidelines of the UST Section. The EC will notify the Laurinburg Fire
Department to ascertain the necessary permits to remove the UST(s). The PD or the EC will notify the
NCBP of a UST discovery within 48 hours, verbally or by email.

Appendix D to Environmental Management Plan
Contingency Plan to Address Newly Discovered Contaminant Sources
Mountaire Scotland County Feed Mill; Scotland County, North Carolina
Page 2 of 2

Residual petroleum‐contaminated media (i.e., soil and/or groundwater) on the Brownfields Property can
be handled under the NCBP’s land-use restrictions rather than the UST Section’s Notice of Residual
Petroleum. The PD will submit copies of all reports and correspondence relating to such closure to the
NCBP.

2.0 Buried Drums

If the GC discovers buried drums of unknown materials at the Property, the PD or the EC will notify
DEQ within 48 hours of discovery, verbally or by email. The EC will evaluate the drums for contents and
obvious integrity issues, labeling, etc. Once the EC determines the condition of the drums, they will be
either removed immediately for proper off-site disposal or removed from the area and temporarily
relocated to a staging area in a designated location of the Property with proper secondary containment for
sampling, and proper disposal.

The EC will evaluate the soil that surrounds these features for stains, odor, or other evidence of
contamination. Based on field observations, the EC may elect to collect post‐excavation confirmation
samples from areas where contaminated soil was excavated for laboratory analysis by the analytical
parameters presented above. The EC will provide the PD, its contractor, and the NCBP copies of field-
monitoring and analytical data, with recommendations to address contaminated soil.

3.0 Buried Waste Materials

If buried waste materials are discovered at the Property, the PD or the EC will notify DEQ within 48
hours of discovery, verbally or by email. The EC will evaluate the material to characterize the nature of
the waste material. If buried wastes are encountered, the EC will evaluate the soil that surrounds these
features for stains, odor, or other evidence of contamination. Based on field observations, the EC may
elect to collect post‐excavation confirmation samples from areas where contaminated soil was excavated
for laboratory analysis by the analytical parameters presented above. The EC will provide the PD, its
contractor, and the NCBP copies of field-monitoring and analytical data, with recommendations to
address contaminated soil as applicable.

Appendix D

Appendix E
Environmental Management Plan
Contingency Plan to Address Unexploded Ordnance
Mountaire Scotland County Feed Mill
Scotland County, North Carolina

The Laurinburg-Maxton Airport was originally constructed as the Laurinburg-Maxton Army Air Base,
and portions of the site were used as the base’s bazooka practice range, a dynamite magazine, and a
practice grenade court. Two reconnaissance surveys with geophysical methods were conducted on the
property and did not identify unexploded ordnance (UXO), but the potential remains that UXO may
remain at the site.

All personnel working in areas suspected to have UXO present are to undergo Construction UXO Safety
Training. The attached figure from the Construction UXO Safety Guide will aid in the identification of
suspected UXO items.

If the GC encounters suspected UXO items during construction, the GC will follow the Recognize,
Retreat, and Report steps detailed in the Construction UXO Safety Guide:

1) Recognize
• Remember that munitions come in many shapes and sizes, look old or new, and are found alone
or in clusters
• Should be considered extremely dangerous regardless of size or age
• Can be found on the surface or buried several feet below ground level

2) Retreat
• Immediately stop all construction activities in the area, and warn others of potential danger
• Do not approach the munition or a suspect munition (some fuses are sensitive to changes in
temperature, movement or pressure)
• Move away from the area and keep others away from it

3) Report
• Report any munitions or suspected munitions encountered to your foreman or site supervisor
• Report the size, shape, and location of the munition

The GC will immediately notify the EC, PD, and Maxton Police Department if any suspected UXO are
encountered. All personnel should be kept away from the area until the appropriate authorities assess and
dispose of the any suspected UXO. If UXO is identified on the property, additional reconnaissance
surveys will be required to assess the potential of remaining munitions.

Appendix E

Appendix B

Addendum to Environmental Management Plan
Evaluation of Soil from Off‐site Sources
Mountaire Scotland County Feed Mill
Scotland County, North Carolina

The North Carolina Brownfields Program (NCBP) requires analysis of fill soil to demonstrate that it
meets acceptable standards and can be considered clean for use at the Brownfields property. Although
the NCBP is considered to be a redevelopment program, testing backfill material is not required in the
Department of Environmental Quality (DEQ) regulatory programs other than to state that clean backfill
should be utilized. We understand the desire of the NCBP to place uncontaminated soil from an off-site
source onto a brownfields property. The two scenarios outlined below will be implemented to ensure the
backfill material meets the intent of the NCBP requirement.

Fill Material from Borrow Pit – Backfill material obtained from a commercial borrow pit using virgin
material will not be tested. Borrow pits of this nature are used daily for residential and commercial
projects and are acceptable sources of clean fill.

Fill Material from Construction/Grading Sites – Backfill material that is obtained from off-site
construction or grading sites or sources other than a barrow pit will be tested.

The soil samples selected for laboratory analysis will be submitted to a DEQ‐certified analytical
laboratory for analysis for semivolatile organic compounds (SVOCs) according to SW-846 Method
8270D, volatile organic compounds (VOCs) according to Method 5035B (prep) with Method 8260B
(testing), and Priority Pollutant (PP) metals.

When possible and depending on the construction/grading site, the environmental consultant (EC) will
first estimate stockpile volumes of approximately 1,000 cubic yards in size and mark them off with pin
flags and string. The attached figure from the UST Section’s Guidelines for Sampling (December 2013)
will aid in the EC’s volumetric estimation. The EC will first collect two grab samples for VOC testing
from two of six sample locations where they will collect aliquots that are approximately equal in size.
The EC will collect the samples for VOC testing prior to homogenizing the aliquots into a composite
sample to be tested for SVOCs and PP metals.

The locations of the aliquots will be randomly selected, and the soil samples will be collected with a hand
auger from different depths and locations in the stockpile area being tested. Aliquots used for VOC grab
sampling will be taken at least 12 inches below the stockpile surface. After the VOC samples are
collected, the EC will create a composite sample by homogenizing aliquots in a pre-cleaned Pyrex dish
with a stainless-steel spoon. The composite sample will be transferred to the appropriate containers
supplied by the laboratory. All samples will be placed immediately on ice and submitted to the laboratory
under chain-of-custody. The hand auger and homogenization equipment will be decontaminated between
stockpile samples. The EC will provide documentation to the NCBP, including all analytical data, when
soil from construction/grading sources are utilized at the site.

GUIDELINES FOR SAMPLING

UST Section
North Carolina
Department of Environment and Natural Resources
Division of Waste Management

July 15, 2008 Version

Change 3, Effective December 1, 2013

14
Figure 2 (copy) Volumes of Stockpiles
Note: These equations have been simplified for ease of calculation.
H = Height
L = LengthW = WidthConical Stockpiles:
Volume = (H x L x W)/3
Rectangular Stockpiles - pointed crest:Volume = (H x L x W)/2
Rectangular Stockpiles - flat topped:
Volume = H x [(L x W) - (2 x H x W)]
H = Height
L = LengthW = Width
H = Height
L = LengthW = Width
L > W > H

Appendix F
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Scale:
1" = 800'
Date:Project Number:
Proposed Mountaire Site
Scotland County and Robeson County, North Carolina
Drawn By:
mrw/rnl
Checked By:References:
Filename:Layers:Size:
NC OneMap Scotland County-2016, MapCard Aerial-2015,
The Rail Road Associates Corporation, Field Notes
F
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0800'1600'
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