23035 Theron Soil Export Reeves Approval 2020.10.29

October 29, 2020
Sent Via E-mail Will Smith CUSA NC Holdings, LP c/o Camden
1420 Spring Hill Road, Suite 200 McLean, VA 22102 [e-mail]
Subject: Brownfields Soil Management Chadbourn Mills and Theron 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 a request to export 3,000 cubic yards of soil from the above referenced brownfields properties owned by CUSA NC Holdings, LP to Reeve’s Land Clearing and Inert Debris Landfill (LCID)
(Permit No. 60-S-LCID. This request was submitted on your behalf by Mr. Ralph McGee of Hart & Hickman (H&H) on October 22, 2020 via email. DEQ understands the redevelopment on the Chadbourn Mills Brownfield Property (20086-16-060) and Theron Brownfields Property (23035-19-060) will be done jointly under the DEQ-approved Environmental Management Plan (EMP)
dated January 27, 2020.
DEQ Brownfields and Solid Waste Section reviewed the soil analytical data provided in the Supplemental Brownfields Assessment Report dated October 30, 2019 prepared by H&H as well as previously collected soil samples from the Reeve’s LCID. The exported request includes
grubbing soils from across the brownfields properties excluding EX -18, EX-23, soil generated
during excavation of the crane platform, and trenching from installation of a storm water pipe within sections EX-10 and EX-12. Based upon our review, these soils are approved for disposal to the Reeves LCID Landfill, or another LCID Landfill with background arsenic concentrations similar to those identified at the Brownfields Property, a Construction & Demolition (C&D)
Landfill, Municipal Solid Waste (MSW) Landfill, or at another Brownfields Property with prior
DEQ Brownfields approval.
Mr. Will Smith October 29, 2020
Page 2 All soil export must be conducted under the DEQ Brownfields approved EMP. Per the 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 the 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 Jordan Thompson by phone at 704-223-6549 or by email at
[e-mail], or Ervin Lane by phone at 919-707-8288 or by email at [e-mail]. Sincerely,
Jordan Thompson Ervin Lane Project Manager Hydrogeologist Brownfields Program Solid Waste Section enclosures
ec: Carolyn Minnich, DEQ Ralph McGee [e-mail]