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Home My WebLink About16019_Enfield_EMP_20150930 MAILING ADDRESS – POST OFFICE BOX 639 – CARY, NORTH CAROLINA 27512 NORTH CAROLINA BOARD OF EXAMINERS FOR ENGINEERS AND SURVEYORS LICENSE C-3559 NORTH CAROLINA BOARD FOR LICENSING OF GEOLOGISTS LICENSE C-261 NC DENR REGISTERED ENVIRONMENTAL CONSULTANT NUMBER 00061 ENVIRONMENTAL GEOLOGISTS & ENGINEERS 511 KEISLER DRIVE – SUITE 102 CARY, NORTH CAROLINA 27518 OFFICE: (919) 858–9898 WWW.DUNCKLEEDUNHAM.COM LETTER OF TRANSMITTAL Via electronic transmittal: lebeed.kady@ncdenr.gov To: Lebeed, Kady, North Carolina Brownfields Program From: Daphne Jones, Duncklee & Dunham Date: 9/30/2015 The following document is attached: Draft Letter / Report Final Letter / Report - Enfield Timber EMP Laboratory Report Certification Forms Contract or Change Order Other: For the following action: For Your Review / Information For Your Signature & Return As You Requested Other: Attached is the Environmental Management Plan for Enfield Timber/Old Quality Forest Products Brownfields Site, Project No. 16019-12-042. We had attached a draft version of this EMP to our Remedial Goals letter dated September 10, 2015. Per your email dated 9/29/2015 you stated the remedial goals for Old QFP are acceptable and to submit the final EMP. ec: George Junkin, Enfield Timber Elizabeth Hall, Troutman Sanders Tom Dunham, Duncklee & Dunham 1 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: 9/10/2015 Brownfields Assigned Project Name: Former Quality Forest Products Site Brownfields Project Number: 16019‐12‐042 Brownfields Property Address: 21144 Hwy 301 South, Enfield, North Carolina Brownfields Property Area (acres): 58.78 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): Enfield Timber, LLC (Thomas C. Evelyn) Phone Numbers: Office: (804)966‐2366…..Mobile: Email: tcevelyn54@yahoo.com Primary PD Contact: George Junkin Phone Numbers: Office: Click here to enter text. Mobile: (443)‐324‐9969 george@americanlandconcepts.com Email: Environmental Consultant: Duncklee & Dunham, P.C. Phone Numbers: Office: 919‐858‐9898 x 204 …..Mobile: 919‐271‐3251 Email: daphne@dunckleedunham.com Brownfields Program Project Manager: Lebeed Kady Office: 919‐707‐8378 2 EMP Form ver.1, October 23, 2014 Email: lebeed.kady@ncdenr.gov Other DENR Program Contacts (if applicable, i.e., UST Section, Inactive Hazardous Site Branch, Hazardous Waste, Solid Waste): REC Program (monitored natural attenuation for groundwater at site); formerly regulated under HWS (Harvi Cooper) 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: Enfield Timber will begin site development by installing a saw mill in the northern most building. The saw mill will produce and assemble hardwood crane mats and untreated railroad ties. Enfield Timber will also install a mill to make untreated oak/pine pilings from oak/pine trees. The location of this operation has not been established, but may be either in the location of the former drip pads in the southern end of the site or nearer the saw mill. A log yard will also be established along with storage areas for finished product. The small dilapidated buildings that are structurally unsound our unusable will be raized. At this point there are no plans to remove concrete pads or pavement. 3 EMP Form ver.1, October 23, 2014 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 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): Phase I is anticipated to start on October 1, 2015 and last three months. Phase I will consist of establishing the timber yard and finished product area and setting up the hardwood saw mill. NCBP will be notified when the schedule has been finalized. b) If applicable, Phase 2 start date and anticipated duration (specify activities during each phase): Phase 2 will be the installation of the pine piling mill. The anticipated start date has not been established but may also be October 1, 2015. However, the date has not been established. NCBP will be notified when the schedule has been finalized. 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: 1/1/2016 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): Arsenic, which has been remediated to less than the background concentration of 8.18mg/kg. This concentration does not exceed the site‐specific residential health‐based remedial goal of 35 mg/kg or the site‐specific 4 EMP Form ver.1, October 23, 2014 industrial health‐based remedial goal of 300 mg/kg. Calculations of the remedial goals were presented in the cover letter accompanying the draft EMP dated September 10, 2015. 2) Depth of known or suspected contaminants (feet): Not applicable; contamination does not exceed residential RGs 3) Area of soil disturbed by redevelopment (square feet): Not applicable; contamination does not exceed residential RGs 4) Depths of soil to be excavated (feet): Soil will excavated to prepare footers for the hardwood saw mill and pine piling mill. The anticipated depth of the soil excavation is no greater than three feet 5) Estimated volume of soil (cubic yards) to be excavated (attach grading plan): Not applicable; contamination does not exceed residential RGs 6) Estimated volume of excavated soil (cubic yards) anticipated to be impacted by contaminants: Not applicable; contamination does not exceed residential RGs 7) Estimated volume of contaminated soil expected to be disposed of offsite, if applicable: None 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? 3) If yes, what is the depth of fill soil to be used at the property? 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 1 for information regarding evaluation of soil from off‐site sources. 5 EMP Form ver.1, October 23, 2014 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  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: Arsenic is the only constituent of concern at the site, and has been remediated in the soil to concentrations that do not exceed the site‐specific background concentration of 8.18 mg/kg. The D004 regulatory level for toxicity of arsenic of 5.0 mg/l. Using the inherent 20x dilution factor in the TCLP procedure, concentrations of arsenic would have to exceed 100 mg/kg in the soil to exceed this threshold. The other characteristics listed are not applicable. 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. 6 EMP Form ver.1, October 23, 2014 ☐ 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: The calculated soil remedial goal was presented in the cover letter attached to the draft EMP dated September 10, 2015 and was approved in an email dated September from Lebeed Kady of the NCBP. 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: Not required; contamination does not exceed residential RGs ☐ Field Screening: ☐ Yes  No If yes, describe method; If no, explain rationale: No VOCs are present at the site. Additionally, the remaing arsenic concentrations do not exceed the residential RGs. ☐ Soil Sample Collection: ☐ Yes  No If yes, describe method (e.g., in‐situ grab, composite, stockpile, etc.); If no, explain rationale: Not required; contamination does not exceed residential RGs ☐ 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: Not required; contamination does not exceed residential RGs ☐ 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 7 EMP Form ver.1, October 23, 2014 ☐ 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 ☐ 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: PD does not plan to take any soil offsite. If, however, it is required, the soil will be properly tested and sent to a Subtitle D landfill for use as daily cover. 8 EMP Form ver.1, October 23, 2014 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: Not required; contamination does not exceed residential RGs and no VOCs are present in soil on this site. 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? Approximately 8 feet below ground surface in the northern part of the property to around 1 foot bgs in the southern portion of the property. Is groundwater known to be contaminated by onsite ☐ offsite ☐ both ☐ or unknown sources? Describe source(s): Former wood treatment operations at the property. What is the direction of groundwater flow at the Brownfields Property? South to southeast Will groundwater likely be encountered during planned redevelopment activities? ☐ Yes  No If yes, describe these activities: Groundwater will not likely be encountered during the excavation for the hardwood sawmill footers. The depth to the seasonal high water table in the vicinity of the hardwood sawmill is approximately 5 feet – well below the depth of the footers. The depth required for the pine piling mill footers is not know at this time. However, the location of the mill will be moved such that groundwater is not encountered. The PD will use the historical depth to groundwater data for the REC program groundwater monitoring to determine the seasonal high water table.. 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): Although groundwater is not anticipated to be encountered, if it is encountered and it is necessary to extract the groundwater for the mill footers, the water will be containerized, tested for arsenic and chromium and disposed of in a manner similar to the groundwater investigation‐derived waste collected during the periodic groundwater sampling as part of the REC program 9 EMP Form ver.1, October 23, 2014 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): The only surface water is Fishing Creek, which forms the southern boundary of the property. Of the 59‐acre site, only 18 acres are cleared and used for facility operations, which are located in the central and northern portion of the property. The land next to the creek are unusable wetlands. Additionally, no open excavations are planned. The new construction will use sub‐grade pilings as support for its structures. 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): Not applicable. Redevelopment will only occur in the already‐developed northern/central portion of the site. 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 10 EMP Form ver.1, October 23, 2014 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? No volatile constituents of concern at the site. 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: No volatile constituents of concern at the site. 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: No volatile constituents of concern at the site. 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: No volatile constituents of concern at the site. 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: No volatile constituents of concern at the site. 11 EMP Form ver.1, October 23, 2014 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. 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: No volatile constituents of concern at the site. 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 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-.REOEVElOPMENT REPORTING In accorcfance with the site's Brownfield Agreement, provide a report within the designated schedule to the State Brownfields Project Manager. 0 Check box to acknowledge consent to provide a redevelopment summary report In c:ompllante with the site's Brownflelds Agreement. APPROVAL SJGNATUitES Date George M. Junkin/Member/Enfield Timber, LLC &,L~ Consultant -Date Daphne M. Jones, L.G./Senlor Geologist/Duncklee & Dunham, P.C, Brownfields Project Manage ~Lebeed Kady 12 EMP Form ver.1, October 23, 2014 ,, Appendix 1 Appendix 1 Addendum to Environmental Management Plan Evaluation of Soil from Off‐Site Sources Enfield Timber/Former Quality Forest Products Site Enfield, 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 Environment and Natural Resources (DENR) regulatory programs other than to state that clean backfill should be utilized. We also understand the desire of the NCBP to not place contaminated 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 Barrow Pit – Backfill material obtained from a commercial barrow pit using virgin material will not be tested. Barrow 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 DENR‐certified analytical laboratory for analysis for semivolatile organic compounds (SVOCs) according to SW-846 Method 8270D and volatile organic compounds (VOCs) according to Method 5035B (prep) with Method 8260B (testing). Metals are generally naturally occurring, and if the fill soil is from a different underlying lithology, its metals concentrations may differ enough from the background concentrations at the former Quality Forest Products site such that it would be deemed unsuitable, even though the metals are not from contaminant releases. We will, however, also test any soil to be brought onsite for total arsenic to ensure it does not exceed the 35 mg/kg calculated residential remedial goal for this site. When possible, 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 I (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. The locations of the aliquots will be randomly selected, and the soil samples will be collected using a hand auger from different depths and locations within 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 then 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 container supplied by the laboratory. All samples will be placed immediately on ice and then 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 Appendix 2 Appendix 2 Environmental Management Plan Contingency Plan to Address Newly Discovered Contaminant Sources Enfield Timber/Former Quality Forest Products Site Enfield, North Carolina During site-redevelopment 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 within the North Carolina Department of Environment and Natural Resources (DENR) within 48 hours of discovery, if only by email. These sources may include, but are not necessarily limited to: 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 DENR‐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 underground storage tanks (USTs) at the site, and none are expected due to the shallow water table conditions. There were, however, ASTs previously used 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 DENR. 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 City of Raleigh 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, if only by email. Residual petroleum‐contaminated media (i.e. soil and/or groundwater) on the 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 DENR within 48 hours of discovery, if only 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 offsite 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 DENR within 48 hours of discovery, if only 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. site.