05016_Southern Mfg IHSB Issue

From:Minnich, Carolyn
To:"Hanna Assefa"
Subject:RE: Southern Manufacturing
Date:Friday, November 22, 2002 11:08:40 AM
Attachments:2002 61CFR.pdf
Hi Hanna:
Thanks for the comments, but I think I uncovered a new regulation that will effect our decision.
Yesterday, I was talking with Pat Curran of the Public Health, DHHS about the project. He was familiar
with the site from site visits in the 1970s and 1980s. I asked about potential of leaving the asbestos soil in
place and covering with a soil cap. He educated me on the NESHAP 40 CFR 61.151 regulations. I
attached the regulations for quick reference. This regulation puts strict regulations on leaving asbestos in
place and considers it an inactive waste disposal site. Were you aware of these regulations when you
approved the soil cap? Based on my initial review, it appears they will have to remove the soil or fall
under strict NESHAP ruling. I know the Prospective Developer with not like the response and I want to
make sure we are on the same page. Please call me to discuss further.

Thank You,
Carolyn Minnich
Brownfields Project Manager
NCDENR
c/o City of Charlotte
Neighborhood Development Key Business
(v) 704/336-3499 (f) 704/336-2527
-----Original Message-----From: Hanna Assefa [mailto:[e-mail]] Sent: Thursday, November 21, 2002 6:05 PMTo: Minnich, Carolyn; DAPHNE OLSZEWSKI; BRUCE NICHOLSON; CHARLOTTE JESNECKSubject: Re: Southern Manufacturing
First clarification of the background info. The 6 to 8 inches in some areas was approved forindustrial commercial exposure where no children were expected to be playing in the soil . At
that time site use as an outdoor arena was not on the table. The approval was also contingenton language in the land use restrictions that would limit soil disturbance and allowed for strict
monitoring of soil disturbance and erosion.
As for your question regarding how much soil is enough- I like Daphne's suggestion with theAGRI. people to determine how much soil is needed for the long term survival of grass/
groundcover. You might even specify the appropriate type of grass to plant- It might make adifference.

I would also like to point out that heavy equipment used during soil capping and arena
construction activities will likely tear up 4 mil plastic under 4 inches of soil. Therefore,consider heavy equipment usage during construction activities in your decision.
Have you considered using sturdy geotechnical fabric instead of plastic. That will mark wherethe contaminated horizon is and serve as an indicator when the soil is disturbed. More than
likely a few inches of soil on top of plastic will easily wash of especially in your sloped
areas. Drainage issues will also have to be addressed for plastic. Ask for the thickness of soilyou feel comfortable with without counting on the plastic as a barrier.
"Minnich, Carolyn" wrote:
Background: This is the site with asbestos in the top soil. Hanna approved a soil cap of 6-8
inches for certain areas of the site. In the brownfields program based on land use, we feltthis was not adequate. We requested 2 feet of soil. The countered with some proposedlanguage which I discussed with y'all a few weeks ago. Benne Hutson on behalf of the PDhas brought another scenario to the table for this project. If they lay a liner down now beforeany soil cap, how much soil would be necessary to protect the environmental and public health? He
proposed 4 inches.I asked the following additional questions via voice mail: 1) What is the
land use in these areas? 2) what will be the expose and traffic of the public in subject
areas? 3) What type of liner will be installed? 4) What are the monitoring and
precaution measures? My question to you all is, What soil cap thickness would be
adequate with a liner? I'm thinking at least 6-8 inches because what can grow in less than1/2 a foot. The area at a minimum would be covered with shallow root grass andmaintained a lawn service company. Let me know your thoughts. They are eager to getsomething worked out because this site maybe slated for the Knights Stadium or the newArena, but that isn't public knowledge.
Thank You,
Carolyn Minnich
Brownfields Project Manager
NCDENR
c/o City of Charlotte
Neighborhood Development Key Business
(v) 704/336-3499 (f) 704/336-2527
From:Minnich, Carolyn
To:"[e-mail]"
Cc:"[e-mail]"
Subject:Southern Manufacturing
Date:Thursday, May 22, 2003 12:38:23 PM
Hi Rick:

Yes, I did talk with Hanna yesterday afternoon. She recommend once the site activities are complete and the letter
report of activities has been submitted to the Brownfields Program, you all submit a written request the IHSB for a
change in the site status. I will forward Hanna copies of the brownfields agreements once the documents are final
after the public comment period ends in June. If you have questions or comments, please contact us. Enjoy the
holiday weekend.
Thank You.
Carolyn Minnich
Brownfields Project Manager
NC Division of Waste Management
c/o City of Charlotte
Neighborhood Development Key Business
600 East Trade Street
Charlotte, NC 28202
Office: 704/336-3499
Fax: [phone]
Mobile: [phone]
-----Original Message-----From: [e-mail] [mailto:[e-mail]]Sent: Thursday, May 22, 2003 11:46 AMTo: [e-mail]: No Subject
Carolyn,
Have you had any success contacting Hanna Assefa? If at all posible I would like to resolve the
outstanding issue of the Inactive hazardous Site Inventory before this holliday weekend.
Thanks
Best regards,
Rick
From:Minnich, Carolyn
To:"[e-mail]"
Subject:RE: No Subject
Date:Thursday, May 22, 2003 1:39:14 PM

See my replies below.
-----Original Message-----From: [e-mail] [mailto:[e-mail]]Sent: Thursday, May 22, 2003 1:28 PMTo: [e-mail]: No Subject
Carolyn,
Thanks for the info. Did Hanna indicate that she would honor our request, if we put it in writing? Do
you think that she will require additional work performed and should that request come from our
company or must it come from BBA?[Minnich, Carolyn] She indicated that they would want to
review the site activities to date and would like a copy of the final letter report summarizing the sites
activities. Yes, I think she will be reasonable. I believe this is an achievable goal for you all to be
removed from the list. The request can come from either company. If it's from you all it would be
submitted on behalf of BBA Holdings.
When does the public comment periord end and will I receive a formal notification from you that
everything is buttoned up?[Minnich, Carolyn] The public comment period end June 1 and we allow
a few extra days for mail delivery. You will receive copies for the agreement for your signature
within a couple weeks. The plat will need to be submitted to the Mecklenburg County Deed's office
and a copy sent back to us. A cover letter with the final documents will explain the process. As far a
compliance with the soil cap requirement, I am awaiting a summary report from you. You may want
to have your consultant prepare this.
Please foreward me a telephone number and mailing address for Hanna.
[Minnich, Carolyn] 919/733-2801 x 279
Superfund Section
DENR
401 Oberlin Road, Suite 150
Raleigh, NC 27605
thanks[Minnich, Carolyn] , thank you! CFM
rick
From:Minnich, Carolyn
To:"[e-mail]"
Subject:RE: No Subject
Date:Monday, June 16, 2003 1:18:26 PM
Hi Rick:
You were on my list to call today, but I'll send my message via e-mail. I have not received the plat, but I need to
talk with about the final report completion of the project. I met with Hanna last week and we discussed what would
be needed to received a No Further Action in the IHSB and meeting the brownfields requirements. We are very
close to the end of this project, but I need a more complete documentation report to wrap up of the project. This
may need to be prepared by your consultant who did the receptor survey or someone else. At a minimum I need the
following information in a letter report:
-what remediation option was selected from the agreement?
-what liner was installed & specifications sheet?
-on what date did the activities occur?
-who installed the liner & soil?
-what methods were used for spreading the soil?
-date of site inspections with DENR (me)?
-summary of erosion controls installed?
-before and after survey with points on site plan and elevation changes. This is a change from the before and after
topographic maps. I spoke briefly with you surveyor and it will be difficult to get a good before and after with 2 ft
contours. Therefore, if possible I would like before and after elevations of various points on the map would serve to
show a change in elevations.
-pictures of the process, if available
I have bits and pieces of this information, but we need it assembled in one complete report. The faxed letter you
sent me a few weeks ago is a good opening, but I need more. After speaking with Hanna last week, she stated that
once conditions of the brownfields agreement were met and a letter to this effect was sent, the site would be
eligible to be delisted from the Inactive Hazardous Site Inventory. This is great news. They will still need a letter
from you all requesting the removal from the list and a copy of the Brownfields approval letter. Call me discuss
further. I'm in today, but out tomorrow in training. I will be in the rest of the week. I can send you a formal letter
requesting this report if you want it for your records.
Thank You.
Carolyn Minnich
Brownfields Project Manager
NC Division of Waste Management
c/o City of Charlotte
Neighborhood Development Key Business
600 East Trade Street
Charlotte, NC 28202
Office: 704/336-3499
Fax: [phone]
Mobile: [phone]
-----Original Message-----From: [e-mail] [mailto:[e-mail]]Sent: Monday, June 16, 2003 12:59 PMTo: [e-mail]
Subject: No Subject
Carolyn,
Have you received the plat showing the earth the remediation work and is it acceptable?
If so please send me a letter reflecting the fact that the work has been completely according to the
Brownsfield Agreement. If not, please call me to discuss it.
Best regards,
Rick Lazes
From:[e-mail]
To:[e-mail]
Subject:Latest draft, if this works for you I"ll send an original by mail. thanks again, rick
Date:Monday, June 16, 2003 4:07:03 PM
Fiber Mills, LLC
3610 Red Oak CourtNew Orleans, La. 70131
Carolyn MinnichBrownsfields Project Manager
NC Division of Waste Mangement c/o City of Charlottte60 East Trade Street
Charlotte, NC 28202
Dear Carolyn:
This letter will serve to notify you that we have successfully completed all of the remediationwork required under our Brownsfields Agreement for the Former Southern Manufacturing
Site, 1000 Seaboard Street, Charlotte, Mecklenburg County, North Carolina.
In regards to paragraph 13 of the Brownsfields Agreement concerning the areas whereasbestos-containing waste is located, as denoted on the plat component of the Notice of
Brownsfields Property referenced in paragraph 17; we have elected option 13 (c) to “install ageotextile liner over the areas and cover it with six inches of compacted non-asbestos
containing material, and grow vegetation on the area adequate to prevent exposure of theasbestos-containing waste;”
Prior to installing the six inches of clean soil over the contaminated area we installed a
geotextile liner. Please see the specifications of this liner attached hereto as Exhibit A.
During the months of April and May, 2003 Baucoms Grading, LLC of Charlotte, NorthCarolina provided the labor and equipment necessary to install the geotextile liner and and soil
cap. We selected to install Geotex 401, a nonwoven geotextile liner, manufactured by SIGeosolutions to cover the asbestos-impacted areas. The liner was approved by DENR on April
21, 2003. The approval letter and specifications are included as Exhibit A. The non-asbestos-containing material, e.g. fill dirt, was transported to the site in dump trucks and then
distributed over the impacted areas (after the installation of the geotextile liner) with earthmoving equipment and then raked manually to assure proper contouring. Eight inch by eight
inch rail road ties were installed at the perimeters of the areas that were covered to preventerosion of the new soil. After the new soil was raked, it was seeded with fescue grass seed and
mulched with hay to promote the growth of the new grass and reduce erosion.
Site visits were conducted between Ms. Carolyn Minnich of DENR and site representativeMr. Mac Goodwin on April 22 and May 19 to confirm site activities. Site photos were
collected by Ms. Minnich for the DENR files.
Please attach the plat that you received from our surveyor, Tony Sanders with Survey &Mapping Control, Inc. as Exhibit B. This plat shows hatched the areas where asbestos-
From:Minnich, Carolyn
To:"[e-mail]"
Subject:Southern Man. Final Report
Date:Wednesday, June 04, 2003 4:22:16 PM
Attachments:SoInd_topo.doc
Southern Manu. Fax 05-28-03 Summary.pdf
Hi Hanna:
I would like your input on the final report for the Southern Manufacturing Remedial Activities. In the BF Program,
I am working with Rick Lazes the Prospective Developer (PD). As we previously discussed, it is his desire and
BBA Holding, Inc. to be removed from the Inactive Hazardous Sites Inventory list. They have covered the asbestos
impacted areas with a liner and a minimum of six inches of soil. This should meet your program requirements and
there are land use restrictions. The BFA is attached for your reference.
I requested the PD provide a summary report of the site activities to demonstrate compliance with the brownfields
agreement. The agreement is still in public comment and is due to come out June 30th. I received the attached letter
as a summary report minus the final topographic map. It is not sufficient. I need more information, but I thought it
might be worthwhile to talk with you and get the full picture of your requirements, too. My goal is to have this final
report can meet both of our program needs.
I would like the report to include the following at a minimum:
-what liner was installed & specification?
-on what date did the activities occur?
-who installed the liner & soil?
-what methods were used for spreading the soil?
-date of site inspections with DENR (me)?
-summary of erosion controls installed?
-before and after survey with points on site plan and elevation changes
After we talk, I will contact Rick and explain what is needed. Also, the word attachment is what the surveyor wants
to include on the final Brownfields Plat versus having to show before & after measurements. I don't think it's
enough. Would it be sufficient for your program?
I would like your feedback. I will be in Raleigh next week for the Rick/EI Workshop Wednesday and Thursday
morning. Will you be available to talk Thursday AM?
Thank You.
Carolyn Minnich
Brownfields Project Manager
NC Division of Waste Management
c/o City of Charlotte
Neighborhood Development Key Business
600 East Trade Street
Charlotte, NC 28202
Office: 704/336-3499
Fax: [phone]
Mobile: [phone]
-----Original Message-----
From: Minnich, Carolyn
PAGE 01
3610 Red Oak Court. New Orleans, La. 70131
OFC. (504) 36.1.4321. FAX [phone]
)3 NO. OF PAGES:DATE:
COMPANY:NC Division of Waste ManagementTO;
FAX NO.:704-336-2527
SUBJECT:Borwnsfields Remediation
Carolyn Milmich
Brownsfields Project Manager
Dear Carolyn:
This letter will serve to notify you that we have successfully completed all of the remediation work
required under our Brownsfields Agreement at 1000 Seaboard Street, Charlotte, North Carolina. I
have sent you two topographical surveys, one prior to completing the remediation work and one
after it was comleted. These maps show all of the areas on the property that were known to have
buried asbestos and identify those same areas areas that we have covered with geotextile material
and a minimum of six inches of non contaminated soil. In addition we have complied with all of the
other aspects of our Brownsfields Agreement.
Please send me a letter confinning that this work has been satisfactorily completed in compliance
with the tenns of oW' Brownsfields Agreement.
ThankyOU for your continued assistance with this project
Best regards,
""'~...c.J'\.a_.I\ D c~.~~.~
Richard Lazes, president
Sent: Monday, June 02, 2003 11:42 AM
To: Bruce Nicholson (E-mail)
Subject: FW: So. Industrial Site Topo Certification
Hi Bruce:
I have been talking with the surveyor about how to properly and clearly indicate the site has been adequately
covered with a soil cap. I have an initial topographic survey. It shows contours on the site indicating the current
elevations prior to remedial activities. The survey was explaining to be that a final topo would just show the lines at
2 ft contours. A revised topo would be difficult to see the difference. The survey suggested they attached stated on
the final brownfields plat. I requested the PD update the plat to reflect the actual areas with the soil cap. They did a
bit more in areas and other area was not necessary to be covered. The surveyor has taken field measurements and
would swear on his license the have a minimum of 6" of compacted soil.
I also received the following letter from Rick Lazes, the PD as his version of a summary report. I was thinking of a
bit more, but maybe I'm asking for more that is necessary. My idea of a summary report would include more details
on what they installed (yes, I have this information, but from a fax), when the did it, who did it, what compaction
methods were used, what grass seed was installed, what presentation erosion controls were installed, who did the
surveying and when. I expected a more thorough summary report, but is that necessary. Am I asking for to much, is
this sufficient for you. After the agreement is complete, they are going to Hanna to request removal from the IHSB
Inventory.
What are your thoughts?
Thank You.
Carolyn Minnich
Brownfields Project Manager
NC Division of Waste Management
c/o City of Charlotte
Neighborhood Development Key Business
600 East Trade Street
Charlotte, NC 28202
Office: 704/336-3499
Fax: [phone]
Mobile: [phone]
-----Original Message-----
From: SandMC [mailto:[e-mail]]
Sent: Monday, June 02, 2003 6:07 AM
To: [e-mail]
Subject: So. Industrial Site Topo Certification
Dear Carolyn, Attached is the statement I prepared for certifying the
new overlayment of the asbestos contaminated areas. Please edit and I
will update the map. Thanks, Tony Sanders
containing waste is located and where the liner and soil cap has been installed. T he plat alsocertifies that a minimum of 6" of non-asbestos-containing material has been added per the
brownfields agreement requirement. Also attach the topographical survey Exhibit C of thesite, which depicts the survey points and the elevations before and after the remediation took
place.
Thankyou for your continued support throughout this project.
Best regards,
Richard Lazes, president