CCB0036_ImperialTobacco_NoViolationCoverLetter_FID1359213_20191009

ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
MICHAEL SCOTT
Director
NORTH CAROLINA
Environmental Quality
October 9, 2019
Sent via email to: elton.danielsPro ckymountnc.gov
Elton Daniels, Director
Parks and Recreation
City of Rocky Mount
331 S Franklin St.
Rocky Mount, North Carolina 27802
SUBJECT: Structural Fill Inspection and Maintenance Reminder
Imperial Tobacco - Rocky Mount
Coal Combustion By -Products Structural Fill CCB0036
Nash County
Dear Mr. Daniels:
On July 10,2019, Elizabeth Werner, Davy Conners, and Benjamin Jackson, representing the Solid
Waste Section (Section), inspected property containing the closed Imperial Tobacco - Rocky Mount,
CCB0036, located at 270 Gay Street, Rocky Mount, NC, in Nash County. The structural fill on this
property was constructed under the rules codified in 15A NCAC 13B Section. 17 0 0. On May 31, 2005,
the City of Rocky Mount sent a letter to the NC Department of Environmental Quality informing them
that during the demolition of an old warehouse to build an Arts Center and Children's Museum the
City discovered a layer of coal combustion by-product approximately four inches deep beneath the
floor slabs. They estimated the quantity of coal combustion waste to be approximately 225 cubic
yards. The City requested to remove the material and use it to backfill the foundation of the
planetarium. On June 7, 2005 DEQ sent the City a letter stating that the May 31, 200S letter satisfies
the Notification requirements in Section .1700.
During the inspection, it was observed that the site was paved, grassed over and had the Imperial
Center for the Arts and Sciences and the Rocky Mount Children's Museum on it. No exposed ash was
observed.
Attached is a copy of our site inspection report providing additional information.
Owners of properties containing closed structural fills are responsible for the care and maintenance
of the fill in a manner to ensure protection of the public health and environment. 15A NCAC
13B .1705 (a) states in part that structural fills must be "maintained in such a manner as to minimize
the potential for harmful release of constituents of coal combustion by-products to the environment
or create a nuisance to the public."
D_E
NORTH CAROLINA Q
U
department of En i,e V.tal auality
North Carolina Department of Environmental Quality I Division of Waste Management
217 West Jones Street 11646 Mail Service Center I Raleigh, North Carolina 27699-1646
919.707.8200

Imperial Tobacco - Rocky Mount
Inspection/Maintenance Letter
Page 2 of 2
October 9, 2019
One of the most effective ways to minimize releases and/or nuisance conditions is to maintain the
approved cap system over the fill in accordance with .1705(j), which states "all structural fills shall
be covered with a minimum of 12 inches compacted earth, and an additional surface six inches of soil
capable of supporting native plant growth." Many of these sites had alternative caps or end uses that
were approved at the time of construction. Currently the cap system at this facility consists of the
concrete foundation for the planetarium.
Section staff may periodically conduct follow-up inspections of this property to determine continued
compliance with the applicable rules. Failure to maintain compliance with the applicable rules could
result in enforcement action. In the interim, if site conditions change due to property usage or if you
observe any changes to the physical conditions of the cap system, please notify the Section
immediately.
Thank you for your cooperation in this matter. If you have any questions, please contact meat (919)
707-8290 or e-mail [e-mail].
Sincerely,
Digitally signed by Davy Conners
DIN: cn=Davy Conners, o=Division of
Waste Management, ou=Solid Waste
Section,
email=[e-mail], c=US
Date: 2019.10.09 11:44:09-04'00'
Davy Conners
Environmental Specialist II
Division of Waste Management - Solid Waste Section
copies: Ed Mussler, Section Chief, Solid Waste Section
Sarah Rice, Environmental Program Consultant, Solid Waste Section
Jason Watkins, Field Operations Branch Head
e:!5fD,E
NORTH CAROLINA
ilapa�mant Oi EnvironmanGl quality
North Carolina Department of Environmental Quality I Division of Waste Management
217 West Jones Street 11646 Mail Service Center I Raleigh, North Carolina 27699-1646
919.707.8200