CCB0053_RacePark_INSP_20200210

North Carolina Department of Environmental Quality | Division of Waste Management 217 West Jones Street | 1646 Mail Service Center | Raleigh, North Carolina 27699-1646 919.707.8200

February 28, 2020 Sent via email: [e-mail] William Ratchford, Southwood Realty Triangle Real Estate of Gastonia, Inc. 165 South York Street Gastonia, NC 28053 SUBJECT: Site Inspection and Document Request Race Park USA Structural Fill (aka Palisades at Water’s Edge Phase II) Doolie Road South of Hwy 150 (approx. address 122 Doolie Rd) Coal Combustion By-Products Structural Fill CCB0053 Iredell County Dear Mr. Ratchford: On February 10, 2020, staff from the Solid Waste Section (Section) and the Division of Water Resources (DWR) conducted a site visit of the property containing the closed Race Park USA structural fill, CCB0053 in Mooresville, North Carolina. During the site inspection, staff observed the following multiple areas of erosion resulting in degradation of the access roadside slopes and ditches, and of the areas above the newer sediment basin adjacent to and including the cap of the closed structural fill (photos below). Although no ash was observed, continued eroding of these areas could result in such an exposure. Staff also observed stockpiled solid waste from the demolition of the house in the area of proposed future development, that had been left on the ground and exposed to the weather. Please take the following actions to address these concerns: 1. Take immediate action to repair all erosion in these areas to prevent possible damage to the closed structural fill that could lead to re-exposure of ash. Any repairs should be made in consultation with local erosion control staff and in compliance with the site’s approved erosion and sedimentation control plan issued by Iredell County. 2. All solid waste generated from the demolition of the house should be collected and hauled to an approved construction and demolition or municipal solid waste landfill. Copies of disposal receipts should be sent directly to Charles Gerstell, Environmental Sr. Specialist, in our Mooresville Regional Office at [e-mail].
North Carolina Department of Environmental Quality | Division of Waste Management 217 West Jones Street | 1646 Mail Service Center | Raleigh, North Carolina 27699-1646 919.707.8200
Ratchford – Race Park USA Site Inspection Letter Page 2 of 3 February 28, 2020

In addition, please provide a copy of the approved redesign drawings for Phase 2 including utilities. This is a follow-up request from the NOD Resolution letter issued to you in June 2019. Department staff will then arrange a follow-up meeting with you, your consultant and contractor to discuss future grading plans, including but not limited to, appropriate notification and contingency plans that may be required moving forward. As a reminder, Brandy Costner with DWR stated in site meetings last spring in which you were present, that the well on the property containing the now demolished house shall be properly abandoned and the abandonment documentation to be submitted directly to her office. The well appeared intact during this site visit and no documentation of an abandonment has been submitted to date. Please take the necessary steps to close out this issue. Department staff may conduct additional site visits to ensure the above items are being addressed in a timely manner. Failure to act on these items could lead to tiered enforcement action moving forward. Thank you for your cooperation in this matter. If you have any questions or feel a need to meet with staff to discuss these items, please contact me at 336-776-9674 or e-mail [e-mail]. Sincerely, Jason M. Watkins, CPM Field Operations Branch Head Division of Waste Management - Solid Waste Section Copies: Ed Mussler, Section Chief, Solid Waste Section Charles Gerstell, Solid Waste Section Brandy Costner, NCDEQ, Division of Water Resources Randall Moore, Iredell County Erosion Control
North Carolina Department of Environmental Quality | Division of Waste Management 217 West Jones Street | 1646 Mail Service Center | Raleigh, North Carolina 27699-1646 919.707.8200
Ratchford – Race Park USA Site Inspection Letter Page 3 of 3 February 28, 2020

Erosion of roadside slope adjacent to basin and structural fill
Erosion of road fill and slope. Note portion of debris from demolished house in background