CCB0053_PalisadesII_planresponse

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

June 24, 2021

Sent via email: [e-mail] William Ratchford, Southwood Realty
Triangle Real Estate of Gastonia, Inc.
165 South York Street
Gastonia, NC 28053

SUBJECT: Revised Development Plan Response
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,

The letter is in response to the submittal of revised development plans for Phase II of the
reference development, submitted via email by Piedmont Design Associates, PA on June 15,
2021. We are not opposed to the development of the project as designed, however consistent
with past communication with you, your consultant(s), and contractors, we have concerns
related to how construction activities will interact with the ash structural fill and ensuring that
proper processes and measures are in place to mitigate any potential impacts to public health
and the environment.

Based on our review of the plans, it would appear there are several possible points where ash
may be exposed during construction. Those are in initial clearing of the remaining trees between
the current construction road and the northern property boundaries, installation of stormwater
and other utilities, and in building the clubhouse and pool. As such, we are requesting the
following prior to any construction of the next phase of development:

1. Submittal of an ash management plan detailing construction sequencing and best
management practices to be utilized during construction to limit ash exposure. Some
considerations in developing the plan:
a. Timely removal of the aforementioned wooded area of the project and placement
of soil cover across the area.
b. Reducing the amount of time any excavation into the ash fill stays open to mitigate
exposure to both personnel and stormwater (i.e., rain).
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/Triangle Real Estate Palisades Revised Plan Response
Page 2 of 2
June 24, 2021

c. If coal ash material is staged for reuse for any amount of time once removed from
the excavation, it should be properly stored using best management practices.
Coal ash material should be staged, at a minimum on plastic and kept covered to
eliminate the potential for the material to become airborne due to wind, as well
as runoff due to wet weather. Other BMPs should be utilized as needed (i.e.,
wattles, silt fencing, etc.).
d. Contact stormwater should be properly managed. Steps should be taken to
reduce and/or eliminate the potential for contact stormwater. If contact
stormwater is present, then it should be properly handled and disposed of.
e. Proper PPE should be utilized by personnel who may come in contact with coal
ash material.
f. Proper disposal of any excess ash material at a permitted landfill.
2. An on-site preconstruction meeting to discuss the implementation of the approved plan.

We are also willing to meet with you and the appropriate parties in the next few weeks, either in
person or virtually, if assistance is needing to develop the plan requested above. You may contact
me directly at [phone] or [e-mail] to schedule a meeting.

Thank you again for providing the revised plans for our review and we look forward to continuing
to work with you moving forward with this next phase of the development.

Sincerely,

Jason M. Watkins, CPM
Field Operations Branch Head
Solid Waste Section

Copies(email): Ed Mussler, Solid Waste Section Chief
Larry Frost, Coal Ash Project Manager
Charles Gerstell, Sr. Environmental Specialist
Sarah Rice, Environmental Program Consultant
Brandy Costner, Hydrogeologist
Jeff Ledford, Southwood Realty
John Hart, Piedmont Design
Donald Munday, Piedmont Design
Matt Hovis, Neill Grading