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HomeMy WebLinkAbout04004_National Textiles_SIR_2022.02.03 DWM Brownfields Inspection Report Submitted By: jkslaughter_ncdenr Submitted Time: 02/04/2022 10:42 AM I. Inspection Information Date & Time: 02/03/2022 12:52 PM Inspection Type: Drive-By Brownfields Staff: Kevin Slaughter Other Personnel: Tom Parlier – Rough Mill Supervisor Location: Lat: 35.7189514, Long: -81.754073, Brownfields Inspection Report: National Textiles, 04004-00-012 02/03/2022 12:52 PM Page 2 of 8 II. Project Information Number: 04004-00-012 Name: National Textiles Address: 100 Reep Dr City: Morganton County: Burke III. Environmental Current Use of Property: Industrial Structures on Property: Existing Structures Violation: Unknown Vapor Mitigation Systems: Observed Vapor Mitigation Violation: Unknown Use of Surface Water or Groundwater: Not Observed Water Use Violation: No Exposed Soils: Not Observed Exposed Soils Violation: No Summary: Extensive ground floor and basement level floor and wall sealing performed on the east side of building (Photos 5 and 6). Please see LUR 12 “Remarks” in attached Land Use Restriction Update in relation to potential Vapor Mitigation Violation. Summary: N/A Summary: Former textile mill currently used for furniture production. Please see LUR 11 and LUR 15 “Remarks” in attached Land Use Restriction Update in relation to potential Structures Violation. Summary: N/A Brownfields Inspection Report: National Textiles, 04004-00-012 02/03/2022 12:52 PM Page 3 of 8 Use of Basements: Observed Basement Violation: No Storage of Chemicals: Observed Chemical Violation: Unknown Groundwater Monitoring Wells: Not Observed Monitoring Well Violation: No Current Exposure to Public/Public Risk: IV. Inspector Comments Summary: Basement is present, and is used for furniture manufacturing, painting, paint/thinner storage, etc. Floor sealing performed in the “Area of Potential Vapor Concern” shown within the NBP appeared in good condition and was performed and its condition monitored by Mr. Parlier. Summary: Extensive amount of chemicals present at furniture manufacturing facility (Photos 8 and 9). Chemical inventories performed during 2014 and 2016 and no chemicals of concern were identified. Did not attempt to perform an inventory during inspection due to the number of containers present. Condition: Summary: N/A Chain link fence installed around perimeter of the property with guard shack present at entrance. No risk to the public observed during the Site Inspection. Mr. Parlier accompanied me through the facility during the unannounced Site Inspection. Floor crack and penetration sealing on the ground and basement floors appeared in good condition (Photos 5 through 7). According to Mr. Parlier, the floor sealing performed along the eastern side of the facility, encompassing the “Area of Potential Vapor Concern” as shown within the NBP, extends past the area highlighted on the plat map. Brownfields Inspection Report: National Textiles, 04004-00-012 02/03/2022 12:52 PM Page 4 of 8 V. PHOTOGRAPHS Photo 1: Photo of furniture plant offices located on southeastern corner of facility. Brownfields Inspection Report: National Textiles, 04004-00-012 02/03/2022 12:52 PM Page 5 of 8 Photo 2: View of plant facing northeast. Photo 3: Eastern side of plant where PCE source was previously identified. Diesel fuel AST not in use. Brownfields Inspection Report: National Textiles, 04004-00-012 02/03/2022 12:52 PM Page 6 of 8 Photo 4: Photo of furniture manufacturing area. Photo 5: Example of ground floor crack sealing observed during inspection. Brownfields Inspection Report: National Textiles, 04004-00-012 02/03/2022 12:52 PM Page 7 of 8 Photo 6: Basement floor sealing observed during the inspection. Photo 7: Additional basement floor sealing. Brownfields Inspection Report: National Textiles, 04004-00-012 02/03/2022 12:52 PM Page 8 of 8 Photo 8: Small sample of the paints, stains and thinners used during furniture manufacturing. Photo 9: Additional chemicals used in furniture production. Room where chemicals were stored was constructed as a secondary containment room. Approximately 6-inch-tall concrete containment wall visible around perimeter of room and in Photo 8. NC BROWNFIELDS LAND USE RESTRICTIONS (“LUR”) UPDATE Year Certification Made: 2021 Name: National Textiles Project #: 04004-00-012 Address: 100 Reep Drive County: Burke Prospective Developer: Reep Drive LLC / DIC Properties LLC Read the following LURs and mark each restriction accordingly. Additional remarks may be added for compliance status clarification. Attach any required or supplemental documentation, sign, notarize and submit to the following address: NC Division of Waste Management Attn: Brownfields Program Staff 1646 Mail Service Center Raleigh, NC 27699-1646 LUR 1: No use other than industrial may be made of the Property. Heavy and light manufacturing uses are industrial uses for purposes of these land use restrictions; the following definitions of those terms apply herein: i. Heavy Manufacturing: The assembly, fabrication, or processing of goods and materials using processes that ordinarily have greater than average (though legal) impacts on the environment, or that ordinarily have significant impacts (though legal) on the use and enjoyment of adjacent property in terms of noise, smoke, fumes, odors, glare, or health and safety hazards, or that otherwise do not constitute “light manufacturing” or any use where the area occupied by outdoor storage of goods and material used in assembly, fabrication or processing exceeds 25 percent of the floor area of all buildings on the lot. ii. Light Manufacturing: The assembly, fabrication or processing of goods and materials using processes that ordinarily do not create noise, smoke, fumes, odors, glare, or health or safety hazards outside of the building or lot where such assembly, fabrication or processing takes place, where such processes are housed entirely within a building, or where the area occupied by the outdoor storage of goods and material used in such processes does not exceed 25 percent of the floor area of all the buildings on the property; light manufacturing also includes industrial uses in which no process water or wastewater is generated. ☒ In compliance ☐ Out of compliance Remarks: ______________________________________________________________ National Textiles (#04004-00-012) LUR Update LUR 2: Surface water and underground water at the Property may not be used for any purpose without the approval of the Department of Environmental Quality (“DEQ”). ☒ In compliance ☐ Out of compliance Remarks: ______________________________________________________________ LUR 3: No activities that encounter, expose, remove or use groundwater (for example, installation of water supply wells, fountains, ponds, lakes or swimming pools, or construction or excavation activities that encounter or expose groundwater) may occur on the Property, other than those required by paragraph 14 of the Brownfields Agreement (“Agreement”), without prior sampling and analysis of groundwater to the satisfaction of DEQ in any areas proposed for such activities, and submittal of the analytical results to DEQ. If such results disclose to DEQ contamination in excess of North Carolina’s groundwater quality standards, the proposed activities may not occur without the approval of DEQ on such conditions as DEQ imposes, including at a minimum compliance with plans and procedures, approved pursuant to applicable law, to protect public health and the environment during the proposed activities. ☒ In compliance ☐ Out of compliance Remarks: ______________________________________________________________ LUR 4: Soil, landscaping and contours at the Property may not be disturbed without the approval of DEQ, except for mowing and pruning of above-ground vegetation. Such approval shall not be unreasonably withheld. ☒ In compliance ☐ Out of compliance Remarks: ______________________________________________________________ LUR 5: No mining may be conducted on or under the Property, including, without limitation, extraction of coal, oil, gas or any other minerals or non-mineral substances. ☒ In compliance ☐ Out of compliance Remarks: ______________________________________________________________ National Textiles (#04004-00-012) LUR Update LUR 6: No basements may be constructed on the Property. ☒ In compliance ☐ Out of compliance Remarks: ______________________________________________________________ LUR 7: None of the contaminants known to be present in the environmental media at the Property, including those listed in paragraph 8 of the Agreement, may be used or stored at the Property without the prior approval of DEQ, except in de minimis amounts for cleaning and other routine housekeeping activities. ☒ In compliance ☐ Out of compliance Remarks: ______________________________________________________________ LUR 8: LUR 8: The Property may not be used as a playground, or for child care centers or schools. ☒ In compliance ☐ Out of compliance Remarks: ______________________________________________________________ LUR 9: No building on the Property may be constructed or enlarged until DEQ has been consulted regarding the proximity of the planned building or expansion to the Property’s volatile contaminant plume. If DEQ determines that the footprint of the building would fall within one hundred (100) feet of said plume, construction may not occur without a DEQ-approved vapor barrier system and/or mechanical or passive vapor mitigation system, or other effective vapor mitigation system approved by DEQ. Within thirty (30) days following installation of the barrier and/or mitigation system, DEQ shall be provided certification of proper installation under seal of a professional engineer licensed in North Carolina, as well as photographs illustrating the installation and a brief narrative description. No action may be taken that would alter, modify or impede the function of any vapor barrier system and/or mechanical or passive vapor mitigation system without DEQ’s prior written approval. ☒ In compliance ☐ Out of compliance Remarks: ______________________________________________________________ National Textiles (#04004-00-012) LUR Update LUR 10: No enlarged area of any building depicted on the plat component of the Notice of Brownfields Property referenced in paragraph 19 (“existing building”), nor any building not depicted on said plat (“new building”), may be used until mechanical ventilation with outdoor air is provided in compliance with the most current version of the Mechanical Ventilation section of the Ventilation chapter of the North Carolina State Building Code (“Code”) or another standard approved in writing in advance by DEQ, notwithstanding any exceptions the Code or alternative standard may contain, unless compliance with this land use restriction is waived in writing by DEQ in advance in regard to particular enlargements or buildings. Within thirty (30) days following installation of the subject mechanical ventilation in a new building, or modification of a mechanical ventilation system in connection with enlargement of an existing building, a professional engineer licensed in North Carolina shall provide DEQ certification under seal that the ventilation system was installed in accordance with its design specifications and complies with the Code. ☒ In compliance ☐ Out of compliance Remarks: ______________________________________________________________ LUR 11: As to buildings depicted on the plat component of the Notice of Brownfields Property, within 120 days after recordation of the Notice, a professional engineer licensed in North Carolina shall provide DEQ certification under seal that mechanical ventilation with outdoor air is being provided using a mechanical ventilation system that is in compliance with the most current version of the Mechanical Ventilation section of the Ventilation chapter of the Code or another standard approved in writing in advance by DEQ, notwithstanding any exceptions the Code or alternative standard may contain, unless compliance with this LUR is waived in writing by DEQ in advance in regard to particular buildings. ☒ In compliance ☐ Out of compliance Remarks: In April 2016 work and testing at the site was done by National Textiles, LLC, the Prospective Developer and former site owner. During February 2019, NC DEQ sent correspondence to National Textiles requesting a second round of sampling. Reep Drive LLC, the current owner, continues to await National Textiles’ response to that letter. LUR 12: In any building depicted on the plat component of the Notice, within 120 days after recordation of said Notice all sumps, cracks and other subsurface openings and penetrations in the floor within the area denominated “Area of Potential Vapor Concern” shall be and remain permanently sealed with concrete, epoxy resin and/or other material that meets with DEQ’s prior written approval unless this land use restriction is waived in writing, in advance, by DEQ in regard to particular buildings. DEQ may, in its discretion, approve in writing, in advance, new penetrations of the floor in the area denominated “Area of Potential Vapor Concern” in connection with redevelopment activities on condition that any such penetrations be immediately sealed. If such penetrations occur, within thirty (30) days after completion of the redevelopment in question, as determined by DEQ, DEQ shall be provided a report that includes a narrative description and National Textiles (#04004-00-012) LUR Update photographic illustrations, prepared under seal of a licensed professional engineer, certifying that all penetrations in the building in question are sealed. ☒ In compliance ☐ Out of compliance Remarks: In April 2016 work and testing at the site was done by National Textiles, LLC, the Prospective Developer and former site owner. During February 2019, NC DEQ sent correspondence to National Textiles requesting a second round of sampling. Reep Drive LLC, the current owner, continues to await National Textiles’ response to that letter. LUR 13: No party conducting environmental assessment, in the form of sampling or otherwise, or remediation at the Property at the direction of, or pursuant to a permit or order issued by, DEQ may be denied access to the Property for purposes of conducting such assessment or remediation. ☒ In compliance ☐ Out of compliance Remarks: ______________________________________________________________ LUR 14: The owner of any portion of the Property where any existing or later DENR- approved monitoring well is damaged shall be responsible, at DEQ’s discretion, for abandonment or repair of such well(s) in compliance with 15A NCAC 2C to DEQ’s written satisfaction and within a time period acceptable to DEQ, unless this requirement is waived in writing by DEQ. Upon DEQ’s written request to abandon a monitoring well, the owner of the portion of the Property containing the well shall effect abandonment in compliance with 15A NCAC 2C. Said owner shall provide DEQ a written summary of the abandonment procedures used, as well as well abandonment log(s), within thirty (30) days after abandonment. ☒ In compliance ☐ Out of compliance Remarks: ______________________________________________________________ LUR 15: During January of each year after the year in which the Notice referenced in paragraph 19 of the Agreement is recorded, the then current owner of any part of the Property shall submit a notarized Land Use Restrictions Update (“LURU”) to DEQ certifying that: i. the Notice of Brownfields Property containing these land use restrictions remains recorded at the Burke County Register of Deeds office; ii. the land use restrictions are being complied with;