SF_F_NCS000002196_20220727_FRB_PASI(2)

DAFCO Totes (a.k.a., Anderson Family Properties)
NCS000002196
Preliminary Assessment References:

1) US EPA 40 CFR Part 300, Hazard Ranking System, Final Rule, Federal Register Volume 55,
No. 241 Part II, July 1, 2019.

2) United States Environmental Protection Agency, Superfund Chemical Data Matrix, Appendix
B, Updated July 2020. Query at: https://www.epa.gov/superfund/superfund-chemical-data-
matrix-scdm-query

3) Google Maps Latitude and Longitude Determination, Aerial Map and Imagery.
https://www.google.com/maps

4) NC DEQ Hazardous Waste Section, Compliance Branch, “RCRA Inspection Report,
Anderson Family Properties, 2698 Hickory Boulevard, Hudson, NC 28638, Site EPA ID#:
NCS000002196”. June 12, 2018.

5) NC DEQ Hazardous Waste Section, Compliance Branch, “Compliance Schedule Evaluation
Report, Anderson Family Properties, 2698 Hickory Boulevard, Hudson, NC 28638, Site EPA
ID#: NCS000002196”. March 11, 2022.

6) Tailored Chemical Products, Hickory, NC: “Final Report, DAFCO Tote Site, 2698 Hickory
Boulevard, Hudson, North Carolina. April 21, 2020.

7) Caldwell County, NC Geographic Information Service (GIS),
https://gis.caldwellcountync.org. Reviewed October 20, 2021.

8) US Fish and Wildlife Service National Wetland Inventory on line Wetland Mapper.
Reviewed December 29, 2021.
https://www.fws.gov/wetlands/data/mapper.html

9) NC DEQ, DWM, Superfund Section, Inactive Hazardous Sites Branch (IHSB) ARC GIS
Map Viewer: https://ncdenr.maps.arcgis.com/apps/webappviewer/index.html

10) Heath, Ralph, Basic Elements of Groundwater Hydrology with Reference to Conditions in
North Carolina, Parts I-II, US Geological Survey Water Resources Investigations Open-File
Report 80-44, 1980.

11) US Department of Agriculture (USDA), Natural Resources Conservation Service, Web Soil
Survey. Reviewed December 29, 2021.
https://websoilsurvey.ncrs.usda.gov/app/WebSoilSurvey.aspx

12) Goldsmith, R., Milton, Horton, D., Wright, J. W. Jr.: Geologic Map of the Charlotte 1o x 2o
Quadrangle, North Carolina and South Carolina, 1988.

13)US National Climatic Data Center: Data Tools, 1981-2010 Normals.
https://www.ncdc.noaa.gov/cdo-web/datatools/normals
14)City of Lenoir NC Public Utilities website: https://www.cityoflenoir.com/189/Public-Utilities
15)Parker, Stuart F., NC DEQ Superfund Section: Electronic communications with Erika
Leonhart, City of Lenoir re: Municipal Water Accounts. January 3, 2022.
16)Parker, Stuart F., NC DEQ, Superfund Section: Property Access Requests and resident
responses. March 2022.
17)North Carolina Wildlife Resources Commission Fishing Areas GIS Mapping Tool:
https://www.ncpaws.org/wrcmapbook/FishingAreas.aspx
18)Parker, Stuart F., NC DEQ, Superfund Section: PA Passive Soil Gas Investigation Field Notes,
May 26 and June 6, 2022.
19)US EPA Vapor Intrusion Screening Level (VISL) Calculator output. August 5, 2022.
https://epa-visl.ornl.gov/cgi-bin/visl_search

REFERENCE 1

REFERENCE 2

REFERENCE 3
SITE

REFERENCE 4
Document Category: Facility
Document Group: Inspection/Investigation (I)
Document Type: Emergency Response (EMR)
LASERFICHE FILE TRANSMITTAL FORM
DIVISION OF WASTE MANAGEMENT
HAZARDOUS WASTE SECTION
Your Name: Jeff Menzel
EPA ID: NCS000002196
Facility Name/Subject: Anderson Family Properties
Document Date: 05/11/2018
Description: Emergency Response (FCI EMR) with deficiencies. IANOV 2018-052
issued.
Author: Jeff Menzel
Facility/Site Address: 2698 Hickory Blvd.
Facility/Site City: Hudson
Facility/Site Zipcode: 28638
Facility/Site State: North Carolina
Facility/Site County: Caldwell
File Room Use Only
Month Day Year
Date Received
by File Room
Date Scanned
Branch/Unit: Compliance Branch-Western Region
(or Inspection Date)
1 Form Amended 07/27/2017
RCRAINFO DATA ENTRY FORM
HAZARDOUS WASTE SECTION - COMPLIANCE BRANCH
For Violations:
Enforcement Date: 5/31/2018 Docket Number: 2018-052
Enforcement Type: IANOV How many violations were there? 2
For IANOV or CO: The facility is
Violation #1:
Date Determined: 5/11/2018
Scheduled Return to Compliance: 6/30/2018 Actual Return to Compliance: Click here to enter a date.
Regulation Description: 40 CFR 262.11, adopted by reference at lSA NCAC 13A .0107(a)
Comment: A hazardous waste determination must be made
For CSE, Corrections to Violations were:
Violation #2:
Date Determined: 5/11/2018
Scheduled Return to Compliance: 6/30/2018 Actual Return to Compliance: Click here to enter a date.
Regulation Description: 15A NCAC 13A .0109(a)
Comment: The treatment, storage or disposal of hazardous waste is prohibited except as provided in 40 CFR Parts
264 and 265, adopted by reference in 15A NCAC 13A .0109 and .0110.
For CSE, Corrections to Violations were:
.
Page 1 of 4

Jeff Menzel– NC Hazardous Waste Section Home Duty Office: P.O. Box117, Black Mountain, NC 28711
Phone: [phone] Email: [e-mail]
http://portal.ncdenr.org/web/wm/hw

NORTH CAROLINA DEPARTMENT OF ENVIRONMENTAL QUALITY
DIVISION OF WASTE MANAGEMENT
HAZARDOUS WASTE SECTION (HWS) / COMPLIANCE BRANCH
RCRA INSPECTION REPORT

1. Facility Information: Anderson Family Properties
2698 Hickory Blvd.
Hudson, NC 28638
Site EPA ID#: NCS000002196
2. Facility Contact: Dan Anderson-Owner
Phone: [phone] Email: [e-mail]

3. Inspector(s): Jeff Menzel, HWS

4. Survey Participants: Brian Englert-US EPA On-Scene Coordinator, Town of Hudson
Representatives, Hudson Fire Department, Hudson Police Department,
Caldwell County Emergency Management, STAT Inc., Marlin Chemical and NC
DEQ DWM/DWR, Dan Anderson-Owner

5. Date/Time of Inspection: May 11, 2018 / Arrived: 10:00am Departed: 1:00pm
Second visit May 23, 2018 / Arrived: 3:00pm Departed: 4:30pm

Date of Report: June 12, 2018 – Prepared by: Jeff Menzel

6. Purpose of Inspection:

On December 18, 1980, the State of North Carolina, Hazardous Waste Section was authorized to operate the
State Resource Conservation and Recovery Act (RCRA) Hazardous Waste Program under the Solid Waste
Management Act (Act), N.C.G.S. 130A, Article 9 and rules promulgated thereto at 15A NCAC 13A (Rules), in
lieu of the Federal RCRA program.

7. Report:

On May 11, 2018, Jeff Menzel the Division of Waste Management, Hazardous Waste Section, inspected the
Anderson Family Properties facility for compliance with North Carolina Hazardous Waste Management
Rules. On May 10, 2018, Tommy Courtner, Hudson Fire Chief, called EPA's Region 4 National Response Center
(NRC) to request that a site investigation be initiated as some of an estimated 7,000 - 10,000 abandoned 250-
gallon totes, stored at 2698 Hickory Blvd. in Hudson, NC, were found to be leaking. The content of the totes
appears to be wastewater generated from the production of white glue. On May 11, 2018, Mr. Brian Englert,
US EPA On-Scene Coordinator, visited the site in response to the NRC report. Also in attendance were
representatives from the Town of Hudson, Hudson Fire Department, Hudson Police Department, Caldwell
County Emergency Management, STAT Inc., Marlin Chemical and NC DEQ. Also in attendance was Mr. Perry
Keister (former DAFCO, Inc. representative) and Mr. Dan Anderson (site property owner representative).
Page 2 of 4

Jeff Menzel– NC Hazardous Waste Section Home Duty Office: P.O. Box117, Black Mountain, NC 28711
Phone: [phone] Email: [e-mail]
http://portal.ncdenr.org/web/wm/hw

The property located at 2698 Hickory Blvd. in Hudson, NC is owned by Anderson Family Properties, LLC
(Anderson Property) and a portion of the property was leased to DAFCO, Inc. in February 2015. DAFCO's
business consisted of fabrication of wastewater treatment systems and the cleaning of wastewater totes for
reuse. It is our understanding that the totes of glue and wastewater, currently on the Anderson Property,
originated from Tailored Chemical Products, Inc., which is based in Hickory, NC. The totes were provided to
DAFCO for cleaning and were then to be returned to Tailored Chemical for reuse. Information reviewed in
2015 demonstrated that the glue and wastewater within the totes would not be a hazardous substance or
hazardous waste. Being unable to process the totes received, DAFCO discontinued all operations after
completing an Asset Purchase Agreement with a company called Eco-Tote Container Services, LLC (Eco-Tote)
located in Charlotte, NC. Under this agreement, Eco-Tote was to process the wastewater within the totes and
return cleaned totes to Tailored Chemical. Eco-Tote processed only a small number of totes before also
discontinuing their operations. Neither DAFCO nor Eco-Tote are currently in operation and the totes were
abandoned on the property.

In addition to the 7,000 -10,000 abandoned 250-gallon totes, The inspector also observed approximately
twenty-five (25) 55-gallon plastic containers during the May 11, 2018 site inspection. A few of the 55-gallon
containers were labeled as corrosive materials, including sodium hydroxide, ferric sulfate, nitric acid,
potassium hydroxide. On May 10, 2018, emergency response personnel performed screening on liquids
within a few of the 55-gallon containers, and pH levels were found to be less than 2.5 standard units. The
inspector was unable to access at least ten (10) of the 55-gallon containers for inspection as they were
surrounded by totes. A second visit on May 24, 2018 found additional field screening of the 55-gallon
containers has identified at least twelve (12) 55-gallon containers and at least one (1) 250-gallon totes as
holding hazardous waste corrosive liquid (EPA Hazardous Waste Code: D002). There is also one (1)
approximately 25-gallon stainless steel container observed onsite that is labeled as nitric acid. The 55- gallon
containers, 25-gallon container and tote have been segregated and assessed for leaks and Mr. Menzel
requested that the container of nitric acid be placed within an over-pack container, as a small hole in the
container was noted. There were also 5-gallon containers observed on the site that could not be accessed.

8. Site Deficiencies Noted During Compliance Evaluation:

It is the determination of the Section that because of the number of containers on-site identified as holding
abandoned chemicals, which were found to exhibit the characteristic of corrosivity, indicative of a hazardous
waste, constitutes the storage of solid/hazardous waste subject to all applicable requirements of 40 CFR Part
261 through Part 279, incorporated by reference in 15A NCAC 13A .0106 through .0119.

1. 40 CFR 262.11, adopted by reference at lSA NCAC 13A .0107(a), requires that a person who generates a solid
waste, as defined in 40 CFR 261.2, must make an accurate determination as to whether that waste is a
hazardous waste in order to ensure wastes are properly managed according to applicable RCRA regulations.
A hazardous waste determination is made using the following steps:

(a) The hazardous waste determination for each solid waste must be made at the point of waste
generation, before any dilution, mixing, or other alteration of the waste occurs, and at any time in the
course of its management that it has, or may have, changed its properties as a result of exposure to
the environment or other factors that may change the properties of the waste such that the RCRA
classification of the waste may change.

(b) A person must determine whether the solid waste is excluded from regulation under 40 CFR 261.4.
Page 3 of 4

Jeff Menzel– NC Hazardous Waste Section Home Duty Office: P.O. Box117, Black Mountain, NC 28711
Phone: [phone] Email: [e-mail]
http://portal.ncdenr.org/web/wm/hw

(c) If the waste is not excluded under 40 CFR 261.4, the person must then use knowledge of the waste to
determine whether the waste meets any of the listing descriptions under subpart D of 40 CFR part
261. Acceptable knowledge that may be used in making an accurate determination as to whether the
waste is listed may include waste origin, composition, the process producing the waste, feedstock,
and other reliable and relevant information. If the waste is listed, the person may file a delisting
petition under 40 CFR 260.20 and 260.22 to demonstrate to the Administrator that the waste from
this particular site or operation is not a hazardous waste.

(d) The person then must also determine whether the waste exhibits one or more hazardous
characteristics as identified in subpart C of 40 CFR part 261 by following the procedures in paragraph
{d)(l) or (2) of this section, or a combination of both.

(1) The person must apply knowledge of the hazard characteristic of the waste in light of the
materials or the processes used to generate the waste. Acceptable knowledge may include
process knowledge (e.g., information about chemical feedstocks and other inputs to the
production process); knowledge of products, by-products, and intermediates produced by
the manufacturing process; chemical or physical characterization of wastes; information on
the chemical and physical properties of the chemicals used or produced by the process or
otherwise contained in the waste; testing that illustrates the properties of the waste; or other
reliable and relevant information about the properties of the waste or its constituents. A test
other than a test method set forth in subpart C of 40 CFR part 261, or an equivalent test
method approved by the Administrator under 40 CFR 260.21, may be used as part of a
person's knowledge to determine whether a solid waste exhibits a characteristic of
hazardous waste. However, such tests do not, by themselves, provide definitive results.
Persons testing their waste must obtain a representative sample of the waste for the testing,
as defined at 40 CFR 260.10.

(2) When available knowledge is inadequate to make an accurate determination, the person must
test the waste according to the applicable methods set forth in subpart C of 40 CFR part 261
or according to an equivalent method approved by the Administrator under 40 CFR 260.21
and in accordance with the following:

(i) Persons testing their waste must obtain a representative sample of the waste for the
testing, as defined at 40 CFR 260.10.

(ii) Where a test method is specified in subpart C of 40 CFR part 261, the results of the
regulatory test, when properly performed, are definitive for determining the
regulatory status of the waste.

(e) If the waste is determined to be hazardous, the generator must refer to parts 261, 264, 265, 266, 267,
268, and 273 of this chapter for other possible exclusions or restrictions pertaining to management
of the specific waste.

(f) Recordkeeping for small and large quantity generators. A small or large quantity generator must
maintain records supporting its hazardous waste determinations, including records that identify
whether a solid waste is a hazardous waste, as defined by 40 CFR 261.3. Records must be maintained
for at least three years from the date that the waste was last sent to on-site or off-site treatment,
Page 4 of 4

Jeff Menzel– NC Hazardous Waste Section Home Duty Office: P.O. Box117, Black Mountain, NC 28711
Phone: [phone] Email: [e-mail]
http://portal.ncdenr.org/web/wm/hw

storage, or disposal. These records must comprise the generator's knowledge of the waste and
support the generator's determination, as described at paragraphs (c) and (d) of this section. The
records must include, but are not limited to, the following types of information: The results of any
tests, sampling, waste analyses, or other determinations made in accordance with this section;
records documenting the tests, sampling, and analytical methods used to demonstrate the validity
and relevance of such tests; records consulted in order to determine the process by which the waste
was generated, the composition of the waste, and the properties of the waste; and records which
explain the knowledge basis for the generator's determination, as described at paragraph (d)(l) of
this section. The periods of record retention referred to in this section are extended automatically
during the course of any unresolved enforcement action regarding the regulated activity or as
requested by the Administrator.

(g) Identifying hazardous waste numbers for small and large quantity generators. If the waste is
determined to be hazardous, small quantity generators and large quantity generators must identify
all applicable EPA hazardous waste numbers (EPA hazardous waste codes) in subparts C and D of
part 261 of this chapter. Prior to shipping the waste off site, the generator also must mark its
containers with all applicable EPA hazardous waste numbers (EPA hazardous waste codes)
according to § 262.32.

Anderson Family Properties, LLC is in violation of this regulation in that a proper hazardous waste
determination has not been performed for containers of unknown waste materials abandoned on the
property.

2. 15A NCAC 13A .0109(a), requires that any person who treats, stores, or disposes of hazardous waste shall
comply with the requirements set forth in this section. The treatment, storage or disposal of hazardous waste
is prohibited except as provided in 40 CFR Parts 264 and 265, adopted by reference in 15A NCAC 13A .0109
and .0110.

Anderson Family Properties, LLC is in violation of this administrative code in that hazardous waste
has been stored without complying with the requirement to obtain a hazardous waste management
permit as set forth in 40 CFR Parts 264 and 265, adopted by reference in 15A NCAC 13A .0109 and
.0110.

* NOTE: Immediate Action Notice of Violation, Docket #2018-052 was issued for deficiencies listed above.

6/12/2018
______________________________________________________ SENT BY E-MAIL
JEFF MENZEL, / DATE DAN ANDERSON - OWNER
NC HWS-COMPLIANCE BRANCH

cc: Central Office Files
Sean Morris HWS Western Compliance Supervisor

REFERENCE 5
Document Category:
Document Group:
Document Type:
LASERFICHE FILE TRANSMITTAL FORM
DIVISION OF WASTE MANAGEMENT
HAZARDOUS WASTE SECTION
Your Name:
EPA ID:
Facility Name/Subject:
Document Date:
Jeff Menzel
Facility
ENFORCEMENT (E)
Compliance Schedule Evaluation (CSE)
NCS000002196
Anderson Family Properties
02/18/2020
Description:Compliance Schedule Evaluation (CSE) for IANOV 2019-033
Author:Jeff Menzel
Facility/Site Address: 2698 Hickory Blvd.
Facility/Site City: Hudson
Facility/Site Zipcode: 28638
Facility/Site State: North Carolina
Facility/Site County: Caldwell
File Room Use Only
Month Day Year
Date Received
by File Room
Date Scanned
Branch/Unit:Compliance Branch-Western Region
(or Inspection Date)
1 Form Amended 07/27/2017
RCRAINFO DATA ENTRY FORM
HAZARDOUS WASTE SECTION - COMPLIANCE BRANCH
Docket Number: 2019-033
How many violations were there? 2
For Violations:
Enforcement Date: 2/19/2019
Enforcement Type: IANOV
For IANOV or CO: The facility is no longer a SNC (SNN Evaluation)
Violation #1:
Date Determined: 1/25/2019
Scheduled Return to Compliance: 3/19/2019 Actual Return to Compliance: 2/18/2020
Regulation Description: 40 CFR 262.11, adopted by reference at lSA NCAC 13A .0107(a)
Comment: A hazardous waste determination must be made
For CSE, Corrections to Violations were: Observed
Violation #2:
Date Determined: 1/25/2019
Scheduled Return to Compliance: 3/19/2019 Actual Return to Compliance: 2/18/2020
Regulation Description: 15A NCAC 13A .0109(a)
Comment: The treatment, storage or disposal of hazardous waste is prohibited except as provided in 40 CFR Parts
264 and 265, adopted by reference in 15A NCAC 13A .0109 and .0110.
For CSE, Corrections to Violations were: Observed
.
Page 1 of 8

Rose Pruitt– NC Hazardous Waste Section
P.O. Box 651, Rockingham, NC 28380
[e-mail]
http://portal.ncdenr.org/web/wm/hw
NORTH CAROLINA DEPARTMENT OF ENVIRONMENTAL QUALITY
DIVISION OF WASTE MANAGEMENT
HAZARDOUS WASTE SECTION (HWS) / COMPLIANCE BRANCH

1. Facility Information: Anderson Family Properties
2698 Hickory Blvd.
Hudson, NC 28638
Caldwell County
EPA ID#: NCS000002196 and NCR000172924

Remediating Party: Tailored Chemical Products Inc.
700 12th Street NW
Hickory, NC 28601

2. Facility Contact: Jack Temple III, Tailored Chemical Products
Phone: [phone]
Email: [e-mail]
700 12th Street NW
Hickory NC 28601

3. Inspector(s): Jeff Menzel, HWS - Environmental Specialist II
Ken Rhame, EPA

4. Survey Participants: Jeff Menzel HWS
Ken Rhame EPA
Tom Stanek TCP
Gary Sparks STAT

5. Date/Time of Inspection: February 18, 2020 Arrived: 10am Departed: 12pm

Date of Report: March 11, 2022 - Prepared By: Jeff Menzel

6. Purpose of Inspection: Compliance Schedule Evaluation (CSE). To Determine Compliance
with Immediate Action Notice of Violation, Docket # 2018-052 &
Immediate Action Notice of Violation, Docket # 2019-033.

Page 2 of 8

Rose Pruitt– NC Hazardous Waste Section
P.O. Box 651, Rockingham, NC 28380
[e-mail]
http://portal.ncdenr.org/web/wm/hw
7. Report:

This report has been developed to summarize all hazardous waste management deficiencies
discovered at 2698 Hickory Blvd in Hudson, NC. Deficiencies were initially discovered during a
Complaint Investigation (FCI-CMP) conducted on May 11, 2018. The deficiencies were further
defined during multiple Focused Compliance Inspections (FCI) as outlined in this report. An
Immediate Action Notice of Violation, Docket # 2018-052, was issued to Anderson Family
Properties on May 31, 2018 and an Immediate Action Notice of Violation, Docket # 2019-033, was
issued to Tailored Chemical Products on February 19, 2019 for containers of waste abandoned on
the subject property.

Site Summary:

On May 11, 2018, Jeff Menzel the Division of Waste Management, Hazardous Waste Section,
inspected the Anderson Family Properties facility for compliance with North Carolina Hazardous
Waste Management Rules. On May 10, 2018, Tommy Courtner, Hudson Fire Chief, called EPA's
Region 4 National Response Center (NRC) to request that a site investigation be initiated as some
of an estimated 7,000 - 10,000 abandoned 250-gallon totes, stored at 2698 Hickory Blvd. in Hudson,
NC, were found to be leaking. The content of the totes appears to be wastewater generated from
the production of white glue. On May 11, 2018, Mr. Brian Englert, US EPA On-Scene Coordinator,
visited the site in response to the NRC report. Also in attendance were representatives from the
Town of Hudson, Hudson Fire Department, Hudson Police Department, Caldwell County
Emergency Management, STAT Inc., Marlin Chemical and NC DEQ. Also in attendance was Mr. Perry
Keister (former DAFCO, Inc. representative) and Mr. Dan Anderson (site property owner
representative).

The property located at 2698 Hickory Blvd. in Hudson, NC is owned by Anderson Family Properties,
LLC (Anderson Property) and a portion of the property was leased to DAFCO, Inc. in February 2015.
DAFCO's business consisted of fabrication of wastewater treatment systems and the cleaning of
wastewater totes for reuse. It is our understanding that the totes of glue and wastewater, currently
on the Anderson Property, originated from Tailored Chemical Products, Inc., which is based in
Hickory, NC. The totes were provided to DAFCO for cleaning and were then to be returned to
Tailored Chemical for reuse. Information reviewed in 2015 demonstrated that the glue and
wastewater within the totes would not be a hazardous substance or hazardous waste. Being unable
to process the totes received, DAFCO discontinued all operations after completing an Asset
Purchase Agreement with a company called Eco-Tote Container Services, LLC (Eco-Tote) located in
Charlotte, NC. Under this agreement, Eco-Tote was to process the wastewater within the totes and
return cleaned totes to Tailored Chemical. Eco-Tote processed only a small number of totes before
also discontinuing their operations. Neither DAFCO nor Eco-Tote are currently in operation and the
totes were abandoned on the Anderson property.

Page 3 of 8

Rose Pruitt– NC Hazardous Waste Section
P.O. Box 651, Rockingham, NC 28380
[e-mail]
http://portal.ncdenr.org/web/wm/hw
On May 11th, 2018, Mr. Jeff Menzel conducted a site inspection in response to a spill reported by
Caldwell County Emergency Management regarding several leaking totes of wastewater
discovered onsite. In addition, Mr. Jeff Menzel also conducted a site inspection on site on May 23,
2018 in response to another spill reported by Caldwell County Emergency Management, which was
determined to be rainwater that was released from a temporary secondary containment area.
During the site visits, at least twelve (12) 55-gallon containers and at least one (1) 250-gallon tote
containing suspected corrosive liquids were identified and the Section issued an Immediate Action
Notice of Violation, Docket # 2018-052, to Anderson Family Properties on May 31, 2018 requiring
the proper characterization of the suspected hazardous materials, or any other containers holding
unknown waste. In response to the IANOV, the containers of corrosive materials were transferred
to Celadon Recycling Solutions in Lincolnton, NC for reuse as a wastewater treatment product.

On August 2, 2018, the NC Solid Waste Section (SWS) issued a Notice of Violation (SWS NOV) to
both Anderson Family Properties and Tailored Chemical. The SWS NOV required an assessment
and inventory of the contents of the containers identified as holding glue and wastewater industrial
process waste abandoned on the property and specified that a plan of action would need to be
approved prior to waste removal from the site. A tote sampling plan of action was submitted to
the SWS by Tailored Chemical on September 6, 2018 but the plan did not adequately address the
requirements of the SWS NOV in that the proposed tote sampling protocol was insufficient and did
not fully detail the proper characterization and tote management procedures needed for the
removal of waste from the site.

On January 24, 2019, the SWS received laboratory analytical data from Tailored Chemical for one
composite sample of glue and wastewater collected on December 19, 2018 by Mr. Jack Temple, Ill.
The composite sample was collected from approximately 20 totes at the Anderson Property and
was analyzed for RCRA characteristic constituents. The analytical data for the sample identified the
presence of Tetrachloroethene (PCE) at 2.07 mg/I, which exceeds the RCRA regulatory level of 0.7
mg/l and indicates the containers of wastewater represented by the sample are a characteristic
hazardous waste (EPA Waste Code: D039).

On January 25, 2019, Mr. Richard Concepcion with the Section, conducted a site visit at the
Anderson Family Properties in Hudson to observe overall site conditions and to see if the totes
were being processed or moved from the property. Mr. Concepcion reported that there did not
appear to be any change in site conditions or number of totes present.

On January 30, 2019 Mr. Sean Morris, with the Section, submitted an email to Mr. Dan Anderson
and Mr. Jack Temple, Ill notifying both parties that the analytical data for the 20 totes of glue and
wastewater indicates that the waste is a D039 characteristic hazardous waste. Mr. Morris also
explained that because of the discovery of characteristic hazardous waste onsite, a hazardous
waste characterization and sampling plan for the totes must be submitted and approved by the
Section prior to initiating any further waste characterization activities at the site. Mr. Morris also
Page 4 of 8

Rose Pruitt– NC Hazardous Waste Section
P.O. Box 651, Rockingham, NC 28380
[e-mail]
http://portal.ncdenr.org/web/wm/hw
explained that the totes holding D039 hazardous wastewater must be immediately labeled as
hazardous waste, marked with an accumulation start date and must be sent to a proper RCRA
permitted treatment, storage & disposal facility within 90-days. In addition, Mr. Morris explained
that the facility must obtain an EPA Identification Number and comply with all applicable large
quantity generator regulations in 40 CFR 262.17 (e.g. RCRA training, emergency preparedness and
container management requirements) before any additional wastewater assessment work is
performed at the site.

On February 19, 2019, The HWS issued Immediate Action Notice of Violation, Docket # 2019-033,
to Tailored Chemical for failure to make proper waste determinations and for storing hazardous
waste without a permit. Within 30-days of receiving the IANOV the facility was required to submit
a sampling plan. On March 13, 2019 the attorney for Tailored Chemical submitted a sampling plan
letter that was found to be inadequate. One March 20, 2019 the HWS submitted an email to
Tailored Chemical’s attorney that included general guidance for components of an acceptable
sampling plan, and included an example sampling plan provided by EPA-ERRB. On March 22, 2019,
the attorney for Tailored Chemical submitted a letter indicating their willingness to comply with
the IANOV, this was to include a sampling plan which they agreed to submit by April 2, 2019. On
April 2, 2019 the attorney for Tailored Chemical submitted a revised sampling plan letter that was
reviewed by HWS staff & EPA-ERRB staff. The revised sampling plan was also determined to be
inadequate.

On April 4, 2019, U.S. EPA requested a meeting with parties involved with the DAFCO Totes Site
located at 2698 Hickory Blvd. Hudson. The meeting was held to discuss a path forward to conduct
an emergency response action to stabilize the site. The response action will address containers
(chemical totes) that have been compromised due to the length of time being exposed to the
elements (temperature swings) and exposure to sunlight. Some totes were open topped full of
liquids exposed to the weather (rain), some totes were cracked, some totes had rags stuffed in the
valve ports, some totes were bulging/collapsed, some of the totes were observed leaking. Due to
the sample results collected by Tailored Chemical indicating the presence of perchloroethylene
(PCE), the proximity of the leaking totes to a stream and residential properties; EPA requested that
the Potential Responsible Parties (PRPs) initiate the emergency response to transfer material from
the compromised containers into a stable containment system. Tailored Chemical had concerns
regarding the ability to arrange delivery of totes to the site in the time frame being discussed. EPA
explained that a frac-tank could be rented from an Environmental contractor, material could be
haz-catted for compatibility, and screened for VOCs to segregate and bulk the waste. The bulk
waste would then need to be properly characterized for disposal. The PRPs agreed to hire STAT
Environmental to conduct the site stabilization action. The stabilization action begun on April 6,
2019.

Page 5 of 8

Rose Pruitt– NC Hazardous Waste Section
P.O. Box 651, Rockingham, NC 28380
[e-mail]
http://portal.ncdenr.org/web/wm/hw

Investigation History:

On February 25, 2019, Richard Concepcion, HWS Western Chemist, conducted an unannounced
Compliance Development Inspection at Anderson Family Properties located in Hudson, NC
(Caldwell County) to observe overall site conditions and if the totes were being processed or moved
from the property. During this site visit it could be determined that it have not been any changes
in site conditions or number of totes present.

On March 6, 2019, Richard Concepcion conducted an unannounced Compliance Development
Inspection at Anderson Family Properties located in Hudson, NC (Caldwell County) to observe
overall site conditions and if a tree that was reported to have fallen on totes has not caused any
rupture of totes which would have released to the environment. During this site visit it could be
determined that it have not been any disturbance to totes condition related with the fallen tree or
any other conditions.

On April 4, 2019, Jeff Menzel conducted an announced Compliance Development Inspection at
Anderson Family Properties located in Hudson, NC (Caldwell County) to observe overall site
conditions. U.S. EPA received a request to conduct a Removal Site Evaluation (RSE) at the DAFCO
Abandoned Tote Site located at 2698 Hickory Blvd, Hudson, Caldwell County, North Carolina on
April 3, 2019. Arriving on-site, OSC Ken Rhame found approximately 9,000 totes and observed
many of the totes in poor condition, compromised by prolonged exposure to the elements with
some leaking. During efforts by the current property owner and the North Carolina Department of
Environmental Quality (NC DEQ) to compel a removal of the totes by Tailored Chemical; Tailored
Chemical collected a composite sample of 20 chemical totes. Analytical results indicated the
presence of perchloroethylene (PCE) at concentrations exceeding the threshold for hazardous
waste. Due to these results, the condition of the totes, the proximity to a stream and residential
properties; OSC Rhame directed the responsible party to begin transfer operations of the
compromised totes to a stable containment system.

The property owner and Tailored Chemical hired a contractor (STAT Environmental) to conduct the
emergency response action to stabilize the Site. The contractor mobilized and began work on April
6, 2019 and began conducting site stabilization activities while collecting and transferring
approximately 20,000 gallons of the material into frac-tanks. Due to rains being forecast for the
next reporting period, response crews will focus on processing (solidifying) sludge inside the facility
to make room for more compromised totes. Once the material has been transferred from the
compromised totes to a stable containment system, the material will be sampled for waste
determination and properly transported and disposed.

Page 6 of 8

Rose Pruitt– NC Hazardous Waste Section
P.O. Box 651, Rockingham, NC 28380
[e-mail]
http://portal.ncdenr.org/web/wm/hw
On April 9, 2019, Jeff Menzel conducted an unannounced Compliance Development Inspection at
Anderson Family Properties located in Hudson, NC (Caldwell County) to observe overall site
conditions and if the totes were being processed or moved from the property.

On April 24, 2019, Jeff Menzel conducted an unannounced Compliance Development Inspection
at Anderson Family Properties located in Hudson, NC (Caldwell County) to observe overall site
conditions. Tailored Chemical raised concerns about the empty totes as well as sludge in the
bottom of the totes. EPA explained that “RCRA Empty” Totes would need to be manifested and
disposed of properly. EPA also explained that the sludge could be bulked in roll-off boxes and
further solidified if necessary, and then characterized for disposal. The metal cages could be
relinquished to Tailored Chemical for reuse.

On April 30, 2019, Jeff Menzel conducted an unannounced Compliance Development Inspection
at Anderson Family Properties located in Hudson, NC (Caldwell County) to observe overall site
conditions. Work has begun to process the liquids and solids in the totes. As a precautionary
measure for the surrounding community efforts are being made monitor air quality in the work
area and to identify private residencies which may be on private wells.

On May 14, 2019, Jeff Menzel conducted an unannounced Compliance Development Inspection at
Anderson Family Properties located in Hudson, NC (Caldwell County) to observe overall site
conditions. Work has begun to process the liquids and solids in the totes. As a precautionary
measure for the surrounding community efforts are being made monitor air quality in the work
area and to identify private residencies which may be on private wells. Liquid waste is being put
into frac tanks and solidified sludge is composited and TCLP sampled for the presence of
Perchloroethylene.

On May 29, 2019, Jeff Menzel conducted an unannounced Compliance Development Inspection at
Anderson Family Properties located in Hudson, NC (Caldwell County) to observe overall site
conditions. Work has begun to process the liquids and solids in the totes. As a precautionary
measure for the surrounding community efforts are being made monitor air quality in the work
area and to identify private residencies which may be on private wells. Liquid waste is being put
into frac tanks and solidified sludge is composited in a roll-off container. The composited waste is
TCLP sampled for the presence of Perchloroethylene. Estimated waste shipments for this week are
as follows;
20 loads (23 tons per load) to Giant by end of week as hazardous waste.
4 frac tanks (80,000 gallons) to Shamrock to date as non- hazardous waste.
42,000 gallons to Clean Earth as hazardous waste.

On June 17, 2019, Jeff Menzel conducted an unannounced Compliance Development Inspection at
Anderson Family Properties located in Hudson, NC (Caldwell County) to observe overall site
conditions. Work has begun to process the liquids and solids in the totes. Liquid waste is being put
Page 7 of 8

Rose Pruitt– NC Hazardous Waste Section
P.O. Box 651, Rockingham, NC 28380
[e-mail]
http://portal.ncdenr.org/web/wm/hw
into frac tanks and solidified sludge is composited in a roll-off container. The composited waste is
TCLP sampled for the presence of Perchloroethylene. Approximately 2500 totes have been
processed and estimated waste shipments to date are as follows;
431 tons to Giant as hazardous waste solids.
46 tons to US Ecology as hazardous waste solids.
71500 gallons to Shamrock to as non- hazardous waste liquid.
151,000 gallons to Dart in Charlotte, NC as hazardous waste.

On August 8, 2019, Jeff Menzel conducted an unannounced Compliance Development Inspection
at Anderson Family Properties located in Hudson, NC (Caldwell County) to observe overall site
conditions. Work has begun to process the liquids and solids in the totes. Liquid waste is being put
into frac tanks and solidified sludge is composited in a roll-off container. The composited waste is
TCLP sampled for the presence of Perchloroethylene. Approximately 3500 totes have been
processed.

On September 5, 2019, Jeff Menzel conducted an unannounced Compliance Development
Inspection at Anderson Family Properties located in Hudson, NC (Caldwell County) to observe
overall site conditions. Work has begun to process the liquids and solids in the totes. Liquid waste
is being put into frac tanks and solidified sludge is composited in a roll-off container. The
composited waste is TCLP sampled for the presence of Perchloroethylene.
Approximately 4500 totes have been processed and estimated waste shipments to date are as
follows;
960 tons to Giant as hazardous waste solids.
940 tons to US Ecology as hazardous waste solids.
361,000 gallons to Shamrock to as non- hazardous waste
liquid. 487,000 gallons to Dart in Charlotte, NC as hazardous
waste.

On October 9, 2019, Jeff Menzel conducted an unannounced Compliance Development Inspection
at Anderson Family Properties located in Hudson, NC (Caldwell County) to observe overall site
conditions. Work has begun to process the liquids and solids in the totes. Liquid waste is being put
into frac tanks and solidified sludge is composited in a roll-off container. The composited waste is
TCLP sampled for the presence of Perchloroethylene. Estimated waste shipments to date are as
follows;
1121 tons to Giant as hazardous waste solids.
1584 tons to US Ecology as hazardous waste solids.
531,000 gallons to Shamrock to as non- hazardous waste liquid.
667,000 gallons to Dart in Charlotte, NC as hazardous waste.

On November 6, 2019, Jeff Menzel conducted an unannounced Compliance Development
Inspection at Anderson Family Properties located in Hudson, NC (Caldwell County) to observe
Page 8 of 8

Rose Pruitt– NC Hazardous Waste Section
P.O. Box 651, Rockingham, NC 28380
[e-mail]
http://portal.ncdenr.org/web/wm/hw
overall site conditions. Work has begun to process the liquids and solids in the totes. Liquid waste
is being put into frac tanks and solidified sludge is composited in a roll-off container. The
composited waste is TCLP sampled for the presence of Perchloroethylene.

On February 18, 2020, Jeff Menzel conducted an announced Compliance Schedule Evaluation at
Anderson Family Properties located in Hudson, NC (Caldwell County) to observe overall site
conditions in coordination with Ken Rhame with EPA, Tom Stanek with Tailored Chemicals, Gary
Sparks with Stat Inc. and Steve Lucas with Lighthouse Consultants. The area utilized for processing
the totes and waste, the eastern portion of the property near the maintenance building, was
walked including the inside of the maintenance building. No glue waste water totes were observed
remaining on site. Several empty totes were present inside the building and TCP and STAT indicated
the totes previously held waste oil.

Tailored Chemical Products submitted a final report in April 2020, as required by EPA’s
Administrative Settlement, Agreement and Order On Consent for A Removal Action, CERCLA
Docket No. 04-2019-9998, which summarized handling and disposal activities completed at the
site. The removal action resulted in the generation and off-site disposal of the following waste
streams:
1144 tons to Giant as hazardous waste solids.
2412 tons Hazardous Waste solids shipped to US Ecology Detroit, MI
685,000 gallons to Dart in Charlotte, NC as hazardous waste liquids.
455,000 Hazardous Waste Liquids shipped to US Ecology Detroit, MI
591,000 gallons to Shamrock to as non- hazardous waste liquid.

The violations cited in Immediate Action Notice of Violation, Docket # 2018-052, issued to
Anderson Family Properties, and Immediate Action Notice of Violation, Docket # 2019-033, issued
to Tailored Chemical Products have been corrected.

JEFF MENZEL 3/11/22 FACILITY CONTACT
NC HWS – COMPLIANCE BRANCH

Cc: Sean Morris, NCDEQ-HWS
Ken Rhame, EPA Region 4
Jeff Menzel, NCDEQ-HWS
Richard Concepcion, NCDEQ-HW
Raleigh Central Files

REFERENCE 6
Final Report
April 21, 2020
Dafco Tote Site
2698 Hickory Boulevard
I-IUClson, North Carolina
Prepared By:
Tailored Chemical Products
1120 "Tate Boulevard SE
Hickory, North Carolina 28602
Report Certification: I certify render penalty of law that this document and all attachments were
prepared under my direction or supervision in accordance with a system designed to assure that
qualified personnel properly gather and evaluate the information submitted. Based on my inquiry
of the person or persons who manage the system, or those persons directly responsible for
gathering the information, the information submitted is, to the best of my knowledge and belief,
rue, accurate, and complete. I have no personal knowledge that the information submitted is
other than true, accurate, and complete. I am aware that there are significant penalties for
submitting false information, including the possibility of fine and imprisonment for knowing
violations.
TABLE OF CONTENTS
1.0 INTRODUC"I'ION.......................................................................................................................1
2.0 SCOPE OF WORK......................................................................................................................2
3.0 PROCEDURES FOR TOTE CONTAINER LIQUID.................................................................2
3.1 Pumping, Storage and .Testing.......................................................................................2
3.2 Treatment of Liquid........................................................................................
4..............2
3.3 Liquid Disposal....................................................................................................
4.........3
3.3.1 Non Hazardous Liquid Disposal........................................................................3
3.3.2 Hazardous Liquid Disposal.................................4............................3
3.3.3 Liquid Disposal Documeutation......................................................3
4.0 PROCEDURES FOR TOTE, CONTAINER SOLIDS................................................4.....4.........3
4.1 Solidification'... ....... 4.11.11,111,11, ................. w .. .. . .. . o t 4 . . . . . . . .3
4.2 Disposal............................................................................................
4............................4
5.0 SITE AIR MONITORING...............................................................................................
4.4........4
G.0 2020 N AS"TI; DISPOSAL._..............................................................................4
TO FINAL SITE WALK..................................................................
4....................45
FIGURES
Figure 1: Site Location
Figure 2: Site Map
APPENDICES
Appendix A-Dafco Tote Site Work Plan
Appendix B-Field Sampling and Analysis Plan
Appendix C-Liquid and Solid Disposal Documentation
Appendix D-Disposal Documentation for the Empty Totes
Appendix E-Daily Air Monitoring Site Forms
Appendix F-2020 Waste Documents
1
1.0
On behalf of Tailored Chemical Products, Inc. ("TCP"), Lighthouse Technical, PC ("Lighthouse"),
pursuant to Paragraph 23 of the ADMINISTRATIVE SETTLEMENT AGREEMENT AND ORDER ON
CONSENT FOR A REMOVAL ACTION, CERCLA DOCKET No, 04-20194998, IN THE MATTER OF
DAFCO Tote Site, 2698 Hickory Boulevard, Hudson, North Carolina 28638, Tailored Chemical Products,
Inc.,, Respondent, is submitting this final report summarizing the activities associated with the handling
and disposal of the material in wastewater totes stored at the DAFCO Tote Site (Site) in Hudson, Caldwell
County, North Carolina.
The Site address is 2698 Hickory Boulevard, Hudson, North Carolina. The property is approximately 25
acres in size and is owned by Anderson Family Properties, LLC ("Anderson Family"). There is a 65,000
square foot aluminum building with garage bays and loading docks on the property. A structure near the
rear of the Site was used for maintenance of trucks. Underground storage tanks ("UST's") were formerly
located on the Site. An approximately 10,000 gallon above ground storage tank is still on the Site. No
liquids were stored in the AST. The top of the AST has been removed, and a valve on the bottom of the
AST is open. There is a storm water conveyance system on the Site. An intermittent stream flows near the
Site border. The Site has an entrance gate; however, there has been a history of trespassing and burglaries
at the Site.
Anderson Family leased the Site to Anderson Trucking Line, a related company, from 1995 until 2009.
Anderson Trucking used the Site as a trucking and distribution facility until 2009. Part of the facility is still
used as a trucking and distribution facility.
In 2015, Anderson leased a portion of the Site to DAFCO, a North Carolina corporation. DAFCO
fabricated wastewater treatment systems and treated and cleaned wastewater totes for reuse. DAFCO
advertised that it was capable of treating wastewater such that the wastewater could be discharged into
municipal sewer systems.
DAFCO was paid by TCP to treat and clean waste water totes that were delivered to the site. DAFCO
originally operated at a location on Virginia Avenue in Lenoir, North Carolina owned by Kiser Sawmills.
DAFCO failed to pay rent due to Kiser. As a result, from early 2015 until February 2016, Kiser Sawmills
moved approximately 9000 totes, each containing approximately 275 gallons of wastewater, from Virginia
Avenue in Lenoir to the Site.
In 2016, DAFCO sold its assets to Eco-Tote Container Services, LLC (Eco-Tote). Eco-Tote took over
DAFCO's operations on the Site for a short period of time before discontinuing its operations. Both
DAFCO and Eco-Tote have since been administratively dissolved. DAFCO and Eco-Tote abandoned the
Site leaving approximately 9000 untreated wastewater totes on the Site.
On May 31, 2018, the North Carolina Department of Environmental Quality DEQ") issued. a Notice of
Violation ("NOV") to Anderson Family and TCP. The NOV alleged that there were violations of the
Resource Conservation and Recovery Act ("RCRA") and required Anderson Family and TCP to submit a
plan to sample and analyze the contents of the totes. TCP submitted a sampling plan to DEQ in September,
2018. Sampling in January, 2019 indicated the presence of teu•achloroethene at 2.07 mg/I, exceeding the
RCRA regulatory level of 0.7 mg/I for Toxicity Characteristic,
On April 3`d, 2019, DEQ referred the Site to Region 4 of EPA. On April 5'", 2019, Anderson Family and
TCP hired STAT Inc. and began the process of bulking and sampling the material in the wastewater totes.
On May 3`d, 20195 TCP signed the AOC. EPA signed the AOC on May 24", 2019. Anderson Family
refused to sign the AOC, and has not participated in any work on the Site since April, 2019.
TCP completed operations on the Site in March, 2020. The actions of TCP and its contractors on the Site
are detailed in this report and its appendices.
The AOC required the waste water to be evaluated for hazardous constituents and disposed of accordingly.
TCP developed a "Dafco Tote Site Work Plan" for site activities which was submitted to the EPA for
review and approval. Appendix A includes a copy.
TCP contracted with STAT, Inc. of Lenoir, North Carolina to prepare and dispose of the liquid and solid
material removed from each tote as well as the plastic totes and metal frames. Since the totes contained
varying amounts of water and glue product, three waste streams were produced: water decanted from each
tote, solids and the empty plastic and metal containers. The primary chemical of concern was
tetracloroethene (PCE). Approximately 90 totes were determined to contain unknown non glue related
liquids. STAT also assisted with disposal of several miscellaneous wastes through lab packs.
TCP also contracted with Lighthouse Technical ("Lighthouse") to record Site weather conditions daily and
to monitor air quality at the property boundaries and near the work zones. Lighthouse also assisted
TCP/STAT with sampling of the liquid and solids from the totes as requested. A Field Sampling and
Analysis Plan (FSAP) were developed and are included as Appendix B.
3A PROCEDURES FOR TOTE CONTAINER LIQUID
The following procedures were used in removing liquids from each tote, testing and evaluating the liquids
and final disposal.
3_I Pumping, Storage and Testing
After preliminarily screening each tote for volatiles using a photoionization detector (PID), STAT
began collecting free liquid fiom each tote using a vacuum buck. Totes with higher PID readings
were segregated for further evaluation while totes with lover PID readings were handled first.
Liquids were transferred to frac tanks staged on site. Once a frac tank was full, a sample was
collected and submitted for analysis by EPA Method 8260.
3_2 Treatment of Liquid
TCP evaluated the results 0f the Method 82G0 analysis for volatile compounds. If compound
3
levels were detected above the hazardous material regulatory standard, TCP worked with STAT
adding polymers and pH adjustment chemicals to help separate the suspended solids in the liquid.
Subsequent testing was conducted to further determine the volatile chemical concentrations and
thus a disposal route for the liquid.
33 Liquid Disposal
3.3.1 Non Hazardous Liquids Disposal - Once the laboratory analytical results
determined the liquids stored in a given frac tank were nonhazardous, STAT transferred
the liquid to tankers for transport and disposal at Shamrock Environmental Corporation
Shamrock") in Browns Summit, North Carolina,
3.3.2 Hazardous Liquids Disposal -Liquids that were determined to be hazardous by
laboratory analysis were transported to three facilities;
Dart
4132 Pompano Drive
Charlotte, North Carolina 28216
EQ Detroit Inc.
1923 Frederick
Detroit, Michigan 48211
Giant Resource Recovery
654 Judge Street
Harleyville, South Carolina 28448
Giant Resource Recovery -Sumter
755 hrduStrlal Road
Sumter, South Carolina 29150
3.3.3 Liquid Disposal Documentation -The tanks staged on site were filled with liquid
numerous times and tested with laboratory analysis. Disposal was handled by pumping the
liquid into tankers for transport to the facilities identified above according to the waste
classification. Each full frac tank held enough liquid to fill four to five tankers. Appendix
C includes folders designated by frac tank number. Within each folder there are analytical
results and manifests for each tanker filled with liquid from that frac tank. Over the course
of handling liquids at the site, each frac tank was filled and emptied several times.
4.0 PROCEDURES FOR TOTE CONTAINER SOLIDS
The following procedures were used in handling solid material after removing liquids from each tote.
4.1 Solidification
After each tote was opened and the liquids removed, the solids were emptied into roll off boxes
where sawdust and the solidification agent Zappa Sorb, was added. Once the material was
solidified, it was loaded onto dump tricks for transport. The remaining plastic and steel cages
were either recycled or disposed as scrap plastic and metal.
4_2 Disposal of Solids
All tote container solidified solids were considered to be hazardous thus no testing was
performed. The solidified material was transported to three facilities:
Michigan Disposal as Treatment
49350 North I-94 Service Drive
Belleville, Michigan, 48111
EQ Detroit Inc.
1923 Frederick
Detroit, Michigan 48211
Giant Resource Recovery
654 Judge Sheet
Harleyville, South Carolina 28448
Giant Resource Recovery -Sumter
755 Industrial Road
Sumter, South Carolina 29150
43 Solid Disposal Documentation - Appendix C also includes the waste disposal manifests for the
hazardous solids. Appendix D includes the disposal documentation for the empty totes (plastic
and metal cages).
5.0 SITE AIR MONITORING
Lighthouse maintained a weather station on site that provided data including wind direction, speed and
temperature. At the beginning of each day, Lighthouse recorded the wind direction, speed and temperature.
This information was recorded at intervals during the work day which averaged 10 to 11 hours.
In addition to recording weather conditions, Lighthouse used a Honeywell PPB-RAE photoionization
detector (PPB meter) to monitor volatile organic compounds in the ambient air upwind and downwind at
the property boundaries. The PPB meter readings were also collected at the property borders 90 and 180
degrees of the upwind and downwind transect. The PPB meter was capable of measuring volatile organic
compounds in parts per billion. The meter was calibrated each day using isobutylene (50 ppm) as a
standard. hi general, daily ambient air readings at the property boundaries ranged from 0 to .I parts per
billion. Appendix E includes copies of the daily technician forms which document site conditions and the
readings collected.
6_0 2020 FINAL WASTE DISPOSAL.
Approximately 90 totes were segregated during the process described above due to low PID readings and
the physical appearance of the liquids. The material in these 90 totes did not resemble the waste water
stored in the majority of the totes. In some cases, the label on the totes indicated the tote originated from
another source. The liquids from these totes were tested by laboratory analysis and determined to be non
5
hazardous. The liquids were removed and taken to Shamrock Environmental Corporation in Browns
Summit, North Carolina for disposal. Appendix F includes the waste disposal documents and laboratory
analysis for this material.
There were also other materials discovered in the maintenance building that required lab pack disposal by
STAT. The disposal documents for these materials are also included in Appendix F.
7.0 FINAL SITI; WALK
On February 18, 2020 a meeting and site walk was held at the Dafco property. Those iu attendance
included Ken Rhame (EPA), Jeff Menzel (NCDEQ), Tom Stanek (TCP), Gary Sparks (STAT) and Steve
Lucas (Lighthouse).
The area utilized for processing the totes and waste; eastern portion of the property near the maintenance
building; was walked including the inside of the maintenance building. No glue waste water totes were
observed remaining on site. Several empty totes were present inside the building however TCP and STAT
indicated the totes held waste oil at one time. Each tote was now empty. All in attendance agreed the site
waste, addressed by the AOC, had been removed.

REFERENCE 7
SITE
REFERENCE 8
SITE
SITE
SITE
REFERENCE 9
SITE
SITE
REFERENCE 10
REFERENCE 11
REFERENCE 12
SITE+
REFERENCE 13
1981-2010 Normals | Data Tools | Climate Data Online (CDO) | National Climatic Data Center...https://www.ncdc.noaa.gov/cdo-web/datatools/normals1 of 21/31/2022, 2:45 PM
1981-2010 Normals | Data Tools | Climate Data Online (CDO) | National Climatic Data Center...https://www.ncdc.noaa.gov/cdo-web/datatools/normals2 of 21/31/2022, 2:45 PM
REFERENCE 14
REFERENCE 15
From:Erika Leonhardt
To:Parker, Stuart
Subject:[External] RE: Water service account inquiries
Date:Monday, January 3, 2022 11:12:47 AM
Attachments:image002.jpg
CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an
attachment to Report Spam.
Hi,
I have looked at each property and this is what I have come up with:
111 Family Tree Ln: Water and Sewer Service – 119 and 121 look to be owned by the same personas 111 so, I don’t know if there’s just one meter for all addresses or not.
109 Maple Lynn Pl – Water service
120 Maple Lynn Pl – No water or sewer service
3924 Coy Hartley Ln: Water service3929 Coy Hartley Ln: Water service
3925 Coy Hartley Ln: No water or sewer service
I hope this information helps!
Erika Leonhardt
Information Clerk
City Of Lenoir
828-757-2200
[e-mail]
From: Parker, Stuart [mailto:[e-mail]] Sent: Monday, January 3, 2022 10:45 AMTo: [e-mail]: Water service account inquiriesImportance: High
Hello:
I am performing an EPA-funded environmental assessment at a commercial/industrial facility in
Hudson, NC.
Caldwell County GIS indicates that most of the surrounding residential neighborhoods are connected
to Lenoir municipal water.
However, certain properties are outside Hudson municipal boundaries, and the GIS waterline layer
does not appear at those locations.
I would like to know whether these properties have water accounts, so I can determine whether to
request access to sample any private domestic wells that might operate there.
The Properties are:
111, 119 and 121 Family Tree Lane;
109 and 120 Maple Lynn Place;
3924, 3925, 3929 Coy Hartley Lane
Your assistance would be greatly appreciated.
Sincerely,
Stuart F Parker
Hydrogeologist, Division of Waste Management
Superfund Section, Federal Remediation Branch,
NC Dept. of Environmental Quality
[phone] (Office) [phone] Mobile
[e-mail]
REFERENCE 16
REFERENCE 17
REFERENCE 18
REFERENCE 19
Output generated 05AUG2022:17:31:55
Commercial Air Inputs 1
Variable
Commercial
Air
Default
Value
Site-Specific
Value
AFgw (Attenuation Factor Groundwater) unitless 0.001 0.001
AFss (Attenuation Factor Sub-Slab) unitless 0.03 0.03
ATw (averaging time - composite worker)365 365
EDw (exposure duration - composite worker) yr 25 25
EFw (exposure frequency - composite worker) day/yr 250 250
ETw (exposure time - composite worker) hr 8 8
THQ (target hazard quotient) unitless 0.1 1
LT (lifetime) yr 70 70
TR (target risk) unitless 1.0E-06 1.0E-04
Output generated 05AUG2022:17:31:55
Commercial Vapor Intrusion Screening Levels (VISL)2
Key: I = IRIS; P = PPRTV; O = OPP; A = ATSDR; C = Cal EPA; X = PPRTV Screening Level; H = HEAST; D = DWSHA; W = TEF applied; E = RPF applied;
U = user provided; G = see RSL User's Guide Section 5; CA = cancer; NC = noncancer.
Chemical
CAS
Number
Does the
chemical
meet
the
definition
for
volatility?
(HLC>1E-5
or VP>1)
Does the
chemical
have
inhalation
toxicity
data?
(IUR
and/or
RfC)
Is Chemical
Sufficiently
Volatile and Toxic
to
Pose Inhalation
Risk
Via Vapor
Intrusion
from Soil
Source?
(Cvp > Ci,a,Target?)
Is Chemical
Sufficiently
Volatile and Toxic
to
Pose Inhalation
Risk
Via Vapor
Intrusion from
Groundwater
Source?
(Chc > Ci,a,Target?)
Target
Indoor Air
Concentration
(TCR=0.0001
or THQ=1)
MIN(Cia,c,Cia,nc)
(µg/m3)
Toxicity
Basis
Target
Sub-Slab and
Near-source
Soil Gas
Concentration
(TCR=0.0001
or THQ=1)
Csg,Target
(µg/m3)
Target
Groundwater
Concentration
(TCR=0.0001
or THQ=1)
Cgw,Target
(µg/L)
Benzene 71-43-2 Yes Yes Yes Yes 1.31E+02 NC 4.38E+03 5.79E+02
Chloroform 67-66-3 Yes Yes Yes Yes 5.33E+01 CA 1.78E+03 3.55E+02
Dichloroethane, 1,1-75-34-3 Yes Yes Yes Yes 7.67E+02 CA 2.56E+04 3.34E+03
Dichloroethane, 1,2-107-06-2 Yes Yes Yes Yes 3.07E+01 NC 1.02E+03 6.36E+02
Dichloroethylene, 1,1-75-35-4 Yes Yes Yes Yes 8.76E+02 NC 2.92E+04 8.21E+02
Dichloroethylene, cis-1,2-156-59-2 Yes No No Inhal. Tox. Info No Inhal. Tox. Info ---
Dichloroethylene, trans-1,2-156-60-5 Yes Yes Yes Yes 1.75E+02 NC 5.84E+03 4.57E+02
Tetrachloroethylene 127-18-4 Yes Yes Yes Yes 1.75E+02 NC 5.84E+03 2.42E+02
Toluene 108-88-3 Yes Yes Yes Yes 2.19E+04 NC 7.30E+05 8.07E+04
Trichloroethane, 1,1,1-71-55-6 Yes Yes Yes Yes 2.19E+04 NC 7.30E+05 3.11E+04
Trichloroethane, 1,1,2-79-00-5 Yes Yes Yes Yes 8.76E-01 NC 2.92E+01 2.60E+01
Trichloroethylene 79-01-6 Yes Yes Yes Yes 8.76E+00 NC 2.92E+02 2.18E+01
Vinyl Chloride 75-01-4 Yes Yes Yes Yes 2.79E+02 CA 9.29E+03 2.45E+02
Output generated 05AUG2022:17:31:55
Commercial Vapor Intrusion Screening Levels (VISL)3
Key: I = IRIS; P = PPRTV; O = OPP; A = ATSDR; C = Cal EPA; X = PPRTV Screening Level; H = HEAST; D = DWSHA; W = TEF applied; E = RPF applied;
U = user provided; G = see RSL User's Guide Section 5; CA = cancer; NC = noncancer.
Is Target
Groundwater
Concentration
< MCL?
(Cgw < MCL?)
Pure Phase
Vapor
Concentration
Cvp\
(25 ℃)\
(µg/m3)
Maximum
Groundwater
Vapor
Concentration
Chc\
(µg/m3)
Temperature
for Maximum
Groundwater
Vapor
Concentration
(℃)
Lower
Explosive
Limit
LEL
(%
by
volume)
LEL
Ref
IUR
(ug/m3)-1
IUR
Ref
RfC
(mg/m 3)
RfC
Ref
Mutagenic
Indicator
Carcinogenic
VISL
TCR=0.0001
Cia,c(µg/m3)
Noncarcinogenic
VISL
THQ=1
Cia,nc(µg/m3)
No (5)3.98E+08 4.06E+08 25 1.20 U 7.80E-06 U 3.00E-02 U No 1.57E+02 1.31E+02
No (80)1.26E+09 1.19E+09 25 -2.30E-05 U 9.77E-02 U No 5.33E+01 4.28E+02
--1.21E+09 1.16E+09 25 5.40 U 1.60E-06 U -No 7.67E+02 -
No (5)4.20E+08 4.15E+08 25 6.20 U 2.60E-05 U 7.00E-03 U No 4.72E+01 3.07E+01
No (7)3.13E+09 2.58E+09 25 6.50 U -2.00E-01 U No -8.76E+02
1.04E+09 1.07E+09 25 3.00 U --No --
No (100)1.73E+09 1.73E+09 25 6.00 U -4.00E-02 U No -1.75E+02
No (5)1.65E+08 1.49E+08 25 -2.60E-07 U 4.00E-02 U No 4.72E+03 1.75E+02
No (1000)1.41E+08 1.43E+08 25 1.10 U -5.00E+00 U No -2.19E+04
No (200)8.90E+08 9.07E+08 25 8.00 U -5.00E+00 U No -2.19E+04
No (5)1.65E+08 1.55E+08 25 6.00 U 1.60E-05 U 2.00E-04 U No 7.67E+01 8.76E-01
No (5)4.88E+08 5.15E+08 25 8.00 U 4.10E-06 U 2.00E-03 U Mut 2.99E+02 8.76E+00
No (2)1.00E+10 1.00E+10 25 3.60 U 4.40E-06 U 8.00E-02 U Mut 2.79E+02 3.50E+02
Output generated 05AUG2022:17:31:55
Chemical Properties 4
Chemical
CAS
Number
Does the
chemical
meet
the
definition
for
volatility?
(HLC>1E-5
or VP>1)
Does the
chemical
have
inhalation
toxicity
data?
(IUR
and/or
RfC)MW
MW
Ref
Vapor
Pressure
VP
(mm Hg)
VP
Ref
S
(mg/L)
S
Ref
MCL
(ug/L)
Benzene 71-43-2 Yes Yes 78.12 U 9.48E+01 U 1.79E+03 U 5
Chloroform 67-66-3 Yes Yes 119.38 U 1.97E+02 U 7.95E+03 U 80
Dichloroethane, 1,1-75-34-3 Yes Yes 98.96 U 2.27E+02 U 5.04E+03 U -
Dichloroethane, 1,2-107-06-2 Yes Yes 98.96 U 7.89E+01 U 8.60E+03 U 5
Dichloroethylene, 1,1-75-35-4 Yes Yes 96.94 U 6.00E+02 U 2.42E+03 U 7
Dichloroethylene, cis-1,2-156-59-2 Yes No 96.94 U 2.00E+02 U 6.41E+03 U 70
Dichloroethylene, trans-1,2-156-60-5 Yes Yes 96.94 U 3.31E+02 U 4.52E+03 U 100
Tetrachloroethylene 127-18-4 Yes Yes 165.83 U 1.85E+01 U 2.06E+02 U 5
Toluene 108-88-3 Yes Yes 92.14 U 2.84E+01 U 5.26E+02 U 1000
Trichloroethane, 1,1,1-71-55-6 Yes Yes 133.41 U 1.24E+02 U 1.29E+03 U 200
Trichloroethane, 1,1,2-79-00-5 Yes Yes 133.41 U 2.30E+01 U 4.59E+03 U 5
Trichloroethylene 79-01-6 Yes Yes 131.39 U 6.90E+01 U 1.28E+03 U 5
Vinyl Chloride 75-01-4 Yes Yes 62.50 U 2.98E+03 U 8.80E+03 U 2
Output generated 05AUG2022:17:31:55
Chemical Properties 5
HLC
(atm-m 3/mole)
Henry's
Law
Constant
(unitless)
H`
and
HLC
Ref
Henry's
Law
Constant
Used in
Calcs
(unitless)
Normal
Boiling
Point
BP
(K)
BP
Ref
Critical
Temperature
TC\
(K)
TC\
Ref
Enthalpy of
vaporization
at
the normal
boiling point
ΔHv,b\
(cal/mol)
ΔHv,b\
Ref
Lower
Explosive
Limit
LEL
(%
by
volume)
LEL
Ref
5.55E-03 2.27E-01 U 2.27E-01 353.15 U 5.62E+02 U 7340.00 U 1.20 U
3.67E-03 1.50E-01 U 1.50E-01 334.25 U 5.36E+02 U 6990.00 U -
5.62E-03 2.30E-01 U 2.30E-01 330.55 U 5.23E+02 U 6900.00 U 5.40 U
1.18E-03 4.82E-02 U 4.82E-02 356.65 U 5.62E+02 U 7640.00 U 6.20 U
2.61E-02 1.07E+00 U 1.07E+00 304.85 U 4.82E+02 U 6250.00 U 6.50 U
4.08E-03 1.67E-01 U 1.67E-01 333.25 U 5.36E+02 U 7220.00 U 3.00 U
9.38E-03 3.83E-01 U 3.83E-01 321.85 U 5.16E+02 U 6910.00 U 6.00 U
1.77E-02 7.24E-01 U 7.24E-01 394.15 U 6.20E+02 U 8290.00 U -
6.64E-03 2.71E-01 U 2.71E-01 384.15 U 5.92E+02 U 7930.00 U 1.10 U
1.72E-02 7.03E-01 U 7.03E-01 347.15 U 5.45E+02 U 7140.00 U 8.00 U
8.24E-04 3.37E-02 U 3.37E-02 387.15 U 6.02E+02 U 8320.00 U 6.00 U
9.85E-03 4.03E-01 U 4.03E-01 360.35 U 5.71E+02 U 7500.00 U 8.00 U
2.78E-02 1.14E+00 U 1.14E+00 259.85 U 4.25E+02 U 4970.00 U 3.60 U