25056_Statesville Rd_On-Site Tenant Operations Update_20220422

Via Email April 22, 2022
NCDEQ – Division of Waste Management Brownfields Program 1646 Mail Service Center Raleigh, NC 27699-1646
Attn: Ms. Tracy Wahl Re: On-Site Tenant Operations Update
Statesville Road Property 8718 Statesville Road Charlotte, North Carolina Brownfields Project No. 25056-21-060 H&H Project No. LHG-001
Dear Tracy: On behalf of 8718 Statesville, LLC (prospective developer or PD), H&H is providing this update associated with automotive repair tenant operations for the above referenced site located in
Charlotte. The site received eligibility into the North Carolina Department of Environmental Quality (DEQ) Brownfields Program via a Letter of Eligibility (LOE) dated October 29, 2021. Based on information provided by the Brownfields Program, which includes restrictions referenced in the LOE described below, the PD acknowledges that Brownfields eligibility is
contingent upon current and/or future site users not contributing to contamination at the site. As
such, the PD is electing to prepare a Spill Prevention and Communication Plan (Plan) for Bravo Motors and Premier Imports to ensure Brownfields eligibility is not compromised. Specifically, the Plan will include details pertaining to current chemical storage, safety data sheets (SDS), spill prevention measures, and spill response and notification procedures. In addition, H&H will
conduct quarterly inspections to ensure ongoing compliance with the Plan.
According to the LOE, automotive repair operations performed by on-site tenants would need to be limited to six months or less from the date of the LOE. Since that time, the PD and select tenants have taken measures to minimize potential releases associated with their respective
operations. Tenants that have not been agreeable to operational modifications have had their
leases terminated. Specifically, this includes former tenants Nickoles Auto in space 8718-E and Pete Greene in space 8718-I. Tenants that have been amendable to operational modifications include Bravo Motors in space 8718-C&D and Premier Imports in space 8718-G. Please note that Premier Imports has also reduced their operational footprint by approximately half.
Ms. Tracy Wahl April 22, 2022 Page 2
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Specifically, Bravo Motors and Premier Imports have performed, or will perform in the future, the following operational modifications in their respective tenant spaces:
• Remove all automobile parts not currently installed in a vehicle unless they are
actively being repaired.
o If a part is being repaired, it shall be worked on and/or stored within
secondary containment.
• Remove all automotive batteries unless installed in a vehicle or stored in a
temporary laydown area with secondary containment.
• Clean up all oil and chemical spills from the facility as they occur. Clean all floors
with approved cleaning materials daily at the close of business.
o Install a spill kit similar to Spill Kit For Auto Repair Shops - EnSafeCo
LLC or PIG® Oil-Only Spill Kit in 30-Gallon Overpack Salvage Drum -
KIT436 - New Pig.
• Use a secondary catch pan under liquid storage areas, including all vehicles with
leaks.
• Install double wall storage containers for all waste liquids, including, but not
limited to, petroleum products (i.e., waste oil, etc.) and solvents.
• Use only citrus-based solvents or recirculating spray wash cabinets for metal parts
cleaning.
• Designate storage areas with secondary containment for raw materials, materials-
in-use, and waste for retail-sized containers (note that neither Bravo Motors and
Premier Imports is supplied chemicals in bulk).
• Relocate all raw materials, materials-in-use, and waste for retail-sized containers
to the aforementioned designated storage areas.
• On a daily basis, all oil drain containers will be disposed of into a double wall
waste oil container.
• All waste oil is actively being removed from the site on a bi-weekly basis.
• Bravo Motors has applied a retro coat seal to their work area floors;
• Premier Imports has sealed all cracks in their work area floors with a
polyurethane crack repair kit.

Ms. Tracy Wahl April 22, 2022 Page 3
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As a follow up to this update, we request that DEQ meet with the PD on-site to inspect the aforementioned tenant spaces and their respective operational modifications.
If you have any questions or comments, please do not hesitate to contact me. Sincerely, Hart & Hickman, PC
Justin Ballard, PG Project Manager cc: Mr. Shay Yakobovich, Luxe-Holdings, LLC (via email)
Mr. John Brinkos, Brinkos Capital Partners, LLC (via email) Ms. Faria Ibrahim, Hudson Edge, LLC (via email) Mr. Bruce Nicholson, DEQ Brownfields (via email) Mr. Kevin Slaughter, DEQ Brownfields (via email) Ms. Genna Olson, Hart & Hickman, PC (via email)