HomeMy WebLinkAbout20017 Asheville Tannery PRI 2007.04.04Day’s Tobacco Warehouse - Report of Phase I Environmental Site Assessment 339 Old Lyman Street in Asheville, North Carolina MACTEC Project 6685-07-1663
April 4, 2007
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TABLE OF CONTENTS
Page
COVER LETTER
EXECUTIVE SUMMARY ........................................................................................................................... I
1. INTRODUCTION ................................................................................................................................ 1 1.1. Purpose ........................................................................................................................................ 1
1.2. Detailed Scope of Services ......................................................................................................... 1
1.3. Significant Assumptions ............................................................................................................. 2 1.4. Limitations and Exceptions ......................................................................................................... 3
1.5. Special Terms and Conditions .................................................................................................... 3 1.6. User Reliance .............................................................................................................................. 3
2. SITE DESCRIPTION ........................................................................................................................... 3
2.1 Location and Legal Description .................................................................................................. 3 2.2 Site and Vicinity General Characteristics ................................................................................... 4 2.3 Current Use of the Property ........................................................................................................ 4
2.4 Description of Structures, Roads and Other Improvements ........................................................ 4 2.5 Current Uses of Adjoining Properties ......................................................................................... 5
3. USER/OWNER-PROVIDED INFORMATION .................................................................................. 5
3.1 Title Records ............................................................................................................................... 5 3.2 Environmental Liens ................................................................................................................... 5
3.3 Specialized Knowledge ............................................................................................................... 6
3.4 Commonly Known Information .................................................................................................. 6 3.5 Valuation Reduction for Environmental Issues .......................................................................... 6
3.6 Owner/Property Manager/Occupant Information ....................................................................... 6
3.7 Reason for Performing the Phase I ............................................................................................. 6
4. RECORDS REVIEW ............................................................................................................................ 7
4.1 Standard Environmental Record Sources.................................................................................... 7 4.2 Additional Environmental Record Sources ............................................................................... 10 4.3 Physical Setting Sources ........................................................................................................... 10
4.4 Historical Use Information on the Property .............................................................................. 11 4.5 Historical Use Information on the Adjoining Properties .......................................................... 13
5. SITE RECONNAISSANCE ............................................................................................................... 15
5.1 Methodology and Limiting Conditions ..................................................................................... 15 5.2 General Site Setting .................................................................................................................. 15 5.3 Exterior Observations ............................................................................................................... 16
5.4 Interior Observations ................................................................................................................ 16
6. INTERVIEWS .................................................................................................................................... 17
6.1 Interview with Owner/Occupant ............................................................................................... 17
6.2 Interview with Local Government Officials ............................................................................. 17
7. FINDINGS AND OPINION ............................................................................................................... 17
8. CONCLUSIONS AND RECOMMENDATIONS .............................................................................. 18
Day’s Tobacco Warehouse - Report of Phase I Environmental Site Assessment 339 Old Lyman Street in Asheville, North Carolina MACTEC Project 6685-07-1663
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9. DEVIATIONS .................................................................................................................................... 19
10. ENVIRONMENTAL PROFESSIONAL STATEMENT ................................................................... 20
LIST OF APPENDICES
APPENDIX A FIGURES
APPENDIX B ENVIRONMENTAL LIEN SEARCH REPORT
APPENDIX C PROPERTY RECORD CARD
APPENDIX D USER QUESTIONNAIRES AND CORRESPONDANCE RECORDS
APPENDIX E REGULATORY SEARCH INFORMATION
APPENDIX F AERIAL PHOTOGRAPHS
APPENDIX G HISTORICAL INFORMATION (1939 PAMPHLET, TOPOGRAPHIC MAP, CITY DIRECTORIES, SANBORN MAPS, AND 1967 MAP)
APPENDIX H SITE PHOTOGRAPHS
APPENDIX I PERSONNEL QUALIFICATIONS
Day’s Tobacco Warehouse - Report of Phase I Environmental Site Assessment 339 Old Lyman Street in Asheville, North Carolina MACTEC Project 6685-07-1663
April 4, 2007
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EXECUTIVE SUMMARY
PROPERTY NAME: Day’s Tobacco Warehouse
LOCATION: 339 Old Lyman Street, Asheville, North Carolina 28801
This executive summary is provided for convenience and should not substitute for review of the complete
report, including all attachments. Based on the data collected during the assessment, our findings and
conclusions are summarized as follows:
Environmental Conditions Acceptable Further Research
Subject Property Regulatory Status Yes No
Off-Site Listed Facilities Yes No
Subject Property Use
History
No, regarding potential
contamination from previous operations
Yes, environmental sampling
in the areas indicated
Present Subject Property
Use
No, regarding potential contamination from automobile
salvage operation
Yes, environmental sampling in the area of the subject
building
Surrounding Land Use Yes (however, see information
regarding railroad) Possible
MACTEC conducted a Phase I Environmental Site Assessment (Phase I) of the Day’s Tobacco
Warehouse (Former Asheville Tannery) property located at 339 Old Lyman Street in Asheville, North
Carolina. The subject property consists of two parcels of land totaling approximately 10.1 acres in size
(Buncombe County tax parcels 963816938794, 9.5 acres and 963816946105, 0.6 acres). Any exceptions
to or deletions from this practice are described in the appropriate sections of this report. The property
reconnaissance was performed on March 21, 2007.
The information reviewed for this project indicates the Hans Rees’ Sons Tannery began operations at the
subject property in 1889. The tanning operation at this facility utilized extracts from the bark of trees to
chemically treat, or tan, the leather hides. A machine shop for servicing a site boiler was noted on the site
maps during the tannery operation. Gasoline tanks and an ‘oil house’ were also noted on the 1950 and
1954 Sanborn maps of the property. According to the deed records obtained in the environmental lien
search report, the tannery was sold to C.T. Day in 1955. Since the property has been owned by C.T. Day
Day’s Tobacco Warehouse - Report of Phase I Environmental Site Assessment 339 Old Lyman Street in Asheville, North Carolina MACTEC Project 6685-07-1663
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and Day’s Warehouses, primarily cattle, tobacco, and warehousing operation have occurred at the site.
Several of the buildings were used for chemical storage during the 1960s and 1970s, and a vat of
unknown purpose is present in one of the buildings.
The subject property currently contains nine separate buildings. Five of the buildings are currently
vacant. The northern portion of one building is used for storing primarily construction materials; one
building is occupied by an automobile salvage business (EDACO); one building is occupied by Allied
Insulation and contains office and warehouse space; and one building is occupied by Village Antiques for
warehousing antiques; and one building is occupied by Servecare Inc., a janitorial/maintenance service
business, for storage of supplies.
EDR’s review of environmental lists revealed 15 listed sites within the search distances recommended in
ASTM E 1527-05. The subject property was not identified on regulatory databases reviewed for our
assessment. The listed sites do not likely constitute recognized adverse environmental conditions to the
subject property, based on distance and direction, or specific information regarding each site.
The property east of the site has been occupied by a railroad since at least the late 1800s. Historical
railroads are potential sources of contamination with respect to the likelihood of liquid chemical spills and
repetitive operation of equipment. Details of potential contamination resulting from the previous use of
the area east of the site are not known. The adjacent historical railroad is located in a topographically
upgradient direction in relation to the subject property.
With regard to off-site recognized environmental concerns, an EPA policy1 states that “… where
hazardous substances have come to be located on or in a property solely as the result of subsurface
migration in an aquifer from a source or sources outside the property, EPA will not take enforcement
action against the owner of such property to require the performance of response actions or the payment
of response costs.” Hazardous liquids in soil can contaminate downgradient property, when product
releases seep down to the ground water table and then migrate in the directions of ground-water flow as a
spreading plume. Based upon our past experience in North Carolina, EPA and the state Department of
Environment and Natural Resources holds hazardous waste handling facility owners and operators
responsible for corrective action due to releases from their facility. EPA has stated in its policy1 that
1 60 FR 127, July 3, 1995, Final Policy Toward Owners of Property Containing Contaminated Aquifers and Guidance
on Agreements with Prospective Purchasers of Contaminated Property and Model Prospective Purchaser Agreement.
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owners of property with contaminated aquifers will not be held responsible for cleanup, if off-site sources
are the cause of contamination and if the property owner has not contributed to the off-site source. If
upgradient potential contamination is a concern to the proposed property transaction, additional
information could be acquired by searching for and reviewing technical documents (such as
Contamination Assessment Reports and/or Corrective Action Plans) or performing an invasive
hydrogeological assessment of the subject property along the topographically upgradient property
boundary.
Based on the information obtained for this project, we offer the following conclusions and
recommendations:
• The past use of the property for chemical storage, as a machine shop, and as a fitness equipment
manufacturer utilizing solvents constitutes a recognized environmental condition.
Environmental sampling is recommended in the areas of Building #1/1B, Building #1C, Building
#4, and Building #8.
• The past and current presence of gasoline and heating oil storage tanks, and a former ‘oil house’,
indicates a potential recognized environmental condition. Environmental sampling is
recommended in the area of the heating oil storage tank at Building #1, and in the area of
reported gasoline storage tanks and the oil house northwest of Building #1.
• The current use of the property as an automobile salvage business constitutes a recognized
environmental condition. The area currently being used for the salvage business was also
historically a boiler. Environmental sampling is recommended in the area of Building #3.
• If upgradient, off-site, potential contamination is a concern to the proposed property transaction,
additional information could be acquired by searching for and reviewing technical documents
related to the railroad (such as Contamination Assessment Reports and/or Corrective Action
Plans) or performing an invasive hydrogeological assessment of the subject property along the
topographically upgradient property boundary.
MACTEC conducted this Phase I in general accordance with the scope and limitations of ASTM
International Standard Practice E 1527-05, "Standard Practice for Environmental Site Assessments:
Phase I Environmental Site Assessment Process” (E 1527-05). Any exceptions to, or deletions from, this
practice are described in Section 1.4 of this report.
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1. INTRODUCTION
1.1. Purpose
The purpose of this Phase I Environmental Site Assessment was to identify recognized environmental
conditions associated with the subject property (Figure 1 in Appendix A). ASTM Standard Practice E
1527-05 defines recognized environmental conditions as “the presence or likely presence of any
hazardous substances or petroleum products on a property under conditions that indicate an existing
release, a past release, or a material threat of a release of any hazardous substances or petroleum products
into structures on the property or into the ground, groundwater, or surface water of the property. The
term includes hazardous substances or petroleum products even under conditions in compliance with
laws. The term is not intended to include de minimis conditions that generally do not present a material
risk or harm to public health or the environment and that generally would not be the subject of an
enforcement action if brought to the attention of appropriate governmental agencies. Conditions
determined to be de minimis are not recognized environmental conditions.”
1.2. Detailed Scope of Services
MACTEC prepared this Phase I based on readily-available information and site observations. We
conducted the following tasks at the subject property, which are in general accordance with those tasks
established in E 1527-05:
• Reviewed the history of the subject property using readily-available standard historical sources
and interviewed the owner of the subject property.
• Reviewed lists published by selected state and federal environmental regulatory agencies for
records or comments pertaining to past or present environmental concerns at the subject property and/or within specified search distances from the subject property. These distances adhere to the
standard search distances recommended in ASTM Standard Practice E 1527-05. Some of the lists
reviewed include:
• The lists of the Inactive Hazardous Sites Inventory, which includes the National Priorities
List (NPL; one-mile distance);
• Delisted NPL sites (one-mile);
• The list of hazardous-waste facilities (generators and transporters, subject property and adjacent properties; treaters/storers/disposers [TSDs], one-half mile) compiled by the
NCDENR Division of Waste Management (DWM) and permitted under the Resource
Conservation and Recovery Act (RCRA);
• The list of TSDs of hazardous waste subject to corrective action under RCRA (CORRACTS
list; one-mile);
Day’s Tobacco Warehouse - Report of Phase I Environmental Site Assessment 339 Old Lyman Street in Asheville, North Carolina MACTEC Project 6685-07-1663
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• The list of the Comprehensive Environmental Response, Compensation and Liability
Information System (CERCLIS, one-half mile), which contains sites which are proposed to
be placed on the NPL, and sites that are in the screening and assessment phase for possible inclusion on the NPL;
• The list of CERCLIS sites which have been assessed and at which EPA determined that No Further Remedial Action is Planned (NFRAP) to place the sites on the NPL (one-half mile);
• The list of the Emergency Response Notification System (ERNS) compiled by the U.S. Coast
Guard’s National Response Center (subject property);
• The list of registered USTs compiled by the DWM (subject property and adjacent properties);
• The incident list, which includes LUST systems, compiled by the DWM (one-half mile);
• The Incident Management Database (IMD), which is maintained by NCDENR and lists releases of oil or hazardous materials in the state of North Carolina. The site includes LUST sites.
• The list of solid-waste facilities permitted by the DWM (one-half mile);
• The old landfill inventory compiled by the DWM (one-half mile);
• The list of Responsible Party Voluntary Action Sites (VCP; one-half mile); and
• The Brownfields Projects Inventories maintained by the EPA and the DWM (one-half mile).
MACTEC personnel also:
• Conducted a "walk-over" site reconnaissance to look for surficial indications of activities
involving hazardous substances and/or petroleum products.
• Conducted a vehicular reconnaissance in the vicinity of the subject property to verify the location
of the facilities identified during the list review, and to visibly determine if land use on adjacent properties creates the potential for an adverse environmental impact on the subject property.
• Prepared this written report that summarizes our observations, findings, and conclusions.
Our proposed scope of services did not include sampling or evaluating buildings for radon or asbestos-
containing materials, evaluating ambient air quality, identifying wetlands, or testing of the soil, air,
surface water, drinking water, or ground water for chemical contaminants.
1.3. Significant Assumptions
MACTEC made no significant assumptions during the site “walk-over.” The property boundaries in the
field were estimated by comparing physical features such as buildings, fences, drainage features, fire
hydrants, etc. to the provided property boundary survey.
Day’s Tobacco Warehouse - Report of Phase I Environmental Site Assessment 339 Old Lyman Street in Asheville, North Carolina MACTEC Project 6685-07-1663
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1.4. Limitations and Exceptions
Our findings and opinions are relative to the date of our site “walk-over” and should not be relied on to
represent conditions on other dates. These opinions are based on information obtained during the study
and our experience. If additional information becomes available which might change our conclusions, we
request the opportunity to review the information, reassess the potential concerns, and modify our
opinions, if warranted.
Although this assessment has attempted to identify the potential for environmental impacts to the subject
site, potential sources of contamination may have escaped detection due to (1) the limited scope of this
assessment, (2) the inaccuracy of public records, (3) the presence of undetected or unreported
environmental incidents, (4) inaccessible areas, and/or (5) deliberate concealment of detrimental
information.
1.5. Special Terms and Conditions
The terms and conditions of our work are those in MACTEC Proposal PROP07ASHE-018, dated March
6, 2007, which Mr. Robert Camille accepted on March 9, 2007.
1.6. User Reliance
This report is intended for the use of Mr. Robert Camille. The contents should not be relied upon by
other parties without the expressed, written consent of MACTEC.
2. SITE DESCRIPTION
2.1 Location and Legal Description
The subject property is located at 339 Old Lyman Street in Asheville, North Carolina, as shown on Figure
1 in Appendix A. The subject property consists of two parcels of land totaling approximately 10.1 acres
in size (Buncombe County tax parcels 963816938794, 9.5 acres and 963816946105, 0.6 acres).
Environmental Data Resources, Inc. (EDR) was contracted on behalf of MACTEC to conduct a search for
environmental liens on the subject property. The environmental lien search report, included as Appendix
B, contains a legal description of the subject property.
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2.2 Site and Vicinity General Characteristics
The subject property is located in Asheville’s historic “River District”, which became industrially
developed in the early 1900s due to its close proximity to the French Broad River. The subject property
currently contains nine separate buildings that are utilized for various purposes or are vacant, as described
below. Properties in the vicinity of the subject property are commercially or industrially developed.
2.3 Current Use of the Property
The subject contains nine separate buildings as shown on Figure 2 in Appendix A (Note: Building
numbers are referenced on Figure 2 as they have generally been referred to by Day’s Tobacco
Warehouse, Inc.). Five of the buildings (Buildings #1/1B, #1C (A and B), #7, #7D, and #8), are vacant.
The northern portion of Building #1A is used for storing primarily construction materials. Building #3 is
currently occupied by an automobile salvage business (EDACO). Building #6 is currently occupied by
Allied Insulation and contains office and warehouse space. Building #4 is currently occupied by Village
Antiques for warehousing antiques. Building #5 is currently occupied by Servecare, Inc., a
janitorial/maintenance service business, for storage of supplies.
2.4 Description of Structures, Roads and Other Improvements
The subject property contains nine separate buildings: Building #1 (divided into portions as 1 , 1A and
1B), Building #1C (A and B), Building #3, Building #4, Building #5, Building #6, Building #7, Building
#7D, and Building #8, and associated gravel-paved driveway and parking areas. Railroad spurs and
scales that were associated with the tannery and tobacco warehousing operations are present in the
northern portion of the subject property. A general description of the buildings is below:
• Building #1 – 10,000 square foot, office/retail space, brick exterior (two stories)
• Building #1A – 30,000 square foot warehouse
• Building #1B – 12,000 square foot brick addition/warehouse to Building #1
• Building #1C – 4,000 square foot, brick exterior
• Building #3 – 48,000 square foot warehouse
• Building #4 – 17,000 square foot warehouse
• Building #5 – 30,000 square foot warehouse
• Building #6 – 17,000 square foot warehouse with offices
• Building #7 – 30,000 square foot warehouse
• Building #7D – 6,000 square foot warehouse with offices (two stories)
• Building #8 – 4,000 square foot, brick exterior
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Overhead power lines are located at the subject property, and underground utilities located at the subject
property include natural gas, water supply, sanitary sewer, and storm sewer.
2.5 Current Uses of Adjoining Properties
Properties in the vicinity of the subject property are generally commercially or industrially developed.
The property directly west of the subject property contains buildings associated with the former Asheville
Tannery that are currently occupied by commercial/retail businesses, as well as a commercial/warehouse
building.
Asheville Waste Paper is located northwest of the subject property. The Norfolk Southern Railroad tracks
are located adjacent to the subject property’s eastern boundary. A railroad “storage” area (containing
railroad ties and lines) is located northeast of the subject property and a vacant/wooded parcel that is also
owned by Norfolk Southern is located south of the subject property.
The building located southeast of the intersection of Old Lyman Street and Lyman Street, is currently
occupied by the Loren Cook Company, a fan/blower manufacturer (the building appears to be for
warehousing). The Riverview Station building, which is located south of the Loren Cook building and
west of the subject property contains several small businesses including: Resort Telemarketing, Kitchen
Works, Avaloo Custom Sewing, Tom K.’s Kitchen Design, The Dog House, Printing and Design, The
Candle Station, and City Bakery, Inc. The Asheville Metal Recycle Yard is located between the
Riverview Station Buildings and the subject property. V.J.’s Automotive Service Shop is located south of
the Riverview Station Buildings and Paneling World, a kitchen cabinetry and equipment design and
supply store, is located southeast of V.J.’s (west of the subject property).
3. USER/OWNER-PROVIDED INFORMATION
3.1 Title Records
Title records were not provided to MACTEC; however, the property record card for the smaller parcel
was obtained from the Buncombe County tax website and is included in Appendix C.
3.2 Environmental Liens
MACTEC contacted Mr. Alton Day, the current owner of the subject property, and Mr. Robert Camille,
potential purchaser of the subject property, concerning environmental liens on the property. Mr. Day and
Day’s Tobacco Warehouse - Report of Phase I Environmental Site Assessment 339 Old Lyman Street in Asheville, North Carolina MACTEC Project 6685-07-1663
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Mr. Camille did not have knowledge of environmental liens held against the property. Mr. Day and Mr.
Camille completed User Questionnaires, which are included in Appendix D.
As stated in Section 2.1, EDR was contracted by MACTEC to perform an environmental lien search for
the two parcels comprising the subject property. The environmental lien search report is included in
Appendix B. The report indicates that no environmental liens or activity use limitations are held on the
subject property.
3.3 Specialized Knowledge
Mr. Day and Mr. Camille indicated that they did not have specialized knowledge concerning past or
present environmental issues at the subject property. However, Mr. Camille provided MACTEC with a
copy of a Phase I Environmental Site Assessment, prepared by J. Patrick Price and dated October 8, 1999.
The 1999 Phase I was prepared for Day’s Tobacco Warehouse, Inc., and included the subject property
and adjacent parcels.
3.4 Commonly Known Information
Mr. Day and Mr. Camille indicated that it is commonly known that the subject property formerly
contained tobacco warehouses and the Han Rees’ Sons Asheville Tannery. Mr. Day and Mr. Camille
indicated that they had no commonly known information regarding adverse environmental liabilities or
situations with regards to the subject property. MACTEC does not have commonly known information
concerning adverse environmental conditions related to the property.
3.5 Valuation Reduction for Environmental Issues
Mr. Day and Mr. Camille stated that they did not have knowledge of a reduction in value of the subject
property due to past or present environmental concerns.
3.6 Owner/Property Manager/Occupant Information
The Buncombe County tax website lists Day’s Storage Warehouse, Inc, as the property owner. Mr. Alton
Day manages the property, and currently leases four of the buildings to the following businesses: Allied
Insulation Inc., EDACO, Village Antiques, and Servecare, Inc.
3.7 Reason for Performing the Phase I
Mr. Robert Camille has requested preparation of this Phase I related to the potential purchase of the
subject property.
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4. RECORDS REVIEW
4.1 Standard Environmental Record Sources
Environmental Data Resources, Inc. (EDR), under subcontract to MACTEC, reviewed the state and
federal regulatory lists referenced in Section 1.2. Please note that these lists are limited and only include
sites known to the regulatory agencies at the time of publication. These lists identify sites that are
contaminated or exhibit potential for contamination due to the generation or handling of toxic or
hazardous materials. The EDR report is included in Appendix E.
EDR’s review of the regulatory listings revealed 15 sites within the established search radii from the
subject property. The subject property was not listed on the lists reviewed.
According to the EDR report, the Asheville Coal Gas Plant #1 site is listed in the CERCLIS database and
on the Hazardous Substance Disposal Sites list (HSDS). The Asheville Coal Gas Plant site is located at
the intersection of Riverside Drive and Lyman Street, approximately 0.5 miles north of the subject
property in a topographically crossgradient to downgradient direction. The EDR report indicated that a
“preliminary assessment” was completed in 1993, and the priority level is listed as “low.” Based on the
distance and direction from the subject property, it is not likely that potential releases from this facility
would impact the subject property.
One site was listed on the SHWS list. Pathologists Medical Lab, located approximately 4,400 feet east of
the subject property is listed on the North Carolina Inactive Hazardous Sites Branch (last updated
4/30/1990) and the facility status is listed as “requiring no further action.”
According to the EDR report, 13 sites were listed on one or more of the following lists: the Incident
Management Database (IMD), the LUST list, and/or the Brownfields list. Information regarding these
sites (gathered from the EDR report and the internet) is listed in the following table (Note: locations are
relative to the approximate center of the subject property).
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Site Status Location
Asheville Waste Paper 304 Lyman Street
IMD/Brownfields Facility ID: 87252 EDR Map ID: 1 & 7
Date Occurred: 1/28/2005 Incident Description: Fuel Oil was discovered
seeping out bank into French Broad River. Source is fuel oil spill from a 5,000 gallon aboveground storage tank (AST) at Asheville Waste Paper
Ground-water Contamination: Yes Type: Fuel oil
Phase: Response (2/16/2005)
Approximately 300 feet
northwest of subject property (across Old
Lyman Street to the north)
Green’s Mini Mart
414 Depot Street IMD/LUST Incident No. 23522
EDR Map ID: 2
Date Occurred: 6/08/2001
Incident Description: Soil contamination was reported during removal of UST Ground-water Contamination: No
Type: Gasoline/diesel Phase: Closed Out (12/11/2002)
Approximately
700 feet northeast of subject property.
Fmr. D-O-UN Dairies Inc. 403 Depot Street
IMD Facility ID: 86584 EDR Map ID: A4
Date Occurred: 4/28/2003 Incident Description: Waste oil spilled out of drums
without lids Ground-water Contamination: No Type: Waste Oil
Phase: Assessment
Approximately 700 feet
northeast of subject property.
Asheville Fire Station No. 2
315 Livingston Street IMD/LUST
Incident No. 28124
EDR Map ID: B5
Date Occurred: 7/23/1996
Incident Description: Minor soil contamination Ground-water Contamination: No
Type: Gasoline/diesel
Phase: Closed Out (6/6/2003)
Approximately
800 feet east of subject property.
Proposed Sprint Expansion 363 Depot Street
IMD/LUST
Incident No. 20873 EDR Map ID: 8
Date Occurred: 10/22/1999 Incident Description: Sprint conducted Phase I and II
and found ground-water and soil contamination
Ground-water Contamination: Yes Type: Gasoline/diesel
Phase: Response (low risk priority designation)
Approximately 1,100 feet
northeast of
subject property.
Asheville Ice and Storage
357 Depot Street Brownfields (1009310168)
EDR Map ID: 9
Letter of Eligibility from North Carolina
Brownfields Program (8/19/2005)
Approximately
1,200 feet northeast of
subject property.
VJ’s Auto Service Center
500 Lyman Street
IMD/LUST Incident No. 19862
EDR Map ID: C11
Date Occurred: 1/13/1999
Incident Description: Minor soil contamination
observed during removal of UST Ground-water Contamination: No
Type: Gasoline/diesel Phase: Response (low risk priority designation)
Approximately
500 feet
southwest of subject property.
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Site Status Location
Parker Oil Co.
290 Depot Street IMD/LUST
Incident No. 28319
EDR Map ID: 12
Date Occurred: 6/08/2005
Incident Description: Contaminated soil from former UST’s discovered during an environmental
site assessment
Ground-water Contamination: No Type: Petroleum
Phase: Closed Out (12/28/2005)
Approximately
1,400 feet northeast of
subject property.
Parker Oil Co.
290 Depot Street IMD
FacilityID: 86583
EDR Map ID: 12
Date Occurred: 4/01/2003
Incident Description: Heating oil released “inside dike area”, reported as vandalism
Ground-water Contamination: Unknown
Type: Heating Oil Phase: Assessment (site priority 50E)
Approximately
1,400 feet northeast of
subject property.
Mary White Residence
26 Beverly Road West
IMD/LUST TRUST Incident No. 28175
EDR Map ID: 13
Date Occurred: 10/07/2003
Incident Description: Soil contamination from home
heating oil UST Ground-water Contamination: No
Type: Heating Oil
Phase: Not reported (low risk priority designation)
Approximately
1,400 feet west
of subject property.
Pat Bunker Residence 381 S. French Broad Ave. IMD/LUST
Incident No. 5052 EDR Map ID: 14
Date Occurred: 5/19/1989 Incident Description: Soil contamination from home heating oil UST
Ground-water Contamination: No Type: Heating Oil
Phase: Closed Out (12/21/1989)
Approximately 1,900 feet west of subject
property.
Allied Motor Company/
Margaret Deal Estate 291 Haywood Road IMD/LUST TRUST
Incident No. 12396 EDR Map ID: D16/D17
Date Occurred: 5/25/1993
Incident Description: Soil contamination discovered during removal of UST Ground-water Contamination: No
Type: Gasoline/diesel Phase: Closed Out (7/15/1994)
Approximately
2,500 feet west of subject property.
Able Septic Tank Service 20 Brownwood Ave.
IMD/LUST Incident No. 7386 EDR Map ID: 18
Date Occurred: Not reported Incident Description: Contaminated soil discovered
from release from UST Ground-water Contamination: No Type: Gasoline/diesel
Phase: Closed Out (12/20/1991)
Approximately 2,500 feet west
of subject property.
Highland Exchange
Property 28 Adams Street
IMD/LUSt
Incident No. 28366 EDR Map ID: 19
Date Occurred: 1/24/2006
Incident Description: Detected soil contamination in two hand auger borings
Ground-water Contamination: No
Type: Gasoline/diesel Phase: Closed Out (10/02/06)
Approximately
2,500 feet northeast of
subject property.
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4.2 Additional Environmental Record Sources
On April 3, 2007, MACTEC interviewed Mr. Gary Cornett, the City of Asheville Fire Chief, regarding
environmental incidents requiring a response at the subject property. Mr. Cornett indicated several minor
fires have required a response; however, he was not aware of any environmental spills or conditions
requiring a response. Mr. Cornett has worked at the Asheville Fire Department for approximately 25
years.
4.3 Physical Setting Sources
MACTEC reviewed the following sources to obtain information regarding the physical setting of the
subject property:
• Geologic Map of North Carolina, published in 1985 by the North Carolina Geological Survey.
• United States Geological Survey (USGS) Topographic Map, 7.5-minute series, Asheville, N.C.
Quadrangle, dated 1961, photorevised 1991; published by the USGS (Figure 1).
• Soil Survey of Buncombe County, published by USDA Natural Resources Conservation Service,
and obtained from the Buncombe County Geographic Information Systems (GIS) website.
The subject property is located within the Blue Ridge Physiographic Province. Based on a review of the
geologic map, the subject property is underlain by rocks of the Ashe Metamorphic and Tallulah Falls
Formation, which are described as muscovite-biotite gneiss (interlayered and gradational with mica schist,
minor amphibolite and hornblende gneiss). The bedrock in the Blue Ridge Physiographic Province is a
complex crystalline formation that has been faulted and contorted by past tectonic movements. The rock
has weathered to residual soils, which form the mantle for the hillsides and hilltops. The typical residual
soil profile in areas not disturbed by erosion or human activities consists of silty and/or clayey soils near
the surface where weathering is more advanced, underlain by sandy silt and silty sand. There may be
colluvial (old land-slide) material on the slopes and alluvial sediments in stream valleys and floodplains.
According to the Soil Survey of Buncombe County, soils at the subject property are described as
Udorthents, which include soils in areas where the native soil profile has been disturbed by earthwork or
development. According to the site map provided to MACTEC (prepared by Brooks & Medlock
Engineering, PLLC, dated September 17, 2004), the subject property is located almost entirely within the
French Broad River 100-year floodplain; therefore, it presumably contains significant alluvial deposits,
which may consist of sands, cobbles, and boulders.
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The 2004 site survey indicates that the subject property ranges in elevation from approximately 1,990 feet
above mean sea level in the western portion of the subject property to 1975 in the northeastern corner;
however, the majority of this elevation change (i.e., approximately ten vertical feet) is along the western
property boundary adjacent to the railroad tracks. Surface drainage at the subject property appears to
generally flow to the west toward the French Broad River or locally to catch basins that drain either
directly to the river or to the drainage ditches located along southwestern and southern property
boundaries, which also flow to the French Broad River. Assuming that the ground-water table generally
mirrors the local topography, ground water beneath the subject property is expected to generally flow
west toward the French Broad River, which flows to the north.
4.4 Historical Use Information on the Property
MACTEC reviewed readily-available historical information and conducted interviews with persons
knowledgeable of the subject property in order to evaluate the site history. We reviewed/interviewed the
following sources:
• Aerial photographs, dated 1951, 1963, 1975, and 1988, reviewed at the Buncombe County Natural Resources Conservation Service in Asheville, North Carolina (Appendix F).
• Aerial photographs, dated 1968, 1975, and 1985 (orthophotograph), obtained from the Buncombe County Planning and Development Department in Asheville, North Carolina (Appendix F).
• Aerial photograph, dated 1994, obtained from www.terraserver-USA.com (Appendix F)
• Aerial photograph, dated 2002, obtained from the Buncombe County GIS website (Appendix F).
• USGS Topographic Map, Asheville, N.C. Quadrangle, dated 1901, reprinted 1921; published by the USGS (Appendix G).
• City Directories for Asheville, North Carolina dated 1899 – 1908, 1910 – 1917, 1920, 1922, 1923, 1925, 1926, 1928, 1929, 1930, 1932, 1935, 1938, 1940, 1943, 1947, 1950, 1953, 1955, 1956, 1958, 1961 – 1967 , 1969 – 1990, 1992 – 1997, and 1999 – 2005 were reviewed at the
Asheville Public Library in Asheville, North Carolina (Appendix G).
• Sanborn Fire Insurance historical maps dated 1901, 1907, 1913, 1917, 1925, 1950, 1954, 1957,
1960, 1963, and 1972 obtained from EDR and www.NCLive.org website (Appendix G).
• A hand-drawn map of the subject property, dated October 1967, obtained from the Phase I
Environmental Site Assessment, prepared by J. Patrick Price and dated October 8, 1999
(Appendix G, referred to herein as the “1967 map”).
• A pamphlet titled, “A Serial Story of Hans Rees Son’s Inc.,” published in 1939, obtained from the
Asheville Public Library in Asheville, North Carolina (Appendix G).
• Interviews with Mr. Alton Day, subject property owner, on March 16 and 21, 2007.
• Interview with Mr. Phil York, Production Manager of Allied Insulation Inc, which is a current occupant of the subject property, on March 21, 2007.
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• Interview with Gary Cornett, City of Asheville Fire Chief, on April 3, 2007.
Based on our assessment, we have compiled the following historical chronology of the subject property:
According to the pamphlet reviewed, the Hans Rees’ Sons Tannery began operations at the subject
property in 1889. According to the deed records obtained in the environmental lien search report, the
tannery was sold to C.T. Day in 1955 (the city directories listed several addresses for the tannery between
1889 and 1954). The tanning operation at this facility utilized extracts from the bark of trees to
chemically treat, or tan, the leather hides. Upon arrival at the tannery, raw hides were soaked in water and
then in vats of lime water to facilitate manually dehairing of the hides. The hides were then bleached in
tanning liquor, which generally consisted of tannin from the wood, bark, and seeds/nuts of specific trees.
After bleaching, the hides were “finished” by “stuffing”, or “greasing”, the leather, and then they were
stretched and weighed for resale. The preparation activities took place in buildings on the subject
property, and the finishing operations took place in the buildings located on the property directly west of
the subject property. The tannery utilized the following equipment or ancillary processes/equipment at
the subject property: an office (Building #1), scales for weighing hides (adjacent to Building #1); a
laboratory and experimental tan yard (in the area of existing Building #1A/1B); a wash house (Building
#1C); a blacksmiths shop, referred to as “wood shed” on Figure 2; a coal-fired boiler, which has been
removed; a machine shop for servicing the boiler (Building #8); bark sheds, which were located in the
area of existing Buildings #4, #5, #6, and #7; and several elevated water storage tanks, which have been
removed. The leach, or “bleach”, house and “bark mill” were located in the area of existing Building #3,
as indicated on the Sanborn maps. Also, an artesian well is shown on the Sanborn maps approximately 30
feet south of Building #8; however, evidence of this well could not be located during our site visit.
Gasoline tanks and an ‘oil house’ were noted northwest of Building #1 on the 1950 and 1954 Sanborn
maps.
According to the city directories and the Sanborn maps reviewed for this assessment, Big Burley Tobacco
and/or Day’s Tobacco occupied warehouse space at the subject property from 1955 to 1967. According
to the Sanborn maps, Buildings #5, #7, and #7B were constructed between 1957 and 1960; Buildings #4
and #6 were constructed between 1960 and 1963; and Building #3 was constructed between 1963 and
1967.
In the early to mid 1960s, Buildings #1, #1B, #4 and #5 were used for tobacco auctions and warehousing
during. According to Mr. Day, a seasonal cafe (Day’s Café) operated in Building #1 during several
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winters and Building #1A was used as a cattle and livestock barn. The Standard Milling Company –
Charcoal Fuel Division Asheville Plant, a charcoal briquette manufacturing company, occupied Buildings
#6, #7, #7B, and #7D during the early 1960s. Building #7B was used for processing and manufacturing
of the charcoal briquettes, and Buildings #6, #7, and #7D were used for storage.
During the late 1960s and early 1970s, Buildings #4, #5, #6, #7, and #7B were used for tobacco
auctions/warehousing, Building #3 was reportedly used as a paper warehouse (1972 Sanborn map), and
Building #7D was occupied by Skyland Beer Distributing Co. Inc. The 1967 map indicates that Building
#1A was occupied by Beacon Manufacturing Company, presumably for warehousing their textile
products. According to the city directories, Sanborn maps, and the 1967 map, Ticar Chemical occupied
Buildings #1B, #1CA and #8 from approximately 1963 to 1977, and according to the 1972 Sanborn map,
Building #4 was also used as a chemical storage warehouse.
According to the city directories and information provided by Mr. Day, Day’s Tobacco Warehouse
occupied the buildings at the subject property from the mid-1970s to the mid-1980s, when one or more of
the buildings were leased by other businesses. Little’s Fitness Equipment, an exercise equipment
manufacturer, occupied Building #3 from 1986 to 2005, and Elite Fitness Products occupied Building
#1A and #1B from 1999 to 2005. An agricultural products retailer, WNC Feeds Inc., occupied Building
#4 from about 1991 to 1996. Anderson Package and Supply Co. and Smokey Mountain Pallets were
present on the property from 2002 to 2005; however the buildings they occupied were not listed in the
city directories. Reclaimed Wool Co. was also located on the property in 2003; however the building
location was not listed in the city directories. Serve Care Inc., a janitorial service company, has occupied
Building #5 since 1994 and Allied Insulating Inc., has occupied Building #6 since 2000. According to
Mr. Day, Village Antiques currently occupies Building #4, although no listings were found in the city
directories. Mr. Day also indicated that EDACO, an automobile recycling business, began operations in
Building #3 in October of 2006.
4.5 Historical Use Information on the Adjoining Properties
Nearby property usage could potentially impact the surface and subsurface conditions of a property.
Developing a history of past to present uses or occupancies can provide an indication of the likelihood of
recognized environmental conditions. The following sections summarize our findings as to the past
surrounding land use.
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North
Properties north and northeast of the subject property are generally considered to be topographically
crossgradient in relation to the subject property. The adjacent property to the northwest of the subject
property (304 Lyman Street) has been used by Asheville Waste Paper Company since approximately
1967. According to aerial photographs and Sanborn maps, Warehouse #1 was constructed between 1951
and 1954 and was operated by Big Burley Tobacco and/or Day’s Tobacco during the 1950s and early to
mid-1960s.
The adjoining property to the northeast has been owned by Norfolk Southern Railroad since at least 1901.
It is currently used as a railroad maintenance yard and the property primarily contains a stockpile railroad
cross ties as well as several railroad spurs. According to the Sanborn maps, from 1913 to 1925 the
property contained a “Locomotive House”, which was used for housing and maintenance of the
locomotives.
East
Properties east of the subject property are generally considered to be topographically upgradient in
relation to the subject property. The Norfolk Southern Railroad tracks (approximately 400 feet in width)
border the subject property to the east.
South
Properties south of the subject property are generally considered to be topographically crossgradient in
relation to the subject property. A drainage ditch is located along the property’s southern boundary, across
which is a wooded parcel. The parcel is owned by Norfolk Southern and was apparently vacant in the
aerial photographs reviewed.
West
Properties west of the subject property are generally considered to be topographically downgradient in
relation to the subject property. The area west of the subject property currently contains a junkyard
(Asheville Metal Recycle Yard, Inc.) and four buildings including, Paneling World Inc., V.J.’s
Automotive Service, Riverview Station, and the Loren Cook Company. Farther west of these businesses
is Lyman Street and the French Broad River.
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The area currently occupied by the Asheville Metal Recycle Yard, formerly contained buildings used by
the Asheville Tannery (“beam house”). It was also used by Day’s Tobacco Warehouse (Building #2) and
was demolished between 2002 and the present.
The Riverview Station Buildings (191 Lyman Street), west of Building #2 were also used by the
Asheville Tannery (Dry House and Currying Shop). The buildings were used by the Manco Corporation,
a textile manufacturer in 1956 and 1957, and by Ness Brothers Inc, as a cotton waste processing facility,
from at least 1962 to 1970. The building located directly west of Building #1C at the subject property,
which is currently occupied by the Loren Cook Company (also listed as 191 Lyman Street) was
constructed between 1963 and 1972. The Riverview Station Building and Loren Cook Company building
have been occupied by numerous retail businesses since the 1970s.
V.J.’s Auto Service (500 Lyman Street) has been located south of the Riverview Station Building and
west of the subject site since 1999. The building was constructed between 1957 and 1960 and has been
occupied by Ryder Truck Rental, Slosman Corp. Maintenance Dept. (1980 to 1990), Sysco Maintenance
Department (1991 to 1993), Hensley Olen Automobile Service (1994 to 1995) and King’s Transmission
Service (1996 to 1997).
Paneling World is currently located west of the subject property (southeast of V.J.’s Auto). The building
was built between 1963 and 1965 and has contained the following businesses: REA Express Inc. (1965 to
approximately 1974); Friendly Trading Post (from approximately 1974 to 1977); and Paneling World,
which specializes in kitchen cabinetry, has occupied the building since 1980.
5. SITE RECONNAISSANCE
5.1 Methodology and Limiting Conditions
Mr. Matthew Wallace, P.E. and Ms. Susan Kelly, P.E, L.G.., environmental professionals with MACTEC
experienced in environmental site assessments, conducted a site and area visit on March 21, 2007. Mr.
Day was present during the site visit. The site reconnaissance was performed on foot, and the area
reconnaissance was a driving tour on public roads.
5.2 General Site Setting
The subject property is located at 339 Old Lyman Street and currently contains nine separate buildings
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and associated gravel-paved driveways and parking areas (Photographs 1 through 5, Appendix H). Four
of the buildings are currently occupied, as described in Sections 3.6 and 4.4, and the remaining five
buildings are vacant. The surrounding properties contain commercial and industrial businesses. The
Norfolk Southern Railroad tracks are located adjacent to the east property boundary.
5.3 Exterior Observations
MACTEC observed significant debris in the area formerly occupied by Building #7B, presumably from
the flooding that occurred in 2004 (Photograph #6). MACTEC personnel observed approximately 40
five-gallon containers and approximately 80 one-gallon containers that contained water-based paint, oil-
based paint, stain or polyurethane on the loading dock of Building #5 (Photograph #7). MACTEC
observed a petroleum-like stain/seep along the bottom of the western exterior wall of Building #3
(Photograph #8). Mr. Day indicated the location of an underground fuel oil tank in the “courtyard”
between Buildings #1 and #1B (Photograph #9). He indicated that the product was removed in the 1980s,
when the building was converted to natural gas. MACTEC observed piles of salvaged wood in the area
north and west of Building #1A (Photograph #10). Pits, ponds, lagoons, obvious hazardous wastes, or
chemically-stressed vegetation were not observed at the property.
5.4 Interior Observations
MACTEC observed two, apparently empty, 55-gallons with a label indicating “PC-10” solvent/thinner in
Building #1A and #1B (Photograph #11). Adjacent to one of the drums was a sign indicating, “Tank
Cleaned 2/26/04”, suggesting the potential presence of a parts cleaning station in this area. MACTEC
also observed an approximate five-foot deep “vat” in Building #1A (Photograph #12). The vat was empty
at the time of our visit, and Mr. Day indicated that he did not know what it may have been used for in the
past. Mr. Day indicated that Building #1C was formerly used as a wash house by the tannery’s
employees; floor drains were observed along the southern interior wall of Building #1C.
MACTEC observed numerous discarded and crushed automobiles, automobile engine parts, and vehicle
maintenance products in Building #3. Petroleum products such as gasoline, diesel, and lubricants were
observed leaking from automobiles and concentrating on the floor of the facility (Photographs 13 and 14).
Portions of the concrete flooring in Building #3 appeared to be missing and replaced with gravel.
MACTEC observed several drum cradles in Building #8, which was formerly occupied by Ticar
Chemical Company, as discussed in Section 4.4.
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6. INTERVIEWS
6.1 Interview with Owner/Occupant
MACTEC interviewed the property owner Mr. Alton Day regarding the history of the subject property on
March 16 and 21, 2007, as previously discussed.
6.2 Interview with Local Government Officials
MACTEC interviewed Mr. Gary Cornett, the City of Asheville Fire Chief, regarding environmental
incidents requiring a response, on April 3, 2007. Mr. Cornett indicated that records show several reported
responses at 339 Old Lyman Street that are related to fire emergencies. He was not aware of
environmental incidents that have required a response at the subject property.
7. FINDINGS AND OPINION
Based on the findings of our Phase I Environmental Site Assessment at the subject property, we offer the
following comments relative to recognized environmental conditions.
The information reviewed for this project indicates the Hans Rees’ Sons Tannery began operations at the
subject property in 1889. The tanning operation at this facility utilized extracts from the bark of trees to
chemically treat, or tan, the leather hides. A machine shop (Building #8) for servicing a site boiler (in the
area of current Building #3) was noted on the site during the tannery operation. Gasoline tanks and an
‘oil house’ were noted northwest of Building #1 on the 1950 and 1954 Sanborn maps. According to the
deed records obtained in the environmental lien search report, the tannery was sold to C.T. Day in 1955.
Since the property has been owned by C.T. Day and Day’s Warehouses, primarily cattle, tobacco, and
warehousing operation have occurred at the site. Several of the buildings were used for chemical storage
during the 1960s and 1970s, and a vat of unknown purpose is present in Building #1B.
It is MACTEC’s opinion that the past use of the property for chemical storage, as a machine shop, and as
a fitness equipment manufacturer utilizing solvents does constitute a recognized environmental condition.
In addition, the presence of gasoline and heating oil storage tanks and an ‘oil house’ on the property
presents a recognized environmental condition. .
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EDR’s review of regulatory environmental lists revealed 15 listed sites within the search distances
recommended in ASTM E 1527-05. The subject property was not identified on regulatory databases
reviewed for our assessment. The listed sites do not likely constitute recognized adverse environmental
conditions to the subject property, based on distance and direction, or specific information regarding each
site.
The property east of the site has been occupied by a railroad since at least the late 1800s. Historical
railroads are potential sources of contamination with respect to the likelihood of liquid chemical spills and
repetitive operation of equipment. Details of potential contamination resulting from the previous use of
the area east of the site are not known. The adjacent historical railroad is located in a topographically
upgradient direction in relation to the subject property.
With regard to off-site recognized environmental concerns, an EPA policy1 states that “… where
hazardous substances have come to be located on or in a property solely as the result of subsurface
migration in an aquifer from a source or sources outside the property, EPA will not take enforcement
action against the owner of such property to require the performance of response actions or the payment
of response costs.” Hazardous liquids in soil can contaminate downgradient property, when product
releases seep down to the ground-water table and then migrate in the directions of ground-water flow as a
spreading plume. Based upon our past experience in North Carolina, EPA and the state Department of
Environment and Natural Resources holds hazardous waste handling facility owners and operators
responsible for corrective action due to releases from their facility. EPA has stated in its policy1 that
owners of property with contaminated aquifers will not be held responsible for cleanup, if off-site sources
are the cause of contamination and if the property owner has not contributed to the off-site source. If
upgradient potential hazardous waste releases are a concern to the proposed property transaction,
additional information could be acquired by searching for and reviewing technical documents (such as
Contamination Assessment Reports and/or Corrective Action Plans) or performing an invasive
hydrogeological assessment of the subject property.
8. CONCLUSIONS AND RECOMMENDATIONS
We have performed a Phase I Environmental Site Assessment in general accordance with the scope and
limitations of ASTM E 1527-05, for property located at 339 Old Lyman Street in Asheville, North
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Carolina. Any exceptions to or deletions from this practice are described in the appropriate sections of
this report. The property reconnaissance was performed on March 21, 2007. Based on the information
obtained for this project, we offer the following conclusions and recommendations:
• The past use of the property for chemical storage, as a machine shop, and as a fitness equipment
manufacturer utilizing solvents constitutes a recognized environmental condition.
Environmental sampling is recommended in the areas of Building #1/1B, Building 1C, Building
#4, and Building #8.
• The past and current presence of gasoline and heating oil storage tanks, and a former ‘oil house’,
indicates a potential recognized environmental condition. Environmental sampling is
recommended in the area of the heating oil storage tank at Building #1/1B, and in the area of
reported gasoline storage tanks and the oil house northwest of Building #1.
• The current use of the property as an automobile salvage business constitutes a recognized
environmental condition. The area currently being used for the salvage business was also
historically a boiler. Environmental sampling is recommended in the area of Building #3.
• If upgradient, off-site, potential contamination is a concern to the proposed property transaction,
additional information could be acquired by searching for and reviewing technical documents
related to the railroad (such as Contamination Assessment Reports and/or Corrective Action
Plans) or performing an invasive hydrogeological assessment of the subject property along the
topographically upgradient property boundary.
9. DEVIATIONS
A chain-of-title for the property was not provided for this project therefore, MACTEC could not review
written ownership records of the property prior to the provided deed dated 1964. A reference to the
description of the property noted in the 1964 deed indicates the property was sold by Hans Rees Sons,
Inc. to C.T. Day and A.S. Dixon in 1955.
1 60 FR 127, July 3, 1995, Final Policy Toward Owners of Property Containing Contaminated Aquifers and Guidance
on Agreements with Prospective Purchasers of Contaminated Property and Model Prospective Purchaser Agreement.
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APPENDIX A
FIGURES
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APPENDIX B
ENVIRONMENTAL LIEN SEARCH REPORT
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APPENDIX C
PROPERTY RECORD CARD
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APPENDIX D
USER QUESTIONNAIRES AND CORRESPONDANCE RECORDS
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APPENDIX E
REGULATORY SEARCH INFORMATION
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APPENDIX F
AERIAL PHOTOGRAPHS
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APPENDIX G
HISTORICAL INFORMATION
(1939 PAMPHLET, TOPOGRAPHIC MAP, CITY DIRECTORIES,
SANBORN MAPS, and 1967 MAP)
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APPENDIX H
SITE PHOTOGRAPHS
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Photograph 1: View of Building #1 in northern portion of subject property (Building #1B is to the right). View is to the east.
Photograph 2: View of Building #1C in northern portion of subject property. View is to the northwest.
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Photograph 3: View of area between Building #8 (to left in photograph) and Building #3 (to right in photograph.
Photograph 4: View of southern portion of subject property (view is to the south).
Building #6 (Allied Insulation)
Building #7 (vacant) Building #7D
(vacant) Building #3
(EDACO)
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Photograph 5: View of drainage ditch along southern property boundary (view is to the west).
Photograph 6: View of soil with commingled debris on southeastern portion of property that formerly contained Building #7B (Note railroad tracks in the left of photograph).
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Photograph 7: View of paint containers on loading dock on east side of Building #5.
Photograph 8: View of staining/seepage along bottom of exterior wall on west side of Building #3
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Photograph 9: View of fill port and vent pipe (in grassed area) for reported underground heating oil storage tank in ‘center’ of Building #1.
Photograph 10: View of salvaged wood west of Building #1A (view is to the east).
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Photograph 11: View of apparently empty former solvent drum in Building #1.
Photograph 12:View of former vat/pit in Building #1A.
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Photograph 13: View of typical surface staining within Building #3.
Photograph 14: View of typical surface staining within Building #3
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APPENDIX I
PERSONNEL QUALIFICATIONS