NCD003162542_Badin Business Park_Corrective Action_20230629

Badin Business Park LLC 201 Isabella Street Suite 500 Pittsburgh, PA 15212-5858 USA Tel: [phone]
June 29, 2023

Robert C. McDaniel
Hazardous Waste Section
North Carolina Department of Environmental Quality
217 West Jones Street
Raleigh, NC 27699

Re: Clarification to Comments Regarding the Former Ball Field Area Screening–Level
Ecological Risk Assessment
Badin Business Park LLC, Badin, North Carolina
EPA ID: NCD 003 162 542

Dear Mr. McDaniel,

Badin Business Park, LLC (BBP) is seeking clarification on comments received in NCDEQ letter
correspondences dated August 15, 2022 and April 27, 2023. These letters include comments provided by
Toeroek Associates, Inc., the environmental contractor for US EPA Region 4, following their review of
the screening-level ecological risk assessments conducted for the Alcoa/Badin landfill and the former ball
field as well as the work plan for the baseline ecological risk assessment for the Alcoa/Badin landfill.
In Attachment 1 of the August 15, 2022 letter, regarding the “Former Ball Field Area Screening–Level
Ecological Risk Assessment” (April 26, 2021), Toeroek recommends to, “…revise the Scientific
Management Decision Point (SMDP) to conclude that ecological risks are negligible and, therefore,
further investigation or remediation of the site on the basis of ecological risk is not needed.” Toeroek
goes on to explain the basis of this recommendation.
In BBP’s “Response to North Carolina DEQ Comments” letter dated November 14, 2022, BBP
committed to addressing outstanding problem formulation elements to support the determination that no
unacceptable ecological risk is present at the Former Ball Field that would require further investigation or
remediation.
Subsequently, in the April 27, 2023 letter DEQ writes there are no further comments on the “Former Ball
Field Screening-Level Ecological Risk Assessment”. It is unclear whether DEQ considers the existing
submittal sufficient following the assessment by Toeroek or is concurring with BBP’s plan to submit a
revised submittal. Please advise on whether DEQ is expecting a revised submittal modifying the
conclusions to the former ball field area screening–level ecological risk assessment.
Respectfully,

Jason G. Mibroda
Remediation Project Manager