IH2599_20231027_REC Eligibility

October 27, 2023

Ms. Martha C. Bell, President
Ticar Chemical Co., Inc.
32 Martindale Road
Asheville, NC 28804

Re: NOTICE OF REC PROGRAM ELIGIBILITY
TICAR CHEMICAL CO
32 Old Brevard Road
Asheville, Buncombe County, NC
Site ID: NONCD0002599

Dear Ms. Bell,

The North Carolina Department of Environmental Quality (DEQ), Division of Waste Management
(Division), Inactive Hazardous Site Branch (IHSB or Branch), is contacting you regarding the
Inactive Hazardous Site at the above referenced location (Site). The Division is seeking Ticar
Chemical Co., Inc.’s continued cooperation to remediate the Site and address the potential risk
to future occupants of the building on-site. The Division is notifying Ticar Chemical Co., Inc., that
the Site is eligible for assessment and remedial action through the Registered Environmental
Consultant (REC) Program without direct oversight by Division staff.

High concentrations of Site-related vapors measured in sub-slab soil-gas data suggest a source of
solvent-affected soil exists under the southeast corner of the building. The current human health
risk, to occupants, has been demonstrated to be acceptable but changes to the existing structure,
or lack of maintenance of the concrete floor slab, may allow potential harmful vapors to enter
the building. Should this occur, it could pose a health-risk to future building occupants.

Previous studies at the site have documented limited air permeability under the building’s
concrete floor slab. Engineered controls used to reduce the vapor intrusion risk would likely be
ineffective and/or cost prohibitive. If proven to exist, source removal could be the most effective
long-term remedy to potential human health risk and would also serve to improve groundwater
conditions.

Regardless of participation in the REC Program, if the source of vapors is not removed, the
following measures should be taken, at a minimum, to continue protecting human health for the
building occupants and construction workers:
Ms. Bell
October 27, 2023

• Sealing seams and cracks in the building concrete floor slab.
• Implementing a Site Management Plan that includes engineering and institutional
controls, including but not limited to:
o Routine inspection and maintenance of the building concrete floor slab.
o Limiting construction or remodeling of the building that would disturb the slab.
o Limiting access to affected soil and requiring personal protective equipment if soil
must be accessed.
o Routine monitoring of indoor air to ensure the safety of building occupants.

Registered Environmental Consultant Program
North Carolina established the Registered Environmental Consultant (REC) program in 1997 to
privatize the oversight and remediation of sites such as this. Benefits of the REC-program can
include expediency, as well as lower-cost site closures through use of site-specific risk-based
remedial standards with land-use controls. Please note, off-site properties have been affected by
site-related constituents and owners of those properties are required to agree to institutional
controls (deed restrictions) on their property should Ticar Chemical Co. Inc., pursue a Risk Based
remedial closure strategy.

An owner, property owner, operator, or other responsible party can enter into an REC
administrative agreement (AA) with the Branch and hire a private environmental consulting or
engineering firm approved by the Division to implement and oversee assessment and remedial
action. Should you have any questions regarding the REC Program and procedures, please contact
Dianne Thomas at [phone] or visit the REC Program website at:
http://www.deq.nc.gov/about/divisions/waste-management/superfund-section/inactive-
hazardous-sites-program/registered-environmental-consultant-program.

Ticar Chemical Co. Inc., may also perform assessment and remedial action independently and
request a no-further-action (NFA) review from the Branch when remedial action standards for
unrestricted [residential] use are met. Parties conducting cleanups in this manner are not eligible
for less stringent, risk-based remedial standards, nor the statutory cap of remedial action
expenses. Please note, document submittal(s) to the Branch is required per North Carolina
General Statutes (NCGS) § 130A-310.1(b). Since independent cleanups do not receive direct
Branch oversight and approval throughout the process, remedial activities should be performed
in accordance with the most recent version of the Branch’s Guidelines for Assessment and
Cleanup of Contaminated Sites found here:
http://www.deq.nc.gov/about/divisions/waste-management/program-guidance/inactive-
hazardous-sites-guidance-documents

The IHSB appreciates the remedial efforts Ticar Chemical Co., Inc., has completed to date. Further
addressing the Site in the REC Program may allow safe use of the property into the future with
effective risk-management and long-term protection of human health. The IHSB is requesting a
written response in 30-days.

Ms. Bell
October 27, 2023

If you have questions about the requirements that apply to your site, please contact me at (828)
767-2424 or via email at [e-mail]

Sincerely,

Brett Engard
Hydrogeologist
Inactive Hazardous Sites Branch

c.c. Mr. William Clarke, Roberts & Stevens, P.A., [e-mail]
Dianne Thomas, NCDEQ REC Program, Environmental Program Consultant