Carolina Coatings Incorporated Variances (GW Inciedent 8949) variance completion file V7

RE: EMC MEETING DEC. 9TH/CAROLINA COATINGS VARIANCE REQUEST
j
Subject: RE: EMC MEETING DEC. 9TWCAROLINA COATINGS VARIAN CE
REQUEST
Date: Fri, 03 Dec 1999 15:13:33 -0500
From: David Hance <[e-mail]>
Reply-To: DENR
Organization: Groundwater Section
To: ART BARNHARDT <[e-mail]>,
Matt Heller <[e-mail]>
CC: Arthur Mouberry <[e-mail]>,
CARL BAILEY <[e-mail]>,
DAVID HANCE <DAVID.HANCE@ncmaiLnet>,
BARBARA CHRISTIAN <[e-mail]>
HELLO GENTLEMEN:
Just sending an e-mail to remind you both (Art and Matt) that the
Environmental Management Commission will hold its meeting on December 9,
1999 in the Archdale Building Ground Floor Hearing Room at 9:00 A.M ..
One of the agenda i terns i .s the FINAL DECISION ON THE CAROLINA COATINGS
VARIANCE REQUEST.
It is requested that the hearing officer attend this meeting to
answer any questions on the hearing officers report that may posed by
Commission members. It. is also requested that technical staff in the MRO
(i.e. Matt Heller) attend to respond to any technical questions that may
come .up about this site .
I can be reached at 919-715-6189 if we need to talk.
dh
12/3/1999 3:13 PM
re: carolina coatings variance/emc final action in 12/99
1 of 1
Subject: re: caroiina coatings variance/emc final action in 12/99
Date: Wed, 10 Nov 1999 11 :34:10 -0500
From: David Hance <[e-mail]>
Reply-To: DENR
Organization: Groundwater Section
To: ART BARNHARDT <[e-mail]>,
Matt Heller <[e-mail]>
CC: DAVID HANCE <DA [e-mail]>,
CARL BAILEY <[e-mail]>,
Arthur Mouberry <[e-mail]>,
BARBARA CHRISTIAN <[e-mail]>
HELLO ART AND MATT:
THE HEARING OFFICERS REPORT FOR THE CAROLINA COATINGS VARIANCE
REQUEST IN CHARLOTTE NC WAS APPROVED TO GO TO THE FULL COMMISSION BACK
IN OCTOBER BY THE GROUNDWATER COMMITTEE.
THE FULL ENVIRONMENTAL MANAGEMENT COMMISSION WILL TAKE UP THIS ISSUE
AT IT'S DECEMBER 9, 1999 MEETING IN RALEIGH, NC. THIS MEETING rs
SCHEDULED FOR 9:00 A.M. IN THE ARCHDALE BUILDING ON THAT DATE.
IT IS REQUESTED THAT THE HEARING OFFICER AND THE TECHNICAL STAFF
INVOLVED WITH THIS VARIANCE ATTEND THIS MEETING. IF YOU HAVE QUESTIONS
PLEASE CONTACT ME AT 919-715-6189.
DH
11/10/1999 12:59 PM
(
DIVISION OF WATER QUALITY
GROUNDWATER SECTION
September 27, 1999
MEMORANDUM
TO: Kerr T. Stevens, Director,
Division of Water Quality
THROUGH: Greg Thorpe, Deputy Director
Division of Water Quality
THROUGH: Arthur Mouberry, P.E., Chief,
Groundwater Section
FROM: Art Barnhardt, Groundwater Supervisor,
Fayetteville Regional Office
SUBJECT: Hearing Officer's Report and Recommendations
Variance Request from 15A NCAC 2L .0202 and .0106(j)
Carolina Coatings Incorporated Property
711 Pressley Road
Charlotte, NC/ Mecklenburg County
(Groundwater Incident# 8949)
In accordance with your memorandum dated July 13, 1999, a Public Hearing was held on
August 12, 1999 at 7:00 P.M. in the Criminal Courts Building of the Mecklenburg County
Courthouse in Charlotte, North Carolina. I served as the hearing officer and a summary of the public
hearing and my recommendations are attached for your consideration.
The issue concerns whether the Environmental Management Commission (EMC) should
approve or deny a request for a variance of the Groundwater Quality Standards in Title 15A North
Carolina Administrative Code (NCAC) Subchapter 2L .0202 (15A NCAC 2L .0202) and 15A
NCAC 2L .0106(j). Such a variance may be granted by the EMC under the authority of North
Carolina General Statute (NCGS) 143-215.3(e). The procedures for application and for public
notification found in 15A NCAC 2L .0113 have been followed for this request.
Also attached for your review and consideration are those documents considered relevant to
this request including a summary of background information.
If you have any questions, please do not hesitate to call.
1
..
PUBLIC NOTICE AND PUBLIC HEARING
On July 9, 1999 public notice was issued advising interested parties that a hearing on the
variance request for Carolina Coatings Incorporated was scheduled for August 12, 1999 (Attachment
1 ). Notice of this variance request was sent to local government officials and the Mecklenburg
County Health Director pursuant to the 15A NCAC 2L .0113 rule. Individual notices were sent per
requirements of title 15A NCAC 2L .0113 to sixteen adjacent property owners and area property
owners identified by Carolina Coatings Incorporated in the variance request. Approximately 130
notices were sent to the public at large consisting of persons listed in the Groundwater Section's
Mailing List. Corporations, environmental groups, firms, government agencies, partnerships, and
individuals were sent a copy of the notice and are those persons who have expressed an interest in
regulatory actions that require a public hearing. Most of these persons reside or work in the
Charlotte Metropolitan Area. A copy of the notice was also published in The Charlotte Observer
on July 11, 1999.
The public hearing was conducted as scheduled. The Division was represented by four staff
members:
Art Barnhardt
Matt Heller
Shawna Caldwell
Randy Prillaman
Hearing Officer (Fayetteville Regional Office)
Mooresville Regional Office
Mooresville Regional Office
Recorder (Central Office)
The hearing was attended by five citizens consisting of adjacent property owners and o\,ner
representatives. One person had verbal comments. Opening remarks were given by me, followed
by the staff presentation by Matt Heller (Attachment 2). Verbal and written comments from
interested parties were received during the hearing and prior to the closing of the hearing record on
September 13, 1999 and are paraphrased below. Written comments are included as (Attachment 3)
Verbal Comments durim~ hearing by:
Joe Garmon and he stated that he owned property adjacent to the Carolina Coatings Site and at the
time the variance is granted, is Carolina Coatings relieved of all responsibility?
Written comments were submitted bv:
Jack Smith ofMetrolina Landscape Company which stated (1 )that they were unsure of what they
could or should do about this variance request, (2)wanted the right environmental thing done,
(3)wanted to be protected from devaluation of property due to contamination issues (4) asked for
a staff person to contact him and discuss the situation with him as opposed to having to hire a
consultant/lawyer.
2
Meredith Stover, agent for John Layne-Adjacent Property Owner which (1 )stated his concerns
of contaminates migrating onto Mr. Layne's property (2) wanted relief and protection of any clean-
up that would be required (3) Mr. Layne was not opposed to the variance request but wanted a
written response on his regulatory responsibility if contamination migrated onto his property.
DISCUSSION/RECOMMENDATION
Attachment # 4 consists of the important memoranda related to this variance request. The
June 24, 1999 memoranda discusses the variance in light of the requirements of 15A NCAC 2L
.0113 and provides detailed information about this site. The two issues before the Environmental
Management Commission (EMC) are whether to grant a variance from the Groundwater Quality
Standards for Benzene as found in NCAC 2L .0202 and a variance from the requirement to continue
to implement a corrective action plan using the best available technology as required by 15A NCAC
2L .0106 (j).
A total of $493,000 has been expended to clean-up this site, none of which was reimbursed
through any type of trust fund. This included 2,400 cubic yards of contaminated soil removed to the
extent practicable and groundwater extraction and treatment of an estimated 328,500 gallons of
affected groundwater. Carolina Coatings has submitted supporting information demonstrating that
continued operation of best available technology will not result in significant long term remediation
of the site to the groundwater quality standards in 15A NCAC 2L .0202 and contend that continued
operation of the existing system will be a serious financial burden without equal or greater public
benefit. The annual cost to operate the groundwater remediation system is projected to be $48,000.
Notable factors about ground water quality/flow characteristics and remediation
to date:
-The affected area of ground water impact was estimated to be 10,000 square feet (surface
area) and less than 45 feet (vertically) pelow ground surface at the beginning of remedial
efforts. As of the last sampling event, only one monitoring well contained contamination
above the title 15A NCAC 2L .0202 Groundwater Quality Standard for Benzene. ( Note the
concentration observed for Benzene was at 2 parts per billion [ppb] which has a s_tandard of
1 parts per billion [ppb]).
-At the last sampling event, the recovery well was not collecting ground water with
detectable concentrations of any of the target compounds.
-The ground water flow velocity at this hydrogeologic setting has been estimated to
be on the order of 1.1 feet per year. Using this rate of movement, it would take 100 years
for ground water to migrate from the source area to the property/variance boundary.
-At present there is no indication that contaminates have reached the fractured bedrock
portion of the aquifer in this area.
3
Based upon all information collected to date, the limited extent of contamination, the ability
of the contaminants to attenuate, the extremely low probability of any off-site impacts and the
financial burden of continued remediation without significant environmental improvement, it is my
recommendation that the EMC consider granting the variance request without further monitoring
requirements.
The following is a listing of attachments for the hearing officer's report submitted for the
Carolina Coatings Incorporated variance request:
Attachment # 1 -Public Notice
Attachment# 2 -Mooresville Regional Office Staff Presentation and Hearing Registrations
Attachment # 3 -Written Comments
Attachment # 4 -Memoranda Related to the Variance Request for Carolina Coatings
Incorporated
4
Attachment # 1 -PUBLIC NOTICE
. . .,,
... ,_ -fNOTICE OF VARIANCE APPLICATION AND HEARING
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
Notfce is hereby given ofa variance application and public hearing to be held by the Department of
Environment and Natural Resources on behalf of the Environmental Management Commission. The hearing
concerns a request for a variance from the Groundwater Quality Standards of 15A NCAC 2L .0202 and the
Corrective Action requirements ofl5ANCAC 2L .0106 G) fora site at 711 Pressley Road in Charlotte, North
Carolina. The Division of Water Quality refers to this site identi~ed in the variance request as Groundwater
Incident# 8949. This property consists of 6.17 acres of land was previously owned by the proprietor of
Carolina Coatings Incorporated, Mr. Linwood Carter, and was used as a solvent-based paint mixing facility
until 1991. The property is now owned by Wattyl Paints of Atlanta, Georgia. Carolina Coatings Incorporated
is entirely responsible for cleanup for Groundwater Incident# 8949. This variance application from Carolina
Coatings Incorporate~ was received for review by the Department on December 9, 1996.
The property where the release of volatile organic substances has occurred is located as follows: Inside
the city limits of Charlotte, North Carolina. Take Interstate 77 in Charlotte and exit onto South Tryon Street
(NC 49) and proceed one block north. Tum left (west) onto Pressley Road for 0.38 miles. The former
Carolina Coatings facility is located on the left. The site is listed in Mecklenburg County ta.x records as
Parcel Number 145-291-03.
Carolina Coatings Incorporated requests that the Environmental Management Commission grant the
following variance to its rules under the authority of 15A NCAC 2L .0113 so that i(does the following:
(1) Allow concentratio'ns of Benzene, Ethylbenzene, and Xylene (-o,-m, and p) to remain at levels
above 15A NCAC 2L .0202 Groundwater Quality Standards as analyzed on October 9, 1997 in all
monitoring wells. These concentrations will be required to remain within the property boundaries of
711 Pressley Road. Pursuant to the transfer of ownership of this property in 1991, Mr. Carter had
environmental assessments conducted of soils and groundwater at this site. Benzene, Ethylbenzene,
Toluene and Xylene (BETX) were found in soils around this site and groundwate~ samples showed
the presence of several volatile organic compounds such as Benzene, Ethylbenzene and Xylene.
Since the transfer of ownership of this property to Wattyl Paints all solvent-based paint mixing
operations have ceased and were moved to Atlanta, Georgia. Only latex water-based paint mixing has
been conducted at this property since 199 i. All potential sources of groundwater contamination have
been identified at this property by Carolina Coatings Incorporated. The entire property at 711
Pressley Road is located in an area with a mixture of commercial, industrial, and residential
development.
Site assessments were completed by September 1992 and a remedial action plans for this site
were submitted in late spring 1993. The site assessments revealed a plume of substances in soil and
groundwater. Site assessment information on file in the Mooresville Regional Office shows that the
vertical extent of this plume to be less than 48 feet below the ground surface. This plume was
estimated to have covered an area of approximately 10,000 square feet (0.23 acres) prior to the
implementation of corrective actions by Carolina Coatings Incorporated.
From June 2, 1993 through January 1997 concentrations of substances at this site were
significantly reduced by soil removal operations and groundwater cle:mup technologies located at the
site. A concrete pad and waste water settling tan.ks were removed during this renovation and clean
l
Attachment # 2 -MOORESVILLE REGIONAL
OFFICE STAFF PRESENTATION AND
HEARING REGISTRATIONS
AS A VISUAL AID, I HA VE PROVIDED COPIES OF TWO SITE MAPS. THE FIRST MAP
SHOWS THE SITE IN RELATION TO THE SURROUNDING AREA. THE SECOND MAP
SHOWS THE SITE IN DETAIL AND THE LOCATIONS OF GROUNDWATER MONITORING
WELLS.
I WOULD LIKE TO BEGIN BY SUMMARIZING THE HISTORY OF THE CONTAMINATION
AT THIS SITE:
IN 1991 AND 1992, SOIL AND GROUNDWATER SAMPLES WERE COLLECTED FROM THE
CAROLINA COATINGS PROPERTY LOCATED AT 711 PRESSLEY ROAD IN CHARLOTTE.
SAMPLES COLLECTED NEAR A CONCRETE PAD AREA BEHIND THE CAROLINA
COATINGS WAREHOUSE BUILDING WERE FOUND TO CONTAIN ETHYLBENZENE,
BENZENE AND XYLENE. THESE ARE ALL PETROLEUM COMPOUNDS.
BASED ON THE ANALYTICAL RESULTS OF THIS SAMPLING, APPROXIMATELY 850
CUBIC YARDS OF SOILWERE DETERMINED TO BE CONTAMINATED. IN ADDITION,
SHALLOW GROUNDWATER UNDERNEATH APPROXIMATELY 1/4 OF AN ACRE AT THE
SITE CONTAINED BENZENE, ETHYLBENZENE AND XYLENE AT CONCENTRATIONS
ABOVE THE NORTH CAROLINA GROUNDWATER STANDARDS.
IN MARCH OF 1993, THE GROUNDWATER SECTION RECEIVED A COMPLETE
REMEDIAL ACTION PLAN FOR CONTAMINATED SOIL AND GROUNDWATER AT THE
SITE. THE REMEDIAL ACTION PLAN CALLED FOR THE EXCAVATION OF ALL OF THE
CONTAMINATED SOIL ON THE PROPERTY AND THE TRANSPORT OF THIS SOIL TO A
PERMITTED SOIL REMEDIATION FACILITY. IN ADDITION, THE PLAN PROPOSED TO
PUMP CONTAMINATED GROUNDWATER TO THE SURFACE, TREAT IT USING A
CARBON FILTER, AND REINTRODUCE IT TO THE GROUND.
IN MAY OF 1993, APPROXIMATELY 1500 CUBIC YARDS OF SOIL WAS EXCAVATED
FROM THE SITE AND TRANSPORTED TO THE CAROLINA STALITE THERMAL
TREATMENT FACILITY. AFTER BACKFILLING THE EXCAVATION, A GROUNDWATER
RECOVERY WELL AND A GROUNDWATER MONITOR WELL WERE INSTALLED IN
ORDER TO TREAT THE CONTAMINATED GROUNDWATER.
IN MARCH OF 1994, THE GROUNDWATER PUMP AND TREATMENT SYSTEM BEGAN
OPERATING. THE PUMP AND TREATMENT SYSTEM CONTINUED TO OPERATE UNTIL
JANUARY OF 1997. DURING THAT TIME PERIOD, MORE THAN 328,000 GALLONS OF
GROUNDWATER WERE TREATED.
BETWEEN MARCH OF 1994 AND MARCH OF 1997. THREE MONITOR WELLS WERE
SAMPLED ON A QUARTERLY BASIS TO DETERMINE GROUNDWATER QUALITY.
DURING THIS PERIOD OF MONITORING, BENZENE, ETHYLBENZENE AND XYLENES
WERE DETECTED IN ONLY ONE WELL, MONITOR WELL #9.
THE MAXIMUM CONCENTRATION OF BENZENE DETECTED IN MONITOR WELL #9
BETWEEN MARCH OF 1994 AND MARCH OF 1997 WAS 27 MICROGRAMS PER LITER.
BENZENE WAS NOT DETECTED IN MONITOR WELL #9 DURING THE LAST
QUARTERLY SAMPLING EVENT IN MARCH OF 1997.
THE MAXIMUM CONCENTRATION OF ETHYLBENZENE DETECTED IN MONITOR WELL
#9 BETWEEN MARCH OF 1994 AND MARCH OF 1997 WAS 32 MICROGRAMS PER LITER.
ETHYLBENZENE WAS NOT DETECTED IN MONITOR WELL #9 DURING THE LAST
QUARTERLY SAMPLING EVENT IN MARCH OF 1997.
THE MAXIMUM CONCENTRATION OF XYLENE DETECTED IN MONTI OR WELL #9
BETWEEN MARCH OF 1994 AND MARCH OF 1997 WAS 860 MICROGRAMS PER LITER.
XYLENE WAS NOT DETECTED IN MONITOR WELL #9 DURING THE LAST QUARTERLY
SAMPLING EVENT IN MARCH OF 1997.
IN JANUARY OF 1997, THE GROUNDWATER SECTION ALLOWED THE GROUNDWATER
PUMP AND TREAT SYSTEM TO BE TURNED OFF BECAUSE THE EXISTING
GROUNDWATER PUMP AND TREAT SYSTEM COULD NOT ADDRESS THE REMAINING
LOW LEVELS OF GROUNDWATER CONTAMINATION.
IN OCTOBER OF 1997, FIVE MONITOR WELLS AT THE SITE WERE SAMPLED. THE
ONLY PETROLEUM COMPOUND DETECTED IN THE WELLS WAS BENZENE. BENZENE
WAS ONLY DETECTED IN MONITOR WELL #9. THE CONCENTRATION OF BENZENE
AT THE TIME OF SAMPLING WAS 2 MICROGRAMS PER LITER. THE NORTH CAROLINA . .
GROUNDWATER STANDARD FOR BENZENE IS 1 MICROGRAMS PER LITER.
NOW I WOULD LIKE TO SUMMARIZE THE VARIAN CE REQUEST:
CAROLINA COATINGS INCORPORATED IS REQUESTING A VARIANCE TO THE
GROUNDWATER STANDARDS FOR BENZENE, ETHYLBENZENE AND XYLENE FOR THE
PROPERTY AT 711 PRESSLEY ROAD. THE NORTH CAROLINA GROUNDWATER
STANDARD FOR BENZENE IS 1 MICROGRAM PER LITER AND THE MOST RECENT
ANALYTICAL RESULTS INDICATE THAT BENZENE IS PRESENT IN GROUNDWATER
ON THE PROPERTY AT 2 MICROGRAMS PER LITER. THE NORTH CAROLINA
GROUNDWATER STANDARD FOR ETHYLBENZENE IS 29 MICROGRAMS PER LITER
AND THE MOST RECENT ANALYTICAL RESULTS INDICATE THAT ETHYLBENZENE IS
NOT PRESENT IN GROUNDWATER ON THE PROPERTY. THE NORTH CAROLINA
GROUNDWATER STANDARD FOR XYLENE IS 530 MICROGRAMS PER LITER AND THE
MOST RECENT ANALYTICAL RESULTS INDICATE THAT XYLENE IS NOT PRESENT IN
GROUNDWATER ON THE PROPERTY.
I HA VE COMPLETED A REVIEW OF THE INFORMATION IN THE VARIANCE AND THE
GROUNDWATER SECTION'S FILE FOR THIS INCIDENT. BASED ON MY REVIEW, I
BELIEVE THAT THE FOLLOWING STATEMENTS MADE IN THE VARIANCE REQUEST
ARE ACCURATE AND SHOULD BE CONSIDERED :
1) THERE ARE NO WATER SUPPLY WELLS WITHIN 2000 FEET OF THE AREA OF
REMAINING GROUNDWATER CONTAMINATION.
2) THE CLOSEST SURF ACE WATER BODIES TO THE REMAINING CONTAMINATION
ARE TWO INTERMITTENT TRIBUTARIES TO SUGAR CREEK. THESE INTERMITT ANT
TRIBUTARIES ARE APPROXIMATELY 1,100 FEET FROM THE AREA OF GROUNDWATER
CONTAMINATION.
3) THERE ARE NO ON-SITE EXPOSURE PATHWAYS FOR THE CONTAMINATED
GROUNDWATER.
4) COMPUTER MODELING INDICATES THAT THE GROUNDWATER CONTAMINATION
WILL NOT AFFECT ADJACENT PROPERTIES.
5) THE EXISTING PUMP AND TREAT SYSTEM WOULD REQUIRE MODIFICATION IN
ORDER TO BE ABLE TO ADDRESS THE REMAINING LOW LEVELS OF PETROLEUM
COMPOUNDS.
6) NO OTHER CURRENTLY AVAILABLE TECHNOLOGIES COULD BETTER ADDRESS
THE REMAINING CONTAMINATION.
7) 493,000 DOLLARS HA VE BEEN SPENT ADDRESSING THE CONT AMINA TI ON AT THIS
SITE. IT WOULD COST 48,000 DOLLARS PER YEAR TO CONTINUE TO OPERA TE THE
SYSTEM, NOT INCLUDING THE COST OF SYSTEM MODIFICATIONS.
8) GROUNDWATER INFLUENT INTO THE TREATMENT SYSTEM HAS DECREASED TO
LESS THAN ANALYTICAL DETECTION LIMITS.
9) THE AREA OF REMAINING SHALLOW GROUNDWATER CONTAMINATION IS
ESTIMATED TO BE LESS THAN 1/4 ACRE IN EXTENT.
10) THE REMAINING CONTAMINANTS HA VE THE CAPACITY TO DEGRADE AND
ATTENUATE.
Attachment # 3 -WRITTEN COMMENTS
SALE
Stoever Properties, Inc.
704-333-9483
August 17, 1999
Mr. David Hance
EHNR -DWQ -Groundwater Sec.
P.O. Box 29578
Raleigh, NC 27626-0578
Re: 711 Pressley Road #8949
Charlotte, NC
Dear Mr. Hance:
LEASE
I went to your meeting in Charlotte, and unfortunately they could not get the
recorder to work and I left after 30 minutes.
DEVELOPMENT
Mr. Layne, owner of 801 Pressley Road, has reviewed your request for a variance,
and we do not see any reason to oppose this. Mr. Layne's one concern is: Whose
responsibility is it if any of the solvent leeched on to his property? Please give us
an answer to this by the end of August.
Sincerely,
Meredith D. Stoever
cc: Mr. Linwood Carter
605 Hermitage Court• Charlotte, NC 28207
Fax [phone]
Attachment #4 -Memoranda Related to the
Variance Request for Carolina Coatings
Incorporated
SALE
-Stoever Properties, Inc.
704-333-9483
July 29, 1999
Mr. David Hance
ENHR -DWG -Groundwater Section
P.O. Box 29578
Raleigh, NC 27626-0578
Re: 711 Pressley Road
Charlotte, NC
Dear Mr. Hance:
LEASE DEVELOPMENT
Mr. Layne has passed along the letter of July 7, 1999 from Mr. M. Carl Bailey, Jr.
in regard to the above referenced property.
Mr. Layne is concerned about his protection in the case of any leaking of
chemicals from 711 Pressley Road to 801 Pressley Road. He would want relief
from any problems as well as monetary protection and guarantee of any clean-up
required by Wattyl Paints of Atlanta, GA
Mr. Layne is also requesting a plat of the property indicating where the
monitoring wells are located.
Sincerely,
. Stoever
Agent for Mr. Layne
cc: Mr. John W. Layne
605 Hermitage Court • Charlotte, NC 28207
Fax [phone]
DIVISION OF WATER QUALITY
GROUNDWATER SECTION
June 24, 1999
MEMORANDUM
To: Kerr T. Stevens
From: Arthur Mouberry #
Subject: Request for Variance from 15A NCAC 2L .0202 and 15A
NCAC 2L .0106(j) for a Site Owned by the Carolina Coatings Incorporated at 711
Pressley Road in Charlotte, North Carolina (Groundwater Incident Number
8949).
From 1971 through 1991, Mr. Linwood Carter operated a portion of the Carolina
Coatings Incorporated property as a paint blending facility located at 711 Pressley Road in
Charlotte, North Carolina. This site is at the intersection of Billy Graham Parkway and US
Interstate 77. In 1991, Mr. Carter sold this facility to Wattyl Paints of Atlanta, Georgia. The
new owner of this facility moved all solvent based mixing processes out of North Carolina 1991.
Mr. Carter maintains cleanup responsibilities for substances found at this site .
The Carolina Coatings facility consists of a total of 47,000 square feet of warehouse and
office space on 6.17 acres of land. During the period this property was owned by Mr. Carter,
Carolina Coatings manufactured paint using a batch mixing process which blended latex
emulsions with dry pigments, wetting agents, water, defoamers and other ingredients. This
process required the storage of empty fifty-five gallon drums on a concrete pad located rear of
the building. Waste water settling tanks were also located in this area. During the course of
business operations leaks had occurred in dmms located at this site and from the wastewater
settling ponds.
Pursuant to the transfer of ownership of this property in 1991, Mr. Carter had
environmental assessments conducted of soils and groundwater at this site . Ethylbenzene,
Toluene and Xylene were found in soils around this site. Analysis of groundwater samples
showed the presence of several volatile organic compounds, Benzene, Ethylbenzene, Toluene
and Xylene. Since 1991 only latex water-based, products have been processed at 711 Pressley
Road by Wattyl Paints. The owner of Carolina Coatings Incorporated, Mr. Linwood Carter, is
entirely responsible for cleanup of this release which is shown in Division of Environmental
Management files as Groundwater Incident Number 8949.
1
Pursuant to title 15A NCAC 2L .0113(c) variance applications are required to have
specific information in order to adequately review a request. The Carolina Coatings variance
request is contained in a report titled "Variance Request -Carolina Coatin Qs Site -Charlotte .
North Carolina. December 9; 1996 , Dames and Moore N .C. Job No .23995-002-200.". In
addition, memoranda and other correspondence are included with this request. The information
submitted by Dames and Moore on behalf of the Carolina Coating Incorporated appears to meet
the requirements of 15A NCAC 2L .0113(c) and is summarized as follows:
Rule .0113 (c)(I): Resolution b y the County or governin g Board:
Carolina Coatings Incorporated has always been a privately owned
company. No resolution is necessary.
Rule .0113 (c)(2): A descri ption of past. existing or pro posed activities that would result in a
dischar ge of contaminants into groundwater:
The former Carolina Coatings Incorporated is located inside the city limits of
Charlotte, North Carolina at 711 Pressley Road (Mecklenburg County Tax
Identification Number 145-291-03). The report titled "Variance Request -Carolina
Coatin ~s Site -Charlotte. North Carolina. December 9 , 1996, Dames and Moore
N.C. Job No.23995-002-200" contains the relevant information about this site. The
site consists of approximately 6.17 acres of land.
A Notice of Violation was issued to Carolina Coatings Incorporated by the
Department on August 28, 1992. Remedial Action Plans were submitted to the
Mooresville Regional Office on June 29, 1992 and March 23, 1993. On January 18,
1994, a discharge permit for an on-site infiltration gallery was authorized by the
Division of Water Quality (WQ0007993). Details of soil and groundwater corrective
actions are documented in a report titled "Soil and Groundwater Remediation
Report (April 19, 1994)" at the Mooresville Regional Office. All potential sources
of groundwater contamination were identified at this property by the company.
This property at 711 Pressley Road in Charlotte, North Carolina, formerly owned
by Mr. Linwood Carter, and is in an area with a mixture of commercial, industrial,
and residential development.
The comprehensive site assessment and other investigations revealed
Benzene, Toluene, Ethylbenzene, and Xylene (o, m, and p) (BETX) in the
groundwater and soil beneath the site. This area was located at the southwest
corner of the building near an 88 foot by 66 foot concrete pad and three small
wastewater settling tanks. This was where the company stored chemicals and
performed batched mixing operations for solvent-based paints. This area is
2
approximately 10 feet from the northwest property line and 75 feet from the
southwest property line. The entire property at 711 Pressley Road is surrounded
by a fence. This plume was estimated to have covered an area of approximately
10,000 square feet (0.23 acers) prior to the implementation of correctiv~ actions by
the Carolina Coatings Incorporated. According to information at the Mooresville
Regional Office the vertical extent of this plume is believed to be less than 48 feet
below the ground surface.
Carolina Coatings Incorporated implemented cleanup of soils at this site in
September 1992 with the removal of 900 cubic yards of soil that exceeded the 50
milligram per kilogram target cleanup level. Between June 2, 1993 and June 25,
1993, the company removed an additional 1,500 cubic yards of contaminated soils.
Excavated soils were treated offsite and clean fill material was used as backfill. As a
result of soil remediation, the concrete pad was removed and subsequently replaced.
In July 1993 the company installed a pump-and-treat system with a single
groundwater recovery well (RW-1) located near the south corner of the former
concrete storage pad as shown in Figure 6 of the variance. From March 23, 1994
through January 1997 a total of 328,500 gallons of groundwater bas been treated via
pump-and-treat technology. The treated discharge was sent to an upgraident
infiltration gallery. An infiltration gallery is a closed-loop conveyance that allows
water and other fluids, discharged through the pump-and-treat system, to be sent
back into the subsurface where they recirculated into the cleanup system for
continual treatment. An infiltration gallery may also serve to enhance intrinsic
biodegradation of contaminants by introducing dissolved oxygen in the subsurface
which may stimulate biologic decomposition of some dissolved substances. Non-
Discharge Permit WQ0007993 was issued on January 18, 1994 for the infiltration
gallery. The Groundwater Section staff have recommended that, if the variance
request is granted, no permit for this infiltration gallery is to be reissued. The
company's environmental consultant, Dames and Moore, reports that this device
will no longer be used once the variance is granted.
The Division of Water Quality required Carolina Coatings Incorporated to
perform groundwater monitoring to determine the vertical and lateral extent of
contamination at the site. Table 2 of the report titled "Variance Request -Carolina
co-atings Site -Charlotte, North Carolina. December 9, 1996, Dames and Moore
N.C. Job No.23995-002-200" shows that three of six monitoring wells were sampled
from March 1994 through September 1996 on a quarterly schedule. Groundwater
samples were analyzed using US Environmental Protection Method 8020. Page 6 of
the variance request shows that only Monitoring Well# 9 has had concentrations of
Benzene, Ethylbenzene, and Xylene above the Groundwater Quality Standards in
15A NCAC 2L .0202. Toluene has never appeared in any of the monitoring wells at
a concentration in excess of the Groundwater Quality Standard in 15A NCAC 2L
.0202. Table 2 of the report titled "Variance Request -Carolina Coatine:s Site -
Charlotte, North Carolina, December 9, 1996. Dames and Moore N.C. Job
No.23995-002-200" shows that the highest concentration of Benzene, Ethylbenzene,
and Xylene have been found in this well. The highest concentration of Benzene in
exceedence of the Groundwater Quality Standard was 0.027 milligrams per liter or
3
27 micrograms on September 3, 1996. The highest concentration of any substance
in exceedence of the 15A NCAC 2L .0202 Groundwater Quality Standard found at
this site was Xylene (o,p,m). Xylene appeared at the December 1994 monitoring
event at 0.860 milligrams per Liter or 860 micrograms/Liter.
As shown on Table 1 of the report titled "Variance Request -Carolina
Coatings Site -Charlotte, North Carolina, December 9, 1996, Dames and Moore
N.C. Job No.23995-002-200"from March 29, 1994 through October 30, 1996, the
company conducted analysis of samples from Recovery Well# 1 on the influent side
of the cleanup system to determine the effectiveness of the pump-and-treat cleanup.
This data shows that the source of the groundwater contamination at this site has
been significantly reduced such that the plume can no longer be detected.
Based on the results of the groundwater monitoring and recovery well
monitoring in September and October 1996, the Carolina Coatings reqµested a
variance and that the pump and treat groimdwatercleanup system be shut off. In
January 1997 the Mooresville Regional Office agreed that active cleanup should be
discontinued. Based on the results of groundwater monitoring and monitoring of
influent samples in the recovery well from the pump and treat cleanup system the
cleanup system was turned off. This variance request encompasses the entire
property at 711 Pressley Road in Charlotte, North Carolina.
Potential sources of groundwater contamination in the area are discussed in
Pages 9 through 11 and in Appendix A of the report titled "Variance Request-
Carolina Coatin~s Site -Charlotte, North Carolina, December 9, 1996, Dames and
Moore N.C. Job No.23995-002-200." . Appendix A shows Vista Site Assessment
Reports of these properties with maps. Potential sources of groundwater
contamination are summarized as follows:
1) The property at 711 Pressley Road formerly owned by Carolina
Coatings Incorporated (Mecklenburg County Tax Identification
Number 145-291-03). This site is now owned by Wattyl Paints. The
Vista Site Assessment Report lists this site on the state "CERCLIS"
and as a "Large Quantity Generator" of hazardous wastes.
2) The property at 807 Pressley Road known as The .Gifford-Hill
Company located 1/10 of a mile northwest of the site. This property is
upgradient from the site and is listed with the Division of \Vaste
Management-Underground Storage Tank Section as having reported
a leaking petroleum underground storage tank on June 1, 1989.
3) Property at 927 Pressley Road known as Climate Conditioning of
Charlotte located 0.2 miles northwest of the site. This property is
upgradient from the site and is listed with the Division of \Vaste
Management-Underground Storage Tank Section as having reported
a leaking petroleum underground storage tank on December 27, 1994.
In addition, Page# 11 of the "Vista Site Assessment Report" shows
4
that at one time this company removed three underground storage
tanks that contained gasoline.
4) Observer Transport Company located 0.3 miles northwest of the site
at 1001 Pressley Road. This property is upgradient from the site and
is listed with the Division of Waste Management-Underground
Storage Tank Section as having reported three gasoline leaks on April
12, 1988, April 17, 1992, and April 15, 1994. Page# 12 of the "Vista
Site Assessment Report" shows that two of these tanks contained
"Gasoline" and ''Diesel Fuel". The third tank contained a product
described as "Petroleum Other".
5) Xerox Corporation located 0.35 miles northwest of the site at 4740
Dwight Evans Road. This property is upgradient from the site and is
listed with the Division of Waste Management-Underground Storage
Tank Section as having reported a leaking petroleum underground
storage tank on September 30, 1986. Page# 12 of the "Vista Site
Assessment Report" shows that this tank contained "Gasoline" and
"Diesel Fuel".
6) White Machines which is located 0.53 miles north of the site at 4300
Barringer Drive. This property is cross-gradient from the site and is
listed with the Division of Waste Management-Undergro!Jnd Storage
Tank Section as having reported a leaking petroleum underground
storage tank on March 21, 1990. Page # 13 of the "Vista Site
Assessment Report" shows that this tank contained "Gasoline" and
"Diesel Fuel".
7) Piedmont Natural Gas which is located 0.4 miles east of the site at
Verbena & Yancey Streets. This property is downgradient from the
site and is listed in the variance request as having reported a leaking
petroleum underground storage tank on January 15, 1990. Page# 13
of the "Vista Site Assessment Report" shows that this tank contained
"Gasoline" and "Diesel Fuel".
8) Industrial Truck Sales which is located approximately 0.1 miles east
of the site at 3910 Stuart Boulevard. This property is down gradient
from the site and is listed in the variance request as a "RCRA small
quantity generator". Page# 9 and# 10 of the "Vista Site Assessment
Report" shows that underground storage tanks have also been at this
property. Three tanks have been removed consisting of one 8,000
gallon gasoline tank, a 1,000 gallon oil tank, and a 250-gallon oil tank.
One 500-gallon oil tank is list as "active/in service" at this property.
5
9) Ryder Truck Rental Incorporated which is located approximately
0.11 miles east of the site at 3901 Stuart Boulevard. This property is
downgradient from the site and is listed in the variance request as a
"RCRA small quantity generator". Page# 10 and 11 of the "Vista
Site Assessment Report" shows that eight "in service" underground
storage tanks are present at this property containing "gasoline, diesel
fuel, motor oil, oil" and a fluid described as "hazardous".
10) Chemlawn Services Corporation which is located approximately 0.03
miles southeast at 655-R Pressley Road. This property is .located
downgradient from the site. Appendix A shows that this site once had
a 2,000 gallon underground storage tank for diesel fuel. This tank is -
listed as "removed" from the property.
11) Page# 9 of the "Vista Site Assessment Report" shows two "in service"
underground storage tanks at the RSM Company located at 811
Pressley Road located approximately 0.09 miles northwest. This
property is upgraident from the site.
12) Page# 12 of the "Vista Site Assessment Report" shows that Ridgeway
Chemicals Incorporated has three underground storage tanks at 651
Michael Wylie Drive located 0.25 miles northeast of the site. These
tanks are listed as "active/in service" in the report. A 1,000 gallon
tank was removed from this site. The contents of all four tanks are
reported as "unknown". This property is cross-gradient from the
site.
13) Pressley Road ( a public roadway).
14) Public sewer lines and other utilities in the area.
15) Southern Railroad (a private rail company).
In addition, Page #15 through Page# 17 of Appendix A shows eight known
sources of groundwater contamination in the general area near 711 Pressley Road.
Due to inadequate information on the location of these sites, it is not possible to
represent them on maps contained in Appendix A. Scaled diagrams of this site are
found in Figures# 1 through# 4 and Figure# 11 of the report titled "Variance
Req uest -Carolina Coatin ~s Site -Charlotte, North Carolina, December 9, 1996,
Dames and Moore N.C. Job No.23995-002-200." !.
6
Rule .Ol 13 (c )(3 ): Descrip tion of the pro posed area for which the variance is re quested .... :
Maps of the area are shown in Figures 1 through 5 of the report titled
"Variance Req uest-Carolina Coatin gs Site -Charlotte, North Carolina, December
9, 1996 , Dames and Moore N.C. Job No.23995-002-200." . The property at 711
Pressley Road for which Carolina Coatings Incorporated has requested this
variance for Groundwater Incident Number 8949 is within an area consisting of a
mixture of residential, commercial and industrial develQpment. The map on Figure
11 shows that the property is bordered on its east side by Pressley Road and four
adjacentproperties border the Carolina Coatings site on its north, south and west
sides. The Southern Railroad Line is to the west within 1,000 feet of the area in
which the release of substances occurred. The property on the west side is vacant
land identified under Mecklenburg County Tax Identification Number 145-291-07
and owned by Mr. Linwood Carter, who is also the proprietor of Carolina Coatings
Incorporated. In applying for a variance at 6500 North Tryon Street, Carolina
Coatings Incorporated did not include this adjacent property or any portion of it in
the request.
Table 4 in the report lists adjacent property owners by Mecklenburg County
Tax parcel numbers and addresses. The last column of this table locates these
adjacent properties relative to the site at 711 Pressley Road. Figure 11 sho,Ys these
properties and owners from a tax line map in Book 145, Pages 27-29 (Revised
5/7/96).
Figure 4 of the variance request also shows that the area of groundwater and
soil contamination prior to remedial actions was of an amorphous shape, much of
which extended beneath the former concrete pad and settling tanks. Since soil
removal activities and the implementation of the pump and treat cleanup system,
the area where substances are known to exist is shown in Figures 7 through 12 of the
variance request. These figures reveal that the area in which substances persist at
concentrations in exceedence of the Groundwater Quality Standards in 15A i'\CAC
2L .0202 is roughly in the shape of an ellipse. The groundwater contamination that
the Carolina Coatings Incorporated is responsible for encompasses both the
recovery well and Monitoring Well# 9 and appears limited to this area. Figures 8
through 10 and Figure 12 of the report shows that substances at 711 Pressley Road
Street have not migrated onto adjacent properties at concentrations above
Groundwater Quality Standards in 15A NCAC 2L .0202. This variance is for all
the land entirely within the property boundaries of 711 Pressley Road for which
Carolina Coatings Incorporated has cleanup responsibilities.
Pages 11 through 13 of the report titled "Variance Req uest -Carolina
Coatin gs Site -Charlotte, North Carolina, December 9, 1996, Dames and Moore
N.C. Job No.23995-002-200" discusses groundwater contaminant migration and the
potential impact to water supply wells and surface streams in the area. Two water
supply wells are located within one-half mile of the site. These wells are 2,.300 feet
south of the Carolina Coatings property at Yorkmont Road and Loch lane Drive.
The company could not ascertain if these water supply wells are currentl~· in use as
7
a source of drinking water supply or other uses. Based on water use data and
hydrogeologic conditions in the general area, Carolina Coatings Incorporated does
not believe that this variance will have an effect on these wells. Based groundwater
flow calculations, the company does not believe that the variance will impact any
receptors near 711 Pressley Road.
Rule .0113(c)(4): Supportine information to establish that the variance will not endaneer
the public health and safetv ... :
This part of the variance concerns Groundwater Quality Standards shown in
15A NCAC 2L. 0202 and has been requested for Benzene, Ethylbenzene, and
Xylene(-o,-m, and p). In order to assess health impacts, groundwater sampling was
conducted at on-site monitoring wells to assess the extent of contamination, the
concentration levels of substances, and the movement of substances to adjacent
pro-perties. Groundwater monitoring from Carolina Coatings Incorporated
indicates that substances released at this site do not pose a hazard to the public. As
shown in Figure 5, nine monitoring well were originally installed at 711 Pressley
Road by the company. During site renovation to remove soil and repair the
concrete storage pad, two of these wells (Monitoring Wells MW# 2 and MW# 8)
were abandoned by the company prior to the implementation of groundwater
cleanup.
Carolina Coatings has conducted quarterly groundwater sampling at
Monitoring Well MW# 3, Monitoring Well MW# 7, and Monitoring Well M\V # 9
from March 1994 through October 1997. Monitoring Well MW# 3 is located
upgradient approximately 125 feet to 150 feet from the area in which the release of
substances occurred at the northwest property line. Monitoring Well MW# 7 is
located within 35 feet directly to the south-southwest of this area and is roughl~
down-gradient to the area that was impacted by the release. Monitoring Well MW#
9 is within the area of the release and is slightly downgradient from Recovery \Veil
RW # 1. Thirteen separate sampling events occurred during this period. As shown
in an April 19, 1999 letter sent to Groundwater Section, the last sampling and
analysis at all monitoring wells occurred on October 9, 1997. Toluene has never
appeared in any sample taken from monitoring wells from this site above the
Groundwater Quality Standard.
Table 2 of the variance request and data in the April 19, 1999 letter shows
that Monitoring Well MW# 3 and Monitoring Well MW# 7 have never had
concentrations of substance above detectable limits. Only Monitoring '\Vell l'HW #
9 has shown concentrations of Benzene, Ethylbenzene, and Xylene above the
Groundwater Quality Standards in 15A NCAC 2L .0202. The only substance that
appeared in Monitoring Well MW# 9 during the October 9, 1997 monitoring event
was Benzene at 0.002 milligrams per liter or 2.0 micrograms per liter. The
Groundwater Quality Standard for Benzene is 0.001 milligram per liter or 1.0
microgram per liter. It is also important to note that Table 2 shows several graphs
of the concentrations levels of substances analyzed from Monitoring Well MW# 9
8
from March 1994 to September 1996. Although Ethylbenzene and Xylene have
been reduced below respective Groundwater Quality Standards, the concentration
of Benzene from samples taken from this well have fluctuated over time. In
September 1995 this concentration was reduced below the Groundwater Quality
Standard but later "rebounded" to the extent that the Benzene level in this well was
in exceed of the standard during subsequent quarterly monitoring events. In order
to provide additional supporting data for this variance request, Carolina Coatings
Incorporated sampled the downgraident monitoring wells MW # 5 and MW # 6.
No substances were detected in these wells above Groundwater Quality Standards
in 15A NCAC 2L .0202.
The Division also required the Carolina Coatings Incorporated to evaluate
the effectiveness of groundwater cleanup efforts by examining concentrations of
substances in the recovery well used as a sump to collect dissolved hydrocarbons
from the site. This monitoring effort was necessary to understand the effect pump-
and-treat cleanup has had on concentrations of constituents at the site. Table 1 of
the report titled "Variance Re c1 uest -Carolina Coatin e s Site -Charlotte, North
Carolina. December 9, 1996 , Dames and Moore N.C. Job No.23995-002-200"
provides a record of monthly groundwater samples obtained at the influent of the
recovery well for the pump-and-treat groundwater remediation system. This
monitoring was conducted from March 29, 1994 through October 30, 1996.
Except for Benzene, concentrations of substances monitored from the
recovery well have never exceeded the Groundwater Quality Standards in 15A
NCAC 2L .0202. Since monthly sampling of this recovery well influent began in
March 1994, the Benzene concentration has fluctuated from levels above the
Groundwater Quality Standard to below detectable limits. The highest
concentration of Benzene reported at this site was 0.0076 milligrams per liter or 7.6
micrograms per liter from the May 6, 1994 sampling event. The Groundwater
Quality Standard for Benzene is 0.001 milligram per liter or 1.0 microgram per
liter. Samples taken from September 30, 1996 through October 30, 1996 showed
concentrations of all substances below detectable limits.
From the information shown on Page 13 of the variance request, Carolina
Coatings Incorporated evaluated the impact granting a variance would have on
nearby receptors. The nearest downgradient adjacent property is a small strip of
the vacant land owned by Mr. Linwood Carter which is approximately 110 feet
from the area in which substances were released at 711 Pressley Road. Based on an
average hydraulic conductivity of 0.06 feet per day, an approximate hydraulic
graident of 0.01 feet per foot, and an effective porosity of 20 percent for silty clay,
the groundwater flow is calculated at 1.1 feet per year. Assuming no contaminant
dilution or attenuation and this figures, it is believed that it would take 100 years for
the plume of substances to reach this property boundary. In addition to
groundwater flow calculations, Carolina Coatings Incorporated has also submitted
the results of modeling using the Domenico Solute Transport Model for this site as
discussed on Page 13 of the reporttitled "Variance Re q uest -Carolina Coatin es
Site -Charlotte , North Carolina, December 9, 1996, Dames and Moore N.C. Job
No. 23995-002-200". The results of this modeling support the companies view that
9
this variance will not impact adjacent properties. Data from this modeling may be
found in Appendix B of the variance request.
No water supply wells were identified at adjacent properties to 711 Pressley
Road. A well survey only identified only two water supply wells within the½ mile
radius of the site as specified under 15ANCAC 2L .0113(c)(4). ·These are located in
Figure 2 of the variance request at the intersection of Lochlane Drive and Yorkmont
Road approximately 2,300 feet south of 711 Pressley Road. According to the
information in this request, these wells are cross-gradient from the site. Page 12
states that is not known if these wells are being used as a source of drinking water
supply or for purposes other than drinking water. Drinking water for the City of
Charlotte is obtained from Mountain Island Lake on the Catawba River twelve
miles north of the site. All downgradient properties and other area properties are
supplied drinking water from the City of Charlotte.
'It is higqly improbable that public water·supply lines will be impacted by
this variance. Numerous water supply lines and other utilities are located along
Pressley Road, Bishop Drive and Yorkwood Road. Contacts with the Charlotte
Mecklenburg Utility Department and found that utilities are not a potential path for
migration of petroleum hydrocarbons from the site. Page 12 of the variance request
shows that the depth to the groundwater in this area is approximately 15 feet to 20
feet. The utility department reported that area water lines and utilities are buried
less than five (5) feet from the surface. Groundwater contamination from Incident
Number 8949 that is beneath 711 Pressley Road is too deep within the subsurface to
impact these lines. In addition, Page 12 also states the Carolina Coatings
Incorporated does not believe any buildings with basements will be impacted by this
variance request.
Rule .0113(c)(5): Supporting information to establish that requirements of the rule cannot
be achieved bv providing best available technolo2"' economicallv reasonable:
The part of the request that concerns variance to Corrective Action in 15A
NCAC 2L .0106(j) will allow Carolina Coatings Incorporated to discontinue
Corrective Action at this site. The company has submitted suppo.rting information
in the report with other documents demonstrating that the continued application of
best available technology will not result in significant long term remediation of the
site to the Groundwater Quality Standards contained in lSA NCAC 2L .0202. The
is due to the high probability that continued cleanup activities at the site will not
significantly reduce contaminant levels below the Groundwater Quality Standards
in 15A NCAC 2L .0202.
Since discovery of the release in 1991, Carolina Coatings Incorporated has
disposed of a total of2,400 cubic yards ofBTEX contaminated soil. Page 6 of the
report titled "Variance Request-Carolina Coatings Site -Charlotte, North
Carolina. December 9, 1996, Dames and Moore N.C. Job No.23995-002-200" states
that the company has treated approximately 328,500 gallons of groundwater to
comply with the cleanup requirements of the Corrective Action Plan that was
implemented in March 24, 1994. Pages 15 through 16 of the report titled
"Variance Re q uest -Carolina Coatin gs Site -Charlotte, North Carolina, December
9 , 1996, Dames and Moore N.C. Job No.23995-002-200" states that a total of
$493,000 has been expended to design and install the remediation system, operate
the system, monitor progress of cleanup activity, and cleanup this site. Page 15 of
the variance request shows that the owner of Carolina Coatings Incorporated, Mr.
Linwood Carter, is retired and is reported in the variance request as financing the
cleanup of this site from this personal savings. He bas had no direct employment
since the sale of the property at 711 Pressley Road in 1991 to Wattyl Paints
Incorporated.
Groundwater analysis of samples from on-site monitoring wells showed
significant reductions in the concentrations of substances from March 1995 through
October 9, 1997. As previously stated the groundwater pump-and-treat cleanup
system operated from March 24, 1994 through January 1997. Except for
Monitoring Well# 9, Benzene and other substances related to paint mixing
operations have not been observed above Groundwater Quality Standards from
quarterly groundwater samples. Although concentrations of Benzene, Toluene,
Ethylbenzene, and Xylenes have been significantly reduced near Monitoring Well#
9 since cleanup operations began, the concentration of Benzene at a portion of this
site remains at levels in exceedence of the Groundwater Quality Standard in 15A
NCAC 2L .0202. Page 7, Page 8, and Table 3 of the report titled "Variance Re q uest
-Carolina Coatings Site -Charlotte, North Carolina, December 9, 1996 , Dames and
Moore N.C. Job No .23995-002-200" shows that after the pump-and-treat cleanup
system was temporarily taken out of operation for a period of five days,
concentrations of substances in monitoring wells, including Monitoring Well# 9, did
not change significantly. Table 1 shows that while the cleanup system was in
operation, results from groundwater samples taken from the influent of Recovery
Well RW # 1 during the period of March 29, 1994 through October 30, 1996,
revealed remaining concentrations of substances beneath 711 Pressley Road had
been significantly reduced such that they could no longer be detected.
In order to demonstrate that the requirements of the rule cannot be achieved
using best available technology, title 15A NCAC 2L .0113(c)(5) requires that specific
technology considered be identified, the costs of implementing the technology be
shown, and the impacts of the costs on the applicant be provided. Page 16 of the
report titled "Variance Re q uest -Carolina Coatin gs Site -Charlotte, North
Carolina, December 9, 1996 , Dames and Moore N.C. Job No.23995-002-200" states
that continued operation and monitoring at 711 Pressley Road will cost Carolina
Coatings approximately $48,000 per year. In addition, Page 14 of the request
shows that in order to continue cleanup with the pump-and-treat system, significant
upgrades will be needed for this system. These modifications include the installation
of additional groundwater recovery wells, new pumps, and renovations to increase
the size of the infiltration gallery. The company believes that the _low residual levels
of contaminants in the groundwater at this site does not warrant the continued use
of the pump-and-treat cleanup system. -
11
Carolina Coatings Incorporated has considered the use of air sparging with
soil vapor extraction (SVE) as alternate technology to the present pump-and-treat
cleanup system. This technology is an in-situ remediation method that involves the
physical introduction of air below the water table to volatilize groundwater
contaminants from groimdwater and subsurface materials into a vapor phase. The
SVE portion of this system captures the volatilized substances so that they may be
removed from the subsurface environment. As shown on Page 15 of the report
titled "Variance Request -Carolina Coatings Site -Charlotte. North Carolina,
December 9, 1996, Dames and Moore N.C. Job No.23995-002-200" states that the
average hydraulic conductivity in saturated zone beneath the site is 2 x 10-5
centimeter per second. Based on this low permeability, Carolina Coatings does not
believe the use of this type of technology will be effective at removing substances
that remain at 711 Pressley Road.
Carolina Coatings Incorporated did not identify any technology, other than
those already at the site and alternate technology identified in the variance, that
would meet the requirements of 15A NCAC 2L .0106(i) as "best available
technology". Pursuant to the requirements of 15A NCAC 2L .0113(c)(5), the
company does not believe that continuing remediation is economically reasonable.
Rule .0113(c)(6): Supporting information to establish that compliance would produce
serious financial hardship on the applicant:
Carolina Coatings Incorporated has submitted information showing that
compliance with the rules will result in a serious financial hardship. Page 15 of the
variance request shows that the owner of Carolina Coatings Incorporated, lVlr.
Linwood Carter, is retired and is reported in the variance request as financing the
cleanup of this site from this personal savings. He has had no direct employment
since the sale of the property at 711 Pressley Road in 1991 to Wattyl Paints
Incorporated. Allowing the persistence of low levels of contaminants in
groundwaters that, after approximately three years of applying best available
technology, have asymptotically approached the Groundwater Quality.Standards in
15A NCAC 2L .0202 through a variance is a prudent means of addressing Carolina
Coatings release at this site. It is no less effective a means of addressing residual
concentrations of substances at this site than continuing the use of pump-and-treat
system and is less expensive.
12
Rule .0113 (c)(7): Su pp ortin~ information that com pliance would p roduce serious financial
hardship without eq ual or ereater public benefit:
The company has submitted information in the request demonstrating that
the environment, safety and public health would not be impacted by this variance.
A January 6, 1997 letter from the Mooresville Regional Office serves as a
justification for this variance as it states that " ....... continuation of pump and treat
remediation is neither cost effective nor environmentally beneficial". The letter
further states that the "Risk to the public is minimal considering the lack of active
water supply well systems, distance to surface water bodies, and the industrial
character of the site and surrounding sites.".
Rule .0113 (c)(8): "A co p,1 of an v S p ecial Order ... ":
No Special Order by Consent has been issued for this site.
Rule .0113 (c)(9): "A list of names and addresses of p ro pertv owners ... ":
The property owners within the proposed area of the variance are shown in
Table 4 and the map in Figure 11 of the report titled "Variance Re q uest-Carolina
Coatin gs Site -Charlotte, North Carolina, December 9 , 1996, Dames and Moore
N.C. Job No.23995-002-200". This listing includes the Trimming-Associates LTD,
the Presseley Park Restaurant owned by Ionnis and Gregory Andreas, Rebpat
Leasing, Joachim H. Klitzsch, James A. Williams, J. David Fortenbery, Davis
Brothers Venture, Exit Fourteen Associates, the former Carolina Coatings site at
711 Pressley Road now owned by Wattyl Paints, John W. Layne, Linwood T. Carter
(property adjacent to 711 Pressley Road), the North Carolina Department of
Transportation, Southern Railroad, and two parcels of land owned by Eight
Hundred Eleven Pressley. Title 15A NCAC 2L .0113(e)(E) requires that
notification of a public hearing on this variance be given to the owner or owners of
these adjacent properties "at least 30 days prior to the date of the hearing".
It is the recommendation of the Groundwater Section that the subject variance
request to Corrective Action requirements of 15A NCAC 2L .0106U) and Groundwater
Quality Standards contained in 15A NCAC 2L .0202 proceed to public notice in
accordance with 15A NCAC 2L .0113(e). On February 27, 1997, the Division of
Epidemiology completed their review of the risk assessment methodology for this site and
recommended that this variance be granted for Carolina Coatings Incorporated at their
former property located at 711 Pressley Road in Charlotte, North Carolina. Upon your
concurrence with our recommendation, the Groundwater Section will proceed with the
13
preparation of the required public notice and hearing. Upon completing of the
requirements of lSA NCAC 2L .0113(d -f), with a recommendation to grant this variance
from the Environmental Management Commission Groundwater Committee, this request
will proceed to the Environmental Management Commission for final action in lSA NCAC
2L .0113(g). If there are any questions regarding this matter or if any additional
information is needed, please let me know.
ATTACHMENTS:
cc: Groundwater Section Assistant Chiefs
Mooresville Regional Groundwater Supervisor
Dr. Ken Rudo
David Hance
14
State of ·North Carolina
Department of Environment,
Health and Natural Resources
Division of Epidemiology
James B. Hunt, Jr., Governor
Jonathan B. Howes, Secretary
Michael Moser, M.D., M.P.H., Director
MEMORANDUM
February 27, 1997
TO: Arthur Mouberry, P.E., Chief
Groundwater Section
FROM: Kenneth Rudo, Ph.D.,Toxicologist \tvt'(l..,
NA
D E HNR.
Medical Evaluation and Risk Assessment Branch
Occupational and Environmental Epidemiology Section
SUBJECT: Request forVariance at the Carolina Coatings, Inc. Property at 711
Pressley Road in Charlotte,· North Carolina
After reviewing the monitor well and site-specific data for the above site, the
Occupational and Environmental Epidemiology Section (OEES) would like to put
forward the following observations and recommendations. Although benzene
contamination in MW-9 still exceeds North Carolina groundwater standards, the
contamination is confined onsite, and itappears that it will remain onsite for many
years . In addition, there doesn't appear to be any private drinking water wells within a
1500 foot radius of the site, based on the documentation supplied to OEES . Because
the benzene contamination should not pose any risk to any private drinking water wells
and is confined onsite, the contamination should not pose any risk to public health
under the conditions described in the variance request. Therefore, OEES would
recommend granting the variance at this site.
If you have any further questions, please feel free to contact me at 715-6430.
KR:lp
P.O. Box 29601
Raleigh, NC 27626-0601 NOC An Equal Opportunity Affirmative Action Em~toyer
50% recycled/10% post -consumer pope,
Carolina Coatings-Variance Request
January 6, 1997
Page Two
A. Significant upgrade of the existing system and installation of
additional recovery wells would be necessary to capture the
lateral extent of the existing benzene above the NCAC 2L
standard. The current system, which has been operational for 2.5
years, has an insufficient capture zone to remediate the site to
below 2L groundwater standards.
B. Risk to public health is minimal considering the lack of active
water supply well systems, distance to surface water bodies, and
the industrial character of the site and surrounding sites.
If a variance is granted for the subject site, the MRO does not recommend continued
sampling of onsite monitoring wells based on the following reasons:
1) The groundwater plume is spatially limited (<30 feet radially) and does not
extend offsite .
2) Groundwater modeling of the plume does not predict off site migration of the
plume above the 2L standards.
2) Secondary sources have been removed and the contaminants have the capacity
to degrade or attenuate.
Attached to this memo is a summary of the variance request. If you should have any
questions, I can be reached by phone at 704.663.1699 ext. 261 or by E-mail at
<[e-mail]. us>.
Attachment: Variance Request Summary
Release
NOV
CSA
Carolina Coatings
711 Pressley Road, Charlotte, North Carolina
Environmental site assessment for property transfer purposes performed in 1991
detected the presence of ethylbenzene, toluene and xylenes (BTEX) in soils
surrounding the pad. Subsequent assessment detected concentrations of BTEX
compounds above the 2L standard in onsite monitoring wells.
On August 28, 1992, the MRO issued Carolina Coatings a Notice of Violation
in accordance with 15A NCAC 2C 2L requiring restoration of groundwater and
soil at the site and elimination of the source. Source of the contamination was
apparently surface spill resulting from leaking drum storage and three settling
tanks located adjacent to the southeastern side of the pad.
A remedial action plan (RAP) was received on June 30, 1992. The horizontal
and vertical extent of groundwater contamination was delineated and findings
presented in this report; no BTEX constituents were detected in the deep well
(MW-8) nor the downgradient wells MW-1,5,6 and MW-7. Additional
information was requested by the MRO staff including additional soil sampling
and potential methods of remediation and disposal of excavated soil. On March
29, 1993, the requested information was submitted in the form of a RAP
Addendum.
The RAP addendum documented removal of approximately 1500 cubic yards of
contaminated soil surrounding the concrete drum storage pad and beneath the
pad. Confirmatory soils samples indicated no remaining soil with BTEX
concentration compounds above the 50 mg/kg target cleanup level.
CAP The corrective action plan was presented in a report entitled Soil and
Groundwater Remediation received on May 13, 1994 by the MRO. This report
proposed the use of a pump and treat system comprised of a single recovery
well and infiltration gallery. Recovered groundwater was processed through an
equalization tank, four fiber cartridge filter units and two carbon filter units in
senes.
The CAP was not reviewed by the MRO or approved by the Director.
On January 18, 1994, the NC DEHNR Water Quality Division issued a
discharge permit for treated groundwater into the onsite infiltration gallery
( #WQ0007993).
The groundwater pump and treat system was activated on March 23, 1994 after
the required 48-hour notification to the MRO. Currently, the system is
operating at an approximate recovery rate of 0.25 gpm which equals an
approximate aquifer withdraw of 328,500 gallons of groundwater since system
startup.
Analytical results of system influent and effluent samples indicate ethylbenzene
and toluene concentrations below the 2L standard. Xylene and benzene
concentrations have decreased significantly but have exceeded the 2L standard
periodically.
Groundwater has been monitored between March 1994 and September 1996.
Monitoring well MW-9 has been the only groundwater monitoring well that has
ever exceeded the 2L standard for BTEX compounds. Analytical results of the
September 1996 sampling indicate benzene at a concentration of 27 ppb and
xylene at 104 ppb.
Groundwater flow at the site is determined to be primarily east with radial
components. A groundwater gradient of 0.01 ft/ft has been calculated for the
site. Rising head test completed in four shallow monitoring wells indicate a
hydraulic conductivity value of 3.87 x 10-5 cm/sec or 0.06 ft/day.
The calculated time that the plume would encounter the property boundary
given the current hydrogeologic conditions is 100 years. Using the Domenico
solute transport model and assuming a 27 ppb source concentration of benzene
(September's analytical results) and a first-order decay coefficient of 720 days,
the modeled benzene concentration at the property boundary would be <lppb.
Carolina Coatings has submitted a variance request with supporting information
that demonstrates continued use of the current system is cost-prohibitive and
will not result in significant long-term remediation of the site to groundwater
standards. The variance request further suggests that remediation of the site to
groundwater standards would require significant modification of the current
groundwater recovery and treatment system.
The following facts and financial information has been submitted by Carolina
Coatings to further support their variance request:
1) Only one monitoring well, MW-9, has had benzene and xylene
concentrations above the 2L standard since groundwater monitoring
began in March 1994. Therefore, BTEX affected groundwater is limited
to the area surrounding MW-9.
2) System influent sample concentrations have decreased from a maximum
of 7.6 ppb benzene and 440 ppb xylenes in May 1994 and March 1995
respectively. The system has been operational for 2.5 years and has
treated approximately 328,500 gallons of recovered groundwater.
Toluene and ethylbenzene have decreased to below the analytical
detection limit over the course of system operation.
.....
3) A total of $493,000 has been spent by the former owner of Carolina
Coatings on assessment and active remediation of the contaminated soil
and groundwater using best available technology economically
reasonable for the site. The continued, yearly operation and monitoring
cost of the site is estimated at $48,000. Mr. Carter, the retired, former
owner of the facility, maintains sole environmental liability of site
remediation and therefore continued operation would impose serious
financial hardship for Mr. Carter without significant environmental
benefit.
4) No potential surface water receptors or onsite receptors (i.e., basements,
artificial conduits) will be impacted above the 2L standard based on
groundwater modeling. The nearest, potential water supply wells are
located 2300 feet south of the site and are hydrologically separated from
the site aquifer.
SEP.22.1999 10:23AM ENVIRONMENTAL MGMT
DIVISION OF WATER QUALITY
September 22, 1999
M E M O R A N P U M
TO:
FROM:
Arthur Mouberry
DWQ-GW Section, RCO
Parker-Lincoln Bldg.
Art Barnhardt, F~
DWQ-GW Section ,.__,,,/
NO.057
SUBJECT: Layne Property -Adjacent to Carolina
Coatings Variance Site
Mr. John Layne owns property in the vicinity
of the Carolina Coatings Property. Carolina
Coatings is in the midst of requesting a
variance from 2L. Written comments were
received from Mr. Layne's agent requesting a
regulatory perspective from the Division.
Specifically, they want a response on the
issue of "responsibility .. if any of the
solvent leeched on to his property?"
I spoke with Mr. Layne's agent, and it sound
like they would be satisfied with the "Arthur"
letter that we sometimes send out to folks in
this situation.
I will be happy to draft the letter for your
signature. Let me know your wishes.
Related information attached.
RE: DIRECTOR'S APPROVAL TO PROCEED ... TINGS VARIANCE/ OCTOBER GWC MEETING
1 of 1
Subject: RE: DIRECTOR'S APPROVAL TO PROCEED TO THE EMC GWC/CAROLINA
COATINGS VARIANCE/ OCTOBER GWC MEETING
Date: Fri, 08 Oct 1999 16:29:27 -0400
From: David Hance <[e-mail]>
Reply-To: DENR
Organization: Groundwater Section
To: ART BARNHARDT <[e-mail]>,
Matt Heller <[e-mail]>
CC: Arthur Mouberry <[e-mail]>,
CARL BAILEY <[e-mail]>,
DAVID HANCE <[e-mail]>
HELLO ART AND MATT:
THE DIRECTOR HAS GIVEN APPROVAL TO PROCEED TO THE ENVIRONMENTAL
MANAGEMENT COMMISSION GROUNDWATER COMMITTEE AT THE OCTOBER 13, 1999
MEETING WITH APPROVAL OF THE CAROLINA COATINGS VARIANCE.
THE VARIAN CE MEMORANDUM ART BARN HART WROTE UP WITH A TI ACHMENTS
HAS BEEN SENT TO THE EMC GROUNDWATER COMMITTEE AND DWQ STAFF IN THE
GROUNDWATER COMMITTEE PACKET.
A COPY OF THE COMPLETE GROUNDWATER COMMITTEE PACKET HAS BEEN SENT
TO BOTH OF YOU IN FEDERAL EXPRESS MAIL. IT SHOULD ARRIVE MONDAY
MORNING.
PLEASE NOTE THAT THE EMC GROUNDWATER COMMITTEE MEETING WILL BE HELD
IN RALEIGH AT THE ARCHDALE BUILDING -GROUND FLOOR HEARING ROOM AT
10:00 A.M.
ON WEDNESDAY, OCTOBER 13, 1999. BOTH OF YOU SHOULD BE THERE. ALSO NOTE
THAT THE CENTRAL OFFICE HA VE NOT MADE ARRANGEMENTS FOR AN OVERNIGHT
STAY, IF YOU DEEM IT NECESSARY.
ASSUMING THAT THE GROUNDWATER COMMITTEE AGREES THAT THIS VARIANCE
SHOULD BE GRANTED PURSUANT TO 15A NCAC 2L .0113, THE VARIANCE WILL THEN BE
SENT TO THE FULL COMMISSION FOR FINAL ACTION. BASED ON THE REGULAR
SCHEDULE THE COMMISSION WOULD GET THIS VARIANCE AT IT'S DECEMBER 1999
MEETING. IF THEY HOLD A MEETING IN NOVEMBER (LIKE THEY HA VE IN THE PAST)
WE MAY TRY TO GET THIS ON THAT AGENDA-TO MOVE IT ALONG.
IF YOU DO NOT GET YOUR GROUNDWATER COMMITTEE PACKET OR NEED TO SPEAK
TO ME, CALL 919-715-6189.
DH
10/8/1999 4:31 PM
Carolina Coatings Variance Request
1 of 1
Subject: Carolina Coatings Variance Request
Date: Fri, 01 Oct 1999 10:21:53 -0400
From: Greg Thorpe <[e-mail]>
To: DAVID HANCE <DA [e-mail]>
CC: CARL BAILEY <[e-mail]>,
Arthur Mouberry <[e-mail]>,
ART BARNHARDT <[e-mail]>
David,
I have just gotten to the documents you forwarded to me on the subject
request. I would like to have more time to complete my review of these
documents, if at all possible. What are the consequences to the
applicant if this does not go before the Groundwater Committee in
October? I realize this means that the variance request will not go
before the EMC until February 2000. What I'm interested in knowing is,
what are the impacts (fiscal or otherwise) on the applicant if the
variance request goes to the Groundwater Committee in Dec '99 and to the
full EMC in Feb '00? Please advise. Thanks!!
10/1/99 11:37 AM
PUBLIC NOTICE AND PUBLIC HEARING
On July 9, 1999 public notice was issued advising interested parties that a hearing on the
variance request for Carolina Coatings Incorporatedwas scheduled for August 12, 1999 (Attachment
1). Notice of this variance request was sent to local government officials and the Mecklenburg
County Health Director pursuant to the 15A NCAC 2L .0113 rule. Individual notices were sent per
requirements of title 15A NCAC 2L .0113 to sixteen adjacent property owners and area property
owners identified by Carolina Coatings Incorporated in the variance request. Approximately 130
notices were sent to the public at large consisting of persons listed in the Groundwater Section's
Mailing List. Corporations, environmental groups, firms, government agencies, partnerships, and
individuals were sent a copy of the notice and are those persons who have expressed an interest in
regulatory actions that require a public hearing. Most of these persons reside or work in the
Charlotte Metropolitan Area; A copy of the notice was also published in The Charlotte Observer
on July 11, 1999.
The public hearing was conducted as scheduled. The Division was represented by four staff
members:
Art Barnhardt
Matt Heller
Shawna Caldwell
Randy Prillaman
Hearing Officer (Fayetteville Regional Office)
Mooresville Regional Office
Mooresville Regional Office
Recorder (Central Office)
The hearing was attended by five citizens consisting of adjacent property owners and o\,ner
representatives. One person had verbal comments. Opening remarks were given by me, followed
by the staff presentation by Matt Heller (Attachment 2). Verbal and written comments from
interested parties were received during the hearing and prior to the closing of the hearing record on
September 13, 1999 and are paraphrased below. Written comments are included as (Attachment 3)
Verbal Comments during hearing by:
Joe Garmon and he stated that he owned property adjacent to the Carolina Coatings Site and at the
time the variance is granted, is Carolina Coatings relieved of all responsibility?
Written comment s were submitted hY-·
Jack Smith ofMetrolina Landscape Company which stated (l)that they were unsure of what they
could or should do about this variance request, (2)wanted the right environmental thing done,
(3)wanted to be protected from devaluation of property due to contamination issues (4) asked for
a staff person to contact him and discuss the situation with him as opposed to ha Ying to hire a
consultant/lawyer.
2
Meredith Stover, agent for John Layne-Adjacent Property Owner which (!)stated his concerns
of contaminates migrating onto Mr. Layne's property (2) wanted relief and protection of any clean-
up that would be required (3) Mr. Layne was not opposed to the variance request but wanted a
written response on his regulatory responsibility if contamination migrated onto his property.
DISCUSSION/RECOMMENDATION
Attachment # 4 consists of the important memoranda related to this variance request. The
June 24, 1999 memoranda discusses the variance in light of the requirements of 15A NCAC 2L
.0113 and provides detailed information about this site. The two issues before the Environmental
Management Commission (EMC) are whether to grant a variance from the Groundwater Quality
Standards for Benzene as found in NCAC 2L .0202 and a variance from the requirement to continue
to implement a corrective action plan using the best available technology as required by I SA NCAC
2L .0106 (j).
A total of$493,000 has be~n expended to clean-up this site, none of which was reimbursed
through any type of trust fund. This included 2,400 cubic yards of contaminated soil removed to
the extent practicable and groundwater extraction and treatment of an estimated 328,500 gallons of
affected groundwater. Carolina Coatings has submitted supporting information demonstrating that
continued operation of best available technology will not result in significant long term remediation
of the site to the groundwater quality standards in 15A NCAC 2L .0202 and contend that continued
operation of the existing system will be a serious financial burden without equal or greater public
benefit. The annual cost to operate; the groundwater remediation system is projected to be $48,000.
Notable factors about ground water quality/flow characteristics and remediation
to date:
-The affected area of ground water impact was estimated to be 10,000 square feet (surface
area) and less than 45 feet (vertically) below ground surface at the beginning of remedial
efforts. As of the last sampling event, only one monitoring well contained contamination
above the title 15A NCAC 2L .0202 Groundwater Quality Standard for Benzene. ( Note the
concentration observed for: Benzene was 2 parts per billion [ppb] which has a standard of 1
part per billion [ppb ]). .
-At the last sampling event, the recovery well was not collecting ground water with
detectable concentrations of any of the target compounds.
-The ground water flow velocity at this hydrogeologic setting has been estimated to
be on the order of 1.1 feet per year. Using this rate of movement, it would take 100 years
for ground water to migrate from the source area to the property/variance boundary.
-At present there is no indication that contaminates have reached the fractured bedrock
portion of the aquifer in this area.
3
Based upon all information collected to date, the limited extent of contamination, the ability
of the contaminants to attenuate, the extremely low probability of any off-site impacts and the
financial burden of continued remediation without significant environmental improvement, it is my
recommendation that the EMC consider granting the variance request without further monitoring
requirements.
The following is a listing of attachments for the hearing officer's report submitted for the
Carolina Coatings Incorporated variance request:
Attachment# 1 -Public Notice
Attachment# 2 -Mooresville Regional Office Staff Presentation and Hearing Registrations
Attachment# 3 -Written Comments
Attachment# 4 -Memoranda Related to the Variance Request for Carolina Coatings
Incorporated
4
Attachment # 1 -PUBLIC NOTICE
• .
Attachment # 2 -MOORESVILLE REGIONAL
OFFICE STAFF PRESENTATION AND
HEARING REGISTRATIONS
Attachment # 3 -WRITTEN COMMENTS
Attachment #4 -Memoranda Related to the
Variance Request for Carolina Coatings
Incorporated
''"'!"'
Attachment# 1 -PUBI.JC NOTICE
-· .. r NOTICE OF VARIANCE APPLICA'I'ION AND HEARING
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
Notrce is hereby given of a variance application and public hearing to be held by the Department of
Environment and Natural Resources on behalf of the Environmental Management Commission. The hearing
concerns a request for a variance from the Groundwater Quality Standards of 15A NCAC 21 .0202 and the
Corrective Action requirements of 15A NCAC 2L .0106 (j) for a site at 711 Pressley Road in Charlotte, North
Carolina. The Division of Water Quality refers to this site identifi_ed in the variance request as Groundwater
Incident # 8949. This property consists of 6.17 acres of land was previously owned by the proprietor of
Carolina Coatings Incorporated, Mr. Linwood Carter, and was used as a solvent-based paint mixing facility
until 1991. The property is now owned by Wattyl Paints of Atlanta, Georgia. Carolina Coatings Incorporated
is entirely responsible for cleanup for Groundwater Incident# 8949. This variance application from Carolina
Coatings Incorporateg, was received for review by the Departm<!nt on December 9, 1996.
The property where the release of volatile org:mic substances ha.s occurred is located as follows: Inside
the city limits of Charlotte, North Carolina. Take Interstate 77 in. Charlotte and exit onto South Tryon Street
(NC 49) and proceed one block north. Tum left (west) onto Pressley Road for 0.38 miles. The former
Carolina Coatings facility is located on the left. The site is lis\ed in Mecklenburg County tax records as
Parcel Number 145-291-03.
Carolina Coatings Incorporated requests that the Environmental Management Commission grant the
following variance to its rules under the authority of 15A NCAC 2L .0113 so that it"does the following:
(l) Allow concentratio·ns of Benzene, Ethylbenzene, and Xylene (-o,-rn, and p) to remain at levels
above 15A NCAC 2L .0202 Groundwater Quality Stand.1Ids as analyzed on October 9, 1997 in all
monitoring wells. These concentrations will be required to remain within the property boundaries of
71 I Pressley Road. Pursuant to the transfer of ownership of this property in 1991, Mr. Carter had
environmental assessments conducted of soils and groundwater at this site. Benzene, Ethylbenzene,
Toluene and Xylene (BETX) were found in soils around this site and growidwate~ samples showed
the presence of several volatile organic compounds such as Benzene, Erhylbenzene and Xylene.
Since the transfer of ownership of this property to Wattyl Paints all solvent-based paint mixing
operations have ceased and weremoved to Atlanta, Georgia. Only l:ltex water•based paint mixing has
been conducted at this property since 1991. All potential sources of groundwater contamination have
been identified at this property by Carolina Coatings Incorporated. The entire property at 711
Pressley Road is located in an area with a· mixture of commercial, industrial, and residential
development. ·
Site assessments were completed by September 1992 and a remedial action plans for this site
were submitted in late spring 1993. The site assessments revealed a plume of substances in soil and
groundwater. Site assessment information on file in the Mooresville Regional Office shO\vs that the
vertical extent of this plume to be less than 48 feet below the ground surface. This plume was
estimated to have covered an area. of approximately I 0,000 squ3re feet (0.23 acres) prior to the
implementation of corrective actions by Carolina Coatings Incorporated.
From June 2, 1993 through January 1997 concentrations of substances at this site were
significantly reduced by soil removal operations and groundwate: ckmup technologies located at the
sne. A concrete pad and waste water settling tanks were removed during this renovation and clean
l
fill material was used in place of this contaminated soil. In July 1993 the company rnstalled a
groundwater pump-and-treat cleanup system and it began: operation on March 24, 1994.
Except for one monitoring well located in the area where the plume of groundwater
contamination has been identified (Monitoring Well MW-9), concentrations of substances have never
exceeded quantifiable levels. Since December 1994 analysis of samples, MW-9 showed only
margjnal reductions in the concentration of substances in groundwater. Based on gTOundwater
ana1ysis of samples from semi-annual monitoring from 1993 through 1996, the Division of Water
Quality recommended that pump and treat system be turned off to determine if residual concentrations
of substances would increase, if no treatment system were operating. From August 27, 1996 t'ru'ough
September 3, 1996 the cleanup system ceased operation. A groundwater sample ta.\en on September
3, 1996 demonstrated upward "rebounding'' of Benzene above the Groundwater Quality Standard in
1 SA NCAC 2L .0202 in monitoring well MW-9. Analysis of a groundwater sample taken on Octa ber
9, 1997 through showed the Ethylbenzene or Xylene concentrations did not exceed detection Ii.re.its
and th~ Benzene concentration was 0.002 milligrams per liter. The Groun·dwater Qu:ilrty Stand.a.rd
for Benzene is 0.001 milligrams per liter. ;
The company has also conducted monitoring at a recovery well near monitoring well ~~ -9. Tnis
recovery well is used as a sump to collect groundwater and other liquids for removal by the purr.;i-2..11d-
treat cleanup systems. Groundwater monitoring at thi= inlet of this recovery well sam;;led on
September 30, 1996 and October 30, 1996 showed that concentrations ofBTEX were below detectable
levels. This monitoring occurred after the cleanup system had been turned off for a period of five
days.
Based on concentrations of substances found in monitoring wells, substances found in frie well
used for recovery of contaminants, and calculations of the time it would take for substances to ::ii grate
to receptors at surrounding properties, the company does not believe that a variance will result ir~ an
adverse impact to the public. There are no drinking water supply wells at adj a cent properties and the
nearest water supply wells are 2,300 feet cross gradient from the site. No water supply intakes from
surface water bodies are located within ½. of a mile from the site. Public water supply bes are
deemed too shallow to be impacted by subsmnces at 711 Pressley Road.
(2) Allow for the restoration of groundwater without requiring continued remedial ac::or....s in
accordance with l5A NCAC 2L .0106G). Carolina. Coatings Incorporated has submitted su;::;,or.ing
infonnation demonstrating that the continued application ofbest available technology will r.ct result
in significant long term remediation of the site to the Groundwater Quality Standards con::ii:ie-::5 in
15A NCAC 2L .0202. This is due to the high probability that continued remediaticn ac~ivit:es a: the
site will not significantly reduce contaminant levels below Groundwater Quality Scar:dards in : 5A
NCAC 2L .0202.
Since discovery of the release in 1991, Carolina Coatings Incorporated has dispos e::i of;; :o~l of
2,400 cubic yards of contaminated soil during site renovation operations in June 1993. Carv:ina
Coatings Incorporated has submitted infonnation showing that the compar.y h:is tre::.:ed ;; :o~J of
328,500 gallons of groundwater via pump-and-treat technology. The company re~-::m.s :hat:: !o:z.l of
$ 493,000 has been expended to design and install the remediation system, Oferate the s:,·~~m,
monitor progress of cleanup activity, and cle:inup this sfte. Carolina Coatings Inc.:rpo:-ateci :-e!:~ves
that the public will not benefit from continued cleanup using present techr..ology at ::1e s::~ c:--th~
alternatives discussed and that a variance is the most effective means of deali::g w:th r~::-.a:::ing
concentrations.
' I
I
I
'
Attachment # 2 -MOORESVILLE REGIONAL
OFFICE STAFF PRESENTATION AND
HEARING REGISTRATIONS
AS A VISUAL AID, I HA VE PROVIDED COPIES OF TWO SITE MAPS. THE FIRST MAP
SHOWS THE SITE IN RELATION TO THE SURROUNDING AREA. THE SECOND :MAP
SHOWS THE SITE IN DETAIL AND THE LOCATIONS OF GROUNDWATER MONITORING
WELLS.
I WOULD LIKE TO BEGIN BY SUMMARIZING THE H1STORY OF THE CONTM1INATION
AT THIS SITE:
IN 1991 AND 1992, SOIL AND GROUNDWATER SAMPLES WERE COLLECTED FROM THE
CAROLINA COATINGS PROPERTY LOCATED AT 711 PRESSLEY ROAD IN CHARLOTIB.
SAMPLES COLLECTED NEAR A CONCRETE PAD AREA BEHIND THE CAROL:r.-;A
COATINGS WAREHOUSE BUILDING WERE FOUND TO CONTAIN ETHYLBENZE~"E,
BENZENE AND XYLENE. THESE ARE ALL PETROLEUM COMPOUNDS.
BASED ON THE ANALYTICAL RESULTS OF THIS SAMPLING, APPROXI?vL.\ TEL Y 850
CUBIC YARDS OF SOILWERE DETERMINED TO BE CONTAMINATED. IN ADDITIO~,
SHALLOW GROUNDWATER UNDERNEATH APPROXIMATELY 1/4 OF AN ACRE AT lliE
SITE CONTAINED BENZENE, ETHYLBENZENE AND XYLENE AT CONCENTRATIONS
ABOVE THE NORTH CAROLINA GROUNDWATER STANDARDS.
IN MARCH OF 1993, THE GROUNDWATER SECTION RECEIVED A CO;\,fPLETE
REMEDIAL ACTION PLAN FOR CONTAMINATED SOIL AND GROUNDWATER AT IBE
SITE. THE REMEDIAL ACTION PLAN CALLED FOR THE EXCAVATION OF ALL OF TI-IE
CONTAMINATED SOIL ON THE PROPERTY AND THE TRANSPORT OF THIS SOIL TO A
PERMITTED SOIL REMEDIATION FACILITY. IN ADDITION, THE PLAN PROPOSED TO
PUMP CONTAMINATED GROUNDWATER TO THE SURFACE, TREAT IT USING A
CARBON FILTER, AND REINTRODUCE IT TO THE GROUND.
IN MAY OF 1993, APPROXIMATELY 1500 CUBIC YARDS OF SOIL WAS EXCA VAITD
FROM THE SITE AND TRANSPORTED TO THE CAROLINA ST ALITE IBERMAL
:
TREATMENT FACILITY. AFTER BACKFILLING THE EXCAVATION, A GROUNDWATER
RECOVERY WELL AND A GROUNDWATER MONITOR WELL WERE INSTALLED IN
ORDER TO TREAT THE CONTAMINATED GROUNDWATER.
IN MARCH OF 1994, THE GROUNDWATER PUMP AND TREATMENT SYSTEM BEGA.i\l'
OPERATING. THE PUMP AND TREATMENT SYSTEM CONTINUED TO OPERA TE UNTIL
JANUARY OF 1997. DURING THAT TIME PERIOD, MORE THAN 328,000 GALLONS OF
GROUNDWATER WERE TREATED.
BETWEEN MARCH OF 1994 AND MARCH OF 1997. THREE MONITOR WELLS WERE
SAMPLED ON A QUARTERLY BASIS TO DETE~INE GROUNDWATER QUALITY.
DURING THIS PERIOD OF MONITORING, BENZENE,,ETHYLBENZENE AND XYLENES
WERE DETECTED IN ONLY ONE WELL, MONITOR WELL #9.
THE MAXIMUM CONCENTRATION OF BENZENE DETECTED IN MONITOR WELL #9
BETWEEN MARCH OF 1994 AND MARCH OF 1997 WAS 27 MICROGRAMS PER LITER.
BENZENE WAS NOT DETECTED IN MONITOR WELL #9 DURING THE LAST
QUARTERLY SAMPLING EVENT IN MARCH OF 1997.
THE MAXIMUM CONCENTRATION OF ETHYLBENZENE DETECTED IN MONITOR WELL
#9 BETWEEN MARCH OF 1994 AND MARCH OF 1997 WAS 32 :MICROGRAMS PER LITER
ETHYLBENZENE WAS NOT DETECTED IN MONITOR WELL #9 DURING THE LAST
QUARTERLY SAMPLING EVENT IN MARCH OF 1997.
THE MAXIMUM CONCENTRATION OF XYLENE DETECTED IN MONTIOR WELL #9
BETWEEN MARCH OF 1994 AND MARCH OF 1997 WAS 860 :MICROGRAMS PER LITER.
XYLENE WAS NOT DETECTED IN MONITOR WELL #9 DURING THE LAST QUARTERLY
SAMPLING EVENT IN MARCH OF 1997.
IN JANUARY OF 1997, THE GROUNDWATER SECTION ALLOWED THE GROUNDWATER
PUMP AND TREAT SYSTEM TO BE TURNED OFF BECAUSE THE EXISTING
GROUNDWATER PUMP AND TREAT SYSTEM COULD NOT ADDRESS TilE REMAINING
LOW LEVELS OF GROUNDWATER CONTAMINATION.
IN OCTOBER OF 1997, FIVE MONITOR WELLS AT THE SITE WERE SAMPLED. THE
ONLY PETROLEUM COMPOUND DETECTED IN THE WELLS WAS BENZENE. BENZENE
WAS ONLY DETECTED IN MONITOR WELL #9. THE CONCENTRATION OF BENZENE
AT THE TIME OF SAMPLING WAS 2 MICROGRAMS PER LITER. THE NORrH CAROLINA
GROUNDWATER STANDARD FOR BENZENE IS 1 MICROGRAMS PER LITER.
NOW I WOULD LIKE TO SUMMARIZE TIIE VARIANCE REQUEST:
CAROLINA COATINGS INCORPORATED IS REQUESTING A VARIANCE TO THE
GROUNDWATER STANDARDS FOR BENZENE, ETHYLBENZENE AND XYLENE FORIBE
PROPERTY AT 711 PRESSLEY ROAD. THE NORTH CAROLINA GROUND\VATER
STANDARD FOR BENZENE IS I MICROGRAM PER LITER AND THE MOST RECENT
ANALYTICAL RESULTS INDICATE THAT BENZENE IS PRESENT IN GROUNDWATER
ON THE PROPERTY AT 2 MICROGRAMS PER LITER. THE NORTH CAROLINA
GROUNDWATER STANDARD FOR ETHYLBENZENE IS 29 MICROGRAMS PER LITER
AND THE MOST RECENT ANAL YIICAL RESULTS IND I CA TE THAT ETIIYLBENZENE IS
NOT PRESENT IN GROUNDWATER ON THE PROPERTY. THE NORTH CAROLINA
GROUNDWATER STANDARD FOR XYLENE IS 530 MICROGRAMS PER LITER AND rnE
MOST RECENT ANAL YilCAL RESULTS INDICATE TIIAT XYLENE IS NOT PRESENT~
GROUNDWATER ON THE PROPERTY .
I HA VE COMPLETED A REVIEW OF THE INFORMATION IN THE VARIAN CE AND TI-IE
GROUNDWATER SECTION'S FILE FOR THIS INCIDENT. BASED ON MY REVIEW, I
BELIEVE THAT THE FOLLOWING STATEMENTS MADE IN THE VARIAN CE REQUEST
ARE ACCURATE AND SHOULD BE CONSIDERED:
1) THERE ARE NO WATER SUPPLY WELLS WITHIN 2000 FEET OF THE AREA OF
REMAINING GROUNDWATER CONTAMINATION.
2) THE CLOSEST SURFACE WATER BODIES TO THE REMAINING CONTAMINATION
ARE TWO INTERMITTENT TRIBUTARIES TO SUGAR CREEK. THESE INTERMITT ANT
TRIBUTARIES ARE APPROXIMATELY 1,100 FEET FROM TIIB AREA OF GROUNDWATER
CONTAMINATION.
3) THER,E ARE NO ON-SITE EXPOSURE PATHWAYS FOR THE CONT~INATED
GROUNDWATER.
4) COMPUTER MODELING INDICATES TIIATTHE GROUNDWATER CONTAfvfiNATION
WILL NOT AFFECT ADJACENT PROPERTIES.
5) THE EXISTING PUMP AND TREAT SYSTEM WOULD REQUIRE MODIFICATION IN
ORDER TO BE ABLE TO ADDRESS THE REMAINING LOW LEVELS OF PETROLEUM
COMPOUNDS.
6) NO OTHER CURREN1L Y AVAILABLE TECHNOLOGIES COULD BETTER ADDRESS
THE REMAINING CONTAMINATION.
7) 493,000 DOLLARS HA VE BEEN SPENT ADDRESSING THE CONT Afv1INA TION AT THIS
SITE. IT WOULD COST 48,000 DOLLARS PER YEAR TO CONTINUE TO OPERA TE IBE
SYSTEM, NOT INCLUDING THE COST OF SYSTEM MODIFICATIONS.
8) GROUNDWATER INFLUENT INTO THE TREATMENT SYSTEM HAS DECREASED TO
LESS THAN ANALYTICAL DETECTION LIMITS.
9) THE AREA OF REMAINING SHALLOW GROUNDWATER CONT AMINA TI ON IS
I
ESTIMATED TO BE LESS THAN 1/4 ACRE IN EXTENT .
l 0) THE REMAINING CONTAMINANTS HA VE THE CAPACITY TO DEGRADE AND
ATTENUATE.
Attachment # 3 -WRITTEN COMMENTS
-·-·---
SALE
Stoever Properties, Inc.
704-333-9483
August 17, 1999
Mr. David Hance
EHNR -DWQ -Groundwater Sec.
P.O. Box 29578
Raleigh. NC 27626-0578
Re: 711 Pressley Road #8949
Charlotte, NC
Dear Mr. Hance:
LEASE
I went to your meeting in Charlotte, and unfortunately they could not get the
recorder to work and I left after 30 minutes.
DEVELOPMENT
Mr. Layne, owner of 801 Pressley Road, has reviewed your request for a variance,
and we do not see any reason to oppose this. Mr. Layne's one concern is: Whose
responsibility is it if any of the solvent leeched on to his property? Please give us
an answer to this by the end of August
Sincerely,
Meredith D. Stoever
cc: Mr. Linwood Carter
605 Hermitage Court• Charlotte, NC 28207
Fax [phone]
'AUGUST 2ND> 1999
~1. CARL BAtLEY, JR.
ASSISl'ANT CHIEF FOR PLANNING
GROUNDWATF.R SECTION
NORTH CAROLINA DEPARTMENT OF
ENVlROMAENT A..~D NATURAL RESOURCES
MR. BAILEY:
Vr-'E AR£ lN RECEi.PT OF YOUR LETTER DATED JULY 29TH, COPY
A Tf ACHED. I HA VE READ AND REREAD THE TEXT ANDTO BE
HON"_"'~T WE Ai"lli NOT SURE WHAT \l/E COULD/SHOULD DO.
WE DO KNOW -nvo TI-i.iNGS • # 1 WE WANT T.nE RIGHT .
·'\'"\ ENVIRONMENTAL THING DON£ #2 AS PROPERTY OWNERS W"E WA NT
:)/ OUR SE.t VES PROTECTITD FROM POLLUTION' AND ANY P'JSSIDLE
DF.CRE/\SE IN PROPERTY VALUE DUE TO RELATED PROBLEMS.
...... :,..,.
1S THERF. A ST AfF AOVISF.tJfENT PERSON OR COMMITTEE THAT \.VOULD
H..'ql.P US RATHER THAN OUR COMPANY HAVL~G TO HIRE A PRIV /-.IT
CONSUL TANT OR LEGAL COl:'NCll. 'l
ANY HELP A°N-0 CONSIDERATION WOULD BE APPRECIATED .
'Crf 1.,1,;y
1TH
IONS
CC: DA VlD HI\.NCc
309 MORNIN3SIOE ROAC O CHARLOTTE, NC 29214 0 [phone] □ FAX (704) 3i4-14o:)5
Attachment #4 -Memoranda Related to the
' Variance Request for Carolina Coatings
Incorporated
DIVISION OF WATER QUALITY
GROUNDWATER SECTION
June 24, 1999
MEMORANDUM
To:
From:
Subject:
Kerr T. Stevens
Arthur Mouberry #
Request for Variance from 15A NCAC 2L .0202 and 15A
NCAC 2L .01060) for a Site Owned by the Carolina Coatings Incorporated at 711
Pressley Road in Charlotte, North Carolina (Groundwater Incident Number
8949).
From 1971 through 1991, Mr. Linwood Carter operated a portion of the Carolina
Coatings Incorporated property as a paint blending facility located at 711 Pressley Road in
Charlotte, North Carolina. This site is at the intersection of Billy Graham Parkway and US
Interstate 77. In 1991, Mr. Carter sold this facility to Wattyl Paints of Atlanta, Georgia. The
new owner of this facility moved all solvent based mixing processes out of North Carolina I 991.
Mr. Carter maintains cleanup responsibilities for substances found at this site.
The Carolina Coatings facility consists of a total of 47,000 square feet of warehouse and
office space on 6.17 acres of land. During the period this property was owned by Mr. Carter,
Carolina Coatings manufactured paint using a batch mixing process which blended latex
emulsions with dry pigments, wetting agents, water, defoamers and other ingredients. Trus
process required the storage of empty fifty-five gallon drums on a concrete pad located rear of
the building. Waste water settling tanks were also located in this area. During the course of
business operations leaks had occurred in dmms located at this site and from the wastewater
settling ponds.
PLtrsuant to the transfer of ownership of this property in 1991, Mr. Carter had
environmental assessments conducted of soils and groundwater at this site. Ethylbenzene.
Toluene and Xylene were found in soils around this site. Analysis of groundwater samples
showed the presence of several volatile organic compounds, Benzene, Ethylbenzene, Toluene
and Xylene. Since 1991 only latex water-based, products have been processed at 711 Pressley
Road by Wattyl Paints. The owner of Carolina Coatings Incorporated, Mr. Linwood Carter, is
entirely responsible for cleanup of this release which is shown in Division of Environmental
Management files as Groundwater Incident Number 8949.
Pursuant to title 15A NCAC 2L .0113(c) variance applicarions are required to have
specific information in order to adequately review a request. The Carolina Coatings variance
request is contained in a report titled "Variance Reguest -Carolina Coatings Site -Charlotte,
North Carolina, December 9, 1996. Dames and Moore N.C. Job No.23995-002-200.". In
addition, memoranda and other correspondence are included with this request. The information
submitted by Dames and Moore on behalf of the Carolina Coating Incorporated appears to meet
the requirements of ISA NCAC 2L .0113(c) and is summarized as follows:
Rule .0113(c)(l): Resolution by the County or goveming Board:
Car_olina Coatings Incorporated has always been a privately owned
company. No resolution is necessary. '
Rule .0113(c)(2): A description of past. existing or proposed activities that would result in a
dischar 2e of contaminants into groundwater:
The former Carolina Coatings Incorporated is located inside the city limits of
Charlotte, North Carolina at 711 Pressley Road (Mecklenburg County Tax
Identification Number 145-291-03). The report titled "Variance Request -Carolina
Coatings Site -Charlotte, North Carolina, December 9. 1996, Dames and Moore
N.C. Job No.23995-002-200" contains the relevant information about this site. The
site consists of approximately 6.17 acres of land. 1
A Notice of Violation was issued to Carolina Coatings Incorporated by the
Department on August 28, 1992. Remedial Action Plans were submitted to the
Mooresville Regional Office on June 29, 1992 and March 23, 1993. On January 18,
1994, a discharge permit for an on-site infiltration gallery was authorized by the
Division of Water Quality (WQ0007993). Details of soil and groundwater corrective
actions are documented in a report titled "Soil and Groundwater Remediation
Report (April 19, 1994)" at the Mooresville Regional Office. All potential sources
of groundwater contamh1ation were identified at this property by the company.
This property at 711 Pressley Road in Charlotte, North Carolina, formerly owned
by Mr. Linwood Carter, and is in an area with a mixture of commercial, industrial,
and residential development.
The comprehensive site assessment and other investigations revealed
Benzene, Toluene, Ethylbeozene, and Xylene (o, m, and p) (BETX) in the
groundwater and soil beneath the site. This area was located at the southwest
corner of the building near an 88 foot by 66 foot concrete pad and three small
wastewater settling tanks. This was where the company stored chemicals and
performed batched mixing operations for solvent-based paints. This area is
2
I
approximately 10 feet from the northwest property line and 75 feet from the
southwest property line. The entire property at 711 Pressley Road is surrounded
by a fence. This plume was estimated to have covered an area of approximately
10,000 square feet {0.23 acers) prior to the implementation of correctiv_e actions by
the Carolina Coatings Incorporated. According 'to information at the Mooresville
Regional Office the vertical extent of this plume is believed to be less than 48 feet
below the ground surface. :
Carolina Coatings Incorporated implemented cleanup of soils at this site in
September 1992 with the removal of 900 cubic y;,1.rds of soil that exceeded the 50
milligram per kilogram target cleanup level. Between June 2, 1993 and June 25,
1993, the company removed an additional 1,500 cubic yards of contaminated soils.
Excavated soils were treated offsite and clean fill material was used as backfill. As a
result of soil remediation, the concrete pad was removed and subsequently replaced.
In July 1993 the company installed a pump-and-treat system with a sing.le
groundwater recovery well (RW-1) located near the south corner of the former
concrete storage pad as shown in Figure 6 of the variance. From March 23, 1994
through January 1997 a total of 328,500 gallons of groundwater has been treated Yia
pump-and-treat technology. The treated discharge was sent to an upgraident
infiltration gallery. An infiltration gallery is a closed-loop conveyance that allows
water and other fluids, discharged through the pump-and-treat system, to be sent
back into the subsurface where they recirculated. into the cleanup system for
continual treatment. An infiltration gallery may also serve to enhance intrinsic
biodegradation of contaminants by introducing dissolved oxygen in the subsurlace
which may stimulate biologic decomposition of some dissolved substances. Non•
Discharge Permit WQ0007993 was issued on January 18, 1994 for the infiltration
gallery. The Groundwater Section staff have recommended that, if the variance
request is granted, no permit for this infiltration gallery is to be reissued. The
company's environmental consultant, Dames and Moore, reports that this device
will no longer be used once the variance is granted.
The Division of Water Quality required Carolina Coatings Incorporated to
perform groundwater monitoring to determine the vertical and lateral extent of
contamination at the site. Table l of the report titled "Variance Request -Carolina
co-atin2s Site -Charlotte, North Carolina, December 9, 1996, Dames and Moore
N.C. Job No.23995-002.:.200 11 shows that three of six monitoring wells were sampled
from March 1994 through September 1996 on a quarterly schedule. Groundwater
samples were analyzed using US Environmental Protection Method 8020. Page 6 of
the variance request shows that only Monitoring Well# 9 has bad concentrations of
Benzene, Ethylbenzeoe, and Xylene above the Groundwater Quality Standards in
15A NCAC 2L .0202. Toluene has never appeared in any of the monitoring wells at
a concentration in excess of the Groundwater Quality Standard in 1 SA NCAC 2L
.0202. Table 2 of the report titled "Variance Re·guest -Carolina Coatings Site -
Charlotte, North Carolina, December 9, 1996, Dames and Moore N.C. Job
No.23995~002-200" shows that the highest concentration of Benzene, Ethylbenzene,
and Xylene have been found in this well. The highest concentration of Benzene in
exceedence of the Groundwater Quality Standard was 0.027 milligrams per liter or
3
27 micrograms on September 3, 1996. The highest concentration of any substance
in exceedence of the ISA NCAC 2L .0202 Groundwater Quality Standard found at
this site was Xylene (o,p,m). Xylene appeared at the December 1994 monitoring
event at 0.860 milligrams per Liter or 860 micrograms/Liter.
As shown on Table 1 of the report titled ;'Variance Re q uest -Carolina
Coatine s Site -Charlotte. North C arolina, December 9. 1996, Dames and Moore
N.C. Job No.23995-002-200"from March 29, 1994 through October 30, 1996, the
company conducted analysis of samples from Recovery '\Vell # 1 on the influent side
of the cleanup system to determine the effectiveness of the pump-and-treat cleanup.
This data shows that the source of the eroundwater contamination at this site has
been significantly reduced such that the plume can no longer be detected.
Based on the results of the groundwater monitoring and recovery well
monitoring in September and October 1996, the Carolina Coatings reqµested a
variance and tha.t the pump and treat groundwater cleanup system be shut off. In
January 1997 the Mooresville Regional Office agreed that actin cleanup should be
discontinued. Based on the results of groundwater monitoring and monitoring of
influent samples in the recovery well from the p1Jmp and treat cleanup system the
cleanup system was turned off. This variance request encompasses the entire
1
property at 711 Pressley Road in Charlotte, North Carolina.
Potential sources of groundwater contam!:nation in the area are discussed in
Pages 9 through 11 and in Appendix A of the report titled "Variance Re g uest •
Carolina Coatings Site• Charlotte, North Carolina. Decemb er 9, 1996. Dames and
Moore N.C. Job No.23995-002-200." . Appendix A shows Vista Site Assessment
Reports of these properties with maps. Potential sources of groundwater
contamination are summarized as follows:
1) The property at 711 Pressley Road formerly owned by Carolina
Coatings Incorporated (Mecklenburg County Tax Identification
Number 145-291-03). This site is now owned by Wattyl Paints. The
Vista Site Assessment Report lists this site on the state "CERCLIS"
and as a ''Large Quantity Generatbr" of hazardous wastes.
2) The property at 807 Pressley Road known as The Gifford-Hill
Company located 1/10 of a mile northwest of the site. This property is
upgradient from the site and is listed with the Division of \Vaste
Management-Underground Storage Tank Section as having reported
a leaking petroleum underground storage tank on June 1, 1989.
3) Property at 927 Pressley Road known as Climate Conditioning of
Charlotte located 0.2 miles northwest of the site. This property is
upgradieot from the site and is listed with the Division of \Vaste
Management-Underground Storage Tank Section as ha,·ing reported
a leaking petroleum underground storage tank on December 27, 1994.
In addition, Page# 11 of the "Vista Site Assessment Report,, shows
4
4)
5)
6)
7)
8)
that at one time this company removed three underground storage
tanks that contained gasoline.
Observer Transport Company Iodated 0.3 miles northwest of the site
at 1001 Pressley Road. This property is upgradient from the site and
is listed with the Division of Waste Management-Underground
Storage Tank Section as having rt ported three gasoline leaks on April
12, 1988, April 17, 1992, and Apdl 15, 1994. Page# 12 of the "Vista
Site Assessment Report" shows thet two of these tanks contained
"Gasoline" and "Diesel Fuel". The third tank contained a product
described as "Petroleum Other".
Xerox Corporation located 0.35 miles northwest of the site at 4740
Dwight Evans Road. This property is upgradlent from the site and is
listed with the Division of Waste Management-Underground Storage
Tank Section as having reported a leaking petroleum underground
storage tank on September 30, 1986. Page# 12 of the "Vista Site
Assessment Report" shows that thts tank contained "Gasoline" and
"Diesel Fuel".
White Machines which is located 0.53 miles north of the site at 4300
Barringer Drive. This property is cross-gradient from the site and is
listed with the Division of Waste Management-Undergro~nd Storage
Tank Section as having reported a leaking petroleum underground
storage tank on March 21, 1990. Page# 13 of the "Vista Site
Assessment Report'' shows that this tank contained "Gasoline" and
"Diesel Fuel".
Piedmont Natural Gas which is located 0.4 miles east of the site at
Verbena & Yancey Streets. This p\-operty is downgradient from the
! site and is listed in the variance request as having reported a leaking
petroleum underground storage tank on January 15, 1990. Page# 13
of the "Vista Site Assessment Report" shows that this tank coo tained
"Gasoline" and "Diesel Fuel".
Industrial Truck Sales which is located approximately 0.1 miles east
of the site at 3910 Stuart Boulevard. This property is downgradienr
from the site and is listed in the variance request as a "RCRA smaU
quantity generator". Page# 9 and# 10 of the "Vista Site Asse-ssment
Report" shows that underground storage tanks have also been at this
property. Three tanks have been removed consisting of one 8,000
gallon gasoline tank, a 1,000 galloh oil tan~ and a 250-gaUoa oiJ tank.
One 500-gallon oil tank is list as "active/in service" at this property.
5
9) Ryder Truck Rental Incorporated which is located approximately
0.11 miles east of the site at 3901 Stuart Boulevard. This property is
dowogradient from the site and is listed in the variance request as a
"RCRA small quantity generator". Page# 10 and 11 of the "Vista
Site Assessment Report" shows that eight "in service" underground
storage tanks are present at this property containing ''gasoline, diesel
fuel, motor oil, oil" and a fluid described as "hazardous".
10) Chemlawn Services Corporation which is located approximately 0.03
miles southeast at 655-R Pressley ~oad. This property is .located
downgradient from the site. Appendix A shows that this site once had
a 2,000 gallon underground storage tank for diesel fuel. This tank is-
listed as "removed" from the property.
11) Page# 9 of the "Vista Site Assessment Report" shows two "in service"
underground storage tanks at the RSM Company located at 811
Pressley Road located approximately 0.09 miles northwest. This
property is upgraident from the site.
12) Page# 12 of the "Vista Site Assessment Report" shows that Ridgeway
Chemicals Incorporated has three underground storage tanks at 651
Michael Wylie Drive located 0.25 miles northeast of the site. These
tanks are listed as "active/in service" in the report. A 1,000 gallon
tank was removed from this site. The contents of all four tanks are
reported as "unknown". This property is cross-gradient from the
site ..
13) Pressley Road ( a public roadway).
14) Public sewer lines and other utilities in the area.
15) Southern Railroad (a private rail company).
In addition, Page #15 through Page# 17 of Appendix A shows eight known
sources of groundwater contamination in the general area near 711 Pressley Road.
Due to inadequate information on the location of these sites, it is not possible to
represent them 011 maps contained in Appendix A. Scaled diagrams of tbis site are
found in Figures# 1 through# 4 and Figure# 11 ·'or the report titled "Variance
Re q uest-Carolina Coatings Site -Charlotte, N o rth Carolina, December 9, 1996,
Dames and Moore N.C. Job No.23995-002 -200." :.
6
Rule .0113(c)(3 ): Description of the proposed area for which the variance is requested .... :
Maps of the area are shown in Figures 1 through S of the report titled
"Variance Request -Carolina Coatings Site -Charlotte, North Carolina, December
9, 1996, Dames and Moore N.C. Job No.23995•002-200.". The property at 711
Pressley Road for which Carolina Coatings Incorporated has requested this
variance for Groundwater Incident Number 8949 is within an area consisting of a
mixture of residential, commercial and industrial development. The map on Figure
11 shows that the property is bordered on its east side by Pressley Road and four
adjacent properties border the Carolina Coatings site on its north, south and west
sides. The Southern Railroad Line is to the west within 1,000 feet of the area in
which the release of substances occurred. The property on the west side is vacant
land identified under Mecklenburg County Tax ~dentification Number 145-291-07
and owned by Mr. Linwood Carter, who is also the proprietor of Carolina Coatings
Incorporated. In applying for a variance at 6500 North Tryon Street, Carolina
Coatings Incorpor-ated did not include this adjacent property or any portion of it in
the request.
Table 4 in the report lists adjacent property owners by Mecklenburg County
Tax parcel numbers and addresses. The last column of this table locates these
adjacent properties relative to the site at 711 Pressley Road. Figure 11 sbo,,·s these
properties and owners from a tax line map in Book 145, Pages 27-29 (ReYised
5/7/96). .
Figure 4 of the variance request also shows that the area of groundwater and
soil contarnination prior to remedial actions was of an amorphous shape, much of
which extended beneath the former concrete pad and settling tanks. Since soil
removal activities and the implementation of the pump and treat cleanup system,
the area where substances are known to exist is shown in Figures 7 through 12 of the
variance request. These figures reveal that the area in which substances pe.r-sist at
concentrations in e:x:ceedence of the Groundwater Quality Standards in 15A ~CAC
2L .0202 is roughly in the shape of an ellipse. The groundwater contamination that
the Carolina Coatings Incorporated is responsible for encompasses both the
recovery well and Monitoring Well# 9 and appears limited to this area. Figures 8
through 10 and Figure 12 of the report shows that substances at 711 Pressley Road
Street have not migrated onto adjacent properties at concentrations aboye
Groundwater Quality Standards in ISA NCAC 2L .0202. This variance is for al)
the land entirely within the property boundaries of 711 Pressley Road for which
Carolina Coatings Incorporated has cleanup responsibilities.
Pages 11 through 13 of the report titled 11 Variance Request -Carolina
Coatings Site -Charlotte, North Carolina. December 9, 1996, Dames and :'.\Ioore
N.C. Job No.23995-002-200" discusses groundwater contaminant migration and the
potential impact to water supply wells and surface streams in the area. Two water
supply wells are located within one-half mile of the site. These wells are 2,300 feet
south of the Carolina Coatings property at Yorkmont Road and Loch lane Drive.
The company could not ascertain if these water supply wells are currently in use as
7
a source of drinking water supply or other uses. Based on water use data and
hydrogeologlc conditions in the general area, Carolina Coatings Incorporated does
not believe that this variance will have an effect on these wells. Based groundwater
flow calculations, the company does not believe that the variance will Impact any
receptors near 711 Pressley Road.
Rule .0U3 (c)(4}: Su pportine Information to establish that the variance will not endan e er
the p ublic health and safe ty ... :
This part of the variance concerns Groundwater Quality Standards shown in
15A NCAC 2L. 0202 and has been requested for Benzene, Ethylbenzene, and
Xylene(-o,-m, and p). In order to assess health impacts, groundwater sampling was
conducted at on-site monitoring wells to assess the extent of contamination, the
concentration levels of substances, and the movement of substances to adjacent
properties. Groundwater monitoring from Carolina Coatings Incorporated
indicates that substances released at this site do not pose a hazard to the public. As
shown in Figure S, nine monitoring well were originally installed at 711 Pressley
Road by the company. During site renovation to remove soil and r-epair the
concrete storage pad, two of these wells (Monitoring Wells MW# 2 and MW# 8)
were abandoned by the company prior to the implementation of groundwater
cleanup.
Carolina Coatings has conducted quarterly groundwater sampling at
Monitoring Well MW# 3, Monitoring Well MW# 7, and Monitoring Well M\V # 9
from March 1994 through October 1997. Monitoring Well MW# 3 is located
upgradient approximately 125 feet to 150 feet from the area in which the release of
substances occurred at the northwest property line. Monitor-ing Well MW# 7 is
located within 35 feet directly to the south-southwest of this ar-ea and is roughly
down-gradient to the area that was impacted by the release. Monitoring Well MW#
9 is within the area of the release and is slightly downgradient from Recovery \Vell
RW # 1. Thirteen separate sampling events occurr-ed during this period. As shown
in an April 19, 1999 letter sent to Groundwater Section, the last sampling and
analysis at all monitoring wells occurred on October 9, 1997. Toluene has never
appeared in any sample taken from monitoring wells from this site above the
Groundwater Quality Standard.
Table 2 of the variance request and data in the April 19, 1999 letter shows
that Monitoring Well MW# 3 and Monitoring Well MW# 7 have never had
concentrations of substance above detectable limits. Only Monitoring \.Vell MW#
9 has shown concentrations of Benzene, Ethylbenzene, and Xylene above the
Groundwater Quality Standards in lSA NCAC 2L .0202. The only substance that
appeared in Monitoring Well MW# 9 during the October 9, 1997 monitoring event
was Benzene at 0.002 milligrams per liter or 2.0 micrograms per liter. The
Groundwater Quality Standard for Benzene is 0.001 milligram per liter or 1.0
microgram per liter. It is also important to note that Table 2 shows several graphs
of the concentrations levels of substances analyzed from Monitoring Well M\V # 9
8
from March 1994 to September 1996. Although Ethylbenzene and Xylene have
been reduced below respective Groundwater Quality Standards, the concentration
of Benzene from samples taken from this well have fluctuated over time. In
September 1995 this concentration was reduced.below the Grou.ndwater Quality
Standard but later "rebounded" to the extent that the Benzene level in this well was
in exceed of the standard during subsequent quarterly monitoring events. In order
to provide additional supporting data for this variance request, Carolina Coatings
Incorporated sampled the downgraideot monitoring wells MW# 5 and MW # 6.
No substances were detected in these wells above Groundwater Quality Standards
in ISA NCAC :ZL .0202 .
. The Division also required the Carolina Coatings Incorporated to evaluate
the effectiveness of groundwater cleanup efforts by examining concentrations of
substances in the recovery well used as a sump to collect dissolved hydrocarbons
from the site. This monitoring effort was necessary to understand the effect pump-
and-treat cleanup bas had on concentrations of constituents at the site. Table 1 of
the report titled "Variance Reguest -CaroUna Coatines Site -Charlotte, North
Carolina, December 9. 1996, Dames and Moore N.C. Job No.23995-O02-2O0''
provides a record of monthly groundwater samp~es obtained at the influent of the
recovery well for the pump-and-treat groundwater remediation system. This
monitoring was conducted from March 29, 1994 through October 30, 1996.
Except for Benzene, concentrations of sub.stances monitored from the
recovery well have never exceeded the Groundwater Quality Standards in ISA
NCAC 2L .0202. Since monthly sampling of this _recovery well influent began in
March 1994, the Benzene concentration has fluct\lated from levels abo\'e the
Groundwater Quality Standard to below detectable limits. The highest
concentration of Benzene reported at this site wa~ 0.0076 milligrams per liter or 7.6
micrograms per lite:r from the May 6, 1994 sampling event. The Groundwater
Quality Standard for Benzene is 0.001 milligram per liter or 1.0 microgram per
liter. Samples taken from September 30, 1996 through October 30, 1996 showed
concentrations of all substances below detectabJe,limits.
From the information shown on Page 13 of the variance request, Carolina
Coatings Incorporated evaluated the impact granting a variance would have on
nearby receptors. The nearest downgradient adjacent property is a small strip of
the vacant land owned by Mr. Linwood Carter which is approximately 110 feet
from the area in which substances were released ~t 711 Pressley Road. Based on an
ave:rage hydraulic conductivity of 0.06 feet per day, an approximate hydrauJic
graident of 0.01 feet per foot, and an effective porosity of 20 percent for silty clay,
the groundwater flow is calculated at 1.1 feet per year. Assuming no contaminant
dilution or attenuation and this figures, it is believed that it would take 100 years for
the plume of substances to reach this property boundary. In addition to
groundwater flow calculations, Carolina Coatings Incorporated has also submitted
the results of modeling using the Domenico Solute, Transport Model for this site as
discussed on Page 13 of the report titled "Variao~e Request -Carolina Coatings
Site -Charlotte, North Carolina, December 9, 1996. Dames and l\.1oore N.C. Job
No. 23995-002-200;,. The results of this modeling support the companies view that
9
this variance will not impact adjacent properties. Data from this modeling may be
found in Appendix B of the variance request.
No water supply wens were identified at adjacent properties to 711 Pressley
Road. A well survey only identified only two water supply wells witbiu the½ mile
radius of the site as specified under 15A NCAC 2L .0113(c)(4). These are located in
Figure 2 of the variance request at the intersection of Locblane Drive and Yorkmont
Road approximately 2,300 feet south of711 Pres~ley Road. Accordjng to the
information in this request, these wells are cross-gradient from the site. Page 12
states that is not known if these wells are being used as a source of drinking water
supply or for purposes other than drinking water. Drinking water for the City of
Charlotte is obtained from Mountain Island Lake on the Catawba River twelve
miles north of the site. All downgradient properties and other area properties are
supplied drinking water from the City of Charlotte.
'It is higbly improbable that public water·supply lines will be impacted by
this variance. Numerous water supply lines and ,other utilities are located along
Pressley Road, Bishop Drive and Yorkwood Rot1d. Contacts ·with the Charlotte
Mecklenburg Utility Department and found that utilities are not a potential path for
migration of petroleum hydrocarbons from the site. Page 12 of the variance request
shows that the depth to the groundwater in this '.area is approximately 15 feet to 20
feet. The utility department reported that area water lines and utilities are buried
less than five (5) feet from the surface. Groundwater contamination from Incident
Number 8949 that is beneath 711 Pressley Road is too deep within the subsurface to
impact these lines. In addition, Page 12 also states the Carolina Coatings
Incorporated does not believe any buildings with basements will be impacted by this
variance request.
Rule .0113(c)(S): Supporting information to establish that requirements of the rule cannot
be achieved bv providing best available technoloev ecoilomicallv reasonable:
The part of the request that concerns va1·iance to Corrective Action in IS.A
NCAC 2L .0106(j) will allow Carolina Coatings1'Incorporated to discontinue
Corrective Action at this site. The company has submitted supporting information
in the report with other documents demonstrating that the continued application of
best available technology will not result in significant long term remediation of the
site to the Groundwater Quality Standards contained in ISA NCAC 2L .0202. The
is due to the high probability that continued cleanup activities at the site will not
significantly reduce contaminant levels below the Groundwater Quality Standards
in 15A NCAC 2L .0202. ·,
Since discovery of the release in 1991, Carolina Coatings Io corporated has
disposed of a total of 2,400 cubic yards of BTEX contaminated so II. Page 6 of the
report titled ''Variance Request -Carolina Coatings Site -Charlotte, I\"ortb
Carolina, December 9. 1996, Dames and Moore.N.C. Job No.23995-002-200'' states
that the c·ompany has treated approximately 328,500 gallons of groundwater to
\
comply with the cleanup requirements of the Cohective Action Plan that was
implemented in March 24, 1994. Pages 15 through 16 of the report titled
"Variance Req uest-Carolina Coatings Site -Charlotte, North Carolina. December
9, 1996, Dames and Moore N.C. Job No.23995-0C,2-200" states that a total of
$493,000 has been expended to design and install the remediation system, operate
the system, monitor progress of cleanup activity,' and cleanup this site. Page 15 of
the variance request shows that the owner of Carolina Coatings Incorporated, Mr.
Linwood Carter, is retired and is reported in the variance request as financing the
cleanup of this site from this personal savings. He has had no direct employment
since the sale of the property at 711 Pressley Road in 1991 to \Vattyl Paints
Incorporated.
Groundwater analysis of samples from on-site monitoring wells showed
significant reductions in the concentrations of substances from March 1995 through
October 9, 1997. As previously stated the grou~dwater pump-and-treat cleanup
system operated from March 24, 1994 through January 1997. Except for
Monitoring Well# 9, Benzene and other substances related to paint mixing
operations have not been observed above Groun~water Quality Standards from
quarterly groundwater samples. Although concentrations of Benzene, Toluene,
Ethylbenzene, and Xylenes have been sienificantly reduced near :Monitoring Well#
9 since cleanup operations began, the concentration of Benzene at a portion of this
site remains at levels in e)(ceedence of the Groundwater Quality Standard in 1 SA
NCAC 2L .0202. Page 7, Page 8, and Table 3 of the report titled "Variance Reg uest
-Carolina Coatin2s Site -Charlotte, North Car-oUna , December 2, 1996, Dames and
Moore N.C. Job No .23995-002-200'' shows that after the pump-and-treat cleanup
system was temporarily taken out of operation for a period of five days,
concentrations of substances in monitoring· wells; including Monitoring \Vell # 9, did
not change significantly. Table 1 shows that whi,e the cleanup system was in
operation, results from groundwater samples taken from the influent of Recovery
Well RW # 1 during the period of March 29, 1994 through October 30, 1996,
revealed remaining concentrations of substances beneath 711 Pressley Road had
been significantly reduced such that they could no longer be detected.
In order to demonstrate that the requirements of the rule cannot be achieved
using best available technology, title ISA NCAC 2L .0113(c)(5) requires that specific
technology considered be identified, the costs of implementing the technology be
shown, and the impacts of the costs on the applicant be provided. Page 16 of the
report titled "Variance Req uest -Carolina Coatine s Site -Charlotte. North
Carolina. Decemb er 9, 1996, Dames a nd Moore N.C. Job No.23995-002-200" states
that continued operation and monitoring at 711 Pressley Road will cost Carolina
Coatings approximately $48,000 per year. In addition, Page 14 of the request
shows that in order to continue cleanup with the pump-and-treat system, significant
upgrades will be needed for this system. These m:Odifications include the installation
of additional groundwater recovery wells, new p~mps, and renovations to increase
the size of the infiltration gallery. The company believes that the _low residual le\·els
of contaminants in the groundwater at this site does not warrant the continued use
of the pump-and-treat cleanup system. -
11
Carolina Coatings Incorporated has considered the use of air sparging with
soil vapor extraction (SVE) as alternate technology·to the present pump-and-treat
cleanup system. This technology is an in-situ remediation method that involves the
physical introduction of air below the water table to volatilize groundwater
contaminants from groundwater and subsurface materials Into a vapor phase. The
SVE portion of this system captures the volatilized substances so that they may be
removed from the subsurface environment. As thown on Page 15 of the report
titled "Variance Request -C arolina Coatin e s Site -Charlotte, North Carolina,
December 9 , 1996, Dames and Moore N.C. Job No.23 99 5-002-200" states that the
average hydraulic conductivity in saturated zone beneath th~ site is 2 x 10-s
centimeter per second. Based on this low permeability, Carolina Coatings does not
believe the use of this type of technology will be effective at removing substances
that remain at 711 Pressley Road.
Carolina Coatings Incorporated did not ide·ntify any technology, other than
those already at the site and alternate technology identified io the variance, that
would meet the requirements of ISA NCAC 2L .~106(j) as "best a-vailable
technology". Pursuant to the requirements of 15ANCAC2L .0113(c)(S), the
company does not believe that continuing remediation is economically reasonable.
Rule .0113 (c)(6): Su pportine information to establish that comp liance would p roduce
serious financial hardship on the a pplicant:
Carolina Coatings Incorporated has submitted information showing that
compliance with the rules will result in a serious fmancial hardship. Page 15 of the
variance request shows that the owner of Carolina Coatings Incorporated, l\Ir.
Linwood Carter, is retired and is reported in the.variance request as fioancing the
cleanup of this site from this personal savings. H,e has had no direct employment
since the sale of the property at 711 Pressley Roid in 1991 to \Vattyl Paints
Incorporated. Allowing the persistence of low levels of contaminants in
groundwaters that, after approximately three ye~rs of applying best available
technology, have asymptotically approached the;Groundwater Quality.Standards in
15A NCAC 2L .0202 through a variance is a pru:dent means of addressing Carolina
Coatings release at this site. It is no less effective a means of addressing residual
concentrations of substances at this site than continuing the use of pump-and-treat
system and is less expensive.
12
Rule .0113(c)(7): Supporting information thd compliance would produce serious financial
hardship without equal or ereater public benefit:
The company has submitted information in the request demonstrating that
the environment, safety and public health would not be impacted by this variance.
A January 6, 1997 letter from the Mooresville Regional Office serves as a
justification for this variance as it states that " ....... co11tinuation of pump and treat
remediation is neither cost effective IJOT environmehtally beneficial". The letter
further states that the ''Risk to the public is minimal co11siderfog the lack of active
water supply well systems, distance to surface water bodies, and the industrial
character of the site and surrounding sites.".
Rule .0113(c)(8): "A copy ofanv Special Order ... ":
No Special Order by Consent has been issued for this site.
Rule .0113(c}(9}: "A list of narnes and addresses of property owners ... ":
The property ownei-s within the proposed area of the variance are shown in
Table 4 and the map in Figure 11 of the report titled "Variance Request-Carolina
Coatings Site -Charlotte, North Carolina, December 9, 1996, Dames and Moore
N.C. Job No.23995-002-200". This listing includes the Trimming-Associates LTD,
the Presseley Park Restaurant owned by lonnis and Gregory Andreas, Rebpat
Leasing, Joachim H. Klitzsch, James A. Williams, J. David Fortenbery, Davis
Brothers Venture, Exit Fourteen Associates, the former Carolina Coatings site at
711 Pressley Road now owned by Wattyl Paints, John W. Layne, Linwood T. Carter
(property adjacent to 711 Pt-essley Road), the North Carolina Department of
Transportation, Southern Railroad, and two parcels of land owned by Eight
Hundred Eleven Pressley. Title ISA NCAC 2L .0113(e)(E) requires that
notification of a public bearing on this variance be given to the owner or owners of
these adjacent properties "at least 30 days prior to the date of the heariDg".
It is the recommendation of the Groundwater Section that the subject Yariance
request to Corrective Action requirements of ISA NCAC 2L .0106G) and Groundwater
Quality Standards contained in 15A NCAC 2L .0202 proceed to public notice in
accordance with ISA NCAC 2L .0113(e). On February27, 1997, the Division of
Epidemiology completed their review of the risk assessiv-ent methodology for this site and
recommended that this variance be granted for Carolin, Coatings Incorporated at their
former property located at 711 Pressley Road in Charlotte, North Carolina. Upon your
concurrence with our recommendation, the Groundwater Section will proceed with the
13
preparation of the req11ired public notice and hearing. Upon completing of the
requirements of ISA NCAC 2L .0113(d -t), with a recommendation to grant this variance
from the Environmental Management Commission Groundwater Committee, this request
will proceed to the Environmental Management Commission for final action in 15A NCAC
2L .0113(g). If there are any questions regarding this matter or if any additional
information is needed, please let me know.
ATTACHMENTS:
cc: Groundwater Section Assistant Chiefs
Mooresville Regional Groundwater Supervisor
Dr. Ken Rudo
David Hance
14
Stot.e of Norhh Carolina
Department of Environment,
Health and Natural Resources
Division of Epidemiology
James B. Hunt. Jr .• Governor
Jonathan B. Howes, Secretary
Michael Moser, M.D., M.P.H .• Director
MEMORANDUM
February 27, 1997
TO: Arthur Mouberry, P.E., Chief
Groundwater Section
FROM: Kenneth Rudo, Ph.D., Toxicologist \~(l..,
.NA
DEHNA.
Medical Evaluation and Risk Assessment Branch
Occupational and Environmental Epidemiology Section
' }~
SUBJECT: Request for Variance at the Carolina Coatings, Inc. Property at 711
Pressley Road in Charlotte, North Carolina
After reviewing the monitor well and site-specific data for the above site, the
Occupational and Environmental Epidemiology Section (OEES) would like to put
forward the following observations and recommendations. Although benzene
contamination in MW-9 still exceeds North Carolina groundwater standards, the
contamination is confined onsite, and it appears that it will remain onsite for many
years. In addition, there doesn't appear to be any private drinking water wells within a
1500 foot radius of the site, based on the documentation supplied to OEES. Because
the benzene contamination should not pose any risk t.o any private drinking water wells
and is confined onsite, the contamination should not pose any risk to public health
under the conditions described in the variance request. Therefore, OEES would
recommend granting the variance at this site.
If you have any further questions, please feel free to contact me at 715-6430.
KR:lp
P.O. Box 29601
Raleigh. NC 27626-0601 NOC An Equ.ol QpportuniTy Affirmcm,,e Ac-t,on En'l::iQVer
5Cf-4 recycled/10'1, POSH:or-;<.Jn-,~ PQpe<
Carolina Coatings-Variance Request
January 6, 1997
Page Two
A. Significant upgrade of the existing system and installation of
additional recovery wells would be necessary to capture the
lateral extent of the existing '·benzene above the NCAC 2L
standard. The current system, which has been operational for 2.5
years, has an insufficient capture zone to remediate the site to
below 2L groundwater standards.
B. Risk to public health is minimal considering the lack of active
water supply well systems, distance to surface water bodies, and
the industrial character of the site and surrounding sites.
If a variance is granted for the subject site, the MRO does not recommend continued
sampling of onsite monitoring wells based on the following reasons:
1) The groundwater plume is spatially limited (<30 feet radially) and does not
extend offsite .
2) Groundwater modeling of the plume does not predict offsite migration of the
plume above the 2L standards.
2) Secondary sources have been removed and the contaminants have the capacity
to degrade or attenuate.
Attached to this memo is a summary of the variance request. If you should have any
questions, I can be reached by phone at 704.663.1699 ext. 261 or by E-mail at
<[e-mail]>.
Attachment : Variance Request Summary
Release
NOV
CSA
Carolina Coatings
711 Pressley Road, Charlotte, North Carolina
Environmental site assessment for property transfer purposes performed in 1991
detected the presence of ethylbenzene, toluene and xylenes (BTEX) in soils
surrounding the pad. Subsequent assessment detected concentrations of BTEX
compounds above the 2L standard in onsite monitoring wells.
On August 28, 1992, the MRO issued Carolina Coatings a Notice of Violation
in accordance with 15A NCAC 2C 2L requiring restoration of groundwater and
soil at the site and elimination of the source . Source of the contamination was
apparently surface spill resulting from leaking drum storage and three settling
tanks located adjacent to the southeastern side of the pad.
A remedial action plan (RAP) was receive!f on June 30, 1992. The horizontal
and vertical extent of groundwater contamination was delineated and findings
presented in this report; no BTEX constituents were detected in the deep well
(MW-8) nor the downgradient wells MW-·1,5,6 and MW-7. Additional
information was requested by the MRO staff including additional soil sampling
and potential methods of remediation and disposal of excavated soil. On March
29, 1993, the requested information was submitted in the form of a RAP
Addendum.
The RAP addendum documented removal of approximately 1500 cubic yards of
contaminated soil surrounding the concrete drum storage pad and beneath the
pad. Confirmatory soils samples indicated no remaining soil with BTEX
concentration compounds above the 50 mg/kg target cleanup level.
CAP The corrective action plan was presented in a report entitled Soil and
Groundwater Remediation received on May 13, 1994 by the l\.1RO. This report
proposed the use of a pump and treat system comprised of a single recover::
well and infiltration gallery. Recpvered groundwater was processed through an
equalization tank, four fiber cartridge filter units and two carbon filter units in
series.
The CAP was not reviewed by the MRO or approved by the Director.
On January 18, 1994, the NC DEHNR Water Quality Division issued a
discharge permit for treated groundwater into the onsite infiltration gallery
(#WQ0007993).
The groundwater pump and treat system was activated on March 23, 1994 2fte-r
the required 48-hour notification to the MRO. Currently, the system is
operating at an approximate recovery rate of 0.25 gpm which equals an
approximate aquifer withdraw of 328,500 gallons of groundwater since system
startup.
Analytical results of system influent and effluent samples indicate ethylbenzene
and toluene concentrations below the 2L standard. Xylene and benzene
concentrations have decreased significantly but have exceeded the 2L standard
periodically.
Groundwater has been monitored between March 1994 and September 1996.
Monitoring well MW-9 has been the only groundwater monitoring well that has
ever exceeded the 2L standard for BTEX ~ornpounds. Analytical results of the
September 1996 sampling indicate benzene at a concentration of 27 ppb and
xylene at 104 ppb.
Groundwater flow at the site is determined to be primarily east with radial
components. A groundwater gradient of 0~0 l ft/ft has been calculated for the
site. Rising head test completed in four shallow monitoring wells indicate a
hydraulic conductivity value of 3.87 x 10-t cm/sec or 0.06 ft/day.
The calculated time that the plume would encounter the property boundary
given the current hydrogeologic conditions is 100 years. Using the Domenico
solute transport model and assuming a 27 ppb source concentration of benzene
(September's analytical results) and a first-order decay coefficient of 720 days,
the modeled benzene concentration at the property boundary would be <lppb.
\
Carolina Coatings has submitted a varianc"e request with supporting information
that demonstrates continued use of the current system is cost-prohibitive and
will not result in significant long-term remediation of the site to groundwater
standards. The variance request further suggests that remediation of the site to
groundwater standards would require significant modification of the current
groundwater recovery and treatment systehi.
The following facts and financial information has been submitted by Carolina
Coatings to further support their variance request:
1) Only one monitoring well, MW-9, has had benzene and xylene
concentrations above the 2L standard since groundwater monitoring
began in March 1994. Therefore, BTEX affected groundwater is limited
to the area surrounding MW-9 .
2) System influent sample concentrations have decreased from a ma-..:imum
of 7.6 ppb benzene and 440 ppb xylenes in May 1994 and March 1995
respectively. The system has been operational for 2.5 years and has
treated approximately 328,500 gallons of recovered groundwater.
Toluene and ethylbenzene have decreased to below the analytical
detection limit over the course of system operation.
3) A total of $493,000 has been spent by the former owner of Carolina
Coatings on assessment and active remediation of the contaminated soil
and groundwater using best availaqle technology economically
reasonable for the site. The continued, yearly operation and monitoring
cost of the site is estimated at $48,000. Mr. Carter, the retired, former
owner of the facility, maintains sole environmental liability of site
remediation and therefore continued operation would impose serious
financial hardship for Mr. Carter without significant environmental
benefit.
4) No potential surface water receptors or onsite receptors (i.e., basements,
artificial conduits) will be impacted above the 2L standard based on
groundwater modeling. The nearest, potential water supply wells are
located 2300 feet south of the site and are hydrologically separated from
the site aquifer.
' time Sensitive Signature
_U~g ently!
-
Needed
To:
From:
Subject:
Date:
Donna Pittman
David Hance~
Deputy Director's Signature needed and Concurrence from the Director on the
Hearing Officer's Report for the Carolina Coatings Variance Request (GW
Incident # 8949).
9/29/99
Attached is the hearing officer's report for the Carolina Coatings variance
request in Charlotte, NC. You will recall that this is the variance request for a release of
solvents from a paint mixing facility that was once owned by Mr. Linwood Carter. This
individual has conducted groundwater cleanup and soil removal for many years to address
concentrations of BTEX. Pursuant to title 15A NCAC 2L .0113, this individual requested a
variance.
A public hearing was held on August 12, 1999 pursuant to the 15A NCAC 2L
.0113 and a handful of local property owners and representatives attended this hearing. A
written comment was also received prior to the September 12, 1999 deadline that was
published in the notice. Art Barnhardt of the Fayetteville Regional Office was the hearing
officer for this variance.
Per requirements of the rules, final action on groundwater variances must be
taken by the Environmental Management Commission (EMC). Based on comments received
from the public, the residual concentrations of substances at the site, the lack of apparent
Page-1-
D
. .,
otna Pittman
Page2
September 29, 1999
receptors, and other factors noted on page 4 of the hearing officer's report, it is recommended
that this variance request be approved with no monitoring requirement.
The Groundwater Section intends to take this variance request to the EMC
Groundwater Committee at the October 1999 meeting with the hearing officer's
recommendation. Once approval is granted by the Groundwater Committee, this variance
will go to the full Commission for final action pursuant to 15A NCAC 21 .0113. At this time,
the earliest the EMC may approve this variance is at the December 9, 1999 meeting. This is
presuming the EMC holds it's normal number of meetings contained in the regular schedule
that was published last year on September 1, 1998. If the Commission chooses to hold a
meeting in November 1999 as they have in the past and elects to address action items at that
meeting, this .item may go before them in November.
It is requested that the Division do the following:
1. Have the Deputy Director review this variance request and sign the memorandum;
2. Send this request to Tommy Stevens for his concurrence. To signify this, he may
initial the last page of the four page memorandum;
3. Notify me that this packet is approved and ready for pick-up. Please feel free to
contact me at 9-715-6189.
Once the Division is satisfied that this variance should go forward to the
EMC Groundwater Committee, we will send the four page memorandum with the attached
information to the Groundwater Committee in their oacket that is scheduled to eo out next
week. If Possible, we would like to have the Division approvals on this memorandum by
2:00 P .M. on October 4. 1999. This is so we can ~et copies made of this material for a
mailing that will go out on Tuesday, October 5 ,1999. If you need to discuss this variance
further, please call Art Barnhardt at 910-486-1541 and Arthur Mouberry at 715-6170. I plan
to be in the office the rest of the week.
CC: Arthur Mouberry Carl Bailey Art Barnhardt David Hance
Page -2-
Time Sensitive Sig nature
Ur g ently !
-
N eeded
To:
From:
Subject:
Date:
Donna Pittman
David Hance /Jh ~
/-~
Deputy Director's Signature needed and Concurrence from the Director on the
Hearing Officer's Report for the Carolina Coatings Variance Request (GW
Incident# 8949).
9/29/99
Attached is the hearing officer's report for the Carolina Coatings variance
request in Charlotte, NC. You will recall that this is the variance request for a release of
solvents from a paint mixing facility that was once owned by Mr. Linwood Carter. This
individual has conducted groundwater cleanup and soil removal for many years to address
concentrations of BTEX. Pursuant to title 15A NCAC 2L .0113, this individual requested a
vanance.
A public hearing was held on August 12, 1999 pursuant to the lSA NCAC 2L
.0113 and a handful of local property owners and representatives attended this hearing. A
written comment was also received prior to the September 12, 1999 deadline that was
published in the notice. Art Barnhardt of the Fayetteville Regional Office was the hearing
officer for this variance.
Per requirements of the rules, final action on groundwater variances must be
taken by the Environmental Management Commission (EMC). Based on comments received
from the public, the residual concentrations of substances at the site, the lack of apparent
Page -1-
Donna Pittman
Page 2
September 29, 1999
receptors, and other factors noted on page 4 of the hearing officer's report, it is recommended
that this variance request be approved with no monitoring requirement.
The Groundwater Section intends to take this variance request to the EMC
Groundwater Committee at the October 1999 meeting with the hearing officer's
recommendation. Once approval is granted by the Groundwater Committee, this variance
will go to the full Commission for final action pursuant to 15A NCAC 21 .0113. At this time,
the earliest the EMC may approve this variance is at the December 9, 1999 meeting. This is
presuming the EMC holds it's normal number of meetings contained in the regular schedule
that was published last year on September 1, 1998. If the Commission chooses to hold a
meeting in November 1999 as they have in the past and elects to address action ite~s at that
meeting, this item may go before them in November.
It is requested that the Division do the following:
1. Have the Deputy Director review this variance request and sign the memorandum;
2. Send this request to Tommy Stevens for his concurrence. To signify this, he may
initial the last page of the four page memorandum;
3. Notify me that this packet is approved and ready for pick-up. Please feel free to
contact me at 9-715-6189.
Once the Division is satisfied that this variance should go forward to the
EMC Groundwater Committee, we will send the four page memorandum with the attached
information to the Groundwater Committee in their oacket that is scheduled to eo out next
week. If vossible. we would like to have the Di.vision avvrovals on this memorandum by
2:00 P.M. on October 4. 1999. This is so we can ~et copies made of this material for a
mailing that will go out on Tuesday, October 5 ,1999. If you need to discuss this variance
further, please call Art Barnhardt at 910-486-1541 and Arthur Mouberry at 715-6170. I plan
to be in the office the rest of the week.
CC: Arthur Mouberry Carl Bailey Art Barnhardt David Hance
Page -2-
PUBLIC NOTICE AND PUBLIC HEARING
On July 9, 1999 public notice was issued advising interested parties that a hearing on the
variance request for Carolina Coatings Incozporated was scheduled for August 12, 1999 (Attachment
1). Notice of this variance request was sent to local government officials and the Mecklenburg
County Health Director pursuant to the 15A NCAC 2L .0113 rule. Individual notices were sent per
requirements of title ISA NCAC 2L .0113 to sixteen adjacent property owners and area property
owners identified by Carolina Coatings Incozporated in the variance request. Approximately 130
notices were sent to the public at large consisting of persons listed in the Groundwater Section's
Mailing List. Cozporations, environmental groups, firms, government agencies, partnerships, and
individuals were sent a copy of the notice and are those persons who have expressed an interest in
regulatory actions that require a public hearing. Most of these persons reside or work in the
Charlotte Metropolitan Area. A copy of the notice was also published in The Charlotte Observer
on July 11, 1999.
The public hearing was conducted as scheduled. The Division was represented by four staff
members:
Art Barnhardt
Matt Heller
Shawna Caldwell
Randy Prillaman
Hearing Officer (Fayetteville Regional Office)
Mooresville Regional Office
Mooresville Regional Office
Recorder (Central Office)
The hearing was attended by five citizens consisting of adjacent property owners and owner
representatives. One person had verbal comments. Opening remarks were given by me, followed
by the staff presentation by Matt Heller (Attachment 2). Verbal and written comments from
interested parties were received during the hearing and prior to the closing of the hearing record on
September 13, 1999 and are paraphrased below. Written comments are included as (Attachment 3)
Verbal Comments during hearing by:
Joe Garmon and he stated that he owned property adjacent to the Carolina Coatings Site and at the
time the variance is granted, is Carolina Coatings relieved of all responsibility?
Written comments were submitted by:
Jack Smith ofMetrolina Landscape Company which stated (l)that they were unsure of what they
could or should do about this variance request, (2)wanted the right environmental thing done,
(3)wanted to be protected from devaluation of property due to contamination issues ( 4) asked for
a staff person to contact him and discuss the situation with him as opposed to having to hire a
consultant/lawyer.
2
Meredith Stover, agent for John Layne-Adjacent Property Owner which (l)stated his concerns
of contaminates migrating onto Mr. Layne's property (2) wanted relief and protection of any clean-
up that would be required (3) Mr. Layne was not opposed to the variance request but wanted a
written response on his regulatory responsibility if contamination migrated onto his property.
DISCUSSION/RECOMMENDATION
Attachment # 4 consists of the important memoranda related to this variance request. The
June 24, 1999 memoranda discusses the variance in light of the requirements of 15A NCAC 2L
.0l 13 and provides detailed information about this site. The two issues before the Environmental
Management Commission (EMC) are whether to grant a variance from the Groundwater Quality
Standards for Benzene as found in NCAC 2L .0202 and a variance from the requirement to continue
to implement a corrective action plan using the best available technology as required by 15A NCAC
2L .0106 (j).
A total of$493,000 has be~n expended to clean-up this site, none of which was reimbursed
through any type of trust fund. This included2,400 cubic yards of contaminated soil removed to
the extent practicable and groundwater extraction and treatment of an estimated 328,500 gallons of
affected groundwater. Carolina Coatings has submitted supporting information demonstrating that
continued operation of best available technology will not result in significant long term remediation
of the site to the groundwater quality standards in 15A NCAC 2L .0202 and contend that continued
operation of the existing system will be a serious financial burden without equal or greater public
benefit. The annual cost to operate, the groundwater remediation system is projected to be $48,000.
Notable factors about ground water quality/flow characteristics and remediation
to date:
-The affected area of ground water impact was estimated to be 10,000 square feet (surface
area) and less than 45 feet (vertically) below ground surface at the beginning of remedial
efforts. As of the last sampling event, only one monitoring well contained contamination
above the title 15A NCAC 2L .0202 Groundwater Quality Standard for Benzene. ( Note the
concentration observed for, Benzene was 2 parts per billion [ppb] which has a standard of 1
part per billion [ppb ]). .
-At the last sampling event, the recovery well was not collecting ground water with
detectable concentrations of any of the target compounds.
-The ground water flow velocity at this hydrogeologic setting has been estimated to
be on the order of 1. 1 feet per year. Using this rate of movement, it would take 100 years
for ground water to migrate from the source area to the property/variance boundary.
-At present there is no indication that contaminates have reached the fractured bedrock
portion of the aquifer in this area.
3
Based upon all information collected to date, the limited extent of contamination, the ability
of the contaminants to attenuate, the extremely low probability of any off-site impacts and the
financial burden of continued remediation without significant environmental improvement, it is my
recommendation that the EMC consider granting the variance request without further monitoring
requirements.
The following is a listing of attachments for the hearing officer's report submitted for the
Carolina Coatings Incorporated variance request:
Attachment# 1 -Public Notice
Attachment # 2 -Mooresville Regional Office Staff Presentation and Hearing Registrations
Attachment# 3 -Written Comments
Attachment# 4 -Memoranda Related to the Variance Request for Carolina Coatings
Incorporated
4
1 of 1
(displayed) -re: Ch ... g officers report/carolina coatings
,bject: Return Receipt (displayed) -re: Changes made to draft Hearing officers report/carolina
coatings
Date: Fri, 24 Sep 1999 11 :34:44 -0400
From: [e-mail]
To: David Hance <[e-mail]>
This is a Return Receipt for the mail that you sent to
[e-mail].
Note: this Return Receipt only acknowledges that the message was
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Disposition-Notification-To: David Hance <[e-mail]>
Date: Thu, 23 Sep 1999. 18: 07: 18 -0400
From: David Hance <[e-mail]>
Reply-To: DENR
Organization: Groundwater Section
X-Mailer: Mozilla 4.61 [en] (Win95; I)
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To: ART BARNHARDT <[e-mail]>
CC: Arthur Mouberry <[e-mail]>,
CARL BAILEY <[e-mail]>,
TED BUSH <[e-mail]>,
DAVID HANCE <[e-mail]>,
Matt Heller <[e-mail]>
Subject: re: Changes made to draft Hearing officers report/carolina
coatings
Content-Type: multipart/mixed;
boundary="------------49F1F2B6968807CDEE302A81"
9/27/99 10:17 AM
1 of 1
~ to draft Hearing officers report/carolina coatings
Subject: re: Changes made to draft Hearing officers report/carolina coatings
Date: Thu, 23 Sep 1999 18:07:18 -0400
From: David Hance <[e-mail]>
Reply-To: DENR
Organization: Groundwater Section
Art,
To: ART BARNHARDT <[e-mail]>
CC: Arthur Mouberry <[e-mail]>,
CARL BAILEY <[e-mail]>,
TED BUSH <[e-mail]>,
DAVID HANCE <DA [e-mail]>,
Matt Heller <[e-mail]>
Attached is a copy of the hearing officers -report with the changes you were provided yesterday.
In addition, I have made some minor editorial corrections to the report ( such as spelling out some
abbreviations and punctuation). Please note that I have included some additional information in
the public hearing section of this report on page 2. This information gives some specifics on the
notice that was done to meet the requirements of the rule. It has been renamed "Public Notice and
Public Hearing". Attachment# 4 also includes Dr. Rudo's recommendation and the
recommendation of the MRO Staff in 1996.
I have also sent you a hard copy of the entire report with attachments via fax transmission ( 46
pages) so you can get the full feel of how it reads.
If after reviewing this report, you find that it needs more information or changes please provide
these via e-mail. If this report is satisfactory to you please print out a new copy and sign-it. If
possible, I would like the signed copy back to us by Monday, September 27, 1999. Therefore, if you
can fed-ex it from the FRO region I would appreciate it or find some other means of getting it to
me.
Call me at 919-715-6189 if we need to talk further. PLEASE NOTE THAT I WILL BE ON LEAVE
FRIDAY. SEPTEMBER 24, 1999.
dh
Name: V2Carcoat.wpd D\ 2Carcoatw )d Type: WordPerfect Document (application/wordperfect5.1)
Encoding: base64
9/23 /99 6:29 PM
DIVISION OF WATER QUALITY
GROUNDWATER SECTION
September 27, 1999
MEMORANDUM
TO: Kerr T. Stevens, Director,
Division of Water Quality
THROUGH: Greg Thorpe, Deputy Director
Division of Water Quality
THROUGH: Arthur Mouberry, P .E., Chief,
Groundwater Section
FROM: Art Barnhardt, Groundwater Supervisor,
Fayetteville Regional Office
SUBJECT: Hearing Officer's Report and Recommendations
Variance Request from 15A NCAC 2L .0202 and .0106(j)
Carolina Coatings Incorporated Property
711 Pressley Road
Charlotte, NC/ Mecklenburg County
(Groundwater Incident# 8949)
In accordance with your memorandum dated July 13, 1999, a Public Hearing was held on
August 12, 1999 at 7:00 P.M. in the Criminal Courts Building of the Mecklenburg County
Courthouse in Charlotte, North Carolina. I served as the hearing officer and a summary of the public
hearing and my recommendations are attached for your consideration.
The issue concerns whether the Environmental Management Commission (EMC) should
approve or deny a request for a variance of the Groundwater Quality Standards in Title 15A North
Carolina Administrative Code (NCAC) Subchapter 2L .0202 (15A NCAC 2L .0202) and 15A
NCAC 2L .01060). Such a variance may be granted by the EMC under the authority of North
Carolina General Statute (NCGS) 143-215.3(e). The procedures for application and for public
notification found in 15A NCAC 2L .0113 have been followed for this request.
Also attached for your review and consideration are those documents considered relevant to
this request including a summary of background information.
If you have any questions, please do not hesitate to call.
1
PUBLIC NOTICE AND PUBLIC HEARING
On July 9, 1999 public notice was issued advising interested parties that a hearing on the
variance request for Carolina Coatings Incorporated was scheduled for August 12, 1999 (Attachment
1 ). Notice of this variance request was sent to local government officials and the Mecklenburg
County Health Director pursuant to the 15A NCAC 2L .0113 rule. Individual notices were sent per
requirements of title 15A NCAC 2L .0113 to sixteen adjacent property owners and area property
owners identified by Carolina Coatings Incorporated in the variance request. Approximately 130
notices were sent to the public at large consisting of persons listed in the Groundwater Section's
Mailing List. Corporations, environmental groups, firms, government agencies, partnerships, and
individuals were sent a copy of the notice and are those persons who have expressed an interest in
regulatory actions that require a public hearing. Most of these persons reside or work in the
Charlotte Metropolitan Area. A copy of the notice was also published in The Charlotte Observer
on July 11, 1999.
The public hearing was conducted as scheduled. The Division was represented by four staff
members:
Art Barnhardt
Matt Heller
Shawna Caldwell
Randy Prillaman
Hearing Officer (Fayetteville Regional Office)
Mooresville Regional Office
Mooresville Regional Office
Recorder (Central Office)
The hearing was attended by five citizens consisting of adjacent property owners and owner
representatives. One person had verbal comments. Opening remarks were given by me, followed
by the staff presentation by Matt Heller (Attachment 2). Verbal and written comments from
interested parties were received during the hearing and prior to the closing of the hearing record on
September 13, 1999 and are paraphrased below. Written comments are included as (Attachment 3)
Verbal Comments durin 2 hearin2 b y :
Joe Garmon and he stated that he owned property adjacent to the Carolina Coatings Site and at the
time the variance is granted, is Carolina Coatings relieved of all responsibility?
Written comments were submitted b y :
Jack Smith ofMetrolina Landscape Company which stated (1 )that they were unsure of what they
could or should do about this variance request, (2)wanted the right environmental thing done,
(3)wanted to be protected from devaluation of property due to contamination issues (4) asked for
a staff person to contact him and discuss the situation with him as opposed to having to hire a
consultant/lawyer.
2
Meredith Stover, agent for John Layne-Adjacent Property Owner which (1 )stated his concerns
of contaminates migrating onto Mr. Layne's property (2) wanted relief and protection of any clean-
up that would be required (3) Mr. Layne was not opposed to the variance request but wanted a
written response on his regulatory responsibility if contamination migrated onto his property.
DISCUSSION/RECOMMENDATION
Attachment # 4 consists of the important memoranda related to this variance request. The
June 24, 1999 memoranda discusses the variance in light of the requirements of 15A NCAC 2L
.0113 and provides detailed information about this site. The two issues before the Environmental
Management Commission (EMC) are whether to grant a variance from the Groundwater Quality
Standards for Benzene as found in NCAC 2L .0202 and a variance from the requirement to continue
to implement a corrective action plan using the best available technology as required by 15A NCAC
2L .0106 (j).
A total of $493,000 has been expended to clean-up this site, none of which was reimbursed
through any type of trust fund. This included 2,400 cubic yards of contaminated soil removed to the
extent practicable and groundwater extraction and treatment of an estimated 328,500 gallons of
affected groundwater. Carolina Coatings has submitted supporting information demonstrating that
continued operation of best available technology will not result in significant long term remediation
of the site to the groundwater quality standards in 15A NCAC 2L .0202 and contend that continued
operation of the existing system will be a serious financial burden without equal or greater public
benefit. The annual cost to operate the groundwater remediation system is projected to be $48,000.
Notable factors about ground water quality/flow characteristics and remediation
to date:
-The affected area of ground water impact was estimated to be 10,000 square feet (surface
area) and less than 45 feet (vertically) below ground surface at the beginning of remedial
efforts. As of the last sampling event, only one monitoring well contained contamination
above the title 15A NCAC 2L .0202 Groundwater Quality Standard for Benzene. ( Note the
concentration observed for Benzene was at 2 parts per billion [ppb] which has a standard of
1 parts per billion [ppb ]).
-At the last sampling event, the recovery well was not collecting ground water with
detectable concentrations of any of the target compounds.
-The ground water flow velocity at this hydrogeologic setting has been estimated to
be on the order of 1.1 feet per year. Using this rate of movement, it would take 100 years
for ground water to migrate from the source area to the property/variance boundary.
-At present there is no indication that contaminates have reached the fractured bedrock
portion of the aquifer in this area.
3
Based upon all information collected to date, the limited extent of contamination, the ability
of the contaminants to attenuate, the extremely low probability of any off-site impacts and the
financial burden of continued remediation without significant environmental improvement, it is my
recommendation that the EMC consider granting the variance request without further monitoring
requirements.
The following is a listing of attachments for the hearing officer's report submitted for the
Carolina Coatings Incorporated variance request:
Attachment# 1 -Public Notice
Attachment# 2 -Mooresville Regional Office Staff Presentation and Hearing Registrations
Attachment# 3 -Written Comments
Attachment# 4 -Memoranda Related to the Variance Request for Carolina Coatings
Incorporated
4
P.RELiM1NARt · · · ·;
SUBJECT to COP'?'
REVISION
A total of$493,000 has been expended to clean-up this site, none of which was reimbursed
through any type of trust fund. This included 2,400 cubic yards of contaminated soil removal to the
extent practicable and groundwater extraction and treatment of an estimated 328,500 gallons of
affected groundwater. Carolina Coatings has submitted supporting information demonstrating that
continued operation of best available technology will not result in significant long term remediation
of the site to the groundwater quality standards in 15A NCAC 2L .0202 and contend that continued
operation of the existing system will be a serious financial burden without equal or greater public
benefit. The annual cost to operate the groundwater remediation system is projected to be $48,000.
Notable factors about ground water quality/flow characteristics and remediation
to date:
-The affected area of ground water impact was estimated to be 10,000 sq.ft.(surface area)
and less than 45 ft. (vertically) below ground surface at the beginning of remedial efforts.
As of the last sampling event, only one monitoring well contained contamination above the
2L standard (benzene at 2 ppb which has a standard of 1 ppb ).
-At the last sampling event, the recovery well was not collecting ground water with
detectable concentrations of any of the target compounds.
-The ground water flow velocity at this hydrogeologic setting has been estimated to
be on the order of 1.1 ft./yr. Using this rate of movement, it would take 100 years for ground
water to migrate from the source area to the property/variance boundary.
-At present there is no indication that contaminates have reached the fractured bedrock
portion of the aquifer in this area.
Based upon all information collected to date, the limited extent of contamination, the ability
of the contaminants to attenuate, the extremely low probability of any off-site impacts and the
financial burden of continued remediation without significant environmental improvement, it is my
recommendation that the EMC consider granting the variance request without further monitoring
requirements.
t l
j C:
96 ,LETTER
6
=? er
Attachment ~-SEPTEMBER 16, 1996
MEMORANDUM FROM THE
MOORESVILLE REGIONAL OFFICE
Carolina'Coatings Hearing Officer Report
I of I
Subject: Carolina Coatings Hearing Officer Report
Date: Wed, 22 Sep 1999 13:32:41 -0400
From: Art Barnhardt <[e-mail]>
Organization: NC Dept. of Environment and Natural Resources
To: DAVID HANCE <DA [e-mail]>
David:
Matt has looked at it and said it was f 'ine. Please go into the file and
make changes to the list of attachments as needed and as we discussed.
E-mail it back with these changes and I'll print, sign and send the
origional back to you e-mail .
ArtB.
Name: Carcoat.wpd
O carcoat.w ['<l Type: WordPerfect Document (application/wordperfect5.1)
Encoding: base64
9/22 992 : 1-1-'
re: draft copy ofho report-carolina coatings variance
I of I
Subject: re: draft copy of ho report-carolina coatings variance
Date: Wed, 22 Sep 1999 15:22:16 -0400
From: David Hance <[e-mail]>
Reply-To: DENR
Organization: Groundwater Section
ART:
To: ART BARNHARDT <[e-mail]>
CC: DAVID HANCE <DA [e-mail]>
I HAVE GONE OVER THE REPORT FOR THE CAROLINA COATING VARIANCE. SOME
EDITORIAL CHANGES ARE NEEDED. THEY ARE SHOW WITH AN ARROW POINTING
RIGHT (------>) AT THE BEGINNING OF THE LINE.
THESE HAVE BEEN FAXED TO YOU.
IF YOU ARE OK WITH THEM .... PLEASE LET ME KNOW. I WILL MAKE THOSE
CHANGES IN THE DOCUMENT YOU SENT ME AND SEND IT BACK TO YOU FOR
SIGNATURE VIA FAX.
ONCE YOU ARE SATISFIED ...... THIS WILL GO TO MANAGEMENT. I WILL
SEND BOTH YOU AND MATT THIS AS AN E-MAIL ATTACHMENT.
DH
(919-715-6189)
9/22/99 4:18 PM
re: Draft Hearing officers report for Carolina Coatings Variance Request
1 of 1
Subject: re: Draft Hearing officers report for Carolina Coatings Variance Request
Date: Wed, 22 Sep 1999 14:55:23 -0400
From: David Hance <[e-mail]>
Reply-To: DENR
Organization: Groundwater Section
Hi Matt;
To: Matt Heller <[e-mail]>
CC: ART BARNHARDT <[e-mail]>,
DAVID HANCE <DA [e-mail]>
I have reviewed Art's hearing officers report. He mentions Attachment# 2 as the "staff
presentation". I do not have what you presented at the hearing (i.e. your write up). Please fax
this to me at 919-115-0588 todav. I will then have all the materials needed to go forward to
management with this variance.
Call me at 919-715-6189 if we need to talk.
dh
9/22/99 3:00 PM
Carolina Coatings Hearing Officer Report
1 of 1
Subject: Carolina Coatings Hearing Officer Report
Date: Wed, 22 Sep 1999 13:32:41 -0400
From: Art Barnhardt <[e-mail]>
Organization: NC Dept. of Environment and Natural Resources
To: DAVID HANCE <DA [e-mail]>
David:
Matt has looked at it and said it was fine. Please go into the file and
make changes to the list of attachments as needed and as we discussed .
E-mail it back with these changes and I'll print, sign and send the
origional back to you e-mail.
ArtB.
F Name: Carcoat.wpd · · ·· ·· l
Type: WordPerfect Document ( application/wordperfectS .1)
Encoding: base64
9/22/99 2:17 PM
MEMORANDUM
DIVISION OF WATER QUALITY
GROUNDWATER SECTION
September 22, 1999
TO: Tommy Stevens, Director
THROUGH: Greg Thorpe, Deputy Director
THROUGH: Arthur Mouberry, Section Chief
FROM: Art Barnhardt, Groundwater Supervisor
Fayetteville Regional Office
SUBJECT: Hearing Officer's Report and Recommendations
Variance Request from 15A NCAC 2L .0202 and .0106G)
Carolina Coatings Incorporated Property
711 Pressley Road
Charlotte, NC/ Mecklenburg County
Groundwater Incident # 8949
In accordance with your memorandum dated July, 13 1999, a Public Hearing was held on
August 12, 1999 at 7:00 p.m. in the Criminal Courts Building of the Mecklenburg County
Courthouse in Charlotte, North Carolina. I served as the hearing officer and a summary of the public
hearing and my recommendations are attached for your consideration.
The issue concerns whether the Environmental Management Commission (EMC) should
approve or deny a request for a variance of the Groundwater Quality Standards in Title 15A North
Carolina Administrative Code (NCAC) Subchapter 2L .0202 (15A NCAC 2L .0202) and 15A
NCAC 2L .0106G). Such a variance may be granted by the EMC under the authority of North
Carolina General Statute (NCGS) 143-215.3(e). The procedures for application and for public
notification found in 15A NCAC 2L .0113 have been followed for this request.
Also attached for your review and consideration are those documents considered relevant to
this request including a summary of background information.
If you have any questions, please do not hesitate to call.
PUBLIC HEARING
A public notice was published advising interested parties that a public hearing was scheduled
on August, 12 1999 (Attachment 1). The public hearing was conducted as scheduled. The Division
was represented by four staff members:
Art Barnhardt
Matt Heller
Shawna Caldwell
Randy Prillaman
Hearing Officer
Mooresville Regional Office
Mooresville Regional Office
Recorder
The hearing was attended by five citizens consisting of adjacent property owners and owner
representatives. One person had verbal comments. Opening remarks were given by me, followed
by the staff presentation by Matt Heller (Attachment 2). Verbal and written comments from
interested parties were received during the hearing and prior to the closing of the hearing record on
September 13, 1999 and are paraphrased below. Written comments are included as (Attachment 3)
Verbal Comments during hearing bv:
Joe Garmon and he stated that he owned property adjacent to the Carolina Coatings Site and at the
time the variance is granted, is Carolina Coatings relieved of all responsibility?
Written comments were submitted bv:
Jack Smith of Metrolina Landscape Company which stated (1 )that they were unsure of what they
could or should do about this variance request, (2)wanted the right environmental thing done,
(3)wanted to be protected from devaluation of property due to contamination issues (4) asked for
a staff person to contact him and discuss the situation with him as opposed to having to hire a
consultant/lawyer.
Meredith Stover, agent for John Layne-Adjacent Property Owner which (l)stated his concerns
of contaminates migrating onto Mr. Layne's property (2) wanted relief and protection of any clean-
up that would be required (3) Mr. Layne was not opposed to the variance request but wanted a
written response on his regulatory responsibility if contamination migrated onto his property.
DISCUSSION/RECOMMENDATION
Attachment # 4 consists of the Division of Water Quality memoranda concerning this
variance request. The June 24, 1999 memoranda discusses the variance in light of the requirements
of 15A NCAC 2L .0113 and provides detailed information about this site. The two issues before the
Environmental Management Commission (EMC) are whether to grant a variance from the
Groundwater quality standards for benzene as found in NCAC 2L .0202 and a variance from the
requirement to continue to implement a corrective action plan using the best available technology
as required by 15A NCAC 2L .0106 (j).
A total of$493,000 has been expended to clean-up this site, none of which was reimbursed
through any type of trust fund. This included 2,400 cubic yards of contaminated soil removal to the
extent practicable and groundwater extraction and treatment of an estimated 328,500 gallons of
affected groundwater. Carolina Coatings has submitted supporting information demonstrating that
continued operation ofbest available technology will not result in significant long term remediation
of the site to the groundwater quality standards in 15A NCAC 2L .0202 and contend that continued
operation of the existing system will be a serious financial burden without equal or greater public
benefit. The annual cost to operate the groundwater remediation system is projected to be $48,000.
Notable factors about ground water quality/flow characteristics and remediation
to date:
-The affected area of ground water impact was estimated to be 10,000 sq.ft.(surface area)
and less than 45 ft. (vertically) below ground surface at the beginning of remedial efforts .
As of the last sampling event, only one monitoring well contained contamination above the
2L standard (benzene at 2 ppb which has a standard of 1 ppb ).
-At the last sampling event, the recovery well was not collecting ground water with
detectable concentrations of any of the target compounds.
-The ground water flow velocity at this hydrogeologic setting has been estimated to
be on the order of 1.1 ft/yr. Using this rate of movement, it would take 100 years for ground
water to migrate from the source area to the property/variance boundary.
-At present there is no indication that contaminates have reached the fractured bedrock
portion of the aquifer in this area.
Based upon all information collected to date, the limited extent of contamination, the ability
of the contaminants to attenuate, the extremely low probability of any off-site impacts and the
financial burden of continued remediation without significant environmental improvement, it is my
recommendation that the EMC consider granting the variance request without further monitoring
requirements.
Attachment # 1 -PUBLIC NOTICE
Attachment # 2 -PROCEEDING OF THE
HEARING AND REGISTRATION LIST
Attachment# 3 -HEARING OFFICER'S
SPEECH
Attachment# 4 -APRIL 4, 1996 LETTER
FROMS&ME
Attachment #5-SEPTEMBER 16, 1996
MEMORANDUM FROM THE
MOORESVILLE REGIONAL OFFICE
Attachment# 6 -DIVISION OF WATER
QUALITY MEMORANDA CONCERNING
THE VARIANCE REQUEST FOR
GROUNDWATER INCIDENT NUMBER 8094
SEP.ZZ.iggg 10 :23AM ENVIRONMENTAL MGMT
N0.057 P,3/3
SALE
Stuever Properties, Inc.
704-333-9483
August 17, 1999
Mr. David Hance
EffNR. • DWQ .. Groundwater Sec.
P.o. aox 29s1s
Raleigh, NC 27626 .. 0S78
Re: 711 .Ptessley Road #8949
Charlotte, NC
LEASE
'"° \0
3=111
is
~
Q
:;::a,. ::; -c:., -a,
Dear Mr. Han~c; ~
I went to your meeting in Charlotte. and unfortunately they c;ould not get the
recorder to work and I left after 30 minutes.
Mr. Layne, owner of 801 Pressley Roada has reviewed your request for a variance,
and we do not see any reason to oppose this. Mr. Layne's one concern is: Whose
responsibility is it if any of the solvent leeched on to bis propeny? Please give us
an answer to this by the end of August
Sincerely»
~
Meredith D. Stoever
cc: Mr. Linwood Carter
605 Hennitage Court• Charlotte, NC 28207
Fax 704-343~9321
0
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variance-ca':olina co~ings-ho report
1 of2
Subject: variance-carolina coatings-ho report
Date: Mon, 20 Sep 1999 12:03:30 -0400
From: David Hance <[e-mail]>
Reply-To: DENR
Organization: Groundwater Section
ART,
To: Matt Heller <[e-mail]>,
ART BARNHARDT <[e-mail]>
CC: CARL BAILEY <[e-mail]>,
DAVID HANCE <DA [e-mail]>
AS WE PREVIOUSLY DISCUSSED, THE PERIOD FOR GETTING COMMENTS FROM THE
PUBLIC ON THE CAROLINA COATINGS VARIANCE EXPIRED ON THE 13TH OF SEPTEMBER.
A HEARING OFFICERS REPORT AND RECOMMENDATION NEEDS TO BE READY FOR THE
EMC GROUNDWATER COMMITTEE TO VOTE ON.
ATTACHED ARE COPIES OF HO REPORTS FROM PREVIOUSLY APPROVED VARIANCES IN
CHARLOTTE AND STATESVILLE. LARRY COBLE AND SHERRI KNIGHT WERE HEARING
OFFICERS FOR THESE. YOU MAY USE THESE REPORTS AS TEMPLATES FOR YOUR
REPORT ON THIS VARIANCE. MATT CAN ASSIST YOU AS NECESSARY WITH THE
TECHNICAL ISSUES.
THE EARLIEST THAT THIS HEARING OFFICERS REPORT CAN BE APPROVED BY THE
GROUNDWATER COMMITTEE IS AT THE OCTOBER 1999 MEETING. IN ORDER TO GET THIS
TO THE GROUNDWATER COMMITTEE, THE REPORT WILL NEED TO BE COMPLETED AND
REVIEWED BY THE DIVISION DIRECTOR OR HIS DESIGNEE.
BASED ON A MAILING DEADLINE TO GET THE EMC GROUNDWATER COMMITTEE
PACKET IN THE MAIL ON FRIDAY, OCTOBER 1, 1999, THE FOLLOWING SCHEDULE APPLIES
TO THE CAROLINA COATINGS VARIANCE:
SEPTEMBER 27TH.(10:00 AM) ..................... HEARING OFFICERS REPORT COMPLETED
SEPTEMBER 27TH (4:00 PM) .................... GROUNDWATER SECTION STAFF AT CO AND
HEARING OFFICER DISCUSS REPORT AS NECESSARY
SEPTEMBER 28TH .................... HO REPORT GOES TO THE DNISION DIRECTOR
OR HIS DESIGNEE TO SIGN/CONCUR.
OCTOBER 1, 1999 ..................... HO REPORT GOES TO THE EMC GROUNDWATER COMMITTEE
IN
MAIL.
OCTOBER 13, 1999 ................... GWC MEETING HELD AND VOTE TAKEN TO RECOMMEND
FULL
COMMISSION APPROVAL.
DECEMBER 9, 1999 .................... FULL EMC APPROVES THE VARIANCE FOR CAROLINA
COATINGS
WHEN YOU FINISH THE REPORT PLEASE SEND BY E-MAIL ATTACHMENT. ONCE IT IS
READY TO GO TO THE DIVISION YOU CAN FED-EX A SIGNED VERSION TO ME.
9/20/99 1:56 PM
SALE
Stoever Properties, Inc.
704-333-9483
LEASE DEVELOPMENT
August 17, 1999
Mr. David Hance
EHNR -DWQ -Groundwater Sec.
P.O. Box 29578
Raleigh, NC 27626-0578
Re: 711 Pressley Road #8949
Charlotte, NC
Dear Mr. Hance:
I went to your meeting in Charlotte, and unfortunately they could not get the
recorder to work and I left after 30 minutes.
Mr. Layne, owner of 801 Pressley Road, has reviewed your request for a variance,
and we do not see any reason to oppose this. Mr. Layne's one concern is: Whose
responsibility is it if any of the solvent leeched on to his property? Please give us
an answer to this by the end of August.
Sincerely,
///!)/~ ~muu-/
Meredith D. Stoever
cc: Mr. Linwood Carter
605 Hermitage Court• Charlotte, NC 28207
Fax [phone]
CJ
\0 ::!:: \0 C)
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.:r::-::;:
SALE
Stoever Properties, Inc.
704-333-9483
LEASE DEVELOPMENT
August 17. 1999
Mr. David Hance
"° EHNR -DWQ -Groundwater Sec . \0
P.O. Box 29578 l:a ·
C:
Raleigh, NC 27626-0578 G"")
N)
0
711 Pressley Road #8949 Re: l=-
::i: Charlotte, NC §
U1
Dear Mr. Hance: <.11
I went to your meeting in Charlotte, and unfortunately they could not get the
recorder to work and I left after 30 minutes.
Mr. Layne, owner of 801 Pressley Road. has reviewed your request for a variance,
and we do not see any reason to oppose this. Mr. Layne's one concern is: Whose
responsibility is it if any of the solvent leeched on to his property? Please give us
an answer to this by the end of August.
Sincerely,
~
Meredith D. Stoever
cc: Mr . Linwood Carter
605 Hermitage Court• Charlotte, NC 28207
Fax [phone]
0
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0
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SALE
Stoever P roperties, Inc.
704-333-9483
LEASE DEVELOPMENT
July 29, 1999
Mr. David Hance
ENHR -DWG -Groundwater Section
P.O. Box 29578
Raleigh, NC 27626-0578
Re: 711 Pressley Road
Charlotte, NC
Dear Mr. Hance:
Mr. Layne has passed along the letter of July 7, 1999 from Mr. M. Carl Bailey, Jr.
in regard to the above referenced property.
Mr. Layne is concerned about his protection in the case of any leaking of
chemicals from 711 Pressley Road to 801 Pressley Road. He would want relief
from any problems as well as monetary protection and guarantee of any clean-up
required by Wattyl Paints of Atlanta, GA
Mr. Layne is also requesting a plat of the property indicating where the
monitoring wells are located.
Sincerely,
. Stoever
Agent for Mr. Layne
cc: Mr. John W. Layne
605 Hermitage Court• Charlotte, NC 28207
Fax [phone]
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Author: David Hance at NRGWS0lP
Date: 8/16/1999 10:27 AM
Priority: Urgent
Receipt Requested
TO: Art [e-mail] at Internet
TO: Matt [e-mail] at Internet
CC: Carl Bailey
CC: Arthur Mouberry
CC: David Hance
Subject: re: Carolina Coatings Variance-proposed schedule
Message Contents------------------------------------
Dear Art and Matt:
Here are the important milestones and steps in getting this
variance for Carolina Coatings finalized:
September 13, 1999 ............ final written comments received FROM
the public.
September 27, 1999 ........... Hearing Officers Report and
Recommendations Finalized. This
will need to include a comment
summary and listing of hearing
participants.
October 7, 1999 .............. Variance recommendation mailed to the
EMC Groundwater Committee in the
meeting packet.
October 14, 1999 ............... EMC Groundwater Committee meets to
make a recommendation to the full
Commission.
November 9, 1999 ............... Variance information included in the
Commission packet sent by the
Division.
*December 9, 1999 ................ Full Commission meets to take final
action on the Carolina Coatings
Variance.
December 16, 1999 ................ A letter is sent to the RP and
others informing them of the EMC
decision PURSUANT TO
15A NCAC 2L .0113.
* NOTE: THE EMC MAY MEET IN NOVEMBER 1999 AND THIS VARIANCE COULD GO
TO THEM EVEN EARLIER. NOT CONFIRMED AS OF YET.
BASED on the comments collected at the hearing .... I think this
schedule is reasonable. If additional comments dictate a longer
period of time, we can make adjustments. Please note that the
Director wants a hearing officers recommendation NO LATER THAN
December 13, 1999.
If the two of you want an example of how a hearing officers report
is written, I can send you some previous variances as examples . PLEASE
LET ME KNOW. E-mail me or call 919-715-6189.
THANKS FOR ALL YOUR HELP IN BRINGING THIS VARIANCE FORWARD TO
HEARING .
DAVID HANCE
P.S. >>>>>>> MY FATHER GOT THROUGH HIS OPERATION GREAT AND IS RESTING
AT HOME. (dh)
AS A VISUAL AID, I HA VE PROVIDED COPIES OF TWO SITE MAPS. THE FIRST MAP
SHOWS THE SITE IN RELATION TO THE SURROUNDING AREA. THE SECOND MAP
SHOWS THE SITE IN DETAIL AND THE LOCATIONS OF GROUNDWATER MONITORING
WELLS.
I WOULD LIKE TO BEGIN BY SUMMARIZING THE HISTORY OF THE CONTAMINATION
AT THIS SITE:
IN 1991 AND 1992, SOIL AND GROUNDWATER SAMPLES WERE COLLECTED FROM THE
CAROLINA COATINGS PROPERTY LOCATED AT 711 PRESSLEY ROAD IN CHARLOTTE.
SAMPLES COLLECTED NEAR A CONCRETE PAD AREA BEHIND THE CAROLINA
COATINGS WAREHOUSE BUILDING WERE FOUND TO CONTAIN ETHYLBENZENE,
BENZENE AND XYLENE. THESE ARE ALL PETROLEUM COMPOUNDS.
BASED ON THE ANALYTICAL RESULTS OF THIS SAMPLING, APPROXIMATELY 850
CUBIC YARDS OF SOIL WERE DETERMINED TO BE CONTAMINATED. IN ADDITION,
SHALLOW GROUNDWATER UNDERNEATH APPROXIMATELY 1/4OF AN ACRE AT THE
SITE CONTAINED BENZENE, ETHYLBENZENE AND XYLENE AT CONCENTRATIONS
ABOVE THE NORTH CAROLINA GROUNDWATER STANDARDS.
IN MARCH OF 1993, THE GROUNDWATER SECTION RECEIVED A COMPLETE
REMEDIAL ACTION PLAN FOR CONTAMINATED SOIL AND GROUNDWATER AT THE
SITE. THE REMEDIAL ACTION PLAN CALLED FOR THE EXCAVATION OF ALL OF THE
CONTAMINATED SOIL ON THE PROPERTY AND THE TRANSPORT OF THIS SOIL TO A
PERMITTED SOIL REMEDIATION FACILITY. IN ADDITION, THE PLAN PROPOSED TO
PUMP CONTAMINATED GROUNDWATER TO THE SURFACE, TREAT IT USING A
CARBON FILTER, AND REINTRODUCE IT TO THE GROUND.
IN MAY OF 1993, APPROXIMATELY 1500 CUBIC YARDS OF SOIL WAS EXCAVATED
FROM THE SITE AND TRANSPORTED TO THE CAROLINA STALITE THERMAL
TREATMENT FACILITY. AFTER BACKFILLING THE EXCAVATION, A GROUNDWATER
RECOVERY WELL AND A GROUNDWATER MONITOR WELL WERE INSTALLED IN
ORDER TO TREAT THE CONTAMINATED GROUNDWATER.
IN MARCH OF 1994, THE GROUNDWATER PUMP AND TREATMENT SYSTEM BEGAN
OPERATING. THE PUMP AND TREATMENT SYSTEM CONTINUED TO OPERATE UNTIL
JANUARY OF 1997. DURING THAT TIME PERIOD, MORE THAN 328,000 GALLONS OF
GROUNDWATER WERE TREATED.
BETWEEN MARCH OF 1994 AND MARCH OF 1997. THREE MONITOR WELLS WERE
SAMPLED ON A QUARTERLY BASIS TO DETERMINE GROUNDWATER QUALITY.
DURING THIS PERIOD OF MONITORING, BENZENE, ETHYLBENZENE AND XYLENES
WERE DETECTED IN ONLY ONE WELL, MONITOR WELL #9.
THE MAXIMUM CONCENTRATION OF BENZENE DETECTED IN MONITOR WELL #9
BETWEEN MARCH OF 1994 AND MARCH OF 1997 WAS 27 MICROGRAMS PER LITER.
BENZENE WAS NOT DETECTED IN MONITOR WELL #9 DURING THE LAST
QUARTERLY SAMPLING EVENT IN MARCH OF 1997.
THE MAXIMUM CONCENTRATION OF ETHYLBENZENE DETECTED IN MONITOR WELL
#9 BETWEEN MARCH OF 1994 AND MARCH OF 1997 WAS 32 MICROGRAMS PER LITER.
ETHYLBENZENE WAS NOT DETECTED IN MONITOR WELL #9 DURING THE LAST
QUARTERLY SAMPLING EVENT IN MARCH OF 1997.
THE MAXIMUM CONCENTRATION OF XYLENE DETECTED IN MONTI OR WELL #9
BETWEEN MARCH OF 1994 AND MARCH OF 1997 WAS 860 MICROGRAMS PER LITER.
XYLENE WAS NOT DETECTED IN MONITOR WELL #9 DURING THE LAST QUARTERLY
SAMPLING EVENT IN MARCH OF 1997.
IN JANUARY OF 1997, THE GROUNDWATER SECTION ALLOWED THE GROUNDWATER
PUMP AND TREAT SYSTEM TO BE TURNED OFF BECAUSE THE EXISTING
GROUNDWATER PUMP AND TREAT SYSTEM COULD NOT ADDRESS THE REMAINING
LOW LEVELS OF GROUNDWATER CONTAMINATION.
IN OCTOBER OF 1997, FIVE MONITOR WELLS AT THE SITE WERE SAMPLED. THE
ONLY PETROLEUM COMPOUND DETECTED IN THE WELLS WAS BENZENE. BENZENE
WAS ONLY DETECTED IN MONITOR WELL #9. THE CONCENTRATION OF BENZENE
AT THE TIME OF SAMPLING WAS 2 MICROGRAMS PER LITER. THE NORTH CAROLINA
GROUNDWATER STANDARD FOR BENZENE IS 1 MICROGRAMS PER LITER.
NOW I WOULD LIKE TO SUMMARIZE THE VARIANCE REQUEST:
CAROLINA COATINGS INCORPORATED IS REQUESTING A VARIANCE TO THE
GROUNDWATER STANDARDS FOR BENZENE, ETHYLBENZENE AND XYLENE FOR THE
PROPERTY AT 711 PRESSLEY ROAD. THE NORTH CAROLINA GROUNDWATER
STANDARD FOR BENZENE IS 1 MICROGRAM PER LITER AND THE MOST RECENT
ANALYTICAL RESULTS INDICATE THAT BENZENE IS PRESENT IN GROUNDWATER
ON THE PROPERTY AT 2 MICROGRAMS PER LITER. THE NORTH CAROLINA
GROUNDWATER STANDARD FOR ETHYLBENZENE IS 29 MICROGRAMS PER LITER
AND THE MOST RECENT ANALYTICAL RESULTS INDICATE THAT ETHYLBENZENE IS
NOT PRESENT IN GROUNDWATER ON THE PROPERTY. THE NORTH CAROLINA
GROUNDWATER STANDARD FOR XYLENE IS 530 MICROGRAMS PER LITER AND THE
MOST RECENT ANALYTICAL RESULTS INDICATE THAT XYLENE IS NOT PRESENT IN
GROUNDWATER ON THE PROPERTY.
I HA VE COMPLETED A REVIEW OF THE INFORMATION IN THE VARIANCE AND THE
GROUNDWATER SECTION'S FILE FOR THIS INCIDENT. BASED ON MY REVIEW, I
BELIEVE THAT THE FOLLOWING STATEMENTS MADE IN THE VARIANCE REQUEST
ARE ACCURATE AND SHOULD BE CONSIDERED:
1) THERE ARE NO WATER SUPPLY WELLS WITHIN 2000 FEET OF THE AREA OF
REMAINING GROUNDWATER CONTAMINATION.
2) THE CLOSEST SURF ACE WATER BODIES TO THE REMAINING CONTAMINATION
ARE TWO INTERMITTENT TRIBUTARIES TO SUGAR CREEK. THESE INTERMITTANT
TRIBUTARIES ARE APPROXIMATELY 1,100 FEET FROM THE AREA OF GROUNDWATER
CONTAMINATION.
3) THERE ARE NO ON-SITE EXPOSURE PATHWAYS FOR THE CONTAMINATED
GROUNDWATER.
4) COMPUTER MODELING INDICATES THAT THE GROUNDWATER CONTAMINATION
WILL NOT AFFECT ADJACENT PROPERTIES.
5) THE EXISTING PUMP AND TREAT SYSTEM WOULD REQUIRE MODIFICATION IN
ORDER TO BE ABLE TO ADDRESS THE REMAINING LOW LEVELS OF PETROLEUM
COMPOUNDS.
6) NO OTHER CURRENTLY AVAILABLE TECHNOLOGIES COULD BETTER ADDRESS
THE REMAINING CONTAMINATION.
7) 493,000 DOLLARS HA VE BEEN SPENT ADDRESSING THE CONT AMINA TI ON AT THIS
SITE. IT WOULD COST 48,000 DOLLARS PER YEAR TO CONTINUE TO OPERATE THE
SYSTEM, NOT INCLUDING THE COST OF SYSTEM MODIFICATIONS.
8) GROUNDWATER INFLUENT INTO THE TREATMENT SYSTEM HAS DECREASED TO
LESS THAN ANALYTICAL DETECTION LIMITS.
9) THE AREA OF REMAINING SHALLOW GROUNDWATER CONTAMINATION IS
ESTIMATED TO BE LESS THAN 1/4 ACRE IN EXTENT.
10) THE REMAINING CONTAMINANTS HA VE THE CAPACITY TO DEGRADE AND
ATTENUATE.
Public Hearing Registration Form
0 I · C . 1, • (Legibly print. please!)
~{{_,YQ AIL OoJ?'ljS
Hearing _ ___i_~____c__:_:U:..=-=----o_r-__ V_Ni-_l-AN __ ·u;_ __ /+p_(J_<..-_L _C:-A_. _77_o_,J ___ Date __ B_-_\ '2_-_q_q __ _
Please furnish the Information requested below and Indicate whether you wish to be heard during this
public hearing. This Information Is necessary In order that you be given an opportunity to speak and so
that your name and affiliation. will be correctly entered In the hearing record.
Name 'yA,'T(ll(J( tlA LL..A.l,H--~ Title ~10/L fz1Uti;tJ-:;.,,.:£.d.
Employer/Representing ~ E'.6 ~ \J\.e>o(l,~
Malling Address _'5-=3::::....o;:;_;_l __ 7_,_e,_~---'N=----' _~_R.._~_, __ \ \/_~-=,1 ........... Sv"'"'·'--'1_T€: __ L{,__,_I _______ _
City and State C\.Nxr \o+\--e.. Zip Code __ 'Z;_'B,_·2.._l~J ___ _
Yes b!Q
✓ f<.est¾-.JL r1;3 hrf Iv adrLj.$ ives-hns. trr 4J»n"1~-hs 06 i;/ltl1rm,11tewl-t.P. ~
Do you wish to be heard? If your pre~ntatlon will exceed three minutes, please submit ~/
three copies of your statement to the hearing clerk along with this registration form. \
:;.I(
Do you wish to receive a copy of regulations, If any, resulting from this hearing?
Division of Environmental Management.
North Carolina Department of Environment. Health. and Natural Resources
8-02-1999 3:06PM FROM METROLINA LANDSCAPE 394 1405
AUGUST 2ND? 1999
M. CARL BAILEY, JR.
ASSISTANr CHIEF FOR PLANNING
GROUNDWATER SECTION
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT /i,._,_~D NATURAL RESOURCES
MR BAILEY:
WE ARE IN RECEiPT OF YOUR LETTER DATED JULY 29TH,. COPY
ATfACHED. J HAVE READ AND REREAD THE TEXT AND TO B~
HONEST WE ARE NOT SURE WHAT WE COULD/SHOULD DO.
WE DO KNOW TWO THH\lGS. #l WE WANT TdE RIGHT
ENVIRONMENTAL TlliNG DONE #2 AS PROPERTY OWNERS WE WANT
OUR SELVES · PROTECTED FROM POLLUTION AND ANY POSSIBLE
DECREASE IN PROPERTY VALUE DUE TO RELATED PROBLEMS.
IS THERE A STAFF ADVISEMENT PERSON OR COMMITTEE THAT WOULD
HELP US RATHER THAN OUR COMPANY HA V 1NG TO HIRE A PRIVATE
CONSUL TANT OR LEGAL COUNCIL'!
ANY HELP ANTI CONSIOERA TION WOULD BE APPRECIATED .
'CTF LLY .
1TH
IONS
CC: DA VtD HANCE
309 MORNINGSIDE ROAD D CHARLOTTE, NC 28214 □ [phone] D FAX [phone]
P.2
SALE
Stoever Properties, Inc.
704-333-9483
July 29, 1999
Mr. David Hance
ENHR -DWG -Groundwater Section
P.O. Box29578
Raleigh, NC 27626-0578
Re: 711 Pressley Road
Charlotte, NC
Dear Mr. Hance:
LEASE DEVELOPMENT
Mr. Layne has passed along the letter of July 7, 1999 from Mr. M. Carl Bailey, Jr.
in regard to the above referenced property.
Mr. Layne is concerned about his protection in the case of any leaking of
chemicals from 711 Pressley Road to 801 Pressley Road. He would want relief
from any problems as well as monetary protection and guarantee of any clean-up
required by Wattyl Paints of Atlanta, GA
Mr. Layne is also requesting a plat of the property indicating where the
monitoring wells are located.
Sincerely,
. Stoever
Agent for Mr. Layne
cc: Mr. John W. Layne
605 Hermitage Court • Charlotte, NC 28207
Fax [phone]
...
Author: David Hance at NRGWS0lP
Date: 7/26/1999 3:24 PM
Priority: Urgent
Receipt Requested
TO: "Matt Heller" <Matt [e-mail] .state .nc.us> at Internet
CC: Art Barnhardt@FRO .ENR.STATE.NC.US at Internet
CC: Carl Bailey
CC: David Hance
Subject: Re[2): question
------------------------------------Message Contents------------------------------------
MATT ...
WHAT YOU ARE SAYING SOUNDS LIKE THE GENERAL TYPE PRESENTATION MOST
REGIONS HAVE DONE WITH RESPECT TO VARIANCES.
THE REASON I BROUGHT THIS UP IS THAT WE HAVE OVERHEAD PROJECTORS
AND A SCREEN HERE IN THE CENTRAL OFFICE IF NEEDED THAT EVENING.
SOME REGIONS HAVE FAVORED THE USE OF XEROXED SITE MAPS AND TABLES
ON OVERHEAD-TYPE MYLAR ... AS A COMMUNICATIVE TOOL. THIS IS TO HELP
HEARING ATTENDEES VISUALIZE WHAT YOU ARE TELLING THEM. SOME TECHNICAL
PRESENTATIONS HAVE ALSO INCLUDED THE USE OF HANDOUTS.
THE EXTENT OF VISUALS IS REALLY UP TO THE REGIONAL OFFICE STAFF
PRESENTATOR AND THE HEARING OFFICER. IF IT IS DETERMINED THAT THERE
IS A NEED FOR AN OVERHEAD PRESENTATION ... PLEASE LET ME KNOW BY
THURSDAY, AUGUST 5, 1999.
dh 919-715-6189
****************
ps .. fyi---there has been some interest in this hearing from a
property manager for some of the adjacent property owners. This
company is known as Norcom Development Corporation. They have not
raised any issues ..... but have requested additional information from
me on the variance (the summary, site maps, etc).
Reply Separator _________________ _
Subject: re: question
Author: "Matt Heller" <Matt [e-mail]> at Internet
Date: 7/26/1999 2:07 PM
David -I am not planning on doing an overhead presentation. I am
planing on talking about the dimensions and concentration of the
remaining plume, the fate and transport of the plume and the
remedial actions that have been conducted to date. Let me know if
the scope of this presentation should be different .
Matt
Date sent:
From:
Subject:
Thu, 22 Jul 1999 10:19:43 -0400
David [e-mail] (David Hance)
re: question
To: · [e-mail],
Art [e-mail]
Copies to: David [e-mail] (David Hance)
> Matt:
>
>
> Since the Regional Staff does the technical presentations for
> variances, are you planning to use overheads and a screen?
>
> If so .... what materials will you use? I have the variance here that
> shows tables and maps of the site.
>
>
>
>
>
If we need to talk ... feel free to contact me at 919-715-6189.
Matt Heller, P.G.
Division of Water Quality
Groundwater Section
Mooresville Regional Office
919 North Main Street
Mooresville, NC 28115
Matt [e-mail] .state.nc.us
[phone], ext. 241
Fax [phone]
dh
Author: David Hance at NRGWS0lP
Date: 7/22/1999 10:19 AM
Priority: Urgent
Receipt Requested
TO: Matt [e-mail] at Internet
TO: Art [e-mail] at Internet
CC: David Hance
Subject: re: question
------------------------------------Message Contents------------------------------------
Matt:
Since the Regional Staff does the technical presentations for
variances, are you planning to use overheads and a screen?
If so .... what materials will you use? I have the variance here that
shows tables and maps of the site.
If we need to talk ... feel free to contact me at 919-715-6189.
dh
Author: David Hance at NRGWS0lP
Date: 7/22/1999 10:15 AM
Priority: Urgent
Receipt Requested
TO: Art [e-mail] .US at Internet
TO: Matt [e-mail] at Internet
CC: Arthur Mouberry
CC: Carl Bailey
CC: David Hance
Subject: re: FINAL ho speech for Carolina Coatings Variance
------------------------------------Message Contents------------------------------------
Art and Matt:
The final hearing officers speech for Art Barnhardt has been sent
to both of you in interoffice mail. It will go out in today's mail
and should arrive by Monday July 26th. Please call me at 919-715-6189
if it does not arrive.
dh
Included with this memorandum is an information packet which contains a
summary of the variance and directions to the hearing location. You will need to
discuss the development of your hearing officer's speech with David Hance. Mr.
Hance may be contacted at 919-715-6189. Please be advised staff have not made
arran gements for your overnight stay .
The written comment period for this variance will close .at 12:00 P.M.
(midnight) on September 13, 1999. Pursuant ·to established Division policy, I am
requiring you to complete the hearing officer's report and the recommendation to
the Environmental Management Commission Groundwater Committee no later
than December 13, 1999. This period ohime is ninety (90) days after the closing date
for written public comment and allows Division staff adequate time to review your
recommendation. Unless significant new site information becomes available after the
public hearing or other extraordinary circumstances occur that dictate a longer review
period by the hearing officer, the earliest date that this variance may be considered by
the Groundwater Committee is October 14, 1999. If your review of the variance
shows that there is a need for a longer evaluation period, please contact Arthur
Mouberry at [phone].
I appreciate your taking the time to conduct this hearing. The staff will be glad
to assist you through the proceedings. If you have any questions, feel free to call Carl
Bailey at [phone] or David Hance.
Attachments.
cc: Arthur Mouberry
Carl Bailey
David Hance
2
• I
I
'
DIVISION OF WATER QUALITY
GROUNDWATER SECTION
June 24, 1999
MEMORANDUM
To: Kerr T. Stevens
From: Arthur Mouberry #
Subject: Request for Variance from 15A NCAC 2L .0202 and 15A
NCAC 2L .0106(i) for a Site Owned by the Carolina Coatings Incorporated at 711
Pressley Road in Charlotte, North Carolina (Groundwater Incident Number
8949).
From 1971 through 1991, Mr. Linwood Carter operated a portion of the Carolina
Coatings Incorporated property as a paint blending facility located at 711 Pressley Road in
Charlotte, North Carolina. This site is at the intersection of Billy Graham Parkway and US
Interstate 77. In 1991, Mr. Carter sold this facility to Wattyl Paints of Atlanta, Georgia. The
new owner of this facility moved all solvent based mixing processes out of North Carolina 1991 .
Mr. Carter maintains cleanup responsibilities for substances found at this site.
The Carolina Coatings facility consists of a total of 47,000 square feet of warehouse and
office space on 6.17 acres ofland. During the period this property was owned by Mr. Carter,
Carolina Coatings manufactured paint using a batch mixing process which blended latex
emulsions with dry pigments, wetting agents, water, defoamers and other ingredients. This
process required the storage of empty fifty-five gallon drums on a concrete pad located rear of
the building. Waste water settling tanks were also located in this area. During the course of
business operations leaks had occurred in drums located at this site and from the wastewater
settling ponds.
Pursuant to the transfer of ownership of this property in 1991, Mr. Carter had
environmental assessments conducted of soils and groundwater at this site. Ethylbenzene,
Toluene and Xylene were found in soils around this site. Analysis of groundwater samples
showed the presence of several volatile organic compounds, Benzene, Ethylbenzene, Toluene
and Xylene. Since 1991 only latex water-based, products have been processed at 711 Pressley
Road by Wattyl Paints. The owner of Carolina Coatings Incorporated, Mr. Linwood Carter, is
entirely responsible for cleanup of this release which is shown in Division of Environmental
Management files as Groundwater Incident Number 8949.
1
Pursuant to title 15A NCAC 2L .0l 13(c) variance applications are required to have
specific information in order to adequately review a request. The Carolina Coatings variance
request is contained in a report titled "Variance Re quest -Carolina Coatin Q:s Site -Charlotte,
North Carolina, December 9 , 1996. Dames and Moore N.C. Job No.23995-002-200.". In
addition, memoranda and other correspondence are included with this request. The information
submitted by Dames and Moore on behalf of the Carolina Coating Incorporated appears to meet
the requirements of 15A NCAC 2L .0113(c) and is summarized as follows:
Rule .0113 (c)(l): Resolution b y the Countv or e.oveming Board:
Carolina Coatings Incorporated has always been a privately owned
company. No resolution is necessary.
Rule .0l 13 (c)(2): A descri ption of pas t, existing or pro posed activities that would result in a
dischar ge of contaminants into e:r oundwater:
The former Carolina Coatings Incorporated is located inside the city limits of
Charlotte, North Carolina at 711 Pressley Road (Mecklenburg County Tax
Identification Number 145-291-03). The report titled "Variance Re quest -Carolina
Coatin gs Site -Charlotte, North Carolina . December 9 , 1996. Dames and Moore
N.C. Job No.23995-002-200" contains the relevant information about this site. The
site consists of approximately 6.17 acres of land.
A Notice of Violation was issued to Carolina Coatings Incorporated by the
Department on August 28, 1992. Remedial Action Plans were submitted to the
Mooresville Regional Office on June 29, 1992 and March 23, 1993. On January 18,
1994, a discharge permit for an on-site infiltration gallery was authorized by the
Division of Water Quality (WQ0007993). Details of soil and groundwater corrective
actions are documented in a report titled "Soil and Groundwater Remediation
Report (April 19, 1994)" at the Mooresville Regional Office. All potential sources
of groundwater contamination were identified at this property by the company.
This property at 711 Pressley Road in Charlotte, North Carolina, formerly owned
by Mr. Linwood Carter, and is in an area with a mixture of commercial, industrial,
and residential development.
The comprehensive site assessment and other investigations revealed
Benzene, Toluene, Ethylbenzene, and Xylene (o, m, and p) (BETX) in the
groundwater and soil beneath the site. This area was located at the southwest
corner of the building near an 88 foot by 66 foot concrete pad and three small
wastewater settling tanks. This was where the company stored chemicals and
performed batched mixing operations for solvent-based paints. This area is
2
approximately 10 feet from the northwest property line and 75 feet from the
southwest property line. The entire property at 711 Pressley Road is surrounded
by a fence. This plume was estimated to have covered an area of approximately
10,000 square feet (0.23 acers) prior to the implementation of correctiv~ actions by
the Carolina Coatings Incorporated. According to information at the Mooresville
Regional Office the vertical extent of this plume is believed to be less than 48 feet
below the ground surface.
Carolina Coatings Incorporated implemented cleanup of soils at this site in
September 1992 with the removal of 900 cubic y~rds of soil that exceeded the 50
milligram per kilogram target cleanup level. Between June 2, 1993 and June 25,
1993, the company removed an additional 1,500 cubic yards of contaminated soils.
Excavated soils were treated offsite and clean fill material was used as backfill. As a
result of soil remediation, the concrete pad was removed and subsequently replaced.
In July 1993 the company installed a pump-and-treat system with a single
groundwater recovery well (RW-1) located near the south corner of the former
concrete storage pad as shown in Figure 6 of the variance. From March 23, 1994
through January 1997 a total of 328,500 gallons of groundwater has been treated via
pump-and-treat technology. The treated discharge was sent to an upgraident
infiltration gallery. An infiltration gallery is a closed-loop conveyance that allows
water and other fluids, discharged through the pump-and-treat system, to be sent
back into the subsurface where they recirculated into the cleanup system for
continual treatment. An infiltration gallery may also serve to enhance intrinsic
biodegradation of contaminants by introducing dissolved oxygen in the subsurface
which may stimulate biologic decomposition of some dissolved substances. Non-
Discharge Permit WQ0007993 was issued on January 18, 1994 for the infiltration
gallery. The Groundwater Section staff have recommended that, if the variance
request is granted, no permit for this infiltration gallery is to be reissued. The
company's environmental consultant, Dames and Moore, reports that this device
will no longer be used once the variance is granted.
The Division of Water Quality required Carolina Coatings Incorporated to
perform groundwater monitoring to determine the vertical and lateral extent of
contamination at the site. Table 2 of the report titled "Variance Re q uest-Carolina
co-atin gs Site -Charlotte, North Carolina, December 9, 1996. Dames and Moore
N.C. Job No.23995-002-200" shows that three of six monitoring wells were sampled
from March 1994 through September 1996 on a quarterly schedule. Groundwater
samples were analyzed using US Environmental Protection Method 8020. Page 6 of
the variance request shows that only Monitoring Well# 9 has had concentrations of
Benzene, Ethylbenzene, and Xylene above the Groundwater Quality Standards in
15A NCAC 2L .0202. Toluene has never appeared in any of the monitoring wells at
a concentration in excess of the Groundwater Quality Standard in 15A NCAC 2L
.0202. Table 2 of the report titled "Variance Re q uest -Carolina Coatin gs Site -
Charlotte, North Carolina, December 9, 1996. Dames and Moore N.C. Job
N o.23995-002-200" shows that the highest concentration of Benzene, Ethylbenzene,
and Xylene have been found in this well. The highest concentration of Benzene in
exceedence of the Groundwater Quality Standard was 0.027 milligrams per liter or
3
27 micrograms on September 3, 1996. The highest concentration of any substance
in exceedence of the 15A NCAC 2L .0202 Groundwater Quality Standard found at
this site was Xylene ( o,p,m). Xylene appeared at the December 1994 monitoring
event at 0.860 milligrams per Liter or 860 micrograms/Liter.
As shown on Table 1 of the report titled "Variance Req uest -Carolina
Coatin gs Site -Charlotte, North Carolina, December 9, 1996 , Dames and Moore
N.C. Job No.23995-002-200"from March 29, 1994 through October 30, 1996, the
company conducted analysis of samples from Recovery Well# 1 on the influent side
of the cleanup system to determine the effectiveness of the pump-and-treat cleanup.
This data shows that the source of the groundwater contamination at this site has
been significantly reduced-such that the plume can no longer be detected.
Based on the results of the groundwater monitoring and recovery well
monitoring in September and October 1996, the Carolina Coatings reqµested a
variance and that the pump and treat groundwater cleanup system be shut off. In
January 1997 the Mooresville Regional Office agreed that active cleanup should be
discontinued. Based on the results of groundwater monitoring and monitoring of
influent samples in the recovery well from the pump and treat cleanup system the
cleanup system was turned off. This variance request encompasses the entire
property at 711 Pressley Road in Charlotte, North Carolina.
Potential sources of groundwater contamination in the area are discussed in
Pages 9 through 11 and in Appendix A of the report titled "Variance Re q uest -
Carolina Coatin 2:s Site -Charlotte, North Carolina, December 9, 1996 , Dames and
Moore N.C. Job No.23995-002-200.". Appendix A shows Vista Site Assessment
Reports of these properties with maps. Potential sources of groundwater
contamination are summarized as follows:
1) The property at 711 Pressley Road formerly owned by Carolina
Coatings Incorporated (Mecklenburg County Tax Identification
Number 145-291-03). This site is now owned by Wattyl Paints. The
Vista Site Assessment Report lists this site on the state "CERCLIS"
and as a "Large Quantity Generator" of hazardous wastes.
2) The property at 807 Pressley Road known as The Gifford-Hill
Company located 1/10 of a mile northwest of the site. This property is
upgradient from the site and is listed with the Division of Waste
Management-Underground Storage Tank Section as having reported
a leaking petroleum underground storage tank on June 1, 1989.
3) Property at 927 Pressley Road known as Climate Conditioning of
Charlotte located 0.2 miles northwest of the site. This property is
upgradient from the site and is listed with the Division of Waste
Management-Underground Storage Tank Section as having reported
a leaking petroleum underground storage tank on December 27, 1994.
In addition, Page # 11 of the "Vista Site Assessment Report" shows
4
that at one time this company removed three underground storage
tanks that contained gasoline.
4) Observer Transport Company located 0.3 miles northwest of the site
at 1001 Pressley Road. This property is upgradient from the site and
is listed with the Division of Waste Management-Underground
Storage Tank Section as having reported three gasoline leaks on April
12, 1988, April 17, 1992, and April 15, 1994. Page# 12 of the "Vista
Site Assessment Report" shows that two of these tanks contained
"Gasoline" and "Diesel Fuel". The third tank contained a product
described as "Petroleum Other".
5) Xerox Corporation located 0.35 miles northwest of the site at 4740
Dwight Evans Road. This property is upgradient from the site and is
listed with the Division of Waste Management-Underground Storage
Tank Section as having reported a leaking petroleum underground
storage tank on September 30, 1986. Page # 12 of the "Vista Site
Assessment Report" shows that this tank contained "Gasoline" and
"Diesel Fuel".
6) White Machines which is located 0.53 miles north of the site at 4300
Barringer Drive. This property is cross-gradient from the site and is
listed with the Division of Waste Management-Underground Storage
Tank Section as having reported a leaking petroleum underground
storage tank on March 21, 1990. Page# 13 of the "Vista Site
Assessment Report" shows that this tank contained "Gasoline" and
"Diesel Fuel".
7) Piedmont Natural Gas which is located 0.4 miles east of the site at
Verbena & Yancey Streets. This property is downgradient from the
site and is listed in the variance request as having reported a leaking
petroleum underground storage tank on January 15, 1990. Page# 13
of the "Vista Site Assessment Report" shows that this tank contained
"Gasoline" and "Diesel Fuel".
8) Industrial Truck Sales which is located approximately 0.1 miles east
of the site at 3910 Stuart Boulevard. This property is downgradient
from the site and is listed in the variance request as a "RCRA small
quantity generator". Page# 9 and# 10 of the "Vista Site Assessment
Report" shows that underground storage tanks have also been at this
property. Three tanks have been removed consisting of one 8,000
gallon gasoline tank, a 1,000 gallon oil tank, and a 250-gallon oil tank.
One 500-gallon oil tank is list as "active/in service" at this property.
5
9) Ryder Truck Rental Incorporated which is located approximately
0.11 miles east of the site at 3901 Stuart Boulevard. This property is
downgradient from the site and is listed in the variance request as a
"RCRA small quantity generator". Page# 10 and 11 of the "Vista
Site Assessment Report" shows that eight "in service" underground
storage tanks are present at this property containing "gasoline, diesel
fuel, motor oil, oil" and a fluid desc_ribed as "hazardous".
10) Chemlawn Services Corporation which is located approximately 0.03
miles southeast at 655-R Pressley Road. This property isJocated
downgradient from the site. Appendix A shows that this site once had
a 2,000 gallon underground storage tank for diesel fuel. This tank is-
listed as "removed" from the property.
11) Page# 9 of the "Vista Site Assessment Report" shows two "in service"
underground storage tanks at the RSM Company located at 811
Pressley Road located approximately 0.09 miles northwest. This
property is upgraident from the site.
12) Page # 12 of the "Vista Site Assessment Report" shows that Ridgeway
Chemicals Incorporated has three underground storage tanks at 651
Michael Wylie Drive located 0.25 miles northeast of the site. These
tanks are listed as "active/in service" in the report. A 1,000 gallon
tank was removed from this site. The contents of all four tanks are
reported as "unknown". This property is cross-gradient from the
site.
13) Pressley Road ( a public roadway).
14) Public sewer lines and other utilities in the area.
15) Southern Railroad (a private rail company).
In addition, Page #15 through Page # 17 of Appendix A shows eight known
sources of groundwater contamination in the general area near 711 Pressley Road.
Due to inadequate information on the location of these sites, it is not possible to
represent them on maps contained in Appendix A. Scaled diagrams of this site are
found in Figures # 1 through # 4 and Figure # 11 of the report titled "Variance
Re q uest -Carolina Coatings Site -Charlotte. North Carolina, December 9, 1996,
Dames and Moore N.C. Job No.23995-002-200." !.
6
Rule .0113 (c)(3): Descri ption of the pro posed area for which the variance is re quested .... :
Maps of the area are shown in Figures 1 through 5 of the report titled
"Variance Req uest-Carolina Coatin es Site -Charlotte, North Carolina, December
9, 1996. Dames and Moore N.C. Job No.23995-002-200.". The property at/11
Pressley Road for which Carolina Coatings Incorporated has requested this
variance for Groundwater Incident Number 8949 is within an area consisting of a
mixture of residential, commercial and industrial development. The map on Figure
11 shows that the property is bordered on its east side by Pressley Road and four
adjacent properties border the Carolina Coatings site on its north, south and west ·
sides. The Southern Railroad Line is to the west within 1,000 feet of the area in
which the release of substances occurred. The property on the west side is vacant
land identified under Mecklenburg County Tax Identification Number 145-291-07
and owned by Mr. Linwood Carter, who is also the proprietor of Carolina Coatings
Incorporated. In applying for a variance at 6500 North Tryon Street, Carolina
Coatings Incorporated did not include this adjacent property or any portion of it in
the request.
Table 4 in the report lists adjacent property owners by Mecklenburg County
Tax parcel numbers and addresses. The last column of this table locates these
adjacent properties relative to the site at 711 Pressley Road. Figure 11 shows these
properties and owners from a tax line map in Book 145, Pages 27-29 (Revised
5/7/96).
Figure 4 of the variance request also shows that the area of groundwater and
soil contamination prior to remedial actions was of an amorphous shape, much of
which extended beneath the former concrete pad and settling tanks. Since soil
removal activities and the implementation of the pump and treat cleanup system,
the area where substances are known to exist is shown in Figures 7 through 12 of the
variance request. These figures reveal that the area in which substances persist at
concentrations in exceedence of the Groundwater Quality Standards in 15A NCAC
2L .0202 is roughly in the shape of an ellipse. The groundwater contamination that
the Carolina Coatings Incorporated is responsible for encompasses both the
recovery well and Monitoring Well# 9 and appears limited to this area. Figures 8
through 10 and Figure 12 of the report shows that substances at 711 Pressley Road
Street have not migrated onto adjacent properties at concentrations above
Groundwater Quality Standards in 15A NCAC 2L .0202. This variance is for all
the land entirely within the property boundaries of 711 Pressley Road for which
Carolina Coatings Incorporated has cleanup responsibilities.
Pages 11 through 13 of the report titled "Variance Re q uest-Carolina
Coatin gs Site -Charlotte, North Carolina. December 9, 1996, Dames and Moore
N.C. Job No.23995-002-200" discusses groundwater contaminant migration and the
potential impact to water supply wells and surface streams in the area. Two water
supply wells are located within one-half mile of the site. These wells are 2,300 feet
south of the Carolina Coatings property at Yorkmont Road and Lochlane Drive.
The company could not ascertain if these water supply wells are currently in use as
7
a source of drinking water supply or other uses. Based on water use data and
hydrogeologic conditions in the general area, Carolina Coatings Incorporated does
not believe that this variance will have an effect on these wells. Based groundwater
flow calculations, the company does not believe that the variance will impact any
receptors near 711 Pressley Road.
Rule .0113 (c)(4): Su pportin e information to establish that the variance will not endan eer
the p ublic health and safetv ... :
This part of the variance concerns Groundwater Quality Standards shown in
15A NCAC 2L. 0202 and has been requested for Benzene, Ethylbenzene, and
Xylene(-o,-m, and p). In order to assess health impacts, groundwater sampling was
conducted at on-site monitoring wells to assess the extent of contamination, the
concentration levels of substances, and the movement of substances to adjacent
pro-perties. Groundwater monitoring from Carolina Coatings Incorporated
indicates that substances released at this site d9 not pose a hazard to the public. As
shown in Figure 5, nine monitoring well were originally installed at 711 Pressley
Road by the company. During site renovation to remove soil and repair the
concrete storage pad, two of these wells (Monitoring Wells MW# 2 and MW# 8)
were abandoned by the company prior to the implementation of groundwater
cleanup.
Carolina Coatings has conducted quarterly groundwater sampling at
Monitoring Well MW# 3, Monitoring Well MW# 7, and Monitoring Well MW# 9
from March 1994 through October 1997. Monitoring Well MW# 3 is located
upgradient approximately 125 feet to 150 feet from the area in which the release of
substances occurred at the northwest property line. Monitoring Well MW# 7 is
located within 35 feet directly to the south-southwest of this area and is roughlr
down-gradient to the area that was impacted by the release. Monitoring Well MW#
9 is within the area of the release and is slightly down gradient from Recovery Well
RW # 1. Thirteen separate sampling events occurred during this period. As shown
in an April 19, 1999 letter sent to Groundwater Section, the last sampling and
analysis at all monitoring wells occurred on October 9, 1997. Toluene has never
appeared in any sample taken from monitoring wells from this site above the
Groundwater Quality Standard.
Table 2 of the variance request and data in the April 19, 1999 letter shows
that Monitoring Well MW # 3 and Monitoring Well MW # 7 have never had
concentrations of substance above detectable limits. Only Monitoring Well MW#
9 has shown concentrations of Benzene, Ethylbenzene, and Xylene above the
Groundwater Quality Standards in 15A NCAC 2L .0202. The only substance that
appeared in Monitoring Well MW# 9 during the October 9, 1997 monitoring event
was Benzene at 0.002 milligrams per liter or 2.0 micrograms per liter. The
Groundwater Quality Standard for Benzene is 0.001 miUigram per liter or 1.0
microgram per liter. It is also important to note that Table 2 shows several graphs
of the concentrations levels of substances analyzed from Monitoring Well MW# 9
8
from March 1994 to September 1996. Although Ethylbenzene and Xylene have
been reduced below respective Groundwater Quality Standards, the concentration
of Benzene from samples taken from this well have fluctuated over time. In
September 1995 this concentration was reduced below the Groundwater Quality
Standard but later "rebounded" to the extent that the Benzene level in this well was
in exceed of the standard during subsequent quarterly monitoring events. In order
to provide additional supporting data for this variance request, Carolina Coatings
Incorporated sampled the downgraident monitoring wells MW # 5 and MW # 6.
No substances were detected in these wells above Groundwater Quality Standards
in 15A NCAC 2L .0202.
The Division also required the Carolina Coatings Incorporated to evaluate
the effectiveness of groundwater cleanup efforts by examining concentrations of
substances in the recovery well used as a sump to collect dissolved hydrocarbons
from the site. This monitoring effort was necessary to understand the effect pump-
and-treat cleanup has had on concentrations of constituents at the site. Table 1 of
the report titled "Variance Request -Carolina Coatin gs Site -Charlotte. North
Carolina, December 9, 1996 , Dames and Moore N.C. Job No.23995-002-200"
provides a record of monthly groundwater samples obtained at the influent of the
recovery well for the pump-and-treat groundwater remediation system. This
monitoring was conducted from March 29, 1994 through October 30, 1996.
Except for Benzene, concentrations of substances monitored from the
recovery well have never exceeded the Groundwater Quality Standards in 15A
NCAC 2L .0202. Since monthly sampling of this recovery well influent began in
March 1994, the Benzene concentration has fluctuated from levels above the
Groundwater Quality Standard to below detectable limits. The highest
concentration of Benzene reported at this site was 0.0076 milligrams per liter or 7.6
micrograms per liter from the May 6, 1994 sampling event. The Groundwater
Quality Standard for Benzene is 0.001 milligram per liter or 1.0 microgram per
liter. Samples taken from September 30, 1996 through October 30, 1996 showed
concentrations of all substances below detectable limits.
From the information shown on Page 13 of the variance request, Carolina
Coatings Incorporated evaluated the impact granting a variance would have on
nearby receptors. The nearest downgradient adjacent property is a small strip of
the vacant land owned by Mr. Linwood Carter which is approximately 110 feet
from the area in which substances were released at 711 Pressley Road. Based on an
average hydraulic conductivity of 0.06 feet per day, an approximate hydraulic
graident of 0.01 feet per foot, and an effective porosity of 20 percent for silty clay,
the groundwater flow is calculated at 1.1 feet per year. Assuming no contaminant
dilution or attenuation and this figures, it is believed that it would take 100 years for
the plume of substances to reach this property boundary. In addition to
groundwater flow calculations, Carolina Coatings Incorporated has also submitted
the results of modeling using the Domenico Solute Transport Model for this site as
discussed on Page 13 of the report titled "Variance Req uest -Carolina Coatin gs
Site -Charlotte, North Carolina, December 9, 1996 . Dames and Moore N.C. Job
No. 23995-002-200". The results of this modeling support the companies view that
9
this variance will not impact adjacent properties. Data from this modeling may be
found in Appendix B of the variance request.
No water supply wells were identified at adjacent properties to 711 Pressley
Road. A well survey only identified only two water supply wells within the ½ mile
radius of the site as specified under 15A NCAC 2L .0113(c)(4). -These are located in
Figure 2 of the variance request at the intersection of Lochlane Drive and Y orkmont
Road app·roximately 2,300 feet south of 711 Pressley Road. According to the
information in this request, these wells are cross-gradient from the site. Page 12
states that is not known if these wells are being used as a source of drinking water
supply or for purposes other than drinking water. Drinking water for the City of
Charlotte is obtained from Mountain Island Lake on the Catawba River twelve
miles north of the site. All downgradient properties and other area properties are
supplied drinking water from the City of Charlotte.
'It is hig}!ly improbable that public water supply lines will be impacted by
this variance. Numerous water supply lines and other utilities are located along
Pressley Road, Bishop Drive and Yorkwood Road. Contacts with the Charlotte
Mecklenbu~g Utility Department and found that utilities are not a potential path for
migration of petroleum hydrocarbons from the site. Page 12 of the variance request
shows that the depth to the groundwater in this area is approximately 15 feet to 20
feet. The utility department reported that area water lines and utilities are buried
less than five (5) feet from the surface. Groundwater contamination from Incident
Number 8949 that is beneath 711 Pressley Road is too deep within the subsurface to
impact these lines. In addition, Page 12 also states the Carolina Coatings
Incorporated does not believe any buildings with basements will be impacted by this
variance request.
Rule .0113 (c)(5): Su pp ortin g information to establish that requirements of the rule cannot
be achieved b providin g best available technolo gv economicallv reasonable:
The part of the request that concerns variance to Corrective Action in 15A
NCAC 2L .0106U) will allow Carolina Coatings Incorporated to discontinue
Corrective Action at this site. The company has submitted supporting infonnation
in the report with other documents demonstrating that the continued application of
best available technology will not result in significant long term remediation of the
site to the Groundwater Quality Standards contained in 15A NCAC 2L .0202. The
is due to the high probability that continued cleanup activities at the site will not
significantly reduce contaminant levels below the Groundwater Quality Standards
in 15A NCAC 2L .0202.
Since discovery of the release in 1991, Carolina Coatings Incorporated has
disposed of a total of 2,400 cubic yards of BTEX contaminated soil. Page 6 of the
report titled "Variance Req uest -Carolina Coatin gs Site -Charlotte, North
Carolina. December 9, 1996, Dames and Moore N.C. Job No.23995-002-200" states
that the company has treated approximately 328,500 gallons of groundwater to
10
• f • I
comply with the cleanup requirements of the Corrective Action Plan that was
implemented in March 24, 1994. Pages 15 through 16 of the report titled
"Variance Req uest-Carolina Coatings Site -Charlotte, North Carolina, December
9, 1996, Dames and Moore N.C. Job No.23995-002-200" states that a total of
$493,000 has been expended to design and install the remediation system, operate
the system, monitor progress of cleanup activity, and cleanup this-site. Page 15 of
the variance request shows that the owner of Carolina Coatings Incorporated, Mr.
Linwood Carter, is retired and is reported in the variance request as financing the
cleanup of this site from this personal savings. He has had no direct employment
since the sale of the property at 711 Pressley Road in 1991 to Wattyl Paints
Incorporated.
Groundwater analysis of samples from on-site monitoring wells showed
significant reductions in the concentrations of substances from March 1995 through
October 9, 1997. As previously stated the groundwater pump-and-treat cleanup
system operated from March 24, 1994 through January 1997. Except for
Monitoring Well# 9, Benzene and other substances related to paint mixing
operations have not been observed above Groundwater Quality Standards from
quarterly groundwater samples. Although concentrations of Benzene, Toluene,
Ethylbenzene, and Xylenes have been significantly reduced near Monitoring Well#
9 since cleanup operations began, the concentration of Benzene at a portion of this
site remains at levels in exceedence of the Groundwater Quality Standard in 15A
NCAC 2L .0202. Page 7, Page 8, and Table 3 of the report titled "Variance Req uest
-Carolina Coatin ~s Site -Charlotte, North Carolina, December 9, 1996, Dames and
Moore N.C. Job No .23995-002-200" shows that after the pump-and-treat cleanup
system was temporarily taken out of operation for a period of five days,
concentrations of substances in monitoring wells, including Monitoring Well# 9, did
not change significantly. Table 1 shows that while the cleanup system was in
operation, results from groundwater samples taken from the influent of Recovery
Well RW # 1 during the period of March 29, 1994 through October 30, 1996,
revealed remaining concentrations of substances beneath 711 Pressley Road had
been significantly reduced such that they could no longer be detected.
In order to demonstrate that the requirements of the rule cannot be achieved
using best available technology, title 15A NCAC 2L .0113(c)(5) requires that specific
technology considered be identified, the costs of implementing the technology be
shown, and the impacts of the costs on the applicant be provided. Page 16 of the
report titled "Variance Re q uest -Carolina Coatine s Site -Charlotte. North
Carolina, December 9, 1996 , Dames and Moore N.C. Job No.23995-002-200" states
that continued operation and monitoring at 711 Pressley Road will cost Carolina
Coatings approximately $48,000 per year. In addition, Page 14 of the request
shows that in order to continue cleanup with the pump-and-treat system, significant
upgrades will be needed for this system. These modifications include the installation
of additional groundwater recovery wells, new pumps, and renovations to increase
the size of the infiltration gallery. The company believes that the _low residual levels
of contaminants in the groundwater at this site does not warrant the continued use
of the pump-and-treat cleanup system. -
11
Carolina Coatings Incorporated has considered the use of air sparging with
soil vapor extraction (SVE) as alternate technology to the present pump-and-treat
cleanup system. This technology is an in-situ remediation method that involves the
physical introduction of air below the water table to volatilize groundwater
contaminants from groundwater and subsurface materials into a vapor phase. The
SVE portion of this system captures the volatilized substances so that they may be
removed from the subsurface environment. As shown on Page 15 of the report
titled "Variance Re q uest-Carolina Coatin gs Site -Charlotte, North Carolina,
December 9 , 1996, Dames and Moore N.C. Job No.23995-002-200" states that the
average hydraulic conductivity in saturated zone beneath the site is 2 x 10-5
centimeter per second. Based on this low permeability, Carolina Coatings does not
believe the use of this type of technology will be effective at removing substances
that remain at 711 Pressley Road.
Carolina Coatings Incorporated did not identify any technology, other than
those already at the site and alternate technology identified in the variance, that
would meet the requirements of 15A NCAC 2L .01060) as "best available
technology". Pursuant to the requirements of 15A NCAC 2L .0113(c)(5), the
company does not believe that continuing remediation is economically reasonable.
Rule .0113 (c)(6): Su pp ortin g information to establish that com pliance would produce
serious financial hardshi p on the a pplicant:
Carolina Coatings Incorporated has submitted information showing that
compliance with the rules will result in a serious financial hardship. Page 15 of the
variance request shows that the owner of Carolina Coatings Incorporated, Mr.
Linwood Carter, is retired and is reported in the variance request as financing the
cleanup of this site from this personal savings. He has had no direct employment
since the sale of the property at 711 Pressley Road in 1991 to Wattyl Paints
Incorporated. Allowing the persistence of low levels of contaminants in -
groundwaters that, after approximately three years of applying best available
technology, have asymptotically approached the Groundwater Quality-Standards in
15A NCAC 2L .0202 through a variance is a prudent means of addressing Carolina
Coatings release at this site. It is no less effective a means of addressing residual
concentrations of substances at this site than continuing the use of pump-and-treat
system and is less expensive.
12
Rule .0113 (c)(7): Su pportin g information that com pliance would produce serious financial
hardshi p without eq ual or greater public benefit:
The company _has submitted information in the request demonstrating that
the environment, safety and public health would not be impacted by this variance.·
A January 6, 1997 letter from the Mooresville Regional Office serves as a
justification for this variance as it states that " ....... continuation of pump and treat
remediation is neither cost effective nor environmentally beneficial". The letter
further states that the "Risk to the public is minimal considering the lack of active
water supply well systems, distance to surface water bodies, and the industrial
character of the site and surrounding sites.".
Rule .0113 (c)(8): "A co pv of an y S pecial Order ... ":
No Special Order by Consent has been issued for this site.
Rule .0113 {c){9): "A list of names and addresses of pro p ertv owners ... ":
The property owners within the proposed area of the variance are shown in
Table 4 and the map in Figure 11 of the report titled "Variance Re q uest-Carolina
Coatin gs Site -Charlotte, North Carolina, December 9, 1996 , Dames and Moore
N.C. Job No.23995-002-200". This listing includes the Trimming-Associates LTD,
the Presseley Park Restaurant owned by Ionnis and Gregory Andreas, Rebpat
Leasing, Joachim H. Klitzsch, James A. Williams, J. David Fortenbery, Davis
Brothers Venture, Exit Fourteen Associates, the former Carolina Coatings site at
711 Pressley Road now owned by Wattyl Paints, John W. Layne, Linwood T. Carter
(property adjacent to 711 Pressley Road), the North Carolina Department of
Transportation, Southern Railroad, and two parcels of land owned by Eight
Hundred Eleven Pressley. Title 15A NCAC 2L .0113(e)(E) requires that
notification of a public hearing on this variance be given to the owner or owners of
these adjacent properties "at least 30 days prior to the date of the hearing".
It is the recommendation of the Groundwater Section that the subject variance
request to Corrective Action requirements of 15A NCAC 2L .0106(j) and Groundwater
Quality Standards contained in 15A NCAC 2L .0202 proceed to public notice in
accordance with 15A NCAC 2L .0113(e). On February 27, 1997, the Division of
Epidemiology completed their review of the risk assessment methodology for this site and
recommended that this variance be granted for Carolina Coatings Incorporated at their
former property located at 711 Pressley Road in Charlotte, North Carolina. Upon your
concurrence with our recommendation, the Groundwater Section will proceed with the
13
preparation of the required public notice and hearing. Upon completing of the
requirements of 15A NCAC 2L .0113(d -t), with a recommendation to grant this variance
from the Environmental Management Commission Groundwater Committee, this request
will proceed to the Environmental Management Commission for final action in 15A NCAC
2L .0113(g). If there are any questions regarding this matter or if any additional
information is needed, please let me know.
ATTACHMENTS:
cc: -Groundwater Section Assistant Chiefs
Mooresville Regional Groundwater Supervisor
Dr. Ken Rudo
David Hance
14
Directions to Variance Hearing for the Carolina
Coatings Variance (Site located at 711 Pressley Road in
Charlotte, NC)
HEARING LOCATED AT:
Mecklenburg County Courthouse Criminal Courts Building -2nd Floor, Courtroom 2203
700 East Fourth Street, Charlotte, NC (Thursday, August 12, 1999 at 7:00 PM)
MOORESVILLE REGIONAL OFFICE STAFF PRESENTER:
Matt Heller [phone]; fax -[phone]
RALEIGH GROUNDWATER SECTION STAFF RECORDER:
David Hance [phone]; fax -{919) 715-0588
HEARING OFFICER: Art Barnhardt [phone]; fax -[phone]
CONTACTS AT THE COURT HOUSE -
CAPT. DEATON -[phone]
MAIN NUMBER FOR SHERIFF' S OFFICE -[phone]
SECURITY POST AT THE CRIMINAL COURTS BUILDING -[phone]
FROM FAYETTEVILLE NC:
Take US 401 to Laurinburg, North Carolina and then take US -74 west to Charlotte, NC.
Take US 74 -NC 27 (East Independence Blvd) in the City of Charlotte. Take NC 27 and
get onto McDowell Street. Turn left on McDowell Street and proceed three city blocks then
turn onto East Trade Street. The Criminal Courts Building is located adjacent to the
Government Center. NOTE: East Fourth Street is a one way street going east to west.
East Third Street is a one way street going west to east.
FROM RALEIGH, NC:
Take 1-85 into Charlotte and exit onto NC 16 (Brookshire Freeway). NC 16 will become 1-
277. Take 1-277 to S. Graham Street and then go onto East Trade Street. The Criminal
Courts Building is located adjacent to the Government Center. NOTE: East Fourth
Street is a one way street going east to west. East Third Street is a one way street going west
to east.
(See Attached Maps)
Public Hearing-Variance Request
August 12, 1999
Variance to 15A NCAC 2L .0202 and 15A NCAC 2L .0106U)
711 Pressley Road, Charlotte, North Carolina (Groundwater Incident Number 8949)
HEARING LOCATED AT:
Mecklenburg County Courthouse
Criminal Courts Building -2nd Floor, Courtroom 2203
700 East Fourth Street -(at 7:00 PM)
HEARING OFFICER'S SPEECH
HEARING OFFICER: Art Barnhardt, Division of Water Quality, Regional Groundwater Supervisor
(Fayetteville Regional Office)
HEARJNG OFFICER : GOOD EVENING, I WOULD LIKE TO CALL THIS PUBLIC
HEARING TO ORDER. MY NAME IS ART BARNHARDT, AND I AM THE
DIVISION OF WATER QUALITY REGIONAL GROUNDWATER SUPERVISOR IN
THE FAYETTEVILLE REGIONAL OFFICE. I HAVE BEEN DESIGNATED HEARING
OFFICER FOR THIS EVENING'S HEARING.
THIS HEARING IS BEING HELD PURSUANT TO NORTH CAROLINA GENERAL
STATUTE lS0B-21.2. IN ACCORDANCE WITH THE GENERAL STATUTES, A
PUBLIC NOTICE OF THIS HEARING WAS PUBLISHED IN CONFORMITY WITH
15A NCAC 2L .0113 OF THE GROUNDWATER RULES AND GENERAL NOTICE
HAS BEEN GIVEN IN THE LOCAL PAPER ACCORDING TO PROCEDURES IN 15A
1
NCAC 2L .0113 (e) (1). NOTICES WERE ALSO DISTRIBUTED TO THE PUBLIC AT
LARGE, LOCAL GOVERNMENT OFFICIALS AND PROPERTY HOLDERS WITHIN
AND NEAR THE AREA OF THE PROPOSED VARIANCE. THE PUBLIC NOTICE
STATED THAT A MORE DETAILED SUMMARY OF THIS VARIANCE COULD BE
OBTAINED FROM STAFF AND COPIES OF THIS SUMMARY ARE BEING MADE
AVAILABLE TO PERSONS ATTENDING THIS HEARING TONIGHT.
THE PURPOSE OF THIS HEARING IS TO OBTAIN PUBLIC COMMENT AND
PARTICIPATION IN THE CONSIDERATION OF THE VARIANCE REQUEST FOR
CAROLINA COATING INCORPORATED OF CHARLOTTE, NORTH CAROLINA.
MR. LINWOOD CARTER, THE PROPIERTOR OF CAROLINA COATINGS
INCORPORATED, IS REQUESTING THIS VARIANCE FROM RULES CONTAINED
IN 15A NCAC 2L GROUNDWATER CLASSIFICATION AND STANDARDS FOR
THE PROPERTY LOCATED AT 711 PRESSLEY ROAD. THIS PROPERTY,
PREVIOUSLY OWNED BY MR. CARTER, IS NOW OWNED BY WATTYL PAINTS
OF ATLANTA, GEORGIA. MR. CARTERONCEOPERATEDASOLVENT,BASED
PAINT MIXING FACILITY AT 711 PRESSLEY ROAD. IN 1991, HE SOLD THIS
FACILITY TO WATTYL PAINTS. SINCE THAT TIME, ALL SCLVENT BASED
PAINT MIXING PROCESSES HAVE BEEN MOVE OUT OF NORTH CAROLINA.
THE VARIAN CE REQUEST SHOWS THAT ONLY WATER, BASED PAINT MIXING
2
IS BEING CONDUCTED AT 711 PRESSLEY ROAD BY THE WA TrYL PAINT
COMPANY.
THIS PROPOSED VARIANCE FOR CAROLINA COATINGS INCORPORATED
WILL APPLY ONLY TO AN AREA CONSISTING OF THIS PROPERTY AT 711
PR];'.SSLEY ROAD (PARCEL NUMBER 145-291-03). CAROLINA COATINGS
INCORPORATED ESTIMATES THE TOTAL AREA OF LAND FOR WHICH THIS
VARIANCE IS REQUESTED IS APPROXIMATELY 6.1 7 ACRES. IN THE
SUPPORTING INFORMATION SUBMITTED IN THIS VARIANCE
REQUESTCAROLINA COATINGS INCORPORATED INFORMED THE DIVISION
THAT THIS SITE IS LOCATED WITHIN AN AREA CONTAINING A MIXTURE OF
COMMERCIAL, INDUSTRIAL AND RESIDENTIAL PROPERTIES.
THE APPLICANT PROPOSES TO ALLOW THE CONCENTRATION OF BENZENE
TO REMAIN AT A LEVEL ABOVE 15A NCAC 2L .0202 STANDARD AS
ANALYZED ON OCTOBER 9, 1997. THIS CONCENTRATION WILL BE REQUIRED
TO REMAIN WITHIN THE PROPERTY BOUNDARIES OF 711 PRESSLEY ROAD.
CAROLINA COATINGS INCORPORATED ALSO PROPOSES THAT CORRECTIVE
ACTIONS REQUIRING THE APPLICATION OF BEST AVAILABLE TECHNOLOGY
IN 15A NCAC 2L .0106 (j) NOT BE APPLIED TO THE AREA WITHIN THE
3
BOUNDARIES OF THE PROPOSED VARIANCE. CAROLINA COATINGS
INCORPORATED HAS REPORTED THAT A TOTAL OF $ 493,000 HAS BEEN
EXPENDED TO CLEANUP THIS SITE .. CAROLINA COATINGS INCORPORATED
HAS SUBMITTED SUPPORTING INFORMATION DEMONSTRATING THAT THE
CONTINUED APPLICATION OF BEST AVAILABLE TECHNOLOGY WILL NOT
RESULT IN SIGNIFICANT LONG TERM REMEDIATION OF THE SITE TO THE
GROUNDWATER QUALITY STANDARDS IN 15A NCAC 2L .0202. THE
COMPANY BELIEVES THAT APPLICATION OF BEST AVAILABLE TECHNOLOGY
AT THIS LOCATION IS A SERIOUS FINANCIAL IMPACT WITHOUT EQUAL OR
GREATER PUBLIC BENEFIT.
THIS HEARING WILL CONFORM TO PROCEDURES IN 15A NCAC 2L .0113.
ADDITIONAL COPIES OF THE NOTICE OF VARIANCE APPLICATION AND
HEARING ARE LOCATED IN THIS BUILDING AND ARE AVAILABLE FOR PUBLIC
REVIEW .
A WRITTEN RECORD OF THIS HEARING WILL BE PREPARED WHICH WILL
INCLUDE ALL THE RELEVANT COMMENTS, QUESTIONS, AND DISCUSSIONS.
FOR THIS REASON, THE HEARING IS BEING TAPE RECORDED. WRITTEN
COMMENTS RECEIVED THROUGH SEPTEMBER 13, 1999 WILL ALSO BE
4
INCLUDED IN THE RECORD. BASED ON THESE PUBLIC COMMENTS AND ON
ANALYSIS BY THE GROUNDWATER STAFF, I WILL MAKE A
RECOMMENDATION TO THE ENVIRONMENTAL MANAGEMENT COMMISSION.
IN MAKING THE FINAL DECISION, THE ENVIRONMENT AL MANAGEMENT
COMMISSION CONSIDERS THE WRITTEN RECORD, THE RECOMMENDATION
OF THE HEARING OFFICER, THE RECOMMENDATIONS OF DIVISION STAFF,
AND THE CONCERNS OF ITS MEMBERS. THE COMMISSION MUST ALSO
CONSIDER WHETHER THE APPLICANT HAS COMPLIED WITH 15A NCAC 2L
.0113(g).
IF THE APPLICANT DECIDES THAT THE COMMISSION'S DECISION IS
UNACCEPTABLE, A PETITION MAY BE FILED ACCORDING TO PROCEDURES IN
15A NCAC 2L .0113(h). THE DECISION ON THE VARIANCE BY THE
ENVIRONMENTAL MANAGEMENT COMMISSION IS FINAL AND BINDING
ACCORDING TO THE CONDITIONS SHOWN IN ISA NCAC 2L .Ol 13(h).
AT THIS TIME I WOULD LIKE TO RECOGNIZE (names of local and state officials)
AND THANK YOU FOR ATTENDING THIS HEARING. I WOULD ALSO LIKE TO
RECOGNIZE THE FOLLOWING PEOPLE FROM THE DIVISION OF WATER
QUALITY (DWQ central office and DWQ regional office personnel).
5
MR. MATT HELLER (staff speaker,) OF THE DIVISION OF WATER QUALITY-
GROUNDW ATER SECTION MOORESVILLE REGIONAL OFFICE WILL NOW
SUMMARIZE THE PROPOSED VARIANCE WHICH IS THE SUBJECT OF THIS
HEARING.
STAFF SPEAKER: (staff speaker summarizes variance request).
HEARING OFFICER: THANK YOU. WE WILL NOW ACCEPT PUBLIC
COMMENT ON THE PROPOSED VARIANCE. I WOULD LIKE TO REQUEST THAT
EVERYONE FILL OUT A REGISTRATION FORM. AFTER ALL REGISTERED
SPEAKERS HAVE HAD AN OPPORTUNITY TO COMMENT, I WILL ALLOW
ADDITIONAL SPEAKERS AS TIME PERMITS. WHEN YOUR NAME IS CALLED,
PLEASE COME UP TO THE MICROPHONE AND ST ATE YOUR NAME AND
AFFILIATION. ALL COMMENTS SHOULD BE LIMITED TO MA TIERS THAT ARE
RELATIVE TO THE PROPOSED ADOPTION OF THIS VARIANCE. IF YOUR
COMMENTS ARE LONGER THAN THREE MINUTES, I WOULD LIKE TO REQUEST
THAT THEY BE SUBMITTED IN WRITING. I RESERVE THE RIGHT TO QUESTION
SPEAKERS IF THE NEED SHOULD ARISE.
DIVISION OF WATER QUALITY STAFF WILL BE AVAILABLE TO ANSWER YOUR
QUESTIONS IF NECESSARY. I WOULD NOW LIKE TO CALL [first speaker].
6
[speakers ... ]
(the hearing officer, referring to THE REGISTRATION CARDS, calls each speaker to the microphone
in turn)
HEARING OFFICER: THANK YOU [last speaker]. ARE THERE ANY MORE
COMMENTS? SINCE THERE ARE NO MORE COMMENTS, I DECLARE THE
HEARING CLOSED. THE HEARING RECORD WILL REMAIN OPEN UNTIL
12:00 PM (MIDNIGHT) ON SEJ!TEMER 13, 1999. ANYONE WISHING TO SUBMIT
WRITTEN COMMENTS MAY DO SO UNTIL THAT DATE. AFTER WHICH TIME,
THE COMMENTS WILL BE MADE PART OF THE PUBLIC RECORD AND I SHALL
MAKE RECOMMENDATIONS TO THE ENVIRONMENT AL MANAGEMENT
COMMISSION. WRITTEN COMMENTS MUST BE ADDRESSED TO DAVID HANCE
AT THE DIVISION OF WATER QUALITY GROUNDWATER SECTION. THE
ADDRESS WRITTEN COMMENTS NEED TO BE SENT TO IS SHOWN IN THE
PUBLIC NOTICE AND IS AS FOLLOWS:
David Hance
DENR,DWQ,Groundwater Section
P.O. Box 29578
Raleigh, NC 27626,0578
A FACSIMILE COPY OF WRITTEN COMMENTS MAY BE SENT TO MR.
HANCE BY DIALING (919) 715,0588. HIS TELEPHONE NUMBER IN RALEIGH IS
(919) 715,6189. COMMENTS MAY ALSO BE SENT TO MR. HANCE VIA £,MAIL BY
7
CONT ACTING HIS INTERNET MAILING ADDRESS SHOWN IN THE PUBLIC
NOTICE. MR. HANCE'S BUSINESS CARDS SHOWS THIS INFORMATION AND
ARE LOCATED AT PLACE YOU REGISTERED FOR THIS HEARING.
IT IS THE DESIRE OF THE COMMISSION TO ALWAYS ACT IN THE BEST
POSSIBLE INTEREST OF THE PUBLIC. THEREFORE, PUBLIC PARTICIPATION IS
A VERY IMPORTANT PART OF THE RULE-MAKINO PROCESS. I WOULD LIKE
TO THANK YOU FOR A TIEN DINO THE HEARING AND OFFERING YOUR
COMMENTS.
8
Directions to Variance Hearing for the Carolina
Coatings Variance (Site located at 711 Pressley Road in
Charlotte, NC)
HEARING LOCATED AT:
Mecklenburg County Courthouse Criminal Courts Building -2nd Floor, Courtroom 2203
700 East Fourth Street, Charlotte, NC (Thursday, August 12, 1999 at 7:00 PM)
MOORESVILLE REGIONAL OFFICE STAFF PRESENTER:
Matt Heller [phone]; fax -[phone]
RALEIGH GROUNDWATER SECTION STAFF RECORDER:
David Hance [phone]; fax -[phone]
HEARING OFFICER: Art Barnhardt [phone]; fax· [phone]
CONTACTS AT THE COURT HOUSE -
CAPT. DEATON -[phone]
MAIN NUMBER FOR SHERIFF' S OFFICE -[phone]
SECURITY POST AT THE CRIMINAL COURTS BUILDING-[phone]
FROM FAYETTEVILLE NC:
Take US 401 to Laurinburg, North Carolina and then take US -74 west to Charlotte, NC.
Take US 74 -NC 27 (East Independence Blvd) in the City of Charlotte. Take NC 27 and
get onto McDowell Street. Turn left on McDowell Street and proceed three city blocks then
turn onto East Trade Street. The Criminal Courts Building is located adjacent to the
Government Center. NOTE: East Fourth Street is a one way street going east to west.
East Third Street is a one way street going west to east.
FROM RALEIGH. NC:
Take I-85 into Charlotte and exit onto NC 16 (Brookshire Freeway). NC 16 will become 1-
277. Take 1-277 to S. Graham Street and then go onto East Trade Street. The Criminal
Courts Building is located adjacent to the Government Center. NOTE: East Fourth
Street is a one way street going east to west. East Third Street is a one way street going west
to east.
(See Attached Maps)
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
July 7, 1999
DIVISION OF WATER QUALITY
Property at 65 5 Pressley Road
(Ta,': Id Numberl45,.291-01)
The Department of Environment, Health and Natural Resources has received a
_.,.,.. request for a variance from the Groundwater Quality Standards of 1 SA NCAC 2L
•• ·'.' ··.u ~ .• 0202 and Corrective Action requirements of 15A NCAC 2L .0106(j). 15A NCAC 2L .. : t ~ ~ .0113(e)(l)(E) requires adequate notice be given to area properties and adjacent
property owners prior to hearing.
You will find enclosed a Public Notice regarding the variance hearing. Please refer
to the enclosure for additional information. If you have any questions concerning this
variance request, please contact David Hance at [phone].
. Enclosure
Sincerely,
M. Carl Bailey, Jr.
Assistant Chief for Planning
Groundwater Section
GROUNDWATER SIIC:TION
P.O. Box 29578, RALEIGH, NORTH CAROLINA 27626-0578 -2728 CAPITAL, BLVD., RALEIGH, NC 27604
PHONE [phone]I FAX 9l9-715-0588
AN EQUAL OPPORTUNITY/ AFFIRMATIVE ACTION EMPLOYER• ISOo/o RECYCLED/!Oo/o POST-CONSUMER PAPER
Author: "Art Barnhardt GW" <Art [e-mail]> at Internet
~te: 7/16/1999 12:19 PM
~iority: Normal
TO: David Hance at NRGWS0lP
Subject: RE: CAROLINA COATINGS VARIANCE
------------------------------------Message Contents------------------------------------
David:
I have read over the speech. I don't have any changes to make .
Thanks for doing all the preparatory leg work for me .
ArtB.
Author: David Hance at NRGWS0lP
Date: 7/16/1999 12:03 PM
Priority: Urgent
Receipt Requested
TO: Art [e-mail] at Internet
TO: Matt [e-mail] .nc.us at Internet
CC: Carl Bailey
CC: David Hance
CC: Barbara [e-mail] .STATE.NC.US at Internet
Subject: RE: CAROLINA COATINGS VARIANCE
------------------------------------Message Contents------------------------------------
* IMPORTANT** DRAFT HEARING OFFICER'S SPEECH* CAROLINA COATINGS VAR*
HELLO ART AND MATT;
ART ....... I HAVE JUST FAXED YOU ART-A DRAFT HEARING OFFICERS
SPEECH FOR THE CAROLINA COATINGS VARIANCE HEARING THAT WILL BE HELD ON
AUGUST 12TH AT THE MECKLENBURG COUNTY COURTHOUSE. PLEASE REVIEW AND
GET CHANGES TO ME. IF YOU HAVE QUESTIONS --PLEASE CALL ME AT
919-715-6189. IF POSSIBLE, I WOULD LIKE YOUR CHANGES BY FRIDAY, JULY
23, 1999 SO WE CAN FINALIZE THE SPEECH AND GET IT OUT TO YOU .
MATT-------THIS WAS SENT TO YOU TO ENABLE COORDINATION BETWEEN THE
TWO OF YOU AT THE HEARING OFFICER. AS IT SHOWS, ART WILL MAKE THE
HEARING OFFICERS PRESENTATION PORTIONS AND WILL HAND OFF THE TECHNICAL
DISCUSSION TO YOU. HE WILL THEN PICK IT BACK UP AND ASK FOR COMiVIENTS .
DAVID HANCE
IS BEING CONDUCTED AT 711 PRESSLEY ROAD BY THE WATTYL PAINT
COMPANY.
THIS PROPOSED VARIAN CE FOR CAROLINA COATINGS IN CORPORA TED
WILL APPLY ONLY TO AN AREA CONSISTING OF THIS PROPERTY AT 711
PRESSLEY ROAD (PARCEL NUMBER 145-291-03). CAROLINA COATINGS
INCORPORATED ESTIMATES THE TOTAL AREA OF LAND FOR WHICH THIS
VARIANCE IS REQUESTED IS APPROXIMATELY 6.17 ACRES.
SUPPORTING INFORMATION SUBMITTED IN THIS
IN THE
VARIANCE
REQUESTCAROLINA COATINGS INCORPORATED INFORMED THE DIVISION
THAT THIS SITE IS LOCATED WITHIN AN AREA CONTAINING A MIXTURE OF
COMMERCIAL, INDUSTRIAL AND RESIDENTIAL PROPERTIES.
THE APPLICANT PROPOSES TO ALLOW THE CONCENTRATION OF BENZENE
TO REMAIN AT A LEVEL ABOVE 15A NCAC 2L .0202 STANDARD AS
ANALYZED ON OCTOBER 9, 1997. THIS CONCENTRATION WILL BE REQUIRED
TO REMAIN WITHIN THE PROPERTY BOUNDARIES OF 711 PRESSLEY ROAD.
CAROLINA COATINGS INCORPORATED ALSO PROPOSES THAT CORRECTIVE
ACTIONS REQUIRING THE APPLICATION OF BEST AVAILABLE TECHNOLOGY
IN 15A NCAC 2L .0106 (j) NOT BE APPLIED TO THE AREA WITHIN THE
3
BOUNDARIES OF THE PROPOSED VARIANCE. CAROLINA COATINGS
INCORPORATED HAS REPORTED THAT A TOTAL OF$ 493,000 HAS BEEN
EXPENDED TO CLEANUP THIS SITE .. CAROLINA COATINGS IN CORPORA TED
HAS SUBMITTED SUPPORTING INFORMATION DEMONSTRATING THAT THE
CONTINUED APPLICATION OF BEST AVAILABLE TECHNOLOGY WILL NOT
RESULT IN SIGNIFICANT LONG TERM REMEDIATION OF THE SITE TO THE
GROUNDWATER QUALITY STANDARDS IN ISA NCAC 2L .0202. THE
COMP ANY BELIEVES THAT APPLICATION OF BEST AVAILABLE TECHNOLOGY
AT THIS LOCATION IS A SERIOUS FINANCIAL IMPACT WITHOUT EQUAL OR
GREATER PUBLIC BENEFIT.
THIS HEARING WILL CONFORM TO PROCEDURES IN ISA NCAC 2L .0113.
ADDITIONAL COPIES OF THE NOTICE OF VARIANCE APPLICATION AND
HEARING ARE LOCATED IN THIS BUILDING AND ARE AVAILABLE FOR PUBLIC
REVIEW.
A WRITTEN RECORD OF THIS HEARING WILL BE PREPARED WHICH WILL
INCLUDE ALL THE RELEVANT COMMENTS, QUESTIONS, AND DISCUSSIONS.
FOR THIS REASON, THE HEARING IS BEING TAPE RECORDED. WRITTEN
COMMENTS RECEIVED THROUGH SEPTEMBER 13, 1999 WILL ALSO BE
4
INCLUDED IN THE RECORD. BASED ON THESE PUBLIC COMMENTS AND ON
ANALYSIS BY THE GROUNDWATER STAFF, I WILL MAKE A
RECOMMENDATION TO THE ENVIRONMENTAL MANAGEMENT COMMISSION.
IN MAKING THE FINAL DECISION, THE ENVIRONMENTAL MANAGEMENT
COMMISSION CONSIDERS THE WRITTEN RECORD, THE RECOMMENDATION
OF THE HEARING OFFICER, THE RECOMMENDATIONS OF DIVISION STAFF,
AND THE CONCERNS OF ITS MEMBERS. THE COMMISSION MUST ALSO
CONSIDER WHETHER THE APPLICANT HAS COMPLIED WITH 15A NCAC 2L
.0113 (g).
IF THE APPLICANT DECIDES THAT THE COMMISSION'S DECISION IS
UNACCEPTABLE, A PETITION MAY BE FILED ACCORDING TO PROCEDURES IN
15A NCAC 2L .0113(h). THE DECISION ON THE VARIANCE BY THE
ENVIRONMENTAL MANAGEMENT COMMISSION IS FINAL AND BINDING
ACCORDING TO THE CONDITIONS SHOWN IN 15A NCAC 2 L .0113 (h).
AT THIS TIME I WOULD LIKE TO RECOGNIZE (names of local and state officials)
AND THANK YOU FOR ATTENDING THIS HEARING. I WOULD ALSO LIKE TO
RECOGNIZE THE FOLLOWING PEOPLE FROM THE DIVISION OF WATER
QUALITY (DWQ central office and DWQ regional office personnel).
5
DRAFT
[speakers ... ]
(the hearing officer, referring to THE REGISTRATION CARDS, calls each speaker to the microphone
in turn)
HEARING OFFICER: THANK YOU [last speaker]. ARE THERE ANY MORE
COMMENTS? SINCE THERE ARE NO MORE COMMENTS, I DECLARE THE
HEARING CLOSED. THE HEARING RECORD WILL REMAIN OPEN UNTIL
12:00 PM (MIDNIGHT) ON SEPTEMER 13, 1999. ANYONE WISHING TO SUBMIT
WRITTEN COMMENTS MAY DO SO UNTIL THAT DA TE. AFTER WHICH TIME,
THE COMMENTS WILL BE MADE PART OF THE PUBLIC RECORD AND I SHALL
MAKE RECOMMENDATIONS TO THE ENVIRONMENTAL MANAGEMENT
COMMISSION. WRITTEN COMMENTS MUST BE ADDRESSED TO DAVID HANCE
AT THE DIVISION OF WATER QUALITY GROUNDWATER SECTION. THE
ADDRESS WRITTEN COMMENTS NEED TO BE SENT TO IS SHOWN IN THE
PUBLIC NOTICE AND IS AS FOLLOWS:
David Hance
DENR-DWQ,Groundwater Section
P.O. Box 29578
Raleigh, NC 27626,0578
A FACSIMILE COPY OF WRITTEN COMMENTS MAY BE SENT TO MR.
HANCE BY DIALING [phone]. HIS TELEPHONE NUMBER IN RALEIGH IS
(919) 715,6189. COMMENTS MAY ALSO BE SENT TO MR HANCE VIAE,MAILBY
7
"~ CONTACTING HIS INTERNET MAILING ADDRESS SHOWN IN THE PUBLIC ~
NOTICE. MR. HANCE'S BUSINESS CARDS SHOWS THIS INFORMATION AND
ARE LOCATED AT PLACE YOU REGISTERED FOR THIS HEARING.
IT IS THE DESIRE OF THE COMMISSION TO ALWAYS ACT IN THE BEST
POSSIBLE INTEREST OF THE PUBLIC. THEREFORE, PUBLIC PARTICIPATION IS
A VERY IMPORTANT PART OF THE RULE-MAKING PROCESS. I WOULD LIKE
TO THANK YOU FOR ATTENDING THE HEARING AND OFFERING YOUR
COMMENTS.
8
Author: David Hance at NRGWS0lP
Date: 7/15/1999 4:01 PM
)Priority: Urgent
Receipt Requested
TO: Art [e-mail] .US at Internet
TO: Matt [e-mail] at Internet
CC: Barbara [e-mail] at Internet
CC: Arthur Mouberry
CC: Carl Bailey
CC: David Hance
Subject: re: update on Carolina Coatings Variance request
------------------------------------Message Contents------------------------------------
Dear Art and Matt:
I am sending a copy of the summary that the director reviewed prior
to giving us approval to proceed with public hearing on the variance
for Carolina Coatings. Directions and maps are also included in the
packet that will go "interoffice mail" on Friday, July 16, 1999.
As an update ... we have sent notices to the newspaper, adjacent
property owners, local officials, and 130 people on the GW Rules
Mailing list that live and work in the Charlotte area informing them
that this hearing will be held on August 12, 1999 at the Courthouse.
Art ... My next step is to get a draft hearing officers speech for
you to review and make changes. I will get into this in the near
future.
David Hance (919.715.6189)
I • ..
Included with this memorandum is an information packet which contains a
summary of the variance and directions to the hearing location. You will need to
discuss the development of your hearing officer's speech with David Hance. Mr.
Hance may be contacted at 919-715-6189. Please be advised staff have not made
arrarnzements for your overni ght stay .
The written comment period for this variance will close at 12:00 P.M.
(midnight) on September 13, 1999. Pursuant ·to established Division policy, I am
requiring you to complete the hearing officer's report and the recommendation to
the Environmental Management Commission Groundwater Committee no later
than December 13, 1999. This period of time is ninety (90) days after the closing date
for written public comment and allows Division staff adequate time to review your
recommendation. Unless significant new site information becomes available after the
public hearing or other extraordinary circumstances occur that dictate a longer review
period by the hearing officer, the earliest date that this variance may be considered by
the Groundwater Committee is October 14, 1999. If your review of the variance
shows that there is a need for a longer evaluation period, please contact Arthur
Mouberry at [phone].
I appreciate your taking the time to conduct this hearing. The staff will be glad
to assist you through the proceedings. If you have any questions, feel free to call Carl
Bailey at [phone] or David Hance.
Attachments .
cc: Arthur Mouberry
Carl Bailey
David Hance
2
t
I
'
DIVISION OF WATER QUALITY
GROUNDWATER SECTION
June 24, 1999
MEMORANDUM
To: Kerr T. Stevens
From: Arthur Mouberry #
Subject: Request for Variance from 15A NCAC 2L .0202 and 15A
NCAC 2L .0106G) for a Site Owned by the Carolina Coatings Incorporated at 711
Pressley Road in Charlotte, North Carolina (Groundwater Incident Number
8949).
From 1971 through 1991, Mr. Linwood Carter operated a portion of the Carolina
Coatings Incorporated property as a paint blending facility located at 711 Pressley Road in
Charlotte, North Carolina. This site is at the intersection of Billy Graham Parkway and US
Interstate 77. In 1991, Mr. Carter sold this facility to Wattyl Paints of Atlanta, Georgia. The
new owner of this facility moved all solvent based mixing processes out of North Carolina 1991.
Mr. Carter maintains cleanup responsibilities for substances found at this site.
The Carolina Coatings facility consists of a total of 47,000 square feet of warehouse and
office space on 6.17 acres ofland. During the period this property was owned by Mr. Carter,
Carolina Coatings manufactured paint using a batch mixing process which blended latex
emulsions with dry pigments, wetting agents, water, defoamers and other ingredients. This
process required the storage of empty fifty-five gallon drums on a concrete pad located rear of
the building. Waste water settling tanks were also located in this area. During the course of
business operations leaks had occurred in drums located at this site and from the wastewater
settling ponds.
Pursuant to the transfer of ownership of this property in 1991, Mr. Carter had
environmental assessments conducted of soils and groundwater at this site. Ethylbenzene,
Toluene and Xylene were found in soils around this site. Analysis of groundwater samples
showed the presence of several volatile organic compounds, Benzene, Ethylbenzene, Toluene
and Xylene. Since 1991 only latex water-based, products have been processed at 711 Pressley
Road by Wattyl Paints. The owner of Carolina Coatings Incorporated, Mr. Linwood Carter, is
entirely responsible for cleanup of this release which is shown in Division of Environmental
Management files as Groundwater Incident Number 8949.
1
Pursuant to title 15A NCAC 2L .0113(c) variance applications are required to have
specific information in order to adequately review a request. The Carolina Coatings variance
request is contained in a report titled "Variance Request -Carolina Coatings Site -Charlotte ,
North Carolina. December 9. 1996, Dames and Moore N.C. Job No.23995-002-200.". In
addition, memoranda and other correspondence are included with this request. The information
submitted by Dames and Moore on behalf of the Carolina Coating Incorporated appears to meet
the requirements of 15A NCAC 2L .0l 13(c) and is summarized as follows:
Rule .0113 (c)(l): Resolution b y the County or governing Board:
Carolina Coatings Incorporated has always been a privately owned
company. No resolution is necessary.
Rule .0113 (c)(2): A descri ption of past existin g or pro posed activities that would result in a
dischare:e of contaminants into gr oundwater:
The former Carolina Coatings Incorporated is located inside the city limits of
Charlotte, North Carolina at 711 Pressley Road (Mecklenburg County Tax
Identification Number 145-291-03). The report titled "Variance Re q uest -Carolina
Coatin ~s Site -Charlotte, North Carolina. December 9, 1996, Dames and Moore
N.C. Job No.23995-002-200" contains the relevant information about this site. The
site consists of approximately 6.17 acres of land.
A Notice of Violation was issued to Carolina Coatings Incorporated by the
Department on August 28, 1992. Remedial Action Plans were submitted to the
Mooresville Regional Office on June 29, 1992 and March 23, 1993. On J?nuary 18,
1994, a discharge permit for an on-site infiltration gallery was authorized by the
Division of Water Quality (WQ0007993). Details of soil and groundwater corrective
actions are documented in a report titled "Soil and Groundwater Remediation
Report (April 19, 1994)" at the Mooresville Regional Office. All potential sources
of groundwater contamination were identified at this property by the company.
This property at 711 Pressley Road in Charlotte, North Carolina, formerly owned
by Mr. Linwood Carter, and is in an area with a mixture of commercial, industrial,
and residential development.
The comprehensive site assessment and other investigations revealed
Benzene, Toluene, Ethylbenzene, and Xylene (o, m, and p) (BETX) in the
groundwater and soil beneath the site. This area was located at the southwest
corner of the building near an 88 foot by 66 foot concrete pad and three small
wastewater settling tanks. This was where the company stored chemicals and
performed batched mixing operations for solvent-based paints. This area is
2
' '
approximately 10 feet from the northwest property line and 75 feet from the
southwest property line. The entire property at 711 Pressley Road is surrounded
by a fence. This plume was estimated to have covered an area of approximately
10,000 square feet (0.23 acers) prior to the implementation of correctiv~ actions by
the Carolina Coatings Incorporated. According to information at the Mooresville
Regional Office the vertical extent of this plume is believed to be less than 48 feet
below the ground surface.
Carolina Coatings Incorporated implemented cleanup of soils at this site in
September 1992 with the removal of 900 cubic yards of soil that exceeded the 50
milligram per kilogram target cleanup level. Between June 2, 1993 and June 25,
1993, the company removed an additional 1,500 cubic yards of contaminated soils.
Excavated soils were treated offsite and clean fill material was used as backfill. As a
result of soil remediation, the concrete pad was removed and subsequently replaced.
In July 1993 the company installed a pump-and-treat system with a single
groundwater recovery well (RW-1) located near the south corner of the former
concrete storage pad as shown in Figure 6 of the variance. From March 23, 1994
through January 1997 a total of 328,500 gallons of groundwater has been treated via
pump-and-treat technology. The treated discharge was sent to an upgraident
infiltration gallery. An infiltration gallery is a closed-loop conveyance that allows
water and other fluids, discharged through the pump-and-treat system, to be sent
back into the subsurface where they recirculated into the cleanup system for
continual treatment. An infiltration gallery may also serve to enhance intrinsic
biodegradation of contaminants by introducing dissolved oxygen in the subsurface
which may stim11late biologic decomposition of some dissolved substances. Non-
Discharge Permit WQ0007993 was issued on January 18, 1994 for the infiltration
gallery. The Groundwater Section staff have recommended that, if the variance
request is granted, no permit for this infiltration gallery is to be reissued. The
company's environmental consultant, Dames and Moore, reports that this device
will no longer be used once the variance is granted.
The Division of Water Quality required Carolina Coatings Incorporated to
perform groundwater monitoring to determine the vertical and lateral extent of
contamination at the site. Table 2 of the report titled "Variance Re quest-Carolina
co-atin ~s Site -Charlotte, North Carolina, December 9. 1996, Dames and Moore
N.C. Job No.23995-002-200" shows that three of six monitoring wells were sampled
from March 1994 through September 1996 on a quarterly schedule. Groundwater
samples were analyzed using US Environmental Protection Method 8020. Page 6 of
the variance request shows that only Monitoring Well# 9 has had concentrations of
Benzene, Ethylbenzene, and Xylene above the Groundwater Quality Standards in
15A NCAC 2L .0202. Toluene has never appeared in any of the monitoring wells at
a concentration in excess of the Groundwater Quality Standard in 15A NCAC 2L
.0202. Table 2 of the report titled "Variance Re q uest -Carolina Coatine s Site -
Charlotte, North Carolina, December 9, 1996. Dames and Moore N.C. Job
No.23995-002-200" shows that the highest concentration of Benzene, Ethylbenzene,
and Xylene have been found in this well. The highest concentration of Benzene in
exceedence of the Groundwater Quality Standard was 0.027 milligrams per liter or
3
j • I
27 micrograms on September 3, 1996. The highest concentration of any substance
in exceedence of the 15A NCAC 2L .0202 Groundwater Quality Standard found at
th_is site was Xylene (o,p,m). Xylene appeared at the December 1994 monitoring
event at 0.860 milligrams per Liter or 860 micrograms/Liter.
As shown on Table 1 of the report titled "Variance Request-Carolina
Coatings Site -Charlotte, North Carolina, December 9, 1996, Dames and Moore
N.C. Job No.23995-002-200"from March 29, 1994 through October 30, 1996, the
company conducted analysis of samples from Recovery Well# 1 on the influent side
of the cleanup system to determine the effectiveness of the pump-and-treat cleanup.
This data shows that the source of the groundwater contamination at this site has
been significantly reduced such that the plume can no longer be detected.
Based on the results of !he groundwater monitoring and recovery well
monitoring in September and October 1996, the Carolina Coatings req_µested a
variance and that the pump and treat groundwater cleanup system be shut off. In
January 1997 the Mooresville Regional Office agreed that active cleanup should be
discontinued. Based on the results of groundwater monitoring and monitoring of
influent samples in the recovery well from the pump and treat cleanup system the
cleanup system was turned off. This variance request encompasses the entire
property at 711 Pressley Road in Charlotte, North Carolina.
Potential sources of groundwater contamination in the area are discussed in
Pages 9 through 11 and in Appendix A of the report titled "Variance Request-
Carolina Coatings Site -Charlotte. North Carolina. December 9, 1996, Dames and
Moore N.C. Job No.23995-002-200.". Appendix A shows Vista Site Assessment
Reports of these properties with maps. Potential sources of groundwater
contamination are summarized as follows:
1) The property at 711 Pressley Road formerly owned by Carolina
Coatings Incorporated (Mecklenburg County Tax Identification
Number 145-291-03). This site is now owned by ~attyl Paints. The
Vista Site Assessment Report lists this site on the state "CERCLIS"
and as a "Large Quantity Generator" of hazardous wastes.
2) The property at 807 Pressley Road known as The Gifford-Hill
Company located 1/10 of a mile northwest of the site. This property is
upgradient from the site and is listed with the Division of Waste
Management-Underground Storage Tank Section as having reported
a leaking petroleum underground storage tank on June 1, 1989.
3) Property at 927 Pressley Road known as Climate Conditioning of
Charlotte located 0.2 miles northwest of the site. This property is
upgradient from the site and is listed with the Division of Waste
Management-Underground Storage Tank Section as having reported
a leaking petroleum underground storage tank on December 27, 1994.
In addition, Page # 11 of the "Vista Site Assessment Report" shows
4
that at one time this company removed three underground storage
tanks that contained gasoline.
4) Observer Transport Company located 0.3 miles northwest of the site
at 1001 Pressley Road. This property is upgradient from the site and
is listed with the Division of Waste Management-Underground
Storage Tank Section as having reported three gasoline leaks on April
12, 1988, April 17, 1992, and April 15, 1994. Page# 12 of the "Vista
Site Assessment Report" shows that two of these tanks contained
"Gasoline" and "Diesel Fuel". The third tank contained a product
described as "Petroleum Other".
5) Xerox Corporation located 0.35 miles northwest of the site at 4740
Dwight Evans Road. This property is upgradient from the site and is
listed with the Division of Waste Management-Underground Storage
Tank Section as having reported a leaking petroleum underground
storage tank on September 30, 1986. Page # 12 of the "Vista Site
Assessment Report" shows that this tank contained "Gasoline" and
"Diesel Fuel".
6) White Machines which is located 0.53 miles north of the site at 4300
Barringer Drive. This property is cross-gradient from the site and is
listed with the Division of Waste Management-Undergro!!nd Storage
Tank Section as having reported a leaking petroleum underground
storage tank on March 21, 1990. Page# 13 of the "Vista Site
Assessment Report" shows that this tank contained "Gasoline" and
"Diesel Fuel".
7) Piedmont Natural Gas which is located 0.4 miles east of the site at
Verbena & Yancey Streets. This property is downgradient from the
site and is listed in the variance request as having reported a leaking
petroleum underground storage tank on January 15, 1990. Page# 13
of the "Vista Site Assessment Report" shows that this tank contained
"Gasoline" and "Diesel Fuel".
8) Industrial Truck Sales which is located approximately 0.1 miles east
of the site at 3910 Stuart Boulevard. This property is downgradient
from the site and is listed in the variance request as a "RCRA small
quantity generator". Page# 9 and# 10 of the "Vista Site Assessment
Report" shows that underground storage tanks have also been at this
property. Three tanks have been removed consisting of one 8,000
gallon gasoline tank, a 1,000 gallon oil tank, and a 250-gallon oil tank.
One 500-gallon oil tank is list as "active/in service" at this property.
5
9) Ryder Truck Rental Incorporated which is located approximately
0.11 miles east of the site at 3901 Stuart Boulevard. This property is
downgradient from the site and is listed in the variance request as a
"RCRA small quantity generator". Page # 10 and 11 of the "Vista
Site Assessment Report" shows that eight "in service" underground
storage tanks are present at this property containing "gasoline, diesel
fuel, motor oil, oil" and a fluid described as "hazardous".
10) Chemlawn Services Corporation which is located approximately 0.03
miles southeast at 655-R Pressley Road. This property is_located
downgradient from the site. Appendix A shows that this site _once had
a 2,000 gallon underground storage tank for diesel fuel. This tank is -
listed as "removed" from the property.
11) Page # 9 of the "Vista Site Assessment Report" shows two "in service"
underground storage tanks at the RSM Company located at 811
Pressley Road located approximately 0.09 miles northwest. This
property is upgraident from the site.
12) Page# 12 of the "Vista Site Assessment Report" shows that Ridgeway
Chemicals Incorporated has three underground storage tanks at 651
Michael Wylie Drive located 0.25 miles northeast of the site. These
tanks are listed as "active/in service" in the report. A 1,000 gallon
tank was removed from this site. The contents of all four tanks are
reported as "unknown". This property is cross-gradient from the
site.
13) Pressley Road ( a public roadway).
14) Public sewer lines and other utilities in the area.
15) Southern Railroad (a private rail company).
In addition, Page #15 through Page# 17 of Appendix A shows eight known
sources of groundwater contamination in the general area near 711 Pressley Road.
Due to inadequate information on the location of these sites, it is not possible to
represent them on maps contained in Appendix A. Scaled diagrams of this site are
found in Figures # 1 through # 4 and Figure # 11 of the report titled "Variance
Re q uest -Carolina Coatin ~s Site -Charlotte. North Carolina, December 9, 1996,
Dames and Moore N.C. Job No.23995-002-200." ~
6
Rule .0113 (c)(3): Description of the pro posed area for which the variance is re quested .... :
Maps of the area are shown in Figures 1 through 5 of the report titled
"Variance Re q uest-Carolina Coatin ~s Site -Charlotte, North Carolina, December
9, 1996, Dames and Moore N.C. Job No.23995-002-200." • The property af'711
Pressley Road for which Carolina Coatings Incorporated has requested this
variance for Groundwater Incident Number 8949 is within an area consisting of a
mixture of residential, commercial and industrial development. The map on Figure
11 shows that the property is bordered on its east side by Pressley Road and four
adjacent properties border the Carolina Coatings site on its north, south and west
sides. The Southern Railroad Line is to the west within 1,000 feet of the area in
which the release of substances occurred. The property on the west side is vacant
land identified under Mecklenburg County Tax Identification Number 145-291-07
and owned by Mr. Linwood Carter, who is also the proprietor of Carolina Coatings
Incorporated. In applying for a variance at 6500 North Tryon Street, Carolina
Coatings Incorporated did not include this adjacent property or any portion of it in
the request.
Table 4 in the report lists adjacent property owners by Mecklenburg County
Tax parcel numbers and addresses. The last column of this table locates these
adjacent properties relative to the site at 711 Pressley Road. Figure 11 shows these
properties and owners from a tax line map in Book 145, Pages 27-2, (Revised
5/7/96).
Figure 4 of the variance request also shows that the area of groundwater and
soil contamination prior to remedial actions was of an amorphous shape, much of
which extended beneath the former concrete pad and settling tanks. Since soil
removal activities and the igtplementation of the pump and treat cleanup system,
the area where substances are known to exist is shown in Figures 7 through 12 of the
variance request. These figures reveal that the area in which substances persist at
concentrations in exceedence of the Groundwater Quality Standards in 15A NCAC
2L .0202 is roughly in the shape of an ellipse. The groundwater contamination that
the Carolina Coatings Incorporated is responsible for encompasses both the
recovery well and Monitoring Well# 9 and appears limited to this area. Figures 8
through 10 and Figure 12 of the report shows that substances at 711 Pressley Road
Street have not migrated onto adjacent properties at concentrations above
Groundwater Quality Standards in 15A NCAC 2L .0202. This variance is for all
the land entirely within the property boundaries of 711 Pressley Road for which
Carolina Coatings Incorporated has cleanup responsibilities.
Pages 11 through 13 of the report titled "Variance Re q uest -Carolina
Coatin 2s Site -Charlotte. North Carolina, December 9 , 1996. Dames and Moore
N.C. Job No.23995-002-200" discusses groundwater contaminant migration and the
potential impact to water supply wells and surface streams in the area. Two water
supply wells are located within one-half mile of the site. These wells are 2,300 feet
south of the Carolina Coatings property at Yorkmont Road and Lochlane Drive.
The company could not ascertain if these water supply wells are currently in use as
7
a source of drinking water supply or other uses. Based on water use data and
hydrogeologic conditions in the general area, Carolina Coatings Incorporated does
not believe that this variance will have an effect on these wells. Based groundwater
flow calculations, the company does not believe that the variance will impact any
receptors near 711 Pressley Road.
Rule .0113 (c)(4): Su pportin 2 information to establish that the variance will not endan 2er
the p ublic health and safetv ... :
This part of the variance concerns Groundwater Quality Standards shown in
15A NCAC 2L. 0202 and has been requested for Benzene, Ethylbenzene, and
Xylene(-o,-m, and p). In ord-er to assess health impacts, groundwater sampling was
conducted at on-site monitoring wells to assess the extent of contamination, the
concentration levels of substances, and the movement of substances to adjacent
pro-perties. Groundwater monitoring from Carolina Coatings Incorporated
indicates that substances released at this site do not pose a hazard to the public. As
shown in Figure 5, nine monitoring well were originally installed at 711 Pressley
Road by the company. During site renovation to remove soil and repair the
concrete storage pad, two of these wells (Monitoring Wells MW# 2 and MW# 8)
were abandoned by the company prior to the implementation of groundwater
cleanup.
Carolina Coatings has conducted quarterly groundwater sampling at
Monitoring Well MW# 3, Monitoring Well MW# 7, and Monitoring Well MW# 9
from March 1994 through October 1997. Monitoring Well MW# 3 is located
upgradient approximately 125 feet to 150 feet from the area in which the release of
substances occurred at the northwest property line. Monitoring Well MW# 7 is
located within 35 feet directly to the south-southwest of this area and is roughl):7
down-gradient to the area that was impacted by the release. Monitoring Well MW#
9 is within the area of the release and is slightly downgradient from Recovery Well
RW # 1. Thirteen separate sampling events occurred during this period. As shown
in an April 19, 1999 letter sent to Groundwater Section, the last sampling and
analysis at all monitoring wells occurred on October 9, 1997. Toluene has never
appeared in any sample taken from monitoring wells from this site above the
Groundwater Quality Standard.
Table 2 of the variance request and data in the April 19, 1999 letter shows
that Monitoring Well MW# 3 and Monitoring Well MW# 7 have never had
concentrations of substance above detectable limits. Only Monitoring Well MW#
9 has shown concentrations of Benzene, Ethylbenzene, and Xylene above the
Groundwater Quality Standards in 15A NCAC 2L .0202. The only substance that
appeared in Monitoring Well MW# 9 during the October 9, 1997 monitoring event
was Benzene at 0.002 milligrams per liter or 2.0 micrograms per liter. The
Groundwater Quality Standard for Benzene is 0.001 milligram per liter or 1.0
microgram per liter. It is also important to note that Table 2 shows several graphs
of the concentrations levels of substances analyzed from Monitoring Well MW# 9
8
from March 1994 to September 1996. Although Ethylbenzene and Xylene have
been reduced below respective Groundwater Quality Standards, the concentration
of Benzene from samples taken from this well have fluctuated over time. In
September 1995 this concentration was reduced below the Groundwater Quality
Standard but later "rebounded" to the extent that the Benzene level in this well was
in exceed of the standard during subsequent quarterly monitoring events. In order
to provide additional supporting data for this variance request, Carolina Coatings
Incorporated sampled the downgraident monitoring wells MW# 5 and MW # 6.
No substances were detected in these wells above Groundwater Quality Standards
in 15A NCAC 2L .0202.
The Division also required the Carolina Coatings Incorporated to evaluate
the effectiveness of groundwater cleanup efforts by examining concentrations of
substances in the recovery well used as a sump to collect dissolved hydrocarbons
from the site. This monitoring effort was necessary to understand the effect pump-
and-treat cleanup has had on concentrations of constituents at the site. Table 1 of
the report titled "Variance Re q uest -Carolina Coatin ~s Site -Charlotte, North
Carolina, December 9, 1996. Dames and Moore N.C. Job No.23995-002-200"
provides a record of monthly groundwater samples obtained at the influent of the
recovery well for the pump-and-treat groundwater remediation system. This
monitoring was conducted from March 29, 1994 through October 30, 1996.
Except for Benzene, concentrations of substances monitored from the
recovery well have never exceeded the Groundwater Quality Standards in 15A
NCAC 2L .0202. Since monthly sampling of this recovery well influent began in
March 1994, the Benzene concentration has fluctuated from levels above the
Groundwater Quality Standard to below detectable limits. The highest
concentration of Benzene reported at this site was 0.0076 milligrams per liter or 7.6
micrograms per liter from the May 6, 1994 sampling event. The Groundwater
Quality Standard for Benzene is 0.001 milligram per liter or 1.0 microgram per
liter. Samples taken from September 30, 1996 through October 30, 1996 showed
concentrations of all substances below detectable limits.
From the information shown on Page 13 of the variance request, Carolina
Coatings Incorporated evaluated the impact granting a variance would have on
nearby receptors. The nearest downgradient adjacent property is a small strip of
the vacant land owned by Mr. Linwood Carter which is approximately 110 feet
from the area in which substances were released at 711 Pressley Road. Based on an
average hydraulic conductivity of 0.06 feet per day, an approximate hydraulic
graident of 0.01 feet per foot, and an effective porosity of 20 percent for silty clay,
the groundwater flow is calculated at 1.1 feet per year. Assuming no contaminant
dilution or attenuation and this figures, it is believed that it would take 100 years for
the plume of substances to reach this property boundary. In addition to
groundwater flow calculations, Carolina Coatings Incorporated has also submitted
the results of modeling using the Domenico Solute Transport Model for this site as
discussed on Page 13 of the report titled "Variance Re q uest-Carolina Coatin~s
Site -Charlotte. North Carolina, December 9, 1996 . Dames and Moore N.C. Job
No. 23995-002-200". The results of this modeling support the companies view that
9
this variance will not impact adjacent properties. Data from this modeling may be
found in Appendix B of the variance request.
No water supply wells were identified at adjacent properties to 711 Pressley
Road. A well survey only identified only two water supply wells within the ½ mile
radius of the site as specified under 15A NCAC 2L .0113(c)(4). ·These are located in
Figure 2 of the variance request at the intersection ofLochlane Drive and Yorkmont
Road approximately 2,300 feet south of 711 Pressley Road. According to the
information in this request, these wells are cross-gradient from the site. Page 12
states that is not known if these wells are being used as a source of drinking water
supply or for purposes other than drinking water. Drinking water for the City of
Charlotte is obtained from Mountain Island Lake on the Catawba River twelve
miles north of the site. All downgradient properties and other area properties are
supplied drinking water from the City of Charlotte.
'It is higbly improbable that public water supply lines will be impacted by
this variance. Numerous water supply lines and other utilities are located along
Pressley Road, Bishop Drive and Yorkwood Road. Contacts with the Charlotte
Mecklenburg Utility Department and found that utilities are not a potential path for
migration of petroleum hydrocarbons from the site. Page 12 of the variance request
shows that the depth to the groundwater in this area is approximately 15 feet to 20
feet. The utility department reported that area water lines and utilities are buried
less than five (5) feet from the surface. Groundwater contamination from Incident
Number 8949 that is beneath 711 Pressley Road is too deep within the subsurface to
impact these lines. In addition, Page 12 also states the Carolina Coatings
Incorporated does not believe any buildings with basements will be impacted by this
variance request.
Rule .0113 (c)(5): Su pp ortin g information to establish that re q uirements of the rule cannot
be achieved b v providin g best available technolo gy economicall v reasonable:
The part of the request that concerns variance to Corrective Action in 15A
NCAC 2L .01060) will allow Carolina Coatings Incorporated to discontinue
Corrective Action at this site. The company has submitted suppo.rting infonnation
in the report with other documents demonstrating that the continued application of
best available technology will not result in significant long term remediation of the
site to the Groundwater Quality Standards contained in 15A NCAC 2L .0202. The
is due to the high probability that continued cleanup activities at the site will not
significantly reduce contaminant levels below the Groundwater Quality Standards
in 15A NCAC 2L .0202.
Since discovery of the release in 1991, Carolina Coatings Incorporated has
disposed of a total of 2,400 cubic yards of BTEX contaminated soil. Page 6 of the
report titled "Variance Re q uest -Carolina Coatin ~s Site -Charlotte, North
Carolina. December 9, 1996, Dames and Moore N.C. Job No.23995-002-200" states
that the company has treated approximately 328,500 gallons of groundwater to
10
comply with the cleanup requirements of the Corrective Action Plan that was
implemented in March 24, 1994. Pages 15 through 16 of the report titled
"Variance Req uest-Carolina Coatin es Site -Charlotte, North Carolina, December
9, 1996, Dames and Moore N.C. Job No.23995-002-200" states that a total of
$493,000 has been expended to design and install the remediation system, operate
the system, monitor progress of cleanup activity, and cleanup this-site. Page 15 of
the variance request shows that the owner of Carolina Coatings Incorporated, Mr.
Linwood Carter, is retired and is reported in the variance request as financing the
cleanup of this site from this personal savings. H~ has bad no direct employment
since the sale of the property at 711 Pressley Road in 1991 to Wattyl Paints
Incorporated.
Groundwater analysis of samples from on-site monitoring wells showed
significant reductions in the concentrations of substances from March 1995 through
October 9, 1997. As previously stated the groundwater pump-and-treat cleanup
system operated from March 24, 1994 through January 1997. Except for
Monitoring Well# 9, Benzene and other substances related to paint mixing
operations have not been observed above Groundwater Quality Standards from
quarterly groundwater samples. Although concentrations of Benzene, Toluene,
Ethylbenzene, and Xylenes have been significantly reduced near Monitoring Well#
9 since cleanup operations began, the concentration of Benzene at a portion of this
site remains at levels in exceedence of the Groundwater Quality Standard in 15A
NCAC 2L .0202. Page 7, Page 8, and Table 3 of the report titled "Variance Re q uest
-Carolina Coatin es Site -Charlotte, North Carolina, December 9, 1996, Dames and
Moore N.C. Job No .23995-002-200" shows that after the pump-and-treat cleanup
system was temporarily taken out of operation for a period of five days,
concentrations of substances in monitoring wells, including Monitoring Well# 9, did
not change significantly. Table 1 shows that while the cleanup system was in
operation, results from groundwater samples taken from the influent of Recovery
Well RW # 1 during the period of March 29, 1994 through October 30, 1996,
revealed remaining concentrations of substances beneath 711 Pressley Road had
been significantly reduced such that they could no longer be detected.
In order to demonstrate that the requirements of the rule cannot be achieved
using best available technology, title 15A NCAC 2L .0113(c)(5) requires that specific
technology considered be identified, the costs of implementing the technology be
shown, and the impacts of the costs on the applicant be provided. Page 16 of the
report titled "Variance Re q uest -Carolina Coatin es Site -Charlotte, North
Carolina, December 9, 1996, Dames and Moore N.C. Job No.23995-002-200" states
that continued operation and monitoring at 711 Pressley Road will cost Carolina
Coatings approximately $48,000 per year. In addition, Page 14 of the request
shows that in order to continue cleanup with the pump-and-treat system, significant
upgrades will be needed for this system. These modifications include the installation
of additional groundwater recovery wells, new pumps, and renovations to increase
the size of the infiltration gallery. The company believes that the _low residual levels
of contaminants in the groundwater at this site does not warrant the continued use
of the pump-and-treat cleanup system. -
11
I
J
j
I
Carolina Coatings Incorporated has considered the use of air sparging with
soil vapor extraction (SVE) as alternate technology to the present pump-and-treat
cleanup system. This technology is an in-situ remediation method that involves the
physical introduction of air below the water table to volatilize groundwater
contaminants from groundwater and subsurface materials into a vapor phase. The
SVE portion of this system captures the volatilized substances so that they may be
removed from the subsurface environment. As shown on Page 15 of the report
titled "Variance Reg uest-Carolina Coatin gs Site -Charlotte, North Carolina,
December 9, 1996, Dames and Moore N.C. Job No.23995-002-200" states that the
average hydraulic conductivity in saturated zone beneath the site is 2 x 10-5
centimeter per second. Based on this low permeability, Carolina Coatings does not
believe the use of this type of technology will be effective at removing substances
that remain at 711 Pressley Road.
Carolina Coatings Incorporated did not identify any technology, other than
those already at the site and alternate technology identified in the variance, that
would meet the requirements of 15A NCAC 2L .0106(j) as "best available
technology". Pursuant to the requirements of 15A NCAC 2L .0113(c)(5), the
company does not believe that continuing remediation is economically reasonable.
Rule .0113 (c)(6): Su pp ortin e information to establish that com pliance would p roduce
serious financial hardshi p on the a pplicant:
Carolina Coatings Incorporated has submitted information showing that
compliance with the rules will result in a serious financial hardship. Page 15 of the
variance request shows that the owner of Carolina Coatings Incorporated, Mr.
Linwood Carter, is retired and is reported in the variance request as financing the
cleanup of this site from this personal savings. He has had no direct employment
since the sale of the property at 711 Pressley Road in 1991 to Wattyl Paints
Incorporated. Allowing the persistence of low levels of contaminants in -
groundwaters that, after approximately three years of applying best available
technology, have asymptotically approached the Groundwater Quality-Standards in
15A NCAC 2L .0202 through a variance is a prudent means of addressing Carolina
Coatings release at this site. It is no less effective a means of addressing residual
concentrations of substances at this site than continuing the use of pump-and-treat
system and is less expensive.
12
Rule .0113(c)(7): Supporting information that compliance would produce serious financial
hardship without equal or greater public benefit:
The company _has submitted information in the request demonstrating that
the environment, safety and public health would not be impacted by this variance.
A January 6, 1997 letter from the Mooresville Regional Office serves as a
justification for this variance as it states that " ....... continuation of pump and treat
remediation is neither cost effective nor environmentally beneficial". The letter
further states that the "Risk to the public is minimal considering the lack of active
water supply well systems, distance to s11rface water bodies, and the industrial
character of the site and surrounding sites.".
Rule .0113(c)(8): "A copv of anv Special Order ... ":
No Special Order by Consent has been issued for this site.
Rule .0113(c)(9): "A list of names and addresses of propertv owners ... ":
The property owners within the proposed area of the variance are shown in
Table 4 and the map in Figure 11 of the report titled "Variance Request -Carolina
Coatings Site -Charlotte. North Carolina, December 9, 1996, Dames and Moore
N.C. Job No.23995-002-200". This listing includes the Trimming-Associates LTD,
the Presseley Park Restaurant owned by Ionnis and Gregory Andreas, Rebpat
Leasing, Joachim H. Klitzsch, James A. Williams, J. David Fortenbery, Davis
Brothers Venture, Exit Fourteen Associates, the former Carolina Coatings site at
711 Pressley Road now owned by Wattyl Paints, John W. Layne, Linwood T. Carter
(property adjacent to 711 Pressley Road), the North Carolina Department of
Transportation, Southern Railroad, and two parcels of land owned by Eight
Hundred Eleven Pressley. Title ISA NCAC 2L .0113(e)(E) requires that
notification of a public hearing on this variance be given to the owner or owners of
these adjacent properties "at least 30 days prior to the date of the hearing".
It is the recommendation of the Groundwater Section that the subject variance
request to Corrective Action requirements of 15A NCAC 2L .0106(j) and Groundwater
Quality Standards contained in 15A NCAC 2L .0202 proceed to public notice in
accordance with ISA NCAC 2L .0113(e). On February 27, 1997, the Division of
Epidemiology completed their review of the risk assessment methodology for this site and
recommended that this variance be granted for Carolina Coatings Incorporated at their
former property located at 711 Pressley Road in Charlotte, North Carolina. Upon your
concurrence with our recommendation, the Groundwater Section will proceed with the
13
. .
preparation of the required public notice and hearing. Upon completing of the
requirements of 15A NCAC 2L .0113(d-f), with a recommendation to grant this variance
from the Environmental Management Commission Groundwater Committee, this request
will proceed to the Environmental Management Commission for final action in 15A NCAC
2L .Ol 13(g). If there are any questions regarding this matter or if any additional
information is needed, please let me know.
ATTACHMENTS:
. cc: Groundwater Section Assistant Chiefs
Mooresville Regional Groundwater Supervisor
Dr. Ken Rudo
David Hance
14
.
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
DIVJSION OF WATER QUALITY
July 9, 1999
SECRETARY Rebpat Leasing WAYNE MCDEVITT ~
~ • ~ 722 Pressley Road
Charlotte, NC 2821 7
'I'
.• , :J REGARDING: Property at 722 Pressley Road ;~ :.";'~;'. J TO WHOM IT MA y CONCERN: (Tax Id Number 145-271-09)
· ·. _, ;. _.;;;:t~ The Department of Environment, Health and Natural Resources has received a
~-/"·J . ti:;f\!jlt request for a vari~ce fro1:11 the G~oundwater Quality Standards of l?A NCAC 2L ·~; ,_. .. ;· r .. ,t;_" .e~::;. .. 0202 and Corrective Action reqmrements of 15A NCAC 2L .0106(j). 15A NCAC 2L ~;,~ ~~,::'.i/(;:: :1r -~--~} .0l 13(e)(l)(E) req~ires adeq~ate notice be given to area properties and adjacent
· --~ ;..'--:-1:---_.,. ~., property owners pnor to hearing. ~,,~~~/ --~~'(~
.. l ;:<:;·.~ ,. )~~ You will find enclosed a Public Notice regarding the variance hearing. Please refer
:-;-: ::,.,.~ · -~·:-~--:st to the enclosure for additional information. If you have any questions concerning this
I . .-( ~ ·l -::J variance request, please contact David Hance at [phone].
(~i
;,: --:,,~
.,
.. , ... ~r· 3 't
..•. ~~~
.-a
'-:J Enclosure
Sincerely,
M. Carl Bailey, Jr.
Assistant Chief for Planning
Groundwater Section
GROUNDWATER SECTION
P.O. BOX 29578, RALEIGH, NORTH CAROLINA 27626-0578 • 2728 CAPITAL, BLVD., RALEIGH, NC 27604
PHONE [phone] FAX [phone]
AN EQUAL OPPORTUNITY I AFFIRMATIVE ACTION EMPLOYER • 50% RECYCLED/I 0% POST-CONSUMER PAPER
CAROLINA COATINGS/GWI 8949
WELL OWNERS/ADJACENT PROPERTIES./ AND STAKEHOLDERSSheet1
TRIMMING ASSOCIATES L TO. I I CHARLOTTE INC I 1145-271-05
IONNIS ANO GREGORY ANDREAS 740 PRESSLEY ROAD CHARLOTTE NC 145-271-07
REBPAT LEASING 722 PRESSLEY ROAD CHARLOTTE NC 145-271-09
JOACHIM H. KLITZSCH 700 PRESSLEY ROAD CHARLOTTE NC 145-271-10
JAMES A. WILLIAMS 654 PRESSEL Y ROAD CHARLOTTE NC 145-271-11
J. DAVID FORTNEBERY 644 PRESSLEY ROAD CHARLOTTE NC 145-271-12
DAVIS BROTHERS VENTURE 650 PRESSLEY ROAD CHARLOTTE NC 145-271-15
EXIT FOURTEEN ASSOCIATES 665 PRESSLEY ROAD CHARLOTTE NC 145-291-01
CAROLINA COATINGS INCORPORATED 711 PRESSLEY ROAD CHARLOTTE NC 145-291-03
JOHN W. LAYNE 801 PRESSLEY ROAD CHARLOTTE NC 145-291-04
LINWOOD T . CARTER 7518 MEGINGTON DRIVE CHARLOTTE NC 28226 145-291-07
EIGHT HUNDRED ELEVEN PRESSLEY 803 PRESSLEY ROAD CHARLOTTE NC 145-291-08
EIGHT HUNDRED ELEVEN PRESSLEY 805 PRESSLEY ROAD CHARLOTTE NC 145-291-09
MS. PAM SYFERT (city manager) CITY OF CHARLOTTE-GOVERNMENT CNT 600 E. FOURTH STREET CHARLOTTE NC 28202
HON. PAT MCCROY (MAYOR) CITY OF CHARLOTTE· GOVERNMENT CNT 600 E. FOURTH STREET CHARLOTTE NC 28202
MR. PETER SAFIR (HEAL TH DIRECTOR) MECKLENBURG COUNTY HEAL TH DEPT. (AMH) 429 BILLINGSLY ROAD CHARLOTTE NC 28211
SOUTHERN RAILWAY OLD HIGHWAY 70A HICKORY NC 28602
WATTYL PAINTS 5156 RIVER ROAD COLUMBUS GA 31904
PATRJCKJ.GALLAGHER DAMES AND MOORE NC 5301 • 77 CENTER DR., SUITE 41 CHARLOTTE NC 28217
NCDOT DONGOLLIS P.O. BOX 25201 RALEIGH NC 27611
Page 1
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AKIN, I. HARLES -S[ .N!CE OISTRJBUTING CO p o a~,<Q . ..;;
r iU;SE.PAA l~LI: ', llG 28002
>--i 1201 MAPLE ST --ALBRIGHT, CLYDE B ATTY CC .'IIE MILLS CORP GRECNSBORO NC 21,ms
ALBURY, ROBERT ch RAY'S GROCERY ROUTE #2, BOX 191 CANTON NC 28716
ALEXANDER. HARLOLD 11627 WYCUFF COURT BURLINGTON INC 27215
ALIX. JONATHAN --AW ARE ENVIRONMENTAL 9305 MONROE RO SUITE J . CHARLOTTE NC 28270
ALLEN, !-RED R EXECUTIVE DIR NC AGGREGATCS ASSOC!ATI~ I PO BOX 3C-503 RALEIGH 1'C 2?622
ALSTOI'.. SARAH GU\XO ~ WELLCOM!:: INC. 5 ~~OORE DRIVE RTP NC 27709
ANDERSON, GLEN CADMUS (THE) GROUP INC I 1s20 1-fNY M su1re 100 DURHAM NC 27713
APA COORDINATOR ENR OFFICE OF POLICY DEVELOPMENT INTEROFFICE
APPLEBAUM, STEVE CL CAN HARBORS ENVIRONMENT AL SERVICE PO BOX 8530?7 BRAl/'l;ffiEE MA 02185
ASBURY, DeNNlS OIROF UTIL PUBLIC UTILITIES DEPT 191 MEBANE BR IDGE ROAD EDEN NC 27288
AS.S EFA, HANNA ENR I OSWM -SUPERFUND SECT10 L INTEROFFICE I --ASST SECRET ARY -lll,, -~ ARCHDALE BLDG ~ ~ INTEROFF ICE
ATTORNEY OENl!RAL'S OFFICE ~-ENVIRONMENTAL PROTECTION SEC ~ [ 1293 ARCHDALE BUILDING _ . .,... -~ IITTE~OFFIC!' -
AUCOIN. LINDY BODE CONE MIUS CORP 1201 MAPLE ST GREENSBORO NC 27410
AUGBURGER. TOM US FISH AND WILDLIFE SERVICE PO B01:33726 RALEIG!-i NC 27637
A vcocK. C RONALD EXEC DIR , ---NC ASSOC Of CO COMMISSIONERS -PO BOX 1488 ---RALEIGH "c 27502
BABB,GARY I BA9B & ASSOCIATES PO BOX 3?697 RALEIGH INc I 27627
BAILEY, CLAYTON I CX>PER. ALDUS , AND SCULL y FOUNDERS SQUARE, 900 JACKSON ST. SUITE 100 DALLAS TX 7S202
BAILEY, JIM I ATLANTIC DIV NAVAL FACILITY I ENGINEERING COMMAND CODE 181 NORFOLK VA 23511
BAKER, TL, SUP ENV PROG TEXASGULF INC I Po BOX4B AURORA NC 27806
BALES,JIM PO BOX85 BUlE.S CREEK NC 27506
BANKS, SHELVA 614 FOREST PARK RO ELIZABETH CITY NC 27904
BARDIN, W EARL F IRST UNI0,"1,1 NATIONAL BANK PO BOY.3006 RAtEIGn NC 27602
BASNIGHT, SYBIL FRIEt:os OF ROANOKE ISLAND PO BOX 1750 .-.ANTEO INC I 27954
BEATY, D.C. GENERAL ELECTRIC COMPANY i299 PENNSYLVANIA AVE., t#/, SUITE 1100 WASHINGTON OE 20004
BECK, KRISTIN IEnv. Cord.) DUPONT COMPANY FIBERS P.O. BOX 2042 WILMINGTON I NC I 28402
BELL, JANICE I PATTON BOGGS & BLOW PO BOX20004 I GREENSBORO NC 27470
BENNETT, JAY 2320 BRISBAYNE CIRCLE RALEIGH NC 27615
BILLINGS, RANDALL L EXEC DIR I p;[DMONT TRlAO CCUNCiL OF GVT 2216 W MEADOWVIEW RD SUITE 201 GREENSBORO NC 27407
BIWNGSLEY, EVERETT ORANGE WATER & SEWER AUTHRO ITV P080X366 CARRBORO NC 27510
BLACK , BILL C OFFICE ENG US ARMY CORPS OF ENGINEERS PO BOX 144 MONCURE I NC 27559
BLACK, CHESTER ASSOC DIR NCSU-AGRICULTURAL EXT SERV l 1oa RICKS HALL INTEROFFICE I
BLACKSON, BUD BLACKSON TANK S[:1VICE RT 2 BOX 300AB FUQUAY-VARINA NC 27526
BLACKWELL, CHARLES D PRESIDENT 'APPLIED WATER TECHNOLOGY INC 621 HUTTON STRe:ET SUITE 107 RALEIGH NC 27506
BLANCHARD, STEVEN K DIRECTOR PUBLIC WORKS COMMISSI0."4 PO DRAWER 1089 FAYETTEVILLE NC 28302
BUCK,CLIFFT DUPONT CO FIBER DEPT PO BOX2C-42 WILMINGTON NC 28-402
BLOCKER, MARY I P.O. BOX 35 CULBERSON \IJ,C 28903
BOONE, JOHN ----=· -fN AilONWIOE TANKS ENV SERVIN -PO BOX 472349 CHARLOTTE ,i-r<e 28247
BOONE, LARRY !NATIONWIDE TANK & ENV SERVICE PO BOX 472349 ---l cHARLOTTE \NC I 28247 -
BORDEN, ANN M r5.&M F" IP O BOX 58069 RAU'IGe NC 27658
BORDEN, BOB PO BOX 790S RALEIGH NC 27695
BOSWELL,JT PHO DIR ENV CON LOUISIANA-PACIFIC CORP IPO BOX3107 CONROE TX TT305
BOYER, KEVIN RUST ENVIRONMErfT & INFRAASTRU 5510 SIX FORKS RD RALEIGH NC 27605
BOYLE, CHARLES G ----ju,.w ENGtNEER!NG 2801 YQRK,.".,lON T RO -CHARLOTTE INC 28208
BOYLE, KAY B.O.C GASSCS P.O. BOX 12338 RTP NC 27709
BOYTER, JOHN RALEIGH CHA~~~9ER OF COMMERCE PO BOX2978 RALEIGH NC 27602
BRENNER, MICHAEL PO BOX 76 !WINSTON SALEM NC 27102
BRIDGES, GARY McCALL BROTHERS P.O. BOX 668710 CHARLOTTE IIC 28266
BRIDGES, WILLIED ENGINEER RCA MAGNET WIRE CO IP O BOX 1226 LAURINBURG NC 28353
BROCK, WALT~R S ENVIRONMENT AL QUALITY AUDIT P.O. BOX 2074 CARY NC 275\2
BROOM ERK El, JAN US ARMY CORPS OF ENGINEERS P O BOX 1890 (EN-GIBRODMERKEL) IWtl.MlhlGJJ)tl !Ne 28402
B ROWN , J OHN M 10911 BALSRIGGAN CT CHARLOTTE NC 2B262
BRU ESCH, PAUL R STAFF ENG BURLINGTON K'.JITTEO FABRICS PO BOX21207 GRECNSBORO INc 27420
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BUMGARDNER, CARLL ENV IFEDERA!. PAPER eoARo co :;Jc I RIEGELWOOD OPERATIONS RiEGELWOOO tlC 28456
BURGER, RONALD J. DUPONT CORPORA TIO: Z P.O. BOX 2042 WILMHiGTON INc 28402
BURNS, RICHARD G HYDROLOGIST USDA FOREST SERVICE PO BOX2750 ASHEVILLE INC I 26802
BYNUM, HAROLD N SMITH HELMS MULLISS & MOORE PO 80X21927 GREENSBORO ·NC 27420
CA.IN, STEVE -N.C.G.W.A P.O. BOX 1290 NEWMARKET ,•, 22844
CALI l/'fAH, DO B -SPATCO ENVIRONMENTAL l!':G 5100 NORTH 1-85, STE 7 CHARLOTTE I,.,; I 28205
CALOWELL, SHAWNA W EDGERTON ENVIRONMENTAL SER 12200 GATEWAY BLVD SUiTE 205
-
1J.'.J.;;8P,:1 S,ill.l£ NC 27560
CALOUCHE, SAM -FIRESTONE FIBERS & TEXTILES ... IP O BOX 1369 KINGS MOUNTAIN INc 280B6 -
CAMPBELL, BART EDGECOMBE COUNTY HEAL TH DEPT 2909 N MAIN STREET TARBORO NC 27686
CAMPBELL, STEVE GROUNDWATER MANAGEMC'JT ASSOCIATES 222-C COTANCHE STREET GRE!::NVILLE NC 27858
CANAVELLO, DOUG PYRAMID ENVIRONMENTAL 2700 PINEDALE ROAD I GREENSBORO NC 27408
CANNON, REGINA CH2M HILL SUITE 700 115 PERIMETER CENTER PLACE NE ~TLJINT;.. GA 30346
CANTOR, RICK -ESE BIOSCIENCES --i17◄1-F SOUTHERN PINE Sl.VD CHARLOTTE l ►it I 28273
CARR, STEVE J ENVIRON SPECIAUS INl[MS 12233 MD C1-C1 RTP NC 2i70&
CARRARA, GUIDO J PRESIDENT G C ENVIRONMENTAL PO 80X40125 !RALEIGH NC 27!'29
CARROW, HARVEY VAC P OBOX322 KINSTON NC 28502
CARTER, DERB -J soUTHERN ENVIRONMENTAL LAW CNTR, 137 E FRANKLIN ST SUITE 404 CHAPEL HILL -NC 27514
-----..::l -l DU,<E-POWcR CO PO BOX 1007 -!C><AlltClTTl "INC CARTER, JOHN S f 28201
CARTER, PHIL WAKE COUNTY SCUD WAST[ MGMT PO BOX550 RALEIG!i NC I 27602
CARVER, FRANK ENVIRONMENTAL HEAL TH PROGRAM WESTERN CAROUNA UNIVERSITY ICULLOWHEE NC 28723
CATON. MATT A ENVIRONMENTAL ENG LUFKlt!ICOOPER INDUSTRIES PO BOX 728 LUFKIN ROAD APEX NC 27502
CAVANAUGH, STEVE HOBBS UPCHURCH PO BOX 1737 SOUTHERN PINES NC I 28388
C,E.O. NANTAHALA POWER AND LIGHT CO. 301 l!P & L LOOP FRANKLIN NC I 28734
c.e .o. NEW RIVER LIGHT & POWER CO. P.O. BOX 1113 BOONE NC 28607
C.E.O. ALBEMARLE ELECTRIC MEMBERSHIP CORP. !P.O. BOX 69 HERTFORD NC 2i~4
C.E.O. BLUE RIDGE ELECTRIC MEMBCRSHIP CORP . IP"O, eox112 L[rKJIR NC I 28645
c.e.o. BRUNSWICK ELECTRIC MEMBEHSHI!' CORP. P.O. eox 626 S1-'.Al..LOTTE NC I 28459
C.E .0 . CAPE HATTERAS ELECTRIC MEMBERSHIP CORP. I BUXTON NC 27920
C.E"O CARTERET-CRAVEN ELECTRIC MEMBERSHIP CORP. lp,o" BOX 1'99 MOREHEAD CITY NC 28557
C.E.O. CENTRAL ELECTRIC MEMBERSHIP CORP. P.O. BOX 1107 SANFORD INc 27330
CLtl CRESENT ELECTRIC MEMBE.~SHIP CORP. )p_Q_ BOX 1631 STATESVILLE m; 2Be87
C.E.O. DAVIDSON ELECTRIC MEMBESHIP CORP. I P .0. BOX 948 LEXINGTON, NC 27292
c.e..o . EOGECOMBE..f..4ARTIN COUNTY ELECTRIC MEMBERSHIP CO. P.O. DRAWER 188 j TARBORO NC I 27886
c.e.o. FOUR COUNTY ELECTRIC MEMBERSHIP CORP. P.O. BOX667 BURGA\1\.1 NC I 213425
C.E.O. FRENCH BROAD ELECTR!C MEMBERSHIP CORP. P.O. BOX 9 r-..•iARSHALL NC 28753
C.E ,O, HALIFAX ELECTRIC MEMBERSHIP CORP. P.O. BOX667 ENFIELD NC I 27823
c.e.o. HARKERS ISLAND ELECTRIC MEMBERSHIP COR?. P. 0, BOX 190 HARKERS !SL.ANO NC I 28531
C.E .O . HAYWOOD ELECTRIC MEMBERSHIP CORP. 1819 ASHEVILLE ROAD WAYNESVILLE NC 28786
C.E.O. JONES-ONSLOW ELECTRIC MEMBERSHIP CORP. 259 WESTERN BLVD. JACKSOfl.'VILLE NC 28540
C.E.O" Lt.n.1BEE RIVER ELECTRIC MEMBERSHIP CORP. P.O. BOX 630 RED SPRINGS NC 283?7
c"e.o" PEE DEE ELECTRIC MEMBERSHIP CORP P.O. BOX 859 WADESBORO NC 28170
C.E.0 PIEOMO~!T ELECTRIC MEMBERSHIP CORP. P.O. DRA\.·VER , 179 H!LLSBOROUGH j NC 2n18
c.i:.o. PITT AND GREEN ELECTRIC MEMBERSHIP CORP P.O. BOX2"'9 FARMVILLE INC 27828
C"E.O" RANDOLPH ELECTRIC MEMBERSHIP CORP. P.O. BOX. 40 ASHEBORO NC 27203
C.E.O. ROANOKE ELECTRIC MEMBERSHIP CORP. P.O. BOX 440 RICH SQUARE NC 27869
C"E.O. RUTHERFORD ELECTRIC MEMBERSHIP CORP. P.O. BOX 1569 FOREST CITY NC 28043
C.E.O. ]SOUTH RIVER ELECTRIC MEMBERSHIP CORP. P.O. BOX 931 DUNN NC 28334
C.E.O. SURRY YADKIN ELECTRIC MEMBERSHIP CORP. DOBSON NC 27017
C"E"O. TIDELAND ELECTRIC MEMBERSHIP CORP. P.O. BOX 159 PANTEGO INc 27860
C.E.O TRI-COUNTY ELECTRIC MEMBERSHIP CORP. P.O. BOX 130 DUDLEY NC 28333
C.E.O UNION ELECTRIC MEMBERSHIP CORP. P.O. BOX5014 MONROE NC 2a,10
c.e.o. WAKE ELECTRIC MEMBERSHIP CORP. P.0.BOX 1229 WAKE FOREST NC 2756?
C.E ,O. BLUE RIDGE MOUNTIAN ELECTRIC MEMBERSHIP CORP" YOUNG HARRIS GA 30582
c.e.o . BROAD RIVER ELECTRIC COOPERATIVE, ttlC P.O. BOX 780 GAFFNEY SC I 21l'3<10
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C.E.O. MECKLENBURG ELECTRIC COOPERATIVE ORA\l"JER 1£'!) MOL;~'TAIN CITY TN 3i663
C.EJ>. TRI STATE ELCCTRIC MEMBERSHIP CORP BOX 68 McCAYSVILLE GA 30555
C.E.O. Vil AFOAM INC. 222. SURRAT OR H!GH POINT NC 27263
C.E.O. AGRiCULTURAL RESOURCES CENTER 112 SOUTH 6LOUNT STREET R/l.LEIGH NC 27601
CG MCS OFC OF STAFF JUDGE ADVOCATE ATTN CIVIL LAW CAMP LEJEUNE NC 28542
CHADWICK, ASHLEY T LAIDLAW ENV!RONMENT AL SVCS 1640 ANTIOCH PIKE AtiTiOCH TN 37013
CHADWICK, THERESA M. USOA-NRCS 4405 BLAND ROAD, SUITE 205 RALEIGH NC 27609
CHANDLER, DELORIS CHANDLER SOIL CONSULTANTS 600 SOUTH CHURTOS APT 97 HILLSBORO NC 27278
CHANEY. JOHNNY CITY OF ASHEBORO P.O. BOX 1106 ASHEBORO NC 2i204
CHAPMAN, ANTHONY EATON CORPORATION l Posox 112a KINGS MOUNTAIN INC 28086
CHEOSEY, GEORGE VP SOIL REMEDIATiON CO PO BOX6217 DENVER lco I 80206
CHERRY, DEBORAH l reNNESSEE VALLEY AUTHORITY l•oo WEST SUMMIT RD KNOXVILLE ITN I 37902
CHESSON, H.O. CHESSON fl.ANAGE.MENT INC. 2030 ~5 SERVICE RD .. STE A-11 DURHAM NC I 27i05
CHIEF, OWQ-WATER QUALITY SECTIO --ENR-OWQ INTEROFFICE I
CHIEF, ENVIRONMENTAL OPERATIONS __,.._ ENRJDWC --INTEROFFICE..--I
CHIEF, LAND QUALITY C ENR/OIV OF LAND RESOURCES
--
INTEROFFICE I I
CHROSTOWSKI, PAUL TriE WEINBERG GROUP, INC. 1220 19TH STREET, t,r,/v WASHINGTON l oc I 20036
CLARK, LARRY R ENV ENGINEER TENNESSEE VALLEY AUTHORITY 270 HANEY BUILDING CHATTANOOGA TN I 37401
Cl.ARK. OR. ROGER T.T.U.U.S. 661 ANDERSON DRIVE PITTSBURGH PA I 15220
CLARKE, WILLIAM ROBERTS STEVENS & COGBURN PA PO BOX 7647 ASHEVILLE INc I 28802
COAN,ANN NC FARM BUREAU FEDERATION I P.O. BOX :27765 RALEIGH NC I 27611
COKER, JERRY F AREA ENV MGR WEYERHACUSER PAP[R COMPAr:v I Po eox 787 PLYMOUTH NC I 27962
COLE, C TIMOTHY UNIFI INC PO BOX 737 MADISON INC 27025
COLEY, ED WINTERVILLE MACHINE WORKS 226 SOUTH Mill STREET WINTERVILLE INc 28590
COLLIE, PEYTON NRECA 4301 WILSON Bl VD. ARLINGTON VA 22203
COLLINS,RS COlUNS ASSOCIATES INC 8 HICKORY RIDGE CT LAKE WYLIE SC 29710
COLSTON, NEWT --l et.ACK & VEATCH 8604 CUFF CAMERON OR STE is-4 CHARLOTTE lr,c I 28269
COMMANDtNG GENERAL ATTN: SJ.A. ADMIN SECTION I MARINE CORPS BASE PSC BOX 2004 CAMP LEJEUNE NC 28542
COPERHAVER, JIM lvePCo P.O. BOX 26666 RICHMOND VA 23261
COREY, HELEN OGDEN ENVIRONMENTAL & ENGINEERING SERV. !tJC. Po uo;r. J1-o1 ~ HUNTERSVIUE \NC I 28070
CORDER, JEFFERY W ,02 CANDLEWICK RD ABERDEEN NC I 28315
CORNETTE, JIM RICHARD CATLIN & ASSOC PO BOX 10279 WILMINGTON NC 28405
CORNITUS, EVE ADVANCED ANALYTICS 1025 CONCORD AVENUE COLUMBUS CH 43212
CORREALE, CHRIS US ARMY CORPS OF ENGINEERS PC BOX 1890 WILMlfJGTON NC 28402
COX, TEO WINTERVILLE ~ACHINE WORKS j POBOX520 WUJTERVILLE NC 28590
COVER. CVNT\IIA = 1N.C. CITIZENS FOR BUSINESS AND INDUSTRY P.O. BOX 2508 RALEIGH Im: I 27602
CRANDALL, SOSBY AQUATERRA INC., 4901 WATERS EDGE DRIVE RALEIGH NC 27606
CRAWFORD, THOMAS J PRIN ENG CP&L PO BOX 1551 RALEIGH NC I 27502
CRISER, DAVID E.. CRISER & TRO'JTY.AN P.O.BOX 3727 WILMINGTON NC 28406
CROSBY, VICTOR W. 1469 TABOR ROAD HARMONY INC I 28634
CROUCH, MICHAEL S \DEL TA Et.lVIRONMENTAL CO....,SULTAN 6701 CARMEL RD SUITE 200 CHARLOTTE NC I 28226
CROWLE, DAVID A OWENS-CORNING FIBERGLASS CORP FIBERGLAS TO'W ER-T/11 TOLEDO ioH <3659.
DALZELL, ROBERT 23CES/CEV 560 INTERCEPTOR RD IPoPEAFB NC I 28308
DAVIS, DAVID DAVIS ENTERPRISES 310 POINT RD MOCKSVILLE NC I 270'28
DAVIS. GARY COMMANDING GENERAL AC/S ENVIRONMENTAL MANAGEMENT BUILDING ONE MARINE CORPS BASE CAMP LEJEUNE NC I 2B542
DAWSON, AMOS C Ill ATTORNEY MAUPIN TAYLOR Ell.IS ADAMS PA PO DRAWER 19764 RALEIGH NC I 27619
DAY, WILLIAM J VICE PRES DAVIS & FLOYD ENGINEERS INC I PO DRAWER 428 GREENWOOD SC I 29646
DWQ REGIONAL SUPERVISOR ENRJDWQ I ASHEVILLE REGIONAL OFFICE COURIER06-78-45 I
OWQ REGIONAL SUPERVISOR ENR/DWQ FAYETTEVILLE REGIONAL OFFICE COURIER14-56-25 I
OWQ REGIONAL SUPERVISOR ENRIOWQ I MOORESVILLE REGIONAL OF:1CE j coURIER13-21-07 I I
DWQ REGIONAL SUPERVISOR ENR/0\NQ RALEIGH REGIONAL OFFICE INTEROFFlCE I
owa REGIONAL SUPERVISOR ENR/OWO WASHINGTON REGIONAL OFFICE COURIEROl-74-29 I
OWQ REGIONAL SUPERVlSOR ENRIDWQ WIU./JlNGTON REGIONAL OFFICE COURIER04-1a.33 I I
OWO REGIONAL SUPERVISOR Ef..lR/O'J./Q WINSTON SALEM REG!ONAL OFFICE lcouRIERO!l-2,-•s I
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DEMAITRE, EUGENE ~----,.--lsUREAU OF NATIONAL AFFAIRS ~ ;::::_ -N-308B. 1231 25TH STREET, NW. . WASHINGTON DC 20037
-
DEN BRAVEN, OR. K.R. COLLEGC CF lNGINEERING (CFATS) UNIV[RSITY OF IDAHO MOSCOW !1 0 83844
DEPUTY SECRET ARY -ENR ENR INTEROFFICE
DERRICK, CHARLES LONG 8E.ACH, TOWN OF POBOX217 LONG BEACH ;'.\IC 26461
DEVANEY, LEN R ENVR ENGR AT&T PO BOX 25000 PLANT ENG GREENSBORO . ., 27420
DEWEESE, BOB DIV OF PLANT OPER DEPT OF PUBLIC EDUCATION EOUCA TION !lLDG INTEROFfiCE
DICK, CHARLES M TRIGON CNGINEERING CONSULTANT PO BOX 18846 GREENSBORO :NC I 27419
DIRECTOR L......,-IEN R OW"--INTEROFFICE
DIRECTOR ~ ~ I EtlR/OIVISION OF SOLID &HAZ W INTEROFFICE
DIRECTOR ENR•OJ IJ OF MARiNE FISHERIES MOREHEAD CITY COURIER11-12-i3
-
DIRECTOR ~ ENR . OfFICE OF POLICY DEVELOPMENT -INTEROFFICE -
DIRECTOR ,...,_, ENR!OII/ OF LAND RESOURCES ~ ::... --INTEROFFIC E
DIRECTOR .'C 1ENR/1lWr.l I INTEROFFICE --~ -
DIRECTOR ~ =--_i
--ENR/OFr;cE OF GEN COUNSC .. l ---~ INTEROFFICE -=----9'-~
DIRECT~ (-er-<....::..___! !:._ ENR/PUBLIC AFFAIRS I ~~ INTEROFFIC~
~
~ -
DIRE:cTOR
-, :.: ~-DIVISION ENVIRONMENTAL HEft.LTH -I 1330 ST MARY'S ST -INt.ROFFICE _:, -
DIRECTOR L/ ~-= "k-NC ENVIRONMEf1fTAL DEFENSE FU!\D ~ 2500 BLUE RIDGE ROAD, bl..JITE 330 -J RALEIGH ,_.1ic:•~ 27607
DIR~CTOI< I ~ DIVISION OF EPiDEMJOLCGY = 1 COOPLR BUILDING INTEROF!ICE = I --~
DIRECTOR BRUNSWICK COUNTY HEAL TH DEPT. BOUVi.<\ COURIER 04-20-08
DOLL,BARRY ENSAFE SERVICES, PC 5540 CENTERVILLE OR .. SUITE 205 RALEIGH NC 27808
DONALDSON, HENRY A MGR SAF&ENV CRANSTON PR!NT WORKS CO 13a1 CRANSTON ST CRANSTON RI 2920
DORSETT,·AL 400 E VANDALIA RO GREENSBORO NC I 27406
DOUCETTE., Bill ARCADIS, GERAGHTY, AND MILLER 2840 PLAZA PLACE, SUITE 350 !RALEIGH NC I 27612
DRESSEL, PETER J. PEIOMONT GEOLOGIC 6003 CHAPEL HIU ROAD, SUITE 113 RALEIGH NC 2?607
DREYFUSS, LISA N MS BUREAU OF NATIONAL AFFAIRS RM387 SOUTH 1231 i5TH ST NW WASHINGTON DC I 20037
DRISCOLL. JOHN--LAW Et IGINE:-RING ,2801 YORKMONT RO., SUITE 30D (:l;A!<LOTTE -Ire 28208
DUAATt.. JACI\IE -ENVIRONMENT AL REPORTER 1 123, 25TH ST NW SUITE 347 WASIIINGTON loc 20037
DULA, GEORGE E CHAIRMAN FRIENDS OF THE WATAUGA DRIVE POBOX254 I REINHOLDS PA 17569
DUNCKLEE, DAVE DUNCKLEE & DUt~HAM POBOX33366 RALEIGH NC 27636
DUNN, GLENN I POYflER & SPRU:LL POBOX10Dm RALE IGH NC 27605
OURWAY, MARK 6 BENT TREE DRIVE ASHEVILLE NC 28803
EARP, STEPHEN W SMITH HELMS MtiLUSS & MOORE PO BOX21927 GREENSBORO INC 27~20
EDMUND, BILL P.O. BOX 239 CHADBOURN NC 28431
EID, JON ENV ENO GROUP UNlmJ CAMP CORP FRANKLIN VA 23851
ELLIS, TOM RESOURCES PLANNING & DEVEL AGRICULTURE BLOG INTEROFFICE
CUISON. SHERRIE A -PARKER POE ADAMS & BERNSTEI N b oo c; ;ARLOTTE PLAZA CHARLOTTE rlC 282~4
EMMEL. ROBERT H CMIEF ENVIRONMN REEVES BROTHERS JNC POBOX892 sPARTANBURG SC 29304
ESTRIDGE, JOHN IM003A5) DUKE POWER COMe.,A.NY 13339 HAGARS FERRY RO. ! HUNiERSVILl.E NC 28078 -EVERETT, GEORGE T MANUFACTURERS & CHEMICAL IND (MCIC) 620; :. W!::.ST STREET, SUITE 101 RALEIGH NC 27603
EDWARDS, SHANNON ROCK-TEUN COMPANY 207 FOREST ~ILLS SCHOOL RD. MARSHVILLE Ne 28103
ETURIME;Vt<; --CLARIANT CORPORATION P.O. BOX 669246 CHARLOTTE ,,c 28266
EXECUTIVE DIRECTOR THE. ALBEMARLE COMMISSION (REGION R) [512 S CHURCH STRCET, P.O. BOX 646 HERTFORD NC 27944
EXECUTIVf OlRl:CTOR !MID-EAST COMMISSION WASHINGTON COURIER 16-02-04 NC
EXECUTIVE DIRECTOR REGION O COUNCIL OF GOVT'S EXECUTIVE ARTS BLOG FURMAN RO BOONE NC 28607
EXECUTIVE DIRECTOR j PEE DEE COUNCIL OF GOVERNMENT 302 LE.A.K STREET ROCKINGHAM NC 2S379
EXECUTlVE DIRECTOR KERR-TAR COUNCIL OF GOVT PO BOX 709 HENDERSON NC 27536
EXECUTIVE DIRECTOR NEUSE RIVER COUNCIL OF GOVT NEWBERN COURIER01-34-3□
EXECUTIVE DIRECTOR J PLANNING & ECON DEV SW NC P O DRA\/VER 850 BRYSON CITY NC 28713
EXECUTIVE DIRECTOR I REGION L COUNCIL OF GOVT ROCKY MOUNT COURIER07-60-07
EXECUTIVE DIRECTOR ISOTHERMAL PLAN & OEV COMM IPOBOX841 RUTHERFORDTON NC 28139
EXECUTM; DIRtCTOR I CENTRALINA COU~C"-OF GOVT 11 Ct:AROLOTTETOWN CNT. (box35008 CHARLOTTE 1..., 28235
EXECUTIVE DIRECTOR LAND-OF-SKY REGIONAL COUNCIL t 25 HERITAGE DRIVE ASHEVlLLE NC 28800
EXECUTIVE DIRECTOR TRIANGLE J COUNCIL OF GOVT PO BOX 12276 RTP NC 27709
EXECUTIVE DIRECTOR l wESTERN PIEDMOt ff COUNCIL GO\/T I P.O BOX 9026 lttlCK(lRV l l >C 28503
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EXECUTIVE DIRECTOR =-------,-;;..,. -CLEAt'. WATER FUND OF NC PO BOX 1008 ~A.l EI~ IIC I 27602
FELDI, USAA POYNER & SPRUILL I Po BOX 10096 RALEIGH NC 27605
FERGUSON, LARRY 15129 MELBOURNE RD. RALEIGti NC 27606
FERRELL, GLORIA us~ 3916 SUNSET ROAD RALEIGH IIIC 27607
FINCH, HELEN THARRINGTON SMITH & HARGROVE Ip O BOX 1151 "-'-1.Elc.<l NC 27602
FITZGERALD, PAUL DUKE POWER CO 13339 HAGERS FERRY RO HUNTERSVILLE lnc 280i8
FLINTON, GEORGE ENVIRONMENTAL CONSTRUCTIOIJ P. 0. BOX 703 I MATTHEWS NC I 28106
FLOYD, J MICHAEL MCCALL BROTHERS INC PO BOX668710 CHARLOTTE INc 28266
FLYNN, LINDA S ENVIR SPEC OMNI PROFESSIONALS PO BOX 13404 IRTP NC 27709
FORBES, BOB CH2M Hill, INC 4624 PARKWiA.Y PLAZA BLVD. SU!T,~ 200 CHARLOTTE ~c 28217
FORTUNE, MAURICE IR R DONNELLEY 8, SONS co 3075 HIGHLAND PKWY. I DOWNERS GROVE IL I 60515
FOSTER, GARY CITY OF WILMINGTON -HOUSiNG AUTHORITY DRAWER 899 l w1LMINGTON I Ne 28402
FOWLER, WILL B. 3797H\f./Y24 NEWPORT NC 28570
FREEMAN, FRANKLIN GOVERNOR'S OFFICE 116 WEST Jet JES ST RALEIGH NC 27603
GABBARD, WILLIAM O PRESIDENT GABBARD ENVIRONMENTAL SERVICE 7611 HOPE FARM RD FORT WA YUE IN 45815
GAINES, JOSEPH L. TRIGON ENGINEERING CONSULTANTS, INC. 6200 HARRIS TECHNOLOGY Bl VD. -lcHARLOTTE 1,,c 26269
GAUJHER, ESTHER ---------, 309 CARL AUSTIN ROAD STATESVILLE NC 28677
GARDNER, CHARLES H ENR-DIVISION LAND RESOURCES -INTEROFFICE
GARNER, MARVIN E ASSOCIATE RIVERS & ASSOCIATES INC PO BOX929 I GREENVILLE INc I 27834
GARRISON, JACK BENZINGER AND GARRISON ENVIRONMENTAL P.O. BOC 14609 RTP NC 27709
GELBLUM, ROB NC ATTORNEY GENERALS OFFICE f P.O. BOX 629 RALEIGH NC 27602
GHEESLING, FRANK IERM -SOUTHEAST INC 300 CHASTAIN CNTR BLVD STE 375 KENNESAW GA 30144
GILBERT, NEIL 9416 BELMONT LANE MARVIN NC I 28173
GILLESPIE, ARTHURS ENV MGR LITHIUM CORP OF AMERICA PO BOX 795 I BESSEMER CITY INc I 28016
GIVENS, GEORGE F GENERAL COUNC NC GENERAL ASSEMBLY-ERC 545 STATE LEGISLA.TIVE BUILOJNG )RALEIGH UC 27611
GLEN, SAMUEL 726 EVERETT ROAD PISGAH FOREST NC 28768
GODDARD, GREG WILSON COUNTY COMMISSION 11110 KINGSWOOD RD WILSON NC 27893
GOKEL, DEAN GEOCHEMINC 2500 GATEWAYCENTRE BLVD ST 300 I MORRISVILLE INc I 27560
aoo m itAN", 11;0 A lt<,\/100< 3600-G WOODPARK BLVD CHARLOTTE NC I 28200
GOODRICH, 0 A I ENR/DWQ/NPOES GROUP ltlTEROFFICE
GOODWIN,C L I EASTMAN CHEMICAL CO PO BOX 1993 FANB-4 I KINGSPORT TN 37652
GRABER, WENDY I 2203 WHITLEY DRIVE DURHAM NC 27707
GRADY, JOHN D JR PE PO BOX762 GOLDSBORO NC 27533
GRAHAM, LARRV ENVIRONM:'.:NTAL ENGINEER!NG SERVICES P.O. BOX 4:26 ABERDEEN NC 28315
GRANTSTAFF, JEANIE FROEHLITJG & ROBERTSON POBOX27524 I RICHMOND VA 23261
GRASER,LEE Irv. A. WT8C-K 400 SUMMIT HILL DR KNOXVILLE TN 37902
GRAVES, DAVID M PH.D CHEMICAL & ENVIRONMENTAL TECH ] PO BOX 12298 RTP NC I 27709
GRAVES, DAVID M I CAROLINA ENVIRONMENT AL LABS 1229 NORTH HORNER BLVD. SANFORD NC 27330
GREER, BILL N.CPECA 2953 TERRY LANE MARIETTA IGA I 30064
GRESHAM, ROBERT E SERVICE DISTRIBUTING CO INC POBOX310 ALBEMARLE INc 28001
GROVER, RACHEL I DWM-HAZARDOUS WASTE SECTION INTEROFFICE-OBERLIN ROAD
GRUBBS, R HOWARD i woMBLE CARLYLE SArl0RIDGE&RIC[ DRAWER 84 1600 ONE TRIAD PK WINSTON-SALEM INc 27102
GUSSMAN, ROBERT J DIR ENV AH ECUSTA POBDX200 PISGAH FOREST NC 28768
HACKMAN, EDWARD B. (vp & gm) HOECHST CELANESE CORP. 4600 HYW 421 N, PO BOX 327 WILMINGTON NC 28402
HAGER, HAMP PETROLEUM WORLD INC IP O BOX307 CLIFFSIDE NC 28024
HALE, BETSY KILPATRICK ANO CODY 1100 PEACHTREE ST ATLANTA GA 30309
HALL, DAPHNE l cDM 8140 WALNUT HILL LANE l □ALLAS lrx I 75231
HALLMAN. GLEN 3177 HOLLYHILL CIRCLE VALDESE NC 28690
HARDIN, CHRISTOPHER 0., GEO-ENVIRONMENiAL CONSt;;.. TANTS. INC. 11704 REAMES ROAD lcHARLOTTE NC I 28269
HARDIN, STEVE U.SGS 3916 SUNSET RIDGE RD. !RALEIGH NC 2760i
HARRISON, PAT CSX TRANSPORTATION 1590 MARIETTA BOULEVARD, N.W., !ATLANTA GA 30318
HANSON, AF ENVIR CONTROL ENGR l ouTBOARD MARINE CORPORATION [ 100 SEAHORSE DRIVE WAUKEGAN IIL I 60085
HARBAUGH, OR. KAREN F KOSA (KFH-99-48) P.O. BOX327 lw1LMINGTON INc 28401
HARDISON, ALLAN COASTAL REGIONAL SOLID WASTE MGMT. AUTHORITY P.O. BOX 128 COVEC!TY INc I 28523
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HARO't,JAN ENVIRONMENTAL SERVICES lf.lCCRPORATEO 1100 WAKE FOREST ROAD, SUITE 200 I RALEIGH NC 27604
HARRILL, FREDDIE BLUC RiDGE ENV SERViCES INC 406 BEAUMONDE AVE SHCLBY NC 28150
HARRIS, SUSAN GROUNDVVATER PROr-CSS!ONALS OF NC JP.O. BOX 28052 RALEIGH I NC 27611
HARRIS, VERNON O JR PRESIDENT COLONIAL ENGINEERiNG INC PO BOX 97005 RALEIGH NC 27624
HART, RON TERMINAL MANAGER SPRAGUE ENERGY CORP 1002 S FRONT ST WILMlrlGTON NC 2B401
HARWOOD, JOE E louKc POWER coM?Ar-JY -422 S CHURCH STREET PBOSO CHARLOTTE 11,c I 28242
HA VWORTH, DANA R ENVIRONMENTAL COMPLIANCE CONS 9715 LITTLE RIVER COURT MATTHEWS NC I 28105
HENSLEY, LON E. WARRENS CREEK RD. 15 COUNDTRY PLACE PARK CHf\.NDLER NC 28715
HENSLEY. KEN HENSLEY'S \'VELL DRILLING I RT 1 BOX 62-G CLARKSVILLE VA 23927
HICKS, TERESA lwlOORE & V/J.1,4 ALLEN IP O BOX 265!)7 RALEIGH NC I 27611
HILL, JOHN TRIANGLE E!NIRONMENTAL P.O. BOX-41087 RALEIGH NC 27629
HINSON, THOMAS H. CPEC 1103 POOLE DRIVE GA.~NER NC I 27529
tHTE. J[5SE'" G. GANNETT FLEMING COROORY & CARPENTER, INC.. la01 s. McDOWELL STREET. surrE 914 CHARLOTTE NC 2820<
HOBGOOD, KIM HUNTOl i & WILL.WAS P.O.80X109 RALEIGH NC I 27602
HOt..BROOt<, TIMOTHY B ENGINEER SECOR INTERNATIONAL 355 UNION BLVD., SUITE 200 LAKEWOOD co 80228
HOLLOWAV, LARRV BFI l 8607 ROBERTS DR SUITE 100 ATLANTA IGA 30350
HOLTON, MARGARET NATURAL RESOUR -LEAGUE OF WOMEN VOTERS OF NC 411 HOLLY LANE CHAPEL HILL NC 27514
HOOD,ALVIN IPOLYMASK 5340 QUEENS CIRCLE ROAD HICKORY I NC 28602
HORTON, GERALD W PE DSA DESIGN GROUP 5511 CAPITAL CENTER DR S-P100 RALEIGH NC 27605
HOWARD, WILLIAM R J REYNOLDS TOBACCO CO PO BOX2959 WINSTON.SALEM NC 27102
HOWELL, THOMAS C Ill RIVERS &ASSOCIATES POBOX929 GREENVILLE NC 27835
HUBBARD, MICHAEL WATTORNEV SMITH ANDERSON ET AL PO 80X2611 RALEIGH NC I 27602
HUFFMAN, RENA ENV COORO KEMET ELECTRON\CS CORPORATION 1Pa 80X242B SHELBY NC I 28150
HUME, HALD KAYSER ROTH HOSIERY INC POBOX7707i GREENSBORO NC 27407
IWERKS, HARVEY M S H & E MGR ICI AMERICAS It lC I PO BOX530 I FAYETTEVILLE NC I 28302
JACOGS,AMV SPANGLER ENVIRONMENT AL CONSULTANTS, INC. P.O. BOX387 !RALEIGH NC I 27602
JACKSON, GLEN PO BOX 86 !TEACHE Y NC 211464
JACKSON , NANCY !OGDEN ENVIRONMENTAL & ENGINEERING SERV INC !P.O. BOX 3142 I HUNTERSVILLE t•C 28070
JAIN, ASKOK K REG MGR NCASt PO BOX 14 1020 GAINESVILLE FL 32614
JANES, DEBORAH A. US EPA MAIL DROP 5 RESEARCH TRI Pl/. "" 27711
JESTER, JON IJARRETT BAY BOAiWORKS 530 SENSATION WEIGH BEAUFORT NC I 28516
JENNINGS , MARK FOAM DESIGN INC., 2425 S. ALSTON AVENUE DURHAM NC 27713
JERNIGAN. CONNIE H. WILSON COUNTY COOPERATIVE EXTEl'JSlON SE!lV1CE P.O. BOX 3027 WILSON NC 27895
JESNICK, CHARLOTTE DIV. OF SOLID & HAZARDOUS WASTE P.O. BOX 27687 RALEIGH NC 27611
JOH, LARRY ARTERVA SPECIAL TIES (S.a.r.l.) PO BOX.327 I WILMINGTON NC I 28402
JOHNSON, GIL CITY OF RALEIGH CONST MGMT PO BOX 590 RALEIGH NC 27602
JONES, MICHELE ELECTRO GAU.ERV 24 HAY'-NARD DRIVE i suRRY NH 3<31
KALBERER, WILLIAM A STAR ENTERPRISE P080X45S2 ATLANTA I GA 30302
KARLAWISH, KEITH B B & T LOAN SERVICE PO BOX 1847 WILSON NC 27894
KELLY, JAMES E PETROLEUM ENV!RONMENT>i. CONSU PO BOX 26413 CHARLOTTE NC 28221
KELLY.JIM OMN l PROFESSIONALS P.O. BOX 13404 RTP NC I 27709
KETCHUM, MICHAEL L MONSANTO COMPANY 3175 LENOX PARK BLVD., SUITE 110 MEMPHIS TN 38115
KILPATRICK, JERRY O CHEMIST EMERSON ELEC CO I MURPHY NC 28906
KING, SUSAN R NEUSE RIVER FOUNDATION PO BOX 15451 NEWBERN t>C 28561
KLIMEK, ALAN CHIEF I DIVISION OF AIR QUALITY ARCHDALE BLOG 8TH FLOOR INTEROFFICE
_,_ .l 1
•U,INGMAN, ROSS BUXTON ENVIRONMENT AL P.O. BOX 11550 CHARLOTTE l,.c 28220
KNIGHT, JEFF 2501 WESTMORELAND DRIVE GREENSBORO NC 27408
KRUG, LISA SPECIALIZED MARINE INC 837 SUNNYVALE DR WILMINGTON NC I 28412
KUCHNIA, JOHN BLOG SYSTEMS ENG DEPT OF PUBLIC INSTRUCTION 301 N WILMINGTON EDUCATION 8LO INTEROFFICE
KUNEFF, TERRY CIVIL ENGINEER HAYES SEAY MATTERtJ &MATTERN 2300 W MEADOWVIEW DR SUITE 110 GREENSBORO NC I 27-407
KUSZAJ, DR JAMES M OGLETREE LAW FIRM POBOX31608 RALEIGH NC 27622
KWIATKOWSKI, D P I E~:OGERTON ENV SERVICE INC 2200 GATEWAY BLVD SUITE 205 MORRISVILLE lri ~ 27560
LABAOORF, KATE looOEN ENVIRONMENTAL = P .O . BOX# 3142 HLIITTERSVul .E -INC 28070 -
LAKE,ALANS lo1veNs CORNING FIBERGlASS TOWER TOLEDO OH I 43659
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lAMB,ALLEN ' I LAMB INDUSTRIAL CONSULTANTS P090X638 LUMBERTON j Nc 28359
LANO QUALITY REGIONAL ENGINEER jENR \"!ASHINGTO!'! REGIONAL OFFIC:: COUR;ER01-74-29
LANO QUALITY REGIONAL ENGINEER ENR WILMINGTON REGIO!JAL OFFIC : COURIER04-16-33
LANO QUALITY REGIONAL ENGINEER JeNR RALEIGH REGIONAL OFFICE INTEROFFICE I
LANO QUALITY REGIONAL ENGINEER ENR FAYETTEVILLE REGIONAL OFFICE COURIER14--5S-25
LAND QUALITY REGIONAL ENGINEER ENR V.JINSTON SALEM REGION.AJ. Ort· .;E COURiCR09-27-46 I
LANO QUALITY REGIONAL ENGINEER EIIR -MOCRESViLLE REG'.ONAL Off!C-:: --COURIER13-21-07 I I
LANO QUALITY REGIONAL ENGINEER ENR ASHEVILLE REGIONAL OFFICE -COURIER00-78~6 I
LAS ATER , Eb -I soYLE CONSULT ANTS 307-T WEST TREMONT -CHAP.LOTTE Jr& I 28203 ---
LAWRENCE, JAMES EMCO WHEATON lt!C.-RETAIL OIV. 2300 INOUSTRiAL PARK OR. WILSON NC 27893
LAYMON, LEE M10-ATlANT1C ASSOCIATES 1310-H CORPORATION PAAKWAY RALEIGH NC 27610
LAZZARA, LYNN SOIL SOLUTIONS 1703 VARGRAVE ST WINSTON-SALEM NC I 27107
LAZ~HADOERTON, MATTY 223 TWIN OAKS PLACE CARY INC 27511
LEE, CLIFFORD El DUPONT CO PO BOX BOO KINSTON INc I 28501
LeE, DENNIS 5221 FIELDSTONE DR RALEIGH NC 27609
LEE, TOM NEWsm.-, GRAHAM .. .... ECETERA, ECETERA P.O.BOX 51579 DURHAM NC 27702
LEINBACH, CHAD CONNER CONSULTING, LL.C. 1284 WINDY RIDGE ROAD l cHAPEL Hill NC 27514
LEWIS, RONALD COUNTY MANAGER UNION COUNTY POBOX21B MONROE NC I 28111
LEWIS, TERESA R CPT (USAF) USAF 4MG/SGPB 1855 WRIGHT AVE SJAFS S JOHNSON AFB NC 27531
UMARtA t,1 ....=----ENR LIBRARY !ARCHDALE BLDG., 7TH FLOOR -INTEROFFICE
LIEPE, OR. PAUL EDISON ELECTRICAL INSTITUTE (GHPC, INC) 701 PENNSYLVANIA AVENUE, NW WASHINGTON DC I 2000<
LITTLE, J MAC!< LITTLE & LITTLE LANDSCAPE ARC PO SOX 1448 RALEIGH NC 27602
LITTLE, LINDA W I 5000 HERMITAGE ORIVE RALEIGH NC 27612
LIVELY, LAWRENCE st.111THFIELO FOODS INC PO B0."'.447 SMITHFIELD VA 23,430
LLOVD, DAVIDE NEPTCO Jpo BOX2323 PAWTUCKET RI 2861
LOEB, CHRISTOPHER W I ROBiNSON BRADSHAW & HINTON 1900 INOEPENDCNCE CC:NTER CHARLOTTE It<: 28246
LONG, JOHN R GRAHAM HEDRICK KENNON & Ct-EEK PO BOX51579 OURHAM NC 27717
LOVOAHL, STACY ARCAOtS GERAGHTY & MILLER 2846 PLAZA PL.ACE RALEIGH I Nc 27512
LOVEDRLL. CHRJS GERAGHTY & MILLER INC 2840 PlAZA PLACE SUITE 350 RALEIGH NC 27612
LOWDER.WES S&ME ltlC 44 BUCK SHOALS RD UNIT ~ ARDEN INC 28704
LOWER,RICH DELTA ENVIRONMENTAL 6701 CARMEL ROAD, SUITE 200 CHARLOTTE 1,ic 2822S
LOWENKRON, LARRY NESTE RESINS PO BOX270 SPRINGFIELD OR I 97477
LUCAS, STEVE I 640 BELLMORROW DRIVE CHAP.LOTTE ,~ 28214
MAGEE, AMELIA S -I KING ANO SPALDING 191 PEACHTREE STREET ATLArJTA GA I 30303
MALLORY, NEIL KERR-TAR REGIOIJAL COU:JCIL GVT PO BOX 7~9 HENDERSON j NC 27536
MARTI1', ROBERT OGDEN ENVIRONMENTAL & ENGINEERING SERV INC. leo oon,1, HUNTERSVILLE NC I 28070
MARROW, THOMAS S. ( ictty mgr.) I CITY OF OXFORD 300 WILUAMSBORO ST, PO BOX 1307 OXFORD NC 27565
MARSHALL, H. TILLMAN APPLIED GEOSC!ENCES & ENGINEERING 405-A PAAKWAY OR \GREENSBORO NC I 27401
MASON, STEVE CHEROKEE ENVIRONMENTAL GROUP 1600 COLON ROAD SANFORD NC 27330
MATSON, KRIS N. C. S. U. (Biological & Agri. Engineering) BOX 7625 RALEIGH w. 27695
MATTHEWS , JOE C NORTHV'JEST PEIOMONT COUNCIL 400 WEST FOURrrt ST. 1w1NSTON-SA!.EM NC 27101
MA YES, BRETT SUITE 301 j ENVIRONMENTAL MATERiALS INC 9900 N CFNTRAL EXPRCSSWAY DAUAS TX 75231
MAYOR TOWN OF PINE KNOLL SHORES 100 MUNICIPAL CIRCLE PINE KNOLL SHORES NC I 28512
MCALISTER, ERIC C ENV CONTACT PROCTER & GAMBLE MFG 6200 BRYAN PARK ROAD BROWNS SUMMll NC 27214
MCBRIDE, FRANK T ., MANAGER N.C. WILDLIFE RESOURCES COMMISSION 1142 , 1-85 SERVICE ROAD CREEDMOOR NC 27522
MCCALL, GARMON C MCCALL BROTHERS INC 6700 BELHAVEN BLVD CHARLOTTE r;e .......J 28216
MeC ONW!LL, ;AME$ 0 . 14525 BLACK FARMS ROAD HUNTERSVILLE I-IC 1 28078
McO E'.Vfn I WA 't~IE ENrl ARCHDALE BLDG INTEROFFICE I •
MCFARLANE, BRUCE C GROUP COORD KOHLER CO MAIL STOP 203 444 HJGHLAf !D DRIVE KOHLER WI 53044
MCKEEMAN, CHRIS NESTE RESINS lrso CORINTH ROA □ MONCURE NC I 27559
MCKEON, JOSEPH BASF CORPORATION 3000 CONTINENTIAL OR!VE r JORTH MT. OLIVE [NJ 7828
MCKINNEY, JOE C MITCHELL COUNTY ~ PO BOX409 BAKERSVILLE NC 28705
MCLAUGHLIN, DR RICHARD N<;S U 80t 761 9 -t>C&U BAL~•G>l -I Nc 27695
MCLAWHORN, JAMES NORTH CAROLINA UTILITIES COMMISSIO~ I-PUBLIC STAFF INTEROFFICE
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MCNAUGHT, DAVID PAMLICO-TAR RIVER FOUNDATION PO BOX 1854 WASHINGTON NC 27889
MCNULTY, JOSEPH F TUGGLE OUGGINS MESCHAt!& CLRor· IP a DRA\111:R x GRCENSBORO NC 27◄02
MCSLOY, KEVIN METROMONT PRESTRESS CO. P.O. BOX 2466 GREENVILLE SC 2W02
MEAD, HELEN OMAHA OISTRiCT CORP OF ENGRS 215 N 17TH ST OMAHA NE 68102
MEOWITH, BERNARD W UNION CAMP CORPORATION PO BOX 525B ASHEVlLLE NC 28813
MEEKS, ELMO NACCO MATERIALS 1-l.ANOLING GROt..:.' 1N.:. 2040 MORGANTON BLVD LENOIR NC 28545
MEYDEN, HENK J VANOER ALCOA PO Box 576 BAD IN NC 28009
MILES, JERRY NESCO INC PO BOX234 MONROE NC 28110
MILLER, JAMES B . \DUKE POWER COMPANY (EC13K) 526 S. CHURCH STREET !CHARLOTTE !IC I 28201
MILLER, TODD EXEC DIR NC COAST Al FEOERA Ti ON 3609 HIGHWAY 2< NEWPORT NC 28570
MINOCK, LARRY IDEOIC8 &CP PO BOX 10009 RICHMOND VA I 23240
MINOR, EDWARD C ASSOC GEN COUN IUNION CAMP CORP FRANKLIN VA 23851
MOORE, GARY W JR RESEARCH ENG INSTITUTE OF TEXTILE TECHNOLOGY 2551 IVY ROAD CHARLOTTESVILLE VA 22903
MOORE,JIM I PO BOX 71788 ALBANY GA 31707
MOORE, STEPHEN 1111 MO 4010 BARRETT DR SUITE 104 !RALEIGH NC 27609
MOORMAN, WC JR ECONOMIC OEVELO REGION K COU.\ICIL OF GOVERNMNT PO BOX 709 HENDERSON NC 27536
M()ij!S..,!<, r,<ARTY ENR-OWM-HAZARDOUS WASTE SECT ION INTEROFFICE COURIER# 52-01-r.'O
-
MARION DAN CH2M HILL, INC 4824 PARKWAY PlAZA BLVD. sui1e 200 CHARLOTTE NC 28217
MORRIS, BILL ROY F WESTON INC 1000 PERIMETER PARK OR SUITE E MORRISVILLE NC 27560
MOSER, CHARLIE DRILLERS SERVICE INC P O DRAWER 1407 HICKORY I NC 28603
MUNDY, WALTER T MGR SE& PE GENERAL ELECTRIC CO POBOX21B8 HICKORY NC 28603
MUROAN, MARK C. LAW ENGINERRING PO BOX 11297 ..._ -,;; CHARLOTT£:. --=--NC 28220
MUROOC~, JOHN C IJSA.CC IPOBOX-'128 . c~ORO NC 28020 ..
MURPHY, LESTER S AVIATION FUEL TERMINALS INC 296 RADIO ISLAND RO BEAUFORT NC 28516
MURPHY, MARK R CS>< TRANSPORTATION INC 500 WATER STREET JACKSONVILLE FL I 32202
MURRAY, MARY CATHERINE . OGDEN ENVIRONMENTAL AND ENGIN.:ERING SERVICES 9800 W, KINCEY AVE. SUITE 190 HUNTERSVILLE i'-1' I 28076
MYERS, JERRY 0 ROCKINGHAM COUNTY MANAGER PO BOX206 WENTWORTH NC 27375
NEAL, RONNIE L SR PLANT ENG LIGGETT GROUP INC PO BOX 1572 DURHAM NC I 277fY2
NEFF, B. PAUL I 1471 STONEWOOD COURT !HAMPTON GA 30228
NELSON, FORREST E TriE CAROLINAS READY MIXED CON \1515 MOCKiNGSIRD LANE STE 711 -CHAJ11.o tTli -JNC 28203
NELSON, PERRY )436 CEDAR HILL LANE RALEIGH
-1NC 2760S
NELSON, SUZANNE C KIMBERLY-CLARK CORP 1400 Hot.Cot-AB BRIDGE RD ROSWELL GA I 30076
NESTOR, JOE --NESCO ENVIRONME"ITAL 1 6736 ROCKY FALLS ROAD ~KARLOma -NC 28211
NEWSOME, ANGIE CLEAN WATER FU.JD OF NC 29 AND H2 PAGE AVENUE ASHEVILLE I NC 26801
NIEVES, LUIS A MGR ENV COMP FLORIDA STEEL CORPORA TIOi J IP O BOX 31328 1720 CLEVELAND S TAMPA IFL 33631
NIGHTINGALE, ELLIOT J. =-NGC, P.C. 4722 SHARON ROAD, E-124 CHARLOTTE !'IC I 28210
NOLAND, MICK PVI/C OF FAYETTEVILLE PO BOX 1089 FAYETTEVILLE NC 28-..~2
NORRIS, ROlANO B II ENSR CONSL.:L TING & ENGINEERING 2700 \'\'YCLIFF RO SUITE 300 RALEIGH NC 27607
NCOOA& CS I RESEARCH STATIONS DIVISION NCDA-CHERRY FARM UNIT 201 STEVENS MILL ROAD GOLDBORO NC 27530
OAKLEY, ANDREW A GOLOTEX INC P O BOX 2007 ◄ 01 PATETOWN RD GOLDSBORO NC 27530
PALMER.EC JR ENVIROATTY ENVIRO LAW CDrlSULTING SERVICE 330 PROVIDENCE RD ATHENS GA 30606
PINARD, RAYMOND N. SYNTHRON INCORPORA TEO 1P.O. BOX 11 11, 305AfAHERSTROAD MORGANTON NC :28655
PANTON, ROBERT EXEC DIR !PEE DEE COUNCIL OF GO\/T 302 LEAK STREET ROCKINGHAM NC 28378
PARASCONDOLA, STEVE P.O. BOX 2611 RALEIGH NC 27602
PASTERACK, KEN EDER ASSOCIATES Js1g PLEASANT HOME ROAD, SUITE CJ AUGUSTA GA 30907
PATEL, MANHAR N MONSATO CORP THE AGRICULTURAL PO BOX2307 FAYETTEVIU.E NC 28302
PATTERSON, LISA WILLIAM O OANiEL AND ASSOC 1150 SE MAYNARD RO CARY NC 27511
PARKER, EDWARD E. PELLETIER OIL FACILITY 7511 NEW BERN HWY MAYSVILLE NC 28555
PAYNE, BOB CEDAR ROCK ENVIRONMENTAL SERVICES INC., 807 BULLARO LANE GRAHAM NC 27253
PERRY, SANDY NC ELECTRIC MEMBERSHIP P .O. SOX 27305 RALEIGH NC 27611
PERRY. WlWAM R UNITED METAL RECYCLERS PO BOX 159 KERNERSVILLE NC 27285
PETERSON, DERRICK 3709 TORRO CANYON ROAD AUSTIN T>< 78746
PHILLIPS, TOM S.tATE. BQAF,0 OF El..&.Vil'leRS OF P~Hl. F1'1:E SP. CONTRA CT 3801 WAKE FOREST ROAD, SUITE 201 RALEIGH INC 27609
PIBL,ROMAN SUITE 1700 1700 BROADWAY DENVER lea I 80290
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PJERONI, ANDY R.M.C.i. 2110 NEW MARKET PK\•VY., SUITE 205 I MARIETTA JGA 30067
PLATT, CODY S& ME INCORPORATED 13118 SPRING FOREST ROAD IRALCIGH INc I 27616
POLLOCK, BRUCE C MAJOR USAF OIC USAF OIC BIOENVIRONMENTAL ENG 4MG/SGPB SEYMOUR JOHNSON AFB GOLDSBORO NC 27531
POOLE, NW N W POOLE WELL CO RT 12, BOX 1 . 5801 FARM WELL RD. RALEIGH NC 27610
POWELL, ELIZABETH M SMITH HELMS MG.LISS & MOORE IP O BOX 27525 I RALEIGH INC 27611
POWELL, ROLAND L VICE PRESIDENT DAVIS & FLOYD ltiC P O ORA\iV[R 428 I GREENV-JOOD SC 29548
PROSSER, JERRY ... _~ 1ERM --7300 CARMEL EXECUTIVf: Pl-t<~ SUITE; 200 -<-.,c CHARLOTTE NC 28226
PUSLIC INFORMATION OFFICER lENR-OWO --9TH FLOOR ARCHDALE BUILDlNG ........, ")-INTEROFFICE
RAO(i ft, BO PANTRY (THE) INC PO BOX 1410 SANFORD !Ne 27330
RAGAN, BRAD 1405 JAKE ALEXAt DCR BLVD. WEST SALISBURY NC 2S14i
RAHN, PHIU..IP AQUATERRA, INC., P.O. BOX 37579 RALIEGH INC 27627
RAMSEY I ARNOLD J l o·sRIEN & GERE ENG IP O BOX 80308 RALEIGH NC 27623
RARING, ANDREW M P080X34 BETHANIA NC 27010
RASCOE J PETER 111 NAVY B."i.SE 1510 GILBERT ST !NORFOLK VA I 23511
RA YMONO, BILL ENVIRONMENTAL RESEARCH TECI i 135 NAGOG PARK ACTON MA 1720
READLING, SCOTT TENNECO PACKAG!NG INC., P.O. BOX 1108 WAYNESVILLE INc I 28766
REESE, GERTRUDE ::::J.,,,J;-' 1817 ISLAND FORD ROAD ..,,. STATESVILLE NC 28677
REESE, MARC BEAMAN CORPORATION 6306 OLO 421 ROAD IUBERTY NC 27298
REGA'N ,ED NC ASSOC OF CO COMMISSIONERS (rq eox !•" ~ RALEIGH NC 27602
REGIONAL GROUNDWATER SEC SUPER ENR-OWQ MOORESVILLE REGIONAL OFFICE COURIER13-21-07 I
REGIONAL GROUNDWATER SEC SUPER ENR-DWO WINSTON-SALEM REGIONAL OFFICE COURIEROS-27-46
REGIONAL GROUNDWATER SEC SUPER ENR-DWQ WILMINGTON REGIONAL OFFICE COURIER04-16-33 I I
REGIONAL GROUNDWATER SEC SUPER IENR-DWQ WASH1NGTON REGIONAL OFFICE COURiER01-74-29 I I
REGIONAL GROUNDWATER SEC SUPER I ENR-OWQ ASHEVILLE REGIONAL OFFICE COURIER06-78-16 I I
REGIONAL GROUNDWATER SEC SUPER ENR-OWQ I FAYETTEVILLE REGIONAL OFFICE COURIER14-56-25 I
REGIONAL GROUNDWATER SEC SUPER ENR-DWQ RALEIGH REGIONAL OFFICE I 1NTEROFFICE I
REICH, RICK PETREE-STOCKTON 1001 WEST FOURTH ST. Wl!~STON-SALEM NC I 27101
REYNOLDS, DAVID NC LEAGUE OF MUNICIPALITIES PO BOX3069 RALEIGH NC 27602
REYNOLDS, PETER A !ASHLAND PETROLEUM CCM0 ANY PO BOX 391 ENV.ENG.FACIUTIES !ASHLAND KY I 41114
RHODES. r.nCHll'El. ENR!DEH,EHSS I! JTEROFFICE I
RICHARDSON, HOOD HOOD RICHA.~OSON P A 206 NORTH MARKET STREET WASHINGTON NC 27889
RICHARDSON, 0. L. (VP) -NATIONSBANK TRUST REAL ESTATE {NC1-002-11-13) -CHARLOTTE NC 28255
RIFE, KIRK L TRIGON ENGINEERING CONSULT ANT ~ PO BOX 18846 -GREENSBORO NC 27-419 -
RITCHIE, BARBARA E ENVIRON MGR IFMC CORP LITHIUM DIVISION POBOX795 BESSEMER CITY INc 28016
ROBERTSON, PAMELA M ROCKINGHAM COUNTY CLERK RCBC POBOX206 1wENTWORTH INc 27375
ROBINSON, MICHAEL L MITCHELL COUNTY MANAGER PO BOX409 BAKERSVILLE NC 28705
ROGERS, JAMES A. NACCO MATERIALS HANDLING GROUP , INC. 2040 MORGANTON BLVD., S.W., LENOIR NC I 28645
ROSS, CHARLES CAROLiNA POWER ANO LIGHT POBOX327 INEWHILL NC 27562
ROSS, WILLIAM JR BROOKS LAW FIRM IP O BOX 26000 GREENSBORO NC 27420
ROUSE, B. COMMANDING GENERAL (ATTN: AC!S•EMD/IRO) PSC BOX 20004 CAMP LEJUNE NC 28542
RUOO,KENDR DIV OF EPIDEMliE.ES INTEROFFICE.
RUSSELL, 0 L PRESIDENT ALLEY WILLIAMS CARMEN & KING I Po sox 1110 BURLINGTON NC 27216
SACHS, HARVEY j ErnSON ELECTRICAL INSTITUTE {GHPC, INC) 701 PENNSYLVANIA AVE., N.W. WASHINGTON DC 20004
SAFRIT, DON ENR-DWQ-WQ INTEROFFICE I I I
SAKWA, MICHELE E. ENVIRONMENTAL COMPLIANCE CORP. 1401 -SOUTH MARTIN LUTHER KING JR. DRIVE WINSTON-SALEM NC I
SALAVA, MARGARET B. NCAPHCC, ltiC. 413 GLENWOOD AVENUE RALEIGH NC 27603
SAMPLE, RICHARD lsuRn AIJDAssoc:.ATES 217 HENDERSON DRIVE ~JACKSONVILLE INc I 28540
!iA~FO:Rl'H, MIK E =-EXCEL ENVIRONMENTAL ASSOCIATION I P.O. BOX 6172 ru>"[ONI~ N~ 28056
SHAEFFER, RICK CROWN CENTRAL PETROLEUM IP.O. BOX 1168 BALTIMORE MD 21203
SCHECTER, ROGER DIRECTOR ENR/DIVISION OF COASTAL MGMT COOPER BUILDING INTEROFFICE I
SCHIMMING, WA PCS PHOSPHATE P.O. BOX 30321 RALEIGH NC 27622
SCHMITT, DEANNA L MAUPIN TAYLOR ELLIS &ADAMS PA PO DRAWER 19764 RALEIGH NC I 27619
SCHUMAK, BERN lAW ENGINEERING l2so1 YORKMONT ROAD, SUITE 100 --= CHARLOTTE ~ NC ....., 26208
SECHRIST, RICK IAMPINC IPO BOX3608 I HARRISBURG PA 1i111
Page 9
MAILWGWL.XLS
SETZER. ED LEGACY ENVIRONMENTAL P .0. BOX -4560 GREENSBORO NC I 274C-4
SETZER, STANLEY NC HIGHWAY 10 E lcLAREMONT NC 2861C
SETZER, STANLEY NC GROUNDWATER ASSOCIATION ]POBOX67 TEACHEY INC I 28464
SHALTER, WILLIAM D MGR ENV AFF UNIMINCORP 4000 BAKER ROAD OTTAWA l1L I 61350
SHAFFER, CARL INCSU P.O. BOX 7619, NCSU RALEIGH INc I 27695
SHEFFIELD, FRANK H ATTORNEY I 1001 COLLEGE STRL.~T NEW BERN NC 28563
SHEPHERD, JOHN ENR DIVISION OF FOREST RESOURCES INTEROFFICE
SHERIOAN, WILLIAM 4110-105 SEOGEWOOD DRIVE RALEIGH NC 27612
SHI, J . STEPHEN KILPATR!CK STOCKTON, LPP 1100 PEACHTREE STREET, NW I ATLANTA GA 30309
SHILUOAY, JIM GERAGHTY ANO MILLER 2840 PLAZA PLACE, SUITE 350 RALEIGH NC 27612
SHILLINGTON, THOMAS P E25 3008ANDERSON CR SU ITE 102 RALEIGl i NC 27609
SHIRRON, ROBERT. L. (COLONEL) US ARMY DIRECTOR OF PUBL!C WORKS BUSINESS CENTER FORTSRAGG NC 28307
SHORT,OAN CCA ENViRONMEtlTAl INC. 4324 WHrTETAIL l..A.!':E MIDLAND INC 28107
SIGMON, KENNETH G MCCALL BROTHERS !NC PO BOX668710 -CHARLOml "-'<:: ,,~ .. J I 28265
SIMS, DON ENGINEERING CONSUL TI NG SERV;CES. LDT. I sc DUNDAS CIRCLE GREENSBORO NC 27407
SIMONS, JAMES D OENR-OlV LAND RES LANO QUALi INTEROFF IC E
SINGER, JENNIFER GEOVATION CONSULTANTS 468, ROUTE 17-A, P.O. BOX 293 FLORIDA NY 10921
SLOCUM, ROBERT W JR NC FORESTRY ASSOCIATION 1600 GLENWOOD AVE SUITE I RALEIGH NC I 27608
SMITH, BRENDA COOPER El~V!RONMENTAL 5101 coU:ffRY CLUB ROAD WINSTON -SALEM NC 27104
SMITH, CLIFTON J CONSOLIDATED DIESEL COMPANY PO BOX670 WHITAKERS NC 27891
SMITH, DENISE L ENGINEER TECH NREA DEPT CODE LN FACILITIES DIRECTORATE MCAS CHERRY POINT NC 28533
SMITH, LOUISE EXEC DIR NC ASSr I LAUNDCRERS & CLEANERS j 1043 DRESSER COURT I RALEIGH NC I 27609
SMITH, P J EVP ENV TECHNOLOGY OF N AMERICA I 2229 TOML YN STREE T RICHMOND VA 23230
SMITH, ROBERT K HENDERSON COUNTY HEAL TH DEPT HENDERSONVlll.E COURIER06-92·01
SMOLEN, MD COOPERATIVE EXTENSION SER AGR 214 AGRICULTURAL HALL STILLWATER OK 74078
SONNENBERG, KYLE TO'i.'VN MArJAGER, TOWN OF SOUTHERN PINES I 125 S.E. BROAD STRECT SOUTHER' I PINES NC 28378
SORSA, KRISTI R.M.T. INC .. 744 HEARTLAND TRAIL MADISON WI 53717
SPALT, ALAN DIRECTOR AGRICULTURAL RESOURCES CENTER 11SWMAJNST CARRBORO NC 27510
STALLINGS, LElGH ATTORNEY PO BOX 12347 RALEIGH NC 27605
STAMBAUGH, ROY EXXON COMPA."-'Y USA P.O. BOX 2180, ROOM 2658K HOUSTON TX 1ns2
STANBACK, FRED I 507 WEST INNES, # 270 S11.U$DUl'W -''!"<' 28144
STARR.BETH NATL AFFAIRS INC BUREAU OF 1231 25TH ST NW -ROOM ◄70N WASHINGTON Joc r 20037
STATE DOCUMENTS ASSISTANT
.,....,. ·-!ATKINS, J MURREY LIBRARY -LINC ATCr.ARLOTTE-t.;t!CC STATION CHARLOTTE
~ ,,e r-28223
STENBER, W. J. !REV) ST. JUDE CATHOLIC CHURCH I P.O. BOX 147 GLEti DALE WV I 25038
STEWART, JOHN 2641-G RANDLEMAN ROAD GREENSBORO NC I 27406
STEWART, KEN ECONOMIC ALLIANCE 6435 WESTPORT DRIVE lw1LMINGTON NC 28409
STIMPSON, RICHARD A ENV ENG SHUFORD MILLS INC PO BOX 1530 HICKORY NC 28603
STRILEY, DAVID J MGR ENV AFFRS CHAMPIOtl INTERNATIONAL CORP KNIGHTS BRIDGE DR HAMILTON OH I 45020
STUTTS, JI\CK DELTA EiJVIRONMENTALCONSULTANTS 6701 CARMEL RO , SUITE 200 -CHA.~LOTTE = NC 282"1€
SULLIVAN . PETc'"' OSATANTIC ◄944 PAA.tW/AY PLAZA BLVD., SUITE 195 CHARLOTTE N(; 28217
SULTRICK, KEITH WACHOVIA BANK (# NC 3n51) I 100 N. MAIN STREET WINSTON-SALEM r:c 27150
SUMMERSON, GRAHAM ABACUS CONSUL TING !4126 ll\,lNGSTONE PLACE l ouRHM< NC 27707
SVANDA, RICHARD A PE DIRECTOR JOSTEUS INC 5501 NORMAN CENTER DRIVE MINNEAPOLIS MN 554'37
TENNENT, KEIL.A STRANG-FLETCHER SUITE 400, KRYSTAL BUILDING CHATTANOOGA rn 37402
TANN ER, MARY SHEILD ENVIRONMENTAL d 2848 1-85 SOUTH , SUITE H CHARLOTTE I"': 2B208
TEGLAS, ALEX FACTORY ENBINEER STANLEY FURNITURE CO -$1 STAtlLEYTOWN lvA 24168
TELFER, PHILLIP ENR-OFFICE OF GEN. COUNSEL INTEROFFICE
TEW.BRANT ENVIRONMENTAL INVESTIGATIONS 2327 ENGELERT DR. . SUITE 1 DURHAM NC 27713
THOMAS. PAULI'-S ENVPOLSPEC N C LEAGUE OF MUNICIPALITIES IPOBOX3069 RALEIGH I "<: 27602
THOMAS, STEVEN D SAFETY ENG BEAMAN CORP OLD HIGHWAY 421 NORTH !LIBERTY 'N, 27298
THOMPSON, OALE R 1007 DREXEL H;LLS BLVD NEW CUMBERLAND PA 17070
THOMPSON, MIKE IENR FOREST RESOURCES INTEROFFICE
TRIMBURGER. KAREN GROUNDWATER TECHNOLOGY 1000 PERIMETER PARK DR, SUITE I MORRISVILLE NC 27560
TUCKER , ROBERT E ASSIST CO ENG WAKE COUNTY C O S PO BOX550 !RALEIGH NC 27502
Page 10
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TURLINGT ON, JEFF ROUTE 1. P.O. BOY ~~7 COATS tlC 27521
TYLER, NANCY SCOTT -LEVIN ASSOC IA TES INC 60 BLACKSMITH R0.4.:-J NEWTQ\,",1 N PA 18940
TYNAN, MIKE PROBE TECI ~NOLOGIES, Ii .iC P. 0 . BOX 1369 CONCORD NC 26206
UEBLER, ROBERT L M 0 OHS WP..SHINGTON REGIGNAL OFFICE COURIER0; · 74-29
UNDERWOOD, GEOFF G.T.I. P.O. BOX 1077 DENVER NC 2803:7
Ul EC.K , JOHt-i 'IG& E Et-..lGINr:E:~ING ~ '----4105-C STUART AN!' ~EW BLVD ---CHARL01 · -INC 28217
VANBUREN, CAROL JONES e-= lKEN '..!EDY COViNGTOfl LOBlh"LL&HiC -SUITS: 4200 100 r. T!'YON ST -CHARLOi ~ !NC I 28202
VAN EC!<, WI IAEl,I A 1702 KILARNEY DR. lcARY NC 27511
VANDERMEYOEN, HJ ALCOA PO 80X576 BADlN NG 28009
VAUGHAN, MIKE WATER TECHUOLOGY AND CONTROLS INC. 642 TA~CO ROAD REIOSVILl.'.::. INC 27320
VAUGHAN, ROLAND H., MAYOR !rowN OF EDENTOI J P.O. BOX300 EOENTQl,1 NC I 27932
VETTER, RICK MOORE & VAN ALLEN I PLLC P.O. BOX 25507 I RALEIGH NC I 27611
VOIGHT, VICTOlllA L ASST AG 08'JR -SUPERFUND PRQl""~M . ◄0i OBER LI N RD ?OBOX 2 7687 ' -INTER0ff1CE __j
WAHAB, ALLEN OWQ/CONSTRUCTION GRA.'lTS &LOAN fl'ITEROFFICE
WAHEEOUL, HAQ TERRA TEST INC PO BOX 52155 RALEIGH NC 27612
WAINER, NANCY L LITTLE & LITTLE PO BOX 1448 RALEIG; I NC 27602
WAITE, MARJOHY A HEAD ACQ Uf\lC HEALTH SCIENCES LIBRARY Clii'758Si CHAPEL HILL JIC I 27509
WALDEN, DERRYL ENR FOREST RESOURCES 1NttR0""1 E
WALLER, MARTi"iA J ~ -PAAKER POE ADAMS & BERNSTINE ~ ~ 2500 CHARLOTTE PLAZA CHARLOTTr I«; 26244
WALLER, MART'f 2600 CHARLOTTE PLAZA --
CHARLOTTE JIC I 28244
WALTER, JERRY EXECUTIVE DIR CAPE FEAR COUNCIL OF GCVT 1-480 HARBOUR DRIVE WILMINGTON NC I 26401
WALTERS, JIM DIR ENV AFFAIRS lwesr POINT-PEPPERELL INC PO SOX 1347 LUMBERTON NC 28358
WALTON, RONALD N ENV SUPERVISOR CAPE INOUSTRlES PO BOX 327 WILMll :GTON NC 28402
WALTON, ROBERT UNC-CH HEAL TH & SAFETY 2121 FINLEY GOLF COURSE RO . CHAPEL-HILL NC 27514
WARD, DON VICE CHAIRMAN ------NC PETROLEUM MARKETERS ASSOC IP O BOX 30519 _.,., ___ RALEIGH NC 27622
WARD, MARVfN S -'CAROLINA. READY YIX COt.JCRC.TE 15'15 MOCKINGBiRD · ;; S l E 711 -CHARlOTTEl _,--IN<; 28209
\"IM~ER, SO NYA ECS l s..c DUNDAS CIRCLE -GREENS60 HO INC 2740{
W!AR, DR. JOH -.I j CATAWBA COLL.EGE-DIR CENTER FOR THE ENVIRONMENT 2300 '/./EST INNES STREET SALISBURY = INC I ::e,44
WEA THERSPOCN, 1.VILUAM H NC PEiROlEUM COUNCIL 150 FAYETTEVILLE MALL STE 2850 ~ -RALEIGH NC 27601
WEBER, STEVEN D PARKER POE ADAMS & BERNSTEIN f25oo Ct--t.ARLOTTE Pi..AZA ~ CHARLOTTE. INC 28244
WEEK, OMEGA P El<!\/ COORDINATOR USAF POPE AFB 317 SPTG/OEV POPE AFB INC I 263C6
WEINSOFF, DA\ID TOUCHSTONE ENVIRONMENTAL INC 449 15TH ST SUITE 301 OAKLAND CA 94612
WEST, JASON HSI GEOTRANS 1080 HOLCOMB BR[OGE RD .. BOLG 100-SUITE 190 ROSWELL GA 300i6
WEST, SUSAN B NC FISHERIES ASSOCIATION PO BOX 183 BOXTON NC I 27920
WHALEY, CHARLIE INGERSOLL~RAND COMPA.\IY 501 SANFORD AVENUE j MOCKS\/ILLE NC 27028
WHITAKER, TONY M. CIVIL CONSULTANTS INC. 3622 LYCKAN PKWY. , SUITE 3003 DURHAM NC I 27707
WHITE, GINNY FAYETTEVILLE OBSERVER-TIMES 458 WHITEFIELD STREET, P.O. BOX 84Q I FAYETTEVILLE NC I 28302
WHITE,KENT AOUATERRA 4901 WATERS EDGE DRIVE RALEIGH NC I 2i606
WHITE, STANFORD I P.O. DRAWER 1447 NAGStiEAO NC I 27957
WHITENAEUfi, STEVE STATE CONSTRUCTION OFFICE 301 N. WILMINGTON STREET SUITE 450 RALEIGH NC I 27601
WHITESIDE, RANDY W ARCHER DANIELS MIOl.AM) CO 1730 EAST t,.IDQRE STREET., s.e., SOUTHPORT tlC I 28461
WHITESIDE, STEPHEN L VP GEi CONSULT ANTS INC 7n1 SIX FORKS ROAD SUITE 13S RALEIGH NC 27615
WHITMAN, G,C, PACE ANALYTICAL laeoo '<IUCEY AVENUE, SUITE ,co HUNTERSV ILLE ,x: 26078
~
WILLIAMS, DR. LUANNE DIV. OF EPIDEMIOLOGY INTEROFFICE
WILLIAMS, K WAYNE GREAT SMOKEY MTNS NATL PARK 107 PARK HEADQUARTERS RD GATLINBURG TN 37738
WILLIAMS, TEG CH2M HILL. INC 4824 PARKWAY BOULEVARD CHARLOTTE ,,c 28217
WILKES, scoTr NESCO, INC P.O. BOX 234 MONROE "" I 28110
WILMS . R PAUL NC HOME BUILDERS ASSOCIATION PO BOX 12166 RAL£1 Grl i.c I 27605
WILSON, LESLEY HAY BP OIL COMPANY ENV RESOURCES LAKEVIEW 400, 2555 WESTSIDE PKWY, SUITE 300 #1600 ALPHARETTA GA 30201
WIN KLER, JOAM R & A ENVIRONMENTAL 1114 BRUSH ROAS GRE:::::NBORO !Ne 2740Q
WIRTH, GARY N. 1614 TIPPAH AVENUE CHJ!i,RL.OTTE l><e 28205
WOLF->iALL, SUSAN ENVIRONMENTAL SYSTEMS CORPORATION 200 TECH CENTER DR IVE KNOXVILLE TN 37912
WOLFE, OAV10 AWARE ENVIRONMENTAL 9305 . J MONROE. ROAD CHARLOTTE • NC 26270
WOOD, BOB M.GR E.NV AFFAIRS LEXINGTON FURNITURE IND P080X 1006 Lc.XINGTON NC I 27293
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WRIGHT, I. CLA RKE, jr WAAO & SMITH PA PO BOX867 NEWBEP..N NC I 28563
WRIGHT, Kl!:N DIXI E. YARNS, If.JC p 0 oq,; ,(.-.i ~tO,N-1,4 NC 28053
WRIGHTS, JANET P:o. BOX 1060 CC,,::'LEE MtE NC I 27014
WU, .ITS A.SSOClATE PROF l uN1v OF NC AT cHA.qt.orrE DEPT c1v1;,_ EN',;, UNCC CHA~H.OTTE tlC 28223
ZABEL. PEGGY RMTINC PO BOX 1!!iflr GREENVILLE SC 29606
ZHAO, JOHN METROPOLITAN LABS 2500 ALMCDA AVr. SUITE: 102 NORF"ORK VA 23513
ZODROW, CHRISTOPHER N \.".JEST POINT-PEPPERELL INC POBOX71 WESTPO;NT GA 31833
S&MEINC 44 BUCK SHOALS ROAD UNIT G-9 ARDEN NC I 28704
lcMSD POBOX4;? GRIFTON NC 28530
ASMO NORTH CAROLINA INC 4 70 CRAWFORD RD { GT;; TI b\lU,L( NC 28677
AUTUMN HOUSE INC 1206 PREMIER[. RO GRANITE FALLS NC 28630
USAF USAF CUNIC/SGPM POPE AFB NC 28308
NC PUBLIC HEAL TH ASSOC 1009 DRESSER COURT RALEIGH 1,:c 27609
NC HOME BUILDERS ASSOC 1303 ANNAPOLIS OR RALCIGH NC '27608
CARGILL, INC NUTRENA FEED DIV PO BOX 3899 WILSON NC 27895
JACKSON PAPER MANFACTURING CO . POBOX667 SYI.VIA NC 28779
JEFFCO INC 5269 US H\'\'Y 158 ADVANCE NC 27006
iGRANUTEC lt!C 4409 tm AIRPORT DRIVE W ILSON NC 27896
10AN!EL WILLIAM G & ASSOC 1150 SE MAYNARD RD CARY NC I 275 11
I CAROLINA ENVIRONMENTAL LABS 1229 N HORNER BLVD !SANFORD NC I 27330
ITENNESSEE VALLEY AUTHORITY 400 W SUMMI T HILL OR ET-9H 1KNOXVILLE TN 37902
KO & ASSOCIATES PC 1011 SCHAUB DR SUITE 202 RALCIGH NC 27605
WITHERS & RAVEi:EL EiJG. & SURV. l!~C 111 MacKENAN DR. CARY NC 27513
MATT MA.~SHALL & CO. P.O. BOX 77357 GREENSBORO NC 274 17
THOMASVILLE CHAMBER OF COMM. 6 W. MAIN ST, ?O BOX 1400 THOMASV!LlE iJC 27361
l u:sT1TuTE OF TEXTILE TECHNOLOGY 2551 IVY ROAD CHARLOTTESVILLE VA 22903
BOSS SAWYER INC. 300 NORTH HUGHES BLVD ELIZABETH CITY NC 27809
TOWN OF CARY P.O. BOX 8005 CARY NC 27512
UNIFI, INC . P.O. BOX 18109 GREENSBORO NC 27419
EMPIRE ENERGY MANAGEMErJT SYSTEM 725 5TH AVE ., rLOOR 17 NEW YORK f<Y 10002
AEROQUIP CORPORATION P.O. BOX 900 MOORESVIUE NC 281 15
BARRETT KAYS & ASSOCIATES P.O. BOX 2979 RALEIGH NC 27602
THE NATURE CONSERVANCY 4011 UNIVERSITY OR. SUITE 201 DURHAM NC 27707
DIVISION OF COAST AL MANAGEMENT COOPER BLDG. INTEROFFICE
CHOWAN COUNTY HEALTH DEPARTMENT COURIER 10-62-0B EDENTON, NC INTEROFFlCE
CONSULTING ENGINEERS COUNCIL OF NC l301 WOMAN'S CLUB DRIVE, SUITE 123 RALEIGH, NC 27612
LAW ENGINEERING 3301 ATLANTIC AVE., RALEIGH NC 2760-4
!ADAMS PRODUCTS COM0 ANY 720 EAST NE\'\.' SERt.l RD. KINSTON NC 28501
!GROUNDWATER MANP..GEM ENT ASSOC!ATIOi: 101-E WOODWINDS INDUSTRIAL CT . CARY NC 27511
I ECOLOGICAL SERVICES INC. 620 NORTH 1-85 SERVICE RD. CHARLOTTE NC 28216
1 ENVIRONMENT AL SERVICES , INC 1100 WPJ<.E FOREST RD., SUITE 200 RALEIGH NC 27604
CONESTOGA-ROVERS & ASSOC . 8615 W, BRYN MAWR AVE. CHICAGO IL I 60631
TANK. REMOVAL SERVICE INC . 105 FERN AVE. MARION "" 28752
DUNKLEE ANO DUN\-'.AM P.O. BOX 33366 DURHAM 1tJC 27636
CONCORD TELEPHONE COMPANY.'. IP.O. BDX'l27 CONCORD INr. 28026
ANDREW & KUSKE 902 MARKET STREET WILMINGTON ii"' 28401
MEAOE ENGINEERING P.O. BOX 37228 CHARLOTTE NC 28237
UNC-CH ENVIRONMENTAL RESOURCE PROGRAM SCHOOL OF PUBLIC HEAL TH, CB #7400, ROSENAU HALL CHAPEL HILL INC 27599
TET ENVIRONMENTAL 621 CLEMSON ROAD COLUMBIA SC 2g223
GAGE CAROLINA METALS, If.IC. 1090 E. WILMl:iGTON STREET, P.O. BOX 938 BURGAW NC 2&425
HAYES, SEAY, MATTERN & ,...AHERN. INC. 1305 NAVAi iO DR IVE, SUITE 303 RALEIGH NC 27609
PATONIZUCCHINO & ASSOCIATES 1001 WADE AVENUE. SUITE 101 RALEIGH NC 27605
NATIONAL STARCH AND CHEMICAL CO. 485 CEDAR SPRINGS ROAD SALISBURY 1~ 28147
BP Oil COMPAi IY LAKEVIEW 400. 2555 WESTSIDE PKWY, SUITE 300, CS# 1600 ALPHARETTA GA 30201
Page 12
MAILWGWL.XLS
RESOLVE 1255 23RD STREET. N.W., SUITE 275 WASHINGTON DC I 20037
LANDOESIGN EtlGIN::RING SERVICES INC 1208 EASTCHESTER OR!VE. sun 200 IH1GH POii ff NC I 27255
l cHICAGO RAW:ifDE -4328 SOUTH YORK ROAD ' GASTONIA NG I 28052
I ANHEUSER-BUSCH RECYCLING CORPORAHON 3636 SOUTI l GEYER ROAO ST. LOUIS MO I 63127
I ENVIRONMENTAL CHEMISTS, INC. 6602 WINDMILL WAY W ILMINGTON NC I 28405
I BAl'.ERY FEEDS, !NC . 5805 HIG!'iV\/A Y 7 4 EAST MARSHVILLE I Ne 28103
I HAYWOOD COMMV: TY COLLEGE 185 FREEDLA.NDCR DRIVE CLYDE NC I 28721
I BRETHAUER CONSUL TA.NT ENGINEER 1012 NORTH SALEM STREET APEX NC I 27502
NC ELECTRIC MEMBERSH!P CORPORATION 3'400 SUMMER BL VD . RALEIGH NC 27616
SOUTHEAST TECHNICAL seqv1ccs [, 125 ESSEX DRIVE WILMINGTON NC I 28403
HRP/SPECTRUM, INC 7001 PELHAM ROAD, SUITE J GREENVILLE SC 29515
ECOSCIENCE CORPORATION 612 WADE AVEt-iUE, SUITE 200 R.A-.LEIGH NC I 27605
IMS ENVIRONMENTAL 1117-103 CORPORATION PARK\NAY RALEIGH INc I 27610
BRASWELL EQUIPME: :T COMPANY P.O. BOX 3005 BOTHELL WA I 98041
TRIGON ADMINISTRATORS INC. P. 0. BOX 37249 RALEIGH NC 27627
HOBBS UPCHURCH S. ASSOC PA 290 SW BROAD STREET SOUTHERN PINES NC 28387
QUANTUM ENVIRONMENTAL INC. 2200 GATEWAY BLVD., SUITE 205 MORRISVIUE NC 27460
SOUTHEASTERN WELL OR!LUNG INC. I 16535 COOL SPRINGS RO. CLEVE1.AND NC 27013
l v1RGINIAJDECJ0ER &s PO BOX 10009 2N FL-OERS RICHMOND VA 23240
1oooEN ENVIRONMENTAL s. ENG. P,O. BOX 3142 I HUNTERSVILLE NC I 28070
JGANNETT FLEMING 2743 PERIMETER PARKWAY, BLDG. 100. SUITE 350 AUGUSTA a,, I 30909
WILCOX, BETTY I (HANO CARRY a copy to her}
Page 13
,;. "•JAMES 8 . HUNT J -,
' ERNOR
i;=!~ ·: ;:::.• Southern Railway
. Old Highway 70A
Hickory, NC 28602
To Whom it May Concern:
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
July 7, 1999
REGARDING: 711 Pressley Road in
Charlotte, North Carolina (Mecklenburg
County Tax Id Number 145-291-03).
The Department of Environment, Health and Natural Resources has received a
request for a variance from the Groundwater Quality Standards of 15A NCAC 2L
.0202 and Corrective Action requirements of 15A NCAC 2L .01060). 15A NCAC 2L
.0113(e)(l)(E) requires adequate notice be given to area properties and adjacent
property o\vners prior to hearing.
You will find enclosed a Public Notice regarding the variance hearing. Please refer
to the enclosure for additional information. If you have any questions concerning this
variance request, please contact David Hance at [phone].
Sincerely,
M. Carl Bailey, Jr.
Assistant Chief for Planning
Groundwater Section
GIROUNDWATIIR SECTION
P.O. BOX 29578, RALEIGH, NORTH CAROLINA 27628•0!578 • 2728 CAPITAL, BLVD., RALEIGH, NC 27604
PHONE 9 I 9-733-3221 FAX [phone]
AN EQUAL OPPORTUNITY / AFFIRMATIVE ACTION EMPLOYER • 150'1(, RECYCLED/I 0% POST-CONSUMER PAPER
' j
1
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES ' I
--·-~---
DIVISION OF WATER QUALITY \
~R ;.•. Jt'··<~
\.,.,,'~•AMES B. HUNT J~.-.~ .. ,,
\. ,.G~VERNOR ,. . .. : 'Ji~,~-: '
July 7, 1999
M John W. Layne
801 Pressley Road
Charlotte, NC 28217
REGARDING:
TO WHOM IT MAY CONCERN:
Property at 801 Pressley Road
(Tax Id Number145-291-04)
The Department of Environment, Health and Natural Resources has received a
~~a request for a variance from the Groundwater Quality Standards of 15A NCAC 2L
.Jld:'l
-~~
.0202 and Corrective Action requirements of 15A NCAC 2L .0106(j). 15A NCAC 2L
.Ol 13(e)(llE) requires adequate notice be given to area properties and adjacent
property owne!s prior to hearing.
You will find enclosed a Public Notice regarding the variance hearing. Please refer
to the enclosure for additional information. If you have any questions concerning this
variance request, please contact David Hance at [phone] .
Enclosure
Sincerely,
,,pl~~
M. Carl Bailey, Jr.
Assistant Chief for Planning
Groundwater Section
GROUNDWATER SECTION
P.O. Box 29578, RALEIGH, NORTH CAROLINA 27626-0578 • 2728 CAPITAL, BLVD., RALEIGH, NC 27604
PHONE [phone] FAX -9 I 9-71 5-0588
AN EQUAL OPPORTUNITY/ AFFIRMATIVE ACTION EMPLOYER • 50% RECYCLED/10o/o POST-CONSUMER PAPER
NORTH CAROLINA DEPARTMENT OF 1
ENVIRONMENT AND NATURAL RESOURCES ,
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DIVISION OF WATER QUALITY I
Davis Brothers Venture
650 Pressley Road
~'.;8,.-1:~. Charlotte, NC 28217
July 7, 1999
REGARDING:
, TO WHOM IT MAY CONCERN:
Property at 650 Pressley Road
(Tax Id Numberl45-271-15)
r-~:W!f~~\~S~ The Department of Environment, Health and Natural Resources has received a
request for a variance from the Groundwater Quality Standards of 15A NCAC 2L
• .0202 and Corrective Action requirements of 15A NCAC 2L .0106(j). 15A NCAC 2L
.,,,_,.,.-..-n<t .0113(e)(l)(E) requires adequate notice be given to area properties and adjacent
property O\Vnefs prior to hearing.
_ You will find enclosed a Public Notice regarding the variance hearing. Please refer
~to the enclosure for additional information. If you have any questions concerning this
M. Carl Bailey, Jr.
Assistant Chief for Planning
Groundwater Section
GROUNDWATER SECTION
P.O. Box 29578, RALEIGH, NORTH CAROLINA 27626-0!578 • 2728 CAPITAL, BLVO., RALEIGH, NC 27604
PHONE 919-733•322I FAX
0
919-715-0588
AN EQUAL OPPORTUNITY / AFFIRMATIVE ACTION EMPLOYER • !50% Al!CYCLl!D/10o/o POST•CONSUMER PAPER
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J. David Fortenbery
644 Pressley Road
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
July 7, 1999
-~ ...... -.... n.' Charlotte, NC 28217
REGARDING:
TO WHOM IT MAY CONCERN:
Property at 644 Pressley Road
(Tax Id Number145-271-12)
Sincerely,
/)11~~
M. Carl Bailey, Jr.
Assistant Chief for Planning
Groundwater Section
GROUNDWATER SECTION
P.O. Box 29578, RALEIGH, NORTH CAROLINA 27626•0578 • 2728 CAPITAL, BLVD., RALEIGH, NC 27604
PHONE [phone] FAX.[phone]
AN EQUAL OPPORTUNITY/ AFFIRMATIVE ACTION EMPLOYER • 50% RECYCLED/10% POST-CONSUMER PAPER
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NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES ,
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DIVISION OF WATER QUALITY l
DE R ~. ~ .. ;-,, •~.:tr11~:, '
'"'.JAMES B. HUNT
l,
.:GOV ERNOR
~;~:~ ~-July 7, 1999
Ms. Pam Syfert
:u.\-l~~,Office of the City Manager
id'.-!'iU'il'-City of Charlotte
600 E. Fourth Street -Government Center
Charlotte, NC 28202-2244
• Dear Ms. Syfert:
The Department of Environment, Health and Natural Resources has
-· · received a request for a variance from the Groundwater Quality Standards of
, _,. 15A NCAC 2L .0202 and Corrective Action requirements of 15A NCAC 2L
.. 01060) (Groundwater Classifications and Standards). 15A NCAC 2L
_ .0113(e)(1 )(D) requires adequate notice be given to governmental units
having jurisdiction over the geographical area covered by the variance prior to
·-· hearing.
f.: ,~ You will fi~d enclosed a Public Notice regarding the variance hearing.
j : Please refer to the enclosure for additional information.
-f
Enclosure
Sincerely,
/J11LJ~
M. Carl Bailey, Jr.
Assistant Chief for Planning
Groundwater Section
GROUNDWATER SECTION
P.O. Box 29578, RALEIGH, NORTH CAROLINA 27626-0578 • 2728 CAPITAL, BLVD,, RALEIGH, NC 27604
PHONE [phone] FAX '919-715-0588
AN EQUAL OPPORTUNITY/ AFFIRMATIVE ACTION EMPLOYER • 50% Rl!CYCLED/10% POST-CONSUMER PAPER
.. .. , .. ..,,.
~LWAYN "!IC
f~ l -.. Ionnis and Gregory Andreas
740 Pressley Road
Charlotte, NC 2821 7
NORTH CAROLINA DEPARTMENT OF 1
ENVIRONMENT AND NATURAL RESOURCES ,
July 7, 1999
I
J
DIVISION OF WATER QUALITY I
REGARDING: Property at 7 40 Pressley Road
(Tax Id Number145-271-07)
TO WHOM IT MAY CONCERN:
The Department of Environment, Health and Natural Resources has received a
;i:...c:~:e~~request for a variance from the Groundwater Quality Standards of 15A NCAC 2L
.0202 and Corrective Action requirements of 15A NCAC 2L .0106(j). 15A NCAC 2L
.0113(e)(l)(E) requires adequate notice be given to area properties and adjacent
property owners prior to hearing.
You will find enclosed a Public Notice regarding the variance hearing. Please refer
to the enclosure for additional information. If you have any questions concerning this
variance request, please contact David Hance at [phone].
Enclosure
Sincerely,
/)t1t;,1 ~
M. Carl Bailey, Jr.
Assistant Chief for Planning
Groundwater Section
GROUNDWATER SECTION
P.O. Box 29578, RALEIGH, NORTH CAROLINA 27626-0578 -2728 CAPITAL, BLVD., RALEIGH, NC 27604
PHONE [phone] FAX.[phone]
AN EQUAL OPPORTUNITY/ AFFIRMATIVE ACTION EMPLOYER -50% AECYCLED/10% POST-CONSUMER PAPER
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,~~-•Go R •, R
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES ' • I
DIVISION OF WATER QUALITY 4
i
July 7, 1999
'\ .;:·:;?1,
~ . ~-· · · , Joachim H. Klitzsch
700 Pressley Road
Charlotte , NC 2821 7
REGARDING:
TO WHOM IT MAY CONCERN:
Property at 700 Pressley Road
(Tax Id Number145-271-10)
The Department of Environment, Health and Natural Resources has received a
request for a variance from the Groundwater Quality Standards of 15A NCAC 2L
.0202 and Corrective Action requirements of 15A NCAC 2L .0106G). ISA NCAC 2L
·~, .. ., .. · .... , .Ol 13(e)(l)(E) requires adequate notice be given to area properties and adjacent
property owners prior to hearing.
You will find enclosed a Public Notice regarding the variance hearing. Please refer
to the enclosure for additional information. If you have any questions concerning this
variance request, please contact David Hance at [phone] .
Enclosure
Sincerely,
~M ~
M. Carl Bailey, Jr.
Assistant Chief for Planning
Groundwater Section
GROUNDWATl!ll 81:CTION
P.O. Box 29578, RALEIGH, NORTH CAROLINA 27626-0578 • 2728 CAPITAL, BLVD., RALEIGH, NC 27604
PHONI! 919·733-3221 FAX.919-715•0588
AN EQUAL OPPORTUNITY/ AFFIRMATIVE ACTION EMPLOYl!R • 50% Rl!CYCLED/10% POST-CONSUMER PAPER
~~
,.········ ' .. . !' NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
.. ;.£",', •
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OR
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"• ,'t~ ' WAYNE.MC
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DMSION OF WATER QUALITY
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July 7, 1999
James A. Williams
654 Pressley Road
.............. ,,...,Charlotte, NC 28217
REGARDING: Property at 654 Pressley Road
(Tax Id Number145-271-11)
TO WHOM IT MAY CONCERN:
The Department of Environment, Health and Natural Resources has received a
request for a variance from the Groundwater Quality Standards of 15A NCAC 2L
.0202 and Corrective Action requirements of 15A NCAC 2L .0106(j). 15A NCAC 2L
.Ol 13(e),l)(E) requires adequate notice be given to area properties and adjacent
proper\y owners prior to hearing.
You will find enclosed a Public Notice regarding the variance hearing. Please refer
to the enclosure for additional information. If you have any questions concerning this
variance request, please contact David Hance at [phone] .
Enclosure
Sincerely,
M. Carl Bailey, Jr.
Assistant Chief for Planning
Groundwater Section
GROUNDWATER SECTION
P.O. Box 29578, RALEIGH, NORTH CAROLINA 27626·0!578 • 2728 CAPITAL, BLVD., RALEIGH, NC 27604
PHONE 91 9•733-3221 FAX .[phone]
AN EQUAL OPPORTUNITY/ AFFIRMATIVE ACTION EMPLOYER • !50% RECYCLt:D/10% POST-CONSUMER PAPER
' I
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-.
'NOTICE OF VARIANCE APPLICATION AND HEARING
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
Notfce is hereby given of a variance application and public hearing to be held by the Department of
Environment and Natural Resources on behalf of the Environmental Management Commission. The hearing
concerns a request for a variance from the Groundwater Quality Standards of 15A NCAC 2L .0202 and the
Corrective Action requirements ofl 5A NCAC 2L .0106 G) for a site at 711 Pressley Road in Charlotte, North
Carolina. The Division of Water Quality refers to this site identifi_ed in the variance request as Groundwater
Incident# 8949. This property consists of 6.17 acres ofland was previously owned by the proprietor of
Carolina Coatings Incorporated, Mr. Linwood Carter, and was used as a solvent-based paint mixing facility
until 1991. The property is now owned by Wattyl Paints of Atlanta, Georgia. Carolina Coatings Incorporated
is entirely responsible for cleanup for Groundwater Incident# 8949. This variance application from Carolina
Coatings lncorporateg. was received for review by the Department on December 9, 1996.
The property where the release of volatile organic substances has occurred is located as follows: Inside
the city limits of Charlotte, North Carolina. Take Interstate 77 in Charlotte and exit onto South Tryon Street
(NC 49) and proceed one block north. Tum left (west) onto Pressley Road for 0.38 miles. The former
Carolina Coatings facility is located on the left. The site is listed in Mecklenburg County tax records as
Parcel Number 145-291-03.
Carolina Coatings Incorporated requests that the Environmental Management Commission grant the
following variance to its rules under the authority of 15A NCAC 2L .0113 so that if does the following:
(1) Allow concentrations of Benzene, Ethylbenzene, and Xylene (-o,-m, and p) to remain at levels
above 15A NCAC 2L .0202 Groundwater Quality Standards as analyzed on October 9, 1997 in all
monitoring wells. These concentrations will be required to remain within the property boundaries of
711 Pressley Road. Pursuant to the transfer of ownership of this property in 1991, Mr. Carter had
environmental assessments conducted of soils and groundwater at this site. Benzene, Ethylbenzene,
Toluene and Xylene (BETX) were found in soils around this site and groundwate~ samples showed
the presence of several volatile organic compounds such as Benzene, Ethylbenzene and Xylene.
Since the transfer of ownership of this property to Wattyl Paints all solvent-based paint mixing
operations have ceased and were moved to Atlanta, Georgia. Only latex water-based paint mixing has
been conducted at this property since 1991. All potential sources of groundwater contamination have
been identified at this property by Carolina Coatings Incorporated. The entire property at 711
Pressley Road is located in an area with a mixture of commercial, industrial, and residential
development.
Site assessments were completed by September 1992 and a remedial action plans for this site
were submitted in late spring 1993. The site assessments revealed a plume of substances in soil and
groundwater. Site assessment information on file in the Mooresville Regional Office shows that the
vertical extent of this plume to be less than 48 feet below the ground surface. This plume was
estimated to have covered an area of approximately 10,000 square feet (0.23 acres) prior to the
implementation of corrective actions by Carolina Coatings Incorporated.
From June 2, 1993 through January 1997 concentrations of substances at this site were
significantly reduced by soil removal operations and groundwater cleanup technologies located at the
site. A concrete pad and waste water settling tanks were removed during this renovation and clean
1
..,,
fill material was used in place of this contaminated soil. In July 1993 the company installed a
groundwater pump-and-treat cleanup system and it began operation on March 24, 1994.
Except for one monitoring well located in the area where the plume of groundwater
contamination has been identified (Monitoring Well MW-9), concentrations of substances have never
exceeded quantifiable levels. Since December 1994 analysis of samples, MW-9 showed only
margjnal reductions in the concentration of substances in groundwater. Based on groundwater
analysis of samples from semi-annual monitoring from 1993 through 1996, the Division of Water
Quality recommended that pump and treat system be turned off to determine ifresidual concentrations
of substances would increase, ifno treatment system were operating. From August 27, 1996 through
September 3, 1996 the cleanup system ceased operation. A groundwater sample taken on September
3, 1996 demonstrated upward "rebounding" ofBenzene above the Groundwater Quality Standard in
15A NCAC 2L .0202 in monitoring well MW-9. Analysis of a groundwater sample taken on October
9, 1997 through showed the Ethylbenzene or Xylene concentrations did not exceed detection limits
and the Benzene concentration was 0.002 milligrams per liter. The Groundwater Qualfty Standard
for Benzene is 0.001 milligrams per liter.
The company has also conducted monitoring at a recovery well near monitoring well MW-9. This
recovery well is used as a sump to collect groundwater and other liquids for removal by the pump-and-
treat cleanup systems. Groundwater monitoring at the inlet of this recovery well sampled on
September 30, 1996 and October 30, 1996 showed that concentrations ofBTEX were below detectable
levels. This monitoring occurred after the cleanup system had been turned off for a period of five
days.
Based on concentrations of substances found in monitoring wells, substances found in the well
used for recovery of contaminants, and calculations of the time it would take for substances to migrate
to receptors at surrounding properties, the company does not believe that a variance will result in an
adverse impact to the public. There are no drinking water supply wells at adjacent properties and the
nearest water supply wells are 2,300 feet cross gradient from the site. No water supply intakes from
surface water bodies are located within ½ of a mile from the site. Public water supply lines are
deemed too shallow to be impacted by substances at 711 Pressley Road .
(2) Allow for the restoration of groundwater without requiring continued remedial actions in
accordance with 15A NCAC 2L .0106U). Carolina Coatings Incorporated has submitted supporting
information demonstrating that the continued application of best available technology will not result
in significant long term remediation of the site to the Groundwater Quality Standards contained in
15A NCAC 2L .0202. This is due to the high probability that continued remediation activities at the
site will not significantly reduce contaminant levels below Groundwater Quality Standards in 15A
NCAC 2L .0202.
Since discovery of the release in 1991, Carolina Coatings Incorporated has disposed of a total of
2,400 cubic yards of contaminated soil during site renovation operations in June 1993. Carolina
Coatings Incorporated has submitted information showing that the company has treated a total of
328,500 gallons of groundwater via pump-and-treat technology. The company reports that a total of
$ 493,000 has been expended to design and install the remediation system, operate the system,
monitor progress of cleanup activity, and cleanup this site. Carolina Coatings Incorporated believes
that the public will not benefit from continued cleanup using present technology at the site or the
alternatives discussed and that a variance is the most effective means of dealing with remaining
concentrations.
2
Author: David Hance at NRGWS0lP
Date: 6/28/1999 11:30 AM
Priority: Urgent
Receipt Requested
TO: [e-mail] at Internet
TO: [e-mail] at Internet
CC: Arthur Mouberry
CC: Carl Bailey
CC: David Hance
TO: Burrie Boshoff
Subject: re: update on gW Variances
Message Contents------------------------------------
Hello Tommy and Donna:
On behalf of Arthur Mouberry, here is an update on two variance in
Charlotte, NC. As you know .... we obtained signatures on public
notices for two public hearings to be held in August 1999 concerning
variances.
One of these variances is for an EMRO Marketing Company site
(Speedway 145) at 6500 North Tryon Street also known as Groundwater
Incident Number 5846. This is a variance for an underground storage
tank release for which the responsible party has been cleaning up for
some time. The site is regulated by the DWM UST Section.
The other variance is for a release of substances from a paint
mixing facility under Groundwater Incident Number 8949. This site is
the former Carolina Coatings facility owned by Mr. Linwood Carter and
is located at 711 Pressley Road in Charlotte. This site falls in the
Groundwater Section's universe as a result of spills that occurred
over the years. The company has acted aggressively to remediate this
site .
The Groundwater Section has been informed by staff in the UST
Section -Mooresville Regional Office that they do not believe that
the Emro Marketing Variance should proceed to public notice and
hearing at this time. They have cited that the concentration of
Benzene has risen significantly over the last year. In addition, the
MRO has examined product inventory information at this active gasoline
retail outlet and is investigating apparent discrepancies with the
company. Prior to cleanup activities, this site was a Class A site
and there are active wells in the area. Therefore, the DWM-UST
Section in the MRO believes further investigation of concentrations of
substances is warranted at this time and have authorized additional
monitoring. They still believe a variance may be possible based on
current information. If actions other than a variance, such as
additional cleanup, is necessary the MRO will follow through with the
company on this.
Based on our discussions with the DWM-UST Section in the MRO, the
variance notice and other materials are on hold at this time in our
office. If the variance can go forward to public hearing you will
receive a new notice with a new date for that hearing for your
signature. If for any reason the company withdraws the variance
request a letter will be requested from them and place in our records.
The Carolina Coatings variance will go forward to public hearing on
August 12th as shown in the notice that the Director signed last week.
If we need further discussions ... feel free to call me at 715-6189
or Arthur Mouberry at 715-6170.
David Hance
If possible, we would like your response to this request for information by Tuesday,
June 6, 1999 so we can contact these property owners prior to the public hearing on August
12, 1999. If you need to discuss this request, feel free to contact Mr. Hance at (919) 715-
_.-· 6189.
Enclosure
cc: David Hance
Sincerely,
1:L~~
Assistant Chief for Planning
Groundwater Section
Patrick J. Gallagher (Dames and Moore-NC)
• I
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2
Time. Sensitive
Public Notices!
(Signatures needed)
To: -
From:
Subject:
Date:
Donna Pittman
DavidHance ~
Public Notices -Two Variances -Emro Marketing Company (GWI#5846) and
Carolina Coatings (GWI#8949)
June 24, 1999
Here are the memoranda and public notices for two variances at locations in
Charlotte, North Carolina. The Director's review of variances for completeness prior to public
hearing is required under 15A NCAC 2L .0113(d). One of these variances is a Groundwater
Section variance at a paint mixing facility formerly owned by Carolina Coatings Incorporated
located at 711 Pressley Road. The proprietor of Carolina Coatings was Mr. Linwood Carter
whom the Director has had legislative inquiries concerning his variance. The other variance is
from the Division of Waste Management UST Section for petroleum releases at underground
storage tanks owned by the Emro Marketing Company at 6500 North Tryon Street.
The memoranda from Arthur Mouberry for these facilities provides a summary of
each of the attached variances. To assist the Director or his designee in the review of this
material, yellow post-it notes have been placed on pages referenced in the summaries for each
the variances. Key text is also highlighted yellow. The date of the hearings have been arranged
for August 12, 1999 in Charlotte, NC at 7:00 P.M. as shown in the attached notices. We intend to
hold two hearings in one evening at the same location Mr. Art Barnhardt, Division of Water
Quality Region Groundwater Supervisor in the Fayetteville Region, has agreed to be the hearing
officer for this variance. Staff in the Groundwater Section and the DWM UST Section will be
assisting the hearing officer with this variance as well as Central Office Groundwater Section
staff.
Donna Pittman
Page2
October 7, 1997
Once these notices are signed by the Director, the Groundwater Section will need
to get an adequate number of copies made to notice adjacent properties, area well owners, and
other individuals. Please note that we are under a 30-day window to notice the public prior to the
date of the hearing. Upon com pletin g the Director's review o{the memoranda and signature
on each o f the TWO notices, I would be glad to come b y and p ick them up with the attached
variances. If possible, we would like to get the signed notices ready by 9:30 .4..~. on
Wednesday, June 30, 1999. Please feel free to contact me at 715-6189 or my E-Mail
address if you have questions.
CC: Arthur Mouberry
Carl Bailey
M E
To:
From:
Subject:
Date:
M 0
Arthur Mouberry
David Hance(~
2 variances in Charlotte
June 23, 1999
R A N D u M
Attached is the paperwork for the Carolina Coatings Variance (Linwood Carter)
and the Emro Marketing Variance. Included with the actual requests and attached information
from these companies, are public notices for the Director's signature and summaries of each
variance request for the Director to review. The Director must review these requests for
completeness pursuant to ISA NCAC 2L .0113 (d).
Carl Bailey has reviewed the notices and memoranda for these requests and is
satisfied with them. If the information in these request is sufficient to you, please sign the
summary that is addressed to the Division Director for each of these variance reauests.
You mav get the memoranda. notices and variance materials back to me. If possible. I would
Qreatlv appreciate QettinQ the signed memoranda and materials back from you by 10:30
A.M. tomorrow on 6/24/99.
-. . •,
-·.• ,. ~ fNOTICE OF VARIANCE APPLICATION AND HEARING
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
Notfce is hereby given of a variance application and public hearing to be held by the Department of
Environment and Natural Resources on behalf of the Environmental Management Commission. The hearing
concerns a request for a variance from the Groundwater Quality Standards of 15A NCAC 2L .0202 and the
Corrective Action requirements of 15A NCAC 2L .0106 G) for a site at 711 Pressley Road in Charlotte, North
Carolina. The Division of Water Quality refers to this site identifi_ed in the variance request as Groundwater
Incident# 8949. This property consists of 6.17 acres of land was previously owned by the proprietor of
Carolina Coatings Incorporated, Mr. Linwood Carter, and was used as a solvent-based paint mixing facility
until 1991. The property is now owned by Wattyl Paints of Atlanta, Georgia. Carolina Coatings Incorporated
is entirely responsible for cleanup for Groundwater Incident# 8949. This variance application from Carolina
Coatings Incorporateg. was received for review by the Department on December 9, 1996.
The property where the release of volatile organic substances has occurred is located as follows: Inside
the city limits of Charlotte, North Caro.lina. Take Interstate 77 in Charlotte and exit onto South Tryon Street
(NC 49) and proceed one block north. Tum left (west) onto Pressley Road for 0.38 miles. The former
Carolina Coatings facility is located on the left. The site is listed in Mecklenburg County tax records as
Parcel Number 145-291-03.
Carolina Coatings Incorporated requests that the Environmental Management Commission grant the
following variance to its rules under the authority of 15A NCAC 2L .0113 so that if does the following:
(1) Allow concentrations of Benzene, Ethylbenzene, and Xylene (-o,-m, and p) to remain at levels
above 15A NCAC 2L .0202 Groundwater Quality Standards as analyzed on October 9, 1997 in all
monitoring wells. These concentrations will be required to remain within the property boundaries of
711 Pressley Road. Pursuant to the transfer of ownership of this property in 1991, Mr. Carter had
environmental assessments conducted of soils and groundwater at this site. Benzene, Ethylbenzene,
Toluene and Xylene (BETX) were found in soils around this site and groundwate~ samples showed
the presence of several volatile organic compounds such as Benzene, Ethylbenzene and Xylene.
Since the transfer of ownership of this property to Wattyl Paints all solvent-based paint mixing
operations have ceased and were moved to Atlanta, Georgia. Only latex water-based paint mixing has
been conducted at this property since 1991. All potential sources of groundwater contamination have
been identified at this property by Carolina Coatings Incorporated. The entire property at 711
Pressley Road is located in an area with a mixture of commercial, industrial, and residential
development.
Site assessments were completed by September 1992 and a remedial action plans for this site
were submitted in late spring 1993. The site assessments revealed a plume of substances in soil and
groundwater. Site assessment information on file in the. Mooresville Regional Office shows that the
vertical extent of this plume to be less than 48 feet below the ground surface. This plume was
estimated to have covered an area of approximately 10,000 square feet (0.23 acres) prior to the
implementation of corrective actions by Carolina Coatings Incorporated.
From June 2, 1993 through January 1997 concentrations of substances at this site were
significantly reduced by soil removal operations and groundwater cle:inup technologies located at the
site. A concrete pad and waste water settling tanks were removed during this renovation and clean
1
.... . .
fill material was used in place of this contaminated soil. In July 1993 the company (.nst~lled a
groundwater pump-and-treat cleanup system and it began operation on March 24, 1994.
Except for one monitoring well located in the area where the plume of groundwater
contamination has been identified (Monitoring Well MW-9), concentrations of substances have never
exceeded quantifiable levels. Since December 1994 analysis of samples, MW-9 showed only
marginal reductions in the concentration of substances in groundwater. Based on groundwater
ana1ysis of samples from semi-annual monitoring from 1993 through 1996, the Division of Water
Quality recommended that pump and treat system be turned off to determine ifresidual concentrations
of substances would increase, ifno treatment system were operating. From August 27, 1996 through
September 3, 1996 the cleanup system ceased operation. A groundwater sample taken on September
3, 1996 demonstrated upward "rebounding" ofBenzene above the Groundwater Quality Standard in
15A NCAC 2L .0202 in monitoring well MW-9. Analysis of a groundwater sample taken on October
9, 1997 through showed the Ethylbenzene or Xylene concentrations did not exceed detection limits
and th~ Benzene concentration was 0.002 milligrams per liter. The Groundwater Quality Standard
for Benzene is 0.001 milligrams per liter.
The company has also conducted monitoring at a recovery well near monitoring well MW-9. This
recovery well is used as a sump to collect groundwater and other liquids for removal by the pump-and-
treat cleanup systems. Groundwater monitoring at the inlet of this recovery well sampled on
September 30, 1996 and October 30, 1996 showed that concentrations ofBTEX were below detectable
levels. This monitoring occurred after the cleanup system had been turned off for a period of five
days.
Based on concentrations of substances found in monitoring wells, substances found in the well
used for recovery of contaminants, and calculations of the time it would take for substances to migrate
to receptors at surrounding properties, the company does not believe that a variance will result in an
adverse impact to the public. There are no drinking water supply wells at adjacent properties and the
nearest water supply wells are 2,300 feet cross gradient from the site. No water supply intakes from
surface water bodies are located within ½ of a mile from the site. Public water supply lines are
deemed too shallow to be impacted by substances at 711 Pressley Road.
(2) Allow for the restoration of groundwater without requiring continued remedial actions in
accordance with ISA NCAC 2L .0106(j). Carolina Coatings Incorporated has submitted supporting
information demonstrating that the continued application of best available technology will not result
in significant long term remediation of the site to the Groundwater Quality Standards contained in
15A NCAC 2L .0202. This is due to the high probability that continued remediation activities at the
site will not significantly reduce contaminant levels below Groundwater Quality Standards in 15A
NCAC 2L .0202.
Since discovery of the release in 1991, Carolina Coatings Incorporated has disposed of a total of
2,400 cubic yards of contaminated soil during site renovation operations in June 1993. Carolina
Coatings Incorporated has submitted information showing that the company has treated a total of
328,500 gallons of groundwater via pump-and-treat technology. The company reports that a total of
$ 493,000 has been expended to design and install the remediation system, operate the system,
monitor progress of cleanup activity, and cleanup this site. Carolina Coatings Incorporated believes
that the public will not benefit from continued cleanup using present technology at the site or the
alternatives discussed and that a variance is the most effective means of dealing with remaining
concentrations.
2
DIVISION OF WATER QUALITY
GROUNDWATER SECTION
June 24, 1999
MEMORANDUM
To: Kerr T. Stevens
From: Arthur Mouberry #
Subject: Request for Variance from 15A NCAC 2L .0202 and 15A
NCAC 2L .0106G) for a Site Owned by the Carolina Coatings Incorporated at 711
Pressley Road in Charlotte, North Carolina (Groundwater Incident Number
8949).
From 1971 through 1991, Mr. Linwood Carter operated a portion of the Carolina
Coatings Incorporated property as a paint blending facility located at 711 Pressley Road in
Charlotte, North Carolina. This site is at the intersection of Billy Graham Parkway and US
Interstate 77. In 1991, Mr. Carter sold this facility to Wattyl Paints of Atlanta, Georgia. The
new owner of this facility moved all solvent based mixing processes out of North Carolina 1991.
Mr. Carter maintains cleanup responsibilities for substances found at this site.
The Carolina Coatings facility consists of a total of 47,000 square feet of warehouse and
office space on 6.1 7 acres of land. During the period this property was owned by Mr. Carter,
Carolina Coatings manufactured paint using a batch mixing process which blended latex
emulsions with dry pigments, wetting agents, water, defoamers and other ingredients. This
process required the storage of empty fifty-five gallon drums on a concrete pad located rear of
the building. Waste water settling tanks were also located in this area. During the course of
business operations leaks had occurred in drums located at this site and from the wastewater
settling ponds.
Pursuant to the transfer of ownership of this property in 1991, Mr. Carter had
environmental assessments conducted of soils and groundwater at this site. Ethylbenzene,
Toluene and Xylene were found in soils around this site. Analysis of groundwater samples
showed the presence of several volatile organic compounds, Benzene, Ethylbenzene, Toluene
and Xylene. Since 1991 only latex water-based, products have been processed at 711 Pressley
Road by Wattyl Paints. The owner of Carolina Coatings Incorporated, Mr. Linwood Carter, is
entirely responsible for cleanup of this release which is shown in Division of Environmental
Management files as Groundwater Incident Number 8949.
1
Pursuant to title 15A NCAC 2L .0l 13(c) variance applications are required to have
specific information in order to adequately review a request. The Carolina Coatings variance
request is contained in a report titled "Variance Request -Carolina Coatings Site -Charlotte,
North Carolina, December 9, 1996, Dames and Moore N.C. Job No.23995-002-200.". In
addition, memoranda and other correspondence are included with this request. The information
submitted by Dames and Moore on behalf of the Carolina Coating Incorporated appears to meet
the requirements of 15A NCAC 2L .0l 13(c) and is summarized as follows:
Rule .0113(c)(l): Resolution by the County or governing Board:
Carolina Coatings Incorporated has always been a privately owned
company. No resolution is necessary.
Rule .0113(c)(2): A description of past. existing or proposed activities that would result in a
discharge of contaminants into groundwater:
The former Carolina Coatings Incorporated is located inside the city limits of
Charlotte, North Carolina at 711 Pressley Road (Mecklenburg County Tax
Identification Number 145-291-03). The report titled "Variance Request-Carolina
Coatings Site -Charlotte, North Carolina, December 9, 1996, Dames and Moore
N.C. Job No.23995-002-200" contains the relevant information about this site. The
site consists of approximately 6.17 acres of land.
A Notice of Violation was issued to Carolina Coatings Incorporated by the
Department on August 28, 1992. Remedial Action Plans were submitted to the
Mooresville Regional Office on June 29, 1992 and March 23, 1993. On J!lnuary 18,
1994, a discharge permit for an on-site infiltration gallery was authorized by the
Division of Water Quality (WQ0007993). Details of soil and groundwater corrective
actions are documented in a report titled "Soil and Groundwater Remediation
Report (April 19, 1994)" at the Mooresville Regional Office. All potential sources
of groundwater contamination were identified at this property by t4e company.
This property at 711 Pressley Road in Charlotte, North Carolina, formerly owned
by Mr. Linwood Carter, and is in an area with a mixture of commercial, industrial,
and residential development.
The comprehensive site assessment and other investigations revealed
Benzene, Toluene, Ethylbenzene, and Xylene ( o, m, and p) (BETX) in the
groundwater and soil beneath the site. This area was located at the southwest
corner of the building near an 88 foot by 66 foot concrete pad and three small
wastewater settling tanks. This was where the company stored chemicals and
performed batched mixing operations for solvent-based paints. This area is
2
approximately 10 feet from the northwest property line and 75 feet from the
southwest property line. The entire property at 711 Pressley Road is surrounded
by a fence. This plume was estimated to have covered an area of approximately
10,000 square feet (0.23 acers) prior to the implementation of correctiv~ actions by
the Carolina Coatings Incorporated. According to information at the Mooresville
Regional Office the vertical extent of this plume is believed to be less than 48 feet
below the ground surface.
Carolina Coatings Incorporated implemented cleanup of soils at this site in
September 1992 with the removal of 900 cubic yards of soil that exceeded the 50
milligram per kilogram target cleanup level. Between June 2, 1993 and June 25,
1993, the company removed an additional 1,500 cubic yards of contaminated soils.
Excavated soils were treated offsite and clean fill material was used as backfill. As a
result of soil remediation, the concrete pad was removed and subsequently replaced.
In July 1993 the company installed a pump-and-treat system with a single
groundwater recovery well (RW-1) located near the south corner of the former
concrete storage pad as shown in Figure 6 of the variance. From March 23, 1994
through January 1997 a total of 328,500 gallons of groundwater has been treated via
pump-and-treat technology. The treated discharge was sent to an upgraident
infiltration gallery. An infiltration gallery is a closed-loop conveyance that allows
water and other fluids, discharged through the pump-and-treat system, to be sent
back into the subsurface where they recirculated into the cleanup system for
continual treatment. An infiltration gallery may also serve to enhance intrinsic
biodegradation of contaminants by introducing dissolved oxygen in the subsurface
which may stimulate biologic decomposition of some dissolved substances. Non-
Discharge Permit WQ0007993 was issued on January 18, 1994 for the infiltration
gallery. The Groundwater Section staff have recommended that, if the variance
request is granted, no permit for this infiltration gallery is to be reissued. The
company's environmental consultant, Dames and Moore, reports that this device
will no longer be used once the variance is granted.
The Division of Water Quality required Carolina Coatings Incorporated to
perform groundwater monitoring to determine the vertical and lateral extent of
contamination at the site. Table 2 of the report titled "Variance Re q uest-Carolina
Coatin gs Site -Charlotte, North Carolina, December 9, 1996, Dames and Moore
N.C. Job No.23995-002-200" shows that three of six monitoring wells were sampled
from March 1994 through September 1996 on a quarterly schedule. Groundwater
samples were analyzed using US Environmental Protection Method 8020. Page 6 of
the variance request shows that only Monitoring Well# 9 has had concentrations of
Benzene, Ethylbenzene, and Xylene above the Groundwater Quality Standards in
15A NCAC 2L .0202. Toluene has never appeared in any of the monitoring wells at
a concentration in excess of the Groundwater Quality Standard in 15A NCAC 2L
.0202. Table 2 of the report titled "Variance Re q uest -Carolina Coatings Site -
Charlotte, North Carolina, December 9 , 1996, Dames and Moore N.C. Job
No.23995-002-200" shows that the highest concentration of Benzene, Ethylbenzene,
and Xylene have been found in this well. The highest concentration of Benzene in
exceedence of the Groundwater Quality Standard was 0.027 milligrams per liter or
3
27 micrograms on September 3, 1996. The highest concentration of any substance
in exceedence of the 15A NCAC 2L .0202 Groundwater Quality Standard found at
th_is site was Xylene ( o,p,m). Xylene appeared at the December 1994 monitoring
event at 0.860 milligrams per Liter or 860 micrograms/Liter.
As shown on Table 1 of the report titled "Variance Request -Carolina
Coatin~s Site -Charlotte, North Carolina, December 9, 1996, Dames and Moore
N.C. Job No.23995-002-200"from March 29, 1994 through October 30, 1996, the
company conducted analysis of samples from Recovery Well# 1 on the influent side
of the cleanup system to determine the effectiveness of the pump-and-treat cleanup.
This data shows that the source of the groundwater contamination at this site has
been significantly reduced such that the plume can no longer be detected.
Based on the results of !he groundwater monitoring and recovery well
monitoring in September and October 1996, the Carolina Coatings reqµested a
variance and that the pump and treat groundwater cleanup system be shut off. In
January 1997 the Mooresville Regional Office agreed that active cleanup should be
discontinued. Based on the results of groundwater monitoring and monitoring of
influent samples in the recovery well from the pump and treat cleanup system the
cleanup system was turned off. This variance request encompasses the entire
property at 711 Pressley Road in Charlotte, North Carolina.
Potential sources of groundwater contamination in the area are discussed in
Pages 9 through 11 and in Appendix A of the report titled "Variance Request -
Carolina Coatines Site -Charlotte, North Carolina, December 9, 1996, Dames and
Moore N.C. Job No.23995-002-200." . Appendix A shows Vista Site Assessment
Reports of these properties with maps. Potential sources of groundwater
contamination are summarized as follows:
1) The property at 711 Pressley Road formerly owned by Carolina
Coatings Incorporated (Mecklenburg County Tax Identification
Number 145-291-03). This site is now owned by Wattyl Paints. The
Vista Site Assessment Report lists this site on the state "CERCLIS"
and as a "Large Quantity Generator" of hazardous wastes.
2) The property at 807 Pressley Road known as The Gifford-Hill
Company located 1/10 of a mile northwest of the site. This property is
upgradient from the site and is listed with the Division of Waste
Management-Underground Storage Tank Section as having reported
a leaking petroleum underground storage tank on June 1, 1989.
3) Property at 927 Pressley Road known as Climate Conditioning of
Charlotte located 0.2 miles northwest of the site. This property is
upgradient from the site and is listed with the Division of Waste
Management-Underground Storage Tank Section as having reported
a leaking petroleum underground storage tank on December 27, 1994.
In addition, Page # 11 of the "Vista Site Assessment Report" shows
4
that at one time this company removed three underground storage
tanks that contained gasoline.
4) Observer Transport Company located 0.3 miles northwest of the site
at 1001 Pressley Road. This property is upgradient from the site and
is listed with the Division of Waste Management-Underground
Storage Tank Section as having reported three gasoline leaks on April
12, 1988, April 17, 1992, and April 15, 1994. Page # 12 of the "Vista
Site Assessment Report" shows that two of these tanks contained
"Gasoline" and "Diesel Fuel". The third tank contained a product
described as "Petroleum Other".
5) Xerox Corporation located 0.35 miles northwest of the site at 4740
Dwight Evans Road. This property is upgradient from the site and is
listed with the Division of Waste Management-Underground Storage
Tank Section as having reported a leaking petroleum underground
storage tank on September 30, 1986. Page # 12 of the "Vista Site
Assessment Report" shows that this tank contained "Gasoline" and
"Diesel Fuel".
6) White Machines which is located 0.53 miles north of the site at 4300
Barringer Drive. This property is cross-gradient from the site and is
listed with the Division of Waste Management-Undergr-o1:1nd Storage
Tank Section as having reported a leaking petroleum underground
storage tank on March 21, 1990. Page# 13 of the "Vista Site
Assessment Report" shows that this tank contained "Gasoline" and
"Diesel Fuel".
7) Piedmont Natural Gas which is located 0.4 miles east of the site at
Verbena & Yancey Streets. This property is downgradient from the
site and is listed in the variance request as having reported a leaking
petroleum underground storage tank on January 15, 1990. Page# 13
of the "Vista Site Assessment Report" shows that this tank contained
"Gasoline" and "Diesel Fuel".
8) Industrial Truck Sales which is located approximately 0.1 miles east
of the site at 3910 Stuart Boulevard. This property is downgradient
from the site and is listed in the variance request as a "RCRA small
quantity generator". Page# 9 and# 10 of the "Vista Site Assessment
Report" shows that underground storage tanks have also been at this
property. Three tanks have been removed consisting of one 8,000
gallon gasoline tank, a 1,000 gallon oil tank, and a 250-gallon oil tank.
One 500-gallon oil tank is list as "active/in service" at this property.
5
9) Ryder Truck Rental Incorporated which is located approximately
0.11 miles east of the site at 3901 Stuart Boulevard. This property is
down gradient from the site and is listed in the .variance request as a
"RCRA small quantity generator". Page# 10 and 11 of the "Vista
Site Assessment Report" shows that eight "in service" underground
storage tanks are present at this property containing "gasoline, diesel
fuel, motor oil, oil" and a fluid described as "hazardous".
10) Chemlawn Services Corporation which is located approximately 0.03
miles southeast at 655-R Pressley Road. This property isJocated
downgradient from the site. Appendix A shows that this site once had
a 2,000 gallon underground storage tank for diesel fuel. This tank is-
listed as "removed" from the property.
11) Page# 9 of the "Vista Site Assessment Report" shows two "in service"
underground storage tanks at the RSM Company located at 811
Pressley Road located approximately 0.09 miles northwest. This
property is upgraident from the site.
12) Page# 12 of the "Vista Site Assessment Report" shows that Ridgeway
Chemicals Incorporated has three underground storage tanks at 651
Michael Wylie Drive located 0.25 miles northeast of the site. These
tanks are listed as "active/in.service" in the report. A 1,000 gallon
tank was removed from this site. The contents of all four tanks are
reported as "unknown". This property is cross-gradient from the
site.
13) Pressley Road ( a public roadway).
14) Public sewer lines and other utilities in the area.
15) Southern Railroad (a private rail company).
In addition, Page #15 through Page # 17 of Appendix A shows eight known
sources of groundwater contamination in the general area near 711 Pressley Road.
Due to inadequate information on the location of these sites, it is not possible to
represent them on maps contained in Appendix A. Scaled diagrams of this site are
found in Figures# 1 through# 4 and Figure# 11 of the report titled "Variance
Req uest -Carolina Coatings Site -Charlotte, North Carolina, December 9, 1996,
Dames and Moore N.C. Job No.23995-002-200." !.
6
Rule .Ol 13 (c )(3 ): Descri ption of the pro posed area for which the variance is req uested .... :
Maps of the area are shown in Figures 1 through 5 of the report titled
"Variance Req uest-Carolina Coatin e s Site -Charlotte, North Carolina, December
9, 1996, Dames and Moore N.C. Job No.23995-002-200.". The property at-711
Pressley Road for which Carolina Coatings Incorporated has requested this
variance for Groundwater Incident Number 8949 is within an area consisting of a
mixture of residential, commercial and industrial development. The map on Figure
11 shows that the property is bordered on its east side by Pressley Road and four
adjacent properties border the Carolina Coatings site on its north, south and west
sides. The Southern Railroad Line is to the west within 1,000 feet of the area in
which the release of substances occurred. The property on the west side is vacant
land identified under Mecklenburg County Tax Identification Number 145-291-07
and owned by Mr. Linwood Carter, who is also the proprietor of Carolina Coatings
Incorporated. In applying for a variance at 6500 North Tryon Street, Carolina
Coatings Incorporated did not include this adjacent property or any portion of it in
the request.
Table 4 in the report lists adjacent property owners by Mecklenburg County
Tax parcel numbers and addresses. The last column of this table locates these
adjacent properties relative to the site at 711 Pressley Road. Figure 11 shows these
properties and owners from a tax line map in Book 145, Pages 27-29 (Revised
5/7/96).
Figure 4 of the variance request also shows that the area of groundwater and
soil contamination prior to remedial actions was of an amorphous shape, much of
which extended beneath the former concrete pad and settling tanks. Since soil
removal activities and the implementation of the pump and treat cleanup system,
the area where substances are known to exist is shown in Figures 7 through 12 of the
variance request. These figures reveal that the area in which substances persist at
concentrations in exceedence of the Groundwater Quality Standards in 15A NCAC
2L .0202 is roughly in the shape of an ellipse. The groundwater contamination that
the Carolina Coatings Incorporated is responsible for encompasses both the
recovery well and Monitoring Well# 9 and appears limited to this area. Figures 8
through 10 and Figure 12 of the report shows that substances at 711 Pressley Road
Street have not migrated onto adjacent properties at concentrations above
Groundwater Quality Standards in 15A NCAC 2L .0202. This variance is for all
the land entirely within the property boundaries of 711 Pressley Road for which
Carolina Coatings Incorporated has cleanup responsibilities.
Pages 11 through 13 of the report titled "Variance Re q uest-Carolina
Coatin gs Site -Charlotte, North Carolina, December 9, 1996, Dames and Moore
N.C. Job No.23995-002-200" discusses groundwater contaminant migration and the
potential impact to water supply wells and surface streams in the area. Two water
supply wells are located within one-half mile of the site. These wells are 2,300 feet
south of the Carolina Coatings property at Y orkmont Road and Lochlane Drive.
The company could not ascertain if these water supply wells are currently in use as
7
a source of drinking water supply or other uses. Based on water use data and
hydrogeologic conditions in the general area, Carolina Coatings Incorporated does
not believe that this variance will have an effect on these wells. Based groundwater
flow calculations, the company does not believe that the variance will impact any
receptors near 711 Pressley Road.
Rule .0ll3(c)(4): Su pportin 2 information to establish that the variance will not endan2er
the p ublic health and safety ... :
This part of the variance concerns Groundwater Quality Standards shown in
15A NCAC 2L. 0202 and has been requested for Benzene, Ethylbenzene, and
Xylene(-o,-m, and p ). In ord-er to assess health impacts, groundwater sampling was
conducted at on-site monitoring wells to assess the extent of contamination, the
concentration levels of substances, and the movement of substances to adjacent
properties. Groundwater monitoring from Carolina Coatings Incorporated
indicates that substances released at this site do not pose a hazard to the public. As
shown in Figure 5, nine monitoring well were originally installed at 711 Pressley
Road by the company. During site renovation to remove soil and repair the
concrete storage pad, two of these wells (Monitoring Wells MW# 2 and MW# 8)
were abandoned by the company prior to the implementation of groundwater
cleanup.
Carolina Coatings has conducted quarterly groundwater sampling at
Monitoring Well MW# 3, Monitoring Well MW# 7, and Monitoring Well MW# 9
from March 1994 through October 1997. Monitoring Well MW# 3 is located
upgradient approximately 125 feet to 150 feet from the area in which the release of
substances occurred at the northwest property line. Monitoring Well MW# 7 is
located within 35 feet directly to the south-southwest of this area and is roughly
down-gradient to the area that was impacted by the release. Monitoring Well MW#
9 is within the area of the release and is slightly downgradient from Recovery Well
RW # 1. Thirteen separate sampling events occurred during this period. As shown
in an April 19, 1999 letter sent to Groundwater Section, the last sampling and
analysis at all monitoring wells occurred on October 9, 1997. Toluene has never
appeared in any sample taken from monitoring wells from this site above the
Groundwater Quality Standard.
Table 2 of the variance request and data in the April 19, 1999 letter shows
that Monitoring Well MW# 3 and Monitoring Well MW# 7 have never had
concentrations of substance above detectable limits. Only Monitoring Well MW#
9 has shown concentrations of Benzene, Ethylbenzene, and Xylene above the
Groundwater Quality Standards in 15A NCAC 2L .0202. The only substance that
appeared in Monitoring Well MW# 9 during the October 9, 1997 monitoring event
was Benzene at 0.002 milligrams per liter or 2.0 micrograms per liter. The
Groundwater Quality Standard for Benzene is 0.001 milligram per liter or 1.0
microgram per liter. It is also important to note that Table 2 shows several graphs
of the concentrations levels of substances analyzed from Monitoring Well MW # 9
8
from March 1994 to September 1996. Although Ethylbenzene and Xylene have
been reduced below respective Groundwater Quality Standards, the concentration
of Benzene from samples taken from this well have fluctuated over time. In
September 1995 this concentration was reduced below the Groundwater Quality
Standard but later "rebounded" to the extent that the Benzene level in this well was
in exceed of the standard during subsequent quarterly monitoring events. In order
to provide additional supporting data for this variance request, Carolina Coatings
Incorporated sampled the downgraident monitoring wells MW # 5 and MW # 6.
No substances were detected in these wells above Groundwater Quality Standards
in 15A NCAC 2L .0202.
The Division also required the Carolina Coatings Incorporated to evaluate
the effectiveness of groundwater cleanup efforts by examining concentrations of
substances in the recovery well used as a sump to collect dissolved hydrocarbons
from the site. This monitoring effort was necessary to understand the effect pump-
and-treat cleanup has had on concentrations of constituents at the site. Table 1 of
the report titled "Variance Re quest-Carolina Coatine s Site -Charlotte, North
Carolina, December 9, 1996, Dames and Moore N.C. Job No.23995-002-200"
provides a record of monthly groundwater samples obtained at the influent of the
recovery well for the pump-and-treat groundwater remediation system. This
monitoring was conducted from March 29, 1994 through October 30, 1996.
Except for Benzene, concentrations of substances monitored from the
recovery well have never exceeded the Groundwater Quality Standards in 15A
NCAC 2L .0202. Since monthly sampling of this recovery well influent began in
March 1994, the Benzene concentration has fluctuated from levels above the
Groundwater Quality Standard to below detectable limits. The highest
concentration of Benzene reported at this site was 0.0076 milligrams per liter or 7.6
micrograms per liter from the May 6, 1994 sampling event. The Groundwater
Quality Standard for Benzene is 0.001 milligram per liter or 1.0 microgram per
liter. Samples taken from September 30, 1996 through October 30, 1996 showed
concentrations of all substances below detectable limits.
From the information shown on Page 13 of the variance request, Carolina
Coatings Incorporated evaluated the impact granting a variance would have on
nearby receptors. The nearest downgradient adjacent property is a small strip of
the vacant land owned by Mr. Linwood Carter which is approximately 110 feet
from the area in which substances were released at 711 Pressley Road. Based on an
average hydraulic conductivity of 0.06 feet per day, an approximate hydraulic
graident of 0.01 feet per foot, and an effective porosity of 20 percent for silty clay,
the groundwater flow is calculated at 1.1 feet per year. Assuming no contaminant
dilution or attenuation and this figures, it is believed that it would take 100 years for
the plume of substances to reach this property boundary. In addition to
groundwater flow calculations, Carolina Coatings Incorporated has also submitted
the results of modeling using the Domenico Solute Transport Model for this site as
discussed on Page 13 of the report titled "Variance Re q uest -Carolina Coatine s
Site -Charlotte, North Carolina, December 9, 1996, Dames and Moore N.C. Job
No. 23995-002-200". The results of this modeling support the companies view that
9
this variance will not impact adjacent properties. Data from this modeling may be
found in Appendix B of the variance request.
No water supply wells were identified at adjacent properties to 711 Pressley
Road. A well survey only identified only two water supply wells within the ½ mile
radius of the site as specified under 15A NCAC 2L .0113(c)(4). -These are located in
Figure 2 of the variance request at the intersection of Lochlane Drive and Y orkmont
Road app-roximately 2,300 feet south of 711 Pressley Road. According to the
information in this request, these wells are cross-gradient from the site. Page 12
states that is not known if these wells are being used as a source of drinking water
supply or for purposes other than drinking water. Drinking water for the City of
Charlotte is obtained from Mountain Island Lake on the Catawba River twelve
miles north of the site. All downgradient properties and other area properties are
supplied drinking water from the City of Charlotte.
'It is hig)!ly improbable that public water supply lines will be impacted by
this variance. Numerous water supply lines and other utilities are located along
Pressley Road, Bishop Drive and Yorkwood Road. Contacts with the Charlotte
Mecklenburg Utility Department and found that utilities are not a potential path for
migration of petroleum hydrocarbons from the site. Page 12 of the variance request
shows that the depth to the groundwater in this area is approximately 15 feet to 20
feet. The utility department reported that area water lines and utilities are buried
less than five (5) feet from the surface. Groundwater contamination from Incident
Number 8949 that is beneath 711 Pressley Road is too deep within the subsurface to
impact these lines. In addition, Page 12 also states the Carolina Coatings
Incorporated does not believe any buildings with basements will be impacted by this
variance request.
Rule .0113 {c){5): Su pp ortin g information to establish that re q uirements of the rule cannot
be achieved bv providin g best available technolo gv economicallv reasonable:
The part of the request that concerns variance to Corrective Action in 15A
NCAC 2L .0106(j) will allow Carolina Coatings Incorporated to discontinue
Corrective Action at this site. The company has submitted suppo-rting information
in the report with other documents demonstrating that the continued application of
best available technology will not result in significant long term remediation of the
site to the Groundwater Quality Standards contained in 15A NCAC 2L .0202. The
is due to the high probability that continued cleanup activities at the site will not
significantly reduce contaminant levels below the Groundwater Quality Standards
in 15A NCAC 2L .0202.
Since discovery of the release in 1991, Carolina Coatings Incorporated has
disposed of a total of 2,400 cubic yards of BTEX contaminated soil. Page 6 of the
report titled "Variance Re quest -Carolina Coatin gs Site -Charlotte, North
Carolina, December 9, 1996 , Dames and Moore N.C. Job No.23995-002-200" states
that the company has treated approximately 328,500 gallons of groundwater to
10
comply with the cleanup requirements of the Corrective Action Plan that was
implemented in March 24, 1994. Pages 15 through 16 of the report titled
"Variance Request-Carolina Coatings Site -Charlotte, North Carolina, December
9, 1996, Dames and Moore N.C. Job No.23995-002-200" states that a total of
$493,000 has been expended to design and install the remediation system, operate
the system, monitor progress of cleanup activity, and cleanup this site. Page 15 of
the variance request shows that the owner of Carolina Coatings Incorporated, Mr.
Linwood Carter, is retired and is reported in the variance request as financing the
cleanup of this site from this personal savings. He has had no direct employment
since the sale of the property at 711 Pressley Road in 1991 to Wattyl Paints
Incorporated.
Groundwater analysis of samples from on-site monitoring wells showed
significant reductions in the concentrations of substances from March 1995 through
October 9, 1997. As previously stated the groundwater pump-and-treat cleanup
system operated from March 24, 1994 through January 1997. Except for
Monitoring Well# 9, Benzene and other substances related to paint mixing
operations have riot been observed above Groundwater Quality Standards from
quarterly groundwater samples. Although concentrations of Benzene, Toluene,
Ethylbenzene, and Xylenes have been significantly reduced near Monitoring Well#
9 since cleanup operations began, the concentration of Benzene at a portion of this
site remains at levels in exceedence of the Groundwater Quality Standard in 15A
NCAC 2L .0202. Page 7, Page 8, and Table 3 of the report titled "Variance Request
-Carolina Coatings Site -Charlotte, North Carolina, December 9, 1996, Dames and
Moore N.C. Job No .23995-002-200" shows that after the pump-and-treat cleanup
system was temporarily taken out of operation for a period of five days,
concentrations of substances in monitoring wells, including Monitoring Well# 9, did
not change significantly. Table 1 shows that while the cleanup system was in
operation, results from groundwater samples taken from the influent of Recovery
Well RW # 1 during the period of March 29, 1994 through October 30, 1996,
revealed remaining concentrations of substances beneath 711 Pressley Road had
been significantly reduced such that they could no longer be detected.
In order to demonstrate that the requirements of the rule cannot be achieved
using best available technology, title 15A NCAC 2L .0113(c)(5) requires that specific
technology considered be identified, the costs of implementing the technology be
shown, and the impacts of the costs on the applicant be provided. Page 16 of the
report titled "Variance Request -Carolina Coatings Site -Charlotte, North
Carolina. December 9, 1996, Dames and Moore N.C. Job No.23995-002-200" states
that continued operation and monitoring at 711 Pressley Road will cost Carolina
Coatings approximately $48,000 per year. In addition, Page 14 of the request
shows that in order to continue cleanup with the pump-and-treat system, significant
upgrades will be needed for this system. These modifications include the installation
of additional groundwater recovery wells, new pumps, and renovations to increase
the size of the infiltration gallery. The company believes that the _low residual levels
of contaminants in the groundwater at this site does not warrant the continued use
of the pump-and-treat cleanup system. -
11
Carolina Coatings Incorporated has considered the use of air sparging with
soil vapor extraction (SVE) as alternate technology to the present pump-and-treat
cleanup system. This technology is an in-situ remediation method that involves the
physical introduction of air below the water table to volatilize groundwater
contaminants from groundwater and subsurface materials into a vapor phase. The
SVE portion of this system captures the volatilized substances so that they may be
removed from the subsurface environment. As shown on Page 15 of the report
titled "Variance Re q uest -Carolina Coatine s Site -Charlotte, North Carolina,
December 9, 1996, Dames and Moore N.C. Job No.23995-002-200" states that the
average hydraulic conductivity in saturated zone beneath the site is 2 x 10-5
centimeter per second. Based on this low permeability, Carolina Coatings does not
believe the use of this type of technology will be effective at removing substances
that remain at 711 Pressley Road.
Carolina Coatings Incorporated did not identify any technology, other than
those already at the site and alternate technology identified in the variance, that
would meet the requirements of 15A NCAC 2L .0106G) as "best available
technology". Pursuant to the requirements of 15A NCAC 2L .0113(c)(5), the
company does not believe that continuing remediation is economically reasonable.
Rule .0113 (c)(6): Su pp ortine information to establish that com pliance would produce
serious financial hardship on the a pp licant:
Carolina Coatings Incorporated has submitted information showing that
compliance with the rules will result in a serious financial hardship. Page 15 of the
variance request shows that the owner of Carolina Coatings Incorporated, Mr.
Linwood Carter, is retired and is reported in the variance request as financing the
cleanup of this site from this personal savings. He has had no direct employment
since the sale of the property at 711 Pressley Road in 1991 to Wattyl Paints
Incorporated. Allowing the persistence of low levels of contaminants in -
groundwaters that, after approximately three years of applying best available
technology, have asymptotically approached the Groundwater Quality-Standards in
15A NCAC 2L .0202 through a variance is a prudent means of addressing Carolina
Coatings release at this site. It is no less effective a means of addressing residual
concentrations of substances at this site than continuing the use of pump-and-treat
system and is less expensive.
12
Rule .0113 (c)(7): Su pportin2 information that com p liance would produce serious financial
hardshi p without eq ual or greater p ublic benefit:
The company has submitted information in the request demonstrating that
the environment, safety and public health would not be impacted by this variance.
A January 6, 1997 letter from the Mooresville Regional Office serves as a
justification for this variance as it states that " ....... continuation of pump and treat
remediation is neither cost effective nor environmentally beneficial". The letter
further states that the "Risk to the public is minimal considering the lack of active
water supply well systems, distance to surface water bodies, and the industrial
character of the site and surrounding sites.".
Rule .0113 (c)(8): "A co pv of an v Sp ecial Order ... ":
No Special Order by Consent has been issued for this site.
Rule .0113 (c)(9): "A list of names and addresses of p ro perty owners ... ":
The property owners within the proposed area of the variance are shown in
Table 4 and the map in Figure 11 of the report titled "Variance Req uest -Carolina
Coatin gs Site -Charlotte, North Carolina, December 9, 1996, Dames and Moore
N.C. Job No.23995-002-200". This listing includes the Trimming-Associates LTD,
the Presseley Park Restaurant owned by Ionnis and Gregory Andreas, Rebpat
Leasing, Joachim H. Klitzsch, James A. Williams, J. David Fortenbery, Davis
Brothers Venture, Exit Fourteen Associates, the former Carolina Coatings site at
711 Pressley Road now owned by Wattyl Paints, John W. Layne, Linwood T. Carter
(property adjacent to 711 Pressley Road), the North Carolina Department of
Transportation, Southern Railroad, and two parcels of land owned by Eight
Hundred Eleven Pressley. Title 15A NCAC 2L .0113(e)(E) requires that
notification of a public hearing on this variance be given to the owner or owners of
these adjacent properties "at least 30 days prior to the date of the hearing".
It is the recommendation of the Groundwater Section that the subject variance
request to Corrective Action requirements of 15A NCAC 2L .0106(j) and Groundwater
Quality Standards contained in 15A NCAC 2L .0202 proceed to public notice in
accordance with 15A NCAC 2L .0113(e). On February 27, 1997, the Division of
Epidemiology completed their review of the risk assessment methodology for this site and
recommended that this variance be granted for Carolina Coatings Incorporated at their
former property located at 711 Pressley Road in Charlotte, North Carolina. Upon your
concurrence with our recommendation, the Groundwater Section will proceed with the
13
preparation of the required public notice and hearing. Upon completing of the
requirements of 15A NCAC 2L .0113(d-f), with a recommendation to grant this variance
from the Environmental Management Commission Groundwater Committee, this request
will proceed to the Environmental Management Commission for final action in 15A NCAC
2L .0113(g). If there are any questions regarding this matter or if any additional
information is needed, please let me know.
ATTACHMENTS:
cc: Groundwater Section Assistant Chiefs
Mooresville Regional Groundwater Supervisor
Dr. Ken Rudo
David Hance
14
NOTICE OF VARIANCE APPLICATION AND HEARING
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
Notice is hereby given of a variance application and public hearing to be held by the Department of
Environment and Natural Resources on behalf of the Environmental Management Commission. The hearing
concerns a request for a variance from the Groundwater Quality Standards of 15A NCAC 2L .0202 and the
Corrective Action requirements of 15A NCAC 2L .0106 (j) for a site at 711 Pressley Road in Charlotte, North
Carolina. The Division of Water Quality refers to this site identified in the variance request as Groundwater
Incident # 8949. This property consists of 6.17 acres of land was previously owned by the proprietor of
Carolina Coatings Incorporated, Mr. Linwood Carter, and was used as a solvent-based paint mixing facility
until 1991. The property is now owned by Wattyl Paints of Atlanta, Georgia. Carolina Coatings Incorporated
is entirely responsible for cleanup for Groundwater Incident# 8949. This variance application from Carolina
Coatings Incorporate~ was received for review by the Department on December 9, 1996.
The property where the release of volatile organic substances has occurred is located as follows: Inside
the city limits of Charlotte, North Carolina. Take Interstate 77 in Charlotte and exit onto South Tryon Street
(NC 49) and proceed one block north. Tum left (west) onto Pressley Road for 0.38 miles. The former
Carolina Coatings facility is located on the left. The site is listed in Mecklenburg County tax records as
Parcel Number 145-291-03.
Carolina Coatings Incorporated requests that the Environmental Management Commission grant the
following variance to its rules under the authority of 15A NCAC 2L .0113 so that if does the following:
(1) Allow concentrations of Benzene, Ethylbenzene, and Xylene (-o,-m, and p) to remain at levels
above 15A NCAC 2L .0202 Groundwater Quality Standards as analyzed on October 9, 1997 in all
monitoring wells. These concentrations will be required to remain within the property boundaries of
711 Pressley Road. Pursuant to the transfer of ownership of this property in 1991, Mr. Carter had
environmental assessments conducted of soils and groundwater at this site. Benzene, Ethylbenzene,
Toluene and Xylene (BETX) were found in soils around this site and groundwater samples showed
the presence of several volatile organic compounds such as Benzene, Ethylbenzene and Xylene.
Since the transfer of ownership of this property to Wattyl Paints all solvent-based paint mixing
operations have ceased and were moved to Atlanta, Georgia. Only latex water-based paint mixing has
been conducted at this property since 1991. All potential sources of groundwater contamination have
been identified at this property by Carolina Coatings Incorporated. The entire property at 711
Pressley Road is located in an area with a mixture of commercial, industrial, and residential
development.
Site assessments were completed by September 1992 and a remedial action plans for this site
were submitted in late spring 1993. The site assessments revealed a plume of substances in soil and
groundwater. Site assessment information on file in the Mooresville Regional Office shows that the
vertical extent of this plume to be less than 48 feet below the ground surface. · This plume was
estimated to have covered an area of approximately 10,000 square feet (0.23 acres) prior to the
implementation of corrective actions by Carolina Coatings Incorporated.
From June 2, 1993 through January 1997 concentrations of substances at this site were
significantly reduced by soil removal operations and groundwater cleanup technologies located at the
site. A concrete pad and waste water settling tanks were removed during this renovation and clean
1
fill material was used in place of this contaminated soil. In July 1993 the company installed a
groundwater pump-and-treat cleanup system and it began operation on March 24, 1994.
Except for one monitoring well located in the area where the plume of groundwater
contamination has been identified (Monitoring Well MW-9), concentrations of substances have never
exceeded quantifiable levels. Since December 1994 analysis of samples, MW-9 showed only
marginal reductions in the concentration of substances in groundwater. Based on groundwater
ana1ysis of samples from semi-annual monitoring from 1993 through 1996, the Division of Water
Quality recommended that pump and treat system be turned off to determine if residual concentrations
of substances would increase, if no treatment system were operating. From August 27, 1996 through
September 3, 1996 the cleanup system ceased operation. A groundwater sample taken on September
3, 1996 demonstrated upward "rebounding" of Benzene above the Groundwater Quality Standard in
15A NCAC 2L . 0202 in monitoring well MW-9. Analysis of a groundwater sample taken on October
9, 1997 through showed the Ethylbenzene or Xylene concentrations did not exceed detection limits
and the Benzene concentration was 0.002 milligrams per liter. The Groundwater Qualily Standard
for Benzene is 0.001 milligrams per liter.
The company has also conducted monitoring at a recovery well near monitoring well MW-9. This
recovery well is used as a sump to collect groundwater and other liquids for removal by the pump-and-
treat cleanup systems. Groundwater monitoring at the inlet of this recovery well sampled on
September 30, 1996 and October 30, 1996 showed that concentrations ofBTEX were below detectable
levels. This monitoring occurred after the cleanup system had been turned off for a period of five
days.
Based on concentrations of substances found in monitoring wells, substances found in the well
used for recovery of contaminants, and calculations of the time it would take for substances to migrate
to receptors at surrounding properties, the company does not believe that a variance will result in an
adverse impact to the public. There are no drinking water supply wells at adjacent properties and the
nearest water supply wells are 2,300 feet cross gradient from the site. No water supply intakes from
surface water bodies are located within ½ of a mile from the site. Public water supply lines are
deemed too shallow to be impacted by substances at 711 Pressley Road.
(2) Allow for the restoration of groundwater without requiring continued remedial actions in
accordance with 15A NCAC 2L .0106(j). Carolina Coatings Incorporated has submitted supporting
information demonstrating that the continued application of best available technology will not result
in significant long term remediation of the site to the Groundwater Quality Standards contained in
15A NCAC 2L .0202. This is due to the high probability that continued remediation activities at the
site will not significantly reduce contaminant levels below Groundwater Quality Standards in 15A
NCAC 2L .0202.
Since discovery of the release in 1991, Carolina Coatings Incorporated has disposed of a total of
2,400 cubic yards of contaminated soil during site renovation operations in June 1993. Carolina
Coatings Incorporated has submitted information showing that the company has treated a total of
328,500 gallons of groundwater via pump-and-treat technology. The company reports that a total of
$ 493,000 has been expended to design and install the remediation system, operate the system,
monitor progress of cleanup activity, and cleanup this site. Carolina Coatings Incorporated believes
that the public will not benefit from continued cleanup using present technology at the site or the
alternatives discussed and that a variance is the most effective means of dealing with remaining
concentrations.
2
i
I I
i
\
Author: David Hance at NRGWS0lP
Date: 6/23/1999 3:57 PM
friority: Urgent
Receipt Requested
TO: Art [e-mail] at Internet
TO: [e-mail] at Internet
TO: Matt [e-mail] at Internet
CC: Arthur Mouberry
CC: Carl Bailey
CC: David Hance
CC: Burrie Boshoff
CC: Barbara [e-mail] at Internet
Subject: re: Variances/ 2L/ Charlotte/Public hearings
------------------------------------Message Contents------------------------------------
Hello Art and others:
we have been getting some work done on some variances in the
Mooresville Regional Office. Art Barnhardt, Groundwater Supervisor
in the Fayetteville Regional Office e has been designated the hearing
officer for the two variances to 15A NCAC 2L .0113. You recall that
these variances are for the Emro Marketing Company (6500 North Tryon
Street) for a tank release and for Carolina Coatings Incorporated for
releases from a paint mixing facility.
Based on Art's advice and the 15A NCAC 2L .0113 variance hearing
requirements, I have found a location, time and date for these
hearings. We intend to hold the Carolina Coatings hearing will be
held on:
** August 12, 1999 at 7:00 PM at the Charlotte Mecklenburg County
Courthouse. The Emro Marketing Variance will go to hearing on the same
evening at the same location at 8:00 PM. ***
Since you Matt Heller have been overseeing the Carolina Coatings
facility for the GWS in the MRO and you Allen Schiff have been
providing oversight for the Emro facility, you are the best persons to
serve as technical staff to present these variances at the hearings.
You would also assist the hearing officer in making his recommendation
to the Environmental Management Commission.
Notices have been prepared for the Directors signature and will be
sent out. You will all get a copy of this. Upon a final decision by
the Commission, there will be no more variances in .the Mooresville
Region as of the date of this e-mail. In addition, once the Emro
Marketing Company variance receives a final decision by the
Commission, there will be no more variances from the Division of Waste
Management.
Please contact me at 919-715-6189 if we need to talk or send an
email back to me.
DAVID HANCE
..
NOJ'ICE OF VARIANCE APPLICATION AND HEARING
DEPARTMENT OF ENVIRONMENT AND NATURAL
RESOURCES
DIVISION OF WATER QUALITY
Notice is hereby given of a variance application and public hearing to be held by the Department of
Environment and Natural Resources on behalf of the Environmental Management Commission. The hearing
concerns a request for a variance from the Groundwater Quality Standards of 15A NCAC 2L .0202 and the
Corrective Action requirements of 15A NCAC 2L .0106 G) for a site at 711 Pressley Road in Charlotte, North
Carolina. The Division of Water Quality refers to this site identified in the variance request as Groundwater
Incident# 8949. This property consists of 6.17 acres of land was previously owned by the proprietor of
Carolina Coatings Incorporated, Mr. Linwood Carter, and was used as a solvent-based paint mixing facility
until 1991. The property is now owned by Wattyl Paints of Atlanta, Georgia. Carolina Coatings Incorporated
is entirely responsible for cleanup for Groundwater Incident# 8949. This variance application from Carolina
Coatings Incorporated was received for review by the Department on December 9, 1996.
The property where the release of volatile organic substances has occurred is located as follows: Inside
the city limits of Charlotte, North Carolina. Take Interstate 77 in Charlotte and exit onto South Tryon Street
(NC 49) and proceed one block north. Tum left (west) onto Pressley Road for 0.38 miles. The former
Carolina Coatings facility is located on the left. The site is listed in Mecklenburg County tax records as
Parcel Number 145-291-03.
Carolina Coatings Incorporated requests that the Environmental Management Commission grant the
following variance to its rules under the authority of 15A NCAC 2L .0113 so that it does the following:
(1) Allow concentrations of Benzene, Ethylbenzene, and Xylene (-o,-m, and p) to remain at levels
above 15A NCAC 2L .0202 Groundwater Quality Standards as analyzed on October 9, 1997 in all
monitoring wells. These concentrations will be required to remain within the property boundaries of
711 Pressley Road. Pursuant to the transfer of ownership of this property in 1991, Mr. Carter had
environmental assessments conducted of soils and groundwater at this site. Benzene, Ethy I benzene,
Toluene and Xylene (BETX) were found in soils around this site and groundwater samples showed
the presence of several volatile organic compounds such as Benzene, Ethylbenzene and Xylene.
Since the transfer of ownership of this property to Wattyl Paints all solvent-based paint mixing
operations have ceased and were moved to Atlanta, Georgia. Only latex water-based paint mixing has
been conducted at this property since 1991. All potential sources of groundwater contamination have
been identified at this property by Carolina Coatings Incorporated. The entire property at 711
Pressley Road is located in an area with a mixture of commercial, industrial, and residential
development.
Site assessments were completed by September 1992 and a remedial action plans for this site
were submitted in late spring 1993. The site assessments revealed a plume of substances in soil and
groundwater. Site assessment information on file in the Mooresville Regional Office shows that the
vertical extent of this plume to be less than 48 feet below the ground surface. This plume was
estimated to have covered an area of approximately 10,000 square feet (0.23 acres) prior to the
implementation of corrective actions by Carolina Coatings Incorporated.
1
bJl,A
corn~r of the building near an 88 foot by 66 foot concrete pad and three small . q~
wastewater settling tanks. This was where the company stored chemicals and
performed batched mixing operations for solvent-based paints. This area is
approximately 10 feet from the northwest property line and 75 feet from the
southwest property line. The entire property at 711 Pressley Road is surrounded
by a fence. This plume was estimated to have covered an area of approximately
10,000 square feet (0.23 acers) prior to the implementation of corrective actions by
the Carolina Coatings Incorporated. According to information at the Mooresville
Regional Office the vertical extent of this plume is believed to be less than 48 feet
below the ground surface.
Carolina Coatings Incorporated implemented cleanup of soils at this site in
September 1992 with the removal of 900 cubic yards of soil that exceeded the 50
milligram per kilogram target cleanup level. Between June 2, 1993 and June 25,
1993, the company removed an additional 1,500 cubic yards of contaminated soils.
Excavated soils were treated offsite and clean fill material was used as backfill. As a
result of soil remediation, the concrete pad was removed and subsequently replaced.
In July 1993 the company installed a pump-and-treat system with a single
groundwater recovery well (RW-1) located near the south corner of the former
concrete storage pad as shown in Figure 6 of the variance. From March 23, 1994
through January 1997 a total of 328,500 gallons of groundwater has been treated via
pump-and-treat technology. The treated discharge was sent to an upgraident
infiltration gallery. An infiltration gallery is a closed-loop conveyance that allows
water and other fluids, discharged through the pump-and-treat system, to be sent
back into the subsurface where they recirculated into the cleanup system for
continual treatment. An infiltration gallery may also serve to enhance intrinsic
biodegradation of contaminants by introducing dissolved oxygen in the subsurface
which may stimulate biologic decomposition of some dissolved substances. Non-
Discharge Permit WQ0007993 was issued on January 18, 1994 for the infiltration
gallery. The Groundwater Section staff have recommended that, if the variance
request is granted, no permit for this infiltration gallery is to be reissued. The
company's environmental consultant, Dames and Moore, reports that this device
will no longer be used once the variance is granted.
The Division of Water Quality required Carolina Coatings Incorporated to
perform groundwater monitoring to determine the vertical and lateral extent of
contamination at the site. Table 2 of the report titled "Variance Request -Carolina
Coatings Site -Charlotte, North Carolina, December 9 , 1996, Dames and Moore
N.C. Job No.23995-002-200" shows that three of six monitoring wells were sampled
from March 1994 through September 1996 on a quarterly schedule. Groundwater
samples were analyzed using US Environmental Protection Method 8020. Page 6 of
the variance request shows that only Monitoring Well# 9 has had concentrations of
Benzene, Ethylbenzene, and Xylene above the Groundwater Quality Standards in
15A NCAC 2L .0202. Toluene has never appeared in any of the monitoring wells a f-0.....
concentration in excess of the Groundwater Quality Standard in 15A NCAC 2L
3
bJt , .
. 0202. Table 2 of the report titled "Variance Req uest -Carolina Coatings Site -· · -~!/
Charlotte, North Carolina, December 9, 1996 , Dames and Moore N.C. Job
No.23995-002-200" shows that the highest concentration of Benzene, Ethylbenzene,
and Xylene have been found in this well. The highest concentration of Benzene in
exceedence of the Groundwater Quality Standard was 0.027 milligrams per liter or
27 micrograms on September 3, 1996. The highest concentration of any substance
in exceedence of the 15A NCAC 2L .0202 Groundwater Quality Standard found at
this site was Xylene (o,p,m). Xylene appeared at the December 1994 monitoring
event at 0.860 milligrams per Liter or 860 micrograms/Liter.
As shown on Table 1 of the report titled "Variance Req uest -Carolina
Coatings Site -Charlotte, North Carolina, December 9, 1996 , Dames and Moore
N.C. Job No.23995-002-200"from March 29, 1994 through October 30, 1996, the
company conducted analysis of samples from Recovery Well# 1 on the influent side
of the cleanup system to determine the effectiveness of the pump-and-treat cleanup.
This data shows that the source of the groundwater contamination at this site has
been significantly reduced such that the plume can no longer be detected.
Based on the results of the groundwater monitoring and recovery well
monitoring in September and October 1996, the Carolina Coatings requested a
variance and that the pump and treat groundwater cleanup system be shut off. In
January 1997 the Mooresville Regional Office agreed that active cleanup should be
discontinued. Based on the results of groundwater monitoring and monitoring of
influent samples in the recovery well from the pump and treat cleanup system the
cleanup system was turned off. This variance request encompasses the entire
property at 711 Pressley Road in Charlotte, North Carolina.
Potential sources of groundwater contamination in the area are discussed in
Pages 9 through 11 and in Appendix A of the report titled "Variance Req uest-
Carolina Coatings Site -Charlotte, North Carolina, December 9, 1996 , Dames and
Moore N.C. Job No.23995-002-200." . Appendix A shows Vista Site Assessment
Reports of these properties with maps. Potential sources of groundwater
contamination are summarized as follows:
1) The property at 711 Pressley Road formerly owned by Carolina
Coatings Incorporated (Mecklenburg County Tax Identification
Number 145-291-03). This site is now owned by Wattyl Paints. The
Vista Site Assessment Report lists this site on the state "CERCLIS"
and as a "Large Quantity Generator" of hazardous wastes.
2) The property at 807 Pressley Road known as The Gifford-Hill
Company located 1/10 of a mile northwest of the site. This property is
upgradient from the site and is listed with the Division of Waste
Management-Underground Storage Tank Section as having reported
a leaking petroleum underground storage tank on June 1, 1989.
4
.. ~
1 t· ;~1-;., -~ ~ ..,~
• r , • ./Jtt/li,,J,,'7:1
3) Property at 927 Pressley Road known as Climate Conditioning of
Charlotte located 0.2 miles northwest of the site. This property is
upgradient from the site and is listed with the Division of Waste
Management-Underground Storage Tank Section as having reported
a leaking petroleum underground storage tank on December 27, 1994.
In addition, Page # 11 of the "Vista Site Assessment Report" shows
that at one time this company removed three underground storage
tanks that contained gasoline.
4) Observer Transport Company located 0.3 miles northwest of the site
at 1001 Pressley Road. This property is upgradient from the site and
is listed with the Division of Waste Management-Underground
Storage Tank Section as having reported three gasoline leaks on April
12, 1988, April 17, 1992, and April 15, 1994. Page# 12 of the "Vista
Site Assessment Report" shows that two of these tanks contained
"Gasoline" and "Diesel Fuel". The third tank contained a product
described as "Petroleum Other".
5) Xerox Corporation located 0.35 miles northwest of the site at 4740
Dwight Evans Road. This property is upgradient from the site and is
listed with the Division of Waste Management-Underground Storage
Tank Section as having reported a leaking petroleum underground
storage tank on September 30, 1986. Page # 12 of the "Vista Site
Assessment Report" shows that this tank contained "Gasoline" and
"Diesel Fuel".
6) White Machines which is located 0.53 miles north of the site at 4300
Barringer Drive. This property is cross-gradient from the site and is
listed with the Division of Waste Management-Underground Storage
Tank Section as having reported a leaking petroleum underground
storage tank on March 21, 1990. Page# 13 of the "Vista Site
Assessment Report" shows that this tank contained "Gasoline" and
"Diesel Fuel".
7) Piedmont Natural Gas which is located 0.4 miles east of the site at
Verbena & Yancey Streets. This property is downgradient from the
site and is listed in the variance request as having reported a leaking
petroleum underground storage tank on January 15, 1990. Page# 13
of the "Vista Site Assessment Report" shows that this tank contained
"Gasoline" and "Diesel Fuel".
5
8) Industrial Truck Sales which is located approximately 0.1 miles east
of the site at 3910 Stuart Boulevard. This property is downgradient
from the site and is listed in the variance request as a "RCRA small
quantity generator". Page # 9 and # 10 of the "Vista Site Assessment
Report" shows that underground storage tanks have also been at this
property. Three tanks have been removed consisting of one 8,000
gallon gasoline tank, a 1,000 gallon oil tank, and a 250-gallon oil tank.
One 500-gallon oil tank is list as "active/in service" at this property.
9) Ryder Truck Rental Incorporated which is located approximately
0.11 miles east of the site at 3901 Stuart Boulevard. This property is
downgradient from the site and is listed in the variance request as a
"RCRA small quantity generator". Page # 10 and 11 of the "Vista
Site Assessment Report" shows that eight "in service" underground
storage tanks are present at this property containing "gasoline, diesel
fuel, motor oil, oil" and a fluid described as "hazardous".
10) Chemlawn Services Corporation which is located approximately 0.03
miles southeast at 655-R Pressley Road. This property is located
downgradient from the site. Appendix A shows that this site once had
a 2,000 gallon underground storage tank for diesel fuel. This tank is
listed as "removed" from the property.
11) Page# 9 of the "Vista Site Assessment Report" shows two "in
service" underground storage tanks at the RSM Company located at
811 P ress ley R oad loca ted approxima te ly 0.09 miles northwest. This
property is upgraident from the site.
12) Page # 12 of the "Vista Site Assessment Report" shows that Ridgeway
Chemicals Incorporated has three underground storage tanks at 651
Michael Wylie Drive located 0.25 miles northeast of the site. These
tanks are listed as "active/in service" in the report. A 1,000 gallon
tank was removed from this site. The contents of all four tanks are
reported as "unknown". This property is cross-gradient from the
site.
13) Pressley Road ( a public roadway).
14) Public sewer lines and other utilities in the area.
15) Southern Railroad (a private rail company).
6
<)
• From the information shown on Page 13 of the variance request, Carolina~
Coatings Incorporated evaluated the impact granting a variance would have on "7 ;{>
nearby receptors. The nearest downgradient adjacent property is a small strip of
the vacant land owned by Mr. Linwood Carter which is approximately 110 feet
from the area in which substances were released at 711 Pressley Road. Based on an
average hydraulic conductivity of 0.06 feet per day, an approximate hydraulic
graident of 0.01 feet per foot, and an effective porosity of 20 percent for silty clay,
the groundwater flow is calculated at 1.1 feet per year. Assuming no contaminant
dilution or attenuation and this figures, it is believed that it would take 100 years for
the plume of substances to reach this property boundary. In addition to
groundwater flow calculations, Carolina Coatings Incorporated has also submitted
the results of modeling using the Domenico Solute Transport Model for this site as
discussed on Page 13 of the report titled "Variance Req uest -Carolina Coatings
Site -Charlotte, North Carolina, December 9 , 1996 , Dames and Moore N.C. Job
No. 23995-002-200". The results of this modeling support the companies view that
this variance will not impact adjacent properties. Data from this modeling may be
found in Appendix B of the variance request.
No water supply wells were identified at adjacent properties to 711 Pressley
Road. A well survey only identified only two water supply wells within the ½ mile
radius of the site as specified under 15A NCAC 2L .0113(c)(4). These are located in
Figure 2 of the variance request at the intersection of Lochlane Drive and Y orkmont
Road approximately 2,300 feet south of 711 Pressley Road. According to the
information in this request, these wells are cross-gradient from the site. Page 12
states that is not known if these wells are being used as a source of drinking water
supply or for purposes other than drinking water. Drinking water for the City of
Charlotte is obtained from Mountain Island Lake on the Catawba River twelve
miles north of the site. All downgradient properties and other area properties are
supplied drinking water from the City of Charlotte.
'It is highly improbable that public water supply lines will be impacted by
this variance. Numerous water supply lines and other utilities are located along
Pressley Road, Bishop Drive and Y orkwood Road. Contacts with the Charlotte
Mecklenburg Utility Department and found that utilities are not a potential path for
migration of petroleum hydrocarbons from the site. Page 12 of the variance request
shows that the depth to the groundwater in this area is approximately 15 feet to 20
feet. The utility department reported that area water lines and utilities are buried
less than five (5) feet from the surface. Groundwater contamination from Incident
Number 8949 that is beneath 711 Pressley Road is too deep within the subsurface to
impact these lines. In addition, Page 12 also states the Carolina Coatings
Incorporated does not believe any buildings with basements will be impacted by this
variance request.
10
<>..t
Rule .0U3{c){5): Supporting information to establish that req uirements of the rule cannot ~
be achieved b y p roviding best available technolo gy economically reasonable:
The part of the request that concerns variance to Corrective Action in 15A
NCAC 2L .0106(j) will allow Carolina Coatings Incorporated to discontinue
Corrective Action at this site. The company has submitted supporting information
in the report with other documents demonstrating that the continued application of
best available technology will not result in significant long term remediation of the
site to the Groundwater Quality Standards contained in 15A NCAC 2L .0202. The
is due to the high probability that continued cleanup activities at the site will not
significantly reduce contaminant levels below the Groundwater Quality Standards
in 15A NCAC 2L .0202.
Since discovery of the release in 1991, Carolina Coatings Incorporated has
disposed of a total of 2,400 cubic yards of BTEX contaminated soil. Page 6 of the
report titled "Variance Req uest -Carolina Coatings Site -Charlotte, North
Carolina. December 9, 1996 , Dames and Moore N.C. Job No.23995-002-200" states
that the company has treated approximately 328,500 gallons of groundwater to
comply with the cleanup requirements of the Corrective Action Plan that was
implemented in March 24, 1994. Pages 15 through 16 of the report titled
"Variance Req uest-Carolina Coatings Site -Charlotte. North Carolina, December
9 , 1996, Dames and Moore N.C. Job No.23995-002-200" states that a total of
$493,000 has been expended to design and install the remediation system, operate
the system, monitor progress of cleanup activity, and cleanup this site. Page 15 of
the variance request shows that the owner of Carolina Coatings Incorporated, Mr.
Linwood Carter, is retired and is reported in the variance request as financing the
cleanup of this site from this personal savings. He has had no direct employment
since the sale of the property at 711 Pressley Road in 1991 to Wattyl Paints
Incorporated.
Groundwater analysis of samples from on-site monitoring wells showed
significant reductions in the concentrations of substances from March 1995 through
October 9, 1997. As previously stated the groundwater pump-and-treat cleanup
system operated from March 24, 1994 through January 1997. Except for
Monitoring Well# 9, Benzene and other substances related to paint mixing
operations have not been observed above Groundwater Quality Standards from
quarterly groundwater samples. Although concentrations of Benzene, Toluene,
Ethylbenzene, and Xylenes have been significantly reduced near Monitoring Well #
9 since cleanup operations began, the concentration of Benzene at a portion of this
site remains at levels in exceedence of the Groundwater Quality Standard in 15A
NCAC 2L .0202. Page 7, Page 8, and Table 3 of the report titled "Variance Req uest
-Carolina Coatin gs Site -Charlotte. North Carolina, December 9. 1996 , Dames and
Moore N.C. Job No .23995-002-200" shows that after the pump-and-treat cleanup
system was temporarily taken out of operation for a period of five days,
concentrations of substances in monitoring wells, including Monitoring Well# 9, did
11
Author: "Art Barnhardt GW" <Art [e-mail] .state.nc.us> at Internet
Date: 6/22/1999 12:22 PM
Priority: Normal
TO: David Hance at NRGWSOlP
Subject: re: Hearing officer for two variances
------------------------------------Message Contents------------------------------------
David:
Any of the days are fine with me. I PREFER the 12th.
ArtB .
Author: David Hance at NRGWS0lP
Date: 6/22/1999 10:44 AM
Priority: Urgent
Receipt Requested
TO: Art [e-mail] at Internet
CC: Arthur Mouberry
CC: Carl Bailey
CC: David Hance
Subject: re: Hearing officer for two variances
------------------------------------Message Contents------------------------------------
Art,
Arthur Mouberry asked me to contact you on the matter I am about to
discuss in this e-mail.
We have two requests for variances to the cleanup requirements and
standards in 15A NCAC 2L .0113. These variances are in Charlotte,
North Carolina. One is for a former batch paint mixing facility known
as Carolina Coatings Incorporated. The other is a UST release from
Emro Marketing Company. These companies have completed their
activities and the variances have been reviewed by the MRO and the
staff here at the CO. We are finalizing memoranda to the Director of
DWQ and notices for him to sign.
As required in the rule, we will be holding public hearings on
these variances. Arthur wants to conduct both hearings on a single
evening in downtown Charlotte. We will hold one hearing at 7:00 PM
and then another at 8:00 PM. We do not anticipate comments for
Carolina Coatings since the place is nearly clean and most of the
neighbors are industries or commercial properties. There are some in-
use water wells and abandoned water wells around the Emro Marketing
site and there is the potential for interest from the public. It's my
experience that very few people are interested in groundwater
variances at all, even when we send them notices.
Arthur felt that you would be excellent choice for hearing officer
for both of these variances. What I need to know from you is to find
out which evening is open for you to serve as hearing officer for
these variances. Because of 30-day notice requirements under 15A NCAC
2L .0113, the necessity for management signatures, and requirement to
get notices to area property owners, we anticipate the best week to
hold BOTH HEARINGS ON A SINGLE EVENING will occur during the week of:
> AUGUST 9TH THROUGH AUGUST 13TH <
The central office will be assisting you in getting your hearing
officers speech and other information on this variance. Technical staff
at the Mooresville Regional Office will present the variance to the
public. Matt Heller is the MRO GW Section staff handling the Carolina
Coatings Variance. Allen Schiff with the MRO/DWM/UST Section is
handling the Emro Marketing Variance.
Please let me know which evenings during this week is best for
you to serve as hearing officer. I need to check on the status of the
Charlotte Mecklenburg Courthouse during that week and need to provide
a date to them so we can reserve a courtroom. If necessary, we could
go to the following week.
calt 919-,15-6189. Please
greatly appreciate hearing
If you need to talk with me further please
respond by e-mail. If possible, I would
from you by tomorrow afternoon by 2:30 PM.
D. Hance
********************************************************************
p.s.--the Flynt Fabrics variance in you region is next after these.
********************************************************************
Author: Arthur Mouberry at NRGWS0lP
Date: 6/21/1999 4:51 PM
Priority: Normal
Receipt Requested
TO: David Hance
Subject: Re[4]: PUBLIC HEARINGS ON 2 UPCOMING VARIANCES
------------------------------------Message Contents------------------------------------
David,
Schedule them both for the same night. One at 7 and the other at 8.
Carolina Coating first .
Arthur
_________________ Reply Separator
Subject: Re[3]: PUBLIC HEARINGS ON 2 UPCOMING VARIANCES
Author: David Hance at NRGWS0lP
Date: 6/21/99 4:49 PM
Arthur,
WITHOUT SENDING OUT THE NOTICES IT IS DIFFICULT TO GAGE PUBLIC
SENTIMENT. USUALLY WE HAVE NOT ENCOUNTERED ANY PROBLEMS. CAROLINA
COATINGS SHOULD BE NO BIG ISSUE. THE OTHER VARIANCE AT EMRO MARKETING
DOES INVOLVE SOME WELLS AND MAY HAVE SOME INTEREST.
I COULD SCHEDULE 2 HEARINGS. THE CAROLINA COATINGS COULD GO FIRST
FROM SAY 6:30 PM TO 8:00 PM AND THEN DO EMRO MARKETING FROM 8:00 PM TO
10:30 PM. BOTH OF THESE ARE IN CHARLOTTE AND WE HAVE USED THE
COURTHOUSE.
HOW DOES THIS SOUND TO YOU???
DH
Reply Separator _________________ _
Subject: Re[2]: PUBLIC HEARINGS ON 2 UPCOMING VARIANCES
Author: Arthur Mouberry at NRGWS0lP
Date: 6/21/1999 4:25 PM
David,
Art is a good choice, are the facilities both in the same county? If so
than we can probably schedule them both for the same night unless we are
expecting a lot of opposition.
Arthur
Reply Separator
Subject: RE: PUBLIC HEARINGS ON 2 UPCOMING VARIANCES
Author: David Hance at NRGWS0lP
Date: 6/21/99 2:04 PM
ARTHUR:
CARL IS HAS COMPLETED HIS REVIEW OF ONE OF MY VARIANCES . HE IS
WORKING ON THE OTHER ONE . LOOKS LIKE THESE MAY BE ABLE TO PROCEED TO
HEARING LATE NEXT MONTH AT THE EARLIEST.
AT THIS POINT WE NEED TO SELECT HEARING OFFICERS FROM STAFF. THESE
VARIANCES ARE IN BARBARA CHRISTIAN'S REGION (CHARLOTTE) AND SHE SHOULD
NOT SERVE AS HEARING OFFICER THESE VARIANCES. PRESUMING THAT WE WANT
REGIONAL GW STAFF TO SERVE AS HEARING OFFICERS FOR RULES AND
ACTIVITIES THAT REQUIRE HEARING, HERE IS A LISTING OF REGIONAL STAFF
WITH THEIR PRESENT OR PAST INVOLVEMENT'S IN PUBLIC HEARINGS ON ISSUES:
DON LINK -RETIRING
SHERRI KNIGHT -CURRENTLY COMMITTED TO WCCC RULES
JAY ZIMMERMAN - A CORRECTIVE ACTION VARIANCE FOR CONE MILLS IN LATE
1996.
ART BARNHARDT -HAS NEVER BEEN A HEARING OFFICER
WILLIE HARDISON -CURRENTLY COMMITTED TO WCCC RULES
CHARLIE STEHMAN - A CORRECTIVE ACTION VARIANCE FOR A UST AT PAW CREEK
IN CHARLOTTE IN LATE 1996.
ART WOULD BE AN EXCELLENT CHOICE FOR ONE HEARING . WOULD WE WANT
ONE HEARING OFFICER TO SERVE FOR BOTH HEARINGS. THESE VARIANCES ARE
FOR EMRO MARKETING AND FOR CAROLINA COATINGS -TWO SEPARATE COMPANIES.
PLEASE NOTE THAT ART HAS AN UPCOMING VARIANCE IN HIS REGION (FLYNT
FABRICS) AND BARBARA MAY BE A GOOD CANDIDATE FOR A HEARING OFFICER ON
THIS.
PLEASE LET ME KNOW WHO YOU WANT ME TO CONTACT. I WILL TRY TO SEE
IF THE MECKLENBURG COUNTY COURTHOUSE IS OPEN IN THE EVENINGS.
DAVID HANCE
Author: David Hance at NRGWS0lP
Date: 6/21/1999 4:49 PM
Priority: Urgent
Receipt Requested
TO: Arthur Mouberry
CC: David Hance
CC: Carl Bailey
Subject: Re[3]: PUBLIC HEARINGS ON 2 UPCOMING VARIANCES
Message Contents------------------------------------
Arthur,
WITHOUT SENDING OUT THE NOTICES IT IS DIFFICULT TO GAGE PUBLIC
SENTIMENT. USUALLY WE HAVE NOT ENCOUNTERED ANY PROBLEMS. CAROLINA
COATINGS SHOULD BE NO BIG ISSUE. THE OTHER VARIANCE AT EMRO MARKETING
DOES INVOLVE SOME WELLS AND MAY HAVE SOME INTEREST.
I COULD SCHEDULE 2 HEARINGS. THE CAROLINA COATINGS COULD GO FIRST
FROM SAY 6:30 PM TO 8:00 PM AND THEN DO EMRO MARKETING FROM 8:00 PM TO
10:30 PM. BOTH OF THESE ARE IN CHARLOTTE AND WE HAVE USED THE
COURTHOUSE .
HOW DOES THIS SOUND TO YOU???
DH
________________ Reply Separator
Subject: Re[2]: PUBLIC HEARINGS ON 2 UPCOMING VARIANCES
Author: Arthur Mouberry at NRGWS0lP
Date: 6/21/1999 4:25 PM
David,
Art is a good choice, are the facilities both in the same county? If so
than we can probably schedule them both for the same night unless we are
expecting a lot of opposition.
Arthur
Reply Separator
Subject: RE: PUBLIC HEARINGS ON 2 UPCOMING VARIANCES
Author: David Hance at NRGWS0lP
Date: 6/21/99 2:04 PM
ARTHUR:
CARL rs HAS COMPLETED HIS REVIEW OF ONE OF MY VARIANCES. HE IS
WORKING ON THE OTHER ONE. LOOKS LIKE THESE MAY BE ABLE TO PROCEED TO
HEARING LATE NEXT MONTH AT THE EARLIEST.
AT THIS POINT WE NEED TO SELECT HEARING OFFICERS FROM STAFF. THESE
VARIANCES ARE IN BARBARA CHRISTIAN'S REGION (CHARLOTTE) AND SHE SHOULD
NOT SERVE AS HEARING OFFICER THESE VARIANCES. PRESUMING THAT WE WANT
REGIONAL GW STAFF TO SERVE AS HEARING OFFICERS FOR RULES AND
ACTIVITIES THAT REQUIRE HEARING, HERE IS A LISTING OF REGIONAL STAFF
WITH THEIR PRESENT OR PAST INVOLVEMENT'S IN PUBLIC HEARINGS ON ISSUES:
DON LINK -RETIRING
SHERRI KNIGHT -CURRENTLY COMMITTED TO WCCC RULES
JAY ZIMMERMAN -A CORRECTIVE ACTION VARIANCE FOR CONE MILLS IN LATE
1996.
ART BARNHARDT -HAS NEVER BEEN A HEARING OFFICER
WILLIE HARDISON -CURRENTLY COMMITTED TO WCCC RULES
CHARLIE STERMAN -A CORRECTIVE ACTION VARIANCE FOR A UST AT PAW CREEK
IN CHARLOTTE IN LATE 1996 .
ART WOULD BE AN EXCELLENT CHOICE FOR ONE HEARING. WOULD WE WANT
ONE HEARING OFFICER TO SERVE FOR BOTH HEARINGS. THESE VARIANCES ARE
FOR EMRO MARKETING AND FOR CAROLINA COATINGS -TWO SEPARATE COMPANIES.
PLEASE NOTE THAT ART HAS AN UPCOMING VARIANCE IN HIS REGION (FLYNT
FABRICS) AND BARBARA MAY BE A GOOD CANDIDATE FOR A HEARING OFFICER ON
THIS.
PLEASE LET ME KNOW WHO YOU WANT ME TO CONTACT. I WILL TRY TO SEE
IF THE MECKLENBURG COUNTY COURTHOUSE IS OPEN IN THE EVENINGS .
DAVID HANCE
Author: David Hance at NRGWS0lP
Date: 6/21/1999 2:04 PM
Priority: Urgent
Receipt Requested
TO: Arthur Mouberry
CC: Carl Bailey
CC: David Hance
Subject: RE: PUBLIC HEARINGS ON 2 UPCOMING VARIANCES
Message Contents
ARTHUR:
CARL IS HAS COMPLETED HIS REVIEW OF ONE OF MY VARIANCES . HE IS
WORKING ON THE OTHER ONE . LOOKS LIKE THESE MAY BE ABLE TO PROCEED TO
HEARING LATE NEXT MONTH AT THE EARLIEST.
AT THIS POINT WE NEED TO SELECT HEARING OFFICERS FROM STAFF. THESE
VARIANCES ARE IN BARBARA CHRISTIAN'S REGION (CHARLOTTE) AND SHE SHOULD
NOT SERVE AS HEARING OFFICER THESE VARIANCES. PRESUMING THAT WE WANT
REGIONAL GW STAFF TO SERVE AS HEARING OFFICERS FOR RULES AND
ACTIVITIES THAT REQUIRE HEARING, HERE IS A LISTING OF REGIONAL STAFF
WITH THEIR PRESENT OR PAST INVOLVEMENT'S IN PUBLIC HEARINGS ON ISSUES:
DON LINK -RETIRING
SHERRI KNIGHT -CURRENTLY COMMITTED TO WCCC RULES
JAY ZIMMERMAN -A CORRECTIVE ACTION VARIANCE FOR CONE MILLS IN LATE
1996.
ART BARNHARDT -HAS NEVER BEEN A HEARING OFFICER
WILLIE HARDISON -CURRENTLY COMMITTED TO WCCC RULES
CHARLIE STERMAN -A CORRECTIVE ACTION VARIANCE FOR A UST AT PAW CREEK
IN CHARLOTTE IN LATE 1996.
ART WOULD BE AN EXCELLENT CHOICE FOR ONE HEARING . WOULD WE WANT
ONE HEARING OFFICER TO SERVE FOR BOTH HEARINGS. THESE VARIANCES ARE
FOR EMRO MARKETING AND FOR CAROLINA COATINGS -TWO SEPARATE COMPANIES.
PLEASE NOTE THAT ART HAS AN UPCOMING VARIANCE IN HIS REGION (FLYNT
FABRICS) AND BARBARA MAY BE A GOOD CANDIDATE FOR A HEARING OFFICER ON
THIS.
PLEASE LET ME KNOW WHO YOU WANT ME TO CONTACT. I WILL TRY TO SEE
IF THE MECKLENBURG COUNTY COURTHOUSE IS OPEN IN THE EVENINGS .
DAVID HANCE
;rJ ""(S ~ 111'1
~~~~~~~~~~.:i,L)_~~~ ~--------"='-~---=--=-=~ . .
,
5) Comments received within a thirty-day period following the date of the public
hearing are included in the hearing record pursuant to 15A NCAC 2L .0113(£).
6) Based on information submitted in the variance request, comments received as a
result of public notice and hearing, the concerns of the applicant, the concerns of
the Groundwater Section staff and the hearing officer, a hearing officers report
with a recommendation is prepared.
7) The Environmental Management Commission Groundwater Committee meets to
recommend to the full Commission if the variance should be granted or denied
based on the requirements contained in 15A NCAC 2L .0113 and the
recommendations of the hearing officer.
8) The full Environmental Management Commission meets to grant or deny the
variance pursuant to the rule and the recommendation received from the
Groundwater Committee.
9) If the variance is granted by the Environmental Management Commission, a letter
will be sent to the person requesting the variance describing the final decision
taken by the Commission and any conditions placed on approval of that variance.
10) If the variance is denied by the Environmental Management Commission, a letter
will be sent to the person requesting the variance describing the final decision
taken by the Commission and the specific reasons for that denial. If the applicant
believes that the Commission's decision is unacceptable, he may file a petition for
a contested case pursuant to 15A NCAC 21 .Ol 13(h) and North Carolina General
Statute 150B.
At this time the memorandum to the Director of the Division of Water Quality is being
prepared by staff. On April 12, 1999, the Groundwater Section requested the 1997 monitoring
data for this site from your environmental consultant, Dames and Moore. We have received this
information and will proceed with completing the summary noted in Number 1 above. Once that
is completed, it will be immediately forwarded to the Director of the Division of Water Quality
for his review. The earliest a public hearing may be held on this variance is in mid-June 1999.
The Environmental Management Commission Groundwater _Committee and the Environmental
Management Commission have scheduled their 1999 meetings in the second week of September,
October and December.
Attached is a copy of the title 15A NCAC 2L rules (Classifications and Standards
Applicable to the Groundwaters of the North Carolina). Please refer to Rule .0113 -Variance on
Pages 14 though 16 for more information. Feel free to call me at [phone], if you need
any further infonnation on this matter.
cc: Mo~sville Regional Groundwater Supervisor
_p-.fvid Hance
Sincerely,
~~~ Arthur Mouberry, P.E.
Chief, Groundwater Section
~ PARADIGM ANALYTICAL LABORATORIES, INC.
Results for Volatiles
byGC8020
Client $§1mple ID: MW-3 Analyzed By: CKC
Client Project ID: Carolina Coatings Date Collected: 03/31/97
Lab Sample ID: 22552 Date Received: 04/01/97
Lab Project ID: G112-121 Matrix: Water
Compound Date Quantitation Result
Analyzed Dilution Limit (ug/KG) (ug/KG)
Benzene 4/11/97 1. 1 BQL
Chlorobenzene 4/11/97 1 1 BQL
Diisopropyl ether (DIPE) 4/11/97 1 1 BQL
Ethyl benzene 4/11/97 1 1 BQL
Methyl-tert-butyl ether (MTBE) 4/11/97 1 2 BQL
Toluene 4/11/97 1 1 BQL
m/p-Xylene 4/11/97 1 2 BQL
a-Xylene 4/11/97 1 2 BQL
Styrene 4/11/97 1 2 BQL
Surrogate Spike Recoveries Spike Spike Percent
Added Result Recovered
(ug/KG) (ug/KG) (%)
Trifluorotoluene 40 40 100
Comments:
All values corrected for dilution and %solids.
Flags:
BQL = Below quantitation limit
Reviewed By: l:A\J
\
PARADIGM ANALYTICAL LABORATORIES, INC.
Results for Volatiles
byGC 8020
Client Sample ID: MW-7
Client Project ID: Carolina Coatings
Lab Sample ID: 22554
Lab Project ID: G112-121
Compound Date
Analyzed
Benzene 4/11/97
Chlorobenzene 4/11/97
Diisopropyl ether (DIPE) 4/11/97
Ethyl benzene 4/11/97
Methyl-tert-butyl ether (MTBE) 4/11/97
Toluene 4/11/97
m/p-Xylene 4/11/97
a-Xylene 4/11/97
Styrene 4/11/97
Surrogate Spike Recoveries
Trifluorotoluene
ues corrected for dilution and %solids.
Below quantitation limit
Dilution
1
1
1
1
1
1
1
1
1
Spike
Added
(ug/KG)
40
Analyzed By: CKC
Date Collected: 03/31/97
Date Received: 04/01 /97
Matrix: Water
Quantitation Result
Limit (ug/KG) (ug/KG)
1 BQL
1 BQL
1 BQL
1 BQL
2 BQL
1 BQL
2 BQL
2 BQL
2 BQL
Spike Percent
Result Recovered
(ug/KG) (%)
40 100
Reviewed By:
PARADIGM ANALYTICAL LABORATORIES, INC.
Client Sample ID: MW-9
Results for Volatiles
byGC 8020
Client Project ID: Carolina Coatings
Lab Sample ID: 22553
Lab Project ID: G112-121
Compound Date
Analyzed Dilution
Benzene 4/11/97 1
Chlorobenzene 4/11/97 1
Diisopropyl ether (DIPE) 4/11/97 1
Ethyl benzene 4/11/97 1
Methyl-tert-butyl ether (MTBE) 4/11/97 1
Toluene 4/11/97 1
m/p-Xylene 4/11/97 1
a-Xylene 4/11/97 1
Styrene 4/11/97 1
Surrogate Spike Recoveries Spike
Added
(ug/KG)
Trifluorotoluene 40
Comments:
All values corrected for dilution and %solids.
Flags:
BQL = Below quantitation limit
Analyzed By: CKC
Date Collected: 03/31/97
Date Received: 04/01/97
Matrix: Water
Quantitation Result
Limit (ug/KG) (ug/KG)
1 BQL
1 BQL
1 BQL
1 BQL
2 BQL
1 SOL
2 BQL
2 BQL
2 BQL
Spike Percent
Result Recovered
(ug/KG) (%)
40 100
Reviewed By: LAJ
~ar~03-99 11 :16am From-PARADIGM LABS 9103501557 T-192 P.03/07 F-745
...... -..... --··---------------------1 --. -·
Client-Sample ID: MW-5
Results for Volatiles
byGC 8020
Client .Project ID: Carolina Coatings
Lab Sample ID: 31024
Lab Project IO: G112-151
Compound
Benzene
Chlorobenzene
Diisopropyl ether (DIP£;)
Ethylbenzene
Methyl-tert-butyl ether (MTBE)
Toluene
m/p-Xylene
o-Xylene
Styrene
Surrogate Spike Recoveries
Trifluorotoluene
Date
Analyzed
10/23/97
10/23/97
10/23/97
10/23/97
10/23/97
10/23/97
10/23/97
10/23/97
10/23/97
Dilution
1
1
1
1
1
1
1
1
1
Spike
Added
(ug/L)
40
Comments:
All values corrected for dilution.
Flags:
BQL = Below quantitation limit
Analyzed By: WML
Date Collected: 10/09/97
Date Received: 10/10/97
Matrix: Water
Quantitation Result
Limit (ug/L) (ug/L)
1 BQL
1 BQL
1 BQL
1 BOL
2 BQL
1 BQL
2 BQL
2 BQL
2 BQL
Spike Percent
Resutt Recovered
(ug/L) (O/o)
38 95
Reviewed By: LA½}
I
' !
' '
Mar-03-99 11:16am From-PARADIGM LASS 9103501557 T-19Z P.04/0T F-745
... ··-·-----------------------, --. -·
Client §~mple 10: MW-6
Results for Volatiles
byGC8020
Client Project ID: Carolina Coatings
Lab Sample ID: 31025
Lab Project ID: G112-151
· Compound
Benzene
Chlorobenzene
Diisopropyt ether (DIPE:)
Ethylbenzene
Methyl-tert-butyt ether (MTBE)
Toluene
m/p--Xylene
o-Xytene
styrene
Surrogate Spike Recoveries
T rifluo rotol uene
Date
Analyzed
10/15/97
10/15/97
10/15/97
10/15/97
10/15/97
10/15/97
10/15/97
10/15/97
10/15/97
Dilution
1
1
1
1
1
1
1
1
1
Spike
Added
(ug/L)
40
Comments:
All values corrected for dilution.
Flags:
BQL = Below quantitation limit
Analyzed By: CKC
Date Collected: 10/09/97
Date Received: 10/10/97
Matrix: Water
Quantitation
Limit (ug/L)
1
1
1
1
2
1
2
2
2
Spike
Result
(ug/L)
41
Result
(Ug/L)
BQL
BQL
BQL
BOL
BQL
BQL
BQL
BQL
SUL
Percent
Recovered
{%)
102
Reviewed By; LAW
ijar-03-99 11:16am Fram-PARADIGM LASS 9103501557
Results for Volatiles
byGC 8020
T-l9Z P.05/07 F-745
Client _Sample 10: MW-7
Client Project 10: Carolina Coatings
Lab Sample ID: 31026
Lab Project ID: G112-151
Compound
Benzene
Chlorobenzene
Oiisopropyl ether (01P~)
Ethylbenzene
Methyl-tert-butyl ether (MTBE)
Toluene
m/p-Xylene
a-Xylene
Styrene
surrogate Spike Recoveries
Trifluorotoluene
Date
Analyzed
10/15/97
10/15/97
10/15/97
10/15/97
10/15/97
10/15/97
10/15/97
10/15/97
10/15/97
comments:
All values corrected for dilution.
Flags:
BQL = Below quantltation limit
Dilution
1
1
1
1
1
1
1
1
1
Spike
Added
(ug/L)
40
Analyzed By: CKC
Oate Collected: 10/09/97
Date Received: 10/10/97
Matrix: Water
Quantitation
Limit (ug/L)
1
1
1
1
2
1
2
2
2
Spike
Result
(ug/L)
41
Result
(ug/L)
BQL
BOL
BQL
BQL
BQL
SOL
BQL
BQL
BQL
Percent
Rec_overed
(%)
102
Reviewed By: l Av}
" PARADIGM ANALYTICAL LABORATORIES, INC.
Results for Volatiles
byGC 8020
Client ~~mple ID: MW-3 Analyzed By: CKC
Client Project ID: Carolina Coatings Date Collected: 03/31/97
Lab Sample ID: 22552 Date Received: 04/01/97
Lab Project ID: G112-121 Matrix: Water
Compound Date Quantitation Result
Analyzed Dilution Limit (ug/KG) (ug/KG)
Benzene 4/11/97 t 1 BQL
Chlorobenzene 4/11/97 1 1 BQL
Diisopropyl ether (DIPE) 4/11/97 1 1 BQL
Ethyl benzene 4/11/97 1 1 BQL
Methyl-tert-butyl ether (MTBE) 4/11/97 1 2 BQL
Toluene 4/11/97 1 1 BQL
m/p-Xylene 4/11/97 1 2 BQL
a-Xylene 4/11/97 1 2 BQL
Styrene 4/11/97 1 2 BQL
Surrogate Spike Recoveries Spike Spike Percent
Added Result Recovered
(ug/KG) (ug/KG) (%)
Trifluorotoluene 40 40 100
Comments:
All values corrected for dilution and %solids.
Flags:
BQL = Below quantitation limit
Reviewed By: (.A\J
PARADIGM ANALYTICAL LABORATORIES, INC.
Client Sample ID: MW-7
Results for Volatiles
byGC 8020
Client Project ID: Carolina Coatings
Lab Sample ID: 22554
Lab Project ID: G112-121
Compound Date
Analyzed Dilution
Benzene 4/11/97 1
Chlorobenzene 4/11/97 1
Diisopropyl ether (DIPE) 4/11/97 1
Ethylbenzene 4/11/97 1
Methyl-tert-butyl ether (MTBE) 4/11/97 1
Toluene 4/11/97 1
m/p-Xylene 4/11/97 1
o-Xylene 4/11/97 1
Styrene 4/11/97 1
Surrogate Spike Recoveries Spike
Added
(ug/KG}
Trifluorotoluene 40
Comments:
All values corrected for dilution and %solids.
Flags:
BQL = Below quantitation limit
Analyzed By: CKC
Date Collected: 03/31/97
Date Received: 04/01/97
Matrix: Water
Quantitation Result
Limit (ug/KG) (ug/KG)
1 BQL
1 BQL
1 BQL
1 BQL
2 BQL
1 BQL
2 BQL
2 BQL
2 -BQL
Spike Percent
Result Recovered
(ug/KG) (%}
40 100
Reviewed By:
PARADIGM ANALYTICAL LABORATORIES, INC.
Client Sample ID: MW-9
Results for Volatiles
byGC 8020
Client Project ID: Carolina Coatings
Lab Sample ID: 22553
Lab Project ID: G112-121
Compound Date
Analyzed Dilution
Benzene 4/11/97 1
Chlorobenzene 4/11/97 1
Diisopropyl ether (DlPE) 4/11/97 1
Ethyl benzene 4/11/97 1
Methyl-tert-butyl ether (MTBE) 4/11/97 1
Toluene 4/11/97 1
m/p-Xylene 4/11/97 1
a-Xylene 4/11/97 1
Styrene 4/11/97 1
Surrogate Spike Recoveries Spike
Added
(ug/KG)
Trifluorotoluene 40
Comments:
All values corrected for dilution and %solids.
Flags:
BQL = Below quantitation limit
Analyzed By: CKC
Date Collected: 03/31/97
Date Received: 04/01/97
Matrix: Water
Quantitation Result
Limit (ug/KG) (ug/KG)
1 BQL
1 BQL
1 BQL
1 BQL
2 BQL
1 BQL
2 BQL
2 BQL
2 BQL
Spike Percent
Result Recovered
(ug/KG) (%)
40 100
Reviewed By : u-J
~ PARADIGM ANALYTICAL LABORATORIES, INC.
Results for Volatiles
byGC 8020
Client Sample ID: Trip Blank Analyzed By: CKC
Client Project ID: Carolina Coatings Date Collected: 03/31/97
Lab Sample ID: 22555 Date Received: 04/01/97
Lab Project ID: G112-121 Matrix: Water
Compound Date Quantitation Result
Analyzed Dilution Limit (ug/KG) (ug/KG)
Benzene 4/11/97 1 1 BQL
Chlorobenzene 4/11/97 1 1 BQL
Diisopropyl ether (DIPE) 4/11/97 1 1 BQL
Ethylbenzene 4/11/97 1 1 BQL
Methyl-tert-butyl ether (MTBE) 4/11/97 1 2 BQL
Toluene 4/11/97 1 1 BQL
m/p-Xylene 4/11/97 1 2 BQL
o-Xylene 4/11/97 1 2 BQL
Styrene 4/11/97 1 2 BQL
Surrogate Spike Recoveries Spike Spike Percent
Added Result Recovered
(ug/KG) (ug/KG) (%)
Trifluorotoluene 40 40 100
Comments:
All values corrected for dilution and %solids.
Flags:
BQL = Below quantitation limit
Reviewed By: uvJ
Mait.03-99 11 :16am From-PARADIGM LABS 9103501557 T-192 P.02/07 F-745 _______ ... __ ---·-------------..--•-.-------, -··-·
Client-Sample 10: MW-3
Results for Volatiles
byGC 8020
Client Project ID: Carolina Coatings
Lab Sample ID: 31023
Lab Project ID: G112-151
Compound Date
Analyzed Dilution
Benzene 10/15/97 1
Chlorobenzene 10/15/97 1
Diisopropyl ether (OIPI;) 10/15/97 1
Ethylbenzene 10/15/97 1
Methyl-tert-butyl ether (MTBE) 10/15/97 1
Toluene 10/15/97 1
m/p-Xylene 10/15/97 1
o-Xylene 10/15/97 1
Styrene 10/15/97 1
Surrogate Spike Recoveries Spike
Added
(ug/L)
Trifluorotoluene 40
Comments:
All values corrected for dilution.
Flags:
BQL = Below quantitatlon llmit
Analyzed By: CKC
Date Collected: 10/09/97
Date Received: 10/10/97
Matrix: Water
Quantitation Result
Umit (ug/L) (ug/L}
1 BOL
1 BQL
1 BOL
1 BQL
2 BQL
1 BQL
2 BQL
2 BQL
2 BQL
Spike Percent
Result Recovered
(ug/L) (%)
41 102
Reviewed By: lA W
Mar~03-99 11 :16am From-PARADIGM LABS 9103501557 T-192 P.03/07 F-745
··-.. - -... ·--·----------------------1 --. -·
Client-Sample ID: MW-5
Results for Volatiles
byGC B020
Client Project IO: Carolina Coatings
Lab Sample ID: 31024
Lab Project 10: G112-151
Compound
Benzene
Chlorobenzene
Oiisopropyt ether (DIPe)
Ethylbenzene
Methyl-tert-butyl ether (MTBE)
Toluene
m/1rXylene
o-Xylene
styrene
Surrogate Spike Recoveries
Tlifluorotoluene
Date
Analyzed
10/23197
10/23/97
10/23/97
10/23/97
10/23/97
10/23/97
10/23/97
10/23/97
10/23/97
Dilution
1
1
1
1
1
1
1
1
1
Spike
Added
(ug/L)
40
Comments:
All values corrected for dilution.
Flags:
BQL = Below quantitation limit
Analyzed By: WML
Date Collected: 10/09/97
Date Received: 10/10/97
Matrix: Water
Ql.lantitation
Limit (ug/L)
1
1
1
1
2
1
2
2
2
Spike
Resutt
(ug/L)
38
Result
(ug/L)
BQL
BQL
BQL
SOL
BQL
BQL
BQL
BQL
BQL
Percent
Recovered
{%)
95
Reviewed By: LA vJ
Mar-03-99 11 :16am From-PARADIGM LABS 9103501557 T-192 P.04/07 F-745
-··--------·-----------------1 ---·
Client-Sample ID: MW-6
Results for Volatiles
byGC 8020
Client Project ID: Carolina Coatings
Lab Sample ID: 31025
Lab Project ID: G112-151
· Compound
Benzene
Chlorobenzene
Oiisopropyt ether (DIPE)
Ethylbenz:ene
MethyHert-butyl ether (MTBE)
Toluene
m/p,-Xylene
o-Xytene
styrene
Surrogate Spike Recoveries
Trffluorotoluene
Date
Analyzed
10/15/97
10115/97
10/15/97
10/15/97
10/15/97
10/15/97
10/15/97
10/15/97
10/15/97
Dilution
1
1
1
1
1
1
1
1
1
Spike
Added
(UQ/L)
40
Comments:
All values corrected for dilution.
Flags:
BQL = Below quantltation limit
Analyzed By: CKC
Date Collected: 10/09/97
Date Received: 10/10/97
Matrix: Water
Quantitation
Limit (ug/L)
1
1
1
1
2
1
2
2
2
Spike
Result
(ug/L)
41
Result
(Ug/L)
BQL
BQL
BQL
BQL
BQL
BQL
BQL
Bal
Bal
Percent
Recovered
(%)
102
Reviewed By: LAW
Mar-03-99 11:16am From-PARADIGM LABS 9103501557
Results for Volatiles
byGC 8020
T-192 P.05/07 F-745
Client Sample 10: MW-7
ClientProject ID: Carolina Coatings
Lab Sample ID: 31028
Lab Project ID: G112-151
Compound Date
Analyzed Dilution
Benzene
Chlorobenzene
Clisopropyl ether (DIP!:;)
Ethylbenzene
Methyl-tert-butyl ether (MTBE)
Toluene
m/p-Xylene
o--X.ylene
Styrene
surrogate Spike Recoveries
Trtfluorotoluene
comments:
All values corrected for dilution.
Flags:
BQL = Below quantltation limit
10/15/97
10/15/97
10/15/97
10/15/97
10/15/97
10/15/97
10/15/97
10/15/97
10/15/97
1
1
1
1
1
1
1
1
1
Spike
Added
(ug/L)
40
Analyzed By: CKC
Date Collected: 10109/97
Date Received: 10110/97
Matrix: Water
Quantitation
Limit (ug/L)
1
1
1
1
2
1
2
2
2
Spike
Result
(ug/L)
41
Result
(ug/L)
BQL
BQL
BQL
BQL
BQL
BQL
BQL
BQL
BQL
Percent
Recovered
(%)
102
Reviewed By: LA v}
• · Mar-03-99 11:16am From-PARADIGM LABS 9103501557 T-192 P.07/07 F-745
--------·---·-----------------------7 ---...
Client ~ample 10; Trip Blank
Results for Volatiles
byGC 8020
Client Project ID: Carolina Coatings
Lab Sample ID: 31028
Lab Project ID: G112-151
Compound Date
Analyzed Dilution
Benzene 10/23/97 1
Chlorobenzene 10/23/97 1
Diisopropyl ether (DIPE) 10/23/97 1
Ethylbenzene 10/23/97 1
Methyl-tert-butyl ether {MTBE) 10/23/97 1
Toluene 10/23/97 1
m/p-Xylene 10/23/97 1
o-Xylene 10/23/97 1
Styrene 10/23/97 1
surrogate Spike Recoveries Spike
Added
(ug/L)
Trifluorotoluene 40
comments:
All values corrected for dilution.
Flags:
BQL = Below quantitation limit
Analyzed By: WML
Date Collected; 10/09/97
Date Received: 10/10/97
Matrix: Water
Quantitation Result
Limit (ug/L) (ug/L)
1 BQL
1 BQL
1 BQL
1 BQL
2 BOL
1 BOL
2 BQL
2 BQL
2 BQL
Spike Per-cent
Result Re~overed
(ug/L) (%)
39 98
Reviewed By: LA~
Site investigations conducted in 1991 and a site assessment in September 1992 showed soil
and groundwater contamination at this property. Between June 2, 1995 and June 25, 1995 , 1500
cubic yards of soils were excavated and removed from this property. A groundwater pump and
treat system was installed in July 1993 to treat BTEX contaminated groundwater. On January 18,
1994--a permit was issued by the Division of Water Quality authorizing the discharge of treated
groundwater into an on-site infiltration gallery. Since installation of the pump and treat cleanup
system, approximately 328,500 gallons of groundwater have been cleaned up, recovered, and
returned via the infiltration gallery.
According to information submitted by the company, this facility is within the City of
Charlotte in an area that is zoned 1-2 (Heavy Industry). Information submitted by the company
shows that there are five underground storage tanks within ½ mile of this site that have reported
releases of petroleum at area properties. There are two registered "small quantity generators" of
hazardous wastes within½ mile of the site.
The company also reports that releases of substances have occurred at nine area properties
which are located at a distance of greater than ½ mile from the site. Six of this properties have
had releases of. petroleum. Two of them are. described as being listed on the "Inactive · Sites
Inventory-State Priority Sites" list with the Division of Waste Management-Superfund Section.
The remaining site is described as listed in the "Inactive Sites Inventory" with the Division of
Waste Management-Superfund Section.
The company reports that there are no wells located in the area and that all properties
obtain water supply from the City of Charlotte. Monitoring well data indicates contamination at
this site is in excess of groundwater standards as described by 15A NCAC 2L .0202.
Pursuant to requirements of 15A NCAC 2L .0106, extensive efforts have been made by
Mr. Linwood Carter to reduce contamination levels at this site for the past 2 · ½ years.
Approximately $493,000 to assess the site and remediate substances in groundwater and
subsurface soils at the Carolina Coatings site. The responsible party does not believe that any
public benefit can be gained through the continuous implementation of a Corrective Action Plan
relying on active remedial technology to cleanup groundwaters at this site. Information has also
been submitted to show that efforts to reduce contaminate levels such that they meet the criteria
of 15A NCAC 2L .0202 would be a serious financial hardship on the applicant pursuant to 15A
NCAC 2L .0113 © (6).
Please review the attached report and provide the Groundwater Section with a
recommendation regarding the risk assessment methodology contained in this variance request.
If possible, the Section would like to receive your recommended response by February 7, 1997.
2
Upon receiving your recommendation, the Section will forward a recommendation to the
Director of the Division of Water Quality.
If you need additional assistance or information please call me at 715-6170.
cc: Carl Bailey
Dr. Burrie Boshoff
David Hance
Mooresville Regional Office Groundwater Supervisor
3
Carolina Coatings-Variance Request
January 6, 1997
Page Two
A. Significant upgrade of the existing system and installation of
additional recovery wells would be necessary to capture the
lateral extent of the existing benzene above the NCAC 2L
standard. The current system, which has been operational for 2.5
years, has an insufficient capture zone to remediate the site to
below 2L groundwater standards.
B. Risk to public health is minimal considering the lack of active
water supply well systems, distance to surface water bodies, and
the industrial character of the site and surrounding sites.
If a variance is granted for the subject site, the MRO does not recommend continued
sampling of onsite monitoring wells based on the following reasons:
1) The groundwater plume is spatially limited (<30 feet radially) and does not
extend offsite .
2) Groundwater modeling of the plume does not predict offsite migration of the
plume above the 2L standards.
2) Secondary sources have been removed and the contaminants have the capacity
to degrade or attenuate.
Attached to this memo is a summary of the variance request. If you should have any
questions, I can be reached by phone at 704.663.1699 ext. 261 or by E-mail at
<[e-mail]>.
Attachment: Variance Request Summary
Release
NOV
CSA
CAP
Carolina Coatings
711 Pressley Road, Charlotte, North Carolina
Environmental site assessment for property transfer purposes performed in 1991
detected the presence of ethylbenzene, toluene and xylenes (BTEX) in soils
surrounding the pad. Subsequent assessment detected concentrations of BTEX
compounds above the 2L standard in onsite monitoring wells.
On August 28, 1992, the MRO issued Carolina Coatings a Notice of Violation
in accordance with 15A NCAC 2C 2L requiring restoration of groundwater and
soil at the site and elimination of the source. Source of the contamination was
apparently surface spill resulting from leaking drum storage and three settling
tanks located adjacent to the southeastern side of the pad.
A remedial action plan (RAP) was received on June 30, 1992. The horizontal
and vertical extent of groundwater contamination was delineated and findings
presented in this report; no BTEX constituents were detected in the deep well
(MW-8) nor the downgradient wells MW-1,5,6 and MW-7. Additional
information was requested by the MRO staff including additional soil sampling
and potential methods of remediation and disposal of excavated soil. On March
29, 1993, the requested information was submitted in the form of a RAP
Addendum.
The RAP addendum documented removal of approximately 1500 cubic yards of
contaminated soil surrounding the concrete drum storage pad and beneath the
pad. Confirmatory soils samples indicated no remaining soil with BTEX
concentration compounds above the 50 mg/kg target cleanup level.
The corrective action plan was presented in a report entitled Soil and
Groundwater Remediation received on May 13, 1994 by the MRO. This report
proposed the use of a pump and treat system comprised of a single recovery
well and infiltration gallery. Recovered groundwater was processed through an
equalization tank, four fiber cartridge filter units and two carbon filter units in
senes.
The CAP was not reviewed by the MRO or approved by the Director.
On January 18, 1994, the NC DEHNR Water Quality Division issued a
discharge permit for treated groundwater into the onsite infiltration gallery
(#WQ0007993).
The groundwater pump and treat system was activated on March 23, 1994 after
the required 48-hour notification to the MRO. Currently, the system is
operating at an approximate recovery rate of 0.25 gpm which equals an
approximate aquifer withdraw of 328,500 gallons of groundwater since system
startup.
Analytical results of system influent and effluent samples indicate ethylbenzene
and toluene concentrations below the 2L standard. Xylene and benzene
concentrations have decreased significantly but have exceeded the 2L standard
periodically.
Groundwater has been monitored between March 1994 and September 1996.
Monitoring well MW-9 has been the only groundwater monitoring well that has
ever exceeded the 2L standard for BTEX compounds. Analytical results of the
September 1996 sampling indicate benzene at a concentration of 27 ppb and
xylene at 104 ppb.
Groundwater flow at the site is determined to be primarily east with radial
components. A groundwater gradient of 0.01 ft/ft has been calculated for the
site. Rising head test completed in four shallow monitoring wells indicate a
hydraulic conductivity value of 3.87 x 10·5 cm/sec or 0.06 ft/day.
The calculated time that the plume would encounter the property boundary
given the current hydrogeologic conditions is 100 years. Using the Domenico
solute transport model and assuming a 27 ppb source concentration of benzene
(September's analytical results) and a first-order decay coefficient of 720 days,
the modeled benzene concentration at the property boundary would be <1 ppb.
Carolina Coatings has submitted a variance request with supporting information
that demonstrates continued use of the current system is cost-prohibitive and
will not result in significant long-term remediation of the site to groundwater
standards. The variance request further suggests that remediation of the site to
groundwater standards would require significant modification of the current
groundwater recovery and treatment system.
The following facts and financial information has been submitted by Carolina
Coatings to further support their variance request:
1) Only one monitoring well, MW-9, has had benzene and xylene
concentrations above the 2L standard since groundwater monitoring
began in March 1994. Therefore, BTEX affected groundwater is limited
to the area surrounding MW-9.
2) System influent sample concentrations have decreased from a maximum
of 7 .6 ppb benzene and 440 ppb xylenes in May 1994 and March 1995
respectively. The system has been operational for 2.5 years and has
treated approximately 328,500 gallons of recovered groundwater.
Toluene and ethylbenzene have decreased to below the analytical
detection limit over the course of system operation.
3) A total of $493,000 has been spent by the former owner of Carolina
Coatings on assessment and active remediation of the contaminated soil
and groundwater using best available technology economically
reasonable for the site. The continued, yearly operation and monitoring
cost of the site is estimated at $48,000. Mr. Carter, the retired, former
owner of the facility, maintains sole environmental liability of site
remediation and therefore continued operation would impose serious
financial hardship for Mr. Carter without significant environmental
benefit.
4) No potential surface water receptors or onsite receptors (i.e., basements,
artificial conduits) will be impacted above the 21 standard based on
groundwater modeling. The nearest, potential water supply wells are
located 2300 feet south of the site and are hydrologically separated from
the site aquifer.
i.
~ State of North Carolina
Department of Environment,
Health and Natural Resources
Division of Water Quality
James B. Hunt, Jr., Governor
Jonathan B. Howes, Secretary
A Preston Howard, Jr., P.E., Director
MEMORANDUM:
AVA
DEHNR
January 14, 1997
TO: Dr. Ken Rudo, Ph.D, Toxicologist,
Environmental Epidemiology Section
FROM:
SUBJECT:
Arthur Mouberry, P.E., Chief .£;JJ
Groundwater Section ~
The Carolina Coatings Incorporated Request for Variance
from 15A NCAC 2L .0202 Groundwater Quality Standards
for Property at 711 Pressley Road in Charlotte, North
Carolina (DWQ Groundwater Incident Number #08949).
Auached is a variance request on behalf of Carolina Coatings Incorporated from Dames
and Moore Incorporated. The request is for a variance to groundwater standards for Benzene,
Ethylbenzene, Toluene, Xylene (-o,-m, and -p). This site was contaminated by releases of
solvents from three wastewater settling tanks and materials that were stored on a concrete pad.
The materials that were once stored on the 88 by 66 foot concrete pad consisted ofempty 55
gallon drums and raw materials used in batch mixing process for paints. This site is also listed as
in VISTA Information as "a RCRA Large Quantity Generator (EPA ID: NCD003150208)".
The area requested for variance is for all the property at 711 Pressley Road which consists
of approximately 6.17 acres of land. Carolina Coatings operated a solvent-based paint blending
facility and warehouse at this site from 1971 until late 1991. Carolina Coatings Incorporated is
owned by Mr. Linwood Carter. In 1991 the Carolina Coatings facility was sold to Wattyl Paints
of Atlanta, Georgia . Solvent based paint mixing processes were moved to a facility in Georgia .
Only latex water based products have been processed at this property since late 1991.
Groundwater Section. Voice 919-733-3221 FAX [phone]
P.O . Box 29578. Raleigh. North Carolina 27626-0578
2728 Capital Blvd .. Raleigh. North Carolina 27604
N!iC
ffMt5'f1ea
An Equal Opportunity/Affirmative Action Employer
50"k recycles/10% post-consumer paper
Site investigations conducted in 1991 and a site assessment in September 1992 showed soil
and groundwater contamination at this property. Between June 2, 1995 and June 25, 1995 , 1500
cubic yards of soils were excavated and removed from this property. A groundwater pump and
treat system was installed in July 1993 to treat BTEX contaminated groundwater. On January 18,
1994 a permit was issued by the Division of Water Quality authorizing the discharge of treated
groundwater into an on-site infiltration gallery. Since installation of the pump and treat cleanup
system, approximately 328,500 gallons of groundwater have been cleaned up, recovered, and
returned via the infiltration gallery.
According to information submitted by the company, this facility is within the City of
Charlotte in an area that is zoned 1-2 (Heavy Industry). Information submitted by the company
shows that there are five underground storage tanks within ½ mile of this site that have reported
releases of petroleum at area properties. There are two registered "small quantity generators" of
hazardous wastes within½ mile of the site.
The company also reports that releases of substances have occurred at nine area properties
which are located at a distance of greater than½ mile from the site . Six of this properties have
had releases of petroleum. Two of them are described as being listed on the "Inactive · Sites
Inventory-State Priority Sites" list with the Division of Waste Management-Superfund Section.
The remaining site is described as listed in the "Inactive Sites Inventory" with the Division of
Waste Management-Superfund Section.
The company reports that there are no wells located in the area and that all properties
obtain water supply from the City of Charlotte . Monitoring well data indicates contamination at
this site is in excess of groundwater standards as described by 15A NCAC 2L .0202.
Pursuant to requirements of 15A NCAC 2L .0106, extensive efforts have been made by
Mr. Linwood Carter to reduce contamination levels at this site for the past 2 ½ years.
Approximately $493,000 to assess the site and remediate substances in groundwater and
subsurface soils at the Carolina Coatings site . The responsible party does not believe that any
public benefit can be gained through the continuous implementation of a Corrective Action Plan
relying on active remedial technology to cleanup groundwaters at this site . Information has also
been submitted to show that efforts to reduce contaminate levels such that they meet the criteria
of 15A NCAC 2L .0202 would be a serious financial hardship on the applicant pursuant to 15A
NCAC 2L .0113 © (6).
Please review the attached report and provide the Groundwater Section with a
recommendation regarding the risk assessment methodology contained in this variance request.
If possible, the Section would like to receive your recommended response by February 7, 1997.
2
Upon receiving your recommendation, the Section will forward a recommendation to the
Director of the Division of Water Quality.
If you need additional assistance or information please call me at 715-6170.
cc: Carl Bailey
Dr. Burrie Boshoff
David Hance
Mooresville Regional Office Groundwater Supervisor
3
Carolina Coatings-Variance Request
January 6, 1997
Page Two
A. Significant upgrade of the existing system and installation of
additional recovery wells would be necessary to capture the
lateral extent of the existing benzene above the NCAC 2L
standard. The current system, which has been operational for 2.5
years, has an insufficient capture zone to remediate the site to
below 2L groundwater standards.
B. Risk to public health is minimal considering the lack of active
water supply well systems, distance to surface water bodies, and
the industrial character of the site and surrounding sites.
If a variance is granted for the subject site, the MRO does not recommend continued
sampling of onsite monitoring wells based on the following reasons:
1) The groundwater plume is spatially limited (<30 feet radially) and does not
extend offsite .
2) Groundwater modeling of the plume does not predict offsite migration of the
plume above the 2L standards.
2) Secondary sources have been removed and the contaminants have the capacity
to degrade or attenuate.
Attached to this memo is a summary of the variance request. If you should have any
questions, I can be reached by phone at 704.663.1699 ext. 261 or by E-mail at
<[e-mail]>.
Attachment: Variance Request Summary
Release
NOV
CSA
Carolina Coatings
711 Pressley Road, Charlotte, North Carolina
Environmental site assessment for property transfer purposes performed in 1991
detected the presence of ethylbenzene, toluene and xylenes (BTEX) in soils
surrounding the pad. Subsequent assessment detected concentrations of BTEX
compounds above the 2L standard in onsite monitoring wells.
On August 28, 1992, the MRO issued Carolina Coatings a Notice of Violation
in accordance with 15A NCAC 2C 2L requiring restoration of groundwater and
soil at the site and elimination of the source. Source of the contamination was
apparently surface spill resulting from leaking drum storage and three settling
tanks located adjacent to the southeastern side of the pad.
A remedial action plan (RAP) was received on June 30, 1992. The horizontal
and vertical extent of groundwater contamination was delineated and findings
presented in this report; no BTEX constituents were detected in the deep well
(MW-8) nor the downgradient wells MW-1,5,6 and MW-7. Additional
information was requested by the MRO staff including additional soil sampling
and potential methods of remediation and disposal of excavated soil. On March
29, 1993, the requested information was submitted in the form of a RAP
Addendum.
The RAP addendum documented removal of approximately 1500 cubic yards of
contaminated soil surrounding the concrete drum storage pad and beneath the
pad. Confirmatory soils samples indicated no remaining soil with BTEX
concentration compounds above the 50 mg/kg target cleanup level.
CAP The corrective action plan was presented in a report entitled Soil and
Groundwater Remediation received on May 13, 1994 by the MRO. This report
proposed the use of a pump and treat system comprised of a single recovery
well and infiltration gallery. Recovered groundwater was processed through an
equalization tank, four fiber cartridge filter units and two carbon filter units in
senes.
The CAP was not reviewed by the MRO or approved by the Director.
On January 18, 1994, the NC DEHNR Water Quality Division issued a
discharge permit for treated groundwater into the onsite infiltration gallery
(#WQ0007993).
The groundwater pump and treat system was activated on March 23, 1994 after
the required 48-hour notification to the MRO. Currently, the system is
operating at an approximate recovery rate of 0.25 gpm which equals an
approximate aquifer withdraw of 328,500 gallons of groundwater since system
startup.
Analytical results of system influent and effluent samples indicate ethylbenzene
and toluene concentrations below the 2L standard. Xylene and benzene
concentrations have decreased significantly but have exceeded the 2L standard
periodically.
Groundwater has been monitored between March 1994 and September 1996.
Monitoring well MW-9 has been the only groundwater monitoring well that has
ever exceeded the 2L standard for BTEX compounds. Analytical results of the
September 1996 sampling indicate benzene at a concentration of 27 ppb and
xylene at 104 ppb.
Groundwater flow at the site is determined to be primarily east with radial
components. A groundwater gradient of 0.01 ft/ft has been calculated for the
site. Rising head test completed in four shallow monitoring wells indicate a
hydraulic conductivity value of 3.87 x 10·5 cm/sec or 0.06 ft/day.
The calculated time that the plume would encounter the property boundary
given the current hydrogeologic conditions is 100 years. Using the Domenico
solute transport model and assuming a 27 ppb source concentration of benzene
(September's analytical results) and a first-order decay coefficient of 720 days,
the modeled benzene concentration at the property boundary would be <1 ppb.
Carolina Coatings has submitted a variance request with supporting information
that demonstrates continued use of the current system is cost-prohibitive and
will not result in significant long-term remediation of the site to groundwater
standards. The variance request further suggests that remediation of the site to
groundwater standards would require significant modification of the current
groundwater recovery and treatment system.
The following facts and financial information has been submitted by Carolina
Coatings to further support their variance request:
1) Only one monitoring well, MW-9, has had benzene and xylene
concentrations above the 2L standard since groundwater monitoring
began in March 1994. Therefore, BTEX affected groundwater is limited
to the area surrounding MW-9.
2) System influent sample concentrations have decreased from a maximum
of 7 .6 ppb benzene and 440 ppb xylenes in May 1994 and March 1995
respectively. The system has been operational for 2.5 years and has
treated approximately 328,500 gallons of recovered groundwater.
Toluene and ethylbenzene have decreased to below the analytical
detection limit over the course of system operation.
3) A total of $493,000 has been spent by the former owner of Carolina
Coatings on assessment and active remediation of the contaminated soil
and groundwater using best available technology economically
reasonable for the site. The continued, yearly operation and monitoring
cost of the site is estimated at $48,000. Mr. Carter, the retired, former
owner of the facility, maintains sole environmental liability of site
remediation and therefore continued operation would impose serious
financial hardship for Mr. Carter without significant environmental
benefit.
4) No potential surface water receptors or onsite receptors (i.e., basements,
artificial conduits) will be impacted above the 2L standard based on
groundwater modeling. The nearest, potential water supply wells are
located 2300 feet south of the site and are hydrologically separated from
the site aquifer.
Author: Randy Prillaman at NRGWS0lP
Date: 4/16/1999 10:08 AM
Priority: Normal
TO: David Hance
Subject: Incident 8949
------------------------------------Message Contents------------------------------------
David-
Incident number 8949 belongs to CAROLINA COATINGS, INC on 711 PRESSLEY
RD in Charlotte . Hope this helps.
Author: "Matt Heller" <Matt Heller@mro .enr.state .nc.us> at Internet
)Date: 3/24/1999 2: 04 PM
Priority: Normal
TO: David Hance at NRGWS0lP
Subject: re: NEW QUESTION-Variance Carolina Coatings
----------~~------------------------Message Contents
They have sampled a few times since 1996, most in conjunction with
their permit, I think -you may want to check that file in Raleigh - I
don't see any results after 10/97 -you may want to call their
consultant, Patrick Gallagher at 704-522-0330
Date sent: Tue, 23 Mar 1999 13:53:28 -0500
From:
Subject:
To:
David [e-mail] (David Hance)
re: NEW QUESTION-Variance Carolina Coatings
Matt [e-mail]
Copies to: David [e-mail] (David Hance)
> HI MATT,
>
> ANOTHER QUESTION RELATED TO THIS VARIANCE .... HAS THE COMPANY
> CONTINUED SEMIANNUAL MONITORING AT THIS SITE? IF SO ... COULD YOU
> SEND ME A COPY OF THE RESULTS SINCE 9-3-96. IF NOT ... PLEASE CALL ME
> AT 919-715-6189. I WILL NOT BE IN THE OFFICE TOMORROW BUT I WILL BE
> AT OUR MEETING THURSDAY. I WILL BE IN FRIDAY.
>
>
>
>
DAVID HANCE
> *********************************************************************
> p.s.-What is the GW incident number for this? Is it GW 8949?
> WE HAVE SOME INFORMATION THAT SHOWS A DIFFERENT NUMBER AT OUR OFFICE.
>
>
>
>
DH
> **********************************************************************
> *
Matt Heller, P.G.
Division of Water Quality
Groundwater Section
Mooresville Regional Office
919 North Main Street
Mooresville, NC 28115
Matt [e-mail]
[phone], ext. 241
Fax [phone]
Author: "Matt Heller" <Matt [e-mail] .state.nc.us> at Internet
Date: 3/24/1999 1:46 PM
Priority: Normal
TO: David Hance at NRGWSOlP
Subject: Re: 2Re: carolina coatings
------------------------------------Message Contents--------~---------------------------
David:
I imagine they wouldn't need a permit if you tell them not to
remediate any more groundwater.
I don't know what would happen to the gallery -I imagine they would
dismantle it and use the area for something else. This is a question
for the responsible party, I think.
Date sent:
From:
Subject:
To:
Copies to:
> Thanks Matt ....
>
Mon, 22 Mar 1999 11:18:20 -0500
David [e-mail] (David Hance)
2Re: carolina coatings
"Matt Heller" <Matt [e-mail] .us>
David [e-mail] .state.nc.us (David Hance)
> As a follow-up to my previous questions ---Carolina Coatings has
> a non discharge permit for an infiltration gallery at this site
> (WQ0007993). Our information shows that the remediation system is shut
> off. David Goodrich in Permits and Compliance Branch has recommended
> the permit not be renewed if the variance is granted.
>
>
>
Will the MRO concur with this?
> What will happen to the infiltration gallery if a variance is
> granted?
>
> If possible, I would like these questions answered on or before
> 3/25/99. I will be in the office today, tomorrow and Friday. I will
> be out in Greensboro on Wednesday and in our meeting Thursday .
>
>
>
>
>
>
>
>
>
> Subject: Carolina coatings
DH
Reply Separator
> Author: "Matt Heller" <Matt [e-mail]> at Internet
> Date: 3/22/1999 10:59 AM
>
>
> David
>
> No formal CSA submitted for this site -Remedial action plan defined
> extent of gw contamination and soil contamination and was
> submitted 7/1/92
>
> CSA not formally approved by DENR
>
> CAP submitted 4/19/94
>
> Aerial extent of gw contamination prior to remediation is estimated at
> 10,000 sq. ft
>
> depth of contamination is less than 48 ft bgs
>
> system has been off since 1/97
>
> Matt Heller, P.G.
> Division of Water Quality
> Groundwater Section
> Mooresville Regional Office
> 919 North Main Street
> Mooresville, NC 28115
> Matt [e-mail]
> [phone], ext. 241
> 'Fax [phone]
Matt Heller, P.G.
Division of Water Quality
Groundwater Section
Mooresville Regional Office
919 North Main Street
Mooresville, NC 28115
Matt [e-mail] .us
[phone], ext. 241
Fax [phone]
Author: "Matt Heller" <Matt Heller@mro .enr.state .nc.us> at Internet
Date: 3/24/1999 1:57 PM
i . . 1 Priority: Norma
TO: David Hance at NRGWS0lP
Subject: re: Another message/ Carolina coatings variance
------------------------------------Message Contents------------------------------------
looks like most recent influent/effluent was using EPA 8020
Date sent:
From:
Subject:
To:
Mon, 22 Mar 1999 17:00:38 -0500
David_Hance@mail .enr.state.nc.us (David Hance)
re: Another message/ Carolina coatings variance
Matt [e-mail]
Copies to: David [e-mail] (David Hance)
> Matt,
::,
::,
> I did not see any reference to the analytical methods used by
> Carolina Coatings in samples collected from monitoring wells and
> samples from the influent.
::,
::,
> Does the MRO have this information?
::,
::,
::,
Matt Heller, P .G.
Division of Water Quality
Groundwater Section
Mooresville Regional Office
919 North Main Street
Mooresville, NC 28115
[e-mail]
[phone], ext. 241
Fax [phone]
David Hance
Author: David Hance at NRGWS0lP
Date: 3/23/1999 1:53 PM
Priority: Urgent
Receipt Requested
TO: Matt [e-mail] at Internet
CC: David Hance
Subject: re: NEW QUESTION-Variance Carolina Coatings
------------------------------------Message Contents------------------------------------
HI MATT,
ANOTHER QUESTION RELATED TO THIS VARIANCE .... HAS THE COMPANY
CONTINUED SEMIANNUAL MONITORING AT THIS SITE? IF SO ... COULD YOU
SEND ME A COPY OF THE RESULTS SINCE 9-3-96. IF NOT ... PLEASE CALL ME
AT 919-715-6189. I WILL NOT BE IN THE OFFICE TOMORROW BUT I WILL BE
AT OUR MEETING THURSDAY. I WILL BE IN FRIDAY.
DAVID HANCE
*********************************************************************
p.s.-What is the GW incident number for this? Is it GW 8949?
WE HAVE SOME INFORMATION THAT SHOWS A DIFFERENT NUMBER AT OUR OFFICE .
DH
**********************************************************************
*
Author: David Hance at NRGWS0lP
Date: 3/22/1999 5:00 PM
Priority: Urgent
Receipt Requested
TO: Matt [e-mail] at Internet
CC: David Hance
Subject: re: Another message/ Carolina coatings variance
------------------------------------Message Contents------------------------------------
Matt,
I did not see any reference to the analytical methods used by
Carolina Coatings in samples collected from monitoring wells and
samples from the influent.
Does the MRO have this information?
David Hance
• DAMES & Mo,oRE) .. N.C.
NCDEHNR
Mr. Preston Howard
December 9, 1996
Page2
A NORTH CAROLINA GENERAL PARNERSHIP
above the North Carolina groundwater standard of 1 ug/1. The area in which the benzene
contamination is evident is isolated to within the vicinity of m.or.Jtor well M\V-9, as depicted in the
attached variance request Figure 8.
The variance request has been prepared and is being submitted based upon the follovving:
• The relatively low concentrations of benzene are limited to an area within the vicinity of
monitor well M\V..:9.
• The contamiti.ated area is confined entirely onsite. Groundwater velocity calculations
indic~ate that it would take the contamination approximately l 00 years to reach the property
boundary, if natural attenuation and degradation are not considered.
• Natural attenuation and degradation ofbenzene d.o occur and if these factors are considered,
modeling indicates that the remaining contaminarion never will reach the property boundary.
• There are no potential receptors on sit e. The elosest offsite potential receptors are two
potential water supply wells. These potential wells are over 2 ,300 feet from the Carolina
Coatings facility ai-id are hydraulically separated. from the site by a tributary of Sugar Creek.
• Mr. Carter has aggressively rcmediate d subsurface soil and groundwater at the site and hac;
spent over $493,000.00 of his personal savings on this site remediation. Continuing this
effort would impos~ additional financiai hardship upon him, with no apparent public benefit.
Dames & tv1oore and M r. Linwood Can,.!r request that th1.! NC DEHNR. approve no further action
for the Carolina Coatings site and that a Variance be granted fhr the surficial aquifer beneath the site.
VARCOV.L'IR
• DAMES & MOORE,-N.C.
NCDEHNR
Mr. Preston Howard
December 9, 1996
Page 3
A NORTH CAROLINA GENERAL PARNERSHIP
If you have any questions or need additional information, please do not hesitate to call Mr. Patrick
Gallagher in the Dames & Moore Charlotte office at 704-522-0330.
Respectfully submitted,
DAMES & MOORE -N.C.
rlfe _ , ·:AcMAL
PatncK J. · 1allagher, rj.E.
Project Engineer
~Q!~
!.vlar:aging. Principal-in-Charge
C.:noiina Operations
EncJ.osure
cc: Linwood Carter
Landon Davidson -NC DEHNR Mooresville Region Office
Linda Overton -Wattyl Paint
VARCOV.LTR
-'~--------------------------------------------------,.
Author: David Hance at NRGWS0lP
Date: 3/22/1999 11:18 AM
Priority: Urgent
Receipt Requested
TO: "Matt Heller" <Matt Heller@mro .enr.state.nc.us> at Internet
CC: David Hance
Subject: 2Re: carolina coatings
------------------------------------Message Contents ------------------------------------
Thanks Matt ....
As a follow-up to my previous questions ---Carolina Coatings has
a non discharge permit for an infiltration gallery at this site
(WQ0007993). Our information shows that the remediation system is shut
off. David Goodrich in Permits and Compliance Branch has recommended
the permit not be renewed if the variance is granted.
Will the MRO concur with this?
What will happen to the infiltration gallery if a variance is
granted?
If possible, I would like these questions answered on or before
3/25/99. I will be in the office today, tomorrow and Friday. I will
be out in Greensboro on Wednesday and in our meeting Thursday.
DH
Subject:
Reply Separator
Carolina coatings
Author:
Date:
David
"Matt Heller" <Matt [e-mail] .us> at Internet
3/22/1999 10:59 AM
No formal CSA submitted for this site -Remedial action plan defined
extent of gw contamination and soil contamination and was
submitted 7/1/92
CSA not formally approved by DE NR
CAP submitted 4/19/94
Aerial extent of gw contamination prior to remediation is estimated at
10,000 sq. ft
depth of contamination is less than 48 ft bgs
system has been off since 1/97
Matt Heller, P.G.
Division of Water Quality
Groundwater Section
Mooresville Regional Office
919 North Main Street
M.;··1 restfille, NC 28115
Matt [e-mail] .nc .us
[phone], ext. 241
Fax [phone]
Author: "Matt Heller" <Matt [e-mail] .us> at Internet
Date: 3/22/1999 10:59 AM
Priority: Normal
TO: David Hance at NRGWS0lP
Subject: carolina coatings
David
Message Contents------------------------------------
No formal CSA submitted for this site -Remedial action plan defined
extent of gw contamination and soil contamination and was
submitted 7/1/92
CSA not formally approved by DENR
CAP submitted 4/19/94
Aerial extent of gw contamination prior to remediation is estimated at
10,000 sq. ft
depth of contamination is less than 48 ft bgs
system has been off since 1/97
Matt Heller, P.G.
Division of Water Quality
Groundwater Section
Mooresville Regional Office
919 North Main Street
Mooresville, NC 28115
Matt [e-mail]
[phone], ext. 241
Fax [phone]