FACTSHEET

DAIMLER TRUCKS

11550 STATESVILLE BOULEVARD

CLEVELAND, NORTH CAROLINA

EPA ID NUMBER: NCD 018 652 339

A Hazardous Waste Management Permit modification to implement a Risk-Based Remediation and to terminate the Alternate Mechanism in lieu of Post-Closure Permit (Alternate Mechanism) has been requested for the Daimler Trucks North America LLC (Daimler Trucks) Facility located at 11550 Statesville Boulevard in Cleveland, North Carolina, under the Resource Conservation and Recovery Act (RCRA). Specifically, Daimler Trucks requested a Class 3 permit modification to terminate groundwater corrective action at the Facility. The request would result in a finding of No Further Action based on the Remedial Action Plan submitted by Daimler Trucks in accordance with N.C.G.S. § 130A-310.65 through 310.77. This statute provides a mechanism for facilities to remediate contaminated sites to site-specific remediation standards.

North Carolina has been authorized by the United States Environmental Protection Agency to administer RCRA including the Hazardous and Solid Waste Amendments (HSWA) of 1984. The State has determined that Daimler Truck’s proposed actions as described in the Remedial Action Plan satisfy the full intent of the North Carolina Hazardous Waste Management Rules and Solid Waste Management Act as amended. When finalized, the Alternate Mechanism and Post-Closure Care will be terminated.

BACKGROUND

The Facility was originally owned and operated by MAN Truck & Bus Division of MAN Roland, Inc. (MAN Truck), from approximately 1979 until May 1989. MAN Truck manufactured and assembled buses used in urban transport. The property and business was purchased by Freightliner Corporation, the predecessor in interest to Daimler Trucks. Daimler Trucks custom manufactures large, Class 8 diesel trucks.

During its operation, MAN Truck used three spray paint booths and one cleaning booth. The use of these paint booths generated wash water and waste solvents which were drained into a 5,000gallon concrete underground storage tank (UST).

The 5,000-gallon concrete UST was used from 1979 through August 1988 after which it was excavated. Soil samples were collected from the open pit following excavation activities. Toluene and 1,1,1trichloroethane were documented in soils at the site. Their presence constituted disposal of listed hazardous wastes as defined by 40 CFR 261.31, incorporated by reference in 15A NCAC 13A .0106.

Based upon the results of the environmental sampling, the precursor to the Department of Environmental Quality (DEQ) entered into an Administrative Order on Consent on February 7, 1991 (Docket Number 89-065) (“MAN AOC”). The MAN AOC identified the 5,000-gallon concrete UST as the sole regulated unit at the Facility and designated MAN Truck as the responsible party in the investigation of adverse environmental impacts originating from the UST. The MAN AOC required assessment of groundwater quality.

Groundwater assessment indicated the presence of elevated concentrations of volatile organic compounds. Impacts to groundwater quality are most elevated near the area of the former UST. Contaminants detected during preliminary groundwater assessment activities conducted in the early 1990’s included acetone, ethylbenzene, methylene chloride, toluene, total xylenes, benzyl alcohol, Nnitrosodiphenylamine, naphthalene, 4chloro-3-methylphenol, 2methylphenol, 4-methylphenol, and 2methylnaphthalene. Monitoring events conducted in March 2016 indicate the presence of elevated concentrations of benzene, isopropylbenzene, npropylbenzene, 1,1-dichloroethane, and naphthalene. The lateral and vertical extent of the groundwater contaminant plume is fully defined. Contamination is located wholly onsite and the plume is not expanding. The currently approved corrective action is monitored natural attenuation.

Risk-Based Remediation under N.C.G.S. § 130A-310.65 through 310.77

N.C.G.S. § 130A-310.65 through 310.77 provides a mechanism for facilities to remediate contaminated sites based on an evaluation of potential risks to human health and the environment. Because MAN Truck is the responsible party for corrective action under RCRA, MAN Truck notified DEQ of its intent to pursue No Further Action pursuant to N.C.G.S. § 130A-310.65 through 310.77 on March 15, 2012. Because Daimler Trucks is the property owner that is the subject of the Alternate Mechanism, Daimler Trucks acknowledged and endorsed MAN Trucks request on August 9, 2012.

Man Truck submitted a Remedial Investigation Report and Health-Based Risk Assessment (later renamed Remedial Action Plan and Health-Based Risk Assessment (RAP)) on July 24, 2012. After several revisions to the document, the RAP was approved by DEQ on August 9, 2016.

In support of the proposal of to remediate to risk-based remediation goals and thus be granted No Further Action, MAN Truck evaluated all constituents of concern that have the potential to impact human health and the environment, all potential current and future receptors, and all potential pathways that might provide a mechanism for potential receptors to be exposed to remnant groundwater contamination.

No complete exposure pathway between documented contamination and human receptor populations exists under the current risk exposure scenario. The only potential human receptors that may reasonably come into contact with identified contamination in the future are onsite construction workers/utility workers. The results of the risk assessment indicate that exposure to potential contaminants of concern do not pose a significant risk to future construction/utility workers. The risk assessment relied on conservative default exposure factors that would tend to overestimate the potential risks.

Public Participation

The North Carolina Hazardous Waste Management Rules require that the public be given a fortyfive (45) day period to comment on the proposed permit modifications. This forty-five (45) day period will commence on August 26, 2016, and end on October 10, 2016. During this time, the public will have the opportunity to comment on the Class 3 permit modification to (1) remediate to risk-based remediation goals, (2) reduce the post-closure period, and (3) terminate the Alternate Mechanism. Should the Alternate Mechanism be terminated, Daimler Trucks will still be subject to perpetual land use restrictions under N.C.G.S. § 130A-310.65 through 310.77 and N.C.G.S. § 143B-279.9. Land use restrictions will be applied to two areas on the property designated as Areas A and B. Area A is defined as the area of property overlying area of contamination. Area B is defined as a buffer area. Area B applies to the entire real property. Each person who owns any portion of either Area A or Area B shall submit annual certification to the DEQ, or its successor in function, confirming that land use restrictions are still recorded in the Office of the Rowan County Register of Deeds and that activities and conditions applying to Area A and to Area B remain in compliance with the land use restrictions.

A Public Hearing will be held on September 27, 2016, at 1:00 o’clock p.m., in the Rowan County Public Library located at 201 West Fisher Street in Salisbury, North Carolina. All attendees will have the opportunity to present five (5) minute oral statements regarding the proposed remediation to risk-based remediation goals in accordance with N.C.G.S. § 130A-310.65 through 310.77 and the proposed termination of the Alternate Mechanism. Written comments may also be submitted at any time during the forty-five day public comment period. Comments should be sent to the following address:

Julie S. Woosley, Hazardous Waste Section Chief

NC Division of Waste Management

Hazardous Waste Section

1646 Mail Service Center

Raleigh, NC 276991646

All comments received during the public comment period or at the hearing will be considered in the decision to terminate the Alternate Mechanism. Comments received after the public comment period ends will not be considered. The statutory authority for calling the hearing is G.S. 130A294(f). Applicable State rules are found in the North Carolina Hazardous Waste Management Rules 15A NCAC 13A .0105, .0109, and .0113. These rules adopt the requirements of the Federal Resource Conservation and Recovery Act as amended by the Hazardous and Solid Waste Amendments of 1984.

Administrative Record

The entire administrative record can be viewed electronically at the following weblink: http://deq.nc.gov/about/divisions/waste-management/waste-management-rules-data/e-documents. To locate relevant files, search using the ID Number: *018652339*.

Contact Person

Anyone desiring additional information may contact Mary Siedlecki at (919) 707-8208 or at or at the address listed above.