RA-28712_47952_G_O_20210803_UST Inspection

CEDAR ROCK ENVIRONMENTAL, P.C.
107 Pioneer Trail
Graham, NC 27253
[phone]

August 3, 2021

Mr. Larry & Pat Howell
5101 Inverness Drive
Durham, NC 27712

Reference: Inspection of an underground storage tank (UST) located at 137 Roxdale
Place, Roxboro, North Carolina

Cedar Rock Project # 325922590

Dear Mr. Howell:

Cedar Rock Environmental, P. C. (Cedar Rock) performed a site inspection on July 28, 2021 at
the above referenced location. The purpose of the inspection was to determine if the UST
previously used for storing heating oil had leaked causing significant contamination of the
underlying soils.

An inactive UST was observed partially beneath the foundation wall of the house as shown on the
Site Sketch. Both the fill and vent pipes of the UST were observed to be intact. The depth to the
top of the UST is approximately 20 inches below land surface (bls). The size of the UST could
not be determined because one end is beneath the house and the tank had been partially filled with
some solid material. The tank most likely has a capacity between 270 and 560 gallons. White
flagging was installed to mark the western end of the tank (see Photo). No other USTs used for
storing heating oil were discovered on the property using a metal detector to survey the outside
perimeter of the residence where USTs are usually located. Two copper fuel delivery/return lines
were observed to be capped and crimped at the former furnace location. No petroleum odors or
stains were observed near the former oil furnace location.

Once the orientation of the UST was determined, a soil boring was performed at the western end
of the tank using a 3.25-inch diameter stainless steel hand auger. The boring was advanced to a
depth of approximately 6.0 feet bls. A strong petroleum odor was observed in the soils from a
depth of approximately 4.0 to 6.0 feet bls suggesting significant leakage from the UST has
occurred. The soils at the base of the boring consist of an orange-brown sandy silt. One soil
sample, CR-1, was collected at the base of the boring and can be submitted for laboratory analysis,
if required.

The property is currently serviced by a municipal water supply. Two onsite water supply wells
were observed. One was filled and abandoned, the other inactive and disconnected but does not
appear to have been filled and abandoned. The inactive (not abandoned) well is located
approximately 134 feet southwest of the petroleum release. Because this well is within 150 feet
of the release, and unless a well abandonment record can be produced showing the well has been
properly filled by a certified well driller, the property would be classified as “High Risk” by the
Cedar Rock
ENVIRONMENTAL
Mr. Larry & Pat Howell
August 3, 2021
Page 2

State. No other wells were identified within 150 feet of the release.

Based on the results of this investigation, significant contamination of the soils surrounding the
UST has been confirmed. Current law (NCGS 143-215.85 (a) and (b)) requires that any significant
release of petroleum be immediately reported to the North Carolina Department of Environmental
Quality (DEQ), Division of Waste Management, Raleigh Regional Office (919-791-4200).
According to State law, upon reporting the release, the current property owner where a release is
discovered is identified by the State as the “Responsible Party” for any State required action
relating to the UST leakage. Upon request by the property owner, Cedar Rock will submit a UST-
61 form to satisfy the State’s notification requirement for the release.  

Currently, the property cannot be legally conveyed until a Notice of Residual Petroleum (NRP) is
filed with the Person County Register of Deeds office pursuant to NCGS 143B- 279.11 (d). The
NRP would contain applicable land use restrictions to minimize the risk of exposure to existing
contamination. The land use restrictions prohibit any disturbance of site soils within a specified
radius of the estimated extent of soil contamination and prohibit the future operation or installation
of any water supply wells on the property within 150 feet of the petroleum release. Further, the
State will not issue a Notice of No Further Action (NFA) letter to officially close out the release
incident for “High Risk” properties such as this wherein soil or groundwater contamination
exceeding applicable standards remains onsite. The property would be reclassified to “Low Risk”
if all water supply wells, active or inactive, within 150 feet of the release were properly abandoned
by a certified well driller. Once reclassified to “Low Risk” and an NRP approved, the DEQ would
issue a “Conditional” NFA letter to formally close out the release incident. The “Conditional”
provision in the NFA letter will be removed upon receiving a certified copy of the filed NRP and
the completion of Public Notification requirements. Filing the NRP, abandoning any wells within
150 feet of the release and completing Public Notification would not be required if all soil
contamination exceeding applicable standards is removed, however, removal of the tank and
contaminated soils is not technically or economically feasible at this time as a result of the location
of the tank.

Currently the State will require initial abatement or remedial action regarding the release of heating
oil from a UST on a “High Risk” property. Further, once the presence of the UST and confirmed
contaminated soil is disclosed to other interested parties as required by State law, future buyers,
homeowner’s insurance providers, or lenders may also require initial abatement and/or remedial
actions relating to the UST prior to making any commitments towards the property. There also
exists a potential for further environmental impact to the property from continued leakage from
the UST.

An NFA letter can be obtained in two different scenarios. Scenario One requires the removal of
the UST and all associated contaminated soil exceeding applicable standards. Scenario Two
requires reclassifying the property to “Low Risk” by abandoning any supply wells within 150 feet
of the release, abandoning the UST to prevent further leakage, filing an NRP and performing the
Public Notification.

We recommend pursuing Scenario Two and reclassifying the property to “Low Risk” followed by
abandonment of the UST considering the removal of the tank and contaminated soils would be
extremely disruptive to the property, cost prohibitive, and may not result in a clean closure if all
Mr. Larry & Pat Howell
August 3, 2021
Page 3

of the contamination is not removed. The tank abandonment would consist of exposing a portion
of the UST by hand excavation, cutting a hole about two feet in diameter on the topside of the
UST, removing all tank and fuel line contents, pressure wash cleaning of the tank interior, and
filling the tank with an excavatable flowable fill cement slurry. A summary report signed by a
licensed geologist would be generated that would include photographs of each step of the
abandonment process, including a photograph of the interior of the UST to show the UST was
properly cleaned. Cedar Rock can provide this service for a charge of $3,500.00 plus $1.25 per
gallon of recovered fluids assuming the tank is no larger than 560 gallons. If the tank is
discovered to be greater than 560 gallons, an additional charge of $1.00 for every gallon
exceeding 560 gallons capacity would apply. Preparing and filing the NRP and performing the
Public Notification requirement will cost an additional $1,250.00. Cedar Rock would not be
responsible for properly abandoning any water supply wells to lower the risk classification of the
property.

Attached is an invoice for the site inspection. We appreciate the opportunity to be of service to
you. If you have any questions regarding the content of this report, please call me at 336-376-
0394.

Sincerely,

Robert A. Payne, N.C. Licensed Geologist #0970

Attachment
Mr. Larry & Pat Howell
August 3, 2021
Page 4

Site Sketch. Not to scale. Sketch used for reference purposes only.

Photo. View of the UST location. Western end of the UST marked with white flag.
N 8 ft
House
UST
Location of
soil sample CR-1
Roxdale Place
Well
31 ft
68 ft
46 ft