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HomeMy WebLinkAboutWI-28992_48178_CA_SCH_20211119 3502 Hayes Road • Monroe, North Carolina 28110 113 West Firetower Road, Suite G • Winterville, North Carolina 28590 Phone (704) 845-4010 • (888) 870-4133 • Fax (704) 845-4012 January 19, 2022 Mr. Clark Wipfield NCDEQ-UST Section Wilmington Regional Office 127 Cardinal Drive Extension Wilmington, NC 28405 Re: Site Check Report Home Race Mart #1 7824 Seven Springs Highway Nakina, Columbus County North Carolina Facility ID Number: 00-0-0000034121 Incident Number: Pending GRI Project Number: 5836 Dear Mr. Wipfield, Please find enclosed the referenced report for the above mentioned site. If you have any questions, please contact Ethan Rogerson at 704-845-4010. Sincerely, Geological Resources, Inc. Leslie Maxtone-Graham Administrative Assistant Enclosure Cc: Mr. Sanjeev Sethi; K&S, LLC, Inc. 3502 Hayes Road • Monroe, North Carolina 28110 113 West Firetower Road, Suite G • Winterville, North Carolina 28590 Phone (704) 845-4010 • (888) 870-4133 • Fax (704) 845-4012 Engineering Certification: C-2727 • Geology Certification: C-127 Site Check Report Home Race Mart #1 7824 Seven Springs Highway Nakina, Columbus County North Carolina Facility ID Number: 00-0-0000034121 Incident Number: Pending GRI Project Number: 5836 Prepared for: Sanjeev Sethi K&S, LLC 7824 Seven Creeks Highway Nakina, North Carolina 28455 November 19, 2021 Ethan Rogerson, G.I.T. Project Manager William Regenthal, P.G. Report Editor ___________________________________________________________________________________________ Prepared by: Geological Resources, Inc. Site Check Report Prepared on: November 19, 2021 Home Race Mart #1 Project Manager: Ethan Rogerson, G.I.T. GRI Project No. 5836 i EXECUTIVE SUMMARY The Home Race Mart #1 site is located at 7824 Seven Springs Highway in Nakina, Columbus County, North Carolina. The property operates as a petroleum retail facility and convenience store. The site is covered by concrete, asphalt and grass. There are one 12,000-gallon compartmentalized gasoline, one 6,000- gallon diesel and one 2,000-gallon off-road diesel USTs currently in use at the site with six associated dispenser islands. On October 21, 2021, two soil sample (SS-PREM-2' and SS-ORDSL-2’) were collected at the 4,000-gallon gasoline and 2,000-gallon off-road diesel spill buckets, respectively. Concentrations of TPH-GRO and TPH- DRO exceeded the RALs that exceeded the RALs were reported in soil sample SS-ORDSL-2’. Based on this information, a soil quality violation exists and further assessment is warranted at the site. ___________________________________________________________________________________________ Prepared by: Geological Resources, Inc. Site Check Report Prepared on: November 19, 2021 Home Race Mart #1 Project Manager: Ethan Rogerson, G.I.T. GRI Project No. 5836 iii ACRONYMS ACM: Asbestos Containing Materials AFVR: Aggressive Fluid-Vapor Recovery ARR: Acknowledgement of Report Receipt AS: Air Sparging AST: Aboveground Storage Tank ASTM: American Society for Testing and Materials BGS: Below Ground Surface CAP: Corrective Action Plan CFR: Code of Federal Regulations CSA: Comprehensive Site Assessment DPE: Dual Phase Extraction DRO: Total Petroleum Hydrocarbons Diesel Range Organics DWM: Division of Waste Management DWR: Department of Water Resources EPA: Environmental Protection Agency EPH: Extractible Petroleum Hydrocarbons ESA: Environmental Site Assessment GCL: Gross Contamination Level GRI: Geological Resources, Inc. GRO: Total Petroleum Hydrocarbons Gasoline Range Organics LSA: Limited Site Assessment MAC: Maximum Allowable Concentration as specified in T15A NCAC 2L.0202 MADEP: Massachusetts Department of Environmental Protection MCC: Maximum Contaminant Concentrations MMPE: Mobile Multi-Phase Extraction NAPL: Non-Aqueous Phase Liquid, “Free Product” NCDEQ: North Carolina Department of Environmental Quality NCDOT: North Carolina Department of Transportation NFA: Notice of No Further Action NORR: Notice of Regulatory Requirements NOV: Notice of Violation NPDES: National Pollutant Discharge Elimination System NRP: Notice of Residual Petroleum O&M: Operation and Maintenance PAHs: Polynuclear Aromatic Hydrocarbons PCA: Pre-Construction Assessment RAL: Regulatory Action Level SCLs: Soil Cleanup Level SPCC: Spill Prevention Control and Countermeasures SVE: Soil Vapor Extraction SVOCs: Semi-Volatile Organic Compounds SWPPP: Stormwater Pollution Prevention Plan TCLP: Toxicity Characteristic Leaching Procedure (EPA Method SW-846 1311) TOC: Top of Casing TPH: Total Petroleum Hydrocarbons USGS: United States Geological Survey UST: Underground Storage Tank UVF: Ultraviolet Fluorescence VOCs: Volatile Organic Compounds VPH: Volatile Petroleum Hydrocarbons ___________________________________________________________________________________________ Prepared by: Geological Resources, Inc. Site Check Report Prepared on: November 19, 2021 Home Race Mart #1 Project Manager: Ethan Rogerson, G.I.T. GRI Project No. 5836 TABLE OF CONTENTS EXECUTIVE SUMMARY ....................................................................................................................... i SITE INFORMATION ............................................................................................................................ ii ACRONYMS ................................................................................................................................. iii A. SITE HISTORY AND CHARACTERIZATION .....................................................................1 B. SITE CHECK PROCEDURES ...........................................................................................2 C. SITE INVESTIGATION ..................................................................................................2 D. SUMMARY AND CONCLUSIONS ..................................................................................3 E. LIMITATIONS .............................................................................................................3 FIGURES Figure 1: Site Location Map Figure 2: Site Map Figure 3: Soil Quality Map TABLES Table 1: UST Owner/Operator Information Table 2: UST System Information Table 3: Summary of Soil Sample Analytical Results APPENDICES Appendix A: State Correspondence Appendix B: 24-Hour Release and UST Leak Reporting Form (UST-61) Appendix C: Laboratory Report – Soil Sample ___________________________________________________________________________________________ Prepared by: Geological Resources, Inc. Site Check Report Prepared on: November 19, 2021 Home Race Mart #1 Project Manager: Ethan Rogerson, G.I.T. GRI Project No. 5836 1 A. SITE HISTORY AND CHARACTERIZATION 1. UST Owner and Operator Information: In accordance with the Site Check Report guidelines, the UST owner and operator information has been summarized in the attached Table 1. 2. UST System Information: In accordance with the Site Check Report guidelines, the UST system information has been summarized in the attached Table 2. There are one 12,000-gallon compartmentalized gasoline, one 6,000-gallon diesel and one 2,000-gallon off-road diesel USTs currently in use at the site with six associated dispensers at the site. A copy of the NCDEQ Registered Tank Report is shown below: 3. Non-UST Information: There are currently no ASTs at the site. 4. Comprehensive Description of the Release: On August 25, 2021, compliance testing was conducted. The 4,000-gallon compartment of the gasoline UST and 2,000-gallon off-road diesel spill buckets received non-passing testing results. The non-passing spill buckets were reportedly repaired and received a passing compliance test. State correspondence is included as Appendix A. On October 21, 2021, two soil samples (SS-PREM-2' and SS-ORDSL-2’) were collected approximately 2 feet bgs, from unlined ATG sumps directly adjacent to the 4,000-gallon gasoline compartment and 2,000-gallon ___________________________________________________________________________________________ Prepared by: Geological Resources, Inc. Site Check Report Prepared on: November 19, 2021 Home Race Mart #1 Project Manager: Ethan Rogerson, G.I.T. GRI Project No. 5836 2 off-road diesel spill buckets, respectively. A release was confirmed upon receipt of the laboratory results for the soil samples collected in October 2021. A copy of the UST-61 Form has been included as Appendix B. 5. Description of the Site Characteristics: The Home Race Mart #1 site is located at 7824 Seven Springs Highway in Nakina, Columbus County, North Carolina. (Figure 1). The property operates as a petroleum retail facility and convenience store. The site is covered by concrete, asphalt and grass. There are one 12,000-gallon compartmentalized gasoline, one 6,000-gallon diesel and one 2,000-gallon off-road diesel USTs currently in use at the site. The surrounding properties are agricultural and residential. A Site Map has been included as Figure 2. B. SITE CHECK PROCEDURES 1. Results of Tank and Line Tightness Testing: On October 26, 2020, two non-passing UST spill buckets were reported at the site. The non-passing spill buckets were reportedly repaired and received passing compliance tests. 2. Summary of Site Check Procedure: On October 21, 2021, GRI performed a site check that included collecting soil samples from unlined ATG sumps directly adjacent to the 4,000-gallon gasoline compartment and 2,000-gallon off-road diesel spill buckets, respectively. Soil samples SS-PREM-2' and SS-ORDSL-2’ were collected approximately 2 feet bgs, from unlined ATG sumps directly adjacent to the 4,000-gallon gasoline and 2,000-gallon off road diesel spill buckets, respectively. 3. Soil Excavation Activities: No soil excavation activities were conducted. C. SITE INVESTIGATION 1. Field Screening: Soil samples were not screened with a PID for VOCs. 2. Soil Sampling Information: Soil sample SS-PREM-2' and SS-ORDSL-2’ were collected on October 21, 2021 and were submitted for laboratory analyses of TPH-GRO and/or TPH-DRO. The concentrations of GRO and DRO reported in soil sample SS-ORDSL-2' exceeded the RALs. No free product was observed at the site. A soil quality map is presented as Figure 3. A summary of soil sample analytical results is presented in Table 3. The laboratory report is provided as Appendix C. A summary of the soil sampling data from the October 2021 Site Check activities is show below: ___________________________________________________________________________________________ Prepared by: Geological Resources, Inc. Site Check Report Prepared on: November 19, 2021 Home Race Mart #1 Project Manager: Ethan Rogerson, G.I.T. GRI Project No. 5836 3 Sample ID Sample Depth (ft-BGS) Gasoline-Range TPH Diesel-Range DRO RAL (mg/kg) 50 100 Soil to Water MCC (mg/kg) NE NE SS-ORDSL-2 2 176 3,250 SS-PREM-2 2 8.67 NR 3. Ground Water and Surface Water Sampling Information: A ground water sample was not collected during the October 21, 2021, site check. 4. Quality-Control Measures: Clean, disposable nitrile gloves were used for the collection of the soil samples. The samples were collected in laboratory supplied containers and shipped to the laboratory in a cooler following proper chain-of-custody procedures. D. SUMMARY AND CONCLUSIONS  The site is a petroleum retail facility and convenience store. Surrounding properties are agricultural and residential.  The spill buckets associated with the 4,000-gallon gasoline compartment and 2,000-gallon off- road diesel USTs received non-passing testing results and were reportedly repaired.  A Site Check was conducted on October 21, 2021.  Two soil samples (SS-PREM-2’ and SS-ORDSL-2') were collected from the unlined ATG sumps directly adjacent to the non-compliant spill buckets.  Concentrations of GRO and DRO exceeding the RALs were reported in soil sample SS-ORDSL-2’.  Based on this information, a soil quality violation exists and further assessment is warranted for this site. E. LIMITATIONS This report has been prepared for the exclusive use of K&S, LLC, Inc. for the specific application to the referenced site in Columbus County, North Carolina. The assessment was conducted based on the scope of work and level of effort specified by NCDEQ and with resources adequate only for that scope of work. Our findings have been developed in accordance with generally accepted standards of geology and hydrogeology practices in the State of North Carolina, available information, and our professional judgment. No other warranty is expressed or implied. The data that are presented in this report are indicative of conditions that existed at the precise locations ___________________________________________________________________________________________ Prepared by: Geological Resources, Inc. Site Check Report Prepared on: November 19, 2021 Home Race Mart #1 Project Manager: Ethan Rogerson, G.I.T. GRI Project No. 5836 4 sampled and at the time the samples were collected. In addition, the data obtained from samples would be interpreted as being meaningful with respect to parameters indicated in the laboratory report. No additional information can logically be inferred from these data. FIGURES SITE LOCATIONFigure 1 Site Location Home Race Mart #17824 7 Creeks HighwayNakina, North CarolinaColumbus CountyIncident No. N/AGRI Project No. 5836500 M2000 FTDate: 11/20/2021Location: 34.134276° N -78.668266° W Dad TABLES UST ID Number 1-3 and 1B Facility ID Number Owner or Operator? Owner UST ID Number 2 and 3 Facility ID Number Owner or Operator? Owner UST ID Number 2 and 3 Facility ID Number Owner or Operator? Owner UST ID Number 1 and 1B Facility ID Number Owner or Operator? Owner Unknown Telephone Number Unknown Address Home Run Food Mart, Inc. Unknown Unknown 00-0-0000034121 Dates of Ownership / Operation 08/01/1993 - 10/08/2010 Name of Owner or Operator Name of Owner or Operator Dates of Ownership / Operation Home Run Food Mart, Inc.04/03/2002 - 10/08/2010 Address Telephone Number Address Telephone Number Unknown Unknown 00-0-0000034121 00-0-0000034121 Name of Owner or Operator Dates of Ownership / Operation Nikki and Vicky, Inc.10/08/2010 - 01/03/2017 00-0-0000034121 TABLE 1 UST OWNER/OPERATOR INFORMATION HOME RACE #1 (INCIDENT NO. PENDING) 7824 Seven Creeks Highway, Nakina, NC 28455 910-234-0453 Name of Owner or Operator Dates of Ownership / Operation K & S, LLC 01/03/2017 - Current Address Telephone Number Page 1 of 1 Date: 11/12/21 Was Release Associated with UST System? (Yes / No) 1B Gasoline 4,000 12/1/1993 Single Wall Steel/FRP Unknown Single Wall FRP Current No 3 Diesel 2,000 4/3/2002 Single Wall Steel/FRP Unknown Other Current No 2 Diesel 6,000 4/3/2002 Single Wall Steel/FRP Unknown Double Wall FRP Current Yes 1 Gasoline 8,000 12/1/1993 Single Wall Steel/FRP Unknown Single Wall FRP Current No TABLE 2 UST SYSTEM INFORMATION HOME RACE #1 (INCIDENT NO. PENDING) UST ID No. Current or Most Recent Contents Capacity (gallons) Date Installed Construction Details Tank Dimensions Description of Associated Product Piping and Pumps Status of UST Facility ID #: 00-0-0000034121 Page 1 of 1 Date: 11/12/21 5030/ 8015D 3550/ 8015C Sample IDDate Collected (mm/dd/yy)Sample Depth(ft-BGS)Gasoline-Range TPHDiesel-Range TPH50 100 NE NE NE NE SS-ORDSL-2 10/21/2021 2 176 3,250 SS-PREM-2 10/21/2021 2 8.67 NR Notes: • Results reported in mg/kg (milligrams per kilograms) • ft-BGS: feet below ground surface. • RAL: Regulatory Action Level. • MCCs: Maximum Contaminant Concentrations (soils). • SCLs: Soil Cleanup Levels. • < : Less than the method detection limit specified in the laboratory report • Concentrations in bold face type indicate the reported concentrations exceeded the soil-to-water MCCs. • Concentrations in italic type indicate the reported concentrations exceeded the residential SCLs. • NE: Not Established • NR: Not Requested. TABLE 3 SUMMARY OF SOIL SAMPLE ANALYTICAL RESULTS HOME RACE #1 (INCIDENT NO. PENDING) RAL (mg/kg) Soil to Water MCC (mg/kg) Residential SCLs (mg/kg) Analytical Method  Facility ID #: 00-0-0000034121 Page 1 of 1 APPENDICES Appendix A State Correspondence Page 1 of 9 9/14/2021 12:50 PM North Carolina Department of Environmental Quality Underground Storage Tank UST-10BPrinted:9/14/2021 12:49 PM Inspection Result:Failed Inspection Date:8/25/2021 Partial Inspection:No Arrive and Depart Times:10:55 AM-11:25 AM Facility ID:00-0-0000034121 Inspector John Hooks Facility Name HOME RACE MART #1 Insp.Type Compliance Facility Address 7824 SEVEN SPRING HIGHWAY NAKINA,NC 28455 Columbus County Located facility,USTs onsite Reason(s)Routine Compliance Location 34.134353,-78.668531 Permit Exp.12/31/2021 Facility Phone (910)642-7444 CONTACTS Contact Type Contact Information Owner since 1/3/2017 K &S LLC ,7824 SEVEN CREEKS HIGHWAY NAKINA,NC 28455,Phone:(910) 642-7444,Email:Sanjeev_sethi@aol.com Owner Auth Rep since 1/3/2017 SANJEEV SETHI,7824 SEVEN CREEKS HIGHWAY NAKINA,NC 28455,Phone: (910)234-0453,Cell Phone:(910)642-7444,Email:sanjeev-sethi@aol.com Regulatory Operator since 10/15/2018 SHIVAM LLC ,7824 SEVEN CREEKS HIGHWAY NAKINA,NC 28455,Phone:(910) 922-6795 Operator since 1/3/2017 SHIVAM LLC ,7824 SEVEN CREEKS HIGHWAY NAKINA,NC 28455,Phone:(910) 922-6795 OWNERSHIP CHANGE New Owner Change Date Basis Transfer of Ownership Form (UST-15)Submitted No EMERGENCY RESPONSE Emergency response placard with emergency response operator contact information is posted in the dispensing areas if the dispensers are left on without an attendant present? N/A OTHER PARTICIPANTS Name Organization INSPECTOR COMMENTS Type Date Comment ADDITIONAL INSPECTOR COMMENTS bf at both dsl.sumps at all.flex pipe at all TANKS AND PIPING INFORMATION Tanks Tank #1(1B- prem) Tank #2(3-off dsl)Tank #3(dsl)Tank #4(reg-) Tank ID 1B-prem 3-off dsl dsl reg- TIMS Tank ID 1B 3 2 1 Is tank registered?Yes Yes Yes Yes Date tank installed 12/1/1993 4/3/2002 4/3/2002 12/1/1993 Capacity of Tank in Gallons 4000 2000 6000 8000 Is tank regulated Yes Yes Yes Yes Diameter (Inches) Tank /Product use Motor Fuel Motor Fuel Motor Fuel Motor Fuel UST-10B Facility ID:00-0-0000034121 Page 2 of 9 9/14/2021 12:50 PM Tanks Tank #1(1B- prem) Tank #2(3-off dsl)Tank #3(dsl)Tank #4(reg-) Product stored in Tank Gasoline,Gas Mix Diesel Diesel Gasoline,Gas Mix Product Detail Premium BLANK BLANK Regular If hazardous substance, CAS#or description If other,description Tank status Current Current Current Current Tank closure report submitted Date tank last operated Inches of product in Tank Compartment tank Yes No No Yes Other compartment(s)#4(reg-)#1(1B-prem) Base compartment No Yes Manifolded tank No No No No Manifolded with tank(s) Master manifold tank New Tank System installed in accordance with NC or MI Yes Yes Yes Yes Tank Construction Material (DW required after 11/1/07) Single Wall Steel/FRP Single Wall Steel/FRP Single Wall Steel/FRP Single Wall Steel/FRP If other,description Tank Manufacturer/Model Unknown Unknown Unknown Unknown If other,describe Tank material verified by Invoice Invoice Invoice Invoice Date Pipe Installed 12/1/1993 12/1/1993 12/1/1993 12/1/1993 Was UST Piping Installed on or after 11/1/2007? No No No No Piping Construction Material (DW required after 11/1/07) Double Wall FRP Double Wall FRP Double Wall FRP Double Wall FRP If other,description Pipe Manufacturer/Model Unknown Unknown Unknown Unknown If other,describe Pipe material verified by Visual Visual Visual Visual If E-blend >10%or Biodiesel Blend >20%; Was UST-20 completed and approved? N/A N/A N/A N/A CORROSION PROTECTION Tank Corrosion Protection Tank #1(1B- prem) Tank #2(3- off dsl) Tank #3(dsl)Tank #4(reg-) DWM notified of current CP method Yes Yes Yes Yes Integrity assessment performed after 3/1/06 No No No No CP Method 1 Steel/FRP Composite Steel/FRP Composite Steel/FRP Composite Steel/FRP Composite if other,Description CP Installation Date 12/1/1993 4/3/2002 4/3/2002 12/1/1993 CP Method 2 if other,Description CP Installation Date Flex Connector ,Piping Extensions,and/or other metal fittings Present Other Metal Other Metal Other Metal Other Metal Flex connector isolated from ground Yes Yes Yes Yes UST-10B Facility ID:00-0-0000034121 Page 3 of 9 9/14/2021 12:50 PM Tank Corrosion Protection Tank #1(1B- prem) Tank #2(3- off dsl) Tank #3(dsl)Tank #4(reg-) Source of verification of CP for Flex Connectors,piping extensions and/or other metal fittings Visual Visual Visual Visual if other,Description Submersible pump (STP)is isolated from ground Yes Yes Yes Yes Piping extensions and/or other metal fittings are isolated from ground Yes Yes Yes Yes Flex connector,STP and/or other metal fittings protected from corrosion N/A N/A N/A N/A Corrosion protection method Flex connector ,Piping extensions,and/or other metal fittings CP Installation Date Dielectric Coating Installed (If tank installed after 12/22/88 Yes Yes Yes Yes Pipe Corrosion Protection Tank #1(1B- prem) Tank #2(3-off dsl) Tank #3(dsl)Tank #4(reg-) DWM notified of current CP method Yes Yes Yes Yes CP method FRP Piping Flexible Flexible FRP Piping if other,Description CP Installation Date 12/1/1993 4/3/2002 4/3/2002 12/1/1993 Dielectric Coating Installed (If piping installed after 12/22/88 N/A N/A N/A N/A Dispenser Corrosion Protection Dispenser #1(1) Dispenser #2(2) Dispenser #3(3) Dispenser #4(4) Flex Connector ,Piping Extensions, and/or other metal fittings Present Other Metal Other Metal Other Metal Other Metal Flex connector isolated from ground Yes Yes Yes Yes Source of verification of CP for Flex Connectors,piping extensions and/or other metal fittings Visual Visual Visual Visual if other,Description Piping extensions and/or other metal fittings are isolated from ground Yes Yes Yes Yes Flex Connectors,Piping extensions and/or other metal fittings protected from corrosion N/A N/A N/A N/A Corrosion protection method Isolated Isolated Isolated Isolated Flex connector,Piping extensions, and/or other metal fittings CP Installation Date Source of Information for verification of corrosion protection for Riser pipe and other metal piping Visual Visual Visual Visual if other,Description Dispenser Corrosion Protection Dispenser #5(5) Flex Connector ,Piping Extensions, and/or other metal fittings Present Other Metal Flex connector isolated from ground Yes Source of verification of CP for Flex Connectors,piping extensions and/or other metal fittings Visual UST-10B Facility ID:00-0-0000034121 Page 4 of 9 9/14/2021 12:50 PM Dispenser Corrosion Protection Dispenser #5(5) if other,Description Piping extensions and/or other metal fittings are isolated from ground Yes Flex Connectors,Piping extensions and/or other metal fittings protected from corrosion N/A Corrosion protection method Isolated Flex connector,Piping extensions, and/or other metal fittings CP Installation Date Source of Information for verification of corrosion protection for Riser pipe and other metal piping Visual if other,Description CP Conclusions CP Requirements Met?Yes Issues SPILL PREVENTION Has DWM been notified of spill methods?Yes Spill/Overfill Details Tank #1(1B- prem) Tank #2(3-off dsl) Tank #3(dsl)Tank #4(reg-) Is a drop tube present?Yes Yes Yes Yes Type of Stage I vapor recovery?Coaxial Not Required Not Required Coaxial Local Fill Tank #1(1B- prem) Tank #2(3-off dsl) Tank #3(dsl)Tank #4(reg-) Does Tank have a Second Fill?No No No No Spill Protection Catchment Basin Catchment Basin Catchment Basin Catchment Basin Is spill prevention equipment provided and verified? Yes Yes Yes Yes Manufacturer/Model Other Other Other Other If other,describe opw opw opw opw Spill bucket is double-walled?N/A N/A N/A N/A Monitoring Type (UST-6B) Is spill bucket interstice monitored every 30 days?(If installed before 11/1/07) Spill bucket is isolated or made of non- corroding materials?(If installed after 11/1/07) N/A N/A N/A N/A Date spill prevention provided 12/1/1993 4/3/2002 4/3/2002 12/1/1993 Last 12 monthly spill bucket checks completed and all deficiencies corrected (UST-27)? Is spill prevention operating properly?No No Yes Yes If No,select all that apply Hole/Defect Hole/Defect If other,describe O&M walkthrough inspection completed in accordance with national standard (e.g. PEI RP 900)(UST-27)? No No No No UST-10B Facility ID:00-0-0000034121 Page 5 of 9 9/14/2021 12:50 PM Local Fill Tank #1(1B- prem) Tank #2(3-off dsl) Tank #3(dsl)Tank #4(reg-) 3 Year Tightness Test Date (UST-6D/23A) 10/26/2020 10/26/2020 10/26/2020 10/26/2020 Primary Tightness Test Result (UST-6D/23A) Fail Fail Pass Pass Secondary Tightness Test Result (UST-6D/23A) Tightness Testing done in accordance with a standard? Yes Yes Yes Yes OVERFILL PREVENTION Has DWM been notified of overfill methods?Yes Overfill Control Tank #1(1B- prem) Tank #2(3-off dsl) Tank #3(dsl)Tank #4(reg-) Is overfill prevention equipment provided and verified? Yes Yes Yes Yes Date overfill control provided 12/1/1993 4/3/2002 4/3/2002 12/1/1993 Type of overfill equipment Auto Shutoff Device Ball Float Valve Ball Float Valve Auto Shutoff Device Source of information for overfill control verification UST-22A UST-22A UST-22A UST-22A If other,describe Manufacturer/Model BLANK BLANK BLANK BLANK If other,describe Is overfill control operating properly?No Yes Yes No If No,select all that apply Incorrect length/volume Incorrect length/volume If other,describe Overfill check date (UST-22A)10/26/2020 10/26/2020 10/26/2020 10/26/2020 Overfill check result (UST-22A)Fail Pass Pass Fail Capacity of Tank in Gallons 4000 2000 6000 8000 Diameter (Inches) Dispenser Sumps Dispenser #1(1) Dispenser #2(2) Dispenser #3(3) Dispenser #4(4) Are containment sumps present?Yes Yes Yes Yes Installation Date 10/31/2007 10/31/2007 10/31/2007 10/31/2007 Sump Manufacturer Unknown Unknown Unknown Unknown If Other (Specify) Sump Construction Type Single Walled Single Walled Single Walled Single Walled Sump Construction Material Plastic Plastic Plastic Plastic If Other (Specify) Are containment sumps monitored?No No No No Is monitoring required per 2N .0900?No No No No Piping components and/or STP were installed/replaced on or after 11/1/07? No No No No Are spills or small weeps evident in sumps? No No No No Are single wall piping components located in containment sump?(If installed after 11/1/07) UDC Visual Inspection Date (annually)(UST-22C) 10/26/2020 10/26/2020 10/26/2020 10/26/2020 UDC Visual Inspection Results (UST-22C) Pass Pass Pass Pass UST-10B Facility ID:00-0-0000034121 Page 6 of 9 9/14/2021 12:50 PM Dispenser Sumps Dispenser #1(1) Dispenser #2(2) Dispenser #3(3) Dispenser #4(4) Annual containment sump check completed in accordance with national standard (e.g.PEI RP 900)? Yes Yes Yes Yes Dispenser Sumps Dispenser #5(5) Are containment sumps present?Yes Installation Date 10/31/2007 Sump Manufacturer Unknown If Other (Specify) Sump Construction Type Single Walled Sump Construction Material Plastic If Other (Specify) Are containment sumps monitored?No Is monitoring required per 2N .0900?No Piping components and/or STP were installed/replaced on or after 11/1/07? No Are spills or small weeps evident in sumps? No Are single wall piping components located in containment sump?(If installed after 11/1/07) UDC Visual Inspection Date (annually)(UST-22C) 10/26/2020 UDC Visual Inspection Results (UST-22C) Pass Annual containment sump check completed in accordance with national standard (e.g.PEI RP 900)? Yes Other Sumps Sump#1(offd slstp) Sump#2(on dsl stp) Sump#3(pre mstp) Sump#4(reg stp) Are containment sumps present?Yes Yes Yes Yes Installation Date 10/31/2007 10/31/2007 10/31/2007 10/31/2007 Sump Manufacturer Environ:Tank Sump Environ:Tank Sump Environ:Tank Sump Environ:Tank Sump If Other (Specify) Sump Construction Type Single Walled Single Walled Single Walled Single Walled Sump Construction Material Plastic Plastic Plastic Plastic If Other (Specify) Are containment sumps monitored?No No No No Is monitoring required per 2N .0900?No No No No Piping components and/or STP were installed/replaced on or after 11/1/07? No No No No Are spills or small weeps evident in sumps? No No No No Are single wall piping components located in containment sump?(If installed after 11/1/07) Sump Visual Inspection Date (annually)(UST-22C) 10/26/2020 10/26/2020 10/26/2020 10/26/2020 Sump Visual Inspection Results (UST-22C) Pass Pass Pass Pass Annual containment sump check completed in accordance with national standard (e.g.PEI RP 900)? Yes Yes Yes Yes UST-10B Facility ID:00-0-0000034121 Page 7 of 9 9/14/2021 12:50 PM SITING AND SECONDARY CONTAINMENT Siting And Sec.Containment-General Tank #1(1B- prem) Tank #2(3-off dsl) Tank #3(dsl)Tank #4(reg- ) UST system upgraded with corrosion protection,spill and overfill before 1/1/91? N/A N/A N/A N/A UST system and/or piping are located within siting and secondary containment areas? No No No No LEAK DETECTION General Tank #1(1B- prem) Tank #2(3-off dsl) Tank #3(dsl)Tank #4(reg-) DWM notified of leak detection method?Yes Yes Yes Yes Piping Type Piping type Pressurized System Pressurized System Pressurized System Pressurized System if other,specify Suction check type Type LLD present.MLLD MLLD MLLD MLLD Tank Release Detection Primary leak detection method Automatic Tank Gauging Automatic Tank Gauging Automatic Tank Gauging Automatic Tank Gauging if other,specify Primary LD install date 4/3/2002 4/3/2002 4/3/2002 4/3/2002 Secondary leak detection method if other,specify Piping Release Detection Primary leak detection method Line Tightness Testing (LTT) Line Tightness Testing (LTT) Line Tightness Testing (LTT) Line Tightness Testing (LTT) if other,specify Primary LD install date 4/3/2002 4/3/2002 4/3/2002 4/3/2002 Secondary leak detection method if other,specify Equipment Checks Last 12 monthly RD equipment checks completed and all deficiencies corrected (UST-27)? if no,select all that apply Annual RD equipment operability check result (UST-22B) Pass Pass Pass Pass if Fail,select all that apply Annual RD equipment operability check date (UST-22B) 10/26/2020 10/26/2020 10/26/2020 10/26/2020 RD equipment checks completed per national standard (e.g.PEI RP 900/1200) (UST-22B/27)? Yes Yes Yes Yes PIPING LEAK DETECTION Pressurized Piping Tank #1(1B- prem) Tank #2(3-off dsl) Tank #3(dsl)Tank #4(reg-) Last MLLD/ELLD Test Date 10/26/2020 10/26/2020 10/26/2020 10/26/2020 MLLD/ELLD Test Result Pass Pass Pass Pass Last LTT Test Date 10/26/2020 10/26/2020 10/26/2020 10/26/2020 LTT Test Result Pass Pass Pass Pass Does test result indicate suspected release? No No No No UST-10B Facility ID:00-0-0000034121 Page 8 of 9 9/14/2021 12:50 PM Pressurized Piping Tank #1(1B- prem) Tank #2(3-off dsl) Tank #3(dsl)Tank #4(reg-) Number of MLLD/ELLD Types 1 1 1 1 MLLD/ELLD Equipment Tank #1(1B- prem)LLD #1 Tank #2(3-off dsl)LLD #1 Tank #3(dsl)LLD #1 Tank #4(reg-) LLD #1 MLLD/ELLD Manufacturer/Model Red Jacket:FX1V V-R/RJ:FX1DV (M) V-R/RJ:FX1DV (M) Red Jacket:FX1V If other,describe MLLD/ELLD Third Party Certified? Yes Yes Yes Yes MLLD/ELLD Testers MLLD/ELLD Tester #1 MLLD/ELLD Tester Name Rodney Ferguson MLLD/ELLD Testing Company Name NTM MLLD/ELLD Testing Company Phone Number (800)643-8265 Pressurized Piping LTT LTT #1 LTT Manufacturer/Method AcuRite:Training &Serv If other,describe LTT Third Party Certified?Yes Pressurized Piping LTT Tester LTT Tester #1 LTT Tester Name Rodney Ferguson LTT Testing Company Name NTM LTT Testing Company Phone Number (800)643-8265 AUTOMATIC TANK GAUGE ATG Systems ATG #1 ATG Manufacturer/Model V-R:TLS-350 CSLD If other,describe ATG Third Party Certified?Yes Is ATG console operational?Yes Tanks #1(1B-prem),#2(3-off dsl),#3(dsl),#4(reg-) ATG Monthly LD Tank #1(1B-prem)Tank #2(3-off dsl)Tank #3(dsl)Tank #4(reg-) 2021 Aug Pass Pass Pass Pass 2021 Jul Pass Pass Pass Pass 2021 Jun Pass Pass Pass Pass 2021 May Pass Pass Pass Pass 2021 Apr Pass Pass Pass Pass 2021 Mar Pass Pass Pass Pass 2021 Feb Pass Pass Pass Pass 2021 Jan Pass Pass Pass Pass 2020 Dec Pass Pass Pass Pass 2020 Nov Pass Pass Pass Pass 2020 Oct Pass Pass Pass Pass 2020 Sep Pass Pass Pass Pass ATG Conclusions Leak Detection Requirements Met?Yes UST-10B Facility ID:00-0-0000034121 Page 9 of 9 9/14/2021 12:50 PM ATG Conclusions Do the results indicate a suspected release? Issues REPAIRS Repairs Any Repair Issues?No Issues Delivery Information Tank #1(1B- prem) Tank #2(3-off dsl) Tank #3(dsl)Tank #4(reg-) All deliveries made to permitted tanks Yes Yes Yes Yes SITE DIAGRAM 1 NORTH CAROLINA Environmental Quality North Carolina Department of Environmental Quality | Division of Waste Management 217 West Jones Street | 1646 Mail Service Center | Raleigh, North Carolina 27699-1646 919.707.8171 ROY COOPER Governor ELIZABETH S. BISER Secretary MICHAEL SCOTT Director September 14, 2021 CERTIFIED MAIL 70182290000182956365 RETURN RECEIPT REQUESTED Sanjeev Sethi, Registered Agent K & S LLC 7824 Seven Creeks Highway Nakina, NC 28455 Re: NOTICE OF VIOLATION OF 15A NCAC 2N .0301(UPG2, UPG3), .0407(MT8, RCD6), .0603(RLS7) Home Race Mart #1 7824 Seven Spring Highway, Nakina, NC 28455 Columbus County Facility ID#: 00-0-0000034121 Dear Sanjeev Sethi: On August 25, 2021, I conducted a compliance inspection at the above-referenced facility. I observed that underground storage tanks (USTs) at Home Race Mart #1 are not in compliance with North Carolina UST regulations (North Carolina Administrative Code [NCAC] 2N "Criteria and Standards Applicable to Underground Storage Tanks). According to those rules (15A NCAC 2N .0203) K & S LLC is identified as the owner and/or operator of UST(s) at Home Race Mart #1. The following violations of the state rules (15A NCAC 2N) were observed on August 25, 2021 at Home Race Mart #1. Following each violation are the actions required to correct the violations: Violation 1: 15A NCAC 2N .0301 UPG2; Failure to meet the spill prevention requirements of a 'new tank system' as required by federal regulation 40 CFR 280.20(c) (as incorporated by 15A NCAC 2N .0301). Corrective Action(s): All UST systems installed after December 22, 1988 are defined as 'new tank systems.' All "new tank systems" that are filled by transfers of more than 25 gallons at one time are required to have spill prevention equipment. Please complete the following actions: 1) Repair or empty your spill prevention equipment. If the spill prevention equipment is replaced as part of the repair then the spill prevention equipment must meet the secondary containment requirements of 15A NCAC 2N .0900 and must have an integrity test conducted after installation that is documented on a UST-23A form, Triennial UST Spill Bucket Integrity Testing. Submit a copy of invoices, designs or other documentation of the completed work within 30 days of receipt of this NOV to the inspector at the address provided. In addition, if spill prevention is added, please submit a UST-8 form, Notification for Activities Involving USTs, identifying methods (i.e., catchment basin) used along with a UST-23A form, Triennial UST Spill Bucket Integrity Testing. Comment: Tank #1B-prem: Spill Bucket Failed the most recent test Tank #3-off dsl: Spill Bucket Failed the most recent test Violation 2: 15A NCAC 2N .0301 UPG3; Failure to meet the overfill control requirements of a 'new tank system' as required by federal regulation 40 CFR 280.20(c) (as incorporated by 15A NCAC 2N .0301). Corrective Action(s): All UST systems installed after December 22, 1988 are defined as 'new tank systems.' All "new tank systems" that are filled by transfers of more than 25 gallons at one time are required to have overfill control equipment. Please North Carolina Department of Environmental Quality | Division of Waste Management 217 West Jones Street | 1646 Mail Service Center | Raleigh, North Carolina 27699-1646 919.707.8171 complete one of the following actions: 1) The overfill prevention equipment was inspected however the equipment is not installed at the correct height in the tank or it needs repairing and does not meet the performance standards of 15A NCAC 2N .0301. Provide documentation, on a UST-22A form, Overfill Prevention Equipment Operability Check, of an operability check conducted in accordance with the manufacturer's written guidelines, PEI RP 1200 “Recommended Practice for the Testing and Verification of Spill, Overfill, Leak Detection and Secondary Containment Equipment at UST Facilities” and the instructions on the UST-22A form. Submit a copy of invoices, designs or other documentation, such as a letter signed by the installer or a report from an equipment contractor, of the completed work within 30 days of receipt of this notice to the inspector at the address provided. In addition, if overfill control is added, please submit a UST-8 form Notification for Activities Involving USTs identifying methods (i.e., automatic shut-off device or overfill alarm) used and provide documentation of an operability check on a UST-22A form, Overfill Prevention Equipment Operability Check. Comment: This Violation and Corrective Action Applies to the Overfill Equipment Associated with: Tank #1B-prem: , Tank #reg-: Violation 3: 15A NCAC 2N .0407 MT8; Failure to perform periodic operation and maintenance walkthrough inspections as required by federal regulation 40 CFR 280.36 (as incorporated by 15A NCAC 2N .0407) Corrective Action(s): Periodic operation and maintenance walkthrough inspections must be conducted for the following: 1) Conduct a monthly spill bucket inspection in accordance with PEI RP 900, "Recommended Practices for the Inspection and Maintenance of UST Systems" and document the results on form UST-27, "Monthly Walkthrough Inspections". 2) Conduct a monthly inspection of your leak detection equipment (e.g. ATG console operation and leak detection records) in accordance with PEI RP 900, "Recommended Practices for the Inspection and Maintenance of UST Systems" and document the results on form UST-27, "Monthly Walkthrough Inspections". 3) The periodic operation and maintenance walkthrough inspections were not done in accordance with a national standard. Conduct the periodic inspections in accordance with PEI RP 900, "Recommended Practices for the Inspection and Maintenance of UST Systems" and submit the results on the applicable UST form. Within 30 days of receipt of this notice, please submit the inspection results on one of the following applicable forms: UST-22B, Annual Leak Detection Equipment Operability Check; UST-22C, Annual Sump Visual Inspections; and/or UST-27, Monthly Walkthrough Inspections, to the inspector at the address provided. Comment: Tank #1B-prem: , Tank #1B-prem: , Tank #1B-prem: , Tank #3-off dsl: , Tank #3-off dsl: , Tank #3-off dsl: , Tank #dsl: , Tank #dsl: , Tank #dsl: , Tank #reg-: , Tank #reg-: , Tank #reg-: Violation 4: 15A NCAC 2N .0407 RCD6; Failure to provide records demonstrating operation and maintenance walkthrough inspections have been completed as required by federal regulation 40 CFR 280.36 (as incorporated by 15A NCAC 2N .0407) Corrective Action(s): 1) Provide records demonstrating that the operation and maintenance walkthrough inspections have been completed. Within 14 days of receipt of this notice, please submit the operation and maintenance walkthrough inspection results on one of the following applicable forms: UST-22B, Annual Leak Detection Equipment Operability Check; UST- North Carolina Department of Environmental Quality | Division of Waste Management 217 West Jones Street | 1646 Mail Service Center | Raleigh, North Carolina 27699-1646 919.707.8171 22C, Annual Containment Sump Visual Inspections; and/or UST-27, Monthly Walkthrough Inspections, to the inspector at the address provided. Comment: Tank #1B-prem: , Tank #3-off dsl: , Tank #dsl: , Tank #dsl: , Tank #reg-: , Tank #reg-: Violation 5: 15A NCAC 2N .0603 RLS7; Failure to investigate a suspected release in accordance with federal regulation 40 CFR 280.52 (as incorporated by 15A NCAC 2N .0603) after a failing tightness test of the spill containment, the presence of fuel in spill containment buckets or the degradation of the spill containment equipment to the point where that equipment can not reasonably be expected to perform its intended function was observed. Corrective Action(s): Tank owners or operators must investigate a suspected release as directed below. 1) The spill containment bucket failed a tightness test or the condition of the spill containment bucket has deteriorated such that it may need repairing or replacing. All replaced spill buckets must meet the secondary containment requirements of 15A NCAC 2N .0900. You must complete the actions listed below. Conduct a tightness test (if one has not already been completed) of the existing spill containment bucket(s) integrity (prior to repair/replacement) in accordance with the manufacturer's recommendations* or a code of practice developed by a nationally recognized association. If a testing standard is not available then you must fill the spill containment bucket(s) with clean water to within 1.5 inches of the top of the spill bucket; mark the water level; wait a minimum of 1 hour and re-check the level. A spill containment bucket fails the tightness test if there has been any change in level. Submit a copy of the test results to the inspector at the address provided. If any spill containment bucket fails the tightness test, you must complete all of the following tasks: (a) Conduct a site check around the spill containment bucket for the tanks listed above in accordance with 40 CFR 280.52(b) (as incorporated by 15A NCAC 2N .0603) using the sampling protocol and methodology of the most recent version of the UST Section Guidelines for Site Checks, Tank Closure, and Initial Response and Abatement and submit, within 30 days of receipt of this notice, a site check report or initial abatement report (whichever is applicable) to the inspector at the address provided; AND (b) Repair or replace the spill containment bucket and test the tightness of the spill containment bucket in accordance with the manufacturer's recommendations, a code of practice developed by a nationally recognized association, or the alternate instructions listed above if no standard is available. All replaced spill buckets must meet the secondary containment requirements of 15A NCAC 2N .0900. Within 30 days of receipt of this notice, unless noted differently above, submit a UST-17B, UST Suspected Release 7 Day Notice, with the results and any supporting information for all equipment repairs, equipment replacements, tightness test(s), and site check as required in the above sections to the inspector at the address provided. * Proper disposal of liquids in accordance with State and Federal requirements is required. See the attached document Recommended ways to dispose of small quantities of petroleum and petroleum/water mixtures for some suggested methods. Comment: Tank #1B-prem: , Tank #3-off dsl: Notice of Deficiency: Deficiency 1: NCGS 143-215.94NN-SS OPTR4; Failure to maintain compliance with UST regulations which requires Primary Operator retraining as required by NCGS 143-215.94NN - 143.215.94SS. Corrective Action(s): Please perform the following corrective action: 1) Within 30 days of receipt of this notice, the Primary Operator designated for this facility must go to the following website http://tankschool.nc.gov and take the NC DEQ on-line course for retraining. Retraining as a Primary Operator must be completed and a Primary Operator training certificate achieved within 30 days of receipt of this notice. North Carolina Department of Environmental Quality | Division of Waste Management 217 West Jones Street | 1646 Mail Service Center | Raleigh, North Carolina 27699-1646 919.707.8171 Corrective actions must be completed and reported to the inspector at the address provided within 30 days of receipt of this notice, unless otherwise noted in one of the corrective actions listed above. Assessment of civil penalties may be recommended for violations described in this NOV, as well as, operating permit revocation/denial unless the violations are corrected. If K & S LLC believes that the inspection findings are in error, or if K & S LLC has any questions pertaining to this NOV and/or corrective actions please have it contact me at (910) 796-7409 or john.hooks@ncdenr.gov. Sincerely, John Hooks, Environmental Specialist Division of Waste Management, NC DEQ D Enclosures cc: Michael Phelps w/ Enclosures (electronic) Files (electronic) Appendix B 24-Hour Release and UST Leak Reporting Form (UST-61) UST-61 24-Hour Release and UST Leak Reporting Form. For Releases in NC This form should be completed and submitted to the UST Section’s regional office following a known or suspected release from an underground storage tank (UST) system. This form is required to be submitted within 24 hours of discovery of a known or suspected release (DWM USE ONLY) Incident # ________ Risk (H,I,L,U)_______ Received On ________ Received By ________ Reported by (circle one): Phone, Fax or Report Region _______ Suspected Contamination? (Y/N) ________ Confirmed GW Contamination? (Y/N) ______ Confirmed Soil Contamination ?(Y/N) ______ Samples Taken?(Y/N) ______ Free Product? (Y/N) _____ If Yes, State Greatest Thickness ______________ Facility ID Number ______________ Date Leak Discovered ___________ Comm/Non-Commercial? ________ Reg/Non-regulated? _____________ INCIDENT DESCRIPTION Incident Name: Address: County: City/Town: Zip Code: Regional Office (circle one): Asheville, Mooresville, Fayetteville, Raleigh, Washington, Wilmington, Winston-Salem Latitude (decimal degrees): Longitude (decimal degrees) : Obtained by: Briefly describe suspected or confirmed release: (including but not limited to: nature of release, date of release, amount of release, amount of free product present and recovery efforts, initial responses conducted, impacts to receptors)  GPS  Topographic map  GIS Address matching  Other  Unknown Describe location: HOW RELEASE WAS DISCOVERED (Release Code) (Check one)  Release Detection Equipment or Methods  During UST Closure/Removal  Property Transfer  Visual/Odor  Water in Tank  Water Supply Well Contamination  Groundwater Contamination  Surface Water Contamination  Other (specify) _______________ SOURCE OF CONTAMINATION Source of Release (Check primary source) Cause of Release (Check primary cause) Type of Release (Check one) Product Type Released (Check primary product type released)  Tank  Piping  Dispenser  Submersible Turbine Pump  Delivery Problem  Spill Bucket  Other  Unknown Definitions presented on reverse  Spill  Overfill  Corrosion  Physical/Mechanical Damage  Install Problem  Other  Unknown Definitions presented on reverse  Petroleum  Non-Petroleum  Both Location (Check one)  Facility  Residence  Other  Gasoline/ Diesel/ Kerosene  Heating Oil  Other Petroleum Products  Metals  Other Inorganics  Other Organics  Diesel/Veg. Oil Blend  Vegetable Oil 100%  E10 – E20  E21 – E84  E85 – E99  Ethanol 100%  E01 – E09 Ownership 1. Municipal 2. Military 3. Unknown 4. Private 5. Federal 6. County 7. State Operation Type 1. Public Service 2. Agricultural 3. Residential 4. Education/Relig. 5. Industrial 6. Commercial 7. Mining UST Form 61 (02/19) Page 1 of 2 Y Y Y N 11/4/21 Comm. Reg. 28412 X Google maps X X X X X 00-0-0000034121 Home Race Mart #1 7824 Seven Springs Highway Nakina Columbus confirmed a petroleum release. During site check activites, the soil sample collected at the off-road diesel spill bucket Petroleum Retail Facility 34.134353 -78.668531 X site check IMPACT ON DRINKING WATER SUPPLIES Water Supply Wells Affected? 1. Yes 2. No 3. Unknown Number of Water Supply Wells Affected __________________ Water Supply Wells Contaminated: (Include Users Names, Addresses and Phone Numbers. Attach additional sheet if necessary) 1. 2. 3. UST SYSTEM OWNER UST Owner/Company Point of Contact Address City State Zip Code Telephone Number UST SYSTEM OPERATOR UST Operator/Company Address City State Zip Code Telephone Number LANDOWNER AT LOCATION OF UST INCIDENT Landowner Address City State Zip Code Telephone Number Draw Sketch of Area (showing two major road intersections) or Attach Map Person Reporting Incident Company Telephone Number Title Address Date UST Form 61 (02/19) Page 2 of 2 Definitions of Sources Tank: means the tank that stores the product and is part of the underground storage tank system Piping: means the piping and connectors running from the tank or submersible turbine pump to the dispenser or other end-use equipment (Vent, vapor recovery, or fill lines are excluded.) Dispenser: includes the dispenser and the equipment used to connect the dispenser to the piping (e.g., a release from a suction pump or from components located above the shear valve) Submersible Turbine Pump (STP) Area includes the submersible turbine pump head (typically located in the tank sump), the line leak detector, and the piping that connects the submersible turbine pump to the tank Delivery Problem: identifies releases that occurred during product delivery to the tank. (Typical causes associated with this source are spills and overfills.) Other: serves as the option to use when the release source is known but does not fit into one of the preceding categories (e.g., for releases from vent lines, vapor recovery lines, and fill lines) Unknown: identifies releases for which the source has not been determined Definitions of Causes Spill: use this cause when a spill occurs (e.g., when the delivery hose is disconnected from the tank fill pipe or when the nozzle is removed from the dispenser) Overfill: use when an overfill occurs (e.g., overfills may occur from the fill pipe at the tank or when the nozzle fails to shut off at the dispenser) Physical or Mechanical Damage: use for all types of physical or mechanical damage, except corrosion (e.g., puncture of tank or piping, loose fittings, broken components, and components that have changed dimension) Corrosion: use when a metal tank, piping, or other component has a release due to corrosion (e.g., for steel, corrosion takes the form of rust) Installation Problem: use when the problem is determined to have occurred specifically because the UST system was not installed properly Other: use this option when the cause is known but does not fit into one of the preceding categories (e.g., putting regulated substances into monitoring wells) Unknown: use when the cause has not been determined NC See attached Map Ethan Rogerson, GIT 11/4/2021 704-845-4010 3502 Hayes Road, Monroe, NC 28110 Agent Geological Resources Inc. Sanjeev Sethi 7824 Seven Creeks Highway Nakina 28455 910-642-744 K & S LLC Shivam LLC 7824 Seven Creeks Highway Nakina NC 28455 910-642-7444 7824 Seven Creeks Highway K&S Foodmart LLC Nakina NC 28455 910-642-7444 Appendix C Laboratory Report – Soil Sample 11/03/21 Technical Report for GRI (Geological Resources Inc.) Home Race 1; Nakina, NC SGS Job Number: FA90187 Sampling Date: 10/21/21 Report to: GRI 3502 Hayes Rd Monroe, NC 28110 egr@geologicalresourcesinc.com; carriekennedy@geologicalresourcesinc.com; jjr@geologicalresourcesinc.com; nml@geologicalresourcesinc.com ATTN: Ethan Rogerson Total number of pages in report: Certifications: FL(E83510), LA(03051), KS(E-10327), NC(573), NJ(FL002), NY(12022), SC(96038001) DoD ELAP(ANAB L2229), AZ(AZ0806), CA(2937), TX(T104704404), PA(68-03573), VA(460177), AL, AK, AR, CT, IA, KY, MA, MI. MS, ND, NH, NV, OK, OR, UT, VT, WA, WV This report shall not be reproduced, except in its entirety, without the written approval of SGS. Test results relate only to samples analyzed. SGS North America Inc. • 4405 Vineland Road • Suite C-15 • Orlando, FL 32811 • tel: 407-425-6700 • fax: 407-425-0707 Test results contained within this data package meet the requirements of the National Environmental Laboratory Accreditation Program and/or state specific certification programs as applicable. Client Service contact: Muna Mohammed 407-425-6700 Norm Farmer Technical Director Orlando, FL 11/03/21 e-Hardcopy 2.0 Automated Report 21 SGS is the sole authority for authorizing edits or modifications to this document. Unauthorized modification of this report is strictly prohibited. Review standard terms at: http://www.sgs.com/en/terms-and-conditions The results set forth herein are provided by SGS North America Inc. Please share your ideas about how we can serve you better at: EHS.US.CustomerCare@sgs.com 1 of 21 FA90187 Table of Contents -1- Sections: Section 1: Sample Summary ...................................................................................................3 Section 2: Summary of Hits ....................................................................................................4 Section 3: Sample Results ........................................................................................................5 3.1: FA90187-1: SS-ORDSL-2 ............................................................................................6 3.2: FA90187-2: SS-PREM-2 ..............................................................................................8 Section 4: Misc. Forms ............................................................................................................9 4.1: Chain of Custody ...........................................................................................................10 Section 5: GC Volatiles - QC Data Summaries .....................................................................12 5.1: Method Blank Summary ................................................................................................13 5.2: Blank Spike Summary ...................................................................................................15 5.3: Matrix Spike/Matrix Spike Duplicate Summary ...........................................................17 Section 6: GC/LC Semi-volatiles - QC Data Summaries .....................................................18 6.1: Method Blank Summary ................................................................................................19 6.2: Blank Spike Summary ...................................................................................................20 6.3: Matrix Spike/Matrix Spike Duplicate Summary ...........................................................21 1234562 of 21 FA90187 SGS North America Inc. Sample Summary GRI (Geological Resources Inc.) Job No:FA90187 Home Race 1; Nakina, NC Sample Collected Matrix Client Number Date Time By Received Code Type Sample ID FA90187-1 10/21/21 14:45 JR 10/26/21 SO Soil SS-ORDSL-2 FA90187-2 10/21/21 15:00 JR 10/26/21 SO Soil SS-PREM-2 Soil samples reported on a dry weight basis unless otherwise indicated on result page. 3 of 21 FA901871 Summary of Hits Page 1 of 1 Job Number:FA90187 Account:GRI (Geological Resources Inc.) Project:Home Race 1; Nakina, NC Collected:10/21/21 Lab Sample ID Client Sample ID Result/ Analyte Qual RL MDL Units Method FA90187-1 SS-ORDSL-2 TPH-GRO (C6-C10)176 32 16 mg/kg SW846 8015C TPH (C10-C28)3250 1200 600 mg/kg SW846 8015C FA90187-2 SS-PREM-2 TPH-GRO (C6-C10)8.67 8.1 4.0 mg/kg SW846 8015C 4 of 21 FA901872 SGS North America Inc. Sample Results Report of Analysis Orlando, FL Section 3 5 of 21 FA901873 SGS North America Inc. Report of Analysis Page 1 of 1 Client Sample ID:SS-ORDSL-2 Lab Sample ID:FA90187-1 Date Sampled:10/21/21 Matrix:SO - Soil Date Received:10/26/21 Method:SW846 8015C Percent Solids:83.5 Project:Home Race 1; Nakina, NC File ID DF Analyzed By Prep Date Prep Batch Analytical Batch Run #1 1U70083.D 1 11/01/21 19:19 KB n/a n/a G1U309 Run #2 a 1U70044.D 1 10/31/21 12:52 KB n/a n/a G1U308 Initial Weight Final Volume Methanol Aliquot Run #1 5.49 g 5.0 ml 20.0 ul Run #2 5.49 g 5.0 ml 25.0 ul CAS No.Compound Result RL MDL Units Q TPH-GRO (C6-C10)176 32 16 mg/kg CAS No.Surrogate Recoveries Run# 1 Run# 2 Limits 460-00-4 4-Bromofluorobenzene 150% b 159% b 56-149% 98-08-8 aaa-Trifluorotoluene 105%99%66-132% (a) Confirmation run. (b) Outside control limits. ND = Not detected MDL = Method Detection Limit J = Indicates an estimated value RL = Reporting Limit B = Indicates analyte found in associated method blank E = Indicates value exceeds calibration range N = Indicates presumptive evidence of a compound 6 of 21 FA9018733.1 SGS North America Inc. Report of Analysis Page 1 of 1 Client Sample ID:SS-ORDSL-2 Lab Sample ID:FA90187-1 Date Sampled:10/21/21 Matrix:SO - Soil Date Received:10/26/21 Method:SW846 8015C SW846 3546 Percent Solids:83.5 Project:Home Race 1; Nakina, NC File ID DF Analyzed By Prep Date Prep Batch Analytical Batch Run #1 WW31225.D 200 10/28/21 13:00 KA 10/27/21 09:15 OP88031 GWW1252 Run #2 Initial Weight Final Volume Run #1 20.0 g 1.0 ml Run #2 CAS No.Compound Result RL MDL Units Q TPH (C10-C28)3250 1200 600 mg/kg CAS No.Surrogate Recoveries Run# 1 Run# 2 Limits 84-15-1 o-Terphenyl 0% a 56-122% (a) Outside control limits due to dilution. ND = Not detected MDL = Method Detection Limit J = Indicates an estimated value RL = Reporting Limit B = Indicates analyte found in associated method blank E = Indicates value exceeds calibration range N = Indicates presumptive evidence of a compound 7 of 21 FA9018733.1 SGS North America Inc. Report of Analysis Page 1 of 1 Client Sample ID:SS-PREM-2 Lab Sample ID:FA90187-2 Date Sampled:10/21/21 Matrix:SO - Soil Date Received:10/26/21 Method:SW846 8015C Percent Solids:86.6 Project:Home Race 1; Nakina, NC File ID DF Analyzed By Prep Date Prep Batch Analytical Batch Run #1 1U70045.D 1 10/31/21 13:18 KB n/a n/a G1U308 Run #2 Initial Weight Final Volume Methanol Aliquot Run #1 3.96 g 5.0 ml 100 ul Run #2 CAS No.Compound Result RL MDL Units Q TPH-GRO (C6-C10)8.67 8.1 4.0 mg/kg CAS No.Surrogate Recoveries Run# 1 Run# 2 Limits 460-00-4 4-Bromofluorobenzene 109%56-149% 98-08-8 aaa-Trifluorotoluene 107%66-132% ND = Not detected MDL = Method Detection Limit J = Indicates an estimated value RL = Reporting Limit B = Indicates analyte found in associated method blank E = Indicates value exceeds calibration range N = Indicates presumptive evidence of a compound 8 of 21 FA9018733.2 SGS North America Inc. Misc. Forms Custody Documents and Other Forms Includes the following where applicable: • Chain of Custody Orlando, FL Section 4 9 of 21 FA901874 FA90187: Chain of Custody Page 1 of 2 10 of 21 FA9018744.1 Job Number:FA90187 Client:GRI Date / Time Received:10/26/2021 2:45:00 PM Delivery Method:FX Project:HOME RACE #1 Airbill #'s:923153843474 Cooler Information 1. Custody Seals Present 2. Custody Seals Intact 4. Cooler temp verification 3. Temp criteria achieved 5. Cooler media IR Gun Ice (Bag) Trip Blank Information 1. Trip Blank present / cooler 2. Trip Blank listed on COC 2. Samples preserved properly Sample Information 1. Sample labels present on bottles 5. Sample recvd within HT 4. Condition of sample 3. Sufficient volume/containers recvd for analysis: Intact Comments FROZEN @ 15:38 - 10/26/21 SM001Rev. Date 05/24/17 SGS Sample Receipt Summary Cooler Temps (Raw Measured) °C: Cooler Temps (Corrected) °C: Cooler 1: (2.6); Cooler 1: (2.8); 3. Type Of TB Received W or S N/A 6. Dates/Times/IDs on COC match Sample Label 7. VOCs have headspace 8. Bottles received for unspecified tests 9. Compositing instructions clear 10. Voa Soil Kits/Jars received past 48hrs? 11. % Solids Jar received? Misc. Information 25-Gram 5-GramNumber of Encores:Number of 5035 Field Kits:Number of Lab Filtered Metals: Test Strip Lot #s:pH 0-3 230315 pH 10-12 219813A Other: (Specify) Y or N N/A Y or N Therm ID:IR 1; Therm CF:0.2; # of Coolers:1 Y or N N/A 12. Residual Chlorine Present? Residual Chlorine Test Strip Lot #: Technician:Reviewer:NATHANS Date:Date:10/26/2021 2:45:00 P FA90187: Chain of Custody Page 2 of 2 11 of 21 FA9018744.1 SGS North America Inc. GC Volatiles QC Data Summaries Includes the following where applicable: • Method Blank Summaries • Blank Spike Summaries • Matrix Spike and Duplicate Summaries Orlando, FL Section 5 12 of 21 FA901875 Method Blank Summary Page 1 of 1 Job Number:FA90187 Account:GRINCC GRI (Geological Resources Inc.) Project:Home Race 1; Nakina, NC Sample File ID DF Analyzed By Prep Date Prep Batch Analytical Batch G1U308-MB 1U70042.D 1 10/31/21 KB n/a n/a G1U308 The QC reported here applies to the following samples:Method: SW846 8015C FA90187-2 CAS No.Compound Result RL MDL Units Q TPH-GRO (C6-C10)ND 5.0 2.5 mg/kg CAS No.Surrogate Recoveries Limits 460-00-4 4-Bromofluorobenzene 108%56-149% 98-08-8 aaa-Trifluorotoluene 106%66-132% 13 of 21 FA9018755.1.1 Method Blank Summary Page 1 of 1 Job Number:FA90187 Account:GRINCC GRI (Geological Resources Inc.) Project:Home Race 1; Nakina, NC Sample File ID DF Analyzed By Prep Date Prep Batch Analytical Batch G1U309-MB 1U70069.D 1 11/01/21 KB n/a n/a G1U309 The QC reported here applies to the following samples:Method: SW846 8015C FA90187-1 CAS No.Compound Result RL MDL Units Q TPH-GRO (C6-C10)ND 5.0 2.5 mg/kg CAS No.Surrogate Recoveries Limits 460-00-4 4-Bromofluorobenzene 110%56-149% 98-08-8 aaa-Trifluorotoluene 108%66-132% 14 of 21 FA9018755.1.2 Blank Spike Summary Page 1 of 1 Job Number:FA90187 Account:GRINCC GRI (Geological Resources Inc.) Project:Home Race 1; Nakina, NC Sample File ID DF Analyzed By Prep Date Prep Batch Analytical Batch G1U308-BS 1U70041.D 1 10/31/21 KB n/a n/a G1U308 The QC reported here applies to the following samples:Method: SW846 8015C FA90187-2 Spike BSP BSP CAS No.Compound mg/kg mg/kg %Limits TPH-GRO (C6-C10)20 23.3 117 74-128 CAS No.Surrogate Recoveries BSP Limits 460-00-4 4-Bromofluorobenzene 110%56-149% 98-08-8 aaa-Trifluorotoluene 109%66-132% * = Outside of Control Limits. 15 of 21 FA9018755.2.1 Blank Spike Summary Page 1 of 1 Job Number:FA90187 Account:GRINCC GRI (Geological Resources Inc.) Project:Home Race 1; Nakina, NC Sample File ID DF Analyzed By Prep Date Prep Batch Analytical Batch G1U309-BS 1U70068.D 1 11/01/21 KB n/a n/a G1U309 The QC reported here applies to the following samples:Method: SW846 8015C FA90187-1 Spike BSP BSP CAS No.Compound mg/kg mg/kg %Limits TPH-GRO (C6-C10)20 19.2 96 74-128 CAS No.Surrogate Recoveries BSP Limits 460-00-4 4-Bromofluorobenzene 112%56-149% 98-08-8 aaa-Trifluorotoluene 110%66-132% * = Outside of Control Limits. 16 of 21 FA9018755.2.2 Matrix Spike/Matrix Spike Duplicate Summary Page 1 of 1 Job Number:FA90187 Account:GRINCC GRI (Geological Resources Inc.) Project:Home Race 1; Nakina, NC Sample File ID DF Analyzed By Prep Date Prep Batch Analytical Batch FA90215-1MS 1U70048.D 1 10/31/21 KB n/a n/a G1U308 FA90215-1MSD 1U70049.D 1 10/31/21 KB n/a n/a G1U308 FA90215-1 a 1U70047.D 1 10/31/21 KB n/a n/a G1U308 The QC reported here applies to the following samples:Method: SW846 8015C FA90187-2 FA90215-1 Spike MS MS Spike MSD MSD Limits CAS No.Compound mg/kg Q mg/kg mg/kg %mg/kg mg/kg %RPD Rec/RPD TPH-GRO (C6-C10)ND 19.4 19.0 98 19.4 21.3 110 11 74-128/17 CAS No.Surrogate Recoveries MS MSD FA90215-1 Limits 460-00-4 4-Bromofluorobenzene 102%103%103%56-149% 98-08-8 aaa-Trifluorotoluene 102%106%103%66-132% (a) Pre-weighed vials were altered in the field; sample weights are estimated. * = Outside of Control Limits. 17 of 21 FA9018755.3.1 SGS North America Inc. GC/LC Semi-volatiles QC Data Summaries Includes the following where applicable: • Method Blank Summaries • Blank Spike Summaries • Matrix Spike and Duplicate Summaries Orlando, FL Section 6 18 of 21 FA901876 Method Blank Summary Page 1 of 1 Job Number:FA90187 Account:GRINCC GRI (Geological Resources Inc.) Project:Home Race 1; Nakina, NC Sample File ID DF Analyzed By Prep Date Prep Batch Analytical Batch OP88031-MB WW31195.D 1 10/27/21 KA 10/27/21 OP88031 GWW1251 The QC reported here applies to the following samples:Method: SW846 8015C FA90187-1 CAS No.Compound Result RL MDL Units Q TPH (C10-C28)ND 5.0 2.5 mg/kg CAS No.Surrogate Recoveries Limits 84-15-1 o-Terphenyl 67%56-122% 19 of 21 FA9018766.1.1 Blank Spike Summary Page 1 of 1 Job Number:FA90187 Account:GRINCC GRI (Geological Resources Inc.) Project:Home Race 1; Nakina, NC Sample File ID DF Analyzed By Prep Date Prep Batch Analytical Batch OP88031-BS WW31196.D 1 10/27/21 KA 10/27/21 OP88031 GWW1251 The QC reported here applies to the following samples:Method: SW846 8015C FA90187-1 Spike BSP BSP CAS No.Compound mg/kg mg/kg %Limits TPH (C10-C28)50 42.3 85 62-116 CAS No.Surrogate Recoveries BSP Limits 84-15-1 o-Terphenyl 82%56-122% * = Outside of Control Limits. 20 of 21 FA9018766.2.1 Matrix Spike/Matrix Spike Duplicate Summary Page 1 of 1 Job Number:FA90187 Account:GRINCC GRI (Geological Resources Inc.) Project:Home Race 1; Nakina, NC Sample File ID DF Analyzed By Prep Date Prep Batch Analytical Batch OP88031-MS WW31199.D 5 10/27/21 KA 10/27/21 OP88031 GWW1251 OP88031-MSD WW31200.D 5 10/27/21 KA 10/27/21 OP88031 GWW1251 FA90171-1 a WW31198.D 5 10/27/21 KA 10/27/21 OP88031 GWW1251 The QC reported here applies to the following samples:Method: SW846 8015C FA90187-1 FA90171-1 Spike MS MS Spike MSD MSD Limits CAS No.Compound mg/kg Q mg/kg mg/kg %mg/kg mg/kg %RPD Rec/RPD TPH (C10-C28)20.3 J 53.3 52.2 60*53.5 53.6 62 3 62-116/35 CAS No.Surrogate Recoveries MS MSD FA90171-1 Limits 84-15-1 o-Terphenyl 72%77%59%56-122% (a) Dilution required due to matrix interference; extract was viscous. * = Outside of Control Limits. 21 of 21 FA9018766.3.1