16029_Southern States_Phase I_20120725

Report Date: July 25, 2012
Report Expires: July 17, 2013
MAA Job #: 000R2377.00
PREPARED BY:

Mid-Atlantic Associates, Inc.
409 Rogers View Court
Raleigh, North Carolina 27610
919.250.9918
919.250.9950 (fax)
www.MAAonline.com
PREPARED FOR (USER):

Mr. Hanglae Cho
Sirius Metal Recycling, Inc.
560 Oak Crest Drive
Chapel Hill, North Carolina 27516

PHASE I
ENVIRONMENTAL SITE
ASSESSMENT REPORT
Former Southern States
6601 Ward Boulevard (Highway 301)
Wilson, North Carolina
Mid-Atlantic Associates, Inc. PESA Report – Former Southern States
Project Number: 000R2377.00 Wilson, North Carolina
800.486.7568 – www.MAAonline.com

TABLE OF CONTENTS

1.0 Executive Summary 1

2.0 Introduction 3
2.1 Purpose..............................................................................................................................3
2.2 Scope of Services..............................................................................................................3
2.3 Significant Assumptions.....................................................................................................3
2.4 Limitations and Exceptions ................................................................................................4
2.5 Special Terms and Conditions...........................................................................................4
2.6 User Reliance.....................................................................................................................4
3.0 Site Description 4
3.1 Site Location and Legal Description ..................................................................................4
3.2 Site and Vicinity General Characteristics...........................................................................5
3.3 Current Use of the Property...............................................................................................5
3.4 Description of Structures, Roads, Utilities & Other Site Improvements.............................5
3.5 Current Use of the Adjoining Properties ............................................................................5
4.0 User Provided Information 5
4.1 Title Records......................................................................................................................6
4.2 Environmental Liens or Activity and Use Limitations.........................................................6
4.3 Specialized Knowledge......................................................................................................6
4.4 Commonly Known or Reasonably Ascertainable Information ...........................................6
4.5 Valuation Reduction for Environmental Issues..................................................................6
4.6 Owner, Property Manager, and Occupant Information......................................................6
4.7 Reason for Performing Phase I ESA .................................................................................6
5.0 Records Review 7
5.1 Environmental Regulatory Records...................................................................................7
5.1.1 Subject Site Environmental Regulatory Records.....................................................7
5.1.2 Adjacent Site(s) Environmental Regulatory Records ..............................................7
5.2 Additional Environmental Record Sources ........................................................................8
5.2.1 Subject Site Environmental Records .......................................................................8
5.2.2 Subject Site Environmental Records – Underground Release Incident..................9
5.3 Physical Setting Sources .................................................................................................10
5.3.1 Geologic Setting......................................................................................................10
5.3.2 Surface Drainage....................................................................................................11
5.3.3 Groundwater ...........................................................................................................11
5.4 Historical Use Information on the Subject Site ................................................................11
5.4.1 Aerial Photographs .................................................................................................11
5.4.2 Topographic Maps ..................................................................................................12
5.4.3 Sanborn Maps.........................................................................................................12
5.4.4 City Directions.........................................................................................................12
5.4.5 Tax and Deed Information ......................................................................................12
5.5 Historical Use Information on Adjoining Properties ........................................................ 13
5.5.1 Aerial Photographs ................................................................................................ 13
5.5.2 Topographic Maps ................................................................................................. 14

Mid-Atlantic Associates, Inc. PESA Report – Former Southern States
Project Number: 000R2377.00 Wilson, North Carolina
800.486.7568 – www.MAAonline.com

TABLE OF CONTENTS – Page 2

5.5.3 Sanborn Maps........................................................................................................ 14
5.5.4 City Directories....................................................................................................... 15
6.0 Site Reconnaissance 15
6.1 Methodology and Limiting Conditions............................................................................. 15
6.2 General Site Setting, Structures and Utilities.................................................................. 15
6.3 Exterior Observations ......................................................................................................16
6.3.1 Pits, Ponds or Lagoons...........................................................................................16
6.3.2 Stained Soil or Pavement/Stressed Vegetation......................................................16
6.3.3 Solid Waste.............................................................................................................16
6.3.4 Wastewater.............................................................................................................16
6.3.5 Wells .......................................................................................................................16
6.3.6 Septic Systems .......................................................................................................16
6.3.7 Storage Tanks/Vessels...........................................................................................17
6.3.8 PCBs.......................................................................................................................17
6.3.9 Surrounding Land Use............................................................................................17
6.3.10 Other Evidence of Environmental Impacts ...........................................................17
6.4 Interior Observations........................................................................................................18
6.4.1 Heating and Cooling Systems.................................................................................18
6.4.2 Staining and Chemical Storage/Use.......................................................................18
6.4.3 Drains and Sumps ..................................................................................................18
6.4.4 Asbestos Containing Materials and Lead-Based Paint ..........................................18
6.4.5 Other Evidence of Environmental Impacts .............................................................18
7.0 Interviews 18
7.1 Interview with Owner........................................................................................................18
7.2 Interview with Site Manager.............................................................................................19
7.3 Interview with Occupants.................................................................................................19
7.4 Interviews with Local Government Officials.....................................................................19
7.5 Interview with Others .......................................................................................................19
8.0 Findings 19

9.0 Opinion 20
9.1 Subject Site Environmental Concerns and Opinions.......................................................20
9.2 Adjacent Site(s) Environmental Concerns and Opinions.................................................21
9.3 Surrounding Site(s) Environmental Concerns and Opinions...........................................21
10.0 Conclusions and Recommendations 21
10.1 Conclusions......................................................................................................................21
10.2 Recommendations...........................................................................................................22
11.0 Deviations 22

Mid-Atlantic Associates, Inc. PESA Report – Former Southern States
Project Number: 000R2377.00 Wilson, North Carolina
800.486.7568 – www.MAAonline.com

TABLE OF CONTENTS – Page 3

12.0 Additional Services 22

13.0 References 23

14.0 Signatures of Environmental Professional(s) 23

15.0 Qualifications of Environmental Professionals 24

16.0 Appendices 24

Appendix 16.1 Topographic Site Map
Appendix 16.2 Site Map
Appendix 16.3 Site Photographs
Appendix 16.4 Historical Research Documentation
Appendix 16.5 Regulatory Records Documentation
Appendix 16.6 Subject Site Environmental Records – Aboveground Release Incident
Appendix 16.7 Subject Site Environmental Records – Underground Release Incident
Appendix 16.8 User-Provided Information
Appendix 16.9 Special Contractual Conditions
Appendix 16.10 Qualifications of the Environmental Professional(s)

Mid-Atlantic Associates, Inc. 1 PESA Report – Former Southern States
Project Number: 000R2377.00 Wilson, North Carolina
800.486.7568 – www.MAAonline.com

FORMER SOUTHERN STATES
6601 WARD BOULEVARD (US HIGHWAY 301)
WILSON, NORTH CAROLINA

1.0 Executive Summary

Mid-Atlantic Associates, Inc. (Mid-Atlantic) has performed a Phase I Environmental Site
Assessment (PESA) in conformance with the scope and limitations of the American Society for
Testing and Materials (ASTM) Practice E 1527-05 at the property located at 6601 Ward Boulevard
(US Highway 301) in Wilson, Wilson County, North Carolina (the “subject site”). Site maps showing
the location and layout of the subject site are provided in Appendix 16.1 and Appendix 16.2.

The subject site consists of one rectangular-shaped parcel of land totaling approximately 2.07
acres and recorded as Parcel ID Number 3721-34-9130 by the Wilson County Tax Administrator’s
Office. The site is improved with one 11,250 square foot commercial/industrial facility and three
wood-framed storage buildings, several of which were historically used to store raw materials
(potash, nitrates, etc.) associated with the former on-site pesticide and fertilizer manufacturing
activities. Additional site improvements include a sub-grade molasses pit, two truck weigh scales,
chain-link fencing, asphalt-paved parking areas and concrete sidewalks, loading docks and
secondary containment areas. Based on our review of historical documents and previous
environmental reports, it also appears the historical site operations utilized numerous bulk storage
aboveground storage tanks (ASTs), underground storage tanks (USTs) and a loading rack and
dispenser pumps.

Based on interview information and historical documents, the subject site appears to have been
developed with the present-day facilities since approximately 1956. The site reportedly operated as
a manufacturing and distribution facility for pesticides and fertilizers (FCX, Inc. and Southern States
Cooperative, Inc.) from the time of its development until approximately 2006. During this time, the
site also appears to have been used for the bulk storage of petroleum and associated on-site
fueling activities (prior to the mid-1990’s). The subject site has been non-operational since
Southern States vacated the property in approximately 2006.

Mid-Atlantic has performed this PESA in general conformance with the scope and limitations of
ASTM Practice E 1527-05 and 40 CFR Part 312. Any exceptions to, or deletions from, these
practices are described in Section 2.4 and Section 11.0 of this report. This assessment has
revealed the following recognized environmental conditions (RECs) in connection with the
subject property:

• The historical on-site manufacturing, storage and distribution of pesticides and fertilizers,
including the storage of these materials in ASTs;
• The historical use of the subject site as a bulk petroleum storage and distribution facility,
including the storage of petroleum in ASTs and the documented release(s) from these
activities;
• The documented release from a 550-gallon heating oil UST on the northeast portion of
the site;
• The former operation of three petroleum USTs at unknown locations on the subject site;
• The potential operation of a service station to the north and topographically upgradient of
the subject site, across Ward Boulevard (US Highway 301); and
Mid-Atlantic Associates, Inc. 2 PESA Report – Former Southern States
Project Number: 000R2377.00 Wilson, North Carolina
800.486.7568 – www.MAAonline.com

• The historical industrial operations, chemical mixing activities and use of bulk chemical
ASTs on the north adjacent site, across Ward Boulevard (US Highway 301).

The subject site historically utilized numerous ASTs for the bulk storage of various pesticides,
fertilizers and petroleum products. In addition, soil and groundwater contamination have been
documented at the site as a result of released petroleum from the former on-site ASTs and 550-
gallon heating oil UST system (Incident No. 21616 and Incident No. 5313, respectively). Previous
site assessment and remediation activities have been conducted in response to these releases,
specifically in the areas surrounding the truck weigh scales on the south and northwest portions of
the site. These activities included the excavation of petroleum-impacted soils and remediation of
groundwater through monitored natural attenuation, which appears to have remediated soil and
groundwater beneath these portions of the site to beneath applicable regulatory action levels.
Therefore, no additional assessment and/or remedial activities appear to be necessary at the site
to address the previous on-site petroleum releases.

The potential environmental impacts associated with the historical storage and manufacturing of
pesticides and fertilizers at the site do not appear to have been evaluated at this time. Therefore,
soil and/or groundwater beneath the site may have been impacted as a result of these industrial
activities. Based on our knowledge of the historical site operations, the remaining on-site areas of
concern appear to be primarily associated with the former bulk pesticide and fertilizer ASTs; the
historical railcar loading/unloading areas; and the unidentified locations of several former petroleum
USTs, which were reportedly removed from the site in 1989. In addition to these on-site areas of
concern, it also appears that historical off-site activities may potentially have resulted in an adverse
environmental impact to groundwater beneath the subject site. These off-site activities include the
potential former operation of a service station to the north and topographically upgradient of the
subject site, in addition to the former chemical mixing operations and bulk ASTs previously utilized
on the northwest adjacent property, across Ward Boulevard (US Highway 301).

Based on the results of this assessment, Mid-Atlantic recommends additional Phase II activities at
the site to address the aforementioned RECs. It is Mid-Atlantic’s understanding that the results of
this assessment will be used to prepare and submit an application to the North Carolina
Brownfields Program. Therefore, assuming that eligibility will be granted for the site, future
assessment and/or remedial activities should be coordinated through the North Carolina
Brownfields Program. Mid-Atlantic can assist you with these activities at your request.

Mid-Atlantic Associates, Inc. 3 PESA Report – Former Southern States
Project Number: 000R2377.00 Wilson, North Carolina
800.486.7568 – www.MAAonline.com

2.0 INTRODUCTION
2.1 Purpose

The purpose of this PESA was to identify RECs that are indicative of an existing release, past
release, or material threat of a release at the subject site. This PESA was performed to satisfy
one of the requirements to qualify for the innocent landowner, bona fide prospective purchaser or
contiguous property owner defense to the Comprehensive Environmental Response,
Compensation, and Liability Act (CERCLA), and as amended by the Small Business Liability Relief
and Brownfields Redevelopment Act: that is, the practices that constitute “all appropriate inquiries
into the previous ownership and uses of the property consistent with good commercial or
customary practice” as defined in 40 CFR 312. The PESA was conducted in substantial
compliance with ASTM Designation: E 1527-05 – Standard Practice for Environmental Site
Assessments: Phase I Environmental Site Assessment Process.

2.2 Scope of Services

This PESA was conducted in accordance with ASTM E 1527-05 and 40 CFR Part 312. This was
done by gathering required information that was publicly available within reasonable time and cost
constraints and which could be practically reviewed. This report will be considered valid until a
period of one year following the date of our site reconnaissance. Our scope of services included
the following:

• Records Review – Obtaining and reviewing publicly available records (of both current
and historical significance) in order to help identify “recognized environmental
conditions” in connection with the subject site. Those specific records reviewed,
including those records which were sought and were not readily available or reasonably
ascertainable, are identified in the report.
• Site and Surrounding Properties Reconnaissance – Conducting a site and
surrounding property reconnaissance, the objective of which was to obtain information
indicating the likelihood of the existence of “recognized environmental conditions” in
connection with the subject site, as defined in ASTM E-1527-05.
• Interviews – Conducting interviews with persons associated with the subject site and
with appropriate local government officials in order to identify “recognized environmental
conditions” in connection with the subject site. The specific parties interviewed and the
nature and scope of the interviews are described in the report.
• Report – Summarizing the results of our investigation into this report.

2.3 Significant Assumptions

Mid-Atlantic assumes that information provided by the User of the PESA report and those
interviewed in conjunction with the PESA is true and accurate to the best of their knowledge.
No other significant assumptions were used during the performance of this PESA.

Mid-Atlantic Associates, Inc. 4 PESA Report – Former Southern States
Project Number: 000R2377.00 Wilson, North Carolina
800.486.7568 – www.MAAonline.com

2.4 Limitations and Exceptions

As contracted, the scope of work of this PESA did not include a detailed review of agency files
on specific, environmentally-related incidents (unless mentioned in the report) which may have
occurred near the subject site. It also did not include other issues that may be addressed,
depending on site-specific circumstances, during commercial real estate transactions. These
include, but are not limited to, asbestos, lead-based paint, radon, lead in drinking water,
wetlands, cultural or natural resources, industrial hygiene, health and safety, ecological
resources, endangered species, indoor air quality, biological agents, mold, etc.

Our professional services have been performed using the degree of care and skill ordinarily
exercised, under similar conditions, by reputable environmental consultants practicing in this or
similar localities. No other warranty, expressed or implied, is made as to the professional
information included in this report. Although this study has been a reasonably-thorough attempt
to identify conditions that are indicative of releases and threatened releases of hazardous
substances, as well as pollutants, contaminants, petroleum and petroleum products and
controlled substances on and/or off-site, there is always the possibility that potential sources of
contamination have escaped detection due to the limitations of this study, the availability of
historical records, the inaccuracy of governmental records and/or the presence of undetected
and unreported environmental accidents. Mid-Atlantic reserves the right to alter our findings
based on our review of any information obtained and reviewed after the date of this report.

2.5 Special Terms and Conditions

This PESA was conducted in accordance with the terms and conditions of Mid-Atlantic’s
contract with the client.

2.6 User Reliance

The User may rely on the contents of this PESA subject to the limitations placed on the scope,
nature and type of Mid-Atlantic’s services as stated in the PESA and subject to those Terms and
Conditions as stated in Mid-Atlantic’s contract with the client. The User and any additional
parties specifically granted reliance, are the only parties to whom Mid-Atlantic grants the right to
rely upon the PESA. No other third party may rely on the PESA unless the express written
consent of Mid-Atlantic is first obtained.

3.0 Site Description
3.1 Site Location and Legal Description

The subject site is located at 6601 Ward Boulevard (US Highway 301) in Wilson, Wilson County,
North Carolina (Drawing 1.1). The subject site consists of one rectangular-shaped parcel of land
totaling approximately 2.07 acres and recorded as Parcel ID Number 3721-34-9130 by the Wilson
County Tax Administrator’s Office.

Mid-Atlantic Associates, Inc. 5 PESA Report – Former Southern States
Project Number: 000R2377.00 Wilson, North Carolina
800.486.7568 – www.MAAonline.com

3.2 Site and Vicinity General Characteristics

The subject site is located in the southeast portion of Wilson, North Carolina in a generally
commercial/industrial setting. The parcel is zoned I-2 (Industrial II - Heavy) by the City of Wilson
Planning and Development Department.

3.3 Current Use of the Property

At the time of the site inspection, the subject site was vacant and non-operational. The most recent
use of the site includes operation of the former Southern States facility.

3.4 Description of Structures, Roads, Utilities & Other Site Improvements

The site is improved with one 11,250 square foot commercial/industrial facility, which historically
operated as an office, showroom and storage warehouse (feed, seed, etc.) for FCX and Southern
States. The main facility is constructed of brick/concrete block exterior walls with a concrete slab on
grade foundation. The site is also improved with three wood-framed storage buildings, several of
which were previously used to store raw materials for use in the pesticide/fertilizer manufacturing
process (potash, nitrates, etc). Additional site improvements include a sub-grade molasses pit, two
truck weigh scales, chain-link fencing, asphalt-paved parking areas and concrete secondary
containment areas, loading docks and sidewalks.

Vehicular access is provided to the site from the north by Ward Boulevard (US Highway 301) and
from the west by Cargill Avenue. The Norfolk-Southern Railroad runs along the eastern property
boundary of the subject site, and a rail spur is located immediately adjacent to the site and was
historically used for railcar loading/unloading activities by FCX. The subject site and its
surrounding properties are provided with municipal water and sewer services by the City of
Wilson Public Services Department.

3.5 Current Use of the Adjoining Properties

The subject site is bounded to the northwest, across Ward Boulevard, by several vacant and
dilapidated commercial/industrial structures; to the northeast, across the Norfolk-Southern
Railroad, by a vacant commercial/industrial warehouse facility; to the southwest, across Cargill
Avenue, by Rogers Behavioral Health Service; to the south, across Cargill Avenue, by Eastern
Carolina Propane Gas; and to the southeast by Ihrie Supply Company.

4.0 User Provided Information

Pursuant to ASTM E 1527-05, Mid-Atlantic requested the following site information from the
User. The contact for this project was Mr. Hanglae Cho, president of Sirius Metal Recycling, Inc.
(prospective buyer). A copy of the User Questionnaire completed by Mr. Cho is included in
Appendix 16.8 and User-provided information is summarized in the following sections.

Mid-Atlantic Associates, Inc. 6 PESA Report – Former Southern States
Project Number: 000R2377.00 Wilson, North Carolina
800.486.7568 – www.MAAonline.com

4.1 Title Records

No Title Records were provided to Mid-Atlantic by the project contact. Refer to Section 5.4.5 for
a discussion of deed research performed by Mid-Atlantic personnel.

4.2 Environmental Liens or Activity and Use Limitations

No information regarding knowledge of environmental liens or activity and use limitations for the
subject site was provided to Mid-Atlantic by the User. The project contact was not aware of
environmental liens associated with the subject site, nor did he have knowledge of activity and
use limitations regarding the subject site.

4.3 Specialized Knowledge

Mid-Atlantic was not provided with specialized knowledge regarding the subject site by the
project contact.

4.4 Commonly Known or Reasonably Ascertainable Information

The project contact indicated in the User questionnaire that past uses of the subject site include
the operation of an agricultural sales facility (former Southern States). No additional commonly
known or reasonably ascertainable information was provided to Mid-Atlantic by the project
contact.

4.5 Valuation Reduction for Environmental Issues

The project contact indicated in the User questionnaire that the potential purchase price for the
property does not reasonably reflect the fair market value of the property. However, the user
gave no indication as to whether this price was a reflection of known or suspected
environmental contamination at the site.

4.6 Owner, Property Manager, and Occupant Information

The current property owner of the subject site is listed as Southern States Cooperative, in care
of the Tax Department. Mid-Atlantic was granted access to the site by Mr. Johnson Bissette,
real estate broker with First Wilson Properties. The site is currently vacant and unoccupied.

4.7 Reason for Performing Phase I ESA

Mid-Atlantic understands that the findings of this PESA will be used to evaluate the subject site with
respect to a pending property transaction and completion of an application to the North Carolina
Brownfields Program. The purpose of a PESA is to identify existing or potential RECs (as defined
by ASTM Standard E-1527-05) in connection with the subject site. This PESA was also performed
to permit a User to satisfy one of the requirements to qualify for the innocent landowner, contiguous
property owner, or bonafide prospective purchaser limitations within the scope of Comprehensive
Environmental Response, Compensation, and Liability Act (CERCLA) (42 U.S.C 9601) liability.

Mid-Atlantic Associates, Inc. 7 PESA Report – Former Southern States
Project Number: 000R2377.00 Wilson, North Carolina
800.486.7568 – www.MAAonline.com

5.0 Records Review
5.1 Environmental Regulatory Records

Mid-Atlantic contracted EDR to conduct a regulatory database search in accordance with ASTM
E 1527-05 standards. The purpose of the search is to identify certain properties and facilities in
the vicinity of the subject site (including the subject site, as applicable) which are regulated by
the United States Environmental Protection Agency (EPA) and various state and local
environmental regulatory agencies. Detailed information pertaining to each database
researched is presented in the EDR report, a copy of which is attached as Appendix 16.5.

5.1.1 Subject Site Environmental Regulatory Records

Based upon our review of the EDR report, the subject site was identified in the Incident
Management Database (IMD) and Leaking Aboveground Storage Tank (LAST) Database.
Based on information provided in these databases, petroleum-impacted soils were encountered
at the site as a result of an aboveground release. The release was discovered in November
1998 and reportedly impacted groundwater beneath the site (Incident No. 21616). Following
approval of a Corrective Action Plan (CAP) and completion of quarterly groundwater monitoring
activities at the site, the incident files were closed out in both the IMD and LAST Database.

In addition to the above-referenced release, the subject site was also identified in the UST,
Leaking Underground Storage Tank (LUST) and LUST Trust Fund Databases. Information
provided in these databases indicates the site historically operated four petroleum USTs, which
are described as follows:

• One 550-gallon petroleum UST installed in 1962 and removed in 1989;
• One 550-gallon fuel oil UST installed in 1964 and removed in 1989;
• One 550-gallon kerosene UST installed in 1962 and removed in 1989; and
• One 3,000-gallon petroleum UST installed in 1976 and removed in 1989;

According to the LUST Database, petroleum-impacted soils were encountered during removal
of the above-referenced 550-gallon fuel oil UST (Incident No. 5313). The release reportedly did
not impact groundwater beneath the site and the incident files have been closed out in the
LUST Database. No additional releases were reported in connection with the 3,000-gallon
petroleum (non-specified), 550-gallon petroleum (non-specified) and 550-gallon kerosene USTs.
Additional file review information regarding the previous on-site release incidents is discussed in
Sections 5.2.1 and 5.2.2 of this report.

5.1.2 Adjacent and Surrounding Site(s) Environmental Regulatory Records

The property adjacent to the south of the subject site (Ihrie Supply Company, Inc.) was
identified in the UST Database. Based on information provided in this database, the south
adjacent site historically operated one 10,000-gallon gasoline UST, which was removed from
the site in 1991. The adjacent site was not identified in the IMD or LUST Database and no
indications of a release were encountered during Mid-Atlantic’s review of regulatory databases/
lists. Therefore, the historical operation of a UST on the south adjacent site is not considered to
be a REC.

Mid-Atlantic Associates, Inc. 8 PESA Report – Former Southern States
Project Number: 000R2377.00 Wilson, North Carolina
800.486.7568 – www.MAAonline.com

The EDR Report identified several additional off-site properties in regulatory databases/lists
within a one-mile radius of the subject site. However, the off-site properties identified in the EDR
Report are not anticipated to pose an environmental threat to the subject site based on such
factors as distance from the subject site, current regulatory status, and estimated groundwater
flow direction. In addition, none of the sites listed in the EDR Orphan Summary were identified
within one mile of the subject site.

5.2 Additional Environmental Record Sources

5.2.1 Subject Site Environmental Records – Aboveground Release Incident

Mid-Atlantic reviewed the incident files associated with the documented aboveground release at
the subject site (Incident No. 21616). The file review was conducted at the North Carolina
Department of Environment and Natural Resources (NCDENR) State Records Center (SRC)
and the following documents were available for review:

• Soil Excavation Report, Southern States Cooperative prepared by Duncklee & Dunham,
P.C. and dated November 23, 1998;
• Comprehensive Site Assessment Report, Southern States Cooperative prepared by
Duncklee & Dunham, P.C. and dated July 28, 2000;
• Corrective Action Plan, Southern States Cooperative prepared by Duncklee & Dunham,
P.C. and dated October 30, 2000;
• Groundwater Monitoring Report, Southern States Cooperative prepared by Duncklee &
Dunham, P.C. and dated November 29, 2001 (most recent monitoring report);
• Approval – Site Closure Request prepared by the NCDENR and issued to Southern
States Cooperative on December 17, 2001; and
• Monitoring Well Abandonment Record, Southern States Cooperative prepared by
Duncklee & Dunham, P.C. and dated February 8, 2002.

No other significant prior environmental investigative reports for the aboveground release at the
subject site were available for review. Copies of the pertinent portions of the above-referenced
reports are provided in Appendix 16.6.

Based on the information obtained during the file review, the southern portion of the subject site
was historically used for the storage and distribution of petroleum, which included the operation
of several bulk ASTs, dispenser pumps and a loading rack (Note: several additional ASTs were
also utilized on this portion of the site for the storage of liquid fertilizer). While digging footers to
support the installation of a truck weigh scale, petroleum-impacted soils were encountered on
the southern portion of the site, adjacent to the petroleum AST containment area. The release
was reported to the NCDENR on September 10, 1998 and a soil assessment was subsequently
conducted to determine the degree and extent of impacted soils. The results of the initial soil
assessment indicated that several targeted areas exhibited total petroleum hydrocarbon,
gasoline and diesel range organics (TPH-GRO/DRO) concentrations exceeding their respective
regulatory action levels. As a result, the petroleum-impacted soils were excavated and hauled
off-site for proper disposal. In total, approximately 1,364 tons of petroleum-impacted soils were
excavated from the vicinity of the former on-site loading rack and dispenser pump area.

Upon completion of excavation activities, confirmatory soil samples were collected from the
sidewalls and base of the excavation. The subsequent laboratory analytical results indicated
that the lateral extent of soil contamination had been reached; however, the samples collected
Mid-Atlantic Associates, Inc. 9 PESA Report – Former Southern States
Project Number: 000R2377.00 Wilson, North Carolina
800.486.7568 – www.MAAonline.com

from the southern base of the excavation indicated that the vertical extent of contaminated soil
had not been defined prior to encountering groundwater. Based on the low levels of TPH-GRO/
DRO detected at the base of the excavation and the availability of municipal water to the area,
Southern States requested that the NCDENR grant satisfactory site closure; however, NCDENR
requested additional assessment activities at the site. In response to this request, monitoring
well MW-1 was installed immediately adjacent to the western edge of the excavation area.
During well installation activities, one soil sample was collected from the boring for monitoring
well MW-1 at a depth just above the water table and no target compounds were detected in this
sample at concentrations exceeding the laboratory method detection limit (MDL) and/or the Soil-
to-Groundwater Maximum Soil Contaminant Concentrations (MSCCs). Upon completion of well
installation activities, one groundwater sample was collected from well MW-1 and the laboratory
analytical results indicated that benzene was present in the sample at a concentrations ranging
from 4 to 7 micrograms per liter (ug/L), exceeding the North Carolina Groundwater Quality
Standard of 1 ug/L for benzene. Methyl-tert-butyl-ether (MTBE) and xylenes were also detected
in the groundwater sample collected from monitoring well MW-1; however, the concentrations
were beneath their respective NCGQS.

Based on groundwater analytical results from the additional assessment activities, the NCDENR
requested the performance of a Comprehensive Site Assessment (CSA), which included the
advancement of two soil borings (MW-5 and SB-062900), four additional shallow monitoring
wells (MW-2 through MW-5) and one intermediate Type III well (MW-1d). Laboratory analytical
results from the CSA sampling activities indicated that the groundwater samples collected from
shallow monitoring wells MW-1 and MW-4 exhibited benzene at concentrations exceeding the
NCGQS. No additional target compounds were detected in the groundwater samples at
concentrations exceeding the NCGQS. In addition, concentrations of TPH-GRO/DRO were not
detected at or above the laboratory MDL for the soil samples collected during the CSA activities.

In addition to the sampling activities discussed above, a receptor survey was also conducted for
the CSA. The results of the survey indicated that the subject site and its surrounding properties
are served by the City of Wilson public waster supply. Based on the results of the receptor
survey and groundwater analytical results, a Corrective Action Plan (CAP) was developed for
the site, which identified the remediation of groundwater beneath the site through monitored
natural attenuation. Based on the results of the initial soil excavation and subsequent sampling
activities, it appeared that the accessible petroleum contaminated soils had been removed from
this portion of the site. Therefore, no additional soil assessment or remediation activities were
deemed necessary.

In January 2001, the NCDENR approved the CAP for monitored natural attenuation at the site
and directed Southern States to conduct quarterly groundwater monitoring activities. Following
completion of the fourth quarterly monitoring event, which indicated that target compounds were
no longer present at concentrations exceeding the NCGQS, the NCDENR issued a Notice of No
Further Action (NFA) for the aboveground release incident (Incident No. 21616). Upon closure
of the incident files, the on-site monitoring wells were abandoned.

5.2.2 Subject Site Environmental Records – Underground Release Incident

Mid-Atlantic conducted a file review at the NCDENR Raleigh Regional Office (RRO) to obtain
additional information associated with the previous underground release incident at the subject
site (Incident No. 5313). The following documents were available for review:

Mid-Atlantic Associates, Inc. 10 PESA Report – Former Southern States
Project Number: 000R2377.00 Wilson, North Carolina
800.486.7568 – www.MAAonline.com

• Underground Storage Tank Closure Soil Assessment Report, Southern States
Cooperative prepared by Aquaterra, Inc. and dated October 12, 1989;
• Draft Comprehensive Site Assessment and Corrective Action Report, Southern States
Cooperative prepared by Aquaterra, Inc. and dated April 6, 1990;
• Soil Remediation Report, Southern States Cooperative prepared by Aquaterra, Inc. and
dated January 17, 1991; and
• Memorandum – Incident 5313 Closeout of Southern States prepared by the NCDENR
and dated March 13, 1991.

No other significant prior environmental investigative reports were available for the underground
release at the subject site. Copies of the pertinent portions of the above-referenced reports are
provided in Appendix 16.7.

In September 1989, one 550-gallon fuel oil UST was removed from the northwest portion of the
site, adjacent to the entrance of the main office/showroom facility (Drawing 1.2). Upon removal,
petroleum-impacted soils were encountered in the excavation and, as a result, several soil
samples were collected and the excavation was subsequently backfilled. Based on the results of
the initial UST closure soil sampling activities, a CAP was developed for the site. The CAP was
approved by the NCDENR in October 1990 and included excavation and removal of the
petroleum-impacted soils. The subsequent over-excavation activities were initiated in December
1990 and completed in January 1991. In total, approximately 83 tons of petroleum-impacted
soils were excavated and removed from this portion of the site. Upon the completion of over-
excavation activities, several confirmatory soil samples were collected from the sidewalls and
base of the excavation and the laboratory analytical results indicated that TPH-GRO/DRO
concentrations were not detected at or above the laboratory MDL. Based on these results, the
NCDENR issued a NFA for the underground release incident (Incident No. 5313).

5.3 Physical Setting Sources

The geologic and hydrogeologic settings of a site are considered of interest since they may
provide information related to the direction and physical mechanisms of contaminant migration,
if present, from on-site and off-site sources.

5.3.1 Geologic Setting

According to the map titled Geology of North Carolina (1985), prepared by the North Carolina
Geological Survey Section of the North Carolina Department of Natural Resources and Community
Development, the subject site is located in the Yorktown Formation and/or Duplin Formation of the
Coastal Plain physiographic region. These stratigraphic units are described as follows:

• Duplin Formation – Shelly, medium- to coarse-grained sand, sandy marl, and limestone,
bluish gray; mainly in area south of Neuse River; and
• Yorktown Formation – Fossiliferous clay with varying amounts of fine-grained sand, bluish
gray, shell material commonly concentrated in lenses; mainly in area north of Neuse River.

The formations described above are undivided on the map titled Geology of North Carolina (1985).
The subject site is located north of the Neuse River; therefore, the site is most likely located within
the Yorktown Formation.

Mid-Atlantic Associates, Inc. 11 PESA Report – Former Southern States
Project Number: 000R2377.00 Wilson, North Carolina
800.486.7568 – www.MAAonline.com

5.3.2 Surface Drainage

According to the USGS Topographic Quadrangle Map of Williamston, North Carolina
(Appendix 16.1), the topography of the subject site appears to be relatively flat. The maximum
site elevations appear to occur near the northeast property boundary of the site, with minimum
elevations occurring near the southwest portion of the site. In general, the regional topography
slopes to the southwest towards the Hominy Swamp. In the absence of any other obvious
significant structural or geomorphic drainage features, surface drainage is suspected to be
influenced primarily by the surrounding topography.

5.3.3 Groundwater

Groundwater levels and flow directions are typically site specific. Site-specific groundwater flow
can be influenced by impermeable surfaces, the proximity of nearby drainage features,
sinkholes, creeks, swamps, and pumped groundwater wells. Fractures, joints, bedding planes
and other discontinuities in the underlying rock can affect the groundwater conditions. In this
setting, the surface of the groundwater table is expected to be a subdued replica of the local
topography. Based on Mid-Atlantic’s observations and review of available information, the
regional groundwater flow direction is interpreted to be to the southwest towards the Hominy
Swamp. However, we cannot accurately predict the direction of groundwater flow based solely on
topographic observations and several local components of groundwater flow may exist.

5.4 Historical Use Information on the Subject Site

Mid-Atlantic reviewed historical aerial photographs, Sanborn® Maps, topographic maps, city
directories and tax/deed records to evaluate past uses of the subject site. Copies of documents
corresponding to the historical sources are attached as Appendix 16.4.

5.4.1 Aerial Photographs

Historical aerial photographs for the subject site and its surrounding properties were provided to
Mid-Atlantic by EDR; however, based on the scale and clarity, additional aerial photographs
were obtained from outside sources, as referenced in Section 13.0. Mid-Atlantic’s review of
historical aerial photographs focused primarily on the 1952, 1957 and 1993 aerial photographs
provided by EDR; the 1961 and 1979 aerial photographs obtained from the North Carolina
Department of Transportation (NCDOT); and the 2006 and 2010 aerial photographs obtained
from Terraserver.com.

The subject site appears as cleared and undeveloped land on the 1952 aerial photograph.
Historical aerial photographs from 1957, 1961, 1979, 1993, 2006 and 2010 show the subject
site developed with the present-day commercial/industrial structures. The historical photographs
from 1961 and 1979 also identify several bulk ASTs on the central and southern portions of the
site, along with an apparent loading rack and fuel dispenser on the southern portion of the site.
The 1979 aerial photograph also identifies three additional bulk ASTs on the northeast portion of
the site, adjacent to the railroad spur along the eastern property boundary of the site.

The bulk ASTs on the southern portion of the site appear to have been associated with historical
truck fueling operations; the bulk ASTs on the central portion of the site appear to have been
associated with historical pesticide manufacturing operations; and the bulk ASTs on the
northeast portion of the site appear to have been associated with historical railcar loading and/or
Mid-Atlantic Associates, Inc. 12 PESA Report – Former Southern States
Project Number: 000R2377.00 Wilson, North Carolina
800.486.7568 – www.MAAonline.com

unloading activities. Although several of these ASTs were observed on the 1993 aerial
photograph, the ASTs were no longer present on the 2006 aerial photograph; however, three
additional ASTs were observed on the west-central portion of the site in the 2006 aerial
photograph and the two present-day plastic ASTs were observed on the southwest portion of
the site on the 2011 aerial photograph. The historical operation of these storage vessels on the
subject site represents the potential for an adverse environmental impact and thus constitutes a
REC.

5.4.2 Topographic Maps

The historical topographic map from 1904 could not be interpreted based on scale (1:62,500).
The 1978 and 1998 historical topographic maps show the subject site developed with the
present-day commercial/industrial structures. No environmentally suspect features were
identified on the subject site during Mid-Atlantic’s review of historical topographic maps.

5.4.3 Sanborn® Maps

Historical Sanborn® fire insurance map coverage was not available for a majority of the subject
site area. A small portion of the site was depicted on the 1973 Sanborn map, which only
identified the storage and sales facility on the upper northwest portion of the site. Refer to
Sections 5.4.1, 5.4.2 and 5.4.4 for additional historical document information associated with
the subject site.

5.4.4 City Directories

Mid-Atlantic’s review of historical city directories identified the subject site as Southern States
Cooperative in 2006. No additional listings were provided for the subject site and the historical
operation of a pesticide and fertilizer manufacturing facility on the site constitutes a REC.

5.4.5 Tax and Deed Information

Property record information obtained from the Wilson County Tax Administrator’s Office
identifies the current owner of Parcel ID Number 3721-34-9130 as follows:

Southern States Cooperative c/o Tax Department
Post Office Box 26234
Richmond, Virginia 23260

Mid-Atlantic reviewed chain-of-title information for Parcel ID Number 3721-34-9130 obtained
from the Wilson County Register of Deeds. Title and deed information is summarized in the
following table.

Book/Page Grantor Grantee Date
1294/0331 FCX, Inc.* Southern States Cooperative,
Inc. 03/13/1986
0591/0089 E. Sharpe Newton and wife,
Matrene T. Newton
Farmers Cooperative
Exchange, inc. 03/25/1955
* FCX, Inc., prior to Charter Amendment effective December 15, 1965, was known as Farmers
Cooperative Exchange, Inc.

Mid-Atlantic Associates, Inc. 13 PESA Report – Former Southern States
Project Number: 000R2377.00 Wilson, North Carolina
800.486.7568 – www.MAAonline.com

No other land titles or deeds were referenced for the subject site. The historical use of the
subject site as a pesticide and fertilizer manufacturing facility represents the potential for an
adverse environmental impact and thus constitutes a REC. Copies of the current property deed
and chain-of-title information are included in Appendix 16.4.

5.5 Historical Use Information on Adjoining Properties

Mid-Atlantic reviewed historical aerial photographs, Sanborn Maps, topographic maps, and city
directories to evaluate past uses of adjoining properties. Copies of documents corresponding to
the historical sources are attached as Appendix 16.4.

5.5.1 Aerial Photographs

Historical aerial photographs for the subject site and its surrounding properties were provided to
Mid-Atlantic by EDR; however, based on the scale and clarity, additional aerial photographs
were obtained from outside sources, as referenced in Section 13.0. Mid-Atlantic’s review of
historical aerial photographs focused primarily on the 1952, 1957 and 1993 aerial photographs
provided by EDR; the 1961 and 1979 aerial photographs obtained from the NCDOT; and the
2006 and 2010 aerial photographs obtained from Terraserver.com. Mid-Atlantic’s review of
aerial photographs revealed the following information associated with the historical use of the
adjacent properties:

West/Northwest Adjacent Property, across Ward Boulevard (US Highway 301)

• Historical aerial photographs from 1952, 1957, 1961, 1979 and 1993 identify one historic
commercial/industrial warehouse structure (interpreted to be a tobacco warehouse) on
the west/northwest adjacent property; and
• The west/northwest adjacent property appears as undeveloped land on the 2006 and
2011 aerial photographs.

Northwest Adjacent Property, across Ward Boulevard (US Highway 301)

• The northwest adjacent property appears as undeveloped land on the 1952 aerial
photograph; and
• The present-day commercial/industrial structures were identified on the northwest
adjacent property on the 1957, 1961, 1979, 1993, 2006 and 2011 aerial photographs. In
addition, two bulk ASTs were observed on the northwest adjacent property on the 1961
and 1979 aerial photographs. The historical industrial operations and use of bulk ASTs on
the adjacent property represent the potential for an adverse environmental impact to the
subject site and thus constitute a REC.

North Adjacent Property, across Ward Boulevard (US Highway 301)

• Historical aerial photographs from 1952, 1957, 1961, 1979, 1993, 2006 and 2011 identify
one historic commercial structure on the north adjacent property. The Wilson County Tax
Department identifies the former structure as a “convenience store.” In addition, two
dispenser islands appear to be located on the property immediately adjacent to the east
of this convenience store, approximately 250 feet to the north of the subject site.
Therefore, the potential operation of a service station in close proximity to and
topographically upgradient of the subject site represents a REC.
Mid-Atlantic Associates, Inc. 14 PESA Report – Former Southern States
Project Number: 000R2377.00 Wilson, North Carolina
800.486.7568 – www.MAAonline.com

Northeast Adjacent Property, across the Norfolk-Southern Railroad

• The northeast adjacent property appears as undeveloped land on the 1952, 1957 and
1961 aerial photographs; and
• The present-day commercial/industrial warehouse structure was identified on the
northeast adjacent property on the 1979, 1993, 2006 and 2011 aerial photographs.

South Adjacent Property, across Cargill Avenue

• The south adjacent property appears as undeveloped land on the 1952, 1957, 1961,
1979 and 1993 aerial photographs; and
• The present-day commercial structure (Eastern Carolina Propane Gas) was identified on
the south adjacent property on the 2006 and 2011 aerial photographs.

Southeast Adjacent Property

• The southeast adjacent property appears as undeveloped land on the 1952, 1957 and
1961 aerial photographs; and
• The present-day commercial/industrial structure (Ihrie Supply Company) was identified on
the southeast adjacent property on the 1979, 1993, 2006 and 2011 aerial photographs.

Southwest Adjacent Property, across Cargill Avenue

• The southwest adjacent property appears as undeveloped land on the 1952, 1957 and
1961 aerial photographs; and
• The present-day commercial structure (Rogers Behavioral Health Service) was identified
on the southwest adjacent property on the 1979, 1993, 2006 and 2011 aerial
photographs.

5.5.2 Topographic Maps

The historical topographic map from 1902 could not be interpreted based on scale (1:625,000).
Historical topographic maps from 1978 and 1998 show the subject site bounded to the
northeast, northwest, southeast and southwest by the present-day and former commercial/
industrial structures. Additional environmentally suspect features were not identified on the
adjacent properties during Mid-Atlantic’s review of historical topographic maps.

5.5.3 Sanborn® Maps

Historical Sanborn® fire insurance map coverage was only available for the adjacent properties
to the north, northwest and west/northwest of the subject site. Mid-Atlantic’s review of the 1973
historical Sanborn map revealed the following RECs associated with the northwest adjacent
property, across Ward Boulevard (US Highway 301):

• Historical chemical mixing operations inside the buildings located on the northern portion
of the adjacent site; and
• Historical operation of bulk chemical ASTs on the northern portion of the adjacent site,
along the eastern exterior of the above-referenced chemical mixing buildings.

Mid-Atlantic Associates, Inc. 15 PESA Report – Former Southern States
Project Number: 000R2377.00 Wilson, North Carolina
800.486.7568 – www.MAAonline.com

The historical industrial operations, chemical mixing activities and use of bulk chemical ASTs on
the north adjacent site represent the potential for an adverse environmental impact to the
subject site and thus constitute a REC.

5.5.4 City Directories

Mid-Atlantic’s review of historical city directories revealed the following information concerning
the adjacent properties:

1501 Cargill Avenue – Southeast Adjacent Property

• 2011 – Ihrie Supply Company, Inc. (wholesale plumbing fixtures and supplies)
• 2000 – Ihrie Supply Company, Inc. (plumbing, heating and air conditioning)
• 1994 – Ihrie Supply Company, Inc. (wholesale plumbing and heating)
• 1989 – Ihrie Supply Company, Inc. (plumbing fixtures)
• 1984 – Ihrie Supply Company, Inc. (plumbing fixtures)
• 1979 – Ihrie Supply Company, Inc. (plumbing fixtures)
• 1973 – Ihrie Supply Company, Inc. (plumbing fixtures)

1500 Cargill Avenue – South Adjacent Property, across Cargill Avenue

• 2011 – Eastern Carolina Propane Gas

6631 Ward Boulevard – Southwest Adjacent Property, across Cargill Avenue

• 2012 – Rogers Behavioral Health Service (mental health service)
• 2006 – Wilson County Farm Bureau (life insurance)
• 2000 – Wilson County Farm Bureau (insurance agents)

6.0 Site Reconnaissance
6.1 Methodology and Limiting Conditions

On July 17, 2012, Mid-Atlantic personnel conducted a physical/visual reconnaissance of the
subject site and the surrounding area. Our reconnaissance included a visual inspection of the
entire site, including the interior and exterior of the on-site structures. We did not encounter
limiting conditions during our site reconnaissance that hindered our ability to identify RECs.
Photographs taken during Mid-Atlantic’s site reconnaissance are included in Appendix 16.3.

6.2 General Site Setting, Structures and Utilities

The subject site is located in the southeast portion of Wilson, North Carolina in a generally
commercial/industrial setting. The site is improved with one 11,250 square foot commercial/
industrial facility, which historically operated as an office, showroom and storage warehouse (feed,
seed, etc.) for FCX and Southern States. The main facility is constructed of brick/concrete block
exterior walls with a concrete slab on grade foundation. The site is also improved with three wood-
framed storage buildings, several of which were previously used to store raw materials for use in
Mid-Atlantic Associates, Inc. 16 PESA Report – Former Southern States
Project Number: 000R2377.00 Wilson, North Carolina
800.486.7568 – www.MAAonline.com

the pesticide/fertilizer manufacturing process (potash, nitrates, etc). Additional site improvements
include a sub-grade molasses pit, two truck weigh scales, chain-link fencing, asphalt-paved parking
areas and concrete secondary containment areas, loading docks and sidewalks.

Vehicular access is provided to the site from the north by Ward Boulevard (US Highway 301) and
from the west by Cargill Avenue. The Norfolk-Southern Railroad runs along the eastern property
boundary of the subject site, and a rail spur is located immediately adjacent to the site and was
historically used for railcar loading/unloading activities by FCX. The subject site and its
surrounding properties are provided with municipal water and sewer services by the City of
Wilson Public Services Department.

6.3 Exterior Observations

6.3.1 Pits, Ponds or Lagoons

Mid-Atlantic personnel observed no evidence of pits, ponds, or lagoons on the subject site. One
sub-grade pit was observed underneath the covered storage area along the southern exterior of
the main facility. Based on interview information, the sub-grade pit appears to have been used
by FCX (previous property owner) to store molasses for use in the pesticide and fertilizer
manufacturing process. At the time of the site inspection, the pit was filled with water/runoff.

6.3.2 Stained Soil or Pavement/Stressed Vegetation

Mid-Atlantic personnel observed no evidence of stained soil or pavement, or stressed
vegetation along the exterior portions of the on-site facility.

6.3.3 Solid Waste

Mid-Atlantic personnel observed no evidence that may indicate that trash, debris or other types
of solid waste have been buried or disposed of at the subject site.

6.3.4 Wastewater

The facility does not discharge wastewater into the municipal sewer system.

6.3.5 Wells

Mid-Atlantic personnel observed several abandoned monitoring wells on southern and central
portions of the subject site. The monitoring wells are associated with previous site assessment
activities associated with the former aboveground petroleum release. Additional information
regarding the assessment and remedial activities performed at the site in connection with this
release is discussed in Section 5.2.1.

The subject site and its surrounding properties are provided with water services from the City of
Wilson Public Services Department. Mid-Atlantic personnel did not observe evidence of water-
supply wells on the subject site.

Mid-Atlantic Associates, Inc. 17 PESA Report – Former Southern States
Project Number: 000R2377.00 Wilson, North Carolina
800.486.7568 – www.MAAonline.com

6.3.6 Septic Systems

The subject site and its surrounding properties are provided with sewer services from the City of
Wilson Public Services Department. Mid-Atlantic did not observe evidence of septic systems on
the subject site.

6.3.7 Storage Tanks/Vessels

Mid-Atlantic personnel observed two empty 1,000-gallon plastic ASTs on the southern portion of
the subject site, adjacent to the former bulk petroleum AST containment area. In addition, three
55-gallon drums of herbicides and one 100-gallon tank of unknown contents were observed
inside one of the covered raw material storage bins on the eastern portion of the site. The 55-
gallon drums were staged on a wooden pallet and no staining or evidence of a release was
observed in the vicinity of these storage vessels.

6.3.8 PCBs

Older transformers and other electrical equipment could contain polychlorinated biphenyls
(PCBs) at a level that subjects them to regulation by the U.S. EPA. PCBs in electrical equipment
are controlled by United States Environmental Protection Agency regulations 40 CFR, Part 761.
Mid-Atlantic observed two pole-mounted transformers on the central portion of the subject site
during the site inspection. The transformers were not labeled with a blue dot, which would have
indicated that the transformers had been tested for and did not contain PCBs. Mid-Atlantic did
not observe evidence of staining, leaks or fire damage on or around these units during the site
inspection. No other equipment likely to contain PCBs was observed at the subject site.

6.3.9 Surrounding Land Use

In some situations, past and current uses of surrounding properties may pose a potential
environmental concern to a subject site. Mid-Atlantic visually inspected, to the extent practical,
surrounding properties for current site uses and evidence of past site uses that could potentially
have an adverse environmental impact on the subject site.

The subject site is bounded to the northwest, across Ward Boulevard, by several vacant and
dilapidated commercial/industrial structures; to the northeast, across the Norfolk-Southern
Railroad, by a vacant commercial/industrial warehouse facility; to the southwest, across Cargill
Avenue, by Rogers Behavioral Health Service; to the south, across Cargill Avenue, by Eastern
Carolina Propane Gas; and to the southeast by Ihrie Supply Company. The current use of the
adjacent and surrounding properties does not appear to pose an environmental threat to the
subject site.

6.3.10 Other Evidence of Environmental Impacts

Mid-Atlantic personnel did not observe other evidence of past, current or future activities on the
exterior portions of the site structures that could potentially have an adverse environmental
impact on the subject site.

Mid-Atlantic Associates, Inc. 18 PESA Report – Former Southern States
Project Number: 000R2377.00 Wilson, North Carolina
800.486.7568 – www.MAAonline.com

6.4 Interior Observations

6.4.1 Heating and Cooling Systems

At the time of the site inspection, the on-site facilities were vacant with no evidence of heating
and/or cooling systems observed. Based on historical documents and available information, it
appears that heating oil was previously used in historical site heating applications. The former
550-gallon heating oil UST was removed from the northwest portion of the site in September
1989 and, upon removal, petroleum-impacted soils were encountered in the excavation
(Incident No. 5313). Over-excavation activities were conducted in the vicinity of the former UST
basin and the incident file was later closed out. Additional information regarding the UST closure
and over-excavation activities is discussed in Section 5.2.1.

6.4.2 Staining and Chemical Storage/Use

During the site inspection, Mid-Atlantic personnel observed no evidence of chemical storage,
use or staining on the interior portions of the on-site structures.

6.4.3 Drains and Sumps

Mid-Atlantic personnel did not observe evidence of drains or sumps inside the subject site
structures, with the exception of the sanitary drains associated with the facility restrooms.

6.4.4 Asbestos Containing Materials and Lead-Based Paint

Asbestos-containing materials and lead-based paint surveys were not conducted as part of this
investigation.

6.4.5 Other Evidence of Environmental Impacts

Mid-Atlantic personnel did not observe other evidence of past, current or future activities that
could potentially have an adverse environmental impact on the subject site.

7.0 Interviews
7.1 Interview with Owner

The current owner of record for the subject site is listed as Southern States Cooperative, Inc.
The owner representative and point-of-contact for this project was Mr. Ted Crowe, Project
Manager for Southern States Cooperative. According to Mr. Crowe, the subject site operated as
a pesticide and fertilizer manufacturing and distribution facility from the time of its development
until approximately 2006, when Southern States ceased operations at the subject site. The site
has reportedly been vacant and non-operation since 2006.

Mr. Crowe was unable to provide Mid-Atlantic with any additional environmental reports for the
subject site, aside from those which were available and reviewed at the NCDENR. Mr. Crowe
also indicated that, to the best of his knowledge, the former on-site USTs had all been removed
from the site and, if necessary, the proper environmental actions were conducted upon removal.
Mid-Atlantic Associates, Inc. 19 PESA Report – Former Southern States
Project Number: 000R2377.00 Wilson, North Carolina
800.486.7568 – www.MAAonline.com

Mr. Crowe had no knowledge of the specific locations, contents and/or operational procedures
associated with the former on-site UST and AST systems. Additionally, Mr. Crowe indicated that
the sub-grade molasses pit and railcar unloading areas were utilized by FCX prior to Southern
States’ purchase of the property.

7.2 Interview with Site Manager

At the time of the site inspection, the subject site was vacant and non-operational. Therefore, no
site manager was available for interview.

7.3 Interview with Occupants

At the time of the site inspection, the subject site was vacant and non-operational. Therefore, no
site occupants were available for interview.

7.4 Interview with Local Government Officials

During the performance of this PESA, Mid-Atlantic attempted to conduct an interview with a
representative of the local fire department; however, Mid-Atlantic was unable to obtain interview
information from the local fire department. Mid-Atlantic’s assessment was not hindered by this
lack of information.

7.5 Interview with Others

Mid-Atlantic also conducted an interview with Mr. Jim Wright, Director of Environmental
Services for Southern States Cooperative. Mr. Wright indicated that he began working with
Southern States in 2001 and, by that time, the environmental issues associated with the subject
property had already been resolved. Therefore, Mr. Wright had limited knowledge as to the
historical site operations and associated environmental conditions. Mr. Wright, however, was
able to confirm that the sub-grade pit observed during the site inspection was indeed historically
used to store molasses while FCX was operating on the subject site (prior to 1986).

8.0 Findings

The following known/suspect RECs, historical RECs and/or de minimus conditions were
identified during the performance of this PESA:

• The subject site has operated as a pesticide and fertilizer manufacturing and distribution
facility since development of the site in 1956. These historical operations included the
use of numerous bulk ASTs;
• The subject site was identified in the UST, LUST and LUST Trust Databases and
historically operated one 550-gallon fuel oil UST, one 550-gallon kerosene UST, one
550-gallon unidentified petroleum UST and one 3,000-gallon unidentified petroleum
UST. The USTs were reportedly removed from the site in 1989. Upon removal of the
550-gallon fuel oil UST, petroleum-impacted soils were encountered beneath the former
UST and subsequent over-excavation activities were conducted to remove the impacted
soils (Incident No. 5313);
Mid-Atlantic Associates, Inc. 20 PESA Report – Former Southern States
Project Number: 000R2377.00 Wilson, North Carolina
800.486.7568 – www.MAAonline.com

• The subject site historically operated a bulk petroleum storage and fueling facility, which
resulted in a documented aboveground petroleum release (Incident No. 21616). The
subject site was also identified in the IMD and LAST Databases as a result of these
historical operations; however, previous assessment and remedial activities have been
conducted at the site and the incident file associated with the former on-site petroleum
release has been closed out;
• The subject site historically utilized the eastern adjacent railroad spur for various loading/
unloading activities. In addition, three ASTs were identified on the northeast portion of
the site, adjacent to the railcar loading/unloading areas, on the 1979 aerial photograph;
• Historical aerial photographs from 1952 through 2011 identify one historic structure on
the north adjacent property. The Wilson County Tax Department identifies the former
structure as a “convenience store” and, in addition, two dispenser islands appear to be
located on the property immediately adjacent to the east of this convenience store; and
• Historical chemical mixing operations and bulk chemical ASTs were identified on the
north adjacent property, across Ward Boulevard (US Highway 301) on the 1973
Sanborn® fire insurance map.

9.0 Opinions
9.1 On-Site Environmental Concerns and Opinions

The former bulk ASTs on the southern portion of the site appear to have been associated with
historical truck fueling operations; the bulk ASTs on the central portion of the site appear to
have been associated with historical pesticide manufacturing operations; and the bulk ASTs on
the northeast portion of the site appear to have been associated with historical railcar loading
and/or unloading activities. The previous operation of these bulk ASTs and the historical on-site
industrial activities associated with these storage vessels represent the potential for an adverse
environmental impact to the subject site and thus constitute RECs.

Based on information provided in the IMD and LAST databases, petroleum-impacted soils were
encountered at the site in November 1998 as a result of an aboveground release. The release
impacted groundwater beneath the site (Incident No. 21616) and, following approval of a CAP
and completion of quarterly groundwater monitoring activities, the incident files were closed out
in both the IMD and LAST Database. Although no additional assessment and/or remediation
activities appear to be necessary for this release, the historical presence of released petroleum
and subsequent assessment and remediation activities at the site continue to represent a REC.

In addition to the above-referenced release, the subject site was also identified in the UST,
LUST and LUST Trust Fund Databases. Information provided in these databases indicates the
site historically operated four petroleum USTs, three of which could not be identified during Mid-
Atlantic’s review of historical documents and previous environmental reports. According to the
LUST Database, petroleum-impacted soils were encountered during removal of the 550-gallon
fuel oil UST (Incident No. 5313). The release reportedly did not impact groundwater beneath the
site and the incident files have been closed out in the LUST Database. Although no additional
assessment and/or remediation activities appear to be necessary for this release, the historical
presence of released petroleum and the former operation of several on-site petroleum USTs at
unknown locations continue to constitute RECs.

Mid-Atlantic Associates, Inc. 21 PESA Report – Former Southern States
Project Number: 000R2377.00 Wilson, North Carolina
800.486.7568 – www.MAAonline.com

9.2 Off-Site Environmental Concerns and Opinions

The historical operations on the northwest adjacent property, across Ward Boulevard (US
Highway 301), included the operation of two bulk chemical ASTs and their associated chemical
mixing operations. These historical operations, along with the presence of bulk chemical ASTs
on the adjacent property, represent the potential for an adverse environmental impact to the
subject site and thus constitute a REC.

Historical aerial photographs identify a former commercial structure on the north adjacent
property, across Ward Boulevard (US Highway 301). The Wilson County Tax Department
identifies the former structure as a “convenience store.” In addition, two dispenser islands
appear to be located on the property immediately adjacent to the east of this convenience store,
located approximately 250 feet to the north of the subject site. Therefore, the potential operation
of a service station in close proximity to and topographically upgradient of the subject site
represents a REC.

9.3 Data Gaps

A data gap is a lack of or inability to obtain information despite good faith efforts. A PESA report
should identify and comment on significant data gaps when they affect the Environmental
Professional’s ability to identify RECs. The Environmental Professional must also identify the
sources of information that were consulted to address these significant data gaps. Mid-Atlantic
did not identify data gaps while conducting the required PESA activities.

10.0 Conclusions and Recommendations
10.1 Conclusions

Mid-Atlantic has performed this PESA in general conformance with the scope and limitations of
ASTM Practice E 1527-05 and 40 CFR Part 312. Any exceptions to, or deletions from, these
practices are described in Section 2.4 and Section 11.0 of this report. This assessment has
revealed the following RECs in connection with the subject property:

• The historical on-site manufacturing, storage and distribution of pesticides and fertilizers,
including the storage of these materials in ASTs;
• The historical use of the subject site as a bulk petroleum storage and distribution facility,
including the storage of petroleum in ASTs and the documented release(s) from these
activities;
• The documented release from a 550-gallon heating oil UST on the northeast portion of
the site;
• The former operation of three petroleum USTs at unknown locations on the subject site;
• The potential operation of a service station to the north and topographically upgradient of
the subject site, across Ward Boulevard (US Highway 301); and
• The historical industrial operations, chemical mixing activities and use of bulk chemical
ASTs on the north adjacent site, across Ward Boulevard (US Highway 301).

Mid-Atlantic Associates, Inc. 22 PESA Report – Former Southern States
Project Number: 000R2377.00 Wilson, North Carolina
800.486.7568 – www.MAAonline.com

10.2 Recommendations

The subject site historically utilized numerous ASTs for the bulk storage of various pesticides,
fertilizers and petroleum products. In addition, soil and groundwater contamination have been
documented at the site as a result of released petroleum from the former on-site ASTs and 550-
gallon heating oil UST system (Incident No. 21616 and Incident No. 5313, respectively). Previous
site assessment and remediation activities have been conducted in response to these releases,
specifically in the areas surrounding the truck weigh scales on the south and northwest portions of
the site. These activities included the excavation of petroleum-impacted soils and remediation of
groundwater through monitored natural attenuation, which appears to have remediated soil and
groundwater beneath these portions of the site to beneath applicable regulatory action levels.
Therefore, no additional assessment and/or remedial activities appear to be necessary at the site
to address the previous on-site petroleum releases.

The potential environmental impacts associated with the historical storage and manufacturing of
pesticides and fertilizers at the site do not appear to have been evaluated at this time. Therefore,
soil and/or groundwater beneath the site may have been impacted as a result of these industrial
activities. Based on our knowledge of the historical site operations, the remaining on-site areas of
concern appear to be primarily associated with the former bulk pesticide and fertilizer ASTs; the
historical railcar loading/unloading areas; and the unidentified locations of several former petroleum
USTs, which were reportedly removed from the site in 1989. In addition to these on-site areas of
concern, it also appears that historical off-site activities may potentially have resulted in an adverse
environmental impact to groundwater beneath the subject site. These off-site activities include the
potential former operation of a service station to the north and topographically upgradient of the
subject site, in addition to the former chemical mixing operations and bulk ASTs previously utilized
on the northwest adjacent property, across Ward Boulevard (US Highway 301).

Based on the results of this assessment, Mid-Atlantic recommends additional Phase II activities at
the site to address the aforementioned RECs. It is Mid-Atlantic’s understanding that the results of
this assessment will be used to prepare and submit an application to the North Carolina
Brownfields Program. Therefore, assuming that eligibility will be granted for the site, future
assessment and/or remedial activities should be coordinated through the North Carolina
Brownfields Program. Mid-Atlantic can assist you with these activities at your request.

11.0 Deviations

This PESA substantially complies with the scope of services and ASTM E 1527-05, as
amended, except for exceptions and /or limiting conditions as discussed in Section 2.4.

12.0 Additional Services

Mid-Atlantic did not conduct surveys/investigations for asbestos-containing materials or lead-
based paint during the performance of this assessment.

Mid-Atlantic Associates, Inc. 23 PESA Report – Former Southern States
Project Number: 000R2377.00 Wilson, North Carolina
800.486.7568 – www.MAAonline.com

13.0 References

The following sources were used during performance of this PESA:

• USGS Topographic Quadrangle Map of Wilson, North Carolina (Appendix 16.1);
• Geologic Map of North Carolina, North Carolina Geologic Survey, 1985;
• Wilson County GIS website (http://gis.wilson-co.com/ConnectGIS_v6/Disclaimer.aspx);
• Current property deed and chain-of-title information obtained from the Wilson County
Register of Deeds (Appendix 16.4);
• Aerial photographs of the subject site area from 2006 and 2011 provided by
Terraserver.com (www.terraserver.com) and their business partners AirPhotoUSA and
LandVoyage. Copies of the aerial photographs were printed under a paid subscription
(Appendix 16.4);
• Aerial photographs of the subject site area from 1961 and 1979 purchased from the
North Carolina Department of Transportation (Appendix 16.4);
• The EDR Radius Map Report, Environmental Data Resources, Inc. (Appendix 16.5);
• EDR Historical Topographic Map Report (Appendix 16.4);
• EDR City Directory Abstract (Appendix 16.4);
• EDR Sanborn® Map Report (Appendix 16.4);
• EDR Aerial Photo Decade Package (Appendix 16.4);
• Soil Excavation Report, Southern States Cooperative prepared by Duncklee & Dunham,
P.C. and dated November 23, 1998 (Appendix 16.6);
• Comprehensive Site Assessment Report, Southern States Cooperative prepared by
Duncklee & Dunham, P.C. and dated July 28, 2000 (Appendix 16.6);
• Corrective Action Plan, Southern States Cooperative prepared by Duncklee & Dunham,
P.C. and dated October 30, 2000 (Appendix 16.6);
• Groundwater Monitoring Report, Southern States Cooperative prepared by Duncklee &
Dunham, P.C. and dated November 29, 2001 (most recent monitoring report);
• Approval – Site Closure Request prepared by the NCDENR and issued to Southern
States Cooperative on December 17, 2001 (Appendix 16.6);
• Monitoring Well Abandonment Record, Southern States Cooperative prepared by
Duncklee & Dunham, P.C. and dated February 8, 2002 (Appendix 16.6);
• Underground Storage Tank Closure Soil Assessment Report, Southern States
Cooperative prepared by Aquaterra, Inc. and dated October 12, 1989 (Appendix 16.7);
• Draft Comprehensive Site Assessment and Corrective Action Report, Southern States
Cooperative prepared by Aquaterra, Inc. and dated April 6, 1990 (Appendix 16.7);
• Soil Remediation Report, Southern States Cooperative prepared by Aquaterra, Inc. and
dated January 17, 1991 (Appendix 16.7); and
• Memorandum – Incident 5313 Closeout of Southern States prepared by the NCDENR
and dated March 13, 1991 (Appendix 16.7).

Mid-Atlantic Associates, Inc. 24 PESA Report – Former Southern States
Project Number: 000R2377.00 Wilson, North Carolina
800.486.7568 – www.MAAonline.com

14.0 Signatures of Environmental Professional(s)

I declare that, to the best of my professional knowledge and belief, I meet the definition of
Environmental Professional as defined in §312.10 of 40 CFR 312 and have the specific
qualifications based on education, training and experience to assess a property of the nature,
history, and setting of the subject property. I have developed and performed the all appropriate
inquiries in general conformance with the standards and practices set forth in 40 CFR Part 312.
Darin M. McClure
Principal Engineer

15.0 Qualifications of Environmental Professionals

All phases of this PESA were conducted, completed and reviewed by qualified Mid-Atlantic
personnel experienced in conducting PESAs on similar sites. Summaries of the experience of
those conducting this PESA are included in Appendix 16.10.

16.0 Appendices

Mid-Atlantic Associates, Inc. PESA Report – Former Southern States
Project Number: 000R2377.00 Wilson, North Carolina
800.486.7568 – www.MAAonline.com

Appendix 16.1

Topographic Site Map
Mid-Atlantic Associates, Inc. PESA Report – Former Southern States
Project Number: 000R2377.00 Wilson, North Carolina
800.486.7568 – www.MAAonline.com
Appendix 16.2

Site Map

Mid-Atlantic Associates, Inc. PESA Report – Former Southern States
Project Number: 000R2377.00 Wilson, North Carolina
800.486.7568 – www.MAAonline.com

Appendix 16.3

Site Photographs

Former Southern States
Wilson, North Carolina

Mid-Atlantic Associates, Inc. 1 July 2012
Photo 1 –Office, showroom and storage
warehouse located on northern portion of the
subject site. View is facing southeast
Photo 2 – Covered raw material storage bins
located along eastern property boundary of
the subject site
Photo 3 – Covered raw material storage bins
located along southern property boundary of
the subject site
Photo 4 – Wood-framed storage building
located along eastern property boundary of
subject site (adjacent to Photo 3)
Photo 5 – Truck weigh scales located on
southern portion of subject site (former
excavation area for aboveground release)
Photo 6 – Former bulk petroleum and fertilizer
AST containment area, located on southern
portion of the subject site
Former Southern States
Wilson, North Carolina

Mid-Atlantic Associates, Inc. 2 July 2012

Photo 7 – 55-gallon plastic drums (herbicide)
and 100-gallon plastic tote (unknown) located
inside the covered raw material storage bins
Photo 8 – Two empty 1,000-gallon plastic
ASTs located adjacent to the former bulk AST
containment area on southern portion of site
Photo 9 – Loading docks located along
eastern exterior of main facility, adjacent to
railroad spur along eastern property boundary
Photo 10 – Sub-grade molasses pit located
along the southern exterior of main facility
Photo 11 – Abandoned monitoring well, one of
several located throughout the subject site
Photo 12 – On-site pole-mounted
transformers with no observed staining
Former Southern States
Wilson, North Carolina

Mid-Atlantic Associates, Inc. 3 July 2012

Photo 13 – View of northwest adjacent site
(former chemical mixing operations) from the
subject site, across Ward Boulevard
Photo 13 – Vacant, abandoned structures
located on northwest adjacent property

Mid-Atlantic Associates, Inc. PESA Report – Former Southern States
Project Number: 000R2377.00 Wilson, North Carolina
800.486.7568 – www.MAAonline.com

Appendix 16.4

Historical Research Documentation

Mid-Atlantic Associates, Inc. PESA Report – Former Southern States
Project Number: 000R2377.00 Wilson, North Carolina
800.486.7568 – www.MAAonline.com

Appendix 16.5

Regulatory Records Documentation
Mid-Atlantic Associates, Inc. PESA Report – Former Southern States
Project Number: 000R2377.00 Wilson, North Carolina
800.486.7568 – www.MAAonline.com

Appendix 16.6

Subject Site Environmental Records -
Aboveground Release Incident

Mid-Atlantic Associates, Inc. PESA Report – Former Southern States
Project Number: 000R2377.00 Wilson, North Carolina
800.486.7568 – www.MAAonline.com

Appendix 16.7

Subject Site Environmental Records -
Underground Release Incident
Mid-Atlantic Associates, Inc. PESA Report – Former Southern States
Project Number: 000R2377.00 Wilson, North Carolina
800.486.7568 – www.MAAonline.com

Appendix 16.8

User-Provided Information

Mid-Atlantic Associates, Inc. PESA Report – Former Southern States
Project Number: 000R2377.00 Wilson, North Carolina
800.486.7568 – www.MAAonline.com

Appendix 16.9

Special Contractual Conditions

None

Mid-Atlantic Associates, Inc. PESA Report – Former Southern States
Project Number: 000R2377.00 Wilson, North Carolina
800.486.7568 – www.MAAonline.com

Appendix 16.10

Qualifications of the Environmental Professional(s)

Mid-Atlantic Associates, Inc. PESA Report – Former Southern States
Project Number: 000R2377.00 Wilson, North Carolina
800.486.7568 – www.MAAonline.com
Darin M. McClure

Darin McClure, a Principal and founder of Mid-Atlantic, has over 20 years of experience with a
broad range of environmental-related projects. Mr. McClure has successfully managed a
diverse mix of projects for a diverse group of clients. Mr. McClure specializes in
soil/groundwater assessment and remediation, Brownfields redevelopment, and assisting
facilities with compliance under a variety of regulatory programs (NPDES, Oil Spill Prevention,
etc.). Mr. McClure is a licensed Professional Engineer in the states of North Carolina, Virginia,
South Carolina, and Pennsylvania. Mr. McClure is considered an Environmental Professional as
defined in 40 CFR Part 312 and ASTM E 1527-05.

Charles B. Hoffman

After receiving his degree in Environmental Geology in 2008, Mr. Hoffman now has over four
years of experience working in the environmental field. His experience includes the
management and oversight of numerous Phase I and Phase II Environmental Site
Assessments, as well as various applications that relate to the remediation and/or natural
attenuation of contaminated sites.