MO-29737_48853_CA_LTRRPT_20230118

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

January 17, 2023

Tiffany Property Investments, LLC c/o
Mr. Scott Rubzin
P. O. Box 34614
Charlotte, NC 28234

Reference: Inspection of an underground storage tank (UST) located at 2149 6th Street NW,
Hickory, North Carolina

Cedar Rock Project # 358422590

Dear Mr. Rubzin/:

Cedar Rock Environmental, P. C. (Cedar Rock) performed a site inspection on January 16, 2023 at the
above referenced location. The purpose of the inspection was to determine if the UST previously used for
storing heating oil had leaked causing significant contamination of the underlying soils. It is our
understanding the residence was built in 1955 which is most likely when the UST was installed.

An inactive UST was observed to be located as shown in the Site Sketch. Both the fill and vent pipes of
the UST were observed to be intact, however, the vent pipe was missing its cap. The depth to the top of
the UST is approximately 18 inches below land surface (bls). The UST has a length of about 77 inches
with a diameter of approximately 44.75 inches and a capacity of about 550 gallons. The UST was measured
to contain approximately 3 gallons of fluid. White flagging was installed to mark the ends of the UST (see
Photo). No other USTs on the property were discovered using a metal detector to survey along the outside
perimeter of the house where USTs would usually be located. Two copper fuel delivery/return lines were
observed connected to an inactive furnace in the crawlspace. No petroleum odors or stains were observed
in the crawlspace.

Once the orientation of the UST was determined, a soil boring was performed at the northern end of the
tank using a 3.25-inch diameter stainless steel hand auger. The boring was advanced to a depth of
approximately 5.25 feet bls, about the bottom of the UST. A strong petroleum odor and local discoloration
was observed in the soils from a depth of approximately 4.75 to 5.25 feet bls suggesting significant leakage
from the UST has occurred. The soils at the base of the boring consist of a reddish orange-brown sandy
silt.

The property is currently serviced by an onsite water supply well located approximately 70 feet southwest
of the petroleum release. Because this well is located within 150 feet of the petroleum release, the property
would be classified as “High Risk” by the State. No other wells were observed within 150 feet of the
release.

Based on the results of this investigation, significant contamination of the soils surrounding the UST has
been confirmed. Current law (NCGS 143-215.85 (a) and (b)) requires that any significant release of
petroleum be immediately reported to the North Carolina Department of Environmental Quality (DEQ),
Division of Waste Management, Mooresville Regional Office (704-663-1699). According to State law,
upon reporting the release, the current property owner where a release is discovered is identified by the
Cedar Rock
ENVIRONMENTAL
Mr. Scott Rubzin
January 17, 2023
Page 2

State as the “Responsible Party” for any State required action relating to the UST leakage. Upon your
request, Cedar Rock submitted a UST-61 form to satisfy the State’s notification requirement for the release.

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

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

An NFA letter can be obtained in two different scenarios. Scenario One requires the removal of the UST
and all associated contaminated soil exceeding applicable standards. Scenario Two requires reclassifying
the property to “Low Risk” by abandoning the active water supply well (requires a certified well driller and
the submittal of a well abandonment record), connecting to municipal water, filing an NRP, performing the
Public Notification task and abating the petroleum release (removing tank contents and cleaning the tank
interior) pursuant to 15A NCAC 2L .0106(b). We recommend pursuing Scenario Two in that access for
the excavation of contaminated soils is limited and would not likely be successful in the removal of all
contamination.

In the event the property is reclassified to “Low Risk” to allow for the abandonment of the tank, it would
consist of exposing a portion of the UST by hand excavation, cutting a hole about two feet in diameter on
the topside of the UST, removing all tank and fuel line contents, pressure wash cleaning of the tank interior,
and filling the tank with a structurally supportive yet excavatable flowable fill cement slurry. A summary
report signed by a licensed geologist would be generated that would include photographs of each step of
the abandonment process, including a photograph of the interior of the UST to show the UST was properly
cleaned. Cedar Rock can provide this service for a charge of $4,000.00 plus $1.40 per gallon of recovered
fluids. Preparing and filing the NRP and performing the Public Notification requirement will cost an
additional $1,250.00. Cedar Rock would not be responsible for properly abandoning the active water
supply well or providing a replacement water supply.

If required, Cedar Rock can remove the UST including up to 15 tons of contaminated soil for a charge of
$15,000.00 plus $1.40 per gallon of recovered fluids. Tonnage in excess of 15 tons will be an added
charge at the rate of $140.00 per ton. This would include appropriate environmental assessment, reporting,
and site restoration. All work performed would be in accordance with the recommended practices and
procedures outlined in the Guidelines for Site Checks, Tank Closure, and Initial Response and Abatement,
Change 11 (May 17, 2021), published by the North Carolina Department of Environmental Quality,
Mr. Scott Rubzin
January 17, 2023
Page 3

Division of Waste Management, UST Section. Please keep in mind that attempting to remove the UST and
all contaminated soils exceeding applicable standards carries some financial risk because if all the
contamination cannot be removed (i.e. if the contamination extends deeper than our excavation equipment
can reach or to beneath the foundation of the house), the State will still require abandonment of the active
water supply well, filing an NRP and performing Public Notification before issuing an NFA letter.

Attached is an invoice for the site inspection. We appreciate the opportunity to be of service to you. If you
have any questions regarding the content of this report, please call me at 336-684-3836.

Sincerely,

Josiah D. Payne, N.C. Licensed Geologist #2825

Attachment
Mr. Scott Rubzin
January 17, 2023
Page 4

Site Sketch. Sketch is to scale relative to itself.

Photo. View of the UST location. Both ends of the UST are marked with white flags.
N
House UST Location of soil boring
3.5 ft
Deck
0.5 ft
Porch
Patio