MO-29640_48765_CA_O_20230327

524 East Boulevard | Charlotte, NC 28203 | phone [phone] | www.vanburenlaw.com

March 24, 2023

VIA EMAIL ONLY

North Carolina Department of Environmental Quality
Attn: Mr. Brad Newton
610 East Center Avenue
Suite 300
Mooresville, NC 28115

RE: 1910 Hunt, LLC (“Hunt”); Former Flint Mill, Gastonia, NC (the
“Property”); Incident #48765

Dear Mr. Newton:

Van Buren Law, PLLC represents Hunt. After receipt of your letter dated
November 30, 2022, Hunt decided to further excavate petroleum contaminated
soils remaining at the Property. Hunt is going to redevelop the mill building on
the Property for residential usage.

Hunt excavated and removed an additional 203 tons of petroleum impacted
soils in two separate excavation events. Evidence of an old railroad spur was
found in the excavation. Confirmation samples from the final excavation event
revealed no exceedances of Residential MSCCs, except for one constituent
(benzo(a)pyrene) in one soil sample (SS-2A) collected on the sidewall adjacent to
the mill building. SS-2A was collected at about six feet below the ground surface.
The levels of benzo(a)pyrene (.76 ppm) in SS-2A only slightly exceeded its
Residential MSCC (.66 ppm). ECS was concerned that further excavation in the
vicinity of SS-2A would undermine the structural integrity of the mill building.
Benzo(a)pyrene is not a vapor risk.

Benzo(a)pyrene is a polycyclic aromatic hydrocarbon that is the result of
the incomplete combustion of organic matter, such as wood, coal, oil and gasoline.
The low levels of benzo(a)pyrene found in SS-2A could be due to exhaust from
machinery and engines using the railroad spur found in the excavation, as
March 24, 2023
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opposed to the release from the former heating oil tank. ECS believes no further
assessment at the Property is warranted.

Based on the recent assessment results, Hunt hereby requests a No Further
Action Letter for Incident #48765. Please call me with any questions.

Very truly yours,

Carol Jones Van Buren

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