MO-30292_49318_C_MISCCLO_20230908_JPS Composites

ATC Associates of North Carolina PC
7606 Whitehall Executive Center Drive, Suite 800
Charlotte, NC 28273
Phone [phone]
Fax: [phone]
www.atcassociates.com

September 8, 2023

Mr. Ryan Mills
Environmental Program Consultant, Division of Waste Management
UST Section – Corrective Action Branch
North Carolina Department of Environmental Quality
610 East Center Avenue, Suite 301
Mooresville, NC 28115

Re: UST Closure In-Place Request
JPS Composite Materials, Inc., UST Facility ID 00-0-0000009583
535 Connor Street, Statesville, Iredell County, North Carolina 28677

Dear Mr. Mills:

ATC Associates of North Carolina, P.C. (ATC) is pleased to submit this UST (Underground Storage Tank)
Closure In-Place Request letter for the planned closure of the 30,000-gallon heating oil UST system located
at the above referenced facility. ATC has completed an evaluation of closure methods for the UST system
to provide recommendations to the client, JPS Composite Materials, Inc. (JPS), for the most appropriate
method of tank closure. Background information and other relevant information pertaining to this request
are included herein.

Background
JPS has operated as a fiberglass manufacturing facility since the late 1800s. One 20,000-gallon
underground storage tank (UST) System and one 30,000-gallon UST system are located at the site, and
are registered as UST numbers 5 (UST-5) and 6 (UST-6), respectively, by the North Carolina Department
of Environmental Quality (NCDEQ), Division of Waste Management, UST Section. The NCDEQ’s database
indicates that the single-walled steel USTs were installed in 1963 and 1978, and both are registered as
commercial, non-regulated USTs. The USTs were used as heating oil tanks for use solely on premises.
In accordance with the NCDEQ Guidelines for Site Checks, Tank Closure, and Initial Response and
Abatement, Change 11, 2021 (STIRA), the USTs are non-regulated, commercial USTs. ATC additionally
understands that there have been no releases confirmed or suspected from either of the above-mentioned
tanks prior to recent UST Closure activities.
The USTs historically contained #5 fuel oil, with no history of any other contents, according to information
provided by JPS. According to JPS representatives, they are single wall steel USTs. The 20,000-gallon
UST is located at the loading dock near the boiler room and the 30,000-gallon UST is in the southeastern
portion of the property towards Pine Street. Aboveground and underground piping leads from the 30,000-
gallon UST to the 20,000-gallon UST, with underground piping leading into the boiler room. The UST
Systems are considered separate systems, and the connected piping is allocated equally between them,
in accordance with the definition of “Connected Piping” in North Carolina Administrative Code, Title 15A,
Subchapter 02N (NCAC 15A .02N), Section .0203.
UST Closure In-Place Request Letter, September 8, 2023
JPS Composite Materials, Inc., Statesville, Iredell County, NC

2
JPS representatives have regularly measured the liquid levels in both tanks, and there has been no liquid
level change since at least 2016.
UST Closure Activities
After cleaning of the 30,000-gallon UST during UST closure activities, several thumb to pinky sized
corrosion holes were observed in the bottom of that tank and water was noted to be entering the UST
through these holes. No water was observed in the UST prior to removal of the heating oil. After consultation
with NCDEQ, this was determined to be an unusual operating condition and thus required to be reported.
Initial response actions were taken to remove the tank contents, clean the UST, and plug the holes to
mitigate the potential for any additional groundwater entering the tank, fulfilling the requirements for Initial
Response Actions in accordance with NCAC 15A .02N, Section .0702. A UST-61 form was submitted for
the 30,000-gallon UST on August 23, 2023, to serve as the 24-hour notification of an unusual operating
condition, in accordance with NCAC 15A .02N, Section .0601.
It is possible that an actual release has not occurred based on the absence of water in the UST prior to
removing the heating oil, the high viscosity of the Number 5 heating oil, and review of tank-stick records
kept by the facility since at least 2016.
No unusual operating conditions requiring 24-hour reporting were observed during the cleaning of the
20,000-gallon UST or associated lines, and therefore, the UST was closed in-place on August 23, 2023,
with a UST Closure Report and UST-2A form to be submitted within the required time frames outlined in
applicable guidance and regulations.
Closure In-Place Request - 30,000-Gallon UST System (UST-6)

The UST is located along the southeastern portion of the JPS facility bounded by Pine Street and an active
railroad to the South. The tank is approximately 10.6 feet in diameter and 47 feet in length. The bottom of
the tank is approximately 16 to 18 feet below grade, depending on the slope of the ground surface in that
area. Low-hanging overhead power lines run approximately 15 feet from the western side of the UST and
diagonally over the UST basin itself toward the east. An access road for JPS facility operations is located
approximately 20 feet to the south of the UST. To the west, large cooling towers are present within
approximately 25 feet of the UST basin. To the north, there is a loading dock within 10 feet from the UST
basin. Asphalt covers the UST and surrounding area.

The 30,000-gallon UST is a non-regulated, commercial tank. Since an unusual operating condition was
identified during the closure of the 30,000-gallon UST, environmental sampling may be required as part of
closing the UST, whether the UST is closed in place or removed. Following closure, the NCDEQ’s UST-2A
form will be completed and submitted to the NCDEQ to have their database updated to indicate that UST-
6 has been closed.

Based on ATC’s evaluation of the site conditions (known and estimated), it is ATC’s opinion that the 30,000-
gallon UST be abandoned in place, with closure sampling to be conducted in accordance with NCDEQ
STIRA Guidelines, Section 3.7.3. Removal of the UST itself would result in an excavation to a depth of at
least 18 feet below the top of the asphalt, which would require a protective system such as benching,
stepping, or shoring in accordance with OSHA standards provided in 29 CFR 1926.652(b) and (c).
Additionally, due to the 30,000-gallon UST’s location in proximity to the loading dock, cooling towers, access
road, and overhead power, the plant operations will need to be shut down for the period of time it requires
ATC Project #199JPS2301JPS Composite Materials, Inc.
535 Connor Street, Statesville, Iredell County, NC 28677

Photographic Log

www.oneatlas.com

Pine Street to the South.
west and north, overhead power to the west and diagonally across UST Basin, railroad, and
View of 30,000-gallon UST, facing West, in proximity to cooling towers, loading dock to the 1.
JPS Composite Materials, Inc. ATC Project #199JPS2301
535 Connor Street, Statesville, Iredell County, NC 28677

Photographic Log
www.oneatlas.com

2. View of 30,000-gallon UST, facing East Northeast, in proximity to cooling towers, loading
dock, overhead power running over UST basin, and Pine Street to the South.

Legend
525 Connor St
Jps Composite Materials
100 ft
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