WA-921_11941_G_NORR_20220330_SA MRP CAP RQST

ROY COOPER Governor
ELIZABETH S. BISER
Secretary
MICHAEL SCOTT
Director

North Carolina Department of Environmental Quality | Division of Waste Management | UST Section
Washington Regional Office | 943 Washington Square Mall | Washington, NC 27889 | [phone]
March 30, 2022
North East Oil Company, Inc
c/o Lars Simonsen, Registered Agent
Post Office Box 848
Edenton, NC 27932
Re: Notice of Regulatory Requirements
15A NCAC 2L .0407(d) [Intermediate Risk]
Risk-based Assessment and Corrective Action
For Petroleum Underground Storage Tanks
Red Apple Market #1 / A&A Texaco
100 W. Main St. / 100 E. Main St., Harrellsville
Hertford County
Incident Numbers: 11941 / 13418
Risk Classification: High
Ranking: H 234 D
Dear Mr. Simonsen:
The Underground Storage Tank (UST) Section, Division of Waste Management, Department of
Environmental Quality (Department) has received a Ground Water Monitoring Report dated March 7, 2022,
which documents the results from a limited ground water sampling event onsite on January 27, 2022.
During this most recent sampling event, concentrations of petroleum constituents in the
groundwater were detected in multiple monitoring wells above the cleanup standards defined in Title 15A
of the North Carolina Administrative Code (NCAC) Subchapter 2L .0202. This site remains designated as
High Risk due to the presence of non-potable supply wells within 250 feet of the release.
Non-aqueous phase liquid (NAPL, or free product) was reportedly not detected at a measurable
thickness in any of the monitoring wells for the third consecutive event. However, monitoring well MW-10,
which previously demonstrated measurable NAPL most recently in December 2019, was reportedly not
gauged or sampled during this event.
The next sampling event, including NAPL gauging, should be scheduled for the 3rd quarter of 2022,
with a report documenting the results submitted no later than October 31, 2022.
The event should include gauging all onsite wells with historic detections of NAPL: MW-1, MW-2,
MW-3, MW-9, MW-10, RW-1, and AMW-4. If NAPL is not detected in these wells, sampling should
target those same historic-NAPL wells and sufficient peripheral wells to ensure protection of nearby water
supply wells. Additionally, at-risk supply wells WSW-1 and/or WSW-9, and any other supply wells
potentially threatened by the release, should also be sampled.
Effective October 1, 2004, the Department requires that all work not determined to be an emergency
response or associated with risk assessment (i.e., the Limited Site Assessment Report, per Title 15A NCAC
2L .0405) must be preapproved if State Trust Fund reimbursement is anticipated. To comply with this
requirement, a completed Preapproval/Claim Authorization Form encompassing the scope of work
described above must be received in this office prior to the start of any tasks for which you intend to seek
reimbursement.
Recent reports have also recommended the implementation of the existing 2004 Corrective Action
Plan (CAP) as a viable remedial strategy. Unless the abandonment of all at-risk receptors can be
accomplished, allowing for risk reclassification, this proposal would require the submittal of a preapproval
request for Task 6.066 - CAP Design describing the proposed scope of work based on the 2004 CAP with
any modifications necessary based on current site conditions, or Task 1.010 – Request for Bid if no changes
are needed, for a formal evaluation of the proposed strategy by the Department.
Please note that any remedial strategy that incorporates a designed mechanical system will
require all applicable documents be completed and sealed by a North Carolina Professional Engineer.
Upon completion of any preapproved activities, you should submit your claim promptly.
Reimbursement funds are budgeted based on completed preapprovals, but delays in reimbursement or even
denial due to a failure to meet the statute of limitations on claiming a completed task can result if the work
is not completed in a timely fashion or if claims are not submitted immediately following work completion.
If you have any questions regarding trust fund eligibility or reimbursement from the Commercial
Leaking Petroleum Underground Storage Tank Cleanup Fund, please contact the UST Section Trust Fund
Branch at [phone]. If you have questions regarding the information contained in this letter, please
contact me at the address or telephone number listed below.

Sincerely,

Jared M. Edwards
Hydrogeologist
Washington Regional Office
UST Section, Division of Waste Management, NCDEQ

cc: Geological Resources, Inc. - Mr. William Regenthal (electronic copy)
Washington Regional Office | 943 Washington Square Mall | Washington, NC 27889 | [phone]