WS-3058_8695_E_NOV_20221207_GMR

December 7, 2022
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
7019 0700 0000 3642 9806

Attn: Kelly Lettmann, Registered Agent
For BFI Waste Systems of N.A., LLC
CT Corporation System
160 Mine Lake Ct., Suite 200
Raleigh, NC 27615

Re: Notice of Violation of 15A NCAC 2L .0400
Risk-based Assessment and Corrective Action
for Petroleum Underground Storage Tanks

Browning-Ferris Service, Inc
2901 Manufacturers Rd
Greensboro, Guilford County
Incident number: 8695
Risk Classification: I-90R

Dear Ms. Lettmann:

Information received by this office of the UST Section, Division of Waste Management, on June 19, 1992
confirms a release or discharge from a petroleum underground storage tank (UST) system at the above-
referenced location. Records indicate that you were the owner or operator of this UST system. This letter
explains the violation(s) and associated corrective action(s) you must take as a result of the release or
discharge in accordance with North Carolina statutes and rules. The UST Section, Division of Waste
Management, administers the state's rules for USTs and the required response for petroleum releases. Those
rules are located in Title 15A, Subchapter 2L and Title 15A, Subchapter 2N of the North Carolina
Administrative Code (NCAC).

VIOLATION 1:
Failure to submit a Monitoring Report to the UST Section in accordance with Title 15A NCAC 2L .0407(c),
2L .0110, and 2L .0111.

REQUIRED CORRECTIVE ACTION:
Based on the determination that the risk posed by the discharge or release at the subject site is intermediate,
you must comply with assessment requirements pursuant to Title 15A NCAC 2L .0407(c), 2L .0110 and
2L .0111. Please submit a Monitoring Report in accordance with Title 15A NCAC 2L .0407(c), 2L .0110,
and 2L .0111, and the most recent version of the UST Section Corrective Actions Guidelines. The
Monitoring Report must be received by this office within 30 days of the date of receipt of this notice.

Page 2 of 2

VIOLATION 2:
Failure to file a Notice of Residual Petroleum (Notice) with the Register of Deeds in Guilford County and
then to submit a certified copy of the filed Notice to the Winston-Salem Regional Office in accordance with
North Carolina General Statute (NCGS) 143B-279.9 and 143B-279.

REQUIRED CORRECTIVE ACTION:
Since the subject site has not been remediated to below “unrestricted use standards,” you were required to
file a Notice of Residual Petroleum (Notice) with the Register of Deeds in Guilford County and then to
submit the certified copy of the filed Notice to the Winston-Salem Regional Office. You must submit a
certified copy of the recorded Notice to this office within 30 days of receipt of this letter.

Please take the corrective action(s) for the above violation(s) as necessary to bring the site into compliance.
Corrective actions must be taken and reported to the Winston-Salem Regional Office, within 30 days from
the date of this notice, unless otherwise noted in the above corrective actions, to avoid recommendation of
civil penalties for continuing violations.

Penalties may be assessed for the violation(s) described within this Notice of Violation. Your prompt
attention to the items described herein is required. Failure to comply with the State's rules, in the manner
and time specified, may result in the assessment of additional civil penalties and/or the use of other
enforcement mechanisms available to the State. Each day that a violation continues may be considered a
separate violation.

Please note that performing assessment and cleanup work that is not required under 15A NCAC 2L .0400
is not reimbursable from the Commercial Leaking Petroleum Underground Storage Tank Cleanup Funds.

If you have any questions regarding the actions that must be taken or the rules mentioned in this letter,
please contact Ashley Dinkins at the Guilford County Department of Health and Human Services, 400 W.
Market Street, Suite 300, Greensboro, NC 27401 or [phone]. If you have any questions regarding
trust fund eligibility or reimbursement, please contact the UST Section Trust Fund Branch at (919) 707-
8171.

Sincerely,

James W. Brown
Regional Supervisor
Winston-Salem Regional Office
UST Section, Division of Waste Management, NCDEQ

cc: Allied Waste North America, Inc.
18500 North Allied Way
Phoenix AZ 85054-6164