WS-10181_45313_G_NORR_20210423_ARA

April 23, 2021

McCleod Oil Company
Michael Thompkins, RA
P.O. Box 100
Mebane, NC 27302

Re: Notice of Regulatory Requirements
15A NCAC 2L .0407< Select Rule by Risk >
Risk-based Assessment and Corrective Action
for Petroleum Underground Storage Tanks

West 70 Curb Market
110 Woodlawn Road, Mebane
Alamance County
Incident Number: 45313
Risk Classification: Intermediate
Ranking: I130D

Dear Mr. Thompkins:
The Limited Site Assessment Report received on February 15, 2021 has been reviewed by the UST Section,
Division of Waste Management, Winston-Salem Regional Office. The review indicates groundwater
contamination exceeds the groundwater quality standards established in Title 15A NCAC 2L .0202 The risk
posed by the discharge or release at the subject site is classified by the Department of Environmental Quality
as intermediate, as stipulated under Title 15A NCAC 2L .0406. The land use at the site is classified as
industrial/commercial. Please note that Title 15A NCAC 2L .0407(a) requires you to notify the Department
of any changes that might affect the risk or land use classifications that have been assigned.
Title 15A NCAC 2L .0407(c) [Intermediate Risk] requires you to comply with the assessment and cleanup
requirements of Title 15A NCAC 2N .0706 and Title15A NCAC 2L .0106(c) and 2L .0106(g). Failure to
comply in the manner and time specified may result in the assessment of civil penalties and/or the use
of other enforcement mechanisms.
Typically, a Comprehensive Site Assessment (CSA) Report prepared in accordance with these requirements
and the most recent version of the Guidelines for Assessment and Corrective Action for UST Releases
submitted to this office within 90 days of the date of this notice would satisfy this requirement. Alternatively,
an extension to this deadline may be obtained through the completion and submittal of a Risk Assessment
Report within 90 days of this notice. This report supplements the LSA through the assessment of groundwater

characteristics and the risk to nearby receptors. Specifically, the Risk Assessment Report should include, at a
minimum:
• The installation of three horizontal extent monitoring wells and one vertical extent
monitoring well. One monitoring well shall be installed upgradient of the source of
contamination and two monitoring wells shall be installed downgradient of the source of
contamination, as best as can be determined, and located such that groundwater flow
direction and hydraulic gradient may accurately be determined. The vertical extent
monitoring well shall be installed immediately downgradient of the source area of
contamination, as best as can be determined, with any drilling greater than a depth of 75 feet
requiring authorization from the regional office incident manager. Note, the vertical extent
monitoring well must not connect aquifers.
• The analysis of representative soil samples collected during the construction of the
monitoring wells. One soil sample must be collected in the unsaturated zone and one in the
smear/saturated zone from suspected worst-case locations exhibiting visible contamination
or elevated levels of volatile organic compounds based on field screening techniques. Only
the suspected most contaminated soil sample in each zone from each boring should be
submitted for laboratory analysis using the EPA 8015B TPH (or equivalent) appropriate for
the fuel types suspected in the release.
• The collection of groundwater samples from the new monitoring wells, analyzed by the
appropriate method(s) for the constituents relevant to the release.
• The collection of groundwater samples from any onsite water supply wells and any water
supply wells located adjacent to the site less than 250 feet from the source area of the release,
analyzed by the appropriate method(s) for the constituents relevant to the release. Sampling
of more than 5 water supply wells will require approval of the regional office incident
manager.
• The survey of all monitoring wells and collection of potentiometric data for the completion
of a potentiometric surface / groundwater elevation and flow map.
• The completion of one aquifer slug test in a representative well to provide a calculation of
hydraulic conductivity, transmissivity, and linear groundwater velocity.
Because a release or discharge has been confirmed, a Licensed Geologist or a Professional Engineer, certified
by the State of North Carolina, is required to prepare and certify all reports submitted to the Department in
accordance with 15A NCAC 2L .0103(e) and 2L .0111(b).
Effective October 1, 2004, the Department of Environmental Quality 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 for a CSA, a completed Preapproval/Claim Authorization Form, encompassing the
required comprehensive assessment activities must be received in this office within 14 days of the date of this
letter.
However, as the Risk Assessment Report qualifies as an exempted scope of work, written preapproval is not
required to complete the activities described above, as documented under Task 2.610 in the 2020 Reasonable
Rate Document, Version dated August 1, 2020. Upon completion of any eligible activities, you should submit
your claim promptly. Reimbursement funds are budgeted based on completed preapprovals, but delays in

reimbursement or even denial due to exceeding the statute of limitations on claiming eligible costs can result
where claims are not submitted immediately following work completion.
Please note that before you sell, transfer, or request a “No Further Action” determination for a property that
has not been remediated to below “unrestricted use” standards, you must file a Notice of Residual Petroleum
("Notice") with the Register of Deeds in the county where the property is located (NCGS 143B-279.9 and
143B-279.11).
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 any questions regarding the actions that must be taken or the rules mentioned in
this letter, please contact me at the address or telephone number listed below.
Sincerely,

Karen J. Hall
Environmental Sr. Specialist
Winston-Salem Regional Office
UST Section, Division of Waste Management, NCDEQ

Attachments: Title 15A NCAC 2L .0407
UST Section Memo 02/01/2019 – 2020 RRD Task 2.610

cc: Alamance County Health Department via email
Progress Environmental, Mr. Jeff Balsieper, via email