WA-1141_13374_G_NORR_20200320_MRP RQST

ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
MICHAEL SCOTT
Director

State of North Carolina | Environmental Quality | Waste Management
Washington Regional Office | 943 Washington Square Mall | Washington, NC 27889 | [phone]
March 20, 2020
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(c) [Intermediate Risk]
Risk-based Assessment and Corrective Action
For Petroleum Underground Storage Tanks
Gurganus Mobil
277 US Highway 64 West, Plymouth, NC
Washington County
Incident Number: 13374
Risk Classification: Intermediate
Ranking: I 185 D
Dear Mr. Simonsen:
The UST Section, Division of Waste Management, Department of Environmental Quality
(Department) is in receipt of the Soil Excavation and Ground Water Monitoring Report dated February 17,
2020, which documents the results of a targeted excavation in November 2019 and a limited ground water
sampling event on January 27, 2020.
The limited excavation targeted non-aqueous phase liquids (or NAPL) trapped in the soil above
and just below the top of the water table in what is known as the ‘smear zone’. Approximately 736.14 tons
of highly contaminated soil was removed during this event.
The subsequent groundwater sampling event found no measurable NAPL in the replacement
monitoring wells installed in the excavation footprint for the first time since April 2008. Sampling at each
of the new wells did document concentrations of petroleum constituents dissolved in the groundwater above
the cleanup standards defined in Title 15A of the North Carolina Administrative Code (NCAC) Subchapter
2L .0202. However, only MW-3R and MW-4R demonstrated dissolved concentrations at levels that were
above the Intermediate Risk classification thresholds defined in Title 15A NCAC 2L .0406(2). As such,
this site remains Intermediate Risk.
A gauging and groundwater sampling event to evaluate NAPL rebound and/or dissolved
phase concentrations for at least the four replacement wells should be scheduled in the 3rd quarter
of 2020, with a report submitted no later than October 31, 2020.
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. 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: North East Oil Co, Inc. - Mr. Lars Simonsen, Registered Agent (electronic copy)
Geological Resources, Inc., Mr. William Regenthal (electronic copy)
Washington Regional Office | 943 Washington Square Mall | Washington, NC 27889 | [phone]