HomeMy WebLinkAbout20064_Simpson Gas_Regulatory file review summary20140422
April 22, 2014
Mr. Ben Lassiter, PhD
Restoration and Monitoring Coordinator
Land Trust for the Little Tennessee
P.O. Box 1148
Franklin, NC 28744-1148
RE: NCDENR File Review
Summary Simpson Oil Company
Dear Mr. Laseter:
Per your request, Martin & Slagle GeoSciences, PA, performed a review of the North
Carolina Department of Environment and Natural Resources (NCDENR) UST Section
file regarding Simpson Oil Company. Following is an index of the contents of the file in
chronological order.
July 17, 1998 – Max (or Mac) Stanfield with the Macon County Health
Department called NCDENR ARO to file a complaint against Simpson Oil
Company indicating that
1. Drains located under the bulk ASTs discharge directly to the Little
Tennessee River.
2. Cleaning fuel trucks directly on to the ground behind the station.
3. Not careful about spills off loading dock.
4. Runoff from washing station runs into storm drain.
September 15, 1998 – NCDENR issues NOV citing an inspection from DWQ that
confirmed evidence of leaking from ASTs. Letter requires Comprehensive Site
Assessment (CSA) within 60 days of notice, with options for alternate schedule
upon request.
November 4, 1998 – Simpson Oil (via Alpha Environmental) requests extension
to deadline for CSA.
November 6, 1998 – NCDENR grants extension to January 28, 1999.
January 8, 1999 – NCDENR receives tables summarizing analytical results of
investigation.
January 20, 1999 – Max Stanfield with Macon County Health Department calls to
inquire about status of Simpson Oil Company investigation. Mr. Stanfield
indicated that he believes there are USTs on site that had not been removed
because there is a propane tank on top of them.
April 22, 2014
Page 2 of 4
January 26, 1999 – Alpha Environmental submits letter to DWQ with a summary
of activities since September.
1. Completed initial sampling
2. Met with State on January 8, 1999
3. Identified several possible up gradient sources of contamination
4. Requests an extension to complete CSA to April 28, 1999
January 27, 1999 – NCDENR grants extension.
February 4, 1999 – Alpha Environmental provides document identifying potential
petroleum contaminant sources surrounding the Simpson Oil site.
1. Commercial Building (believed to be the current location of the retail shop
east of Duncan Oil Co. toward the river) Former paint store with waste oil
tank. Part of building removed when Big Bear Lane connecting East and
Northeast Main Street was built. Alpha incorrectly refers to “West Main
Street”.
2. Duncan Oil Company – notes multiple USTs removed from site in Nov.
1998. Neighbors reported strong odor. No closure report submitted to
NCDENR.
3. Commercial Building – (believed to the property immediately west of
Simpson Oil owned by Huscussons) Indicate two USTs still in ground
noting presence of vent pipes. No fill ports. Closure status unknown.
4. Commercial Building facing “West” (believed to be Northeast) Main
Street. Fuel oil tank in use. No indication if UST or AST.
5. Don’s Texaco – Multiple USTs on site. Closure status unknown.
6. Metal Storage Building (location unknown) Previously a bulk storage area
for Exxon Petroleum
7. Depot Junction – 200-gallon fuel spill early 1997 supposedly washed to
sanitary sewer.
8. Franklin Storm Sewer Pump and Piping.
March 17, 1999 – UST Closure Report – Alpha Environmental submitted closure
report for two USTs removed by Simpson in 1994. Closure report indicates
samples were collected in FORMER UST excavations. Submits results.
March 24, 1999 – Notice of Regulatory Requirements (NORR) sent To Simpson
Oil Company from UST Section instructing Simpson to take additional action.
April 30, 1999 – Telephone LOG Conversation with Mike Kelly who was
following up on a complaint from Senator Carpenter regarding the Simpson Oil
Site. J. A. told him that that LSA had been requested and should be completed
July 24, 1999.
April 22, 2014
Page 3 of 4
September 16, 1999 – Telephone Log – J.A. contacted Robert Moore Alpha
Environmental regarding status of LSA indicating that Raleigh had asked for
more information. Moore indicated that Simpson was waiting on Trust Fund
determination before going forward with investigation.
10-27-99 – Memo from George Mathis Head Trust fund Section to Jan Anderson
requesting additional information on Simpson Site regarding contamination from
ASTs. Memo includes copy of TF Application submitted to STF on May 3, 1999.
Application clearly indicates that USTs were removed in 1994 release confirmed
1999. Memo also indicates that STF attempted to get additional information from
Simpson regarding the release.
December 6, 1999 – e-mail from STF to Jan Anderson requesting additional
information regarding the Simpson Oil site.
February 16, 2000 – E-mail from STF to Jan Anderson again requesting info
Simpson Oil Site.
March 14, 2000 – E-mail from Jan Anderson to STF indicating that there is no
way to distinguish UST release from AST release.
November 28, 2000 – Letter from STF rejecting Simpson application for
eligibility for TF reimbursement.
There is nothing more in the file regarding this issue. Although Ms. Anderson indicated
that the site is a “low risk” site, there is nothing in the file that indicates that the work
required to score the site was ever performed. It appears that Simpson Oil Company
never responded to the NORR issued by NCDENR and that the case file remains open.
May 2010
Apparently contaminated soil was encountered during a sewer line construction project
along North East Main Street near the Simpson Oil Company site. Diesel range organics
were detected in one soil sample at 20.7 mg/kg. Soil was excavated and a temporary
storage permit was issued in August 2010 to store the soil on plastic on the Whitmire
Farm. In a letter dated September 1, 2010, Mountain, Geology, Inc. wrote a letter to
McGill & Associates indicating that the excavated soil was field screened with a
photoionization detector and that “non-contaminated’ soil was returned to the excavation
site. 35-40 tons of contaminated soil was placed in temporary storage.
In a memo sent to Jan Anderson with NCDENR, Paul Higdon, subcontractor for the
county on the construction of the sewer line, indicated that he was including a copy of the
disposal permit application, referencing a letter from Mike Owens that is not included in
the file.
April 22, 2014
Page 4 of 4
On December 14, 2010 a permit was issued for the storage/treatment of 50 cubic yards of
soil or less describing the conditions as follows:
“Soil shall be spread to a thickness of 1” and then shall be seeded with winter rye or
another appropriate crop, and covered with straw.
There is no indication of communication from NCDENR directly with Simpson Oil
Company regarding this matter and no NOV or NORR was issued to Simpson Oil
Company.
If you have any questions or comments regarding the contents of the file, please do not
hesitate to contact us. As always, we appreciate the opportunity to work with you and
LTLT.
Sincerely
Martin & Slagle GeoSciences, PA
Christine Slagle
Principal Scientist
Enclosure