MO-7444_36096_G_NORR_20190816_Notice of Regulatory Requirements

ROY COOPER NORTH CAROLINA
Governor Environmental Quality
MICHAEL S. REGAN
Secretary
MICHAEL SCOTT
Director
August 16, 2019
Pilot Travel Centers LLC
Attn: Joey Cupp
5508 Lonas Drive
Knoxville, TN 37909
(via email)
Re: Notice of Regulatory Requirements
15A NCAC 2L .0407(b)
Risk -based Assessment and Corrective Action
for Petroleum Underground Storage Tanks
Pilot Travel Center #056
2825 Lane Street, Kannapolis
Cabarrus County
Incident Number: 36096
Risk Classification: High
Dear Mr. Cupp:
The purpose of this correspondence is to respond to the Corrective Action Performance Report
for Pilot Travel Center #056. Corrective Action Monitoring and Action Performances reports should be
submitted in accordance with the most recent revised monitoring report template "Corrective Action
Performance Report" (Task 6.105/6.106). See the 4/18/2017 section of the following link for revised
monitoring report templates https://deq.nc.gov/about/divisions/waste-management/ust/whats-new#2017.
Corrective Action Monitoring and Corrective Action Performance reports are separate reports.
Corrective Action Monitoring Reports requirements are defined in Template 9A. Corrective Action
Performance Reports requirements are defined in Template 9B. Reports failing to be submitted in
accordance with the most recent template requirements are considered incomplete.
The UST Section, Division of Waste Management (DWM), Mooresville Regional Office (MRO)
received the July 9, 2019 Corrective Action Performance Report on July 12, 2019. The July 9, 2019
Correction Action Performance Report is incomplete. See the August 8, 2019 letter from Scott Ryals for
details.
North Carolina Department of Environmental Quality I Division of Waste Management
Mooresville Regional Office 1 610 East Center Avenue, Suite 301 1 Mooresville, North Carolina 28115
704.663.1699

A Corrective Action Monitoring Report was not received. Please note the following monitoring
report requirements:
• Site History and Characterization —
Provide information on owners and occupants of property within or adjacent to area containing
contamination or the area where contamination is expected to migrate and describe land use. Refer
to tables (Use Table B-6, Property Owners/ Occupants; and Table B-10, Land Use) and refer to
land use map.
Present information on receptors/potential receptors.
Refer to table (Use Table B-5, Public and Private Water Supply Well and other Receptor
Information;) and to potential receptor map that clearly identifies water supply wells (municipal or
public/private wells, etc.) and other potential receptors (surface water bodies, basements, utilities,
wellhead protection areas, etc.) within 1500' of the source of the release.
Describe current proximity of plumes to potential receptors.
Present current information on the provision of bottled water or on the connection of properties to
municipal water.
• Add the groundwater flow direction to the topographic map
• A site map* and cross -sections illustrating the UST system(s), drawn to scale, should show:
Buildings and property boundaries;
Streets, roads, highways (labeled);
Underground utilities, such as sewer lines and other conduits; basements; and vaults;
Water supply wells, surface water bodies;
Location and orientation of current and former UST(s), pumps, product lines,
sumps, etc.;
Length, diameter and volume of current and former UST(s);
Type of material(s) stored in UST(s) (currently and formerly); and
North arrow and scale.
Map(s)* and geological cross -sections, drawn to scale, depicting all soil analytical results obtained
to date, to include:
Description of soil and bedrock lithology (as determined by investigation to date);
Location and orientation of UST(s)/AST(s), pumps, piping, sumps, etc. (current and former), any
known spills, and (if applicable) illustrating any excavation dimensions or remediation system
components;
Soil sample identification (unique letter and/or numerical code), location, and depth;
Soil sample analytical results;
Date soil sample collected;
Final limits of each stage of excavation for each excavation on site;
A general plan depicting the footprint of any soil remediation system installed on site; and
Two geological cross -sections, drawn across the contaminated area and intersecting at right angles,
showing the vertical distribution of the contaminants in the unsaturated zone. (Indicate vertical and
horizontal scale, orientation of each section, location of water table, soil types and lithology, all
borings and sample locations represented by the sections, and soil analytical results for each
represented sample, and show sections as labeled lines on the map.)
Map, drawn to scale, depicting the groundwater and surface water analytical results, should include:
Location and orientation of UST(s), pumps, piping, sumps, etc. (current and former);
Groundwater sample identification (unique letter and/or numerical code referencing monitoring or
water supply well) and location;
Date of sampling;
Surface water sample identification (unique letter and/or numerical code) and location; and
Groundwater and surface water sample analytical results.
D 1E
North Carolina Department of Environmental Quality I Division of Waste Management
Mooresville Regional Office 1 610 East Center Avenue, Suite 301 1 Mooresville, North Carolina 28115
704.663.1699

Mr. Ryals requested that operation of the treatment system be discontinued until such time as your
consultant can provide information supporting continued operation. At present, the Corrective Action
Performance report is incomplete and no Monitoring report was submitted. Please provide the materials
needed to complete the Corrective Action Monitoring and Corrective Action Performance reports within
sixty (60) days of the date of this letter. Include text and/or figures for support.
Please note that sampling and correction action must be conducted in accordance with the
Guidelines for Assessment and Corrective Action for UST Releases. Failure to comply in the manner and
time specified may result in the assessment of civil penalties and/or the use of the other enforcement
mechanisms.
If you have any questions regarding trust fund eligibility or reimbursement from the Commercial
or Noncommercial Leaking Petroleum Underground Storage Tank Cleanup Funds, 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 by email at Trudy.Beverlykncdenr.gov or
telephone at [phone].
Sincerely,
� qI 4
Trudy Beverly, L.G.
Hydrogeologist
Mooresville Regional Office
UST Section, Division of Waste Management, NCDEQ
cc: Robert Wagner, Apex Companies, LLC (via email)
Scott Ryals, UST Section, Trust Fund Branch (via email)
David Troutman, Cabarrus County Health Department (via email)
Mike Downs, Cabarrus County Manager (via email)
D F.
North Carolina Department of Environmental Quality I Division of Waste Management
Mooresville Regional Office 1 610 East Center Avenue, Suite 301 1 Mooresville, North Carolina 28115
704.663.1699

Beverly, Trudy
From: Robert Wagner < [e-mail] >
Sent: Friday, August 16, 2019 2:17 PM
To: Beverly, Trudy; Joey Cupp; Keith Carlton
Cc: Mike Downs; David Troutman; Ryals, Scott
Subject: [External] RE: [EXT] Pilot Travel Center #056 - Incident #36096 — Notice of
Regulatory Requirements
• xternal email. Do not click links or open attachments unless you verify. Send all suspicious email as an
report.soam(@nc.Eov
Trudy
Thanks for the email.
I have received Scott's letter as well and we are currently working on updating the performance report.
In discussions with Pilot, the near term goal is to get the site reduced to intermediate risk and get a Notice of
Residual Petroleum recorded for the site to limit groundwater use and development other than
commercial/industrial.
The remediation system was deactivated on Wednesday August 14 per Scott's letter.
We believe area groundwater users are not at risk, based on over a decade of monitoring with no impact, the
direction of groundwater flow, and current dissolved -phase concentrations.
The revised performance report will discuss this in further detail in an attempt to reduce the ranking and move
towards a NORP.
Please let me know if you have any questions in the meantime or need anything additional to get this site to
closure with the NORP.
Thanks,
Robert
Robert Wagner
Sr Program Manager
7724 Garland Cir
Roanoke, VA 24019
1) 540-563-4920 Y4451 M) 540-798-1494
APEX
a Add me to your contact list!
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ENR Top 30 All -Environmental Firm IM CID
We've moved! Our new address is 7724 Garland Cir, Roanoke, VA 24019. Please update your contact
list. Thanks.
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From: Beverly, Trudy <[e-mail]>
Sent: Friday, August 16, 2019 1:44 PM
To: Joey Cupp <[e-mail]>
Cc: Robert Wagner <[e-mail]>; Mike Downs <[e-mail]>; David Troutman
<[e-mail]>; Ryals, Scott <[e-mail]>
Subject: [EXT] Pilot Travel Center #056 - Incident #36096 — Notice of Regulatory Requirements
CAUTION
Please see the attached Notice of Regulatory Requirements letter for Pilot Travel Center #056 located at 2825
Lane Street, Kannapolis, Cabarrus County, North Carolina (Incident #36096).
Trudy
GhQlriiYYSnI of CuavwYil�IllEl OualYly
Trudy Beverly, L.G.
Hydrogeologist, Division of Waste Management
North Carolina Department of Environmental Quality
UST Section, Mooresville Regional Office
704.235.2182 (Office)
Trudy. Beverlykncdenr. gov
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.
Office Mailing Address:
610 East Center Avenue, Suite 301
Mooresville, NC 28115
Branch's Underground Storage Tanks Website Address: https://deq.nc.gov/about/divisions/waste-management/ust
Branch's Above Ground Storage Tanks Website Address: hops://deg.nc.Rov/about/divisions/waste-management/ust/ast-proeram
INTERACTIVE MAPS WITH DWM SITES AND PERMITTED FACILITIES:
https://deq.nc.gov/about/divisions/waste-management/waste-mana,¢ement-rules-data/waste-management ig s=mats
File Review Procedures:
https://deq.nc. gov/about/divisions/waste-management/ust/file-review-procedures#mooresville-regional-office
ONLINE ACCESS TO UST SECTION DOCUMENTS (Laserfiche):
https://cdocs.deq.nc. gov/WasteManagement/Search.astx
Document Submittal & UST File Names for Laserfiche Policies:
hops://files.nc.gov/ncdeq/Waste%2OManagement/DWMIUST/Corrective%2OAction/Electronic%2ODocument%2OSubmittal%2OMemo%2OUpdate.pdf
https://files.nc. gov/ncdeq/Waste%20Management/DWM/UST/Corrective°/`2OActionfUST%20file%20names%20for%2OLaserfiche.docx
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