MO-7444_36096_G_C_20190809_Engineering Review of Corrective Action Performance Report

ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
MICHAEL SCOTT
Director
Mr. Joey Cupp
Pilot Fling J
5508 Lonas Road
Knoxville, TN 37939
NORTH CAROLINA
Environmental Quality
August 8, 2019
RE: Correction Action Performance Report
Pilot Station #56
285 Lane Street
Kannapolis, NC
Incident #36096
Dear Mr. Cupp:
The purpose of this correspondence is to respond to the Corrective Action Performance Report for
the remedial actions for the subject site. A petroleum release from an unknown source was
detected on June 13, 2006.
An air sparge (AS) / Soil Vapor Extraction (SVE) system was installed on the site on April 18,
2012. The system consists of 16 AS wells and 3 SVE wells.
A review of the report revealed the following deficiencies:
1. Page I, Section 3, "Information about release", indicates that the release information is all
unknown, but then on page 1, Section 2, a historical narrative the releases at the site are
given.
2. Groundwater flow was indicated as being to the North -Northwest, which is away from any
nearby receptors. In accordance with General Statute 143-215.94Vb, an explanation of
why the residual contamination remaining onsite poses a threat to the upgradient receptors
will need to be provided.
3. The report lacks any detail on the total contaminant mass at the site, the remaining
contaminant mass at the site, or the amount of contaminant mass removed by the system at
the site.
4. A Corrective Performance Report is required to be sealed by a licensed professional
engineer.
NORiH GAROLINA ��� ��
�epa6lronf o1 BNtommMlal mui�
North Carolina Department of Environmental Quality I Division of Waste Management
217 West Jones Street 1 1646 Mail Service Center I Raleigh, North Carolina 27699-1646
919.707.8200

Based upon the information supplied in the July 7, 2019 report, no information was given to show
that the active AS/SVE system was providing any benefit to the site and therefore operation of the
system is to be discontinued until such time as your consultant can provide information supporting
the continued operation. This report, as presented, is incomplete and not reimbursable as it does
not meet the definitions of a performance report.
Please provide a written response to this correspondence within sixty (60) days of the date of the
correspondence making sure to include any and all calculations and/or figures to support any
response. If your response is not received within the 60 days, the UST Section will consider the
report incomplete and non -reimbursable.
Please contact Scott Ryals at 919-707-8168 if you have any questions.
Sincerely,
Scott C. Ryals, CEE, 4((031590)
U ST Section
North Carolina Division of Waste Management
CC by e-mail:
Trudy Beverly, MRO
Robert Wagner, Apex Environmental
William Hunneke, Trust Fund Branch Head
Ron Taraban, MRO Supervisor
Scott Bullock, Corrective Action Branch Head
MO-7444 36096 M DENR 20190809 CAPR Comments

Beverly, Trudy
From: Ryals, Scott
Sent: Friday, August 9, 2019 8:44 AM
To: Beverly, Trudy; Taraban, Ron; Hunneke, William F; Bullock, Scott; Robert
Wagner
Subject: Engineering Review of Corrective Action Performance Report
Attachments: SKM_45819080908381.pdf
Please see the attached review of the July 2019 Corrective Action Performance Report.
.. . ......
PE
NORTH OAROI IN
Department of Environmental quality
Scott Ryals, PE, CEE
Environmental Engineer, Waste Management, UST
North Carolina Department of Environmental Quality
919.707-8168 (Office)
919.707-8168 (Fax)
Sc ott.ryals@ncdenr,gov
Ernad coffespondence to arrd from this address is subiect to the
North Carolina AJbIic Records Law and may be cftsclosed to th►mparties.