WA-921_11941_G_NORR_20200319_SA 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 19, 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
Red Apple Market #1 / A&A Texaco
100 West / 100 East Main St, Harrellsville, NC
Hertford County
Incident Number: 11941 / 13418
Risk Classification: High
Ranking: H 234 D
Dear Mr. Simonsen:
The UST Section, Division of Waste Management, Department of Environmental Quality
(Department) is in receipt of the Ground Water Monitoring Report dated December 18, 2019, which
documents the results from a limited ground water sampling event on December 3, 2019.
During this most recent sampling event, concentrations of petroleum constituents in the
groundwater were detected in multiple monitoring wells above the cleanup standards defined in Title 15A
of the North Carolina Administrative Code (NCAC) Subchapter 2L .0202. This site is designated as High
Risk due to the presence of non-potable supply wells within 250 of the source area at RAM #1 and the
historic detection of non-aqueous phase liquids (NAPL) in wells onsite, representing contaminant levels
above the applicable Gross Contaminant Levels (GCLs) from 15A NCAC 2L .0406(2).
For the first event since 2012 NAPL was found at a measurable thickness in monitoring wells at
these sites, being detected in MW-3 and MW-10 during this event. This coincided with water level depths
that were slightly lower than typically seen onsite, indicating potential intermittent drought conditions may
have affected the movement of NAPL in the subsurface. This may be related to the presence of a sandy
layer recorded in drilling logs at approximately 16-17 feet below ground surface onsite.
A sampling event evaluating the levels of NAPL in should be scheduled for the 3rd quarter
of 2020, with attempts made to conduct the sampling during a similar drought/dry period, if possible.
The event should target gauging all onsite wells with historic detections of NAPL: MW-1, MW-2,
MW-3, MW-9, MW-10, RW-1, and AMW-4. If NAPL is not detected in these wells, sampling should
target those historic-NAPL wells that do not have dissolved-phase data from the most recent sampling event
to evaluate constituent levels in comparison to the GCLs: MW-2, MW-3, MW-10, RW-1, and AMW-4.
The laboratory analysis for these wells should capture the extended volatile organic compound analyte list,
including MTBE, IPE, EDB, and naphthalene, as well as ethanol and the alternate oxygenate/daughter list:
ETBE, TAME, TAA, TBA, and TBF.
Additionally, considerable effort should be made to access and resample groundwater from the two
primary at-risk supply wells, WSW-1 and WSW-9. A report documenting the monitoring well gauging and
groundwater sampling event should be 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]