WS-3727_12188_G_NORR_20230110_CA Design NORR

North Carolina Department of Environmental Quality | Division of Waste Management
Winston-Salem Regional Office | 450 West Hanes Mill Road | Suite 300 | Winston-Salem, NC 27105 | [phone]

January 10, 2023

Paul T. Hendrick
Beroth Oil Company
723 Coliseum Dr., Ste. 101
Winston-Salem, NC 27106

Re: Notice of Regulatory Requirements
15A NCAC 02L .0407(d)
Risk-based Assessment and Corrective Action
for Petroleum Underground Storage Tanks

Jonesville Amoco-B
428 N. Bridge Street
Jonesville, Yadkin County
Incident Number: 12188
Risk Classification: Intermediate
Ranking: 195

Dear Mr. Hendrick:

The Corrective Action Feasibility Study (CA FS) received on September 26, 2022 has been reviewed by
the UST Section, Division of Waste Management, Winston-Salem Regional Office. Based upon this
review, it has been determined that a Corrective Action (CA) Design, in accordance with the most recent
version of the UST Section Corrective Action Guidelines and the applicable State Trust Fund Reasonable
Rate Document, needs to be submitted. It has also been determined that the following modifications, to the
proposed actions in the CA FS, needs to be incorporated into the CA Design:
1.) Design the dual phase remediation system without an oxidizer and reduce the air flow during the
earlier part of the remediation system operation to remain within allowable vapor concentrations.
a. Estimate the operation and maintenance cost by adding an additional year of active
remediation to compensate for the reduced air flow and contaminant removal levels during
the beginning part of the system operation.
2.) Make the following modifications to the sampling, operation, and maintenance schedule:
a. Sample seven monitoring wells per sampling event. Include a trip blank.
b. After the first quarter of active remediation, during the quarters that the remediation system
is running:
i. Use six hours of scheduled maintenance per month.
ii. Do semi-annual sampling.
iii. Include one mobilization and one per diem per month.
iv. Include periodic measurement of free product.
c. Do semi-annual sampling during the last year of natural attenuation.

Page 2 of 2 Incident Number: 12188 January 10, 2022

North Carolina Department of Environmental Quality | Division of Waste Management
Winston-Salem Regional Office | 450 West Hanes Mill Road | Suite 300 | Winston-Salem, NC 27105 | [phone]

Failure to implement the plan and schedule in the manner and time specified may result in the
assessment of civil penalties and/or the use of other enforcement mechanisms.
Because a release or discharge has been confirmed, a Licensed Geologist or a Professional Engineer,
certified by the State of North Carolina, is required to prepare and certify all reports submitted to the
Department in accordance with 15A NCAC 02L .0103(e) and 02L .0111(e).
Any CA Design incorporating engineering practices must be sealed by the professional engineer who
developed the remediation system design, as required by 15A NCAC 02L .0103(e).
The Department of Environmental Quality 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
02L .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
necessary to complete the CA Design, must be received in this office within 14 days of the date of this
letter. Upon completion of preapproved activities that define an individual step within the Corrective Action
Plan process, 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 of
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 any questions regarding the actions that must be taken or the rules mentioned
in this letter, please contact me at the address or telephone number listed below.

Sincerely,
Linda Estkowski Hydrogeologist Winston-Salem Regional Office
UST Section, Division of Waste Management, NCDEQ

cc: Kevin R. Beroth, Beroth Oil Company, P.O. Box 4089, Winston-Salem, NC 27115
Cherie Cranfill, Yadkin County Health Department, via email [e-mail]
Ryan Kerins, Terraquest Environmental Consultants, P.C., via email [e-mail]