WS-9333_44564_G_NORR_20221216_ROD

December 16, 2022 Gandhi & Associates, LLC
Attention: Mr. Dilip Gandhi
9201 Leesville Road, Suite 201 Raleigh, North Carolina 27613
Re: Notice of Regulatory Requirements 15A NCAC 2L .0407(c)
Risk-based Assessment and Corrective Action for Petroleum Underground Storage Tanks
Eagle Food Mart 2
3767 Boywood Road
Graham, Alamance County
Incident Number: 44564
Risk Classification: High
Ranking: H342R

Dear Mr. Gandhi: The Corrective Action Feasibility Study received on May 7, 2021, the Groundwater Monitoring Report
received on August 1, 2022, and the Proposed Klozur CR Injection Points 50 map received on December
16, 2022 have been reviewed by the UST Section, Division of Waste Management, Winston-Salem
Regional Office.
The plan in the Corrective Action Feasibility Study and proposed injection points are hereby approved.
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.
If coverage under the Leaking Petroleum Underground Storage Tank Cleanup Fund (Fund) has been
previously granted or is anticipated, additional steps must be taken before this plan is implemented to avoid
a potential loss of coverage. To help ensure cost effective implementation of any Corrective Action Plan,
a Record of Decision, in accordance with the UST Section Corrective Action Guidelines and the applicable
State Trust Fund Reasonable Rate Document, must first be prepared in coordination with the UST Section,
documenting the soil and groundwater cleanup goals and scheduled milestones that will be used to evaluate
the effectiveness of this remediation strategy. A failure to obtain this Record of Decision will jeopardize
any future reimbursement of cleanup costs from the Fund.
Additionally, effective October 1, 2004, 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 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 required Record of Decision task, must be received in this office within 14 days of the
Page 2 of 2

date of this letter. Upon completion of the preapproved activities, you should submit your claim promptly.
Reimbursement funds are budgeted based on completed preapprovals. Delays in reimbursement or even
denial due to exceeding the statute of limitations on claiming eligible costs can result where 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,
Mindy Lepard Hydrogeologist Winston-Salem Regional Office
UST Section, Division of Waste Management, NCDEQ

cc: Alamance County Health Department, via email, [e-mail]
Mr. Raj Shah, Agra Environmental, Inc., via email, [e-mail]