FA-92637_96691_G_NORR_20230222

North Carolina Department of Environmental Quality | Division of Waste Management
Fayetteville Regional Office | 225 Green Street | Suite 714 | Systel Building | Fayetteville,
NC 28301 | [phone]

February 22, 2023

Mr. William Johnson
Raeford Oil Company
P.O. Box 430
Raeford, NC 28376

Re: Notice of Regulatory Requirements
15A NCAC 2L .0507(d)
Risk-based Assessment and Corrective Action for
Aboveground Storage Tanks and Other Petroleum Sources

Raeford Oil Bulk Plant
609 W. Prospect Avenue
Raeford, Hoke County
Incident Number: 96691
Risk Classification: High
Ranking: H-270-A

Dear Mr. Johnson:

The UST Section is in receipt of the Free Product Recovery Report, dated January 24, 2023. This office requests that
you continue with free product recovery efforts while also completing the required assessment for the submittal of a
Comprehensive Site Assessment (NORR dated 12/1/2022).

For the Comprehensive Site Assessment, it is important that you obtain vertical soil data from within the free product
plume and potential source zones. Please include vertical soil borings with TPH analytical data collected from the
unsaturated and smear zones to acquire contaminant mass data from within the free product plume. This data will
greatly assist with decisions towards a remedial strategy and free product recovery. 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,

Kenneth E. Currie
Hydrogeologist
Fayetteville Regional Office
UST Section, Division of Waste Management, NCDEQ

Attachment: Notice of Regulatory Requirements dated December 1, 2022

c: Mr. Kirk B. Pollard, P.G., Mineral Springs Environmental, P.C., Raleigh, NC (email copy)
FRO Digital Incident File #96691

North Carolina Department of Environmental Quality | Division of Waste Management
Fayetteville Regional Office | 225 Green Street | Suite 714 | Systel Building | Fayetteville,
NC 28301 | [phone]

December 1, 2022

Attn: Ms. Joy Tompkins
Raeford Oil Company, Inc.
P.O. Box 430
Raeford, NC 28376

Re: Notice of Regulatory Requirements
15A NCAC 02L .0507(d) [High Risk]
Risk-based Assessment and Corrective Action
For Petroleum Underground Storage Tanks

Raeford Oil Company Bulk Plant
609 W. Prospect Avenue
Raeford, Hoke County
Incident Number: 96691
Risk Classification: High
Ranking: H-270-A

Dear Ms. Tompkins:

The Limited Site Assessment Report received on November 2, 2022, has been reviewed by the UST
Section, Division of Waste Management, Fayetteville Regional Office. The risk posed by the discharge or
release at the subject site is classified by the Department of Environmental Quality as high, as stipulated
under Title 15A NCAC 02L .0506. The land use at the site is classified as residential. Title 15A NCAC
02L .0507(a) requires you to notify the Department of any changes that might affect the risk or land use
classifications that have been assigned.
Title 15A NCAC 02L .0507(d) [High Risk] requires you to comply with the assessment and cleanup
requirements of Title 15A NCAC 02N .0706 and Title15A NCAC 02L .0106(c) and 02L .0111(b). A
Comprehensive Site Assessment (CSA) Report prepared in accordance with these requirements and the
most recent version of the UST Section Assessment Guidelines must be received by this office within 90
days of the date of this notice. In addition, you must submit a summary of the CSA Report to the local
Health Director and the local Chief Administrative Officer in accordance with 15A NCAC 02L .0114. The
summary should be submitted to these persons no later than five working days after submittal of the CSA
Report to this office.
NOTE: Title 15A NCAC 02L .0504(2) requires the responsible party to investigate and begin recovery of
any non-aqueous phase product as soon as possible. It is understood recovery efforts have been taken and
recovery should continue. Given the length of time it will take to prepare a CSA Report, you are requested
to provide product recovery details in a Free Product Recovery Report due on or before January 31, 2023.
Failure to comply in the manner and time specified may result in the assessment of civil penalties
and/or the use of other enforcement mechanisms.
Page 2 of 2
Incident Number 96691
December 2, 2022

North Carolina Department of Environmental Quality | Division of Waste Management
Fayetteville Regional Office | 225 Green Street | Suite 714 | Systel Building | Fayetteville,
NC 28301 | [phone]

An extension to this deadline may be obtained through the completion and submittal of an Accelerated Site
Characterization (ASC) Report prior to the completion of the CSA. The scope of work defined by the ASC
Report consists of generating an updated conceptual site model based upon real-time field screening using
high-resolution site characterization practices. In this process the vertical and horizontal extent of soil and
ground water contamination onsite may be quickly evaluated to reduce the number of iterative steps
necessary to complete plume delineation and allow for the creation of a more accurate comprehensive soil
and ground water assessment and monitoring network plan to improve the quality and reduce the costs of
the subsequent CSA Report.
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).
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,

Kenneth E. Currie, Hydrogeologist
Fayetteville Regional Office
UST Section, Division of Waste Management, NCDEQ

cc: Ms. Helene Edwards, Director, Hoke County Health Department (email copy)
Mr. Kirk B. Pollard, L.G., Mineral Springs Environmental, P.C., Raleigh, NC (email copy)
Digital Incident File #: 96691