RA-1098_7093_G_NORR_20220113_SA MRP RQST

ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
MICHAEL SCOTT
Director

North Carolina Department of Environmental Quality | Division of Waste Management | UST Section
Washington Regional Office | 943 Washington Square Mall | Washington, NC 27889 | [phone]
January 13, 2022
Mr. Boyd Tolman
Stallings Oil Company
300 South Wesleyan Boulevard
Rocky Mount, NC 27804
Re: Notice of Regulatory Requirements
15A NCAC 2L .0407(d) [Intermediate Risk]
Risk-based Assessment and Corrective Action
For Petroleum Underground Storage Tanks
U-Filler Up #26
101 Smith Church Road, Roanoke Rapids, NC
Halifax County
Incident Number: 7093
Risk Classification: Intermediate
Ranking: I 0170 D
Dear Mr. Tolman:
The UST Section, Division of Waste Management, Department of Environmental Quality
(Department) is in receipt of the Ground Water Monitoring Report, dated December 9, 2021, documenting
the results from a ground water sampling event on November 16, 2021.
During this most recent sampling event, concentrations of petroleum constituents in the
groundwater were detected in multiple monitoring wells above the groundwater quality standards defined
in Title 15A of the North Carolina Administrative Code (NCAC) Subchapter 2L .0202. Additionally, the
benzene concentrations reported for monitoring well MW-1 exceeded the applicable gross contaminant
levels (GCLs) defined for an Intermediate Risk classification in Title 15A NCAC 2L .0406(2).
A semiannual sampling event should be conducted during the 2nd quarter of 2022, with a
monitoring report documenting the results submitted to this office no later than July 29, 2022.
The Conclusions section of the aforementioned report noted the potential to either proceed with an
existing unimplemented Corrective Action Plan (CAP) which had been delayed as a result of the funding
prioritization requirements in Session Law 2004-124, or evaluate the effectiveness of a mobile multi-phase
extraction (MMPE) system in reducing targeted contaminant levels in key onsite wells.
Although aggressive fluid-vapor recovery (AFVR) events have reportedly been conducted onsite
in the past, the completion of a MMPE event with proper evaluation including pre- and post-event sampling
to determine the efficiency of both dissolved and volatilized/vapor recovery may be warranted prior to
implementing the existing CAP.
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 covering the
either an updated Corrective Action Design (Task 6.066) or a proposed scope to complete and evaluate the
effectiveness MMPE onsite, must be received and approved by this office prior to the start of any tasks for
which you intend to seek reimbursement. A request for preapproval to continue the required semiannual
monitoring described above should be incorporated into the selected strategy as appropriate.
Please note that the 3-step CAP process is not required for someone who is not seeking
reimbursement for a comprehensive Corrective Action Plan, so direct implementation of the existing CAP
absent consideration for reimbursement remains an available option as well.
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 physical address, telephone number, or email address listed below.

Sincerely,

Jared M. Edwards
Hydrogeologist - Washington Regional Office
UST Section, Division of Waste Management, NCDEQ
[phone] / [e-mail]
cc: Geological Resources, Inc. – William Regenthal (electronic copy)
Washington Regional Office | 943 Washington Square Mall | Washington, NC 27889 | [phone]