WA-921_11941_G_NORR_20220901_SA MRP CAP 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]
September 1, 2022
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) [High Risk]
Risk-based Assessment and Corrective Action
For Petroleum Underground Storage Tanks
Red Apple Market #1 / A&A Texaco
100 W. Main St. / 100 E. Main St., Harrellsville
Hertford County
Incident Numbers: 11941 / 13418
Risk Classification: High
Ranking: H 234 D
Dear Mr. Simonsen:
The Underground Storage Tank (UST) Section, Division of Waste Management, Department of
Environmental Quality (Department) has received a Ground Water Monitoring Report dated August 18,
2022, which documents the results from a receptor survey update and a limited ground water sampling
event conducted onsite between July 12 and 13, 2022.
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 risk classification
remains ‘High’ due to the presence of non-potable supply wells within 250 feet of the release.
Non-aqueous phase liquid (NAPL, or free product) was reportedly not detected at a measurable
thickness in any of the monitoring wells for the fourth consecutive event.
The next sampling event should be scheduled for the 1st quarter of 2023, with a report documenting
the results submitted no later than May 1, 2023.
The event should include sampling of plume core monitoring wells MW-1, MW-2, MW-3, MW-9,
MW-10, RW-1, and AMW-4, as well as a representative number of peripheral wells to ensure protection
of nearby water supply wells and allow for the continued evaluation of plume stability. Additionally, any
at-risk supply wells that remain at that time should also be sampled.
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 reimbursement from the Commercial Leaking Petroleum Underground
Storage Tank Cleanup Fund (Trust Fund) 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.
Recent reports have also recommended the implementation of the existing 2004 Corrective Action
Plan as a remedial strategy. Unless the abandonment of all at-risk receptors can be accomplished to allow
for risk reclassification, this proposal requires the submittal of a preapproval request for Task 6.066 –
Corrective Action Design describing the proposed scope of work based on the 2004 Corrective Action Plan
with any modifications necessary based on current site conditions, or Task 1.010 – Request for Bid if no
changes are needed, for a formal evaluation of the proposed strategy by the Department.
Alternatively, Trust Fund Branch staff have indicated that their records show no reimbursement
made for any historic Corrective Action Plan task at this site. Accordingly, if an alternate remedial strategy
is preferred, preapproval for Task 6.065 – Corrective Action Feasibility Study Report may be requested.
This request should be included with, or submitted separately from, any request for tasks associated
with the required sampling efforts and the resulting authorized scope must be completed within the same
timeframe defined above.
Please note that any remedial strategy that incorporates a designed mechanical system will
require all applicable documents be completed and sealed by a North Carolina Professional Engineer.
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, 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: Geological Resources, Inc. - Mr. Ethan Rogerson (electronic copy)
Washington Regional Office | 943 Washington Square Mall | Washington, NC 27889 | [phone]