WA-921_11941_G_NORR_20230405_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]
April 5, 2023
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, NC
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 February 24,
2023, that documents a limited ground water sampling event conducted onsite on February 6, 2023.
During this most recent sampling event, concentrations of petroleum constituents in the groundwater were
detected in multiple monitoring wells above the groundwater quality standards (GWQS) defined in Title
15A of the North Carolina Administrative Code (NCAC) Subchapter 2L .0202. Additionally, non-aqueous
phase liquid (NAPL, or free product) was reportedly detected at a measurable thickness in a total of 6
monitoring or recovery wells for the first time since December 2019.
Due to the presence of non-potable supply wells within 250 feet of the release above GWQS, the site risk
classification remains ‘High’.
The next sampling event should be scheduled for the 3rd quarter of 2023, with a report documenting the
results due no later than October 31, 2023.
The event should include gauging/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.
The report recommends a mobile multi-phase extraction (MMPE) event to address the NAPL observed
onsite, as well as the use of injectable in situ chemical oxidation (ISCO) compounds to address
contamination at the site due to concerns about available space onsite and discharge options needed for
permanent mechanical extraction alternatives. The Department does not object to either recommendation.
Page 2 of 2
RAM #1 (11941) / A&A Texaco (13418)
April 5, 2023

North Carolina Department of Environmental Quality | Division of Waste Management | UST Section
Washington Regional Office | 943 Washington Square Mall | Washington, NC 27889 | [phone]
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.
If an ISCO pilot is intended, please note that reimbursement would also require confirmation that the
technology selected has been approved by the UST Section’s Innovative Technology Committee (ITC). A
specific list of approved technologies, and information on how to obtain acceptance for a technology not
yet approved, is available at: https://www.deq.nc.gov/about/divisions/waste-management/underground-
storage-tanks-section/innovative-technologies.
In the interim, NAPL recovery through MMPE (with or without surfactant injection) may be preapproved
where the scope requested meets the waste stream monitoring and system operational oversight
requirements described by the Trust Fund Branch in the 2022 Reasonable Rate Scope of Work Document
and associated Trust Fund claim forms.
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, telephone number, or email listed below.

Sincerely,

Jared M. Edwards
Environmental Program Consultant, Washington Region
UST Section, Division of Waste Management, NCDEQ
[phone] / [e-mail]

cc: Geological Resources, Inc. - Mr. Ethan Rogerson (electronic copy)