WA-1016_12613_G_NORR_20230220_MR 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]
February 20, 2023
North East Oil Company, Inc
c/o Mr. Lars P. Simonsen, Registered Agent
Post Office Box 848
Edenton, NC 27932
Re: Notice of Regulatory Requirements
15A NCAC 2L .0407(d) [Intermediate Risk]
Risk-based Assessment and Corrective Action
For Petroleum Underground Storage Tanks
Former Phelps Amoco
US Hwy 64 West, Creswell, NC
Washington County
Incident Number: 12613
Risk Classification: Intermediate
Ranking: I 140 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 January 30,
2023, which documents the results from a limited ground water sampling event on January 10, 2023.
During the most recent sampling event, multiple petroleum constituents were detected in the groundwater
samples in multiple wells at concentrations above the applicable groundwater quality standards (GWQS)
defined in Title 15A of the North Carolina Administrative Code (NCAC) Subchapter 2L .0202.
Additionally, benzene concentrations at MW-21 exceeded the applicable gross contaminant levels (GCLs)
defined for an Intermediate Risk classification in 15A NCAC 2L .0406(2). Accordingly, the site risk
classification remains ‘Intermediate’.
The report recommended performing soil sampling near MW-21 to determine if a targeted excavation to
remove residual contamination at that location is a viable remedial strategy.
The Department acknowledges that targeted excavation has shown benefits in situations such as this and
does not object to pursuing this remedial alternative, whether by pre-screening soil samples or using real-
time field screening of soil via multi-wavelength ultraviolet fluorescent tools during an excavation itself.
If an excavation is completed, groundwater sampling should be conducted within 90 days of the remedial
action to evaluate the effect on reducing groundwater contamination onsite, with a report submitted
approximately 30 days following the sampling event.
If the excavation approach is not pursued, a biannual sampling event to include monitoring wells MW-14
and MW-21, along with other representative sample locations, must be conducted in the 2nd quarter of 2025,
with a report documenting the findings of that sampling event submitted to this office by July 31, 2025.
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 Commercial Leaking Petroleum Underground Storage Tank Cleanup Fund (Trust Fund) reimbursement
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. 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 Trust Fund, please
contact the UST Section Trust Fund Branch at [phone]. If you have any questions regarding this
notice, please contact me at the physical address, telephone number, or email address 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. – William Regenthal (electronic copy)
Washington Regional Office | 943 Washington Square Mall | Washington, NC 27889 | [phone]