WS-9069_44302_G_NORR_20200312_CAPNORR

March 11, 2020

Eden Oil Company, Inc., Registered Agent
R & C Teague, Inc.
P.O. Box 1375
Reidsville, NC 27323

Re: Notice of Regulatory Requirements
15A NCAC 2L .0407(b) [High Risk]
Risk-based Assessment and Corrective Action
For Petroleum Underground Storage Tanks

Pagetown Exxon
8035 Cherry Grove Rd., Reidsville
Caswell County
Incident Number: 44302
Risk Classification: High
Ranking: 365

Dear Madam or Sir:

The Comprehensive Site Assessment Report (CSA) received on August 25, 2015 and the
supplemental information to the CSA, dated June 2, 2016, have been reviewed by the UST Section, Division
of Waste Management, Winston-Salem Regional Office.
The review indicates that corrective action is necessary to remediate environmental contamination.
Title 15A NCAC 2L .0407 (b) [High Risk] requires you to comply with the assessment and cleanup
requirements of Title 15A NCAC 2N .0707 and Title 15A NCAC 2L .0106(c) and 2L .0106(h).
A Corrective Action Plan (CAP) with a schedule for implementation of the CAP prepared in accordance with these requirements must be received by this office within 90 days of the date of this notice.
If your incident is eligible (or potentially eligible) for access to the Commercial Leaking Petroleum Underground Storage Tank Cleanup Fund (State Trust Fund) you may submit a Corrective Action
Feasibility Study in accordance with the June 1, 2016 North Carolina Petroleum UST Release Corrective
Action Phase Project Management Guidance and the applicable State Trust Fund Reasonable Rate
Document instead of a completed CAP.

In the Corrective Action Plan, natural attenuation of groundwater contamination must be used to
the maximum extent possible, plume stability should be evaluated, and efforts must be made to determine
whether or not the elimination of potential receptors, leading to risk reduction, is immediately practicable.
A responsible party who submits a Corrective Action Plan that proposes natural attenuation or cleanup to
alternate standards must provide public notice as specified in 15A NCAC 2L .0409(a).
Failure to implement the plan and schedule in the manner and time specified may result in
the assessment of civil penalties and/or the use of other enforcement mechanisms.
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 2L .0103(e) and 2L .0111(b).
Effective October 1, 2004, the Department of Environmental Quality 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,
encompassing the scope of work necessary to evaluate the feasibility of a proposed remediation strategy,
must be received in this office within 14 days of the date of this letter. Upon completion of preapproved
activities that define an individual step within the Corrective Action Plan process, 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 of 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 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,
Linda Estkowski
Hydrogeologist
Winston-Salem Regional Office
UST Section, Division of Waste Management, NCDEQ

cc: Caswell County Health Department
Jeff Ballsieper, Progress Environmental, Inc. via email [e-mail]

Winston-Salem Regional Office | 450 W Hanes Mill Rd | Suite 300 | Winston-Salem, NC 27105 | [phone]