WA-28331_47588_G_NORR_20230807_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]
August 7, 2023
Speedway, LLC
c/o Mr. Samuel Kramer
Post Office Box 1500
Springfield, Ohio 45501
Re: Notice of Regulatory Requirements
15A NCAC 2L .0407(d) [Intermediate Risk]
Risk-based Assessment and Corrective Action
For Petroleum Underground Storage Tanks
Speedway #6966
1109 US Highway 64 East, Plymouth, NC
Washington County
Incident Number: 47588 (see also 11890)
Risk Classification: High
Ranking: H 0230 D
Dear Mr. Kramer:
The Underground Storage Tank (UST) Section, Division of Waste Management, Department of
Environmental Quality (Department) has received the July 28, 2023, Ground Water Monitoring Report,
documenting the results from groundwater sampling efforts conducted onsite on April 11, 2023.
During this most recent sampling event, groundwater samples from multiple monitoring wells
demonstrated petroleum compounds at concentrations above the applicable groundwater quality standards
(GWQS) defined in Title 15A of the North Carolina Administrative Code (NCAC) Subchapter 2L .0202.
Additionally, the continued presence of one impacted receptor, the semi-potable water supply well located
at 1109 East Main Street, Plymouth, NC (approximately 750 feet from the source area). Accordingly, the
risk classification for this release remains High.
Due to the presence of a down gradient and impacted water supply well within 1,000 feet of the
subject site, additional remedial activities, and/or supplemental assessment efforts are necessary. No
proposed remedial strategy was provided among the recommendations in the report. Such recommendations
must be made for review by the Department to determine if formal evaluation via a Feasibility Study is
appropriate. Supplemental assessment could include the installation of nested monitoring wells down
gradient of the source area to further delineate the contaminant plume and/or further sampling and
investigation of the impacted water supply well.
Please note that the removal of the at-risk water supply well at 1109 East Main Street would trigger
a re-evaluation of the risk posed by this release and potential reclassification to Low. Once the risk
classification is lowered, the incident would be eligible for risk-based closure following the completion and
filing of a Notice of Residual Petroleum with the Washington County Register of Deeds.
A semiannual groundwater sampling event should be scheduled for the 4th quarter of 2023, with a
Ground Water Monitoring Report documenting the results of that event and including a proposed remedial
strategy submitted no later than December 29, 2023.
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 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
and approved by this office well prior to the start of any tasks for which you intend to seek reimbursement.
Recommended remedial alternatives may be proposed in the scope of work explanation associated
with a preapproval request that includes any appropriate measures to evaluate the feasibility of that strategy
(e.g., a pilot study for the utilization of air sparging, oxygen demand testing for evaluation of oxygen
releasing compound injections, etc.)
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 eligibility or reimbursement from the Trust Fund, please
contact the UST Section Trust Fund Branch at [phone]. If you have questions about the information
contained in this letter, please contact me at the physical address, telephone number, or email address below.
Sincerely,
A. Alfred J Discepolo
Hydrogeologist - Washington Region
UST Section, Division of Waste Management, NCDEQ
[phone] / [e-mail]
cc: AECOM Technical Services of NC – Brett Schaefer, PE (electronic copy)
Washington Regional Office | 943 Washington Square Mall | Washington, NC 27889 | [phone]