FA-695_12628_G_NORR_20220207_Feb 2022 MRP

February 7, 2022

Mr. David Wayne McLamb, Registered Agent
McLamb’s L.P. Gas & Supply Co., Inc.
3469 NC Highway 242 S
Benson, NC 27504

Re: Notice of Regulatory Requirements
15A NCAC 2L .0407(c)
Risk-based Assessment and Corrective Action
for Petroleum Underground Storage Tanks

McLamb’s L.P. Gas & Supply
3469 NC Highway 242 S
Benson, Johnston County
Incident Number: 12628
Risk Classification: High
Ranking: H140-D

Dear Mr. McLamb:

The Groundwater Monitoring Report dated February 1, 2022, has been reviewed. This office suggests
consideration that a Groundwater Fate & Transport Model be prepared for this incident as a more expedient
path to incident closure using the Risk-Based Corrective Action rules than continued annual groundwater
monitoring. I ask that you discuss the merits of this suggestion with your consultant along with the requirements
necessary for risk-based incident closure.

The UST Section must consider the most cost-effective measures to remediate and close out Trust Fund
eligible petroleum UST release incidents. This incident is an open high risk mainly because of Naphthalene
exceeding the 15A NCAC 2L .0202 groundwater standards and a water supply well located approximately 200’
hydraulically upgradient of the contaminant plume. Historical sampling data for MW-2 over the last 10 years
does not lend that Naphthalene will naturally attenuate to less than the groundwater standards within any
reasonable period so this makes Risk-Based closure a very attractive consideration.

If you have questions regarding the information contained in this letter, please contact me at the
Fayetteville Regional Office address below or at [phone].

Sincerely,

Kenneth E. Currie, Hydrogeologist
Fayetteville Regional Office
UST Section, Division of Waste Management

c: Mr. Tom Will, P.G., East Coast Environmental, P.A., Raleigh, NC (email copy)
FAY/UST Electronic File #12628