WA-27683_38811_G_NORR_20201202_CSA ASC RQST

ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
MICHAEL SCOTT
Director

State of North Carolina | Environmental Quality | Waste Management
Washington Regional Office | 943 Washington Square Mall | Washington, NC 27889 | [phone]
December 2, 2020
Scott Driscoll
E.J. Pope & Son, Inc.
PO Drawer 649
Mount Olive, NC 28365
Re: Notice of Regulatory Requirements
15A NCAC 2L .0407(c) [High Risk]
Risk-based Assessment and Corrective Action
For Petroleum Underground Storage Tanks
Handy Mart 15 / Peele Property
UST Facility ID: 00-0-0000005485
2495 US Highway 13 North, Goldsboro, NC
Wayne County
Incident Number: 38811
Risk Classification: High
Ranking: H 190 A
Dear Mr. Driscoll:
The Washington Regional Office of the Underground Storage Tank (UST) Section, Division of
Waste Management, Department of Environmental Quality (Department) has received and reviewed the
November 20, 2020 Limited Site Assessment Report for the subject site.
Based on the definitions provided in Title 15A of the North Carolina Administrative Code (NCAC)
Subchapter 2L Section .0406, the risk posed by the discharge or release at this site is classified as High.
Due to several adjacent residential properties, the applicable land use for evaluating site risk has been
classified as Residential.
Title 15A NCAC 2L .0407(c) [High Risk] requires you to comply with the assessment and cleanup
requirements of Title 15A NCAC 2N .0706 and Title15A NCAC 2L .0106(c) and 2L .0106(g). A
Comprehensive Site Assessment (CSA) Report prepared in accordance with these requirements and the
most recent version of the Guidelines for Assessment for UST Releases must be received by this office
within 90 days of the date of this notice. In addition, you must submit a summary of the CSA Report to the
local Health Director and the local Chief Administrative Officer in accordance with Title 15A NCAC 2L
.0114. The summary should be submitted to these persons no later than five working days after submittal
of the CSA Report to this office.
Failure to comply in the manner and time specified may result in the assessment of civil
penalties and/or the use of other enforcement mechanisms.
Within the CSA Report conclusions and recommendations, a plausible contaminant source and a
general proposed response to abate and remediate that source should be included as a preliminary step in
moving towards any formal corrective action plan. If not included in the CSA Report, this information must
be provided separately prior to the authorization of any corrective action feasibility study tasks.
An extension to the CSA deadline may be obtained through the completion and submittal of an
Accelerated Site Characterization (ASC) Report prior to the completion of the CSA. The scope of work
defined by the ASC Report consists of generating an updated conceptual site model based upon real-time
field screening using high-resolution site characterization practices. In this process the vertical and
horizontal extent of soil and ground water contamination onsite may be quickly evaluated to reduce the
number of iterative steps necessary to complete plume delineation and allow for the creation of a more
accurate comprehensive soil and ground water assessment and monitoring network plan to improve the
quality and reduce the costs of the subsequent CSA Report.
Additionally, Title 15A NCAC 2L .0407(a) requires you to notify the Department of any changes
that might affect the risk or land use classifications that have been assigned. If information becomes
available that would alter these classifications such that the regulatory requirements described above are no
longer applicable, please provide documentation of such to the Department prior to the CSA deadline.
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 Title 15A NCAC 2L .0103(e) and 2L .0111(b).
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 State 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 Commercial
Leaking Petroleum Underground Storage Tank Cleanup Fund, 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 physical address, telephone number, or email address listed below.
Sincerely,
Jared M. Edwards
Hydrogeologist - Washington Regional Office
UST Section, Division of Waste Management, NCDEQ
[phone] / [e-mail]
cc: E.J. Pope & Son, Inc., Scott Driscoll (electronic copy)
Geological Resources, Inc., William Regenthal (electronic copy)