WA-860_11537_G_NORR_20191210

December 10, 2019

Mallard Oil Company
ATTN: Mr. Randy Godsell
Post Office Box 1008
Kinston, North Carolina 28503

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

Lawson Park Exxon
103 Rhem Street, New Bern
Craven County
Incident Number: 11537
Risk Classification: Intermediate
Ranking: I 180 D

Dear Mr. Godsell:

The Division of Waste Management (DWM) Underground Storage Tank (UST) Section received the
Groundwater Monitoring Report (Report) dated November 29, 2019. The report has been reviewed
and will be maintained in the Washington Regional Office. The report indicates continued levels of
groundwater contamination. The subject incident has been determined by the Department, in response
to North Carolina General Statute (NCGS) 143-215.94E(e4), to be of sufficiently high priority to allow
funding by the State Trust Fund Program. Therefore, you are directed to proceed with assessment.
Specifically, you are required to:

 Sample the groundwater on a nine-month schedule until groundwater contamination no longer
exceeds ten times the NCAC 2B surface water standards for two consecutive sampling events.
The next monitoring event should be conducted in August-September 2020 and should include
MW-2.

 Submit the results of the groundwater sampling activities in a letter report within 30 days of
receipt of the analytical results.

Effective October 1, 2004, the Department requires that all work following the submittal of the Limited
Site Assessment Report (Title 15A NCAC 2L .0405) be preapproved if State Trust Fund
reimbursement is anticipated. To comply with this requirement, a completed Preapproval/Claim
Authorization Form, encompassing the required remedial activities, must be received in this office

within 14 days of the date of this letter. Upon completion of the preapproved activities, you should
submit your claim promptly. Reimbursement funds are budgeted based on completed preapprovals,
but lengthy delays in reimbursement can occur if claims are not submitted immediately following work
completion.

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).

Please note that before you sell, transfer, or request a “No Further Action” determination for a property
that has not been remediated to below “unrestricted use” standards, you must file a Notice of Residual
Petroleum ("Notice") with the Register of Deeds in the county where the property is located (NCGS
143B-279.9 and 143B-279.11).

Failure to comply with the State's rules in the manner and time specified may result in the assessment
of civil penalties and/or the use of other enforcement mechanisms.

If you have any questions regarding the actions or the rules mentioned in this letter, please contact me
at the address or telephone number listed below. If you have any questions regarding trust fund
eligibility or reimbursement, please contact the UST Section Trust Fund Branch at [phone].

Sincerely,

Allison Ward
Hydrogeologist
Washington Regional Office

cc: Eastern Carolina Environmental Services, Mr. Thomas Benthall, via email
WaRO