WI-28564_47809_G_NORR_20230124

North Carolina Department of Environmental Quality | Division of Waste Management
Wilmington Regional Office | 127 Cardinal Drive Extension | Wilmington, NC 28405 |
[phone]

January 24, 2023

RD White & Sons, Inc.
Mr. Robert H. White, Registered Agent
PO Box 40
Shallotte, NC 28459

Re: Notice of Regulatory Requirements
– 2nd REQUEST for Information
15A NCAC 2L .0407(d) [Intermediate Risk]
Risk-based Assessment and Corrective Action
For Petroleum Underground Storage Tanks

R D White & Sons, Inc.
4541 White Street, Shallotte,
Brunswick County
Incident Number: 47809
Risk Classification: Intermediate
Ranking: I 085 D

Dear Mr. White:

As stated in the original Notice of Regulatory Request, dated February 17, 2022, the Limited Site
Assessment (LSA) Report received on September 25, 2021 and the sample results received on February 7,
2022 have been reviewed by the UST Section, Division of Waste Management, Wilmington Regional
Office. After review, 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 or remediation
activities as required in this Notice of Regulatory Requirements dated January 24, 2023. Specifically, you
are required to complete and submit a Risk Assessment Report to the Division within 60 days of the date
of this letter.
The additional Assessment Report supplements the LSA through the assessment of groundwater
characteristics and the risk to nearby receptors. Specifically, at a minimum, the Risk Assessment Report
should include:
 The installation of three horizontal extent monitoring wells and one vertical extent monitoring well.
One monitoring well shall be installed upgradient of the source of contamination and two
monitoring wells shall be installed downgradient of the source of contamination, as best as can be
determined, and located such that groundwater flow direction and hydraulic gradient may
accurately be determined. The vertical extent monitoring well shall be installed immediately
downgradient of the source area of contamination, as best as can be determined. Note, the vertical
extent monitoring well must not connect aquifers.
 The analysis of representative soil samples collected during the construction of the monitoring
wells. One soil sample must be collected in the unsaturated zone and one in the smear/saturated
zone from suspected worst-case locations exhibiting visible contamination or elevated levels of
volatile organic compounds based on field screening techniques. Only the suspected most
contaminated soil sample in each zone from each boring should be submitted for laboratory analysis
using the EPA 8015B TPH (or equivalent) appropriate for the fuel types suspected in the release.

 The collection of groundwater samples from the new monitoring wells, analyzed by the appropriate
method(s) for the constituents relevant to the release.
 The survey of all monitoring wells and collection of potentiometric data for the completion of a
potentiometric surface / groundwater elevation and flow map.
 The completion of one aquifer slug test in a representative well to provide a calculation of hydraulic
conductivity, transmissivity, and linear groundwater velocity.
Title 15A NCAC 2L .0407(d) [Intermediate 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).
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.
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 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
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).

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,
Liz Price
Hydrogeologist
Wilmington Regional Office
UST Section, Division of Waste Management, NCDEQ

cc: Brunswick County Health Department

Henry Nemargut, via email correspondence

RD White & Sons via email - [e-mail]

Wilmington Regional Office | 127 Cardinal Drive Ext| Wilmington, NC 28405 | [phone]