FA-695_12628_G_NORR_20230411_Notice of Deficiency

North Carolina Department of Environmental Quality | Division of Waste Management
Fayetteville Regional Office | 225 Green Street | Suite 714 | Systel Building |
Fayetteville, NC 28301 | [phone]

April 11, 2023

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 South
Benson, Johnston County
Incident Number:12628
Risk Classification: High
Ranking: H-140-D
Dear Mr. McLamb:
During a review of records, a deficiency of information was confirmed for the above referenced facility.
Information originally received by this office on December 17, 1993, confirmed a release or discharge from
a petroleum underground storage tank (UST) system at the above-referenced location. Records indicate
that McLamb’s L.P. Gas & Supply Co., Inc., was the owner of this UST system at the time of release
discovery. Therefore, McLamb’s L.P. Gas & Supply Co., Inc., is the responsible party for assessment
and/or corrective action of this release.

No assessment or corrective actions have been conducted at this facility since the Groundwater Monitoring
Report, dated February 1, 2022. The incident is ranked “High Risk” due to petroleum hydrocarbon
concentrations in the groundwater exceeding the 15A NCAC 2L .0202 Groundwater Standards and at least
one nearby water supply well.

Therefore, you must comply with the assessment and reporting requirements of Title 15A NCAC
2L .0407(c). It is requested that you sample MW-2 for laboratory analysis using EPA 6200B and submit
the results in the Letter Report format within 60 days of receipt of this Notice.

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).

Page 2 of 2
Incident Number: 12628
April 11, 2023

North Carolina Department of Environmental Quality | Division of Waste Management
Fayetteville Regional Office | 225 Green Street | Suite 714 | Systel Building | Fayetteville, NC 28301 | [phone]

If you have questions, please contact me at the Fayetteville Regional Office address below or at (910) 433-
3347.

Sincerely,

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

Attachments: Notice of Regulatory Requirements, dated February 2, 2022

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

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