FA-3257_29432_G_NORR_20230807_CSA Request

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

August 8, 2023

Mr. Robert C. Harrison
P.O. Box 16556
Myrtle Beach, SC 29587

Re: Notice of Regulatory Requirements
15A NCAC 02L .0407(d) [Intermediate Risk]
Risk-based Assessment and Corrective Action
For Petroleum Underground Storage Tanks

Mill Road Grocery
500 Mill Road
Rockingham, Richmond County
Incident Number: 29432
Risk Classification: Intermediate
Ranking: I-225-A

Dear Mr. Harrison:

The Groundwater Sampling Report dated February 1, 2022, along with the Free Product Evaluation Report
dated July 7, 2023, have each been reviewed by the UST Section, Division of Waste Management,
Fayetteville Regional Office. Results of the GC/MS analysis and the comparative evaluation of product at
the site indicate the gasoline in MW-2 is from the earlier release of gasoline detected in 2007. You are
considered the responsible party for that 2007 release discovery. The risk posed by the discharge or release
at the subject site is classified by the Department of Environmental Quality as intermediate, as stipulated
under Title 15A NCAC 02L .0406. The land use at the site is classified as residential. Title 15A NCAC
02L .0407(a) requires you to notify the Department of any changes that might affect the risk or land use
classifications that have been assigned.
Title 15A NCAC 02L .0407(d) [Intermediate Risk] requires you to comply with the assessment and cleanup
requirements of Title 15A NCAC 02N .0706 and Title 15A NCAC 02L .0106(c) and 02L .0111(b). A
Comprehensive Site Assessment (CSA) Report prepared in accordance with these requirements and the
most recent version of the UST Section Assessment Guidelines 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 15A NCAC 02L .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.
An extension to this 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
Page 2 of 2
Incident Number: 29432
August 8, 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]

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.
The Department of Environmental Quality 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
02L .0405) must 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 delays in reimbursement or even denial due to exceeding the statute of
limitations on claiming eligible costs can result where 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 15A NCAC 02L .0103(e) and 02L .0111(e).
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,

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

cc: Cheryl Speight, Interim Director, Richmond County Health Department (email copy)
Michael G. Jones, P.G., Pyramid Environmental & Engineering, P.C., Greensboro, NC (email copy)