Notices of Residual Petroleum at Residential Sites

Notices of Residual Petroleum
at Residential Sites
EMD/EQB/Tank Program
What is an NRP?
• Notice of Residual Petroleum (NRP) is put in
place when a former underground storage
tank (UST) site cannot be remediated below
2L (NC groundwater standards) for
groundwater and/or below residential
MSCCs for soil.
• NRPs are registered with the Register of
Deeds of Onslow County
• Includes Land Use Restrictions (LURs) for
soil and/or groundwater.
Public Notification Requirements
• Must notify the local health director, the
county manager, and the city manager.
• Must notify all property owners and
occupants residing within or contiguous to
the area containing contamination.
– Previously meet this requirement by posting a
legal notice in the Local News paper.
– New NCDENR regulator requiring additional
notifications at residential sites – Per 15A NCAC
2L .0409(b).
Public Notification Requirements
Current NRP Sites
• 69 NRP sites at Lejeune and New River
• 20 of the 69 sites are within Residential
Example LUR Boundaries
• Notifying current residents within
established LUR boundaries
• Notifying future residents within
established LUR boundaries
Notifying Current Residents
• Send a general letter to all residences that fall within the
LUR boundary and adjacent to that boundary.
– List out the NRP sites in that letter.
– Provide the LUR boundary map.
• Send letters to city/county officials and post notice in the
local newspaper
Issue: Will need to figure out a way to distinguish which
residents are considered “adjacent”.
Notifying Future Residents
• Approached NCDENR with posting notifications at Family Housing
– NCDENR disapproved because there is no guarantee that the
notification will be seen.
Send letters as new residents move in.
– How do you track when a new resident moves in?
– Could result in multiple letters to be sent at different times.
– Potential to miss notifying a resident.
2. Send letters annually to identified residents.
– Could be several months after a resident moves in before seeing notice.
3. Add notification as a lease addendum.
– NCDENR recommends this approach
Notifying Future Residents