HomeMy WebLinkAboutFA-647_11717_MISC_EMAIL_2016.04.141
Brown, James
From:Rae Brown <rtb@geologicalresourcesinc.com>
Sent:Thursday, April 14, 2016 2:44 PM
To:Brown, James
Subject:RE: ePATA for MMPE - 15-752; Corner Store; Garland
Attachments:SKMBT_36316041414410.pdf
Follow Up Flag:Follow up
Flag Status:Flagged
Hi James,
In May 2014, a CAP was submitted that proposed 6 MMPE events in the first year of implementation. This was the
selected and approved technology for this site (NORR 11/30/15). Since CAP acceptance, 3 MMPE Events have been
conducted (Feb 2015, August 2015, and September 2015); and, including the initial MMPE pilot test (January 2014), a
total of 73,157 gallons of contaminated water and have been removed during the 384 hours (16 days) of remediation. I
have attached Benzene isoconcentration maps to show some of the impact the events have had to date; and tables
were included in the reports submitted.
The TA submitted December 14, 2015, is in compliance with the CAP and proposes 2 MMPE events which would be
Events 4 and 5. At this point, the delayed approval has extended the implementation of the CAP’s proposed 6 events
beyond a year. Therefore, the TA should be approved as the CAP has been approved for implementation.
NPDES permits allow water to be discharged into surface bodies such as ditches; however, no permit would be granted
to discharge purge water without pre‐treatment. In addition, discharging into a municipal system would also require
pre‐treatment since benzene concentrations exceed 5,000 ppb; POTWs can require transport as the permitted discharge
point may not be located on or adjacent to the site. One of the reasons, the MMPE was selected was to minimize costs;
in lieu of treating water on‐site, transport and disposal were elected.
Costs evaluated in the CAP were for MMPE events that included transport and disposal of fluids off‐site. If the CAP is to
be altered, please provide a reason for the modification and provide a NORR indicating that the current CAP is not
required to be implemented as approved.
This site is ranked as Intermediate Risk because ground water contamination exceeds GCLs. There is no provision in 2L
for closing the incident or reducing the site risk until the contamination is less than GCLs. In order to close this incident,
the requires active remediation.
Thanks,
Rae
Rae Troiano Brown, P.G.
Project Manager
Geological Resources, Inc.
113 West Firetower Road, Suite G, Winterville, NC 28590
Main (704) 698‐1254 Cell (252) 227‐3005 Fax (704) 845‐4012
rtb@geologicalresourcesinc.com
www.geologicalresourcesinc.com
NCPCM Vendor of the Year Recipient
2
From: Brown, James [mailto:james.brown@ncdenr.gov]
Sent: Monday, February 15, 2016 10:42 AM
To: Rae Brown <rtb@geologicalresourcesinc.com>
Subject: FW: ePATA for MMPE ‐ 15‐752; Corner Store; Garland
Rae,
Scotts questions about MMPE….can you relay through me.
James
James W Brown
UST Section
225 Green Street, Suite 714
Fayetteville, NC 28301
Office: 910‐433‐3346
POC for ITRC
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.
From: Ryals, Scott
Sent: Monday, February 15, 2016 10:36 AM
To: Brown, James <james.brown@ncdenr.gov>
Subject: FW: ePATA for MMPE ‐ 15‐752; Corner Store; Garland
So what was the impact of the last two MMPE events? Why can’t the water be disposed of with a NPDES or POTW?
Scott C. Ryals, PE, CEE
Environmental Engineer
Trust Fund Branch, UST Section
Department of Environmental Quality
919-707-8168 office
Scott.ryals@ncdenr.gov
1646 Mail Service Center
217 West Jones Street
Raleigh, NC 27699-1646
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.
3
From: Brown, James
Sent: Friday, February 12, 2016 10:47 AM
To: Ryals, Scott <scott.ryals@ncdenr.gov>
Subject: ePATA for MMPE ‐ 15‐752; Corner Store; Garland
Please see attached
James W Brown
UST Section
225 Green Street, Suite 714
Fayetteville, NC 28301
Office: 910‐433‐3346
POC for ITRC
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.
From: Rae Brown [mailto:rtb@geologicalresourcesinc.com]
Sent: Tuesday, December 15, 2015 4:23 PM
To: Brown, James <james.brown@ncdenr.gov>
Subject: 15‐752; Corner Store; Garland
Hi James,
Attached is the TA for work requested at the Corner Store.
Please let me know if there are any questions.
Thanks
Rae
Rae Troiano Brown, P.G.
Project Manager
Geological Resources, Inc.
113 West Firetower Road, Suite G, Winterville, NC 28590
Main (704) 698‐1254 Cell (252) 227‐3005 Fax (704) 845‐4012
rtb@geologicalresourcesinc.com
www.geologicalresourcesinc.com
NCPCM Vendor of the Year Recipient