WQ0034465_Staff Report_20191114

WQROS REGIONAL STAFF REPORT FOR
UIC Program Support
Permit No. WI0034465
Date: 11/14/2019 County: Durham
To: Shristi Shrestha Permittee/Applicant: G1axoSmithKline
Regional Office Reviewer: Brion N. Byers Facility Name: GSK, South Campus, North Complex
L GENERAL INFORMATION
1. This application is (check an that apply): ❑ New ❑ Renewal
® Minor Modification ❑ Major Modification
a. Date of Inspection: November 5, 2019
b. Person contacted and contact information: Brian Eichlin
c. Site visit conducted by: Brion Byers, RRO
d. Inspection Report Printed from BIMS attached: ❑ Yes ® No
e. Physical Address of Site including zip code: 3029 Cornwallis Rd., Durham, Durham Co., NC
f. Driving Directions if rural site and/or no physical address:
g. Latitude: 35.912064 Longitude:-78.865933
Source of Lat/Long & accuracy (i.e., Google Earth, GPS, etc.): GPS by TWT (obtained from application)_
II. DESCRIPTION OF INJECTION WELLS) AND FACILITY
L Type of injection system:
❑ Geothermal Heating/Cooling Water Return
® In situ Groundwater Remediation
❑ Non -Discharge Groundwater Remediation
❑ Other (Specify:_
2. For Geothermal Water Return Well(s) only
a. For existing geothermal system:
Were samples collected from Influent/Effluent sampling ports? ❑ Yes ❑ No.
Provide well construction information from well tag:
b. Does existing or proposed system use same well for water source and injection? ❑ Yes ❑ No
If No, please provide source/supply well construction info (i.e., depth, date drilled, well contractor,
etc.) and attached map and sketch location of supply well in relation to injection well and any other
features in Section IV of this Staff Report.
3. Are there any potential pollution sources that may affect injection? ® Yes ❑ No
What is/are the pollution source(s)? There appear to be several release/contaminated (chlorinated solvents)
areas onsite.
4. What is the distance of the injection well(s) from the pollution source(s)? Unknown
5. What is the minimum distance of proposed injection wells from the property boundary? No Proposed change
to the injection wells.
6. Quality of drainage at site: ® Good ❑ Adequate ❑ Poor
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WQROS REGIONAL STAFF REPORT FOR
UIC Program Support
7. Flooding potential of site: ® Low ❑ Moderate ❑ High
8. For Groundwater Remediation systems, is the proposed and/or existing groundwater monitoring program
(number of wells, frequency of monitoring, monitoring parameters, etc.) adequate? ❑ Yes ❑ No. If No,
attach map of existing monitoring well network if applicable and recommend any changes to the groundwater -
monitoring program. Unknown, have not reviewed Monitoring Reports for the site
9. Does the map included in the Application reasonably represent the actual site (property lines, wells, surface
drainage)? ® Yes ❑ No. If No, or no map, please attach a sketch of the site. Show property boundaries,
buildings, wells, potential pollution sources, roads, approximate scale, and north arrow.
10. For Non -Discharge groundwater remediation systems only:
a. Are the treatment facilities adequate for the type of waste and disposal system? ❑ Yes ❑ No ❑ N/A.
If no, please explain:
b. Are the site conditions (soils, topography, depth to water table, etc.) consistent with what was reported by
the soil scientist and/or Professional Engineer? ❑ Yes ❑ No ❑ N/A. If no, please explain:
III. EVAL UATIONAND RECOMMENDATIONS
1. Do you foresee any problems with issuance/renewal of this permit? [:]Yes ®No. If yes, explain.
2. List any items that you would like WQROS Central Office to obtain through an additional information request.
Make sure that you provide a reason for each item:
Item Reason
3. List specific special conditions or compliance schedules that you recommend to be included in the permit when
issued. Make sure that you provide a reason for each special condition:
Condition
Reason
RRO agrees with relocating MW-11, after
Construction will damage MW-I I
completion of redevelopment activities.
Moving to semi-annual sampling is acceptable,
As discussed during site visit, Golder has
as it has been two years since the last injection.
extensive background data related to
And there are no downgradient receptors that
groundwater contamination and effects of ZVI
are being impacted.
injection.
4. Recommendation
❑ Deny. If Deny, please state reasons:
❑ Hold pending receipt and review of additional information by regional office
❑ Issue upon receipt of needed additional information
® Issue
5. Signature of report preparer(s):
Signature of WQROS Regional Supervisor:
Date: 11 4(gZI:9l
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WQROS REGIONAL STAFF REPORT FOR
UIC Program Support
IV. ADDITIONAL REGIONAL STAFF REVIEW COMMENTS/ATTACHMENTS (If Needed)=
Summary of Proposed Minor Permit Modification:
• GSK site has groundwater contaminated with chlorinated compounds exceeding 2L Standards. GSK has
completed numerous injection events in several different areas and multiple vertical zones with zero valent
iron (ZVI). I have not reviewed previous reports to confirm the number or the extent of injections at this
facility.
• The site is being redeveloped under the Brownfield Program. Environmental Management plans
redevelopment of the site have been submitted and approved by the Brownfields Program.
• Permit Modification Request is to:
o Relocate monitoring well MW-11 to a new location (within 50' of original location), once
redevelopment activities for grading are completed
o Reduce the frequency of sampling from quarterly to semi-annual. Permit requires quarterly
sampling (for two year after completion of injection), then allows for reduction to semi-annual.
Golder wants clarification. Permit is not clear if this after each injection event or just the initial
injection event.
RRO Site Visit 01/05/2019)
DWR RRO (Brion N. Byers) completed a site visit at the GlaxoSmithKline, South Campus, North Complex
Facility on November 5, 2019. DWR met with representatives from GSK (Brian Eichlin & Andrew Wrenn) as well
as a representative of the property owner. The flowing was items where discussed during the site visit.
• The need to relocate MW-11 because of proposed construction and regrading of the area. MW-11 will be
reinstalled after construction is complete.
o DWR wants the well to be reinstalled and screened in the same zone.
• GSK discussed the history of the site and that they have completed quarterly sampling far longer than the
permit required. Injection is has not occurred in downgradient area (MW-11) in several years and future
injection are not currently planned. GSK plans to continue with semi-annual monitoring.
• GSK further discussed their injection procedures and injection wells at the source area.
• Injection and monitoring wells observed by DWR, were in good condition and well maintained. Onsite
injection equipment also appeared to be well maintained and in good working order.
Recommendations by RRO:
• Based on the information provide in the application and the site visit, RRO agrees with the relocation of
monitoring well MW-11.
• RRO is also permissible to the reduction in sampling frequency to semi-annual from quarterly, if no
downgradient receptors (water -supply wells or surface water bodies) are being impacted.
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