WI0400548_Permit (Issuance)_20200513

NC Department of Environmental Quality — Division of Water Resources (DWR)
NOTIFICATION OF INTENT (NOI) TO CONSTRUCT OR OPERATE INJECTION WELLS
The following are `permitted by rule" and do not require an individual permit when constructed in accordance
with the rules of 15A NCAC 02C.0200 (NOTE: This form must be received at least 14 DAYS prior to injection)
AQUIFER TEST WELLS (15A NCAC 02C .0220)
These wells are used to inject uncontaminated fluid into an aquifer to determine aquifer hydraulic characteristics.
IN SITU REMEDIATION (15A NCAC 02C .0225) or TRACER WELLS (15A NCAC 02C .02291:
1) Passive Injection Systems - In -well delivery systems to diffuse injectants into the subsurface. Examples include
ORC socks, iSOC systems, and other gas infusion methods (Note: Injection Event Records (IER) do not need to be
submitted for replacement of each sock used in ORC systems).
2) Small -Scale Injection Operations — Injection wells located within a land surface area not to exceed 10,000
square feet for the purpose of soil or groundwater remediation or tracer tests. An individual permit shall be required
for test or treatment areas exceeding 10,000 square feet.
3) Pilot Tests - Preliminary studies conducted for the purpose of evaluating the technical feasibility of a
remediation strategy in order to develop a full scale remediation plan for future implementation, and where the
surface area of the injection zone wells is located within an area that does not exceed five percent of the land surface
above the known extent of groundwater contamination. An individual permit shall be required to conduct more
than one pilot test on any separate groundwater contaminant plume.
4) Air Injection Wells - Used to inject ambient air to enhance in -situ treatment of soil or groundwater.
5) In -Situ Thermal Wells (IST) — Used to `heat' contaminated groundwater to enhance remediation
Print Clearly or Type Information. Illegible Submittals Will Be Returned as Incomplete.
DATE: April 28, 2020 PERMIT NO. W10400548 (to be filled in by DWR)
NOTE- If this NOI is being submitted as notification of a modification of a previously issued NOI for this site (e.g.,
different injection wells, plume, additives, etc.) and still meets the deemed permitted by rule criteria, provide the
previously assigned permit tracking number and any needed relevant information to assess and approve injection:
Permit No. WI Issued Date:
A. WELL TYPE TO BE CONSTRUCTED OR OPERATED
(1) Air Injection Well.......................................Complete sections B through F, J, M
(2) Aquifer Test Well.......................................Complete sections B through F, J, M
(3) Passive Injection System...............................Complete sections B through F, H-M
(4) Small -Scale Injection Operation ......................Complete sections B through M
(5) X Pilot Test.................................................Complete sections B through M
(6) In -Situ Thermal (IST) Well...........................Complete all sections except K
B. STATUS OF WELL OWNER: Choose an item.
Deemed Permitted GW Remediation NOI Rev. 2-14-2020 Page 1

C. WELL OWNER(S) — State name of Business/Agency, and Name and Title of person delegated authority to
sign on behalf of the business or agency:
Name(s): Shannon Lloyd, Remediation Project Manager - Ashland, LLC
Mailing Address: 5475 Rings Road, Suite 500
City: Dublin State: OH Zip Code: 43017
County: Franklin
Day Tele No.: 614-790-2274 Cell No.:
614-315-7401
EMAIL Address: [e-mail] Fax No.:
D. PROPERTY OWNER(S) (if different than well owner/applicant)
Name and Title: Blake Jones, Vice President of Construction
Company Name Koury Corporation
Mailing Address: 2275 Vanstory Street, Suite 200
City: Greensboro State: _NC_ Zip Code: 27403
County: Guilford
Day Tele No.: 336 312 2387 Cell No.:
EMAIL Address: Fax No.:
E. PROJECT CONTACT (Typically Environmental Consulting/Engineering Firm)
Name and Title: Ryan Gerber, Senior Project Engineer
Company Name Arcadis G&M of North Carolina, Inc.
Mailing Address: 5420 Wade Park Boulevard
City: Raleigh State: NC Zip Code: 27607
County: Wake
Day Tele No.: 919-415-2265 Cell No.:
EMAIL Address: Rvan.aerberna.arcadis.com Fax No.:
F. PHYSICAL LOCATION OF WELL SITE
(1) Facility Name & Address: Koury Corporation
2800 Patterson Street (See Attachment 1— Figure 1)
City: Greensboro County: Guilford Zip Code: 27407
(2) Geographic Coordinates: Latitude": 360 3' 28.5" N or °
Longitude": 790 50' 21.6" W or °
Reference Datum: WGS84 Accuracy: 2 m (est.)
Method of Collection: Goo lg e Maps
"FOR AIR INJECTION AND AQUIFER TEST WELLS ONLY: A FACILITY SITE MAP WITH PROPERTY
BOUNDARIES MAY BE SUBMITTED IN LIEU OF GEOGRAPHIC COORDINATES.
G. TREATMENT AREA
Land surface area of contaminant plume: 1,227,448
Land surface area of inj. well network:
315
square feet
square feet (< 10,000 ft2 for small-scale injections)
Percent of contaminant plume area to be treated: <0.1% (must be < 5% of plume for pilot test injections)
Deemed Permitted GW Remediation NOI Rev. 2-14-2020 Page 2

H. INJECTION ZONE MAPS — Attach the following to the notification.
(1) Contaminant plume map(s) with isoconcentration lines that show the horizontal extent of the
contaminant plume in soil and groundwater, existing and proposed monitoring wells, and existing and
proposed injection wells; and
(2) Cross-section(s) to the known or projected depth of contamination that show the horizontal and vertical
extent of the contaminant plume in soil and groundwater, changes in lithology, existing and proposed
monitoring wells, and existing and proposed injection wells.
(3) Potentiometric surface map(s) indicating the rate and direction of groundwater movement, plus existing
and proposed wells.
DESCRIPTION OF PROPOSED INJECTION ACTIVITIES AT THE SITE — Provide a brief narrative
regarding the cause of the contamination, and purpose, scope, goals of the proposed injection activity:
As described in the Monitoring Well Installation and Enhanced Reductive Dechlorination Pilot Study
Work Plan (Arcadis 2019), the pilot study injection program will be performed to evaluate enhanced reductive
dechlorination (ERD,) as a potential remedial technology to reduce groundwater chlorinated volatile organic
compound (CVOC) concentrations, specifically trichloroethene (TCE), under site -specific hydrogeologic
conditions. The pilot study program will be conducted in the partially weathered rock (PWR)hydrostratigraphic
unit, which is believed to be the zone of highest mass transport. The layout for the pilot study is provided in
Attachment 1— Figure 2.
The ERD pilot study will consist of one injection of and emulsified vegetable oil (EVO) substrate (EOS
Pro). The EVO substrate will be diluted in a mixing tank to between 1 and 3 percent by volume with potable
water obtained from an on -site water source (a nearby hydrant was previously used to supply large volumes of
water to the Site). Additionally, a tracer dye (fluorescein) will be added to the injection solution to monitor the
direction and extent of groundwater flow from the injection well in the downgradient well network; the target
erection concentration will be 40 mg/L fluorescein. Injection well IW-1D will be screened from approximately
80 to 100 feet below ground surface; the actual screened interval will be determined during installation based on
field conditions. It is estimated that up to 7,500 ,gallons will be injected during the pilot study event to achieve
a target radius of influence of 10 feet.
The process flow diagram for the ERD pilot study is provided in Attachment 1 — Figure 3. The
erection system will be fitted with a ball valve, flow totalizer, and pressure gauge to monitor and control
injection volume and pressure. In addition, the injection wellhead assembly will include an air release valve to
prevent air entrainment in the formation and prevent in -well air lock duringthe he injection. The injection solution
will be delivered to the injection well using temporary above -,grade transfer hoses. The estimated flow rate is
approximately I gallon per minute under rgravity feed and/or low-pressure pumping conditions. The injection
pressure upper limit at the well head is less than 20 pounds per square inch (psi), though attempts will be made
to keep injection pressures below 5 psi while achieving adequate flow. During injections, dose -response well
MW-3413, located approximately 10 feet from the injection well, will be monitored for arrival of the injection
J. WELL CONSTRUCTION DATA
(1) No. of injection wells: 1 Proposed - Existing (provide NC Well
Construction Record (GW-1) for each well)
Deemed Permitted GW Remediation NOI Rev. 2-14-2020 Page 3

(2) Appx. injection depths (BLS): 80-100'
(3) For Proposed wells or Existing wells not having GW-1s, provide well construction details for each
injection well in a diagram or table format. A single diagram or line in a table can be used for
multiple wells with the same construction details. Well construction details shall include the
following (indicate if construction is proposed or as -built):
(a) Well type as permanent, Geoprobe/DPT, or subsurface distribution infiltration gallery
(b) Depth below land surface of casing, each grout type and depth, screen, and sand pack
(c) Well contractor name and certification number
Attachment 3 provides a summary of the planned construction details for injection well IW-lD. Injection well
IW-1D will be installed via rotosonic drilling methods by Cascade Environmental (NC Well Contractor
Certification Number 29928).
K. INJECTION SUMMARY
NOTE: Only injectants approved by the epidemioloa section of the NC Division of Public Health, Department
of Health and Human Services can be injected. Approved injectants can be found online at
hgp:Hdeq.nc.,gov/about/divisions/water-resources/water-resources-permits/wastewater-branch/ground-water-
protection/Uound-water-approved-injectants. All other substances must be reviewed by the DHHS prior to use.
Contact the UIC Program for more info i1you wish to get approval for a different additive. However, please
note it may take 3 months or longer.
Injectant: EOS Pro (1-3% v/v) Total Amt. to be injected (gal)/event: Up to 7,500 gallons
Injectant: Fluorescein dye (40 mg/L) Total Amt. to be injected (gal)/event: Up to 7,500 gallons
Injectant: Total Amt. to be injected (gal)/event:
Injectant: Total Amt. to be injected (gal)/event:
Injectant: Total Amt. to be injected (gal)/event:
Amt. Water to be injected (gal/event): Up to 500 gallons
Total Amt. to be injected (gal/event): Up to 8,000 ,gallons
No. of separate injection events: 1 Est. Total Amt. to be injected (gal): Up to 8,000 gallons
Source of Water (if applicable): On -site fire hydrant
L. MONITORING PLAN — Describe below or in separate attachment a monitoring plan to be used to determine
if violations of groundwater quality standards specified in Subchapter 02L result from the injection activity.
The Dronosed monitorinLy Drouram is included in Attachment. Baseline monitorinLy will occur prior to the Dilot
test. Post -injection monitoring will include: monthly monitoring at two wells (MW-34D and IW-lD,) for two
months following the injection event; quarterly monitoring at three wells (MW-19, MW-34D, and IW-1D) fo
two years following conclusion of monthly monitoring; and semi-annual monitoring at six wells (MW-2, MW-
2D, MW-2BR, MW-3, MW-12D, and MW-21,) for two years following the conclusion of quarterly monitoring.
During the baseline and post -injection performance monitoring events, samples from each monitoring well will
Deemed Permitted GW Remediation NOI Rev. 2-14-2020 Page 4

be analyzed for VOCs via USEPA Method 826013. In addition, samples from MW-2D, MW-19, MW-21, and
MW-34D will be analyzed for the following biogeochemical parameters: total organic carbon (TOC) via USEPA
Method 9060A, anions (nitrate and sulfate) via USEPA Method 300.0, dissolved iron via USEPA Method 6100;
and dissolved gases (,methane, ethane, and ethene) via AM20GAX. Samples from injection well IW-1 will be
analyzed for VOCs and biogeochemical parameters during the baseline monitoring event and TOC only during
performance monitoring events. Additionally, samples will be collected from MW-19 and MW-34D for anal
for fluorescein dye.
M. SIGNATURE OF APPLICANT AND PROPERTY OWNER
Well Owner/Applicant: "I hereby certify, under penalty of law, that I am familiar with the information
submitted in this document and all attachments thereto and that, based on my inquiry of those individuals
immediately responsible for obtaining said information, I believe that the information is true, accurate and
complete. I am aware that there are significant penalties, including the possibility of fines and imprisonment,
for submitting false information. I agree to construct, operate, maintain, repair, and if applicable, abandon the
injection well and all related appurtenances in accordance with the 15A NCAC 02C 0200 Rules. "
Jessica K. Lowder, Environmental Scientist II
of Applicant Print or Type Full Name and Title
Property Owner (if the property is not owned by the Well Owner/Applicant):
"As owner of the property on which the injection well(s) are to be constructed and operated, I hereby consent to
allow the applicant to construct each injection well as outlined in this application and agree that it shall be the
responsibility of the applicant to ensure that the injection well(s) conform to the Well Construction Standards
(15A NCAC 02C C. 0200). "
"Owner" means any person who holds the fee or other property rights in the well being constructed. A well
is real property and its construction on land shall be deemed to vest ownership in the land owner, in the
absence of contrary agreement in writing.
Blake Jones, Vice President - Construction Division
Signature* of Property Owner (if different from applicant) Print or Type Full Name and Title
*An access agreement between the applicant and property owner may be submitted in lieu of a signature on this form.
Please send I (one) hard color copy of this NOI along with a copy on an attached CD or Flash Drive at least
two (2) weeks prior to injection to:
DWR — UIC Program
1636 Mail Service Center
Raleigh, NC 27699-1636
Telephone: [phone]
Deemed Permitted GW Remediation NOI Rev. 2-14-2020 Page 5

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Figure 3
Proposed ERD Pilot Study Layout
Former Ashland Facility
Greensboro, North Carolina
PARCADIS built assets
ultancy
farnaturaland
built assets
MW-7S
MW-7M 1
MW 7D t
1 �
WAREHOUSE MW BR '
AND ;
1 OFFICE BUILDING MVy-3
1 1
IW-1 i
1 ,
i
i - 1
MW-34D
1 ,
MW-19 4 j
MW-21 �.
MW-2BR
MW-20 "�-
_J-
_J-
J
Legend
V Monitor Well
C�) ART Recovery Well
�H Railroad Tracks
0 Existing Area
Former Area
Former Spur
...... Property
N
0 Proposed Injection Well w/10-ft ROI
0 Proposed Dose -Response Well
0 30 60 120
Scale in Feet
Image Source: ArcGIS Online Services Hosted by ESHL

Figure 4
ERD Process Flow Diagram
Former Ashland Facility
Greensboro, North Carolina
00 ARCAD IS buiLta &Consultancy
for natural. and
built assets

8" MANHOLE, FLUSH MOUNT,
TRAFFIC -RATED H-20
2' x 2' x 6" CONCRETE PAD
GROUND SURFACE
0
LOCKING J-PLUG WELL CAP
8" BOREHOLE
2" PVC OUTER CASING
NEAT CEMENT
(PORTLANDTYPE 1/11)
76
U
76 LL
6" BOREHOLE
C0
t7
4" SCH 80 PVC RISER
Z
O
IX
BENTONITE SEAL
U
78 O
J
W
m
80 1j
W
FILTER SAND
2
H
a
w
0
4" 10-SLOT SCREEN (PVC)
LLH
100
FORMER ASHLAND LLC FACILITY
NOTES
GREENSBORO, NORTH CAROLINA
Diagram is not drawn to scale.
PROPOSED WELL CONSTRUCTION
Well construction details may be adjusted based on field conditions.
DIAGRAM FOR IW-1 D
04 ARCAD I S
FIGURE

Figure 6
Proposed Schedule
Former Ashland Facility
Greensboro, North Carolina
PARCADIS I beik"-15onsWtancy
fornataralaaE
built assets
Months From Injection
0
1
2
3
4
5
6
7
8
9
10
11 12
13
IM
26
27
Submit Work Plan
NCDEQ Review/Approval
Prepare/Submit UIC Permit
Application
Injection and Monitoring Well
Installation
Baseline Groundwater Sampling
Perform Pilot Study
Performance Monitoring
Submit Monitoring Data to NCDEQ
Electronically
Submit Annual Compliance
Monitoring Report
Prepare/Submit Final Evaluation
Report
a - Contingent upon finalizing contractor availability and/or approval of the work plan and UIC permit.

Table 1
Proposed ERD Pilot Study Performance Monitoring Program
Former Ashland Chemical Distribution Facility
Greensboro, North Carolina
F ARCADIS e�m �suu
Monitoring Event Baseline
VOCs
TOC
Anions
Dissolved Fe
Dissolved Gases
Tracer Dye
Field Parameters
X
---
---
---
---
---
X
X
X
X
X
X
---
X
X
---
---
---
---
---
X
X
---
---
---
---
---
X
---
---
---
---
---
---
---
X
X
X
X
X
---
I X
X
X
X
X
X
---
X
X
X
X
X
X
---
X
X
X
X
X
X
---
X
X
X
X
X
X
---
---
X
---
---
---
---
---
I ---
VOCs
---
---
---
---
---
X
---
X
X
TOC
---
X
X
X
---
Monthly
Anions
---
---
---
---
---
---
---
X
---
X
---
(Months 1 and 2)
Dissolved Fe
---
---
---
---
---
---
---
X
---
X
Dissolved Gases
---
---
---
---
---
---
---
X
---
X
---
Tracer Dye
---
---
---
---
---
---
---
X
---
---
---
Field Parameters_
---
---
---
---
---
---
---
X
---
---
---
VOCs
---
---
---
---
---
X
---
X
---
X
X
TOC
---
---
---
---
---
X
---
X
X
X
---
Quarterly
Anions
---
---
---
---
---
X
---
X
---
X
---
(Months 3, 9,
Dissolved Fe
---
---
---
---
---
X
---
X
---
X
---
15, and 21)
Dissolved Gases
---
---
---
---
---
X
---
X
---
X
---
Tracer Dye
---
---
---
---
---
X
---
X
---
X
---
Field Parameters
---
---
---
---
---
X
---
X
---
X
---
VOCs
X
X
X
X
X
X
X
X
---
X
X
TOC
---
X
---
---
X
X
X
X
X
Semiannual
Anions
---
X
---
---
X
X
X
---
X
(Months 6, 12,
Dissolved Fe
---
X
---
---
X
X
X
---
X
18, and 24)
Dissolved Gases
---
X
---
X
X
X
---
X
Tracer Dye
X
X
X
X
X
X
---
---
Field Parameters
X
X
X
Acronyms and Abbreviations:
Anions = Nitrate and sulfate by USEPA Method 300. If nitrate is not detected during the baseline sampling event, it will be removed from the monitoring program for future events.
Dissolved Fe = dissolved iron (by USEPA Method 3500). Sample will be field filtered with a 0.45-micron filter.
Dissolved gases = methane, ethane, and ethene (by RSK-175)
ERD = enhanced reductive dechlorination
Field parameters = temperature, pH, dissolved oxygen, oxidation-reduction potential, conductivity, and turbidity (by field meters)
QA/QC = quality assurance/quality control
TOC = total organic carbon (by USEPA Method 9060A)
USEPA = United States Environmental Protection Agency
VOC = volatile organic compound (by USEPA Method 8260B)
X = Proposed Sample
= Sample not collected
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