WQ0036621_Permit_20131016

S
_1
NORTH CAROLINA
ENVIRONMENTAL MANAGEMENT COMMISSION
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
RALEIGH, NORTH CAROLINA
PERMIT FOR THE OPERATION OF A WELL FOR INJECTION
In accordance with the provisions of Article 7, Chapter 87; Article 21, Chapter 143, and other
applicable Laws, Rules, and Regulations
PERMISSION IS HEREBY GRANTED TO
Weston Solutions, Inc.
FOR THE OPERATION OF 4 IN SITU REMEDIATION INJECTION/ EXTRACTION
WELLS, defined in Title 15A North Carolina Administrative Code 2C .0209(5)(b)(viii), to inject
Newman Zone — Buffered Nonionic Formulation for the, introduction of bioremediation nutrient
substances for the remediation of chlorinated volatile organic compounds. These injection
wells/points are located at the Cotton Mill Square site, 801 Merritt Drive, Greensboro, Guilford
County, North Carolina, and will be operated in accordance with the application submitted June
26, 2013, and in conformity with the specifications and supporting data subsequently submitted,
all of which are filed with the Department of Environment and Natural Resources and are
considered a part of this permit.
This permit is for Construction and Operation only, and does not waive any provisions of the
Water Use Act or any other applicable Laws, Rules, or Regulations. Operation and use of an
injection well shall be in compliance with Title 15A North Carolina Administrative Code 2T
.1600, and any other Laws, Rules, and Regulations pertaining to well construction and use.
This permit shall be effective, unless revoked, from the date of its issuance until October 31,
2018, and shall be subject to the specified conditions and limitations set forth in Parts I through
X hereof.
Permit issued this the 22nd day of November, 2013.
.for Thomas A. Reeder, Director
Division of Water Resources
By Authority of the Environmental Management Commission.
Permit No. WI0036621 PAGE 1 OF 7
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PART I - WELL CONSTRUCTION GENERAL CONDITIONS
1. The Permittee must comply with all conditions of this permit and with the standards and
criteria specified in Criteria and Standards Applicable to Injection Wells (15A NCAC 2C
.0200). Any noncompliance with conditions of this permit constitutes a violation of the
North Carolina Well Construction Act and is grounds for enforcement action_ as provided for
in N.C.G.S. 87-94.
2. This permit shall become voidable unless the facility is constructed in accordance with the
conditions of this permit, the approved plans and specifications, and other supporting data.
3. This permit is valid only for construction of the number of injection wells described in the
application and other supporting data. Construction of additional injection wells must be
approved in advance by the Water Quality Regional Operations Section.
4. Each injection well shall not hydraulically connect separate aquifers.
5. Each injection well shall be constructed in such a manner that water from land surface cannot
migrate into the gravel pack or well screen.
6. Each injection well shall be secured to reasonably insure against unauthorized access and
use. Each well shall be permanently labeled with a warning that it is for injection purposes
and the entrance to each well must be secured with a locking cap.
7. Each injection well shall be afforded reasonable protection against damage during
construction and use.
8. Each injection well shall have permanently affixed an identification plate.
PART II - WELL CONSTRUCTION SPECIAL CONDITIONS
1. At least forty-eight (48) hours prior to constructing each injection well, the Permittee shall
notify the Water Quality Regional Operations Section -Underground Injection Control (UIC)
Central Office staff, telephone number 919-807-6352 and the Winston-Salem Regional
Office Water Quality Regional Operations Section Staff, telephone number [phone].
2. Bentonite grout shall not be used to seal any water -bearing zone with a chloride
concentration equal to or greater than 1,500 milligrams per liter. In areas where elevated
chloride levels are known to exist or are probable, such as coastal areas, chloride levels shall
be verified in the field to determine existing conditions.
Permit No. WI0036621 PAGE 2 OF 7
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i
PART III - OPERATION AND USE GENERAL CONDITIONS
1. This permit is effective only with respect to the nature, volume of materials, rate of injection,
and number of injection wells as described in the application and other supporting data.
2. This permit is not transferable without prior notice to, and approval by, the Director of the
Division of Water Resources (Director). In the event there is a desire for the facility to
change ownership, or there is a name change of the Permittee, a formal permit amendment
request must be submitted to the Director, including any supporting materials as may be
appropriate, at least 30 days prior to the date of the change.
3. The issuance of this permit shall not relieve the Permittee of the responsibility of complying
with any and all statutes, rules, regulations, or ordinances that may be imposed by other
local, state, and federal agencies having jurisdiction. Furthermore, the issuance of this permit
does not imply that all regulatory requirements have been met.
PART IV - PERFORMANCE STANDARDS
1. The injection facility shall be effectively maintained and operated at all times so that there is
no contamination of groundwater which will render it unsatisfactory for normal use.
2. In the event that the facility fails to perform satisfactorily, including the creation of nuisance
conditions or failure of the injection zone to adequately assimilate the injected fluid, the
Permittee shall take immediate corrective actions including those actions that may be
required by the Division of Water Resources such as the repair, modification, or
abandonment of the injection facility. ti
3. The Permittee shall be required to comply with the terms and conditions of this permit even
if compliance requires a reduction or elimination of the permitted activity.
4. The issuance of this permit shall not relieve the Permittee of the responsibility for damages to
surface or groundwater resulting from the operation of this facility.
PART V - OPERATION AND MAINTENANCE REQUIREMENTS
1. The injection facility shall be properly maintained and operated at all times.
2. The Permittee must notify the Division and receive prior written approval from the Director
of any planned alterations or additions in the permitted facility or activity not specifically
authorized by the permit.
3. At* Ieast forty-eight (48) hours prior to the initiation of the operation of the facility for
injection, the Permittee must notify by telephone the Water Quality Regional Operations
Section-UIC, Central' Office staff, telephone number 919-807-6352. Notification is required
so that Division staff can inspect or otherwise review the injection facility and determine if it
is in compliance with permit conditions.
Permit No. WI0036621 PAGE 3 OF 7
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`LF i
PART VI - INSPECTIONS
1. Any duly authorized officer, employee, or representative of the Division of Water Resources
may, upon presentation of credentials, enter and inspect any property, premises, or place on
or related to the injection facility at any reasonable time for the purpose of determining
compliance with this permit, may inspect or copy any records that must be maintained under
the terms and conditions of this permit, and may obtain samples of groundwater, surface
water, or injection fluids.
2. Department representatives shall have _ reasonable access for purposes of inspection,
observation, and sampling associated with injection and any related facilities as provided for
in N.C.G.S. 87-90.
3. Provisions shall be made for collecting any necessary and appropriate samples associated
with the injection facility activities.
PART VII - APPLICABLE BOUNDARIES
The COMPLIANCE BOUNDARY for the disposal system is specified by regulations in 15A
NCAC 2L, Groundwater Classifications and Standards. The Compliance Boundary for the
disposal system individually permitted after December 30, 1983 is established at either (1)
250 feet from the waste disposal area, or (2) 50 feet within the property boundary, whichever
is closest to the waste disposal area. This is illustrated on Figure 1. An exceedance of Class
GA Standards at or beyond the Compliance Boundary is subject to remediation action
according to 15A NCAC 2L .0106(d) (2). Please be aware that the Compliance Boundary
designation refers to the injectant substances and not the contaminant plume.
2. The REVIEW BOUNDARY is established around the disposal systems midway between the
Compliance Boundary and the perimeter of the waste disposal area. An exceedance of Class
GA Standards at the Review Boundary may require action in accordance with 15A NCAC 2L
.0106(d) (1). Please be aware that the Review Boundary designation refers to the injectant
substances and not the contaminant plume.
PART VIII - MONITORING AND REPORTING REQUIREMENTS
1. The proposed monitoring plan included in the application shall be followed with some
modification. The monitoring will consist of sampling existing wells DW-10-dl, EW-511,
and MW-36-s (for Zone 1); and DW-02-dl, DW-06-d1, MW-13-s, and MW-14-s (for Zone
3) for Chloride, Conductivity, Dissolved Oxygen, pH, ReDox (ORP), Sulfate, Temperature,
Total Iron, Total Organic Carbon, and Volatile Organic Compounds before the injections
begin and thereafter- every six months (twice every year) for at least two years. The
parameters of Nitrate Nitrogen and Nitrite Nitrogen shall be sampled during the final
sampling event. Any additional monitoring, including groundwater, surface water, or soil
sampling, deemed necessary by the Division of Water Resources to ensure surface water and
groundwater protection may be established and an acceptable sampling reporting schedule
shall be followed.
Permit No; W-IO036621 PAGE 4 OF 7
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PART IX - PERMIT RENEWAL
In order to continue uninterrupted legal use of the injection facility for the stated purpose, the
Permittee must submit an application to renew the permit 120 days prior to its expiration date.
PART X - CORRECTIVE ACTION
1. Any injection well not constructed or operated in accordance with this permit, or the criteria
and standards specified in 15A NCAC 02C .0200, shall be subject to corrective action as
provided for in rule 15A NCAC 02C .0206.
2. The following corrective actions shall apply to elevated concentrations of injectants or
reaction byproducts resulting from the permitted injection activity:
a. Continued monitoring until concentrations return to pre -injection values or meet the
standards specified in 15A NCAC 02L .0202, whichever are greater. The frequency,
duration, and location of monitoring shall be appropriate for site specific conditions
and potential receptors.
b. Groundwater quality parameters that do not attenuate as described in 2a above may
warrant a corrective action plan as provided for in rule 15A NCAC 02C .0206,
depending on the type, concentration, and distribution of the groundwater quality
standards being exceeded.
PART XI - CHANGE OF WELL STATUS
1. The Permittee shall provide written notification within 15 days of any change of status of an
injection well. Such a change would include the discontinued use of a well for injection. If a
well is taken completely out of service temporarily, the Permittee must install a sanitary seal.
If a well is not to be used for any purpose that well must be permanently abandoned
according to 15A NCAC 2C .0240, Well Construction Standards.
2. When operations have ceased at the facility and a well will no longer be used for any
purpose, the Permittee shall abandon that injection well in accordance with the procedures
specified in 15A NCAC 2C .0240, including but not limited to the following:
(A) All casing and screen materials may be removed prior to initiation of abandonment
procedures if such removal will not cause or contribute to contamination of the
groundwaters.
(B) The entire depth of each well shall be sounded before it is sealed to insure freedom
from obstructions that may interfere with -sealing operations.
(C) The well shall be thoroughly disinfected, prior to sealing, if the Director determines
that failure to do so could lead to the contamination of an underground source of
drinking water.
Permit No. WI0036621 PAGE 6 OF 7
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2. All sample results shall be submitted to the Water Quality Regional Operations Section's
Winston-Salem Regional Office and the Raleigh Central Office annually. Monitoring reports
shall include, at a minimum, analytical data and an update on the status and location of
monitoring and injection wells. Well locations may be given in a table with the name and
geographic coordinates or shown on an updated version of the surveyor's base map.
3. Within 30 days of completion of well construction, a complete Well Construction Record
(Form GW-1) shall be submitted to the addresses specified in Part VII.6 below.
4. The Permittee shall submit an Injection Event Record within 30 days of completing each
injection.
5. The Permittee shall submit a final project evaluation within 9 months after completing all
injection -related activity associated with this permit, or produce an interim evaluation to be
submitted with a renewal application for this permit. Both the final project evaluation and
interim evaluation shall contain historical monitoring data and updated contaminant plume
and potentiometric surface maps. PLEASE NOTE: Prior to closing this permit, the Permittee
must meet groundwater quality standards or pre -injection levels, whichever concentration is
higher, for all of the injection constituents; otherwise, continued monitoring as approved in
the monitoring plan will be required until such levels can be established.
6. All monitoring results, forms, and reports required in this Part shall be submitted to:
UIC Program Staff DWR - WQROS
DWR — WQROS and Winston-Salem Regional Office
1636 Mail Service Center 585 Waughtown Street
Raleigh, NC 27699-1636 Winston-Salem, NC 27107
7. The Permittee shall report by telephone, within 48 hours of the occurrence or first knowledge
of the occurrence, to the Winston-Salem Regional Office, telephone number [phone],
any of the following:
(A)Any occurrence at the injection facility which results in any unusual operating
circumstances;
(B) Any failure due to known or unknown reasons, that renders the facility incapable of
proper injection operations, such as mechanical or electrical failures.
8. Where the Permittee becomes aware of an omission of any relevant facts in a Ipermit
application, or of any incorrect information submitted in said application or in any report to
the Director, the relevant and correct facts or information shall be promptly submitted to the
Director by the Permittee.
9. In the event that the permitted facility fails to perform satisfactorily, the Permittee shall take
such immediate action as may be required by the Director.
Permit No. W10036621 PAGE 5 OF 7
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(D) Drilled wells shall be completely filled with cement grout or bentonite grout, which
shall be introduced into the well through a pipe which extends to the bottom of the
well and is raised as the well is filled.
(E) In the case of gravel -packed wells in which the casing and screens have not been
removed, neat -cement, or bentonite grout shall be injected into the well completely
filling it from the bottom of the casing to the top.
(F) In those cases when, as a result of the injection operations, a subsurface cavity has
been created, each well shall be abandoned in such a manner that will prevent the
movement of fluids into or between underground sources of drinking water and _ in
accordance with the terms and conditions of the permit.
(G) The Permittee shall submit a Well Abandonment Record (Form GW-30) as specified
in 15A NCAC 2C .0225(k) (1) (A) within 30 days of completion of abandonment.
3. The written documentation required in Part IX (1) and (2) (G) shall be submitted to:
Water Quality Regional Operations Section-UIC Program
DENR-Division of Water Resources
1636 Mail Service Center
Raleigh, NC 27699-1636
PART XII — WORKER PRECAUTIONS DURING APPLICATION
1. Some effects reported to be associated with the product proposed to be used are as follows:
eye, skin, nose, throat, and lung irritation. If the product is released into the environment in a
way that could result in a suspension of fine solid or liquid particles (e.g., grinding, blending,
vigorous shaking or mixing), then proper personal protective equipment should be used. The
application process should be reviewed by an industrial hygienist to ensure that the most
appropriate personal protective equipment is used.
2. Persons working with these products should wear goggles or a face shield, gloves, and
protective clothing. Face and body protection should be used for anticipated splashes or
sprays.
3. Eating, drinking, smoking, handling contact lenses, and applying cosmetics should not be
permitted in the application area during or immediately following application.
4. Safety controls should be in place to ensure that the check valve and the pressure delivery
. systems are working properly.
5. The Material Safety Data Sheets should be followed to prevent incompatible or adverse
reactions and injuries.
Permit No. W10036621 PAGE 7 OF 7
ver. 10/16/2013 UIC-5I/5T

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40 EXISTING -WELL PROPOSED FOR INJECTION
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Scale in Feet
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1 inch = 200 Feet
FIGURE 1
WESTON SOLUTIONS, INC.
COTTON MILL SQUARE
GROUNDWATER REMEDIATION PERMIT
GUILFORD COUNTY
WC10036621
WELL LOCATION MAP

EXECUTIVE SUMMARY SHEET
FOR THE COTTON MILL SQUARE SITE IN GUILFORD COUNTY
1. Rescission of Existing Permit WQ0029385
The permittee wishes to rescind existing groundwater remediation system Permit WQ0029385,
which was most recently issued on November 3, 2006. This permit allows the establishment and
operation of a 28,800 GPD "closed -loop" recirculation in -situ bioremediation system to treat
ground water over a large area contaminated with chlorinated solvents. The permitted system
used 10 injection wells and 14 extraction wells to treat an impacted area of approximately 12
acres.
The remediation system is currently inactive and a system abandonment plan has been
submitted. Written notification of consent to rescind the permit from the oversight agency, the
Division of Waste Management's Inactive Sites Branch, has been received, meeting the closure
requirement of 15A NCAC 02T .1608(a)(2) so that closure can proceed.
A new permit is being requested because the existing system has served its purpose and the
forthcoming remediation activity is on a much smaller scale than the activity that took place
under the existing permit (the forthcoming action has a maximum total injection volume of
16,500 gallons, whereas the previous system was operating on a capacity limit of 28,800 gallons
per day for more than 5 years).
2. Issuance of New Permit WQ0036621
The new permit is for further groundwater remediation consisting of extraction and subsequent
injection activities. Contaminated ground water will be extracted from existing well EW-509 in
Zone 1. This water, combined with potable water (if needed) to-achieve_a_ 1:4 to 1 10 dilution
factor with the Newman Zone injectant, will be injected into ells EW-509 and IW�-20011,.In Zone
3, contaminated ground water will be extracted from existing wells EW-512, IW-206, and,IW-
210, and a similar mixture (which may contain potable water) will be_made by adding the
Newman Zone injectant and will be injected into wells I 05 and IW-206.
The Compliance Boundary for these extraction/injection wells is established at 250 feet from
each well, or 50 feet inside the property boundary (see Figure 1). The monitoring wells for this
remediation permit are all situated outside of the areas enclosed by the Compliance Boundaries.
Monitoring will be performed in wells situated outside of the Compliance Boundary in wells
DW-10-d1, EW-511, and MW-36-s (for Zone 1); and in wells DW-02-d1, DW-06-d1, MW-13-s,
and MW-14-s (for Zone 3).

DIVISION OF WATER QUALITY
AQUIFER PROTECTION SECTION
November 13, 2013
PERMIT ISSUANCE MEMO
TO: Debra Watts
THROUGH: Thomas Slusser
FROM: David Goodrich
RE: Permit To Inject Newman Zone
Cotton Mill Square property
I recommend that Permit Number WQ0036621 be issued to Weston Solutions, Inc. to inject Newman Zone and
simultaneously operate extraction wells to remediate soils and groundwater contaminated with chlorinated volatile
organic compounds (CVOCs).
SITE DESCRIPTION The site is a former Alcatel -Lucent industrial facility which experienced releases at three
locations (Zones 1, 2 and 3). The contaminant plumes are reportedly stable at this time.
HYDROGEOLOGIC DESCRIPTION The site is situated in the Piedmont Physiographic Province ofthe state and
is geologically situated in the Carolina Slate Belt. The bedrock is. composed of megacrystic and well -foliated
metamorphosed granitic rock, overlain by saprolite materials of varying thickness (0 to 70 feet). The depth to water
across the site ranges from approximately 3 feet to 37 feet, and the surficial shallow aquifer appears to have a
horizontal hydraulic gradient of approximately 0.017. The intermittent and deep aquifer units have comparable
hydraulic gradients. Based on an average hydraulic conductivity of 0.153 ft/day in the shallow saprolite aquifer unit,
the average groundwater flow rate in the upper aquifer unit is estimated to be 0.017 ft/day. Using the respective values
pertaining to the intermediate and deep aquifer zones provided by the applicant, the respective flow rates for these
aquifer units are approximately 0.14 ft/day and 0.25 ft/day.
EXTENT OF CONTAMINATION The size of the area impacted by the chemical releases is different for each of
the three aquifer zones. The shallow aquifer has an impacted area which measures approximately 1000 ft wide
(average) by 1000 feet long (Figure E-5); the intermediate/transitional aquifer zone has an impacted area which
measures approximately 900 ft wide (average) by 2600 feet long (Figure E-6); and the deep aquifer zone has an
impacted area which measures approximately 1000 ft wide by 1700 feet long (Figure E-7). The contaminated ground
water extends into the bedrock aquifer zone to a total depth of approximately 100 feet below ground surface (Figures
C-2, C-3, C-4, and C-5). The total volume of impacted groundwater is estimated to be approximately 8.5 million
cubic feet, or approximately 64 million gallons.
PROPOSED INJECTION The inj ectant is approved by the Division and is known as Newman Zone — Buffered
Nonionic Formulation. It will be injected into 4 wells, and extraction will take place from two of the same wells and
from two other wells prior to injection to provide the water for the injections. The injection wells (and extraction
wells) are all permanent. A maximum total injection volume of 16,500 gallons is anticipated into the 4 wells. The
total injected volume is equivalent to less than one four thousandth of the volume of groundwater impacted by the
contaminant substances.
HOW IT WORKS The injectant is primarily composed of food grade soybean oil, water, sodium —L-lactate,
sodium bicarbonate, and proprietary additives, emulsifiers and preservatives. It serves to feed native microbes for the
facilitation of bioremediation within the subsurface.

MONITORING The proposed monitoring plan was initially based on the monitoring included in the
Remedial Action Plan submitted for the Division of Waste Management in June of 2012. This plan has been modified
whereby the number of monitoring wells has been diminished, and the parameters have been modified in accordance
with the recommendations of the APS Regional Office and the Central Office. Monitoring will consist of a single pre -
injection sampling event and post -injection sampling events every six months at wells DW-10-d1, EW-511, and MW-
36-s (for Zone 1); and at wells DW-02-d1, DW-06-d1, MW-13-s and MW-14-s (for Zone 3) for Water Level,
Chloride, Total Iron, Temperature, Sulfate, pH, ReDox (ORP), Volatile Organic Compounds, Total Organic Carbon,
Conductivity, and Dissolved Oxygen. The final sampling event will include sampling for Nitrate Nitrogen, Oil &
Grease, and Nitrite Nitrogen. Post -injection monitoring will be performed for at least two years.
EPIDEMIOLOGY On October 7, 2004, the DHHS' Epidemiology Branch provided comments on Newman
Zone for groundwater remediation. Dr. Luanne K. Williams did not present any information that would preclude the
use of these products for injection, but did provide a health risk analysis and worker safety precautions, which are in
Part X of the attached permit. -
REGIONAL OFFICE COMMENTS Shuying Wang of the Winston-Salem Regional Office recommended issuance of
this permit. The Regional Office noted the absence of a specific monitoring plan in the application package, and
recommended several parameters. The monitoring plan was subsequently. provided, and has been adjusted with input
from the Central Office.

Central Files: APS SWP
10/17/13
Permit Number WQ0036621 Permit Tracking Slip
Program Category Status Project Type
Non -discharge In review New Project
Permit Type Version Permit Classification
Groundwater Remediation A individual
Primary Reviewer Permit Contact Affiliation
david.goodrich Steve E. Johnson
Manager Project Senior
Coastal SW Rule 1400 Weston Way
West Chester PA 19380
Permitted Flow
Facility
Facility Name Major/Minor Region
Cotton Mill Square Site (CMS) Minor Winston-Salem
Location Address
Se Of Spring Garden St Merritt Dr
Greensboro NC 27407
Owner
County
Guilford
Facility Contact Affiliation
Owner Name Owner Type
Weston Solutions Inc Non -Government
Owner Affiliation
Jaikishen N. Motwani
President Vice
1400 Weston Way
Dates/Events West Chester PA 19380
Scheduled
Orig Issue App Received Draft Initiated Issuance Public Notice Issue Effective Expiration
06/26/13
Regulated Activities Requested/Received Events
Groundwater remediation RO staff report requested
07/02/13
Additional information requested
07/03/13
RO staff report received
07/16/13
Additional information received
07/23/13
Additional information received
07/24/13
Additional information received
07/24/13
Other agency comments received
07/26/13
Other agency comments requested
07/26/13
Other agency comments received
08/27/13
Additional information requested
09/16/13
Additional information received
10/02/13

Additional information requested
Additional information received
Outfall NULL
Central Files: APS SWP
10/17/13
10/08/13
10/09/13
Waterbody Name Stream Index Number Current Class Subbasin

NORTH CAROLINA --
ENVIRONMENTAL MANAGEMENT COMMISSION
DEPARTMENT OF ENVIRONMENTAL QUALITY
RALEIGH, NORTH CAROLINA
PERMIT FOR THE USE OF A WELL FOR INJECTION
In accordance with the provisions of Article 7, Chapter 87; Article 21, Chapter 143; and other
applicable Laws, Rules, and Regulations
PERMISSION IS HEREBY GRANTED TO
WESTON SOLUTIONS
Guilford County
FOR THE
continued operation of four (4) in -situ remediation injection/extraction wells defined in Title 15A
North Carolina Administrative Code 2C .0209(5)(b)(viii), to inject diluted Newman Zone
emulsified vegetable oil (EVO) for the remediation of chlorinated volatile organic compounds
(VOCs). These injection wells/points are located the Cotton Mill Square Site, 801 Merritt Drive
Greensboro, Guilford County, NC, and will be operated in accordance to the application received
October 26, 2018, and subsequent additional information received by the Division of Water
Resources (Division) on February 1, 2019, and in conformity with the specifications, and
supporting data subsequently submitted, all of which are filed with the Department of
Environmental Quality and are considered a part of this permit.
This permit is for Operation only, and does not waive any provisions of the Water Use Act or any
other applicable Laws, Rules, or Regulations. Operation and use of an injection well shall be in
compliance with Title 15A North Carolina Administrative Code 02T .1600, and any other Laws,
Rules, and Regulations pertaining to well construction and use.
This permit shall be effective, unless revoked, from the date of issuance until January 31, 2024,
and shall be subject to the specified conditions and limitations set forth in Parts I through XI
thereof.
Permit issued this the day of -( 2019
6&c�- ) _ uJ
ll�*
For Linda Culpepper, Director
Division of Water Resources
By Authority of the Environmental Management Commission.
Permit No. WQ0036621 PAGE I OF 7
ver. 2-25-2016 UIC-5I/5T

PART I — PERMIT GENERAL CONDITIONS
1. The Permittee shall comply with all conditions of this permit and with the standards and criteria
specified in Criteria and Standards Applicable to Injection Wells (15A NCAC 2C .0200).
Noncompliance with conditions of this permit constitutes a violation of the North Carolina
Well Construction Act and is grounds for enforcement action as provided for in N.C.G.S. 87-
94.
2. This permit shall become voidable unless the facility is constructed in accordance with the
conditions of this permit, the approved plans and specifications, and other supporting data [I 5A
NCAC 02C .0211(1)].
3. This permit is valid only for construction or operation of the number of injection wells
described in the application and other supporting data. Construction of additional injection
wells must be approved in advance by the Division of Water Resources (DWR) [15A NCAC
.0211(a)].
4. This permit is not transferable without prior notice and approval. In the event there is a desire
for the facility to change ownership, or there is a name change of the Permittee, a formal permit
amendment request and any supporting materials must be submitted at least 30 days prior to
the date of the change [15A NCAC 02C .0211(q)].
5. The issuance of this permit shall not relieve the Permittee of the responsibility of complying
with any and all statutes, rules, regulations, or ordinances that may be imposed by other local,
state, and federal agencies having jurisdiction. Furthermore, the issuance of this permit does
not imply that all regulatory requirements have been met [15A NCAC 02C .0203].
PART II - WELL CONSTRUCTION GENERAL CONDITIONS
Each injection well shall not hydraulically connect separate aquifers [15A NCAC 02C
.0211(c)]. -
2. Multi -screened wells shall not hydraulically connect different aquifers or zones having
differences in water quality that would result in a degradation of any aquifer or zone [15A
NCAC 02C .0225(g)(17)].
3. Each injection well shall be constructed in such a manner that water from land surface cannot
migrate into the gravel pack or well screen [15A NCAC 02C .0225(g)(4)].
4. Bentonite grout shall not be used to seal any water -bearing zone with a chloride concentration
equal to or greater than 1,500 milligrams per liter. In areas where elevated chloride levels are
known to exist or are probable, such as coastal areas, chloride levels shall be verified in the
field to determine existing conditions. [15A NCAC .0225(g)(8)].
Each injection well shall be secured to reasonably insure against unauthorized access and use.
Each well shall be permanently labeled with a warning that it is for injection purposes and the
entrance to each well shall be secured with a locking cap as defined in G.S. 87-85(16) [15A
NCAC 02C .0225(g)(23)].
Permit No. WQ0036621 PAGE 2 OF 7
ver. 2-25-2016 UIC-5I/5T

6. Each injection well shall be afforded reasonable protection against damage during construction
and use [15A NCAC 02C .0225(i)(3)].
7. Each permanent injection well shall have a permanently affixed identification plate [15A
NCAC .0225(g)(20)].
PART III - WELL CONSTRUCTION SPECIAL CONDITIONS
At least forty-eight (48) hours prior to constructing or operating any injection well, the
Permittee shall notify the Underground Injection Control (UIC) Central Office staff, telephone
number 919-807-6406, and the Winston-Salem Regional Office staff, telephone number 336-
776-9800 [15A NCAC 02C .0211(k)].
PART IV - OPERATION AND USE CONDITIONS
1. The Permittee shall be required to comply with the terms and conditions of this permit even
if compliance requires a reduction or elimination of the permitted activity [ 15A NCAC 02C
.02110)].
2. The issuance of this permit shall not relieve the Permittee of the responsibility for damages
to surface water or groundwater resulting from the operation of this facility [ 15A NCAC 02C
.0206].
3. The injection facility shall be properly maintained and operated at all times to achieve
compliance with the conditions of this permit and the rules of 15A NCAC 02C .0200, even
if compliance requires a reduction or elimination of the permitted activity [ 15A NCAC 02C
.02110)].
4. In the event that the facility fails to perform satisfactorily, including the creation of nuisance
conditions or failure of the injection zone to adequately assimilate the injected fluid, the
Permittee shall take immediate corrective actions that may be required, such as the repair,
modification, or abandonment of the injection facility [15A NCAC 02C .0206].
PART V - INSPECTIONS [ 15A NCAC 02C .0211(k)]
Any duly authorized officer, employee, or representative of the Division of Water Resources
(DWR) may, upon presentation of credentials, enter and inspect any property, premises, or
place on or related to the injection facility at any reasonable time for the purpose of determining
compliance with this permit, may inspect or copy any records that must be maintained under
the terms and conditions of this permit, and may obtain samples of groundwater, surface water,
or injection fluids.
2. DWR representatives shall have reasonable access for purposes of inspection, observation, and
sampling associated with injection and any related facilities as provided for in N.C.G.S. 87-
90.
3. Provisions shall be made for collecting any necessary and appropriate samples associated with
Permit No. WQ0036621 PAGE 3 OF 7
ver. 2-25-2016 UIC-5I/5T

the injection facility activities.
PART VI. - APPLICABLE BOUNDARIES
1. The COMPLIANCE BOUNDARY for the waste disposal area is specified by regulations in
15A NCAC 2L, Groundwater Classifications and Standards. The Compliance Boundary for
the disposal system individually permitted after December 30, 1983 is established at either (1)
250 feet from the waste disposal area, or (2) 50 feet within the property boundary, whichever
is closest to the waste disposal area. This is illustrated on Figure 1. An exceedance of Class
GA Standards at or beyond the Compliance Boundary is subject to remediation action
according to 15A NCAC 2L .0106(d)(2). Please be aware that the Compliance Boundary
designation refers to the injectant substances and not the contaminant plume.
2. The REVIEW BOUNDARY is established around the waste disposal area midway between
the Compliance Boundary and the perimeter of the waste disposal area. Any exceedance of
Class GA Standards at the Review Boundary may require action in accordance with 15A
NCAC 2L .0106(d)(1). Please be aware that the Compliance Boundary designation refers to
the injectant substances and not the contaminant plume.
PART VII. - MONITORING AND REPORTING REQUIREMENTS
1. Permit monitoring and reporting requirements are suspended while the injection wells are not
in operation. The Division shall be notified in writing thirty (30) days prior to operation of the
system. These requirements will begin when system operation begins. Please note that
monitoring and reporting requirements suspended by this permit do not affect monitoring and
reporting that may be required by any other permit or corrective action plan at this site.
2. If re -injection recommences, the monitoring will consist of sampling the following existing
wells prior to injection and every six (6) months thereafter for at least two (2) years: DW-10-
dl, EW-511, and MW-36-s (for Zone 1); and DW-02-dl, DW-06-dl, MW-13-s, and MW-14-
s (for Zone 3). Parameters shall include Chloride, Conductivity, Dissolved Oxygen, pH,
ReDox (ORP), Sulfate, Temperature, Total Iron, Total Organic Carbon, and Volatile Organic
Compounds (VOCs). The parameters of Nitrate Nitrogen and Nitrite Nitrogen shall be
sampled during the final sampling event. Any additional monitoring, including groundwater,
surface water, or soil sampling, deemed necessary by the Division of Water Resources to
ensure surface water and groundwater protection may be established and an acceptable
sampling reporting schedule shall be followed.
3. An Annual Report with all historical monitoring results shall be submitted in bound hard copy
format with attached CD or flash drive to the WQROS Central Office, and Winston-Salem
Regional Office starting from date permit is issued. Monitoring reports shall include, a
summary of injection activities and monitoring results, analytical data presented in a
spreadsheet distinguishing between pre -injection and post injection data, and an update on the
status and location of monitoring and injection wells. Well locations may be given in a table
with the name and geographic coordinates or shown on an updated version of the site map
[15A NCAC 02C .0225(k)(2)].
4. Records of well construction, repair, or abandonment shall be submitted within 30 days of
completion of such activities [15A NCAC 02C .0225(k)(1)(A)].
Permit No. WQ0036621 PAGE 4 OF 7
ver. 2-25-2016 UIC-5I/5T

5. An Injection Event Record shall be submitted within 30 days of each injection event [15A
NCAC 02C .0225(k)(1)(B)].
6. The Permittee shall submit a Final Project Evaluation (FPE) within 9 months after completing
all injection -related activity associated with this permit or produce an interim evaluation to be
submitted with a renewal application for this permit. Both the final project evaluation and
interim evaluation shall contain historical monitoring data and updated contaminant plume and
potentiometric surface maps. PLEASE NOTE: Inj ectants and related reaction byproducts must
attenuate to pre -injection concentrations or groundwater standards specified in rule 15A NCAC
02L .0202, whichever is greater, in order for this permit to be closed. Otherwise, corrective
action may be required [15A NCAC 02C .0225(k)(2)].
7. All monitoring results, forms, and reports required in this Part shall be submitted to:
UIC Program Water Quality Regional Operations Section
NC Division of Water Resources and DWR Winston-Salem Regional Office
1636 Mail Service Center 450 W. Hanes Mill Road, Suite 300
Raleigh, NC 27699-1636 Winston-Salem, NC 27105
8. The Permittee shall report any monitoring or other information that indicates noncompliance
with a specific permit condition, that a contaminant may cause a violation of applicable
groundwater quality standards, or that a malfunction of the injection system may cause the
injected fluids to migrate outside the approved injection zone or area. As specified in rule 15A
NCAC 02C .0211(r), noncompliance notification shall be as follows:
(A) Oral notification shall be given within 24 hours of the occurrence, or first knowledge of
the occurrence, to the Winston-Salem Regional Office, telephone number 336-776-9800.
- (B) Written notification shall be made within five days of the occurrence and submitted to the
addresses in Item #6 above.
(C) The written notification shall contain a description of the noncompliance and its cause;
the period of noncompliance, including dates and times; if the noncompliance has not
been corrected, the anticipated time it is expected to continue; and any steps taken or
planned to reduce, eliminate, and prevent reoccurrence of the noncompliance.
9. Where the Permittee becomes aware of an omission of any relevant facts in a permit
application, or of any incorrect information submitted in said application or in any report to
the Director, the relevant and correct facts or information shall be promptly submitted to the
Director by the Permittee [15A NCAC 02C .0211(b)].
PART VIII - CORRECTIVE ACTION [ 15A NCAC 02C .0206]
1. Any injection well not constructed or operated in accordance with this permit, or the criteria
and standards specified in 15A NCAC 02C .0200, shall be subject to corrective action as
provided under rule 15A NCAC 02C .0206.
2. The following corrective actions shall apply to elevated concentrations of inj ectants or reaction
Permit No. WQ0036621 PAGE 5 OF 7
ver. 2-25-2016 UIC-5I/5T

byproducts resulting from the permitted injection activity:
(A) Continued monitoring until concentrations return to pre -injection values or meet the
standards specified in 15A NCAC 02L .0202, whichever are greater. The frequency,
duration, and location of monitoring shall be appropriate for site specific conditions and
potential receptors.
(B) Groundwater quality parameters that do not attenuate as described in 2(A) above may
warrant a corrective action plan as provided under rule 15A NCAC 02C .0206, depending
on the type, concentration, and distribution of the groundwater quality standards being
exceeded.
PART IX - PERMIT RENEWAL [ 15A NCAC 02C .021 I (b)]
In order to continue uninterrupted legal use of the injection facility for the stated purpose, the
Permittee should submit an application to renew the permit 120 days prior to its expiration date.
PART X - CHANGE OF WELL STATUS [I 5A NCAC 02C .0240]
1. The Permittee shall provide written notification within 15 days of any change of status of an
injection well. Such a change would include the discontinued use of a well for injection. If a
well is taken completely out of service temporarily, the Permittee must install a sanitary seal.
If a well is not to be used for any purpose that well must be permanently abandoned according
to 15A NCAC 2C .0240, Well Construction Standards.
2. When operations have ceased at the facility and a well will no longer be used for any purpose,
the Permittee shall abandon that injection well in accordance with the procedures specified in
15A NCAC 2C .0240, including but not limited to the following:
(A)All casing and screen materials may be removed prior to initiation of abandonment
procedures if such removal will not cause or contribute to contamination of the
groundwaters.
(B) The entire depth of each well shall be sounded before it is sealed to insure freedom
from obstructions that may interfere with sealing operations.
(C) The well shall be thoroughly disinfected, prior to sealing, if WQROS staff determines
that failure to do so could lead to the contamination of an underground source of
drinking water.
(D) Drilled wells shall be completely filled with cement grout or bentonite grout, which
shall be introduced into the well through a pipe which extends to the bottom of the well
and is raised as the well is filled.
(E) In the case of gravel -packed wells in which the casing and screens have not been
removed, neat -cement, or bentonite grout shall be injected into the well completely
filling it from the bottom of the casing to the top.
Permit No. WQ0036621 PAGE 6 OF 7
ver. 2-25-2016 UIC-5M

(F) In those cases when, as a result of the injection operations, a subsurface cavity has been
created, each well shall be abandoned in such a manner that will prevent the movement
of fluids into or between underground sources of drinking water and in accordance with
the terms and conditions of the permit.
(G)The Permittee shall submit a Well Abandonment Record (Form GW-30) as specified
in 15A NCAC 2C .0225(k)(1)(A) within 30 days of completion of abandonment.
PART XI — WORKER PRECAUTIONS DURING APPLICATION [I 5A NCAC 02C
.0225(a)]
1. Some effects reported to be associated with the product proposed to be used are as follows:
eye, skin, nose, throat, and lung irritation. If the product is released into the environment in a
way that could result in a suspension of fine solid or liquid particles (e.g., grinding, blending,
vigorous shaking or mixing), then proper personal protective equipment should be used. The
application process should be reviewed by an industrial hygienist to ensure that the most
appropriate personal protective equipment is used.
2. Persons working with these products should wear goggles or a face shield, gloves, and
protective clothing. Face and body protection should be used for anticipated splashes or
sprays.
3. Eating, drinking, smoking, handling contact lenses, and applying cosmetics should not be
permitted in the application area during or immediately following application.
4. Safety controls should be in place to ensure that the check valve and the pressure delivery
systems are working properly.
Permit No. WQ0036621 PAGE 7 OF 7
ver. 2-25-2016 UIC-51/5T

'Legend
_ Injection Well
Extraction Well
Saprolite Monitor Well N
® Intermediate Zone, Monitor Well
Bedrock Monitor Well
;� -• . _ _., - __,. Abandoned'Saprolite Monitor Well.
r _ -, a Abandoned Intermediate
r Y Zone, Monitor Well
Zone 3 -
"rMI,-407
RN-2,o
ri r Abandoned Bedrock Monitor Well
I
}+�;\_ mFao3., �Rw3? t ® Surface Water Monitoring Locations
Zone 9 _`�' Cotton Mill Square Boundary . (%�_.9 - 0N-001-h .. IVY4 'ML406� ,.MF409DW-0541 .,_.., - -
1 DW-,4�d2 ` _. _ r - ...._
' '�MF402 ML408 - "(D'Pwo"i Buildings/Roads
�EWS12
EMU y Y" A7W.au ^- .., _
"wD�� MW-0478 r 0 Injection Well
M '- {';' iwwa37-sz raw-38 �'' W.n:, �M,"'2 - - • p Compliance Monitoring Well
W1a-s r _ Compliance Boundary (Approx.)
I'NM17 2_h,pSvad„.� MW-,3-s _ Zone 4 r - 0 -
rQSD ION-203 . MF204 Feet
• - .. '1041' :. MW01, r BMW-26.9 M •�
Mw.'•; "w-2� 1 inch = 300;Feet
_ r
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- - 'IW299; """`°'� �In ecfion Well & Com liance
. _g .. ; iw zo7 Iw-z°6 Ew so7 1 p
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Zone,2 •"'�w EW306 \ W.oa �� 8W.o.3 ...::u -•;,;; •: •._ .
= Updated 02/02/2019
•I` EW-503 EWsoa®� ---::;'=- Well. Permit •No.WQ0036621
EWs92`a.. 4d Cotton Mill Square Facility
'1 EW501 i a rmu.4
�"A Zone•5 - o�NE� P� `' Greensboro, North Carolina
.� > ' s Zone 6
Mt"niaai�t� s � ® : `�oRFp�K �waoa�2>,r.,w43 DW1641
` DW,2d1,
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Mw.41.,�i IN/303 IW 306
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40
6A
AWC-"®ENR
North Carolina Department of Environment and Natural Resources
Division of Water Resources
Water Quality Programs John E. Skvada, III
Pat McCrory Thomas A. Reeder Secretary
Governor ' Director
November 22, 2013
Jaildshen N. Motwani — Vice President/Principal Client Service Manager r 3
Weston Solutions, Inc.
1400 Weston Way
West Chester, PA 19380 s
Subject Groundwater Remediation Permit Niftht s D03662__ 1
Cotton Mill Square Site (CMS)
Guilford County
Dear Mr. Motwani:
In accordance with your request for permit issuance received June 26, 2013, we are forwarding herewith Permit No.
10036621,—dated November 22, 2013, to Weston Solutions, Inc., for the operation of the subject groundwater
remediation facility.
This permit shall be effective from the date of issuance until October 31, 2018 and shall be subject to the conditions and
limitations as specified therein. Please pay particular attention to the monitoring requirements in this permit Failure to
establish an adequate system for collecting and maintaining the required operational information will result in future
compliance problems.
If any parts, requirements, or limitations contained in this permit are unacceptable, you have the right to request an
4udicatory hearing upon written request within thirty (30) days following receipt of this permit This request must be in
the form of a written petition, conforming to Chapter 150B of the North Carolina General Statutes, and filed with the
Office of Administrative Hearings, 6714 Mail Service Center, Raleigh, NC 27699-6714. Unless such demands are made
this permit shall be final and binding.
H you need any additional information concerning this matter, please contact David Goodrich at [phone] or at
[e-mail].
Sincerely,
J. V*
,for Thomas A. Reeder
cc: Guilftd County Health Department
Winston-Salem Regional Office, Water Quality Regional Operations Section
Stev-E. Johnson, Weston Solufm% 1400 Weston Way, West Chester, PA 19380
Technical Assistance and Certification Unit
Permit File WQ0036621
107 Mal 5ewke Center, Raleigh, Nodh cacuW2MS4617
Locafion:512 N. 6alisbwy SL Retelgh, NaM Cambia ZM4
ph= 919-807-6464 t FAX 91M-6496
� oppabmfly lA+ia ��

NORTH CAROLINA
ENVIRONMENTAL MANAGEMENT
DEPARTMENT OF ENVIItONMENT AND NATURAL
RALEIGH, NORTH CAROLINA
PERMIT FOR THE OPERATION OF A WELL FOR INJECTION
In accordance with the provisions of Article 7, Chapter 87; Article 21, Chapter 143, and other
applicable Laws, Rules, and Regulations
PERMISSION IS HEREBY GRANTED TO
Weston Solutiofis, Inc.
FOR THE OPERATION OF 4 IN SITU REMEDIATION INJECTION/ EXTRACTTON
WELLS, defined in Title 15A North Carolina Administrative Code 2C .0209(5)(b)(viii), to inject
Newman Zone — Buffered Nonionic Formulation for the introduction of bioremediation nutrient
substances for the remediation of chlorinated volatile organic compounds. These injection
wells/points are located at the Cotton Mill Square site, 801 Merritt Drive, Greensboro, Guilford
County, North Carolina, and will be operated in accordance with the application submitted June
26, 2013, and in conformity with the specifications and supporting data subsequently submitted,
all of which are filed with the Department of Environment and Natural Resources and are
considered a part of this permit.
This permit is for Construction and Operation only, and does not waive any provisions of the
Water Use Act or any other applicable Laws, Rules, or Regulations. Operation and use of an
injection well shall be in compliance with Title 15A North Carolina Administrative Code 2T
.1600, and any other Laws, Rules, and Regulations pertaining to wellconstruction and use.
This permit shell be effective, unless revoked, from the date of its issuance until October 31,
2018, and shall be subject to the specified conditions and limitations set forth in Parts I through
X hereof.
Permit issued this the 22nd day of November, 2013.
for Thomas A. Reeder, Director
Division of Water Resources
By Authority of the Environmental Management Commission.
Permit No. W10036621 PAGE I OF 7
ver_ 10/162013 UIG5I/5T

PART I - WELL CONSTRUCTION GENERAL CONDITIONS
1. The Permittee must comply with -all conditions of this permit and with the standards and
criteria specified in Criteria and Standards Applicable to Injection Wells (15A NCAC 2C
.0200). Any.noncompliance with conditions of this permit constitutes a: violation of the
North Carolina Well Construction Act and is grounds for enforcement action as provided for
in N.C.G.S. 87-94.
2. This permit shall become voidable unless the facility is constructed in accordance with the
conditions of this permit, the approved plans and specifications, and other supporting data.
3. This permit is valid only -for construction of the number of injection wells described in the
application and other supporting data. Construction of additional injection wells must be
approved in advance by the Water Quality Regional Operations Section.
4. Each injection well shall not hydraulically.connect separate aquifers.
5. Each injectionwell shall be constructed in such a manner that water from land surface cannot
migrate into the gravel pack or well screen.
6.. Each injection well shall be secured to reasonably insure against unauthorized access and
use. Each well shall be permanently labeled with a warning that it is for injection purposes
and the entrance to.each well must be secured with a locking cap..
7. Each .injection well shall be afforded reasonable protection against damage during
construction and use.
8. Each injection well shall have permanently affixed an identification plate.
PART II - WELL CONSTRUCTION SPECIAL CONDITIONS
1. At least forty-eight (48) hours prior to constructing each injection well, the Permittee shall
notify the Water Quality Regional Operations Section -Underground Injection Control (UIC)
Central Office staff% telephone number 919-807-6352 and the Winston-Salem Regional
Office Water Quality Regional Operations Section Staff, telephone number [phone].
2. Bentonite grout shall not be used to seal any water -bearing zone with 'a chloride
concentration equal to or greater than 1,500 milligrams per liter. In areas where elevated
chloride levels are known to exist or are probable, such as coastal areas, chloride levels shall
be verified in the field to determine existing -conditions.
_ rnuE+No:.WI0032,1 PAGE 2 OF 7
ver. 10//1b12013 . UIC-5115T

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PART VI - 07SPECTIONS
1. Any duly authorized. officer; employee, or -representative of the Division of Water Resources
may, upon presentation of credentials, enter -and inspect -any property, premises, or place on
or related to the injection facility at any reasonable time for the purpose of determining
compliance with this permit, may inspect or copy any records that must be maintained under
the terms and conditions of this permit; mud may obtain samples of groundwater, surface
water, or -injection -fluids.
2. Department representatives shall have reasonable access• for purposes of • .inspection,
observation, and sampling associated with injection and any related facilities as provided for
inN.C.G.S. 87-90.
3. Provisions shall be made for collecting any necessary and appropriate samples associated
with the injection facility activities.
PART VII- APPLICABLE BOUNDARIES
1. The COMPLIANCE BOUNDARY for the disposal system is specified by regulations in 15A
NCAC 2L,'Groundwater Classifications and Standards. The Compliance.Boundary for the
disposal system individually permitted after December.30, 1983 is established at either (1)
250 feet from the waste disposal area, or (2) 50 feet within the property boundary, whichever
_..----2a ^1�1se5t=to=thsa1-area?'!,: is-�rstrated-on-g�-exceedancof-Class_
GA Standards at or beyond the Compliance Boundary is subject to -re action
according_ to 15A NCAC 2L .0106(d) (2). Please be aware that the Compliance Boundary
designation refers to the Wectant substances and not the contaminant plume.
2. The REVIEW BOUNDARY is established around the disposal systems midway between the
Compliance Boundary and the perimeter of the waste disposal area An exceedance of Class
GA Standards at the Review Boundary may require action in accordance with 15A NCAC 2L
.0106(d) (1). Please be aware that the Review Boundary designation refers to the injectant
substances and not the contaminant plume.
PART VIII - MONITORING AND REPORTING REQUIREMENTS
1. The proposed monitoring plan included in the application shall be followed with some
modification. The monitoring will consist of sampling existing wells DW-10-d1. EW 511,
and 36-s (for Zone 1); and DW-02-dl, DW-06-dl, MW-13-s, and MW-14s (for Zone
.1 f� Chloride, Conductivity, Dissolved Oxygen, pld, ReDox (ORP), Sulfate, Temperature,
Total Iron, Total Organic Carbon, and Volatile Organic Compounds before the injections
begin and thereafter- every six months (twice every year) . for at least two years. The
pamnefers of Nitrate Nitrogen and. Nitrite Nitrogen. shall be sampled during the final
sampling event. Any additional monitoring, including groundwater, surface water, or soil
samplurg, deemed necessary by the Division of Water Resources to ensure surface water and
groundwater protection may be established and an acceptable sampling reporting schedule
shall be followed.
PemdtN9. Wd0G36621 PAGE d pF 7
Yer.1Q/16=3 * UIG5I/5T

2. All sample results shall be submitted to the Water Quality Regional Operations Section's
Winston-Salem Regional Office and the Raleigh Central Office annually. Monitoring reports
shall include, at -a minimum, analytical data and an update on the status and location of
monitoring and injection wells. Well locations may be given in a table with the name and
geographic coordinates or shown on an updated version of the surveyor's base map.
3. Within 30 days of completion of well construction, a complete Well 'Constxuotion Record
(Form OW-1) shall be submitted to the addresses specified in Part VIL6 below.
4. The Permittee shall submit. an` Wection'Eveuit Record within 30 days of completing each
injection.
S. The Permittee shall submit a final project evaluation within 9 months after completing all
injection -related activity associated with'this permit, or produce an interim evaluation to be
submitted with a renewal applicgion for this permit. Both the final project evaluation and
interim evaluation shall contain historical monitoring -data and updated contaminant plume
and potentiometric surface maps. PLEASE NOTE: Prior -to closing this permit: the Permittee
emu_ meet groundwaterWuality standards or pre-iniection levels. whichever concentration is
higher for all of the injection constituents: otherwise, continued monitoring .as .approved in
the monitoring plan will be required until such levels can be established.
6. All monitoring results, forms, and reports required in this Part shall be submitted to:
— -- UIC-Program b
DWR— WQROS and Winston-Salem Regional Office
1636 Mail Service Center 585 Waughtown Street
Raleigh, NC 27699-1636 Winston Salem, NC 27107
7. The Pennittee shall report by telephone, within 48 hours of the occurrence or first knowledge
of the occurrence, to the Winston-Salem Regional Office, telephone number (336) 771.-5000,
any of the following.
(A)Any occurrence at the injection facility which results in any unusual operating
circumstances;
(B) Any failure due to .known or unknown reasons, that renders the facility incapable of
proper injection operations, such as mechanical or electrical. failures.
8. Where the Permittee becomes aware of an omission of any relevant facts in a permit
application, or of any incorrect information submitted in said application or in any report to
the Director, the relevant and correct facts or information shall be promptly submitted to the
Director by the Permittee.
9. In the event that the permitted facility fails to perform satisfactorily, the Pennittee shall take
such immediate action as may be required by the Director.
PermitNo. W1006621 PAGE 5 OF 7
vei.10/161201.3 UIC-5U5T

PIM A - PER?M RENEWAL
In order to continue uninterrupted legal use of the injection facility for -the stated purpose, the
Permittee must submit an application to renew the permit 120 days prior to its expiration date.
PART X - CORRECTIVE ACTION
1. Any injection well not constructed or operated in accordance with this permit, or the criteria
and standards specified in 15A NCAC 02C .0200, shall be subject to corrective action as
provided for in rule 15A NCAC 02C .0206.
2. The following corrective actions shall apply to elevated concentrations of injectants or
reaction byproducts resulting from the permitted injection activity:
a. Continued monitoring until concentrations return to pre -injection values or meet the
standards specified in 15A NCAC 02L .0202, whichever are greater. The frequency,
duration, and location of monitoring shall be appropriate for site specific conditions
and potential receptors.
b. Groundwater quality parameters that do not attenuate as described in 2a above may
warrant a corrective action plan as provided for in rule 15A NCAC 02C .0206,
depending on the type, concentration, and distribution of the groundwater quality
standards being exceeded.
PART XI - CHANGE OF WELL STATUS
1. The Permittee shall provide written notification within 15 days of any change of status of an
injection well. Such a change would include the discontinued use of a well for injection. If a
well is taken completely out of service temporarily, the Permittee must install a sanitary seal
If a well is not to be used for any purpose that -well must be permanently abandoned
according to 15A NCAC 2C .0240, Well Construction Standards.
2. When operations have ceased at the facility and a well will no longer be used for any
purpose, the Permittee shall abandon that injection well in accordance with the procedures
specified in 15A NCAC 2C .0240, including but not limited to the following.
(A)All casing and screen materials may be removed prior to initiation of abandonment
procedures if such removal will not cause or contribute to contamination of the
groundwaters.
(B) The entire depth of each well shall be sounded before it is sealed to insure freedom
from obstructions that may interfere with sealing operations.
(C) The well shall be thoroughly disinfected, prior to sealing, if the Director determines
that failure to do so could lead to the contamination of an underground source of
drinking water.
Permit No. WI0036621 PAGE 6 OF 7
ver. 10/16/2013 UIG50T

(D)Drilled wells shall be completely filled with cement grout or bentonite grout, which
shall be introduced into the well through a pipe which extends to the bottom of the
well and is raised as the well is filled
(E) In the case of gravel -packed wells in which the casing and screens have not been
removed, neat -cement, or bentonite grout shall be injected into the well completely
filling it from the bottom of the casing to the top.
(F) In those cases when, as a result of the injection operations, a subsurface cavity has
been created, each well shall be abandoned in such a manner that will prevent the
movement of fluids into or between underground sources of drinking water and in
accordance with the terms and conditions of the permit.
(G)The Permittee shall submit a Well Abandonment Record (Form GRt 30) as specified
in 15A NCAC 2C .0225(k) (1) (A) within 30 days of completion of abandonment.
3. The written documentation required in Part IX (1) and (2) (G) shall be submitted to:
Water Quality Regional Operations Section-UIC Program
DENR Division of Water Resources
1636 Mail Service Center
Raleigh, NC 27699-1636
PART X1I — WORKER PRECAUTIONS DURING APPLICATION
1. Some effects reported to be associated with the product proposed to be used are as follows:
eye, skin, nose, throat, and lung irritation. If the product is released into the environment in a
way that could result in a suspension of fine solid or liquid particles (e.g., grinding, blending,
vigorous shaking or mixing), then proper personal protective equipment should be used. The
application process should be reviewed by an industrial hygienist to ensure that the most
appropriate personal protective equipment is used.
2. Persons working with these products should wear goggles or a face shield, gloves, and
protective clothing. Face and body protection should be used for anticipated splashes or
sprays.
3. Eating, drinking, smoking, handling contact lenses, and applying cosmetics should not be
permitted in the application area during or immediately following application.
4. Safety controls should be in place to ensure that the check valve and the pressure delivery
systems are working properly.
5. The Material Safety Data Sheets should be followed to prevent incompatible or adverse
reactions and injuries.
PermitNo. W10036621 PAGE 7 OF 7
ver. 10/16/2013 UIC-515T

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® E)(ISTINGWELLPROPOSED FOR INJECTION
EXISTING WELL PROPOSED FOR MONITORING
--� COMPLIANCE BOUNDARY
PROPERTY LINE �— — FIGURE 1
J r'� WESTON SOLUTIONS, INC.
COTTON MILL SQUARE
o 200
400
Scaie Feet GROUNDWATER REMEDIAMON PERMIT
_ ..�-- i
Feat
GUILFORD COUNTY
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r�wsna 3` 1 inch = 200 Feat 1NQ 036621
WELL LOCATION MAP

EXECUTIVE SUMMARY SHEET
FOR THE COTTON MILL SQUARE SITE IN GUILFORD COUNTY
1. Rescission of Existing Permit WQ0029385
The permittee wishes to rescind existing groundwater remediation system Permit WQ0029385,
which was most recently issued on November 3, 2006. This permit allows the establishment and
operation of a 28,800 GPD "closed -loop" recirculation in -situ bioremediation system to treat
ground water over a large area contaminated with chlorinated solvents. The permitted system
used 10 injection wells and 14 extraction wells to treat an impacted area of approximately 12
acres.
The remediation system is currently inactive and a system abandonment plan has been
submitted. Written notification of consent to rescind the permit from the oversight agency, the
Division of Waste Management's Inactive Sites Branch, has been received, meeting the closure
requirement of 15A NCAC 02T .1608(a)(2) so that closure can proceed.
A new permit is being requested because the existing system has served its purpose and the
forthcoming remediation activity is on a much smaller scale than the activity that took place
under the existing permit (the forthcoming action has a maximum total injection volume of
16,500 gallons, whereas the previous system was operating on a capacity limit of 28,800 gallons
per day for more than 5 years).
ssuance of New Permit�NQD0368� -
The new permit is for further groundwater remediation consisting of extraction and subsequent
injection activities. Contaminated ground water will be extracted from existing well EW-509 in
Zone 1. This water, combined with potable water (if needed) to achieve a 1:4 to 1:10 dilution
factor with the Newman Zone injectant, will be injected int�-wellft09aanol I,W-20�on'e
3, contaminated ground water will be extracted from existing wells EW-512, IW-206, and IW-
210, and a similar mixture (which may contain potable water) will be made by adding the
Newman Zone injectant and will be injected into wei s-iV11v205aaI;W20�
The Compliance Boundary for these extraction/injection wells is established at 250 feet from
each well, or 50 feet inside the property boundary (see Figure 1). The monitoring wells for this
remediation permit are all situated outside of the areas enclosed by the Compliance Boundaries.
Monitoring will be performed in wells situated outside of the CoMgJU_ a Dpundary in wells