WI0300182_Permit (Issuance)_20120127

NORTH CAROLINA
ENVIRONMENTAL MANAGEMENT COMMISSION
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
RALEIGH, NORTH CAROLINA
PERMIT FOR THE CONSTRUCTION AND 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
Plantation Pipe Line Company, Inc. - Mount Holly Road Group (MHRG)
FOR THE CONSTRUCTION AND/OR OPERATION OF TWO (2) TYPE 5I INJECTION
WELLS, defined in Title 15A North Carolina Administrative Code 2C .0209(e)(3)(C), to inject
sodium bromide to act as a tracer to characterize the hydrogeology at the Plantation Pipe Line
Company, Inc. - MHRG Site, 6869 Freedom Dr., Charlotte, Mecklenburg County, NC 28214,
and. will be operated. in accordance with the application submitted September 6, 2011, and in _
conformity with the specifications and supporting data submitted November. 3, 2011, and
January 13, 2012, 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 2C
.0100 and .0200, 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 December 31,
2014, and shall be subject to the specified conditions and limitations set forth in Parts I through
X hereof.
Permit issued this the 27th day of January, 2012.
Charles, Wakild, P.E., Director
Division of Water Quality
By Authority of the Environmental Management Commission.
Permit No. WI0300182 PAGE 1 OF 6
ver. June 2011 UIC-5I/5T

J' WDE R
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Charles Wakild, P.E.
Governor Director
January 27, 2012
Mr. Jerry Aycock, Director of Remediation and Emergency Response
Plantation Pipe Line Company, Inc.
1100 Aldermen Dr., Suite.200
Alpharetta, Georgia 30005
Ref: Issuance of Injection Permit WI0300182
Plantation Pipe Line Company, Inc.
Charlotte, Mecklenburg County, North Carolina
Dear Mr. Aycock:
Dee Freeman
Secretary
In accordance with the application received -on September 6, 2011; and additional information received November 3,
2011, and January 13, 2012, we are forwarding permit number WI0300182. This permit is to inject sodium bromide to
act as a hydrogeologic tracer at the Plantation Pipe Line Company -Mount Holly Road Group (MHRG) Site, 6869
Freedom Dr., Charlotte, Mecklenburg County, NC 28214. This permit shall be effective from the date of issuance until
December 31, 2014, and shall be subject to the conditions and limitations stated -therein, including the requirement to
submit a final project evaluation as stated in PART VII —.MONITORING AND REPORTING REQUIREMENTS. Please
read the entire permit to ensure that you are aware of all compliance requirements of the permit..
Also, please pay attention to Part VII.2. The proposed . monitoring plan has been revised per the additional
information received January 13, 2012.
You will need to notify this office and the Mooresville Regional Office by telephone 48 hours prior to initiation of
operation of the facility. In order to continue uninterrupted legal use of the injection facility�for the stated purpose, you
must submit an application to renew the permit 120 days prior to its expiration date. Please contact me at 919-807-6406
or Michael.Rogerstt'�i.ncdenr.gov if you have any questions about your permit. .
Best Regards,
Michael Rogers, P.G. (NC & L)
Environmental Specialist
Underground Injection Control Program
cc: Andrew Pitner, Mooresville Regional Office
Stanford Lummus, S&ME Inc., 301 Zima Park Dr., Spartanburg, SC 29301
Ed Leach, DWM-Mooresville Regional Office
Mecklenburg County Environmental Health Department
W10300182 Permit File .
AQUIFER PROTECTION SECTION
1636 Mail Service Center, Raleigh, North Carolina 27699-1636
Location: 512 N. Salisbury St., Raleigh, North Carolina 27604
Phone: [phone] FAX: [phone]
Internet www.ncwateroualitv.ora
An Equal Opportunity 1 Affirmative Action Employer
One
NorthCarolina
Naturally

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 Aquifer Protection 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
At least forty-eight (48) hours prior to constructing each injection well, the Permittee shall
notify the Aquifer Protection Section -Underground Injection Control (UIC) Central Office
staff, telephone number 919-807-6406 and the Mooresville Regional Office Aquifer
Protection Section Staff, telephone number 704-66371699.
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. W10300182 PAGE 2 OF 6
ver. June 2011 UIC-5I/5T

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 Quality (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, tender 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 Quality such as the repair, modification, or abandonment
of the injection facility.
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 least forty-eight (48) hours prior to the initiation of the operation of the facility for
injection, the Permittee must notify by telephone the Aquifer Protection Section-UIC, Central
Office. staff, telephone number 919-807-6406.. 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. WI0300182 PAGE 3 OF 6
ver. June 2011 UIC-5I/5T

PART VI -.INSPECTIONS
1. Any duly authorized officer, employee, or representative of the Division of Water Quality
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 - MONITORING AND REPORTING REQUIREMENTS
1. Within 30 days of completion of well construction, a completed Well Construction Record
(Form GW-1) must be submitted for each injection well to:
Aquifer Protection Section-UIC Program
DENR-Division of Water Quality
1636 Mail Service Center
Raleigh, NC 27699-1636
2. The proposed revised monitoring plan received January 13, 2012, included in the application
shall be followed. All sample results shall be submitted to the Aquifer Protection Section's
Mooresville Regional Office -and the Raleigh Central Office. Any monitoring (including
groundwater, surface water, or soil sampling) deemed necessary by the Division of Water
Quality to ensure surface and ground water protection, will be established and an acceptable
sampling reporting schedule shall be followed.
3. The Peirnittee shall submit an Injection Event Record within 30 days of completing .each
injection.
4. The Permittee shall produce a final project evaluation within 9 months after completing all
injection -related activity associated with this permit or produce a project interim evaluation
before submitting a renewal. application for this permit. This document shall assess the
injection projects findings in a written summary. The final project evaluation shall also
contain monitoring well sampling .data, contaminant plume maps and potentiometric surface
maps.
Permit No. WI0300182 PAGE 4 OF 6
ver. June 2011 UIC-5I/5T

5. The monitoring results and the final project evaluation shall be submitted to:
UIC Program Staff DWQ - Aquifer Protection Section
DWQ —.Aquifer Protection Section and Mooresville Regional Office
1636 Mail Service Center 610 East Center Avenue, Suite 301
Raleigh, NC 27699-1636 Mooresville, NC 28115
6. The Permittee shall report by telephone, within 48 hours of the occurrence or first knowledge
of the occurrence, to the Mooresville Regional Office, telephone number 704-663-1699., 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.
7. 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.
8. 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.
PART VIII - 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 IX - CHANGE OF WELL STATUS
l . 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 .0214, 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 .0214, 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.
Permit No. WI0300182 PAGE 5 OF 6
ver. June 2011 UIC-5I/5T

(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.
(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 .0213(h)(1) within 30 days of completion of abandonment.
3. The written documentation required in Part IX (1) and- (2) (G) shall be submitted to:
Aquifer Protection Section-UIC Program
DENR-Division of Water Quality
1636 Mail Service Center
Raleigh, NC 27699-1636
PART X — 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. WI0300182 PAGE 6 OF 6
ver. June 2011 UIC-5I/5T

I
- DIVISION OF WATER QUALITY
AQUIFER PROTECTION SECTION
January 23, 2012
MEMORANDUM
TO: Debra Watts
FROM: Michael Rogers M X-
RE: Issuance of Permit to Inject Sodium Bromide (Permit #WI0300182)
Plantation Pipe Line Company, Inc.
I recommend that Permit Number WI0300182 be issued to Plantation Pipe Line Company, Inc. to inject sodium bromide
(tracer) to study the hydrogeology characteristics of the interface/connection between the saprolite and the transition zone.
The site is located at 6869 Freedom Drive, Charlotte, Mecklenburg County, NC 28130.
SITE DESCRIPTION: The subject site is an active petroleum storage and distribution facility (Figures H-1 and H-2).
Evidently, there was a spillage or leak of petroleum products from pipelines at the site over the years resulting in petroleum
contamination in the soil and groundwater. The site has been undergoing air disparaging and soil vapor extraction since
1999.
HYDROGEOLOGIC DESCRIPTION: The site is located in the Charlotte Belt of the Piedmont Physiographic Province and is
primarily comprised of metamorphic rocks. The area of the site consists of sand and silt, partially weathered rock/transition
zone, and bedrock. Depth to GW in the surficial aquifer ranges from approximately 10-15 feet BLS and flows in a
generally southwesterly direction (Figure H-3) at a reported 3.65 feet per year (my estimate is 116 feet per year based upon
information provided on page 7 in the application).
EXTENT OF CONTAMINATION: The contaminant plume is linear in shape and appears to be contained on site. It is
approximately 750 feet long and 250 feet wide (Figure 114).
PROPOSED INJECTION: The proposed injection will be via 2 proposed injection wells installed to approximately 80 feet
BLS. The purpose of the injection is to study the hydrogeology of the interface/connection between the saprolite and the
transition zone. Although the slug of injectant to be used (11,000 gallons/well) could result in some movement of the
plume, the potential deleterious impact or displacement of the plume onto adjoining properties and/or receptors is minimal
for the following reasons: (1) the injectant is an inert tracer, (2) the groundwater flow rate at the fastest is approximately
116 feet per year, and (3) there are no known potable wells downgradient. There is a small intermittent stream located
approximately 100 feet downgradient of proposed injection well ITZ-2. However, it appears the injection will be below the
level of the stream. A surface water sampling point has been added to the monitoring plan as a precaution. The injection
wells are highlighted in yellow on Figures H-3, and E-1.1 and 1.2.
HOW IT WORKS: The sodium bromide,will be used as tracer to evaluate the hydrogeologic features of the
saprolite/transition zone. There will be 2 injection wells- 1 at the northern end of the property and a 2nd well near the
southern end of the property line (ITZ-1 and ITZ-2, respectively). The wells will be about 500 feet apart (they are
highlighted in yellow on Figures H-3, H-4, E-1.1, and E-1.2). ITZ-1 will be installed first and will undergo two injection
events. The first injection will start with 13 gallons of water mixed with 1.2 pounds of sodium bromide and will be fed into
the well. Once the tracer has been introduced, approximately 11,000 gallons of potable chase water will be pumped into
the well from a source tank at approximately 30 psi for 10 days. A second injection event will occur about 90 days later.
The procedure for this second event will be the same except the injectant will be fed into the well under non -pressurized
conditions. This second event at ambient pressure will last approximately 90 days. After the injection process is finished
for ITZ-1, the applicant will then install ITZ-2 and the injection process repeated (Refer to Figure E-3 for the injection
timeline).

i
MONITORING: ,The groundwater monitoring will consist of a pre -injection sampling event and then monitored
continuously for bromide and pH/ORP. Additionally, the monitoring wells (+I surface water location) located in the
vicinity of ITZ-2 will be sampled monthly for BETX, MTBE, and naphthalene (this was per our request). Refer to Figures
E-1.1 and E-1.2 for location of the monitoring wells, which are highlighted in pink.
EPIDEMIOLOGY: The DHHS has reviewed and approved the referenced injectant(s).
REGIONAL OFFICE COMMENTS: Fach of the RO comments/recommendations are discussed below (RO's
comments/recommendations are underlined).
Given the creek's proximity to ITZ-2 the MRO recommends adding creek sampling to proposed monitoring plan. This
additional monitoring point was added to the sampling plan.
Andrew Pitner and Maria Schutte of the Mooresville RO recommend issuance of this permit.

51 Calculations Worksheet
Applicant/Facility: P, -�► ,c tit �j�d �^!�
Permit No. M71
—7—
Date: - a /
Reviewer:
Depth to groundwater (GW): i 0 BLS
GW flow direction: % S�
v
MWs installed in same aquifer as injection? ► (Y or N); Inj zone: MW zone: (YD 0;4'p�
Nearest water supply well:' N� 611J
Groundwater Flow Rate
__. 0 UU D SSWHC X s C)" gradient(FT?) flow rate/DAB'.(?) X 365 FTA; R
4� SY or porosity (-.30)
Reported:
[FYI- 60 min/day X.24 hrs X 365 days = 525.600]
Calculations for Potential Contaminate Plume DisplacementC" -?0'
3.142 (7r) X r2 X %-0 height = j O 0 - CF
r 0 0 0 CF X . ZO SY-or porosity (i.e. -.30) CF of available void
space
.R-P O CF of available void space X 7.48 gallons = ?-3, / -9 (o gallons of water in void sn
Gallons of injectant = Sr`l• >' of fluid displaced by injectant (move decimal)
gallons of water in void space
Potential displacement of plume by injection: /-Qc-j /t46J)
Injection Volume and Pumping Rate Per Well Per Day
u total amt. of injectant / number of wells / % 0 number of days of injection event =
// L) 0
amount of injectant per well per day (average gallons per day)
S:UIC/Applications and forms/ 51 Calculations worksheei version 9/10/10

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