WI0300295_Permit (Issuance)_20151113

_)IVISION OF WATER RESOURCES
WQROS
November 13, 2015
MEMORANDUM
TO: Debra Watts
FROM: Michael Rogers
RE: Issuance of permit to inject 3DMe, Sodium Lactate (SL), magnesium hydroxide, and sodium carbonate
(Permit #WI0300295)
Lincoln County
I recommend that Permit Number WI0300295 be issued to the Robert Bosch Tool Corporation to inject the above referenced
additives to remediate groundwater (GW) contaminated with chlorinated VOCs.
SITE DESCRIPTION: The site is a former tool manufacturing facility, now used for a moving/storage company. Due to
past improper use and storage of chemicals GW is contaminated with various contaminates including cVOCs (Figure 1A
&9C).
HYDROGEOLOGIC DESCRIPTION: The site is located within the Piedmont geologic province. In the area of the site, the
undisturbed overburden consists primarily of layers of saprolitic silts and clays. Depth to bedrock (fractured schist and
gneiss) varies as the site is large and sloped with a topographic high in the middle. GW flow generally mimics
topography (refer to Figures 9D1/&9D2). The velocity also varies from 6 to 150 ft/yr in the surficial aquifer throughout
the site.
EXTENT OF CONTAMINATION: The groundwater contamination plume(s) are large with some almost '/2 mile in length
(Figures 9E1 thru 9E4).
PROPOSED INJECTION: This injection project will consist of Phase 2 and Phase 3 (will be postponed until the Avery's
private well is P&A and they are hooked up to city water). Phase I was completed as a deemed permitted project under
WI0300226/WI0300244. For Phase 2 and 3, injection will be via a combination of existing wells, proposed new
permanent injection wells, and new DPTs as shown in Figures 1A thru 1F. Also, there will be an injection of SL in one
area via 17 SVE wells (Figure 1E). Estimated average injection pressure for the wells will be appx 100 psi, and near zero
(gravity fed) for the injection of SL into the SVE wells. The flow rates will be approximately @3-5GPM. Note- the
injection plan/map was modified several times per my request and the RO. See below for a breakdown of the number of
wells and amounts of additives per different phases.
3DMe + other
additives
Existing Wells
New Wells
Total Wells
Gallons
Phase 2
23
95
118
23,175
Phase 3
5
125
130
15,390
Total
28
220
248
38,565
Est. Avg. al/well = 150 -155
Na Lactate + other
additives
Existing SVE
Wells
Total Wells
Gallons
Phase 2 Only
17 (14 vertical, 3
horizontal)
17
1080
Total
17
17
1080
Est. Avg. gal/well = 63
TOTAL NO.
WELLS
265

HOW IT woRKs: The 3DMe and S't _ ,,.1 allows for enhanced bioremediation thaw= �;ults in dechlorination of the cVOCs
by providing a hydrogen source (chlorine atoms are replaced with hydrogen by the subsurface stimulated biological
community). Magnesium hydroxide and sodium carbonate are pH buffers.
MONITORING: Practically all active wells at the site are monitored per requirements of the DWM. Also, per the -request -of
the RO, 2 additional monitoring wells are to be installed on the southern part of the property (see email dated 11/4/15 and
Add Info received 11/10/15). Refer to the monitoring plan in the application (blue post -it tab).
EPIDEMIOLOGY: The DHHS has approved the injectant(s).
REGIONAL OFFICE COMMENTS: A final Add Info (dated November 5 2015) was received by the RO where the Applicant
will be installing additional monitoring wells to intercept any injectants on the south side of the property. After review of
numerous additional information requests received by the CO and the RO, .Andrew Pitner and Ed Watson of the Mooresville
RO indicate all of their concerns listed in the Staff Report have been met and, therefore, recommend issuance of this permit
(refer to emails from Andrew and Ed dated October 13 and November 13, 2015).

L
_'Am
NCDENR
North Carolina Department of Environmental Quality
Pat McCrory Donald R. van der Vaart
Governor Secretary
November 18, 2015
Scott Pihlaja, Director, Total Quality & Facilities Management
Robert Bosch Tool Corporation
1800 West Central Road
Mount Prospect, IL 60056
Re: Issuance of Injection Permit WI0300295
Robert Bosch Tool Corporation ,
Lincoln County, NC
Dear Mr. Pihlaja:
In accordance with the application received on July 24, 2015, and additional information received August 18, .
October 13, October 19, October 28, and November 10, 2015; we are forwarding permit number WI0300295.
This permit is to inject 3DMe, sodium lactate, magnesium hydroxide, and sodium carbonate to remediate
groundwater contaminated with VOCs at the Former Robert Bosch Tool Corporation Lincolnton Manufacturing
Division Facility located at 124 Legionaire Road, Lincolnton, Lincoln County, NC 28092. This permit shall be
effective from date of issuance, until October 31, 2020, and shall be subject.to the conditions and limitations
stated therein, including the requirement to submit a Final Project Evaluation (FPE) 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.
Please note the following:
• Per permit condition Part VI.5, 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;
• Per permit condition Part III.I, at least forty-eight (48) hours prior to constructing or
operating each injection well, the Permittee shall notify the Underground Injection Control
(UIC) Central Office staff, telephone number 919-807-6406 and the Mooresville Regional
Office staff, telephone number 828-296-4500;
• Per permit condition Part HI.2, the proposed Phase 3 injection plan in the application
cannot occur until (a.) the potable well on abutting property owned by Mr. and Mrs. Avery
is plugged and abandoned according to 15A NCAC 02C .0240, and (b.) Mr. and Mrs. Avery
are connected to a municipal water supply;
1636 Mail Service Center, Raleigh; North Carolina 27699-1636
Phone: [phone] Internet: http:l/www.ncwater.ora
An Equal Opporlunity 1 Affirmative Action Employer— Made in part by recycled paper

Robert Bosch Tool Corporation
Page 2 of 2
.Per---per-mit-conditions-P--art V-I.3-&4,-and-I-X.2(% within-30-days after each injection event,
please provide the well construction (if not previously submitted) and injection information
on the applicable forms listed below. Note: if well construction/abandonment information
is essentially the same (e.g., direct push points or geo-probes), then only one GW-1 or GW-
30 form is needed. Just indicate in the comments section on the form the total number of
well points. These forms -are -available on -the -Division of Water Resources' website at
http: //Portal;ncd en r.ory/web/wq/aps/mvpro/repo rting-forms.
➢ Injection Event Record (IER)
➢ Well Construction Record (GW-I)
➢ Well Abandonment Record (GW-30)
In order to continue uninterrupted legal use of this well for the stated purpose, you should submit an application
to renew the permit 120 days prior to its expiration date. As indicated in the permit, this permit is not
transferable to any person without prior notice to, and approval by, the Director of the Division of Water
Resources. If you have any questions regarding your permit or the Underground Injection Control Program
please call me at [phone].
Best Regards,
Michael Rogers, P.G. (NC & FL)
Hydrogeologist
Division of Water Resources
Water Quality Regional Operations Section
cc: Andrew Pitner & Ed Watson, WQROS — Mooresville Regional Office
Central Office File, WI6300295
Gary Wise, Environment & Infrastructure, AMEC Foster Wheeler, 37 Villa Road, Suite 20.1, Greenville,
SC 29615

NORTH CAROLINA
ENVIRONMENTAL MANAGEMENT COMMISSION
DEPARTMENT OF ENVIRONMENTAL QUALITY
RALEIGH, NORTH CAROL INA
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
Robert Bosch Tool Corporation
FOR THE CONSTRUCTION/OPERATION OF 265 IN SITU REMEDIATION INJECTION
WELLS, defined in. Title 15A North Carolina Administrative Code 02C .0209(5)(b)(viii), to inject
3-D MicroEmulsion (3DMe), sodium lactate, magnesium hydroxide, and sodium carbonate for the
enhanced bioremediation of groundwater contaminated with chlorinated volatile organic
compounds (cVOCs). These injection wells/points will be located at the former Robert Bosch
Tool Corporation Lincolnton Manufacturing Facility located at 124 Legionaire Road, Lincolnton,
Lincolnton County, NC 28092, and will be operated in accordance with the application submitted
July 24, 2015, and in conformity with the specifications and supporting data submitted, August
18, October 13, October 19, October 28, and November 10, 2015, all of which are filed with the
Department of Environmental Quality 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 02C .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 October 31, 2020,
and shall be subject to the specified conditions and limitations set forth in this permit.
Permit issued this the day of November 2015.
a�c
S. Jay Zimmerman, Director
Division of Water Resources
By Authority of the Environmental Management Commission.
Pen -nit No. WI0100353 PAGE 1 OF 7
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PART I — PERMIT GENERAL CONDITIONS
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 [15A
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)].
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)].
5. 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
Permit No. W10100353 PAGE 2 OF 7
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NCAC 02C .0225(g)(23)].
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)].
8. A completed Well Construction Record (Form GW-1) shall be submitted as described in Part
VI.6 of this permit.
PART III - WELL CONSTRUCTION SPECIAL CONDITIONS
1. At least forty-eight (48) hours prior to constructing or operating each injection well, the
Permittee shall notify the Underground Injection_Control (UIC) Central Office staff, telephone
number 919-807-6406, and the Mooresville Regional Office staff, telephone number 704-663-
1699 [15A NCAC 02C .0211(k)].
2. The proposed Phase 3 injection plan in the application shall not occur until the potable
well on abutting property owned by Mr. and Mrs. Avery is plugged and abandoned
according to 15A NCAC 02C .0240; and Mr. and Mrs. Avery are connected to a municipal
water supply.
PART IV - OPERATION AND USE CONDITIONS
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 surfacewater or groundwater- resulting from the operation of this facility [I 5A 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].
Permit No. WI0100353 PAGE 3 OF 7
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PART V - INSPECTIONS [15A NCAC 02C .0211(k)]
1. 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
the injection facility activities.
PART VI - MONITORING AND REPORTING REQUIREMENTS
The proposed monitoring plan (revised per Additional Information received August 18 and
November 10, 2015) included in the application shall be followed. Any additional monitoring,
including groundwater, surface water, or soil sampling, deemed necessary. to ensure surface
water and groundwater protection may be established ;and an acceptable sampling reporting
schedule shall, be followed [15A NCAC 02C .02250)].
2. All sample results shall be:submitted to the.WQROS Central Office and Mooresville Regional
Office. 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 site snap
[15ANCAC 02C .0225(k)(2)].
3. 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)].
4. An Injection Event Record (IER) shall be submitted within 30 days of each injection event
[15A NCAC 02C .0225(k)(1)(B)].
5. 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: In
jectants and related reaction'byproducts must
attenuate to pre -injection concentrations or groundwater standards specified in rule 15A NCAC
02C .0202, whichever is greater, in order for this permit to be closed. Otherwise, corrective
action as described Part VII shall be required [15A NCAC 02C .0225(k)(2)].
Permit No. W10100353 PAGE 4 OF 7
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6. 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 Mooresville Regional Office
1636 Mail Service Center . 610 East Center Ave.
Raleigh, NC 27699-1636 Mooresville, NC 28115
7. 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 Mooresville Regional Office, telephone number 704-663-
1699.
(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.
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 [15A NCAC 02C .021 l(b)]
PART VII - 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
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
Permit No. WI0100353 PAGE 5 OF 7
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exceeded.
PART VIII - PERMIT RENEWAL [15A NCAC 02C .0211(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 IX - CHANGE OF WELL STATUS [15A 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 scree_ n 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.
(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 Pennittee 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.
Permit No. W10100353 PAGE 6 OF 7
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3. The written documentation required in Part IX (1) and (2) (G) shall be submitted to:
UIC Program
DENR-Division of Water Resources
1636 Mail Service Center
Raleigh, NC 27699-1636
PART X - WORKER PRECAUTIONS DURING APPLICATION [15A NCAC 02C
.0211(b)]
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. W10100-153 PAGE 7 OF 7
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