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HomeMy WebLinkAboutWI0400035_Permit_20131121DIVISION OF WATER QUALIT-i AQUIFER PROTECTION SECTION November 21, 2013 MEMORANDUM TO: Debra Watts FROM: Michael Rogers M RE: Renewal of Permit to Inject 3DMe (Permit #W10400035) Ares Capital Corp. I recommend that Permit Number W10400035 be re -issued to the above applicant to inject 3DMe to remediate groundwater (GW) contaminated with VOCs. This permit was issued on May 3, 2012, and will expire on April 30, 2014. Following the review of the performance monitoring data collected after the injection events, the Permittee has requested the permit be modified and renewed to include up to an additional injection event. Previous injection events have resulted in some decrease of COCs. The Permittee submitted a revised application reflecting a modified injection zone/monitoring plan to be more in compliance with 2C .0225. Since the permit for this injection activity has previously been approved, and information contained therein is essentially the same, I am attaching this modified memo reflecting those proposed changes from the previous permit. Please refer to the previous permit issuance memorandum for more information on this site. PROPOSED INJECTION: Approximately 3695 gallons of 3DMe and blended potable water will be injected via 5 permanent injection wells from 15-33 BLS (average of 739 gal/well). These wells are located at different locations on the subject property. Please refer to Figure 3 in the application package for the location of the injection wells (highlighted in yellow). MONITORING: Monitoring will be completed semi-annually. Please refer to revised Figure 3 in the application package for more information of the location of the monitoring wells (highlighted in pink). REGIONAL OFFICE COMMENTS: Each of the RO comments/recommendations are discussed below (RO's comments/recommendations are underlined). Shuying Wang requested that BW-22 be added to the MP to monitor for COCs in the deeper aquifer. This was requested and this well was added to the revised MP. Shuying Wang and Sherri Knight with the Winston-Salem RO recommends re -issuance of this permit. Central Files: APS SWP 11 /22/13 Permit Number W10400035 Permit Tracking Slip Program Category Ground Water Permit Type Injection In situ Groundwater Remediation Well Primary Reviewer michael.rogers Coastal SW Rule Permitted Flow Status Project Type In review Renewal with major mod Version Permit Classification Individual Permit Contact Affiliation Christopher Hay Environmental Manager Program 313 Gallimore Dairy Rd Greensboro NC 274099724 Facility Facility Name Major/Minor Region Fairchild Industrial Products Company Minor Winston-Salem Location Address County 3920 Westpoint Blvd Forsyth Winston Salem NC 27103 Facility Contact Affiliation Owner Owner Name Owner Type Ares Capital Corporation Non -Government Owner Affiliation Joshua Bloomstein & Counsel Gen'I Pres Vice 2200 Pennsylvania Ave Nw Ste 600-W Dates/Events Washington DC 20037 Scheduled Orig Issue App Received Draft Initiated Issuance Public Notice Issue Effective Expiration 12/01 /03 10/08/ 13 Regulated Activities Requested/Received Events Groundwater monitoring RO staff report requested 10/15/13 Groundwater remediation RO staff report received 10/29/13 Additional information requested 11/12/13 Additional information received 11/19/13 Outfall NULL Waterbody Name Stream Index Number Current Class Subbasin 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 Ares Capital Corporation FOR THE CONSTRUCTION AND/OR OPERATION OF 5 (FIVE) IN SITU REMEDIATION/TRACER INJECTION WELLS, defined in Title 15A North Carolina Administrative Code 2C .0209(5)(b)(viii), to inject 3DMe, for the reductive dechlorination of volatile organic compounds (VOCs) These injection wells/points will be located at Fairchild Industrial Products Company, 3920 Westpoint Blvd., Winston-Salem, Forsyth County, NC 27103, and will be operated in accordance with the application submitted October 8, 2013, and in conformity with the specifications and supporting data submitted November 19, 2013, 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 April 30, 2019, and shall be subject to the specified conditions and limitations set forth in Parts I through XI hereof. Permit issued this the 22nd day of November 2013 �'j Thomas A. Reeder, Director Division of Water Resources By Authority of the Environmental Management Commission. Permit No. W10400035 PAGE 1 OF 7 ver. 11 / 14/2013 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 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. 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, 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 WQROS staff and receive prior approval 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 WQROS Central Office staff, telephone number 919-807-919-807-6406, and the WQROS Winston-Salem Regional Office staff, telephone number 336-771-5000. Notification is required so that staff can inspect or otherwise review the injection facility and determine if it is in compliance with permit conditions. Permit No. WI0400035 PAGE 3 OF 7 ver. 11 / 14/2013 UIC-5I/5 T 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 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 Permittee shall take such immediate action as may be required by the Director. PART VIII - 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 under 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 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 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. Permit No. WI0400035 PAGE 5 OF 7 ver. 11 / 14/2013 UIC-51/5T PART XI — 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. WI0400035 PAGE 7 OF 7 ver. 1 1 / 14/2013 UIC-51/5T A�ja NCDENR North Carolina Department of Environment and Natural Division of Water Resources Water Quality Programs Pat McCrory Thomas A. Reeder Governor Director November 22, 2013 Mr. Joshua Bloomstein, Vice President & General Counsel Ares Capital Corporation 2200 Pennsylvania Ave., Suite 600-W Washington, NC 20037 Ref: Issuance of Injection Permit WI0400035 Ares Capital Corporation Forysth County, North Carolina Dear Mr. Ares: Resources John E. Skvarla, III Secretary In accordance with the application received on October 8, 2013, and additional information received November 19, 2013, we are forwarding permit number WI0400035. This permit is to inject 3DMe for the remediation of volatile organic compounds (VOCs). These injection wells/points will be located at the Fairchild Industrial Products Company Facility, 3920 Westpoint, Blvd., Winston-Salem, Forysth County, North Carolina 27103. This permit shall be effective from May 1, 2014, (i.e., the day after the expiration date of the existing permit), which may differ from the date of this letter, until April 30, 2019, 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. PIease 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 VII.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 conditions Part VII.3 &4, and IX.2(G), 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-I 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's website at httpJ/portal.ncdenr.ore/web/wg/aps/mpro/reportiniz-forms 1636 Mail Service Center, Raleigh, North Carolina 27699-1636 Location: 512 N. Salisbury St. Raleigh, North Carolina 27604 Phone: 919-807-64641 FAX: 91 M07-6496 Internet www.ncwaterguality.org An Equal Opportunity 1 Affirmative Action Employer Central Files: APS SWP 11/25/13 Permit Number W10400035 Permit Tracking Slip Program Category Ground Water Permit Type Injection In situ Groundwater Remediation Well Primary Reviewer michael.rogers Coastal SW Rule Permitted Flow Status Project Type Issued Renewal with major mod Version Permit Classification Individual Permit Contact Affiliation Christopher Hay Environmental Manager Program 313 Gallimore Dairy Rd Greensboro NC 274099724 Facility Facility Name Major/Minor Region Fairchild Industrial Products Company Minor Winston-Salem Location Address 3920 Westpoint Blvd Winston Salem Owner Owner Name Ares Capital Corporation NC 27103 County Forsyth Facility Contact Affiliation Owner Type Non -Government Owner Affiliation Joshua Bloomstein & Counsel Gen'I Pres Vice 2200 Pennsylvania Ave Nw Ste 600-W Dates/Events Washington DC 20037 Scheduled Orig Issue App Received Draft Initiated Issuance Public Notice Issue Effective Expiration 12/01/03 10/08/13 11/22/13 05/01/14 04/30/19 Regulated Activities Requested/Received Events Groundwater monitoring RO staff report requested 10/15/13 Groundwater remediation RO staff report received 10/29/13 Additional information requested 11/12/13 Additional information received 11/19/13 Outfall NULL Waterbody Name Stream Index Number Current Class Subbasin DIVISION OF WATER QUALITY AQUIFER PROTECTION SECTION April 26, 2012 PERMIT ISSUANCE MEMO TO: Debra Watts THROUGH: Thomas Slusser FROM: David Goodrich RE: Permit To Renew Injection Permit 3DMe and Regenesis Bio-Dechlor Inoculum Fairchild Industrial Products Company Site in Winston-Salem I recommend that Permit Number WI0400035 be renewed and issued to Ares Capital Corporation to inject 3DMe and Regenesis Bio-Dechlor Inoculum to remediate soils and groundwater contaminated with PCE and TCE. The injection activities associated with this permit have been completed, and post -injection groundwater monitoring is the only activity planned for the immediate future. A Final Project Evaluation has yet to be submitted, and is due within nine months after completing all injection -related activity (i.e., post -injection groundwater monitoring). The Winston-Salem Regional Office, in their permit review, recommended the installation of a deep monitoring well to evaluate the impact of future injections on the deeper groundwater environment. If further injections are intended, the modified permit will include a requirement for the installation (and monitoring) of a deep monitoring well. 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 Ares Capital Corporation FOR THE OPERATION OF 15 TYPE 5I INJECTION WELLS, defined in Title 15A North Carolina Administrative Code 2C .0209(e)(3)(C), to inject 3D Microemulsion and BDI plus solution, for the enhancement of bioremediation of chlorinated solvents. These injection wells will be located at the Fairchild Industrial Products Company Site, 3920 Westpoint Boulevard, Winston-Salem, Forsyth County, North Carolina, and will be operated in accordance with the renewal application submitted March 29, 2012, and in conformity with the specifications and supporting data submitted April 4, 2012 and April 24, 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 April 30, 2014, and shall be subject to the specified conditions and limitations set forth in Parts I through X hereof. Permit issued this the 3rd day of May, 2012. for Charles Wakild, P.E., Director Division of Water Quality By Authority of the Environmental Management Commission. Permit No. WI0400035 PAGE 1 OF 6 ver. June 2011 UIC-5I/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 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. 9. Within 30 days of completion of well construction, a completed Well Construction Record (Form GWA) must be submitted for each injection well to: Aquifer Protection Section — UIC Staff DENR — Division of Water Quality 1636 Mail Service Center Raleigh, NC 27699-1636 PART II - WELL CONSTRUCTION SPECIAL CONDITIONS 1. 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 919-807-6352 and the Winston-Salem Regional Office Aquifer Protection Section Staff, telephone number (336) 771-5000. 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. WI0400035 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 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 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 919-807-6352. 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. W10400035 PAGE 3 OF 6 ver. June 2011 UIC-51/5T 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 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 monitoring plan included in the application shall be followed. All sample results shall be submitted quarterly, semi-annually, or annually to the Aquifer Protection Section's Winston-Salem 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 Permittee 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. 5. The monitoring results and the final project evaluation shall be submitted to: UIC Program Staff DWQ — Aquifer Protection Section and 1636 Mail Service Center Raleigh, NC 27699-1636 DWQ - Aquifer Protection Section Winston-Salem Regional Office 585 Waughtown Street Winston-Salem, NC 27107-2241 Permit No. WI0400035 PAGE 4 OF 6 ver. June 2011 UIC-51/5T 6. 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 (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. 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 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 .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. (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. WI0400035 PAGE 5 OF 6 ver. June 2011 UIC-5I/5T (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. WI0400035 PAGE 6 OF 6 ver. June 2011 UIC-51/5T NCDENR North Carolina Department of Environment and Natural Resources Division of Water Quality Beverly Eaves Perdue Coleen H. Sullins Governor Director June 13, 2011 Louis Schaab Allied Capital Corporation 1919 Pennsylvania Avenue NW Washington, DC 20006 Ref: Reduce Frequency of Required Reporting Injection Well Permit # W10400035 Fairchild Industrial Products Company, Winston-Salem, Forsyth County, NC Dear Mr. Schaab: Dee Freeman Secretary Presently Allied Capital Corporation is required to submit quarterly reports regarding groundwater remediation activities associated with the permit and facility referenced above. This letter authorizes Allied Capital Corporation to submit the required monitoring results semi-annually or annually instead of quarterly if it so chooses. This option for reduced reporting frequency in no way alters the analytical parameters, wells, or monitoring frequency required in the permit referenced above. Additionally, this option does not apply to any other reporting requirements required by any other permit or regulatory agency. Please contact me by email at Thomas.Slusser@ncdenr.gov or telephone at 919-715-6164 if you have any questions. Best Regards, Thomas Slusser, L.G. Program Manager Underground Injection Control Program cc: W10400035 permit file Aquifer Protection Section, Winston-Salem Regional Office Chris Hay, Kleinfelder Southeast, Inc., 313 Gallimore Dairy Road, Greensboro, NC 27409 AQUIFER PROTECTION SECTION 1636 Mail Service Center, Raleigh, North Carolina 27699-1636 Location: 2728 Capital Boulevard, Raleigh, North Carolina 27604 Phone: 919-733-3221 ; FAX 1: 919-715-0588; FAX 2: 919-715-60481 Customer Service: 1-877-623-6748 Internet: www.ncwaterauality.org One NorthCarolina ;Vaturallry An Equal Oppoitunity, 1 Affirmative Action Employer DOCUMENTS FROM EARLIER PERMIT APPLICATIONS 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 Allied Capital Corporation FOR THE OPERATION OF 15 TYPE 5I INJECTION WELLS, defined in Title 15A North Carolina Administrative Code 2C .0209(e)(3)(C), to inject 3D Microemulsion and BDI plus solution, for the enhancement of bioremediation of chlorinated solvents. These injection wells will be located at the Fairchild Industrial Products Company Site, 3920 Westpoint Boulevard, Winston-Salem, Forsyth County, North Carolina, and will be operated in accordance with the permit modification submitted February 9, 2010 and additional information submitted June 2, 2010, and in conformity with the specifications and supporting data 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 Actor 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 May 31, 2012, and shall be subject to the specified conditions and limitations set forth in Parts I through X hereof. Permit issued this the fill- day of , 2010. J, ('JA Coleen H. Sullins, Director Division of Water Quality By Authority of the Environmental Management Commission, Permit No. WI040003 PAGE 1 OF 6 ver.8/07 AP/UIG6 PART I - WELL CONSTRUCTION GENERAL CONDITIONS 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. 9. 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 Staff DENR-Division of Water Quality 1636 Mail Service Center Raleigh, NC 27699-1636 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) 715-6168 and the Winston-Salem Regional Office Aquifer Protection Section Staff, telephone number (336) 771-5000. Permit No. WI011000'.4' PAGE 2 OF 6 ver.8/07 AP/UIC-6 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 which may be imposed by other local, state, and federal agencies which have jurisdiction. Furthermore, the issuance of this permit does not imply that all regulatory requirements have been met. PART IV - PERFORMANCE STANDARDS 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. 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. 2. 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. 3. 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 physical 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) 715-6168. 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. WI040o l PAGE 3 OF 6 ver.8/07 AP/UIC-6 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. The proposed monitoring plan included in the application shall be followed. All sample results shall be submitted to the Aquifer Protection Section's Winston-Salem 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 insure surface and ground water protection, will be established and an acceptable sampling reporting schedule shall be followed. 2. The Permittee shall submit an Injection Event Record within 30 days of completing each injection. 3. 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. 4. The monitoring results and the final project evaluation shall be submitted to: and to: Aquifer Protection Section-UIC Staff DENR-Division of Water Quality 1636 Mail Service Center Raleigh, NC 27699-1636 Aquifer Protection Section DENR-DWQ Winston-Salem Regional Office 585 Waughtown Street Winston-Salem, NC 27107-2241 Permit No. WI0400(.)? PAGE 4 OF 6 ver.8/07 AP/UIC-6 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 (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. 6. 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. 7. 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 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 .0113, 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 .0113(b), 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. WI04000' 5 PAGE 5 OF 6 ver.8/07 AMIC-6 (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 Staff DENR-Division of Water Quality 1636 Mail Service Center Raleigh, NC 27699-1636 PART X — WORKER PRECAUTIONS DURING APPLICATION Some effects reported to be associated with the product proposed to be used are as follows: eye, skin, nose, throat, lungs and gastrointestinal irritation or burns. 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. Site access should be limited to worker's involved in the injection of the solution. 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. WI0400 , PAGE 6 OF 6 ver.8/07 AP/MIC-6 DIVISION OF WATER QUALITY AQUIFER PROTECTION SECTION June 7, 2010 PERMIT ISSUANCE MEMO TO: Debra Watts cl l 1 0 THROUGH: Thomas Slusser — �� � FROM: John. McCray RE: Permit To Inject 3DMe and Re,_,enesis Bio-Dechlor Inoculum Fairchild Industrial Products Company I recommend that Permit Number WI0400035 be issued to Fairchild Industrial Products to inject 3DMe and Regenesis Bio-Dechlor 1110eUlum to remediate soils and groundwater contaminated with PCF. and TCf . SITE DESCRIPTION The Fairchild Industrial Products Company site is a multi -use facility housing office space, wareltousing, shipping, light manufacturing, and assembly operations. PCE contamination above 2L standards was discovered and subsequent remedial activities have been conducted. Previous investigations identified spillage onto the process room floor and the above ground storage tanks as the possible sources of contamination. Remedial activities previously conducted consisted of injection of hydrogen Release Compound in order to facilitate anaerobic dechIorinaLion. HYDROGEOLOGIC DESCRIPTION The site is located in the Piedmont Physio<graphic Province and is underlain by bedrock ofthe Carolina Slate Belt. Residual soils underlying the site consist of silty sand with some layers of sandy silt and sandy clay and extend to depths greater than 43.5 feet below the ,round surface(bgs). Bedrock was not penetrated by any of tlic wells and it was determined not to have been contaminated by the spill at the site. The surficial aquifer was encountered at depths ranging from 10.6 to 24.2 feet (bgs) across the site and flows toward the southeast under a hydraulic gradient of .02 foot per foot. The aquifer has an estimated effective porosity of 0.25 with a hydraulic conductivity of1 2 feet per day allowing the water to flow at an estimated rate of 0.1 feet per day. , EXTENT OF CONTAMINATION Contamination underlying the site has been reduced into two separate Plumes. The plumes are located under the western and southeastern portions of the property. The western plume. underlying the building, is approximately 90ft. long by 70 ft. wide (according, to text) with the long axis extending along a line defined by wells MvA'-] 0 and MW-9. The southeastern plume, underlying an area just to the southeast of the building, is approximately 601E ]on,, by 45 fi. wide (according to text) with the long axis that is sub -parallel to the larger plume. Plume locations are illustrated on FiLlure 7 in the permit application received February 9. 2010. PROPOSED INJECTION The Applicant proposes to inject 3DMe and Bio-dechlor Inoculum (BDI) (if needed) into the underlying aquifer through fifteen permanent injection wells at low (10 -15 psi) pressure in two injection events. The total volume of the injectants is 6,000 gallons, of which 3,000 gallons are 3DMe solution and 3,000 gallons are BDI solution. The estimated percentage of pore volume displacement relative to the contaminant plume volume is 0.1 %. HOW IT WORKS The remedial process of 3D-Me is as a carbon energy source for naturally occurring halorespirating bacteria to continue consumption and degredation of the contaminants. Bio-dechlor inoculum is a proprietary blend of halorespirating bacteria, including dehalococcoides. MONITORING Subsequent groundwater monitoring will be conducted utilizing the previously approved plan. This plan consists of eight monitoring wells (MWs-1, 2, 5, 6, 7, 9, 10, and 13) for the following parameters: VOCs, nitrite, nitrate, phosphate, sulfate, sulfide, iron, chloride, manganese, lactic acid, pyruvic acid, acetic acid, and propionic acid. Field measurements will be made of alkalinity, total organic carbon, conductivity, dissolved oxygen, oxidation-reduction potential, pH, and temperature. EPIDEMIOLOGY On January 17. 2007, the DHHS' Epidemiology Branch provided comments on 31)Me for groundwater remediation. Dr. Luanne 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 Shnvin`, Wan- of the \Vinslon-Salem Regional Office recommends issuance of this permit. 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 Fairchild Industrial Products Company FOR THE CONSTRUCTION AND OPERATION OF TYPE 5I INJECTION WELLS, defined in Title 15A North Carolina Administrative Code 2C .0209(e)(3)(C), for use to inject an HRCT"' Slurry to enhance reductive dechlorination of the dissolved chlorinated hydrocarbon contamination at this site. These injection wells/points will be located at 3920 Westpoint Boulevard, Winston-Salem, North Carolina, and will be operated in accordance with the application submitted November 17, 2006 and in conformity with the specifications and supporting data 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 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 May 30, 2010, and shall be subject to the specified conditions and limitations set forth in Parts I through X hereof. Permit issued this the Z� day of 2007. , Alan W. Klimek, Director Division of Water Quality By Authority of the Environmental Management Commission. Permit No. WI0400035 PAGE 1 OF 6 vei .2/07 AP/TJIC-6 PART I - WELL CONSTRUCTION GENERAL CONDITIONS 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. 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. 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. 9. 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 Staff DENR-Division of Water Quality 1636 Mail Service Center Raleigh, NC 27699-1636 PART II - WELL CONSTRUCTION SPECIAL CONDITIONS 1. 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) 715-6164 and the Winston-Salem Regional Office Aquifer Protection Section Staff, telephone number (336) 771-5000. Permit No. WI0400035 PAGE 2 OF 6 ver.2l07 APIUIC-6 PART III - OPERATION AND USE GENERAL CONDITIONS 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 which may be imposed by other local, state, and federal agencies which have jurisdiction. Furthermore, the issuance of this permit does not imply that all regulatory requirements have been met. PART IV - PERFORMANCE STANDARDS 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. 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. 2. 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. 3. 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 physical alterations or additions in the permitted facility or activity not specifically authorized by the permit. 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) 715-6164. 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. WI0400035 PAGE 3 OF 6 vu.2/07 AP/UIC-6 PART VI - INSPECTIONS 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 The proposed monitoring plan included in the application shall be followed. All sample results shall be submitted to the Aquifer Protection Section's Winston-Salem 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 insure surface and ground water protection, will be established and an acceptable sampling reporting schedule shall be followed. 2. The Permittee shall submit an Injection Event Record within 30 days of completing each injection. 3. The Permittee shall produce a final project evaluation within 9 months after completing all injection -related activity associated with the permit application. 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. 4. The monitoring results and the final project evaluation shall be submitted to: Aquifer Protection Section-UIC Staff DENR-Division of Water Quality 1636 Mail Service Center Raleigh, NC 27699-1636 and to: Permit No. WI0400035 PAGE 4 OF 6 ver.2/07 AP/UIC-6 Aquifer Protection Section DENR-DWQ Winston-Salem Regional Office 585 Waughtown Street Winston-Salem, NC 27107 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 (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. 6. 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. 7. 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 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 .0113, 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 .0113(b), 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. Pernut No. WI0400035 PAGE 5 OF 6 ver.2/07 AP/UIC-6 (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-LUIC Staff DENR-Division of Water Quality 1636 Mail Service Center Raleigh, NC 27699-1636 PART X — WORKER PRECAUTIONS DURING APPLICATION I . 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. WI0400035 PAGE 6 OF 6 ver.2/07 AMIC-6 DIVISION OF WATER QUALITY AQUIFER PROTECTION SECTION May 1, 2007 MEMORANDUM TO: THROUGH FROM: SUBJECT: Debra Watts Qu Qi Peter Pozzo Injection well permit No. WI0400035 modification and renewal for Fairchild Industrial Products Company The subject permit application has been reviewed with the following remarks: 1. Site Overview: This facility houses office space, warehousing, shipping, light manufacturing, and assembly areas. An unknown quantity of perchloroethylene (PCE) has contaminated the soil and groundwater to above 2L standards at this site during multiple releases. Potential sources include spillage onto the process room floor that has reached the subsurface and spillage/leakage from above ground storage tanks. Two previous permits (WI0400021 and WI0400025) have been issued for injection of Hydrogen Release Compound (HRCTM) at this site to remediate this plume. The results of the full scale injection show decreases in the target contaminants on the formation of their daughter products. Two additional injection wells will be added and three additional injections events will be performed. 2. Injection: The applicant proposes to inject 7 pounds (17.5 gallons total) of HRCTM per vertical foot for the two new wells and 5 gallons each for 9 existing wells from 20 to 35 feet below ground surface. HRCTM releases lactic acid in the subsurface, where it is metabolized by anaerobic microbes producing dissolved hydrogen. This hydrogen is used by other anaerobic microbes which remove chlorine atoms from the solvent molecules. 3. Monitoring: The results of the HRCTM injection will be monitored at 8 monitoring wells. The location and depth of the wells, and quarterly sampling suite is sufficient to monitor the injection results. Sampling parameters include VOC's, nitrite, nitrate, phosphate, sulfate, sulfide, iron, chloride, manganese, lactic acid, pyruvic acid, acetic acid, propionic acid, alkalinity, TOC, conductivity, DO, oxidation-reduction potential, pH, and temperature. 4. Epidemiology: Dr. Luanne Williams provided a risk evaluation of HRCTM on August 1, 2000 and did not identify any concerns that would prohibit this injection. 5. Regional Office: Sherri Knight conducted a review of the site and didn't find any concerns that would prevent issuing the permit. Based upon the remarks presented above, I recommend issuance of the permit. If you have any questions, please let me know. Central Files: APS SWP 12/04/06 i l i,lt tit W10400035 Permit Tracking Slip Program Category Status Project Type Ground Water In review Minor modification Permit Type Version Permit Classification Injection In situ Groundwater Remediation Well (51) Individual Primary Reviewer peter.pozzo Permitted Flow Permit Contact Affiliation Christopher Hay, El 313 Gallimore Dairy Rd Greensboro NC 27409 Facility Name Major/Minor Region Fairchild Industrial Minor Winston-Salem Location Address 3920 Westpoint Blvd Winston-Salem NC 27103 County Forsyth Facility Contact Affiliation Owner Owner Name Owner Type Fairchild Industrial Non -Government Owner Affiliation 3920 Westpoint Blvd Winston Salem NC 27103 Scheduled Orig Issue App Received Draft Initiated Issuance Public Notice Issue Effective Expiration 12/01 /03 11 /17/06 PgUlatr=d Aa;tivities Rfef = ;t &Rec vivo( Unknown 00 RO staff report requested RO staff report received Waterbody Name Stream Index Number Current Class Subbasin DIVISION OF WATER QUALITY GROUNDWATER SECTION November 20, 2003 MEMORANDUM TO: Ted Bush THROUGH: Evan Kane FROM: Mike Ranck�� SUBJECT: Injection well permit application for Fairchild Industrial Products Company The subject permit application has been reviewed with the following remarks: Site Overview: This facility houses office space, warehousing, shipping, light manufacturing, and assembly areas. An unknown quantity of perchloroethylene (PCE) has contaminated the soil and groundwater to above 2L standards at this site during multiple releases. Potential sources include spillage onto the process room floor that has reached the subsurface and spillage/leakage from above ground storage tanks. Two previous permits (WI0400021 and WI0400025) have been issued for injection of Hydrogen Release Compound (HRCTM) at this site to remediate this plume. The results of the pilot test (WI0400021) in 2000 indicated that HRCTM injection would likely be an effective means of chlorinated hydrocarbon remediation at this site. The second injection (WI0400025) was performed in 2001. Sampling in November 2002 indicated that HRCTM was continuing to reduce PCE levels at the monitor wells from this injection. 2. Injection: The applicant proposes to inject 7 pounds of HRCTM per vertical foot at 26 locations (6 existing, 20 proposed) from 20 to 35 feet below ground surface. HRCTM releases lactic acid in the subsurface, where it is metabolized by anaerobic microbes producing dissolved hydrogen. This hydrogen is used by other anaerobic microbes which remove chlorine atoms from the solvent molecules. 3. Monitoring: The results of the HRCTM injection will be monitored at 8 monitoring wells. The location and depth of the wells, and quarterly sampling suite is sufficient to monitor the injection results. Sampling parameters include nitrite, nitrate, phosphate, sulfate, sulfide, iron, chloride, manganese, lactic acid, pyruvic acid, acetic acid, propionic acid, alkalinity, TOC, conductivity, DO, oxidation- reduction potential, pH, and temperature. 4. Epidemiology: Dr. Luanne Williams provided a risk evaluation of HRCTM on August 1, 2000 and did not identify any concerns that would prohibit this injection. 5. Other concerns: Two water supply wells are located within 1500 feet of the site. One well is actively used, the other is not (home is served by municipal water). Based upon the remarks presented above, I recommend issuance of the permit. If you have any questions, please let me know. NORTH CAROLINA ENVIRONMENTAL MANAGEMENT COMMISSION DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES RALEIGH, NORTH CAROLINA PERMIT FOR THE CONSTRUCTION AND OPERATION OF WELLS 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 Fairchild Industrial Products Company FOR THE CONSTRUCTION AND OPERATION OF TYPE 5I INJECTION WELLS, defined in Title 15A North Carolina Administrative Code 2C .0209(e)(3)(C), for use to inject an HRCT111 slurry to enhance reductive dechlorination of the dissolved chlorinated hydrocarbon contamination at this site. These injection wells/points will be located at 3920 Westpoint Boulevard, Winston-Salem, North Carolina, and will be operated in accordance with the application submitted September 17, 2003 and in conformity with the specifications and supporting data 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 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 November 30, 2006, and shall be subject to the specified conditions and limitations set forth in Parts I through X hereof. Permit issued this the I` -sr day of ��;� E,.,,��L�A 2003. Ted L. Bush, Jr., Assistant Chief Groundwater Section Division of Water Quality By Authority of the Environmental Management Commission. Permit No. WI0400035 PAGE 1 OF 6 ver.3/01 G W/UIC-6 PART I - WELL CONSTRUCTION GENERAL CONDITIONS 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. Each injection well shall not hydraulically connect separate aquifers. 4. Each injection well shall be constricted in such a manner that water from land surface cannot migrate into the gravel pack or well screen. 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 must be secured with a locking cap. 6. Each injection well shall be afforded reasonable protection against damage during construction and use. 7. Each injection well shall have permanently affixed an identification plate. 8. A completed Well Construction Record (Form GW-1) must be submitted for each injection well to, DENR-Division of Water Quality, Groundwater Section UIC-Staff, 1636 Mail Service Center, Raleigh, NC 27699-1636, within 30 days of completion of well construction. PART II - WELL CONSTRUCTION SPECIAL CONDITIONS 1. At least forty-eight (48) hours prior to constructing each injection well, the Permittee shall notify the Groundwater Section -Underground Injection Control (UIC), Central Office staff, telephone number (919) 715-6165. PART III - OPERATION AND USE GENERAL CONDITIONS This permit is effective only with respect to the nature, volume of materials and rate of injection, as described in the application and other supporting data. 2. This pen -nit 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. Permit No. W10400035 PAGE 2 OF 6 ver.3/01 GW/UIC-6 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 which may be imposed by other local, state, and federal agencies which have jurisdiction. Furthermore, the issuance of this permit does not imply that all regulatory requirements have been met. PART IV - PERFORMANCE STANDARDS 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. 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. 2. 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. 3. 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 physical 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 Groundwater Section -Underground Injection Control (UIC), Central Office staff, telephone number (919) 715-6165. 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. PART VI - INSPECTIONS 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. Permit No. WI0400035 PAGE 3 OF 6 ver.3/01 GW/UIC-6 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 The proposed monitor plan included in the application addendum received November 17, 2003 shall be followed. All sample results shall be submitted to the Groundwater Section's Winston-Salem 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 insure surface and ground water protection, will be established and an acceptable sampling reporting schedule shall be followed. 2. The Permittee shall produce a final project evaluation within 9 months after completing all injection -related activity associated with the permit application. 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. 3. The final project evaluation shall be submitted to the Underground Injection Control Program, Groundwater Section, NC DENR-Division of Water Quality, 1636 Mail Service Center, Raleigh, NC 27699-1636 and to the Groundwater Section, Winston-Salem Regional Office, 585 Waughtown Street, Winston-Salem, NC 27107. 4. 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 (336) 771-4600, 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. 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. 6. 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. WI0400035 PAGE 4 OF 6 ver.3i01 GW/ JIC-6 PART VIII - PERMIT RENEWAL The Permittee shall, at least three (3) months prior to the expiration of this permit, request an extension. PART 1X - CHANGE OF WELL STATUS 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 .0213(h)(1), 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 materials may be removed prior to initiation of abandonment procedures if the Director finds such removal will not be responsible for, or contribute to, the contamination of an underground source of drinking water. (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. (D)Drilled wells shall be completely filled with cement 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 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 temis 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. Permit No. WI0400035 PAGE 5 OF 6 ver.3- 01 GW/UIC-6 3. The written documentation required in Part IX (1) and (2) (G) shall be submitted to: Groundwater Section-UIC Staff DENR-Division of Water Quality 1636 Mail Service Center Raleigh, NC 27699-1636 PART X — WORKER PRECAUTIONS DURING APPLICATION 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. The Material Safety Data Sheets should be followed to prevent incompatible or adverse reactions and injuries. Permit No. WI0400035 PAGE 6 OF 6 ver.3/01 G W/UIC-6 Application Reviewer: _ � Qrw k,1 Pre -Review: Conducted? );es ❑ No O.K. to Process? ETIYes ❑ No If No, What Action Is Needed? ❑ Pre -Review Return ❑ Hold, Pending Receipt of Addinfo.: Name/Affiliation of Person Contacted: Date(s) of Contact: Owner: �xisting ❑ Unknown Owner Type Facility/Operation:, ❑ Proposed ❑­txisting Regulated Activities: Application/Permit: Permit Type: ❑ Injection Water Only GSHP Well System (SQW) ❑ Injection Mixed Fluid GSHP Well System (5QM) ❑ Injection Tracer Well (5T) ❑ Injection Experimental Technology (5X25) Project Type: ❑ New ❑ Major Mod. Notes: ❑ By Phone ❑ By E-Mail ❑ By Letter on -Gov't (❑ Ind. or Ddrg) ❑ Gov. -Municipal ❑ Gov. -County ❑ Gov. -State ❑ Gov. -Federal ❑ Facility ❑ Operation Injection In situ Groundwater Remediation Well (5I) ❑ Injection Heating/Cooling Water Return Well (5A7) ❑ injection Other Wells (5Z) ❑ Injection Aquifer Recharge (5R21) ❑ Minor Mod. Renewal ❑ Renewal w/ Mod. FORM: BIMS 10/04/2007