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HomeMy WebLinkAboutWI0400131_Permit (Issuance)_20100810NORTH 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 Petitioner for DSCA Site #41-0024 FOR THE CONSTRUCTION AND/OR OPERATION OF 20 TYPE 5I INJECTION WELLS. defined in Title 15A North Carolina Administrative Code 2C .0209(e)(3)(C), to inject EHC, for the remediation of groundwater contaminated with chlorinated solvents. These injection wells/points will be located at the Fortner A Cleaner World #162, 4506 High Point Road, Greensboro, Guilford County, NC 27407, and will be operated in accordance with the application submitted April 13. 2010. and in conformity with the specifications and supporting data, 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 A 100 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 July 31, 24I2, and shall be subject to the specified conditions and limitations set forth in Parts I through X hereof. Permit issued this the 10`t' day of August 2010. �)& �' udk Coleen H. Sullins, Director Division of Water Quality By Authority of the Environmental Management Commission. Permit No. WI040013I PAGE I OF 6 ver. Jan?014 APUC-6 PART I - WELL CONm'RUCTION 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 (I 5A 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 dun'n,; 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) 715-6166 and the Winston-Salem Regional Office Aquifer Protection Section Staff, telephone number (336) 771-5000. Permit No. WI0400131 PAGE 2 OF 6 ver. dan.2010 APfMC-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 ofthe 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 he 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) 715-6166. 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. W10400131 PAGE 3 OF 6 ver. Jan.241 o APfUIC-C PART VI - INSPECT1uNS 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 except that during the pre -injection sampling event, collect groundwater elevation data from all monitoring wells and provide an updated groundwater potentiornetric map (the groundwater elevation data used for the potentiometric map provided in the application was collected December 16 through December 19, 2008). 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 Permit No. WI0400131 PAGE 4 OF 6 ver. Jan.2010 APIi.JIC-6 5. The Permittee shall report by telephone. within 4$ 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_ 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 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. W IWO 131 PAGE 5 OF G ver. ]an.2010 AP/UIC-6 (D) Drilled wells shall be completely filled with cement grout, orbentonite 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 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. WI0400131 PAGE 6 OF 6 ver. Jan.2010 APIUIC-6 DIVISION OF WATER QUALITY AQUIFER PROTECTION SECTION August 6, 2010 MEMORANDUM ►r�`� G TO: Debra Watts 11D, ¢' ] FROM: Michael Roger Cam- e.k. THROUGH: Thomas Slusser RE: Permit To Inject EHC {Permit #WI0400I 31) �� v) Former A Cleaner World (FACW ) I recommend that Permit Number W10400131 be issued to the applicant to inject EHC to remediate groundwater contaminated with chlorinated solvents. SITE DESCRIPTION: The subject Site is an active drop-off/pick up facility for dry cleaning located 4506 High Point Road, Greensboro, Guilford County, NC 27407 (Figures 1 and 2). The source of contamination is from former dry-cleaning operations that occupied a building that was demolished 1991. HYDROGEOI.OGIC DESCRIPTION: The Site is located in the Carolina Slate Belt of the Piedmont Physiographic province. In the area of the Site, the overburden consists of interbedded sand, silt, and clay coarsening with depth to partially weathered rock (saprolite) and granitic bedrock. Depth to groundwater (GW) is approximately 15 feet below land surface (BLS). in the area of the injection, the GW generally flows generally east-southeast at approximately 18 ftlyear (Figures 3 and 4). There is a west-northwest GW flow component on the west side of the property. EXTENT OF CONTAMINATION: The PCE contaminant plume is kidney bean shaped and extends off -site to the west approximately 600 feet and to the southeast approximately 1200 feet (Figure 5). According to the Applicant, there are no water supply wells within 114 mile of the Site. PROPOSED MJECTION: The proposed injection consists of injecting a total of approximately 5653 gallons of EHC via 20 direct push injection wells into a permeable reactive barrier (PRB). Theoretically, contaminated GW in the source area will migrate east-southeast through the PRB and be remediated (refer to Figure 3). Approximately 283 gallons of EHC will be injected through each well from about 14 to 38 feet BLS (47 gallons per day per well). There is one event planned, which will last 6 days. The estimated amount of fluid displacement from injection is approximately .8 %. Based upon the displacement volume and the very slow GW flow rate (approximately 18 feet per year), the potential displacement of the plume is, therefore, low. HOW IT WORKS: EHC is a patented combination of controlled release carbon and zero valent (ZVI) iron particles used for stimulating the insitu chemical reaction of organic compounds in GW. The injectant is a nutrient rich product that stimulates bacterial growth in GW, which in turn reduces the redox potential in the subsurface. The bacteria ferment carbon and releases fatty acids, which serve as electron donors for other bacteria. The ZVI stimulates dechlorination and additionally reduces the redox potential. Between natural attenuation and injection of this compound, solvent contamination in the GW is reduced. MONITORING: The following wells are proposed to be monitored for injection effectiveness: MW-1. MW-2, MW-3, MW-10S, MW-18S, and MW-18D. However, I am allowing the removal of MW-10S from the monitoring plan. because this well is approximately 600 feet east-southeast of the injection area and is not useful for monitoring the injection effectiveness. Per my request, groundwater elevation data is to be collected from all monitoring wells during the pre -injection activity and an updated groundwater flow map to be provided as the GW elevation data submitted in the application was collected in 2008. Monitoring frequency will be once prior to injection, and then I month, 3 months, 6 months, and one year after injection. EPIDEMIOLOGY: Dr. Luanne Williams has reviewed and approved EHC as an injectant. REGIONAL OFFICE COMMENTS: The only comment the regional office had was that High Point Rd. is very busy highway and that there should be cautioned taken by the drilling crew during injection activities. Sbuying and Sherri Knight of the Winston-Salem RD recommend issuance of this permit.