WI0400182_Permit (Issuance)_20110526

NORTH CAROLINA
ENVIRONMENTAL MANAGEMENT COMMISSION
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
RALEIGH, NORTH. CAROLINA
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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
USI Realty Corporation
FOR THE CONSTRUCTION AND/OR OPERATION OF 1 TYPE 5I INJECTION WELLS, defined
in Title 15A North Carolina Administrative Code 2C .0209(e)(3)(C), to inject I% milk solution for
the reduction of nitrate, nitrite, ammonia, and TKN by enhanced bioremediation. This injection
wells/points will be located at the Former Ingram Plywood Facility, 718 Bassett Dr., Thomasville,
Davidson County, NC 27360, and will be operated in accordance with the application submitted
March 25, 2011, and in conformity with the specifications and supporting data submitted May 5,
2011, and May 10, 2011, 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 April 30. 2013a, and
shall be subject to the specified conditions and limitations set forth in Parts I through X hereof.
Permit issued this the 26th day of May, 2011.
Coleen H. Sullins, Director
Division of Water Quality
By Authority of the Environmental Management Commission.
Permit No. W D sa -I > _ PAGE 1 OF F
ver. Oct.2010 ANUIC-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 ?C .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 Program
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 [phone] and the Winston-Salem Regional Office Aquifer Protection Section Staff,.
telephone number [phone].
Permit No, VLr104001 s-' PAGE 2 4F 6
ver. act.20I 0 AP/UIC-6

PART III - OPERATION AND USE GENERAL CONDITIONS
1. This permit is effective only with respect to the nature, volume ofmaterials, rate of injection. and
number of injection wells as described in the application and other supporting data.
?. 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 maybe 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 tithes 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.
?. 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 fxom the operation of this facility. y
PART V - OPERATION AND MAINTENANCE REQUIREMENTS
1, The injection facility shall be properly maintained and operated at all times.
3. 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 [phone]. 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. W i41 11PAGE 3 OF 6
ver, Oct?U] 0 APUIC-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. 8 7-
90.
Provisions shall be made for collecting any necessary and appropriate samples associated with
the injection facility activities.
PART VII - MONITORING AND REPORTING REQUIREMENTS
The revised monitoring plan received May 10, 2011, shall be followed including a baseline pre -
injection sampling event.
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 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:
and to:
Aquifer Protection Section-UIC Program
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. WI040 a 1 PAGE 4 OF 6
ver. Oct.2010 APIUIC-6

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 [phone], any of
the following:
(A)Any occurrence at the injection facility which results in any unusual operating
circumstances;
(B) Any failure due to known or unknown reasons, that renders the facility incapable of
proper injection operations, such as mechanical or electrical failures.
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 Pennittee 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
Pau ittee 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
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. WI1 s4� F - PAGE 5 OF 6
ver. Qct.201 D AP•UC-6

(D) Drilled wells snail 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 (Farm 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 he 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. WD 14,1W PAGE 6 OF 6
ver, Oci.?O] 0 APIUIC-6

DIVISION OF WATER QUALITY
AQUIFER PROTECTION SECTION
May 12. 2011
MEMORANDUM
TO: Debra Watts
FROM: Michael Rogers M
RE: Issuance of Permit to Inject 1 % mills solution (Permit #WI0400182)
US1 Realty Corp. (Former Ingram Plywood Facility)
I recommend that Permit Number W10400182 be issued to USI Realty Corp. to inject the above referenced compound(s) to
remediate groundwater (GW) contaminated with nitrate, nitrite, ammonia, and total kjeldahl nitrogen (TKN). The site is located
at the Former Ingram Plywood facility, 718 Bassett Dr., Thomasville, Davidson County, NC 27360.
SITE DESCRIPTION: The subject site is a former plywood manufacturing facility, which shaped and molded plywood.
Resins used in the manufacturing apparently was stored and/or disposed of improperly and has evidently impacted the
groundwater in the area (Figures 1 and 2). Presently, the site is vacant.
HYDROGEOLOGIC DESCRIPTION: The site is located in the North Carolina Piedmont Province. The site geology consists
primarily of inter -bedded silt and fine sand to the total depth investigated. Depth to GW in the surficial aquifer ranges from
approximately 8-15 feet BLS and flows in a generally southerly direction at a reported velocity of 511 feet/year (Figure 4).
EXTENT OF CONTAMINATION: The primary contaminant of concern is nitrate. The plume is sortof like a lima bean in shape:
approximately 150 feet long and 100 feet wide. The 10 mglL contour line is located within property boundaries (Figure 3).
According to the Applicant, there are no known active water supply wells within 114 mile.
PROPOSED INJECTION: This proposed injection is a pilot test, and will be via 1 injection well slightly upgradient of
monitoring well MW-10 in the nitrate plume. Currently, there is only one injection, event planned. The injection event
will last 1 day with 480 gallons of injectantto be injected. The potential displacement of the interstitial void space is
approximately 17%. Refer to revised Figure 3 for location of the injection well and monitoring wells (disregard Figure
5). Also, see a new schematic of the proposed injection well construction behind Additional Information Letter received
May 6, 2011.
HOW IT wORKS: The Applicant is proposing to use a solution of I % milk and 99% water. Studies indicate this 1% milk
solution can remediate groundwater contamination by providing a carbon source for stimulation of the biologic community
(bioremediation),
MONITORING: There will be 2 existing monitoring wells (MW-10 and PMW-7) and 3 proposed monitoring wells in the
sampling network. Monitoring will be prior to injection, during injection, and then at weeks 1, 3, 6, and 12. During injection
field parameters only will be collected. At my request, they added PMW-7 to the monitoring plan, and I am requesting a pre-
injection/baseline monitoring event as a permit condition. Refer to Revised Figure 3 for the location of the monitoring wells
(highlighted in yellow).
EPIDEMIOLOGY: The DHHS has reviewed and approved the above referenced injectant(s).
REGIONAL OFFICE COMMENTS: Each of the RO comments/recommendations are discussed below (RO's
comments/recommendations are underlined).
The W-SRO had no continents or recommendations.
Sherri Knight, and Shuying Wang of the Winston-Salem Regional Office recommends issuance of this permit.

5I Calculations Worksheet
-xpplicantlFacility: ttLE��`/�i i 7� CE;►�P �_��vlz.rr
Permit No. 'All /
Date: III
Reviewer: &tt
V v - I -
Depth to groundwater (GW) BLS
GW flow direction: gry
MWs installed in same aquifer as injection?_(Y or N ): Inj zone: ID MW zone: —
Nearest water supply well: i
Groundwater- Flow Rate
►'" av HC X . W- Qradient(F1'?) flow rate/DAY(?) X 365 = FT/IR
3 J SY or porosity (--.30)
Reported:���
[FIT 60 min/day X 24 hrs X 365 days = 525.600! 1
Calculations for Potential Contaminate Plume Displacement
3.142 (;1) X r- X 15 height = .''x CF
CF X . ' J Sir or porosity (i.e. —.30) = S_ CF of available void
space
_CF of available void space X 7.49 gralions = gallons of water in void sp
gallons of injectant = _°�6 of fluid displaced by injectant (move decimal)
gallons of water in void space
Potential displacement of plume by injection;
Injection Volume and Pumpin- Rate Per Well Per Da,
`-/? L) total amt. of injectant ; number of wells number of days of injection event =
q S D amount of injectant per well per day (average 4gallons per day)
S:UICApplications and forms 51 Calculations worksheet version 9,'ifl'l0