HomeMy WebLinkAboutWI0400140_Permit (Issuance)_20101007DIVISION OF WATER QUALITY
AQUIFER PROTECTION SECTION
October 7. 2010
MEMORANDUM
TO: Debra Watts
FROM: Michael Rogers #'�
CJ 'iD II
THROUGH: Thomas Slusser
RE: Issuance of permit to inject RegenOx (Permit # WI0400140)
ARAMARK Uniform and Career Apparel facility located at 509 Teague Street, Greensboro, Guilford
County, NC 27406
I recommend that Permit Number W10400140 be issued to ARAMARK Uniform and Career Apparel to inject RegenOx to
remediate groundwater (GW) contaminated with chlorinated solvents.
SITE DESCRIPTION: The subject Site is an industrial laundry facility and uniform distribution depot (Figure 1), A PCE
spill occurred in the 1980s and the Site has been undergoing various forms of remediation since then.
HYDROGEOLOGIC DESCRIPTION: The Site is located in the Piedmont Physiographic Province, and within the Carolina
Slate Belt. In the area of the Site, the overburden consists of saprolite to approximately 40 feet BLS, a transition zone to 45
feet BLS, and fractured crystalline bedrock at approximately 45-50 feet. The injection for this project is in the overlying
unsaturated zone (vadose zone). Depth to groundwater (GW) is approximately 30 feet BLS. GW in the saprolite generally
flows southeast at approximately I i fllyear (Figure 8) and 40 feetlyear in the transition zone.
EXTENT OF CONTAMINATION: The contaminant plume in the surficial aquifer (saprolite) is generally oval and is
approximately 300 feet long and 150 feet wide (Figure 11). The contaminant plume in the transition zone is fairly massive and
extends off -site over 500 feet downgradient. According to the Applicant, the nearest water supply well is located approximately
100 feet southwest of the site, which is cross -gradient (Figure I).
PROPOSED INJECTION: The proposed injection consists of 3 separate injection events with each event injecting a total of
5482 gallons of injectant via 18 direct push injection wells (estimated 61 gallons per day per well). Each injection event is
to last 3-5 days with 3-8 weeks between events (Attachment H). These wells will inject from 5-22 feet BLS in the
unsaturated zone (soil hot zones). The estimated amount of fluid displacement from injection when the injectant reaches
the saturated zone is approximately 12%. Therefore, the potential displacement of the plume is low.
HOW IT WORKS: RegenOx is used to remediate groundwater contaminated with volatile organic compounds by oxidation.
This remediation approach has been approved by the Guilford County Environmental Health Department, which has
oversight and is a contract County for the Division of Waste Management.
MONITORING: Per our request, ARAMARK submitted a revised monitoring plan. The wells to be used as part of the
monitoring network are identified on Attachment F. For volatiles and metals, the proposed monitoring frequency will be once
prior to injection and then approximately 6 months following the 3rd and final injection. Geochemical field parameters will be
analyzed prior to each of the 3 injection events and approximately 2 weeks after each of the 3 injection events. Additionally,
soil samples will be collected l month after the final event to determine effectiveness of the remediation in the soil.
EPIDEMIOLOGY: The DHHS has reviewed and approved RegenOx as an injectant.
REGIONAL OFFICE COMMENTS: Each of the RG comments/recommendations are discussed below {RG's
comments/recommendations are underlined},
Item #I -Since infection of Regenax is to treat contaminated soil in the vadose zone, at some point after in6ection is
completed ... treated soil should be sampled for contaminants to be treated. ARAMARK has submitted a revised monitoring plan
to accomplish this item.
Item #2-To monitor effects of the proposed in on groundwater gualfty and in'ectants are not over applied, in'ectant
concentrations in GW should be also monitored. ARAMARK has submitted a revised monitoring plan to accomplish this item.
Item U-In order to monitor effects of injection activities on GW, an additional sampling event 6 months after the last injection
event is completed, should be considered. ARAMARK has submitted a revised monitoring plan to accomplish this item.
Shuying Wang and Sherri Knight of the Winston-Salem RO, 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 141. and other
applicable Laws, Rules, and Regulations
PERMISSION IS HEREBY GRANTED TO
ARAMARK Uniform and Career Apparel, LLC
FOR THE CONSTRUCTION ANDIOR OPERATION OF 18 TYPE 51 INJECTION WELLS,
defined in Title 15A North Carolina Administrative Code 2C .0209(e)(3)(C), to inject RegenOx . for
the remediation of groundwater contaminated with chlorinated solvents. These injection wells/points
will be located at the ARAMARK Uniform and Career Apparel, LLC facility, 509 Teague Street,
Greensboro, Guilford County, NC 27406, and will be operated in accordance with the application
submitted June 3. 2010, and in conformity with the specifications and supporting data received
August 26, 21010, 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 anyprovisions ofthe 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 September 30, 201?_
and shall he subject to the specified conditions and limitations set forth in Parts I through X hereof'.
Permit issued this the 13`h day of October 2010.
. L' \j*
oleen H. Sullins. Director
Division of Water Quality
By Authority of the Environmental Management Commission.
Permit No. W 10 - PAGE ] OF 7
ver. Jan?010 AP,'UICd►
PART I - WELL CONSTKLJCTION 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 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. WI04 (1140 PAGE _' OF 7
per. 1an.2010 APfUIC-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.
?. 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 theresponsibilityofcomplying 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 TV _ 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.
?. 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.
?. 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 fort' -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-U1C, Central Office staff.
telephone number (919) 71;-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. WI0-» PAGE 3 OF 7
per. ]an.2010 APU1C-n
PART VI - INSPECTIOINS
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
I. The proposed revised monitoring plan received August 26, 2010, which is 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. If an additional injection event or volume that exceeds the proposed
volume is required, the Permittee must notify the Division and receive prior written approval
from the Director or his representative.
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.
Permit No. W1440) i 4c F PAGE 4 OF 7
ver. Jan.2010 APAnC-b
The monitoring results and the final proiect 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
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, anv 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 anv 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 Ui - 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 ?C .0113, Well Construction Standards.
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
I5A NCAC ?C .0113(b). including but not limited to the following:
Permit No. W104 PAGE 5 OF 7
ver. Ian-2010 AP'-MC-6
(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.
(D) Drilled wells shall be completely filled with cement gout, or bentonite grout which shall
be introduced into the well through a pipe which extends to the bottom ofthe 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
1 SA 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, 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.
Permit No. W104(1i 1.1 PAGE 6 OF 7
ver. ]an.2610 APIMC-6
3_ Eating. drinkin4ir, smoking. handlin- 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. W10-- PAGE 7 OF 7
ver. Jan 2010 AP/UIC-6
51 Final Project Evaluation (FPE) Checklist
Permittee/Applicant: (J,rucJ� - * c.2 c GLC_ /
Permit No.: WI 0 S-oo r 4-0
Reviewer: S63 •r c s k S h rcg4-&xa.
Date: _ it 12- 1 2-o 1 ?-
1. Permit issued date: 12 1 13 Z Z c / 0 Expiration date: 9 / 3 0 1 -7 0 12-
2. BIMS: Check to see if there is a current renewal Application for this permit number under
review or newer permit issued (search by facility address). If this is case, no FPE is needed at
this time.
3. intent ofPermittee for this site (i.e., permit complete and no further injection activities planed,
future injection activities are planned, permit to be renewed,
etc.): A/0-t r te.C'M -
4. FPE or equivalent received? Y Date rec'd: 0 G / t 2120 Z If FPE or Al is needed, date
sent: . Date received:
5. Proposed monitoring reports received for most part? Y
6. Proposed sampling frequency complied with (e.g, monitored for 4 quarters)?
7. Proposed parameters analyzed?
y
8. Any clear evidence of daughter products? If evident, RD may want to review.
9. GW-ls or equivalent received? N Date: `As Built' well construction info
entered into BIMS? ; Date:
10. Status of injection wells (i.e., active- to be use as monitoring wells, abandoned,
etc.)
11. If abandoned, GW-30s Records received? Date: Status entered/changed into
BIMS? Date:
12. (Note- if we have not received GW-1s13Os for DPT wells, and obtaining these records is
problematic, injection well status forms (OW-68) may suffice. Bottom line, we need some
kind of a record, even e-mail from the Permitteelconsultant, with info on when the well points
were plugged.)
13. Any outstanding NGVs in BIMS?
14. Completion Letter Sent date:
Notes:
RIMS updated- `Permit Completed'
Revised 9-20-20 ] 6
51 Calculations Worksheet
Appticant/Facilit�•:,
Permit No. WI —
Date: ��I S Sre
Reviewer: D
C.s i
Depth to groundwater (GW): — 3 � BLS � ID
GW flow direction:
6--/WAC C--, 6,0 6-14, 42 c
MWs installed in same aquifer as injection?& (Y or N); lnj zone: �L U�w zone: � r t' 6)
ron er Flow Rate
00013
HC X .023 adient(FT?)
r SY or porosity (---.30)
;flow rate/DAY(?)
//, a-�
X 365 — FVYR
Reported: / CJ
Calculations for Potential Contaminate Plume Displacement
r~ X height = 2 fo d Z) CF
J CF X SY or porosity (i.e. —.30) _
space
6 f CF of available void
Z-3 CF of available void space X 7.4$ ag llons = �6 gallons of water in void sp
gallons of injectant = Id, % of fluid displaced by injectant (move decimal)
y5� gallons of water in void space
Potential displacement of plume by injection
fA t i
Injection 'Volume and Pumping Rate Pe Well Per Day
41, tVeA,�
total amt. of injectan�/ _&Lnumber of wells 1 number of days of injection event =
C�
amount of injectant per well per day (average gallons per day)
2 S-O - ?5") 3
--_ 63CO-Z
S:UIC/Applications and forms/ 5I Calculations worksheet version 7/23/10
5I Calculations Worksheet
Notes
I
PL,� W 1 pc� a rtla' `1
MW�
Ifie
5:UIC./Applications and forms/ 5I Calculations worksheet version 712310