HomeMy WebLinkAboutWI0400093_Permit (Modification)_20160914Cerirral Files. APS SwP
0211211
Permit Number W10400093 Permit Tracking Slip
Program Category Status Project Type
Ground Water Active Renewal with major mod
Permit Type
Injection In situ Groundwater Remediation Well (51)
Primary Reviewer
michael.rogers
Coastal SW Rule
Permitted Flow
Version Permit Classification
2.00 Individual
Permit Contact Affiliation
Beau Hodge
G M P R S
1130 Situs Ct
Raleigh NC 27606
Facility _
Facility Name Major/Minor Region
Precision Fabrics Group, Inc. Greensboro Facility Minor Winston-Salem
Location Address County
301 E Meadowview Rd Guilford
Greensboro NC 27406 Facility Contact Affiliation
Owner
Owner Name Owner Type
Precision Fabrics Group Inc Non-Govemment
Owner Affiliation
Lee Aiken
301 Meadowview Rd
Greensboro NC
27406
Dates/Events
Scheduled
Orig Issue App Received Draft Initiated Issuance
Public Notice Issue Effective
Expiration
03/20/08 09l03109
01 /25/10 01 /25/10
12/31 /11
Regulated Activities
Requested/Received Events
Groundwater remediation
Additional information received
RO staff report requested
09/29/09
RO staff report received
11/24/09
Additional information requested
12/14/09
Additional information received
12/15/09
Additional information requested
01 /28/10
Additional information received
01 /29/10
Outfall `jUIL
Waterbody Name Stream Index Number Current Class Subbasin
DIVISION OF WATER QUALITY
AQUIFER PROTECTION SECTION
3anuary 25. 2f11 t,
MEMORANDUM
TO: Debra Watts
FROM: Michael Rogers
THROUGH: Thomas Slusser 7�
RE: Permit To Inject. Anaerobic Biocliem (ABC) and Dehalococcoides bacteria (DHC'.) (Permit #W10400093)
Precision Fabrics Group Inc., Greensboro, Guilford County, NC 27406
I recommend that Permit Number W10400093 be issued to the Precision Fabrics Group, Inc. (PFG) to inject ABC and DHC
bacteria to remediate groundwater (GW) contaminated with chlorinated solvents.
SITE DESCRIPTION: PFG's site is a fabric manufacturing facility that has been in operation by various owners since the 1940s
in downtown Greensboro (Figure 1). Past usage of TCE near former storage tanks has resulted in GW contaminated by VOCs.
A previous consultant conducted a pilot remediation injection project targeting the contamination at the property boundary
(barrier remediation), but this approach was unsuccessful. ERM. the present consultant, is proposing to inject remediation
products in the source area of the plume instead.
HYDROGEOLOGIC DESCRIPTION: The geology of the Site consists of top soillsaprolite, partially weathered rock (PWR),
fractured quartz vein, highly fractured bedrock (transition zone), and competent granitic/metamorphic bedrock. A small
fault is also present (Figure 4 & 9). The injection will be into the fractured quartz/PWR zone. GW (a.) flows generally
south, (b.) is approximately 25 feet BLS, and (c.) flows at approximately 406 ftlyear (Figure 8). The southern property
boundary is approximately 700-800 feet south.
EXTENT OF CONTAMINATION: The TCE contaminant plume in the shallow and intermediate aquifers, as presented in Figure
7, extends the entire length of the Site to the southern property boundary. It is approximately 250 feet wide and 60 feet thick in
the source area.
PROPOSED INJECTION: A total of 8000 gallons of ABC mixed with DHC will be injected into one existing monitoring
well (MW33SIIW-1) and one proposed injection well (IW-2) installed in the source area. The locations of the injection
wells are illustrated in Figure 10. There is a total of 1 proposed injection event every 6 months for 2 years (total 4 events).
However, the third and fourth injection events will be predicated on the effectiveness of each injection. Dilution water
will be obtained from city water sources.
HOW IT WORKS: Chlorinated ethenes such as TCEIPCE can be biologically transformed by DHC. Simple organic
compounds such as lactate and fatty acids can be added to stimulate the growth of the bacteria (i.e. food). Anaerobic ABC
will be used as food for the bacteria.
MONITORING: Per our request, a revised proposed monitoring plan (MP) was submitted (Attachment F). The revised MP
includes obtaining groundwater elevation data obtained from all wells at the Baseline sampling event, and adding 2
additional wells (IW-1, IW-2, and MW-3) to the plan. The MP consists of a baseline, 3-month, 6-month, 9-month, and 12-
month sampling events. No adverse geochemical reactions or displacement of the plume onto adjoining properties are
anticipated (approximately 7% of pore volume replaced wlinjectant per event).
EPIDEMIOLOGY: Dr. Luanne Williams has reviewed and approved ABC as an injectiot and dehalococcoides bacteria (B ACQ)
is on the DENR list of approved injectable compounds.
REGIONAL OFFICE COMMENTS: Shuving Wang and Sherri Knight of the Winston-Salem RO recommend issuance of this
permit.
MCDENR
Woriti Carollna Dez)artl en', at E-nvimnrnent and Natural Resoum-es
Be►,env 'Eave :,erduc-
GjDVMOI
DIv1s+0r1 o;1Nate - ;jualm.
i101?�'i' r �LJ�11�1�
�11f�ci�'
lanuary 2-5. 2010
Lee Aiken. Director of Manufacturinu Senices
Precision Fabrics Group. Inc.
P.O. Box 214448
Greensboro, NC 27420
Ref: Issuance of Injection Permit NV10400093
Precision Fabrics Group. Inc. Facility
301 Last Meadow',iew Road
Greensboro. Guilford County. NC 27406
Dear Mr. Aiken:
Der=-eemar
Secretary
In accordance with the application received on September 3. 2009. and the supporting data received December 15. 2009.
we are forwarding permit number W10400093. This permit is to iniect Anaerobic BioChem (ABC) and Dehalococcoides
bacteria f.DHQ to remediate groundwater contaminated with chlorinated solvents products at the facility referenced
above. This permit shall he effective from the date of issuance until December 31, 2011, and shall be subject to the
conditions and limitations stated therein. including the requirement to submit a final project evaluation as stated in PART
VII -]MONITORING AND REPORTING REQUIREMENTS. Please read the entire permit to ensure that you are aware
of all compliance requirements of the permit.
You will need to notify this office and the Winston-Salem Regional Office by telephone 48 hours prior to initiation of
operation of the facility. In order to continue uninterrupted legal use of the injection facility for the stated purpose, you
must submit an application to renew the permit 120 days prior to its expiration date. Please contact me at 919-71 5-6166
or Michael.rogerstdmcderingov if you have any questions about your permit.
Best Re,.zards_
Michael Rogers. P.G. (NC & FL)
EriNdronmental Specialist
Underground Injection Control Program
M Sherri Knight — Winston-Salem Regional Office
Kim Caulk — Superfund Section. DWM
Beau Hodge — ERM NC, Inc:,
W10400093 Permit File
t U "J 111a 11 .le Nil.-: -r1�,' Rakelp NCO 111 an]rlr 111= :NI I
Laemlror, 272E vapital Equievara. +mieiat, wr{1 ..aroerru ter;
pmrie 91 FLY. o;--7,IS-L66o F".-1';-::i14-� i,u;'rnm -- _ -
lnleTWL wwww.ngWatemualitv,orQ
[ lh_
Norr-th�tr�r��l1CarnIina
� �1
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
Precision Fabries Group, lnc.
FOR THE CONSTRUCTION AND OPERATION OF'_' TYPE 5I INJECTION WELLS. defined in
Title 15A North Carolina Administrative Code 2C .0209(e)(3)(C). to inject Anaerobic BioChem
(ABC) and Dehalococcoides bacteria (DHC), to stimulate reduction of chlorinated solvents in
groundwater. These injection wells/points will be located at the Precision Fabric Group. Inc.
F•acihty, 301 Nlleado,rvvlcw Road. Greensboro. Guilford County, NC 2740u, and will be operated in
accordance with the application received September 3. 2009, and in conformity with the
specifications and supporting data submitted December 15, 2[ 0i 1. and Januan 29. 2010. 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 December 31. 2011,
and shall be subject to the specified conditions and limitations set forth in Parts I through X hereof.
Permit issued this the 2 day of January 201 i 1.
oleen H. Sullins. Director
Division of Water Quality
By Authority of the Environmental Management Commission.
Permit No. W104000093 PAGE I OF 6
ver.1110 UIC-5I
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 (I5A 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.
a. 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
(Farm 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 (3 �ti 1 .,71-5000.
Permit No. WI04000093 PAGE 2 OF f
ver.1 / 10 LJIC-5I
PART III - OPERATIO-N AND USE GENER4L CONDITIOIla
1. This permit is effective only with respect to the nature, volume of materials, rate of injection.
and number of iniection 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 he submitted to the Director, including any supporting materials as ma} 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 anv and all statutes. rules. regulations. or ordinances ;hich 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
I . 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 Pertnittee 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-liIC. 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. WI04000093 PAGE 3 OF 6
ver.1 '1 U UIC-51
PART VI - INSPECTIOnv ,
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.
?. 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.
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 received January 29. 2010. 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.
3. The Perrnittee 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:
Aquifer Protection Section-UIC Staff
DENR-Division of Water Quality
1636 Mail Service Center
Raleigh, NC 27699-1636
and to:
Permit No. W104000093 PAGE 4 OF 6
Ver,1110 UIC-51
Aquirer Protection Section
DENR-DWQ Winsion-Salern Regional Office
' Vl atdt_T}itr►wn 4tl CL`i
W insion-Salemt. NC" 10
'361 771-30011
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 (33G1771-5000,
any of the follor�ring:
(A)Any occurrence at the injection facility which results in any unusual operating,
circumstances:
(g) 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 1 aA 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 13A 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
uroundwaters.
(S) The entire depth of each well shall be sounded before it is sealed to insure freedom
from obstructions that may interfere with sealing operations,
Permit No. WI04000093 PAGE 5 OF 6
ver.1 / 10 LTIC-51
(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 hentonite 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 hentonite 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 Ili (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 areas follo"A's:
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 reN iewed 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_
I 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. W104000093 PAGE 6 OF 6
ver. i , 10 UIC-5I