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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