WI0400198_Permit (Issuance)_20130517

DIVISION OF WATER QUALITY
AQUIFER PROTECTION SECTION
May 17, 2013
PERMIT ISSUANCE MEMO
TO: Debra Watts
THROUGH: Thomas Slusser
FROM: David Goodrich.
RE: Renewal of Permit to Inject Sodium Persulfate Sodium Hydroxide
Former Knollwood Gulf Service Station
I recommend that Permit Number W10400198 be renewed to the Atlantic Richfield Company 1
BP Products North America, Inc. to inject Klozur (Sodium Persulfate) and Sodium Hydroxide to
remediate soils and groundwater. Injections and groundwater monitoring are still in progress at
the facility under the terms and conditions of the existing permit which was issued on August 9,
2011. The renewed permit will be effective from August 1, 2013 to July 31, 2018.
The Winston-Salem Regional Office approves of this renewal, with the addition of single a post -
injection sampling of Monitoring Well MW-16 for Sodium Persulfate, pH, Sulfate, and Carbon
Dioxide. In accordance with the original monitoring schedule, quarterly monitoring is ongoing at
the facility as of this time, and a second injection event is planned for the very near future. To
date, only one of the three permitted injection events have taken place.
Groundwater monitoring is scheduled to take place on a quarterly schedule at wells MW-3, MW-
5R, MW-8R, MW-18, and MW-19 for pH, specific conductivity, oxidation-reduction potential,
temperature, BTEX, MTBE, sulfate, and carbon dioxide_ The renewed permit contains language
requiring the continuation of groundwater monitoring until certain concentrations are achieved.

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
Atlantic Richfield Company 1 BP Products North America, Inc.
FOR THE CONSTRUCTION AND/OR OPERATION OF 120 IN SITU
REMEDIATION/TRACER INJECTION WELLS, defined in Title 15A North Carolina
Administrative Code 2C .0209(5)(b)[viii), to inject sodium persulfate and sodium hydroxide, for
the oxidation of gasoline and diesel fuel. These injection wells/points will be located at the
former Knollwood Gulf Station (BP 24163), 381 Knollwood Street, Winston-Salem, Forsyth
County, North Carolina, and will be operated in accordance with the application submitted
March 27, 2013, and in conformity with the specifications and supporting data submitted
therewith, 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 effective date of its issuance until July
31, 2018, and shall be subject to the specified conditions and limitations set forth in Parts I
through X hereof.
Permit issued this the 24th day of May, 2013 and effective August 1, 2013.
or Charles Wakild, P.E_, Director
Division of Water Quality
By Authority of the Environmental Management Commission.
Permit No. WI0400198 PAGE I OF 7
per. January 2013 UIC-5I15T

PART I - WELL CONSTRUCTION GENERAL CONDITIONS
I. The Pennittee 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.
5. 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.
PART II - WELL CONSTRUCTION SPECIAL CONDITIONS
At leapt 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 919-807-6352 and the Winston-Salem Regional Office Aquifer
Protection Section Staff, telephone number [phone].
2. Bentonite grout shall not be used to seal any water -bearing zone with a chloride
concentration equal to or greater than 1,500 milligrams per liter. In areas where elevated
chloride levels are known to exist or are probable, such as coastal areas, chloride levels shall
be verified in the field to determine existing conditions.
Permit No. WI0400198 PAGE 2 OF 7
ver. January 2013 UIC-5I15T

PART III - OPERATION AND USE GENERAL CONDITIONS
I. 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 of the responsibility of complying
with any and all statutes, rules, regulations, or ordinances that may be imposed by other
local, state, and federal agencies having jurisdiction. Furthermore, the issuance of this permit
does not imply that all regulatory requirements have been met.
PART IV - PERFORMANCE STANDARDS
L 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.
2. 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.
3. 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.
4. 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.
N
PART V - OPERATION AND MAINTENANCE REQUIREMENTS
1. The injection facility shall be 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 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 919-807-6352. 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. W10400198 PAGE 3 OF 7
ver. January 2013 UIC-5115T

PART VI - INSPECTIONS
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
1- The proposed monitoring plan included in the application shall be followed. This will consist
of the quarterly sampling of wells MW-3, MW-5R, MW-8R, MW-18 and MW-19 for pH,
specific conductivity, oxidation-reduction potential, temperature, BTEX, MTBE, sulfate, and
carbon dioxide. In addition, well MW-16 will be sampled once after the next injection event
for sodium persulfate, pH, sulfate, and carbon dioxide. Any additional monitoring, including
groundwater, surface water, or soil sampling, deemed necessary by the Division of Water
Quality to ensure surface water and groundwater protection may be established and an
acceptable sampling reporting schedule shall be followed.
2. All sample results shall be submitted to the Aquifer Protection Section°s Winston-Salem
Regional Office and the Raleigh Central Office on a quarterly schedule. Monitoring reports
shall include, at a minimum, analytical data and an update on the status and location of
monitoring and injection wells. Well locations may be given in a table with the name and
geographic coordinates or shown on an updated version of the surveyor's base map_
3. Within 30 days of completion of well construction, a complete Well Construction Record
(Form GW-1) shall be submitted to the addresses specified to Part VH.6 below.
4. The Permittee shall submit an Injection Event Record within 30 days of completing each
injection.
S. The Permittee shall submit a final project evaluation within 9 months after completing all
injection -related activity, including post -injection monitoring, associated with this permit, or
produce an interim evaluation to be submitted with a renewal application for this permit.
Both the final project evaluation and interim evaluation shall contain historical monitoring
data and updated contaminant plume and potentiometric surface maps_ PLEASE NOTE:
Prior to closingthispermit, the Permittee must meet groundwater quality standards -or pre -
injection levels, whichever concentration is higher, for all of the injection constituents;
otherwise continued monitoring as approved in the monitoring -plan will be re uired until
such levels can be established.
Permit No. WI0400198 PAGE 4 OF 7
ver. January 2013 UIC-5I15T

6. AlI monitoring results, forms, and reports required in this Part shall be submitted to:
UIC Program Staff DWQ - Aquifer Protection Section
DWQ — Aquifer Protection Section and Winston-Salem Regional Office
1636 Mail Service Center 585 Waughton Street
Raleigh, NC 27699-1636 Winston-Salem, NC 27107
7. 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.
8. 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.
9. 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 V111- PERNUT 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 15A NCAC 2C .0240, 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 .0240, including but not limited to the following:
Permit No. W10400198 PAGE 5 OF 7
ver. January 2013 UIC-5I15T

(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 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
tilling 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 (Norm GW-30) as specified
in 15A NCAC 2C .0225(k) (1) (A) 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. Sodium hydroxide is highly corrosive and sodium persulfate is a strong oxidant. Some effects
reported to be associated with the products proposed to be used are as follows: eye, skin,
nose, throat, and lung irritation and/or corrosion. The amount of damage depends on the
length (duration) of contact Skin contact can produce inflammation and blistering
characterized by scaling, redness, itching, and occasionally, blistering. Eye contact may
produce inflammation characterized by redness, watering and itching and severe contact may
result in blindness or corneal damage. Inhalation may produce irritation to the respiratory and
GI tract and severe exposure may result in Iung damage, chocking, or death. Please see the
instructions in the MSDS sheet for these chemicals in regards to first aid treatment if
exposed, and the exposure controls and personal protection when using sodium hydroxide or
sodium persulfate. 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
Permit No. WI0400198 PAGE 6 OF 7
ver. January 2013 UIG-5I15T

■
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. The injection area in situated in an active parking lot near an active road, and traffic
safety precautions should be observed during any and all field activities. To minimize
exposure, access to the area of mixing and application should be limited to those required to
work with the chemical. All persons involved in the handling and use of sodium hydroxide
should be familiar with the MSDS information and the information in this section of the
permit (Part X— Worker Precautions During Application).
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. Sodium hydroxide should be stored and used only in well -ventilated
areas. Do not store it near heat, spark, or flame.
ti •
Permit No. WI0400198 PAGE 7 OF 7
►+er_ January 2013 UIC-5115T

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 97; Article 21. Chapter 143, and other
applicable Laws. Rules, and Regulations
PERMISSION IS HEREBY GRANTED TO
Atlantic Richfield Company 1 BP Products North America, Inc.
FOR THE CONSTRUCTION AND OPERATION OF 120 TYPE 51 INJECTION WELLS,
defined in Title 15A North Carolina Administrative Code 2C .0209(e)(3)(C), to inject sodium
persulfate and sodium hydroxide, for the oxidation of gasoline and diesel, These injection
wells/points will be located at the former Knollwood Gulf Station (BP 24163}, 381 Knollwood
Street, Winston-Salem, Forsyth County, North Carolina, and will be operated in accordance with
the application submitted July 6, 2011, and in conformity with the specifications and supporting
data submitted July 12, 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 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
.4100 and .0240. 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, 2013,
and shall be subject to the specified conditions and limitations set forth in Parts I through X
hereof.
Permit issued this the 9th day of August, 2011.
for Coleen H. Sullins, Director
Division of Water Quality
By Authority of Environmental Management Commission.
Permit No. W10400199 PAGE 3 OF
ver. June 2011 UIC-5115T

PART I - WELL CONS XTION GENERAL CONDITIONS
I. 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.
PART Il - WELL CONSTRUCTION SPECIAL CONDITIONS
1. 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 919-715-6162 and the Winston-Salem Regional Office Aquifer
Protection Section Staff, telephone number [phone].
?. Bentonite grout shall not be used to seal any water -bearing zone with a chloride
concentration equal to or greater than 1,500 milligrams per liter. In areas where elevated
chloride levels are Down to exist or are probable, such as coastal areas, chloride levels shall
be verified in the field to determine existing conditions.
Permit No. 'W10400198 PAGE 2 OF 7
per. June 2011 UIC-51.'51

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.
1 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 that may be imposed by other
local, state, and federal agencies having jurisdiction. Furthermore. the issuance of this permit
does not imply that all regulatory requirements have been met,
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,
2. 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.
3. 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.
4. 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.
2. 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 919-715-6162. 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, W10400198 PAGE 3 OF 7
Vet. June 2011 UIC-51'5T

PART VI - INSPECTIGiNb
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
1. 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
2, The proposed monitoring plan 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 ensure surface and
ground water protection, will be established and an acceptable sampling reporting schedule
shall be followed.
IThe Permittee shall produce a project luminary report that includes a final project evaluation
within 9 months of the completion of all injection and monitoringisampling activities.
documenting injection activities and groundwater sampling results. This document shall
assess the injection projects findings in a written summary. The final project evaluation
included therein shall also contain monitoring well sampling data, contaminant plume maps
and potentiometric surface maps.
4. The monitoring results and the project summary report shall be submitted to:
UIC Program Staff DWQ - Aquifer Protection Section
DWQ — Aquifer Protection Section and Winston-Salem Regional Office
1636 Mail Service Center 585 Waughton Street
Raleigh, NC 27699-1636 Winston-Salem, NC 27107
Permit No. WI0400198 PAGE 4 OF 7
per. June 2011 UIC-5I'5T

5. 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 m echani cal or el ectri cal failures.
6. Where the Pen, ittee 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 1rIH - 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 15A NCAC ?C .0214, 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 3C .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.
(D)Drilled wells shall 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.
Permit No. WI0400199 PAGE a OF"
ver. June 2012 UIC-5I15T

(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 Program
DENR-Division of Water Quality
1636 Mail Service Center
Raleigh, NC 27699-1636
PART X — WORKER PRECAUTIONS DURING APPLICATION
1. Sodium hydroxide is highly corrosive and sodium persulfate is a strong oxidant. Some effects
reported to be associated with the products proposed to be used are as follows: eye, skin,
nose, throat, and lung irritation and/or corrosion. The amount of damage depends on the
length (duration) of contact Skin contact can produce inflammation and blistering
characterized by scaling. redness, itching, and occasionally, blistering, Eye contact may
produce inflammation characterized by redness, watering and itching and severe contact may
result in blindness or corneal damage. Inhalation may produce irritation to the respiratory and
GI tract and severe exposure may result in lung damage, chocking. or death. Please see the
instructions in the MSDS sheet for these chemicals in regards to first aid treatment if
exposed, and the exposure controls and personal protection when using sodium hydroxide or
sodium persulfate. 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. The injection area in situated in an active parking lot near an active road, and traffic
safety precautions should be observed during any and all field activities. To minimize
exposure, access to the area of mixing and application should be limited to those required to
work with the chemical. All persons involved in the handling and use of sodium hydroxide
should be familiar with the MSDS information and the information in this section of the
permit (Part X — Worker Precautions During Application),
Pennii No. WI0400199 PAGE b OF 7
Ver. June ?OI 1 UIC-5115T

3. Eating, drinking, smoking. handling contact lenses, and applying cosmetics should never be
permitted in the application area during or immediately following application. After
handling, wash hands and face thoroughly with soap and water before eating, drinking. or
smoklna.
4. Safety controls should be to 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. Sodium hydroxide should be stored and used only in well -ventilated
areas. Do not store it near heat, spark, or flame.
Permit No. W10400199 PAGE + OF
ver. June 2011 UIC-51.'53

DIVISION OF WATER QUALITY
AQUIFER PROTECTION SECTION
August 8, 2011
PERMIT ISSUANCE MEMO
TO: Debra Watts
THROUGH: Thomas Slusser
FROM: David Goodrich
RE: Permit To Inject Sodium Persulfate and Sodium Hydroxide
Former Knollwood Gulf Service Station
I recommend that Permit Number WI0400198 be issued to the Atlantic Richfield CompanylBP Products North
America to inject Klozur (Sodium Persulfate) and Sodium Hydroxide to remediate soils and groundwater
contaminated with gasoline and diesel fuel.
SITE DESCRIPTION The site is paved and is currently used as a parking lot. It was formerly a retail fueling,
station/convenience store having underground storage tanks for gasoline, diesel, waste oil, and kerosene storage.
A subsurface release of gasoline took place before or during 1983 from a ruptured UST product line. Details
concerning the loss of diesel fuel were not reported. Previous site remediation efforts have included the removal
of approximately 500 tons of soil contaminated with petroleum hydrocarbons in December of 1990 upon the
closure and removal of the older USTs, as well as the extraction of 308 gallons of free product by a recovery
system in the mid to late 1980's. A new set of five USTs was installed in 1994 and remained active until they
were (all) removed in 2004.
HYDROGEOLOGIC DESCRIPTION The site is located in the Milton lithotectonic belt in the Piedmont
physiographic province. Reference sources state that bedrock is a strongly foliated biotite gneiss and schist,
however, none of the site borings (to a maximum depth of 55 feet) have been deep enough to encounter bedrock
or broken material that is usually found just above the bedrock. The overburden materials consist of soil
composed of silty/clayey sand, sandy clay/sill, and silt/clay overlying saprolite. The water table has been
encountered at depths ranging from 10 to 16 feet below the ground surface and the average hydraulic gradient is
approximately 0.012 (1 2%) towards the northwest. Using a hydraulic conductivity value of 0.13 feet per day
from slug tests and an effective porosity value of 20% results in an estimated groundwater flow rate of
approximately 2.8 feet per year.
EXTENT OF CONTAMINATION The extent of contamination (as evidenced by contaminated ground
water) appears to be approximately �20 feet long (Figure 4), approximately 200 feet wide, and 50 feet deep
(Figures SA &. 513). Assuming an effective porosity of 20%, this represents a total impacted ground water
volume of 440,000 cubic feet.
PROPOSED INJECTION The injectant is an oxidant and catalyst that will be injected into 40 injection
points per event (made by direct -push) in three separate injection events (120 points total) separated by ninety
days between each event. The total volume of injection fluid will be 30,000 gallons per event, resulting in a
grand total volume of 90,000 gallons (12,032 cubic feet). This injection volume represents less than 3% of the
volume of impacted ground water,
HOW IT WORKS The injectant works by oxidizing the hydrocarbon compounds. The initial injectant
substance, sodium persulfate ("Klozur") is a strong oxidant which will undergo alkaline activation by the
addition (mixing) of sodium hydroxide, which serves as a catalyst. This chemical combination will keep the pH
above a level of 10.5 standard units and facilitate the oxidation of the hydrocarbons by direct oxidation and by
the formation of free radicals that further support the oxidation process.

MONITORING The monitoring plan proposed in the application package will be followed. This plan
consists of installing two additional monitoring wells, and then sampling these wells prior to the initiation of
injection activities, along with two other wells, for the field parameters of pH, specific conductivity, oxidation-
reduction potential, temperature, and the laboratory parameters of total petroleum hydrocarbons gasoline range
organics and total petroleum hydrocarbons diesel range organics by SW-846 Method 8015. Approximately 90
days after the first injection event, sampling will be performed for the same set of field parameters and for the
laboratory parameters of BTEX and MTBE by EPA Method 6200B, for sulfate by EPA Method 300, and for
carbon dioxide by EPA Method 4500-COS. Sampling will be performed (repeated) quarterly thereafter, or 90
days after the next injection event (and quarterly thereafter) if the results of the first post -injection sampling
event indicate that a second injection event is needed.
EPIDEMIOLOGY On August 25, 2008 and on April 30, 2009. the DHHS' Epidemiology Branch provided
comments on sodium persulfate and on sodium hydroxide, respectively, for groundwater remediation. Dr.
Kenneth Ruda did not present any information that would preclude the use of these products for injection but
did provide a health risk analysis and worker safety precautions, which are in Part X of the attached permit.
REGIONAL OFFICE COMMENTS Shuying Wang of the Winston-Salem Regional Office recommend issuance
of this permit. The injection area is situated in an active parking area near a busy street and the Regional Office
is recommending the addressing of safety issues at the time of the injection activities. The Regional Office is
also recommending a permit condition requiring the submission of a project summary report which includes a
final project evaluation within 9 months of completing the injection and monitoring/sampling activities.

1 Assigged Date: 3 � "i 6
Reviewer: bb-o"c' Existing ermit No.: �,tr7�L "�t� $ Date to Processing: N2
Owner: EI Existing Owner Type: on -Government io ❑ Individual Organization
❑ Unknown ❑ Government 0 ❑ Municipal ❑ Federal ❑ County ❑ State
Facility: WE)dsting
roposed Facility Type: El Facility
❑ Operation
Permit Tvpe: Deemed
❑ Aquifer Test Wells
❑ Geothermal Aqueous Closed Loop Welts
❑ Geothermal Direct Expansion Closed Loop Wells
❑ In Situ Groundwater Remediation Wells circle one
{ air sparge, passive, small scale, pilot test }
❑ Stormwater Drainage Wells
❑ Tracer Wells
❑ Other Wells
Facility Reeulated Activities:
Individual
❑ Aquifer Storage and Recovery Wells
❑ Geothermal Heating & Cooling Water Return Wells
VIn ,Situ Groundwater Remediation Wells
❑ Experimental Technology Wells
❑
Tracer Wells
❑
Aquifer Recharge Wells
❑
Subsidence Control Wells
❑
Salinity Barrier Wells
Aplicatinn Type: ❑ New ❑ Major Modification ❑ Minor Modification ❑ Name Change
❑ Ownership Change ff Renewal ❑ Renewal wl Modification ❑ Rescission
Notes: -S:� J��•
UIC RIMS Entry Form Jan. 24, 2013

Application Reviewer:
Pre -Review: Conducted? _ Yes ❑ No
O.K. to Process? @I Yes ❑ No
If No, What Action Is Needed? ❑ Pre -Review Return
❑ Hold, Pendine Receipt of Addinfo.:
Name/Affiliation of Person Contacted:
Date(s) of Contact: ❑ By Phone ❑ By E-Mail ❑ By Letter
Owner: ❑ Existing S Unknown Owner T}pe m Non -Gov't (❑ Ind. or ® Org) ❑ Gov. -Municipal
❑ Goy': County ❑ Goy. -State ❑ Gov. -Federal
Facilim/Oyeration: ❑ Proposed ❑ Existing
Regulated Activities:
,Application/Permit:
Perm it 7: pe:
❑ Injection Water Only GSHP Well System (5QW)
❑ Injection Mixed Fluid GSHP Well System (5QM )
❑ Injection Tracer Well (5T)
❑ Injection Experimental Technology (51?5)
Project Type: [% New ❑ Major Mod.
Notes-
❑ Facilih, ❑ Operation
® Injection In situ Groundwater Remediation Well (51)
❑ Injection Heating/Cooling Water Return Well (5A7)
❑ Injection Other Wells (5Z)
❑ Injection Aquifer Recharge (5R211
❑ Minor Mod. ❑ Renewal ❑ Renewal wl Mod.
FORM: BIMS 10/04/2007

Rogers, Michael
From: Rogers, Michael
Sent: Wednesday, September 30, 2015 4:20 PM
To: ',ZiMa, Jasen' �
Subject: rM-'11 10400198`AR00/BP
I agree with your recommendation. Continue monitoring the referenced wells until at least 2 events show sulfate at
pre -injection levels or meets 2L standards.
Regards,
From: Zinna, Jasen [mailto:[e-mail])
Sent: Tuesday, September 29, 2015 7:57 AM
To: Rogers, Michael <[e-mail]>
Subject: RE: W10400198 ARCO/BP
Michael,
never received a response for the attached report for the last sampling event. We will be collecting groundwater
samples again in October and wanted to confirm that you are in agreement to only collect samples for sulfate analysis
from 4 wells (513, 8R, 18, and 19) since those are the only exceedances at the site. Please see section 3.2 of the report for
my recommendations
Jasen Zinna. P,E.
Senior Engineer
D- 1-919-461-1285 C 1-561-271-9662
Jasen ZinnaCcDaecom,com
AECaM
1600 Perimeter Park Dr. 400. Morrisville. North Carolina 27560
T 1-919-461-1100 F 1-919-461-1415
www. aecom.com
From: Rogers, Michael[mailto:michael.ronersncdenr.qav]
Sent: Tuesday, February 03, 2015 4:24 PM
To: Zinna, Jasen
Cc: Frisch, Greg (Ehs Support)
Subject: W10400198 ARC0/8P
Greetings -
We received the report titled Final Status Report, Former Knollwood Gbif Station (BP #24163), 381 Knollwood Street,
Winston-Salem, North Carolino (dated December 15, 2014). In the Conclusions and Recommendations Section, sulfate
concentrations resulting from injection activities in MW-5R, MW-8R, MW-18, and MW-19 are still above the 15A NCAC
2L standard of 250 mg1L. One of the recommendations is to continue to collect samples from these welts until the
water quality meets the 2L standards. We concur with this recommendation and request these welts be monitored until
sulfate meets the 2L standard for 2 consecutive semiannual monitoring events- At that point, the Division will consider
closing the permit and issuing a Permit Completion Letter_
If you have any questions or comments, please advise. Thank you for your cooperation.
Michael Rogers, P.G. (NC & FL)
Hydrogeologist
NCDENR - DWR

Water quality Regional Operations Section
1636 Mail Service Center
Raleigh, NC 27699
Direct No. 919-907-6406
�►�:lJD-Qrta1.ncdenr.org/web/wq/aps/gwpro/reportinp,-forms
NOTE: Per Execrative Order No. 150, all a -marls sent to and from this account are subject to the North Carohno Public
Records Cow and may be disclosed to third parties.

June 24, 2015
Mr. Charles Sherren
Thruway Shopping Center, LLC.
7501 Wisconsin Avenue, Suite 1500
Bethesda, Maryland, 20814
RE: Semi -Annual Report
Former Knollwood Gulf Station (BP 24163)
381 Knollwood Street
Winston-Salem, Forsyth County, North Carolina
Injection Permit W10400198
NCDENR Incident No. 6400
URS Project number: 60426590
Dear Mr. Sherren:
Please find enclosed a CD containing an electronic copy of the Semi -Annual Report for
the above referenced site. A CD has been sent based on your previous request for an
electronic copy of reports for the site_ Should you want a paper copy as well, or should
you have any questions regarding this submittal, please do not hesitate to contact the
undersigned at [phone] or Jasen.Zinnaoaecom.com.
Sincerely,
URS Corporation — North Carolina
Jasen Zinna, PH
Project Manager
Enclosure
URS Corporation — North Carolina
1600 perimeter Park Drive, Suite 400
Morrisville, NC 27560
Tel' 919-461-1100
Fax' 919-461-1415