WI0400098_Permit (Modification)_20151209

1 ,DIVISION OF WATER RESOURCir o
Water Quality Regional Operations Section
December 9. 2015
MEMORANDUM
TO: Debra Watts
FROM: Michael Roger
RE: Permit Renewal and Name Change for Permit ##WI0400098
Former Flakt Products Site
I recommend that Permit Number WI0400098 be re -issued to the above appiicant to inject hydrogen peroxide and associated
supplemental agents ferrous sulfate and phosphoric and/or sulfuric acid to remediate groundwater (GW) contaminated with
VOCs_ This permit was issued on April 26. 201 1. and expires on March 31, 2016. Following the review of the performance
monitoring data collected after the injection events. the Pennittee has requested the permit be r to ude a possible
future injection into 6 existing wells. The previous permit allowed for the injection o 429.480 allons. To date, the
Perm ittee has only injected 270A31 gallons. Previous injections have resulted in decrease ofCOCs and the Perm ittee wants
to renew the permit and continue to monitor groundwater quality. with an option to conduct an additional injection if needed.
Since the permit for tins injection activity has previously been approved, and information contained therein is essentially
the same. I am attaching this modified memo reflecting those proposed changes from the previous permit. Please refer to
the previous permit issuance memorandum for more information on this site including injection info.
REGIONAL OFFICE COM M FN'rs: Each of the RO comments/recommendations are discussed beloNk (RO's
comments/recommendations are underlined).
The W-SRO recommends permit renewal.

NORTH CAROLINA
ENVIRONMENTAL MANAGEMENT COMMISSION
DEPARTMENT OF ENVIRONMENTAL QUALITY
RALEIGH, NORTH CAROLINA
PERMIT FOR THE USE 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
ASS, Inc.
FOR THE OPERATION OF SIX (6) IN SITU REMEDIATION INJECTION WELLS, defined in
Title 15A North Carolina Administrative Code 02C .0209(5){b)(viii), to inject hydrogen peroxide,
ferrous sulfate, and phosphoric and sulfuric acid for the remediation of groundwater contaminated
with volatile organic compounds (VOCs). These injection wells/points will be located at the
Former Flakt Products Site, 2000 Lowery Street. Winston-Salem, Forsyth County, NC 2 710 1. and
will be operated in accordance with the application and Permit Name Change request submitted
October 5, 2015, and in conformity with the specifications and supporting data submitted October
6, 2015, all of which are filed with the Department of Environmental Quality and are considered
a part of this permit.
This permit is for 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 02C .0100 and .0200, and any
other Laws, Rules, and Regulations pertaining to well construction and use.
This permit shall be effective, unless revoked. from April 1, 2016 (i.e., the day after the expiration
date of the existing permit). until March 31, 2021, and shall be subject to the specified conditions
and limitations set forth in this permit.
Permit issued this the k` day of January 2016.
S. Jay Zimmerman, Director
Division of Water Resources
By Authority of the Environmental Management Commission.
Permit No. W10400098 PAGE 1 OF 7
ver. 1/15/2015 MC-51 5T

PART I — PERMIT GENERAL CONDITIONS
1. The Permittee shall 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).
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 [ 15A
NCAC 02C .0211(t)].
3. This permit is valid only for construction or operation 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 Division of Water Resources (DWR) [ 15A NCAC
.0211(a)].
4. This permit is not transferable without prior notice and approval. 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 and any supporting materials must be submitted at least 30 days prior to
the date of the change [ 15A NCAC 02C .0211(q)].
5. 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 [15A NCAC 02C .0203].
PART II - WELL CONSTRUCTION GENERAL CONDITIONS
Each injection well shall not hydraulically connect separate aquifers [15A NCAC 02C
.0211(c)].
2. Multi -screened wells shall not hydraulically connect different aquifers or zones having
differences in water quality that would result in a degradation of any aquifer or zone [15A
NCAC 02C .0225(g)(17)].
3. Each injection we]1 shall be constructed in such a manner that water from land surface cannot
migrate into the gravel pack or well screen [ 15A NCAC 02C .0225(g)(4)].
4. Bentonite grout shall not be used to seal any water -bearing zone with a chloride concentration
equal to or greater than 17500 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. [I5A NCAC .0225(g)(8)].
5. Each injection well shall be secured to reasonably insure against unauthorized access and use.
Each well shall be pennanently labeled with a warning that it is for injection purposes and the
entrance to each well shall be secured with a locking cap as defined in G.S. 87-85(15) [15A
NCAC 02C .0275(g)(23)].
Permit No. W1040 y098 PAGE 2 OF 7
ver. 11 ] 5/2015 U iC-51 /5 T

6. Each injection well shall be afforded reasonable protection against damage during construction
and use 115A NCAC 02C .0225(i)(3)].
7. Each permanent injection well shall have a permanently affixed identification plate [15A
NCAC .0225(g)(20)].
8. A completed Well Construction Record (Form GWA) shall be submitted as described in Part
VI.6 of this permit.
PART III - WELL CONSTRUCTION SPECIAL CONDITIONS
I. At least forty-eight (48) hours prior to constructing or operating each injection well, the
Perraittee shall notify the Underground Injection Control (UIC) Central Office staff_ telephone
number 919-807-6406, and the Winston-Salem Regional Office staff, telephone number 336-
776-9800 [15A NCAC 02C .0211(k)].
] . The Permittee shall be required to comply with the terns and conditions of this permit even
if compliance requires a reduction or elimination of the permitted activity [15A NCAC 02C
.02110)].
2. The issuance of this permit shall not relieve the Permittee of the responsibility for damages
to surface water or groundwater resulting from the operation of this facility [I5A NCAC 02C
.02061.
3, The injection facility shall be properly maintained and operated at all times to achieve
compliance with the conditions of this permit and the rules of 15A NCAC 02C .0200, even
if compliance requires a reduction or elimination of the permitted activity [ I5A NCAC 02C
.02116)].
4. 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 that may be required, such as the repair,
modif cation. or abandonment of the injection facility 115A NCAC 02C .0206].
Permit No. W10400098 FIAGL I OF 7
►+er. 111512015 U1C-51/5T

PART V -INSPECTIONS [ 15A NCAC 02C .0211(k)]
1. Any duly authorized officer, employee, or representative of the Division of Water Resources
(DWR) 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. DWR 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 VI - MONITORING AND REPORTING REQUIREMENTS
The proposed monitoring plan included in the application shall be followed_ Any additional
monitoring, including groundwater, surface water, or soil sampling, deemed necessary to
ensure surface water and groundwater protection may be established and an acceptable
sampling reporting schedule shall be followed [15A NCAC 02C-02250)].
2. All sample results shall be submitted to the WQROS Central Office and Winston-Salem
Regional Office. 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 site
map [15A NCAC 02C .0225(k)(2)].
3. Records of well construction, repair, ar abandonment shall be submitted within 30 days of
completion of such activities [15A NCAC 02C .0225(k)(1)(A)].
4. An Injection Event Record shall be submitted within 30 days of each injection event [15A
NCAC 02C .0225(k)(1)(B)].
5. The Permittee shall submit a Final Project Evaluation (FPE) within 9 months after completing
all injection -related activity 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
potentiornetric surface maps. PLEASE NOTE: _IJectants and related reaction byproducts must
attenuate to pre -injection concentrations or groundwater standards specified in rule 15A NCAC
02C .0?02, whichever is greater, in order for this permit to be closed. Otherwise, corrective
action as described Part V I I shall be required [15A NCAC 02C .0225(k)(2)].
6. All monitoring results, forms, and reports required in this Part shall be submitted to:
UIC Program Water Quality Regional Operations Section
NC Division of Water Resources and DWR Winston-Salem Regional Office
1636 Mail Service Center 450 West Hanes Mill Road
Raleigh. NC 27699-1636 Winston-Salem, NC 27105
Pen -nit No_ W10400098 PACE 4 OF 7
ver_ U1512015 UIC-51�5T

7. The Permittee shall report any monitoring or other information that indicates noncompliance
with a specific permit condition, that a contaminant may cause a violation of applicable
groundwater quality standards, or that a malfunction of the injection system may cause the
injected fluids to migrate outside the approved injection zone or area. As specified in rule
15A NCAC 02C .0211(r), noncompliance notification shall be as follows:
(A) Oral notification shall be given within 24 }tours of the occurrence, or first knowledge
of the occurrence, to the Winston-Salem Regional Office, telephone number 336-
776-9800.
(B) Written notification shall be made within five days of the occurrence and submitted
to the addresses in Item 96 above-
(C) The written notification shall contain a description of the noncompliance and its
cause; the period of noncompliance, including dates and times; if the noncompliance
has not been corrected, the anticipated time it is expected to continue; and any steps
taken or planned to reduce, eliminate, and prevent reoccurrence of the
noncompliance.
8. Where the Pertnittee 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 [ 15A NCAC 02C .0211(b)].
PART VI1- CORRECTIVE ACTION [I 5A NCAC 02C .02061
Any injection well not constructed or operated in accordance with this permit, or the criteria
and standards specified in 15A NCAC 02C .0200, shall be subject to corrective action as
provided under rule 15A NCAC 02C .0206.
2, The following corrective actions shall apply to elevated concentrations of injectants or reaction
byproducts resulting from the permitted injection activity:
(A) Continued monitoring until concentrations return to pre -injection values or meet the
standards specified in 15A NCAC 02L .0202. whichever are greater. The frequency,
duration, and location of monitoring shall be appropriate for site specific conditions and
potential receptors.
(B) Groundwater quality parameters that do not attenuate as described in 2(A) above may
warrant a corrective action plan as provided under rule 15A NCAC 02C .0206, depending
on the type, concentration, and distribution of the groundwater quality standards being
exceeded.
PART VI11 - PERMIT RENEWAL [I NCAC 02C .0211(b)]
In order to continue uninterrupted legal use of the injection facility for the stated purpose, the
Permittee should submit an application to renew the permit 120 days prior to its expiration date.
Permit No. W10400098 PAGE 5 OF 7
ver. Id 5/2015 U 1 C-S i15 T

PART IX - CHANGE 4F WELL STATUS [I 5A NCAC 02C .02401
1. The Permittee shall provide written notification within I5 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 roust 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:
(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.
(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.
(C) The well shall be thoroughly disinfected, prior to sealing, if WQROS staff determines
that failure to do so could lead to the contamination of an underground source of
drinking water.
(D) Dril led 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
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 _0225(k)(1)(A) within 30 days of completion of abandonment.
3_ The written documentation required in fart IX (1) and (2) (G) shall be submitted to:
UIC Program
DENR-Division of Water Resources
1636 Mail Service Center
Raleigh, NC 27699-1636
Permit No. W10400098 PAGE 6 GF 7
ver_ 1/15/2015 l][C-5115T

PART X —WORKER PRECAUTIONS DURING APPLICATION [15A NCAC 02C
.0211(b)]
1. 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.
3. Eating.. drinking, smoking, handling contact lenses, and applying cosmetics should not be
permitted in the application area during or immediately following application.
4. Safety controls should be in place to ensure that the check valve and the pressure delivery
systems are working properly.
5. The Material Safety Data Sheets should be followed to prevent incompatible or adverse
reactions and injuries -
Permit No. V'1041) 008 PAGE 7 OF 7
per. V 15/2015 UIC-5I15T

DIVISION OF WATER QUALITY
AQUIFER PROTECTION SECTION
April 5, 2011
PERMIT ISSUANCE MEMO
TO: Debra Watts
THROUGH: Thomas Slusser
FROM: John McCraI
RE: Permit To Inject Catalyzed Fydrogen Peroxide i Fenton's Reagent)
Former Flakt Products. Inc, Site
I recommend that Permit Number WI0400099 be issued to Former Flaki Products. Inc. Site to inject Catalyzed
Hydrogen Peroxide (1'entun's Reagent) to remediate groundwater contaminated with chlorinated solvents. This
permit is a renewal with modification based on results from a pilot study conducted under the original issuance of
W10400098.
SITE DESCRIPTION The Flakt Products Inc. site formerly housed metal fabrication operations_ and has been
vacant. with the exception of a cardboard recycling facility in the northeast portion of the building, since 1985.
Chlorinated solvent contamination were the results of releases from above and below ground storage tanks and metal
degreasing pits. Remedial activities previously conducted consisted of in -situ volitization of contaminamsunderlying.
the degreasing pits. recovery well operation. and the prey ious pilot study conducted under the original permit
W 10400098.
HYDROGEOLOGIC DESCRIPTION The site is located in the Piedmont Physioggaphic Province and is underlain
by bedrock ofthe Milton Belt. The site is underlain fly up to 20 feet of artificial fill overlying- residual silty and clayey
sand that extends to a depth of as much as 100 feet below ground surface (bgs) in the vicinity- of MW-1?0D.
Weathered bedrock underlies residual soils. extending to depths rangin<u het wee❑ 70 ft bgs under the ea stem portion
of the facility to 110 fl bgs under the western portion of the facility. and is underlain by competent bedrock. Within
the confines of the site, the depth to groundwater ranges from 28 feet bgs to 77 feet bus. sloping to the south across
the site and flows toward the southeast under a variable hydraulic piadient steepening in the vicinity of the recovery
wells (Fig. 3). The aquifer has an estimated Specific Yield (available water of the aquifer) of 0.03 to 0.35 with a
hydraulic conductivity of 5.1 to 7.8 feet per day (based on site specific slug tests W10400099 application, 2009)
al}etwing the water to flow at an estimated rate: of'0.8 feet per day.
EXTENT OF CONTAMINATION Figure 4 shows the lateral extent of contamination and the extent of the
injection area in the vicinity of Ilie former UST. Depth of contamination bused on the deepest recovery well screen
interval is 115 feet. The areal extent of the plume covers an area ol'approximately 1-7,000 sq, it. and has probably
been spread by an extensive network of structural fractures within the sfaprobte and bedrock which can sme as v
source of residual contamination in groundwater over time.
PROPOSED INJECTION The Applicant proposes to inject a total of 429.480 gallons of catalyzed hydrogen
peroxide solution into the underlying aquifer through eighty (80) permanent injection wells at low (10-40 psi)
pressure over a series of three injection events. The total volume of the injectants is —33% of the estimated
percentage of pore volume occupied by the contaminant plume volume, or —11 % of the contaminant plume volume
per event.

HOW IT WORKS The remedial process of catalyzed hydrogen peroxide is by short acting, strong in -situ
oxidation that directly destroys organic compounds such as the site contaminants. Hydrogen peroxide is catalyzed by
ferrous iron sulfate, which boosts the oxidant strength via generation of sulfate free radicals, which also are strong,
short-lived oxidizing agents. Acid added into the solution (part of the Geo-Cleanse product) is a stabilizer for the
ferrous sulfate and provides an optimum pH for the oxidizing reactions.
MONITORING Subsequent groundwater monitoring will be conducted according to the plan set forth in the
renewal application and will also include sampling from RW-b and RW-14. The plan set forth in Section D. 4.0 of
the renewal application consists of a baseline event, daily events, and a 30-day post injection sampling event and will
measure parameters as established in Section F. 4.0.
EPIDEMIOLOGY On iun� 2i. ?fl(l . the DHHS' Epidemiology Branch provided comments on Ferltvfi
Reagent for groundwater remediation. Dr. Luanne W [I] iams 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 Shuyinu'Wang of the Winston-Salem Regional Office recommends issuance of
this permit with consideration of further information.

NORTH CAROLINA
ENVIRONMENTAL MANAGEMENT CONORS91ON
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
R&LEIGH, 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
M � �1:i ►t ��� ti] ► i 1:�. ��7 :I3`i�.7:��Tt �1-�71 lli7
Flakt Products, Inc.
FOR THE OPERATION OF 80 TYPE 5I INJECTION WELLS, defined in Title 15ANorth Carolina
Administrative Code 2C .0209(e)(3)(C), to inject catalyzed hydrogen peroxide (Fenton's Reagent),
for the in -situ chemical oxidation of chlorinated solvents, These injection wells will be located at the
Former Flakt Products Site, 200 Lowery Street, Winston-Salem, Forsyth County, North Carolina,
and will be operated in accordance with the permit modification submitted October 21, 2010 and
additional information submitted January 31, 2011, and in conformity with the specifications and
supporting data submitted, all of which are filed with the Department of Environment and Natural
Resources and are considered a part of this permit.
This permit is for Construction and Operation only, and -does not waive any provisions of the Water
Use Actor any other applicable Laws, Rules, or Regulations. Operation and use of an injection wa
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 ofits issuance until March 31, 2015, and
shall be subject to the specified conditions and limitations set forth in Parts I through X hereof,
Permit issued this the z day of %} PIZTI— , 2011.
C leo en H. Sullins, Director
Division of Water Quality
By Authority of the Enviromr►ental Management Commission.
Permit No. W1040008 PAGE 1 OF, 6
ver.8107 APMIC-6

PART 1- 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 (l5A 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.
1 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,
S. 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 he 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 shad 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 11- WELL CONSTRUCTION SPECIAL CONDITIONS
At least forty-eight (48) hours prior to constructing each injection well, the Permitter shall notify the
Aquifer Protection Section -Underground Injection Control (UIC) Central Office staff', telephone
number [phone] and the Winston-Salem Regional Office Aquifer Protection Section Staff,
telephone uutuber [phone].
Permit W W10400i luR PAGE 2 OF 6
Ver.8107 - APILIIC-6

PART III - OPERATION AND USE GENERAL CONDITIONS
1. This permit is effective only with respect to the nature, volume of materials, rate ofinjection, 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 Permitted, a formal permit amendment request must
be submitted to the Director, including any supporting materials as may be appropriate, at least
30 days prior to the date of the change.
3. The issuance of this permit shall not relieve the Permittee of the responsibility of complying with
any and all statutes, rules, regulations, or ordinances which maybe unposed by other local, state,
and federal agencies which have jurisdiction. Furthermore, the issuance of this permit does not
imply that all regulatory requirements have been met.
PART IV - PERFORMANCE STANDARDS
The injection facility shall be effectively maintained and operated at all 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 inj ection zone to adequately assimilate the injected fluid, the Peru ittee shall take
immediate corrective actions including those actions that may be required by the Diyision of
Water Quality such as the repair, modification, or abandonment of the injection facility.
2. The. Permittee shall be required to comply with the term 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 - OPERATIO'NAND MAINTENANCE REQUIREMENTS
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 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,
thePermittee must notify by telephone the Aquifer Protection Section-UIC, Central Office staff,
telephone number [phone]. Notification is required so that Division staff can inspect or
otherwise review the injection facility and determine if it is in compliance with permit
conditions.
Permit No, W1040 08 PAGE 3 OF 5
ver.8107 ANUIC-6

PART VI - INSPECTIONS
Any duly authorized officer, employee, or representative of the Division of Water Quality may,
upon presentation of credentials, enter and inspect any property, premises, or place on or related
to the injection facility at any reasonable time for the purpose of determining compliance with
this permit, may inspect or copy any records that must be maintained under the terms and
conditions of this permit, and may obtain samples of groundwater, surface water, or injection
fluids.
2. Department representatives shall have reasonable access for purposes ofinspection, 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 but shall also include
samples to be taken from RWs 6 and 14 during the baseline and performance sampling event at
30 days post -injection to be analyzed for VOCs. All sample results shall be submitted to the
Aquifer Protection Section's Winston-Salem Regional Office and the Raleigh Central Office.
Anymonitoring (including groundwater, surface water, or soil sampling) deemed necessary by
the Division of Water Quality to insure surface and ground water protection, will be establisher)
and an acceptable sampling reporting schedule shall be followed.
r 2. The Permittee shall summit an Injection Event Record within 30 days of completing each
injection.
3. The Peamittee 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 potentiometrie surface maps.
4. The monitoring results and the final project evaluation shall be submitted to:
and to:
Aquifer Protection Section-UIC Stan'
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
Wiuston-Salem, NC 27107-2241
4.- .
Pcimit No. W10400099 PAGE 4 OF 6
ver.$I07 APIMC-6

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 [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.
6. 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,
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 - PERXHT 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 III - 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. Ifa l
well is not to be used for any purpose that well trust be permanently abandoned according to � •
15A 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
15A NCAC 2C A113(b), including but not limited to the following:
(A)A11 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 chinking
water.
Permit No. W104C41r31)y PAGE 5 OF 6
ver.8i07 APMIC-6

(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 filling
it fiom 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 manger 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.
(Q) The Permittee shall submit a Well Abandonment Record (Form GW-30) as specified in
I5A 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
❑ENR-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, lungs and gastrointestinal irritation or burns. 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 inixing), then proper personal protective equipment
should be used. The application process should be reviewed by an industrial hygienist to ensure
that the most appropriate personal protective equipment is used.
2, Persons working with these products should wear goggles or a face shield, gloves, and protective
clothing. Face and body protection should be used for anticipated splashes or sprays.
3. Eating, drinking, smoking, handling contact lenses, and applying cosmetics should not be
permitted in the application area during or immediately following application.
4, Site access should be limited to worker's involved in the injection of the solution. Safety
controls should be in place to ensure that thecheck 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, WI040009S PAGE 6 OF 6
ver.8147 APU C-6

NORTH CAROLINA
ENVIRONMENTAL MANAGEMENT COMMISSION
DEPARTMENT OF ENVIRONMENT AND NATURAL RTRCES
RALEIGH, NORTH CAROLINA
PERMIT FOR THE CONSTRUCTION AND OPERATION O/AELL FOR INJECTION
In accordance ith the provisions of Article 7_ Chapter 87. Art Chapter 141- and other
applicable Laws, Rules, and Regulat
PERMISSION IS HEREBY
Flakt Products, Inc
rs
1-10 � It
ro If.(,
h -4 rn , 1 r,. r ;&/
FOR THE OPERATION\of
PE 51 INJECTION LLS. defined in Title 1 5AiiNorth Carolina
Administrative Code 2C .3)(C), to inject catal ed hydrogen peroxide (Fenton's Reagent).
for the in -situ chemical ofchlorinated svly ts. These injection wells will be located at the
Former Flakt Products Siowery Street, W' ston-Salem. Forsyth County, North Carolina,
and will be operated in aa with the perrdt modification submitted October 21, 21010 and
additional information suuary 31, 20I 1, and in conformity with the specifications and
supporting data submitte'ch are file with the Department of Environment and Natural
Resources and are considrt this permit.
TO
This permit is for Construction and OpR Lion only, and does not waive any provisions of the Water
Use Act or any other applicable Laws, s, or Regulations. Operation and use of an injection well
shall be in compliance with Title 15A Nort Carolina Administrative Code 2C .0100 and .0200, and
any other Laws, Rules, and Regulations pert fining to well construction and use.
This permit shall be effective. unless revoked. m the date of its issuance until March 31. 2013, and
shall be subject to the specified conditions and 0pitations set forth in Parts I through X hereof.
Permit issued this theE21*y of
..I
Coleen H. S fins. Director
Division of W�ter Quality
1 -
By Authority of e Environmental Management Co
1
R p-� L- .-Mil.
fission.
Permit No. W IO-4' 1 11 ti PAGE 1 OF 6
ver-9/07 AP UIC-6

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,aith 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
inigrate 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 G W-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 H - WELL CONSTRUCTION SPECIAL CONDITIONS
At least forty-eight (48) hours prior to constructing each injection well, the Pennittee shall notify the
Aquifer Protection Section -Underground Injection Control (U1C) Central Office staff, telephone
number [phone] and the Winston-Salem Regional Office Aquifer Protection Section Staff.
telephone number [phone].
Permit No. W10-1. } , PAGE 2 OF h
ver,8107 AP 21I C-6

PART III - OPERATION AND USE GENERAL CONDITIONS
1. This permit is effective only with respect to the nature, volume ofmaterials, rate of injection. and
number of injection wells as described in the application and other supporting data.
?. This permit is not transferable without prior notice to, and approval by. the Director of the
Division of Water Quality (Director), In the event there is a desire for the facility to change
ownership, orthere is a name change ofthe 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.
The issuance of this permit shall not relieve the Permittee of the responsibility of complying with
any and all statutes, rules, regulations. or ordinances which 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
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 Pen, ittee 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.
2. 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 fom--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 star:
telephone number (919) 71-6168. Notification is required so that Division staff can inspect or
otherwise review the infection facility and determine if it is in compliance with permit
conditions.
Permit No. V►10- PAGE 3 GE 6
N-er,K 07 AP IC 6

PART VI - INSPECTIUIvs
I . 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 ofinWection. observation.
and sampling ass,)ciated 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 but shall also include
samples to be taken from RWs 6 and 14. 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,
2. The Permittee shall submit an Injection Event Record within 30 days of completing each
injection.
3. The Pennittee 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 potendometric surface maps.
4. The monitoring results and the final project evaluation shall be submitted to:
and to:
Aquifer Protection Section-UIC Staff
DENR-Division of Water Quality
1636 Mail Service Center
Raleigh. NC ?7699-1636
Aquifer Protection Section
DENR-DWQ Winston-Salem Regional Office
585 Waughtown Street
Winston-Salem. NC 27107-2241
Permit No. WI01 PAGE 4 OF 6
ver.8/07 AP'UI C-6 -

5. The Perminee 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 , 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.
' 6. 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.
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 V111 - 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
I . 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 .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
15A NCAC 2C .0113(b). including but not limited to the following:
(A)AII 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 he sounded before it is sealed to insure freedom from
obstructions that may interfere with sealing operations.
(C) The well shall be thoroughly disinfected. prior to sealing. if the Director determines that
failure to do so could lead to the contamination of an underground source of drinking
water.
Permit No. W10- PAGE _5 OF n
ver.K Il� - APOITIC-h

(D)Drilled wells shall be completely filled with cement grout, or bentonite gout 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, orbentonite 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 IX (1) and (?) (G) shall be submitted to:
Aquifer Protection Section-UIC Staff
DENR-DiNision 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, lungs and gastrointestinal irritation or bums. If the product is released into the
environment in a way that could result in a suspension of fine solid or liquid particles (e.g.,
grinding, blending,, vigorous shaking or mixing), then proper personal protective equipment
should be used. The application process should be reviewed by an industrial hygienist to ensure
that the most appropriate personal protective equipment is used.
2. Persons working with these products should wear goggles or a face shield, gloves, and protective
clothing. Face and body protection should be used for anticipated splashes or sprays.
3. Eating, drinking, smoking. handling contact lenses, and applying cosmetics should not be
permitted in the application area during or immediately following application.
4. Site access should be limited to worker's involved in the injection of the solution. 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. WI9- PAGE 6 OF 6
ver.8147 APUIC-6 -

DIVISION OF WATER QUALITY
AQUIFER PROTECTION SECTION
March 27, 2009
MEMORANDUM
TO: Debra Watts ,
FROM: Thomas Slusser 7. 7S
RE: Permit To Inject Catalyzed Hydrogen Peroxide (Fenton's Reagent)
Former Flakt Products, Inc. Facility
I recommend that Permit Number WI0400098 be issued to Flakt Products, Inc. for the use of Fenton's chemistry to remediate
ground water contaminated with chlorinated solvents. This permit is for a pilot test of an injection project intended to
supplement groundwater remediation activities operating under NPDES permit NCO085871 at this same facility,
SITE DESCRIPTION The site is a former metal fabrication facility in operation since 1965. The building has been vacant
since 1985 except for a cardboard recycling facility operating in the northeast portion of the building. Groundwater
contamination is primarily on the south side of the building near the former UST area.
HYDROGEOLOGIC DESCRIPTION The site is located in the western piedmont and is underlain by sandy, silty. clayey soils
and saprolite developed from felsic metamorphic rocks. Fractures of varying frequency occur in saprolite and bedrock with
some zones of intense fracturing. Depth to groundwater ranges from 28 feet north of the facility to 77 feet south of the facility,
near a line of recovery wells associated with a NPDES groundwater remediation system. Groundwater flows to the south under
a hydraulic gradient increasingly steeper toward the line of recovery wells; see Figure 3.
EXTENT OF CONTAMINATION Figure 4 shows the lateral extent of contamination and the pilot test area near recovery
well RW-I0. The depth of contamination is at least 115 feet based on the deepest recovery well screened interval. The
abundance of fractures probably helped distribute contamination at depth and is likely to act as a source of residual
contamination in groundwater over time.
PROPOSED INJECTION 1800 gallons of catalyzed hydrogen peroxide will be injected via nine permanent injection
wells, which are to be constructed near the former UST area as indicated in Figure 2A. Six wells will be screened from 50-55
feet depth and three screened from 60-65 feet depth; there will be two pairs of nested wells, having one of each of these wells in
a single borehole. These injection intervals were chosen for this pilot test in order to correspond to the screened intervals of
nearby monitoring wells MW-I 12 and MW-129. The proposed injectant makes use of Fenton's chemistry, which is hydrogen
peroxide catalyzed with iron sulfate and an acid. Hydrogen peroxide will be injected at a concentration not to exceed 11.3%.
which is less than the maximum of 15% that the UIC Program typically permitted in previous permits.
HOW IT WORKS Hydrogen peroxide is a strong, short-lived oxidant that directly destroys organic compounds, such as
the site contaminants. Hydrogen peroxide is catalyzed by ferrous iron sulfate, which boosts the oxidant strength via generation
of sulfate free radicals, which are also strong, short-lived oxidizing agents. The acid, to be either phosphoric or sulfuric, is a
stabilizer for the ferrous sulfate and provides the optimum pH for these powerful oxidizing reactions.
MONITORING The groundwater monitoring plan detailed in Attachment F of the application package will be followed
with the following revision: RCRA metals are to sampled prior to injection and until concentrations return to pre -injection
levels. Wells proposed for monitoring are located in the vicinity of the injection wells; the most downgradient well, recovery
well RW-10. is -- 10 feet from the nearest injection well. Offsite migration of contaminants is not of concern because of the
recovery well network and low injection volume to pore space ratio (21 % based on average porosity estimate).
EPIDEMIOLOGY On June 21.2004, Dr. Luanne Williams provided comments on Fentons's Reagent for groundwater
remediation. Dr. Williams 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 Sherri Knight of the Winston-Salem Regional Office recommends issuance of this pen -nit

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
Flakt Products, Inc.
FOR THE CONSTRUCTION AND OPERATION OF 9 TYPE 5I INJECTION WELLS. defined in
Title 15A North Carolina Administrative Code 2C _0209(e)(3)(C), to inject Hydrogen Peroxide
catalyzed with Ferrous Sulfate and Phosphoric Acid or Sulfuric Acid, for the chemical oxidation of
chlorinated solvents. These injection wells/points will be located at the former Flakt Products, Inc.
facility. located at 2000 Lowery Street in Winston-Salem, Forsyth County, North Carolina, and will
be operated in accordance with the application submitted October 14, 2008, and in conformity with
the specifications and supporting data submitted on March 2, 2009, 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 February 28, 2011,
and shall be subject to the specified conditions and limitations set forth in Parts I through X hereof.
4 y
Permit issued this the '�0 day of . 2009.
oleen H. Sullins, Director
Division of Water Quality
By Authority of the Environmental Management Commission.
Permit No. W10400098 PAGE I OF 6
ver.8107 APIMC-6

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 (15A NCAC 2C
.0200). Any noncompliance with conditions of this permit constitutes a violation of the
Notch 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.
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.
S. 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
:iI li I ls'.'i aI �[�I�7►� �,�II [�]a�.y xeiv- 61*00 On 111-&I
At least forty-eight (48) hours prior to constructing each injection well, the Permittee shall notify
the Aquifer Protection Section -Underground Injection Control {UIC} Central Office staff,
telephone number [phone], and the Winston-Salem Regional Office Aquifer Protection
Section Staff, telephone number [phone].
Permit No. WI0400098 PAGE 2 OF 6
ver.8107 AWMC-6

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,
?. 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 Pentiittee of the responsibility of complying
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 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-
1 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 forty-eight (48) hours prior to the initiation of the operation of the facility for
injection, the Permittee must notify by telephone the Aquifer Protection Section-UIC, Central
Office staff, telephone number [phone], and the Winston-Salem Regional Office,
telephone number [phone]. Notification is required so that Division staff can inspect
or otherwise review the injection facility and determine if it is in compliance with permit
conditions.
Permit No. WI0400098 PAGE 3 OF 6
ver.8107 APIUIC-6

PART VI - INSPECTIONS
Any duly authorized officer, employee, or representative of the Division of Water Quality
may, upon presentation of credentials, enter and inspect any property, premises, or place on
or related to the injection facility at any reasonable time for the purpose of determining
compliance with this permit, may inspect or copy any records that must be maintained under
the terms and conditions of this permit, and may obtain samples of groundwater, surface
water, or injection fluids.
2. Department representatives shall have reasonable access for purposes of inspection,
observation, and sampling associated with injection and any related facilities as provided for
in N.C.G.S. 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 with the
following revision: groundwater samples shall be analyzed for RCRA metals (Arsenic,
Barium, Cadmium, Chromium, Lead, Mercury, Selenium and Silver) prior to injection and
thereafter until concentrations return to pre -injection concentrations.
2. All sample results shall be submitted to the Aquifer Protection Section's Winston-Salem
Regional Office and the Central Office in Raleigh. 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 Permittee shall submit an Injection Event Record within 30 days of completing each
injection.
4. The Permittee shall produce a final project evaluation within 9 months after completing all
injection -related activity associated with this permit or produce a project interim evaluation
before submitting a renewal application for this permit. This document shall assess the
injection projects findings in a written summary. The final project evaluation shall also
contain monitoring well sampling data, contaminant plume maps and potentiometric surface
maps.
5. The monitoring results and the final project evaluation shall be submitted to:
Aquifer Protection Section-UIC Staff Aquifer Protection Section
DENR-Division of Water Quality and to: Winston-Salem Regional Office
1636 Mail Service Center 585 Waughtown Street
Raleigh, NC 27699-1636 Winston-Salem, NC 27107
Permit No. W 10400098 PAGE 4 OF 6
ver.8107 d,P1UIC-6

6. The Permittee shall report by telephone, within 48 hours of the occurrence or first knowledge
of the occurrence. to the Winston-Salem Regional Office, telephone number [phone],
any of the following:
(A) Any occurrence at the injection facility which results in any unusual operating
circumstances;
(B) Any failure due to known or unknown reasons, that renders the facility incapable of
proper injection operations, such as mechanical or electrical failures.
7. Where the Permittee becomes aware of an omission of any relevant facts in a permit
application, or of any incorrect information submitted in said application or in any report to
the Director, the relevant and correct facts or information shall be promptly submitted to the
Director by the Permittee.
8. In the event that the permitted facility fails to perform satisfactorily. the 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
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 .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 15A NCAC 2C .0113(b), including but not limited to the following:
(A) All casing and screen materials may he removed prior to initiation of abandonment
procedures if such removal will not cause or contribute to contamination of the
groundwaters.
(B) The entire depth of each well shall be sounded before it is sealed to insure freedom
from obstructions that may interfere with sealing operations.
(C) The well shall be thoroughly disinfected, prior to sealing, if the Director determines
that failure to do so could lead to the contamination of an underground source of
drinking water.
Permit No. W10400098 PAGE 5 OF 6
ver.$147 APUIC-6

(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
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 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
1. 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.
3. Eating, drinking, smoking, handling contact lenses, and applying cosmetics should not be
permitted in the application area during or immediately following application.
4. Safety controls should be in place to ensure that the check valve and the pressure delivery
systems are working properly.
5. The Material Safety Data Sheets should be followed to prevent incompatible or adverse
reactions and injuries.
Permit No. W10400098 PAGE 6 OF 6
ver.8107 APfUIC-6

Central Files: APS SWP
10/15/08
Permit Number WI0400098 Permit Tracking Slip
Program Category Status Project Type
Ground Water In review New Project
Permit Type Version Permit Classification
Injection In situ Groundwater Remediation Well (5I) Individual
Primary Reviewer
thomas.slusser
Permitted Flow
Permit Contact Affiliation
John Conant, Director
2000 Day Mill Rd Cep 880-1911
Windsor CT 06095
Facility
Facility Name Major/Minor Region
Former Flakt Products Site Minor Winston-Salem
Location Address
2000 Lowery St
Winston Salem NC 27101
Owner
County
Forsyth
Facility Contact Affiliation
Owner Name Owner Type
Individual
Fred Godley Owner Affiliation
Fred Godley
PO Box 1140
Cornelius NC 28031
Scheduled
Orig Issue App Received Draft Initiated Issuance
10/14/08
ulated Activities
❑utfall 'NJ ULL
Waterbody Name
Public Notice Issue Effective Expiration
Requested/Received Events
RO staff report received
RO staff report requested
Stream Index Number Current Class 5ubbasin