WI0400254_PERMIT_20130211

DIVISION OF WATER QUALITY
AQUIFER PROTECTION SECTION
February 11, 2013
MEMORANDUM
TO: Debra Watts /��
FROM: Michael Rogers / �' l
RE: Issuance of permit to inject Biosolve (Permit #WI0400254)
ExxonMobil Former Facility #46602
I recommend that Permit Number WI0400254 be issued to ExxonMobil to inject Biosolve to remediate groundwater
(GW) contaminated with petroleum products. In order for you to better follow the information below in the memo, a
timeline for this permit follows.
Event
Date
Permit application received
June 22, 2012
Additional Information Request No. 1 sent requesting
additional wells installed and plume delineated
June 28, 2012
Received Add Info Request No. 1 including
groundwater data from three recently installed
additional monitoring wells
November 15, 2012
Staff Report requested from Winston-Salem RO
November 30, 2012
Staff Report received
January 7, 2013
Additional Information Request No. 2 sent
January 15, 2013
Received Additional Information Request No. 2
February 1, 2013
Forward draft permit to you
February 11, 2013
SITE DESCRIPTION: The subject site is a former demolished ExxonMobil service station, which is now a Walgreens
Drugstore (Figures 1 and 2).
HYDROGEOLOGIC DESCRIPTION: The Site is located in the Charlotte Slate Belt of the Piedmont Physiographic Region.
In the area of the Site, the overburden consists primarily of clayey heterogeneous saprolite to approximately 58 feet BLS.
Below 58 feet is meta -granitic bedrock. Depth to groundwater (GW) is approximately 20 to 25 feet BLS. GW generally
flows north to northwest at approximately 20 ft/year based upon an assumed average hydraulic of 2.82E-04 and porosity
of 30% (Figure 3).
EXTENT OF CONTAMINATION: The extent of the contaminant plume at this site is not clearly delineated. Even after
installing three additional monitoring wells downgradient and collecting groundwater analytical data, the plume is still not
technically delineated. The three additional wells were installed per our first Additional Information request we sent on
June 28, 2012. Analytical data with updated plume maps were received November 15, 2012. The site is located in a
highly urbanized commercial/retail area of Greensboro and is bordered on the north by High Point Road, a major four lane
highway through Greensboro. It could take the Permittee several additional months (or years) to acquire legal access,
install wells, obtain laboratory analytical data, and submit more data to determine the leading edge .of any contaminant
plume; especially if there may be petroleum contaminants coming from other sources in the area. It is possible that the
lateral extent of the plume coming from the Former ExxonMobil facility could never be clearly delineated. Refer to
Figure 4 - Groundwater Analytical Map -August 22, 2012. Injection wells are highlighted in pink, monitoring wells in
yellow, and wells used for obtaining groundwater elevation data only- in orange. 'Where wells are both pink and yellow -
they are both used for injection and monitoring. Note all wells will be gauged for groundwater elevation data.

PROPOSED INJECTION: The proposed injection consists of 2 separate injection events with each event injecting a total of
3000 gallons of Biosolve (a surfactant) via five permanently installed injection wells (estimated 600 gallons per day per
well). Each injection event is to last 1 day with six months between events. Within 48 hours of each event, three days of
aggressive fluid vapor recovery will occur. The objective is to inject/extract the surfactant/potable water mixture through
the subsurface to recover dissolved phase contaminants of concern exceeding the applicable North Carolina GCL
standards. Groundwater recovery will be monitored to ensure recovery of at least two times the injected volumes. Since
they are extracting two times the injected volume, the potential displacement of the plume is, therefore, low. Note that
there are no known private potable wells located within 300 meters of the site, or public water wells within 1500 meters of
the site (refer to Appendix B. in the Add Info package received November 15, 2012).
HOW IT WORKS: Biosolve is used to remediate groundwater contaminated with petroleum compounds by reducing the
molecular tensions holding hydrocarbons to other sources or compounds, thereby allowing the petroleum molecules to be
flushed and removed.
MONITORING: The proposed revised monitoring plan is to collect groundwater samples from the five wells used for
injec 'on plus the three newly installed monitoring (MW-22, MW-23, and MW-24). However, I am requesting MW-22
an MMPE2 added to the monitoring plan. Proposed frequency is prior to injection, shortly after injection and
yr"= trac ion, and then quarterly thereafter. Based upon analytical results, a second injection may occur six months later, and
(efit ' possibly a third injection event six months after that.
EPIDEMIOLOGY: The DHHS has reviewed and approved Biosolve as an injectant.
REGIONAL OFFICE COMMENTS: Each of the RO comments/recommendations are discussed below (RO's
comments/recommendations are underlined).
Item #1- ... If nothing needs to be worried about the injectant, Winston-Salem RO suggests to include field parameters,
pH, dissolved oxygen. specific conductance, and temperature into the monitoring plan. Since Biosolve is basically a
surfactant, no additional parameters are necessary other than the referenced field parameters. These parameters have been
added to the revised monitoring plan received in the second Add Info package received February 1, 2013.
Item #2- Complete well construction records of MW-22 to MW-24, and Table 1 updated with these wells. This
information was supplied in the second Add Info package received February 1, 2013.
Item #3- If the depth of MW-22 is deeper than MW-14 and MMPE3, an additional well requested in Section IV item 7 of
this review form may not be necessary. The depth of newly installed MW-22 is 20 feet. This is shallower than MW-14 (25
feet deep) and MMPE3 (40 feet deep). However, MW-22 is cross gradient of the injection area. There are two new
monitoring wells installed down gradient: MW-23 (screened from 12 to 22 feet) and MW-24 (screened from 10 to 25
feet). Although they are not as deep as MMPE3, I believe these wells will suffice for the following reasons: (1) All
injection wells including MMPE3 will be monitored prior to injection, undergo extraction of two times the amount of
injectant, and will be monitored after the injection; and (2) There are no distinct separate aquifers in the overlying
saprolite (i.e, injection and monitoring wells are essentially in the same surficial aquifer).
Sherri Knight, of the Winston-Salem RO, recommended issuance of this permit in the Staff Report received January 7,
2013.
I consulted Thomas on this project and he also recommends permit issuance.

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
ExxonMobil Environmental Services
FOR THE CONSTRUCTION AND/OR OPERATION OF FIVE (five) IN SITU
REMEDIATION/TRACER INJECTION WELLS, defined in Title 15A North Carolina
Administrative Code 2C .0209(5)(b)(viii), to inject Biosolve, for the remediation of groundwater
contaminated with volatile hydrocarbons. These injection wells/points will be located at the
Former ExxonMobil Facility #46602, 3701 High Point Road, Greensboro, Guilford County, NC
27407, and will be operated in accordance with the application submitted, June 22, 2012, and in
conformity with the specifications and supporting data submitted November 15, 2012, and
February 1, 2013, 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 January 31,
2018, and shall be subject to the specified conditions and limitations set forth in Parts I through
X hereof.
Permit issued this the 15th day of February 2013.
ft Charles Wakild, P.E., Director
Division of Water Quality
By Authority of the Environmental Management Commission.
Permit No. WI0400254 PAGE 1 OF 6
ver. January 2013 UIC-5I/5T

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
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 II - 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 919-807-6406 and the Winston-Salem Regional Office Aquifer
Protection Section Staff, telephone number 336-771-5000.
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. WI0400254 PAGE 2 OF 6
ver. January 2013 UIC-51/5T

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.
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
1. 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 919-807-6406 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. WI0400254 PAGE 3 OF 6
ver. January 2013 UIC-5I/5T

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 revised monitoring plan received February 1, 2013, shall be followed except
that monitoring wells MW-18 and MMPE2 shall be added to the monitoring plan. 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 quarterly. 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 in Part VII.6 below.
4. The Permittee shall submit an Injection Event Record within 30 days of completing each
injection.
5. The Permittee shall submit a final project evaluation within 9 months after completing all
injection -related activity associated with this permit or produce an interim evaluation while
submitting 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.
6. All monitoring results, forms, and reports required in this Part shall be submitted to:
UIC Program Staff
DWQ — Aquifer Protection Section and
1636 Mail Service Center
Raleigh, NC 27699-1636
DWQ - Aquifer Protection Section
Winston-Salem Regional Office
585 Waughtown Street
Winston-Salem, NC 27107
Permit No. WI0400254
ver. January 2013 UIC-5I/5T
PAGE 4 OF 6

7. The Permittee shall report by telephone, within 48 hours of the occurrence or first knowledge
of the occurrence, to the Morresville 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.
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 VIII - PERMIT RENEWAL
In order to continue uninterrupted legal use of the injection facility for the stated purpose, the
Permittee must submit an application to renew the permit 120 days prior to its expiration date.
PART IX - CHANGE OF WELL STATUS
1. The Permittee shall provide written notification within 15 days of any change of status of an
injection well. Such a change would include the discontinued use of a well for injection. If a
well is taken completely out of service temporarily, the Permittee must install a sanitary seal.
If a well is not to be used for any purpose that well must be permanently abandoned
according to 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.
(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. WI0400254 PAGE 5 OF 6
ver. January 2013 UIC-51/5T

(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 .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. 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. WI0400254 PAGE 6 OF 6
ver. January 2013 UIC-5I/5T