HomeMy WebLinkAboutWI0500248_PERMIT_20110415NORTH 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
Petitioner for DSCA Site 92-0033
FOR THE CONSTRUCTION AND OPERATION OF 5 TYPE 5I INJECTION WELLS, defined in
Title 15A North Carolina Administrative Code 2C .0209(e)(3)(C), to inject a Zero-Valent Iron,
Hydrogen Release Compound (HRC), EHC, minor vitamin stimulants, nutrients, and oxygen
scavengers, and chemical oxygen scavengers solution for the enhancement of anaerobic
bioremediation of tetrachloroethylene (PCE). These injection wells/points will be located at the
Courtesy Cleaner Site, 8111 Creedmoor Road, Raleigh, Wake County, North Carolina, and will be
operated in accordance with the application submitted April 13, 2010, and in .conformity,with the
specifications and supporting data submitted September 1, December 9, 2010 and March 3, 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 .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 March 31, 2013, and
shall be subject to the specified conditions and limitations set forth in Parts I through X hereof.
Permit issued this the day of 1 L , 2011.
`514,79-zei\
2
v'C-oleen H. Sullins, Director
Division of Water Quality
By Authority of the Environmental Management Commission.
Permit No. W10500248
ver.8/07 AP/UIC-6
PAGE 1 OF 7
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.
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
D.ENR-Division of Water Quality
1636 Mail Service Center
Raleigh, NC 27699-1636
PART II - WELL CONSTRUCTION SPECIAL CONDITIONS
At least forty-eight (48) hours prior to constructing each injection well, the Permittee shall notify the
Aquifer Protection Section -Underground Injection Control (UIC) Central Office staff, telephone
number (919) 715-6168 and the Raleigh Regional Office Aquifer Protection Section Staff, telephone
number (919) 791-4200.
Permit No. WI0500248 PAGE 2 OF 7
ver.8/07 AP/UIC-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.
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 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
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. 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.
2. 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 P -iuzittee 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 (919) 715-6168. 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. WI0500248
ver.8/07
AP/UIC-6
PAGE 3 OF 7
PART VI - INSPECTIONS
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 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
I . One new monitoring well shall be installed downgradient from the proposed injection wells. The
well shall be placed —9 - 12 ft., a distance equal to approximately six to nine months of travel at
the theoretical groundwater velocity, from the downgradient-most injection well. The new
monitoring well shall be screened within the same zone as the proposed injection:
2. The proposed monitoring plan included in the application shall .be followed and incorporate the
new monitoring well specified in Part VII.1. All sample results shall be submitted to the Aquifer
Protection Section's Raleigh Regional Office and the Raleigh Central Office. Any monitoring
(including groundwater, surface water, or soil sampling) deemed necessary by the Division of
Water Quality to insure surface and ground water protection, will be established and an
acceptable sampling reporting schedule shall be followed.
3. The 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.
Permit No. WI0500248 PAGE 4 OF 7
ver.8/07 'AP/UIC-6 •
5. The monitoring results and the final project evaluation shall be submitted to:
Aquifer Protection Section-UIC Staff
DENR-Division of Water Quality
1636 Mail Service Center
Raleigh, NC 27699-1636
and to:
Aquifer Protection Section
. DENR-DWQ Raleigh Regional Office
1628 Mail Service Center
Raleigh, NC, 27699-1628
6. The Permittee shall report by telephone, within 48 hours of the occurrence or first knowledge of
the occurrence, to the Raleigh Regional Office, telephone number (919)791-4200, 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 ofany incorrect information submitted in said application or in any report to the Director, the
relevant and correct facts or information shall be promptly submitted to the Director by the
Permittee.
8. In the event that the permitted facility fails to perform satisfactorily, the Permittee shall take such
immediate action as may be required by the Director.
PART VIII - PERMIT RENEWAL
In order to continue uninterrupted legal use of the injection facility for the stated purpose, the
Permittee must submit an application to renew the permit 120 days prior to its expiration date.
PART IX - CHANGE OF WELL STATUS
1. The Permittee shall provide written notification within 15 days of any change of status of an
injection well. Such a change would include the discontinued use of a well for injection. If a
well is taken completely out of service temporarily, the Permittee must install a sanitary seal. If a
well is not to be used for any purpose that well must be permanently abandoned according to
15A NCAC 2C .0113, Well Construction Standards.
Permit No. WI0500248 PAGE 5 OF 7
ver.8/07 AP/UIC-6
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 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 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
Permit No. WI0500248 PAGE 6 OF 7
ver. 8 /07 AP/UIC-6
PART X — WORKER PRECAUTIONS DURING APPLICATION
I. 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.
6. Access to the area of application should be limited to the workers applying the product. In
order to minimize exposure to unprotected individuals, measure should be taken to prevent
access to the area of application.
Permit No. WI0500248 _ PAGE 7 OF 7
.ver.8/07 AP/UIC-6
DIVISION OF WATER QUALITY
AQUIFER PROTECTION SECTION
April 12, 2011
PERMIT ISSUANCE MEMO
TO: Debra Watts
THROUGH: Thomas Slusser
FROM: - John McCray
RE:
Permit To Inject a solution composed of Hydrogen Release Compound, zero valent iron,
EHC, a vitamin and nutrient mixture, and Ca -propionate
Courtesy Cleaners Site
I recommend that Permit Number WI0500248 be issued to the Petitioner for DSCA Site 92-0033 to inject a solution
composed of Hydrogen Release Compound, zero valent iron, EHC, a vitamin and nutrient mixture, and Ca -propionate
to enhance reductive dechlorination by biological activity within groundwater contaminated with chlorinated solvents.
SITE DESCRIPTION The site has operated as a full service dry-cleaning facility since 1992. A Phase II Limited
Subsurface Investigation discovered groundwater contamination by chlorinated solvents in 2005. Steps were taken by
facility operators to mitigate further contamination in 2008 by discontinuing the use of PCE. No remedial activities
have previously been undertaken at the site.
HYDROGEOLOGIC DESCRIPTION The site is underlain by residual material and bedrock of the Raleigh Belt
located within the Piedmont physiographic province. Residuum overlying the bedrock consists of silty and sandy clay
changing to silty sand and sandy silt and extends to a depth of approximately 68 feet. Bedrock consists of interlayered
mica gneiss, graphitic schist and mica garnet schist and immediately underlies the saprolite. Depth to groundwater
across the site varies from 22 to 27ft below ground surface(Table 4). Flow of the groundwater occurs at 0.004 ft/day
to the south across the site under a hydraulic gradient of 0.004 ft/ft. The aquifer has an average hydraulic
conductivity .414 ft/day and an effective porosity of —39%.
EXTENT OF CONTAMINATION Contamination at this site underlies the southern portion of the dry cleaning
facility and the parking area to the south of the facility and is elliptical in areal shape, The short axis is 122 feet and
the long axis is 202 feet and extends to a maximum depth of —51 feet.
PROPOSED INJECTION The Applicant proposes a single injection event of a solution composed of Hydrogen
Release Compound, zero valent iron, EHC, a vitamin and nutrient mixture, and propionate to enhance reductive
dechlorination of chlorinated solvent contamination underlying the site. The injections will occur through five direct -
push injection points (Figure 7) over a depth interval of seven feet. The total volume of injectant is proposed to be
—750 gallons, and will equal —5% of the pore volume within the saprolite aquifer.
HOW IT WORKS innovative Environmental Technologies, Incorporated's mixture is a solution composed of
Hydrogen Release Compound, zero valent iron, EHC, a vitamin and nutrient mixture, and propionate designed to
provide compatible components to increase reductive dechlorination through stimulation of microbial activity.
MONITORING Groundwater monitoring will consist of one pre -injection event, then quarterly for the one-
year period following the injection event. All samples collected will be analyzed for physical parameters to include
temperature, dissolved oxygen, pH, oxidation-reduction potential, specific conductivity, and total and dissolved iron.
Laboratory testing will analyze samples for VOCs, sulfates, methane, ethane, ethane, and volatile fatty acids. Samples
will be taken from three existing monitoring wells (MW-1, MW-7, and DW-1) and one new monitoring weII installed
down -gradient (to the west) of the injection area. Monitoring well and sampling information is discussed in Section
G: Monitoring Plan and well details shown in table ADT 3.
EPIDEMIOLOGY The DHHS' Epidemiology Branch provided comments on August 1, 2000 for the use of
Hydrogen Release Compound (HRC), on October 2, 1998 for the.use of Zero Valent Iron (ZVI), and on April 27,
2009 for the use of Vitamins B6 and B 12, Sodium Sulfite, Nutrients, and Propionate for groundwater remediation.
Neither Dr. Luanne K. Williams nor Dr. Kenneth Rudo presented any information that would preclude the use of
HRC, ZVI, and the supplemental nutrient solution'for injection, but did provide health risk analyses and worker safety
precautions, which are in Part X of the attached permit.
REGIONAL OFFICE COMMENTS Eric Rice of the Raleigh Regional Office recommend issuance of this permit with
the receipt of additional information as well as the installation of an additional monitoring well. Concentrations and
demand calculations were provided in Appendix 2. Because of the size of the proposed injection area (shown, Fig. 7)
and the spacing between injection points, it is not considered necessary to have individual locations identified by the
consultant. An additional, down -gradient, monitoring well is to be required in the permit.