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HomeMy WebLinkAboutWI0300058_Regional Office Historical File Pre 2018Michael F. Easley, Governor William G. Ross Jr., Secretary North Carolina Department of Environment and Natural Resources Alan W. Klimek, P.E. Director Division of Water Quality September 22, 2006 Mr. Vance Dann Southern States Cooperative, Inc. 6606 West Broad Street Richmond, NC 23230 RE: Issuance of Injection Well Permit WI0300059 Dear Mr. Dann: EECMVIE, SEP 2 6 2006 NCDENRMRO DWQ - A. tslfer Protection In accordance with the renew application submitted on August 30, 2006, we are forwarding permit number WI0300059. This permit is for the injection of oxygen to into an air sparging system to enhance aerobic biodegradation of the dissolved petroleum hydrocarbon contamination in groundwater at Southern States Salisbury Service, 1710 Jake Alexander Boulevard, Salisbury, North Carolina. This permit shall be effective from the date of issuance until September 30, 2008 and shall be subject to the conditions and limitations stated therein, including the requirement to submit a final project evaluation as stated in PART VII — MONITORING AND REPORTING REQUIREMENTS. Please read the entire permit to ensure that you are aware of all compliance requirements of the permit. You will need to notify this office by telephone 48 hours prior to initiation of operation of the facility. In order to continue uninterrupted legal use of the injection facility for the stated purpose, you must submit an application to renew the permit 120 days prior to its expiration date. If you have any questions regarding your permit please feel free to contact me at (919) 715-6935. cc: Thomas Dunham Mooresville Regional Office. CO-UIC files Enclosure Sincerely, � k Qu Qi, PG UIC Program Manager Aquifer Protection Section 1636 Mail Service Center Raleigh, NC 27699-1636 Internet: http://h2o.enr.state.nc.us 2728 Capital Boulevard Raleigh, NC 27604 Nne orthCarolina Naturally Phone (919) 733-3221 Customer Service Fax (919) 715-0588 1-877-623-6748 Fax (919) 715-6048 An Equal Opportunity/Affirmative Action Employer — 50% Recycled/10% Post Consumer Paper 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 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 Southern States Cooperative, Inc. FOR THE CONSTRUCTION AND OPERATION OF TYPE 5I INJECTION WELLS, defined in Title 15A North Carolina Administrative Code 2C .0209(e)(3)(C), for the injection of oxygen into an air sparging system to enhance aerobic biodegradation of the petroleum hydrocarbon contamination in.groundwater at this site. These injection wells/points will be located at 1710 Jake Alexander Boulevard, in Salisbury, Rowan County, North Carolina, and will be operated in accordance with the application received on July 18, 2003 and renew request received on August 30, 2006, 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 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 September 30, 2008, and shall be subject to the specified conditions and limitations set forth in Parts I through X hereof. Permit issued this the 22 day of ci2), , 2006. ��► lan W. Klimek, Director 1 Division of Water Quality By Authority of the Environmental Management Commission. Permit No. WI0300059 PAGE 1 OF 1 ver.4/05 APGUIC-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 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 DENR-Division of Water Quality 1636 Mail Service Center Raleigh, NC 27699-1636 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) 715-6935 and the Mooresville Regional Office Aquifer Protection Section Staff, telephone number (704)663-1699. Permit No. WI0300059 PAGE 2 OF 2 ver.4/05 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 inj ection 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, the Permittee must notify by telephone the Aquifer Protection Section-UIC, Central Office staff, telephone number (919) 715-6935. 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. WI0300059 PAGE 3 OF 3 ver.4/05 AP/UIC-6 PART VI - INSPECTIONS 1. Any duly authorized officer, employee, or representative of the Division of Water Quality may, upon presentation of credentials, enter and inspect any property, premises, or place on or related to the injection facility at any reasonable time for the purpose of determining compliance with this permit, may inspect or copy any records that must be maintained under the terms and conditions of this permit, and may obtain samples of groundwater, surface water, or injection fluids. 2. Department representatives shall have reasonable access for purposes of inspection, observation, and sampling associated with injection and any related facilities as provided for in N.C.G.S. 87-90. 3. Provisions shall be made for collecting any necessary and appropriate samples associated with the injection facility activities. PART VII - MONITORING AND REPORTING REQUIREMENTS 1. The proposed monitoring plan included in the application shall be followed. All sample results shall be submitted to the Aquifer Protection Section's Mooresville 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 produce a final project evaluation within 9 months after completing all injection -related activity associated with the permit application. 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. 3. 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 27699-1636 Aquifer Protection Section DENR-DWQ Mooresville Regional Office 610 East Center Ave. Mooresville, NC 28115 4. The Permittee shall report by telephone, within 48 hours of the occurrence or first knowledge Permit No. WI0300059 PAGE 4 OF 4 ver.4/05 AP/UIC-6 of the occurrence, to the Mooresville Regional Office, telephone number (704)663-1699, 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. 5. 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. 6. 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. 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 Permit No. WI0300059 PAGE 5 OF 5 ver.4/05 AP/UIC-6 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 pure oxygen are as follows: eye, nose, and throat irritation, nausea, dizziness, pulmonary irritation leading to pulmonary edema and pneumonitis. Intense and potentially fatal pulmonary edema may develop tracheal irritation, fever, nausea, vomiting, acute bronchitis, sinusitis, malaise, paresthesias, and conjunctivitis. 2. The application process should be reviewed by an industrial hygienist to. ensure that the most appropriate personal protective equipment is used. 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. WI0300059 PAGE 6 OF 6 ver.4/05 AP/UIC-6 DIVISION OF WATER QUALITY AQUIFER PROTECTION SECTION May 11, 2006 MEMORANDUM To: Andrew Pitner Mooresville Regional Office From: Jesse Wiseman Central Office UIC Program Re: Notice of Expiration UIC Permit No. WI0300059 Southern States Cooperative Incorporated Rowan County UIC Permit No. WI0300059 (Injection In situ Groundwater Remediation Well (5I)) issued to Southern States Cooperative Incorporated is due to expire on September 30, 2006. A Notice of Expiration regarding this permit was sent by this office to Vance Dann of Southern States Salisbury Service on May 11, 2006. This letter is attached for your records. Attachment cc: CO-UIC Files Michael F. Easley, Govemor William G. Ross Jr., Secretary North Carolina Department of Environment and Natural Resources Alan W. Klimek, P.E. Director Division of Water Quality May 11, 2006 Vance Dann Southern States Salisbury Service 6606 West Broad Street Richmond, VA 23230 CERTIFIED MAIL RETURN RECEIPT REQUESTED . 7002 2410 0003 0273 4409 Subject: Notice of Expiration North Carolina Well Construction Standards Applicable to Injection Wells - Subchapter 2C UIC Permit No. WI0300059 Issued to Southern States Cooperative Incorporated Rowan County Dear Mr. Dann: The Underground Injection Control (UIC) Program of the North Carolina Division of Water Quality is responsible for regulating injection well construction and operation activities within the state. Our records show that the injection well permit referenced above will expire on September 30, 2006. This permit was issued on September 25, 2003 for the injection system located at 1710 Jake Alexander Boulevard in Salisbury, North Carolina. Please submit the enclosed form, STATUS OF INJECTION WELL SYSTEM (form GW/UIC-68) to indicate the current status of your injection well system within 30 calendar days of the receipt of this,letter. If you intend to conduct additional injections or pursue any injection -related activities that are beyond the scope of the permit referenced above, you must submit a letter requesting a renewal and/or amendment of the permit that describes in detail the procedure, locations, volume, and frequency of injected material, and any other pertinent information regarding the proposed activity. In 'addition, our records indicate that a final project evaluation is due within 9 months after completion of the injection operation. To date we have not received this report. If the injection project has been completed, please submit the required final project evaluation as indicated in your permit in PART VII — MONITORING AND REPORTING REQUIREMENTS. If any injection well is no longer being used for any purpose, it must be permanently abandoned according to the regulatory requirements specified in the North Carolina Administrative Code NorthCarolina Naturally Aquifer Protection Section 1636 Mail Service Center Internet: www.ncwaterqualitv.org Location: 2728 Capital Boulevard An Equal Opportunity/Affirmative Action Employer— 50% Recycled/10% Post Consumer Paper Raleigh, NC 27699-1636 Telephone: (919) 733-3221 Raleigh, NC 27604 Fax 1: (919) 715-0588 Fax 2: (919) 715-6048 Customer Service: (877) 623-6748 Vance Dann May 11, 2006 Page 2 of 2 Title 15A Subchapter 2C Section .0214. If any injection well is to be permanently abandoned, well abandonment records must be submitted to our office to ensure proper abandonment. Please call Mike Ranck at (919) 715-6164, or email him at Michael.Ranck@ncinail.net if you have any questions regarding this correspondence, your permit, or the enclosed form. Sincerely, W Jesse Wiseman Processing Assistant UIC Program Enclosure cc: Tom Dunham, Duncklee & Dunham, P.C. SiMoo� e vi egonal s ffie - w/o n su e CO-UIC Files w/o enclosure MEMORANDUM To: From: (1k DIVISION OF WATER QUALITY GROUNDWATER SECTION September 26, 2003 Peggy Finley, Regional Groundwater Supervisor Groundwater Section Mooresville Regional Office Mark Pritzl Mark.Pritzl@ncmail.net Hydrogeological Technician If UIC Group Groundwater Section Raleigh Central Office NC DEPT, OF ENVIRONMENT AND NATURAL RESOURCES RECEIVED SEP 3 0 2003 MOORESVILLE REGIONAL OFFICE DWQ-GROUNDWATER SECTION Re: Issuance of injection well permit type 5I (in -situ Groundwater Remediation Well) Permit Number WI0300059 (Southern States Salisbury Service) for the injection of Oxygen into an air sparging system to enhance aerobic biodegradation of the dissolved petroleum hydrocarbon contamination in groundwater at 1710 Jake Alexander Boulevard, in Salisbury, North Carolina. The UIC group greatly appreciates Andrew Pitner's thorough review and assistance with this UIC application. Please retain the application paper work and permit copy for the MRO-UIC files. If you have any questions regarding this Memo or the UIC program, please contact me at (919) 715-6166. cc: CO-UIC Files Enclosures 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 Southern States Cooperative Incorporated FOR THE CONSTRUCTION AND OPERATION OF FOURTEEN TYPE 51 INJECTION WELLS, defined in Title 15A North Carolina Administrative Code 2C .0209(e)(3)(C), for the injection of Oxygen into an air sparging system to enhance aerobic biodegradation of the dissolved petroleum hydrocarbon contamination in groundwater at this site. These 14 injection wells will be located at 1710 Jake Alexander Boulevard, in Salisbury, North Carolina, and will be operated in accordance with the application received on July 18, 2003, 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 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 September 30, 2006, and shall be subject to the specified conditions and limitations set forth in Parts I through X hereof. Permit issued this the 2S day of aro, ) titkat Ted L. Bush, Jr., Assistant Chief Groundwater Section Division of Water Quality , 2003. By Authority of the Environmental Management Commission. Permit No. WI0300059 PAGE 1 OF 6 ver.3/01 GW/UIC-5 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. Each injection well shall not hydraulically connect separate aquifers. 4. Each injection well shall be constructed in such a manner that water from land surface cannot migrate into the gravel pack or well screen. 5. Each injection well shall be secured to reasonably insure against unauthorized access and use. Each well shall be permanently labeled with a warning that it is for injection purposes and the entrance to each well must be secured with a locking cap. 6. Each injection well shall be afforded reasonable protection against damage during construction and use. 7. Each injection well shall have permanently affixed an identification plate. 8. A completed Well Construction Record (Form GW-1) must be submitted for each injection well to, DENR-Division of Water Quality, Groundwater Section UIC-Staff, 1636 Mail Service Center, Raleigh, NC 27699-1636, within 30 days of completion of well construction. PART II - WELL CONSTRUCTION SPECIAL CONDITIONS 1. At least forty-eight (48) hours prior to constructing each injection well, the Permittee shall notify the Groundwater Section -Underground Injection Control (UIC), Central Office staff, telephone number (919) 715-6166. PART III - OPERATION AND USE GENERAL CONDITIONS 1. This permit is effective only with respect to the nature, volume of materials and rate of injection, 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. Permit No. WI0300059 PAGE 2 OF 6 ver.3/01 GW/UIC-5 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. 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, the Permittee must notify by telephone the Groundwater Section -Underground Injection Control (UIC), Central Office staff, telephone number (919) 715-6166. Notification is required so that Division staff can inspect or otherwise review the injection facility and determine if it is in compliance with permit conditions. 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. Permit No. WI0300059 PAGE 3 OF 6 ver.3/01 GW/UIC-5 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 monitor plan included in the application received on July 18, 2003, shall be followed and all sample results shall be submitted to the Groundwater Section's Mooresville 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 produce a final project evaluation within 9 months after completing all injection -related activities associated with the permit application. This document shall assess the injection projects findings in a written summary. The final project evaluation shall also include all monitoring well sampling data, the contaminant plume maps and the potentiometric surface maps. 3. The final project evaluation shall be submitted to the Underground Injection Control Program, Groundwater Section, NC DENR-Division of Water Quality, 1636 Mail Service Center, Raleigh, NC 27699-1636 and to the Groundwater Section, Mooresville Regional Office, 919 North Main Street, Mooresville, NC 28115. 4. The Permittee shall report by telephone, within 48 hours of the occurrence or first knowledge of the occurrence, to the Mooresville Regional Office, telephone number (704) 663-1699, 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. 5. 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. 6. 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. Permit No. WI0300059 PAGE 4 OF 6 ver.3/O 1 GW/UIC-5 PART VIII - PERMIT RENEWAL The Permittee shall, at least three (3) months prior to the expiration of this permit, request an extension. 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 .0213(h)(1), 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 .0214, including but not limited to the following: (A) All casing and materials may be removed prior to initiation of abandonment procedures if the Director finds such removal will not be responsible for, or contribute to, the contamination of an underground source of drinking water. (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, 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 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 cavityhas 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. Permit No. WI0300059 PAGE 5 OF 6 ver.3/O1 GW/UIC-5 3. The written documentation required in Part IX (1) and (2) (G) shall be submitted to: Groundwater 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 short-term exposure to 100% oxygen are as follows: • Inhalation of 100% oxygen can 'result in nausea, dizziness, pulmonary irritation leading to pulmonary edema, and pneumonitis (Meditex - Medical Management by Micromedex TOMEs Plus System CD-ROM Database, Volume 52, 2002). • Intense and potentially fatal pulmonary edema may develop tracheal irritation, fever, nausea, vomiting, acute bronchitis, sinusitis, malaise, paresthesias and conjunctivitis (Meditext — Medical Management by Micromedex TOMEs Plus System CD-ROM Database, Volume 52, 2002). • Inhalation of 100% oxygen can cause eye, nose and throat irritation (Meditext — Medical Management by Micromedex TOMEs Plus System CD-ROM Database, Volume 52, 2002). 2. The application process should be reviewed by an industrial hygienist to ensure that the most appropriate personal protective equipment is used. 3. Eating, drinking, smoking, handling contact lenses, and applying cosmetics should never 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. WI0300059 PAGE 6 OF 6 ver.3/01 GW/UIC-5 Michael F. Easley, Governor William G. Ross Jr., Secretary North Carolina Department of Environment and Natural Resources Alan W. Klimek, P. E. Director Division of Water Quality Coleen H. Sullins, Deputy Director Division of Water Quality September 26, 2003 Mr. Vance Dann Southern States Salisbury Service 6606 West Broad Street Richmond, VA 23230 Dear Mr. Dann: In accordance with the application received on July 18, 2003, we are forwarding Permit Number WI0300059 for the injection of Oxygen into an air sparging system to enhance aerobic biodegradation of the dissolved petroleum hydrocarbon contamination in groundwater at 1710 Jake Alexander Boulevard, in Salisbury, North Carolina. This permit shall be effective from the date of issuance until September 30, 2006, and shall be subject to the conditions and limitations stated therein, including the requirement to submit a final project evaluation as stated in PART VII - MONITORING AND REPORTING REQUIREMENTS. You will also need to notify this office by telephone 48 hours prior to initiation of injection at this facility. In order to continue uninterrupted legal use of this injectant for the stated purpose, you should submit an application to renew the permit three months prior to its expiration date. If you have any questions regarding your permit please contact me at (919) 715-6166 or Evan Kane at (919) 715-6165. Sincerely, li a Mark Pritzl Hydrogeological Technician UIC Program cc: Tom Dunham, Duncklee & Dunham (fax copy) MRO-UIC Files (Mr. Pitner) CO-UIC Files Enclosures N. C. Division of Water Quality / Groundwater Section 1636 Mail Service Center Raleigh, N.C. 27699-1636 Phone: (919) 733-3221 Fax: (919) 715-0588 Internet: http://gw.ehnr.state.nc.us gia Customer Service 1-877-623-6748 GROUNDWATER SECTION September 17, 2003 MEMORANDUM To: Debra Watts, Supervisor, Permits & Compliance Branch Through: Evan Kane, Hydrogeologist, UIC Program Manager From: I ' i . Mark Pritzl, Hydrogeological Technician, UIC Program Re: Southern States' injection well application for the injection of Oxygen into an air sparging system to enhance aerobic biodegradation of petroleum hydrocarbon dissolved in groundwater at this site. • This site is located in the Charlotte Belt of the Piedmont Physiographic Province of North Carolina. The site is underlain by clays, silts and sands that grade down to mainly silty sands to a depth of 40 feet below land surface (bls). Partially weathered metavolcanic bedrock was encountered at a depth of roughly 40 feet bls. Competent bedrock has not been encountered at this site. • Shallow groundwater movement is generally toward the south-east across the entire site. Water levels collected in May 2003, show that depth to the water table ranges from 3 to 16 feet below land surface (bls). The consultant has calculated average groundwater seepage velocity to be 10 feet/year, and this may be somewhat conservative. Monitor well water level data collected on May 8, 2003, indicate that the upper surficial aquifer is recharging the transition zone, where most lateral groundwater movement takes place. • VOC contamination exists in the surficial aquifer, and petroleum released from the former dispenser island is the likely cause of VOC groundwater contamination. The dissolved contamination is consistent with a petroleum release, and the table behind this summary shows what was reported in the last sampling event. • The site contains a combination Air-Sparge (AS) and Soil -Vapor -Extraction (SVE) system that has been in operation since 1999. In March 2002, this system was discontinued due to air quality issues. The AS system was to deliver ambient air to groundwater for the enhancement of aerobic biodegradation of dissolved petroleum contamination. The SVE system was to remove volatiles from both the unsaturated zone and the AS system. The AS system consists of fourteen AS wells, each constructed to a depth of 25 feet, with a two foot screen from 23- 25 feet bls. (see map behind summary) The applicant proposes to augment the AS system with the injection of pure Oxygen, and states that the SVE system will not operate during the entire injection process. • The AS system will be enhanced with the injection of pure oxygen to generate more dissolved oxygen in groundwater for naturally occurring aerobic bacteria to use. These bacteria will break down the hydrocarbons to CO2 & H2O, and the consultant has calculated the amount of oxygen (oxygen demand) needed for the bacteria to break down the estimated dissolved hydrocarbon contamination. A L, • The injection of oxygen will be done manually from 02 cylinders, utilizing 13 cylinders for each of the three proposed injection events. At the beginning of each event, the AS system will be turned on and allowed to equilibrate. Then, the 02 cylinder will be attached to a feeder pipe and the ball valve will be slowly opened. The oxygen will be injected at a rate of 8 cubic feet per minute (cfm), and at this rate each 251 cubic foot 02 cylinder will last roughly 0.5 hour. The AS blower will introduce ambient air at 160 cfm, and the injection of pure oxygen at 8 cfm will give a total rate of 168 din. This initial injection event will increase the oxygen content of the injected air from roughly 21% to 26% by volume. After the initial injection event, the other two injection events will be conducted approximately two weeks apart. A 5 ppm to 10 ppm DO concentration is the goal in the core wells, which will indicate that the surficial aquifer has increased its DO level. If a 5 ppm to 10 ppm DO concentration can be achieved, then injection events beyond the three proposed will be conducted on a monthly basis. • Prior to initiation of the AS system and the addition of oxygen, monitoring wells in the core of the plume will be monitored for dissolved oxygen (DO)(MW-1, MW-4 and MW-5). DO will be monitored in these three monitoring wells for the duration of the injection event. Once all of the oxygen has been added to the air stream, the system will be remain operational for an additional hour to purge the lines of any oxygen -augmented air. DO will be monitored in these three monitor wells at approximately 12 hours, 36 hours and one week post -system shutdown. Long term monitoring will continue semi-annually, as required by the approved CAP. • Some of the limiting factors for 02 injection at this site are; there is significant dissolved iron (ferrous) in the heart of the plume, and this could scavenge the delivered oxygen, preventing the bacteria from utilizing it, the radius of influence of the injected oxygen may be limited so as to be ineffective, and finally, the plume itself may be too toxic for the bacteria to propagate, especially at total VOCs with concentrations above 10,000 ug/L. • At this time, I recommend that a permit be issued to Southern States for the introduction of oxygen into the AS system for the enhancement of aerobic degradation of dissolved VOCs. PY_, DIVISION OF WATER QUALITY GROUNDWATER SECTION MOORESVILLE REGIONAL OFFICE August 13, 2003 MEMORANDUM TO: Mark Pritzl — UIC Group Groundwater Section -Central Office FROM: Andrew Pitner �(1 SUBJECT: Southern States Coop., Salisbury, NC I am attaching the Preconstruction Injection Facility Inspection Report Form for the subject site to this memo along with my comments after looking at the application (I will also be sharing these with the consultant for the project as part of my review of their latest semi-annual report). I am also attaching an information paper related to the site that was last updated in 2001 (the remediation strategy has changed somewhat, but most of the rest of it should be reasonably accurate. Let me know if you have any questions. Page 1 of 2 North Carolina Department of Environment and Natural Resources Division of Water Quality Groundwater Section PRECONSTRUCTION INJECTION FACILITY INSPECTION REPORT -FORM A INJECTION WELL PERMIT NO. WI 0 0045GI NAIVIE OF OWNER DATE ,/\S-c-,Cv��� ADDRESS OF OWNER l,¢ CI U3. • S LYE:- �\ o I (t.-.) cC��\-lcL1 �S �i�v\C ZLtiV1l� (Street/ road or lot and subdivision, county, town) LOCATION OF PROPOSED INJECTION WELLL(and source well(s), if applicable) n 1 ` jc\L\ 1 l l�1 �� 1 ` -e \t r' U11 11 ? Q A LI 5 ac31-- \v-\ (Street/ road or lot and subdivision , county, town, if different than owner's address, plus description Cloy Potential pollution source -co-c vtia �':�.,�1� S s\— �� �\ Distance from well Potential pollution source J,r \; .12N- ckv Distance from well Potential pollution source o ti ,,r-7,4CO,6%0(,10 \ Distance from well o �1LiOfk '' 100 + Minimum distance of proposed well from property boundary `" ZU S4, Quality of drainage at site 0,6A'e.0fib. Flooding potential of site (good,adequate,poor) (high,moderate, low) DRAW SKETCH OF SITE (Show property boundaries, buildings, wells, potential pollution sources, roads, approximate scale, and north arrow.) of location on site) 7 conks J -k GW/UIC-1 March 28, 2001 Page 11111 PRECONSTRUCTION INJECTION FACILITY INSPECTION REPORT - FORM A (cont.) GPS Data: Latitude: COMMENTS Longitude: ' 63 • �7° / t c 2 'e-r CJ\G",iN f (kl`N-S V'\ v,`sJ er \\ CL. )C t LSl J ' — G' a - SD t , q 1S t" ` (�-LI.U'L�' , (.iV�2%? N V11nnC!v �t/iS ����diS• �S\1 J of \ V J INSPECTOR Office 1\11 R-6 WITNESS ! �/7i-.fir% Address J7 WITNESS Address v\ CY v-d GW/UIC-1 March 28, 2001 MRO Review of June 2003 UIC Permit Application for Southern States Cooperative, Inc., Salisbury, NC. Groundwater Incident #12547. By Andrew Pitn�r, August 13, 2003. I am familiar with the site and have reviewed the permit application. I support the proposed injection, but offer the following comments: • The calculations for oxygen demand should be taken as a very rough first estimate of the amount of required oxygen. The assumptions made in these calculations are likely to have significant error associated with them (treating the contamination in MW-4 as benzene, when most of the contaminant mass is actually xylenes and trimethylbenzene isomers; and no "fudge factor" to account for inefficiency of the delivery system). Despite those issues, it is not an unreasonable way to get a first guess at the amount of oxygen required. • The goal of 5 to 10 ppm DO in core wells is seems optimistic given historical DO levels at the site during and after operation of the AS/SVE system without the any additional oxygen input. DO response from core wells in the past was variable, but most wells have shown a clear and consistent decline in DO since the air sparge system was shut down in March 2002. INFORMATION PAPER Updated 8/13/01 Southern States. Cooperative, Inc. Salisbury, Rowan County, North Carolina Groundwater Incident N2: 12547 I. Site History (abbreviated) • 5/20/93 — petroleum impacted soil and groundwater discovered on site during completion of Comprehensive Site Assessment (CSA) activities for the Former Exxon Terminal across the street. • 4/19/94 — NOV issued to Southern States Cooperative, Inc. • 7/13/94 — CSA for Southern States received by DENR; additional information required. • 12/17/96 — CSA approved by DENR. • 9/18/97 — CAP received by DENR. • 6/19/98 — CAP approved by DENR. II. Incident Data A. Setting: Mixed industrial/commercial adjacent with single-family residential at distance to north and northeast. B. Chemicals of Concern (COC): Petroleum constituents: BTEX (benzene, toluene, ethylbenzene, xylenes), : IPE (isopropyl ether), EDB (ethylene dibromide), 1 ,2-dichloroethane, 1,2,4- trimethylbenzene, 1,3,5-trimethylbenzene, butylbenzene, n-propylbenzene, and isopropylbenzene. C. Source: A petroleum release from a former on -site AST system and the associated pump island and piping. III. Contamination A. Soil Contamination — Petroleum contaminated soils exist near the former pump island. B. Groundwater Plume Aerial Extent: o Surficial Aquifer - approximately 400 ft x 240 ft, or 96,000 ft2 or 2.2 acres. o Bedrock Aquifer not contaminated. C. Historical maximum concentrations of selected COC's: CONSTITUENT Benzene MAXIMUM (µ9►L) Ethylbenzene Toluene Xylenes EDB IPE 23,000 COC'S DETECTED IN MONITORING WELLS DATE 5/3/95 LOCATION MW-4 MOST RECENT (µGIL) 1,500 DATE 5/30/01 2L GROUNDWATER STANDARD 15,000 Free Petroleum Product 18,000 17,800 1.9 240 5 5/26/94 NMI-1 MW-4 1,200 1,700 5/30/01 5/30/01 29 1,000 Not detected 7/28/99 5/3/95 5/3/5 N/A' MW-4 MW-4 MW-5 N/A 17,600 0.7 nd N/A 5/30/01 5/30/01 5/30/01 N/A 530 0.0004 70 N/A IV. Corrective Action System A. Type of System: Active remediation of contaminated soil and groundwater is occurring via air sparging and soil vapor extraction systems in the source area. Natural attenuation was chosen to address groundwater contamination beyond the source area. B. Monitoring: MWs 1-11 and MW-1 d are monitored on a semi-annual basis for COC's andnatural attenuation parameters. Soil samples are collected annually to assess the progress of active soil remediation systems. Area receptors — Eight water supply wells have been identified within 1,500 feet of the Southern Information Paper Southern States Cooperative, Inc. GW Incident No. 12547 Page 2 of 2 States Cooperative site. Of these, two have been determined to be currently active. All others have been disconnected and the locations are hooked to city water. The two wells are hydraulically up gradient of the site at distances of roughly 600 and 1,200 feet. Active and inactive wells have been sampled and have not shown petroleum -related compounds such as BTEX. VI. Opinions - Based on the most recent groundwater sampling data and other file information the following statements and opinions can be made: A. The COC's are not contained on site; off site contamination extends to the adjacent property to the south. B. Portions of the petroleum plume associated with releases from the Southern States Cooperative are likely commingled with the petroleum plume associated with the Former Exxon Terminal directly across Jake Alexander Blvd. from the site. C. There. is no data indicating groundwater impacts to residential areas in the vicinity. DIVISION OF WATER QUALITY GROUNDWATER SECTION MOORESVILLE REGIONAL OFFICE August 13, 2003 MEMORANDUM TO: Mark Pritzl — UIC Group Groundwater Section -Central Office FROM: Andrew Pitner SUBJECT: Southern States Coop., Salisbury, NC am attaching the Preconstruction Injection Facility Inspection Report Form for the subject site to this memo along with my comments after looking at the application (I will also be sharing these with the consultant for the project as part of my review of their latest semi-annual report). I am also attaching an information paper related to the site that was last updated in 2001 (the remediation strategy has changed somewhat, but most of the rest of it should be reasonably accurate. Let me know if you have any questions. Th n \N Da'‘Nif' Page 1 of 2 o- • NAME OF OWNER North Carolina Department of Environment and Natural Resources Division of Water Quality Groundwater Section PRECONSTRUCTION INJECTION FACILITY INSPECTION REPORT -FORM. A INJECTION WELL PERMIT NO. WI 030�'045�j ��\S`l seCDO DATE ADDRESS OF OWNER {b}. (_/. 0 w - \5 J 6E' v . 1L.\G\iN.VNkOmil\ , \ L\ 2 1�2-QC) cz-y'v-k2 L1" \ S �i�v1C4-�(_.1.11U\ (Street/ road or lot and subdivision, county, town) LOCATION OF PROPOSED INJECTION WELL (and source well(s), if applicable) \\,\ (a) A\.Q--KTv\&-1\ raQc L l t--} ` Ir') LcS�-.7�v� C v\--Vvt (Street/ road or lot and subdivision , county, town, if different than owner's address, plus description Q n� S T -. tlos- Potential pollution source col- w- Distance from well -v 10 Potential pollution source " r qv\F;Ne i 0.9'Distance from''well u miv 0,-\ 1.cc tiv1\u'R, \ Distance from well Potential pollution source DO -I- Minimum distance of proposed well from property boundary `" Z U 54, Quality of drainage at site ov)\9\koT.IC L Flooding potential of site 'L`�� (good,adequate,poor) (high,moderate,low) of location on site) DRAW SKETCH OF SITE (Show property boundaries, buildings, wells, potential pollution sources, roads, approximate scale, and north arrow.) • c-Q\--cor A-c) i V�Cc� Scv:Vc =� GW/UIC-1 March 28, 2001 Page 2 of 2 PRECONSTRUCTION INJECTION FACILITY INSPECTION REPORT - FORM A (cont.) GPS Data: Latitude: Longitude: — . �20i ki COMMENTS J P {�_ i U,_ G� C C P S l \c �� (�✓L 43 \ c... G2 �� 'C i U\1`)"\5.:,'\ I, \ l Nf P c�`f"\ C. \ J c_L.t.A.\ (NiN hl,'t \ G^V�i'lG, Y� h€_.. -U'\h/ ��o- J is �� �rc>K U �v ���'�,ecl (J r � ` n L) \P &- \. O C2`� , s r i-- ivvz,c— pu,vvt 1S \-r-)C v�,- --C cr-k ( 'iW ce. c, v-,eb N u,.w•QJ �s ')2J- (sit Q. 1 O > ,../k* s rl(* V ; \�1.e. c�1u, -6; � c-1�2�3 �vt�; ca-i - of � c� S 5-t-t-v, .. \ y\5r,1 �+ i r 1- \ - INSPECTOR S , Office Ni C) WITNESS Mi Address I -7 c 6 -MA iC r`n�� �� ��� I.ti<ir S� t.s'3.,t (1? WITNESS Address GW/UIC-1 March 28, 2001 MRO Review of June 2003 UIC Permit Application for Southern States Cooperative, Inc., Salisbury, NC. Groundwater Incident #12547. By Andrew Pitnr August 13, 2003. I am familiar with the site and have reviewed the permit application. I support the proposed injection, but offer the following comments: • The calculations for oxygen demand should be taken as a very rough first estimate of the amount of required oxygen. The assumptions made in these calculations are likely to have significant error associated with them (treating the contamination in MW-4 as benzene, when most of the contaminant mass is actually xylenes and trimethylbenzene isomers; and no "fudge factor" to account for inefficiency of the delivery system). Despite those issues, it is not an unreasonable way to get a first guess at the amount of oxygen required. • The goal of 5 to 10 ppm DO in core wells is seems optimistic given historical DO levels at the site during and after operation of the AS/SVE system without the any additional oxygen input. DO response from core wells in the past was variable, but most wells have shown a clear and consistent decline in DO since the air sparge system was shut down in March 2002. INFORMATION PAPER Updated 8113/01 Southern States Cooperative, Inc. Salisbury, Rowan County, North Carolina Groundwater Incident N2: 12547 I. Site History (abbreviated) • 5/20/93 — petroleum impacted soil and groundwater discovered on site during completion of Comprehensive Site Assessment (CSA) activities for the Former Exxon Terminal across the street. • 4/19/94 — NOV issued to Southern States Cooperative, Inc. • 7/13/94 — CSA for Southern States received by DENR; additional information required. 12/17/96 — CSA approved by DENR. • 9/18/97 — CAP received by DENR. • 6/19/98 — CAP approved by DENR. II. Incident Data A. Setting: Mixed industrial/commercial adjacent with single-family residential at distance to north and northeast. B. Chemicals of Concem (COC): Petroleum constituents: BTEX (benzene, toluene, ethylbenzene, xylenes), IPE (isopropyl ether), EDB (ethylene dibromide), 1,2-dichloroethane, 1,2,4- trimethylbenzene, 1 ,3,5-trimethylbenzene, butylbenzene, n-propylbenzene, and isopropylbenzene. C. Source: A petroleum release from a former on -site AST system and the associated pump island and piping. III. Contamination A. Soil Contamination — Petroleum contaminated soils exist near the former pump island. B. Groundwater Plume Aerial Extent: o Surficial Aquifer - approximately 400 ft x 240 ft, or 96,000 ft2 or 2.2 acres. o Bedrock Aquifer — not contaminated. C. Historical maximum concentrations of selected COC's: COC'SDETECTED INMONITORING'WELLS ' CONSTITUENT MAXIMUM DATE LOCATION MOST RECENT (p.GIL) DATE 2L GROUNDWATER STANDARD Benzene 23,000 513/95 MW-4 1,50) 5/30/01 1 Ethylbenzene 15,000 53/95 MW-1 1,200 5/30/01 29 Toluene 18,000 5/26/94 MW-4 1,700 5/30/01 1,000 Xylenes 17,800 7/28/99 MW-4 17,600 5/30/01 530 EDB 1.9 5/3195 MW-4 0.7 5/30/01 0.0004 IPE 240 5/3195 MW-5 nd 5/30/01 70 Free Petroleum Product Not detected N/A N/A N/A N/A N/A IV. Corrective Action System A. Type of System: Active remediation of contaminated soil and groundwater is occurring via air sparging and soil vapor extraction systems in the source area. Natural attenuation was chosen to address groundwater contamination beyond the source area. B. Monitoring: MWs 1-11 and MW-1 d are monitored on a semi-annual basis for COC's and natural attenuation parameters. Soil samples are collected annually to assess the progress of active soil remediation systems. V. Area receptors — Eight water supply wells have been identified within 1,500 feet of the Southern Information Paper Southern States Cooperative, Inc. GW Incident No. 12547 Page 2 of 2 States Cooperative site. Of these, two have been determined to be currently active. All others have been disconnected and the locations are hooked to city water. The two wells are hydraulically up gradient of the site at distances of roughly 600 and 1,200 feet. Active and inactive wells have been sampled and have not shown petroleum -related compounds such as BTEX. VI. Opinions - Based on the most recent groundwater sampling data and other file information the following statements and opinions can be made: A. The COC's are not contained on site; off site contamination extends to the adjacent property to the south. B. Portions of the petroleum plume associated with releases from the Southern States Cooperative are likely commingled with the petroleum plume associated with the Former Exxon Terminal directly across Jake Alexander Blvd. from the site. C. There is no data indicating groundwater impacts to residential areas in the vicinity.