WI0600104_Permit (Issuance)_20130115

DIVISION OF WATER QUALITY
AQUIFER PROTECTION SECTION
January 15, 2013
PERMIT ISSUANCE MEMO
TO: Debra Watts
FROM: Thomas Slusser
RE: Permit To Inject Pepsi Bottling Ventures' Beverage Remediation Product, Sodium B icarbonate,
and Sodium Hexametaphosphate
NCDOT Priority Site #3, Rockingham, Richmond County
I recommend that Permit Number WI0600104 be issued to the NCDOT to inject Pepsi Bottling Ventures' beverage
remediation product, sodium bicarbonate, and sodium hexametaphosphate to remediate groundwater contaminated
with chlorinated solvents.
SITE DESCRIPTION NCDOT Priority Site #3 is the location of a former asphalt plant and testing facility owned
and operated by multiple companies from approximately 1962 to 1973. NCDOT acquired the property for the
widening of US Highway 220 and is now responsible for groundwater contamination associated with the asphalt plant
testing facility and possibly other sources. Site topography is relatively flat except for small mounds of old asphalt
and cut banks from the sand and gravel mining activities. Local topography generally slopes downgradient as the site
sits atop a ridgeline. Currently the site is devoid of structures, has some young trees and other vegetation, and is
occasionally "mined" as a source of sand and gravel. Successful anaerobic bioremediation was conducted in a pilot
test at this site under injection well permit WI0600032. The injectant for that permit was sodium lactate, sodium
hexametaphosphate, and sodium bicarbonate.
HYDROGEOLOGIC DESCRIPTION The site is located in the Sandhills Province of south central NC. The land
surface and injection zone consists of the sand, silt, and clay of the Middendorf Formation, which extends to a depth
of approximately 120 feet below land surface. Below this formation lies chlorite schist of the Piedmont Province.
Average depth to water is 40 feet below land surface. Effective porosity is estimated at 40%. Based on previous
injections conducted under permit WI0600032, gravity feed injection rates were observed of 10-25 gallons per
minute. Groundwater flow is highly variable due to cross -bedded sands riddled with layers and lenses of sandy clay,
koalinite clay, gravel, and sandstone cemented with iron -manganese oxides. Groundwater flow is estimated to range
from 0.5-29 ft/day. Since the site sits on top of a groundwater recharge zone, the vertical hydraulic gradient is
roughly 5x the horizontal hydraulic gradient.
EXTENT OF CONTAMINATION As of June 2011, the contaminant plume was at least 1000 feet long and 400 feet
wide, with contamination extending east, southeast, and south beneath US Highway 220 for several hundred feet from
the site. See Figure 278 for details. Depth of water and groundwater contamination is approximately 30 feet and 90
feet, respectively, below land surface at injection well 3-IW-1. See Figures 279 and 280 for details.
PROPOSED INJECTION Pepsi Bottling Ventures' Beverage Remediation Product, sodium bicarbonate, and sodium
hexametaphosphate are to be injected several events and via several existing and proposed injection wells. Injection
and monitoring activities will take place throughout roadway construction processes. Injection and monitoring wells
will need to be abandoned and reinstalled throughout the roadway construction process. Injections will occur in three
separate treatment zones with a total acreage of approximately 7.5 acres or 326,700 feet2; see Figures 312-314 for
details. No contaminant plume displacement is anticipated based on the phased injection and monitoring schedule
and aquifer properties. As demonstrated during the pilot test conducted under permit WI0600032, no injection
pressures were necessary since the formation readily accepted the injectant at rates of 10-25 gallons per minute.

HOW IT WORKS Sodium hexametaphosphate provides phosphate nutrient that is essential for cell growth and
microbial reproduction. Sodium bicarbonate provides buffering capacity for the acid that is produced as part of the
remediation process. Pepsi Bottling Ventures' Beverage Remediation Product consists of approximately 89.5%
water, 10% high -fructose corn syrup, and 0.5% of various food -grade additives used for flavoring, color, stability,
etc., several of which have already been approved for use by DHHS. The high -fructose corn syrup content is
desirable for providing a carbon substrate/energy source for the naturally occurring microbes that have demonstrated
ability to degrade TCE and daughter products via anaerobic bioremediation.
MONITORING The proposed monitoring plan shall be followed. Quarterly monitoring will be conducted
during injections and for a year afterwards; thereafter, biannual (twice a year) sampling will be conducted.
Parameters include water levels, pH, redox potential, temperature, conductivity, dissolved oxygen, volatile organic
compounds, total organic carbon, methane, ethane, ethane, chloride, phosphate, total metals, and dissolved metals.
The monitoring well network and plan are quite extensive and complicated given the episodic abandonment and
reinstallation of wells that will occur throughout the roadway construction process. The monitoring plan is detailed in
tables �308 of the permit application package.
EPIDEMIOLOGY On March 22, 2012, the DHHS' Epidemiology Branch provided comments on Pepsi Bottling
Ventures' Beverage Remediation Product for groundwater remediation. Dr. Ken Rudo did not present any
information that would preclude the use of these products for injection but will use the results of this product's
performance monitoring data to make a final evaluation on the suitability of this product for remediation purposes
statewide.
REGIONAL OFFICE COMMENTS Staff of the Fayetteville Regional Office recommend issuance of this permit. FRO
recommended the addition of three items to the permit. The two regarding well construction tags were not included
because compliance issues with existing wells are addressed separately from the permitting process, and the
requirement for well construction tags for injection wells is already included in the standard permit language.

•
Figure 315. Conceptual Diagram of Surface and Subsurface Portions of the
Injection System
10,000 gallon of recovered softdrinks from Pepsi Bottling
Ventures North Carolina Facilities with HFCS content of
approximately 1 lb per gallon.
Primary
Gravity Feed from Tank
1,000 gal Poly -Tanks with following solution:
Mix recovered softdrink with 350 lbs of Na-Bicarbonate,
50 lbs of Na-Polymetaphosphate
in 1,000 gallon poly -lank to produce
1,000 gal. of solution with approximately 10% HFCS by
weight, 518 mmoles/l of bicarbonate,
and 10 mmoles/I of polymetaphosphate.
See Tables 280through 290 for injection volumes.
a
u
0
a
u
a
60 f1
110 It
co
10ft
60
Pressure Gauge
Secondary j
' Pumped from
I Mixer (<50 PSI) if
required
I I
'Proposed Antecedent Injection Wells:
3-MW-1, 3-MW-2, 3-MW-3, 3-MW-3D, 3-MW-5, 3-
MW-6, 3-MW-7, 3-MW-8, 3-MW-9, 3-MW-I0, 3-MW-
12, 3-MW-13, 3-MW-I6, 3-MW-17, 3-MW-18, 3-MW-
19, 3-MW-20, and 3-IW-1
See Table 291 for well depths and screen intervals.
See Figure 311. Note that some wells will be
abandon after the Antecedent Injection to
accommodate future road construction work.
New injection wells for Treatment Zones 1, 2, and 3.
All injection wells will be in nested pairs. Each nest well pair will include a shallow well a deep well completed to depths of 60 feet
bsg and 110 feet bsg, respectively. All shallow wells will be constructed with S0 feet of 4-inch 20 slot schedule 40 PVC screen
and 10 fl of 4-inch schedule 40 PVC riser. The sand pack will consist of- #3 gravel from 80.5 feet bsg to 8 feet bsg. The hydrated
bentonite seal will extend from 8 feet bsg to 6 feel bsg and a portland/bentonite grout will extend from 6 feet bsg to 2 feet bsg.
A concrete collar will be installed from 2 feel bsg ot 0 feet bsg and completed at the surface with a locking flush grade or stickup
vault as appropriate for the expected conditions around the well. All deep wells will be constructed with 80 feet of 4-inch 20 slot
schedule 40 PVC screen and 60 ft of 4-inch schedule 40 PVC riser. The sand pack will consist of - #3 gravel from 110.5 feet bsg to
48 feet bsg. The hydrated bentonite seal will extend from 48 feet bsg to 46 feet bsg and a portand/bentonile grout will extend from
44 feet bsg to 4 feet bsg. A concrete collar will be installed from 2 feet bsg ot 0 feet bsg and completed at the surface with a locking
flush grade or stickup vault as appropriate for the expected conditions around the well.
New Treatment Zone 1 injection wells will include 3-IW-25/3-IW-2D, 3-1W-3S/34W-3D, 3-IW-43/3-IW-4D, 3-IW-5S/3-IW-5D, and
3-IW-65/3-IW-6D. Tables 281, 282, and 283 list the injection schedule volumes, and masses of reagents. Figare 312 shows proposed
new injection well locations.
New Treatment Zone 2 injection wells will include 3-IW-7S/3-IW-7D, 3-IW-83/3-IW-8D, 3-IW-95/3-1W-9D, 34W-10S/34W-10D,
3-IW-11S/3-IW-11D, 3-IW-123/3-IW-I2D, 3-IW-135/3-IW-13D, 3-1W-14S/3-IW-14D, and 3-IW-15S/3-IW-15D. Tables 284, 285, and 288
list the injection schedule volumes, and masses of reagents. Figure 312 shows proposed new injection well locatons.
New Treatment Zone 3 injection wells will include 3-IW-165/3-IW-16D, 3-IW-17S/3-IW-17D, 3-IW-18S/3-IW-18D, and 3-IW-19S/3-IW-19D.
Tables 287, 288, and 289 list the injection schedule volumes, and masses of reagents. Figure 312 shows proposed
new injection well locations.
Injectate concentration and volumes will be as speed in Tables 281 through 289 unless empirical observations during the
remediation program indicate need for adjustment.
F-315

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
NC Department of Transportation
FOR THE CONSTRUCTION AND OPERATION OF IN SITU REMEDIATION INJECTION
WELLS, defined in Title 15A North Carolina Administrative Code 2C .0209(5)(b)(viii), to inject
Pepsi Bottling Ventures' Beverage Remediation Product, sodium hexametaphosphate, and
sodium bicarbonate, for the anaerobic bioremediation of chlorinated solvents. These injection
wells/points will be located at NCDOT Priority Site #3, located at the southwest corner of the
intersection of US Hwy.,220 and Sandy Ridge Church Road in Rockingham, Richmond County,
North Carolina, and will be operated in accordance with the application submitted October 25,
2012, 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 December 31,
2017, and shall be subject to the specified conditions and limitations set forth in Parts I through
X hereof.
Permit issued this the 18th day of January, 2013.
Charles Wakild, P.E., Director
Division of Water Quality
By Authority of the Environmental Management Commission.
Permit Mn Wtt16M1 nd
neap 1 nr.Z

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 isfor 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 Central Office staff, telephone number 919-807-6412,
and the Fayetteville Regional Office Aquifer Protection Section Staff, telephone number 910-
433-3300.
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. WI0600104 PAGE 2 OF 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 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 Central
Office staff, telephone number 919-807-6412, and the Fayetteville Regional Office Aquifer
Protection Section Staff, telephone number 910-433-3300. •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.
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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. 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 Fayetteville
Regional Office and the Raleigh Central Office quarterly or semiannually in pace with the
approved monitoring plan. 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. The monitoring results and final project evaluation shall be submitted to:
UIC Program Staff
DWQ — Aquifer Protection Section and
1636 Mail Service Center
Raleigh, NC 27699-1636
DWQ - Aquifer Protection Section
Fayetteville Regional Office
225 Green Street, Suite 714
Fayetteville, NC 28301-5043
Permit No. WI0600104
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 Fayetteville Regional Office, telephone number 910-433-3300, 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 VHI - PERMIT RENEWAL
In order tb 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 shall 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.
(D)Drilled wells shall be completely filled with cement grout or bentonite grout, which
Permit No. WI0600104 PAGF s nF 6

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 We11 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 the
addresses given in Part VII.6 above.
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.
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