WI0500507_Permit (Issuance)_20120518

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
Wake County Solid Waste
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. sodium lactate and
Emulsified Oil Substrate (EOS), for the enhanced anaerobic bioremediation of chlorinated
solvents. These injection wells/points will be located at the closed Feltonsville Landfill facility,
6000 Old Smithfield Road, Holly Springs, Wake County, North Carolina, and will be operated in
accordance with the application submitted April 3, 2012, and in conformity with the
specifications and supporting data submitted May 9, 2012, 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 April 30, 2014,
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 May, 2012.
tLo_r_ Charles Wakild, P.E., Director
Division of Water Quality
By Authority of the Environmental Management Commission.
Permit No. WI0500507 PAGE 1 OF 7
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PART I - WELL CONSTRUCTIONGENERALCONDITIONS- —
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 Constr.-notion-Act and is grounds for enforcement action as provided Tor == -_ — __
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 as to have its well cap no less than
two feet' above land surface, and constructed such that water from land surface cannot
migrate into the gravel pack or well screen.
6. Each injection well shall be secured to reasonably insure against unauthorized access and
use. Each well shall be permanently labeled with a warning that it is for injection purposes
and the entrance to each well must be secured with a locking cap.
7. Each injection well shall be afforded reasonable protection against damage during
construction and use.
8. Each injection well shall have permanently affixed an identification plate.
PART II - WELL CONSTRUCTION SPECIAL CONDITIONS
1. At least forty-eight (48) hours prior to constructing each injection well, the Permittee shall
notify the Aquifer Protection Section -Underground Injection Control (UIC) Central Office
staff, telephone number 919-807-6352 and the Raleigh Regional Office Aquifer Protection
Section Staff, telephone number [phone].
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..
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I.1
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. The surface stream shall be monitored during all injection activities, and injection activities
shall cease immediately upon any indication of injectant impacts to the stream, or daylighting
on the surface of the ground, and 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. 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.
4. 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.
5. 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.
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3. At least forty-eight (48) hours prior to the initiation of the operation of the facility for
injection, the Permittee must notify by -telephone -the Aquifer Protection Section-UIC, Central -
Office staff, telephone number 919=807-6352. Notification is-requiied"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.
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. 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 Program
DENR-Division of Water Quality
1636 Mail Service Center
Raleigh, NC 27699-1636
2. The proposed monitoring plan included in the application shall be followed, with the addition
of monitoring at wells MW-8, MW-9, MW-10, MW-19, and MW-29, the addition of sodium
and Total Dissolved Solids to the list of sampling parameters, sampling before injection
begins and quarterly (after injection) for one year, and monitoring the surface stream for the
presence of soybean oil and sodium lactate during the injection activities. All sample results
shallbe 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 ensure 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
lI
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contain monitoring well sampling data, contaminant plume maps and potentiometric surface
maps.
5. The monitoring results and the final project evaluation shall be submitted to:
UIC Program Staff
DWQ — Aquifer Protection Section and
1636 Mail Service Center
Raleigh, NC 27699-1636
DWQ - Aquifer Protection Section
Raleigh Regional Office
1678 Mail Service Center
Raleigh, NC 27699-1678
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 [phone], any of
the following:
(A)Any occurrence at the injection facility which results in any unusual operating
circumstances;
(B) Any failure due to known or unknown reasons, that renders the facility incapable of
proper injection operations, such as mechanical or electrical failures.
7. Where the Permittee becomes aware of an omission of any relevant facts in a permit
application, or of any incorrect information submitted in said application or in any report to
the Director, the relevant and correct facts or information shall be promptly submitted to the
Director by the Permittee.
8. In the event that the permitted facility fails to perform satisfactorily, the Permittee shall take
such immediate action as may be required by the Director.
PART VIII - PERMIT RENEWAL
In order to continue uninterrupted legal use of the injection facility for the stated purpose, the
Permittee must submit an application to renew the permit 120 days prior to its expiration date.
PART IX - CHANGE OF WELL STATUS
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 .0214, 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)A11 casing and screen materials may be removed prior to initiation of abandonment
procedures if such removal will not cause or contribute to contamination of the
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groundwaters.
(B) The entire depth ofeach_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 Program
DENR-Division of Water Quality
1636 Mail Service Center
Raleigh, NC 27699-1636
PART X — WORKER PRECAUTIONS DURING APPLICATION
1. Some effects reported to be associated with the product proposed to be used are as follows:
eye, skin, nose, throat, and lung irritation. Significant inhalation exposure can cause
coughing, wheezing, and shortness of breath. It may cause a skin allergy where very low
exposures can cause itching and a skin rash. 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.
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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-ihat-thecheck valve and the pressure delivery
systems are working properly. - = -
5. The Material Safety Data Sheets should be followed to prevent incompatible or adverse
reactions and injuries.
6. Access to the area of application should be limited to the workers applying the product. In
order to minimize exposure to unprotected individuals, measures should be taken to prevent
access to the area of application.
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DIVISION OF WATER QUALITY
AQUIFER PROTECTION SECTION
May 10, 2012
PERMIT ISSUANCE MEMO
TO: Debra Watts
THROUGH: Thomas Slusser
FROM: David Goodrich
RE: Permit To Inject Sodium Lactate and Emulsified Oil Substrate
Closed Feltonsville Landfill
I recommend that Permit Number WI0500507 be issued to Wake County Solid Waste to inject Sodium Lactate
and Emulsified Oil Substrate to remediate soils and groundwater contaminated with chlorinated solvents and
metals.
SITE DESCRIPTION The site is a closed, unlined county landfill that was closed and capped in 1998.
Methane gas vents were installed in 2004, and groundwater monitoring wells subsequently detected the presence
of chlorinated solvents and other volatile organic compounds at the Compliance Boundary of the facility. It was
determined that natural attenuation alone was not sufficient to address the situation at the site.
HYDROGEOLOGIC DESCRIPTION The site is situated in the Piedmont Physiographic Province and is
underlain by the Chatham Group, near the southeastern edge of the Durham Triassic Basin. A diabase dike cuts
across the landfill in a northwest -southeast orientation, and may locally influence groundwater flow direction in
the bedrock aquifer unit. Native (unaltered) shallow material at the site consists primarily of orange to reddish
brown clayey silt with little coarse to fine sands and partially weathered diabase, and extends from the surface to
a depth of approximately 30 to 35 feet in the treatment area. This is underlain by Triassic Sediments and a
Diabase (bedrock) intrusion. Ground water is encountered at a depth of approximately eight feet. The hydraulic
gradient beneath the site is approximately 2% and the shallow groundwater velocity is estimated to be 0.15 feet
per day (55 feet per year).
EXTENT OF CONTAMINATION The impacted soil and ground water is estimated to be approximately
2,000 feet long, 1,200 feet wide, and have a vertical depth of 40 feet in the unconsolidated Triassic Sediments
(Figures 4 and 5). These dimensions represent an impacted volume of approximately 96 million cubic feet, with
an estimated impacted groundwater volume of approximately 70 million gallons.
PROPOSED INJECTION Two injection events are planned, and they will take place approximately six
months apart. During each event, all five of the proposed permanent injection wells will be used to introduce the
two injectants, which will enhance anaerobic bioremediation by providing food for the native microbes. The
total volume of injectant liquid that will be applied during each event will be approximately 1,210 gallons, and
both events represent a total of 2,420 gallons. This is less than one tenth of one percent of the total estimated
volume of impacted ground water.
HOW IT WORKS The two remedial substances, sodium lactate and emulsified oil substrate (EOS), serve
to promote the degradation of the chlorinated solvent substances by the enhancement of anaerobic
bioremediation. The injectant substances promote anaerobic conditions and provide a source of carbon and
energy to existing microbial populations.

MONITORING The proposed groundwater monitoring plan will be followed, with the recommended
addition of monitoring at wells MW-8, MW-9, MW-10, MW-19 and MW-29, and for the analyses of sodium
and Total Dissolved Solids, for pre -injection sampling and quarterly sampling for one year. The permit also
requires the surface stream to be monitored for the presence of soybean oil and sodium lactate during the
injection procedure. The original plan calls for sampling four existing wells in the immediate vicinity of the
treatment area immediately before injection, one month after injection, two months after injection, and 4 to 5
months after injection. As per the original sampling plan, groundwater samples will be analyzed for pH,
temperature, redox potential, dissolved oxygen, conductivity, turbidity, water level, nitrate, sulfate, ferrous iron,
carbon dioxide, alkalinity, chlorides, chemical oxygen demand, Volatile Organic Compounds, and for dissolved
methane, ethane, and ethane gases. Metabolic acids will be sampled for during the one month sampling event,
and bacteria samples (for size and species) will be taken during the sampling events immediately prior to
injection and at 4 to 5 months after injection.
EPIDEMIOLOGY On April 17, 2000 and October 28, 2003, the DHHS' Epidemiology Branch provided
comments on sodium lactate and EOS for groundwater remediation. Dr. Luanne Williams did not present any
information that would preclude the use of these products for injection, but did provide a health risk analysis and
worker safety precautions, which are in Part X of the attached permit.
REGIONAL OFFICE COMMENTS Eric Rice of the Raleigh Regional Office recommends issuance of this
permit. The Regional Office recommended that a detailed site map be furnished to show the location of each
injection well; that the injection wells be constructed with a stickup so that protection would be furnished
against potential flooding conditions; that the surface stream be monitored during injection in case of injectant
contamination; and that the groundwater sampling plan be amended to include pre -injection sampling and
subsequent quarterly sampling for one year at wells MW-8, MW-9, MW-10, MW-19, and MW-29 for field
parameters (already included), VOCs (already included), sodium, and Total Dissolved Solids. These
recommendations have been addressed and/or included in the permit.