WI0700459_Permit (Issuance)_20170914

Water Resources
Environmental Quality
September 14, 2017
Steven Walton
West Pharmaceutical
530 Herman O. West Drive
Exton, PA 19341
Re: Issuance of Injection Permit WI0700459
Former West Pharmaceutical Facility
Lenoir County, NC
Dear Mr. Walton:
ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
S. JAY ZIMMERMAN
Director
In accordance with the permit application received on July, 18, 2017, and additional information received on
September 6, 2017 we are forwarding permit number WI0700459. This permit is to inject ABC and
dehalococcoides to remediate groundwater contaminated with VOCs at the Former West Pharmaceutical
Facility, 2525 Rouse Road Extension, Kinston, Lenoir County, NC 28505.
This permit shall be effective from September 14, 2017, until August 31, 2022, and shall be subject to the
conditions and limitations stated therein, including the requirement to submit a Final Project Evaluation (FPE) 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.
Please note the following:
• Per permit condition Part VI.1, the proposed monitoring plan (provided in page 11 of the attachment)
received on July 18, 2017. shall be followed
• Per permit condition Part VI.5, prior to closing this permit, the Pennittee must meet groundwater quality
standards or pre -injection levels, whichever concentration is higher, for all of the injection constituents;
otherwise, continued monitoring as approved in the monitoring plan will be required until such levels
can be established; -
• Per permit conditions Part VI.3 &4, and IX.2(G), within 30 days after each injection event, please
provide the well construction (if not previously submitted) and injection information on the applicable
forms listed below. Note: if well construction/abandonment information is essentially the same (e.g.,
direct push points or geo-probes), then only one GW-1 or GW-30 form is needed. Just indicate in the
comments section on the form the total number of well points. These forms are available on the
Division of Water Resources' website at htto://deq.nc.eov/about/divisions/water-resources/water-
resources-permits/wastewater-branch/ground-water-protection/ground-water-reporting-forms
!� N atF�ing Compares -
State of North Carolina I Environmental Quality I Division of Water Resources
Water Quality Regional Operations Section
1636 Mail Service Center Raleigh, North Carolina 27699-1636
919-707-9129

> Injection Event Record
> Well Construction Record (GW-1)
> Well Abandonment Record (GW-30)
In order to continue uninterrupted legal use of this well for the stated purpose, you should submit an application
to renew the permit 120 days prior to its expiration date. As indicated in the permit, this permit is not transferable
to any person without prior notice to, and approval by, the Director of the Division of Water Resources. If you
have any questionsregarding your permit or the Underground Injection Control Program please call me at (919)
807-6406.
Best Regards,
91ffaac ia
Shristi Shrestha
Underground Injection Control (UIC) - Hydrogeologist
Division of Water Resources
Water Qualify Regional Operations Section
cc: Randy Sipe, WQROS — Washington Regional Office
Central Office File, W10700459
Rick Tarravechia, ERM NC, Inc., 15720 Brixham Hill Avenue, Suite 120, Charlotte, NC 28277

NORTH CAROLINA
ENVIRONMENTAL MANAGEMENT COMMISSION
DEPARTMENT OF ENVIRONMENTAL QUALITY
RALEIGH, NORTH CAROLINA
PERMIT FOR THE USE 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
Former West Pharmaceutical Services Facility
Lenoir County
FOR THE CONSTRUCTION AND/OR OPERATION OF 50 (Fifty) IN SITU REMEDIATION
INJECTION WELLS, defined In Title 15A North Carolina Administrative Code 2C
.0209(5)(b)(viii), to inject the following additives (either individually or in combination): ABC
and dehalococcoides, for the remediation of groundwater contaminated with volatile organic
compounds (VOCs) products. These injection wells/points will be located at the Former West
Pharmaceutical Facility, 2525 Rouse Road Extension, Lenoir County, Kinston NC 28504, and will
be operated in accordance with the application submitted July 18, 2017, and in conformity with
the specifications and supporting data submitted September 6, 2017, all of which are filed with the
Department of Environmental Quality and are considered a part of this permit.
This permit is for Construction and Operation only,�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 02C .0100 and
.0200, and any other Laws, Rules, and Regulations pertaining to well construction and use.
Permit issued this the 14th day of September 2017.
J Li-14A
fS. Jay Zimmerman, Director
Division of Water Resources
By Authority of the Environmental Management Commission.
Permit No. WI00700459
ver. 2-25-2016 UIC-51/5T
PAGE 1 OF 7

PART I — PERMIT GENERAL CONDITIONS
1. The Permittee shall 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).
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 [15A
NCAC 02C .0211(1)].
3. This permit is valid only for construction or operation 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 Division of Water Resources (DWR) [15A NCAC
.0211(a)].
4. This permit is not transferable without prior notice and approval. In the event there is a desire
for the facility to change ownership, or there is a name change of the Pemuttee, a formal permit
amendment request and any supporting materials must be submitted at least 30 days prior to
the date of the change [15A NCAC 02C .0211(q)].
5. 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 [15A NCAC 02C .0203].
PART II - WELL CONSTRUCTION GENERAL CONDITIONS
1. Each injection well shall not hydraulically connect separate aquifers [15A NCAC 02C
.0211(c)].
2. Multi -screened wells shall not hydraulically connect different aquifers or zones having
differences in water quality that would result in a degradation of any aquifer or zone [15A
NCAC 02C .0225(g)(17)].
3. Each injection well shall be constructed in such a manner that water from land surface cannot
migrate into the gravel pack or well screen [15A NCAC 02C .0225(g)(4)].
4. 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. [15A NCAC .0225(g)(8)].
5. Each injection well shall be secured to reasonably insure against unauthorized access and use.
Each well shall be permanently labeled with a waming that it is for injection purposes and the
entrance to each well shallbe secured with a.locking cap .as defined in G.S. 87-85(16) [15A
NCAC 02C .0225(g)(23)].
Permit No. W100700459 PAGE 2 OF 7
ver. 2-25-2016 UIC-5I/5T

6. Each injection well shall be afforded reasonable protection against damage during construction
and use [15A NCAC 02C .0225(i)(3)].
7. Each permanent injection well shall have a permanently affixed identification plate [15A
NCAC .0225(g)(20)].
8. A copy of the completed Well Construction Record (Form GW-1) shall be submitted as
described in Part VI.3 of this permit (the original document goes to the address indicated on
the form).
PART III - WELL CONSTRUCTION SPECIAL CONDITIONS
1. At least forty-eight (48) hours prior to constructing or operating each injection well, the
Permittee shall notify the Underground Injection Control (UIC) Central Office staff, telephone
number 919-807-6406, and the Washington Regional Office staff, telephone number 252-946-
6481 [15A NCAC 02C .0211(k)].
PART IV - OPERATION AND USE CONDITIONS
1. 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 [15A NCAC 02C
.0211(j)].
2. The issuance of this permit shall not relieve the Permittee of the responsibility for damages
to surface water or groundwater resulting from the operation of this facility [15A NCAC 02C
.0206].
3. The injection facility shall be properly maintained and operated at all times to achieve
compliance with the conditions of this permit and the rules of 15A NCAC 02C .0200, even
if compliance requires a reduction or elimination of the permitted activity [15A NCAC 02C
.0211(j)].
4. 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 that may be required, such as the repair,
modification, or abandonment of the injection facility [15A NCAC 02C .0206].
Permit No. WI00700459 PAGE 3 OF 7
ver. 2-25-2016 UIG51/5T

PART V - INSPECTIONS [15A NCAC 02C .0211(k)]
1. Any duly authorized officer, employee, or representative of the Division of Water Resources
(DWR) 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. DWR 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 VI - 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 to
ensure surface water and groundwater protection may be established and an acceptable
sampling reporting schedule shall be followed [15A NCAC 02C .0225(j)].
2. All sample results shall be submitted to the WQROS Central Office and Washington Regional
Office. Monitoring reports shall include, at a minimum, analytical data and an update on the
status and location of monitoring and injection wells. Well locations maybe given in a table
3. with the name and geographic coordinates or shown on an updated version of the site map
[15A NCAC 02C .0225(k)(2)]..
4. Records of well construction, repair, _or abandonment shall be submitted within 30 days of
completion of such activities [15A NCAC 02C .0225(k)(1)(A)].
5. An Injection Event Record shall be submitted within 30 days of each injection event [15A
NCAC 02C .0225(k)(1)(B)].
6. The Pemuttee shall submit a Final Project Evaluation (FPE) within 9 months after completing
all injection -related activity associated with this permit or produce an interim evaluation to be
submitted with a renewal application for this permit. Both the fmal project evaluation and
interim evaluation shall contain historical monitoring data and updated contaminant plume and
potentiometric surface maps. PLEASE NOTE: Injectants and related reaction byproducts must
attenuate to pre -injection concentrations or groundwater standards specified in rule 15A NCAC
02L .0202 whichever is greater, in order for this permit to be closed. Otherwise, corrective
action as described in Part VII may be required [15A NCAC 02C .0225(k)(2)].
Permit No. WI00700459 PAGE 4 OF 7
ver. 2-25-2016 UIC-5I/5T

7. All monitoring results, forms, and reports required in this Part shall be submitted to:
UIC Program
NC Division of Water Resources and
1636 Mail Service Center
Raleigh, NC 27699-1636
Water Quality Regional Operations Section
DWR Washington Regional Office
943 Washington Square Mall
Washington, NC 27889
7. The Permittee shall report any monitoring or other information that indicates noncompliance
with a specific permit condition, that a contaminant may cause a violation of applicable
groundwater quality standards, or that a malfunction of the injection system may cause the
injected fluids to migrate outside the approved injection zone or area. As specified in rule
15A NCAC 02C .0211(r), noncompliance notification shall be as follows:
(A)
(B)
(C)
Oral notification shall be given within 24 hours of the occurrence, or first knowledge
of the occurrence, to the Washington Regional Office, telephone number 252-946-
6481.
Written notification shall be made within five days of the occurrence and submitted
to the addresses in Item #6 above.
The written notification shall contain a description of the noncompliance and its
cause; the period of noncompliance, including dates and times; if the noncompliance
has not been corrected, the anticipated time it is expected to continue; and any steps
taken or planned to reduce, eliminate, and prevent reoccurrence of the
noncompliance.
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 [15A NCAC 02C .0211(b)].
PART VII - CORRECTIVE ACTION [15A NCAC 02C .0206]
1. Any injection well not constructed or operated in accordance with this permit, or the criteria
and standards specified in 15A NCAC 02C .0200, shall be subject to corrective action as
provided under rule 15A NCAC 02C .0206.
2. The following corrective actions shall apply to elevated concentrations of injectants or reaction
byproducts resulting from the permitted injection activity:
(A) Continued monitoring until concentrations return to pre -injection values or meet the
standards specified in 15A NCAC 02L .0202, whichever are greater. The frequency,
duration, and location of monitoring shall be appropriate for site specific conditions and
potential receptors.
(B)
Groundwater quality parameters that do not attenuate as described in 2(A) above may
warrant a corrective action plan as provided under rule 15A NCAC 02C .0206, depending
on the type, concentration, and distribution of the groundwater quality standards being
exceeded.
Permit No. WI00700459 PAGE 5 OF 7
ver. 2-25-2016 UIC-5115T

PART VIII - PERMIT RENEWAL [15A NCAC 02C .0211(b)]
In order to continue uninterrupted legal use of the injection facility for the stated purpose, the
Permittee should submit an application to renew the permit 120 days prior to its expiration date.
PART IX - CHANGE OF WELL STATUS [15A NCAC 02C .0240]
1. The Permittee shall provide written notification within 15 days of any change of status of an
injection well. Such a change would include the discontinued use of a well for injection. If a
well is taken completely out of service temporarily, the Permittee must install a sanitary seal.
If a well is not to be used for any purpose that well must be permanently abandoned according
to 15A NCAC 2C .0240, Well Construction Standards.
2. When operations have ceased at the facility and a well will no longer be used for any purpose,
the Permittee shall abandon that injection well in accordance with the procedures specified in
15A NCAC 2C .0240, including but not limited to the following:
(A)All casing and screen materials maybe 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 WQROS staff' 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 .0225(k)(1)(A) within 30 days of completion of abandonment.
Permit No. WI00700459 PAGE 6 OF 7
ver. 2-25-2016 UIC-5I/5T

3. The written documentation required in Part IX (1) and (2)(G) shall be submitted to:
UIC Program
DEQ-Division of Water Resources
1636 Mail Service Center
Raleigh, NC 27699-1636
PART X — WORKER PRECAUTIONS DURING APPLICATION [15A NCAC 02C
.0225(a)]
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 orliquid particles (e.g., grinding, blending,
vigorous shaking or mixing), then proper personal protective equipment should be used. The
application process should be reviewed by an industrial hygienist to ensure that the most
appropriate personal protective equipment is used.
2. Persons working with these products should wear goggles or a face shield, gloves, and
protective clothing. Face and body protection should be used for anticipated splashes or
sprays.
3. Eating, drinking, smoking, handling contact lenses, and applying cosmetics should not be
permitted in the application area during or immediately following application.
4. Safety controls should be, in place to ensure that the check valve and the pressure delivery
systems are working properly.
5. The Material Safety Data Sheets should be followed to prevent incompatible or adverse
reactions and injuries.
Permit No. WI00700459 PAGE 7 OF 7
ver. 2-25-2016 UIC-5I/5T

DIVISION OF WATER RESOURCES
WQROS
September 6, 2017
MEMORANDUM
TO: FILE / Debra Watts
FROM: Shristi Shrestha
RE: Issuanceof permit to inject (Permit #WI0700459)
Former West Pharmaceutical Facility
Lenoir County
I recommend that Permit Number WI0700459 be issued to the above to inject the following additive(s) to remediate
groundwater (GW) contaminated with Volatile Organic Compounds: ABC with dehalococcoides.
SITE DESCRIPTION: The West site was involved in production of specialty rubber products since 1975 and ceased
manufacturing in January 2003 after an explosion occurred at the site. West entered an Administrative Order on Consent
(AOC) with USEPA for management of site investigation activities. A comprehensive site assessment of the environmental
impacts of fire incident was required as a condition of AOC. Based on assessment activities following the fire, halogenated
VOC's were detected in site groundwater (Page 2 of application).
HYDROGEOLOGIC DESCRIPTION: The Kinston area, including the subject site, is located within the Atlantic Coastal Plain
province of North Carolina. The Ethology of the Coastal Plain province generally consists of unconsolidated sediments and
sedimentary rocks deposited on top of crystalline basement rocks.
The surface water bodies within ''/ mile of the site are an unnamed stream which is a tributary of Briery Run Creek. The
stream is in proposed injection area. The depth to groundwater varies across the site from 0.5 to 6 ft bgs and is generally to
east-southeast, towards two drainage ditches located on the perimeter of the site. Based on observations during remedial
investigation well installation and routine water level measurements, the shallow aquifer is unconfined. Based on rising
head slug tests, hydraulic conductivities at the site range from 0.19 to 3.3 feet per day in the shallow unconfined aquifer
zone and 0.07 to 0.24-feet per day in deeper confined aquifer zone. The hydraulic conductivities determined for shallow
aquifer are within range typical of silty and fine sands. The calculated groundwater velocity in the shallow aquifer at the
site is approximately 4.05 feet per year. (refer to page 9, fig 3).
EXTENT OF CONTAMINATION: The groundwater contamination plume is located on the south-east side of the Former West
Facility. It is approximately 413ft in length and 375ft in width. As shown in the cross section the contamination is located
above the clay layer. (Refer Figure 2, 4, 5, 8, 9).
PROPOSED INJECTION: The injection will take place in source area from 5-15 below land surface. It is proposed to inject
around 8,000 gals of ABC with dehalococcoides and 17,000 gals of water into 50 injection points. A breakdown of the
injection events is listed in the table below. (refer to page 4, 11 and Fig 5)
INJECTION WELLS
DPT points
Total
Gallons over
1 Event(s)
Total volume in 1 well
Average volume / well/day
50
25,000
500
-- 42 gals
How IT WORKS• The proposed in -situ bioremediation method consists of injecting Anaerobic BioChem (ABC) and
Dehaloccoccoides (DHC) bacteria into the aquifer. ABC is a mixture of lactate, fatty acids and a phosphate buffer. It proves
food for the microorganism for the dehalorespiring bacteria so it can actively reduce chlorinated compounds to organic
compounds such as ethane and ethene. DHC help to reduce daughter product vinyl chloride to ethene (refer to page 10).

MONITORING: A detailed monitoring plan is presented in page 11 of the application. See attached.
EPIDEMIOLOGY: The DHHS has approved the injectant(s).
REGIONAL OFFICE COMMENTS:
The Washington Regional Office recommends permit issuance.

Attachment 4 — Injection Procedure
The injection event will include 50 injection points placed on approximately 30-foot centers. The injection points will be
advanced via direct -push technology (DPT) to a depth of approximately 15 feet below ground surface (bgs). The
concentrated ABC® solution will be batch mixed in a 500-gallon tank for injection into the subsurface. Water obtained
from the municipal water system will be used to prepare the ABC® solution. Fluids will be injected into each of the
injection wells by connecting the tank of mixed injectant to the DPT well via cam -lock fittings and flexible hoses. Then
fluids will be injected into the top of the well and will flow through the well screen and into the surrounding aquifer. The
injection will be performed using a pump capable of generating up to 100 pounds per square inch pressure (psi). The
anticipated injection pressure is 40-100 psi depending on site -specific conditions. The actual injection pressure will be
determined in the field based on site -specific conditions. The injection event is expected to last 10 to 12 days. A map of
the general locations of the injection points per event is provided in Figure 5.
Attachment 5 — Fracturing Plan
Not Applicable — Application is not for fracturing.
Attachment 6 — Well Construction Details
Fifty injection points will be advanced via temporary direct -push methods to a depth of approximately 15 feet. The
injection will be performed directly through the DPT drill rods and attached 5-foot stainless steel well screen. No
temporary PVC wells will be installed. Injection will occur on 5 foot vertical intervals between 5 and 15 ft bgs at each
location. A schematic of DPT construction details (temporary wells) used for the injection points are include as Figure
10.
Attachment 7 — Monitoring Plan
During the remediation project, groundwater samples will be collected from existing and proposed monitor wells within
the treatment area at the site. Prior to injection, baseline groundwater samples will be collected from each of the wells
referenced below including 4 new additional monitor wells (MW-16 through MW-19). Following the baseline sampling
event, quarterly sampling will be conducted in each of the wells for the first year post injection. Groundwater samples will
be collected semi-annually for year 2 following the injection and then annually thereafter, or until a new plan is proposed.
A summary of the monitoring plan is provided in the following table.
Summary of Groundwater Monitoring Plan
Wells
Sample Frequency Parameters
Year I Year Years VOCs TOC Iron Mn SO4 NO3 Field
2 3+ Parameters
MW-9 BL/Qrtly SA AN X X X X X X X
MW-10 BL/Qrtly SA AN X X X X X X X
MW-11 BL/Qrtly SA AN X X X X X X X
MW-13 BL/Qrtly SA AN X X X X X X X
MW-16 (p) BL/Qrtly SA AN X X X X X X X
MW-17 (p) BL/Qrtly SA AN X X X X X X X
MW-18 (p) BL/Qrtly SA AN X X X X X X X
MW-19 (p) BL/Qrtly SA AN X X X X X X X
BL = Baseline VOCs = Volatile organic compounds TOC = Total Organic Compounds Mn = Manganese
(p) proposed by EPA 8260B S0a2 = Sulfate
Qrtly = Quarterly AN = Annually
SA = Semi Annually NO3 = Nitrate
Field Parameters: oxygen reduction potential (Eh), pH, dissolved oxygen (DO) temperature, and specific conductance
Attachment 8 — Well Tabulation Data
Well construction details and groundwater contaminant concentrations for existing monitoring wells within the injection
area are summarized below.
In -Situ Groundwater Remediation Application Rev. 3-1-2016 Page 11 of 14

Permit No. WI D 1O O QS
Date:
.g?/zi / /,7-
Applicant/Facility: Pl/P-a.t" pkovfrmClcptatcpi / %moo-tnWn In42S IDAar~acttr:CCL:
Fa
DTW: O' 5 • G f-t-
GW Flow Direction: Fad — SSccs.t,±hta„±
MWs installed in same aquifer as injection? V - ; Inj. zone: S-1 S (o5iU S MW zone: 8 8 fr-- . LIs
Comments:
Groundwater Flow Rate:
HC X gradient(FT?) = flow rate/DAY(?) X 365 =
SY or porosity (—.30)
Calculations for potential contaminate displacement:
FT/YR
Reported: L/- S (S Ft/yr
2SOXiier2X 7t X
425, boo
/27, Soo
25, 000
gallons of injectant =
gallons of water in void sp
height = .4/-25, O O O C.F.
CF X 013 SY or porosity (i.e. —.30) = 1 2 7,SO 0 CF of available void space
CF of available void sp X 7.48 gallons = 9 5 3 3O O gallons of water in void space
= 2.62 /.
O 2 (o % of fluid displaced by injectant (move decimal)
2 62f•
Potential displacement of plume by injection: V efl yt teext
S:\APS\Shared for APS\Groundwater Protection\WELLS INJECTION PROGRAM \APPLICATIONS and FORMS\51 Calculations
and Checklist Worlsheet.doc Ver. 5/24/10

Notes
RO supervisor signed Staff Report and approves permit issuance?
Dimension of plume in Memo?
Total the amount of injectant in Memo?
Monitoring frequency in Memo?
Potential for contaminant plume migration in Memo?
RO's concerns addressed in Memo itemize. if necessary)?
Total amount of injectant broken down per well, per day, event, etc: in Memo?
S:\APS\Shared for APS\Groundwater Protection\WELLS_INJECTION PROGRAM\APPLICATIONS and FORMS\51 Calculations
and Checklist Worksheetdoc Ver. 5/24/10