WQ0029385_Final Permit_20061103

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Michael F. Easley, Governor
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William G. Ross Jr,, Secretary
rNorth
Carolina Department of Environment and Natural Resources
Alan W. Klimek, P.E. Director
Division of Water Quality
November 3, 2006
MR. STEVE E. JOHNSON
WESTON SOLUTIONS, INC.
1400 WESTON WAY
WEST CHESTER, PA 19380
Subject: Permit No. WQ0029385
Weston Solutions, Inc.
Groundwater Remediation Facilities
Guilford County
Dear Mr. Johnson:
In accordance with your permit application received October 5, 2005, and subsequent additional
information received, we are forwarding herewith Permit No. WQ0029385, dated September 21, 2006, to Weston
Solutions, Inc. for the construction and operation of the subject groundwater remediation facility.
This permit shall be effective from the date of issuance until May 19, 2011, and shall be subject to the
conditions and limitations as specified therein. Please pay particular attention to the monitoring requirements in this
permit. Failure to establish an adequate system for collecting and maintaining the required operational information
will result in future compliance problems.
If any parts, requirements, or limitations contained in this permit are unacceptable, you have the right to
request an adjudicatory hearing upon written request within thirty (30) days following receipt of this permit. This
request must be in the form of a written petition, conforming to Chapter 150B of the North Carolina General
Statutes, and filed with the Office of Administrative Hearings, 6714 Mail Service Center, Raleigh, NC 27699-6714.
Unless such demands are made this permit shall be final and binding.
6164.
If you need any additional information concerning this matter, please contact Peter Pozzo at (919) 715-
Sincerely,
I ILL,
1.4Jz_N
AAAlan W. Klimek, P.E.
cc: Guilford County Health Department
Winston-Salem Regional Office, Aquifer Protection Section
Technical Assistance and Certification Unit
APS — Central Files
None Carolina
Nturallb,
Aquifer Protection Section 1636 Mail Service Center Raleigh, NC 27699-1636 Phone [phone] Customer Service
Internet: http://h2o.enr.statr.nc.us 2728 Capital Boulevard Raleigh, NC 27604 FAX [phone]
An Equal opporlunitylAffirmaEve Action Employer — 50% Recycledll O% Post Consumer Paper

NORTH CAROLINA
ENVIRONMENTAL MANAGEMENT COMMISSION
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
GROUNDWATER REMEDIATION PERMIT
In accordance with the provisions of Article 21 of Chapter 143, General Statutes of North Carolina as amended,
and other applicable Laws, Rules, and Regulations
PERMISSION IS HEREBY GRANTED TO
Weston Solutions, Inc.
Guilford County
FOR THE
construction and operation of a 28,800 GPD groundwater remediation facility consisting of a recirculation in -situ
bioremediation system and hydraulic containment system to remediate chlorinated solvent contamination, with no
discharge of wastes to the surface waters, pursuant to the application received October 5, 2005, and subsequent
additional information received by the Division of Water Quality (Division), and in conformity with the project
plan, specifications, and other supporting data subsequently filed and approved by the Division and considered a
part of this permit.
This permit shall be effective from the date of issuance until May 19, 2011 and this permit supersedes the
permit issued May 19, 2006, and shall be subject to the following specified conditions and limitations:
I. PERFORMANCE STANDARDS
The Raleigh Central Office, telephone number [phone], and Winston-Salem Regional Office,
telephone number [phone], shall be notified at least forty-eight (48) hours in advance of operation
of the installed facilities so that an in -place inspection can be made. Such notification to the regional
supervisor shall be made during the normal office hours from 8:00 a.m. until 5:00 p.m. on Monday
through Friday, excluding State Holidays.
2. Performance monitoring goals are provided in Table 1. The treated water discharged into the injection
wells must not cause a violation of Class GA Standards for any constituent beyond the Compliance
Boundary, nor cause the migration of the contamination into unaffected areas. If the treatment system
fails to consistently achieve this standard, additional treatment units or changes in operational needs may
be required.
3. This permit shall become voidable if the soils fail to adequately assimilate the remaining wastes and may
be rescinded unless the facilities are installed, maintained, and operated in a manner, which will protect
the assigned water quality standards of the surface and groundwaters.
4. The issuance of this permit shall not relieve the Permittee of the responsibility for damages to surface or
groundwaters resulting from the operation of this facility.
WQ0029385 Page 2 of 7

Any residuals generated from these treatment facilities must be disposed in accordance with General
Statute 143-215,1 and in a manner approved by the Division,
6. Injection of untreated groundwater outside the designated in -situ bioremediation treatment area is
prohibited.
H. OPERATION AND MAINTENANCE REQUIREMENTS
The facilities shall be properly maintained and operated as a non -discharge system to prevent the
discharge of any wastewater resulting from the operation of this facility. The groundwater recovery,
treatment and disposal system shall be inspected monthly. If it is determined that the system is
malfunctioning or leading to the release of wastes to the environment, a threat to human health, or a
nuisance, all repairs should be made as soon as possible and reported to the Winston-Salem Regional
Office (see Section VI. NONCOMPLIANCE NOTIFICATIONI, All components of the groundwater
recovery, treatment, and disposal system shall be properly weatherproofed to prevent freezing and failure
of the system.
2. Upon classification of the wastewater treatment and remediation facilities by -the Water Pollution Control
System Operators Certification Commission (WPCSOCC), the Permittee shall designate and employ a
certified operator to be in responsible charge (ORC) and one or more certified operator(s) to be back-up
ORC(s) of the facilities in accordance with 15A NCAC 8G .0201. The ORC shall visit the facilities in
accordance with 15A NCAC 8G .0204 or as specified in this permit and shall comply with all other
conditions specified in these rules,
If requested by the owner, the Division will consider remote monitoring in lieu of (frequency) physical
inspections, on a case -by -case basis, following at least two years of successful operation.
4. The Permittee shall maintain an inspection log or summary including at least the date and time of
inspection, observations made, and any maintenance, repairs, or corrective actions taken by the Permittee.
This log of inspections shall be maintained by the Permittee for a period of three years from the date of
the inspection and shall be made available to the Division or other permitting authority, upon request.
Any duly authorized officer, employee, or representative of the Division may, upon presentation of
credentials, enter and inspect any property, premises or place on or related to the disposal site or 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 leachate.
III. WELL CONSTRUCTIONlABANDONMENT CRITERIA
1. The thirteen extraction wells shall be constructed of PVC casing and screen, and the screened or open -
hole interval of each well shall be located as specified in the permit application.
2. The seventeen injection wells shall be constructed of PVC casing and screen and the screened or open -
hole interval of each well shall be located as specified in the permit application. Prior to operation of the
groundwater remediation system, the permittee shall certify the mechanical integrity of the injection
well(s) as defined by 15A NCAC 2C .0207.
Flow measurement devices shall be installed to monitor the volumes injected at each injection well. Also
each injection wellhead shall be equipped to measure the injection pressure at the screened interval. If the
injection pressure is greater than atmospheric pressure, the mechanical integrity of the injection well(s)
shall be demonstrated according to 15A NCAC 2C .0207,
WQ0029385 Page 3 of 7

4. Pursuant to rule 15A NCAC 2C .021 l(g), injection may not commence until construction of the injection
wells is completed, the permittee has submitted notice of completion of construction to the Winston-
Salem Regional Office, and the regional office staff has inspected or otherwise reviewed the injection
well and finds it in compliance with the permit. If the permittee has not received notice from the
Winston-Salem Regional Office of the intent to inspect or otherwise review the injection well within 10
days after the regional office has received the notice, the permittee may commence operation of the
injection wells.
5. The well(s) must be constructed by either a North Carolina Certified Well Contractor, the property owner,
or the property lessee according to General Statutes 87-98.4(b)(2). If the construction is not performed by
a certified well contractor, the property owner or lessee, provided they are a natural person, must
physically perform the actual well construction activities. All well(s) must be constructed according to the
North Carolina Well Construction Standards (I5A NCAC 2C .0108) and any local county roles.
6. The Winston-Salem Regional Office, telephone number [phone], shall be notified at least forty-
eight (48) hours prior to the construction of any monitoring well so that an inspection can be made of the
monitoring well location. Such notification to the regional groundwater supervisor shall be made during
the normal office hours from 8:00 a.m. until 5:00 p.m. on Monday through Friday, excluding state
holidays.
7. 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 I SA NCAC 2C
.0113(b).
IV. MONITORING REQUIREMENTS
1. Extracted groundwater shall be sampled for the parameters specified below:
VOCs
Oxidation -Reduction Potential
Dissolved Oxygen
Conductivity
pH
Temperature
2. Extracted groundwater from EW-505, EW-Combined, EW-509, EW-511, and EW-513 shall also be
sampled for the parameters specified below:
Total Organic Carbon
Ferrous Iron
Total Iron
Methane
Ethane
Ethene
Chloride
Sulfate
3. The groundwater monitoring location, and frequency are specified in Table 2.
4. Prior to sampling the parameters, the measurement of water levels must be taken. The depth to water in
each well shall be measured from the surveyed point on the top of the casing. The measuring points (top
of well casing) of all monitoring wells shall be surveyed relative to a common datum.
WQ0029385 Page 4 of 7

Any laboratory selected to analyze parameters must be Division of Water Quality certified for those
parameters required.
6. Any additional groundwater quality monitoring, as deemed necessary by the Division, shall be provided.
V. REPORTING REQUIREMENTS
1. Three (3) copies of the following forms shall be mailed to the address below:
a. GW-1 Well Construction Record
b. GW-59 Groundwater Quality Monitoring: Compliance Report Form
c. GW-59A Compliance Report Form
Mail these documents to the following address: Division of Water Quality
1617 Mail Service Center
Information Processing Unit
Raleigh, NC 27699-1.61.7
Updated blank forms (GW-1, GW-59, GW-59A) may be downloaded from the Division of Water Quality
website at http://h2o.enr.state.nc.us/ or requested from the address mentioned above.
2. The results of the sampling and analysis must be received on forms GW-59 and GW-59A on or before the
last working day of the month following the sampling month. The data of all groundwater sampling
analyses required by the permit conditions must be reported using the most recent GW-59 and GW-59A
forms along with attached copies of the laboratory analyses.
3. For the initial sampling of the well(s), the permittee shall submit a copy of the GW-1 form with forms
GW-59 and GW-59A for each well to the address listed above. Initial GW-59 forms that do not include
copies of the GW-1 form may be returned to the permittee without being processed. Failure to submit
these forms as required by this permit may result in enforcement activities pursuant to NC General
Statutes 143-215.6A.
4. The permittee shall retain records of all monitoring information, including calibration and maintenance
records, continuous monitoring data and reports required by this permit, for at least 3 years from the date
of the sample measurement, report or application. Records of this monitoring information shall include,
but not be limited to, the following:
a. the date, exact place, and time of sampling or measurements,
b. the individual who performed the sampling or measurements,
c. the date the analyses were performed,
d. the analytical techniques or methods used, and
e. the results of such sampling, measurements, and analyses.
5. The permittee shall report to the Winston-Salem Regional Office (see Section VI. NONCOMPLIANCE
NOTIFICATION) any monitoring or other information which indicates:
a. any contaminant may cause an endangerment to an underground source of drinking water,
b. any noncompliance with, a permit condition due to a malfunction of the system, or
c. any cause of fluid migration outside the injection zone or area.
WQ0029385 Page 5 of 7

The written submission shall contain a description of the noncompliance and its cause, the period of
noncompliance, including exact dates and times. If the noncompliance is not corrected and is expected to
continue, steps taken or planned to reduce, eliminate, and prevent reoccurrence of the noncompliance
shall be provided to the Regional Office in a timely manner.
6. The permittee shall submit an annual report summarizing the volume of fluid discharged into the injection
wells and the summary results of related groundwater monitoring. Isoconcentrations (horizontal and
vertical direction) and water level contour maps shall be prepared on an annual basis and submitted with
this report. If an annual report containing this information (e.g, corrective action plan:) is required by a
regulatory agency, the permittee may submit two (2) copies of that report in lieu of the preceding
information within thirty days of its publication (no later than November 30). The permittee shall submit
this report to the following address: Aquifer Protection Section, Groundwater Protection Unit,1636
Mail Service Center, Raleigh, NC 27699-1636.
W. NONCOMPLIANCE NOTIFICATION
The Permittee shall report by telephone to the Winston-Salem Regional Office, telephone number (336)
771-4600, as soon as possible, but in no case more than 24 hours or on the next working day following
the occurrence or first knowledge of the occurrence of any of the following:
a. Any occurrence at the groundwater remediation facility which results in the treatment of significant
amounts of contaminated groundwaters which are abnormal in quantity or characteristic, such as the
dumping of the contents of a basin or tank, the known passage of a slug of hazardous substance
through the facility, or any other unusual circumstances;
b. Any process unit failure, due to known or unknown reasons, that renders the groundwater treatment
and disposal system incapable of adequate treatment and disposal, such as mechanical or electrical
failures of pumps, aerators, compressors, etc.;
c. Any failure of a pumping station, sewer line, or treatment facility resulting in a by-pass directly to
receiving waters without treatment of all or any portion of the influent to such station or facility; or
d. Any time that self -monitoring information indicates that the groundwater treatment and disposal
system is not in compliance with any specified permit limitations.
2. Occurrences outside normal business hours may also be reported to the Division's Emergency Response
personnel at telephone number [phone] or to the Emergency Management's switchboard at (919)
733-3300. Also, persons reporting such occurrences by telephone shall file a written report within five
(5) days following first knowledge of the occurrence. This report must outline the actions taken or
proposed to be taken to ensure that the problem does not recur.
VH. APPLICABLE BOUNDARIES
The COMPLIANCE BOUNDARY for the disposal system is specified by regulations in 15A NCAC 2L,
Groundwater Classifications and Standards. The Compliance Boundary for the disposal system
individually permitted on or after December 30, 1983 is established at either 250 feet from the waste
disposal area, or 50 feet within the property boundary, whichever is closest to the waste disposal area. An
exceedance of Class GA Standards at or beyond the Compliance Boundary is subject to remediation
action according to 15A NCAC 2L .0106("d)(2).
2. The REVIEW BOUNDARY is established around the disposal systems midway between the Compliance
Boundary and the perimeter of the waste disposal area. Any exceedance of Class GA Standards at the
Review Boundary may require action in accordance with 15A NCAC 2L .0106(d)(1).
VIII. GENERAL CONDITIONS
1. Issuance of this permit does not constitute approval for reimbursement from the Leaking Petroleum
Underground Storage Tank Cleanup Fund (15A NCAC 2P) or any other fund. Additionally, the issuance
WQ0029385 Page 6 of 7

of this permit does not remove the permittee's responsibility to comply with the corrective action
requirements of the Division of Waste Management. Furthermore, the permittee should notify and report
all changes concerning the remedial system to the Division of Waste Management. It is the permittee's
responsibility to comply with the requirements of all involved agencies.
2, This permit shall become voidable unless the facilities are constructed in accordance with the conditions
of this permit, the approved plans and specifications, and other supporting data,
3. This permit is effective only with respect to the nature and volume of wastes described in the application
and other supporting data.
4. This permit is not transferable. In the event there is a desire for the facilities to change ownership, or
there is a name change of the Permittee, a formal permit request must be submitted to the Division
accompanied by an application fee, documentation from the parties involved, and other supporting
materials as may be appropriate. The approval of this request will be considered on its merits and may or
may not be approved.
5. A set of approved plans and specifications for the subject project must be retained by the Permittee for the
life of this project.
6. Failure to abide by the conditions and limitations contained in this permit may subject the Permittee to an
enforcement action by the Division in accordance with North Carolina General Statute 143-215.6A to
143-215.6C.
7. The annual administering and compliance fee must be paid by the Permittee within thirty (30) days after
being billed by the Division, Failure to pay the fee accordingly may cause the Division to initiate action
to revoke this permit as specified by 15A NCAC 2T .0105 (e)(3).
8. The issuance of this permit does not preclude the Permittee from complying with any and all statutes,
rules, regulations, or ordinances, which may be imposed by other government agencies (local, state, and
federal), which have jurisdiction.
9. Sixty (60) days prior to termination of operations, the permittee must request a rescission of the permit
from the Division of Water Quality,
10. If the permittee wants to continue operation of this system, at least six (6) months prior to the expiration
of this permit, the permittee shall request its extension. Upon receipt of the request, the Commission will
review the adequacy of the facilities described therein, and if warranted, will extend the permit for such
period of time and under such conditions and limitations as it may deem appropriate.
Permit issued this the 3T1 day of November 2006
NORTH CAROLINA ENVIRONMENTAL MANAGEMENT COMMISSION
an W, Klimek, P.E., Director
Division of Water Quality
By Authority of the Environmental Management Commission
Permit Number WQ0029385
WQ0029385 Page 7 of 7

Table 1
Performance Monitoring Goals
Cotton Mill Square Project, Greensboro, North Carolina
WQ0029385
Start-U Phase
Initial Reducing Phase
Maintained Reducing Phase
Parameter
Year 1
Years 2 and 3
Years 4 and 5
Overall Goal
Establish reducing conditions
Reduce concentrations of parent
Reduce concentrations of parent
compounds site -wide
compounds and daughter products
site -wide
Volatile
Fluctuating concentrations with
Parent concentrations in majority of
Parent and daughter concentrations
Organic
some significant increases in parent
wells decreasing. Daughter
decreasing in majority of wells.
Compunds
compounds due to desorption and
concentrations increasing in some
plume mipyation
wells.
Sulfate
Fluctuating readings with some
Majority of wells trending
Majority of wells trending
wells trending downward as
downward as compared to
downward or maintaining reduced
compared to background
background
concentrations (< 25 mg/L)
Oxidation-
Fluctuating readings with some
Majority of wells trending
Majority of wells trending
Reduction
wells trending downward as
downward as compared to
downward or maintaining reduced
Potential
compared to background
background
concentrations (<0)
Dissolved
Fluctuating readings with some
Majority of wells trending
Majority of wells trending
Oxygen
wells trending downward as
downward as compared to
downward or maintaining reduced
compared to background
background
concentrationswells (< 1.5 mg/L)
Total Organic
Fluctuating readings with some
Majority of wells trending upward
Majority of wells trending upward
Carbon
wells trending upward as compared
as compared to background
or maintaining elevated
to background
concentrations (>10 m )
Ferrous Iron,
FIuctuating readings with some
Majority of wells trending upward
Majority of wells trending upward
Total Iron,
wells trending upward as compared
as compared to background
or maintaining elevated
Methane,
to background
concentrations as compared to
Ethane, Ethene,
background
Chloride,
Conductivi

Table 2
Recirculation In Situ Bioremediation - Performance M6nitoring Program
Cotton Mill Square Project, Greensboro, North Carolina
WQ0029385
Location
Sampling Frequency
Location
Sampling Fre uemc
DW-02
February, August
IW-204
August
DW-03
February, August
IW-205
August
DW-04
February, August
IW-206
August
DW-05
February, August
IW-207
August
DW-06
February, August
IW-208
August
DW-07
February, August
IW-209
August
DW-08
February, August
IW-210
August
DW-09
February, August
MW-01(s)
August
DW-10
February, August
MW-02(s)
February, August
DW-11
February, August
MW-03(s)
February, August
DW-13
February, August
MW-04(s)
February, August
DW-14
February, August
MW-10(s)
August
DW-15
February, August
MW-12(s)
February, August
DW-16
February, August
MW-13(s)
February, August
DW-17
August
MW-14(s)
February, August
DW-18
February, August
MW-18(i)
August
DW-19
February, August
MW-19(1)
February, August
EW-501
August
MW-23(i)
February, August
EW-502
August
MW-24(s)
February, August
EW-503
August
MW-26(i)
February, August
EW-504
August
MW-28(s)
February, August
EW-505
February, August
MW-30(i)
February, August
EW-506
August
MW-36(s)
February, August
EW-507
August
MW-37(s)
August
EW-508
August
MW-41(s)
February, August
EW-509
February, August
MW-45(i)
February, August
EW-510
August
MW-46(i)
February, August
EW-511
February, August
MW-49(i)
February, August
EW-512
August
MW-50(i)
February, August
EW-513
February, August
MW-51(i)
February, August
EW-Combined
February, August
PMW-1
August
IW-201
August
PMW-2
August
IW-202
August
TMW-2
August
IW-203
August