WS-9333_44564_CA_CAI_20210930_FS-Email

From:Lepard, Mindy
To:rbshah
Subject:RE: [External] 44564 - Eagle Mart 2 - Corrective Action Feasibility Study
Date:Thursday, September 30, 2021 4:29:00 PM
Raj,

The Corrective Action and Trust Fund branches had a discussion about the Feasibility Study earlier this week.
Additional work is requested before moving on to the Record of Decision phase of the Corrective Action Plan
process. This work includes:

Installation of an additional shallow monitoring well in the area between MW-10 and MW-12. The
proposed monitoring well at the southern property boundary to determine if the 1,2-DCA impacting SW-1
is coming from off-site is not necessary. The USTs at this site did not contain leaded gasoline, therefore it
is apparent that the 1,2-DCA detections, which are below the MCL standards, are due to an off-site
source.
Installation of VEW-3 at the property boundary in line with SW-2 with a screened interval at the depth of
the high-yielding fractures
Revise the remediation plan for installation of the proposed permeable reactive barrier to the area
northeast of MW-12
Revise the remediation plan to include injection of Klozur CR in the area around MW-12
Full sampling event after the installation of the additional monitoring wells to be reported in a Monitoring
Report

Please let me know if you have any questions.

Thanks,
Mindy

------------------------------------** Important Message**------------------------------------------------------------------
Until further notice, all UST Section “deliverables/documents” (letters, reports, recorded NRPs etc.) must be submitted
electronically to the appropriate Incident Manager (See below for County Assignments and Contact Information). If a document
is too large to send via email, please upload the document onto the Division of Waste Management FTP site. Follow the uploadwith an email notifying the Incident Manager of the document’s presence on the FTP server. Contact the appropriate IncidentManager for FTP instructions. Please provide a responsible party email address with each submittal, if available.

COUNTY ASSIGNMENTS (Subject to Change. Check List Frequently):
Guilford County: Gene Mao (336-641-3589) Ashley Dinkins (336-641-5557)
Christina Schroeter: Ashe and Forsyth (336-776-9683)
Mindy Lepard: Alamance and Surry (336-776-9686)
Linda Estkowski: Caswell, Davie, Rockingham, Stokes, Watauga, Yadkin (336-776-9680)
Doug Whitmire: Allegheny, Davidson, Randolph, Wilkes (336-776-9685)
Karen Hall: All counties and phases through an LSA, Complaints and Spills (336-776-9681)
Shelia McIntosh: File Reviews (336-776-9630) ALL UST ARCHIVED FILES CAN BE FOUND ON THE FOLLOWING LINK:
https://deq.nc.gov/about/divisions/waste-management/laserfiche
DWM LOCATOR TOOL: USE MAP FOR LOCATING UST SITES ACROSS THE STATE:
https://ncdenr.maps.arcgis.com/apps/webappviewer/index.html?id=7dd59be2750b40bebebfa49fc383f688UST FACILITY DABASE (Facility Permitting and Inspection Documents):
https://xapps.ncdenr.org/wm/docs/WMDocs_Search.jsp

From: rbshah <[e-mail]>
Sent: Thursday, September 16, 2021 12:48 PM
To: Lepard, Mindy <[e-mail]>
Subject: FW: [External] 44564 - Eagle Mart 2 - Corrective Action Feasibility Study

CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to
Report Spam.

Mindy,

Just wanted to make sure that you received my previous email and if you had any questions. Thanks.

Raj

Raj B. Shah, P.E., LEED®APTechnical DirectorAgra Environmental, Inc.P.O. Box 5611Cary, North Carolina 27513Office: [phone] Ext. 101Mobile: [phone]Fax: (919) [e-mail]

From: rbshah <[e-mail]>
Date: Wednesday, September 1, 2021 at 5:56 PM
To: "Lepard, Mindy" <[e-mail]>
Subject: Re: [External] 44564 - Eagle Mart 2 - Corrective Action Feasibility Study

Mindy,

Sorry for the delay. Please see below for the response to your questions. If you have any further questions or
need additional information, please call/email me. Thanks.

Raj

Raj B. Shah, P.E., LEED®APTechnical DirectorAgra Environmental, Inc.P.O. Box 5611Cary, North Carolina 27513Office: [phone] Ext. 101Mobile: [phone]Fax: (919) [e-mail]

From: "Lepard, Mindy" <[e-mail]>
Date: Tuesday, July 13, 2021 at 3:32 PM
To: "[e-mail]" <[e-mail]>
Subject: FW: [External] 44564 - Eagle Mart 2 - Corrective Action Feasibility Study

Raj,

I just sent this email to Aaron Springer and saw that he left the company. I copied you on that email but see that
it may be an old address so I thought I’d send this to you at the email address in Aaron’s automatic reply to
make sure you get it. I apologize if you are receiving it twice.

The Corrective Action Branch and Trust Fund Branch met last week to review the recommendations in the
Feasibility Study Report. We have a few questions and suggestions from the report before we all meet to discuss
the remedial strategy.

What is the depth of the injections? The depth of the injections is outlined in the feasibility study in
section 9. On injections near MW-1, MW-2, and MW-6 the target treatment zone is 15’-35’ and near MW-
10 the treatment zone is 12’-32’. The PRB injection depth will be between 10’-30’.
What was the radius of influence of the injections from the pilot study? Not available as there are no
other monitoring wells/points in the immediate vicinity of MW-2 that we could have used during the pilot
test. Based on our past experience and as a rule of thumb 5 to 7 feet is a good estimate of the radius of
influence of each injection point.
How did you arrive at 12,780 pounds of Klozur CR?
Klozur-CR Estimate for Graham, NC Site
Area
Number of
IPs
KCR, lbs
per IP
Volume of 20%
KCR slurry per
point, gal Total Mass of KCR, lb Total KCR Slurry, gal
MW-1 16 270 146 4,320 2,336
MW-2 6 270 146 1,620 876
MW-6 6 270 146 1,620 876
VEW-1 1 270 146 270 146
MW-10 12 225 122 2,700 1,464
RB 10 225 122 2,250 1,220
otal 51 12,780 6,918
Would it be better to install another monitoring well between MW-10 and MW-12 before putting in the
reactive barrier to better define the amount of contamination in that area? As MW-12 is known to be
contaminated, we do not recommend installation of an additional well between MW-10 and MW-12. It is,
however, recommended that a shallow monitoring well (MW-16) be installed along the southern property
edge. Additionally, a new vertical extent well (VEW-3) should be installed near the property edge in line
with the source area and SW-2

Could you conduct a packer test on SW-2 to test where the MTBE may be coming into the well? Maybe
pack off below 90 feet and collect a sample. A packer test would not be an option for SW-2 since it is an
open borehole well with extremely fractured (vertical and horizontal) rock. There would be no way to
isolate zones with no communication from other depths.

We will schedule a meeting when you’ve had time to look over these questions and are ready to discuss the
remedial strategy. Let me know if you have any questions and the timeframe that you think you’ll need.

Thanks,
Mindy

------------------------------------** Important Message**------------------------------------------------------------------
Until further notice, all UST Section “deliverables/documents” (letters, reports, recorded NRPs etc.) must be submitted
electronically to the appropriate Incident Manager (See below for County Assignments and Contact Information). If a documentis too large to send via email, please upload the document onto the Division of Waste Management FTP site. Follow the upload
with an email notifying the Incident Manager of the document’s presence on the FTP server. Contact the appropriate Incident
Manager for FTP instructions. Please provide a responsible party email address with each submittal, if available. COUNTY ASSIGNMENTS (Subject to Change. Check List Frequently):Guilford County: Gene Mao (336-641-3589) Ashley Dinkins (336-641-5557) Christina Schroeter: Ashe and Forsyth (336-776-9683)Mindy Lepard: Alamance and Surry (336-776-9686)Linda Estkowski: Caswell, Davie, Rockingham, Stokes, Watauga, Yadkin (336-776-9680)
Doug Whitmire: Allegheny, Davidson, Randolph, Wilkes (336-776-9685)
Karen Hall: All counties and phases through an LSA, Complaints and Spills (336-776-9681)
Shelia McIntosh: File Reviews (336-776-9630)

ALL UST ARCHIVED FILES CAN BE FOUND ON THE FOLLOWING LINK:
https://deq.nc.gov/about/divisions/waste-management/laserficheDWM LOCATOR TOOL: USE MAP FOR LOCATING UST SITES ACROSS THE STATE:https://ncdenr.maps.arcgis.com/apps/webappviewer/index.html?id=7dd59be2750b40bebebfa49fc383f688
UST FACILITY DABASE (Facility Permitting and Inspection Documents):
https://xapps.ncdenr.org/wm/docs/WMDocs_Search.jsp

From: Aaron D Springer <[e-mail]> On Behalf Of [e-mail]
Sent: Friday, May 7, 2021 1:49 PM
To: Lepard, Mindy <[e-mail]>
Cc: [e-mail]
Subject: [External] 44564 - Eagle Mart 2 - Corrective Action Feasibility Study

CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to
Report Spam.

Mindy,

The Corrective Action Feasibility Study for Incident #44564 Eagle Mart 2 has been uploaded to the CAB WS FTP
file folder.

Thank you,
Aaron D. Springer
Environmental ScientistAgra Environmental, Inc.P.O. Box 5611Cary, North Carolina 27512Mobile: [phone]Office: [phone]Fax: (919) [e-mail]