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WithersRavenel
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115 MacKenan Drive | Cary, NC 27511
t: 919.469.3340 | f: 919.467.6008 | www.withersravenel.com | License No. C‐0832
Asheville | Cary | Greensboro | Pittsboro | Raleigh | Wilmington
April 18, 2022
State of North Carolina
Department of Environment Quality
Trust Fund Branch
Division of Waste Management‐Underground Storage Tank Section
1646 Mail Service Center
Raleigh, North Carolina 27699‐1646
Attn: Mr. Herb Berger, L.G.
RE: LETTER REPORT – MOBILE MULTI‐PHASE EXTRACTION EVENT
Duke Foster/D&M Market
54 Nicks Road
Mebane, Caswell County, North Carolina
Groundwater Incident Number: 18698
UST Number: WS‐5420
WR Project Number: 02172214.03
Mr. Berger:
WithersRavenel, Inc. (WR) has completed this Letter Report to document the Air Sparge
Enhanced Mobile Multi‐Phase Extraction (AS/MMPE) event described in task authorization (TA)
TA‐02 for the above referenced site approved by the Federal & State Lead Program on February
22, 2022. WR mobilized to the subject site on March 28, 2022, for the purposes of performing a
MMPE event on monitoring well MW‐3 and utilizing air sparge well AS‐1 for air injection. The
site location is depicted on Figure 1 and site features including monitoring well locations are
depicted on Figure 2.
Sparge‐Enhanced MMPE Event
Prior to performance of the March 2020 sparge enhanced MMPE event, S&ME completed and
submitted a “Deemed as Permitted” Notification of Intent (NOI) to construct or operate injection
wells to the NCDEQ‐DWR. NCDEQ approved the NOI with Permit # WI0400541 on February
28, 2020. A copy of the NOI and approval are included in Appendix A.
WR personnel, along with Eastern Environmental Management, LLC (Eastern) mobilized to the
site on March 28, 2022, for the purposes of performing a 96‐hour sparge enhanced MMPE
event. This event was initiated to reduce the presence of compounds exceeding GCLs within
well MW‐3. In the performance of the MMPE, Eastern connected to air sparge well AS‐1 and
utilized air sparge and vacuum extraction equipment mounted within an enclosed trailer and
stored removed fluids within a 6,000‐gallon tanker trailer.
WithersRavenel
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Letter Report ‐ MMPE Event Duke Foster/D&M Market (Inc. 18698)
April 2022 Page 2 of 2
WR gauged site monitoring wells prior to sampling as described above and performance of
remedial actions at the location. Gauging of groundwater elevations within wells MW‐2, MW‐3
and MW‐4 showed the following:
Well ID Depth to
LNAPL
Depth to Water Well Depth LNAPL
Thickness
MW‐2 ‐‐‐ 20.85 30 ‐‐‐
MW‐3 ‐‐‐ 19.99 30 ‐‐‐
MW‐4 ‐‐‐ 19.31 30 ‐‐‐
In the completion of the sparge enhanced MMPE activities, Eastern installed 1‐in dia PVC
stingers into well MW‐3 at a depth approximately 1‐ft beneath the measured groundwater
elevation. These stingers were plumbed at the surface to 2.0‐in chemical resistant flexible hose,
which was connected to a vacuum truck servicing the vacuum/pressure regenerative blower
housed in the equipment trailer. For induction of air for the purposes of sparging, ½‐in dia PVC
tubing was placed within AS‐1 at a depth beneath the measured groundwater elevation. This
tubing was plumbed to a compressor with which air was injected into air sparge well AS‐1.
Following setup, the air sparge/MMPE system was started and operated continuously for a
period of 96‐hours to induce movement and recovery total fluids from MW‐3. Eastern
personnel monitored the performance of the sparge and MMPE system over the course of the
event, adjusted the stinger depths and optimized recovery as necessary.
Throughout the course of the MMPE event, effluent emissions ranged from 322 parts per million
(ppm) to 2,960 ppm. In completion of the sparge‐enhanced MMPE event, a total of 5,928‐gal of
contaminated water was recovered and based on mass removal calculations, a total of 514.50‐
pounds or 83.63‐gal of VOCs were removed as vapor.
After completion of the MMPE event, Eastern dismantled the MMPE setup at the location. WR
personnel gauged MW‐1, MW‐2, and MW‐3 during the water recovery after removal of the
stingers and found the water levels to be the following:
MW‐2 =21.11‐ft,
MW‐3 = 28.02‐ft, and
MW‐4 = 19.36‐ft.
No LNAPL was measured within the wells following completion of the MMPE event.
Field notes from the event are included in Appendix B. The manifest, disposal documents, and
the MMPE report are included in Appendix C.
WithersRavenel
Our People. Your Success.
Letter Report ‐ MMPE Event Duke Foster/D&M Market (Inc. 18698)
April 2022 Page 3 of 2
WR appreciates the opportunity to be of service to the Federal & State Lead Program. Should
you have any questions regarding the attached, please do not hesitate to contact Elizabeth Allyn
at (919) 469‐3340.
Cordially,
WithersRavenel
Elizabeth A. Allyn, P.G.
Environmental Project Geologist II
WithersRavenel
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FIGURES
CBM
LA
DRAWN BY:
04/15/21 02172214.03
1
SUBJECT SITE
±1.33 ACRES
SCALE:FIGURE NO.:
PROJECT NO.:DATE:APPROVED BY:
DUKE FOSTER - D&M MARKET
NCDEQ INCIDENT #18698
54 NICKS ROAD
MEBANE, CASWELL COUNTY, NC
GENERAL LOCATION MAP
1"=500 '
GRAPHIC SCALE
1 inch = 500 ft.
0 500250 1000
WithersRavenel
Engineers | Planners | Surveyors
115 MacKenan Drive | Cary, NC 27511 | t: 919.469.3340 | license #: F-1479
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NICKS ROADNC HWY 119MW-1
MW-4
FORMER UST
SYSTEM
SITE PROPERTY
BOUNDARY
MW-7 WR-2
WR-1
MW-13 MW-12
MW-5
MW-3
MW-8
MW-1MW-1A
MW-2
MW-9
MW-11
NC HWY 119NICK
S
ROAD
AS-1
MW-2
MW-3
H. A. WALKER SITE
NCDEQ INCIDENT # 9615
KBB
LA
DRAWN BY:
05/19/2021 02172214.03
1
SCALE:FIGURE NO.:
PROJECT NO.:DATE:APPROVED BY:SITE MAPWithersRavenel
Engineers | Planners | Surveyors
115 MacKenan Drive | Cary, NC 27511 | t: 919.469.3340 | license #: F-1479
www.withersravenel.com
1"=50 '
GRAPHIC SCALE
1 inch = 50 ft.
0 5025 100
LEGEND
TYPE II MONITORING WELL LOCATION
DUKE FOSTER/D&M MARKET
MONITORING WELL
AIR SPARGE WELL LOCATION
NOTES:
1.) 2013 AERIAL OBTAINED FROM THE LOCAL COUNTY GIS DEPARTMENT.
DUKE FOSTER - D&M MARKET
NCDEQ INCIDENT #18698
54 NICKS ROAD
MEBANE, CASWELL COUNTY, NC
MW-#
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TABLE B‐7
Well ID Date of
Installation
Screened
Interval
(feet)
Total Depth (feet below
ground
surface)
Well
Diameter (inches)
Top‐of‐Casing
Elevation (feet)
Date Water Level
Measured
Depth‐to‐LNAPL
(feet)
Depth‐to‐Water
Uncorrected(feet)
LNAPL Thickness
(feet)
Corrected
Groundwater
SurfaceElevation
(feet)
7/1/2015 21.47 21.50 0.03 83.65
2/17/2016 20.45 20.48 0.03 84.67
10/4/2017 NM 22.06 NM 83.06
3/21/2019 NM 17.95 NM 87.17
3/2/2020 NM 18.85 NM 86.27
3/6/2020 NM 19.55 NM 85.57
3/31/2020 NM 19.01 NM 86.11
3/30/2021 NM 16.21 NM 88.91
2/17/2016 NM 22.00 NM 83.69
10/4/2017 NM 22.66 NM 83.03
3/21/2019 NM 19.93 NM 85.76
3/2/2020 NM 20.25 NM 85.44
3/6/2020 NM 20.82 NM 84.87
3/31/2020 NM 19.89 NM 85.80
3/30/2021 NM 17.26 NM 88.43
3/28/2022 NM 20.85 NM 84.84
4/1/2022 NM 21.11 NM 84.58
2/17/2016 NM 23.90 NM 80.40
10/4/2017 NM 21.95 NM 82.35
3/21/2019 NM 18.04 NM 86.26
3/2/2020 NM 18.91 NM 85.39
3/6/2020 NM 19.70 NM 84.60
3/31/2020 NM 19.14 NM 85.16
3/30/2021 NM 16.40 NM 87.90
3/28/2022 NM 19.99 NM 84.31
4/1/2022 NM 28.02 NM 76.28
2/17/2016 NM 20.20 NM 84.22
10/4/2017 NM 21.93 NM 82.49
3/21/2019 NM 17.38 NM 87.04
3/31/2020 NM 18.64 NM 85.78
3/30/2021 NM 15.70 NM 88.72
3/28/2022 NM 19.31 NM 85.11
4/1/2022 NM 19.36 NM 85.06
3/2/2020 NM 19.38 NM 85.43
3/31/2020 NM 19.13 NM 85.68
1)
2)
3)4)NM = Not Measured.
TABLE B‐7
MONITORING WELL CONSTRUCTION INFORMATION AND LIQUID LEVEL DATA
Duke Foster/D&M Market
Incident # 18698
54 Nicks RoadMebane, North Carolina
Notes:
Top of Casing (TOC) elevations and monitoring well construction information obtained from 5/26/2020 report prepared by S&ME, Inc.
LNAPL ‐ Light Non‐Aqueous Phase Liquid
Groundwater elevation adjusted for LNAPL is [Top of Casing Elevation ‐ Depth to Water] + [LNAPL Thickness * 0.8581]
MW‐1 6/25/2015 105.1223520‐35
MW‐2 2/17/2016 15‐30 30 2 105.69
MW‐3 2/17/2016 15‐30 30 2 104.30
104.42
AS‐1 2/17/2020 35‐37.5 37.5 2 104.81
MW‐4 2/17/2016 15‐30 30 2
Page 1 of 1
WithersRavenel
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ATTACHMENT A
NOTICE OF INTENT FOR AIR SPARGE ENHANCED MMPE
Submit the original of this form to the Division of Water Resources within 30 days of injection. Form UIC-IER
Attn: UIC Program, 1636 Mail Service Center, Raleigh, NC 27699-1636, Phone No. 919-807-6464 Rev. 3-1-2016
North Carolina Department of Environmental Quality – Division of Water Resources
INJECTION EVENT RECORD (IER)
Permit Number__WI0400541___________
1. Permit Information
NCDEQ/DWM/UST/Trust Fund Branch
Permittee
__Duke Foster / D&M Market_________________
Facility Name
__54 Nicks Road, Mebane, Caswell County, NC___
Facility Address (include County)
2. Injection Contractor Information
WithersRavenel during MMPE by Eastern
Environmental Management, LLC
Injection Contractor / Company Name
Street Address_115 MacKenan Drive___________
___Cary _____NC_________27511______
City State Zip Code
(_919_) __469-3340_
Area code – Phone number
3. Well Information
Number of wells used for injection ___1________
Well IDs____AS-1__________________________
Were any new wells installed during this injection
event?
Yes No
If yes, please provide the following information:
Number of Monitoring Wells ___4____________
Number of Injection Wells_____1_____________
Type of Well Installed (Check applicable type):
Bored Drilled Direct-Push
Hand-Augured Other (specify) ________
Please include a copy of the GW-1 form for each
well installed.
Were any wells abandoned during this injection
event?
Yes No
If yes, please provide the following information:
Number of Monitoring Wells _______________
Number of Injection Wells__________________
Please include a copy of the GW-30 for each well
abandoned.
4. Injectant Information
___Air____________________________________
Injectant(s) Type (can use separate additional sheets
if necessary
Concentration ___________________________
If the injectant is diluted please indicate the source
dilution fluid.____________________________
Total Volume Injected (gal)____________________
Volume Injected per well (gal)_________________
5. Injection History
Injection date(s)___3/28/2022 – 4/1/2022________
Injection number (e.g. 3 of 5)___2___ ______
Is this the last injection at this site?
Yes No
I DO HEREBY CERTIFY THAT ALL THE
INFORMATION ON THIS FORM IS CORRECT TO
THE BEST OF MY KNOWLEDGE AND THAT THE
INJECTION WAS PERFORMED WITHIN THE
STANDARDS LAID OUT IN THE PERMIT.
________________________________________________4/14/2022______
SIGNATURE OF INJECTION CONTRACTOR DATE
____Elizabeth A. Allyn__________________________________________
PRINT NAME OF PERSON PERFORMING THE INJECTION
1
Jim Evan Peele
From:Lyndal Butler
Sent:Tuesday, April 28, 2020 2:51 PM
To:Jim Evan Peele
Subject:FW: WI0400541 NOI Duke Foster/ D&M Market Incident #18698
From: Shrestha, Shristi R <shristi.shrestha@ncdenr.gov>
Sent: Friday, February 28, 2020 10:10 AM
To: Berger, Herb <herbert.berger@ncdenr.gov>; Lyndal Butler <LButler@smeinc.com>
Cc: Snider, Lon <lon.snider@ncdenr.gov>
Subject: WI0400541 NOI Duke Foster/ D&M Market Incident #18698
Thank you for submitting the Notice of Intent to Construct or Operate Injection Wells (NOI) for the above referenced
site.
Please remember to submit the following regarding this injection activity:
1. Well Construction Records (GW-1) and Abandonment Records (GW-30) when completed.Please provide copies of
the GW-1s and GW-30s if not already submitted (originals go the address printed on the form). NOTE: Direct push or
Geoprobe wells are considered wells and require construction (GW-1) and abandonment forms (GW-30). If well
construction/abandonment information is the same for the wells, only one form needs to be completed- just indicate
total number of injection points in the Comments/Remarks section of form.
1)
2. Injection Event Records (IER). All injections, including air and passive systems require an IER. The IER can be
modified for air sparge wells (e.g., air flow ‘continuous’ for date or rate of injection, etc.). The forms can be found under
the following link https://deq.nc.gov/about/divisions/water-resources/water-resources-permits/wastewater-
branch/ground-water-protection/ground-water-applications
When submitting the above forms, you will need to enter the nine-digit alpha-numeric number on the form (i.e.,
WI0XXXXXX) that has been assigned to the injection activity at this site. This notification has been given the deemed
permit number WI0400541.This number is also referenced in the subject line of this email. You may if you wish, scan
and send back as attachments in reply to this email, as it will already have the assigned deemed permit number in the
subject line.
Thank you,
Shristi
Shristi R. Shrestha
Hydrogeologist, Ground Water Resources Section
NCDEQ Division of Water Resources
919-707-3662 office
shristi.shrestha@ncdenr.gov
512N. Salisbury Street
1636 Mail Service Center
Raleigh, NC 27699 1636
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.
WithersRavenel
Our People. Your Success
ATTACHMENT B
FIELD NOTES AND SITE PHOTOGRAPHS
WithersRavenel
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Duke Foster/D&M Market WR Project No. 02172214.03
Photographic Record Photograph Date: March 28-April 1, 2022
Frame No. 1
Description: View of site building with MW-2, MW-3, and AS-1 in foreground.
Frame No. 2
Description: MMPE set up.
WithersRavenel
Our People. Your Success.
Duke Foster/D&M Market WR Project No. 02172214.03
Photographic Record Photograph Date: March 28-April 1, 2022
Frame No. 3
Description: Additional photograph of MMPE set up.
Frame No. 4
Description: Air injection into air sparge well AS-1.
WithersRavenel
Our People. Your Success.
Duke Foster/D&M Market WR Project No. 02172214.03
Photographic Record Photograph Date: March 28-April 1, 2022
Frame No. 5
Description: Rear of site property used as convenience center for the landfill.
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ATTACHMENT C
DISPOSAL MANIFEST AND MMPE CALCULATIONS
MOBILE MULTI‐PHASE EXTRACTION EVENT
SITE NAME: Duke Foster / D&M Market
INCIDENT NUMBER: 18698
AVERAGE DEPTH TO GROUNDWATER: 19.5 feet
INDICATE AVERAGE HYDRAULIC CONDUCTIVITY (if known):‐
IDENTIFY THE WELL I.D. OF EACH WELL USED FOR MMPE: MW‐3 (2"), AS‐1 (2")
TOTAL GALLONS OF PRODUCT/WATER RECOVERED DURING MMPE (gallons): 5,928 gallons
DRY STANDARD CUBIC FEET PER MINUTE (DSCFM) AIR FLOW CALCULATIONS (Qstd)
Vacuum Velocity Pipe ID Temp Rel Humid Water Qstdnches of Hg (ft/min) (in) (°F) (%/100) Vapor (Vol%) (flow)
3/28/2022 10:00 0 25.00 396 2 98 100 0.031 7.92
3/29/2022 10:00 1,440 25.00 388 2 114 100 0.057 7.34
3/30/2022 10:00 2,880 25.00 405 2 110 100 0.056 7.73
3/31/2022 10:00 4,320 25.00 393 2 115 100 0.055 7.44
4/1/2022 10:00 5,760 25.00 398 2 115 100 0.056 7.53
NOTES
Qstd = Flow at DSCFM
Vacuum = The level of vacuum being applied should be recorded from the vacuum truck tank (inches of Hg)
Velocity = The rate at which air flows is measured at the blower discharge piping (anemometer or pitot tube)
Pipe ID = The inside diameter of the blower discharge piping (from the vacuum truck)
Temperature = The temperature of the air stream exiting the blower discharge piping (dry bulb temp., in deg.°F)Relative humidity = The % relative humidity of the air stream exiting the blower discharge piping
Bwsw = water vapor % by weight, i.e., pounds of water per pound of dry air, derived from the Psychrometric chart (temp Vs relative humidity)
Bws = water vapor % by volume
EQUATIONS
Bws = (Bwsw/18 lb‐mole H20)/[(1/28.84 lb‐mole dry air) + (Bwsw/18 lb‐mole H2O)]
Qstd = (1‐Water Vapor) * velocity * (PI * (diameter/24)2) * (528°R/(Temp + 460))
EMISSION CALCULATIONS
Elapsed
Time Flow PPMmeasured PPMwet PPMdry K PPMconc Cc:m Cc PMRc PMRg PMR
(min) (DSCFM) (ppm) (#C ‐ gas)(mg/dsm3)(lb/dscf) (lb/hr) (lb/hr) (lb)
1440 7.34 2960 2960 3055 1 3055 1524 0.000095154 9.764 11.30 271.1924
2880 7.73 1620 1620 1718 1 1718 857 0.000053514 5.090 5.89 141.37084320 7.44 740 740 784 1 784 391 0.000024419 2.444 2.83 67.87919
5760 7.53 386 386 408 1 408 204 0.000012724 1.226 1.42 34.05939
Total emissions in pounds 514.50
Gallons of Gasoline Removed:
=Gallons = 6.152 lbs/gallon
83.63 Gallons of Gasoline Removed as Vapor
NOTES
PPMmeasured = Actual measurements (ppm) taken with a OVA or TVA at the blower discharge piping
PPMwet = "wet" concentration
PPMdry = "dry" concentration
K = Number of carbons in calibration gas: (Methane K = 1, Propane K = 3, Isobutylene = 4, Hexane K = 6)
PPMc= PPMv, Volumetric concentration of VOC emissions as carbon, dry basis at STP
Cc:m = mg/dsm3, mass concentration of VOC emissions as carbon
Mc = 12.01 mg/mg‐mole, molecular weight of carbon
K3 = 24.07 dsm3/106 mg‐mole, mass to volume conversion factor at STP
Cc = lb/dcsf, mass concentration of VOC emissions as carbon, dry basis at STP
PMRc = lb/hr, pollutant mass removal rate of VOC's as carbon
PMRg = lb/hr, pollutant mass removal rate of of VOC's as gasoline
PMR = lb, pollutant mass removal of VOC's as gasoline
EQUATIONS
PPMwet = PPMmeasured Cc = (Cc:m)(62.43x10‐9 lb‐m3/mg‐ft3)
PPMdry = (PPMwet)/(1‐Bws)PMRc = (Cc)(Qstd)(60 min/hr)
PPMc = (PPMd)(K) PMRg = (PMRc)(Mg/Mcg)
Cc:m = (PPMc)(Mc / K3)PMR = (PMRg)(#minutes/60)
Date Time Elapsed Time
Page 1 of 1