WI0100091_Permit_20100831

S-
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
Davidson River Village, LLC
FOR THE CONSTRUCTION AND/OR OPERATION OF 40 TYPE 5I INJECTION WELLS,
defined in Title 15A-North Carolina Administrative Code 2C .0209(e)(3)(C), to inject ORC
Advanced, for the remediation of groundwater contaminated with petroleum products. These
injection wells/points will be located in the vicinity of Building 27 at the former Ecusta Paper Mill
Plant, l Ecusta Road, Brevard, Transylvania County, NC 28712, and will be operated in accordance
with the application submitted April 26, 2010, and in conformity with the specifications. and
supporting data received July 23, 2010, 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 July 31, 2012, and
shall be subject to the specified conditions and limitations set forth in Parts I through X hereof.
Permit issued this the 316 day of August 2010.
04tc!- � w�
Coleen H. Sullins, Director
Division of Water Quality
By Authority of the Environmental Management Commission.
Permit No. WI0100091 PAGE 1 OF 7
ver. Jan.2010 AP/UIC-6

PART I - WELL CONS'�,.itiSCTION GENERAL CONDITIONS
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
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.
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 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.
9. 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 Staff
DENR-Division of Water Quality .
1636 Mail Service Center
Raleigh, NC 27699-1636
PART II - WELL CONSTRUCTION SPECIAL CONDITIONS
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 [phone] and the Asheville Regional Office Aquifer Protection Section Staff,
telephone number [phone].
Permit No. WI0100091 PAGE 2 OF 7
ver. Jan.2010 AP/UIC-6

J _ _
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PART III - OPERATIONv AND USE GENERAL CONDITIONa-�
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 maybe 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 which may be imposed by other local, state,
and federal agencies which have jurisdiction. Furthermore, the issuance of this permit does not
imply that all regulatory requirements have been met.
PART HIV - 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. 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.
2. 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.
3. 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 physical alterations or additions in the permitted facility or activity not specifically
authorized by the permit.
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 [phone]. Notification is required so that Division staff can inspect or
otherwise review the injection facility and determine if it is in compliance with permit
conditions.
Permit No. WI0100091 PAGE 3 OF 7
ver. Jan.2010 - AP/UIC-6

PART VI - INSPECTION'S
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. The proposed monitoring plan included in the application shall be followed except for the
following:
(A) The following field parameters will be analyzed- pH (field), conductivity, DO, and
ORP.
(B) Quarterly sampling will occur after each injection event until groundwater quality has
met standards according to 15A NCAC 2L .0200.
2. All sample results shall be submitted to the Aquifer Protection Section's Asheville 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 insure surface and ground)
water protection, will be established and an acceptable sampling reporting schedule shall be
followed.
3. During each injection event, any spill or daylighting of the injectant shall be contained or
intercepted by the ditch, which discharges to the existing water treatment plant and settling basin.
4. The Permittee shall submit an Injection Event Record within 30 days of completing each
injection.
5. 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 contain
monitoring well sampling data, contaminant plume maps and potentiometric surface maps.
Permit No. WI0100091 PAGE 4 OF 7
ver. Jan.2010 APMC-6

6. 'The monitoring results and the final project evaluation shall be submitted to:
and to:
Aquifer Protection Section-UIC Staff
DENR-Division of Water Quality
1636 Mail Service Center
Raleigh, NC 27699-1636
Aquifer Protection Section
DENR-DWQ Asheville Regional Office
2090 US Highway 70
Swannanoa, NC 28778
7. The Permittee shall report by telephone, within 48 hours of the occurrence or first knowledge of
the occurrence, to the Asheville 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.
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.
9. 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 .0113, 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:
Permit No. WI0100091 PAGE 5 OF 7
ver. Jan.2010 AP/UIC-6

(A) All 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
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 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 Staff
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. 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. -
Permit No. WI0100091 PAGE 6 OF 7
ver. Jan.2010 APIUIC-6

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. WI0100091 PAGE 7 OF 7
ver. Jan.2010 APIUIC-6

DIVISION OF WATER QUALITY
AQUIFER PROTECTION SECTION
August 24, 2010
MEMORANDUM VJ
TO: Debra Watts 6�p
FROM: Michael Rogers
THROUGH: Thomas Slusser S
RE: Permit to Inject Oxygen Release Compound (ORC) Advanced (Permit #WI0100091)
Davidson River Village, LLC
I recommend that Permit Number WI0100091 be issued to the applicant to inject ORC Advanced to remediate groundwater
contaminated with petroleum products.
SITE DESCRIPTION: The subject Site is the Former Ecusta Paper Mill located at 1 Ecusta Road, Brevard, Transylvania
County, NC 28712 (Figures 1 and 2). The source of contamination is believed to be from former underground storage
tanks containing petroleum products at a former garage on -site. For your information, a UIC 5I injection permit
(WI0100072) was issued for this site in 2009 for injecting acetic acid in the caustic building area, approximately 1000 feet
to the south. The ascetic acid was injected to neutralize high pH.
HYDROGEOLOGIC DESCRIPTION: The Site is located in the Blue Ridge geologic province adjacent to the Brevard fault
zone, which is a linear southeast dipping thrust fault. In the area of the Site, the overburden consists of sand, gravelly sand,
clay (saprolite), weathered rock, and crystalline bedrock. Depth to groundwater (GW) averages 9.2 feet below land surface
(BLS). GW generally flows southeast at approximately 59 ft/year (Figure 5A).
EXTENT OF CONTAMINATION: The hydrocarbon contaminant plume is generally oblong and is approximately 150 feet long
and 90 feet wide (Figure 6). The extent of the contamination is still' for the most part on the property. According to the
Applicant, there are no water supply wells within 1500 feet of the injection area.
PROPOSED INJECTION: The proposed injection consists of injecting a maximum of approximately 8,000 gallons of ORC
Advanced via a maximum of 40 direct push Geo probe injection wells. Approximately 200 gallons of ORC Advanced will
be injected through each well fro about 9 to 14 feet BLS. There are a total of 2 injection events planned. Each event will
last approximately 30 days_ wi�6 to 12 mon s m etween each event. The estimated amount of fluid displacement from
injection is approximate 14%. The potential displacement of the plume is, therefore, low.
HOW IT WORKS: ORC Advanced is slow -release oxygen compound used to remediate groundwater contaminated with
petroleum products by stimulating the naturally occurring biologic community. Between natural attenuation and injection
of this compound, petroleum contamination in the GW is reduced.
MONITORING: The existing monitoring wells near Building 37 will be monitored for injection effectiveness (MW-11, MW-35,
MW-36, MW-37, MW-38, and MW-39). The screened interval for these wells is from about 5 to 15 feet BLS, roughly the same
depths as the injection zone. Per our request, the monitoring frequency was modified. The wells will be sampled 3 months after
the injection, and then every 3 months thereafter until groundwater meets 2L standards (estimated to take approximately one
year). Parameters to be analyzed include field parameters of temperature, pH, conductivity, DO, and ORP, and laboratory
analysis for BETX and naphthalene. Sampling of the wells in March 2010 will act as the pre -injection sampling event.
EPIDEMIOLOGY: Dr. Luanne Williams has reviewed and approved ORC Advanced as an injectant.

REGIONAL OFFICE COMMENTS: Each of the RO comments/recommendations are discussed below (RO's
comments/recommendations are underlined). Most of the Region's comments/recommendations below were addressed in the
Additional Information Letter received from Shaw Environmental Inc., on July 23, 2010.
Item # 1-Any Vill or dUlighting of injection fluid should be intercepted by the drainage. I added this proviso in the permit
as a permit condition. However, this is unlikely occur because injection volumes and pressures are monitored by the injection
contractor and technicians.
Item #24would recommend adding arsenic to the post -injection monitoring plan. I asked about this in an Add Info letter to
Shaw Environmental. Naturally occurring arsenic has been detected in soils on,this Site; but historical groundwater analytical
data provided in the Add Info letter indicated previous arsenic levels in the GW were either` below laboratory detection levels or
were below MCL in the vicinity of Building 27 (there have not been any exceedances of arsenic in the groundwater on this
property). Therefore, since (1) arsenic is below detection limits or below MCL, (2) the post -injection monitoring did not already
include any sampling for any other metals, and (3) they are no public or private wells in the vicinity, I did not request they add
arsenic as the sole metal.
Brett Laverty and Landon Davidson of the Asheville RO recommend issuance of this permit.

5I Calculations Worksheet
Applicant/Facility: 014VI 9Sd A_/ 91 VNk- V / C "Ie � � % � 4:'
M141 U-
Permit No. WI
Date:
Reviewer:
Depth to groundwater (GW): `j, BLS.
GW flow direction: :5L-
MWs installed in same aquifer as injection?_t (Y or N); Inj zone: % iy MW zones. %S r-
Groundwater Flow Rate
HC X 013 adient(FT?) _ - %�, flow rate/DAY(?) X 365 = FT/YR
r� D SY or porosity (-.30) /
Reported:
Cale
314 X height =
J _ J ?-Si CF X 9 ,)�L) SY or porosity (i.e. -.30) _ ��� CF of available void
space 1 k
3i ?Sr CF of available void space X 7.48-gallons = _600 j'_gallons of water in void sp
J;p"O0,3 gallons of injectant = , % of fluid displaced by injectant (move decimal)
_](30 � 05-- gallons of water in void space
Potential displacement of plume by injection: Z-y 1,J
Injection Volume and Pumping Rate Per Well Per Day
cic .
DO 0 total amt. of injectant number of wells /number of days -of injection event =
el �' I _ amount of injectant per well per day (average gallons per da � -�, �� j p p Y( g g p Y)
S:UIC/Applications and forms/ 5I Calculations worksheet version 7/23/10

5I Calculations Worksheet
Notes
BLS
S:UIC/Applications and forms/ 5I Calculations worksheet
version 7/23/10

Central Files: APS SWP
08/24/10
Permit Number W10100091 - Permit Tracking Slip
Program Category
Ground Water
Permit Type
Injection In situ Groundwater Remediation Well (51)
Primary Reviewer
michael.rogers
Coastal SW Rule
Permitted Flow
Facility
Status Project Type
In review New Project
Version Permit Classification
Individual
Permit Contact Affiliation
Amar Bumb
PE PhD
3 Independence Pointe
Greenville SC 29615
Facility Name Major/Minor Region
Former Ecusta Paper Mill - Building 27 Area Minor Asheville
Location Address County
1 Ecusta Rd Transylvania
Brevard NC 28712 Facility Contact Affiliation
Owner
Owner Name
Owner Type
Davidson River Village LLC
Unknown
Owner Affiliation
John Hanselman
36 Washington St Ste 220
Wellesley MA
02481
Dates/Events
Scheduled
Prig Issue App Received Draft Initiated Issuance
Public Notice Issue Effective
Expiration
04/26/10
Regulated Activities
Requested/Received Events
Groundwater remediation
RO staff report requested
05/11/10
RO staff report received
06/22/10
Additional information requested
07/02/10
Additional information received
07/23/10
Outfall NULL
Waterbody Name Stream Index Number Current Class Subbasin