WI0300102_Permit (Issuance)_20050329

DIVISION OF WATER QUALITY
AQUIFER PROTECTION SECTION
March 29, 2005
MEMORANDUM
TO: Debra Watts &) f
THROUGH: Evan Kane "I#
FROM: Mike RanckAg
SUBJECT: 5I Injection well permit application for Celanese International Corp.
Mecklenburg County
WI0300102
The subject permit application has been reviewed with the following remarks:
Site Overview: Tetrachloroethene (PCE) from a former dry cleaning operation has
contaminated groundwater at the site. Groundwater contamination is widespread
across the property boundary into a residential subdivision. Injection is proposed
for areas on the applicant's property with the greatest levels of VOCs in
groundwater. The application is for Phase I of remediation, which includes
construction and use of temporary injection wells.
2. Injection: Injection of a molasses -whey solution (IRZTM) is proposed. This
product provides an organic carbon source in the aquifer, which should enhance
microbial activity and lead to reducing conditions. Anaerobic microbes then
remove chlorine atoms from the solvent molecules, ultimately producing ethane
and ethene. Proposed injection will occur in 142 wells, screened from 45-65 feet
below ground surface. Injection of the solution will occur semi-annually for 30
months.
3. Monitoring: As described in the additional information submitted March 8, 2005,
the monitoring plan includes 27 monitoring wells and 3 surface water samples.
Most monitoring wells are located within the area of injection, however several
are downgradient. No upgradient monitoring was proposed. To address the lack
of upgradient (background) monitoring and deficiencies in the analysis plan, the
following language has been included in the permit; "In addition to the analysis
plan in the application, OMW-5, OMW-6, OMW-7, and MW-12 shall be
analyzed for redox parameters, alkalinity, and total organic carbon at all
scheduled sampling events. Additionally, all wells in the sampling plan shall be
analyzed for oxygen -reduction potential, dissolved oxygen, pH, specific
conductance, and temperature at all scheduled sampling events."

4. Epidemiology:
Dr. Luanne Williams provided a risk evaluationof the f molasses and
did not identify any concerns that would prevent injection
5. Other concerns: The 1VIRO expressed a concern that there are too submitted March few
well xto
track plume geometry. Additional informationin
the monitoring plan for the injection. Note that injection is occurring
Monitoring is
upgradient areas of the plume that are on the applicant's property.
occurring throughout the injection area and also downgradient of the injection
(within the contamination plume).
Based upon the remarks presented above, I recommend issuance of the permit. If you
have any questions, please let me know.

NORTH CAROLINA
ENVIRONMENTAL MANAGEMENT COMMISSION
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
RALEIGH, NORTH CAROLINA
PERMIT FOR THE CONSTRUCTION AND OPERATION OF WELLS 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
Celanese International Corp.
FOR THE CONSTRUCTION AND OPERATION OF TYPE 5I INJECTION WELLS, defined
in Title 15A North Carolina Administrative Code 2C .0209(e)(3)(C), to inject In -situ Reactive
ZoneTM, to enhance reductive dechlorination of dissolved chlorinated solvent contamination.
These injection wells/points will be located at the Dreyfus Research Park, 2300 Archdale Drive,
Charlotte, North Carolina, and will be operated in accordance with the application submitted
January 25, 2005, and in conformity with the specifications and supporting data submitted March
8, 2005, 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 April 1, 2009,
and shall be subject to the specified conditions and limitations set forth in Parts I through X
hereof.
Permit issued this the _ ��} day of A,,A 1 , 2005.
AA Alan W. Klimek, P.E., Director
Division of Water Quality
By Authority of the Environmental Management Commission.
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I
PART I - WELL CONSTRUCTION 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
1. 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 Mooresville Regional Office Aquifer
Protection Section Staff, telephone number [phone].
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PART III - OPERATION AND USE GENERAL CONDITIONS
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 may be 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 IV - PERFORMANCE STANDARDS
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.
3. 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.
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PART VI - INSPECTIONS
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. In addition to
the analysis plan in the application, OMW-5, OMW-6, OMW-7, and NM-12 shall be
analyzed for redox parameters, alkalinity, and total organic carbon at all scheduled sampling
events. Additionally, all wells in the sampling plan shall be analyzed for oxygen -reduction
potential, dissolved oxygen, pH, specific conductance, and temperature at all scheduled
sampling events. All sample results shall be submitted to the Aquifer Protection Section's
Mooresville 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.
2. The Permittee shall produce a final project evaluation within 9 months after completing all
injection -related activity associated with the permit application. 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.
3. 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 Mooresville Regional Office
610 East Center Avenue / Suite 301
Mooresville, NC 28115
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4. The Permittee shall report by telephone, within 48 hours of the occurrence or first knowledge
of the occurrence, to the Mooresville 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.
5. 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.
6. 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
The Permittee shall, at least 120 days prior to the expiration of this permit, request an
extension.
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 .0113(b), including but not limited to the following: _
(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
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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. Persons working in the application area should wear goggles or a face shield, gloves, and
protective clothing.
2. Eating, drinking, smoking, handling contact lenses, and applying cosmetics should not be
permitted in the application area.
3. In order to minimize exposure to unprotected individuals, measures should be taken to
prevent access to the area of application. to workers applying the product.
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