WI0300136_Permit (Issuance)_20091008

DIVISION OF WATER QUALITI'
AQUIFER PROTECTION SECTION
October 8, 2009
MEMORANDUM
TO: Debra Watts
FROM: Thomas Slusser
RE: Permit To Inject RegenOx
Country Cupboard Convenience Store
I recommend that Permit Number WI0300136 be issued to Sunoco, Inc. to inject RegenOx to remediate ground water
contaminated with gasoline.
SITE DESCRIPTION The site is an operating convenience store located Salisbury, Rowan County. Sunoco, Inc. used to
supply gasoline products, but now BP is the supplier.
HYDROGEOLOGIC DESCRIPTION The site is located in the Carolina Slate Belt of the Piedmont physiographic province.
Bedrock consists of felsic to intermediate intrusive rock types such as granite and diorite. Sandy, clayey saprolite underlies the
site for the full tboaMWdepth of injection and monitoring wells. Typical depth to water has historically been approximately 32
feet.
EXTENT OF CONTAMINATION The gasoline plume is currently detectable in monitoring wells MW-3, MW-5, MW-6,
VMW-7, and includes an area approximately 15 feet by 40 feet; see Figure 4 for well locations. The vertical extent of
contamination is approximately 70 feet.
PROPOSED INJECTION The proposed injection plan consists of three injection events, and each event consists of 200
gallons of RegenOx solution being injected via 4 injection wells. This corresponds to approximately gallons of inj ectant per
linear foot of injection well screened interval.
HOW IT WORKS RegenOx consists of sodium carbonate and sodium percarbonate chemical oxidizers plus ferrous
sulphate as a catalyst that enhances the oxidation power of the (per)carbonates. The chemical oxidants directly destroy
groundwater contaminants and also produce oxygen that remains in solution to stimulate aerobic bioremediation after the
chemical oxidants have been consumed.
MONITORING The proposed monitoring plan will be followed with the following modifications: MW-4,VMW-11,
and the Harris well will be added to the monitoring well network; groundwater samples will be collected prior to injection and
quarterly for one year after the last injection event; and sulphate will be added to the list of analytical parameters.
EPIDEMIOLOGY On September 5, 2007, Dr. Luanne Williams provided comments RegenOx for groundwater
remediation. Dr. Williams did not present any information that would preclude the use of these products for injection but did
provide a health risk analysis and worker safety precautions, which are in Part X of the attached permit.
REGIONAL OFFICE COMMENTS Maria Schutte and Andrew Pitner of the Mooresville Regional Office recommend issuance
of this permit. MRO concerns about using monitoring wells as injection wells have been satisfied since this is a common
practice and there are other monitoring wells available to evaluate the impact of the injection project. Additionally, the
proposed volume of inj ectant is quite low compared to the contaminant plume. MRO staff have indicated that they are okay
with the proposed injection activity after discussing these points with me.

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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
Sunoco, Inc.
FOR THE CONSTRUCTION AND OPERATION OF 4 TYPE 5I INJECTION WELLS, defined in
Title 15A North Carolina Administrative Code 2C .0209(e)(3)(C), to inject RegenOx, to chemically
oxidize gasoline contamination in groundwater. These injection wells/points will be located at
Country Cupboard convenience store, located at 2010 Statesville Boulevard in Salisbury, Rowan
County, North Carolina, and will be operated in accordance with the application submitted June 24,
2009, and in conformity with the specifications and supporting data submitted October 2, 2009, all of
which are filed with the Department of Environment and Natural Resources and are considered apart
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 September 30, 2011,
and shall be subject to the specified conditions and limitations set forth in Parts I through X hereof.
Permit issued this the ' C�I— day of OESI4v/4- , 2009.
Coleen H. Sullins, Director
Division of Water Quality
By Authority of the Environmental Management Commission.
Permit No. WI0300136 PAGE 1 OF 7
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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
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
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.
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.
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 with the
following modifications: (1) monitoring wells MW-4, MW-11, and the Harris well.shall be
added to the monitoring well network; (2) groundwater samples shall be collected prior to the
first injection event and quarterly for one year after the last injection event; (3) sulphate shall
be added to the list of analytical parameters.
2. 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.
3. The Permittee shall submit an Injection Event Record within 30 days of completing each
injection.
4. 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.
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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
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.
7. 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.
8. 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.
Permit No. WI0300136 PAGE 5 OF 7
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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
drinking water.
(D) Drilled wells shall be completely filled with cement or bentonite grout, which. shall be
introduced into the well through a pipe that 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
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PART X — WORKER PRECAUTIONS DURING APPLICATION
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.
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.
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