WI0100089_Efile10272020_20201027

Laverty, Brett
From: Davidson, Landon
Sent: Tuesday, August 07, 2012 1:37 PM
To: Stepp, Jonathan; Laverty, Brett
Subject: RE: Tyco Electronics Corporation Injection Permit W10100089 Modification
Just spoke with David Goodrich regarding this email and he says CO is planning a phone call with the consultants. CO
disagrees with this argument and will hold the line or language in the rule as previously communicated. I opted out of
participating on the call.Thanks
L
G. Landon Davidson, P.G.
I.i:EiEI,P-Envisionof*eterOualitp'
Aquifer Protection Section
Pa;ion F.IAPS Supervisor
Asheville Regional Office
20 9 0 U S.Hw-', 7-0
Surannano� N.C. 28fr8
ph.:82 9-29 fr45W
far:R2J2947403 _
web page:http://portal.ncdenr.org/web/wq/aps
Email correspondence to and from this address is subject to
the North Carolina Public Records Law and may be disclosed
to third parties unless the content is exempt by statute or
other regulation.
From: Chris Gilbert [mailto:[e-mail]]
Sent: Thursday, August 02, 2012 6:30 AM
To: Goodrich, David
Cc: Davidson, Landon; Ramey, David E; Foster, Glen L; Evan Yurkovich
Subject: Tyco Electronics Corporation Injection Permit WI0100089 Modification
David,
Thank you for speaking with Evan and I on Thursday,August 1, 2012 about the recent application to modify the
referenced injection permit. As we discussed, in our opinion,the water from RW-07 is not contaminated. It is treated
groundwater mixed with additives. We feel that the treated groundwater from RW-07 can be reintroduced into MW-39
in a manner consistent with the rules. Further information is below. Let us know what you think.
Evidence that the groundwater is treated
Table 2 of the Sodium Permanganate Injection Pilot Test Report submitted to the DENR on February 28, 2011, contains
pre and post pilot test volatile organic compound (VOC) groundwater sample analytical results. Analytical results from
four sampling events are summarized on the table. The August 11, 2010 sampling was conducted 4 days prior to the
pilot test injection and the September 22, October 6, and October 19, 2010 sampling events were conducted after the
pilot test injection was completed. The results from the sampling are summarized as follows:
• The color of the water extracted from RW-07 post injection is bright purple. This is an indication that the
extracted water is primarily excess, unreacted injectant (the injectant was a mixture of potable water and a
concentrated sodium permanganate solution).

• VOC concentrations detected in RW-07 from the pre injection sampling contained exceedances of the 2L
Standard, but post injection samples were non-detect (although the post injection results contained elevated
laboratory reporting limits due to the purple color).
• RW-06 is an adjacent well located a few feet away from the injection well, RW-07 and hydraulically connected to
RW-07, but screened across a deeper interval. Following injection the color of the water in RW-06 was slightly
pink in color. RW-06 contained VOC concentrations over the 2L Standard during the first two sampling events
and then detections were below laboratory reporting limits during the following two sampling events (the post
injection results from RW-06 did not contain appreciably elevated laboratory reporting limits; the reporting limit
changed from about 1.0 to 5.0 micrograms per liter [µg/L] for most analytes and the results were non-detect).
• VOC concentrations detected in nearby observation monitoring well MW-39 are representative of the untreated
groundwater(trichloroethene greater than 150,000 µg/L in all four sampling events). By comparison, it is
obvious that groundwater from RW-07 is treated groundwater.
Rules regarding the reintroduction of treated groundwater
During our correspondence on this topic you cited a couple of rules under Chapter 2,Title 15A of the North Carolina
Administrative Code (NCAC). The rules you cited were 02T SECTION .1600—GROUNDWATER REMEDIATION SYSTEMS
and 02C SECTION .0200—CRITERIA AND STANDARDS APPLICABLE TO INJECTION WELLS. From our discussions I
understand that "WI" permits(like the one we have) are issued pursuant to the 02C .0200 rules and "WQ" permits are
issued pursuant to the 02T.1600 rules.
The 02C .0225 rule allows groundwater remediation wells to be used to inject treated groundwater. The 02C .0225 rule
also says that when on-site contaminated groundwater is used,the groundwater remediation injection wells shall be
permitted in accordance with the 02T .1600 rules. However, in our situation,there are no aboveground treatment
process to permit according to the 02T .1600 rules. We are planning to use on-site treated groundwater and our
groundwater has been treated in-situ in accordance with an approved "WI" permit. In our opinion,the proposed
removal of treated groundwater from RW-07,the storage of the treated groundwater in a tank, and the reinjection of
the treated groundwater into MW-39 under a "WI" permit should be acceptable under the current rules without a
variance.
Sincerely,
-Chris Gilbert
Christopher F. Gilbert, P.E.
Altamont Environmental, Inc.
231 Haywood Street
Asheville, North Carolina 28801
Phone: [phone] ext. 202
Direct Dial: [phone]
Cell: [phone]
Fax: [phone]
[e-mail]
www.altamontenvironmental.com
2

ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
Water Resources LINDA CULPEPPER
Environmental Quality Interim Director
February 9,2018
Richard J. Suminski
Tyco Electronics Corporation
P.O. Box 3608,M/S 038-34
Harrisburg,PA 17105-3608
Subject: Completion of 5I Injection Well Permit WI0100089
Tyco Electronics Corporation
Buncombe County
Dear Mr. Suminski:
On March 14, 2012, the Water Quality Regional Operations Section(Former Aquifer Protection Section)
issued a 5I groundwater remediation permit to the above for the remediation of contaminated groundwater
located at the 1396 Charlotte Highway, Fairview, Buncombe County,NC 28730. Expiration date for the
permit is May 31,2012.
A review of the file indicates the Final Project Evaluation(FPE)has been received,per permit conditions
on February 28,2012. Therefore,this completes the monitoring and compliance reporting requirements of
your permit.
Please be advised this permit is expired and no further injection activities are permitted. Any future
injection activities must be conducted per the requirements of 15A NCAC 2C.0225(Revised May 1,2012).
You must submit either (1) a Notification of Intent to Install groundwater remediation wells, or (2) an
Application for Permit to Construct Wells for Injection(whichever is applicable). Please reference permit
number WI0100089 in any future correspondence for this site. Operating an injection well without a valid
permit could result in a civil penalty of up to$25,000 per day. Please contact Shristi Shrestha at 919-807-
6406 or Debra Watts at 919-807-6338 if you have any questions.
Best Regards,
Shristi Shrestha
Hydrogeologist
Water Quality Regional Operations Section
Division of Water Resources
State of North Carolina I Environmental Quality I Division of Water Resources
Water Quality Regional Operations Section
1636 Mail Service Center I Raleigh,North Carolina 27699-1636
... 919-707-9129

cc: Landon Davidson-Andrew Moore WQROS-Asheville Regional Office
Central Office File,WI0100089
Alec Macbeth,Altamont Environmental Inc.,231 Haywood St.,Asheville,NC 28801

Laverty, Brett
From: Davidson, Landon
Sent: Monday, July 23, 2012 2:55 PM
To: Laverty, Brett
Subject: FW: Tyco Electronics Injection Permit W10100089 Modification
Brett-
Below was the final correspondence on this topic, at least from us.At some point, it would benefit Jonathan to bring him
up to speed on this topic from UIC angle.Thanks.
Landon
G. Landon Davidson, P.G.
I-.CDEI-.P.-Division of N tef Ouelity
Agtiifei Protection 5e;tion 4e
P.egionalAPS Supervisor
Asheville P.egionel Offi:e ,
3090U.S.H•.-,%;. TO
Sv:ennena=. L.C. Z8? 8
pl},;828
web page:http://portal.ncdenr.org/web/wq/aps
Email correspondence to and from this address is subject to
the North Carolina Public Records Law and may be disclosed
to third parties unless the content is exempt by statute or
other regulation.
From: Chris Gilbert [mailto:cgilbertC,aaltamontenvironmental.com]
Sent: Monday, July 23, 2012 10:59 AM
To: Goodrich, David
Cc: Evan Yurkovich; Davidson, Landon
Subject: RE: Tyco Electronics Injection Permit WI0100089 Modification
David,
Thank you for the response. We plan to discuss your recommendation with our client and be back in touch with you
very soon.
Sincerely,
-Chris Gilbert
From: Goodrich, David [mailto:[e-mail]]
Sent: Tuesday, July 17, 2012 1:30 PM
To: Chris Gilbert
Cc: Davidson, Landon
Subject: Tyco Electronics Injection Permit WI0100089 Modification
Mr. Gilbert,
The inability of the well/formation to properly assimilate the injectant mixture has inhibited the injectant's effectiveness
at remediating the contaminated groundwater.
i

After some discussion,we are recommending that a modified permit be issued which would allow the use of"fresh"
injectant in well MW-39._Assuming we can successfully facilitate remediation through a modified permit, an NOV or
other regulatory requirement letter would not be necessary.
Using the untreated recovered (extracted)water from well RW-7 as an injectant into well MW-39 would require the
approval of a variance that would have to be signed by our Director, Charles Wakild. A variance would be necessary
based on the specific language of NCAC 2T.1600 and NCAC 2C .0225 that permit treated groundwater, injectants or
ambient air;that is, not mixtures of extracted contaminated groundwater and previously injected additives.
This would require specific information regarding the amount of extracted water that would be injected into well MW-
39,the ability of well MW-39 to accommodate the intended injection volume, and the concentration of injectant
ingredients (and contaminant substances) in the water to be injected.Variances of this type are unusual and, typically,
only granted under unusual circumstances when other options are not available, or when such options would impose a
significant risk to human health or the environment.
Please take this recommendation under advisement, and feel free to contact us with any questions you may have.
Regards,
David Goodrich, P.G.
Aquifer Protection Section Central Office
Office Telphone Number: [phone]
Aquifer Protection Section Main Number: [phone]
Fax Number: [phone]
2

AQUIFER PROTECTION REGIONAL STAFF REPORT
Date: May 13, 2010 County: Buncombe
To: Aquifer Protection Central Office Permittee: Tyco Electronics Corp.
Central Office Reviewer: Thomas Slusser Project Name: Fairview Facilitv
Regional Login No: Application No.:WI0100089
L GENERAL INFORMATION
1. This application is (check an that apply): ®New ❑ Renewal
❑ Minor Modification❑Major Modification
❑ Surface Irrigation❑ Reuse❑ Recycle❑High Rate Infiltration❑Evaporation/Infiltration Lagoon
❑ Land Application of Residuals ❑Attachment B included ❑ 503 regulated ❑ 503 exempt
❑Distribution of Residuals ❑ Surface Disposal
❑ Closed-loop Groundwater Remediation ® Other Injection Wells(including in situ remediation)
Was a site visit conducted in order to prepare this report? ®Yes or❑No.
a. Date of site visit: May 13,2010
b. Person contacted and contact information: Alec Macbeth(Altamont Environmental) [phone]
c. Site visit conducted by: Brett Laverty
d. Inspection Report Attached: ®Yes or❑No.
2. Is the following information entered into the BIMS record for this application correct?
® Yes or❑No. If no, please complete the following or indicate that it is correct on the current application.
For Treatment Facilities:
a. Location:
b. Driving Directions:
c. USGS Quadrangle Map name and number:
d. Latitude: Longitude:
e. Regulated Activities/Type of Wastes(e.g., subdivision,food processing,municipal wastewater):
For Disposal and Injection Sites:
(If multiple sites either indicate which sites the information applies to, copy and paste a new section into the
document for each site, or attach additional pages for each site)
a. Location(s): 1396 Charlotte Highway Fairview,NC 28730
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b. Driving Directions: Interstate 40 to U.S.74 Alt-E. Stay on U.S.74 Alt-E for 6.1 miles.Facility entrance
on left just past the Food Lion and Fox Run Drive.
i
c. USGS Quadrangle Map name and number: Oteen 35082-E4-TF-024
d. Latitude: 82°24'25.00" Longitude: 350 31' 31.18"
II. NEWAND MAJOR MODIFICATIONAPPLICATIONS(this section not needed for renewals or minor
modifications,skip to next section)
Description Of Waste(S)And Facilities
1. Please attach completed rating sheet. Facility Classification:
FORM: Tyco Electronics UIC Permit.doc 1

AQUIFER PROTECTION REGIONAL STAFF REPORT
2. Are the new treatment facilities adequate for the type of waste and disposal system?
❑ Yes❑No ❑N/A. If no,please explain:
3. Are the new site conditions (soils, topography, depth to water table, etc) consistent with what was reported by
the soil scientist and/or Professional Engineer?❑Yes ❑No ❑N/A. If no,please explain:
4. Does the application (maps, plans, etc.) represent the actual site (property lines, wells, surface drainage)? ❑
Yes❑No ❑N/A. If no,please explain:
5. Is the proposed residuals management plan adequate and/or acceptable to the Division. ❑ Yes ❑No ❑
N/A. If no, please explain:
6. Are the proposed application rates for new sites(hydraulic or nutrient)acceptable?
❑ Yes ❑No ❑N/A. If no,please explain:
7. Are the new treatment facilities or any new disposal sites located in a 100-year floodplain?
❑ Yes ❑ No ❑ N/A. If yes, please attach a map showing areas of 100-year floodplain and please explain
and recommend any mitigative measures/special conditions in Part IV:
8. Are there any buffer conflicts(new treatment facilities or new disposal sites)? ❑ Yes or❑No. If yes, please
attach a map showing conflict areas or attach any new maps you have received from the applicant to be
incorporated into the permit:
9. Is proposed and/or existing groundwater monitoring program (number of wells, frequency of monitoring,
monitoring parameters, etc.) adequate? ❑ Yes ❑ No ❑ N/A. Attach map of existing monitoring well
network if applicable. Indicate the review and compliance boundaries. If No, explain and recommend any
changes to the groundwater monitoring program:
10. For residuals, will seasonal or other restrictions be required? ❑ Yes ❑No ❑ N/A If yes, attach list of sites
with restrictions(Certification B?)
III RENEWAL AND MODIFICATIONAPPLICATIONS(use previous section for new or maior modification
systems)
I
Description Of Waste(S)And Facilities N/A
1. Are there appropriately certified ORCs for the facilities? ❑Yes or❑No.
Operator in Charge: Certificate#:
Backup-Operator in Charge: Certificate#:
2. Is the design, maintenance and operation (e.g. adequate aeration, sludge wasting, sludge storage, effluent
storage, etc) of the treatment facilities adequate for the type of waste and disposal system? ❑ Yes or ❑ No.
If no,please explain:
3. Are the site conditions (soils, topography, depth to water table, etc) maintained appropriately and adequately
assimilating the waste? ❑Yes or❑No. If no,please explain:
FORM: Tyco Electronics UIC Permit.doc 2

AQUIFER PROTECTION REGIONAL STAFF REPORT
4. Has the site changed in any way that may affect permit (drainage added, new wells inside the compliance
boundary, new development, etc.)? If yes, please explainIs the residuals management plan for the facility
adequate and/or acceptable to the Division?
❑ Yes or❑No. If no,please explain:
5. Are the existing application rates (hydraulic or nutrient) still acceptable? ❑ Yes or ❑ No. If no, please
explain:
6. Is the existing groundwater monitoring program (number of wells, frequency of monitoring, monitoring
parameters, etc.) adequate? ❑ Yes ❑ No ❑ N/A. Attach map of existing monitoring well network if
applicable. Indicate the review and compliance boundaries. If No, explain and recommend any changes to the
groundwater monitoring program:
7. Will seasonal or other restrictions be required for added sites? ❑Yes❑No ❑N/A If yes,attach list of sites
with restrictions(Certification B?)
8. Are there any buffer conflicts (treatment facilities or disposal sites)? ❑ Yes or ❑ No. If yes, please attach a
map showing conflict areas or attach any new maps you have received from the applicant to be incorporated
into the permit:
9. Is the description of the facilities, type and/or volume of waste(s) as written in the existing permit correct? ❑
Yes or❑No. If no,please explain:
10. Were monitoring wells properly constructed and located? ❑ Yes or ❑ No ❑ N/A. If no, please explain:
11. Has a review of all self-monitoring data been conducted (GW, NDMR, and NDAR as applicable)? ❑ Yes or
❑No ❑N/A. Please summarize any findings resulting from this review:
12. Check all that apply: ❑ No compliance issues; ❑ Notice(s) of violation within the last permit cycle; ❑
Current enforcement action(s) ❑ Currently under SOC; ❑ Currently under JOC; ❑ Currently under
moratorium. If any items checked, please explain and attach any documents that may help clarify
answer/comments (such as NOV, NOD etc): Have all compliance dates/conditions in the existing permit,
(SOC, JOC, etc.) been complied with? ❑ Yes ❑ No ❑ Not Determined ❑ N/A.. If no, please explain:
i
13. Are there any issues related to compliance/enforcement that should be resolved before issuing this permit? ❑
Yes or❑No ❑N/A. If yes,please explain:
�I
FORM: Tyco Electronics UIC Permit.doc 3

AQUIFER PROTECTION REGIONAL STAFF REPORT
IV INJECTION WELL PERMIT APPLICATIONS(Complete these two sections for all systems that use injection
wells,including closed-loop groundwater remediation effluent injection wells,in situ remediation injection wells,and heat
pump injection wells.)
Description Of Well(S)And Facilities—New,Renewal,And Modification
1. Type of injection system:
❑ Heating/cooling water return flow(5A7)
❑ Closed-loop heat pump system(5QM/5QW)
®In situ remediation(5I)
❑ Closed-loop groundwater remediation effluent injection(5L/"Non-Discharge")
❑ Other(Specify:
2. Does system use same well for water source and injection? ❑ Yes ®No
3. Are there any potential pollution sources that may affect injection?® Yes ❑No
• What is/are the pollution source(s)?Liquid nitrogen and compressed gas cylinders
• What is the distance of the injection well(s)from the pollution source(s)?The liquid nitrogen and
compressed gas cylinders are approximately 25 ft from injection site but separated by an exterior
cinder block wall.
4. What is the minimum distance of proposed injection wells from the property boundary? 125 ft.
5. Quality of drainage at site: ❑ Good ®Adequate ❑ Poor
6. Flooding potential of site: ® Low ❑ Moderate ❑ High
7. For groundwater remediation systems, is the proposed and/or existing groundwater monitoring program
(number of wells, frequency of monitoring,monitoring parameters, etc.)adequate? ® Yes ❑No. Attach
map of existing monitoring well network if applicable. If No, explain and recommend any changes to the
groundwater monitoring program:
8. Does the map presented represent the actual site(property lines,wells, surface drainage)? ®Yes or❑No. If
no or no map, please attach a sketch of the site. Show property boundaries,buildings,wells,potential pollution
sources,roads,approximate scale, and north arrow.
Injection Well Permit Renewal And Modification Only:
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1. For heat pump systems, are there any abnormalities in heat pump or injection well operation(e.g.turbid water,
failure to assimilate injected fluid,poor heating/cooling)?
❑Yes ❑No. If yes, plain:
2. For closed-loop heat pump systems,has system lost pressure or required make-up fluid since permit issuance
or last inspection?❑ Yes ❑No. If yes, explain:
3. For renewal or modification of groundwater remediation permits(of any type),will
continued/additional/modified injections have an adverse impact on migration of the plume or management of
the contamination incident? ❑ Yes ❑No. If yes, plain:
FORM: Tyco Electronics UIC Permit.doc 4

AQUIFER PROTECTION REGIONAL STAFF REPORT
4. Drilling contractor: Name:
Address:
Certification number:
5. Complete and attach Well Construction Data Sheet.
FORM: Tyco Electronics UIC Permit.doc 5

AQUIFER PROTECTION REGIONAL STAFF REPORT
V. EVALUATIONAND RECOMMENDATIONS
1. Provide any additional narrative regarding your review of the application.:
• There is no contingency plan for accidental spillage or potential daylighting of the injection fluid.
A storm drain is located approximately 25 ft from the injection fluid mixing area.
• Altamont Environmental will be diluting the sodium permanganate with municipal water.Are
there any potential unfavorable reactions between chlorine and the injection fluid?
2. Attach Well Construction Data Sheet- if needed information is available
3. Do you foresee any problems with issuance/renewal of this permit? ❑Yes ®No. If yes,please explain
briefly.
4. List any items that you would like APS Central Office to obtain through an additional information request.
Make sure that you provide a reason for each item:
Item Reason
5. List specific Permit conditions that you recommend to be removed from the permit when issued. Make sure
that you provide a reason for each condition:
Condition Reason
6. List specific special conditions or compliance schedules that you recommend to be included in the permit when
issued. Make sure that you provide a reason for each special condition:
Condition Reason
7. Recommendation: ❑ Hold,pending receipt and review of additional information by regional office; ❑ Hold,
pending review of draft permit by regional office; ❑ Issue upon receipt of needed additional information;
Issue; ❑ Deny. If deny,please state reasons:
8. Signature of report preparer(s):
Signature of APS regional supervisor:
FORM: Tyco Electronics UIC Permit.doc 6

AQUIFER PROTECTION REGIONAL STAFF REPORT
Date:
ADDITIONAL REGIONAL STAFF REVIEW ITEMS
FORM: Tyco Electronics UIC Permit.doc 7