WI0300150_Permit_20101007

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
A&G Real Estate, LLC
FOR THE CONSTRUCTION AND OPERATION OF 2 TYPE 51 INJECTION WELLS, defined in
Title 15A North 'Carolina Administrative Code 2C .0209(e)(3)(C), to inject a 3-D Microemulsion
6
solution for the efihancement of bioremediation of chlorinated ethenes. These injection points will
be located at the N . issan West Automotive Dealership Site, 2755 East Franklin Boulevard, Gastonia,
Gaston County, No , ith Carolina, and will be operated in accordance with the application submitted
June 25, 2010, and in conformity with the specifications and supporting data submitted August 23,
2010, all of which are filed with the Department of Enviromnent and Natural Resources and are
considered a part of this, permit.
This permit is for Construction and Operation only, and do'es 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 1'5A North Carolina Administrative Code 2C.01 00 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 30,2010,
and shall be subject to the specified conditions and limitations set forth in Parts I through X hereof.
A --
Permit issued this the -7 dayof Ocj)bk'S� ,2010.
,(J& �, L4
Coleen H. Sullins, Director
Division *of Water Quality
By Authority of the Environmental Management Commission.
Permit No. W10300150 PAGE 1 OF 7
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PART I -WELL CONSTkuCTION 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 (15ANCAC 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 pen -nit 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.
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
I
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 11 - WELL CONSTRUCTION SPECIAL CONDITIONS
At least forty-eight (48) hours priorto constructing each injection well, the Permittee shall notifythe
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].
Pennit No. W10300150 PAGE20F7
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PART III - OPERATION AND USE GENERAL CONDITI(jiN6'
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 P ennittee, 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 Pennittee 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 perforin 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 abandomnent 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 Pennittee 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. W10300150 PAGE 3 OF 7
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PART VI - INSPECTION!�- -
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. In addition to the proposed monitoring well network identified for quarterly sampling* in the
permit application, the applicant shall add MWs-1 and -2 to be included with those wells to be
sampled quarterly. I
2. The proposed monitoring plan needs to be extended for two more quarterly events The proposed
monitoring plan included,in the application shall be followed. 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.
5. The monitoring results and the final project evaluation shall be submitted to:
Aquifer Protection Section-UIC Staff
DENR-Division of Water Quality
1636 Mail Service Center
Raleigh, NC 27699-1636
Permit No. WI0300150 PAGE 4 OF 7
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and to:
Aquifer Protection Section
DENR-DWQ Mooresville Regional Office
C
610 East Center Ave. Suite 3 01
Mooresville, NC 28115
6. The Pem-littee 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 maybe 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
I . 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. Ifa
well is not to be used for any purpose that well must be permanently abandoned according to,
15A NCAC 2C .0 113, 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 .0 113 (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.
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(B) The entire depth oi -each well shall be sounded before it is seated 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 tenns 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 associaied with the product proposed to be used are as follows: eye,
skin, nose,'throat, lungs and gastrointestinal irritation or bums. 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.
Eating, drinking, smoking, handling contact lenses, and applying cosmetics should not be
permitted in the application area during or immediately following application.
4. Site access should be limited to worker's. involved in the injection of the solution. Safety
controls should be in place to ensure that the check valve and the pressure delivery systems are
working properly.
Permit No. WI0300150 PAGE60F7
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5. The Material Safety Data Sheets should be followed to prevent incompatible or adverse reactions
and injuries.
Permit No. W10300150 PAGE 7 OF 7
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y.,
DIVISION OF WATER QUALITY
AQUIFER PROTECTION SECTION
October 4, 2010
PERMIT ISSUANCE MEMO
TO: Debra Watts
THROUGH: Thomas Slusser—IS
FROM: John McCray�`�''7
RE: Permit To Inject 3-D Microemulsion (3DMe) and water
Nissan West Automotive Dealership Site
I recommend that Permit Number WI0300150 be issued to A&G Real Estate, LLC to inject 3-D Microemulsion and
water to remediate groundwater contaminated with Tetrachloroethene (Tei )
SITE DESCRIPTION The site has operated as an automotive dealership since approximately 1986. There is one
proposed injection area located adjacent to the main building in the area of the former oil/water separator. The source
of contamination is from the operation of the oil/water separator.
HYDROGEOLOGIC DESCRIPTION The site is underlain by 12 to 16 feet of artificial fill placed after the removal
of alluvial soils during the initial clean-up of the site. Down -gradient of and underlying the fill, alluvial sandy silt
associated with Duhart's Creek underlies the site and extends to depths greater than 20 feet. Borings at the site were
not extended into the underlying residuum because of the limited depth of contamination. Depth to groundwater
ranges from 10 ft to 12 ft and flows east across the site toward Duhart's Creek at a rate of approximately 188 ft per ear
under a hydraulic gradient of 0.02 ft/ft.
EXTENT OF CONTAMINATION Contamination at this site is confined within the alluvium ly extends a
relatively short distance from the source. The PCE plume is elliptical in shape and extends to northe t from the
former location of the oil/water separator— 21 ft. and — 15 ft. wide. The maximum concentration o measured at
the proposed injection site has been measured as high as 53.3ug/L. After the soil removal, the fUE concentration was
measured to be 2.Oug/L.
PROPOSED INJECTION The Applicant proposes one injection event using a 3DMe solution to stimulate
reductive dechlorination of RCE contamination underlying the site. Injection will occur at through two temporary
push points at a depth interval from 1 Oft-20ft. The injection event will total — 73% of the adjacent pore volume, and
will total 685 gallons. The high pore volume percentage is not a high concern because of a conservative 10% .
effective porosity value used by the consultant.
HOW IT WORKS 3-D Microemulsion is a mixture of esterified lactic and fatty acids that an
electron donor to stimulate reductive dechlorination.
MONITORING Groundwater monitoring was proposed to be conducted using on monitoring well, MW-3.
However, both central and regional office staffs feel that adding monitoring wells MW-1 and 2 will provide adequate
monitoring of down -gradient aquifer conditions. The proposed monitoring plan was for an initial monitoring event to
be conducted one month following the injection event then quarterly thereafter for 2 more sampling events. This
schedule is being extended by APS staff to four quarterly events because of the longevity of the injectant. Slev
es
will be analyzed for volatile organics by EPA Method 6200B. At the request of regional office staff, MAC
included measuring field parameters dissolved oxygen and oxidation reduction potential during sampling ts.
Monitoring well data is provided in Attachment G and parameters are summarized in Attachment F.
—z� —

EPIDEMIOLOGY On January 17, 2007, the DHHS' Epidemiology Branch provided comments on 3DMc for
groundwater remediation. Dr. Luanne 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 of the Mooresville Regional Office recommends issuance of this
permit. Her recommendation was made based on information provided by MACTEC in an Addendum dated August
13,2010.