WI0300154_Permit (Issuance)_20101230

DIVISION OF WATER QUALITY
AQUIFER PROTECTION SECTION
December 30, 2010
PERMIT ISSUANCE MEMO
TO: Debra Watt
THROUGH: Thomas Slusser
FROM: John McCray
RE: Permit To Inject Oxygen (ISOC)
Former Terrell Shell gasoline station Site
I recommend that Permit Number WI0300154 be issued to Acme of South Carolina to inject Oxygen to remediate
groundwater contaminated with hydrocarbons.
SITE DESCRIPTION Hydrocarbons were released to the groundwater through the use of a former UST operated by
a gas station. Contaminants have been known to be in the soil and groundwater at the site since 1995. Prior remedial
activity at the facility has consisted of air sparging and soil vapor extraction. Currently the site is being used as a
location for commercial buildings. Contamination is located within the matrix of sandy saprolite and within the
groundwater of the surficial aquifer, extending into the upper limit of the bedrock. Groundwater flow across the site
diverges off of a groundwater ridge and is moving contaminants to the west-southwest and to the north-west.
HYDROGEOLOGIC DESCRIPTION The site is located within the inner Piedmont Physiographic Province and is
underlain primarily by saprolitic sand and clayey sand derived from underlying bedrock. Within the constraints of the
site, the surficial aquifer is contained within the saprolite and extends down into the fractures of the bedrock (Figures
4 and 5). The average depth to groundwater is 40 feet below ground surface, and it flows to the west-southwest
around to the north-west off of a groundwater ridge under a hydraulic gradient of .013 ft/ft through an aquifer with a
hydraulic conductivity of approximately 0.65 ft/day. The average velocity for groundwater under these conditions is
approximately .04 ft/day.
EXTENT OF CONTAMINATION Contaminant distribution of hydrocarbons for concentrations above the
NCGWQS, within the surficial aquifer based on the most recent sampling event, has a biaxial distribution. The
contaminant plume extends to the west-southwest and to the north-west from a point near the MW-2 area. The
contamination plume extending to the west-southwest is — 200 ft. long and —50 ft. wide, whereas the plume extending
to the north-west is —130ft. long and —76 ft. wide. The plume extends to an overall depth of —80 ft. below ground
surface in the vicinity of monitoring well MW-2D.
PROPOSED INJECTION The applicant proposes to inject oxygen at a moderated pressure to maintain a
dissolved oxygen concentration of 20 to 40 parts per million into the surficial aquifer through 3 shallow and 2 deep
monitoring wells outfitted with ISOC units over a period of five years. The total volume of injectant comprises a
negligible percentage of the injection area.
HOW IT WORKS The main remedial activity of the dissolved oxygen is to provide an electron receptor to cause
degredation of the hydrocarbons.
MONITORING Seven (7) existing monitoring wells located at the site currently being used to monitor for
changes in contaminant concentrations as part of ongoing activities at the site will be used to monitor the injection.
Sampling for constituents will be conducted quarterly using wells MW 1R, MW 1 D, MW5R, MW6, MW9R, MW 13,
and MW 15 in order to measure field parameters pH, dissolved oxygen, oxygen -reduction potential (ORP), .

temperature, and conductivity and to conduct laboratory analysis for VOCs using EPA Method 6200B, sulfate and
nitrate by EPA method 300, alkalinity by EPA method 310.1, methane by RSK SOP-75, dissolved iron, biological
oxygen demand (BOD), and chemical oxygen demand (COD) by appropriate methods. Monitoring will continue for
five years (Table 5).
EPIDEMIOLOGY On May 21, 2002, the DHHS' Epidemiology Branch provided comments on the use of
Oxygen to enhance bioremediation of petroleum groundwater contaminants. Dr. Luanne K. 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 recommended issuance of this
permit upon satisfactory response to an NOV issued for well construction violations.

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
Acme of South Carolina
FOR THE OPERATION OF 5 TYPE 5I INJECTION WELLS, defined in Title 15A North Carolina
Administrative Code 2C .0209(e)(3)(C), to operate an in situ Submerged Oxygen Curtain (iSOC) for
the enhancement aerobic degradation of hydrocarbon contaminants. These injection wells will be
located at site of the former Terrell Shell, 7995 NC Highway 150, Terrell, Catawba County, North
Carolina, and will be operated in accordance with the application submitted September, 1, 2010, and
in conformity with the specifications and supporting data submitted, 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 uiTU1=November 30;_20l 5,
and shall be subject to the specified conditions and limitations set forth in Parts I through X hereof.
Permit issued this the 30a' day of December, 2010.
Coleen H. Sullins, Director
Division of Water Quality
By Authority of the Environmental Management Commission.
Permit No. WIO 100154 PAGE 1 OF 6
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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 isvalid 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 Program
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].
Permit No. WI0300154
ver. Oct.2010
AP/UIC-6
PAGE 2 OF 6

PART III - OPERATION ti1vD 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 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 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 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.
Permit No. WI03001 54 PAGE 3 OF 6
ver. Oct.2010 AP/UIC-6

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. 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 ensure surface and ground water
protection, will be established and an acceptable sampling reporting schedule shall be followed.
2. The Permittee shall submit an Injection Event Record within 30 days of completing each
injection.
3. 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.
4. The monitoring results and the final project evaluation shall be submitted to:
Aquifer Protection Section-UIC Program
DENR-Division of Water Quality
J
1636 Mail Service Center
Raleigh; NC 27699-1636
and to:
Aquifer Protection Section
DENR-DWQ Mooresville Regional Office
610 East Center Avenue, Suite 301
Mooresville, NC 28115 -
Permit No. WI03001 54 PAGE 4 OF 6
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� \ 1
5. The Permittee shall reportby 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.
6. 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.
7. 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 .0214, 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:
(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.
Permit No. WI0300154 PAGE 5 OF 6
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(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 Program
DENR-Division of Water Quality
1636 Mail Service Center
Raleigh, NC 27699-1636
109
PART X — WORKED PRECAUTIONS DURING APPLICATION
1. Some effects reported to be associated with the product proposed to be used are as follows:
irritation to the eyes, nose, and throat; can cause dizziness, nausea, pulmonary irritation leading
to pulmonary edema, and pneumonitis.. Intense and potentially fatal pulmonary edema may
develop tracheal irritation, fever, nausea, vomiting, acute bronchitis, sinusitis, malaise,
paresthesias and conjunctivitis. .
2. The application process should be reviewed by an industrial hygienist to ensure that the most
appropriate personal protective equipment is used.
3. 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.
5. -It is imperative that the Material Safety Data Sheets be followed to prevent incompatible or
adverse reactions and injuries.
Permit No. WI03001 54 PAGE 6 OF 6
ver. Oct.2010 AP/UIC-6