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Home My WebLink AboutWI0300154_Complete File - Historical_20100830GMA Groundwater Management Associates, Inc. August 30, 2010 Mr. Thomas Slusser, PG Program Manager UIC Program — Aquifer Protection Section NCDENR — Division of Water Quality 1636 Mail Service Center Raleigh, North Carolina 27699-1636 2205 A Candun Drive Apex. North Carolina 275X Telephone (919) 363-6310 Facsimile (919) 363-6203 www.gmo-nc.com Re: Application for Permit to Construct And/Or Use A Well(s) for Injection — Type 5I Wells Former Terrell Shell, NC Highway 150 and Sherrill's Ford Rd, Terrell, Catawba County UST Incident Number # 15677, Risk Classification: High (395D) Dear Mr. Slusser: On behalf of Acme of South Carolina, Inc., GMA is submitting two copies of the Application for Permit to Construct a Well for Injection. In the New Technology Cleanup Plan for the site, GMA recommended the use of the In -Situ Submerged Oxygen Curtain (iSOC) to address the remaining dissolved phase hydrocarbons present above the North Carolina 2L groundwater standards. The application and additional information, including pertinent tables and figure, are attached. Mr. William Lyke, PG, PE is signing and sealing this letter for the sections relating to site geology and hydrogeology. Mr. Matthew Tendam, PE is signing and sealing this letter for all other portions of the application A Should you have any questions or please do not hesitate to contact me at 919.363.63,10 a•`.`� C ►,� Sincerely, �� : • • • •�iy%� t GMA ��Slp�. y = t _. 8 T w c ♦O C f0 5� 0 �\ f Matthew J. Tenda.50 m, PE ''-ga• c�',�GIN//ti��` William L. Lyke, PG, PE Project Engineer ii/;/.(��\, Sr. Hydrogeologist/Civil Engineer Enclosure: UIC Permit Application and Attachments cc: Steve DeGeorge RECEIVED I DENR / DWQ AQUIFER PRnTFrTIr)N SECTION SEP 01 2010, The Groundwater Experts Acme of South Carolina, Inc. August 19, 2010 Steven DeGeorge Robinson, Bradshaw and Hinson 101 North Tryon Street, Suite 1900 Charlotte, NC 28246 RE: Letter authorizing you as agent with regards to former Terrell Shell (Incident No. 15677) environmental matters. Dear Mr. DeGeorge: I write this letter to you on behalf of Acme of South Carolina, Inc., hereby authorizing you as agent for the company with regards to environmental and cleanup matters at the property formerly known as "Terrell Shell' at 7995 NC Highway 150, Terrell, NC 28682 (NCNENR Incident No. 15677). Sincerely, Mark Roberts Vice President 4973 Willow Pond Rd. I Gastonia, NC 28056 1 704.854,3399 1 Fax: 704.866.8603 State of North Carolina Department of Environment and Natural Resources Division of Water Quality APPLICATION FOR PERMIT TO CONSTRUCT AND/OR USE A WELL(S) FOR INJECTION Type 5I Wells — In. Situ Groundwater Remediation / Type 5T Wells — Tracer Injection • Do not use this form for remediation systems that extract contaminated groundwater, treat it, and reinject the treated groundwater. • Submit TWO copies of the completed application and all attachments to the address on the last page of this form. • Any changes made to this form will result in the application package being returned. Application Number (to be completed by DWQ): I. GENERAL INFORMATION: 1. Applicant's Name (generally the responsible party): Acme of South Carolina 2. Signing Official's Name*: Steven DeGeorge Title: Attorney * Signing Official must be in accordance with instructions in part VI on page 7. 3. Mailing address of applicant: Robinson, Bradshaw and Hinson 101 North Tryon Street, Suite 1900 City: Charlotte State: NC Zip Telephone number: 704.377.8380 Fax number: 704.373.3980 4. Property Owner's Name (if different from Applicant): Mr. CarollLinebeger, Sr. 5. Property Owner's mailing address: P.O. Box 385 28246 City: Terrell State: NC Zip: 28682 6. Name and address of contact person who can answer questions about the proposed injection project: Name: Matthew Tendam, PE Title: Project Engineer Company: Groundwater Management Associates, Inc. Address: 2205 A City: Apex State: NC Zip: 27523 Telephone number: 919.363.6310 Fax number: 919.363.6203 Email 11. PERMIT INFORMATION: Project is. New ( Modification of existing permit ( Renewal of existing permit without modification Renewal of existing permit with modification If this application is being submitted for renewal or modification to an existing permit, provide: existing permit number and the issuance date For renewal without modifications, fill out sections I & H only, sign the certification on the last page of this form, and obtain the property owner's signature to indicate consent (if the applicant is not the owner). For all renewals, submit a status report including monitoring results of all injection activities to date. Revised 6/09 UIC-5I/5T RECEIVED / DENR / DWQ Page 1 of 7 AQUIFFR"PRnTFrTnN SECTION CEP 01 2010 APPLICATION FOR PEI',= 1I TO CONSTRUCT AND/OR USE A ,�;LL(S) FOR INJECTION Type 5I Wells — In Situ Groundwater Remediation / Type 5T Wells — Tracer Injection III. INCIDENT & FACILITY DATA A. FACILITY INFORMATION 1. Facility name: Former Terrell Shell 2. Complete physical address of the facility: 7995 NC Highway 150 CfE`� p9 edrl}- State: NC Zip: 28682 City: Terrell County: p: B. INCIDENT DESCRIPTION 1. Describe the source of the contamination: Petroleum hydrocarbons were discovered in October of 1995 when soil samples were collected during the closure and removal of five USTs at the site. The UST system was removed when the former Terrell Shell gas station/store closed in 1995. The release occurred from four previously installed USTs removed from the site in 1995. The system contained four gasoline USTs, and one 550-gallon orphaned kerosene tank. 2. List all contaminants present in soils or groundwater at the site (contaminants may be listed in groups, e.g., gasoline, diesel, jet fuel, fuel oil, chlorinated ethenes, chlorinated ethanes, metals, pesticides/herbicides, etc): Benzene, toluene, ethylbenzene, xylenes, MTBE, naphthalene, IPE 3. Has LNAPL or DNAPL ever been observed at the site (even if outside the injection zone)? ( Yes If yes, list maximum measured separate phase thickness feet (No f no, list maximum concentration of total VOCs observed at site: 26,740 (4/10) ppb 4. Agenc managing the contamination incident: UST Sectio ( Superfund Section (including REC Program and DSCA sites) ( DWQ Aquifer Protection Section ( Solid Waste Section ( Hazardous Waste Section ( Other: Incident managers name Brad Newton and phone number. 704.663.1699 6. Incident number or other site number assigned by the agency managing the contamination incident: 15677 C. PERMITS List all permits or construction approvals that have been issued for the facility or incident, including those not directly related to the proposed injection operation: 1. Hazardous Waste Management program permits under RCRA: NA 2. DWQ Non -Discharge or NPDES permits: NA 3. County or DEH subsurface wastewater disposal permits: NA Other environmental permits required by state or federal law: well construction permits for off -site monitoring wells Revised 6/09 UIC-5I/5T Page 2 of 7 APPLICATTON FOR PEh . ' T TO CONSTRUCT AND/OR USE A-.;LL(S) FOR INJECTION Type 5I Wells —In Situ Groundwater Remediation / Type 5T Wells — Tracer Injection IV. INJECTION DATA A. INJECTION FLUID DATA 1. List all proposed injectants. NOTE: Any substance to be injected as a tracer or to promote in situ remediation must be reviewed by the Occupational and Environmental Epidemiology Section (OEES) of the Division of Public Health, Department of Health and Human Services. Review the list of approved injectants or contact the UIC Program to determine if the injectants you are proposing have been reviewed by OEES. Injectant: Oxygen via inSitu Submerged Oxygen Curtain 0SOC) Concentration at point of injection: 20-40 ppm Percent if in a mixture with other injectants: Injectant: Concentration at point of injection: Percent if in a mixture with other injectants: Injectant: Concentration at point of injection: Percent if in a mixture with other injectants: Injectant: Concentration at point of injection: Percent if in a mixture with other injectants: 2. Source of fluids used to dilute or chase the injectants listed above: None ( Municipal water supply ( Groundwater from private well or any well within''/4 mile of injection site ( Air ( Other: 3. If any well within 'A mile of injection site, a private well, or surface water is to be used as the fluid source, supply the following information: a. Location/ID number of source: b. Depth of source: c. Formation: d. Rock/Sediment type: e. In Attachment C, provide a current, complete chemical analysis of the water from the source well, including analyses for all contaminants suspected or historically recognized in soil or groundwater on the site. NOTE: If contaminated groundwater is to be used as the dilution or chase fluid, this is not the properpermit application form. You must apply for a closed -loop groundwater remediation permit using application form GWRS. Revised 6/09 UIC-5I/5T Page 3 of 7 l APPLICATION FOR PEI'�, , �T TO CONSTRUCT AND/OR USE A' .4;LL(S) FOR INJECTION Type 5I Wells — In Situ Groundwater Remediation / Type 5T Wells — Tracer Injection B. PROPOSED OPERATING PARAMETERS 1. Duration of Injection: 5 years a. Maximum number of separate injection events: continuous b. Expected duration of each injection event: continuous c. Expected duration between events (if more than one event): 2. Injection rate per well: NA gallons per minute (gpm) 3. Total Injection volume: NA gallons per day (gpd); gallons per event (if separate events) 4. Injection pressure: NA pounds/square inch (psi) 5. Temperature at point of injection: 65 OF 6. Briefly describe how the above parameters will be measured and controlled: The iSOC units are attached to oxvLaen cvlinders and a pressure reLFulator. The concentration of oxveen iniected will be estimated from the rate of use of the oxygen cylinders . 7. Estimated hydraulic capacity of the well: NA gpm C. INJECTION WELL CONSTRUCTION DATA 1 ( Existing well(s) proposed for use as an injection well. Provide the data in (2) through (6) below to the best c our knowledge. ( Proposed well(s) to be constructed or use as an infection we .Provide the data in (2) throug�(6) elow as proposed construction specifications. 2. Well Drilling Contractor's Name: unknown NC Well Contractor Certification number: unknown 3. Date to be constructed: NA Number of borings: Approximate depth of each boring (feet): 4. Screened interval/Injection interval of injection wells: Depth: 30 to 105 feet below ground surface (if multiple intervals, indicate shallowest and deepest depth). 5. Well casing (N/A if injection is through direct push rods): Type: QPVC ( Stainless steel( Other: Casing depth: to ft. 6. Grout (N/A if injection is through direct push rods): Type: Cement Bentonite ( Other: Grout depth: 3 to 98 ft. Revised 6/09 UIC-5I/5T Page 4 of 7 APPLICATION FOR PEY -:ELT TO CONSTRUCT AND/OR USE A , �LL(S) FOR INJECTION Type 5I Wells —In Situ Groundwater Remediation / Type 5T Wells — Tracer Injection V. ATTACHMENTS Provide the following items as separate attachments with the given headings: A. SITE HISTORY Provide a brief description of the site history including: (1) site usage historically and present, (2) origin of the contamination, (3) previous remedial action(s). NOTE.- G.S. 89E-18 requires that any geologic plans, reports, or documents in which the performance is related to the public welfare or safeguarding of the environment be prepared by a licensed geologist or subordinate under their direction. G.S. 89E-13 requires that all drawings, reports, or documents involving geologic work prepared or approved by a licensed geologist, or a subordinate under their direction, be signed and sealed by the licensed geologist. B. HYDROGEOLOGIC DESCRIPTION Provide a hydrogeologic description, soils description, and cross section of the subsurface to a depth that includes the known or projected depth of contamination. The hydrogeologic description shall include: (1) the regional geologic setting; (2) significant changes in lithology; (3) the hydraulic conductivity, transmissivity, and specific yield of the aquifer to be used for injection, including a description of the test(s) used to determine these parameters; and (4) the depth to the mean seasonal high water table. C. INJECTION FLUID COMPOSITION Describe the chemical, physical, biological and radiological characteristics of each injectant. Attach the Material Safety Data Sheet (MSDS) for each injectant. If a private well or a well within 'A mile of the injection site is used as the source well, include chemical analysis of source fluid here. D. INJECTION RATIONALE Attach a brief description of the rationale for selecting the injectants and concentrations proposed for injection, including: (1) goals of the injection project; (2) explanation and/or calculations of how the proposed injectant volume and concentration were determined; (3) a description of the reactions between the injectants and the contaminants present including specific breakdown products or intermediate compounds that may be formed by the injection; and (4) summary results of modeling or testing performed to investigate the injectant's potential or susceptibility to change (biological, chemical or physical) in the subsurface. E. INJECTION PROCEDURE AND EQUIPMENT Provide a detailed description of all planned activities related to the proposed injection including but not limited to: (1) construction plans and materials; (2) operation procedures; (3) a detailed diagram of the surface and subsurface portions of the system; and (4) a planned injection schedule. Revised 6/09 UIC-5I/5T Page 5 of 7 APPLICATION FOR PE�T TO CONSTRUCT AND/OR USE A j'LL(S) FOR INJECTION Type 5I Wells — In Situ Groundwater Remediation / Type 5T Wells — Tracer Injection F. MONITORING PLAN Provide a plan for monitoring the results of the injection, including: (1) a list of existing and proposed monitoring wells to be used; (2) a list of monitoring parameters and analytical methods to be used; and (3) a schedule for sampling to monitor the proposed injection. NOTE: The selected monitoring wells must be located so as to detect any movement of injection fluids, process by- products, or formation fluids outside the injection area or zone. The monitoring parameters should include the target contaminants as well as secondary or intermediate contaminants which may result from the injection and other parameters which may serve to indicate the progress of the intended reactions, such as pH, ORP, dissolved oxygen, and other electron acceptors and donors. The monitoring schedule should be consistent with the pace of the anticipated reactions and rate of transport of the injectants and contaminants. G. WELL DATA Provide a tabulation of data on all existing or abandoned wells within 'Amile of the injection well(s) which penetrate the proposed injection zone, including, but not limited to, monitoring wells and wells proposed for use as injection wells. Such data shall include a description of each well's use (water supply, monitoring, etc), total depth, screened or open borehole depth interval, and well construction or abandonment record, if available. H. MAPS Attach the following scaled, site -specific maps: (1) Area map based on the most recent USGS 7.5' topographic map of the area, at a scale of 1:24,000 and showing the location of the proposed injection site. (2) Site map including: a. - all property boundaries; b. all buildings within the property boundary; c. existing and proposed injection wells or well field(s) d. any existing sources of potential or known groundwater contamination, including waste storage, treatment or disposal systems within '/4 mile of the injection well or well system; e. all surface water bodies within 'A mile of the injection well or well system; and f. all existing or abandoned wells within'/4 mile of the injection well(s) which penetrate the proposed injection zone, including, but not limited to, monitoring wells and wells proposed for use as injection wells. (3) Potentiometric surface map(s) including: a. direction of groundwater movement b. existing and proposed monitoring wells c. existing and proposed injection wells (4) Contaminant plume map(s) including: a. the horizontal extent of the contaminant plume, including isoconcentration lines b. existing and proposed monitoring wells c. existing and proposed injection wells (5) Cross-section(s) to the known or projected depth of contamination, including: a. horizontal and vertical extent of the contaminant plume, including isoconcentration lines b. major changes in lithology c. existing and proposed monitoring wells d. existing and proposed injection wells Revised 6/09 UIC-5I/5T Page 6 of 7 APPLICATION FOR PERMIT TO CONSTRUCT AND/OR USE A WELL(S) FOR INJECTION Type 5I Wells —In Situ Groundwater Remediation / Type 5T Wells —Tracer Injection VI. CERTIFICATION (to be signed as required below or by that person's authorized agent) NCAC 15A 2C .021 l(b) requires that all permit applications shall be signed as follows: 1. for a corporation: by a responsible corporate officer 2. for a partnership or sole proprietorship: by a general partner or the proprietor, respectively 3. for a municipality or a state, federal, or other public agency: by either a principal executive officer or ranking publicly elected official 4. for all others: by the well owner. If an authorized agent is signing on behalf of the applicant, then supply a letter signed by the applicant that names and authorizes their agent. I hereby certify under penalty of law that I have personally examined and am familiar with the information submitted in this document and all attachments therein, and that, based on my inquiry of those individuals immediately responsible for obtaining said information, I believe that the information is true, accurate, and complete. I am aware that there are penalties, including the possibility of fines and imprisonment, for submitting false information. I agree to construct, operate, maintain, repair, and if applicable, abandon the injection well(s) and all related appurtenances in accordance with the approved specifications and conditions of the Permit. Printed Name apade Si Date: /�/ to VII. CONSENT OF PROPERTY OWNER (if the property is not owned by the applicant) ("Oivner" means any person who holds the fee or other properol rights in the well being conshructed tl well is real property and its construction on land shall be deemed to vest ownership in the land owner, in the absence of contrary agreement in writing.) As owner of the property on which the injection well(s) are to be constructed and operated, I hereby consent to allow the applicant to construct each injection well as outlined in this application and agree that it shall be the responsibility of the applicant to ensure that the injection well(s) conform to the Well Construction Standards (Title 15A NCAC 2C .0200). Printed Name an -Title: l.L cw a. Signature: Revised 6/09 Date: �?- Z S — % D Submit TWO copies of the completed application package, including all attachments, to: UIC Program Aquifer Protection Section North Carolina DENR-DWQ 1636 Mail Service Center Raleigh, NC 27699-1636 Telephone (919) 733-3221 RECEIVED 1DENR/DWQ A0UIFFR-PR0TFr,T1rin1 cECTION UIC-5I/5T SEP 01 Zulu Page 7 of Permit Application Attach men ' Former Terrell Shell 7995 NC Highway 150 Terrell, Catawba County, North Carolina NCDENR Incident 15677 A. SITE HISTORY The presence of petroleum -contaminated soil and groundwater was confirmed at the former Terrell Shell (N350 16' 40", W810 3' 42'�, located at the intersection of NC. Highway 150 and Sherrill's Ford Road, Terrell, Catawba County (Figures 1 & 2). Initial soil sampling indicated soil was contaminated with gasoline -range petroleum hydrocarbons. Hydrocarbon concentrations from these samples ranged from <10 parts per million (ppm) to 956 ppm as reported in the 1997 Comprehensive Site Assessment . In October 2000, a remediation system incorporating components of air sparging (AS) and soil vapor extraction (SVE) was installed at the site. One purpose of the SVE system was to withdraw vapors and free product from the subsurface through SVE wells. Historically, there have been several occasions where the SVE and AS systems have not been operational. Prior to June 25, 2002, the remediation system had been off for an undetermined amount of time. The remediation system was restarted in June 2002. The system operated until December 2004 when, by order of the North Carolina Department of Environment and Natural Resources (NCDENR), directed work was suspended at the site and the remediation system was shut down. The remediation system was re -started in February 2007 after the NCDENR issued an order to resume directed work at the site. B. HYDROGEOLOGIC DESCRIPTION The site is located at an elevation of approximately 850 feet above mean sea level. The site's geographic area is characterized by low rounded hills and shallow valleys usually containing some type of surface drainage. The site appears to be located along the axis of a groundwater divide that axis divide trends in mostly northwest to southeast. The site is underlain to at least 70 feet by soils consisting primarily of poorly sorted, medium- to fine-grained sand size particles exhibiting saprolitic texture with minor feldspar. These residual soils (saprolite) were derived from the chemical weathering of the underlying parent rock. The soils observed at the site consist primarily of the B and C Horizons. The B Horizon consist of resistant minerals, clay minerals, and minor amount of hematite or limonite. The C Horizon underlies the B Horizon and overlies the parent rock. The C Horizon consist of partially weathered parent rock retaining much of the original structures and textures of the original parent material. Secondary permeable structures (joints, fractures, and minor schistocity) were noted in the C Horizon soil exposed along area roadcuts. Bedrock, consisting of mostly quartz rich, fine grained meta -volcanic or igneous lithology occurs at irregular depths beneath the site. 1 +'C Permit Application AttachmeW_- Former Terrell Shell 7995 NC Highway 150 Terrell, Catawba County, North Carolina NCDENR Incident 15677 A trace of hydrogeological cross sections is shown in Figure 3. Representative hydrogeologic cross sections are included as Figures 4 and S. The cross sections were developed from limited historical boring logs. The lithologic contacts shown in the cross sections is approximate and inferred in some areas. Monitoring well construction details are included in Table 1 and recent groundwater gauging data are provided in Table 2. A summary of historical groundwater elevation data is included in Appendix I. An equipotential map of the water -table surface (surficial aquifer) for April 26, 2010, is shown in Figure 6. Groundwater flow was mostly to the west and northwest that day which is consistent with historical groundwater flow data. Groundwater generally migrates radially from a topographic ridge along which NC 150 and Sherrill's Ford Road were built (Figure 1). Historical groundwater flow directions have ranged from west to northwest of the site but appears that the plume has migrated primarily to the west (discussed below). The average depth to groundwater on April 26, 2010 was approximately 39 feet below ground surface (bgs) at an approximate horizontal hydraulic gradient of 0.013 feet/foot between MW1R and MWBR (Figure 6). On April 26, 2010, the hydraulic head at "shallow" well MW1R was 0.43 feet higher than that at "deep" well MW1D (Table 2), which equates to a downward -directed hydraulic gradient of approximately 0.01 feet/foot. The hydraulic head at well MW2D was 1.75 feet lower than that at well MW1D (Table 2), which equates to a downward -directed hydraulic gradient into bedrock of approximately 0.055 feet/foot. The hydraulic head at well MW2D was 2.18 feet lower than that at well MW1R (Table 2), which equates to a downward -directed hydraulic gradient of approximately 0.032 feet/foot between these two wells. Downward vertical gradients have been consistently measured between MW1R/MW1D and MW1D/MW2D. It is possible the use of the on -site WSW (WSW -IA) and possibly vicinity WSWs were creating the vertical gradient. Also the site is positioned on a natural groundwater recharge area where a large component of groundwater flow is directed downward. A hydraulic conductivity (K) of 0.65 ft/min was reported for the site in the Corrective Action Plan dated April 22, 1999. Reportedly, this K value was calculated from rising head slug test data from performing slug tests on MW3 and MW4. A full copy of the CAP could not be located so GMA cannot verify that this value is accurate A horizontal groundwater flow velocity was also calculated`in the CAP. Based on that calculation, it appears that 0.65 ft/day was used as K and the reporting of K in feet/minute was erroneous. Reportedly, the K was calculated based on pumping tests performed on wells MW3 and MW4. Using a K of 0.65 ft/day, an assumed effective porosity of 0.2 and the April 2010 horizontal gradient, an average horizontal groundwater velocity was calculated as approximately 15 ft/year. The depth to water averages 40 feet bgs with approximate 10 foot seasonal changes. 2 _,1C Permit Application Attachmem Former Terrell Shell 7995 NC Highway 150 Terrell, Catawba County, North Carolina NCDENR Incident 15677 C. INJECTION FLUID COMPOSITION The proposed injectant is high concentrations of oxygen delivered by the in Situ Oxygen Curtain (iSOC). Oxygen will be injected into the subsurface via existing monitoring wells. Concentrations of oxygen injected will be in the 20 to 40 parts per million (ppm) range. D. INJECTION RATIONALE Processes ofNatural Attenuation and Biodegradation Dissolved oxygen (DO), temperature, pH, conductivity, oxygen reducing potential (ORP) and carbon dioxide measurements were collected from select wells (listed below) during the groundwater -sampling event conducted on February 10, 2010. Additionally, on February 10, 2010 groundwater samples from select monitoring wells (MW1D, MW1R, MW5R, MW6, MW9R, MW13 and MW15) were collected to evaluate if the anaerobic conditions exist at the site. The samples were transferred to Prism Laboratories of Charlotte, North Carolina for analysis of nitrate and sulfate by EPA Method 300, alkalinity by EPA Method 310.1, and methane by RSK SOP-75. A summary of historical field collected groundwater quality data is included as Table 3, and field collected and analytical data for NA parameters are included as Table 4. Table 8 shows a summary of selected parameters that are affected by aerobic (>2 mg/L DO), anoxic (1-2 mg/L DO), and anaerobic (0 mg/L DO). Dissolved hydrocarbon constituents remain in the subsurface at the site providing a continued organic carbon food source for microbes. Natural attenuation and degradation of petroleum hydrocarbons generally utilizes terminal electron acceptors (TEA) along the following continuum: DO followed by nitrate then ferrous iron followed by sulfate, and finally methane. Carbon dioxide and methane are produced as a byproduct of specific biodegradation processes. Changes in alkalinity and pH also occur as a result of certain biodegradation processes. Methane can be used in methanogenesis to degrade hydrocarbons under anaerobic conditions. Aerobic Degradation DO is an important parameter to monitor as hydrocarbons degrade most readily under aerobic conditions. In April 2010, measured DO concentrations ranged from 0.30 to 6.4 mg/L. In general, DO concentrations were lower in April 2010 compared to February 2010 and October 2009 DO concentrations. In source area wells MW1D, MW1R, and MW9R, DO was measured at less than 1 mg/I in April 2010. This indicates the source area is anoxic or anaerobic. Negative ORP values measured in these same wells support the assumption that the source area is 3 _�C Permit Application Attachmen� Former Terrell Shell 7995 NC Highway 150 Terrell, Catawba County, North Carolina NCDENR Incident 15677 anoxic or anaerobic. Comparing source area DO concentrations to up -and downgradient concentration indicates that aerobic degradation has occurred in the past. Source area DO concentrations are generally depleted relative to areas outside the plume. It appears that site conditions have been historically amenable to aerobic degradation. Anaerobic Degradation Parameters to evaluate anaerobic degradation have only been collected once at the site so time trend conclusions cannot be drawn at this time. As described previously, hydrocarbons biodegrade utilizing TEA along the continuum of oxygen followed by ferrous iron then nitrate followed by sulfate and finally methane. A brief discussion of each of these parameters follows. Ferrous iron concentrations in source area wells are indistinguishable from background well concentrations. This indicates little iron is present for biodegradation through iron reduction. It is not likely that iron reducing conditions have been present in the past. Also, it appears that sufficient dissolved iron concentrations are not present to support future natural biodegradation. Source area and downgradient nitrate concentrations are depleted relative to upgradient nitrate concentrations. This indicates that nitrate has been utilized as a TEA during the biodegradation process. The depleted downgradient concentrations indicate that low nitrate concentration water may be migrating out of the source area possibly diluting naturally occurring nitrate concentrations. Hydrocarbon concentrations have been measured in downgradient wells which may have also consumed nitrate in the biodegradation process. It is possible that nitrate containing groundwater may migrate from upgradient areas into the source area. The historical data show that naturally occurring nitrate is nearly fully consumed in the source area. Biodegradation, under nitrate reducing conditions, will be limited in the future because of the relatively low upgradient nitrate concentrations and that nitrate appears to be fully utilized in the source area under natural conditions. Sulfate concentrations across'the site are relatively equal. The highest sulfate concentration in February 2010 was measured in downgradient well MW13. The sulfate concentration measured in MW13 indicates sufficient sulfate to promote biodegradation under sulfate reducing conditions. However, site wide sulfate concentrations are relatively low and would likely not support biodegradation under sulfate reducing conditions. Concentrations of alkalinity and methane measured in samples from MW1D indicate higher concentrations versus background wells. Methane is produced during certain anaerobic biodegradation processes. Elevated alkalinity concentrations in MW1D may indicate that rd _IC Permit Application Attachmern,_�_-' Former Terrell Shell 7995 NC Highway 150 Terrell, Catawba County, North Carolina NCDENR Incident 15677 anaerobic biodegradation has been occurring, or it could be a result of natural geochemistry. Concentrations of methane concentrations in samples collected from MW1R and MW9R are relatively low but were detected above background levels. Summary of Natural Attenuation and Biodegradation Processes It appears that hydrocarbon concentrations have been reduced on a limited basis by processes of natural attenuation and biodegradation. Site specific data indicate that biodegradation has most likely occurred under aerobic or anaerobic (nitrate reducing) conditions. Source area DO concentrations are depleted relative to background wells. There does not appear to be adequate nitrate, iron, or sulfate to support continued anaerobic biodegradation. It appears that enhancing the aerobic conditions at the site will be beneficial to meet groundwater remedial goals in a time and cost effective manner. Aquifer conditions have been amenable to support natural biodegradation. Historical biodegradation has occurred mostly under aerobic or nitrate reducing conditions. There does not appear to be sufficient nitrate or sulfate to support continued anaerobic degradation. Enhancing the aerobic conditions at the site appears to be a cost effective means to help reach groundwater remedial goals. During aerobic degradation, oxygen is used as an electron acceptor to ultimately convert hydrocarbons to carbon dioxide and water. Active remediation across the entire lateral extent of the plume is cost prohibitive. The groundwater remedial strategy is to remediate the source area and allow processes of natural attenuation and degradation to address the downgradient portions of the plume. Remediating the source area will also allow uncontaminated or less contaminated groundwater to migrate downgradient thus increasing contaminant dispersion and dilution. The basic source area remedial strategy is to provide additional oxygen to enhance the aerobic degradation processes. A traditional means to supply oxygen to the subsurface is the use of an AS system (such as the one installed on -site). The current AS well configuration is not adequate to address the on -site lateral and vertical extent of the dissolved phase hydrocarbon plume. AS can only deliver DO concentrations to the theoretical solubility limit of oxygen in the injected medium (i.e., 810 mg/Q. Available site -specific data can be used to estimate DO concentrations that could be delivered by an air sparge system. Such data show that the ambient DO is consumed relatively quickly under natural conditions in the subsurface and that DO is limiting. There are also natural oxygen sinks (e.g., total organic carbon, TOC) that further reduce the available DO for biodegradation. With the predominant soil types at the site, the TOC may be relatively elevated. At a minimum, increasing DO concentrations above ambient conditions will be highly beneficial. In general, the more DO that can be delivered to the subsurface the shorter 5 _.�JC Permit Application Attachment...-` Former Terrell Shell 7995 NC Highway 150 Terrell, Catawba County, North Carolina NCDENR Incident 15677 timeframe to reach groundwater remedial goals. A system that could provide high concentrations of DO (i.e., >20 mg/L) would be highly beneficial. It is proposed to enhance the aerobic conditions at the site using the iSOC system. The iSOC system is a proprietary gas delivery system that infuses oxygen (or any gas) into liquid. It has been shown to be able to deliver high DO concentrations (40-60+ ppm) to the subsurface. The DO concentrations delivered are dependent upon the depth the unit is installed. The deeper the unit is installed, the more oxygen that can be delivered. The technology is relatively simple to implement and maintain. E. INJECTION PROCEDURE AND EQUIPMENT The basic components of the iSOC system are the gas diffusion apparatus and an oxygen tank. The oxygen tank is typically connected to the iSOC system with a pressure regulator and 1/4 inch outer diameter polyurethane tubing. The iSOC apparatus is installed into a monitoring or recovery well and is secured with nylon coated wire. A pressure regulator is installed on the oxygen cylinder which delivers the oxygen to the diffusion system apparatus. The system delivers high concentrations of oxygen to an approximate 15-20 foot radius around the well. Due to the high concentrations and persistence of the delivered oxygen, DO migrates downgradient with groundwater flow. The iSOC system will target the on -site source area. Based on information provided by inVentures, five iSOC diffusion systems will be adequate to address the remaining source area. It is proposed to use existing monitoring wells at the site as the delivery wells. Trenches will be installed from monitoring well vaults to AS well heads to allow polyurethane tubing to be installed through the existing AS piping system. Monthly maintenance visits will be required to check the status of the iSOC system and change out oxygen cylinders as necessary. The iSOC design includes the use of the five iSOC diffusion devices connected to a common 300 ft3 oxygen cylinder. A second cylinder will be stored on site as well to provide a backup. The oxygen cylinders will be installed within the treatment compound area. The oxygen cylinders will be stored and secured with steel chains or other appropriate measures. Given the apparent historic theft at the site, extra efforts will be made to secure the treatment compound area and the oxygen cylinders. It is proposed to install the iSOC units in existing wells MW1D, MW1R, MW2D, MW2R and MW9R. This should provide adequate coverage of the source area across the vertical and lateral extent of the source area. Samples from three of the MWs (MW1D, MW2R and MW9R) contain the highest measured hydrocarbon concentrations in April 2010. Recent groundwater R Permit Application Attachment_ Former Terrell Shell 7995 NC Highway 150 Terrell, Catawba County, North Carolina NCDENR Incident 15677 gauging data show approximately 10 feet of water column in MW2R and 15 feet in MW9R. These relatively small water columns will reduce the DO concentrations the iSOC can produce. However, the large water columns present in MW1D and MW2D should allow the iSOC to provide high concentrations of DO. Presumably DO will migrate horizontally with groundwater and up vertically based on the vertical gradient and buoyancy of oxygen bubbles. This configuration of iSOC placement should provide adequate source area coverage initially. Installing the iSOC units in the monitoring wells will require installing trenches from the monitoring well vaults to AS vaults. The trenches will allow the iSOC tubing to be installed through the existing AS trenching network. It is anticipated the trenches will be approximately one -foot deep and one foot wide. A schedule 40 PVC pipe will be laid in the bottom of the trench which will act as a protective conduit for the iSOC tubing. Native material removed during trenching will be used to backfill the trenches unless contaminated soil is encountered. If contaminated soil is encountered, clean backfill will be transported to the site to use as backfill material. After the trenching is complete, the asphalt will be repaired. The asphalt currently requiring repair at the site will also be repaired at the same time. The asphalt repair currently necessary will be bid out with the remedial system construction (Section 4.2). The design is based on remediating the source areas and immediate downgradient areas. As un-impacted groundwater migrates through and from the source area, the hydrocarbon concentrations in downgradient portions of the plume should begin to decline. Another benefit of a product such as the iSOC system is that it can be moved to various delivery wells. As remediation progresses the locations of the iSOC units will be evaluated and modified to optimize the oxygen delivery. As described previously, downgradient portions of the plume will be addressed by the downgradient migration of unimpacted groundwater and DO and by other biodegradation mechanisms. Limitations to the use of the iSOC system include the production of iron oxide precipitates and DO consumption by TOC. The formation of iron oxides can lead to well fouling and reduce the effectiveness of the iSOC system. Dissolved iron measurements collected during April 2010 sampling event indicate relatively low dissolved iron concentrations reducing the potential of iron oxide precipitates. These data will continue to be collected in future sampling events to evaluate the formation of iron oxides. TOC has not been measured at the site but it is assumed to be relatively high at the site given the predominant soil types. High TOC concentrations will utilize DO, reducing the effectiveness of the iSOC system. Prior to installing the iSOC systems the existing AS wells will be developed with a surge block and submersible pump. During operation of the iSOC system, the units will be inspected quarterly to check for the formation of iron oxides on the units. If iron oxides have formed, the 7 ,-,2,C Permit Application Attachments-- Former Terrell Shell 7995 NC Highway 150 Terrell, Catawba County, North Carolina NCDENR Incident 15677 units can be cleaned with a low pressure spray wash. It is critical to maintain a good connection between the iSOC treatment wells and the aquifer. If significant iron oxides are noted on the iSOC units, the AS wells will be developed as described above to maintain a good connection between the aquifer and iSOC delivery well. F. MONITORING PLAN To track the effectiveness of the proposed groundwater remedial technology (i.e. deliver of high DO concentrations), it is proposed to initiate a limited quarterly groundwater sampling program on select monitoring wells. This will be coupled with ongoing comprehensive semi-annual groundwater sampling events. It is anticipated that the downgradient effects of the proposed remedy will not be seen for at least one year. Therefore, comprehensive semi-annual monitoring will be adequate to track trends in hydrocarbon concentrations. Samples will be collected quarterly from wells MW1R, MW1D, MWSR, MW6, MW9R, MW13, and MW15. All samples will be analyzed for VOCs by EPA Method 620013, sulfate and nitrate by EPA Method 300, alkalinity by EPA Method 310.1, methane by RSK SOP-75, dissolved iron by an appropriate method, biological oxygen demand (BODO and chemical oxygen demand (COD). Prior to purging, groundwater quality parameters including DO, pH, conductivity, ORP, and temperature will be measured with a downhole water quality meter. All site monitoring wells will continue to be sampled semi-annually for VOCs by EPA Method 6200B. The water quality parameters listed above will be measured in a smaller subset of the monitoring well network. The subset would minimally be the seven targeted wells listed above, Vicinity WSWs will continue being sampled on a quarterly basis for VOCs by EPA Method 6200B and ethylene dibromide by EPA Method 504.1. After the first year of monitoring, the sampling plan will be evaluated and optimized to minimize monitoring costs while maintaining the ability to track the effectiveness of increasing the DO concentrations. The first year monitoring plan including the number of samples per well and per analysis is provided as Table S. ___ C Permit Application Attachment,—, Former Terrell Shell 7995 NC Highway 150 Terrell, Catawba County, North Carolina NCDENR Incident 15677 G. WELL DATA Please refer to Tables 1 and 2 for this information. All tables included are" 1. Summary of Monitoring Well Construction Details 2. Summary of Recent Groundwater Elevation Data 3. Historical Summary of Field Collected Water Quality Data 4. Summary of Field Collected and Analytical Data for Natural Attenuation Parameters 5. Proposed Monitoring Plan 6. Summary of Groundwater Analytical Data H. MAPS 1. Site Location 2. Site Map 3. Hydrogeologic Cross Section Location 4. Geologic Cross Section A -A' 5. Geologic Cross Section B-B' 6. Equipotential Map — 4/26/2010 7. Estimated Horizontal Extent of Benzene at Concentrations Greater than the 15A NCAC 2L standard, 4/27/10 8. Estimated Horizontal Extent of Toluene at Concentrations Greater than the 15A NCAC 2L standard, 4/27/10 9. Estimated Horizontal Extent of Ethylbenzene at Concentrations Greater than the 15A NCAC 2L standard, 4/27/10 10. Estimated Horizontal Extent of Total Xylenes at Concentrations Greater than the 15A NCAC 2L standard, 4/27/10 11. Estimated Horizontal Extent of MTBE at Concentrations Greater than the 15A NCAC 2L standard, 4/27/10 12. Estimated Horizontal Extent of Naphthalene at Concentrations Greater than the 15A NCAC 2L standard, 4/27/10 13. Estimated Horizontal Extent of IPE at Concentrations Greater than the 15A NCAC 2L standard, 4/27/10 14. Remedial System Well Locations 15. Locations of Water Supply Wells 9 ,,_� ,::C Permit Application Attachmen�.L Former Terrell Shell 7995 NC Highway 150 Terrell, Catawba County, North Carolina NCDENR Incident 15677 Tables 10 Table 1 rmary of Well Construction Deti Former Terrell Shell NC 150 and Sherrill's Ford Road, Terrell, Catawba County NCDENR Incident 15677 Monitoring Well Date Construction Elevation of Top of Casing (feet) Well Depth (feet BLS) Screened Interval (feet BLS) MW1 2/1/1996 99.90 40.3 30.3-40.3 MW1 R 5/5/2001 99.61 50.7 30.7-50.7 MW2 3/1/1996 98.51 37.85 27.85-37.85 MW2R 5/5/2001 98.17 48.4 30 to 50 MW3 3/1/1996 100.13 41.5 31.5-41.5 MW3R 5/5/2001 100.17 50.7 30 to 50 MW4 3/1/1996 101.73 44.6 34.6-44.6 MW4R 12/15/2002 101.83 55 40-55 MW5 7/1 /1996 101.11 43 33-43 MW5R 12/18/2002 100.61 55 40-55 MW6 11/1/1996 96.49 44.85 34.85-44.85 MW7 10/29/1996 98.98 44.95 34.95-44.95 MW8 on or prior to 11/01/99 99.97 <45 <35 - <45 _ MW8R 12/18/2002 99.36 56 41-56 MW9 on or prior to 11/01/99 101.22 45.28 unknown MW9R 12/15/2002 101.52 55 40-55 MW10 on or prior to 11/01/99 98.14 45 ? - 45 MW11 5/8/2003 97.82 55 40-55 MW12 4/13/2009 102.55 51 40-55 MW13 9/23/2009 101.92 80 75-80 MW14 9/23/2009 102.71 60 45-60 MW15 9/23/2009 102.39 48 38-48 MW16 2/9/2010 96.55 50 35-50 MW1D on or prior to 12/01/96 100.08 70 65-70 MW2D on or prior to 12/01/96 100.18 105 100-105 MW12D 9/23/2009 102.33 110 105-110 MW-REC1 on or prior to 8/01/96 99.82 45.2 35.2-45.2 MW-REC1-R 12/15/2002 100.37 52 40-52 VEW-1 12/4/1996 99.56 37 27 - 37 Notes: Data prior to 7/1/02 obtained from Terraine, Inc. reports Top of Casing Elevations measured to arbitrary site datum BLS = below land surface T:\100s\162\17 (Terrell's)\UIC Permit Application\16217 UIC Permit Tables 0810 Page 1 of 1 Table 2 Summary of Recent Groundwater Elevation Data Former Terrell Shell NC 150 and Sherrill's Ford Road, Terrell, Catawba County NCDENR Incident 15677 Well Top of Casing Depth to Water Elevation I of Water Depth to Water Elevation of Water Depth to Water Elevation I of Water April 13, 2009 October 14, 2009 April 26, 2010 M W 1 D 100.08 43.24 56.84 42.00 58.08 38.93 61.15 MW1R 99.61 42.80 56.81 41.33 58.28 38.03 61.58 MW2D 100.18 43.60 56.58 42.43 57.75 40.78 59.40 MW2R 98.17 41.31 56.86 39.83 58.34 36.85 61.32 MW3R 100.17 43.36 56.81 42.02 58.15 39.16 61.01 MW4R 101.83 45.05 56.78 43.64 58.19 40.59 61.24 MWSR 100.61 43.49 57.12 41.57 59.04 39.31 61.30 MW6 96.39 39.45 56.94 37.97 58.42 35.43 60.96 MW7 98.98 NG NG NG NG NG NG MWBR 99.36 42.91 56.45 41.66 57.70 39.22 60.14 MW9R 101.52 44.77 56.75 43.32 58.20 40.17 61.35 MW10 98.14 41.26 56.88 39.86 58.28 37.11 61.03 MW 11 97.82 40.96 56.86 39.71 58.11 37.29 60.53 MW12 102.55 45.81 56.74 54.90 47.65 Dry Dry MW12D 102.33 NI NI 45.09 57.24 41.79 60.54 MW13 101.92 NI NI 43.84 58.08 40.73 61.19 MW14 102.71 NI NI 45.15 57.56 42.04 60.67 MW15 102.39 NI NI 44.66 57.73 41.26 61.13 MW16 99.56 NI NI NI NI 36.00 63.56 MWRECI 99.82 NG NG NG NG NG NG Notes: All measurements taken from top of casing. Elevations of tops of casings as reported by Terraine, Inc. and GMA. Elevation of top of casing of MW6 re-established at 96.39 ft after repairs 4/22/08. NI - Not Installed NG - Not Gauged MW1, MW2, MW3, MW4, MW5, MW8 and MW9 were replaced with MW1R, MW2R, MW3R, MW4R, MWSR, MWBR, and MW9R in 2001 T:\100s\162\17 (Terrell's)\UIC Permit Application\16217 UIC Permit Tables 0810 Page 1 of 1 f. r O� N \� w N N F+ A N �'A�ANAOV�NOCo F�.,��-� w i N N N N l\ N N N N N N N N N i+ N N N N N N O W N E; N N W N O W N �D N 01 N N O N N N N N O N OD ~O N t\'i N N N O w N N \ N N O N N N N N N N N N O N N N N W O N N N W j N N O r N N N O W iD O N N O p y Cl 00 N Nc C. 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L 1 ..-1 ~ N .+ O ,may O �D •.-� ry r N N O W N W N N N O\ O LO .--i N\ O W N " N Ol .--I N N .-i M •--� C-D ,�.y �O N W .= ry N O O M W N W O` N N .ti 8\ '""i N 8 N\i V' O\ � N 4 O\ 7 ,may N W ry O N N ID n 0\ y O\ O O N t0 '� .ti ,..� .� V' O\ N C O\ ' 4 �-9 .ti N �O L� .� 'ti 7 .--i .�-� V' .-i ,�y ry .-+ .ti ,y ,.y ti M 3 v Ln iO 3 00 3 Table 3 Histori ummary of Field Collected Groundwater Quality (meters Former Terrell Shell NC 150 and Sherrill's Ford Road, Terrell, Catawba County NCDENR Incident 15677 well, Date DO m 1 CO2 m L ORP millivolts pH Temperature *C' Conductivity umhos MW9R 4/30/2003 0.5 75 164 5.66 17.7 33.7 12/8/2003 0.4 95 148 5.52 17.4 52.1 4/15/2004 9.6 55 47 5.73 17.7 39.0 10/10/2004 5.1 95 20 5.95 17.7 60.0 4/18/2007 5.8 NR 363.1 6.04 16.9 0.0 11/20/2007 4.04 45 -1.6 5.26 19.0 45 4/22/2008 2.21 10 -66.4 5.1 19.5 87 10/2/2008 0.68 5 -125.9 4.8 18.6 72 4/13/2009 1.02 5 13.9 5.1 18.3 81 10/14/2009 3.1 5 69.8 5.2 14.5 84 2/10/2010 1.9 5 150 5.4 16.3 159 4/26/2010 0.71 10 124.9 5.8 18.5 203 MW10 8/9/2000 4.7 NM NM 5.01 21.3 4.6 10/30/2000 3.0 NM NM 4.65 19.0 5.9 2/2/2001 1.7 NM NM 4.65 18.7 4.2 6/21/2001 4.3 NM NM 4.9 19.0 4.4 7/9/2002 0.6 140 207 4.88 18.8 14.5 10/23/2002 1.3 120 236 4.55 17.8 43.02 4/30/2003 0.9 125 191 5.29 18.4 17 12/8/2003 0.6 120 179 5.08 17.4 22.4 4/15/2004 9.8 90 153 5.44 10.2 56.6 10/10/2004 3.8 55 150 5.12 18.2 13.8 4/18/2007 1.1 15 149.2 4.96 19.1 50 11/20/2007 2.78 30 -46.0 5.22 19.2 40 4/22/2008 1.35 5 -53.1 4.89 19.6 56 10/2/2008 2.7 5 -137.8 4.93 19.2 53 4/13/2009 6.89 5 16.9 5.5 19.0 172 10/14/2009 6.5 5 179.2 6 16.4 215 2/10/2010 NM NM NM NM NM NM 4/26/2010 0.16 5 209.8 5.7 19.1 135 Mwll 12/8/2003 0.9 65 194 4.94 17.2 38.6 4/15/2004 9.9 60 151 5.50 17.1 30.4 10/10/2004 6.4 105 112 5.18 18.1 24.7 4/19/2007 3.3 35 109.5 4.69 18.6 44* 11/20/2007 5.83 10 -52.3 5.05 17.5 66 4/22/2008 4.48 10 -182.1 4.79 19.6 241 10/1/2008 7.8 5 176.7 4.6 18.6 41 4/13/2009 6.62 5 148.9 6.5 18.4 148.9 10/14/2009 5.8 5 23.1 5.0 17.2 -72 2/10/2010 NM NM NM NM NM NM 4/26/2010 6.1 5 270.2 4.6 18.6 74 MW12 4/13/2009 8.09 5 72.9 6.5 17.6 181 2/10/2010 NM NM NM NM NM NM 10/14/2009 6.5 10 -36.8 6.1 17.3 MW12D 10/14/2009 3.1 5 160.4 8.5 16.4 4/26/2010 4.3 10 68.2 6.0 17.2 253 MW13 10/14/2009 1.56 5 126.3 6.5 15.6 204 2/10/2010 1.26 15 56.2 6.5 16.6 166 4/26/2010 0.30 10 55.2 6.7 18.0 181 MW14 10/14/2009 6.8 5 1.2 5.2 16.5 60 4/26/2010 7.6 10 42.6 5.3 16.9 55 MW15 10/14/2009 6.7 5 69.7 5.4 14.3 76 2/10/2010 8.7 5 116.1 5.3 9.92 55 4/26/2010 6.4 5 116.5 5.1 16.6 203 MW16 2/10/2010 8.96 5 220.8 6 11.8 1 121 MW = Monitoring Well DO = Dissolved Oxygen CO2 = Carbon Dioxide mg/L = milligrams per liter pH measured in standard units FP=Free Product * readings would not stabilize NM - Not Measured T:\100s\162\17 (Terrell's)\UIC Permit Application\16217 UIC Permit Tables 0810 Page 3 of 3 Table 4 Summary of Field Collected and Analytical Data for Natural Attenuation Parameters Former Terrell Shell NC 150 and Sherrill's Ford Road, Terrell, Catawba County NCDENR Incident 15677 r .. .: U� g�adi.,. p ent ;Wells. '- 2/10/2010 9.02 5 43.5 4.5 12.0 45 0.501 5.5 4.9 <0.187 0.911 MWSR 4/26/2010 ND 4.8 15 180.6 7.4 16.7 73 - - - - - 2/10/2010 - 8.92 5 187.7 4.3 14.2 64 0.20 2.3 5.3 <0.187 <5.0 MW6 4/26/2010 ND - 5 289.8 4.4 19.2 87 .;. Source AreaWeNs .. . .,. 2/10/Z010 2/10/2010 - 2.56 , 5 50.7 11.7 18.9 740 0.15 ] .0293 6.8 0.547 J 210 MW1D 460 18,. 0.42 5 -123.7 12.2 18.9 2331 - - - - - 2/10/2010 - 1.86 5 -49.5 5.1 15.4 150 1.7 .040 J 5.1 <0.187 6.6 MW1R 4/26/2010 5,370 0.30 10 -75.6 7.5 18.9 65 2/10/2010 - 1.9 5 150 5.4 16.3 159 1.5 0.19 5.9 3.97 ] 56 MW9R 4/26/2010 21,190 1 0.71 10 124.9 5.8 18.5 203 - - - - . Downgrad�ent,,Wells , .... , ,. ., . 2/10/2010 -.., e.-1.26 15 56.2 6., .5 16.6 166 1.8 .046 J 41 <0187 . 140 MW13 4/26/2010 1,464 0.30 10 55.2 6.7 18.0 181 2/10/2010 - 8.7 5 116.1 5.3 9.92 55 3.5 .0991 5.4 <0.187 13 MW15 4/26/2010 ND 6.4 5 116.5 5.1 16.6 203 :J ND - No BTEX compounds detected above compound specific method detection limits. DO - Dissolved Oxygen CO2 - Carbon Dioxide ORP - Oxidation Reduction Potential; mV - millivolts pH measured in standard units µg/L - microgram per liter mg/L - milligrams per liter "-" indicates parameter was not measured on listed date T:\100s\162\17 (Terrell's)\UIC Permit Application\16217 UIC Permit Tables 0810 Page 1 of 1 Table 5 Proposed Annual Monitoring Plan - Year 1 Former Terrell Shell NC 150 and Sherrill's Ford Road, Terrell, Catawba County NCDENR Incident 15677 VOCs EPA 6200B Ethylene Dibromide 504.1 Groundwater Quality Parameters Sulfate EPA 300 Nitrate EPA 300 Alkalinity EPA 310.1 Methane RSKSOP-75 Ferrous Iron Biological Oxygen Demand Chemical Oxygen Demand uarterl Monitored Wells MW111 4 - 4 4 4 4 4 4 4 4 MW1D 4 - 4 4 4 4 4 4 4 4 MWSR 4 - 4 4 4 4 4 4 4 4 MW6 4 4 4 4 4 4 4 4 4 MW9R 4 - 4 4 4 4 4 4 4 4 MW13 4 - 4 4 4 4 4 4 4 4 MW15 4 - 4 4 4 4 4 4 4 4 WSW1 4 4 - - - - - - - - WSW 1A 4 4 - - - - - - - - WSW2 4 4 - - - - - - - - WSW3 4 4 - - - - - - - - WSW6 4 4 - - - - - - - - Semi -Annual Monitored Wells MW211 2 - 2 - - - - - - - MW213 2 - 2 - - - - - MW311 2 - 2 - - - - - - - MW411 2 - 2 - - - - - - MW811 2 - 2 - - - - - - - MW10 2 - 2 - - - - - - - MW11 2 - 2 - - - - - MW12 2 - 2 - - - - MW12D 2 - 2 - - - - - - MW14 2 - 2 - - - - - - MW16 2 - 2 - - - - - - - Totals 70 20 50 28 28 28 28 28 28 28 T:\100s\162\17 (Terrell's)\UIC Permit Application\16217 UIC Permit Tables 0810 Page 1 of 1 N r 3 3 3 3 3 �Q � r 0 �•30 � � f N p N A N C A v ry o. N N� WNW N��N�� NN��-• �\ N� Y�r�\ N�� N�N� �\ NAY O �\ N��N�� WO N •-r v O Nr• T� W Y � N O V ID In `W N��' IpN NNY��A��O� W AN�F+W OrN V gyp\ ��D NOD �F+N D7 Atn OI �' W �+�+�' V ID InOONOI t+NCO VI\O�Y W Y r N V ID VI V �pN W p N N O N N N N � N N � N N O � N N O p O p ID N � O N N p OOO N N N N p0 N N � 00000000 N N N O N • N O OOOO N N p N N OOOOOOOOOOOOOO N N N N N N N -o o o "o �O N N � 000000000000000 N N N N N N N N N N OOO 00000000 OO�O ODW OO V V AA � W 00 WN N � �D�O��D IO 000000 Oa7 V VAAW � 0000 WN N � i-+O O O � � �O�O �' 0000 CIO aDW p V 000000 V AAW W N N t+00 O �� TO�tD �' 0000 OCD 0000000 V V AA W WN N � O � n O W n O n O n n n pl n n n Z Z Z V j.. Y Y A Q1 N VI �.+ W {/� N O N A G O G N V I V A O V Y tp V 1 V 1 A Y A V Vt W U 1! A 01 A Y Y O W o o VI yf A b N Z Z N A N N W N N W A Y N Y V Y W W O W A O 1 N IO N N A Y 0 0 N N N 0 0 T F+ W O O In O to "' O �' �'• V �'• y �' �" O O G O O O O O V Y O N VI O O p O O p p W 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 O O 0 0 O O m A,,—. NpY n nnn r- r F' n Y n n Y ZZZ OOOOOooY OD V V — -n n n �' of W.o,,N OD OO N W NN YO N ^ O{Wj 01 coa, In 01 ID 00000000000000O1 V1 A OI c+wO A OD A OI W VI N Y N W IO OI W NN OI A NO N N00000000000000 Y W Y W A w w A Y N co A W O+Cl`N�000AOOG VI �D O A twit OWf - O O O o C O) o A O cc p OI W O O O O O O O O O O O o O o o 0 0 0 0 0 0 0 0 A I''!++ n n n n n n n n n 2 Z m Z Y n n VI W Y N o w A b b O Z oo OI OD O N W Y V W A V O VIA A VI N Y 01 I� V VI OI W Y V O Z 2 O z W N OD A Y W W O N N Y VIA W N A Y N VI 01 O NNN O� N N OD N O O T T O= O R N S O W OI' F- �OOOOY Y F' 0000 W W G w 00 0 000000"A p GY 000 OOOOOOOo 00 O O V O O O ?! A NW n n n n n n n n n Z Z Z OI YCVWO1V W OI Y Ip Ip N N t, p N O Op A V I ao W T Cn V OOOIO0000 A V A VI W I+ AID Y F' N Z zZ Yn O O0 0 0 OOy yb �OOOOOOIp O 000 O O T-- o 0 0 0 O O o 0 0 0 OOo0 A W A N V V Y N Y N O A W W W N O O O N N V �O V f' Y IO tD Y Y W w Y A A A A p Y W Y W A VI A N A OD 0 F+ Y N O W W A W A A W N O O G N 3 p In y Vt y In - to - VI to ut p O G O p O A V w 0 L. 0 0 0 0 0 0 N l00 b O O O O O 0 O O O O o o O 0 0 O o 0 0 0 0 OYj N OD 0 0 o 0 0 0 0 0 0 0 0 0 0 o o 0 0 0 0 0 0 0 Q/ m p o p o o O p o o 0 o o o o o o z^ D �^ ^ n n n n n n n n �•O➢OD000.- z z z z^^ ^nnn .-oou0_oo A z^ n z z o 0 o z z 00D0000000000000�DDa0000000�0000 z n n n n n n n n n z z z z z z z n n n n n n n n z n n z z o 0 0 o oo" O000 f 000 00 c A n n A N A n V t n n V I V l n n l n l n n n t n V I Z Z O O V Z W G Y N N V W A I' O W Y W W ut N N 01 V I+ N 01 OD Y A O F+ Y yyI AA OD t0 N VI V V O A VI l0 V V V V W V N Y V O o N N OD DD 0 0 Y 01 C7 A 0 0 A F+ o? N Y W O N W p V o A W A VI 0 cc A t'' Y D A pl W o O Y V N 0 W N O W W N Y W D O v 0 m 0 o O i n O o y y Y O O O O O O O A A O o o 0 0 0 0 0 0 yl V y y y 0 0 0 0 0 �!9 Z Y F. " n n n n Z Z DDDDDDlO Z Z Z Z Z" N F^.. 1-• �^.. �A�A� n Z InDDDDDD➢D Z 2 2 2 2 Z Z Z D Z Z D DOF' O O NA�o00A➢D o o o p o O Z Z z 2 DD 2 Z DD 2plcn{n DDDDO Y O O O Y Y O O O O Y y N O p O Y Y NDD O p O z z ZZZ DDD➢DDDD Z r7i O y (D A ' N � 0 N F F F F N A A W � W b p'L � a i m �+A �• r• A NN�OH A �D A t�'„ p •�oNAD �•� NVNoW V 00�� " A N�NO� 0 A A "d ONONA� NVNiW A �'r N�NoWO V A A A �� rNiW �N•0N�+ OWON0D NOON0� ��OA��0�ANNO1 O�-0N0�' W�ON0ND YWN0�O dY00N0 :�NAO AVN0 NoVN Y�NA •NNNo �ONNp WVN•• ON�NoO NNN•o 00 rA�A WNOo r W d3� NONO� WNi�O WONoW VNiV �lNoAA N�oWND NNN ONOO] N•No�+ NONO� VoN�D1 �oNNO.J. �WoNV VN� �ONoOJ �N �VNoV ff-ili-8 �NNO0 tANNop YNNI�-n. ypml O�V oo �N�D NOOND �A��rNI�On� AN NO�o0'0 N1O- ��A�O �I�On� �NONO� NA� �WNo�O N10 Nit•�p„ ��RO �O�ADo �AN o�NOD o V0oW• Z Z Z A Z 000 A A A o A n A A n A A A A 0 A n 0 0 A A 0 A A A n A A O N n n n n n A A �� ANN W FaNAO NOOA A A A N Ar = m pppp O c t O O O O p O O p p 0 0 0 0 0~ 0 0 0 0 0~ pb�,OOp� V CCLIO 1C01T0OO 1_�"NOD Z z A - _A A A n -A A A A A A A A A Z O Z Z p O Z Z O p n Z F, OO n n �. n - A A A A A A A ~ Z Z p 00000 n n A. f.. n n " A n r�'If A A Of+r•ONOrOD A A W N V r. Z, 41 r 0�N�OOOO N O� O W n n E.. t, n n r �. iAA A A F+ A 01N r N W r � m ~00� - W N 0 0 0 W(A , n O 0 O O C CD OO p p 0000� �'• 0 0 0 W m �• rA• �• n A A A A A A A Z r-pOppOO0000•- Z Z Z Z 2 r• iA-• r iA• A A A A n A A `•OO0000•- Z Z r• �• rA• n n n �A-• •-o•-••-Ai+O�f'�"'yOV0000� n n �DOr WA rNZq. A- n Amain• n ��000 n OC IZZZZZ l0 O f' ➢a+� N =Y p OOp0000.- �A�A� m ZZZ A Z NNNN A A AA A A A n A n A n Z Z Z Z Z ZN N N N A A n A W Z OOOOOONN A NNNN A A n A A n W W0OD r 00 Vr r �'' NW r0 r ZNNNNN• A A A A r A W r NrOW A V 0 0 ppt 0000 0 W DD O O p 0~ O0,C W N W C X �pOp000000NN A WWWWWWOp 000O0000 fA�Z f OOOOWN N Z Z Z Z A in A A in in A A in A A A A A A A Z Z Z Z Z Z A in A A �n vi A A �n in A A �n to A A �n vi A A in in Z p"C% O r 0 N �O 0� W F' �D W O O A A A N41NONYIO• A~ 00 �O VI V N VIZ OpO N Z r W o0 A OD 00 V1 OfO0o0OAOOOO O� O V W 0 o 000 W 01 f''p Q W m OOOO0000"'"'v�u'i"i"v'u'OOpOOp0000 Z Z Z Z2 n A A A A A n n A n n ZZZZZZZ A �. A `• n A A A A A �• Z 22�"A. p 0➢000`� �A. A A A A h A .-O ZJZ�- pOpOpOD000_�A Z Z Z Z Z�A.. fA..r A A fA+fA+A A �A AZZO A o O O p OZZZZG O pA O W p OO p D000.- "pOO p OOD o00 ZZZ Z A v, A -- A A A A n A A A A ZZZ ZZ Z A in A A �n �n A in A A A A A A A -p Z Z poopt+rtn n A W r r r T t+r F+ r Wyk pO N W W W-4ZZ r A Nam, A 0 r 00 'p,r rO�WN OlnWOOO rW O 01V V OOpN apZ i..➢O V m p O O p o 0 0 0 �' v' v' v' �n �n �n �n p O p 0 0 p o 0 0 0 LM�OpO�ooO1n Z Z Z Z Z A �A'• �A-• ,A.. A A n A z ZZZZ Z ZZZ i sA-• r "A+ n A n "-tn A Z DDDDDo000 Z Z Z Z� r r "A-• A n A A ""•->DDDDDD Z z Z Z Z Z Z Z DD➢D Z z A A A.. r A n W~ Z Z D z Z DD Z Z D D 2 2 DD ZZZ D D Q1 D0 � D D D D 0 0 0 in D D D D D D D D D 0 0 0 7 i m Table 6 Summary of Groundwater Analytical Data Former Terrell Shell NC 150 and Sherrill's Ford Road, Terrell, Catawba County NCDENR Incident 15677 Sample Sample Date Benzene Toluene Ethyl - benzene X lenes MTBE EDB IPE Naphthalene 2L Standards L 1 600' 600' 500' 204 0.0004 70 65 MW8R 12/17/2002 <1 <1 <1 <3 <5 <1 <5 NA 5 13/2003 <1 <1 <1 <3 <5 <1 <5 NA 12/7/2003 <1 <1 <1 <3 170 <1 43 NA 4/15/2004 <1 <1 <1 1.51 94 <1 27 NA 10 9 2004 <1 <1 <1 <3 160 <1 30 <5 4 182007 <1 <1 <1 <3 260 <1 31 <1 11192007 <1 <1 <1 <2 28 <1 15 <1 4/21 2008l2O <1 <1 <2 2.73 <1 4.91 <1 9 30 2001 <1.0 <1.0 <2.0 2.41 <1.0 7.1 <1.0 4/13 2009 <1.0 <1.0 <2.0 5.6 <1.0 4.91 <1.0 1014/2009 <1.0 <1.0 <2.0 27 <1.0 4.91 <1.0 4/26/2010 <1.0 <1.0 <2.0 59 NA 5.9 <5.0 MW9 8 8/2000 38 000 2,700 11 000 5 800 NO 4 600 NA 10 29 20000 29 500 1,800 6,950 6,450 NO ND NA 2 1 2001 11,000 22,000 1,500 7,600 3,900 NO 1,200 NA 6 20 2001 3,200 5,500 320 2,640 950 ND 250 NA MW9R 12 17/2002 8,800 13,000 810 4,600 8,700 <1 1,000 NA 4 29/2003 14,000 30,000 1700 8,400 16,000 <100 1,700 NA 12/7/2003 1,300 2,500 260 730 1,800 <100 <500 NA 4/15/2004 870 1,400 73 510 1,700 <10 230 NA 10 9/2004 2,900 2,700 220 1,240 3,800 <10 600 4,500 4/17/2007 3,100 3,800 160 1,400 5,200 <10 630 2,900 11 19/2007 3,100 4,200 170 1,320 5,500 <40 600 2,900 4/21 2008 2,600 3,700 200 1,800 4,400 <100 460J 3,100 10 1 2008 4,900 5,700 733 2,800 12,000 <100 860 3,000 4 13 2009 4,900 6,000 270 3,100 13,000 <100 820 3,100 10 14 2009 2,800 3,300 190 2,200 9,000 <100 510 3,000 4/26/2010 5 700 10,000 690 4,800 9,500 NA 840 2,400 MW10 8 8/2000 6 500 10,000 620 3,200 4,300 ND 1,700 NA 10/29/2000 7 400 10,600 ND 850 3,500 NO NO NA 2 1/2001 6,000 7,400 490 2,700 1,800 NO 710 NA 6/20/2D01 5,400 5,900 370 2,000 1,300 NO 600 NA 7/8/2002 2,800 3,000 230 1,000 650 NO 380 NA 10/22/2002 2000 1,800 150 730 450 <10 320 NA 4 29/2003 240 97 15 120 150 <10 140 NA 12/7/2003 <1 <1 <1 <3 24 <5 10 NA 4/15/2004 <10 <10 <10 <30 <50 <10 <50 NA 10/9 2004 60 33 7 28.9 180 <1.0 44 4.43 4/17/2007 4.7 <1 <1 3.7 140 <1 22 <1 11/19/2007 4.1 1.7 <1 3.28J 32 <1 3.83 <1 4/212008 6.9 1.2 1.2 6.2 7.7 <1 2.41 <1 1012008 9.4 <1.0 1.1 12.7 11 <1.0 2.63 <1.0 413/2009 0.74 1.0 <1.0 <2.0 <5.0 <1.0 <1.0 <1.0 1014/2009 <0.50 <1.0 <1.0 <2.0 <5.0 <1.0 <5.0 <1.0 4/26/2010 140 3.2 30 79 230 NA 56 2.01 MWll 5/13/2003 <1 <1 <1 <3 <5 <1 <5 NA 12/7/2003 <1 <1 <1 <3 35 <5 <5 NA 4/15/2004 2.0 3.5 <1 1.0 28 <1 <5 NA 10 9 2004 <1 <1 <1 <3 20 <1.0 <5 <5 418/2007 <1 <1 <1 <3 23 <1 <5 <1 11 19 2007 <1 <1 <1 <2 7.2 <1 <5 <1 4 21 2008 <0.50 <1 <1 <2 <5 <1 <5 <1 9 30 2008 <0.50 <1.0 <1.0 <2.0 <5.0 <1.0 <5.0 <1.0 4 13 2009 <0.50 <1.0 <1.0 <2.0 <5.0 <1.0 <5.0 <1.0 1014/2009 <0.50 <1.0 <1.0 <2.0 <5.0 <1.0 <5.0 <1.0 4/26/2010 <0.50 <1.0 <1.0 <2.0 <5.0 NA <5.0 <5.0 MW12 4 13 2009 240 1.4 <1.0 82 140 <1.0 70 4.4 10 15 2009 <0.50 <1.0 <1.0 <2.0 <5.0 <1.0 <5.0 <1.0 MW12D 1015/2009 <0.50 <1.0 <1.0 <2.0 <5.0 <1.0 <5.0 <1.0 4/26/2010 <0.50 <1.0 <1.0 <2.0 <5.0 NA <5.0 <1.0 MW13 10/15/2009 540 1200 85 2,260 220 <10 54 110 4/26/2010 140 53 51 1220 140 NA 413 323 MW14 *** 10/14 2009 <0.50 <1.0 <1.0 <2.0 <5.0 <1.0 <5.0 <1.0 4/26/2010 <0.50 <1.0 <1.0 <2.0 <5.0 <1.0 NA <5.0 MW15 1014/2009 <0.50 <1.0 <1.0 <2.0 <5.0 <1.0 <5.0 <1.0 4/26/2010 <0.50 <1.0 <1.0 <2.0 <5.0 NA <5.0 <5.0 MW16 2 8/2010 <0.50 <1.0 0.711 4.8 <5.0 <1.0 <5.0 <1.0 4/26/2010 <0.50 1 <1.0 <1.0 <2.0 <5.0 NA <5.0 <5.0 Concentrations in micrograms per liter (µg/L) or parts per billion (ppb) Shaded concentrations indicate exceedance of 15A NCAC 2L groundwater standards - Concentration is Estimated EDB=Ethylene dibromide MTBE = Methyl tert butyl ether IPE= Isopropyl ether 1. On January 1, 2010 the NC 2L groundwater standard for Toluene changed from 1,000 ppb to 600 ppb 2. On January 1, 2010 the NC 2L groundwater standard for Ethylbenzene changed from 550 ppb to 600 ppb 3. On January 1, 2010 the NC 2L groundwater standard for Total Xylenes changed from 530 ppb to 500 ppb 4. On January 1, 2010 the NC 2L groundwater standard for MTBE changed from 200 ppb to 20 ppb 5. On January 1, 2010 the NC 2L groundwater standard for Napthalene changed from 21 ppb to 6 ppb MW 10, 4/16/04- detected tetrachlorethane at 700 ug/I and trichlorothene at 49 ug/L. ** MW 14 10/15/09 detected Bromodichloromethane at 2.9 ug/L and Chloroform at 28 ug/L *** MW 14 4/27/10 detected Bromodichloromethane at 1.5 ug/L and Chloroform at 33 ug/L T:\100s\162\17 (Terrell's)\UIC Permit Application\16217 UIC Permit Tables 0810 Page 3 of 3 SITE LOCATION r' 850 1000 0 1000 2000 Feet N LAKE NORMAN NORTH QUADRANGLE w E NORTH CAROLINA - CATAWBA COUNTY 7.5 MINUTE SERIES (TOPOGRAPHIC) S • SITE CONTOUR INTERVAL=10 FEET MAP DATED 1993 ACME FIGURE 1 TERRELL, CATAWBA COUNTY, NC GMA '� GROUNDWATER MANAGEMENT ASSOCIATES, INC. DATE 10/21/2008 .. 2205 CANDUN DRIVE, SUITE A M ,. APEX, NORTH CAROLINA 27523 PROJECT 16217 NW14 \ WORLD PETROLEUM BAIT SHOP MW6 �MW11 MWBR US J"HWAY 150 6MW: W3R� V • SB-3 MAIL' NW12 B W9R M R SB-2• MW15 W12D 100 b MW13 MhW16 V I MW6 • MWIO SB-4 MW2 *V W2R M �MW1R SB-9 ASPHALT PARKING LOT MW10� SB-8 • SB-7•W O1 TERRELL MW • CAMPING 6 CENTER M 4 GRAVEL LOT REMEDIATION SYSTEM MWS* MWSR* RECREATIONAL VEHICLE PARKING LEGEND • SOIL SAMPLE LOCATION i$� MONITORING WELL - — — - APPROXIMATE AREA OF UST • POTABLE WATER WELL EXCAVATION Cp M A ® BUILDING o 20 40 North Ismagnift SCALE: 1 in = 40 ft oa,ne.ot< Ma, ant Ina File: Soil Sampling.dwg SITE MAP Date: 06/08/10 Pro'ect No. 162-17 FORMER TERRELL SHELL, TERRELL, CATAWBA CO., NC Figure 2 WORLD PETROLEUM BAIT SHOP MW8 #�MW11 M W8R US HIGHWAY 150 W10 MW6 SVE-4 W3 MW2 AS-4 MW3R W2R MAIL 4W2p 1R ASPHALT PARKING LOT MW12 BOX MW1D' AS-5 S -5 -1 MW9R A REC- W1 - M W9 MW-RE -1R +!'y t^ S 3 TERRELL POST OFFICE " M 2D �� J' AS-1 M W7 T WWOi P� ?o TERRELL MW4 CAMPING 9p CENTER GRAVEL MW4 LOT MW13 REMEDIATION TEM RECREAl10NAL MW5R VEHICLE PARKING MW5 ' LEGEND MONITORING WELL REMEDIATION TRENCHES 0 15 30 • POTABLE WATER WELL ® BUILDING PROPERTY LINE North SCALE: 1 in = 30 ft EDGE OF PAVEMENT - CENTERLINE OF ROAD GMA ,, ❑ AS-1 = AIR SPARGING WELL ® SVE-3 = SOIL VAPER EXTRACTION WELL =06MM Groundwater Nanogement As lcte% Inc File: hydrogeoloic.dwg HYDROGEOLOGIC CROSS SECTION LOCATIONS Date: 06/17/10 Project No. 162-17 FORMER TERRELL SHELL, TERRELL, CATAWBA CO., NC Figure 3 WEST EAST A o A ............................. . ...... V......... 120, . ..M111111 ,<,'' 1.... :x...2................ m DRY LAND SURFACE 61.35 61.15 59.40 61.58 61.32 60.96 1001 - = ..... -. ............................ ................................ ...... 4: ---------.. .... . ....... 80' - ........ ............ ..... .. .... 70' - ....... ....... ......... ..... ..... ........ ......... ............... 60' i<O B30 5 501 . ....... Ns ... ... .... ... .................... �07QO' ?I 40' .. .... ............ ...... .... N. L . ............. ...... ..... ..... 30. . ... .. ... .. ...... .... . .... . .... . ... . .... . .... . .... 20. . ..... ..... ...... ...... . .... . .... . .... . .... . .... . .. .. ...... ..... ..... ..... ..... ..... ...... . .... . .... . .... . 10, . ..... ..... ..... ..... ..... ...... ...... ...... .. ....... ..... ..... ..... ..... ..... ..... ..... ..... ..... ...... ...... 0 . ...... ...... ...... ...... ...... ...... ...... ...... .. ...... ..... ...... ...... .............. ...... ...... ...... ....... ...... ...... <0.5 -10 . . ..... ..... ..... ..... ...... ...... ...... ...... ...... ...... ..... ..... ..... ..... ..... ..... .. ..... ..... ...... ...... -20' SCALE IN FEET NOTE: ELEVATIONS BASED ON ARBITRARY SITE DATUM OF 100.00 FEET 0 15' 30' AS2 PROJECTED ONTO CROSS SECTION PLANE 1*=30' LEGEND— APPROXIMATE VERTICAL EXTENT OF BENZENE 830 BENZENE CONCENTRATION (ppb) SAND SILT MONITORING WELL T WATER TABLE (4/26/2010) GMA 59.40 = WATER LEVEL ELEVATION CLAY BEDROCK SCREENED INTERVAL ? LITHOLOGIC CONTACT INFERRED LITHOLOGIC CONTACTS ARE APPROXIMATE BASED ON BORING GROUNDWATIR MANA09MINT "SOCIATIS, INC. LOGS FOR MW1, MW11D, MW2D,AND MW12 DRAWINGS/16217 File: A -A' HYDROGEOLOGIC CROSS SECTION A —A' Date: 6/17/2010 Project No. 16217 FORMER TERRELL SHELL, TERRELL, CATAWBA COUNTY, NC Figure 4 NORTH SOUTH B B, o Ln 120'- a ......61.15............................. 81.24...........LAND . ..............59,4061.58 61.03 SU FA ...........100'- 81.30... . ........................ ....:.:.:.... — ... ..— .. :...•.:..::... ..... ...... 70' 60' - 1140 , ..:....T� .. ... .. .. .............. 50' - 1 83- <0.5 + <0 5 30' 20' - ... ..... ..... ....... �... ..... ..... ..... ..... ..... ..... ..... ..... ..... ..... ..... ... 10' - ...... ...... .. .... 0 .... ...... ...... ...... ...... ...... ...... ...... ...... ...... ..... ...... ...... ...... ...... 0.5 ...... ...... ...... .. ... ...... ...... ...... ..... ..... ..... ..... ..... ...... ...... ...... ...... .. -10' - -20' - SCALE IN FEET 0 15' 30' NOTE: ELEVATIONS BASED ON ARBITRARY SITE DATUM OF 100.00 FEET AS5 PROJECTED ONTO CROSS SECTION PLANE 1'=30' — LEGEND — APPROXIMATE VERTICAL EXTENT OF BENZENE 830 BENZENE CONCENTRATION (ppb) SAND + SILT MONITORING WELL 1 WATER TABLE (4/26/2010) GMA 61.15 = WATER LEVEL ELEVA11ON CLAY r BEDROCK ] ? LITHOLOGIC CONTACT INFERRED SCREENED INTERVAL ON BORING /a LITHOLOGIC CONTACTS ARE APPROXIMATE BASED OAOUNDWATIN MANAGEMENT ASSOCIATES, INC. LOGS FOR MW1, MW1D, MW2D,AND MW12 DRAWINGS/16217 File: B-B' HYDROGEOLOGIC CROSS SECTION B—B' Date: 6/17/2010 Project No. 16217 FORMER TERRELL SHELL, TERRELL, CATAWBA COUNTY, NC Figure 5 WORLD PETROLEUM BAIT SHOP 6 .50 WBR / 60.53 A — us WAY 150 MW110 MwG� 60.E 61.03 M��' W3 W2R mw2 $V \l " (5..40 2 ASPHALT PARI KING LOT MAIL' 61.58 _ 1.50 X M BG0 WDR \ NG MW12 IM \p M D R Y REC-i r N G ,. MW12D MW15 (60.54. LL OS 0 wwot 3 MW TERRELL CAMPING 70 CENTER GRAVEL MW4 � LOT MW13 REMEDIATION SYSTEM MW5h MW5Rh RECREATIONAL VEHICLE PARKIN MW16 LEGEND Arrows indicate direction of groundwater 0 20 40 MONITORING WELL flow. Isotropic conditions are assumed. POTABLE WATER WELL SCALE: 1 in = 40 ft ® BUILDING Contour interval = 0.50 foot North Elevation in () not used to construct map. NG = NOT GAUGED GMA _6 9W06Q0--- Groundwater Mwogemwt Associates, Inc. File: 1662-17—EQUIP. EQUIPOTENTIAL MAP, 04/26/10 Date: 05/20/10 Project No. 162-17 FORMER TERRELL SHELL, TERRELL, CATAWBA CO., NC Figure 6 ESTIMATED HORIZONTAL EXTENT OF BENZENE AT CONCENTRATIONS GREATS THAN 15A NCAC 2L GROUNDWATER STANDARD, 4/27/10 1 ti ,l WORLD PETROLEUM BAIT SHOP MWa �Mw11 MW6R us HIGHWAY 150 MW14 MW10 MW6<050 � <0.50 M MW2R MW2 \ W3R 6700 (<a 6d ) ASPHALT P INO LOT MW1R NS % BOX 570C) Myy104 8.5c MW12 13 WOR 6100 *MWI NCz REC-1 ?c' LL OS 0 M W15 W12D �- 1$1MW7 WW01 <O.Mw,, TERRELL CAMPING CENTER GRAVEL LOT MW13 NS REMEDIAiION SYSTEM 140 MW5 M7 " RECREATIONAL VEHICLE PARKING M W16 0 20 40 North mmi SCALE: 1 in = 40 ft Concentrations of Benzene in groundwater are posted LEGEND beside each well in parts per billion. MONITORING WELL Benzene standard (per NCAC 2L) is 1 ppb. POTABLE WATER WELL (<0.50) Not used for contouring. GYMA 00 ® BUILDING .�01"iiiiRMG�w NS = NOT SAMPLED BENZENE ISOCONTOUR Qroundroter Man mt Associates, Inc. File: NewBenzene.dwg BENZENE 04/27/10 Date: 05/20/10 Project No. 162-17 FORMER TERRELL SHELL, TERRELL, CATAWBA CO., NC Figure 7 ESTIMATED HORIZONTAL EXTENT OF TOLUENE AT CONCENTRATIONS GREATER THAN 15A NCAC 2L GROUNDWATER STANDARD, 04/27/10 WORLD PETROLEUM BAIT SHOP MWB111�t"MW11 M W8R us H04WAY 150 MW14 MW10 MW6 -------` `:.0 MW3 {�Mw2 <1.0 �,MW2R \ ` 41.0} ASPHALT PARKINS LOT W2D MW1R BOX 000 MW1D�i %0�} MW12 p WOR 6900 M *MW1 S RE0-1 j� art LL OS 0 MW15 MW12D W.1 � TERRELL �+ MW CAMPING $ CENTER GRAVEL MW13 MW4 LOT REMEDIATION SYSTEM MW5R$, MW5#,� RECREATIONAL VEHICLE PARKI MW16 0 20 40 North SCALE: 1 in = 40 ft Concentrations of Toluene in groundwater are posted LEGEND beside each well in parts per billion. MONITORING WELL Toluene standard (per NCAC 2L) is 600 ppb. POTABLE WATER WELL (<1.0) Not used for contouring. GMA ® BUILDING 60O � TOLUENE ISOCONTOUR NS = NOT SAMPLED Groundwater Manogement As Iatee, Inc. File: Toluene TOLUENE 04/27/10 Date: 05/20/10 Project No. 162-17 FORMER TERRELL SHELL, TERRELL, CATAWBA CO., NC Figure 8 ESTIMATED HORIZONTAL EXTENT OF ETHYLBENZENE AT CONCENTRATIONS GREATER THAN 15A NCAC 2L GROUNDWATER STANDARD, 04/27/10 t WORLD PETROLEUM BA!T SHOP MW8 4$�Mw11 MWBR <i.4 US WG {WAY 150 MW14 _ W10 MWB n MW3 W3R� M W2 ,$V' 2) MW2D ASPHA! T PARKING LOT �Mw1R BO L' 90 MWID* �. MW12 J WOR 660 * W1 M REC-1 4 R LL OS E MW15 MW12D F 'MW7 Q, W:1 0 TERRELL 10 Mw CAMPING b CENTER h q GRAVEL MW4 LOT MW13 REMEDIATION SYSTEM 1it MWSR* RECREATIONAL VEHICLE PARKI N� <1.0 MW16 North LEGEND Concentrations of Ethylbenzene in groundwater are MONITORING WELL posted beside each well in parts per billion. Ethylbenzene standard (per NCAC 2L) is 600 ppb. • POTABLE WATER WELL (240) Not used for contouring. CvMA ® BUILDING -al 111mmom NS = NOT SAMPLED -- ETHYLBENZENE ISOCONTOUR (;rmndwater Man ent Aaoelateti Ina File: NewEthybenzene.dwg ETHYLBENZENE 04/27/10 Date: 05/20/10 Project No. 162-17 FORMER TERRELL SHELL, TERRELL, CATAWBA CO., NC Figure 9 ESTIMATED HORIZONTAL EXTENT OF TOTAL XYLENES AT CONCENTRATIONS GREATER THAN 15A NCAC 2L GROUNDWATER STANDARD, 04/27/10 1 WORLD PETROLEUM BAIT SHOP MWB J�Mw11 M WBR US HIGHWAY 150 MW14 MW6 <. e, �` r " MW2 MW2R $500 241 ASPHALT PARKING T � �W2b MW1R NS""'� MW12 BOX 4800p �v a WOR 4800 NS IREC-1* MW1 MW12D R LL OS 0 MW15 MW7 q, Wwo 0 <2° TERRELL CAMPING b CENTER M \\ GRAVEL IN c LOT MW13 REMEDIATION SYSTEM 1220 MWS MWSR RECREATIONAL VEHICLE PARKI MW16 5� 0 20 40 SCALE: 1 in = 40 ft North LEGEND Concentrations of Total Xylenes in groundwater are posted beside each well in parts per billion. Total $ MONITORING WELL Xylenes standard (per NCAC 2L) is 500 ppb. POTABLE WATER WELL (24) Not used for contouring. GMA BUILDING XYLENES ISOCONTOUR NS = NOT SAMPLED �50a�OTAL Gmundwatw Mmogemmt A»odate* Ina File: NewXylenes.dwg TOTAL XYLENES 04/27/10 Date: 05/20/10 Project No. 162-17 FORMER TERRELL SHELL, TERRELL, CATAWBA CO., NC Figure 10 ESTIMATED HORIZONTAL EXTENT OF MTBE AT CONCENTRATIONS GREATER THAN 15A NCAC 2L GROUNDWATER STANDARD, 04/27/10 WORLD PETROLEUM BAIT SHOP *MW11 S MW8R CN <5.0 50 20 Fq+fON►Y 160 MW14 - "- W10 MW6 W3R MW2 4MW2R (<5.0) ASPHALT PARKING LOT W2D MW1R MAIL' ' 500 MpryD* BM MW12 W9R 6800 'MW1 'I S �� r� R LL OS 0 0 W12D !�$ MW15 �MW7 TERRELL 1,;W4R h CEN CAMPING ko 4 GRAVEL MW13 LOT REMEDIATION SYSTEM MW5 MW5R� RECREATIONAL VEHICLE PARKI a M W16 0 20 40 North SCALE: 1 in = 40 ft LEGEND Concentrations of MTBE in groundwater are posted MONITORING WELL beside each well in parts per billion. MTBE standard (per NCAC 2L) is 20 ppb. 40 POTABLE WATER WELL (<0.5) Not used for contouring. GMA ® BUILDING _ MTBE MTBE ISOCONTOUR masimmm = METHYLTERTBUTYLETHER�ZO— NS = NOT SAMPLED DASHED WHERE INFERED cro nda ater Monogem.t A..oaetea Inc File: NewMTBE.dwg MTBE 04/27/10 Date: 05/20/10 Project No. 162-17 FORMER TERRELL SHELL, TERRELL, CATAWBA CO., NC Figure 11 ESTIMATED HORIZONTAL EXTENT OF NAPHTHALENE AT CONCENTRATIONS GREATER THAN 15A NCAC 2L GROUNDWATER STANDARD, 04/27/10 1 1 ,+ WORLD PETROLEUM BAIT SHOP M W8 4#M W11 MwBR �t US HIGHWAY 150 tt :+ MW14 MW6 MW3 2 W3R WW2 4$0 i ASPHALT PA:,KING LOT W1 R hM NS 2400 MWID� ' x MW12 O W811% 6, . M *MWt NS REc-I*!,,_ �- MW12D R LL OS E MW15 '$MW7 _ WW01 .p 5 TERRELL -p MW CAMPING b CENTER MW4 GRAVEL LOT MW13 REMEDIATIONN SYSTEM IMWrG`J O MW5 RECREATIONAL VEHICLE PARKI M W16 1$ 0 20 40 SCALE: 1 in = 40 ft North LEGEND Concentrations of Naphthalene in groundwater are posted beside each well in parts per billion. MONITORING WELL Naphthalene standard (per NCAC 2L) is 6 ppb. • POTABLE WATER WELL (1.4) NOT USED FOR CONTOURING GvMA ® BUILDING 6 - — NAPHTHALENE ISOCONTOUR r. NS = NOT SAMPLED G- ndwater Man ent Amoodatek Inc File: NewNaph.dwg NAPHTHALENE 04/27/10 Date: 05/20/10 Project No. 162-17 FORMER TERRELL SHELL, TERRELL, CATAWBA CO., NC Figure 12 ESTIMATED HORIZONTAL EXTENT OF ISOPROPYL ETHER AT CONCENTRATIONS GREATER THAN 15A NCAC 2L GROUNDWATER STANDARD, 04/27/10 } WORLD PETROLEUM BAIT SHOP M #�Mw11 NS MWeR us HIGHWAY 150 MW14 MW10 MM�6 <5.0 .7 J eW3 / MW2 WW2R W3R ASPHALT PARKING LOT AM VW1R f MA!, € .t! MW1D� MW12 d 0 W91R . M 4$MW1 R LL OS E MW15 W12D 1%W7 ®1 TERRELL ?a MW CAMPING b h CENTER GRAVEL MW13 MW4 LOT REMEDIATION SYSTEM Mw50 MW5RRECREATIONAL VEHICLE PARKI MW16 <5.0 0 20 40 SCALE: 1 in = 40 ft North LEGEND Concentrations of IPE in groundwater are posted beside MONITORING WELL each well in parts per billion. Isopropyl Ether standard (per NCAC 2L) is 70 ppb. POTABLE WATER WELL (<0.5) Not used for contouring. J = Estimated Value ® BUILDING GvMA UISOPROPYL ETHER ISOCONTOUR ��► NS = NOT SAMPLED Gaundwatw Man ent A w Iotet, Ina File: NewIPE.dwg ISOPROPYL ETHER 04/27/10 Date: 05/20/10 Project No. 162-17 FORMER TERRELL SHELL, TERRELL, CATAWBA CO., NC Figure 13 I a U.S. HIGHWAY 150 MW10 AREAS OF PATCHING SVE-4 WWI. 1 AS-4 MW3R$ AS-3 � VEW-2 — L — AS-2 -F0 — — — MW21) MAIL $ I $MW1R BOX MW1D L$ MW9R I �AS-5 SVE-5 MW9 $ EW-1 REC-1 �M$W1 I MW—REC-1R AREAS _ _ �I OF r SVE-3 L!L'j PATCHING MW2 $ $MW2R ASPHALT PARKING LOT a AS-1 ❑— TERRELL POST OFFICE o o i MW7 L� /////// 10 to J w M W4$Rj WW01 • _ TERRELL / CAMPING CENTER MW4$ GRAVEL REMEDIATION SYSTEM LOT MW5$ MWSR$ RECREATIONAL VEHICLE PARKING LEGEND MONITORING WELL — — — — REMEDIATION TRENCHES • POTABLE WATER WELL ® BUILDING ❑ AS-1 = AIR SPARGING WELL ® SVE-3 = SOIL VAPER EXTRACTION WELL File: Remedial system.DWG REMEDIAL SYSTEM LAYOUT Project No. 162-17 ACME, TERRELL, CATAWBA CO., NC 0 10 20 North SCALE: 1 in = 20 f GMA 6 alasialm Groundwater Management Associates. Inc. Date: 6/09/10 Fiqure 14 / WW24 / � I SAWE GABRI m \ I / - - \ n 1 i W5 NC \g0 � WW4 WWI 1500 FT DIUS A WW7 \ 5* \ \YYW18 WW5 \ \ WW3 �yEp WW1 B /\\ \ 4 WW1 / PoWWB\2 \\ \ \ \ WW6 If If If WW20 0 y� N 0 LEGEND SCALE IN FEET PROPERTY LINE 0 250' 500' ACTIVE POTABLE DOT RIGHT—OF—WAY 1'=500' ACTIVE NON POTABLE 0 RESIDENCE INACTIVE CHURCH GMA,, -�- ACTIVE —SERVES TWO PROPERTIES � ? USE/STATUS UNKNOWN OWW20 REFER TO TABLE 1 FOR maMMM WSW INFORMATION Groundwater Management Associates. Inc. File: DRAWINGS/16217 1500RAD LOCATIONS OF WATER SUPPLY WELLS Date: 5/14/09 Project No. 16217 FORMER TERRELL SITE, TERRELL, CATAWBA CO., NC Figure 15 EX 1. �1 NCDENR North Carolina Department of Environment and Natural Resources Beverly Eaves Perdue Governor Division of Water Quality Coleen H. Sullins Dee Freeman Director Secretary December 29, 2010 Steven DeGeorge c/o Robinson, Bradshaw, and Hinson 101 North Tryon Street, Suite 1900 Charlotte, NC 28246 Ref: Issuance of Injection Permit WI0300154 Former Terrell Shell Terrell, Catawba, North Carolina Dear Mr. DeGeorge: In accordance with the application received on September 1, 2010, we are forwarding permit number WI0300154. This permit is to operate an in situ Submerged Oxygen Curtain to remediate groundwater contaminated with hydrocarbon related compounds at the facility referenced above. This permit shall be effective from the date of issuance until November 30, 2015, and shall be subject to the conditions and limitations stated therein, including the requirement to submit a final project evaluation as stated in PART VII — MONITORING AND REPORTING REQUIREMENTS. Please read the entire permit to ensure that you are aware of all compliance requirements of the permit. You will need to notify this office by telephone 48 hours prior to initiation of operation of the facility. In order to continue uninterrupted legal use of the injection facility for the stated purpose, you must submit an application to renew the permit 120 days prior to its expiration date. Please contact me at (919) 715-6168 or john.mccray@ncdenr.gov if you have any questions about your permit. cc: Andrew Pitner, Mooresville Regional Office Matthew Tendam, PE, Groundwater Management Associates, Inc. Brad Newton, Mooresville Regional Office, DWM, UST Section C WI03"00 f 54 Per ntt File AQUIFER PROTECTION SECTION 1636 Mail Service Center, Raleigh, North Carolina 27699-1636 Location: 2728 Capital Boulevard, Raleigh. North Carolina 27604 Phone: 919-733-3221 1 FAX 1: 919-715-0588: FAX 2: 919-715-60481 Customer Service: 1-877-623-6748 Internet: wwwmwaterauality.org An Equal Opportunity % Affirmative Action Employer Best Regards, John Mc �r�ay Environmental Specialist One Na r - 2205 A Candun Drive Apex, North Carolina 27523 Telephone: (919) 363-63 7 0 Fax: (919) 363-6203 Groundwater Management Associates, Inc. November 3, 2010 Mr. Andrew Pitner, PG NCDENR — DWQ — Mooresville Regional Office 610 East Center Drive Suite 301 Mooresville, North Carolina 28115 Re: Response to Notice of Violation Former Terrell Shell, Terrell, Catawba County 7955 North Carolina Highway 150, Terrell, Catawba County Groundwater Incident #15677 Risk -Rank: High H395D Dear Mr. Pitner: On behalf of Acme of South Carolina (Acme), Groundwater Management Associates, Inc. (GMA) is submitting this response to the Notice of,Violation (NOV) issued to Acme on October 6, 2010. During a routine Division of Water Quality (DWQ) site inspection, the conditions of several monitoring wells (MWs) were noted as not being compliant with the well construction standards outlined in 15A NCAC 2C (NC 2C Rules). Four violations were noted during the site inspection. Since the date of the NOV, the issues outlined in the letter have been addressed. A summary of the actions taken to date, in response to each Violation, is included below. An inspection of the MW conditions was performed on October 12, 2010, to assess the needed repairs. The MW repairs were completed by a NC Certified Well Contractor (NC CWC) between October 21 and 22, 2010. Photographs of monitoring well conditions post -repair are included as Attachment I. Violation 1: Failure to grout well casing, for a non water supply well, as required, in rule 15A NCAC 2C. 0108(i). Corrective Action 1: During the site inspection, it was noted that five monitoring wells were in need of additional grout: MW1R, MW4R, MW9R, MW10 and MW1D. Additional grout and bentonite were added to the annulus around the MWs to within approximately 6 to 8 inches of the existing grade. Violation 2: Failure to maintain a well in a condition whereby the well will not serve as a source or channel of contamination or pollution to the water supply of the aquifer as required by rule 15A NCAC 2C. 0112(a). Corrective Action 2: During the site inspection on October 12, 2010, it was noted that nearly every well needed some combination of a new locking plug, a gasket around the manhole, one or more new bolts, and well tags. During the repair visit, all MWs were equipped with new Mr. Andrew Pitner 11/3/2010 Page 2 of 3 locking expandable plugs. The manhole covers were retrofitted with new rubber gaskets to minimize surface water infiltration. Additionally, the bolt holes were rethreaded as they had been stripped over the years and new bolts were installed on the covers. Finally, new well tags, were created for each monitoring well and are maintained in the manhole cover. In 2001 and 2002, several replacement MWs (MW1R, MW2R, MW3R, MW4R, MW5R, MW8R, MW9R, and MW-REC1R) were installed due to a consistently declining water table. At that time, the old MWs were not abandoned in case, in the future, the water table rebounded to pre-2002 levels. However, since that time the water table has not rebounded to pre-2002 levels. During the assessment of the MW conditions, GMA attempted to gauge the depth to water and total depth of several of the older MWs. Two of the manhole covers of the older MWs (MW7 and MW9) are stuck under asphalt or grass and could not be opened. Monitoring well MW5 could be not located. During gauging of MW1, MW2 and MW3, an obstruction was encountered in all three MWs below the recorded total depth. It is not know what the obstruction is but appears to render these MWs no longer usable. No well construction or abandonment records are available for these MWs. It is recommended to abandon MW1, MW2, and MW3 as outlined below. A New Technology Cleanup Plan (NTCP) was submitted for the site on June 17, 2010,.which recommended installation of the In -situ Oxygen Curtain (iSOC) system into several of the onsite air sparge (AS) wells. The installation of the iSOC and required tubing will require wellhead modifications and cutting the asphalt near several AS wells. It is proposed that during the iSOC construction, MW1, MW2 and MW3 should be properly abandoned by a NC CWC. The condition of the currently inaccessible MWs (MW7 and MW9) will also be assessed during the construction efforts. Since asphalt cutting equipment will already be on -site, it will reduce time and cost to repair these MWs. Also, reimbursement from the State Trust Fund (STF) will be sought for the costs to abandon the old MWs. A Pre Approval request for STF funds to perform these tasks will be made concurrent,with the Pre Approval request for iSOC installation costs. It is anticipated that the iSOC installation will occur in the next few months. Once the MWs are properly abandoned, the well abandonment records will be submitted to DWQ. If it is decided to keep any of the older MWs, they will be repaired to be compliant with the well construction standards outlined in the NC 2C Rules. Documentation of any MW repairs will be submitted to DWQ once complete. Violation 3.• Construction of a well without a permit from the Department, as required, by rule 15A NCAC ZC. 0105. Corrective Action 3. A permit to construct a monitoring well was obtained prior to the installation of MW12 on the west -adjacent property. Monitoring well MW12 was installed under Permit Number MW0300509 issued April 8, 2009. At that time, it was anticipated that additional monitoring wells would be necessary to delineate the hydrocarbon plume to the west. However, the additional MWs were inadvertently left off the original permit application. A Request for an Addendum to Permit Number MW0300509 was submitted to the DWQ on October 13, 2010. As of the date of this letter, an approval of this addendum has not been received. Mr. Andrew Pitner 11/3/2010 Page 3of3 Violation 4. Failure to ensure that the top of the well casing is terminated at a height at least 12 (twelve) inches above land surface, as specified in rule 15A NCAC 2C. 0107(d)(5). The water supply well (WW01) is located in a non permitted, below grade vault that is approximately 5 feet from the building foundation Corrective Action 4.• The current property owner, Mr. Carol Lineberger installed, and is the owner of water supply well, WW01. This well consistently shows dissolved concentrations of several hydrocarbon constituents above the groundwater standards outlined in 15A NCAC 2L.0202 (NC 2L standards). In 2003, Acme paid for the installation of a replacement well, WW01B located approximately 190 feet southeast in the RV Sales Center parking lot. According to Mr. Lineberger (10/22/10 conversation with GMA field technician), the site is now provided water by WW01B. Acme does not have responsibility for, the construction, operation or future abandonment of WW01. Any future inquiries as to the status of WW01 should be directed to Mr. Lineberger. These issues were discussed between Mr. Matthew Tendam, PE of GMA and yourself in a telephone conversation on October 22, 2010. Should you have any questions or require additional information regarding this letter, please do not hesitate to contact me at 919.363.6310 Sincerely, GMA 1 Matthew J. Tendam, P.E. Project Engineer Enclosures: Attachment I cc: Mr. Steven DeGeorge, Robinson Bradshaw and Hinson, PA Mr. Brad Newton NCDENR -MRO Mr. Carol Lineberger, Property Owner Mr. Mike Cash, Catawba County Environmental Health Attachment I: Monitoring Well Repair Photographs Former Terrell Shell 7955 North Carolina Highway 150 Terrell, Catawba County, North Carolina GMA Project Number: 16217 Photograph 1 October 21-22, 2010: Repairs to MW1D i Photograph 2 October 21-22, 2010: Repairs to MW2R Attachment I: Monitoring Well Repair Photographs Former Terrell Shell 7955 North Carolina Highway 150 Terrell, Catawba County, North Carolina GMA Project Number: 16217 t a ov6 ` r Al kz P� � Pw i Photograph 3 October 21-22, 2010: Repairs to MW2D l . l4 0. - ,- h � � {:a-a,Q y �'�' ,.4.^',+.}.r fir,,,,.' •.e,.� ``�� - Photograph 4 October 21-22, 2010: Repairs to MW2R Attachment I: Monitoring Well Repair Photographs Former Terrell Shell 7955 North Carolina Highway 150 Terrell, Catawba County, North Carolina GMA Project Number: 16217 Photograph 5 October 21-22, 2010: Repairs to MW4 Photograph 6 October 21-22, 2010; Repairs to MW4R Attachment I: Monitoring Well Repair Photographs Former Terrell Shell 7955 North Carolina Highway 150 Terrell, Catawba County, North Carolina GMA Project Number: 16217 Ma i^kf Vi f � Photograph 7 October 21-22, 2010; Repairs to MW6 Photograph 8 October 21-22, 2010; Repairs to MW6 Attachment I: Monitoring Well Repair Photographs Former Terrell Shell 7955 North Carolina Highway 150 Terrell, Catawba County, North Carolina GMA Project Number: 16217 Photograph 9 October 21-22, 2010; Repairs to MW9R Photograph 10 October 21-22, 2010; Repairs to MW10 Attachment I: Monitoring Well Repair Photographs Former Terrell Shell 7955 North Carolina Highway 150 Terrell, Catawba County, North Carolina GMA Project Number: 16217 Photograph 11 October 21-22, 2010; Repairs to MW11 1` R �. >�03F Ali,• - NCDENR North Carolina Department of Environment and Natural Resources Beverly Eaves Perdue Governor ACME of South Carolina 4973 Willow Pond Road Gastonia, NC 28056 Attention: Mark Roberts Dear Mr. Roberts: Coleen H. Sullins Director, Division of Water Quality RE: Monitoring Well Construction Permit Permit #WM0300599 Former Terrell Shell UST site #15677 Sherrills Ford Road, Terrell, Catawba County Dee Freeman Secretary November 15, 2010 In accordance with your completed application received on October 21, 2010, we are forwarding herewith Monitoring Well Construction Permit Numbered WM0300599 and issued for the construction of five monitoring wells in the NCDOT Right -of -Way and the property along Sherrills Ford Road adjacent to the subject UST site in Terrell, Catawba County. This Permit will be effective from the date of issuance and shall be subject to the conditions and limitations as specified therein. In addition, your "Response to Notice of Violation" letter was received on November 4n , 2010. Per your letter, wells MW1, MW2 and MW3 are slated for abandonment during the proposed iSOC installation. This is acceptable, as long as all well caps and covers are properly maintained. The Mooresville Regional Office (MRO) recommends further attempts to locate MW5 and abandon it also. The MRO is satisfied with the steps taken to correct the 2C violations noted in NOV-201 O-PC-1 052. Should you have any questions, please contact Maria Schulte at (704) 663-1699 ext .2184, or by email at Maria. Schuttena.ncdenr. gov. Sincerely, u Andrew H. Pitner, P.G. Regional Aquifer Protection Section Supervisor Enclosure CC: Aquifer Protection Section, Raleigh Matthew Tendam, Groundwater Management Associates, Inc, 101-E Woodwinds Industrial Court, Cary, 27511 Division of Water Quality i Aquifer Protection Section / Mooresville Regional Office One 610 East Center Avenue, Suite 301, Mooresville, North Carolina 28116 NorthCarolliina Phone: 704-663-16991 FAX: 704-663-60401 Customer Service 1-877-623-67481 Internet: www.ncwaterauality.org %�,jq&rallbr An Equal Opportunity 1 Afimralive kfion Employer - 50% Recycled 110% Post Consumer Paper NORTH CAROLINA ENVIRONMENTAL MANAGEMENT COMMISSION DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES PERMIT FOR THE CONSTRUCTION OF A WELL OR WELL SYSTEM Permit Ns WM0300599 In accordance with the provisions of Article 7, Chapter 87, North Carolina General Statutes, and other applicable Laws, Rules, and Regulations, PERMISSION IS HEREBY GRANTED TO ACME of South Carolina (Groundwater Management Associates, Inc. as Agent) FOR THE CONSTRUCTION OF FIVE MONITORING WELLS to be constructed in the Charlotte Belt Geologic Unit, in the NCDOT Right -of -Way and the property along Sherrills Ford Road adjacent to the subject UST site in Terrell, Catawba'County, and in accordance with the application dated October 18, 2010 and received in this office on October 21, 2010 and in conformity with specifications and supporting data, 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 well construction only, and does not waive any provisions or requirements of the Water Use Act of 1967, or any other applicable laws or regulations. Construction of a well under this Permit shall be in compliance with the North Carolina Well Construction Regulations and Standards, and any other laws and regulations pertaining to well construction. This Permit will be effective from the date of its issuance and shall be subject to other specified conditions, limitations, or exceptions as follows: 1. The borehole shall not penetrate to a depth greater than the depth to be monitored or the depth from which contaminants are to be recovered. 2. The well shall not hydraulically connect separate aquifers. 3. All water -bearing zones that are known to contain polluted, saline, or other nonpotable water shall be adequately cased and cemented off so that pollution of the overlying and underlying groundwater zones will not occur. 4. Construction materials shall be compatible with the contaminants to be monitored or recovered. The casing shall equal or exceed Schedule 40. 5. The well shall be constructed in such a manner that water from land surface cannot migrate into the gravel pack or well screen area. 6. When a sand. pack.is placed around the screen, a seal shall be installed above the sand. 7. Grout shall be placed in the annular space between the casing and the borehole wall from land surface to a depth within two feet above the top of the well screen or to the bottom of the casing for open-end wells. =2 Andrew H. Pitner, P.G. Regional Aquifer Protection Section Supervisor Division of Water Quality By Authority of the Environmental Management Commission Permit Ne WM0300599 I 8. All wells shall be secured to reasonably insure against unauthorized access and use. The well shall be permanently labeled with a warning that it is for monitoring or recovery purposes and the entrance to the well must be secured with a lockable cap. 9. All wells shall be afforded reasonable protection against damage during construction and use. 10. Each well shall have permanently affixed an identification plate. 11. A completed GW-1 and copies of all water quality results must be submitted for each well to the Division of Water Quality. 12. When any monitor or recovery well is no longer useful for its intended purpose, it shall be properly abandoned and an abandonment report filed with the Division of Water Quality. Permit issued this the 15th day of November 2010 . r „..,.r w -rr.Srr.TT COMMISSION x�� NCDENR North Carolina Department of Environment and Natural Resources Division of Water Quality Beverly Eaves Perdue Coleen H. Sullins Governor Director September 8, 2010 Steven DeGeorge c/o Acme of S.C. Robinson, Bradshaw and Hinson 101 North Tryon Street Suite 1900 Charlotte, NC 28246 Subject: Acknowledgement of Application No. WI0300154 Former Terrell Shell Injection In situ Groundwater Remediation Well (5I) Catawba Dear Mr. DeGeorge: Dee Freeman Secretary The Aquifer Protection Section of the Division of Water Quality (Division) acknowledges receipt of your permit application and supporting materials on September 1, 2010. This application package has been assigned the number listed above and will be reviewed by John McCray. The reviewer will perform a detailed review and contact you with a request for additional information if necessary. To ensure the maximum efficiency in processing permit applications, the Division requests your assistance in providing a timely and complete response to any additional information requests. Please be aware that the Division's Regional Office, copied below, must provide recommendations prior to final action by the Division. Please also note at this time, processing permit applications can take as long as 60 - 90 days after receipt of a complete application. If you have any questions, please contact John McCray at 919-715-6168, or via e-mail atjohn.mccray@ncdenr.gov. If the reviewer is unavailable, you may leave a message, and they will respond promptly. Also note that the Division has reorganized. To review our new organizational chart, go to htta://h2o.enr.state.nc.us/documents/dwq_orgchartpdf. PLEASE REFER TO THE ABOVE APPLICATION NUMBER WHEN MAKING INQUIRIES ON THIS PROJECT. Sincerely, QuAzfk— 14� for Debra J. Watts Supervisor cc: Mooresville Regional Office, Aquifer Protection Section Matthew Tendam, PE (Groundwater Management Associates, Inc - 2205 A Candun Drive. Apex. NC 27523 ) Permit Application File WI0300154 AQUIFER PROTECTION SECTION 1636 Mail Service Center, Raleigh, North Carolina 27699-1636 Location: 2728 Capital Boulevard, Raleigh, North Carolina 27604 One Phone: 919-733-3221 \ FAX 1: 919-715-0588; FAX 2: 919-715-60481 Customer Service: 1-877-623-6748 NoI'ii1Ca1"011lla Internet: wrq Ww.ncwateuality.orq A7&4�4 An Equal Opportunity 1 Affirmative Acton Employer Mccray, John From: Pitner, Andrew Sent: Wednesday, November 17, 2010 2:33 PM To: Mccray, John Cc: Schutte, Maria Subject: W 10300154 Terrell Shell Attachments: WM0300599 Terrell Shell.pdf; Terrell NOV Response Letter 110310.pdf Hi John, Acme/GMA have responded to our 2C NOV for Terrell Shell (attached); they've repaired/grouted most of the monitoring wells at the site and applied for a MW.permit (also attached) for off -site wells that needed it. Though there are still a couple wells that need attention, we're ok with letting the UIC permit proceed as they have indicated that asphalt cutting that will be done for the UIC permit will also allow them to also address a couple of the other problem MWs at the site. Let Maria or I know of any questions. Andrew Andrew Pitner, P.G. - Andrew. Pitner@ncdenr.gov Division of Water Quality - Aquifer Protection Section Mooresville Regional Office (MRO) North Carolina Department of Environment & Natural Resources 610 East Center Avenue, Suite 301, Mooresville, NC 28115 MRO Main Phone: (704) 663-1699 Direct Office Phone: (704) 235-2180 MRO Fax: (704) 663-6040 DWQwebsite: www.ncwaterguality.org NOTICE: Emails sent to and from this account are subject to the Public Records Law and may be disclosed to third parties. AQUIFER PROTECTION REGIONAL STAFF REPORT Date: October 1, 2010 To: Aquifer Protection Central Office Central Office Reviewer: John McCrav Regional Login No: County: Catawba Permittee: Mr. Caroll Lineberger, Sr. Project Name: Former Terrell Shell Site Application No.: WI0300154 L GENERAL INFORMATION 1. This application is (cheek all 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: 09/30/10 MRO conducted site visit w/o consultant, as they are in Apex area and this is such a small facility we thought we could save them some travel expense. b. Person contacted and contact information: Matthew Tendam 919-363-6310; c. Site visit conducted by: Maria Schutte d. Inspection Report Attached: ❑ Yes or N 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): b. Driving Directions: From Mooresville take NC 150 West to Intersection with Sherrills Ford Road in Terrell. c. USGS Quadrangle Map name and number: d. Latitude: Longitude: FORM: WI0300154 staff report Former Terrell Shell Sept-10 AQUIFER PROTECTION REGIONAL STAFF REPORT IL ' & KI, -deleted 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)? This injection is for remediation of former USTs. What is the distance of the injection well(s) from the pollution source(s)? 0 ft. 4. What is the minimum distance of proposed injection wells from the property boundary? ---8 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 N No. Attach map of existing monitoring well network if applicable. If No, explain and recommend any changes to the groundwater monitoring program: Several on -site wells are in various states of neglect, some were not constructed to 2C regs and these wells will require repair before the proposed Injection/Monitoring plan can be put in place. 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. Iniection Well Permit Renewal And Modification Onlv: 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, explain: 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: FORM: WI0300154 staff report Former Terrell Shell Sept-10 2 AQUIFER PROTECTION REGIONAL STAFF REPORT 3. For renewal or modification of groundwater remediation permits (of any type), will continued/additional/modified ini ections have an adverse impact on migration of the plume or management of the contamination incident? ❑ Yes ® No. If yes, explain: 4. Drilling contractor: Name: To Be Determined Address: Certification number: 5. Complete and attach Well Construction Data Sheet. V. EVALUATIONAND RECOMMENDATIONS 1. Provide any additional narrative regarding your review of the application.: The MRO's biggest concern here was the state of the onsite monitoring wells. Numerous covers are missing bolts. A number of wells are not secured, either no lock or cap is loose enough to pull off, some wells have no cap at all, just an open hole and MW9R, one of the proposed injection wells, appears to be improperly grouted. An onsite water supply well has improper subgrade completion. The MRO will issue an NOV to owner in regards to the 2C issues and cc the CO-UIC. Per the UIC application this site was last sampled in April 2010, so somebody should have been aware of the well conditions. This proposal is for the injection of Oxygen via an Oxygen curtain to treat BTEX compounds and MTBE contamination associated with former USTs. System does not require water for injection. They want to use existing monitoring wells for injection, with Oxygen source being connected via a trench system between wells. There is a plethora of WSWs in the area, surface water tributaries are 1200 to I500 feet away and since Oxygen is the injected material the MRO does not have a concern offurther impact. It is worth reminding consultant to locate underground utilities before trench -work begins. The MRO recommends approval of permit, but only upon the applicant demonstrating compliance with 2C via completion of monitoring well repairs. 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 FORM: WI0300154 staff report Former Terrell Shell Sept-10 0 r AQUIFER PROTECTION- REGIONAL STAFF REPORT 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: Hold permit until existing 2C concerns have been addressed. 8. Signature of report preparer(s): Maria Schutte Signature of APS regional supervisor: Date: October 1, 2010 Andrew Pitner ADDITIONAL REGIONAL STAFF REVIEW ITEMS FORM: WI0300154 staff report Former Terrell Shell Sept-10 Mccray, John From: Pitner, Andrew Sent: Friday, October 01, 2010 5:51 PM To: Mccray, John Cc: Schutte, Maria Subject: W 10300154 Terrell Shell UST Attachments: W 10300154 staff report Former Terrell Shell Sept-10-ahpsigned.pdf Hi John, Maria and I visited the subject site yesterday and they've got some issues with their monitoring wells. We're going to issue an NOV next week for a variety of concerns and we'd like to hold the UIC permit until those have been addressed. The staff report should be attached. Let us know if you have any questions. Andrew Andrew Pitner, P.G. - Andrew. Pitner(d)ncdenr.eov Division of Water Quality - Aquifer. Protection Section Mooresville Regional Office (MRO) North Carolina Department of Environment & Natural Resources 610 East Center Avenue, Suite 301, Mooresville, NC 28115 MRO Main Phone: (704) 663-1699 Direct Office Phone: (704) 235-2180 MRO Fax: (704) 663-6040 DWQ website: www.ncwaterguality.ore NOTICE: Emails sent to and from this account are subject to the Public Records Law and may be disclosed to third parties. AQUIFER PROTECTION SECTION APPLICATION REVIEW REQUEST FORM Date: September 13, 2010 To: ❑ Landon Davidson, ARO-APS ❑ Art Barnhardt, FRO-APS ® Andrew Pitner, MRO-APS ❑ Jay Zimmerman, RRO-APS ❑ David May, WaRO-APS ❑ Charlie Stehman, WiRO-APS ❑ Sherri Knight, WSRO-APS From: John McCray , Groundwater Protection Unit Telephone: (919) 715-6168 Fax. (919) 715-0588 E Mail. john.mccrayAncdenr.goe A. Permit Number: WI0300154 B. Owner: Mr. Caroll. Lineberger, Sr. C. Facility/Operation: Former Terrell Shell Site ® Proposed , ❑ Existing ❑ Facility ❑ Operation D. Application: 1. Permit Type: ❑ Animal ❑ Surface Irrigation ❑ Reuse ❑ H-R Infiltration ❑ Recycle ❑ FE Lagoon ❑ GW Remediation (ND) ® UIC - (5I) in -situ groundwater remediation For Residuals: ❑ Land App. ❑ D&M ❑ Surface Disposal ❑ 503 ❑ 503 Exempt ❑ Animal 2. Project Type: ® New ❑ Major Mod. ❑ Minor Mod. ❑ Renewal ❑ Renewal w/ Mod. E. Comments/Other Information: ❑ I would like to accompany you on a site visit. Attached, you will find all information submitted in support of the above -referenced application for your review, comment, and/or action. Within 30 calendar days, please take the following actions: ® Return a Completed Form APSSRR. ❑ Attach Well Construction Data Sheet. ❑ Attach Attachment B for Certification by the LAPCU. ❑ Issue an Attachment B Certification from the RO*. * Remember that you will be responsible for coordinating site visits, reviews, as well as additional information requests with other RO-APS representatives in order to prepare a complete Attachment B for certification. Refer to the RPP SOP for additional detail. When you receive this request form, please write your name and dates in the spaces below, make a copy of this sheet, and return it to the appropriate Central Office -Aquifer Protection Section contact person listed above. RO-APS Reviewer: Date: FORM: APSARR 02/06 Page 1 of 1 2.� North Carolina Department of Health and Human Services Division of Public Health . Epidemiology Section 1912 Mail Service Center • Raleigh, North Carolina 27699-1912 Tel 919-733-3410 9 Fax 919-733-9555 Michael F. Easley, Governor May 21, 2002 TO:- Evan Kane Groundwater Section FROM: Luanne K. Williams, Pharm.D., Toxicologist C�(,'`" Medical Evaluation and Risk Assessment Unit Occupational and Environmental Epidemiology Branch North Carolina Department of Health and Human Services Carmen Hooker Odom, Secretary . SUBJECT: Use of Oxygen to Enhance Bioremediation-of Petroleum Groundwater Contaminants at a Defense Department Facility in Hertford, North Carolina I am writing in response to a request for a health risk evaluation regarding the use of oxygen to enhance bioremediation of petroleum groundwater contaminants at a Defense Department facility in Hertford, North Carolina. Based upon my review of the information submitted, I offer the following health risk evaluation: WORKER PRECAUTIONS DURING APPLICATION Some effects reported to be associated with short-term exposure to 100% oxygen are as- follo xs: Inhalation of 100% oxygen. can result in nausea, dizziness, pulmonary irritation leading to pulmonary edema, and pneumonitis (Meditext — Medical Management by Micromedex TOMEs Plus System CD-ROM Database, Volume 52, 2002). • Intense and potentially fatal pulmonary edema may develop tracheal irritation, fever, nausea, vomiting, acute bronchitis, sinusitis, malaise, paresthesias and conjunctivitis (Meditext — Medical Management by Micromedex TOMEs Plus System CD-ROM Database, Volume 52, 2002). • Inhalation of 100% oxygen can cause eye, nose, and throat irritation (Meditext — Medical Management by Micromedex TOMEs Plus System CD-ROM Database, Volume 52, 2002). The application process should be reviewed by an industrial hygienist to ensure that the most appropriate personal protective equipment is used. ® Location: 2728 Capital Boulevard • Parker Lincoln Buildutg • Raleigh, N.C. 2760 F An Equal Opportunity Employ;• Evan Kane Memo May 21, 2002 Page Two Eating, drinking, smoking, handling contact lenses, and applying cosmetics should never 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 adverse reactions and injuries. OTHER PRECAUTIONS Access to the area of application should be limited to the workers applying the product. In order to minimize exposure to unprotected individuals, measures should be taken to prevent'access to the area of application. 2. According -to the information submitted by ATC Associates, the base operates their.own public water system. The active wells are located 1,250 to 1,800 feet northwest of the injection site. Efforts should be -made to prevent contamination of existing or future wells that may be located near the application area. 3. ' According to the information submitted by ATC Associates, there is an unnamed swamp located approximately 1,000 feet south of the injection site. Because of the proximity to this water bode. measures should be taken to prevent adverse impact to this surface water body. Please do not hesitate to call me if you have any questions at (919),715-6429. cc: Mr. Wade Jordan, Ph.D. Harvey Point Defense Testing Activity 2835 Harvey Point Road Hertford, North Carolina 27944 Mr. Joseph Olinger ATC Associates of North Carolina, P.C. 6512 Falls of Neuse Road Raleigh, North Carolina 27615 Air Products & Chemicals, Inc. 720I Hamilton Boulevard Allentown, PA 18195-1501