WI0300180_Permit_20111213

DIVISION OF WATER QUALITY
AQUIFER PROTECTION SECTION
December 13, 2011
MEMORANDUM
TO: Debra Watts /
FROM: Michael Rogers{v
RE: Issuance of Permit to Inject Adventus O-SOX (Permit #WI0300180)
Patterson Property, LLC
I recommend that Permit Number WI0300180 be issued to Patterson Property, LLC to inject Adventus O-SOX to remediate
groundwater (GW) contaminated with petroleum products. The site is located 8800 Monroe Road, Charlotte, Mecklenburg
County, NC 28212.
SITE DESCRIPTION: The subject site is a former lumberyard now used as a commercial storage facility (Figures 1 through
3). Evidently, there was a leak of petroleum products from former underground storage tanks. Soil excavation was
conducted to the point of meeting 21, standards. There are some residual low -levels of petroleum in the groundwater in the
areas of tanks. Due to the low levels of groundwater contamination and the location of the site, the UST section of the
DWM has granted a NFA to this site. However, to avoid having to file a Notice of Residual Petroleum with the register of
deeds in Mecklenburg County, the property owner/permittee has voluntarily initiated groundwater remediation to bring the
groundwater contamination levels down to 21, standards.
HYDROGEOLOGIC DESCRIPTION: The site is located in Charlotte Belt of the Piedmont Physiographic Province. The
contaminated surficial aquifer underlying the area of the site reportedly consists of fill overlying saprolitic material
(weathered silty clays and sand). Soil borings did not go into bedrock. Depth to GW in the surficial aquifer ranges from
approximately 20 to 25 feet BLS and flows in a generally southerly direction. Since there are only 2 wells on -site, and
groundwater remediation is going to be via passive oxygen release compounds (ORC) socks, no groundwater flow
rate/elevation information was included in the application.
EXTENT OF CONTAMINATION: The petroleum_ contamination is reportedly limited and contained on -site in the area of the
former USTs (refer to narrative in MRO Staff Report and Figure 2).
PROPOSED INJECTION: The proposed passive injection will be via 2 existing wells utilizing suspended ORC filter socks.
One set of socks will be inserted in the wells and left for approximately 6 months until the ORC is depleted. Then, the
socks will be replaced with fresh socks, and then replaced again (essentially 3 cycles). The potential impact or
displacement of the plume by the injection is low for the following reasons: (1) The injection is passive with no chemicals
injected under pressure, (2) the injectant consists only of an oxygen release compound, (3) a total of 3 socks will be
suspended into each of wells over approximately 18 months, and (4) the extent of the area of influence will be
approximately 10 feet downgradient (the nearest downgradient receptor is a small creek located approximately 500 feet).
The injection/monitoring wells are highlighted in yellow on Figure 2.
HOW IT WORKS: Adventus O-SOX is an oxygen release compound made of calcium oxyhydroxide. When placed in water,
this material will hydrate releasing oxygen and forming calcium hydroxide and water. Increasing DO in the groundwater
will stimulate aerobic biodegradation of the petroleum products (i.e., enhance the natural attenuation remediation).
MONITORING: After the socks are suspended in the wells, groundwater monitoring will be conducted quarterly for DO, pH,
and conductivity. When DO levels drop back to levels prior to initiating ORC treatment, the socks will be replaced. Then, after
one month groundwater samples will be collected and analyzed for petroleum products. If groundwater concentrations remain
above 2L standards, the cycle will be repeated. Once all compounds are remediated to below 2L standards, the wells will be
monitored quarterly for one year to confirm that 2L standards have been achieved. Per the request of the MRO, I am requesting
that ORP and calcium be added to the monitoring plan.

EPIDEMIOLOGY: The DHHS has review:; and approved the referenced injectant(s).' -
REGIONAL OFFICE COMMENTS: Each of the RO comments/recommendations are discussed below (RO's
comments/recommendations are underlined).
The Mooresville Regional Office recommended permit issuance upon adding the recommended modification to the monitoring
plan (i.e., add calcium and ORP to the monitoring plan, and emphasize that there shall be 4 quarters of sampling after the last
insertion of the ORC release socks). That recommendation is added to the permit.
Maria Schutte and Andrew Pitner of the Mooresville RO, recommends issuance of this permit.

51 Calculations Wo>rksheet
Applicant/Facility: ,� S�� /L/ t! r„1 egg DJ L_r 11 /-X&)Z .
J
Permit No. W1
Date:
Reviewer:' PW �Z
--yt), J f s o— a x
Depth to groundwater (OW): Q6 BLS
GW flow direction: CO Z
MWs installed in same aquifer as injection?-J) or N); Inj zone: %� —3 2—MW zone:
Nearestwater supply well: ���0d
Groundwater Flow Rate
HC X gradient(FT?) = flow rate/DAY(?) X 365 = I FT/YR
SY or porosity (—.30)
Reported:
[FYI- 60 min/day X 24 hrs X 365 days = 525,600]
Calculations for Potential Contaminate Plume Displacement // A-
3.142 (7c) X r2 X height =
space
CF X SY or porosity (i.e. —.30) =
CF
CF of available void
CF of available void space X 7.48 gallons = gallons of water in void sp
gallons of injectant = % of fluid displaced by injectant (move decimal)
gallons of water in void space
Potential displacement of plume by injection:
Injection 17olume and Pumping Rate Per Well Per l ay � f'/(�� 2 f Z� C�S
total amt. of injectant /
_number of wells / number of days of injection _gent =
X J f� MJg
amount of iniectant per well per day (average gallons per day)
S:UIC/Applications and forms/ 5I Calculations worksheei version 9/10/10

NORTH CAROLINA
ENVIRONMENTAL MANAGEMENT COMMISSION.
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
RALEIGH, NORTH CAROLINA
PERMIT FOR THE CONSTRUCTION AND OPERATION OF A WELL FOR INJECTION
In accordance with the provisions of Article 7, Chapter 87; Article 21, Chapter 143, and other
applicable Laws, Rules, and Regulations
PERMISSION IS HEREBY GRANTED TO
Patterson Property, LLC
FOR THE CONSTRUCTION AND/OR OPERATION OF 2 TYPE 5I INJECTION WELLS,
defined in Title 15A North Carolina Administrative Code 2C .0209(e)(3)(C), to inject Adventus
O-Sox for the enhanced remediation of petroleum products. These injection wells/points will be
located at the former Edwards Lumber Facility, 8800 Monroe Road, Charlotte, Mecklenburg
County, NC 28212, and will be operated in accordance with the application submitted September
1, 2011, and in conformity with the specifications and supporting data submitted September 20,
2011, all of which are filed with the Department of Environment and Natural Resources and are
considered a part of this permit.
This permit is for Construction and Operation only, and does not waive any provisions of the
Water Use Act or any other applicable Laws, Rules, or Regulations. Operation and use of an
injection well shall be in compliance with Title 15A North Carolina Administrative Code 2C
.0100 and .0200, and any other Laws, Rules, and Regulations pertaining to well construction and
use.
This permit shall be effective, unless revoked, from the date of its issuance until November 30,
2013, and shall be subject to the specified conditions and limitations set forth in Parts I through
X hereof.
Permit issued this the 190' day of December, 2011.
IAOIV69��
Coleen H. Sullins, Director
Division of Water Quality
By Authority of the Environmental Management Commission.
Permit No. WI0 300l 80 PAGE 1 OF 6
ver. June 2011 UIC-5I/5T

PART I - WELL CONSTRUCTION GENERAL CONDITIONS
1. The Permittee must comply with all conditions of this permit and with the standards and
criteria specified in Criteria and.Standards Applicable to Injection Wells (15A NCAC 2C
.0200). Any noncompliance with conditions of this permit constitutes a violation of the
North Carolina Well Construction Act and is grounds for enforcement action as provided for
in N.C.G.S. 87-94.
2. This permit shall become voidable unless the facility is constructed in accordance with the
conditions of this permit, the approved plans. and specifications, and other supporting data.
3. This permit is valid only for construction of the number of injection wells described in the
application and other. supporting data. Construction of additional injection wells must be
approved in advance by the Aquifer Protection Section.
4. Each injection well shall not hydraulically connect separate aquifers.
5. Each injection well shall be constructed in such a manner that water from land surface cannot
migrate into the gravel pack or well screen.
6. Each injection well shall be secured to reasonably insure against unauthorized access and
use. Each well shall be -permanently labeled with a warning. that it is for injection purposes
and the entrance to each well must be secured with a locking cap.
7. Each injection well shall be afforded reasonable protection against damage during
construction and use.
8. Each injection well shall have permanently affixed an identification plate.
PART II_- WELL CONSTRUCTION SPECIAL CONDITIONS
1. At least forty-eight (48) hours prior to constructing each .injection well, the Perinittee shall
notify the Aquifer Protection Section -Underground Injection Control (UIC) Central- Office
staff, telephone number 919-71'5-6166 and the Mooresville Regional, Office Aquifer
Protection Section Staff,, telephone number 704-663-1699.
2. Bentonite grout shall not be used to seal any water -bearing zone with a chloride
concentration equal to or greater than 1,500 milligrams per liter. In areas where elevated
chloride levels are known to exist or are probable, such as coastal areas, chloride levels shall
be verified in the field to determine existing conditions.
Permit No. WI0300180 PAGE 2 OF 6
ver. June 2011 UIC-5I/5T

PART III - OPERATION AND USE GENERAL CONDITIONS
This permit is effective only with respect to the nature, volume of materials, rate of injection,
and number of injection wells as described in the application and other supporting data.
2. This permit is not transferable without prior notice to, and approval by, the Director of the
Division of Water Quality (Director). In the event there is a desire for the facility to change
ownership, or there is a name change of the Permittee, a formal permit amendment request
must be submitted to the Director, including any supporting materials as may be appropriate,
at least 30 days prior to the date of the change.
3. The issuance of this permit shall not relieve the Permittee of the responsibility of complying .
with any and all statutes, rules, regulations, or ordinances that may be imposed by other
local, state, and federal agencies having jurisdiction. Furthermore, the issuance of this permit
does not imply that all regulatory requirements have been met.
PART IV - PERFORMANCE STANDARDS
1. The injection facility shall be effectively maintained and operated at all times so that there is
no contamination of groundwater which will render it unsatisfactory for normal use.
2. In the event that the facility fails to perform satisfactorily, including the creation of nuisance
conditions or failure of the injection zone to adequately assimilate the injected fluid, the
Permittee shall take immediate corrective actions including those actions that may be
required by the Division of Water Quality such as the repair, modification, or abandonment
of the injection facility.
3. The Permittee shall be required to comply with the terms and conditions of this permit even
if compliance requires a reduction or elimination of the permitted activity.
4. The issuance of this permit shall not relieve the Permittee of the responsibility for damages to
surface or groundwater resulting from the operation of this facility.
PART V - OPERATION AND MAINTENANCE REQUIREMENTS
I. The injection facility shall be properly maintained and operated at all times.
2. The Permittee must notify the Division and receive prior written approval from the Director
of any planned alterations or additions in the permitted facility or activity not specifically
authorized by the permit.
3. At least .forty-eight (48) hours prior to the initiation of the operation of the facility for
injection, the Permittee must notify by telephone the Aquifer Protection Section-UIC, Central
Office staff, telephone number 919-715-6166. Notification is required so that Division staff
can inspect or otherwise review the injection facility and determine if it is in compliance with
permit conditions.
Permit No. WI0300 ]-W PAGE 3 OF 6
ver. June 2011 UIC-5I!5T

PART VI - INSPECTIONS
1. Any duly authorized officer, employee, or representative of the Division of Water Quality
may, upon presentation of credentials, enter and inspect any .property, premises, or place on
or related to the injection facility at any reasonable time for the purpose of determining
compliance with this permit, may inspect or copy any records that -must be maintained under
the terms and conditions of this permit, and may obtain samples of groundwater,. surface
Water, or injection fluids. .
2. Department representatives shall 'have reasonable access for purposes .of inspection,
observation, and sampling associated with injection and any related facilities as provided for
in N.C.G.S. 87-90.
3. Provisions shall be made for collecting any necessary and appropriate samples -associated
with the injection facility activities.
PART VII - MONITORING AND REPORTING REQUIREMENTS
1. Within 30 days of completion of well construction, a completed Well Construction Record
(Form GW=l) must be submitted for each injection well to:
Aquifer Protection Section-UIC Program
DENR'-Division of Water Quality
1636 Mail Service Center
Raleigh, NC 27699-1636
2. The proposed monitoring plan received included in the application shall be followed except
that ORP and calcium shall be added -to the monitoring plan. Additionally, samples shall be
collected each quarter for 4 quarters after the final injection -to confirm groundwater quality
meets standards according to 15A NCAC 2L. 0200.
3. All sample results shall 'be submitted to the Aquifer Protection Section's Mooresville
Regional Office and the Raleigh Central Office. Any monitoring (including groundwater,
surface water, or soil sampling) deemed necessary by the Division of Water Quality to ensure
surface and ground water protection, will be established and an acceptable sampling
reporting schedule shall be followed.
4. The Permittee shall submit an Injection Event Record within 30 days of completing each
injection.
5. The Permittee shall produce a final project evaluation within 9 months after completing all
injection -related activity associated with this permit or produce a project interim evaluation
before submitting a renewal application for this permit. This document shall assess the
injection projects findings in a written summary. The final project' evaluation shall also
contain monitoring well sampling data, contaminant plume maps and potentiometric surface
maps.
6. The monitoring results and the final project evaluation shall be submitted to:
Permit No. WI0300180 PAGE 4'OF 6
ver. June 2011.UIC-5I/5T

UIC Program Staff
DWQ — Aquifer Protection Section and
1636 Mail Service Center
Raleigh, NC 27699-1636
DWQ - Aquifer Protection Section
Mooresville Regional Office
610 E. Center Ave.
Mooresville, NC 28115
6. The Permittee shall report by telephone, within 48 hours of the occurrence or first knowledge
of the occurrence, to the Mooresville Regional Office, telephone number 704-663-1699, any
of the following:
(A)Any occurrence at the injection facility which results in any unusual operating
circumstances;
(B) Any failure due to known or unknown reasons, that renders the facility incapable of
proper injection operations, such as mechanical or electrical failures.
7. Where the Permittee becomes aware of an omission of any relevant facts in a permit
application, or of any incorrect information submitted in said application or in any report to
the Director, the relevant and correct facts or information shall be promptly submitted to the
Director by the Permittee.
8. In the event that the permitted facility fails to perform satisfactorily, the Permittee shall take
such immediate action as may be required by the Director.
PAIN VIII - PERMIT RENEWAL.
In order to continue uninterrupted legal use of the injection facility for the stated purpose, the
Permittee must submit an application to renew the permit 120 days prior to its expiration date.
PART IX - CHANGE OF WELL, STATUS
1. The Permittee shall provide written notification within 15 days of any change of status of an
injection well. Such a change would include the discontinued use of a well for injection. If a
well is taken completely out of service temporarily, the Permittee must install a sanitary seal.
If a well is not to be used for any purpose that well must be permanently abandoned
according to 15A NCAC 2C .0214, Well Construction Standards.
2. When operations have ceased at the facility and a well will no longer be used for any
purpose, the Permittee shall abandon that injection well in accordance with the procedures
specified. in 15A NCAC 2C .0214, including but not limited to the following:
(A) All casing and screen materials may be removed prior to initiation of abandonment
procedures if such removal will not cause or contribute to contamination of the
groundwaters.
(B) The entire depth of each well shall be sounded before it is sealed to insure freedom
from obstructions that may interfere with sealing operations.
(C) The well shall be thoroughly disinfected, prior to sealing, if the Director determines
Permit No. WI0 00j 1 ')0 PAGE 5 OF 6
ver. June 2011 UIC-5I/5T

that failure to do so could lead to the contamination of an underground source of
drinking water.
(D) Drilled wells shall be completely filled with cement grout or bentonite grout, which
shall be. introduced into the well through a pipe which extends to the bottom of the
well and is raised as the well is filled.
(E) In the case of gravel -packed wells in which the casing and screens have not been
removed, neat -cement, or bentonite grout shall be injected into the well completely
filling it from the bottom of the casing to the top.
(F) In those cases when, as a result of the injection operations, a subsurface cavity has
been created, each well shall be -abandoned in such a manner that will prevent the
movement of fluids. into or between underground sources of drinking water and in
accordance with the terms and conditions of the permit.
(G) The Permittee.shall submit a Well Abandonment Record (Form GW-3.0) as specified
in 15A NCAC 2C .0213(h)(1) within 30 days of completion of abandonment.
3. The'.written documentation required in Part IX (1) and (2) (G) shall be submitted to:
Aquifer Protection Section-UIC Program
DENR-Division of Water Quality
1636 Mail Service Center
Raleigh, NC 27699-1636 .
PART X — WORKER PRECAUTIONS DURING APPLICATION
1. Some effects reported to be associated with the product proposed. to be used areas follows:
eye, skin, nose, throat, and lung irritation. If the product is released into the environment in a
way that could result in a suspension of fine solid or liquid particles (e.g., grinding, blending,
vigorous shaking or mixing), then proper personal protective equipment should be used. The
application process should be reviewed by an industrial hygienist to ensure that the most
appropriate personal protective equipment is used.
2. Persons working with these products should wear goggles or a face shield, gloves, and
protective clothing. Face and body protection should be used for anticipated splashes or
sprays.
3. Eating, drinking, smoking, handling contact lenses, and applying cosmetics should not be
permitted in the application area during or immediately following application.
4. Safety controls should be in .place to ensure that the check valve and the pressure delivery
systems are working properly.
5. The Material Safety Data Sheets should be followed to prevent incompatible or adverse
reactions and injuries.
Permit No. WI0300180 PAGE 6 OF 6
ver. June 2011 UIC-5I/5T

POLARIS - Version 3.1
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Parcel Information
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Parcel ID#: 18921101 GIS ID#:
18921101
Owner PATTERSON
Name: PROPERTY LLC
AND C/O LEVINE
PROPERTIES INC
Mailing PO BOX 2439
Address: MATTHEWS, NC 2810(
Property Characteristics
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Land Area: '10.812AC
Fire District:00-CITY OF
CHARLOTTE
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)istrict:
Account NC CORP
Fype:
Municipality: 1-CHARLOTTE
Property WAREHOUSE
Jse:
Deed Reference(s) and Sales
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' 1 26271-599 (21 / 01 1)
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