WI0300186_Permit (Issuance)_20111110

DIVISION OF WATER QUALITY
AQUIFER PROTECTION SECTION
November 10, 2011
PERMIT ISSUANCE MEMO pp,�
TO: Debra Watts Ott 0
THROUGH: Thomas Slusser
FROM: David Goodrich 21Z
RE: Permit To Inject Fluorescein as a Tracer
AkzoNobel Surface Chemistry, LLC Cedar Springs Road Plant in Salisbury
I recommend that Permit Number WI0300186 be issued to AkzoNobel Surface Chemistry, LLC to inject
Fluorescein dye to quantify the groundwater flux in the deep bedrock hydrostratigraphic unit and verify local
hydraulic conductivity in groundwater contaminated with volatile and semivolatile organic compounds, metals,
and chlorinated ethenes and ethanes.
SITE DESCRIPTION This is a former National Starch Chemical Company Superfund site that is currently
owned and operated by AkzoNobel Surface Chemistry LLC. The site has extensive chemical contamination,
primarily caused by the practice of using unlined trenches and a lagoon to handle and dispose of more than
350,000 gallons of wastewater containing many different kinds of chemicals.
HYDROGEOLOGIC DESCRIPTION The bedrock beneath the site is part of the Churchland Plutonic Suite,
which consists of granite and other plutonic intrusive rock. The bedrock is overlain by saprolite which varies in
thickness from approximately 60 feet to approximately 10 feet. Surficial soils are primarily a mixture of silt and
clay, with an increase in particle size with depth to coarse sand and weathered rock just above the surface of the
bedrock. Shallow ground water is encountered at depths ranging from approximately 7 feet near the unnamed
tributary stream to more than 50 feet at uphill locations. The average hydraulic gradient in the most shallow
groundwater unit is approximately 2.1%, and assuming an effective porosity of 15% and hydraulic conductivity
of 1 ft/day, the average groundwater flow rate would be on the order of 0.14 feet per day.
EXTENT OF CONTAMINATION The exact size of the impacted area is not known. Based on the
sampling data from monitor wells of various depths, the impacted area is at least 1,500 feet long, 1,500 feet
wide, and mostly contained in the saprolite and shallow bedrock in an approximate vertical extent of 100 feet
(Figures 3, 7, 8 and 9).
PROPOSED INJECTION The injectant is fluorescein dye, which is used as a tracer to trace the path of
groundwater flow. Only one well will be used for the injection, which will be into deep fractured bedrock, and
the injection will be performed in such a manner as to have no hydraulic impact on the ground water in the
vicinity of the injection well. This will be achieved by slowly introducing the dye in a flow stream that will be
equal to a simultaneous withdrawal of water from the well, and a closed -loop circulation will take place within
the well and the recirculating pumping system that will bring the dye to a uniform concentration in the well's
hydraulic column (approximate volume of 71 gallons). The concentration of dye will gradually decline over
time as the dye -laden water slowly leaves the well and is replaced by ordinary ground water. The volume of
injected water will be less than 1% of the total volume of water impacted by the contamination.
HOW IT WORKS This is a tracer substance and has no significant or intended remedial impact.
MONITORING The monitoring will consist of sampling the injection well for the concentration of
fluorescein dye immediately after injection, and then at 1, 2, 3, 7, 14, 28, and 42 days after the injection, or until

the dye concentration declines to less than 90% of its initial concentration. Laboratory analysis will be used, and
the schedule may be adjusted based on the rate of dye dissipation. We are adding the requirement of visually
examining the nearby unnamed tributary stream during each sampling event, and sampling the stream during
each sampling event for the concentration of the dye, provided the stream is flowing.
EPIDEMIOLOGY On July 31, 2000, the DHHS' Epidemiology Branch provided comments on Fluorescein
for groundwater tracing. Dr. Luanne K. Williams did not present any information that would preclude the use of
these products for injection but did provide a health risk analysis and worker safety precautions, which are in
Part X of the attached permit.
REGIONAL OFFICE COMMENTS Maria Schutte and Andrew Pitner of the Mooresville Regional Office
recommend issuance of this permit. They recommend requiring ongoing visual inspections of the unnamed
tributary stream adjacent to the injection well, and the sampling of this stream (when flowing) for fluorescein
dye. The permit will require a visual inspection of the stream and sampling of the stream at every monitoring
(sampling) event of the proposed monitoring schedule (see above).

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
AkzoNobel Surface Chemistry, LLC
FOR THE OPERATION OF 1 TYPE 5T INJECTION WELL, defined in Title 15A North
Carolina Administrative Code 2C .0209(e)(3)(J), to inject fluorescein dye for the characterization
of local hydrogeologic conditions. These injection wells/points will be located at the AkzoNobel
Cedar Springs Road Plant, 485 Cedar Springs Road, Unit A, Salisbury, Rowan County, North
Carolina, and will be operated in accordance with the application submitted October 24, 2011,
and in conformity with the specifications and supporting data submitted therein, 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 October 31,
2014, and shall be subject to the specified conditions and limitations set forth in Parts I through
X hereof.
Permit issued this the 17th day of November, 2011.
for Coleen H. Sullins, Director
Division of Water Quality
By Authority of the Environmental Management Commission.
Permit No. WI0300186 PAGE 1 OF 7
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PART I - WELL CONS `nJCTION 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 Permittee shall
notify the Aquifer Protection Section -Underground Injection Control (UIC) Central Office
staff, telephone number 919-715-6162 and the Mooresville Regional Office Aquifer
Protection Section Staff, telephone number [phone].
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. WI0300186 PAGE 2 OF 7
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PART III - OPERATIOk ,k"ND 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.
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
1. The injection facility shall be properly maintained and operated at all times.
2. The Permittee must notify the Division and receive prior written approval from the Director
of any planned alterations or additions in the permitted facility or activity not specifically
authorized by the permit.
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 919-715-6162. 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. WI0300186 PAGE 3 OF 7
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PART VI - INSPECTIOiNn,
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-1) must be submitted for each injection well to:
Aquifer Protection Section-UIC Program
DENR-Division of Water Quality
1636 Mail Service Center
Raleigh, NC 27699-1636
2. The proposed monitoring plan included in the application shall be followed, along with
visually inspecting the unnamed tributary stream during each sampling event, and sampling
the unnamed tributary stream during each sampling event for fluorescein dye, when the
stream is flowing, at a downstream location approximately 100 north of the injection well.
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.
3. The Permittee shall submit an Injection Event Record within 30 days of completing each
injection.
4. The Permittee shall produce a final project evaluation within 9 months after completing all
injection -related activity associated with this permit or produce a project interim evaluation
before submitting a renewal application for this permit. This document shall assess the
injection projects findings in a written summary. The final project evaluation shall also
contain monitoring well sampling data, contaminant plume maps and potentiometric surface
maps.
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5. The monitoring results and the final project evaluation shall be submitted to:
UIC Program Staff DWQ - Aquifer Protection Section
DWQ — Aquifer Protection Section and Mooresville Regional Office
1636 Mail Service Center 610 East Center Avenue, Suite 301
Raleigh, NC 27699-1636 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 [phone],
any of the following:
(A)Any occurrence at the injection facility which results in any unusual operating
circumstances;
(B) Any failure due to known or unknown reasons, that renders the facility incapable of
proper injection operations, such as mechanical.or electrical failures.
7. Where the Permittee becomes aware of an omission of any relevant facts in a permit
application, or of any incorrect information submitted in said application or in any report to
the Director, the relevant and correct facts or information shall be promptly submitted to the
Director by the Permittee.
8. In the event that the permitted facility fails to perform satisfactorily, the Permittee shall take
such immediate action as may be required by the Director.
PART VIII - PERMIT RENEWAL
In order to continue uninterrupted legal use of the injection facility for the stated purpose, the
Permittee must submit an application to renew the permit 120 days prior to its expiration date.
PART IX - CHANGE OF WELL STATUS
1. The Permittee shall provide written notification within 15 days of any change of status of an
injection well. Such a change would include the discontinued use of a well for injection. If a
well is taken completely out of service temporarily, the Permittee must install a sanitary seal.
If a well is not to be used for any purpose that well must be permanently abandoned
according to 15A NCAC 2C .0214; Well- Construction Standards.
2. When operations have ceased at the facility and a well will no longer be used for any
Jpurpose, 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.
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(B) The entire depth of each well shall be sounded before it is sealed to insure freedom
from obstructions that may interfere with sealing operations.
(C) The well shall be thoroughly disinfected, prior to sealing, if the Director determines
that failure to do so could lead to the contamination of an underground source of
drinking water.
(D) Drilled wells shall be completely filled with cement grout or bentonite grout, which
shall be introduced into the well through a pipe which extends to the bottom of the
well and is raised as the well is filled.
(E) In the case of gravel -packed wells in which the casing and screens have not been
removed, neat -cement, or bentonite grout shall be injected into the well completely
filling it from the bottom of the casing to the top.
(F) In those cases when, as a result of the injection operations, a subsurface cavity, has
been created, each well shall be abandoned in such a manner that will prevent the
movement of fluids into or between .underground sources of drinking water and in
accordance with the terms and conditions of the permit.
(G) The Permittee shall submit a Well Abandonment Record (Form GW-30) as specified
in 15A NCAC 2C .0213(h) (1) within 30 days of completion of abandonment.
3. The written documentation required in -Part IX (1) and (2) (G) shall be submitted to:
Aquifer Protection Section-UIC Program
DENR-Division of Water Quality
1636 Mail Service Center
Raleigh, NC 27699-1636
PART X — WORKER PRECAUTIONS DURING APPLICATION
1. Some effects reported to be associated with the product proposed to be used are as 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.
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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.
6. 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.
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