WI0300192_Permit (Issuance)_20120613

DIVISION OF WATER QUALITY
AQUIFER PROTECTION SECTION
June 13, 2012
PERMIT ISSUANCE MEMO
TO: Debra Watts
THROUGH: Thomas Slusser
FROM: David Goodrich
RE: Permit To Inject BioSolve
Former Exxon Mobil Retail Facility No. 42094
I recommend that Permit Number WI0300192 be issued to ExxonMobil Environmental Services to inject BioSolve to
remediate soils and groundwater contaminated with petroleum hydrocarbons.
SITE DESCRIPTION Presently a vehicle repair facility, the site is a former service station / retail store that was
active between 1970 and 1990. Five USTs were used during this time to store gasoline, fuel oil and heating oil. The
tanks were removed in 1990 and evidence of a leak was found at that time. The most highly impacted soil is at the
capillary fringe, just above the water table, over a depth range of approximately 11 to 15 feet below land surface.
There are reportedly no active water supply wells within '/< mile of the site. The site has been classified as being of
"Intermediate Risk", and free product has been observed at a maximum thickness of 0.73 feet in monitor well MW-9
(between the former dispenser islands).
HYDROGEOLOGIC DESCRIPTION The site is situated in the Charlotte Belt of the Piedmont Physiographic
Province and is underlain by granitic intrusions. Borings on the site have revealed the overlying material to consist
primarily of silt and clay with some sand and silty sand. Partially weathered bedrock has been encountered at depths
as shallow as 18 feet with competent bedrock at 22 feet. Ground water is typically encountered at depths of 10 to 20
feet below land surface, and hydraulic perching is possible. The average hydraulic gradient is approximately 1 % (0.01
ft/ft) in a south -southeasterly direction. Based on a typical hydraulic conductivity of 2.83 ft/day, the average
groundwater flow rate across the site is estimated to be approximately 0.15 ft/day.
EXTENT OF CONTAMINATION The affected volume of soil and ground water is approximately 120 feet in
length, approximately 70 feet in width, and has an average depth of approximately 15 feet (figures 4, 5, 6 & 7 of the
Additional Information Request Package). This represents a total impacted soil and groundwater volume of
approximately 126,000 cubic feet, containing a groundwater volume of approximately 190,000 gallons.
PROPOSED INJECTION BioSolve is a surfactant substance which serves to displace the hydrocarbon
substances by being preferentially absorbed onto the surfaces of the soil particles. It facilitates extraction and
bioavailability by making the petroleum substances more mobile and serving to microencapsulate the substance and
make them more readily available to petroleum -eating bacteria. The injection event will be followed with an
aggressive fluid vapor recovery event on the four injection wells (MW-5, MW-9, INJ-1 and INJ-2) that is intended to
remove the liberated fluids and vapors. The injections will take place simultaneously through these four permanent
injection wells during 11yo injection events. During each injection event, each of the four wells _will 600
gallons of injectant fluid. IfIf wo mJechon events are performed (by repeating the procedure), the total injected volume
will be approximately 4800 gallons. This volume represents less than 3% of the total estimated volume of ground
water impacted by the UST leakages.
HOW IT WORKS BioSolve is a surfactant substance which serves to break up the hydrocarbohs, to reduce their
volatility, to mobilize them for extraction, and to make hydrocarbon breakdown products more readily available to
natural bacteria that feed on it. It is reportedly harmless to the bacteria which feed on hydrocarbon substances.

MONITORING As per the proposed monitoring program, monitor wells Vff-5, MW-6, MW-7, MW-8, MW-
9, and DW-1 will be measured for free -product thickness after injection and vapor recovery activities. Re e- cling the
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modifications recommended by APS, monitor wells MW-5, MW-7, MW-9, the new pair of monitor wells installed
downgradient of injection area INJ-1/1\4W-9, the new deep monitor well installed downgradient of injection area INJ-
2/MW-5, and monitor wells DW-1, MW-2R, MW-6 and MW-8 will be sampled for Volatile Organic Compounds,
water level, free product thickness, and for the field parameters of Conductivity, pH, and ORP. Sampling will be
performed each quarter after the final injection event for a full year. The field parameters of Conductivity, pH and
ORP will serve as an indicator of injectant/ treatment products, and any significant change in any of these parameters
in a particular well shall initiate an expansion of the sampling parameters for that well to include Calcium, Arsenic,
Iron, Zinc, and Sulfates.
EPIDEMIOLOGY On February 26, 2002, the DHHS' Epidemiology Branch provided comments on BioSolve
for groundwater remediation. Dr. Luanne Williams did not present any information that would .preclude the use of
these products for injection, but did provide ahealth risk analysis and worker safety precautions, which are in Part X
of the attached permit.
REGIONAL OFFICE COMMENTS Maria Schutte of the Mooresville Regional Office recommends issuance of this
permit. The Mooresville Regional Office further recommended that the field parameters of C ondudiyity nH, and
_ORP serve as an indicator of the presence of injectants/ treatment products and that any significant change of any of
these parameters in a particular well will initiate an expansion of the list of sampling parameters for that well to
include Sulfates, Calcium, Arsenic, Iron, and Zinc. The Regional Office further recommends that the wellheads ofthe
existing monitor wells be maintained (i.e., messing bolts, unsecured locks, etc.); that the monitor wells be sampled
quarterly for the first year after the final injection; that a deep well be installed downgradient (southeast) of the INJ-
2/MW-5 injection area near existing monitor well MW-2R and added to the monitoring program; and that a well nest
(a sha oll w monrtor well and a deep monitor well) be installed downgradient (southeast) ofthe INJ-1/MW-9 injection
and added to the monitoring prQgr�m_to track the ctant and to better assess the vertical extent of its impacts.
Existing monitor well MW-2R will also be added to the monitoring program. All ofthese recommendations have been
included m t e permit.

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
ExxonMobil Environmental Services
FOR THE CONSTRUCTION AND/OR OPERATION OF 4 CLASS 5 INJECTION WELLS,
defined in Title 15A North Carolina Administrative Code 2C .0209(5)(b)(viii), to inject
BioSolve, for the mobilization, dispersal, and bioenhanced remediation of petroleum
hydrocarbons. These injection wells/points will be located at the former Exxon Mobil Retail
Facility Number 42094, 3721 Freedom Drive, Charlotte, Mecklenburg County, North Carolina,
and will be operated in accordance with the application submitted March 2, 2012, and in
conformity with the specifications and supporting data submitted May 14, 2012 and June 19,
2012, 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 May 31, 2014,
and shall be subject to the specified conditions and limitations set forth in Parts I through X
hereof.
Permit issued this the 27th day of June, 2012.
for Charles Wakild, P.E., Director
Division of Water Quality
By Authority of the Environmental Management Commission.
Permit No. WI0300192 PAGE I OF 7
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) and Well Construction Standards applicable to monitor wells (15A NCAC 2C 0100).
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 or monitor well shall not hydraulically connect separate aquifers.
5. Each injection well or monitor 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 or monitor 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 or monitor purposes and the entrance to each well must be secured
with a locking cap.
7. Each injection well or monitor well shall be afforded reasonable protection against damage
during construction and use.
8. Each injection well or monitor well shall have permanently affixed an identification plate.
PART II - WELL CONSTRUCTION SPECIAL CONDITIONS
Prior to beginning injection, a deep monitor well shall be constructed downgradient of
injection area INJ-2/MW-5 near existing well MW-2R. A well pair consisting of one shallow
monitor well and one deep monitor well shall be constructed downgradient of injection area
INJ-1/MW-9. All three of these. wells shall be included in the monitoring program.
2. At least forty-eight (48) hours prior to constructing each injection well or monitor well, the
Permittee shall notify the Aquifer Protection Section -Underground Injection Control (UIC)
Central Office staff, telephone number 919-807-6352 and the Mooresville Regional Office
Aquifer Protection Section Staff, telephone number [phone].
3. 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. WI0300192 PAGE 2 OF 7
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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 wellheads of the existing monitor wells shall be secured against tampering, and
conditions such as missing padlocks; missing bolts, etc. shall be corrected before injection
operations commence.
2. 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.
3. 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
Penn ittee 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.
4. 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.
5. The issuance of this permit shall not relieve the Permittee of the responsibility for damages to
surface or groundwater resulting from the operation of this facility.
PART V - OPERATION AND MAINTENANCE REQUIREMENTS
1. The injection facility shall be properly maintained and operated at all times.
2. The Permittee must notify the Division and receive prior written approval from the Director
of any planned alterations or additions in the permitted facility or activity not specifically
authorized by the permit.
3. At least forty-eight (48) hours prior to the initiation of the operation of the facility for
injection, the Permittee must notify by telephone the Aquifer Protection Section-UIC, Central
Office staff, telephone number 919-807-6352. 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. WI0300192 PAGE 3 OF 7
ver. June 2011 UIC-5I/5T.

PART VI - INSPECTIONS
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 with some
modifications. As per the proposed monitoring program, monitor wells MW-5, MW-6, MW-
7, MW-8,,MW-9, and DW-1 will be measured for free -product thickness after injection and
vapor recovery activities. Monitor wells MW-5, MW-7, MW-9, the new pair of monitor
wells installed downgradient of injection area INJ-1/MW-9, the new deep monitor well
installed downgradient of injection area INJ-2/MW-5, and monitor wells DW-1, MW-2R,
MW-6 and MW-8 will be sampled for Volatile Organic Compounds, water level, free
product thickness, and for the field parameters of Conductivity, pH, and ORP. Sampling will
be performed each quarter after the final injection event for a full year. The field parameters
of Conductivity, pH and ORP will serve as an indicator of injectant/ treatment products, and
any significant change in any of these parameters in a particular well shall initiate an
expansion of the sampling parameters for that well to include Calcium, Arsenic, Iron, Zinc,
and Sulfates. 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
Permit No. WI0300192 PAGE 4 OF 7
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N
before submitting a renewal application for this permit. This document shall assess the
injection projects findings in a written summary. The final project evaluation shall also
contain monitoring well sampling data, contaminant plume maps and potentiometric surface
maps.
5. The monitoring results and the final project evaluation shall be submitted to:
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 VIH - 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 .0240, 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 .0240, including but not limited to the following:
Permit No. WI0300192
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UIC-5I/5T
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(A) All casing and screen materials may be removed prior to initiation of abandonment
procedures if such removal will not cause or contribute to contamination of the
groundwaters.
(B) The entire depth of each well shall be sounded before it is sealed to insure freedom
from obstructions that may interfere with sealing operations.
(C) The well shall be thoroughly disinfected, prior to sealing, if the Director determines
that failure to do so could lead to the contamination of an underground source of
drinking water.
(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 .0225(k)(1)(A) 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
Some. effects reported to be associated with the product proposed to be used are as follows:
eye, skin, nose, throat, and lung irritation. Significant inhalation exposure can cause central
nervous system depression and lung, liver, and kidney injury. 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.,
Permit No. WI0300192 PAGE 6 OF 7
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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.
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.
Permit No. WI0300192 PAGE 7 OF 7
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