WI0300210_Permit_20121109

i
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
North Carolina Department of Transportation — Roadside Environment Unit
FOR THE CONSTRUCTION AND OPERATION OF 35 IN SITU REMEDIATION
INJECTION WELLS, defined in Title 15A North Carolina Administrative. Code 2C
.0209(5)(b)(viii), to inject emulsified oil substrate EOS 598B42 with EOS Vitamin B12
Supplement, for the mobilization and facilitated natural bioremediation of chlorinated ethenes
And ethanes. These injection wells/points will be located at the former NCDOT Asphalt Testing
Site Number 2-66 at 164 Bostian Bridge Drive, Statesville, Iredell County,. North Carolina, and
will be operated in accordance with the application submitted September 6, 2012, and in
conformity with the specifications and supporting data submitted September 17, 2012 and
November 1, 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 October 31,
2017, and shall be subject to the specified conditions and limitations set forth in Parts I through
X hereof.
Permit issued this the 9th day of November, 2012.
for Charles Wakild, P.E., Director
Division of Water Quality
By Authority of the Environmental Management Commission.
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Permit No. WI0300210
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'PART I - WELL CONSTRUCTION GENERAL CONDITIONS
1. The Permittee must comply with all conditions of this permit and with the standards and
criteria specified in Criteria and Standards Applicable to Injection Wells (15A NCAC 2C
.0200). Any noncompliance with conditions of this permit constitutes a violation. of the
North Carolina Well Construction Act and is grounds for enforcement action as provided for
in N.C.G.S. 87-94. -
2. This permit shall become voidable unless the facility is constructed in accordance with the
conditions of this permit, the approved plans and specifications, and other supporting data.
3. This permit is valid only for construction of the number of irijection 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 919-807-6352 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.
PART III - OPERATION AND USE GENERAL CONDITIONS
1. This permit is effective only with respect to the nature, volume of materials, rate of injection,
and number of injection wells as described in the application and other supporting data.
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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 Pennittee 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.
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.
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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 c6nditions 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
surface water sampling. Groundwater samples will be obtained from deep monitoring well
DMW-7, and from deep saprolite monitoring wells DMW-1, DMW-2, DMW-6, DMW-8,
DMW-9, DMW-10, and DMW-11. A baseline sampling of all these wells has already been
performed, and all of these wells will be sampled on a quarterly schedule for two years after
the injection event takes place. Field measurements will be taken for Dissolved Oxygen
(DO), Oxidation -Reduction Potential (ORP), pH, specific conductivity, ferrous iron and
temperature. Laboratory analyses will be performed for purgeable halocarbons according to
EPA Method 601, and for metabolic acids, nitrate, sulfate, sulfide, metals (Arsenic, Barium,
Cadmium, Chromium, Lead, Mercury, Selenium and Silver), methane, ethane, ethane, and
Total Organic Carbon (TOC).
A baseline sampling of surface water for field measurements shall be taken at points
upstream and downstream of the injection area along the tributary stream prior to injection,
and post -injection on the same quarterly schedule as the well sampling for two years after the
injection takes place. In the event that the field measurements of the surface water samples
indicate an impact from the injection activities, laboratory analyses,.as described above, will
also be performed on the surface water samples.
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.
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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.
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 seat.
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.
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2. When operations have ceased at the facility and a well will ono 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:
(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 wellshall 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
1. 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
coughing, wheezing, and shortness of breath. Skin exposure can cause a skin allergy where.
very low future exposures can cause itching and a skin rash. 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.
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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.
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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DIVISION OF WATER QUALITY
AQUIFER PROTECTION SECTION
November 1, 2012
PERMIT ISSUANCE MEMO
TO: Debra Watts
THROUGH: Thomas Slusser
FROM: David Goodrich 2141
RE: Permit To Inject EOS 598B42 with EOS Vitamin B12 Supplement
Former NCDOT Asphalt Testing Site No. 2-66 in Statesville
I recommend that Permit Number W10300210 be issued to the NCDOT Roadside Environmental Unit to inject
EOS 5981342 with EOS Vitamin B12 Supplement to remediate soils and groundwater contaminated with
Chlorinated Ethenes and Ethanes.
SITE DESCRIPTION The site is a former NCDOT asphalt testing facility which was active between +/- 1964
and +/- 1989. It is currently leased and is used for mineral processing and asphalt production. The soil and
groundwater contamination is believed to be the result of the former testing operations.
HYDROGEOLOGIC DESCRIPTION The site is situated in the Charlotte Belt of the Piedmont Physiographic
Province. The bedrock consists of metamorphosed quartz diorite at a depth of 35 to 65 feet, overlain primarily
by weathered bedrock and saprolite which begins at a depth of 5 to 15 feet and generally grading vertically to
clay towards the surface. There appear to be relatively thin areas of sandy silt overlying the bedrock in some
locations. The surface soils overlying the weathered bedrock and saprolite are primarily composed of fill
material. Groundwater is typically encountered under unconfined conditions at a depth of approximately 20 to
30 feet below ground surface. The hydraulic gradient is approximately 2% in a west-northwest direction and the
groundwater velocity is estimated to be approximately 55 feet per year.
EXTENT OF CONTAMINATION The volume impacted by the chlorinated substances is approximately
250 feet long, approximately 180 feet wide (maximum width), and approximately 20 feet deep (figures H-2, H-
4, H-5 and H-6). Assuming minimal bedrock fracturing, these dimensions suggest an impacted subsurface
volume of approximately 75,000 cubic feet and an impacted groundwater volume of approximately 56,000
gallons.
PROPOSED INJECTION The injectant is a blend of emulsified oil substrate which is composed of
soybean oil, lactate, non-ionic surfactants, macronutrients, micronutrients, and vitamins which stimulate the
growth and health of anaerobic bacteria. The surfactants serve to free up the chlorinated substances and most of
the other ingredients. serve to promote native bacteria which perform biodegradation. Injection will take place
through 35 injection points via direct -push drill rods in a single injection event, resulting in a total injection
volume of approximately 1,350 gallons (approximately 38 gallons per injection point). The total injection
volume is equal to less than 3% of the volume of groundwater which has been impacted by the contamination.
HOW IT WORKS The surfactants serve to separate the chlorinated substances from the soil particles and
mobilize them. Most of the other injectant components serve to promote the growth and activity of the
biodegrading bacteria which are naturally present in the soil.
MONITORING The proposed monitoring plan will be followed. The plan is to sample deep monitoring
well DMW-7 and from deep saprolite monitoring wells DMW-1, DMW-2, DMW-6, DMW-8, DMW-9, DMW-
10, and DMW-11. A baseline sampling of all of these wells has already been performed, and the wells will be

sampled quarterly for two years after the injection event takes place. Field measurements will be taken for
Dissolved Oxygen (DO), Oxidation -Reduction Potential (ORP), pH, specific conductivity, ferrous iron and
temperature. Laboratory analyses will be performed for purgeable halocarbons according to EPA Method 601,
and for metabolic acids, nitrate, sulfate, methane, ethane, ethane, and Total Organic Carbon (TOC). Upon the
recommendations of the MRO, the sampling plan also includes groundwater sampling for metals (Arsenic,
Barium, Cadmium, Chromium, Lead, Mercury, Selenium and Silver) and sulfide. As per the MRO
recommendations, the procurement of baseline surface water sampling (field parameters only) will take place at
locations upstream and downstream of the injection area, and will be performed after injection on the same
schedule as the sampling of the monitoring wells. If the field parameter testing of the post -injection surface
water sample(s) indicate a possible injection impact to the surface waters, chemical analyses, as described for
the monitoring wells above, will be performed on the surface water samples.
EPIDEMIOLOGY On October 28, 2003, the DHHS' Epidemiology Branch provided comments on
emulsified oil substrate for groundwater remediation. Dr. Luanne Williams did not present any information that
would preclude the use of these products for injection, but did provide a health risk analysis and worker safety
precautions, which are'in Part X of the attached permit.
REGIONAL OFFICE COMMENTS Maria Schutte of the Mooresville Regional Office recommends issuance of
this permit. The Regional Office requested revised geologic cross -sections be provided which includes the
proposed injection borings, as well as a copy of the property access agreement with the owner of a neighboring.
property to allow access for post -injection groundwater monitoring and surface water monitoring. They further
recommend that the groundwater sampling parameters include metals and sulfide, and that surface water
monitoring take place for field parameters upstream and downstream of the injection area, and that chemical
analyses be performed on the surface water samples if the field parameter testing indicates- surface water impacts
from the injection activities. The sampling has been revised to reflect these recommendations. The -MRO
comments also recommended that the Central APS Office contact the NCDWM's Inactive Hazardous Sites
Branch to confirm that they have not already reviewed and/or approved of the actions which our injection permit
is addressing. I contacted Keith Snavely of the DWM IHSB, who informed me that these actions have not taken
place for this facility.