WI0300345_Permit (Issuance)_20170717

DIVISION OF WATER RESOURCEi-- -1
WQROS
July 17, 2017
IT) IXU• `_MAIM 1 U 1
TO: Debra Watts
FROM: Michael Rogers
RE: Issuance of permit to inject (Permit #WI0300345)
Trex Properties, LLC
Mecklenburg County
I recommend that Permit Number WI0300345 be issued to the above to inject the following additive(s) to remediate
groundwater (GW) contaminated with VOCs: Klozur and Fe EDTA.
SITE DESCRIPTION: The site is a former waste recycling facility. During past operations, there were incidental spills of
solvents and other hazardous chemicals/waste. Due to this past improper use and spillage of other chemicals, GW is
contaminated with various contaminates including VOCs (Figures 1 and 2).
HYDROGEOLOGIC DESCRIPTION: The site is located within the Charlotte Belt of the Piedmont geological province. The
hydrogeology on site consists of layers of saprolitic silts and clays overlying increasingly compact PWR, and bedrock
consisting of meta -diorite. Depth to bedrock varies between appx 50-100 feet BLS. GW flow direction for the surficial
aquifer (target aquifer) is generally north. The reported velocity also varies but averages appx 57ft/yr (refer to Figures 4
and 5).
EXTENT OF CONTAMINATION: The groundwater contamination plume(s) are large and vary in shape and size but are
roughly circular in shape and are 500 ft. by 600 ft. (Refer to Figure 3). The plumes are not delineated to the north because
Sugar Creek acts as a barrier and no VOCs has been reported.
PROPOSED INJECTION: For this project, there will be injections via proposed 20 permanent wells. There is one injection
event planed over 15 days. The flow rates will be approximately @ 5 GPM and estimated average injection pressure for
the wells will be appx 20-80 psi. Based upon the size of the treatment area and the amount of additives to be injected
(69,500 gallons), the potential plume displacement will be low (<1%). NOTE: For proposed well construction in BIMS,
I averaged well construction info for saprolite/shallow wells and deeper/PWR wells. As -built construction will be entered
when GW-Is come in.
NOTE on add info requests- I made the received date for Add Info # 1 the date I received approval from Kennedy
Holt for Fe EDTA (February 21, 2017), a compound the Permittee requested approval for included in first add
info request package. For Add Info #2, I used Friday July 14 for the received date for the revised monitoring
plan.
HOW IT WORKS: The Klozur persulfate will act as an oxidation agent to reduce VOCs, and the Fe EDTA will be an
activator.
MONITORING: Monitoring wells installed for the assessment and correction plan for this site over the years will be used in
the monitoring plan (MP). Per the request of the RO, iron was added to the monitoring plan. Per my request, an additional
semiannual sampling event was added (refer to Add Info #2 email rec'd 7/14/2017). Refer to the revised monitoring plan
[Section 7] in the application. Monitoring wells/locations are highlighted in yellow on Figure 3 (Injection Map).
NOTE:
o Due to the steep terrain, there are limitations on the placement and number of monitoring wells for this site
outside the IZ on the north side of the plume (see Topo Map Figure 2 and email from Brian Bellis dated
January 30, 2017).

o The monitoring wells' -:.gated across Sugar Creek are not useful __ ._,Zonitoring because the creek acts as
barrier to shallow groundwater movement. However, there are 3 surface water sampling locations in the
monitoring plan to monitor injection activities (Figure 3 in Monitoring Plan Section 7).
EPIDEMIOLOGY: The DHHS has approved the injectant(s).
REGIONAL OFFICE COMMENTS: Each of the RO comments/recommendations are discussed below (RO's
comments/recommendations are underlined).
1. Surface water monitoring during injection event to monitor for potential daylighting. The Applicant revised the
injection/monitoring plan to include this request of observing for any possible daylighting via add info received
7/14/2017.
2. Add iron to the list of parameters. The Applicant revised the injection/monitoring plan.
3. Indicate location for containment of injectant chemicals. The Applicant provided this information "to Ed Watson
around the time he sent the Staff Report. The chemicals will be stored in a building or trailer (see email from Ed Watson).
The Mooresville Regional Office recommends permit issuance.

5I Calculations Worksheet
Applicant/Facility:
Permit No. WI
Date:
Reviewer: Al /L...
Depth to groundwater (GW): 'v % r BLS
GW flow direction: i N A
MWs installed in same aquifer as injection? __(Y or N); Inj zone: MW zone:
Groundwater Flow Rate
HC X gradient(FT?) = flow rate/DAY(?) X 365 = FT/YR
SY or porosity (-.30)
Reported:
Calculations for Potential Contaminate Plume Displacement
c7
3.15 TO X c) �X ao height =y 0 CF
0,3 3, O 0 0 CF X . o -O SY or porosity (i.e. -.30) _ , 6 0 0 0 v CF of available void
-T—
space
�o 00 J 0 v CF of available void sp X 7.48 gallons 98 Q o i gallons of water in void space
6 9 5 oo gallons of injectant = L. L__% of fluid displaced by injectant (move decimal
y
) Y L? dr 00 0 gallons of water in void space
Potential displacement of plume by injection:
Injection Volume and Pumping Rate Per Well Per Day
�.
total amt. of injectant / 0 number of wells / _number of days of injection event =
3 _amount of injectant per well per day (average gallons per day)
S:UIC/Applications and forms/ 51 Calculations worksheet V version 7/23/10

5I Calculations Worksheet
Notes
e—, I 1 2 PC6
S:UIC/Applications and forms/ 5I Calculations worksheet version 7/23/10

NORTH CAROLINA
ENVIRONMENTAL MANAGEMENT COMMISSION
DEPARTMENT OF ENVIRONMENTAL QUALITY
RALEIGH, NORTH CAROLINA
PERMIT FOR THE USE 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
Trex Properties, LLC
Mecklenburg County
FOR THE CONSTRUCTION OF 20 (twenty) IN SITU REMEDIATION INJECTION WELLS,
defined in Title 15A North Carolina Administrative Code 2C .0209(5)(b)(viii), to inject the
following additives (either individually or in combination): Klozure and Fe EDTA, for the
remediation of groundwater contaminated with volatile organic compounds (VOCs) products:
These injection wells/points will be located at the Trex Charlotte, NC Facility, 3114 & 3124
Cullman Avenue, Charlotte, NC, and will be operated in accordance with the application received
January 23, 2017, and in conformity with the specifications and supporting data submitted
February 21, and July 14, 2017, all of which are filed with the Department of Environmental
Quality 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 02C .0100- and
.0200, and any other Laws, Rules, and Regulations pertaining to well construction and use.
This permit shall be effective from date of issuance, until June 30, 2022.
Permit issued this the 21st day of July 2017.
S. Jay Zimmerman, Director
Division of Water Resources
By Authority of the Environmental Management Commission.
Permit No. WI0300345 PAGE 1 OF 7
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PART I — PERMIT GENERAL CONDITIONS
The Permittee shall 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).
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 [I 5A
NCAC 02C .0211(1)].
3. This permit is valid only for construction or operation 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 Division of Water Resources (DWR) [15A NCAC
.0211(a)].
4. This permit is not transferable without prior notice and approval. 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 and any supporting materials must be submitted at least 30 days prior to
the date of the change [15A NCAC 02C .0211(q)].
5. 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 [15A NCAC 02C .0203].
PART II - WELL CONSTRUCTION GENERAL CONDITIONS
Each injection well shall not hydraulically connect separate aquifers [15A NCAC 02C
.0211(c)].
2. Multi -screened wells shall not hydraulically connect different aquifers or zones having
differences in water quality that would result in a degradation of any aquifer or zone [15A
NCAC 02C .0225(g)(17)].
3. Each injection well shall be constructed in such a manner that water from land surface cannot
migrate into the gravel pack or well screen [15A NCAC 02C .0225(g)(4)].
4. 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. [15A NCAC .0225(g)(8)].
5. 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 shall be secured with a locking cap as defined in G.S. 87-85(16) [15A
NCAC 02C .0225(g)(23)].
Permit No.- W10300345 PAGE 2 OF 7
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6. Each injection well shall be afforded reasonable protection against damage during construction
and use [15A NCAC 02C .0225(i)(3)].
7. Each permanent injection well shall have a permanently affixed identification plate [15A
NCAC .0225(g)(20)].
8. A copy of the completed Well Construction Record (Form GW-1) shall be submitted as
described in Part VI.3 of this permit (the original document goes to the address indicated on
the form).
PART III - WELL CONSTRUCTION SPECIAL CONDITIONS
At least forty-eight (48) hours prior to constructing or operating each injection well, the
Permittee shall notify the Underground Injection Control (UIC) Central Office staff, telephone
number 919-807-6406, and the Mooresville Regional Office staff, telephone number 704-663-
1699 [15A NCAC 02C .0211(k)].
PART IV - OPERATION AND USE CONDITIONS
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 [15A NCAC 02C
.02110)].
2. The issuance of this permit shall not relieve the Permittee of the responsibility for damages
to surface water or groundwater resulting from the operation of this facility [15A NCAC 02C
.0206].
3. The injection facility shall be properly maintained and operated at all times to achieve
compliance with the conditions of this permit and the rules of 15A NCAC 02C .0200, even
if compliance requires a reduction or elimination of the permitted activity [15A NCAC 02C
.02110)].
4. In the event that the facility fails to perform satisfactorily, including the creation of nuisance
conditions or failure of the injection zone toyadequately assimilate the injected fluid, the
Permittee shall take immediate corrective actions that may be required, such as the repair,
modification, or abandonment of the injection facility [15A NCAC 02C .0206].
Permit No. WI0300345 PAGE 3 OF 7
ver. 2-25-2016 UIC-5I/5T

PART V -INSPECTIONS [15A NCAC 02C .0211(k)]
Any duly authorized officer, employee, or representative of the Division of Water Resources
(DWR) 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. DWR 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 VI - MONITORING AND REPORTING REQUIREMENTS
1. The proposed monitoring plan (revised per Additional Information received July 14, 2017)
shall be followed. Any additional monitoring, including groundwater, surface water, or soil
sampling, -deemed necessary to ensure surface water and groundwater protection may be
established and an acceptable sampling reporting schedule shall be followed [I 5A NCAC 02C
.02250)].
2. All sample results shall be submitted to the WQROS Central Office and Mooresville Regional
Office. Monitoring reports shall include, at a minimum, analytical data and an update on the
status and location of monitoring and injection wells. Well locations may be given in a table
with the name and geographic coordinates or shown on an updated version of the site map
[15A NCAC 02C .0225(k)(2)]:
3. Records of well construction, repair, or abandonment shall be submitted within 30 days of
completion of such activities [15A NCAC 02C .0225(k)(1)(A)].
4. An Injection Event Record shall be submitted within 30 days of each injection event [15A
NCAC 02C .0225(k)(1)(B)].
The Permittee shall submit a Final Project Evaluation (FPE) within 9 months after completing
all injection -related activity associated with this permit or produce an interim evaluation to be
submitted with a renewal application for this permit. Both the final project evaluation and
interim evaluation shall contain historical monitoring data and updated contaminant plume and
potentiometric surface maps. PLEASE NOTE: Injectants and related reaction byproducts must
attenuate to pre -injection concentrations or groundwater standards specified in rule 15A NCAC
02L .0202, whichever is greater, in order for this permit to be closed. Otherwise, corrective,
action as described in Part VII may be required [15A NCAC 02C .0225(k)(2)].
Permit No. W10300345 PAGE 4 OF 7
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6. All monitoring results, forms, and reports required in this Part shall be submitted to:
UIC Program Water Quality Regional Operations Section
NC Division of Water Resources and DWR Mooresville Regional Office
1636 Mail Service Center 610 East Center Ave.
Raleigh, NC 27699-1636 Mooresville, NC 28115
7. The Permittee shall report any monitoring or other information that indicates noncompliance
with a specific permit condition, that a contaminant may cause a violation of applicable
groundwater quality standards, or that a malfunction of the injection system may cause the
injected fluids to migrate outside the approved injection zone or area. As specified in rule
15A NCAC 02C .0211(r), noncompliance notification shall be as follows:
(A) Oral notification shall be given within 24 hours of the occurrence, or first knowledge
of the occurrence, to the Mooresville Regional Office, telephone number 704-663-
1699.
(B) Written notification shall be made within five days of the occurrence and submitted
to the addresses in Item #6 above.
(C) The written notification shall contain a description of the noncompliance and its
cause; the period of noncompliance, including dates and times; if the noncompliance
has not been corrected, the anticipated time it is expected to continue; and any steps
taken or planned to reduce, eliminate, and prevent reoccurrence "of the
noncompliance.
8. 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 [15A NCAC 02C .0211(b)].
PART VII - CORRECTIVE ACTION [15A NCAC 02C .0206]
1. Any injection well not constructed or operated in accordance with this permit, or the criteria
and standards specified in 15A NCAC 02C .0200, shall be subject to corrective action as
provided under rule 15A NCAC 02C .0206.
2. The following corrective actions shall apply to elevated concentrations of injectants or reaction
byproducts resulting from the permitted injection activity:
(A) Continued monitoring until concentrations return to pre -injection values or meet the
standards specified in 15A NCAC 02L .0202, whichever are greater. The frequency,
duration, and location of monitoring shall be appropriate for site specific conditions and
potential receptors.
(B) Groundwater quality parameters that do not attenuate as described in 2(A) above may
warrant a corrective action plan as provided under rule 15A NCAC 02C .0206, depending
on the type, concentration, and distribution of the groundwater quality standards being
exceeded.
Permit No. W10300345 PAGE 5 OF 7
ver. 2-25-2016 UIC-51/5T

PART VIII -PERMIT RENEWAL [15A NCAC 02C .0211(b)]
In order to continue uninterrupted legal use of the injection facility for the stated purpose, the
Permittee should submit an application to renew the permit 120 days prior to its expiration date.
PART IX - CHANGE OF WELL STATUS [15A NCAC 02C .0240]
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:
(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 WQROS staff 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 Pennittee 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.
Permit No. W10300345 PAGE 6 OF.7
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l
3. The written documentation required in Part IX (1) and (2)(G) shall be submitted to:
UIC Program
DEQ-Division of Water Resources
1636 Mail Service Center
Raleigh, NC 27699-1636
PART X — WORKER PRECAUTIONS DURING APPLICATION [15A NCAC 02C
.0225(a)]
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.
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. W10300345 PAGE 7 OF 7
ver. 2-25-2016 UIC-51/5 T