WI0300282_Permit (Issuance)_20150323

I)MSION OF WATER RESOURCES "
WQROS
March 23, 2015
MEMORANDUM
TO: Debra Watts
FROM: Michael Rogers
RE: Issuance of permit to inject EAS (Permit #WI0300282)
NCDOT Geotechnical Unit
I recommend that Permit Number WI0300282 be issued to the above to inject EAS to remediate groundwater (GW)
contaminated with petroleum products.
SITE DESCRIPTION: The site is at the location of a former Exxon Service Station, which has been demolished, and is
currently in a NCDOT right of way (R.O.W.). Due to past use, the GW is contaminated with petroleum products (Figures
1 and 2).
HYDROGEOLOGIC DESCRIPTION: The site is located within the Piedmont geologic province. In the area of the site, the
overburden consists primarily of layers of sand and clays lying above partially weathered rock bedrock. Looking at the
cross -sections, the injection for this project will be in shallow sandy clay horizon. GW flow is generally southeast. The
velocity is approximately 2 feet/year (Figure 10).
EXTENT OF CONTAMINATION: There is one small plume on -site, which is appx 150 feet long and 100 feet wide (Figure
4).
PROPOSED INJECTION: The proposed injection will consist of a total of 4 injection events via 21 proposed permanent
wells (Figure 5). Appx 1 will be in' Der a 1/well . There will be appx 6 months between events.
The injection will be vi fed at appx`1 psi at 0.7 gal/min (gravity feed). With a total volume of appx 4,620 gallons,
the potential displacement is appx o or ess. a mjec ion we s are o ed on Figure 5.
How IT wORKs: The Applicant is proposing to use a solution of EAS with no chase water. The injectant is a sulfate
metabolic supplement designed to enhance the kinetics and efficiency of microbial activity. It stimulates biodegrading by
providing a soluble, readily available electron acceptor solution.
MONITORING: Thirteen (13) monitoring wells and four (4) supply wells will be monitored. The wells to be monitored are
highlighted in yellow on Figure 2. There will be sampling pre -injection, then at one month, 3 months, and 6 months after
inj. I am going to request that field parameters be added to the monitoring plan along with an additional sampling event at
1 year after injection.
EPIDEMIOLOGY: The DHHS has approved this solution as an injectant.
REGIONAL OFFICE COMMENTS: Each of the RO comments/recommendations are discussed below (RO's
comments/recommendations are underlined).
Item # 1 - More specifics are needed about the monitoring plan (MP).
A. Revised pages referencing their MP have been received in an Add Info received 3/12/15. The wells to be
monitored are highlighted in yellow on Figure 2. The plan includes all 13 monitoring wells and 4 active water
supply wells (WSW-9 thm 12). Reference to WSW-3 (not part of the sampling plan) is shown in NE corner of
map on Figure 2, which is off the map.
B. PIW71 and PMW-1 thru 3 (wells installed for the EAS pilot study) are now shown on revised Figure 2. They are
not going to be used in the MP. We received the well construction records for these wells 3/12/15 and were
entered into BIMS by Eric Smith.

l
C. FYI- Table 1 and Figure 2 016w some WSWs that are abandoned.
Item #2- MRO would like to discuss setback from WSWs w/CO. The DWM originally recommended a 150 foot setback
in the CAP for this project.
A. The DWM stated via email dated 2/23/15 (attached) that 150 foot setback was a recommendation and they have
deferred to DWR's UIC program.
B. The injection area has been revised anyway, and is now appx 150 feet away from .WSW-11.
Item #3- Info on pilot test. In Section 3.E of the application, the pilot test results indicated that BTEX concentrations
decreased significantly over time after a one time gravity feed of 55 gallons of EAS into PIW-1. After review of the
effectiveness, the DWM UST Section approved a CAP using EAS.
After review of the additional information received March 12, 2015, Andrew Pitner and Michael Parker of the
Mooresville RO, recommends issuance of this permit.

5I Calculations Workskeet
Applicant/Facility:�/J
Permit No. WI � Y 06 � � �•
Date: 2 o r S'
Reviewer:
Depth to groundwater (GW): N/0 —/S� / BLS
N
GW flow direction: V
MWs installed in same aquifer as injection? Y 2 (Y or N); Inj zone: /U —`� MW zone: Ste —
Groundwater Flow Rate
N
HC X gradient(FT?) = flow rate/DAY(?) X 365 = FT/YR
SY 30
or porosity
Reported:
Calculations for Potential Contaminate Plume Displacement
3.142 (7c) X S�r2 X height CF
f LI / 3g CF X , 30 SY or porosity (i.e. —.30) = tip y CF of available void
space
CF of available void sp X 7.48 gallons = gallons of water in void space
! ` �� 3i, �3� = 6GG,333 g
(�0 gallons of injectant = 4_% of fluid displaced by injectant (move decimal)
6'6 lot 333
33 gallons of water in void space
Potential displacement of plume by injection:
Injection Volume and Pumping Rate Per Well Per Day
lS S/ 0" t!al asnt. of injectant
—�
/ number of wells / _number of days of injection event =
J
ainount of injectant per well per day (average gallons per day)
S:UIC/Applications and forms/ 51 Calculations worksheet �� �� _ Z/ (�� � _ v_ersj n 7 3/10

5I Calculations Worksheet
Notes
S:UIC/Applications and forms/ 5I Calculations worksheet ' version 7/23/40

NORTH CAROLINA
ENVIRONMENTAL MANAGEMENT COMMISSION
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
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
North Carolina Department of Transportation — Geotechnical Unit
FOR THE CONSTRUCTION OF TWENTYONE (21) IN SITU REMEDIATION INJECTION
WELLS, defined in Title 15A North Carolina Administrative Code 02C .0209(5)(b)(viii), to
inject EAS, for the enhanced bioremediation of petroleum contaminated groundwater. These
injection wells/points will be located at the Former Preslar's Exxon facility, 901. NC Hwy 24/27
(R.O.W.), Midland, Cabarrus County, NC 28107, and will be operated in accordance with the
application submitted February 2, 2015, and in conformity with the specifications and supporting
data submitted March 12, 2015, 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 02C
.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 February 29,
2020, and shall be subject to the specified conditions and limitations set forth in this permit.
Permit issued this the 30th day of March 2015.
S. Jay Zimmerman, Director
Division of Water Resources
By Authority of the Environmental Management Commission.
Permit No. WI0300282 PAGE 1 OF 7
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PART I — PERMIT GENERAL CONDITIONS
1. 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
[15A 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 (D)V-R) [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
1. 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)].
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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 completed Well Construction Record (Form GW-1) shall be submitted as described in Part
VI.6 of this permit.
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
1. 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 to adequately 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. WI0300282 PAGE 3 OF 7
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PART V - INSPECTIONS [15A NCAC 02C .0211(k)]
1. 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 included in the application shall be followed except that field
parameters shall be added to the monitoring plan along with at least one additional
monitoring event at 12 months after injection. 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 [15A 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)].
5. 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 02C 0202 whichever is greater, in order for this permit to be
closed. Otherwise, corrective action as described Part VII shall be required [15A NCAC 02C
.0225(k)(2)].
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6. All monitoring results, forms, and reports required in this Part shall be submitted to:
UIC Program
NC Division of Water Resources and
1636 Mail Service Center
Raleigh, NC 27699-1636
Water Quality Regional Operations Section
D.WR Mooresville Regional Office
610 East Center Ave.
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.
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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 contaminatio f th
groundwaters.
n o e
(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 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.
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3. The written documentation required in Part IX (1) and (2) (G) shall be submitted to:
UIC Program
DENR-Division of Water Resources
1636 Mail Service Center
Raleigh, NC 27699-1636
PART X —WORKER PRECAUTIONS DURING APPLICATION [15A NCAC 02C
.021 T(b)]
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.
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