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HomeMy WebLinkAboutWI0400098_Application_20201214wood, December 4, 2020 Mr. Michael Rogers, P.G. Hydrogeologist NCDENR — DWR UIC Program 1636 Mail Service Center Raleigh, NC 27699-1636 Subject: Renewal of Existing Injection Permit #WI0400098 Without Modification Former Flakt Products Site 2000 Lowery Street Winston-Salem, North Carolina Wood Project Number 3031052007 Dear Mr. Rogers: On behalf of ABB, Inc. (formerly Flakt Products, Inc.), Wood Environment & Infrastructure Solutions, Inc. (Wood) is submitting two copies of the enclosed Application for Permit to Construct and/or use a Well(s) for Injection for the former Flakt Products site in Winston-Salem, North Carolina (Site). As discussed with Ms. Shristi Shrestha on October 14, 2020 and summarized in emails to her and you on October 15 and November 9, since the previous permit renewal no injections have occurred because ABB was monitoring groundwater plume stability as part of pursuing a risk -based closure for the site. In March 2020, the NCDEQ IHSB indicated to ABB their concurrence that the remaining groundwater plume was stable, and that ABB could pursue a risk -based closure. More recently, however, the site property owner (City of Winston- Salem) indicated they are not amenable to land use restrictions required as part of a risk -based closure. Therefore, ABB plans to continue annual groundwater monitoring and reporting. Details of previous injection events are documented in Injection Event Records on file with the NCDEQ, while the most recent reported site groundwater conditions are documented in Wood's February 5, 2020 Annual Progress Report on file with NCDEQ (NONCD 000 0017). While ABB has no plans to perform another injection near -term, because a risk -based closure does not appear to be an option at this time they desire to renew the injection permit should the need for another injection arise. Ms. Shrestha indicated that ABB should submit a Renewal of Injection Permit Without Modification, and if ABB decides another injection is warranted, they will then submit an Injection Permit Modification. In keeping with the permit requirements Wood will submit Injection Event Records following any additional injection event and will submit a final project evaluation within nine months of completion of all injection related activities. Wood Environment & Infrastructure Solutions, Inc. 2030 Falling Waters Road, STE 300 Knoxville, TN 37922 Tel (865) 671-6774 Fax (865) 671-6254 www.woodplc.com Should you have any questions or comments concerning this document, please contact Joe Deatherage at (865) 671-6774 or joe.deatherage(@woodplc.com. Sincerely, Wood Environment & Infrastructure Solutions, Inc. )?__� 0_41 K. Ricky A. Ryan, P.E. K. Joe Deatherage Senior Principal Registered Site Manager/Project Manager Enclosure c: Vance Litz, ABB (with electronic enclosure) Eugene Shephard, Wood (with electronic enclosure) Ryan Newcomb, City of Winston-Salem (with electronic enclosure) Robert Prestwood, City of Winston-Salem (with electronic enclosure) Nicholas Geis, City of Winston-Salem (with electronic enclosure) Gwen Roye, City of Winston-Salem (with electronic enclosure) Alan Griffith, Griffith Enterprises (with electronic enclosure) Tod Dalehite, Pratt Industries (with electronic enclosure) North Carolina Department of Environmental Quality — Division of Water Resources APPLICATION FOR PERMIT TO CONSTRUCT AND/OR USE A WELL(S) FOR INJECTION Groundwater Remediation (15A NCAC 02C .02251 Do not use this form for UIC wells Permitted by Rule (ref. 15A NCAC 02C .0217) Permit Number (to be completed by DWR for new projects): WI0400098 I. APPLICATION INFORMATION 1. Project is: [ ] New [ ] Modification [X ] Renewal without modification [ ] Renewal with modification 2. If this application is being submitted for Renewal and/or Modification to an existing permit, provide: Existing permit number WI0400098 Issued Date: January 11, 2016 & Expiration Date: March 31, 2021 For all Renewals, attach an updated site map and status report including monitoring results of all injection activities to date. For Renewal without modification only, fill out sections I & II only, sign the certification on the last page of this form, and obtain the property owner's signature to indicate consent (if the applicant is not the owner). II. WELL OWNER(S)/PERMIT APPLICANT (generally the responsible party) 1. Name(s): ABB, Inc. 2. Signing Official's Name*: R. Keith Knauerhase Title: Chief Counsel * Signing Official must be in accordance with instructions in Part XII. 3. Mailing address of Permittee/Applicant: 45 Griffin Road South City: Bloomfield State: CT Zip: 06002 4. Telephone number: 860-301-3505 Email: keith.r.knauerhase(iDus.abb.com 5. Status (choose one): Individual X Business/Org. Federal State County Municipality III. PROPERTY OWNER(S) (if different than well owners) 1. Name(s): 2. Mailing address: City: 3. Telephone number: Email: State: Zip: IV. PROJECT CONTACT — (generally the environmental/engineering consultant). 1. Name: Title: 2. Company: 3. Address: 4. City: State: Zip: 5. Telephone number: Email: Groundwater Remediation Application Rev. 2-17-2020 Page] of 8 V. FACILITY INFORMATION 1. Facility name: Phone No. (if available): 2. Physical address: City: County: Zip: 3. Geographic Coordinates: Latitude: Reference Datum: Longitude: Accuracy: Method of Collection (i.e., Google Earth, GPS, etc.): 4. Brief description of business: VI. INCIDENT DESCRIPTION 1. Source and date of contamination: 2. List all contaminants present in soils or groundwater at the site (contaminants may be listed in groups, e.g., gasoline, diesel, jet fuel, fuel oil, chlorinated ethenes, chlorinated ethanes, metals, pesticides/herbicides, etc): 3. Has LNAPL or DNAPL ever been observed at the site (even if outside the injection zone)? [ ] Yes If yes, list maximum measured separate phase thickness: feet [ ] No If no, list maximum concentration of total VOCs observed at site: ppb 4. Agency managing the contamination incident: [ ] UST Section [ ] Superfund Section (including REC Program and DSCA sites) [ ] DWR Aquifer Protection Section [ ] Solid Waste Section [ ] Hazardous Waste Section [ ] Other: 5. Incident manager's name: Phone No.: 6. Incident number or other incident mgmt. agency tracking number: VII. PERMITS List all applicable permits or construction approvals issued for the facility or incident: 1. Previous or other UIC permits issued by DWR (e.g., NOIs) 2. Other Non -Discharge or NPDES permit issued by DWR: 3. County or DEH subsurface wastewater disposal permits: 4. Hazardous waste management or other environmental permits required by state or federal law: Groundwater Remediation Application Rev. 2-17-2020 Page 2 of 8 VIII. INJECTION SUMMARY 1. List all proposed injectants/additives. NOTE: Only injectants approved by the epidemiology section of the NC Division of Public Health, Department of Health and Human Services can be injected. Approved injectants can be found online at hgp:Hdeq.nc. gov/about/divisions/water-resources/water-resources-permits/wastewater-branch/ground-water- protection/ground-water-approved-injectants. All other substances must be reviewed by the DHHS prior to use. Contact the UIC Program for more info if you wish to get approval for a different additive. However, please note it may take 3 months or longer. If no iniectants are to be used use N/A. Inj Total Amt. to be injected (gal Injectant: Total Amt. to be injected (gal)/event: Injectant: Total Amt. to be injected (gal)/event: Injectant: Total Amt. to be injected (gal)/event: Injectant: Total Amt. to be injected (gal)/event: Total Amt. to be injected (gal/event): No. of separate injection events: Total Amt. to be injected (gal): Source of Water (if applicable): 2. Estimated Injection rate per well: GPM 3. Estimated Injection pressure: pounds/square inch (PSI) 4. Temperature at point of inj 5. Injection will be via: OF Existing well(s)- Total No.: , Well Type (DPT, Permanent, etc.) Proposed well(s)- Total No.: , Well Type (DPT, Permanent, etc.): 6. NC Certified Well Drilling Contractor's Name (if known): NC Well Contractor Certification No.: 7. Date to be constructed if proposed: (attach well construction records [GW-1 sl for existing injection wells) 8. Screened interval/Injection interval of injection wells: Depth from to feet below land surface (BLS)(if multiple intervals, indicate shallowest to deepest depth) 9. Well casing (leave blank if Geoprobes®): Type (PVC, stainless steel, other): Casing depth: to ft. BLS Type (PVC, stainless steel, other): Casing depth: to ft. BLS Groundwater Remediation Application Rev. 2-17-2020 Page 3 of 8 10. Grout (leave blank if Geoprobes): Type (cement, bentonite, other): Grout depth: to ft. BLS Type (cement, bentonite, other): Grout depth: to ft. BLS IX. ATTACHMENTS — provide the following information in separate attachments. The attachments should be clearly identified and presented in the order below to expedite review of the permit application package. 1. INJECTION ZONE — Per 15A NCAC 02C .0225(fl(3), specify the horizontal and vertical portion of the subsurface within which the proposed injection activity will take place and beyond which no violations of groundwater quality standards shall result from the injection as determined by an approved monitoring plan. The determination shall be based on the hydraulic properties of the specified zone. Provide any supporting documentation in a separate attachment. 2. HYDROGEOLOGIC EVALUATION — Per 15A NCAC 02C .0225(D(4), provide a hydrogeologic evaluation of the injection zone that includes all of the following: (A) Regional and local geology and hydrology; (B) Changes in lithology underlying the facility; (C) Depth to bedrock; (D) Depth to the mean seasonal high water table; (E) Hydraulic conductivity, transmissivity, and storativity, of the injection zone based on tests of site -specific material, including a description of the test(s) used to determine these parameters; (F) Rate and direction of groundwater flow as determined by predictive calculations or computer modeling; (G) Lithostratigraphic and hydrostratigraphic logs of any existing test and injection wells; and (H) For systems re -injecting treated on -site contaminated groundwater only- evaluation of infiltration galleries or injection wells. 3. INJECTANT INFORMATION — Per 15A NCAC 02C .0225(f)(6), provide information on each injectant as indicated below: (A) MSDS, concentration at the point of injection, and percentage if present in a mixture with other injectants; (B) The source of fluids used to dilute, carry, or otherwise distribute the injectant throughout the injection zone. If any well within the area of review of the injection facility is to be used as the fluid source, then the following information shall be submitted: location/ID number, depth of source, formation, rock/sediment type, and a chemical analysis of the water from the source well, including analyses for all contaminants suspected or historically recognized in soil or groundwater on the site; (C) A description of the rationale for selecting the injectants and concentrations proposed for injection, including an explanation or calculations of how the proposed injectant volumes and concentrations were determined; (D) A description of the reactions between the injectants and the contaminants present including specific breakdown products or intermediate compounds that may be formed by the injection; (E) A summary of results if modeling or testing was performed to investigate the injectant's potential or susceptibility for biological, chemical, or physical change in the subsurface; and (F) An evaluation concerning the development of byproducts of the injection process, including increases in the concentrations of naturally occurring substances. Such an evaluation shall include the identification of the specific byproducts of the injection process, projected concentrations of byproducts, and areas of migration as determined through modeling or other predictive calculations. 4. INJECTION PROCEDURE — Per 15A NCAC 02C .0225(fl(7), submit a table with a detailed description of the proposed injection procedure that includes the following: (A) The proposed average and maximum daily rate and quantity of injectant; (B) The average maximum injection pressure expressed in units of pounds per square inch (psi); and (C) The total or estimated total volume to be injected. Groundwater Remediation Application Rev. 2-17-2020 Page 4 of 8 5. FRACTURING PLAN (if applicable) — Per 15A NCAC 02C .0225(1)(9), submit a detailed description of the fracturing plan that includes the following: (A) Material Safety Data Sheets of fracturing media including information on any proppants used; (B) a map of fracturing well locations relative to the known extent of groundwater contamination plus all buildings, wells, septic systems, underground storage tanks, and underground utilities located within the Area of Review; (C) a demonstration that buildings, wells, septic systems, underground storage tanks, and underground utilities will not be adversely affected by the fracturing process; (D) injection rate and volume; (E) orientation of bedding planes, joints, and fracture sets of the fracture zone; (F) performance monitoring plan for determining the fracture well radius of influence; and (G) if conducted, the results of geophysical testing or pilot test of fracture behavior conducted in an uncontaminated area of the site. 6. WELL CONSTRUCTION DETAILS — Per 15A NCAC 02C .0225(f)(10), submit the following information in tabular or schematic form as appropriate for each item: (A) number and depth of injection wells; (B) number and depth of borings if using multi -level or "nested" well systems; (C) indication whether the injection wells are existing or proposed; (D) depth and type of casing; (E) depth and type of screen material; (F) depth and type of grout; (G) indication whether the injection wells are permanent or temporary "direct push" points; and (H) plans and specifications of the surface and subsurface construction details. 7. MONITORING PLAN — Per 15A NCAC 02C .0225(f)(11), submit a monitoring plan that includes the following: (A) target contaminants plus secondary or intermediate contaminants that may result from the injection; (B) other parameters that may serve to indicate the progress of the intended reactions; (C) a list of existing and proposed monitoring wells to be used; and (D) a sampling schedule to monitor the proposed injection. Monitoring wells shall be of sufficient quantity and location to detect any movement of injection fluids, injection process byproducts, or formation fluids outside the injection zone. The monitoring schedule shall be consistent with the proposed injection schedule, pace of the anticipated reactions, and rate of transport of the injectants and contaminants. 8. WELL DATA TABULATION — Per 15A NCAC 02C .0225(t)(12), provide a tabulation of data on all existing or abandoned wells within the area of review of the injection well(s) that penetrate the proposed injection zone, including monitoring wells and wells proposed for use as injection wells. Such data shall include a description of each well's type, depth, and record of construction or abandonment. 9. MAPS AND CROSS -SECTIONS — Per 15A NCAC 02C .0225(ff(13). provide scaled, site -specific site plans or maps depicting the location, orientation, and relationship of facility components including the following: (A) area map based on the most recent USGS 7.5' topographic map of the area, at a scale of 1:24,000 and showing the location of the proposed injection site; (B) topographic contour intervals showing all facility related structures, property boundaries, streams, springs, lakes, ponds, and other surface drainage features; (C) all existing or abandoned wells within the area of review of the wells listed in the well data tabulation that penetrate the proposed injection zone; (D) potentiometric surface map(s) that show the direction of groundwater movement, existing and proposed wells; (E) contaminant plume map(s) with isoconcentration lines that show the horizontal extent of the contaminant plume in soil and groundwater, and existing and proposed wells; (F) cross-section(s) to the known or projected depth of contamination that show the horizontal and vertical extent of the contaminant plume in soil and groundwater, major changes in lithology, and existing and proposed wells; and (G) any existing sources of potential or known groundwater contamination, including waste storage, treatment, or disposal systems within the area of review of the injection well or well system. Groundwater Remediation Application Rev. 2-17-2020 Page 5 of 8 X. UIC SYSTEMS RE -INJECTING TREATED ON -SITE CONTAMINATED GROUNDWATER ONLY 1. FEES — Per 15A NCAC 02C .0225(m), submit/attach fees for new permits or modifications (refer to fee schedule at https://deq.nc.gov/about/divisions/water-resources/water-resources-permits/wastewater-branch/ground-water- protection/non-discharge-groundwater-remediation 2. SOILS EVALUATION - Per 15A NCAC 02C .0225(f)(2), for systems with proposed discharge within seven feet of land surface and above the seasonal high water table, a soil evaluation of the disposal site shall be provided to the Division by the applicant. If required by G.S. 89F, a soil scientist shall submit this evaluation. This evaluation shall be presented in a report that includes the following information: (A) Field description of soil profile. Based on examinations of excavation pits or auger borings, the following parameters shall be described by individual horizons to a depth of seven feet below land surface or to bedrock: thickness of the horizon; texture; color and other diagnostic features; structure; internal drainage; depth, thickness, and type of restrictive horizons; pH; cation exchange capacity; and presence or absence of evidence of any seasonal high water table. Applicants shall dig pits when necessary for evaluation of the soils at the site. (B) Recommendations concerning annual and instantaneous loading rates of liquids, solids, other wastewater constituents and amendments. Annual hydraulic loading rates shall be based on in -situ measurement of saturated hydraulic conductivity in the most restrictive horizon. 3. ENGINEERING PLANNING DOCUMENTS — Per 15A NCAC 02C .0225(f)(8), the following documents shall be provided to the Division by the applicant (Note: if required by G.S. 89C, a professional engineer shall prepare these documents): (A) engineering plans for the entire system, including treatment, storage, application, and disposal facilities and equipment, except those previously permitted unless they are directly tied into the new units or are critical to the understanding of the complete process; (B) specifications describing materials to be used, methods of construction, and means for ensuring quality and integrity of the entire groundwater remediation system; (C) plans that include construction details of recovery, injection, and monitoring wells and infiltration galleries; (D) operating plans that include: (i) the operating schedule including any periodic shut -down times; (ii) required maintenance activities for all structural and mechanical elements; (iii) a list of all consumable and waste materials with their intended source and disposal locations; (iv) restrictions on access to the site and equipment; (v) provisions to ensure the quality of the treated effluent and hydraulic control of the system at all times when any portion of the system ceases to function, such as standby power capability, complete system -off status, or duplicity of system components; and (E) Completed, signed, and sealed Professional Engineer's Certification for new permit applications (form attached). Groundwater Remediation Application Rev. 2-17-2020 Page 6 of 8 Xi . CER'I`MCATION (to he signed as required below or by that person's authorized agim[*) N(:Ai~' 15A 02C .021 1(e) recru Tres ttm all perm it applications s1 ] i bee sli-med a_s Fol lows: I- fod s corpexatioir by a responsible corporale offikxr 2_ for a partrLenhip or sole Proprietorship: by a geiwruE paaTtner ur then pTc-g3netnr, rccpe=tively 3 _ fixr a m unicipal itw or a swle, feral, uT other public. ,car= by either a princ IN i executive officer or ranking publicly e1e%;L-rd of5clal 4. fhr all ethers: -hy the weli c5%&Twr. t if ao aulho r1r a �RLst is wing o�n b*h:Alf of the a pplicastl, then su pply a leiie: r signm try the stpplicant ihsi names ind au chorizes their agent. "I hereby c°en if), mukr jencdly of lerw rho I hmw rwma14' exanyined emd ap?a fo=fi6r with I&' Pftfi r-rmd6wr ruhmrtred rn lho d c mrenf and all aflachmentr rherery, mid f ear on Mr Jngwrn: of these irxfl ndrraIN Jmmedirtte4- resprmiNe jv obiaming said w+ ;o?P, f belkve rhea i& inhrnaurrrm ix Crane_ aacLvate, and comp4eit}. f -am aware AV rkw Gm pewleyes, mdurfmg rfv sibdlay offws and rrrrprrsrurneeat, A r .serhuriirmg fake i01formazon, f agree ro corr.€wwl. opawe, nwInladh. rehear, and i f rqf unable, abamdan the h7fe fion wells) Und all Pekded a'pparrrerartmCcs i" WCOVe PWO Wirh I& rdppr,ved speerfir-caia rs mxf co dilenny of the Permit, ' . Typmd Or PHOt-M NarrkC 13ignature; XM. iC:0NSF,NT OF 'PROPF.lRTY OWNPR ff the Rmperty is not awned 4 she peJnn a applicant) ` Own�ef- means any person who hold s the fcc or other property rioLts in dre wel I being construmcd_ A wr, I I i 5 rra I properry and its construedoa on lwkd shall be dleertked to vest ownumhip in the land o h-ncr, in the absence ofrontrary agnemmrnt in wraing. "ifs rawrrer OfOw proper3�-on u'hwh the miachm weftW are 10 &1 conhirtm fortaml ryperaled, I herrhymmrs-erri fo Zdkrw the aMWan 110 aomd r each injrcr %'efd as owl awd In Ands appik w dem and a�,,ree rhiv it hall he the .respow iNfiiy of the aMAmw to emswre rhm Ark' b7j6LIJun well4) crmforrrr rrx fhe Well 'I'yped or Printed Na ne WW 'Uitk, I )aTnQiL Nuemke, Assistant C it%- 1�1ana-,er gip: 1]a: 12/1/2020 Submit TWO hard Copies of the com plettd applleai iun package with an elecmriic version is C:D or USB Flash Drive to, DIVIS110,1 OF WATER RESUURUES — UIC PROGRAM 1636 MAIL SERVICE CENTER RALEIGIdL NORTH C'AROLINA 27699-1636 TELEPHONE NU'hMR: (919) 707- ID CrrrwMLmarerRemedia#imk App11Wiw Rev. 2-17--n213 Page 7 of 9 Professional Engineer's Certification (for new permit application for UIC systems re -injecting treated on -site contaminated groundwater only): Permit No.: WI Typed or Printed Name of Professional Engineer: License Number: Name of Engineering Firm (if applicable): Mailing Address: City State: Zip: Office Number: O Mobile Number: O Email Address: I, , attest that this application for has been reviewed by me and is accurate and complete to the best of my knowledge. I further attest that to the best of my knowledge the proposed design has been prepared in accordance with the applicable regulations. Although certain portions of this submittal package may have been developed by other professionals, inclusion of these materials under my signature and seal signifies that I have reviewed this material and have judged it to be consistent with the proposed design. North Carolina Professional Engineer's Seal, Signature, and Date: Groundwater Remediation Application Rev. 2-17-2020 Page 8 of 8