WI0400131_Permit (Issuance)_20100810

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
Petitioner for DSCA Site #41-0024
FOR THE CONSTRUCTION AND/OR OPERATION OF 20 TYPE 5I INJECTION WELLS.
defined in Title 15A North Carolina Administrative Code 2C .0209(e)(3)(C), to inject EHC, for the
remediation of groundwater contaminated with chlorinated solvents. These injection wells/points
will be located at the Fortner A Cleaner World #162, 4506 High Point Road, Greensboro, Guilford
County, NC 27407, and will be operated in accordance with the application submitted April 13.
2010. and in conformity with the specifications and supporting data, 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 Actor 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 A 100 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 July 31, 24I2, and
shall be subject to the specified conditions and limitations set forth in Parts I through X hereof.
Permit issued this the 10`t' day of August 2010.
�)& �' udk
Coleen H. Sullins, Director
Division of Water Quality
By Authority of the Environmental Management Commission.
Permit No. WI040013I PAGE I OF 6
ver. Jan?014 APUC-6

PART I - WELL CONm'RUCTION 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 (I 5A 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 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 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 dun'n,; construction
and use.
8. Each injection well shall have permanently affixed an identification plate.
9. 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 Staff
DENR-Division of Water Quality
1636 Mail Service Center
Raleigh, NC 27699-1636
PART II - WELL CONSTRUCTION SPECIAL CONDITIONS
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 [phone] and the Winston-Salem Regional Office Aquifer Protection Section Staff,
telephone number [phone].
Permit No. WI0400131 PAGE 2 OF 6
ver. dan.2010 APfMC-6

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.
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 ofthe responsibility of complying with
any and all statutes. rules, regulations, or ordinances which may be imposed by other local. state,
and federal agencies which have jurisdiction. Furthermore, the issuance of this permit does not
imply that all regulatory requirements have been met.
PART IV - PERFORMANCE STANDARDS
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. 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.
2. 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.
3. 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 he 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 physical 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 [phone]. 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. W10400131 PAGE 3 OF 6
ver. Jan.241 o APfUIC-C

PART VI - INSPECT1uNS
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. The proposed monitoring plan included in the: application shall be followed except that during
the pre -injection sampling event, collect groundwater elevation data from all monitoring wells
and provide an updated groundwater potentiornetric map (the groundwater elevation data used
for the potentiometric map provided in the application was collected December 16 through
December 19, 2008). All sample results shall be submitted to the Aquifer Protection Section's
Winston-Salem 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 insure surface and ground water protection, will be established and an acceptable sampling
reporting schedule shall be followed.
2. The Permittee shall submit an Injection Event Record within 30 days of completing each
injection.
3. 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.
4. The monitoring results and the final project evaluation shall be submitted to:
and to:
Aquifer Protection Section-UIC Staff
DENR-Division of Water Quality
1636 Mail Service Center
Raleigh, NC 27699-1636
Aquifer Protection Section
DENR-DWQ Winston-Salem Regional Office
585 Waughtown Street
Winston-Salem, NC 27107
Permit No. WI0400131 PAGE 4 OF 6
ver. Jan.2010 APIi.JIC-6

5. The Permittee shall report by telephone. within 4$ hours of the occurrence or first knowledge of
the occurrence. to the Winston-Salem 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.
6. 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.
7. 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_
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
well is not to be used for any purpose that well must be permanently abandoned according to
15A NCAC 2C .0113, 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 .0113(b). 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 the Director determines that
failure to do so could lead to the contamination of an underground source of drinking
water.
Permit No. W IWO 131 PAGE 5 OF G
ver. ]an.2010 AP/UIC-6

(D) Drilled wells shall be completely filled with cement grout, orbentonite 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 .0213(h)(1) 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 Staff
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. 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. WI0400131 PAGE 6 OF 6
ver. Jan.2010 APIUIC-6

DIVISION OF WATER QUALITY
AQUIFER PROTECTION SECTION
August 6, 2010
MEMORANDUM ►r�`� G
TO: Debra Watts
11D, ¢' ]
FROM: Michael Roger
Cam- e.k.
THROUGH: Thomas Slusser
RE: Permit To Inject EHC {Permit #WI0400I 31) �� v)
Former A Cleaner World (FACW )
I recommend that Permit Number W10400131 be issued to the applicant to inject EHC to remediate groundwater contaminated
with chlorinated solvents.
SITE DESCRIPTION: The subject Site is an active drop-off/pick up facility for dry cleaning located 4506 High Point Road,
Greensboro, Guilford County, NC 27407 (Figures 1 and 2). The source of contamination is from former dry-cleaning
operations that occupied a building that was demolished 1991.
HYDROGEOI.OGIC DESCRIPTION: The Site is located in the Carolina Slate Belt of the Piedmont Physiographic province.
In the area of the Site, the overburden consists of interbedded sand, silt, and clay coarsening with depth to partially
weathered rock (saprolite) and granitic bedrock. Depth to groundwater (GW) is approximately 15 feet below land surface
(BLS). in the area of the injection, the GW generally flows generally east-southeast at approximately 18 ftlyear (Figures 3
and 4). There is a west-northwest GW flow component on the west side of the property.
EXTENT OF CONTAMINATION: The PCE contaminant plume is kidney bean shaped and extends off -site to the west
approximately 600 feet and to the southeast approximately 1200 feet (Figure 5). According to the Applicant, there are no water
supply wells within 114 mile of the Site.
PROPOSED MJECTION: The proposed injection consists of injecting a total of approximately 5653 gallons of EHC via 20
direct push injection wells into a permeable reactive barrier (PRB). Theoretically, contaminated GW in the source area will
migrate east-southeast through the PRB and be remediated (refer to Figure 3). Approximately 283 gallons of EHC will be
injected through each well from about 14 to 38 feet BLS (47 gallons per day per well). There is one event planned, which
will last 6 days. The estimated amount of fluid displacement from injection is approximately .8 %. Based upon the
displacement volume and the very slow GW flow rate (approximately 18 feet per year), the potential displacement of the
plume is, therefore, low.
HOW IT WORKS: EHC is a patented combination of controlled release carbon and zero valent (ZVI) iron particles used for
stimulating the insitu chemical reaction of organic compounds in GW. The injectant is a nutrient rich product that
stimulates bacterial growth in GW, which in turn reduces the redox potential in the subsurface. The bacteria ferment
carbon and releases fatty acids, which serve as electron donors for other bacteria. The ZVI stimulates dechlorination and
additionally reduces the redox potential. Between natural attenuation and injection of this compound, solvent
contamination in the GW is reduced.
MONITORING: The following wells are proposed to be monitored for injection effectiveness: MW-1. MW-2, MW-3, MW-10S,
MW-18S, and MW-18D. However, I am allowing the removal of MW-10S from the monitoring plan. because this well is
approximately 600 feet east-southeast of the injection area and is not useful for monitoring the injection effectiveness. Per my
request, groundwater elevation data is to be collected from all monitoring wells during the pre -injection activity and an updated
groundwater flow map to be provided as the GW elevation data submitted in the application was collected in 2008. Monitoring
frequency will be once prior to injection, and then I month, 3 months, 6 months, and one year after injection.

EPIDEMIOLOGY: Dr. Luanne Williams has reviewed and approved EHC as an injectant.
REGIONAL OFFICE COMMENTS: The only comment the regional office had was that High Point Rd. is very busy highway and
that there should be cautioned taken by the drilling crew during injection activities.
Sbuying and Sherri Knight of the Winston-Salem RD recommend issuance of this permit.