WI0300038_Regional Office Historical File Pre 2018

_ North Carolina Department of Environment, Health, and Natural Resources
tjj f Division of Environmental Management - Groundwater Section
4
r l-T'7C_ •t l l�E� l 4,1
PRECONSTRUCTIOI INJECTION FACILITY INSPECTION REPORT - FORM .A
INJECTION WELL PERMIT NO. WIll DATE
NAME OF OWNER c + J c Pe tf -ni J t' ur'1-1 CO-7 ' .
ADDRESS OF OWNER 170
KiLt h .
15
L-1c)- 1 lierewt-i 1 (74 303bg
(Street/ road or lot and suddivision, county, town)
LOCATION OF PROPOSED INJECTION WELL (and source well(s), if applicable)
Sri 1'Ne i.s C i ) C� =s CLLCc( (sS. Se" E S•P)lr,<<x %z:. •-�
JY1 (5._1-1-6 _r 1.1 P
u
(Street/ road or lot and suddivision , county, town, if different than owner's address, plus description of location on site)
Potential pollution
Potential pollution
Potential pollution
Minimum distance of
Quality of drainage
source
source
source
Phi ru Iff-urn e iPe ,>•,`- Distance
1,) lk S`LizLttDistance
'DtSsiLccC 1`5E- X ,t-\C-r`1Distance
from well
from well
from well
proposed well from property boundary
at site C•1 c-1 Flooding potential of site
(good, adequate, poor)
v
0
(high, moderate, low;
DRAW SKETCH OF SITE (Show property boundaries, buildings, wells, potential pollution sour6es, roads, approximate
scale, and north arrow.)
5ce
Cs- 1-40 -c -

PRECONSTRUCTION INJECTION
FACILITY INSPECTION REPORT - F(5`RM
COMMENTS
C-11-, u -±-s %c.
INSPECTOR
WITNESS
Address
ur'rot' + • LIT lA\Ci—t'1-"'� L�,c- (I (
_ix) J.'�-7p - it - LA 7 1 f 1.L-r cS-YZ;r c.Ll- �1�-r1R.c
1 1r1 `�''+l c & y v%r, s .I ^ l>: ,-- -i -, -. 1 J-17,( ' 0. ;1� f i
L C.- 1 11 ] 7 LC. 4 tfa 1 G--[. .. -l�l l E�7 4 _7
L1
pc %- : !„ y rr. Inv i IL -�--� ra
.: , i't'��1 � Ur � r ri (�':�'�`iiL.7 �''i.( ^L' :F-Tc�• (. i.t
J
1(i?Office
1� )3 t .,.,_I
11 J
:e .c..
•WITNESS
Address
7L
ell
1.
a.
•
JULY, 1994

}
MEMORANDUM
To:
From:
GROUNDWATER SECTION
May 6, 1998
Barbara Christian
Groundwater Section
Morresville Regional Office
Amy Axon?
UIC Program Manager
Groundwater Section
Central Office
Re: Request for inspection and review of new injection well permit application for use of
Ozone at Citgo site, Charlotte, NC.
An application submitted by S&ME, Inc. on behalf of Citgo Petroleum Corporation, Charlotte,
for a new permit for construction and operation of an injection facility has been received by CO -
UIC. A copy of this application has been submitted to your office by the permittee.
1. Please review the application and submit any comments to CO-UIC. Retain the
application for your files.
2. Please inspect the proposed injection well site to verify that the location and
construction plans submitted in the application are accurate and that the NCAC
T15A:02C.0200 standards are being complied with, using the enclosed Preconstruction
Injection Facility Inspection Report (form A).
Return any application review comments and the completed Preconstruction Injection Facility
Inspection Report (form A) to the RCO-UIC by May 22, 1998. If the inspection cannot be
accomplished by this date, please inform CO-UIC.
After the permit has been issued and when operation is about to commence, the CO-UIC will
notify the MRO, which may, at your discretion, inspect the facility in operation.
cc: UIC Files
C:1WPDOCSWERMIT ASKRWCNA. WPD

NCDENR r •
JAMES B. FiUNTJR;'
t' GOVERNOR 41,
F ,
• WAYNE MCDEVITT,T
SECRETARY "�,k�'�]5��;;
Toff
%7 4ey I
'• A. PRESTON HOWARD,
DIRECTOR : -
. I
•� i
fi
c 1,
1
August 3, 1998
Mr. Scott Eaton
Citgo Petroleum Corporation
P.O. Box 47427
Doraville, GA 30362
Dear Mr. Eaton:
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
N.C. DE YT. Cif
EN.vI:to'k`-u;: T.
8P NATURAL ITfr.:7'.'OU1tUIs'S
AUG 5 1998
BIV151D`111Bf(E?�H14�11r1111i4iEVII. 4Mal mg
a fU3I
Your permit application to injection ozone into the subsurface, received on April 24, 1998, has
been reviewed and determined to be incomplete. As specified in Title I5A NCAC Section
2C.0211, the following information must be submitted in order to complete the review process:
1. A hydrogeologic description, soils description, and cross section of the subsurface to a
depth that includes the known or projected depth of contamination. The number of
borings shall be sufficient to determine the following:
a) The regional geologic setting;
b) significant changes in lithology;
c) the hydraulic conductivity of the saturated zone;
d) the depth to the mean seasonal high water table; and
e) a determination of transmissivity and specific yield.
2. The Groundwater Section concurs with the concerns pointed out in Dr. Williams' July
9, 1998 memo, which is enclosed. Submit a report detailing the actions you plan to take
in order to satisfy the comments and requests in the memo, particularly the statements
that are listed on page 2, section 4.
3. Information/reports that show the effectiveness of ozone treatment of petroleum
contaminated groundwater.
If the requested information is not submitted within 45 days of receipt of this letter, the permit
application will be returned to you as incomplete. If you wish to reapply for a permit, the new
application must include the required information. If you have any questions regarding the
permit or injection well rules, please contact me at [phone].
Enclosures
cc: UIC Files
MRO
David Klemm, S&ME, Inc
Sincerely,
Amy on, Manager
Underground Injection Control Program
C:IivlyFiles\SITELIiTTlcitgoozone.doc
GROUNDWATER SECTION
P.O 130X 29578, RALEIGH, NC 27626-0578 - 2728 CAPITAL BLVD., RALEIGH, NC, 27604
PHoNE [phone] FAX [phone]
AN EQUAL OPPORTUNITY / AFFIRMATIVE ACTION EMPLOYER - 50% RECYCLEO/1 0 % POST -CONSUMER PAPER
•

410
MEMORANDUM
To: Barbara Christian
Groundwater Section
Mooresville Regional Office
From:
Amy Axon
UIC Group
Central Office
tndwater Section
Date: October 20, 1998
Subject: Issuance of injection well permit for Citgo Petroleum Corporation.,
Charlotte, Mechlenberg County, North Carolina.
Permit No. WI0300046 to use wells for a injection of ozone to enhance degradation of
petroleum hydrocarbons at Citgo Petroleum Corporation has been issued. A copy of the
permit is enclosed for your files. If you have any questions, please contact me at (919) 715-
6165.
cc: UIC Files
Enclosures

? {_,if -
.
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
October 20, 1998
Mr. Scott Eaton
Citgo Petroleum Corporation
P.O.Box 47427
Doraville, GA 30362
Dear Mr. Eaton:
In accordance with the application submitted on your behalf by S&ME, dated April 24,
1998 and supplemental information submitted June 15th and September 1, 1998 we are
forwarding Permit No. WI0300046. This permit is for the injection of Ozone into
injection well SP-3, for the purpose of oxidizing petroleum contamination. Please note
this permit is only for the well mentioned above. If you want to inject ozone into any
other wells, as mentioned as a possibility in the permit application, you must apply for
and receive another injection well permit prior to injection.
This permit shall be effective from the date of issuance until October 31, 2003, and shall
be subject to the conditions and limitations stated therein, including the requirement to
notify this office by telephone 48 hours prior to initiation of operation of the facility.
In order to continue uninterrupted legal use of this well for the stated purpose, you should
submit an application to renew the permit three months prior to its expiration date.
If you have any questions regarding your permit please feel free to contact me at (919)
715-6165.
Sincerely,
Amy Axon, Manager
Underground Injection Control Program
cc: UIC Files
MRO Files
David Klemm, S&ME, Inc.
Enclosures
GROUNDWATER SECTION
P.O 80X 29578, RALEIGH, NC 27626-0578 - 2728 CAPITAL BLvo., RALEIGH, NC, 27604
PHONE [phone]zz 1 FAX [phone]
AN EQUAL OPPORTUNITY / AFFIRMATIVE ACTION EMPLOYER - 50% RECYCLED/10% POST -CONSUMER PAPER

NORTH CAROLINA
ENVIRONMENTAL MANAGEMENT COMMISSION
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
RALEIGH, NORTH CAROLINA
PERMIT FOR THE 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
Citgo Petroleum Corporation
FOR THE OPERATION OF AN INJECTION WELL SYSTEM for the purpose of injecting Ozone
through one injection well (SP-3). This injection system is Iocated at Paw Creek, North Carolina,
in Mecklenburg County, and will be operated in accordance with the application dated April 24, 1998,
and in conformity with the specifications and supporting data submitted, all of which is filed with the
Department of Environment and Natural Resources and is considered a part of this permit.
This permit is for 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 system shall be
in compliance with Title 15 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, 2003,
and shall be subject to the conditions and limitations specified in Parts I through VIII herein.
Permit issued this the / ��, S day of October 1998.
Ted L. Bush, Jr., Assistant Chief
Groundwater Section
Division of Water Quality
By Authority of the Environmental Management Commission.
WI0300046 Page 1 of 6

PART I - 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 is effective only with respect to the nature, volume of materials and rate of
injection, as described in the application and other supporting data.
3. 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.
4. The issuance of this permit shall not relieve the Permittee of the 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.
5. The issuing of this permit does not constitute approval for reimbursement from LEAKING
PETROLEUM UNDERGROUND STORAGE TANK CLEANUP FUNDS
(15A NCAC 2P).
PART II - PERFORMANCE STANDARDS
1. The injection facility shall be effectively maintained and operated at all times so that there is
no contamination of ground waters that will render them 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 (Division) such as the repair, modification, or abandonment
of the injection facilities.
2. The issuance of this permit shall not relieve the Permittee of the responsibility for damages
to surface or ground waters resulting from the operation of this facility.
WI0300046 Page 2 of 6

PART III - OPERATION AND MAINTENANCE REQUIREMENTS
1. 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.
2. 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 Groundwater Section - Underground
Injection Control (UIC), Central Office st8f, , 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.
PART IV - INSPECTIONS
1. 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 V - MONITORING, REPORTING AND RECORD KEEPING REQUIREMENTS
SECTION A: MONITORING
1. 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 a sampling and reporting schedule, as approved or specified by the Division,
shall be followed in accordance with the application dated April 24, 1998 and supplemental
information, which is filed with the Department of Environment and Natural Resources. This
permit does not relieve the applicant of any monitoring responsibilities specified by the site's
NPDES permit.
WI0300046 Page 3 of 6

2. The Permittee shall report by telephone, within 48 hours of the occurrence or first knowledge
of the occurrence, to the Groundwater Section Staff; Mooresville Regional Office, telephone
number [phone], any of the following:
(A)
(B)
Any occurrence at the injection well facility that results in any unusual operating
circumstances.
Any failure due to known or unknown reasons, that renders the facility incapable of
proper injection operations, such as mechanical or electrical failures.
3. The Permittee shall report any monitoring or other information which indicates that any
contaminant may cause an endangerment to an underground source of drinking water; or any
noncompliance with a permit condition; or malfunction of the injection system which may
cause fluid migration outside the injection zone or area of review. The information shall be
provided to the Mooresville Regional Office orally within 24 hours of the occurrence and as
a written submission within five days of the occurrence. The written submission shall contain
a description of the noncompliance and its cause, the period of noncompliance, including
exact dates and times, and 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.
4. 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.
SECTION B: REPORTING
1. The Permittee shall produce a final project report within 90 days after completing
injection activity. This document shall comprehensively assess the injection project's
effectiveness and include, but not be limited to the following information:
(A)
(B)
(C)
Monitoring well sampling data.
Contaminant plume isoconcentration maps before and after the injection.
Chemical and physical fate of the injectant and its byproducts.
The Permittee shall report any additional monitoring or other information, which may be
useful in evaluating the effectiveness of ozone injection to oxidize the petroleum
contamination.
2. The final project report shall be submitted to the Underground Injection Control Program,
Groundwater Section, NC DENR Division of Water Quality, P.O. Box 29578, Raleigh, NC
27626-0578 and to the Groundwater Section, Mooresville Regional Office, 919 N. Main St.,
Mooresville, NC 28115.
W10300046 Page 4 of 6

3. 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 Permittee shall promptly submit the relevant and correct facts or information
to the Director.
SECTION C: RECORD KEEPING
The Permittee shall retain copies or records of all monitoring information, including ail
calibration and maintenance records, all original strip, chart recordings for continuous
monitoring instrumentation and copies of all reports required by this permit, for a period of
at least 3 years from the date of the sample, measurement, report, or application. Records
of monitoring information shall include but not be limited to:
(A)
(B)
(C)
(D)
(E)
(F)
The date, exact place, and time of sampling or measurements.
The individual(s) who performed the sampling or measurements.
The date(s) analyses were performed.
The individual(s) who performed the analyses.
The analytical techniques or methods used.
The results of any such sampling, measurements, and analyses.
PART VI - PERMIT RENEWAL
The Permittee shall, at Least three (3) months prior to the expiration of this permit,
request an extension.
PART VH - 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 seal.
If a well is not to be used for any purpose, that well must be permanently abandoned
according to 15 NCAC 2C .0214, 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 15 NCAC 2C .0214, including but not limited to the following:
(A) All casing and materials may be removed prior to initiation of abandonment
procedures if the Director finds such removal will not be responsible for, or contribute
to, the contamination of an underground source of drinking water.
WI0300046 Page 5 of 6

The entire depth of each well shall be sounded before it is sealed to insure freedom
from obstructions that may interfere with sealing operations.
Each 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.
Each well shall be completely filled with cement 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.
In the case of gravel -packed wells in which the casing and screens have not been
removed, the casing shall be perforated opposite the gravel pack, at intervals not
exceeding 10 feet, and grout injected through the perforations.
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.
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 VII (1) and (2)(G) shall be submitted to:
Groundwater Section - UIC Staff
DENR - Division of Water Quality
P.O. Box 29578
Raleigh, NC 27626-0578
PART VJU - SPECIAL CONDTITONS
NONE
WI0300046 Page 6 of 6

State of North Carolina
Department of Environment,
Health and Natural Resources
Division of Water Quality
James B. Hunt, Jr., Governor
Jonathan B. Howes, Secretary
A. Preston Howard, Jr., P.E., Director
January 24, 1996
Scott Eaton
CITGO Petroleum Corporation
PO Box 47427
Doraville, GA 30362
Dear MrEaton:
In accordance with the application submitted on your behalf by S& ME, Inc., dated November
22, 1996 and the additional information submitted in a letter dated January 24, 1997 we are
forwarding Permit No, WI4300038. This permit is for the modification of an existing air sparging
well system to be used for the injection of Triethylphosphate, for the purpose of stimulating the
biological degradation of petroleum contamination..
This permit shall be effective from the date of issuance until January 31, 2002, and shall be
subject to the conditions and limitations stated therein, including the requirement to notify this office
by telephone 48 hours prior to initiation of operation of the facility.
In order to continue uninterrupted legal use of this well for the stated purpose, you should
submit an application to renew the permit six months prior to its expiration date.
If you have any questions regarding your permit please feel free to contact me at
[phone].
Sincerely,
//1.6 1:2
Mark R, Milligan, L.G.
Underground Injection Control Program
cc: David Klemm, S ME Inc., w/ enclosure
UIC Files, w/ enclosure
j RO Files, w/ enclosure
Enclosures
nirnnc:otTcevv.pdocs\perm:its\traranne2
Groundwater Section, � Voice 919-733-3221 FAX [phone]
P.Q. Box 29578, Raleigh, North Carolina 27626-0578 An Equal Opportunity/Affirmative Action Employer
moommummummommor
2728 Capital Blvd., Raleigh, North Carolina 27604 50% recycles/10% post -consumer paper

-44
NORTH CAROLINA
ENVIRONMENTAL MANAGEMENT COMMISSION
DEPARTMENT OF ENVIRONMENT, HEALTH, AND NATURAL RESOURCES
RALEIGH, NORTH CAROLINA
PERMIT FOR THE 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
CITGO Petroleum Corporation
FOR THE OPERATION OF AN INJECTION WELL SYSTEM for the purpose of injecting
Triethylphosphate (TEP) through an air sparging system consisting of 7 wells. This well system is
located at 7600'Mt. Holly Road, in Charlotte, North Carolina, in Mecklenburg County, and will
be operated in accordance with the application dated November 22, 1996, and in conformity with
the specifications and supporting data submitted, all of which are filed with the Department of
Environment, Health, and Natural Resources and are considered a part of this permit.
This permit is for 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 15 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 January
31, 2002, and shall be subject to the conditions and limitations specified in Parts 1 through VIII
herein.
Permit issued this the ,Z 9 day of Jaunuary, 1997.
Ted L. Bush, Jr., Assistant Chief
Groundwater Section
Division of Water Quality
By Authority of the Environmental Management Commission.
PERMIT NO. WI0300038

v
PART I - 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 (15ANCAC 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 is effective only with respect to the nature, volume of materials and rate of
injection, as described in the application and other supporting data.
3. 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.
4. The issuance of this permit shall not relieve the Permittee of the responsibility of complying
with any and all statutes, rules, regulations, or ordinances which may be imposed by other
Iocal, state, and federal agencies which have jurisdiction. Furthermore, the issuance of this
permit does not imply that all regulatory requirements have been met.
PART II - PERFORMANCE STANDARDS
1. The injection facility shall be effectively maintained and operated at all times so that there is
no contamination of ground waters which wiII render them 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 (Division) such as the repair, modification, or abandonment
of the injection facilities.
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 groundwaters resulting from the operation of this facility.
PART DI - OPERATION AND MAINTENANCE REQUIREMENTS
1. The injection facility shall be properly maintained and operated at all times.
PAGE 2 OF 8

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 Groundwater Section - Underground
Injection Control (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.
PART IV - INSPECTIONS
1. 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 V - MONITORING AND REPORTING REQUIREMENTS
SECTION A
1. 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 report by telephone, within 48 hours of the occurrence or first knowledge
of the occurrence, to the Groundwater Section Staff, Mooresville Regional Office, telephone
number [phone], any of the following:
(A)
(B)
Any occurrence at the injection well facility which results in any unusual •
operating circumstances;
Any failure due to known or unknown reasons, that renders the facility incapable
of proper injection operations, such as mechanical or electrical failures.
PAGE 3 OF 8

3. 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.
4. 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.
SECTION B
1. The Permittee shall collect samples from wells TW1, MW-11, and MW-17 prior to the start
of TEP injection and every January, April, July, and October thereafter, for the following
parameters:
(A)
(B)
(C)
D)
(E)
(F)
Water level, must be made prior to sampling for the remaining parameters.
The depth to water in each well shall be measured from a surveyed point on
the top of the casing
pH, must be made in the field immediately upon sample collection
Dissolved Oxygen, must be made in the field
Total Phosphorous
Volatile Organic Compounds by EPA Method 601 or Standard Method
6210D with MTBE
Any additional groundwater quality monitoring, as deemed necessary by the
Division, shall be provided.
The results of the sampling and analysis shall be submitted on Form GW-59 (Compliance
Monitoring Report Form) to the Underground Injection Control Program, Groundwater
Section, NC DEHNR Division of Water Quality, P.O. Box 29578, Raleigh, NC 27626-0578
and to the Groundwater Section, Mooresville Regional Office, 919 N. Main St., NC 28115
every February, May, August, and November.
2. The Permittee shall collect a sample from well MW-18 prior to the start of TEP injection for
the following parameters:
(A)
(B)
(C)
D)
(E)
Water Ievel, must be made prior to sampling for the remaining parameters.
The depth to water in each well shall be measured from a surveyed point on
the top of the casing
pH, must be made in the field immediately upon sample collection
Dissolved Oxygen, must be made in the field
Total Phosphorous
Any additional groundwater quality monitoring, as deemed necessary by the
Division, shall be provided.
The results of the sampling and analysis shall be submitted on Form GW-59 along with the
results required in Part V Section B (1).
PAGE 4 OF 8

r
3. For the area of influence of the 7 existing air sparge wells (TEP injection wells), the Permittee
shall report biodegradation rates and the data, methods, and calculations used to determine
these biodegradation rates prior to the start of TEP injection and every January, April, July,
and October thereafter.
4. The Permittee shall report any monitoring or other information which may be useful in
evaluating the effectiveness of TEP injection to stimulate the biological degradation of
petroleum hydrocarbon contamination in the saturated or unsaturated zones.
5. The Permittee shall report any monitoring or other information which indicates that any
contaminant may cause an endangerment to an underground source of drinking water and any
noncompliance with a permit condition or malfunction of the injection system which may
cause fluid migration outside the injection zone or area of review. The information shall be
provided to the Mooresville Regional Office orally within 24 hours of the occurrence and as a
written submission within five days of the occurrence. The written submission shall contain a
description of the noncompliance and its cause, the period of noncompliance, including exact
dates and times, and 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.
6. The Permittee shall retain copies or records of all monitoring information, including all
calibration and maintenance records, all original strip chart recordings for continuous
monitoring instrumentation and copies of all reports required by this permit, for a period of at
least 3 years from the date of the sample, measurement, report, or application. Records of
monitoring information shall include but not be limited to:
(A)
(B)
(C)
(D)
(E)
(F)
the date, exact place, and time of sampling or measurements;
the individual(s) who performed the sampling or measurements;
the date(s) analyses were performed;
the individual(s) who performed the analyses;
the analytical techniques or methods used; and
the results of any such sampling, measurements, and analyses
PART VI - PERMIT RENEWAL
The Permittee shall, at least six (6) months prior to the expiration of this permit,
request an extension.
PART VII - 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
PAGE 5 OF 8

well is taken completely out of service temporarily, the Permittee must install a sanitary seal.
Ea well is not to be used for any purpose that well must be permanently abandoned
according to 15 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
15 NCAC 2C .0214, including but not limited to the following:
All casing and materials may be removed prior to initiation of abandonment
procedures if the Director finds such removal will not be responsible for, or
contribute to, the contamination of an underground source of drinking water.
The entire depth of each well shall be sounded before it is sealed to insure freedom
from obstructions that may interfere with sealing operations.
Each 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.
Each well shall be completely filled with cement 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.
In the case of gravel -packed wells in which the casing and screens have not been
removed, the casing shall be perforated opposite the gravel pack, at intervals not
exceeding 10 feet, and grout injected through the perforations.
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.
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 VII (1) and (2)(G) shall be submitted to:
Groundwater Section - UIC Staff
DEHNR Division of Water Quality
P.O. Box 29578
Raleigh, NC 27626-0578
PART VIII - SPECIAL CONDITIONS
NONE
PERMIT NO. WI0300038
PAGE 6 OF 8

CARBON FILTER
COALESCING FILTER
PARTICULATE FILTER
COMPRESSOR
SAMPLE PORT
PHOSterTM TANK
GROUND SURFACE
WATER TABLE
EXISTING CLASS 5P
SPARGE WELL
ATTACHMENT 1
PERMIT NO. WI0300038
SCALE: NOT TO SCALE
CHECKED BY:
DRAWN BY: SB
DATE: 11-13-96
ENVIRONMENTAL SERVICES
ENGINEERING • TESTING
INJECTION DIAGRAM
CITGO PETROLEUM
CORPORATION
CHARLOTTE, NORTH CAROLINA
1
FIGURE NO:
Joe NO: 1254-90-295
e'
5
PAGE 7 OF 8

ar•
COLONIAL FIFELJNE
PROPERTY
. A
LEGEND
(4)
4
APPROMMAMEd
'MEP
APPROXIMATE L
PROPOSED LOCI
ATTACHMENT 2
PERMIT NO. WI0300038
ENVIRONMENTAL SERVICES • ENGINEMNG • TESTING
LOCATION OF E
SITE PLAN SPARGE WELL LOCATIONS
CITGO PETROLEUM CORPORATION
CHARLOTTE, NORTH CAROUNA
150 DRAWN BY: CCK/j CHECKED BY:
264-90-295 DATE 11-13-96 1 FIGURENO: 3
PAGE 8 OF 8

Nei _h Cerolina t ena me_nt of Environment, Hesi: h, and Natural Resources
Division o'.-,._ tai Management - Groundwater Section
-Nu;,r"."—fC .,''lC:1.=
�t - =O.rRM
INJECTION WELL PERMIT NO. rq l
NAME OF OWNER
L.
rso
.et.?,.v rin,.; I a—
DATE 1-41-6
ADDRESS SS OF OWNER
(Street/ road cr lot and sucdivision, crun:y, roan)
LOCATION OF INJECTION WELL , and source well (s) ,
(jL Pe,ILmiduA'1 �Vm,
re o ll ,(C
_f applicable)
(5rreer/ r as r and suCdlvisicr7 , county, town, i7 cif erent :nan owner's actress, plus descriprion or location cn site)
?ctentiai pollution source x.JPS Distance. from well
Potential pollution source Distance from well
Potential pollution source Distance from well
Minimum distance of well from Property boundary
Quality of drainage at site s Ga 7yd/P Flooding potential of site
good.acecuare,poor)
(hign,,soderate, low)
DRAW SOTC.3 OF SITE (Show proper-7 coundar:es. buildings, iel7s, porent:ai p. 1 iuz;'on sources, reads, aocrnximare
scale, and norr.h arr cw. )
DESC2IBE INJECTION SYSTEM (ver-.c=i =:os2d iwo. .rcaser borercle yr csseC .pater gel;; scut --a well and
in ✓`tics? 3ii: :occi.^.at;cn source .nc •oll: =•esc.-wr'on aoaiicaoie)

- C` N RUCTION
Dr-4 1:::c contractor: Name
T'c� al ce�tn or. well
Address : SS !tour(;w g7
v^r rwM.�/r4 S r�U' 1
Beg s traticni number
Total depth of source well
(;r acpi;C2Dle)
Inspection point Measurement 'Meets minimum standards Comments
tuz'rs
r.,ti;ur , a�� bo .LcLLT" vs No
C s inc
Ue^`_1
Diameter
eicht (A.L.S.)
Grout
Depth.
Screens
Deuth(s)
Length(s)
T.D. ?Mat=
Static water level
Well y-;ezd
� r • s --a
Endlosur..- ._.l.CC
(concreted)
Sampling port
(labelled)
rfa.ter tight p ..pe entry
Well a„c'osu;e entry
T7ent
▪ uncti :nine of heat pump system { .err ,a ;r^.m :re Cvner rr_nCt-arcs ra-eriy.)
_.
▪ �7.
�&Sur;fir. e
i
/V 04O Na /
Office =o , G
.+ r

I1
ii •Ito-" (5' 21 ��Ir�t;I r�
r ,r evop° •S ,ti c—w,
116 0o-ocg,,e/4-,t D-" •r
tQ &,S— bp.,,, ey�il9,t
I Iy ,p?P•.''. •
i I ▪ G i i S . p�1t+ili%„e�
�r J �( ;5�ec�
' / -1- PADS leis �r. 6
r: • /pr..;a, cc...eq.) e„i,.+S 1�Cdu:cl.V.C{
i ptst a,„.75 7J boe 1 CI Scc .
CARBON FILTER
COALESCING FILTER
PARTICULA1E FILTER
COMPRESSOR
--SAMPLE PORT
•
PI IOStct 114 TANK ' . •
•
SCAT I: 1 I(iT 141 ~t:AL E
al
?i CIIL(.ILCI) l,Y:
4:
f4RAwrI
wl
I iA IC:
11 1.5 96
•
Aid
GI<O1,011) SURFACE
— — _ MIER TABLE
EXISTING CI.ASS 5P
SPARGE WELL
•
Et M1lO1•U.1LI 1 fAL E;Envic.L s
n kali•Ci:1111.10 • '1 I:E1•1'II ICI
r1
INJ[_C iIo)II Itl Li II i i •.1, l
(1-1-Go Pit; 1 <i lE 1 111..1
C,()t<I)01 A 11011 1 l 1
CJ IAI<1.0 1 CE, 11(ll{III %:P;I((iI II IA
.I0l3 iio. 1 25•1 ``-]il -2.05
n ,
1

•
•
n.c,
- r,�._.
•
awvr._
1
1� CCLCYiiL
,• S
",,N •.0,`._ 1.. _ 'voc.:ED
-s.i.11 \
o
� • 1
RWi`� '--- jj
r�
•
IAH-isy y
- -vv
/1;
kro-15
rgCcipr: 1
°Gr'irr
• }n
AFRROXImATE L^_C.AT1ON OF RECO4ZRY ELL
ApPROxiMATE LOCATION Cr EXISTiNG MONITORING v,ELI.
To b e I
FRC?CSE _CC=1CN Cr SPARGE tiELL- S.Lstir •;oH,
re we
=G- SJ Lu 5v4`ce uf£ f!5 Y
(J w:'15 70 vjf j yr
1 S1P, r�aCi•.r.

State of North Carolina
Department of Environment,
Health and Natural Resources
Division of Water Quality
James B. Hunt, Jr., Governor
Jonathan B. Howes, Secretary
A. Preston Howard, Jr., P.E., Director
GROUNDWATER SECTION
December 3, 1996
MEMORANDUM
To: Barbara Christian
Groundwater Section
Mooresville Regional Office
From:
Mark Milligan I..
UIC Group
Groundwater Section
Raleigh Central Office
Re: Request for review of new injection well permit application for construction and operation
and for pre -construction inspection.
An application by S&ME, inc, for a new permit for construction and operation of an injection
facility has been received by RCO - UIC. A copy of the application is enclosed. This application is
for the injection of Triethylphosphate in a modified air sparging/big-venting process.
1. Please review the application and submit any comments to RCO-UIC. Retain the
application for your files.
2. Please inspect the proposed injection well site to verify that the location and construction
plans submitted in the application are being followed and that the NCAC Ti 5A:02C.©200
standards are being complied with, using the enclosed Preconstruction Injection Facility
Inspection Report (fonn A).
Return any application review comments and the completed Preconstruction .Injection Facility
Inspection Report (form A) to the RCO-UIC by December 1.8, 1996 (within 2 weeks). If the
inspection cannot be accomplished by this date, please inform. RCO-UIC. Please note that I will be
out of the office from December 21 to January 20, thus a timely response on your part is
appreciated.
After the permit has been issued and the facility has been constructed and when operatic n is about
to commence, the ,RCO-UIC may request the MRO to inspect the facility in operation.
cc: UIC Files
MRO
Enclosures
Groundwater Section,
P.O. Box 29578, Raleigh, North Carolina 27626-0578
2728 Capital Blvd., Raleigh, North Carolina 27
N
c
tt rm-c.lai3auel ioc e i,askrwcnt.cit
Voice 919-733-3221 FAX [phone]
An Equal opportunity/Affirmative Action Employer
cycles/'1tt'°. post -consumer paper

November 21, 1996
North Carolina Department of Environment, Health,
and Natural Resources
DWQ Groundwater Section
P.O. Box 29578
Raleigh, North Carolina 27626 -0578
A I I ENTION: Mr. Mark Milligan
Reference: INJECTION PERMIT APPLICATION
CITGO Petroleum Corporation
Charlotte, North Carolina
S&ME Project 1264-90-295
Dear Mr, Milligan:
Enclosed is an injection permit application for the injection of triethylphosphate gas at the
CITGO Petroleum Corporation terminal in Charlotte, North Carolina (Figure 1). The
injection process will be used to stimulate the biological degradation of petroleum
hydrocarbons in the subsurface, The process is known as PHOSterTM and is patented
by the Department of Energy. Essentially, the injection of triethylphosphate is a modified
air spargingfbio-venting process. Triethylphosphate is contained within a contactor tank
in a liquid phase. Air from a typical air sparging process is routed through the contactor
tank over the liquid triethylphosphate. The triethylphosphate evaporates according to its
vapor pressure. As the triethylphosphate evaporates, the air being routed though the
tank acts as a carrier gas and transports the triethylphosphate to the sparge well for
injection in a gaseous phase at an approximate concentration of 70 ppmv. The nutrients
are utilized by naturally occurring microorganisms which biologically degrade the
hydrocarbons,
SekME, Inc, 155 Tradd Street, Spartanburg, South Carolina 29301, [phone], Fax [phone]
Greenville, South Carolina, [phone]
RdtrAWO POW

Injection Permit Application S&ME Project 1264-90-295
CITGO Petroleum Corporation November 1996
Insitu bio-remediation of petroleum hydrocarbons is typically limited by oxygen. In many
cases, the injection of air alone is sufficient to provide adequate biorespiration of the
contaminant, which is why air sparging/bio-venting have become such popular
remediation techniques. However, in some cases, the lack of nutrients may also inhibit
biological consumption of the contaminants. Research conducted at the Department of
Energy Savannah River Site in Aiken, South Carolina indicates the primary limiting factor,
after oxygen, is phosphates. As a result, PHOSterTh was developed which. allows for
efficient, controlled injection of phosphate in a form readily available to micro-organisms.
In two field scale tests, PHOSterTM improved the rate of biodegradation by as much as
one order of magnitude. A brief description of PHOSterT"", published by the DOE, is
attached.
Currently, an air sparging project is being performed at the CITGO terminal through seven
Class 5P injection wells. Prior to air sparging, approximately 0.5 feet of measurable
product existed on the water table surface in the area of the project. The goal of the
project was to see if low volume air sparging would enhance biological degradation of the
residual free phase gasoline. A layout of the site and the current extent of the plume are
shown on Figure 2. The locations of the sparge wells are shown on Figure 3.
The initial results indicate that air sparging enhances remediation of residual free phase
gasoline. However, it was determined through respirometry testing that biological
degradation rates were sufficiently suppressed and that air sparging could not be
performed below residual free phase gasoline without potential for surface emissions,
unless some other engineering control (eg. vapor extraction) were employed. Since we
are attempting to provide solely insitu treatment of the contaminants, we are proposing
to test the PHOSterTM technology to evaluate if subsurface biological activity can be
enhanced to the point where surface emissions would not occur. Initially, the TEP will be
2

Injection Permit Application S&ME Project 1264-90-295
CITGO Petroleum Corporation November 1996
injected through the seven existing Class 5P air injection wells. If the TEP application
proves successful, we will perform TEP addition at all future air sparging wells.
We have included three additional documents to aid in expedited approval of this
proposal. These include triethylphosphate information submitted to Dr. Louanne Williams
(NCDEHNR Occupational and Environmental Epidemiology Section), Dr. William's
response, and additional triethylphosphate fate information in response to Dr. Williams'
comments.
CITGO and S&ME appreciate your consideration of this request. If you have any
questions or need further information, do not hesitate to call.
Sincerely,
S&ME, Inc. el'' ' ['�f` ,(4 6'1
J/2if4:T!L')
SEA
2
oo
David E. Klemm, P.G. V loGi,S ` r3
Project Manager
CC
c`c-°�°``�6
Stanfg9cf Lummus, P.E.
Senior Environmental Engineer
DEK/SUId
cc: Mr. Scott Eaton, CITGO Petroleum Corporation - Doraville, GA
Mr. Gil Butler, DEM Moonesville Regional Office
3

NORTH CAROLINA
ENVIRONMENTAL MANAGEMENT COMMISSION
DEPARTMENT OF ENVIRONMENT, HEALTH, AND NATURAL RESOURCES
APPLICATION FOR PERMIT TO C ONSTRUCT AND/OR USE A WELL FOR LNJECTTON
(NON -HEAT PUMP SYSTEM)
This is not the proper form for injection wells to be used in a closed -loop groundwater remediarion
system. Wells of this type require a separate
Groundwater Remediation Permit Application.
Class 5 Wells
TO: DIRECTOR, NORTH CAROLINA DIVISION OF WATER QUALITY
DATE: No YN+ E3c7-..r; Z2. , 19 ot(o
In accordance with the provisions of Article 7, Chapter 87; Article 21, Chapter 143; and regulations pursuant
thereto, APPLICATION is hereby made for a PERMIT to construct and/or use an injection well or well system
as described below and in any accompanying data submitted as part of this APPLICATION.
Please type or print clearly.
A. PERM1T APPLICANT
Name: CITGO Petroleum Corporation
Address: Post Office Box 47427
City: Doraville, GA Zip code: 30362
County: - I)eKalb
Telephone: [phone]
B. STATUS OF APPLICANT
Federal State Private X
Public Commercial Other
Native American Lands
C. PROPERTY OWNER (if different from applicant)
Name: Same
Address:
City: Zip code:
County:
Telephone:
D. FACILITY (SITE) DATA
Name of Business or Facility CITGO Petroleum Corporation
Address: Box 58
City: Paw Creek. NC
County: 1'lecklenburp
Telephone: [phone]
Contact Person: ,Jim Iltke
Zip code: 28130
E. INJECTION PRO(:hDURE (Briefly describe how the injection well(s) will be used.)
Injection of triethylphosphate gas through air sparp;inw' wells.
Application is to enhance hinrlerr.adatinn of petroleum hydrocarbon in
sail and grrmndwater.
F. WELL USE Will the injection well(s) also be used as the supply well(s) for either of the following:
(a) The injection operation? YES NO X
(b) Your personal consumption? YES NO X
GW-5 7 N (10/96) Pace I of 4

G. CONSTRUCTION DATA (check one)
X EXISTING WELL being proposed for use as an injection well. Provide the data
in (1) through (7) below to the best of your knowledge. Attach a copy of
Form GW-1 (Well C®struction Record) if available.
X PROPOSED WELL to be constructed for use as an injection well. Provide the
data in (1) through (7)below as PROPOSED construction specifications. Submit
Form GW-1 after construction.
NOTE: THE WELL DRILLING CONTRACTOR CAN SUPPLY THE DATA FOR EITHER EXISTING OR
PROPOSED WELLS IF THIS INFORMATION IS UNAVAILABLE BY OTHER MEANS .
(1) Well Drilling Contractor's Name: S &ME , Inc .
NC Driller Registration number. 1461
(2) Date to be constructed: Approximate depth: 30 ft .
(3) Well casing:
(a) Type: Galvanized steel Black steel Plastic Other(specify) PVC
(b) Inside diameter. 2 inches; Wall thickness inches or schedule # Sch 40
(c) Casing depth: From 0 to 28 ft. (reference to land surface)
(d) Casing extending above ground 0 inches (must be at least 12 inches)
(4) Cement grout:
(a) Around inner or "primary" casing From 0 to 24 ft. (must be from the land
surface to the point of injection)
(b) Around outer (pit) casing, if present From to ft.
(5) Screens (if applicable):
(a) Type: PVC ; Inner diameter. 2 inches
(b) Depth: From 28 to 30 feet below land surface
(6) Gravel (if applicable): From 27 to 30 feet below land surface
Q77 N.C. State Regulations (Title 15A NCAC 2C Section .0200) require the permittee to make provisions
N / A for monitoring wellhead processes. A faucet on both influent (recovered groundwater) and effluent
(water being injected into the well) lines is generally required. Will there be a faucet on:
(a) the influent line? yes no (b) the effluent line? yes no
H. PROPOSED OPERATING DATA
(a) Injection rate: Average (oily) 2-5 aa?let�s-per-raifxute-(gpm)
How will the rate be measured? In line flow meters
(b) Injection volume: Average (L'aily) 5000 lons-per-clay tgpd) CFD air + TEP
How will the volume be measured? calculated
(c) Injection pressure: Average (r}aily) 20 pounds/square inch (psi)
How will the pressure be measured? pressure gauge
(d) Injection temperature: Annual Average 70 degrees F
How was this determined? average ambient temperature
(e)
Hydraulic capacity of well: N / A
(f) Expected lifetime of injection facility 2 years
GW-57N (10/96) Page 2 of 4

L INJECTION FLUID DATA
(/1)
N/A
Fluid source. If underground, from what depth, formation and type of rock/sediment unit will the
fluid be drawn (e.g., granite, limestone, sand, etc.).
Depth: Formation: Rock/sediment unit
(a) SOURCE WELL CONSTRUCTION INFORMATION (if different from injection well).
Attach a copy of Form GW-1 (Well Construction Record). If Form GW-I is not available,
provide the data in part G (1) through (7) of this application form to the best of your
knowledge.
Q21 Chemical Analysis of Source Water.
N / A application:
pH ; Total hardness
Chloride
(3)
ppm; Nitrate
The following chemical characteristics MUST accompany this
ppm (parts per million or mgfl); Iron ppm;
ppm; Coliform bacteria counts/100 ml.
Substances added to injected fluid. Some substances may be added to (1) enhance in -situ treatment
of contaminated soil and/or groundwater and (2) improve well operation. Only substances that can
be demonstrated to have advantages that outweigh disadvantages will be considered.
Will any substances be added to the effluent? If yes, provide a detailed description of
these substances, including quantity and schedule of substances to be added. Epidemiologic data
should be submitted to aid evaluation. Provide copies of published reports or pilot studies that
justify the type, quantity and schedule of additivies proposed.
TEP gas is added to the injected air stream at anproxirnately
70 ppmv.
J. INJECTION -RELATED EQUIPMENT
Attach a diagram showing the engineering layout of the (1) injection equipment_ and (2) exterior
piping/tubing associated with the injection operation. Describe the method for determining mechancial
integrity of the injection well over a five (5) year period.
K. TOPOGRAPHIC MAP
Attach a scaled topographic map which extends one mile beyond the property boundaries of the facility
and indicates the location of the facility.
L HYDROGEOLOGIC MAPS AND CROSS SECTIONS
Attach scaled maps and cross sections indicating the vertical and lateral limits of all underground
sources of drinking water within 3,000 ft. Include their position relative to the injection formation,
and the direction to water which may be affected by the proposed injection.
NI. LOCATION OF WELL(S)
Attach a detailed, scaled map of the site of the facility, showing the location of and distances between the
proposed wells(s) (source wells and injection wells) and any waste (including hazardous waste) treatment,
storage or disposal facilities; buildings; property boundaries; surface water bodies; and any other potential
source of groundwater contamination. Additionally, indicate on the map the direction and distance to
existing wells (injection wells, water supply wells, dry wells, abandoned wells) Iocated within 1,500 feet of
the proposed injection well(s). Include with the map a description of each existing well, incorporating type,
construction information, date drilled, and depth. Indicate on the map at least two nearby reference points
such as roads, road intersections, streams, etc., and identify them by US, NC or SR (county secondary
roads) numbers or name. Label all features clearly. Include a north arrow on the map to indicate orientation.
GW-57N (10/96) Page 3 of 4

N. HYDRAULIC CONTROL
Attach calculationslmodels which demonstrate the expected changes in pressure, formation fluid
displacement and direction of movement of the injected fluid. Describe any plans to monitor fluid
movement. if contaminants are present, the operation of an injection well must not result in the midzaLion
of a contaminant off properly boundaries.
0. CONTINGENCY PLANS
Attach a brief plan to address emergency control methods that will be utilized in case of an injection well
failure or loss of power so as to prevent the discharge of fluids outside the injection zone area.
CERTIFICATION
"I hereby certify, under penalty of law, that I have personally examined and am familiar with the
information submitted in this document and all attachments thereto and that, based on my inquiry of those
individuals immediately responsible for obtaining said information, I believe that the information is true,
accurate and complete. I am aware that there are significant penalties, including the possibility of fines and
imprisonment, for submitting false information. I agree to construct, operate. maintain., repair, and I agree
to, if applicable, abandon the injection well and all related appurtenances in accordance with the approved
specifications and conditions of the Permit."
t;/br Authorized Agent)
PLEASP'PLY.A LP "ER SIGNED E,OWNER
AUTHORIZING Tl EABOVE.tGE"17 IF.AL'7'7IOW-ZED AGE,,\TISSIGNER.
Q. CONSENT OF PROPERTY OWNER (Owner means any person who holds the fee or other property rights
in the well being constructed. A well is real property and its construction on land rests ownership in the
land owner in the absence of contrary aareement in writing).
If the property is owned by someone other than the applicant, the property owner hereby consents to alley v
the applicant to construct each injection well as outlined in this application and that it shall be the
responsibility of the applicant to ensure that each injection well conforms to the Well Construction
Standards (Title 15A NCAC 2C ,0200)
Name of Property Owner (Print):
Mailing Address: _
Different From Applicant)
Please return the completed application package to:
LTIC Program.
WQ/Groundwater Section
P.O. I3ox 29578
Raleigh, NC 27626-0578
(telephone: [phone]I65)
(1096) lea eaof4

ADDENDUM TO INJECTION WELL PERMIT APPLICATION
CITGO PETROLEUM CORPORATION
CHARLOTTE, NORTH CAROLINA
GROUNDWATER INCIDENT #05735
GENERAL SITE HISTORY
The subject site is the CITGO Petroleum Corporation bulk storage terminal located in the
Paw Creek community of Charlotte, North Carolina. The site consists of seven
aboveground bulk petroleum storage tanks, an office/warehouse and truck loading rack.
In 1990 a subsurface leak was discovered from a pressurized line connecting a storage
tank containing regular gasoline to a vapor recovery unit. A subsurface environmental
assessment was performed defining the extent of the free phase and dissolved gasoline
plume. Currently, thirty-eight monitoring wells and five recovery wells exist at the site.
The results of the assessment indicated the plume migrated approximately 750 feet to the
northeast in the direction of natural groundwater flow. A site plan depicting the site, the
existing monitoring well network, and results of the most recent groundwater sampling is
attached a Figure 2. The groundwater flow map is attached as Figure 4.
Remediation of the site was initiated in 1993 via a free product and total fluid recovery
system in the areas of site containing free phase gasoline. Vapor extraction was initiated
on the recovery wells approximately six months following initiation of the pump and treat
system. A horizontal air sparging well was installed at the up gradient end of the plume
in November 1994 to begin remediation of dissolved contamination. Shortly after, DEM
indicated their desire to concentrate remedial efforts in the free product area.
Free product and total fluid recovery has yielded over 36,000 gallons of gasoline since
the initiation of recovery. However, the last year of system operation has resulted in
less than 200 gallons recovered indicating the remaining product is in a residual, non-
recoverable state. In August 1996, seven air sparging wells were installed at the
northeastern property border to evaluate if air sparging would expedite free product
remediation. The goal of the test was to incorporate a remedial technology which would
provide totally in -situ remediation of the remaining contamination, eliminating the need for
discharge of treated groundwater and vapor to the environment. The test indicated free
product remediation could be enhanced, however, bio-respiration rates were not sufficient
to provide adequate subsurface destruction of the resulting petroleum vapors. Thus, we
are proposing the addition of TEP to enhance in -situ bio-degradation of the contaminants.
The following information provides additional support to the permit application.
1

A. Permit Applicant
CITGO Petroleum Corporation
Post Office Box 47427
Doraville, Georgia 30362
Dekalb County
Phone [phone]
B. Status of Applicant
Private Industry
C. Property Owner
Same as Applicant
D. Facility (Site Data)
CITGO Petroleum Corporation
Box 58
Paw Creek, North Carolina 28130
Mecklenburg County
Phone [phone],6
Contact Person: Jim Utke
Business: Bulk Petroleum Storage/Distribution Terminal
SIC Code: 5171
E. Injection Procedure
This is basically a modified air sparging system. Triethylphosphate (TEP)
is stored in a tank in a liquid state. Air is passed over the TEP. As TEP
evaporates according to its vapor pressure, it is picked up by the air and
transported to the injection well where it is injected as a gas at an
approximate concentration of 70 ppmv. The TEP is utilized by indigenous
microorganisms to enhance the biological degradation of petroleum
hydrocarbons in the subsurface.
F. Well Use
The injection wells are used solely for the air sparging process. The wells
are not used as water supply wells for the injection operation or for personal
consumption.
11

G. Construction Data
Seven air sparging wells are currently being utilized at the site. Based on
the success of air sparging, it is planned to provide air sparging over the
entire extent of the plume. The first phase of the full scale project will
include twenty additional Class 5P sparge wells. The locations of the
existing and proposed sparge wells are shown on Figure 3.
Construction of the wells will be identical with the exception of the total
depth, which will be a function of the depth to groundwater. The total depth
will generally vary between 20 and 30 feet below land surface. For
purposes of this application we assume a total depth of 30 feet.
(1) Well Drilling Contractor: S&ME, Inc.
NC Driller Registration Number: 1461
(2) Date of Construction: Dependent on receipt of injection permit
Approximate Depth: 30 feet bls
(3) Well Casing: PVC
Inside Diameter: 2 inches
Wall Thickness: Sch 40
Casing Depth: 0 - 27.5 feet bls
Casing extending above ground: 0 inches
(4) Cement Grout: 1 - 26 feet bls
Bentonite Seal: 26 - 27 feet bls
(5) Screen Type: PVC
Depth: 27.5 - 30 feet bls
(6) Gravel: 27 - 30 feet bls
(7)
N/A: Water is neither injected or recovered from these wells.
A sample port exists at the TEP tank for monitoring injection
concentration.
H. Proposed Operating Data
(a) The air sparging injection rate will range between 2 - 5 scfm.
The air flow is monitored to each sparge well using an in -line
float type flow meter.
ill

(b) The average daily air injection volume will be approximately
5000 cubic feet per day depending on the flow rate. The
injection operation is continuous. Therefore, the daily injection
volume is equal to the average flow rate times the number of
minutes of flow. The amount of TEP being injected will be
calculated as a percentage of the total flow rate based upon
the TEP concentration in the air stream.
(c) The injection pressure will be formation dependent. Based
upon the currently operating air sparging wells, the pressure
will range between 20 and 40 psi. Each well has its own
pressure gauge.
(d) The injection temperature will be close to ambient air
temperature.
(e) Hydraulic Capacity of the well: Not applicable
(f) The expected life time of the air sparging system is
approximately 2 years.
I. Injection Fluid Data
(1) Not Applicable: The fluid is compressed ambient air with
approximately 70 ppmv TEP.
(2) Not Applicable: No source water is used in the process.
(3) TEP is added to the air stream at approximately 70 ppmv.
J. Injection - Related Equipment
Attached is a diagram of the injection process (Figure 5). Ambient air is
compressed using a rotary screw compressor. The air is passed through
a particulate filter, a oil coalescing filter, and a vapor phase carbon filter.
The air is transported through reinforced rubber hose to an air distribution
manifold. The flow rate and pressure to each individual well is regulated at
the manifold. The air then flows through the PHOSterT"'' contactor tank
where triethylphosphate is picked up at an approximate concentration of 70
ppmv. The air/PHOSterT'll gas flows through 0.5 inch, reinforced rubber
hose to the sparge well. The sparge well is constructed of Sch 40 PVC
riser and screen and is installed approximately 10 feet below the saturated
IV

water table. All materials contacting TEP have been tested for chemical
compatibility.
K. Topographic Map
Figure 1 is a topographic map extending at least one mile beyond the
terminal property.
L. Hydrogeotogic Maps and Cross Sections
The site is located in the Charlotte Belt of the Piedmont Physiographic
province of North Carolina. The Charlotte Belt is characterized by igneous
and metamorphic lithologies consisting of gabbro and granitic rock types.
The soils in the Piedmont are typically characterized by the degree of
weathering of the parent rock material. The surface to near surface soils
are typically severely weathered indicating no remnant structure of the
parent rock. These soils usually consist of fine grain clayey silts called
residuum. With increasing depth from the surface the soils will begin to
retain some of the parent rock structure. These soils consist of fine to
medium grain silts and silty sands called saprolite. Weathering will
decrease with depth until the saprolitic soils become weathered rock and
then competent bedrock. The surficial groundwater aquifer at the site exists
in the saprolitic soil zone.
The lithology below the CITGO terminal is typical of the Piedmont
Physiographic Province. Most of the subsurface assessment performed at
the facility terminated in the saprolitic zone. Only one well installed at the
site penetrated competent bedrock at 56 feet below land surface.
Groundwater typically ranges between 5 and 20 feet below the land surface.
The contaminant of concern is gasoline which has a specific gravity less
than water, thus is primarily located in the capillary fringe and at the top of
the saturated surficial aquifer.
Hydrogeologic maps and cross sections have not been included. The
proposed injection will have minimal influence outside the radius of
influence of the sparge well (approximately 30 feet) and will be injected no
more than approximately 10 feet below the water table surface. The
injection fluid is TEP gas which is biodegradable in the subsurface. No
groundwater source wells have been identified within 1500 feet of the
downgradient limits of the plume.
V

M. Location of Wells
Figure 3 is a site plan indicating seven currently operating sparge wells and
the additional twenty proposed Class 5P injection wells. The existing
monitoring well network is shown on the map. A tabulation of the
construction details for all monitoring wells is attached as Table 1. No
groundwater supply wells exist within 1500 feet of the site.
N. Hydraulic Control
Not applicable.
O. Contingency Plans
In this process the • nutrient is made available for use by indigenous
microorganisms. There is no attempt to recover injected triethylphosphate.
Since the method of injection is by evaporation of TEP into the air, there is
no way the injection concentration can exceed vapor pressure of TEP (100
ppm at 68 degrees F). The ethyl group of TEP degrades to carbon dioxide
and water and the phosphates are incorporated into biomass. During the
initial testing of TEP injection, phosphorous concentrations will be monitored
in the groundwater. We will compare total phosphate concentrations prior
to and after TEP injection. We would also like to point out that CITGO has
tested this technology at their Panama City, Florida terminal with no
measurable increase in the phosphate concentration of the groundwater.
VI

V
oi
CD
C71
0)
V
CI1
V
O
0)
O
O
O
0
V
a)
W
IV
0)
V
O
O
CO
O
O
b
N
O
W
03
V
0)
co
C.)1
O
0
A
O
0)
O
O
O
N
V
V
CD
O
y
v
y
(D
O
A
O
00
0
A
W
0
0)
O
O
0
N
V
O
CO
V
v
01
A
A
O
O
(71
O
0
0)
O
O
O
N
[)cn
V
(0
N
V
(71
0)
(71
N
N
W
b
co
0
N
W
O
A
0
O
O
n
OL
Q7
V
(n
W
fV
W
y
A
(D
(0
O
co
CO
N
O
O
O
n
O
0)
V
(71
()1
-4
(1
IV
O
o
O
W
0
Co
0
N
O
O
O
n
cn
0)
O
co
V
(]1
0)
ti
W
co
O
W
O
O
O
cn
W
V
N
(n
W
-4
(J1
0)
0)
(71
N
W
01
0)
O
O
O
n
N
V
W
(h
V
(71
co
O
O
N
O
0
f11
O
N
O
O
O
O
O
0
V
W
'vs
O
-1
0)
N
41.
V
N
w
0
0
0
N
01
O
O
0
O
V
v
V
iV
V
V
O
W
O
W
O
O
O
0
0
N
N
(D
V
Co
A
V
V
Co
ti
W
W
0
Co
0
W
W
O
N
O
0
O
N
0o
y
0)
W
C7
V
V
a)
W
IV
V
W
0
W
0
N
W
O
N
O
O
O
V
W
Ce)
V
-1
v
W
.0)
V
CO
w
G7
i)1
CO
CJ1
N
Ca
0
O
co
r)
(71
O
co
V
v
C71
A
N
C71
O
O
0
N
01
O
O
O
N
(A
V
A
(D
O
V
A
0)
(D
Co
w
0
W
0
W
O
A
O
O
0
N
N
A
r1
0)
(0
V
-4
0)
CD
.A
V
W
0
O
0
W
C71
O
A
O
O
0
N
N
W
V
03
O
0)
()1
V
O
O
0,
0)
fV
O
0
O
N
O
O
O
J.
h7
V
CJI
Co
A
CO
r)
(71
0,
0)
CD
00
CO
CJ1
CO
C71
N
O
O
0
N
..a
rl
0)
Co
0)
i
V
0)
0o
ti
0)
N
O
N
V
O
N
O
O
0
N
O
V
CO
V
(0
V
0)
O
wi
N
w
0
A
O
N
O
O
O
(D
V
V
(D
co
V
V
O
CO
N
CO
in
W
(h
N
03
C71
N
O
O
O
a
CO
-4
V
C71
V
v
U1
03
A
w
O
O
C71
0
W
O
O
N
0
O
O
i
3
V
V
(D
V
Co
Co
CD
W
co
0
N
W
O
O
O
A
0
0
O
N
C7)
V
A
A
co
V
.A
0)
CO
O
O
N
(71
O
N
0
O
O
(71
V
N
.A
a)
V
N
0)
O
O
N
0
O
O
i
a
a
ti
03
V
Co
A
W
O
N
O
O
9)
0
N
O
O
N
0
0
O
i
•
w
ti
V
O
V
V
0
A
ti
U1
V
Cal
N
0
O
O
J
V
O
fV
0
V
V
0)
W
W
N
0
O
0
N
O
O
0
O
O
J
a
V
co
ti
V
A
N
O
0
O
N
C7)
0
A
0
O
O
N
O
0)
W
W
V
0)
W
W
O
.03
v
N
V
01
N
0
m
v
0)
CD
N
0)
-4
(.)1
(1
IV
f71
i
V
N
O
O
O
i
3
63
Co
V
V
CO
v
(71
N
A
O
(71
O
N
0
O
O
i
a
O
Co
GO
i
V
CO
Co
03
0)
W
C71
C71
00
0)
W
[71
N
0
O
O
j
ti
CO
Co
A
ti
CO
O "CO
VI
O
O
N
N
O
N
0
O
O
i
O
0
Co
Co
N
i
O
W
O
O
(71
0
W
O
0
N
0
O
O
i
y
CO
U1
W
ti
V
Co
CO
C71
O
O
N
U1
N
O
O
O
v
Co
N
G7
v
V
CD
V
ti
0
O
N
U1
O
N
O
O
O
J
13
V
v
V
(D
(1
V
Co
A
C71
O
0
N
(I1
O
N
0
O
O
3
V
03
W
0)
03
W
O
.A
N
01
O
O
O
N
(I1
O
N
0
O
O
i
r)
03
N
0)
A
O
W
O
(0
N
(n
A
O
A
N
(71
?.
N
'O
O
O
i

SCALE
0
SCALE:
2000
FEET
AS SHOWN
DATE 11-13-96
•
•
U' • . .+ •
•
•
� addl!i!vlle
v,IC__/
J.
4(1
SOURCE TOPOGRAPHIC MAP OF MOUNTAIN ISLAND LAKE, NORTH CAROLINA
QUADRANGLE, 7.5 MINUTE SERIES, USGS
ENVIRONVENTAL SERVICES
ENGINEERING • TESTING
SITE TOPOGRAPHIC MAP
CITGO PETROLEUM
COROPORATION
CHARLOTTE, NORTH CAROLINA
1
JOB NO: 1264-90-295
8OS
FIGURE NO:
1
i

COLONIAL PIPELINE
PROPERTY
MW—i2.
WOODED
AREA
4
CHARLOTTE -- MECKLENBURG
SCHOOL DISTRICT PROPERTY
,41
A
BDL
BELOW DETECTION LIMIT
APPROXIMATE LOCATION OF RECOVERY WELL
APPROXIMATE LOCATION OF EXISTING MONITORING WELL
BENZENE CONCENTRATION IN WELL IN ug/L (06-04-96)
ESTIMATED EXTENT OF DISSOLVED BENZENE PLUME
TOTAL BETX CONCENTRATION IN WELL IN ug/L (O6—O4--96)
ESTIMATED EXTENT OF DISSOLVED TOTAL BETX PLUME
MTBE CONCENTRATION IN WELL IN ugfL (06-04-96)
ESTIMATED EXTENT OF DISSOLVED MTBE PLUME
FREE PRODUCT IN WELL (Ft) 06-03-94
ESTIMATED EXTENT OF FREE PRODUCT
if2
FUEL OIL
/WATER
ARATOR
3
UNLEADED".,
REFERENCE; CITGO PETROLEUM CORPORATION
DRAWING NUMBER i47-100—E
DATED 9/4/57.
REVISION DATED 3/22/91,
Eai4QR 4dENTA# SE GE E iC 1 N • iESTiNG
SITE PLAN/PLUME MAP
CITGO PETROLEUM CORPORATION
CHARLOTTE, NORTH CAROLINA
5ODRAW4 BY; H„S./CCK CHECKED FRY.
�; 1 ZS4-- 0° 2 DATE. O7—O 6 El NO;

(A L PIPEUNE
PROPERTY
APPROXIMATE LOCATION OF RECOVERY WELL
APPROXIMATE LOCATION OF EXISTING MONITORING WELL
PROPOSED LOCATION OF SPARGE WELL
LOCATION OF EXISTING SPARGE WELL
MCS-4
'TTE MECKC'LENBURG
DISTRICT PROPERTY
UNE ROW
REFERENCE: CaTGGO PETROLEUM CORPORATION
DRAWING NUMBER 147-1OO—E
DATED 9,i 4,f 57,
RE\1SION DATED 3/22,/91,
FORMER UNDERGROUND
TOR AGE TANK
ENVIR
iT.
SPTE PLAN SPARGE `ELL LOCATIONS
CITGO PETROLEUM CORPORATION
CHARLOTTE, NORTH CAROLINA
SCALE
ORAWN Y. CCK/SP OHECKE E3Y.
NO: 1264--9t -295 DAB: 11Y-1 95 FI ORE NO.

0
COLONIAL PIPELINE
PROPERTY
LEGEND
MCS-6
MW-25
CS-7 MCS-3
-2 \
RW-4
RW-5 Mcs-1
MCS-5
MCS-4
MW-24 745
/50
t
MW-18
x-�
MW-17
MW-21
MW-22
._ C IAL PIPE LINE ROW
COLONIAL PIPELINE ACCESS ROAO---
RODUCr UNSS
APPROXIMATE LOCATION OF RECOVERY WELL
® APPROXIMATE LOCATION OF EXISTING MONITORING WELL
770 GROUNDWATER ELEVATION CONTOUR
PKOA
#2
FUEL OIL
TY gpUNbQRY
UNLEADED
2
FUEL 01
CHARLOTTE - MECKLENBURG
SCHOOL DISTRICT PROPERTY
MW-4
jMW-2
160
Z
FORMER UNDERGROUND
STORAGE TANK
11'
MW-29
WELL
ELEVATION
06-03-96
MW-1
768.29
MW-2
767.74
MW-3
764.98
MW-4
765.69
M W-5
765.77
MW-6
768.92
MW-7
772.41
MW-9
765.28
MW-10
759.53
MW-11
756.93
MW-12
760.69
MW-t3
765.56
MW-14
773.11
MW-15
768.08
MW-16
758.13
MW-17
750.77
MW-18
751.13
MW-19
756.47
MW-20
743.89
MW-21
744.26
MW-22
749.87
MW-23
773.61
MW-24
744.90
MW-25
746.06
MW- 26
757.94
MW-27
766.94
MW-28
745.95
MW-29
784.00
TW-1
756.10
MCS-1
744.77
MCS-2
743.95
MCS-3
742.92
MCS-4
749.91
MCS-5
746.23
MCS-6
747.99
MCS-7
743.65
RW-1 '
756.64
RW-2
752.88
RW-3
743.89
RW-4
744.42
RW-5
743.10
ENVIRONMENTAL SERVICES • ENGINEERING • TESTING
a
REFERENCE: CITGO PETROLEUM CORPORATION
DRAWING NUMBER 147-100-E
DATED 9/4/57.
REVISION DATED 3/22/91.
GROUNDWATER SURFACE MAP
CITGO PETROLEUM PRODUCTS TERMINAL
CHARLOTTE, NORTH CAROLINA
SCALE: 1 " = 150' DRAWN BY: CCK CHECKED BY:
�� JOB NO: 1264-90-295 . DATE. 07-08-96 FIGURE NO:

COLONIAL PIPELINE
PROPERTY
0
BDL
•7.,1
.02
LEGEND
MW-2
cie
CREEK
<1.0
C1..
1
RW-5� �
RW-
MW-21
1..11
COLONIAL PIPE LINE
L iAL iP A S
�x••••11.
MW-22
MW-28
<1.0
CHARLOTTE - MECKLENBURG
SCHOOL DISTRICT PROPERTY
OAD
® x�
MW-1704,2 R -2 TU 2: -1 MkMvW-.4111
RW-1
®MW-19
10
\y �
.� •tom
N
BELOW DETECTION LIMIT
APPROXIMATE LOCATION OF RECOVERY WELL
APPROXIMATE LOCATION OF EXISTING MONITORING WELL
BENZENE CONCENTRATION IN WELL IN ug/L (06-04-96)
ESTIMATED EXTENT OF DISSOLVED BENZENE PLUME
TOTAL BETX CONCENTRATION IN WELL IN ug/L (06-04-96)
ESTIMATED EXTENT OF DISSOLVED TOTAL BETX PLUME
MTBE CONCENTRATION IN WELL IN ug/L (06-04-96)
ESTIMATED EXTENT OF DISSOLVED MTBE PLUME
FREE PRODUCT IN WELL (Ft.) 06-03-94
ESTIMATED EXTENT OF FREE PRODUCT
M -12
MW-26
x�x •ND amok
MW-10�
`�• ` •� 110
•
MW-16
OIL/WATER
4._ ,7 / SEPARATOR. MW-4 N'
NDARY
�MW-2
r ik42
MW-1
MW-27
REFERENCE: CITG0 PETROLEUM CORPORATION
DRAWING NUMBER 147-100-E
DATED 9/4/57.
REVISION DATED 3/22/91.
FORMER UNDERGROUND
STORAGE TANK
90295PM.DWG
MW-29
ENVIRONMENTAL SERVICES • ENGINEERING • 1ESTING
PLUME MAP
CITGO - PETROLEUM PRODUCTS TERMINAL
CHARLOTTE, NORTH CAROLINA
SCALE
1" = 150' DRAWN BY: H.S./CCK CHECKED BY:
JOB N0: 12 64-90-295 DATE
07-09-96 FIGURE N0:

CARBON FILTER
COALESCING FILTER
PARTICULATE FILTER
COMPRESSOR
SAMPLE PORT
. .
PHOSter1 TANK • .• - •
R SCALE: NOT TO SCALE
§i CHECKED BY:
m
DRAWN BY: SB
▪ •
•
• - -
EXISTING CLASS 5P
SPARGE WELL
GROUND SURFACE
WATER TABLE
DAM 11-13-96
U
INJECTION DIAGRAM
CITGO PETROLEUM
CORPORATION
CHARLOTTE, NORTH CAROLINA
ENWROt'1ENTAL SERVICES
ENGIhEERINO • TESTING JOEI NO: 1254-90-295
FIGURE NO:
5

PHOSter
vapor phase nutrient stimulation
system for bioventing, bioreactors, in situ bioremediation
and other biotechnology applications
PHOSterT's is a patented gas -phase nutrient delivery system that can be used to control the
addition of vapor phase phosphorus and improve bioremediation processes. Phostercan be
easily and cost-effectively added to an existing biosparging or bioventing system to provide the
phosphorus that is often lacking for an optimally healthy microbial environment. In two field
scale tests, PHOSterT`i demonstrably improved the rate of biodegradation, and in one case by
as much as one order of magnitude. PhosterTM was developed by a team of researchers at the
Savannah River Technology Center, Oak Ridge National Laboratory and the Ecova
Corporation.. Compared to unproven and unsuccessful existing technology such as liquid
fertilizer delivery, PHOSterT`s provides improved control, improved simplicity of delivery
design, improved flexibility for customization to site needs, improved documentation of system
performance, and improved application of phosphorus feedstock. Traditional approaches for
adding PHOSter to sites are based on addition of liquid fertilizer or phosphoric acid vapors.
Such systems have been shown to influence very small areas and often result in overstimulating
a small area, resulting in undesirable effects like formation clogging.
The PHOSter system uses a relatively safe form of organic phosphate, triethylphosphate or
TEP. TEP is added to an air injection stream by contacting or infusing the vapors from the
liquid. With PhosterTm, the presence of the ethyl groups on the phosphate reduces the
nutrient's dissolution rate into water and provides a "time released" stimulation and prevents
clogging, and because the phosphorus is in a gas form it is more readily dispersed in the
formation. The Phosterrm has proven to be successful in two field site applications and is being
applied in a third. The enclosed information provides more details on Phoster, but do not
hesititate to contact one of the inventors, Brian Looney at [phone].
Enclosures:
General Description of Phoster
Phoster versus the Competition
Summary of Laboratory and Field Test Results
Patent Filed for Phoster
Published Field Test of Phoster
Material Safety Data Sheet for triethylphosphate

General Description of PHOSterTm
The PHOSterT`s system is a new process to control the addition of vapor phase
phosphorus to bioremediation (airsparging) systems, bioreactors, etc. Phosphorus is often
the limiting nutrient in such systems. As a result, a reliable system for adding this nutrient
in a controlled manner and in a form that will act relatively uniformly within the system is
a key element in both process control and in reducing the time needed to destroy
contaminants. For example, in a bioventing process, air is drawn through the soil at an oil
contaminated site. This stimulates aerobic bacteria to break down contaminants. The
PHOSterm' system allows a controlled amount of phosphorus to be added to the injection
air. This phosphorus injection method provides relatively precise control on the biomass
growth, allowing the engineer/scientist to maximize the oil degradation rate without
overstimulation of the microbial community. Traditional approaches for adding
phosphorus to sites are based on addition of aqueous phosphate (e.g., orthophosphate)
solutions to the ground surface or to wells. Such systems have been shown to influence
relatively small areas and often result in overstimulation, which can cause the formation to
become clogged with biomass. Addition of phosphoric acid has also been proposed as an
alternative, but this would also tend to overstimulate a small area because of the high
solubilitylionizability of the acid. Full scale process control and efficient utilization of the
phosphorus in phosphoric acid systems have also never been field demonstrated. The
PHOSter system uses controlled addition of a relatively safe form of organic
phosphorus (nominally triethyl phosphate, TEP) to the injected air. The TEP is added in a
contactor or by infusion pump at a rate that will not saturate the injected air (no
precipitation of TEP). Research conducted at the Department of Energy's Savannah
River Technology Center (SRTC) shows that PHOSterTm provide phosphorus in a form
that is readily available to the microorganisms. The presence of organic groups (ethyl
groups), however, reduces the nutrient's dissolution rate into water, and provides a more
uniform, "time released" stimulation. The PHOSter system was added to a full scale field
demonstration in which stimulation of indigenous methanotrophs resulted in broad scale
improvements of in situ destruction of chlorinated solvent contamination (trichloroethene)
in soil and groundwater. A second test at a bioventing site with BTEX contamination
resulted in an increase in the bioremediation rate by a factor of 5 in the first 40 hours of
operation, as measured by the increase of carbon dioxide respiration.
PHOSter Versus the Competition
The need for a reliable means of uniformly adding phosphorus to stimulate and control
bioremediation processes has been widely recognized. Prior to development of the
PHOSter process, only two competing processes had been proposed. The most common
approach uses solutions of orthophosphate applied to the ground surface or added to welts
as a liquid or as liquid droplets or aerosols (e.g. Lawes et al., U.S. Patent 4,749,491;
Raymond et al., U.S. Patent 3,846,290; and several other studies that are available in
published literature). An alternate approach using vapors from phophoric acid has been
proposed (Graves et al., U.S. Patent 5,171,491). The effectiveness of the liquid based

techniques is limited by the mobility of the orthophosphate in the soil and groundwater.
Several field studies have been completed using liquid phosphorus solution addition.
None of these field studies documented either successful controlled stimulation or clear
improvement in the bioremediation rate. In some cases, the high phosphorus near the
injection location overstimulated the community in a small area and plugged the formation.
The addition of vapor from phosphoric acid has been demonstrated at a small scale in the
laboratory. No field tests have been published, and in a press release from IT Corporation
(the owner of the Graves et al. patent that primarily addresses nitrogen addition), the
addition of phosphoric acid vapor is identified as "challenging" and use of this part of the
patent was "not recommended" for general application. The PHOSterTm system eliminates
or reduces many of the problems associated with phosphoric acid vapor (e.g., difficulty in
handling, only a small fraction of the phosphorus is available, extreme corrosivity, and
very high solubility that limits the mobility from the delivery point). Further, the
PHOSterTm system has been tested successfully in both the laboratory and at field sites. A
patent has been granted for PHOSterTM, and testing at sites in Michigan, New York and
South Carolina have been completed or is underway. The pros and cons of PhosterT'i
versus the competition are summarized in Table 1.
Table 1. PhosterT`3 versus competing Phosphorus Delivery Systems
Laboratory Studies
Successful
Field Application
Successful
Difficulty in adding
nutrient
Broad distribution of
nutrient
Potential for
overstimulation
Control and
documentation of
performance
Flexible Operation
Cost of Phosphorus
Utilization of
Phosphorus
Regulatory
Acceptability
Recommended for
general application
PHOSter System
Yes
yes
low to moderate
Yes
low
Simple controls and
quantitative
documentation
Yes
moderate
Excellent
Approved in 3 states
Yes
Acid Vapors
yes
no tests documented
moderate to high
Limited
moderate
"challenging"
Not Documented
low
low
possible but no field
data available
"no"
Nutrient Solution
yes
no (several attempts)
low
Limited
limited mobility
simple controls but has
not successfully
stimulate real site
Yes but has not
successfully stimulated
real site
low
Moderate
possible, but has not
been successfully
applied
not successful yet

SUMMARY OF LABORATORY AND
FIELD TEST RESULTS
Two full scale field tests of the PHOSterm' system have been completed in Michigan and
South Carolina, and an additional test is underway in New York. The following
information summarizes the laboratory and field results to date.
Under sponsorship of the United States Department of Energy's Office of Technology
Development, scientists and engineers completed a fourteen month field test of in situ
bioremediation of trichloroethene. One objective of the test was to stimulate contaminant
degradation by naturally occurring, indigenous microorganisms in the subsurface by
injection of gas phase nutrients. The demonstration utilized two horizontal wells to
deliver air and other nutrient gases to the subsurface and to extract contaminants.
The test successfully stimulated the microbial community and resulted in biological
contaminant breakdown. The deeper horizontal well at the site, approximately 300 feet
long and 150 feet deep, was used to inject air and other nutrient gases. This well was 30
to 40 feet below the water table surface. A second horizontal well, approximately 175
feet Long and 75 feet deep in the vadose zone, was used to extract residual contamination
in the vadose zone, extract material sparged from the water table, and to control the
distribution and migration of injected nutrient gases. The gaseous nutrients injected for
the test included oxygen (air), carbon (methane), nitrogen (nitrous oxide), and phosphorus
(triethylphosphate or TEP). The demonstration consisted of the following six operating
campaigns: 1) vacuum extraction from the upper well; 2) vacuum extraction with air
injection; 3) vacuum extraction with injection of air containing 1% methane; 4) vacuum
extraction with injection of air containing 4% methane; 5) vacuum extraction of air with
periodic pulses of methane, and 6) vacuum extraction with injection of air containing
added nitrogen and phosphorus with periodic pulses of methane. The underground
injection control permit (DOE, 1991) to perform various campaigns of gaseous nutrient
injection was submitted to the South Carolina Department of Health and Environmental
Control (SCDHEC) in April 1991 and approved in June 1991, representing the first
approved underground injection in the United States. Prior to initiation of each campaign,
a peer review panel convened to review the available data and provide final approval for
the next operating campaign. A test plan documenting the site background, the proposed
monitoring activities, the criteria for success, methods and quality assurance, the project
schedule, the organizational structure and funding, and the relevant permits, patents,
contracts and agreements was written and published in September 1991 (Hazen, 1991).
Note that this test site was contaminated with chlorinated solvents, necessitating the
addition of carbon to support the growth of the microbial community. Sites contaminated
with gasoline, oils, diesel and other -petroleum hydrocarbons would be stimulated by
adding (as needed) only oxygen, nitrogen, and/or phosphorus.
Throughout the test, a large amount of monitoring data was collected to evaluate
biodegradation. Key indicators included fluorescent antibody counts of known_

contaminant degrading organisms, DNA probes and chemical measurements to determine
the chemical expression of contaminant degrading enzymes, other measures of
microorganism numbers and types, chemical measurements (including measurements of
daughter products and breakdown products), and trichloroethylene mineralization analysis.
The TCE mineralization analyses proved to be a good indicator of the test performance
and correlated with the other measurements listed above. All of the data have been
documented in final reports that are available upon request. The mineralization test
method, laboratory data used to select volatile triethyl phosphate as the phosphorus
source, and the field results are described below to document the impact of the nutrient
injection final campaign.
A key measure during the field demonstration test was demonstration of carbon-14 Iabeled
TCE disappearance in microcosms (small sealed vials). Field samples were analyzed
within hours of collection and analyses continued for two days thereafter. In these
experiments, Iabeled TCE was injected into sealed tubes containing 10 mL of groundwater
sample and incubated for 48 hours. The radioactive and nonradioactive carbon dioxide
concentrations in the samples were determined using gas chromatography and gas
proportional counting, as described by Phelps et al., 1989. First, a laboratory study
demonstrating that gas phase TEP could be utilized by the microbial community in a
manner analogous to orthophosphate was performed. In this case, multiple TCE
mineralization tests were performed with various nutrients spiked into the vial. The
results are summarized in the following table:
Nutrient Added Summary of Effect on Mineralization Rate
range=0to 111
Methane + inorganic orthophosphate +-
methane + triethylphosphate 1 E 1
methane + nitrous oxide -i--1-
methane 0
plus signs were assigned to any value greater than methane
The data indicated that TEP stimulated and could be utilized by the contaminant degraders
in the microbial community. TEP was selected for gas phase nutrient injection based on
these results and the following properties: 1) TEP has a relatively high vapor pressure
which allows the TEP to be easily introduced into the injection gas, 2) TEP has a lower
toxicity and flammability than other organic phosphate compounds, 3) TEP is less soluble
and less corrosive and reactive than inorganic phosphoric acid resulting in the potential for
more uniform spread of the injected nutrient into the ground and reduced handling and
engineering problems, and 4) the presence of organic groups on the phosphorus provides
the possibility that the microbial stimulation will be more uniform (time released) because
of the need to convert the phosphorus to orthophosphate through biological removal of
the organic chains (similar to organic Iawn fertilizers).

The rate of TEP introduction is limited by its vapor pressure. For this test, the rate was
well below the theoretical limit based on optimizing the carbon:nitrogen:phosphorus ratio
(for sites where gasoline and oils are present in the ground, growth rate estimates would
be used to select phosphorus addition needs). A gas concentration of 0.007% TEP was
selected at an air flow rate of 200 SCFM. This was equivalent to approximately 1.06
gallons per day. A total of 100 gallons of TEP was injected over 93 days. The TCE
mineralization results collected during the field demonstration suggest that the TEP
injection performed as expected. Prior to addition of phosphorus, the sitewide
mineralization rates ranged from 0 to 3% with and average of approximately 2.5%.
During addition of TEP, the sitewide 48 hour mineralization rates increased and ranged
from 3% to 26% with a mean of 15%. Upon addition of the TEP, the concentration of
chlorinated solvents in most of the wells monitoring soil gas concentration above the
water table dropped substantially and rapidly. Such a sudden and dramatic change in these
concentrations had not been observed in any other campaign of the test over the previous
11 months. The mineralization results suggest that the phosphorus is stimulating
contaminant degrading organisms in the groundwater, while the concentration changes
above the water table indicate that the added phosphorus is impacting a relatively large
zone, including passing through the 30 to 40 feet of water -saturated sands into the vadose
zone.
The second test involved a bioventing/biosparging field demonstration conducted over a
ten month period at a former glycol dehydrator site in Michigan. The chemicals of interest
at this site were benzene, toluene, ethylbenzene, xylenes and alkanes (primarily C4 to CO.
Three different air sparging operation modes (pulsed, continuous, and offgas recycle) were
tested. Nitrous oxide and TEP were also injected under the same test. Respirometry data
show that PHOSterT''s increased the biodegradation rate by an order of magnitude in a
matter of days as shown by the increase in kinetic degradation rates in Table 2. (Please see
the enclosed paper SPE 29753 for more details). One will also note that in every instance
the biodegradation rate was slowly decreasing before the addition of PHOSterTM and in a
short time after adding PHOSterT''s the biodegradation rate increased dramatically, for
both the saturated and unsaturated zones.
Data on the use of PHOSterrm in New York is not available yet, but PHOSter has been
accepted the regulators there.

Table 2. Biokinetic Rates Based on Carbon Dioxide Respirometry at the Michigan
PHOSterm Test Site.
Unsaturated Zone
Date
Biodegradation Rate (mg/Kg/day)
October 5-13, 1993
3.65
October 18-25, 1993
0.65
December 13-26, 1993
0.21
January 29 - February 4, 1994
***
5.92
April 18-26, 1994
1.22
June 27 - July 4, 1994
0.28
November 7-21, 1994 ***
4.28
Saturated Zone
Date
Biodegradation Rate (mg/Kg/day)
October 5-12, 1993
0.07
October 18-24, 1993
0.007
December 13-19, 1993
0.032
January 29 - April 4, 1994 ***
0.43
April 18-26, 1994
0.02
June 27 - July 4, 1994
0.012
November 7-21, 1994 ***
0.42
*** System was operating with the PHOSterT`s process.
References
DOE, 1991. Modification to SC UIC Permit #I03. Westinghouse Savannah River
Company, Aiken SC 29808. Document Number WSRC-RP-91-354.
Hazen, T. C., 1991, Test Plan for In Situ Bioremediation Demonstration of the Savannah
River Site Integrated Demonstation Project DOE/OTD TTP #SR 0566-01. WSRC, Aiken
SC 29808. Document Number WSRC-RD-91-23.
Phelps, T. J., D. Ringelberg, D. Hedrick, J. Davis, C. B. Fliermans, and D. C. White,
1989. Microbial biomass and activities associated with subsurface environments
contaminated with chlorinated hydrocarbons, J. GeomicrobioIogy, 6:157-170.

October 9, 1996
Dr. Luanne Williams
NCDEHNR
Occupational and Environmental Epidemiology Section
Post Office Box 29601
Raleigh, North Carolina 27626-0601
Subject:
Dear Dr. Williams
TRIETHYLPHOSPHATE INJECTION
CITGO Petroleum Corporation
Charlotte, North Carolina
S&ME Project 1264-90-295
In response to your request, we are including additional information regarding gaseous
phase triethylphosphate injection (TEP) at the CITGO Petroleum Corporation facility in
Charlotte, North Carolina. As you already discussed with Mr. Scott Eaton, we plan to test
the applicability of TEP injection to increase natural biorespiration of petroleum
hydrocarbons. We have included a copy of a Material Safety Data Sheet (MSDS) for
TEP which should contain most of the requested information. Included below are
responses to each of the items contained in your facsimile transmission to Mr. Scott
Eaton on October 4, 1996.
GENERAL REQUIRED INFORMATION
The manufacturer name, address, phone number are included at the top of
the MSDS sheet.
2. The Division of Environmental Management contact person for this site is
Mr. Gil Butler located at the Mooresville, North Carolina. Regional Office.
[phone]
S&ME, Inc, 155 Tradd Street, Spartanburg, South C'orolino 29301, [phone], Fax [phone]
Greenvdle, South CaroCiio, [phone]

Triethylphosphate Injection S&ME Project 1264-90-295
CITGO Petroleum Corporation October 1996
3. The site contact person for CITGO Petroleum Corporation is:
Mr. Scott Eaton
CITGO Petroleum Corporation
Post Office Box 47427
Doraville, Georgia 30362
[phone]
4. The contractor and contact for the project is:
David E. Klemm
S&ME, Inc.
155 Tradd Street
Spartanburg, South Carolina 29301
[phone]
5. There are no identified groundwater supply wells within 1500 feet of the
site. The Paw Creek area of Charlotte is a relatively industrialized area of
the city and pubic water supply is available to the site and surrounding area.
6. The source of the contaminant was a subsurface line from a bulk storage
tank to the site vapor recovery unit. The product spilled was gasoline.
7. The nearest surface body of water is an unnamed intermittent tributary to
Gum Branch. This intermittent stream appears to be a groundwater
recharge area (losing stream) which apparently inhibited the free product
plume from further migration. The only contaminant detected in the stream
is low concentrations of MTBE. The location of the stream relative to the
plume is shown on Figure 1.
REQUIRED PRODUCT SPECIFIC INFORMATION
1. Not applicable.
2. TEP is a compound in itself. The chemical composition of TEP is
(C2H5)3PO4 . Ambient air will be passed over the TEP which will evaporate
according to its vapor pressure. The TEP will then be injected in a gaseous
state at approximately 70 ppm by volume. The only ingredients of the
injection will be limited to ambient air and TEP. The air will provide a
2

Triethylphosphate injection S&ME Project 1264-90-295
CITGO Petroleum Corporation October 1996
nitrogen and oxygen source to indigenous microorganisms, as well act as the
"carrier gas" for the TEP. The TEP provides a phosphorous source nutrient for the
indigenous microorganisms.
3. Not applicable.
4. Not applicable.
5. The by-products of degraded hydrocarbons are carbon dioxide and water.
6. The degradation by-products of TEP are carbon dioxide, water, and
phosphates. The ethyl groups of the TEP are bio-degradable and will be
reduced to CO2 and water. The phosphates will be incorporated into
biomass which essentially is immobile. There is little migratory potential
associated with gaseous phase injection of TEP.
7. The bioremediation process can best be described as low volume bio-
venting. An existing air sparging system will be utilized for the injection.
Currently, ambient air is being injected approximately 10 feet below the
saturated zone. The primary mechanism of remediation is volatilization,
transport to the vadose zone, extraction via a soil vapor extraction system,
and treatment utilizing a catalytic oxidizer unit. Since elimination of free
product from the air sparging area, it is planned to utilize TEP injection to
stimulate natural degradation of the hydrocarbons in the subsurface.
Addition of TEP requires only a simple modification to the existing air
sparging system. Since the mechanism of remediation is being modified
from a volatilization/extraction/off gas treatment system to a subsurface bio-
remediation system, air injection rates will be reduced and soil vapor
extraction will be terminated. Vadose zone monitoring points will be utilized
to monitor the vertical depletion of soil oxygen content and soil gas TEP
content. Monitoring wells screened across the saturated zone will be used
to measure oxygen depletion with time. The oxygen depletion rates will be
used to calculate the hydrocarbon degradation potential. The actual TEP
injection concentration is limited by the vapor pressure of TEP. The
estimated injection concentration will be 70 ppm by volume. Sampling ports
prior to well injection will be used to monitor the concentration of TEP in the
air stream. Initially, TEP injection will be performed on a continuous basis.
Once monitoring indicates optimum respiration rates have been achieved,
the TEP injection will be controlled by valves at the TEP contactor tank.
8. Animal toxicity data is included on the MSDS sheet.
3

Triethylphosphate Injection S&ME Project 1264-90-295
CITGO Petroleum Corporation October 1996
Enclosed are three additional documents for your review. The first includes a general
description of TEP injection (PHOSterTM) and results from two field tests. The second
document is the test results from the TEP injection performed at the CITGO facility in
Panama City, Florida. The final report is the proposed Corrective Action Modification for
the CITGO Charlotte, North Carolina facility.
Our initial respirometry testing at the facility has indicated that natural bio-respiration rates
are depressed. We are anxious to test TEP injection to stimulate natural biodegradation
at this site. We look forward to your response to this proposal. Should you have any
questions or need additional information, do not hesitate to contact us at [phone].
Sincerely,
S&ME, Inc.
H41'
gRe
e®`ItEBBB6Bpu
®q,: t- CARS, o04„,
q� �Nseo,'
SEAL
7
1228
David E. Klemm, P.CW,
Project Manager %, f
o�o�ad E. \4,�a
Be"aaooaaaaoa °4
Stan Lummus, P.E.
Seni Environmental Engineer.
cc: Mr. Scott Eaton
CITGO Petroleum Corp. without enclosures
4

Ltly
FROM : RCS CORPORA`iON
PHONE N0. : Oct. 04 1996 03:55PM P2
1il ••H�
MILES
ECESSegetOrMaseliMillielfaSISCOMIla
TRANSPORTATION EMERGENCY
CALL CHEHIREC: 300-424-030G
DISTRICT OF COLUMBIA: 202-483-7616
wr
I. PRODUCT IDENTIFICATION:
PR05UCT NAME........:
PRODUCT CODE........:
CifENICAY.
CHEMICAL NAME •
SYNONYh'S •
CAS NUMBER.-.. ..... •:
FORMULA.. ... ....
rfAFETv DATA SHEETl
HILES I9c_
[NDUSTRIAL CHEMICALS DIVISION
Mebar 'Road
Pittsburgh, PA 15205-9741
NON -TRANSPORTATION
MILE; EMERGENCY PHONE...: [phone]
MILES, INFORMATION PhONE. ; (100) • 662-2927
Triethyl Phasph.te
V608
Organic Phosphate
Phosphoric Acid. Trietiyl Ester
TSP
78-40-0
(Cz}i5) 3Po4
Y:.
HAZARDOUS INGREDIENTS;
M.
I', GRZDI :.NT NAME
/CAS NUMBER EXPOSURE LIMITS
TrLethyl Phosphate
78-40-O OSHA : Not Established
AGGIH: Net Established
r..
III. PHYSICAL PROPERTIES:
CONCENTRATION (71)
Essentially 100 X
PmyercAL FnzK , Liquir1
COLOR... ' Colorless
mop, --- • ..: Pleasant eider-Illtio Oder (oP estar) -
MOLECULAR WEXONT : 1o2.1S
pN • Ncue=al
soiLING POYNT 419 F C21 C} @ 1013 mbar
176 F (20 e) 5 5 Mhar
SEI.TING/FREEZING ?MT..: -69 F (-$6 C)
v;scoSr i Y • (Dynamic); 1.7 mPas• R 69 F (20 C)
•SOLUBILITY IN WATER :•......• : Soluble
SOLUBTLITY7(N0N AQUEOUS).:.: S4lubto in aUkar; benzene.
Organic solvents
SPEr^IC GR.'�VITY .."... 1.07 4 aa•. F' (20' C)
BULK:DENaIYI'..........,.......: het, APplica:'le ..
Product Ccdoa V6OS,
Approval date: 07/29/92
with decomposition;
alnekol, end Mani
NOS Pasa.1
Continued on next page

Vl.l i.��7o �a•v-r
FRC; : RCS CORPORATION PriCNE NO. :
Oct. PA 1956 03:56FM P3
uu.i
PHYSICAL PROPERTIES (Continued)
VAPOR PRESSURE • 0.1 mbar @ 65 F (20 C)
% O; DENSITY 6.28 (Air = 1)
IV. FXAr AlID EXPLOSION DATA:
...� �� W........ .....
FLASH POINT ' 266 F (130 C): DIN 61376.
AUTO—IGNI7IoN TEXPERATUR6 896 F (40 C); DIN 5179+4.
EXTIHOUISHINC MBDIA....... ...,i.: Water; Carbon Dioxide; Dry ChemioaL; Foam;
Re.lon; Watsr ¢pray for Large fires.
SPECIAL FIRE empr MG ?.00EDURRS: Firefighters should be equipped with
b�SI—contained breathing apparatus co protect against potentially toxic and
irritztir g fumes.
V . HUMAN REALM DATA:
ROUTE(S) OF ENTRY.......: Eye Contact; Skin. Contact; Inhalation; Ingestion
HUMAN EFFECTS A SYMPTOMS OF OVzREJPOSUR.;
ACUTE SFFECTS OF EXPOSURE...,.: C:t the basis oe animal toxicity data (ee
S .ri r xII), we would ekpect this product to be irritating to the eyes and
skin. Symptoms may include redness, icohing, swelling and pain. We uo.i:d
also expect this product to be moderately toxic by ingestion. Symptoms of
ingestion are unknown.
CHRONIC EFFECTS OF EXPOSURE..,; Prolonged or repe,tod exposure may dry and
defat the skin producing irritation and dermatitis. Prolonged or repeated
contact with the eyes may cause oenjunctivits,
CARCINOGENICITY... ; This prodt:ct is mot listed by NTP, IARC or
tregulatnd as a carcinogen by OSHA.
MMICAL CONtITIONS
AGGRAVATED BY EXPOSURE. : Persona with preexisting eye, Skin dX
resplrc.tory tract Go;iditions be more susceptible to the affects cf this
product.
YI. EXERGEHGY gum FYRsi AID PROCEDURES:
rIAST AID 70R EYES._ • Ia cede of contact, immediately flush eye: vith
plenty of cuter for at leant 15 minutes. Call a physician if irritation
pereistr.
Product Code; V6O$ HSDS Page 2
Appravai dnt:c: 07/29192 GyntAnvcd aft next pa3,e

FROM : RCS CORPORATION
PHONE NO, :
Oct, 04 1996 03:57PM P4
.w.i u u a
V. FIRST AID PROCEDURES (Continued)
FIRST AID FOR SKrN..... acao oGecmedical flush
nClskin
n withrrikrty.of water.
Remove canta�n:n.aced clothing.
persists. Wash cloning before reuse.
FIRST AID rOR INHALATION: If inhaled, remove to fresh a:r• Ifnot
obreathinG it
c• respiration, If breathing is difficult. give
give arti.sCial .esF
a physlcien. Bail a physician.
FIRST �ZD FOR xNGESTr4N.i i swallowed, immediately
VIi_ EKPLOYE; PROTECTION RECOMMENDATIONS:
RMrH----lr,
Elf£ PROTECTION REQUIREMENTS........: Protective goggles are recommended'
sKIK rROTECTION REQLTIREHEN75...., , .: Permeation resistant gloves and eLothing
are recommended to minimize SiCin contact.
approved respirator doe
RESPIRATOR REQuiREKEN''5...
organic vapor is recommended. roees9
veNTIT.ATIOK REQUIREMENTS • Use local exhaust vonti,lation at p
equipment, especially ii material is heated.
ADDITIONAL PROY�CTIVE, HEASUAES • Emareency showers and eye wash stations
Should be available, TraidA
t emhitisasr hay,dsthe
andsafe
use
beForeandling saCia$,of this
product. Emp1eyens slo
drinking, or using tobacco pVodtjcts.
r
VIII. REACTIVITY
..... ......
r--..r-r.+..•+mow--
STABILITY • under normal conditions of use and storage, this
prodtieL is stable.
HAZARDOUS POLYSERZZATIRN...s Will not ooQur.
INCOMP T1BILIT/ES.,.,,..•..: react violently if in contact with oxidizing
materials, one known,
CONDST=ONS ' h
DECOKPOSI'fICN TEX°ERATJRE,. ENo ar decobon mposition
de, taho= %Agedrbon az iroeted. o£
ngcoHpoglriON gROpvcrS • otar►ii.ally tex:e.fumCs•.
phosphorous and other p
..
IX, SPILL AND LEAF PROCEDURESs^___--r----
—.I rr'--r1----
Utilize protective clothing and equipment.
SPaLi. OR LEAK tAclPRObe talon s with suitable absorbent and plaoad ih ear►tsinera.
Spills should be taken up
Still area- cars. be uashad xith.water, Collettwash later for approved
disposal.
WASTE DISPOSAL ?(ZTOD • Waste- disposal. should., be•. in aGCaxdaAGe with
existing. federal, state and focal envi rondenLal 'regulations..
Product Coda: V6OS
Approval dace: 07'29/92
MSS Page 3
Cvnt[nued on next page

OCT. i . _9% .1 : kmH'1
FROM : RCS CORPORATION
t ,
I..ILV LIlY 1L'..i. .��.�•••
PHONE NO.
Oct. E4 19% 33:50PM P5
-------_..FA.G.�,l�tto.. ^
ll5 ix STORAGE D..TA: _.-_--..„._--...r--
X SPECIAL. _- _--_„-_ .�k---r--
GS TIM.P_RATHRE(HTNIKAX): A..mb1`nth6Z?rP�(50 C)aonCaano:.
5HEL _ ..2 months SHELF LIFE ...,..+�.......•..: Nome known.
ctoscd• Store in a dry,
5PNgSHANDLING/STORAGE PRECAUTIONS! -A^ original io td. Ssimilat Store
rod`-
40019aue,ay excess vecheat,nin origi tightly void attr roo!
cool Pners . Y mere immediately after use. & store
ssary
contact. 1 Reseal cm t8 S£ heated, Provide ventil.at.ion•
GantacL. p�etoct f:�aeo freezing.
avay from Food and beverages,
......... ^_r__w_N'•+w-••-rrrw
XI.- SHIPPING INFORMATION: .......... --`
Tel -ethyl Phosphate
TECHNICAL SHIPPING KA} E. - ....: Chemicals, NOT
FREIGHT CLASS 13L' !�...... Chemicals, �`iO1 (;ItfFC $OQ00}
FREIGHT CLASS FAfl+AGK• . , . • • • . • . Te iethyi Phosphate
FRGDVCT La4.8Ei... ...... , ........ .
DOT (t;K-181)
PROPER SKIPPING NAME ..... Nene
..; _Regutatad
HA%ARD CLASS 0R DIVISION •..•.
i1S0 / IKDO CODE
PROPER SHIPPING
......
HAZARD CLASS D-
yI QHNUMBER.
. ; .tone
Noe-Resulated
IC.0.O / IATA
PROM SHIPPING NAHE. r • • , , ..... • None Noh^Reg,�:atad
HAZARD CLASS DIVISIOK liiii{ EFti ..:
;t ANT AL TOXICITY DATA: ___---r..r+.r_..__.
A Y I _�..w-.r....w r rw-+...r--•--+..rr._-�.w.... _r-r••---r--
ACUTE TOXICITY 1310 mg/kg tRac� (1)
ORjL t.D5O...,....••. of establishes. for pC 7uGt.
DERK,�L LbSa........ Data n hours).
8.82 mg/1 (Rat, 2 (2)
IC�iiA:.+ LCSO. • .- Moderately irritating Le rabbit eyes.
EYE EFFECTS,....,..: to rwbbit skin (4• hts.) • (2)
lion-iyt•iCaCiL1g' •:r.
Slightly irritating --to guinea pig skin. (3)
Product Coda: V668
approval. date; 07/29/ 92
MSAS •Page 4
Continued ow text'papa .. _..

UW f . 177o : a . r.J.Jn r
FROM ; RCS CORPORATION
P
••
•
PHDNE NO. : Oct. 04 1996 03:58PM P5
eOoe
xtt. ANteAL TOXICITY DATA (Continued)
nNSzrI2A7zary pane not esCabiLshed for product,
CHn0NIC TOXiCTTY...,..: Adverse effects of Eho reprodur.rive system vere
reported trot a study of chronically fed male rats. aduerse effects on the
newborn were. observed in a Study of female rats cod prier to mat;r,g and during
pregnancy. (3)
OTHER TOXICITY D&tA.,.1 i.: rat studies. 400 mg/kg (intraperitoneel injection)
far 37 days caused peritonea/ irritation, ascite.s, anesthesia, with no
paralysis. Inhalation of 28,000 ppm (6h) (Rat:) cauccd wcaknoaa, gasping
respiration, and dtath. Early symptoms of cholinesterase inhibition were also
seen. (4)
AQUATIC TOXICITY... ■ ..: Golden orfe (Leuciscip idu.) ; LCo = 1000 mg/1. (5)
i Chemicat :-lazsrd :hformation Profiles (CH1vs1, craft report, Oak Ridge
Laboratory.
2 Teats at the Institute for Toxicology, Bayer AG
3 Occupational Health Serviees (DES) Materiel Safety Data, Sheet.
4 patty's Industrial Hygiene and Toxicology.
5 T,ats carried out in the biological le.bvrataries eE the Environmental
Protection Department, Bayer AC.
FEDERAL REGUL.A:M INFORMATION:
M.
OS!.L* STATUS_ • This product is hazardous under the criteria of
the Federal OSHA hazard Communication Standard 29
CFR 1910.1200.
TSCA STATUS , .. , On ?SCA Inventory
CMCLA RCPORTABLE QUANTITY..; Nana.
SARA TITLE III;
SECTION 302 ZXTREFILY
HAZARDOUS SUBSTANCES..: Bone.
SECTION 31.1/312
HAZARD CATEGORIES • Immediate Health hazard; Delayed Health hazard
SECT/ON 31S
TOXIC C}ENICALS.......; ,done.
RCRA STATUS ... If discarded in its purchased foray, this produet
would not be s hazardous waste either by listing
or by chars.cteristio. However. undot•. RCRA, a is
the rocponsib:l.ity of the product user to
determine at the time of disposal, whether a
material ,,Maiming the product or derived from
the product should be, c),assiEied as a hazardouS
blasts. (40 CFR 261.20-24)
F rodsc t Coda; V608 MSOS Page 5
Approval date: 07/29/P2 Continued on next page

OCT. 7.1996 a:49PM C1T(U Jiv lLLr1 r•�•
FROM : RCS CORPORATION
• .
PHONE NO.
Oct. 04 1996 03:59PM P7
ATV.
OTHER RE6ULAY0RY INPORKATIONs
The following ehemica.s
product spetifie health
b• appiioable for state
requirements you 'should
COMPONENT i NAME
/CAS NUMBER
fir_ .
rY
are specifically listed by individual states: other
and .5aft:y darn in other oect=.onc oe the MSDS may 4.'
re
requirements. Fo: details. on your regulatory
contact the a7nropriste agency in your state.
Triotktyl phosphate
7B-40-0
CONCENTRATION , SIA'E CODE
Essontialiy 100 : PA.S, NA
NJ4 New Jersey Other — included in 5 predominant ingredients > 1L
PA3 = PennsyLVartiia Non'laazardous present at 3% or greater..
CAi.IFORHYA PROPOSITION 65
To ttLo hest of our knowledge,
othEs CaliFarrtitiakhas�£aalid to causeLevels
caneersthirth
substances, which the state f
Aof.nets or. other reproductive effects.
MASSACNUSRTT'S SUBSTANCE LIST (1'cSL) HgZaxdarss Substrzriors, on the tiSL
Hazardous Substances and Extraordinarily
ravat h• identi.fied when present in products, To the bast of cur knowledge,
this product contains no substances at a Level .rhLch could tequire reporting
under the statute.
xv, APPROVALS:
,,,,,; Revise Sections III, V, VIII and XI.
REASON FOR ISSUE�, P . Kelly
PcZF ARID 9Y
APPROVED BY • D. R. keket tern.
APPROVAL tA7E.. • 07/29/92
SUPERSEDES DATE 01/14/92
MOS NUMBER ...... .z 02674
amassed or implied, except
This information L. furnished wit heuC warrar.C7, oxp.
that it is accurate' to the. best knowledge of Kites roc. The
ldata. Oh thi$ 11sheet
relates only to the specific material designated herein.
assues AO
legal casponsibility for use or reliance upon these data.
Product —Ceder v608 •
• Apii'ovel...date: 07/29/92'
n515 Page 6
Last' ;age'

State of North Carolina
Department of Environment,
Health and Natural Resources
Division of Epidemiology
James B. Hunt, Jr., Governor
Jonathan B. Howes, Secretary
Michael Moser, M.D., M.P.H.
October 29, 1996
Mr. Gil Butler
Mooresville Regional Office
919 North Main Street
Mooresvilie, North Carolina 28115
Dear Mr. Butler:
F fA
IDEHNR
NOV - 2
I am writing in response to a request from Mr. Stanford Lummus with S&ME for a health
evaluation regarding the use of the Miles, Inc. Product triethylphosphate on the subsurface soil
at the Citgo Petroleum Corporation site in Paw Creek in Mecklenburg County. Based upon my
review of the product and process information submitted by S&ME, I offer the following
evaluation.
In order to safely use this product, the workers applying the product should be informed
of the following precautions in addition to the precautions mentioned on the MSDS sheets:
WORKER PRECAUTIONS DURING APPLICATION OF PRODUCT
1. If the product is released into the environment in a way that should result in a
suspension of fine solid or liquid particles (e.g., grinding, blending, vigorous shaking or
mixing, or opening of a container whose internal pressures may be different from
ambient pressures), then proper respiratory protection should be worn. The application
process should be reviewed by an industrial hygienist to ensure that the most
appropriate respiratory equipment is worn if necessary
2. Persons working with this product should wear goggles or a face shield, gloves, and
protective clothing. Face and body protection should be used for anticipated splashes
or sprays. In order to prevent contamination of the worker's home and other work
areas, the gloves and protective clothing should only be worn in the application area and
should never be taken home.
3. Eating, drinking, smoking, handling contact lenses, and applying cosmetics should not
be permitted in the application area during or immediately following application.
4. Workers should wash their hands after applying the product.
P.O. Box 27687, Raleigh,
North Carolina 2761 1-7687
� An Equal Opportunity Affirmative Action Employer
50% recycled/10% post -consumer paper

Mr. Gil Butler
October 29, 1996
Page Two
OTHER PRECAUTIONS
1. According to the October 9 letter submitted by Mr. Stanford Lummus from S&ME, no
private wells were identified within 1500 feet of the area of application and public water
supply is available to the area. Contrary to the letter prepared by S&ME
triethylphosphate is expected to have very high to high mobility in soil and
biodegradation in either soil or water is not a major fate process for this compound
(Hazardous Substances Data Bank CD-ROM 1996). In order to prevent contamination
of nearby private wells, a buffer of at least 1500 feet should be placed between the area
of application and private wells. In addition, the area of application should be
downgradient from private wells, if possible, in order to prevent contamination from the
application area to the nearby wells.
2. According to Mr. Lummus and report submitted, an intermittent tributary to Gum Branch
is located adjacent to the application site. It is recommended to evaluate the migration
of triethylphosphate following injection to this nearby stream to ensure no exceedances
of North Carolina water quality standards.
3. Triethylphosphate is moderately toxic so 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.
If you have any questions, please do not hesitate to call me at [phone].
Sincerely,
iLetAume 71". 6/<j_le,e2./77x4/
Luanne K. Williams, Pharm.D., Toxicologist
Medical Evaluation and Risk Assessment Branch
Occupational and Environmental Epidemiology Section
LKW:Ip
Enclosure
cc: Mr. Bill Pate, Medical Evaluation and Risk Assessment Branch
Ms. Linda Blalock, Groundwater Section
Mr. Brian Wagner, Groundwater Section
Mr. David E. Klemm, S&ME
Mr. Stanford Lummus, S&ME
Mr. Scott Eaton, Citgo Petroleum Corporation

Synesis Environmental, Inc.
955 Colony Parkway
Aiken, SC 29303
Phone: [phone]
Fax: [phone]
November 12, 1996
Dr. Luanne K. Williams
North Carolina Department of Environment
Health and Natural Resources
P.O. Box 27687
Raleigh, NC 27611-7687
RE: Biodegradation of Triethylphosphate
Dear Dr. Williams:
I am writing this letter in response to your October 29, 1996 letter to Mr. Gil Butler of the
Mooresville Regional Office. I work as a bioremediation consultant to CITGO Petroleum
Corporation through S&ME. Inc. You may recall that CITGO Petroleum Corporation and
SinIE have proposed injection of vapor phase triethylphospate (TEP) to enhance in situ
bioremediation of petroleum hydrocarbons at CITGO's Charlotte Distribution Terminal.
Mr. Butler evidently requested that you review the proposed injection of TEP. We
appreciate the time that you took to develop health and safety recommendations for
handling and application of TEP. However, we would like to provide evidence that
suggests that biodegradation in either soil or water is a major fate process for TEP, which
is contrary to what you discovered on the Hazardous Substance Data Bank CD-ROM
(1996). There is published literature that strongly suggests that TEP is biodegraded in soil
and groundwater.
For example, Michel er al. 11986) specifically discusses TEP and the microbiological
mechanisms for liberation of phosphate during aqueous bioreactions. That work was
based on earlier work performed by Wolfendem and Spence (1967) who reported on
aqueous biodegradation of alkyl phosphates - TEP is an alkyl phosphate. Additional work
by Bennett and Kofsky (1985) and Fiedler er al (1974) additional supporting data that
TEP is biodegraded. As an example of a field evidence, Shamory et al (1995) reported an
order -of -magnitude increase in subsurface petroleum biodegradation rates after injection
of TEP at a site in Traverse City, Michigan. This strongly suggests that the TEP is
utilized in bioreactions. The injection of vapor phase TEP has been proposed at the
Charlotte facility based on a recently granted patent for TEP enhanced in situ
bioremediation.

Synesis Environmental, Inc.
955 Colony Parkway
Aiken. SC 29803
Phone: [phone]
Fax: [phone]
This information strongly supports that TEP is utilized in subsurface microbial reactions.
As a result, the potential for human or ecological exposure to TEP from subsurface vapor
phase injection is minimal.
We thank you for your time associated with this matter and hope that you will take
consider this information. If you have any questions. please do not hesitate to contact me.
Sincereelly,
ohn S. Haselow, PhD, PE
REFERENCES
Bennett. J.W., and S. Kofsky. 1985. Comparison of two defined media for inhibitor and
incorporation studies of aflatoxin biosynthesis, Dev. Ind. Microbiol., 26, 479-486.
Fiedler. H.J., H. Mai. and W. Seyfarth, 1974. Suitability of covalent P-N Compounds as
nutrient for Aspergillus niger. Zentl Bakeriol Parasiteikd, Internationskr. Hyg., 129.313-
326.
Michel, L.J., L.E. Macaskie. and A.C.R. Dean, 1986. Cadmium accumulation of
immobilized cells of a Citrobactor sp. using various phosphate donors, Biotech. Bioeng.,
28. 1358-1365.
Shamory, B.D., A.W. Lawrence, D.L. Miller, J.A. Miller. R.L. Weightman. R.M. Raetz,
T.D. Hayes. 1995. In Situ Bioremediation of a Former Natural Gas Dehydrator Site
Csing Bioventing/Biosparging, Society of Petroleum Engineers Paper 29753.
Wolfenden, R. and G. Spence, 1967. Biochim., Biophys. Acta, 132, 296.
CC: Gil Butler, NCDEHNR
Scott Eaton, CITGO Petroleum Corporation
David Klemm, S&ME. Inc. ✓