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NCG510110_Regional Office Historical File Pre 2018 (2)
Michael F. Ea.s.ley, Governor William G. Ross Jr.. Se,cretary North CaroItna Departmeni of Environment and Natural Resources Alan 'W. Klimek, P. E. Director Division of Water Quality Coker, H. Sullins, Deputy Director Division of Water Quality May 5, 2004. Ms. Debbie Sailors Petroleum World, Inc. 681 NC Highway 120 Mooreshoro, NC 2811.4 Subject: Rescission of NPDES General Permits Permit Numbers NCG510019, NCG510356 & NCG510311 Petroleum World_Inc„ Sites Bob's Superette, G&J Foodway and Banoak Food sites Catawba & Lincoln Counties Dear Ms. Sailors: Reference is made to the recent requests for rescission of the subject NPDES General Permits that were submitted on your behalf by Shield Engineering, Inc. The letters state groundwater remediation activities have ceased at the subject. sites and therefore they no longer require coverage under the general permit, in. accordance with your requests, NPDES General Permits NCG5110019, NCG510356 & NCG5103I 1 are rescinded, effective immediately. Please he advised that these permit rescissions are based wholly upon your statement that the activities which would require general perrnit coverage. at the sites have ceased or been eliminated. Division staff has not visited. the sites to obtain independent verification. Operating a treatment facility, discharging wastewater or discharging specific t)pes of stormwater to waters of the State without a valid NPDES penultwill subject the responsible party to a civil penalty of up to $25,000 per day. Enforcement action will be certain for persons that have voluntarily relinquished permit coverage when, in fact, continuing permit coverage was necessary. If, in retrospect,you feel the site still .requires permit coverage, you should notify this office immediately. Furthermore, if in the future you wish to again discharge to the Stales surface waters, you must first apply for and receive a new NPDES .permit, If you .have questions about this matter, please contact Bob Sledge at (919) .xtension 547 or the Water Quality staff in our .Mooresville Regional Office at (704) 663-.1699, Sincerely, Alan W, Klimek, P.E. cc: Mooresville Regional Office w/attach nts Stormwater & General Permits Unit Point Source Compliance — Bob Sledge w/attachments Central Files - w/attachments Fran McPherson, DWQ Budget Office WAT 'T. OF EN Nit:lilt TURN,. 94ililOURCES SV' - OFFICE :11 MAY 1 1 2004 Division of Water (919)733-7015 uahtv 1617 Mail Service, Center Fa. (919)733-96.12 Raleigh, ,NC 27699-.1617 Customer Service 1 877 623-.7748 ENGINEERING, INC. April 23, 2004 Ms, Fran McPherson Annual Administering and Compliance Fee Coordinator Division of Water Quality North Carolina Department of Environment and Natural Resources 1617 Mail Service Center Raleigh, North Carolina 27699-1617 Subject: Annual. Permit Fee and Request for Permit Recision NPDES Permit No. NCG510019 ob's Superette GWI Number #5117 Shield Project 1950069 Dear Ms, McPherson: On behalf of Petroleum World, Inc. (PWI), Shield Engineering.. Inc. (Shield) submits this letter informing you that PWI will not be renewing the NPDES permit for the subject site, and requests that this permit be rescinded. This project received a No Further Action from the North Carolina Department of -Environment and Natural Resources. Division of Waste Management on December 18,, 2002. The treatment system is no longer in use and has been permanently removed from the site, A copy of the renewal invoice and No Further Action Letter is attached. Sincerely, SHIELD ENG. RJ,NG, INC Michael D. Armour, P,G. Principal Registered, North Carolina # 1209 Attachments Field Services Manager cc: Debbie Sailors, Petroleum World, Inc., Mooresboro, NC Taggar7 Cry )11e. NC 2620E cts I 9951.95O069LETTERS`=4-23-04 NPDES Rescind Leltes.doc k+Gvv+v.shieldengTneeranq.cam Telephone 704.394.6973 Fax 704.394.6968 tifa Department gent and tural Resources ion of \,Vasie Management F. E3; G. RoqqDex t R;. t alTheu. Direeeor i s28 i k,s ail0s received the of etG'8t' recelzre t ". No Fe Bob's Superette 4311 es NC Higlyway.27, r. Coe.. , �arD.rarr flitO rep0 C dL Sed e zor.ed r su C r.tra QtTce RiU'tiIT Dar. e: tr Ily-Lageolefigest UST Src.iat :" the Dee ory rt Bata-:° 0\ e infarrrat. rt�c0r. a:t ed it" "h a q9, ex Ic rNeeth Ce, -& 4 :r,te e :htepe, , E ACTT ` r_MPLO - - sCr`C re us/ r' CO ENGINEERING, INC. April 26, 2004 I\4s, Fran McPherson Annual Administering and Coniphance Fee Coordinator Division of Water Quality North Carolina Department of Environment and Natural Resources 1617 Mail Senice Center Raleigh, North Carolina 27699-1617 Subject: Annual Permit Fee and Request for Permit Rescission NPDES Permit No. NCG510356 3 Foodway GWI Number 612519 Shield Project 1950019 Dear Ms. McPherson: Or: behalf of Petroleum World, (PWI), Shield Engineering, Inc. (Shield) submits this letter informing you that PWI will not be renewing the NPDES permit for the subject site, and requests that this permit be rescinded, The groundwater recovery and treatment portion of the remedi anon system is no longer in operation and is no longer needed at the subject site. The North Carolina Department of Environment and Natural Resources, Division of Waste Management UST Section agrees that the renewal of the pennit is not necessary. A copy of the renewal invoice is attached for reference. Sincerely, SHIE1,13 ENGINEERING INC Michael D. tour, LG. Principal Registered, North Carolina 41209 Attachnionis Kevin A. impson Project Manager cei Debbie Sailors, Petroleum World, Inc., Mooreshoro, NC Brad Newton, NCDENR-MRO HProiects '3995 1950019APDES RCATind Lever dor Taggart Creek Road one, NC 28208 www skkeldenrgineenng corn Telephone 704 394 6913 Fax 704 394 6968 1 SHIELD ENGINEERING, INC. April 26, 2004 Ms. Fran McPherson Annual Administering and Compliance Fee Coordinator Division of Water Quality North Carolina Department of Environment and Natural Resources 1617 Mail Service Center Raleigh, North Carolina 27699-1617 Subject: Annual Permit Fee and Request for Permit R+eseission NPDES Permit No, NCG510311 Banoak/Martins GWI Number #5340 Shield Project 1950049 Dear Ms. McPherson: On behalf of Petroleum World, Inc. (PWI), Shield Engineering, Inc. (Shield) submits this 'fetter informing you that PWI will not be renewing the NPDES permit for the subject site, and requests that this permit be rescinded. The groundwater recovery and treatment system is no longer in operation and was removed from the subject site in April 2002. The North Carolina Department of Environment and Natural Resources, Division of Waste Management UST Section agrees that the renewal of the permit is not necessary. A copy of the renewal invoice is attached for reference. Sincerely. SHIELD ENGINEERING, INC.. Michael D. Armour, LL.G. Kevin A. Simpson Principal Project Manager Registered, North Carolina #1209 Attachments cc: Debbie Sailors, Petroleum World, Inc., Mooresboro, NC Brad Newton, NCDENR-MRO 1f:IF''rojeciss199519i0O49APDESRescind Letrer-Banoak_floc Taggar Creek Road otte. NC 28205 www.shleldengneenng.cam Telephone 704 394,6913 Fax 704.394.6969 June 25, 2003 Ms. Debbie Sailors Petroleum World, Inc. 681 NC Highway 120 Mooresboro, NC 28114 Michael F. Easley, Governor JUN 2 7 2003 WATER QUALITY SECTION Subject: Requests for Rescission of NPDES Permits Permit Numbers NCG510019, NCG510356 & NCG510311. Petroleum World, Inc. Sites Bob's Superette, G&J Foodway and Banoak Food sites Catawba & Lincoln Counties Dear Ms. Sailors: Reference is made to your requests for rescission of the subject NPDES General permits, submitted on your behalf by Shield Engineering, Inc. Responses regarding each of the subject facilities/permits are provided below. NCG510019; Bob's Superette Request Summary The submittal states the Division of Waste Management (DWM) has certified that no further action is required to remediate the site. The treatment system is not being used and will be removed at a future date, and therefore the site no longer requires coverage under the general permit. DWQ Response Upon receipt of a statement from you that the on site treatment system has either been removed or that it has no potential (ability) to discharge, the Division will promptly rescind NPDES general permit coverage. Until that time, you are required to abide by all terms of the permit, including payment of annual permit fees. NCG510356; G&J Foodway Request Summary The submittal states the site is scheduled for soil excavation that will preceed issuance of a No Further Action certification from DWM. DWM's UST Section has stated it will not approve the costs of the annual permit fee and therefore, the fee invoice has been returned along with a request for rescission of permit coverage. Customer Service 1 800 623-7748 division of Water Quality 1617 Mail Service Center Raleigh, NC 27699-1617 (919) 733-7015 Fax: (91'9) 73:3 E'a12 DWQ Response requirepermit No evidence has been provided as to whether the circumstancesatne site, is onalDES has coverage have ceased. If the treatment system fetatn coverage a under the permit. As long as the potential for a discharge, it is necessary g payment of the annual permit is in effect, the permittee Pe zpleurneWo ld all ©f its mac ,lerms, and it is not relevant elepan whether or not the fee. This is the responsibility o and $80.00 fee will be paid by the UST trust fund. The expectation ©iesfor last f tpyear the e current year are being returned to you along with this letter, with an t. NCG510 I $ nroak Foods Request Sum wry see if The submittal states the site is currently being evaluated twater supply,aditional remhdia would eliminate necessary or if local residents can be connected to public the need for continued remediation. It further stated that you had been denied reimbursement for the annual permit fee from the UST trust fund. DWQ Response The submittal provided no evidence that either the ee in there �ous discussion,site ii the treatment for continuing permit coverage has ceased. As statedpev system remains at the site, is operational and has potential for a discharge, it is necessary to retain coverage under the permit. As long as the permit is in effect, ff f et, the the permittee must abide de by or all of its terms, including payment of the annual fees. The in the current year is returned along with this letter with the expectation of prompt payment. With regard to each of these matters, when you provide statements that will be abide charrgc nh the es have ceased and the treatment works have been removed, the pleaseis atter, contact Bob Sledge at permits without delay. If you have questiothe ns r Qualitybout tstaff in our Mooresville Regional Office at (919) 733-5083, extensionor (704) 663-1699. Thank you for your cooperation. Sincerely, cc: Mooresville Regional. Office wlattachments Stormwater & General Permits Unit Point Source Compliance — Bob Sledge - wlattachments Central Files - wlattachmnents Fran McPherson, DWQ Budget Office Mr. Michael D. Armour, P.G. Shield Engineering, Inc.. 4301 Taggart Creek Road Charlotte, NC 28208 May 15, 2003 Ms. Fran McPherson Annual Administering and Compliance Fee Coordinator Division of Water Quality North Carolina Department of Environment and. Natural Resources 1617 Mail Service Center Raleigh, North Carolina 27699-1617 Subject: Annual Permit Fee and Notice of Permit Rescinding NPDES Permit No. NCG510019 Bob's Superette GWI Number #5117 Shield Project 1950069 Dear Ms. McPherson: On behalf of Petroleum. World, Inc. (PW1), Shield Engineering, Inc. (Shield) submits this letter informing you that PWI will not be renewing the NPDES permit for the subject site, and requests that this permit be rescinded. This project received a No Further Action from the North Carolina Department of :Environment and Natural Resources, Division of Waste Management on December 18, 2002. The treatment system is no longer in use and will be permanently removed from the site at a future date. The renewal invoice is attached. Sincerely, SHIELD ENGINEERING, INC. Michael D. Armour, P.G. Principal Registered, North Carolina # 1209 cc: Debbie Sailors, Petroleum World, Inc., Mooresboro, NC 430't Taggart Crk Charlotte, NC 28208 995119501)69TTERS''5-1-t13NPDES Rescind Letter.doc ngineering,cnm Telephone 704,394, 6913 Fax 704,394.6968 SOC PRIORITY PROJECT: Yes No x To: Permits and Engineering Unit Water Quality Section Attention: Charles Alvarez Date: August 26, 1993 NPDES STAFF REPORT AND RECOMMENDATION County: Catawba Permit No. fCG51O11O PART I - GENERAL INFORMATION 1. Facility and. Address: BoRhbodesF&©d BealOil Mart c/o 1404 East Main Street Lincolnton, NC 29092 2. Date of Investigation: 08-23-93 3. Report prepared By: Samar Bou-Ghazale, Env. Engineer I 4. Persons Contacted and Telephone Number: Mr. Ted A. Goodman, Hydrogeologist of Handex; (704) 598-7900 . Directions to Site: The site is located on the west side of NC Hwy 127, approximately 250 feet west of the intersectionCof NC 127 and Moss Farm Road (SR 1149) in Catawba County, 6. Discharge Point(s). List for all discharge points: Latitude: 35° 41' 06" Longitude: 81° 22' 24" Attach a•U.S.G.S. map extract and indicate treatment facility site and discharge point on map. U.S.G.S. Quad No.: E 13 NE U.S.G.S. Name: Hickory, N.C. 7. Site size and expansion are consistent with application? Yes, x NoIf No, explain: 8. Topography relationship to flood plain included): Sloping southeast toward locat di in a flood plains rate of 2 to 3 The site is no 9. Location of nearest dwelling: The nearest house is located on the East side of NC Hwy 127, approximately 130 feet across the Highway from Bob's Food Mart. 10. Receiving stream or affected surface waters: Unnamed tributary to Hop Creek. a. Classification: WS-III b. River Basin and Subbasin No.: Catawba ; 030835 c. Describe receiving stream features and pertinent downstream uses: Discharge will take place into a storm drainage system located on the East corner of Bob's Food Mart. The storm drainage system outlet pipe is located on the East side of Hwy 127 approximately 200 feet below the site. The receiving water course is a dry ditch that flows through a residential area. PART II - DESCRIPTION OF DISCHARGE AND TREATMENT WORKS 1. a. Volume of wastewater to be permitted: 0.101 MGD (Ultimate Design Capacity) b. What is the current permitted capacity of the wastewater treatment facility? N/A c. Actual treatment capacity of the current facility (current design capacity)? N/A d. Date(s) and construction activities allowed by previous Authorizations to Construct issued in the previous two years: N/A e. Please provide a description of existing or substantially constructed wastewater treatment facilities: N/A f. Please provide a description of proposed wastewater treatment facilities: The proposed wastewater treatment system will consist of monitoring wells, recovery wells, oil/water separator, air stripper, and an activated carbon adsorption unit. Possible toxic impacts to surface waters: None expected. g. h. Pretreatment Program (Wren only): N/A NPDES Permit Staff Report Version 10/92 Page 2 2. Residuals handling and utilization/disposal scheme: Generation of residuals is not expected. 3. Treatment plant classification (attach completed rating sheet): Proposed, no rating given 4. SIC code(s) : 5541 Primary: 66 Secondary: Main Treatment Code: 5600 PART III - OTHER PERTINENT INFORMATION 1. Is this facility being constructed with Construction Grant Funds or are any public monies involved (municipals only)? N/A. 2. Special monitoring or limitations (including toxicity) requests: N/A. 3. Important SOC, JOC or Compliance Schedule dates: (please indicate) N/A. 4. Alternative Analysis Evaluation: Spray Irrigation: Connection to Regional Sewer System: Subsurface: Other Disposal Options: PART IV - EVALUATION AND RECOMMENDATIONS Rhodes & Beal Oil Company, is requesting an NPDES General Permit for the discharge of treated groundwater resulting from a leaking underground gasoline storage tank (UST) at Bob's Food Mart. The proposed method of treatment is typical of treatment methods used by the petroleum industry for similar groundwater remediation activities. Field investigation revealed that after discharging from the facility into a storm drainage system, the proposed treated groundwater exits into a dry ditch approximately 200 feet from the discharge point into the storm drain. It then flows approximately 900 feet to an unnamed tributary to Hop Creek through a residential area. NPDES Permit Staff Report Version 10/92 Page 3 Because h proximity to adjacent residences, the applicant should be required to demonstrate that the proposed facilities will not create nuisance problems (noise, odors) prior to issuance of an Authorization to Construct. is ended that the PDES Permitbe issued. DES Permit Staff Report Version Page PROPS CROSSRC4CS 4,4 Mk a 0755 I/I NW (LONGVI£W) to of North Carolina Department of Environment, Health and Natural Resources / Division of Environmental Management James B. Hunt, Jr., Governor Jonathan B. Howes, Secretary A. Preston Howard, Jr., P.E., Director Mr. Wendel Boggs Rhodes & Beal Oil Company 1404 East Main Street I..incointon, NC 29092 August 9, .1993 Subjects Application No. NCG51.0110 Additional Information Request Bob's Food Mart Hickory Lincoln County Dear Mr. Boggs: The Permits and Engineering. Unit has completed a preliminary engineering review of the subject application. Thee fbllowi.ng items must be addressed before we can complete our review: 1) Please document the cost of connecting to the available sanitary sewer versus the cost of discharging to the surface waters of the State. 2) For new facilities, final plan layout, including connection of piping systems., must be submitted signed and sealed by a North Carolina registered Professional Engineer. A plan of the remcdiation equipment in relation to other features at the site (such as roads, buildings and wells) with buffer distances from property lines (50 feet from property lanes), and the location of the discharge point needs to be signed and sealed by a registered Engineer, 3) A copy of calculations of removal efficiencies for benzene, toluene and other constituents of interest expected to be obtained using the treatment equipment. Refer to the subject permit application number when providing the requested information. Please submit three copies of ail information to my attention at the address below. Also, please note that failure to provide this additional information on or before September 1.0, 1993 will subject your application to being returned as incomplete, in accordance with 15A. NCAC 2H .0208. Regional Offices Asheville Fayetteville Mooresville R.alefgh Washington r'ihriingtort Winston-Salem 704/251-6208 919/486-1541 704/663-1699 919/571-4700 919/946-6481 919/395-3900 919/896-7007 P.U. Box 29535, Rai. An Equa Pollution Prevention Pays 1, North Carolina 27626-0535 Telephone 919-733-7015 Opportunity Affirmative Action Fmpldv"er. Mr. Wendel Boggs August 9, 1993 Page Two If you have any questions nn this matter, please. a at 1 w: Sincerely, Permit File NCG510110 Handex, Inc,„ Mike Jones Charles A. Al Environmental Engineer. NPDES Group James G. Martin, Governor William Yvr. Cobey, Jr., 'Secretary State of North Carolina Department of Environment, Health and Natural Resources Division of Enrirorrtnental Management 512 North Salisbury Street • Raleigh, North Carolina 27611 A. Preston Howard, Jr., Pa . Ac tin g Director NOTICE OF INTENT National Poll t nt Discharge El rnination System, Application for Coverage under General Permit NCG510; Grog nd'v'ate' designed to treat petroleum contarninated groundwater. 1, Name, Address , location, and telephone number of facility requesting Perr .it. Bob's Food Mar t c / o Rhodes & Bea A. Official Name: B. Mailing Address: n r Wendel Boggs (i)Street Address; (2)City; (3)State; (4)Zip; (5)County; C. Location. (Attach map delineating general (1)Street Address; (2)City; (3)State; (4)County; Fact C. D. Telephone Number; Contact: Name; Title;. Company Name; Phone Number; )N/A Rhodes & Beal Oil Co. c Senior Project Manage Beal Oil Co. 4 725 2508 Application type (check appropriate A. New or Proposed; K B , Existi'ng. C„ Modification; e nature of the modification Description of discharge A. Please state the nurnber of separate discharge points. LEA; 2,[1; 3,[I; 4,[1; 1, selection): n projects Oil Co. o MikeJ(Hande�X of the ��ones Carolinas, Inc.) Wendel Boggs If previously permitted, provide permit number and issue date Page 1 B. Please describe the amount of wastewater being discharged per each separate discharge polnt 1101_2:gallons per day (g-pd) 2: (-gTxi) 3: ) (6 xi) ( EST ) C. Check the duration and frequency of the discharge, per each separate discharge point: 1. Continuous: 2, Intermittent( 3. Seasonal (check month(s) theJanuary .; February [ March k]; Apn May [June id; 'July it August [)1; September W..;Octoberik November W; Decnmber 4. 4. How many days per week is there a discharge?(check the days the discharge occurs) Monday ()I, Tuesday kb Wednesday W, Thursday kl.,Friday kJ Saturday [xl, Sundayki. 5. How much of the volume discharged is treated? (state inpercent) 1 ()0 57c REFER TO ATTACHED . • RFIVE ACTION PLAN FOR. SErIa4.D & 4. 6-10 D. Describe the type of wastewater being discharged per separate discharge point. Specify what is being removed and products recovered. This includes a listing of any Chemicals found in detectable amounts with the maximum observed concentration reported. The summary of analytical results containing this maximum value should also be submitted (i.e, the listing, not the graphical scan). The most recent sample must be no older than one year previous to the date of this application. The .following volatile organic compounds should be included along with any suspected fuel additive; 1. Benzene"; 2. Toluene*; 3. Ethyllpenzene; 'Xylene"-; 5. Lead; Methyl tert-butylether (MThE); 7. Dibromoethane (EDB); 8. 1„2-dichloroethane; 9. Isopropyl ether; 10. Naphthalene; 11, Phenol; '(An EPA approved method capable of detection levels to 1 ppb should be used to detect these cornixpunds). E. Please check the appropriate type of treatment being used to treat the ground 1. Ol/Water Separator; x 3. Air Stripper; Diffused Aeration; 4, Activated Carbon Absorption; v 5. Othenspedfy); a er; 6. Separately, please describe in detail(size, vo urne,capacity, desxgn flow through treatment, etc.) each type of treatment that was checked in 1 through 5. Include, if any, the rnanurac-turer5 nformation on each type of treatment. Also provide the removal efficiency of each compound detected for the project, if known. Give design specifics (i.e. design volume of each unit, materials used in air stripper, etc.). Existing treatment facilities should be described in detail and design criteria or operational data should be provided(including calculations) to ensure that the facility can comply with requirements of the General Permit. Please include model and calculations used in determining the design requirements for the air stripper. 7. Vslhat are the well sizes and how many exist 8. Please state the pump sizes and their location in relation to the treatment used in part 9. Please ex -plain what fail-safe measures, such as audible and visual alarms or automatic shutoff systems, are provided to ensure no system failures. 10. is there an access to the effluent for sampling?( either an open pipe or a valve to obtain a sample) Page 2 Pr ' :,----4(51.E: Construction of any wastewater treatment facilities require submission of three (3) sets of plans and spe.cifications along with their application. Design of treatment facilities must comply with requirement 15A NCAC 2H. .0138. if construction applies to the dis.-..charge, include the three sets of plans and specifications with the application. 5, What is the nature of the business applying for this permit. Retail Food Market 6.. 1,,,:arrie of receiving water or waters; Classification: (Attach a USCS topographical map with all int(s clearly marked) Is the discharge directly to the receiving w.aterNY,N) NO If no, state specifically the discharge point. Mark clearly the pathway to the potential receiving waters on the site map, (This includes tracing the pathway of the storm sewer to its discharge point, if a storm sewer is the only viable means of discharge.) S, Pease address possible non -discharge alternatives for the following options: REFER TO CORRECTIVE ACTION PLAN, SECTION 8. 8 (page, 2j) A,. Connection to a Regional Sewer Collection System; c,'Libsurrace DiSpOSal; pray Irrigation; 9,. I certify that I am .farniliar with the inforrnatian contained irt the application and that to the best of my knowledge and belief such information is true, complete, and accurate. Pnni Nain of P Date Application Signed. Signature of Applicant Any person who knowingly makes any false statement, representation, or certification in any application, record, report, plan or other document filed or required to be maintained under Article 21 or regulations of the Environmental Management Corrin-Ussion implementing that Article, or who falsifies, tarnpers with or knowingly renders inaccurate any recording or monitoring device or method required to be operated or maintained under Article 21 or regulations of the Environmental Management Commission implementing that Article, shall be guilty of a misdemeanor punishable by a rine not to exceed $10,000, or by imprisonment not to exceed six months, or by both. (18 USC. Section )001 provides a punishment by a fine of not more than $10,000 or imprisonment not more than 5 years,or both, for a similar offense.) Notice of Intent must be accompanied by a check or money order for $40C,00 made payable to the North Carolina Department of Environment, Health, and Natural Resources. Mail three (3) copies of entire package to: Division of Environmental Management NPDES Permits Group Post Office Box 29535 Raleigh, North Carolina 17626-0535 CO RECTIVE ACTION FOR T- ROUTEBOB'S FOOD MART NORTH1 Handex Project 4 -0 PreparedFor: RHODES AND BEAL OIL COMPANY 1404 Fast Main Street Lirlrter, N.C. 29092 eparc# 6 Michael C. Jones, Ra Senior Project Manage Prepared HANDEX OF THE CAROLINAS, INC. }-G WOODPARK BOULEVARD CHARLOTTE, NORTH CAROLINA March 1 2, 93 AUG' Figure 1 : Figure 2: Figure 3 : Figure 4 Figure 5: Figure 6 : Figure 7 : Figure 8 : Figure 9: Figure 10 : Figure 11 : Figure 12 Figure 13 : Figure 14 Figure 15 Figure 16 : Figure 17 : Figure 18 : Figure 19 Table 1 : Table 2 Table 3 Table 4 Table 5 : Table 6 Table 7 TABLE OF CONTENTS (Continued) FIGURES Topographic Map of Surrounding Area (SGS Report 9-92) Site Plan Water Supply Wells (SGS Report 9-92) Cross Sections Line Map (SGS Report 9-92) Cross Section A -A' (SGS Report 9-92) Cross Section B-B' (SGS Report 9-92) Cross Section C-C' (SGS Report 9-92) Cross Section D-D' (SGS Report 9-92) Water Table Contour Map - Nonrestrictive Flow (SGS Report 9-92'. Water Table Contour Map - Showing Bedrock Influence (SGS Report 9-92) Benzene Concentration Map (SGS Report 9-92) MTBE Isoconcentration Map (SGS Report 9-92) BTEX Concentration Map Projected Capture Zones - 2 Vacuum Enhanced Wells (1.0 GPM) Projected Capture Zones - 2 Vacuum. Enhanced Wells (2.0 GPM) Projected Capture Zones - 2 Vacuum Enhanced Wells (3.5 GPM) Conceptual Remediation Plan Recovery Well and Piping Layout Recovery Well Detail TABLES Ground Water Analytical Results Summary (SGS Repor Soil Analytical Results Summary (SGS Report 9-92) Predicted Vacuum Enhanced Pumping Results Timeline for Installation and Remediation Tracking Summary of Cleanup Standards and Discharge Criteria Air Stripper Design Concentrations NPDES Discharge Criteria APPENDICES 9-92) APPENDIX A : CORRESPONDENCE WITH NCDEHNR APPENDIX B : GROUND WATER MODELING DATA AND RESULTS APPENDIX C : OIL WATER SEPARATOR/AIR STRIPPER DESIGN & SPECS, andex 1.0 INTRODUCTION The following presents the Corrective Action Plan (CAP) for the Rhodes 8, Beal Oil Company, Bob's Food Mart Facility located at Route 8, Box 122, in Hickory, North Carolina. The Site Assessment. Report for the facility was submitted in September 1992, to the North Carolina Department of Environment, Health, and Natural Resources (DEHNR), Division of Environmental Management (DEM) in Mooresville, NC, The assessment reports were approved by DEM and a CAP was requested for the site. The due date for the CAP has been extended to March 12, 1993. The CAP extension letter is presented in Appendix A. 1.1 OBJECTIVES The goal of the proposed corrective actions is to remove hydrocarbons from the affected ground water and soil quality. These remediation efforts should be guided by the level of risk to the population, the standards set by the State of North Carolina, and the level of effort economically and technologically advisable. The objectives of the CAP are to provide a plan to accomplish the following goals: • Establish hydraulic control over the core of the hydrocarbon plume in the source areas and control downgradient migration of hydrocarbons. * Removal of Liquid Phase Hydrocarbons (LPHs) from the water table if present; • Reduce dissolved phase hydrocarbons (DPHs) in ground water to risk based closure levels; • Removal of residual hydrocarbons in unsaturated soils which may act as continuing source of dissolved hydrocarbons to ground water. The CAP was prepared to evaluate approaches to cleanup of petroleum hydrocarbons and includes a comparison of cleanup approaches based on technological sound remedial methods, cost considerations, site conditions, and recovery endpoint goals. 1.2 PROPOSED REMEDIATION ENDPOINTS The primary remediation endpoints will be the reduction of residual hydrocarbons in unsaturated soils, and reduction and containment of DPHs to levels which can ndcx substantiate a variance request (North Carolina Administrative Code T15A:2t_.0106 and 0113). The variance request will be made after a sustained effort has been made to rernediate the petroleum hydrocarbons in the subsurface at the site. After the data trends show an asymptotic decline in ground water concentrations, a variance request for cleanup to concentrations other than drinking water standards will be submitted to DEM for review under the provisions of T15A:2L:.0106 (e) and (f). 2.0 BACKGROUND 2.1 SITE DESCRIPTION The site is located in south Hickory, North Carolina, in a primarily rural residential area. Immediately upgradient of the site to the east is a Wilco gasoline station which has an active petroleum storage tank facility. To the south of the site, across Highway 127, are residences. To the southwest of the site across HWY 127, is a Quality Gasoline outlet, which has an active petroleum storage facility. To the west of the site is an open gravel area for parking, and to the north is farm land. The topographic map of the area surrounding the site is presented as Figure 1. The general site plan is presented as Figure 2. There are presently six (6) monitor wells on site, and four (4) monitor wells located on adjacent properties. There are presently no recovery wells at the site, although there is subsurface vapor extraction piping in place around the former tank system. Utilities located on the site include a potable drinking water well, service station product lines, and subsurface and overhead power lines. There are four (4) monitor well immediately adjacent to the site surrounding the Wilco tanks. 2.2 PREVIOUS INVESTIGATION RESULTS The Comprehensive Site Assessment (CSA) was conducted by Southeastern Geological Services (SGS) during 1992. The site assessment describes the geology of the site, hydrogeology, well installation procedures, areal and vertical extent of hydrocarbons, and sensitive receptors in the area. The assessment was approved by the NCDEHNR in late 1992. The findings of the earlier investigation are summarized as follows : 2 The suspected source of hydrocarbons is the former UST system. Potential receptors in the area are outlined in the CSA, and include several potable wells within 1/2 mile of the site (potable wells shown on Figure 3). The Geology of the site is saprolitic soils over most of the site with some bedrock at surface on the northern part of the site. The saprolitic soils at the site consist generally of varicolored clayey silts. The bedrock/saprolite interface appears to consist of varicolored silty sands The bedrock consists of amphibolite and granitic gneiss. Foliations are reported to be approximately horizontal.. The surficial aquifer is contained within the saprolite and uppermost fractured bedrock. This surficial aquifer will be the primary target of the site remediation efforts. Cross sections are provided as Figures 4 through Figure 8. The interaction of the water table with bedrock seems to be irregular, however, for the purposes of the remediation, Handex has considered the saprolite to be interconnected by fractures with the upper bedrock for modeling and recovery purposes. Figure ,9 and 10 show the latest water table contour maps. The ground water recovery will need to affect the surficial water in the saprolite, and the upper bedrock. The average water table gradient from the CSA is reported as 0.035. The average of the hydraulic conductivities presented in the CSA is 0.67 ft/day. The average transmissivity value presented in the CSA is 3.70 ft2 /day. Handex recalculated the transmissivity to better approximate interconnected flow in the upper bedrock and saprolite. The average horizontal velocity presented in the CSA is 0.16 feet per day. The CSA reports that approximately 550 cubic yards of contaminated soils remain. The areal extent of the hydrocarbons has been assessed by the present well array. The CSA describes the ground water contamination as extending vertically to approximately 69 feet below land surface (BLS). The vertical extent of hydrocarbons indicates that the hydrocarbons are migrating into the upper fractured bedrock. andex 2.2.1 Ground Water Quality Assessment The areal distribution of dissolved hydrocarbons was assessed by collecting ground water samples from the shallow wells located surrounding and within the containment dike. The results of the ground water analyses are summarized on Table 1, and show the chemical analyses from two sampling events, The highest benzene concentrations are present in MW-1 which penetrates the former tank basin and MW-3 and MW-4 located downgradient of the former tank basin, The highest benzene, toluene, ethylbenzene, and xylenes (BTEX) concentrations are present in MW-1 which penetrates the former tank basin and MW-3 and MW-4 located downgradient of the former tank basin. The results of the perimeter well sampling showed no detectable concentrations of MTBE or BTEX. Figure 11 is a benzene concentration contour map, and Figure 12 is the Methyl Tertiary Butyl Ether (MTBE) concentration contour from the prior report. The BTEX concentration contour map which shows the latest results from each of the monitor wells is presented as Figure 13. The vertical extent of hydrocarbons has been assessed using monitor well MW-5. The detected concentrations of hydrocarbons in MW-5 were below laboratory detection limits. The vertical extent of petroleum hydrocarbons has been assessed to an adequate degree for the present time. 2.2.2 Soil Quality Assessment Soil quality was assessed using chemical and vapor analyses over the study area, Chemical analysis of soil showed the detection of concentrations of petroleum hydrocarbons and total petroleum hydrocarbons (TPH). The locations where the soils displayed the highest vapor and laboratory concentrations in the soil were near MW-1. The soil vapor readings for each sample collected are presented on Table 2. The results of the soil assessment indicate the soils in these areas of the site will require remediation. These areas will be addressed in the corrective action plan. 4 andax 2.2.3 Water Table Contour In the assessment report, the water table contour map indicated ground water flow to the southwest on the ridge top, and thence to the southeast and northwest on the ridge flanks. This seems likely given the topographic position of the site. The final ground water contour (unrestricted flow) is presented as Figure 9. The direction of ground water flow is variable across the site due to the topography and presence of bedrock near surface. The site can best be described as ground water flow in a saddle with flow along the ridge at the crest and downhill along the flanks of the ridge. The gradient used for the remediation planning was along the ridge from the area near MW-1 toward the new tank field. The gradient measured in this direction was determined to be an average gradient of 0.05. The annual water table fluctuations range from 1 to 4 feet. 2.2.4 Potential Receptors The sensitive receptors in the area are detailed in the prior assessment report. The land use surrounding the site is primarily residential, rural farming, and small businesses. There are two other gasoline stations adjacent to the property, a Wilco to the northeast of the site with a tankfield adjacent to Bob's Food Mart property line, and a Quality Gas across Highway 127, to the south of the site. There are 10 potable wells within a 1/2 mile radius of the site, one of which is the potable well at Bob's Food Mart. These potable wells are typically installed to a depth of over 150 feet to recover water from the lower bedrock aquifer. The focus of the remedial action is to prevent further downgradient migration of petroleum hydrocarbons in the surficial water table zone, and recover hydrocarbons which have migrated vertically into the upper fractured bedrock aquifer. 2.3 SITE GEOLOGY AND HYDROGEOLOGY Soil borings and monitor wells were used to characterize the uppermost saprolite zone which contains petroleum hydrocarbons. The earlier soil borings reported weathered - amphibolite and granitic gneiss bedrock was encountered between 38 and 50 feet below land surface (BLS). The average depth to competent bedrock is approximately 38 feet. The Geology of the site is saprolitic soils over most of the site with some bedrock at ndex* surface on the northern part of the site. The saprolitic soils at the site consist generally of varicolored clayey silts. The bedrock/saprolite interface appears to consist of varicolored silty sands atop fractured bedrock. The bedrock consists of amphibolite and granitic gneiss. Foliations are reported to be approximately horizontal. The surficial aquifer is contained within the saprolite and uppermost fractured bedrock. This surficial aquifer will be the primary target of the site remediation efforts. Cross sections are provided as Figures 4 through Figure 8. The interaction of the water table with bedrock seems to be irregular, however, for the purposes of the remediation, Handex has considered the saprolite to be interconnected by fractures with the upper bedrock for modeling and recovery purposes. Figure 9 and 10 show the latest water table contour maps. The ground water recovery will need to affect the surficial water in the saprolite, and the upper bedrock. The average water table gradient from the CSA is reported as 0.035. The average of the hydraulic conductivities presented in the CSA is 0.67 ft/day. The average transmissivity value presented in the CSA is 3.70 ft2 /day. Handex recalculated the transmissivity to better approximate interconnected flow in the upper bedrock and saprolite. The average horizontal velocity presented in the CSA is 0.16 feet per day. The CSA describes the ground water contamination as extending vertically to approximately 69 feet below land surface (BLS). The vertical extent of hydrocarbons indicates that the hydrocarbons are migrating into the upper fractured bedrock. The saprolite is the primary zone containing petroleum hydrocarbons and is the focus of the assessment and remediation efforts. For purposes of remediation, Handex will focus on the surficial zones of the uppermost 40 feet of the water bearing saprolite unit, and will address most of the remedial efforts to that area. 6 andexm 3.0 CORRECTIVE ACTIONS COMPLETED OR IN PROGRESS The soil remediation efforts conducted during the underground storage tank removal reportedly removed approximately 500 cubic yards of soil which was landfarmed on an adjacent parcel of land., There have been no ground water remediation efforts documented at the site to date. The release of petroleum hydrocarbons is suspected to come from the prior UST system, which was removed in January, 1992. There have been no liquid -phase hydrocarbons identified in any of the wells at the site. The present plume geometry appears to be stabilized and is slowly moving toward the flanks of the ridge to the north west and southwest of the site. 4.0 CAP AQUIFER ANALYSIS 4.1 EXPECTED AQUIFER CHARACTERISTICS The aquifer testing conducted at the site consisted of three bail tests reported in the GSA. The results of the testing were used in the preparation of a particle tracking model to assess whether the proposed recovery operation was adequate to address the petroleum hydrocarbons in the subsurface. The aquifer thickness was of great concern in the preparation of the model. Dissolved hydrocarbon concentrations were detected in the deep well (MW-5) borehole samples at a depth of 40 feet below the water table. These concentrations must have migrated through fractures in the bedrock an show some interconnected fractures do exist. The recovery of hydrocarbons from these fractures will be greatly dependent on the location of the recovery wells to allow interaction with the bedrock fracture system. 4.2 GROUND WATER MODELING From the basic aquifer parameters presented in the OSA, the calculated zones of influence of pumping wells were modeled using a particle tracking model developed and released by the US Environmental Protection Agency (EPA). The input data, calculations, and explanations of the model parameters are presented in Appendix B. 7 ander' The aquifer parameters used in the model are summarized in Appendix B. Three model runs were conducted, all under vacuum enhanced pumping conditions. Each figure shows the particle tracking for the capture zone of the wells used in the model over a one _ - year period. The actual flow rate from each vacuum enhanced pumping well will vary based on the bedrock fractures encountered when drilling the wells. The flow rate will be somewhat dependent on the bedrock fractures encountered and the production of water from each fracture. The initial modeling run was to see if pumping under non -vacuum enhanced conditions would provide plume capture. The results of the analysis did not look favorable. The second modeling runs were predicted using vacuum enhanced ground water recovery. Vacuum enhanced ground water recovery is achieved by applying a vacuum of up to 20 inches of mercury to the pumping well. This provides increased flow from the well in tight formations without a corresponding decrease in pumping elevation. The transmissivity of the aquifer and hydraulic conductivity do not change with vacuum enhancement, however, the equivalent drawdown in the recovery wells will be greater with vacuum application than under atmospheric conditions. The predicted results of vacuum enhanced pumping are presented on Table 3. To show capture at different flow rates, Handex prepared three model runs, one at 1 gallon per minute (GPM) per well, one at 2.0 GPM, and one at 3.5 GPM. The model results for pumping under vacuum enhanced conditions are shown on Figures 14, 15, and 16. The 1 GPM scenario does not show coverage of the entire hydrocarbon affected area after one year. The 2 GPM scenario provides a good approximation of plume capture after one year, and the 3.5 GPM model shows total plume capture after one year of recovery. The input data and graphical representation of the recovery capture zones are presented in Appendix B. The capture zones will also provide capture of hydrocarbons present in the vadose zone soils near the former tank system. This will provide recovery of hydrocarbons from soil required for soil cleanup. 8 m•••••=1.1 andczx 5.0 REMEDIAL ACTION ALTERNATIVES EVALUATION 5.1 SOIL REME©IATION ALTERNATIVES The selection of a sail remediation technology depends on the extent of contamination, the geologic setting, the risk of sensitive receptors, the established remediation endpoints and the ability of the technology to achieve those endpoints. The degree of residual petroleum hydrocarbons detected by soil analyses coincides with the dissolved hydrocarbon plume. Hydrocarbons in soil are usually evidenced in the residual and vapor phase from the liquid -phase hydrocarbons passing through soils; the liquid phase can also be present in the soil column. In any event, it is imperative that impacted soils be addressed to eliminate a potential source of continuing ground water contamination. To do so, remedial technologies are evaluated with respect to the site conditions. A brief overview of how each technology can be applied is also provided. 5.1.1 Excavation and Treatment of Soil Excavation of impacted soils may be a practical approach, particularly if the extent of soil contamination is limited. At Bob's Food Mart, 550 cubic yards of contaminated soil have already been excavated for treatment. Any further excavation of contaminated soils would not be practical due to the impact to the canopy and pump island areas, The soil volume that requires treatment is not large, however, the soil can be treated effectively in place using the proposed remediation system more cost effectively. 5.1.2 Soil Vapor Extraction Impacted soils can be remediated through in -situ volatilization or soil vapor extraction, depending on the permeability of the soils. This technique works well with highly volatile compounds, such as gasoline, in permeable substrates. It does not necessarily work well with heavier hydrocarbon mixtures such as diesels, waste oils, or fuel oils, and its influence can be effective, yet limited, in low permeability soils. In -situ volatilization involves removal of volatile hydrocarbon compounds from the soils using forced or drawn air currents. This may be augmented by injection of air or steam in conjunction with extraction. 9 Extraction can be accomplished using various size and types of blowers, such as regenerative blowers or high -vacuum low flow pumps; the selection of blower type is strictly dependent on the permeability of the subsurface and the desired radius of influence. Once extracted, vapors may need to be treated depending on air emission regulations. After the concentration and flow rates are established, Handex will evaluate air dispersion modeling at the site first. If the modeling shows that the soil vapors will not meet the air quality discharge criteria for Mecklenburg County, the most appropriate off -gas treatment system will be selected. Possible off -gas treatment systems to be evaluated are +� Vapor -Phase Carbon Treatment Catalytic Oxidation Thermal Oxidation + Regenerative Thermal and Catalytic Oxidation Biological Soil -Vapor Treatment These potential off -gas treatment systems will be evaluated with respect to air discharge permit considerations, facility operations, predicted vapor treatment system longevity, and cost effectiveness. 5.1.3 Recommended Soil Remediation Method The preferred soil remediation method is to extract vapors from the vadose zone from the recovery wells using a liquid -ring pump. The liquid ring pump maintains high vacuum between 15 and 20 inches of mercury at 10 to 20 cubic feet per minute (CFM) on each recovery well. The air recovered from this extraction will be sampled to determine the concentration of hydrocarbons present in the off -gas stream. If the concentrations are Tess than 40 pounds per day, then there should be no air discharge permit necessary. The source will have to be registered with DEM. If the from soil -vapor extraction system exceeds the 40 pound per day limit, then temporary air treat will be proposed. The air treatment system will be selected at a later date after a full scale pilot test is conducted on the entire extraction well array. This will provide accurate concentration data and air 10 cindcxm flow rates to decide if off -gas treatment is necessary, and to allow for the sizing of the treatment unit. The analysis of Vacuum Enhanced pumping test data from other sites with similar subsurface conditions shows that the air -flow capacity of the saprolite is very low, although the ability to sustain a vacuum is very high. This means that the ability for the soil to exchange air through interconnected pore space within the soil will occur at a relatively slow rate. The soil remediation might be enhanced by pneumatic fracturing and the addition of air inlet wells installed in strategic location around the site to increase air volume and air flow through the soil. This would translate to a greater air flow rate through the soil and should remediate the soil in a shorter period of time. Handex proposes to pneumatically fracture the soils to enhance the recovery of vapors from the vadose zone and to install air inlet pipes at the boundaries of the contaminated area to allow passive inflow of fresh air into the subsurface. The air inlets are designed to allow oxygen to enter the formation and increase the effectiveness of the vapor extraction and enhance natural biodegradation of hydrocarbons in the soil. This soil remediation is the most effective and technologically sound approach investigated. 5.2 GROUND WATER / LPH REMEDIAL ALTERNATIVES As with soil contamination, remedial technologies concerning ground water are dependent on extent and type of contamination, hydrogeollogic settings, and risk exposure to sensitive receptors. Hydrocarbon impacts to the ground water are usually in the form of liquid phase and/or dissolved phase hydrocarbons. Several approaches apply to remediating this type of subsurface contamination. Trenching Containment • Liquid -Phase Hydrocarbons (LPH) Recovery • Ground Water Extraction and Treatment The most appropriate and cost effective method of recovery and containment of ground water is to pump ground water under vacuum enhanced conditions using submersible pumping equipment. 11 cindax Air sparging was investigated from literature, as a stand-alone treatment method. Air sparging is usually well suited for sandy of granular soil media, and is not well suited to remediation of large plumes in saprolite. Additionally air sparging has a tendency to drive water and LPH away from the sparge point. For this reason, air sparging is not as well suited for containment of hydrocarbons at the site as vacuum enhanced pump and treatment, Air sparging alone cannot effectively achieve downgradient capture of hydrocarbons, and address the site cleanup. 5.3 GROUND WATER EXTRACTION METHODS Handex evaluated the following pumping methods for ground water pumping at the site. • Total Fluids Pumping - At the site, Handex proposes to use pneumatic pumping equipment to recover total fluids from the subsurface. This selection is made based on the depth to fluids in the subsurface, desired flow rate, and desired area of influence. These pumps minimize emulsification of the liquid -phase hydrocarbons such that separation can be achieved with a minimum of retention time in the separator. • Dual Phase Pumping -- Dual phase pumping involves using a dual punp, system within one recovery well or the recovery trench well to recover ground water and liquid -phase hydrocarbons (LPH) separately. The lower pump of a dual pump system is used to lower the water table to recover dissolved hydrocarbons and create a cone of depression to induce liquid -phase hydrocarbon flow into the recovery well. The upper pump is then used to only recover the liquid phase that enters the well. This system will not be employed at the site due to the additional cost and the limited thickness of LPH. + Vacuum Enhanced/Total Fluids Extraction - Pumping ground water or total fluids can often be enhanced by applying a vacuum to the subsurface at the paint of fluid removal. Vapor extraction and pumping augment each other in that application of the negative pressure effectively creates a stronger hydraulic gradient toward the recovery point and accelerates contaminant and ground water flow toward the extraction point. This in turn increases the contaminant recovery 12 rate and recovery well yield. In the addition, pumping ground water or total fluids draws down the water table and exposes soils that may also be impacted. This allows for recovery of residual and vapor -phase hydrocarbons in the soils. 5.3.1 Vacuum Enhanced Ground Water Pump and Treatment The use of vacuum enhanced ground water and LPH recovery has been applied to petroleum sites with low hydraulic conductivities to increase the effective capture zone, increase the pumping rate, and enhance soil cleanup. The procedure includes using a submersible pump to provide direct ground water and LPH recovery by pumping, and simultaneously recover soil vapors from the same well at high vacuum, up to 25'' of mercury (Hg). The vacuum enhancement increases the well yield by as much as 250 %, and provides enhanced recovery of liquid -phase hydrocarbons from the soil and capillary fringe. The bail test data yielded aquifer hydraulic conductivity data which was used with the predictable vacuum enhancement to obtain the equivalent drawdown for the proposed recovery wells. No vacuum enhanced pumping test was conducted on the site, however, Handex has experience in vacuum enhanced ground water recovery in tight saprolftic soils and has demonstrated an increase in the pumping rate of over 250 %. This remedial method would also provide soil treatment which would greatly reduce the life of the recovery and treatment project, and therefore the overall project cost. 5.4 RECOMMENDED REMEDIAL OPTION The preferred soil and ground water remediation method is to extract vapors from the vadose zone from the recovery wells using a liquid -ring pump which maintains high vacuum (up to 20 inches of mercury) on the recovery well and pump total fluids using submersible pumps. The conceptual remediation plan for the proposed system is presented as Figure 17. Table 4 presents the projected timeline for the remediation at the site. The remedial option selected was based on overall effectiveness, initial cost, long term operation costs, reliability, and estimated time to cleanup. 13 6.0 SOIL REMEDIATION DESIGN The remediation of soil containing hydrocarbons will be accomplished by extracting soil vapors from the subsurface using a liquid -ring pump. This technology has been tested in similar soils and produced a large radius of influence. The following sections describe the soil remediation process and design. 6.1 DESIGN OF SOIL -VAPOR EXTRACTION SYSTEM The ground water recovery/vapor extraction well array proposed for the site is shown on Figure 18. This well array was designed using the radius of influence inferred from vapor extraction feasibility tests conducted in saprolite of similar composition at another site. The vapor extraction well array will be composed of wells designed for ground water and vapor extraction. The ground water/vapor extraction wells will be connected to the liquid -ring pump by solvent welded PVC piping installed in a subsurface trench from each well, and joined to a manifold pipe near the liquid -ring pump. A valve will be installed at each well head to tnrottle or shut-off the system as necessary. Subsurface piping from the extraction wells to the liquid -ring pump will be accomplished with the least disturbance of the existing site features possible, along with the ground -water piping. The general piping layout diagram is also presented on Figure 18. The total air flow extracted from the subsurface is expected to be approximately 8-10 cubic feet per minute (CFM) per well using 2 recovery wells. The proposed soil -vapor extraction is predicted to yield approximately less than 30 CFM from the entire recovery system. The liquid -ring pump requirements are that it provide 20 inches of vacuum measured in mercury at each of the 2 ground water and vapor extraction points at an extraction rate of approximately 10 to 15 CFM per well. In addition to the two recovery wells, it may be possible to extract hydrocarbon vapors from the existing vapor extraction piping installed during the tank replacement activities. It is not anticipated that the soil vapor extraction system will sustain volatile organic emissions greater than 40 pounds per 14 andex day. After the pilot testing of the system, the level of discharge will be evaluated with. respect to the discharge standard, and off -gas treatment will be proposed if necessary. 7.0 GROUND WATER LPH RECOVERY DESIGN 7.1 RECOMMENDED GROUND WATER RECOVERY SYSTEM To accomplish ground water cleanup objectives, ground water is pumped to create a cone of depression in the water -table near the hydrocarbon source. This reduces the hydraulic head in the surficial aquifer, causing the ground water containing dissolved hydrocarbons to migrate toward the recovery well. The recovery of dissolved hydrocarbons is based on the recovery of ground water, therefore, hydraulic control of the dissolved hydrocarbon plume must be demonstrated. The ground water recovery system recommended for the site consists of pumping total fluids from two (2} recovery wells as shown on Figure 18. The recovery well detail is presented as Figure 19. This recovery scenario is predicted to produce an average flow of 1,0 to 3.5 GPM from each extraction well, for an average flow of 2.0 to 7 GPM from the entire recovery system. The pumping equipment to be used in the recovery wells will consist of electric submersible pumps which will be capable of over 10 GPM sustained pumping. 7.2 RECOVERY WELL DESIGN The proposed recovery well array consists of two (2) new recovery wells installed to a depth of 60 feet below land surface (BLS). The proposed recovery wells will consist of approximately 50 feet of 6-inch diameter, 0.020 inch slotted, schedule 40 PVC, well screen, set with 30 feet below the static water level and 20 feet above the static water table. The wells will contain at least 10 feet of solid well casing above the screen to provide a good surface seal for vacuum enhanced recovery. The proposed recovery wells will be constructed of 6-inch diameter well casing and screen to allow for the installation of pumping equipment and operational considerations. The details of the recovery wells are shown on Figure 19. 15 ander 7.3 GROUND WATER PIPING DESIGN The subsurface ground water recovery piping will be constructed of PVC since the recovery is not anticipated to encounter any separate phase hydrocarbons, The conceptual recovery piping layout is shown as Figure 18. The pumping equipment selected will be capable of developing sufficient head to overcome the piping system friction losses and will be capable of delivering more than the required maximum flow rate of 3.5 gallons per minute (GPM) per well to the treatment system. Subsurface piping and electrical lines will be installed in one subsurface trench connecting the recovery wells and the treatment system. The PVC lines for vacuum enhancement will also be installed in the same trenches as the ground water piping. To regulate flow through the system, a shut-off/throttling valve, flow meter, and sampling port will be installed at each recovery wells and sampling ports and valves will be provided at each of the treatment system units. 7.4 GROUND WATER PUMP DESIGN The pumps required to pump ground water at a rate of between 0.5 and 5.0 GPM from each of the wells are electric submersible pumps. This type of pump is useful in pumping where separate -phase hydrocarbons (SPH) is not anticipated. The use of electric submersibles should not effect the operation of the oil/water separator. The pump intakes will be set at approximately 15 feet below the static water levels. The pumps will be equipped with a check -valve to prevent back -flow of water from the treatment system when the pump is shut down. The pumps will be wired directly to the control box. 7.5 TOTAL EXPECTED WATER FOR TREATMENT The normal predicted flow rate required for hydrocarbon recovery is 2.5 gallons per minute (GPM) per well, with a maximum flow per well estimated at 3.5 GPM per well. Since there are two proposed wells pumping at 2.5 GPM, the average flow for the site would be approximately 5.0 GPM. Under peak flow conditions, the treatment system would have to effectively treat 3.5 GPM per well, or a total of 7.0 gallons per minute. 16 atndcx Since the pumping units will be set at a specific flow rate, the treatment system will not be affected by significant rainfall events and subsequent infiltration. The treatment and piping systems will be specified at 10 gallons per minute to allow for excess system capacity. The peak flow specifications are particularly important for the piping, oil/water separator, air stripper and the carbon treatment unit. 8.0 GROUND WATER TREATMENT SYSTEM DESIGN 8.1 RECOMMENDED GROUND WATER TREATMENT SYSTEM The recommended ground -water treatment system for the site was chosen with the General NPDES discharge for cleanup of petroleum sites in mind. The General NPDES permit requires the treatment system to be configured with a phase separation oil/water separator, an aeration unit as primary treatment, and a carbon polishing unit prior to discharge. This system is shown on the conceptual process flow diagram presented on Figure 17. If the general NPDES discharge permit is not obtained, then alterations of the treatment system may be made. The process schematic shows the oil/water separator for the recovered ground water at the site. The recovered ground water is pumped from the separator for treatment through the low profile air stripper, then flows through a particulate filter prior to final polishing in the carbon adsorption unit. The water will be treated through the remediation system and discharged through the general NPDES permit for petroleum remediation sites. The treatment units required to accomplish the cleanup objectives are described in the following sections. The ground -water treatment systems will be enclosed in a building to protect it from the elements and freezing. Signed and sealed as -built drawings of the treatment system will be provided after the system is installed. 17 andcx' 8.2 OIL WATER SEPARATOR The first step in the treatment system is the separation of the LPH and dissolved phases of hydrocarbons. The oil/water separator selected for the site has a 100 gallon capacity, coalescing packed media, and is rated at a normal flow rate of 10 gallons per minute. This should be able to accomplish phase separation even at the maximum predicted flow rate for the system. The peak flow for the system may be increased due to significant rainfall events and subsequent infiltration. The specifications and details of the oil water separator/air stripper are presented in Appendix C. Liquid -phase hydrocarbons have not been identified in any of the monitor wells, however, some may be encountered after start-up. The oil/water separator is required as a treatment process element to meet the requirements of the NPDES General Permit for petroleum contaminated ground water remediation. 8.3 LPH HOLDING TANK DESIGN The oil water separator will automatically discharge LPH to a product holding tank or drum located near the treatment system. The holding tank will be fitted with a high level shut-off switch which will shut down the recovery systems if the tank is full. This fail-safe will assure that no LPH discharge occurs. The tank will be managed in such a way that the tank is periodically emptied of LPH prior the automatic system shut-off being activated. 8.4 DESIGN OF PRIMARY TREATMENT AIR STRIPPING The low -profile air stripper treatment system will receive the water from the ground water recovery wells for primary treatment using aeration. The recovery water will be treated through the oil -water separator and flow into the low profile air stripper. The treatment system selected for the facility consists of an ejector systems "Stripperator" which includes a low profile air stripper. This aeration unit consists of a single baffled tray connected to a sump through which high volumes of air are forced using a blower. The process is very efficient for removal of volatile organic compounds usually associated with ground water cleanups at petroleum sites. The summary of cleanup standards and 18 ndexm discharge criteria are presented on Table 5, Concentrations of MTBE are expected in the treatment system and should be primarily removed from the water using aeration. The low -profile air stripper has been designed for a normal flow rate of 5 gallon per minute (GPM), however, it is capable of treating water at up to 10 GPM. The air stripper will be located in the treatment compound shown on Figure 17. The low profile air stripper will be fitted with an exhaust stack at the top of the unit, a single aeration tray, a sump at the bottom of the unit, a high level switch to shut off the recovery system should the air stripper become flooded, access ports for cleaning, an effluent sampling port, and a sight glass for the sump. The electric blower accompanying the low -profile unit will force air into the treatment unit. The controls for the unit will be included as needed. The water treatment parameters used for the air stripper design were taken from the monitor wells displaying the highest BTEX concentrations. The most significant concentrations were MTBE and benzene which were the limiting factors in the design. The results of the recovery well average water concentrations for two proposed recovery wells are presented on Table 6. These average concentrations were used to prepare the air stripper design presented in Appendix C. These calculations show that the selected air stripper has sufficient capacity to treat the average reported BTEX and MTBE concentrations from the recovery wells. A particulate filter will be installed between the air stripper and the carbon unit to remove particulate matter and lengthen the time between backflushing and carbon changes. 8.5 DESIGN OF SECONDARY TREATMENT : CARBON ADSORPTION UNIT The secondary treatment system will consist of a granular activated carbon adsorption (GALA) unit. This process will assure that any hydrocarbons not removed from the wastewater stream by aeration will be adsorbed prior to waste water discharge to the NPDES outfall. The GALA unit will consist of one 24' diameter carbon unit which contains 19 andcxe 400 pounds of activated carbon for ground water treatment. The carbon bed life expectancy of this unit is a minimum of one year, depending on particulate matter in the treated water, and may be as much as two years. The carbon treatment unit will be capable of backwashing the carbon to remove particulates, and extend the carbon bed life. A particulate filter will be installed in -line between the air stripper and the carbon adsorption unit to remove solids. This should greatly extend the carbon bed life and limit carbon replacements. The GACA, in this application as a polishing unit, will receive limited volatile and semi volatile hydrocarbons which should easily be treated. 8.7 PRETREATMENT for IRON, LEAD (Pb), and BIOFOULING Characterization of ground water samples for water chemistry parameters other than BTEX and MTBE have not been performed, These parameters are anticipated to have an effect on the overall maintenance of he recovery and treatment systems, however, the effects should be minimized by regular maintenance of the system. These parameters were evaluated in the preparation of the treatment system design. Pre-treatment for lead (Pb) is not anticipated. Iron and biofouling of the treatment system has been considered in the maintenance schedule for the site. The primary treatment system will aerate and precipitate iron. The removal of iron and biofouling on the aeration trays will be done monthly with periodic maintenance, or as needed, Any iron sludges created in the air stripper will be removed from the sump, tested for toxicity, and disposed of as necessary. The primary treatment system will aerate and precipitate iron. The removal of 'iron and biofouling on the aeration trays will be done monthly with periodic maintenance, or as needed. Should iron fouling of the aeration unit be a problem, a sequestering agent will be placed in line to inhibit iron fouling. 20 nde 8.6 SYSTEM CONTROLS and SAFETY MECHANISMS The recovery and treatment system safety controls would consist of high level shut-off switches in the oiliwater separator, water sump, LPH holding tank, and wet -well. An air stripper blower failure switch will turn off the electric submersible pumps at the breaker box. 8.8 GROUND WATER DISPOSAL SYSTEM Handex has reviewed the options for disposal of treated ground water at the site. The possible options considered were: • Infiltration of treated ground water • Discharge of treated water to sanitary sewer • Discharge of treated water to surface water using NPDES General Permit No. NCG510000, for "Petroleum Contaminated Groundwater Remediation and Similar Discharges" The proposed pumping rate of the recovery system will create a normal flow rate of 4 to 7 gallons per minute for disposal. Infiltration of this water would be difficult at this flow rate without a large infiltration gallery. There are fouling problems and maintenance of infiltration galleries which are operational concerns. The other disposal options offer a better solution to the problem. Disposal of treated water to the sanitary sewer was considered as an option. At the present time, the sanitary sewer system is available along Highway 127. The costs of disposal to the sewer in monthly volume charges and analytical fees would be greater than disposal of water through a NPDES general permit. From the cost analysis, the best option is to discharge treated ground water to the General NPDES Permit. The engineering report will be used to apply for a general NPDES permit to discharge treated ground water for the site. The treatment system effluent water -quality objectives will be the same as the criteria listed in the NPDES General Permit No. NCG510000 "Petroleum Contaminated Groundwater Remediation and Similar Discharges". These NPDES general permit discharge criteria and monitoring 21 requirements are listed on the Table 7. The actual disposal piping will be four -inch diameter Schedule-40 PVC pipe which will discharge from the system to the ditch along the mutual property boundary with Wilco. The water will flow by gravity and no pumping equipment will be required. The proposed discharge location is shown on Figure 18, 8.9 TREATMENT SYSTEM EFFLUENT WATER QUALITY OBJECTIVES The treatment system effluent water -quality objectives will be the same as the criteria listed in the NPDES General Permit No. NCG510000, "Petroleum Contaminated Groundwater Remediation and Similar Discharges". These NPDES general permit discharge criteria and monitoring requirements are listed on the Table 7, Since the ground water would not meet the discharge criteria without treatment, treatment is proposed. The treatment system is designed to meet the treatment system component requirements of the NPDES general permit, and the effluent water quality requirements as well. If system monitoring shows that the treatment system has failed to reduce hydrocarbon concentrations within these goals, the NCDEM office administering the General NPDES permit will be notified within 24 hours, or on the next working dayL Details of such incidents and their resolution will be included in the tri-annual reports, 9.0 DISPOSAL OF RECOVERED LPH Recovered liquid -phase hydrocarbons (LPH) will be disposed of in accordance with applicable local, State, and Federal laws. No substantial amounts of LPH are anticipated at this site. 10.0 PERATION AND MAINTENANCE The operation and maintenance of the proposed system will consist of many tasks relating to the vapor recovery, pumping, treatment, and disposal systems and equipment at the site. A brief synopsis of the planned operation and maintenance schedule are listed in the following sections. 22 andexe 10.1 GAUGING AND BAILING OF WELLS Ground water and LPH levels will be measured in each well monthly, and ground -water contour maps prepared using these data. This data will help remediation tracking and show the development of the cone of influence around each extraction point. The results of these activities will be summarized in the tri-annual reports presented to DEM. 10.2 RECOVERY SYSTEMS MONITORING The recovery wells and trench will be examined at each scheduled operation and maintenance site visit to determine whether adjustments are needed. Flow and pump intake levels will be adjusted as specified by the project manager. The total flow from ground water recovery system will be checked, as well as flow from the water holding tanks and product sump. The pumping of the recovery trench will be adjusted as necessary to maintain proper flow in this area. 10.3 TREATMENT EQUIPMENT MONITORING The treatment system is designed to function with a minimum of operation and maintenance. During maintenance visits, Handex will check the system for proper operation of the oil/water separator, check the air stripper for fouling and clean as necessary, check the carbon unit for excessive pressure and back -flush as necessary, and inspect and adjust the vapor treatment equipment. System controls will be adjusted as necessary. Sampling of the system will consist of 1) Monitoring of the hydrocarbon concentrations in the recovery system influent, air stripper effluent, and carbon treatment system effluent. Influent and effluent water samples collected monthly will be analyzed in accordance with the General NPDES permit to verify treatment efficiency. These analyses will be conducted the first two weeks, and monthly thereafter. 2) Collecting air quality samples of the soil -vapor extraction system periodically to assess concentration changes with time. Minimum frequency Quarterly the first year and annually thereafter. During the weekly checks, maintenance of the syster maintain system efficiency and maximize operational general inspection. 23 ill be performed as necessary to e and the system will be given a andcx° 11.0 REMEDIATION SYSTEtI MONITORING AND REPORTING The reports required for the remediation tracking are (1) monthly discharge monitoring reports, (2) tri-annual remediation progress reports, and (3) client reports. These reports summarize the appropriate information collected about the remediation system, recommend changes to the system, and draw conclusions about the overall effectiveness of the system to achieve remediation goals. 11.1 DISCHARGE MONITORING REPORTS The discharge monitoring reports are required on a monthly basis for the General NPDES discharge permit proposed for the site. These reports will contain effluent quality data, flow data, and site information. The General NPDES discharge will be routed to the intermittent stream west of the site. If system monitoring shows that the treatment system has failed to reduce hydrocarbon concentrations within the established remediation goals, the NCDEM will be notified within 24 hours, or on the next working day. Details of exceedances and their resolution will be included in the tri-annual reports, however, the system has a carbon polishing unit which should keep exceedances from occurring. 11.2 TRI-ANNUAL REPORTING The tri-annual reports will provide tables, graphs, figures, and a written summary of the remedial action progress. This information will be used to assess the remedial progress during the year, and project necessary changes to increase the effectiveness or reduce costs for the recovery, treatment, and disposal systems. It is anticipated that the first reports will show the results of the treatment systems effectiveness, soil -vapor extraction, LPH recovery, and ground water recovery. 11.3 WATER -QUALITY SAMPLING OF OBSERVATION WELLS Included in the tri-annual reports will be ground water analytical data from selected monitor wells at the site. Samples from designated wells will be analyzed for BTEX and MTBE using EPA Method 602 (modified) tri-annually to document remediation progress. These data will be used to track remediation progress toward the remediation goals. In 24 the oreparation of a variance request, these data will be used to demonstrate the remediation progress made to date. The proposed monitor wells to be sampled for BTEX analysis for the initial tri-annual report are wells 1, 2, 3, 4, 5, 7, 8, and the two recovery wells RW-1 and RW-2. These analyses will be used to assess changes in concentrations with time. The number of wells to be sampled in the following tri-annual frequency may be reduced based on the results from these wells. Chemical analyses of ground water from each of the recovery wells will be done tri-annually to assess remediation progress. These data will be reported in the tri-annual reports. 12.0 REMEDIATION PROGRESS EVALUATION The cleanup objectives of the proposed corrective action are to recover LPH from the water table and soil if present, recover soil vapors from the subsurface, recover dissolved phase hydrocarbons from the areas identified in the assessment reports, and areas of highest concentrations, and maintain a downgradient capture of the dissolved hydrocarbons. The approach selected for ground water recovery and treatment should accomplish these goals. The goals of the remedial action will to be re-examined one year after treatment starts, and each following year. 13.0 REMEDIAL ACTION COMPLETION After the data trends show an asymptotic decline in ground water concentrations, a variance request for cleanup to concentrations other than drinking water standards will be submitted to DEM for review. The variance request will request a reduction or elimination of the ground water and soil remediation at the site based on the efforts to date, the long term use of the property, and a basic evaluation of risk to the public if the contaminant levels remain above drinking water standards. This variance request should be submitted after a significant reduction of dissolved hydrocarbons in ground water has 25 been achieved. Cleanup of the silty soils at the site to drinking water standards may not be achievable using best available technology econ u is 11 reasonable. The variance request will provide supporting information that cleanupt drinking water standards would produce hardship without equal or greater public benefit. The remedial action will be deemed completed after the rian e request is i approved. 26 REFERENCES Cedergren, H.R. (1977). See2"d ed.) NY.,NY.: John Wiley & Sons, pp.66-76. Driscoll, F.G. (1986). Groundwater and Wells.(2"d ed.) St. Paul, Minnesota: Johnson Division, pp. 1-1089. Johnson, A.I., USGS (1967). Specific Yield - Compilation of Specific Yields for Various Materials: U.S. Geological Survey Water -Supply Paper 1662-D. Washington D.C.: U.S. Govt. Printing Office, pp. D1-D33. Keeling J.F. and Tsang C.F. (1983). Velocity Plots and Capture Zones of Pumping Centers for Ground -Water Investigations, Ground Water, Volume 21, No. 6,. November -December 1983, pp. 701-714. North Carolina Administrative Code, Title 15, Subchapter 21.. North Carolina Department of Health and Natural Resources, December 1989, Classification and Water quality Standard A icable to the Ground Waters of North Carolina, Section§ .010Q, .0200, and .0 SGS Report (January, 1991). Comprehensive Site Assessment Report (and follow-up reports), Southeastern Geological Services, Shelby, NC, pp. 1-15. 27 andex° In SECTIONS IN SAP BOB'S F ,T CATAWBA COUNTY FIGURE5 CROSS SECT ION -- BOB'S D =MRT CATAWBA COUNTY' a' 2 FIGURE 6 CROSS SECTION- C FOOD T TD Fracture Zone t Pathway Bedrock SCALES: FIGURE CROSS SECTION BOB'S FOOD PiAFRT T LT 00 zene SCALES.: HORIZ FIGURE CROSS SECTION T ION FOODP\ART CATAWBA COUNTY benzene ca Monitor Well r Former Tank Basin FIGURE 9 NON-RESTRICTIVE F WATER TAB_E CONTOUR AP 1"" 1QQ' BOET5 FOOD /TART CATAWBA COUNTY Monitor Well > Flow Direction 100' Former Tank Basin FIGURE 10 SHOWING BEDROCK INFLUENCE WATER TABLE CONTOUR P\AP BOB'S FOOD t\ART CATAWBA COUNTY 1 FIGURE 1 BENZENE CONCENTRATION BOB's FOOD fT 9 Bed n Bedrock: no anafind acquirer' nnfidn FIGURE 12 iv\TBE ISOEONCENTRATION BOB'S FOOD INNART CATAWF3A COUNTY AP Monito We VACUUM WELL SEAL FIL al ELECTRIC SUBMERSIBLE PUMP 24' x 24" x 24' DEEP SKIRTED SIE I_ PRCTTW P ANNDLE 2' PVC SLEEVE ELECTRIC POWER x 2' PVC SADDLE 2" PVC VAPOR LINE TO I hLATP ENT SYSTEPI 1' TOTAL FLUIDS LINE TO TRUNK TO TREATPLENT SYSTEP P I TLESS PVC VELE CA.S I NG 6' X 4' IA I_ RalucER ELECTRIC POWER CORD 4' D1A, 0.01 SLOT SCE 40 PLC VF1t SCREEN RECOVERY WELL W/ EJECTOR T'IPE PUMP AND VACUUM ENHANCEMENT BOB'S FOOD MART RHODES AND 19EALE OIL COMPANY RECOVERY WELL DETAIL FIGURE 19 ilandax® TABLE GROUND WATER QUALITY ANALYTICAL RESULTS ( SUMMARY FROM THE SGS REPORTS ) BOB -GONG MJ 03-03-93 SAMPLE TOTAL DATE MW # B T E X BTEX MTBE IPE (PPB) (PPB) (PPPPB) (PPB) (PPB) (PPB 25/92 03/25/92 710 3600 30 4900 10040 860 120 53+ 174 6 14 729 14 24 9fla 190 28 176fl 3818 99 960 ND ND 2731 ND ND 4600 300 ND ND ND ND ND ND ND ND ND ND ND ND ND B = BENZENE T = TOLUENE E = ETHYLBENZENE X = XYLENES MTBE = METHYL TERTIARY BUTYL ETHER IPE = ISOPROPYL ETHER TABLE 2 SOIL QUALITY ANALYTICAL RESULTS (SUMMARY FROM THE SGS REPORTS) 1) Excavation Samples - taken 1-8-92 SAMPLE LOCATION DEPTH TPH (feet) (ppm) SW-1 South Wall 15 < 6 SW-2 East Wall 15 < 6 SW-3 west Wall 15 15 SW-4 North Wall 15 11000 13-1 Center Floor 19 38000 ) soil Borings 1-4 and Monitor Wells 3 & 4 Sampled 5-20 & 21-92 BORING DEPTH TPH (feet) (PPm) SB-1 24 < 1 SB-2 24 SB -3 25 (1 SR -4 25 (1 MW -3 30 MW -4 25 < 1 The samples were analyzed for total petroleum hydrocarbons by EPA method 5030- TABLE 3 PREDICTED VACUUM ENHANCED GROUND WATER FLOW DURING PUMPING WITH VACUUM APPLIED TO RECOVERY WELLS WELL NUMBER PUMPING ACTUAL RATE / NO DRAWDOWN VACUUM (GPM) R 0.5 FT) 7.0 7.0 VACUUM APPLIED Hg) 7.0 7.0 7.0 5„ 10" 15 " 20 EQUIVALENT DRAWDOWN *** TT) 7.0 12.4 17.8 3.2 VACUUM ENHANCED PUMP/RATE (GPM) NA .1 * 2.3 28.6 7.0 25 a, 34.0 2.9 * .5 * Vacuum enhanced pumping rates estimated from test data at other sites. *** EQUIVALENT DRAWDOWN = (1.08 x INCHES Hg) ± ACTUAL DRAWDOWN andcx n HANDEX HANDEX HANDEX HANDEX HANDEX HANDEX HANDEX TABLE 4 Remediati©n Implementation and Evaluation Timeline 1993 thru 1997 REMEDIATION IMPLEMENTATION AND EVALUATION T[MELINE BOB'S FOOD MART STORE HIGHWAY 127, HICKORY, N,C, TASK DESCRIPTION SUBMIT CAP TO QE APPLY FOR NPDES GENERAL PERMIT RECEIVE COMPLETED NPDES PERMIT ANNUAL SAMPLING OF ALL WELLS ORDER EQUIPMENT AND INSTALL BEG OPE N GROUND WATER AND SOIL REMEDIATION - STARTUP CATION AND MAINTENANCE OF SYSTEM FUTURE YEARS TIMELINES TASK DESCRIPTION HANDEX HANDEX HANDEX HANDEX AN EX ANDEX FILE NAME 305-'TIME PREPARED 03-12-93 PREP, BY : Mike Jones OPERATION AND MAINTENANCE EPORT ON NPDES DISCHARGE MONTHLY TRI-ANNUAL SAMPLING OF SELECTED 4" "ELLS TRIANNUAL REPORTS OF REMEDIATION ANNUA ANNUA AMPLING OF ALL WELLS EDIATION - RECOMMEND CHANGES UBMIT FOR VARIANCE REQUEST TO NCDEHNR *******THE TIME TO CLEANUP IS ESTIMATED ONLY AND MAY VARY FROM WHAT IS SHOWN HERE ******** TABLE 5 SUMMARY OF CLEANUP STANDARDS AND DISCHARGE CRITERIA GROUND WATER STANDARDS COMMENTS IMITATIONS Remediate ground water to NC drinking water standards listed in NCAC, Title 15, Subchapter 2L, Section .0202, Water Quality Standards for Class GA Waters. SOIL STANDARDS Benzene = 1.0 erg/i Toluene = 1000 pg/I Ethylbenzene = 29 pg/l Total Xylenes = 400 pg/I 1,2-Dichloroethane = 0.38 pg/I Ethylene Dibromide - 0,0005 pg/I Remediate soil to levels which do not present a continuing source of hydrocarbons to ground water, (DEM action level policy guidelines) TPH < 10 ppm = no action TPH > 10 < 100 ppm = evaluate TPH > 100 ppm = remediate AIR DISCHARGE STANDARDS Mecklenburg County Air Pollution Control Permit for a petroleum contamination site, an air discharge must not exceed the following criteria or off -gas treatment or dispersion modeling will be required. Benzene < 8,1 Ibs. per year Toluene < 98 lbs. per day Ethylbenzene = no specific limit Xylenes < 57 lbs. per day NPDES DISCHARGE STANDARDS The general NPDES discharge permit for petroleum contaminated sites has discharge monitoring requirements as follows KEY : ,ug/l = Micrograms per liter TPH = Total Petroleum Hydrocarbons ppm = Parts per million FLOW - measured weekly Benzene = 71,4 pg/I Toluene = 11 pg/I MTBE = no limit established Lead = 25 pg/l andcx® TABLE 6 CONCENTRATION AVERAGES AND FLOW REQUIREMENTS FOR AIR STRIPPER DESIGN BOB-CONC MJ 03-03-93 SAMPLE DATE 03/25/92 03/2°5/92 03/25/92 03/2 92 03/25/92 03/25/92 MW # 1 2 3 4 5 6 7 8 9 10 710 530 1900 1000 ND ND WEIGHTED WATER CONC. AV (MW-1 THRU MW-4 ONLY) ND TOTAL T E X BTEX MTBE IPE 3600 170 190 960 ND ND ND ND 1035 830 28 ND ND ND ND ND ND ND ND 4900 14 1700 ND ND ND 700 ND ND 10040 720 3818 ND ND ND ND ND 860 ND ND ND 14 4600 300 ND ND 4327 ND ND ND ND 120 24 99 ND 1444 18 ND ND ND ND ND ND 65 NOTE CONCENTRATION AVERAGES ARE FOR MW-1 THROUGH MW-4 ONLY ID TABLE 7 NPDES DISCHARGE CRITERIA A. Effluent Limitatims and Monitoring Requirements Final NPDES Permit No. NCG510000 During the period beginning on the effective date of the permit discharge from outfall(s) serial number 001. Such discharges s below: Flow Toluene Benzene Methyl Tert Butyl Ether 'Lead Discharge Limitation) Monthly Averageily !a rid lasting until expiration, the Permittee is authorized to 11 be limited and monitored by the Permittee as specified Monitoring Requirements Measuremerd Sample Saralple Frequency L_ Location Weekly Pump or Meter Log Effluent 22 µg/l Monthly Grab Effluent 142.8 µg/1 Monthly Grab Effluent Monthly Grab Effluent 50 µgr1 Monthly Grab Effluent There shall be no discharge of floating solids or visible foam in other than trace amounts. The monitoring requirements and discharge limitations shall only apply if leaded petroleum products are the source of the groundwater contamination. Minimum treatment will include an oillwater separator, air stripping or diffused aeration and activated carbon adsorption, Design and Construction of the Waste Treatment Facility will emphasize the use of plastic pipes and fittings where practically possible. GroundwnuC7 Rcrncdi 9'6tti;n APPENDIX A COFIFIESPONDENCE WITH ND LU Li t.;/.0-it '35E; PO2 State of North Carolina Department of Environment, Health, and Natural Resources Mooresville Regional Office Jana . Bunt, r., Goyim= Jonathan D. SOW0011, Secretary DIVISION OF ENVIRONMENTAL MANAGEMENT February 3 1993 Mr. Wendell Boggs Rhodes & Beal Oil Company 404 East Main Street Lincolnton, North Carolina 28092 RE: Request for Extension Bob's Food Mart Groundwater Incident #6223 Catawba County, N.C. Dear Mr. Boggs: Your request for additional time for submitting the corrective action plan at the above referenced site has been reviewed by the Groundwater Section of the Mooresville Regional Office. Based on the information you have provided with your request for an extension, the request is hereby granted until March 12, 1993. Failure to send the site assessment report by the extended due date may result in a recommendation for the assessment of civil penalties beginning from the original:due date. Should you have further questions regarding this, matter, please call Arlen Burney or me at (704) 663-1699. Sincerely, Brenda J. Smith, P.G. Regional Supervisor cc: Incident Management Unit Richard Kelly, Southeastern Geological Services FAB/sc PO a 950, 919 !iced, Mir Saw. Mczoossvilk, N 21015C950o TecrAvorie 704463-1659 • FAX 704653-6W An Eq..) opporwrary Affirrnative Acdon F-trOoycr APPENDIX GROUND 'i PATER!MODELING DATA AND RESULTS CAPTURE ZONE MODELING Bob's Food Mart, NC A particle tracking groundwater flow model was employed to simulate groundwater flow in the area of the site and determine the optimum recovery well array and flow rates. The computer -generated model was constructed utilizing current static flow conditions as a baseline from which to calculate the area of influence of the proposed recovery system. The modeled system consists of two recovery wells operating under vacuum -enhanced conditions. The model used for this simulation was developed and released by the US EPA, and is a semi -analytical groundwater particle tracking program. The model was chosen on the basis of several criteria: first, the calculation methodology had to be proven and accepted by regulatory agencies; second, the program had to produce accurate, reproducible results; and third, the program had to be relatively easy to set up and run. This EPA model has been in use for several years and has been recognized by state regulatory agencies as well as the EPA. As a semi -analytical model the input parameters are relatively easy to determine, and the program is computationally efficient* Studies conducted prior to release by the EPA tested the model output against known case studies with consistent accuracy. The flow calculations used in the model are based on several assumptions typical of most groundwater flow models: the aquifer is isotropic and behaves as though it were homogeneous. The calculations are valid for horizontal flow conditions with fully penetrating wells and equal horizontal and vertical hydraulic conductivities. Water table geometry must be planar with a constant gradient. General site characteristics input to the model were transmissivity, static saturated thickness, porosity, direction of groundwater flow, and hydraulic gradient. These parameters were obtained or calculated from data supplied by SEG. Model input Parameters Groundwater movement at this site appears to involve both the saprolite and underlying fractured bedrock, Detection of soluble hydrocarbons in bedrock monitor wells indicates the overburden and bedrock aquifers are likely to be hydraulically connected, allowing the aquifer system to behave as one unit. To enable use of a simple analytical model, several simplifying assumptions were made: the two units were assumed to behave as though they are one continuous aquifer; local flow conditions in the area of the former tank field were extended to the entire model domain; and the aquifer saturated thickness was taken to be 40 feet, the sum of the overburden thickness (approximately 6 feet) and the maximum depth into the bedrock at which soluble hydrocarbons were detected (30 to 35 feet). The effect of these assumptions will be considered during discussion of the model results. c1 *Index Data supplied consisted of hydraulic conductivity (K) of the saprolite, saturated thicknesses as described above (b), and porosity (n). The groundwater flow direction and hydraulic gradient were determined from water table contour maps supplied by SEG (the "Groundwater Nonrestrictive Flow" map dated 8/11/92). Flow conditions in the former tank field area were represented by an hydraulic gradient of 0.05 feet/ft to the southwest The hydraulic conductivity (K) used was an average of those supplied for MW-1, MW-2, and MW-3, determined from slug tests as reported by SEG. The K values calculated from these tests were 0.25 ft/day, 1.63 ft/day, and 0.13 ft/day, respectively, and the average is 0.67 ft/day. The porosity supplied was 0.15. For the model, aquifer transmissivity (T) was calculated from the hydraulic conductivity (K) and saturated thickness (b) by the formula: T = K b Driscoll, 1986 Using the saturated thickness of 40 feet and hydraulic conductivity of 0.67 ft/day, a transmissivity of 26.8 ft2/day (200.5 gpd/ft) was obtained. To calculate steady-state flow rates for the recovery wells, the aquifer specific capacity (Qs) was estimated from Driscoll's (1986) equation: T 05 1500 where Qs = Specific Capacity in gpm/ft, T = Transmissivity in gpd/ft, and Q = discharge in gpm. In this case, T = 200.5 gpd/ft, so Q= (200.5 gpd/ft) / 1500 = 0.13 gpm/ft. Under atmospheric conditions, flow from the well (Q, in gpm) is: Qs sobs where Sobs = drawdown observed (or desired) in the well, in feet. 02 At this site, desired drawdown is 7 feet, so the theoretical atmospheric conditions flow rate from each well would be: Q = (0.13 gpm/ft) x (7 feet) 0.91 gpm per well. Vacuum -Enhanced Conditions To calculate the increased well yield realized through vacuum -enhancement, the technique of Blake and Gates (1986) was used. The expected flow rate was determined from the specific capacity calculated above, the actual drawdown to be attained in the pumping wells, and the expected vacuum to be applied to the well. The drawdown desired is 7 feet, and a vacuum of 20 inches of mercury will be applied to each well. Since the sum of the actual drawdown in the well and the vacuum applied to the well is the equivalent drawdown present in the well, 27 feet of equivalent drawdown was used in the flow rate calculations below: Q = Q iv where: 0 = flow rate in gpm, ©5 = specific capacity in gpm/ft, and sequi,, = equivalent drawdown, in feet. Since both wells would be operated at 7 feet of drawdown with a constant vacuum, the flow rates will be equal. They were determined as follows;. Q = (0.13 gpm/ft) x (27 feet) 3.5 gpm per well. This is the theoretical maximum attainable flow rate with an sequin of 27 feet. The simulations were run with flow rates of 3.5 gpm, 2.0 gpm, and 1,0 gpm per well. Simulation Results To simulate steady-state conditions, the simulation was run for 1 year. The model results are presented as a particle -track plan of the recovery system capture zone, included as Figure 14 (3.5 gpm from each well), Figure 15 (2,0 gpm), and Figure 16 (1.0 gpm) in the body of this report. To illustrate the effect of the recovery system on the soluble plumes detected at the site, the plots are overlain on the March 25, 1992, BTEX lsoconcentration Map. On all Figures the green lines are groundwater particle pathlines, and represent the distance and path a groundwater particle would be expected to follow after pumping starts. C3 lcindcx These plots should be used with caution, however. Variations in conditions from those represented by the simplifying assumptions described earlier will cause the actual capture zone to be somewhat different from that depicted in these plots. Variations in the water table surface will have the most pronounced effect, with the water table rise shown to the southwest on the "Nonrestrictive Map" causing the capture zone to extend farther in that direction and to narrow in the northwest -southeast direction. Capture of the center portion of the plume should not be significantly affected. In addition, variability of the hydraulic conductivity between the bedrock and overlying saprolite aquifers may cause the well yield to be lower than expected. However, sediments with a lower hydraulic conductivity will also require a lower flow rate to achieve the same amount of capture at a well. References: Driscoll, F.G., G oundwater and Wells, Johnson Division, St. Paul, Minnesota, 1986. Blake, S.B., and Gates, M.M., Vacuum Enhanced Hydrocarbon Recovery: A Case Study, in Proceedings of Petroleum Hydrocarbons and Organic Chemicals in Groundwater, NWWA/API, 1986. C 4 EJECTORS APPENDIX SYSTEMS STRIPPEI3ATOR SPECIFICATIONS EJECT 910 N lipnal Avenue Addison, Illinois 6W01 (708) 54 -2214 FAX 708-`,A3-2014 1-& 3-O9L-LEAK QUOTATION HANDEX OF THE CAROLINAS 3600 G Woodpark Blvd. Charlotte, NC 28206 Attn: Michael Jone Phone: 704-598-7900 FAX: 704-598-2248 Quote Specifications: REVISED QUOTE Ref: Bob's Food Quote # 930489-00 Date: 03/02/93 Terms: Net 30 days Freight: prepaid and added FOB Addison Quotation is valid for 60 days Stripperator Application Parameters (5 GPM Q 58 F): CONSTITUENT INFLUENT DESIGN PROJECTED EFFLUENT EFFLUENT Benzene 3,000 ppb < 1 ppb « 1 ppb Toluene 5,000 ppb < 10 ppb < 1 ppb Ethyl Benzene 800 ppb < 1 ppb « 1 ppb Xylenes 8,000 ppb < 10 ppb < 1 ppb MTBE 5,000 ppb none <150 ppb Effluent projections at 10 GPM are as follows: B: <5 T: <5 EB:. <1 X: <5 MTBE: <500 The air requirement We offer the following': -400 CFM; the blower is 3.0 HP. ESI Stripperator Integrated coalescing oil/water separator and Cascade eir stripping system with 3 HP blower and effluent sump. Baffled separator with polypropylene coalescing pack has gasketed removable lid. Air stripper has TEFC blower motor and blower back pressure gauge. Constructed from epoxy coated carbon steel.. THE UNIT LISTED INCLUDES THE FOLLOWING OPTIONAL EQUIPMENT: Explosion proof blower motor (NEC Class 1, Div. 2, Group D). Explosion proof motor starter (mounted and prewired). 3/4 HP XP transfer pump with level controls. includes sump high -high switch. igh/Low blower pressure switch (includes 25' of cord). TO si h S IN :, 910 Naon Avenue Addison, tUu cis 60101 (108) 5,nrn1: FAX - 413 Iart u e ' Yours truly, EJECTORTM $ 23C. WilliamRecker V ce President MANDEX OF -`%' 3 :CAROL H.s Quote # 910489-00 Page is ' p11 expenses " . EJECTOR e';11thoiStNC ' 910 National Avenue Addison, Illinois 60101 (708) 543-2214 FAX 708-543-2014 1-803-01L-LEAK ESI STRIPPERATOR 0-10 gpm coalescing oillwarer separator with 6 tube air stripper and .mcgral effluent ,sump, inclkided are 3 hp blower and back pressure guage. STRIPPERATOR • , _ . • • • • _ • . • — _ . • — . • . • • — . — — „ S 8,575.00 3 hp TEFC blower standard Aut STRIPPER OlLivATER SEPARATOR OILivATER TtirLuENT SEPARATOR CLEAN OJT DRAIN SEPARATOR OUT DRAIN %/ATER EFFLANT (GR.AvIT y TRANSFER PUMP ITEM Blower motor starter TEFC 3/4 hp transfer pump with level controls coNrpot, PANEL .0 HATCH %/ATER Ern...UO.0 (TRAhrSCER ADD TO NET TOTAL 5 6,00 00 Explosion -proof blower motor Explosion -proof blower motor starter 5 1.450,00 4 hp e.xplosion-proof transfer pump with controls h High effluent switch 500 00 5 1,400,00 S 2.850,00 395•00 Dimensions: 89- L x 50- W x 59" 1-1 Inlet: 2 1/2" NPIT Outlet: 3" NPTF Product Effluent 1 if2". NPTF Drains: 1 112" NPTF 5 195 00 6' (CONTROL PANEL MOUIITfr�i, AIR STRIPPER BAFFLES PLATE SUPPORTS AIR STRIPPER TUBES TOP ,V1 SuMP INFLUENT STRIPPER INFLUENT B9.D' LONG 24_©' OIL ,CATER SEPARAT O L/ ATER I N F L uE N T .--f SEPARATOR CLEAN OUT DRAIN - SEPARATOR CLEAN OUT DRAIN vATER EFFLuENT (GRAvITY DRAIN) SUMP -' TRANSFER PUMP FRONT 1NSPECTIN MATCH ATER EFFLUENT (TRANSFER PuHIP)' T 4;SP SYSTFu5, INC, 1i In S191.1.P(RA1O9 EJECTOR SYSTEMS, INC. 910 Na!ronal AN-enue Addison, $111ncAs 60101 (708) 543-2214 FAX 7 08-543— 2Us 4 4100— OIL -/ EA K SPECIFICATIONS FOR THE io GPM ESI STRIPPERATOR 2-18-93 The following specifications outline standard and optional equipment for the 10 gpm ES 1 Stripperator. These specifications may be altered by ESI without prior notice A. General The Stripperator is a single piece of process equipment which integrates oil/water separation and air stripping. The dimensions of the unit are 92" long X 50" wide X 65" high. Raw water will enter the unit through a 21/2* npt coupling. Separated product will exit the unit through a 11/2' npt coupling (product storage tank by others) and treated water will exit the unit through a 3' npt coupling. No process piping between the oil/water separator and air stripper will be required. Off gas will exit the unit through a 6" pipe section. The outside of the Stripperator shall be constructed of 11 gauge epoxy coated carbon steel. The Stripperator lid is secured with latches (no bolts) and constructed of 18 gauge epoxy coated carbon steel. The weight of the lid is 56 pounds. The unit shall include an effluent sump. The unit includes (3) 11/2- npt drain ports, 2 for the separator and 1 for the air stripper. The Stripperator shall be constructed to allow for pick up with a fork lift. Oil/water separator The separator portion of the stripperator shall be capable of 0-10 gpm flow rates. Separation is accomplished through the use of baffles and a clog resistant coalescing pack. The coalescing pack will be easily removed for cleaning. The separator shall be capable of removing 60 micron droplets at 40°F. The separator working volume is 95 gallons. The product effluent weir is adjustable; product will flow to an external product tank supplied by others. The spacing on the coalescing pack is 11/2" to minimize the chance of clogging and allow for easy cleaning. The pack angle shall be at a 60° angle to the bottom. Flow from the separator to the air stripper will be by gravity. No elevating of the separator is required to feed the air stripper. External piping between the separator and the air stripper will not be allowed. 'EMIE+ TO YSTEMS, INC. 910 Nal;onar Avenue Addison. Illinois 6010; (708) 543-2214 FAX 708-543-2014 1-6[l4•OIL-LEAK C. Air stripper The air stripper portion of the Stripperator is similar to the Cascade low profile air stripper as manufactured by Ejector Systems, Inc. The air stripper is designed to handle flows up to 10 gpm. This system incorporates bubbler aeration with a horizontal tray configuration to create the required mass transfer. The unit employs 6 aeration tubes and 5 baffles, The aeration tubes will be constructed of 0.035 inch thick nylon. The tubes will incorporate two rows of 5/16" diameter holes. The large diameter holes and flexible tube material will result in a minimum of fouling and cleaning effort. The blower shall be 3 hp TEFC (standard) radial -blade pressure type. Standard blower electrical input is 230 volt, single phase. Blower inlet shall be 6 inch, output shall be 400-600 cfm @ 16" w.c.. The blower shall be dynamically balanced with inlet damper and screen. Blower shall be rated for AMCA type B spark resistance. Blower and fan blade shall be constructed of cast aluminum. Removal of the Stripperator lid provides complete access for cleaning the air stripper. The air stripper includes a blower back pressure gauge. Fittings will not be allowed on the lid. Ef1"fuent sump The treated water frorn the air stripper will flow into an effluent sump. The volume of the effluent sump is 60 gallons.. The standard unit will employ gravity flow of the treated water to the final discharge point. The sump has an inspection hatch, The sump has a floor hatch to accommodate a vertical transfer pump. 2. uu5u.u.5,55t EjEGTOR SYSTEMS.NG 910 National Avenue Addisorx,Nuats 60101 (708) 543-.2214 FAX 708,543-2014 1-80(X0IL-LEAK E. Optlofts 1. Air stripper/blower a. high/low pressure switch b. Class Division II explosiort proof c. 3-phase power d, motor starter with disconnect 2. Effluent sump a. 3/4 hp vertical effluent transfer pump with controls Note: Effluent connection from the transfer pump shall be 1 ½ npt TEFC ii. explosion -proof b. high -high level switch 3.