WI0501030_Permit (Issuance)_20191004 (2)

Permit Number WI0501030
Central Files: APS _ SWP _
10/2/2019
Permit Tracking Slip
Program Category
Ground Water
Permit Type
Injection In situ Groundwater Remediation Well
Primary Reviewer
shristi.shrestha
Coastal SWRule
Permitted Flow
Facility
Status
Issued
Version
Project Type
New Project
Permit Classification
Individual
Permit Contact Affiliation
Facility Name
Former Guilford Fibers Plant
Location Address
200 Dickens Rd
Fuquay Varina
Owner
NC 27526
Major/Minor
Minor
Facility Contact Affiliation
Region
Raleigh
County
Wake
Owner Name
Lear Corporation
Dates/Events
Owner Type
Non -Government
Owner Affiliation
Jack Nunes
21557 Telegraph Rd
Southfield
MI 48033
Orig Issue
10/1/2019
App Received
8/15/2019
Regulated Activities
Draft Initiated
Scheduled
Issuance
Groundwater remediation
Outfall
Public Notice Issue
10/1/2019
Requested /Received Events
Effective
10/4/2019
Expiration
9/30/2024
RO staff report requested
RO staff report received
Additional information requested
Additional information received
8/16/19
9/16/19
9/20/19
Waterbody Name Streamlndex Number Current Class Subbasin

h
DIVISION OF WATER RESOURCES
WQROS
September 26, 2019
MEMORANDUM
TO: FILE / Jay Zimmerman
FROM: Shristi Shrestha
RE: Issuance of permit to inject (Permit #WI0501030)
Former Guilford Fibers Plant
Wake County
I recommend that Permit Number WI0501030 be issued to the above to inject the following additive(s) to remediate
groundwater (GW) contaminated with Chlorinated solvents: Electron Donor Solution (EDS-ER).
SITE DESCRIPTION: The site is a former textile manufacturing facility which used to produce polyester fibers. TCE and
other chemicals were used for parts cleaning before 1991. Assessment activities have concluded that gravel pit (#2) located
at the MW-12 well nest is impacted by chlorinated volatile organic compounds. (refer page 2 application)
HYDROGEOLOGIC DESCRIPTION: The site is located in Coastal Plain Physiographic Province of North Carolina. The fall
line, which separates the Coastal Plain and Piedmont Physiographic Provinces passes through Wake County to the west of
the Site. The site is located within the Surficial and Black Creek Aquifers.
Middle Creek watershed area of the Neuse River Basin is the location of the site. Groundwater flow at the site is towards
North-northeast. The reported seepage velocity for shallow aquifer ranges from 76ft/yr. to 2.2*453 ft./yr. The reported
seepage velocity for intermediate zone is from 12ft/yr. to 20ft/yr. (refer to Attachment 2)
EXTENT OF CONTAMINATION: The groundwater contamination plume(s) are large and vary in shape and size and exists in
all zones from the water table wells to the bedrock wells. (Refer to Figures 7-9)
PROPOSED INJECTION: A total of 66 injection wells are proposed to be installed. There is one injection event planed
over 35- 40 days. The injectant EDS-ER will be mixed with potable water in a poly -tank prior to injection. The flow rates
will be approximately 1 GPM and estimated average injection pressure for the wells will be 1-10 psi. Based upon the size
of the plumes in the shallow aquifer (1500 ft. long and 750 ft. wide) and the amount of additives to be injected together with
water (410,000 gallons), the potential plume displacement will be negligible.
Total no. of
Appx avg.
Total Gallons injectant into
well points
amount to be
injected into
each
well/event
all wells/event
(gallons)
66
6200
410,000
HOW IT WORKS: EDS-ER (proposed injectant) when mixed with water forms EVO (emulsified vegetable oil) which
forms a long lasting source of food for the microbes that help in anaerobic degradation of chlorinated volatile organic
compounds present at the site. (Refer to attachment 3)

MONITORING: A baseline groundwater sampling will be done before injection. Two performance groundwater monitoring
events will be done at 60 and 180 days following the source area injection. Details of the monitoring plan is listed in
Attachment 7.
EPIDEMIOLOGY: The DIMS has approved the injectant(s).
REGIONAL OFFICE COMMENTS: Each of the RO comments/recommendations are discussed below (RO's
comments/recommendations are underlined).
After review of an additional information received by the RO, Brion Byers and Rick Bolich of the Raleigh RO, did not
have any issues and recommends issuance of this permit.
1. Recommend approval of the permit on condition that source water for diluting EDS-ER will be not derived from WSW#2.
The consultant has communicated this in the attached email from 9/20/19 that municipal water source will be used. This
has been added as permit condition III.3.
2. Based on findings in the application, specifically detection of chlorinated compounds above 2L Standards in Guilford
PW (WSW#2) which penetrates multiple fracture zone, RRO recommends abandonment of WSW#2. This request has been
added as a permit condition III.2.
The Raleigh Regional Office recommends permit issuance.

5I Calculations Worksheet
Applicant/Facility: Le-'-. pywvart., 6 tA4.1i-enoet F aehQ i «'
Permit No. WI 050103 b
Date: /2 6 /) 0 / /
Reviewer: 54-
Depth to groundwater (GW): f • St — 3 e'S BLS
GW flow direction: Neltil, ll/M.14 C4
MWs installed in same aquifer as injection? If (Y or N); Inj zone: 20'20 .74T_ 6G5 MW zone: 6 -& E. a• ed. S
Nearest water supply well: L
Groundwater Flow Rate
HC X adient(FT?) = flow rate/DAY(?) X 365 = FT/YR
SY or porosity ((.30)
[FYI- 60 min. X 24 hrs X 365 days = 525,600]
Calculations for Potential Contaminate Plume Displacement
IS'v0 7-5o
37142-0) X r2 X 6 O height = 6 9-, S 0 (0 1 000 CF
yr, S'tia„ C[aw 24• u2:3
6a, tOV 0 0 0 CF X 0.3 SY or porosity (i.e. —.30) = 2012 SD, CO 0
space
Reported:MIA/ (D ., - 2.2.xit5?
't
a: /2.-'2y �ta
CF of available void
2-0, 2 f O d 0 0 CF of available void space X 7.48 gallons = i S /, 4 te.., 6u goallons of water in void sp
0, 2-7-
`? MAC 0 gallons of injectant = % offluid displaced by injectant (move decimal)
/ S i "0/ 00 O gallons of water in void space
Potential displacement of plume by injection: i(y G
Injection Volume and Pumping Rate Per Well Per Day
zt-,0, 000
total amt. of injectant / 6 re number of wells / 0 number of days of injection event =
& amount of injectant per well per day (average gallons per day)
S:UIC/Applications and forms/ 51 Calculations worksheet version 9/10/10

ROY COOPER.
Governor
MICHAEL S. REGAN
Secretary
LINDA CULPEPPER
Director
Jack Nunes
Lear Corporation
21557 Telegraph Road
Southfield, MI 48033
NORTH CAROLINA
Envtronmentat Quality
October 4, 2019
Re: Issuance of Injection Permit WI0501030
Former Guilford Fibers Plant
Wake County, NC
Dear Mr. Nunes:
In accordance with the permit application received on August 15, 2019, and additional information
received September 20, 2019, we are forwarding permit number WI05001030. This permit is to inject
EDS-ER to remediate groundwater contaminated with Chlorinated solvents at the Former Guilford
Fibers Facility, 200 Dickens Road, Fuquay-Varina, Wake County, NC 27526
This permit shall be effective from date of issuance until September 30, 2024, and shall be subject to
the conditions and limitations stated therein, including the requirement to submit a Final Project
Evaluation (FPE) as stated in PART VII — MONITORING AND REPORTING REQUIREMENTS.
Please read the entire permit to ensure that you are aware of all compliance requirements of the permit.
Please note the following:
• Per permit condition Part III.2, due to contamination present in the Water Supply well #2
the Permitee shall abandon the well with proper measure as stated in 15A NCAC 02C .0113(b).
• Per permit condition Part I11.3, municipal water source will be used for mixing EDS-ER.
• Per permit condition Part VI.1, the proposed monitoring plan as submitted in the application
from August 15, 2019 shall be followed.
North Carolina Department of Environmental Quality I • Division of Water Resources
512 North Salisbury Street 11636 Mall Service Center I Raleigh, North Carolina 27699-1636
919.707.9000

• Per permit condition Part VI.5, prior to closing this permit, the Permittee must meet
groundwater quality standards or pre -injection levels, whichever concentration is higher, for
all of the injection constituents; otherwise, continued monitoring as approved in the monitoring
plan will be required until such levels can be established;
• Per permit conditions Part VI.3 &4, and IX.2(G), within 30 days after each injection event,
please provide the well construction (if not previously submitted) and injection information on
the applicable forms listed below. Note: if well construction/abandonment information is
essentially the same (e.g., direct push points or geo-probes), then only one GW-1 or GW-30
form is needed. Just indicate in the comments section on the form the total number of well
points. These forms are available on the Division of Water Resources' website at
http ://deq.nc. gov/about/divisions/water-resources/water-resources-permits/wastewater-
branch/ground-water-protection/ground-water-rep orting-forms
> Injection Event Record
> Well Construction Record (GW-1)
> Well Abandonment Record (GW-30)
In order to continue uninterrupted legal use of this well for the stated purpose, you should submit an
application to renew the permit 120 days prior to its expiration date. As indicated in the permit, this
permit is not transferable to any person without prior notice to, and approval by, the Director of the
Division of Water Resources. If you have any questions regarding your permit or the Underground
Injection Control Program, please call me at [phone].
Best Regards,
Shristi Shrestha
Underground Injection Control (UIC) - Hydrogeologist
Division of Water Resources
Water Quality Regional Operations Section
cc: Rick Bolich and Brion Byers, WQROS — Raleigh Regional Office
Central Office File, WI05001030
Bonani Langan, Wood Environment & Infrastructure Solutions Inc., 4021 Stirrup Creek Drive,
Suite 100, Durham NC 27703

NORTH CAROLINA
ENVIRONMENTAL MANAGEMENT COMMISSION
DEPARTMENT OF ENVIRONMENTAL QUALITY
RALEIGH, NORTH CAROLINA
PERMIT FOR THE USE OF A WELL FOR INJECTION
In accordance with the provisions of Article 7, Chapter 87; Article 21, Chapter 143; and other
applicable Laws, Rules, and Regulations
PERMISSION IS HEREBY GRANTED TO
Former Guilford Fibers Facility
FOR THE CONSTRUCTION AND OPERATION OF 66 (Sixty-six) IN SITU REMEDIATION /
TRACER INJECTION WELLS, defined in Title 15A North Carolina Administrative Code 2C
.0209(5)(b)(viii), to inject the following additives (either individually or in combination): EDS-
ER together with potable water, for the remediation of groundwater contaminated with Chlorinated
solvents. These injection wells/points will be located at the Former Guilford Fibers Facility, 200
Dickens Road, Fuquay-Varina, Wake County, NC 27526 and will be operated in accordance with
the permit application submitted August 15, 2019, and in conformity with the specifications and
supporting data submitted September 20, 2019, all of which are filed with the Department of
Environmental Quality and are considered a part of this permit.
This permit is for Construction and Operation only and does not waive any provisions of the Water
Use Act or any other applicable Laws, Rules, or Regulations. Operation and use of an injection
well shall be in compliance with Title 15A North Carolina Administrative Code 02C .0100 and
.0200, and any other Laws, Rules, and Regulations pertaining to well construction and use.
This permit shall be effective, unless revoked, from date of its issuance until September 30, 2024.
Permit issued this the 4th day of October 2019.
For Linda Culpepper, Director
Division of Water Resources
By Authority of the Environmental Management Commission.
Permit No. WI0501030 PAGE 1 OF 7
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PART I — PERMIT GENERAL CONDITIONS
1. The Permittee shall comply with all conditions of this permit and with the standards and criteria
specified in Criteria and Standards Applicable to Injection Wells (15A NCAC 2C .0200).
Noncompliance with conditions of this permit constitutes a violation of the North Carolina
Well Construction Act and is grounds for enforcement action as provided for in N.C.G.S. 87-
94.
2. This permit shall become voidable unless the facility is constructed in accordance with the
conditions of this permit, the approved plans and specifications, and other supporting data [15A
NCAC 02C .0211(1)].
3. This permit is valid only for construction or operation of the number of injection wells
described in the application and other supporting data. Construction of additional injection
wells must be approved in advance by the Division of Water Resources (DWR) [15A NCAC
.0211(a)].
4. This permit is not transferable without prior notice and approval. In the event there is a desire
for the facility to change ownership, or there is a name change of the Permittee, a formal permit
amendment request and any supporting materials must be submitted at least 30 days prior to
the date of the change [15A NCAC 02C .0211(q)].
5. The issuance of this permit shall not relieve the Permittee of the responsibility of complying
with any and all statutes, rules, regulations, or ordinances that may be imposed by other local,
state, and federal agencies having jurisdiction. Furthermore, the issuance of this permit does
not imply that all regulatory requirements have been met [15A NCAC 02C .0203].
PART II - WELL CONSTRUCTION GENERAL CONDITIONS
1. Each injection well shall not hydraulically connect separate aquifers [15A NCAC 02C
.0211(c)].
2. Multi -screened wells shall not hydraulically connect different aquifers or zones having
differences in water quality that would result in a degradation of any aquifer or zone [15A
NCAC 02C .0225(g)(17)].
3. Each injection well shall be constructed in such a manner that water from land surface cannot
migrate into the gravel pack or well screen [15A NCAC 02C .0225(g)(4)].
4. Bentonite grout shall not be used to seal any water -bearing zone with a chloride concentration
equal to or greater than 1,500 milligrams per liter. In areas where elevated chloride levels are
known to exist or are probable, such as coastal areas, chloride levels shall be verified in the
field to determine existing conditions. [15A NCAC .0225(g)(8)].
5. Each injection well shall be secured to reasonably insure against unauthorized access and use.
Each well shall be permanently labeled with a warning that it is for injection purposes and the
entrance to each well shall be secured with a locking cap as defined in G.S. 87-85(16) [15A
NCAC 02C .0225(g)(23)].
Permit No. W10501030 PAGE 2 OF 7
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6. Each injection well shah be afforded reasonable protection against damage during construction
and use [15A NCAC 02C .0225(i)(3)].
7. Each permanent injection well shall have a permanently affixed identification plate [15A
NCAC .0225(g)(20)].
8. A copy of the completed Well Construction Record (Form GW-1) shall be submitted as
described in Part VI.3 of this permit (the original document goes to the address indicated on
the form).
PART III - WELL CONSTRUCTION SPECIAL CONDITIONS
1. At least forty-eight (48) hours prior to constructing or operating each injection well, the
Permittee shall notify the Underground Injection Control (UIC) Central Office staff, telephone
number 919-807-6406, and the Raleigh Regional Office staff, telephone number 919-791-4200
[15A NCAC 02C .0219(d)(1)].
2. Due to contamination present in the Water Supply well #2, the Permitee shall abandon the
well with proper measure as stated in 15A NCAC 02C .0113(b).
3. The Permitee shall as stated in the additional information received on September 20, 2019, use
municipal water source for mixing EDS-ER at the site.
PART IV - OPERATION AND USE CONDITIONS
1. The Permittee shall be required to comply with the terms and conditions of this permit even
if compliance requires a reduction or elimination of the permitted activity [15A NCAC 02C
.0211(j)].
2. The issuance of this permit shall not relieve the Permittee of the responsibility for damages
to surface water or groundwater resulting from the operation of this facility [15A NCAC 02C
.0206].
3. The injection facility shall be properly maintained and operated at all times to achieve
compliance with the conditions of this permit and the rules of 15A NCAC 02C .0200, even
if compliance requires a reduction or elimination of the permitted_ activity [15A NCAC 02C
.0211(j)].
4. In the event that the facility fails to perform satisfactorily resulting in the creation of nuisance
conditions, failure of the injection zone to adequately assimilate the injected fluid, or
daylighting, the Permittee shall take immediate corrective actions including, but not limited
to, repairs, modifications, or abandonment of the injection facility. The Permitee shall report
non-compliance according to Part VI.7 of this permit [15A NCAC 02C .0206].
Permit No: W10501030 PAGE 3 OF 7
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PART V - INSPECTIONS [15A NCAC 02C .0211(k)]
1. Any duly authorized officer, employee, or representative of the Division of Water Resources
(DWR) may, upon presentation of credentials, enter and inspect any property, premises, or
place on or related to the injection facility at any reasonable time for the purpose of determining
compliance with this permit, may inspect or copy any records that must be maintained under
the terms and conditions of this permit, and may obtain samples of groundwater, surface water,
or injection fluids.
2. DWR representatives shall have reasonable access for purposes of inspection, observation, and
sampling associated with injection and any related facilities as provided for in N.C.G.S. 87-
90.
3. Provisions shall be made for collecting any necessary and appropriate samples associated with
the injection facility activities.
PART VI - MONITORING AND REPORTING REQUIREMENTS
1. The proposed monitoring plan received on August 15, 2019, shall be followed. Any additional
monitoring, including groundwater, surface water, or soil sampling, deemed necessary to
ensure surface water and groundwater protection may be established and an acceptable
sampling reporting schedule shall be followed [15A NCAC 02C .0225(j)].
2. An Annual Report with all historical monitoring results shall be submitted in bound hard copy
format with attached CD or flash drive to the AFOGPB Central Office, and Raleigh Regional
Office starting from date permit is issued. Monitoring reports shall include, a summary of
injection activities and monitoring results, analytical data presented in a spreadsheet
distinguishing between pre -injection and post injection data, and an update on the status and
location of monitoring and injection wells. Well locations may be given in a table with the
name and geographic coordinates or shown on an updated version of the site map [15A NCAC
02C .0225(k)(2)].
3. Records of well construction, repair, or abandonment shall be submitted within 30 days of
completion of such activities [15A NCAC 02C .0225(k)(1)(A)].
4. An Injection Event Record shall be submitted within 30 days of each injection event [15A
NCAC 02C .0225(k)(1)(B)].
5. The Permittee shall submit a Final Project Evaluation (FPE) within 9 months after completing
all injection -related activity associated with this permit or produce an interim evaluation to be
submitted with a renewal application for this permit. Both the final project evaluation and
interim evaluation shall contain historical monitoring data and updated contaminant plume and
potentiometric surface maps. PLEASE NOTE: Injectants and related reaction byproducts must
attenuate to pre -injection concentrations or groundwater standards specified in rule 15A NCAC
02L .0202, whichever is greater, in order for this permit to be closed. Otherwise, corrective
action as described in Part VII may be required [15A NCAC 02C .0225(k)(2)].
Permit No. WI0501030 PAGE 4 OF 7
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6. All monitoring results, forms, and reports required in this Part shall be submitted to:
UIC Program Water Quality Regional Operations Section
NC Division of Water Resources and DWR Raleigh Regional Office
1636 Mail Service Center 1628 Mail Service Center
Raleigh, NC 27699-1636 Raleigh, NC 27699
7. The Permittee shall report any monitoring or other information that indicates noncompliance
with a specific permit condition, that a contaminant may cause a violation of applicable
groundwater quality standards, or that a malfunction of the injection system may cause the
injected fluids to migrate outside the approved injection zone or area. As specified in rule 15A
NCAC 02C .0211(r), noncompliance notification shall be as follows:
(A) Oral notification shall be given within 24 hours of the occurrence, or first knowledge
of the occurrence, to the Raleigh Regional Office, telephone number 919-791-4200.
(B) Written notification shall be made within five days of the occurrence and submitted
to the addresses in Item #6 above.
(C) The written notification shall contain a description of the noncompliance and its
cause; the period of noncompliance, including dates and times; if the noncompliance
has not been corrected, the anticipated time it is expected to continue; and any steps
taken or planned to reduce, eliminate, and prevent reoccurrence of the
noncompliance.
8. Where the Permittee becomes aware of an omission of any relevant facts in a permit
application, or of any incorrect information submitted in said application or in any report to
the Director, the relevant and correct facts or information shall be promptly submitted to the
Director by the Permittee [15A NCAC 02C .0211(b)].
PART VII - CORRECTIVE ACTION [15A NCAC 02C .0206]
1. Any injection well not constructed or operated in accordance with this permit, or the criteria
and standards specified in 15A NCAC 02C .0200, shall be subject to corrective action as
provided under rule 15A NCAC 02C .0206.
2. The following corrective actions shall apply to elevated concentrations of inj ectants or reaction
byproducts resulting from the permitted injection activity:
(A) Continued monitoring until concentrations return to pre -injection values or meet the
standards specified in 15A NCAC 02L .0202, whichever are greater. The frequency,
duration, and location of monitoring shall be appropriate for site specific conditions and
potential receptors.
(B) Groundwater quality parameters that do not attenuate as described in 2(A) above may
warrant a corrective action plan as provided under rule 15A NCAC 02C .0206, depending
on the type, concentration, and distribution of the groundwater quality standards being
exceeded.
Permit No. W10501030 PAGE 5 OF 7
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PART VIII - PERMIT RENEWAL [15A NCAC 02C .0211(b)]
In order to continue uninterrupted legal use of the injection facility for the stated purpose, the
Permittee should submit an application to renew the permit 120 days prior to its expiration date.
PART IX - CHANGE OF WELL STATUS [15A NCAC 02C .0240]
1. The Permittee shall provide written notification within 15 days of any change of status of an
injection well. Such a change would include the discontinued use of a well for injection. If a
well is taken completely out of service temporarily, the Permittee must install a sanitary seal.
If a well is not to be used for any purpose that well must be permanently abandoned according
to 15A NCAC 2C .0240, Well Construction Standards.
2. When operations have ceased at the facility and a well will no longer be used for any purpose,
the Permittee shall abandon that injection well in accordance with the procedures specified in
15A NCAC 2C .0240, including but not limited to the following:
(A) All casing and screen materials may be removed prior to initiation of abandonment
procedures if such removal will not cause or contribute to contamination of the
groundwaters.
(B) The entire depth of each well shall be sounded before it is sealed to insure freedom
from obstructions that may interfere with sealing operations.
(C) The well shall be thoroughly disinfected, prior to sealing, if WQROS staff determines
that failure to do so could lead to the contamination of an underground source of
drinking water.
(D) Drilled wells shall be completely filled with cement grout or bentonite grout, which
shall be introduced into the well through a pipe which extends to the bottom of the well
and is raised as the well is filled.
(E) In the case of gravel -packed wells in which the casing and screens have not been
removed, neat -cement, or bentonite grout shall be injected into the well completely
filling it from the bottom of the casing to the top.
(F) In those cases when, as a result of the injection operations, a subsurface cavity has been
created, each well shall be abandoned in such a manner that will prevent the movement
of fluids into or between underground sources of drinking water and in accordance with
the terms and conditions of the permit.
(G) The Permittee shall submit a Well Abandonment Record (Form GW-30) as specified
in 15A NCAC 2C .0225(k)(1)(A) within 30 days of completion of abandonment.
Permit No. WI0501030 PAGE 6 OF 7
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3. The written documentation required in Part IX (1) and (2)(G) shall be submitted to:
UIC Program
DEQ - Division of Water Resources
1636 Mail Service Center
Raleigh, NC 27699-1636
PART X — WORKER PRECAUTIONS DURING APPLICATION [15A NCAC 02C
.0225(a)]
1. Some effects reported to be associated with the product proposed to be used are as follows:
eye, skin, nose, throat, and lung irritation. If the product is released into the environment in a
way that could result in a suspension of fine solid or liquid particles (e.g., grinding, blending,
vigorous shaking or mixing), then proper personal protective equipment should be used. The
application process should be reviewed by an industrial hygienist to ensure that the most
appropriate personal protective equipment is used.
2. Persons working with these products should wear goggles or a face shield, gloves, and
protective clothing. Face and body protection should be used for anticipated splashes or
sprays.
3. Eating, drinking, smoking, handling contact lenses, and applying cosmetics should not be
permitted in the application area during or immediately following application.
4. Safety controls should be in place to ensure that the check valve and the pressure delivery
systems are working properly.
5. The Material Safety Data Sheets should be followed to prevent incompatible or adverse
reactions and injuries.
Permit No. WI0501030 PAGE 7 OF 7
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