WI0800206_Permit (Issuance)_20110120

MEMORANDUM
TO:
FROM:
THROUGH: Thomas Slusser �s
DIVISION OF WATER QUALITY
AQUIFER PROTECTION SECTION
Debra Watts
Michael Rogers.
January 13, 2011
RE: Issuance of permit to inject magnesium sulfate (Epsom salt) (Permit #WI0800206)
Conoco Phillips - Former Conoco Store #33051
I recommend that Permit Number WI0800206 be issued to Conoco Phillips to inject the above referenced injectant(s) to
remediate groundwater (GW) contaminated with petroleum hydrocarbons.
SITE DESCRIPTION: The site is a former Conoco Service Station (Store #33051) located at 2636 Castle Hayne Road,
New-14tarrover County, NC 223,42< It is still being used as a service station, but under different ownership.
During the replacement of 2000 gallons underground petroleum storage tanks in 1994, petroleum contamination was
discovered in the soil and groundwater. Since the reporting of the contamination, the site has undergone groundwater
gremediation through various techniques. The Applicant is now looking at an alternative remediation process (Figures 1
and 2).
HYDROGEOLOGIC DESCRIPTION: The site is located within the Coastal Plain geologic province. In the area of the site, the
overburden consists primarily of surficial deposits of sand interbedded with sandy clay lenses. Below this sand is a clay
layer, and below the clay is the Castle Hayne Formation, which consists primarily of limestone. Injection will be in the
surficial deposits. Depth to groundwater averages 11.5 feet BLS. Groundwater flow direction is generally west at 38
feet/year (Figure 8).
EXTENT OF CONTAMINATION: The benzene and MTBE plumes are not clearly delineated,. but groundwater contamination is
evident across Castle Hayne Road to the west (Figures 5 and 6). According to the information provided there are several
private water supply wells within 1/4 mile. The nearest well appears to be adjacent upgradient to the site (Figure 12).
PROPOSED INJECTION: The proposed injection will be via 6 proposed permanently installed wells in the plume. Initially,
the Applicant was going to install 4 new wells and use 2 existing vapor extraction wells for injection; but as they could not
provide well construction informationfor the VE wells, they agreed to install 6 new wells instead. There will be a pilot
study injection and 2 follow-up full-scale injections for a total of 3 injection events with 6 months in between events.
Injectants will be gravity fed. The information for the injection is below.
Injection
Well(s)
PIW-1
through
PIW-6
Total AMT of
Injectant (gal)
TOTAL
800
Approximate
Days for
Injection
3
Appx. AMT
of Injectant
Per Well Per
Day (gal)
44
Estimated
AMT of Fluid
Displacement
1%
Potential
Displacement
of Plume
Low
800 3
The injection wells are highlighted in yellow on Figures 9R and 10R.

HOW IT WORKS: The Applicant is proposing to use magnesium sulfate (Epsom salt). This product will remediate
groundwater contaminated with petroleum hydrocarbons by stimulation of the biologic community (bioremediation)
resulting in oxidation of the contaminants.
MONITORING: The wells to be monitored are highlighted in yellow on Figure 11. I have requested they modify the monitoring
plan as originally submitted to include collecting groundwater elevation data from all wells for the preinjection monitoring event
as the groundwater contour map that was included in the application package was based on data collected March 2010.
Monitoring events will include a pre -injection, then one month, 2 months, 3 months, and at 6 months.
EPIDEMIOLOGY: The DHHS has approved the above compounds as injectants.
REGIONAL OFFICE COMMENTS: Each of the RO comments/recommendations are discussed below (RO's
comments/recommendations are underlined).
Charlie Stehman of the Wilmington Regional Office did not have any comments and recommends issuance of the permit.

5I Calculations Worksheet
Applicant/Facility: (.60 A) 0 c.-0 Lc -Li P(
Permit No. WI 8 4 01,6
Date: Oyi D
Reviewer:) 6-657
Depth to groundwater (GW): N //. S� BLS
GW flow direction:
/ o t, AAA., , S` efC — , je 5�
MWs installed in same aquifer as injection? j / (Y or N); Inj zone: �i-7 MW zone: y J'.-- dr
Nearest water supply well: /412) Si A (.1, gr c �
Groundwater Flow Rate U
•30
X . OO$? gradient(FT?) _./®1/72.. flow rate/DAY(?) X 365
SY or porosity (—.30)
[FYI- 60 min/day X 24 hrs X 365 days = 525,600]
Calculations for Potential Contaminate Plume Displacement
60j< /oho
r2 X . height = 2 6 o v v CF
=
FT/YR
Reported: L'
2 4003 CF X . 30 SY or porosity (i.e. —.30) = /J 8 O 0 CF of available void
spac
e0-0 CF of available void space X 7.48 gallons = 89y gallons of water in void sp
ROO gallons of injectant =
gallons of water in void space
% of fluid displaced by injectant (move decimal)
Potential displacement of plume by injection: GO [.J
Injection Volume and Pumping Rate Per Well Per Day
Boo
total amt. of injectant / 6 number of wells / _ number of days of injection event
amount of injectant per well per day (average gallons per day)
S:UIC/Applications and forms/ 5I Calculations worksheet version 9/10/10

5I Calculations Worksheet
o £s Plisse
Notes
A o< E .
c�•• �i�k — l'c
v y 4
/vrk.) e
W `- S� /S
y�
5=1-
M w17—
�
1ST" .� :0- /S.
S:UIC/Applications and forms/ 5I Calculations worksheet version 9/10/10

NORTH CAROLINA
ENVIRONMENTAL MANAGEMENT COMMISSION
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
RALEIGH, NORTH CAROLINA
PERMIT FOR THE CONSTRUCTION AND OPERATION OF A WELL FOR INJECTION
In accordance with the provisions of Article 7, Chapter 87; Article 21, Chapter 143, and other
applicable Laws, Rules, and Regulations
PERMISSION IS HEREBY GRANTED TO
Conoco Phillips
FOR THE CONSTRUCTION AND/OR OPERATION OF 6 TYPE 5I INJECTION WELLS, defined
in Title 15A North Carolina Administrative 2C .0209(e)(3)(C), to inject magnesium sulfate (Epsom
salt) for the enhanced bioremediation of petroleum hydrocarbons. These injection wells/points will
be located at the Former Conoco Store #33051, 2636 Castle Hayne Road, Wilmington, New Hanover
County, NC 28401, and will be operated in accordance with the application submitted August 23,
2010, and in conformity with the specifications and supporting data submitted, September 13, 2010,
and December 23, 2010, all of which are filed with the Department of Environment and Natural
Resources and are considered a part of this permit.
This permit is for Construction and Operation only, and does not waive any provisions of the Water
Use 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 2C .0100 and .0200, and
any other Laws, Rules, and Regulations pertaining to well construction and use.
This permit shall be effective, unless revoked, from the date of its issuance until December 31, 2013,
and shall be subject to the specified conditions and limitations set forth in Parts I through X hereof.
Permit issued this the 20th day of January, 2011.
Coleen H. Sullins, Director
Division of Water Quality
By Authority of the Environmental Management Commission.
Permit No. WI0800206 PAGE 1 OF 6
ver. Oct.2010 AP/UIC-6

PART I - WELL CONSTRUCTION GENERAL CONDITIONS
1. The Permittee must comply with all conditions of this permit and with the standards and criteria
specified in Criteria and Standards Applicable to Injection Wells (15A NCAC 2C .0200). Any
noncompliance with conditions of this permit constitutes a violation of the North Carolina Well
Construction Act and is grounds for enforcement action as provided for in N.C.G.S. 87-94.
This permit shall become voidable unless the facility is constructed in accordance with the
conditions of this permit, the approved plans and specifications, and other supporting data.
3. This permit is valid only for construction of the number of injection wells described in the
application and other supporting data. Construction of additional injection wells must be
approved in advance by the Aquifer Protection Section.
4. Each injection well shall not hydraulically connect separate aquifers.
5. Each injection well shall be constructed in such a manner that water from land surface cannot
migrate into the gravel pack or well screen.
6. Each injection well shall be secured to reasonably insure against unauthorized access and use.
Each well shall be permanently labeled with a warning that it is for injection purposes and the
entrance to each well must be secured with a locking cap.
7. Each injection well shall be afforded reasonable protection against damage during construction
and use.'
8. Each injection well shall have permanently affixed an identification plate.
9. Within 30 days of completion of well construction, a completed Well Construction Record
(Form GW-1) must be submitted for each injection well to:
Aquifer Protection Section-UIC Program
DENR-Division of Water Quality
1636 Mail Service Center
Raleigh, NC 27699-1636
PART II - WELL CONSTRUCTION SPECIAL CONDITIONS
At least forty-eight (48) hours prior to constructing each injection well, the Permittee shall notify the
Aquifer Protection Section -Underground Injection Control (UIC) Central Office staff, telephone
number [phone] and the Wilmington Regional Office Aquifer Protection Section Staff,
telephone number [phone].
Permit No. WI0800206 PAGE 2 OF 6
ver. Oct.2010. AP/UIC-6

PART III - OPERATION AND USE GENERAL CONDITIONS
1. This permit is effective only with respect to the nature, volume of materials, rate of injection, and
number of injection wells as described in the application and other supporting data.
2. This permit is not transferable without prior notice to, and approval by, the Director of the
Division of Water Quality (Director). In the event there is a desire for the facility to change
ownership, or there is a name change of the Permittee, a formal permit amendment request must
be submitted to the Director, including any supporting materials as may be appropriate, at least
30 days prior to the date of the change.
3. The issuance of this permit shall not relieve the Permittee of the responsibility of complying with
any and all statutes, rules, regulations, or ordinances which may be imposed by other local, state,
and federal agencies which have jurisdiction. Furthermore, the issuance of this permit does not
imply that all regulatory requirements have been met.
PART IV - PERFORMANCE STANDARDS
1. The injection facility shall be effectively maintained and operated at all times so that there is no
contamination of groundwater which will render it unsatisfactory for normal use. In the event
that the facility fails to perform satisfactorily, including the creation of nuisance conditions or
failure of the injection zone to adequately assimilate the injected fluid, the Permittee shall take
immediate corrective actions including those actions that may be required by the Division of
Water Quality such as the repair, modification, or abandonment of the injection facility. '
2. The Permittee shall be required to comply with the terms and conditions of this permit even if
compliance requires a reduction or elimination of the permitted activity.
3. The issuance of this permit shall not relieve the Permittee of the responsibility for damages to
surface or groundwater resulting from the operation of this facility.
PART V - OPERATION AND MAINTENANCE REQUIREMENTS
1. The injection facility shall be properly maintained and operated at all times.
2. The Permittee must notify the Division and receive prior written approval from the Director of
any planned alterations or additions in the permitted facility or activity not specifically
authorized by the permit.
3. At least forty-eight (48) hours prior to the initiation of the operation of the facility for injection,
the Permittee must notify by telephone the Aquifer Protection Section-UIC, Central Office staff,
telephone number [phone]. Notification is required so that Division staff can inspect or
otherwise review the injection facility and determine if it is in compliance with permit
conditions.
Permit No. WI080O206 PAGE 3 OF 6
ver. Oct.2010 AP/UIC-6

PART VI - INSPECTIONS
1. Any duly authorized officer, employee, or representative of the Division of Water Quality may,
upon presentation of credentials, enter and inspect any property, premises, or place on or related
to the injection facility at any reasonable time for the purpose of determining compliance with
this permit, may inspect or copy any records that must be maintained under the terms and
conditions of this permit, and may obtain samples of groundwater, surface water, or injection
fluids.
2. Department representatives shall have reasonable access for purposes of inspection, observation,
and sampling associated with injection and any related facilities as provided for in N.C.G.S. 87-
90.
3. Provisions shall be made for collecting any necessary and appropriate samples associated with
the injection facility activities.
PART VII - MONITORING AND REPORTING REQUIREMENTS
1. The proposed revised monitoring plan included in the application shall be followed. All sample
results shall be submitted to the Aquifer Protection Section's Wilmington Regional Office and
the Raleigh Central Office. Any monitoring (including groundwater, surface water, or soil
sampling) deemed necessary by the Division of Water Quality to ensure surface and ground
water protection, will be established and an acceptable sampling reporting schedule shall be
followed.
2. The Permittee shall submit an Injection Event Record within 30 days of completing each
injection.
3. The Permittee shall produce a final project evaluation within 9 months after completing all
injection -related activity associated with this permit or produce a project interim evaluation
before submitting a renewal application for this permit. This document shall assess the injection
projects findings in a written summary. The final project evaluation shall also contain
monitoring well sampling data, contaminant plume maps and potentiometric surface maps.
4. The monitoring results and the final project evaluation shall be submitted to:
and to:
Aquifer Protection Section-UIC Program
DENR-Division of Water Quality
1636 Mail Service Center
Raleigh, NC 27699-1636
Aquifer Protection Section
DENR-DWQ Wilmington Regional Office
127 Cardinal Drive Extension
Wilmington, NC 28405
Permit No. WI0S00206 PAGE 4 OF 6
ver. Oct.2010 AP/UIC-6

5. The Permittee shall report by telephone, within 48 hours of the occurrence or first knowledge of
the occurrence, to the Wilmington Regional Office, telephone number [phone], any of the
following:
(A)Any occurrence at the injection facility which results in any unusual operating
circumstances;
(B) Any failure due to known or unknown reasons, that renders the facility incapable of
proper injection operations, such as mechanical or electrical failures.
6. Where the Permittee becomes aware of an omission of any relevant facts in a permit application,
or of any incorrect information submitted in said application or in any report to the Director, the
relevant and correct facts or information shall be promptly submitted to the Director by the
Permittee.
7. In the event that the permitted facility fails to perform satisfactorily, the Permittee shall take such
immediate action as may be required by the Director.
PART VIII - PERMIT RENEWAL
In order to continue uninterrupted legal use of the injection facility for the stated purpose, the
Permittee must submit an application to renew the permit 120 days prior to its expiration date.
PART IX - CHANGE OF WELL STATUS
1. The Permittee shall provide written notification within 15 days of any.change'of status of an
injection well. Such a change would include the discontinued use of a well for injection. If a
well is taken completely out of service temporarily, the Permittee must install a sanitary seal. If a
well is not to be used for any purpose that well must be permanently abandoned according to
15A NCAC 2C .0214, Well Construction Standards.
2. When operations have ceased at the facility and a well will no longer be used for any purpose,
the Permittee shall abandon that injection well in accordance with the procedures specified in
15A NCAC 2C .0214, including but not limited to the following:
(A) All casing and screen materials may be removed prior to initiation of abandonment
procedures if such removal will not cause or contribute to contamination of the
groundwaters.
(B) The entire depth of each well shall be sounded before it is sealed to insure freedom from
obstructions that may interfere with sealing operations.
(C) The well shall be thoroughly disinfected, prior to sealing, if the Director determines that
failure to do so could lead to the contamination of an underground source of drinking
water.
Permit No. WI08000 PAGE 5 OF 6
ver. Oct.201 0 AP/UIC-6

(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 bentonitc grout shall be injected into the well completely filling
it from the bottom of the casing to the top.
(F) In those cases when, as a result of the injection operations, a subsurface cavity has been
created, each well shall be abandoned in such a manner that will prevent the movement
of fluids into or between underground sources of drinking water and in accordance with
the terms and conditions of the permit.
(G) The Permittee shall submit a Well Abandonment Record (Form GW-30) as specified in
15A NCAC 2C .0213(h)(1) within 30 days of completion of abandonment.
3. The written documentation required in Part IX (1) and (2) (G) shall be submitted to:
Aquifer Protection Section-UIC Program
DENR-Division of Water Quality
1636 Mail Service Center
Raleigh, NC 27699-1636
PART X — WORKER PRECAUTIONS DURING APPLICATION
1. Some effects reported to be associated with the product proposed to be used are as follows: eye,
skin, nose, throat, and lung irritation. If the product is released into the environment in a way
that could result in a suspension of fine solid or liquid particles (e.g., grinding, blending,
vigorous shaking or mixing), then proper personal protective equipment should be used. The
application process should be reviewed by an industrial hygienist to ensure that the most
appropriate personal protective equipment is used.
2. Persons working with these products should wear goggles or a face shield, gloves, and protective
clothing. Face and body protection should be used for anticipated splashes or sprays.
3. Eating, drinking, smoking, handling contact lenses, and applying cosmetics should not be
permitted in the application area during or immediately following application.
4. Safety controls should be in place to ensure that the check valve and the pressure delivery
systems are working properly.
5. The Material Safety Data Sheets should be followed to prevent incompatible or adverse reactions
and injuries.
Permit No. WIO8002 t PAGE 6 OF 6
ver. Oct.2010 AP/U1C-6