WI0800206_Permit (Modification)_20191004 (2)

DIVISION OF WATER RESOURCES
WQROS
August 29, 2019
MEMORANDUM
TO: FILE / Debra Watts
FROM: Shristi Shrestha
RE: ,-re of permit to inject (Permit #WI0800260)
Phillips 66 RM Site #6265 Facility
New Hanover County
I recommend that Permit Number WI0800260 be issued to the above to inject the followin g additive(s) to remediate
groundwater (GW) contaminated with petroleum hydrocarbons: Ivey -Sol. '�
Please find the attached memo from Michael Rogers January 13, 2011 for details on site description, Hydrogeologic
description and event of contamination. s
3
PROPOSED INJECTION: It is proposed to use wells 1W-1, IW-3, 1W-4, IW-6, RWS-1, RW-3 and RW-5 wells to inject 840
gals of Ivey -Sol into each well for a total of 5,880 gals. The solution will be gravity fed into each well to a depth of ranging
from 5 to 30 ft. bgs (refer to monitoring well construction details listed on page 1). The radius of influence of each well is
given approximately as 20 ft. (refer to Attachment 4: Injection Procedure).
HOW IT WORKS: The goal of surfactant Ivey -Sol injection is to help in desorption of target contamination from soil and
groundwater such that it can be extracted easily.
MONITORING: The details of the monitoring plan are listed in attachment 7. A baseline groundwater monitoring sampling
,�will be done before injection. Following that a quarterly sampling will be conducted. Up gradient monitoring well will be
MW-4; source area monitoring and recovery wells are MW-5, MWd-16, MWD-17, MW-53, RW-3 and RW-5.
Downgradient wells are MW-7, RWS-1%RW-4.
y �-� c `.',SL.. � �.+Z r - cr _ .. rccr 4
EPIDEMIOLOGY: The DHHS has approve the injectant(s).
REGIONAL OFFICE COMMENTS: Each of the RO comments/recommendations are discussed below (RO's
comments/recommendations are underlined).
Municipal water at the proposed injection location is provided by the Cape Fear Public Water Authority (CFPUA) and more
specifically. served by the Sweeney Water Treatment Plant (Sweeney Plant). The Sweeney Plant derives raw water from
the Cape Fear River which has been documented as containing PFAS in the inlet of the Sweeney Plant. Furthermore. PFAS
have been documented in the effluent of the Sweeney Plant at levels in excess of 2L Standards. For this reason, additional
information has been requested from the consultant to aid in determining if any permit modifications are needed to ensure
that water free of PFAS are not injected into the injection wells (as well as other information).
Consultant has provided a response indicating that the water will be obtained from the CFPUA Richardson Water Treatment
Plant which utilizes nano filter treatment technology and that the tanker truck will be cleaned with water from the Richardson
Plant. It has been documented that some of the water supply wells which provide water to the Richardson Plant contain
levels of PFAS. Some additional documentation may be considered appropriate indicating that PFAS are not present in the
plant effluent. Although plant staff have reportedly indicated to the consultant that effluent lab results may be provided,
this information has not been obtained to date.
The Wilmington Regional Office recommends permit issuance upon receipt of additional information. This matter was
discussed with Jay Zimmerman and Debra Watts and it was concluded to issue permit with a condition for sampling the
potable water before injection.

5I Calculations Worksheet
Applicant/Facility: 7LwGi' 6& Carviy, 1 p `' d 6 6 C U
Permit No. WI 0 8 0 0 2 4 G UU
Date: 'f29 /2©19`
Reviewer: gh rc Sfit, S'h �"cSfh4,
Depth to groundwater (GW): ) /' 5 BLS
GW flow direction: hicat-
i
MWs installed in same aquifer as injection? V (Y or N); Inj zone: 5 - 30 MW zone: 5-30
Nearest water supply well:
Groundwater Flow Rate
HC X LIiadient(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
3.11 -(t) X` _ r2 X 2 S height = 29 , 0 0 0 CF
boo
space
Reported: c
CF X D .3 SY or porosity (i.e. -.30) = 2 63 , 2 0 0 CF of available void
2, vu6,136
2.& $ 200 CF of available void space X 7.48 gallons = gallons of water in void sp
Si g 8 0 L2allons of injectant = 0 • L 9 % of fluid displaced by injectant (move decimal)
2. G d / 36, gallons of water in void space
Potential displacement of plume by injection: L o"A.,
Injection Volume and Pumping Rate Per Well Per Day
$ te- 0 total amt. of injectant / -77' number of wells / 3 S- number of days of injection event
e-AD L. 1-/- amount of injectant per well per day (average gallons per day)
S:UIC/Applications and forms/ 5I Calculations worksheet version 9/10/10

ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
LINDA CULPEPPER
Director
Edward Kuhn
Phillips 66 Company
420 South Keeler, PB-1417
Bartlesville, OK 74003
NORTH CAROLINA
Environmental Quality
October 4, 2019
Re: Modification of Injection Permit WI0800206
Phillips 66RM Site # 6265
New Hanover County, NC
Dear Mr. Kuhn:
In accordance with the permit modification received on June 11, 2019, and additional information
received August 7, 2019, September 25, 2019 we are forwarding permit number WI0800206. This
permit is to inject Ivey -Sol to remediate groundwater contaminated with petroleum hydrocarbons
located at the Phillips 66RM Site #6265 Facility, 2636 Castle Hayne Road, Wilmington, New Hanover
County, NC 28249.
This permit shall be effective from October 4, 2019 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 VI — 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 VI.1, the potable water to be used for injection shall be sampled
and analyzed for all PFAS compounds before injection or the analytical results of the source
water shall be provided indicating that it is free of all PFAS containing compounds.
• Per permit condition Part VI.2, the proposed monitoring plan shall be followed.
• Per permit condition Part VI.6, 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.
North Carolina Department of Environmental Quality I Division of Water Resources
512 North Salisbury Street 1 1636 Mail Service Center I Raleigh, North Carolina 27699-1636
919.707.9000

• Per permit conditions Part VL4 &5, 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's website at
http://deq.nc.gov/about/divisions/water-resources/water-resources permits/wastewater-
branch/ground-water-protection/ground-water-reporting-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: Morella Sanchez -King — Bryan Lievre, WQROS — Wilmington Regional Office
Central Office File, WI0800206
Gabriel Araos, ATC Associates of North Carolina, 2725 E. Millbrook Road, Suite #121, Raleigh,
NC 27604

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
Phillips 66RM Site#6265
FOR THE OPERATION OF 9 (Nine) IN SITU REMEDIATION / TRACER INJECTION
WELLS, defined in Title 15A North Carolina Administrative Code 2C .0209(5)(b)(viii), to inject
Ivey -Sol together with potable water, for the remediation of groundwater contaminated with
petroleum hydrocarbons. These injection wells/points will be located at the Phillips .66RM Site
#6265 Facility, 2636 Castle Hayne Road, Wilmington, New Hanover County, NC 28249, and will
be operated in accordance with the modification request submitted June 11, 2019, and in
conformity with the specifications and supporting data submitted August 7, 2019, September 25,
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 a Culpepper, Director
Division of Water Resources
By Authority of the Environmental Management Commission.
Permit No. WI0800206
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PAGE 1 OF 7

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 mariner 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. WI0800206 PAGE 2 OF 7
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6. Each injection well shall 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 Wilmington Regional Office staff, telephone number 910-796-
7215 [15A NCAC 02C .0219(d)(1)].
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].
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.
Permit No. WI0800206 PAGE 3 OF 7
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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 potable water to be used for injection shall be sampled and analyzed for all PFAS
compounds before injection or the analytical results of the source water shall be provided
indicating that it is free of all PFAS containing compounds.
2. The proposed monitoring plan 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)].
3. An Annual Report with all historical monitoring results shall be submitted in bound hard copy
format with attached CD or flash drive to the GPB Central Office, and Wilmington 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)].
4. 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)].
5. An Injection Event Record shall be submitted within 30 days of each injection event [15A
NCAC 02C .0225(k)(1)(B)].
6. 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: Iniectants 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)].
7. All monitoring results, forms, and reports required in this Part shall be submitted to:
UIC Program
NC Division of Water Resources and
1636 Mail Service Center
Raleigh, NC 27699-1636
Water Quality Regional Operations Section
DWR Wilmington Regional Office
127 Cardinal Drive Extension
Wilmington NC 28405
Permit No. WI0800206 PAGE 4 OF 7
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8. 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 Wilmington Regional Office, telephone number 910-796-
7215.
(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. WI0800206 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
groundwater.
(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. WI0800206 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. WI0800206 PAGE 7 OF 7
ver. 5-21-2019 UIC-5I/5T

Permit Number WI0800206
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
Minor modification
Permit Classification
Individual
Permit Contact Affiliation
Gabriel Araos
Manager Project Senior
2725 E Miilbrook Rd
Raleigh
NC 27604
Facility Name
Phillips 66RM Site#6265 (Former Conoco Store #33051)
Location Address
2636 Castle Hayne Rd
Wilmington
Owner
NC 28401
Major/Minor
Minor
Facility Contact Affiliation
Region
Wilmington
County
New Hanover
Owner Name
Phillips 66 Company
Dates/Events
Owner Type
Non -Government
Owner Affiliation
Edward Kuhn
Eastem Manager Region
420 S Keeler St
Bartlesville
OK 74003
Orig Issue
1/20/2011
App Received
6/11/2019
Regulated Activities
Draft Initiated
Scheduled
Issuance
Groundwater remediation
Outfall
Public Notice Issue
10/2/2019
Requested /Received Events
Effective
10/4/2019
Expiration
9/30/2024
RO staff report requested
RO staff report received
Additional information requested
Additional information requested
Additional information received
Additional information received
Additional information received
8/16/19
7/25/19
9/9/19
9/25/19
8/7/19
Waterbody Name Streamlndex Number Current Class Subbasin