WI0800206_Permit (Issuance)_20130830

Debra Watts
-DIVISION OF WATER QUALITY
AQUIFER PROTECTION SECTION
August 27, 2013
MEMORANDUM
TO:
FROM: Michael Roger
RE: ( Renewal o Permit to Inject Magnesium Sulfate (Permit #WI0800206)
i Ts 6 Company
I recommend that Permit Number WI0800206 be re -issued to the above applicant to inject Magnesium Sulfate to
remediate groundwater (GW) contaminated with petroleum products. This permit was re -issued on August 31, 2012, and
will expire on December 31, 2013. Following the review of the performance monitoring data collected after the injection
events, the Applicant has requested the permit be modified and renewed to include a total larger volume of injectant
(6,000 gallons), deeper injection depth of 25 feet, permission for up to 4 additional injection events, and a permit
expiration date extension. Previous injection events have resulted in some decrease of COCs, but benzene and MTBE are
still above 2L standards in some wells. They want to continue with injecting the Magnesium Sulfate but with more
volume and somewhat deeper depth (previous injection depth was 9 feet BLS).
Since the permit for this injection activity has previously been approved, and information contained therein is essentially
the same, I am attaching this modified memo reflecting those proposed changes from the previous permit. Please refer to
the previous permit issuance memorandum for more information on this site.
PROPOSED INJECTION: As previously mentioned, 6,000 gallons of Magnesium Sulfate will be injected via six
permanently installed injection wells. Approximately 1000 gallons will be injected in each well into the upper surficial
aquifer from 5-25 feet below land surface (BLS). These wells were deepened (over reamed) since the last injection from
9 feet to 25 feet BLS. There are a total of 4 proposed injection events with each event lasting 2-4 days in duration. The
potential displacement of the plume is low. Please refer to Figure 2 in the application package for the location of the
injection wells. Injection wells are highlighted in orange, monitoring wells in pink.
MONITORING: Proposed monitoring consists of a pre -injection event, then monthly for the first quarter follow by one
quarterly sampling event, for a total of five events over a six month period. Also, I am requesting that RW-3 be added to
the monitoring plan. Please refer to Figure 3 in the application package for more information of the location of the
monitoring wells.
REGIONAL OFFICE COMMENTS: Each of the RO comments/recommendations are discussed below (RO's
comments/recommendations are underlined).
Morella Sanchez -King with the Wilmington RO had no issues with this renewal application and recommends re -issuance
of this permit. However, she had a comment/question concerning monitoring frequency since the injection volume has
increased. As in the previous monitoring plan, I think that the proposed monitoring over six months is adequate for the
following reasons:
• Previous monitoring shows no obvious increases of sulfate from injection activities.
• We have a permit condition (Part VII.6), which states that prior to closing this permit; the Permittee must meet
groundwater quality standards or pre -injection levels, whichever concentration is higher. Otherwise, continued
monitoring will be required until such levels can be established.
• The amount of injectant (6,000 gallons) is still displacing only appx 1% of the void space in the aquifer (see
attached Calculation Worksheet).

5I Calculations Worksheet
Applicant/Facility:
Permit No. WI r,,,/U 0 a- c7
Date: g/
Reviewer: 41, „ 2.
Depth to groundwater (GW): f / P • a S BLS
GW flow direction:
MWs installed in same aquifer as injection? /(Y or N); Inj zone: .� .a'S� MW zone: - _ L3
4-0
Groundwater Flow Rate
c�
HC X _ gradient(FT?) = flow rate/DAY(?) X 365 = $ c, FT/YR
SY or porosity (—.30)
Calculations for Potential Contaminate Plume Displacement
2-0
4i, X ? 3 it X height = 3 r 0 O' `� CF
space
-6 203
CF X SY or porosity (i.e. —.30) =
Reported:
CF of available void
CF of available void sp X 7.48 eallons = gallons of water in void space
6 000 gallons of injectant = 0-- 1 % of fluid displaced by injectant (move decimal)
gallons of water in void space
Potential displacdment of plume by injection: _ LO L-.)
Injection Volume and Pumping Rate Per Well Per Day
000
total amt. of injectant / 4' number of wells / —
/c)O 3 amount of injectant per well
be/vitro-4 12s2AihmAr
:'`JIC/Applications and forms/ 5I Calculations worksheet
version 7/23/10

5I Calculations Worksheet
Notes
, e?), AA/5
6 //1/6- c <-)0 13 e--,44/ s-ac___
0 0 _LI k,./
G- 'J et
S:UIC/Applications and forms/ 51 Calculations worksheet
version 7/23/10

ATA,
NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Resources
Water Quality Programs
Pat McCrory Thomas A. Reeder John E. Skvarla, III
Governor Director Secretary
August 30, 2013
Mr. Steve Belin, Eastern Regional Manager
Phillips 66 Company
420 South Keeler Avenue, PB-1670
Bartlesville, OK 74004
Ref: Issuance of Injection Permit WI0800206
Former Conoco Store #33051
New Hanover County, North Carolina
Dear Mr. Belin:
In accordance with the renewal application received on July 22, 2013, and additional information received
August 6, and August 27, 2013, we are forwarding permit number WI0800206. This permit is to inject
Magnesium Sulfate for the enhanced bioremediation of petroleum products. These injection wells/points
will be located at the Former Conoco Store #33051, 2636 Castle Hayne Road, Wilmington, New Hanover
County, North Carolina 28401. This permit shall be effective from January 1, 2014, (i.e., the day after the
expiration date of the existing permit), until December 31, 2018, 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 VH.1, the proposed monitoring plan included in the application
has been modified to include adding RW-3 to the monitoring plan;
• Per permit condition Part VII.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;
• Per permit conditions Part VH.4 &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
1636 Mail Service Center, Raleigh, North Carolina 27699-1636
Location: 512 N. Salisbury St. Raleigh, North Carolina 27604
Phone: [phone] FAX: [phone]
Internet: www.ncwaterquality.orq
An Equal Opportunity t Affirmative Action Employer

Phillips 66 Company
Page 2 of 2
well points. These forms are available on the Division of Water Resources's website at
http://portal.ncdenr.org/web/wq/aps/ rwp'ro/reportift-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,
Michael Rogers, P.G. (NC'& FL)
Hydrogeologist
cc: Morella Sanchez -King, Wilmington Regional Office
Central Office File, WI0800206
Gabriel Araos, ATC Associates of North Carolina, P.C., 2725 E. Millbrook Road, Suite #121,
Raleigh, NC 27604

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
Phillips 66 Company
FOR THE CONSTRUCTION AND/OR OPERATION OF 6 (SIX) IN SITU
REMEDIATION/TRACER INJECTION WELLS, defined in Title 15A North Carolina
Administrative Code 2C .0209(5)(b)(viii), to inject Magnesium Sulfate for the remediation of
groundwater contaminated with petroleum products. These injection wells/points will be located
at the Former Conoco Store #33051, 2636 Castle Hayne Road, Wilmington, New Hanover
County, North Carolina 28401, and will be operated in accordance with the application
submitted July 22, 2013, and in conformity with the specifications and supporting data submitted
August 6, and August 27, 2013, 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,
2018, and shall be subject to the specified conditions and limitations set forth in Parts I through
X hereof.
Permit issued this the 30th day of August, 2013.
,Tobk_
Thomas A. Reeder, Director
Division of Water Resources
By Authority of the Environmental Management Commission.
Permit No. WI0800206 PAGE 1 OF 7
ver. June 2013 UIC-5I/5T

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.
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.
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.
PART II - WELL CONSTRUCTION SPECIAL CONDITIONS
1. 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 919-807-6406 and the Wilmington Regional Office Aquifer
Protection Section Staff, telephone number 910-796-7215.
2. 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.
Permit No. WI0800206 PAGE 2 OF 7
ver. June 2013 UIC-5I/5T

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 Resources (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 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.
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.
2. 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 Resources such as the repair, modification, or
abandonment of the injection facility.
3. 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.
4. 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 919-807-6406. 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. WI0800206
ver. June 2013
UIC-5I/5T
PAGE 3 OF 7

PART VI - INSPECTIONS
1. Any duly authorized officer, employee, or representative of the Division of Water Resources
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 monitoring plan included in the application shall be followed except that RW-3
shall be added to the monitoring plan;
2. Any additional monitoring, including groundwater, surface water, or soil sampling, deemed
necessary by the Division of Water Resources to ensure surface water and groundwater
protection may be established and an acceptable sampling reporting schedule shall be
followed.
3. All sample results shall be submitted to the Aquifer Protection Section's Wilmington
Regional Office and the Raleigh Central Office for a pre -injection monitoring event, then
monthly for the first quarter, followed by one quarterly sampling event, for a total of five
events over a six month period. Monitoring reports shall include, at a minimum, analytical
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 surveyor's base map.
4. Within 30 days of completion of well construction, a complete Well Construction Record
(Form GW-1) shall be submitted to the addresses specified in Part VII.7 below.
5. The Permittee shall submit an Injection Event Record within 30 days of completing each
injection.
6. The Permittee shall submit a final project evaluation 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 updatedcontaminant plume
and potentiometric surface maps. PLEASE NOTE: 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.
Permit No. WI0800206 PAGE 4 OF 7
ver. June 2013 UIC-51/5T

7. All monitoring results, forms, and reports required in this Part shall be submitted to:
UIC Program Staff DWR - Aquifer Protection Section
DWR — Aquifer Protection Section and Wilmington Regional Office
1636 Mail Service Center 127 Cardinal Drive Extension
Raleigh, NC 27699-1636 Wilmington, NC 28405
8. 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 910-796-7215, 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.
9. 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.
10. 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 .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
Permit No. WI0800206 PAGE 5 OF 7
ver. June 2013 UIC-5I/5T

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.
(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.
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 Resources
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.
Permit No. W10800206 PAGE 6 OF 7
ver. June 2013 UIC-51/5T

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. June 2013 UIC-51/5T

Permit Number WI0800206
Central Files: APS SWP
09/06/13
Permit Tracking Slip
Program Category
Ground Water
Permit Type
Injection In situ Groundwater Remediation Well
Primary Reviewer
michael.rogers
Coastal SW Rule
Permitted Flow
Facility
Status
Issued
Project Type
Renewal with major mod
Version Permit Classification
Individual
Permit Contact Affiliation
Gabriel Araos
Manager Project Senior
2725 E Miilbrook Rd
Raleigh NC 27604
Facility Name
Former Conoco Store #33051
Location Address
2636 Castle Hayne Rd
Wilmington
Owner
NC 28401
Major/Minor
Minor
Region
Wilmington
County
New Hanover
Facility Contact Affiliation
Owner Name
Phillips 66 Company
Dates/Events
Owner Type
Non -Government
Owner Affiliation
Steve A. Belin
Eastern Manager Region
420 S Keeler St
Bartlesville OK 74004
Orig Issue App Received
01/20/11 07/22/13
Regulated Activities
Draft Initiated
Scheduled
Issuance
Public Notice Issue
08/30/13
Effective
01/01/14
Re ■ uested/Received Events
Expiration
12/31/18
Groundwater remediation
Outfall NULL
RO staff report requested
Additional information requested
Additional information received
RO staff report received
Additional information requested
Additional information received
Waterbody Name
07/26/13
07/26/13
08/06/13
08/21/13
08/26/13
08/27/13
Stream Index Number Current Class Subbasin