WI0800206_Staff Report_20190810

DocuSign Envelope ID: 1 FA2CC26-28D7-48AE-or—_' EF455D5197D7
North Carolina Department of Environmental Quality - Division of Water Resources,
WQROS REGIONAL STAFF REPORT FOR
UIC Program Support
Permit No. WI800206
Date: 7/9/2019 County: New Hanover
To: Shristi Shrestha Permittee/Applicant: Phillips 66 Company
Central Office Reviewer Facility Name: Phillips 66 RM Site #6265 (fka Conoco Store #33051)
L GENERAL INFORMATION
1. This application is (check all that apply): ❑ New ® Renewal
® Minor Modification ❑ Major Modification
a. Date of Inspection: NA
b. Person contacted and contact information:
c. Site visit conducted by: NA
d. Inspection Report Printed from BIMS attached: ❑ Yes ❑ No.
e. Physical Address of Site including zip code: 2636 Castle Hai ne Rd.. Wilminwton. NC 28401
f. Driving Directions if rural site and/or no physical address:
g. Latitude: 34.290994 Longitude: -77.920753
Source of Lat/Long & Accuracy (i.e., Google Earth, GPS, etc.):_ Google Earth
II. DESCRIPTION OF INJECTION WELL(S) AND FACILITY
1. Type of injection system:
❑ Geothermal Heating/Cooling Water Return
® In situ Groundwater Remediation pp`'
O Non -Discharge Groundwater Remediation AFfg f���
0 Other (Specify:_) Rg j w elity
9 ©pnasertion
2. For Geothermal Water Return Well(s) only
a. For existing geothermal system only:
Were samples collected from Influent/Effluent sampling ports? ❑ Yes ❑ No.
Provide well construction information from well tag:
b. Does existing or proposed system use same well for water source and injection? ❑ Yes ❑ No
If No, please provide source/supply well construction info (i.e., depth, date drilled, well contractor, etc.) and
attached map and sketch location of supply well in relation to injection well and any other features in Section IV
of this Staff Report.
3. Are there any potential pollution sources that may affect injection? ® Yes 0 No
What is/are the pollution source(s)? _Release(s) of petroleum product( s) from underground storage tanks which
have impacted soil and groundwater in the area of proposed iniection points (Incident #14178).
What is the distance of the injection well(s) from the pollution source(s)? Infection is at pollution sources
4. What is the minimumdistance of proposed injection wells from the property boundary? Beyond site bound:in
5. Quality of drainage at site: 0 Good
6. Flooding potential of site: 0 Low
® Adequate 0 Poor
® Moderate 0 High
WQROS Staff Report Rev. 4/15/2016 Page 1

DocuSign Envelope ID: 1FA2CC26-28D7-48AE-9 iF455D5197D7
7. For Groundwater Remediation Injection Systems only, is the proposed and/or existing groundwater monitoring
program (number of wells, frequency of monitoring, monitoring parameters, etc.) adequate? ® Yes ❑ No.
If No, attach map of existing monitoring well network if applicable and recommend any changes to the
groundwater -monitoring program.
8. Does the map included in the Application reasonably represent the actual site (property lines, wells, surface
drainage)? ® Yes ❑ No. If No, or no map, please attach a sketch of the site. Show property boundaries,
buildings, wells, potential pollution sources, roads, approximate scale, and north arrow.
9. For Non -Discharge Groundwater Remediation systems only (i.e., permits with WQ prefix):
a. Are the treatment facilities adequate for the type of waste and disposal system? ❑ Yes ❑ No ❑ N/A.
If No, please explain:
b. Are the site conditions (soils, topography, depth to water table, etc.) consistent with what was reported by
the soil scientist and/or Professional Engineer? ❑ Yes ❑ No ❑ N/A. If no, please explain:
Ill. EVALUATION AND RECOMMENDATIONS
1. Do you foresee any problems with issuance/renewal of this permit? ® Yes ❑ No. If Yes, explain. See
Section IV.
2. List any items that you would like WQROS Central Office to obtain through an additional information request.
Make sure that you provide a reason for each item:
Item Reason
3. List specific special conditions or compliance schedules that you recommend to be included in the permit when
issued. Make sure that you provide a reason for each special condition:
Condition Reason
Permittee should demonstrate that the mixture
water is free of PFAs
Municipal water systems in area contain PFAS
4. Recommendation
❑ Deny. If Deny, please state reasons:
❑ Hold pending receipt and review of additional information by Regional Office
® Issue upon receipt of needed additional information
❑ Issue
5. Signature of Report Preparer(s):
Doeu$Ianed by:
Signature of WQROS Regional Supervisor:
Date: 8/15/2019
r
Docu3igned by:
Kihv1 iA. Sruntit —le-iin1
E3ABA14AC7DC434...
WQROS Staff Report Rev. 4/15/2016 Page 2

DocuSign Envelope ID: 11-A2CC26-28D7-48AE-9r EF455D5197D7
IV. ADDITIONAL REGIONAL STAFF REVIEW COMMENTS/ATTACHMENTS (Optional /If Needed)
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 f 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.
A copy of the above information requests and responses are attached.
WQROS Staff Report Rev. 4/15/2016 Page 3

WATER QUALITY REGIONAL OPERATIONS SECTION
APPLICATION REVIEW REQUEST FORM
Date: June 12, 2019
To: Morella Sanchez -King- Geoff Kegley
From: Shristi Shrestha, WQROS — Animal Feeding Operations and Groundwater Protection Branch
Telephone: [phone] Fax: [phone] E-Mail: [e-mail]
Permit Number: WI0800206
A. Applicant: Phillips 66 Company
B. Facility Name: Philips 66 RM Site#6265 (Former Conoco Store#33051)
C. Application:
Permit Type: In -situ Groundwater Remediation Well
Project Type: Renewal with modification
E. Comments/Other Information:
I would like to accompany you on a site visit.
Attached, you will find all information submitted in support of the above -referenced application for your
review, comment, and/or action. Within 30 calendar days, please return a completed WQROS Staff
Report.
When you receive this request form, please write your name and dates in the spaces below, make a copy of
this sheet, and return it to the appropriate Central Office Groundwater Protection Branch contact person
listed above.
RO-WQROS Reviewer: Date:
COMMENTS:
NOTES:
FORM: WQROS-ARR ver. 092614 Page 1 of 1

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AQUIFER PROTECTION SECTION REGIONAL OFFICE STAFF REPORT
To: AQUIFER PROTECTION SECTION CENTRAL OFFICE
Central Office Reviewer: Michael Rogers
Application No.: WI0800206
Permittee: Former Conoco C-Store (Jet Gas) Project Name: Wrightsboro Conoco
Regional LoginNo.:
County: New Hanover
GENERAL INFORMATION
1. This application is (indicate all that apply):
New X Renewal Minor Modification Major Modification
Surface Irrigation Reuse Recycle
High Rate Infiltration
Evaporation/Infiltration Lagoon Land Application of Residuals Attachment B included
503 Regulated 503 Exempt Distribution of Residuals
Surface Disposal
Closed Loop Groundwater Remediation
X Other Injection Wells
2. Was a site visit conducted in order to prepare this report? Yes X No
a. Date of site visit: Have visited this site many times previously
b. Person contacted and contact information: N/A
c. Site visit conducted by: NA
d. Inspection report attached: Yes X No
3. Is the following information entered into the BIMS record for this application correct? Yes X No
If no, please complete the following information or indicate that it is correct on the current
application.
For Treatment Facilities:
a. Location:
b. Driving directions:
c. USGS Quadrangle number and map name:
d. Latitude: 34 17' 27.31 "N
Longitude: 77 55' 14.82"W
e. Regulated activities/type of wastes: (e.g., subdivision, food processing, municipal
wastewater):
AQUIFER PROTECTION SECTION REGIONAL OFFICE STAFF REPORT

For Disposal Sites: to, copy and paste a new
(If multiple sites either indicate which sites the information applies
section into the document for each site, or attach additional pages for each site)
a. Location(s):
b. Driving directions:
c. USGS Quadrangle map name and number.
Longitude:
d.
Latitude:
NEW AND MAJOR MODIFICATION APPLICATIONS (this section not needed for renewals
or minor modifications, skip to next section)
DESCRIPTION OF WASTES AND FACILITIES
1. Please attach a completed rating sheet. Facility classification:
2. Are the new treatment facilities adequate for the type of waste and disposal system?
No N/A If no, please explain:
Yes
3. Are the new site conditions (soils, topography, etc.) consistent with what was reportednbyAthe
soil scientist and/or professional engineer? Yes
No
If no, please explain:
4. Does the application (maps, plans, etc.) represent the actual site (property lines, wells,
surface drainage)? Yes
No N/A If no,.please explain:
5. Is the proposed residuals management AplanIf no, adequatepleand/or acceptable to the Division?
Yes No
6. Are the proposed application rates for the new sites (hydraulic or nutrient) acceptable?
Yes No N/A If no, please explain:
year floodplain?
7. Are the new treatment facilities or any new disposal
please attasites ch hd la map shn the 0owing the areas of
Yes No
the 100 year floodplain and explain and recommend any mitigative measures/special
conditions in Part IV:
8. Are there any buffer conflicts (new treatment facilities or new disposal sites)? Yes No
If yes, please attach a map showing conflict areas or attach any new maps you have
received from the applicant to be incorporated into the permit:
9. Is the proposed or existing groundwater monitoring program (number of wells, frequency Attach of
monitoring, monitoring parameters, etc.) pndicate review and compuate? Yes �ance boundaries.
NA
map of monitoring well network if applicable.
If No, explain and recommend any changes to the groundwater monitoring program. Attach
map of existing monitoring well network, if applicable, indicating the review and
compliance boundaries.

AQUIFER PROTECTION SECTION REGIONAL OFFICE STAFF REPORT
10. For residuals, will seasonal or other restrictions be required? Yes No N/A
If yes, attach list of sites with seasonal restrictions (Certification B?)
RENEWAL AND MODIFICATION APPLICATIONS (use previous section for new or
major modification systems)
DESCRIPTION OF WASTE(S) AND FACILITIES
1. Is there an appropriately certified ORC for the facility? Yes No
Operator in Responsible Charge: Certificate # :
Back-up Operator : Certificate # :
2. Is the design maintenance and operation (e.g. adequate aeration, sludge wasting, ,sludge
storage, effluent storage, etc.) of the treatment facilities adequate for the type of waste
and disposal system? Yes No If no, please explain:
3. Are the new site conditions (soils, topography, etc.) maintained appropriately and
adequately assimilating the waste? Yes No If no, please explain:
4. Has the site changed in any way that may affect the permit (drainage added, new wells
installed inside the compliance boundary, new development, etc.). Yes No
If Yes, please explain:
5. Is the residuals management plan adequate and/or acceptable to the Division?
Yes No If no, please explain:
6. Are the existing application rates (hydraulic or nutrient) still acceptable?
Yes No If no, please explain:
7. Is the existing groundwater monitoring program (number and location of monitoring wells,
frequency of monitoring, monitoring parameters, etc.) adequate?
Yes No N/A Attach map of existing monitoring well network if
Applicable. Indicate review and compliance boundaries. If No, explain and provide
recommended changes to the groundwater monitoring program:
8. Will seasonal or other restrictions be required for added sites? Yes No N/A
If yes, attach list of sites with restrictions (Certification B?)
9. Are there any buffer conflicts (new treatment facilities or new disposal sites)?
Yes No If yes, attach a map showing the conflict areas or attach
any new maps you have received from the applicant to be incorporated into the permit:
10. Is the description of the facilities type and/or volume of waste(s) as written in the existing
permit correct?
Yes No If no, please explain:
11. Were monitoring wells properly constructed and located? Yes No N/A
If no, please explain:

12. Has the review of all self -monitoring data been conducted (GW, NDMR, and NDAR as
applicable) ? Yes No Please summarize any findings from the review:
Compliance
AQUIFER PROTECTION SECTION REGIONAL OFFICE STAFF REPORT
13. Check all that apply: No compliance issues
Notices of violation within the last permit cycle
Current enforcement action(s)
Currently under SOC
Currently under JOC
Currently under moratorium
If any items are checked, please explain and attach any documents that may help clarify
answer/comments (such as NOV, NOD, etc.).
14. Have all compliance dates/conditions in the existing permit, SOC, JOC, etc. been
complied with? Yes No N/A If no, please explain:
15. Are there any issues related to compliance/enforcement that should be resolved before
issuing this permit? Yes No If yes, please explain:
INJECTION WELL PERMIT APPLICATIONS (Complete these two sections for all systems that
use injection wells, including closed loop groundwater remediation effluent injection wells, in situ
remediation injection wells, and heat pump injection wells.
Description of well(s) and Facilities — New. Renewal. and Modification
1. Type of injection system:
Heating/cooling water return flow (5A7)
Closed -loop heat pump system (5QM/5QW)
X In situ remediation (51)
Closed -loop groundwater remediation effluent injection (5L nondischarge)
Other (specify)
2. Does the system use the same well for water source and injection? Yes X No
3. Are there any pollution sources that may affect injection? X Yes No If yes, what
are the pollutant source(s) and distance(s) from the closest injection well: Petroleum in
groundwater may require Haz-Mat and site safety procedures.
4. What is the minimum distance of proposed injection wells from the property boundary?
Injection points extend to the property boundary.
5. Quality of drainage at the site: X Good Adequate Poor
6. Flooding potential of site: X Low Moderate High
7. For groundwater remediation systems, is the proposed and/or existing groundwater
monitoring program (number of wells, frequency of monitoring, monitoring parameters,
etc.) adequate? X Yes No Attach map of monitoring well network if
applicable. If no, explain and recommend any changes to the monitoring program.

8. Does the map presented represent the actual site (property lines, wells, surface
drainage)? X Yes No If no, or no map, please attach a map of the site
showing property boundaries, buildings, wells, potential pollution sources, roads,
approximate scale, and north arrow.
AQUIFER PROTECTION SECTION REGIONAL OFFICE STAFF REPORT
Iniection Well Permit Renewal And Modification Only:
1. For heat pump systems, are there any abnormalities in the heat pump or injection well
operation (e.g. turbid water, failure to assimilate injected fluid, poor heating/cooling)?
Yes No If yes, please explain:
2. For closed loop heat pump systems, has the system lost pressure or required make-up
fluid since permit issuance or last inspection? Yes No If yes, please
explain:
3. For renewal or modification of groundwater remediation permits, will
continued/additional/modified injections have an adverse impact on migration of the
plume or management of the contamination incident? Yes No X If yes, please
explain:
4. Drilling contractor: Name
Address
Certification Number
5. Complete and attach well construction data sheet:
EVALUATION AND RECOMMENDATIONS
1. Provide any additional narrative regarding your review of the application.
2. Attach well construction data sheet, as needed information is available. Not needed.
3. Do you foresee any problems with issuance/renewal of this permit? Yes No X
If yes, please explain: Remediation at this site has taken 15 years since discovery of
the release.
4. List any items that you would like the APS Central Office to obtain through additional
information request. Please provide a reason with each item. None
5. List specific permit conditions that you recommend to by removed from the permit when
issued. Please provide a reason for each recommendation. None
6. List specific special conditions or compliance schedules that you recommend to be
included in the permit when issued. Please provide a reason for each recommendation.
7. Recommendation:
Hold, pending receipt and review of additional information by the regional office;
Hold, pending review of draft permit by the regional office;
X Issue
Deny If denied, please state reasons

Signature of report
preparer: CFS
Signature of APS regional
supervisor: CFS
Date: October 20. 2010
ADDITIONAL REGIONAL STAFF REVIEW ITEMS

AQUIFER PROTECTION SECTION
APPLICATION REVIEW REQUEST FORM
Date: Se:Aember 14. 2010
To: ❑ Landon Davidson, ARO-APS
❑ Art Barnhardt, FRO-APS
❑ Andrew Pitner, MRO-APS
❑ Jay Zimmerman, RRO-APS
From: Michael Rogers Groundwater Protection Unit
Telephone: [phone]
Entail: Michael.Rogersgncmail.net
❑ David May, WaRO-APS
® Charlie Stehman, WiRO-APS
❑ Sherri Knight, W-SRO-APS
Fax: [phone]
A. Permit Number: WI 0800206
B. Owner: Former Conoco Phillips Store
C. Facility/Operation:
❑ Proposed ® Existing
❑ Facility ❑ Operation
D. Application:
1. Permit Type: ❑ Animal ❑ SFR-Surface Irrigation❑ Reuse ❑ H-R Infiltration
El Recycle ❑ I/E Lagoon ❑ GW Remediation (ND)
® UIC — 5I Groundwater Remediation Well
For Residuals: ❑ Land App. ❑ D&M ❑ Surface Disposal
El 503 ❑ 503 Exempt ❑ Animal
2. Project Type: ® New ❑ Major Mod. ❑ Minor Mod. ❑ Renewal ❑ Renewal w/ Mod.
E. Comments/Other Information: ❑ I would like -to accompany you-ona site visit.
11,
NOTE:
Attached, you will find all information submitted in support of the above -referenced application for your
review, comment, and/or action. Within, please take the following actions:
® Return a Completed APSARR Form and attach laboratory analytical results, if applicable.
❑ Attach Well Construction Data Sheet.
El Attach Attachment B for Certification by the LAPCU.
El Issue an Attachment B Certification from the RO.*
* Remember that you will be responsible for coordinating site visits and reviews, as well as additional
information requests with other RO-APS representatives in order to prepare a complete Attachment B for
certification. Refer to the RPP SOP for additional detail.
When you receive this request form, please write your name and dates in the spaces below, make a copy
of this sheet, and return it to the appropriate Central Office -Aquifer Protection Section contact person
listed above.
RO-APS Reviewer: Date:
FORM: APSARR 07/06 Page 1 of 1

North Carolina Department of Health and Human Services
Division of Public Health • Epidemiology Section
1912 Mail Service Center • Raleigh, North Carolina 27699-1912
Tel [phone] • Fax [phone]
Michael F. Easley, Governor Carmen IIooker Odom, Secretary
November 13, 2006
MEMORANDUM
TO: Qu Qi
Underground Injection Control Program
Aquifer Protection Section
11
FROM: Luanne K. Williams, Phann.D., Toxicologist `,
Medical Evaluation and Risk Assessment Unit
Occupational and Environmental Epidemiology Branch
North Carolina Department of Health and Human Services
SUBJECT: Use of Non -Biological Products Epsom Salt, Technical Grade (magnesium
sulfate, heptahydrate) and Iron Sulfate to Enhance Biodegradation of
Contaminated Groundwater
I am writing in response to a request for a health risk evaluation regarding the use of non -
biological products including epsom salt, technical grade (i.e., magnesium sulfate, heptahydrate)
and iron sulfate to enhance biodegradation of contaminated groundwater. It is my understanding
from the information submitted by Delta Environmental Consultants, Inc., that if the dissolved
iron concentration significantly decreases, then the application will be modified from magnesium.
sulfate to iron sulfate. Based upon my review of the information submitted by Delta
Environmental Consultants, Inc., I offer the following health risk evaluation:
1. Some effects or hazards reported to be associated with the chemicals proposed for use are
as follows:
• Exposure can cause irritation of eyes, nose and throat; early flushing; nausea;
vomiting; hypotension; ECG changes (prolonged PR and QRS intervals); CNS
depression; respiratory depression; impairment of neuromuscular transmission
(hyporeflexia, paralysis); and gastrointestinal hemorrhaging (Micromedex TOMEs
Plus System CD-ROM Database, Volume 70, 2006)
2. If the products are 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.
CD Location: 5505 Six Forks Road, 2"d Floor, Room D1 • Raleigh, N.C. 27609 An Equal Opportunity Employer

3. Persons working with this product should at least wear goggles or a face shield, gloves,
and protective clothing. Face and body protection should be used for anticipated splashes
or sprays. Again, consult with an industrial hygienist to ensure proper protection.
4. Eating, drinking, smoking, handling contact lenses, and applying cosmetics should never
be permitted in the application area during or immediately following application. 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 adverse reactions and
injuries.
6. Access to the area of application should be limited to the workers applying the product.
In order to minimize exposure to unprotected individuals, measures should be taken to
prevent access to the area of application.
7. According to the information submitted, the area is served by a public water supply.
There are no public water supply wells within 900 feet down gradient of the site. There
is one on -site non -potable well (used for washout and hydrostatic testing) 160 feet up
gradient from the proposed site of injection. The nearest surface water body is the Neuse
River which is approximately Y4 mile northwest of the site. Efforts should be made to
prevent contamination of existing or future wells and surface waters that may be located
hear the application area.
8. Based on the information submitted, iron sulfide and magnesium carbonate are typical
degradation products. An inorganic analysis including iron, sulfate, and total dissolved
solids should be done before and after the injection of the magnesium sulfate. This is
needed so that a comparison can be made between the naturally -occurring inorganics
prior to injectionand post injection and to ensure that the iron, sulfate, and total dissolved
levels do not exceed the groundwater quality standards of 0.3 mg/L, 250 mg/L, and 500
mg/L, respectively, as a result of the injection.
Please do not hesitate to call me if you have any questions at [phone].
cc: -Mr. Rodney Vaughn, 4414 Buffalo Road (P.O. Box 338), Selma, NC 27576
- Ms. Nancy Forster, Delta Environmental Consultants, Inc., 5000 Peachtree Industrial
Boulevard, Suite 100, Norcross, GA 30071 .
- Mr. John G. Blumberg, PQ Corporation, P.O. Box 840, Valley Forge, PA 19482
c Z +'ZE Wd 9 I fr0i ' 90