WI0800264_Permit (Issuance)_20120131

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
Tom Potter Oil Company, Inc.
FOR THE CONSTRUCTION AND/OR OPERATION OF FOUR (4) TYPE 5I INJECTION
WELLS, defined in Title 15A North Carolina Administrative Code 2C .0209(e)(3)(C), to inject
oxygen via in -situ Submerged Oxygen Curtain (iSOC) for the enhanced remediation of
petroleum products. These injection wells/points will be located at the former Tee Pee #3 Store,
1644 Live Oak St., Beaufort, Carteret County, NC 28516, and will be operated in accordance
with the application submitted October 31, 2011, and in conformity with the specifications and
supporting data, 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 January 31,
2016, and shall be subject to the specified conditions and limitations set forth in Parts I through
X hereof.
Permit issued this the 31st day of January, 2012.
Oei\c„ u2,1s1s2
• harles Wakild, P.E., Director
Division of Water Quality
By Authority of the Environmental Management Commission.
Permit No. WI0800264 PAGE 1 OF 6
ver. June 2011 UIC-5115T

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. WI0800264 PAGE 2 OF 6
ver. June 2011 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 Quality (Director). In the event there is a desire for the facility to change
ownership, or there isa 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 Quality 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. WI0800264 PAGE 3 OF 6
ver. June 2011 UIC-51/5T

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. 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
2. The proposed monitoring plan received included in the application shall be followed.
Additionally, in order to provide baseline groundwater quality data, the latest groundwater
sampling results from the semiannual monitoring shall be submitted (October 2011).
3. 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.
4. The Permittee shall submit an Injection Event Record within 30 days of completing each
injection.
5. 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.
Permit No. WI0800264 PAGE 4 OF 6
ver. June 2011 UIC-5I/5T

6. The monitoring results and the final project evaluation shall be submitted to:
UIC Program Staff
DWQ — Aquifer Protection Section and
1636 Mail Service Center
Raleigh, NC 27699-1636
DWQ - Aquifer Protection Section
Wilmington Regional Office
127 Cardinal Dr. Extension
Wilmington, NC 28405
6. 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.
7. 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.
8. 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.
Permit No. WI0800264 PAGE E 5 OF 6
ver. June 2011 UIC-5I/5T

(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 .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. WI0800264 PAGE 6 OF 6
ver. June 2011 UIC-5I/5T

DIVISION OF WATER QUALITY
AQUIFER PROTECTION SECTION
January 28, 2012
MEMORANDUM
TO: Debra Watts
FROM: Michael Rogers M Y
RE: Issuance of Permit to Inject Oxygen (Permit #WI0800264)
Tom Potter Oil Company, Inc.
I recommend that Permit Number WI0800264 be issued to Tom Potter Oil Company, Inc. to inject oxygen to remediate
groundwater (GW) contaminated with petroleum products. The site is located at 1644 Live Oak St., Beaufort, Carteret
County, NC 28516.
SITE DESCRIPTION: The subject site is a former service station presently used as a restaurant (Figures 1 and 2).
Evidently, there was a spillage or leak of petroleum products at the site resulting in groundwater contamination. The site
has undergone previous remediation, but there is still some residual contamination. The applicant is proposing injecting
oxygen via in -situ submerged oxygen curtain (iSOC) to remediate groundwater.
HYDROGEOLOGIC DESCRIPTION: The site is located in the Coastal Plain Physiographic Province. The area of the site is
overlain by topsoil to 1 foot, fine sandy clay to approximately 6 feet, medium to fine sand from 6 feet to 16 feet, then clayey
medium to fine sand with shell fragments to 30 feet BLS. Below this surficial aquifer lies the confining Yorktown
Formation. Depth to GW in the surficial aquifer averages approximately 2 feet BLS and flows in a generally east to
northeasterly direction (Figure 5) at a reported 48 feet per year at 25 % porosity (my estimate is also 48 feet per year using
an average porosity of 25%).
EXTENT OF CONTAMINATION: The contaminant benzene plume is linear in shape and is approximately 200 feet long and
75 feet wide (Figure 6).
PROPOSED INJECTION: The proposed injection will be via 4 wells screened from 3 to 20 feet BLS. The potential impact
or displacement of the plume onto adjoining properties and/or receptors is minimal for the following reasons: (1) the
injection product is oxygen, (2) the groundwater flow rate is only approximately 48 feet per year, and (3) there are no
known receptors downgradient. The Applicant indicates in the application that the benzene plume could persist for
additional 30 years of no active remediation is implemented at the site. The injection wells are highlighted in pink on
Figure 11.
HOW IT WORKS: The proposed injection consists of delivery of high concentrations of oxygen delivered by in -situ
Submerged Oxygen Curtain (iSOC) diffusion apparatus via the referenced 4 injection wells. The basic components of the
iSOC to be installed in each well consist of the gas diffusion apparatus, a pressure regulator, and an oxygen tank. The
proposed preliminary design includes the 4 iSOC diffusion apparatuses connected to a bank of common 300 ft.3 oxygen
cylinders. The injection of oxygen continuously into the surficial aquifer will promote aerobic degradation of the dissolved
petroleum related contamination by providing a readily available electronic acceptor for biodegradation of the contaminant
compounds.
MONITORING: There is an extensive groundwater monitoring well network at the site. Samples will be collected quarterly
from 10 select monitoring wells (highlighted in yellow on Figure 11). These wells along with 11 additional wells
(highlighted in orange on Figure 11) will be sampled semiannually as part of the monitoring plan instituted by the DWM.
The latest semiannual analytical report will provide pre -injection sampling data. I am going to request a copy of the latest
semiannual data in the cover letter, which should have occurred in October 2011.
EPIDEMIOLOGY: The DHHS has reviewed and approved the referenced injectant(s).

REGIONAL OFFICE COMMENTS: Each of the RO comments/recommendations are discussed below (RO's
comments/recommendations are underlined).
The regional office did not have any comments in the staff report.
The Wilmington Regional Office recommends permit issuance.

51 Calculations Worksheet
Applicant/Facility: Tom )0L 76fL, 0/1.-
Permit No. WI V 9 g6,
z�
Date: j1d-6�j
Reviewer:rr7f L
Depth to groundwater (GW): ABLS
GW flow direction: N L Alt
MWs installed in same aquifer as injection? (Y or N); Inj zone: 3 - ?
Nearest water supply well: /") «► �} j� rcD
Groundwater Flow Rate
NlLi 1- -7-•
.tt 1„/-6 _
MW zone: Arw-5 ; .28 -x
?. / �/d HC X , 003(4 gradient(FT?) _ . i3 flow rate/DAY(?) X 36 = f 7 FT/YR
SY or porosity (-.30)
[FYI- 60 min/day X 24 hrs X 365 days = 525,600]
Calculations for Potential Contaminate Plume Displacement 4_ /��'��r�
1 Reported: Y
3.142 (�t) -X r2 X height = CF
CF X
space
SY or porosity (i.e. -.30) = CF of available void
CF of available void space X 7.48 ryallons = gallons of water in void sp
gallons of injectant = % of fluid displaced by injectant (move decimal)
gallons of water in void space
Potential displacement of plume by injection:
Injection Volume and Pumping Rate Per Well Per Day
total amt. of injectant / LI 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