WI0800528_Permit (Issuance)_20200123

PERMIT ISSUANCE MEMO
TO:
Nat Wilson
GWRS
DIVISION OF WATER RESOURCES
GWRS
N
January 23, 2020
FROM: Michael Rogers, UIC Program Manager
GWRS
RE: Permit Issuance for Permit WI0800528
Former Modem Dry Cleaners Site, Wilmington, NC
I recommend that the above permit be issued. The Applicant is requesting a permit to inject sodium lactate
(WillClear Plus).
HIGHLIGHTS/COMMENTS:
• They will inject WillClear Plus mixed with groundwater from a well upgradient (MW-WSP-1D) into 4
existing wells and into 25 soil borings. 7,150 gallons will be injected per each event with a total of 5
events lasting approximately 2 weeks. Laboratory analytical results of the source well included in the
application do not show any VOCs above detection levels. Therefore, a reasonable conclusion is the
source well is outside the contaminate plume (the groundwater elevation map shows it also upgradient).
• Since they are only injecting 7,150 gallons per each event (total of 35,750 gallons for 5 events), the
potential displacement of plume in shallow zone is low (appx 1.2% of total aquifer volume- reported
2,800,512 gal).
• The Site is approximately 4.5 miles to the west and upgradient of the CFPUA ASR well, which has
reported PFAS in the groundwater.
REGIONAL OFFICE COMMENTS: Wilmington Regional Office recommends issuance of this permit.
• After receipt of all additional information requests, the WiRO is OK with permit issuance (see email dated
1/23/20).

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ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
LINDA CULPEPPER
Director
NORTH CAROLINA
Environmental Quality
January 23, 2020
Re: Issuance of Injection Permit WI0800528
Former Modern Dry Cleaners Site
New Hanover County, NC
Dear Ms. Stella:
In accordance with the permit application received on September 26, 2019, and additional
information received October 8, 2019, November 5 and 18, 2019, and January 14 and 23, 2020, we
are forwarding permit number WI0800528 to inject WillClear Plus for the enhancement of
bioremediation of chlorinated solvents.
This permit shall be effective, unless revoked, from the day of issuance until December 31, 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 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 III.1, at least forty-eight (48) hours prior to constructing or operating
any injection well, the Permittee shall notify the Underground Injection Control (UIC)
Central Office staff, telephone number 919-707-9000, and the Wilmington Regional Office
staff, telephone number 910-796-7215.
• Per permit condition IV.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.
• Per permit condition VI.2, sample results shall be submitted to the DWR UIC Program
and Wilmington Regional Office annually starting from date well construction and/or
injection activities commence. Monitoring reports shall include, a summary of injection
activities and monitoring results, historical analytical data presented in a
tabular/spreadsheet format distinguishing between pre -injection and post injection data,
and an update on the status and location of monitoring and injection wells.
CP5NVITH� E
o.o.rwwra.t nwo.wrmhl r
North Carolina Department of Environmental Quality I Division of Water Resources
512 North Salisbury Street 11636 Mail Service Center I Raleigh, North Carolina 27699-1636
919.707.9000

• Per permit conditions Part VI.3 &4, 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' website at https://deq.nc.gov/about/divisions/water-
resources/water-resources-permits/wastewater-branch/ground-water-protection/ground-
water-rep orting-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 (DWR). 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)
Underground Injection Control (UIC) Program Manager
Division of Water Resources
Ground Water Resources Section
cc: WQROS — Wilmington Regional Office
Central Office File, WI0800528
Matthew Ayers, WSP USA, 600 East Crescent Ave., Suite 200, Upper Saddle River, NJ 07458

NORTH CAROLINA
ENVIRONMENTAL MANAGEMENT COMMISSION
DEPARTMENT OF ENVIRONMENTAL QUALITY (DEQ)
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
Brookfield Properties
New Hanover County
FOR THE CONSTRUCTION AND/OR OPERATION OF 4 (four) IN SITU REMEDIATION
INJECTION WELL(S) defined in Title 15A North Carolina Administrative Code 2C
.0209(5)(b)(viii), and to advance 25 soil borings to inject WillClear Plus, for the remediation of
groundwater contaminated with volatile organic compounds (VOCs). These injection wells/points
will be located at the Former Modern Dry Cleaners Facility, located at 3750 Oleander Drive,
Wilmington, NC 28403, and will be operated in accordance with the permit application received
September 26, 2019, and in conformity with the specifications and supporting data received
October 8, 2019, November 5 and 18, 2019, and January 14 and 23, 2020, 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 the date of issuance until December 31, 2024.
Permit issued the Z1 ay of , 2020
for Linda Culpepper, Director
Division of Water Resources
By Authority of the Environmental Management Commission.
Permit No. WI0800528 PAGE 1 OF 7
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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(k)].
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(o)].
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(b)].
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(h)(17)].
3. Each injection well shall be constructed in such a manner that water from land surface cannot
migrate into the gravel pack or well.screen [15A NCAC 02C .0225(h)(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(h)(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(h)(23)].
Permit No. WI0800528 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(j)(3)].
7. Each permanent injection well shall have a permanently affixed identification plate [15A
NCAC .0225(h)(20)].
8. If not previously submitted, 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 any injection well, the
Permittee shall notify the Underground Injection Control (UIC) Central Office staff, telephone
number 919-707-9000, and the Wilmington Regional Office staff, telephone number 910-796-
7215.
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(i)].
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(i)].
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].
Permit No. WI0800528 PAGE 3 OF 7
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PART V - INSPECTIONS [15A NCAC 02C .0211(j)]
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.
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 proposed monitoring plan revised per Additional Information received November 18,
2019, 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(k)].
2. An Annual Report with all historical monitoring results shall be submitted in bound hard copy
format with attached CD or flash drive to the UIC Program Central Office, and Wilmington
Regional Office starting within one year of the first injection event. 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(1)].
3. Records of well construction, repair, or abandonment shall be submitted within 30 days of
completion of such activities [15A NCAC 02C .0225(1)].
4. An Injection Event Record (IER) shall be submitted within 30 days of each individual injection
event [15A NCAC 02C .0225(1)].
5. 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: Injectants 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(1)].
Permit No. WI0800528 PAGE 4 OF 7
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6. 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
WQROS Wilmington Regional Office
127 Cardinal Drive Extension
Wilmington, NC 28405
7. 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(p), noncompliance notification shall be as follows:
(A)
(B)
(C)
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.
Written notification shall be made within five days of the occurrence and submitted
to the addresses in Item #6 above.
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.
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.
PART VIII - PERMIT RENEWAL [15A NCAC 02C .0211(h)]
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.
Permit No. WI0800528 PAGE 5 OF 7
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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
groundwaters.
(B) The entire depth of each well shall be sounded before it is sealed to insure freedom
from obstructions that may interfere with sealing operations.
(C) The well shall be thoroughly disinfected, prior to sealing, if 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(1) within 30 days of completion of abandonment.
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
Permit No. WI0800528 PAGE 6 OF 7
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PART X — WORKER PRECAUTIONS DURING APPLICATION [15A NCAC 02C
.0225(a)]
1. Some effects reported to be associated withthe 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. WI0800528 PAGE 7 OF 7
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