WI0800219_Correspondence_20110127

RESPONSE TO COMMENTS
Underground Injection Control Permit Application
SWMU350
MCB CamLej, North Carolina
PREPARED FOR: David Goodrich, NCDENR
COPIES:
Charity Rychak, MCB CamLej EMD
David Lundquist, MCB CamLej EMD
Bryan Beck, NAVFAC Mid -Atlantic
Beth Hartzell, NCDENR
PREPARED BY: CH2M HILL
DATE: January 27, 2011
Introduction
The purpose of this document is to address the comments received on the Underground
Injection Control Permit Application provided by the North Carolina Department of
Environment and Natural Resources (NCDENR) on January 6, 2011. The responses to
comments are provided in bold.
The following specific comments were made and addressed as follows:
1) Part (3) of Section B (Hydrogeologic Description) of the submitted
Application for Permit to Construct and/or Use a Well for Injection (Form
UIC-5I/5T) requires the value of the specific yield (or storativity) of the
aquifer to be used for injection; and Part (4) requires the depth to the mean
seasonal high water table.
The average specific yield of the aquifer is 0.078 in the shallow aquifer (15 feet
below ground surface [ft bgsj), and 0.005 in the intermediate aquifer (30 ft
bgs), as calculated by O'Brien and Gere (1993). This information has been
added on page 3 of Attachment B.
The mean seasonal high water table as measured in April, 2010, is 6.3 ft bgs.
This information has been added on page 2 of Attachment B.
2) Part (3) of Section E (Injection Procedure and Equipment) requires a detailed
diagram of the surface and subsurface portions of the system; and Part (4)
requires a planned injection schedule that should include the anticipated
number of injection events and the time between consecutive events. Please
distinguish between the tracer event(s) and the remediation injection
event(s).
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RESPONSE TO COMMENTS
UIC PERMIT APPLICATION - SWMU 350
MCB CAMP LEJEUNE, NORTH CAROLINA
Four figures have been added to Attachment E. Figure 1 presents the proposed
locations of wells included in the tracer study, and Figure 3 provides a
subsurface view of the tracer study design. Figures 2 and 4 present surface and
subsurface diagrams of the IM injection events.
The proposed injections schedule is included in Figure 5 of Attachment H. The
following text has been added to Attachment E to clarify scheduling of
injection events:
Surface and subsurface diagrams of the tracer study and IM injections are
presented in Figures 1 through 4.
Injection Events Schedule
Injections will take place within the target area during three separate field
mobilizations. The first event will be a tracer study conducted to evaluate the radius
of influence (ROI) of an injection point in the shallow aquifer. This information will
be used to optimize the injection spacing during the main injection events, the
second and third field mobilizations. The second field event will involve injections
of RegenOxTM and ORC-A®. The third and final mobilization will involve a second
round of RegenOxTM and ORC-A® injections, if necessary. The schedule of field
events can be found in Figure 5 of Attachment H and is summarized here:
• Tracer Study: February 21-25, 2011
• IM Injections, Round 1: April 2 - June 1, 2011
• IM Injections, Round 2: February 23 - March 21, 2012
3) Part (2) of Section H (Maps) requires a site map that includes (d) any existing
sources of potential or known groundwater contamination, including waste
storage, treatment or disposal systems within 1/4 mile of the injection well or
well system; (e) all surface water bodies within 1/4 mile of the injection well or
well system; and (f) all existing or abandoned wells within 1/4 mile of the
injection well(s) which penetrate the proposed injection zone, including, but
not limited to, monitoring wells and wells proposed for use as injection wells.
(d) Potential sources of groundwater contamination have been added to Figure
2 of Attachment H.
(e) There are no surface water bodies within 1/4 mile of the injection well or
well system
(f) All existing or abandoned wells within 1/4 mile of the injection wells which
penetrate the proposed injection zone (20-35 ft bgs) are shown on Figure 2-2 of
Attachment H.
In addition to the above revisions, the following text has been added to
Attachment H to clarify fulfillment of the requirements:
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RESPONSE TO COMMENTS
UIC PERMIT APPLICATION - SWMU 350
MCB CAMP LEJEUNE, NORTH CAROLINA
Maps
The required site -specific maps are provided in the figures in Attachment H._Notes on the
map requirements are presented below.
(1) Area map based on the most recent USGS 7.5' topographic map of the area,
at a scale of 1:24,000 and showing the location of the proposed injection
site.
Note: Included, Figure 1
(2) Site map (Figure 2):
a. all property boundaries;
b. all buildings within the property boundary;
c. existing and proposed injection wells or well field(s)
d. any existing sources of potential or known groundwater contamination,
including waste storage, treatment or disposal systems within 1/4 mile
of the injection well or well system;
Note: The following facilities are potential source areas, and are labeled
on the Site Map.
- Padgett Toyota
- Circle K Convenience Store
- Former John's Mobil Service Gas Station
- Former ASTs (SWMU 350)
(3)
e. all surface water bodies within 1/4 mile of the injection well or well
system;
Note: There are no surface water bodies within 1/4 mile of the proposed
injection well system.
f. all existing or abandoned wells within 1/4 mile of the injection well(s)
which penetrate the proposed injection zone, including, but not limited
to, monitoring wells and wells proposed for use as injection wells.
Note: All existing wells within 1/4 mile of the proposed injection zone are
shown on Figure 2. Abandoned wells at the Circle K Convenience Store
did not exceed 15 ft bgs, and are therefore outside of the proposed
injection zone.
Potentiometric surface map(s) including:
a. direction of groundwater movement
b. existing and proposed monitoring wells
c. existing and proposed injection wells
Note: Included on Figures 2-5, 2-6, and 2-7.
(4) Contaminant plume map(s) including:
a. the horizontal extent of the contaminant plume, including
isoconcentration lines
b. existing and proposed monitoring wells
c. existing and proposed injection wells
Note: Included on Figures 2-3, 2-4, and 4.
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RESPONSE TO COMMENTS
UIC PERMIT APPLICATION - SWMU 350
MCB CAMP LEJEUNE, NORTH CAROLINA
Cross-section(s) to the known or projected depth of contamination,
including:
a. horizontal and vertical extent of the contaminant plume, including
isoconcentration lines
b. major changes in lithology
c. existing and proposed monitoring wells
d. existing and proposed injection wells
Note: Included on Figures 2-3 and 2-4.
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