WI0800036_Correspondence_20030117

North Carotin
January 17, 2003
Mr. David Lown
Federal Remediation Branch Head
Superfund Section - Division of Waste Management
1646 Mail Service Center
Raleigh, NC 27699-1646
Subject: HRC & ORC Injection Pilot Test
Dear Mr. Lown:
Michael F. Easley, Governor
William G. Ross Jr., Secretary
partmeat of Environment and Natural Resources
Alan W. Klimek, P.E. Director
Division of Water Quality
As you requested in your letter of December 12, 2002, the Underground Injection Control Group
of the Groundwater Section of DWQ has reviewed the draft work plan for pilot test injections of
Hydrogen Release Compound (HRC) and Oxygen Release Compound (ORC), received on
December 12, 2002. The proposed injection project as presented in the draft work plan meets
state regulatory requirements (15A NCAC 2C.0200) for construction and operation of wells for
the purpose of injecting ORC at Site 78 North and HRC at Site 78 South, at Marine Corps Base
Camp Lejeune, in Onslow County, North Carolina.
Due to the site's status as a National Priorities List site, the state's administrative permitting
requirements have been waived for this project. A technical report summarizing the project and
including monitoring data should be submitted to the UIC Program upon completion of the
injection project. If you have any questions regarding this letter please contact me at (919) 715-
6165.
Sincerely,
Evan O. Kane, L.G.
Underground Injection Control Program Manager
cc: Charlie Stehman — GWS, Wilmington Regional Office
CO-UIC files
Groundwater Section 1636 Mail Service Center Raleigh, NC 27699-1636 [phone] Customer Service
1 800 623-7748

Evan Kane
From: David Lown [[e-mail]]
Sent: Tuesday, January 07, 2003 12:12 PM
To: [e-mail]
Subject: [Fwd: Re: Lejeune HRC/ORC OU 1 project plans]
Evan,
I emailed your questions to Baker Environmental and received the
following responses. Let me know if you require additional
information.
Dave
Original Message
Subject: Re: OU 1 project plans
Date: Tue, 07 Jan 2003 10:56:31 -0500
From: "Christine Harwood" <[e-mail]>
To: <[e-mail]>
CC: "Mark Dejohn" <[e-mail]>,"Nina Mendt"
<[e-mail]>,"Rich Bonelli" <[e-mail]>,"Tom
Fuller" <[e-mail]>
Dave,
Rich wanted me to respond to these comments this morning since I'll be
out this afternoon. He will follow up with a phone call this
afternoon.
1) Are the chlorinated plumes comingled with BTEX and do you plan to
monitor the response of the BTEX to the compounds being injected?
At the HRC injection location (Plume 3 at Site 78 South), there is BTEX
comingled with the chlorinated plumes. The response of the BTEX will be
monitored during the post injection sampling. There is very little BTEX
at the location of the ORC injection (Plume 1), but it will also be
monitored during post -injection sampling.
2) How is GW-44 constructed? The cross-section shows three screened
intervals Are these in a single well?
GW-44 only has one 5 foot screen located from about 25-30 feet below
grade. The three screens on Figure 2-16 are the three Geoprobe
locations (2' screens), the sampling of which was done in September
2000. GW-44 was constructed shortly after these samples were taken at
the lowest screen interval (highest concentration).
3) Where is GW-60 screened? This well is not shown on the
cross -sections.
GW-60 is screened from 25 to 30 feet below the ground surface. It was
screened at the location of highest TCE contamination using on -site lab
results from June 2002 for that location (78-IS62).
Let me know if you have any other questions.
Christine
Christine L. Harwood
Civil Associate II
Baker Environmental, Inc.
420 Rouser Road
Coraopolis, PA 15108
412-269-6072 office
412-269-6057 fax

North Carolina
Department of Environment and Natural Resources
Division of Waste Management
Michael F. Easley, Governor
William G. Ross Jr., Secretary
Dexter R. Matthews, Director
December 12, 2002
Mr. Evan Kane
Manager
Underground Injection Control Program
Groundwater Section
Parker -Lincoln Building
Raleigh, NC
gA
NCDENR
RE: Hydrogen Release Compound (HRC) / Oxygen Release Compound (ORC)
Injection Pilot Test
Operable Unit 1, Site 78
Marine Corps Base Camp Lejeune
Dear Mr. Kane:
The NC Superfund Section is reviewing the project plans for a pilot study to be
conducted at Camp Lejeune in early February 2003. The project plans are attached.
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Camp Lejeune will inject HRC and ORC into the groundwater to remediate
chlorinated solvents that are contaminating the shallow aquifer in the industrial area at
Hadnot Point. The contaminated groundwater at this location is presently being remediated
by a pump -and -treat system. The HRC and ORC compounds are to be provided by
Regenesis Bioremediation Products, Inc.
Because Camp Lejeune is a National Priorities List site, permits are not required for
remediation activities performed onsite. However, the remediation activities must meet the
substantive requirements of any permits that are applicable.
The project plans detail how these tests will be conducted. Specifics can be found in
Section 4.0 Pilot Study Implementation. If necessary, I will be glad to meet with you to
discuss the site characteristics and the proposed tests.
1646 Mail Service Center, Raleigh, North Carolina 27699-1646
Phone: [phone] FAX: [phone] Internet: www.enr.state.nc.us
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AN EQUAL OPPORTUNITY \ AFFIRMATIVE ACTION EMPLOYER - 50% RECYCLED / 10% POST CONSUMER PAPER

Mr. Evan Kane
December 12, 2002
Page 2 of 2
If you require additional information or have any issues or comments, please contact
me at [phone] ext. 278. Contractors will be mobilizing to the field the week of
January 20 and injection will begin the week of February 3.
Sincerely,
David J. Lown, L.G., P.E.
Federal Remediation Branch Head
NC Superfund Section
cc: Randy McElveen, N.C. Superfund Section