WI0600068_Permit (Issuance)_20110228

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
Petitioner for DSCA Site No. 26-0003
FOR THE CONSTRUCTION AND OPERATION OF 107 TYPE 5I INJECTION WELLS,
defined in Title 15A North Carolina Administrative Code 2C .0209(e)(3)(C), to inject Sodium
Pemanganate and Potassium Permanganate, for the oxidation of chlorinated dry cleaning
solvents which include PCE. These injection wells/points will be located at Smitty's Cleaners
Site, 3060 Owen Drive, Fayetteville, Cumberland County, North Carolina, and will be operated
in accordance with the application submitted December 29, 2010, and in conformity with the
specifications and supporting data submitted January 25, 2011, 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,
2014, and shall be subject to the specified conditions and limitations set forth in Parts I through
X hereof.
Permit issued this the 28th day of February, 2011.
or Coleen H. Sullins, Director
Division of Water Quality
By Authority of the Environmental Management Commission.
Permit No. WI0600068
ver. Feb.2011 AP/UIC-6
PAGE 1 OF 5

PART I - WELL CONSi1WCTION 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 the performance of the number of subsurface injections
described in the application and other supporting data. The performance of additional
injections must be approved in advance by the Aquifer Protection Section.
4. Each injection shall be performed and the injection hole immediately backfilled with
hydrated bentonite so that water from land surface cannot migrate into the subsurface.
PART II - WELL CONSTRUCTION SPECIAL CONDITIONS
At least forty-eight (48) hours prior to performing each boring and injection event, the
Permittee shall notify the Aquifer Protection Section -Underground Injection Control (UIC)
Central Office staff, telephone number (919) 715-715-6162 and the Fayetteville Regional
Office Aquifer Protection Section Staff, telephone number [phone].
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 events 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 is a 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 which may be imposed by other
local, state, and federal agencies which have jurisdiction. Furthermore, the issuance of this
permit does not imply that all regulatory requirements have been met.
PART IV - PERFORMANCE STANDARDS
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.
2. 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.
Permit No. WI0600068 PAGE 2 OF 5
. ver. Feb.2011 AP/UIC-6

PART V - OPERATION AND MAINTENANCE REQUIREMENTS
1. The Permittee must notify the Division and receive prior written approval from the Director
of any planned alterations or additions to the permitted procedure, or for any activity not
specifically authorized by the permit.
2. 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 [phone]. 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.
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. The proposed monitoring plan included in the application shall be followed. All sample
results shall be submitted to the Aquifer Protection Section's Fayetteville 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.
2.
The Permittee shall submit an Injection Event Record within 30 days of completing each
injection. -
3. 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. WI0600068 PAGE 3 OF 5
ver. Feb.2011 AP/UIC-6

4. The monitoring results and the final project evaluation shall be submitted to:
and to:
Aquifer Protection Section-UIC Program
DENR-Division of Water Quality
1636 Mail Service Center
Raleigh, NC 27699-1636
Aquifer Protection Section
DENR-DWQ Fayetteville Regional Office
225 Green Street
Suite 714 / Systel Building
Fayetteville, NC 28301-5043
5. The Permittee shall report by telephone, within 48 hours of the occurrence or first knowledge
of the occurrence, to the Fayetteville Regional Office, telephone number [phone], 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.
6. 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.
7. 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 penuit 120 days prior to its expiration date.
PART IX - CHANGE OF WELL STATUS
1. When operations have ceased at the facility and a well will no longer be used for any
purpose, the Permittee shall abandon that 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. WI0600068 PAGE 4 OF 5
ver. Feb.2011 AP/UIC-6

(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.
2. 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 al
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. WI0600068 PAGE 5 OF 5
ver. Feb.201I AP/UIC-6

DIVISION OF WATER QUALITY
AQUIFER PROTECTION SECTION
February 21, 2011
PERMIT ISSUANCE MEMO
TO: Debra Watts
THROUGH: Thomas Slusser
FROM: David Goodrich
RE: Permit To Inject Sodium Permanganate and Potassium Permanganate
Smitty's Cleaners — DSCA Site No. 26-0003
I recommend that Permit Number WI0600068 be issued to Joyce W. Smith, the petitioner for DSCA Site 26-
0003, to inject Sodium Permanganate and Potassium Permanganate to remediate soils and groundwater
contaminated with chlorinated ethenes which are primarily PCE and PCE breakdown products.
SITE DESCRIPTION The site is -located in an industrial area in the City of Fayetteville. It has been the site of,
an active dry cleaning facility for more than-30 years, beginning hi -The -early 1960's and is still active. In the late
1990's, the use of PCE as the primary solvent for dry cleaning operations was discontinued in favor of varsol.
PCE was first reported in the monitoring wells of a downgradient fuel facility owned by Exxon.
DYDROGEOLOGIC DESCRIPTION The immediate area has sand at the surface, underlain by
unconsolidated surficial material which overlies the confining layer of the Black Creek aquifer formation.
Twenty-nine monitoring wells have been installed on the site, and have shown the site geology to consist of a
perched ione in the source area that extends from a depth of approximately 17 feet to 20 feet down to the top of
a clay semi -confining unit at a depth of approximately 20 to 25 feet. Shallow ground water beneath the site is
typically encountered at a depth of 20 feet to 30 feet below land surface, with extreme measurements of 16.32
feet and 42.57 feet. The drilling logs indicate that the materials overlying the Black creek formation consist. of
sand interspersed with layers of clay and silty clay. The average hydraulic gradient is approximately 0.01, and
the rate of groundwater flow is estimated to be 36.5 feet per year.
EXTENT OF CONTAMINATION The affected ground water extends eastward from the source area for a
distance of approximately 2,000 feet, attaining a maximum width of approximately 2,500 feet at this distance.
The saturated thickness varies from 10 feet to 60 feet, with an average thickness of 40 to 50 feet. The
remediation treatment will be performed on the area of highest contaminant concentration, although it will be
volumetrically less than 1% of the entire contaminant plume.
PROPOSED INJECTION The injectant will consist of a mixture of Sodium Permanganate, Potassium
Permanganate, and municipal supply water. A mobile direct -push unit will be used to push injection rods to the
desired depths for the injection of the mixture, the rods withdrawn, and each hole abandoned by being filled
with hydrated bentonite. A pilot study will first be performed in which 1,980 gallons of a Sodium Permanganate
mixture will be injected into 22 direct -push points over two, 620 square -foot areas into the unsaturated zone.
The procedure will also be performed in another area by injecting 450 gallons of injectant into the saturated
zone through 9 more direct -push points. The effectiveness of these efforts will be evaluated for 3 to 12 months.
Pending a successful outcome, the full-scale remedial effort will consist of 76 direct -push points that will be
performed over an area of approximately 8,585 square feet to inject a total of 5,928 gallons of combined Sodium
Permanganate and Potassium Permanganate injectant. The area impacted is estimated to be more than 60 acres
in size, but the concentration of the contaminants is low in at least 90% of the affected area.

HOW IT WORKS The Sodium Permanganate and Potassium Permangana are both oxidants which will
facilitate the chemical degradation of the solvent substances.
MONITORING Groundwater monitoring will be performed prior to injection, and then quarterly for at
least one year following injection, for Volatile Organic Compounds by EP Method 8260, for Total Manganese
and Dissolved Manganese by EPA Method 6010, for .� .. oxidation-reduction
potential, and specific conductivity, on existing we
proposed well that is to be installed inside the building. s is t e same monitoring as is descn.ed in the
proposed monitoring plan. Since all of the monitoring wells are situated in the most highly contaminated area of
the plume, the monitoring data will not be entered into the BIMS computer system.
EPIDEMIOLOGY On June 11, 1999, the DHHS' Epidemiology Branch provided comments on Sodium
Permanganate, and provided an email on April 4, 2002 stating that the precautions listed in the comments for
Sodium Permanganate can also be followed for Potassium Permanganate, for groundwater remediation. Dr.
Luanne Williams did not present any information that would preclude the use of these products for injection but
did provide a health risk analysis and worker safety precautions, which are in Part X of the attached permit.
REGIONAL OFFICE COMMENTS Jim Barber of t 1 Office recommends issuance of this
pe
y ATC (issued on Jul 13 2010 or later
um er an ounty Health Department in the interests o pu is ea y assis ing these agencies in err
identification of impacted water supply wells. Table 1 of the subject permit application makes several references
to sampling events that have already taken place at water supply wells in the affected area under the Drycleaning
Solvent Cleanup Act Program (DSCA). Mr. Al Chapman, who is with the DWM Superfund Section DSCA
Program, was contacted to ascertain his agency's responsibilities for notification of these organizations. He
verified that the DWM is actively working with both agencies to keep them informed, and to extend a water line
to those residences, etc. whose water supplies could be endange ed by the subject contamination. The Regional
Office also recommended that the subject permit be copied to the City of Fayetteville's Public Works
Commission and to the Cumberland County Health Department.
-0 ao‘A A9
cent area -wide groundwater monitoring re o 1
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DIVISION OF WATER QUALITY
AQUIFER PROTECTION SECTION
February 25, 2011
PERMIT ISSUANCE MEMO
TO: Debra Watts
THROUGH: Thomas Slusser
FROM: David Goodrich
RE: Permit To Inject Sodium Permanganate and Potassium Permanganate
Smitty's Cleaners — DSCA Site No. 26-0003
I recommend that Permit Number WI0600068 be issued to Joyce W. Smith, the petitioner for DSCA Site 26-
0003, to inject Sodium Permanganate and Potassium Permanganate to remediate soils and groundwater
contaminated with chlorinated ethenes which are primarily PCE and PCE breakdown products.
SITE DESCRIPTION The site is located in an industrial area in the City of Fayetteville. It has been the site of
an active dry cleaning facility for more than 30 years, beginning in the early 1960's and is still active. In the late
1990's, the use of PCE as the primary solvent for dry cleaning operations was discontinued in favor of varsol.
PCE was first reported in the monitoring wells of a downgradient fuel facility owned by Exxon.
HYDROGEOLOGIC DESCRIPTION The immediate area has sand at the surface, underlain by
unconsolidated surficial material which overlies the confining layer of the Black Creek aquifer formation.
Twenty-nine monitoring wells have been installed on the site, and have shown the site geology to consist of a
perched zone in the source area that extends from a depth of approximately 17 feet to 20 feet down to the top of
a clay semi -confining unit at a depth of approximately 20 to 25 feet. Shallow ground water beneath the site is
typically encountered at a depth of 20 feet to 30 feet below land surface, with extrenie measurements of 16.32
feet and 42.57 feet. The drilling logs indicate that the materials overlying the Black creek formation consist of
sand interspersed with layers of clay and silty clay. The average hydraulic gradient is approximately 0.01, and
the rate of groundwater flow is estimated to be 36.5 feet per year.
EXTENT OF CONTAMINATION The affected ground water extends eastward from the source area for a
distance of approximately 2,000 feet, attaining a maximum width of approximately 2,500 feet at this distance.
The saturated thickness varies from 10 feet to 60 feet, with an average thickness of 40 to 50 feet. The
remediation treatment will be performed on the area of highest contaminant concentration, although it will be
volumetrically less than 1 % of the entire contaminant plume.
PROPOSED INJECTION The injectant will consist of a mixture of Sodium Permanganate, Potassium
Permanganate, and municipal supply water. A mobile direct -push unit will be used to push injection rods to the
desired depths for the injection of the mixture, the rods withdrawn, and each hole abandoned by being filled
with hydrated bentonite. A pilot study will first be performed in which 1,980 gallons of a Sodium Permanganate
mixture will be injected into 22 direct -push points over two, 620 square -foot areas into the unsaturated zone.
The procedure will also be performed in another area by injecting 450 gallons of injectant into the saturated
zone through 9 more direct -push points. The effectiveness of these efforts will be evaluated for 3 to 12 months.
Pending a successful outcome, the full-scale remedial effort will consist of 76 direct -push points that will be
performed over an area of approximately 8,585 square feet to inject a total of 5,928 gallons of combined Sodium
Permanganate and Potassium Permanganate injectant. The area impacted is estimated to be more than 60 acres
in size, but the concentration of the contaminants is low in at least 90% of the affected area.

HOW IT WORKS The Sodium Permanganate and Potassium Permanganate are both oxidants which will
facilitate the chemical degradation of the solvent substances.
MONITORING Groundwater monitoring will be performed prior to injection, and then quarterly for at
least one year following injection, for Volatile Organic Compounds by EPA Method 8260, for Total Manganese
and Dissolved Manganese by EPA Method 6010, for temperature, dissolved oxygen, pH, oxidation-reduction
potential, and specific conductivity, on existing wells MW-1, MW-2, MW-3R, MW-5, MW-6, and on one
proposed well that is to be installed inside the building. This is the same monitoring as is described in the
proposed monitoring plan. Since all of the monitoring wells are situated in the most highly contaminated area of
the plume, the monitoring data will not be entered into the BIMS computer system.
EPIDEMIOLOGY On June 11, 1999, the DHHS' Epidemiology Branch provided comments on Sodium
Permanganate, and provided an email on April 4, 2002 stating that the precautions listed in the comments for
Sodium Permanganate can also be followed for Potassium Permanganate, for groundwater remediation. Dr.
Luanne Williams did not present any information that would preclude the use of these products for injection but
did provide a health risk analysis and worker safety precautions, which are in Part X of the attached permit.
REGIONAL OFFICE COMMENTS Jim Barber of the Fayetteville Regional Office recommends issuance of this
permit. He further recommended that copies of the most recent area -wide groundwater monitoring report issued
by ATC (issued on July 13, 2010 or later) be forwarded to the Fayetteville Public Works Commission and to the
Cumberland County Health Department in the interests of public health by assisting these agencies in their
identification of impacted water supply wells. Table 1 of the subject permit application makes several references
to sampling events that have already taken place at water supply wells in the affected area under the Drycleaning
Solvent Cleanup Act Program (DSCA). Mr. Al Chapman, who is with the DWM Superfund Section DSCA
Program, was contacted to ascertain his agency's responsibilities for notification of these organizations. He
verified that the DWM is actively working with both agencies to furnish them with information which includes
the July 13, 2010 ATC groundwater monitoring report, to keep them informed, and to extend a water line to
those residences, etc. whose water supplies could be endangered by the subject contamination. The Regional
Office also recommended that the subject permit be copied to the City of Fayetteville's Public Works
Commission and to the Cumberland County Health Department