WI0700049_Other Correspondence_20011102

mailbox:///Cl/WINDOWSr lication%20Data/Mozilla/Profiles/M
Subject: HRC Treatability Study
From: Mark Pritzl <[e-mail]>
Date: Fri, 02 Nov 2001 15:37:32 -0500
To: george lane <[e-mail]>
CC: [e-mail], [e-mail], Evan Kane <[e-mail]>,
[e-mail], [e-mail], Debra Watts
<[e-mail]>
George Lane,
The Underground Injection Control Group (UIC) of the Groundwater Section has
reviewed the Final Treatability Study Work Plan for Operable Unit 1, Site 47 Marine
Corps Air Station Cherry Point North Carolina and Application for a Permit to
Construct and/or Use a Well(s) for Injection, dated March, 2001 and August 23,
2001, respectively.
The Work Plan and unsigned UIC application meet all state regulatory requirements
(15A NCAC 2C.0200) to construct and operate injection wells for the purpose of
injecting an HRC slurry to enhance reductive dehalogenation of the dissolved
groundwater contamination at this site. At this time the Groundwater Section/UIC
Program has no further comments or suggestions and gives its approval to commence
this Final Treatability Study Work Plan. The Groundwater Section wishes CH2MHi11
success in it's Study and appreciates the professionalism in its response to the
Groundwater Section's concerns.
If you have any questions regarding this letter or the state injection well rules
please contact me at [phone] or Evan Kane at [phone].
Sincerely,
Mark Pritzl
UIC Program
1 of 1 11/2/2001 3:47

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Subject: Cherry Point HRC Injection
From: Mark Pritzl <[e-mail]>
Date: Thu, 01 Nov 2001 08:43:40 -0500
To: GROVER NICHOLSON <[e-mail]>
CC: Bill <[e-mail]>, JACK BUTLER <[e-mail]>, Evan
Kane <[e-mail]>, Debra Watts <[e-mail]>
Bill Billi and Grover Nicholson,
The Underground Injection Control Group (UIC) of the Groundwater Section has reviewed the Final
Treatability Study Work Plan for Operable Unit 1, Site 47 Marine Corps Air Station Cherry Point
North Carolina and Application for a Permit to Construct and/or Use a Well(s) for Injection, dated
March, 2001 and August 23, 2001, respectively. The application material does not meet all state
regulatory requirements specified in 15A NCAC 2C.0200 to construct and operate wells for the
purpose of injecting a HRC slurry for Enhanced Reductive Dehalogenation of the dissolved
contamination at this site.
• Monitor wells data shows that the vertical hydraulic gradient is roughly the same as the
horizontal hydraulic gradient, which indicates a vertical groundwater flow component in the
surficial aquifer at this study site. More specifically, the site area is a recharge zone with
shallow groundwater movement toward deeper zones. Two potentiometric maps were
submitted but they are inadequate in showing direction of groundwater movement, which is
required by 15A NCAC 2C .0211 (d)(3)(B)(iii).
• The vertical extent of the contaminant plume (including isoconcentration lines and plume cross
sections) was not submitted as required by 15A NCAC 2C .0211 (d)(3)(B)(iv).
• Since groundwater direction and the vertical extent of the contaminant plume has not been fully
characterized, it is unclear if the proposed monitor well system will meet requirements set by
15A NCAC 2C .0213 (c)(2)(D).
It is noted that the documents in question are dated in March and August of 2001, but were not
received in this office until October 24 of 2001. To better serve The Division of Waste Management,
it is recommended that any future proposed injection activities be submitted in a timely matter so that
the UIC Group can properly assist with the review of further injection well proposals.
If you have any questions regarding this review please contact me at [phone] or Evan Kane at
[phone].
Mark Pritzl
UIC Program
Groundwater Section
Division of Water Quality
1 of' 1 11/2/2001 1:41

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uNITED STATES MARINE CORPS
MARINE CORPS AIR STATION
PSC BOX 8003
CHERRY POINT, NORTH CAROLINA 28533-0003
5090/26742
LN
October 19, 2001
North Carolina Department of
Environment and Natural Resources
Division of Water Quality
Groundwater Section, UIC Program
Attn: Mr. Mark Pritzl
1636 Mail Service Center
Raleigh, North Carolina 27699-1636
Dear Mr. Pritzl:
Enclosed please find a completed but unsigned APPLICATION FOR
PERMIT TO CONSTRUCT AND/OR USE A WELL(S) FOR INJECTION and a copy of
the Final Treatability Study Work Plan for Operable Unit 1, Site 47.
Marine Corps Air Station (MCAS) Cherry Point is implementing the
described work under the Air Station's IR program and the
Comprehensive Environmental Response, Compensation, and Liability Act
(CERCLA). Since this is an on -site response action subject to 40 CFR
300.400(e) (1), we are not seeking a permit for this work. However, in
order to ensure compliance with the substantive requirements of the
State's Underground Injection Control Program, we ask that you review
these documents and assist us in identifying and correcting any
deficiencies or problem areas that you note. The North Carolina
Department of Environment and Natural Resources, Superfund Section,
Federal Facilities Branch has reviewed and approved the enclosed work
plan. This work is scheduled to commence on November 3, 2001.
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If you have questions or require additional information, please
contact Mr. William Belli of the Environmental Affairs Department at
[phone].
Sincerely,
D. A. McFARLAND
Supervisory Environmental Engineer
By direction of the
Commanding General
Enclosures: 1. APPLICATION FOR PERMIT TO CONSTRUCT AND/OR USE A
WELL(S) FOR INJECTION
2. Final Treatability Study Work Plan for Operable
Unit 1, Site 47