WI0500375_Staff Report_20110516

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North Carolina Department of Environment and Natural
Beverly Eaves Perdue
(4),iiernor
Memorandum
Division of Water Quality
Coleen IL Sullins
Director
May 16, 2011
To: John McCray
Groundwater Protection Unit, Central Office
From: Eric Rice
Aquifer Protection Section, Raleigh Regional Office
Through: Jay Zimmerman, Regional Supervisor 5�
Aquifer Protection Section, Raleigh Regional Office
Subject: American Cleaners
201 South Estes Drive
Chapel Hill, N.C.-Orange County
Permit # W10500375
RECEIVED /DENR/DWQ
Aquifer Protection Section
MAY 17 2011
Resources
Dec Freeman
Secretary
Enclosed is the regional staff report regarding the submittal of a permit application for the
injection of EHC at the facility listed above in Chapel Hill, N.C. The permit is being requested in
order to remediate the presence of chlorinated solvents in groundwater associated with a release
from a dry cleaning operation. Please contact me at [phone] if you have any questions
about the staff report.
cc: file
Attachment: APRSR form
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AQUIFER PROTECTION REGIONAL STAFF REPORT
Date: May 16, 2011 County: Orange
To: Aquifer Protection C.O. Permittee: Phillip Atkins (DSCA Petitioner 68-0002)
Central Office Reviewer: John McCray Project Name: American Cleaners
Regional Office Inspector: Eric Rice (RRO) 9WI0500375
I. GENERAL INFORMATION
1. This application is (check all that apply): ® New ❑ Renewal
❑ Minor Modification ❑ Major Modification
Surface Irrigation ❑ Reuse ❑ Recycle ❑ High Rate Infiltration ❑ Evaporation/Infiltration Lagoon
❑ Land Application of Residuals ❑ Attachment B included ❑ 503 regulated ❑ 503 exempt
❑ Distribution of Residuals ❑ Surface Disposal
❑ Closed -loop Groundwater Remediation ® Other Injection Wells (including in situ remediation)
Was a site visit conducted in order to prepare this report? N Yes or ❑ No.
a. Date of site visit: May 10, 2011
b. Person contacted and contact information: Kevin Baarson (Withers and Ravenel)
c. Site visit conducted by: E. Rice
d. Inspection Report Attached: ❑ Yes or ® No.
2. Is the following information entered into the BIMS record for this application correct?
❑ Yes or ® No. If no, please complete the following or indicate that it is correct on the current application.
For Disposal and Injection Sites:
(If multiole sites either indicate which sites the information aD0lies to. coon and Haste a new section into the
document for each site, or attach additional pages for each site
a. r ,. atien(s)-
b. Driving Directions: 40 to 151501 to Chapel Hill. Right onto Willow Drive, Left .into commercial area.
Former facility was located on east end of Harris Teeter
c. USGS Quadrangle Map name and number: unk.
d. Latitude: 35 55 23 Longitude: 79'01 33 Note: GPS unit non -operational. Google earth lat. long. (DMS)
J.T SS is 79 C)l 34
IY. INJECTION WELL PERMITAPPLICATIONS (Complete these two sections for all systems that use injection
wells, including closed -loop groundwater remediation effluent injection wells, in situ remediation injection wells, and heat
pump injection wells.)
Description Of Well(S) And Facilities — New, Renewal. And Modification
1. Type of injection system:
❑ Heating/cooling water return flow (5A7)
❑ Closed -loop heat pump system (5QM/5QW)
® In situ remediation (5I)
❑ Closed -loop groundwater remediation effluent injection (5L/"Non-Discharge")
FORM: American Cleaners (OR) WI0500375.doc 1

AQUIFER PROTECTION REGIONAL STAFF REPORT
❑ Other (Specify:
2. Does system use same well for water source and injection? ❑ Yes ® No
3. Are there any potential pollution sources that may affect injection? ❑ Yes ® No
What is/are the pollution source(s)? What is the distance of the injection well(s) from the
pollution source(s)?
4. What is the minimum distance of proposed injection wells from the property boundary? Points appear to be
located just off of property boundary
5. Quality of drainage at site: ® Good ❑ Adequate ❑ Poor
6. Flooding potential of site: ® Low ❑ Moderate ❑ High
7. For groundwater remediation systems, is the proposed and/or existing groundwater monitoring program
(number of wells, frequency of monitoring, monitoring parameters, etc.) adequate? ❑ Yes ❑ No. Attach
map of existing monitoring well network if applicable. If No, explain and recommend any changes to the
groundwater monitoring program:
8. Does the map presented represent the actual site (property lines, wells, surface drainage)? ® Yes or ❑ No. If
no or no map, please attach a sketch of the site. Show property boundaries, buildings, wells, potential pollution
sources, roads, approximate scale, and north arrow.
V. EVALUATIONAND RECOMMENDATIONS
1. Provide any additional narrative regarding your review of the application.: Permit application is regarding a
pilot study for the injection of four hundred thirty two (432) gallons of a twenty nine percent solution of EHC
to treat the presence of chlorinated solvents in groundwater. EHC is reported to be comprised of a controlled
release carbon and zero valence iron particles. Injection will be completed utilizing twelve temporary injection
points that will be abandoned following injection. Injection will be completed under pressures of between 40
and 60 psi at a depth of approximately eight to ten feet below grade. Site observations: Site is located in the city
of Chapel Hill. Geologic setting is in the Triassic Basin. Groundwater seepage velocity was measured to be
approximately 13 ft/yr. The site setting is located on commercial property with a Church daycare located
adjacent to the injection area. City water is available to the surrounding properties. Injection area is located just
inside the property line. Recommendations: 1. Require analytical methods and frequency as proposed in
Attachment F of the application 2. Recommend vapor monitoring in conjunction with the groundwater
monitoring at adjacent daycare located at Olin T. Brinkley Baptist Church.
Attach Well Construction Data Sheet - if needed information is available
2. Do you foresee any problems with issuance/renewal of this permit? ❑ Yes ® No. If yes, please explain
briefly.
3. List any items that you would like APS Central Office to obtain through an additional information request.
Make sure that you provide a reason for each item:
FORM: American Cleaners (OR) WI0500375.doc 2

AQUIFER PROTECTION REGIONAL STAFF REPORT
Item Reason
4. List specific Permit conditions that you recommend to be removed from the permit when issued. Make sure
that you provide a reason for each condition:
Condition Reason
5. List specific special conditions or compliance schedules that you recommend to be included in the permit when
issued. Make sure that you provide a reason for each special condition:
Condition
Reason
41 and #2
#1Necesssary and #2 the presence of a daycare
approximately 80 feet from injection area
6. Recommendation: ❑ Hold, pending receipt and review of additional information by regional office; ❑ Hold,
pending review of draft permit by regional office; ❑ Issue upon receipt of needed additional information;
Issue; ❑ Deny. If deny, please state reasons:
ir
7. Signature of report preparer(s): .
Signature of APS regional supervisor:
Date:
Attachments:
FORM: American Cleaners (OR) W10500375.doc 3

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RECEIVED / DENR / DVVO
',,AWer Protertion Sectim
MAY 14 201' AQUIFER PROTECTION SECTION
APPLICATION REVIEW RF. UEST FORM
Date: April21, 2011
To: ❑ Landon Davidson, ARO-APS
❑ Art Barnhardt, FRO-APS
❑ Andrew Pitner, MRO-APS
® Jay Zimmerman, RRO-APS
E'Jb'�Co 17
❑ David May, WaRO-APS
❑ Charlie Stehman, WiRO-APS 0ffi'
❑ Sherri Knight, WSRO-APS
From: John McCraw , Groundwater Protection Unit
Telephone: [phone] Fax: [phone]
E Mail: john.mccrayei;ncdenr.gov
A. Permit Number: WI0500375
B. Owner: Petitioner for DSCA Site 68-0002
C. Facility/Operation: American Cleaners
® Proposed ❑ Existing ❑ Facility ❑ Operation
D. Application:
1. Permit Type: ❑ Animal ❑ Surface Irrigation ❑ Reuse ❑ H-R Infiltration
❑ Recycle ❑ VE Lagoon ❑ GW Remediation (ND)
® UIC - (5I) in -situ groundwater remediation
For Residuals: ❑ Land App. ❑ D&M ❑ Surface Disposal
❑ 503 ❑ 503 Exempt ❑ Animal
2. Project Type: ® New ❑ Major Mod. ❑ Minor Mod. ❑ Renewal ❑ Renewal w/ Mod.
E. Comments/Other Information: ❑ I would like to accompany you on a site visit.
Attached, you will find all information. submitted in support of the above -referenced application for your
review, comment, and/or action. Within 30 calendar days, please take the following actions:
® Return.a Completed Form APSSRR.
❑ Attach Well Construction Data Sheet.
❑ Attach Attachment B for Certification by the LAPCU.
❑ Issue an Attachment B Certification from the RO*.
* Remember that you will be responsible for coordinating site visits, reviews, as well as additional
information requests with other RO-APS representatives in order to prepare a complete Attachment B for
certification. Refer to the RPP SOP for additional detail.
When you receive this request form, please write your name and dates in the spaces below, make a copy
of this sheet, and return it to the appropriate Central Office -Aquifer Protection Section contact person
listed above.
RO-APS Reviewer:? Date:
FORM: APSARR 02/06 Page 1 of 1

North Carolina Department of Health and Human Services
Division of Public Health • Epidemiology Section
1912 Mail Service Center • Raleigh, North Carolina 27699-1912
Tel [phone] • Fax [phone]
Michael F. Easley, Governor Carmen Hooker Odom, Secretary
November 3, 2004
x.
MEMORANDUM
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TO: Evan Kane _
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Underground Injection Control Program °o
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Aquifer Protection Section -o
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W
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FROM: Luanne K. Williams, Pharm.D., Toxicologisg�
Medical Evaluation and Risk Assessment Unit C7
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Occupational and Environmental Epidemiology Branch
North Carolina Department of Health and Human Services
SUBJECT: Use of a Non -Biological Product EHC® by Adventus Remediation Technologies
to Enhance Biodegradation of Groundwater Contaminated with Chlorinated
Compounds at the BASF Technical Marketing Building Site in Enka, North
Carolina.
I am writing in response to a request for a health risk evaluation regarding the use
of use of a non -biological product EHCO, by Adventus Remediation Technologies, to
Enhance Biodegradation of Groundwater Contaminated with Chlorinated Compounds at
the BASF Technical Marketing Building Site in Enka, North Carolina. Based upon my
review of the information submitted, I offer the following health risk evaluation:
PRECAUTIONS DURING APPLICATION
1. Some effects or hazards reported to be associated with the chemical proposed for use are
as follows:
• Exposure can cause irritation of skin, eyes, nose, throat, and lungs (Medical
Management Micromedex TOMES Plus System CD-ROM Database, Volume 62,
2004)
2. If the products are 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 it is imperative that proper personal protective equipment be used. The
application process should be reviewed by an industrial hygienist to ensure that the most
appropriate personal protective equipment is used. r'
Location: 2728 Capital Boulevard • Parker Lincoln Building • Raleigh, N.C. 27604 An Equal Opportunity Employer

3. Persons working with this product should at least wear goggles or a face shield, gloves,
and protective clothing. Face and body protection should be used for anticipated splashes
or sprays. Again, consult with an industrial hygienist to ensure proper protection.
4. Eating, drinking, smoking, handling contact lenses, and applying cosmetics should never
be permitted in the application area during or immediately following application. 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 adverse reactions and
injuries.
6. Access to the area of application should be limited to the workers applying the product.
In order to minimize exposure to unprotected individuals, measures should be taken to
prevent access to the area of application.
7. According to the information submitted, no public or private water supplies were
identified within a 1500-foot radius. Hominy Creek is less than 30 feet to the east of the
injection areas. The nearest residence is greater than 1500 feet from the injection area,
and the nearest workplace is the Buncombe County Offices at 300 feet from the injection
area. Both of these are located upgradient from the injection area. Efforts should be
made to prevent contamination of existing or future wells and nearby surface waters that
may be located near the application area.
Please do not hesitate to call me if you have any questions at [phone].
cc: BASF
Mr. Joe McKeon
BASF Safety and Ecology
100 Campus Driver
Mail Stop F-409A
Florham Park, NJ 07932
ENSR Consulting and Engineering, (NC), Inc
Nanjun Shetty, P.E.
7041 Old Wake Forest Road, Suite 103
Raleigh, NC 27616
Adventus Remediation Technologies
Kerry Bolanos-Shaw
1345 Fewster Drive
Mississauga, Ontario L4W 2A5