WI0500375_Permit (Issuance)_20110601

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 68-0002
FOR THE CONSTRUCTION AND OPERATION OF 12 TYPE 5I INJECTION WELLS, defined in
Title 15A North Carolina Administrative Code 2C .0209(e)(3)(C), to inject an EHC solution for the
enhancement of anaerobic bioremediation of chlorinated ethenes. These injection wells/points will
be located at the former American Cleaners Site, 201 South Estes Drive, Chapel Hill, Orange
County, North Carolina, and will be operated in accordance with the application submitted April 15,
2011, and in conformity with the specifications and supporting data submitted, 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 April 30, 2013, and
shall be subject to the specified conditions and limitations set forth in Parts I through X hereof.
Permit issued this the day of , 2011.
r
Coleen H. Sullins, Director
`E Division of Water Quality
By Authority of the Environmental Management Commission.
Permit No. WI0500375 PAGE 1 OF 7
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PART I - WELL CONSTRUCTION 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 construction of the number of injection wells described in the
application and other supporting data. Construction of additional injection wells must be
approved in advance by the Aquifer Protection Section.
4. Each injection well shall not hydraulically connect separate aquifers.
Each injection well shall be constructed in such a manner that water from land surface cannot
migrate into the subsurface.
6. Utilized direct push equipment shall be afforded reasonable security against misuse and
vandalism during injection activities.
7. Each injection point shall be located and recorded so that its general location can be reasonably
identified.
8. Within 30 days of completion of well construction, a completed Well Construction Record
(Form GW-1) must be submitted for each injection well to:
Aquifer Protection Section-UIC Staff
DENR-Division of Water Quality
1636 Mail Service Center
Raleigh, NC 27699-1636
PART II - WELL CONSTRUCTION SPECIAL CONDITIONS
At least forty-eight (48) hours prior to constructing each injection well, the Permittee shall notify the
Aquifer Protection Section -Underground Injection Control (UIC) Central Office staff, telephone
number [phone] and the Raleigh Regional Office Aquifer Protection Section Staff, telephone
number [phone].
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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 wells 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 maybe 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 maybe 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
The injection facility shall be effectively maintained and operated at all times so that there is no
contamination of groundwater which will render it unsatisfactory for normal use. In the event
that the facility fails to perform satisfactorily, including the creation of nuisance conditions or
failure of the injection zone to adequately assimilate the injected fluid, the Permittee shall take
immediate corrective actions including those actions that may be required by the Division of
Water Quality such as the repair, modification, or abandonment of the injection facility.
2. 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.
3. 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.
PART V - OPERATION AND MAINTENANCE REQUIREMENTS
1. The injection facility shall be properly maintained and operated at all times.
2. The Permittee must notify the Division and receive prior written approval from the Director of
any planned physical alterations or additions in the permitted facility or activity not specifically
authorized by the permit.
3. 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.
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PART VI - INSPECTIONS
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. Vapor monitoring currently being conducted in the daycare facility of the Olin T. Brinkley
Baptist Church shall be expanded to coincide with the post -injection monitoring schedule.
2. The proposed monitoring plan included in the application shall be followed and incorporate the
expanded vapor monitoring specified in Part VII.1. All sample results shall be submitted to the
Aquifer Protection Section's Raleigh 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 insure surface and ground water protection, will be established and
an acceptable sampling reporting schedule shall be followed.
3. The Permittee shall submit an Injection Event Record within 30 days of completing each
injection.
4. 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.
5. The monitoring results and the final project evaluation shall be submitted to:
Permit No. WI0500375 PAGE 4 OF 7
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and to:
Aquifer Protection Section-UIC Staff
DENR-Division of Water Quality
1636 Mail Service Center
Raleigh, NC 27699-1636
Aquifer Protection Section
DENR-DWQ Raleigh Regional Office
1628 Mail Service Center
Raleigh, NC, 27699-1628
6. The Permittee shall report by telephone, within 48 hours of the occurrence or first knowledge of
the occurrence, to the Raleigh 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.
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.
8. 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 permit 120 days prior to its expiration date.
PART IX - CHANGE OF WELL STATUS
The Permittee shall provide written notification within 15 days of any change of status of an
injection well. Such a change would include the discontinued use of a well for injection. If a
well is taken completely out of service temporarily, the Permittee must install a sanitary seal. If a
well is not to be used for any purpose that well must be permanently abandoned according to
15A NCAC 2C .0113, Well Construction Standards.
2. When operations have ceased at the facility and a well will no longer be used for any purpose,
the Permittee shall abandon that injection well in accordance with the procedures specified in
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15A NCAC 2C .0113(b), 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.
(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.
3. The written documentation required in Part IX (1) and (2) (G) shall be submitted to:
Aquifer Protection Section-UIC Staff
DENR-Division of Water Quality
1636 Mail Service Center
Raleigh, NC 27699-1636
PART X — WORKER PRECAUTIONS DURING APPLICATION
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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 a 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.
6. Access to the area of application should be limited to the workers applying the product. In
order to minimize exposure to unprotected individuals, measure should be taken to prevent
access to the area of application.
Permit No. WI05003.75 PAGE 7 OF 7
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DIVISION OF WATER QUALITY
AQUIFER PROTECTION SECTION
May 31, 2011
PERMIT ISSUANCE MEMO
TO: Debra Watts
THROUGH: Thomas Slusser
FROM: John McCray
RE: Permit To Inject an EHC solution
American Dry Cleaners Site
I recommend that Permit Number WI0500375 be issued to the Petitioner for DSCA Site 68-0002 to inject an EHC
solution to remediate groundwater contaminated with chlorinated solvents through in situ chemical reduction.
SITE DESCRIPTION The site currently operates as a retail center in which American Dry Cleaners previously
operated as a full service dry-cleaning facility. An investigation conducted in 1995 for an Underground Storage Tank
removal and Closure Report discovered groundwater contamination by chlorinated solvents. Following a site
assessment, soil excavation was conducted in early 1996 to reduce site contamination. Aggressive Fluid Vapor
Recovery activities were conducted at the site to mitigate continuing contamination in 2009 and 2010.
HYDROGEOLOGIC DESCRIPTION The site is underlain by residual material and siltstone and sandstone of the
Deep River Triassic Basin. Residuum overlying the bedrock consists of silty sand and sandy silt and extends to a
depth maximum of approximately 15 feet. Bedrock consists of siltstone that pinches out under the southern part of
the site, and arkosic sandstone which underlies the siltstone. Depth to groundwater across the site varies from 3 to 5ft
below ground surface(Attachment B). Flow of the groundwater occurs at 0.018 ft/day to the east across the site under
a hydraulic gradient of 0.016 ft/ft. The aquifer has an average hydraulic conductivity .23 ft/day and an effective
porosity of —20%.
EXTENT OF CONTAMINATION Contamination at this site underlies the southern portion of the dry cleaning
facility and the parking area to the south of the facility and is roughly triangular in areal shape (Attachment #4a),
extending to the ease southeast away from the former facility. The surface area of the plume is approximately 88,500
square feet and extends to a maximum depth of—31feet (Attachment 5b).
PROPOSED INJECTION The Applicant proposes a single injection event of a solution composed of EHC to
enhance reductive dechlorination of chlorinated solvent contamination underlying the site. The injections will occur
through twelve direct -push injection points (Attachment 3) over a depth interval of ten feet. The total volume of
injectant is proposed to be 432 gallons, and will equal «1% of the pore volume within the saprolite aquifer
contaminated by chlorinated solvents.
HOW IT WORKS EHC is a solution containing zero-valent iron and controlled release carbon designed to
stimulate in situ chemical reduction of chlorinated solvents.
MONITORING Groundwater monitoring will consist of one pre -injection event, then at one week, one
month, two months and quarterly for the one-year period following the injection event. Vapor Monitoring within
the daycare will be added to the proposed monitoring plan to be conducted at the same frequency of the
groundwater sampling. All samples collected will be analyzed for physical parameters to include temperature,
dissolved oxygen, pH, oxidation-reduction potential, and specific conductivity. Laboratory testing will analyze
samples for VOCs; chlorides, carbon dioxide, methane, ethane, and ethene. Pre -injection samples will be taken from

eleven existing monitoring wells (2W-2, 2W-2D, 2W-4 through 2W-6, 2W-8, MW-1 through MW-5), and post -
injection samples will be taken from six existing monitoring wells (2W-5, 2W-6, MW-1, MW-2, MW-3, and MW-5).
Monitoring well and sampling information are discussed in Attachment F: Monitoring Plan and well details are
shown in Attachment G: Well Data.
EPIDEMIOLOGY The DHHS' Epidemiology Branch provided comments on November 3, 2004 for the use of
EHC for groundwater remediation. Dr. Luanne K. Williams did not present any information that would preclude the
use of EHC solution for injection, but did provide health risk analyses and worker safety precautions, which are in
Part X of the attached permit.
REGIONAL OFFICE COMMENTS Eric Rice of the Raleigh Regional Office recommend issuance of this permit with
the additional consideration of vapor monitoring within the church daycare. After talking with Mike Cunningham of
DWM DSCA, vapor monitoring that is currently being conducted will be expanded to coincide with injection and
post injection monitoring.