WI0700012_Permit (Issuance)_20171129

Central Filth: APS _ SWP
11/29/2017
Permit Number •1N10700012 Permit Tracking Slip
Program Category
Ground Water
Permit Type
Status Protect Type
Issued Renewal
Version Permit Classification
Injection Other Wells Individual
Primary Reviewer
shristi.shrestha
Coastal SWRuIe
Permitted Flow
Facility
Permit Contact Affiliation
Mark D. Johnson
General Manager
1530 NC Hwy 306 S
Aurora
' NC 278069245
Facility Name
PCS Phosphate Company Inc.
Location Address
1530 Hwy 306 S
Aurora
Owner
NC 27806
Major/Minor Region
Minor Washington
County
Beaufort
Facility Contact Affiliation
Owner Name
PCS Phosphate Company Inc
Dates/Events
Owner Type
Non-Govemment
Owner Affiliation
Raef Sully
President
1101 Skokie Blvd
Northbrook
IL 60062
Scheduled
Orig Issue App Received Draft Initiated Issuance Public Notice Issue Effective Expiration
12/5/1991 9/29/2017 11/27/2017 2/2/2018 1/31/2023
Regulated Activities Requested /Received Events
Groundwater remediation
Outfall
RO staff report received
RO staff report requested
RO staff report received
11/8/17
10/9/17
Waterbody Name Streamlndex Number Current Class Subbasin

ISION OF WATER RESOURCES
WQROS
November 16, 2017
MEMORANDUM
TO: FILE / Debra Watts
FROM: Shristi Shrestha
RE: Issuance of permit to inject (Permit #WI0700012)
PCS Phosphate Company Inc. Facility
Beaufort County
L.r)r-Cjt
ti
I recommend that Permit Number WI0700012 be re -issued to the above. The facility was designed in 1988 response to
leak incident involving tank 008. The facility works continuously to withdraw contaminated water which is'treated by an
anthracite/sand filter and UV. This mechanism is removing contaminants from the tank farm area where the leak took place.
Please refer to the memo from Michael Rogers from February 11, 2008 for further details.
According to the project interim report submitted with the renewal application, the injection/withdrawalstem is operating
satisfactorily and is able to capture groundwater within the limits of the tank farm. The iniectedfresh water flows northward
toward the withdrawal wells as well as southward and radially outward from two end wells (CIW-1 and CIW-7). About
one-third to one half of the injected water is captured by the withdrawal well. The remaining injection water flows away,
mostly southward from the tank farm. The water level in the Croatan Formation is lower than the water level in overlying
aquifers and hence groundwater cannot migrate into overlying aquifers. Please refer to Fig 4 and 6 for Phosphorous
concentration with time. Source (Project interim evaluation).
The Washington Regional staff have provided a staff report and recommended re -issuing the permit.

Water Resources
Environmental Quality
November 27, 2017
Mark Johnson
1530 NC HWY 306S.
Aurora, NC 27808
Re: Issuance of Injection Permit WI0700012
PCS Phosphate Company, INC.
Beaufort County, NC
Dear Mr. Johnson:
ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
LINDA CULPEPPER
Interim Director
In accordance with the permit renewal application received on September 29, 2017, we are forwarding permit
number WI0700012. This permit is to control migration of contaminated groundwater at the PCS Phosphate
Company, Inc. located at 1530 NC Highway 306S., Aurora, Beaufort County, NC 27806. This permit shall be
effective from February 2, 2018 (i.e., the day after the expiration date of the existing permit), which may differ
from the date of this letter and shall be subject to the conditions and limitations stated therein, including the
requirement to submit a Final Project Evaluation (FPE) as stated in PART VII — MONITORING AND
REPORTING REQUIREMENTS. Please read the entire permit to ensure that you are aware of all compliance
requirements of the permit.
In order to continue uninterrupted legal use of this well for the stated purpose, you should submit an application
to renew the permit 120 days prior to its expiration date. As indicated in the permit, this permit is not transferable
to any person without prior notice to, and approval by, the Director of the Division of Water Resources; If you
have any questions regarding your permit or the Underground Injection Control Program please call me at (919)
807-6406.
Best Regards,
Shristi Shrestha
Underground Injection Control (UIC) - Hydrogeologist
Division of Water Resources
Water Quality Regional Operations Section
cc: David May and Will Hart, WQROS — Washington Regional Office
Central Office File, WI0700012
-c1 Nothing Compares=.,_
State of North Carolina I Environmental Quality I Division of Water Resources
Water Quality Regional Operations Section
1636 Mail Service Center I Raleigh, North Carolina 27699-1636
919-707-9129

NORTH CAROLINA
ENVIRONMENTAL MANAGEMENT COMMISSION
DEPARTMENT OF ENVIRONMENTAL QUALITY
RALEIGH, NORTH CAROLINA
PERMIT FOR THE USE 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
PCS Phosphate Company, Inc.
Beaufort County
FOR THE OPERATION OF 7 (Seven) INSITU REMEDIATION / INJECTION WELLS, defined
in Title 15A North Carolina Administrative Code 2C .0209(5)(b)(viii), to inject water to control
the migration of contaminated groundwater. These injection wells/points are located at the at the
PCS Phosphate Company, Inc. Facility, 1530 NC Highway 306S., Aurora, Beaufort County, NC
27806, and will be operated in accordance with the renewal application submitted September 29,
2017, and in conformity with the specifications and supporting data submitted, all of which are
filed with the Department of Environmental Quality 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 02C .0100 and
.0200; and any other Laws, Rules, and Regulations pertaining to well construction and use.
This permit shall be effective from February 2, 2018 (i.e., the day after the expiration date of the
existing permit), until January 31', 2023 and shall be subject to specified conditions and
limitations set forth in Parts I through VIII hereof.
Permit issued this the 27th day of November 2017.
For Linda Culpepper, Interim Director
Division of Water Resources
By Authority of the Environmental Management Commission.
Permit No. WI00700012 PAGE 1 OF 6
ver. 2-25-2016 UIG5I/5T

PART I — PERMIT GENERAL CONDITIONS
1. The Permittee shall 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).
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 [15A
NCAC 02C .0211(1)].
3. This permit is valid only for construction or operation 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 Division of Water Resources (DWR) [15A NCAC
.0211(a)].
4. This permit is not transferable without prior notice and approval. In the event there is a desire
for the facility to change ownership, or there is a name change of the Pertnittee, a formal permit
amendment request and any supporting materials must be submitted at least 30 days prior to
the date of the change [15A NCAC 02C .0211(q)].
5. The issuance of this permit shall not relieve the Permittee of the responsibility of complying
with any and all statutes, rules, regulations, or ordinances that may be imposed by other local,
state, and federal agencies having jurisdiction. Furthermore, the issuance of this permit does
not imply that all regulatory requirements have been met [15A NCAC 02C .0203].
PART lI - WELL CONSTRUCTION GENERAL CONDITIONS
1. Each injection well shall not hydraulically connect separate aquifers [15A NCAC 02C
.0211(c)].
2. Multi -screened wells shall not hydraulically connect different aquifers or zones having
differences in water quality that would result in a degradation of any aquifer or zone [15A
NCAC 02C .0225(g)(17)].
3. Each injection well shall be constructed in such a manner that water from land surface cannot
migrate into the gravel pack or well screen [15A NCAC 02C .0225(g)(4)].
4. Bentonite grout shall not be used to seal any water -bearing zone with a chloride concentration
equal to or greater than 1,500 milligrams per liter. In areas where elevated chloride levels are
known to exist or are probable, such as coastal areas, chloride levels shall be verified in the
field to determine existing conditions. [15A NCAC .0225(g)(8)].
5. Each injection well shall be secured to reasonably insure against unauthorized access -and use.
Each well shall be permanently labeled with a warning that it is for injection purposes and the
entrance to each well shall be secured with a locking cap as defined in G.S. 87-85(16) [15A
NCAC 02C .0225(g)(23)].
Permit No. WI00700012 PAGE 2 OF 6
ver. 2-25-2016 UIC-5I/5T

6. Each injection well shall be afforded reasonable protection against damage during construction
and use [15A NCAC 02C .0225(i)(3)].
7. Each permanent injection well shall have a permanently affixed identification plate [15A
NCAC .0225(g)(20)].
8. A copy of the completed Well Construction Record (Form GW-1) shall be submitted as
described in Part VI.3 of this permit (the original document goes to the address indicated on
the form).
PART III - WELL CONSTRUCTION SPECIAL CONDITIONS
1. At least forty-eight (48) hours prior to constructing or operating each injection well, the
Permittee shall notify the Underground Injection Control (UIC) Central Office staff, telephone
number 919-807-6406, and the Washington Regional Office staff, telephone number 252-946-
6481 [15ANCAC 02C .0211(k)].
PART IV - OPERATION AND USE CONDITIONS
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 [15A NCAC 02C
.0211(j)].
2. The issuance of this permit shall not relieve the Permittee of the responsibility for damages
to surface water or groundwater resulting from the operation of this facility [15A NCAC 02C
.0206].
3. The injection facility shall be properly maintained and operated at all times to achieve
compliance with the conditions of this permit and the rules of 15A NCAC 02C .0200, even
if compliance requires a reduction or elimination of the permitted activity [15A NCAC 02C
.0211(j)].
4. 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 that may be required, such as the repair,
modification, or abandonment of the injection facility [15A NCAC 02C .0206].
PART V - INSPECTIONS [15A NCAC 02C .0211(k)]
1. Any duly authorized officer, employee, or representative of the Division of Water'Resources
(DWR) 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.
Permit No. WI007000I2 PAGE 3 OF 6
ver. 2-25-2016 UIC-5I/5T

2. DWR 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 VI - MONITORING AND REPORTING REQUIREMENTS
1. The Permittee shall collect samples from the riser pipe of CIW7 (fluid to be injected into last
injection well in line) and from monitoring wells MWTF-1 C, MWTF-2C and MWTF-3C
(groundwater from the Croatan formation) every April and October for the following
parameters: Total Dissolved Solids pH, Manganese, Total Organic Carbon, Sulfate, Chloride,
Total Phosphorous, and Fluoride.
2. All sample results shall be submitted to the WQROS's Washington Regional Office and the
Raleigh Central Office Any monitoring (including groundwater, surface water, or soil
sarnpling) 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
3. Records of well construction, repair, or abandonment shall be submitted within 30 days of
completion of such activities [15A NCAC 02C .0225(k)(1)(A)].
4. An Injection Event Record shall be submitted within 30 days of each injection event [15A
NCAC 02C .0225(k)(1)(B)].
5. The Permittee shall submit a Final Project Evaluation (FPE) within 9 months after completing
all injection -related activity associated with this permit or produce an interim evaluation to be
submitted with a renewal application for this permit. Both the final project evaluation and
interim evaluation shall contain historical monitoring data and updated contaminant plume and
potentiometric surface maps
6. All monitoring results, forms, and reports required in this Part shall be submitted to:
UIC Program
NC Division of Water Resources and
1636 Mail Service Center
Raleigh, NC 27699-1636
Water Quality Regional Operations Section
DWR Washington Regional Office
943 Washington Square Mall
Washington, NC 276889
7. The Pemiittee shall report any monitoring or other information that indicates noncompliance
with a specific permit condition, that a contaminant may cause a violation of applicable
groundwater quality standards, or that a malfunction of the injection system may cause the
injected fluids to migrate outside the approved injection zone or area. As specified in rule
15A NCAC 02C .0211(r), noncompliance notification shall be as follows:
(A) Oral notification shall be given within 24 hours of the occurrence, or first knowledge
of the occurrence, to the Washington Regional Office, telephone number 252-946-
6481.
Written notification shall be made within five days of the occurrence and submitted
(B)
Permit No. WI00700012 PAGE 4 OF 6
ver. 2-25-2016 UIC-5I/5T

to the addresses in Item #6 above.
(C) The written notification shall contain a description of the noncompliance and its
cause; the period of noncompliance, including dates and times; if the noncompliance
has not been corrected, the anticipated time it is expected to continue; and any steps
taken or planned to reduce, eliminate, and prevent reoccurrence of the
noncompliance.
8. 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 [15A NCAC 02C .0211(b)].
PART VII - PERMIT RENEWAL [15A NCAC 02C .0211(b)]
In order to continue uninterrupted legal use of the injection facility for the stated purpose, the
Permittee should submit an application to renew the permit 120 days prior to its expiration date.
PART VIII - CHANGE OF WELL STATUS [15A NCAC 02C .0240]
1. 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 .0240, 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
15A NCAC 2C .0240, 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 WORDS staff 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.
Permit No. WI00700012 PAGE 5 OF 6
ver. 2-25-2016 UIC-5I/5T

(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 .O225(k)(1)(A) within 30 days of completion of abandonment.
3. The written documentation required in Part IX (1) and (2)(G) shall be submitted -to:
UIC Program
DEQ-Division of Water Resources
1636 Mail Service Center
Raleigh, NC 27699-1636
Permit No. WI00700012 PAGE 6 OF 6
ver. 2-25-2016 UIC-5I/5T