WI0600074_Correspondence_20110614

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North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Coleen H. Sullins Dee Freeman
Governor Director Secretary
June 14,2011
Mr. Steve Edge, Solid Waste Director
Robeson County Solid Waste Management Facility
246 Landfill Rd.
St. Pauls, NC 28384
Ref: Issuance of Injection Permit WI0600074
Robeson County
St. Pauls, Robeson County, North Carolina
Dear Mr. Edge:
In accordance with the application received on April 1, 2011, and additional information received May 26, 2011, we are
forwarding permit number WI0600074. This permit is to inject 3-D Microemulsion to remediate groundwater
contaminated with various volatile and semivolatile organic compounds at the Robeson County Solid Waste Management
Facility, 246 Landfill Rd., St. Pauls, Robeson County, NC 28384. This permit shall be effective from the date of issuance
until May 31, 2013, and shall be subject to the conditions and limitations stated therein, including the requirement to
submit a fmal project evaluation as stated in PART VIE — MONITORING AND REPORTING REQUIREMENTS. Please
read the entire permit to ensure that you are aware of all compliance requirements of the permit.
Please pay special attention to Part VII.2 in the permit. The proposed monitoring plan included in the application
has been modified per the Additional Information received May 26, 2011.
You will need to notify this office and the Fayetteville Regional Office by telephone 48 hours prior to initiation of
operation of the facility. In order to continue uninterrupted legal use of the injection facility for the stated purpose, you
must submit an application to renew the permit 120 days prior to its expiration date. Please contact me at 919-715-6166
or Michael.Rogers(a,ncdenr.gov if you have any questions about your permit.
Best Regards,
//�� Q✓—
Michael Rogers, P.G. (NC & FL)
Environmental Specialist
Underground Injection Control Program
cc: Art Barnhardt, Fayetteville Regional Office
Matt Einsmann, Brown and Caldwell, 5410 Trinity Rd., Suite 320, Raleigh, NC 27607
WI0600074 Permit File
Elizabeth D. Wemer, Division of Waste Management -Oberlin Office
AQUIFER PROTECTION SECTION
1636 Mail Service Center, Raleigh, North Carolina 27699-1636 ,
Location: 2728 Capital Boulevard, Raleigh, North Carolina 27604
Phone: [phone] k FAX 1: 919-715-0588; FAX 2:919-715-6048 \ Customer Service: 1-877-623-6748
Internet: www.ncwateroualitv.orq
An Eaun 0poonunily t Amrtpatne Action Employe,
One
NorthCarolina
illie

Brown AND
Caldwell
5410 Trini ad
Suite 320
Raleigh, NC 27607
T: 919.233.9178
F: 919.233.0144
March 25, 2011
Mr. Michael Rogers, P.G.
Environmental Specialist
NC DENR Division of Water Quality
Aquifer Protection Section
1636 Mail Service Center
Raleigh, North Carolina 27699-1636
RECEIVED / DENR / DWQ
Aquifer Protection Section
MAY 26 2011
139605
Subject: Response to Additional Information Request
Application for Permit to Construct and/or Use a Well(s) for
Injection
Injection Well Permit Application W10600074
Robeson County Landfill
St. Pauls, Robeson County, North Carolina
Dear Mr. Rogers:
0n behalf of Robeson County, Brown and Caldwell submits the following
additional information in response to your letter dated May 20, 2011.
First, the pilot test will consist of injecting 3DMeTM solution into one injection
point (IP-2). During the initial injection, data from injection points IP-1 and IP-
3, monitoring well MW-5, and monitoring points MP-1 and MP-2 will be
collected to assist in determining the radius of influence (ROI) of the injection.
If the solution is not observed in any of the observation points during the
initial injection, then the solution will also be injected in IP-1 and IP-3.
Monitoring well MW-5 and monitoring points MP-1 and MP-2 will then be used
to assess the ROI of the injection.
Therefore, we are requesting approval to install three injection points (IP-1
through IP-3) and two monitoring points (MP-1 and MP-2). A figure has been
included in Attachment A to show the location of the proposed injection and
monitoring points in relation to the existing monitoring well MW-5.
Second, page 5 of the UIC permit application has been revised to reflect the
proper casing length of the injection points. A new copy of page 5 has been
included in Attachment B. In addition, separate schematics of the proposed
injection points and monitoring points have been included in Attachment C.
Third, a Material Safety Data Sheet for 3DMeTM has been included in
Attachment D.
P:\Robeson County\139605 - Robeson TO21 - CMS\C-IC PermitU,tr_ M Rogers_UIC Permit Application_AdditionaI
Information 20110524.docx

Mr. Michael Rogers, P.G.
NC DENR Division of Water Quality
Page 2
May 24, 2011
RECEIVED / DENR / DWQ
Aquifer Protection Section
MAY 26 201
If you have any questions or need any additional information, please contact
me at [phone].
Very truly yours,
Brown and Caldwell
Matt Einsmann, PE
Project Manager
Attachments (4)
1. Attachment A: Figure of Proposed Injection and Monitoring Points
2. Attachment B: Page 5 of the UIC Permit Application
3. Attachment C: Schematic of Injection and Monitoring Points
4. Attachment D: MSDS for 3DMeT""
cc. Steve Edge, Robeson County
Jim Barber, Fayetteville Regional Office
P:1Roheson County1139605 - Robeson TO2I - CMS WIC Permitlltr_ M Rogers_CIC Permit Application Additional
Information 2(II10524.docx

Response to Additional Information Request - Application for Permit to Construct and/or Use a Wells) for Injection
RECEIVED / DENR / DWQ
Aquifer Protection Section
MAY 26 2011
Attachment A: Figure of Proposed Injection and Monitoring Points
Brown Caldwell

MW-20
110
139.0
111
138.;
MMW3
MMW-5
0 MMW-4
4
!NW -10
4
M W-2
MW-11
MMW-6
MMW-6A
MW-8A
410
MW-9
MMw-7
4
MW-8
4-
MW-3
112
an.5
•
MP-1
MONITORING POINT
• INJECTION POINT
IP-1
10' IP-2 15'
IP-1 IP-3
MW-5
MP-1
MP-2

Response to Additional Information Request - Application for Permit to Construct and/or Use a Well(s) for Injection
Attachment B: Page 5 of UIC Permit Applications
Brown Caldwell
13

RECEIVED / DENR / Uv1IQ
Aquifer Protection Section
MAY 28 2011
Response to Additional Information Request - Application for Permit to Construct and/or Use a Well(s) for Injection
Attachment C: Schematic of Injection and Monitoring Points
:rswnAN ..wel

PROPOSED INJECTION POINT CONSTRUCTION
6 - INCH OUTSIDE DIAMETER BOREHOLE
APPROXIMATE GROUNDWATER DEPTH - 4 FEET
BGS
I -INCH DIAMETER PVC CASING
METHOD DRILLED BY HOLLOW -STEM AUGER
BOTTOM OF WELL AT APPROXIMATELY 15 FEET
BELOW GROUND SURFACE
STICKUP WELL VAULT
SURFACE GRADE
SURFACE TO 3 FEET
DOS CEMENT-
BENTONITE GROUT
34 FEET BGS
BENTONITE SEAL
4-15 FEET BGS SAND
FILTER PACK
I0
1-INCH PVC WITH 0,02-
INCH SLOT WELL
SCREEN
NOTE: NOT TO SCALE

PROPOSED MONrrORENG POINT CONSTRUCTION
6 - INCH OUTSIDE DIAMETER BOREHOLE
APPROXIMATE GROUNDWATER DEPTH - 4 FEET
BGS
I -INCH DIAMETER PVC CASING
METHOD DRILLED BY HOLLOW -STEM AUGER
BO FOM OF WELL AT APPROXIMATELY 15 FEET
BELOW GROUND SURFACE
STICKUP WELL VAULT
SURFACE GRADE
ISURFACE TO 3 FEET
BGS CEMENT-
BENTONITE GROUT
3-4 FEET BGS
BENTONITE SEAL
5 feet
4.15 FEET BGS SAND
FILTER PACK
10 feet
I -INCH PVC WITH 0.02-
LNCH SLOT WELL
SCREEN
NOTE: NOT TO SCALE

RECEIVED / DENR / DWQ
Aquifer Protection Section
r1AY 26 2011
Response to Additional Information Request - Application for Permit to Construct and/or Use a Well(s) for Injection
Attachment D: MSDS for 3DMeTM
r•wnANDCa •well

A711
NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Coleen H. Sullins Dee Freeman
Governor Director Secretary
May 20, 2011
Matt Einsmann. Project Manager
Brown and Caldwell
5410 Trinity Rd., Suite 320
Ralei<gh, NC 27607
Re: Additional Information Request
Injection Well Permit Application WI0600074
Robeson County - Robeson County Landfill
St. Pauls, Robeson County, North Carolina
Dear Mr. Einsmann:
While reviewing the above referenced 5I groundwater remediation permit application our staff identified some
items that need clarification and/or additional information. Please address the following items:
• There is some confusion on the correct number of proposed injection well(s), construction, and location.
On page 5 of the application and there are 3 boring/wells noted, but a series of temporary injection
points are indicated on Figure 5. Additionally, on the Attachment H page it indicates 'a map of the
injection and monitoring point locations is included in Attachment H'. However, no map/figure was
included. Please provide an updated map/figure showing the number and location of proposed injection
wells and monitoring points.
• On page 5, the injection well(s) have casing from 0 to 15 feet and screen from 5 to 15 feet. Please
provide a schematic of the construction of the proposed injection wells IP-1 through IP-3 (if this is the
correct designation), a revised page 5 showing the correct well construction, and the site map showing
the proposed locations. Also, provide the construction of the proposed monitoring points MP-1 through
MP-3 and locations.
• Please provide MSDS sheets for the 3-DME. This is required per section V.0 in the application.
Please note: We are receiving incomplete 5I groundwater remediation permit applications from Brown and
Caldwell where the bulk of the attachments are copies of previous assessment reports and/or corrective action
plans. These previously submitted reports to various agencies do not necessarily reflect the current proposed
injection and monitoring plans when inserted into the application. Please refer to the additional information
request letter dated May 4 we sent to Reinhard Ruhmke for the USI Realty Corp. project.
AQUIFER PROTECTION SECTION
1636 Mail Service Center, Raleigh, North Carolina 27699-1636
Location: 2728 Capital Boulevard. Raleigh, North Carolina 27604
Phone: [phone] \ FAX 1: 919-715-0588; FAX 2: 919-715-6048 \ Customer Service: 1-877-623-6748
Internet: www.ncwaterquality.orq
An Equal Opportunity 1 Affirmative Action Employer
One
NorthCarolina
Naturally

Please submit 2 copies of your responses with any corrected text pages/figures (same scale and page size) for
insertion and/or replacement into the previously submitted UIC Application within 30 calendar days of receipt
of this letter. Send one copy to my attention at the Central Office and the other copy to the attention of Jim
Barber at the Fayetteville Regional Office.
If you have any questions regarding your permit application please call me at [phone] or email me at
Michael.Rogers cr,ncdenr.gov.
Thank you for your cooperation.
Best Regards,
Michael Rogers, P.G. (NC & FL)
Environmental Specialist
cc: Steve Edge, Robeson County Solid Waste Management Facility, 246 Landfill Rd., St. Pauls, NC 28384
Art Barnhardt, Fayetteville Regional Office
Elizabeth Werner, Division of Waste Management -Oberlin Office
Central Office File, W10600074