Loading...
HomeMy WebLinkAboutWI0600077_Correspondence_20121116\w1O‘bbo77 Goodrich, David From: Mike Armour [marmour@shieldengineering.com] Sent: Friday, November 16, 2012 2:11 PM To: Goodrich, David Cc: Kyle Hoover; Barber, Jim Subject: RE: Kelton Residence- Notification of Intent to Construct or Operate Injection Wells Yes, I am withdrawing the October 3, 2012 application for modifying the permit. Thank you for your assistance. Michael D. Armour. Principal Geologist Shield Engineering, Inc. phone: 704.394.6913 fax: 704.394.6968 direct: 704.971.4143 www.shieldenqineering.com From: Goodrich, David [mailto:david.cloodrich@alncdenr.aovj Sent: Friday, November 16, 2012 2:03 PM To: Mike Armour Cc: Kyle Hoover; Barber, Jim Subject: RE: Kelton Residence- Notification of Intent to Construct or Operate Injection Wells • Mike, Thank you for your recent message and Notification submittal. Please confirm that you are withdrawing the October 3, 2012 application for modifying the permit. We will use the information contained in the original permit application, as well as the information in the application to modify, to meet the data submission requirements of the Notification form. Regards, David Goodrich Office Telphone Number: (919) 807-6352 Aquifer Protection Section Main Number: (919) 807-6464 Fax Number: (919) 807-6496 From: Mike Armour fmailto:marmour©shieldenaineerina.comj Sent: Friday, November 16, 2012 11:38 AM To: Goodrich, David Cc: Kyle Hoover Subject: Kelton Residence- Notification of Intent to Construct or Operate Injection Wells David, 1 Goodrich, David From: Goodrich, David Sent: Friday, October 19, 2012 1:40 PM To: Barber, Jim Cc: Barnhardt, Art Subject: RE: WI0600077 Kris Kelton injection site Jim, Thank you for your comments on the proposed modifications for this injection permit. I recently sent the following email to the Permittee's consultant, which explains the situation that we now have which allows the Permittee to have his permit modified, or closed out. I will share his answer as soon as I receive it. Regards, David Mr. Armour, The Aquifer Protection Section is in receipt of the application dated October 3, 2012 to modify existing Injection Permit W10600077, which was issued to Kris Kelton on August 15, 2011. New injection rules were enacted in May of 2012 which allow the treatment of contaminant plumes of less than 10,000 square feet in area (Rule 15A NCAC 02C .0225(b)(2)) by submitting a completed Notification of Intent to Construct or Operate Injection Wells instead of obtaining a permit. Your client is therefore able to modify the existing permit (as recently requested by your letter and application package), or, alternatively, close out the existing permit and submit a completed Notification of Intent. If the permit were closed out, the obligations stated in the permit (including the post - injection reporting obligations, well abandonments, and final report submission) would still have to be observed. Please consider whether it would be advantages %9 [ ? % vKora, ose it out. Feel free to contact me at (919) 807-6352 if you have any questions. Regards, David Goodrich Office Telphone Number: (919) 807-6352 Aquifer Protection Section Main Number: (919) 807-6464 Fax Number: (919) 807-6496 Office Telphone Number: (919) 807-6352 Aquifer Protection Section Main Number: (919) 807-6464 Fax Number: (919) 807-6496 From: Barber, Jim Sent: Friday, October 19, 2012 1:26 PM To: Goodrich, David 1 Cc: Barnhardt, Art Subject: WI0600077 Kris Kelton injection site David; I received the acknowledgement letter this morning for the above project. I have reviewed the document (partial copy attached) submitted to Ken Currie with DWM — UST and don't have any comments. Unless you need me to visit the site again based on your technical review of the document, I don't plan to visit the site again. If the document is acceptable to you, please make the appropriate changes to the existing permit and reissue. Thanks Jim Barber 2 Goodrich, David To: Subject: Mr. Armour, marmour@shieldengineering.com Modification of Injection Permit WI0600077 The Aquifer Protection Section is in receipt of the application dated October 3, 2012 to modify existing Injection Permit WI0600077, which was issued to Kris Kelton on August 15, 2011. New injection rules were enacted in May of 2012 which allow the treatment of contaminant plumes of less than 10,000 square feet in area (Rule 15A NCAC 02C .0225(b)(2)) by submitting a completed Notification of Intent to Construct or Operate Injection Wells instead of obtaining a permit. Your client is therefore able to modify the existing permit (as recently requested by your letter and application package), or, alternatively, close out the existing permit and submit a completed Notification of Intent. If the permit were closed out, the obligations stated in the permit (including the post - injection reporting obligations, well abandonments, and final report submission) would still have to be observed. Please consider whether it would be advantageous to modify the permit, or to close it out. Feel free to contact me at (919) 807-6352 if you have any questions. Regards, David Goodrich Office Telphone Number: (919) 807-6352 Aquifer Protection Section Main Number: (919) 807-6464 Fax Number: (919) 807-6496 1 L Permit Number WI0600077 Central Files: APS_ SWP_ ' 10/17/12 Permit Tracking Slip Program Category Ground Water Permit Type Injection In situ Groundwater Remediation Well Primary Reviewer david.goodrich Coastal SW Rule Permitted Flow Facility Facility Name Kris Kelton SFR Location Address 4994 Phillipi Church Rd Raeford Owner NC 28376 Status Project Type In review Major modification Version Permit Classification Individual Permit Contact Affiliation Steven Lucas 4301 Taggart Creek Rd , Charlotte NC 28208 Major/Minor Minor Region Fayetteville County Hoke Facility Contact Affiliation Owner Name Kris Dates/Events Kelton Owner Type Individual Owner Affiliation Kris Kelton 4994 Phillipi Church Rd Raeford NC 28376 Orig Issue 08/15/11 App Received 10/08/12 Regulated Activities Groundwater monitoring Groundwater remediation Duffel! NULL Draft initiated Scheduled Issuance Public Notice Issue Effective Requested/Received Events RO staff report received RO staff report requested Expiration Waterbody Name Stream Index Number Current Class Subbasin NCDENR North Carolina Department of Environment and Natural Resources Division of Water Quality Beverly Eaves Perdue Charles Wakild, P.E. Dee Freeman Governor Director Secretary October 17, 2012 Kris Kelton 4994 Phillipi Church Road Raeford, NC 28376 Dear Mr. Kelton: Subject: Acknowledgement of Application No. WI0600077 Kris Kelton SFR Injection In situ Groundwater Remediation Well System Hoke County The Aquifer Protection Section acknowledges receipt of your permit application and supporting documentation received on October 8, 2012. Your application package has been assigned the number listed above, and the primary reviewer is David Goodrich. Central and Fayetteville Regional Office staff will perform a detailed review of the provided application, and may contact you with a request for additional information. To ensure maximum efficiency in processing permit applications, the Aquifer Protection Section requests your assistance in providing a timely and complete response to any additional information requests. Please note that processing standard review permit applications may take as long as 60 to 90 days after receipt of a complete application. If you have any questions, please contact David Goodrich at (919) 807-6352 or david.goodrich@ncdenr.gov. Sincerely, fl for Debra J. Wa Groundwater Protection Unit Supervisor cc: Fayetteville Regional Office, Aquifer Protection Section Michael D. Armour — Shield Engineering, Inc. Permit File WI0600077 AQUIFER PROTECTION SECTION 1636 Mail Service Center, Raleigh, North Carolina 27699-1636 Location: 512 N. Salisbury St, Raleigh, North Carolina 27604 Phone: 919.807-64641 FAX: 919-807-6496 Internet: www.ncwatereuartv.org An Equal Opportunity 1 Affirmative Action Employer Noe thttCarolina ra`u all SHIELD ENGINEERING, INC. October 3, 2012 Mr. Thomas Slusser UIC Program Manager Aquifer Protection Section, Division of Water Quality North Carolina Department of Environment and Natural Resources 1636 Mail Service Center Raleigh, North Carolina 27699-1636 RECEIVEDIDENRIDWQ OCT 082012 Aquifer Protection Section Re: Application for Underground Injection Control Permit Modification UIC Permit #WI0600077 Kris Kelton Residence Incident Number 90010 4994 Philippi Church Road Raeford, North Carolina 28376 Dear Mr. Slusser: Shield Engineering, Inc. (Shield), on behalf of Browns Cable, submits the attached application to modify the existing Underground Injection Control (UIC) permit (permit #WI0600077). This application is fundamentally for allowing two changes to the existing permit as prelude to conducting a planned second injection event at the site. The first change is for the use of direct -push injection points. The second change is for the additional use of calcium peroxide as a high base activator. The first injection event was very successful in removing the free phase product and a portion of the dissolved phase petroleum constituents in the ground water. However, during the first injection event day lighting of the permitted injection chemicals occurred in a number of injection wells, including in the primary source area around monitoring well MW-l. To better address removal of the residual dissolved phase contaminants and to preclude day lighting during injection in a planned second injection event, the injection contractor (ExoTech, Inc.) recommended focused injection around monitoring wells MW-1 and MW-3 (the monitoring wells containing residual amounts of dissolved phase petroleum constituents) via four direct -push technology (e.g. Geoprobe) advanced injection boring points around each monitoring well for a total of eight direct -push injection points. The injection would be conducted within an interval from about 3 to 4 feet above and below the depth to groundwater that would be determined at the beginning of the injection activities. Maximum injection point depth is anticipated at approximately 16 feet below ground surface. ExoTech, Inc. further recommended the use of calcium peroxide as the high base activator in the area of monitoring well MW-3 versus the currently permitted sodium hydroxide as this chemical will also slowly release oxygen over the course of approximately 6 months providing enhancement of biodegradation of the dissolved phase contaminants of concern. The amounts of chemical to be injected per injection point is presented in the attached permit application for modification. This application includes supporting materials consisting of: letter of authorization; communications from the injection contractor presenting the recommended changes; MSDS sheets for the existing permitted and proposed injection chemicals; Figures consisting of a Site Location Map, a Site Map noting well locations and identifications; Proposed Direct -Push Injection Locations including cross-section layout; Cross Section presenting subsurface information, existing monitoring and injection wells and proposed direct -push injection points; and most recent ground water elevation contour map as well as pre -injection and post -injection contaminant of concern concentration maps previously submitted to your office in the Shield September 12, 2012 Monitoring Report and Oxidation Injection Summary Report. 4301 Taggart Creek Road Charlotte, NC 28208 www.shieldengineering.com Fax 704.394.6968 Telephone 704.394.6913 Application for UIC Permit Modification UIC Permit #WI0600077 Kelton Residence Raeford, NC October 3, 2012 Page 2 Please contact the undersigned at (704) 394-6913 if you have any questions, or need any further information in order to process and approve this modification application. We appreciate your timely assistance on this project. Sincerely SHIELD ENGINEERING, INC. A. Kyle\3oover, L.G., E.I. Project Manager NC License #2198 Michael D. Armour, M.S., L.G. Principal NC License #1209 `%o w at /!/t_ •• NDATN C,,'i a; • ;: %!• o • o .•.GtS •. o� cc Ms. Rosa Ferrari, Nationwide Insurance Mr. Russell Brown, Browns Cable Mr. Kris Kelton Mr. Ken Currie, NCDENR-FRO RECEIVE mQ OCT t 112 Aquifer Protetft Section h:\action (0140)\projects\2007\nationwide\browns cable-kelton property - raeford, nc\uic permit documents\uic permit modification\cover letter- uic permit modification application.doc *SHIELD a North Carolina Department of Environment and Natural Resources APPLICATION FOR PERMIT TO CONSTRUCT AND/OR USE A WELL(S) FOR INJECTION In Situ Groundwater Remediation I Tracer Injection Do not use this form for the following: • in situ remediation, tracer, or aquifer test injection wells permitted by rule (ref. 15A NCAC 02C .0217) • remediation systems that reinject treated contaminated groundwater (ref. 15A NCAC 02T .1600ECEl1f!A EQIQENfVIDWQ OLr08ZU2 Aquifer Protection Section 1. Project is: [ ] New [X ] Modification [ ] Renewal without modification [ ] Renewal with modification 2. If this application is being submitted for renewal or modification to an existing permit, provide: existing permit number WI0600077 and the issuance date 8-15-11 For renewal without modifications, fill out sections I & II only, sign the certification on the last page of this form. and obtain the property owner's signature to indicate consent (if the applicant is not the owner). For all renewals, submit a status report including monitoring results of all injection activities to date. Application Number (to be completed by DWQ): I. APPLICATION INFORMATION II. WELL OWNER (generally the responsible party) 1. Name: Kris Kelton 2. Signing Official's Name*: Michael D. Armour Title: Principal -Shield Engineering, Inc. * Signing Official must be in accordance with instructions in part VI on page 7. 3. Mailing address of applicant: 4994 Phillipi Church Road City: Raeford State: NC Zip: 28376 4. Telephone number: 910-849-8874 Email: 5. Status (choose one): X Individual Business/Org. Federal State County Municipality III. PROPERTY OWNER (if different than well owner) 1. Name: 2. Physical address: City: State: Zip: 3. Mailing address: City: State: Zip: 4. Telephone number: Email: IIII. PROJECT CONTACT — Person who can answer technical questions about the proposed injection project. 1. Name: Michael D. Armour Title: Principal 2. Company: Shield Engineering. Inc. 3. Address: 4301 Taggart Creek Road 4. City: Charlotte State: NC Zip: 28208 5. Telephone number: 704-394-6913 Email: marmour@shieldengineering.com Revised 5/1/2012 UIC-5U5T Page 1 of 5 APPLICATION FOR PERMIT TO CONSTRUCT AND/OR USE h vVELL(S) FOR INJECTION In Situ Groundwater Remediation I Tracer Injection V. FACILITY INFORMATION 1. Facility name: Residence of Kris Kelton Ph#: 910-849-8874 2. Mailing address: 4994 Phillipi Church Road City: Raeford County: Hoke State: NC Zip: 28376 3. Geographic Coordinates: Latitude: 34°58' 13.05"N Longitude: 79°05'53.36"W Reference Datum: Google Earth Accuracy: Method of Collection: 4. Brief description of business: Residence VI. INCIDENT DESCRIPTION 1. Source and date of contamination: Heating Oil Release from an Aboveground Storage Tank Release occurred December 2006 2. List all contaminants present in soils or groundwater at the site (contaminants may be listed in groups, e.g., gasoline, diesel, jet fuel, fuel oil, chlorinated ethenes, chlorinated ethanes, metals, pesticides/herbicides, etc): Heating Oil 3. Has LNAPL or DNAPL ever been observed at the site (even if outside the injection zone)? [X] Yeslf yes, list maximum measured separate phase thickness: 1.02 feet [ ] No If no, list maximum concentration of total VOCs observed at site: ppb 4. Agency managing the contamination incident: [X] UST Section [ ] Superfund Section (including REC Program and DSCA sites) [ ] DWQ Aquifer Protection Section [ ] Solid Waste Section [ ] Hazardous Waste Section [ ] Other: 5. Incident manager's name: Ken Currie Ph#: 910-433-3300 6. Incident number or other incident mgmt. agency tracking number: 90010 VII. PERMITS List all applicable permits or construction approvals issued for the facility or incident: 1. Hazardous Waste Management program permits under RCRA: 2. DWQ Non -Discharge or NPDES permits: 3. County or DEH subsurface wastewater disposal permits: 4. Other environmental permits required by state or federal law: Injection Permit WI0600077 Revised 5/1/2012 UIC-5I/5T Page 2 of 5 APPLICATION FOR PERMIT TO CONSTRUCT AND/OR USE A WELL(S) FOR INJECTION In Situ Groundwater Remediation I Tracer Injection VIII. ATTACHMENTS — provide the following information in separate attachments. The attachments should be clearly identified and presented in the order below to expedite review of the permit application package. I. INJECTION ZONE — Specify the horizontal and vertical portion of the subsurface within which the proposed injection activity will take place and beyond which no violations of groundwater quality standards shall result from the injection as determined by an approved monitoring plan. The determination shall be based on the hydraulic properties of the specified zone. Provide any supporting documentation in a separate attachment. 2. HYDROGEOLOGIC EVALUATION — Provide a hydrogeologic evaluation of the injection zone that includes all of the following: (A) Regional and local geology and hydrology; (B) Changes in lithology underlying the facility; (C) Depth to bedrock; (D) Depth to the mean seasonal high water table; (E) Hydraulic conductivity, transmissivity, and storativity, of the injection zone based on tests of site -specific material, including a description of the test(s) used to determine these parameters; (F) Rate and direction of groundwater flow as determined by predictive calculations or computer modeling; and (G) Lithostratigraphic and hydrostratigraphic logs of any existing test and injection wells. 3. INJECTANT INFORMATION — List each injectant in the space below and provide the following information for each injectant. NOTE: Approved injectants can be found online at http://portal.ncdenr.orRhveb/wq/aps/gwpro. All other substances must be reviewed by the Division of Public Health, Department of Health and Human Services. Contact the UIC Program for more information (Ph# 919-807-6496). 110 pounds Sodium Persulfate activated with 20 gallons of Sodium Hydroxide (already permitted) in each of 4 direct - push injection points in the vicinity of monitoring well MW-1; 55 pounds Sodium Persulfate activated with 165 pounds calcium peroxide in each of 4 direct -push injection points in the vicinity of monitoring well MW-3.Injection interval will be approximately 3 to 4 feet above and below the top of groundwater that is determined at the beginning of injection activities requiring injection points with depths up to 16 feet below grade. Use of direct -push injection points and calcium peroxide are the reasons for the permit modification. (A) MSDS, concentration at the point of injection, and percentage if present in a mixture with other injectants; (B) The source of fluids used to dilute, carry, or otherwise distribute the injectant throughout the injection zone. If any well within the area of review of the injection facility is to be used as the fluid source, then the following information shall be submitted: location/ID number, depth of source, formation, rock/sediment type, and a chemical analysis of the water from the source well, including analyses for all contaminants suspected or historically recognized in soil or groundwater on the site; (C) A description of the rationale for selecting the injectants and concentrations proposed for injection, including an explanation or calculations of how the proposed injectant volumes and concentrations were determined; (D) A description of the reactions between the injectants and the contaminants present including specific breakdown products or intermediate compounds that may be formed by the injection; (E) A summary of results if modeling or testing was performed to investigate the injectant's potential or susceptibility for biological, chemical, or physical change in the subsurface; and (F) An evaluation concerning the development of byproducts of the injection process, including increases in the concentrations of naturally occurring substances. Such an evaluation shall include the identification of the specific byproducts of the injection process, projected concentrations of byproducts, and areas of migration as determined through modeling or other predictive calculations. 4. INJECTION PROCEDURE — Submit a table with a detailed description of the proposed injection procedure that includes the following: (A) The proposed average and maximum daily rate and quantity of injectant; (B) The average maximum injection pressure expressed in units of pounds per square inch (psi); and (C) The total or estimated total volume to be injected. Revised 5/1/2012 UIC-51/5T Page 3 of 5 APPLICATION FOR PERMIT TO CONSTRUCT AND/OR USE A WELL(S) FOR INJECTION In Situ Groundwater Remediation I Tracer Injection 5. FRACTURING PLAN (if applicable) — Submit a detailed description of the fracturing plan that includes the following: (A) Material Safety Data Sheets of fracturing media including information on any proppants used; (B) a map of fracturing well locations relative to the known extent of groundwater contamination plus all buildings, wells, septic systems, underground storage tanks, and underground utilities located within the Area of Review; (C) a demonstration that buildings, wells, septic systems, underground storage tanks, and underground utilities will not be adversely affected by the fracturing process; (D) injection rate and volume; (E) .orientation of bedding planes, joints, and fracture sets of the fracture zone; (F) performance monitoring plan for determining the fracture well radius of influence; and (G) if conducted, the results of geophysical testing or pilot test of fracture behavior conducted in an uncontaminated area of the site. 6 WELL CONSTRUCTION DETAILS — Submit the following information in tabular or schematic form as appropriate for each item: (A) number and depth of injection wells; (B) number and depth of borings if using multi -level or "nested" well systems; (C) indication whether the injection wells are existing or proposed; (D) depth and type of casing; (E) depth and type of screen material; (F) depth and type of grout; (G) indication whether the injection wells are permanent or temporary "direct push" points; and (H) plans and specifications of the surface and subsurface construction details. 7. MONITORING PLAN — Submit a monitoring plan that includes the following: (A) target contaminants plus secondary or intermediate contaminants that may result from the injection; (B) other parameters that may serve to indicate the progress of the intended reactions; (C) a list of existing and proposed monitoring wells to be used; and (D) a sampling schedule to monitor the proposed injection. Monitoring wells shall be of sufficient quantity and location to detect any movement of injection fluids, injection process byproducts, or formation fluids outside the injection zone. The monitoring schedule shall be consistent with the proposed injection schedule, pace of the anticipated reactions, and rate of transport of the injectants and contaminants. 8. WELL DATA TABULATION — Provide a tabulation of data on all existing or abandoned wells within the area of review of the injection well(s) that penetrate the proposed injection zone, including monitoring wells and wells proposed for use as injection wells. Such data shall include a description of each well's type, depth, and record of construction or abandonment. 9. MAPS AND CROSS -SECTIONS — Provide scaled, site -specific site plans or maps depicting the location, orientation, and relationship of facility components including the following: (A) area map based on the most recent USGS 7.5' topographic map of the area, at a scale of 1:24,000 and showing the location of the proposed injection site; (B) topographic contour intervals showing all facility related structures, property boundaries, streams, springs, lakes, ponds, and other surface drainage features; (C) all existing or abandoned wells within the area of review of the wells listed in the well data tabulation that penetrate the proposed injection zone; (D) potentiometric surface map(s) that show the direction of groundwater movement, existing and proposed wells; (E) contaminant plume map(s) with isoconcentration lines that show the horizontal extent of the contaminant plume in soil and groundwater, and existing and proposed wells; (F) cross-section(s) to the known or projected depth of contamination that show the horizontal and vertical extent of the contaminant plume in soil and groundwater, major changes in lithology, and existing and proposed wells; and (G) any existing sources of potential or known groundwater contamination, including waste storage, treatment, or disposal systems within the area of review of the injection well or well system. Revised 5/1/2012 UIC-51/5T Page 4 of 5 APPLICATION FOR PERMIT TO CONSTRUCT AND/OR USE A WELL(S) FOR INJECTION in Situ Groundwater Remediation I Tracer Injection IX. CERTIFICATION* (to be signed as required below or by that person's authorized agent*) NCAC 15A 02C .0211(e) requires that all permit applications shall be signed as follows: 1. for a corporation: by a responsible corporate officer 2. for a partnership or sole proprietorship: by a general partner or the proprietor, respectively 3. for a municipality or a state, federal, or other public agency: by either a principal executive officer or ranking publicly elected official 4. for all others: by the well owner. *If an authorized agent is signing on behalf of the applicant, then supply a letter signed by the applicant that names and authorizes their agent. "I hereby certify under penalty of law that I have personally examined and am familiar with the information submitted in this document and all attachments therein, and that, based on my inquiry of those individuals immediately responsible for obtaining said information, I believe that the information is true, accurate, and complete. 1 am aware that there are penalties, including the possibility of fines and imprisonment, for submitting false information. 1 agree to construct, operate, maintain, repair, and if applicable, abandon the injection well(s) and all related appurtenances in accordance with the approved specifications and conditions of the Pernik" Printed Name and Title: ichael DICrm9'ur, Principal, Shield Engineering, Inc. 3 Signature: - Date: /1) - - /c,\ X. CONSENT OF PROPERTY OWNER (if the property is not owned by the permit applicant) "Owner" means any person who holds the fee or other property rights in the well being constructed. A well is real property and its construction on land shall be deemed to vest ownership in the land owner, in the absence of contrary agreement in writing. "As owner of the property on which the injection well(s) are to be constructed and operated, I hereby consent to allow the applicant to construct each injection well as outlined in this application and agree that it shall be the responsibility of the applicant to ensure that the injection well(s) conform to the Well Construction Standards (Title 1 SA NCAC 02C .0200)." Printed Name and Title: See Attached Letter of Authorization Signature: Date: Submit TWO copies of the completed application package, including all attachments, to: DWQ - Aquifer Protection Section 1636 Mail Service Center Raleigh, NC 27699-1636 Telephone (919) 807-6464 RECEIVED/DENRIDWQ OCT 0 8 2012 Aquifer Protection Section Revised 5/1/2012 UIC-5I/5T Page 5 of 5 A.741. NCDENR North Carolina Department of Environment and Natural Resources Division of Water Quality Beverly Eaves Perdue Charles Wakild, P.E. Dee Freeman Governor Director Secretary November 20, 2012 Mr. Kris Kelton — Owner 4994 Phillipi Church Road Raeford, North Carolina 28376 Dear Mr. Kelton: Subject: Return of Application to Modify Permit Number WI0600077 Kris Kelton SFR Injection In -situ Groundwater Remediation Well System Hoke County Pursuant to my conversations and email correspondence with Michael D. Armour of Shield Engineering, Inc., we are herewith returning the submitted application to modify existing Injection permit WQ0600077, received by the Aquifer Protection Section on October 8, 2012. Our new injection well regulations (15A NCAC 02C .0225(b) (2)) allow for remedial injections to take place on a contaminant plume of less than 10,000 square feet in area without the acquisition of a permit or permit modification. Mr. Armour has submitted a Notification of Intent to Construct or Operate Injection Wells form, which describes the intended injection activities that will be taking place. Please note that the obligations contained in the existing Permit WI0600077, issued on August 15, 2011, are still in effect and that the additional injection activities do not impact or diminish the regulatory obligations contained within that permit. If you have any questions regarding these actions, please contact me at (919) 807-6352, or Division staff at (919) 807-6464. Sincerely, )764‘,4 David Goodrich Aquifer Protection Section cc: Michael D. Armour, Shield Engineering, Inc., 4301 Taggart Creek Rd., Charlotte, NC 28208 Fayetteville Regional Office, Aquifer Protection Section Permit File WI0600077 AQUIFER PROTECTION SECTION 1636 Mail Service Center, Raleigh, North Carolina 27699-1636 Location: 512 N. Salisbury St., Raleigh, North Carolina 27604 Phone: 919.807-64641 FAX: 919-807-6496 Internet: www.ncwaterauality.orq An Equal Opportunity 1 Affirmative Action Employer North Carolina ,Naturally NC ENR North Carolina Department of Environment and Natural Resources Division of Water Quality Beverly Eaves Perdue Coleen H. Sullins Dee Freeman Governor Director Secretary • August 15, 2011 Mr. Steven B. Lucas, Principal Shield Engineering, Inc. 4301 Taggart Creek Road Charlotte, North Carolina 28208 Ref: Issuance of Injection Permit WI0600077 Kris Kelton Residence Raeford, Hoke County, North Carolina. Dear Mr. Lucas: In accordance with the application received on June 9, 2011, and the supporting data received add info received dates if applicable, we are forwarding permit number WI0600077. This permit is to inject PetroSolv, Klozur, and Sodium Hydroxide to remediate groundwater contaminated with heating oil at the facility referenced above. This permit shall be effective from the date of issuance until July 31, 2014, and shall be subject to the conditions and limitations stated therein, including the requirement to submit a final project evaluation 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. You will need to notify this 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) 715-6162 or david.goodrich@ncdenr.gov if you have any questions about your permit. Best Regards, David Goodrich, Hydrogeologist cc: Art Barnhardt, Fayetteville Regional Office Ken Currie, NCDWM UST Section, 1646 Mail Service Center, Raleigh, NC 27699-1646 WI0600077 Permit File AQUIFER PROTECTION SECTION 1636 Mail Service Center, Raleigh, North Carolina 27699-1636 Location: 2728 Capital Boulevard, Raleigh, North Carolina 27604 Phone: 919-733-3221 \ FAX 1: 919-715-0588; FAX 2: 919-715-60481 Customer Service: l-877-623-6748 Internet: www.ncwatemualitv.orq An Equal Opportunity t Affirmative Action Employer N/ttoi/r`�trh C�a:arrolin�a Hi" YC.tm al Avfx'i NCD North Carolina Department of Environment and Natural Resources Division of Water Quality Beverly Eaves Perdue Coleen H. Sullins Dee Freeman Govemor Director Secretary June 20, 2011 Kris Kelton — Owner 4994 Phillipi Church Road Raeford, NC 28348 Dear Ms. Kelton: Subject: Acknowledgement of Application No. WI0600077 Kris Kelton SFR Injection In situ Groundwater Remediation Well (5I) System Hoke County The Aquifer Protection Section acknowledges receipt of your permit application and supporting documentation received on 6/9/2011. Your application package has been assigned the number listed above, and the primary reviewer is David Goodrich. Central and Fayetteville Regional Office staff will perform a detailed review of the provided application, and may contact you with a request for additional information. To ensure maximum efficiency in processing permit applications, the Aquifer Protection Section requests your assistance in providing a timely and complete response to any additional information requests. Please note that processing standard review permit applications may take as long as 60 to 90 days after receipt of a complete application. If you have any questions, please contact David Goodrich at (919) 715-6162 or david.goodrich@ncdenr.gov. Sincerely, C`1 for Debra J. Watts Groundwater Protection Unit Supervisor cc: Fayetteville Regional Office, Aquifer Protection Section Steven B. Lucas — Shield Engineering 4301 Taggart Creek Road, Charlotte, NC 28208) Permit File WI0600077 AQUIFER PROTECTION SECTION 1636 Mai! Service Center. Raleigh. North Carolina 27699-1636 Location: 27 28 ;,aoital Boulevard. Raleigh. North Carolina 27604 Pnone 919-733 3221 FA./ 919-'715-058E: FAX 2: 919-715-6048 i Customer Service 1-877-623-6748 Interne: ww :.ncr ateroualitv.orc ... =_aui. :Joa,,:!wr .ATrmativ... One NorthCaroiina Naturally