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HomeMy WebLinkAboutWI0600080_Application_20110802REPLY TO ATTENTION OF RECEIVED / DENR I DWQ DEPARTMENT OF THE ARMY AQUIFER PROTFf TI(}N SECTION US ARMY INSTALLATION MANAGEMENT COMMAND AUG 11 2011. HEADQUARTERS,UNITED STATES ARMY GARRISON, FT BRAGG 2175 REILLY ROAD, STOP A FORT BRAGG, NORTH CAROLINA 28310-5000 August 2, 2011 Directorate of Public Works North Carolina Department of Environment and Natural Resources Underground Injection Control (UIC) Program Aquifer Protection Section, Division of Water Quality 1636 Mail Service Center Raleigh, North Carolina 27699-1636 Dear UIC Program Manager: Attached are two copies of a UIC-5I/5T underground injection well permit application form related to a proposed groundwater remediation system installation at Pope Army Airfield's Site ST008 on Fort Bragg. As instructed on the application, two copies of the form are being submitted, including two copies of all attachments and supporting information. Mr. James Brown in the Underground Storage Tank section of the Fayetteville Regional Office is Fort Bragg's NCDENR regulator related to the site. If you have any questions concerning this matter, please contact Mr. Steven Harris at (910) 396-7432 or Ms. Christie Lowery at (910) 907-3645. Sincer Gregor . Bean Director of Public Works Enclosure July 27, 2011 UIC Program Aquifer Protection Section North Carolina DENR-DWQ 1636 Mail Service Center Raleigh, NC 27699-1636 RECEIVED / D€NR / DWO At U1Rr=R DROTFr.Tlt1N SECTION AUG 11 2011. RE: Underground Injection Control (UIC) Permit Application Pope Army Air Field Site ST008 Pope AAF, Fayetteville, North Carolina UIC Program Manager: Please find the enclosed two full copies of the completed UIC permit application for injection of BOS 200® to treat petroleum impacts within the subsurface of the above referenced property. One of the two copies includes the original signature of the applicant (Steven Harris, Ft. Bragg PWC for Pope Army Air Field [Pope AAF)). The application was completed by URS Group, Inc. — North Carolina on behalf of Pope AAF. The Project Geologist's signature and seal below is included to confirm that the geologic plans, reports, and documents included in this report were completed by or under the direction of a licensed geologist. If you have any questions regarding this submittal please do not hesitate to contact Jon Kucera at (919) 461-1349. Sincerely, URS Group, Inc, Jon Kucer , PE Project Manager Enclosures cc: Christie Lowery, Fort Bragg (hard copy / 2 electronic) Lucas Walsh, USACE Omaha District (electronic) Steven Harris, Fort Bragg PWC (hard copy / electronic) 0INp ;p 00 CA11144\ 4.4 4$ i ii . 4'i . 4tr s Mike Ranck, PG i O 7-20)0,44 u , 47 Project Geologist y0 % GF01,pG 's+ ' P URS Group, Inc. 1600 Perimeter Park Drive, Suite 400 Morrisville, NC 27560 Tel: 919.461.1100 Fax: 919.461.1415 RECEIVED / DENR / DWQ State of North Carolina AQUIFER PR�1TF[ TI N SECTION Department of Environment and Natural Resources AUG 11 2011. Division of Water Quality APPLICATION FOR PERMIT TO CONSTRUCT AND/OR USE A WELL(S) FOR INJECTION Type 5I Wells — In Situ Groundwater Remediation / Type 5T Wells — Tracer Injection • Do not use this form for remediation systems that extract contaminated groundwater, treat it, and reinject the treated groundwater. • Submit TWO copies of the completed application and all attachments to the address on the last page of this form. • Any changes made to this form will result in the application package being returned. Application Number (to be completed by DWQ): 1/4-0O(000 o$O I. GENERAL INFORMATION: 1. Applicant's Name (generally the responsible party): Pope Army Airfield 2. Signing Official's Name*: Steven Harris for Gregory Bean Title: Ft. Bragg PWC * Signing Official must be in accordance with instructions in part VI on page 7. 3. Mailing address of applicant: DPW Bldg 3-1137, Ft. Bragg City: Fayetteville State: NC Zip: 28310 Telephone number: (910) 907-3645 Fax number: (910) 396-4188 4. Property Owner's Name (if different from Applicant): Gregory G. Bean, Director of Public Works 5. Property Owner's mailing address: DPW Bldg 3-1631 Butner Road, Ft. Bragg City: Fayetteville State: NC Zip: 28310 6. Name and address of contact person who can answer questions about the proposed injection project: Name: Jon Kucera Title: Project Manager Company: URS Corporation — North Carolina Address: 1600 Perimeter Park Drive City: Morrisville State: NC Zip: 27560 Telephone number: (919) 461-1349 610 0— MBA-1,J Fax Fax number: (919) 461-1415 Email Address: Jon Kucera(iiURScorp.com II. PERMIT INFORMATION: 1. Project is: (X) New ( Modification of existing permit ( Renewal of existing permit without modification ( Renewal of existing permit with modification 2. If this application is being submitted for renewal or modification to an existing permit, provide: existing permit number and the issuance date 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. Revised 6/09 UIC-5I/5T Page 1 of 7 APPLICATION FOR PERMIT TO CONSTRUCT AND/OR USE A WELL(S) FOR INJECTION Type 5I Wells — In Situ Groundwater Remediation / Type 5T Wells — Tracer Injection III. INCIDENT & FACILITY DATA A. FACILITY INFORMATION 1. Facility name: Pope Army Air Field 2. Complete physical address of the facility: Pope AAF Site ST008, Intersection of Reilly Road and Interceptor Road, Ft. Bragg'°v City: Fayetteville County: Cumberland State: NC Zip: 28310 B. INCIDENT DESCRIPTION I. Describe the source of the contamination: The Site was formerly used for storage and distribution of No. 2 Fuel Oil for Pope AFB. Fuel oil was delivered via tanker trucks and rail cars to four (4) 25,000- gallon underground storage tanks (UST) for storage. Ancillary piping and dispensers distributed the product. The fueling facility was in operation from 1954 until 1985. During the 1990 Base -wide UST Evaluation Program, one UST at the Site failed a precision pressure test. In November 1992, the four (4) USTs, ancillary piping, and dispensers were excavated and removed. The excavation was approximately fifteen (15) feet deep and free product was observed on top of accumulated water in the excavation. Reportedly, the excavation was lined with plastic sheeting and backfilled with the impacted soils encountered during the UST removals. 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): No. 2 Fuel Oil 3. Has LNAPL or DNAPL ever been observed at the site (even if outside the injection zone)? (X) Yes If yes, list maximum measured separate phase thickness 4.35 feet (No If no, list maximum concentration of total VOCs observed at site: ppb 4. Agency managing the contamination incident: ( UST Section (X) Superfund Section (including REC Program and DSCA sites) ( DWQ Aquifer Protection Section ( Solid Waste Section ( Hazardous Waste Section ( Other: 5. Incident managers name Art Shacter / Martha Morgan and phone number (919) 508-8477 6. Incident number or other site number assigned by the agency managing the contamination incident: C. PERMITS List all permits or construction approvals that have been issued for the facility or incident, including those not directly related to the proposed injection operation: 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: Revised 6/09 UIC-5I/5T Page 2 of 7 APPLICATION FOR PERMIT TO CONSTRUCT AND/OR USE A WELL(S) FOR INJECTION Type 5I Wells — In Situ Groundwater Remediation / Type 5T Wells — Tracer Injection IV. INJECTION DATA A. INJECTION FLUID DATA 1. List all proposed injectants. NOTE: Any substance to be injected as a tracer or to promote in situ remediation must be reviewed by the Occupational and Environmental Epidemiology Section (OEES) of the Division of Public Health, Department of Health and Human Services. Review the list of approved injectants or contact the UIC Program to determine if the injectants you are proposing have been reviewed by OEES. Injectant: BOS 200® Concentration at point of injection: 301bs BOS 200®/18.95ga1 water and bacteria concentrate @ MW8-19 Percent if in a mixture with other injectants: 16.05% BOS 200® + 0.44% bacteria concentrate + 83.51% water Injectant: BOS 200® Concentration at point of injection: 60Ibs BOS 200®/28.29 gal water and bacteria concentrate A MW-HF1 Percent if in a mixture with other injectants: 20.26% BOS 200®+ 0.45% bacteria concentrate + 79.28% water Injectant: Concentration at point of injection: Percent if in a mixture with other injectants: Injectant: Concentration at point of injection: Percent if in a mixture with other injectants: 2. Source of fluids used to dilute or chase the injectants listed above: ( None (X) Municipal water supply ( Groundwater from private well or any well within VI mile of injection site ( Air ( Other: 3. If any well within'/4 mile of injection site, a private well, or surface water is to be used as the fluid source, supply the following information: a. Location/ID number of source: b. Depth of source: c. Formation: d. Rock/Sediment type: e. In Attachment C, provide a current, complete 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. NOTE: If contaminated groundwater is to be used as the dilution or chase fluid, this is not the proper permit application form. You must apply for a closed -loop groundwater remediation permit using application form GWRS. Revised 6/09 ULC-51/5T Page 3 of 7 APPLICATION FOR PERMIT TO CONSTRUCT AND/OR USE A WELL(S) FOR INJECTION Type 5I Wells — In Situ Groundwater Remediation / Type 5T Wells — Tracer Injection B. PROPOSED OPERATING PARAMETERS 1. Duration of Injection: 2 days a. Maximum number of separate injection events: 1 b. Expected duration of each injection event: 2 days c. Expected duration between events (if more than one event): N/A 2. Injection rate per well: --35 gallons per minute (gpm) 3. Total Injection volume: gallons per day (gpd); —20 gallons per well 4. Injection pressure: 400-700 pounds/square inch (psi) 5. Temperature at point of injection: —65 °F (ambient air/soil temperature) 6. Briefly describe how the above parameters will be measured and controlled: Maximum pressure of each injection will be monitored and recorded from pressure gauge at discharge side of injection pump . Flow will be monitored and recorded by volume removed from calibrated tank during each injection. 7. Estimated hydraulic capacity of the well: 0.5 — 2 gpm C. INJECTION WELL CONSTRUCTION DATA 1. Injection will be via: ( ( Existing well(s) proposed for use as an injection well. Provide the data in (2) through (6) below to the best of your knowledge. Proposed well(s) to be constructed for use as an injection well. Provide the data in (2) through (6) below as proposed construction specifications. (X) Soil borings to be constructed for use as injection points. 2. Well Drilling Contractor's Name: AST Environmental, Inc. NC Well Contractor Certification number: NCWC 3395-A 3. Date to be constructed: August 30 and 31, 2011 Number of borings: 32 Approximate depth of each boring (feet): 16 ft bgs 4. Screened interval/Injection interval of injection wells: Depth: 11.5_ to _ 16.0 feet below ground surface (if multiple intervals, indicate shallowest and deepest depth). 5. Well casing (N/A if injection is through direct push rods): Type: ( PVC ( Stainless steel ( Other: Casing depth: to ft. 6. Grout (N/A if injection is through direct push rods): Type: ( Cement ( Bentonite Grout depth: to ft. ( Other: Revised 6/09 UIC-5I/5T Page 4 of 7 APPLICATION FOR PERMIT TO CONSTRUCT AND/OR USE A WELL(S) FOR INJECTION Type 5I Wells —L: Situ Groundwater Remediation / Type 5T Wells — Tracer Injection V. ATTACHMENTS Provide the following items as separate attachments with the given headings: A. SITE HISTORY Provide a brief description of the site history including: (1) site usage historically and present, (2) origin of the contamination, (3) previous remedial action(s). NOTE: G.S. 89E-18 requires that any geologic plans, reports, or documents in which the performance is related to the public welfare or safeguarding of the environment be prepared by a licensed geologist or subordinate under their direction. G.S. 89E-13 requires that all drawings, reports, or documents involving geologic work prepared or approved by a licensed geologist, or a subordinate under their direction, be signed and sealed by the licensed geologist. B. HYDROGEOLOGIC DESCRIPTION Provide a hydrogeologic description, soils description, and cross section of the subsurface to a depth that includes the known or projected depth of contamination. The hydrogeologic description shall include: (I) the regional geologic setting; (2) significant changes in lithology; (3) the hydraulic conductivity, transmissivity, and specific yield of the aquifer to be used for injection, including a description of the test(s) used to determine these parameters; and (4) the depth to the mean seasonal high water table. C. INJECTION FLUID COMPOSITION Describe the chemical, physical, biological and radiological characteristics of each injectant. Attach the Material Safety Data Sheet (MSDS) for each injectant. If a private well or a well within 'A mile of the injection site is used as the source well, include chemical analysis of source fluid here. D. INJECTION RATIONALE Attach a brief description of the rationale for selecting the injectants and concentrations proposed for injection, including: (1) goals of the injection project; (2) explanation and/or calculations of how the proposed injectant volume and concentration were determined; (3) 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; and (4) summary results of modeling or testing performed to investigate the injectant's potential or susceptibility to change (biological, chemical or physical) in the subsurface. E. INJECTION PROCEDURE AND EQUIPMENT Provide a detailed description of all planned activities related to the proposed injection including but not limited to: (1) construction plans and materials; (2) operation procedures; (3) a detailed diagram of the surface and subsurface portions of the system; and (4) a planned injection schedule. Revised 6/09 UIC-5I/5T Page 5 of 7 - APPLICATION FOR PERMIT TO CONSTRUCT AND/OR USE A WELL(S) FOR INJECTION Type 5I Wells —In Situ Groundwater Remediation / Type 5T Wells — Tracer Injection F. MONITORING PLAN Provide a plan for monitoring the results of the injection, including: (1) a list of existing and proposed monitoring wells to be used; (2) a list of monitoring parameters and analytical methods to be used; and (3) a schedule for sampling to monitor the proposed injection. NOTE: The selected monitoring wells must be located so as to detect any movement of injection fluids, process by- products, or formation fluids outside the injection area or zone. The monitoring parameters should include the target contaminants as well as secondary or intermediate contaminants which may result from the injection and other parameters which may serve to indicate the progress of the intended reactions, such as pH, ORP, dissolved oxygen, and other electron acceptors and donors. The monitoring schedule should be consistent with the pace of the anticipated reactions and rate of transport of the injectants and contaminants. G. WELL DATA Provide a tabulation of data on all existing or abandoned wells within 'A mile of the injection well(s) which penetrate the proposed injection zone, including, but not limited to, monitoring wells and wells proposed for use as injection wells. Such data shall include a description of each well's use (water supply, monitoring, etc), total depth, screened or open borehole depth interval, and well construction or abandonment record, if available. H. MAPS Attach the following scaled, site -specific maps: (1) 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. (2) Site map including: a. all property boundaries; b. all buildings within the property boundary; c. existing and proposed injection wells or well field(s) d. any existing sources of potential or known groundwater contamination, including waste storage, treatment or disposal systems within 'A mile of the injection well or well system; e. all surface water bodies within '/ mile of the injection well or well system; and f. all existing or abandoned wells within %a mile of the injection well(s) which penetrate the proposed injection zone, including, but not limited to, monitoring wells and wells proposed for use as injection wells. (3) Potentiometric surface map(s) including: a. direction of groundwater movement b. existing and proposed monitoring wells c. existing and proposed injection wells — (4) Contaminant plume map(s) including: a. the horizontal extent of the contaminant plume, including isoconcentration lines b. existing and proposed monitoring wells c. existing and proposed injection wells (5) Cross-section(s) to the known or projected depth of contamination, including: a. horizontal and vertical extent of the contaminant plume, including isoconcentration lines b. major changes in lithology c. existing and proposed monitoring wells d. existing and proposed injection wells ? Revised 6/09 UIC-5I/5T Page 6 of 7 APPLICATION FOR PERMIT TO CONSTRUCT AND/OR USE A WELL(S) FOR INJECTION Type 5I Wells — In Situ Groundwater Remediation / Type 5T Wells — Tracer Injection VI. CERTIFICATION (to be signed as required below or by that person's authorized agent) RECEIVED !DENR !DWQ QUEER PROTEC.TICN SECTION NCAC 15A 2C .021 l(b) requires that all permit applications shall be signed as follow . 1. for a corporation: by a responsible corporate officer AUG 11 ZDII 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. I am aware that there are penalties, including the possibility of fines and imprisonment, for submitting false information. I agree to construct, operate, maintain, repair, and if applicable, abandon the injection well(s) and all related appurte •aces in accordance with the approved specifications and conditions of the Permit. Printed Name Signatu o(N G. l-3EAI4J Tired ol- PLt6I. e. (Orlc..$ Date: oR puj 1l VII. CONSENT OF PROPERTY OWNER (if the property is not owned by the 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 15A NCAC 2C .0200). Printed Name and Title: Signature: Date: Submit TWO copies of the completed application package, including all attachments, to: UIC Program Aquifer Protection Section North Carolina DENR-DWQ 1636 Mail Service Center Raleigh, NC 27699-1636 Telephone (919) 733-3221 Revised 6/09 UIC-51/5T Page 7 of 7 ATTACHMENTS ATTACHMENT A - SITE HISTORY 1) Site Usage Site ST-Q8, situated in a highly industrialized area near the center of the base between Taxiway B and Boxcar Street, and adjacent to Tank Creek, consists of former Building 41105. The Site was historically used as a No.2 fuel oil storage and distribution center for the base. Fuel oil was delivered to the Site by tanker trucks and rail cars, where it was unloaded and stored in four 25,000 gallon underground storage tanks (USTs). Presently there are no buildings or structures on the ground surface or subsurface in the vicinity of the former fuel storage facility. 2) Origin of the Contamination The facility was in operation from 1954 to 1985. As part of a base wide UST evaluation program the USTs were precision tested in 1990. One of the tanks failed precision testing. In November 1992, the four tanks, ancillary piping, and fuel dispensers were excavated and removed. During excavation, soil contamination was encountered and free product was observed on water that collected in the open excavation. Contaminated soil was used to backfrll the excavation on top of a plastic liner after the tanks were removed. A Site map, provided in Attachment H, illustrates the former UST locations as well as the initial soil and groundwater sampling locations. 3) Previous Remedial Actions The original remediation approach at the Site involved the use of air sparging to address the presence of LNAPL and reduce the dissolved phase constituents of concern (COCs) in groundwater. However, operation of the air sparging system was suspended in June 2010 due to decreased effectiveness. The current remediation approach at the Site involves gauging of all monitoring (temporary and recovery) wells and the use of aggressive fluid vapor recovery (AFVR), oleophilic socks, and passive skimmers for the removal of LNAPL. ATTACHMENT B - HYDROGEOLOGIC DESCRIPTION 1) Regional Geologic Setting The Site is located in the Atlantic Coastal Plain Physiographic Province of eastern North Carolina. The Coastal Plain consists of an eastward -thickening wedge of Cretaceous to Holocene sediments, comprised of layers of fluvial and marine sands, silts, and clays. According to the North Carolina Geologic Survey's Geologic Map of North Carolina 1985, Cumberland County is primarily underlain by the Cape Fear, Middendorf, and Black Creek formations of Cretaceous age. These formations consist of sandy clays, clayey sands, silts, and mudstone. 2) Significant Changes in Lithology The lithology at the Site is relatively consistent within and surrounding the area of contamination. 3) Aquifer Properties (Hydraulic Conductivity, Transmissivity, and Specific Yield of the Aquifer to be Used for Injection and Tests Used to Determine These Parameters) To date no specific aquifer characteristic testing has been performed at Site ST008. However, numerous aquifer capacity tests were performed at an adjacent site (i.e., 1200 feet to the east), Site SS007, and URS believes the lithology at SS007 is very similar if not the same as at ST008. Hydraulic conductivity (K) was calculated from rising -head slug tests and confirmed by laboratory geotechnical analysis (URS, 2001). Transmissivity (T) was calculated from a step- drawdown test using a saturated aquifer thickness of 22 feet (URS, 2001). Hydraulic conductivity (K): 0.5 — 82.3 ft/day (average of 29 ft/day) Transmissivity (T): 460 ft2/day estimated Specific Yield (Sy): 0.20 — 0.30 Hydraulic conductivity (K) was calculated for soils comprising the surficial aquifer based on the monitoring well slug tests using the Bower and Rice unconfined aquifer slug test method (Bower and Rice, 1976). A K value from a step drawdown test closely approximated slug test results. Specific yield (Sy) for the surficial aquifer was estimated based on published typical values for silty to sandy sediments (McWhorter and Sunada, 1981). 4) Depth to the Mean Seasonal High Water Table The mean seasonal high water table at the Site (as indicated by measurements from the wells that are the focus of the injection event) ranges from approximately 11 to 16 feet below ground surface. 1 ATTACHMENT C - INJECTION FLUID COMPOSITION BOS 200® Composition and Characteristics BOS 200® is composed of a specially -formulated blend of activated carbon, sulfate reduction media, micronutrients, and facultative microbes. When the product is used, a proprietary mixture of naturally occurring microbes (Trap & Treat® Bacteria Concentrate) is added to speed up the remediation process. Potentially hazardous components of BOS 200® include the activated carbon and calcium sulfate (gypsum) mixture, which is an odorless black powder with NFPA Ratings of zero for health and reactivity, and one for flammability. The material decomposes at 1450°C. Contact with strong oxidizers, such as ozone, liquid oxygen, chlorine, etc., may result in fire. Routes of entry include inhalation, skin absorption, and ingestion. The material may produce eye irritation if exposed to dusting conditions without protective eye equipment; it is not a primary skin irritant and is non -toxic through inhalation and ingestion. The effects of long-term, low-level exposures to carbon have not been determined. The material, when wet, removes oxygen from air. Trap & Treat® Bacteria Concentrate Composition and Characteristics Trap & Treat® Bacteria Concentrate is composed of a tan to flesh -colored liquid blend of naturally occurring bacteria and fungi with an odor similar to sour milk. According to the MSDS for the material, none of the ingredients have been found to be hazardous under OSHA's Hazard Communication Rule, 29 CFR.1910.1200. The material may cause irritation to skin and eyes. Fire, explosion, and reactivity information for this material indicate no flash point and no incompatibilities. ATTACHMENT D - INJECTION RATIONALE 1) Current LNAPL recovery techniques and methodologies have exhibited reduced efficiency over the past six months. The goal of the injection of BOS 200® at Site ST008 is to address light non - aqueous phase liquid present in monitoring wells MW8-19 and MW-HF1. 2) The proposed injectant volumes and concentrations were determined by AST Environmental, Inc. through a review of historical LNAPL thickness, depths, and distribution. 3) The LNAPL at the Site is expected to react with the injectant by adsorption "trapping" and then biologically breaking down to carbon dioxide and methane through both aerobic and anaerobic bio-degradation "treating". This is a proprietary treatment mechanism that adsorbs the contaminant into the carbon matrix and allows attached growth microbes to biologically break down the contaminant, releasing either carbon dioxide or methane. Once this conversion is completed, the CO2 and methane move outside of the Carbon matrix leaving additional room for more of the hydrocarbons. See attached proposal for calculation of injectant masses. ATTACHMENT E - INJECTION PROCEDURE & EQUIPMENT 1) URS proposes to inject the BOS200® as a field prepared slurry (see attached map in Attachment H). The treatment area is approximately 2,400 square feet with the advancement of an estimated 32 borings within the area. Spacing of the points will be in grid pattern (i.e., offset rows with approximately 7.5 foot spacing between each point). Borings are to be advanced between approximately 11.5 and 16.0 feet below ground surface (ft bgs). A direct push technology (DPT) drill rig will be used as a delivery platform. A "top down" injection method will be utilized in which BOS200® is injected one foot at a time between approximately 11.5 feet bgs and 16.0 feet bgs (injection intervals may change based on conditions observed in the field). An injection manifold inclusive of quick connect couplings, a ball valve, and a pressure gauge will be attached to the top of the DPT rods. Concurrent with the DPT advancement, The BOS200® liquid slurry will be mixed together and continue to be mixed during the injection events. The injection system will be a contractor supplied temporary mobile system. General components consist of a mixing tank, product pump, metering and measuring system and affiliated conveyance hose. The application apparatus will include an injection pump with controller able to modulate flow to below five gallons per minute (gpm). The injection pressure will be monitored at the injection manifold through pressure gauges. 2) The mobile system will be equipped with tanks for mixing the injection solution. Municipal water will be used for the solution mixing. The solution will be injected at ambient temperatures. High pressure hose will extend from the mixing tank, to the injection pump, to the injection. A pressure gauge, shut-off valves, and pressure bleed -off will also be installed in -line. Injection will be performed using a diaphragm pump. Injection pressures may range from 400 to 700 pounds per square inch (psi) and injection flow rates are estimated to be approximately 35 gpm per injection point. The injection pressure will be monitored continuously using a pressure gauge and the injection rate will be adjusted using the injection pump and valves. After injection, the injection pump will be turned off and the shut-off valve will be closed. 3) Detailed diagrams of the surface and subsurface portions of the system are provided in the attached figures. 4) It is anticipated that the injections will take place in fall 2011, pending Underground Injection Control (UIC) permit approval by the North Carolina Department of Environment and Natural Resources (NCDENR). URS anticipates the injection event at Site ST008 will take 1-2 days. ATTACHMENT F - MONITORING PLAN 1) List of existing monitoring wells to be used for sampling: MW8-I MW8-08, MW8-09, MW8-11, MW-13. MW8-18, W8-19, MW-HF1, MW8-1 2) List of monitorin _ parers and analytical methods to be used: • LNAPL thickness in all Site wells • Volatile aromatics (EPA Method 602), semi volatile compounds (EPA Method 625), extractable petroleum hydrocarbons (EPH) and volatile petroleum hydrocarbons (VPH) will be collected prior to the injection event and approximately 1 year after completion of the event. This will be performed in conjunction with Site performance monitoring. • Sulfate, Sulfite, Nitrate and Nitrite 3) Schedule for gauging/sampling to monitor the proposed injection: LNAPL thickness will be measured in all Site wells prior to the injection event, 1 day after the event, 1 week after the injection event, 2 weeks after the injection event, and the approximately monthly for the next year. Sulfate, Sulfite, Nitrate and Nitrite will be collected in the wells specified above prior to the injection event, approximately 3 months after the injection event, 6 months after the injection event and after approximately 1 year. Attachment G Monitoring and Air Sparge Well Construction Details Site ST008, Pope AFB Well Identification Number Date Installed Well Casing Diameter (inches) Screened Interval (feet bls) Measured Total Well Depth (feet btoc) Top of Casing Elevation (feet msl) Northing Coordinate Easting Coordinate AS-1 NA 2 24 - 29 28.85 192.21 518108.81 1997431.35 AS-2 NA 2 23-28 27.80 192.40 518067.16 1997412.89 AS-3 NA 2 24 - 29 28.10 194.87 518044.93 1997437.35 AS-4 NA 2 13 - 18 17.43 195.95 518027.85 1997462.75 AS-5 NA 2 24 - 29 28.30 196.28 518005.27 1997516.13 AS-6 NA 2 23 - 28 28.00 196.75 517977.76 1997493.06 AS-7 NA 2 18 - 23 22.90 193.04 518056.51 1997402.23 AS-8 NA 2 20 - 25 24.00 192.71 518045.27 1997389.82 MP-8A 12/8/1999 1 10 - 15 14.70 193.25 518057.85 1997430.09 MW8-06 1/14/1997 2 13-23 23.94 196.33 517817.68 1997521.66 MW8-07 1/15/1997 2 9 - 19 19.73 195.94 517995.63 1997589.71 MW8-08 1/15/1997 2 8 - 18 18.15 196.86 517933.52 1997491.11 MW8-09 1/15/1997 2 10-20 20.05 196.39 517886.92 1997377.34 MW8-10 1/16/1997 2 35 - 38 37.40 193.63 518018.10 1997409.54 MW8-II 1/17/1997 2 13-23 22.00 195.53 518016.82 1997438.11 MW8-12 1/21/1997 1 11 -21 21.50 192.10 518102.42 1997410.17 MW8-13 1/21/1997 2 12-22 25.00 191.51 518030.67 1997386.40 MW8-14 1/21/1997 2 10-20 20.13 192.58 518098.55 1997621.90 MW8-15 1/23/1997 2 10-20 20.60 191.92 518159.94 1997473.95 MW8-16 10/30/1997 2 8-23 22.55 195.45 518034.63 1997540.22 MW8-17 10/30/1997 2 5-20 19.77 193.65 518095.36 1997500.98 MW8-18 10/30/1997 2 5-20 19.80 191.63 518077.04 1997401.00 MW8-I9 10/30/1997 2 8-23 20.15 196.21 517970.90 1997434.41 MW8-20 2/6/2003 2 5-20 20.00 191.64 NA NA MW8-21 2/6/2003 -- 5-20 20.00 192.56 518237.32 1997477.74 MW8-RW I (08RW 1) 12/8/1999 4 10 - 15 15.40 193.25 518044.25 1997417.32 MW8-RW2 (08RW2) NA NA NA NA NA NA NA MW8-X1 NA 2 20-25 24.55 192.00 518139.82 1997444.30 MW-HFI 1/1/1994 4 12 - 17 16.70 196.17 517999.58 1997501.44 MW-11F2 1/1/1994 4 12 - 17 17.50 195.06 518051.41 1997456.11 MW-H3 NA NA NA NA 190.80 518443.49 1997843.07 T-1 NA 1 10 - 15 15.70 192.19 517993.99 1997356.36 T-3* NA 1 8 - 13 13.20 191.99 518093.93 1997354.65 T-5* NA 1 10 - 15 15.60 196.34 517924.11 1997366.14 T-6* NA 1 10-15 15.35 196.67 517931.21 1997404.94 T-7• NA 1 9 - 14 14.90 192.73 518043.43 1997403.22 T-8* NA 1 10 - 15 15.75 195.40 518027.34 1997427.75 bls - below land surface bloc - below top of casing msl - mean sea level NA - not available * Abandoned July 2009 due to well construction integrity concerns PACommon Projects\PopeAFBUnstallation Restoration \PBc\6.0 UST Sites\STOOS\2 Fieldwork\LNAPL Recovery Table \ST008 LNAPL Gauging_I2-20-10 AST Environmental, Inc. April 22, 2011 Jonathan J. Kucera Jr., PE URS Corporation 1600 Perimeter Park Drive Morrisville, NC 27560 PO Box 4424 665 McKinney Avenue Midway, Kentucky 40347 859-846-4900 Fax: 859-846-4903 Web Site: astenvironmental.com RE: Proposal for BOS 200® Injection at Pope Air Force Base — Site ST008 Fayetteville, Cumberland County, North Carolina Dear Mr. Kucera, AST Environmental, Inc. (AST) appreciates the opportunity to provide this proposal for the above referenced site. This letter proposal presents the remedial approach and cost to inject BOS 200® to address light non -aqueous phase liquid (LNAPL) present in monitoring wells MW8-19 and MW-HF1 at Site ST008. AST is also providing a cost to conduct a BOS 200® pilot test in the area of TW19-06 at Site SS019. The pilot test will be conducted during the same mobilization as the ST008 injections. The cleanup goal is to remove LNAPL from the wells. ST008 Injection Design During the December 2010 groundwater monitoring event, LNAPL was detected in monitoring wells MW8-19 and MW-HF1 at 0.11 and 0.29 feet thick, respectively. The injection design addresses the two wells separately with a 900 s.f. treatment area centered around each well. A targeted injection grid will be completed around each well. The grid spacing corresponds to a conventional 7.5-foot triangular grid. The injections are designed to achieve a 7.5' effective radius of influence (ROI) and straddle across the assumed smear zone. The smear zone is based on historical depth to product readings obtain from each well. The assumed smear zone in each treatment area is: MW8-19 from 13.5-feet to 16-feet below ground surface (bgs) and MW-HF1 from 11.00-feet to 13.00-feet bgs. The smear zone will be verified in each treatment area prior to injection by completing a soil boring adjacent to each well. The soil from the borings will be screened using a PID and visually inspected to identify free product or highly impacted soil. Injections will be completed every 1- vertical feet across the smear zone with adjacent injection points staggered in order to increase efficiency by creating some overlap between injections. The following summarizes the injection plan. MW8-19 Treatment Area • 900 square feet • Free phase petroleum, 0.11 feet • 16 injection points • 48 injections : alternating depths beginning: (13.5', 14.5', 15.5' and 14.0', 15.0', 16.0') • Injection — 30 Ibs/injection = 1,440 Ibs of BOS 200®, 5 gallons bacteria concentrate, —900 gallons of water Mr. Jonathan J. Kucera April 22, 2011 Page 2 MW-HF1 Treatment Area • 900 square feet • Free phase petroleum, 0.29 feet • 16 injection points • 32 injections : alternating depths beginning: (11.5', 12.5' and 12.0', 13.0') • Injection — 60 lbs/injection = 1,920 lbs of BOS 200®, 5 gallons bacteria concentrate, —900 gallons of water ST019 Pilot Test Injection Design AST is proposing to complete a BOS 200® pilot test in an approximate 575 square foot area around TW19-12 and RW19-02. The pilot test will be conducted during the same mobilization for the ST008 injections. The goal of the pilot test is to demonstrate the performance of the BOS 200® to eliminate the large volume (0.52 feet, TW19-12 and 0.44 feet, RW19-02) of free product in the wells by allowing the biological process to optimize the cleanup efficiency. The area will be purposely under dosed to demonstrate the effects of the biological treatment. A targeted injection grid will be completed around the well. The grid spacing corresponds to a conventional 7.5-foot triangular grid. The injections are designed to achieve a 7.5' effective radius of influence (ROI) and straddle across the assumed smear zone. The top of the smear zone is based on historical depth to product levels in the wells and the bottom based on depth to water levels. The assumed smear zone in: the treatment area is from 17.50-feet to 19.50-feet below ground surface (bgs). The treatment area will be injected with the maximum slurry density per injection of 2 pounds of BOS 200® to 1 gallon of water. The maximum slurry density injected into the smear zone will provide approximately half the volume of BOS 200® required to remove the estimated volume of free product present in the wells based on carbon adsorption calculations. Injections will be completed every 1- vertical foot across the smear zone with adjacent injection points staggered in order to increase efficiency by creating some overlap between injections. The following summarizes the injection plan. ST019 Pilot Area • 575 square feet • Free phase petroleum • 10 injection points • 25 injections : alternating depths beginning: (17.5', 18.5', 19.5' and 18', 19') • Injection — 60 Ibs/injection = 1,500 Ibs of BOS 200®, 5 gallons bacteria concentrate, —750 gallons of water Monitoring Well Installation At the direction of URS, AST will install a new monitoring well at the site. The well will be installed to 35 feet with 10 feet of well screen. The well will be completed at the surface with a flush mounted 12-inch well can installed in a 2-foot by 2-foot concrete well pad. Assumptions AST has made the following assumptions regarding this approach: Mr. Jonathan J. Kucera '.E. April 22, 2011 Page 3 1. The injection permit (UIC permit) for the site will be acquired by others. 2. There will be adequate water onsite (75-gpm service) to prepare the BOS materials for injection. AST will provide a water truck to shuttle water. The water will be provided at no cost to AST. Hydrant permits and fees will be provided by others. 3. The site stratigraphy allows for pushing up to 300 If of 1.25 geoprobe rods per day using 7720 probe. The site stratigraphy will allow for the injection of the up to 1700 Ibs of BOS 200® per day. 4. All utilities and underground appurtenances will be located prior to AST arriving onsite. AST has not included any provisions to perform subsurface utility clearance (such as hang auger boreholes). This can be provided by AST for an additional cost. AST will not be responsible for repairs to mismarked or unmarked buried utilities and other appurtenances. 5. Any boring logs will be prepared by others. 6. Work hours are between 7:00 a.m. and 5:00 p.m. Pricing and Schedule: ST008 Injection Preplanning Mobilization and Demobilization of the Injection/Probe Crew and Site Preparation BOS 200® - 3,350 Ibs ($5.75/Ib as published on Remediation Products, Inc. (RPI) website) Bacteria Concentrate —10 gallons ($75/gallon as published on the RPI website) Shipping and taxes — approximately $0.25/Ib (actual cost will be passed directly to purchaser) Installation Cost - (includes Geoprobe®, injection trailer, generator, 2 - support truck, injection heads and tips, etc.) Injection Cost ST019 Pilot Test Mobilization and Demobilization of the Injection/Probe Included in ST008 Crew and Site Preparation Injection Cost BOS 200® - 1,500 Ibs ($5.75/Ib as published on Remediation Products, Inc. (RPI) website) Bacteria Concentrate — 5 gallons ($75/gallon as published on the RPI website) Shipping and taxes — approximately $0.25/Ib (actual cost will be passed directly to purchaser) Installation Cost - (includes Geoprobe®, injection trailer, generator, Mr. Jonathan J. Kucera April 22, 2011 Page 4 '.E. 2 - support truck, injection heads and tips, etc.) Pilot Test Cost Monitoring Well Installation Mobilization and Demobilization of the Probe Installation of Well — Lump Sum Included in Injection Cost The injection efforts and well installation will require the following work days to complete the activities: • ST008 injections - 2 days • ST019• Pilot Test - 1 day • Monitoring Well Installation- 0.5 days If you have any questions or wish to discuss the information provided herein, please call me at 859-846-4900. Sincerely, AST Environmental, Inc. Duane Guilfoil, P.E. Vice President MOBILE INJECTION SYSTEM DIAGRAM Transfer Pump (or Hydrant Pressure) Flow Meter Pressure Gauge (5x) ►O- Flow Meter (5x1 Injection Pump (Moyno) Pressure Gauge Flow Meter Injection Manifold