WI0600047_Permit (Issuance)_20091218

NORTH CAROLINA
ENVIRONMENTAL MANAGEMENT COMMISSION
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
RALEIGH, NORTH CAROLINA
PERMIT FOR THE CONSTRUCTION AND OPERATION OF A WELL FOR INJECTION
In accordance with the provisions of Article 7, Chapter 87; Article 21, Chapter 143, and other
applicable Laws, Rules, and Regulations
PERMISSION IS HEREBY GRANTED TO
North Carolina Department of Transportation
FOR THE OPERATION OF 3 TYPE 5I INJECTION WELLS, defined in Title 15A North Carolina
Administrative Code 2C .0209(e)(3)(C), to inject Sodium Lactate, Sodium Bicarbonate, and Sodium
Polymetaphosphate solutions, for the enhancement of bioremediation of chlorinated aliphatic
solvents. These injection wells/points will be located at Johnson Brother's Utility and Paving
Company, Inc., 1924 N. Main St., Lillington, Harnett County, North Carolina, and will be operated
in accordance with the application submitted August 13, 2009 and subsequent information received
December 17, 2009, and in conformity with the specifications and supporting data submitted, all of
which are filed with the Department of Environment and Natural Resources and are considered a part
of this permit.
This permit is for Construction and Operation only, and does not waive any provisions of the Water
Use Act or any other applicable Laws, Rules, or Regulations. Operation and use of an injection well
shall be in compliance with Title 15A North Carolina Administrative Code 2C .0100 and .0200, and
any other Laws, Rules, and Regulations pertaining to well construction and use.
This permit shall be effective, unless revoked, from the date of its issuance until November 30, 2011,
and shall be subject to the specified conditions and limitations set forth in Parts I through X hereof.
j �;
Permit issued this the t U day of t-3ecffr P) ` , 2009.
0 ,!)
!
`Coleen H. Sullins, Director
Division of Water Quality
By Authority of the Environmental Management Commission.
Permit No. WI0600047 PAGE1 OF 6
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PART I - WELL CONSTRUCTION GENERAL CONDITIONS
1. The Pennittee must comply with all conditions of this permit and with the standards and criteria
specified in Criteria and Standards Applicable to Injection Wells (15A NCAC 2C .0200). Any
noncompliance with conditions of this permit constitutes a violation of the North Carolina Well
Construction Act and is grounds for enforcement action as provided for in N.C.G.S. 87-94.
2. This permit shall become voidable unless the facility is constructed in accordance with the
conditions of this permit, the approved plans and specifications, and other supporting data.
3. This permit is valid only for construction of the number of injection wells described in the
application and other supporting data. Construction of additional injection wells must be
approved in advance by the Aquifer Protection Section.
4. Each injection well shall not hydraulically connect separate aquifers.
5. Each injection well shall be constructed in such a manner that water from land surface cannot
migrate into the gravel pack or well screen.
6. 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 must be secured with a locking cap.
7. Each injection well shall be afforded reasonable protection against damage during coast uction
and use.
8. Each injection well shall have permanently affixed an identification plate.
9. Within 30 days of completion of well construction, a completed Well Construction Record
(Form GW-1) must be submitted for each injection well to:
Aquifer Protection Section-UIC Staff
DENR-Division of Water Quality
1636 Mail Service Center
Raleigh, NC 27699-1636
PART II - WELL CONSTRUCTION SPECIAL CONDITIONS
At least forty-eight (48) hours prior to constructing each injection well, the Pennittee shall notify the
Aquifer Protection Section -Underground Injection Control (UIC) Central Office staff, telephone
number [phone] and the Fayetteville Regional Office Aquifer Protection Section Staff,
telephone number [phone].
Permit No. WI0600047 PAGE 2 OF 6
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PART III - OPERATION AND USE GENERAL CONDITIONS
1. This permit is effective only with respect to the nature, volume of materials, rate of injection, and
number of injection wells as described in the application and other supporting data.
2. This permit is not transferable without prior notice to, and approval by, the Director of the
Division of Water Quality (Director). In the event there is a desire for the facility to change
ownership, or there is a name change of the Permittee, a formal permit amendment request must
be submitted to the Director, including any supporting materials as may be appropriate, at least
30 days prior to the date of the change.
3. The issuance of this permit shall not relieve the Permittee of the responsibility of complying with
any and all statutes, rules, regulations, or ordinances which may be imposed by other local, state,
and federal agencies which have jurisdiction. Furthermore, the issuance of this permit does not
imply that all regulatory requirements have been met.
PART IV - PERFORMANCE STANDARDS
1. The injection facility shall be effectively maintained and operated at all times so that there is no
contamination of groundwater which will render it unsatisfactory for normal use. In the event
that the facility fails to perform satisfactorily, including the creation of nuisance conditions or
failure of the injection zone to adequately assimilate the injected fluid, the Permittee shall take
immediate corrective actions including those actions that may be required by the Division of
Water Quality such as the repair, modification, or abandonment of the injection facility.
2.
The Permittee shall be required to comply with the terms and conditions of this permit even if
compliance requires a reduction or elimination of the permitted activity.
3. The issuance of this permit shall not relieve the Permittee of the responsibility for damages to
surface or groundwater resulting from the operation of this facility.
PART V - OPERATION AND MAINTENANCE REQUIREMENTS
1. The injection facility shall be properly maintained and operated at all times.
2. The Permittee must notify the Division and receive prior written approval from the Director of
any planned physical alterations or additions in the permitted facility or activity not specifically
authorized by the permit.
3. At least forty-eight (48) hours prior to the initiation of the operation of the facility for injection,
the Permittee must notify by telephone the Aquifer Protection Section-UIC, Central Office staff,
telephone number (919) 7.15-6168. Notification is required so that Division staff can inspect or
otherwise review the injection facility and determine if it is in compliance with permit
conditions.
Permit No. WI0600047 PAGE 3 OF 6
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PART VI - INSPECTIONS
1. Any duly authorized officer, employee, or representative of the Division of Water Quality may,
upon presentation of credentials, enter and inspect any property, premises, or place on or related
to the injection facility at any reasonable time for the purpose of determining compliance with
this permit, may inspect or copy any records that must be maintained under the terns and
conditions of this permit, and may obtain samples of groundwater, surface water, or injection
fluids.
2. Department representatives shall have reasonable access for purposes of inspection, observation,
and sampling associated with injection and any related facilities as provided for in N.C.G.S. 87-
90.
3. Provisions shall be made for collecting any necessary and appropriate samples associated with
the injection facility activities.
PART VII - MONITORING AND REPORTING REQUIREMENTS
1. The proposed monitoring plan included in the application shall be followed. All sample results
shall be submitted to the Aquifer Protection Section's Fayetteville Regional Office and the
Raleigh Central Office. Any monitoring (including groundwater, surface water, or soil sampling)
deemed necessary by the Division of Water Quality to insure surface and ground water
protection, will be established and an acceptable sampling reporting schedule shall be followed.
2,
The Permittee shall submit an Injection Event Record within 30 days of completing each
injection.
3. The Permittee shall produce a final project evaluation within 9 months after completing all
injection -related activity associated with this permit or produce a project interim evaluation
before submitting a renewal application for this permit. This document shall assess the injection
projects findings in a written summary. The final project evaluation shall also contain
monitoring well sampling data, contaminant plume maps and potentiometric surface maps.
4. The monitoring results and the final project evaluation shall be submitted to:
and to:
Aquifer Protection Section-UIC Staff
DENR-Division of Water Quality
1636 Mail Service Center
Raleigh, NC 27699-1636
Aquifer Protection Section
DENR-DWQ Fayetteville Regional Office
225 Green St., Suite 714
Fayetteville, NC 28301
Permit No. WI0600047 PAGE 4 OF 6
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7-Th

5. The Permittee shall report by telephone, within 48 hours of the occurrence or first knowledge of
the occurrence, to the Fayetteville Regional Office, telephone number [phone] , any of the
following:
(A)Any occurrence at the injection facility which results in any unusual operating
circumstances;
(B) Any failure due to known or unknown reasons, that renders the facility incapable of
proper injection operations, such as mechanical or electrical failures.
6. 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.
7. In the event that the permitted facility fails to perform satisfactorily, the Pennittee shall take such
immediate action as may be required by the Director.
PART VIII - PERMIT RENEWAL
In order to continue uninterrupted legal use of the injection facility for the stated purpose, the
Permittee must submit an application to renew the permit 120 days prior to its expiration date.
PART IX - CHANGE OF WELL STATUS
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 .0113, Well Construction Standards.
2. When operations have ceased at the facility and a well will no longer be used for any purpose,
the Permittee shall abandon that injection well in accordance with the procedures specified in
15A NCAC 2C .0113(b), including but not limited to the following:
(A) All casing and screen materials may be removed prior to initiation of abandonment
procedures if such removal will not cause or contribute to contamination of the
groundwaters.
(B) The entire depth of each well shall be sounded before it is sealed to insure freedom from
obstructions that may interfere with sealing operations.
(C) The well shall be thoroughly disinfected, prior to sealing, if the Director determines that
failure to do so could lead to the contamination of an underground source of drinking
water.
Permit No. WI0600047 PAGE 5 OF 6
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(D) Drilled wells shall be completely filled with cement grout, or bentonite grout which shall
be introduced into the well through a pipe which extends to the bottom of the well and is
raised as the well is filled.
(E) In the case of gravel -packed wells in which the casing and screens have not been
removed, neat -cement, or bentonite grout shall be injected into the well completely filling
it from the bottom of the casing to the top.
(F) In those cases when, as a result of the injection operations, a subsurface cavity has been
created, each well shall be abandoned in such a manner that will prevent the movement
of fluids into or between underground sources of drinking water and in accordance with
the terms and conditions of the permit.
(G) The Permittee shall submit a Well Abandonment Record (Form GW-30) as specified in
15A NCAC 2C .0213(h)(1) within 30 days of completion of abandonment.
3. The written documentation required in Part IX (1) and (2) (G) shall be submitted to:
Aquifer Protection Section-UIC Staff
DENR-Division of Water Quality
1636 Mail Service Center
Raleigh, NC 27699-1636
PART X — WORKER PRECAUTIONS DURING APPLICATION
1. Some effects reported to be associated with the product proposed to be used are as follows: eye,
skin, nose, throat, and lung irritation. If the product is released into the environment in a way
that could result in a suspension of fine solid or liquid particles (e.g., grinding, blending,
vigorous shaking or mixing), then proper personal protective equipment should be used. The
application process should be reviewed by an industrial hygienist to ensure that the most
appropriate personal protective equipment is used.
2. Persons working with these products should wear goggles or a face shield, gloves, and protective
clothing. Face and body protection should be used for anticipated splashes or sprays.
3. Eating, drinking, smoking, handling contact lenses, and applying cosmetics should not be
permitted in the application area during or immediately following application.
4. Site access should be limited to worker's involved in the injection of the solution. Safety
controls should be in place to ensure that the check valve and the pressure delivery systems are
working properly.
5. The Material Safety Data Sheets should be followed to prevent incompatible or adverse reactions
and injuries.
Permit No. WI0600047 PAGE 6 OF 6
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i

PERMIT ISSUANCE MEMO
TO: Debra Watts
FROM: Michael Roger,
RE:
DIVISION OF WATER RESOURCES
3/8/2019
Renewal with Modification for Permit WI0600047
NCDOT Priority Site #32
Harnett County
I recommend that the above permit be renewed. The Applicant is requesting a modification and renewal of the
existing permit. Essentially, this injection will be the same as the permit issued in 2011 with the same amount of
injectant, except they will use beverage remediation products (BRP) as the primary additive, and 5 wells instead
of 3.
During the process of reviewing monitoring reports and potentially closing out this permit, I noticed some elevated
phosphate in the last monitoring report due to injection activity. After discussions with NCDOT where I told
them they needed to continue to monitor until groundwater quality met 2L or pre -injection levels, the Permittee
decided to renew the permit in early part of 2018. However, they withdrew the application in March 2018 because
they want to renew the permit and try a different additive (BRP) to further clean up groundwater. They re-
submitted a renewal application with modification request in November 2018. As part of monitoring per the
injection permit requirements, they will also continue to monitor phosphate as well.
Since this is a permit renewal, refer to the previous memo dated 12/18/2009 for site info.
HIGHLIGHTS/COMMENTS:
• This permit was originally issued December 18, 2009, and expired November 30, 2011. The 2009 permit
is attached.
• They are proposing to inject into 5 existing injection wells (highlighted in orange on Figure 17).
• Per my request they are going to install 2 new proposed monitoring wells (32-MW-26 and 32-MW-26D)
to detect any impacts of the injection closer to the southwest, downgradient of the injection area (refer to
Table 5). Monitoring wells highlighted in yellow on Figure 17.
• The monitoring plan includes sampling all wells as per the previously issued permit, plus the new
additional monitoring wells.
• NCDOT requested the permit be written such that they can use any "Additives or Tracers Approved by
NC DHHS to Inject into Groundwater". I was not comfortable abiding to this request. 1 added a permit
condition in Part III.2 that they need to notify us 30 days prior to injection if they opt to use different
approved additives.
• Since the same amount of injectant being used is the same as last time, the potential displacement of
plume is low.

• FYI, there is no MSDS for BRP as it is considered a food/beverage grade product and is exempt from the
requirement to create a MSDS sheet.
REGIONAL OFFICE COMMENTS: Fayetteville Regional Office recommends issuance of this permit.

5I Calculations Worksheet
Applicant/Facility: /Ut✓D 6 % — S//
Permit No. WI 0400 6 V?"
Date:
Reviewer:
M�,
Mc Si ,Z vfv flj,vi '/t6(/
Depth to groundwater (GW): N /'r BLS
GW flow direction: S'aa-Z
MWs installed in same aquifer as injection? )((YY or N); Inj zone: �/S t-fv MW1zone:.� 0:0 C
Nearest water supply well: ()7%,ry 5
Sin, ,,.,Q-vry 6O h.A)—JOi%'�/
Groundwater Flow Rate
HC X gradient(FT?) = flow rate/DAY(?) X 365 =
SY or porosity (—.30)
Reported:/3 ch Z?
FT/YR
[FYI- 60 min. X 24 hrs X 365 days = 525,600]
Calculations for Potential Contaminate Plume Displacement
LiAD
3$43{ .) X a`O C) XX L%Seight = o2, /G !) QO CF
/66 0 0 c7 CF X �IS SY or porosity (i.e. —.30) = / 7a/ 003 CF of available void
space
%�atoo
c.3
CF of available void space X 7.48 gallons = a gallons of water in void sp
TO/ 000 gallons of injectant = / % of fluid displaced by injectant (move decimal)
a-91), s (y a
gallons of water in void spa e
Potential displacement of plume by injection:
Injection Volume and Pumping Rate Per Well Per Day
a'.5\
total amt. of injectant / r number of wells / 5—number of days of injection event =
.c J amount of injectant per well per day (average gallons per day)
r/d—c--
S:UIC/Applications and forms/ 5I Calculations worksheet
o / k r° croa 0 s`ve-4-3
version 9/10/10

DIVISION OF WATER QUALITY
AQUIFER PROTECTION SECTION
December 18, 2009
PERMIT ISSUANCE MEMO
TO: Debra Watts
THROUGH: Thomas Slusser
FROM: John elc;;,.v
RE: Permit To Inject S. €tium ; ; :,Sp
SO
i; do
I Prm ity SPX. NO.:,
I recommend that Permit Number WI060004 % be issued to Ilk- NC DOT to inject Sodium
to remediate ground wat contaminated with cniormzned
SITE DESCRIPTION 1" . .. . Equipment
cleaning activities associated with asphalt testing at this site led to the release of chlorinated aliphatic compound
solvents.
HYDROGEOLOGIC DESCRIPTION
V, 'Jill the constraints oi'the
.Aquifer.
stir is located along the western boundary of the Coast! lain
.n primarily by silts and tine _.ands of Coastal Plain Sedimentaryi t±(
e sediments cornnuse a surficial aquifer and the hvdraulicaily connected Black
EXTENT OF CONTAMINATION Contaminant distribution of 1,1-DCE for concentrations above the
NCGWQS, based on the most recent sampling event, is ovate in plan view (-250feet in length) with the long axis
corresponding to the North -South aligned A -A' cross section and is —125 ft wide. The plume extends to a depth
greater than the monitoring well network (>60ft bgl)(Fig. 17 and 18).
PROPOSED INJECTION The applicant proposes to inject, either by gravity or at a pressure not to exceed 50
psi, 200 gallons of solution composed of Sodium Lactate, Sodium Bicarbonate, and Sodium Polymetaphosphate into
the shallow groundwater zone through two existing monitoring wells and 400 gallons of solution into the deeper
groundwater zone through one monitoring well followed by 200 gallons of potable water per well during each event.
A total of four injection events are scheduled, resulting in a total injection volume of 3200 gallons of solution and
2400 gallons of potable water, or 5600 gallons of total injected fluids. The total volume of injectants comprises
approximately an average of <1% of the pilot injection area.
HOW IT WORKS The main remedial activity of the injectant solution is to promote a more favorable
environment for naturally occurring halorespirating bacteria to continue consumption and degredation of the
contaminants. Sodium Bicarbonate is introduced to increase the pH of the groundwater to a more neutral level, and
the Sodium Lactate and Sodium Polymetaphosphate compounds provide other essential components for cell growth
such as energy, carbon, and phosphate.
MONITORING All monitoring wells located at the site will be used for monitoring for changes in
groundwater flow and contaminant concentrations during the injection events and afterward. One sampling event will
be conducted prior to injection and post injection monitoring will be done on a quarterly basis and will last for one
year.

EPIDEMIOLOGY On August 30, 2006, the DHHS' Epidemiology Branch provided comments on Sodium
Lactate, Sodium Bicarbonate, and Sodium Polymetaphosphate for groundwater remediation. Dr. Luanne K. Williams
did not present any information that would preclude the use of these products for injection but did provide a health
risk analysis and worker safety precautions, which are in Part X of the attached permit.
REGIONAL OFFICE COMMENTS Art Ba,a nh.ardt of the .Fayett ;°iit Regional Office recommends issuance of this
permit.