WI0600080_Staff Report_20110815

Central Files: APS SWP
08/15/11
Permit Number WI0600080
Permit Tracking Slip
Program Category
Ground Water
Permit Type
Injection In situ Groundwater Remediation Well (51)
Status Project Type
In review New Project
Version Permit Classification
Individual
Primary Reviewer Permit Contact Affiliation
david.goodrich Jon J. Kucera Jr.
Coastal SW Rule
Permitted Flow
Facility
Facility Name
Pope Army Air Field 2
Location Address
Pope Aaf Site St008
Fort Bragg
Owner
1600 Perimeter Park Dr
Morrisville NC 27560
Major/Minor Region
Minor Fayetteville
County
Cumberland
NC 28310 Facility Contact Affiliation
Owner Name Owner Type
Pope Army Airfield Government - Federal
Owner Affiliation
Greg Bean
Director Of Public Works Attn Imse-Brg-
Fort Bragg NC 28310
Dates/Events
Orig Issue
App Received
08/11/11
Draft Initiated
Scheduled
Issuance
Public Notice Issue
Regulated Activities Requested/Received Events
Groundwater monitoring
Groundwater remediation
Outfall NULL
RO staff report received
RO staff report requested
Effective Expiration
Waterbody Name Stream Index Number Current Class Subbasin

AQUIFER PROTECTION SECTION
APPLICATION REVIEW REQUEST FORM
Date: August 15, 2011
To: ❑ Landon Davidson, ARO-APS
X Art Barnhardt, FRO-APS
❑ Andrew Pitner, MRO-APS
❑ Jay Zimmerman, RRO-APS
From: David Goodrich , Land Application Unit
Telephone: [phone]
E-Mail: david.eoodrichQ,ncdenr.gov
❑ David May, WaRO-APS
❑ Charlie Stehman, WiRO-APS
❑ Sherri Knight, WSRO-APS
Fax: [phone]
A. Permit Number: WI0600080
B. Owner: Pope Army Airfield oO S
C. Facility/Operation: Pope Army Airfield II
❑ Proposed X Existing
D. Application:
1. Permit Type: E Animal
❑ Recycle
RECEIVED / DENR / DWQ
Aquifer Protection. Section
SEP 26 2011
X Facility X Operation
❑ Surface Irrigation ❑ Reuse ❑ H-R Infiltration
❑ I/E Lagoon X GW Remediation (ND)51 Injection
❑ UIC - (5A7) open loop geothermal
For Residuals: ❑ Land App. ❑ D&M ❑ Surface Disposal
❑ 503 ❑ 503 Exempt El Animal
2. Project Type: X New D Major Mod. ❑ Minor Mod. ❑ Renewal ❑ Renewal w/ Mod.
E. Comments/Other Information: ❑ I would like to accompany you on a site visit.
Attached, you will find all information submitted in support of the above -referenced application for your
review, comment, and/or action. Within 30 calendar days, please take the following actions:
X Return a Completed APSARR Form. - Please comment
❑ Attach Well Construction Data Sheet.
❑ Attach Attachment B for Certification by the LAPCU.
❑ Issue an Attachment B Certification from the RO. *
* Remember that you will be responsible for coordinating site visits and reviews, as well as additional
information requests with other RO-APS representatives in order to prepare a complete Attachment B for
certification. Refer to the RPP SOP for additional detail.
When you receive this request form, please write your name and dates in the spaces below, make a copy
of this sheet, and return it to the appropriate Central Office -Aquifer Protection Section contact person
listed above.
RO-APS Reviewer:
Date:
9/1 •i ','
s
FORM: APSARR 07/06 Page 1 of 1

AQUIFER PROTECTION SECTION REGIONAL STAFF REPORT
Date: 09/15/11 County: Cumberland
To: Aquifer Protection Section Central OfficePermittee: Ft. Bragg-U.S. Army Env. Command
Central Office Reviewer: David Goodrich Project Name: Pope Army Airfield ST008
Regional Login No: ?? Application No.: WI00600080
I. GENERAL INFORMATION
1. This application is (check all that apply): ® New El Renewal
❑ Minor Modification El Major Modification
❑ Surface Irrigation ❑ Reuse ❑ Recycle ❑ High Rate Infiltration ❑ Evaporation/Infiltration Lagoon
❑ Land Application of Residuals
❑ Distribution of Residuals
❑ Attachment B included
❑ Surface Disposal
❑ 503 regulated ❑ 503 exempt
❑ Closed -loop Groundwater Remediation ® Other Injection Wells (including in situ remediation)
Was a site visit conducted in order to prepare this report? ® Yes or ❑ No.
a. Date of site visit: 08/31/11
EIVED DENR I DWQ
b. Person contacted and contact information: Ms. Christie Lowery - Project ManaRECutEle protection Section
SEP 26 2011
c.
Site visit conducted by: Jim Barber
d. Inspection Report Attached: ❑ Yes"or ® No.
2. Is the following information entered into the BIMS record for this application correct?
/1 Yes or ❑ No. If no, please complete the following or indicate that it is correct on the current application.
For Treatment Facilities:
a. Location: Fort Bragg, NC.
b. Driving Directions: The project site, for in -situ remediation, is located between the taxiway/main runway
of Pope Airfield and Boxcar Street. Access to the site is thru the main gate off of Boxcar Street..
c. USGS Quadrangle Map name and number: Overhills N.C. (G-22-NE)
d. Latitude: 35.173278 Longitude: -79.008503 (ST008)
e. Regulated Activities / Type of Wastes (e.g., subdivision, food processing, municipal wastewater):
Groundwater remediation system consisting of Injection Wells for the remediation of petroleum products
(No. 2 fuel oil) from underground storage tanks, distribution lines and pump manholes..
For Disposal and Infection Sites:
(If multiple sites either indicate which sites the information applies to, copy and paste a new section into the
document for each site, or attach additional pages for each site)
a. Location(s): Ft. Bragg NC
b. Driving Directions: The project site, for in -situ remediation, is located between the taxiway/main runway
of Pope Airfield and Boxcar Street. Access to the site is thru the main gate off of Boxcar Street..
c. USGS Quadrangle Map name and number: Overhills N.C. (G-22-NE)
d. Latitude: 35.173278 Longitude: -79.008503
FORM: APSARRFtBraggUICWI0600080Sept201 1 ST008.doc 1

AQUIFER PROTEc:TION SECTION REGIONAL STAFF REPORT
IL NEW AND MAJOR MODIFICATION APPLICATIONS (this section not needed for renewals or minor
modifications, skip to next section)
Description Of Waste(S) And Facilities
1. Please attach completed rating sheet. Facility Classification:
2. Are the new treatment facilities adequate for the type of waste and disposal system?
0 Yes ❑ No 0 N/A. If no, please explain:
3. Are the new site conditions (soils, topography, depth to water table, etc) consistent with what was reported by
the soil scientist and/or Professional Engineer? ❑ Yes ❑ No ❑ N/A. If no, please explain:
RECEIED Aqu'►fevP of DE nRS D iWon
Q
SEP 26 2011
4. Does the application (maps, plans, etc.) represent the actual site (property lines, wells, surface drainage)? U
Yes ❑ No ❑ N/A. If no, please explain:
5. Is the proposed residuals management plan adequate and/or acceptable to the Division. ❑ Yes ❑ No ❑
N/A. If no, please explain:
6. Are the proposed application rates for new sites (hydraulic or nutrient) acceptable?
❑ Yes ❑ No ❑ N/A. If no, please explain:
7. Are the new treatment facilities or any new disposal sites located in a 100-year floodplain?
❑ Yes ❑ No ❑ N/A. If yes, please attach a map showing areas of 100-year floodplain and please explain
and recommend any mitigative measures/special conditions in Part IV:
8. Are there any buffer conflicts (new treatment facilities or new disposal sites)? ❑ Yes or ❑ No. If yes, please
attach a map showing conflict areas or attach any new maps you have received from the applicant to be
incorporated into the permit:
9. Is proposed and/or existing groundwater monitoring program (number of wells, frequency of monitoring,
monitoring parameters, etc.) adequate? 0 Yes ❑ No ❑ N/A. Attach map of existing monitoring well
network if applicable. Indicate the review and compliance boundaries. If No, explain and recommend any
changes to the groundwater monitoring program:
10. For residuals, will seasonal or other restrictions be required? ❑ Yes ❑ No ❑ N/A If yes, attach list of sites .
with restrictions (Certification B?)
III. RENEWAL AND MODIFICATION APPLICATIONS (use previous section for new or Ana/or modification
systems)
Description Of Waste(S) And Facilities
1. Are there appropriately certified ORCs for the facilities? ❑ Yes or ❑ No.
Operator in Charge: Certificate #:
Backup- Operator in Charge: Certificate #:
FORM: APSA RRFtBraggUICWI0600080Sept20 1 1 ST008.doc
2

AQUIFER PROTECTION SECTION REGIONAL STAFF REPORT
2. Is the design, maintenance and operation (e.g. adequate aeration, sludge wasting, sludge storage, effluent
storage, etc) of the treatment facilities adequate for the type of waste and disposal system? ❑ Yes or ❑ No.
If no, please explain:
3. Are the site conditions (soils, topography, depth to water table, etc) maintained appropriately and adequately
assimilating the waste? ❑ Yes or ❑ No. If no, please explain:
4. Has the site changed in any way that may affect permit (drainage added, new wells inside the compliance
boundary, new development, etc.)? If yes, please explain:
5. Is the residuals management plan for the facility adequate and/or acceptable to the Division?
❑ Yes or ❑ No. If no, please explain:
6. Are the existing application rates (hydraulic or nutrient) still acceptable? ❑ Yes or ❑ No. If no, please
explain:
7. Is the existing groundwater monitoring program (number of wells, frequency of monitoring, monitoring
parameters, etc.) adequate? ❑ Yes ❑ No ❑ N/A. Attach map of existing monitoring well network if
applicable. Indicate the review and compliance boundaries. If No, explain and recommend any changes to the
groundwater monitoring program:
8. Will seasonal or other restrictions be required for added sites? ❑ Yes ❑ No ❑ N/A If yes, attach list of sites
with restrictions (Certification B?)
9: Are there any buffer conflicts (treatment facilities or disposal sites)? ❑ Yes or n No. If yes, please attach a
map showing conflict areas or attach any new maps you have received from the applicant to be incorporated
into the permit:
10. Is the description of the facilities, type and/or volume of waste(s) as written in the existing permit correct? ❑
Yes or ❑ No. If no, please explain:
11. Were monitoring wells properly constructed and located? ❑ Yes or ❑ No ❑ N/A. If no, please explain:
12. Has a review of all self -monitoring data been conducted (GW, NDMR, and NDAR as applicable)? ® Yes or
❑ No ❑ N/A. Please summarize any findings resulting from this review:
13. Check all that apply: ❑ No compliance issues; ❑ Notice(s) of violation within the last permit cycle; ❑
Current enforcement action(s) ❑ Currently under SOC; ❑ Currently under JOC; ❑ Currently under
moratorium. If any items checked, please explain and attach any documents that may help clarify
answer/comments (such as NOV, NOD etc):
14. Have all compliance dates/conditions in the existing permit, (SOC, JOC, etc.) been complied with? ❑ Yes
❑ No ❑ Not Determined ❑ N/A.. If no, please explain:
15. Are there any issues related to compliance/enforcement that should be resolved before issuing this permit? ❑
Yes or ❑ No ❑ N/A. If yes, please explain:
FORM: APSARRFtBraggUICWI0600080Sept2011ST008.doc 3

•
AQUIFER PROTECTION SECTION REGIONAL STAFF REPORT
IV. INJECTION WELL PERMIT APPLICATIONS (Complete these two sections for all systems that use injection
wells, including closed -loop groundwater remediation effluent injection wells, in situ remediation injection'wells, and heat
pump injection wells.)
Description Of Well(S) And Facilities — New, Renewal, And Modification
1. Type of injection system:
❑ Heating/cooling water return flow (5A7)
❑ Closed -loop heat pump system (5QM/5QW)
® In situ remediation (51)
❑ Closed -loop groundwater remediation effluent injection (5L/"Non-Discharge")
❑ Other (Specify: )
2. Does system use same well for water source and injection? ❑ Yes N No
3. Are there any potential pollution sources that may affect injection? ❑ yes Z No
What is/are the pollution source(s)? . What is the distance of the injection well(s) from the pollution
source(s)? ft:
4. What is the minimum distance of proposed injection wells from the property boundary? 5000+' ft.
5. Quality of drainage at site: Z Good ❑ Adequate ❑ Poor
6. Flooding potential of site: ® Low . ❑ Moderate ❑ High
7. For groundwater remediation systems, is the proposed and/or existing groundwater monitoring program
(number of wells, frequency of monitoring, monitoring parameters, etc.) adequate? ® Yes ❑ No. Attach
map of existing monitoring well network if applicable. If No, explain and recommend any changes to the
groundwater monitoring program:
8. Does the map presented represent the actual site (property lines, wells, surface drainage)? ® Yes or ❑ No. If
no or no map, please attach a sketch of the site. Show property boundaries, buildings, wells, potential pollution
sources, roads, approximate scale, and north arrow.
Injection Well Permit Renewal And Modification Only:
1. For heat pump systems, are there any abnormalities in heat pump or injection well operation (e.g. turbid water,
failure to assimilate injected fluid, poor heating/cooling)?
❑ Yes ❑ No. If yes, explain: •
2. For closed -loop heat pump systems, has system lost pressure or required make-up fluid since permit issuance
or last inspection? ❑ Yes ❑ No. If yes, explain:
3. For renewal or modification of groundwater remediation permits (of any type), will
continued/additional/modified injections have an adverse impact on migration of the plume or management of
the contamination incident? ❑ Yes ❑ No. Imes, explain:
4. Drilling contractor: Name:
FORM: APSARRFtBraggUICWI0600080Sept201IST008.doc 4

AQUIFER PROTEMION SECTION REGION/STAFF REPORT
Address:
Certification number:
5. Complete and attach Well Construction Data Sheet.
FORM: APSARRFtBraggUICWI0600080Sept2011ST008.doc 5

AQUIFER PROTE: i ION SECTION REGIONAL STAFF REPORT
V. EVALUATION AND RECOMMENDATIONS
1. Provide any additional narrative regarding your review of the application.: .
2. Attach Well Construction Data Sheet - if needed information is available
3. Do you foresee any problems with issuance/renewal of this permit? ❑ Yes ® No. If yes, please explain
briefly.
4. List any items that you would like APS Central Office to obtain through an additional information request.
Make sure that you provide a reason for each item:
Item
Reason
5. List specific Permit conditions that you recommend to be removed from the permit when issued. Make sure
that you provide a reason for each condition:
Condition
Reason
6. List specific special conditions or compliance schedules that you recommend to be included in the permit when
issued. Make sure that you provide a reason for each special condition:
Condition
Reason
7. Recommendation: n Hold, pending receipt and review of additional information by regional office; ❑ Hold,
pending review of draft permit by regional office; ❑ Issue upon receipt of needed additional information;
Issue; ❑ Deny. If deny, please state reasons:
8. Signature of report preparer(s):
Signature of APS regional supervisor:
q/,ql,►
Date:
t
►7-4 _ FoIZ i2T E,4R04/ThT
ADDITIONAL REGIONAL STAFF REVIEW ITEMS
There are no groundwater users in the area of the remediation site, based upon visual observations during the
site visit. Ft. Bragg and Pope Airfield are served by a municipal water system with the exception of outlying
FORM: APSARRFtBraggUICWI0600080Sept2011ST008.doc
6

•
AQUIFER PROTECTION SECTION REGIONAL STAFF REPORT
areas (drop zones, ranges) that are served by wells which are over 3 miles or more from the proposed
remediation site.
A copy of the final UIC permit should be provided to the Superfund Section, in the Division of Waste
Management. The contact person for this site is Ms. Marti Morgan (919-508-8468). The mailing address is as
follows:
Division of Waste Management
Superfund Section
1646 Mail Service Center
Raleigh, NC 27699-1646
Attn: Ms. Marti Morgan
FORM: APSARRFtBraggUICWI0600080Sept2011ST008.doc 7

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Goodrich, David
From: Rudo, Ken
Sent: Wednesday, October 12, 2011 10:46 AM
To: Goodrich, David
Subject: FW: Epidemiological Assessment of Trap & Treat Bacteria Concentrate
Mr. Goodrich I have reviewed the health risk evaluation Luanne Williams did for this product in October of 2006. I am in
concurrence with her risk evaluation. Please go ahead and use her evaluation as our response to this application.
Sincerely Kenneth Rudo, Ph.D, Toxicologist, OEEB
From: Goodrich, David
Sent: Thursday, September 15, 2011 2:43 PM
To: Rudo, Ken
Subject: Epidemiological Assessment of Trap & Treat Bacteria Concentrate
Hi Ken,
I sent a note with attachments to Dr. Shehee last month regarding an assessment of this substance, which will be used
to remediate ground water contaminated with Number 2 Fuel Oil. Please let me know if you require additional
information to assess this remedial substance.
Thank you.
Regards,
David Goodrich
Aquifer Protection Section Central Office
Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed to third parties by an authorized State
official. Unauthorized disclosure of juvenile, health, legally privileged, or otherwise confidential information, including confidential information relating to an ongoing
State procurement effort, is prohibited by law. If you have received this e-mail in error, please notify the sender immediately and delete all records of this e-mail.
1

Goodrich, David
From: Goodrich, David
Sent: Wednesday, September 21, 2011 8:51 AM
To:'[e-mail]
Cc: Rudo, Ken
Subject: Trap and Treat Bacteria Concentrate
Dear Advanced Microbial Services:
I work for the State of North Carolina Division of Water Quality's Aquifer Protection Section and am preparing to issue a
permit for the underground injection of your Trap and Treat Bacteria Concentrate for the subsurface remediation of
Number 2 fuel oil at a site in Fort Bragg, North Carolina.
In accordance with our procedures, any and all substances that are injected into the ground must be reviewed by our
Epidemiology Section in the North Carolina Division of Public Health. The Material Safety Data Sheet for Trap and Treat
Bacteria Concentrate has been submitted to the Epidemiology Section for their review, but more information concerning
the substance's compound -specific (chemical -specific) information is needed for them to assess the necessary
precautions associated with applying this product and its potential health effects if consumed by individuals drinking
well water.
i
I am writing to request additional information regarding Trap and Treat Bacteria Concentrate's compound -specific
composition. If this information is proprietary, we have security protocols to prevent it from being accessed by all
persons who are not directly involved with our permitting/review process.
Regards,
David Goodrich
Aquifer Protection Section Central Office
Telephone [phone]
t

DIVISION OF WATER QUALITY
AQUIFER PROTECTION SECTION
October 6, 2011
MEMORANDUM
TO: FILE
THROUGH: Debra Watts, Groundwater Protection Unit Supervisor
FROM: David Goodrich
RE: Confidential Information Associated with Pope Army Airfield (Site ST4O
Permit Application for Injection Permit WI0600080
The Pope Army Airfield at Fort Bragg has submitted information in support of this permit application and
has requested that it be treated as a trade secret and not be released to the public, in accordance with
NCGS 132-1.2 and 15A NCAC .0211(f). Based on my examination of this information and the request
for protection of confidential information submitted by the applicant, I have concluded that this
information is entitled to protection as a trade secret and should not be released to the public. This
information is kept in a locked file cabinet in the Groundwater Protection Unit Supervisor's office and is
not to be released to the public.

AwcwA,an
1CDENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality -
Beverly Eaves Perdue Coleen H. Sullins Dee Freeman
Governor Director Secretary
August 16, 2011
MEMORANDUM
To: Dr. Mina Shehee
Epidemiology Section
DHHS - Division of Public Health
1912 Mail Service Center
Raleigh, NC 27699-1219
From: David Goodrich
Hydrogeologist
Subject: Health Risk Evaluation Request
Trap & Treat Bacteria Concentrate by RPI (Remediation Products, Inc.)
Please conduct a health risk evaluation of the subject product, which is intended to be injected via
wells for enhanced degradation of groundwater contaminated with Number 2 Fuel Oil associated with
aviation activity.
The following contact can provide additional information to aid your review of the subject product:
c Advanced Microbial Systems, Inc., ph# 918-246-9733, can provide you with additional
chemical information and additional information about site specific use of the subject product.
Please contact me by telephone at 919-715-6162 or email at david.eoodrichna ncdenr.gov if you need
any other information to aid your review.
Attachments
AQUIFER PROTECTION SECTION
1636 Mail Service Center, Raleigh, North Carolina 27699-1636
Location: 2728 Capital Boulevard, Raleigh, North Carolina 27604
Phone: [phone] FAX 1: 919-715-0588; FAX 2: 919-715-6048 i Customer Service: 1-877-623-6748
Internet: vnw✓.ncwateraualitv.orq
An Equal Opportunity 1 Affirmative Action Employer
Nor thCarolini.
Naturally

2,
North Carolina Department of Health and Human Services
Division of Public Health • Epidemiology Section
1912 Mail Service Center • Raleigh, North Carolina 27699-1912
Tel [phone] • Fax [phone]
Michael F. Easley, Governor
October 13, 2006
MEMORANDUM
TO:. Qu Qi
Underground Injection Control Program
Aquifer Protection Section
FROM: Luanne K. Williams, Pharm.D., Toxicologist ptkur—
Medical Evaluation and Rislc Assessment Unit
Occupational and Environmental Epidemiology Branch
North Carolina Department of Health and Human Services
SUBJECT: Use of a Non -Biological Product BOS 100® to Enhance Biodegradation of
Groundwater Contaminated with Chlorinated Compounds and a Biological
Product BOS 200® for Remediation of Groundwater Contaminated with
Hydrocarbons
Carmen IIooker Odom, Secretary
RECEIVED 1 DENR I DWQ
AQUIFER'PRn7FCTION SECTION
OCT 2 01006
I am writing in response to a request for a health risk evaluation regarding the use of use
of a non -biological product BOS 100® to enhance biodegradation of groundwater contaminated
with chlorinated compounds and a biological product BOS 200® for remediation of groundwater
contaminated with hydrocarbons. Based upon my review of the information submitted, I offer
the following health risk evaluation:
PRECAUTIONS DURING APPLICATION
1. The microorganisms in BOS 200® are naturally found in soil. These microorganisms are not
ordinarily associated with infection in healthyhumans (except through an existing wound).
However, these microorganisms may cause infection in the young, the aged, and
immunocompromised such as individuals with AIDS, cancer, hepatitis, or with individuals
following dialysis or surgical procedures. In addition, some of the ingredients within the
BOS 100® product have been known to cause eye and skin irritation.
If the products are 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 it is
imperative that proper personal protective equipment be used. The application process
should be reviewed by an industrial hygienist to ensure that the most appropriate personal
protective equipment is used.
Location: 5505 Six Forks Road, 2nd Floor, Room al • Raleigh, N.C. 27609
An Equal Opportunity Employer

3. Persons working with this product should at least wear goggles or a face shield, gloves, and
protective clothing. Face and body protection should be used for anticipated splashes or
sprays. Again, consult with an industrial hygienist to ensure proper protection.
4. Eating, drinking, smoking, handling contact lenses, and applying cosmetics should never be
permitted in the application area during or immediately following application. 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 adverse reactions and
injuries.
6. Access to the area of application should be limited to the workers applying the product. In
order to minimize exposure to unprotected individuals, measures should be taken to prevent
access to the area of application.
7. Efforts should be made to prevent contamination of existing or future wells and surface water
that may be located near the application area.
Please do not hesitate to call me if you have any questions at [phone].
cc: Scott Noland
Remediation Products, Inc.
6390 Joyce Drive
Suite 150 West
Golden, CO 81403