WI0700012_Correspondence_20170929

Project Interim Evaluation
RECENEDINCDEQ/D► R
SEP292017
Water duality Regional
Operations SNction
Injection Permit WI0700012 was originally requested to support the PCS Phosphate Tank Farm Remedial
Action System. This system was designed in response to a May 1988 leak incident involving Tank 008.
Figure 1 shows a plan view of the Tank Farm Area Remedial Action System.
The Croatan Formation injection well system was designed to operate with the water level in the
injection wells at Elevation 12 to 15 feet (MSL) and the water level between the withdrawal wells at
Elevation -1 feet (MSL). The injection system was designed to operate at 19 gpm, with flows varying
from about 4 gpm at the two end wells (CIW-1 and CIW-7) to about 2 gpm at the center well (CIW-4).
The withdrawal well system was designed to operate at 6 gpm, with flows varying from about 3/ gpm at
the center well (CWW-4) to about 1 gpm at the two end wells (CWW-1 and CWW-7). Figure 2 shows a
profile of the withdrawal wells where Figure 3 shows a profile of the injection wells.
Potentiometric surface studies of the Croatan Formation have shown that the injection / withdrawal
well system is operating satisfactorily to capture groundwater within the limits of the tank farm. The
withdrawal wells also capture groundwater from north of the tank farm and from beyond the east and
west ends of the line of withdrawal wells. The injected fresh water flows northward toward the
withdrawal wells as well as southward and radially outward from the two ends wells (CIW-1 and CIW-7).
About one-third to one-half of the injected water is captured by the withdrawal wells. The remaining
injection water flows away, mostly southward, from the tank farm.
The water level in the Croatan Formation is lower than the water level in the overlying aquifers, and
hence, groundwater in the Croatan Formation cannot migrate upward into overlying aquifers. The
injection well system has caused the potentiometric water level in the Croatan Formation below the
tank farm to rise by about 1 to 4 feet. The hydraulic head difference between the Croatan Formation
and underlying Castle Hayne aquifer, across the 100-foot thick Yorktown-Pungo River aquitard, has
typically been between 20 and 30 feet in the tank farm area. Hence, the small rise in the potentiometric
water level in the Croatan Formation of 1 to 4 feet is minor in comparison to the prevailing hydraulic
head difference across the aquitard, and did not result in an appreciable increase in the amount of
downward recharge toward the Castle Hayne aquifer. Operation of the injection well system, therefore,
has not caused any significant migration of groundwater from the Croatan Formation into other
overlying or underlying aquifers.
The injection/withdrawal well system is being operated such that the zone of capture of the withdrawal
wells encompasses the tank farm. Hence, groundwater below the tank farm cannot mig e into
previously uncontaminated portions of the Croatan Formation. Groundwater at the line of injection
wells, prior to operation of the system, was not impacted by spills/leaks from the tank farm. Hence,
groundwater initially abutting the south sider of the tank farm that was caused to flow away from the
tank farm by the injection wells, and not captured by the withdrawal wells, was not contaminated. The
injection wells, therefore, did not cause contaminants in the Croatan Formation below the tank farm to
migrate horizontally into previously uncontaminated portions of the formation. Figure 4 shows the
phosphorous concentration of the Surficial Withdrawal Wells over time. Figure 5 shows the
phosphorous concentration of CWW-1, CWW-3 and CWW-7.

Michael F. Easley, Governor
William G. Ross Jr., Secretary
CO lN� {f ,l, North Carolina Department of Environment and Natural Resources
-c
Coleen H. Sullins Director
Division of Water Quality
August 16, 2007
R. M. Smith
PCS Phosphate Company, Inc.
PO Box 48
Aurora, NC 27806
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
7006 2150 0003 5466 5376
Subject: Notice of Expiration
UIC Permit No. WI0700012
PCS Phosphate Company, Inc.
Beaufort County
Dear Mr. Smith:
The Underground Injection Control (UIC) Program of the Division of Water Quality is
responsible for the regulation of injection well construction and operation activities within the
state of North Carolina. Our records show that the operating permit referenced above for the
geothermal heat pump injection well system on your property at 1530 Highway 306 South in
Aurora, North Carolina will expire on January 15, 2008. In addition, our records do not indicate
that the injection well system has been abandoned.
In order to comply with the regulatory requirements listed under North Carolina Administrative
Code (NCAC) Title 15A, Subchapter 2C, Section .0211, you must take one of the following
actions:
A. Submit the form RENEWAL APPLICATION FOR PERMIT TO USE WELL (S) FOR INJECTIONWITH A
HEAT PUMP SYSTEM (form G W/UIC-57 HPR) if the injection well system on your
property is still active;
B. Submit the form STATUS OF INJECTION WELL SYSTEM (form GW/UIC-68) if the injection
well system is inactive or has been temporarily or permanently abandoned..
If the injection well system is no longer being used for any purpose, it must be permanently
abandoned according to the regulatory requirements listed under NCAC Title 15A, Subchapter
2C, Section .0214. If the injection well system is to be permanently abandoned, the well
abandonment record(s) must be submitted to our office to certify that the abandonment was
Cloy` Caroma
�turatly
Aquifer Protection Section 1636 Mail Service Center Raleigh, NC27699.1636 Telephone: [phone].
Internet www.ncwaternualitv.org Location:. 2728 Capital Boulevard Raleigh, NC27604 Fax I: [phone]
PBX 2: [phone]
An Equal OpporhlnitylAffirmative Action Employer 50% Recycled110% Post Consumer Paper Customer Service: [phone]

properly conducted. If the injection well system is still active, a renewal application is to be
submitted at least 5 months prior to the expiration of this permit.
Please submit the appropriate form(s) within 30 calendar days of the receipt of this letter. If you
have any questions regarding the permit or injection well rules, or if you would like assistance
completing these forms please call Qu Qi at [phone], or email him at au.ei@a,ncmail.net.
Sincerely,
A /0
Gregory/Njwolfe OA III
Aquifer Protection Section
Enclosures
1. GW/UIC-57 OTH
2. cwnnC-68
cc: Washington Regional Office - APS w/o enclosures
APS Central Files - Permit. No. WI0700012 w/o enclosures

Certified Mail
August 27, 2012
Thomas Slusser
UIC Program Manager
NCDENR - WATER QUALITY
1601 Mail Service Center
Raleigh, N. C. 27699-1601
Re: Renewal Request:
Permit WI 0700012
PCS Phosphate Inc. - Beaufort County
Dear Thomas:
Please find enclosed:
1. Permit No. WI0700012
2. E-mail series between William Hart, Michael Rogers and Thomas Slusser.
As instructed in the E-mail series, PCS is requesting renewal of Permit No. WI0700012.
We are requesting no changes to the current permit. The injection well is operated as part
of our Tank Farm Remedial Action System. Should you need to contact me concerning
this request, I can be reached as follows:
Phone [phone]
Ce11 252-402-5459
E-mail [e-mail]
Sincerely,
D. Daniel Winstead III
Environmental Engineer
PCS Phosphate
C:\Users\srshresthaWppDatatLocal\Microsoft\Windows\Temporary Internet Files \Content.Outlook\YCJ3IQOY\TFRAS Injection
Well Permit.docx

pc:
R. M. Smith / 12-07-00
Mike Brom
Will Hart WaRO
CAUsers\srshrestha\AppData\Local \Microsoft\Windows\Temporary Internet Files\Content.Outlook\YCJ3IQOY\TFRAS Injection
Well Permit.docx

PotashCorp®
Helping Nature Provide
Certified Mail
August 27, 2012
Thomas Slusser
UIC Program Manager
NCDENR - WATER QUALITY
1601 Mail Service Center
Raleigh, N. C. 27699-1601
Re: Renewal Request:
Permit WI 0700012
PCS Phosphate Inc. - Beaufort County
Dear Thomas:
Please find enclosed:
RECEIVEDIDENRIDWQ
SEP 0 7 2012
Aquifer Protection Section
1. Permit No. WI0700012
2. E-mail series between William Hart, Michael Rogers and Thomas Slusser.
As instructed in the E-mail series, PCS is requesting renewal of Permit No. WI0700012.
We are requesting no changes to the current permit. The injection well is operated as part
of our Tank Farm Remedial Action System. Should you need to contact me concerning
this request, I can be reached as follows:
Phone [phone]
Cell 252-402-5459
E-mail [e-mail]
Sincerely,/6)
L i2r
D. Daniel Winstead III
Environmental Engineer
PCS Phosphate
H:\State correspondence\20121TFRAS Injelgt ,_3QQ� iIQQy� h, Aur NC USA 27806 T (252) 3I2.4111
PCS �F �riSww potaskorp.com

pc:
R. M. Smith / 12-07-00
Mike Brom
Will Hart WaRO
H:\State Cortespondence\20I2\TFRAS Injection Well Pennit.docx

"Hart, William" <[e-mail]>
05/08/2012 03:54 PM
To "[e-mail]" <[e-mail]>
cc
bcc
Subject FW: WI0700012 - PCS Tank Farm
History:
F This message has been replied to.
Hello, Danny. Hope you've had a nice break from the mine. I hope this will answer your question concerning your permit renewal. Please don't
hesitate to contact me if there is anything I can help with.
w
From: Slusser, Thomas
Sent: Tuesday, May 08, 2012 3:04 PM
To: Rogers, Michael; Hart, William
Subject: RE: WI0700012 - PCS Tank Farm
Just have PCS send a letter requesting renewal of their permit as long as there are no changes being requested. The old 5Z "other injection
wells" form was removed from the website because it is outdated and is no longer relevant under the new 02C .0200 rules. If they are
requesting any modification of the existing permit then let me know and we can figure out how best to address it under to the new rules.
Thomas.
NOTE: Our offices have moved. The mailing address remains the same, but my new telephone number, fax number, and physical
address are as follows:
ph" 919-807-6412 I fax" 919-807-6480
Physical Address: Room 640M, Archdale Building, 512 N. Salisbury St., Raleigh, NC 27604.
f-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be disclosed to third parties unless the content Is exempt by statute or other regulation
From: Rogers, Michael
Sent: Monday, May 07, 2012 1:56 PM
To: Hart, William; Slusser, Thomas
Subject: RE: WI0700012 - PCS Tank Farm
Thomas-

See below. For a 5Z renewal, would they use the groundwater remediation application I reference below or some other alternative? Hit reply all.
Thanks
Michael Rogers, P.G. (NC & FL)
Environmental Specialist
NC Div of Water Quality- Aquifer Protection Section (APS)
1636 Mail Service Center
Raleigh, NC 27699-1636
Direct Line 919-807-6406
htto://portal.ncdenr.oro/web/wqlaps/owpro/permit-applications#geothermApps
E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be disclosed to third parties
From: Hart, William
Sent: Monday, May 07, 2012 10:57 AM
To: Rogers, Michael
Subject: RE: WI0700012 - PCS Tank Farm
My question was if that was the correct form. The project (5Z — Other) does not involve injection of remediation additives or in -situ
remediation. Groundwater is extracted from one aquifer and injected into the contaminated aquifer; groundwater is likewise extracted from
the contaminated aquifer and routed through the process for removal of sulfur. Extraction and injection are used to control migration of the
plume.
From: Rogers, Michael
Sent: Monday, May 07, 2012 10:42 AM
To: Hart, William
Subject: RE: WI0700012 - PCS Tank Farm
Click on link below, then open Permit App for inj of remediation additives.
Michael Rogers, P.G. (NC & FL)
Environmental Specialist
NC Div of Water Quality- Aquifer Protection Section (APS)
1636 Mail Service Center
Raleigh, NC 27699-1636
Direct Line 919-807-6406

http://portal.ncdenr.orq/web/walaps/gwpro/permit-applications#geothermApps
E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be disclosed to third parties
From: Hart, William
Sent: Monday, May 07, 2012 8:45 AM
To: Rogers, Michael
Cc: DWinstead©pcsphosphate.com
Subject: WI0700012 - PCS Tank Farm
Hello Michael, I got an email from Mr. Danny Winstead, PCS Aurora about renewing the permit referenced. Mr. Winstead is seeking the correct
application form to begin the renewal process. This permit is a Type 5Z and the forms/applications page on the website directs users to the UIC
staff. I think you processed the 2008 renewal. Can you help me help Danny? Thank you.
Will Hart, Hydrogeologist
Division of Water Quality/Aquifer Protection Section
Washington Regional Office
943 Washington Square Mall
Washington, NC 27889
[e-mail]
Telephone: [phone]
Fax: [phone]
E-mail correspondence to and from this address may be subject to the North Carolina Public,?ecards Law and may be disclosed to third parties

Michael F. Easley, Governor
William G. Ross Ir., Secretary
North Carolina Department of Environment and Natural Resources
Coleen H. Sullins Director
Division of Water Quality
August 16, 2007
R. M. Smith
PCS Phosphate Company, Inc.
PO Box 48
Aurora, NC 27806
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
7006 2150 0003 5466 5376
Subject: Notice of Expiration
UIC Permit No. WI0700012
PCS Phosphate Company, Inc.
Beaufort County
Dear Mr. Smith:
The Underground Injection Control (UIC) Program of the Division of Water Quality is
responsible for the regulation of injection well construction and operation activities within the
state of North Carolina. Our records show that the operating permit referenced above for the
geothermal heat pump injection well system on your property at 1530 Highway 306 South in
Aurora, North Carolina will expire on January 15, 2008. In addition, our records do not indicate
that the injection well system has been abandoned.
In order to comply with the regulatory requirements listed under North Carolina Administrative
Code (NCAC) Title 15A, Subchapter 2C, Section .0211, you must take one of the following
actions:
A. Submit the form RENEWAL APPLICATION FOR PERMIT TO USE WELL(S) FOR INJECTION WITHA
HEAT PUMP SYSTEM (form GW/UIC-57 HPR) if the injection well system on your
property is still active;
B. Submit the form STATUS OF INJECTION WELL SYSTEM (form GW/UIC-68) if the injection
well system is inactive or has been temporarily or permanently abandoned.
If the injection well system is no longer being used for any purpose, it must be permanently
abandoned according to the regulatory requirements listed under NCAC Title 15A, Subchapter
2C, Section .0214. If the injection well system is to be permanently abandoned, the well
abandonment record(s) must be submitted to our office to certify that the abandonment was
No" Carolina
,Naturally
Aquifer Protection Section 1636 Mail Service Center Raleigh, NC 27699-1636 Telephone: [phone]
Internet: www.ncwaterqualitv.orp Location:. 2728 Capital Boulevard Raleigh, NC 27604 Fax 1: [phone]
Fax 2: [phone]
An Equal Opportunity/Affirmative Action Employer-50%Recycled/10% Post Consumer Paper Customer Service: [phone]

properly conducted. If the injection well system is still active, a renewal application is to be
submitted at least 5 months prior to the expiration of this permit.
Please submit the appropriate form(s) within 30 calendar days of the receipt of this letter. If you
have any questions regarding the permit or injection well rules, or if you would like assistance
completing these forms please call Qu Qi at [phone], or email him at qu.gi(a ncmail.net.
Sincerely,
Gregory/N.
olfe OA III
Aquifer Protection Section
Enclosures
1. GW/UIC-57 OTH
2. GW/UIC-68
cc: Washington Regional Office - APS w/o enclosures
APS Central Files - Permit No. W10700012 w/o enclosures