WI0700012_Permit (Issuance)_20080212

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Permit Number WI0700012
Central Files: APS SWP
02/12/08
Permit Tracking Slip
Program Category Status Project Type
Ground Water In review Renewal
Permit Type Version Permit Classification
Injection Other Wells (5Z) Individual
Primary Reviewer
michael.rogers
Permitted Flow
Facility
Permit Contact Affiliation
D
PO Box 48
Aurora
Winstead, III, Engineer
Environmental
NC 27806
Facility Name
PCS Phosphate Company, Inc.
Location Address
1530 Hwy 306 S
Aurora
Owner
NC 27806
Major/Minor Region
Minor Washington
County
Beaufort
Facility Contact Affiliation
Owner Name
PCS Phosphate Company Inc
es/Events
Owner Type
Non -Government
Owner Affiliation
Brent Heimann
PO Box 48
Aurora
NC 27806
Orig Issue App Received Draft Initiated Scheduled
Issuance
12/05/91 09/07/07
Public Notice
Issue
ts-ik
Effective Expiration
Regulated Activities Requested/Received Events
RO staff report requested
RO staff report received
Unknown 00
Outfall NULL
09/14/07
10/11/07
Waterbody Name
Stream Index Number Current Class Subbasin

Michael F. Easley, Govemor
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
s
Coleen H. Sullins. Director
Division of Water Quality
February 5, 2008
PCS Phosphate Company, Inc.
Attn: Mr. D. Daniel Winstead, III
1530 Hwy 306 South
Aurora, NC 27806
Re: Issuance of Injection Well Permit
Permit No. WI0700012
Issued to PCS Phosphate Company, Inc.
Dear Mr. Winstead:
In accordance with your application received September 7, 2007, I am forwarding Permit No.
WI0700012 for the operation of a type 5Z injection well system to be located at 1530 Hwy 306
South, Aurora, NC 27806. This permit shall be effective from the date of issuance until January
31, 2013, and shall be subject to the conditions and limitations stated therein.
In order to continue uninterrupted legal use of this well for the stated purpose, you should submit
an application to renew the permit three (3) months prior to its expiration date. As indicated in
the permit, this permit is not transferable to any person without prior notice to, and approval by,
the Director of the Division of Water Quality. If you have any questions regarding your permit
or the Underground Injection Control Program please call Mr. Qu Qi at [phone] or me at
[phone].
Best Regards,
Michael Rogers
Environmental Specialist
cc: David May — Washington Regional Office
Central Office File — WI0700012
Attachment(s)
Aquifer Protection Section 1636 Mail Service Center Raleigh, NC 27699-1636
Internet: http://www.ncwaterqualitv.org 2728 Capital Boulevard Raleigh, NC 27604
An Equal Opportunity/Affirmative Action Employer— 50% Recycled/10% Post Consumer Paper
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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
PCS Phosphate Company, Inc.
FOR THE OPERATION OF A TYPE 5Z INJECTION WELL SYSTEM, defined in Title 15A
North Carolina Administrative Code 2C .0209(e)(3)(C), consisting of 7 injection wells for the
purpose of injecting water to control migration of contaminated groundwater. This well system
is located in the Tank Farm area at PCS Phosphate Company Inc., Aurora, North Carolina, in
Beaufort County, and will be operated in accordance with the application dated September 7,
2007, 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 January 31,
2013, and shall be subject to the specified conditions and limitations set forth in Parts I through
IX hereof.
Permit issued this the 1iday of th*De"Zs , 2008.
Coleen H. Sullins, Director
Division of Water Quality
By Authority of the Environmental Management Commission.
Permit No. WI0700012 Page 2

PART I - WELL CONSTRUCTION GENERAL CONDITIONS
1. The Permittee 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. 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.
3. Each injection well shall be afforded reasonable protection against damage during
construction and use.
4. Each injection well shall have permanently affixed an identification plate.
5. This permit is effective only with respect to the nature, volume of materials and rate of
injection, as desdribed in the application and other supporting data.
6. 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.
7 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 II — 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.
Permit No. WI0700012 Page 3

P .
•
PART III - 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.
PART IV — 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 terms 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 V — MONITORING AND REPORTING REQUIREMENTS
SECTION A
1. 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 report by telephone, within 48 hours of the occurrence or first
knowledge of the occurrence, to the Washington 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.
3. 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
Permit No. WI0700012 Page 4

to the Director, the Permitteek shall 'promptly submit the relevant and correct facts or
information to the Director.
4. In the event that the permitted facility fails to perform satisfactorily, the Permittee shall
take such immediate action as may be required by the Director.
SECTION B
1. The Permittee shall collect samples from the riser pipe of CIW7 (fluid to be injected into
last injection well in line) and from monitoring well MWTF-1CR (groundwater from the
Croatan formation) every January, April, July, and October for the following parameters:
Total Coliform Organisms
The Permittee shall collect samples from the riser pipe of CIW7 (fluid to be injected into
last injection well in line) and from monitoring well MWTF-1CR (groundwater from the
Croatan formation) every April and October for the following parameters:
Total Dissolved Solids Cadmium
Total Organic Carbon Chromium
Chloride Manganese
Fluoride Sulfate
pH Total Phosphorous
The results of the sampling and analysis shall be submitted on Form GW-59
(Compliance Monitoring Report Form) every February, May, August, and November to:
NCDENR - Division of Water Quality
Aquifer Protection Section
UIC Program
1636 Mail Service Center
Raleigh, NC 27699-1636
and to
NCDENR Washington Regional Office
Division of Water Quality
APS - Groundwater Section
943 Washington Square Mall
Washington, NC 27889.
2. Provisions shall be madefor collecting samples of the injection well system supply water,
both prior to its entrance to treatment devices and subsequent to leaving the treatment
devices but before entering the injection well.
3. The Permittee shall report any monitoring or other information which indicates that any
contaminant may cause an endangerment to an underground source of drinking water and
any noncompliance with a permit condition or malfunction of the injection system which
Permit No. WI0700012 Page 5

may cause fluid migration outside the injection' dine or area of review. The information
shall be provided to the Regional Office orally within 24 hours of the occurrence and as a
written submission within five days of the occurrence. The written submission shall
contain a description of the noncompliance and its cause, the period of noncompliance,
including exact dates and times, and if the noncompliance has not been corrected, the
anticipated time it is expected to continue and any steps taken or planned to reduce,
eliminate, and prevent recurrence of the noncompliance.
4. The Permittee shall retain copies or records of all monitoring information, including all
calibration and maintenance records, all original strip chart recordings for continuous
monitoring instrumentation and copies of all reports required by this permit, for a period
of at least 3 years from the date of the sample, measurement, report, or application.
Records of monitoring information shall include but not be limited to:
(A) the date, exact place, and time of sampling or measurements;
(B) the individual(s) who performed the sampling or measurements;
(C) the date(s) analyses were performed;
(D)the individual(s) who performed the analyses;
(E) the analytical techniques or methods used; and
(F) the results of any such sampling, measurements, and analyses
PART VI — PERMIT RENEWAL
The Permittee shall, at least three (3) months prior to the expiration of this permit,
request an extension.
PART VII — 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 .0214, including but not limited to the following:
(A) All casing and materials may be removed prior to initiation of abandonment
procedures if the Director finds such removal will not be responsible for, or
contribute to, the contamination of an underground source of drinking water.
(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.
Permit No. WI0700012 Page 6

(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.
(D)Drilled wells shall be completely filled with cement 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 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 VII (1) and (2) (G) shall be submitted to:
NCDENR - Division of Water Quality
Aquifer Protection Section
UIC Program
1636 Mail Service Center
Raleigh, NC 27699-1636
PART VIII — SPECIAL CONDITIONS
1. The quality of the injected water will not exceed the given concentrations for the
following parameters:
Total Dissolved Solids: 500.0mg/L
Total Organic Carbon: 10.0mg/L
Chloride:55.0mg/L
Fluoride: 1.0mg/L
Total Phosphorous: 0.15mg/L
Total Coliform Organisms: 1/100m1
Cadmium: 0.005mg/L
Chromium: 0.05mg/L
Manganese: 0.05mg/L
Sulfate:50.0mg/L
2. The pH of the injected water will be between 6.5 and 8.5 standard units.
3. The temperature of the injected fluid will not exceed 35.5° C (96° F).
4. The injected water shall consist of depressurization well (DPW) water treated
multi -media anthracite/sand filter and an ultraviolet light treatment tube system.
with a
Permit No. WI0700012
Page 7

LIVISION OF WATER QUALITY
AQUIFER PROTECTION SECTION
February 11, 2008
MEMORANDUM
TO: DEBRA WATTS
THROUGH: QU QI
FROM: MICHAEL ROGERS (
A
N
RE: Recommendation for the Issuance of UIC Permit WI0700012
I have reviewed the subject permit application, and I am recommending the permit be re -issued
with the following comments:
1. Site History/Overview: This facility processes phosphate to produce phosphoric acid
(PA). In the late 1980s to early 1990s one of the tanks in the tank farm area holding PA
leaked and leached into the surficial and Croatan aquifers resulting in a plume on the
north side of the plant. A groundwater remediation plan was approved by DWQ in 1990
and a UIC permit issued 1991.
2. Site Geology: The surficial aquifer extends from land surface to approximately 27 to 31
feet below land surface (BLS), and is predominately sand, clay, and gravel. The Croatan
lies below surficial deposits, extends to 47 to 53 feet BLS, and consists of sand and shell.
3. Remediation/Injection System: The permitted remediation system consists of several
water supply, injection, withdrawal, and monitoring wells. The supply water (source) for
the remediation injection system currently consists of pumping groundwater out of the
Castle Hayne limestone (180 to 280 BLS) at a surface mine located several miles away
and piping it to the facility. The water is treated by an anthracite/sand filter and ITV and
then injected into the Croatan aquifer south of the plume via injection wells CIW-1
ough CIW-7. A mounding effect occurs and pushes water northwards toward
withdrawal wells located along the north side of the plant. The withdrawal wells installed
in the surficial aquifer (SWW-1 through SWW-7) and the Croatan aquifer (CWW-1
through CWW-7) in turn pumps out contaminated water that has moved through the
plume (the plume is located between the injection wells on the south and the withdrawal
wells on the north). Water from the withdrawal wells is then dischar • ed iitto rocess
Bonds located on -site (refer to Attachment V, Figure 1). This remediation plan results in
`flus 'ng) out contaminates in the groundwater in the area of the tank farm. The amount
of water pumped into the injection wells and withdrawn for the second quarter of 2007 is
included in Attachment VI.
4. Monitoring: There are 3 clusters of monitoring wells on -site. Each cluster consists of 3
wells installed at various depths in the surficial and Croatan aquifers. One cluster of
monitoring well is located near the injection wells (MWTF-1) and 2 clusters of
monitoring wells are located along the slurry wall next to the tanks on the north side
(MWTF-2 and MWTF-3). Samples collected from MWTF-1 on April 24_, 2007,indicate
jaLall-ameters meet permit requirements prior to water being injected into the aquifer

(refer to Attachment 1,page 3). The 2 other clusters are used to sample water being
discharged into the process ponds.
5. Epidemiology: Only groundwater being treated by anthracite/sand filter and UV is being
inj ected.
6. Regional Office Comments: The Washington Regional Office provided a staff report
and recommended re -issuance of the permit.
Please let me know if you have any questions, comments, or concerns about issuing this
permit.