WI0500329_Permit (Issuance)_20170914

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
Peden Family, LLC I & II
FOR THE OPERATION OF THREE (3) EXISTING TYPE 5I INJECTION WELLS, AND THE
CONSTRUCTION AND OPERATION OF FIVE (5) TYPE 51 INJECTION WELLS, as defined
in Title 15A North Carolina Administrative Code 2C .0209(e)(3)(C), to inject Aerosol OT-75
surfactant (ethyl alcohol and dioctyl sodium, sulfosuccinate), for the emulsification,
encapsulation and desorption of gasoline and diesel fuel. A second phase of injection is also
allowed, if needed, consisting of the injection of PermeOx Plus (calcium peroxide and calcium
hydroxide) for the oxidation and enhanced bioremediation of remaining gasoline and diesel fuel.
:These injection wells/points will be located at the property owned by the Peden Family at 1859
Capital Boulevard, Raleigh, Wake County, North Carolina, and will be operated in accordance
with the application submitted November 29, 2010, and in conformity with the specifications and
supporting data submitted an March 1, 2011, 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 February 29,
2012, and shall be subject to the specified conditions and limitations set forth in Parts I through
X hereof.
Permit issued this the 14th day of , 2011.
orz Coleen H. Sullins, Director
Division of Water Quality
By Authority of the Environmental Management Commission.
Permit No. WI0500329 PAGE 1 OF 7
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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
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 constructions 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 shallbe afforded reasonable protection against damage during
construction 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 Program
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 Permittee shall notify
the Aquifer Protection Section -Underground Injection Control (UIC) Central Office staff,
telephone number [phone] and the Raleigh Regional Office Aquifer Protection Section
Staff, telephone number [phone].
Permit No. WI0500329 PAGE 2 OF 7
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PART III - OPERATIONN 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
Permitteeshall 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 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 [phone]. 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.
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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 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. 8'7-90.
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. Monitoring wells MW-4, MW-5, MW-7 and MW-8 shall be sampled for liquid levels, pH,
temperature, specific conductance or ORP, Volatile Organic Compounds, and Total Lead
before the first injection event.
2.
.The proposed monitoring plan included in the application shall be followed, with quarterly
monitoring continuing for at lgast one year after the completion of the second injection event,
if that event takes place. Changes to this plan are as follows. Monitor well MW-7 will be
sampled quarterly for liquid level, Volatile Organic Compounds, and Total Lead. Monitor
wells MW-1, MW-1R, and MW-9 shall have a baseline sampling event prior to the second
injection event that will include sampling for Total Lead, and have two post -injection
quarterly sampling events that will also include Total Lead. All sample results shall be
submitted to the Aquifer Protection Section's Raleigh 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 ensure surface and ground water
protection, will be established and an acceptable sampling reporting schedule shall be
followed.
3. The Permittee shall submit an Injection Event Record within 30 days of completing each
injection.
4. 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.
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5. The monitoring results and the final project evaluation shall be submitted to:
Aquifer Protection Section-UIC Program
DENR-Division of Water Quality
1636 Mail Service Center
Raleigh, NC 27699-1636
and to:
Aquifer Protection Section
DENR-DWQ Raleigh Regional Office
3800 Barrett Drive
Raleigh, NC 27609
6. The Permittee shall report by telephone, within 48 hours of the occurrence or first knowledge
of the occurrence, to the Raleigh 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.
7. 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.
8. 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.
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 .0214, 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:
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(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.
(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 Program
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 products proposed to be used are as follows:
eye, skin, nose, throat, and lung irritation. If either 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. The product ingredients and reaction products are strong oxidizing agents that can be a fire
and explosion hazard when mixed with finely divided reducing agents such as organic matter
or when exposed to heat. These products may ignite combustibles such as wood, paper, oil,
or clothing. Caution must be taken to keep these products away from combustibles, and to
keep combustibles away from spilled material.
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3. 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.
4. Only workers who are properly outfitted with protective gear as described herein shall
participate in the application procedure, and only workers shall be allowed access to the work
area. In order to minimize exposure to unprotected individuals, measures should be taken to
prevent access to the area of application.
5. Precautions shall be taken to prevent the product from contaminating existing or future wells
that may be located near the application area.
6. Eating, drinking, smoking, handling contact lenses, and applying cosmetics should not be
permitted in the application area during or immediately following application.
7. Safety controls should be in place to ensure that the check valve and the pressure delivery
systems are working properly.
8. Runoff may create a fire or explosion hazard. Precautions should be taken to prevent runoff.
9. The Material Safety Data Sheets should be followed to prevent incompatible or adverse
reactions and injuries.
Permit No. WI0.500329 PAGE 7 OF 7
ver. Oct.2010 . AP/UIC-6

DIVISION OF WATER QUALITY
AQUIFER PROTECTION SECTION
March 9, 2011
PERMIT ISSUANCE MEMO
TO: Debra Watts (\
THROUGH: Thomas Slusser
FROM: David Goodrich
RE: Permit To Inject Aerosol OT-75 and PermeOx Plus
Peden Family , LLC Facility
I recommend that Permit Number WI0500329 be issued to Peden Family, LLC I & II to inject Aerosol OT-75
and PermeOx Plus to remediate soils and groundwater contaminated with gasoline and diesel fuel. The first
injectant substance, Aerosol OT-75, is primarily a surfactant that is intended to liberate the hydrocarbons for
subsequent pump -out removal. After this phase is completed, if necessary, an oxidizing injectant, PermeOx
Plus, shall be injected to facilitate the . destruction of the remaining hydrocarbon substances through oxidation
and bioremediation under aerobic microbial respiration.
SITE DESCRIPTION The site is flat and in an industrial area of Raleigh. The contamination originated from
leaking underground storage tanks that were closed in March of 2000. Fluid and vapor recovery has taken place
at the site, and free product is still present in the proposed injection area, removing more than 120 gallons of
product.
HYDROGEOLOGIC DESCRIPTION Geologically, the site is located in the Raleigh Belt. Surficial material
consists of unconsolidated sediments of varying thickness overlying a basement rock of Cenozoic gneiss, biotite
gneiss, and schist intruded by volcanic rocks which in the granite family. The site itself has a surface layer of
primarily sandy silt that is approximately 15 to 25 feet in thickness, overlying a weathered saprolite that is
approximately 5 to 15 feet in thickness, and underlain by bedrock consisting of biotite gneiss and schist. Ground
water is typically encountered at a depth of 30 to 35 feet below ground level with a seasonal high water table
elevation of approximately 24 feet below ground level. The measured hydraulic gradient is approximately 1 %,
or 1 foot in 100. Based on the information provided and an assumed effective porosity of 0.15 and values of
hydraulic conductivity furnished in the permit application, groundwater velocity in the subsurface materials
potentially varies from 0.2 inches per month to 1.6 feet per day.
EXTENT OF CONTAMINATION The affected area is approximately 100 feet wide and 200 feet long, and
is oriented parallel to the axis of natural groundwater flow, extending north by northeast from the former UST
area, as indicated on Figure 5 in Attachment G and on Figures 4A and 4B in. Attachment H. The depth of
contamination is difficult to estimate, but is thought to extend into the fractures of the underlying bedrock, as
indicated in Figure 5B, and thus attain a total thickness of more than 30 feet in the saturated zone.
PROPOSED INJECTION The first phase injectant, Aerosol OT-75, is primarily a surfactant, and the
second phase injectant, PermeOx Plus, is an oxidant. Three existing monitoring wells (MW-1, MW-9, and MW-
10) and five proposed permanent injection points (PZ-1, PZ-2, PZ-3, PZ-4, and PZ-5) will be used for injection.
The injection will be followed by groundwater extraction at all of these wells and injection points, and also at
monitoring well MW-1R. Depending on the effectiveness of this operation, as measured by the possible return
of free product to the monitor wells, the procedure may be repeated. After approximately 90 days have passed, a
second phase may take place, if needed (as evidenced by the re -appearance of free product or of hydrocarbon
contaminants at concentrations above the North Carolina Gross Contaminant Levels), that will consist of a
single injection event that will inject the oxidant through the same three monitoring wells and five injection

points. The total proposed injection volumes are 6,800 gallons for Aerosol OT-75 during the first phase and
1,400 gallons of PermeOX Plus during the second phase. Assuming an effective porosity of 0.15 in the shallow
unconsolidated saturated zone, the first phase injection would occupy a volume of 6,060 cubic feet. A thickness
of five feet in this zone would produce an area of 35 feet squared for the first phase injection and 16 feet squared
for the second phase. These figures represent approximately 6% and 1 % of the entire affected volume of the
subsurface, but a significantly higher percentage of the area of most concentrated contamination
HOW IT WORKS The first phase injectant, Aerosol OT-75, serves as a surfactant to free the hydrocarbon
contaminants from the soil particles and allow them to be transported by the ground water. The second phase
injectant, PermeOx Plus, serves as an oxidant which supports degradation of the hydrocarbons through direct
oxidation and supports natural bioremediation under aerobic microbial respiration.
MONITORING The original monitoring plan calls for obtaining liquid levels (depth to water) in ten
monitoring wells and the five injection points at 30 days post injection, 60 days post injection, and then
quarterly (after 60 days have passed without a rebounding of free product or of dissolved constituents above the
North Carolina Gross Contaminant Levels), until such time as four consecutive quarters of sample data indicate
no measurable free product and no dissolved constituent concentrations above the North Carolina Gross
Contaminant Levels. Only liquid levels will be taken during each sampling event at monitoring wells MW-1,
MW-7 and MW-9, and at injection points PZ-1, PZ-3, PZ-4 and PZ-5. Monitoring wells MW-1R, MW-1D,
MW-10, and PZ-2 will be sampled for field parameters and Volatile Organic Compounds during each sampling
event. Monitoring wells MW-3, MW-4, MW-5 and MW-8 will be sampled quarterly for field parameters and
Volatile Organic Compounds. If the second phase injection is performed, the entire monitoring procedure will
begin again. The changes APS is requiring consist of adding Total Lead to the sampling program when sampling
is performed for Volatile Organic Compounds, and the performance of a baseline sampling event for all
parameters in monitoring, wells MW-1, MW-1R and MW-9 before the second injection event takes place. The
APS is also requiring that monitoring wells MW-4, MW-5, MW-7 and MW-8 be sampled before the first phase
injection takes place, and that MW-7 be added to the list of wells that will be sampled quarterly for field
parameters, Volatile Organic Compounds, and Total Lead.
EPIDEMIOLOGY On April 20, 2009 and March 21, 2003, the DHHS' Epidemiology Branch provided
comments on Aerosol OT-75 and on PermeOx Plus for groundwater remediation. Drs. Ken Rudo and Luanne
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 Eric Rice of the Raleigh Regional Office recommended issuance of this
permit. All of the concerns of the Raleigh Regional Office were subsequently addressed by the applicant, and
all of the recommendations made by the Regional Office were included in the permit.