WI0500329_Staff Report_20110308

Goodrich, David
From:
Sent:
To:
Subject:
David,
Rice, Eric
Tuesday, March 08, 2011 2:14 PM
Goodrich, David
Peden Family, LLC (WI0500329)
I have reviewed the February 28, 2011, rec. March 3, 2011 RRO, submittal (in response to the Division's information
request) from 5& ME for the Peden Family UIC application (W10500329) located at 1859 Capital Blvd. Raleigh -Wake
County. The information appears to be an acceptable response to the additional information request. Contact me if you
have any question concerning my review.
Eric R.
Email correspondence to and from this address may be subject to the North Carolina Public Records law and may be disdosed to third parties
1

AVA
NCDER,
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Coleen H. Sullins' Dee Freeman
Governor Director Secretary
February 8, 2011
Memorandum
To: David Goodrich
Land Application Unit, Central Office
From: Eric Rice
Aquifer Protection Section, Raleigh Regional Office
Through: Jay Zimmerman, Regional Supervisor
Aquifer Protection Section, Raleigh Regional Office
Subject: UIC (51) Permit
Peden Family, LLC
1859 Capital Boulevard
Raleigh, N.C.-Wake County
Permit # WI0500329
Enclosed is the regional staff report regarding the submittal of a permit application for the
injection of a surfactant and follow-up injection of an oxidizer at the facility listed above in
Raleigh, N.C. The permit is being requested in order to remediate petroleum contaminants in
groundwater associated with a release from an underground storage tank. Please contact me at
[phone] if you have any questions about the inspection.
cc: file
Attachment: APRSR form
Aquifer Protection Section
1628 Mail Service Center. Raleigh. North Carolina 27699-I628
Location: 3300 Barrett Dr.. Raleigh. North Carolina 27609
Phone: [phone] FAX: [phone]''t Customer Service: 1-877-623-6748
Internet: www.ncwaterqualitv.org
An F.qual Opportunity Affirmative Action Rmplo}er
RECEIVED / DENR / DWQ
Aquifer Protection Section
FEB 0 9 2011
North Carolina
jVatitrallji

AQUIFER PROTECTION REGIONAL STAFF REPORT
Date: February 8, 2011
To: Aquifer Protection Central Office
Central Office Reviewer: David Goodrich
Regional Office Inspector: Eric Rice (RRO)
County: Wake
Permittee: Peden Family, LLC
Project Name: Peden Family, LLC
#WI0500329
L GENERAL INFORMATION
1. This application is (check all that apply): ® New ❑ Renewal
❑ Minor Modification ❑ Major Modification
n Surface Irrigation ❑ Reuse ❑ Recycle ❑ High Rate Infiltration ❑ Evaporation/Infiltration Lagoon
❑ Land Application of Residuals ❑ Attachment B included ❑ 503 regulated ❑ 503 exempt
n Distribution of Residuals ❑ Surface Disposal
❑ 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.
b.
c.
d.
Date of site visit: January 28, 2011
Person contacted and contact information: Tom Raymond and David Wells (S&ME)
Site visit conducted by: E. Rice
Inspection Report Attached: ❑ Yes or ® No.
2. Is the following information entered into the BIMS record for this application correct?
❑ Yes or ® No. If no, please complete the following or indicate that it is correct on the current application.
For Disposal and Iniection 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): near recycling building
b. Driving Directions: Capital Boulevard to right on Hodges Road, end of road
c. USGS Quadrangle Map name and number:
d. Latitude: 35 48 29 Longitude: 78 37 05 to the nearest second
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: )
RECEIVED / DENR / DWQ
Aquifer Protection Section
FEB 0 9 2011
FORM: Peden Family W10500329.doc 1

AQUIFER PROTECTION REGIONAL STAFF REPORT
2. Does system use same well for water source and injection? ❑ Yes El No
3. Are there any potential pollution sources that may affect injection? ® Yes ❑ No
What is/are the pollution source(s)? Some type of lift station for waste water What is the distance of the
injection well(s) from the pollution source(s)? Approximately 25 feet
4. What is the minimum distance of proposed injection wells from the property boundary? 130 feet
5. Quality of drainage at site: ❑ 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 n 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.
V. EVALUATION AND RECOMMENDATIONS
1. Provide any additional narrative regarding your review of the application. Permit application is regarding the
injection of a 3% solution of Aerosol OT 75 a surfactant followed by the extraction of contaminated
groundwater (Phase I). The application indicates if residual contaminants remain after the initial treatment, then
a 45% solution of PermeOx (an oxidant) will be injected. Petroleum contaminants in groundwater are a result
of a release from an underground storage tank. Total volume for the surfactant will be six thousand eight
hundred gallons and a total of one thousand four hundred gallons for the permeOx. Injection will be by way of
three monitoring wells (MW-1, MW-9,MW-10) and five new injection points (PZ-1, PZ-2,PZ-3,PZ-4,PZ-5).
Following injection of the surfactant, groundwater will be extracted after one to two weeks utilizing several
existing monitoring wells (MW-1, MW-1R, MW-9, MW-10) and the injection points (PZ-1, PZ-2, PZ-3, PZ-4,
PZ-5) with MMPE. If LNAPL rebounds after the injection, then injection will be repeated. If after initial
injection residual product is observed above the GCL's (after approx. ninety days), then Phase II will be
implemented which will consist of the injection of the PermeOx. Free product is present at a thickness of three
tenths of a foot in the injection area. Observations: Site is in an industrial setting. Several of the buildings on
site are being used as recycling centers for plastic, metal, and cardboard. City water is available. Injection
location will encompass a relatively small area located in a grassy area between the truck weigh scales and one
of the recycling buildings. The surfactant is being injected to address the presence of free product. The intent is
to unbind the contaminants from the soils particles then vacuum the material out of the subsurface. If necessary
a second injection event consisting of 46 % Permex (an oxidizer) will be injected. A concern is that the oxidizer
could have an adverse reaction with any free product remaining after the first injection event.
Recommendations/requirements: 1. Request construction diagrams/details for the existing wells which will be
FORM: Peden Family WI0500329.doc 2

AQUIFER PROTECTION REGIONAL STAFF REPORT
utilized as injection wells (MW-1, MW-9, MW-10) 2. It is recommended that vapor monitoring is conducted in
the building during the initial injection event to monitor for vapors that might be a direct result of the injection
or request documentation from the applicant that explains why vapor monitoring will not be conducted or is not
necessary 3. Page E-2 of the application has a system diagram that details construction of (what are assumed to
be) PZ injection wells. The diagram on the left side indicates that an open borehole may be used in
construction. The 02C well construction rule requires that grout is installed to land surface. 4. Require applicant
to confirm that page E-2 of the application details the construction of the PZ injection wells 5. Details of the
phase II injection not included in the permit such as what wells will be used to inject. Request info. 6. Include
well MW-9 in the Attachment F Monitoring Plan with requirement to collect field parameters and VOC's (well
has not been sampled over many sampling events). 7. Monitoring requirements: Per attachment F in the
application
In regards to the second injection event consisting of the PermeOx (Phase II): 8. Require applicant to confirm
there is no free product present prior to injection of the oxidizer or supply documentation why no adverse
reaction would occur if free product is present 9. Require a status report to the Central and Regional Office on
the site conditions (free product, groundwater chemistry, etc.) prior to the second injection 10. The addition of
metals analysis to the monitoring plan. 11. Additional quarters of groundwater monitoring maybe necessary
given that the second injection event will likely extend injectant reactions beyond the standard four quarters of
monitoring for the initial injection event 12. Monitoring requirements: Per attachment F in the application 13.
Also, include metals analysis for approximately two quarters including a baseline sampling event prior to
injection for wells MW-1, MW-9, and MW-1R. Metals analysis maybe necessary with the expectation that
PermeOx will temporarily lower the groundwater pH.
Attach Well Construction Data Sheet - if needed information is available
2. Do you foresee any problems with issuance/renewal of this permit? ® Yes ❑ No. If yes, please explain
briefly. Satisfactory answer for #8 above if Phase II is completed
3. 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
Items #1,2,3,4,5,6
For second injection event items #8,9,10
Necessary
FORM: Peden Family WI0500329.doc
3

1

AQUIFER PROTECTION REGIONAL STAFF REPORT
4. 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
5. 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
Item #7, 11, 12, 13
Necessary
6. Recommendation: ® Hold, pending receipt and review of additional information by regional office or CO
(#1 well diagrams); ❑ Hold, pending review of draft permit by regional office; ❑ Issue upon receipt of
needed additional information; ❑ Issue; ❑ Den . If deny, please state reasons:
s,
7. Signature of report preparer(s): rr
Signature of APS regional supervisor: L
Date:
1
Attachments:
e
FORM: Peden Family WI0500329.doc 4

Michael F. Easley, Governor
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
Coleen Sullins, Director
Division of Water Quality
April 20, 2009
MEMORANDUM
To: Dr. Mina Shehee
Epidemiology Section
Division of Public Health
Department of Health and Human Services
From: Thomas Slusser, 715-6164; [e-mail]
Aquifer Protection Section
Division of Water Quality
Department of Environment and Natural Resources
Subject: Health Risk Evaluation Request
Use of Chemicals as Surfactants
Calfax 16L-35, Aerosol OT-75, Sodium Chloride, Calcium Chloride, Xanthan Gum
Please find attached package submitted by AMEC, who is proposing to use the product as a surfactant to
enhance recovery of petroleum products in groundwater. We request that you conduct a health risk
evaluation for the products. If you need additional information please call or email me or Harold
Thurston at [phone].
Thank you,
4
1912 Mail Service Center, Raleigh, NC 27699-1219
No thCarolna
,Naturally
Aquifer Protection Section 1636 Mail Service Center Raleigh, NC 27699-1636 Phone [phone] Customer Service
Internet: http://h2o.enr.state.nc.us 2728 Capital Boulevard Raleigh, NC 27604 Fax [phone]
Fax [phone]
An Equal OpportunitylAfiirmative Acton Employer — 50% Recycled/10% Post Consumer Paper

Slusser, Thomas
From: Ken Rudo [[e-mail]]
Sent: Tuesday, May 12, 2009 3:06 PM
To: Thomas Slusser
Cc: Mina Shehee
Subject: Health Risk Assessment/AMEC Air National Guard Site / Charlotte, NC
Mr.Slusser, As discussed earlier today, I am responding to the above risk
assessment/remediation request via email in order to get this to the interested parties in a
timely manner. After reviewing the information and after a toxicological literature
evaluation, these products are generalized irritants upon exposure to skin, the eyes, and via
ingestion and inhalation. Based on the information supplied to our branch, if personal
protective equipment is worn while using these products in accordance with MSDS sheets, there
should not be an increased health risk occupationally. In addition, because there are no
drinking water wells within 1000 feet of the contaminated site, the use of these products in
the remediation process should not pose an increased health risk to drinking water in this
area. If drinking water wells are found within 300 feet of this site, please notify this
office.
OEEB may have some concerns related to the interaction of these products from a potential
groundwater contamination standpoint if drinking water wells are within 300 feet of this
area. If you have any further questions, please feel free to contact me at 919-707-5911.
Sincerely, Kenneth Rudo Ph.D, Toxicologist

Michael F. Easley, Governor
MEMORANDUM
33
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]
March 21, 2003 Carmen Hooker Odom, Secretary
TO: Mark Pritzl
Groundwater Section
rr'
N
FROM: Luanne K. Williams, Pharm.D., Toxicologist &/kAl
Medical Evaluation and Risk Assessment Unit
Occupational and Environmental Epidemiology Branch
North Carolina Department of Health and Human Services
SUBJECT: Use of PermeOx® Plus to Enhance Bioredmediation of Hazardous Wastes
I am writing in response to a request for a health risk evaluation regarding the use of
PermeOx® Plus to enhance bioremediation of hazardous wastes. Based upon my review of the
information submitted, I offer the following health risk evaluation:
WORKER PRECAUTIONS DURING APPLICATION
1. Some effects reported to be associated with the product ingredients and reaction products
(following the addition of water) include nose irritation, throat irritation, eye irritation,
skin irritation, severe burns, nausea vomiting, and difficulty breathing (Meditext ® -
Medical Management by Micromedex TOMES Plus System CD-ROM Database, 2003).
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. Keep combustibles away from spilled material.
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.
2. 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.
3. Eating, drinking, smoking, handling contact lenses, and applying cosmetics should never
be permitted in the application area during or immediately following application.
Location: 2728 Capital Boulevard • Parker Lincoln Building • Raleigh, N.C. 27604 An Equal Opportunity Employer

Mark Pritzl Memo
March 21, 2003
Page Two
4. 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.
OTHER PRECAUTIONS
1. 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.
2. Because of the potential risks associated with the use of this product, every effort
should be made to prevent contamination of existing or future wells that may be
located near the application area.
3. Runoff may create a fire or explosion hazard. Precautions should be taken to
prevent runoff.
Please do not hesitate to call me if you have any questions at [phone].
Enclosures
cc: Mr. Chuck Elmendorf, Panther Technologies, Inc, 220 Route 70E, Suite B,
Medford, NJ 08055