WI0600060_Permit (Issuance)_20100930

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
CSX Transportation, Inc.
FOR THE CONSTRUCTION AND/OR OPERATION OF 90 TYPE 51 INJECTION WELLS,
defined in Title 15A North Carolina Administrative Code 2C .0209(e)(3)(C), to inject emulsified
edible oil substrate (EOS) and sodium lactate to remediate groundwater contaminated by metals
chromium and antinomy. These injection wells/points will be located at the site of a train derailment
located approximately 830 feet northwest of the intersection of North Carolina Hwy. 211 and
Microwave Tower Rd., Council, Bladen County, NC 28434, and will be operated in accordance with
the application received on June 17, 2010, and in conformity with the specifications and supporting
data 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 August 31, 2013,
and shall be subject to the specified conditions and limitations set forth in Parts I through X hereof.
Permit issued this the 30th day of September 2010.
V \C
• oleen H. Sullins, Director
Division of Water Quality
By Authority of the Environmental Management Commission.
Permit No. WI0600060
ver. Jan 2010 AP/UIC-6
PAGE 1 OF 7

PART I - WELL CONS'inJCTION GENERAL CONDITION ,
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 construction 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 shall be 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 Staff
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 Fayetteville Regional Office Aquifer Protection Section Staff,
telephone number [phone].
Permit No. WI0600060 PAGE 2 OF 7
ver. Jan.2010 AP/UIC-6

PART III - OPERATIONN AND USE GENERAL CONDITION
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 maybe 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 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 abandonnient 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 physical 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.
Permit No. WI0600060 PAGE 3 OF 7
ver. Jan.2010 AP/UIC-6

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. 87-
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. Within 60 days of completion of the injection event, an `as -built' survey of the location of
injection wells shall be submitted to the Aquifer Protection Section -Underground Injection
Control (UIC) Central Office and the Fayetteville Regional Office Aquifer Protection Section at
the addresses referenced below.
2. The proposed monitoring plan included in the application shall be followed; except that
monitoring shall occur for at least two quarters after laboratory analytical results indicate the
contaminants of concern (COCs} are below 15A NCAC 2L .0200. All sample results shall be
submitted to the Aquifer Protection Section's Fayetteville 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 insure 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.
Permit No. W I0600060 PAGE 4 OF 7
ver. Jan.2010 AP/UIC-6

5. The monitoring results and the final project evaluation shall be submitted to:
Aquifer Protection Section-UIC Staff
DENR-Division of Water Quality
1636 Mail Service Center
Raleigh, NC 27699-1636
and to:
Aquifer Protection Section
DENR-DWQ Fayetteville Regional Office
Systel Building
225 Green St., Suite 714
Fayetteville, NC 28301-5094
6. The Permittee shall report by telephone, within 48 hours of the occurrence or first knowledge of
the occurrence, to the Fayetteville 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 .0113, Well Construction Standards.
Permit No. WI0600060 PAGE 5 OF 7
ver. Jan.2010 AP/UIC-6 '

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 .0113(b), including but not limited to the following:
(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 Staff
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 product proposed to be used are as follows: eye,
skin, nose, throat, and lung irritation. If the 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.
Permit No. W10600060 PAGE 6 OF 7
ver. Jan.2010 AP/UIC-6

2. Persons working with triese products should wear goggles or a fait ___eld, gloves, and protective
clothing. Face and body protection should be used for anticipated splashes or sprays.
3. Eating, drinking, smoking, handling contact lenses, and applying cosmetics should not be
permitted' in the application area during or immediately following application.
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 incompatible or adverse reactions
• and injuries.
Permit No. WI0600060
ver. Jan.2010 AP/UIC-6.
PAGE 7 OF 7

DIVISION OF WATER QUALITY
AQUIFER PROTECTION SECTION
MEMORANDUM
TO: Debra Watts
FROM: Michael Rogers Ars--
r
RE:
September 29, 2010
Issuance of permit to inject emulsified edible oil substrate (EOS) and sodium lactate (Permit #WI0600060)
CSX Transportation, Inc. derailment spill site located approximately 830 feet northwest of the intersection
of North Carolina Hwy. 211 and Microwave Tower Rd., Council, Bladen County, NC 28434
I recommend that Permit Number WI0600060 be issued to CSX Transportation, Inc. to inject emulsified edible oil substrate
(EOS) and sodium lactate to remediate groundwater (GW) contaminated with the metals chromium and antinomy.
SITE DESCRIPTION: The subject Site is the site of a train derailment and spill located approximately 830 feet northwest of
the intersection of North Carolina Hwy. 211 and Microwave Tower Rd., Council, Bladen County, NC 28434 (Figures 1
and 2). The spill event occurred in 1986, and the site has been undergoing various forms of remediation since then. The
site is in a rural area surrounded by pasture and woods.
HYDROGEOLOGIC DESCRIPTION: The Site is located in the Coastal Plain Physiographic Province. In the area of the Site,
the overburden consists of sand and silty sand to approximately 30 feet BLS. Underlying the surficial aquifer at
approximately 30 feet BLS is the Pee Dee confining aquifer, which consists primarily of silty clay. The contamination,
injection, and monitoring for this project is in the surficial aquifer. Depth to groundwater (GW) is approximately 1 foot
BLS. GW generally flows northeast at approximately 237 ft/year (Figure 6).
EXTENT OF CONTAMINATION: The metals contaminant plume is generally oval and is approximately 600 feet long and 300
feet wide (Attachment F). According to the Applicant, the nearest water supply well is located approximately 650 feet
southeast of the site, which is upgradient. The nearest downgradient well is located over one quarter of a mile east to northeast
(Figure 3).
PROPOSED INJECTION: The proposed injection consists of injecting a total of approximately 250,000 gallons of injectant
via 90 injection wells over 2 to 3 weeks (132 gallons per day per well). There will be 45 clusters with 2 wells in each
cluster. One well will be screened at 5 to 15 feet and the other well will be screened at 15 to 25 feet. These clusters will be
installed along linear lines and will act as a Reactive Barrier Zone. As GW flows thru the emplaced injectant, the GW
undergoes remediation. There are 3 events planned with 12 to 18 months between events. The actual number of events
will be dependent upon injection effectiveness. According to the Applicant, the estimated amount of fluid displacement
from injection is approximately 20%. Because the design of this injection is to act as a barrier zone and the injection will
be at or near 1 to 2 pounds PSI (i.e. gravity flow), the potential displacement of the plume is low.
HOW IT WORKS: EOS and lactate are used to remediate groundwater contaminated with metals by stimulating microbes.
Microbes are capable of transforming hexavalent chromium [Cr(VI)] to Cr(IlI). Chromium reducing bacteria are
widespread, and with the addition of food such as lactate and/or vegetable oil, a reducing environment is created with
sufficient electron donor material present for biological processes to occur. Once the Cr(III) is created, there is a reaction
with water, creating Cr(OH)3. This resulting compound is insoluble and immobile at most natural pH conditions and,
therefore, does not remain in solution. In other words, the end compound precipitates out. The Site has been undergoing
various forms of groundwater remediation for several years, including pump and treat. The remaining contaminants of
concern (COCs) are the reference metals. This remediation approach has been included in the RAP submitted to the
Inactive Hazardous Sites Branch of the DWM.

MONITORING: The wells to be use a. __ part of the monitoring network are iden____ on Attachment F. The proposed
monitoring frequency will be once prior to injection and then approximately 45 days following the injection. Follow-up
sampling frequency would be based upon these results. However, I am putting in the permit that quarterly sampling occur for at
least two quarters after laboratory results indicate COCs are below MCL. This is in order to confirm that the remediation is
permanent as effectiveness of this treatment for elevated metals is related to natural pH and redox conditions.
EPIDEMIOLOGY: The DHHS has reviewed and approved EOS as an injectant.
REGIONAL OFFICE COMMENTS: Each of the RO comments/recommendations are discussed below (RO's
comments/recommendations are underlined).
Item #1-As built survey of the injection wells location shall be submitted within 60 days after -ilia -dilation -and introduction of the
oxidative materials. I have requested this in the permit.
Jim Barber, who signed for Art Barnhardt of the Fayetteville RO, recommends issuance of this permit.

5I Calculations Worksheet
Applicant/Facility: G S,<- (/I�q,✓S /��M�j�-,, ,J
Permit No. WIX;/ to gi
Date: 9/ // 0 n
Reviewer: V2o 6-6(t-S
c:SS `/SU
Depth to groundwater (GW):- / BLS
GW flow direction: /"L - /
MWs installed in same aquifer as injection? 1 (Y or N); Inj zone: /S-7- 0)-;---
Nearest water supply well: 6 Si(-5 c-- (% ao.,, 50
,A-JztAAAr- 0 ti,-.J.LfLe. AAA:
Groundwater Flow Rate
MW zone:
HC X . c J gradient(FT?) = -� flow rate/DAY(?) X 365 = a 3 7 FT/YR
• 0 SY or porosity (-.30)
[FYI- 60 min/day X 24 hrs X 365 days = 525,600]
Calculations for Potential Contaminate Plume Displacement �a �„� Z/24),
3.142 (7c) X r2 X height = % go
vim! d �-�
CF X SY or porosity (i.e. -.30) = CF of available void ,
Reported:
space
CF of available void space X 7.48 gallons = gallons of water in void sp
gallons of injectant = % of fluid displaced by injectant (move decimal)
gallons of water in void space
Potential displacement of plume by injection:
Injection Volume and Pumping Rate Per Well Per Day
CO ,D0-0 total amt. of injectant / 90 number of wells / 3 number of cloy& of injection event =
' / 5 amount of injectant per well per day (average gallons per day)
S:UIC/Applications and forms/ 51 Calculations worksheet version 9/10/10

5I Calculations Worksheet
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Notes
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S:UIC/Applications and forms/ 5I Calculations worksheet
version 9/10/10