WI0600071_Permit (Issuance)_20110323

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
Petitioner for DSCA Site#83-0001
FOR THE CONSTRUCTION AND/OR OPERATION OF 8 TYPE 5I INJECTION WELLS, defined
in Title 15A North Carolina Administrative Code 2C .0209(e)(3)(C), to inject Adventus EHC and
Zero Valent Iron for the reduction of chlorinated volatile organic compounds (CVOCs). These
injection wells/points will be located at the One Hour Cleaners, 1514 S. Main St., Laurinburg,
Scotland County, NC 28352, and will be operated in accordance with the application submitted
January 21, 2011 and in conformity with the specifications and supporting data submitted March 11,
2011, all of which are filed with the Department of EnvironmentandNatural 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 28, 2013,
and shall be subject to the specified conditions and limitations set forth in Parts I through X hereof.
Permit issued this the 23rd day of March, 2011.
tl
Coleen H. Sullins, Director
Division of Water Quality
By Authority of the Environmental Management Commission.
Permit No. WI0600071 PAGE 1 OF 6
ver. Oct.2010 AP/UIC-6

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 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. Eachinjection 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 Fayetteville Regional Office Aquifer Protection Section Staff,
telephone number [phone].
Permit No. WI0600G71 PAGE 2 OF 6
ver. Oct.2010 AP/UIC-6

PART III - OPERATION 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 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.
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.
Permit No. WI0600071 PAGE 3 OF 6
ver. Dct.2010 AP/UIC-6

PART VI - INSPECTIInv,
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. The proposed revised monitoring plan received March 11, 2011, which is included in the
application, shall be followed.
2.. All sample results shall be submitted to the Aquifer Protection Section's Fayetteville Regional
Office and the Raleigh Central Office. Any ionitoring (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.
5. The monitoring results and the final project evaluation shall besubmitted to:
and to:
Aquifer Protection Section-UIC Program
DENR-Division of Water Quality
1636 Mail Service Center
Raleigh, NC 27699-1636
Aquifer Protection Section
DENR-DWQ Fayetteville Regional Office
225 Green St.
Systel Building, Suite 714
Fayetteville, NC 28301
Permit No. WI0600071 PAGE 4 OF 6
ver. Oct.2010 • AP/UIC-6

6. The Permittee shall report oy 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 orin 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.
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 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.
Permit No. WI0600071 PAGE 5 OF 6
ver. Oct.2010 AP/UIC-6

(D) Drilled wells snaii 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 T 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.
2. 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.
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. WI0600071 PAGE 6 OF 6
ver. Oct.201-0 AP/UIC-6

DIVISION OF WATER QUALITY
AQUIFER PROTECTION SECTION
March 17, 2011
MEMORANDUM
TO: Debra Watts a 1
FROM: Michael Rogers
RE: Issuance of Permit to Inject Adventus EHC and ZVI (Permit #WI0600071)
Petitioner for DSCA Site #83-0001 (One Hour Cleaners)
I recommend that Permit Number WI0600071 be issued to DSCA Petitioner to inject Adventus EHC and ZVI to remediate
groundwater (GW) contaminated with chlorinated volatile organic compounds (CVOCs) primarily PCE. The site is located at
One Hour Cleaners, 1514 S. Main St., Laurinburg, Scotland County, NC 28352.
SITE DESCRIPTION: The subject site is an active dry cleaning facility, which has evidently impacted the groundwater in
the area (Figures 1 and 2A).
HYDROGEOLOGIC DESCRIPTION: The site is located in the southwestern portion of the North Carolina Coastal Plain
Physiographic Province. There are 3 main aquifers in the vicinity of the site: surficial, Black Creek, and Cape Fear. The
surficial aquifer, which is the target aquifer, consists primarily of surficial deposits of sandy silts and sandy clays. Below
the surficial aquifer is a thin clay layer, which is the top of The Black Creek. This formation consists primarily of fine to
medium sand with an intra-clay barrier in some areas forming the Upper Black Creek and Lower Black Creek. Depth to
GW in the surficial aquifer ranges from approximately 7 to 14 feet BLS and flows in a generally northerly direction at
approximately 11 feet/year (Figure 3A).
EXTENT OF CONTAMINATION: The PCE plume is massive. The .0007 mg/L isocontour line is approximately 1500 feet long
and 1400 feet wide (Figure 4A). According to the Applicant, the public water supply well (WSW#2) for Laurinburg has had
detections of PCE. The well, however, is located approximately 200 feet outside the .0007 isocontour line.
PROPOSED INJECTION: The proposed injection will be in the source area. There is one injection event planned lasting 2
days. Approximately 3000 gallons of injectant will be injected via 8 direct push wells (estimated 375 gallons per well).
The potential displacement of the plume by the injection is approximately 4% (the reported potential displacement is 10%).
Therefore, the risk is low.
HOW IT WORKS: Adventus EHC and ZVI are used to remediate groundwater contaminated with volatile organic
compounds by chemical reduction and stimulation of the biologic community (bioremediation).
MONITORING: Per my request, Hart and Hickman, the consultant, will install 1 additional monitoring well (OW-1)
downgradient of the injection area to the monitoring plan. Monitoring wells are highlighted in yellow on Figure 2B. And
evaluation will be conducted after the monitoring to determine if more injection events are warranted. The sampling frequency
follows.
Injection Event
Timeframe
Pre -injection
A few days prior to
injection
Post -injection
1 month, 3 months, and 6
months
EPIDEMIOLOGY: The DHHS has reviewed and approved Adventus EHC and ZVI as injectants.
REGIONAL OFFICE COMMENTS: Each of the RO comments/recommendations are discussed below (RO's
comments/recommendations are underlined).

Item #1-A copy of the Hart and Hickman report should be forwarded to the PWS and the Scotland County Health Dept. Jim
Barber and I discussed this via telephone. We concluded that sending additional copies of the application to various agencies
was not warranted. Jim was going to discuss this project and issues involved with the appropriate personnel where he works.
Jim Barber, signing for Art Barnhardt of the Fayetteville RO, recommends issuance of this permit.

51 Calculations Worksheet
Applicant/Facility: dig 6 kb Lf R Cr2,J 0S S' 72 . 8 ? _v U 01
Permit No. WI , 1/i -/
Date: V,,1-(///
Reviewer: 1) 6-S
n
srCt-
Depth to groundwater (GW): — 1`1 BLS
GW flow direction: -r'! /1%0RT)d'Ky4 I,d
MWs installed in same aquifer as injection? y (Y or N); Inj zone:
Nearest water supply well: IA) S w N 11 3� So
Groundwater Flow Rate
ti,33
/-e) v i 0 l4 c •+
vs-
MW zone: /U •-,
HC X , ()Ogg gradient(FT?) = v 3 flow rate/DAY(?) X 365 = /0.7- FT/YR
SY or porosity (-.30)
[FYI- 60 min/day X 24 hrs X 365 days = 525,600]
Calculations for Potential Contaminate Plume Displacement
WOO r//1/4)le LID
�.� a.. r x a 0 height = 3 f 0 0
.303
space
30o3
'o8
CF X . 3 0 SY or porosity (i.e. -.30) = �� 6 Q
CF
Reported: /0
CF of available void
CF of available void space X 7.48 gallons = / fill 8 gallons of water in void sp
gallons of injectant = 0,f fluid displaced by inject
gallons of water in void space t0L ! S / PR)
Potential displacement of plume by injection: L v L�
s
Injection Volume and Pumping Rate Per Well Per Day
300
move decimal)
total amt. of injectant / 8 number of wells / 2_ number of days of injection event =
amount of injectant per
(average gallons per day)
S:UIC/Applications and forms/ 5I Calculations worksheet aeld1 l / Ilad if Wau--
version 9/10/10