WI0600080_Permit (Issuance)_20111019

I4 •
NORTH CAROLINA 7'O
ENVIRONMENTAL MANAGEMENT COMMISSION �I
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
Pope Army Airfield
FOR THE CONSTRUCTION AND OPERATION OF 32 TYPE 5I INJECTION WELLS,
defined in Title 15A North Carolina Administrative Code 2C .0209(e)(3)(C), to inject BOS 200
and Trap & Treat Bacteria Concentrate for the chemical and biochemical breakdown and
bioremediation of Number 2 Fuel Oil. These injection wells/points will be located'atSite ST008
at the Pope Army Airfield at Fort Bragg in Fayetteville, Cumberland County, North Carolina,
and will be operated in accordance with the application submitted August 11, 2011, and in
conformity with the specifications and supporting data submitted August 26, 2011, August 29,
2011, September 30, 2011, and October 12, 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 September 30,
2014, and shall be subject to the specified conditions and limitations set forth in Parts I through
X hereof.
Permit issued this the 19th day of October, 2011.
;For Coleen H. Sullins, Director
Division of Water Quality
By Authority of the Environmental Management Commission.
Permit No. WI0600080 PAGE 1 OF 7 -
ver. June 2011 UIC-5115T

PART I - WELL CONS`f iuJCTION 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. Each injection well shall have permanently affixed an identification plate.
PART II - WELL CONSTRUCTION SPECIAL CONDITIONS
1. 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 919-715-6162 and the Fayetteville Regional Office Aquifer
Protection Section Staff, telephone number [phone].
2. Bentonite grout shall not be used to seal any water -bearing zone with a chloride
concentration equal to or greater than 1,500 milligrams per liter. In areas where elevated
chloride levels are known to exist or are probable, such as coastal areas, chloride levels shall
be verified in the field to determine existing conditions.
Permit No. WI0600080 PAGE 2 OF 7
ver. June 2011 UIC-5I/5T

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 that may be imposed by other
local, state, and federal agencies having 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.
2. 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.
3. 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.
4. 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 919-715-6162. 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. WI0600080 PAGE 3 OF 7
ver. June 2011 UIC-5115T

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 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
2. The proposed monitoring plan included in the application shall be followed. 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 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 be submitted to:
UIC Program Staff
DWQ — Aquifer Protection Section and
1636 Mail Service Center
Raleigh, NC 27699-1636
DWQ - Aquifer Protection Section
Fayetteville Regional Office
225 Green Street, Suite 714
Fayetteville, NC 28301-5043
Permit No. WI0600080 •
ver. June 2011 UIC-5I/5T
PAGE 4 OF 7

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 .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:
(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. WI0600080 PAGE 5 OF 7
ver. June 2011 UIC-51/5T

(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 product proposed to be used areas 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. The microorganisms in BOS 200 are naturally found in soil, and are not ordinarily associated
with infection in healthy humans (except through an existing wound). However, these
microorganisms may cause infection in the young, the aged, and the immunocompromised
such as individuals with AIDS, cancer, hepatitis, or with individuals following dialysis or
surgical procedures.
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. Eating, drinking, smoking, handling contact lenses, and applying cosmetics should not be
permitted in the application area during or immediately following application.
5. Safety controls should be in place to ensure that the check valve and the pressure delivery
systems are working properly.
6. The Material Safety Data Sheets should be followed to prevent incompatible or adverse
reactions and injuries.
Permit No. WI0600080 PAGE 6 OF 7
ver. June 2011 UIC-51/5T

7. 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.
Permit No. WI0600080 • PAGE 7 OF 7
ver.June 2011 UIC-5U5T

DIVISION OF WATER QUALITY
AQUIFER PROTECTION SECTION
October 12, 2011
PERMIT ISSUANCE MEMO
TO: Debra Watts
THROUGH: Thomas Slusser
FROM: David Goodrich
RE: Permit To Inject BOS 200 with Trap & Treat Bacteria Concentrate
Pope Army Airfield Site ST008
I recommend that Permit Number WI0600080 be issued to Pope Army Airfield to inject BOS 200 with Trap &
Treat Bacteria Concentrate to remediate soils and groundwater contaminated with Number 2 Fuel Oil.
SITE DESCRIPTION The site is situated in a highly industrialized area near the center of the military base.
Four 25,000-gallon underground storage tanks were used to store fuel oil between 1954 and 1985. One of the
UST units failed a tightness test in 1990. All four tanks were removed in 1992, and free product and
contaminated soil were observed. Free product has been observed to a thickness of 4.35 feet. Historic remedial
activities have included air sparging, aggressive fluid vapor recovery, oleophilic socks, and passive skimmers.
This site is approximately 2000 feet east of Site SS019.
HYDROGEOLOGIC DESCRIPTION The site is located in the Coastal Plain Physiographic Province of
eastern North Carolina, which is geologically composed of unconsolidated Cretaceous -age coastal sediments
extending to a depth of approximately 200 feet. Site borings have been performed to a maximum depth of more
than 37 feet and have shown the local geologic column to consist of silty sand, sand, gravely sands,
discontinuous inorganic clays, and inorganic silts. There are no continuous or extensive layers or formations.
Shallow ground water is typically found at a depth of 13 to 20 feet, with a seasonal high water table of
approximately 11 to 16 feet. The shallow hydraulic gradient is approximately 1.6% towards the northwest, and
the hydraulic conductivity calculated from slug testing combined with an effective porosity of 0.2 results in a
shallow groundwater velocity of approximately 2.3 ft/day.
EXTENT OF CONTAMINATION Although the exact size of the impacted area is not known and maps are
based on the observed thickness of free product instead of chemical concentrations, considering the groundwater
gradient and other factors, the contamination appears to occupy an area which is approximately 160 feet long,
150 feet wide, and to a depth of approximately 30 feet (see Figures 4a, 4b and 5). Assuming an average effective
porosity of 20% in all of the affected strata results in a total impacted groundwater volume of approximately
144,000 cubic feet, or 1,080,000 gallons.
PROPOSED INJECTION BOS 200 is a blend of activated carbon, sulfate reduction media,
micronutrients, and facultative microbes. Trap & Treat Bacteria Concentrate is a blend of naturally occurring
bacteria and fungi that degrade fuel oil. When used together, these mixtures absorb and
chemically/biochemically break down fuel oil products and promote the growth of naturally -occurring and
introduced microorganisms that feed on fuel oil. Thirty-two borings will be advanced using direct push
technology to a depth of approximately 16 feet, and injection will take place over a vertical interval of 11.5 to 16
feet. Each injection point will be subsequently abandoned by backfilling with bentonite grout. A single injection
event will take place, and each of the 32 borings will receive approximately 20 gallons of injectant (total). The
total injection volume will be approximately 640 gallons, which represents less than 0.1% of the total estimated
volume of impacted ground water.

BOW IT WORKS BOS 200 is a blend of activated carbon, sulfate reduction media, micronutrients, and
facultative microbes. Trap & Treat Bacteria Concentrate is a blend of naturally occurring bacteria and fungi that
degrade fuel oil. When used together, these mixtures absorb and chemically/biochemically break down fuel oil
products and promote the growth of naturally -occurring and introduced microorganisms that feed on fuel oil.
MONITORING The proposed monitoring plan will be followed. It consists of measuring the free
product thickness present in all 32 existing monitoring/air sparing wells prior to the injection event, one day
after the event, one week after the event, two weeks after the event, and approximately monthly for the next
year. Nine selected monitor wells will be sampled for Sulfate,. Sulfite, Nitrate, and Nitrite prior to the injection
event, approximately three months after the injection event, six months after the injection event, and
approximately one year after the injection event. These nine wells will be sampled for Volatile Aeromatics by
EPA Method 602, Semi -volatile compounds by EPA Method 625, extractable petroleum hydrocarbons (EPH),
and for volatile petroleum hydrocarbons (VPH) prior to the injection event and approximately one year after the
injection event.
EPIDEMIOLOGY . On October 13, 2006 and on October 12, 2011, the DHHS' Epidemiology Branch
provided comments on BOS 200 and on Trap & Treat Bacteria Concentrate for groundwater remediation. Dr.
Luanne K. Williams and Dr. Ken Rudo 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 Jim Barber of the Fayetteville Regional Office recommend issuance of this
permit.