WI0700124_Permit (Issuance)_20090316

DIVISION OF WATER QUALIT1
AQUIFER PROTECTION SECTION
March 16, 2009
MEMORANDUM
TO: Debra Watts
FROM: Thomas Slusser
RE: Permit To Inject Anaerobic BioChem (ABC®) plus Zero Valent Iron (ZVI) {collectively, ABC+}
Former Southgate Koretizing Facility
Elizabeth City, Pasquotank County
I recommend that Permit Number WI0700124 be issued to Southgate Properties of NC, LLC, for a pilot test using ABC+ to
remediate ground water contaminated with chlorinated solvents.
SITE DESCRIPTION The remediation site is located in a shopping mall complex with plenty of paved parking spots and
other stores nearby, including a gas station. Southgate Koretizing operated as a laundry and drycleaning facility from 1972 to
1983. This structure was demolished and now a Captain D's restaurant is in its place. Contamination was discovered in 1998.
HYDROGEOLOGIC DESCRIPTION The injection site is located in the surficial aquifer of the outer coastal plain in
northeast NC. Depth to groundwater is —5 feet. Regional groundwater flow is east-southeast, but locally groundwater flows
westward at a rate of —100 feet/year. The contamination plume trends southwest an as spread at a rate ranging from 22 to 32
feet/year, based on the operating years of the drycleaning facility and a plume length of 800 feet. The difference between the
groundwater and contaminant flow rates probably reflects retardation (slowing) factors associated with the contaminants, and
the difference in flow directions probably reflects stratigraphic controls and sediment deposition patterns.
EXTENT OF CONTAMINATION Figures 7 and 8 show the extent of contamination. The pilot test will only focus on the
area between Captain D's and the Exxon gas station, as illustrated in Figure 2.
PROPOSED INJECTION -15,000 gallons of ABC+ solutionwill be injected via 15 proposed temporary, direct -push
injection wells. The injection interval of these wells will be 5-25 feet below ground surface. Only one injection event is
planned in order to determine technology effectiveness. If this pilot test proves effective, then a more comprehensive injection
plan will be proposed.
HOW IT WORKS ABC® consists of organic acids used to stimulate microbial degradation of contaminants. Microbial
fermentation of these compounds releases hydrogen, which is used by other microbes as an energy source. The process of
utilizing this energy source results in reduction of the contaminants. Zero valent iron is bits of iron filings (think ground -up
cast-iron frying pan). Oxidation (rusting) of the iron particles releases electrons that directly, abiotically reduce the
contaminants to innocuous end products.
MONITORING The proposed groundwater monitoring plan will be followed. Additional information received from the
consultant indicates that other down- and side -gradient and monitoring wells are sampled at least biannually as part of the
monitoring plan required by the Division of Waste Management.
EPIDEMIOLOGY On November 4, 2004, and October 2, 1998, Dr. Luanne Williams provided comments on ABC® and
zero valent iron, respectively, for groundwater remediation. Dr. 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 Washington Regional Office recommends issuance of this permit.

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
Southgate Properties of NC, LLC
FOR THE CONSTRUCTION AND OPERATION OF 15 TYPE 51 INJECTION WELLS, defined in
Title 15A North Carolina Administrative Code 2C .0209(e)(3)(C), fora pilot test to inject Anaerobic
BioChem® plus Zero Valent Iron, collectively known as ABC+, for the chemical and biological
reductive dechlorination of groundwater contaminated with chlorinated solvents. These injection
wells/points will be located at the former Southgate Koretizing facility, currently a Captain D's
Seafood restaurant in Southgate Mall, located at 1409 W. Ehringhaus Street in Elizabeth City,
Pasquotank County, North Carolina, and will be operated in accordance with the application
submitted November 13, 2008, and in conformity with the specifications and supporting data
submitted, all of which are filed with theDepartment of Environment and Natural Resources and are
considered a part of this permit.
Plus 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, 2011,
and shall be subject to the specified conditions and limitations set forth in Parts I through X hereof.
Permit issued this the `" t day of \I"C A olt—N , 2009.
Coleen H. Sullins, Director
Division of Water Quality
By Authority of the Environmental Management Commission.
Permit No. WI0700124 PAGE 1 OF 6
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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 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 Washington Regional Office Aquifer Protection
Section Staff, telephone number [phone].
Permit No. WI0700124 PAGE 2 OF 6
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PART III - OPERATIC : ;AND USE GENERAL CONDITIO.
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.
Z. The Permittee shall -be -required -to -comply -with the terms-and-conditions-ofthis-permiteven-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. WI0700124 PAGE 3 OF 6
ver.8/07 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. The proposed monitoring plan included in the application shall be followed. A11 sample
results shall be submitted to the Aquifer Protection Section's Washington 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.
2. The Permittee shall submit an Injection Event Record within 30 days of completing each
injection.
3. 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.
4. 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
Washington Regional Office
743 Washington Square Mall
Washington; NC 27889
Permit No. WI0700124
ver.8/07 AP/UIC-6
PAGE 4 OF 6

5. The Permittee shall it by telephone, within 48 hours of th. „incurrence or first knowledge
of the occurrence, to the Washington 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.
6. 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 P ermittee.
7. 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-incindethe-discontinued-use-of a well-forinjectionlf 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.
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.
Permit No. WI0700124 PAGE 5 OF 6
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(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 DC (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.
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. WI0700124 PAGE 6 OF 6
ver.8/07 AP/UIC-6

Permit Number WI0700124
Central Files: APS_ SWP_
11/19/08
Permit Tracking Slip
Program Category
Ground Water
Permit Type
Injection In situ Groundwater Remediation Well (51)
Primary Reviewer
thomas.slusser
Permitted Flow
Facility
Facility Name
Former Southgate Koretizing
Location Address
1409 W Ehringhaus St
Elizabeth Cty NC 27909
Owner
Status Project Type
In review New Project
Version Permit Classification
Individual
Permit Contact Affiliation
Genna Olson, PG
2725 E Millbrook Rd
Raleigh
Major/Minor
Minor
NC 27604
Region
Washington
County
Pasquotank
Facility Contact Affiliation
Owner Name
Southgate Properties of NC LLC
Dates/Events
Owner Type
Non -Government
Owner Affiliation
Peter McGrath, / Agent Attorney
100 N Tryon St
Charlotte NC 28202
Orig Issue App Received
i08
Regulated Activities
Outfall NULL
Draft Initiated
Scheduled
Issuance
Public Notice Issue Effective
Requested/Received Events
RO staff report received (2 -
RO staff report requested / / _r 2<„,0
1.
Expiration
Waterbody Name
Stream Index Number Current Class Subbasin