WI0700199_Permit (Issuance)_20110330

DIVISION OF WATER QUALITY
AQUIFER PROTECTION SECTION
March 30, 2011
PERMIT ISSUANCE MEMO
TO: Debra Watts
THROUGH: Thomas Slusser
FROM: John-McCray /1
RE: Permit To Inject Oxygen (ISOC)
Former Midway Motors Site
I recommend that Permit Number WI0700199 be issued to Freeman Family LLC to inject Oxygen to remediate
groundwater contaminated with hydrocarbons.
SITE DESCRIPTION Hydrocarbons were released to the groundwater through the use of a former UST operated by
Midway Motors. Contaminants have been known to be in the soil and groundwater at the site since 1994. No
remedial activity outside of natural attenuation has occurred at the facility. Currently the site is being used for storage
and part-time business ventures. Contamination is located within the groundwater of the surficial aquifer and is
moving toward the west.
HYDROGEOLOGIC DESCRIPTION The site is located within the Coastal Plain Physiographic Province and is
underlain primarily by clayey and sandy silts Quaternary in age, underlain by sediments of the Pliocene Series
Yorktown Formation. Within the constraints of the site, these -sediments compose a surficial aquifer contained
primarily within the clayey and sandy silt layers (Fig. 6) of the Quaternary deposits, and a lower, semi -confined
aquifer contained within a fossiliferous, clayey and silty medium to coarse sand of the Yorktown Formation. The two
aquifers are separated by an approximately sixteen foot thick sandy and silty clay unit extending downward from 15
feet below ground surface (bgs). The fossiliferous sand of the Yorktown Formation is approximately 14 feet thick
and underlie the site from - 31 ft bgs to -45 ft bgs. Silty clay and clayey silt of the Yorktown Fromation underlie the
sand unit and extend to depths greater than 75 ft bgs. Groundwater of the surficial aquifer is encountered at 3-6 feet
bgs, exhibits variable flow, with an overall flow to the east-southeast under a hydraulic gradient of .01 ft/ft through an
aquifer with with 25% porosity and an approximate hydraulic conductivity of 15 ft/day. The average velocity for the
surficial groundwater under these conditions is approximately 0.6 ft/day.
EXTENT OF CONTAMINATION Contaminant distribution of hydrocarbons for concentrations above the
NCGWQS, are confined to the surficial aquifer based on the most recent sampling event, has an irregular shape in
plan view (-560 feet in length) with the long axis trending northwest -southeast and is —280 ft wide. The plume
extends to a depth of —30 ft bgs.
PROPOSED INJECTION The applicant proposes to inject oxygen at a rate sufficient to maintain a 40 to 60
parts per million concentration (ppm) into the surficial aquifer through 4 recovery wells (RW 1, RW3, RW4, and
RW5) refitted with ISOC units over a period of five years. The injectate is a dissolved gas and is not expected to add
any significant volume.
HOW IT WORKS The main remedial activity of the injectant is to increase aerobic degradation of the
hydrocarbon contaminants.

MONITORING Twelve (12) existing monitoring wells (MWIR, MW22, MW23, MW23D, MW29, MW30,
MW35, MW38, MW39, DCW2, RW3, and RW5) located at the site will be used to monitor for changes in
contaminant concentrations as part of the remedial injection activities at the site. Sampling for constituents will be
conducted quarterly and field measurements for pH, dissolved oxygen, oxygen -reduction potential (ORP),
temperature, and conductivity, and laboratory samples will be analyzed for VOCs (EPA Method 6200B), sulfate and
nitrate (EPA Method 300), alkalinity (EPA Method 310.1), methane (RSK SOP-75), dissolved iron, biological
oxygen demand (GODS), and chemical oxygen demand (COD) for one year. After the first year, the sampling plan
will be evaluated to optimize cost versus efficacy.
EPIDEMIOLOGY - On May 21, 2002, the DHHS' Epidemiology Branch provided comments on the use of
Oxygen to enhance bioremediation of petroleum groundwater contaminants. Dr. Luanne K. 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 Will Hart of the Washington Regional Office has no issues with the application
and 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
Freeman Family LLC
FOR THE OPERATION OF 4 TYPE 5I INJECTION WELLS, defined in Title 15A North Carolina
Administrative Code 2C .0209(e)(3)(C), to inject compressed Oxygen gas, for the enhancement of
aerobic bioremediation of hydrocarbons. These injection points will be located at the former Midway
Motors facility now converted into a storage facility with part-time businesses, 2139 US Highway 17
North, Merry, Bertie County, North Carolina, and will be operated in accordance with the application
received November 22, 2011, and additional information received and in conformity with the
specifications and supporting data submitted, 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 Nort Caro ma A ministrative Code 2C .0100 and .0200-,r1
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 31 day of 1 (a(r1 , 2011.
Coleen H. Sullins, Director
Division of Water Quality
By Authority of the Environmental Management Commission.
Permit No. WI0700199 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].
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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 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.
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PART VI - INSPECTIOiNb
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 Permittee shall submit As Built plans of the injection facilities, including a detailed site map,
within 30 days of completing installation of equipment.
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 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.
5. As -Built plans, 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 Washington Regional Office
943 Washington Square Mall
Washington, NC 27889
6. The Permittee shall report by telephone, within 48 hours of the occurrence or first knowledge of
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the occurrence, to the vv`ashington 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 9f an
injection well. Such a change would include the discontinued use of a well for injection. If a
well-is-taken-completely-out-ofservicetemporari3ythe-Permittee-mustinstall-asanitaryseal. Ifa
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.
(D) Drilled wells shall be completely filled with cement grout, or bentonite grout which shall
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be introduced into dre well through a pipe which extends u.e 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 beabandoned 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:
-irritation to the eyes, nose, and throat; can cause dizziness, nausea, pulmonary irritation leading
to pulmonary edema, and pneumonitis. Intense and potentially fatal pulmonary edema may
develop tracheal irritation, fever, nausea, vomiting, acute bronchitis, sinusitis, malaise,
paresthesias and conjunctivitis.
2. The application process should be reviewed by an industrial hygienist to ensure that the most
appropriate personal protective equipment is used.
3. Eating, drinking, smoking, handling contact lenses, and applying cosmetics should not be
permitted in the application area during or immediately following application.
4. Site access should be limited to worker's involved in the injection of the solution. Safety
controls should be in place to ensure that the check valve and the pressure delivery systems are
working properly.
5. It is imperative that the Material Safety Data Sheets be followed to prevent incompatible or
adverse reactions and injuries.
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