Wi0500448_Staff Report_20211210

WQROS STAFF REPORT
Date: December 10, 2021
To: Groundwater Resources CO
Central Office Reviewer: Shristi Shrestha
Regional Office Inspector: Eric Rice (RRO)
L GENERAL INFORMATION
1. This application is (check ali that apply): ❑ New ® Renewal
❑ Minor Modification 0 Major Modification
❑ Surface Irrigation 0 Reuse ❑ Recycle ❑ High Rate Infiltration ❑ Evaporation/Infiltration Lagoon
O Land Application of Residuals
❑ Distribution of Residuals
❑ Attachment B included
El Surface Disposal
0 503 regulated ❑ 503 exempt
❑ Closed -loop Groundwater Remediation ® Other Injection Wells (including in situ remediation)
Was a site visit conducted in order to prepare this report? ❑ Yes or ® No.
II. EVALUATION AND RECOMMENDATIONS
County: Wilson
Permittee: United Technologies Corp.
Project Name: Kidde Technologies
# WI0500448
1. Provide any additional narrative regarding your review of the application.: Application is requesting the
renewal of the existing permit without any modification. The Semi -Annual Progress Report dated December
2020 was utilized for the RRO review. In a conversation with permittee representatives it was indicated that a
more recent report has been submitted to the Division, the Regional Office could not locate the report nor was it
located in laserfiche. Please note that in the most recent permit renewal no additional injections were requested
for the Northern Plume, Western Plume, and Western Plume Northern Tail areas. Only the Central Plume area
with the horizontal well configuration is where it is understood that additional injection events are being
requested for this permit renewal. The most recent permit approval does not appear to have a limitation on
injection volumes or frequency of injection events. The injection event in 2020 consisted of 6300 gallons of
ABC, 3000 gallons of a pH buffer and 3 pounds of vitamin B-12, The total injection volumes should be some
indication of injection limitations for future events. The August 2020 injection appears to be the sole injection
event under the last permit approval. RRO recommends some limitations are put in place on future injection
volumes and frequency of events. If the groundwater seepage velocity (site average is approx.65 ft/yr) is used as
a benchmark in the assumption as to when the leading edge of a particular injection event will be noted in
downgradient wells PZ-IC, MW-13FY, MW-27FY, the earliest expected noted effect on geochemistry would
be in well PZ-1C which is located approximately one years' time of travel from the injection area. Wells MW-
13FY and MW-27FY geochemical changes related to an injection event would be around two and a half year's
time of travel. Also, a review of the 2020 Semi -Annual report appears to not have silver, phosphate and sodium
which are required parameters based on the injectants that have been used. In a conversation with the permittee
representative (12-9-21) it was stated that these parameters were analyzed for following the injection event.
RRO request that CO confirm the correct parameters are being analyzed per the approved the permit for this
renewal request.
FORM: Kidde Tech W10500448 2021 RenewalRenewal 2021 1

12/10/2021