HomeMy WebLinkAboutWI0500448_Permit Renewal_20220118ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
S. DANIEL SMITH
Director
Bobby Sterling
United Technologies Corporation
4200 Airport Drive NW
Wilson, NC 27896
NORTH CAROLINA
Environmental Quality
January 18, 2022
Re: Renewal of Injection Permit WI0500448
Kiddie Technologies Inc. Facility
Wilson County, NC
Dear Mr. Sterling:
In accordance with the permit renewal application received on October 1, 2021 and additional
information received January 11, 2022 we are forwarding permit number WI0500448. This permit is
to inject the following additives ABC, Vitamin B-12, Sodium Bicarbonate, ZVI, Sodium Sulfite and
potable water at the above referenced facility located at 4200 Airport Drive NW, Wilson, NC 27896.
This permit shall be effective from February 1, 2022 (i.e. the day after the expiration of current permit),
until January 31, 2027 and shall be subject to the conditions and limitations stated therein, including
the requirement to submit a Final Project Evaluation (FPE) as stated in PART VII— MONITORING
AND REPORTING REQUIREMENTS. Please read the entire permit to ensure that you are aware of
all compliance requirements of the permit.
Please note the following:
• Per Permit Condition VI.1; The proposed monitoring plan, also attached (Attachment B),
shall be followed. Any additional monitoring, including groundwater, surface water, or soil
sampling, deemed necessary to ensure surface water and groundwater protection may be
established and an acceptable sampling reporting schedule shall be followed [15A NCAC 02C
.0225(k)].
• Per permit condition Part VI.5; prior to closing this permit, the Permittee must meet
groundwater quality standards or pre -injection levels, whichever concentration is higher, for all
of the injection constituents; otherwise, continued monitoring as approved in the monitoring plan
will be required until such levels can be established.
• Per permit conditions Part VI.3 &4, and IX.2(G), within 30 days after each injection event,
please provide the well construction (if not previously submitted) and injection information on
the applicable forms listed below. Note: if well construction/abandonment information is
essentially the same (e.g., direct push points or geo-probes), then only one GW-1 or GW-30
form is needed. Just indicate in the comments section on the form the total number of well
£ D_E
NORTH CAROLINA
Ueperl roan of Environmental aeali�
North Carolina Department of Environmental Quality I Division of Water Resources
512 North Salisbury Street 11636 Mail Service Center I Raleigh, North Carolina 27699-1636
919.707.9129
points. These forms are available on the Division of Water Resource's website at Forms,
Permit & Application Tracking INC DEQ
> Injection Event Record
> Well Construction Record (GW-1)
➢ Well Abandonment Record (GW-30)
In order to continue uninterrupted legal use of this well for the stated purpose, you should submit an
application to renew the permit 120 days prior to its expiration date. As indicated in the permit, this
permit is not transferable to any person without prior notice to, and approval by, the Director of the
Division of Water Resources. If you have any questions regarding your permit or the Underground
Injection Control Program, please call me at (919) 707-3662.
Best Regards,
Rivicial
Shristi Shrestha
Underground Injection Control (UIC) - Hydrogeologist
Division of Water Resources
Groundwater Resources Section
cc: Wilson County Environmental Health Department
Caleb Krouse, AECOM, caleb.krouse@aecom.com
Kim Caulk, Division of Waste Management, kim.caulk@ncdenr.gov
£D_E
NORTH CAROLINA
North Carolina Department of Environmental Quality I Division of Water Resources
512 North Salisbury Street 11636 Mail Service Center I Raleigh, North Carolina 27699-1636
919.707.9129
Department of Environmental Quality
NORTH CAROLINA ENVIRONMENTAL MANAGEMENT
COMMISSION
DEPARTMENT OF ENVIRONMENTAL QUALITY (DEQ)RALEIGH,
NORTH CAROLINA
PERMIT FOR THE USE 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
United Technologies Corporation
Wilson County
WI0500448
FOR THE CONSTRUCTION AND/OR OPERATION OF 7 (SEVEN) IN SITU
GROUNDWATER REMEDIATION, INJECTION WELL(S) defined in Title 15A North Carolina
Administrative Code 2C .0209(5)(b)(viii), to inject the following additives (either individually or
in combination): ABC, Vitamin B-12, Sodium Bicarbonate, ZVI, Sodium Sulfite and potable water
for remediation of groundwater contaminated with chlorinated volatile organic compounds
(Attachment A). These injection wells will be located at Kiddie Technologies Inc. facility, 4200
Airport Drive NW, Wilson, NC 27896, and will be operated in accordance with the permit renewal
request received October 1, 2021, and in conformity with the specifications and supporting data
submitted January 11, 2022 all of which are filed with the Department of Environmental Quality
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 02C .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 issuance until January 31, 2027.
Permit issued the 18th day of January, 2022.
r—DocuSigned by:
td Nti L
"-97024499402C471
for S. Daniel Smith,
DirectorDivision of Water Resources
By Authority of the Environmental Management Commission.
Permit No. WI0500448 PAGE 1 OF 10
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PART I — PERMIT GENERAL CONDITIONS
1. The Permittee shall 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).
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 [15A
NCAC 02C .0211(k)].
3. This permit is valid only for construction/operation 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 Division of Water Resources (DWR) [15A NCAC.0211(a)].
4. This permit is not transferable without prior notice and approval. 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 and any supporting materials must be submitted at least 30 days prior to
the date of the change [15A NCAC 02C .0211(o)].
5. 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 [15A NCAC 02C .0203].
PART II - WELL CONSTRUCTION GENERAL CONDITIONS
1. Each injection well shall not hydraulically connect separate aquifers [15A NCAC 02C
.0211(b)].
2. Multi -screened wells shall not hydraulically connect different aquifers or zones having
differences in water quality that would result in a degradation of any aquifer or zone [15A
NCAC 02C .0225(h) (17)].
3. Each injection well shall be constructed in such a manner that water from land surface cannot
migrate into the gravel pack or well screen [15A NCAC 02C .0225(h)(4)].
4. 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. [15A NCAC .0225(h)(8)].
5. 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 shall be secured with a locking cap as defined in G.S. 87-85(16) [15A
NCAC 02C .0225(h) (23)].
Permit No. WI0500448 PAGE 2 OF 10
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6. Each injection well shall be afforded reasonable protection against damage during construction
and use [15A NCAC 02C .0225(j)(3)].
7. Each permanent injection well shall have a permanently affixed identification plate [15A
NCAC .0225(h) (20)].
8. If not previously submitted, a copy of the completed Well Construction Record (Form GW-1)
shall be submitted as described in Part VI.3 of this permit (the original document goes to the
address indicated on the form).
PART III - WELL CONSTRUCTION SPECIAL CONDITIONS
At least forty-eight (48) hours prior to constructing or operating any injection well, the
Permittee shall notify the Underground Injection Control (UIC) Central Office staff, telephone
number 919-707-9000, and the Raleigh Regional Office staff, telephone number 919-791-
4200.
PART IV - OPERATION AND USE CONDITIONS
1. The Permittee shall be required to comply with the terms and conditions of this permit evenif
compliance requires a reduction or elimination of the permitted activity [15A NCAC 02C
.0211(i)].
2. The issuance of this permit shall not relieve the Permittee of the responsibility for damages b
surface water or groundwater resulting from the operation of this facility [15A NCAC 02C
.0206].
3. The injection facility shall be properly maintained and operated at all times to achieve
compliance with the conditions of this permit and the rules of 15A NCAC 02C .0200, evenif
compliance requires a reduction or elimination of the permitted activity [15A NCAC 02C
.0211(i)].
4. In the event that the facility fails to perform satisfactorily resulting in the creation of nuisance
conditions, failure of the injection zone to adequately assimilate the injected fluid, or
daylighting, the Permittee shall take immediate corrective actions including, but not limitedto,
repairs, modifications, or abandonment of the injection facility. The Permitee shall reportnon-
compliance according to Part VI.7 of this permit [15A NCAC 02C .0206].
PAGE 3 OF 10
Permit No. WI0500448
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PART V - INSPECTIONS [15A NCAC 02C .0211(j)]
1. Any duly authorized officer, employee, or representative of the Division of Water Resources
(DWR) 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. DWR 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 VI - MONITORING AND REPORTING REQUIREMENTS
1. The proposed monitoring plan attached (Attachment B) with this permit shall be followed. Any
additional monitoring, including groundwater, surface water, or soil sampling, deemed
necessary to ensure surface water and groundwater protectionmay be established and an
acceptable sampling reporting schedule shall be followed [15A NCAC 02C .0225(k)].
2. An Annual Report with all historical monitoring results shall be submitted in bound hard copy
format with attached CD or flash drive to the UIC Program Central Office, and RaleighRegional
Office starting within one year of the first injection event. Monitoring reports shall include, a
summary of injection activities and monitoring results, analytical data presented in a
spreadsheet distinguishing between pre -injection and post injection data, and an update on the
status and location of monitoring and injection wells. Well locations may be given in a table
with the name and geographic coordinates or shown on an updated version of the site map
[15A NCAC 02C .0225(1)].
3. Records of well construction (GW-1), repair, or abandonment (GW-30) shall be submitted
within 30 days of completion of such activities [15A NCAC 02C .0225(1)]. NOTE: DPT well
points are considered wells.
4. An Injection Event Record (IER) shall be submitted within 30 days of each individual injection
event [15A NCAC 02C .0225(1)].
5. The Permittee shall submit a Final Project Evaluation (FPE) within 9 months after completing
all injection -related activity associated with this permit or produce an interim evaluation to be
submitted with a renewal application for this permit. Both the final project evaluation and
interim evaluation shall contain historical monitoring data and updated contaminant plume and
potentiometric surface maps. PLEASE NOTE: Injectants and related reaction byproducts must
attenuate to pre -injection concentrations or groundwater standards specified in rule 15A NCAC
02L .0202, whichever is greater, in order for this permit to be closed. Otherwise, corrective
action as described in Part VII may be required [15A NCAC 02C .0225(1)].
PAGE 4 OF 10
Permit No. WI0500448
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6. All monitoring results, forms, and reports required in this Part shall be submitted to:
UIC Program
NC Division of Water Resources and
1636 Mail Service Center
Raleigh, NC 27699-1628
Water Quality Regional Operations
WQROS Raleigh Regional Office
1628 Mail Service Center
Raleigh, NC 27699
7. The Permittee shall report any monitoring or other information that indicates noncompliance
with a specific permit condition, that a contaminant may cause a violation of applicable
groundwater quality standards, or that a malfunction of the injection system may cause the
injected fluids to migrate outside the approved injection zone or area. As specified in rule 15A
NCAC 02C .0211(p), noncompliance notification shall be as follows:
(A) Oral notification shall be given within 24 hours of the occurrence, or first knowledgeof
the occurrence, to the Raleigh Regional Office, telephone number 919-791-4200.
(B) Written notification shall be made within five days of the occurrence and submitted to
the addresses in Item #6 above.
(C) The written notification shall contain a description of the noncompliance and its
cause; the period of noncompliance, including dates and times; if the noncompliance
has not been corrected, the anticipated time it is expected to continue; and any steps
taken or planned to reduce, eliminate, and prevent reoccurrence of the noncompliance.
PART VII - CORRECTIVE ACTION [15A NCAC 02C .0206]
1. Any injection well not constructed or operated in accordance with this permit, or the criteria
and standards specified in 15A NCAC 02C .0200, shall be subject to corrective action as
provided under rule 15A NCAC 02C .0206.
2. The following corrective actions shall apply to elevated concentrations of injectants or reaction
byproducts resulting from the permitted injection activity:
3. Continued monitoring until concentrations return to pre -injection values or meet the standards
specified in 15A NCAC 02L .0202, whichever are greater. The frequency, duration, and
location of monitoring shall be appropriate for site specific conditions andpotential receptors.
4. Groundwater quality parameters that do not attenuate as described in 2(A) above may warrant
a corrective action plan as provided under rule 15A NCAC 02C .0206, dependingon the type,
concentration, and distribution of the groundwater quality standards being exceeded.
PART VIII - PERMIT RENEWAL [15A NCAC 02C .0211(h)]
In order to continue uninterrupted legal use of the injection facility for the stated purpose, the
Permittee should submit an application to renew the permit 120 days prior to its expiration date.
PAGE 5 OF 10
Permit No. WI0500448
ver. 9-1-2020 UIC-GW Remediation
PART IX - CHANGE OF WELL STATUS [15A NCAC 02C .0240]
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 .0240, 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 .0240, 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
groundwater.
(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 WQROS staff 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 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 .0225(1) within 30 days of completion of abandonment.
PAGE 6 OF 10
Permit No. WI0500448
ver. 9-1-2020 UIC-GW Remediation
PART X — WORKER PRECAUTIONS DURING APPLICATION [15A NCAC 02C
.0225(a)]
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.
PAGE 7 OF 10
Permit No. WI0500448
ver. 9-1-2020 UIC-GW Remediation
Attachment A
Attachment 1 Injection Plan (2022) Submitted 1/11/2022.
Injection Permit WI0500448 Kidde Technologies — Wilson, NC
The proposed injection plan includes injection into horizontal wells HW-1, HW-3, and HW-5 while
groundwater extraction operations continue at horizontal wells HW-2 and HW-4. A map of the horizontal
well locations is included on the following page. HW-1, HW-3, and HW-5 well screens are approximately
24 feet below ground surface (bgs), while HW-2 and HW-4 well screens are approximately 14 feet bgs.
The injection plan includes approximately 60,000 gallons (total) of injection mixture injected into wells
HW-1, HW-3, and HW-5 over a period of approximately 6 weeks. During this period, an estimated 60,000
to 300,000 gallons of groundwater will be extracted from HW-2 and HW-4, treated on -site via the existing
groundwater treatment system, and discharged to the sewer under an existing agreement with the City of
Wilson. The total injection event amendment mixture will include:
• Approximately 30,195 pounds of Anaerobic BioChem (ABC).
• Approximately 305 pounds of Vitamin B-12.
• Approximately 24,000 pounds of sodium bicarbonate.
• Approximately 12,000 pounds of zero valent iron (injectable liquid suspension provided by Tersus
Environmental).
• Approximately 20 pounds of sodium sulfite (oxygen scavenger).
• Up to 60,000 gallons of City of Wilson municipal water
Permit No. WI0500448 PAGE 8 OF 10
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Attachment B
Updated Injection Permit Monitoring Plan
Injection Permit WI0500448 Kidde Technologies — Wilson, NC
II
Screened
Interval
(feet bgs)
Sampling and
Analysis
Site VOCs
Field Paramet
Methane, Ethene,
Ethane
Total Organic Car
c
0
L
To
I-
Manganese
Sulfate
RCRA Metals
Total Dissolved Sc
Phosphate
E
2
15
0
N
Nitrate
Central Plume Monitoring Wells (See Note 1)
MW-03FY
10 - 30
X
X
X
X
X
X
X
X
MW-06
7.78 - 22.78
X
X
X
X
X
X
X
X
MW-12FY
8- 33
X
X
X
X
X
X
X
X
MW-13FY
8- 33
X
X
X
X
X
X
X
X
MW-15R
15-25
X
X
X
X
X
X
X
X
X
MW-27FY
10-30
X
X
X
X
X
X
X
MW-28R
15-25
X
X
X
X
X
X
X
X
PZ-1 C
10-35
X
X
X
X
X
X
X
Northern Plume Monitoring Wells (See Note 2)
MW-07
8.61 - 23.61
X
X
X
X
X
X
X
X
PZ-2B
10-20
X
X
X
X
X
X
X
MW-29R
15-25
X
X
X
X
X
X
X
MW-36FY
16-31
X
X
X
X
X
X
X
Western Plume Monitoring Wells (See Note 2
MW-10
5.75 - 20.75
X
X
X
X
X
X
X
X
MW-16R
18-25
X
X
X
X
X
X
X
X
MW-32FY
18-28
X
X
X
X
X
X
X
X
Western Plume Northern Tail Monitoring Wells (See
Note 2)
MW-17FY
7-27
X
X
X
X
X
X
X
X
MW-20FY
10-30
X
X
X
X
X
X
X
X
MW-24FY
13-28
X
X
X
X
X
X
X
X
Total Number of Wells =
18
18
10
10
18
10
1
18
13
8
8
8
Permit No. WI0500448
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UIC-GW Remediation
PAGE 9 OF 10
Notes:
1.) All monitoring plan changes indicated in the updated monitoring plan relate to analysis of Central
Plume Monitoring Wells.
The horizontal well ERD injection proposed for 2020 will be within the Central Plume.
2.) In accordance with the permit, monitoring within the Western Plume, Northern Tail, and Northern
Plume will continue with
the same monitoring wells and analysis as recent monitoring events. No additional injections are
proposed or requested in
these areas at this time.
3.) Sulfate analysis required until such time as MW-15R result reaches 250 mg/L for two straight events
4.) Field parameters will include temperature, pH, dissolved oxygen, oxygen -reduction potential, and
specific conductivity.
5.) Sampling events will be performed approximately 3 months prior to the first horizontal well injection
event (baseline),
approximately 3 months after the injection event, and semi-annually thereafter.
bgs = below ground surface
ERD = enhanced reductive dechlorination
RCRA = Resource and Conservation Recovery Act
VOC = volatile organic compound
Permit No. WI0500448 PAGE 10 OF 10
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