WQ0035324_Rescission Request_20221031

Via E-Mail
October 31, 2022
Mr. Michael Rogers
North Carolina Depailment of Environmental Quality
Division of Water Resources
1636 Mail Service Center
Raleigh, North Carolina 27699-6464
Re: Groundwater Remediation System Closure Report
Former Pro Cleaners
8377 Creedmoor Road
Raleigh, Wake County, North Carolina
DSCA Site ID DC920001
DWR Permit No. WQ0035324
H&H Job No. DSO-130J
Dear Mr. Rogers:
1.0 Introduction
hart '%.1 hickman
SMARTER ENVIRONMENTAL SOLUTIONS
Hart & Hickman, PC (H&H) has prepared this Groundwater Remediation System Closure Report
for the remediation system located at 8377 Creedmoor Road in Raleigh, North Carolina. The
system was installed as part of groundwater remediation efforts associated with the Pro Cleaners
dry-cleaning solvent release site (DSCA Site ID DC920001). H&H performed the closure
activities under contract to the North Carolina Depailiuent of Environmental Quality (DEQ) Dry-
cleaning Solvent Cleanup Act (DSCA) Program. The closure activities are regulated by the DEQ
Division of Water Quality (DWR) under Groundwater Remediation Permit No. WQ0035324 the
closure requirements detailed in Title 15A NCAC 02C .0240(f). The work was performed in
accordance with the Groundwater Remediation System Closure Plan dated May 18, 2022, and
approved by the DWR in an email dated July 8, 2022.
2923 South Tryon Street, Suite 100
Charlotte, NC 28203
704.586.0007 main
3921 Sunset Ridge Rd , Suite 301
Raleigh, NC 27607
919.847.4241 main
www.harthickman.com

Mr. Michael Rogers
October 31, 2022
Page 2
2.0 Background
The groundwater remediation system consisted of an In -Situ Delivery (ISDTM) system, which
extracted groundwater, treated it with carbon filtration and CarBstrateTM amendment for enhanced
reductive dechlorination, then reinjected the treated groundwater. Figure 1 depicts the location of
the former remediation system and associated remediation wells. Table 1 summarizes well
construction details for the remediation wells.
Operation of the ISDTM system was initiated on August 28, 2012. The system initially operated in
a limited pilot study area from August 28, 2012 through February 25, 2013. The full-scale system
was then installed and began operation on September 10, 2013. Until May 2016, the full-scale
recirculation system extracted groundwater from three 2-inch diameter polyvinyl chloride (PVC)
extraction wells (EW-8, EW-9, and EW-10). In April 2016, one 4-inch diameter PVC extraction
well (EW-9A) was installed to replace EW-9 and to enhance the system's extraction rate. The
system extracted groundwater from wells EW-8, EW-9A, and EW-10 between April 2016 and
August 12, 2020, when the system was shut down.
Extracted groundwater was treated with two AF-500 granular activated carbon (GAC) vessels,
mixed with CarBstrateTM amendment, then reinjected through injection wells, all on an automated
and continual basis. Injection wells IW-1 through IW-7 are 2-inch diameter injection wells
installed during the pilot testing phase. During the full-scale implementation in 2013, wells IW-1,
IW-5, and IW-7 were replaced with 4-inch diameter injection wells IW-1A, IW-5A, and IW-7A
to enhance injection effectiveness. Injection ceased on August 12, 2020, when the system was shut
down.
Components of the ISDTM system included an injection pump, booster pump, solution tank, mixer,
metering pump, air -actuated ball valves, flow meters, compressor, pressure gauges, and touch
screen programmable logic controller (PLC) component. The equipment was housed in a weather-
proof, insulated walk-in enclosure that was skid -mounted. The remediation piping consisted of 1
to 2-inch diameter PVC pipe installed horizontally at a depth of approximately 2 feet below ground
hart hickman
https://harthick.sharepoint.com/sites/MasterFiles-1/Shared Documents/AAA-Master Projects/DSCA - DSO/DSO-130 Pro Cleaners/Remediation/Closure
Rpt/DC920001 20221031_ClosureRpt.docx
SMARTER ENVIRONMENTAL SOLUTIONS

Mr. Michael Rogers
October 31, 2022
Page 3
surface (bgs), covered with a washed pea gravel and ABC crusher run, and stubbed up outside of
the northern side of the building.
As referenced above and documented in prior correspondence to the NC DWR, the system was
shut down on August 12, 2020. Based on the review of groundwater monitoring data, system
performance data, and a cost -benefit evaluation, the DSCA Program elected to keep the system
shut down and requested that H&H properly decommission the system. A letter from the DSCA
Program authorizing closure of the system is included in Attachment 1. Note that H&H is
continuing ongoing monitoring of selected monitoring wells and downgradient water supply wells
under the direction of the DSCA Program.
3.0 System Closure Activities
Before conducting remediation system closure activities, H&H prepared a health and safety plan
(HASP) for the site per the Occupational Safety and Health Administration (OSHA) guidelines.
The HASP detailed measures to be taken to protect worker safety during field activities.
H&H subcontracted Contaminant Control Inc. (CCI) to complete decommissioning of the
groundwater remediation system. System decommissioning and closure activities were completed
in three phases (Phase I, Phase II, and Phase III). On July 25, 2022, Phase I of the system
decommissioning was completed and included the removal of spent carbon utilizing a pressure
washer and vacuum truck. Spent carbon and associated fluids were drummed on -site for
subsequent transportation and disposal as F002-listed hazardous waste at an approved hazardous
waste disposal facility. Waste disposal manifests are included in Attachment 2. In addition, CCI
removed bollards surrounding the remediation system building and contracted a licensed
electrician to disconnect the remediation system wiring.
The remediation system building, associated piping at the building, down well system pumps, and
the system holding tank were leased from ETEC Advanced Bioremediation Solutions (ETEC) by
the DSCA Program. On August 2, 2022, Phase II work was performed during which ETEC
hart hickman
https://harthick.sharepoint.com/sites/MasterFiles-1/Shared Documents/AAA-Master Projects/DSCA - DSO/DSO-130 Pro Cleaners/Remediation/Closure
Rpt/DC920001 20221031_ClosureRpt.docx
SMARTER ENVIRONMENTAL SOLUTIONS

Mr. Michael Rogers
October 31, 2022
Page 4
personnel disconnected and removed all leased system components from the site.
On August 22, 2022, CCI returned to the site to complete the final system closure activities (Phase
III). Phase III activities included the cutting of subsurface remediation system piping connecting
the system to the associated injection and extraction wells. Where the piping previously connected
to the system, the piping was cut flush with the ground surface. Where the piping previously
connected to the injection and extraction wells, the piping was cut within the manhole. Following
disconnection, grout was pumped into the piping at both ends of piping runs. Down well pumps
and other equipment were removed from the wells. In addition, CCI completed the removal of
system tanks that previously contained the spent carbon, demolition of the system building's
concrete pad, and parking lot restoration activities. Photographs documenting the remediation
system closure activities are included in Attachment 3.
On October 3 and 14, 2022, H&H completed additional follow-up activities to convert the injection
and extraction wells to groundwater monitoring wells and ensure compliance with Title 15A
NCAC 02C 2C well construction regulations. These activities included removal of some sediment
that had accumulated in the well vaults, topping off of grout within the well vaults, and installation
of new well caps.
4.0 Certification
I certify that I am a qualified groundwater scientist who has received a baccalaureate or post -graduate
degree in the natural sciences or engineering, and has sufficient training and experience in
groundwater hydrology and related fields, as demonstrated by state registration and completion of
accredited university courses. I further certify that the remediation system closure activities
documented in this report were completed in accordance with the approved Groundwater
Remediation Closure Plan, and that the information submitted is complete, factual, and accurate.
hart hickman
https://harthick.sharepoint.com/sites/MasterFiles-1/Shared Documents/AAA-Master Projects/DSCA - DSO/DSO-130 Pro Cleaners/Remediation/Closure
Rpt/DC920001 20221031_ClosureRpt.docx
SMARTER ENVIRONMENTAL SOLUTIONS

Mr. Michael Rogers
October 31, 2022
Page 5
If you have questions or require additional information, please contact Genna Olson at (919) 723-
2511.
Very truly yours,
Hart & Hickman, PC
Genna Olson, PG
Principal Geologist
.pF 0L9?,
'I'Nq KG�s'
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Attachments: Table 1, Figure 1, Attachment 1 — Letter from DSCA Program, Attachment 2 —
Waste Disposal Manifest, Attachment 3 - Photograph Log
cc: David Kwiatkowski, DSCA Program
hart hickman
https://harthick.sharepoint.com/sites/MasterFiles-1/Shared Documents/AAA-Master Projects/DSCA - DSO/DSO-130 Pro Cleaners/Remediation/Closure
Rpt/DC920001 20221031_ClosureRpt.docx
SMARTER ENV RONMENTAL SOLUTIONS

TABLE
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hickman
SMARTER ENVIRONMENTAL SOLUTIONS

Table 1: Remediation Well Construction Data
DSCA ID No.: DC920001
Well ID
Date Installed
mm/dd/
(mm/dd/yy)
Number of Samples
Well Depth
[feet]
feet
Well Diameter
inch
[inch]
Screen Interval
feet
[feet]
Status
Active/Inactive
� )
IW-1
11/3/08
1
47
2
29-39, 45-47
Inactive
IW-1A
7/27/13
0
47
4
29-39, 45-47
Active
IW-2
11/6/08
0
67
2
35-50, 54-60, 65-67
Active
IW-3
11/5/08
9
47
2
27-47
Active
IW-4
11/11/08
14
87
2
30-45, 55-60, 75-87
Active
IW-5
11/13/08
22
87
2
35-60, 70-87
Inactive
IW-5A
7/27/13
0
87
4
35-60, 70-87
Active
IW-6
11/14/08
1
87
2
40-50, 60-87
Active
IW-7
11/6/08
11
87
2
35-50, 60-70, 80-87
Inactive
IW-7A
7/27/13
0
87
4
35-50, 60-70, 80-87
Active
*EW-8
11/12/08
14
87
2
30-55, 60-65, 75-87
Active
*EW-9
11/11/08
15
87
2
35-45, 50-57, 62-67, 72-
87
Inactive
EW-9A
4/4/16
3
83
4
63-83
Active
*EW-10
11/17/08
1
87
2
30-55, 60-75, 80-87
Active
Note:
*Formerly injection well (IW)
Page 1 of 1

FIGURE
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SMARTER ENV3RONMENTAL SOLUTIONS

LEGEND
FORMER PRO CLEANERS
— — — — SOURCE PROPERTY BOUNDARY
PROPERTY BOUNDARY
PERMANENT MONITORING WELL
® INJECTION WELL
EXTRACTION WELL
REMEDIATION SYSTEM PIPING
TRENCH
AZALEA PLACE
0
APPROXIMATE
30
60
SCALE IN FEET
TITLE
ISDTM SYSTEM LAYOUT
PROJECT
FORMER PRO CLEANERS
DSCA SITE ID: DC920001
8377 CREEDMOOR ROAD
RALEIGH, WAKE COUNTY
hart hickman
SMARTER ENVIRONMENTAL SOLUTIONS
3921 Sunset Ridge Road
Raleigh, North Carolina 27607
919-847-4241(p) 919-847-4261(f)
License # C-1269 / #C-245 Geology
DATE: 10-25-18
REVISION NO. 0
JOB NO. DSO-130
FIGURE NO. 1

ATTACHMENT 1
LETTER FROM DSCA PROGRAM
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SMARTER ENV3RONMENTAL SOLUTIONS

ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
MICHAEL SCOTT
Director
NORTH CAROLINA
Environmental Quality
May 16, 2022
Mr. Michael Rogers
North Carolina Department of Environmental Quality
Division of Water Resources
1636 Mail Service Center
Raleigh, North Carolina 27699-6464
Re: Groundwater Remediation System Closure
Former Pro Cleaners
8377 Creedmoor Road
Raleigh, Wake County, North Carolina
DSCA Site ID DC920001
DWR Permit No. WQ0035324
Dear Mr. Rogers:
The North Carolina Division of Water Resources (NC DWR) previously issued Groundwater
Remediation Permit No. WQ0035324 for the In -Situ Delivery (ISDTM) groundwater remediation
system at the above referenced site. The system was installed under the oversight of the Dry-cleaning
Solvent Cleanup Act (DSCA) Program to address groundwater impacted by releases of dry-cleaning
solvents at the site. As documented in prior correspondence from the DSCA Program's contractor,
Hart & Hickman, PC (H&H), the system has been shut down since August 20, 2020. Based on review
of groundwater monitoring data, system performance data, and a cost -benefit evaluation, the DSCA
Program has elected to keep shut down and requested that H&H properly decommission the system.
This letter is intended to fulfill the NC DWR requirement for a letter from the oversight agency
authorizing closure of the system. A Closure Plan will be submitted by H&H under separate cover.
If you have questions, please contact me at [e-mail] or [phone].
Sincerely,
David Kwiatkowski, DSCA Project Manager
Division of Waste Management, NCDEQ
GDE
North Carolina Department of Environmental Quality I Division of Waste Management
217 West Jones Street 11646 Mail Service Center I Raleigh. North Carolina 27699-1646
919.707.8200
DeD+ulinenl al Environment, Ouali'y

ATTACHMENT 2
WASTE DISPOSAL MANIFEST
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SMARTER ENV3RONMENTAL SOLUTIONS

Please print or type.
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marked and labeled/placarded, and are in all respects in proper condition for transport according to applicable internationaland national governmental regulations. N export shipment and I am the Primary
Exporter, I certify that the contents of this consignment conform to the terms of the attached EPA Acknowledgment of Consent.
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DESIGNATED FACILITY TO EPA's e-MANIFEST SYSTEM

ATTACHMENT 3
PHOTOGRAPH LOG
iii
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SMARTER ENVIRONMENTAL SOLUTIONS

Photograph 1: View of the former Pro Cleaners groundwater remediation system.
Photograph 2: Representative view of bollard removal activities.
hart hickman
3921 Sunset Ridge Rd., Suite 301
Raleigh, NC 2607
919.874.4241(p) 919.847.4261(f)
FORMER PRO CLEANERS DSCA SITE ID: DC920001
8377 CREEDMOOR ROAD
RALEIGH, WAKE COUNTY, NORTH CAROLINA

Photograph 3: Representative view of bollard removal activities.
Photograph 4: View of completed bollard removal.
hart hickman
3921 Sunset Ridge Rd., Suite 301
Raleigh, NC 2607
919.874.4241(p) 919.847.4261(f)
FORMER PRO CLEANERS DSCA SITE ID: DC920001
8377 CREEDMOOR ROAD
RALEIGH, WAKE COUNTY, NORTH CAROLINA

Photograph 5: Representative view of spent carbon removal activities.
Photograph 6: Representative view of spent carbon removal activities.
hart hickman
3921 Sunset Ridge Rd., Suite 301
Raleigh, NC 2607
919.874.4241(p) 919.847.4261(f)
FORMER PRO CLEANERS DSCA SITE ID: DC920001
8377 CREEDMOOR ROAD
RALEIGH, WAKE COUNTY, NORTH CAROLINA

Photograph 7: Representative view of remediation system electrical wiring disconnection.
Photograph 8: Representative view of remediation system piping disconnection and building removal.
hart hickman
3921 Sunset Ridge Rd., Suite 301
Raleigh, NC 2607
919.874.4241(p) 919.847.4261(f)
FORMER PRO CLEANERS DSCA SITE ID: DC920001
8377 CREEDMOOR ROAD
RALEIGH, WAKE COUNTY, NORTH CAROLINA

Photograph 9: Representative view of remediation system building and holding tank removal.
Photograph 10: Representative view of down well pump removal.
hart hickman
3921 Sunset Ridge Rd., Suite 301
Raleigh, NC 2607
919.874.4241(p) 919.847.4261(f)
FORMER PRO CLEANERS DSCA SITE ID: DC920001
8377 CREEDMOOR ROAD
RALEIGH, WAKE COUNTY, NORTH CAROLINA

Photograph 11: Representative view of system piping disconnection activities.
Photograph 12: Representative view of extraction/injection well conversion to monitoring well.
hart hickman
Po-
3921 Sunset Ridge Rd., Suite 301
Raleigh, NC 2607
919.874.4241(p) 919.847.4261(f)
FORMER PRO CLEANERS DSCA SITE ID: DC920001
8377 CREEDMOOR ROAD
RALEIGH, WAKE COUNTY, NORTH CAROLINA

Photograph 13: Representative view of the system building's concrete pad demolition activities.
Photograph 14: Representative view of completed parking lot restoration and closure of groundwater remediation system.
hart hickman
3921 Sunset Ridge Rd., Suite 301
Raleigh, NC 2607
919.874.4241(p) 919.847.4261(f)
FORMER PRO CLEANERS DSCA SITE ID: DC920001
8377 CREEDMOOR ROAD
RALEIGH, WAKE COUNTY, NORTH CAROLINA