WI0700012_Application_20220929

Alatrien-
CERTIFIED MAIL
September 26, 2022
NC Division of Water Resources
Groundwater Resources Section
Attn: Michael Rogers
1636 Mail Service Center
Raleigh, NC 27699
Subject: Underground Injection Control Program
Permit Renewal Package
Injection Well Permit #WI0700012
PCS Phosphate Company, Inc.1
Tank Farm Remedial Action System
RECEIVED
SEP 2 9 2022
NC oea/owR
€:entrrol Office
Please see attached for the permit renewal package associated with Injection Well Permit #W10700012. This
package includes:
■ Completed Application for Permit to Construct and/or Use a Well for Injection (Rev. 2-17-2020)
■ Updated site map
• Status report including monitoring results of all injection activities to date
Please do not hesitate to contact me at [phone] if you have any questions regarding this renewal
package.
Sincerely,
V
James . Stroud
Supervisor, Environmental Affairs & Technical Services
Nutrien
Attachments
PC: 12-07-02 (w/ attach)
ec: T. E. Herring (w/ attach)
J. A. Casey (w/ attach)
H. B. Mills (w/ attach)
1530 NC Hwy 306 South, Aurora, NC USA 27806 _ nutrien.com
1 Effective January 1, 2018, PCS Phosphate Company, Inc. is an indirectsubsidiary of Nutrien Ltd. PCS Phosphate Company, Inc.
remains the legal operating entity and permittee.

North Carolina Department of Environmental Quality — Division of Water Resources
APPLICATION FOR PERMIT TO CONSTRUCT AND/OR USE A WELL(S) FOR INJECTION
Groundwater Remediation [15A NCAC 02C .0225)
Do not use this form for UIC wells Permitted by Rule (ref. 15A NCAC 02C .0217)
Permit Number (to be completed by DWR for new projects):
I. APPLICATION INFORMATION
1. Project is: [ ] New [ ] Modification [X] Renewal without modification [ ] Renewal with modification
2. If this application is being submitted for Renewal and/or Modification to an existing permit, provide:
Existing permit number WI0700012 Issued Date: 2/2/2018 & Expiration Date: 1/31/2023
For all Renewals, attach an updated site map and status report including monitoring results of all injection activities
to date.
For Renewal without modification only, fill out sections I & H only, sign the certification on the last page of this form,
and obtain the property owner's signature to indicate consent (if the applicant is not the owner).
H. WELL OWNER(S)/PERMIT APPLICANT (generally the responsible party)
1. Name(s): PCS Phosphate Company, Inc.
2. Signing Official's Name*: William Ponton Title: General Manager
* Signing Official must be in accordance with instructions in Part XII.
3. Mailing address of Permittee/Applicant: 1530 NC HWY 306 South
City: Aurora _ State: NC Zip: 27806
4. Telephone number: 252-402-6044 Email: _ iames.stroudgnutrien.com
5. Status (choose one): Individual X Business/Org. Federal State County Municipality
III. PROPERTY OWNER(S) (if different than well owners)
1. Name(s):
2. Mailing address:
City: State: Zip:
3. Telephone number: Email:
IV. PROJECT CONTACT — (generally the environmental/engineering consultant).
1. Name: Title:
2. Company:
3. Address:
4. City: State: Zip:
5. Telephone number: Email:
Groundwater Remediation Application Rev. 2-17-2020 Page 1 of 8

V. FACILITY INFORMATION
1
2
3
Facility name: Phone No. (if available
Physical address:
City: County:
Zip:
Geographic Coordinates: Latitude: Longitude:
Reference Datum: Accuracy:
Method of Collection (i.e., Google Earth, GPS, etc.):
4. Brief description of business:
VI. INCIDENT DESCRIPTION
1. Source and date of contamination:
2. List all contaminants present in soils or groundwater at the site (contaminants may be listed in groups, e.g., gasoline,
diesel, jet fuel, fuel oil, chlorinated ethenes, chlorinated ethanes, metals, pesticides/herbicides, etc):
3
4.
Has LNAPL or DNAPL ever been observed at the site (even if outside the injection zone)`
[ ] Yes If yes, list maximum measured separate phase thickness:
[ ] No If no, list maximum concentration of total VOCs observed at site:
Agency managing the contamination incident:
feet
ppb
[ ] UST Section [ ] Superfand Section (including REC Program and DSCA sites)
[ ] DWR Aquifer Protection Section [ ] Solid Waste Section
[ ] Hazardous Waste Section [ ] Other:
5. Incident manager's name: Phone No.:
6. Incident number or other incident mgmt. agency tracking number:
VII. PERMITS
List all applicable permits or construction approvals issued for the facility or incident:
1. Previous or other UIC permits issued by DWR (e.g., NOIs)
2. Other Non -Discharge or NPDES permit issued by DWR:
3. County or DEH subsurface wastewater disposal permits:
4. Hazardous waste management or other environmental permits required by state or federal law:
Groundwater Remediation Application Rev. 2-17-2020 Page 2 of 8

VM. INJECTION SUMMARY
1. List all proposed injectants/additives.
NOTE: Only injectants approved by the epidemiology section of the NC Division of Public Health, Department of
Health and Human Services can be injected. Approved injectants can be found online at
http://dey .nc.gov/about/divisions/water-resources/water-resources-permits/wastewater-branch/eround-water-
protection/ground-water-approved-injectants. All other substances must be reviewed by the DHHS prior to use.
Contact the UIC Program for more info if you wish to get approval for a different additive. However, please note
it may take 3 months or longer. If no injectants are to be used use N/A.
Injectant:
Total Amt. to be injected (gal)/event:
Injectant: Total Amt. to be injected (gal)/event:
Injectant: Total Amt. to be injected (gal)/event:
Injectant:
Injectant:
Total Amt. to be injected (gal/event):
No. of separate injection events:
Source of Water (if applicable):
Total Amt. to be injected (gal)/event:
Total Amt. to be injected (gal)/event:
Total Amt. to be injected (gal):
2. Estimated Injection rate per well: GPM
3. Estimated Injection pressure: oounds/square inch (PSI)
4. Temperature at point of injection: OF
5. Injection will be via:
Existing well(s)- Total No.: ; Well Type (DPT, Permanent, etc.):
Proposed well(s)- Total No.: : Well Type (DPT, Permanent, etc.):
6. NC Certified Well Drilling Contractor's Name (if known):
NC Well Contractor Certification No.:
Date to be constructed if proposed:_ [attach well construction records [GW-1 sl for
existing injection wells)
8. Screened interval/Injection interval of injection wells:
Depth from to feet below land surface (BLS)(if multiple intervals, indicate shallowest
to deepest depth)
9. Well casing (leave blank if Geoprobes®):
Type (PVC, stainless steel, other):
Casing depth: to ft. BLS
Type (PVC, stainless steel, other):
Casing depth: to ft. BLS
Groundwater Remediation Application Rev. 2-17-2020 Page 3 of 8

10. Grout (leave blank if Geoprobes):
Type (cement, bentonite, other):
Grout depth: to ft. BLS
Type (cement, bentonite, other):
Grout depth: to ft. BLS
IX. ATTACHMENTS — provide the following information in separate attachments. The attachments should be clearly
identified and presented in the order below to expedite review of the permit application package.
1. INJECTION ZONE — Per 15A NCAC 02C .022 .: specify the horizontal and vertical portion of the subsurface within
which the proposed injection activity will take place and beyond which no violations of groundwater quality standards shall
result from the injection as determined by an approved monitoring plan. The determination shall be based on the hydraulic
properties of the specified zone. Provide any supporting documentation in a separate attachment.
2. HYDROGEOLOGIC EVALUATION — Per 15A NCAC 02C .0225(t)(4). provide a hydrogeologic evaluation of the injection
zone that includes all of the following:
(A) Regional and local geology and hydrology;
(B) Changes in lithology underlying the facility;
(C) Depth to bedrock;
(D) Depth to the mean seasonal high water table;
(E) Hydraulic conductivity, transmissivity, and storativity, of the injection zone based on tests of site -specific material,
including a description of the test(s) used to determine these parameters;
(F) Rate and direction of groundwater flow as determined by predictive calculations or computer modeling;
(G) Lithostratigraphic and hydrostratigraphic logs of any existing test and injection wells; and
(H) For systems re -injecting treated on -site contaminated groundwater only- evaluation of infiltration galleries or
injection wells.
3. INJECTANT INFORMATION — Per 15A NCAC 02C .0225(l)(6), provide information on each injectant as indicated below:
(A) MSDS, concentration at the point of injection, and percentage if present in a mixture with other injectants;
(B) The source of fluids used to dilute, carry, or otherwise distribute the injectant throughout the injection zone. If any
well within the area of review of the injection facility is to be used as the fluid source, then the following information
shall be submitted: location/ID number, depth of source, formation, rock/sediment type, and a chemical analysis
of the water from the source well, including analyses for all contaminants suspected or historically recognized in
soil or groundwater on the site;
(C) A description of the rationale for selecting the injectants and concentrations proposed for injection, including an
explanation or calculations of how the proposed injectant volumes and concentrations were determined;
(D) A description of the reactions between the injectants and the contaminants present including specific breakdown
products or intermediate compounds that may be formed by the injection;
(E) A summary of results if modeling or testing was performed to investigate the injectant's potential or susceptibility
for biological, chemical, or physical change in the subsurface; and
(F) An evaluation concerning the development of byproducts of the injection process, including increases in the
concentrations of naturally occurring substances. Such an evaluation shall include the identification of the specific
byproducts of the injection process, projected concentrations of byproducts, and areas of migration as determined
through modeling or other predictive calculations.
4. INJECTION PROCEDURE — Per 15A NCAC 02C .0225(f)(7). submit a table with a detailed description of the proposed
injection procedure that includes the following:
(A) The proposed average and maximum daily rate and quantity of injectant;
(B) The average maximum injection pressure expressed in units of pounds per square inch (psi); and
(C) The total or estimated total volume to be injected.
Groundwater Remediation Application Rev. 2-17-2020 Page 4 of 8

5. FRACTURING PLAN (if applicable) — Per 15A NCAC 02C .0225tf)(9). submit a detailed description of the fracturing plan
that includes the following:
(A) Material Safety Data Sheets of fracturing media including information on any proppants used;
(B) a map of fracturing well locations relative to the known extent of groundwater contamination plus all buildings,
wells, septic systems, underground storage tanks, and underground utilities located within the Area of Review;
(C) a demonstration that buildings, wells, septic systems, underground storage tanks, and underground utilities will not
be adversely affected by the fracturing process;
(D) injection rate and volume;
(E) orientation of bedding planes, joints, and fracture sets of the fracture zone;
(F) performance monitoring plan for determining the fracture well radius of influence; and
(G) if conducted, the results of geophysical testing or pilot test of fracture behavior conducted in an uncontaminated
area of the site.
6. WELL CONSTRUCTION DETAILS — Per 15A NCAC 02C .0225it).1{�0 , submit the following information in tabular or
schematic form as appropriate for each item:
(A) number and depth of injection wells;
(B) number and depth of borings if using multi -level or "nested" well systems;
(C) indication whether the injection wells are existing or proposed;
(D) depth and type of casing;
(E) depth and type of screen material;
(F) depth and type of grout;
(G) indication whether the injection wells are permanent or temporary "direct push" points; and
(H) plans and specifications of the surface and subsurface construction details.
7. MONITORING PLAN —Per 15A NCAC 02C .0225 t 11 s. submit a monitoring plan that includes the following:
(A) target contaminants plus secondary or intermediate contaminants that may result from the injection;
(B) other parameters that may serve to indicate the progress of the intended reactions;
(C) a list of existing and proposed monitoring wells to be used; and
(D) a sampling schedule to monitor the proposed injection.
Monitoring wells shall be of sufficient quantity and location to detect any movement of injection fluids, injection process byproducts, or
formation fluids outside the injection zone. The monitoring schedule shall be consistent with the proposed injection schedule, pace of
the anticipated reactions, and rate of transport of the injectants and contaminants.
8. WELL DATA TABULATION — Per 15A NCAC 02C .0225t I7s 12 r. provide a tabulation of data on all existing or abandoned
wells within the area of review of the injection well(s) that penetrate the proposed injection zone, including monitoring
wells and wells proposed for use as injection wells. Such data shall include a description of each well's type, depth, and
record of construction or abandonment.
9. MAPS AND CROSS -SECTIONS — Per 15A NCAC 02C .0225(t)(13), provide scaled, site -specific site plans or maps
depicting the location, orientation, and relationship of facility components including the following:
(A) area map based on the most recent USGS 7.5' topographic map of the area, at a scale of 1:24,000 and showing the
location of the proposed injection site;
(B) topographic contour intervals showing all facility related structures, property boundaries, streams, springs, lakes,
ponds, and other surface drainage features;
(C) all existing or abandoned wells within the area of review of the wells listed in the well data tabulation that penetrate
the proposed injection zone;
(D) potentiometric surface map(s) that show the direction of groundwater movement, existing and proposed wells;
(E) contaminant plume map(s) with isoconcentration lines that show the horizontal extent of the contaminant plume in
soil and groundwater, and existing and proposed wells;
(F) cross-section(s) to the known or projected depth of contamination that show the horizontal and vertical extent of
the contaminant plume in soil and groundwater, major changes in lithology, and existing and proposed wells; and
(G) any existing sources of potential or known groundwater contamination, including waste storage, treatment, or
disposal systems within the area of review of the injection well or well system.
Groundwater Remediation Application Rev. 2-17-2020 Page 5 of 8

X. UIC SYSTEMS RE -INJECTING TREATED ON -SITE CONTAMINATED GROUNDWATER ONLY
1. FEES — Per 15A NCAC 02C .0225(m), submit/attach fees for new permits or modifications (refer to fee schedule
at h s://de .nc. ov/about/divisions/water-resources/water-resources- ermits/wastewater-branch/ ound-water-
rotection/non-dischar ,,e- groundwater-remediation
2. SOILS EVALUATION - Per 15A NCAC 02C .0225(f)(2), for systems with proposed discharge within seven feet
of land surface and above the seasonal high water table, a soil evaluation of the disposal site shall be provided to the
Division by the applicant. If required by G.S. 89F, a soil scientist shall submit this evaluation. This evaluation shall be
presented in a report that includes the following information:
(A) Field description of soil profile. Based on examinations of excavation pits or auger borings, the following
parameters shall be described by individual horizons to a depth of seven feet below land surface or to bedrock:
thickness of the horizon; texture; color and other diagnostic features; structure; internal drainage; depth, thickness,
and type of restrictive horizons; pH; cation exchange capacity; and presence or absence of evidence of any seasonal
high water table. Applicants shall dig pits when necessary for evaluation of the soils at the site.
(B) Recommendations concerning annual and instantaneous loading rates of liquids, solids, other wastewater
constituents and amendments. Annual hydraulic loading rates shall be based on in -situ measurement of saturated
hydraulic conductivity in the most restrictive horizon.
3. ENGINEERING PLANNING DOCUMENTS — Per 15A NCAC 02C .0225(f)(8), the following documents shall
be provided to the Division by the applicant (Note: if required by G.S. 89C, a professional engineer shall prepare
these documents):
(A) engineering plans for the entire system, including treatment, storage, application, and disposal facilities and
equipment, except those previously permitted unless they are directly tied into the new units or are critical to the
understanding of the complete process;
(B) specifications describing materials to be used, methods of construction, and means for ensuring quality and integrity
of the entire groundwater remediation system;
(C) plans that include construction details of recovery, injection, and monitoring wells and infiltration galleries;
(D) operating plans that include:
(i) the operating schedule including any periodic shut -down times;
(ii) required maintenance activities for all structural and mechanical elements;
(iii) a list of all consumable and waste materials with their intended source and disposal locations;
(iv) restrictions on access to the site and equipment;
(v) provisions to ensure the quality of the treated effluent and hydraulic control of the system at all times when
any portion of the system ceases to function, such as standby power capability, complete system -off status,
or duplicity of system components; and
(E) Completed, signed, and sealed Professional Engineer's Certification for new permit applications (form attached).
Groundwater Remediation Application Rev. 2-17-2020 Page 6 of 8

XII. CERTIFICATION (to be signed as required below or by that person's authorized agent*)
NCAC 15A 02C .0211(e) requires that all permit applications shall be signed as follows:
1. for a corporation: by a responsible corporate officer
2. for a partnership or sole proprietorship: by a general partner or the proprietor, respectively
3. for a municipality or a state, federal, or other public agency: by either a principal executive officer or
ranking publicly elected official
4. for all others: by the well owner.
*If an authorized agent is signing on behalf of the applicant, then supply a letter signed by the applicant
that names and authorizes their agent.
"1 hereby certify under penalty of law that I have personally examined and am familiar with the information
submitted in this document and all attachments therein, and that, based on my inquiry of those individuals
immediately responsible for obtaining said information, I believe that the information is true, accurate, and
complete. I am aware that there are penalties, including the possibility offines and imprisonment, for submitting
false information. I agree to construct, operate, maintain, repair, and if applicable, abandon the injection well(s)
and all related appurtenances in accordance with the approved specifications and conditions of the Permit. "
Typed or Printed Name and
William Ponton,
Date: 0i/ Z4I ZW 2-2L
XIII. CONSENT OF PROPERTY OWNER (if the property is not owned by the permit applicant)
"Owner" means any person who holds the fee or other property rights in the well being constructed. A well is real
property and its construction on land shall be deemed to vest ownership in the land owner, in the absence of contrary
agreement in writing.
"As owner of the property on which the injection well(s) are to be constructed and operated, I hereby consent to
allow the applicant to construct each injection well as outlined in this application and agree that it shall be the
responsibility of the applicant to ensure that the injection well(s) conform to the Well Construction Standards
(15A NCAC 02C . 0200). "
Typed or Printed Name and T
Signature:
Date:
Submit TWO hard copies of the completed application package with an electronic version in CD or USB Flash
Drive to:
RECEIVED DIVISION OF WATER RESOURCES — UIC PROGRAM
1636 MAIL SERVICE CENTER
SEp 2 9 2022 RALEIGH, NORTH CAROLINA 27699-1636
TELEPHONE NUMBER: [phone]
NC DEQ/DWR
Central Office
Groundwater Remediation Application Rev. 2-17-2020 Page 7 of 8

Professional Engineer's Certification (for new permit application for UIC systems re -injecting treated on -site
contaminated groundwater only):
Permit No.: WI
Typed or Printed Name of Professional Engineer:
License Number:
Name of Engineering Firm (if applicable):
Mailing Address:
City:
Office Number: ( ]
Email Address:
I,
State: Zip:
Mobile Number: (_)
s attest that this application for
has been reviewed by me and is accurate and complete to the best of my knowledge. I further attest that to the best
of my knowledge the proposed design has been prepared in accordance with the applicable regulations. Although
certain portions of this submittal package may have been developed by other professionals, inclusion of these materials
under my signature and seal signifies that I have reviewed this material and have judged it to be consistent with the
proposed design.
North Carolina Professional Engineer's Seal, Signature, and Date:
Groundwater Remediation Application Rev. 2-17-2020 Page 8 of 8

Tank Farm Remedial Action Plan Status Report
Injection Permit No. WI0700012 was originally requested to support the Tank Farm Remedial Action
Plan formulated in response to a phosphoric acid release from Tank 008 in May 1988. Past
potentiometric surface studies of the Croatan Formation have shown that the injection and withdrawal
systems are operating satisfactory to capture groundwater within the limits of the Tank Farm area. The
injected water flows northward toward the withdrawal wells, as well as southward and radially outward
from the end wells, CIW-1 and CIW-7. About 1/3 to 1/2 of the injected water is captured by the
withdrawal system.
Infection System
The injection well system was designed to operate with the water level in the Water Level Control Tank
at 12 to 15 feet MSL and the water level between withdrawal wells at -1 feet MSL. Currently, the water
level control tank is maintained between 11 to 12 feet MSL.
The injection system was also designed to operate at 19 gpm with flows varying from about 4 gpm at
CIW-I and CIW-7 to about 2 gpm at the center well, CIW-4. Since implementation, the injection
system has operated at an average of 11.6 gpm. In the past 5 years, the injection system has been
operating at an average rate of 5 gpm.
Withdraw System
The withdrawal system was designed to operate at 6 gpm with flows varying from 0.75 gpm at the
center well, CWW-4, to 1 gpm at end wells, CWW-1 and CWW-7. Since implementation, the
withdrawal system has operated at an average of 8.8 gpm. In the past 5 years, the withdrawal system
has been operating at an average rate of 1.4 gpm.
System Improvements
The observed decrease in injection rate is directly correlated to a decrease in withdrawal rates. This
change is resulting from system inefficiencies discovered in Q4 2020 and previously communicated in
our quarterly reports.
It was determined during a critical assessment of the system that 5 withdrawal wells were non-
operational. An application to construct 5 replacement wells was completed and submitted for approval.
Upon receipt of Permit No. WR0700823, the '5 replacement wells were constructed and put into service.
Each of the 14 withdraw wells were cleaned and purged to remove compacted sediment and improve
withdraw rates. A static water level study was also conducted, and all withdraw pumps were adjusted to
the appropriate depth inside of the wells.
Continued maintenance of the withdrawal system is scheduled over the next 8-12 months. These
activities are expected to improve withdrawal rates and, subsequently, improve injection rates. The site
is currently installing and completing test trials on new flowmeters to improve tracking of withdrawal
volumes and eliminate potential deficiencies with the current equipment.

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�116trien-
CERTIFIED MAIL
September 26, 2022
NC Division of Water Resources
Groundwater Resources Section
Attn: Michael Rogers
1636 Mail Service Center
Raleigh, NC 27699
Subject: Underground Injection Control Program
Permit Renewal Package
Injection Well Permit #WI0700012
PCS Phosphate Company, Inc.'
Tank Farm Remedial Action System
Please see attached for the permit renewal package associated with Injection Well Permit #W10700012. This
package includes:
■ Completed Application for Permit to Construct and/or Use a Well for Injection (Rev. 2-17-2020)
■ Updated site map
■ Status report including monitoring results of all injection activities to date
Please do not hesitate to contact me at [phone] if you have any questions regarding this renewal
package.
Sincerely,
V
James Stroud
Supervisor, Environmental Affairs & Technical Services
Nutrien
Attachments
PC: 12-07-02 (w/ attach)
ec: T. E. Herring (w/ attach)
J. A. Casey (w/ attach)
H. B. Mills (w/ attach)
1530 NC Hwy 306 South, Aurora, NC USA 27806
RECEIVED
SEP 2 9 2022
NC DEQ/DWR
Central Office
1 Effective January 1, 2018, PCS Phosphate Company, Inc. is an indirect subsidiary of Nutrien Ltd. PCS Phosphate Company, Inc.
remains the legal operating entity and permittee.
nubien.00m