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Home My WebLink AboutWQ0036881_Staff Report_20180508DocuSign Envelope ID: 79791638-B930-4064-A60C-31826A532086 WQROS REGIONAL STAFF REPORT FOR UIC Program Support Permit No. WQ0036881 Date: May 8, 2018 County: Cherokee To: Michael Rogers Permittee/Applicant: Northrop Grumman Central Office Reviewer Facility Name: Former Clifton Precision Site L GENERAL INFORMATION 1. This application is (check all that apply): ❑ New ❑ Renewal ❑ Minor Modification ® Major Modification a. Date of Inspection: NA b. Person contacted and contact information: NA c. Site visit conducted by: NA d. Inspection Report Printed from BIMS attached: ❑ Yes ❑ No. e. Physical Address of Site including zip code: f. Driving Directions if rural site and/or no physical address: g. Latitude: Longitude: Source of Lat/Long & accuracy (i.e., Google Earth, GPS, etc.): II. DESCRIPTION OF INJECTION WELLS) AND FACILITY 1. Type of injection system: ❑ Geothermal Heating/Cooling Water Return ® In situ Groundwater Remediation ® Non -Discharge Groundwater Remediation ❑ Other (Specify: 2. For Geothermal Water Return Well(s) only a. For existing geothermal system: Were samples collected from Influent/Effluent sampling ports? ❑ Yes ❑ No. Provide well construction information from well tag: b. Does existing or proposed system use same well for water source and injection? ❑ Yes ❑ No If No, please provide source/supply well construction info (i.e., depth, date drilled, well contractor, etc.) and attached map and sketch location of supply well in relation to injection well and any other features in Section IV of this Staff Report. 3. Are there any potential pollution sources that may affect injection? ❑ Yes ® No 4 5 6 What is/are the pollution source(s)? What is the distance of the injection well(s) from the pollution source(s)? What is the minimum distance of proposed injection wells from the property boundary? 340 feet Quality of drainage at site: ❑ Good ❑ Adequate ❑ Poor Flooding potential of site: ❑ Low ❑ Moderate ❑ High Rev. 6/1/2015 Page 1 DocuSign Envelope ID: 79791638-B930-4064-A60C-31826A532086 WQROS REGIONAL STAFF REPORT FOR UIC Program Support 7. For Groundwater Remediation systems, is the proposed and/or existing groundwater monitoring program (number of wells, frequency of monitoring, monitoring parameters, etc.) adequate? ® Yes ❑ No. If No, attach map of existing monitoring well network if applicable and recommend any changes to the groundwater - monitoring program. 8. Does the map included in the Application reasonably represent the actual site (property lines, wells, surface drainage)? ® Yes ❑ No. If No, or no map, please attach a sketch of the site. Show property boundaries, buildings, wells, potential pollution sources, roads, approximate scale, and north arrow. 9. For Non -Discharge groundwater remediation systems only: a. Are the treatment facilities adequate for the type of waste and disposal system? ® Yes ❑ No ❑ N/A. If no, please explain: b. Are the site conditions (soils, topography, depth to water table, etc.) consistent with what was reported by the soil scientist and/or Professional Engineer? ® Yes ❑ No ❑ N/A. If no, please explain: III. EVALUATIONAND RECOMMENDATIONS 1. Do you foresee any problems with issuance/renewal of this permit? ❑ Yes ® No. If yes, explain. 2. List any items that you would like WQROS Central Office to obtain through an additional information request. Make sure that you provide a reason for each item: Item Reason Clarification on Remedial Well Construction Detail A Figure 8 and Detail D Figure 10 do not appear to match each other with respect to grout type and grout depth from land surface nor do they appear to meet 15A NCAC 02C .0225(g)(9)(B), which requires grout to land surface. Demonstration as to why remedial wells cannot 15A NCAC 02C .0225(g)(22) requires that all be constructed to 15A NCAC 02C piping, wiring, and vents shall enter the well .0225(g)(22) through the top of the casing unless otherwise approved by the Director based on a design demonstrated to preclude surficial contaminants from entering the wellhead. Clarification on Oxygen Sparge Well 15A NCAC 02C .0225(b)(4)(B) requires that air Construction injection wells be constructed in accordance with the well construction standards applicable to monitoring wells specified in 02C .0108. 15A NCAC 02C .0108(i) requires that grout be placed in the annular space between the outermost casing and the borehole wall from the land Rev. 6/1/2015 Page 2 DocuSign Envelope ID: 79791638-B930-4064-A60C-31826A532086 WQROS REGIONAL STAFF REPORT FOR UIC Program Support surface to the top of the bentonite seal. Detail B Figure 8 of the application shows the top of the cement grout at 3 feet below ground surface, whereas Detail E Figure 10 of the application only shows bentonite holeplug to 6 feet below ground surface. Clarification on proposed monitoring network See additional staff review comments below to meet 15A NCAC 02C .02250) and 15A NCAC 02T .1607 Any information needed to approve Methanol (Section H.1.), potassium hydroxide injectants/well maintenance chemicals (Section H.1.), Hydrochloric/muriatic acid (EAB proposed in the application. [ 15A NCAC 02C IM Work Plan pdf page 14), and Miracle Gro .0225 and 15A NCAC 02C .0112(g)] (Section H.5.) are proposed for either injection or well maintenance and do not appear to be approved for use in NC. The source of the extracted groundwater that To determine compliance with 15A NCAC 02L will be used to flush the pH buffer and/or .0202 and 15A NCAC 02C .0225(e)(5)(C). amendments described in Section H.5. of the application and in the EAB IM Work Plan Section 2. 3. List specific special conditions or compliance schedules that you recommend to be included in the permit when issued. Make sure that you provide a reason for each special condition: Condition Reason 4. Recommendation ❑ Deny. If Deny, please state reasons: ❑ Hold pending receipt and review of additional information by regional office ® Issue upon receipt of needed additional information ❑ Issue Rev. 6/1/2015 Page 3 DocuSign Envelope ID: 79791638-B930-4064-A60C-31826A532086 WQROS REGIONAL STAFF REPORT FOR UIC Program Support DocuSigned by. 5. Signature of report preparer(s): `5C147F587AE94 to. .�� Signature of WQROS Regional Supervisor: Date: IV. ADDITIONAL REGIONAL STAFF REVIEW COMMENTS/ATTACHMENTS (If Needed) Overall, the proposed monitoring network in the application is: (1) inadequate for the Enhanced Anaerobic Bioremediation injections, (2) somewhat vague with regard to proposed additional monitoring wells, (3) displays some minor inconsistency with the EAB IM Work Plan document provided with the application, (4) and does not address/discuss the monitoring required as part of the active groundwater remediation system. With regard to (1), the proposed monitoring plan in Attachment G.3. of the application predominately consists of performance monitoring wells within the injection zone and may not be adequate to detect the movement of injection fluids or injection process byproducts outside of the injection zone. However, there is an adequate monitoring network if the wells in the Corrective Action Monitoring Plan (CAMP) are included. This includes the following wells: MW-35, MW-12, MW-13, MW-28, MW-36, RW-2, RW-3, RW-5, CMP-1, CMP-3, CMP- 4, and SW-3. With regard to (2), MW-8 and MW-12 are included in the monitoring plan with the application. However, both of these wells are constructed in regolith. There are several references to constructing additional transition zone and bedrock wells at the locations of MW-8 and MW-12 "if appropriate". See Figure 3 in application. We need clarification on whether these wells will, or will not, be constructed. With regard to (3), Section 5.1.2 of the EAB IM Work Plan states "the wells to monitored may change with each sampling event depending on the previous data and current operations." We need to clarify that once a monitoring plan is approved, it is incorporated into the permit and may not change without a permit modification. With regard to (4), the application indicates the currently operating groundwater treatment injection system will continue to operate, however, there is no discussion of the monitoring associated with that portion of the system. Overall, the Division needs to make clear to the applicant, that they will be required to sample all of the wells listed in Section G3 of the application for the constituents and the frequency proposed until the permit is rescinded and the data must be submitted annually. In addition, we need to make clear that the applicant shall continue to conduct the monitoring that was required in the first version of the permit. Note that this monitoring includes the additional CAMP wells noted above. Rev. 6/1/2015 Page 4