WQ0029191_Final Permit_20071019

O�o� W A
Michael F. Easley, Governor
rWilliam G. Ross Jr., Secretary
y North Carolina Department of Environment and Natural Resources
0 �
Coleen H. Sullins Director
Division of Water Quality
October 19, 2007
Samuel C. Itin
Total Petrochemicals USA, Inc.
1201 Louisiana Street
Suite 1800
Houston, TX 77002
Subject: Permit Number WQ0029191
Total Petrochemicals USA, Inc.
Groundwater Remediation Facility
Guilford County
Dear Mr. Itin:
In accordance with your request for modification received August 7, 2007, we are forwarding herewith Permit
No. WQ0029191, dated October 19, 2007, to Total Petrochemicals USA, Inc. for the construction and continued operation
of the subject groundwater remediation facility.
This permit shall be effective from, the date of issuance until February 8, 2011, shall void Permit No. WQ0029191
issued February 8, 2006, and shall be subject to the conditions and limitations as specified therein. Please pay particular
attention to the monitoring requirements in this permit. Failure to establish an adequate system for collecting and
maintaining the required operational information will result in future compliance problems.
If any parts, requirements, or limitations contained in this permit are unacceptable, you have the right to request
an adjudicatory hearing upon written request within thirty (30) days following receipt of this permit. This request must be
in the form of a written petition, conforming to Chapter 150B of the North Carolina General Statutes, and filed with th4e
Office of Administrative Hearings, 6714 Mail Service Center, Raleigh, NC 27699-6714. Unless such demands are made
this permit shall be final and binding.
If you need any additional information concerning this matter, please contact Peter Pozzo at [phone],
Sincerely,
Colect7 H. Sullins
cc: Guilford County Environmental Health Department
Winston-Salem Regional Office, Aquifer Protection Section
Rusty Fields,GES
Technical Assistance and Certification Unit
APS — Central Files
APS Files
One
NoilbCarolina
'VQturalilf
Aquifer Protection Section 1636 Mail Service Center Raleigh, NC 27699-1636 Telephone: [phone]
Internet: www.newaterquaiiiy.org Location: 2728 Capital Boulevard Raleigh, NC 27604 Fax 1: [phone]
Fax 2: [phone]
An Equal Opportunity/Affirmative Action Employer— 50% Recycledl10% Post Consumer Paper Customer Service: [phone]

,;.
.:
s...
i_..
"i;

NORTH CAROLINA
ENVIRONMENTAL MANAGEMENT COMMISSION
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
GROUNDWATER REMEDIATION PERMIT
In accordance with the provisions of Article 21 of Chapter 143, General Statutes of North Carolina as amended,
and other applicable Laws, Rules, and Regulations
PERMISSION IS HEREBY GRANTED TO
Total Petrochemicals USA, Inc.
Guilford County
FOR THE
construction and operation of a 72,000 GPD groundwater remediation facility consisting of an electro thermal -
dynamic stripping process combined with a vapor extraction and groundwater extraction system to remediate
petroleum hydrocarbon contaminated groundwater. Additionally, the injection of Dry Acid® Special to remove
non-conductive deposits from the electrodes, with no discharge of wastes to the surface waters, pursuant to the
application received August 7, 2007, received by the Division of Water Quality (Division), and in conformity
with the project plan, specifications, and other supporting data subsequently filed and approved by the Division
and considered a part of this permit.
This permit shall be effective from the date of issuance until February 8, 2011, shall void Permit No.
WQ0029191 issued February 8, 2006 and shall be subject to the following specified conditions and limitations:
I. PERFORMANCE STANDARDS
Upon completion of construction and prior to operation of this permitted facility, a certification must be -
received from a professional engineer certifying that the permitted facility has been installed in
accordance with this permit, the approved plans and specifications, and other supporting materials. If this
Project is to be completed in phases and partially certifiedyou shall retain the responsibility to track
further construction approved under the same permit, and shall provide a final certificate of com letion
once the entire project has been completed. Mail the Certification to: Aquifer Protection Section,
Groundwater Protection Unit, 1636 Mail Service Center, Raleigh, NC 27699-1636.
2. The Winston-Salem Regional Office, telephone number [phone], shall be notified at least forty-
eight (48) hours in advance of operation of the installed facilities so that an in -place inspection can be
made. Such notification to the regional supervisor shall be made during the normal office hours from
8:00 a.m. until 5:00 p.m. on Monday through Friday, excluding State Holidays.
The groundwater treatment system shall consistently achieve at least 95% removal of the influent
contaminants or 15A NCAC 2L Section .0202(g) Class GA Standards (whichever is higher) prior to
discharge to the injection wells once the effluent from the oil/water separator reaches a temperature of
185 °F or within 60 days following commencement of heating in each treatment zone. The treated water
discharged into the injection wells must not cause a violation of Class GA Standards for any constituent
beyond the Compliance Boundary, nor cause the migration of the contamination into unaffected areas. If
the treatment system fails to consistently achieve this standard, additional treatment units or changes in
operational needs may be required.
WQ0029191mod Page 1 of 7

4. This permit shall become voidable if the soils fail to adequately assimilate the remaining wastes and may
be rescinded unless the facilities are installed, maintained, and operated in a manner, which will protect
the assigned water quality standards of the surface and groundwaters.
5. The issuance of this permit shall not relieve the Permittee of the responsibility for damages to surface or
groundwaters resulting from the operation of this facility.
6. Any residuals generated from these treatment facilities must be disposed in accordance with General
Statute 143-215.1 and in a manner approved by the Division.
7. Diversion or bypassing of the untreated groundwater from the treatment facilities is prohibited.
H. OPERATION AND MAINTENANCE REQUIREMENTS
The facilities shall be properly maintained and operated as a non -discharge system to prevent the
discharge of any wastewater resulting from the operation of this facility. The groundwater recovery,
treatment and disposal system shall be inspected monthly. If it is determined that the system is
malfunctioning or leading to the release of wastes to the environment, a threat to human health, or a
nuisance, all repairs should be made as soon as possible and reported to the Error! Reference source not
found. Regional Office (see Section VI. NONCOMPLIANCE NOTIFICATION). All components of
the groundwater recovery, treatment, and disposal system shall be properly weatherproofed to prevent
freezing and failure of the system.
2. Upon classification of the wastewater treatment and remediation facilities by the Water Pollution Control
System Operators Certification Commission (WPCSOCC), the Permittee shall designate and employ a
certified operator to be in responsible charge (ORC) and one or more certified operator(s) to be back-up
ORC(s) of the facilities in accordance with 15A NCAC 8G .0201. The ORC shall visit the facilities in
accordance with 15A NCAC 8G .0204 or as specified in this permit and shall comply with all other
conditions specified in these rules.
3. If requested by the owner, the Division will consider remote monitoring in lieu of (frequency) physical
inspections, on a case -by -case basis, following at least two years of successful operation.
4. The Permittee shall maintain an inspection log or summary including at least the date and time of
inspection, observations made, and any maintenance, repairs, or corrective actions taken by the Permittee.
This log of inspections shall be maintained by the Permittee for a period of three years from the date of
the inspection and shall be made available to the Division or other permitting authority, upon request.
5. Any duly authorized officer, employee, or representative of the Division may, upon presentation of
credentials, enter and inspect any property, premises or place on or related to the disposal site or 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 leachate.
III. WELL CONSTRUCTION/ABANDONMENT CRITERIA
I . The extraction wells shall be constructed of solid carbon steel casing, stainless steel screen, and the
screened interval of each well shall be located from five feet to thirty-five feet below land surface.
2. The injection wells shall be constructed of steel casing and the depth of each well shall be located from
five feet to thirty-three feet below land surface. Prior to operation of the groundwater remediation system,
the permittee shall certify the mechanical integrity of the injection well(s) as defined by 15A NCAC 2C
.0207.
WQ0029191 Paget of 7

_ 3. Flow measurement devices shall be installed to monitor the volumes injected into each injection well.
Also each injection wellhead shall be equipped to measure the injection pressure at the screened interval.
If the injection pressure is greater than atmospheric pressure, the mechanical integrity of the injection
well(s) shall be demonstrated according to 15A NCAC 2C .0207.
4. Pursuant to rule 15A NCAC 2C .0211(g), injection may not commence until construction of the injection
wells is completed, the permittee has submitted notice of completion of construction to the Winston-
Salem Regional Office, and the regional office staff has inspected or otherwise reviewed the injection
well and finds it in compliance with the permit. If the permittee has not received notice from. the
Winston-Salem. Regional Office of the intent to inspect or otherwise review the injection well within 10
days after the regional office has received the notice, the permittee may commence operation of the
injection wells.
5. The well(s) must be constructed by either a North Carolina Certified Well Contractor, the property owner,
or the property lessee according to General Statutes 87-98.4(b)(2). If the construction is not performed by
a certified well contractor, the property owner or lessee, provided they are a natural person, must
physically perform the actual well construction activities. All well(s) must be constructed according to the
North Carolina Well Construction Standards (15A NCAC 2C .0108) and any local county rules.
IV. MONITORING REQUIREMENTS
1. The influent and effluent from the treatment system shall be sampled every month, and monitor wells
AMW-8S, AMW-9S, SBMW-2R/2P2D/2B shall be sampled annually (every November) for the
following parameters:
Benzene 1,2-Dibromoethane
1,2-Dichloroethane Ethylbenzene
4-Isopropyltoluene Naphthalene
Tcrt- B„ty l Alcohol Toluene
Xylenes 1,2,4-Trimethylbenzene
2-Methylnaphthalene Lead
2. The samples shall be prepared and analyzed for lead by Standard Method 3030C. Additionally, during the
initial baseline analysis and the finial site closure analysis, duplicate samples to confirm, the concentration
of EDB in the wells shall also be analyzed by EPA Method 504.1.
3. Any laboratory selected to analyze parameters must be Division of Water Quality certified for those
parameters required.
4. Any additional groundwater quality monitoring, as deemed necessary by the Division, shall be provided.
V. REPORTING REQUIREMENTS
1. Two (2) copies of the following forms shall be mailed to the address below:
a. GW-1
Well Construction Record
b. GW-30
Well Abandonment Record
c. GW-59
Groundwater Quality Monitoring: Compliance Report Form
d. GW-59A
Compliance Report Form
WQ0029191 Page3 of 7

Mail these documents to the following address: Division of Water Quality
1617 Mail Service Center
Information Processing Unit
Raleigh, NC 27699-1617
Updated blank forms (GW-1, GW-30, GW-59, GW-59A) may be downloaded from the Division of Water
Quality website at http://h2o.enr.state.nc.us/ or requested from the address mentioned above.
2. The results of the sampling and analysis must be received on forms GW-59 and GW-59A on or before the
last working day of the month following the sampling month. The data of all groundwater sampling
analyses required by the permit conditions must be reported using the most recent GW-59 and GW-59A
forms along with attached copies of the laboratory analyses.
3. For the initial sampling of the well(s), the permittee shall submit a copy of the GW-1 form with forms
GW-59 and GW-59A for each well to the address listed above. Initial GW-59 forms that do not include
copies of the GW-1 form may be returned to the permittee without being processed. Failure to submit
these forms as required by this permit may result in enforcement activities pursuant to NC General
Statutes 143-215.6A.
4. The permittee shall retain records of all monitoring information, including calibration and maintenance
records, continuous monitoring data and reports required by this permit, for at least 3 years from the date
of the sample measurement, report or application. Records of this monitoring information shall include,
but not be limited to, the following:
a. the date, exact place, and time of sampling or measurements,
b. the individual who performed the sampling or measurements,
c. the date the analyses were performed,
d. the analytical techniques or methods used, and
c. the results of such sampling, measurPments, and analyses.
The permittee shall report to the Winston-Salem Regional Office (see Section V1. NONCOMPLIANCE
NOTIFICATION) any monitoring or other information which indicates:
a. any contaminant may cause an endangerment to an underground source of drinking water,
b, any noncompliance with a permit condition due to a malfunction of the system, or
c. any cause of fluid migration outside the injection zone or area.
The written submission shall contain a description of the noncompliance and its cause, the period of
noncompliance, including exact dates and times. If the noncompliance is not corrected and is expected to
continue, steps taken or planned to reduce, eliminate, and prevent reoccurrence of the noncompliance
shall be provided to the Regional Office in a timely manner.
6. The permittee shall submit an annual report summarizing the volume and injection pressures of effluent
discharged into the injection wells and the summary results of related groundwater, influent, and effluent
monitoring, Isoconcentrations (horizontal and vertical direction) and water level contour maps shall be
prepared on an annual basis and submitted with this report. If an annual report containing this information
(e.g. corrective action plan) is required by a regulatory agency, the permittee may submit two (2) copies
of that report in lieu of the preceding information within thirty days of its publication (no later than April
30). The permittee shall submit this report to the following address: Aquifer Protection. Section,
Groundwater Protection Unit, 1636 Mail Service Center, Raleigh, NC 27699-1636.
WQ0029191 Page4 of 7

VI. NONCOMPLIANCE NOTIFICATION
I. The Permittee shall report by telephone to the Winston-Salem Regional Office, telephone number (336)
771-5000, as soon as possible, but in no case more than 24 hours or on the next working day following
the occurrence or first knowledge of the occurrence of any of the following:
a. Any occurrence at the groundwater remediation facility which results in the treatment of significant
amounts of contaminated groundwaters which are abnormal in quantity or characteristic, such as the
dumping of the contents of a basin or tank, the known passage of a slug of hazardous substance
through the facility, or any other unusual circumstances;
b. Any process unit failure, due to known or unknown reasons, that renders the groundwater treatment
and disposal system incapable of adequate treatment and disposal, such as mechanical or electrical
failures of pumps, aerators, compressors, etc.;
c. Any failure of a pumping station, sewer line, or treatment facility resulting in a by-pass directly to
receiving waters without treatment of all or any portion of the influent to such station or facility; or
d. Any time that self -monitoring information indicates that the groundwater treatment and disposal
system is not in compliance with any specified permit limitations.
2. Occurrences outside normal business hours may also be reported to the Division's Emergency Response
personnel at telephone number [phone] or to the Emergency Management's switchboard at (919)
733-3300. Also, persons reporting such occurrences by telephone shall file a written report within five
(5) days following first knowledge of the occurrence. This report must outline the actions taken, or
proposed to be taken to ensure that the problem does not recur.
VH. APPLICABLE BOUNDARIES
The COMPLIANCE BOUNDARY for the disposal system is specified by regulations in 15A NCAC 2L,
Groundwater Classifications and Standards. The Compliance Boundary for the disposal system
individually permitted on or after December 30, 1983 is established at either (1) 250 feet from the waste
disposal area, or (2) 50 feet within the property boundary, whichever is closest to the waste disposal area.
An exceedance of Class GA Standards at or beyond the Compliance Boundary is subject to re -mediation
action according to 15A NCAC 2L .0106(d)(2).
2. The REVIEW BOUNDARY is established around the disposal systems midway between the Compliance
Boundary and the perimeter of the waste disposal area. Any exceedance of Class GA Standards at the
Review Boundary may require action in accordance with 15A NCAC 2L .0106(d)(1).
VM. GENERAL CONDITIONS
Issuance of this permit does not constitute approval for reimbursement from the Leaking Petroleum
Underground Storage Tank Cleanup Fund (15A NCAC 2P) or any other fund. Additionally, the issuance
of this permit does not remove the permittee's responsibility to comply with the corrective action
requirements of the Division of Waste Management. Furthermore, the permittee should notify and report
all changes concerning the remedial system to the Division of Waste Management. It is the permittee's
responsibility to comply with the requirements of all involved agencies.
2. This permit shall become voidable unless the facilities are constructed in accordance with the conditions
of this permit, the approved plans and specifications, and other supporting data.
I This permit is effective only with respect to the nature and volume of wastes described in the application
and other supporting data.
WQ0029191 Pages of 7

This permit is not transferable. In the event there is a desire for the facilities to change ownership, or
there is a name change of the Permittee, a formal permit request must be submitted to the Division
accompanied by an application fee, documentation from the parties involved, and other supporting
materials as may be appropriate. The approval of this request will be considered on its merits and may or
may not be approved.
5. A set of approved plans and specifications for the subject project must be retained by the Permittee for the
life of this project.
6. Failure to abide by the conditions and limitations contained in this permit may subject the Permittee to an
enforcement action by the Division in accordance with North Carolina General Statute 143-215.6A to
143-215.6C.
7. The annual administering and compliance fee must be paid by the Permittee within thirty (30) days after
being billed by the Division. Failure to pay the fee accordingly may cause the Division to initiate action
to revoke this permit as specified by 15A NCAC 2T .0105 (e)(3).
The issuance of this permit does not preclude the Permittee from complying with any and all statutes,
rules, regulations, or ordinances, which may be imposed by other government agencies (local, state, and
federal), which have jurisdiction..
9. Sixty (60) days prior to closure of the injection wells, the permittee must request a rescission of the permit
from the Division of Water Quality. Guidelines for the closure of the injection wells may be obtained
from http-.//h2o.enr.state.nc.us or requested from the Division of Water Quality.
10. If the permittee wants to continue operation of this system, at least six (6) months prior to the expiration
of this permit, the permittee shall request its extension. Upon receipt of the request, the Commission will
review the adequacy of the facilities described therein, and if warranted, will extend the permit for such
period of time and under such conditions and limitations as it may deem appropriate.
Permit issued this the nineteenth day of October 2007
NORTH CAROLINA ENVIRONMENTAL MANAGEMENT COMMISSION
Coleen H. Sullins, Director
Division of Water Quality
By Authority of the Environmental Management Commission
Permit Number WQ0029191
WQ0029191 Page6 of 7

Pen -nit No. WQ0029191.
ENGINEER'S CERTIFICATION
Partial Final
1, , as a duly registered Professional Engineer in the State of
North Carolina, having been authorized to observe (periodically, weekly, full time) the construction of the project,
Project Nance
Location and County
for the Permittee hereby state that, to the best of my abilities, due care and diligence was used in the observation
of the construction such that the construction was observed to be built within substantial compliance and intent of
this permit, the approved plans and specifications, and other supporting materials.
Signature
Date
Registration No.
WQ0029191mod Page 7 of 7