WI0100106_Staff Report_20181008

DocuSign Envelope ID: B21B585C-F2A8-4677-8870-A41437EDC858
WQROS REGIONAL STAFF REPORT FOR
UIC Program Support
Permit No. WI0100106
Date: October 8, 2018 County: Buncombe
To: Michael Rogers Permittee/Applicant: Milkco Inc.
Central Office Reviewer Facility Name: Former Andrex Industries Facility
L GENERAL INFORMATION
1. This application is (check all that apply): ❑ New ® Renewal
❑ Minor Modification ❑ Major Modification
a. Date of Inspection:
b. Person contacted and contact information:
c. Site visit conducted by:
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? —200 feet
Quality of drainage at site: ❑ Good ® Adequate ❑ Poor
Flooding potential of site: ® Low ❑ Moderate ❑ High
Rev. 6/1/2015
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DocuSign Envelope ID: B21B585C-F2A8-4677-8870-A41437EDC858
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. See staff review comments.
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
Injection monitoring plan for RW-1 and RW-5.
Injections are proposed into RW-1 and RW-5 as
noted on Table 2 of the renewal application.
However, there is no injection monitoring plan
included on Table 6 for these wells.
Confirmation that, if constructed, IW-10 will
It's difficult to determine whether MW-44 is an
be installed as an "above rock" well. If not,
appropriate monitoring point for IW-10, as is
MW-44 may not be an appropriate monitoring
proposed on Table 6, as it is not clear in what
point for a bedrock injection well.
aquifer zone IW-10 will be installed. MW-44 is
screened in saprolite/partially-weathered rock
(PWR).
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
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DocuSign Envelope ID: B21B585C-F2A8-4677-8870-A41437EDC858
WQROS REGIONAL STAFF REPORT FOR
UIC Program Support
❑ 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 DocuSigned by:
5. Signature of report preparer(s): n0G,,Smgnci by,
5C147F587AE940 ...
Signature of WQROS Regional Supervisor: l r
7E617A38285848C...
Date: 10/8/2018
IV ADDITIONAL REGIONAL STAFF REVIEW COMMENTS/ATTACHMENTS (If Needed)
The previous version of the injection permit, issued December 13, 2013, required that MW-13, MW-14, and
MW-23 be sampled at 30- and 150-day intervals, in addition to the proposed 90-day interval, following
injection into IW-7 and IW-10. MW-13 and MW-14 were proposed monitoring points associated with injection
into IW-7 and MW-23 was the proposed monitoring point associated with IW-10. During the previous permit
period, injections did not occur within IW-7 or IW-10, and therefore the monitoring associated with these
injections wells was not required. Table 6 included with the current renewal application does not include the
30- and 150-day monitoring schedule for these wells as was required in the previous version of the permit. Note
that the proposed location of IW-10 has moved since the 2013 application so that MW-23 is no longer
gpplicable for evaluation of injection into IW-10 and is not proposed as a monitoring point associated with IW-
10. Rather, it is now a monitoring point associated with IW-9. It may be advantageous to note the requirements
for MW-13 and MW-14 if the consultant is contacted regarding RW-1, RW-5, and IW-10.
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