WQ0035324_Staff Report_20181203

WATER QUALITY REGIONAL OPERATIONS STAFF REPORT
Date: 11/29/2018 County: Wake
To: WQ Regional Operations CO Permittee:
Central Office Reviewer: Facility Name: Former Pro Cleaners
Regional Office Inspector: Permit# WQ0035324
L GENERAL INFORMATION
1. This application is(check all that apply): ❑New ❑Renewal
❑Minor Modification®Major Modification
El Surface Irrigation❑Reuse❑Recycle❑High Rate Infiltration❑Evaporation/Infiltration Lagoon
❑Land Application of Residuals ❑Attachment B included ❑503 regulated ❑503 exempt
❑Distribution of Residuals ❑ Surface Disposal
❑ Closed-loop Groundwater Remediation ❑ Geothermal Water Return
Was a site visit conducted in order to prepare this report? ❑Yes or❑No.
a. Date of site visit:
b. Person contacted and contact information:
c. Site visit conducted by:
d. Inspection Report Attached: ❑Yes or❑No.
2. Is the following information entered into the BIMS record for this application correct?
❑Yes or❑No. If no,please complete the following or indicate that it is correct on the current application.
For Disposal and Injection Sites:
(If multiple sites either indicate which sites the information applies to, copy and paste a new section into the
document for each site, or attach additional pages for each site)
a. Location(s):
b. Driving Directions:
c. USGS Quadrangle Map name and number:
d. Latitude: Longitude:
IV. INJECTION WELL PERMIT APPLICATIONS(Complete these two sections for all systems that use injection
wells,including closed-loop groundwater remediation effluent injection wells,in situ remediation injection wells,and heat
pump injection wells.)
Description Of Well(S)And Facilities—New,Renewal,And Modification
1. Type of injection system:
❑Heating/cooling water return flow
❑ Closed-loop heat pump system
®In situ remediation(51)
FORM: ??? 1

WATER QUALITY REGIONAL OPERATIONS STAFF REPORT
❑ Closed-loop groundwater remediation effluent injection(5L/"Non-Discharge")
❑ Other(Specify: )
2. Does system use same well for water source and injection? ® Yes ❑No
3. Are there any potential pollution sources that may affect injection? ❑Yes ❑No
What is/are the pollution source(s)? What is the distance of the injection well(s)from the
pollution source(s)?
4. Quality of drainage at site: ❑ Good ❑Adequate ❑Poor
5. Flooding potential of site: ❑Low ❑Moderate ❑High
V. EVALUATIONAND RECOMMENDATIONS
1. Provide any additional narrative regarding your review of the application.: Heart&Hickman(H&H)In-Situ
Delivery's(ISD)treatment performance is limited by the injection rate of the injection wells and the aquifer's
ability to accept treated groundwater. H&H plans a major modification to the current remediation system by
use of a secondary discharge of treated groundwater into the City of Raleigh's municipal sewer. This will allow
for greater recovery and treatment of contaminated groundwater.H&H does not specify in the modification
request: 1)volume of treated groundwater to be disposed of in the sewer, but that it will be agreed upon
between the City of Raleigh and H&H prior to discharge of treated groundwater,2)volume of water that the
ISD is capable of treating and how that compares with the additional volume to be treated and discharged to
Raleigh's sewer system, and 3)how they plan to discharge treated groundwater into the sewer system.After
emailing Justin Ballard with H&H with Raleigh Regional Office's(RRO)questions(see attached email
correspondence),the RRO is satisfied with the answers. The DWR RRO approves H&H's permit modification
request as outlined in the October 2,2018 Non-Discharge Remediation Permit Application.
2. Do you foresee any problems with issuance/renewal of this permit? ❑Yes ❑No. If yes,please explain
briefly.
3. List any items that you would like APS Central Office to obtain through an additional information request.
Make sure that you provide a reason for each item:
Item Reason
4. List specific Permit conditions that you recommend to be removed from the permit when issued. Make sure
that you provide a reason for each condition:
FORM: ??? 2

WATER QUALITY REGIONAL OPERATIONS STAFF REPORT
Condition Reason
5. 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
6. Recommendation: ❑Hold,pending receipt and review of additional information by regional office; ❑Hold,
pending review of draft permit by regional office; ® Issue upon receipt of needed additional information; ❑
Issue-sample results pending; ❑Deny. If deny, please state reasons:
7. Signature of report preparer(s):
Signature of APS regional supervisor: ' l" 3/�
Date:
Attachments:
Email correspondence between Justin Ballard(Hart&Hickman)and Brion N.Byers(DWR: RRO).
FORM: ??? 3

Byers, Brion N
From: Justin Ballard <[e-mail]>
Sent: Wednesday, November 28, 2018 1:40 PM
To: Byers, Brion N
Cc: Rogers, Michael; Bolich, Rick
Subject: [External] RE: Former Pro Cleaners -WQ0035324 - Permit Modification
CAUTION:bi e nail oo NM @finT'�(n`ma?g{ �; -r ml4:3 1 -r.oil s etc) '-,rn flIY In . IG19,'-C'
Report Spam.
Brion, •
Please see my comments below in blue and let me know if you have any further questions. Thanks!
Justin
From: Byers, Brion N <[e-mail]>
Sent:Tuesday, November 27, 2018 2:00 PM
To:Justin Ballard <[e-mail]>
Cc: Rogers, Michael<[e-mail]>; Bolich, Rick<[e-mail]>
Subject: Former Pro Cleaners-WQ0035324- Permit Modification
Mr. Ballard,
I have been reviewing your Permit Modification request for the Former Pro Cleaners (DSCA Site#92-0001) and have a
few questions.
1) Permit No. WQ0035324 effective August 1, 2016, specifically states that the permit is for a 12,960 gpd
groundwater remediation facility.Since your modification requests to increase the volume of recovery,
treatment, and discharge of additional groundwater to the City of Raleigh's sewer system,what additional
volumes are expected? How much will the City of Raleigh allow to be discharged to their sewer system? The
original UIC permit application requested a 12,960 gpd limit; however,treatment rates over the past year have
been approximately 1,000 gpd. As such,we are not asking for an increase to the approved 12,960 gpd but
rather approval to modify how the treated groundwater is discharged (i.e. no longer strictly to the injection well
network). For the portion that will go to the City of Raleigh's sewer system,we have asked the City to grant us a
7,000 gpd in our City of Raleigh Industrial User Permit application. Note that I have received verbal approval for
that amount but expect to have the final Industrial User Permit sometime in the next 1-2 weeks. I can forward to
you once I receive if you'd like.
2) With the additional groundwater being treated, is there an expected drop in effectiveness and/or efficiency of
the GAC filters?What is the effective treatment rate for the GAC filters? Do you expect any need for additional
sampling and/or maintenance of the system? The current GAC filter setup is designed for'the 12,960 gpd
amount that was applied for in the original permit application. As such, we do not expect a drop in effectiveness
and/or efficiency since we will still be well below that threshold. However,we are proposing to increase our
current quarterly GAC sampling(pre, mid, and post-GAC samples for each event)to monthly sampling to
monitor the GAC vessels ability to handle the additional treatment volume.
3) Lastly, the permit modification request did not state how H&H plans to discharge excess treated groundwater to
the City of Raleigh's sewer system, could you explain how you plan to connect to the sewer system? H&H
proposes to discharge treated groundwater into the City of Raleigh's sewer system via a proposed conduit that
will be connected to existing sewer infrastructure. The conduit will have a flow meter so that we are able to
monitor discharge volumes. The installation will occur at a manhole located approximately 30'from system. All
1

installation work will be permitted and inspected by the City of Raleigh and the discharge will be permitted by
the City of Raleigh Industrial User Permit.
Please feel free to call me if you have any questions.
Thank you,
Brion
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Brion N. Byers, P.G.
Hydrogeologist
Division of Water Resources—Raleigh Regional Office
Department of Environmental Quality
[phone] office
brion.byersancdenr.gov
Physical: 3800 Barrett Drive, Raleigh, NC 27609
Mailing: 1628 Mail Service Center, Raleigh, NC 27699-1628
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