DEQ-CFW_00075001

Cycle No.
Date(s)
Amount
injected
Amount
withdrawn/recove
red
Amount flushed for
sampling / routine
operation
Amount Stored
Comments
1
2/21/2013
0
0
0
0
Begin Cycle 1 Injection -
1
5/2/2013
26.583
0
0.263
26.32
End Cycle 1 injection
1
10/1/2013
26.583
0
1.272
25.312
Begin Cycle 1 Recovery (To System / Flouride Tracer Study)
1
10/6/2013
26.583
5.257
1.347
19.979
Pause Cycle 1 Recovery (Sand Issues / Recovery to System End)
1
12/26/2013
26.583
5.257
1.425
19.9
Resume Cycle 1 Recovery (To Pond / Surface)
1
12/31/2013
26.583
5.257
7.573
13.753
End Cycle 1 Recovery Pumping
1
3/4/2014
26.583
5.257
7.573
13.753
End Cycle 1 - Total Remaining Bubble 13.753 MG (Reset all totalizers to zero to begin cycle 2)
2
3/5/2014
0
0
0
0
Begin Cycle 2 injection
2
6/13/2014
28.714
0
0.172
28.542
End Cycel 2 injection (Pump removed and well screen and sili-bead gravel pack added)
2
10/18/2016
28.714
0
0.473
28.24
Begin Cycle 2 Recovery (Recovered To System / Flushing totals to Surface Pond)
2
11 /12/2016
28.714
17.5631
0.49
10.661
End Cycle 2 Recovery
2
3/27/2017
28.714
17.53
0.605
10.546
End Cycle 2 - Total Remaining Bubble 10.546 (Reset all totalizers to zero to begin cycle 3)
3
3/28/2017
0
0
0
0
Begin Cycle 3 injection
3
6/5/2017
24.58
0
0.056
24.525
End Cycle 3 injection (Cycle 3 Is not complete, Recovery Remains)
N
CUETOTAL
E
79.877
22.787
8.234
48.824
48.824 MG (Total Bubble Size Remaining)

Greenville Utility Commission (GUC) Aquifer Storage and Recovery (ASR) Well
In December 2002, the former Division of Water Quality issued North Carolina's first injection well permit
for an ASR to GUC (Permit No. W10700040). This well was intended to be used to inject treated drinking
water for storage in the Black Creek and Upper Cape Fear aquifers during times of excess supply, and later
recover the water when demand peaks and exceeds the capacity of the GUC's drinking water treatment
plant. A recent inquiry with GUC indicated the ASR well is experiencing turbidity issues, which is further
discussed below.
Original ASR Concerns
Two major concerns were raised about issuing this permit.
First, whether the construction of this well would hydraulically connect the Black Creek Aquifer and
the Upper Cape Fear Aquifer (UCFA). Data collected by GUC at the site indicated that water in these
two aquifers is chemica a two aquifers were not significantly
different. owever, the well construction has been modified since it was on c ' atT
underlying UCFA was sealed off. The well now only injects and recovers water in the Black Creek
1� er. After modification, the well ID was changed from ASR-1 to ASR-1M ('M' for modlfied well).
Second, data submitted by GUC indicated that the recharge water would meet all groun water
quality standards in 15A NCAC 2L .0202 except for three trihalomethanes (TH'Ms) -- chloroform,
bromodichloromethane, and chlorodibromomethane -- disinfection by-products formed by reaction
of chlorine with dissolved organic compounds in the water.
Since the injection/recharge water came directly from a public water treatment facility (PWT) and met all
relevant National Primary and Secondary Drinking Water Standards, the Division believed that despite the
exceedance of groundwater quality standards for these three compounds, injection of this water was not
expected to pose a threat to human health or the environment, or to render the groundwater unsuitable
for its best intended usage.
Permit Conditions and Compliance
The ASR permit_was initially issued in 2004 and has been renewed several Mites. The most current permit
was reissued on February 12, 2016 and expires September 1, 2019.tio ruction and operation of the
injection well was approved, but #y only issued for two years from issuance. This allowed GUC time
to construct the well and carry out cycle testing. Full-scale operation of the system required amendment
of the permit or issuance of a second permit. Permit conditions that addressed the above concerns were:
The permit specified that the recharge water must meet all groundwater quality standards in 15A
NCAC 2L .0202, except for disinfectants and disinfection by-products.
The permit specified a monitoring program to be performed during the cycle testing.
9 months after all injection and recovery cycles are completed, a Final Project Evaluation (FPE) report
is required (this FPE is required for both ASR sites permitted in NC). This document shall .assess the
injection project's findings in a written summary to include, but not be limited to, the following:
o An assessment of the impact of the injection activities on water quality of the injected water and
native groundwater,
o A determination or calculation of the lateral extent of the injection zones based upon data
collected during the cycle testing,
o Re-evaluation of the transmissivity and storativity of the injection zones,
o Monitoring well sampling data and pertinent head data, and any other pertinent information.
O-L-1
DEQ-CFW 00075002

Cape Fear Public Utility Authority (CFPUA) Aquifer Storage and Recovery (ASR)
Background:
The Underground Injection Control program is a Federal Program under the Safe Drinking Water Act; and
regulated under 40 CFR Part 144 through 148. The Division of Water Resources within the Department of
Environmental Quality permits underground injection wells, and oversees their compliance and
enforcement. NC Administrative Code for this program is under 15A NCAC 2C .0219 (attached). One of
the types of underground injection wells is the Aquifer Storage and Recovery (ASR). ASR systems are
intended to allow for injection of water into aquifers for temporary storage. ASR systems provide an
alternative to more traditional above ground storage tanks and lagoons.
Aquifer Storage and Recovery (ASR) Wells Nation -Wide
ASR wells are systems that are increasing in number nationwide, especially in areas with potential water
shortages. These systems are intended to store water when it is readily available, and recover water
during dry and high demand periods. The distribution of ASR wells in the United States varies. In the
North-East and Mid -Eastern states, ASRs are not widely used since they have an abundance of drinking
water. However, in many states, ASR is a popular option. Per the USEPA website, as of 2009, a total of
542 Aquifer and Storage Recovery (ASR) wells are capable of operation. Over half of these are in Region
4, Region 9, and Region 10:
Region 4 (southeastern states) has 124 ASRs. These include AL, FL, GA, KY, MS, NC, SC and TN.
Regions 9 and 10 (western states plus) have up to 155 ASRs. Region 9 includes CA, NV, AZ, HI, the
Pacific Islands and 148 Tribes. Region 10 includes WA, OR, ID, AK and 271 Native Tribes
Distribution of Aquifer Storage and Recovery Wells by EPA Region
I-e
C`
NUJ
47 - 58
9 �4
�f
DEQ-CFW 00075003

In response to the discovery of GenX in the aquifer, the original plan of CFPUA was to pump out twice the
volume that was injected, up to 200 million gallons. In addition to the 31,021,000 gallons removed as
indicated on the Injection and Recovery r0ummary Spreadsheet, they have also pumped out a total of
232,700 gallons during the six weeks of GenX sampling of the ASR Well (Table below).
o
DATE
o
Water Purged
0
6 /20/17
0
7,500 gallons
0
6/29/17
0
15,800 gallons
0
7/6/17
0
43,200 gallons
0
7/13/17
0
58,400ga'llons
0
7/17/17
0
59,400 gallons
0
7/20/17
0
48,400 gallons
Attachments 1
1. 15A NCAC 2C .020 Ries
2. Site and ASR Maps
B. CFPUA Injection and Recovery Summary Spreadsheet
4. CFPUA Permit W10800149
C 9)
DEQ-CFW 00075004

level was above 21-standar . The previously referenced Injection and Recovery lummar s read sheet
was received August 7, 2017 rev" "ie� w oT a sprea s ee in icates that at the en of Cycle 2, monitoring
cfeta-s#eifeH su mitted 60 days after the cycle ended on March 27, 2017. It appears
monitoring data for the last cycle has not been submitted yet. The WiRO and CFPUA has been contacted
to determine if the data has been received. For Cycle 3, the injection component of the cycle was done,
but the recovery component was not initiated due to GenX concerns. Therefore, Cycle 3 has not been
completed. According to our records, no NOVs have been issued to this site.
Infection Rates
The current permitted flow rate is 70,000 GPD at 30 PSI. The target amount of water stored is 360 MG.
To date the total stored volume is 48.824 MG.
GenX Discovery
The unregulated compound GenX has been recently discovered in the Cape Fear, where source water
was drawn into the Sweeney Water Treatment Plant (WTP) in Wilmington, to be treated and distributed
to its customers. This compound is a byproduct of DuPont and Chemours' manufacturing process, which
has been discharged into the Cape Fear River for several years..
After it was reported that GenX was found in the drinking water treated and distributed by the Sweeney
WTP, the CFPUA sampled the stored groundwater in the ASR-11VI to determine if it was present in the
previously injected water. The initial laboratory analytical results indicated a concentration of 820 parts
per trillion (ppt). Follow up testing has shown a gradual decrease in concentration levels, and per the last
sampling results available, is below the NC DHHS Advisory Level of 140 ppt (see sampling table below).
The CFPUA stopped injecting after June 5, 2017, and it has been reported that Chemours is no longer
discharging this compound into the Cape Fear River.
Week
Date
GenX Sampling Results (ppt)
Lab Used
#1
6/22/2017
820
Test America, Colorado
#1
6/22/2017
588
EPA lab, Research Triangle
(ORD)
#2
6/29/2017
400
Test America, Colorado
#2
6/29/2017
336
EPA lab, Research Triangle
(ORD)
#3
/06/2017
190
Test America, Colorado
#3
/06/2017
148
EPA lab, Research Triangle
(ORD)
#4
7/13/2017
120
Test America, Colorado
#4
7/13/2017
84
EPA lab, Research Triangle
(ORD)
#5
7/20/2017
120
Test America, Colorado
#5
7/20/2017
94
EPA lab, Research Triangle
(ORD)
Path Forward
0
DEQ-CFW 00075005

Two wells were installed: ASR-1 (both an injection well and a recovery well) in May 2004, and TM-1
(recovery well only) in June 2000. The ASR-1 has had continual turbidity issues. A permit renewal with
modification was issued on February 12, 2016 wer section of the well screen installed in
the Upper Cape Fear Aquifer to be sealed off. n April 6, 2016, the well construction was modifie so
�je screen is instala in the rsiacreek Aquifer only with a total depth of 399 feet below Ian
surface (BLS)..--. rren- ewe is sti iving turbidity issues and is in testing g an3 eva uation mode.
• ` d, turbidity has been the primary concern since recovered water could not be
used for the intended purpose until turbidity was reduced to <5 ntu.
Total aluminum and total iron exceedances, which generally correlate positively with turbidity,
suggests that particulate matter in the groundwater was the primary source of the metal
exceedances.
• Data suggests that excessive turbidity is the result of the mobilization of naturally -occurring kaolinite
(a clay mineral) from the storage -zone aquifers.
Cafe Fear Public Utility Authority (CFPUA) ASR Well
The second ASR permitted in North Carolina is the CFPUA ASR (Permit No. W10800149), located in
Wilmington NC (see attached maps). It was originally permitted in September 2008and has been
reissued several times. The current permit was issued February 12, 2016, and expires January 31, 2021.
When the original permit was issued, it allowed up to 3 ASR wells to be installed. Two wells were
installed (ASR-1 and ASR-2) in the Pee Dee aquifer and the permitted third well was never drilled.
ASR-1/ASR-1M
phis ae11 was originally installed April a* has undergone 2 complete injection/recovery cycle.* areG Q,
5�third injection but recove as�nr,� r__r rr to d Attached is an Injection and Recovery
rYpread sheet submitted by the CFPUA summarizing the volumes of water injected and
- recovered, along with date . uring t e time frame of Cycle 2, the well experienced silting/clogging
issues. Therefore, to mitigate the silting/fouling of the well, which was originally completed as an hole with with no screen, the CFPUA requested a permit modification to allow a screen to be installed along
with a filtering pack consisting of Silibeads® (very small manufactured glass beads). A variance was
granted by the Wilmington Regional Office on November 13, 2015, to allow the use of Silibeads® in lieu of
quartz sand or other rock materials. The well modification was completed on July 20, 2016. The well ID
was changed from ASR-1 to ASR-1M ('M' for modified well).
ASR-2
CFPUA decided to cap ASR-2 after construction and testing due to low water production and detected
interference of the radius of influence (ROI) between ASR-1 and ASR-2. The well status is considered
'inactive'.
Permit Conditions and Compliance
The most recent permit required 6 monitoring wells: three wells in the Castle Hayne aquifer, two in the
Upper Pee Dee aquifer, and one in the surficial aquifer (see attached site maps and permit). The
monitoring plan is included in the attached permit. The permit requires that, with the exception of the
three trihalomethanes (THMs), the injected water must meet groundwater standards (2L standards) at
the point of injection. Since there is the possibility of metal mobilization (i.e., arsenic), the groundwater is
tested for a suite of metals.
A preliminary review of the monitoring data for Cycle 1 was submitted in 2014 and did not show any 2L
exceedances. However, for a few of the parameters (e.g., bromate), the laboratory minimum detection
3
DEQ-CFW 00075006

CAPE FEAR PUBLIC UTILITY AUTHORITY (CFPUA) AQUIFER STORAGE AND RECOVERY (ASR)
August 7, 2017
Background:_
The Underground Injection Control program is a Federal Program under the Safe Drinking Water Act; and
regulated under 40 CFR Part 144 through 148. The Division of Water Resources within the Department of
Environmental Quality permits underground injection wells, and oversees their compliance and
enforcement. NC Administrative Code for this program is under 15A NCAC 2C .0200 (attached). One of
the types of underground injection wells is the Aquifer Storage and Recovery (ASR). ASR systems are
intended to allow for injection of water into aquifers for temporary storage. ASR systems provide an
alternative to more traditional above ground storage tanks and lagoons. Cape Fear Public Utility
Authority (CFPUA) has a permitted ASR.
CFPUA Aquifer Storage and Recovery Site
• Faced with increasing peak deman
periodic fluctuations of water sups
storage when there is excess u
• To determine whew syn
constructed one in
and has conducted
r w r, CFPUA ap lied for a permit for an ASR to manage
►�d�de nd by alternately injecting drinking water for
la
ter r covering water when there is insufficient supply.
is Site was capable for a full-scale ASR operation, CFPUA
I (ASR-1, currently active) in the Upper Peedee Aquifer
on, storage, and recovery.
• The permit dictates ho oftefi sampling must occur after a recharge and recovery of injected
water and what to sample r (see attached ;permit, Part X).
• Cycle test 3 was proposed for the period March 29, 2017 through May 10, 2017. CFPUA
proposed six weeks of testing during this period to include the ASR-1 and three of the monitoring
wells (see attached site map of ASR-1 and monitoring wells).
CFPUA Permit
ASR permit number for the CFPUA is W10800149. It was originally issued 2008, renewed in 2011,
2013 and modified in 2016. The current permit will need to be renewed by 2021.
Issues that must be addressed in an ASR permit application include:
o A complete water quality analysis of the water to be injected (all National Primary and
Secondary Drinking Water Standards) as well as a basic water quality analysis of native
water in the aquifer.
o Modeling of potential reactions between the injected water and native waters and
between the injected water and aquifer matrix.
o Groundwater monitoring at points other than the ASR well itself.
o Determination of an injection zone that specifies the horizontal and vertical portion of
the proposed injection activity. No violation of groundwater quality standards specified
in 15A NCAC 2L .0200 is allowed to occur outside this zone. (The injection zone is
indicated on the monitoring well map, attached)
Disinfection by-products and disinfectants are the only compounds currently allowed to exceed
2L standards in the injected water, but this is onlyjustified on the basis that the injected water is
treated drinking water to be recovered and used as treated drinking water.
DEQ-CFW 00075007

GENX Discovery
During the ASR cycle tests, CFPUA injected 48.8 million gallons into the ASR. They stopped
injecting in June 2017.
o Cycle Test Injection #1 ended March 4, 2014 — total 13.75 MG stored
o Cycle Test Injection #2 ended June 13, 2014 — total 28.538 MG stored
o Due to repairs needed, and additional flushing and recovery, the Cycle Test Injection #3
was delayed. In November 2016, there was a total 24.4 MG stored
o Cycle Test injection #3 ended June 5, 2017 — 24.4 MG added; a total of 48.811 MG.
ASR #1well testing was done concurrently with raw and finished water testing for the GenX
compound. Below are the sampling results:
Week
Date
GenX Sampling Results (ppt)
Lab Used
#1
6/22/2017
820
Test America, Colorado
#1
6/22/2017
588
EPA lab, Research Triangle
(ORD)
#2
6/29/2017
400
Test America, Colorado
#2
6/29/2017
336
EPA lab, Research Triangle
(ORD)
#3
7/06/2017
190
Test America, Colorado
#3
7/06/2017
148
EPA lab, Research Triangle
(ORD)
#4
7/13/2017
120
Test America, Colorado
#4
7/13/2017
84
EPA lab, Research Triangle
(ORD)
#5
7/20/2017
120
Test America, Colorado
#5
7/20/2017
94
EPA lab, Research Triangle
(ORD)
PATH FORWARD
• The original intent of CFPUA was to pump out twice the volume that was injected up to 200-
�s. So far they have pumped out a total of 232,700 gallons during the six weeks of
GenX sampling of the ASR Well:
0 6 /20/17 7,500 gallons
0 6/29/17 .15,800 gallons
0 7/6/17
43,200 gallons
0 7/13/17
58400 gallons
0 7/17/17
59,400 gallons
0 7/20/17
48,400 gallons
DEQ-CFW 00075008

• Water is being proposed to be pumped from the ASR at approximately 500 GPM which is not
expected to affect wells in the neighborhood or overwhelm downstream pump stations. This
water will be sent to the Northside WWTP, starting approximately September 1, 2017.
• Other wells being tested are a private well nearby (750 feet from the ASR, Mr. Paige) where
testing results were non -detect. Also, the Wrightsville Beach public water supply well #11,
located approximately 3000 feet from the ASR, has been tested. GenX test concentrations
ranged from 24 to 44 ppt.
• Two more wells will be placed in the PeeDee aquifer between the ASR and Wrightsville Beach to
monitor GenX concentrations.
• CFPUA still plans on constructing a temporary line from the ASR well to tie in to the sewer force
main along Military Cutoff Road (approximately 3,000 feet).
o CFPUA will physically disconnect the ASR well from the distribution system and install a
Reduced Pressure Zone (RPZ) at the well end of the temporary line and a check valve at
the sewer force main.
o They will continue to test for GenX as they pump and better determine total volume of
recovered water to be pumped.
Currently CFPUA is seeking guidance from the Division on acceptable concentrations.
o It will be difficult to pump water until non -detect levels of GenX are found without
impacting water supply wells in the area.
o CFPUA recently requested the Division to prioritize and establish groundwater IMACS for
all perfluorinated compounds discharged under NPDES NC0003573.
Items to Consider
• With the exception of disinfectants and disinfection by-products, the permit requires that the
injected water shall at all times comply with groundwater quality standards in 15A NCAC 02L
.0202.
• The permit requires regular monitoring for typical parameters of concern for a public water
supply (see attached permit requirements), but does not include GenX.
• 15A NCAC 02L .0202 does not specify a numeric value for a GenX groundwater standard;
therefore, the Class GA or Class GSA groundwater standard for GenX is the practical quantitation
limit [15A NCAC 02L .0202'(b)(2)].
• 15A NCAC 2L .0106 (b) states that "Any person conducting or controlling an activity which results
in the discharge of a waste...to the groundwaters of the State ... shall take immediate action to
terminate and control the discharge."
• The last sample for the ASR shows GenX at 120 ppt and the DHHS health advisory level is 140 ppt.
�• THE QUESTION IS did CFPUA know the water had GenX when they were still recharging the
aquifer? November 23, 2016, Dr. Knape with NC state, sent a paper he published in ES&T Letters
to NC DWR staff and CFPUA concerning GenX test results, where he states "None of the newly
discovered compounds being discharged by the Chemours plant south of Fayetteville are
removed by the advanced and conventional treatment processes employed in the Sweeney WTP
in Wilmington (see email attached).
DEQ-CFW 00075009

CAPE FEAR PUBLIC UTILITY AUTHORITY (CFPUA) AQUIFER STORAGE AND RECOVERY (ASR)
Background:
The Underground Injection Control program is a Federal Program under the Safe Drinking Water Act. It
falls under 40 CFR Part 144 through 148. The oversight on this program is the Division of Water
Resources, where EPA provides a grant of $110,000 and the state matches a portion of this grant. Most At
the state's responsibility is to permit underground injection wells, and oversee their compliance and
enforcement. Rules were developed for this program under 15A NCAC 2C .0200 (attached). One of the
types of underground injection wells is the Aquifer St ora a and Recovery (ASR). Cape Fear Public Utility
Authority (CFPUA) has a permitted ASR.
CFPUA Aquifer Storage and Recovery Site
• Facth-iea�ig dead s ' -wwatNthe Cape Fear Pu 'c Utility Authority (CFPUA)
applied for a permit for AS t
nage periodic fluctuate of water supply and demand by
alternately injecting d in wat
or storage when th is excess supply and later recovering
water when there i in of ie sup
• To determine whet the
at this site w capable for a full-scale ASR operation, CFPUA
constr e o nje t n/r overy
well (AS ,currently active) in the Upper Peedee Aquifer
and has c ducte y tests of injectio
storage, and recovery.
• The permit 'ctates o ten sampli
must occur after a recharge and recovery of injected
water and wha to sa ple for (see
tached permit).
• The last set of to in was Marc
9 2017 through May 10, 2017. They did six weeks of testing
during this period include e ASR-1 and three of the monitoring wells (see attached site map
of ASR-1 and monit ing w s).
CFPUA Permit
• ASR permit number for the CFPUA is W10800149. It was originally issued 2008, renewed in 2011,
2013 and modified in 2016.
• Issues that must be addressed in an ASR permit application include:
o A complete water quality analysis of the water to be injected (all National Primary and
Secondary Drinking Water Standards) as well as a basic water quality analysis of native
water in the aquifer.
o Modeling of potential reactions between the injected water and native waters and
between the injected water and aquifer matrix.
o Monitoring at points other than the ASR well itself.
o An injection zone that specifies the horizontal and vertical portion of the proposed
injection activity. No violation of groundwater quality standards specified in 15A NCAC 2L
.0200 can occur outside this zone. (The injection zone is indicated on the monitoring well
map, attached)
• Disinfection by-products and disinfectants are the only compounds currently allowed to exceed
2L standards in the injected water, but this is only justified on the basis that the injected water is
treated drinking water to be recovered and used as treated drinking water.
DEQ-CFW 00075010

CAPE FEAR PUBLIC UTILITY AUTHORITY (CFPUA) AQUIFER STORAGE AND RECOVERY (ASR)
Background:
The Underground Injection Control program is a Federal Program under the Safe Drinking Water Act, 1 --tr ei-i rel'(. d
fagonw4er 40 CFR Part 144 through 148. Tffie-ove is the imogi:eizA �iog-a�f-ater
R es,-w4ere FRA provides a grant of S� 0, nn and tip stat_____— a4t44:�e s-&--pro twul ,-� ge t. Most
',__the..s e's responsibility is to permit underground injection wells, and oversee their compliance and
enforce men . Rt�l�.s-u a4&4avaWf�ed.for this program Lar 15A NCAC 2C .0200 (attached). One of the
PC-�`� " types of underground injection wells is the Aquifer Storage and Recovery (ASR). Cape Fear Public Utility
ecx)e Authority (CFPUA) has a permitted ASR.
CFPUA Aquifer Storage and Recovery Site
• Faced with increasing peak demands for water, the-C-ape-Fea ' (CFPUA)
applied for a permit for an ASR to manage periodic fluctuations of water supply and demand by
alternately injecting drinking water for storage when there is excess supply and later recovering
water when there is insufficient supply.
• To determine whether the system at this site was capable for a full-scale ASR operation, CFPUA
constructed one injection/recovery well (ASR-1, currently active) in the Upper Peedee Aquifer
and has conducted cycle tests of injection, storage, and recovery.
• The permit dictates how often sampling must occur after a reclarge and recovery of injected
water and what to sample for (see attached permitipar �- X
• The last set of testing was March 29 2017 through May 10, 2017. They did six weeks of testing
during this period to include the ASR-1 and three of the monitoring wells (see attached site map
of ASR-1 and monitoring wells).
CFPUA Permit
• ASR permit number for the CFPUA is W10800149. It was originally issued 2008, renewed in 2011,
2013 and modified in 2016.
• Issues that must be addressed in an ASR permit application include:
o A complete water quality analysis of the water to be injected (all National Primary and
Secondary Drinking Water Standards) as well as a basic water quality analysis of native
water in the aquifer.
o Modeling of potential reactions between the injected water and native waters and
between the injected water and aquifer matrix.
o Monitoring at points other than the ASR well itself.
o An injection zone that specifies the horizontal and vertical portion of the proposed
injection activity. No violation of groundwater quality standards specified in 15A NCAC 2L
.0200 can occur outside this zone. (The injection zone is indicated on the monitoring well
map, attached)
• Disinfection by-products and disinfectants are the only compounds currently allowed to exceed
2L standards in the injected water, but this is only justified on the basis that the injected water is
treated drinking water to be recovered and used as treated drinking water.
DEQ-CFW 00075011

GENX Discovery
• DATE or timeframe CFPUA injected 48 million gallons into the ASR (Was this done so much e
week? So, much a month?)
• As soon as the GenX product was discovered in the Cape Fear Water Treatment Facility's raw
water, the ASR well was tested. Below are the sampling results
ASR Testing Results:
Week
Sampling Results (ppt)
Lab Used
#1
820
Test America, Colorado
#1
588
EPA lab, Research Triangle (ORD)
#2
400
Test America, Colorado
#2
336
EPA lab, Research Triangle (ORD)
#3
190
Test America, Colorado
#3
148
EPA lab, Research Triangle (ORD)
#4
120
Test America, Colorado
• Weeks #,5 and #6 were not available at the time of conversation, but the`,Deputy Director for the
Division of Water Resources has these results.
• The original intent of CFPUA was to pump out twice the volume that was injected up to 200
million gallons. So far they have pumped out XXX million gallons -what's the schedule to
continue??:
• Water is being pumped from the ASR at 300 gpm to keep from affecting wells in the
neighborhood, and is being sent to a WWTP.
• Other wells being tested are a private well nearby (3000 ft from the ASR, Mr. Paige) which was
non -detect. Also the Wrightsville Beach public water supply well #11, which was 44 and 37 ppt
respectively.
• CFPUA still plans on constructing a temporary line from the well approximately 3,000 feet to tie in
to the sewer force main along Military Cutoff Road.
o CFPUA will physically disconnect the well from the distribution system and install an RPZ
at the well end of the temporary line and a check valve at the force
o They will continue to test for GenX as they pump and determine total volume to be
pumped based on test results.
Currently they are seeking guidance from the Division on acceptable concentrations knowing that
it will be very difficult to pump to the non -detect level without impacting wells in the area.
o Gary McSmith with the CFPUA indicated they were working on a request to Jay for the
adoption of an IMAC for at least the known fluorinated compound.
o The last test results I have seen for the ASR site are below the health advisory level of 140
parts per trillion.
Path Forward
DEQ-CFW 00075012

GENX Discovery
• DATE or timeframe CFPUA injected 48 million gallons into the ASR (Was this done so much a
week? So much ;a month?)
• As soon as the GenX product was discovered in the Cape Fear Water Treatment Facility's raw
water, the ASR well was tested. Below are the sampling results
A&R Testing Results:Q � p e,-lk -,"V—bK
Week
��,� Sampling Results (ppt)
—$-
Lab Used
#1
820
Test America, Colorado
#1
588
EPA lab, Research Triangle (ORD)
#2
400
Test America, Colorado
#2
336
EPA lab, Research Triangle (ORD)
#3
190
Test America, Colorado
#3
148
EPA lab, Research Triangle (ORD)
#4
120
Test America, Colorado
• Weeks #5 and #6'were not available at the time of conversation, but the Deputy Director for th.e
Division of Water Resources has these results. 10,
• The original intent of CFPUA was to pump out twice the volume that was injected up to 200
million gallons. So far they have pumped out;XXX million gallons - what's the schedule to
continue??.
—A.— Water is being pumped from the ASR at 300 gpm to keep from affecting wells in the
neighborhood, and is being sent to a WWTP.
• Other wells being tested are a private well nearby (3000 ft from the ASR, Mr. Paige) which was
non -detect. Also the Wrightsville Beach public water supply well #11, which was 44 and 37 ppt
respectively.
CFPUA still plans on constructing a temporary line from the well approximately 3,000 feet to tie in
to the sewer force main along Military Cutoff Road.
o CFPUA will physically disconnect the well from the distribution system and install an RPZ
at the well end of the temporary line and a check valve at the force
o They will continue to test for GenX as they pump and determine total volume to be
pumped based on test results.
Currently they are seeking guidance from the Division on acceptable concentrations knowing that
it will be very difficult to pump to the non -detect level without impacting wells in the area.
o Gary McSmith with the CFPUA indicated they were working on a request to Jay for the
adoption of an IMAC for at least the known fluorinated compound.
o The last test results I have seen for the ASR site are below the health advisory level of 140
parts per trillion.
Lis
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DEQ-CFW 00075013

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DEQ-CFW 00075014

To: Gary McSmith <[e-mail]>
Subject: ASR Timeline
March 4, 201 n e 1 —13.75 MG Store (Original Remaining Bubble)
ICI rc ' - Start Cycle-2 intec io
une 13, 201 nd Cycle 2 injection 8��Store
une , 20 Pump Removed for inspec — ess egins to address sand issues
August 9 — August 12, 2016 Flushing after sili-bead ' stallation
October 14, 2016 — Flushing in preparation for start o cycle 2 recovery
October 18, 2016 — Start Cycle 2 recover to distribution
October 22, 2016 — Well Off waiting on fresh hypochlorite o chemical)
October 24, 2016 — Resume Cycle 2 recovery to distributio 1.
November 12, 2016 — End Cycle 2 recovery — System in Stor a Mode 10.66 MG Stored
Total Bubble Size Remaining Cycle 1 13.75 + Cycle 2 10.66 4,24� 11 M 'Total Bubble Size)
March 28, 2017 — Start Cycle 3 injection
Ju a 6 2017 End Cycle 3 injection — 24.58 Recharged — Flushing
Total Bubble Size Current = Cycle 1 & 2 total 24.411 + Cycle 3 24.4 48.8'f 1 MG
John Malone
Interim Water Resources Manager
Water Treatment Supervisor
Cape Fear Public Utility Authority (CFPUA)
Water Treatment Division
PH:: 91.0-332-6643
Cell: 910-515-6143
Fax: [phone]
John. Maloneacfpua. or
%try'
NOTICE: E-Mail correspondence to and from this address may be subject to the NC Public Records Lair and may be
disclosed to third parties.
DEQ-CFW 00075015

Watts, Debra
From: Gregson, Jim
Sent: Friday, August 04, 2017 4:52 PM
To: Watts, Debra; Zimmerman, Jay
Subject: FW: ASR Timeline
Jim Gregson
Regional Supervisor
Water Quality Regional Operations Section
Division of Water Resources
Department of Environmental Quality
910.796.7215 Reception Desk
910.796.7386 Direct
910.350.2004 Fax
Jim. [e-mail]
Wilmington Regional Office
127 Cardinal Drive Ext
Wilmington, NC 28405
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.
From: Gary McSmith [mailto:[e-mail]]
Sent: Friday, August 04, 2017 4:51 PM
To: Gregson, Jim <[e-mail]>
Subject: FW: ASR Timeline
Hi Jim,
Here's the information you requested.
Best Regards,
Gary McSmith, P.E.
Assistant Engineering Director
Cape Fear Public Utility Authority
235 Government Center Drive
Wilmington, NC 28403
910-332-6629 Desk
910-833-4197 Cell
From: John Malone
Sent: Tuesday, July 18, 2017 1:21 PM
DEQ-CFW 00075016

Watts, Debra
From:
Gregson, Jim
Sent:
Tuesday, August 01, 2017 2:27 PM
To:
Watts, Debra
Cc:
King, Morelia s; Kegley, Geoff, Risgaard, Jon
Subject:
ASR Update
Debra,
Geoff and I met with CFPUA and Rick Catlin at the ASR site this morning to discuss the plans for pumping the 48MG of
treated water out of the well. The Authority still plans on constructing a temporary line from the well approximately
3,000 feet to tie in to the sewer force main along Military Cutoff Road. From there it would flow to the Bradly Creek
Pump Station and ultimately to the Northside WWTP. They will physically disconnect the well from the distribution
system and install an RPZ at the well end of the temporary line and a check valve at the force main tap. Original estimates
were to pump around 2X the injected volume or around 200 MG. They will test for GenX as they pump and determine
total volume to be pumped based on test results. They are seeking guidance from the Division on acceptable
concentrations knowing that it will be very difficult to pump to the non -detect level without impacting wells in the
area. Gary McSmith indicated they were working on a request to Jay for the adoption of an IMAC for at least the known
fluorinated compound. The last test results I have seen for the ASR site are below the health advisory level of 140 parts
per trillion. -
Jim Gregson
Regional Supervisor
Water Quality Regional Operations Section
Division of Water Resources
Department of Environmental Quality
910.796.7215 Reception Desk
910.796.7386 Direct
910.350.2004 Fax
Tim. rgregsonamcdenr.Rov
Wilmington Regional Office
127 Cardinal Drive Ext
Wilmington, NC 28405
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.
1
DEQ-CFW 00075017

GCE�l
Watts, Debra u=�
To: Gregson, Jim
Cc: King, Morella s; Kegley, Geoff; Risgaard, Jon; Watts, Debra; Wilson, Nat; Rogers, Michael
Subject: RE: ASR Update
Nat
See the email below.
Jim
A couple of things.
• First, thanks for keeping us up-to-date.
• Second, I'm going to try and talk to Linda Culpepper this afternoon and see what are our options are as far as
compliance level for the ASR. If we meet to discuss with staff like Standards and Classifications (Jeff Manning's
group), I'll invite you and your staff as well.
• Third, in talking with some of the Hydros here, I'm wondering if the Catlin group has been too quick in making this
decision of withdrawing 200MG of water from the ASR. Even though they have pumped this water into the ASR, I
think we need to keep Nat Wilson's group informed in that this may have implications as far as capacity use i.e.
how this would affect the aquifer area wide.
• And finally, has the Catlin group looked at other options, like dilution with water from another source? Running
the currently stored water through some kind of filter and returning to storage? Etc.
We will still look to see what kind of guidelines we can provide, but thought I'd share the above for your consideration.
Debra Watts
Supervisor, Animal Feeding Operations and Groundwater Protection Branch
Division of Water Resources
North Carolina Department of Environmental Quality
919 807 6338 office
debra.watts(dncdenr.gov
512 N. Salisbury Street
1636 Mail Service Center
Raleigh, NC 27699-1636
j' !.--'Nothing Compares
Email correspondence to and from this address is subject to the
/forth Carolina Public t'er or s Law and may be disclosed to thirdpa ies.
From: Gregson, Jim
Sent: Tuesday, August 01, 2017 2:27 PM
To: Watts, Debra <[e-mail]>
Cc: King, Morelia s <[e-mail]>; Kegley, Geoff <[e-mail]>; Risgaard, Jon
<[e-mail]>
Subject: ASR Update
DEQ-CFW 00075018

Debra,
Geoff and I met with CFPUA and Rick Catlin at the ASR site this morning to discuss the plans for pumping the 48MG of
treated water out of the well. The Authority still plans on constructing a temporary line from the well approximately
3,000 feet to tie in to the sewer force main along Military Cutoff Road. From there it would flow to the Bradly Creek
Pump Station and ultimately to the Northside WWTP. They will physically disconnect the well from the distribution
system and install an RPZ at the well end of the temporary line and a check valve at the force main tap. Original estimates
were to pump arQL nd X the injected volume or around 200 MG. They will test for GenX as they pump and determine
total volume to be pumped based on test resu ts. ey are seeking guidance from the Division on acceptable
concentrations knowing that it will be very difficult to pump to the non -detect level without impacting wells n the
area. ary McSmith indicated they were working on a request to Jay for the adoption of an IMAC for at least the known
fluorinated compound. The last test results I have seen for the ASR site are below the health advisory level of 140 parts
per trillion.
Jim Gregson
Regional Supervisor
Water Quality Regional Operations Section
Division of Water Resources
Department of Environmental Quality
910.796.7215 Reception Desk
910.796.7386 Direct
910.350.2004 Fax
Jim.gre sg_on(a,ncdenr.gov
Wilmington Regional Office
127 Cardinal Drive Ext
Wilmington, NC 28405
Email corresfoondence to and from this address is subiect to the
North Carolina Public Records Lair and may be disclosed to third parties.
DEQ-CFW 00075019

DEQ-CFW 00075020

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DEQ-CFW 00075021