WI0800206_Staff Report_20190816

North Carolina Department of Environmental Quality - Division of Water Resources
WQROS REGIONAL STAFF REPORT FOR
UIC Program Support

WQROS Staff Report Rev. 4/15/2016 Page 1
Permit No._WI800206_____________
Date: _7/9/2019________ County: _New Hanover______________________
To: ___Shristi Shrestha________________Permittee/Applicant: _Phillips 66 Company___
Central Office Reviewer Facility Name: _Phillips 66 RM Site #6265 (fka Conoco Store #33051)_
I. 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:
c. Site visit conducted by: NA
d. Inspection Report Printed from BIMS attached: Yes No.
e. Physical Address of Site including zip code: 2636 Castle Hayne Rd., Wilmington, NC 28401
f. Driving Directions if rural site and/or no physical address:
g. Latitude: 34.290994 Longitude: -77.920753
Source of Lat/Long & Accuracy (i.e., Google Earth, GPS, etc.):__Google Earth___________________
II. DESCRIPTION OF INJECTION WELL(S) 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 only:
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
What is/are the pollution source(s)? _Release(s) of petroleum product(s) from underground storage tanks which
have impacted soil and groundwater in the area of proposed injection points (Incident #14178).
What is the distance of the injection well(s) from the pollution source(s)? __Injection is at pollution sources__
4. What is the minimum distance of proposed injection wells from the property boundary? _Beyond site boundary
5. Quality of drainage at site: Good Adequate Poor
6. Flooding potential of site: Low Moderate High
DocuSign Envelope ID: 1FA2CC26-28D7-48AE-9771-EF455D5197D7

WQROS Staff Report Rev. 4/15/2016 Page 2
7. For Groundwater Remediation Injection Systems only, 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 (i.e., permits with WQ__________prefix):
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. EVALUATION AND RECOMMENDATIONS
1. Do you foresee any problems with issuance/renewal of this permit? Yes No. If Yes, explain. See
Section IV.
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

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
Permittee should demonstrate that the mixture
water is free of PFAs
Municipal water systems in area contain PFAS

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
5. Signature of Report Preparer(s):
Signature of WQROS Regional Supervisor:
Date: 8/15/2019
DocuSign Envelope ID: 1FA2CC26-28D7-48AE-9771-EF455D5197D7

WQROS Staff Report Rev. 4/15/2016 Page 3
IV. ADDITIONAL REGIONAL STAFF REVIEW COMMENTS/ATTACHMENTS (Optional / If Needed)
Municipal water at the proposed injection location is provided by the Cape Fear Public Water Authority
(CFPUA) and more specifically, served by the Sweeney Water Treatment Plant (Sweeney Plant). The Sweeney
Plant derives raw water from the Cape Fear River which has been documented as containing PFAS in the inlet
of the Sweeney Plant. Furthermore, PFAS have been documented in the effluent of the Sweeney Plant at levels
in excess of 2L Standards. For this reason, additional information has been requested from the consultant to aid
in determining if any permit modifications are needed to ensure that water free of PFAS are not injected into
the injection wells (as well as other information).

Consultant has provided a response indicating that the water will be obtained from the CFPUA Richardson
Water Treatment Plant which utilizes nano filter treatment technology and that the tanker truck will be cleaned
with water from the Richardson Plant. It has been documented that some of the water supply wells which
provide water to the Richardson Plant contain levels of PFAS. Some additional documentation may be
considered appropriate indicating that PFAS are not present in the plant effluent. Although plant staff have
reportedly indicated to the consultant that effluent lab results may be provided, this information has not been
obtained to date.

A copy of the above information requests and responses are attached.
DocuSign Envelope ID: 1FA2CC26-28D7-48AE-9771-EF455D5197D7