WI0501030_Staff Report_20190924 (2)

WQROS REGIONAL STAFF REPORT FOR
UIC Program Support
Permit No. W10501030
Date: 9/24/2019 County: Wake
To: Shristi Shrestha Permittee/Applicant: Lear Corporation
Regional Office Reviewer: Brion N.Byers Facility Name: Former Guilford Fibers Plant
L GENERAL INFORMATION
I. This application is(check all mac apply): ®New ❑ Renewal
❑Minor Modification ❑ Major Modification
a. Date of Inspection: N/A
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: 200 Dickens Rd., Fuquay-Varina, Wake Co NC
f. Driving Directions if rural site and/or no physical address:
g. Latitude: 35.612810 Longitude: -78.804823
Source of Lat/Long& accuracy(i.e., Google Earth,GPS,etc.): Google Earth
I_I_. DESCRIPTION OF INJECTION WELLM AND FACHJTY
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 existine 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? Z Yes ❑No
What is/are the pollution source(s)?The site is a pollution source
4. What is the distance of the injection well(s)from the pollution source(s)?
5. What is the minimum distance of proposed injection wells from the property boundary? >430 feet
6. Quality of drainage at site: ❑Good ❑Adequate ❑Poor
T Flooding potential of site: ❑ Low ❑ Moderate ❑ High
Rev.6/1/2015 Page I

WQROS REGIONAL STAFF REPORT FOR
UIC Program Support
8. 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. Sample Guilford Production Well(WSW#2) see site maps in application
9. 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.
10. 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. EVALDATIONANDRECOMMENDATIONS
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
Is Guilford PW(WSW#2)going to be used as Has 2L exceedances(Cross-section A-A').
source water? Response from Wood Env. Is
that WSW #2 will NOT be use as source water.
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
Do NOT use Guilford PW(WSW#2)as source Analytical Data listed in Cross-section A-A',
water for injectant dilution(Application multiple different zones have 2L exceedances.
Attachment 7, pg I Source Area Injection Plan). Could not locate an analytical table in the
application to confirm.
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): ��f
Rev.6/1/2015 Page 2

WQROS REGIONAL STAFF REPORT FOR
UIC Program Support
Signature of WQROS Regional Supervisor: y
Date:
IV ADDITIONAL REGIONAL STAFF REVIEW COMMENTSIATTACIIMENTS flt Needed)=
Summary of Proposed Injection Permit:
• Various chlorinated volatile organic compounds(CVOCs)were previously used at the Former Guilford
Fibers facility. Reportedly,the gravel pit in the vicinity of M W 12 (gravel pit#2)was used by the previous
owner to dispose of contaminated rinse water.
• As proposed in the permit application; nested injection wells will be installed at three different depths
(approximately 10-20' his(Shallow),40-50' his(Intermediate), and 70-50' his(Deep)).
• Injectant to be used,elector donor solution—extended release(EDS-ER)by Tersus Environmental diluted
to approximately 2%-total of approximately 410,000 gallons(EDR-ER+ Water)to be injected=6,200
gallons per injection point.
o Multiple sources for source water are listed in the application—one source listed is Guilford PW
(WSW#2; Attachment 7,pg 1: Source of Area Injection Plan),which has 2L exceedances(Cross-
section A-A'). In some instances,the source water has higher 2L exceedances than the zone to be
injected into. (Attachment 9,Figures 9, 10, ... etc)
• Dehalococcoides microbes(DHC)will be added at a later date(once reducing conditions exist)—it does
not appear that the consultant is including this as part of the permit application.
Additional Information
In response to an additional information request, Wood Plc stated that they"do not anticipate extracting and
reinjecting contaminated water"(email Response dated 9/20/2019 from Bonani Langan).
Recommendations by RRO:
• Based on the response from Wood Plc, PRO recommend proceeding with approval of the permit with the
condition that source water for diluting the EDS-ER not be derived from a contaminated source(i.e. WSW
#2).
• Also, based on the findings in the application, specifically detection of chlorinated compounds above 2L
Standards in Guilford PW(WSW#2)which penetrates multiple fracture zone,the RRO recommends
abandonment of WSW#2.
Rev.6/I/2015 Page 3

Byers, Brion N
From: Langan, Bonani <[e-mail]>
Sent: Friday, September 20, 2019 1:24 PM
To: Shrestha, Shristi R
Cc: Byers, Brion N; [e-mail];Watts, Debra; 'Avtar Mavi'
Subject: RE: [External] UIC Permit Status
External email. Do not click inks or open attachments unless you verify.Send all suspicious email as an attachment to
re o, s am nc. ov
Shristi,
Thank you for your voicemail. We are planning to use a municipal water source for make up water during the injection
and do not anticipate extracting and re-injecting contaminated water. Please let me know if you have any other
questions.
Kind regards,
Bonani
From:Shrestha, Shristi R<[e-mail]>
Sent: Monday,September 16, 2019 1:37 PM
To: Langan, Bonani<[e-mail]>
Cc: Byers, Brion N <[e-mail]>;[e-mail]; Watts, Debra
<[e-mail]>
Subject: RE: [External] UIC Permit Status
Good afternoon,
We are in the process of reviewing the permit for Former Guilford Fibers Plant and had a concern about the application.
It seems from Fig 20 that the proposed Water supply well is in a contaminated area. If that is the case then the water
which is extracted is considered waste and re-injection is not allowed according to 15A NCAC 02C.209 5b unless the
water is treated. Please let us know if there is any alternative for the water source or if you want to re-inject the water
then please apply for a Non-Discharge permit.The details can be found under the following link
httos://d eg.nc.gov/a bout/divisions/water-resources/water-resources-oe rm its/wastewater-bra n ch/ground-wate r-
protecti o n/no n-d ischa rge-gro u ndwate r-remed iatio n
Thank you,
Shristi
Shristi R. Shrestha
Hydrogeologist
Water Quality Regional Operations Section
Animal Feeding Operations &Groundwater Protection Branch
North Carolina Department of Environmental Quality
919-707-3662 office
shristi.shresthaCo)ncdenr.00v
512N. Salisbury Street
1636 Mail Service Center
Raleigh, NC 27699 1636
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Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.
From:Tom Proctor [mailto:[e-mail]]
Sent: Monday,September 16, 2019 12:30 PM
To:Shrestha,Shristi R<[e-mail]>
Subject: [External] UIC Permit Status
Externs email.Do not dick lin s or open attachments unless you verify.Send all suspicious a ail as an attachment Yo
e ortis am nc, ov
Shristi, I hope you're well. I'm an owner of the former Guilford Mills
property in Fuquay-Varina, NC. I signed a UIC permit application that
Bonani Langan of Wood Environment submitted to your office on behalf
of Lear Corporation sometime in June. Could you please provide me with
an update as to the status of the permit request and, if possible, send me a
copy of the finalized permit for my records? Thanks, and if you have any
questions please let me know.
Best Regards,
Tom Proctor, P.G. RSM
President, Principal Environmental Geologist
Proctor Environmental Services,Inc.
919-630-0721
5113 Yachtsman Ct., Raleigh, NC 27615
Tom(o)Pro cto rEnvi ro n m e ntal.com
P ro ct o r E n v i r o n m e n t a I.c o m
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