391 LUKENS DRIVE NEW CASTLE, DELAWARE 19720-2774 SITE ... · General UIC Permitting Process...

SDMS DocID 2150853

WASTE MANAGEMENT SECTION

SITE INVESTIGATION &

RESTORATION BRANCH

STATE OF DELAWARE

DEPARTMENT OF NATURAL RESOURCES

AND E N V I R O N M E N T A L , C O N T R O L

DIVISION OF A I R AND W A S T E MANAGEMENT

391 LUKENS DRIVE NEW CASTLE, DELAWARE 19720-2774 TELEPHONE: (302) 39S-2600

FAX: (302^395-2601

March 24, 2011

Mr. Christian W. Matta Remedial Project Manager DE, VA, WV Remedial Branch 1650 Arch Street-(3HS23) Philadelphia, PA 19103-2029

RE: Comments on the Groundwater Flow Model Report, Public Well TCE Site (DE-1361) Millsboro, Delaware March 2, 2011

Dear Mr. Matta:

The Delaware Department of Natural Resources and Environmental Control (DNREC) has reviewed the "Groundwater Flow Model Report, Public Well TCE Site (DE-1361) Millsboro, Delaware", dated March 2, 2011, which was prepared by ARCADIS U.S., Inc. This document was reviewed by the DNRECs Division of Waste and Hazardous Substances Site Investigation and Restoration Branch (DNREC-SIRB) as well as the Water Supply Section and the Groundwater Discharges Section of DNRECs Division of Water.

The following general and specific comments were generated from the review of this report by DNREC-SIRB for the above referenced report.

DNREC-SIRB General Comments:

• Comments made by DNREC-SIRB on the Site Geology Section of the ARCADIS Alternatives Discharges Report have not been incorporated into this document.

• The boring logs of the deep wells installed by ARCADIS during this study, which were mentioned in the text, are missing from Appendix A. Please include them.

• There are geophysical logs available from the Delaware Geological Survey (DGS), and the Town of Millsboro for the deep wells within the area of the hydrogeologic investigation that should have been mentioned in the text and included in Appendix A.

• A detailed cross-section(s) of the wells in the study area, illustrating the site stratigraphy and the layers of the model, has not been included in the document.

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Mr. Christian W. Matta March 24, 2011 of 8

• Site geology/stratigraphy needs to be updated to include DNREC and DGS studies and data collected within the study area. See Division of Water Comment 1 below.

• The discussion of Site Geology would greatly benefit by the addition of a table with the measured thickness of the formations encountered within the study area.

• Only one injection site in the northwest corner of Atkins Park has been proposed and modeled. At a minimum, at least 1 alternate injection site needs to be selected as the proposed site in Atkins Park has residential/commercial wells in close proximity to it and it is not clear to DNREC that the Town of Millsboro has agreed to the use of this location for injection.

DNREC-SIRJB Specific Comments:

Comment 1: Section 1. Introduction - Page 2, 2 bulleted item. Please note that PW-1 and PW-2 were not originally installed as contaminant recovery wells, although the operation of those wells has provided control to the lateral and vertical plume migration. The continued operation of those wells will be required for adequate plume control until alternative means of control have been proposed and implemented by the PRPs.

Comment 2: Section 2.1. Site Setting - Page 3, 1̂ ' paragraph. ARCADIS has included the installation dates for PW-3, PW-4 and PW-5 in the text. Please add the installation dates for PW-1 and PW-2, which were 1953 and 1973 respectively, in the text. A table containing the well construction information for these wells should be added to the text as these are the extraction wells that are being evaluated. Also, note that the impact to the PW-1 and PW-2 was detected in October 2005.

Comment 3: Section 2.1 Site Setting - Page 3, 1" paragraph. DNREC has defined "Site" as the TCE source property and the contaminant plume of TCE that has impacted the Millsboro's Public Wells 1 and 2 (PW-1 and PW-2). (EA Engineering, Science & Technology, 2007, Final Focused Feasibility Study, Millsboro TCE Contamination Site, DE-1361, Edgewood, MD & DNREC-SIRJB, Final Plan of Remedial Action for the Millsboro TCE Contamination Site, DE-1361). Please define what ARCADIS means by "Site."

Comment 4: Section 2.2. Physical characteristics of the Site - Page 3, T' paragraph. The use of the word "probable source" in the next to last sentence of this paragraph should be replaced with "source". The property at 225 W. DuPont Highway has been identified as the source of the contaminant plume that has impacted PW-1 and PW-2 by DNREC. (EA Engineering, Science & Technology, 2007, Final Focused Feasibility Study, Millsboro TCE Contamination Site, DE-1361, Edgewood, MD; and DNREC-SIRB, Final Plan of Remedial Action for the Millsboro TCE Contamination Site, DE-1361). This change should be made throughout the entire document.

Comment 5: Section 2.2.2. Site Geology - Page 4, 2"'' paragraph, 2"'' sentence. Please provide the date of the reference(s) for DGS publication cited for the Columbia Formation.

Comment 6: Section 2.2.2. Site Geology - Page 5, 2"** paragraph, 2""* sentence. Please correct the reference "DGS, 1986" to read "DGS, 1984" which is the correct date of publication as it appears in the references in Section 9. Please make this change throughout the entire document.

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Mr. Christian W. Matta March 24, 201 1 of 8

Comment 7: Section 2.2.3. Site Hydrogeology - Pages 6 & &. ARCADIS mentions hydraulic conductivities, horizontal hydraulic gradient, vertical hydraulic gradient and groundwater velocity within the Columbia aquifer but not within the Bethany and Manokin aquifers. This section would greatly benefit by the addition of a table with the characteristics of the aquifers encountered within the study area.

Comment 8: Section 3.1. Monitoring Well Network - Page 8, 1̂ paragraph, last sentence. The soil boring logs for the deep wells which ARCADIS installed during the study have not been included in Appendix A as stated in the text. Please include the boring logs in the Appendix of the Final version of the report. There are also geophysical logs available for these wells which should be included in the Appendix.

Comment 9: Section 3.2.1. Aquifer Test Observations - Page 10, 1̂ ' paragraph. The pump test data shows that leakage occurs between the Bethany and the Manokin under pumping of PW-5 but it appears that it is not the case for the wells in the Columbia and the Bethany/Manokin aquifers. What is the rate of seepage/leakage between the Bethany and the Manokin and how was it determined?

Comment 9: Section 3.2.1. Aquifer Test Observations - Page 10, T' paragraph. It was observed by ARCADIS that during the aquifer test that wells screened in the Columbia showed a minor response during the pump test of the Manokin Aquifer and that because of the external pumping influences from PW-1 and PW-2, the drawdown data collected in the Columbia Aquifer were not used as a quantitative part of the Manokin Aquifer pump test analysis. That considered, then what is the seepage rate between the Columbia and the Bethany and how was it determined?

Comment 10: Section 3.2.2. Pump Test Analysis - Page 11, 1" paragraph, last sentence. ARCADIS mentions that "the simulated responses to pumping fit the observed data well for drawdown and recovery of the PW-5 pump cycles (Attachment B-l)." Attachment B-l has not been included in Appendix B unless ARCADIS is referring to Table B-l. In addition, the well test analysis plots/groundwater elevation graphs/plots in Appendix B should be assigned a figure number which is then referenced in the text.

Comment 11: Section 4 - Groundwater Flow Model Construction - Page 12, 1'' paragraph. Please describe the 6 layers of the model including general lithologies, thickness and other geological/hydrogeological characteristics. What cross-sections, boring logs and relevant publications were reviewed during model construction? Are the site specific cross sections that were created from the wells that were installed which illustrate the model layers? At a minimum, please illustrate the model layers on the generalized cross section in Figure 2.

Comment 12: Section 6.1. Groundwater Flow Scenarios - Page 14, bulleted item titled Scenario 2; Preferred Conditions, I" sentence. The phrase, "the operation of, is repeated twice. Please remove one of the phrases from this sentence.

Comment 13: Section 7. Summary of Modeling Activities - Page 19, paragraph 3. Please include a discussion of what the modeled rate of migration of contaminants from the vicinity of PW-1 and PW-2 to surface water would be should the pumping of PW-1 and PW-2 be discontinued. Also, please discuss what the modeled rate of vertical migration is into the Bethany/Manokin aquifer should the pumping of PW-1 and PW-2 be discontinued and PW-3 and/or PW-4 being pumped.

Comment 14: Section 7. Summary of Modeling Activities - Page 20, bulleted item 6. Can adequate capture of the plume be achieved by pumping just either PW-1 or PW-2 at greater than 220 gpm?

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Comment 15: Section 9. References - Page 21. Please provide the proper reference (authors, etc.) for the Delaware Geological Survey Reports of Investigation.

Comment 16: Figure 2. Please highlight the 6 layers of the model on the Generalized Cross Section.

Comment 17; Figure 3. The map symbol for existing monitoring well MW-IOD indicates that this well is a Manokin well, which it is not. Please correct this on the map. Please outline and identify the Town of Millsboro's W.A. Atkins Park on the figure along with the PRP's property to the west.

Comment 18: Figures 4-19. Please highlight the outline of the Town of Millsboro's W.A. Atkins Park and Mallinckrodt's acreage to the west.

Comment 19: Appendix A. Please include the boring logs and the geophysical logs for the wells that were installed in Atkins Park in the Appendix of the Final version of the report.

Comment 20; Appendix C. Figures C-l - C-14. Please highlight the outline of the Town of Millsboro's W.A. Atkins Park and Mallinckrodt's acreage to the west.

The comments below are the combined comments from the Water Supply Section and the Groundwater Discharges Section of the Division of Water. We have both general process related comments and specific comments on the Groundwater Flow Model Report.

General UIC Permitting Process Comments:

In order to obtain an Underground Injection Control (UIC) permit for a remediation project of the scope of the Millsboro TCE project, a site-specific Corrective Action Work Plan (CAWP) must first be approved by the Department of Natural Resources and Environmental Control (Department). In this case, the approval for the CAWP will be coming from both the DNREC Site Investigation and Restoration Branch and possibly the EPA Region III.

The CAWP must include (a) a detailed, site specific in-situ hydrogeologic assessment of the specific injection site. The assessment must address, among other things, the vertical and horizontal hydraulic conductivity, storage capacity of the soil, potential for mounding, and the continuity and potential for migration of contaminated water through the aquitard; (b) construction details showing the size, depth, and location of all injection and monitoring wells; details on the transmission line and appurtenances; and details on any pumps or structures that will be constructed as part of this project; and (c) documentation on the quality of the injectate, demonstration that the injectate will meet all Primary Drinking Water Standards, and assessment of the potential for chemical reactions that may release pollutants due to the mixing of two different sources of water. The results of the Corrective Action report may then be submitted as part of the UIC permit application(s).

The Department understands that it may be necessary to construct and operate test injection wells to collect some of the site specific hydrogeologic data. The UIC program can issue a short-tenn UIC Permit to operate test injection wells for a specific period of time in order to collect site specific information. The attached UIC test application may be used to request approval to operate any test injection wells.

Once the test results have verified the ability of the project to succeed, the applicant can submit a final UIC permit application for the corrective action. In the case of the Millsboro project, we understand that

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the initial UIC application is for an for an interim measure that addresses the treated water from the PW I and 2 wells as the Town transitions from the Columbia Formation wells to the Manokin wells.

The information obtained during this aquifer test has not been analyzed for the design of the injection wells. The properties of the Columbia aquifer have not been calculated from the test results, and it is not clear whether adequate data have been collected. The respondents may consider proceeding with the preparation of a UIC permit application once the specific site for injection has been secured. If further information needs to be collected, the application process will make that clear.

The contact for the Department for the UIC program is Mr. Ron Graeber at 302-739-9948 or [email protected] ARCADIS Millsboro Groundwater Model Flow Report Comments:

1) Section 2.2.2 - site geology description is outdated based on the 1984 reference. The most recent mapping performed by Ramsey (2010) identifies the surficial units across the model area to be the Omar Formation (Middle Pleistocene) west of Rt. 113 and the Ironshire Formation (Late Pleistocene) situated between the Indian River and Rt. 113. Each of these units unconformably overlies the Beaverdam Formation (Pliocene), according to Ramsey (2010). The remaining units underlying the Beaverdam Formation, the Bethany and Cat Hill Formations, mentioned in the report were stratigraphically accurate.

2) Section 2.2.3 - ARCADIS described the Bethany Formation as containing an upper confining unit, the Pocomoke aquifer, middle confining unit, the Ocean City aquifer, and lower confining unit. They were correct in stating the Pocomoke aquifer is the only named aquifer in Delaware; however, the report continued to use the Ocean City aquifer. In addition, there seems to be some confusion between the site hydrogeology and the conceptual model. ARCADIS reported that layers I and 2 represented the upper and lower Columbia aquifer; layers 3 through 5 represent the Bethany Formation; and layer 6 represented the Pocomoke, Ocean City, and Manokin aquifers. This configuration would imply that the "M" wells completed in MW-II, -12, -13, and -14 were in a thin unnamed sand in the Bethany Formation, when in fact it is the poorly developed Pocomoke aquifer. Based on the boring log descriptions and Delaware Geological Survey geophysical logs [Pg53-30(MW-14), Pg53-27(MW-1 1), Pg53-31(MW-I5), Pg53-28(MW-12), and Pg53-29(MW-13)] located in Atkins Park, it appears as though layer 4 should be representing the Pocomoke aquifer and layer 6 should be representing the Manokin aquifer. Moving southeast towards the other production wells (PW-1, -2, -3, and -4), it appears that the confining unit between the Pocomoke and Manokin aquifers begins to thin out to a point where the Pocomoke and Manokin appear to behave as one hydrologic unit, according to geophysical logs run in Pg53-32 (MW-] 6) and Pg53-14 (immediately adjacent to PW-3).

3) Section 3.2.1 - ARCADIS did not provide any discussion for the multiple recharge/drawdown events (see Figure B-l & attachments for MW-1 I, -12, -13, -14, -15, -16) that occurred after pumping was increased in PW-5 to 580 gpm on the fourth day. Reasons for the fluctuations cannot be offered due to a lack of information regarding pump schedule/rates and precipitation data.

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mailto:[email protected]

Mr. Christian W. Matta March 24, 201 I of 8

4) Section 3.2.1 - Implies that both PW-1 & PW-2 were pumping during the test run in PW-5; however, it was stated that both PW-1 & PW-2 were shut-off an hour prior to initiation of the test and only PW-1 was re-started on the third day of the test to meet the water needs of the town. Which wells were pumping during the test? Why was a pump test run during a known period of high demand (i.e., 4'"' of July week in a community near the coast) versus a period of low demand when all supply wells could have remained off for the duration of the test?

5) The concern about contaminant transport from the Columbia to the Manokin was not examined quantitatively, using the aquifer test and modeling results. As a rough estimate of leakage from the Columbia into the Manokin, it helps to look at the leakance factor calculated during the Jacob-Hantush analysis of the aquifer test data. These results are included as AQTESOLV outputs in Appendix B. The calculated r/B for each monitor well is on the order of 0.01 (dimensionless). The wells are located at an average distance of less than 200 feet from PW-5. This gives a leakance factor L (or B) of around 4,000 meters and a resistance of more than 10,000 days. That is a very high resistance, and indicates an aquitard that is only slightly leaky.

Interpretation of this result depends on the conceptual model of aquifer layers in the study area. The descriptive conceptual model in the study report indicates that the Columbia is separated from the Manokin by a leaky unit called the Bethany Formation. However, the detailed logs indicate otherwise. The Columbia and Bethany appear to be separated by a consistent unit of layers of clay and sandy silt. The Bethany Formation itself appears to consist of a thick layer of sandy silts near PW-5, while the area of the contaminant plume seems to have a better developed aquifer within the Bethany Formation. The concern about contaminant transport from the Columbia to the Manokin should be examined.quantitatively, using the aquifer test and modeling results.

6) Section 3.2.1 - ARCADIS stated that the Columbia aquifer showed a minor response (approximately less than 0.1 ft) during the pump test in the Manokin aquifer; however, negative drawdown was observed in the shallow observation wells in the Columbia aquifer from the start of the test on 6/29/10 through 7/l/l0(see Figure B-3). It was only after PW-1 began pumping at 200 gpm in the Columbia aquifer that drawdown was clearly evident in each of the shallow observation wells.

7) Section 3.2.2 - It appears as though ARCADIS calculated transmissivity and hydraulic conductivity for the Manokin aquifer using an average of individual time-drawdown plots for each of the deep observation wells. A composite analysis of all the observation wells may better serve the data due to the lateral variation in the lower confining unit of the Bethany Formation in the southeasterly direction. This analysis would help identify any wells that may be isolated from the portion of the aquifer the pumping well draws the majority of its supply, and it could also provide additional information to evaluate the conceptual model layer between the Pocomoke and Manokin aquifers.

8) The hydraulic conductivity assigned to the Pocomoke model layer was not based on aquifer tests

included in this report. The value of 0.5 feet/day is approximately 1% to 10% of values

frequently seen for the aquifer in wells where tests have been run. Use of such extreme values of

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aquifer properties should have been investigated by running aquifer tests on the middle monitoring wells. In addition, the groundwater model that uses the upward flow into the Columbia aquifer as an assumption has it highest residuals (errors) in the shallow observation points used for calibration. The model appears to adequately predict the response of the Manokin aquifer, but the residuals in the Columbia (mean: 0.52 ft) are more than 200% of the range of observed differences in water levels (as depicted in Figure B-3). The model does not accurately predict the effect of the pumping of the Manokin on the Columbia. The assumption of upward flow from the Manokin into the Columbia may not be valid.

9) Was any data available (i.e., head data from observation wells) near the model boundaries to indicate whether the no flow cells had any effect on the area of concern?

10) Due to the variations evident in the Bethany Formation confining units from west to east it would be recommended that a pump test be run in either PW-3 or -4 to further evaluate the potential for drawdown of the contaminant plume. The pump test should be run as a variable-discharge test to evaluate the model scenarios ARCADIS derived for the Manokin wells.

11) Was any data available near the model boundaries to indicate that the no flow cells were not too close to the area of concern?

12) Were the lithologic descriptions in MW-6 and MW-7 similar to those of MW-11, -12, -13, -14, -15, and -16? If so, why does ARCADIS think that pumping in the Manokin aquifer needs to be limited to 200 gpm, since no drawdown was observed in the Columbia aquifer during the PW-5 test at a rate of 580 gpm, prior to the re-start of PW-1 (Columbia aquifer)? If the descriptions were different and more interconnection was evident via interconnected sands then a pump test is warranted in either PW-3 or PW-4. The pump test could be run as a step test versus a constant rate test.

Recommendations:

1) The conclusion that "Operation of PW-1 and PW-2 is required to control lateral and vertical plume migration" should be replaced by "Operation of multiple shallow recovery wells is required to control lateral and vertical plume migration". The model did not analyze any scenarios related to other recovery wells or demonstrate their failure to control migration of the plume.

2) The use of unsubstantiated and extreme values of aquifer parameters (see Comment 8, above) could be corrected by drilling a new middle layer observation well, at least 4 inches in diameter, performing geophysical logs, and running an aquifer test, using the other "M" wells as observation wells. However, this would be a refinement of the current model. The alternate course of action is seen in recommendation 7.

3) The soil boring log descriptions are inconsistent in their classifications. Some layers are described as hard or loose, while others have no indications of hardness. Some layers describe the percentage of silt in silty sands (e.g. 20% to 25%), while others lack quantitative information. These inconsistencies are most frequently mitigated in other studies in Delaware by using geophysical logs to provide objective measurements of the physical properties of the units.

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4) There is no figure or table showing the correlation between the lithologic descriptions and the model layers. Addifional drilling for this project should include geophysical logs of wells to allow better correlation and model adjustnients.

5) The modeling scenarios have been constrained to only tho.se that use the facilities of the Town of Millsboro. No evidence has been presented relating to ideal locations of recovery facilities or optimization of the recovery .system although it appears from subsequent discussions that this is a immediate step to address the need to dispose of the treated water from PW| & 2 rather than the actual remedial design to address the TCE plume.

6) A composite analysis should be performed using all the monitor wells, to identify any wells that may be isolated from the portion of the aquifer the pumping well draws the majority of its supply.

7) A variable-rate discharge test should be completed in either PW-3 or -4 to evaluate the model scenarios ARCADIS derived for the Manokin wells.

8) Once a UIC recharge location has been secured, a UIC test pennit application should be provided to the Department along with the results of the CAWP.

References

Hinaman, K.C., and Tenbus, F.J., 2000, Hydrogeology and simulation of ground-water flow at Dover Air Force Base, Delaware: United States Geological Sur\'ey Water Resources Investigations Report 99-4224, 72 p.

Ramsey, Kelvin W., 2010, Stratigraphy, Correlation, and Deposidonal Environments of the Middle to Late Pleistocene Interglacial Deposits of Southern Delaware, Delaware Geological Survey Report of Investigations No. 76, 43 p.

If you have any questions regarding the information contained in this letter, please do not hesitate to contact me at (302) 395-2600.

Sincerely,

Robert C. Asreen, Jr. Project Manager

Enclosure

RCA:vdh;RCAI IOI5.doc; DE 1361 11 B II

pc: Kathy Stiller Banning, Program Manager II Paul Will, Program Manager I John T. Barndt, Division of Water Resources, Program Manager

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http://tho.se

DELAWARE DEPARTMENT OF

NATURAL RESOURCES AND ENVIRONMENTAL CONTROL

Underground Injection Control (UIC) Class V Well Application Form

Note: Information that has been previously submitted to another DNREC Division, Section or Branch, other than the Ground Water Discharges Section (GWDS), is not considered part of this application.

The Director shall not issue a pennit before receiving a complete application for a permit. An application for a permit is complete when the Director receives an application form and any supplemental information which are completed to his or her satisfaction. The completeness of any applicafion for a permit shall be judged independently of the status of any other permit application or permit for the same facility or activity. [40 CFR §144.31]

If an application requires public advertisement, the applicant shall provide a second copy, for public review.

All information provided shall be considered public information and shall be considered part of the public record pertaining to the permit application. If the applicant can demonstrate that information provided is not a matter of public record at the time of the application, and that the release of such Information to the public would constitute an invasion of personal privacy or would seriously affect the applicant's business or competitive situation, the Department may designate such information as confidential information. [7 Del. Code §7903]

Any underground injection, except into a well authorized by rule or except as authorized by permit issued under the UIC program, is prohibited. The construction of any well required to have a [UIC] permit is prohibited until the [UIC] permit has been issued. [40 CFR §144.11]

Instructions: All applicable items must be completed in order to avoid delay in processing this application. Where attached sheets or other technical documentation are utilized in lieu of filling in the blank spaces on this form, please provide a cross reference in the blank spaces and identify each attachment by item number. Only original signatures are acceptable. When possible, please submit your application and associated paperwork on double-sided paper.

If each well is identical, you may complete one application, to cover all wells

Number of identical wells:

Application Date: (M/D/YYYY)

A. APPLICANT

Name:

Address:

City: , County: , State:

Zip code:

Telephone: Fax: ;

In accordance with 40 CFR §144.32, all applications shall be signed by an authorized official, and shall include the following certification statement:

"I hereby certify, under penalty of law, that 1 have personally examined and am familiar with the information submitted in this document and all attachments thereto and that, based on my inquiry of those individuals immediately responsible for obtaining said information, I believe that the information is true, accurate and complete. I am aware that there are significant penalties, including the possibility of fines and imprisonment,

Page 1 of 8 Revised January 2007

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for submitting false information. I agree to construct, operate, maintain, repair, and I agree to, applicable, abandon the injection well and all related appurtenances in accordance with the approved specifications and conditions of the approval."

Signature:

Print Applicant Name & Title:

B. PROPERTY OWNER (if different from applicant)

Name:

Address:

City:

Zip code:

Telephone:

County: State:

CONSENT O F PROPER TY O fVNER

If the property is owned by someone other than the applicant, the property owner hereby consents to allow the applicant to construct each injection well as outlined in this application and that it shall be the responsibility of the applicant to ensure that each injection well conforms to the Well Construction Standards.

Signature of Property Owner if Different from Applicant

Print Owner Name & Title:

DELAWARE-REGISTERED PROFESSIONAL ENGINEER/GEOLOGIST (Optional)

"1 certify that the features of this injection point have been designed or examined by me and found to be in conformity with modern principles of injection of fluids and well design for the purpose described in this application. There is reasonable assurance, in my professional judgment, that the injection point, when properly maintained and operated, will discharge the fluid in compliance with all applicable statues of the State of Delaware and the rules of the Department of Natural Resources and Environmental Control. It is agreed that the undersigned will furnish the applicant with a set of instructions for proper maintenance and operation of the injection point."

(seal)

DE Registration number:

Signature:

Print Name & Title:

Company name:

Mailing address:

Issue date: Expiration date:


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D. STATUS OF APPLICANT

. Federal Q StateQ Private Q Native American Lands Q

Public n Commercial j I Other (please specify) Q -

E. FACILITY (SITE) DATA

Name of Business or Facility:

Address:

City: , County: , State:

Zip code:

Telephone: Fax:

Contact Person (name & title):

Tax Map number:

4-digit SIC code (up to 4 codes): , , ,

Is business currently in operation or have operations ceased? If still in operation, provide current

business name.

Please provide a description of the activities conducted by the applicant which require a UIC permit or Authorization. Please also include the event(s) which led to the need for remediation, if applicable:

Please mark in the appropriate box a listing of all permits or construction approvals received or applied for under any of the following programs:

I I Hazardous Waste Management program under RCRA.

n LIIC program under SDWA.

n NPDES program under CWA.

I I Prevention of Significant Deterioration (PSD) program under the Clean Air Act.

I I Nonattainment program under the Clean Air Act.

f~~| National Emission Standards for Hazardous Pollutants (NESHAP) preconstruction approval under the Clean Air Act.

I I Ocean dumping permits under the Marine Protection Research and Sanctuaries Act.

I I Dredge and fill permits under section 404 of CWA.

I I Other relevant environmental permits, including State permits. Explain:

F. WELL USE Will the injection point(s) also be used for your personal consumption?

Yes n No n


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G. INJECTION PROCEDURE (Briefly describe how the injection point(s) will be used, including the

expected duration of injection activities.)

H. PROJECT DESCRIPTION

1) Description and Use of Facility; include a brief description of the nature of the business

2) Description of Injectate (include a MSDS sheet(s))

3) Treatment of Injectate prior to Injection (including mixing ratios)

4) Description of any discharged fluid, including destination of discharged fluid.

5) Please attach any approval letters from any DNREC Division (including the Tank Management Branch

(TMB) or the Site Investigation and Restoration Branch (SIRB)), in relation to the injection activities.

CONSTRUCTION DATA (check one)

The construction of any well required to have a [UIC] permit is prohibited until the [UIC] permit has been issued. [40 CFR §144.11]

D EXISTING INJECTION WELL to be modified. Provide the data in (1) through (7) below as

PROPOSED construction specifications. Submit a copy of the completion report after construction.

I I EXISTING WELL being proposed for use as an injection well. Provide the data in (1) through (7)

below to the best of your knowledge. Attach a copy of a well permit and completion report.

r~l PROPOSED WELL to be constructed for use as an injection well. Provide the data in (1) through

(7) below as PROPOSED construction specifications. Submit a copy of the completion report after

construction.


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If each well is identical, you may complete one application, to cover all wells

Number of identical wells:

Well permit number($) (if existing wells):

NOTE: The well drilling contractor can supply the data for either existing or proposed well if this is information is

unavailable by other means.

(I) Well drilling Contractor's Name:

Drillers License Number:

(2) Date to be constructed: (M/D/YYYY)

Approximate depth: ft

(3) Well casing:

(a) Type: Galvanized steel {Z\ Black steel [^ Plastic [^

Other (specify) CU -_

(b) Inside diameter; inches;

Wall thickness inches or Schedule #

(c) Casing depth: From to ft. (reference to land surface)

(d) Casing extending above ground inches

(4) Grout Seal:

(a) Around inner or "primary" casing: From to ft. (from the land surface to the point

of injection)

(b) Around outer (pit) casing, if present: From to ft.

(c) Type

(5) Screens (if applicable):

(a) Type: ; Inner diameter inches

(b) Depth: From to feet below land surface

(6) Gravel (if applicable): From to feet below land surface


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J. PROPOSED OPERATING DATA

(1) Injection rate: Maximum (daily)

Average (daily) gallons per minute (gpm)

How will the rate be measured?

gallons per minute (gpm)

(2) Injection volume: Average gallons per minute (gpm)

Maximum gallons per minute (gpm)

How will the volume be measured?

(3) Injection pressure: Average (daily) pounds/square inch (psi)

How will the pressure be measured?

(4) Depth to injection area: feet

(5) Expected lifetimeof//?/"ec//o/; activities: months

(6) Anticipated start date:

(7) Temperature of injectate: Average

Maximum

Minimum

degrees F

degrees F

degrees F

K. INJECTION-RELATED EQUIPMENT

Attach a diagram showing the layout of the (i) injection equipment, (ii) exterior piping/tubing associated with the injection operation, and (iii) the proposed injection points.

L. TOPOGRAPHIC MAP

Attach a scaled, color topographic map extending 3,000 feet beyond the property boundaries of the source (not to exceed one (1) mile), depicting the facility and the following: the facility's intake and discharge structures; each of its hazardous waste treatment, storage, or disposal facilities; and each well where fluids from the facility are injected underground. Also include those wells, springs, and other surface water bodies, and drinking water wells listed in public records or otherwise known to the applicant within a quarter (%) mile of the facility property boundary. [40 CFR §144.31]

M. HYDROGEOLOGIC MAPS AND CROSS SECTIONS

Attach scaled maps and cross sections indicating the vertical and lateral limits of all underground sources of drinking water within 3,000 ft. Include their position relative to the injection formation, and the direction to water which may be affected by the proposed injection. [40 CFR §146.14]


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N. AREA OF REVIEW

Attach a detailed, scaled color map of the site of the facility, showing the location of and distances between the proposed well(s) (source wells and injection wells) and any waste (including hazardous waste) treatment, storage or disposal facilities; buildings; property boundaries; surface water bodies; and any other potential source of groundwater contamination. Additionally, indicate on the map the direction and distance to existing wells (injection wells, water supply wells, dry wells, abandoned wells) located within 3,000 feet of the proposed injection well(s). Include with the map a description of each existing well incorporating type, construction information, date drilled, and depth. Indicate on the map at least two nearby reference points such as roads, road intersections, streams, etc., and identify them by numbers or name. Label all features clearly. Include a north arrow on the map to indicate orientation.

The map shall include a drawing indicating the plume of contamination (including the entire boundary of the contamination) and the direction of movement of the injected fluid (this may be shown on any submitted map).

O. MONITORING FLAN

Describe any plans to monitor fluid movement. If contaminants are present, the operation of an injection well must not result in the migration of a contaminant off property boundaries.

P. CONTINGENCY PLAN

Attach a brief plan to address emergency control methods that will be utilized in case of an injection well failure or loss of power so as to prevent the discharge of fluids outside the injection zone area. [40 CFR §146.70]

Q. ABANDONMENT PLAN

Plugging and abandonment. Any Class I permit shall include, and any Class V permit or Authorization may include, conditions to ensure that plugging and abandonment of the well wil I not allow the movement of fluids either into an underground source of drinking water or from one underground source of drinking water to another. Any applicant for a UIC permit or Authorization shall be required to submit a plan for plugging and abandonment. Where the plan meets the requirements of this paragraph, the Secretary shall incorporate it into the permit or Authorization as a condition. Where the Secretary's review of an application indicates that the permittee's plan is inadequate, the Secretary shall require the applicant to revise the plan, prescribe conditions meeting the requirements of this paragraph, or deny the application. For purposes of this paragraph, temporary intermittent cessation of injection operations is not abandonment. In the event a radioactive source tool has been irretrievably lost down an injection well, the Department shall be immediately notified. [40 CFR §146.10]

Financial responsibility. The permit or Authorization shall require the permittee to maintain financial responsibility and resources to close, plug, and abandon the underground injection operation in a manner prescribed by the Secretary. The permittee may be required to show evidence of financial responsibility to the Secretary by submission of surety bond, or other adequate assurance, such as financial statements or other materials acceptable to the Secretary. [40 CFR §144.52]


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Please return the completed application package to:

DNREC - GWDS Attn: Kathy Wright 89 Kings Highway Dover, DE 19901

Telephone: 302-739-9948 Fax: 302-739-7764

When possible, please submit your application and associated paperwork on double-sided paper. .


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391 LUKENS DRIVE NEW CASTLE, DELAWARE 19720-2774 SITE ... · General UIC Permitting Process...

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