WI0400090_Complete File - Historical_20070913

Michael F. Easley, Govemor
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
Coleen H. Sullins Director
Division of Water Quality
September 13, 2007
Mr. Keith Snavely
NCDENR DWM ISB
1646 Mail Service Center
Raleigh, NC 27699-1646
RE: Former Burlington Industries, 300 Meadowview Rd.
Greensboro, Guilford County, North Carolina
Dear Mr. Snavely:
The Groundwater Protection Unit of the Aquifer Protection Section of the Division of Water
Quality has reviewed the permit application for injection of EOS®, received on August 20, 2007.
The proposed injection as presented in the work plan meets relevant state regulatory
requirements (15A NCAC 2C .0200) for construction and operation of an injection well system.
In general we would prefer to see sampling events prior to injection then semi-annually until the
bio-degradation reactions have completed.
Due to the site's coverage under the Comprehensive Environmental Response, Compensation,
and Liability Act (CERCLA), the state's administrative permitting requirements have been
waived for this project under N.C.G.S. 130A-310.3 (e). A technical report summarizing the
project including all monitoring data should be submitted to the Groundwater Protection Unit
upon completion of the injection project.
If you have any questions regarding this letter please call me at [phone].
Since ,
Peter Po 0
Hy
drogeo o
cc: Robert Rogero, Solutions-IES
Tony Lieberman, Solutions-IES
Aquifer Protection Section — Winston-Salem Regional Office
CO-UIC files
Aquifer Protection Section 1636 Mail Service Center
Intemet: www.ncwaterguality.org Location: 2728 Capital Boulevard
An Equal Opportunity/Affirmative Action Employer— 50% Recycled/10% Post Consumer Paper
Noo' hCarolina
,Naturally
Raleigh, NC 27699-1636 Telephone: [phone]
Raleigh, NC 27604 Fax 1: [phone]
Fax 2: [phone]
Customer Service: [phone]

Central Files: APS SWP
08/22/07
Permit Number W10400090 Permit Tracking Slip
Program Category Status Project Type
Ground Water In review New Project
Permit Type Version Permit Classification
Injection In situ Groundwater Remediation Well (51) Individual
Primary Reviewer
peter.pozzo
Permitted Flow
Permit Contact Affiliation
Tony Lieberman
1101 Nowell Rd
Raleigh NC
Facility
Facility Name Major/Minor Region
Former Burlington Industries Minor Winston-Salem
Location Address
300 E Meadowview Rd
Greensboro NC 27406
wner
County
Guilford
Facility Contact Affiliation
Owner Name Owner Type
NCDENR Division of Waste Management Inactive Hazardous Government - State
Sites Branch
Owner Affiliation
Keith Snavely
27606
1646 Mail Service Ctr
Raleigh NC 276991646
Dates/Events
Scheduled
Orig Issue App Received Draft Initiated Issuance Public Notice Issue Effective Expiration
08/20/07
Regulated Activities Reauested/Received Events
RO staff report requested
RO staff report received
Outfall r, JL
Waterbody Name Stream Index Number Current Class Subbasin

State of North Carolina
Department of Environment and Natural Resources
Division of Water Quality
APPLICATION FOR PERMIT TO CONSTRUCT AND/OR USE A WELL(S) FOR INJECTION
Type 5I Wells — In Situ Groundwater Remediation / Type 5T Wells — Tracer Injection
• Do not use this form for remediation systems that extract contaminated groundwater, treat it, and reinject the treated groundwater.
• Submit TWO copies of the completed application and all attachments to the address on the last page of this form.
• Any changes made to this form will result in the application package being returned.
Application Number (to be completed by DWQ):
I. GENERAL INFORMATION:
1. Applicant's Name (generally the responsible party): Keith Snavely
2. Signing Official's Name: Keith Snavely Title: Hydrogeologist
3. Mailing address of applicant: NCDENR Division of Waste Management. Inactive Hazacrin, is Sites Branch
1646 Mail Service Center,. 401 Oberlin Road, Suite 150
City: Raleigh State: NC Zip. 27605
Telephone number: 919 508-8479
Fax number: 919 715-9605
4. Property Owner's Name (if different from Applicant): John K. Snider, President/CEO
5. Property Owner's mailing address: P.n. Box 16046
City:
State: NC Zip: 27416
6. Name and address of contact person who can answer questions about the proposed injection project:
Name: Tong I iPhPrman Title: Bioremediation Program MGR
Company: Snlutions-IFS =
Address:11 r11 Nowell Road
City: RalPiah State: NC Zip: 27607
Telephone number: 919 873-1060 Fax number: 919 873-1074
Email Address: tliPhPrmanAgnhitinns-iPs rnm
H. PERMIT INFORMATION:
1. Project is: ZNew ❑ Modification of existing permit ❑ Renewal of existing permit without modification
If this application is being submitted for renewal or modification to an existing permit, provide:
existing permit number and the issuance date
For renewal without modifications, fill out sections I & II only, sign the certification on the last page of this
form, and obtain the property owner's signature to indicate consent (if the applicant is not the owner).
UIC-5I/5T ver. 12-05 Page I of 7

APPLICATION FOR PERMIT TO CONSTRUCT AND/OR USE A WELL(S) FOR INJECTION
Type 51 Wells — In Situ Groundwater Remediation / Type 5T Wells — Tracer Injection
III. INCIDENT & FACILITY DATA
A. FACILITY INFORMATION
1. Facility name: Fnrmer Btirlinclton Industries
2. Complete physical address of the facility:_ 300 East Meadowview Road
City: GrPPnshnrn County: r;uilfnrd State: NC Zip: 97408
B. INCIDENT DESCRIPTION
1. Describe the source of the contamination:
Unknown, suspected buried drums and still bottoms.
2. List all contaminants present in soils or groundwater at the site (contaminants may be listed in groups, e.g.,
gasoline, diesel, jet fuel, fuel oil, chlorinated ethenes, chlorinated ethanes, metals, pesticides/herbicides, etc):
Chlorinated ethenes.
3. Has LNAPL or DNAPL ever been observed at the site (even if outside the injection zone)?
❑ Yes If yes, list maximum measured separate phase thickness: feet
V No If no, list maximum concentration of total VOCs observed at site: 5,885 ppb
4. Agency managing the contamination incident:
❑ UST Section V Superfund Section (including REC Program and DSCA sites)
❑ DWQ Aquifer Protection Section ❑ Solid Waste Section
❑ Hazardous Waste Section ❑ Other:
5. Incident number or other site number assigned by the agency managing the contamination incident:
NONCD0000027
C. PERMITS
List all permits or construction approvals that have been issued for the facility or incident, including those not
directly related to the proposed injection operation:
1. Hazardous Waste Management program permits under RCRA: NONCD0000027
2. DWQ Non -Discharge or NPDES permits: S2019 (City of Greensboro) -no longer active
3. County or DEH subsurface wastewater disposal permits: None known
4. Other environmental permits required by state or federal law:.NnnP known
UIC-51/5T ver. 12-05 Page 2 of 7

APPLICATION FOR PERMIT TO CONSTRUCT AND/OR USE A WELL(S) FOR INJECTION
Type 5I Wells — In Situ Groundwater Remediation / Type 5T Wells — Tracer Injection
IV. INJECTION DATA
A. INJECTION FLUID DATA
1. List all proposed injectants.
NOTE: Any substance to be injected as a tracer or to promote in situ remediation must be reviewed by the
Occupational and Environmental Epidemiology Section (OEES) of the Division of Public Health, Department of
Health and Human Services. Review the list of a�roved injectants or contact the UIC Program to determine if
the injectants you are proposing have been reviewed by OEES.
• 17 -u -• -•- _•1111111111111111- • _••11111111111111•1'�111111-• • 11R.WMEARRIM. •
Inj ectant:
Concentration at point of injection:
Inj ectant:
Concentration at point of injection:
Inj ectant:
Concentration at point of injection:
Injectant:
Concentration at point of inj
2. Source of fluids used to dilute or chase the injectants listed above:
❑ None
© Municipal water supply
❑ Groundwater from private well or any well within '/4 mile of injection site
❑ Air
❑ Other:
3. If groundwater from a private well or any well within'/4 mile of injection site is to be used as the fluid source,
supply the following information:
a. Location/ID number of source well:
b. Depth of source: N/A
c. Formation: N/A
d. Rock/Sediment type: N/A
e. In Attachment B, provide a current, complete chemical analysis of the water from the source well, including
analyses for all contaminants suspected or historically recognized in soil or groundwater on the site.
NOTE: If contaminated groundwater is to be used as the dilution or chase fluid, this is not the proper permit
application form. You must apply for a closed -loop groundwater remediation permit using application form
GP'P6.
UIC-5I/5T ver. 12-05 Page 3 of 7

APPLICATION FOR PERMIT TO CONSTRUCT AND/OR USE A WELL(S) FOR INJECTION
Type 5I Wells — In Situ Groundwater Remediation / Type 5T Wells — Tracer Injection
B. PROPOSED OPERATING PARAMETERS
1. Duration of Injection:
Maximum number of separate injection events: 1 event
Expected duration of each injection event: 60 hours
Expected duration between events (if more than one event): N/A
2. Injection rate per well: Pst 7nnm gallons per minute (gpm)
3. Total Injection volume: est. 12,600 gallons per day (gpd); 103,900 gallons per event (if separate events)
4. Injection pressure: <10 psi pounds/square inch (psi)
5. Temperature at point of injection: arabient °F
6. Briefly describe how the above parameters will be measured and controlled:
Flow distribution manifold with flow meters, gate valves and pressure gauges.
7. Estimated hydraulic capacity of the well: < 7 gpm
1. Injection will be via:
❑ Existing well(s) proposed for use as an injection well. Provide the data in (2) through (6) below to the best of
your knowledge.
7 Proposed well(s) to be constructed for use as an injection well. Provide the data in (2) through (6) below as
proposed construction specifications.
2. Well Drilling Contractor's Name: (,r ha am & Qjrri _ Well nrillinq Campanv
NC Well Contractor Certification number: #2373-Tarrell Graham Jr.
3. Date to be constructed: 10/31 /07 Number of borings: 6
Approximate depth of each boring (feet): estimated 80 ft bgs.
4. Screened interval/Injection interval of injection wells:
Depth: 60— to 8fl — feet below ground surface (if multiple intervals, indicate shallowest and deepest depth).
5. Well casing (N/A if injection is through direct push rods):
Type: 7 PVC ❑ Stainless steel ❑ Other:
Casing depth:
0 to 60 ft.
6. Grout (N/A if injection is through direct push rods):
Type: 7 Cement ❑ Bentonite ❑ Other:
Grout depth: n to r;,9 ft.
UIC-51/5T ver. 12-05 Page 4 of 7

APPLICATION FOR PERMIT TO CONSTRUCT AND/OR USE A WELL(S) FOR INJECTION
Type 5I Wells — In Situ Groundwater Remediation / Type 5T Wells — Tracer Injection
V. ATTACHMENTS
Provide the following items as attachments with the given headings:
A. HYDROGEOLOGIC DESCRIPTION
Provide a hydrogeologic description, soils description, and cross section of the subsurface to a depth that includes the
known or projected depth of contamination. The hydrogeologic description shall include:
(1) the regional geologic setting;
(2) significant changes in lithology;
(3) the hydraulic conductivity, transmissivity, and specific yield of the aquifer to be used for injection, including a
description of the test(s) used to determine these parameters; and
(4) the depth to the mean seasonal high water table.
NOTE: G.S. 89E-18 requires that any geologic plans, reports, or documents in which the performance is related to the
public welfare or safeguarding of the environment be prepared by a licensed geologist or subordinate under his or her
direction. G. S. 89E-13 requires that all drawings, reports, or documents involving geologic work which shall have been
prepared or approved by a licensed geologist or a subordinate under his or her direction be signed and sealed by him or
her.
B. INJECTION FLUID COMPOSITION
Describe the chemical, physical, biological and radiological characteristics of each injectant. Attach the Material Safety
Data Sheet (MSDS) for each injectant. If a private well or a well within'/4 mile of the injection site is used as the source
well, include chemical analysis of source fluid here.
C. INJECTION RATIONALE
Attach a brief description of the rationale for selecting the injectants and concentrations proposed for injection, including:
(1) goals of the injection project;
(2) a description of the reactions between the injectants and the contaminants present including specific breakdown
products or intermediate compounds that may be formed by the injection; and
(3) summary results of modeling or testing performed to investigate the injectant's potential or susceptibility to change
(biological, chemical or physical) in the subsurface.
D. INJECTION PROCEDURE AND EQUIPMENT
Provide a detailed description of all planned activities related to the proposed injection including but not limited to:
(1) construction plans and materials;
(2) operation procedures;
(3) a detailed diagram of the surface and subsurface portions of the system; and
(4) a planned injection schedule.
E. MONITORING PLAN
Provide a plan for monitoring the results of the injection, including:
(1) a list of existing and proposed monitoring wells to be used;
(2) a list of monitoring parameters and analytical methods to be used; and
(3) a schedule for sampling to monitor the proposed injection.
NOTE: The selected monitoring wells must be located so as to detect any movement of injection fluids, process by-
products, or formation fluids outside the injection area or zone. The monitoring parameters should include the target
contaminants as well as secondary or intermediate contaminants which may result from the injection and other
parameters which may serve to indicate the progress of the intended reactions, such as pH, ORP, dissolved oxygen, and
other electron acceptors and donors. The monitoring schedule should be consistent with the pace of the anticipated
reactions and rate of transport of the injectants and contaminants.
UIC-51/5T ver. 12-05 Page 5 of 7

APPLICATION FOR PERMIT TO CONSTRUCT AND/OR USE A WELL(S) FOR INJECTION
Type 5I Wells — In Situ Groundwater Remediation / Type 5T Wells — Tracer Injection
F. WELL DATA
Provide a tabulation of data on all existing or abandoned wells within '/4 mile of the injection well(s) which penetrate the
proposed injection zone, including, but not limited to, monitoring wells and wells proposed for use as injection wells.
Such data shall include a description of each well's use (water supply, monitoring, etc), total depth, screened or open
borehole depth interval, and well construction or abandonment record, if available.
G. MAP
Attach the following scaled, site -specific maps:
(1) Area map based on the most recent USGS 7.5' topographic map of the area, at a scale of 1:24,000 and
showing the location of the proposed injection site.
(2) Site map including:
a. all property boundaries;
b. all buildings within the property boundary;
c. existing and proposed injection wells or well field(s)
d. any existing sources of potential or known groundwater contamination, including waste storage,
treatment or disposal systems within'/4 mile of the injection well or well system;
e. all surface water bodies within 'A mile of the injection well or well system; and
f. all existing or abandoned wells within '/4 mile of the injection well(s) which penetrate the proposed
injection zone, including, but not limited to, monitoring wells and wells proposed for use as injection
wells.
(3) Potentiometric surface map(s) including:
a. direction of groundwater movement
b. existing and proposed monitoring wells
c. existing and proposed injection wells
(4) Contaminant plume map(s) including:
a. the horizontal extent of the contaminant plume, including isoconcentration lines
b. existing and proposed monitoring wells
c. existing and proposed injection wells
(5) Cross-section(s) to the known or projected depth of contamination, including:
a. horizontal and vertical extent of the contaminant plume, including isoconcentration lines
b. major changes in lithology
UIC-51/5T ver. I2-05 Page 6 of 7

APPLICATION FOR PERMIT TO CONSTRUCT AND/OR USE A WELL(S) FOR INJECTION
Type 5I Wells — In Situ Groundwater Remediation / Type 5T Wells — Tracer Injection
VI. CERTIFICATION
1, Keith Snavely inn - , 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,
1 believe that the information is true, accurate and complete. I am aware that there are significant penalties,
including the possibility of fines and imprisonment, for submitting false information. I agree to construct,
operate, maintain, repair, and if applicable, abandon the injection well(s) and all related appurtenances in
accordance with the approved specifications and conditions of the Permit.
Signature: Date:
Title: Hydrogeologist
If authorized agent is acting on behalf of the applicant, supply a letter signed by the applicant authorizing the
above agent.
VI1. CONSENT OF PROPERTY OWNER (if the property is not owned by the applicant)
("Owner " means any person who holds the fee or other property rights in the well being constructed. A well is
real property and its construction on land shall be deemed to vest ownership in the land owner, in the absence of
contrary agreement in writing.)
I, John K. Snider :PresidenV.GE =3„:k;:: % , as owner of the property on which the
injection well(s) are to be constructed and operated, hereby consent to allow the applicant to construct each
injection well as outlined in this application and agree that it shall be the responsibility of the applicant to ensure
that the injection well(s) conform to the Well Construction Standards (Title 15A NCAC 2C .0200)
Signature: Date:
Title:
Submit TWO copies of the completed application package, including all attachments, to:
UIC Program
Aquifer Protection Section
North Carolina DENR-DWQ
1636 Mail Service Center
Raleigh, NC 27699-1636
Telephone [phone]
Q
UIC-51/5T ver.09-06 Page 7 of 7

ATTACHMENT A
Hydrogeologic Description

ATTACHMENT A
Hydrogeologic Description
Al Regional Geologic Setting
The Former Burlington Industries Site is located near the western extent of the Carolina
Slate Belt of the Piedmont Physiographic Province in central Guilford County. Based
upon the Geologic Map of North Carolina (1985), the site is underlain by metamorphosed
intrusive granites with local dioritic intrusions into the felsic igneous complex. The Site
lies in a Felsic Intrusive Complex as mapped by Carpenter in 1982. This complex
consists of white to gray, fine- to coarse -grained, massive to foliated, metamorphosed
bodies of varying assemblages of felsic intrusive rock types. This complex includes
other, separate intrusions such as granite, granodiorite, quartz diorite and quartz
Monzonite. Localized shearing is common in Guildford County. Soil types associated
with this felsic intrusive complex include Appling, Cecil, Durham, Enon, Helena,
Lockhart, Pacolet, Sedgefield, Vance, Wedowee and Wilkes (Carpenter, 1982). The site
is specifically underlain by Mecklenburg -Urban Land Complex (MuB) and Enon-Urban
Land Complex (EuB) (NRCS Web Soil Survey 2.0). Previous consultants working at the
site described the site soils as: "sandy clayey silts".
In the conceptual model for groundwater flow in the Piedmont, precipitation infiltrates
the land surface over large areas, percolates downward through the unsaturated zone, and
recharges the water table. Groundwater moves downward in response to gravity, through
saprolite and openings in bedrock towards areas of lower topography, where it discharges
to surface water in the form of springs, streams and rivers. Generally, groundwater flow
is in the same direction as topographic slope. The depth to groundwater is variable and is
dependent on local conditions. Groundwater can occur either within the soil/saprolite
horizon or entirely within bedrock (LeGrand, 2004). Groundwater at the site varies in
depth depending on topographic location.
A2 Significant Changes in Lithology
In general, the only significant changes in lithology observed during drilling comprises
the weathering profile; weathered residual soils, saprolite, and competent bedrock. These
changes are presented on the two cross -sections from the Remedial Action Plan Report
(Duncklee & Dunham, P.C., March 5, 2003) and are included as Figure 5 and Figure 6
in Attachment G. The surficial soils have been described in boring logs as sand clayey
silts. The saprolite includes in situ weathered residual sediment formed from the
weathering of the bedrock. Felsic granites, amphibole gneisses and diorite were
described on boring logs generated during past drilling of bedrock at the facility. The
depth to each lithology is dependent upon the location on the site and the topography.
Areas closer to the southwest corner of the site near the drainage will typically have less
surficial sediments and saprolite due to erosional processes. Competent bedrock has
typically been encountered at depths of 35 feet or greater, but is dependent upon the rock
type, degree of fracturing and topographic position. At the site, the surficial aquifer

includes surficial sediments and saprolite and has been delineated during previous work
at the site as land surface to approximately 35 ft bgs. The intermediate aquifer ranges
from approximately 35 ft bgs to approximately 70 ft bgs and is primarily comprised of
saprolite and weathered bedrock. The bedrock aquifer approximately lies below the 70 ft
bgs depth and consists of competent bedrock with some fractures.
A3 Hydraulic Conductivity and Transmissivity of the Intermediate Aquifer
Site wide, intermediate aquifer hydraulic conductivities reportedly vary between 4.87
gpd/ft2 in MW-7i to 272 gpd/ft2 in MW-12i. Transmissivity reportedly varies between
212 gpd/ft to 10,914 gpd/ft. All hydraulic conductivity and transmissivity values were
reported in the Remedial Action Plan Report (Duncklee & Dunham, 2003). The specific
yield of the intermediate aquifer is estimated to be approximately 0.20. Based on the
Remedial Action Plan prepared by Aquaterra, Inc. in 1989, the average linear velocity of
groundwater flow in the saprolite is approximately 1.6 to 3.3 ft/day. Solutions-IES has
not performed any verification of these values as calculated by others.
A4 Depth to the Mean Seasonal High Water Table
During the recent groundwater sampling event in April 2007 by Solutions-IES, the depth -
to -water ranged from 5.13 ft below top of casing(btoc; elevation of 77.96 ft relative) in
MW-10S to 23.38 ft btoc (elevation of 78.72 ft relative) in MW-16S. Monitoring well
MW-21 is located across Interstate I-40/85 south of the site and the depth -to -water is 3.67
ft btoc (relative elevation of (76.11 ft). The MW-20 well cluster is located off of the
property and north of Meadowview Road and the depth -to -water in these three wells
ranged from 20.06 to 20.43 ft btoc.

ATTACHMENT B
Injection Fluid Composition

ATTACHMENT B
Injection Fluid Composition
EOS®is a mixture of water, food grade soybean oil, emulsifiers, micronutrients and
Vitamin 13-12 that are mixed and blended to keep the liquid in a single, non -separated
phase concentrate. The emulsified liquid contains oil droplets in the 0.7 to 1.5 micron
size range which allow for ease of dilution, simplicity of injection and optimal subsurface
distribution. All materials used in the process are Generally Recognized As Safe (GRAS)
food -grade materials (21 CFR 184.1400). The Material Safety Data Sheet (MSDS) for
EOSO and Vitamin B-12 are included in Attachment B.
The concentrate will be mixed with potable water provided by the City of Greensboro
during the injection process. The chase water used will also come from the City of
Greensboro. If necessary, the potable water can be passed through a carbon filter to
remove impurities and chlorine residuals from the disinfection process.

ATTACHMENT C
Injection Rationale

ATTACHMENT C
Injection Rationale
C1 Goal of the Injection Project
The goal of this one-time injection is to introduce a biodegradable organic substrate into
portions of the aquifer to stimulate microbial activity and enhance reductive
dechlorination of dissolved chlorinated ethene contaminants present in groundwater at the
site. Six injection wells will be utilized for the injection of EOSO, chase water and
Vitamin 13-12. The locations of the six proposed injection wells are shown on Figure 2 in
Attachment G. The well configuration provides for two linear treatment zones that serve
as a permeable reactive biobarrier (PRBB) where groundwater flows through the
biobarrier and bacteria, enhanced by the added carbon source (EOSO), reductively
dechlorinate the PCE to TCE to cis-1,2-DCE to VC to ethene.
C2 Injectant/Contaminant Reactions and Technology
This project injects a biodegradable organic substrate into a contaminated aquifer. The
technology involves a one-time injection of slowly biodegradable, emulsified oil
substrate (EOSO). EOSO is a water miscible emulsion with an engineered droplet size
that is prepared using food -grade edible oils, surfactants, macro- and micronutrients. The
EOSO process is patented by Solutions-IES (U.S. Patent #6,398,960).
The emulsion is injected and distributed throughout the treatment zone using
conventional injection wells. The vegetable oil becomes trapped within the sediment
grain pores leaving a residual oil phase to support long-term anaerobic biodegradation of
the target contaminants. As the oil slowly biodegrades, it provides a continuous source of
dissolved organic carbon (i.e., fermentation by-products including acetate, propionate,
butyrate) to the native microbial community to stimulate microbiological consumption of
oxygen and production of hydrogen. This reaction is illustrated generically in equation 1:
(Eq. 1) C,8H3202 (linoleic acid) + 34 H2O --Bacteria--> 18 CO2 + 50 H2
The organic substrate is the electron donor in this sequence of reaction. The hydrogen
itself then drives the desired anaerobic biological metabolism of the target contaminants
by a second, more specialized, group of microorganisms. These metabolic
biotransformations are illustrated in equations 2 through 5 where hydrogen is used
sequentially to replace each chlorine atom:
(Eq. 2) C2Cl, (PCE) + H2 -- Bacteria --> C21103 (TCF) + Cl + H+
(Eq. 3) C2HCl 3 (TCE) + H2 -- Bacteria --> C2H2C12 (DCE) + Cl + H+
(Eq. 4) C2H2C12 (cis/traits-DCE) + H2 -- Bacteria --> C2H3C1 (VC) + Cl + H+

(Eq. 5) C2H3C1(VQ + HZ -- Bacteria --> CA (ethene) + Cl + H+
Overall, four hydrogen molecules (41­12) are needed to completely dechlorinate the PCE
molecule to chloride. The formulation of EOSO provides the greatest amount of
hydrogen per mole of substrate used compared to other biodegradable substrates that
were considered for use. These include lactate, polymerized lactate (HRCO), and
molasses which have also been used to stimulate anaerobic reductive dechlorination.
Emulsified vegetable oil also offers the greatest longevity in the aquifer. Substrates that
rely on their solubility to move away from the injection point and create a treatment zone
dissipate quickly and must be replenished frequently. EOSO has been show to remain
effective in aquifers for over three years without re -injection or rejuvenation of the
substrate.
Implementation of the process involves on -site blending of the EOSOconcentrate with
potable water utilizing a Dosatron0 water -powered proportional dosing pump. If the
Dosatron proportional dosing pump is unable to achieve the design flow rate, alternative
mixing and pumping approaches will be implemented. Alternative designs may include
using dilution tanks, chemical feed and transfer pumps to conduct the injection.
C3 EOSO Modeling and Testing Results
Reductive dechlorination of chlorinated ethenes using a carbon source electron donor is a
proven groundwater remediation methodology. The amount of EOSO injected into the
subsurface is determined based on the concentrations of the target compounds (PCE,
TCE and cis-1,2-DCE), the concentrations of competing electron acceptors (i.e.,
dissolved oxygen, nitrate, sulfate, manganese dioxide and ferric iron) and hydrogeologic
conditions (i.e., subsurface lithology and heterogeneity, hydraulic conductivity and
effective porosity of the treatment zone). The available site -specific information obtained
from the Remedial Action Plan (Aquaterra, 1989), Remedial Action Plan Report
(Duncklee & Dunham, 2003) and recent testing by Solutions-IES in April 2007, were
entered into the design spreadsheet provided by EOS Remediation of Raleigh, NC. The
design indicated that 13 drums (5460 lbs) of EOSO would be required at each 3-well
PRB. The design life for this amount of substrate is approximately 3 to 5 years.
To optimize the injection process, the injection was designed to involve diluting the
concentrate 10-fold as it is injected until all the EOSO has been placed in the aquifer.
Then the EOSO is further distributed away from each injection point using potable chase
water. We estimate the volume to be approximately 0.694 lbs of EOSO per gallon water
(404 g/L) added for dilution.
EOSO has been thoroughly tested and is manufactured from food grade soybean oil,
emulsifying agents, micronutrients, vitamin B-12 and water. EOSO was used in a source
area treatment project at the Tarheel Army Missile Plant (TAMP) in Burlington, NC. In
2004, Solutions-IES injected 13,000 pounds of EOSO concentrate into the 100 x 100 ft
(30.5m X 30.5m) zone believed to be the primary source area for the TCE plume. The
EOSO treatment quickly stimulated anaerobic conditions as evidenced by decreased
dissolved oxygen, oxidation-reduction potential, and sulfate concentrations and

increasing ferrous iron, and methane. TCE was gone and only degradation products were
evident within one year of treatment. The regular monitoring program confirmed the
effectiveness of the selected treatment technology. As shown in the figure below, within
one year, TCE concentrations decreased while cis-1,2-dichloroethene and VC increased
in MW-108, a monitoring well located in the center of the treatment plot. Suitable
conditions were established for the contaminants to be reduced to non -chlorinated end -
products.
2500.0
2000.0
1500.0
c
1000.0
C9
500.0
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I I
I I
I I
I I
■ Ethene�
I I
I C I
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O
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■ 1,1-DCE
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❑Trans 1,2-DCE
S I
I ® I
❑ cis 1,2-DCE
®
1
0 TCE
I
I I
■ PCE
I�r
1 1
I I
I I
I I
1 I
I 1
I I
I 1
I I
I I
Apr-04 Jun-04 Aug-04 Oct-04 Dec-04 Feb-05

ATTACHMENT D
Injection Procedure and Equipment

ATTACHEMENT D
Injection Procedure and Equipment
D1 Construction Plans and Materials
Six injection wells will be drilled using 6-inch diameter air rotary and air hammer drilling
techniques. A temporary surface casing will be set during well construction to prevent
caving of the overburden. The borings will be advanced to approximately 80 feet below
ground surface (ft bgs)). The injection wells will be constructed as 2-inch diameter PVC
with 20 feet of 0.020-slot screen. An appropriately sized sand pack will be placed around
the screen to approximately 2 feet above the top of the screen. The remaining annular
space will be backfilled with bentonite pellets (periodically hydrated as they are added to
the annular space) to within 3 feet of land surface. The last 3 feet of annular space shall
be completed with a bentonite grout cement mix. After injection the wells will be
abandoned.
For the injection process, the wells will be manifolded together, but will have individual
flow meters, gate valves and pressure gauges. The Dosatron® diluter (or transfer pump)
will be plumbed into a splitter that will allow individual wells to be shut off from the
injection process as needed. This will allow for the control of pressure and flow rates of
injection at each well. The manifold will be plumbed to a Dosatron® with a potable water
source (City of Greensboro) to provide dilution of the EOS® concentrate. The Dosatron°
will only allow a maximum total flow of 7 gpm. Therefore, to inject three wells
simultaneously the injection rate will be limited to 2 gpm per well.
D2 Operation Procedures
A Dosatron® will be set up on a drum of EOS® via a flexible hose. Water from a fire
hydrant will go through a City of Greensboro supplied flow meter, then into the
Dosatron® for use in diluting the EOS° to the proper 10:1 concentration (10 parts water
to 1 part EOS®. The mixture will then be piped to the splitter where the injectant will be
directed into flexible hoses going to each well head manifold. Each braided hose line
will have a flow meter to determine the total volume of injectant going into each well. A
gate valve and pressure valve at each well manifold will allow field personnel to monitor
and adjust flow rates and fluid pressures during the injection process. Upon completion
of the injection into the first three wells (IW-A, 1W-B and IW-C), the injection system
will be moved over to the other three injection wells (IW-D, IW-E and IW-F). Upon
completion of the injection of EOS®, chase water will be injected into each well (14,700
gallons) to further disperse the EOS® in the subsurface.

D3 Surface and Subsurface System Diagrams
Figure 7 presents a schematic diagram of the injection process.
D4 Injection Schedule
The injection is anticipated to occur during the Fall of 2007. The injection well
installation field activities will commence within one month of receiving authorization
from the UIC to proceed with the injection. The actual injection of EOS® will occur
within two weeks of the completion of the injection wells.

ATTACHMENT E
Monitoring Plans

ATTACHMENT E
Monitoring Plans
El Proposed Monitoring Wells
The following wells will be used for post -injection monitoring:
• MW-13s
• MW-13i
• MW-13d
• MW-16s
• MW-16i
E2 Sampling Parameters
Post injection groundwater sampling will include the following constituents for each
well:
• pH (field);
• Specific Conductance (field);
• Temperature (field);
• Oxidation reduction potential (field);
• Turbidity (field);
• Dissolved oxygen (field);
• Volatile Organic Compounds (Method 8260B).
• Total Organic Carbon (Method 531013);
• Nitrate (Method 353.2);
• Sulfate (Method 375.4); and
• Volatile Organic Compounds (Method 8260B).
E3 Sampling Schedule
The IHSB anticipates performing one post -injection sampling event approximately three
to six months after the injection process is completed.

REFERENCES

REFERENCES
Aquaterra, Inc., 1998. September 1997 Semiannual Ground Water Sampling Report,
Burlington Industries, Inc., 300 Meadowview Road Site, Greensboro, North Carolina.
Carpenter, III, P.A., 1982. Geologic Map of Region G, North Carolina. Regional
Geology Series 2, State of North Carolina, Department of Natural Resources and
Community Development, Geological Survey Section.
Duncklee & Dunham, P.C., 2CO3. Remedial Action Plan Report, Burlington Industries,
Inc., 300 East Meadowview Road Site.
LeGrand, Sr., H.E., 2004. A Master Conceptual Model for Hydrogeological Site
Characterization in the Piedmont and Mountain region of North Carolina, NCDENR,
Division of Water Quality, Groundwater Section.
USDA Soil Mapping (accessed July 2007). Soil Survey Staff, Natural Resources
Conservation Service, United States Department of Agriculture. Web Soil Survey.
Available online at http://websoilstirvey.nres.tisda.gov/.

ATTACHMENT F
Well Data

Summary Table of Wells Within a Quarter -Mile Radius
Former Burlington Industries
300 Meadowview Road, Greensboro, Guilford County, NC
Site
Well Identification
Screened IntervalRelative
(ft, bgs)
Location to
Injection Site
Well Type
Precision Fabrics
MW-1
22-37
upgradient
monitoring well
REC program
MW-2
22-35
upgradient
monitoring well
MW-3
21-36
upgradient
monitoring well
MW-3i
22-37
upgradient
monitoring well
MW-6
90-100
upgradient
monitoring well
MW-7
50-60
upgradient
monitoring well
MW-8
50-60
upgradient
monitoring well
MW-9
17-32
upgradient
monitoring well
MW-11
17-32
upgradient
monitoring well
MW-12
18-33
upgradient
monitoring well
MW-13
50-60
upgradient
monitoring well
MW-15d
88-98
upgradient
monitoring well
MW-15s
15-30
upgradient
monitoring well
MW-16
84-99
upgradient
monitoring well
MW-17i
70-80
upgradient
monitoring well
MW-19s
15-31
upgradient
monitoring well
MW-20
25-30
upgradient
monitoring well
MW-20i
60-65
upgradient
monitoring well
MW-20d
83-98
upgradient
monitoring well
MW-21
15-30
upgradient
monitoring well
MW-21 i
80-100
upgradient
monitoring well
MW-21 d
120-150
upgradient
monitoring well
MW-22s
54-74
upgradient
monitoring well
MW-22i
54-74
upgradient
monitoring well
MW-22d
95-115
upgradient
monitoring well
MW-23s
20-35
upgradient
monitoring well
MW-24s
13-40
upgradient
monitoring well
OW-1
45-65
upgradient
monitoring well
OW-1 a
25-35
upgradient
monitoring well
OW-2
45-65
upgradient
monitoring well
OW-2a
25-35
upgradient
monitoring well
OW-3
120-150
upgradient
monitoring well
OW-3a
83-103
upgradient
monitoring well
OW-4
120-150
upgradient
monitoring well
OW-4a
83-103
upgradient
monitoring well
IW-1
40-70
upgradient
injection well
IW-2
40-70
upgradient
injection well
IW-3
40-70
upgradient
injection well
IW-4
100-150
upgradient
injection well
IW-5
100-150
upgradient
injection well
IW-6
100-150
upgradient
injection well

Summary Table of Wells Within a Quarter -Mile Radius
Former Burlington Industries
300 Meador+view Road, Greensboro, Guilford County, NC
Holding Pond for
Scrubber Waste
MW-1
5-20
side gradient
monitoring well
NCD 051745685
MW-2
5-15
side gradient
monitoring well
MW-3
5-15
side gradient
monitoring well
MW-4S
8-28
side gradient
monitoring well
MW-41D
55.75-60.75
side gradient
monitoring well
MW-5
4.5-11.5
side gradient
monitoring well
MW-6S
5-15
side gradient
monitoring well
MW-61D
33-37.75
side gradient
monitoring well
MW-6A
2-12
side gradient
monitoring well
MW-7
5-15
side gradient
monitoring well
MW-8
14.57-26.51
side gradient
monitoring well
MW-81D
36.5-41.5
side gradient
monitoring well
MW-9R
2.0-12.0
side gradient
monitoring well
MW-10
2.24-12.24
side gradient
monitoring well
TW-1
2-12
side gradient
monitoring well
TW-2
2-12
side gradient
monitoring well
TW-3
2-12
side gradient
monitoring well
TW-4
2-17
side gradient
monitoring well
TW-6
2.15-11.70
side gradient
monitoring well
MW-51D
unknown
side gradient
monitoring well
TW-5
2-12
side gradient
monitoring well
TW-10
6-11
side gradient
monitoring well
MW-9R
6-16
side gradient
monitoring well
Unitex Chemical
Corporation
MW-1
9.5-19.5
sidegradient
monitoring well
NCD061795696
MW-2
8-18
sidegradient
monitoring well
MW-2i
25-30
sidegradient
monitoring well
MW-2d
65-75
sidegradient
monitoring well
MW-3
9.5-19.5
sidegradient
monitoring well
MW-4
15.5-25.5
sidegradient
monitoring well
MW-5
7-17
sidegradient
monitoring well
MW-6
6-16
sidegradient
monitoring well
MW-7
TD = 29
sidegradient
monitoring well
MW-8
14-34
sidegradient
monitoring well
MW-9
TD = 19
sidegradient
monitoring well
EW-1
5-60
sidegradient
monitoring well
South Sea Rattan
MW-1
10-20
downgradient
monitoring well
UST Incident 14632
MW-2
10-20
downgradient
monitoring well
MW-3
10-20
downgradient
monitoring well
MW-4
10-20
downgradient
monitoring well
MW-5
10-20
downgradient
monitoring well
MW-6
5-20
clowngradient
monitoring well
MW-7
5-20
downgradient
monitc, ing well

Summary Table of Wells Within a Quarter -Mile Radius
Former Burlington Industries
300 Meadowview Road, Greensboro, Guilford County, NC
Former Burlington
Industries
MW-1S
39.44
on site/side radient
monitoring well
NONCD0000027
MW-2s
15-25
on site/side radient
abandoned
MW-3s
15-25
on site/side radient
abandoned
MW-4s
15-25
on site/side radient
abandoned
MW-5s
15-25
on site/side radient
abandoned
MW-6s
15-25?
on site/side radient
abandoned
MW-7i
42-52
on site/side radient
abandoned
MW-7S
21.18
on site/side radient
monitoring well
MW-7D
91.71
on site/side radient
monitoring well
MW-7e
60-70
on site/side radient
abandoned
MW-8s
16-26
on site/down radient
abandoned
MW-8i
70-80
on site/down radient
abandoned
MW-9S
19.02
on site/down radient
monitoring well
MVV-91
83.10
on site/side radient
monitoring well
MW-105
16.60
on site/side radient
monitoring well
MW-11s
17-27
on site/down radient
abandoned
MW-12s
16-26
on site/down radient
abandoned
MW-12i
42-52
on site/down radient
abandoned
MW-13S
31.08
on site/down radient
monitoring well
MW-131
79.93
on site/down radient
monitoring well
MW-13D
170.00
on site/down radient
monitoring well
MW-14s
unknown
on site/down radient
destroyed
MW-15i
unknown
on site/down radient
destroyed
MW-16S
33.20
on site/down radient
monitoring well
MW-161
128.69
on site/down radient
monitoring well
MW-171
58.92
on site/side gradient
monitoring well
MW-181
79.65
on site/down radient
monitoring well
MW-191
81.08
n site/side & down gradie
monitoring well
MW-20S'
35.61
on site/upgradient
monitoring well
MW-201'
65.71
on site/upgradient
monitoring well
MW-20D
100.21
on site/upgradient
monitoring well
MW-211
55.89
on site/down radient
monitoring well
E'vvR-2
132+-
on site/central
extraxtion well
EW-1R
unknown
unknown
abandoned
EW-2
13-83
on site/central
abandoned
1 = Same as the Precision Fabrics Wells MW-20s, MW-20i and MW-20d.

ATTACHMENT G
MAPS

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"f '"""_ � .u•� °`%�' ' '�i - ' t "\ ,�h0 �� g •t t .�,4i. ��. jjt '��'...
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ems, � - a Ylt �, �_.�3 .ram . f `x'-3 T�(i?.f.� '.'. ;, '�ie`I � �; (s•N � /\ ! . I ,y � jl� �.
`tS a Y i . , • i . S g L `-• i/ r � > ,�• ., v,.-,' 1 i
REFERENCE: -
USGS 7.5 MINUTE TOPOGRAPHIC MAP _
GREENSBORO, NC 1951 '
z'r � �., .``� ,• �, O 1 ,� j +,�t � (� if 4i s� (.. { � PHOTOREVISED 1991 s•
,. ;-.•Y': i .:" # .. -r`',: 8YN1 �,.,.> - /I.-'. (DRG digital neap hom N.C. Geological Survey, 1997)
Ak
1:24.000
SITE LOCATION MAP
FORMER BURLINGTON INDUSTRIES
GREENSBORO, GUILFORD COUNTY
NORTH CAROLINA
Im
aSolutions,L-J...TP
Industrial & Environmental Services
1101 Nowell Road, Raleigh, NC 27609
Phone [phone], Fax (919) 87Z1074
Created by: RPR
Checked by:TL
Fib: Figure 1.mxd
proieq:
Date: 1510.07A3.NCDW
FIGURE 1
Software: ESRI ArcMap 9.

DRAINAGE
.._- ..._......• .
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PRO,E
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ELEVATHN (FT.)
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MW-181 0 100 200
iZ 91.27 /
PEORAN WEST APPROXIMATE SCALE
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BASEMAP PROVIDED BY DUNCKLEE 6 DUNHAM,
P.C. ENVIRONMENTAL CONSULTANTS FORMER BURLINGTON INDUSTRIES PLANT INTERMEDIATE AQUIFER
%,Wufions.-ffis 300 MEADOWVIEW ROAD POTENTIOMET IL SURFACE MAP 2
1101 NOWELL ROAD GREENSBORO, NC APRIL 2007
RALEIGH. NORTH CAROLINA 27607
TEL., [phone] FAX.: [phone]

1-.-_.._..-.._.. _ .._..-..-
...... DRAPACE I
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o �
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a
CONCRETE
OUTSIDE TIRE Q
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ti
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jn
ASPHALT
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i
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830 � IW-A
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1101 NOWELL ROAD
RALEIGH• NORTH CAROLINA 27607
TEL.: [phone] FAX.: [phone]
TREEn
GRAVEL LIHf I/
MW-171
GRASS
MW-181
5.5
BASEMAP PROVIDED BY DUNCKLEE III DUNHAM,
P.C. ENVIRONMENTAL CONSULTANTS
' 0%
GRABS
'
O
� IW
'
"' MW-16S
MW-20D
• IW
O
MW-1611 '
MW-20I
2,000 1 -F
°MW306
1.000
PEGRAY WEST
FORMER BURLINGTON INDUSTRIES PLANT
300 MEADOWVIEW ROAD
GREENSBORO, NC
LEGEND
Q SIIALLOH KMTORING
WELL
]INTERMEDIATE
MONUCRING WELL
Q DEEP MWTIItING
HELL
PROPOSED IN.IECTMN
HELL
L000 TCE CONCENTRAIMN
Cm/u
L000 — TCE CONTOUR
CWTERIEDIATE AOUWM
CREEL(
0 100 200
APPROXIMATE SCALE
IN FEET
TRICHLOROETHENE ISOCONCENTRATION MAP
DEEP AND INTERMEDIATE AOUIFERS 3
APRIL 2007

DATE
AFTER
%FILE INJECT.DWG I 07/13/07 I PROJECT MANAGER MTL I CHECKEDR R I D TBM/MJZ/RPR I PROJECT N5I10.007A3.NCDW 1
55—GALLON
DRUM WITH
EOS
Concentrate
rj-,
3/B' RE11KE
Hog
SAMPLE/VENT LINE
SAMPLE/VENT LINE
•3—WAY SPUTTER
pDos-atron
BYPASS LINE
1-I/2' rtewmF Hog CENTRIFUGAL PUMP
WATER SOURCE
to r BRAIDED HOSE
to J* MtAM Hog
to r BRAM Hag
r wan mwry
BENTONITE SEAL
2—INCH WELL WITH
20—FOOT SCREEN
TOTAL DEPTH OF WELL
APPROXIMATELY 80 FT
IW—A IW—B IW—C
LEGEND
PRESSURE GAGE
FLOW METER/ACCUMULATOR
0
VALVE — GATE
Dd
VALVE — BALL
QUICK —CONNECT UNION
—}
WATER METER
CHECK VALVE
AV
AIR BLEED VALVE
NOTE:
INITIALLY INJECT EOS INTO WELLS
IW—A. IW—B AND IW—C. WHEN
INITIAL INJECTION IS COMPLETE. MOVE
PIPING AND INJECT INTO IW—D, IW—E AND IW—F.
PIPING AND COMPONENTS SUBJECT TO CHANGE SLIGHTLY
DUE TO WATER SOURCE AND naD CONDITIONS.
CONCEPTUAL DIAGRAM OF EOS INJECTION PROCESS FIGURE
Solutions
1-1111 Indusa-W & avimnmeniml Services
1101 NOWELL ROAD
RALEIGH, NORTH CAROLINA 27607
TEL: [phone] FAX.: [phone]

RECEIVED 1 DENR / DWQ
' JECTION EVENT RECGxw..D Aquifer ProtRrtion Section
North Carolina Department of Environment and Natural Resources - Division of Water fffWit14 20$
Permit Number see attached correspondence
1. Permit Information Lu r
Mr. Keith Snavely, NCDENR
Permittee
Former Burlington Industries
Facility Name
300 East Meadowview Road
Facility Address Greensboro, NC
2. Injection Contractor Information
Solutions-IES, Inc.
Injection Contractor / Company Name
Street Address 1101 Nowell Road
Raleigh North Carolina 27607
City State Zip Code
(919 ) 873-1060
Area code - Phone number
3. Well Information
Number of wells used for injection 6
Well names IW-A, IW-B, IW-C, IW-D
IW-E AND IW-F
Were any new wells installed during this injection
event?
❑ Yes ® No
If yes, please provide the following information:
Number of Monitoring Wells NA
Number of Injection Wells
NA
Type of Well Installed (Check applicable type): NA
❑ Bored ❑ Drilled ❑ Direct -Push
❑ Hand -Augured ❑ Other (specify)
Please include two copies of the G W-I b for each
well installed.
Were any wells abandoned during this injection
event?
❑ Yes ® No
If yes, please provide the following information:
Number of Monitoring Wells NA
Number of Injection Wells
NA
Please include two copies of the G W-30 for each
well abandoned.
4. Injectant Information
EOS AquaBupHTM
Injectant Type
Concentration 12 . 3 0
If the injectant is diluted please indicate the source
dilution fluid. potable water, city of
Greensboro.
Total Volume Injected 8,005 gallons
Volume Injected per well 63 to 2,734 gallonE
5. Injection History
Injection number (e.g. 3 of 5) 2 of 2
Is this the last injection at this site?
© Yes ❑ No
I DO HEREBY CERTIFY THAT ALL THE
INFORMATION ON THIS FORM IS CORRECT TO
THE BEST OF MY KNOWLEDGE AND THAT THE
INJECTION WAS PERFORMED WITHIN THE
STANDARDS LAID OUT IN THE PERMIT.
— � 4 _ — I I WC, e-
SIGNATURE OF INJECTION CONTRACTOR DATE
Brian Rebar
PRINT NAME OF PERSON PERFORMING THE INJECTION
Submit the original of this form to the Division of Water Quality within 30 days of injection. Form UIC-IER
Attn: UIC Program, 1636 Mail Service Center, Raleigh, NC 27699-1636, Phone No. 919-733-3221 Rev. 11/06

OF W ATF9 Michael F. Easley, Goecm,.t
RECEIVED 1 DENR 1 Dbvu
��� 6 Aquifer Protection Section William G. Ross Jr- Secret:%n
Cq North Carolina Department of Environment and Natural Resom,
NOV 14 2008
p Coleen H. Sullins Dire. t '�
Dis:Sion of Water Qu,1111N
September 13, 2007
Nlr. Keith Snavely
NCDENR DWM ISB
1646 Mail Service Center
Raleigh, NC 27699-1646
RE: Former Burlington Industries, 300 Meadoxvview Rd.
Greensboro, Guilford County, North Carolina
Dear Mr. Snavely:
The Groundwater Protection Unit of the Aquifer Protection Section of the Division of Water
Quality has reviewed the permit application for injection of EOS x,, received on August 20, 2007.
The proposed injection as presented in the work plan meets relevant state regulatory
requirements (1 5A NCAC 2C .0200) for construction and operation of an injection well system.
In general we would prefer to see sampling events prior to injection then semi-annually until the
bio-degradation reactions have completed.
Due to the site's coverage under the Comprehensive Environmental Response, Compensation,
and Liability Act (CERCLA), the states administrative permitting requirements have been
waived for this project under N.C.G.S. 130A-310.3 (e). A technical report summarizing the
project including all monitoring data should be submitted to the Groundwater Protection Unit
upon completion of the injection project.
If you have any questions regarding this letter please call me at [phone].
Since
Peter Po zo
Hydrogeol-oz-Tist�
cc: Robert Rogero. Solutions-IES
Toms Lieberman, Solutions-IES
Aquifer Protection Section — Winston-Salem Regional Office
CO-UIC files
Aquifer Protection Section 1636 Mail Service Center
Intemet %.HN%.ncN%aterqualit%.ora Location 272S Capital Boulccard
An Equal Opportunity/Affirmative Action Employer- 5C% Recyaed 10% Post Cor.sum<_r Paper
One
North Can d 1 1'
Jl aturvI111
Raleigh. NC 2769Q-16,6 Telephone: (919) 7'3-3221
Raleieh, NC 27604 F&K l: (919) 71d-0�81,
Fax 2: [phone]
Customer Scr%ice: [phone]

RECEIVED l DENR 1 DM
Aquifer Protection Section
e d Surf o
4 NOV 10 2008
t ' _
North Carolina Department of Health and Human Services
Division of Public Health — Epidemiology SectiM SEP 23 AN 10: 2-0Occupational and Environmental Epidemiology Branch
1912 Mail Service Center • Raleigh, North Carolina 27699-1912
Telephone:[phone] Fax: [phone]
NLichael F. Easley, Governor
Dempsev Benton, Secretary
September 22, 2008
MEMORANDUM
To: Qu Qi — UIC Program
Aquifer Protection System
Division of Water Quality
Department of Environment and Natural Resources
From: Sandy Mort V/
Epidemiology Section
Division of Public Health
Department of Health and Human Services
Leah Devlin, DDS, MPH
State Health Director
Subject: Health Risk Assessment
Use of EOS`) AquaBupHrm to Enhance Remediation of Groundwater
Contaminated with Chlorinated Solvents
This review is provided in response to a request for a health risk evaluation regarding the
use of the proprietary mixture EOS") AquaBupHrm. This product is to be used to enhance
remediation of groundwater contaminated with chlorinated solvents. AquaBupHrm is
identified as a "vegetable oil -based emulsion with alkaline buffer mixture". The
following information is provided regarding precautions during use:
AquaBupHrm is composed of food -grade ingredients. The major component (34-50%
of the undiluted mixture) is refined soybean oil which is generally recognized as safe
(E0S0AquaBupHrm MSDS). The pH buffering component is the second highest
percentage ingredient, 10-15% of the undiluted mixture. This chemical is generally
recognized as safe and is a common food additive. Recommendations for handling
the AquaBupHrm mixture are adequately protective for all components. The mixture
is diluted 1:4 for injection.
AikNorth Carolina Public Health
working For a healthier and safer North Carolina
Everywhere Everyday. Everybody.
Location: 5505 Sir Forks Rd., 2"d Floor, Room 1-2-D1 • Raleigh, NC 27609
An EqualOpporlt+nil v Employer
4AC

RECEIVED / DENR / DWQ
Aquifi+r protaMion $eGtiOta
2. Avoid generation of mists or vapors during use of the product. If there is potentiaNOV Y 0 2008
exposure to mists or vapors wear appropriate protective equipment as indicated below.
I Product is identified as a mechanical irritant to the skin, eyes, and respiratory tract. Avoid
contact with skin. Avoid inhalation of mist or vapors. Protective clothing is
recommended during handling, including PVC coated gloves, NIOSH approved goggles,
safety glasses with side shields, or face shield. It is recommended that contact lenses not
be worn when working with this material. A NIOSH approved organic vapor/mist
respirator is recommended to prevent inhalation of vapors or mists of product. Inhalation
may aggravate any pre-existing respiratory disease; prolonged/frequent skin contact may
lead to dermatitis (inflammation of the skin, symptoms include redness, itching, and in
some cases blistering).
4. Workers exposed to product should practice good personal hygiene, washing exposed
areas immediately, or at least several times daily, with mild soap and water. Do not re -use
contaminated clothing before washing. In case of eye contact immediately flush with
water for 15 minutes and seek medical advice. Signs of exposure include:
Eye contact: redness, tearing, conjunctivitis
Skin contact: drying, chapping, dermatitis
5. Swallowing large amounts may lead to purging of the bowels or bowel obstruction, CNS
depression and respiratory paralysis which can be fatal. Immediately contact a physician
if ingestion is expected.
6. Some components of the mixture are identified to be incompatible with strong oxidizers
or strong acids in their concentrated form. As a precaution, keep the product away from
oxidizing agents, excessive heat, and ignition sources.
7. Store and use in well ventilated areas. Do not store or use near heat, spark, or flame.
8. To minimize exposure, access to the area of mixing and application should be limited to
those required to work with the product.
9. All persons involved in the handling and use of the product should be familiar with the
information in this document and that on the EOS`'AquaBupHrm MSDS.
10. Eating, drinking, smoking, handling contact lenses, and applying cosmetics should never
be permitted in the application area during or immediately following application. After
handling, wash hands and face thoroughly with soap and water before eating, drinking or
smoking.
0
11. Measures should be taken to prevent contamination of this product to nearby wells l =
surface water bodies. rn r
N
U Page 2 of 3 E5
J Location: 5505 Six Forks Rd., `1Floor, Room 1-2-D1 . Raleigh, N.C. 27609 N
An Equal Opportunity Employer � c

RED;-
Aquifo-r p tE ❑�C? nfR , ;nn 5ertipn
NOV U 2008
References: I GTE:C'i IC ,
TOMES. Thomson Micromedex. Thomson Healthcare, GreenwW(Y-01 , WIT 26
ham://csi.micromedex.com/
EOS"�AquaBupffrm MSDS. EOS Remediation LLC, Raleigh, NC. August 13, 2008.
Page 3 of 3
Location: 5505 Sir Forks Rd., 7"a Floor, Room 1-7-DI *Raleigh, ,V.C. 27609 - "A
An Equal Opportunity Employer

[Fwd: RE: [Fwd: Re: 300 Meadowview Road Injection of EOS]]
Subject: [Fwd: RE: [Fwd: Re: 300 Meadowview Road Injection of EOS]]
From: Keith Snavely <Keith. Snavely@ncmai 1. net>
Date: Thu, 13 Sep 2007 11:53:12 -0400
To: Peter Pozzo <Peter. Pozzo@ncmai 1. net>, Tony Lieberman <[e-mail]>, Robert Rogero
<RRogero@solutions-ies. com>
Peter,
You had three questions for us about our application to install 5I wells at the former Burlington Industries
property ("Site") at 300 Meadoview Road. The questions were: (1) Please provide the number of sampling events
following EOS injection, (2) List the amount of injectant used, and (3) Assign upgradient, downgradient and side
gradient monitoring wells you plan to use as part of the EOS monitoring.
Hopefully the following three replies will address your concerns. (1) Specific to the number of monitoring events
scheduled following the EOS injection, we plan to possibly have two complete sampling events for volatiles, but
that number is limited due to the limited funds we have for the project Once the Inactive Hazardous Sites Branch
('Branch") of the Superfund Section spends the Burlington Industry bankrupcty proceeds of $167,000 set aside
for the cleanup of this Site, our remedial efforts will cease.
(2) Reviewing the EOS remediation design tool shown in the attachment, the amount of injectant is limited to13
(55 gallon drums with 52 gallons of product) of EOS for each injection well, for a total of 26 drums or 1,352
gallons of EOS. I believe Solutions IES included their plan, to chase this EOS with a total of 88,000 gallons of
water. Currently the city of Greensboro is allowing us to use potable water, but if they change their minds due to
the drought, we plan to use water from an existing monitoring well and filter it through carbon filters prior to
using it to chase the EOS.
(3) As you suggested, we have included the following monitoring wells as part of our monitoring schedule:
MW-21 i and MW-20i for our upgradient wells, MW 17i for our side gradient well, and MW-9i as our
downgradient well.
Let me know if you have any further questions.
Thanks for your quick turnaround concerning the review process.
Keith
------- Original Message--------
Subject:RE: [Fwd: Re: 300 Meadowview Road Injection of EOS]
Date:Fri, 7 Sep 2007 16:15:50 -0400
From:Tony Lieberman <TL iebermanR solutions -ies.com>
To:Keith Snavely <Keith.Snavely(i�,ncmail.net>
CC:Robert Rogero <RRogero(c�,solutions-ies.coni>, <[e-mail]>
References: <46E07976.7090108(&,,ncmail.net>
Keith:
Thanks for following through on these issues. You might want to send the
attached EOS Remediation design tool along to Peter. We determined the
amount of EOS substrate (injectate) by entering the limited site
information that we had into the tool. This is available from EOS
1 of 3 9/13/2007 2:47 PM

[Fwd: RE: [Fwd: Re: 300 Meadowview Road Injection of EOS]]
Remediation at no charge and is used by consultants nationwide to
estimate the volume of substrate for their sites.
Tony
-----Original Message -----
From: Keith Snavely[mailto:[e-mail]
Sent: Thursday, September 06, 2007 6:05 PM
To: Tony Lieberman
Subject: [Fwd: Re: 300 Meadowview Road Injection of EOS]
Tony,
Here's Peter's response. I just got to my emails late today. I will
reply to him about why our sampling events are limited -namely no more
funding available. I did not explain that to him so I could see his
comments. I will also look over the wells that exist for possible
monitoring , but based on the groundwater flow map- I would think they
are sufficient. We are only going after the hot spots anyway. I will
review them tomorrow and give you a call so I can send something back to
Peter late tomorrow.
Keith
-------- Original Message --------
Subject: Re: 300 Meadowview Road Injection of EOS
Date: Thu, 06 Sep 2007 16:01:13 -0400
From: Peter Pozzo <[e-mail]>
To: Keith Snavely <[e-mail]>
CC: Qu Qi <[e-mail]>
References: <[e-mail]>
<[e-mail]>
<[e-mail]>
Keith,
How was the amount of injectant derived?
The monitoring plan is inadequate. As I read it, there is only one
sampling event 3-6 months after the injection. Technical documents from
EOS Remediation suggest sampling 6-12 months or more from the date of
injection for chlorinated ethenes. This time period will allow time for
the reactions to start and there to be enough breakdown products to be
quantified during the analytical sampling. Additionally, EOS can last
3-5 years in the subsurface so, a sampling schedule should have a
sampling event before injection then semi-annually there after. The
parameters suggested are OK. There a re a few more that we would
generally like to see but the ones proposed are sufficient.
We generally want to see monitoring wells samples up gradient, down
gradient, and either side cross gradient. Are there wells in the
monitoring well network that could accommodate this?
We will be out of the office tomorrow for our annual APS Central Office
staff meeting. I will be back in the office on Monday.
Peter F. Pozzo
Aquifer Protection Section
1636 Mail Service Center
Raleigh, NC 27699
Voice: [phone]
FAX: [phone]
Keith Snavely wrote:
> Sounds good. Thanks for the update. I am supposed to be in the field
> tomorrow, so I will get back any comments that you may have on Friday.
2 of 3 9/13/2007 2:47 PM

[Fwd: RE: [Fwd: Re: 300 Meadowview Road Injection of EOS]J
> Keith
> Peter Pozzo wrote:
» Keith,
>> I am 3/4 of the way through the packet. I should have it finished
>> before I head home today. I will send you any questions tomorrow
>> morning if I have any.
>> Peter F. Pozzo
>> Aquifer Protection Section
>> 1636 Mail Service Center
>> Raleigh, NC 27699
>> Voice: [phone]
>> FAX: [phone]
>> Keith Snavely wrote:
>>> Peter & Qu Qi,
>>> Just checking to see if you have had a chance to review the
>>> information/application for the 5I well (s) being installed at the
>>> former Burlington Industries Site located at 300 Meadowview Road (
>>> Currently Snider Tire), and if you concur that the injection permit
>>> can be waived. The Inactive Hazardous Sites Branch of NC Superfund
>>> and their contractors Solutions-IES have scheduled to begin
>>> installation of the wells on Monday September 17.
>>> Can you give me an update on the status of this permit waiver
>>> request?
>>> Thanks,
>>> Keith Snavely, Hydrogeologist
>>> Inactive Hazardous Sites Branch
>>> NC Superfund Section
EOS design_tools_ver 2.1.z1s Content -Type: application/vnd.ms-excel
Content -Encoding: base64
3 of 3 9/13/2007 2:47 PM

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North Carolina Department of Environment and Natural Resources
Dexter R. Matthews, Director Division of Waste Management Michael F. Easley, Governor
nrilliam G. Ross Jr., Secretary
August 17, 2007
Mr. Peter Pozzo
UIC Program
NC Division of Water Quality
1636 Mail Service Center
Raleigh, NC 27699-1636
RE: 300 Meadowview Road -Waiver Letter for UIC Permit
Greensboro, Guilford County
Dear Mr. Pozzo:
Solutions-IES is under contract with the Inactive Hazardous Sites Branch (Brancli) of the NC
Division of Waste Management to conduct assessments and removal actions at orphan sites across the
state. One of these sites is the property at 300 Meadowview Road that was formerly owned by
Burlington Industries. During, Burlington's ownership, textile processing waste was buried in soils and
still bottoms from their textile processing. This material was removed along with contaminated soils in
the early 1990s. A groundwater plume of chlorinated solvents still remains on the property. Solutions-
IES has proposed to inject EOS(Rinto injection points that will each be advanced to a depth of 80 feet
below groundsurface. Since we are conducting a remedy involving an injectant into groundwater, an
application for a UIC permit for this injection is usually required.
However, in accordance with our Inactive Hazardous Sites Branch statute N.C.G.S. 130A-310.3
( e ), the Division may grant a waiver from any state law or rule that requires that an environmental
permit be obtained from the Department. We are planning to get started when we can schedule the
drillers. In order to meet the substantive requirements of the Underground Injection Control program,
we have enclosed a completed application for a type 5I well for your files.
If you have any questions, I can be reached at [phone].
Enclosure
Sincerely,
Keith Snavely, H drogeologist
Inactive Hazardous Sites Branch
Superfund Section
1646 Mail Service Center, Raleigh, North Carolina 27699-1646
Phone [phone] FAX [phone] Internet httpJ/wastenotnc.org
An Equal Olpporturlty 1 AffErmat ire Action Employer— Printed on Dual Purpose Recycled Paper