Loading...
HomeMy WebLinkAboutWI0400131_APPLICATION FOR PERMIT_20100413State 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 51 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 Numher (to be completed by DWQ): i. GENERAL INFORMATION: A Cleaner World Management Corp. 1. Applicant's Name (generally the responsible party): (Petitioner for DSCA Site 41- 0 Q 2 4 ) 2. Signing Official's Name: Genna K. Olson, P.G. Title: Senior Project Manager 3. Mailing address of applicant: DSCA Program, Mail Service Center 1646 City; Raleigh State: NC Zip: 27699-1646 Telephone number: 919) 508-8400 Fax number: (919) 715-3605 4. Property Owner's Name (if different from Applicant): Mi J Kim 5. Property Owner's mailing address: 4506 High Point Road City: Greensboro State: NC Zip: 27407 6- Name and address of contact person who can answer questions about the proposed injection project: Name; Meghan E. Greiner, P.E. Title: Project Manager Company: ATC Associates of North Carolina, PC Address: 2725 East Millbrook Road, Suite 121 City: Raleigh State: NC Zip: 27604 Telephone number: (919) 871-0999 Fax number: (919) 871-0335 Email Address: meghan.grainer@atcassociates.com II. PERMIT INFORMATION: 1. Project is: ® New ❑ Modification of existing permit ❑ Renewal of existing permit without modification C Renewal of existing permit with modification 2. 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). For all renewals, you must submit a status report including monitoring results of all injection activities to date. Revised 8/07 UIC-5I/5T RECEIVED / DEN / DVVQ Page I of 7 Aqujff r F?rnlQr;ttnn SpcliCl:1 APR 13 2010 APPLICATION FOR PERMIT TO CONSTRUCT AND/OR USE A WFLL(S) FOR INJECTION Type 51 Wells -- In Situ Groundwater Remediation / Type 5T Wells — Tracer Injection Ill. INCIDENT & FACILITY DATA A. FACILITY INFORMATION 1. Facility name: Former A Cleaner World #162/ Current $1.50 Cleaner 2. Complete physical address of the facility: 4506 High Point Road City: Greensboro County: Guilford B. INCIDENT DESCRIPTION 1. Describe the source of the contamination: State: NC Zip: 27407 The property at 4506 High Point Road in Greensboro, North Carolina was first utilized for dry cleaning operations in 1959. The previous building was occupied by Fordham's Inc. (dry cleaning business) from 1959 to 1979, Peerless Cleaners from 1979 to 1982, and A Cleaner World from 1982 to 1991. In 1991 the former building was demolished during the widening of High Point Road and the existing building was constructed. A Cleaner World then continued drycleaning operations in the existing building. A Cleaner World ceased drycleaning operations in 2004 and the machinery was removed in 2005. However, the facility continued to operate as a drop-off station. A suspected release was reported based on a soil sample collected near the drycleaning machine by Shield Environmental in September 2005. In March 2008, drycleaning operations resumed at the site under new name and management ($1.50 Cleaner). 2. List all contaminants present in soils or groundwater at the site {contaminants maybe listed in groups, e.g.. gasoline, diesel, jet fuel, fueI oil, chlorinated ethenes, chlorinated ethenes, metals, pesticides/herb icides. etc): Chlorinated ethenes (primarily PCE and PCE breakdown products). 3. Has LNAPL or DNAPL ever been observed at the site (even if outside the injection zone)? 1-.i Yes If yes, list maximum measured separate phase thickness feet 9 No If no, list maximum concentration of total VOCs observed at site: 1,500 (MW-3) ppb 4. Agency managing the contamination incident: C [1ST Section X. Superfund Section (including REC Program and ❑SCA sites) 0 DWQ Aquifer Protection Section E Solid Waste Section ❑ Hazardous Waste Section U Other: 5. Incident managers name Al Chapman and phone number (919) 508-8580 6. Incident number or other site number assigned by the agency managing the contamination incident: DSCA #41-0024 C. PERMITS List al permits or construction approvals that have been issued for the facility or incident, including those not directly related to the proposed injection operation: Farmer SQG Permit #NCD035996024 I. Hazardous Waste Management program permits under RCRA:Current SQG Permit #NC0991302999 ?. DWQ Non -Discharge or NPDES permits: None identified. 3. County or DEH subsurface wastewater disposal permits: None identified. 4. Other environmental permits required by state or federal law: Guilford County Permit # 037-06-MW26-RWO and DWQ Permits # WM0400450, WM0400451, WM0400452, WM0400453, and WM040G454 for well construction. Revised 8107 UIC-51/5T Page 2 of 7 APPLICATION FOR PERMIT TO CONSTRUCT AND/OR USE A WELL(S) FOR INJECTION Type 5I Wells — In Situ Groundwater Remediation I Type 5T Wells -- Tracer Injection 1V. 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 {GEES} of the Division of Public Health, Department of Health and Human Services. Review the list �'anoroved injectantsT or contact the UIC Program to determine if the injectants you are proposing have been reviewed by GEES. tniPrtant• EHC Concentration at point of injection: 2.7 pounds/gallon lnjectant: Concentration at point of lnjectant: Concentration at point of injection: I nj ectant: Concentration at point of injection: Injectant: Concentration at point of 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 '''A mile of injection site ❑ Air ❑ Other: 3. If any well within'/. mile of injection site, a private well, or surface water is to be used as the fluid source, supply the following information: a. LocationlID number of source: NIA b. Depth of source: NIA c. Formation: N/A d. Rock/Sediment type: NIA e. In Attachment C, provide a current, complete chemical analysis of the water from the source well, including analyses for ail 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 yalicution farm G WRS Revised 8107 U1C-5I15T Page 3 of 7 APPLICATION FOR PERMIT TO CONSTRUCT AND/OR USE A WELL(S) FOR INJECTION Type 51 Wells -- In Situ Groundwater Remedistion / 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: B days Expected duration between events (if more than one event): NIA 2. injection rate per well: 3 to 7 gallons per minute (gpm) 3. Total Injection volume: 942 gallons per day (gpd); 5.553 gallons per event (if separate events) 4. Injection pressure:10 to 300 pounds/square inch (psi) 5. Temperature at point of injection: ambient temp. T 6. Briefly describe how the above oarameters will be measured and controlled: The injection pressure will monitored using a pressure gauge. Valves and the injection pump will be used to control flow and pressure. The temperature of the water supply will determine the temperature of the injection fluids. 7. Estimated hydraulic capacity of the %veil: 3-7 gpm C. INJECTION WELL CONSTRUCTION DATA I. Injection will be via: C] Existing well(s) proposed for use as an injection well. Provide the data in (2) through (6) below to the best of your knowledge- X Proposed well(s) to be constructed for use as an injection well. Provide the data in (2) through (5) below as proposed construction specifications. Total of 24 new direct push injection points to be installed 2. Well Drilling Contractor's Name: Vironex + NC Well Contractor Certification number: 3027-A c-J�L{ `1 WL Lt 3. Date to be constructed: TSB Approximate depth of each boring (feet): 38 Number of borings: 20 4. Screened interval/Injection interval of injection wells: Depth: 14 to 38 feet below ground surface (if multiple intervals, indicate shallowest and deepest depth). 5. Well casing (NIA if injection is through direct push rods): Type: ❑ PVC ❑ Stainless steel ICJ Other: delivered via direct push rods Casing depth: to ft. G. Grout (NIA if injection is through direct push rods): Type: ❑ Cement ❑ Bentonite ® Other: Delivered via direct push rods Grout depth: to ft. Revised 8/07 UIC-51/5T Page 4 of 7 APPLICATION FOR PERMIT TO CONSTRUCT AND/OR USE A WELLS) FOR INJECTION Type 51 Wells — In Situ Groundwater Remediation 1 Type 5T Wells — Tracer Injection V. ATTACHMENTS Provide the following items as attachments with the given headings: A. SITE HISTORY Provide a brief description of the site history including: (1) site usage historically and present, (2) origin of the contamination, (3) previous remedial action(s). 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. 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. C. 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 ''A mile of the injection site is used as the source well, include chemical analysis of source fluid here. D. 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. E. 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. F. 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, O P, dissolved oxygen, and Revised 8107 UIC-5I15T Page 5 of 7 APPLICATION FOR PERMIT TO CONSTRUCT AND/OR USE A WELL(S) FOR INJECTION Type 51 Wells — In Situ Groundwater Remediation 1 Type 5T Wells — Tracer Injection other electron acceptors and donors. The monitoring schedule should be consistent with the pace of the anticipated reactions and rate of transport of the injecrants and contaminants. G. 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. H. MAPS 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'/, mile of the injection well or well system; e. a]I surface water bodies within'/4 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 Revised 8I07 UIC-5115T 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 l Genna K. Olsorlk,P,nG�flmn M's;_n p= nfflct.-O , hereby certify under penalty of law that I 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, for�0jbfft#MiH&40,,se information. 1 agree to construct, operate, maintain, repair, and if applicable, abandon�ll •�• N?1 ? v nd all related appurtenances in accordance with the approved speci�ations and crftklt��j•�it.'y_ Signature• ' Title: Agent f r DSCA Petitioner -0024 If awhorize"geni is acting on behalf of the applic above agent' See agreement in Appendix 1 . =� Dade: 4 1 g /-Z o t � ,.• o 1��ed by the applicant authorizing the VII. CONSENT OF PROPERTY OWNER (if the property is not owned by the applicant) ("01wner " 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.) 1, Mi J Kim Ipi-wr..t namc of M7"n oly l'n , as owner of the property on which the injection wells) 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: See Signed Access Agreement in Appendix 2 Date: Title: Revised 8/07 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 (919) 733-3221 RECEIVED I DENR / ]J Agtrift:r Prate lion Section UIC-5115T APR 13 2010 Page 7 of 7 A ll NCDENR North Carolina Department of Environment and Natural Resources OexteF R. Matthews. Director Division of Waste Management Michael F. Easley, Governor William G. Ross Jr, Secretary November 1, 2005 AC W Management Corp Attn: Chris Edwards, President 2334 English Road High Point, NC 27262 Re: Executed Assessment & Remediation Agreement DSCA Site 1D 41-0024 A Cleaner World # 162 4506 High Point Road, Greensboro Guilford County, North Carolina Dear Mr. Edwards: Enclosed is a copy of the executed Assessment & Remediation Agreement (ARA) for the Dry Cleaning Solvent Act (DSCA) site referenced above. Also enclosed is a copy of your DSCA Petition for Certification as well as the site's Certification Letter. We will keep you informed of any planned site work. If you have any questions, please contact me at 919-508-8452. Sincerely, Niki Fountain DSCA Project Manager Attachments; DSCA Petition for Certification Certification Letter Executed Assessment and Remediation Agreement cc: DSCA Site No. 41-0024 Fite 401 Oberlin Road, Ste, 150, Raleigh, North Carolina 27605-1350 Phone: (919) 508-8400 1 FAX: (919) 733-4811 1 Internet: www.ncdsca.org AN EQUAL OPPORTUNITY 1 AFFIRMATIVE ACTION EMPLOYER - 50% RECYCLED 1 10% HOST CONSUMER PAPER NCDENR North Carolina Department of Environment and Natural Resources Dexter R. Matthews, Director Division of Waste Management Michael F. Easley, Govemor William G. Ross Jr., Secretary Letter of Certification into the Dryeleaning Solvent Cleanup Act Program On November 1, 2005 pursuant to N.C.G.S. § 143-215.104G, the Dry -Cleaning Solvent Cleanup Act (DSCA) Program has certified the site named A Cleaner World #162 located at 4506 High Point Road in Greensboro, Guilford County into the DSCA Program. The site has been assigned the DSCA identification number 41-0024. Evidence of dry-cleaning solvent contamination has been documented arising from dry -Gleaning operations originating from the site. Based on information submitted to the Division at the time of certification, the site is determined to be a large dry-cleaning site within the meaning of N.C.G.S. § 143-215.104B(b)(1) for the purposes of determining a site's financial responsibilities as required by N.C.G.S § 143-215.104F(f). The site will remain certified in the DSCA Program as long as there is at least one eligible: petitioner who is complying with an agreement between the DSCA Program and that petitioner. Signed, John Powers Special Remediation Branch Supervisor 1646 Mail Service Center. Raleigh. North Carolina 27699-1646 Phone 919-50&84001 FAX 919-715-36051 Internet http:!lwastenotnc.org An Equal Opportunity I Affirmalive Action Employer - Primed on 0uaI Purpose Recycled Paper r I A Cleaner World #162 Injection Permit Application ATC Project No. 45.34341.4124 April 9, 2010 A. SM HISTORY (1) Site Usage Historically and Present The property at 4506 High Point Road in Greensboro, North Carolina was first utilized for dry cleaning operations in 1959. The previous building was occupied by Fordham's Inc. (dry cleaning business) from 1959 to 1979, Peerless Cleaners from 1979 to 1982, and A Cleaner World from 1982 to 1991. In 1991 the former building was demolished during the widening of High Point Road and the existing building was constructed. A Cleaner World continued operations in the existing building. A Cleaner World ceased drycleaning operations in 2004 and the machinery was removed in 2005. However, the facility continued to operate as a drop-off station. A suspected release was reported by Shield Environmental in October 2005. In March 2008, drycleaning operations resumed at the site under new management. The current property owner and drycleaning business operator is Mi J. Kim. The name of the current drycleaning operation is $1.50 Cleaner. (2) Origin of the Contamination A Phase I Environmental Site Assessment (ESA) was prepared for Sarah Chi, a prospective purchaser of the property, on August 26, 2004, by Pyramid Environmental and Engineering P.C. Based on this report, the 3,948 square foot commercial building that is presently on the site was built in 1991 by ACW Management Corp. and had been occupied by A Cleaner World since construction. A former building was located on -site, but was demolished when High Point Road was widened in 1991. The farmer on -site building was operated as a dry cleaning business since 1959. The earliest property listing in the city directory was 1958 when the property was listed as Free Howard Trucking. Historical aerial photographs showed that the former commercial building was constructed prior to 1937. The 2004 Phase I ESA identified three recognized environmental conditions (RECs) for the site. The first REC was the on -site dry cleaning operations. The second REC was a 1,000-gallon heating oil underground storage tank (UST) utilized on -site from at least 1982 through 1991. The UST was removed during site redevelopment activities in 1991, but no closure samples were collected to evaluate whether a petroleum release may have occurred. Note that later sampling by ATC showed no significant petroleum contamination attributable to the former heating oil UST. A Cleaner World #I62 Injection Permit Application ATC Project No. 45,34341 A124 April 9, 2010 The third REC was a reported release incident on the adjacent property to the south (currently High Point Road Self -Storage). This property was formerly occupied by Pfizer, Inc, and was listed on the federal Comprehensive Environmental Response Compensation and Liability Information System (CERCLIS) list and the State Inactive Hazardous Sites (IHS) list. Later sampling and a file review by ATC also showed that this property is not significantly contributing to the drycleaning solvent plume originating at the subject site. As part of the entry requirements for the ❑SCA program, Shield Engineering Inc. collected a soil sample (SS-1) from inside the building on September 29, 2005. The depth at which the sample was collected is unknown. The analytical results from the soil sample indicated detectable vinyl chloride, cis- l,2-diebloroethene, trichloroethene (TCE), tetrachloroethene (PCE), total xylenes, n- propylbenzene, 1,3,5 trimethylbenzene. and 1,2,4-trimethyibenzene. The drycleaning business owner and property owner at the time, ACW Management Corporation, subsequently submitted a petitioner questionnaire for certification of the site into the ❑SCA Program. The site was subsequently certified on November 1, 2005, and an Assessment and Remediation Agreement was executed. Between August 2006 and August 2008, ATC Associates of North Carolina, P.C. (ATC), under contract to the DSCA Program, completed assessment activities to delineate the extent of contamination associated with the release. A total of 55 soil borings have been advanced and 30 monitoring wells have been installed. The results of the assessment indicated that chlorinated solvent constituents are the primary contaminant of concern for the site. A plume of PCE extends over 1,000 feet downgradient southeast. Maximum PCE concentrations in the source area are on the order of 1.5 mg/L. Vertically, the plume has impacted both the overburden and the bedrock aquifers. The downgradient edge of the plume intercepts a downgradient stream. Sampling of the stream has indicated constituents of concern above NC 2B Surface Water Standards. Na water supply wells have been identified in the site vicinity that could be impacted by the release. Note that additional monitoring well installations are planned to fully delineate the extent of contamination. Refer to the tables and figures contained in this permit application for additional details regarding the assessment data collected to date. The results of ATC's assessment were documented in a Prioritization Assessment Report dated October 21, 2006, two Assessment Reports dated March 6, 2008, and September 19, 2008, and a Groundwater Monitoring Report dated March 3, 2009. A Cleaner World 4162 Injection Permit Application ATC Project No. 44.34341.4124 April 9. 2010 A Tier i and 2 Risk Assessment was completed in February 2009 to evaluate the risk posed by the contamination and goals for remediation. The protocol for the risk assessment was in accordance with the DSCA Program's risk -based rules. Based on the results of the risk assessment and subsequent discussions with the ❑SCA Program, a level of 0.134 mglL for PCE in groundwater (Source Groundwater Protective of Surface Water) was selected as the goal for groundwater remediation. This permit application covers the completion of a pilot test to evaluate whether EHC® is successful at reducing contaminant concentrations. If this technology is successful, ATC will request approval for full-scale injection to achieve the remedial goal. Note that soil excavation is also currently planned to address soil impacted above risk -based remedial goals. (3) Previous Remedial Action(s) To date, no remedial action has occurred at the site. B. HYDROGEOLOGIC DESCRIPTION (1) The Regional or Geologic Setting 25 According to the North Carolina Geologic Map (1985), the site is located within the Carolina Slate Belt of the Piedmont Physiographic Province. The bedrock underlying the site is "Metamorphosed Granitic Rocle' (CZg) that is megacrystic, well foliated, and locally contains hornblende. (2) Significant Changes in Lithology Based on soils encountered during drilling activities, site soils consist primarily of an interbedded mixture of sand, silt, and clay, generally coarsening with depth to partially weathered rock (saprolite) and bedrock. The soils at this site are Enon Urban -land complex — a product of weathering of the underlying rock, and urban development. The transition from competent bedrock to weathered rock to residual sail is gradual. Competent metamorphosed granite bedrock was encountered during drilling activities at the site at depths ranging from 12 to 73 feet below ground surface (bgs). A Cleaner World #162 Injection Permit Application ATC Project No, 45,34341,4124 April 9, 201❑ (3) Hydrogeologic Parameters Based on recent and historical groundwater elevation data, the direction of groundwater flow across the site is divided. The primary direction of plume migration coincides with groundwater flow to the east-southeast at a hydraulic gradient of 0.02, based on the groundwater elevations for monitoring wells MW-1 and MW-16S in December 2008. A secondary direction of plume migration coincides with groundwater flow to the west-northwest at a hydraulic gradient of0.018, based on the groundwater elevations for monitoring wells MW-1 and MW-9 in December 2008. Two streams are located downgradient of the site to the east-southeast and west-northwest in the two directions of groundwater flow. Shelby tube samples were collected from the subject site for analysis of physical soil parameters. Based on Shelby tube data for the 15 to 17-foot interval below the water table, the total porosity is estimated at 35.1 percent and the effective porosity, generally equivalent to specific vield, is estimated at 18.8 percent. Slug tests were also conducted at the site in August 2008. Evaluation of the slug test data using the Bower -Rice and Hvorslev methods indicated a range in hydraulic conductivity values of 0.269 to 0.781 fdday for the unconsolidated zone and 0.43 to 3.14 ft/day for the bedrock zone. Based on the geometric mean of hydraulic conductivity values for the unconsolidated zone (0.453 ft/day), a hydraulic gradient of 0.02, and an effective porosity of 18.8 percent, the average groundwater flow velocity in the unconsolidated zone is estimated at 0.05 ft/day (17.6 fflyr). Based on the geometric mean of hydraulic conductivity values for the unconsolidated zone (0.453 ft/day) and an estimated aquifer thickness of 24 feet (approximate depth to bedrock minus depth to water in the source area), the average transmissivity of the aquifer is estimated at 16.3 fi /day. (4) Depth to Mean Seasonal High Water Table Based on recent and historical depth to groundwater measurements. tile depth to groundwater across the site varies from 2.16 to 19.74 feet bgs across the contaminant plume. In the area of the proposed remediation activities (source area), the depth to groundwater ranges from approximately 14 to 16 feet bgs. 5' A Cleaner World 4162 Injection Permit Application ATC Project No. 45.34341A124 April 9, 2010 C. INJECTION FLUJD COMPOSITION The proposed injectant is a product developed by Adventus Group called EHCR. EHC® is a patented combination of controlled release carbon and zero valent iron (ZVI) particles used for stimulating the in -situ chemical reaction of organic compounds in groundwater. EHC® is a nutrient rich product that stimulates bacterial growth in groundwater, which in turn reduces the redox potential in the subsurface environment. The bacteria ferment carbon and release voiltle fatty acids which serve as electron donors for other bacteria. The ZVI stimulates dechlorination and additionally reduces the redox potential in the subsurface. A Material Safety Data Sheet for EHCS is included in Appendix 3. D. INJECTION RATIONALE (1) Remedial Goals Based on the results of a Tier 2 risk assessment, the cleanup goal for groundwater remediation is 0.134 mg/L for PCE. The horizontal extent of groundwater impacted above this remedial goal extends from the source area approximately 750 feet to the southeast. The vertical extent of groundwater impacted above the remedial goal encompasses both the unconsolidated and bedrock aquifer zones. This permit application covers completion of a pilot test to evaluate the effectiveness of EHCID for groundwater remediation. For the pilot scope, one permeable reactive barrier (PRB) will be installed downgradient of the source area. The vertical extent of impact to be addressed with the pilot injection extends from approximately 14 to 38 feet bgs. Based on the success of the initial injection, ATC may request approval for full-scale injection to achieve the remedial goals. (2) Contaminant 1 Injectant Reactions As discussed in Section C, the proposed injectant is a product called EHC9 developed by Adventus Group. EHC` is a source of both organic carbon and ZVI. The organic component of EHC® is a fibrous organic material that is nutrient -rich, hydrophilic, and has high surface area. The EHC® stimulates the biological community releasing a variety of volatile fatty acids (for example acetic, propionic, butyric). The ZVI component stimulates direct chemical A Cleaner World 9162 Injection Perneit Application ATC Project No. 45,34341.4124 April 9, 2010 dechlorination and an additional drop in the redox potential of the groundwater via chemical oxygen scavenging. These physical, chemical, and biological processes combine to create an extremely reduced environment that stimulates chemical and microbiological dechlorination of otherwise persistent compounds. Additional details regarding reactions between the EHC" and contaminants are included in Appendir 4. (3) Summary Results of Previous Modeling or Testing Available case studies and product literature are included in Appendix 4 of this permit application. INJECTION PROCEDURE AND EQUIPMENT (1) Construction Plans & Materials The injection site is approximately 2,000 square feet in area and is planned to be treated with a total of 20 direct -push injection points. The injection points will be aligned in a PRB array downgradient of the source area on -site. The injection depths will extend from the water table at approximately 14 feet bgs to direct push refusal, which is estimated at 38 ft bgs. However, note that the total injection depth may be slightly more or less depending on the encountered depth of direct -push refusal. A total volume of 5,653 gallons of injectate slurry is planned for the targeted area. The injectate slurry will be composed of 15,500 lbs of EHC", mixed with 4,653 gallons of water (775 lbs EHC'o and 233 gallons of water in each of 20 points). The target area and proposed injection points are shown in Figure 3. (2) Operation Procedures Injection will be accomplished using a direct -push drilling rig. The direct -push rig will be equipped with the tooling typically required for injection activities. A diagram of the injection system is included in Appendiv 5 and the injection process is described below. At the start of the injection, measured amounts of municipal water, EHO will be added to the onboard slurry mixing tank and the mixer/pump will be started. The injection rod will consist of a 1.5-inch outside diameter Geoprobe drill rod driven to the desired injection depth using a direct -push 7 A Cleaner World 9152 Injection Permit Application ATC Project No, 45.34341 A124 April 9, 2010 drilling rig. A high pressure hose will extend from the mixing tank, to the injection pump, then to a quick connect coupling on the injection rod, The injection rod assemblage is equipped with a shut- off valve at the surface, and an injection head at the injection depth. An expendable point is present which seals the injection head until the desired injection depth is reached. Once the injection depth is reached, the injection pump is engaged, the injection head valve is opened, and the expendable point is shed to facilitate injection. Injection will he performed using a bottom up approach. Injection pressures and flow rates are site specific and will be determined after the first few locations are completed. The injection pressure will be monitored continuously using a pressure gauge and the injection rate will be adjusted using the injection pump and valves. After injection at a desired depth is complete. the rod string will be pulled up into the next injection zone. If it is necessary to break a rod and back pressure exists, the pressure will be relieved into a bucket and dumped back in the pump hopper. Once injection at a Iocation is complete, the residual pressure in the formation will be monitored until a safe level is reached. The injection rod will then be withdrawn and the boring will be abandoned using hydrated bentonite. (3) Diagrams & Figures A diagram of the proposed injection system is provided in Appendix 5, (4) Planned Injection Schedule The injection is expected to take approximately six days total. We anticipate mobilizing to the site to begin field activities within four weeks of approval of necessary permits. F. MONITORING PLAN (I) Existing and Proposed Monitoring Wells Groundwater samples will be collected from monitoring wells MW-1, MW-2, MW-3, MW-IOS, MW-18S, and MW-18D to monitor the effectiveness of the injection activities. Groundwater samples will be analyzed for volatile Organics by EPA Method 8260. In addition, to monitor parameters related to reductive dechlorination and the injected fluids, groundwater samples will 11 A Cleaner World 4162 ATC Project No. 45.34341.4124 Injection Penn it Application April 4, 2010 be analyzed for nitrate, sulfate, methane, ethene, ethane, iron, calcium, magnesium, manganese, and total organic carbon (TOC). Field sampling will also be conducted for dissolved oxygen, oxidation/reduction potential, specific conductivity, pH, temperature, and total and dissolved iron. (3) Sampling Schedule Groundwater samples will be collected from the wells specified above prior to injection and one month, three months, six months, and one year following injection. G. WELL DATA Well construction details for the existing monitoring wells are included in Table 3. Historical receptor surveys conducted at the site did not identify water supply wells within 1,500 feet of the site. A Cleaner World # 162 ATC Project No. 45,34341.4124 Injection Pcnnit Application April 9. 2010 TABLES Note that the attached tables are presented in the forms required by the DSCA Program. The numbering of the tables is specified in the forms. A summary of the tables attached to this permit application is provided below: Analytical Data Tables (ADT) ADT l: Site Chronology ADT 3: Monitoring Well Construction Data ADT 4: Groundwater Elevation Data ADT S: Analytical Data for Groundwater ADT 6: Analytical Data for Surface Water ADT 9: Analytical Data for Natural Attenuation Parameters Note that ADT 2, 7, and 8 contain data that is either not relevant to this site or not relevant to this permit application. As such, these tables are not included in the attachments. Table 1: Site ChronologyE DSCA ID No.: 41-0024 Chronology of Events Date Instructions: Brief description of all significant events that have occurred since a problem was suspected at the facility. Commence with the first date a problem was suspected and continue through the most recent activity described in the current report. 1959 Drycleaning operations commence on -site. 2004 Drycleaning operations cease on -site. Facility becomes pickup and dropoff site only. 2005 Drycleaning machines were removed. 9/29/2005 Shield Engineering collected soil sample (SS-1) inside building. 8110-23/2006 ATC installed eight soil borings (SB-2 through SB-9) and three monitoring wells (MW-1 through MW-3). 10/27/2006 ATC submitted Prioritization Assessment Report. 719-13/2007 ATC conducted direct -push survey (SB-10 through SB-24). I012-512007 ATC installed nine monitoring wells (MW-4 through MW-12). 1/18/2008 ATC noted that the building was no longer occupied. 3/6/2008 ATC submitted Assessment Report. 3/1/2008 Dry-cleaning operations resumed at the site under nev, management. 619108 - 6/18/08 ATC installed monitoring wells MW-I BR, MW-213R, MW-13, MW-14SID, MW-15, MW-16SND, MW-17, and MW- 18SID. 6/20/08 - 6/24/08 ATC collected groundwater samples from all monitoring wells and collected five surface water samples (S-1, S-2, S-3, S- 4, and S-5). Page 1 of 2 Table 1- Site Chronology i DSCA ID No.: 41-0024 Chronology of Events Date Instructions: Brief description of all significant events that have occurred since a problem was suspected at the facility. Commence with the first date a problem was suspected and continue through the most recent activity described in the current report. 7/1/2008 ATC supervised professional surveying of monitoring wells MW-1, MW-1 BR, MW-2, MW-2BR, MW-3, MW-4, MW-6, MW-7, MW-8, MW-9, MW-10, 1MW-11, MW-12, MW-13, MW-14, MW-15, MW-16, MW-17, and MW-18. 8/7/2008 ATC performed slug testing on monitoring wells MW-1, MW-15, MW-1BR, and MW-2BR. 8/28/2008 ATC collected Shelby Tube samples from 5-6.75 feet belo.% land surface (bls) and 15-17 feet b1s. 9/19/2008 ATC submitted Assessment Report. 12/16/08 - 12/19/08 ATC collected groundwater samples from all monitoring wells and collected five surface water samples (S-1, S-2, S-3, S- 4, and S-5). 3/2/2009 ATC submitted Groundwater Monitoring Report. 1/11/2010 - 1/15/2010 ATC advanced 31 soil borings (S13-25 through S13-56) and installed eight soil gas monitoring points (SGMP-1 through SGMP-8). 21212010 - 21312010 ATC collected soil gas samples from SGMP-1, SGMP-3, SGMP-4, and SGMP-5. Page 2 of 2 Table 3: Monitoring Well Construction Data DSCA ID No.: 41-0024 Well I❑ Date Installed (mmlddlyy) Number «1 �ainhlcs Well Depth [feet] Well Diameter [inch] Screen Interval [feet] Status (Active/Inactive) MW-1 9/16/06 25 2 5-25 Active MW-1 BR 6/10/08 2 55 2 50-55 Active M W-2 9/16/06 11 22 2 12-22 Active MW-2BR 6113/09 2 70 2 65-70 Active M W-3 8/16/06 3 27 2 12-27 Active M W-4S 10/2107 3 20 1 10-20 Active MW-4D 1012107 3 64 1 59-64 Active M W-5S 1013107 1 20 1 10-20 Active M W-5D 1013107 1 37 1 32-37 Active M W-6S 1013/07 3 25 1 10-25 Active MW -6D 1013107 3 43 1 38-43 Active MW-7S 1014107 3 30 1 15-30 Active M W-7D 1014107 3 75 1 70-75 Active M W-8 1014107 4 25 2 5-25 Active MW-9 1014107 2 10 2 5-10 Active MW-10S 1014107 3 20 1 10-20 Active MW-l0D 1014107 3 35 1 30-35 Active MW-I 1 1015107 3 19 2 9-19 Active MW-12S 1015107 3 20 1 10-20 Active MW-12D 1015107 3 33 1 28-33 Active M W-13 6/11/08 2 24 2 9-24 Active MW-14S 6/11/08 0 20 1 10-20 Active MW-14D 6111108 2 49 2 44-49 Active M W-15 6/16/08 2 25 2 10-25 Active MW-16S 6/17/08 2 20 1 10-20 Active M W-161 6/17/08 2 50 1 45-50 Active MW-16D 6/17/08 2 65 1 60-65 Active M W-17 6/18/08 1 12 2 7-12 Active MW-18S 6/11/08 2 20 1 10-20 Active MW-18D 6/11/09 2 38 2 33-38 Active Page I of 1 Table 4: Gruund►ti•ater Elevation Data 1 DSCA ID No.: 41-0024 Groundwater Sampling Point Sampling Date (mmlddlyy) TOC Elevation [feet] Depth to Water [feet bgs] Groundwater Elevation feet Depth to NAPL Meet bgs] NAPL Thickness [feet] Corrected* Groundwater Elevation feet MW-1 1118I08 973.00 13.81 859.19 NIA NIA NIA 6/23/08 873.00 12.97 860.03 NIA NIA NIA 12/16/08 873.00 12.80 860.20 NIA NIA NIA %IW-1 RR 6/13/08 972,53 12.32 860.21 NIA NIA NIA 6/20108 872.53 12,49 $60.04 NIA NIA NIA 12/16/08 872.53 12,50 860.03 NIA NIA NIA %iNV-2 1119/08 873.14 13,90 859.24 NIA NIA NIA 6/23/08 873.13 13.08 860.05 NIA NIA NIA 12/16/08 873.13 12,85 860.28 NIA NIA NIA MW-2RR 6/23/08 864.45 13.48 850.97 NIA NIA NIA 12/17/08 864.45 12.90 851.55 NIA NIA NIA %I %N -1 1/18/08 874.59 15.63 858.96 NIA NIA NIA 6/23/08 874.58 14.73 959.85 NIA NIA NIA 12/18/09 874.58 14.61 859.97 NIA NIA NIA %i %\ -1 ti 1/18/08 875.24 15.97 859.27 NIA NIA NIA 6/19/08 875.24 15.00 860.25 NIA NIA NIA 12/16/08 975.24 15.13 860.11 NIA NIA NIA MW-4D 1/18/08 975.31 16.51 958.80 NIA NIA NIA 6/19/08 875.30 15.11 860.19 NIA NIA NIA 12/16/08 875.30 15.32 859.98 NIA NIA NIA MW-55 1/18/08 874.72 15.77 858.95 NIA NIA NIA MW-5D 1/18/08 874.66 15.93 858.73 NIA NIA NIA MW-6S 1/18/08 874.69 13.68 861.01 NIA NIA NIA 6/19/08 874.83 12.40 962.43 NIA NIA NIA 12/16/08 874.83 13.71 961.12 NIA NIA NIA MW-6D 1/19/08 874.77 13.69 861.08 NIA NIA NIA 6/19/08 874.90 12.43 862.47 NIA NIA NIA 12/16/08 874.90 14.67 860.23 NIA NIA NIA Page 1 of 3 'fable 1: Groundwater Elevation Data ❑SCA ID No.: 41-0024 Groundwater SamplingPoint Sampling Date mmlddl YY) TQC Elevation [feet] ] Depth to Water feet b s [ g l Groundwater Elevation feet Depth to NAPL feet b s [ g ] NAPL Thickness feet [feet] Corrected* Groundwater Elevation feet MW-7S 1/18/08 871.02 16.44 854.58 NIA NIA NIA 6/19/08 871.07 16,78 854.29 NIA NIA NIA 12/16/08 871.07 16.88 854.19 NIA NIA NIA MW-7D 1119108 871.08 18.30 852.78 NIA NIA NIA 6119/08 871.12 18.49 852.63 NIA NIA NIA 12/16/08 871.12 17.85 853.27 NIA NIA N/A M W-8 1/18/08 855.11 2.60 852.51 NIA NIA NIA 6A 9/08 854.99 3.31 851.68 NIA NIA NIA 12/17/08 854.99 2.18 $52.81 NIA NIA NIA MW-9 1/18/08 855.01 8.20 846.81 NIA NIA NIA 6/19/09 854.82 DRY DRY NIA NIA NIA 12/17/08 854.82 7.25 847.57 NIA NIA NIA MW-10S 1118I08 950.28 6.49 843.79 NIA NIA NIA 6/20/08 950.28 6,71 843.57 NIA NIA NIA 12/18/08 950.28 6.08 844.20 NIA NIA NIA MW-10D 1/18/09 850.62 6.97 843.65 NIA NIA NIA 6/20/09 850.5E 7.20 843.36 NIA NIA NIA 12/16/08 850.56 6.54 844.02 NIA NIA NIA MW-1 I 1118I08 864.62 5.92 858.70 NIA NIA NIA 6/20/09 864.62 6.47 858.15 NIA NIA NIA 6120I08 864.62 5.47 859.15 NIA NIA NIA IN17108 804.62 5.04 859.58 NIA NIA NIA MW-12S 1/19/08 872.28 13.94 858.03 NIA NIA NIA 6/20108 872.28 13.50 858.79 NIA NIA NIA 12/16/08 872.28 13.06 $59.22 NIA NIA NIA MW-12D 1118108 871.97 14.04 958.24 NIA NIA NIA 6120109 871.97 13.37 858.60 NIA NIA NIA 12/16/08 871.97 13.29 858.68 NIA NIA NIA MV4'-13 6113108 868.84 11.42 857.42 NIA NIA NIA 12/16/08 868,94 11.58 857.26 NIA NIA NIA Page 2 of 3 Table 4: Groundwater HeN•ation Data DSCA ID No.: 41-0024 Groundwater SamplingPoint Sampling Date mmlddl { YY) TGC Elevation [feet] ] Depth to Water feet h s [ g ] Groundwater Elevation feet Depth to NAPL Feet b s [ g ] NAPL Thickness feet [feet] Corrected* Groundwater Elevation [feet] MW-t45 6/13/08 880.44 DRY DRY NIA NIA NIA 12/17/09 880.44 DRY DRY NIA NIA NIA MW-14ll 6/13/08 880.50 19.47 861.03 NIA NIA NIA 12/17/08 880.50 19.74 860.76 NIA NIA NIA MW-15 6/19/08 856.45 3.80 852.65 NIA NIA NIA 12/17/09 856.45 2.16 954.29 NIA NIA NIA M W-16+ 1 6/19/08 847.85 10.04 937.81 NIA NIA NIA 12/18/08 847.85 8.50 939.35 NIA N/A NIA MVa-1G1 6/19/08 847.86 12.37 835A9 NIA NIA NIA 12/18/08 847.86 8.88 838.98 NIA NIA NIA MW-16D 6/19/08 847.95 9.40 938.45 N/A NIA NIA 12/16/08 847.85 9.60 839.25 NIA NIA NIA MW-17 6/19/08 860.61 11.11 849.50 NIA NIA NIA 12/16/08 860,61 9.08 851.53 NIA N/A NIA MW-18S 6123I08 874.42 14,51 859.91 NIA NIA NIA 12/19/09 874.42 14.38 860.04 NIA NIA NIA MW-181) 6/13/08 874,47 14.54 859.93 NIA NIA NIA 6/23/08 874.47 14.31 860.16 NIA NIA NIA 12/19/08 874.47 14.40 860.07 NIA NIA NIA Page 3 of 3 Tahle 5: AnaIYiicaI Data for Groundwater DSCA ID No.: 414)024 O c� O Y y V T m CIMO6 @W5 @005 m005 -.ODDS -.005 10.00S m.W5 NA m.0m m.065 I,tt m-05 m.005 NA IIX Q.M5 -.005 04211 -.010 -.WS MW-I IMQSIDA m.003 -.005 @.005 0.0032 GAW1 @005 @OAKS NA -.OWS @.003 11,118 -.005 m.005 O.IMI0723 MW m6.00 01105 SASS ILM @DWS 12AM O -�O.OJ] -V of -WI -Owl 10.001 m.001 -.601 NA m.003 -001 11.130 -).00I -0001 m.o] 0.59I m001 6.001 a,031 IA" -.001 04120AS m005 m0005 m.005 0.0032 0.0054J m.005 of 00[J3 NA -.ODDS 00M31 I.350 @.005 @005 o0.OW 0.990 moos 11("P771 aim 8091 @W5 MWIM UJ M7k ❑1001 m.001 -DWI 19.001 00052 m.001 m.001 NA m.001 m.001 side DDODI m01 -.DOI 0751 41001 0own 0.10o 1A91 m001 QW23+06 @.UnS @.005 0005 -.WOS 4.018 vROM mAW05 NA kODD5 -.OM t7l -05 -.WS NA kHz -.00S W.020 OMM 215 <Ions Mw-2. t*rj✓<ll1 4).OU5 @.W05 A]U05 m.SpoS m,op3 e0.005 -.O W5 NA •MKX15 N"M iSSO N.005 -.005 01N11161 0.a13 060677 UAW OMS3 5.700 nIpw$ IV17" -0001 m0001 @1101 @.001 D.op2S 41.061 0,8619 NA m.001 m.001 ■,M m.061 -to 001 mpol 4.6011 - .Owl O0W4 aws1 [am @01 lK13M m.005 mDOGOS -*AIDS @.0005 loom a.0D5 10.0005 NA m.00D5 D00391 0.01j -OoS -.005 m.o61 L6,91 m.00$ @605 0.121 -MOOM M.UO5 MW21pt 1v17xaJ 4J OI15 mops moos @m5 m.ons moos moos NA .o.00s m.ms 0.056 -.065 -.4D65 u1 065 I,s,Sa m.uos @oos a019 m.uas moos (MQ3n16 moos -WOS -.ODS ®00005 m.005 mo05 10.1ol15 NA m0005 m.005 0.069 @.W5 @005 NA 0.97 @.005 @1375 8.04 @010 mobs MW-3 11023108 -0005 *OCO5 *005 @A005 m.WS @.005 1f(N1O5 NA d.offl$ 001421 &M )..005 -9-OM o,OW511 I" @003 @.005 9,W% OJI48 <100 IL1&" m005 @.005 -.005 -OMS QW3 mD 00. mDO05 NA @.05 @ADS 4J 0M --9005 m.005 @.005 ii'm m.D05 m.WS 0.839 4POOS m.0115 Mimi m.005 m00005 m.005 *OWS <005 @005 @A as NA 4MVS m.OUS •1l.[05 eo WS O-OOD271 -.00S ■OW m005 M.WS @tA15 DOW5 10005 MW4S OBl19IY1 -am -MOM 0.00$ *JDM m.005 m.005 -.Oo5 NA IGOM -&WS OOD25) m.005 m.005 m.005 m.0007 -.05 -A05 -OOS -ADDS -.065 W17g8 m.00] @.01 @001 01001 m.01 m.001 d.00[ NA -.BOI -O.M m.001 -.001 -OOw m.001 1.0.0107 m.001 -OMI @0M @001 @AOL j0/1[A417 -.063 dW.OMS -0.005 :2005 4).05 m.603 m.0005 NA @.00W5 @.DOS O.W3 @005 O.D00221 0OW291 2LM7J ❑0D241 4).005 m.OD5 - OWS 40.005 MWJD fRY19S18 -00% 00095 @05 v1.0005 ❑1065 m.OM m.0o5 NA -A005 4J(50S OAO$33 -.005 @DOS O.M039J -0OM mwN -0.005 m.MS mOW5 @005 12AIM -.01 @.901 @.091 V0.001 m.Wl @Oo1 m.001 NA -.oD1 @.001 @001 m001 m001 -.001 a %)117 @90[ @WI m.001 Q.U01 @.001 MW-SS 10l10A7 m.005 o.W6.5 Q.003 m.WO5 m.003 @.05 WOW5 NA M..0005 000221 0.031 @.005 @.00S -M.M ar" 10.005 @005 O.00IJ m.o05 m.005 MW5D 16WWw -.DOS m.W05 -M.003 moos -.005 m.003 m.OW5 NA m.0005 0.00037J O.D31 @.005 m.005 O.M 4.2" v005 0000383 0.0tS0 1-0013 m.005 1w1w 0.000W 4.OW5 a/.UO5 OOM47J mO.WS -.005 mO.OWS NA -.0005 O."33J -.005 -.05 -.WS 6.000W M.OW7 40.D05 -ADS @005 @0105 m,05 MW+5.9 W19M 41.{115 m.0005 m0.%5 -O.W03 �0.003 uW5 -OOM5 NA @.01*5 C00191 00025J @.005 @.005 DOMMA @0M17 m,m5 m.005 -GODS mWOS m.05 1211608 m.001 -.001 m.o1 -.WI m.061 111.001 m.001 NA 10.001 m.S101 m.061 m.001 @.Oo[ �0.001 11,0211 m.Wl 40.001 mAD1 40.001 -0.001 1WIOW @.003 @.DUOS 4.05 @.0fw 10-OM -.0M -00175 NA O.OW5 0.001fJ -.005 0.05 d0.Cg5 -.005 4, IKw m1105 @,005 .0005 @09005 @.OD5 MW-6D ONIM -.ODS -.0005 -.005 m.0005 m.005 10005 @005 NA @.005 4AN91 0.0025J @.005 -,:N*5 10005 CAM n1005 -.005 mWs m.W0.5 m.1305 1211601 O.W1 @O.wl @.001 41.M Jkwl m.0ol -.001 NA -.001 011013 -.001 m.601 -Ool -001 oAJM -.DOl m.001 @OMI @ODI 10.0p1 f(lIDM -.005 -.OWO5 m.005 m.o05 m3105 41.005 mAo5 NA @005 0.011 mODS @03 *1)05 @.005 0.002 S<1.1105 m.005 -DOS -DODOS -.005 MW-71; WPM m003 IOMM -DA05 10.D0o5 m.003 10.003 -00005 NA -.0f105 m.005E7. m065 -.005 0.OMW I.olk11 ❑+(u5 .0005 @.005 @OOoS @.o05 1711608 -.001 @.001 m.ol <0001 m001 -.[ql @Owl NA @.001 @.001 @.01 @.01 m001 0.1/9 m.001 m.Wl m.Wl -.O0! -.ODI 1mIW @005 @o0D5 -.605 IOMM ¢.005 -.005 -.OWS NA -.WD5 0.0089 -.003 m.0W5 -.00S -.6(I[17 -005 m.005 m005 m.0003 4).003 MW-7I7 {MJI%M EF -.005 @O 05 m.oW3 @.005 0.005 @A005 NA -IO.OM OAN91 41.0p3 @.05 O.OW261 0.91 m{q5 m005 m,WS m.000s m.005 12116Na ,001 -J.ODI -.W] -.001 -<AI m011 m.001 NA @p11 mD01 m.i701 -.ol m.00I 0.f21 -11161 0.001 mW1 owl @WI Page I Or6 Tahle S.- Analytical Data for Groundwater DSCA ID No.; 41.0024 C ~a. L 4c O 16 el 4 yY. L v � G Y Fu c tl Y D O O O O � eri 2 ? fV M I m $ 10AW17 Dr, Dry Dry Dry 17ry Ivry 17ry Tky Pry 1ky Dry T7ry Tky Dry Tkv Dn Pep I]ry Dry fk)' lulllM dam *(M5 -0f15 ❑OD14 0002) -0.005 m.0005 NA m.OMS 0.00]9] OOMW 10.005 10.005 50.005 amw T.005 m.005 am[ -.00M mn Ow PAW-9 O&r4m m.005 @0005 NO05 0.005 0.O W m0M o0.0005 NA d.M05 0.0052 0.OWN d{0S -DAMS 0005 &0"1 'LOOS -W005 ami. o)OWS moos 17117R10 T.Wl mA01 NO01 0.0019 0.0021 IDWI -.00I NA 10.001 0.00" -COI -.001 m.001 mOD1 MIW37 41.001 10-W a0%. d001 rnml 0670M Dry Dry Dry Dry Dry rlrq Iky Dry Dry Iky Dry D. Dy Dry' rk5' Dry tkF ay a 9 rky MWA IL170 Ql101 v7.001 v1001 01.001 T011 ml%)t 0.001 NA m101 dull -A01 4I001 m.00] v+01 v](lu[17 00037 v1.001 mlMll a).001 41.001 10/10A7 411 K15 C)000S m.00S m.0005 m.005 mDW5 00.0005 NA m.OM5 m.005 0.90331 m.005 OAOONJ 41005 0.111 N.003 m.005 /AM7J m.MO5 m.005 MW-103 wmm m.005 --O!t5 m.005 -OMOS mA05 W.005 mO."5 NA C1W05 0.00391 0.003J O.OD5 <0005 1)OW53) 0./N m.005 -DADS 1.00" RM17 oI.D03 12<1Mv1 10.001 m.001 -.001 -.001 m.001 m.001 10.001 NA m.001 m.001 0.0044 -.ODI -.001 m001 0.111 m.001 m.O01 0.40144 d-(]QI g1.001 0110107 m.MS w.OWS m.005 2.0005 <0.005 m.005 m)Wls NA mPM05 -0.005 0.00211 '0005 000015] R/005 0.100 .UWS -4 W5 UOU211 m.0005 rn.Oal MW-10T7 (02106 ni d 003 W.ODOS 10.005 -.ODDS m.005 m.005 -O f11105 NA -OMPD5 O.DD39) 0.0024 10005 -.005 m.u05 u.1211 y0O5 -dJ M5 11A025 m.0005 d0.M5 12/]8A8 m.00] m.00] W.O01 m.001 m.Wl �0001 @.MI NA 10.001 m.001 0.0020 mMl 19.901 al001 C140 m001 -001 0.0021 m.001 -.001 10/IM7 -D.003 T.000S d.WS m.0005 m.005 m.005 Q.WO5 NA m0005 0.000W U.001J m005 m.005 �O Owus O-wn m005 -.005 m.i105 mD.cws -.005 MW-II rw_lms g1.O05 • MW v1.UO5 --OM05 T.005 10.005 TOWS NA -.0005 0.0047 000111 d.005 -.005 TOM 1,033 -ZOOS v 005 0.000743 '0W05 NDM5 12j17411t QVml 'OMI �.001 m.OR1 m.0[11 N.001 Q1.001 NA Nu MI v5.001 00021 -.001 gD.wl Q U01 1.011 W.001 mps1 m.001 m001 Doul 1011ow m.00S dOMW dW0 m,W05 -DW3 m.005 -0005 NA -.005 0.00111 -LOOS m.00.5 m.005 m.005 RI W07 m.005 -OMS O.OW7IJ -.00PS 40.005 MW.12-5 ONJOAO 1*.005 m.0003 m.005 C.UDM5 q.M5 v0.005 m.OM5 NA -Ck(W5 N.003 10.005 10.05 m.M5 vO.005 Q1.VOU7 W.005 m.005 Q.ODS m.OWS m.005 121170i U.001 m.001 -0001 d.001 -.001 -0.001 m.001 NA 10001 -D.wl -.001 m.001 -.00I m.001 41.0007 -.001 dOnI dA.wl dCP1 00.001 1011007 m.105 -.0003 -.003 2.0005 m.005 41.06'5 O.W0211 NA -C.W05 WJOW41 U-0014J oO 005 40.005 m*M 0.1175 O.OW2.IJ Q1005 1.11U -ODDS m.ODS MW-121) M120" mAM$ m,W05 m.005 1 d.vu15 u1X41541 T.005 -Ojw5 NA m.0005 O.DD$$ 0M W TOM d005 ❑I[05 m0007 n 0.1 Q als 0.117 -DOW5 w.005 1 N1700 NWI m001 m.001 N.ODI -0.001 -!*.MI v1.W1 NA . 001 0.002 0.1Y49 •0.901 -QMI -1I rOi ®0007 mO ML -.011 0.115 m.001 m.001 W-1l 00219M QI.005 g1.000$ -ZOOS m.0003 -0.005 m005 -OM05 NA m.0005 -9 W5 -0 OM -.005-.SOS mWS ..SOS 1017 v WS -ZOOS -MM5 -VOW5 �.MS M 121100]$ m.001 m.001 N101 -0401 -OM1 .0.001 g0.001 NA m.Ml m00I *Wl d,M1 e*Mt CIml '].Or mJ01 *001 - 00 1 mU.Wl m.001 06J19AO N.0U5 m.0005 *.005 Q.MD5 0.005 a 005 mM05 NA -.OMS m.MS m.0M5 '0.005 *005 0.0015J mAfw m.003 4kD115 TOUS 10.0(105 '0.005 M W-14➢ 12117" 1?001 -.WI -.UOI -.001 -OD1 ❑I.WI Q.O(A NA -u71 m.ODI -OOI m.W1 m.001 -001 T.IX107 m.001 d.Ml m.Wl m.001 00.001 MW-]5 [50/19.511 d005 rn.OW5 rnfOl5 10 MD5 <OMS m.u15 v OWS NA m.W05 -.005 -.DOS m.003 m.005 DPD16J O.0007 mI05 m.ODS m.M3 m0005 �.OD3 12117A8 Q1.00I I mWl -0 MI I v0.001 m.001 m.091 1 -M.Wl I NA v7.001 v1.001 10.001 oO.Ml -QA*1 1 10001 -0.0007 m.001 I m0001 -.001 -.D01 m.001 Page 2 ofe -I'ahle 5: AnaMieal ❑ata for Groundwater DSC'A ID No.: 41-0024 e �y 5 o eC `D o `D A .o V u lr N m d w [Mal A A4W-1 OW19AtlS -P.m -*MOS -0.001 -LOCOS m.005 Qf.005 2.0(05 NA 10.0005 ❑.OZS -*-COS moos QW5 O.OW51 m.0007 Q]WS m.UW m005 m.0005 -oom R4 l2�18p3 d]W1 Q✓.Wl 41001 al Wl m101 410ol GIAoI NA d1.001 d].00I D.WI 40.001 @I0l 0f OW7 m001 m.001 m.001 m001 m001 OW19M 000361 m.OMS W.005 -00005 m.005 OMM147 SO.OW5 NA QIp05 0.015 ®.WS 2-d15 m.O05 OOOIS] -*.WM -0 OM m005 ,0.005 �U tOW mOM MW-161 IMF" d0.001 m,001 *001 m.001 41.W1 -0.001 1-1001 NA -0.003 -0.001 m.001 m301 t0.001 d]001 OP=" m.W1 �001 a 001 110.001 C0001 A4W-1pI5 OW1wos O.Oow m,WO5 m.005 c0.00o3 m.005 e0A05 10.0m NA dJ.OM5 U-0011 m.UO3 110.005 m.065 0.0017J &!T m.005 m.005 m.OW 41,W05 410u5 1211 FM 41,OOI 10.001 -*001 m.001 m.00] m.W1 m001 NA 10.001 �0.001 m.001 m.001 m.001 m.001 k"21 df.Wl 0.001 Q1001 4).001 Q1001 mw-17 12116M ¢,Nlj •L].W] <u IV m.001 <0.001 m.001 <0.001 NA 0I.W] m.001 m.001 m.001 m.001 0.101 *AMldf o0=I mW1 41.001 4D.W1 -INCl IXJ231119 I(Ims mW05 m[OS -O.OW m.005 b W!I mOOWS NA -[ 0W 0.0095 0.013 @005 -0005�0.005 0A75 -0005 m.WS ■W71 MAM22 4AUS LIWI-18.4 Ingm -0005 MAWS m.om ,D.WO4 O.OD5 -0.005 •00005 NA -0.0005 WDW5 0.031 m.005 m.O05 m.00S 6.014 mWS 0.0006 0MI 41 m0005 -0(195 nrw•!en Wln.vl% QII]US MAWS m005 �O.Oow mQ.M5 m W3 -001A15 NA m.0005 0.0041J OA29 <O.M5 m-OM m.005 &M I a 005 Q..005 &MIN U,Mr <IMS 12/11)NR <0.035 41,0005 c1.(*i 0.0(w 41.W5 d1.005 m.0005 NA m.0005 m.005 0.039 m.005 -*OOS 0.(OI391 0.22 IRM5 IOW5 11.125 L0017 m.005 SE"Il 0,21' 07A)W NA NA NA NA m,001 NA d).001 NA NA NA m*Ml dI,001 NA NA m001 IQUM m.001 mall maul 41.0[II 904 122.W 0711)M NA NA NA NA m.001 NA <O OoI NA MA 74A 0.0202 m.W1 NA NA 0,N m.oOl m.001 0.0w d0001 -.D.WI SR-1326.3r ON10107 NA NA NA NA m.00! MA m001 NA NA NA o1412 NO01 NA NA ■M16 19001 m.901 0.M114 m.001 m.o01 SB-1424.28' ONIMn NA NA NA NA WUool NA Q1001 NA NA NA <0ONDI <0001 NA NA m001 0011 41.001 v]IKII <001 m.001 5&17 x0.2C 01AW NA NA NA NA m.Wl NA m001 NA NA NA mall a1001 NA NA 110M1 10001 d1.001 <0.001 m.001 m.001 SR-17 32,W 07AW NA NA NA NA m.001 NA m.001 NA NA NA d1.001 'o.001 NA NA 10.001 10.001 m.W1 m.Wl m.W I mAOI 5R•1R M•24' 0711W NA NA NA NA v]0(II NA d100! NA NA NA Q1.001 �0001 NA I NA -OM 1 C0.001 41.IX11 mIXII 41.001 dSWI 9&1153.3r 07AW NA NA NA NA N.U01 NA m0W NA NA NA -.0111 Q0001 NA NA mA01 d.001 41.u01 01 IK11 m.00I m091 SR-1924-2r 07111R17 NA NA NA NA m.001 NA <O.001 NA NA NA 0.00M m.001 NA NA 621 Q1901 Q1001 0."39 m.001 m.001 R M9.%4W 07/11107 NA NA NA NA m.W] NA m.001 NA NA NA O.D1M5 m001 NA NA •2 10001 41001 0.MMM m.001 @001 LL2124.25 07/11107 NA NA NA NA *A.W1 NA <001 NA NA NA �O.W1 �OMI NA NA 0,00111 m.O01 m.001 41.001 -,ow m.01 9R•2226.30' 071IM7 NA NA NA NA m.001 NA m.001 NA NA NA m.001 m.001 NA NA m101 10001 m.WI m.W1 m.001 mA01 S13.22 4347 07112.07 NA NA NA NA m.O01 NA 1O.U01 NA NA NA dO.wl m.O01 NA NA 6.MS1 m-001 41001 dO W1 --Ml m W 1 4n.2324.2w 07111 A7 NA NA NA NA 41.001 NA d0001 NA NA NA dT101 10W1 NA NA mall QI.001 m001 m001 m.001 m.001 SN-2335-37 07111W NA NA NA NA QI.COI NA m.OU] NA NA NA 00043 m001 NA NA 0.05 m.001 m.001 U[0144 '0.001 m001 M-24IS-22' 0711 IA17 NA NA NA NA Q1001 NA 41 W1 NA NA NA -M:MI d1001 NA NA 41.W1 I a0001 m.001 000I m,OOt t.001 mmm Page 3 of 6 Table 5([): AnaNticai Data for Groundwater User Specified Chemicals ❑5CA I No,: 41-0024 3 � 0ro 09 a o � r s a f-0 Cd F - d o o p A 0 J m 09,23+o6 n1.n]U 0.02q m[R15 m.005 mW5 O.wo '0.005 m010 0.010 0.005 40.005 MW.l 05 25AR m.050 m.DlO m.005 m.O05 m.005 m.010 m.005 m.010 m.010 m.005 m.003 1211Ri0R W.o05 W.001 'O.OW1 m.Wl m.001 ro.UM <001 40.001 N.001 m.001 10.0M 0&12wm ama41 m910 m.005 m.005 m.o05 m.410 m.005 W.010 m910 m.W5 m.005 MWABFZ I21lhV8 19.005 �0.001 o).001 n7.001 W.001 m.003 �0.001 m.Wl m011 m,W1 mO.M M3i06 @.OIo m020 m005 m0005 m.005 m.010 m.00S n3.010 m.010 mODM m.00 MW.2 06,23p9 mOso m.010 m.0m moos m0005 @.010 m.005 0.03 4aA1O m.005 m.0015 12117M mOf15 m.001 m.00! m0001 m.001 WA05 m.001 0.022 W0001 mA01 m.o05 06 im a Oso m.010 cWX05 m.00s &OO5 m010 m.W5 m.010 m.010 m.005 m.00s MW-2HR 12/17" 01125 a1A05 •0 N 1 s --i1.OW NA05 m.025 @.005 m.005 N.005 ODDS i0.025 om2 , 6 m.010 U.020 moos e0.005 m.Ws m.010 m.005 b0.010 m,010 mfg5 m005 MW.i 06123M m.050 m.010 m.005 m.00S mA05 m010 m.005 m.010 4*.010 mA05 m.005 l YIEbB mA25 W.Ws m00$ m.005 m.005 <025 m.005 m.005 m000$ m.00s m.023 1071a07 m010 m.010 m.005 m.005 m.005 m0010 �0.005 10.010 "10 113.005 m.005 Mwsti WNIOR m.V50 m.010 m0.0&5 10,003 mW5 --a010 m005 m.010 @,OtO -DM5 N.003 1NUM 0.005 D..001 m.001 m.001 �0.001 m.005 <0.001 m.001 m.001 m.001 m.005 Wolff 0.011 m010 m.005 DO.M m.WS m.010 mOoos 10910 m.010 mA05 m.W3 MW4D 06/19100 O.WfW3 m.010 Q1.1*5 m.005 W.005 n3A10 �0.005 c0.010 n0.010 W.005 41.095 1217" m.005 @001 m.00l m.001 m.001 mA05 &001 m.001 @001 mom m.oas Ww-ss MAW 1*.010 m.010 mn0s �O.om m.00.5 •0.010 QOD5 d.010 �0.010 n).005 m.005 ■M.Sn Ia1M7 m.010 m.010 O.OW2IJ m.DDS m.005 m.010 W0005 m.o10 m.010 m.005 @.005 10110`O7 m.010 m.010 10.005 mW5 m.01n m005 m0010 m.010 m.005 m.005 MW-6S o6lwN --O.M m.010 m.005 m.005 0.0019) m.010 m.WS -aOW 10.010 m.00S m,OVS Ivif'" �Q.(R15 m.0O1 y001 m.001 m.Wl a..00s m.o01 10.01 10.001 W.001 n1.005 10/1007 41010 <.01n -0005 moos m.005 m.010 m.005 NA NA NA NA MWAf] W90R Oi/Y51 m.010 m.005 mAOs m.005 m.010 m.005 N.010 m.010 m.005 m.005 1v160g 100f15 10.001 m.0111 19.0n1 m.001 -*OM m.001 mO01 m.001 m.001 m.005 10/1RU7 00047) 0.010 -0.005 0.000611 m.005 m.010 m.005 NA NA NA NA MW-73 CWV19A8 n11151 m.u1n Ci.als 0.W5 n)fmi m,D1❑ m.OM m.010 m.010 m.p05 m*-W5 121IGN m.005 m.W1 *..001 �0.001 e0.001 rA.M m.W1 �0001 '0.001 O.ODI m.005 1WI007 m014 M.010 10.00s O.W0541 a1005 m.010 mOu5 NA NA NA NA MW-715 06719108 0.00611 -0.010 n].W5 m.005 0.002 0.00511 m.005 mAlO m0010 N.005 m.005 1vA8 16 mOOs m001 m0[It m001 m.001 m.005 m.Wl m.wl m.D01 m.ml QI OM5 1'aL:w 4 of 6 'fable 5 l : Analytical Data for Groundwater User Specified Chemicals MCA ID No.: 41-0024 C � Y E a !n F O Dry MY Ury iay ISry Dry i3ry Dry INY lkry 1). III him -:0010 N.QIO Z005 M.W .0.0[Is Gj11111 -ow NA NA NA NA Mwal kD09A7 MINIM O.rw5 m.o[o -UM5 m.005 OAOi97 *010 0.0002N m.p10 W.010 0.005 mOoos 2117AB Z.005 dDAOI Z.W I -0.001 Z.001 Z.00S ZW I m.001 <O.Oo1 Z.p01 Z.005 06nom Dry Ilry MY ay INY INY IIrY tkY Or7 1:4Y DFY M%r-9 12J17m ml(M m.UOl Z.001 10-W 4p.001 Z.MS mA01 mODI V][NII <0001 9.W3 IWI(Ki7 c0010 10.010 m.095 -4.003 m.005 W.010 Z.005 NA NA NA NA Mw-IfA 06rolm 0006S7 m.010 m.005 m.005 m.OM mp10 m.005 m.010 m.410 V].Op3 m.005 1 IV BAN -0.001 �0.001 D..001 9.001 -0.001 m.WS Z.M1 Z.WI -0.001 lo.Wl loom 101IM7 • .U10 m.Dl❑ Ql005 N.Om ohms m.01u m.MS m.0I0 m.p1p e O05 4.D05 mw-1M3 Osl20AA ❑1.050 m.010 e0.003 @o05 2.W5 m.010 m.005 m.010 m910 M.005 Z.WS 1 VIBAB 10003 m.Wl m.W! m.00I m.001 d.OW --shot '0001 m.00! Qi.W1 eO.005 1 NI IA7 W010 n9.010 01.005 m.00S �0.005 m.010 m.005 NA NA NA NA WWAI OWOM 00% N.010 m.005 W.O05 Z.WS m.010 o.m Z.01O Z.010 mW5 m005 32717AA Z.WS m.WI Q1.001 m001 m.ffiI 1OA05 -0.001 Z.001 m.Wl D.OQI m.005 101111117 v1010 10010 b0 ow 0.0011) --0.005 m.010 N.005 NA T1A NA NA Mw-12.9 0620Ad 0.00691 W.010 0.005 *005 ZO05 *0I0 Z005 m.010 @010 ZOOS Z.WS I2/17M ZWS Z.WI Z.001 Z.00I m.WI -OM Z.001 -0.001 Z.WI 0.001 tiUrn]S PAW 0013 (1.00191 W.OW v1.005 m.005 m.010 m.005 NA NA PIA NA MW-I2D FOZTWROi 0.00731 m.0I0 -0.005 ZOOS m,005 m010 <OMS 10.010 Z"w m.005 m.005 ILITpR )..005 m001 QI.W3 ZOol m.001 m.001 m.Wl e0001 a1.00I 10.001 m.005 MW43 06119m m.050 m010 m.003 m.005 10.005 •6.OIo ZA05 d.QIQ Q.010 m.005 -MAS ILlhL" m.00s 0.004 Q1001 -0.001 1*.001 <PIA)5 �V.001 m.003 c*W Nu 001 *005 Mw-IiD 06119AIN 10.05O m.010 Z.W5 m.003 m.OW m.WO m.005 <9-010 10.011) 'O.WS OW11 IV170 -0.005 e*Ohhl mOOI m.001 -U.001 m.005 m001 mo01 m.001 N.001 m.00.5 MW-IS 06119A A m.030 I m,OlO m.005 m.003 m.UD3 m.010 Z.005 m.010 m.010 00003. H IV17AA I m.005 -0.001 Z.001 m.001 -0.001 1 Z.o05 ZM1 m.001 m.001 e0.001 1 -.0.005 Psgc 5 of 6 Tablt . 1 : Analytical Data for Groundwater User Specified Chemicals DSCA ID No,- 41-0024 .. 0 c OG C 4 4 O 5 O 55 O V O y i c o o a o E 2 LJ n E m Z m s o 'o M1V•IG4 WIM m.030 000311 i,m amm a,(io mA10 m(w ¢P.oro N010 o.fm m.003 1211 L-M m.005 t0.001 �0.001 11)001 IO.ODI m.005 mOwL •D001 100111 W.00I m.065 WIM QA.056 0.0m 1 �0.005 O,NSI ypl$ 01.010 m105 m,UIO O,MI IJ E.Nl7J m.065 MIV-16l 13118a •0.005 10.001 -D.WI 0.001 m.001 'O.003 •O.U01 U..001 W.001 m.001 m.005 WHIM 1O.0sn 11.1,10 m.005 0.002! m.005 *010 a1. 15 11.010 0-000541 MUM 0.000592 Aiw-156 12110" v a[15 m.OGI m.001 10.001 d.00I m,005 D0.001 0.00i Owl Owl m.001 NW-17 lvi6m mQmi mO.wI m.001 da WT CIOOI �000 mm1 m.001 m.001 *.WI mA05 AIVI'-185 06?23W 9.00W1 -J.OIO N065 °O.W m.005 m0010 m.O05 m.019 @UOIO m0005 m-005 12?19= m.050 m.010 m.005 W.005 m.O05 0.00W m-005 m.910 mAlO m.005 m-O05 N1W-11n ON231% 0.006]7 m010 R0.005 m.005 m.005 m.010 m.005 m.019 -0.010 m.005 "0. 5 I N19" N.050 N.010 --O.M <0.005 m.00S SD..010 m0005 m.010 W.010 <0.005 D..005 SEY1016.20, (17AAW NA NA NA NA NA NA NA NA NA NA NA SEW 1 n2 26' O7A W NA NA NA NA NA NA NA NA NA NA NA %' SW j 2A-37 07)tw NA NA NA NA NA NA NA NA NA NA NA SH-1074:9' 07110A15 NA NA NA NA NA NA NA NA NA NA NA ,1147 2n2r 0711097 NA NA NA NA NA NA NA NA NA NA NA S51.1732-W "WIfAY7 NA NA NA NA NA NA NA NA NA NA NA SH-Il20-IA' 0711000 NA NA NA NA NA NA NA NA NA NA NA Sry•1613 3r 07110A7 NA NA NA NA NA HA NA NA NA NA NA All- 1424.21r MAIM NA NA NA NA NA NA NA NA NA NA NA SIL19 ]6-IV 07A 1007 NA NA NA NA NA NA NA NA NA NA NA M-2124.3V 07111N7 NA NA NA NA NA NA NA NA NA NA NA SFS-222&30' 01112mi NA NA NA NA NA NA NA NA NA NA NA SB-224347 0711207 NA NA NA NA NA NA NA NA NA NA NA Sa•2.3744W 0711W NA NA NA NA NA NA NA NA NA NA NA SR-23 35.39, 07111A17 NA NA NA NA NA NA NA NA NA NA NA SN2J 1"T 07111A7 NA NA NA NA NA NA NA NA NA NA NA Page 6 of 6 Table G: Analytical Data for Surface Water + DSCA ID No.: 41-0024 b ❑ CC 71 # O N � ❑ r ti CL7 p � � � 4) � � w 7. '� � .-�. G O O � G 4a � y v_ L •v � U ¢�', hr" 47 ❑ �, QU v N O7 V R A A 0 N A 7, W � V � p� � t; f.j' N p � A ❑ - 7, � ���, C v � 67 LW aG� SW -I 7/10107 NA NA NA NA <0001 NA <0.001 NA NA NA <0.001 r0.001 NA NA 00013 r0,001 <0.001 <0.00t '.n.001 <0.DOt 06124/09 a0-005 [0.0005 sD.005 0.0031 <0 005 r0005 m.0005 NA <0.0005 r0.005 0.0011 J m.005 <0.005 <0.005 0.0062 <O.005 <0.005 0 0015 J 0 OD05 <O.005 S•1 12119m -MOD5 <0.0005 <0.005 <D-0005 -0.005 -0.005 �0-0005 NA ---0-0005 -�0-005 z0.005 s0-005 r0.005 10-005 0.000521 10 005 <0.005 r0 005 - 0 D005 �0.005 06124108 [0.005 sD.0005 sD.005 N.D005 <0.005 �0.005 <0.0005 NA <0,0005 0.0411 <0.005 <0.00$ <0.005 A.005 <0.0007 <0-005 '0.005 s0-005 00005 <0-005 121191D8 [O.DD5 40.0005 40.005 <0.0005 <0.005 -0.005 <0.0005 NA <0 0005 <0.005 O.OD12 J <0.005 50.005 <0.003 0.0071 <0-005 :O.ODS 0.D015 J •-D.[IDDS [0-005 06/24/08 <0.005 c0.0005 c0-005 [0.0005 S0-005 40.005 �O.00D5 NA <0-0005 <0-005 D.ODI6 J <0-005 00.005 <0-DO5 O.D5111 •=0 005 0.005 0.D014 J [0.0005 cO 00$ S-3 12/19/08 <0.005 W.0005 m.005 c0.0005 a0.005 r0-005 [D.DD05 NA [0-0005 a0.005 0.0022 J N-DO5 t0.005 �0-005 0.04^ • 0 005 <0.005 0.0021 <0.0005 N-005 06/2410B [0.005 *.0005 m.005 <0.0005 0.005 r0-005 <O.DOO5 NA C0-0005 <0.005 c0.005 <0.005 <0 005 <0.005 <0.0007 <0.005 N-DOS <0..005 <O.00D5 c0.005 5-4 12/19M m.005 <O.OMS w-Dos w.0005 a0-005 I <-Dos rn.ODOS NA <D.DDOS m.DD5 O.DDO52 J <0-005 <0-005 <D-DDS 0.012 <O.DD5 <D.DD5 0.00061 J -O.DDas m,005 06124M <0.005 <D.0005 r0.005 c0.0005 [0,005 [0-005 10.0005 NA 'O.DD05 N-D05 O-WO59J ID.DO5 10005 [O.DD5 0.007 <O.OD5 [O.D05 0.00051 J <0.0005-0005 5-5 12/19/08 c0.005 m.O0D5 N.005 c0.0005 [0-005 1 [0-005 0.0005 NA ID.OD05 ID.DDS s0.005 10-DD5 a0-OD5 [O.OD5 OAl2 tO.ODS 10.005 0.00053 J 10-0005 10.OD5 gn51 Page i of 2 Table 6: Analytical Data for Surface Water(User Specified Chemicals , DSCA ID No.: 41-0024 �T a � as o i9 fl N U sw•1 7110107 NA NA NA 6124108 0.0069 J a0-01 a0-DD5 S-! 12/19/09 <0.05 �0-01 <O.D05 6/24M 0.008 J 0.015 c0-005 12/19/08 <0 05 <0 01 <0.005 6aVo8 000731 <0.01 <0 ODS 12/19/08 <0-05 <0 01 40 005 6/24108 000971 0.015 0.00235 SA 12119M S0-05 <0-01 SO.OD5 6124108 0.0079 J I [0-01 0.00195 S-5 12/19/08 �0.05 1 N.OI 50.005 NOW Page 2 of 2 Table 9: Analytical Data for Natural Attenuation Parameters F DSCA ID No.: 4I-0024 G7 w b E c p v d No �' c� U ❑ °� rz w a G r 0 •�� �' n _ � 'a C ❑ a C `a E c ❑ m u v Units mr L m L m L m G m m mV m m Nslcm std unit ° C m L m L m L MW-1 121181200E 0.11 <0.5 12.4 NA 0.21 2 83.6 35 15 0.213 5.71 13.03 NA 0.0064 <0.0032 MW-18R 12/17/2008 0.10 NA NA NA NA NA 93.4 NA NA 0,422 5.85 16.86 NA NA NA MW-2 12/17/2008 0.09 NA NA NA NA NA 8A NA NA 0.911 6.00 18.85 NA NA NA MW-2BR 12/17/2008 0.09 NA NA NA NA NA 12.6 NA NA 0.394 6.36 17.56 NA NA NA MW-3 12/18/2008 1.26 3.09 45.2 NA <0.0012 0 93.9 70 20 0.450 6.44 16.43 NA <0.0025 <0.0032 MW4S 12/17/2008 0.75 NA NA NA NA NA 48.1 NA NA 0.266 6.59 13.75 NA NA NA MW4D 12/17/2008 0.88 NA NA NA NA NA 76.2 NA NA 0.475 6.35 14.23 NA NA NA MW-65 12/16/2009 1.17 NA NA NA NA NA 298.3 NA NA 0.345 6.11 16.90 NA NA NA MW-6D 12/16/2008 3.39 NA NA NA NA NA 178.7 NA NA 0.142 6.40 16.64 NA NA NA MW-75 12/16/2008 0.79 NA NA NA NA NA 87.5 NA NA 0.389 6.44 15.69 NA NA NA MW-7D 12/16/2008 0.59 NA NA NA NA NA 61.2 NA NA 0,202 6.09 15.21 NA NA NA MW-8 12/17/2008 0.09 NA NA NA NA NA 122.9 NA NA 0,417 5.84 15.8 NA NA NA MW-9 12/17/2008 0.33 NA NA NA NA NA 139.1 NA NA 0.232 5.50 15.82 NA NA NA MW-10S 12/18/2008 0.56 2.1 35.8 NA 0.002 0 96.7 10 20 0.560 6.41 16.59 NA r0.0025 <0.0032 MW-10D 12/18/2008 0.12 3.66 26.5 NA <0.0012 0 97.1 100 25 0.390 6.10 1 17.15 NA <0.0025 <0.0032 MW-11 12/17/2008 0.15 NA NA NA NA NA 116.5 NA NA 0.246 6.01 17.87 NA NA NA MW-I2S 12/17/2008 0.44 NA NA NA NA NA 68.2 NA NA 0.386 6.38 18.71 NA NA NA MW-12D 12/17/2008 0.52 NA NA NA NA NA 37.9 NA NA 0.369 6.77 14.28 NA NA NA MW-13 12/19/2008 0.07 E0.5 1 39.6 NA 0.076 1.5 0.2 120 15 0.752 6.44 20.55 NA r0.0025 <0.0032 MW-141] 12/17/2009 0.76 NA NA NA NA NA 77.6 NA NA 0.283 6.24 13.72 NA NA NA MW-15 12/17/2009 0.14 NA NA NA NA NA 135.8 NA NA 0.441 5.52 17.34 NA NA NA MW-16S 12/19/2009 0.4 <0.5 3.45 NA 0.56 0 -52.1 1 200 10 0.904 6.62 15.07 NA I <0.01 <0.013 MW-161 12/19/2009 0.28 <0.5 54.6 NA 0.0025 0 -68.0 75 25 0.516 6.97 15.33 NA 0.0042 0.0048 MW-16D 12/18/2008 0.07 0.572 27.7 NA 0.002 0 -84.9 110 20 0.385 6.52 16.11 NA <0.0025 <0.0032 MW-17 12/16/2008 1.04 NA NA NA NA NA 99.3 NA NA 0.421 6.27 12.86 NA NA NA MW-18S 12/19/2008 0.04 NA NA NA NA NA 30.6 NA NA 0,318 5.94 20.04 NA NA NA MW-i8D 12/19/2008 0.07 NA NA NA NA NA 1 88.1 NA NA 0.232 5.73 19.7 NA I NA NA Page I of 1 �A NCDENR North Carolina Department of Environment and Natural Resources Division of Waste Management Beverly Eaves Perdue dexter R. Matthews Dee freeman Governor Director Secretary CONTRACTOR BULLETIN # 29 Subject: UIC Permit Applications and MonitoringlRecove", Well Permit Applications Date: August 17, 2009 For consistency, UIC permit applications and MonitoringlRecovery Well permit applications submitted to the DENR Division of Water Quality's Aquifer Protection Section by the state -lead contractor (SLC) should identify the applicant, address, phone, and SLC contact person as follows: Applicant: <Petitioner's Name> (Petitioner for DSCA Site #xx-xxxx) Address; DSCA Program, Mail Service Center 1646, Raleigh, NC 27699-1646 Phone: 919-508-8400 Contact Person: <SLC Project Manager, <SLC Name, <SLC Phoneme Example: Applicant: Property, Holdings, LLC, (Petitioner, for DSCA Site #99-0001) Address: DSCA Program. Mail Service Center 1646. Raleigh, NC 27699-1646 Phone: 919-508-8400 Contact Perron: Jane Smith. ABC Environmental, 919-555-1122 Additional Requirements: The SLC contact person is to sign the UIC permit application as the signing official, and the phrase "on behalf of DSCA Petitioner" is to follow his/her signature. As an additional requirement, a copy of the Assessment & Remediation Agreement and Limited Power of Attorney for the DSCA Site and a copy of the SLC's DSCA contract are to be included with the application for the UIC permit. The SLC contact person is to sign the Monitoring/Recovery Well permit applications as agent, and the phrase "on behalf of DSCA Petitioner" is to follow his/her signature. 1646 Mail Service Center, Rateigh. North Carolina 27699-1646 Phone 919-508-84001 FAx 919-715-4061 � fnis met www.wastenotnc.org hn =quar Oppommy r Aihrmatrve Azuon Empiayer On-, NorthCaroltna .�'aturally NORTH CAROLINA DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES DIVISION OF WASTE MANAGEMENT SUPERFUND SECTION Dry -Cleaning Solvent Cleanup Act of 1997, as amended (DSCA) Program IN THE MATTER OF: ACW MANAGEMENT CORP A CLEANER WORLD #162 2334 ENGLISH ROAD UNDER THE AUTHORITY OF HIGH POINT, NORTH CAROLINA THE DRY-CLEANING SOLVENT 27262 CLEANUP ACT OF 1997, AS AMENDED, DSCA SITE I.D. 041-0024 N.C.G.S. § 143-215.104A, et seq, AGREEMENT FOR ASSESSMENT AND REMEDIATION PURSUANT TO THE DRY-CLEANING SOLVENT CLEANUP ACT OF 1997, AS AMENDED, PART 6, ARTICLE 21A, CHAPTER 143, N.C.G,S. § 143-215.104A ET SEQ. ("DSCA") I. INTRODUCTION AND STATEMENT OF PURPOSE The North Carolina Department of Environment and Natural Resources, Division of Waste Management ("Division") and ACW Management Corp ("Petitioner"), collectively ("Parties"), hereby enter into this Agreement for Assessment and Remediation ("Agreement") pursuant to the Dry -Cleaning Solvent Cleanup Act of 1997, as amended, Part 6, Article 21 A, Chapter 143, N.C.G.S. § 143-215.104A et seq. ("DSCA"). In executing this Agreement, Petitioner agrees to cooperate with the Division's Dry -Cleaning Solvent Cleanup Act Program ("Program") and the Division's independent contractors ("contractors" or "independent contractors") to assist in the assessment and remediation of the dry-cleaning solvent contamination at the Site, as defined in Section II. E., below. By entering into and complying with this Agreement, Petitioner obtains the liability protection afforded pursuant to N.C.G.S. § 143- 215.104K. Unless otherwise expressly provided herein, terms used in this Agreement that are defined in DSCA or at 15A NCAC 2S .0102, shall have the meaning assigned to them in those provisions, including any amendments thereto. 11. STATEMENT OF FACTS A. On October 18, 2005, Petitioner filed with the Division a Petition for Certification for A Cleaner World #162 pursuant to DSCA. B. On November 1, 2005, the Division certified A Cleaner World #162 (hereinafter "Certified Facility Site") pursuant to DSCA and informed Petitioner of its certification. decision. DSCA ARAv0705 demand to make payment to the Division. These payments will only be required by the Division When task -specific work has been completed by the Division's contractor. VI. ADDITIONAL PROVISIONS A. To obtain a unique EPA ID number for the disposal of hazardous wastes generated during the assessment and remediation of the Site, Petitioner agrees that Petitioner will be the Operator on the RCR.A Subtitle C Site Identification Form. For the purposes of disposing of hazardous waste generated during the assessment and remediation of the Site, Petitioner agrees that Petitioner will be the Generator on Hazardous Waste Manifests. B. The Petitioner agrees to allow the Division and the Division's independent contractors to act as its authorized representatives for the preparation, signing, filing and delivery of any permit application, hazardous waste manifest, non -hazardous waste manifest, National Pollution Discharge Elimination System ("NPDES") permit, for complying with reporting requirements and for any administrative activities that may be necessary during the course of assessment and remediation conducted pursuant to this Agreement on the Petitioner's behalf. Contemporaneous with the execution of this Agreement, Petitioner has executed the Limited Power of Attorney, Attachment 1, which is incorporated herein by reference, granting this authority to the State and its independent contractors. C. The Petitioner agrees to execute such amendments to this Agreement as may be required in order to comply with the provisions of DSCA and rules adopted under DSCA. If Petitioner is a property owner of the Certified Facility Site, Petitioner agrees to file such land use restrictions as shall be required by the Division. D. If, at any time, Petitioner becomes aware of information that may affect the priority ranking score of the Site, Petitioner shall within thirty (30) days provide such information to the Division, The DSCA Prioritization Ranking Form may be downloaded from the Division's web site at www.nedsca.org or by requesting a copy from the Division. The Division may revise the Site's priority ranking score using the most current version of the DSCA Prioritization Ranking System. E. Except as provided by this Agreement, the Division retains all its authority under the Inactive Hazardous Sites Response Act of I987, as amended, regarding inactive hazardous substance or waste disposal sites in relation to the Site. If active dry-cleaning operations or wholesale distribution operations are occurring at the Site, any hazardous wastes generated by those operations shall be managed in accordance with Article 9 of Chapterl30A of the North Carolina General Statutes and the rules adopted at 15A NCAC 13A. F. The signatory for Petitioner to this Agreement certifies that he/she is authorized to execute this Agreement on behalf of Petitioner. G. The Petitioner has designated the following representatives) as the point of contact and the Division will direct all correspondence related to this Agreement to: DSCA APAv07O5 3 ACW Management Corp Attn: Chris Edwards, President 2334 English Road High Point, NC 27262 All documents submitted to the Division pursuant to this Agreement shall be mailed or hand delivered to: North Carolina Division of Waste Mangement DSCA Program Attn: Niki Fountain 1646 Mail Service Center Raleigh, NC 27699-1646 H. Petitioner shall not assignor transfer any interest in this Agreement without the prior consent of the Division. If Petitioner is the owner or operator of the facility or abandoned site, Petitioner shall not transfer the ownership or operation of the facility or abandoned site to another person without prior written notification to the Division. The notification form can be downloaded from the Division's web site at www.ncdsca.org or by requesting a copy from the Division. I. If Petitioner is a property owner of the Certified Facility Site, Petitioner shall provide a copy of this Agreement, a copy of the Required Minimum Management Practices Rules, codified at 15A NCAC 2S .0200 and a copy of the Access Agreement executed by the property owner to all owners and operators of any dry-cleaning business operating at the Certified Facility Site before the execution of this Agreement and provide written documentation to the Division demonstrating that Petitioner has complied with this subsection. The written documentation required to be executed to satisfy this subsection is attached to this Agreement as Attachment 2, incorporated herein by reference- J . If Petitioner owns or operates a wholesale distribution facility or dry-cleaning business engaged in dry-cleaning operations at the Certified Facility Site, Petitioner shall comply with the Required Minimum Management Practices Rules, codified at 15A NCAC 2S .0200, a copy of which is included as part of Attachment 2 to this Agreement. K. All actions taken pursuant to this Agreement shall be in accordance with applicable local, state and federal Iaws and regulations, L. Petitioner understands and agrees that pursuant to N.C.G.S. § 143-215.104T, the State, its agencies, officers, employees, and agents shall be absolutely immune from any liability in any proceeding for any injury or claim arising from negotiating, entering into, monitoring, or enforcing a dry-cleaning solvent assessment agreement, a dry-cleaning solvent remediation agreement, or a Notice of Dry -Cleaning Solvent Remediation under DSCA or any other action implementing DSCA. Petitioner agrees to indemnify and save and hold harmless the Division and its officials and employees from any and all claims or causes of action arising from or on account of acts or omissions of Petitioner or its officers, employees, receivers, trustees, agents, or DSCA ARA0705 4 assigns during the term of this Agreement relating to the Site. Neither the Division nor any official or employee thereof shall be held to be' a party to any contract other than (i) this Agreement involving Petitioner relating to the Site or (ii) any other contract expressly executed by the Division or the State of North Carolina. Petitioner further agrees that the Division and its officers and employees wi11 not become potentially responsible parties pursuant to N.C.G.S. § 143-215.104B(21) by virtue of negotiating, entering into, monitoring, enforcing, or undertaking any other act relating to this Agreement and may not be held liable for any acts of Petitioner's contractors or representatives in implementing this Agreement. M. The Division's authorization of assessment and/or remediation activities pursuant to this Agreement shall be contingent upon the availability of monies in the Fund. The Division shall have no obligation to authorize assessment and/or remediation activities at the Site for which monies are not available in the Fund. N. The Parties agree that Petitioner's entry into this Agreement and actions undertaken by Petitioner in accordance with this Agreement do not constitute an admission of liability by Petitioner. No approval hereunder or receipt of funds hereby shall be taken as a warranty as to the sufficiency or efficacy of the assessment or remediation of the Site. G. Except as provided. under N.C.G.S. § 143-215.104K, nothing herein shall constitute a satisfaction of, or release from, liability for any claim arising as a result of operation, ownership or use of the Site by Petitioner, its agents, lessees, successors or assigns. P. This Agreement may not be modified without the written consent of the Parties; provided, however, Petitioner agrees to execute such amendments to this Agreement as required by section VI.C. Q. Petitioner agrees that, except as provided in Section VI. A., all products generated by, from or as the result of assessment and remediation of the Site are and shall remain the property of the Division. These products may include but are not limited to documents; remediation equipment, pumps and monitoring wells. Provided, however, "products" shall not include any dry-cleaning solvent as defined at N.C.G.S. § 143-215.104B(b)(8), any hazardous substance as defined at N.C.G.S. § 130A-310(2), or any contaminant as defined at N.C.G.S. § 130A-310.3 I (b)(4). R. The obligations under Section VI, Paragraphs, (J) (L) and (Q) above shall survive the termination of this Agreement. S. This Agreement shall continue in force until (1) it is terminated or dissolved by either or both Parties pursuant to its terms, (2) the Parties execute a subsequent agreement governing the assessment and/or remediation of the Site, (3) the Division issues a "no further action" letter with respect to the Site or (4) the Division is unable to obtain the consent of any property owner to file any restrictions on the current or future use of any portion of the Site that are necessary to assure adequate protection of public health and the environment as provided in rules adopted pursuant to G.S. 143-215.104D(b)(3). ❑SCA ARAv0705 T. Termination under Section VI.S. ( 1) shall be effective upon ten {10} business days prior written notice to the other Party. Termination by the Petitioner shall effect forfeiture of the liability protection afforded pursuant to N.C.G.S. § 143-215.1 d4K. Termination by the Division shall entitle the Petitioner to initiate a contested case pursuant to N.C.G.S. Section 143-215.1 04S and N.C.G.S. Section 150B-23. U. in the event that this Agreement is terminated, the Division shall retain all applicable enforcement rights against Petitioner, and Petitioner shall retain all applicable defenses. V. If Petitioner is a property owner of the Certified Facility Site, Petitioner agrees to grant access to the Division and the Division's independent contractors to undertake all work to be performed at the Certified Facility Site. If Petitioner is not a property owner of the Certified Facility Site, Petitioner shall obtain access for the Division and the Division's independent contractors to undertake all work to be performed at the Certified Facility Site. This Agreement shall be deemed executed on the date on which it is signed by the chief of the Superfund Section of the Division or his designee. BY �l —� ack R. Butler, PE [Date] Chief, Superfund Section Division of Waste Management North Carolina Department of Environment and Natural Resdurces By. /ignature I e z 7 6 5 oflfor Petitioner] [Date] V- go-.;h,4" f" [Title 6f Signatory] DSCA AR.Av07O5 6 AGREEMENT FOR ASSESSMENT AND REMEDIATION PURSUANT TO DSCA ATTACHMENT 1 LIMITED POWER OF ATTORNEY 1, Acw /anf^ --- eerp. 4. 0J;s)viw ,. � Petit oner"}, do hereby grant a limited power of attorney to the Division and to the Division's independent contractors, as follows. The Division and the Division's independent contractors shall have the limited power of attorney for the preparation, signing, filing and delivery of any permit application, hazardous waste manifest, non -hazardous waste manifest, National Pollution Discharge Elimination System (NPDES) permit, for complying with any reporting requirements and for,any administrative activities that may be necessary in the course of assessment. and remediation conducted pursuant to the Agreement into which this Attachment 1 is incorporated. This limited power of attorney shall terminate upon termination of the Agreement. Dated ID -�_;, 7 2e>z) 5. (Seal) yt�c Signature of Petitioner STATE OF _ 1 �r,,,,COI_INTY OF On this 9 -7 day of ,�,.- , jkooS_, personally appeared before me, the said named r;5+caPhear 77 Fml Akw�to me known and known tome to be the person described in and who executed the foregoing limited power of attorney and he (or she) acknowledged that he (or she) executed the same and being duly sworn by me, made oath that the statements in the foregoing limited power of attorney are true. My Conunission Expires I . it, . a g 7 (Signature of Notary Public Notary Public (Official Seal) ❑SCA ARAv07O5 Attachment 1 AGREEMENT FOR ASSESSMENT AND REMEDIATION PURSUANT TO DSCA ATTACHMENT 2 REQUIRED NOTIFICATION OF DRY-CLEANING BUSINESS OWNERS AND OPERATORS Pursuant to the requirements set out at Section VI, paragraph I. of the Agreement into which this Attachment 2 is incorporated, the Petitioner has provided a copy of the Agreement, including all attachments, and a copy of the Required Minimum Management Practices Rules, codified at 15A NCAC 2S .0200 to a]I owners and operators of any dry-cleaning business operating at the Certified Facility Site, located at 4506 High Point Rd, Greensboro in Guilford County, North Carolina. The dry-cleaning owner(s) or operator(s) has/have read this notice and acknowledge(s) that the Petitioner has provided a copy of the Agreement and a copy of the Required Minimum Management Practices. For more information please call Niki Fountain t (919)508-8452. Signature of Petitioner �"4_ o VV_-r r7��Y�v r Signature of dry-cleaning business owner, operator or representative Title Name of dry-cleaning business Date Date DSCA ARM0705 Attachment 2 4 15A NCAC 2S .0200 DEFINITIONS The definition of any word or phrase used in this Subchapter shall be the same as given in G.S. 143- 215.104E and the following words and phrases shall have the following meanings: (1) "Act" means the Dry -Cleaning Solvent Cleanup Act of 1997 and any amendments thereto. (2) "Apparel and household fabrics" means apparel and fabrics that have been purchased at retail or have been purchased at wholesale for rental at retail. (3) "Business" means "business" as defined in 15A NCAC 13A ,0104, which is hereby incorporated by reference including subsequent amendments and editions. A copy maybe inspected or obtained at no cost from the Division of Waste Management, Dry -Cleaning Solvent Cleanup Act Program, 401 Oberlin Road, Raleigh, NC. (4) "Closed container solvent transfer system" means a device or system specifically designed to fill a dry-cleaning machine with dry-cleaning solvent through a mechanical valve or sealed coupling in order to prevent spills or other loss of solvent liquids or vapors to the environment. (5) "Discovery Site" means the physical site or area where dry-cleaning solvent contamination has been discovered. A discovery site may or may not be the same property as the facility site. (6) "Division" means the Division of Waste Management of the Department of Environment and Natural Resources. (7) "Dry -Cleaning Business" means a business having engaged in dry-cleaning operations or the operation of a wholesale distribution facility at a facility site. (8) "Environmental media" means soil, sediment, surface water, groundwater or other physical substance, (9) "Facility site" means the physical location of a dry-cleaning facility, a wholesale distribution facility or an abandoned site. (10) "Material impervious to dry-cleaning solvent" means a material that has been demonstrated by the manufacturer, an independent testing laboratory such as Underwriters Laboratory, or another organization determined by the Division to be comparable, to maintain its chemical and structural integrity in the presence of the applicable dry-cleaning solvent and prevent the movement of dry- cleaning solvent for a period of a least 72 hours. (11) "Number of full time employees" means the number of full-time equivalent employees employed by a person who owns a dry-cleaning facility, as calculated pursuant to 15A NCAC 02S .0103. (12) "Person" means "person" as defined in G.S. 130A-290, which is hereby incorporated by reference including subsequent amendments and additions. A copy may be inspected or obtained at no cost from the Division of Waste Management, Dry -Cleaning Solvent Cleanup Act Program, 401 Oberlin Road, Raleigh, NC. (13) "Petitioner" means a potentially responsible party who submits a petition for certification of a facility site. DSCA ARAv07O5 Attach=nt 2 APPLICABILITY The provisions contained in this Section set forth the minimum management practices for the storage and handling of dry-cleaning solvents required to be implemented at all dry-cleaning facilities, dry- cleaning solvent wholesale distribution facilities, and abandoned sites. The provisions contained in this Section are applicable only to owners and operators of dry-cleaning facilities, dry-cleaning solvent wholesale distribution facilities, and abandoned sites, REQUIRED MINIMUM MANAGEMENT PRACTICES (a) All abandoned sites, as defined by G.S.143-215.1fl4(B)(b)(1), shall at all times after this Rule becomes effective, comply with Required Minimum Management Practice, Subparagraph (b)(5) of this Rule. (b) All dry-cleaning facilities and wholesale distribution faci li ties -shal 1, at all times after this Rule becomes effective, comply with the following minimum management practices: (1) At no time shall any dry-cleaning solvent, wastes containing dry-cleaning solvent, or water containing dry-cleaning solvent be discharged onto land or into waters of the State, sanitary sewers, storm drains, floor drains, septic systems, boilers, or cooling- towers. All invoices generated as a result of disposal of all dry-cleaning solvent waste shall be made available for review by the Department. If a dry-cleaning facility uses devices such as atomizers; evaporators, carbon filters, or other equipment for the treatment of wastewater containing solvent, all records, including but not limited to, invoices for the purchase, maintenance, and service of such devices, shall be made available to the Department. Records shall be kept for a period of three years. (2) Spill containment shall be installed and maintained under and around dry-cleaning machines, filters, dry-cleaning solvent pumps, stills, vapor adsorbers, solvent storage areas, and waste solvent storage areas by January 1, 2002. Spill containment shall have a volumetric capacity of 110 percent of the Iargest vessel, tank, or container within the spill containment area and shall be capable of preventing the release of the applicable liquid dry- cleaning solvent beyond the spill containment area for a period of at least 72 hours. All floor drains within or beneath the spill containment area shall be removed or permanently sealed with materials impervious to dry-cleaning solvents. Emergency adsorbent spill clean-up materials shall be on the premises. Facilities must maintain an emergency response plan that is in compliance with federal, 'state and local requirements. (3) All perchloroethylene dry-cleaning machines installed at a dry-cleaning facility after the effective date of this Rule shall meet air emissions that equal or exceed the standards that apply to a comparable dry -to -dry perchloroethylene dry-cleaning machine with an integrated refrigerated condenser. All perchloroethylene dry-cleaning facilities must be in compliance with the EPA Perchloroethylene Dry Cleaner NESHAP: 40CFR, Part 63, Subpart M to be eligible for certification. (4) Facilities that use perchloroethylene shall use a closed container solvent transfer system by January 1, 2002. (5) No dry-cleaning facility shall use underground storage tanks for solvents or waste. DSCA ARAvO705 Attachment 2 .A F '�ftl- SUII Rno NCDENR North Carolina Department of Environment and Natural Resource Division of Purchase and Services Michael F. Easley, Governor Michael G. Bryant, Director William G. Ross Jr., Secretary MEMORANDUM TO: Genna K. Olson ATC Associates of North Carolina, P.C. 2725 East Millbrook, Suite 121 Raleigh, NC 27604 FROM: ❑oIan Simmons S Section Chief T Office Property and Services Division of Purchase and Services DATE: September 10, 2498 SUBJECT: N09401 S ❑SCA Program Environmental Service Contract Enclosed please find (1) fully executed duplicate original of the contract N09001S between ATC Associates of NC, P.C., and the Department of the Environment and Natural Resources in the amount of $6,000,000. If you have any questions, please contact me at 919,715.3877. Thank you. DS:meb Enclosures Cc: Jackie Moore, Office of the Controller, (wlenc.) ❑elonda Alexander, Division of Waste Management One Nofth(arofina ,naturally 1645 Mail Service Center, Raleigh, North Carolina 27699-1605 Phone: 919-733-97461 FAX: 919-715-0684 l Internet: www.admin.enr.state.nc.us/purchase/ An Equal Opportunity I AMrmafve Action Employer — 50% Recycled 110% Post Consumer Paper STATE OF NORTH CAROLINA CONTRACT NO. COUNTY OF WAKE CONTRACTOR'S FEDERAL ID NO.: 46-0399408 THIS AGREEMENT ("AGREEMENT") is made and entered into by and between ATC Associates of North Carolina, P.C. a Corporation incorporated in North Carolina with an address of 2725 E. Millbrook Rd, Suite 121, Raleigh North Carolina., 277604, hereinafter referred to as "CONTRACTOR," and the North Carolina Department of Environment and Natural Resources, hereinafter referred to as "DEPARTMENT." WITNESSETH: WHEREAS, the DEPARTMENT is charged with the responsibility of controlling pollution of the underground waters of the State; and WHEREAS, the DEPARTMENT is responsible for administering the Dry -Cleaning Solvent Cleanup Act of 1997, as amended, Part 5, Article 21 A, Chapter 143, N.C.G.S. § 143-215.1 04A et seq. ("DSCA"); and WHEREAS, the CONTRACTOR has exhibited evidence of experience, ability, competence and reputation to perform environmental engineering services at contaminated dry-cleaning facility sites; and WHEREAS, the CONTRACTOR entered a competition to perform certain investigative and/or remedial activities related to contamination resulting from the release of dry-cleaning solvents into the environment at various dry-cleaning facility sites (hereinafter "site(s)") in the State of North Carolina; and WHEREAS, the DEPARTMENT recommended, and on July 22, 2408, the State Building Commission selected, the CONTRACTOR to perform certain investigative and/or remedial activities related to contamination resulting from such sites in the State of North Carolina. NOW, THEREFORE, for and in consideration of the mutual promises to each other, as hereinafter set forth, the parties hereto do mutually agree as follows: 1. The CONTRACTOR hereby, agrees to provide, to the satisfaction ofthe DEPARTMENT, and as authorized on a task order/costs-not-to-exceed basis, professional services to assess and remediate sites and, where necessary, to provide potable water at various sites. Services may include, but are not limited to the following: A. Preparation of site -specific work plans (including technical proposals and cost estimates) for specific technical tasks. B. Review of site files, background data collection, site reconnaissance, property ownership determination, right -of -entry acquisition and receptor surveys. C. Emergency response activities (e.g., containment or recovery of spilled product, emergency vapor recovery, provision of potable water, installation of point -of -entry treatment systems, emergency water line hook-ups, boom maintenance for surface spills, etc.). D. Coordination and oversight of initial remedial actions such as the excavation and treatment and/or disposal of contaminated soil, tank cleaning/decontamination (including the removal and disposal of tank contents and tanks), in -situ tank closure, and the recovery and disposal of free product. Page I of 10 E. Various hydrogeologic assessment activities, including well installation; groundwater and surface water sampling; soil sampling; aquifer testing; pilot testing; expanded contaminant source inventories; human exposure assessments (evaluation of site -specific risks to potential receptor populations from site -related contamination); and other tasks related to comprehensive assessment of soil and groundwater contamination at designated sites. F. Coordination and oversight of various alternate water supply systems, and design and implementation of various strategies for the provision of long-term alternate water supplies to affected residents at designated sites; evaluation of alternatives to include an assessment of the technical feasibility and cost-effectiveness of preferred alternatives; said alternatives to include new wells, paint -of -entry carbon treatment systems, and extension of public water lines. G. Management and oversight of specialty and engineering subcontractors, vendors or CONTRACTOR personnel involved in the installation, operation., and maintenance of various remedial systems at designated sites. H. Preparation and submittal of all required permit applications for the construction ofwells and the construction and operation of various remedial systems at designated sites as may be required by the DEPARTMENT or another governmental agency, including, but not limited to, monitoring well, injection well, NPDES, non -discharge, and air quality permit applications. I. Preparation of site -specific remedial action plans, providing an evaluation of various remedial alternatives for soil and groundwater contaminated sites, including an assessment of the technical feasibility and cost effectiveness of preferred alternatives and the preparation of design drawings and bid documents for various remedial systems. J. Implementation of site -specific remedial action plans, including management and oversight of all phases of site remediation. K. Preparation and implementation of site -specific health and safety plans, including health and safety training for hazardous wastes sites, under the supervision of a qualified health and safety officer, so as to ensure compliance with all applicable OSHA regulations for worker safety and to protect the health and safety of nearby residential and business communities during all phases of site assessment and remediation. L. Preparation and submittal of all required or requested reports or summaries, and any miscellaneous documentation as requested by the DEPARTMENT or Contract Administrator according to schedule(s) agreed to by both parties. M. Providing upon request technical and administrative support to the DEPARTMENT in furtherance of its efforts to provide for public participation in remedial decisions at DSCA sites; such support to include as -needed attendance of key CONTRACTOR personnel at public hearings or public meetings to discuss elements of proposed remedial action plans. Also, providing upon request technical support and administrative support in meetings and rulemaking proceedings, and technical support and expert testimony in litigation related to DSCA where the DEPARTMENT is a party to the litigation. N. Special Conditions: Specific CONTRACTOR tasks to be performed under this AGREEMENT shall be authorized on a task order/costs-not-to-exceed basis following submittal of site specific and task -specific work plans by the CONTRACTOR; no task shall be initiated by the CONTRACTOR until written authorization has been received from the Page 2 of 10 DEPARTMEN'T's Contract Administrator (or his duly authorized staff). The DEPARTMENT will only reimburse pre -approved activities and costs. ii. Unless provided otherwise in the DEPARTMENT's written guidelines and related instructional bulletins, work plans for task and cost approval must include a description of site -specific conditions and information relevant to the proposed activities, a description of the proposed site activities, a description of procedures which will be used to manage waste generated as a result of the activities, a proposed schedule for conducting and reporting on site activities, the estimated cost of conducting the proposed activities, and any other relevant information requested by the DEPARTMENT. iii. The DEPARTMENT will determine task -specific costs according to the Fee Schedule, attached to this AGREEMENT as Attachment 1 and incorporated herein by reference. The unit prices as shown in the Fee Schedule shall be fixed for a period of 36 months from the effective date ofthis AGREEMENT and may be re -negotiated after this period has passed. For cost items not shown on the Fee Schedule, the CONTRACTOR will obtain quotes, or otherwise provide supplemental unit rate pricing, as requested by the DEPARTMENT to ensure standard industry rates are being proposed. iv. Task authorizations and pre -approved costs may be adjusted by the DEPARTMENT's Contract Administrator (or his duly authorized staff). If the CONTRACTOR seeks an adjustment of a previously approved task order or pre -approved costs, the CONTRACTOR must make the request for adjustment prior to completion of the task for which the adjustment is sought; requests for adjustment must be made in writing and demonstrate the need for the adjustment. The CONTRACTOR may orally request the adjustment, provided the CONTRACTOR submits a written request and j ustification for the adjustment within 24 hours of the DEPARTMENT'S oral approval. If CONTRACTOR'S written request and justification are submitted after the DEPARTMENT'S oral approval of the request, the DEPARTMENT reserves the right to determine, after review of the written request for adjustment, that the requested adjustment was not warranted and withdraw its approval of the request. v. In providing services to the DEPARTMENT under this AGREEMENT, the CONTRACTOR is responsible for ensuring that only qualified and trained personnel will be assigned by the CONTRACTOR to perform tasks approved by the DEPARTMENT. A description of qualifications generally expected ofparticular levels of personnel, and work tasks typically performed at each level, is attached to this AGREEMENT as Attachment 2 and incorporated herein by reference. vi. The CONTRACTOR shall not substitute key personnel assigned to the performance of this AGREEMENT without prior approval by the Contract Administrator or his designated agent. The following individuals are designated key personnel for purposes of this AGREEMENT: (See Attachment 3). vii. In providing services to the DEPARTMENT under this AGREEMENT, the CONTRACTOR is responsible for complying with all applicable local, State and federal laws and regulations. viii. The CONTRACTOR shall be responsible for securing a source of clean water for equipment decontamination, including steam cleaning and other equipment decontamination procedures associated with drilling and other activities; ix. The CONTRACTOR shall be responsible for conducting an underground utilities search and mark -out at the site prior to initiating any intrusive investigations, including excavation and drilling activities; Page 3 of 10 x. The CONTRACTOR shall protect and prevent damage to the sites and surrounding lands. To the extent practicable, the CONTRACTOR shall return the site and any affected surrounding lands, including any disturbed or damaged areas, to their original condition. The CONTRACTOR shall be responsible for backfilling all borings and properly abandoning wells at the site in accordance with all applicable local, State and federal laws and regulations and DEPARTMENT guidance. 2. DEPARTMENT hereby agrees to compensate the CONTRACTOR for professional services rendered under this AGREEMENT. The total compensation paid for all work under this AGREEMENT shall not exceed six million dollars ($6,000,000.00). The DEPARTMENT, however, does not guarantee any minimum number of tasks to be performed under this AGREEMENT and therefore does not guarantee any amount of compensation. It is understood and agreed between the CONTRACTOR and the DEPARTMENT that all payments to the CONTRACTOR under this AGREEMENT are expressly contingent upon the availability of monies in the Dry -Cleaning Solvent Cleanup Fund. 3. The DEPARTMENT will compensate the CONTRACTOR for work performed under this Agreement when: (1) CONTRACTOR has completed the work authorized by the DEPARTMENT, provided that CONTRACTOR may request partial payment as frequently as once a month for tasks completed as of the date of the request, if the total amount invoiced is greater than $1,000.00; (2) CONTRACTOR has requested payment and submitted an invoice and all required and requested documentation to the DEPARTMENT; and (3) the DEPARTMENT determines that the CONTRACTOR has completed the work to the satisfaction of the DEPARTMENT and all necessary documentation of the work performed and costs incurred have been received. The DEPARTMENT will compensate the CONTRACTOR as expeditiously as possible in an amount not to exceed the amount authorized in the approved work order. 4. Requests for payment shall be in the form of an itemized invoice from the CONTRACTOR to the DEPARTMENT with the following documents attached: (1) a technical progress report, which should include a description of the work performed and all activities and costs covered by the invoice, a list of any deliverables submitted to the DEPARTMENT during the period covered by the invoice, and a description of any difficulties encountered and remedial actions taken; (2) if CONTRACTOR is requesting partial payment (for tasks completed under an approved work order where the invoiced amount exceeds $1,000.00), the CONTRACTOR should also include in the technical progress report a list of work scheduled during the next period and any anticipated deliverables during the next period; (3) all receipts for costs covered by the invoice; (4) a copy of the work authorization under which work was performed during the period covered by the invoice; (5) a copy of any amendment(s) to the work authorization; and (6) any other documentation requested by the DEPARTMENT. Payments may be delayed if the invoice or attachments to the invoice contain errors or inadequate back-up detail for individual cost items. 3. The CONTRACTOR shall comply with all applicable local, State and federal laws and regulations, and DEPARTMENT policies and guidance when managing, either directly or through the use of subcontracted firms, companies, or individuals, waste produced at a DSCA site. The duty to properly manage waste shall include all waste generated at a DSCA site, including both hazardous waste and non -hazardous waste, and shall further include but not be limited to investigation - derived waste and remedial waste resulting from remediation activities. In addition to the requirements contained in applicable local, State and federal laws and regulations, and DEPARTMENT policies and guidance, the CONTRACTOR shall ensure compliance with the following requirements: A. The CONTRACTOR shall prepare all required hazardous and non -hazardous waste manifests and labels. Page 4 of 10 B. When preparing a manifest for waste produced at a DSCA site that is subject to an Agreement for Assessment and Remediation between the DEPARTMENT and person(s) who have petitioned for certification of the site into the DSCA program ("DSCA Petitioner(s)"), the CONTRACTOR shall identify the DSCA Petitioner(s) as the generator of the waste. The CONTRACTOR shall sign the manifest with CONTRACTOR representative's name followed by the wording "on behalf of DSCA Petitioner(s) for DSCA Site No. [insert assigned site number]." C. When preparing a manifest for waste produced at a DSCA site for which there is no DSCA Petitioner, the CONTRACTOR shall identify the DSCA Program as the generator of the waste, and sign each manifest with CONTRACTOR representative's name followed by the wording "on behalf of the: DSCA Program." D. When transporting waste generated at a DSCA site, the CONTRACTOR shall use only licensed and bonded transporters who have all applicable permits under local, state, and federal laws and regulations, and who have an EPA Identification No. E. The CONTRACTOR shall offer waste generated at a DSCA site only to those facilities, which are authorized to accept, store, treat and/or dispose of such waste, and which have all applicable permits under local, state, and federal laws and regulations for such storage, treatment or disposal. F. The CONTRACTOR shall include in each work plan for task authorization submitted to the DEPARTMENT, an estimate of the types and quantities of waste to be produced from proposed site activities, the types ofcontainers the CONTRACTOR proposes to use to containerize the waste, and estimates of the costs to properly containerize, label, sample, analyze, manifest, transport, store, treat or dispose the wastes. The work plan proposal must present the names, locations, waste profiling requirements, and applicable permits of the anticipated waste transportation and receiving facilities that will be used to manage the waste. G. The CONTRACTOR shall place waste generated during site investigation or monitoring activities ("investigation -derived waste") in appropriate containers as soon as the waste is generated. H. Unless other arrangements can be made by the CONTRACTOR that are approved by the DEPARTMENT, the CONTRACTOR shall: 1] coordinate and meet with transporters on site on the day that waste containerization activities are completed to verify that the drums are properly labeled, identified on the waste manifests, and loaded by the appropriate waste transporter(s) prior to the containers being transported from the site to the waste receiving facility; and 2) ensure that drums containing investigation -derived waste are removed from the site and transported to a waste receiving facility as soon as waste containerization and sampling activities are completed. The containers will be held at the waste receiving facility pending receipt of waste sample laboratory analytical results in a final decision on waste disposal. The waste receiving facility must be permitted to temporarily hold the containers for a minimum of ten (10) days from the date that the containers were collected from the site by the waste transporter. The CONTRACTOR must notify the DEPARTMENT prior to any transportation of the waste from the receiving facility until the waste is ultimately disposed. I. The CONTRACTOR will ensure that each roll -off container used to containerize investigation -derived waste is properly labeled and secured on the site pending the CONTRACTOR'S receipt of waste sample laboratory analytical results and a final decision on waste disposal. Within five (5) working days of receipt of laboratory analysis results, the CONTRACTOR shall coordinate and meet with transporters on -site to verify that appropriate labels have been placed on the roll -off container and the Page 5 of 10 container is identified on a waste manifest, and to confirm the designation of waste facility permitted to store, treat or dispose of the waste. The CONTRACTOR must notify the DEPARTMENT prior to any transportation of the waste from the receiving facility until the waste is ultimately disposed. J. The CONTRACTOR shall instruct facilities receiving any waste containers (drums or roll -off containers) from DSCA sites that the information provided on container labels and associated manifests must not to be altered without prior written authorization and approval from the DEPARTMENT. K. The CONTRACTOR shall provide a copy of all waste sample laboratory analytical results to the DEPARTMENT and to each facility receiving waste from the site. In each instance, a copy shall be provided (electronic transmission or facsimile is permitted) within two (2) working days of CONTRACTOR'S receipt of the results from the laboratory. L. The CONTRACTOR shall provide to the DEPARTMENT copies of each completed waste manifest, associated transport, storage, disposal or treatment weight tickets, disposal certifications and associated invoices and receipts for the waste listed on each manifest. The copies shall be provided to the DEPARTMENT within ten (10) working days of receipt of the documentation showing final disposition of the waste. M. The procedures for the management of remedial waste resulting from remediation activities at DSCA sites, including treatment and disposal options, will be developed following the adoption of risk -based rules establishing cleanup requirements at DSCA sites. 6. In the event that the CONTRACTOR subcontracts for any or all of the services or activities covered by this AGREEMENT, the CONTRACTOR AGREES that: (a) CONTRACTOR is not relieved of any of the duties and responsibilities provided in this AGREEMENT; (b) CONTRACTOR will require that the subcontractor abide by the standards contained herein or provide such information as to allow the CONTRACTOR to comply with these standards; and (c) CONTRACTOR will require that the subcontractor agree to allow the DEPARTMENT access to any records pertinent to the subcontractor's work on the site. The DEPARTMENT will not be responsible for any acts or omissions of any subcontractor. 7. During the term of this AGREEMENT, the CONTRACTOR at its sole cost and expense shall provide commercial insurance of such type and with such terms and limits as may be reasonably associated with this AGREEMENT. Providing and maintaining the adequate insurance coverage is a material obligation of the CONTRACTOR and is of the essence of this AGREEMENT. All such insurance shall meet all laws of the State of North Carolina. Such insurance coverage shall be obtained from companies that are authorized to provide such coverage and authorized by the Commissioner of Insurance to do business in North Carolina. The CONTRACTOR shall at all times comply with the terms of such insurance policies, and all requirements of the insurer under any such insurance policies, except as they may conflict with existing North Carolina laws. The limits of coverage under each insurance policy maintained by the CONTRACTOR shall not be interpreted as limiting the CONTRACTOR'S liability and obligations under this AGREEMENT. The insurances required in this paragraph shall cover all losses incurred during the term of this AGREEMENT, irrespective of when a claim is made. As a minimum, the CONTRACTOR shall provide and maintain the following coverage and limits: A. Worker's Compensation - The CONTRACTOR shall provide and maintain Worker's Compensation Insurance, as required by the laws of North Carolina, as well as employer's liability coverage with minimum limits of $150,000.00, covering all of CONTRACTOR's employees who are engaged in any work under this AGREEMENT. If any work is sublet, the Page 6 of 10 CONTRACTOR shall require the subcontractor to provide the same coverage for all subcontractor employees engaged in any work under this AGREEMENT. B. Commercial General Liability -General Liability Coverage on a Comprehensive Broad Form on an occurrence basis in the minimum amount of $1,000,000.00 Combined Single Limit. (Defense cost shall be in excess of the limit of liability.) C. Professional Liability (Errors and Omissions) - CONTRACTOR shall obtain, at CONTRACTOR's expense, and keep in effect, errors and omissions insurance covering any damages caused by an error, omission or any negligent acts of CONTRACTOR, its subcontractors, agents, officers, or employees under this AGREEMENT. Combined single limit per occurrence shall not be less than $1,000,000.00. Annual aggregate limit shall not be less than $2,000,000.00. D. Automobile - Automobile Liability Insurance, to include liability coverage, covering all owned, hired and non -owned vehicles, used in connection with this AGREEMENT. The minimum combined single limit shall be $150,000.00 bodily injury and property damage; $150,000.00 uninsured/under insured motorist; and $1,000 medical payment. 8. The term of this AGREEMENT shall be three years from its effective date. This AGREEMENT may be extended for a period of two years, if mutually agreeable to both parties and if the CONTRACTOR'S performance to date has been satisfactory to the DEPARTMENT, provided that sufficient funding exists. The sum of payments made by the DEPARTMENT to the CONTRACTOR, for work authorized by the DEPARTMENT on atask order/cost-not-to-exceed basis, shall not exceed four million dollars ($4,000,000.00) for the 2-year agreement extension. period. 9. The CONTRACTOR shall ensure that work performed under this AGREEMENT shall be undertaken and completed in such sequence as to assure its expeditious completion in light of the purposes of this AGREEMENT. If completion of any portion of the work is delayed for causes beyond the control of and without the fault of the CONTRACTOR., and for reasons which could not have been reasonably avoided or anticipated by the exercise of due care and prevention, the time of performance of the work will be extended for a period equal to the delay. Excusable delays shall include, without limitation, acts of God or the public enemy; acts of federal, state, local, or foreign governments; acts of DEPARTMENT's agents; fixes, floods, epidemics; strikes; riots; freight embargoes; and unusually severe weather affecting the progress of work at the site. Such delays shall not be the result of labor or equipment shortages. 10. The DEPARTMENT may terminate this AGREEMENT at any time for any reason satisfactory to the DEPARTMENT by giving five days prior notice in writing to the CONTRACTOR of such termination and specifying the reason(s) thereof and the effective date thereof. In that event, all finished or unfinished documents, data, studies, surveys, drawings, maps, models, photographs, reports and other materials prepared by the CONTRACTOR shall, at the option of the DEPARTMENT, become the DEPARTMENT's property. The CONTRACTOR shall be entitled to receive just and equitable compensation for any satisfactory work completed on such documents and other materials. The CONTRACTOR shall not be relieved of liability to the DEPARTMENT for damages sustained by the DEPARTMENT by virtue of any breach of this AGREEMENT, and the DEPARTMENT may withhold payment to the CONTRACTOR for the purpose of set off until such time as the exact amount of damages due the DEPARTMENT from such breach can be determined. In case of default by the CONTRACTOR., the DEPARTMENT may procure the articles or services from other sources and hold the CONTRACTOR responsible for any excess cost occasioned thereby. The CONTRACTOR may not terminate this AGREEMENT except in the event of a breach of this AGREEMENT by the DEPARTMENT. 11. If the AGREEMENT is terminated by the DEPARTMENT as provided herein, the DEPARTMENT will compensate the CONTRACTOR for work completed, subject to the Page 7 of 10 DEPARTMENT'S right to withhold payment for the purpose of set off. All final invoices shall be submitted by the CONTRACTOR to the DEPARTMENT within 30 days of agreement termination. The CONTRACTOR shall repay to the DEPARTMENT any compensation the CONTRACTOR has received which is in excess of the payment to which the CONTRACTOR is entitled herein. 12. The CONTRACTOR shall ensure that all documents produced as a result of this AGREEMENT are printed double -sided on recycled paper. Figures, maps, design drawings, colored prints and related specialty printings are excluded from this requirement. 13. Any information (i.e., data, documents, statistics, surveys, studies, reports, addresses of property owners, etc.) given to or prepared or assembled by the CONTRACTOR under this AGREEMENT shall be kept as confidential and not divulged or made available to any individual or organization without the prior written approval of the DEPARTMENT. No reports, maps, or other documents produced in whole or in part under this AGREEMENT shall be the subject of an application for copyright by or on behalf of the CONTRACTOR. 14. Information provided to, prepared or assembled by the CONTRACTOR under this AGREEMENT shall not be used to promote, market or offer the CONTRACTOR's services. The CONTRACTOR agrees not to use the existence of this AGREEMENT or the name of the State ofNorth Carolina or any agency thereof as part of any commercial advertising. 15. The CONTRACTOR may not assign this AGREEMENT or its obligations hereunder except as permitted by 9 NCAC 065.1003 and this paragraph. The CONTRACTOR shall provide the DEPARTMENT with written notice of not less than thirty (30) days prior to any consolidation, acquisition, or merger. Any assign shall affirm this AGREEMENT according to the terms and conditions agreed, and the CONTRACTOR shall affirm that the assignee is fully capable of performing all of CONTRACTOR'S obligations under the AGREEMENT. All assignments shall be in writing setting forth the obligations of the CONTRACTOR and ofthe assignee, signed by the DEPARTMENT, the CONTRACTOR and the assignee. 16. This AGREEMENT is made under and shall be governed and construed in accordance with the laws of the State of North Carolina. It is agreed between the parties hereto that the place of this AGREEMENT, its situs and forum, shall be Wake County, North Carolina., and in said County and State shall all matters, whether sounding in contract or tort relating to the validity, construction, interpretation and enforcement of this AGREEMENT, be determined. 17. The CONTRACTOR agrees that in all matters relating to this AGREEMENT, it shall be acting as an independent contractor and not as an employee of the DEPARTMENT. The CONTRACTOR represents that it has, or will secure at its own expense, all personnel required in performing the services under this agreement. The CONTRACTOR shall be wholly responsible for the work to be performed and for the supervision of its employees. Nothing in this AGREEMENT shall be construed to create a joint venture or partnership between the CONTRACTOR and the DEPARTMENT. 18. The CONTRACTOR agrees that the State has the right to audit the records of the CONTRACTOR pertaining to this AGREEMENT both during performance and for 36 months after completion or termination. The CONTRACTOR must retain all records relating to this AGREEMENT and shall allow employees or agents of the DEPARTMENT to inspect such records during the period of time set out herein. The State Auditor shall have access to persons and records as a result of all contracts or grants entered into by State agencies or political subdivisions in accordance with N.C.G, S. § 147-64.7. 19. The CONTRACTOR agrees that any and all non -expendable equipment that is purchased for a site with DSCA or DEPARTMENT funds will be the property of the DEPARTMENT and will remain at that site until the DEPARTMENT deems necessary to dispose, remove, or relocate the equipment to another site or holding facility. Page 8 of 10 20. The CONTRACTOR agrees that he shall be responsible for the proper custody and care of any DEPARTMENT -owned property fiimished him for use in connection with the performance ofthis AGREEMENT and will reimburse the State for its loss or damage, excluding normal wear. 21. This AGREEMENT represents the entirety of the agreements and covenants between the DEPARTMENT and CONTRACTOR with respect to the subject matter hereof and accordingly cannot be amended or modified except by written instrument executed by the parties hereto. 22. The CONTRACTOR has no authority to act or make any representations on behalf of the DEPARTMENT. 23. The CONTRACTOR warrants that its performance will not infringe the copyright, patent or other property rights of any other person. 24. The CONTRACTOR shall indemnify and save and hold harmless the DEPARTMENT, its officers, agents and employees, from liability of any kind, including all claims and losses accruing or resulting to any person, firm or corporation furnishing or supplying work, services, materials or supplies in connection with the performance of this AGREEMENT, and from any and all claims and losses accruing or resulting to any person, firm or corporation that may be injured or damaged by the CONTRACTOR in its performance of this AGREEMENT. The CONTRACTOR represents and warrants that it shall not make claims of any kind or nature against the DEPARTMENT or the DEPARTMENT's officers, agents and employees who are involved in the delivery or processing of CONTRACTOR goods to the DEPARTMENT. The provisions of this paragraph shall survive the termination or expiration of this AGREEMENT. 25. The DEPARTMENT does not waive its sovereign immunity by entering into this AGREEMENT and fully retains all immunities and defenses provided by law with respect to any action based on this AGREEMENT. 26. The parties certify and warrant that no gratuities, kickbacks or contingency fee(s) were paid in connection with this AGREEMENT, nor were any fees, commissions, gifts or other considerations made contingent upon the award of this AGREEMENT. 27. The CONTRACTOR certifies that it (a) has neither used nor will use any funds or compensation earned under this AGREEMENT for payments to lobbyists; (b) will disclose the name, address, payment details and purpose of any agreement with lobbyists whom CONTRACTOR or its subtier contractor(s) or subgrantee(s) will pay with profits or nonappropriated funds on or after December 22, 1989, and (c) will file quarterly updates about the use of lobbyists if material changes occur in their use. 28. The CONTRACTOR certifies that it is in compliance with the Assurances -Non Construction Programs, attached to this Agreement as Attachment 4 and incorporated herein by reference. 29. The CONTRACTOR will take affirmative action in complying with all Federal and State requirements concerning fair employment and employment of people with disabilities, and concerning the treatment of all employees without regard to discrimination by reason ofrace, color, religion, sex, national origin or disability. The Americans with Disabilities Act (ADA) makes it unlawful to discriminate in employment against a qualified individual with a disability and outlaws discrimination against individuals with disabilities in State and local government services and public accommodations. The CONTRACTOR certifies that it and its principals and subcontractors will comply with regulations in ADA Title I (Employment), Title II (Public Services), and Title: III (Public Accommodations) in fulfilling the obligations under this AGREEMENT. 30. Peter Doom is designated as the Contract Administrator (project coordinator) for the DEPARTMENT. However, any changes in the scope of the AGREEMENT that will increase or Page 9 of 10 decrease the total amount of compensation which may be paid under this Agreement shall not be effective until the changes have been approved by the Secretary of the DEPARTMENT or his Authorized Agent. 31. The CONTRACTOR will perform its services using that degree of skill and care ordinarily exercised under similar conditions by reputable members of CONTRACTOR's profession. 32. The effective date of this AGREEMENT shall be the date on which it is executed by the Secretary of the Department or his Authorized Agent. IN WITNESS WHEREOF, the CONTRACTOR and the DEPARTMENT have executed this AGREEMENT in duplicate originals, one of which is retained by each of the parties, the day and year first above written. ATC Associates of North Carolina, P.C. 2725 E. Millbrook Road Suite 121 Raleigh, NC 27604 North Carolina Department of Environment and Natural Resources William G. Ross, Jr,, Secretary By: By`L, (CONTRACTOR'S Signature) Signature of Secretary or Authorized Agent) Date: 41 - a �f Yl (Yl �. �S Wypedame} Title• i (Owner, Partner, Corp. Pres., or V_ Pres. Only) Date: W N (Sign,, �L �dfliSlAiq - �N�C] Page 10 of 10 ATTACHMENT 1 FEE SCHEDULE Personnel Principal Level Senior Level Project Level Staff Level CAD Level Technician Word Processor Subcontractor Management Fees Laboratory Waste Hauling and Disposal Drilling Remediation Bids $1151hour $951hour $80/hour $651hour $50/hour $501hour $40/hour 10% 10% for costs less than $100,000; 5% for costs greater than or equal to $100,000 15% 15% for costs less than $100,000; 10% for costs greater than or equal to $100,000 and less than $200,000; 5% for costs greater than or equal to $200,000 At, Ieast. 2 bids may be required by the DEPARTMENT`s Contract Admiiustrator (or his duly authorized staff) for subcontracted activities that exceed $3,000. Laboratory EPA Method 8260 (soil) $931sample EPA Method 8260 (water) $931sample EPA Method 8270 — Base Neutral Extractables only (soil) $1611sample EPA Method 8270 — Base Neutral Extractables only (water) $1611sample Miscellaneous Per Diem (per person for overnight travel only) $92 Mileage (car or truck) $0.585lmiie Organic Vapor Analyzer $1101day PfUConductivity Meter $251day Page 1 of 2 FEE SCHEDULE Miscellaneous (continued) Interface Probe Electric Water Level Indicator Teflon Bailer Disposable Bailer Stainless Steel Auger Grundfos Pump Survey Equipment Drum Personal Protective Equipment Level B Level C Consumables (include tape, gloves, ice) Maps, Photos Camera Cell Phone ATTACHMENT 1 $301day $251day $201day $S $101day $501day $30/day $40 $301day $201day $20/day Cost Not Reimbursable Not Reimbursable Page 2 of 2 ATTACHMENT 2 PERSONNEL QUALIFICATIONS AND TASK DESCRIPTIONS The following qualifications and task descriptions are for those personnel who will be involved in activities for the Dry -Cleaning Solvent Cleanup Act (DSCA) Program contracts. PERSONNEL AND QUALIFICATIONS TASK DESCRIPTIONS Principal Engineer/Geologist/Hydrogeologist/Scientist ($115/hour) Administrative and/or professional head of the organization or contract. Responsible for conceiving - Expert Testimony and executing plans and firncdons of the organization. Directs the professional staff Normally has a - Legal Strategies financial interest in the company as partial owner, major investor or stockholder, or officer. Charges an - Depositions extremely limited number of hours per site as the Principal. This position should never bill field or field - Contract Oversight (limited) supervision hours. Senior Engineer/Geologist/Hydrogeologist/5cientist ($95/hour) Typically requires an advanced degree. Requires professional registration when applicable, $ years of _ Expert Testimony experience in technical or managerial roles, and compliance regulations. Serves as senior technical . Site strategy and planning leader and contract oversight for environmental remediation projects of medium to large scope and /or _ Contract oversight complexity and has developed substantial expertise in the field of practice. Generally supervises _ Reviews technical reports Project Managers and oversees several projects. Has limited involvement in projects. Duties typically _ Reviews Corrective Action Plans include reviewing reports, developing strategies, and attending client and/or DSCA Program meetings. _ Reviews Engineering/remedial system design Responsible for approving designs, reports, plans, and specifications before submittal to the DSCA _ Health and safety coordinator Program. If significantly involved in a highly technical project, should have substantial technical _ Reviews site safety plans expertise directly related to the project Ensures compliance of field service operations with OSHA safety standards. Addresses public health concerns. I - Project management - Site strategy and planning Project Engineer/GeologistlHydrogeologist/Scientist (S$0/hour) - Develop site health and safety plans Typically possesses a bachelor of science degree in engineering, geology, hydrogeotogy, or a directly - Engineering/remedial system design related field. Serves as manager far entire project and has at least 5 years of experience in the - Data review and analysis environmental field. Duties typically include preparing proposals, reviewing reports, developing - Report preparation (limited) strategies, and attending client and/or DSCA Program meetings. Under general supervision, prepares -Report review environmental design and plan specifications for site remedial activities, Leads and supervises teams of - Site meetings and reconnaissance staff and technician level personnel, but would have a limited number of hours charged to each site, -On-site supervision (periodic) and only a small percentage of total field hours. Serves as site technical expert or supervisor for - Work plan preparation hydrogeological site characterizations and remediation activities and tests, and assembly of reports, - Site investigation planning plans, and specifications. - Field work planning - Site Inspection (periodic) - Obtains permission for of -site access Staff Engineer/Geologist/Hydrogeologist/Scientist ($65/hour) Requires a bachelor's degree in engineering, geology, hydrogeology, or related science and I to 5 years - Report preparation of experience in the environmental field. Works under supervision of the project manager to perform - Field work preparation/planning routine tasks related to environmental investigation and remediation projects. Is the primary person - Supervises site investigation and remediation activities responsible for gathering field data and is competent at data analysis. Mum be able to conduct - Site reconnaissance and mapping investigation and remedial activities including drilling and monitoring well installation, sampling, site - Engineering/remedial system design and installation layout and geologic mapping writing field notes, basic analysis and compiling data, Must have - Limited data review and analysis knowledge of QA/QC procedures and protocol. This position will normally be highest in the number of - Obtains pemtission for off -site access hours billed to on -site wo& however, technicians (see below) should conduct routine or on -going - On -site health and safety supervisor monitoring Technician ($50/hour) - Fieldwork preparation - Operation and maintenance of equipment Typically requires a high school diploma, certified or licensed trades -person, or an associate's degree. ' Well developing and sampling Person may also have a bachelor's degree with less than I year of experience in the environmental - Sail sampling field. Requires minimal training and experience in the environmental field. Responsible for general - Handling of investigation and remediation derived wastes supervision of the installation, maintenance, and repair of on -site equipment. Routine monitoring and _ Remedial system installation, operation, and maintenance collection of samples and equipment maintenance/operating logs. Under appropriate supervision, _ Limited contractor supervision performs routine labor tasks associated with on -site installation, maintenance, and repair of on -site _ Monitoring activities equipment. Well development and collects soil and groundwater samples. - Surveying using GPS and standard methods Draftsperson/CAD ($50/haur) -Drafting Typically requires a high school diploma Requires 2 — & years of experience or 2 years of related - CAD/CARD work college and more than I year of experience. Generally requires a Technical Drawing Certificate, and - Cartography advanced draftg skills such as Computer Aided Drafting (CAD) & Design (CARD) operations. - Plotting of GPS and standard survey data - Spreadsheets - Report generation Word Processor/Clerical ($40/hour) - Word processing Operates Computer for work processing, spreadsheets, and statistical typing, correspondence report - Typing generation, general office work, typing, and filing. - Filing - General secretarial - Document reproduction I : .1u 1 ►M. KEY PERSONNEL FOR THIS AGREEMENT ATC Associates of North Carolina, P.C. Pro ram Manager — Genna K. Olson, P.G. (Raleigh, NC office) Principal in Char2c En inter — Kevin R. Sommers, P.E. (Raleigh, NC office) Principal in Charge Geologist — Paul J. Warmus, P.G. (Raleigh, NC office) Project Manager — Kurt H. Ness, P.G. (Raleigh, NC office) Pro iect Manager— Gabriel Amos, P.E. (Raleigh, NC office) Pro iect Manager -- Stephen Aldis, P.G. (Charlotte, NC office) Pr Ject Manager— S. Eric Shertzer, P.G. (Virginia Beach, VA office) Project Manager — Santiago Vila, P.G. (Raleigh, NC office) Health & Safety Officer — Jeffrey Corson (Raleigh, NC office) Page 1 of 1 ATTACHMENT 4 ASSURANCES — NON CONSTRUCTION PROGRAMS The CONTRACTOR certifies that with regard to: 1. DEBARMENT AND SUSPENSION - To the best of its knowledge and belief that it and its principals: (a) are not presently debarred, suspended, proposed for debarment, declared ineligible, or voluntarily excluded from covered transactions by any Federal or State department or agency; (b) have not within a 3-year period preceding this Agreement been convicted of or had a civil judgment rendered against them for commission of fraud or a criminal offense in connection with obtaining, attempting to obtain, or performing a public (Federal, State, or local) transaction or contract under a public transaction; violation of Federal or State antitrust statutes or commission of embezzlement, theft, forgery, bribery, falsification or destruction of records, making false statements, or receiving stolen property; (c) are not presently indicted for or otherwise criminally or civilly charged by a governmental entity (Federal, State, or local) with commission of any of the offenses enumerated in paragraph (1)(b) of this certification; and (d) have not within a 3-year period preceding this Agreement had one or more public transactions (Federal, State, or local) terminated for cause of default. 2. LOBBYING - To the best of its and its principals' knowledge and belief, that: (a) no Federal appropriated funds have been paid or will be paid, by or on behalf of the undersigned, to any person for influencing or attempting to influence an officer or employee of any agency, a Member of Congress, an .officer or employee of Congress, or an employee of a Member of Congress in connection with the awarding of any Federal contract, the making of any Federal grant, the making of any Federal loan, the entering into of any cooperative agreement, and the extension, continuation, renewal, amendment or modification of any Federal contract, grant, loan, or cooperative agreement; (b) if any funds Other than Federal appropriated funds have been paid or will be paid to any person for influencing or attempting to influence an officer or employee of any agency, a Member of Congress, an officer or employee of Congress, or an employee of a Member of Congress in connection with the Federal contract, grant, loan or cooperative agreement, the undersigned shall complete and submit Standard Form-LLL, "Disclosure Form to Report Lobbying" in accordance with its instructions. 3. DRUG -FREE WORKPLACE REQUIREMENTS - It and its principals will comply by: (a) publishing a statement notifying employees that the unlawful manufacture, distribution, dispensing, possession or use of a controlled substance is prohibited in the CONTRACTOR'S workplace and specifying the actions that will be taken against employees for violation of such prohibition; (b) establishing a drug -free awareness program to inform employees about - Page 1 of 2 ATTACHMENT 4 (1) the dangers of drug abuse in the workplace; (2) the CONTRACTOR'S policy of maintaining a drug -free workplace; (3) any available drug counseling, rehabilitation and employee assistance programs; and (4) the penalties that may be imposed upon employees for drug abuse violations occurring in the workplace; (c) making it a requirement that each employee to be engaged in the performance of this Agreement be given a copy of the statement required by paragraph (a) above; (d) notifying the employee in the statement required by paragraph (a) above, that as a condition of employment under the grant, the employee will - (1) abide by the terms of the statement; and (2) notify the employer of any criminal drug statute conviction for a violation occurring in the workplace no later than five days after such conviction; (e) notifying the DEPARTMENT within ten days after receiving notice under subparagraph (d)(2) above, from an employee or otherwise receiving actual notice of such conviction; (f) taking one of the following actions within 30 days of receiving notice under subparagraph (d)(2) above, with respect to any employee who is so convicted- (1) taking appropriate personnel action against such an employee, up to and including termination; or (2) requiring such employee to participate satisfactorily in a drug abuse assistance or rehabilitation program approved for such purposes by a Federal, State or local health, law enforcement, or other appropriate agency; (g) making a good faith effort to continue to maintain a drug -free workplace through implementation of paragraphs (a), (b), (c), (d), (e), and (f) above. AND - The CONTRACTOR and its principals further certify that they. 4. Will comply with the provisions of the Hatch Act which limit the political activities of employees whose principal employment activities are funded in whole or in part with Federal funds; and S. Will comply, as applicable, with the provisions of the Davis -Bacon Act, the Copeland Act, and the Contract Work Hours and Safety Standards Act regarding labor standards for federally assisted construction subagreements; and 6. Will comply with all applicable requirements of all other federal laws, executive orders, regulations and policies governing this program. Page 2of2 A Cleaner World # 162 A1TC Project No. 45,34341.4124 Injection Permit Application April 9. 2010 APPENDIX 2: PROPERTY OWNER SIGNED ACCESS AGREEMENT ACCESS AGREEMENT B (Petitioner is NOT the Property Owner) Site Name: A Cleaner World #152 Address: 4506 High Point Rd, Greensboro, NC 27407 County: Guilford DSCA Site ID No.: 41-0024 Name of Property Owner typed or printed: Mi J Kim WHEREAS, Mi J Kim (name of Property Owner, hereinafter: Property Owner) is the owner of a parcel of property located at 4506 High Point Rd in Guilford County, North Carolina (Property); and WHEREAS, (the petitioner) is petitioning to the North Carolina Department of Environment and Natural Resources, Division of Waste Management (Division) for certification of the Property into the Dry -Cleaning Solvent Cleanup Act Program (Program) pursuant to the Dry -Cleaning Solvent Cleanup Act of 1997 as amended, Part 6, Article 21A, Chapter 143, N.C.O.S. § 143-215,1 04A et seq. (DSCA); and WHEREAS, the Petitioner intends to enter into an Agreement for Assessment and Remediation (ARA) with the Division concerning the Dry - Cleaning Solvent contamination on the Property; and WHEREAS, the implementation of the ARA will require that the Division and its independent contractors (contractors) have free and unencumbered access to the Property for the purposes of investigating, assessing and remediating Dry -Cleaning Solvent contamination on and around the Property; and WHEREAS, the parties to this Access Agreement are the Division and Property Owner; NOW THEREFORE, in consideration of the terms and conditions contained in this Access Agreement, and for other good and valuable consideration, the receipt and sufficiency of which are hereby acknowledged, the parties hereto agree as follows: Access Agreement B (March 6, 2006) Page 1 1. Grant of License and Permission. Property Owner hereby grants (a) to the Division a license to access the Property to monitor and enforce the ARA and (b) to the Division's contractor(s) a license to access the Property to undertake all work to be performed at the Property, including, but not limited to, the following purposes: a. Inspecting, sketching and photographing the Property; b. Taking such soil, water and air samples as may be necessary, c. Taking other actions related to the investigation of surface or subsurface conditions, such as installation of monitoring wells or excavation of impacted soil; d. Transportation of equipment onto and around the Property as necessary to accomplish the investigation; e. Taking response actions necessary to mitigate any threat to human health and the environment: If, Remediating dry-cleaning solvent contamination at the Property as needed; and g. Undertaking such other activities as necessary to complete the work to be performed as required or permitted under the ARA. 2, Conditions Precedent. The licenses created in Paragraph 1 shall take effect upon the certification of the Property into the Program and shall remain in effect, unless otherwise terminated pursuant to Paragraph 12 below so long as the Property remains certified under the Program. 3. Observation. Upon the Property Owner's reasonable notice and request, the Property Owner and its consultants shall have the right to observe any activities performed by or on behalf of the Division at the Property. Upon the Property Owner's reasonable notice and request, the Division or its contractors shall allow the Property Owner to split samples of any environmental samples obtained on behalf of the Division. All costs associated with obtaining and analyzing the split samples shall be borne solely by the Property Owner. 4. Interference. The Division and its contractors shall endeavor to perform any activities authorized hereunder at the Property in a manner that minimizes interference with the use of the Property. The Division and its contractors will make reasonable attempts to notify the Property Owner at least 48 hours prior to entering the Property for the purposes stated in Paragraph 1. Access Agreement 8 (March 6, 2005) i'a�;: 2 5. Insurance. The Division's contractors have agreed to maintain the insurances as defined in their agreement with the Division, provided however, that the Division shall have no liability for its contractor's failure to maintain such insurance. 6. Site Repair. The Division or its contractors shall remove and shall have the right to remove from the Property all equipment and other materials belonging to the Division or its contractors within a reasonable period of time after the completion of the activities at the Property authorized hereunder. To the extent practicable, the Division's contractors shall restore the Property to the original condition it was in prior to any activities authorized hereunder at the Property, and except as otherwise agreed to by the parties, shall properly abandon any monitoring wells in accordance with any applicable laws and regulations. 7. Protection of Wells and Equipment. The Property Owner shall not damage, remove, pave over or cover any monitoring or remediation wells on the property. The Property Owner also shall not tamper with or affect the operation of assessment or remediation equipment installed on the property by the Division's contractors. S. Notice. Any notices, reports, or other communications required or permitted under this Access Agreement shall be addressed to the representative for each party as set forth below: To Property Owner: To the Division: 9. Limitations. All obligations of the Division pursuant to this Access Agreement shall be contingent upon the availability of moneys in the North Carolina Dry -Cleaning Solvent Act Fund. 10. Governing Law. This Access Agreement shall be governed by and construed in accordance with the laws of the State of North Carolina, without reference to choice of law principles. 11. Integration Clause. This Access Agreement represents the entire understanding and agreement between the parties hereto and supersedes any and all prior agreements, whether written or oral, that may exist between the parties regarding same. No amendment or modification to this Access Agreement or any waiver of any provisions hereof shall be effective unless in writing and signed by both parties. Access Agreement B (Mareb 6, 2006) Page 3 03186�20I0 �9:I9 8a56�8a:•- MAR. 5.2010 9:56AM ATiC 919-871-8335 MIA NO. 9426 F. `} PAGE 02 72, Te in !;on. "rne licenses created in Paragraph 7 may be terminated upon delivery of reasonable written notl=;e to the Division, which termination shall be effective upon receipt of such notice. However, such terminetion will also terminate the ARA and cause, the farfelture of liability protection under the DSCA if no such noise fs served and subject to provisions of Paragraph 2 above, the licenses created herein shall remain in effect unbi such time as all work or activities under the Program have been completed at the Property. The right and obligatlon set out in the first sentence of Paragraph 6 shall survive the termination of this 11cense. 13. Mladificabon, This Access Agreement may not be amended except in writing by the parties to this Access Agreement. The parties each represent and warrant mat this Access Agreement is executed by their duly authorized representatives as of the date accepted and agreed upon below. r� i C3 Accepted and agreed, this S day of (Signature of (Signature for the Division) Atom Agscement 8 (Ndarch b, 2006) Paso 4 A Cleaner World # 1 fit ATC Prnject No. 45.34341 A 124 Injection Permit Application Apri19, 2010 APPENDIX 3: EHC® MSDS (6)ADVENTUS &Ban--% aw CTUwj.QtV i�myariwrreamoroyia Sa�efi 4Data MATERIAL SAFETY DATA SHEET':.., EHC®� Page: 1 of 3 1. 2. PRODUCT IDENTIFICATION-. PRODUCT USE: NL4NUFACTURER: Adventus Americas Inc. 2971 W. Forest Rd, Suite 2 Frccpw, II.. 61032 EHC' Biorcmrdiation product rvr therewediation of contaminated soil and groundwater only. lvat for use In potable drinking water. EMERGEKCY PHONE: Dice HOWE: 815-235-3503 After hours. 630-369-1175 TRANSPORTATION OF DANGEROUS GOOD CLASSIFICATION: Not Regulated WEMIS CLASSMCATION: Not Regulated CONTAINMENT HAZARD: Any vessel that contains wet EHC or FHC and walrr must be vented dne to potential prrssurc build up from. ferroeatadoa gasses. INGREDIENTS CHEMCAL NAME, CA59 TLV (mgltn3) LD low (tng1Kg) % is Product Organic Amendment NM NIE NIE 52 - 82 Iron 7439-99-6 5 (as iron oxide fume) NIE 18 - 48 3. PHYSICAL. DATA Physical state _ _Solid Melting point_ ....... _.......... _.__.._._1371-1480 F Odour threshold__ _ NIA BoU!ag point.._._.___ KgIL Vapanr 10 178TC Vapntrr density Solubility in water_.._._. insoluble Evaporation ratc,........ ._._.___._.. NIA CoeS of +vaterloil NIA Appearance & odour_. —0dmrl=,T;mMrown Flakes 4. FIRE AND EXPLOSION HAZARD DATA FLASH POINT (I1eg. C PMCC)r NIA )LOWER UPPER FLAMviABLE i.Ii141T5 IN AIR % BY VOLUME: NIA NiA AUTO IGNITION TEMP (Deg. C): NIA " ADVENTUS S!:If Bat a NfATL,�sAtETYDArAsrlM: ElIC" Page: 2 of! EX [TNGUISHIh1G 16"IA: I)ry chemicals or shod or unlyernl type foaat SPECIAL PkocEnuRys: ivrefghters should wcu SCRA Ind prolecti Ye cl nl hins. UNUSUAL FM AND EXpr.OSIUN HAZAi{(1S; t7ost can pre=i fire and explosion hazards aebcn cxPw.ad to fire, Chtr cal nmcd Da, or cnetncl with pain:rfrrl oxi0mrs. S. REACITYf' DATA STAItILITY MRMAL COMM): stable: X unelable: CONDTeIONS TO AVOID: Contact with powrrful oxidircrssurh as TNCOM"ATIS]'LITY {Malerials to Avoid): S&M. arad . adds. fk—M oxidixcrs such as strong NA2A-RDOU5 DECOMPOSMONMOM M.- Hydragen• Carbon znono udc, rbon dioxide- S. TOXICOLOGICAL PROPERTIYS ROiTPS OF ENMV: Inhalation IngcsUon (not Ucly) SALTS HAZARDS: Arvtc ovcr=posurc may cause eye, nosq moulh and skin irritation, Carcanogcrdcity. NoI,nformation AvaaWc Signs and Symptoms ofExpcsuo: No I-IfOrT 26an Available Me&Cal Conditions Gen"vily Aggra,kattdbyEx"r, No Inf—a[ion Available 7, PREVE.MVEINEASURE,C PERSONAL PROTECTIW FQVIPKEhT: $ye Protertian: X Gloms: X Clathlmg: RF—W ATORY PROTEMOM (6�,) ADVENTUS soa sahtdx c eau area HsnreclarFan lecfi�oFo¢rr Safetaata MATERIAL, SAF1w TY DATA SMPT: EHC� .. Page: 3 of 3 . Use duet mask in sewcre Lou diIions, Use goad houscixeping pracUta to keep dou to a minimum ViNTIIATION REQUM ALF:NTS: Nu normally rcyuitrj. SPILL AND LEAF PROCEDURES: Swop tip and rcfuru to container. WASTEDLSPOSA ,-. Sanimryland5tl. Follf>w frcdrrnl, Slate and Luzal guidelio us. UANDLING FROCEDLTkF.9: Wear safety glasses for n❑=;kl use. Arvid arncramig exeessivc dust, wrar dust mask in sevcrt condaignc STORAGE REQUUMNIENTR Do not attire near plmrrful acidixcrs mch as strong ands. Kwp dry. Any stis.A 1 that containS wet F_PC ar EHC and wawx must ho vc:n tell due to potcnl iai pressure bui Id up from fermentation gasses. SPRCL41. EL4NDLING INFORMATLON: Treat as a nuisamcn dust S. FIRST AID WASURES NHALATION: Remove to fresh air. Scck medical nrlrnd a. TNGEMOM Scek ascdiW attention. SKT14 CONTAC7. Brush oft excess. Wash with soap and water. EYE CONTACT: I -lush with running waW, Sock medical attrrnion. 9. OTHM INFORMATION ?June 10. PREPARATION ENrORAILAT'ION Prepared BY: Advennms. Rcmcdiaticm Technologies wte PrtgJP v_: 10f28108 1345 Fcwaiu Drive Print Data. S0128108 Mississauga, ❑ntgrio Pttoac 905-273-5374 LAW 2A5 Fax: 405-273-4367 Ucflydfious: N/D-No Dale NIA- Not ApplinUc WE- Not FzUbtished EPIC'° is a -gist Bred 1rsow=;A of Advenkta Intrllc awl Prorxvy I= A Cleaner World #162 ATC Project No. 45.34341.4124 Injection Permit Application April 9, 2010 APPENDIX 4: CASE STUDIES AND PRODUCT LITERATURE ADVENTUS Proven Sail Sed+ment, aril GrounoWter Remediation Techrral es Via Email: aenna.olsonC-atcassociates.com March 2, 2010 Genna Olson ATC Associates Inc. Raleigh, NC 919-871-0999 Subject: Revised Proposal - Treatment of CVOCs using EHCO ISCR Technology Dry Cleaner, Greensboro, NC Adventus Proposal No. AA19-370 Dear Genna: Please find herewith a conceptual remedial design and cost estimate for employing EHC® in sits chemical reduction (ISCR) technology to remove chlorinated volatile organic compounds (CVOCs) from groundwater at the above referenced site (the Site). The cost estimate includes EHC amendments and delivery (estimated); Adventus on -site field support for the initiation of the project is presented as a recommended option. This proposal has been updated form the one provided on May 29, 2009. TECHNOLOGY BACKGROUND EHC® is the original, patented combination of controlled -release carbon and zero valent iron (ZVI) particles used for stimulating in situ chemical reduction (ISCR) of otherwise persistent organic compounds in groundwater. Variations of these materials have been used to treat over 8,000,000 tons of soil/sediment impacted by recalcitrant compounds as part of the company's ❑ARAMEND6 bioremediation technology. Both EHC and DARAMEND are proven, established technologies that have been used at hundreds of sites to date throughout the world. The technologies have been accepted and many Federal, State (including California), and regional regulatory authorities within the USA/Canada (Figure 1a) Europe (Figure 1b) and other places around the world. EHC is available as a solid or liquid material that can be easily injected into the subsurface environment in a variety of ways, based on site -specific designs. Application methods include direct mixing, hydraulic fracturing, pneumatic fracturing, and injection of slurries or liquids. Direct placement in trenches and excavations are also reliable application methods. 2871 W. Forest Road, Suite 2 . Freeport, IL 61032 + Tel: 815.236.3603 . Fax: 815.235.3506 www.AdventusG roup.com C&ADVENTUS EHC Cost Estimate Figure 1 a: Adventus Field -Scale ISCR Projects in North America 41 States n 400 Sites November 2009 Figure 1b: Adventus Field -Scale ISCR Projects in Europe 14 Countries a 50 Sites November 2009 Following placement of EHC into the subsurface environment, a number of physical, chemical and microbiological processes combine to create very strong reducing conditions that stimulate rapid and complete dechlorination of organic solvents and other recalcitrant compounds. First. the organic component of EHC (fibrous organic material) is nutrient rich, hydrophilic and has high surface area; thus, it is an ideal support for growth of bacteria in the groundwater environment. As they grow on EHC particle surfaces, indigenous heterotrophic bacteria consume dissolved oxygen thereby reducing the redox potential in groundwater. In addition, as the bacteria grow on the organic particles, they ferment carbon and release a variety of volatile fatty acids (acetic, propionic, butyric) which diffuse from the site of fermentation into the groundwater plume and serve as electron donors for other bacteria, including dehaiogenators and halorespiring species. Finally, the small ZVI particles provide substantial reactive surface area that stimulates direct chemical dechlorination and an additional drop in the redox potential of the groundwater via chemical oxygen scavenging. These physical, chemical and biological processes combine to create an extremely reduced environment that stimulates chemical and microbiological dechlorination of otherwise persistent compounds. Redox potentials as low as —550 mV may be observed in groundwater after EHC application. At these Eh levels, many organic constituents of interest (COI) are thermodynamically unstable and they will readily degrade via pathways more typical of physical destruction processes (minimum production and no accumulation of typically recognized biodegradation intermediates such as QCE for TCE). Hence, the ISCR technology is microbiologically based in that we rely on indigenous microbes to biodegrade the EHC carbon (refined plant materials), but we do not require the presence or activity of special or otherwise unique bacteria for complete and effective remediation. AA19-370 2 AD Y E 1 V 1 U EHC Cyst Estimate The type of EHC used for a given site depends, in part, on the construction method employed to emplace the material into the subsurface. If a direct mixing or direct placement method is used, the standard slow release, solid EHC material would likely be utilized. If an injection method is used, however, a combination of fast and slow release EHC may be preferred. If the material is to be placed through an existing well network, then a water- soluble, aqueous formulation, EHC-A, may be utilized. In either event, the fibrous organic carbon and ZVI or other reduced metal that comprises the slow release EHC will remain in the location where it is injected. It will not only treat COI that migrates into the treated area, but it will also have a 'halo' or 'zone of influence' of low redox conditions that will extend beyond its physical space, greatly increasing its effectiveness. Figure 2 shows how EHC injection creates a wide zone of influence outside of its immediate location. The native soil color is the yellow visible on the right hand side of the core. The orange discoloration is due to the low redox conditions created by the EHC, which became apparent after exposure to the air for 2 hours. Figure 2: Photograph of a soil core, from 34 ft to 33 ft bgs, showing a 1-inch seam. L"J MODE OF ACTION -- ISCR FOR CVOCs It is critical to understand that the processes of C01 destruction under ISCR conditions are different from the typical pathways. The primary COls in the Site groundwater are PCEfTCE and the recognized daughter products of reductive dehalogenation reactions that occur under normal anaerobic conditions (Figure 3). AA19-370 3 C6,i-) ADV EN TU S EHC Cost Estimate Figure 3: PCE /TCE Degradation Schematic — Sequential Reductive Dehalogenation under Typical Anaerobic Conditions. cis-1,2-DOE PCE TCE trans-1,2-DCE VC Ethene 1,1-DCE I-T Under ISCR conditions (Eh <-550 mV), these pathways are avoided and terminal destruction / mineralization proceeds along the lines of the recognized beta -elimination pathways (Figure 4). These differences have been described by various experts in the field of biotransformation processes (e.g., Dr. John Wilson, US EPA as reported in the AFCEE Technology Transfer Seminar, 2003; Dr. Marls Ferry, MPCAA; J, Szecsody and J. Fruchter et al., Battelle Pacific Northwest National Laboratory). Figure 4: PCE /TCE Degradation Schematic — Representative Reactions for Mineralization under ISCR Conditions. fi—Elimination Pathway �..,` Chlvivacetylene Fe e# Acetylene ....................... Ethene ,.� C1 ..� Ethane Fe° f.............CDCE .. .. .. ....i �............. tDCE �.............i ] 1 DCE. <10% Hydrogenolysis Pathway 4 H+ ........... *................... TCE OH- - AA19-370 4 rb1 ADV EN Tu 5 EHC Cast Estimate CASE STUDIES EHC treatment has effectively removed a range of CVOCs under full-scale field conditions without generation of potentially problematic catabolites (Appendix A)-- EHC for source area treatment in clayey lithology (PCE and catabolites), Former dry cleaner, Oregon • EHC-M for isolated hotspot treatment (TCE and Cr(VI)), NW USA • EHC for source area mass reduction (TCE. TCA and catabolites), Cherry Point. North Carolina • EHC for complete plume treatment using multiple reactive barriers (CF, TCE and OCPs), Confidential site, Southeast USA • EHC injection PRB for plume management (CT, CF). confidential site, Kansas + EHC injection PRB for plume management (cis-DCE and VC), confidential site, Ohio • EHC trench PRB and excavation backfill (PCE and daughters), confidential site, Texas ■ EHC applied via hydraulic fracturing into partially weathered rock, confidential site, Manufacturing facility, North Carolina Of particular interest is the fact that EHC treatment has been proven effective at sites with both very high and very low initial CVOC concentrations. Such broad applicability is consistent with the multiple modes of dechlorination that are generated by a combined chemical/microbiological approach to groundwater treatment. EHC and other Adventus products have been accepted by many regulatory agencies - (http://www.adventusgroup.com/library/regulatory-approvals.shtmi). The product is supplied in 50 lb bags as a powder which can be mixed with soil or slurried in water. Installation techniques vary widely depending on the application. For example, the powder can be mixed with soil and placed at the bottom of an excavation where prior soil removal had been conducted. A slurry can be made and the mixture can be injected into the subsurface using techniques such as direct injection through GeoProbe rods or hydraulic fracturing (Appendix B). POTENTIAL ADVANTAGES OF USING EHC ISCR TECHNOLOGY The patented combination of controlled -release organic carbon plus ZVI uniquely yields ISCR conditions which give EHC powerful technical advantages over other materials that provide only carbon (i.e., emulsified oils, molasses or lactate -based substrates) or only ZVI. These include: • Health and Safety. Safe handling and easy application with no bulky or hazardous material disposal issues; AA19-370 5 (6��) ADVENTUS EHC Cost Estimate • Minimal Methane Production. The presence of ZVI and the complex, controlled - release carbon source help minimize production of potentially problematic fermentation end -products, such as methane; Predictable Performance. EHC uniquely integrated chemical and microbiological degradation processes which allows treatment to proceed at a predictable rate: • Constructability. EHC is easily and quickly injected using conventional construction technologies; • No Mobilization of Contaminants, optimal volume of EHC slurry is injected without the need for extensive water flushing, which avoids potential displacement and mobilization issues; • Accelerated Site Closure due to the ability of the EHC system to rapidly remove COI mass via a combination of biogeochemical degradation processes without relying on physical sorption 1 sequestration as a major "removal" mechanism, ala oils; ■ 1SCR- Combined chemical and biological oxygen scavenging facilitates rapid oxygen consumption and establishment of reduced Eh; Generation of significantly lowered reducing conditions usually eliminates any requirement for specialty microorganisms or inoculants; • No Dead -End Intermediates. Rapid COI removal without accumulation of potentially problematic catabolites, such as cis DCE from TCE or chloroform (CF) from carbon tetrachloride (CT) (see ❑olfing et a!, 2008; Liu et al., 2000) • Applicability. Demonstrated effective on a wide range of COI, including chlorinated solvents, Freons, pesticides, perchlorate and other energetic compounds (explosives); • Longevity with no Rebound. EHC remains active in the environmental for 12 to 60 months hence COI rebound phenomena are not observed (rebound is common when using readily biodegradable, liquid substrates); • Complete Technology. Provision of major, minor and micronutrients that are essential to the activity of fastidious anaerobic bacteria involved in recognized dechlorination reactions; • Buffering Capacity- Provision of substantial pH buffering capacity (i.e., different EHC products are designed to release alkalinity, acidity or to maintain a neutral pH). In contrast, the addition of conventional organic substrates (e.g., emulsified oils, molasses or lactate -based materials) to promote COI biodegradation can lead to aquifer acidification; • Facilitates Natural Attenuation Processes. For all the reasons summarized above, EHC enhances the natural biological processes. Other technologies may offer short AAI9-370 - — 6 Ir1 ADVENTUS FHC Cost Estimate term COI reduction via sorption reactions, etc. but they can alter the environmental conditions such that natural attenuation mechanisms are adversely influenced; and ■ Simultaneous Immobilization of Heavy Metals. EHC will not mobilize arsenic, and EHC-M will simultaneously immobilize many other heavy metals, which may be present as other potential CO Is. UNDERSTANDING SITE CONDITIONS AND GOALS Site soil and groundwater is impacted by CVOCs. The primary constituent of concern is PCE, which has been measured at a maximum concentration of 13 mg/kg in soil and 1.5 mg/L in groundwater. For this remedial measure, the goal is to treat the on site portion of the plume. Figure 5 shows concentrations in groundwater measured in April 2008. The groundwater table is at ca 14.5 ft bgs and the linear groundwater velocity has been estimated at ca 20 ft/year. The lithology is composed of clay overlying saprolite, which is encountered at ca 20 ft bgs (Figure 6). The plume extends into the saprolite and shallow bedrock, however, the groundwater mixing zone has been estimated to extend from the groundwater table down to the bedrock (estimated average treatment thickness of 24 ft). Total porosity is 58.6%. Current redox conditions appears to be hypoxic, with only lower levels of D❑ and nitrate and an ORP of less than 100 mV (Table 1). The aquifer is slightly acidic which can be predictably problematic for carbon -only amendments. Table 1: Geochemical data (December 2008). 0 c a o O � U ca ❑ m m ca m �" 5 — L c c H 0 t z 7 O f4 -] 7 N C Q C: � C 6� SQ Z w a) .� w E cc a� t o2m �� � � ~ m IL m IL m IL m IL mV std unit m IL m IL m IL MW-1 0.11 <0.5 12.4 2 83.6 5.71 NA 0.0064 <0.0032 MW-1 BR 0.10 NA NA NA 93A 5.85 NA NA NA MW--2 0.09 NA NA NA 8.4 6.00 NA NA NA MW-28R 0.09 NA NA NA 12.6 6.36 NA NA NA MW-3 1.26 3.09 45.2 0 93.9 6.44 NA <0.0025 <0.0032 AAIS-370 7 �1 ADVENTUS EHC Cost Estimate Figure 5: PCE concentrations measured in groundwater (mg/L). Approximate extent of initial targeted clean-up area shaded in yellow. 11 - kv 1 - e.,\ V)-" Ap0_0751 � f ti \ 4• IIVf-7� �r � tt) ►�iME t er I II ■I� � �� [0 �] C/ to r°.G°ory� Oro caala>; r r �-y t "IE 1 we-+sv/° (5 cC.°d77) Ito o.a°7t1 1 AA19-37o 8 C6��) ADVENTUS EHC Cost Estimate Figure 6: PCE iso-concentration lines shown on vertical cross-section (mg/L). 1W A C T- eo I [INI T � n 1 •EL Q L L- ! REMEDIAL DESIGN The goal is to create a permeable reactive barrier (PRB) across the plume area for passive plume treatment over time. The groundwater will be treated as it flows through the PRB and an area downgradient from the treatment barrier will be influenced via groundwater flow over time. The extent of this zone will depend on the linear groundwater velocity; at a site in KS, we have observed significant benefits at a distance > 600 ft downgradient of the PRB within a 3 year period (Appendix A). The EHC PRBs will have to be rejuvenated every 4 to 6 years for the life of the source. A design with several PRB units could also be considered for complete plume clean-up over time; the spacing and number of barriers could be varied depending on your clean-up timeframe and linear groundwater velocity. For pilot testing of this approach, we recommend installing a PRB segment directly upgradient of the source area well MW-3. For the purpose of this cost estimate we have assumed a PRB dimension of 100 ft long x 20 ft wide x 24 ft deep (from 14 to 38 ft bgs). The PRB unit will be composed of two lines of injection points spaced 10 ft apart. The injection points will be spaced 10 ft on center within the lines and the lines will be off -set by 5 ft, resulting in an effective spacing of 5 ft AA19-370 9 AD Y E+V ` u EHC Cast Estimate perpendicular to flow (to yield some overlap). To sustain continuous treatment over time, an application rate of 0.5% to soil mass will be applied within the PRBs. This result in a total of 15,500 Ibs of EHC required for a 100-ft long PRB unit. The EHC will be provided in 50 lb bags as a dry powder and mixed with water on site into an aqueous slurry containing 20 to 30% solids. The EHC slurry will be injected into the ground using high-pressure direct injection techniques. PLEASE NOTE that the below construction estimates presented below can be readily modified in the field as required (for example, the density of the slurry can be changed to modify the total injection volume or the injections spacing could be altered based in installation technology). Adventus' costs for one PRB unit are presented in Table 2. These costs include EHC plus delivery (estimated). Adventus on -site field support for the initiation of the project is presented as a recommended option. This cost does not include remedial construction or services assigned to ATC. These costs are valid for 45 days. Table 2: EHC mass requirements, injection details and estimated cost. Value Unit PRB dimensions: PRB length 100 ft PRB width 20 ft Depth to top of plume 14 ft b s Depth to bottom of plume 38 ft b s PRB thickness 24 ft PRB volume 48,000 ft3 Mass of soil in PRB 1,536 U'S. tons Estimated porosity 59% Volume pores ace 28,128 ft3 EHC mass calculations: Percentage EHC by soil mass 0.50% Linear groundwater velocity 0.05 ft/day Contact time 400 days Contact time * application rate multiplier 200 da s*%EHC Mass of EHC required 15,500 Ibs Preparation of EHC Slurry: Percent solids in slur 29% Volume water required 4,653 U.S. gallons Slurry volume 5,653 U.S. gallons PRB injection layout: Number of injection lines 2 lines Spacing between injection points 10 ft Number of points er line 10 points/line Total number of injection points 20 points AA19-370 10 (6;�) ADVENTUS EHC Cost Estimate Injection details: Mass EHC pgr aint 775 Ibs Water volume per point 233 U.S. gallons Slurry volume per point 283 U.S. gallons Number of layers per point 15112 layers/point Mass EHC per layer 50 Ibs Water volume per layer 15 U.S. gallons Slurry volume per layer 18 U.S. gallons Application rates for reference: Slurry volume to pores ace volume 2.7% EHC concentration in groundwater 0.6 Ibslft3 Cost: EHC Mass 15,500 Ibs EHC Unit Price' $2.50 $US/lb EHC Cost $38,750 $US Shipping Estimate`' $2,000 $US Inquire oversight and travel 2 days on site ($2,000) $US TOTAL COST*'* $40,750 $IJS *Price valid for 45 [lays. Volume discount applied where appropriate and assumes payment within 45 days. Any applicable taxes not included. Please provide a copy of your tax exempt certificate or resale tax number when placing your order. "Shipping billed at actual cost plus 9% Transportation quotes assume 5 to 7 day delivery time via truck no lift gate, no pallet jack. ***Field oversight is presented as a recommended option and not included in the total cost. The Adventus performance warranty (below) is predicated on our oversight to verify material emplacement conditions. if additional field oversight is desired. it can be provided on a time and expense basis. DISTRIBUTION OF RESPONSIBILITIES For field scale work at the Site, Adventus will provide environmental biotechnology and design support. It is our intention and understanding that ATC will be responsible for remedial construction, permitting, performance monitoring and reporting. The distribution of responsibilities envisioned is as follows: 1. Adventus will provide and arrange delivery of EHC to the Site. 2. ATC will be responsible for remedial construction contracting. 3. It is highly recommended that Adventus personnel be on site during project start-up to support ATC's field staff. 4. Adventus will provide data interpretation to ATC upon request. 5. Adventus will provide technical writing support to ATC, upon request. G. ATC will provide manpower for receiving shipments, monitoring treatment performance and collecting samples. AAI9-370 11 (6�0 ADV EN T U S EHC Cost Estimate 7. ATC will maintain overall project responsibility, and will maintain all client contact and control of the Site. R. ATC will be responsible for all health and safety, permitting and approvals, sampling and analytical costs along with all data management and reporting costs. Adventus will provide copies of our patents and written, full indemnification hacked by insurance coverage to ATC and the end -user 1 client from any lawsuits purporting patent infringement or other technology violations. Adventus warrants the performance of its technology. In the event that the prescribed EHC injections do not yield at least 80% reduction in overall COI groundwater concentrations within the treatment zone within 9 to 12 months, then we will provide an equivalent amount of EHC at 50% of the listed price (plus delivery costs). Adventus' field installation oversight would also be provided at no cost. This performance guarantee requires that a representative from Adventus is on site for the initiation of the project and that the injections are conducted according with Adventus' recommendations. On behalf of Adventus, I thank you for your interest in our products and technologies. Please contact me by email at josephine.molin@adventusgroup.com or at 773.991.9615 if you have any questions regarding this proposal. Yours truly, Adventus Americas Inc. Josephine Molin Project Engineer Cc: Dr. Jim Mueller — Adventus EHC® is a registered trademark of Adventus Intellectual Property Inc. AAI9-370 12 IA ❑/rMTH Field Profile (6�. i I 144wfProven Soil, Sediment, and Grounawater `� Remediation TechrkWogies �' H Project Update Jan 2010 EHC. Pilot Study for Oregon DEQ's Dry Cleaner Program at a Former Dry Cleaner Site, OREGON USA Project manager/regulatory contact: Don Hanson, Oregon Department of Environmental Quality Sttmmary Groundwater at the former Serry's dry cleaner site in Corvallis, Oregon, was impacted with chlorinated volatile organic compounds (CVOCs). The key CVOCs found at the site include PCE, TCE, DCE, and VC, as high as 22,000, 1,700, 3,100, and 7 ppb, respectively. Field scale pilot tests were performed for the Oregon DEQ's Dry Cleaner Program to evaluate the performance of EHC*, an in situ integrated biological and chemical reduction (ISCR) technology. The method of injection was also evaluated to determine the effectiveness of the injection method in distributing EHC, given the low permeability of soils at the site (sandy silt and silty clay). Subsequent field monitoring has shown greater than 99.9% removal of total CVOC concentrations two years after the injections, without the accumulation ofcatabolites or rebound of CVOCs. The Challenge The groundwater flow direction at the site changes with seasonal conditions, and is either toward the south-east or the north-west. The groundwater velocity is unknown, but assumed to be low due to the type of soils at the site. No confirmed source of PCE has been found, however groundwater concentrations suggest that there may be two hot spots on site: the north-west corner and south-east corner of the building. The building is currently occupied and access is difficult to obtain. The primary goal of the pilot -scale treatment is to reduce groundwater concentrations at the southeastern hot -spot that may have historically contributed to indoor air vapor intrusion at nearby residences. Test Injection A test injection was conducted prior to full-scale implementation to evaluate the effectiveness of direct push methods in distributing EHC in the low permeability soils. A total of 450 lbs of EHC was injected from 13 to 25 ft bgs (4 discrete layers, spaced 4 ft apart) using GeoProbe's pressure activated injection tip. A high pressure pneumatic grout mixing and pumping system was used to mix and pump the EHC to the injection tip. Six soil cores were obtained around the injection point (from 0.5 to 5 ft from the injection point) to assess the radius of influence of the injection (Figure 1). EHC fractures were found at the farthest sampling points indicating that the radius of influence was up to at least 5 ft. Figure 2, 3, 4 and 5 show some of the EHC bands or fractures observed in the soil cores. The following lithology was observed from the soil sampling: ■ Brown sandy, clayey silt from S to 20 ft bgs; ■ Stiff brown silty clay from 20 to 22 ft bgs; • Stiff gray clay below 22 ft bgs; • Water bearing and loose sand layers were encountered at approximately 26 ft bgs. Adventus Group ■ Toll Free: 888.295.8661 ■ Tel: 815.235.3503 www.AdventusGroup.com () ADVENTUS Figure 1: Soil sampling locations around EHC injection point. Figure 2: EHC fracture at 17.5 ft bgs (SB6). Figure 4: EHC fracture at 17 ft bgs (SB7). Field Profile { ►. - .... y Figure 3: Vertical EHC fracture at 26.8 ft bgs (SB6). i s: 'k 2 3 4 3 Figure 5: Vertical EHC fracture at 17 ft bgs (SB9). Adventus Group • Tall Free: 888.295.8661 • Tel: 815.235.3503 2 www.AdventusGroup.com r6� ADVENTUS Field -Scale Pilot Study In August 2006, a total of 10,250 Ibs of EHC was injected into an area measuring approximately 825 112 x 20 ft deep (from 10 to 30 ft bgs), which resulted in an average application rate of 0.6% to soil mass. The EHC was supplied as a dry powder in 50-lb bags and mixed with water on site into slurry containing about 29% solids (Figure 6). Using conventional direct push technology, the EHC slurry was injected at 3 to 6 GPM at a pressure of approximately 200-400 psi. The depth interval targeted was from the groundwater table (ca. 10 tt bgs) to approximately 30 ft bgs, where a less permeable layer was encountered. The EHC was injected in discrete layers using the Geoprobe pressure -activated injection tip and high pressure grout mixing unit. Field Profile Figure 6: Chem Grout's Mixing Unit CG-500. The EHC was added to a total of 32 injection points (Figure 7), including nine additional points south of the building. The additional points were added due to issues with surfacing: it was not possible to achieve the originally 0 Me"-Spice11 (Former Sorry's Dry Cleaner) B1a Cis D11 Etd 11 "wa ! "C-27 EkCa �E20 82a C2e D20 H C-220 EHC-2 HC -230a ENC-10 BS0 Cie D3a l tic -24 NC-26#* NG-25� 840 C46 044 IE413 y,a =1a Ala I I HC-250 0513 CSO Ds(D ES Y2Z20 a A2O HC•29� I I1,1W-8a B6a C843 Do 'a E60 - r3 � zap; A3---------- Sidewalk Figure 7: EHC injection locations, groundwater sampling locations, and monitoring wells. planned application rate of 1 /❑ to soil mass in the tight soil formation at the targeted flow rate of approximately 5 GPM due to pressure build-up in the subsurface. The treatment area was therefore increased resulting in a lower application rate of 0.6% to soil mass within the treatment area. In addition, a relatively tight injection spacing of 5 ft was used for the EHC injections based on the results from the test injection. Approximately 18 lbs of EHC was added per vertical foot on average. Figure 7 also shows the locations of four new monitoring wells (MW-6 to MW-9) installed in January 2007. Previous monitoring performed in February 2005 and August and September 2006 was conducted via direct push probe exploration locations (HC-22 to MC-29). Adventus Group ■ Toll Free: 888.295.8661 • Tel: 815-235.3503 www.AdventusGroup.com C6-)ADVENTUS Field Profile The Result Following injection of EHC into the suspected source area, PCE was decreased to below the detection limit of 1 ug/L and total CVOCs decreased from a maximum of 25,606 ug/L to below 100 uglL at all locations within 12 months (Figure 8). The PCE degradation resulted in an initial build-up of TCE, DCE (primarily cis-DCE) and VC, indicating that sequential dehalogenation was occurring (biological pathway). However, conversion rates were less than Stoichiometric and concentrations of all constituents appeared to decrease simultaneously, suggesting that abiotic treatment mechanisms also occurred at significant rates. Observed generation of VC was limited, indicating that abiotic beta -elimination was a primary pathway for cis-DCE degradation. A smaller concentration of chloroethane (CA) was also observed (maximum concentration of 44 ug/L measured in February 2008 — 18-month data), suggesting that hydrogenation of VC might be occurring. NW sampling cluster 25,000 20,000 J 15,000 i0,000 0 u 51000 7,000 6,o0o a 5,000 4,000 3,000 u 2,000 1,000 0 -18 0 1 5 8 12 14 18 22 24 31 34 Time post injections (months) SE sampling cluster 1 5 8 12 14 18 22 24 31 34 Time post injections (months) 3,500 3,000 2,500 J 2,000 C 1,500 O to 1,000 500 0 NE sampling cluster -18 0 1 5 8 12 14 18 22 24 31 34 Time post injections (months) 10,000 SW sampling cluster 9,000 — 8,000 7,000 6,000 -� 5,000 c 4,000 sj 3,000 2,000 1,000 a 1 5 8 12 14 18 22 24 31 34 Time post injections (months) L _______ _ +PCE fTCE -,&-o-DCE MCA —VC Note. The data from Feb 2005, Aug 2006, and Sep 2006 was obtained via direct push probe exploration locations. Subsequent monitoring was conducted via groundwater monitoring wells installed close to each of the previous direct push sampling clusters. Figure 8: Influence of EHC injections on PCE and daughter products in groundwater. Adventus Group . Toll Free: 888.295.8661 ■ Tel: 815.235.3503 4 www.AdventusGroup.com (6) ADVE N-TUS Field Profile Flistorically, CVOC concentrations in groundwater fluctuate heavily with the seasons in the study area. )Figure 9 shows the groundwater elevation and total CVOCs concentrations measured since the well installations. Transient rebound was observed during the rainy season (18-month data), presumably due to the introduction of CVOCs from the smear zone as a result of a 6 to 7 ft (1.8 to 2.1 m) increase in the groundwater table. While the groundwater table remained high through June 2008 (22- month data), total CVOC concentrations decreased, suggesting continued treatment via resident, active EHC. By August 2008 (dry season), PCE and TCE both decreased to below the detection limit of 1 ppb at all locations. The rebound observed during the following wet season (March 2009) was much smaller than the previous year, suggesting that treatment of the smear zone is being achieved as desorption is promoted. Figure 9: Total CVOCs and depth to groundwater. Degradation end products. An increase in ethene and ethane levels confirms that complete degradation is occurring (Figure 10); ethene levels of up to 760 ug/L were measured in July 2007 (11-month data) which constitutes an increase of 96% compared with 800 the maximum concentrations measured in -+-Ethene- NW 700 August 2006. As total dissolved Ethane -NW 60a concentrations of chlorinated ethenes 50E1 wr-Ethene-NE decreased within the treatment zone, the --O-Ethane-NE concentration of dissolved gases has also -- 400 - u —Ethene - 5W decreased. However, concentrations of ethane U - -*-Ethane - SW remain above baseline levels, suggesting that 200 —Ethene-SE a smaller concentration of sorbed CVOCs 100 remain and that degradation is still ongoing. A Ethane - SE 0 spike in ethane concentrations were observed 0 3 6 9 12 15 18 21 24 27 30 at the NE and 5W monitoring wells during the Time post EHC injection (months) rainy season (I 8-month data), as CVOCs Figure 10: Degradation end products. sorbed to the smear zone entered the system and became available for degradation. EHC indicator parameters. To assess whether the wells are in fact under the EHC zone of influence, the groundwater was sampled for total organic carbon (TOC) and ferrous iron (Fe(II)). A significant increase was observed at all sampling locations, confirming that successful product placement and sufficient distribution had been achieved. TOC and Fe(II) has been measured at a maximum concentration of 2,800 and 130 mg/L respectively. Adventus Group ■ Toll Free: 888.295.8661 ■ Tel: 815.235.3503 5 www.AdventusGroup.com ADVENTUS Field Profile u Redox indicator parameters: Following the EHC injections, the oxidation-reduction potential (ORP) decreased within the injection zone. Sulfate concentrations decreased from a baseline concentration of 7 to 34 mg/L to below the detection limit of 4.1 mg/L, suggesting that sulfate reducing conditions was established within the injection zone. Furthermore, an increase in methane suggests methanogenic conditions and an excess amount of dissolved carbon. As dissolved carbon concentrations declined over time, ORP has increased but remain below background levels. The fluctuations observed in ORP indicates that the redox conditions may also be affected by the shifts in the groundwater table, with generally more reducing conditions during the rainy season. ARP Dissolved Oxygen 150 6 100 5 so J 4 � E 0 E 3 -s0 air a 2 0 -100 -Is0 1 -200 0 0 3 6 9 12 15 18 21 24 27 30 33 0 3 6 9 12 15 18 21 24 27 30 33 Time post EHC injection (months) Time post EHC injection (months) Sulfate Methane 40 25 35 30 ZO 25 j 15 J 0o E 10 20 E 15 s s 10 0 v S 5 0 0 0 3 6 9 12 15 18 21 24 27 30 33 0 3 6 9 12 15 18 21 24 27 30 33 Time post EHC injection (months) Time post EHC injection (months) --O.—NW sampling cluster —ENE sampling cluster -- —SW sampling cluster —A--SE sampling cluster Figure 11: EHC effect on redox indicator parameters measured rr ithin treatment area. The Cost The material cost of using EHC was $1.241ft3 ($441m3). The injections were completed in 5 days. Results of this pilot study have shown that iSCR using the EHC technology offers a safe, effective and cost-efficient remedial solution for dry cleaning and related sites. For more information, please contact. Josephine Molin, Adventus Group, Direct: 773.991.9615, Email: josephine.molin@adventusgroup.com Adventus Group ■ Toll Free. 888.295.8661 ■ Tel: 815.235.3503 6 www.AdventusGroup.com (6 ,,)ADVENTUS Proven Soil Sediment, and GrarimWater Reniedfarion %chnotoos Project - Co -Treatment of TCE and Chromium using EHC-Mo Manufacturing Facility, Washington Lead Consultant - EA Engineering, Science, and Technology, Inc. Summary EHC-M* has been shown to effectively treat ca. 6.1 ppb trichloroethene (TCE) and immobilize ca. 165 ppb hexavalent chromium (Cr(Vl)*) from groundwater at a manufacturing facility in Washington. Following the injection of EHC-M performed in September 2006, subsequent performance monitoring conducted in October 2006 and January, May, July and October 2007 showed TCE and all related daughter products below the detection limit of 0.05 ppb. Cr(VI) was reduced by >90% to 11 ppb one month following the injections and has remained below the detection limit of 5 ppb since the January 2007 sampling event. The Challenge Field Profile EHC-M� The site soil and groundwater is impacted with TCE and elevated levels of Cr (VI). An extraction system is currently in operation at the site, which has cleaned up portions of the downgradient end of the plume to below the treatment goals of 5 ppb for TCE and 80 ppb for Cr(VI). However, an isolated area experienced rebound when the extraction system was not operated and it appeared that the extraction system was not effective for treatment of the source of this rebound. A concentration of 6.1 ppb TCE and 165 ppb Cr(VI) was measured at the former extraction well MW-41 in April 2006 (Figure 1). The conditions were relatively oxic with a ❑O of 5 mg/L and ORP of 200 mV. The goal was to clean up this isolated hot -spot area to allow for the extraction system to be shut down completely at the downgradient end of the plume, which would result in significant cost and energy savings. AMW— 3 • Isolated hot -spot t,r� S 5 E. targeted for remediatian ar'I•_i•. 5 L� �y,!•; _„ L . 7�4 4AW.4_ a1s'..' i. 176 pNN_ILC t-d x ' � 57 NW.�tir 1S.F 17.2 UL Slt VNY.SI 9.8 16 5U IV, Y-6A ! vs ❑p �7 L L'+ 80 250 Cr AMW.SF t� ppb r,U uW{t3 wMW.7d ❑ 250 to 500 Cr ppb bW Mw-! ,'�.► kfNr? ❑ 500 to 1,250 ppb Cr I N4 one Figure 1: Concentration of Cr(VI) in groundwater measured in April 2006. Adventus Group . Tall Free: 888.295.8661 ■ Tel: 815.235.3503 www.AdventusGroup.com (6"YADVEN-TU-S- Field Profile The Solution In September 2006, EHC-M was injected into the suspected hot -spot area upgradient of extraction well M W-4l. The targeted treatment area measured an estimated 50 ft wide x 100 ft long x 10 ft deep (from 75 to 85 ft bgs). A total of 9,600 Ibs of EHC-M was injected into the area, resulting in an average application rate of 0.15% to soil mass. The application rate applied was higher than the concentrations of TCE and Cr(VI) would suggest given the relatively oxic conditions at the site. The EHC-M was injected as a slurry using direct injection. The injection points were spaced 10 to 15 ft apart, which resulted in a total of 32 injection points (Figure 2). t '+IN 0 Largest predicted hot -spot area 32 } 0 Smallest predicted hot -spot area 21 .23 T'� iq L l •ia } t •1x 1 •�7- 24 AIt1 f 1+ •t1 �f s + i 1 p "t it JrCP2 17 �r%t r r l 4 } ti 'f�l�_ •ur Figure 2: Injection layout. The EHC-M was delivered to the site as a dry powder in 50-lb bags. The EHC-M powder was mixed with water on site into a slurry using a 55-USG drum with a paddle mixer at the bottom (Figure 3). The injections were performed using a truck -mounted PowerProbe (Figure 4). Using a vertical spacing of 2 ft, a total of 50 Ibs was injected per injection layer (a total of 300 lbs over G layers per point). The injection work was performed by Soart Longyear over a period of 8 days. <' .. ... Figure 3: Mixing equipment. Figurc 4: Injection of EHC-M slurry using truck -mounted PowerProbe. Adventus Group . Toll Free: 888.295.8661 • Tel: 815.235.3503 2 www.AdventusGroup.com (2;,) AbVENTLIS Field Profile The Result Subsequent performance monitoring conducted in October 2006 and January, May, July and October 2007 showed TCE below the detection limit at the former extraction well MW-41 (Figure 5). Cr(VI) was reduced by >90% to 1 l ppb one month following the injections. Four months following the injections of EHC-M, Cr(IV) in groundwater had been reduced to below the detection limit of 5 ppb. Subsequent monitoring has shown that the chromium remained immobilized. An additional monitoring well, AMW-63, was installed in November 2006 at the center of the injection zone. TCE was non -detect and Cr was measured at 9.5 ppb at this new well in January 2007. TCE has remained below the detection limit of 0.05 ppb since July 2007, whereas total Cr was measured at 6.3 ppb in the latest monitoring event conducted in October 2007. All related daughter products from TCE degradation (cis- DCE, VC) has remained below the detection limit at both MW-41 and AMW-63. 180 160 ■Chrornium 14❑ TCE a 120 100 = 80 t] 60 TCE ¢ 0.05 ppb 40 Cr(VI) < 5 ppb 20 0 Apr-06 Jul-06 Oct-06 Jan-07 Apr-07 Jul-07 Oct-07 Injection of EHC-M Figure 5: Influence of EHC-M Injections on concentrations of TCE and Cr(VI) at MW-41. The Cost The material cost of using EHC-M was $0.32/ft ($1 1.34/m'). Furthermore, continued monitoring is expected to show that ERDIISCR using the EHC-M technology offers a safe, effective and cost-efficient remedial solution for similarly impacted environments. 'All data measures total dissolved Cr, however, it is used to represent Cr(VI). In comparison tests, all Cr detected in the dissolved phase at this site has been hexavalent; the trivalent forms have been found to precipitate out of solution. For information, please contact us at. Adventus Americas Inc. 2871 W. Forest Road - Suite 2 Freeport, IL 61032 USA Ph. 8151235-3503 Fx: 815/235-3506 Email: info@adventus.us Adventus Americas (Canada) 21345 Fewster Drive Mississauga, Ontario, Canada Ph: 905/273-5374 Fx: 9051273A367 Adventus Group ■ Tall Free: 888.295.8661 . Tel: 815.235.3503 3 www.AdventusGroup.cam (6)ADVENTUS Field Profile Proven Soil Sedrrnent. and Groundwater EHC* Renwdiation TechrxAx cs 2005 DEPARTMENT OF THE NAVY SUCCESS STORY — CANDIDATE FOR CONGRESSIONAL BRIEFING Project Enhanced Reductive Dechlorination (ERD) and In Situ Integrated Biological and Chemical Reduction (ISCR) using EHC*, CH2M Hill, U.S. Marine Corps Site, North Carolina Summary Site groundwater was impacted with chlorinated volatile organic compounds (CVOCs) at concentrations as high as 80,000 ppb. A total of 24,100 lbs (10,955 kg) of EHC was injected into areas of elevated CVDCs concentration to yield enhanced ISCR. Six months after the EHC injection, TCA levels had decreased by 94% and TCE levels had decreased by 84 to 90% at the targeted areas, without generation of problematic catabolites. The Challenge The surficial aquifer consists of unconsolidated, inter -lingering beds of fine sand, silt, clay, shell, and peat beds with scattered deposits of coarser grained material as part of relic beach ridges and alluvium. The aquifer averages about 40 ft (12 m) thick and has an estimated average hydraulic conductivity of 10 ft/day (3 mlday). Site groundwater under a sensitive operational facility was impacted by TCE, cis 1,2-DCE, 1,1,1-TCA and 1,1-DCA with maximum detected concentrations of 73,000, 6,600, 24,000 and 4,800 ppb, respectively. These impacts extended from about 10 ft (3 m) bgs to a depth of approximately 20 ft (6 m) bgs. The goal was to reduce the CVDCs mass in a timely and effective manner. The Solution There were two hot spot areas on site targeted for remediation; these were located under Buildings "A" and "B". In January 2005, a total of 24,100 lbs (10,955 kg) of EHC were injected into the two hot spot areas. Approximately 13,400 1bs (9,091 kg) of EHC were injected at Building A into an area measuring approximately 1 10 ft (34 m) long x 150 ft (46 m) wide x 10 ft (3 m) deep, giving an EHC application rate of approximately 0.07% to soil mass. Approximately 10,700 lbs (4,864 kg) of EHC were injected at Building B into an area measuring approximately 100 ft (30 m) long x 150 ft (46 m) wide x 10 R (3 m) deep, giving an EHC application rate of approximately 0.06% to soil mass. The EHC was supplied as a dry powder in 50-lb (23 kg) bags and mixed with water on site into slurry. The EHC slurry was injected into a total of 47 injection locations from 10 to 20 ft (3 to 6 m) bgs. The injections were conducted using a direct injection technique and the injection points were spaced approximately 25 R (7.6 m) apart. Figures I and 2 show the injection layout at Buildings A and B, respectively. Adventus Group ■ Toll Free: 888.295.8661 . Tea: 815.235.3503 www.A d ve ntus G rou p. co rn A VMTU_S Field Profile � 43aiowia Figure 1: Injection layout at Building A. Figure 2-. Injection layout at Building B. The Result Figures 3 and 4 shows the concentration of CVOCs in groundwater at the hottest well at Building A and Building B, respectively, before and after the EHC injection. As summarized below, EHC treatment effectively removed CVOCs without the accumulation of catabolic intermediates. TCA: Six months following the EHC injection, rigorous performance monitoring showed that TCA levels decreased by 94% (from 24,000 to 1,400 ppb) at the hottest area at Building B, without accumulation of problematic catabolites. TCA levels remained non -detect at Building A. TCE: Six months following the EHC injection, TCE levels decreased by 91 % (from 49,000 to 4,400 ppb) at Building A, with a slight increase in DCE levels (from 3,027 to 5,819 ppb). TCE levels decreased by 84% (from 7.400 to 1.200 nt)b) and total DCE levels decreased by 72% (from 5,300 to 1,488 ppb) at Building B. Building A a0.vov o Before EHC 50,000 49.XT injection 40000 [3 6 months after = EHC injection 0 30.000 c m = 20.000 C U 1D'ODO 4,4W 5.819 3,0 8 18 v TCE ❑CE VC Building B 30,004 p Before EHC 25000 24,000 injection CL zv,00v [3 6 months after EHC injection e 0 is 15.000 c ar 17,000 7,400 a t� 4 r„P 5,300 5,000 400 430 78 1Nil 25 L TCA DCA CA TCE DCE VC Figure 3: CVOC in groundwater at the Figure 4: CVOC in groundlater at the hot -spot hot -spot at Building A. Building B. The Cast The material cost of using EHC was US$3.901yd3 (US$5.001m) at Building A and US$3.401yd' (US$4.401m') at Building B. With an estimated life of >36 months, continued monitoring is expected to show that ISCR using the EHC technology offers a safe, effective and cost-efficient remedial solution for similarly impacted environments. Adventus Group ■ Toll Free: 888.295.8661 ■ Tel: 815.235.3503 2 www.AdventusGroup.com ADVENTUS Field Profile �1 � Pwmi Soil, 5edirner?t and Grwndwater EHC® Remedration Ter_hixiOoes Project EHC* Treatment of{rroun& ater flume Containing Chlorinated Solvents, Confidential Client - SE USA The Challenge Groundwater at a former manufacturing facility was impacted by chlorinated solvents, primarily carbon tetrachloride (CT) and trichloroethylene (TCE), as well as organochlorinated pesticides (OCPs). Adventus employed its EHC in situ integrated biological and chemical reduction (1SCR) technology yielding safe, rapid and effective in situ treatment. After only 3 months of EHC application, the CT concentration decreased from 260 ppb to 7.8 ppb (97% removal) without the accumulation of catabolic intermediates. Treatment improved further at the 6-month sampling, showing a removal to 0.8 ppb (99.7% removal). All six of six monitoring wells met the groundwater clean up criteria for volatile organic compounds (VOCs). The Solution EHC* is a patented combination of controlled -release carbon and zero valent iron (ZVI) particles used for stimulating reductive dechlorination of otherwise persistent organic compounds in groundwater. The volume requiring treatment was 110 ft (34 m) wide by approximately 190 ft (58 m) long, from 15 to 40 R (4.6 to 12 m) below ground surface (bgs). The approach was to create three, I0 ft (3 m) wide reactive zones: one at the upgradient edge, and two in the middle of the treatment area. The theory behind this approach is that the volatile fatty acids, hydrogen, and ferrous iron released from EHC would migrate downgradient to treat the plume. Further, contact between contaminants and the ZVi that is incorporated in the EHC product would be chemically treated. A total of 45,000 lbs (20,455 kg) of EHC were applied at the site. Within the reactive zones, the application rate was 0.5% by dry soil mass; however, the overall application rate for the total area treated was 0.08%. The injections were completed in June of 2005 using direct injection (Figure 1). The first round of monitoring well sampling occurred in September of2005. Figure 1: Application of EHC slurry using direct Injection. Adventus Group . Toll Free: 888.295.8661 . Tel: 815.235.3503 www.AdventusGroup.com ADVENVUS The Result Field Profile Excellent treatment results were attained, as shown in Table 1 where the pre-treatment and 3-month post -treatment results are presented for all wells in the treatment area. The full range of analyzed chloroethenes and chloromethanes are shown in Figure 2 for the most highly contaminated well. All constituents at this well were reduced by significant amounts, with CT being reduced by 99.7%. Figure 3 shows the contoured field data for carbon tetrachloride one year prior to injection, and three and six months following the injections. All values were Iess than 1 ppb at the six-month sampling, and all VGC treatment goals were met. Figure 4 shows the degradation of GCPs over time due to EHC application. 300 2 250 LfTy 200 ■ Pre-treatment v ■ 3-months � 150 ❑ 6-months 100 U 50 C PCE TCE cis-11,2- VC DCE 260 CT CF Figure 2: Influence of EHC treatment on chloroethene and chloromethane concentrations (MW #2). Table I: Influence of 3 months of EHC treatment on TCE and CT concentrations in groundwater from all wells in treatment area. All values in ppb. MW #1 MW #2 MW #3 MW #4 MW #5 MW #6 TCE Pre-treatment <1.0 2.5 1.5 44 <1.0 1.0 TCE Post -treatment E1.0 1.1 <1.0 1.3 <1.0 <1.0 CT Pre-treatment <1.0 260 <1.0 3.7 0.34 (est.) 4.2 CT Post -treatment < 1.0 7.8 < 1.0 <1.0 <1.0 <1.0 Adventus Group ■ Toll Free: 888.295.8661 ■ Tel: 815.235.3503 2 www.AdventusGroup.com (6) ADVENTUS „oft I CT (ug/L) ,w t 90ft. o0 +o s 1 year prior to injection i_ , loft Reaci Zone 0ft. React 19 Zone Reac 3 months after injection Field Profile 6 months after injection Figure 3: Influence of EHC treatment on contoured carbon tetrachloride data. 3.5 0 — MW #1 —NM #2 MW #3 MW #4 — MW #5 MW #6 0 2 4 6 8 10 12 Time after injection (months) Figure 4. Influence of EHC treatment on OCPs in groundwater. The Timeline and Cost The EHC injection was completed in twenty days. Three months following EHC additions the concentration of chlorinated solvents decreased by as much as 97%, and as much as 99.7% after 6 months. The concentrations of all VOCs were below the site clean up criteria for all sample locations. The EHC product cost was US$0.171113 (US$61m3). Adventus Group • Tall Free: 888.295.8661 e Tel: 815-235.3503 www.AdventusGroup.com 3 ADVENTUS Field Profile #*Z�W Nover7 Sail, Sedment, and Gmun&water EHC® iiemediatibn Teclu"o9m Project Update Jan 2010 Grain Silo Facility, Kansas Lead Consultant - Malcolm Pimie, Inc. Summary EHCtL has been shown to effectively treat carbon tetrachloride (CT) and its catabolites. A large-scale field effort was undertaken to: i) validate EHC performance under field conditions, and ii) assess the effectiveness of the construction methodology (i.e., direct injection of EHC slurry). 24 tons of EHC were injected into a 270 ft (83 m) long permeable reactive barrier (PRB) intersecting the groundwater plume downgradient of the suspected source area. Subsequent field monitoring showed a 76% and 88% decrease in CT concentrations after just 4 months, without the accumulation of recognized catabolites, such as chloroform (CF). Continued monitoring has shown that the PRB has remained active for over 48 months and that the decreasing trend in CT concentrations has migrated a significant distance downgradient from the PRB with a 99.5% decline in CT observed 70 ft (21 m) from the PRB and a 91% decline observed 600 ft (183 m) from the PRB. The Challenge Site groundwater is impacted with CT at concentrations of up to 2,700 ppb. The CT plume extends approximately 2,500 ft (760 m) from a grain elevator where it discharges into a small creek (Figure 1). The remedial goal is to treat CT to <5 ppb, CF to < I00 ppb, Chloromethane (CM) to < 20 ppb and methylene chloride (MC) to <5 ppb. The CT source area is elusive, but impacts are likely the result of using CT as a fumigant in the grain silos on the site. There is a complex geologic history in the study area which resulted in a mix of interbedded sand, gravel, clay and silt. Two primary saturated sand units have been identified, named as the upper and lower saturated sand units. The upper sand unit is approximately 3 to 4 ft (0.9 to 1.2 m) thick. The thickness of the lower sand unit varies considerably across the site and ranges from 0 to 13 ft (0 to 4 m) thick. The groundwater table is encountered at approximately 23 ft (7 m) bgs at the PRB area; CT impacts extend down to a maximum of approximately 45 R (14 m) bgs. The bedrock rises to an elevation approximately 10 feet (3 meters) above the present day water table at the presumed source area. The CT is believed to have transported along the topography of the bedrock surface to the downgradient aquifer. Access restrictions due to residential properties further complicates source area clean-up. Figure 1: Direction of groundwater plume. Adventus Group • Tall Free: 888.295.8661 ■ Tel: 815.235.3503 www.AdventusGroup.com ADVEN T US Lab -Scale Validation of the EHC Technology Preliminary reactant screening was accomplished by performing batch tests and measuring changes in CF, CT, DCM and CM concentrations with time. Complete removal of CT and all its daughter products was achieved after 65 days of hatch treatment using EHC (Table 1). Table 1: Influence of EHC on CT, CF and DCM in Batch Studies Using Site Materials Field -Scale Pilot Study Field Profile CT CF DCM L] Jpg/LJ IWJLI After 14 days: Control 971 71 ND' EHC ND' 119 ND' After 65 days: Control 551 42 ND' EHC ND' ND` ND' i Detection limit was 16 µg&, "Detection limit was 100 µA In March 2005, a total of 48,000 lbs (21,818 kg) of EHC were injected into a 270 ft (83 m) long PRB across the plume. The EHC was applied at a rate of approximately 1% to soil mass into the upper and lower saturated sand units. The EHC was supplied as a dry powder in 50-lb (23 kg) bags and mixed with water (Figures 2 and 3) on site into slurry containing about 40% solids. The EHC slurry was injected into twenty-seven injection groups composed of 126 injection borings using a direct injection technique. Injection borings targeted a specific depth in either the upper or lower saturated sand unit. Each injection group was spaced 10 ft (3 m) apart. This injection approach was employed to avoid injecting the majority of EHC slurry into the bottom intervals. Figure 2: Mixing equipment used for injection. Figure 3: EHC mixed with water to form slurry. Soil samples were collected to verify proper placement of EHC. Horizontal (Figure 4) as well as vertically rising fractures (Figure 5) were observed. 11 e IQ it t 11 2 3 p 5 6 7 Figure 4: Horizontal EHC fracture. Figure 5: Vertical dipping fracture. Adventus Group • Toll Free: 888.295.8661 ■ Tel: 815-235.3503 2 www.AdventusGroup.com Z�) ADV E NTUS Field Profile The Result Figure 6 shows the concentration of CT and daughter products in groundwater measured upgradient and downgradient of the EHC PRB. The downgradient monitoring wells are located 70 ft (21 m), 140 ft. (43 m) and 600 ft (183 m) downgradient of the PRB, which equals approximately 39, 78 and 333 days in terms of groundwater travel time. Groundwater sampling results as early as four months after installation of the PRB showed a 76% and 88% decline in CT concentration at monitoring wells located 70 and 140 ft (21 and 43 m) downgradient of the PRB, respectively. Groundwater sampling results 13 to 36 months after installation of the PRB have shown a >940/0 decline in CT concentration at the core of the plume 70 ft (21 m) downgradient of the PRB. CF concentrations initially increased as a result of the CT degradation. However, by February 2007 CF had decreased to 8.4 ppb, which is below background and initial concentrations. DCM and CM has remained below the detection limits in both the inflowing and downgradient wells since the May 2006 monitoring event. The edge of the plume retrains non -detect (100% removal) for all analytes since August 2005. At the five most recent sampling events conducted in February and August 2007, April and October 2008 and April 2009, affects of the PRB were observed 600 ft (183 m) downgradient from the PRB, with a 91 % decline in CT concentration measured in April 2008 {from an initial concentration of 140 to 13 ppb} and again, no accumulation of catabolites. Meanwhile, inflowing concentrations have fluctuated with a high of 2,700 ppb measured in February 2007. Inflowing concentrations 21 m downgradientfrom PRB measured 26 m upgradient of PRB 1750 3000 - — 2500 1500 a 2000 a 1250 a ? 1 Ooa 1500 = 750 vo 1 oa0 [o] 500 500 250 0 0 -1 1 4 6 9 13 16 19 22 28 36 42 48 -1 1 4 6 9 13 16 19 22 28 36 42 48 Time post injection (months) Time post injection (months) 43 m downgradientfrom PRB 183 m downgradientfrom PRB 16 (edge ofplume) 250 14 200 12 a rL 10 a 150 a 8 u ci 6 C 100 4 U U 50 z 0 0 -1 1 4 6 9 13 16 19 22 28 36 42 48 •1 1 4 6 9 13 16 19 22 28 36 42 48 Time post injection (months) Time post injection (months) #CT tCF DCM X CM Figure 6: Influence of EHC PRB on concentrations of CT and related degradation products in groundwater. Adventus Group ■ Toll Free: 888.295.8661 e Tel: 815.235.3503 3 www.AdventusGroup.com ���AI7VENTLI� Field Profile Figure 7 shows the estimated extent of CT plume prior to and 22 to 48 months after installation of the EHC PRB. Groundwater levels measured over time did not indicate a change in groundwater direction following the installation of the PRB. i „ l Baseline March 2005 EHC Treaanard zone Monnonng Wei Ano } + CT concertralion (ugA-) y `� Preperry Lme SCALE In FEET O ]GO BOG � _ PRB r 1 •4 PRB i% ,4 February 2007 1 4W October 2008 1^ +f 5 1.' 1, .a �4 Figure 7: Impact of EHC PRB on extent of CT plume. Deb; raflufion runes PRB A August 2007 PRB A i April 2009 After an initial acclimatization period of approximately 5 months, a half life of between 1 and 5 days has been maintained for CT within the reactive zone (Figure 8). Degradation rates did initially increase with time as acclimatization occurred, but has slowly decreased since reaching its peak value of 1.3 days after 17 months, which is likely due to consumption of the EHC amendment. CF concentrations initially were detected as a result of the CT degradation (net negative half lives not shown on graph), but had decreased to below background and initial concentrations by May 2006, maintaining an estimated net half life of 3 to 5 days. ❑CM and CM have remained Adventus Group . Toll Free: 888.295.8661 . Tel: 815-235.3503 4 www.AdventusGroup.com AWIN T_] S Field Profile below the detection limits (<2 ppb) in both the inflowing and downgradient wells since the May 2006 monitoring event. Half lives were calculated using a 1 D equation assuming first order decay: C = Coe"��v) Where: C = concentration [MIL'] Co = initial concentration [MI Q k = decay constant [ l IT] x = PRB width [L] v = flow velocity through PRB [LIT] The Cost Degradation Rates within PRB 5 5 - 6 � #CF G 1 v r -- 200 40a 60O 800 1000 1200 Elapsed time since PRO installation (days) Figure 8: CT and CF half lies ►►ithin PRB. The material cost of using EHC was $371ft' ($395Imx) of PRB cross-section (270 ft long x 9.7 ft deep on average). Using an estimated linear groundwater velocity of 1.8 ft/day (1.6 to 2.2 ft/day estimated) and a porosity of 30%, the PRB is treating an estimated total of 516,000 ft' (14,600 m') of groundwater per year (270 ft long x 9.7 ft average depth x 365 days x 1.8 ft/day x 30%). With an estimated life of at least 5 years, the PRB is expected to treat a total of 2,580,000 ft3 (73,000 m) of groundwater during its life -time at a product cost of $0.04/ft3 ($1.321m'). Furthermore, continued monitoring is expected to show that ERDIISCR using the EHC technology offers a safe, effective and cost-efficient remedial solution for similarly impacted environments. The reactive zone constitutes a green solution (n❑ energy requirements) and maintenance costs are limited to groundwater monitoring over the life of the PRB. Based on observed decline in degradation rates, PRB rejuvenation requirements are estimated after 4 to 5 years. Conclusions Removal Efficiency: Groundwater sampling results have shown up to 99.5% decline in CT concentration at the core of the plume 70 R downgradient of the PRB (from an initial concentration of 1,000 ppb to 5 ppb measured in August 2006), without accumulation of catabolites. Longevity: A single application of EHC has remained active for a period of >4 years, continuously supporting >94% removal of CT, without the accumulation of catabolites. Plume Impacts: The reactive zone has had significant impacts on the extent of the CT plume. In the last 5 sampling events conducted 22 to 48 months after the EHC injections, effects of the PRB has been observed 600 ft (183 m) downgradient from the PRB, with a 91 % decline in CT concentrations measured in April 2008. For more infor;nation, please contact - John Valkenburg, Adventus Group, Direct: 517.669.5400, Email: John.valkenburg@adventusgroup.com Adventus Group ■ Toll Free: 888.295.8661 ■ Tel: 815.235.3503 5 www.AdventusGroup.com rA%v'# ADVENTUS Field Profile Proven Soil, 5edimtvzr, and Grp utiawater E H C Rernedattoo Techrintogrs s Project Update June 2009 Former Unregulated Solid Waste Management Unit, Ohio Lead Consultant— Hull & Associates, Inc. Summary Groundwater at a former unregulated solid waste management unit is impacted by various chlorinated volatile organic compounds (CVOCs), mainly chlorinated ethenes. Groundwater collection trenches totaling approximately 330 ft in length were previously constructed downgradient of the suspected source areas. In February 2006, EHC was injected into the gravel trenches to convert them into permeable reactive barriers (PRBs). A microbial culture of Dehalacoccoides species (KB-1 inoculant; SiREM) was also applied to the main trench. Subsequent field monitoring showed that trichloroethene (TCE) and cis-1,2-dichloroethene (cis-DCE) decreased below the detection limit within the trenches after just 6 months, without the accumulation of recognized catabolites, such as vinyl chloride (VC}. Continued monitoring has shown that the PRBs remain active for over 3 years and that the concentration of total chioroethenes is decreasing downgradient of the center of the PRB (over 97% removal since November 2006). A positive correlation between the presence of EHC breakdown products (TOC and dissolved Fe), Dehalacoccoides count and removal rates has been observed downgradient of the PRB. The Challenge Site groundwater proximal to a known area is impacted by TCE (maximum of 750 ppb; remedial objective = 5 ppb) and its recognized anaerobic daughter products 1,2-DCE (maximum of 5,200 ppb; remedial objective = 70 ppb) and VC (maximum of 630 ppb; remedial objective = 2 ppb). In an effort to mitigate transport of groundwater CVOCs, collection trenches measuring approximately 250 ft long were previously installed along the southern and western boundaries of the former unregulated solid waste management unit. Another collection trench measuring approximately 80 ft long was installed inside of a building (Figure 1 — red lines). The goal of this current project was to turn these existing collection trenches into permeable reactive barriers (PRBs) to passively treat the groundwater as it flowed through the newly created reactive treatment zones. The groundwater table is generally at 6 ft below ground surface (bgs) and the trench extends down to approximately 12 ft bgs. The trenches measures 2 ft wide and are filled with washed river gravel up to a foot above the groundwater table. The Solution c BUILDING I 80 ft J - - € 4 V- — Aso ft Figure 1: Groundwater collection trenches. Using conventional direct push technology, 11,850 Ibs of EHC were injected into the gravel zone to form a reactive zone thus creating an in situ PRB that would treat the groundwater as it !tows through the reactive zone (injections Adventus Group • Toll Free: 888.295.8661 . Tel: 815-235.3503 www.AdventusGroup.com (6) AD`lENTUS Field Profile conducted by Superior Environmental, Figures 2 and 3). The EHC product was delivered as a dry powder and consisted of solid organic carbon and zero-valent iron at 42%. The EHC powder was mixed with water on site into a slurry containing approximately 20 to 25 percent solids using a grout mixer. The injection points were spaced 10 ft apart, resulting in a total of 30 injection points. A total of 400 lbs of EHC (ca 200 USG of slurry) was designed for each injection point. Immediately following the EHC injections, KB-1 inoculant was added to the major trench along the property line to accelerate removal of cis-1,2-dichlorethylene DCE. No inoculants were added at the trench inside the building. Figure 2. EHC injections- ur trench along property lines. Figure 3: EHC injections inside building. Monitoring Program Following the installation of the EHC PRB, the groundwater was sampled for CVOCs on a quarterly basis at the following locations (Figure 4): -Manholes (CB-1 and CB-2), - Downgradient wells (MK-5 and M K-6), - Sidegradient well (MK-7), and - Downgradient piezometer (P5). In addition, groundwater quality field parameters including pH, DO, temperature, water level and ORP have been collected monthly. Nine months following the installation of the PRBs, the groundwater was analyzed for total iron, ferrous iron and TOC to verify which sampling locations are within the EHC zone of influence. Samples from MK-5, MK-6 and P5 were also analyzed for Dehalococcoides species. _ � X Manhole —• t t X Monitoring well > Piezometer -- t a.a,w�rwrew [a4�cer�w ■wa w�sn swewcn i _ n �• w �wraf1r •ww/JC WwGYI W1TI'a.1 -P/M%t�N.k� fa IM .. .:T •.� 4 � t - l L lo, ft-6 Figure 4: Monitoring locations. Adventus Group • Toll Free: 888.295.8661 + Tel: 815.235.3503 2 www.AdventusGroup.com (6 AWEN T U S Field Profile The Result Figures 5 and 6 shows the concentration of total chloroethenes in groundwater collected from the collection manholes at the downgradient end of the trenches. The first round of performance monitoring (May 2006) was conducted approximately three months after the EHC injections and did not show any discernible response. However, subsequent monitoring conducted over a three year period post EHC injection showed almost complete removal of all CVDCs, without the accumulation of catabolites. In the latest monitoring event, conducted in February 2009, total CVOCs decreased by >99.9% at the trench along the property line (from 2,700 to l ppb) and 99.5% at the building trench (from 1,950 to 9 ppb) compared to the initial concentrations measured in September, 2004. Manhole CB-1 (main trench) 2500 aVC 2000 a ❑trans-DCE a 1500 6 1000 scis-DCE C] 500 1TCE 0 -17 -1 3 6 9 12 18 24 27 30 33 36 Months post Injection Figure 5: Influence ofEHC injections on concentrations of chloroethenes in groundwater at collection manhole CB-1. Manhole CB-2 (building trench) 2000 - - ovc a 1500 ©trans-oCE a a `- 1000 c scis-6CE Q U 500 ■TCE O ,ter- NOW� o a Q -17 -1 3 6 9 12 18 24 27 30 33 36 Months post injection Figure 6. Influence of EHC injections on concentrations of chloroethenes in groundwater at collection manhole CB-2. In addition, a steady decline in CVDCs was observed at monitoring well MK-6, which is located 13 ft downgradient from the center of the trench (Figure 7). Eighteen months following the EHC injections total CVGCs had decreased by 99.7%; TCE decreased from 370 ppb to ND (<I ppb), DCE from 2,800 to 4.5 ppb, and VC from 510 ppb to 4.8 ppb. Subsequent measured removal rates have remained between 96.6 and 99.0% for over 3 years of PRB operation. Adventus Group . Toll Free: 888.295.8661 . Tel: 815.235.3503 3 www.AdventusGroup.com AbVtNTus Field Profile MK-6 (13 ft downgradient from center of trench) 4.000 ❑VC C 3,000 ❑trans-OCE Q. Q. `- 2,000 e.1 ■Ci5-flCE C D U 1,000 §TCE -17 -1 3 6 9 12 18 24 27 30 33 36 Months post injection Figure 7.• Influence on total chloroethenes measured 13 ft downgradient from EHC PRE. No consistent CVOC removal has been observed in the other monitoring locations outside of the trench (MK-6 and P5). To verify whether these points were within the direct zone of influence of the EHC, the groundwater was sampled for TOC and total and ferrous iron nine months following the injections. Following the injection of EHC into the subsurface a significant increase would be expected in these parameters within and directly downgradient of the injection zone. The extent of the zone with elevated levels of EHC breakdown products will depend on the linear groundwater velocity and direction. Elevated levels of TOC and iron were measured within the trenches and at MK- 6, directly downgradient from the lowest point of the trench which correlates with the CVOC removal achieved at these locations. No significant increase of EHC breakdown products was observed at the remaining sampling locations and it could therefore be assumed that the EHC PRB has not directly impacted those locations yet. This could possibly be explained by the flaw -pattern created by the gravel trenches installed into the low - permeability clayey soil; the groundwater would be expected to be directed through the gravel collection trenches (as designed) and to be primarily released at the lowest point by collection manhole CB-1. This would also be supported by the significant and fast removal of CVOCs at MK-6 directly downgradient from manhole CB-1 (Figure 8). Figure $: Approximate location ofgravel trench, manhole CB-1 and MK 6. Adventus Group ■ Toll Free: 888.295.8661 • Tel: 815.235.3503 0 www.AdventusGroup.com ADVENTLIS Field Profile Nine months after the EHC injections, the groundwater was also analyzed for Dehalococcoides at MK-5, MK-6 and P5. There appeared to be a positive correlation between the presence of EHC breakdown products, Dehalococcoides levels and CVOC degradation (Table 1 and Figure 9). Table 1: TOC. iron and Dehalococcoides measured in groundwater and corresponding CVOC removal rates nine months followingcr the iniection ofEHC and KB-1. Total Ferrous TOC Fraction Dehalococcoides CVOC Iron (mglL) Dehalococcoides" Count6 Removal` ( [Ironug/L MK-5 5400 0.14 7 2-4% 9 x 10s per Liter 61 % increase MK-6 162000 101 1100 11-28% 4 x 10' per Liter 99% decrease P3 3560 0.14 10 1 2-7% 1 3 x 10' per Liter 1 86% decrease a. Calculated by dividing the number of Dehalococcoides by the total number of bacteria b. Dehalococcoides assumed to contain one rKNA gene copy per organism: number interpreted to represent the number of Dehalococcoides present in sample. c. Change in concentrations of total chloroethenes nine months following injections. 10D% 0 0100% ro 8[Y96 + 80% c 6095 a 60% E >= 404o U 40% + 20% > 20% try o% 1 10 100 1000 1.0000 0.1 Toc Img/l] Figure 9: The Cost 1.0 10.0 100.0 Ferrous iron (mg/1) 1,000.0 Correlation between CVOC removal rates and TOC I ferrous iron in collection manholes and downgradient sampling locations. The material cost of using EHC was $12/ft2 ($1291tn2) of PRB cross-section (a total of 11,850 lbs of EHC injected into PRBs measuring a total of 330 ft long x 5 ft deep on average). Regulatory Contact OHIO EPA For infortnation, please contact its at: Adventus Americas Inc. Adventus Americas (Canada) 2871 W. Forest Road - Suite 2 21345 Fewster Drive Freeport, IL 61032 USA Mississauga, Ontario, Canada Ph. 815/235-3503 Ph: 9051273-5374 Email: info@adventusgroup.com Adventus Group • Toll Free: 888.295.8661 • Tel: 815.235.3503 5 www.AdventusGroup.com (6� ,,)ADVENTUS Field Profile Proven Soil, Sediment and Groundwater EHUM Remediation Technologies Project Installation of EHCTM for Treatment of Chlorinated Volatile Organic Compounds, Site in Texas Summary Adventus installed 1 ton (909 kg) of EHC into a trench and 3 tons (2,730 kg) of EHC into an open excavation at a site that has groundwater contaminated with a mixture of chlorinated solvents. The Challenge Two areas of contamination were targeted for treatment. The first was a dissolved plume migrating from a source zone through a thin permeable soil unit overlying bedrock at approximately 12 ft (3.7 m) below ground surface. The second was an open excavation containing groundwater, after contaminated soil had been removed. The client's site was contaminated with a large range of Contaminants of Concern (COCs) at the two locations (Table 1). Table 1: Initial Concentrations of Contaminants of Concern in the Dissolved Plume and Excavation Areas Initial concentration Initial concentration for Contaminant of Concern for dissolved plume excavation ( ) { ) Tetrachloroethylene (PCE) 1,400 23,000 Trichloroethylene (TCE) 410 8,700 cis-1,2-dichloroethylene (cis-1,2-DCE) 3,900 4,000 trans-1,2-dichloroethylene (trans-1,2-DCE) 110 90 1,1-dichloroethylene (1,1-DCE) 410 3,600 Vinyl chloride (VC) 17 250 1,1-dichloroethane (1,1-DCA) 63 80 The Solution To treat these contaminants, EHC was selected for in situ treatment of the contaminants. Adventus recently adapted its patented combination of controlled -release solid carbon and zero vaient iron (ZVI) particles to yield EHC, a solid material for stimulating reductive dechlorination of otherwise persistent organic compounds in groundwater. Following placement of EHC into the subsurface, a number of physical, chemical and microbiological processes combine to create strong reducing conditions that stimulate rapid and complete dechlorination of organic solvents and other persistent compounds. A permeable reactive barrier (PRB) was constructed to intercept the dissolved groundwater plume (Figure 1). The PRB was constructed with an excavator by digging a 3 ft (0.9 m) wide trench down to the Adventus Group • Toll Free: 888.295,8661 • Tel: 815.235.3503 www.AdveniusGroup.com (p& AD V EN T U S Field Profile top of the bedrock, followed by filling the bottom foot with a mixture of EHC and sand (Figure 2). Only the bottom foot required filling because the groundwater table was less than a foot above the bedrock, and the permeable soil unit was also at this depth. The remainder of the PRB was backfilied with pea gravel. Figure 1: d Backfilling of PRB with pea gravel. Figure 2: EHC and sand mixture used to fill trench and excavation. The bottom 1 ft (0.3 m) of the excavation was lined with sand and EHC (Figure 3), and the downgradient wall of the excavation was lined with a 3 ft (0.9 m) high, 3 ft (0.9 m) wide bench of sand and EHCTM. The 3 ft (0.9 m) high bench would ensure that any water exiting the excavation at the downgradient side would come into contact with the sand and EHC mixture. Figure 3: Lining of open excavation with sand and EHCT•K mixture. Adventus Group • Toll Free: 888.295.8661 ■ Tel: 815.235.3503 2 www.AdventusGroup.com C46�i) ADVENTUS Field Profile The Result The installation was completed in early 2004. To monitor effectiveness of the installation, wells were placed upgradient and downgradient of the OPRB as well as within and downgradient of the excavation. Figure 4 shows results at the excavation (shows complete VCC removal from the source area). Two pairs of upgradient and downgradient monitoring wells are being used to evaluate the effectiveness of the PRB for treatment of the dissolved plume. The data for the first upgradient-downgradient pair are provided in Figure 5, with the upgradient data on the left-hand side, and the downgradient data on the right-hand side. Large reductions of all of the constituents present continue to be observed after 21 months of field data. Data for the second well pairing are shown in Figure 6, with lower Overall reductions potentially due to flow heterogeneity, but consistent performance over time. 180.000 160.000 140.000 120,000 100.000 m 80.000 60.000 40,000 20,000 0 t POE t TOE -� cis-1,2-DCE -o-trans-1,2-DCE -w-1,1-DCE VC -6 -4 -2 0 2 4 6 8 Time after Soil Excavation and EHC Installation (Months) Figure 4: Influence of soil excavation and field installation of EHC on VDC within excavation. 3,000 Upgradient 3,000 Downgradient t PCE -+• PCE z,oan -TCE 5 2,000 ♦-TCE o �-c-1,2-ncE c — c-12-DCE +t-1,2-13CE —t-1,2-DCE —1,1-DCE —1,1-DCE °�' 1,000 —VC v 1,40U —VC C A U U 0 0 0 5 10 1s 20 25 0 5 14 15 20 25 Time (Months) Time (Months) Figure 5: Influence of EHC on groundwater chloroethene concentrations for upgradient and downgradient well pairing N. Adventus Group ■ Toll Free, 888-295.8661 ■ Tel. 815.235.3503 3 www.AdventusGroup.com C160 ADVENTUS Field Profile 3,500 3,000 2,500 2,U00 i 1,500 y 1,000 U Soo 0 0 I Tt, vrari i Pn t 5 10 15 20 Time (Months) 3,500 -PCE 3,000 -TCE °�-" 2,500 -c-1,2-DCE a~ 2,000 ^ t-1,2-DCE V 1,500 -1,1-DCE -VC o 1,000 U 500 -1 0 25 0 PCE rCE c-1,2-DCE t-1,2-DCE 1,1-DCE VC 5 10 15 M 25 Time (Months) Figure 6: Influence of EHC on groundwater chloroethene concentrations for upgradient and downgradient well pairing #2. Bench scale data for PCE and breakdown products were available from two sites other than this one. Using these data, a model was prepared to analyze the expected concentrations downgradient of the trench. The modeled data were compared to observed concentrations in the field (Figure 7). The results show that the field data, after acclimatization, meet or exceed the concentrations drop expected based on both sets of bench data. The Timeline ► VYA I Ww.4s - a e Y HaH life (1.5 or 7h) based on lab data `. M W -48 Modeled influent Observed influent Half life 1.5h y MW-46 & Modeled effluent ~ Observed effluent k R Half life 7h Figure 7: Predicted PCE concentrations downgradient of trench based on bench -scale half lies. The installation was completed in less than 2 days. EHC performance was observed quickly and for an extended period of time (approaching two years at the time of writing). Adventus Group a Toll Free: 888.295.8661 ■ Tel: 815.235.3503 �l www.AdventusGroup.com AINXIETHS Field Profile Proven Sail, Sedimerht, and Groundwater ElLFI'4TM 14ernediation Technologies Project EHCTm Treatment of Chlorinated Ethenes, Ethanes, and Methanes in Saprolite Soils and Partially Weathered Rock, Manufacturing Facility — Western NC Summary Field scale pilot tests were performed to evaluate the performance of enhanced reductive dechlorination (ERD) of chlorinated aliphatic hydrocarbons (CAHs) at a manufacturing facility in western North Carolina. The key CAHs found in groundwater at the site include 1,1,2,2 tetrachloroethane (TeCA), trichloroethene (TCE), and chloroform (CF), as high as 350, 1,100, and 1,500 ppb respectively. Adventus employed its EHC in situ integrated biological and chemical reduction (ISCR) technology yielding safe, rapid, and effective treatment. Eleven weeks after injection, concentrations of TeCA, TCE, and CF in a nearby well reduced by 86%❑, 98%❑ and fife%❑, respectively. After approximately 26 months, the key CAHs in the monitoring wells in the silty -clay (saprolite) zone indicated an overall decrease of up to 95%❑. The Challenge The site is located in the Appalachian Piedmont physiographic province (mountainous) of North Carolina and consists of saprolite soils overlying a partially weathered rock (PWR) zone. Fractured bedrock underlies the PWR zone. Groundwater concentrations have rebounded since historical treatment, indicating the potential for continuing sources, desorption, or problematic hydrogeology or microbial conditions at the site. Presence of low permeability soils, low groundwater velocities and a mixture of CAHs presented a unique challenge for remediation. The Solution EHCTm is a patented combination of controlled -release carbon and zero valent iron (ZVI) particles used for stimulating reductive dechlorination of otherwise persistent organic compounds in groundwater. Two pilot -scale permeable reactive barriers (PRBs) were installed in January 2005 to evaluate the efficacy of EHC to control and treat the chlorinated solvents plume in two areas of the site. The first injection PRB was installed into the saprolite between 10 and 25 ft below ground surface (bgs) and the second injection PRB was installed into the partially weathered rock (PWR) between approximately 30 and 35 ft bgs. Each PRB measured an estimated 40 ft long x 20 ft wide. Approximately 3,000 pounds of EHC was injected in two Geoprobe boreholes in the saprolite zone and 3,500 pounds of EHC was injected at four drilled locations in the PWR zone. Adventus Group ■ Toll Free: 888.295.8661 ■ Tel: 815.235.3503 www.AdveniusGroup.com ADVENTUS Project Description The presence of low permeability soils and the PWR zone required hydraulic fracturing to inject EHC at the site. Injection pressures and ground uplift were monitored, and soil boring and monitoring wells were installed to verify fracture propagation and distribution of the EHC. Soil samples collected around the injection points indicated the presence of EHC material. Based on field observations, the influence of EHC injection extended in a zone approximately 10 to 15 feet around the injection point in the saprolite. The injection in the PWR zone was controlled by the fracture orientation. The presence of high concentrations of total organic carbon and metabolic acids and negative oxidation- reduction potential in the nearby monitoring wells indicated that the injected EHC created anaerobic zones favorable for CAH reduction. The Result Eleven weeks after injection, concentrations of TeCA, TCE, and CF in a nearby well in the PWR zone reduced by 86%, 98% and 66%, respectively. After approximately 26 months, these compounds in the same well reduced over 98%. Potential degradation products of these CAHs such as 1,1,2- trichloroethane, methylene chloride, cis-1,2-dichloroethene, trans-1,2-dichloroethene, vinyl chloride, ethene, ethane and methane were detected in low concentrations, as shown in Figure 3. The concentrations of TeCA, TCE and CF initially increased in one downgradient well in the saprolite zone and gradually decreased. The test results indicated that reductive dechlorination was delayed in the Adventus Group ■ Toll Free: 888.295.8661 ■ Tel: 815.235.3503 P www.AdventusGroup.com (46) ADVENTEIS Project Description aquifer despite the presence of dechlorinating bacteria such as Dehalococcoides, Dehalobacter and Methanogens. The likely reasons for the slow treatment response are the slow rate of groundwater flow as well as desorption of CAHs. After approximately 26 months, the key CAHs in the monitoring wells in the saprolite and PWR zone indicated a decrease of up to 99% (see Figures 1, 2, and 3). Despite the reductions in CAH concentrations, organic carbon is still present supporting the reductive dechlorination process in the saprolite and PWR zone. 5 2� V_ - 110 �loft I 0 I4 1 EHCMW- 2b ' t� 600 f — 400 -- J ERC 9 W-4D2a 4 ® Existing Deep Saprolite Monitoring Well ■ EHC Hydrotrac Injection Location SCALE IN FEET GROUNDWATER FLOW February, 2005 TW-403 TW-4❑ 1 ■ � 1 I � rya 1 ■ , HCW 4D2 ..� � f Apri I, 2007 GROUNDWATER FLOW Figure 1: North plume of CF before and two years after EHC injection in the Saprolite and PWR zone (pg[L). Adventus Group ■ Tall Free: 888.295.8661 * Tel: 815.235.3503 3 www.AdventusGroup.com ADVENTUS Project Description 70 _ I i r If f Ir ®:st ! 11 1 1 1 1/ 1 PT � I 25f 160/' r I 1 87 \ _ / 1 1 l 70 r r PTMW-2Sb — / r PTiW-2S` — 75 I _ � EHC7 2 S7 EHCMW-W-2S2 v — — 2 t- 37 l ■ February, 2005 TW-2S PTMW-2Sa + 4 ) <0.8 � 2_, PTy W-2Sb — PTIW-2S I + I 1 EHCMW-2S1 EHCMW-2S2 + �. + ■ ® Existing Saprolite Monitoring Well (ug/L) ■ EHC Hydrotrac Injection GROUNDWATER FLOW Location April, 2007 a 6 io SCALE IN FEET Figure 2: South plume of CF before and two years after EHC injection in the Saprolite zone (pg/L). Adventus Group ■ Toll Free: 888.295.8661 • Tel: 815.235.3503 4 www.AdventusGroup.com C6;i) ADVENTUS Project Description Chlorinated Ethanes In Well EHCMW-4D2a 250 200 c 150 P 100 Cc50 U 0 Dale Is TaCA ■ 1.12-TCA 0 12-DCA Chlorinated Ethanes in Wall PTMW-2SA 45 40 35 ` 2s 20 G � s5 c V 10 5 D p�'+ ph ph py p5 Ah p6 5P A6 p6 QC p'1 ¢'1 FeO vo )p "P, O� O� �gG PQ )ac pA 06 O� Or 0 Date ■ 1,1,2,2 TeCA ■ 1,12-TCA o 1,2-DCA Chlorinated Ethanes In Well EHCMW2S2 400 0 3 fi U CP Qi64c�PQ�y�°,J`�]eP''�0� ova °Ap1PQ�A� Data ■ 1, 1.22 Te CA ■ 1,1,2-TCA 112-D CA asD 3oa 2so 2vv 1so l00 50 a Chlorinated Ethenes in Well EHCMW-4D2a `o ao a 0 C6- to p� ph to AF' _}� A� f� A� 'A 01 Fad �`>c ! 4� O� 4 �Jc p.$ O� Dafa ■ TCE ■ cis-1,2-DCE 13 VC 131rans 12-Da Chlorinated Ethenes in Well PTMW-2SA 100 - - 90 1 80 70 so s0 QD d 30 c 20 U 10 0 1`3 41 py KP oh Ay o� 01 01 a6 0) Ay o� o� k. V4f lac P$ O`Y Q <-O Q � ��c P� p�` . 6 <V P� Date ■ TCE ■ cis-12-DCE 13Irans 12-OM 0 VC Chlorinated Ethenes in Well EHCMW-2S2 700 -- - — 600 Soo 400 300 200 U 100 O mph oy oy `.oy o6 oy rR6 06 `p1p Lpy o1 �o� 11V pR v° PEA C� am k1P Vlt �� PO du Og gym° PQ Data ■ TCE ■ cis-1,2-DCE 0 trans 1,2 ACE D VC Figure 3: Chlorinated ethanes and ethenes in saprolite (PTMW-2SA, EHC MW2-2S2) and deeper PWR (EHCMW-4D2a) monitoring wells. Adr►entus Group ■Tall Free: 888.295.$651 •Tel: $95.235.3503 5 www.Advent usGraup.cam 0EHCTM Installation Procedures � AI�VENTL�S 6 Direct Injection Introduction EHCTm is the only in situ chemical reduction (ISCR) substrate available for removing persistent organic and/or inorganic contaminants from the subsurface environment. EHC has been employed for source area treatment, plume treatment or plume management using permeable reactive barrier (PRBs). EHC slurry (10 to 45% solids) has been added to numerous aquifers using a variety of injection methods, including hydraulic fracturing, pneumatic fracturing and direct injection. Liquid formulations of EHC, EHC-A, have been added to existing well screens. And solid EHC substrate has been directly mixed into the soil using deep soil mixing equipment or placed into an open excavation or trench. The choice of installation method will depend on your site -specific conditions, including treatment depth and geology. To date, the most commonly practiced in situ application method has been direct slurry injection. This document provides guidelines for preparation of the EHC slurry and using direct injection technology for subsurface application. EHCT"R Slurry Preparation EHC is delivered as a dry powder in 50-lb bags or 2,000 lb Supersacks. EHC consists of solid organic carbon and zero-valent iron and will be mixed with water on site into a slurry containing an estimated 30% solids (i.e., mass of dry EHC divided by total mass of slurry including EHC and water). This results in a final wet density of the slurry of approximately 1.15 g/cm3. EHC slurry -> Adventus recommends preparing the EHC slurries on site in a mixing tank with a paddle - mixer at the bottom. The slurry is then transferred to a feed tank connected to the injection pump; that way the slurry can be prepared continuously while the injections are performed. For example, the ChemGrout mixing system with two mixing bins (www.chemgrout.com/500hp.htm) has been utilized. The EHC slurry mixes quickly in these types of systems (about a minute) and the injections can proceed without interruption. F 2-bin mixing system The EHC slurry has also been prepared in a variety of other ways; everything from in -line automated mixing systems to manual mixing using a hand-held drill with a mixing attachment. However, particularly for larger projects, Adventus recommends having a mechanical mixing system available on site. (6) SOLID SOLUTIONS. SOLID TECHNOLOGY. 1:1 Visit our Web Site at www.adventusgroup.com �/ EHC'rm Injection Approach The preferred approach for the injections is often in the top -down direction using an injection tip that directs the slurry horizontally, for example Geoprobe's pressure activated tip has been successfully utilized (http://www.geoprobe.com/products/geoprobe — accesso ri eslinjprobedesc.htm). For each injection point, the rods are initially advanced to the top of the targeted depth interval and a specified volume of slurry is injected before proceeding down to the next depth. The injections are to be evenly distributed over the targeted depth interval, using a vertical injection spacing of approximately 2-4 ft. We recommend injecting a small volume of water (15 USG) to clear the injection tip between batches and at the end of the injection. Pump Requirements Test of pressure activated tip with 4 horizontal openings. Adventus recommends using an injection pump that is capable of generating at least 300 psi of pressure at a flow rate of 5 gpm. The pump needs to be able to handle solids. For example piston pumps, grout pumps and progressing cavity pumps have worked well in the past, with a preference towards the piston and grout pumps. EHC would typically be injected at pressures of 100 to 200 psi, however, higher pressures are sometimes required to initiate the injection. It. would be ideal to have a higher pressure pump available on site that can generate over 500 psi and as high a flow rate as possible. Deeper installations may require higher injection pressures. Other We recommend having sufficient rod length and injection tips on site to allow 3 to 5 injection points to be capped overnight to prevent backflow if need be (more for shallow depths and less for deep installations). Health and Safety EHC is completely non -hazardous and safe to handle. The EHC MSDS is posted on our web site at www.adventusgroup.com/library/msds.shtmi. When working with EHC, it is recommended to use standard personal protective equipment, including safety glasses, steel toe boots, nitrile gloves, hearing protection (when Geoprobe is operated) and hard hat. Dust mask may be required when in close contact with EHC under certain conditions. For information, please contact us at. Adventus Americas Inc. 2871 W. Forest Road - Suite 2 Freeport, IL 61032 USA Ph. 815/235-3503 Fx: 815/235-3506 Email: info@adventus.us Adventus Americas (Canada) 21345 Fewster Drive Mississauga, Ontario, Canada Ph: 905/273-5374 Fx: 905/273-4367 SOLID SOLUTIONS. SOLID TECHNOLOGY. 2 Visit our Web Site at www.adventusgroup.com 46) �/ A Cleaner World 9162 ATC Project No. 45.34341.4124 Injection Permit Application April 9.2010 APPENDIX 5: DIAGRAM OF INJECTION SYSTEM =:1 Adventus EHC Process Flow Dilution Water With Flow Monitoring Double Piston Pump @ 30% Water From Hydrant, Water Truck, or Storage Tank I Injection Rig External EHC Mixing Tank EHC Mixing 1 Feed Tank Moyno Progressive Cavity Pump @ 23°/° Pump @ 30% 9 GPM @ 1500 PSI 7 GPM @ 300 PSI 5 to 15 GPM @ 300 PSI Instantaneous Pressure Monitoring, Flow Calculations Direct Push Point(s) 1 to 5 Foot Bottom -Up or Top - Down Injection Tools, 1.5" OD and pre -strung 2.125" OD Truck Mounted, Track, and Limited Access ❑PT Rigs ATC — A Cleaner World #162 — Greensboro, NC 16.07.09 "Expect Perfornwnee" 6 rrnn z _ x x a ❑0 Ln\ Lair Lair m m 10 0c i � � � / - ------ - �a0z C) a I �� SEC _ 1 1 v 2 �E . 1 v M m NUE rn ' 1 1 1 ' , 0 ,n ❑ NOTES: TITLE r l UU Kr_ L S;TE MAP A CLEANER WORLD #162 4506 HIGH POINT ROAD ASSOCIATES INC. GREENSBORO, NORTH CAROLINA Raleigh, North Carolina 27604 (919)671-0999 FAX (919)871-0335 CAD FILE DSCA# PREP- 6Y i4EV-13Y SCALE DATE PROJECT NO. 125335TDW0 41-0024 N5 SV 1" = 200' 102I -1-2010 45.34341.4124 cl ci 1 / _ mw-14S/D \/ a cn Sri 0 co IMw-2 (s NM/DRY) t d �r 1 1 t� l tr7 �(860,28) �` (0 860.7fi� 1 F m ' / y � � f/ I � � Q MW-9CN ' (847.57) ' o cj 848 _ 1 Mw-1 I 1 852�` 1 MW-8 - ��� I ��T�'A `�� / r , _ 1 854 �� (852.81 t MW-3 c� o o i (859.97) I c W cv 858� A— MW-lhr 9� f MW-13 860,03)� Q / N ]I 85 r1(857.26) ITE Mw-5S/0 �d m ABANDONED i2 0, I m> ' 1 ' MW-1 I It /(854..29 �� Ui - qr (860.20) t .0 / 1 1 MW-12S/❑ I ( �_ [D 858.68} t O (51 55 �, I MW-1 GS/l/D 0 Z cn 4r� 88 f I t �`a� {S 839.35} U J Z 0 a 1 1 (D 839.25) MW -45/D 0 [V Q 1 1 1 [s 860.11) I ���� �- r' d U (D 859.98) I `� j o= N H car p 1 M W -18 I I L. 1 lJ O pC o J J � 0 1 -- (s 860.07) - Lij o o Z It Of Mw-1OS/D � Q w = � (S 344.20) Z { D m 1 - 1 {D 344.02} C7 Q = cn Ln Z -i cow W, W r�0 u o LEI � Ln r 1 Mw 7s/D (5 854.19) 4� _17 z (D 853.27) �s 1 ($51.53) 1 CL I � I �11 � ► � z 1��_ 114 I \�S Li nJ ,6 - 1 1 111I 11�i ��_ I , ' 1 LEGEND: � I 1 ` ry � �S f F�1 1 o rn it z o EXISTING TYPE II MONITORING WELL 1 1 f Q z � j ¢ o + EXISTING TYPE M MONITORING WELL 1 1 MW-65/D 1 o a a 1 1 gig — GROUNDWATER ELEVATION CONTOUR (ft.) 1 (S 861.12) (859.97) GROUNDWATER ELEVATION (ft.) (D 860,23) { I I I d N o ui s— INFERRED GROUNDWATER FLOW DIRECTION - 1 I -_. O I , I � ' � � r F (NM/DRY) NOT MEASURED/DRY x 0 200 400cl 17 � d 1 z� W �r t j YIELL HOT SAIIPLE01oRr z LL 1'r] m if iim 0 0 �1yr= A DONED-11 0 1� W-15 1 MW -12S/D W-185�% f <C.0007 ) 1 (5 C0A007) i _ (5 0.514) 1 1 MW-12S 12/47 HATER x1+zoos iLlWC+11.ORAREnmErE <0.0007 TR1CtLOROETHfLENE mg/L <0.001 �,z�1nLORapFwE r,yll <0.001 a.i.-uaauraxnwcmod <0.001 VINYL CHLORIDE mq/L <0.001 MW-8 1211F12m ,x/17/xaDa !Tt4ptORORcnm ffkg/t 0.00073 TRICHLOROETI'MM mq/L 0.0065 os la-wPLaROET,Wt iwall <0.001 ,.e,�,a-oatieaoenwc <0.001 VINYL CHLORIDE m /L <0.001 7EI%A0k0 XW"lM <0.0007 TRICHLOR0ETH,7EHE mg/L <0.001 :,r1.x-o1c,LQIopERwrt wgM1 c0.001 .�,�+:-0oLOROE,1wc coon+ VINYL CHLORIDE mg /L c0.00+ MW-1 br , ,E mocoRORESHI m 0.730 T@CHLoROEYHW_EHE reg/L 0.100 w-t,-o01L0MKQ0JW n,A- v J00 �..�, a-aawroEnwc mq/L D.00679 VINYL CHLORIDE mg/L 0.093 MW-1 SR"DWATER tq 1al2om ,ETRACFapItTMYCO,E 0.590 TFKKOROETM.ENE mq/L 0.0m .*-1a-0CSLOROETKVC -aA (Lisa t ,s-Dmaowm w r.qk 0.00t VINYL CHLORIDE mg/L 0.030 _ 1 i MW--2 12� 1° 2Ma* nTRAaanR0FZnmpE 0.0011 TRcHLoROET,YLENE mg/L 0.005 "A 0.490 �1a-ooLanLTwAE mall 0,004 VINYL CHLORIDE mg/L 1.006 /1)W-14S (DRY) (D <0. C0.0007) r� • Mw-13 CROUHONVFTER ,z ,a xooe Wmm .oROR[nnL€re <0.0007 nuCHLOROETRYLENE .rrq/L <0.001 ewFa-cC+aG17Et,WE n4A <0.001 •..-19-a1raLPRORHVC 50.001 VINYL CHLORIDE m GROUNP ATER Mw-1 1 �nmEHE "IT TTdC+ILDROETHYLENE mg/L <D.001 �,.x-o�a,taam,wx mv/L 0.0023 asr-Ta-vo4dgcnwc m4A <0.001 VINYL CHLORIOE m /L <O.DOI (D <0.0057) / (D 0.22) �: Mw-1 MW-2br `1 /;;°;OW (0.590) TEnVZ LOR02VHn LD,E rr4/L 0, W W - 2 b r 1 Tw-HLORDETHYu>E mg/L 0.019 (0.850) _ o+-,a-pC1MnROLT,NML mcA 0MO 1 MW-4S/❑ ,rasa-,.:-mmomomwm AA <0.005 1 i (5 <0.0007) VINYL CHLORIDE mg/L <0.007 (D <0.0007) 1 M 1 1 / i MW-1$5 WOUND TER ,2/14/2wa TerlGaQORORET,mEHE 1r,y 0.014 TR,CitMYI;TH+'LF-IrE mg/L CM24J e.-,a�o+nRxPw,c r�g/L 0.031 rare-+.7-mwoRopTFwHe mull 0.0006 VINYL CHLORIDE m L <0,0005 GROUNDWATER MW-18❑ q/T9 YDOa RTRm -ORaRErH*smE OWL 0.22 TRICHLOROETHYLENE mg/L O.D250 da-,3-Plda-pmErHME mpA O.O3B ewr-ra-mtiq�gEsFRr[ m A <0.005 VINYL CHLORIDE mg/L 0.0017 1 , i LEGEND; MW-4S 12P7 2008 ,2/n 0Da TETRACKLROREPMEW C0.0007 TAk7RflROETHriENE -IL c071 �,2_ppRpRp[T,w,E mplL CO.ODI �1aw4 <0.001 VINYL CHLORIDE m L <0,001 CROM MATER MW-40 12 17 ZON 7E,>uuao *ft7 rLm mqA <0.0007 TR,CHLOROErRriENE mg/L <0.001 u�,a� myL <0.001 r.a..-lr-au.uRacnwe:lk <0.001 VINYL CHLORIDE mg/L <D.00T 1 GROUM2WATER MW-65 ,x 1a/20W Trm oIDAOPETftmE 0.0011 TRICHtORuETHYLEHE mq/L C0.001 aI�11-olnit.gRc�mwc mglL C0,00+ va,.-1a-r.O0.gIgaPMIL rr,A <D.001 VINYL CHLORIDE mgA <0.001 EXISTING TYPE II MONITORING WELL -W '%, ROUNC" EXISTING TYPE III MONITORING WELL � ^4/L vOOe M CHLOROETHYLPNE mq/L 4.07 - TETRACHLOROETHYLENE CONTOUR LINE mg/L �6-12-004,aeocT4%,c mplL <D.IX 4s,.-Ia-� cOAC (<5.0007) TETRACHLOROETHYLENE CONCENTRATION mg/L 1 (NS/DRY) NOT SAMPLED/DRY VINYL CHLORIDE m L <D_DE MW-14D i1❑Rp,x'p7O�TER <0.0067 TRIC}7Lpp0EftSYLERE mq/L <O.DO, La-,}-oiaw�ucrlwlE ,.wIL SO.001 VINYL CHLORIDE m L <0.001 - Mw-3 GROUNDWOR 7£RACIDROREFWfLVIE O.M TFamLOROETHYLENE mg/L 0.038 e-,F-ca+aaoEnwE . aA 0.022 ,rsri1,T�DpTyy[ <0.005 - ngll VINYL CHLORIDE mq/L c0.005 N � w n m a O1 _I U N N a N 6 o Q co 1� r. C4 n � C 0 L) O C) Lu N 2 m ' ¢ m Mw- t 6s/I/D y n 77 (5 <0.0407) Q s (I <D_0007} w 1 fi5/I/D -�Mw-1 Ds/o (1 Lj (S D. J (❑ 0.140) TrrA+CHIARORffHrLIME m <0-0007 TF11CHLORCETHYLENE a,g/L <0-001 C.-12-ocwJRpEnWrt.yx <0-001 ae 1,2-004DWEnwc rrqA CO.00I VINYL CHLORIDE -A 40.001 Mw-1 ss GROU MOT`� ,x/,a/240a 1ETaan LORORcrFnwrE <0.00D7 TRICHLOROET„YLEHE mg/L <0.001 ,A._,2-pp,LpppE,µy4 ma/L c0,001 1.s.-1.2� -9A <0-001 VINYL CHLORIDE mg/L <0.001 ¢ Q Z Z m C�7 J w Z oa 0 u N ¢ z `_° < v Z O O < J L.L Q Mw-161 D "12/18/2006 TCHUC DRORCTHnex <0.0007 TRICFILOROETHYLENE mg/L I <0.001 o-tta-aK,a.oROLnwc rr%A <0.001 ,,a-01aa.amEl,wE <0.001 VINYL CHLORIDE m A I <0,001 Li) rJ TS Mw-1 sD ,2fis1low wMCA MEnmmrc 0.0021 TMCHIDPOETHI-ME mq/L <0.001 e.-,.2-0cHLur�ETFwrc mq/L <0.001 , sa-oouoaoEn.vc "A cO,ODI VINYL CHLORIDE m,11 <0.001 Q LL �=o 0Iv 0 d a Z m Q T Ln Liz JCpW Lr] �7 CJ La w n 1 of LC] Cf a N MW-17 MW-75/0 (0.0098 1 1 (D 0.021) 1 W 65/❑ MW-75 BAOURDRATER 1x/18I10G8 TMMHLORwcnmfw OAN TRN]ILOROEI}„'L61E ,ng/L <0.001 wr-la-ocFwnaocTFwc <O.00+ VINYL CHLORIDE mq/L <0.00+ F C7 ¢ c� i ` ry !1 - ' (S 0.00f1) L (D 0.0088) MW-7D ,s/sooa MWZft ORORERrrLME 0.021 TMCHLOROETHnEFtE "A <O.00T .-, s-ac RCROEr Lu,E mgJL [O.DOT 4 1.2-MMtOR rTeANE COAOT VINYL CHLORIDE mglL <0.001 M W -105 1 2/18/wow T MCKA)� 0.110 7R1CHLORQEmmENE mg/L OA049 �,s-olovnwcnv+E +wlL 0.0044 eaa-rs-0a.nRocnL�wL c0-OO+ VINYL CHLORIDE mg/L <0.001 KIw-1 OD T TFnacHL>aartn+nmrtlmA 0.740 TIROH� mgA 0-0021 ew-,z-DP441oaK%K rr.a/L 0.0028 `...-,a-xranpoEnw�[ nq/L <O.001 VINYL CHLORIDE mg L C0.001 Z Z Z 7 a LLA 0. Q I a La Ld a2 x P W 1 2 z a F 1 1 ti l f 1 MW-17 12/15/ m MRACAIORDRrrmo E mqlL 0.00098 TR,CHLDROETHYLERE mq/L [D,001 ,,=-pplgapLTrrWE . A <D.00+ ean.-12-00 nrom.wE <0,001 VINYL CHLORIDE mq/L <0.001 4 0c N Ln 2 Ldcr Vi C) a U 7 2 p Urr U z r ` ■ I { 1 mri [00 0 , 2/,7 sDos TETf0,L7kORORETRftf11E mq/L C0.0007 TRICHLOROETHTLF7IE mq/L 0.0T6 o,-,alan -DaROErIwrE myL 0.0049 vrw,,x-aclauRxiwrc n.L/L C0,001 VINYL CHLORIDE mq/L <0.001 n m _ 1 r� z o - � - 1 se44 _ 1' 1 1 4 1 � I 1 ' 0. 1 - - — 1 *-h - 1 i 1 1 • • Polrvr — 1 I m \ Q 1 J\ 1 NOTES t. BOLD CONCENTRATIONS ARE ABOVE SURFACE WATER STANDARDS. 2. SURFACE WATER SAMPLES WERE COLLECTED ON 12/19/2008. L _ r Ln 1 1 Ln V � TITLE FIGURE 6 SURFACE WATER SAMPLE LOCATION MAP A CLEANER WORLD #162 4506 HIGH POINT ROAD GREENSBORO, NORTH CAROLINA � � Q D (VkTc A S S 0 C I A T E 5 INC. Raleigh. North Carolina 27604 (919) 871-0999 FAX (919) 871-0336 CAD FILE DSCA # PREP. BY 1253357.DWG 1 41-0024 1 NS REV. BY SCALE DATE PROJECT NO. SV 1 " = 20 0 ' 03- 01- 2010 45.34341. 4124 4 x x NA � V) pv I - z m rn 1 0 — I Z0 ' 1 o 0 1 - _ - 1 , 1 1 � I o ,o o � 11 11 ' ' I HI 1 �H � porNr 1 ' 1 1 1 RoAD O • r 0P •- 0 1 �1 1 rn6 `` 11 1 1 _ l m i • I ,C2 1 ' r Q I • 1 • fc � > 1 1 r A --AZ ' 1 A �Qm ' 0j+T N = f g= • N ' % O rn oc , I • r� .J � f f � ♦ — \ F O 1 Q Q NOTES: TITLE FIGURE 7 GEOLOGIC TRANSECT MAP u A CLEANER WORLD #162 4506 HIGH POINT ROAD A s s a C I AT E S I NC. GREENSBORO, NORTH CAROLINA Ralelgh,North Carolina 27604 (919)871-0999 FAX (919)871-0335 CAD FILE DSCA N PREP- BY REV. BY SCALE DATE PROJECT NO, 1253357-DWG 41-Q024 NS SV 1" - 200' 103-01-20101 45.34341.4124 880A0' 870.00' 8 60.00, 850.00+ 840.00' 830.00 820.00' 810.00' 12 MW-12D (872 28) MW_125(871.97 M W -1 coo"TM tz to zoaa �F7rt n,q/L 0.590 TRKHLoR0ETNYLEHE n,q/L 0.034 �.-I•q.-OCUNpE11"-A 0.130 t-� ny/L 0-001 VINYL CHLORIDE m L 0.060 MW-185 MW-18 (874,66) (874.72) MW-3 MW-18R MW-1 (874.59) (872.53) (873.oC] / ♦ ,r.Jr / r f r / { rr r , ,/ f , ,/ / ,r • r ,' / J ,r r J , J r , / / r , / / J,f J! r r / / / r r r Mw-12SmouwDw ,,ER TErRw_mILWGIWrHnEmf VL c0.0007 TR)CHL0"CMLENE mp/L 40-001 w-I.x-anxoRo[nw>tE m9�L iD.001 ,-,x-On+loRvwm m A cD.001 VINYL CHL9RIpE /L iD.0p1 MW-12D GR01AQWITIR r7Jn/zooa GENE T! [0.0007 TRCHLORVEMYLENE mph 0.016 eh-1,2-OKJ+LO�EM1W,E mq/L 0.0p49 ha>r,,7_BCHWNp(TIWIE nh/L CO.ODI VSNfYL CHLORIDE mg/L i0.001 FINE GRAINED SILT AND CLAY WITH SOME SAND COARSE GRAINED SILTY SAND AND PARTIALLY WEATHERED ROCK /,', //rr,✓ J ' ' r , , ✓ , J r f f r f r !A_l, _ MW- i br Trmr_HL0RCFETH"LENE r1aCNL0R0EhfYLENE n e-IF-MMOROCrwwE VINYL CHLORIDE m� WATER TABLE MW-28R / / rf ,l / • / (864,45) IW / r '' rf � ! 1f7W�M0R0RETNi1ENE D.p40 /r TRtCHLOROET MENE m9/L r J / / 0.002 VINYL CHLORIDE mq/L C0.005 f / 0.750 D000 0.350 0-00079 0.093 MW-3-WELL IDENTIFICATION (874.59) � WELL ELEVATION (TOC) WELL CASING WELL SCREEN 0Q MW-18s raauHorr"1ER , to xo0a TETR"CHL0N0RrrrKMME D.Dt4 TWCHLOROEfHYLENE mq/L 0.0024J 0,031 +R� %.a-palal"aCK4t 0.0008 VINYL CHLORIDE m /L i0.00D5 MW-l8D „`RwIQJ "� �LENE my 0.22 TR,G7I MEnMENE m9/E 0.0250 w-r,7-0Ie�urt0ETwwc ..y/L 0.038 evn.-,,x-ncrEuaoclrwc mq/L [0.905 VINYL CHLORIDE mq/L 0,0017 Mw-1os 77P"CHL TNTLM mq/L 0.110 iRICHFAROFfMYLENE mg/L 0x" e-,2-,11GILORaummE- mq/L 0-0044 rants-o0apacnwa <0.001 VINYL CHLORIDE mq/L i0.001 MW-18s tx taVzooP TVAkC:HL0kORET1fiLEHE m9/ C0.0997 TRICHLOROETKYLERE mg/L [DA01 u"-,.T-00URDET M mq/L i0.001 ,, x-xxa"ccnwc c0.001 VINYL CHLORIDE mq/L i0.001 MW-2br'�'"+TER tzl+Nzaae '0 N 0.E50 HLOROETrYLENE mg/L 0.019 a.-+a-fiCHL0A7C }W2 RgIL 0.030 rrr-,z-or+antgE+wwE ..p/L i0.005 VINYL CHLORIDE mg/L t0.DO5 07 PCE ISOCONCENTRATION CONTOUR 20 m n MW-10D (850.62) 0 140 280 MW-16S/I/D (847.85) MW-10D CRO/Nol""TER Ia zoos �nmFra 0.140 TPoCKOPOETHYLENE m9/L 0.0021 R-oonnkaFr _ myL 0.0028 ,�.-,,t-ulaEUROEnwa np/L c0.001 VINYL CHLORIDE /L c0.001 MW-161 `pjNp14E" rz,a. TETR"CHLOMOCTIMENE m9/ C0.0007 TFOCHLOROEM-MENE ",A C0.071 e:a-ta-paLawoErwuc RwI1 i0.001 „�„_ta-o.a.woETw c9.0]1 VINYL CHLORIDE mg/L <0.011 MW- l 60 i9 TOQ rETR"CNLORORERfrLRL D.00Z7 TmCHL0R0iT1MiNE mg/i C0.D.11 a.-,.x�tpupepnNrr[ .np/L i0.001 en.+.-u-pp9ypuETlwtE ntAl i0.001 VINYL CHLpR10E m m I co oil r i i 140' kG M M 4 N m i W � U a 't LL $ oo en a� N1 w m ~ e d U m - a aI N N � Q a � cv a a z L] o w C7 z 1) t c0 Q m m 7 fY Q Q } Z m Q J ❑ w Z a L4 Q U0 Q U W❑ _ [J7 H ° N CD a JI,-D � Z I Z p 0 ❑ Of � ❑ 0Li w�To Q -i J L co L� ❑ U o LLJ In LL tu) j or o<4-3 CN u� is 7. Water Resources Environmental Quality January 25, 2018 Genna K. Olson ATC Associates of North Carolina 2725 E Millbrook Rd Ste 121 Raleigh, NC 27604 Subject: Permit Rescission Permit No. WI0400131 In -Situ Groundwater Remediation Permit Guilford County Dear Ms. Olson, ROY COOPER Governor MICI-IAEL S. REGAN Secretary LINDA CULPEPPER Interim Director Reference is made to your request for rescission of the subject permit located at the Former Cleaner A World #162 Facility, Guilford NC. Staff from the Winston-Salem Regional Office has agreed that a permit is no longer required. Therefore, in accordance with your request, In -Situ Groundwater Remediation Permit W1400131 is rescinded, effective immediately. If in the future, you wish to operate a In -Situ Groundwater Remediation system, you must first apply for and receive a new permit. Operating an injection system without a valid permit may result in the assessment of civil penalties and/or the use of other enforcement mechanisms available to the state. If it would be helpful to discuss this matter further, please do not hesitate to call Shristi Shrestha at (919) 807-6406. Sincerely, U"�'Uj"zk Linda Culpepper, Interim Director Division of Water Resources Attachment(s) cc: Winston-Salem Regional Office - WQROS Central Files - Permit No. W10400131 Meghan Greiner, ATC Associates, 2725 E. Mi11brook Road, Suite 121, Raleigh , NC 27604 'Not hirig Conipar v,. State of North Carolina I Em ironmentai Quality I Division of Water Resources Water Quality Regional Operations Section 1636 Mail Service Center I Raleigh, Nonh Carolina 27699-1636 919-707-9129 Shrestha, Shristi R From: Watts, Debra Sent: Tuesday, January 30, 2018 2:38 PM To: Genna Olson Cc: Doorn, Peter; Shrestha, Shristi R; Rogers, Michael; Watts, Debra Subject: Questions about signature authority Attachments: guidance for DSGA permit applications.pdf; BULLETIN 29v2.doc Genna Just wanted to touch base with you concerning questions you recently received from Shristi Shresta, one of our UIC permitters. She was asking about signature authority due to questions I was asking. I finally dug up Sulletin29 that Thomas Slusser had sent me, along with guidance for DSGA sites, where it does state that project managers can sign documents and not just officials as indicated in our rules. Since this was agreed to between DWSCA and DWR, we will honor this. My apologies for any confusion this may have caused. Debra Watts Supervisor, Animal Feeding Operations and Groundwater Protection Branch Division of Water Resources North Carolina Department of Environmental Quality 919 807 6338 office d e b ra. watts Cal n cden r. oov 512 N. Salisbury Street 1636 Mail Service Center Raleigh, NC 27699-1636 ho- - --7'Nothing Compare-s — Email correspondence fo and from mis address is Subject to the North Carolina Pubfic Records Law and may be disclosed to third pa fjes. Shrestha, Shristi R From: Genna Olson <golson@harthickman.com> Sent: Tuesday, January 30, 2018 1:05 PM To: Shrestha, Shristi R; Meghan Greiner Subject: RE: [External] RE: VA0400131 Former A Cleaner World # 162 CAUTION: External email. Do not click links or open attachments unless verified. Send all suspicious email as an attachment to report.spam@nc.gov. The DSCA contractor is ATC so I think any employee of ATC would be authorized to sign. From: Shrestha, Shristi R [mailto:shristi.shrestha@ncdenr.gov] Sent: Tuesday, January 30, 2018 11:16 AM To: Genna Olson <golson@harthickman.corn>; Meghan Greiner <meghan.greinerG]a atcassociates.com> Subject: RE: [External] RE: WI0400131 Former A Cleaner World # 162 Genna, In that case it looks like we would need a list of people who are authorized to sign. Thank you, Shristi Shristi R. Shrestha Hydrogeologist Water Quality Regional Operations Section Animal Feeding Operations & Groundwater Protection Branch North Carolina Department of Environmental Quality 919 807-6406 office sh risti .shrestha(&ncder r.gov 512N. Salisbury Street 1636 Mail Service Center Raleigh, NC 27699 1636 Err+ai) c,,,)rrespardence to and fmm this address is subjeyf to the North Carolina Pubtic Records Law and may be disclosed to tnird parties. From: Genna Olson [mailto: ol�C&harthickman.com Sent: Friday, January 26, 2018 4:13 PM To: Shrestha, Shristi R <shristi.shresth4ncdenr_gov>; Meghan Greiner cmeghan. egr iner(aatcassociates.com> Subject: RE: [External] RE: WI0400131 Former A Cleaner World # 162 CAUTION: External email. Do not click links or open attachments unless verified. Send all suspicious email as an attachment to re ort.s am nc. ov. It's fine with me if she signs, but the applicant is the DSCA site petitioner and the power of attorney gives the DSCA contractor the authority to sign as their agent. Meghan is the representative for the DSCA contractor, so I'm not sure why she wouldn't be able to sign? From: Shrestha, Shristi R[mailto:shristi.shresthaCa,,n_c_denr.go�] Sent: Friday, January 26, 2018 1:41 PM To: Meghan Greiner <me han. einer atcassociates.com> Cc: Genna Olson <golson Aharthickman.com> Subject: RE: [External] RE: W10400131 Former A Cleaner World # 162 Genna, We need an email from you giving Meghan authority to sign for rescission of the permit. Thank you, Shristi Shristi R. Shrestha Hydrogeologist Water Quality Regional Operations Section Animal Feeding Operations & Groundwater Protection Branch North Carolina Department of Environmental Quality 919 807-6406 office shristi. sh restha(@ncdenr.gov 512N. Salisbury Street 1636 Mail Service Center Raleigh, NC 27699 1636 Email correspondence to and from this address is su4iscf to the North Carohna Public Records Law and may be dEsclosed to third parries. From: Meghan Greiner[mailto:meghan.greiner6watcassociates.coml Sent: Wednesday, December 20, 2017 12.49 PM To: Shrestha, Shristi R<shristi.shrestha(cL�ncdenr.gov> Subject: RE: [External] RE: WI0400131 Former A Cleaner World # 162 CAUTION: External email. Do not click Iinks or open attachments unless verified. Send all suspicious email as an attachment to report. sparn grlc..ov. I reviewed the injection permit for what was proposed and none of the proposed wells for the injection were constructed. Let me know if there's anything else you need. Thanks Meghan Greiner I SENIOR PROJECT MANAGER I ATC Group Services LLC +1 919 573 1204 1 +1 402 990 3468 mobile 2725 E. Millbrook Road, Suite 121 1 Raleigh, NC 27604 meghan.greinerOatcassociates.com I www.atcqroupservices.com This err,z "" =-'-Ch5meilt: rnav cGr: -n o1F*5dentie I anri/or rlivile;=11 inPtlrrnatm?r. Mr the stile use of tree iFite nC3el7 -aCID Tent( S}. It ynt; are in, _ - --c:peilt. an use, dis:rsbwUors or copying of [7e Pnir:miallun rrantai-TeV In thl, email arl9 its arafir-ments is strlc+ty 15Ve received this ernaii In e■ror. please noz+fv me sewer py repsrinq to this rne—n-age ar❑ lm-,)eaiww'y' leiete and '`estroy arz51 tflpies of this emell .anO any attaclmrlerts- The oe*,s o► apfnlans are iree aufhafs oWn and r1ar not-pfrect the Ilea; 4* op! ni4ns OF ATC- From: Shrestha, Shristi R[maiIto: shristi.shrestha(n;ncdenr.ov� Sent: Tuesday, December 05, 2017 10:31 AM To: Meghan Greiner <me han. einera)atcassociates.com> Subject: RE. [External] RE: WI0400131 Former A Cleaner World # 162 Meghan Thank for replying back. I will work on rescinding the permit. Our records show that there are 19 proposed wells associated with the facility. Were the wells constructed? If they were then please submit construction records and their status after the permit is rescinded. If they were never constructed then I will close them out. Thank you, Shristi Shristi R. Shrestha Hydrogeologist Water Quality Regional Operations Section Animal Feeding Operations & Groundwater Protection Branch North Carolina Department of Environmental Quality 919 807-6406 office sh risti.sh restha CcDncdenr. qoy 512N. Salisbury Street 1636 Mail Service Center Raleigh, NC 27699 1636 Emaii correspondence fo and from this address is subject to the Ncrth Carolina Public Records Law and may be disclosed to third parties. From: Meghan Greiner [rnailto.-meghan. er�Cg:atcassociates.com] Sent: Monday, December 04, 2017 4:49 PM To: Shrestha, Shristi R <shristi.shresthaCwncdenr.gov> Subject: [External] RE: W10400131 Fortner A Cleaner World # 162 CAUTION: External email. Do not click links or open attachments unless verified. Send all suspicious email as an attachment to report. sam a7nc. gov. Hi Shristi, Sorry for the delayed response. The email got buried in my inbox. The work associated with injection permit number WI0400131 was never completed. As an agent for the petitioner for DSCA Site #DC410024, ATC would like to rescind the permit that was issued. A limited power of attorney agreement is attached which allows ATC to act on behalf of the petitioner for this site. Please let us know if you need any additional information. If any future work is planned a new permit application will be submitted. Thanks'. Meghan Greiner I SENIOR PROJECT MANAGER I ATC Group Services LLC +1 919 573 1204 j +1 402 990 3468 mobile 2725 E. Millbrook Road, Suite 121 1 Raleigh, NC 27604 me han. reiner atcassociates.com G www,atcgrout3services.com `his ernafl and Its attachments may son ta& contldentlal and/or priviteged Information for the Sale use of the Frltended recipientl5) If yUU are not the intended ,ecivlerit, any use, disbftution or copying or the infonnation cnntained In this ernail and its amachrvients is strictly P1Olih ted. If yw havr! received this email ire er: or, please notify the sander ty tidying to this message and immealately delete and devrhy any copJes of!h15 emaII a n a any attachments. The viewrs ur apiniOnS expressed are tfie author's okvn and may not reliect the vie vos or ]pin1nns of ASC, From: Shrestha, Shristi R mailto:shristi.shrestha ncdenr, ov Sent: Thursday, August 24, 2017 3:36 PM To: Genna Olson enna.olson ateassociates.corn> Subject: WI0400131 Former A Cleaner World # 162 Good afternoon, We are in the process of closing our expired permit and it looks like Former A Cleaner World #162 site with the permit number W10400131 is also in the list. Our records show that the permit expired 07/31/2012. While going through our records I didn't find injection records and final project evaluation report. If you have a digital copy of the HE report you can send by email too. IER forms can be found in the following link. http: //deq. n c. gov/about/di vis i ons/water-resources/water-resources-permits/was tewater-branc h/zround-water- protection/ground-water-reporting-forms. If you want to rescind the permit I would need a permit rescission request from the owner which can be in the form of an email too. Please contact me at the number below if you have any questions or concerns regarding this. Thank you for your cooperation. Shristi Shristi R. Shrestha Hydrogeologist Water Quality Regional Operations Section Animal Feeding Operations & Groundwater Protection Branch North Carolina Department of Environmental Quality 919 807-6406 office shristi.shrestha Pncdenrgov 512N. Salisbury Street 1636 Mail Service Center Raleigh, NC 27699 1636 Email correspondence to and from this address is subject to the lVarth Carolina Pubfic Records Law and may be disclosed to third parties. Shrestha, Shristi R From: Gonsiewski, James J Sent: Friday, January 19, 2018 1:36 PM To: Shrestha, Shristi R Cc: Knight, Sherri; Wang, Shuying Subject: WI0400131 Former A Cleaner World * 162 Shristi, We looked at this and agree with the rescission request. Please let me know if you have any questions. Thanks, Jim G Jim Gonsiewski, PG Hydrogeologist Division of Water Resources Department of Environmental Quality 336-776-9704 office 336486-7584 mobile Winston-Salem Regional Office 450 W. Hanes Mill Road, Suite 300 Winston-Salem, NC 27105 `Nothing Compares Email correspondence to and from this address is subject to the North Carolina Public Records Lal.w and may be disclosed to third parteas. From: Wang, Shuying Seat: Friday, January 19, 2018 l l :24 AM To: Gonsiewski, James J <jim.gonsiewski@ncdenr.gov> Cc: Knight, Sherri <shcr-i.knight[rr7,ncdenr,gov>; Watts, Debra <debta.watts@ncdenr.gov>; Rogers, Michael <michae1.rogers@ncdenr.gov>; Shrestha, Shristi R cshristi.shrestha@ncdenr.gov> Subject: RE: [External] RE: WI0400131 Former A Cleaner World # 162 Jim, If this is not yours, please let me know, Shristi, you will get a response from either Jim or me. Shuying Wang, P.G. Hydrogeologist Division of Water Resources NC Department of Environmental Quality Winston-Salem Regional Office Phone: (336) 776-9702 Mobile: (336) 403-5429 Fax: (336) 776-9797 Email: ShuYing.Wan1Z(5_),ncdenr.gov 450 W Hanes Mill Road, Suite 300 Winston-Salem, NC 27105 hqp:L/12c)rtal.nedenr.org/wgb/wq h- C.. "Nothing Campares - __- E-mail ail correspondence to and from this address may be subject to the North Carolina .public Records Lary and may be disclosed to third parties runless the content is exempt by statute or other regulation. From: Shrestha, Shristi R Sent: Friday, January 19, 2018 10:54 AM To: Wang, Shuying <shuying.wangancdenr.gov> Cc: Knight, Sherri <sherri.knight@ncdenr.gov>; Watts, Debra <debra.watts{c�r�,ncdenr.gov>; Rogers, Michael <michael.ro ors ncdenr. ova Subject: Fw: [External] RE: WI0400131 Former A Cleaner World # 162 Shuying, We received a rescission request for this permit. Are you the right person to contact for this:' If you are please let me know if you agree with the rescission. E1@Tii:�1i Shristi R. Shrestha Hydrogeologist Water Quality Regional Operations Section Animal Feeding Operations & Groundwater Protection Branch North Carolina Department of Environmental Quality 919 807-6406 office { s hri sti . shresthaCnc dent. g ov] s h ris ti . s h re stt) a (cD n cde n r. goy 512N. Salisbury Street 1636 Mail Service Center Raleigh, NC 27699 1636 Email correspondence to 3 xc From this address is subject to the North Carolina Publk Records Law and may be disclosed to third parties. From: Shrestha, Shristi R Sent: Monday, January 8, 2018 11:47 AM To: Knight, Sherri Subject: FW: [External] RE: W10400131 Former A Cleaner World # 162 Good morning, I have received a rescission request for the following permit . PIease let me know if you have any issues with this. If not I will go ahead and rescind the permit. Shristi Shristi R. Shrestha Hydrogeologist Water Quality Regional Operations Section Animal Feeding Operations & Groundwater Protection Branch North Carolina Department of Environmental Quality 919 807-6406 office shristi.shrestha a7ncdenr,gov 512N. Salisbury Street 1636 Mail Service Center Raleigh, NC 27699 1636 Emali oorrespondenca to and from this address is stjbjecF to tt:e Norih Carolina P:.ablx Recrrds Law erd may be disclosed ; o third parties. From: Meghan Greiner[mailto:meehan.greiner(a7atcassociates.com� Sent: Wednesday, December 20, 2017 12:49 PM To: Shrestha, Shristi R <shristi.shrestha(a,ncdenr.gov> Subject: RE: [External] RE: WI0400131 Former A Cleaner World # 162 CAUTION: External email. Do not click links or open attachments unless verified. Send all suspicious email as an attachment to rev ort.sparn(r, n c. gov. I reviewed the injection permit for what was proposed and none of the proposed wells for the injection were constructed. Let me know if there's anything else you need. CZ-112 Thanks. ��� Meghan Greiner i SENIOR PROJECT MANAGER I ATC Group Services LLC} +1 919 573 1204 +1 402 990 3468 mobile ��H,tr2a I 2725 E. Millbrook Road, Suite 121 1 Raleigh, NC 27604 me han. reiner atcass ciates.c m I www.atcgroupservices.com pr+3h1tlICBEi if }!GV h:3V? {e iYLd thV5 Clrf it IiZ ►7i, Sf C?SC i f `•, ••'£ Se!Ti5?- ny rnpiYI n_j to tf=fS McSSage and I M [TIed �a tef V aej2%�, $jPa dpStre�' an} C4pieS Uf r: r.niaO lnr} -10y afta.hr;—_nCS Tb#E Ir ElPiPlRnS eXpf-e5Sed 3.e Me aAnpr S : WC 3nO tn3y nCt rVirCt tt•C From: Shrestha, Shristi R[mailto:shristi.shresthaAncdenr;govl Sent: Tuesday, December 05, 2017 10:31 AM To: Meghan Greiner <me hart. einer atcassociates.com> Subject: RE: [External] RE: WI0400131 Former A Cleaner World # 162 Meghan Thank for replying back. I will work on rescinding the permit. Our records show that there are 19 proposed wells associated with the facility. Were the wells constructed? If they were then please submit construction records and their status after the permit is rescinded. If they were never constructed then I will close them out. Thank you, Shristi Shristi R. Shrestha Hydrogeologist Water Quality Regional Operations Section Animal Feeding Operations & Groundwater Protection Branch North Carolina Department of Environmental Quality 919 807-6406 office shdsti.shrestha@ncdenr.gov 512N. Salisbury Street 1636 Mail Service Center Raleigh, NC 27699 1636 Erna# carresponc: once to and from this address is subject to the North Carolina Public Records Law and may be disclo-e&d to third parties. From: Meghan Greiner [mailto:megban.geiner@atcassociates.com Seat: Monday, December 04, 2017 4:49 PM To: Shrestha, Shristi R <shristi.shrestha cdenr. ova Subject: [External] RE: WI0400131 Former A Cleaner World # 162 CAUTION: External email. Do not click links or open attachments unless verified. Send all suspicious email as an attachment to report.spam(a),nc. gov. Hi Shristi, Sorry for the delayed response. The email got buried in my inbox. The work associated with injection permit number WI0400131 was never completed. As Site 9DC410024ATC would like_to rescind the permit that was issued. A I im ited p ower of attorney agre=ent is attached which allows ATC to act on behalf of the petitioner for this site. Please let us know if you need any additional information. If any future work is planned a new permit VIPTlication will be submitted. Thanks! � � %S .�`� ? Meghan Greiner i SENIOR PROJECT MANAGER I ATC Group Services LLC +1 919 573 1204 i +1 402 990 3468 mobile 2725 B. Millbrook Road, Suite 121 1 Raleigh, NC 27604 meghan.greiner@atcassociates.com I www.atcgroupservices.com = e]f m971N,� iLv chi Ec]IE A". � np}L'ni:` _ s c r,:ti _. tnr-rrtp,ci,:, any uS-, 1 sLr _,tlQr �r LaQ 1in_ ui 14ctrar, GnnEa neC in this er_1s11 and ,[5 attaC'-1[-1 r-,L: arut"oitou if you nav: eec_ ved this etraii to error, UI"Se n,3! _ 71U'"c' CV teiDIV"q W trrr_ ^nos ire at•r1 ramediaEe v ?ale._ . d,--[rny any c-op+es ai;In 15 emzI and am amdoi,enl5- The iiie s ar Dor,iccit evvsessec are ttie sAttocir'�; e*T, an in ma rnna reriect t, - views or oprrnians or A —'-- From: Shrestha, Shristi R rnailto:shristi.shrestha ncdenr. ov Sent: Thursday, August 24, 2017 3:36 PM To: Genna Olson<genna.olsonaatcassociates.com> Subject: W10400131 Former A Cleaner World # 162 Good afternoon, We are in the process of closing our expired permit and it looks like Farmer A Cleaner World #162 site with the permit number W10400131 is also in the list. Our records show that the permit expired 07/31/2012. While going through our records I didn't find injection records and final project evaluation report. If you have a digital copy of the FPE report you can send by email too. IER forms can be found in the following link. http://deg.nc.gov/about/divisions/water-resources/water-resources-permits/wastewater-branch/ground- water- rotection/ ound-water-re ortin -forms. If you want to rescind the permit I would need a permit rescission request from the owner which can be in the form of an email too. Please contact me at the number below if you have any questions or concerns regarding this. Thank you for your cooperation. Shristi Shristi R. Shrestha Hydrogeologist Water Quality Regional Operations Section Animal Feeding Operations & Groundwater Protection Branch North Carolina Department of Environmental Quality 919 807-6406 office shristi.shrestha ncdenr. ❑v 512N. Salisbury Street 1636 Mail Service Center Raleigh, NC 27699 1636 Email correspondence to and from this address Is sib}ect !c the North Caro-6ni7a Pub c Records Law anti maybe disclosed to third par€ies. MCDENR North C.;arollm Department of Environment and Naiural Resources Division of Water Quality Beveny caves Ferdut ; oleen H. Sullins Governor Director August 10, 2010 Petitioner for DSCA Site #41-0024 DSCA Program Mail Service Center 1646 Raleigh, NC 27599-1646 Ref: Issuance of Injection Permit W10400131 Petitioner for DSCA Site #41-0024 (Former A Cleaner World #162) 4506 High Point Road Greensboro. Guilford County. NC 27407 Dear Petitioner: Dee Freeman 5ecretary In accordance with the application received on April 13, 2010. we are forwarding permit number Wi0400131. This permit is to inject EHC to reinediate groundwater contaminated with chlorinated solvents at the above referenced facilit}'. This permit shall be effective from the date of issuance until July 31. ?012, and shall be subject to the conditions and limitations stated therein. including the requirement to submit a final project evaluation as stated in PART VR — MONITORTNG AND REPORTING REQUIREMENTS. Please read the entire permit to ensure that you are aware of all compliance requirements of the permit. Please refer to Part V11,1 and 2 in the permit as there are some slight modifications to the proposed monitoring plan as submitted in the permit application. You will need to notify this office and the Winston-Salem Regional Office by telephone 48 hours prior to initiation of operation of the facility. In order to continue uninterrupted legal use of the injection facility for the stated purpose, you must submit an application to renew the permit 120 days prior to its expiration date. Please contact me at 919-715-6166 or Miehael.Rogersidmcdenr.gov if you have any questions about your permit. Best ReLyards, y � Michael Rogers, P.G. (NC & FL) Environmental Specialist Underground Injection Control Program cc: Sherri Knight -Winston-Salem Regional Office Meglian Greiner- ATC Associates of North Carolina, PC WI(900131 Permit File Al Chapman - Division of Waste Management AQIr1FER PROTEOT1OfI SE7710N 1636 Mail Servrcf Gente-. Raw ;r rgcon ami na 27699.1SM LQC310r,: 2725 �MMJ 60wevVc Raieinr. North Car Ina 276N C)n,- Pnane: 919-733 3221 � F.tie: ' yi5 '15 G58`c. TAX'-- 91',715.6048' ; USJOmer Service v-877-Z23-5748 �1(�1'�17�3 f�/c�I*I�'7D■Il 1i3a InI9mei www.nrweteraua! �.O:v �?Li �F�iL LLL�� �L. EgLjj�! J� 3:::.L'P..:ir .m-.n ill V_e kr,LJpn III Ploy- Rogers, Michael From: Meghan Greiner [meghan.greiner@atcassociates.com] Sent: Tuesday. August 17, 2010 3138 PM To: Rogers. Michael Subject: RE: W10400131 Former A Cleaner World 51 permit This email is to confirm our phone conversation last week where we discussed not sampling MW-10S as a part of the injection sampling but to sample MW-1 BR instead. Please let me know if this is incorrect. Thanks. Meghan Greiner I Project Engineer I ATC Associates Inc. IRaleigh, NC 2725 E. Millbrook Road I Suite 121 1 Raleigh, NC 27604 919-871-0999 te11919-871-0335 fax I www.atr-assacpates.com From: Rogers, Michael[ma[lto:michael.rogers@ncdenr.gov] Sent: Thursday, August 12, 2010 2:54 PM To: meghan.greiner(u)atcassociates.com Cc: Knight, Sherri; Chapman, Al Subject: WI0400131 Former A Cleaner World 5I permit Please find attached the UIC 51 groundwater remediation permit for the above site. Michael Rogers, P.G. (NC & FL) Environmental Specialist NC Div of Water Quality- Aquifer Protection Section (APS) 1636 Mail Service Center Raleigh, NC 27699-1636 Direct Line (919) 715-6166: Fax 715-0588 (put to my attn on cover letter) httD:lloorta1.ncden r.oralweblwolaoslaworoipermit-ao of i cations E-mail correspondence to and from this address may be subject to the !North Carolina Public Records Law and may be disclosed to third parties HCDENR Nortn Carolina Department of Environment and Division of Water Qualm Beverly Eaves perdue Coleen H. Sullins Governor Director April '_"_. 2010 Genma K. Olson ATC Assoc. coo DSCA Program 1646 Mail Service Center Raleigh. NC 27699 Subject: Acknowledgement of Application No. W10400131 Former A Cleaner World #I62 Injection In situ Groundwater Remediation Well (5I) Guilford Dear Ms. Olson: Natural Resources Gee Freeman Secretary The Aquifer Protection Section of the Division of Water Quality (Division) acknowledges receipt of your permit application and supporting materials on April 112010. This application package has been assigned the number listed above and will be reviewed by Michael Rogers. The reviewer will perform a detailed review and contact you with a request for additional information if necessary. To ensure the maximum efficiency in processing permit applications. the Division requests your assistance in providing a timely and complete response to any additional information requests. Please be aware that the Division's Regional Office. copied below. must provide recommendations prior to final action by the Division. Please also note at this time, processing permit applications can take as long as 60 = 90 days after receipt of a complete application. If you have any questions. please contact Michael Rogers at 919-715-6166. or via e-mail at michael.rogersCamcdenr.gov. If the reviewer is unavailable. you may leave a message. and they will respond promptly. Also note that the Division has reorganized. To review our new organizational chart, go to httr:'.112o.en,.'.,,tate.nc.us/docLimentsid�vq orechartJndE PLEASE REFER TO TIME ABOVE APPLICATION NUMBER WHEN MAKING INQUIRIES OIL THIS PROJECT. Sincerely, Ov� _for Debra J. Watts Supervisor cc: Winston-Salem Regional Office, Aquifer Protection Section Meghan E. Greiner. PE (ATC Associates of NC) 2735 East Millbrook Road, Ste 12' 1. Raleigh, NC 27604 Permit Application File W10400131 AQUIFEF PROTECTION SECTION 1n36 Mail Service Center. Releinn North Carolina 27695-163: Locatiori. 2728 Capital Boulevard. Ralergrr. No Rh CarotFna 2760e Ort: Pnone 919-733-3221 FAX 1. 919-715-058t, FAX 2- Usrome- Service -623-674c North C arolina +n?erne:. www.nmale ualrg _itv,.am �Yattowl4il ire £quaff ,Jppr�unity 4rrrmaPve r�crun fmprQye CvvATC ATC ASSOCIATES OF NORTH CAROLINA, P.C. Engineering Individual Solutions April 9, 2010 Mr. Thomas Slusser NCDENR Division of Water Quality Aquifer Protection Section, UIC Program 1636 Mail Service Center Raleigh, North Carolina 27699-1636 RE: Injection Permit Application Former A Cleaner World #162 4506 High Point Road Greensboro, Guilford County, North Carolina ATC Project No. 45.34341.4124 DSCA Site No. 41-0024 Dear Mr. Slusser: 2725 East Millbrook Road Suite 121 Raleigh, NC 27604 Tel: 919-871-0999 Fax: 919-871-0335 www.atcassociates.com N.C. Engineering License No. C-1598 Enclosed are two copies of an injection permit application prepared by ATC Associates of North Carolina, P.C. (ATC) on behalf of the North Carolina Drycleaning Solvent Cleanup Act (DSCA) Program. The permit application covers injection of EHC, a product developed by Adventus Group, for enhanced reductive dechlorination of chlorinated solvent compounds at the above referenced site. If you have questions or require additional information, please do not hesitate to contact us at (919) 871-4999. Sincerely, ATC Associates of North Carolina, P.C. Nick Shore Staff Scientist alter cc: Al Chapman — NCDENR DSCA Program f � V MTe E. Greiner, P.E. Project Manager RECEIVED 1 DENR I DVVQ Aquifer Pratertinn SectlOtl APR 13 2010 AQUIFER PROTECTION REGIONAL STAFF REPORT Date: May 6, 2010 County: Guilfrod To: Aquifer Protection Central Office Permittee: Petitioner for DSCA site 41-0024 Central Office Reviewer: ;,Michael Rogers Project Name: Former A Cleaner World 9162 Regional Login No: Application No.: WI0400131 L GENERAL INFORMATION 1. This application is (check an that apply): ® New ❑ Renewal ❑ Minor Modification ❑ Major Modification ❑ Surface Irrigation ❑ Reuse ❑ Recycle ❑ High Rate Infiltration ❑ Evaporation/Infiltration Lagoon ❑ Land Application of Residuals ❑ Attachment I3 included ❑ 503 regulated El 503 exempt ❑ Distribution of Residuals ❑ Surface Disposal ❑ Closed -loop Groundwater Remediation ® Other Injection WeIIs (including in situ remediation) Was a site visit conducted in order to prepare this report? ® Yes or ❑ No. a. Date of site visit: 5/6/2010 b. Person contacted and contact information: McRhan E. Greiner. ATC Associates of NC. PC. 9 l 9-871-0999 c. Site visit conducted by: ShUying Wang, WSRO d. Inspection Report Attached: ❑ Yes or ® No. 2. Is the following information entered into the BIMS record for this application correct? ❑ Yes or ® No. If no, please complete the following or indicate that it is correct on the current application. For Treatment Facilities: a. Location: b. Driving Directions: c. USGS Quadrangle Map name and number: d. Latitude: Longitude: e. Regulated Activities 1 Type of Wastes (e.g., subdivision, food processing, municipal wastewater): For Disposal and injection Sites, If multiple sites either indicate which sites the information applies to copy and paste a new section into the document for each site- or attach additional naQes for each site) a. Locations): 4506 High Point Road, Greensboro -NC 27407 b. Driving Directions: Business I40 exit to High Point Road toward the City of High Poin c. USGS QuadrUgle Map name and number: Greensboro d. Latitude: 36�&,2' 00.567"N Longitude: 79' 52'00546"W II. NEW AND MAJOR MODIFTCATIONAPPLICATIONS (this section not needed for renewals or mineir inodi rcations skip to item section Dcscri tion Of Waste 5 And Facilities 1. Please attach completed rating sheet. Facility Classification: 2. Are the new treatment facilities adequate for the type of waste and disposal system? AQ!!RECEIVED F CEa���' DENRIOWQ �FCTt4N FORM: Staff Report FORM - WI0400131 l MAY 12 Zp J0 AQUIFER PRO i ECTION REGIONAL STAFF REPORT IV.. EVECTION WELL PERMITAPPLICATIQIVS (Complete these two sections for all systems that use injection wells, including closed -loop groundwater remediation effluent injection wells, in situ remediation injection wells, and heat pump injection wells.) Description Of Well(S) And Facilities — New Renewal, And Modification 1. Type of injection system: ❑ Heating/cooling water return flow (5A7) ❑ Closed -loop heat pump system (5QM/5QW) ® Ire situ remediation (51) ❑ Closed -loop groundwater remediation effluent injection (5L/"Non-Discharge") ❑ Other {Specify: 2. Does system use same well for water source and injection? ❑ Yes ® No 3. Are there any potential pollution sources that may affect injection? ® Yes ❑ No What is/are the pollution source(s)? A gasoline station. What is the distance of the injection well(s) from the pollution source(s)? 100-200 ft. 4. What is the minimum distance of proposed injection wells from the property boundary? —i 0 ft. 5. Quality of drainage at site: ® Good ❑ Adequate ❑ Poor b. Flooding potential of site: ® Low ❑ Moderate ❑ High 7, For groundwater remediation systems, is the proposed and/or existing groundwater monitoring program (number of wells, frequency of monitoring, monitoring parameters, etc.) adequate? ❑ Yes ® No. Attach map of existing monitoring well network if applicable. If No, explain and recommend any changes to the groundwater monitoring program: suggest MW-1 Br or the new deeper MW-1 By {just one of them, which ever is more contaminated} be incorporated into to the monitoringp]an to monitor if there is any effect of the proposed injection on the bedrock aquifer in the northeastern part of the plume. S. Does the map presented represent the actual site (property lines, wells, surface drainage)? ® Yes or ❑ No. If no or no map, please attach a sketch of the site. Show property boundaries, buildings, wells, potential pollution sources, roads, approximate scale, and north arrow. Iniection Well Permit Renewal And Modification Only: 1. For heat pump systems, are there any abnormalities in heat pump or injection well operation (e.g. turbid water, failure to assimilate injected fluid, poor heating/cooling)? ❑ Yes ❑ No. If yes, explain: ?. For closed -loop heat pump systems, has system lost pressure or required make-up fluid since permit issuance or last inspection? ❑ Yes ❑ No. If yes, explain: FORM: Staff Report FORM - W10400131 4 AQUIFER PRO i ECTION REGIONAL STAr F REPORT V. EVAL UATIONAND RECOMMENDATIONS 1. Provide any additional narrative regarding your review of the application.: Z. Attach Well Constniction Data Sheet- if needed information is available 3. Do you foresee any problems with issuance/renewal of this permit? ® Yes ❑ No. If yes, please explain briefly. Iniection area is between High Point Road with heavy traffic and the front of the buiId`gperated as a dry cleaner business: therefore _extra caution must be taken when conduct the proposed injection at the site to ensure public safety, 4. List any items that you would like APS Central Office to obtain through an additional information request. Make sure that you provide a reason for each item: Item Reason S. List specific Permit conditions that you recommend to be removed from the permit when issued. Make sure that you provide a reason for each condition: Condition Reason 6. List specific special conditions or compliance schedules that you recommend to be included in the permit when issued. Make sure that you provide a reason for each special condition: Condition Reason 7. Recommendation: ❑ Hold, pending receipt and review of additional information by regional office; ❑ Hold, pending review of draft permit by regional office; ❑ Issue upon receipt of needed additional information; IK Issue. ❑ Deny. If deny, please state re�,5ons: 8. Signature of report preparer[s]: Signature of APS regional supervisor: Date: 15 J U FORM: Staff Report FORM - W14400131 6 AS20FER PROTECTION SECTIuN APPLICATION REN71EW REQUEST FORM Date: Anril 26.20)0 To: ❑ Landon Davidson. ARO-APS ❑ David May, WaRO-APS ❑ Art Barnhardt, FRO-APS ❑ Charlie Stehman, WiRQ A4PS ❑ Andrew Pitner_ MRO-APS ® Sherri Knight. W-SRO-APS ❑ Jay Zimmerman, RRO-APS From: Michael Rogers Groundwater Protection Unit Telephone. 919 715-6166 Fax: (919) 715-0588 E Mail: Michael.Rosersriyncmail.net A. Permit Number: M] I1400131 B. Owner: A Cleaner World C. Faeflity/Operation: ❑ Proposed ® Existing ❑ Facility ❑ Operation D. Application: 1. Permit Type: ❑ Animal ❑ SFR-Surface Irrigation❑ Reuse ❑ H-R Infiltration ❑ Recycle ❑ IIE Lagoon ❑ GW Remediation (ND) ® UIC — $1 Groundwater Remediation Well For Residuals ❑ Land App. ❑ D&.M ❑ Surface Disposal ❑ 503 ❑ 503 Exempt ❑ Animal 2. Project Type: ® New ❑ Major Mod. ❑ Minor Mod. ❑ Renewal ❑ Renewal w/ Mod. L. Comments/Other Information: ❑ I would like to accompany you on a site visit. NOTE: Attached, you will find all information submitted in support of the above -referenced application for your review, comment, and/or action. Within, please take the following actions: ® Return a Completed APSARR Form within 30 days. However, if laboratory analytical results are needed in conjunction with the report. submit the report along with lab results whenever received. ❑ Attach Attachment B for Certification by the LAPCU. ❑ Issue an Attachment B Certification from the RO.* * Remember that you will be responsible for coordinating site visits and reviews. as well as additional information requests with other RO-APS representatives in order to prepare a complete Attachment B for certification. Refer to the RPP SOP for additional detail. When you receive this request form, please write your name and dates in the spaces below, make a copy of this sheet. and return it to the appropriate Central Office -Aquifer Protection Section contact person listed above. RO-APS Reviewer: Date: FORM: APSARR 07/06 Page I of 1 .�wrd North Carolina Department of Health and Human Services Division of Public Health ■ Epidemiology Section 1912 Mail Service Center • Raleigh, North Carolina 27699-1912 Tel 919-733-34109 Fax 919-733-9555 Michael F. dimity. Governor November 3, 2004 MEMORANDUM TO: Evan Kane Underground Injection Control Program Aquifer Protection Section FROM: Luanne K. Williams, Pharm.D., Toxicologis�A,�_' Medical Evaluation and Risk Assessment Unit Occupational and Environmental Epidemiology Branch North Carolina Department of Health and Human Services Carmen liooker Odom, Secretary F CiT7 n �v -a � -- —j;�-; ca o t.�ui rn SUBSECT: Use of a Non -Biological Product EHC® by Adventus Remediation Technologies to Enhance Biodegradation of Groundwater Contaminated with Chlorinated Compounds at the BASF Technical Marketing Building Site in Enka, North Carolina. I am writing in response to a request for a health risk evaluation regarding the use of use of a non -biological product EHCS, by Adventus Remediation Technologies, to Enhance Biodegradation of Groundwater Contaminated with Chlorinated Compounds at the BASF Technical Marketing Building Site in Enka, North Carolina. Based upon my review of the information submitted, I offer the following health risk evaluation: PRECAUTIONS DURING APPLICATION Some effects or hazards reported to be associated with the chemical proposed for use are as follows: • Exposure can cause irritation of skin, eyes, nose, throat, and lungs (Medical Management Micromedex TOM -Es Pius System CD-ROM Database, Volume 62, 2004) 2. If the products are released into the environment in a way that could result in a suspension of fine solid or liquid particles (e.g., grinding, blending, vigorous shaking or mixing), then it is imperative that proper personal protective equipment be used. The application process should be reviewed by an industrial hygienist to ensure that the most appropriate personal protective equipment is used. Location: 2728 Caniml &rulcvarcl • Purker Lincoln Building • Itakcigh, N.C. 27604 An Equal Opportunity Employer Persons working with this product should at least wear goggles or a face shield, gloves, and protective clothing. Face and body protection should be used for anticipated splashes or sprays. Again, consult with an industrial hygienist to ensure proper protection. 4. Eating, drinking, smoking, handling contact lenses, and applying cosmetics should never be permitted in the application area during or immediately following application. Safety controls should be in place to ensure that the check valve and the pressure delivery systems are working properly. 5. The Material Safety Data Sheets should be followed to prevent adverse reactions and injuries. 6. Access to the area of application should be limited to the workers applying the product. In order to minimize exposure to unprotected individuals, measures should be taken to prevent access to the area of application. According to the information submitted, no public or private water supplies were identified within a 1500-foot radius. Hominy Creek is less than 30 feet to the east of the injection areas. The nearest residence is greater than 1500 feet from the injection area, and the nearest workplace is the Buncombe County Offices at 300 feet from the injection area. Both of these are located upgradient from the injection area. Efforts should be made to prevent contamination of existing or future wells and nearby surface waters that may be located near the application area. Please do not hesitate to call me if you have any questions at (919) 715-6429. cc: BASF Mr. Joe McKeon BASF Safety and Ecology 100 Campus Driver Mail Stop F-409A Florham Park, N3 07932 ENSR Consulting and Engineering, (NC), Inc Nanjun Shetty, P.E. 7041 Old Waite Forest Road, Suite 103 Raleigh, NC 27616 Adventus Remediation Technologies Kerry Bolanos-Shaw 1345 Fewster Drive Mississauga, Ontario L4W 2A5