WI0500248_INJECTION PERMIT APPLICATION_20100409

INJECTION PERMIT APPLICATION
COURTESY CLEANERS
8111 CREEDMOOR ROAD
RALEIGH, WAKE COUNTY, NORTH CAROLINA
ATC PROJECT NO. 45.34341.9233
DSCA SITE NO. 92-0033
APRIL 9, 2010
RECEIVED 1 DENR 1 DWQ
Aquifer Protection Section
APR 13 Z010

State of North Carolina
Department of Environment and Natural Resources
Division of Water Quality
APPLICATION FOR PERMIT TO CONSTRUCT AND/OR USE A WELL(S) FOR INJECTION
Type 5I Wells — In Situ Groundwater Remediation / Type 5T Wells — Tracer Injectiion
• 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.
• Anychanges made to this form will result in the application package being returned.
Application Number (to be completed by DWQ):
I. GENERAL INFORMATION:
II.
1. Applicant's Name (generally the responsible party): GRE Brennan Station LLC (Petitioner for DSCA Site 92-0033)
2. Signing Official's Name: Genna K. Olson, P.G., Agent Title: Senior Project Manager
3. Mailing address of applicant: DSCA Program
1646 Mail Service Center
City: Raleigh
Telephone number: [phone]
State: NC Zip: 27699-1646
Fax number: [phone]
4. Property Owner's Name (if different from Applicant): Not Applicable
5. Property Owner's mailing address:
. City: State: Zip:
6. Name and address of contact person who can answer questions about the proposed injection project:
Name: Gabriel Araos, P.E. Title: Senior Project Manager
Company: ATC Associates of North Carolina, P.C.
Address: 2725 E. Millbrook Road, Suite 121
City: Raleigh
Telephone number: [phone]
Email Address: [e-mail]
PERMIT INFORMATION:
State: NC Zip:=27604
Fax number: [phone]
1. Project is: gi New Li Modification of existing permit ❑ Renewal of existing permit without modification
❑ 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-51/5T Page 1 of 7

State of North Carolina
Department of Environment and Natural Resources
Division of Water Quality
APPLICATION FOR PERMIT TO CONSTRUCT AND/OR USE A WELL(S) FOR INJECTION
Type 5I Wells — In Situ Groundwat :' 'ation / Type ST Wells — Tracer Injection
• Do
• Submi
• Any ch
se this form for remediation systems
0 copies of the completed app
ade to this form will resu
icatiion Numbe
I. GENERAL I
1. Applicant's Name
2. Signing Official's Na
3. Mailing address of apple
1646 Mail Service Center
ON:
xtract contamin
on and all attachments
the application package be
oundwater, treat it, and reinject the treated groundwater.
e address on the last page of this form.
returned.
o be completed by DWQ):
e res.onsible party
DSCA Program
GRE Brenna
tation LLC (Petitioner for DSCA Site 92-0033)
Title: Senior Project Manager
City: Raleigh
Telephone number: (919) 508-8
4. Property Owner's Name (if different Applicant): Genna
5. Property Owner's mailing address: 4 Co
Place
State: NC Zip: 27699-1646
Fax number: [phone]
!son, P.G.
City: Boston
6. Name and address of contact person who can answe
Name: Gabriel Araos, P.E.
Company: ATC Associates o ,Rg,
Address:2725 E. Millbroo
Carolina, P.C.
ad, Suite 121
State: MA Zip: 02116
estions about the proposed injection project:
Title: Senior Project Manager
City: Raleigh
Telephone number: 91
Email Address: araos45
•
71-0999
atc-enviro.com
II. PERMIT INFORMATI '.
1. Project is: I New ❑ Modificatio
❑ Renewal of existing permit'
2. If this application is being submitted for renewal or ion to an existing permit, pro e:
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
State: NC Zip: 27604
mber: [phone]
UIC-51/5T
of existing pe
without modification
RECEIVED / DENR / DV
Aquifer Protection Section
APR 13 2010
Page 1 of 7
isting permit ❑ Ren

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
INCIDENT & FACILITY DATA
FACILITY INFORMATION
1. Facility name: Courtesy Cleaners
2. Complete physical address of the facility: 8111 Creedmoor Road
City: Raleigh
B. INCIDENT DESCRIPTION
1.
County: Wake
State: NC Zip: 27613
Describe the source of the contamination:
Courtesy Cleaners has operated as a dry cleaner from 1992 through the present. PCE was discovered in the
soil during an environmental investigation in 2005. PCE was used as the dry cleaning solvent until 2008.
2. List all contaminants present in soils or groundwater at the site (contaminants may be listed in groups, e.g.,
gasoline, diesel, jet fuel, fuel oil, chlorinated ethenes, chlorinated ethanes, metals, pesticides/herbicides, etc):
Chlorinated ethenes (primarily PCE and PCE breakdown products).
3. Has LNAPL or DNAPL ever been observed at the site (even if outside the injection zone)?
❑ Yes If yes, list maximum measured separate phase thickness feet
N No If no, list maximum concentration of total VOCs observed at site: 349
4. Agency managing the contamination incident:
❑ UST Section
❑ DWQ Aquifer Protection Section
❑ Hazardous Waste Section
5. Incident managers name Scott Stupak
ppb
E I Superfund Section (including REC Program and DSCA sites)
❑ Solid Waste Section
❑ Other:
and phone number1919) 508-8576
6. Incident number or other site number assigned by the agency managing the contamination incident:
92-0033
C. PERMITS
List all permits or construction approvals that have been issued for the facility or incident, including those not
directly related to the proposed injection operation:
1. Hazardous Waste Management program permits under RCRA: NCD 982173478
2. 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: Air permit : NC0966025
Revised 8/07 UIC-5I/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 / Type 5T Wells — Tracer Injection
IV. INJECTION DATA
A. INJECTION FLUID DATA
1. List all proposed injectants. . .
NOTE: Any substance to be injected as a tracer or to promote in situ remediation must be reviewed by the
Occupational and Environmental Epidemiology Section (OEES) of the Division of Public Health, Department of
Health and Human Services. Review the list of approved injectantsT or contact the UIC Program to determine if
the injectants you are proposing have been reviewed by OEES.
Injectant: Zero-valent iron
Concentration at point of injection: Refer to Appendix 3 - Product Data
Injectant: Hydrogen Release Compound (HRC)
Concentration at point of injection: Refer to Appendix 3 -Product Data
Injectant: EHC
Concentration at point of injection: Refer to Appendix 3 -Product Data
Injectant: Various minor vitamin stimulants, nutrients, and oxygen scavengers
Concentration at point of injection: Refer to Appendix 3 -Product Data
Injectant: Chemical Oxygen Scavengers
Concentration at point of injection: Refer to Appendix 3 -Product Data
2. Source of fluids used to dilute or chase the injectants listed above:
❑ None
© MunicipaI water supply
❑ Groundwater from private well or any well within'/a mile of injection site
❑ Air
❑ Other:
3. If any well within IA mile of injection site, a private well, or surface water is to be used as the fluid source, supply
the following information:
a. Location/ID number of source: NIA
b. Depth of source: N/A
c. Formation: N/A
d. Rock/Sediment type: N/A
e. In Attachment C, provide a current, complete chemical analysis of the water from the source well, including
analyses for all contaminants suspected or historicaIIy recognized in soil or groundwater on the site.
NOTE: If contaminated groundwater is to be used as the dilution or chase fluid, this is not the proper permit
application form. You must apply for a closed -loop groundwater remediation permit using application form
GWRS.
Revised 8/07 UIC-5I/5T Page 3 of 7

APPLICATION FOR PERMIT TO CONSTRUCT AND/OR USE A WELL(S) FOR INJECTION
Type 5I Wells —In Situ Groundwater Remediation / Type 5T Wells — Tracer Injection
B. PROPOSED OPERATING PARAMETERS
1. Duration of Injection:
Maximum number of separate injection events: 1 event
Expected duration of each injection event 1 day
Expected duration between events (if more than one event): N/A
2. Injection rate per well: 3-5 gallons per minute (gpm)
3. Total Injection volume: 750 gallons per day (gpd); 750
, 4. Injection pressure: 50-100 pounds/square inch (psi)
5. Temperature at point of injection: 60-140 °F
6. Briefly describe how the above barometers 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. All solutions will be injected at ambient temperatures except the HRC, which will be
heated to approximately 140 degrees F prior to injection.
7. Estimated hydraulic capacity of the well: 3-5 gpm
gallons per event (if separate events)
C. INJECTION WELL CONSTRUCTION DATA
I. Injection will be via:
❑ Existing well(s) proposed for use as an injection well. Provide the data in (2) through (6) below to the best of
your knowledge.
❑x Proposed well(s) to be constructed for use as an injection well. Provide the data in (2) through (6) below as
proposed construction specifications.
2.
3.
4.
5.
Well Drilling Contractor's Name: Probe Technologies
NC Well Contractor Certification number: 2724-A
Date to be constructed: TBD pending approval
Approximate depth of each boring (feet): 32
Number of borings: 5
Screened interval/Injection interval of injection wells:
Depth: 25 to 32 feet below ground surface (if multiple intervals, indicate shallowest and deepest depth).
WeII casing (N/A if injection is through direct push rods):
Type: ❑ PVC ❑ Stainless steel ❑u Other: N/A
Casing depth: to ft.
6. Grout (N/A if injection is through direct push rods):
Type: ❑ Cement ❑ Bentonite
Grout depth: to ft.
© Other: NIA
Revised 8/07 UIC-51/5T Page 4 of 7

APPLICATION FOR PERMIT TO CONSTRUCT AND/OR USE A WELL(S) FOR INJECTION
Type 5I Wells —In Situ Groundwater Remediation / Type 5T Wells — Tracer Injection
V. ATTACHMENTS
Provide the following items as attachments with the given headings:
A. 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:
(I) 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 Iist of monitoring parameters and analytical methods to be used; and
(3) a schedule for sampling to monitor the proposed injection.
NOTE: The selected monitoring wells must be located so as to detect any movement•of injection fluids, process by-
products, or formation fluids outside the injection area or zone. The monitoring parameters should include the target
contaminants as well as secondary or intermediate contaminants which may result from the injection and other
parameters which may serve to indicate the progress of the intended reactions, such as pH, ORP, dissolved oxygen, and
Revised 8/07 UIC-5I/5T Page 5 of 7

J
'
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
other electron acceptors and donors. The monitoring schedule should be consistent with the pace of the anticipated
reactions and rate of transport of the injectants and contaminants.
G. WELL DATA
Provide a tabulation of data on all existing or abandoned wells within 1 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 weII 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. all surface water bodies within 'A mile of the injection well or well system; and
f. all existing or abandoned weIIs within 'A mile of the injection well(s) which penetrate the proposed
injection zone, including, but not limited to, monitoring weIIs 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 Iines
b. major changes in lithology
Revised 8/07 UIC-5I/5T 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
Genna K. OlsorgtrGsrzmr of sicnin,^-ofticial) , hereby certify under penalty of law that
1 have personally examined and am familiar with the information submitted in this document and all attachments
thereto and that, based on my inquiry of those individuals immediately responsible for obtaining said information,
I believe that the information is true, accurate and complete. I am aware that there are significant penalties,
including the possibility of fines and imprisonment, for submitting false information. I agree to construct,
operate, maintain, repair, and if applicable, abandon the in iaii wells) and all related appurtenances in
accordance with the am .roved n s ecificat'.ns and coatib� ')
p � nrg�p it. �TFu
b'b
•
nate:
Signatur
°i/1/zol0
SEA
If authorized agent is acting on behalf of the appfte • 137,6, ter'.s ied by the applicant authorizing the
above agent. See Power of Attorney in Appene f . e4 #l. 3•,�
ir,„ llr:i;tlr1
Title: AgenSCA Pe timer : •2-0033
VII. CONSENT OF PROPERTY OWNER (if the property is not owned by the applicant)
("Owner" means any person who holds the fee or other property rights in the well being constructed A well is
real property and its construction on land shall be deemed to vest ownership in the land owner, in the absence of
contrary agreement' in writing.)
Not Applicable Srninted name of pnia:m awnon , as owner of the property on which the
injection well(s) are to be constructed and operated, hereby consent to allow the applicant to construct each
injection well as outlined in this application and agree that it shall be the responsibility of the applicant to ensure
that the injection well(s) conform to the Well Construction Standards (Title 15A NCAC 2C .0200)
Signature: Date:
Title:
See Power of Attorney In Appendix
Submit TWO copies of the completed application package, including all attachments, to:
U1.0 Program
Aquifer Protection Section
North Carolina DENR-DWQ
1636 Mail Service Center
Raleigh, NC 27699-1636
Telephone [phone]
Revised 8/07 UIC-5115T Page 7 of 7

APPLICATION FOR PERMIT TO CONSTRUCT AND/OR USE A WELL(S) FOR INJECTION
Type 5I Wells —1n Situ Groundwater Remediation / Type 5T Wells — Tracer Injection
VI. CERTIFICATION
Ib
incl
opera
accord
Signa
Title: Age
Genna K. Olso '. ,. �e :�:_,,,t , hereby certify under penalty of law that
f sis�iae official)
e personally examined and am familiar with the information submitted in this document and all attachments
and that, based on my inquiry of those individuals immediately responsible for obtaining said information,
that the information is true, accurate and complete. I am aware that there are significant penalties,
the possibility of fines and ' for submitting false information. 1 agree to construct,
ntain, repair, and if . + .. injection well(s) and all related appurtenances in
ith the approved s
If authorized age
above agent. see
VII. CONSENT OF PROP
("Owner" means any per
real property and its cons
contrary agreement in writin
e, a
cations and eo
loner #92-0033
g on behalf of the applicant, s
Attorney in Append o
-ti
0
o holds t
on land shall
Genna K. Olson,Rep, name of p
injection well(s) are to be construct
injection well as outlined in this app
that the injection we l(s) conform to the
S ignatur
Title: Agent for DS
See Pnw of-Attomey in Ap
Submit
Revised 8/07
r #92-0
pies of the c
operate
and
boot tf emit.
ate T�- I 1
702_0
cj,NsEo• •
1.6a•
ettotc y the applicant authorizing the
NNAK.v
-00titr,tia''`'
is not owned by the applicant)
property rights in the well being constructed. A well is
ed to vest ownership in the land owner, in the absence of
, as owner of the property on which the
ereby consent to allow the applicant to construct each
ree that it shall be the responsibility of the applicant to ensure
struction Standards (Title 15A NCAC 2C .0200)
Date: ,im 0/ O
applica . ckage, including all attachments, to:
UIC Progra
quifer Protection S
h Carolina DENR-
36 Mail Service Cente
aleigh, NC 27699-1636
elephone [phone]
UIC-51/5T
RECEIVED 1 DENR / DWQ
Aquifer Protection Section
APR 13 2010
Page 7 of 7

APPENDIX 1:
PETITIONER/DSCA ASSESSMENT AND REMEDIATION AGREEMENT
AND ATC/DSCA CONTRACT

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:
COURTESY CLEANERS
UNDER THE AUTHORITY OF
THE DRY-CLEANING SOLVENT
CLEANUP ACT OF 1997, AS AMENDED,
N.C.G.S. § 143-215.104A, et seq.
GRE BRENNAN STATION LLC
200.PROVIDENCE ROAD, SUITE 105
CHARLOTTE, NORTH CAROLINA
28207
DSCA SITE I.D. 092-0033
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. § 143-2I5.104A ET SEQ.
("DSCA")
I. INTRODUCTION AND STATEMENT OF PURPOSE
The North Carolina Department of Environment and Natural Resources, Division of Waste
Management ("Division") and GRE Brennan Station LLC ("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 21A, 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.
II. STATEMENT OF FACTS
A. On December 03, 2007, Petitioner filed with the Division a Petition for Certification for Courtesy
Cleaners pursuant to DSCA.
B. On November 07, 2005, the Division certified Courtesy Cleaners (hereinafter "Certified Facility
Site") pursuant to DSCA and informed Petitioner of its certification decision.
DSCA ARAv0705 1

C. The Certified Facility Site is located at Brennan Station Shopping Center, 8111 Creedmore
Rd, Raleigh in Wake County, North Carolina.
D. Petitioner is a potentially responsible party, within the meaning of N.C.G.S. § 143-
215.104B(b)(21), for assessment and remediation of dry-cleaning solvent contamination at the
Site, as defined in subsection E, below.
E. The "Site" consists of all areas at the Certified Facility Site where dry-cleaning solvent
contamination arising from dry-cleaning or wholesale distribution operations is found and all
areas where dry-cleaning solvent contamination originating at the Certified Facility Site has
come to be located.
F. The Division is authorized to enter into this Agreement pursuant to the authority vested in the
Environmental Management Commission pursuant to DSCA and duly delegated to the Secretary
of the North Carolina Department of Environment and Natural Resources and further delegated
from the Secretary to the Division.
NOW, THEREFORE, for the purpose of assessing and remediating the dry-cleaning solvent
contamination at the Site, the Parties agree as follows:
III. WORK TO BE PERFORMED
It is Petitioner's desire that assessment and remediation at the Site as required or permitted under
DSCA, the rules adopted under DSCA and guidance documents provided by the DSCA Program
shall be performed by independent contractors selected by the Division. The Division's contractors
shall maintain a minimum level of insurance as defined in their contract with the Division.
IV. DISPUTE RESOLUTION
If Petitioner objects to any Division notice of disapproval or decision made pursuant to this
Agreement, Petitioner shall notify the Division in writing of Petitioner's objections within fourteen
(14) calendar days of receipt of the notice of disapproval or decision. The Parties shall then have an
additional fourteen (14) calendar days from receipt by the Division of the notice of disapproval or
decision to reach an agreement. Han agreement cannot be reached within the fourteen (14) calendar
days, or within an additional period if mutually agreed upon by the Parties, the Division shall provide
a written statement of its decision to Petitioner. Any decision or action by the Division that cannot
be resolved through the dispute resolution procedure established herein may be subject to review
pursuant to Chapter 150B of the North Carolina General Statutes, to the extent such review is
provided by law.
V. FINANCIAL RESPONSIBILITY REQUIREMENTS
Upon demand by the Division, Petitioner shall pay to the Division, on behalf of the Dry -Cleaning
Solvent CIeanup Fund ("Fund"), any amounts for which Petitioner is responsible pursuant to
N.C.G.S. § 143-215.104F(f). Petitioner shall have thirty (30) days from the date of notice of such
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,
DSCA ARAv0705 2

VI. ADDITIONAL PROVISIONS
A. To obtain a unique EPA ID number for the disposal of hazardous wastes generated during the
assessment and remediation ofthe Site, Petitioner agrees that Petitioner will be the Operator on
the RCRA 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 thatmay 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 ownerof 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 1987, 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 ofChapter 130A oftheNorth 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.
DSCA ARAv0705 3

G. The Petitioner has designated the following representative(s) as the point of contact and the
Division will direct all correspondence related to this Agreement to:
Shoffner Allison, Hawthorne Retail Partners Representing GRE Brennan Station
LLC
200 Providence Road, Suite 105
Charlotte, NC 28207-1437
All documents submitted to the Division pursuant to this Agreement shall be mailed or hand
delivered to:
North Carolina Division of Waste Management
DSCA Program
Attn: Scott Stupak
1646 Mail Service Center
Raleigh, NC 27699-1646
H. Petitioner shall not assign or 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.
1. 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 laws 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
DSCA ARAv0705 4

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
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 will not become potentially responsible parties pursuant to N.C.G.S. §
143-2I5.10413(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.
O. 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 ofthe
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. § 143-2 I 5.104B(b)(9), any hazardous substance as defined at
N.C.G.S. § 130A-310(2), or any contaminant as defined at N.C.G.S. § 130A-310.31(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
DSCA ARAv0705
5

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).
T. Termination under Section VLS. (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. § 143-215.104K. Termination by the Division shall
entitle the Petitioner to initiate a contested case pursuant to N.C.G.S. Section 143-215.104S 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:
By:
c R. Butler, PE
Chief, Superfund Section
Division of Waste Management
North Carolina Department of Environment
and Natural Resources
[Sifiature of/for Petitioner]
Joseph P. Mahoney
[Title of Siignatooiy.d Sfgn`rlory
DSCA ARAv0705
[Date]
r1/Z7J o7
[Date] i
6

•
Notary Public (Official Seal)
DSCA ARAv0705
AGREEMENT FOR ASSESSMENT AND REMEDIATION PURSUANT TO DSCA
ATTACHMENT I
LIMITED POWER OF ATTORNEY
I, £ rfe: gce/(44A( S7147:ca j 11 _ ("Petitioner"), 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 pennit 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 I is incorporated.
This limited power of attorney shall terminate upon termination of the Agreement.
Dated 1f a' , d007
(Seal)
Signature of Petitioner
STATE OF Hi COUNTY OF
On this .27 day of NaJcwihte , .2067, personally appeared before me, the said named
-us h / hole `f to me,known and known to me 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.
Joseph P. Mahoney
Authorized Signatory
My Commission Expires 1 Z "13 - i 3
OW iiiii0//
?RINN
tck EXP1RFs.,. is ii
Z ��1�
w188
� ;.w ..
/fM-- (Signature of Notary Public) r yr.,. m ro
//iiilmlt 0
Attachment 1

•
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-
215.1048 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 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.
(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 1 5A 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 ofa
facility site.
DSCA ARAv0705 Attachment 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.143-215.104(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 facilities shall, 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 largest vessel, tank, or container within the spill
containment area and shall be capable of preventing the release of the applicable Iiquid 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 ARAv0705 Attachment 2

•
DSCA PETITIONER QUESTIONNAIRE
1. Indicate which of the following describes the Petitioner's relationship to the Facility Site. Check
all that apply:
® Property Owner ❑ Previous Property Owner
❑ ACTIVE Dry -Cleaning Business Owner ❑ Previous Business Owner
❑ ACTIVE Dry -Cleaning Business Operator ❑ Lessee
2. The Petitioner is a:
❑ Corporation ❑ Partnership
4 Limited Liability Company ■ Individual (including sole proprietor)
■ Limited Partnership ❑ Other:
3. Provide the following information concerning the Petitioner: .
Name: GRE Brennan Station LLC
Address: 200 Providence Road, Suite 105, Charlotte, NC 28207
Telephone: [phone] Fax: [phone]
Federal Tax ID: 26-054932 Email:
4. If the Petitioner is not an individual, designate an individual who is authorized to sign for the
business entity and will serve as the contact for the purposes of this Petition:
Name: Shoffner Allison, Hawthorne Retail Partners
Address: 200 Providence Road, Suite 105, Charlotte, NC 28207/437
Telephone: [phone] Fax: [phone]
Federal Tax ID: Email: [e-mail]
5. If the Petitioner is not the property owner, provide the following information regarding the
Property Owner:
GRE Brennan Station LLC
Phone [phone] Fax [phone] .
200 Providence Road, Suite 105
Charlotte, NC 28207
6. Does the Petitioner have, or has the Petitioner ever had, environmental liability insurance
coverage or general liability insurance coverage?
/4 Yes ■ No
7. Please indicate the type of facility the contamination is attributed to:
® Dry Cleaning Business ❑ Wholesale Distributor ❑ Costume
❑ Uniform ❑ Linen • Other:
DSCA Petition October 2007
Page 2

_J
8. Name and Location of the Facility (or Former Facility):
Name: Courtesy Cleaners
Address: 8111 Creedmore Rd
City: Raleigh County: Wake
Shopping Center: Brennan Station
9. [s this an active Dry -Cleaning business:
® Yes ❑ No
10. Type of Facility (if active):
❑ Drop station only 0 Pert dry-cleaning facility
❑ Non -pert dry cleaning facility 0 Perc and non -pert dry-cleaning facility
11. Size and/or status of Dry -Cleaning business(hitp://www.ncdsca.orglRulesRegs.htm):
® Small facility (fewer than 5 full-time equivalent employees)
❑ Medium facility (at least 5 but fewer than 10 full-time equivalent employees)
• Large facility (more than 10 full-time equivalent employees)
❑ Abandoned facility
❑ Wholesale Distributor •
12. lithe site is abandoned, provide the name of the last Dry -Cleaning Business that did business
at the Facility Site:
Name of Facility:Courtesy Cleaners
Address:8111 Creedmore Rd
13. Is there a water supply well located on the property where the facilityis located:
❑ Yes ►/ No
14. Is the facility in an area scheduled for redevelopment:
■ Yes ® No
If yes, will the building where the facility is located be removed: ■ Yes ❑ No
If yes, when is the redevelopment scheduled:
15. If you are the current property owner, please give date property was purchased.
9/28/2007
16. If you are a previous property owner, please give dates you owned the property.
From To
17. If you are the current or past drycleaner, please give dates facility is/was in operation.
From To
DSCA Petition October 2007
Page 3

OTHER INSTRUCTIONS
1. Documentation of a dry-cleaning related release must be submitted.
Therefore, please submit copies of any reports documenting environmental
assessment or remediation activities previously conducted at this site.
This includes any Phase I or Phase 11 reports conducted for property
transfers.
2. Please make sure that the Acknowledgement page is signed and notarized.
3. Please make sure that you have initialed the applicable Appendices on the
Acknowledgement page.
4. Please be aware that you are required to provide access to the Certified Facility
Site as part of the Petition if you ARE the property owner. If you are NOT the
property owner of the Certified Facility Site, you will be required to obtain
access for the Division and the Division's independent contractors in the
Assessment and Remediation Agreement (ARA) to undertake all work to be
performed at the Certified Facility Site.
5. Completed petitions should be mailed to:
Division of Waste Management
ATTN: Scott Stupak - DSCA Program
401 Oberlin Road, Suite 150
Raleigh, North Carolina 27605-1350
DSCA Petition October 2007 Page 4

ACKNOWLEDGEMENT
The Petitioner has indicated their status as a property owner. Therefore, Appendices A,
B and C apply to this Petitioner. Please proceed to these Appendices and read them
carefully since you will be certifying that you agree with or comply with these
Appendices.
Please initial the spaces below to acknowledge that you have read and are in
compliance with each applicable Appendix.
7M Appendix A -7/14 Appendix B
c741 Appendix C
Petitioner (or authorized representative) hereby swears and affirms that the information
provided in this Petition, inclusive of all appendices and attachments, is true and correct
to the best of Petitioner's knowledge.
Petitioner (or authorized representative) hereby affirms Petitioner's intent to make with
the Dry -Cleaning Solvent Cleanup Act Program such agreements as may be reasonably
required under the -North Carolina Dry -Cleaning Solvent Cleanup Act for the
assessment and remediation of a Dry -Cleaning Business at the Facility Site.
If signing as an authorized representative, I also hereby affirm that 1 am authorized to
execute this Petition on behalf of the Petitioner and that I am authorized to legally bind,
and hereby do legally bind, the Petitioner to this Petition and to all certifications
contained in this Petition, inclusive of all appendices and attachments.
This day of 4fAVel4e''- , 200
Signature of Petitioner (or auth.rep.):'
Name of Petitioner (or auth. rep. - typed or printed):
Joseph P. Mahoney
Authorized Signatory
Title of Petitioner (or auth. rep. - typed or printed):
STATE OF i A
COUNTY OF 5 . o11L
I, cpke n 1- Pr'ino , a Notary Public of the county aforesaid, do
hereby certify that aseph i f / [name of Petitioner]
personally appeared before me this day and, having been duly sworn, executed the
foregoing DSCA Petition for Certification in my presence.
DSCA Petition October 2007 4 Page 5

WITNESS my hand and official seal this 0" day of AgwayY , 200 V.
My Commission expires: /1-U-/3
[SEAL]
STEPHEN J. PRINN
Notbry Public
Comm am= et Massachusetts
My Comrnfaslon Expires
December 13, 2013
DSCA Petition October 2007 Page 6

APPENDIX A
ACCESS AGREEMENT A
(Petitioner is the Property Owner)
Courtesy Cleaners
8111 Creedmore Rd
Brennan Station Shopping Center
Raleigh
Wake County
DSCA Site ID No. 092-0033
Name of Petitioner: GRE Brennan Station LLC
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.G.S. § 143-215.104A 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 Petitioner understands that 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 the Petitioner;
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:
1. Grant of License and Permission. hereby grants to (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;
h) Taking such soil, water and air samples as may be necessary;
DSCA Petition October 2007 Page 7

' 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;
f)
g)
Remediating dry-cleaning solvent contamination at the Property as
needed; and
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 Petitioner's reasonable notice and request, the Petitioner
and its consultants shall have the right to observe any activities performed by or on
behalf of the Division at the Property. Upon the Petitioner's reasonable notice and
request, the Division or its contractors shall allow the Petitioner 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 Petitioner.
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 Petitioner at least 48 hours prior to entering the
Property for the purposes stated in Paragraph 1.
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.
DSCA Petition October 2007 Page 8

7. Protection of Wells and Equipment. The Petitioner shall not damage, remove, pave
over or cover any monitoring or remediation wells on the property. The Petitioner
also shall not tamper with or affect the operation of assessment or remediation
equipment installed on the property by the Division's contractors.
8. 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 Petitioner:
Shoffner Allison, Hawthorne Retail Partners Representing GRE Brennan
Station LLC
200 Providence Road, Suite 105
Charlotte, NC 28207-1437
To the Division:
North Carolina Division of Waste Management -DSCA Program
Attn: Scott Stupak
1646 Mail Service Center
Raleigh, North Carolina 27699-1646
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 laws principles.
11.Integration Clause. This Access Agreement represents the entire understanding
and agreement between the parties hereto and supersedes any and ail 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.
12.Termination. The licenses created in Paragraph 1 may be terminated upon delivery.
of reasonable written notice to the Division, which termination shall be effective upon
receipt of such notice. However, such termination will also terminate the ARA and
cause the forfeiture of liability protection under the DSCA. If no such notice is
served and subject to provisions of Paragraph 2 above, the licenses created herein
shall remain in effect until such time as all work or activities under the Program have
DSCA Petition October 2007 Page 9

been completed at the Property. The right and obligation set out in the first sentence
of Paragraph 6 shall survive the termination of this license.
13. Modification. This Access Agreement may not be amended except in writing by the
parties to this Access Agreement.
The parties each represent and warrant that this Access Agreement is executed by their
duly authorized representatives as of the date accepted and agreed upon below.
Accepted and agreed, this day of , 200 _
Joseph P. Mahoney
Authorized Signatory
(Si ature of Petitioner or Signatory for Petitioner)
( nature for the Division)
DSCA Petition October 2007 Page 10

APPENDIX B
CERTIFICATION OF ABILITY TO PAY AND
ACCEPTANCE OF FINANCIAL RESPONSIBILITY
G.S. § 143-215.104F(b)(2) requires that any person petitioning for certification of a Dry-
Cleaning Facility or Wholesale Distribution Facility or Abandoned Site (collectively:
Facility Site) shall provide the North Carolina Department of Environment and Natural
Resources (NCDENR) with information necessary to demonstrate such person's ability
to incur the response costs specified in G.S. § 143-215.104F(f).
The Petitioner has indicated that this facility is a small dry-cleaning facility. Pursuant to
G.S. § 143-215.104F(f), the required amount of response costs are as follows:
For dry-cleaning facilities owned by persons who employ fewer than five
full-time employees, or the equivalent, in activities related to dry-cleaning
operations during the calendar year preceding the date of the Petition, one
percent (1 %) of the costs of assessment or remediation not exceeding one
million dollars ($1,000,000).
Moreover, G.S. § 143-215.104F(f) requires that each Potentially Responsible Party who
petitions NCDENR to certify a Facility Site shall accept written responsibility in the
amounts specified in G.S. § 143-215.104F(f), and described above, for the assessment
or remediation of the Dry -Cleaning Solvent contamination identified in the Petition.
Note: if two or more Potentially Responsible Parties petition NCDENR jointly, the
amounts specified in G.S.. 143-215.104F(f), and described above, shall be the
aggregate requirements for the financial responsibility of all Potentially Responsible
Parties who are party to the Petition. Unless an alternative arrangemeht is agreed to by
the co -petitioners, the financial responsibility requirements of G.S. § 143-215.104F shall
be apportioned equally among the co -petitioners.
The Petitioner shall demonstrate his ability to incur, and his written acceptance of
financial responsibility for, response costs in the amounts specified in G.S. § 143-
215.104F(f), and described above, for the assessment or remediation of the Dry -
Cleaning Solvent contamination identified in the Petition. The Petitioner shall make this
demonstration by signing the Acknowledgement in this Petition.
DSCA Petition October 2007 Page 11

APPENDIX C
COMPLIANCE WITH STATE AND FEDERAL
ENVIRONMENTAL LAWS, RULES AND REGULATIONS
G.S. § 143-215.104F(b)(4) requires that every Potentially Responsible Party petitioning
for certification of a Dry -Cleaning Facility, Wholesale Distribution Facility or Abandoned
Site (collectively Facility Site) shall provide the North Carolina Department of
Environment and Natural Resources (NCDENR) with information necessary to
demonstrate that the Petitioner and any parent, subsidiary or other affiliate of the
Petitioner, has substantially complied with:
1. The terms of any dry-cleaning solvent assessment agreement, dry-cleaning
solvent remediation agreement, brownflelds agreement, or any other similar agreement
to which the Petitioner or any parent, subsidiary or other affiliate of the Petitioner has
been a party;
2. The requirements applicable to any remediation in which the Petitioner has
previously engaged; and
3. Federal and State laws, regulations, and rules for the protection of the
environment.
By signing the Acknowledgement in this Petition, the Petitioner swears and affirms, to
the best of their knowledge, that the conditions stated above have been met.
DSCA Petition October 2007 Page 12

North Carolina Department of Environment and Natural Resources
Division of Waste Management
NOTICE OF TRANSFER OF OWNERSHIP
For Dry -Cleaning Solvent Cleanup Act (DSCA) Sites
The following information is provided as notice that the ownership of the DSCA certified facility or the property where the
certified facility is located has changed. Please submit this form to the DSCA Progrtnn, 401 Oberlin Rd., Suite 150,
Raleigh, NC 27605, Please complete all blames. ff an item is not applicable, indicate with NA. Please type or print
clearly
Date:
0-7
DSCA ID No. (if known): o 9 a - 0 0 3 3
Action Being Taken: a Change property ownership ❑ Change business ownership
Facility Information: I
Facility Name: Cou1 r feSy. CI-ecine>rs
Facility's Address: g1(1 6re.eCOM00f fLcI ; Su.ee t0(
Facility City: a(ei cl 1/ County:
Fortner Owner/Point of Contact: Company Name: Mark Pfaperle,s [[
Mailing Address: a. j a We, s-f ni a't n ST reci' / tide 300
City, State, Zip: filgm, NL • a i' o1 L39
Contact Person:. ftl a fF h eud H o fa%S
Phone Number: (6%if Fax Number: 717 -" 6 g -70SS'
ctx-i- 3 S
Is the former owner a petitioner in the DSCA Program? I Yes„ ❑ No
If yes, does the former owner wish to continue to be a petitioner? Yes ❑ No
"New Owner/Point of Contact: II
Company Name: GRE. P:ofeeiNr'a1rl S+aTibw% L-LC
Mailing Address: aa0 ProVetteh !-d Sul-e (OS
City, State, Zip; Cleat (6.4-fQ i N C. a R 07
Contact Person: SC6Knet F((tSbW
Phone Number: 7 6 `1 ` 3 3 3 - 74 3.0 Fax Number: 704-" 333 - "P 3 "7
Will the new owner petition for entry into the DSCA Program? • Yes ❑ No
If yes, please submit the DSCA Petition for Certification which can be found at: www.negisco.org
If no, please note that there must be an active petitioner in order for the facility to remain certified in
the DSCA Program.
March 1,2005 version

bENR•
North Carolina Department of Environment and Natural Resources
Division of Purchase and Services
Michael F. Easley, Govemor Michael G. Bryant, Director William G. Ross Jr., Secretary
May 1, 2007
MEMORANDUM
TO: ATC Associates of North Carolina, P.C.
2725 E. Millbrook Rd., Suite 121
Raleigh, NC 27604
Attn: Genna Olson
FROM: Dolan Simmons
Section Chief — Office Property and Services
Division of Purchase and Services
SUBJECT: N07011 S
DSCA Program Environmental Service Contract
Enclosed please find one (1) fully executed duplicate original of Contract Number
N07011S between ATC Associates of North Carolina, P.C., and the Department of
Environment and Natural Resources.
Invoices or matters regarding service delivery should be directed to John Powers,
Contract Administrator, Division of Waste Management, 1646 Mail Service Center,
Raleigh, North Carolina 27699-1646,•[phone]. •
Should you have any questions regarding this contract, you may contact me at (919)
715-3877.
DS/plh
cc: John Powers (w/o enc.)
Brenda Clark (wlenc.)
Jackie Moore, Controller's Office
1605 Mail Service Center, Raleigh, North Carolina 27699-1605
Phone: [phone] FAX: [phone] Internet: www.admin.enr
NorthCarolina
naturally
An Equal opportunity 1 Affirmative Action Employer— 50% Recycled 110% Post Consumer Paper

STATE OF NORTH CAROLINA CONTRACT NO. i u7t /
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, 27604, 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 6, Article 21A, Chapter 143, N.C.G.S. § 143-215.104A 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 March 27, 2007, 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 of the 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; saidalternativesto
include new wells, point -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 of wells 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 ekpert testimony in litigation related to
DSCA where the DEPARTMENT is a party to the litigation. •
N. Special Conditions:
i. Specific CONTRACTOR tasks to be performed under this AGREEMENT shall be
authorized on a task orderlcosts-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

•
DEPARTMENTS 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 of this 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 justification 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 4).
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 he responsible for backfilling all borings and
properly abandoning wells at the site in accordance with all applicable Iocal, 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 paymentsto 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 CON fRACTOR for work performed • under this
Agreement when: (1) CONTRACTOR has completed the work authorized by the DEPARTMENT,
provided that CONTRACTORmay 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.
5. 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 aDSCA site, including both hazardous
waste and non -hazardous waste, and shall further include but not be limited to investigation -
derived waste and remedial wasteresulting 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 Iabels.
Page 4 of I0

. 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 of containers 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
0

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 DS CA 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 a task 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 ofthe 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; fires, 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 ainount 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 tenninate this AGREEMENT except in the
event of a breach of this AGREEMENT by She 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
1

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 aII 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 06B.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 of the 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 DS CA 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 furnished him for use in connection with the performance of this
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 subtler
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 3 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 of race, 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. John Powers 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.
ATG Associates of North Carolina, P.C.
2725 E. MilIbrook Road
Suite 121
Raleigh, NC 27604
By:
North Carolina Department of Environment and
Natural Resources
William G. Ross, Jr., Secretary
By: S
(CONTRACTOR'S Signature) (Signature of Secretary or -Authorized Agent)
Kevin R. Sommers
(Typed Name) •
Title; Vice President
(Owner, Partner, Corp. Pres., or V. Pres. only)
Date: 4/
WITNES
(Signature
Date: 4. 3 0 • a0607.
WITNESS:
(Signature) '
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
$115lhour
$95/hour
$ 80/hour
$65/hour
. $50/hour
$50/hour
$40lhour
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 least 2 bids may be required by the DEPARTMENTs Contract Administrator
(or his duly authorized staff) for subcontracted activities that exceed $3,000.
Laboratory
EPA Method 8260 (soil)
EPA Method 8260 (water)
EPA Method 8270 — Base Neutral Extractables only (soil)
EPA Method 8270 — Base Neutral Extractables only (water)
Miscellaneous
Per Diem (per person for overnight travel only)
Mileage (car or truck) •
Organic Vapor Analyzer
pH/Conductivity Meter
Page 1 of 2
$93/sample
$93/sample
$161/sample
$161/sample
$92
$0.50lmile
$110/day
$25/day

ATTACHMENT 1
FEE SCHEDULE
Miscellaneous (continued)
Interface Probe $30/day
Electric Water Level Indicator $25/day
Teflon Bailer $20/day
Disposable Bailer $S
Stainless Steel Auger $10/day
Grundfos Pump $50/day
Survey Equipment $30/day
Drum $40
Personal Protective Equipment
Level B $30/day
LevelC • $20/day
Consumables (include tape, gloves, ice) $20/day
-Maps, Photos Cost
Camera Not Reimbursable
Cell Phone 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 Engincer/Geologist/Hydrogeologist/Scienlist (S115/hour)
Administrative and/or professional head of the organization or contract Responsible for conceiving
and executing plans and functions of the organization. Directs the professional staff Normally has a
financial interest in the company as partial owner, major investor or stockholder, or officer. Charges an
extremely limited number of hours per site as the Principal. This position should never bill field or field
supervision hours.
- Expert Testimony ".
-1 Legal Strategies •
- Depositions
- Contract Oversight (limited)
Senior Engineer/GeologistlHydrogeologist/Scientist (S95/hour)
Typically requires an advanced degree. Requires professional registration when applicable, 8 years of
experience in technical or managerial roles, and compliance regulations. Serves as senior technical
leader and contract oversight far environmental remediation projects of medium to large scope and /or
complexity and has developed substantial expertise in the field of practice. Generally supervises
Project Managers and oversees several projects. Has limited involvement in projects. Duties typically
include reviewing reports, developing strategics, and attending client and/or DSCA Program meetings.
Responsible for approving designs, reports, plans, and specifications before submittal to the DSCA
Program. If significantly involved in a highly technical project, should have substantial technical
expertise directly related to the project. Ensures compliance of field service operations with OSHA
safety standards. Addresses public health concerns.
•
- Expen Testimony
_Site strategy and planning '
- Contract oversight
- Reviews technical reports .
- Reviews Corrective Action Plans
_ Reviews Engineering/remedial system design
-Health and safety coordinator
_ Reviews site safety plans
Project Engineer/Geologist/Hydrogeologist/Scientist (S80/hour)
Typically possesses a bachelor of science degree in engineering, geology, hydrogeology, or a directly
related field. Serves as manager for entire project artd has at least 5 years of experience in the
environmental field. Duties typically include preparing proposals, reviewing reports, developing
strategies, and attending client and/or DSCA Program meetings. Under general supervision, prepares
environmental design and plan specifications for site remedial activities. Leads and supervises teams of
staff and technician level personnel, but would have a limited number of hours charged to each site,
and only a small percentage of total field hours. Serves as site technical expert or supervisor for
hydrogcological site characterizations and remcdiation activities and tests, and assembly of reports,
plans, and specifications.
.
- Project management -
- Site strategy and planning
- Develop site health and safety plans
- Engineering/remedial system design
- Data review and analysis
- Report preparation (limited)
- Report review
- Site meetings and reconnaissance
- On -site supervision (periodic)
- Work plan preparation
- Site investigation planning
- Field work planning
- Site Inspection (periodic)
- Obtains permission for off -site access
Staff Engineer!Geologist/Hydrogeologist/Scientist ($65/hour)
Requires a bachelor's degree in engineering. geology, hydrogeology, or related science and I• to 5 years
of experience in the environmental field. Works under supervision of the project manager to perform
routine tasks related to environmental investigation and remediation projects. Is the primary person
responsible for gathering field data and is competent at data analysis. Must be able to conduct
investigation and remedial activities including drilling and monitoring well installation. sampling, site
layout and geologic mapping, writing field notes, basic analysis and compiling data Must have
knowledge of QA/QC procedures and protocol. This position will normally be highest in the number of
hours billed to on -site work. However, technicians (see below) should conduct routine or on -going
monitoring.
'
- Report preparation
Field work preparation/planning
- Supervises site investigation and remediation activities
- Site reconnaissance and mapping
- Engineering/remedial system design and installation
- Limited data review and analysis
- Obtains permission for off -site access
-On-site health and safety supervisor
.
•
Technician ($SO/tiour)
Typically requires a high school diploma, certified or licensed trades -person, or an associate's degree..
Person may also have a bachelor's degree with less than 1 year of experience in the environmental
field. Requires minimal training and experience in the environmental field. Responsible for general
supervision of the installation, maintenance, end repair of on -site equipment. Routine monitoring and
collection of samples and equipment maintenance/operating logs. Under appropriate supervision,
performs routine labor tasks associated with on -site installation, maintenance, and repair of f on -site
equipment. Well development and collects soil and groundwater samples.
- Field work preparation
- Operation and maintenance of equipment
- Well developing and sampling
- snit sampling
- Handling of investigation and remediation derived wastes
- Remedial system installation, operation, and maintenance
- Limited contractor supervision
_ Monitoring activities
- Surveying using GPS and standard methods
Draftsperson/CAD ' ($50/hour)
Typically requires a high school diploma. Requires 2 — 8 years of experience or 2 years of related
college and more Than I year of experience. Generally requires a Technical Drawing Certificate, and
advanced drafting skills such as Computer Aided Drafting (CAD) de Design (CARD) operations.
- Drafting
- CAD/CADD work
- Cartography
- Plotting of GPS and standard survey data
•
Word Processor/Clerical (S401hour)
Operates computer for work processing, spreadsheets, and statistical typing, correspondence report
generation, general office work, typing, and filing.
- Spreadsheets •
- Report ion
processing
- Wordi
- Typing
-Filing
- Genera! secretarial
- Document reproduction

ATTACHMENT 3
KEY PERSONNEL FOR THIS AGREEMENT
ATC Associates of North Carolina, P.C.
Program Manager — Genna K. Olson, P.G. (Raleigh, NC office)
Principal in Charge Engineer — 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)
Project Manager — Gabriel Araos, P.E. (Raleigh, NC office)
Project Manager — Stephen Aldis, P.G. (Charlotte, NC office)
Project Manager — S. Eric Shertzer, P.G. (Virginia Beach, VA office)
Project Manager — Rob Sok, P.G. (Virginia Beach, VA office)
Health & Safety Officer— Jeffrey Corson (Raleigh, NC office)
Page 1 of 1
a

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
f

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;
(e) 'making it a requirement that each employee to be engaged in the perforranee
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 whichlimit 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 2 of 2

A. SITE HISTORY
The site property is located in Suite 101 of the Brennan Station Shopping Plaza located at 8111
Creedmoor Road in Raleigh, North Carolina. A site location map is included as Figure 1 and a
site map is included as Figure 2. Courtesy Cleaners has operated as a full service dry-cleaning
facility at the site since 1992. The shopping center property is currently owned by GRE Brennan
Station LLC. A tabulated summary of the site chronology is included as Table 1.
Drycleaning solvent contamination was first discovered beneath the site property during a Phase
II Limited Subsurface Investigation by LandAmerica in April 2005. The investigation consisted
of collecting soil samples from borings SS-1, SS-2, SS-3 and SS-4. Tetrachloroethylene (PCE)
was detected in borings SS-1 and SS-2.
Following the Phase II Limited Subsurface Investigation, LandAmerica conducted an additional
investigation in June 2005 that included the installation of three shallow permanent monitoring
wells (MW-1, MW-2, and MW-3) and a receptor survey. Chlorinated solvents were detected at
concentrations in excess of Title 15A NCAC Subchapter 2L .0202 Groundwater Standards (2L
Standards). Water supply wells were not identified during the receptor survey.
LandAmerica and A&W Professional Services, PLLC, submitted a Prioritization Assessment
Report (PAR) to the DSCA Program in June 2005. The PAR summarized the soil and
groundwater investigation and the results of the receptor survey. The PAR also indicated that the
facility utilizes PCE as the dry cleaning solvent in an L-55 dry to dry system. Courtesy Cleaners
was accepted into the Drycleaning Solvent Cleanup Act (DSCA) Program in November 2005.
In May 2007, ENSR Consulting and Engineering, Inc. submitted a second PAR to the DSCA
Program which documented sampling . of monitoring wells MW-1, MW-2, and MW-3. The
results of the groundwater sampling event indicated PCE and/or trichloroethylene (TCE) at
concentrations in excess of the 2L Standards.
ATC Associates of North Carolina, P.C. (ATC) assumed work at the site on behalf of the DSCA
Program in December 2007. On February 6-8, 2008, ATC advanced hand auger boring HA-1 and
direct -push borings GP/GW-1 through GP/GW-9 to assess the extent of impacted soil and
groundwater. Soil samples were collected from GP-1 through GP-8 and groundwater samples

were collected from GW-1 through GW-9. The soil laboratory results were below the laboratory
detection limits. A summary of the soil analytical results is included in Table 2. The
groundwater results indicated the presence of PCE in GW-1, GW-2 and GW-3. Based on the
direct -push groundwater results, ATC then installed four shallow monitoring wells (MW-4
through MW-7) and one deep well (DW-1) on February 26-29, 2008. Monitoring well
construction details are included in Table 3. Groundwater elevation data is summarized in Table
4. The groundwater laboratory results indicated the presence of PCE and TCE above the 2L
Standards. The horizontal and vertical extent of impacted groundwater was delineated. A
receptor survey completed by ATC indicated the presence of five public water supply wells
(operated by Heater Utilities) and 22 private water supply wells within 0.5 miles of the site and
one unnamed tributary of Turkey Creek within 400 feet of the site. Note that the closest supply
well is 795 feet cross -gradient of the site and supply wells or surface water do not appear
threatened by the release. Figure 3 presents the water supply well location map. During the
assessment activities, ATC was informed by the facility operator that new dry cleaning equipment
had been installed that did not use PCE. These results were documented in an Assessment Report
submitted to the DSCA Program in June 2008.
In July 2008, ATC initiated quarterly groundwater sampling at the site and performed subsequent
sampling events in October 2008, January 2009 and May 2009. A Groundwater Monitoring
Report was submitted to the DSCA Program in August 2009 documenting the quarterly sampling
events. ATC did not continue with the quarterly sampling after May 2009 at the request of the
DSCA Program. Table 5 summarizes the historical groundwater analytical data. Figure 4
presents the groundwater elevation contour map for the May 2009 sampling event and Figure 5
presents the groundwater contaminant concentration map for the May 2009 sampling event.
In April 2009 ATC advanced four hand auger soil borings (HA-2, HA-3, HA-4 and HA-5) inside
the facility in order to further assess impacted soil. Laboratory analytical results indicated PCE
and associated breakdown products in each of the samples. The analytical results are included in
Table 2. In March 2010, ATC resumed quarterly groundwater sampling at the site. However, the
groundwater results had not been received upon the preparation of this injection permit.
2

B. HYDROGEOLOGIC DESCRIPTION
According to the North Carolina Geologic Map (1985), the site is located within the Raleigh Belt
of the Piedmont Physiographic Province of North Carolina, more specifically, the site is underlain by
felsic mica gneiss which is interlayered with graphite mica schist and mica garnet schist, commonly
with kyanite; minor hornblende gneiss has also been observed.
Based on soils encountered during drilling operations, the stratigraphy of the site is described as
silty to sandy clay near the ground surface underlain by silty sand, sandy silt, and saprolite/weathered
bedrock. Fairly competent metamorphic bedrock was encountered at a depth of 68 feet below
ground surface (bgs) in the deep well advanced at the site. A geologic transect and cross sections
are included in Figures 6 and 6A.
Based on recent and historical groundwater elevation data, the direction of groundwater flow
across the site is west consistent with topography. The horizontal hydraulic gradient is estimated
at 0.0037 ft/ft based on groundwater elevations for monitoring wells MW-4 and MW-6 in May
2009. The depth to groundwater across the site varies from 21.12 to 29.21 feet bgs across the
contaminant plume. In the area of the proposed remediation activities (source area), the depth to
groundwater ranges from approximately 22 to 27 feet bgs. Table 4 presents the groundwater
elevation data.
Shelby tube samples were collected from the subject site for analysis of physical soil parameters.
Based on Shelby tube data for the 30 to 32 foot interval below the water table, the total porosity is
estimated at 52.9 percent and the effective porosity, generally equivalent to specific yield, is
estimated at 39.5 percent. The hydraulic conductivity calculated from the Shelby tube sample is
1.46x104cm/s (0.414 ft/day). However, this value indicates vertical hydraulic conductivity which
may be lower than horizontal hydraulic conductivity. Based on published references indicating
vertical horizontal conductivity may be on the order of 10 percent_ of horizontal hydraulic
conductivity,.ATC estimates the horizontal hydraulic conductivity may be as high as 4.14 ft/day.
Based on a hydraulic conductivity range of 0.414 to 4.14 ft/day, a hydraulic gradient of 0.0037
ft/ft, and an effective porosity of 39.5 percent, the horizontal groundwater velocity may range
from 0.0039 ft/day (1.4 ft/year) to 0.039 ft/day (14 ft/year). Based on a hydraulic conductivity
range of 0.414 to 4.14 ft/day, the average depth to groundwater of 26.27 feet, and the average
3

depth to bedrock of 68 feet, the transmissivity of the unconsolidated aquifer may range from
17.28 ft2/day to 172.8 ft2/day.
C. INJECTION FLUID COMPOSITION
The proposed injectant is a mixture developed by Innovative Environmental Technologies, Inc.
(IET) designed to use synergistic technologies to reductively dechlorinate the chlorinated volatile
organic compounds (CVOCs). IET's injection mixture has previously been approved for
injection by the NCDENR UIC Program. The primary components of the mixture are Hydrogen --
Release Compound (HRC), zero valent iron (ZVI), and EHC. Additional additives to the
injection mixture include vitamin stimulants (hydrolyzed kelp and blue green algae), yeast
extract, nutrients, and propionate. All of these additions are food -grade and do not pose an
environmental concern. Lastly, nitrogen gas is also included in the injection process. Additional
details regarding the specific components of the injection mixture and the purpose of each
component are provided in Section D (2). The volumes and concentrations of each component
proposed to be injected are summarized in Appendix 2.
D. INJECTION RATIONALE
1. Goals of Injection
A Tier 1 and 2 Risk Assessment was completed for the site in accordance with the DSCA •
Program's Risk Based Corrective Action Guidance. The results of the risk assessment indicated
that concentrations of PCE in soil and groundwater exceed the Tier 2 Site Specific Target Levels
(SSTLs). ATC is implementing a soil vapor extraction system to mitigate the impacted soil
beneath the facility. The goal of the injection is to remediate PCE concentrations in source area
groundwater to below the SSTLs for the protection of groundwater water pathway (0.11 mg/L).
ATC is proposing an injection event in the source area (1,200 square feet). The horizontal extent
of groundwater impacted above the remedial goals is located near MW-1 and MW-2. Vertically,
the extent of groundwater impacted with PCE above the remedial goal is estimated to extend
from the water table to approximately 35 feet below ground surface (bgs). Figure 7 presents the
proposed injection area.
4

2. Reactions Between Injectates and Contaminants
As discussed in Section C, the proposed injectant is a mixture developed by Innovative
Environmental Technologies, Inc. (IET). A description of each component of the injection
mixture and the purpose of each component is provided below:
Hydrogen Release Compound (ARC) — HRC is an organic carbon source produced by
Regenesis that is utilized to enhance anaerobic bioremediation. HRC is a proprietary,
environmentally safe, food -grade, polylactate ester, specially formulated for slow release of lactic
acid. The lactic acid acts as a long-lasting source of hydrogen which stimulates the biological
community for enhanced reductive dechlorination of CVOCs. Reductive dechlorination is a well
known step-by-step contaminant biodegradation mechanism which converts detrimental
contaminants into harmless end products like ethene and ethane. Under the influence of HRC, this
process may continue at an accelerated rate for periods of up to 18 months or longer on a single
injection.
Zero Valent Iron (ZVI1 — Micron scaled ZVI will be injected in a slurry solution and is also
intended to reductively dechlorinate the CVOCs. The primary reduction mechanism with ZVI is
direct electron transfer from the ZVI to the contaminants at the metal -water interface, resulting in
dechlorination and the production of ferrous iron. This is an immediate abiotic reaction. As a
secondary dechlorination mechanism, corrosion of iron metal yields ferrous iron and hydrogen,
both of which are used biotically to reduce chlorinated volatile organic compounds.
EHC - EHC' is an additional source of both organic carbon and ZVI produced by Adventus. 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 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.
5

Yeast Extract — Yeast extract will be added to the injection mixture in an effort to stimulate the
biological community by providing a hydrogen source for reductive dehalogenation, as well as
nutrients and vitamins essential for microorganism and bio-film growth.
Vitamin Stimulants (Blue Green Algae and Hydrolyzed Kelp) — The addition of vitamin
stimulants to the injection mixture is intended to minimize the potential for a stall in reductive
dechlorination at cis-1,2-dichloroethylene, which is sometimes a concern with enhanced
anaerobic bioremediation of CVOCs. The very soluble blue green algae and hydrolyzed kelp will
provide vitamins B-2 and B-I2, as well as organic hydrogen donors and volatile fatty acids, that
lower the activation energy required for the electron transfer of the terminal electron to cis- I,2-
dichloroethene, as well as allow for more efficient utilization of the hydrogen in the anaerobe,
increasing the overall kinetics.
Nutrients — The nutrients to be injected are basically a fertilizer mixture consisting of di -
ammonium phosphate and urea. Nutrients are required for the maintenance of the microbial
metabolic pathways, ATP/ADP synthesis and organelle development.
Propionate — Propionate acts as a substrate for hydrogen production for reductive
dehalogenation. Propionate operates as an electron donor for microorganisms that are able to
reductively dehalogenate chlorinated hydrocarbons.
Nitrogen Gas — Nitrogen gas is injected prior to and following the liquid chemical injectates_
The purpose of the nitrogen gas injection is to clear the injection lines, establish injection
pathways prior to injection, and force the injected fluids into the formation after injection.
Material Safety Data Sheets (MSDS) and proposed injection concentrations for each component
of the injection mixture are included in Appendix 2.
3. Summary Results of Previous Modeling or Testing
Available case studies and product literature are included in Appendix 3 of this permit
application.

E. INJECTION PROCEDURE AND EQUIPMENT
The injection site is approximately 1,200 square feet in area and is planned to be treated with a
total of five direct -push injections with two injection intervals at 25 to 27 feet bgs and 30 to 32
feet bgs. A total volume of 750 gallons of injectate is planned for the targeted area. The target
area is shown in Figure 7. The injection activities are expected to last approximately one day.
Iniectate Procedures
The injection points will be advanced via traditional direct -push technology, utilizing an- RAMS
PowerProbe, mounted on a skid loader, or Geoprobe 6620. The injection rods will consist of IET's
proprietary injection system with retractable injection zones driven to the desired injection depth
using a direct -push drilling rig. Once injection at a location 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.
Injection will be performed using IET's injection trailer and patented injection process. The
different components of the injectant mixture will each be injected in series via IET's patented
process as described below:
Step 1— Injection of nitrogen gas.
Step 2 — Injection of a solution of sodium sulfite, yeast extract, calcium propionate,
nutrients, blue green algae and kelp. "
Step 3 — Injection of ZVI and EHC injection.
Step 4 — Injection of HRC.
Step 5 — Second injection of sodium sulfite and nutrients.
Step 6 — Second injection of nitrogen gas.
IET's injection trailer is equipped with tanks for mixing the injection solutions. Municipal water
will be used for the solution mixing. High pressure hose or PVC pipe will extend from the mixing
tank, to the injection pump, to the injection rod or injection well head. A pressure gauge, shut-off
valves, and pressure bleed -off will also be installed in -line. Injection will be performed using a
diaphragm pump. Injection pressures may range from 50 to 100 psi and injection flow rates may
7

range from 3 to 5 gpm. 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,
the injection pump will be turned off and the shut-off valve will be closed. The residual pressure
in the formation will then be monitored until a safe level is reached. The process will then be
repeated at the next injection Iocation.
G. MONITORING PLAN
Groundwater samples will be collected from monitoring wells MW 1 through MW-7 and DW-1
to monitor the effectiveness of the injection activities. Groundwater samples will be analyzed for
volatile organics by EPA Method 8260. Sampling of the monitoring wells will be performed using
low flow sampling methods which include the monitoring of temperature, dissolved oxygen, pH,
oxidation-reduction potential, specific conductivity, and groundwater elevation. In addition, to
monitor parameters related to reductive dechiorination and the injected fluids, groundwater
samples will be analyzed for sulfates, methane, ethane, and ethene prior to and following
injection, and for volatile fatty acids after injection only. Samples will also be analyzed for total
and dissolved iron through the utilization of field Hach kits. Groundwater samples will be
collected from the wells specified above prior to injection, three months, six months, and one year
following injection.
H. WELL DATA
Well construction details for the existing monitoring wells are included in Table 3. Receptor
surveys conducted at the site identified five public water supply wells and 22 private water supply
wells within 0.5 miles of the site. Note that the closest supply well is 795 feet cross -gradient of
the site and supply wells do not appear threatened by the release. Well construction details for
the water supply wells are included in Table 7.
8

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 1: Site Chronology
ADT 2: Analytical Data for Soil
ADT 3: Monitoring Well Construction Data
ADT 4: Groundwater Elevation Data
ADT 5: Analytical Data for Groundwater
ADT 7: Water Well Survey Data
ADT 9: Analytical Data for Natural Attenuation Parameters
Note that ADT 6 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.

Analytical Data Tables
for
North Carolina Dry -Cleaning Solvent Cleanup Act Program
Facility Name:
Courtesy Cleaners
8111 Creedmoor Road, Raleigh, Wake County, North Carolina
DSCA ID No.:
92-0033
Submittal Date:
4/9/2010
Prepared B. .
ATC Associates of North Carolina, P.C.
2725 East Millbrook Road, Suite 121, Raleigh, North Carolina 27604

Table 1: Site Chronology ADT 1
DSCA ID No.: 92-0033
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.
1992
Courtesy Cleaners begins dry cleaning operations at the site.
4/1/2005
A Phase ['Limited Subsurface Investigation Report prepared by LandAmerica Assessment Corporation (LandAmerica)
identified PCE impacted soils beneath the facility. The scope of work included the advancement of four soil borings (SS-
1 through SS-4). PCE was identified in SS-1 and SS-2.
6/1/2005
LandAmerica conducted additional investigation in June 2005 that included the installation of three shallow monitoring
wells (MW-1, MW-2 and MW-3) and a receptor survey. PCE was detected in MW-I and MW-2 in excess of the 2L
Standards. Water supply wells were not identified during the receptor survey. The results of the Phase [I investigations
were submitted in a Prioritization Assessment Report (PAR) by LandAmerica to the DSCA Program.
11/1/2005
The site was accepted into the DSCA Program and an Assessment & Remediation Agreement was executed.
5/1/2007
A PAR was submitted by ENSR Consulting & Engineering, Inc. to the DSCA Program. Three monitoring wells (MW-1,
MW-2, and MW-3) were sampled. The results of the groundwater sampling activities indicated that groundwater
hadbeen impacted and that the plume was not fully delineated.
6/5/2008
ATC Associates of North Carolina, P.C. (ATC) completed an Assessment Report documenting field activities performed
between 2/5/2008 and 3/4/2008. The scope of work included the advancement of one hand auger (HA-1) soil boring
location on 2/8/08; advancement of direct -push borings GP/GW-1 through GP/GW-9 and the collection of eight soil
samples and nine groundwater samples on 2/6/08 through 2/8/08; installation of one vertical extent monitoring well
(DW-1) and four shallow monitoring wells (MW-4 through MW-7) on 2/26-29/08; collection of groundwater samples
from MW-1, MW-2 and MW-3 on 2/5/08; collection of groundwater samples from MW-4 through MW-7 and DW-1 on
3/4/08; and an updated receptor survey. The receptor survey identified five public water supply wells, 22 private water
supply wells and an unnamed tributary of Turkey Creek within 0.5 miles of the site. The horizontal and vertical extent of
impacted soils and groundwater were defined during the assessment. ATC was also informed that the current operator
does not use PCE in the dry cleaning process. The results were submitted in an Assessment Report dated 6/5/08.
7/29-30/2008
A quarterly groundwater sampling event was conducted. Monitoring wells MW-1 through MW-7 and DW-1 were
sampled. PCE exceeded the 2L Standard in monitoring wells MW-1, MW-2 and MW-3. Additional chlorinated
volatile organic compounds (CVOCs), including TCE and vinyl chloride were also detected in certain samples.
10/21-22/2008
A quarterly groundwater sampling event was conducted. Monitoring wells MW-I through MW-7 and DW-I were
sampled. PCE exceeded the 2L Standard in monitoring wells MW-1, MW-2 and MW-3. Additional CVOCs,
including TCE, cis-1,2-dichloroethylene and vinyl chloride were also detected in certain samples.
1/6-7/2009
A quarterly groundwater sampling event was conducted. Monitoring wells MW-1 through MW-7 and DW-1 were
sampled. PCE exceeded the 2L Standard in monitoring wells MW-1, MW-2 and MW-3. Additional CVOCs, including
TCE and vinyl chloride were also detected in certain samples.
4/22/2009
Soil samples HA-2 through HA-5 were collected via hand auger inside the facility. PCE, TCE and vinyl chloride were
detected in the soil samples.
5/7/2009
Aquarterly groundwater sampling event was conducted. Monitoring wells MW-1 through MW-7 and DW-1 were
sampled. PCE exceeded the 2L Standard in monitoring wells MW-1, MW-2 and MW-3. Additional CVOCs, including
TCE, cis-1,2-dichloroethylene and vinyl chloride were also detected in certain samples.
Page 1 of 2

Table 1: Site Chronology ADT 1
DSCA ID No.: 92-0033
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.
8/11/2009
An Annual Groundwater Monitoring Report was submitted to the DSCA Program documenting the July 2008, October
2008, January 2009, and May 2009 sampling events.
9/10/2009
ATC prepared a draft Risk Assessment and established Site Specific Target Levels (SSTLs) for soil and groundwater
remediation. Based on the Risk Assessment, ATC developed a remediation strategy to mitigate impacts to the soil and
groundwater.
Page 2 of 2

HA-3
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Table 2: Analytical Data for Soil ADT 2
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x
a
u
Sample 1D
DSCA ID No.: 92-0033
Table 2: Analytical Data for Soil ADT 2
N
Depth
[feet bgsl
A
Sampling Date (mm/dd/yy)
I,I,I-Trichloroethane
11
1,1,2,2-Tetrachloroethane
3
g
1,1,2-Trichloroethanae
111
8
1,1-Dichloroethane
El8
g
l,I-Dichloroethylene
1,2-Dichloroethane
(EDC)
S
S
Benzene
0
0
0
o
0
1
Il,
a
g
;
g
_
Benzo(a)pyrene
Carbon tetrachloride
Chloroform
o
g
o
0
o
g
'�
cis-1,2-Dichloroethylene
N
oo
A
Ethylbenzene
—
n
Methyl tert-butyl ether
(MTBE)
1
�
g
Naphthalene
Tetrachloroethylene
1
Toluene
-
W
0
s
trans-1,2-Dichloroethylenc
1
111
g
Trichloroethylene
Vinyl chloride
1
A
Xylenes (total)

Table 3: Monitoring Well Construction Data Ul l 3
DSCA ID No.: 92-0033
Well ID
Date Installed
(mm/dd/yy)
Number of Samples
Well Depth
[feet]
Well Diameter
[inch]
Screen Interval
[feet]
Status
(Active/Inactive)
MW-1
6/13/2005
7
30
2
20-35
Active
MW-2
6/13/2005
7
30
2
10-30
Active
MW-3
6/13/2005
7
30
2
10-30
Active
MW-4
2/27/2008
5
35
2
25-35
Activc
MW-5
2/26/2008
5
35
2
15-35
Active
MW-6
2/27/2008
5
35
2
25-35
Active
MW-7
2/28/2008
5
35
2
15-35
Active
DW-1
2/29/2008
5
88
2
83-88
Active
Page 1 of 1

'Table 4: Groundwater Elevation Data %DT 4
DSCA ID No.: 92-0033
Groundwater
Sampling Point
Sampling Date
(mm/dd/yy)
TOC Elevation
[feet]
Depth to Water
[feet bgs]
Groundwater
Elevation
[feet]
Depth to NAPL
[feet bgs]
NAPL Thickness
[feet]
Corrected*
Groundwater
Elevation [feed
!\.1E1-I
6/13/05
478.78
23.20
455.58
NA
NA
NA
12/11/06
478.78
24.85
453.93
NA
NA
NA
2/5/08
478.78
26.41
452.37
NA
NA
NA
7/30/08
478.78
26.80
451.98
NA
NA
NA
10/22/08
478.78
26.50
452.28
NA
NA
NA
1/7/09
478.78
25.76
453.02
NA
NA
NA
5/7/09
478.78
24.35
454.43
NA
NA
NA
MW-2
6/13/05
478.28
22.88
455.40
NA
NA
NA
12/11/06
478.28
24.48
453.80
NA
NA
NA
2/5/08
478.28
26.08
452.22
NA
NA
NA
7/30/08
478.28
26.55
451.73
NA
NA
NA
10/21/08
478.28
26.11
452.17
NA
NA
NA
I/6/09
478.28
25.45
452.83
NA
NA
NA
5/7/09
478.28
24.00
454.28
NA
NA
NA
MW-3
6/13/05
476.47
21.12
455.35
NA
NA
NA
12/11/06
476.47
23.56
452.91
NA
NA
NA
2/5/08
476.47
24.15
452.32
NA
NA
NA
7/30/08
476.47
24.80
451.67
NA
NA
NA
10/21/08
476.47
24,27
452.20
NA
NA
NA
1/6/09
476.47
23.49
452.98
NA
NA
NA
5/7/09
476.47
22.15
454.32
NA
NA
NA
MW-4
3/4/08
478.99
25.42
453.57
NA
NA
NA
7/30/08
478.99
25.71
453.28
NA
NA
NA
10/21/08
478.99
25.64
453.35
NA
NA
NA
1/6/09
478.99
25.41
453.58
NA
NA
NA
5/7/09
478.99
24.00
454.99
NA
NA
NA
MW-5
3/4/08
478.03
25.70
452.33
NA
NA
NA
7/30/08
478.03
27.12
450.91
NA
NA
NA
10/21/08
478.03
26.28
451.75
NA
NA
NA
1/7/09
478.03
25.19
452.84
NA
NA
NA
5/7/09
478.03
23.90
454.13
NA
NA
NA
MW-6
3/4/08
479.71
28.30
451.41
NA
NA
NA
7/30/08
479.71
29.21
450.50
NA
NA
NA
10/21/08
479.71
28.60
451.11
NA
NA
NA
1/6/09
479.71
27.80
451.91
NA
NA
NA
5/7/09
479.71
26.21
453.50
NA
NA
NA
MW-7
3/4/08
479.07
27.25
451.82
NA
NA
NA
7f29/08
479.07
28.45
450.62
NA
NA
NA
10/21/08
479.07
27.31
451.76
NA
NA
NA
1/7/09
479.07
26.86
452.21
NA
NA
NA
5/7/09
479.07
25.25
453.82
NA
NA
NA
DW-I
• 3/4/08
477.36
25.58
451.78
NA
NA
NA
7/29/08
477.36
25.74
451.62
NA
NA
NA
10/21/08
477.36
25.22
452.14
NA
NA
NA
1/6/09
477.36
25.21
452.15
NA
NA
NA
5/7/09
477.36
23.23
454.13
NA
NA
NA
Page 1 of 1

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Table 7: Water Wells) Survey Data ADT 7
DSCA ID No.: 92-0033
Ref. No./
Well ID
Owner's Narne &
Physical Address
Telephone
Number
Well On
Site (Y/N)
Distance
from
Source
[feet]
Well
Depth
[feet]
Screen
Interval
[feet]
Use of Well
Source of Well
Identification
Direction
(downgradient,
upgradient, etc., to
source area)
Status
(Active/
Inactive)
1919-847-7632
Charles & Carole Vish, 8401
Camellia Drive, Raleigh
Y
2,020
Unknown
Unknown
Drinking
ATC Receptor
Surveysource
North (upgradient to
area)
Active
2
John M. Rogers, 8405
Camellia Drive, Raleigh
Unlisted
Y
2,100
Unknown
Unknown
Drinking
ATC Receptor
Survey
North (upgradient to
source area)
Active
3
William & Leslie Hart, 8409
Camellia Drive, Raleigh, NC
919-846-5662
Y
2,400
Unknown
Unknown
Drinking
ATC Receptor
Surveysource
North (upgradient to
area)
Active
4
I lal Harris, 8416 Camellia
Drive, Raleigh, NC
919-847-4947
Y
2,560
Unknown
Unknown
Drinking
ATC Receptor
Survey
North (upgradient to
source area)
Active
5
Frank & Brenda Ham, 8412
Drive, Raleigh, NC
919-847-4121
Y
2,375
Unknown
Unknown
Drinking
ATC Receptor
Survey
North (upgradient to
source area)
Active
Jack & Kay Menius, 8408
Drive, Raleigh, NC
Y
2.150
Unknown
Unknown
Drinking
ATC Receptor
Survey
North (upgradient to
source area)
Active
7
Andrew & Kleitsch, 8404
Drive, Raleigh, NC
919-848-0222
Y
2,031
Unknown
Unknown
Drinking
ATC Receptor
Survey
North (upgradient to
source area)
Active
8
Kelli Barbour, 8400
Camellia Drive, Raleigh, NC
919-772-5160
Y
1,925
Unknown
Unknown
Abandoned
ATC Receptor
Survey
North (upgradient to
source area)
Abandoned
9
Lorraine Tomasino, 8420
Drive, Raleigh, NC
919-841-9338
Y
2,560
Unknown
Unknown
Drinking
ATC Receptor
Survey
North (upgradient to
source area)
Active
10
Bruce Blackwell, 8401
Azalea Place, Raleigh, NC
Unlisted
Y
1,720
Unknown
Unknown
Abandoned
ATC Receptor
Survey
North (upgradient to
source area)
Abandoned
11
Elias Schnegelberger, 8405
Place, Raleigh, NC
919-847-4828
Y
2,100
Unknown
Unknown
Drinking
ATC Receptor
Survey
North (upgradient to
source area)
Active
12
Jaswantrai Patel, 8409
Azalea Place, Raleigh, NC
919-846-7173
Y
2,210
Unknown
Unknown
Drinking
ATC Receptor
Survey
North (upgradient to
source areal
Active
13
Kenneth Hunsinger, 8413
Azalea Place, Raleigh, NC
919-847-4159
Y
2,300
Unknown
Unknown
Drinking
ATC Receptor
Survey
North (upgradient to
source area)
Active
14
Ann B. Johnson, 8416
Azalea Place, Raleigh, NC
Unlisted
Y
2,550
Unknown
Unknown
Drinking
ATC Receptor
Survey
North (upgradient to
source area)
Active
15
Vance Kennedy, 8412
Azalea Place, Raleigh, NC
919-847-4055
Y
2,200
Unknown
Unknown
Drinking
ATC Receptor
Survey
North (upgradient to
source area)
Active
16
Richard Lemert, 8408
Azalea Place, Raleigh, NC
919-846-0558
Y
2,060
Unknown
Unknown
Drinking
ATC Receptor
Survey
North (upgradient to
source area)
Active
Page 1 of 2

Table 7: Water Well(s) Survey Data ADT 7
DSCA 1D No.: 92-0033
Ref. No./
Well ID
Owner's Name &
Physical Address
Telephone
Number
Well On
Site (Y/N)
Distance
from
Source
[feet]
Well
Depth
[feet]
Screen
Interval
[feet]
Use of Well
Source of Well
Identification
Direction
(downgradient,
upgradient, etc., to
source area)
Status
(Active/
Inactive)
I
Frederick Schwartz, 8404
Azalea Place, Raleigh, NC
919-676-1249
Y
1,900
Unknown
Unknown
Drinking
ATC Receptor
Surveysource
North (upgradient to
area)
Active
I 8919-847-7575
Eugene Kennedy, 8400
Azalea Place, Raleigh, NC
Y
1,775
Unknown
Unknown
Drinking
ATC Receptor
Survey
North (upgradient to
source area)
Abandoned
19
Elizabeth M. Mercer, 8433
Camellia Drive, Raleigh, NC
(919)-847-
5754
Y
2,620
Unknown
Unknown
Drinking
ATC Receptor
Survey
North (upgradient to
source area)
Active
20
Betty Rogerson, 8429
Camellia Drive, Raleigh, NC
(919)-847-
5613
Y
2,630
Unknown
Unknown
Drinking
ATC Receptor
Surveysource
North (upgradient to
area)
Active
21
John & Goldie R. Duperock,
8425 Camellia Drive,
Raleigh NC
(919)-847-
j l53
Y
2,640
Unknown
Unknown
Drinking
ATC Receptor
Survey
North (upgradient to
source area)
Active
22
Stephen Farlow, 8217
Creedmoor Road, Raleigh,
NC
919-556-9677
Y
795
Unknown
Unknown
Drinking
ATC Receptor
Survey
North-northwest
(crossgradient to source
area)
Active
23
Heater Utilities, 202
MacKenan Drive, Cary, NC
(Well at 8208 Morgans Way)
919-467-7854
Y
1,325
Unknown
Unknown
Drinking
ATC Receptor
Survey
South (crossgradient to
source area)
Active
24
Ileater Utilities, 202
MacKenan Drive, Cary, NC
at 2604 Salisbury
Plain)
919-467-7854
Y
2,360
Unknown
Unknown
Drinking
ATC Receptor
Survey
South (crossgradient to
source area)
Active
25
Heater Utilities, 202
MacKenan Drive, Cary, NC
(Well at 8333 Morgans Way)
919-467-7854
Y
2,130
Unknown
Unknown
Drinking
ATC Receptor
Survey
South (crossgradient to
source area)
Active
26(Well
Heater Utilities, 202
MacKenan Drive, Cary, NC
at 3215 Brennan
Drive)
919-467 7R54
Y
2,115
Unknown
Unknown
Drinking
ATC Receptor
Survey
West (downgradient to
source area)
Active
27
Heater Utilities, 202
MacKenan Drive, Cary, NC
(Well at 3120 Avondale
Court)
919-467-7854
Y
1,690
Unknown
Unknown
Drinking
ATC Receptor
Survey
West (downgradient to
source area)
Active
Page 2 of 2

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Table 9: Analytical Data for Natural Attenuation Parameters ADT 9
DSCA ID No.: 92-0033
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FIGURES
Figure 1: Site Location Map
Figure 2: Site Map
Figure 3: Water Supply Well Location Map
Figure 4: Groundwater Elevation Contour Map
Figure 5: Groundwater Contamination Concentration Map
Figure 6: Cross -Section Location Map
Figure 6A: Geologic Cross -Section A -A'
Figure 7: Proposed Injection Area Map

APPENDIX 2:
INJECTANT CONCENTRATIONS AND MSDS DATA SHEETS

INNOVATIVE I O M NTA L. TECH OLOQ S, INC.
Addendum to the October 2009
In -Situ Reductive Dechlorination Proposal
to
ATC Associates, Inc.
For
Courtesy Cleaners
Raleigh, North Carolina
March 2010 .
Innovative Environmental Technologies, Inc.
6130 Kit Road
Pipersville, PA 18947
[phone]

March 12, 2010
ATC Associates
Elizabeth Allyn
Dear Ms. Allyn:
The site in Raleigh, North Carolina has been identified by the State of North Carolina and
their environmental consultant, ATC Associates, Inc. (ATC), as having soils and
groundwater impacted by the historical use of tetrachloroethene. The primary
compounds of concern at the site are this compound and its anaerobic dechlorination
daughter products. Innovative Environmental Technologies, Inc. (IET) has performed an
evaluation of the historical data, boring logs and field analyses. Based on this data
review, IET has identified a treatment area, which will allow for substantial treatment of
residual chlorinated ethenes within the groundwater and soil in the saturated zone. The
proposed methods for the targeted area will utilize synergistic technologies applied via
patented delivery processes.
The map of the proposed injection areas is included as follows:
R AREA

The injection event is proposed to treat 1,200 square feet in the vicinity of MW-1 and MW-2. A
10 foot vertical treatment area from 25 to 35 feet bgs is proposed using two injection intervals
from 25-27 feet bgs and 30-32 feet bgs. An injection radius of 9 feet is proposed and based on
this injection radius, 5 injection points will be required to treat the 1,200 square foot area.
The injections will occur at a maximum gas pressure of 150 psi, with a range of 50-150 psi. The
maximum liquid pressure would be 100 psi, with a range of 50-100 psi. The rate of injection will
be approximately 3 to 5 gpm, with 150 gallons injected over the 10 foot vertical zone targeted in
each injection point for a total of 750 gallons of solution. The project is anticipated to take 1 day
to inject the remedial materials into the five injection points.
A summary of the concentrations of the remedial materials are presented below for each interval
and each injection well.
Remedial Material
Concentration (lb/gal) Per
Interval
Concentration (lb/gal) Per
Injection Point
EHC
50 lbs/75 gal
100 lbs/150 gal
ZVI
27.5 lbs/75 gal
55 lbs/150 gal
Blue Green Algae
5.36 lbs/75 gal
10.72 lbs/150 gal
Yeast Extract
10 lbs/75 gal
20 lbs/150 gal
Kelp
44 lbs/75 gal
88 lbs/150 gal
Nutrient
10 lbs/75 gal
20 lbs/150 gal
Calcium Propionate
50 Ibs/75 gal
100 Ibs/150 gal
The injection points are anticipated to have an anticipated radius of influence of 9 feet.
The total quantities of all materials proposed to be injected are listed in the table below, per
injection point and the total for the 5 injection points:
Remedial Material
Total Per Injection Point
Total Across Site
EHC
100 lbs
500 lbs
ZVI
55 Ibs
275 lbs
Blue Green Algae
10.72 Ibs
53.6 lbs
Yeast Extract
20 Ibs
100 Ibs
Kelp
88 Ibs
440 Ibs
Nutrient
20 Ibs
100 Ibs
Calcium Propionate
100 lbs
500 lbs
If you have any questions or comments, please let me know.
Thank you,
Sincerely,
Elizabeth Bishop
Manager of Technology Assessment
Innovative Environmental Technologies
888-721-8283
[e-mail]

1
INNOVATIVE TIVE ENVIRONMENTAL ONMENTAL TECHNOLOGIES, INC.
Proposal to Perform In -Situ Reductive Dechlorination
of Soil and Groundwater via Synergistic Technologies
to
ATC Associates
For
Courtesy Cleaners
Raleigh, NC
Revised October 2009
Innovative Environmental Technologies, Inc.
6130 Kit Road
Pipersville, PA 18947
[phone]

ATC Associates -- Courtesy Cleaners
Page 2
October 16, 2009
ATC Associates
Gabe Araos
Dear Mr. Araos:
Innovative Environmental Technologies Inc. (IET) has completed a remedial design and
quotation for the site, Courtesy Cleaners, located in Raleigh, NC. The site has been identified as
having impacted soils and groundwater due to the historic use of tetrachloroethene (PCE). The
presence of PCE's daughter products, such as trichloroethene (TCE), cis-1,2-dichloroethene (cis-
1,2-DCE) and vinyl chloride (VC) were identified in the data analysis. The concentrations of
these contaminates is such that reductive dechlorination is taking place at a rate that needs to
,be stimulated, both abiotically and biotically. As a result of IET's evaluation of the historical
data, boring logs and field analyses, a design which will promote and accelerate reductive
dechlorination in the subsurface is being proposed. A 1,200 square foot source area treatment
is being proposed at the Courtesy Cleaners site. The following proposal will set -forth a lump
sum price for the design, implementation and follow up of this process. All costs included in the
lump sum price are listed below.
• All materials necessary to complete the proposed plan
• All equipment and personnel required to execute the proposed plan
• Handling and Management of materials on site
• Mobilization/Demobilization of the injection crews
• All per diem for the required crews
• Site Restoration
• Final field injection report
• Final plot of injection points
• Six quarterly data analysis reports

ATC Associates — Courtesy Cleaners
Page 3
Table of Contents
OBJECTIVE 7
AREA A 8
SCOPE OF SERVICES 8
SUMMARY 9
Recommended Sampling' 10
APPENDICES: 10
APPENDIX 1 (SITE MAP) 11
APPENDIX 2 (CALCULATION SHEETS) 12

ATC Associates — Courtesy Cleaners
Page 4
TECHNOLOGY DISCUSSION
The options available for a cost-effective and reliable technology to treat chlorinated
hydrocarbon contaminants such as tetrachloroethene (PCE), trichloroethene (TCE), cis-1,2-
dichlorethene (cis-1,2-DCE), and carbon tetrachloride in groundwater have in recent years
moved away from traditional pump -and -treat processes, especially in cases where:
• NAPL; micro -emulsions or high concentration adsorbed materials are present leading to
high dissolved phase concentrations.
• Access to groundwater is restricted by surface structures or uses.
• Local restrictions forbid the implementation of other available technologies such as air
sparging or natural attenuation.
• Pump and Treat technologies have been applied, but have reached asymptotic removal
rates.
• Contamination is extensive and concentrations are too high for risk based closure but
otherwise relatively low (typically 10D-7500 ppb).
• The migration of dissolved Chlorinated Aliphatic Compounds (CAHs) across property
boundaries or into adjacent surface water presents a long-term remediation
requirement.
• The vertical migration of free phase CAHs (DNAPL) into underlying drinking water
aquifers is a -concern.
The environmental chemistry of a site in part determines the rate of biodegradation of
chlorinated solvents at that site. The initial metabolism of chlorinated solvents such as
chloroethenes and chloroethanes in ground water usually involves a biochemical process
described as sequential reductive dechlorination. The occurrence of different types and
concentrations of electron donors such as native organic matter, and electron acceptors such as
oxygen and chlorinated solvents, determines to a large degree the extent to which reductive
dechlorination occurs during the natural attenuation of a site. To accelerate the natural
processes, ZVI and enhanced microbial dechlorination processes are proposed to be utilized at
the site. The utilization of coenzymes, oxygen scavengers and nutrients insures that little or no
lag phase in the process is experienced and that the most efficient pathways may be utilized.
Reductive dechlorination only occurs in the absence of oxygen; and, the chlorinated solvent
actually substitutes for oxygen in the physiology of the microorganisms carrying out the process.
As a result of the use of the chlorinated solvent during this physiological process it is at least in
part dechlorinated. The site shall have introduced to the subsurface an oxygen scavenger to
ensure that this process would occur immediately. Further, recent studies suggest that metal —
containing coenzymes, found in certain types of anaerobic microorganisms, and can reductively
dechlorinate one- and two -carbon solvents. Cobalt -containing corrinoid cofactors such as
vitamin B12 mediate the reductive dechlorination of carbon tetrachloride and
tetrachloroethene. In these biological systems the rate -limiting step to complete dechlorination
to ethylene is the last stage conversion of vinyl chloride. The rate of that process has been found
to be significantly enhanced by the presence of vitamin B12, which acts as an electron carrier. It

IF
ATC Associates — Courtesy Cleaners
Page 5
is the core of B12, which contains cobalt, and the various oxidation states the cobalt obtains,
which allows for the electron transfer intra-cellularly. The existence of the cobalt core has also
been seen to catalyze th'e surface reaction of the iron lowering the necessary activation energy
required for the electron transfer.
Zero Valent Iron chemically may be thought of having been the product of the positively charged
metal ions receiving electrons to become the electrically neutral pure metal. The term
"reduction" is applied to any chemical reaction that added electrons to an element. Thus ZVI is a
reduced material. In a similar manner, the chemical term "oxidation" refers to any chemical
reaction that removes electrons from a material. For a material to be reduced, some other
material must be oxidized. In the reduction of a chlorinated compound the zero valent iron is
oxidized. Zero valent iron enhanced abiotic degradation of chlorinated volatile organic
compounds (CVOCs) is essentially a reductive dechlorination process, which uses granular cast
iron as the reducing agent, and produces final reaction products such as ethane, ethene, and
chloride ions in the degradation of TCE. During this treatment process, the corrosion of iron by
water dominates the chemical processes. The corrosion of iron by water results in ferrous ion
generation, hydroxyl ion generation, and hydrogen gas generation. This results in a decrease in
ORP (oxidation/reduction potential; that is, reducing conditions are produced) and an increase
in pH. Accordingly, the end products of this reaction are ferrous iron, chloride ions, and the
dehalogenated compound.
Frequently remedial sites show insignificant or incomplete dechlorination, especially those with
high aquifer sulfate levels. It is generally overlooked that the rapid conversion of sulfate to toxic
free sulfide during bacterial reductive dechlorination plays a significant role in the "stalling" of the
biotic stalling frequently observed. Accumulation of free sulfide is especially important in sites
that display both high sulfate and low available iron. Reductive dechlorination inhibition by free
sulfide has been observed in microcosms conducted for high sulfate field sites. Free sulfide
toxicity to microorganisms can be prevented if ferrous iron precipitates the free sulfide. Further,
iron sulfide mineral precipitates have been shown to catalyze reductive dechlorination of
chlorinated solvents at rates comparable to metallic iron, on a surface area normalized basis.
Microcosms performed at high sulfate sites have been showed to both remove free sulfide toxicity
to dehalogenating bacteria and to enhance catalytic reductive dechlorination when ferrous iron is
added. Further, ferrous iron, itself, may act as an electron donor.
Injected, colloidal reactive iron is a promising new technology, which may be applied, in a
synergistic approach with compatible technologies. There are two primary reactions with CAHs
that take place which will consume the iron and require stoichiometric consideration:
• the anaerobic iron corrosion reaction in which water is disassociated to form hydrogen
gas; and

ATC Associates — Courtesy Cleaners
Page 6
• the direct adsorption of a chlorinated hydrocarbon onto the surface of the iron,
followed by reductive dehalogenation.
Recent research on elemental iron systems suggests that four mechanisms are at work during
the reductive process:
• First, the Fe° acts as a reductant by supplying electrons directly from the metal surface
to an adsorbed halogenated compound.
• Second, hydrogen gas is generated by the anaerobic corrosion of the metallic iron by
water.
• Third, metallic iron may act as a catalyst for the reaction of hydrogen with the
halogenated hydrocarbon using the hydrogen produced on the surface of the iron metal
as the result of anaerobic corrosion with water. Theoretically, these reactions are not
kinetically effective without a catalyst; thus, it is thought that impurities in the iron or
surface defects act as that catalyst.
• Fourth, solubilized ferrous iron can also act as a reductant, albeit at a rate at least an
order of magnitude slower.
Hydrogen gas can be used for reductive dehalogenation by the following reaction:
H2+X-CI=X-H+H'+Cr
Hydrogen Release Compound (HRC) is one of a variety of organic carbon sources, which may be
used to supply necessary dissolved hydrogen to a biological system. It is used to stimulate rapid
degradation of chlorinated solvent contaminants often found in groundwater and soil and has
been applied to treat compounds such as perchloroethene and trichloroethene on sites across
the US. HRC has been shown to achieve rapid in situ degradation of target contamination
without the costs and disruption associated with complex engineered remediation systems, and
without the ongoing cost and liability of natural attenuation approaches.
HRC is a proprietary, environmentally safe, food quality, polylactate ester specially formulated
for slow release of lactic acid upon hydration. The HRC is simply applied to the subsurface via
push -point injection or within dedicated wells. The HRC is then left in place where it passively
works to stimulate rapid contaminant degradation. HRC is a polylactate ester product,
environmentally safe and of food quality. HRC provides a long-lasting, continuous and highly
diffusible source of lactic acid to stimulate microbial production of hydrogen. It reduces time to
closure with minimal site disturbance.
The use of blue green algae and kelp is an additive that not only provides a variety of organic
carbon and hydrogen sources, but also provides a source of nutrients and vitamins. When
anaerobic bacteria digest sugars and carbohydrates; they convert the sugars and carbohydrates
into gases, most commonly hydrogen. By utilizing a variety of very soluble and slightly soluble
kelp and blue green algae sources, IET will be able to provide a longer lasting source of vitamins,
nutrients, and organic carbon than is commercially available in alternative remedial materials.
Blue green algae is rich in gamma-linolenic acid, and also provides alpha-linolenic acid, linoleic
acid, stearidonic acid, eicosapentaenoic acid, docosahexaenoic acid, and arachidonic acid. Blue
green algae and kelp also contain vitamins Bi, B2, B3, B6, B9, B12, vitamin C, vitamin D, and

ATC Associates — Courtesy Cleaners
Page 7
vitamin E. Kelp, Ascopyllum nodosum, contains over 50% carbohydrates, 5% fat, 25% alginic
acid and numerous essential macro -nutrients, micro -nutrients and vitamins. Combined, these
materials offer long term organic hydrogen sources, buffering capacity and essential nutrient for
the sustained, biologically mediated anaerobic dechlorinization.
IET is also proposing to utilize EHC at Courtesy Cleaners. EHC is a fibrous plant based organic
hydrogen donor which slowly produces glucose. Glucose, a six carbon compound is degraded by
most microorganisms through a series of reactions resulting in the formation of smaller carbon
compounds (5 ,4, 3, 2 carbons). These are then re -utilized as building materials either directly or
after modifications for the synthesis of nucleic acids, proteins, carbohydrates and lipids.
Glucose degradation by Embden Meyerhof Pathway - EMP involves ten reactions and operates
both under aerobic as well as anaerobic conditions. Under aerobic conditions, this pathway
functions in conjunction with the tricarboxylic acid (TCA) cycle in which the pyruvate generated
through the EMP is oxidized to CO2 and water. Under anaerobic conditions, pyruvate is reduced
to lactate or ethanol. Energetically this pathway yields 2 moles of pyruvate and 4 ammonium
triphosphates (ATP) per mole of fructose diphosphate fermented. Of these 1 mole of ATP is used
in the phosphorylation of glucose and the second is utilized for the phosphorylation of fructose-
6-phosphate, the net yield is therefore only 2 moles of ATP per mole of glucose fermented.
Studies have shown that hydrogen produced in -situ is one element in a remedial program that
supports the growth of methanogens, homoacetogens, and certain sulfate reducers and
denitrifiers. In addition, many hydrogen -utilizing microorganisms are known mediate reductive
dechlorination reactions. For example, some methanogens and acetogens have been shown to
mediate reductive dechlorination of TCE and PCE. These reactions are believed to be
cometabolic (that is, the reactions occur fortuitously and do not yield energy for the
organisms). In contrast to the cometabolic dechlorinating microbes, a handful of bacteria have
been isolated in the past seven years, which can couple reductive dechlorination of PCE and TCE
for energy and growth (Le., PCE and TCE serve as terminal electron acceptors - just like we
breathe oxygen, they breathe chlorinated solvents).
The application of these two synergist technologies: colloidal iron and microbial reductive
dechlorination process may be further enhanced through microbial amendments and reducing
agents. The proposed treatment technology presented herein applies these technologies.
Critical to the success of the proposed remedial technologies is the successful delivery of the
various materials to the targeted groundwater and soils.
OBJECTIVE
It shall be the objective of Innovative Environmental Technologies, Inc. (IET) to promote the
conditions in -situ, necessary for accelerated dechlorination via microbial processes. Further,
through the introduction of a 1-3 micron zero valent iron colloidal suspension, reduction of the
dissolved phased CVOCs will occur while initiating the production of hydrogen for microbial
mineralization processes

ATC Associates — Courtesy Cleaners
Page 8
The remedial plan described herein is designed to achieve source area reductions of CVOCs in the
vadose and saturated zones. No additional equipment or maintenance will be required and
because no waste streams will be generated, no disposal permitting will be required during the
remedial effort. IET proposes to implement a program, which shall:
• Supply all essential microbial elements necessary for dechlorination processes to occur.
• Introduce zero valent iron (ZVI) to further and quickly address dissolved phase compounds
while acting synergistically with the anaerobic processes.
AREA A
The treatment area proposed for the treatment of the present on -site known groundwater
contamination in the vicinity of MW-1, MW-2, and GW-1 is 1,200 square feet with a 10 foot
vertical contaminated zone to be treated between 25 and 35 feet below ground surface (bgs).
An injection radius of 9 feet is proposed. Based on the area to be treated and the injection radii,
5 injections would be required to treat the 1,200 square foot area with 2 injection intervals at
25-27 feet bgs and 30-32 feet bgs_ Soil concentrations at the site are moderate which indicates
that some absorbsion on the soil particle is occurring. Therefore soil absorbsion correction is
moderate (IET has assumed the value to be 5%). The corresponding dosage calculations are
located in Appendix 2.
SCOPE OF SERVICES
1. SATURATED ZONE INJECTIONS
The following sequence will be followed when injecting into the saturated zone.
1. Subsurface Pathway Development
Initially, nitrogen gas shall be delivered to the subsurface via IET proprietary
I
injection trailer system. Nitrogen gas is used so as not to introduce oxygen
into an environment targeted for anaerobic processes. The gas is introduced at
approximately 175 psi such that delivery pathways and voids are established.
Pathway development shall be verified by observing a substantial pressure
drop.
2. Sodium Sulfite, Nutrient and Micro Nutrient Injection
A solution of sodium sulfite, yeast extract, calcium propionate, nutrients, blue
green algae, and kelp are immediately injected into the subsurface fractures
and voids that were developed during the gas injection step. Sodium sulfite
acts as an oxygen scavenger, iron reducer and sulfate source. As an oxygen
scavenger, the sodium sulfite prevents the oxidation of the ZVI by the
dissolved oxygen while promoting anaerobic conditions that are favorable for
the biodegradation of the CVOCs. Nutrients, injected as organic ammonia and

ATC Associates — Courtesy Cleaners
Page 9
ortho-phosphate, are required for the maintenance of the microbial metabolic
pathways, ATP/ADP synthesis and organelle development.
3. ZVI and EHC Injection
ZVI and EHC is injected immediately following the sodium sulfite/bioslurry
solution to reduce concentrations of dissolved -phase CVOCs while providing
for rapidly generated hydrogen for the microbial stimulation.
4. HRC Injection
HRC will be injected immediately after the ZVI injection to provide a slow
release hydrogen source for the anaerobic dechlorination of the CVOCs.
5. Sodium Sulfite/Nutrient Injection
This injection is conducted to clear the injection lines and to provide for in -situ
mixing and penetration of the HRC product.
6. Post Liquid Injection - Gas Injection
Lastly, the injection lines are cleared of liquids and all injectants are forced
into the created formation and upward into the vadose zone.
Once the injection cycle is complete, the injection point is capped to allow for the
pressurized subsurface to accept the injectants.
The targeted saturated zone at the site shall receive calculated dosages of the
individual remedial components based on biological and stoichiometric demands and
an estimated pore volume based on the known geology of the site.
SUMMARY
Innovative Environmental Technologies, Inc. presents this remedial design as a "Lump -Sum"
amount based on the treatments area. The cost to implement the remedial event for the
proposed treatment area is $23,527.73. The remedial program is anticipated to take 1 day to
implement. The price presented herein is guaranteed regardless of the actual field time
required to implement the program described herein.
The "Lump -Sum" price set -forth assumes that a water supply and a secure storage area for
chemicals are available for the duration of the project.

ATC Associates — Courtesy Cleaners
Page 10
Recommended Sampling:
Field Sampling:
Dissolved Oxygen (DO),
Oxidation/Reduction Potential (ORP),
Specific Conductivity,
pH
Temperature and
Groundwater Elevation.
Laboratory Analyses:
Method 8260 VOCS
TCE
PCE
Cis-1,2-DCE
Trans-1,2-DCE
1,1-DCE
Vinyl Chloride
Ethene
Ethane
Methane
Sulfate
Total and Dissolved Iron
Volatile Fatty Acids using Microseeps or Microbial Insights for the Laboratory Analysis
APPENDICES:

ATC Associates — Courtesy Cleaners
Page 11
APPENDIX 1 (SITE MAP)
u
CANOPY
r` APPROXIMATE EVENT OF
GROUNDWATER c 47AY9UT10N
1 STORY BRICK
Area A L,200 FtXti
RieltdQ, AREA
M°9GPIG11-11
mo a JD w
ss-
PARKING AREA
COURTESY
Van i
b
e.
,11/0•1-e
e
ARKING
AREA
anrs J
/
//
a �

ATC Associates - Courtesy Cleaners
Page 12
APPENDIX 2 (CALCULATION SHEETS)
Area A
Site Name Courtesy Cleaners
Area A
Parameters
Units
Assumptions
Target Area FtX Ft.
Soil Absorbsion Correction for GAC Constant 94 5
Area of influence of Remediation Injection(s) Sq. Ft. 254.46879
Estimated Number of Injections to Treat Area # Injections 5
vertical impacted zone Ft. 10
Total Volume Targeted Cu. Yd. 444.4444444
Porosity % 20.00%
Groundwater Flow Velocity Ft1Yr 7.00
Injection Depth FL - bgs 25.00
Volatile Organic Compounds In Water
1200
TCA
PCE
TCE
c-DCE
t-DCE
1-1 DCA
1,1 DCE
VC
Injection Parameters
ppb 10 0.01 ppm
ppb 500 0.5 ppm
ppb 500 0.5 ppm
ppb 500 0.5 ppm
ppb 10 0.01 ppm
ppb 10 0.01 ppm
ppb 10 0.01 ppm
ppb 50 0.05 ppm
Anticipated Radius of Influence
l
innovative environmental technologies, inc.
Courtesy Cleaners
B2 Calculations 1
Vitamin B2 Calculations
i
Number of Ato ns(Molecuie i Mol. Wt
Cabon
17 ?
121
204
Hydrogen
20 !
11
20
Cobalt
0 i
59's
0
Nitrogen
4
141
56
Oxygen
6
161
96
Phosporus
0 i
311
0
.
=Grans/mole
376i
11 Molar solution=
376ig/liter
,,Conversion molar to Micrometer
1.00E-06?
'1 micromolarselution
3.76E-04;glIiter
150 m icromolar solution
1.66E-02igrliter
Anticipated radius d irtection
9lfeet
Anticipated vertical impact
1Dlfeet
-
Estimated pore.clume
20.00% percent
Calculated impacted liquid
3806.853098lgallons
Calculated impacted liquid
14410.4617211iters
1B2 dosage/injection
270.91668031grams
i
ITotal Injections
51
1B2 Required for Project
1354.5834.02€grams
1
Ft
9
innovative environmental technologies, inc.
Courtesy Cleaners B.12 Calculations I I
Vitamin B12 Calculations;
i 1
Number ofAtomsIMolecule L MoL we
Cabcn 63 ? 121
756
Hydrogen
68 1 1
68
Cobalt
Nitrogen
-1 - -r- - 559—
14 14
59
196
Oxygen
14 l 16
224
Phospons
1 { 31.
31
Grans/mole
13541
1 Molar solution =
1354!gilder 1
Comersionmolar toMicromotar €
1.00E-06
1 mlcromolarsolution
1.35E-03071iter
2 micramoIar solution
271E-034liter •
Anticipated rauius digestion
9,feet
Anticipatedvortical impact
10;feet 1
Estimated pore volume
20.03%j percent
Calculated impacted liquid
3806.853098,gallons i
Calculated impacted liquid
14410.4617211iters
B12 dosage/injection
39.023530331grams
Total biectiars
5
B12 Regr iced for Project
195.11765171srans

ATC Associates - Courtesy Cleaners
Page 13
70.11714C Points
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t, o7o1 .1101 Leage try - comclion Ear mention
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JVI Parameters )}f161
Ssalece arse g90447
Spec$c Compound half Likes 6.- ET 2IA
PCE
TCE
t,1 DCE
1-DCE
a DCE
VC
TCA
DCA
Carinnrlan7 Conic. A.uends
PCE
TCE
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TCE
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24.00
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700 00
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1200 00
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180 00
660.00
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5
5
10
5
10
1
10
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57.29k
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55 b5
251.45
25145
6.026
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251.45
25 145
5 029
5 029
min for 1a1 order
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746 25
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5.11 ,

ATC Associates — Courtesy Clean ers
Page 14
Courtesy Cleaners
;Areo A
•median Point 0
Humber of Pts
-Impact Horizon i
Paint t Depthlsj 1.0e0t1n0
I 25-35' .1 outside
i '5 2
10:
itpecron Pekin
laatsriate
082
53.66:8G Al0at
Z00?Yeast Until
500 iti4C
5020; 5500
517-85`. 6967.73
513.55 51,350 00
5325 51.152600
3D0 HRC s
_-- 61325 978,00
.._........._ ....._.___....,.- —.__._... __.53r
276: &I r 59 SO SZS12-50
---___
1t0: Pounds Kelp
tls Kelp ▪ E9_30 11,180D0
100:10001001 1150. St50.0a
O'.Porlmsr10s 521.S5 50.00
......__5C5Proolarsala .. ! —_.... e205_ _—_ 51,a75.00
i ▪ 515,32518
i Aber
0$j8 ofPraha. 1 $1600 $15000D
r 023 1 760 svps0
Nitrogen—....__..__. _�._.__..,...— .._: ....,.----
DaysollETINemRSTnaler 1 IT 52.7 3: 52.75006
'!.i:ats lETeupentain ate 1 11 51,2!A 5125020
iaae ----1 5as01.53
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Sub Total 3 523,012.75
1.1.1oence Lela Tatsl $23,527,73
Total 6latmlal Cast _I _ 517,51218
:Installs:Oar Cast 1 55,50D.00;
Capital Cost. 523 07278- s
Licence Fee e51 95;
Type
Totals
62-Grams
210.9156803
1351.683402
012- Gleams
39.02353033
195.1176617
EifC
100
SOD
C0rap0nant CINTe1ited13
Kelp
247 - ias
5S
275
88
440
60.07153472
300
Mess-ldiI green algae lq lr i 23164.62100::. 243882061e 1 j Area A
pram ;pi1015emmayCampa0e00 ' t Oisi(abutloo linear
in52-c'8 5350 Member 05p402ts it 5
CastBG.up Alper*
157.85 61720 Graars B71pA
Totals f 593321 , 595778 ?Pewee 13G 4a. e
D 0
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Cosiper Poirot
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:Depth erlgleraloo I 2s-2r
:Crams 0241 f 0
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60 _ , 6
54.705.55
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ra
A
Micropowder Iron

Innovative Envi ronmenta I Techno I ogies ,Inc.
Fe° Micro Powder 1-3 microns
Hydrogen Source and Surface Oxidation Compound
SPECIFICATIONS
Chemical Description:
IRON POWDER FINES
Specifications:
Appearance @ 25 deg. C
Color (Visual)
Apparent Density (g/cm3, MP-488-W)
Tap Density (g/cm3)
True Density (g/cm3)
Sieve Analysis (200 Mesh)
Average Particle Diameter (microns)
% Iron (Mass Balance, MP-1095-W)
% Carbon
% Oxygen
% Nitrogen
Uniform Powder
Grey
1.5 -- 3.0
3.5 -4.5
7.5 — 7.8
0. 2 Maximum
1-3
98 Minimum
<1
0.7 Maximum
<1

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• DINOVATWEENIIRONMEffAL ThOINOLCIGIES, INC. . •
retcrisrcefor enutrovnenfaIpmfessimialssie evatkre aftinvve technapitest
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'-88.8-7214zs3
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Ewing,Nt • Colunibui,01:1 • Doypstaws, • TB • ilo;bnport,
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mAzialw, sArErstVAto, siun
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' • Beam
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• PRODUCkt 6;4thmSulgte.'.
pin? eam;Sulfde - •
43EgiMICAkii.
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CillafFEALA,STraCtrNI;i4 77. 57-0-7
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PRODUCT CODE NQ.: 17572. -
. • geakii n -HAZARDOUS
voMpoStr• 1
•[sofuttin note. . -1
kiis% . • • • I
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1_ 1 .HAZARD .
jteritint
-Seetionlil,;EVALTII &Frgur AID INFOILMATION • '
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• MUTATION': Breathing dust rosy IOW**, nose and throat nniX lapse email:192nd
clis,st &Comfort IteninVe to fresh aft Too artificial. raspiraijon ff not breathing. Cat
['made madleal litteuthm.
conssious, ininwthifrly giving,lalge.nrammts &Nair. Get imrnediafo
*died attendan•Vo not -give aintalog by mouth to an unconscious of convulsing
person. • ' ' '
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EYE CONTActr Darts may britafe the eyes. xiTurpAh. ,•-ly flush Oyes whit jots Of
running water for 15 minutes, lifting the tikei-had Iosinx eyelids awasionally. Get
iminediate medical attemion.
SKW ciniTrA.cr: No fuliatkat is incely Oct briefeoutsat tut mgiietrritaiin/ diet
• prolonged tioniacti fiimeaddy wish' akhi. with Iot* of Soap. add water,. Remove
contaminated clothing and shor.5 wash before muse, Get medical fitting& if imitation
pabilsafterwashipg.•
•trictovAnirs Erivilithwumaii in3C11110LOGIES,
resetroe for ravisant;uslai prefersiemis reeling hmenetive aitensatics tecimainght"

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(. .. — . OMER. ERALTIIDATA:•.. . .
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.: • t • ! ,.
• . ' - IWO 95G makintsperltrmeal, Ineutirividelis) • '
WO ilS kug/kg (lutraverm;::, id, aohiimu.;) . . • ', • : • • •
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•
' Seethe W -PHYWCALDATI
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hrgsfizd NONA YLav•
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Emzeina-GRA.viry (Efat:.,I 163
APPRARANI7E4,19 ODODR: yak: mysIds or powder'
Bonigo kW: nay.
VAPODItiltEiSTRg: n:av:
SOLDR1LITYr..?1014
- • • deefilierV.FIRE. •AND WI.OSIONTr0d0B
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EnCTAL DMEDloiTiRig PROCEDIatES PDECAHOTIONS: lire fighters
- amid Veer self-bootalned Inorolift* apparatus and kril. protOFfivlatbing. Use wafer
spray to cool nearby cdnthMen dntructures exposed to fim.
ILINtirStrAL YJR.E.:SsEXPLOSIONHAEARDS: none
SetlionVI -REACTIVITY
SWAM Stable, •
HAZARDOUS POLION: Vfilgoioemtr
CONDITIONS & MATERTALs TO AVOID: Operifiauies. muffling ares. other high
temperature ficruitei which may Induce therthal depomposition. Avoid adds. oiddhsing
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Itia4RDOTIS DECOMPOSITION PRODUCTS' May Murat* suMF42oxick Sms•
Seetion111VEMPLOYE4PROTECTION '
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1.11 •
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r (*NUM MEASURES: (Gird roam veshladrIzt reqiured. Asi rota& tad saki
` shower should b'e nearby audteadylbr use. ! - • . •
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▪ ' RittiPIRAtORY PliOlEdITON: It use ratilifmns genrIabli 'ask wear it MOM • .
approved iespitstaispptogriatitor dzosegmladei Was. Appropdate tevimiont may be
.a full fice-plece or a half giarkeir-pudigag 4;113141ga respirator with .. =dui a '.
• self-cogalned breathiug appasniuslts .The press= . &reed mode. or at uppliod-alt -.
rasphator. . -' •
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kW:137.611n =MFG; Long-ileeved shirt, truimedmieiy gmea, rubber gleiits, .
iauttaisber apron. - • - • -
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EYE PROTZCXEON: Safety &lasses with- side adds. His kali/ally ricognized that
contact leases should zit be wera-vdmmivotkiag viiiii et mAlimil. beeause contact leases. . .
. • may coahluteto gip severity :Oa eye injury. . .
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Scifian VW qiNVIEWItaligArlritOTPerf0A • • • • 'A • - •
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• •ENViROilltittat 4113.Miinglisi$: ite:Eove all combustible.ma.tedai:froso spill ' 4% • .
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f 7$Ar..T.,-oxt LrAxxitEgittrrxoip Weal: gogglesi•glayaiiad dast.mmk.Cirefully
1. sweep or coop vili:e•sitiviigei:cOmlaim load:bold folilisipiai. Wash therstill aids
' ' thorour4dy to reinovo oxiclisit%resl.cluo. "
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WASTE DISPosA14 Po:large Ras, ▪ seek the advice efapsofessiops1 disposal vendee.
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• Section IX -RtGULAtORYOONIROL.9
»Eri.or ritmspORTATION: Not regulated under the 11.2mi:tort of Mager*
Goads Art.
DOT CLAWFICA.11 ON: N/A.
liOTPRCPER =MDR NAIE;N/A
OMR DOT iNFORMATI ON:N/A
%rags cussipremom D24
OTHkRitE.GilLA.TORY REQICIMEMMT: new
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gesion NiEck1711IONS: HOMING, STORAGE & trim%
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L
?; Store1n a cool, dryr.Well waged PUN aw y fmos ineompalgole mated& kjeBP bags
ar fiber drams dty at al times. Keep ohs lightly dosed. Wash thncaugbly niter
bandrmgFDonot get ineyes. oasldap;orondnthing. ..
P4PEDBY:MSDSDepartraent DATE:IIpdstahrtuary•14,20D2
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11114-*A4T641k: "17'
• ,11410VATIVE agiiIROWERTAI:TpRI101.0 GIES •
BEAR TAVERN ROAD • • • • '
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PNI
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• Jit Eirhig,P1 • "• • tOhgabitip•Ott •‘Doylestpvtil;PA • • • Dayeilpowkt.
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t .888421-8283. • " • •••• - • • • •••••: ••• •
• JQIATERIAL SAFE**DATA SHEET. • • •
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• Pft..• HOUR ElitIER6ENCY-451.5TATICE: . - . - • • .. • •
• • INNOVATIVE OiVIRONMENTA. YECHNOLOGiER":•• 1:11118421:8283 • , . • : - . ' ' . ' '7:'1.:.-...
CHFMTREC ' • • ' . , • . 1: . 1400424-930D- • : .. •".. „. : ,.•.• , -
: • • ,- .•• . ' . • . •',:. _ .. . • ..;" . • : •"+• i •''. •
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••• TRADE rulam ER)1E1. • 7. • • • - ; ; •••••• ' •
- • • • .comP4D+Risi . • • .
•
s • : . - • . •• • — — •
. • syrol;yinf* • Ciatvrecle; eirfoilyldlaretizipuffbaintarc ' •.-. !i•
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Cba
• • • ;tie iig611- via; • cAftgaGit:i.i,113.:1 . • 3 . . ,••• - t•-• .
( • • - • • , Miteedulgaiiht • • • - • " " . • •
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•. 2. . ; ogisipii4; pen:- • . •
44-,s 144Ff Tel*" '-YSF•-;;.• P 4 . : •
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. • - ,• •. • . . •Ammolunaphetspbadi, Diarrap?termtikkoien photphate,CibasTe
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•cherricfmarglir.:‘ set ; ' • 4 - 1.:; • - - •
•
'• • , MeTecuu4acuill= limatighoi
r teltaiLidarVigata • • ' ••• •
: - • ••,.. • : • • ..„.1,„
3; • - notedium Phavb.1.0•13-11 •
• . .• co.011!1•3;bei:'.1•• . .
. • . • ' siniir•I•14 •• 40dIumPtrd Firptutte!
•
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• FLAMMAEItriY: Noll4ortillusEble • •
• REACTIVI* Stab! • " • •
.2110Miatli.P.4111L:
. „ ' •-• • : ; • • 1410‘011e= •
• ' : • 'Chemical Furdly:' • - ysit -
. Mali iaiFolsasee treitv4 ' • .
psis .
• • . . . . - •
, . pitopubr rigrapiummoty;.•
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•
- • 7. „ • :"
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Cidturn pill:play! Ir nplimle,Codkei;FtIllidnigen,
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- : • , :.• .f.,4
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'HEALtfli b itannful Irv/allowed.. May be frritatIng to the McIrs, eyes mid fespiratory tilct. Heated: • -
"Merle! may exits, team] lajim.s. • •
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EirioyIKITVE EratAtOlviirtrALIZernteitcicarAtic.. • -
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PA631"4. rfsiptre e to. 6tvironn. !gad professionals seAing innotiative alteriative technologies" . :
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FIRST AlD; • . " •' • • •• •- : -. ' . • :±1•.•.-:; -`• •• • . --;•. ••-':.•• n''-'t ;•:••••:!. - ••:. c• ,•••
• . .:- .... ' ' • .• ••-• 1.1 '::, ' - --,-; t • ; • ;. ' ,..?•••'.•;•:/. 1: t -, ' ..'.':•-.":;,..•,,,. ; • A :.''..:4 • s . , -4; : v
.
• • l'' ` ' •:, .'-'-'_.`.y-' "--„.; •• ''• ' ..;-:: ,',.: •-• ..',"!.-_,...--4.•••% • .i...,..,-1j.'.••••-:••••.;:: •:;,-,:.!,SVM:.Z •::1..',i:.:21-„;;:: i.,,i11::.-.:_::. •tv.:4:,. -.Z!
• ' '' • ' uNcEsTioNinii not ikause'vOrprtinff:Kes-Aicted persona/wail:aid attest Get nniclicitlidAngelf.'•:- - •Ns
• ; . . ..7 - ..... ...,_ . .. ,.,. . .. ,.... ....,„ . ,:. -!...7!......0.!•_•••1,1,•...12 -1.4•:„.• • • -,,...•,..1.s...7.1„.,y4.1.e -..4•4: -...t:•..4,•....„. ,......,4.77,..."-raS•• !
- -:. • SKIN 6ONT'Ag:tris2. i area c1eoriteotthorau3biywItkioi.,p.iridicrif;i:514orkieicWhiiiilieikeiatiip:: ' ;.--•'
. • - . :Get Me Weal PIP ri4oh If roleagon'Paraists:FoKF•Oriticipiith moNie p aSilti pt. cloii.o.tieflioll.,.'clfotiinInattid;b7.e.
. . . chsthlog.Flush•sicirs fairEediati.iy-vdtra rare ain a iiiitfof 41i1 wafer. If pitiailik-011bkoare kreillioPIrk - - -1 •'--..:
, : . .•., water'patic tilrO/ce. Zilte.rm al barna 1'cinftellmrsedkjp:a yelp it. •.:V..,.,,,,-Z--r,
.. . : ,.: ! '... • „-__,•.:5;'4 :7.•-•..Sitt•k;r4, ..'':•4J; V,..1-24:'•:' ,;• 616.V.125:4-',VI.A.•••'.4:tf...."'-•_?71•111°.;igli..ft7~-36.117
.E.Iii.ecirayieLov:0)9sh ummiglataly quo ogle en.towits otwaFrfolgiajeaotnft.en.r.1-..igtifeEyesIlds 7.„,. .s.°•1',",,
. , • . • , . :shaidd.be tiejd all/Lay:fit ill ;Iyeligitiojnierttfoit -filIosing:FiGalsoideid otbantipAKIAcilonvpasistselfw
[l irAtiiighilki.irei.atieit az 7Tot i":
„...•..•: . ' 7,-:.'; •,•.:3 ' Al , .:Vs.''E.',...: .*':si1t1 ' •.•::l,ia-..'f' ':at-YLv.i :'':.s.".r:-...:?.%•1f.r
exp
anahiti**droliKezknifty0atnidOR,:g t4•i),v..i1...0.,,-.gI3.s;11.d,4ia1,c4.k,.fItwiatdejohsei.lfalast.eit.ru„...l.e...;.p:ini-ikt;r.r-.-..gi
t- -4'.!..-,r..-4.
arrna*GOpileftergon
1l•, i-•
f• ..11 L...
..... ... ... -:. PEI.ZianFlUir-POYE011ai it4FbRadinlog; x....%, ,e• .....•
'got..
. ... . •„eolly,,,,s.'??
• •--.-- ...:. ,l• i • 1':•'... ••!'.. :.3• ; .::.....,'...• .g.:,•-:,•-- • • :- • .7.4••474••it
. •• ,...'• kYE,PROTEGTIDgellikarszifetirgiessoO cii• iiiiticaialigteiicf pricve nt eye corica it. 6.6 pia wear 4intact:1`,y-x---4:r-rRvE -•
- • ' • tenses wherivirdiking wlth thla substance. HiveeyiwaShIrsii fecnrea
dilyoyaliable Where eye ." c.;..1,
. . •
• • :•oontactca4 occuri..--4.;:v • . .. ' .. ••. • '..- .‘•••,..i.••••?.....f4.. • '`", E • • ••:. -.••;.• f ;, • •• rit...r...4-7 -fq.....;,,;•.,:.,: :4 .4'21,1:
1 - , • : . • • . . • -: ,- . ••, ,- • . -. • -• • • '••• J'T • :: -•:..-..- %.1. :.‘ '..?:. •-•'•i. r • -.• • •• ,•'• ••• •• • • - 4 .4. • ,ir•
. . , • •
SKIN PlIGKEST.ION: Weir Impeodousglo.veianilidoieelve.cfctidng.to p.revankAin iontict:sumiested .,t4.:-.,)
.-- • •%, ..-, ,• ....v...1;4-.4 ,.
•• • airati.ctiire.miterlais oaf butyl rpbber. -s • • •-..1 - ,-• -.)-1• c- X.:•'".. • . -..- .-"....-'• • •_;--'• s-•$:::-4,, ...,..-a•i-Pf'•:••9i....c..il•-•
. „ . . . .-. , . , - • _ • ... i.-. . - . . -. „ . ..:.• • - •.• .., . .. : - - .f... .. . . : .7.. ". ....:"?; :•., • : ... • .". .r-:--.•••:•,:••,,..silVtkik-..•
' • Ri•SPIFOITORYPROTEarlair None normally needed. 1.IFe NIOSH or MONA appioved equipment when , ? . • :1--,-1-..7 - -7-1-'
Fe; -...k.: • :
' • ., alrb Dine expcualte limIti aii exceede d. NI 0314/MSHA apprc;ved breathing egurpmbnt mustbetntal!able; •••'',•:.•.*.i•I'..,••••,::;.,414;
•• • for nori•routintimderrie*noy Use. - - •• • : ••• ' - • - : ': • ' - • • •• — : .' X. • • •'• ' • • •-,'• -.•• ''c'-'0-%:'
• , . .. . . .
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• " PHYSICAL; PI2O13612TIEGe -- • •• ' • '
. ... . .- • •• .,. . . ...: .... . : ., - ••.• -,`. ''44:•.;
4 ... '. .
. . • • • • -• . : 4 ..- :.: ' . : -:-• - • - . - - • : "1 . • • ". • • '':' -1-4.'
.. Deceit:pose i • " * '. . . .. • • ' • .' : . ' ...., : ..7 • • ..r.- '.:•r7.: * •
Boinig POW . . - .'- • . ':• :
. . s
• SPECIFIC GRAVITY:• . • • • .
. •
: , • MELTING POINT: '• . 1 33411 C (2ri4ii2 F))11.14ideCompotes'at 1550 i31.1 ki •• • •' '' • • . : :.:• •
'. • • %1101ATII.E; ‘ _ . NA • •
VAPOR PRESSURE: ' • • ' . NA. . • • -.
EVAPCIRATIO.N.GATEIWATE) WA . • • . • , - 1 .. - . -. ' ... -:
VAPOR IDENGITY(AIRLM • • NA • • : • • • ,... .... . . i•e
VIsst)Srn: ' . • • •... . ... • •
:.,. • .
' : • • INNSVAITVE ENVIIKONMENTAI,TECliiritiLddie. SDid •
., ': • '•••• . , . ... :. .. ,_ , ; .. -.
• . •.•
• PAG7R g" 71 resoitra for '611;irogriteitai prifessione4 'seeking ianoordt.virtiternative technoroyea .. • , .„ f•
. - .. • • • ' .• . - ! . • • , - .!: • ••• '•;;:.1'..*:
'• •
• ' • • • • . : • • • • - • - :kr
,.....1 ili i
....: ii r .,
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t 888421;3.28r : ;•.- • •••• ' :... : : * ... : -..-,:-.4.....;::!::::.•:": ..f." ••••'.."..i.. -t•':Z• l' •::. .1.1..2.r." - -• .-* ...i.A"
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. • . ., •L • -.. ...;•-.. ,-,.:',.:-.. • ... i: • •: -.:. ..7 .• ..• ...,..: , ,• ....;?"2:',Xd
• .• . . • . • _ ___
INGESTION: SIightlitOxid.,Dorricstic animal Grail-P-600f Urea it sit nig/kg:Mute orarLDSO of : _ .. •,: ,.., ..,.! z.Vd--:!..
- : • .' Diammmcinlarn PhOsphate 4 >t(10-6 nigtka Al male rats:May saute gaslraintesruiardistOrtploca.- ..• .: • • . • --1.3:•.;
Symptoms may UMW* Irgration., riall.Fer, vpialthw end diarrhea.:- • : • ' • • ' ... ,..•'-' .. ; " . • ' ... :: .6:P
• • •
_ • ' SKIN; Slightly irrliatIng. Sepeated Or milonsid slan'conhict may cause reMenlog, Itching and • • •... • . ' • , . ii,-....,„
• - InSamation: Contiet with heated material nudfsuse, theirnal Mires. • 7,7.. :. ': ' • ' • - .. ..
. . . .„,, .. • • - ..::- :. ..• •••:: • ' - •• , • •• ' -:.:J• :••• ''• • . ' " 'c'".'" •
. • . i1Jihtli1rritah4- Ctntiot,Willi•htalinatp;11gfay opus; the-.;a16uratt...::':` - •-' - ', .• . • -. .• • :': • • •;•-t-7: ;
J.. . . • • •••••-: - :••!. ., ...• , -••• •.--, . .... -- . • ••••.% .. ..i. 7, ' .--' . • '....':,•.-:.-
: • ▪ IN*920910N:tyley-oeutso respkately tract laltatori. •:•;.:.,„•:. ...it .,,, . ._ „ .. ... • • : • ,.. . ;,. , . ....z. „ . • . •:„:,....,. • .• ...:..
'' ' ' • • • . • • ..• • :z - - ••.'•••••• •:- .._ .:•„••••w-1.:•-f, • : • ..ar• it•-:%.:1•,,,•:( .• . -. ‘ :fl.1.---.%%.• r.i. - •-•! • *T• 4 .: •
:14
- r SPECIM. TOVC EFFECTS : Apthmaticb isposed to deist may tiaye diiiicilh) Iribeadthlig". Urei 1.s.a • -- • ,- •-•: .
• .• . .
. .. ' • naturally occutirpsrety.mkal in the body. Kra arindpr..#1dtic,:t kir Ordain MetabollsBipnd la excrit4fre . = •''•: •
' • . • -- • - thaorinp."' ••• • ••• ' • • ' •• , •• ,•• ; ' ' -..-::••1-,•••• • • : - ' '. • '..-. - •::. :• - •-
.
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• ‘" . " • .• ; • • •• • •• • ••••': 1.7
• • •

• • %50.LUBILTIY IN.WATiBT, CL01.00 GM 00C - ,Lien :110. • • • •• • • • • • • • f•O.al.
.• • DAP .41. .. • •• • • • . . •
• ' '44-'4 •
" • • - n ••WP •
• , • • •
' . • •OCTANOLOY/AfER PARTiTION 4.,uEFFICIENT: • • NB
FOUR PDINT: • •• • NA • -' . .
' • - di,FFF:ABANCEIOD,OR:whitigralluiel wiAtittle to no odoi; Afpropnii.odpr vitt? delvalop. : . • .
.
... %.•, , .. ., •• -;::;,; -.......t.i:.
••-: . t.. . •• ....,:,:i. '..1113.0,icinkttinitlrig.: ,:i : 1 ;?...;,1i : ,*:::?••• .'.. : ....;-:: •':•"_.. : 7 7.111... ''. -_.. ::.•. . • ,i..7-7.V4t •
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' . fif4E AMDEKP_LbSION BATA: • ••• •" ': • , :.'::-,- . '• - .4 '. - • : ••' , • --. -: L -..-'--:,
• . • - ..i • ".... -...e • .......• .,, .• •-.... • . 7: -; - t •-• • : -. •••• :::. %, • "?.‘: ••!..' • ,-. - - --. • :.,......;:f-.1.P.t.:
, . • FLASH FONT.: 7.... . NA :. i • .:-. ...' . . - . : s.• .,. .. .. .: • . „.. -f :„... - ,,- -..--• ; ...: z•-• -.• •. • • • • , •.-,J.g.-'1:
• ' AUTOIONITION TEMBRAIllita ' •.':NA . ' - .7.. --. : -• • ' • ••': : . ".‘: j:•:`,.;',.:...• ... .-..... ....•-. :..--•••••'.4,:'*-z.7..4
. . . . . . .. .
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!LAWMAN-T(13MM INAII3 rh BY VOLUM WWI: -,/,-.3NA .•• • . ••=..-tf. • '-"--21: •7, '•;•i;:./.... ...; •••.',411.`:.' "•'
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MATERIAL SAFETY DATA SHEET
Last Revised: March 1, 2001
*****************************+***********************************
Section 1- Material Identification
********i.**,****************:*****:******************************
Supplier: Regenesis Bioremediatian Products
r 1011 Calle Sombra
San Clemente, CA 92673
Telephone: [phone]
Facsimile: [phone]
Chemical Name: Propanoic acid, 24242-(2-hydroxy-l-oxopropoxy)-1-oxopropoxy)
-1-oxopropoxy]-1,2,3-propanetryl ester
Chemical Family: Organic Chemical
Trade Name: Glycerol tripoIylactate
Product Name: Hydrogen Release Compound` (HRC®)
* ****************************************************************
Section 2 - Hazardous Ingredients
* ****************************************************************
CAS #: 201167-72-8
One should anticipate the potential for eye irritation and skin irritation with large
scale exposure or in sensitive individuals. •
*****************************************************************
Section 3 - Physical Data
*****************************************************************
Melting Point: NA
Boiling Point: ND
Flash Point ND
Density. 1.347
Solubility: Acetone and DMSO
Appearance: Amber semi -solid
Odor. Not detectable
Vapor Pressure: None

r
di****************************************************************
Section 4 - Fire and Explosion Hazard Data •
*****************************************************************
Extinguishing Media: Carbon Dioxide, Dry Chemical Powder or Appropriate Foam.
Water may be used to keep exposed containers cool.
For large quantities involved in a fire, one should wear full protective clothing and a
NIOSH approved self contained breathing apparatus with full face piece operated in
the pressure demand or positive pressure mode as for a situation where lack of
oxygen and excess heat are present.
*****************************************************************
Section 5 Toxicological Information .
44**************************************************************
Acute Effects: May be harmful by inhalation, ingestion, or skin absorption.
May cause irritation. To the best of our knowledge, the chemical, physical; and
toxicological properties of the glycerol tripolylactate have not been investigated.
Listed below are the toxicological inforination for glycerol and lactic acid.
RTECS#: MA8050000
Glycerol
Irritation data: SKN RBT 500 MG/24H MLD 85ICAE-,207,1986 •
EYE-RBT 126 MG' MLD BIOFX* 9-4/1970
BYE-RBT 500 MG/24H MLD 85JCAE-,207,1986
Toxicity data: ORL-MUS LD50:4090 MG/KG FRZKAP (6),56,1977
SCU-RBT LD50:100 MGIKG NIIRDN 6,215,1982
ORL-RAT LD50:12600 MGIKG FEPRA7 4,142,1945
JHL-RAT LC50: >570 MG/M3/1H BIOFX* 9-4/1970
]PR -RAT LDSO: 4420 MG/KG RCOCB8 56,125,1987
IVN-RAT LD50:5566 MG/KG ARZNAD 26,1581,1976
IPR MUS LD50: 8700 MG/KG ARZNAD 26,1579,1978
SCU-MUS LD50:91 MGIKG NIIRDN 6,215,1982
' IVN-MUS LD50: 4250 MG/KG JAPMA8 39,583,1950
ORL-RBT LD50: 27 GM/KG DMDJAP 31,276,1959
SKN-RBT LD50:>10GM/KG BIOFX* 9-4/1970
WN RBT LD50: 53 GM/KG NI RDN 6,215,1982
ORL-GPG LD50: 7750 MG/KG JIHTAB 23,259,1941
Target Organ data: Behavioral (headache), gastrointestinal (nausea or vomiting),
Paternal effects (spermatogenesis, testes, epididymis, sperm duct), effects of fertility
(male fertility index, post -implantation mortality).
RTECS#: OD2800000
Lactic acid
Irritation data: SKN RBT 5MG/24H SEV S5JCAE -,656,86
EYE-RBT 750 UG SEV AJOPAA 29,1363,46
Toxicity data: ORL-RAT LD50:3543 MG/KG FMCHA2-,C252,91
SKN-RBT LD50:>2 GM/KG FMCHA2-,C252,91

ORL-MUS LD50: 4875 MGIKG FAONAU 40,144,67
ORL-GPG LD50: 1810 MGIKG JIHTAB 23,259,41
ORL-QAL LD50: >2250 MG/KG FMCHA2-,C252,91
Only selected registry of toxic effects of chemical substances (RTECS) data is
presented here. See actual entry in RTECS for complete information on lactic acid
and glycerol.
* ****************************************************************
Section 6 - Health Hazard Data
* ****************************************************************
Handling: Avoid continued contact with skin.
Avoid contact with eyes.
In any case of any exposure which elicits a response, a physician should be consulted
immediately.
First Aid Procedures:
Inhalation: Remove to fresh air. If not breathing give artificial respiration. In case of
labored breathing give oxygen. Ca11 a physician.
Ingestion: No effects expected. Do not give anything to an unconscious person. Call
a physician immediately.
Skin Contact Flush with plenty of water. Contaminated clothing may be washed or
dry cleaned normally
Eye contact Wash eyes with plenty of water for at least 15 minutes lifting both upper
and lower lids. Ca11 a physician.
*****************************************************************
Section 7 - Reactivity Data
*****************************************************************
Conditions to Avoid: Strong oxidizing agents, bases and acids
Hazardous Polymerization: None known
Further Information: Hydrolyses in water to form Lactic Acid and Glycerol.
*****************************************************************
Section 8 - Spill, Leak or Accident Procedures
* ****************************************************************
After Spillage or Leakage: Neutralization is not required. This combustible material
• may burned in a chemical incinerator equipped with an afterburner and scrubber.
Disposal: Laws and regulations for disposal vary widely by locality. Observe all
applicable regulations and laws. This material, maybe disposed of in solid waste.
Material is readily degradable and hydrolyses in several hours.
No requirement for a reportable quantity (CERCLA) of a spill is known.
*****************************************************************
Section 9 - Special Protection or Handling
*****************************************************************
lined plastic,glass,al
Should be stored in plastic steel, uminum, stainless steel, or
reinforced fiberglass containers.

Protective Gloves: Vinyl or Rubber
Eyes: Splash Goggles or Full Face Shield
Area should have approved means of washing
eyes.
Ventilation: General exhaust.
Storage: Store in cool, dry, ventilated area.
Protect from imcompatible materials.
*****************************************************************
Section 10 - Other Information
*****************************************************************
This material will degrade in the environment by hydrolysis to lactic acid and
glyceroL
Materials containing reactive chemicals should be used only by personnel with
appropriate chemical training.
The information contained in this document is the best available to the supplier as of
the time of writing. Some possible hazards have been determined by analogy to
similar classes of material. No separate tests have been performed on the toxicity of
this material. The items in this document are subject to change and clarification as
more information becomes available.

I
U
14
W
en
1

ADVENTUS .
Criminate(
MAC. aunt•b*TA ems.•,...
L PRODUCTIDRNI1FICATION:
PRODUCT :
Safet Data
mii.
EILC-• �• .., •. Page: I of3.
EHC'
Biowrmediatipn product for the remediation of
contaminated coil and groundwater only. Not foruse
In potable drinking watts
MANUFACTURER: EMERGENCY PHONE:
Advenius Americas Inc. Office Hours: 815-235-3503
2871 W. Forest Rd, Shine 2 After Hours: 630-500-1175
Freeport IL
61032
TRANSPORTATION OF DANGEROUS GOOD CLASSIFICATION:
Not Regulated
WBMVMIS CLASSIFICATION:
Not Regulated
CONTAINMENT HAZARD: •
Any vessel that contains wet EHC or EEC and water most be vented due to potential pressure build up
from fermentation gamSts.
2. LNGREDIBNTS
CHEMICAL NAME: .CAS#
Organic Amendment N!D
Iron 7439-89-6
3. PHYSICAL DATA
Fhyaical state, —
Odour Odour threshold__
Density
pH
Soiubilityin water_,
Caeff. of water/oil.
Appearance & odour
„Solid
_N/A
0.75 Kg/L
. NUA
Insoluble
NIA
Odomriess. Tan/Brown Flakes
4. FIREAND EXPLOSION HAZARD DATA
FLASH POINT (Deg. C PMCC): N/A
FLAMMABLE LQt1ITS iN A!R % BY VOLUME:
Al 1O IGNITION TEMP (Deg. C):
TLV (mg/m3) LD low (tug/Kg) io h Product
NIB NIH 52 - 82
5 (as iron oxide fume) ME 18 - 48
Melting point__ .. .... .1371-1480°F
Boiling point, „ 3000°C
Vapout pressure @ 1787°C
Vapour density (air=1) WA
Evaporation rate N/A
LOWER
N!A
NIA
UPPER
N/A

adds.
6 ADVENTUS
Safety Data
EXi NGEASEIING MEDIA: Dry chemicals Or sand or uninsaaI type foam.
SPECP4.1'ROCIDDRES:
Firefighters shesild wear SCEA and protective clothing
UNUSUAL FIRE AND EXPLOSION HAZARDS;
Dust can incseni fire and explosion hazards when eiposcd to fire. chemical reaction, or contact with
powerful oxidizers.
5 REAGliVITYDATA
gran iTY (NORMAL COND.)5
Stable: X Uitstablc'
CONDITIONS TO AVOID:
INCOMPATIBILITY (MnferfalstoAvoid):
HAZARDOUS b�OOMPOSItION PRODUCTS;
Cogtact yid: powerful oxidvets rude as
strong adds.
Powful oxidizers such as strong
Hydrogen. Carbon monoxide, Carbon
ell xidc.
. 6. TOXICOLOGICAL PROPRRITES
ROUTE. OP /NYRY:
fabalpii0a
Ingestion (not likely)
HEALTH HAZARDS:.
Aorta ovudcposuremayman eye, nose, rnouth end rain irritation.
Chrcinngen!city:' • No Information Mailable
Signs and Symptoms ofEacposnrc No Inform:dog Available
Medical Coi d'itions Generally
Aggratated by Hrposau:
No Information Available
7. PREVENTIVE
PERSONAL PROTECTIVE EQ :
Lye Protedon: X Gloves: X Clotbing:
RESPIRATORY PROTECTION:

(6) ADVEWTUS
Safet Data
'gam
• .1.7. •
4agatiriveAktrilifs; • -;_zYdri • - • - i.ard . •
use dust =skin smite conclitions.
Use good hassekvegdng prdetlirs fa keep dust to a minimum.
VENITIATION REQUEEtkENTS:
Not normally (dial/tel.
SPILL.AND LE& PROCEDURES;
Sweep up and return to amain=
WASTEIHSPOSAI4
taiiitatiland511. Follow Federal, State and Local guidelines_
r1414DIJINO PROCLOURES:
Wear safety glasses for normal 11SC. Avoid generating
er;.-she 451, Wear tinsl mthjp imrdectincEtiorm
STORAGE EEO/M.)41MM
Do not stove near powerful eaddiners such as str ong acids.
Keep dry.
Any vessel that contains wet E:HC or ESC and water must ba waftd doe to potenda1 pressure build up
fiarn fermattation gasses.
SPECIAL HANDLING INkiithiATION:
Treat as a nuisance dust
8. MIST MEASURES
INHALATION: Romento to fresh air. Seek medical attention,
INGESTIoN: Seek medical attention.
SKIN CONTACT; Brush ott excess. Wash with soap anti water.
EYE CONTACT: Flush with running same. Seek medical attention.
9, OTHER INFORMATION
None
PREPARATICiNEVORMATION
Prepared By: AdventasBcruediation Teelmologiea DatePtept/Rev.: 10/28/O8
1345 Fewster Utica Print Date 10/28/08
Nssfstaugo, Oaterio Phottm 905-273-5374
L4W 2A5 Fax:' 903-273-4357 .
Definitions:
N/D - No Data
N/A- Not Applicable N/E- Not Fstablishbrt
EFIC° is a registered bite ma* OfM as1ntcflcctud Property km.

TECHNOLGY REVIEW
awractitaa ray...ra.om
—rvneroisfle Application of Comnatible Chlorinated Solvent Treatments
Innovative Environmental Technologies, Inc (IEI) has successfully applied a synergistic program utlzing a
combination of advaneed delivery systems and unique chemistries for the dechlorination of a variety of
chlorinated solvents In groundwater and soils.
The options available for a cost-effective and reliable technology to treat chlorinated hydrocarbon contaminants such es
PCE, TCE. DCE, and CT in groundwater have in recent years moved away from traditional pump -and -treat processes,
especially in cases where:
• NAPI,, micro -emulsions or high concentration adsorbed materials era present leading to high dissolved phase
concentrations.
• Access to groundwater is restrictedby surface structures or uses.
• Local restrictions forbid the implementation of other available technologies such as air sparging ornatural
attenuation.
• Pump and Treat technologies have been applied, but have reached asymptotic removal rates.
• Contamination is extensive and concentrations arc too high for risk based closure but otherwise relatively low
(typically I00-500 ppb).
• The migration of dissolved Chlorinated Aliphatic Commands (CAlls) across property boundaries or into
adjacent surface water present a long term iemediation requirement.
• The vertical migration of free phase CAHs (DNAPL) into underlying drinking water aquifers is a concern.
Injected, colloidal reactive iron is a promising new technology, which maybe applied, in a synergistic approach with
compatible technologies. There are two primary reactions with CAHs that take place which will consume the iron and
require stoichiometric consideration:
• the anaerobic iron corrosion reaction in which water is disassociated to form hydrogen gas; and
• the direct adsorption of a chlorinated hydrocarbon onto the surface of the iron, followed by reductive
dehalogenation.
Field experience and data on elemental iron_systems demonstrates that there are five mechanisms are at work during the
reductive process:
• First, the Fe° acts es a reductant by supplying electrons directly from the metal surface to an adsorbed
halogenated compound.
• Second, hydrogen gas is generated by the anaerobic corrosion of the metallic iron by water.
• Thin], metallic iron may act as a catalyst for the reaction of hydrogen with the halogenated hydrocarbon
using the hydrogen produced on the surface of the iron metal as the result of anaerobic corrosion with water.
Theoretically, these reactions are not kinetically effective without a catalyst thus, it is thought that impurities
in the iron or surface defects act es that catalyst.
• Fourth, solubilized ferrous iron can also act as a reductant, albeit at a rate at Ieast an order of magnitude
slower.
• Filth, ferrous iron may act as a precipitant oftoxic sulfides.
A side benefit of the incorporation of the ZVI into a coordinated program is the generation of hydrogen gas. However,
this is a minimal benefit in the first injection at a site due to poor utilization rates of the hydrogen.
Hydrogen gas can is be used for reductive dehalogenation by the following reaction:
H2+X-CI =X-H+H++C1

Other issues effecting iron loading is the stoichiometry of the reactions with the CAHs and oxygen dissolved Mike
groundwater. When considering iron loading the minimization of dissolved oxygen will reduce the effect of oxygen on
the surface of the colloidal iron. It is for this reason that IET utilizes oxygen scavengers as part of the treatment
program. It must be remembered that each mole of oxygen dissolved in the groundwater will consume two moles of
metallic iron. An additional important reaction is the reaction of the ferrous iron with oxygen to produce ferric iron
hydroxides.
Thins, colloidal iron is a suitable teclmology, which maybe applied to address NAPL and dissolved phase. chlorinated
compounds in an anaerobic environment. This anaerobic environment may also be utilized to stimulate and enhance
microbial dechlorination processes.
The issue ofc-DCE "stall" is always a question when applying biologically based rlect,torination programs. To
ra» nimC7e' the potential for stall, the following elements are incorporated in the patented IET program:
- Vitamin B12 Vitamin B12 lowers the activation energy required for the electron transfer of the •
terminal electron to c-D1 E. Without the B12, sulfate is a preferential acceptor of the
terminal electron acceptor.
- Vitamin B2 Vitamin B2 allows for a more efficient utilization of the hydrogen in the anaerobe,
increasing the overall kinetics.
- Feurons Iron Production The corrosion of the iron particles to ferrous iron and hydroxides allows for better pH
• control in an reaction which produces free chloride ions, and thus pH depression.
The ferrous and ferric species Either reduce the free sulfates and sulfides in the
environment, allowing for thorough decholorination.
Indigenous anaerobic microbes (such as aeetogens) metabolize the lactic acid producing dissolved hydrogen. The
resulting hydrogen is then used by other subsurface microbes (reductive debalogenators) to strip the solvent molecules
of their chlorine atoms and allow for father biological degradation. Sources of this hydrogen may be butyrate,
acetate, esters or other organics.
Studies have shown that hydrogen produced in -situ can support the growth ofinethanogens, homoacetogens, and
certain sulfate reducers and denittifrers. In addition, many hydrogen -utilizing microorganisms are lmown mediate
reductive dechlorination reactions, For example, some methanogens and acetogens have been shown to mediate
reductive dechtorination of TCE end PCE. These reactions are believed to be cometabolic (that is, the reactions occur
fortuitously and do not yield energy for the organisms). In contrast to the cometabolic dechlorinatingmicrobes, a
handful ofbacteria have been isolated in the past sevenyears which can couple reductive dechlorination of PCE and
ME for energy and growth (Le., PCE andTCE serve as tenninal electron acceptors - just lice we breathe oxygen, they
breathe chlorinated solvents!). Most of these respiratory debalogenators can use hydrogen as an electron donor for
dechlorination, and some can utilize only hydrogen.
The application of these two synergist technologies: colloidal iron and microbial seductive dechlorination process may
be further enhanced through microbial amendments and reducing agents. Critical to the success of the remedial
technologies has been the successful delivery of the various materials to the targetedgroundwater and soils. To date
IET has successfully applied these synergistic technologies to a variety of sites for astounding results.
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NIACET CORPORATION
400 47th St.
Niagara Falls, NY 14304
Fax [phone]
Ph (716) 2851474
MSDS
NIACET
CALCIUM PROPIONATE
Issued: January 2006
EMERGENCY PHONE NUMBER: [phone], [phone]
MATERIAL SAFETY DATA SHEET
CALCIUM PROPIONATE
Page 1 of 2
SECTION 1- PRODUCT IDENTIFICATION
Product Name:
Chemical Synonyms:
Chemical Family:
Chemical Formula:
NIACET Calcium Propionate, FCC
Cal Prop, CP
organic acid, calcium salt
(C3H502)2Ca
SECTION II , INGREDIENTS
Calcium Propionate (dry basis)
Water
SECTION 1I1- PHYSICAL DATA
Molecular Weight:
pH of 10% Aq Soln:
Melting Point
Vapor Pressure:
Solubility in Water:
186.22
7.5 to 10.5
400'C (decomposes)
not applicable
28.5% in water at 20'C
% bir wt.
99 min
5max
Appearance:
Odor:
Boiling Point
Bulk Density:
Reactivity In Water:
CAS #
4075-81-4
7732-18-5
white powder, granules, or crystals
odorless
not applicable
approx. 45 IbsJcu. ft.
does not react
SECTION IV - FIRE & EXPLOSION HAZARD
Flash Point None by Tag Closed Cup
Flammable Limits: - Not Determined Auto -Ignition Temperature: Not Applicable
Unusual Hazards: ' Avoid dispersion of dust to minimize possible explosion hazard.
Extinguishing Media: Appropriate media for surrounding fire.
SECTION V - REACTIVITY DATA
Hazardous Decomposition Products: Carbon monoxide ,
Hazardous Polymerization: Will not occur.
Incompatibility: Strong oxidizing agents
SECTION VI -TOXICITY DATA
Calcium Propionate is a non -toxic food chemical Generally Recognized As Safe by the FDA
Occupational Exposure: No exposure Emits have been set by OSHA, NIOSH or ACGIH.
Carcinogen: IARC: NO, NTP: NO, OSHA: NO

NIAET CORPORATION MSDS
400 47th St. NIACET
Niagara Falls, NY 14304 CALCTUM'PROPIONATE
Fax [phone]
Ph (716) 2851474 Issued: January 2006
EMERGENCY PHONE NUMBER: [phone], [phone]
Page 2 of 2
SECTION VII - HEALTH HAZARD INFORMATION
Primary Routes of Exposure:
Ingestion: If swallowed, wash mouth out with water.
Eye Contact Can cause Intiation. Rush with water for at least 15 minutes, hold eyelids open.
Get medical attention.
Skin Contact: May cause irritation of the skin. Wash area with soap and water.
Get medical attention ii irritation persists.
Inhalation: If irritation develops, remove to fresh air.
Effect of Overexposure:
Dust, in high concentration, may cause Irritation of eyes, nose and throat.
Medical Conditions Aggravated by Exposure:
None identified. Handle with reasonable care.
SECTION VIII - EMPLOYEE PROTECTION
Protective Clothing: Appropriate work apparel. Plastic or rubber gloves optional.
Eye Protection: Safety glasses should always be worn when working with chemicals.
Respiratory Protection: Material should be handled in a manner that does not produce airborne particles.
If dust Is a problem a dust mask or respirator is recommended.
SECTION IX - SPILL AND DISPOSAL PROCEDURES
Action to be taken for Spills:
Wear suitable protective clothing including a respirator or dust mask. Sweep up spillage and collect for
disposal. Wash down area with large quantities of water.
Disposal Methods:
Material is biodegradable. Dispose of In accordance with applicable Federal, state and local regulations.
SECTION X - OTHER REGULATORY CONTROLS
Calcium Propionate TSCA Inventory: YES (ail Ingredients)
OSHA Hazard: NO
Regulated under RECRA: NO
Regulated under CERCLA: NO
Regulated under SARA Title III: NO
'Ma Information herein is given In good faith and believed to be accurate and has been compiled from
sources believed to be reliable. Buyer assumes all risk of use, storage and handling of this product in
compliance with applicable federal. State, and local laws and regulations.

MSDS
Yeast Extract

AutoLyzed yeast •
Provesta® 027
Product Cade: 50300
PRODUCT SPECIFICATION
Chemical and physical data
Paraineler
Unit
Win.
Max. 'Method
-
Moisture
%
7
100 deg C.o 'cn 24 hauls '. .
Protein in product •
°la .
49 .
AOAC 988.05 ' •
Microbiological standard
Paratiieter- . ..
.
. .Unit..
Specification
Method
Total plate count . .
.
. e[u/g .
<7 500 .,
48 hrsot 30 do F. .
Yeastsaiid motds
' tint
C50 ... '.
3:day"s'at30 deg F .
E: ooti
cfulg ' :
NEG -.
FDA BAM Revision A of Sth•Ed," 1995 Chp.4
Coliforins...
cfii/g
10 :
PDA BAMRevision'A of 8tli.Ed,199E Chp.4
Staiplt aurens
.'atiilig
.. 110 .
FDA BAMReiiision A of 81h Ecl,'.1998 Ciip.l2
Salmbndla..
• .
NEG/375 g
NEG ..
ADAC/BAM Method 2004.03
Typical Nutiitional Information
CAtgrics ....
.3711100g
ct otesteri€it , .. '
<Im iotg{'a•
[stories frora.fat .
'63/100g .
.Ash
8g 100g .
Calories trom Satuiatcd fat . , ... _
.7:2/100g .
Bodkin' . . ...
010gj100g
Protein
52g/100g. .
Potassium _.. . .
... 2 5,0100k -
CarboltOrates- • •
26g1i00g
Vita ruit.A. (UJ)
<44 IU,16fog 4?
<0..5mg/I00g91...
Dietari Fiber. . -
- : 5g/100g
temin-C (ascorbic acid)
Sugar -Total
<1g/1OOgi1l.
.Ciilcitum:_•
.0;o1S loft
'Fat -;=Total . . -
- .-.7g/100g .
.
Iron
..O olOg1100g
Saturated Fatty Acids. '.
o.sgFioOg..
. '
.
Trans fatty Acids',.... - .
0.07g/100s
.
Below Deteetion Limit
lies Ir orhaYaa .a bose3 an [.'Fres0n11,!rar ledV? anrsmsgerien;3 tietnit-er, irnp5es boaddidy or otheradal resporrs>:,,o'iy,art ote ram =Iuen? w; r:aarra to 014m2
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governed tl a rt 5;rtora1 *. n Cord Oki
Europe - Africa - Middle Feist -� Asia kiterica
Ohl€rGribH 10:149.ioi4O.a2930i OW Ake:rice4
VON sbelier Zollstr. 59 Fax: ' 49 (0]4068 293 tie 35 Menlo 5tre t IV
22..041 I- mburg Cma�i: ihfottuhly.de 1441-i n511n, ON 55350
Gorinany w►stv.ohly.cnnt lfnited Statet
Tel: fit 320-$S7-2461.
Fag; tX 320-S57-6617
E-mail? iiifotirnvnsta.tom
Toll Free: 0800 32126 39

.;
APPENDIX 3:
CASE STUDIES

Enhanced BibrerneJiatjon of Tetrachloroethene in
Central Indiana Glacial Till
Rayriroltd.. Vriskd(TO [e-mail]) and
Dennis I'. Caiinair (L1RS, Cincinnati, Ohio)
Randy Jackson (NDCI, Piahle Village; Kansas)
Mike Scalzi (fniiovative Biiviriottinental Technologies, Inc., l?ipersviile, Pennsylvania)
Zeiriitiisky (Hoiiz n•Geohydrology, Lawrence, l(aiisas) '
•
•
ABSTRACT: The goal of this project is teinediatioii of soil and groundwater it ipacteil
by tetiiichlotoethene (PCE) that infiltrated the vados`e and ui5peiinost Saturated zone
below art active dry cleaning facility in central Indiana. PCE ivas released and tt'ahsported
to depths less than five meters via the I,riniary pokotity=of thin sand and silt stringers and
via secondary porosity of fractures in lodgment till. Impact to shallow groundwater
ranged to 24 Milligrams per liter (mg/L). Impact above one.ntg/L extended over an
apprbxintatb area of 150 square rneteia. Significant remediation progress was achieved
Oa the cohetirrent 'application .of complementary abiotic_(niicro-scale zero-valent iron
[ZV]) and biotic '(electron donor -enhanced) reductive delialogenatinn teinediation
techrit iogieS. After' sttbstaiitiating the presence of PCB -degrading bacteria in
gratitidwater, a pateht=petiding, retnediation compound -injection fechiiblogy was applied
to the site in May 2002 aiid in September 2003. Primary remediation compounds
included:ZVI and 1Iydrbgeti Release Compound (HRC" . Falibrablo'conditions Were
engendered' thttitithotit the area of application, With reduction of PCE through
trichldro: tliehe B) to cia-1a2-dichteroetltene (cis-1,2-DCE) in several wells after three
nionttis, and si(T'gitificatit reduction of cis-I,2-DCE to vinyl chloride (VC) after nine •
iiientira: The project is progressing Well, and recent Maid -toting indicates that VC is
deghiding in several areas.
INTRODUCTION
In 1998, the site, a dry bleanitig facility in central Indiana, was etif red intd the
lndiafa Voluntary Reniediation Prdgrat8 (VRP.) after the discovery of PCE itiipact to soil
and groundwater: Under the VRP, innovative reniediation technologies are generally well
reeeir ed; aiid ufficieut flekibiIiti' is pioVided to pilot test promising technologies. In -situ
chemical oxidation (ISCO) ivas attempted by others on a pilot scale in 1998 using low-
pressure -injected hydrogen peroxide, riczWever this effort proved unsuccessful in reducing
PCB impact in the saturated zone. Groundwater -monitoring results indicated that the
implementation of ISCO may haie.caused an increase in PCE at 'several monitoring
locations and a. slight reduction in PCE metabolites (chlorinated volatile organic
eointpot'n4s [CVOCs] produced by the anaerobic biodegradation of PCE) in all but a few
otitlyitig monitoring locations. The consensus regarding these unremarkable results is that
the combination of the ephemeral "life" of hydrogen peroxide and relatively impermeable
glacial till precluded the contact time and distribution necessary for the chemical
oxidation of PCE. Further, induced aerobic conditions may have hampered naturally
oceurring anaerobic metabolic aetivity assdciated with the reductive deltalogenation of
PCE.

in 2000, the site and ieniediat apprba h Were evaluated by the authors. CdihIidetations
for evalua'tion'of potentially applicable techiologics at the site hi -eluded its cairtmetelal
bettirie .geblogie setting (frachiied law peimeabili 'till With thin tilt and sand si'ririge'rs),
relatively high cairteittiation of PCE (58 ing1L), area and depth 6f impaet (appriixintately
150 situate meters through 5 dieters depth); depth to ttppefenOst groiindwtiter
(approfiimatety 3 to 5 feet below gfoand 'surface Hsu, potchtial fo inluerlic and
maintain loiv oxidation-ieddetioti (reliolc) potential in groundWater, and evidence of
anaerobic bacteria thatdegiade I'CE.13Aed oil these coiisideintions, a troll -step approach
Was recoiriuriendad: 1) a ssively reduce source area concentrations of PCB ihrouglf
direct -tented Chemical reactibhs, and 2) reduce'resfdual concentrations of CVOCg
through tIitr enhanteinent Of natilrasly oecditing bfodegiadation 'piocesses. Thus, a
cofnbinatidn of short4erm abidtio arid longertenn infcinbiall}r-enlisiti ed .tecliitologies
Wire seleeted fora pilot=scale, and 1'ollOW-up Bill:sr ale, applieatinn.
REMEDIATIOH METHODS
Diie"et Push Perforated Rod Placement. Recent eijierienee at a siniilai project site in
soiftlierti Indiana indicated that, if rearedialoii comPeurids could bc' defiveted tote e mtinc
peniteable silllsand tenses and ftaetures in the iubsiirface; relatively stable and depressed
redok C'diidition's favored by anaerobic bacteria Could be engendered and reasonably
Maintained Ever a felatfvely large atea where the hydraulic gradient and hydraulic
coitoueiivtty alto relativity loiv Based on this infoiinatieb, d direct -push unit tvas used to
drive a petforafed nil t6'depths ranging froth 10 tb 12 feet bgs to be in close proximity to
one of 'the mote permeable silty or fine sandy layers that were identified during
chalacterirntioh Of the site. These More pefineabiti layers are those believed to be the
preferential pathatsy's'tliidugh'which CVOCs were transported arid nc iiniulafed.
Injection. A sequence"of faskspecifc cbrtipoffrids, including ZVI drtd *ei'e
injected ihrouVi the per7'arated rod using a patent:Pending cainpresied nitioged gas"
delivery system. The mass of injectants tried in the ftiTdt2scale apjslicatIonLvar Used on a
ca1nbinatign of a) the quantityteyuired tc jaijtish p siz to 12,
month supply of organic substrate (as electron dnitor far redteiive dehalogejiation) to the
targeted area, b) four pounds of ZVi per Injection point (tiff gWalidiy), e) previous
experience, and d) field observations of surfacing of injected compounds (indicating that
the assimilative capacity of the subsurface had been reached). Compounds were injected
aE 15 locations in May 2002 (pilot scale) and 19 locations in Septernber22003 (full scale),
spaced on approximately 10-foot centers inside and outside the drycleaning facility
The stepwise. injection process and intended effects areas fellows:
b Cg1npt ssed Nitrogen Gas. Compressed nitrogen gas was used to'anagrobically
propel all,lnjethn(s into the subsurface. Nitrogen gas was first Injected into Hie
subsurface at approximately 175 pounds per square inch until a sinfificanf
pressure drop lye's observed at the injection pressure vessei. This propels is
pet'ened to as pie -injection subsurface pathway development. The intent of ihis
step was to open pathways in the subsurface for the injeclants to follow. These
pathways are similar in course to those more permeable pathways along which

CVOCs are made likely to have Migrated. Liquid acid liquid -entrained injectants
were then 'delivered With pressurized nitrogen gas to tits pathways that were
produced during the pathway development step.
Sodhum $Mate Solution: Sodigm sulfite Sglutjon was used t i scavenge o�rygcn
from tiro subsiirince to a) promote the anaemia° pondittons and lower the redox
poteptial to the range favorable to anagoblc inicroorgani , and b) prevent
dissolved oxygen fromreacting with subsequently injee e , Z171. Nuiricnis
(nitrogen as organic ammonia and ortho•pbosp`hate) were injected with the
sodlittn sulfite solution to enhance the growth of the mirrr_obial ,population. •
troondu*er monicing was also promoted by completing a series of injections in
iodized areas over a relatively short period of time. Approximately 25 to 50
gallons pfsedium sulfite solution were injected at each location prior to injecting
tlhe,ZV1, depending largely on the nbility of the subsurface to receive the solution.
9. Micro.Scale ZVI. Iron particles ranging from 1 3micraa$ iit diameter were
injected in a sodium sulfite solution to rapidly reduce relatively high
enncentrajions of dissolves)'CC to levels more suited to "polishing" by slower,
enhanced natural degradation processes. The corrosion of ZVI by water also
produce; hydrogen.that may be utilized by indigenous bacteria that metabolize
PCE and its metabolites. Between four and 16 pounds of ZVI were injected at
each ineatien, depending on the concentration of CVOCs in nearby wells.
4 HRe'. I3et een ti0 and 60 pounds bf HRG® Were injected at each Iocatioh as a
food source (electron dotter) for anaerobic iriiei-oorganutiis capable of -degrading
residuial levels of PCE ewer a period'oftiroiiths.
Vitamin 9-12 and' Yeast Extract, Several' grates each of PIianpnceutisai-grade
Vitamin B-12 and commercial -grade )east extract were co -injected Oh 1-Il;C at
each injection location because indipation are that the metabolism of certain
strains of bacteria, potentially including anaerobic dehalorespiring strains, are
enhanced in the presence of 13-I2 and yeast extract (13-12 itself being produced by
metabolic processes). •
IVIONITORIIVG METHODS AND BASELINE RESULTS
Methods. Baseline groundwater sampling of all monitoring !orations was condtleted.in
May 2062. The pll, temperature, conductivity, redox potential, and dissolved oxygen
(DO) were measured with a YS1-6820 meter via a flow -through cell by low -flow
sampling techniques specified in tine IDEM Office Memorandum, dated December 1,
1999, "Micro -Purge Sampling of Monitoring Wells.' Groundwater 'samples were
collected for dissolved iron by EPA 6010, volatile organic carbon compounds by EPA
1326013, and chloride by EPA 9056.
Bitsedne Groundwater Sampling Results. Monitoring locations that were sampled
inside Ore dry cleaning facility and adjacent business, contained CVOCs ranging from
Q:3 0 fo at the time the injection program was conducted. Monitoring locations
that were sampled outside the building contained CVOCs ranging from non -detectable
concentrations to 0.500 mg/1.. Of the monitoring locations containing CVOCs, PCE
5,

accounted for betiveen 77 and 100 peticetit; trichloroethene!(T'Clj accounted for between
zero and 4 per2itit; and diS-1,2-dichlaroetheiid (cis:l,-BCE) accounted for between nerd
and 19 'perceitt of the concentration of CVOCs hi each location. Vinyl chloride Was
present in only two ninnitoring locations (E-2 and E,8) at between 2 and 4 percent of the
'concentr ition of CVOCs id those locations. lit" CVOCs were detected in backgt0inid
monitoring, 10i itions MW4I and MW-10 during the baseline groundwater-sainpIin6
event. Field iirstrtimeht measurements taken during ba'selirie groundwater sampling
indicated that redbic potential acid DO were In the rang t favorable for reductive
delialogdi ation' of CVOCs by fndigetiotis bacteria.
RESULTS AND DISCUSSION
PCE add its• daitgbter prbdticis were targeted by the injeelioit program. A series of
reduction reactions is needed tt0 conViraCEto ethefe; therefore, those reactions are the
focus of the 'rehedietion and groundwater monitoring efforts. • The reductive
&halogenation rdaction sequence iS a's follows:
PCE —> TCE cis —1 —dC$ (dominant) or -, VC —;• Ethene
trans -1,2- DCE (subordinate)
2V1 *IS used its the apgressiye,,short-terrn reductiot Id rapidly reduce the mote
chiorinatud cofiipaunds (PCE and TCE). The presence of indigenous (bacteria that
degrade .8s-I,2DCE and VC Was strongly spsJrected because of'the ptese0e and
disttibution.of cis-I,2-ACE and VC; therefore bin=amendments as described herein' were
added to enhance the reduction of these coinpounds to elhene. The combination of
injectants was fortuitous; evidence is mounting that an important kinetic relationship
exists br,veep dissolved iron and anaerobic bacteria. This unlooked for synergy is not the
theme of tins discussion, however it warrants further study.
Ruts Atter One Week. itedox potential was reduced in most gr'otiudwater monitoring
!ordtiosjs one .week after completing the infection pmgtam. Hooite. ;• CVOCs
corfcentrationsdid not vary significantly fiiont baseline monitoring results.
Molts olts After Thn a Months. Quarterly groundwater samptirig conducted in August
2002 indicrted a large shift in the distribution of CVOCs in most monitoring locations as
follows:
• taIoriitorinp locations 1r2, E-8; I-1, I-3� and I6 (wells that were regularly
saMpied) had caitcehtrati6ii of PCE ranging from 10 to 22 MO, before
conducting the injection prog3rni After conducting the injection program, PCE
Concentrations in these Wells dropped below labbiatary tlutiatiftable limits.
Conversely, the conceiittatIou of cis-1,2-1)CE in iitotiitiiritig wells E-1, I-1, and I-
3 inueased tit coriceirtration's ranging from appihxiniately3 to 54 OWL where cis-
1,2.DCE Was previously below laboratory quantifiable•liniits. Time -series charts
for deductive if ehalogeriatl0it occurring in monitoring locations E-2, ES, E-3. and
I-6 from May 2002 through Match 2005 are presented in Figure I.

Monitoring Well E-2
O6
E .
c
m
LO
V a
Monitoring Well E-8
sa 1 1 1�aaaa1111t1
•
Legend
Monitoring Wolf 1-3
Monitoring Well 1-6
—ili-- Tettachiorc ethene --+—cis-1,Z-0lrhtprgefitene
--e-- Trichioroetherte —£ Vinyl Gitoride
. Figure 1, Reductive Deftatogenation of CVOCs in select wells,
• Qf the sainpled weds Containin CV9Cs, PCE accounted for between zero and
100 peicenti TCE accounted fdr tietiveen zero and 10 percent, and cis-1;2-DCE
accounted tot- hehirees zero and 100 percept of the concentration of CVOCs in
each well_ Vinyl chloride was defected inly In monitoring well MW-4 and Was
appi—OXiniately 2g percent of the totat CVOC contribution at this location.
pield insli-uutent nieasuremenis indicated the following
• Redox potential was signiecsntly reduced in every root itored location, including
MW-1, which is hydraulically upgradient of the irijectidn area. Redox potential

leas; on average, aptirootimately —200 mV tower than before conducting the
injection program.
• No significant change in pH was observed.
Subsequent laboratory testing (tar$eled polymerise chain renetion)• indicated the
strong presence 6f ethenogenes bacteria that are reportedly capable of anaerobically
degrading CVOCs to ethene in the presence otan electron donor.
-September 2003 Results. Gcuund*ate4 Monitoring,rbSults front September 2003
indicated that' PCE continued to be degraded to cis;t,2-DC and VC, both.pccuinulating
in the 3t*i ri31 mg(L ranger in several monitoring locations. TO coot eitratioas generally
peal;etibefore September 2003, and began to decrease rapidly thereafter.
The fiat:scale injection program was implemented in September 2003. The design for
the full -scene program evolved from the field observations and front favorable analytical
results of ilie prior -scale injection ptagrant. The foil -scale design included closer spacing
bf injection locations; slightly less sodium sulfite solution, and increased dosages of
HRC® and ZVI where the effects bf the pilot scale injection program were less
pronounced.
Results to Match 2005.. Figure 2 (follovi'iilg.page) it a map bf the site rind adjacent
properties and depicts 'a plan Viet/afire cifaaging distribution of PCE, cis-1,2-DC and
VC from May 2002 to March 2005, Over this 34-month period, a 90 percent reduction in
total CVOCs was observed in groundwater Samples collected from monitoring Locations
II, 1-6,, MW-6 and I-13. Over a 70 percent reduction in "total CVOCs was observed in
Monitoring tosations E-8 and I-8: Monitoring location E-2 Indicated a 1.7 percent
increase in total CVOCs, 39 percent of which was Lis-1,2-DCE •and 57 percent of which
WAS VC. In general, PCB has been reduced to below 200 ugfL in all sampled locations;
metabolites' of PCE have been degraded through cis=1,2-DCE to VC; and VC
ctini eatratiofs increased Arid .then decreased With each injection event, indicating the
relative -success of the enhanced biodegradation component of the injection program.
VC concentrations warrant additional evaluation with respect tb suppleinerital
applications of reinediation compounds. VC 'continues to persist in several Wells,
hoWevei; there is no evidence of VC in any perimeter wells, indicating that VC is being
degraded to ethene within the project area All monitoring wells outside the impacted
area are Strongly aerobic with redox in [he +300mV range, therefore additional research
may include the evaluation clan aerobic "front" at which VC is completely degraded to
ethene. Additional monitoring will be conducted Over the next two years to evaluate
plumestability, VC reduction, and the potential for risk -based closure.
CONCLUSIONS
The goal of this project was met in that significant remediation progress was achieved
via the cdncutrent application of complementary abidtic and biotic reductive
dehalogenation technologies. Favorable conditions were engendered tbrou;hotitthe area
of application, with the substantial reduction of PCE and its metabolites in approi:imately
three years. The project is progressing well, and recent monitoring indicates that VC is
continually degrading in several areas.

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LEGEND:
a, maimMonitoring Loczt Dn .a Tetroehlaroethene (i?CE) ContLjaontratlon,(mgO 'o
TPelVad>eodembPC
MOtrmE r.., eis-j,2-Dicht=ashena(GCE) Concentration (mgdL): APPROXIMATE =AEINFEET
of t 2 oich}orhenaja[ a: sty latldo (VC) ConeentrallorMg/L').
yw •. Pflatso (al.0"oet"t) 10 Net Dalntlad
DRY CLEANERS
INDIANAPOLIS, IND1 w
76'y ) UInyI0CI>gmgil)anIcie VC)Plumo 'to• Not Sampled _
( t.
(XI' Dry CleaningM9eh(ne
_
FIGURE 2
CYOCDISTRIBUTION MAP'
REDUCTNE DEHALOGENATION
•
SEQUENCE
i' I

ACKNOWLEDGEMENTS
Ail site investigation, remedfadon, acid monitoring work was parstled uttdeir the
direction ofNatiatnal Dry Cleaners, Inc:. The unique application o ZVI, HRC°, and other
reiriediaXion compounds described herein was pioneered by innovative Environmental
Techtioldgies, Inc., which provided all supplies, proprietary tooting, and many long hours
of deIicattd effort.

Imo; Emirmaltataradmalogles.loc.
Introduction
ITT performed two injection events at a site in eastern Pennsylvania. The applied
technology for the site integrated two compatible and synergistic approaches. One
approach utilized zerovalent iron . (ZVI) and the second relied on biological
transformations of the targeted compounds via reductive dechlorination. These
technologies were chosen based on a. review of the site's pre -injection conditions,
including geochemical and biological parameters. The naturally reducing conditions and
the production of daughter products (1,2-dichloroethene and vinyl chloride) indicated that
the best -suited applied technology would need to occur under anaerobic conditions. The
mechanisms employed by JET in the injection process utilized compressed gas followed
by the remedial liquid introduction.
Reductive Dechlorination: Briefly, for the biological reduction of targeted
compounds to occur a constant low level of hydrogen must be present. Further,
negative ORPs and near neutral pHs are necessary for maintained
dechlorination to occur. When oxygen is present aerobic processes may
consume the poly -lactate ester, propionate and yeast extract rather than the
anaerobic processes desired:
Zero-Valent Iron: The application of ZVI relies on four mechanisms:
• First, the Fo° acts as a reductant by supplying electrons directly from the metal
surface to an adsorbed halogenated compound.
• Second, hydrogen gas is generated by the anaerobic corrosion of the metallic iron
by water.
• Third, metallic iron may act 'as a catalyst for the reaction of hydrogen with the
halogenated hydrocarbon using the hydrogen produced on. the surface bf the iron
metal as the result of anaerobic corrosion with water.
• Pourth, solubilized ferrous iron can also act as a reductant, albeit at a rate at least
an order of magnitude slower.
ZVI is used for the reductive dehalogenation of chlorinated VOCs by the following
reaction:
Fe°+RX+H2O —' Feet+RH+OH-+X
Where R is an organic molecule such as ethene or ethane and X is a halogen, either
chlorine or fluorine.
A second reaction that occurs simultaneously is the reaction of zeroTalent iron with
oxygen to create iron oxides (rust). In order to minimize the loss of ZVI to oxygen
present in the groundwater and in the water that is used to inject ZVI into the subsurface,

an oxygen scavenger, sodium sulfite, was added to the iron in solution. The addition of
an oxygen scavenger is cost-effective as it is very inexpensive and assisted in prolonging
the life of the more expensive zero-valent iron.
Data Analysis by Monitoring Well
WMW-2S, SMW-11S, PMW 14S
_The applied materials have demonstrated effective and long-term viability in the
areas of the site where reductive conditions have been maintained. Reductive
characteristics have been maintained in these areas due to the asphalt cover at
and up -gradient of the wells. Monitoring wells WMW-2S, SMW-1Is and PMW-
145. represent these areas. These three wells have seen dramatic reductions in
CVOC concentration.
WPM--2S
WMW-2S was not sampled during the •last sampling event so its one-year
remedial results cannot be discussed. WMW-2S was last sampled in May 2008.
Before the injection events, the concentrations of CVOCs in July 2007 at this well
were 2,400 pg/L of TCE, 120 pg/L cis-1,2-DCE, and 3.2 pg/L vinyl chloride.
During the May 2008 sampling event, these concentrations were greatly reduced
for TCE and cis-1,2-DCE to 1.3 pg/L TCE, below the standard of 5 pg/L, and 8.4
pglL cis-1,2-DCE; below the. standard of 70 µglL. Vinyl chloride concentrations
had increased from 3.2 pg1L to 11.3 pg/L. This increase Is due to the increase in
the reductive dechiorination rate which produces vinyl chloride as a reaction
product. The concentration of vinyl chloride was expected to decrease to the
PADEP standard of 2 pg/L during theuc ust 2008 sampling event.
0,003
1000
TC6
Vey!CNorde
100
TO
1
6/171200T
Isl2001
11/11Q00T 11S2006 2112Q002
mpf Su
4/1712000
71210006
r

SMW-IIS
One year from the injection event at the site, SMW=11S has all contaminants
below the PADEP standards except vinyl chloride which is above the standard of
2 pg/L. In July 2007, before the injection event in August 2007, the
concentrations of CVOCs in SMW-11S were elevated with the TCE concentration
at 1,560 pg/L, PCE concentration at 21.7 pglL, cis-1,2-DCE concentration at 118
pg/L, and vinyl chloride concentration at 15.7 pg/L. In the last sampling event in
August 2008, the concentrations have decreased significantly. • TCE and PCE
concentrations are now below the laboratory detection limit. Cis-1,2-DCE is
below the PADEP standard of 70 pg/L, with a concentration of 24 pg/L. The
concentration of vinyl chloride has also decreased from 15.7 pg/L to 11 pglL,
which is above the PADEP standard .of 2 pg/L but is expected to decrease, to
below this standard in subsequent sampling events.
SMIN-11S
KO
600
--TCE
-cis-1.2-0CE
Vinyl Chloride
400
200
[100
E00
600
460
t
2110
0
61170007
Mt
816TT007
9125f2007
1111
,008
.
=2008 4/12)2008 611f2008 7121/2008
6)912008
1072:
Sample Date
PMW 14S
One year from the injection event at the site, PMW 14S has all contaminants
below the PADEP standards. In July 2007, before the injection event in August
2007, the concentrations of CVOCs in PMW-14S were elevated with the TCE
concentration at 182 pglL; cis-1,2-DCE concentration at 85.2 pglL, and vinyl
chloride concentration at 12.5 pg/L. In the last sampling event in August 2008,
the concentrations have decreased significantly. TCE concentrations are now
below the laboratory detection limit. cis-1,2-DCE and vinyl chloride
concentrations are below the PADEP standard of 70 pglL and 2 pg/L, with a
concentration of 2.4 pg/L and 1.2 pglL, respectively.

PNNY-7f8
ao
16013E
tiCE
1100151105215
00
Im
t70
t00
00
00
20
7l17R007 115l0007 121112Mf 112107a07 10R000 2211200E 45l N1LOW 721=06 5/212003 10201702.6
App•m1s
In these wells were reductive conditions have been maintained; remediation has
been almost complete with decreases of 99% of total CVOC concentrations.
Conclusions:
The efficacy of the applied technology has been shown across the site. In the
year since the injection event, all the monitoring wells in the area of the injections
have seen remarkable improvement. The shallow wells affected by the remedial
events are at or near clean-up standards set by the PADEP. As noted in the
table below, the percentage of TCE reduction in the last year at the affected
monitoring wells has been near complete.
Monitoring Well
% TCE Reduction
WMW-2S
99.9%
SMW-t1S
100%
PMW-14S
100%
PMW-12S
93.3%

Syuergisiic Treatment of chlorinated VOCs Using Reductive
Dechlorination and Zero Valent Iron
Wllliarir H. Reid (tivbriepavnef-irm.coni), Michael L. Woodruffand Daniel D. Weed (The
Payne Firm, kW., Cincinnati, Ohio USA)
Michael Scalzi (rnikescalzlaXiet inc.net) and Wade Meese (Innovative Envitonnierital-
.Techiiblogy, Inc., Pipersville, Pennsylvania, USA)
ABSTRACT: Eithanced reductive dechlorination and micro -scale zero vaient iron.(ZV [j
injections have been iinpleinented to treat. chlorinated volatile orgaitie compounds
(CVOCs) at a former dry cleaning facility in Cineiniiati, Ohio. These. remedial
approaches, 'comnt`only implemented as 'stand alone. tcchnologies, were combined to
achieve synergistic reductions to overcome the buildup of cis-1,2-dichloroethene (cis-1,2-
DCB), resulting from the breakdown of tetrachIaroethene (PCE). The property is situated
-on a thin veneer, approximately 10-12 feet (3.0-3.7M) thick Of heterogeneous glacial
material; 'overlying shale and interbedded limestone. The glacial material consists
pr4triarily of hard lilt ivith a thin sand seam of site to eight inches (15.2-203 cm) situated
above hie bedrock. The sand seam thickens towards an adjacent down -gradient property
Where CVOCs are present in a highly 'oxidized perched Water -bearing zone. Site
iitvestigatiatis have identified the soil shake area as the former basement of the dry,.
cleania4 facility near a sewer drain, just above the soil/bedrock intetiace. Reductive
dechlodnation was stifunlated in the source area by staging a series of injections at 18
poltits iri the soil source area td enhance the anaerobic environment. Results of the
injet;tiotts have seen the reduction of PCE to beloiuidetection limits in two oldie three
source zone monitoring points; PCE concentrations in the remaining source area
monitoring well inbnitoring location was 0.008 milligrams per liter (mall.). Based on
inoniteriiig results, the cis-1,2-DCE and vinyl chloride continues to degrade, the
subsurface tet:ains anaerobic and sufficient nutrients are present to 'maintain the
degradation.
INTRODUCTION
Tetrachloroelbene (PCE)" and trichl4roethene (TCE) have been used widely. as
solvents and degreasers .shire the 1940s. The widespread use, in combination With
improper handling and storage of PCE and TCE, frit degreasing and dry cleaning, has
resfdted in impacted soil and ground water at facilities where these chemicals were used.
Due le their toxicity and persistence in subsurface media, these volatile organic
conipbunds (VOCs) have been studied extensively in order to develop remediation
technologies to ef%ctively remove these compounds from subsurface media.
The environmental chein.Istry of a site in part determines the rate of biodegradation of
chlorinated solvents at that site. The initial metabolism of chlorinated solvents such as
chloraethenes in ground water usually involves a biochemical process described as
sequential reductive dechlorination. The occurrence of different types and concentrations
of.eleetron donors such as native organic matter, and electron acceptors such as oxygen
andcbiorinated solvents, determines to a large degree the extent to which reductive
deahlorination occurs during the natural attenuation of a site.

Adding amendments fo.the sikiurface Media can stinitilitte the micioornitnisitis. To
1 accelerate the natural proceties. ZVI and enhanced microbial deektorinatidh picriesse
Were ionized a the site. TIi utilirmloil of -ecietizymet; Oxygen ScavatiOr§ and nutrient
iiiiiiied thht little or no lag phife id the process was eaperienced and that The most
1 --' efficient pathways were utilized. Treatment has been iMplemented at a- she in
southwestern Ohio Using complathentatY infer -delft to biologically Mid eheinIcally reduce
chlorinated ethenes.
BriekOtiund
PCE and TCE were prevalent in the SubSitrfate at a fodder dry cleaning facility M.
Cincitinatii Ohio. &Wand grOinid Water sampling result's prior to injeetirig, the redectiVe
dechloririatian arnandrneiits Indic -tiled that cis4,2-dialordethene(cit-1,2-DCE) and vinyl
'chloride, dalighter products of the breakdown of PCE and TCE; were also -present hi the
soil and derniid water.. The presence :cif tlfeie breakdown products indieated that
reduCtive dechlorination of the TCE and PCE was occurring. -
Soils eircduntered 'al the she qOnSISL of Silty Clay With mbar amounts and sand and
gravel •(glacial till), overlying interbedded shale 'arid limestone bedrock. Beard& was
eneountaird acniss the site between 12 and 16 felt lit) bel&.v nurface•gradth A
thin and Merit is present at rite this interface. A soused area ii the kill aneVery low
yieldhig &had water, above the soil/bedrock interfaed- ivat identifiEd, near a floor drain
in The basement of the Fortner dry Cleaner. PCE celicentrationi ratigeil between 78.9
thi11igr kilogram .(mg/kg ) and 140 ing/kg in the, soil snuitii area Ground water
concentrations. of PCE in fife iarne area (pricir to remediation) ranged between 2.5
railligrant§ per titer (thigto and 12 mg/L. the elevated ground water conditions are &rein
part tai the kw floW.,16W:.:ryield nature of the water -bearing zone.
In May 2005 (Figure I) and again in DeCember 2005 (Figure. 2), ZVI and other
clietideid antendthatiff Were injected into the foil and ground water to 'enhance the
reductiVe deehleritniticai lines 'and Stitimlate the indigenous microbes to breakdown
amicentrationa of PCE gild TCE at the property. A total of 18 injection points were
Utilized to distribute the reductive dechlorination ameadittents during the May 2005
KII11.0.1.411
1
ID ET
1.-
13.112.313.017
PP...Ppm
FiGL1RE
MP MP,
r
FIGURE

injection event. SIX injection points were advadeed during the Detembet 2005 evett
which higeted the seurte aria After the nun -lead from the initial injeetions Were dcplefed.
- The ebjecti4e of the injections Was td treat the dissolved add Sorbed phase
chldroethenes at and &Wit giadieirt of the source area. By adding the ainendinerie)
reductive deChlorthitiori of PCE and its daughter products was accomplished by biotic
and abioticceSSES.
MATERIALS AND METHODS
In order fel the rate of recidetive diehlorinatlen to increak, it Vies necessary to
establish ecinclitiork in situthat could accelerate thidealltirintifion proCesi by'plovidirig
nidriontilo the indigenthia microbial pdPulation. injection paints wife Pirated an die
property to Supply essential mierobialinikients necessary for the dechlorination process
to be:Stimalited and 1.6 intrbduCeIVI Which wiiuld accelerate chemical reduction of the
chlorinated Volatile organic coMpotinds (CVOCs), actin g synergistically lArith the
aiiite6Stgle process A sgiftlefioei,if tig;-:s00010 eoppounds, including ZVI and IOC,
Were injected through theperfetafea.10.uting.tipCient-pending, compressed nitrogen gas
delivefiSyStem, The itepWit injeciien proCett a0141encied effects are as follows:
•.
Coniketied Niirdaeit .Gas. Nitrogen gas was deliveredlo-the inbstirfade by injection
at 175 PTothuds per 'Square inch (psi) to open up delivery pathways in the subsurFace.
The pressure was Maintained at a constant rate and pathway development was
ve4fied try Observing a subStantial pressure drop at the point of appliention, once the
pathways forni.d. Nitrogen was used in this step to establish and maintain the
anaerobic conditions in the subsurface. The goal of this step was to open pathways
similar to those along which the CVOCs would have migated.
&Alin Snlfite Sohition. Injecting a solution of thodTgrade .SO1* sulfite
immediately followed the nitrogen injeCtion. .goditInt'stiltit6 was used to. Scavenge
resithial 'oxygen from the subsurface to: I) ensure anaefobie conditions irid
reduce the oxidation/rcduetion potential (ORP) in the range favorable to the anaerobic
croorganlims; and 2) to prevenl dissolved oxygen from reacting with the
sithsequently injected ZVI. Nutrients such as orthophosphate and organic ammonia
Oitrogen) were injected with the Sodium Sulfite -to enhance the growth of the
microbial and help them maintain their metabolic pathways.
hilitro4dale ZVI. ZVI was injected ithinediately following the Scidiinu
sulfite/nutrient slurry. A Primary goal of the ZVI was t� rapidly iedude the high
concentrations of dissolved phase PM in the source area. The corrosion of the ZVI
by ground water also produces hydrogen that 'eari be Utilized by the indigenous
microbial population metabolizing PCE White Maintaining H. Apprbkithat6ly 55
pritthds (24.9 kg) of ZVI was injected into each Ideation thiringbdth injection events:.
111. The ZVI injection Was followed by the injection Of 1-IRC ' Choi vitamins.
13-2 and B-12. The FIRC-64 was treated to appit&iniately ISQ4ewees (F) to enhance
the flow ability of the materiarduring injection. The HRC -provides ari

dotibr for the anaerobic microbe# which degrade the PCE. Approximately 30 pounds
(13.6 kg) Of HRC was idjetted at each Ideation.
Vitamins B-12 slid 13-2. injected with the Rita . Vitarititi B-.12 helps maintain the
aceel'eratfed deductive •deckledination piif ess and lowers the activation energy for
electron transfer of the terminal electron to Cis-1,2-DCE, While .the tore elernentr
Cobalt, catalyzes the surfaee action of the ZVI. in inducing the dissolved phase
CVOCs. Without 13-12, sulfate oleo acts competitively With the CVOCs as an
eleotroit acceptor. Vitamin B-2 allows for more efficient Microbe utiliiatioii of the
hydrogen, increasing the Overall kinetics.
These injection's weid folloWed by ahother injection of the sodiudt sulfrtelniitrient
slurry to clear the injection lines And provide for in'sitti auxin , biro peitettatiori of the
HRC into the formation. Lastly; the iryettioit line's Were then Cleared of all injected
materials with additional nitrogen gas.
RESULTS AND DISCUSSION
In the deklopritent anti impienientation of a inonitdrhtg and evaluation program for
the'project, critithl field and labo`tatorypalahiefers *ere seidled. The colitpoiierits of the
monitoring prggrani reffuired that the'efficaey of the applied techtiiilogy be Wired based
oh tir'get ebtnp6und edncenfratiori reduction, appearance and 'disappearance of daugliter
products, pH Control, dissolved gas evolution and degradation product's Of the organic
hydrogen doribi-: The objectives of the iiiyplemented monitoring program were: I) the
assessment of the ?)the valuation of individual components of the
remedial pi rani and 3) ibe treatineitt effrtitncy of the program.
Grr .ttid Water sarri,pling, deemed oil May 22, 2005. immediately prio1 to the first
injection event to establish the baseline concentrations of the targeted chloririateti
cern/36tmd . A tdtai of°six ground water monitoiitig events were performed Between the
baselin -sampling: event and March 2006. In older to control the analytical "costs
assodiated with the project, the initial satitpling events did not irtelude dissolved gas
anaiysii, field pararnefeis or the analysis of -the breakcian t products of the organic
hydrogen donor. Beginning With )lie Ottobec2005 samplirig.event,'all parameters of the
tiionitoring program were included so at to value the biological Component of the
pirograrti •arid to allow for the scheduling of the second injection event. Scheduling of the
second injection was based on the residual le*eif of the volatile fatty acid precursors
(aietate, butyrate, formate, lactate, propionate and pyruvate) and dissolved gas levels.
in order to: assess the efficacy of the delivery process the evaluation proms has
focuted on the analytical and field results from MW-2. No injection occurred Within
twenty to twenty-five feet of MW-2, a cross gradient monitoring well which historically
exhibited moderate levels of PCE and its daughter products. The analytical data obtained
fr+brh MW-2 supports the design basis of the injection program. The area of influence
achieved 13y the injections exceeded a twenty -foot (6.1 tn) radius based on the decrease in
chlorinated compounds after the first injection ei+ent (Figure 3) and is confirmed by the
fatty acid compound appearances (Figure 4) following the second Injection event

•
X
IL
•
• • •• ••• • • •I ••• • •
F., •
*DM 4,CE Va
Carpid
tECIjRE S
4r1l.b..4rflii•X•4
• • • -
1111,• Tom.. 1.1. •
.4•0••••••=••••
FIGUlii 4
Valuation of the individual componepts of the remedial program coasted of the
ey,O1441P.O. Of thq effects of the zero yale.at iron component and the hiplog1cal component
of the remedial program. The corrosion Otte zero valepf iron compo9erifyaLyalued
by -way of the ftrilt,tenee of the Ferrous fropo.O p11 at MP.- I and MP-2 following the
second 10140166 6/Fat:, The valuation of the biological component was valued by -way of
thi"nipekan4 Ofiliiiolyed gasses at monitoring point i MP-2 and MP-3 before and after
th6.katitalfajection event (Figures 5-7).
ilmtftre...04.01•1211eiallid!
xxac•-.1?-r•••••‘ormai.4
1?1GUR5 ElqUi* 6
The Orlence of.the ZVI corrosian is'Seen Jq the effect of the fer0Rs ir6a speciet�n
the pH. in both MP-2 and MO:3. *fat file corrision ofthe hen eonipbnent dissolved
chlorinated compounds are converted to eibitii6 and the fehius iron ptovide hydroiyi
species as a pH buffer.
The evolution of dissOlved 'gases ibilevilet the second injection event pfovidei
further evidence of the effectiveness of the in-slni piagrank The dissmiIa dissolved ias
nashe.b.:•40•44.4
OtaIRE 7

r
profiles in MP-2 and MP-3 idle& the differed -Cis in the target compound concentrations
in tlidie ateat, The ahility of the 'areal% progain to Coiled the coMpititica for
nilerbbial resources between the delialoginatOis present at Ilia Site, atid the
Ii�ntet�ge mid methanogens is seen in the diSicibied diftribittien In the wells
MR-2 and -MP-3. As eriniPared to aiteriititlie organic toogpii. drnofs, which exhibit
rapid release of hydrtteni the HRC product effectively m&iioenesis freni
'out
criiiipeting the delialognators for microbial resources until thsobied .chloiinated
ecinitootinds ate Mineralized.
The triatmedefficiicy Of the ptograin Is demblistrited by the tigniticant reduttiOns in
the targeted Chlorinated compounds .84 l). Unlit programs diat utize dril
oigeriie Itydfogen dcitibre, thi remedial iik3iiisieh hid no Tag phase between the injection
eventn(�tiIThthi1traIizatioii ;gibe chlorinated ebnipouridS: As a result, the ground water
tiuiping indicates that ctincentratidns of PCE and TCE haiie &creased hi all wells and
monitoring points since the initial injections in May 2005. The higheSt PCE
cencenhation remaining in the source area grand tiiratefaitei• the Maith 2006 sampling
ivas 0.00g mg/L in monitoring point MP-2 i the highest TCE cciicentration Vetii 0.005
in the same well. Concentrations of cis-1,2-DOE and Vinyl chloridd hciWey-er, have
rail at •Oariaus timei as a result of thb breakdciwn of the PCE imd TCE an site.
Shia the iiitia1 sampling event, c1S-11,2-DCE and vinyl chlotide corkentratioitiin
monitoring Well MW-2 increased front 0.420 inga. and 0.009 ing/lf; eesPeallieiY, to 11.0
toe. and 0A40 inWL.
iRleen9.63114611.613965S
hAtagrzten
SO,
0150
1601
i 129:
i g,i • t 1 • 4
7-4Ril i
hfrt0
I ! r.....m.1
1.1 .1 1. - I
....•
4631. trei i 1 . 1. • 1
I• I
ea! 1 — -47-- -.4
eon
24:
4"
m ZOS 4536 WZ wrocs sacs , 'inns zit iktt
tanking
Enka.
FIGURE 8
FIG LIFtE 9 '

r
trOi
t{
• Nef
ran bd. tun
r 11.
ary ityitaa
1..1 •
r
r
VP •
I • t
resm Rm. b:e• mon au* ma.
00110 ID II
CONCLUSIONS:
Tho biological activity and the: rates _cif dechierin. otion appear to Vary across the
injection area based on the concentrations of the targeted compounds and the sorbed
Mass. It is. clear that the polylaotate ester and its degradation trodOls have proyi-de
prolonged hydrogen for the enhanced attenuation phase. The eYects tit thp second
injections are -clearly seen in MP-3 where the rapid disappearance date daughter prollotts-
of the PCE occurred.
The IncerporatiOn of tile vitem4 mitt nutricots. nici the significant ej4-1,47i5cg or Vipyi
Chloride itectunulation. The inclusion of the zero valent Iran has allowed 'for pH eontrof
and enhanced remediation of the site. The anaerobic component of the program appears
to b.e eftectir n addressing the chloroethenes.
The vihurtin 13-12 and to a lesser degree the vitamin B-2, appears. to. mediate tho
reductive dechlorination oldie PCB. in most biological systems, the rati-limiting step. to
complete dechlorination to ethene is the last stage conversion of vinyl chloride. The rate
of that pretest has been found to be significantly enhanced by the presence of vitamin B-
12',.which acts as an electron carrier. It is the core of B-12, which contains Cobalt, and it
the various -.oxidation states of cobait, which allows for the electron transfer intra-
cethaerly within the microbial population. The presence of the cobalt core has also been
seen ja catalyze the surface reaction of the iron lowering the necessary activation energy
reetilmA for the electron transfer.
The accelerated reduction of PCE. ICE and cis-1;1-1Cg to vihyl Chloride (Pigryo 1Z'
and ethene, has continued as expected as hydrogen is generated by the slow releasing
polylactate ester and the effects of the ferrous compounds which formed as a result of the
corrosion of the ZVI. The appearance af ethane in the dissolved gas evaluation also
indigates that the zero valent iron species has contributed to the overall efficacy of the
synergistic integration of these technologies.

•
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cD 005
- As 905
• . 1 /6.,06
o .02
06005
<0.001
50.005
.10.05.5
, 2.cloa
0.025
.0.005
.1005
10.005
.0005
!, 14415 •
0 OM
.0.005.
.0 005
L.10 C05
...n 005
•
.
'
SIP-3
-
.609303
0.051
'0.005
.0 00.1
.3905
.1005
9105
0.006
.0005 .
.0 002
'4.901
06.005
100105
.<0.005
.7.005
0.025
.0.7160
0.050
i i mos
siliba$
nem - •
. 0114 ..
a ri.ls
. 0262
Mos
.0005
..0.1105. .
aces
O064
00.005
310)06
'<Ada
50.005
. . 0.07.6
0_009
. <mad
• 11200 .
.<0.005
35.005
0001
' 0.013
.0.605
FIGURE 12
Ground 1yaottiituriritprinpvilf.ctiritinup uhtil the cis-1,2-DCE has biert degailed and
the vinyl chloride concentrationsielCh the proposed cleanup goals, Once that has been
0.comPlished. CurtfirirfatOy*tkiAtiiPliiitidll be peiformed to determine if the PCE and
'PCB adsorhed.onto the Soil graini has alsii been effectively reduced or whether another
injection to finish the process is required.

L.
FIELD IMPLIMENTATION OF ANEROBTC• DECHLOR I!iATION
UTILIZING ZERO-VALENT IRON WITH AN ORGANIC
HYDROGEN DONOR
1kTtctieelNcafzt'{IE ET- 'C!l'eo (Irrrloru(ive 0:Wm:rnrental Teehrrofagies,
Plper,n Ile! PA3 USA)
ABSTt ACC: Generally zero valent iron and aiiaerbbie stimitlatiomi Utilizing organic
hydrogen donors are vieiVed as 'stand-alpue reriiedial techniques: The projeecl site; a
foiiner 'research facility whlch in ii tamed a RCRA storage facility, entailed the
applicatien'Cif these 'hva synergistic tiolinologies. As a cbitsequette'e'rifle historical use
of the area) groundwvater and spits hard b'eert impacted by chibrtnated ethenes and
chlorinated ethanes. Tkeintegration bf the technologies iricerperated the delivery of
vitaminS.$Z. and B12, an iminrganic Okygen Scavenger, an inorgatiio nutrient addition, an
orgarlid hydrogen donor and a I=3 inicron sized zero-valent iron colloidal suspension:
rriiraductioh of the materials to the subsurface ivas acCamplished via alt Innovative direct-
pusltfinjection approach;,which utilized nitrogen gas, pressor+: vessels and traditional air
diapfiragiiv pumps. Field and laboratory result"§ six months following the injection event
inclimding Feld data lodgers for first tivo months indicate nearly immediate removal of
dissolved oxygen and 'negative oXygen reduction potential of nearly —400 mV.
r aboratot}I data for target eAinpoimnids, daiigitter compounds and inorganic compounds
det)<lQtlstratb' the efficacy of the remedial program. A complete evaluation of the
iridividtial components and the chemistry in -situ at the site indicates that the inclusionof
the vitiinmins and the zero valent iron have provided for dechlorination at high sulfate
levelslvithotit at -Da stall-outand without a lag phase while providing pH control.
1NTRODIic 1 ION
Through the years, chlorinated solvents have.I ad a large impact on several industries,
ipclutding pharmaceuticals. chemical praeessin „'food extraction, dry cleaning, and metal
cleanumg. With wide spread use and improper handling and storage, extensive soil and
water damage has occurred. Due to their toxicity, carcinogenicity, and persistence in the
environment, chlorinated solvents are listed by the United Slates Environmental
Protection Agency as high priority pollutants. If left untreated, chlorinated solvents could
reinain unchanged for a period of fitly years or more. The most common chlorinated
solvents used are Methylene Chloride, tietrachloroethene, trichloroethene, carbon
tel[acltloride, chloroform, tetrachtoroethano, dichloroethene and vinyl chloride. Carbon
tetrachloride is a systematic poison of the nervous system, the intestinal tract, the liver,
and the kidneys. Vinyl chloride and Methylene chloride are known carcinogens, and
ou1d nlso affect the nervous system, the respiratory system, the liver, the blood, and the
Iymph system.
Chlorinated solvents are often founts in separate phases mixtures commonly referred
to as dense nonaqueous-phase liquids ("DNAPLs"). DNAPLs are visible, denser -than -
water, separate oily phase materials in the subsurface whose migration is governed by
gravity, buoyancy, and capillary forces. Chlorinated solvents partition into the water
*seta create a dissolved contaminant plume when in contact with water, thus creating a
tong -term, continuing source of contamination as the soluble constituents slowly dissolve
into moving groundwater. •

In the second Week of June 2003, a series of field injections of remedial liquids,
suspensions and gases occurred in the area of a former RCRA storage facility in IQW
Jersey. The objective of the program Was to a idiess dissolved Lind sorbtd. piiaso
tirloroethenes and chloroethaites. The preinise of the program Was that accelerated
dechlorination of soil `skid water contaminated with chlorinated solvents could be
accomplished by stimulating anaerobic microorganistits and thus lncfeasitig the late of
biological mineralization oldie solvents. This was accomplished by a treatment process
consisting of the injection of a colloidal suspension of iron pbWdef(ZVI) with the
Hydrogen Release Compound (I-IRC, a slow release organic hydrogen donor, primarily
-consisting of a polylactate ester), chemical oxygen scavengers (reducing agents) in
solution with essential nutrients (tirtho-phosphate and nitrogen compounds), vitamin
stimulants 132 and B12 delivered via the compressed gasN2, so as not to oxygenate an
environment targeted for anaerobic processes. The treatment stimulated -naturally
oceurring microorganisms while oiddizing dissolved phase target compounds via the
surface action of the iron particles resulting in die breakdown of chlorinated target
substrates and their daughter products. It was found that the incorporation of the Br acts
as both an enzymatic. stimulus for the anaerobic action and a surface catalyst of the iron
patticie. It is hypothesized that the core element of the I3tz, cobalt, enhances tite surface
Oxidation action orate iron.
A closed delivery system was used; utilizing a combination pf gas and liquid delivery
systems. All of the vessels are iniercomtecled and valved, allowing for mixings,
Washings, filling, and discharge of materials via pressure vessels or mechanical pumping
Systems. The system utilized aliows for a variety of dissimilar compounds to be delivered
via a single injection line. Further, the switching between feed systems is accomplished
without any loss of pressure to the delivery, line eliminating the common problems
experienced from the vacutlet developed down -hole as pressure is released and reapplied.
RES1.1l4T8 AND.,1JISCLISS!ON..
Prior to evaluating tile. field results, an understanding pf the daughter product
ciraracterislics and how those characteristics relate to those of the mother product cvas
nebessary: in particular some method of accounting for the absorbed tnass''of target
tornpoutids on the .soils was necessary sa" that Held -sampling data could be better
ittt<rrpr'eted, Sorption can be defined as the interaction of a contaminant with a solid.
More spiftcally, the term can be further divided into adsorption and absorption. The
fonder iefers to an excess contamination concentration at the surface of a solid while the
latter implies a mare ar less uniform penetration ofthe solid by the contaminant
Unfortunately, in this environment and 'most environmental settings, there is no
information contenting the specific nature of the interaction. As a result sorption shall be
used in a generic way to address both phenomena_ As a -general ruIe, assuming a
chlorinated solvent is equally distributed between phases is ill advised. As hydrophobic
compounds, these solvents will partition preferentially to the soils. Within a system
where tb . Pore water -occupies 30% of the aquifer volume, two (2) liters of aquifer would
contain 6013 mi. of water and 3500 grams of soil (soil is about 2.5 times mate dense than
water,). As -a result, if there was equal distribution of the contaminant between the phases.
sliglit1y less than I5% of the contaminant mass would reside within the aqueous phase.
Give• to hydrophobic nature of the targeted chlorinated solvents much Tess oldie targeted
eontatninant's mass is found in the dissolved phase. This partitioning is strongly
associated with an individual compound's solubility, as the solubility of a hydrophobic
compound decreases, the absorption coefficient increases.

When eValuating the adsorption characteristics of indiVidual compounds the
Freundlich equal:in, On entpiiital eqtialion that is very useful because it accurately
descriliet actscirption data can be applied. This equation is:
gi .4yrfFeequitiblit +1 n ranceitaion
CeSobiliveoilthriuricseentratiart geWeglia
11F widen mutat
K=Coutanl
Usi.tilmblit5W,itdpf,orFrqundRch.Pfuvieters:
. • 14Infig)ClimOr" Ilri
Tctrarhioroahene 143 0.3ta
m Triehteethene 1 56
0.482
r-Diehromethene 1 14 0.452
C-Diebioneillene 1 12 0.587
Thus the: individtial Constants for the mother and daughltrC'olitpoimds may accurately
predict dittz6lved aid sr:died phase chaiiget. By aisignitieridorrection factor for the
diffbreiteet lathe site's sbUs id catberi abicirittioh, a calculated dissolved phase for
daughterprildtictsnfthe decided n'aticia PredeisWa.s'ealeulated.
it is dit'deetaist iti hydrbphobie'thaMCterisliet'cif the Ctiiiipotiricis With each chlorine
lest that istispehiliale for the dramatic Oerase in the Constant "V. Thus, as a Mole of
tettathloroillierietitidereie:s a single' Steil dechlerfintion the feaulting trichloroethene it
nearlY66% less likely to partition to the soil Dilate' tifequiliblitint. Linder these conditions,
rdthnItO there was A c-DCE accuinulation in the disiohled phate duringthe firtt three
mein -lit, that was nil "glair: Therefore, the appeataneo and disappearance ordatighter
rifautis was Clot -ay related to the sorbet fractions,.Whielt in turn Was direetty related to
the SOU Vile in an area arid the time that soil hit been in. Contact ivith varied
coraidnitinot 'Of inipaeled glibuildilider. Ai An =ample, thatWells hinikediately in the
soiree area' OrdoWni &die& will theivil Nitta' Concentrations iif datighter pritridels as a
reniediatinit beaus dad .to the detrifpri.611 aid degradation cif the Mother product(s) wliieh
are Mofeltdraphohiciltait thedattrhterProcItieta.
FreqaattlYrafte4ial sites shbiii insigniflant or inceirtfilete dichlarinatirinz especially
those Willi high aquifer Sulfate Ievels':Titis potential ivas tiatficularly a concern at the
NeW Jetsitsiiii. It It fretpiaitlyiteld that erfaipetition Of Sniffle With the chIciridated
brganick as an eleefren iedepfor is reSii.onsible 'fin? flit Condition. It is gerallY,
.ciC,Terloolied- that the rapid c6b:WI:5161 fsLi1fat610 toxic free Sulfide during bacterial
redtittive'dechlOrinatiokplar a signifitant"rele in the "Mailing' Of the biotic process.
keteinilatioh btfrea initide is ispeCialty ithpornin in sites that display bDthhigh sulfate
and low miailable iron: ReducriVe.deChlbririation inhibition by tree sulfide'has been
Observed in Mierecostris conducted for hi4li sulfate held Sitei. Fret suUlde toxicity to
titierCortanitins bepreverited if feirotts iron precipitant the free 'sulfide. Fulther, iron
thifidi Mineral precipitafet have been shown to Catalyze reductive deelficirination of
chlotinatedtblents at rates cOmpatable to metallic hu On a surface areanorinalized
basis. Microbositis performed at bigli sulfate sites have been -glowed to bat remove flee
Sulfide to ilehatogeriati4 bacteria and tee enhance CatalYtie reductive
dectildrinalioti What ferroutiran it added. Further, fl'rmus lion, ittelf, may act as an
electron -drilla'. The actinnulation hid then the disappearance ofthe ferrous iron species
theretore was finportant in the'evaination of the "efficacy of the ability of the program to

Fe= kw Li4;
lar,a ErNs
ViGLIFig teerrous Iron Across Site
tadmina412SEld
FIGURE 2: Stillate levels eproflz llio Ireatrnept, area
IGURE.* Typical WeB OFtil response following !Napkin even!
Inlilbit the c-WEstallzbin
phenomenon (FIG CIA*
The'eftect of the ferrous ifdri
Id fin -titer confirmed by the
Sulfite leveliobserved across
the area (fIdURE 2).
In any anaerobic
reducti'verlechlbrination
13r:if**, the efficady is
cloSely linked to the -ability of
the' `Chemistry b3 rapidly
deliieye and maintain the
te'clfretive Conditions. Field
TO flit -clam of the area
through in -situ data
ailoWed for reatligne
evaltiation of thiscritical
panipinient. In all Wolis the
rapid.anci sustained reductive
canditrond facilitated
anOpilb deductive
dethlorination with no
apparent lag phase. The
tkiWilgradient well, MW44,
tiptycitiiiiratkly 20 feet
eulside ofthe treatment area,
Is characteristic of the field
,•.,•
ORp_data gathered (Pigure
3). The observed pH, ORP
and ditsbived okygen control
?file sito (Fignre3 and 4),
in cbrilUnction with the
ferrous iron data (Nora I),
fiiHhet enrifirmed the
thernistry of prograrres the
ability' of the individual
ceraponerits to work together
synergistically. oV&r time.
The data nlisi indicates that
the early nienthd bf2-004, pH
leAati, todecrease due -to
eesiveChloride
production. Both the slow
relasing.prailectate'eSter arid
the ZVI' balk-. 'shewn t�
effectively change
groundwater conditions to
erihnitoe reductive
deChlorinaticin of the target

compounds On •01).lotie and utic ay EiS show below. The mot reMovai has
°teethed at the dam, gradient well (IVIW-ZOS; FigrYteS) and the doss-graiiientWeii
(MW-215;17)4ur 6), indicating that the plume is effectively contracting ns a result of the
reinedialProgarti.
• ?Mittel., the getter -Atkin of
danginer procluds, ethane and atilt;
ii0WO that thd 445etitiinate:d
;hlotigginia approach Uoig
§Srtfetistie imernetion ot tird
techgrilogies. The rapid production
Of tbb gases during the first three
n Pth ..ntay. most probably. be
attributed to the effect oldie Iron as
well as die Ana411156k processes.
Utah -gradient well, RIW-21,
experienced , in excess Of -90%
rOcigctiOti» TCA, reducdon ili
158 and 60% reduction in the TCE.
Waal iitc!eaSes in daughter products
in tb4, .Septeinber sampling event
Were followed by decreases in the
Itct,triplrigunit
I • 0.4p441--
-
111.1411
t
nijE4 125r#10311111 pH trends trough a:ridot
tititIcFA•te,.........
L.-
11
4
I...,,,,....•-•••::•41
.„..
• 4.4.44 i
'i•
4 I i
i I i
1 , t
. 4 P
I
PP- i
1 F.
..a. -^: .:-. --. • ...-1—:'.2. -'7...'4 .. - T -.7-.11.
" ...-
lafteladm•—.1.
flQUIE5 ress pew mitattoring wintrgat compound iiqUI10: Itrmediatly oradient tnorihariag we( within
ottiontiecrits friatritord firjeledeatrpoundconcerOalious
• irgikairiTapok4.4•1.1..itino•
..-• - . - ..........
1
rAIi*
ItI
- • . -
kaat
I
I
IT !!
-•• ;
;OM r-4 ,
6.11 I.
a."4/ I4ir:
14. 444.44.4. gy.
.1.11 11.14-N
111..27470.1.1111 4,11:12 r , _L.?.
4,444-7- 4 R.! t 511 : PAT •
FIIIIMET: Crass gnutent derateltime Erdscaetriakes
I
11
Li
. .
• 1
I11
1 -
•
1
• -
t 42,4 . P./L.11.
esr2=1 — f • •
._!?L
FOLPPIBt• Cross vaoltra ethkeptilutte kgeoPtedkalts.

Oenther event,dife most probably tn the absence ofany incursion from the pluuie
(F1dt:117X7 & 8):
Bad
pm;
aal
mai 1 t.J•fJ
pi:maga : barmt;edeal chbisanne hictrontrctes liatRETO Darn paareni chluveVuni, lifvermscrai
Monitoring well 205 saw a decrease iii TC.A.,of 65% and a PCE reduction of 30% with a
slight increase in TCE of 18%, due primarily to anaerobic activity acting on the PCE.
The continued dechlorination of the daughter products seen, in particular the c-DCE
indicatesa continued mineralization of the sorbed and aqueous target compounds
(FIGURE 9 & I 0).
For the six month, period for '0....11144 data is available, the application of a,syneMistio
aPplication 'of Chemistries which allowed for control ofniny of thd issues facing
pr.aCtitioners of anaerobic processes, rapidly generating reductive conditions,'dertiOnstrating4echlotination through to ethane and ethane, minimization ofthe effect $ of
sulfine interpittation of c-DCB generation and rapid remoraof dissolved phase target
panipailnas.
The utilization of vitamin§ iilipArs fora reduction in Lilo attivatibn:ettergyrequired for
•cortipleteelegrigi transrthrough vinyl chloride. By integrating a varietybf stimulation
and tolFtliatchetnisties and applying them via raPid, non -oxygenating processes, the
stint action ;of liteindividual compooents is greater than itthey Were to be used separately.
The Vttarom lowers the oetivation enemy required for the electron transfer of the
•:• 4 • •
terminal elOctron to "c.-.13CE, while the core element of the Bp, 664, catalyzes the
surface action of tile ZV1. Without the B13, sulfate acts as competitively as a terminal
elect:on acceptor. Vitamin B2 allows fora more efficient utilization of the hydrogen in
the anaerobeeindreaSingtheoiretall kinetics.
The pro:didi-on of ferrouS iron as a consequence Ofth- e corrosion orthe zero valent
iron allows for pH control in a reaction that produces free 'iltroride ions, ahethus pH
depression. Further, the ferrous and ferric species reduce the free sulfates An d sulfides in
the environment, allowing for thorough dechlorination without the accumulation of toxic
compounds,
The inclusion of the oxygen segyenger, sodium sulfite, proslpecd neatly immediate
redadhl conditions allowing for maximum utilization of the Mc product a hydrogen
donor rather than en aerobic growlstitistrate. Thus allowing for more successful use of
the o rganic hydrogen donor,targeting anaeroldc processes_ •
' The varied affinities of chlorinated compounds for adsorption to sail is 'directly tied to
ihe number of chlorine atoms in the molecule. By recognizing that the appearance oft.;
1;;1271.4:an:sa.sa;dapai.ats
•
•
:
.1;.1
ilartameanan:aaaer7lai
I 11
- • :7. • ' ' • - • • • • •
I
I
•11- "
•

DCE Is trtquently the result of dechlorhiatiort of sorted trith)oroethene and
tetrachloreetliene, rather than the result °in "StaIt-but" of the anaerOble Process, the
geld application anktunderstithding or biological processes is more clearly presented. In
this Way the Sthichibmettie imbalances seen In mother product disappearance and
daughteicoMpenlid appearan5e May be resolved.
The valuation of the ertietef bra process or prOcesses, as in the case of'synergistic
technologies, requires that tht entire data set be evaluated with an understanding or the
interaetions. between the inorganic eomponents, field conditions and the degradation
pathways of the targeted tbinpounds.

{
Emir= ScL Tec hrtot 1800, 3$ 2128
Response to "Comment on 'Competition for
Hydrogen within a Chlorinated Solvent
Dehalogenating Anaerobic Mixed Culture"'
SIiI: WegreatlyapprectateDolfnescommentsouourrecent
paper (1). raising the Issue of the source of reducing
equivalentsfordehalogenationofcis-1.2-dichloro tbene(cis-
DCE) and vinyl chloride (VC) that occurred after the added
electron darter. benzoate. had been consumed. Doffing
suggested that the only plausible sourceotreducdng equiva-
lents at this stage in our batch cultures was acetate, which
we agree was present Darling suggested several possible
mechanisms by which acetate could serve as a source of
reducing equtvatents. mechanisms that we ourselves had
considered. We too had puzzled over the continued delta-
logenatioa effected in our cultures and conducted experi-
ments to determine whether acetate provided the reducing
egtdvalents for this, or whether some other source aught
have been involved We take this opportunity to share our
experimental results.
In our batch experiments (1). 20 mg/Lyeast extract was
added to serve as a necessary nutrient for dehalogenating
organisms aswell as0.3 mixt benzoate.Inorderto deterrntne.
wit etheryeastextract oracetate tuns the Ilkelysourceofpost-
benzoatedehalogenation.wepreparedstnhller 100-mLbatch
expedmentsnnthatttbenxoatebutw9th20n g/LyeastextracL
1.0 rnM acetate. and their combination. Figure 1 illustrates .
typical results from these experiments in which 8 /rmei cts-
DCE was initially added. Without yeast extract, no ethene
production was detected. even when acetate was present.
With 20 mgil, yeast extract. debalogenatten resulted. pm-
ducing a very similar ethene production profile in tire'
presence or absence of acetate. Etheae production rate
. continued after about 40 days but stoner than Initially. We
condudefromthesestudies thatacetatewasnotasignllkant
source of reducing equtvalenls In our culture but thatyeast
extract was.
The overall degradation pathway for yeast extract is
dlfilcultto followberrurse of its complex composition. There
are thus many possible explanations for the slower deha-
logenation rate after 40 days. Ono possible addiUrinal source
of reducing power that may contribute to the continued
s
5
a
0
}zo trW»
edtaCIL
-e—Mo ,200&l
Tem cum
—14-00yl Van
e
—.1.—keta 1.0001
Ya textb r
so 120 esa ew
lime (day)
FIGURE I. Ethene production from cis-1,2-dkchtoroetheew derta-
logenation
dehalogen anon observed is the decay of biomass produced
from yeast extract fermentation. Its slow decay could preside
a contlnuedsourceofhydrogen for delta logenation.We have
confirmed the potential significance ofcelidecay inreductive
dehalogenatlon In ether studies that will be reported In a
separate article. We thus conclude that yeast extract and
possibly bacterialceridecay,notacetate,weretbellketyactive
sources ofredudngpowerinour cultures follow lagbenzoate
consumption. As a correction to Dolfngs Iast statement,
our dehalogenattng culture was derived from a PCB -con-
taminated groundwater site, not front digested sludge.
Literature Cited
(1) Yang Y.: McCarty.P. L. Enrirwt. Scr. nand t998, 32.3591—
• 3607.
Yanru Yang and Perry L. McCarty'
Department of CMt and Environmental Engineering
Stanford University. Stanford, California 94305-4020
PS0920081
-'Correspondingaruhorphone: (S50)723.1I31:r. (sstl)725-94?4:
e malf: mccartyeclve.stanford.edn.

-
MIN

1121 United States Patent
Scatzi et at.
I lni miJut lfl n@ nu IIn int 11112 urn uH tIi11t1111 ItA fl1 WI
US00764a15262
(ID Patent No,: • US 7,044,182 B2
(as1 Date of Patent: May 16, 2006
C54T ARATI S FOR MOM RaMEDIATION
1TSPYINC A CLUggs DELIVERY SYSTEM
t7A loamu11 MMtdrad Sealed, Uoytestoiw. PA (UP:
W da geese. L1'onhtngswe. OH fliST
(73) Alsigreee; Innovative Erniranrbentel
Tcehriblogtes, Inc., bayfesionn. PA
CUS,
a 1 Umlo S,bjea re may 144sinut. the term ends
patens is extended er dusted tinder }5
15 b lay 4 a des,
(_''1} AppL (ta„ 10/677,322
Lail Filed: ilcf. 3, 3003
C6F1 Friar-Pabliraifon Data
US 2004A112931 § Al JuL
Belated D.S. Apjllkalian Data
PrOvisionul slip➢ ation fja 60r437.ii8I. fled on lea.
6-1003,
tilt int_CJ.
II57b5/,4d t2OQbd1)
it?t US.cL ,.„_. i3712U$;1t7l 6:137)$6;
-13M565.229 137/899
as; tie1d of Classisca➢ad Seared . , 137/208.
W40. 245. 236.. 266. 365.19. 565a.'899
sae application tilt fat complete search hiswry,
C561 Referenres bled
U,S PATitrit boalmal4rs
4933:51 rt • 311893 Dal! 13T�d•6
:529,659 A • 104933 Tremble et et. ......, 137f 66
362,671 A • 1111944 Spanifer al........._ 13N+16
_421765 A • 6 i 47 T_$or --• 13T7208
2.124.440 A • 711947 Chub 137lSa3
2,617,765 A • lfli9S2 Slarr • • iYrrak8
2,954,92I A 1 fr1961 }Vhftemrn' 131266
3,484297 A • 12/1969 Ester: c ut. __ - LLTpas
3.$4jz19 A ° V1911 Eller ._ __: - Id7Pg15
$,871 K96 A VI997 Bethel' it 51.
9E•13355 A 11n99a Saemd,Ys
5441235 61 WWI Per ialo
5.255351 61 l01 Shipho et a1.
6311.605 11 Tlh_+Jo1 K 1b i
6911.155 B1 2/2002 Uinta eta!
e deed by eeiaminer
Primary Eaudirurlo Rived
(74) Arlonul; Agra; de Punt --Gregory 2. Core
fs`a AaSTtzA4T
A preStutizeddelfverysysuem for in -size dt0secy afsub-soil
teurcdtatioa cdni9Q6 ids tp tinrieirouad cedurninmed mak
eQinelodeiAliquid drapluagmpiahpcarin ardtooaingnw
source of wane the pump being also in Itutdcommunication
wieit'>y plurrlisy orbioslurry tanks maned in parallel. the
Limitary tanks each having a drain. Vain mamma located
between the liquid draphtagm pump and each of the Ma-
slvny tanks for eonuo➢ing either the alternate or simuha-
name flow of Quid from the pump to each of the biasluny
edrlkt- A second liquid diaphragm pump Ise ii mu inlet pen
for trrciviag the comkiwed flow of the biaslaay Ltntshis on
millet In fluid communication with a system discharge port.
The system funhoc include a Source of compressed gas in
Quid aoiarnunlcation wilt the dtsehorgc pout. A discharge
rod Is connected to the 'discharge port for delivery of
refnedlal fluids to underground soils. A gas pressure line
leads from a sown of compressed gas to the discharge pot
'ss>Yl k also fn had rommunicadon R4rdt the feed tanks for
manta of i1Jcaanls under pressure. the feed tanks being
[tidjvidaa➢y pr3tturimd by the selective fluid communica-
!!or with the pressure line. Each feed tank includes a
sepamlety valved exhaust pan connected to the system
dnc3iaige port web dint the source of lojectart may be
8wh41ied foam the bioslurry to t_s to any of the feed tanks
Witlustal loss of delivery plcsavr.Thdsoneee of pressurized
gas 1aay be a mM:dril 1 eampressor ore stored compressed
SO
7 Claims, I Drawing Sheet

1
US. Patent May 16, US '.7;044,152 B2
COMPRESSED
OAS
21
FIG./
COMPRESSED
GAS
LIQUID
DiApiiitAtM
PUMp 131
23
DiApiikAbm
PUMP
P2
26
1

US 7,044,152 82
1
APPARATUS FOR.IN SITU ItEIv EDiATION
USING A. CLOSED DELIVERY SYSTEM
The present application Is elated w provisional patent
appfiraaipn' see Na 6Qld3Tr9$! enlirled `Apparatus for
In-S'ire 1'6rue: ration Habig a Closed Delivery System` filed
un Jan. 6. ?Oqi, priority from which is hereby claimed.
F1ELO OF "(HE INV13vff1ON
lire present ingntion refixes to apparal+js lot tiro oiib-
surface injt+aion of remedial Rgirids. shades and colloidal
suspensions to trreg impacted grdtlirdvrate= sand Salle
, BACI(GROtIND OFT E INVENTION
time me many methods and appamius pupated for the
!realm* of contaminated Mauer. Baying the material
mnaKmnon, vacuum extruding: And microbial miaemliza-
dan ate jttsi a few available options. ]3urying the wadi E§
°oinmosly bow radioactive OM regicftrant materials' arc
treated Solids are dcpeslicd In shallow 'reaches obaat [lice
Meters wide and between three and five locums deep. Mach
the wane is filled to about one meter from did fop Of the
french, the trench is covered with rants- A Inge volume cf
heterogehehns contaiminmion is produced by such waste
Which may e.omirmously seep into the soil and water lass-.
etnifori fa another available option. The psnpose of incinera-
tion is to bum Otte contaminants and leave only the clean
soil, howevet this mhy he a very expensive process and not ,
rely feasible if large volumes of soil need tote acated. Also,
hum have pollution side effects of vapor and air pollution
while the' tell is peeing removed and moved to the incinera-
tion site. Soil Vactaim Exhtactian (SVI is a simple and
econbtimeal irchraient method, however organachlorle tom- as
pounds in a concensation of several ppm or lower may not
be readaTy iempied w nn Cavoinsd wfillFrt days of hits.
Fprthi:rchanneling is 1u_W_meetly found within SVE system.
further terra [lte%ystccm's overall efficacy. Lastly many
compounds w) poor Henrys Canstan[s will not he e�- 1
"dandy removed via an SVE approach. This physical
approach rnmcdlatioa process requires time In annual style.
In order to solve the problem with the above-dcscnbed
methods. biological cc in -situ oxidation processes have heat
devised. Critical to any in -situ injection process is the as
efficient delivery of mtucriais to the .targeted area or zone.
Eiv uently rnatcdais may he injected by way ofa cyIia l is ii
dcri4ry rod with an expendable point This point is pushed
Mai ,allow for pumpe l material an escape from the base of
the InJeeird point. re. -stir remadiadaa allows for petroleum so
hydrpcarbon. chlorinated solve. metals and radonueoll to
be treated whhcul bay digging of the soil. so it cm be
pertained where other treatment uppmaches may not be
practical.
En eider la perform in-'si d treatments. an apparatus to ,s
delivery Is Se2ded.'I'be Moir: common and practical is avec!
inje Lion rod hiked -into the son which causes preferential
pathways when mai:dais hen forced transits terminus, then
along die interface between the rod and the *soil. Thaw
pathways prevent efdent application of remedial Materials 69
to the target zone. lb alleviate ibis problem; t hbllow
injection rod tyith lateral discharge holes atlown fof liquids
to be Injected into the contaminated matcvia) ,and. itien
performed well in.nitu injections ore not only priait j bur
Rho very economical. However, problems csitt.tFtex,-ample as
switching between Feed systems cmnoi bi a:-irminp?s6ed
without loss of pleurae to the delivery line. The reseili g.
2
vaahemt es<uses the delivery pathways Id class and results in
rcddnhd lateral dlstnhution al delivered materials. iI is
because or tbetso rrinbTpiits eicpeRenrnd from the vacuum
des loped downhole et pa** Is aclr d and nmpplied
S du.niarty remedial tychaologivxfall wbei linailuonal from
laboratory to fled application. TUis is a problem shot is
farther'cxaee!rbaied when it is desired to deliver dissimilar
compounds sequentially tor appropriate mediation 10
to °`'cue
SUMMARY OF THE INVEisrFiON
The appliennts have devised a chased pn:ssvriacd debr-
is my system for Err=gilu delivery far aais•antil remediation
euinipounds in underground eimlam1npted ma[iee which
includes first a Iialijid di'epiragm pump.conbeesed to an
Inflow source of water. liar liquid diaphragm pump being
also in fluid communication with a plurality of bioslurry
'-a tangs connected En para1Fel. the b asiuny tanks each having
a drain Wive means ate located bctiveen she first liquid
dtaohragm pnoip and each of the isidsiuriy tanks for can-
trolfiog either the alternate er simultaneous Flow or flint
front the first pump to each or the biosWiry' tanks. A seeped
licpuiddtaphro mjium having an inlet p g past for receiving the
eambined COW of the biosturry tanks has an outlet in Auld
tcriununtcation with a system dlwehale prat. The system
tardier includes a sousee of compressed gas in Auid cant-
o msraication with the discharge pun. A discharge rod IS
capbected to the dischnrae post far delivery or remedial
fluids to underground sails.A gas pressure line leads from e
Shur= of comprexsed gas kasha discharge port and is also in
Auld communication with a plurality of feed tanks far
storage of injectants under pressure. the fad talks being
individually pressurized by the selective fluid communica-
tion with the pressure line. Each feed tank includes a
sopacately valved exhaust port connected to the system
disebaoge.port such that the shame or fagectant may be
a switched From the bicslwry tanks to any of rise feed tanks
without loss of delivery pressure, The source ofprt'ssitrized
gas nay be n mechanical compressor or a stored compressed
Th6 shove- described dosed deliv iy dysicrn utill= a
combination bf gat and liquid delivery systems in '41c1 all
deIiVeiy vestals are insefcortoxted and valved. allowing for
Mixtngi, washings. 'dud discharge of materials via
• pressurized delivery vessels and mechanical puinping Sys
tens. The system utilized allnryi for o variety of dissmuuar
certipt{un_ds to be delivered via a single injection line.
Ftzirteeu the switching between feed systems is amain -
Fleshed without any loss of presses to the delivery line
eliminating the common prableras ekpericnced from the
vne+nm developed dowp-hale ag prmsme is released and
reapplied: The deadly.. and thus the field sums of the
syssem:is due Ea the unique Configuration of gas and liquid
feed systems allowing for greaser horizontal Infiltration
heloiv'grade and delivery to low.pe'rmeabiltty coifs such as
edmpaetod clay} which' Es tbbUilY accomplished. Lastly, she
concha system may be mounted In a mobile trailer. being
(a11y self-contained and requiring no electrical external
supply. The only site utility requiaG»mt is an available
miner sperm for slurry preparation. Other objects and advan-
tages of the present invention will be readily apparcnt'ro
dense of skill in the art from the following drawing and
description of the preferred embodiment.

US 7.044,152 B2
3
BRIEF DliketIPTION OriTIE DRAWINGS
Rd. I is n dogram of the present invention.
•
DETAILED Doc:RR-rim OF THE 5
PREMIlieL1t1dBODIMENT
Referring MM. tri EC. L a preferred apparatus is shown
far sirrying out the ahO.Ve:deserilnd plOccis. The tiiiection
De now is indanal by arra.' where Opptithrh.thar A Oa- in
Tenth:dal iniCqsr.rOds.27 WI -known intim cid suitablefor
sujisoli "mjeetions is :ideated to an injection In in fluid
commnaication with the iliseharis pad 25., The .0r4rd syt•
tem Is mounted in fnabile.traiter'24,. •
Try bintekediction aisporatus a' thhitivendsth untulithes Ls
Ito read ranks. TI and 12: Ma biosiarry*ks. LTI and
LT7.; liquid diaphragm pomp. and n Semnd liquid
chaphragen pump. P2: a sit compressor: and nu- air storage
P. liquid feed line front en outside water source is
attached maim liquid &Threw punt?. Pi. The liquid feed m
[Mot am also conhemed 113 Mateo hindurry tugs. L11 mad
L17.. From the two hioslurry tanks. LT1 nod LI2. a liquid
feed line runs to the diaphragni sump. P3. The liquid feed
line then runs tO diem Cud ranks. T1 nodT2. and out the
discharge PM 2.5.•
',think( air line 21 Is attached to the gat compressee. A
gas preasure line is attached from the gas compresmr to the
Iiquddop1oom pump Pl to [hemp feed =lat. T1 andT2.
11114 dill the discharge pod 23. All of the lines Are valved.
mixingswashings. filling. and discharge of So
panniers. Valve VI Is located within the gas line meting -
front the gana compressor toward the outlet Vi and V3 are
valves to rite Smith Mt marling I. reed oinks TI and 12.
Valid V4 is thiAllid line controlling the flow from pump
Valves V3 and Vd am located within the liquid feed line Xi.
conuolling hovie. nom litosludy tales g.TI and L12. Vi and
Vgthc Avid loeitvaires contmlling Bows Into tanks LTI
and E.T2. 11910 the &kludge !rabic controflin,g all flow going
out Or the tidier. VIM and VII are gns feed val vas control-
ling gas flow into Teed teaks T1 and 12. .11)
The' system 10 numbed io an injection rod 27 which is a
hollow. cylindrical pipe that has been drilled M sip; of
uongrroued erd.ritaninetiOn will, a flexible pressure host.
Under high gas metstue: the lejection Ind Is capable of
injecting hurikental 6:1 venlial pathways undergrowth. as
bcith deep andshalloW depths.The meal injectionind has
a mei tip usod for drilling.1n order for the high 'pressure
stresnis of liquid 10 bt injeCted &Ind has a series of ports
drilled i100 the lower end or the rod. The irtieetamte mut
therefore be Injected in any dirdation. SO
A specific operation if the apparatus according to one
embodiment of the invention nutEc fanheidescrilied in
conjunction with the fallowing promo. The pikes begins
by first filling the hinsluny tanks LT1 andi.T2 and the feed
=lull and 22. A sou= °nitrogen Is connected to Inlet ss
21 MA a water:supply is mamma io Liquid Min 23. Valves '
V7aad.V8 are opened which engage an 010101(0201001111010
11(1 bidolorry oinks LT1 and L22. A micto-nutdentsizodium
sulfate is then manually added% the hiorlorry tanks LT1 and
LT2 and allowed to taix. Valves V7 and V6 are shot along an
with disengaging the actuator when the bioslurry tanks are
filled.
The. inletiant pripothtion phase Continnite as a pre -mixed
heated lactate Inchiding;funnitts B2 art4 111210 •PirSitiP)i
poured intd1ithkTL Valves VI14. V3. ma V6 are as
kheitopened. Nan pump P2 la activated mid mania fillql
with an Oppropdaii Vhlurne Odic bind:wry. All valves are
4
eirecd when finished. h.lmot. Zala Went Iron is martually
added end mixed with die Itholurry kites* It They* are
thug Secured .r Valk read "tan17 71and 72 and afterward
tutees V 10 and VII are opened to niZt both tdnd
hugs A110(th jojhlhilil dad too been pmpetiy placed m
selected locafinn_ the injection line is secured to discharge
pan 16 and lialye V9 is. opened.
With the inject= prepandion phase cOmpfel4 the injec-
tion Phise of the process begins. Valve VI is upend to
=le injection pahtsays until 3 significant prcesure drop is
obScifriti ot the Evjecalun pressure res.vel 31 which is filled
scum of compressed gms. preferably alter rarer
pm or carbon dioxide. Valve VI is then Closed and valor V3
lipteled fo introduce the ram velem itorJitioslurry mixture
into the subsurface puhuayx them rcvd twin_ Valve V3
is quiet when feed Milk 72 10 erapty. Next. toite V2 is
opened It introduce the literate mixture into the dauturfact
!Min lank T1 pail is closed 311.er it Ls empty. it wilt t•
undCmload by those of skill in divan thin snitching between
tidier the feed MOO nr the biodurry tanks arms without
loon of Presseno in the injection line therefore avoiding any
dowathold vacuum that would otherwise be aperienced in
switching from the detivety of ace compound to loud=
This is an impontun aspect of the imention.
Thin, tapes y4, VS. and V6 are opened to directly
deliver bioslurry from tanks LT1 and /13 into the subset -
Ail ,eidves are closed when the desired amount of
biashery has heart injected. Fnally. in order to dram the
injection ilk. of the viscous pniyhtlate estox. a redLICiag
agent IE °fie again injected. With ills ideal= crintplife.
pest injection line purge is perforrned. The gas is ittlemeti 10
clear the lifts of any remaining reducing agents. With the
lines cleaned the proems is complete and the next injection
location Ls prepared.
ir should he taiderMead that thm may be other tne&6'
Wens and changes to the present inversion dial will be
obvious to those of dill in the art ficrinj100 foregoing
&mission. however. the present invernitart Amid be lim-
ited only hy the rollowing claims and their legal equivalents.
What is claimed is:
I. A dozed. pressarixed &Suety system for injectinn of
in,sitnternediation compounds such as :slurries. stimulants.
*dents. binlogleal cultures. colloidal suspensions. =Wiz -
Ina. agents. reducing agents and 2TITIIINCo of compounds to
Iniderinatirid. contaminated manta comprising
a Firm liquid cloplinwin pump connected to an inflow
Warne of water. said liquid diaphragm pump being in
fluid carinntionication with a plurality ljrbic.IUET7 tanks
connected In parallel with said first pump. said big -
Mini). oinks each having a drain for discharging an
injectam therefrom:
valtu means towed between said him liquid diaphragm
pump sad each Of iaid biodurry in* for controlling
eitliej the individual or simultaneous flocs ffuld from
said first pump to each of sald biodurry utast
* second liquid diaphragm pump having an Wet pan for
receiving the combined flow of injecianl from said
hinsharry tank drains. the second liquid diaphragm
pomp basing an Mkt In Mild communication with a
system discharge port and
a :duke of tamp:so:al gas in valved fluid cornmunica.
lion with said system discharge poft Whereby an
injectunt 10 dkaargcd therefrom under pressure.
2. The delivery system of claim 1 further ideloding an
injection rod in fluid communication with said total system
discharge port for the delivery of remedial fluids to under-
ground soils.
3
Pro
said
rah.
=it
301:11
can
011
fcec
suer

US 7,044,152 B2
- -5
3. The delivery system of claim 2 further iocladirs4 gat
pressure find lea ln front said wun a of compressed gas to
said system discharge port. the line also being in separate
raked fluid mmmrtafralfoa'whh.ua ch ore plurality of feed
tanks (arsterage of Tojeemm tandei pressure, said feed ranks s
each im:ladrna a separately valved exhaust port in Rued
eoinmrmieetion with safdsystem discharge pan such that the
souse of Niemen by operation of the exhaust part valves.
6
S. The deliitery system of claim 4 whereia.said stxerce of
prissuifzed gas is delivered by a mechanical compacisor.
6. The delivery system of claim 4 wherein tmid source of
pryasiuihxd ens is a atpred-compressed gas souse.
7. T1ie apppmus eecording to delta 1 wherein the liquid
dIpphrkrn piriaja bldshi a lacks. enmprrra or. diaphragm
pump and feed tanks ore mounted is a mobile troller such
cmh be changed Porn one rant: to another without loss or th24 entire faprtional dosed injxtion delivery syghem
delivery prestos to Moil fratup"oricd o a MIL,
4. The delivery system bf claim ,i wherein each of said
feed tanks is in fluid communication with said pressure lines
suet that chch tank may be individdally Pie iuized.
4 • V 0 0

ri re” 5 R e
US0071293(813.2
Tinted States Patent (50) Patent gat US 7,124,388 B2
Scald et al. (4s) Date or Patent Oct. k, 2006
(S9 7.117i1OD occLRAIs
DSCpLOENATION OF MATTO.
invcolom httbsti 55113114551Cawa. PA OA:
Vidilkftese, We:W:03a, on (up ,
(3) Anis. Ibrovativo genistoue!one4
Ikr,liobloties. Zoe, Boyilittrare, PA
&ilea tamarr 6the lament&
wait r &1 oadjosior.uxidaf 15
U.S.a 454(b) by 597 dad.
(20 Appl. bra: 18%10,3511
( 1.22O3
05) Prior Putt/cation Daft
US Z[001:1309 Al Ail, 0. 2004
Piloted U.S.AgpThzkiloo Data
Proririaista appliedca 40/437.93). 9* ha.
soots.
(51) TnI...
A62D (204.01)
Mil tl& U. AVIA 51311402; A'1381105
iStr) er gtania nano.
599415, I i018;919, SWATe.„ 464.415.
58=61; 4231241119.240S
See opplieatba Ala tar ecerVIcle isth 1316*.
(50 Relbrenet4 Ctitel
U.S. marrbticipaprrs
4,4810 A 12/034 WOO*,
5,2)Killt A WM) iCor.cledcri cd.
5,277.315 A 1/1594 Beecooi
(f) ?(o1Ie
iy4.11,10 A S71993 &tech cl
5.6C42096 A =SW mod 44.
4.1113.333 A WINE Set.eAcca
3975,7111- A 1111999 INtiAta
6.0511X7A 54M0 Zismen ft a
6,I50.157 A 11/2953 IA15ztsi1.
6.113419 P5 SCdOX rpm=
6.1.1tn, 131 6.2.421 UsaaS0
641SM al 21252.1 SAigro et all.
0.1$zt 711511 Me= a a
existr at Irma ntaind.
6012404111 rum t reek(
.043.335131 vitral Mee ;ant
4420434 B1 moat F56id '
4.46y61 331 1012901 Marva
6,64.193131. Imo* seaqdd a
hinter/ &miner —Biwa )& Mason
Atfon.)5 Armt Qr FEed—rg3/34 1 oice
(57) Axstma
Accelerated eleeilleduatiorl of loB 52d9rXU ogituoilaucl
viihrht,4P,cdicdvqlfshuNcicabYithindleat laitro-
brOitczoorganisaa and &us ircoiailat tho tato of biologi-
617 Aiiipmble;na at the solTaxta.nis ozCoal bY
a tzeziioaat Fccosa cocas ting of tkiol8,01..itapealloa.nf
leerapoor.do;pbly*abz, "ftee. pates eyotml tripAylartatc„,
icab*rix arzi lithiagYbeitaia.
cbeerdcalotygratccavatteip la plait= whitens/dial azari-
ma. and vitamin gimollatv tuela pf32 p.4.1)313 de1Iien51
via coropthateci gas4v C0.2 fa as aat,I3 axygerque. an
cayfrci;:geottargelidkaeaverolicpreee,th..7.12i-Bpacibit
edaraliteenizzallyogperitialerwiginIszai arlaiikcalcIfe- •
lag diisblved pint WO competkat %tithe Wiwi:cep
or tbo Iron pacittelel raialtiag la 115 brEakdelva or Ctioi-
wed solouds itigh ititriclilorootheae. alehloioetbent,
iiuniaortaaan llslrdaughter
t Tefras, I Drawing Shed

APPENDIX 4:
DIAGRAMS AND PHOTOGRAPHS OF INJECTION SYSTEM

Equipment Discussion Injection Trailer.
Written Description of Physical System: _
The development of the Innovative Environmental Technologies, Inc (IET) delivery system has been a genesis.
Innovative Environmental Technologies, Inc. beganwith the injection of biological augmentation and
stimulation compounds in 1997. The fast systems utilized off -the -shelf pumping systems, however there were
several issues encounter with the systems' application in the field. Most of the pumping systems utilized
developed only minimal lateral infiltration and frequently produced vertical pathways for the introduced liquids.
Based on the field experiences of the early systems, the most current delivery system utiti7es a combination of
gas and liquid delivery systems. All of the vessels are interconnected and valved, allowing for mixings,
washing, filling and discharge of materials via pressure vessels or mechanical pumping systems. The field
system to be utilized in the New Athens project, delivering biological stimulation products, allows for a variety
of dissimilar compounds to be delivered via a single injection line. Further, switching between feed systems is
accomplished without any loss of pressure to the delivery line eliminating the common problems experienced
from the vacuum developed down -hole as pressure is released and reapplied. Lastly, the current system is fully
self-contained requiring no electrical supply. The only site utility requirement is an available water source for
slurry preparation.
The value of the interconnection of the liquid and gas systems has been demonstrated at a variety of sites where
effective delivery of remedial agents necessitated alternating pulsing between the liquid and gas phases. In
many of the applications, where heating of the delivered compound(s) to temperatures in excess of 180°
Fahrenheit was necessary to accomplish optimal lateral delivery the system has performed flawlessly.
By utilizing the Innovative Environmental Technologies, Inc. system a variety of liquids, gases and colloidal
suspensions may be effectively delivered to targeted hydro geological zones at pressures, which allow for
maximum lateral penetration without the creation of new subsurface fractures. To date Innovative
Environmental Technologies has injected via the system lactates, nutrient augmentation packages, liquid
heterotrophs, colloidal iron suspensions, oxygen scavenger compounds, BRC, ORC, calcium peroxide,
hydrogen peroxide and viscous liquids. These materials were delivered via the on -board compressor and
external nitrogen tank wagons. Future projects shall also utilize other gases as required by the specific sites'
subsurface inorganic and organic chemical characteristics.
Discussion of the IET In -Situ Multi Phase Delivery System
Critical Elements:
1) One Champion Compressor with 20 gallon air storage.tank, compressed air generation of 25 CFM @ 175
psig.
2) Two 17-gallon pressure vessels with 4" sealing access through the top of the vessel.
3) One 60 gallon compressed gas storage vessel, Rated for 200 psig, with 175 psig relieve valve.
4) One 300 gallon Polypropylene horizontal liquid storage tank
5) One 175 gallon Polypropylene horizontal liquid storage tank
6) One Warren Rupp, 2" Air driven, Stainless Steel Ball Pump (maximum discharge rate 50 GPM..
7) Motorized Bali Valves— liquid Side
8) Normally closed solenoid --Air pump control
9) Two submersible circulation pumps for liquid storage tanks
10) 18' CarMate, dual Axle trailer (7000 lb capacity)
11) Carrier Air conditioner/beater
The IET, dual phase injection system is capable of storing approximately 16 cubic feet of 175-psig gas, the addition
of a second storage tank would increase the system's storage capacity to approximately 25 cubic feet. Under most
applications the current gas volume is adequate to establish in -situ void space sufficient to accept between 100 and
125 gallons of remedial fluids. When using an external gas supply, gas volume is not an operating issue. The

Warren Rupp liquid delivery pump is capable of delivering a variety of liquids at pressures up to 100 psig.
Innovative Environmental Technologies, Inc. supports the injection trailer with a second storage trailer and an
external bulk water tank. Water is transferred to the injection trailer via a 100-gpm gas powered pump.
As currently configrred, the system is capable of delivering a single batch injection consisting of up to 30 gallons of
colloidal suspension or 30 gallons of heated viscous liquid (175 psig.) in conjunction with 475 gallons of pumped
liquid (100 psig.). The 30 gallon high pressure, compressed gas driven, capacity is divided between two tanks,
allowing for mixtures of colloidal suspensions and viscous liquids if necessary.
In that the system maintains a constant pressure to the injection zone, additional colloidal and viscous liquid volume
may be achieved for any injection event by valving off individual feed tanks while maintaining constant dawn -hole
pressure to the injection zone.
At this time the current configuration has not been found to limit the remedial practioner's flexibility with regard to
the introducing varied liquid or gaseous materials. It is recognized that the current design requires the heating of
viscous liquids outside of the vessels, limiting the volume of heated viscous liquid injection to the capacity of the
external water bath and the heat transfer rate between the bath and the injectant.
MO`13
szg
7
MO11
,0
xeio oar s9Z
-Jassaidatoal SSf'J
wssaddnon
t dFeed Tank ft
r
2 M
45
MOl3
�
g
BIOSLURRY
ltgddFeedtap,
estAtigawzwarin
Mobile Treatment Trailer Design
In -situ Delivery System d Flow Diagram
Innovative Environmental Technologies, Inc.

Innovative Environmental Technologies, Inc.
Patented 18' Injection Trailer
This self-contained mobile injection unit has the capability of delivering a
wide variety of remedial components in a safe, efficient, and economical
manner.
This unit contains the following equipment:
• Onboard Air compressor
• Onboard 8 kw generator
• Commonly plumbed stainless steel feed system
• Pressurized safety shower and eye wash station
• Built-in secondary containment system to avoid spillage
• 2 —110 gallon conical mixing tanks
• 2 —150 gallon bulk feed tank
• 2 — 20 gallon pressurized injection tanks
• 120 gallon capacity compressed air/gas storage

SOURCE: IMAGE COURTESY OF VVVWV.TERRASERVER-USA.COM
1
.00A
E 8
2725 E. Millbrook Road, Ste 121
Raleigh, NC 27604
I NC [phone]
PROJECT NO: 45.34341.9233
DATE: 4/15/2008
ISCALE: 1"=850' REVIEWED BY: SDM
Figure 1
SITE LOCATION MAP
Courtesy Cleaners
8111 Creedmoor Road
Raleigh, Wake County, North Carolina
DSCA # 92-0033

PARKING AREA
LEGEND
O = MONITORING WELL LOCATION
®T DIRECT -PUSH GROUNDWATER SAMPLE LOCATION
CANOPY
PARKING AREA
PARKING AREA[11
1 STORY BRICK
COURTESY
®GW-7 CLEANERS
MW5 0 ED
GW-6
APPROXrMATE SCALE IN FEET
MW2 co 9 MW1
GW-8®GW-1
r
MW4
e
PARKING
AREA
GW-3

SOURCE: Wake County GIS Website
• Private Well Locations
• Abandoned Private Well Locations
• Public Well Locations
— 0.5 mile radius
500 foot radius
*
vT
A$$ O C I n T E 8
2725 E. Millbrook Road, Ste 121
Raleigh, NC 27604
I N C. [phone]
PROJECT NO: 45.34341.9233
SCALE 1" = 185'
DATE: 4/1/2009
REVIEWED BY: GA
FIGURE 3
WATER SUPPLY WELL LOCATIONS
COURTESY CLEANERS
8111 CREEDMOOR ROAD
RALEIGH, NORTH CAROLINA
DSCA SITE #92-0033

o CANOPY
V)
MW6
453.50
PARKING AREA
LEGEND
= MONITORING WELL LOCATION
453.50 = GROUNDWATER ELEVATION IN FEET
- GROUNDWATER ELEVATION CONTOUR (DASHED WHERE APPROXIMATE)
= GROUNDWATER FLOW DIRECTION
MW7
453.82
PARKING AREA
50
1 STORY BRICK
0
M W5 al
454.13
30
60
APPR0XMATE SCALE IN FEET
PARKING AREA
M W4
454.99
PARKING
AREA
COU.TESY
CLEA ERS
M W1MW(�
454.28 454.43v
DW1 MW3
454.13
454.32
P/A
N
LLI
CD
GROUNDWATER ELEVATION CONTOUR MAP
0
0
CV
U
(f)
0
0
0
w Q:
zo
'x:(4.1
U
Ct
>- W
I- C.)
C
O f-
RALEIGH, NORTH CAROLINA
g
0
0
0
CONSTRUCT
c

NOTES:
1. GROUNDWATER SAMPLES COLLECTED 05/07/09
2. DEEP WELL DW-1 NOT USED TO CONSTRUCT
CONTOURS.
,FIGURE 5
PCE ISOCONCENTRAT!ON CONTOUR MAP (MAY, 2009)
COURTESY CLEANERS DSCA #92-0033
8111 CREEDMOOR ROAD
RALEIGH, NORTH CAROLINA
Project Number: 45.34341.9233
Drawing Fife:
Dote:
07/17/09
Scale:
AS SHOWN
TVITC
ASSOCIATES INC
Orn. By: LB
Ckd. By:
App'd By: AW
Figure
5

EL GENO
�W)
PARKING AREA
= MONITORING WELL LOCATION
= SOIL BORING LOCATION
U
PARKING AREA
so
1 STORY BRICK
0
so
APPROmW7E SCALE IN FEET
PARKING AREA
COURTESY
CLEANERS
GP4
GEOLOGIC CROSS SECTION A -A'
COURTESY CLEANERS DSCA #92-0033
8111 CREEDMOOR ROAD
RALEIGH, NORTH CAROLINA
project Nurnber:
45.3434 7.9233
Orn, Sr
L8
Oro.nnq far
3434 T. DWG
Ckd. By -
Dole:
03/03/08
scale:
AS SHOWN
(Vcrc
Ma'o By:
• 5 S O C i A T E 5 I N C.
Figure
6

A
MW-6 DW-1
480T (479 71) 7. (4 )
AVA A MIVAI AMI AIRMOrA...�A//.�.I AvA 7 36--mar dr
470 ---�
460-
450
440 -
430 -
420-
410 -
400 -
390
380
S LTY SAND/SANDY SILT
MW-6 GROUNDWATER (mg/L)
TETRACHLOROETHENE
<0.0007
CHLOROFORM
0.00072J
LEGEND
MW 1 - WELL 1NDENTIFICATION
(478 78) roa OF CASING (FT.)
WELL CASING
WELL SCREEN
- = WATER TABLE
SILTY SAND _
WEATHERED
BEDROCK
SILTY SAND
DW— 1
GROUNDWATER (mg/L)
TETRACHLOROETHENE j<0.0007
MW-1
(4 78.78)
SILTY SAND'
MW-1 GROUNDWATER (mg/L)
TETRACHLOROETHENE
0.34
TRICHLOROETHENE
0.088
CIS-1,2—DICHLOROETHYLENE
0.07
60
GP-3
GROUND
ELEVATION
479 02
A'
MW-4
(4 78.99)
SILTY SAND
SILTY CLAY
SILTY SAND
EXTENT OF CHLORINATED
SOLVENT PLUME
MW-4 GROUNDWATER (mg/L)
TETRACHLOROETHENE
<0.0007
1,2—D1CHL0R0ETHANE
0.00046J
CHLOROFORM
0.00037J
0
30
60
0
0
0
f
APPROXIMATE HORIZONTAL SCALE IN FEET
i
i
SCALE IN FEET
APPROXIMATE VERTICAL

PARKING AREA
LEGEND
O = MONITORING WELL LOCATION
®= DIRECT —PUSH GROUNDWATER SAMPLE LOCATION
PARKING AREA
0
MW7
40
STORY BRICK
MW5®®
GW-6
APPROXlM4TE SCALE IN FEET
MW
GW
DW1
PARKING AREA
COURTESY
CLEANERS
MW3
®GW-2
M W4
0
PARKING
AREA
®GW-3
PROPOSED INJECTION AREA
(1,200 sq.ft.)
U
GW
N
P
80

North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Coleen H. Sullins Dee Freeman
Governor Director Secretary
April 12, 2011
Petitioner for DSCA Site 92-0033
DSCA Program
1646 Mail Service Center
Raleigh, NC 27699-1646
Ref: Issuance of Injection Permit WI0500248
Courtesy Cleaners Site
Raleigh, Wake County, North Carolina.
, Dear Sir or Madam:
In accordance with the application received on April 13, 2010 and subsequent information received September 1,
December 9, 2010, and March 3, 2011, we are forwarding permit number WI0500248. This permit is_ to inject a solution
composed of Hydrogen Release Compound, zero valent iron, EHC, a vitamin and nutrient, mixture, and propionate to
remediate groundwater contaminated with chlorinated solvents at the Courtesy Cleaners facility. This permit shall be
effective from the date of issuance until March 31, 2013, and shall be subject to the conditions and limitations stated
therein, including the requirement to submit a final project evaluation as stated in PART VII — MONITORING AND
REPORTING REQUIREMENTS. Please note that some of the monitoring requirements have changed from your
application. Please read the entire permit to ensure that you are aware of all compliance requirements of the permit.
You will need to notify this office by telephone 48 hours prior to initiation of operation of the facility. In order to
continue uninterrtrpted 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 [phone] or at [e-mail] if you
have any questions about your permit.
cc: Jay Zimmerman, Raleigh Regional Office
Gabriel Araos, P.E., ATC Associates of North Carolina
Scott Stupak, NCDENR DWM Superfund Section
WI0500248 Permit File
AQUIFER PROTECTION SECTION
1636 Mail Service Center, Raleigh, North Carolina 27699-1636
Location` 2728 Capital Boulevard, Raleigh. North Carolina 27604
Phone: [phone] s FAX 1: 919-715-0588; FAX 2` 919-715-6048 i Customer Service:.1-877-623-6748
Internet: www.ncwatemuality.ora
Best Regards,
John R. McCray
Environmental Specialist
One
IN orthCarolina
An Eeual Ooinriunny ; Afnrmative Action Emp`oye-

Mccra , John
From: Gabe Araos [[e-mail]]
Sent: Thursday, March 03, 2011 9:19 AM
To: Mccray, John
Subject: RE: Courtesy Cleaners application
. John,
Did you receive my voice mail message about the monitoring wells? The DSCA case manager agreed with your request
for the new well.
Thanks
Gabe
From: Mccray, John jmailtoaohn.mccrayOncdenr.govl
Sent: Friday, February 11, 2011 12:27 PM
To: araos45Caatc-enviro.com •
Cc: [e-mail]
Subject: Courtesy Cleaners application
Mr. Araos,
Have you received an ok from DSCA to install a new.down-gradient monitoring.well for the proposed Courtesy Cleaner
injection, plan? I am finishing the application and hope to have everything ready for issuance next week.
Best Regards,
John McCray
1

Mccray, John
From: Gabe Araos [[e-mail]]
Sent: Thursday, December 09, 2010 3:11 PM
To: Mccray, John
Subject: RE: Additional Information request for Courtesy Cleaners Injection Permit
Attachments: injection Permit Info Memo rev (2).doc; Courtesy Cleaners Proposal rev.pdf
John,
Sorry about that. We forwarded your request to Scott Stupak at DSCA regarding the additional wells and we are still
waiting for his response. Attached are two documents with the HRC concentration (Injection Permit Info Memo) and the
correct Ca -Propionate calculation (Courtesy Cleaners Proposal).
Thanks
Gabe
From: Mccray, John Lmailto:[e-mail]
Sent: Thursday, December 09, 2010 2:54 PM
To: [e-mail]
Cc: [e-mail]
Subject: FW: Addition! Information request for Courtesy Cleaners Injection Permit
Mr. Araos,
I sent this email to you on October 29 and received an automated "Out -of -Office" email. I since have not received a
response to the matters addressed within the email. Please provide the information as soon as possible so that I may
finalize the permit.
Best Regards,
John McCray
From: Mccray, John
Sent: Friday, October 29, 2010 2:51 PM
To: '[e-mail]'
Subject: RE: Additional Information request for Courtesy Cleaners Injection Permit
Mr. Araos,
I am preparing to write the permit for the Courtesy Cleaners site and noticed that I have some additional information
needs. We are requiring an additional downgradient monitoring well to the west of MW-2 and should be located
outside of the radius of influence of the injection, but at approximately one year's travel distance from the injection
zone. Please provide a plan view of the site and include the new monitoring well.
Provide a concentration for HRC, as there is not one available in the tables provided in Appendix 2.
The tables in Appendix 2 list concentrations for Ca -Propionate, but the calculations provided on page 13 by IET, Inc. use
Sodium Propionate to determine the estimated Hydrogen Demand. Are these two compounds comparable in this
application or do the calculations need to be adjusted?
1

, Let me know if you need a letter stat:':.o J u r information needs. If we receive the , rmation quickly, I anticipate this
permit getting issued by the end of next week.
Best Regards,
John McCray
From: Gabe Araos [mailto:araos45(atc-enviro.coml
Sent: Wednesday, September 01, 2010 10:57 AM
To: Mccray, John
Subject: RE: Additional Information request for Courtesy Cleaners Injection Permit
John,
Attached are the revised pages as per your email. Do you want a hard copy via regular mail?
Thanks
Gabe
From: Mccray, John [ma ilto:[e-mail]
Sent: Monday, August 30, 2010 11:26 AM
To: [e-mail]; [e-mail]
Subject: Additional Information request for Courtesy Cleaners Injection Permit
Ms. Olson,
I have completed the review for UIC permit application W10500248 and need one minor correction. Page 1 of 7 of the
application doesn't require the property owner information since the Petitioner is the owner, and since ATC has been
awarded the contract for site activities and has provided documentation of the contract, the signature of the Owner
granting consent is not required either. Attached is an additional information request asking for a resubmittal of the
two pages of the application without the unnecessary information. A response by email is sufficient and hopefully will
expedite the issuance of the permit.
Best Regards,
John McCray
2

fATIVF ENVIRONMENTAL TECHNOLOGIC, x
Proposal to Perform In -Situ Reductive Dechlorination
of Soil and Groundwater via Synergistic Technologies
to
ATC Associates
For
Courtesy Cleaners
Raleigh, NC
Revised October 2009
Innovative Environmental Technologies, Inc.
6130 Kit Road
Pipersville, PA 18947
[phone]

RTC Associates — Courtesy Cleaners
Page 2
October 16, 2009
ATC Associates
Gabe Araos
Dear Mr. Araos:
Innovative Environmental Technologies Inc. (IET) has completed a remedial design and
quotation for the site, Courtesy Cleaners, located in Raleigh, NC. The site has been identified as
having impacted soils and groundwater due to the historic use of tetrachloroethene (PCE). The
presence of PCE's daughter products, such as trichloroethene (TCE), cis-1,2-dichloroethene (cis-
1,2-DCE) and vinyl chloride (VC) were identified in the data analysis. The concentrations of
these contaminates is such that reductive dechlorination is taking place at a rate that needs to
be stimulated, both abiotically and biotically. As a result of IET's evaluation of the historical
data, boring logs and field analyses, a design which will promote and ;accelerate reductive
dechlorination in the subsurface is being proposed. A 1,200 square foot source area treatment
is being proposed at the Courtesy Cleaners site. The following proposal will set -forth a lump
sum price for the design, implementation and follow up of this process. All costs included in the
lump sum price are listed below.
• All materials necessary to complete the proposed plan
• All equipment and personnel required to execute the proposed plan
• Handling and Management of materials on site
• Mobilization/Demobilization of the injection crews
• All per diem for the required crews
• Site Restoration
• Final field injection report
• Final plot of injection points
• Six quarterly data analysis reports

ATC Associates - Courtesy Cleaners
Page 3
Table of Contents
OBJECTIVE 7
AREA A 8
SCOPE OF SERVICES 8
SUMMARY 9
Recommended Sampling• 10
APPENDICES• 10
APPENDIX 1 (SITE MAP) 11
APPENDIX 2 (CALCULATION SHEETS) 12

ATC Associates — Courtesy Cleaners
Page 4
TECHNOLOGY DISCUSSION
The options available for a cost-effective and reliable technology to treat chlorinated
hydrocarbon contaminants such ,as tetrachloroethene (PCE), trichloroethene (TCE), cis-1,2-
dichlorethene (cis-1,2-DCE), and carbon tetrachloride in groundwater have in recent years
moved away from traditional pump -and -treat processes, especially in cases where:
• NAPL, micro -emulsions or'high concentration adsorbed materials are present leading to
high dissolved phase concentrations.
• Access to groundwater is restricted by surface structures or uses.
• Local restrictions forbid the implementation of other available technologies such as air
sparging or natural attenuation.
• Pump and Treat technologies have been applied, but have reached asymptotic removal
rates.
• Contamination is extensive and concentrations are too high for risk based closure but
otherwise relatively low (typically 100-7500 ppb).
• The migration of dissolved Chlorinated Aliphatic Compounds (CAHs) across property
boundaries or into adjacent surface water • presents a - long-term remediation
requirement.
• The vertical migration of free phase CAHs (DNAPL) into underlying drinking water
aquifers is a concern.
The environmental chemistry of a site in part determines the rate of biodegradation of
chlorinated solvents at that site. The initial metabolism of chlorinated solvents such as
chloroethenes and chloroethanes in ground water usually involves a biochemical process
described as sequential reductive dechlorination. The occurrence of different types and
concentrations of electron donors such as native organic matter, and electron acceptors such as
oxygen and chlorinated solvents, determines to a large degree the extent to which reductive
dechlorination occurs during the natural attenuation of a site. To accelerate the natural
processes, ZVI and enhanced microbial dechlorination processes are proposed to be utilized at
the site. The utilization of coenzymes, oxygen scavengers and nutrients insures that little or no
lag phase in the process is experienced and that the most efficient pathways may be utilized.
Reductive dechlorination only occurs in the absence of oxygen; and, the chlorinated solvent
actually substitutes for oxygen in the physiology of the microorganisms carrying out the process.
As a result of the use of the chlorinated solvent during this physiological process it is at least in
part dechlorinated. The site shall have introduced to the subsurface an oxygen scavenger to
ensure that this process would occur immediately. Further, recent studies suggest that metal —
containing coenzymes, found in certain types of anaerobic microorganisms, and can reductively
dechlorinate one- and two -carbon solvents. Cobalt -containing corrinoid cofactors such as
vitamin B12 mediate the reductive dechlorination of carbon tetrachloride and
tetrachloroethene. In these biological systems the rate -limiting step to complete dechlorination
to ethylene is the last stage conversion of vinyl chloride. The rate of that process has been found
to be significantly enhanced by the presence of vitamin 1312, which acts as an electron carrier. It

ATC Associates —Courtesy Cleaners
Page 5
is the core of B12, which contains cobalt, and the various oxidation states the cobalt obtains,
which allows for the electron transfer intra-cellularly. The existence of the cobalt core has also
been seen to catalyze the surface reaction of the iron lowering the necessary activation energy
required for the electron transfer.
Zero Valent Iron chemically may be thought of having been the product of the positively charged
metal ions receiving electrons to become the electrically neutral pure metal. The term
"reduction" is applied to any chemical reaction that added electrons to an element. Thus ZVI is a
reduced material. In a similar manner, the chemical term "oxidation" refers to any chemical
reaction that,. removes electrons from a material. For a material to be reduced, some other
material must be oxidized. in the reduction of a chlorinated compound the zero valent iron is
oxidized. Zero valent iron enhanced abiotic degradation of chlorinated volatile organic
compounds (CVOCs) is essentially a reductive dechlorination process, which uses granular cast
iron as the reducing agent, and produces final reaction products such as ethane, ethene, and
chloride ions in the degradation of TCE. During this treatment process, the corrosion of iron by
water dominates the chemical processes. The corrosion of iron by water results in ferrous ion
generation, hydroxyl ion generation, and hydrogen gas generation. This results in a decrease in
ORP (oxidation/reduction potential; that is, reducing conditions are produced) and an increase
in pH. Accordingly, the end products of this reaction are ferrous iron, chloride ions, and the
dehalogenated compound.
Frequently remedial sites show insignificant or incomplete dechiorination, especially those with
high aquifer sulfate levels. It is generally overlooked that the rapid conversion of sulfate to toxic
free sulfide during bacterial reductive dechlorination plays a significant role in the "stalling" of the
biotic stalling frequently observed. Accumulation of free sulfide is especially. important in sites
that display both high sulfate and low available iron. Reductive dechlorination inhibition by free
sulfide has been observed in microcosms conducted for high sulfate field sites. Free sulfide
toxicity to microorganisms can be prevented if ferrous iron precipitates the free sulfide. Further,
iron sulfide mineral precipitates have been shown to catalyze reductive dechlorination of
chlorinated solvents at rates comparable to metallic iron, on a surface area normalized basis.
Microcosms performed at high sulfate sites have been showed to both remove free sulfide toxicity
to dehalogenating bacteria and to enhance catalytic reductive dechlorination when ferrous iron is
added. Further, ferrous iron, itself, may act as an electron donor.
Injected, colloidal reactive iron is a promising new technology, which may be applied, in a
synergistic approach with compatible technologies. There are two primary reactions with CAHs
that take place which will consume the iron and require stoichiometric consideration:
• the anaerobic iron corrosion reaction in which water is disassociated to form hydrogen
gas; and

ATC.Associates — Courtesy Cleaners
Page 5
• the direct adsorption of a chlorinated hydrocarbon onto the surface of the iron,
followed by reductive dehalogenation.
Recent research on elemental iron systems suggests that four mechanisms are at work during
the reductive process:
• First, the Fe° acts as a reductant by supplying electrons directly from the metal surface
to an adsorbed halogenated compound.
• Second, hydrogen gas is generated by the anaerobic corrosion of the metallic iron by
water.
• Third, metallic iron may act as a catalyst for the reaction of hydrogen with the
halogenated hydrocarbon using the hydrogen produced on the surface of the iron metal
as the result of anaerobic corrosion with water. Theoretically, these reactions are not
kinetically effective without a catalyst; thus, it is thought that impurities in the iron or
surface defects act as that catalyst.
• Fourth, solubilized ferrous iron can also act as a reductant, albeit at a rate at least an
order of magnitude slower. - -
Hydrogengas can be used for reductive dehalogenation by the following reaction:
H2+X-CI=X-H+H++CI-.
Hydrogen Release Compound (HRC®) is one of a variety of organic carbon sources, which may be
used to supply necessary dissolved hydrogen to a biological system. It is used to stimulate rapid
degradation of chlorinated solvent contaminants often found in groundwater and soil and has
been applied to treat compounds such as perchloroethene and trichloroethene on sites across
the US. HRC has been shown to achieve rapid in situ degradation of target contamination
without the costs and disruption associated with complex engineered remediation systems, and
without the ongoing cost and liability of natural attenuation approaches.
HRC is a proprietary, environmentally safe, food quality, polylactate ester specially formulated
for slow release of lactic acid upon hydration. The HRC is simply applied to the subsurface via
push -point injection or within dedicated wells. The HRC is then left in place where it passively
works to stimulate rapid contaminant degradation. HRC :is a polylactate ester product,
environmentally safe and of food quality. HRC provides a long-lasting, continuous and highly
diffusible source of lactic acid to stimulate microbial production of hydrogen. It reduces time to
closure with minimal site disturbance.
The use of blue green algae and kelp is an additive that not only provides a variety of organic
carbon and hydrogen sources, but also provides a source of nutrients and vitamins. When
anaerobic bacteria digest sugars and carbohydrates, they convert the sugars and carbohydrates
into gases, most commonly hydrogen. By utilizing a variety of very soluble and slightly soluble
kelp and blue green algae sources, IET will be able to provide a longer lasting source of vitamins,
nutrients, and organic carbon than is commercially available in alternative remedial materials.
Blue green algae is rich in gamma-linolenic acid, and also provides alpha-Iinolenic acid, linoleic
acid, stearidonic acid, eicosapentaenoic acid, docosahexaenoic acid, and arachidonic acid. Blue
green algae and kelp also contain vitamins B1, B2, B3, B6, B9, B12, vitamin C, vitamin D, and

ATC Associates —Courtesy Cleaners
Page 7
vitamin E. Kelp, Ascopyllum nodosum, contains over 50% carbohydrates, 5% fat, 25% alginic
acid and numerous essential macro -nutrients, micro -nutrients and vitamins. Combined, these
materials offer long term organic hydrogen sources, buffering capacity and essential nutrient for
the sustained, biologically mediated anaerobic dechlorinization.
IET is also proposing to utilize EHC at Courtesy Cleaners. EHC is a fibrous plant based organic
hydrogen donor which slowly produces glucose. Glucose, a six carbon compound is degraded by
most microorganisms through a series of reactions resulting in the formation of smaller carbon
compounds (5 ,4, 3, 2 carbons). These are then re -utilized as building materials either directly or
after modifications for the synthesis of nucleic acids, proteins, carbohydrates and lipids.
Glucose degradation by Embden Meyerhof Pathway - EMP involves ten reactions and operates
both under aerobic as well as anaerobic conditions. Under aerobic conditions, this pathway
functions in conjunction with the tricarboxylic-acid (TCA) cycle in which the pyruvate generated
through the EMP is oxidized to CO2 and water. Under anaerobic conditions, pyruvate is reduced
to lactate or ethanol. Energetically this pathway yields 2 moles of pyruvate and 4 ammonium
triphosphates (ATP) per mole of fructose diphosphate fermented. Of these 1 mole of ATP is used
in the phosphorylation of glucose and the second is utilized for the phosphorylation of fructose-
6-phosphate, the net yield is therefore only 2 moles of ATP per mole of glucose fermented.
Studies have shown that hydrogen produced in -situ is one element in a remedial program that
supports the growth of methanogens, homoacetogens, and certain sulfate reducers and
denitrifiers. In addition, many hydrogen -utilizing microorganisms are known mediate reductive
dechlorination reactions. For example, some methanogens and acetogens have been shown to
mediate reductive dechlorination of TCE and PCE. These reactions are believed to be
cometabolic (that is, the reactions occur fortuitously and do not yield energy for the
organisms). In contrast to the cometabolic dechlorinatiog microbes, a handful of bacteria have
been isolated in the past seven years, which can couple reductive dechlorination of PCE and TCE
for energy and growth (i.e., PCE and TCE serve as terminal electron acceptors - just like we
breathe oxygen, they breathe chlorinated solvents).
The application of these two synergist technologies: colloidal iron and microbial reductive
dechlorination process may be further enhanced through microbial amendments and reducing
agents. The proposed treatment technology presented herein applies these technologies.
Critical to the success of the proposed remedial technologies is the successful delivery of the
various materials to the targeted groundwater and soils.
OBJECTIVE
It shall be the objective of Innovative Environmental Technologies, Inc. (IET) to promote the
conditions in -situ, necessary for accelerated dechlorination via microbial processes. Further,
through the introduction of a 1-3 micron zero valent iron colloidal suspension, reduction of the
dissolved phased CVOCs will occur while initiating the production of hydrogen for microbial
mineralization processes

ATC Associates — Courtesy Cleaners
Page S
-The remedial plan described herein is designed to achieve -source area reductions -of CVOCs in the
vadose and saturated zones. No additional equipment or maintenance will be required and
because no waste streams will be generated, no disposal permitting will be required during the
remedial effort. IET proposes to implement a program, which shall:
• Supply all essential microbial elements necessary for dechlorination processes to occur.
• Introduce zero valent iron, (ZVI) to further and quickly address dissolved phase compounds
while acting. synergistically with the anaerobic processes.
AREA A
The treatment area proposed for the treatment of the present on -site known groundwater
contamination in the vicinity of MW-1, MW-2, and GW-1 is 1,200 square feet with a 10 foot
vertical contaminated zone to be treated between 25 and 35 feet below ground surface (bgs).
An injection radius of 9 feet is proposed. Based on the area to be treated and the injection radii,
5 injections would ,be required to treat. the 1,200 square foot area with 2 injection intervals at
25-27 feet bgs and 30-32 feet bgs. Soil concentrations at the site are moderate which indicates
that some absorbsion on the soil particle is occurring. Therefore soil absorbsion correction is
moderate (IET has assumed the value to be 5%). The corresponding dosage calculations are
located in Appendix 2. =
SCOPE OF SERVICES
1. SATURATED ZONE INJECTIONS
The following sequence will be followed when injecting into the saturated zone.
1. Subsurface Pathway Development
Initially, nitrogen gas shall be delivered to the subsurface via IET proprietary
injection trailer system. Nitrogen gas is used so as not to introduce oxygen
into an environment targeted for anaerobic processes. The gas is introduced at
approximately 175 psi such that delivery pathways and voids are established.
Pathway development shall be verified by observing a substantial pressure
drop.
2. Sodium Sulfite, Nutrient and Micro Nutrient Injection
A solution of sodium sulfite, yeast extract, calcium propionate, nutrients, blue
green algae, and kelp are immediately injected into the subsurface fractures
and voids that were developed during the gas injection step. Sodium sulfite
acts as an oxygen scavenger, iron reducer and sulfate source. As an oxygen
- scavenger, the sodium sulfite prevents the oxidation of the ZVI by the
dissolved oxygen while promoting anaerobic conditions that are favorable for
the biodegradation of the CVOCs. Nutrients, injected as organic ammonia and

ATC Associates — Courtesy Cleaners
Page 9
ortho-phosphate, are required for the maintenance of the microbial metabolic
pathways, ATP/ADP synthesis and organelle development.
3. ZVI and EHC Injection
ZVI and EHC is injected,immediately following the sodium sulfite/bioslurry
solution to reduce concentrations of dissolved -phase CVOCs while providing
for rapidly generated hydrogen for the microbial stimulation.
4. HRC Injection
HRC will be injected immediately after the ZVI injection to provide a slow
release hydrogen source for the anaerobic dechlorination of the CVOCs.
5. Sodium Sulfite/Nutrient Injection
This injection is conducted to clear the injection lines and to provide for in -situ
mixing and penetration of the HRC product.
6. Post Liquid Injection - Gas Injection
Lastly, the injection lines are cleared of liquids and all injectants are forced
into the created formation and upward into the vadose zone.
Once the injection cycle is complete, the injection point is capped to allow for the
pressurized subsurface to accept the injectants.
The targeted saturated zone at the site shall receive calculated dosages of the
individual remedial components based on biological and stoichiometric demands and
an estimated pore volume based on the known geology of the site.
SUMMARY
Innovative Environmental Technologies, Inc. presents this remedial design as a "Lump -Sum"
amount based on the treatments area. The cost to implement the remedial event for the
proposed treatment area is $23,527.73. The remedial program is anticipated to take 1 day to
implement. The price presented herein is guaranteed regardless of the actual field time
required to implement the program described herein.
The "Lump -Sum" price set -forth assumes that a water supply and a secure storage area for
chemicals are available for the duration of the project.

ATC Associates — Courtesy Cleaners
Page 10
Recommended Sampling:
Field Sampling_
Dissolved Oxygen (DO),
Oxidation/Reduction Potential (ORP),
Specific Conductivity,
pH
Temperature and
Groundwater Elevation.
Laboratory Analyses:
Method 8260 VOCS
TCE
PCE
Cis-1,2-DCE
Trans-1,2-DCE
1,1-DCE
Vinyl Chloride
Ethene
Ethane
Methane
Sulfate
Total and Dissolved Iron
Volatile Fatty Acids using Microseeps or Microbial Insights for the Laboratory Analysis
APPENDICES:

ATC Associates —Courtesy Cleaners
Page 11
APPENDIX 1 (SITE MAP)
Li
CANOPY
AP7R0X ATE EXTENT O
e OuNowATER CCNTAHiNA11ON
1 STORY BRICK
Area A-1 200 RAI
„CuRCE GROUNDWATER
RKINUf; AREA
A
L
vr+mmure aeac er «ir
PARKING
SS-1/N/r!
9190,2
CouRitsr
CLEANER-1
' —
AREA J
i�

ATC Associates — Courtesy Cleaners
Page 12
APPENDIX 2 (CALCULATION SHEETS) - -
Area A
Site Name Courtesy Cleaners
Area A
Parameters
Units
Assumptions
Target Area Ft.X Ft.
Soil Absorbsion Correction for GAC Constant
Area of influence of Remediation Injection(s) Sq. Ft.
Estimated Number of Injections to Treat Area # Injections
vertical impacted zone Ft.
Total Volume Targeted Cu. Yd.
Porosity
Groundwater Flow Velocity Ft1Yr
Injection Depth Ft - bgs
Volatile Organic Compounds in Water
1200
5
254.46879
5
10
444.4444444
20.00%
7.00
25.00
TCA ppb 10 0.01 ppm
PCE ppb 500 0.5 ppm '
TCE ppb 500 0.5 ppm
c-DCE ppb . 500 0.5 ppm
t-DCE ppb 10 0.01 ppm
1-1 DCA ppb 10 0.01 ppm
1,1 DCE ppb 10 0.01 ppm
VC ppb 50 0.05 ppm
Injection Parameters
Anticipated Radius of Influence
innovative environmental technologies, inc.
Courtesy Cleaners ; B2 Calculations
_ 1
Vitamin B2 Calculations _
Number of Atoms/Molecule_ Mol, WI
Cabon 17 12' 204
Hydrogen 20 1 20
Cobalt 0 59 - 0
Nitrogen 4 14 _ 56
Oxygen 6 _ 16 96
Phosporus 0 31 0
Grams/mole
1 Molar solution =
Conversion molar to Micromolar
1 micromolar solution
376
376 ,glliler
1.00E-06
3.76E-00glliler
50 micromolar solution 1.86E-02 ;glliter
Anticipated radius of injection 9,feet
Anticipated vertical Impact 10 feet
Estimated pore volume 2t).00%;percent
Calculated impacted liquid 3806.853098,gallons
Calculated Impacted liquid 14410.46172iliters
B2 dosage/Injection - 270.9166803,grams
Total Injections 5
B2 Required for Project 1354.583402,grams 1312 Required for Project 195.1176517 grams _
Ft 9
i innovative environmental technologies, inc.
Courtesy Cleaners B12 Calculations
'Vitamin B12 Calculations
Number of Atoms/Molecule Mol. Wt '
Gabon 63 12 756
Hydrogen 88 188
Cobalt 1 59 59';
Nitrogen
Oxygen
— Phosporus-
1 Gramslmole
;-1-Molar solution =
;Cornerslon molar to Micromolar
11 micromolar solution
12 micromolar solution
(Anticipated radius of injection
Anticipated vertical impact
Estimated pore volume
;Calculated impacted liquid
14
14
;Calculated impacted liquid
;812 dosage/injection
1354
14 196;
. 16 224;
31 31'
1354 gpiter
1.00E-06
1.35E-03 glliter --r
2.71 E-03, glliter
9 feet
10 feet
20.00%. percent
3806.853098 gallons
14410.46172 liters
39.02353033 grams
Total Injections 5

;. • _ A„_�IaF�i -
ZVCHRC Points
Courtesy Cleaner,
Injection Parameter,
Ramus G1 tnSurrce GE En -action
Area
VEdlc* imaacted _zone
Total Volume
Parcae,
Pore Volume
Pore Volume
Groundwater Fiats Velacty
Retention term within lreatment Area
Targeted Long4•.4y at Treatment System
Targeted Longevity M Treatment System
Mutrgler Gr Ldngerty - cartectl0n tar retention
Percentage Targeted by NI
Area A
Units
Fi
So Ft
Ft
Cu Ye
Gat
m1
FLY,
Days
Yews
Days
Percentage
Percentage
Organic Hydrogen sonar Calculations
Courtesy Cleaners
F.rarneters
Target Area
Sc:1 4040rOpon Correction ear GAC Conalaar
retooled RIM. or 9900M0O* per 110•CLUn
+area cf n10.5.1e of Reu1raiSten ne`V)nrs
Ee 0:e9 tiurme' e1 n1e;Lear la Treat area
Vortical impattedmre
TtmI'•1c FJrr, Targets c
Porosity
Fiats ct sal ie a0l0r0e'x0
Vasa of sot :o oe ter0etet
V a 0nte c 1 ;,ro se Ada re. tars:ra_
Comae: Para Cont. • Ta recMomethane in water
Lissa Di20r2'r-.'earl. 'e1e0IWaarsent-wr -
bass 31 C:x_arrrar1-'eln0509sem05e-xne-
Wasssr r.4010rne"n. 'elrecaWoemeia-so•
!!au of :armpit -Ear: • Tevetr o aemere-sc:
Contaminant Conc. - TnChJOeea0trw in Miter
!Jess ul Con940n-410o1- 7ncreinvenen w&r'
bass o1 ComirinMi - 7rchergernane r
bass c1 ;anfmnant - Trel!arnaelare P son
Iran or Carownent -'rigroraarnane r• sole
Cormaimnant Conc.- OlchlorQWwte rn eater
Vasa of Centssnant - Ditlrlorpnretre s} Yrne"
Vass c1 CORamnarrl - Donaroe7e/le n wet,-
Masa or Corr+ ammsnl - Dien o : eMane n soon
Ides] of Co!aemmenl - aiCnr01011 none n earn
Contaminant Con. - limy,, Chlorrov (VC.) in eater
urn of C4namynt - r: C rr water
Haas of Choi -L' C n weer
Moat 00orar:wen VC.n owe
bass a1 _an4mmar1- V C n saes
H<' Room, cameo of 1. 04
if2 Derrara bosue VOam molar tr4 3rcer o}atics
5wa9 Fac-4.'
Centarara01 lyeeager Dam'no - eacl.yroure
Esx7ex: Crrreaed -lead - Crean Dana. 5emar.:
Eta- sec Ca-rected Var.-0 - 3795-nt : nose 2e1vc:
P0rrent ailocat+an Organic Hydrogen Denture
Darr 71- 'see
Dosage Per nwnt
Zonal Retention Rate
ZVI Reaction Constant
730 Days
Percent Targeted try NI
0.3 m%mfmL H2O Dosage o7 IET-ZVI
A.Wmplion* jVl Parameters J}p�g
9 Zr . 5+10sca area ittKe ig
254 46879 Specific Compound hall Lifva for EFT ZV7
1D PC[
9d 2477 TCE
20 006. 1 1 DCE
3817 03185 t-DCE
1431386914 c-DCE
VC
TCA
DCA
Calamrrlant Lac AOrseo.;c
700 PCE
938 5714286 TCE
2 1.1 DCE
730 1-DCE
053E c4DCE
91 D0 VC
TCA
OCA
Cieareup Standard
PCE
urpb
Fi ll i1
14
S: 5.
0 npcnons
Cu. ` O.
M
trams
904
ram
t
trams
t
G etas
P74,
c
G-etas
�▪ m
Crate.
0
Grans
Pa E-
G-a'n
5
Greens
G4am'
9:
As Wmpa0ns
1 21,
254 16on3
tE
444 4414444
zntra-<
12E6566.667
}64266666
I MOE
G.9
G 07E t5 Cato Sod
34.11E1 ppm
r 2323352.25
3421.350755 Hydrogen berrona Moles - PCE
TCE
1 DOE
t-OCE
c-OCE
VC
TCA
OCP
tam
9.0▪ 7
Emir
rout
min
tan
min
� � gg4U si
C--_ 25
2400
132 00
780 00
69120t0
1200.00
9% 4C
18000
660 80
Targeted E
10
5
10
10
10
Total Mins
Hours
Days
50.29n..
243,35.51 pram,
S IUS
257 45
251 45
5 029
5 029
251 45
25 145
5 029
5025
min for 1st mdef
13560
746 25
57.58
55133.83
4634 57
11158.01281
185966880?
7 74%20009
tralueted Suastn00GS
Ida
Mies o1 ti P1a3ncat ter My Grarro M- srae0Ce0,9a40 v tear _ ante. means
A_S
237515
34.1101
213$e0e65.1®
070.8366207 Hydrogen
2.37E1' 51ak1
34.1151
G 425054E 16®
1954332904 1Nydragen
D 05
C 53751E bane
3.41181
▪ 0.01130756®
5.160572151 Hydrogen
121%66E67 then
SaGarm .05tate
9adr,rr. Atetare
Satan Ouirn*
Caleraa
14154914'
5010
ENC
HOC
Somum Lmalale
Colman Pram:mare
Ii:et :' n5L Rta40e1
berg Capps ora4enete Assam!
floes of 1MC 50c.4xed
i raea 044 ;read -see
Demand Idates - TCE
Mice' of H5C ftsarxeed
Ca106lm ProneneR'Regoaee
Mules of EHC P.e3u2-e0
Mara Kean Reaured
Demand Motes -11C8
tio'1a a1 H3C Reaared
Cas:um PrcpwwN Rem0's0
tans or te0 5saurr:
totes Ke1 Reou5t_•
Demand Moles - VC
0 tes cl'1RC Re04art
Cabman armimarr Resrrea
11OiES 19003 Reoure0
r.•oes Ken aec49.00
IlyeirOgen Demand 1l401e1 -outside VOA
Faces c1 HRC R10uIO0
Voles Comm PrapDRafe i3 -
Poles c1 EHC Paalirtd
Awes Ke16 Reaueed
HEW Proplon.le INC
5407712049 114'.24.5175 11,116 0421
136074 2.1 229649 03E0 223632 ed61
242 23401; 53e 53r6479 502 501427E
124.80'. 99.00 ..
320'7,11736 52077327E4 4985400,3
00A7403472 100.1556563 100
111E15 3 12 5 14149274E'
e7.O3 d E 21192E056
111.58 6 15 3.14444332 t
act 2 4 006576789E
E 012.75
573 155 124 0 0. 142G-5532E-
164 19.2 364 6.2123°7'"
5-55 212 424 9443514E44
322.56 1E 32 0.1057:205'
113- 12 24. '92123E4381
r.;ces 14.62775479
Yeas G 2707-c9234
Vain 4.942506261
Woes 368911e414
kaae C 33C108r4-_
13r., iCE 7859'155E9
Vales L-1ce3=320c
1f01n 1-91/9T4801
V;Iea 1.146:39F.00 ---
miss : 14733322E
kolas C^_E 2.2E0727504
slams C. •YC1757E1:
0104e 051077605e1
NE tea 2 24488?45
bees 0.2221376E
Voles VC 2 13924906'
Woes 2ones0413
twee 0.011822422
tece' :Ot7251es1
Pares E 00088E34
bars 57 1069132a
190130 1008.866566
'toes S3Grrcc -
L'oes 77 62333751
Kelp
70-5C:. =56
14122E i027
711.027E182
142.90`.
_4, EEi37E
65.3310151
Pees Hyafe4e' Gnera 1--
59.21103E15 533119251E
22.5741575E
22 9791375E
4.731475646
135265067
7e1e1 Copee.00 H- Denim;
1.70147500E
0 7382esce7
57129525E

ATC Associates — cot; rt =sy Cio e
Naj 34
Courtesy Cleaners
Imecnon Pony a
Number of Pts
!moan Horizon
1
Area A
Point
TO
Depth(82 Location
25-35 outside
5 2
Infection PO5l2
613tenals
0 B2
53.66 BGAlgae
100 Yeast 0.6J ct
500 EHC
300 HRC
275 T0I
1+0 Pounds Kelp
101 Nu61enl
7 Polymer los
500 Propionate
Lain,
Dais oI Prose
024 Df.ET Ins3o1 Triafer
Days IET 9upeniSm etc
Law
Sub Total
1
02c
80.233
21705
213.50
25
313.25
8a 50
595r.
Si 50
821.95
5205
51.530
34720
$2.750
5125c
S0 00
5957 70
21.350,00
21.525 00
S3.975 00
22.512 00
54.1 B0,00
5153 00
5000
21.475.00
510.325.25
51,577.00
51.107.50
22,753 00
i125000
$6.007.50
523,012.79
tic
Licence Colo. Taal
Taal Material Cost 517 5t2.75
Instaliation Cost S5 500 00
Capita! Cost 523.012.78
Licence Fee 3514 95
8514.45
s23,527.n
Totals
Type
Totals
t32 - Gems
270.9166803
1354 583402
B'2 - Grams
39 02363033
195 1175517
Micro -blue green al7ae eaum 2376,1 62108 24309 70646
,'Tams
Its 5228 53.55
Cost BG Aigan32 51796 S1701
89332+ S95778
Yeast Reduction due to2G Algae 19.00%
EIYC
100
500
Point Summary Comperieon
Num3er orPonit
Grams B2lQt
Pounds BG Algae
Pound." Yeast Ereactpt
Pounds EHC
F0un4S of ZV1f0f
Pounds at Keip
Pounds of Nuir ertvlrt
Faunas Pohmer
Pounds of Propionate
HRC • Los
Cost per Point
Component Comparison,'
- :DE
55
wren A
injection Summmerv: 1e01C5an II bs501son 02
Depth of Infection 25-27" 30-32'
;,rams 026t 0 0
Pounds 6G4 4,1e 5.0
P00009 Ye251 Eriractlpt 10 10
Pduna$ EH 50 54
Pounds 012Y1rp1 27.5 275
Pounds al Kelp 4+ 44
Pounds o1 Nufient+0T 10 10
Pounds P4t9'm9r 0 0
Pounds of Pr0Oldnat5 50 50
H-RC-Los 30 30
Gallons 015unlleFi&rtrien044 75 75
Yeast,propnanate
Soldporoirlt
6"a
149
11.00
20
100
55
8S
20
0
100
50
54.705.55
HRa
60.07403472
300
Area A
Distribution - linear
5
0 0
11
2
10
5.5
0S
2
e
10
6

The injection event is proposed to treat 1,200 square feet in the vicinity of MW-1 and MW-2. A
10 foot vertical treatment area from 25 to 35 feet bgs is proposed using two injection intervals
from 25-27 feet bgs and 30-32 feet bgs. An injection radius of 9 feet is proposed and based on
this injection radius, 5 injection points will be required to treat the 1,200 square foot area.
The injections will occur at a maximum gas pressure of 150 psi, with a range of 50-150 psi. The
maximum liquid pressure would be 100 psi, with a range of 50-100 psi. The rate of injection will
be approximately 3 to 5 gpm, with 150 gallons injected over the 10 foot vertical zone targeted in
each injection point for a total of 750 gallons of solution. The project is anticipated to take 1 day
to inject the remedial materials into the five injection points.
A summary of the concentrations of the remedial materials are presented below for each interval
and each injection well.
Remedial Material
EHC
ZVI
Blue Green Algae
Yeast Extract
Kelp
Nutrient
Calcium Propionate
HRC
Concentration (lb/gal) Per
Interval
50 lbs/75 gal
27.5 lbs/75 gal
5.36 lbs/75 gal
10 lbs/75 gal
44 lbs/75 gal
10 lbs/75 gal
501bs/75 gal
30 lbs/75 gal
Concentration (lb/gal) Per
Injection Point
100 lbs/150 gal
55 lbs/150 gal
10.72 lbs/150 gal
20 lbs/150 gal
88 lbs/150 gal
20 lbs/150 gal
100 lbs/ 150 gal
60 lbs/150 gal
The injection points are anticipated to have an anticipated radius of influence of 9 feet.
The total quantities .of all materials proposed to be injected are listed in the table below, per
injection point and the total for the 5 injection points:
Remedial Material
Total Per Injection Point
Total Across Site
EHC
100 lbs
500 lbs
ZVI
55 lbs
275 lbs
Blue Green Algae
10.72 lbs
53.6 lbs
Yeast Extract
20 lbs
100 lbs
Kelp
88 lbs
440 lbs
Nutrient
20 lbs
100 lbs
Calcium Propionate
100 lbs
500 lbs
HRC
60 lbs
300 lbs

If you have any questions or comments, please let me know.
Thank you,
Sincerely,
Elizabeth Bishop
Manager of Technology Assessment
lnnovative Environmental Technologies
888-721-8283
[e-mail]

Mccray, John
From: Gabe Araos [[e-mail]]
Sent: Wednesday, September 01, 2010 10:57 AM
To: Mccray, John
Subject: RE: Additional Information request for Courtesy Cleaners Injection Permit
Attachments: DC920033_20100901_Injection Permit Appl. Revision.pdf
John, ,
Attached are the revised pages as per your email. Do you want a hard copy via regular mail?
Thanks
Gabe
From: Mccray, John jmailto:[e-mail]
Sent: Monday, August 30, 2010 11:26 AM
To: [e-mail]; araos45©atc-enviro.com
Subject: Additional Information request for Courtesy Cleaners Injection Permit
Ms. Olson,
I have completed the review for UIC permit application W10500248 and need one minor correction. Page 1 of 7 of the
application doesn't require the property owner information since the Petitioner is the owner, and since ATC has been
awarded the contract for site activities and has provided documentation of the contract, the signature of the Owner
granting consent is not required either. Attached is an additional information request asking for a resubmittal of the
two pages of the application without the unnecessary information. A response by email is sufficient and hopefully will
expedite the issuance of the permit.
Best Regards,
John McCray
1

ATC ASSOCIATES OF NORTH CAROLINA, P.C.
Engineering Individual Solutions
2725 East Millbrook Road
Suite 121
Raleigh, NC 27604
Tel: [phone]
Fax: [phone]
www.atcassociates.com
N.C. Engineering License No. C-1598
September 1, 2010
Mr. John McCray
NCDENR Division of Water Quality
Aquifer Protection Section, UIC Program
1636 Mail Service Center
Raleigh, North Carolina 27699-1636
RE: Injection Permit Application
Courtesy Cleaners
8111 Creedmoor Road
Raleigh, Wake County, North Carolina
ATC Project No. 45.34341.9233
DSCA Site No. 92-0033
Dear Mr. McCray:
Enclosed are two corrected copies of the first page and signature page of the injection permit
application submitted on April 13, 2010.
If you have questions or require additional information, please do not hesitate to contact Genna.
Olson or Gabriel Araos in ATC's Raleigh, NC office at [phone].
Sincerely,
ATC Associates of North Carolina, P.C.
Genna K. Olson, P.G. Gabriel Araos, P.E.
Senior Project Manager
Senior Project Manager
cc: Scott Stupak, DWM, Superfund Section
Raleigh Regional Office
Permit File WI0500248

ATA
NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Coleen H. Sullins Dee Freeman
Governor Director Secretary
August 30, 2010
Genna K. Olson. P.G.
GRE Brennan Station. LLC
DSCA Program.
Mail Service Center 1646
Raleigh. NC. 27699-1646
Ref: Additional Information Request
Injection Well Permit Application No. WI0500248
Courtesy Cleaners
Wake County
Dear Ms. Olson:
The Aquifer Protection Section is cull eutly reviewing the above referenced Permit Application received
April 13, 2010 and has identified some items that need additional information. Address the following
issues as required:
• Submit two corrected copies of the first page and signature page of the application. Because
the Petitioner is the property owner, no additional information is required for lines 4 and 5.
Also, because the agent has been awarded a contract from the DSCA program, a signature is
not required for Section VII. Consent of Property Owner.
If you have any questions regarding this request, please contact me at [phone] or email me at
[e-mail]. Thank you in advance for your cooperation and timely response.
Sincerely,
s
�
John McCr
Environmental Specialist
Cc: Scott Stupak, DWM, Superfund Section
Genna Olson, P.G., ATC Associates of North Carolina, P.C.
Raleigh Regional Office
Permit File W10500248
AQUIFER PROTECTION SECTION
1636 Mail Service Center, Raleigh, North Carolina 27699-1636
Location: 2728 Capital Boulevard, Raleigh, North Carolina 27604
Phone: [phone] \ FAX 1: 919-715-0588: FAX 2: 919-715-6048 Customer Service: 1-877-623-6748
Internet: www.ncwaterauality.ora
An Equal opportunity Affirmative Action Empiaye,
North Carolina
Naturally

ATA,
NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Coleen H. Sullins Dee Freeman
Governor Director Secretary
April 22, 2010
Genna K. Olson, P.G.
GRE Brennan Station LLC
Petitioner for DSCA Site 92-0033
1646 Mail Service Center
Raleigh. NC 27699
Subject: Acknowledgement of Application No. WI0500248
Courtesy Cleaners
Injection In situ Groundwater Remediation Well (5I)
Wake
Dear Ms. Olson:
The Aquifer Protection Section of the Division of Water Quality (Division) acknowledges receipt of your permit application and
supporting materials on April 13, 2010. This application package has been assigned the number listed above and will be reviewed by
John McCray.
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 John McCray at 919-715-6168, or via e-mail at [e-mail]. 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 htto://h2.o.enr.state.nc.uti!documents/dwq orachart.pdf.
PLEASE REFER TO THE ABOVE APPLICATION NUMBER WHEN MAKING INQUIRIES ON THIS PROJECT.
Sincerely,
eftnycL
for Debra J. Watts
Supervisor
cc: Raleigh Regional Office, Aquifer Protection Section
Gabriel Araos, PE (ATC Associates of NC) 2725 E. Millbrook Road, Ste 121, Raleigh, NC 27604
Permit Application File WI0500248
AQUIFER PROTECTION SECTION
1636 Mat Service Center, Raleigh, North Carolina 27699-1636
Location: 2728 Capital Boulevard. Raleigh, North Carolina 27604
Phone: [phone] \ FAX [phone]: FAX 2: 919.715-6048l Customer Service: 4-877-623-6748
Internet www.ncwaterouaiity.orq
An Equal Opportunity t Affirmative Acucar, Employer
North Carolina
Naturally

Beverly Eaves Perdue
Governor
Memorandum
To:
From:
Through:
Subject:
ern
NCDENTI
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Coleen H. Sullins
Director
June 15, 2010
John McCray
Groundwater Protection Unit, Central Office
Eric Rice
Aquifer Protection Section, Raleigh Regional Office
Jay Zimmerman, Regional Supervisor
Aquifer Protection Section, Raleigh Regional Office
UIC (5I) Permit
Courtesy Cleaners
8111 Creedmoor Road
Raleigh, N.C.-Wake County
Permit # WI0500248
Dee Freeman
Secretary
Enclosed is the regional staff report regarding the submittal of a permit application for the
injection of HRC and associated injectants at the Courtesy Cleaners site in Raleigh, N.C. The
permit is being requested in order to remediate the release of chlorinated solvents a results of
past dry cleaning operations at the facility. Please contact me at [phone] if you have any
questions about the inspection.
cc: file
Attachment: APRSR form
lyuiter Protection Section
1628 Mail Service Center. Raleigh. North Carolina 27699-1628
Location: 3800 Barrett Dr . Raleigh. North Carolina 27609
Phone. [phone] FAX: 919-S71-1718 ` Customer Service: 1-877-623-6748
Internet: wwwncwaterquality org
An rytwl opportunity 1 Affirmative Aeirun firnployer
WQ
Aquifer
Protection
Se
Q�on � ion
JUN 16 201a
No" ehCarolina
aaurall i

AQUIFER PKUTECTION REGIONAL STAFF REPORT
Date: June 15, 2010
To: Aquifer Protection Central Office
Central Office Reviewer: John McCray
Regional Office Inspector: Eric Rice (RRO)
County: Wake
Permittee: GRE Brennan Station
(DSCA Petitioner 92-0033)
Project Name: Courtesy Cleaners # WI0500248
I. GENERAL INFORMATION
1. This application is (check all that apply): ® New ❑ Renewal
❑ Minor Modification ❑ Major Modification
❑ Surface Irrigation ❑ Reuse ❑ Recycle ❑ High Rate Infiltration ❑ Evaporation/Infiltration Lagoon
❑ Land Application of Residuals
❑ Distribution of Residuals
❑ Attachment B included
❑ Surface Disposal
❑ 503 regulated ❑ 503 exempt
❑ Closed -loop Groundwater Remediation ® Other Injection Wells (including in situ remediation)
Was a site visit conducted in order to prepare this report? ® Yes or ❑ No.
a. Date of site visit: June 8, 2010
b. Person contacted and contact information: Gabe Araos (ATC Associates)
c. Site visit conducted by: E. Rice
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 / 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 pages for each site)
a. Location(s):
b. Driving Directions:
c. USGS Quadrangle Map name and number:
d. Latitude: 35.89750 Longitude: 78.68194 to the nearest second
IV. INJECTION WELL PERMIT APPLICATIONS (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.)
RECEIVED / DENR / DWQ
Aquifer Protection Section
JUN 18 2010
FORM: Courtesy Cleaners (WK) W10500248.doc 1

AQUIFER PkiTECTION REGIONAL S 1AFF REPORT
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)
® In 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)? What is the distance of the injection well(s) from the
pollution source(s)?
4. What is the minimum distance of proposed injection wells from the property boundary? Approx. 50 feet
5. Quality of drainage at site: ® Good ❑ Adequate ❑ Poor
6. 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? n Yes ❑ No. Attach
map of existing monitoring well network if applicable. If No, explain and recommend any changes to the
groundwater monitoring program:
8. Does the map presented represent the actual site (property lines, wells, surface drainage)? ® Yes or n 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.
V. EVALUATION AND RECOMMENDATIONS
1. Provide any additional narrative regarding your review of the application.: Permit application is regarding the
injection of HRC, zero-valent iron, EHC, chemical oxygen scavengers, and various vitamin stimulants and
nutrients to remediate the presence of chlorinated solvents in the groundwater. The proposal calls for one
injection event composed of five direct push injections for a total volume of seven hundred and fifty gallons.
Target injection depths are twenty five to twenty seven feet and a second zone at thirty to thirty two feet. The
concentration of the injectant was not supplied. The calculations supplied in Appendix 2 of the application for
the justification of injection volume concentrations are not easily deciphered. Injection pressures will range
between fifty and one hundred PSI. Groundwater seepage velocity was indicated to be between 1.4 ft/yr and 14
ft/yr. Observations/Recommendations: 1. Request concentration of injectant 2. Injectant volume is not
justified 3. Request map detailing injection locations 4. Because of a Iack of adequate downgradient coverage
for groundwater monitoring, recommend one additional monitoring well West of MW-2. Well should be
located outside calculated radius of influence but sufficient distance to monitoring the injection event 5.
FORM: Courtesy Cleaners (WK) WI0500248.doc 2

AQUIFER PKuTECTION REGIONAL STAFF REPORT
Date:
Monitoring plan as proposed in item G. of the application is an adequate plan with the inclusion of the
additional requested downgradient monitoring well
Attach Well Construction Data Sheet - if needed information is available
2. Do you foresee any problems with issuance/renewal of this permit? ❑ Yes ® No. If yes, please explain
briefly.
3. 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
Item #'s 1,2,3, and 4 above
Necessary
4. 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
5. 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
Item # 5 above
Necessary
6. Recommendation: ® Hold, pending receipt and review of additional information by regional office or central
office; ❑ Hold, pending review of draft permit by regional office; [1 Issue upon receipt of needed additional
information; [l Issue; ❑ Deny. If deny, please state reasons:
7. Signature of report preparer(s):
Signature of APS regional supervisor:
6//fr//
FORM: Courtesy Cleaners (WK) WI0500248.doc 3

AQUIFER P JTECTION REGIONAL 5 1: AFF REPORT
Attachments:
FORM: Courtesy Cleaners (WIC) WI0500248.doc 4

AQUIFER PROTECTION SECTION
APPLICATION REVIEW REQUEST FORM
Date: Mav 6, 2010
To: ❑ Landon Davidson, ARO-APS
❑ Art Barnhardt, FRO-APS
E Andrew Pitner, MRO-APS
® Jay Zimmerman, RRO-APS
From: John McCray , Groundwater Protection Unit
Telephone: f 919) 715-6168
E-Mail: john.mccrayna,ncdenr.gov
El David May, WaRO-APS
❑ Charlie Stehman, WiRO-APS
❑ Sherri Knight, WSRO-APS
Fax: [phone]
A. Permit Number: WI0500248
B. Owner: Petitioner for DSCA Site 92-0033
C. Facility/Operation: Courtesy Cleaners
® Proposed ❑ Existing
D. Application:
1. Perviit Type: ❑ Animal
❑ Recycle
❑ Facility ❑ Operation
❑ Surface Irrigation ❑ Reuse ❑ H-R Infiltration
❑ I/E Lagoon ❑ GW Remediation (ND)
® UIC - (51) in -situ groundwater remediation
For Residuals: ❑ Land App. ❑ D&M El Surface Disposal
❑ 503 ❑ 503 Exempt ❑ Animal
2. Project Type: ® New ❑ Major Mod. ❑ Minor Mod. ❑ Renewal ❑ Renewal w/ Mod.
E. Comments/Other Information: ❑ I would like to accompany you on a site visit.
Attached, you will find all information submitted in support of the above -referenced application for your
review, comment, and/or action. Within 30 calendar days, please take the following actions:
® Return a Completed Form APSSRR. •
❑ Attach Well Construction Data Sheet.
❑ 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, 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 02/06 Page 1 of 1

North Caro. -
Department of Health and Human Services
Division of Public Health
1912 Mail Service Center • Raleigh, North Carolina 27699-I912
2728 Capital Boulevard • [phone] • Courier 56-32-00
Ann F. Wolfe, M.D., M.P.H., Director
August 1, 2000
MEMORANDUM
TO: Mark Pritzel
Underground Injection Control Program
Groundwater Section
FROM: Luanne K. Williams, Pharm.D., Toxicologist
Medical Evaluation and Risk Assessment Unit
Occupational and Environmental Epidemiology Branch
/
SUBJECT: Health Risk Evaluation Regarding the Use of Glycerol Tripolylactate, a Hydrogen
Release Compound, Used to Enhance In Situ Biodegradation Rates for
Chlorinated Compounds Detected in Groundwater at Fairchild Industrial Products
Company in Winston-Salem, North Carolina
I am writing in response to Qore, Incorporation's request for a health risk evaluation
regarding the use of Glycerol Tripolylactate, a hydrogen release compound, to enhance in situ
biodegradation rates for chlorinated compounds detected in the groundwater at Fairchild
IOdus'trial Products Company in Winston-Salem, North Carolina (see enclosed letter dated April
10, 2000). Based upon my review of the information submitted, I offer the following health risk
evaluation:
WORKER PRECAUTIONS DURING APPLICATION
1. Some effects reported to be associated with the product proposed to be used are as
follows: eye, skin, nose, throat, and lung irritation. If the product is 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 proper personal protective
equipment should be used. The application process should be reviewed by an industrial
hygienist to ensure that the most appropriate personal protective equipment is used.
2. Persons working with these products should wear goggles or a face shield, gloves, and
protective clothing. Face and body protection should be used for anticipated splashes or
sprays.
3. Eating, drinking, smoking. handling contact lenses, and applying cosmetics should not be
permitted in the application area during or immediately following application.
EveryWliere. EveryDay. EveryBody.
09 An Equal Opportunity /Affirmative Action Employer 71j f'

Mark Pritzel Memo
August 1, 2000
Page Two
4. 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 incompatible or adverse
reactions and injuries.
OTHER PRECAUTIONS
1. 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.
2. According to the information submitted with the letter dated April 10, 2000, municipal
water is available to the application area, and there are no known public water supply
wells located within 1,500 feet of the site. However, two private water supply wells are
reported to be located approximately 1,200 and 1,500 feet southwest of the site,
respectively. Qore, Inc. has reported that with an initial lactic acid groundwater
concentration of 5,000 and 1,000 ppm, the concentration would be diluted to ] ppm at
45.93 and 41.34 feet, respectively. It appears that impact to the closest wells is unlikely;
however, it is recommended that the Groundwater Section review the data and detemiine
likelihood of potential impact to these wells.
3. According to the information submitted, an unnamed tributary of Salem Creek is located
near the proposed application area. It is recommended to contact Ms. Dianne Reid with
the Water Quality Section at [phone] extension 568 to determine if this product -or
process could impact these water bodies.
If you have any questions, contact me at [phone].
LKW:mbf
c: Mr. John Sealey, Fairchild Industrial Products Company
Mr. Kim Caulk, Qore Property Sciences
Dr. Steve Koenigsberg, Ph.D., Regenesis (manufacturer)
Ms. Dianne Reid, Water Quality Section

Page 1 of 1
Michael Ranck
From: "Luanne Williams" <[e-mail]>
To: "Michael Ranck" <[e-mail]>
Sent: Friday, March 05, 2004 7:05 PM
Attach: Luanne.Williams.vcf
Subject: Re: Underground Injection - HRC-X
Please use the previously provided risk evaluation.
Michael Ranck wrote:
> Dr. Williams,
> The Underground Injection Control program has received an application for
> the injection of HRC-X, a Regenesis product which is very similar to
> Hydrogen Release Compound but is formulated differently to provide extended
> release of product. The major difference is the higher glycerol
> tripolylactate content in the HRC-X. I am writing to you to find out if you
> feel that a full epidemiology review should be completed for HRC-X or if
> your comments dated August 1, 2000 for glycerol tripolylactate in HRC are
> sufficient for the health risks of HRC-X as well. I have attached the MSDS
> for both products. If there is any other information I can get, please let
> me know. •
>
> Thank you,
> Michael Ranck
> Hydrogeologist
> NC DENR, Division of Water Quality
> Groundwater Section, Permits and Compliance Unit
> 1636 Mail Service Center
> Raleigh, NC 27699-1636
> Phone: [phone]
>Fax: [phone]
> E-mail: Michael.Ranck a.ncmail.net
>
Name: HRC X MSDS 2-10-04.pdf
> HRC X MSDS 2-10-04.pdf Type: Acrobat (application/pdf)
> Encoding: base64
> Download Status: Not downloaded with message
Name: HRC MSDS 2-10-04.pdf
> HRC MSDS 2-10-04.pdf Type: Acrobat (application/pdf)
> Encoding: base64
> Download Status: Not downloaded with message
3/8/04

North Carolina
Department of Health and Human Services
Division of Epidemiology
P.O. Box 29601 • Raleigh, North Carolina 27626-0601
Tel: [phone] Fax: [phone]
James B: Hunt Jr., Governor - H. David Bruton, M.D., Secretary
J. Steven Cline, DDS, MPH, Acting Director
MEMORANDUM
TO:
October 2, 1998
Amy Axon
Underground Injection Control Program
Groundwater Section
FROM: Luanne K. Williams, Pharm.D., Toxicologist
Medical Evaluation and Risk Assessment Branch
Occupational and Environmental Epidemiology Section
SUBJECT: Health Risk Evaluation Regarding the Use of Certain Products Manufactured by
Peerless Metal Powders and Abrasive in the Treatment of Groundwater at the
DuPont Kinston Plant in Lenoir County
Ca
1
w
1 am writing in response to a request from Mr. Clifford Lee with DuPont for a health risk
evaluation regarding the use of certain products manufactured by Peerless Metal Powders and
Abrasive in the treatment of groundwater at the referenced site. Based upon my review of the
information submitted, I offer the following health risk evaluation:
WORKER PRECAUTIONS DURING APPLICATION
1. Some effects reported to be associated with the products proposed to be used are as
follows: eye, skin, nose, throat, and lung irritation_ If the product is 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 proper personal protective
equipment should be used. The application process should be reviewed by an industrial
hygienist to ensure that the most appropriate personal protective equipment is used.
2. Persons working with these products should wear goggles or a face shield, gloves, and
protective clothing. Face and body protection should be used for anticipated splashes or
sprays.
3. Eating, drinking, smoking, handling contact lenses, and applying cosmetics should not be
permitted in the application area during or immediately following application.
North Carolina: Host of the 1999 Special Olympic World Summer Games

Amy Axon Memo
October 2, 1998
Page Two
4. Safety•controls should be in place to ensure that the check valve and the pressure delivery
systems are working properly.
5. It is imperative that the Material Safety Data Sheets be followed to prevent incompatible
or adverse reactions and injuries.
OTHER PRECAUTIONS
1. 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.
2. According to the information submitted with the letter dated September 18, 1998, "The
only groundwater production wells within one mile of the study area are DuPont Kinston
Plant wells (used for non -contact cooling water). The nearest public water supply well is
the City of Grifton Well No.2, located 3.4 miles to the northeast. The treatment wall
will be emplaced in the surficial aquifer at the site. This aquifer is not used as either a
public or private source of water; therefore, there will be no impact to any of the
identified wells (which pump groundwater from depths greater than 200 feet). DuPont
Kinston Plant potable water supply is provided by the local municipal water district."
In order to protect public health, it is recommended to confirm the absence of nearby well
users in the area. Measures should be taken to prevent contamination of existing or future
wells that may be located near the application area.
3. According to the information submitted, Beaverdam Branch is the nearest surface water
body located approximately 1,800 feet north of the study area. It is recommended to
contact Ms. Dianne Reid with the Water Quality Section at [phone] extension 568
to determine if these products or process could impact Beaverdam Branch.
If you have any questions, contact me at [phone].
LKW:dg
cc: Ms. Linda Blalock, Groundwater Section
Mr. Bob Cheek, Groundwater Section
Mr. Clifford Lee, DuPont Fibers
Dianne Reid, Water Quality Section

ATA,
NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Coleen H. Sullins Dee Freeman
Governor Director Secretary
April 27, 2009
MEMORANDUM
To: Dr. Mina Shehee
Epidemiology Section
Division of Public Health
Department of Health and Human Services
From: Thomas Slusser, 715-6164; thomas.slusser®ncdenr.gov
Aquifer Protection Section
Division of Water Quality
Department of Environment and Natural Resources
Subject: Health Risk Evaluation Request
Vitamins B2 and B12, Sodium Sulfite, Nutrients, Propionate, Nitrogen Gas
Please find attached package submitted by ATC Associates of NC, who is proposing to use the product
to remediate chlorinated solvents in -groundwater. We request that you conduct a health risk evaluation
for the products.
Please note that some of the materials in the attached package have already been reviewed and
approved: Yeast Extract, Zero Valent Iron, Hydrogen Release Compound, and EHC.
If you need additional information please call or email me or Genna Olson at [phone].
Thank y u
1912 Mail Service Center, Raleigh, NC 27699-1219
AQUIFER PROTECTION SECTION
1636 Mall Service Center, Raleigh, North Carolina 27699-1635
Location: 2728 Capital Boulevard, Raleigh, North Carolina 27604
Phone: [phone] FAX 1: 919-715.0588; FAX 2: 919 715.60481 Customer Service:1-877-623:6748
Internet www.ncwaterauallty orq
An Eauar Opportunity i AfBrmat ee Acton Employer
NorthCaroli a
ativaIty

North Carolina Department of Health and Human Services
Division of Public Health • Epidemiology Section
Occupational and Environmental Epidemiology Branch
1912 Mail Service Center • Raleigh, North Carolina 27699-1912
Tel [phone] • Fax [phone]
Beverly Eaves Perdue, Governor Jeffrey P. Engel, M.D.
Lanier M. Cansler, Secretary State Health Director
MEMORANDUM
TO:
Thomas Slusser
Aquifer Protection Section
Division of Water Quality
May 12, 2009
FROM: Kenneth Rudo, PhD, Toxicologist
MERA/OEEB
THROUGH: Mina Shehee, PhD, Supervisor
MERA/OEEB
SUBJECT: Health Risk Evaluation Request/Swansboro, NC Remediation Site
T have reviewed the information regarding the remediation package submitted by ATC
Associates of Raleigh. They requested a health risk assessment for using numerous materials to
remediate chlorinated solvents in groundwater at a source area in Swansboro, NC that was
previously a dry cleaning facility. After reviewing the. toxicology of the numerous products to be
used in the remediation of this site it appears that the use of these products should not pose an
increased health risk as long as appropriate protective measures to avoid skin and eye contact are
used when handling these products based on information in the MSDS sheets. However, OEEB
has a concern based on a lack of information in the peer reviewed literature and the information
sent to our office for review of potential chemical interactions of these products in groundwater
drinking wells. The large number of individual products combined for the remediation of the
solvents at this site may result in unknown contaminants in groundwater that have not been
addressed in the information available to us for this review. As a result, OEEB would not
recommend using these products for remediation at this site if there are drinking water wells
within 300 feet of the former dry cleaning facility. The information provided to OEEB stated
that ATC Associates believes the nearest wells are 660 feet from the site. Based on this
information, OEEB would recommend an additional site survey to make certain this is the case
and that the results of the follow-up survey are conveyed to Mr.Slusser in the Aquifer Protection
Section.
If you have any further questions regarding this matter, please feel free to contact me at
919-707-5911.
North earolma Public Health
Working for a healthier and safer North Carokna
Everywhere. Everyday, Everybody.
Location: 5505 Si Forks Road, 2"d Floor, Roorn D-1 • Raleigh, N.C. 27609 RECEIVED 1 DENR 1 DWQ
Aquifer Protw'.tikn Section
MAY 14209