WI0400565_Permit (Issuance)_20210219

RECEIVED
FEB 0 8 2021
NC DEQIDWR
Central Office
NCDEQ
DWR-UIC Program
1636 Mail Service Center
Raleigh, NC 27699-1636
February 1, 2021
RE: Notification of Intent to Construct Injection Wells
North Carolina A&T Farm
3136 McConnel Road
Greensboro, NC 27405
Dear Sir or Madam:
Rer
,M.
AxNano is submitting this Notification of Intent to Construct Injection Wells at the subject site to conduct
a small pilot study (approx. 2,500 square feet). Our pilot study is intended to determine whether our
RemRxtm product can be injected, the radius of influence of the injection, and nature of the RemRxtm
product once injected. Injections will be performed using a direct -push drill rig at injection pressures which
may range from 20 to 1,000 pounds per square inch. To assess the injection results, soil borings will be
advanced using a direct -push drill rig. Groundwater quality parameters (conductivity, pH,
oxidation/reduction potential, dissolved oxygen) will also be monitored utilizing existing monitoring wells in
the vicinity of the pilot study site.
Please feel free to reach out to us if you have any questions or concerns.
Sincerely,
Alexis Carpenter, PhD
Principal Scientist
[phone]
[e-mail]
ad —
Jeff Albano, PG
Geologist
[phone]
[e-mail]
2901 East Gate City Blvd, Suite 2200 I Greensboro, NC 27401 1336-217-5171
www.remrxremediation.com

DATE: February 1 , 2021
NC Department of Environmental Quality — Division of Water Resources (DWR)
NOTIFICATION OF INTENT (NOI) TO CONSTRUCT OR OPERATE INJECTION WELLS
The following are `permitted by rule" and do not require an individual permit when constructed in accordance
with the rules of 15A NCAC 02C.0200 (NOTE: This form must be received at least 14 DAYS prior to iniectioal
AQUIFER TEST WELLS (15A NCAC 02C .0220)
These wells are used to inject uncontaminated fluid into an aquifer to determine aquifer hydraulic characteristics.
IN SITU REMEDIATION (15A NCAC 02C .0225) or TRACER WELLS (i5A NCAC 02C .0229):
1) Passive Injection Systems - In -well delivery systems to diffuse injectants into the subsurface. Examples include
ORC socks, iSOC systems, and other gas infusion methods (Note: Injection Event Records (IER) do not need to be
submitted for replacement of each sock used in ORC systems).
2) Small -Scale Injection Operations — Injection wells located within a land surface area not to exceed 10,000
square feet for the purpose of soil or groundwater remediation or tracer tests. An individual permit shall be required
for test or treatment areas exceeding 10,000 square feet.
3) Pilot Tests - Preliminary studies conducted for the purpose of evaluating the technical feasibility of a
remediation strategy in order to develop a full scale remediation plan for future implementation, and where the
surface area of the injection zone wells is located within an area that does not exceed five percent of the land surface
above the known extent of groundwater contamination. An individual permit shall be required to conduct more
than one pilot test on any separate groundwater contaminant plume.
4) Air Injection Wells - Used to inject ambient air to enhance in -situ treatment of soil or groundwater.
5) In -Situ Thermal Wells (IST) — Used to `heat' contaminated groundwater to enhance remediation
Print Clearly or Type Information. Illegible Submittals Will Be Returned as Incomplete.
PERMIT NO. W10400565 (to be filled in by DWR)
NOTE- If this NOI is being submitted as notification of a modification of a previously issued NOI for this site (e.g.,
different injection wells, plume, additives, etc.) and still meets the deemed permitted by rule criteria, provide the
previously assigned permit tracking number and any needed relevant information to assess and approve injection:
Permit No. WI Issued Date:
A. WELL TYPE TO BE CONSTRUCTED OR OPERATED
(1) Air Injection Well .Complete sections B through F, J, M
(2) Aquifer Test Well .Complete sections B through F, J, M
(3) Passive Injection System ...Complete sections B through F, H-M
(4) Small -Scale Injection Operation Complete sections B through M
(5) x Pilot Test Complete sections B through M
(6) In -Situ Thermal (IST) Well Complete all sections except K
B. STATUS OF WELL OWNER: Business/Organization
Deemed Permitted GW Remediation NOI Rev. 2-14-2020 Page 1

C. WELL OWNER(S) — State name of Business/Agency, and Name and Title of person delegated authority to
sign on behalf of the business or agency:
Name(s): AxNano
Mailing Address: 2901 Gate City Blvd. Suite 2200
City: Greensboro State: NC Zip Code: 27401 County: Guilford
Day Tele No.: [phone] Cell No.: [phone]
EMAIL Address: [e-mail] Fax No.:
D. PROPERTY OWNER(S) (if different than well owner/applicant)
Name and Title: Leon Moses/Site Representative
Company Name NC A&T Farm
Mailing Address: 3136 McConnell Road
City: Greensboro State: NC Zip Code: 27405 County: Guilford
Day Tele No.: Cell No.:
EMAIL Address: [e-mail] Fax No.:
E. PROJECT CONTACT (Typically Environmental Consulting/Engineering Firm)
Name and Title: Jeff Albano/Geologist
Company Name AxNano
Mailing Address: 2901 Gate City Blvd, Suite 2200
City: Greensboro
State: NC Zip Code: 27401 County: Guilford
Day Tele No.: [phone] Cell No.: [phone]
EMAIL Address: [e-mail] Fax No.:
F. PHYSICAL LOCATION OF WELL SITE
(1) Facility Name & Address: NC A&T Farm 3136 McConnell Road
City: Greensboro County: Guilford Zip Code: 27405
(2) Geographic Coordinates: Latitude**: 36 ° 03 ' 39 " or °.
Longitude**: 79 ° 44 ' 12 " or °.
Reference Datum: Accuracy:
Method of Collection: Google Earth
* *FOR AIR INJECTION AND AQUIFER TEST WELLS ONLY: A FACILITY SITE MAP WITH PROPERTY
BOUNDARIES MAY BE SUBMITTED IN LIEU OF GEOGRAPHIC COORDINATES.
G. TREATMENT AREA
Land surface area of contaminant plume: N/A square feet
Land surface area of inj. well network: 2,500 square feet (< 10,000 fie for small-scale injections)
Percent of contaminant plume area to be treated: N/A (must be < 5% of plume for pilot test injections)
H. INJECTION ZONE MAPS — Attach the following to the notification.
Deemed Permitted GW Remediation NOI Rev. 2-14-2020 Page 2

(1) Contaminant plume map(s) with isoconcentration lines that show the horizontal extent of the
contaminant plume in soil and groundwater, existing and proposed monitoring wells, and existing and
proposed injection wells; and
(2) Cross-section(s) to the known or projected depth of contamination that show the horizontal and vertical
extent of the contaminant plume in soil and groundwater, changes in lithology, existing and proposed
monitoring wells, and existing and proposed injection wells.
(3) Potentiometric surface map(s) indicating the rate and direction of groundwater movement, plus existing
and proposed wells.
DESCRIPTION OF PROPOSED INJECTION ACTIVITIES AT THE SITE — Provide a brief narrative
regarding the cause of the contamination, and purpose, scope, goals of the proposed injection activity:
Although there is a known release of petroleum hydrocarbons in the vicinity of the pilot study site, ourproposed
pilot study is not associated with remediation of the release. Our pilot study is intended to determine whether
our RemRx" product can be injected, the radius of influence of the injection, and nature of the RemRx"" product
once injected. Injections will be performed using a direct -push drill rig at infection pressures which may range
from 20 to 1,000 pounds per square inch. To assess the injection results, soil borings will be advanced using a
direct -push drill rig. Groundwater quality parameters (conductivity, pH, oxidation/reduction potential. dissolved
oxygen) will also be monitored utilizing existing monitoring wells in the vicinity of the pilot study site.
J. WELL CONSTRUCTION DATA
(1) No. of injection wells: 4 Proposed 0 Existing (provide NC Well
Construction Record (GW-1) for each well)
(2) Appx. injection depths (BLS): 55 feet
(3)
For Proposed wells or Existing wells not having GW-ls, provide well construction details for each
injection well in a diagram or table format. A single diagram or line in a table can be used for
multiple wells with the same construction details. Well construction details shall include the
following (indicate if construction is proposed or as -built):
(a) Well type as permanent, Geoprobe/DPT, or subsurface distribution infiltration gallery
(b) Depth below land surface of casing, each grout type and depth, screen, and sand pack
(c) Well contractor name and certification number
K INJECTION SUMMARY
NOTE: Only injectants approved by the epidemiology section of the NC Division of Public Health. Department
of Health and Human Services can be infected. Approved iniectants can be found online at
http://deq .nc.gov/about/divisions/water-resources/water-resources-permits/wastewater-branch/ground-water-
protection/ground-water-approved-injectants. All other substances must be reviewed by the DHHSprior to use.
Contact the UIC Program for more info if you wish to zet approval for a different additive. However, please
note it may take 3 months or longer.
Injectant: RemRx CRP Total Amt. to be injected (gal)/event: 1,000
Injectant: Total Amt. to be injected (gal)/event:
Injectant: Total Amt. to be injected (gal)/event:
Deemed Permitted GW Remediation NOI Rev. 2-14-2020 Page 3

Injectant: Total Amt. to be injected (gal)/event:
Injectant: Total Amt. to be injected (gal)/event:
Amt. Water to be injected (gal/event): 2,000
Total Amt. to be injected (gal/event): 3,000
No. of separate injection events:1 Est. Total Amt. to be injected (gal): 3.000
Source of Water (if applicable): NC A&T Farm Site
L. MONITORING PLAN — Describe below or in separate attachment a monitoring plan to be used to determine
if violations of groundwater quality standards specified in Subchapter 02L result from the injection activity.
AxNano proposes to monitorgroundwater quality parameters at site monitoring well MW-2 for a period of 6
months post injection. Monitoring will be conducted on a monthly basis. Groundwater parameters to be
monitored include conductivity, pH, oxidation/reduction potential, and dissolved oxygen. In addition to
groundwater qualityparameters, groundwater may be collected for analysis of persulfate, sulfate, and
permanganate.
M. SIGNATURE OF APPLICANT AND PROPERTY OWNER
Well Owner/Applicant: "I hereby cert, under penalty of law, that I 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
injection well and all related appurtenances in accordance with the 15A NCAC 02C 0200 Rules. "
Jeff Albano/Geologist
Signature of Applicant Print or Type Full Name and Title
Property Owner (if the property is not owned by the Well Owner/Applicant):
"As owner of the property on which the injection well(s) are to be constructed and operated, I 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
(15A NCAC 02C .0200)."
"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.
Please refer to attached agreement
Signature* of Property Owner (if different from applicant) Print or Type Full Name and Title
*An access agreement between the applicant and property owner may be submitted in lieu of a signature on this form.
Please send 1 (one) hard color copy of this NOI along with a copy on an attached CD or Flash Drive at least
two (2) weeks prior to injection to:
DWR — UIC Program
1636 Mail Service Center
Raleigh, NC 27699-1636
Telephone: [phone]
Deemed Permitted GW Remediation NOI Rev. 2-14-2020 Page 4

ATTACHMENT A- INJECTION ZONE MAPS

6
0.0
lOf
•
•?c,1, H_
t
O
CD
—I 1
x I t
INC Asa UNIVERSITY 1,41Toull�vJ
EN.0 A:E&T UNIVERSITY FARM I -T. LJ
P 'Ek CiRPFN AOga. `m MOR-1I G RL�,'.A ,UJ
F••fa,a+:trivrtIAt ih=Flr:INFPF:h,A;. P (:� tEX ISOcONC}:UiRATION AtAP t8/5/15} .]'16
,11_1*
{ [ 1_
as sr g=' +; x
1 =An

4t G MVOS
|
ELEVATION
° , \ }
L
! } ƒ < .
§
rir I
,
! — A /�
P z
I �1
at
o
§—
i—
§§
\/
�!z
z
\
1, .
it
,
zI
ft
)
G<
jj
.. :
}; k
! i 1 ` k
I , 1 i \
i I 1
E i r E lr j; / \ \jF \CC
& E a ! s @ 4 a ;
_i

•
r
LS 0
n
O
fD
Z11
PYRAMA I D
I_
Os/
041
ANC A&T UNIVERSITY Cg r/tofu t( j
Et NC A&T UNIVERSITY FARM 111.31 Lt4+J *w 4) t= f4 = n
WiC.R F5RO9O 1111j+IQR'l I C4RC' I`,A .ljlkM Off i»=4,3
131.15¢1tHU)kiEtRIC sURrACE HAP US/ 4/i5]["1)'t•f-'Cff[ 7

ATTACHEMENT B - WELL CONSTRUCTION DIAGRAM

m
BOTTOM -OUT INJECTION SCHEMATIC
SOOZ 'L£ 2l390100
31VOS 01 ION
REDOX TECH, LLC, 200 OUADE DRIVE, CARY, NC 27513
dil 318VON3dX3
r
new
m
m=
0 �Z�
z rnoz
ozo
0
0 m
0
v
30V321fS ONflO ID
SOON 380NdO3O
z

ATTACHMENT C - PROPERTY OWNER CONSENT DOCUMENTATION

NORTH CAROLINA AGRICULTURAL AND TECHNICAL STATE UNIVERSITY
COLLEGE OF AGRICULTURE AND ENVIRONMENTAL SCIENCES
INTERNAL REVIEW FORM AG-02
Intent to Use A&T Farm Land, Facilities, Livestock, Personnel
FrincipLe Investigator
First name
Department
Triad Growth Partners / RemRx
Email
allLOSPO4t.0. • •
A 1 • • ....... • • • • • • • • e
Last name
Carpenter
Phone
[phone]
Project Information
Project Title:?Rx MI injection pilot test
Please indicate the CAES facility/ics you are requesting /or planning to use?
Eirrop Land nAnimal Unit [Green Houses Ell Do not plan to use the farm
/4 Ilive )0\42., U5't t
Moxy
If the pr c ? uses any acilities. answer the question for each checked item.
Yes
Is this a renewal project?
®No
0 Yes (NO
Is this a multi -year project?
If 'Yes', please indicate number ofyears.l2Y8ars
Project start date
41.121/
Project end date
TBD / /
o &e/
? e:-Jk\PUI)

Will this project need to build any farrn structure? 0 Yes 0 No
If "Yes", what type of structure?
Not wfactlysureyet, we may need to bring in some equipment but l do not believe we
will have to build anything.
Ilave you secured funds to build the structures? 0 Yes
Will the facility'ies need electricity, water, heat or cooling? 0 Yes 0 No
L If using Crop Land
What plant/crop are you planning to plant?
Do you have plans of using any genetically modified crops?
No
0 Yes ® No
n; es". identify the genetically modified crop and its status of legal approval, including any state.
federal. etc. approvals.
If "Yes", do you have an adequate containment and management plan?
.... . . 4.0 . ........ ..... p .......... • . ...... 00.4..190..41..00.44,4,0i . • . 4 .. • . ..0 ..................
Please indicate the plot size you arc looking fur and the preferred location (see fan-n map for field#)
The area with the underground storage tanks.
Will you be using pesticides or fertilizers?
0 Yes
® No
If "Yes", list each pesti ide, herbicide and fertilizer to be used and indicate froquency of use:
Do you need irrigation?

If "Yes", please indicate
he
e of irrigation system. you are requesting.
Do you need farm pers
0 Yes No
If "Yes", please indicate the services and duration. you are seeking from N.C. A&T farm personnel.
el?
Do you need any farm equipment?
()Yes ®No
If "Yes", please indicate the farm equipment/s, you are requesting.
2. If using Farm Animals/Livestocks
Which animals are you planning to use?
.................... - - „ - ...... ...... , ..... . ........ ........ . ......
lave you submitted an application to the N.C. A&T IACUC for protocol approval on the use of these
animals?
Has your IACUC application been approved?
OYes ® No
Are you planning to purchase new farm animals? (Yes 0 No
If "Yes", which animals and how many? Please also indicate source of funding.
Do you need a space to house them? 0 Yes No
Do you plan a specific animal feeding or watering reginien?Y s 0 No
If "Yes", please specify

What will happen to the livestock after the project is over?
Do you need farm personnel?
0 Yes
® No
If "Yes", please indicate the services, you are seeking from N.C. A&T fann personnel, and the
duration.
Do you need any farm
0 Ye
Are you planning to use one of the research units? Yes
If "Yes": how you will the unit be used?
quips
3. If using Greenhouse
Are you planting new plants?
How much area will you need?
Do you need farm personnel?
nt?
a
Q
® No
No
Yes ®i No
Yes
No
If "Yes", please indicate the services, you are seeking from N.C. A&T farm personnel, and duration.
Do you need any farm cquipnient/s?
0 Yes
If "Yes". please indicate the farm equipment/s, you are requesting.
Do you need irrigation?
0 Yes @No

1.1"Yes", please indicate the type of irrigation system, you are requesting.
Required Signature
Principal Investigator
Name Alexis Carpenter
Sigriature
Farm Manager
Name- Leon Moses
Signature
"•1
Associate Dean for Research
Name- Dr. Shir ymon-Parker
Signature...
8/31/2020
Date
9.22.2020
Dale