WI0500841_DEEMED FILES_20150529

~ers, Michael
From: Rogers, Michael
Sent:
To:
Thursday, May 28, 2015 3:04 PM
Shire, Ebonee
Subject: FW: Submittal Letter for Notice of Intent Form (NOi) for L.C. Industries for the Blind
WI0500841
This is the acknowledgement email we sent yesterday. Keep this and copy and paste for your use for the next NOi. Just
be sure to make the necessary changes. Thanks.
From: Rogers, Michael
Sent: Wednesday, May 27, 2015 3:25 PM
To: 'Sandy Miller'
Cc: Joe Beaman; William Frederick; Eugene Roddy; Smith, Danny; Bolich, Rick
Subject: RE: Submittal Letter for Notice of Intent Form (NOI) for LC. Industries for the Blind WI0500841
Thank you for submitting the Notke of Intent to Construct or Operate Injection Wells (NOi) at the L. C. Industries for the
Blind. This facility is located at 4500 Emperor Blvd., Durham, Durham County, NC 27703. We received your complete
NOi on May 18, 2015.
Please remember to submit the following regarding this injection activity:
1) Well Construction Records (GW-1) and Abandonment Records (GW-30) when completed. Please provide copies of
the GW-ls and GW-30s if not already submitted (originals go the address printed on the form). NOTE: Direct push
or Geoprobe wells are considered wells and require construction (GW-1) and abandonment forms {GW-30). If well
construction/abandonment information is the same for the wells, only one form needs to be completed-just
indicate total number of injection points in the Comments/Remarks section of form. These forms can be found on
our website at http://portal.ncdenr.org/web/wg/aps/gwpro/reporting-forms.
2) Injection Event Records (IER). All injections, including air and passive systems require an IER. The IER can be
modified for air sparge wells (e.g., air flow 'continuous' for date or rate of injection, etc.).
You can scan and send these forms directly to me at michael.rogers @ncdenr.gov, send by fax to my attention at 919-
807-6406, or via regular mail to address below. When submitting the above forms, you will need to enter the nine-digit
alpha-numeric number on the form (i.e., WI0XXXXXX) that has been assigned to the injection activity at this site. This
notification has been given the deemed permit number WI0500841. This number is also referenced in the subject line of
this email. You may if you wish, scan and send back as attachments in re p ly to this email, as it will already have the
assigned deemed permit number in the subject line.
Thank you for your cooperation.
Michael Rogers, P.G. (NC & FL)
Hydrogeologist
NCDENR -DWR
Water Quality Regional Operations Section
1636 Mail Service Center
Raleigh, NC 27699
Direct No. 919-807-6406
http://portal.ncdenr.org/web/wq/aps/gwpro/reporting-forms
1
NOTE: Per Executive Order No. 150, all e-mails sent to and from this account are subject to the North Carolina Public
Records Law and may be disclosed to third parties.
From: Sandy Miller [mailto:[e-mail]]
Sent: Monday, May 18, 2015 1:24 PM
To: Rogers, Michael
Cc: Joe Beaman; William Frederick; Eugene Roddy
Subject: Submittal Letter for Notice of Intent Form (NOI) for LC. Industries for the Blind WI0500803
Good afternoon Michael,
My apologies; I just noticed that I had omitted the submittal letter in my original email.
I am sending out the hard copy and the submittal letter via U.S. Mail this afternoon to your attention.
Thank you.
Sandy
Sandy Miller
Project Scientist
Highlands Environmental Solutions, Inc.
8410-D Falls of Neuse Road
Raleigh, NC 27615
Office: 919-848-3155
Cell: 919-819-4312
Fax: [phone]
email: [e-mail]
website: www.hesnc.com
Celebrating 10 years of Solutions!
~=
From: Sandy Miller
Sent: Monday, May 18, 2015 12:14 PM
To: 'Rogers, Michael'
Cc: Joe Beaman; William Frederick; 'Eugene Roddy'
Subject: Notice of Intent Form NOi L.C. Industries for the Blind WI0500803
Good afternoon Michael,
Attached is the Notification of Intent to Construct or Operate Injection Wells for the L.C. Industries site.
I am putting the hard copy in the mail this afternoon to your attention.
Please let us know if you have any questions or concerns.
Thank you again for your assistance on this.
Sandy
Sandy Miller
2
Highlands
Environmental
�::, o l ut ions, Inc. 8410-D Falls of Neuse Road; Raleigh, NC 27615
Phone 91 "48-3 f 551 Fax: 91 "48-4265 / www.hesnacom
May 18, 2015
Mr. Michael Rogers
NCDENR — Department of Water ResourcesQROS
rC
512 N. Salisbury Street RECEItt►►EDIDENRIDNN
Raleigh, North Carolina 27604
MAY 2 9 2015
Subject- Submittal of Notification of Intent to Construct or Operate Injection Wells Wat9rQuauty
L.C. Industries, Inc. - Diesel Fuel Release PermitUn j Section
4500 Emperor Boulevard, Durham, Durham County, NC
NCDENR Incident No: 92274
HES Project #202003
Dear Mr. Rogers. -
On behalf of L.C. Industries, Inc., please find enclosed an original copy of our Notification of Intent to
Construct or Operate Injection Wells for the proposed in -situ remediation of petroleum -impacted soil
activities at the subject site. The diesel fuel release resulted from the failure of an underground product
line, and impacted an unpaved area immediately surrounding two aboveground storage tanks (ASTs),
owned by LCI and located at the subject site. Additionally, the release impacted an underground
electrical conduit housing three-phase power lines maintained by Duke Energy, an unpaved area near a
light pole, and a paved parking lot located immediately southeast of the ASTs. The electrical conduit
appears to have acted as a preferential pathway for product migration; allowing for the product to migrate
to the second area southwest of the AST area, where the product surfaced adjacent to a light pole and
concrete walkway.
Emergency remediation activities and soil excavation activities have been performed, as well as
performance and submittal of a Comprehensive Site Assessment (CSA) and a Corrective Action Plan
(CAP), The CAP, which was approved on July 8, 2014, and proposed an in -situ remediation program for
the remaining petroleum -impacted soils. This NOI is being submitted as fulfillment of the approval
process.
If there are any questions regarding this correspondence, or the project In general, please contact me at
[phone].
Sincerely,
Highlands Environmental Solutions, Inc-
.
Sandra Miller
Project Scientist
Enclosure
cc, Mr- Eugene Roddy — L. C. Industries, Inc_

NORTH CAROLINA DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
NOTIFICATION OF INTENT 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. This fo rm shall be submitted at least 2 weeks prior to iniection.
AQUIFER TEST WELLS 0 5A NCAC 02c .0220 )
These wells are used to inject uncontaminated fluid into an aquifer to determine aquifer hydraulic characteristics.
IN SITU REMEDIATION (1 5A NCAC 02C .0225 ) or TRACER WELLS (1 5A NCAC 02C .0229):
1) Passive Injection S y stems -In-well delivery systems to diffuse injectants into the subsurface. Examples include
ORC socks, iSOC systems, and other gas infusion methods.
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 are 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.
Print Clearly or Type Information. Illegible Submittals Will Be Returned As Incomplete.
DATE: --~M=a ..... v ~7 _, 201.L_ PERMIT NO. L,.J( ()';{ (X) g L/ \ (to be filled in by DWR)
A. WELL TYPE TO BE CONSTRUCTED OR OPERATED
(1)
(2)
(3)
(4)
(5)
(6)
___ Air Injection Well ...................................... Complete sections B-F, K, N
___ .Aquifer Test Well ....................................... Complete sections B-F, K, N
___ Passive Injection System ............................... Complete sections B-F, H-N
=X~ __ Small-Scale Injection Operation ...................... Complete sections B-N
___ Pilot Test ................................................. Complete sections B-N
___ Tracer Injection Well ................................... Complete sections B-N
B. STATUS OF WELL OWNER: Business/Organization
C. WELL OWNER-State name of entity and name of person delegated authority to sign on behalf of the business
or agency:
Name: Mr. Eugene Roddy
Mailing Address: 4500 Emperor Boulevard
City: Durham State: NC
Day Tele No.: 919-596-8277 ext. 2265
EMAIL Address: [e-mail]
UICI In Situ Remed. Notification (Revised 3/2/2015)
Zip Code: 27703 County:_D~ur~h~am~---
Cell No.: 336-392-0715
Fax No.:
Page 1
D. PROPERTY OWNER (if different than well owner)
Name: -----=N""'A'--"---------------------------------
Mailing Address:---------------------------------
City: ____________ State: __ Zip Code: _______ County: _____ _
Day Tele No.: ___________ _ Cell No.: ------------
EMAIL Address: _____________ _ Fax No.: ------------
E. PROJECT CONT ACT -Person who can answer technical questions about the proposed injection project.
Name: Sandra Miller
Mailing Address: 8410-D Falls of Neuse Road
City: Ralei gh State: NC Zip Code: 27615 County:_W~ak=e ___ _
DayTeleNo.: 919-848-3155 Cell No.: 919-819-4312
EMAIL Address: smiller@b esnc.com Fax No.: __ ....a.9-=19=------=84"""'8"-----4--"2=6=5 ___ _
F. PHYSICAL LOCATION OF WELL SITE
(1) Physical Address: ___ L=·~C~·~In=d~u=s=tn=·e=s ~In~c.'------------------
___ 4--=5~0~0_E_m_p_er~or_B_o~u~l~ev~ar~d ____________ County: Durham
(2)
City: ---~D=ur=h=a=m=------------State: NC Zip Code: ---=2"-'-7-"-70=3'-----------
Geographic Coordinates: Latitude**: ___ 0 ____ " or --22_0 .=87"""3"'"4""'8 .... 4'------
Longitude**: 0 __ " or __ --"-7~8 °.838443
Reference Datum: ~37~8~'-_____ Accuracy: _______ _
Method of Collection:--'G=o=o=-<g=>=l=-e=M=a=-p=s ____________ _
**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:_<--=3~0~0~0~ ___ square feet
Land surface area of inj. well network: __ <--=3-0~0~0'--__ square feet ts 10,000 ft2 for small-scale injections)
Percent of contaminant plume area to be treated: 100 (must be~ 5% of plume for pilot test injections)
H. INJECTION WNE MAPS -Attach the following to the notification.
(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.
UIC/ln Situ Remed. Notification (Revised 3/2/2015) Page2
I. DESCRIPTION OF PROPOSED INJECTION ACTMTIES -Provide a brief narrative regarding the
purpose, scope, and goals of the proposed injection activity. This should include the rate, volume, and duration
of injection over time.
See attached in fo rmation fi'om 3tier.
J. INJECT ANTS -Provide a MSDS and the following for each injectant. Attach additional sheets if necessary.
NOTE: Approved injectants (tracers and remediation additives) can be found online at
http://portal.ncdenr.org/web/wq/aps/gwpro . All other substances must be reviewed by the Division of Public
Health, Department of Health and Human Services. Contactthe UIC Program for more info (919-807-6496).
Injectant: __ ....::S=e=e'--'a=t=ta=c=h=ed"'"""'"in ... fo""rm'-"""'a=t=io'"'"n._.fr .... o=m=-=3~ti=·e.,__,r.'------------------
Vo1ume ofinjectant: ___________________________ _
Concentration at point of injection: ______________________ _
Percent if in a mixture with other injectants: ___________________ _
Injectant: --------------------------------
Volume of injectant: ___________________________ _
Concentration at point of injection: ______________________ _
Percent if in a mixture with other injectants: ___________________ _
Injectant: --------------------------------
Volume of injectant: ___________________________ _
Concentration at point of injection: ______________________ _
Percent if in a mixture with other injectants: ___________________ _
K. WELL CONSTRUCTION DATA
(1) Number of injection wells: --=2=-5 -'---Proposed'---_____ Existing
(2) Provide well construction details for each injection well in a diagram oi-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:
(a) well type as permanent, direct-push, or subsurface distribution system (infiltration gallery)
(b) depth below land surface of grout, screen, and casing intervals -see attached figure
(c) well contractor name and certification number -Quantex, #3106
UIC/ln Situ Remed. Notification (Revised 3/2/2015) Page 3
L. SCHEDULES - Briefly describe the schedule for well construction and injection activities.
Prior to the detailed activities. HESanticWates completion ol-threepreliminan, tasks: abandonmentol
one damaged well. minor r Jairs to three other existin wells. and co )letion o -a baseline sampling session:
Well construction of the injection wells can begin upon NCDENR's authorization to gnKeed. continUent on the
time schedule of the drilling contractor and the availabilin of the Stier personnel beinvp for set--ulp o1 the
M. MONITORING PLAN - Describe below or in separate attachment a monitoring plan to be used to determine
if violations of groundwater quality standards specified in '�ulhchwipter Q2L result from the injection activity.
See attached in ormation from Stier.
N. SIGNATURE OF APPLICANT AND PROPERTY OWNER
APPLICANT: "I hereby certify, underpenalty of law, that am familiar with the information submitted in this
document and all attachments thereto and that, based on my inquiry of those individuals immediately responsible
for obtaining said information, 1 believe that the information is true, accurate and complete. 1 am aware that
there are significant penalties, including the possibility of fines and imprisonment, for submitting false
information. I agree to construe; operate, maintain, repair, and ij'applicable, abandon the injection well and
all relatd appurtenarteg-in—avrvrdance with the )JA NCAC 02C U2f/0 Rules. "
Print or Type dull Name
"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 b jection 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
"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. ement in 'writing.
C4(5 en e- l eaeld
Signsti-re,�rroperty Owner Off diii'ereny�ry applicant) Print or Type Fsa. ! meet between the applicant a d property owner may be submitted in lieu of a signature on thisform.
Submit the completed noflfication package to:
DWR - UIC Program
1636 Mail Service Center
Raleigh, NC 27699-1636
Telephone: [phone]
UI0A Shu Remed. Notification (Revised 312/2015) Page 4

CA% N,
Ul 280
F592111
Eidt 292
29
ev
Mperor IJ6d
Approximate 'Olwa—
Site Location`,
.............. .. ........ ............ . .... ......
t4O Ut J
4vd
ExA 2840
FAM4
ki
CNY
E)dt
APPMXbMb fta%
0.45 0.90
miles
Source: Microsoft Streets & Trip, 2002 Site Location Diagram
Pfvjod Name Injection Permit
Durham, North Carolina
t
Z: Highlands Chen!
Environmental LC Industries, Inc.
PnVOGI # Drawn by
Solutions, Inc. 202002 SM
Appvxkn9ft Scma Date Rg. #
scale as Noted I December 2014 1

r,
Ism
r
- - • !'''�" Z"16
'e. !
Site Location --TIF r '�
s :Cem
-- _re,
� — ,t _.sir_ r • � � ` „�
_ C_�
. � off. r� -- .� �► ��� t �^ � i`•
JV
i r
ApprmWmaft 5e a%
0 1500 3000 N
188t
Base diagram from Cary, NC, 9:24000
7.5 Minute Topographic Quadrangle,
2002. Topographic Location Diagram
Project Neme Injection Permit
Highlands Durham, North Carolina
C&M
Environmental LC Industries, Inc.
Solutions, Inc. A*d# 202002 ran by SM
Scales I Date ft. #
As Shown December 2014 2

to chemical
storage vessel
Flush Mount Casing
COnCrete
_ Schedule 40 PVC Casing
(approximately 2 ft.)
Meat Portland Cernent Grout
Hydrated Bentonite
p (1.0 feet)
C '
jI ^C^,
111 cY7 ++� Clean sand
o a
F-
C
0.
rn -
Schedule 40 PVC Manufactured Screen
m(0,010 Slot)
_ (5 ft.)
m -
Q
Hlghlsnds Injection Well
Ei Schematic Diagram
Not to Scafa Environumfti LC Industries, Inc.
4500 Emporer Boulevard, Durham, NC
ar...a. w, pr GwWMdI. 6Ya�M1h a,. — - � 4afnQ
8F J8 202002 November2014 12

*mifL1 V;WL
TECHNOLOGIES
Treatment Solutions for Soil Contamination
Highlands Environmental Solutions - LC Industries / Durham, N.C.
Site Description:
The subject site, LC Industries Inc, is located in Durham North Carolina. The original impacted area was
the result of storage tank release. The original work plan utilized the dig and haul method of
remediation. Due to underground infrastructure, pipes and utility lines, the full scope of material
removal was limited and the result was continued impact of the hydrocarbon contaminants. The next
phase of remediation will require a technique that allows for remediation material to be added to site
through in -situ methods and encouraged to travel multiple pathways around the pies and limited access
areas to reach the target residual contaminants.
The three original excavation locations are still exhibiting unacceptable levels of Naphthalene and
Methylnaphthalene. It is not unusual in sites that are not able to fully excavate the target areas to exhibit
a level of rebound or continued influence from the contamination outside the treatment areas. The
following recommendations are based on the three target areas supplemental treatments of an in -situ
remediation process.
Technology Overview:
3 Tier Technologies LLC is a green science and technology company focused on developing innovative
and sustainable materials, processes and applications to optimize in -situ bio-remediation of soils and
water Contaminated by hydrocarbons and other various organic constituents. 3 Tier focuses our efforts
on the use of "Green Technology' that uses significantly Iess equipment, labor, and fuel to execute while
remediating harmful contaminates in -situ. "Green Technology'' is a solid movement to identify products
and methods to clean up various contamination sites without extensive use of equipment that can emit
harmful pollutants to perform the required task and establish systems that allow for material to be
recycled and/or re -used after completing the projects.
To achieve maximum performance in these various treatment processes, 3 Tier Technologies has
discovered that current products offered in today's markets offer a single solution that only impacts
either bio-augmentation or bio-stimulation. The development of a complete regeneration and cleaning
solution would not only enhance the remediation of contaminates, it would also regenerate contaminated
soils and groundwater to a healthy and active state for effective and safe re -use. 3 Tier achieves a
complete regeneration/cleaning system with a suite of products that uses various recipes consisting of
three distinct yet synergistic components, a blend of activated organic bio-polymers derived from very
stable, organic compounds found in brown and oxidized black coal, a ultra high concentration of live
synergistic bacteria, and a readily biodegradable natural enzyme product consisting of a nutrient -rich
extract with a broad-spectrum package of identifiable enzymes, coenzymes, amino acids and other
proteins. These multi -action products are able to degrade common organic constituents with minimal
use of equipment, labor and cost
co
250 National Place. Suite 142. Longwood FL, 32750 • www.3166dech.com • 877-226-70B

Treatment Product
Soll Rx -Soil Rx is the ultimate heavy lifter in hydrocarbon remediation and utilizes a new approach to
solving soil and water hydrocarbon contamination problems. Specially formulated for safety,
effectiveness and environmentally friendliness, Soil Rx utilizes a blend of Polyelectro]yte Enhanced
Biopolymers (PEB), a ultra high concentration oflive synergistic bacteria, and a readily biodegradable
natural enzyme product consisting of a nutrient-rich extract with a broad-spectrum package of
identifiable enzymes, coenzymes, amino acids and other proteins. This triple action product is able to
degrade hydrocarbons with minimal use of equipment, labor and cost Soil Rx's liquid form and low cost
make this a.n easy to use cost effective means for industries to eliminate hydrocarbon contamination
problems that consist of gasoline, jet fuels, diesel fuels, grease, tar, motor oils, crude oils, solvents, etc.
Soil Rx is NCP Listed**.
Disclalme,..*
Soil RX is on the U.S. Environmental Protection Agency's NCP Product Schedule. This listing does NOT mean that EPA approves,
recommends, licenses, certifies, or authorizes the use of Soil Rx on an oil discharge. This listing means only that data. have been
submitted to EPA as required by subpart] of the National Contingency Plan, Sec. 300.915.
Ireabnent Method & Rates;
Due to the relative size of the area to be remediated, 3 Tier recommends applying Soil Rx using a
modified bore-n-pour method of application. This method will provide maximum control and saturation
of the soil that will ensure proper penetration of the product to come in contact with the contaminants
while utilizing the established pathways that the current contaminants are currently using around the
pipes and infrastructure. This method will require a minimal number of injection points per location that
will remain in-place until the process is completed.
3 Tier recommends the use of a 2" GeoProbe direct push unit to establish the required injection points
per location. The approximate depth of each hole will be 7.5' to 8'. These points will then receive one
section of 1" slotted pipe (bottom section) and one section of solid riser. Each injection point is to be
sand filled and capped with Bentonite. After initial injection process, pipes will trimmed flush with the
ground and capped while remaining in-place until no further action notice is received. Established points
may be re-used at a later date for spot treatments or removed after completion. No further equipment
requirements will be needed after initial injection point establishment.
Soil Rx is the remediation workhorse in our suite of hydrocarbon products and must be diluted with
water prior to use. The target goal is to apply 20 ounce of Soil Rx concentrate per cubic yard of soil to be
treated. As previously stated, the work will focus on three target areas that continue to exhibit hot spots
after excavation. Target area One known as Area "C" measures 15' by 18' with approximately 60 cubic
yards of material to treat. Target area Two lmown as Area "A" is approximately 28' by 20' with
approximately 165 cubic yards of material. Target area Three known as Area "D" measures 48' by 20'
and has approximately 275 cubic feet ofmaterial. Though the standard dilution rate is 10 to 1 with the
standard application rate being 1 to 1.5 diluted gallons per cubic yard, for this application, 3 Tier
recommends that the dilution rate be increased to 20 to 1 to ensure proper coverage and moisture
content with the application rate being three gallons diluted material per cubic yard. Therefore, 75
gallons of Soil Rx concentrate will be diluted in 142 5 gallons of clean water for the previously described
areas. Area "C" will require 180 gallons of diluted material, Area "A" will require 495 gallons of diluted
material, and Area "D" will require 825 gallons of diluted material.
Areas "A" and "C" will require 5 injection points each, and Area "D" will require approximately 15
injection points. As previously mentioned these injection points will remain avaHable for use until the
project is completed thus saving potential additional costs for equipment usage. Injection point detail is
available upon request or will be provided prior to work commencement.
Areas "A" and "C" will can be plumbed to on 275 gallon IBC tote which would require Area "C" to be filled
twice while Area "D" will use two separate totes for each half of the area requiring just one fill each.
Tanks and plumbing will remain in-place until all material is absorbed into the injection points and
removed and stored until areas are tested and the need for any additional treatments is determined. Due
to the soil types, initial product application may require up to one week though our experience and past
excavation has shown that material may only need a day or so.
The target areas should be sampled 45 to 60 days after treatment. After the subject results are available,
3 Tier review progress and make further site recommendations. Should additional applications be
required, they will be performed using existing injection points as determined by 3 Tier and HES
personnel.
3 Tier recommends that the site work commence in the spring, once the soil temperatures begin to rise
after the winter cool temperatures. 3 Tier will provide a technical support person for the initial work as
technical support for this project
The following application protocol has been provided by Daniel J Burdette, President, 3 Tier Technologies
LLC. Please contact us for clarification, regulatory clarifications, or schedule technical support.
3tfer
TECHkOL0411Eg
MATERIAL SAFETY DATA OWEET
PRODUCT: Sic -Regan Soil Rx
Section 1— Chemical Product & Company Identification J
Trade Name: Bia-Regen Soil Rx
Chemical Family: Mbdure
Product Description: A concentrated blend of organic biopolymers, bacterial cultures, and amino
acids that is non -hazardous.
Manufacturer: 3 Tier Technologies, LLC
260 National Place, Suite 142, Longwood, FL 32750
Technical Support: 877-226-7498
Chemical Emergency: 407-808-4653
Issue Date: 07/24/2012 Supersedes Date: 02J13=12
Section 2 -- Hazards Identification
Emergency overview: Avoid contact with eyes. Mild skin irritation.
Potential health effects:
Eyes: Contact with eyes may cause severe irritation.
Skin: May cause imitation upon prolonged contact.
inhalation: None known
Ingestion: May cause irritation/nausea if ingested in large quantities
Section 3 — Composition I Information on Ingredients
Components CAS # Percent
Sol[ Rx is a blended composition "not considered hazardous" under the OSHA Hazard Communication
Standard CFR Title 29 1910.1200. All ingredients appear on the EPA TSCA Inventory.
All Bacillus Bacteria contained in this product are DSL Listed and Compliant.
Organic Blopolyrner 141 "3-6 50%
Amino Acids Various 10°%
Bacillus Bacteria ATCC 18250-7 15%
RO Water 7732-16-5 25%
Ingredients of a1°% have been added to a non -hazardous liquid organic substrate.
Active components <15°% are identified above
Section 4 -- First Aid Measures J
First aid procedures
Eye contact: Immediately flush eyes with plenty of water for at least 15 minutes. Seek
medical attention if irritation persists.
Skin Contact: Flush skin with large amounts of water. Remove any contaminated clothing and wash
before reuse. Seek medical attention if irritation occurs.
O 2012 3 T of Teckndapiw. LLC. -Ph: 877-2241-74BB-wwW_UwNtech_wm- WDS BAD -Re rt Shc Rt
Page 1 of 4

Inhalation:
Ingestion:
If symptoms are experienced, remove source of contamination and/or move
victim to fresh air. If breathing is difficult, have trained personnel administer
oxygen. If respiration stops, have trained personnel administer artificial
respiration. Get medical attention immediately.
Give large amounts of water. Do not induce vomiting. If vomiting occurs prevent
aspiration by keeping victim's head below the knees . Get immediate medical
attention.
I Section 5 -Fire Fi g htin g Measures
Flash Point: None
Extinguishing
Media: Water fog or fine spray, carbon dioxide, dry chemical or foam. No special
requirements
Fire fighting
Protection: As in any fire, wear self-contained breathing apparatus pressure-
demand, MSHA/NIOSH (approved or equivalent) and full
protective gear.
I Section 6 -Accidental Release Measures
Personal
Precautions: Isolate area. Keep unnecessary personnel away. Keep out of low areas. Ventilate
closed spaces before entering. Use of safety glasses and impervious gloves
recommended.
Environmental
Precautions: Prevent further leakage or spillage if safe to do so.
Methods for
Containment: Prevent entry into waterways, sewers, basements or confined areas.
Methods for
Clean-up: Wear appropriate protective equipment and clothing during clean-up.
Large spill: Use a non-combustible material like venniculite, sand or earth to soak
up the product and place into a container for later disposal. Dispose in
accordance with all local, state and federal regulations.
Small spill: Follow same procedure as above.
I Section 7 -Handling and Stora ge
Handling:
Storage:
Avoid contact with skin and eyes. Wash hands thoroughly after handling.
Store this product below 120"F (49"C), preferably below 75"F (24"C), in a cool, dry,
well ventilated area away from heat, sparks, flame, oxidizers and out of direct sunlight.
For best results, use within 24 months.
~ 2012 3 Tier T echnologles, LLC. -Ph: 877-226-7498 -www.3tiertech .com -MSDS Bio-Regen Soll Rx
Page 2 of 4
I Section 8 -Ex posure Controls, Personal Protection
Personal Protection
General: Eye wash fountain is recommended. Minimize exposure in accordance with good
hygiene practices. Keep out of reach of children.
Eyes: Wear chemical goggles.
Skin: Suitable protective clothing is recommended but not required. Use impervious gloves.
Respiratory: None required for recommended use. Avoid creating aerosols in poorly ventilated
areas.
I Section 9 -Ph ysical & Chemical Properties
Vapor Pressure:
Vapor Density (air = 1 ):
Equivalent to Water
Equivalent to Water
1.0 approx. Specific Gravity:
Solubility in water:
voe:
Appearance:
pH:
Bolling Point:
Flash Point:
Freezing Point:
Evaporation Rate:
Weight:
Odor:
99%
Negligible
Brown/Black Liquid
6.0 to 8.5
> 212" F (100° C)
None
< 32. F (O" C)
Not Determined
8.7 -9.2 lbs. /gallon
Mild citrus odor
I Section 1 O -Stabillty & Reactivi ty
Chemical Stability: Stable at normal conditions.
Incompatible Materials: Strong oxidizing agents, alkalis
Hazardous Decomposition
Products: None known.
Conditions to avoid: See Section 7.
Hazardous Polymerization: Will not occur.
I Section 11 -Toxicology Information
Toxlcology data: Not available.
I Section 12 -Ecolog ical Information
Ecotoxicity: Readily biodegradable.
[ Section 13 -Dis posal Considerations
Disposal instructions: Dispose in accordance with all applicable regulations. All wastes must be
handled in accordance with local, state and federal regulations. Regulations
vary.
C 2012 3 iler Technolog ies, UC. -Ph: en-226-7498 -www.3liertech.com-MSOS Blo~egen Soil Ric
Page 3 of 4
I Section 14 -Trans p ortation Information
General information:
US DOT:
Non-hazardous.
Not regulated.
Proper Shipping Description: Class 55
I Section 15 -Re gulato ry Information
TSCA Inventory Status: This product and/or all of its components are either included on or
exempt from the TSCA Inventory of Chemical Substances.
DSL (Canada): This product and/or all of its components are either included on or
exempt from the Domestic Substances List.
I Section 16 -Other Information
HMIS ratings:
NFPA ratings:
Disclaimer:
Health: 1
Flammability: O
Physical hazard: 0
Health: 1
Flammability: O
Reactivity: 0
The data and recommendations presented herein are based upon research of
others and are believed to be accurate. However, no warranty is expressed or
implied regarding this data or the results to be obtained from the use thereof.
The manufacturer assumes no responsibility for the injury to customers or
third persons proximately caused by the material if reasonable safety
procedures are not adhered to as stipulated in the data sheet. Additionally,
sine actual use by others is beyond our control, no guarantee, expressed or
implied, is made by the manufacturer as to the effect of such use, the results
to be obtained or the safety and toxicity of the product nor does the
manufacturer assume any liability arising out of use, misuse, by others, of the
product herein. Information provided herein is provided solely for the
customer's assistance in complying with the occupational safety and health
act of 1970 and regulations there under. Any other use is prohibited.
C 2012 3 Tier Technologies, LLC . -Ph: 877-226•7◄98-www.3tiertech.aim-MSDS Bio-Regen Soll Rx
Page 4 of4
x* A UNM D STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON. D.C. 20460
NOY 17 2010
Mr. Daniel J. Burdette
3 Tier Technologies, LLC OWCE of
2302 Mercator Drive soon WAM AND
n3te 02 EME WENCY F ESMNSE
Orlando, FL 32807
Dear Mr. Burdette,
Thank you for providing the technical product data required by the National Oil and
Hazardous Substances Pollution Contingency Plan (NCP), 40 CFR Part 300, on your product "Soil
Rx (alb Bin-Regen Hydrocarbon)." Auer conducting our review, your data submissions have
satisfied the requirements contained in Title 40 of the CFR section 300.915 of the NCP. "Soil Rx
(aka, Bio-Regen Hydrocarbon)" will be listed on the NCP Product Schedule under the
Bioremediation Agent category and may be authorized for use by Federal On -Scene Coordinators
in accordance with 40 CFR section 300.910. The technical data for this product will be kept on
file by the Of17ce of Emergency Management Regulation and Policy Division Oil Program Center
pursuant to 40 CFR section 300.920.
Enclosed are some of the relevant provisions in the NCP on restrictions regarding the
listing of your product Please now, you are required to notify the Environmental Protection
Agency (EPA) of any changes in composition, formulation, handling procedures, or application of
your product. Based on this notice, EPA may require retesting of the product.
Also, note that the listing of "Soil Rx (aka, Bio-Regen Hydrocarbon)" on the NCP Product
Schedule does not constitute approval, certification, authorization, licensing or promotion of the
product; not does it imply compliance with any criteria or minimum standards for such agents.
Failure to comply with these restrictions or the making of any improper refemnee to EPA in an
attempt to demonstrate approval or acceptance of the product will constitute grounds for removal
of the product from the schedule.
Please review the enclosed information and contact Ms. Leigh DeHaven in the Office of
Emergency Management at [phone] if you have any corrections or questions.
Sincerely,
. .
12.
R. Craig Matthiessen, Director
Regulation and Policy Development Division
Office of Emergency Management
Interw Address (URL) ■ tWJAmww,a &*w
-lop CUKUPAPU 1abTQ • Prlr't9d W F1 VNpntsb4 Qi Based Inks on I OD% Poetcorvwner, P odM (>dcd sa Fm SacyaW Papa,-

CERTIFICATE OF ANALYns
3 Tier Technologies, LLC Case Number:
Reported To: 2302 Mercator Dr. Date Received:
Suite 102 Date Reported:
Orlando, FL 32807
Product: SOIL-RX
Lot Number: 100501 ]9018
Overview:
Triad Forensics
IrldependfftSffvke I,abomw y
341 Technology Way Spite 167 Lab 1
Winston-Salem, North Carolina 27101
Tel [phone] Fax [phone]
UH L- www.triaftrensic.com
TFL-10-0721
7/21 /2010
08/25/2010
Test Method: U.S. EPA Appendix C to Part 300
Swirling Flask Dispersant
Test Name: Effectiveness Test, Revised Standard
Dispersant Test, and Bioremediation
Agent Effectiveness Test
In addition to gravimetric analysis, normal alkanes as well as the more highly resistant and
toxic polynuclear aromatic hydrocarbons (PAHs), were monitored using High Resolution Gas
Chromatography Mass Spectrometry (GC/MS) to quantify changes in the oil composition resulting
from biodegradation during a 28-day effectiveness study for SO] L-Rx®i. The bioremediation
effectiveness test was performed Using a Shimadzu GC-2010 with AOC-20i auto sampler. The GC/MS
was operated in the selective ion -monitoring mode (SIM mode) at a scan rate greater than LS scans
per second using Helium as the carrier gas. All other instrument settings and analytical procedures
follow U.S. CPA Method 8270 and the configuratian and calibration section of reference text A; see
below, Concurrent microbiological analyses were performed to determine and monitor the viability
of the microbial cultures being studied. ASCLD-LAB International approved laboratory notebooks
were maintained to document the chemicals, media, surrogates, stock solutions, standards, and
reagents used to perform the 28-day effectiveness study. Effectiveness testing was conducted using
triplicate samples of the following: controI2, nutrient3, and product? Control and treatment flasks
were sampled three times over a 28-day period: day 0, day 7, and day 28.
3 Manufactured by 3 Tier 7bc:hnologies
I Control samples contain approximately 0.5 grams of reference ail and brought to a final volume of 1000-mL with non -sterile
seawater
a Nutrient samples contain approximately 0.5 grams of reference oi1,10-mL of N&P Salt solution, 2 - m L solutions 2-5, and brought to a
final volume of 1000-mL with non -sterile seawater.
4 Product samples contain approximately 0.5 grams of refe rence eil, 10-mL of N&P Salt solution, 2-mLof solutions 2.5, and brought to
a final volume of 1000-mL with 1:10 diluted Soil- RxO/non-sterile seawater soIutian.
Page 1 of 3

The effectiveness study was performed using the test methodologies described in the
following texts:
A EPA Appendix C to Part 300 -Swirling Flask Dispersant Effectiveness Test, Revised
Standard Dispersant Test, and Bioremediation Agent Effectiveness Test
B. 40 CFR part 300 -National Oil and Hazardous Substances Pollution Contingency Plan
C. L.T. McCarthy, Jr., I. Wilder, and J.S. Dorrier. Standard Dispersant Effectiveness and Toxicity
Tests. EPA Report EPA-RZ-73-201 (May 1973).
Every attempt was made to comply with all requirements and quality guidelines for conducting
effectiveness testing. In the referenced test methods, certain resources, chemicals, or equipment
were no longer available. As a result, equivalent substitutes were used to facilitate rigorous testing
and evaluation of the bioremediation product studied. The equivalency of substitute chemicals was
cietermined by comparative assessment of the mass spectra data5 for both the original and all
potential substitute chemicals. Substitutions of equipment mentioned in the reference texts were
made after consulting with the device manufacturer and examining equipment and/or software
manuals.
Independent Laboratory Results:
Data Table 1: Bioremediation Agent Effectiveness Test Data
Sample Description CONTROL NUTRIENT SOIL-RX® PRODUCT
Day of Collection DayO Day7 Day28 DayO Day7 Day 28 DayO Day7 Day28
Gravimetric Results (mg)* 496.20 458.24 456.24 491.03 487.03 454.52 497.65 482.93 347.64
IM krobial Viability ad Activity <3.0 <3.0 <3.0 <3.0 3.6 7.4 43 >1100 >1100
(MPN/g)
GC/MS Results Total Mean 34908.9 35206.2 34287.8 34863.3 32894.1 32610.0 34993.0 24446.0 17597.0
Alkanes (oo m )*"'
GC/MS Results Total Mean 6051.3 5720.9 5892.7 6047.4 5745.8 5205.1 6069.0 3219.2 1600.1
Aromatics (oom)**
Percent Reduction in Total 1.779% 6.463% 49.713%
!M ean Alkanes after 28 Days
lP ercent Reduction in Total 2.621% 13.928% 73.635%
Mean Aromatics after 28 Days
• Gravimetric results are averages of the three replicate studies performed on each sample (ControL Nutrient, and Product) for each
sample day (Day 0, Day 7, Day ZS).
"GC/MS results of averaged total aromatic compounds of the three replicate studies performed on each sample (Control, Nutrient,
and Product) for each sample day (Day 0, Day 7, Day ZS). Total of nine samples per day sampled (Three for Control, Nutrient. and
Product on Day 0, three for Control, Nutrient, and Product on Day 7, and three for Control, Nutrient, and Product on Day ZS).
5 Obtained by a serial dilution and three point calibration curve
PageZof3
Effectiveness testing for the control, nutrient, and product samples was conducted in
triplicate. Minor qualitative changes were noted for the oil fraction in the nutrient and control
sample flasks for bays 7 and 28. However, no observable changes in either color or turbidity were
noted for the nutrient and control samples during the 28-day test period. For all three of the product
flasks, significant qualitative changes in the sample solution's turbidity, coloration, and volume of the
oil fraction were noted. The qualitative changes to the oil fraction layer in each of the samples were
verified quantitatively using U.S. EPA Methods 1664 (gravimetric) and 8270 (Characterization of
Volatile Organic Compounds).
Upon termination of the effectiveness study, a significant reduction in hydrocarbons was
documented for the product samples containing the bioremediation agent in Soil-Rxg. The
microbial viability and activity was maximal for the Soil-Rx@ product samples assayed on day 7 and
day 28. The data obtained from testing those samples indicates that a strong correlation exists
between Soil-Rx§ microbial activity and hydrocarbon compound reduction. The product samples
indicate that the microbes in the Soil-Rx® product are highly effective in reducing hydrocarbon
compounds in a time period of less than 28 days.
Laboratory Statement of Qualifications (SOQ):
Triad Forensics Laboratory (TFL) is compliant with ISO/ IEC 17025:2005, EPA, FDA, NELAC,
AOAC, and ASCLD•LAB International accreditation guidelines for independent testing laboratories.
We are audited and conduct external proficiency tests at feast twice annually to maintain all
accreditations and certifications. All laboratory equipment and instrumentation are calibrated in
accordance with ISO/IEC 17025 guidelines. TFL is certified by, registered with, and operates in the
State of North Carolina.
END OF LABORATORY REPORT
Reported By:
Lauren A. Stainback
Forensic Laboratory Director,
Member AOAC, APHA, and NELAC
ASCU? -LAB Legacy Auditor
Date Signed. AuuguNj 25. 2010
Page 3 ar3

CERTIFICATE OF ANALYSIS
3 Tier Technologies, LLC
Reported To: 2302 Mercator Dr. Suite 102
Orlando, FL 32807
Product: Soil Rx@)
Lot Number: 10050119018
Methodology Overview:
Triad Forensics
independent 5ervive Laborauxy
391 Technology Way Suite 167 bah 1
Winston-Salem, North Carolina 27101
Tel [phone] Fax [phone]
URL.- www.triadfbrensic.com
Case Number-
TFL-10-0913A
Date Received:
6I5l2010
Date Reported:
6/7/2010
Test Name: 24 Hour Acute Toxicity
The freshwater organisms, Pimephales promelas, selected for this study were
purchased from a local fishery and were certified to be free of parasitic and bacterial
pathogens. Approximately 160 live animals were purchased and transported 15 miles to
the laboratory on 6/1/2010. Once the animals arrived at the laboratory, they were placed
in a holding tank of simulated freshwater for observation. Their physical health and size
were satisfactory according to EPA method 2000.0. The physical and chemical
characteristics of the holding water tank were recorded at least once daily and the results
are provided as attachments to this document. All aquarium tanks were cleaned using
the procedure described in EPA 2000.0 Sections 5.2.2-5.2.3. All organisms were fed
0.007 grams Aqueon Tropical Flakes fish food one time per day.
After a five-day observation period, approximately 20-24 healthy organisms were
selected for each test of 0% (control), 12.5%, 18.75%, 25%, 50% and 100% dilute effluent
toxicant. Dilute Soil RxO solution was prepared by the manufacturers instructions by
diluting 1 part Soil Rx@ solution to 10 parts deionized water. 22 Selected organisms were
then placed into aquarium tanks (including 1 bubble air hose, 1 filter, and 1 glass
thermometer) that had been spiked with reagent grade chemicals to create simulated
freshwater having the physical and chemical composition as described in EPA method
2000.0 section 7.2.3.1 and Table 7. Physical and chemical results for all pre- and post -
toxicant water effluents were tested. The results are included as attachments.
After the organisms acclimated to the new environment, the desired level of dilute
toxicant was added to the water. The time was noted at the beginning of the study and
each study had duration of 24 hours. Some tests were terminated before 24 hours of
toxicant exposure time due to greater than 90% organism mortality. Studies in which all
organisms expired were noted and all data have been tabulated and are provided as
attachments.
'Affordable Excellence in Analytical Testing and Forensic Casework'
Page 1 of 3

CERTIFICATE OF ANALYSIS
Triad Forensics
hxle�entSetvicelaboratmy
391 Technology Way Suite 167 Lab 1
Winston-Salem, North Carolina 27101
Tel [phone] Fax [phone]
URL.- www,trladforenstc.com
Starting Live
Effluent
Final Live Organism
Organism Oty.
Methodology
Dilutions in
Oty Past 24 Hour
%
Toxicant Exposure
+
Fathead minnow, Pimephales
promelss, Acute Toxicity Tests with
22
Standard Synthetic Freshwater
12'S
Effluents and Receiving Waters
22
Fathead minnow, Pimephates
promelas, Acute Toxicity rests with
Standard Synthetic Freshwater
22
Effluents and Receiving Waters
18.75
11
Fathead minnow, Pimephales
promeles, Acute Toxicity Tests with
Standard Synthetic Freshwater
22
Effluents and Receiving Waters
25
0
Fathead minnow, Pimephales
promelas, Acute Toxicity Tests with
Standard Synthe#c Freshwater
22
Effluents and Receiving Waters
50
0
Fathead minnow, Pimephales
promeles, Acute Toxicity Tests with
Standard Synthetic Freshwater
22
Effluents and Receiving Waters
100
0
"Affordable Excellence in Analytical Testfng and Forensic Casework"
Page 2 of 3

CERTIFICATE OF ANALYSIS
Independent Laboratory Results:
Triad Forensics
hxlTendentServiee L&)ora my
391 Technology Way Suite 167 Lab 1
Winston-Salem, North Carolina 27101
Tel [phone] Fax [phone]
URL: www.tria4forensic.com
Total organism survival was 100% after 24 hours of exposure at 12.5% dilute Soil
Rx@i solution. LD50 was reached at 18.75% dilute Soil Rx9 solution after 24 hours of
exposure. All organisms expired within 12 hours of exposure to 25%, 50%, and 100%
dilute Soil RxV solutions.
Laboratory Statement of Qualifications (SOD):
Triad Forensics Laboratory (TFL) is compliant with 1SO11EC 17025:2005, EPA,
FDA, NELAC, AOAC, and ASCLD-LAB International accreditation guidelines for
independent testing laboratories. We are audited and conduct external proficiency tests
at least twice annually. All laboratory equipment and instrumentation are calibrated in
accordance with ISOIIEC 17025 guidelines. TFL is certified by, registered with, and
operates in the State of North Carolina.
Reported By
Lauren A. Stainback, Forensic Laboratory Director
Date Signed 06/07/2010
"Affordable Excellence in Analytical Testing and Forensic Casework"
Page 3 of 3

Rogers, Michael
From: Rogers, Michael
Sent: Wednesday, May 27, 2015 3.25 PM
To: 'Sandy Miller'
Cc: Joe Beaman; William Frederick, Eugene Roddy; Smith, Danny; Bolich, Rick
Subject: RF: Submittal Letter for Notice of Intent Form (NOI) far L.G. Industries for the Blind
W10500841
Thank you for submitting the Notice of Intent to Construct or Operate Injection Wells (NOI) at the E. C. Industries for the
Blind. This facility is located at 4500 Emperor Blvd., Durham, Durham County, NC 27703. We received your complete
NOI on May 18, 2015.
Please remember to submit the following regarding this injection activity:
1) Well Construction Records (GW-1) and Abandonment Records (GW-30) when completed. Please provide copies of
the GW-1s and GW-30s if not already submitted (originals go the address printed on the form). NOTE: ❑irect push
or Geoprobe wells are considered wells and require construction (GW-1) and abandonment forms (GW-30). if well
construction/abandonment information is the same for the wells, only one form needs to be completed- just
indicate total number of injection points in the Comments/Remarks section of form. These forms can be found on
our website at http://portal.ncdenr.org/web/wa/aps/gwnro/reporting-forms.
2) Injection Event Records (IER). All injections, including air and passive systems require an IER. The IER can be
modified for air sparge wells (e.g., air flow 'continuous' for date or rate of injection, etc.).
You can scan and send these forms directly to me at michae1.rovers CED ncdenr.go_v, send by fax to my attention at 919-
807-6406, or via regular mail to address below. When submitting the above forms, you will need to enter the nine -digit
alpha -numeric number on the form (i.e., WIOXXXXXX) that has been assigned to the injection activity at this site. This
notification has been given the deemed permit number W10500841. This number is also referenced in the subject line of
this email. You may if you wish, scan and send back as attachments in re
assigned deemed permit number in the subject line.
Thank you for your cooperation.
Michael Rogers, P.G. (NC & FL)
Hydrogeologist
NCDENR - ❑WR
Water Quality Regional Operations Section
1636 Mail Service Center
Raleigh, NC 27699
Direct No. 919-807-6406
htt pJl po rta I. ncde n r, o rp/web/wry/a p slew pro/repo rr i ng-form
to this email, as it will already have the
NOTE: Per Executive Order No. 150, all e-malls sent to rind from this account ore subject to the North Corolin❑ Public
Records Law and rnoy be disclosed to third parties.
From: Sandy Miller [mailto:[e-mail]
Sent: Monday, May 18, 2015 1:24 PM
To: Rogers, Michael

Cc: Joe Beaman; William Frederick; Eugene Roddy
Subject: Submittal Letter for Notice of Intent Form (NOI) for L.C. Industries for the Blind WI0500803
Good afternoon Michael,
My apologies; I just noticed that I had omitted the submittal letter in my original email.
I am sending out the hard copy and the submittal letter via U.S. Mail this afternoon to your attention.
Thank you.
Sandy
Sandy Miller
Project Scientist
Highlands Environmental Solutions, Inc.
8410-D Falls of Neuse Road
Raleigh, NC 27615
Office: 919-848-3155
Cell: 919-819-4312
Fax: [phone]
email: [e-mail]
website: www.hesnc.com
Celebrating 10 years of Solutions!
ilt\ H1:'1tands ~~
From: Sandy Miller
Sent: Monday, May 18, 2015 12:14 PM
To: 'Rogers, Michael'
Cc: Joe Beaman; William Frederick; 'Eugene Roddy'
Subject: Notice of Intent Form NOi LC. Industries for the Blind WI0500803
Good afternoon Michael,
Attached is the Notification of Intent to Construct or Operate Injection Wells for the L.C. Industries site.
I am putting the hard copy in the mail this afternoon to your attention.
Please let us know if you have any questions or concerns.
Thank you again for your assistance on this.
Sandy
Sandy Miller
Project Scientist
Highlands Environmental Solutions, Inc.
8410-D Falls of Neuse Road
Raleigh, NC 27615
Office: 919-848-3155
Cell: 919-819-4312
Fax: [phone]
email: [e-mail]
2
Ro g ers, Michael
From: Rogers, Michael
Sent:
To:
Wednesday, May 27, 2015 2:19 PM
·Smith, Danny; Bolich, Rick
Subject:
Attachments:
FW: WI0500297 Rescission Request
20150527131252545.pdf
Please find attached a permit rescission request. Mr. Poole indicates he converted the open-loop to closed-loop system
shortly after the permit was issued. I am not sure if he used the open-loop well to insert the loops or not. Please let me
know if it is OK to rescind. You can conduct a site inspection prior to recommending rescission if you wish. Let me
know. Thanks.
-----Original Message-----
From: Michael Rogers f mailto:michael.rogers @ncdenr.g ov]
Sent: Wednesday, May 27, 2015 1:13 PM
To: Rogers, Michael
Subject:
This E-mail was sent from "RNPAC7DDO" (Aficio 2075).
Scan Date: 05.27.2015 13:12:52 (-0400)
Queries to: robin.markham @ncdenr.gov
1
Ro gers, Michael
From:
Sent:
To:
Sandy Miller <[e-mail]>
Monday, May 18, 2015 1:24 PM
Rogers, Michael
Cc: Joe Beaman; William Frederick; Eugene Roddy
Subject:
Attachments:
Submittal Letter for Notice of Intent Form (NOi) for LC. Industries for the Blind WI0500803
signed submittal letter.pdf
Good afternoon Michael,
My apologies; I just noticed that I had omitted the submittal letter in my original email.
I am sending out the hard copy and the submittal letter via U.S. Mail this afternoon to your attention.
Thank you.
Sandy "--;J .e,.,.,,, (k;' f).,
Sandy Miller
Project Scientist
Highlands Environmental Solutions, Inc.
8410-D Falls of Neuse Road
Raleigh, NC 27615
Office: 919-848-3155
Cell: 919-819-4312
Fax: [phone]
email: [e-mail]
website: www.hesnc.com
Celebrating 10 years of Solutions!
!::x:
From: Sandy Miller
Sent: Monday, May 18, 2015 12:14 PM
To: 'Rogers, Michael'
Cc: Joe Beaman; William Frederick; 'Eugene Roddy'
Subject: Notice of Intent Form NOi LC. Industries for the Blind WI0500803
Good afternoon Michael,
Attached is the Notification of Intent to Construct or Operate Injection Wells for the L.C. Industries site.
I am putting the hard copy in the mail this afternoon to your attention.
Please let us know if you have any questions or concerns.
Thank you again for your assistance on this.
Sandy
Sandy Miller
Project Scientist
1
Roraers, Michael
From: Sandy Miller <[e-mail]>
Sent: Monday, May 18, 2015 12:13 PM
To: Rogers, Michael
Cc: Joe Beaman; William Frederick; Eugene Roddy
Subject: Notice of Intent Form NOI L.C. Industries for the Blind W10500803
Attachments: Text and all Attachments. pdf
Good afternoon Michael,
Attached is the Notification of Intent to Construct or Operate Injection Wells for the L.C. Industries site.
I am putting the hard copy in the mail this afternoon to your attention.
Please let us know if you have any questions or concerns.
Thank you again for your assistance on this.
Sandy
Sandy Miller
Project Scientist
Highlands En viranmental Snlutians, Inc_
B410-0 Falls of Neuse Road
Raleigh, NC 27615
Office: 919-848-3155
Cell: 919-819-4312
Fax: [phone]
email: www.smi([e-mail]
website: w_ww.hesnc.com
Celebrating 10 years of Solutions
S. >=.rt�ronrrter�ii
l �. �olvtions, Er►c.
From: Rogers, Michael[mailto:[e-mail]]
Sent: Thursday, May 07, 2015 10:07 AM
To: Sandy Miller
Cc: Joe Beaman; William Frederick
Subject: RE: notice of Intent Farm NO L.C. Industries far the Blind W10500803
Thank you and Your welcome.
From: Sandy Miller [maitto Srniller uhesnc.corn]
Sent: Thursday, May 07, 2015 10:02 AM
To: Rogers, Michael
Cc: Joe Beaman; William Frederick
Subject: RE: Notice of Intent Form
Good morning Michael,

Highlands
f. Environmental
Solutions, Inc. 6410-d Falls of Neuse Road,RaFeigh, NC 27615
Phone: 919-W-3155I Far: 91"48-4265 /www,hesnc.com
May 18, 2015
Mr. Michael Rogers
NCDENR - Department of Water Resources
WAROS
512 N. Salisbury Street
Raleigh, North Carolina 27604
Subject: Submittal of Notification of Intent to Construct or Operate Injection Wells
L.C, Industries, Inc. - Diesel Fuel Release
4500 Emperor Boulevard, Durham, Durham County, NC
NCDENR Incident No: 92274
HES Project #202003
Dear Mr. Rogers
On behaff of L.C. Industries, Inc., please find enclosed an original copy of our Notification of Intent to
Construct or Operate Injection Wells for the proposed in -situ remediation of petroleum -impacted soil
activities at the subject site. The diesel fuel release resulted from the failure of an underground product
line, and impacted an unpaved area immediately surrounding two aboveground storage tanks (ASTs),
owned by LCl and located at the subject site. Additionally, the release impacted an underground
electrical conduit housing three-phase power lines maintained by Duke Energy, an unpaved area near a
light pole, and a paved parking lot located immediately southeast of the ASTs. The electrical conduit
appears to have acted as a preferential pathway for product migration; allowing for the product to migrate
to the second area southwest of the AST area, where the product surfaced adjacent to a light pole and
concrete walkway.
Emergency remediation activities and soil excavation activities have been performed, as well as
performance and submittal of a Comprehensive Site Assessment (CSA) and a Corrective Action Plan
(CAP). The CAP, which was approved on July 8, 2014, and proposed an in -situ remediation program for
the remaining petroleum -impacted soils. This NOI is being submitted as fulfillment of the approval
process.
If there are any questions regarding this correspondence, or the project in general, please contact me at
[phone]_
Sincerely,
Highlands Environmental Solutions, Inc.
Sandra Miller
Project Scientist
Enclosure
cc, Mr. Eugene Roddy - L. C. Industries, Inc.

NORTH CAROLINA DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
NOTIFICATION OF INTENT TO CONSTRUCT OR OPERATE INJECTION WELLS
The following are "permitted by rule" and do not require an indivi.dual permit when constructed in accordance
with the rules of I 5A NCAC 02C. 0200. This form shall be submitted tit least2 weeks prior to iniection.
AQUIFER TEST WELLS USA NCAC 02c .02201
These wells are used to inject uncontaminated fluid into an aquiferto determine aquifer hydraulic characteristics,
IN S/1VREMEDIATION OSA NCAC 02c .0225) or TRACER WELLS USA NCAC 02c ;0229):
1) Passive Injection S y stems -In-well delivery systems to diffuse injectants into the subsurface. Examples include
ORC socks, iSOC systems~ and other gas infusion methods. ·
2) Small.:Scale Infection O p erations -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 ofa
remediation strategy 10 order to develop a full scale remediation plan for future implenientatiori, and where the
surface area of the injection zone wells are located within an area that does notexceedfive percent of the land
surface.above the known extent of groi.lndwater 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.
Print Clearly or Type Information. Illegible Submittals Will Be Returned As Incomplete.
DA TE: __ __,M=ay,_7...__,, 20li_ PERMIT NO. ~o < co @ Lj I (to be filled in by DWR)
A. WELL TYPE TO BE CONSTRUCTED OR OPERATED
(1) ---'Air Injection Well.., ..... ~ •... ,.; ... ; ....•. ; ....... ~ .. ,Complete sectionsB-F, K, N
(2) ___ Aquifer Test Well .........................•............. Complete sections B-F, K, N
(3) ___ Passive Injection System ............................... Complete sections B-:-F, H-N
(4) X ~--Small-Scale Injection Operation, .............. , ...... Complete sections B-N
(5) ___ .Pilot Test. .... , .. , ............ , ........................... Complete sections B-N
(6) ___ T.racer Injection Well. ...........................•....... Complete sections B-N
B. STATUS OF WELL OWNER: Business/Organization
C. WELL OWNER-State name of entity and name of person delegated authority to sign on behalf of the business
or agency:
Name: Mr. Eugene Roddy
Mailin:gAddress:.4500 Emperor Boulevard
City: Durham State: NC
DayTeleNo.: 919-596-8277 ext.2265
EMAIL Address: eugene.roddy@lc.,.ind.com
UiCIInSitu Remed. Notification (Revised 3/2/2015)
Zip Code: 27703 County:~D~u=rh-am=---
Cell No.: 336-392-0715
Fax No.: __________ _
Page I
D. PROPERTY OWNER (if different than well owner)
Name: NA
Mailing Address: _____________________________ _
City: ____________ State: __ Zip Code: _______ County: _____ _
Day Tele No.: ___________ _ Cell No.: __________ _
EMAIL Address: _____________ _ Fax No.: __________ _
E. PROJECT CONT ACT -Person who can answer technical questions about the proposed injection project.
Name: Sandra Miller
Mailing Address: 8410-D Falls ofNeuse Road
City: Ralei gh State: NC . Zip Code: 27615 County:~W ...... ak=e ___ _
Day Tele No.: 919-848-3155 Cell No.: __ _,9:;..:1=9-..,,,8=19"---4-"3=1=2'-----
EMAIL Address: smiller@b esnc.com Fax No.: _____ 9=19--~84~8~-4=2~6~5 __ _
F. PHYSICAL LOCATION OF WELL SITE
Physical Address: __ __,L=·-=C~. =In=d=u=stn=·=es=-=In=c'-'-. _______________ _
___ 4~5~0~0~E=m=p=er=o'-=--r=B=o-=u=lec.c.v=~=d~ ___________ County: Durham
(2)
City: ---~D"""ur=ha=m~--------State: NC Zip Code: --=2'"""7 ...... 70=3~------
Geographic Coordinates: Latitude**: ___ 0 ____ " or ~0 -~87~3~4=8~4 ___ _
Longitude**: 0 __ " or __ -___ 78~0 .838443
Reference Datum: ~3 ...... 78~'-_____ Accuracy: _______ _
Method of Collection:.---'G=o=o=g=le=-=M=a=p=s ____________ _
**FOR AIR INJECTION AND AQUIFER TEST WELLS ONLY: A FACILITY SITE MAP WITH PROPERTY
BOUNDARIES MAY BE SUBMITTED IN LIEU OF GEOGRAPHIC COO RD INA TES.
G. TREATMENT AREA
Land surface area of contaminant plume:_<=3....aOO'--"-"'0 ____ s.quare feet
Land surface area of inj. well network:. __ <~3~0~0'--"0'--__ .square feet (S 10,000 ft:2 for small-scale injections)
Percent of contaminant plume area to be treated: 100 (must be.:::: 5% of plume for pilot test injections)
H. INJECTION ZONE MAPS -Attach the following to the notification.
(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.
UIC//n Situ Remed. Notification (Revised 3/2/2015) Page2
I. DESCRIPTION OF PROPOSED INJECTION ACTIVITIES -Provide a brief narrative regarding the
purpose, scope, and goals of the proposed injection activity. This should include the rate, volume, and duration
of injection over time.
See attached in fo rmation fr om 3tier.
J. INJECTANTS -Provide a MSDS and the following for each injectant Attach additional sheets if necessary~
NOTE: Approved injectants (tracers and remediation additives) can be found online at
http :l/portal.ncdenr.org/web/wq/apslgi·vpro ; All other substances must be reviewed by the Division of Public
Health , Department of Health and Human Services. Contact the UIC Program for more info (919-807-6496).
Injectant: ---=S=,e~e~a=tti=a~c~he=d~in_._fo~rm~a-ti~·o~n .... m_o~m~3~ti~·e~r, ________________ _
Volume ofinjectant: ____________________________ _
Concentration at point of injection: _______________________ _
Percent. if in a mixture with other injectants: ___________________ _
Injectan:t: ~-------------------------------
Volume ofinjectant: ____________________________ _
Concentration at point of injection: ______________________ _
Percent if in a mixture with other injectants: ___________________ _
Irijectant:
Volume of injectant: ____________________________ _
Concentration at point of injection: _______________________ _
Percent ifin a mixture. with other injectants: ___________________ _
K. WELL CONSTRUCTION DATA
(1)
(2)
Number of injection wells: --=2;:a,.5 _--'Proposed _____ ~Existing
Provide well construction details for each injection well in a diagram or table for:inat A single
diagram or line in a table can be used. for multiple wens with the same construction details. Well
construction details shall include the following:
(a) well type as permanent, direct-push, or subsurface distribution system (infiltration gallery)
(b) depth below land surface of grout, screen, and casing intervals -see att~ched figure
(c) well contractorllame and certification number-Quantex, #3106
UIC/Jn Siiu Remed . Notification (Revised 3/2/2015) Page3
L. SCHEDULES — Briefly describe the schedule for well construction and injection activities.
Prior to the detailed activities. TIES anticipates completion _of three preliminary tasks: abandonment of
on_e_da_m_aged well. minor repairs to three other gxistinQ well.. and completion of a baseline Lam , in session.
FfreIl construction of the injection wells can bggiLupon NCDENR's authorization to proceed contingent on the
time schedule of the drillinz contractor and the availabiliti, of the 3tiergersonnel being uresent for set-up of the
system,
M. 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_
See attached information tom 3der_
N. SIGNATURE OF APPLICANT AND PROPERTY OWNER
APPLICANT: .1 hereby certify, 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 ofthose individuals immediately responsible
for obtainhzg 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 cons operate, maintain, repair, and if applicable, abandon the injection well and
all relat d appurte t s it y vrdance with the 1 SA MCA C 01 C 0200 Rules. "
LGcgPrrt �adpt
Print or Type lull Name
"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 We11 Construction Standards
(I SA NC.4C 02C .0200). "
" Ownee' means any person who holds the fee or other property rigbts 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 cons ry,_agrcernf71 wn Mg,
_ G� tit e- lzocld
igm►1ureProperty owner (if differen ro i applicant) Print or Type F'uIl NAne
* An accf4xa rt ment between the upplicRnt a d property owner may be submitted in lieu of a signature on this form.
Submit the completed notification package to:
DWR — UIC Program
1636 Mail Service Center
Raleigh, NC 27699-1636
Telephone. [phone]
MUM Situ Remed. Notification (Revised 3I2I241 S) Page 4

Flush Mount Casing
'µ
C6
k6
m
0
R
0
0
1-
�---- 0—
to chemical
Storage vessel
Concrete
- 'Schedule 40 PVC Casing
proximately 2 ft.)
- Neat Portland Caxnent Grout
Hydrated Bentonite
i (1.0 feet)
Clean sand
Schedule 40 PVC Manufactured Screen
- _ (O.010 slot)
(5 ft.)
Highlarsds
Enviramriental
Nod is Scene
S01t�tians,
or 4 —;-- y
Injection Well
Schematic Diaorar�1_
w",rrw.Wd
LC Industries, Inc.
4500 Emporer Boulevard, Durham, NC
202002 November 2014 12

1a �
O
3tier
TECHNOLOGIES
Treatment 5oiutions for Soil Contamination
Highlands Environmental Solutions -- LC Industries / Durham, N.C.
Site Description:
The subject site, LC Industries Inc, is located in Durham North Carolina. The original impacted area was
the result of storage tank release. The original work plan utilized the dig and haul method of
remediation. Due to underground infrastructure, pipes and utility lines, the full scope of material
removal was limited and the result was continued impact of the hydrocarbon contaminants. The next
phase of remediation will require a technique that allows for remediation material to be added to site
through in -situ methods and encouraged to travel multiple pathways around the pies and limited access
areas to reach the target residual contaminants.
The three original excavation locations are still exhibiting unacceptable levels of Naphthalene and
Methylnaphthalene. it is not unusual in sites that are not able to fully excavate the target areas to exhibit
a level of rebound or continued influence from the contamination outside the treatment areas. The
following recommendations are based on the three target areas supplemental treatments of an in -situ
remediation process.
Technology Overview:
3 Tier Technologies LLC is a green science and technology company focused on developing innovative
and sustainable materials, processes and applications to optimize in -situ hio-remediation of soils and
water contaminated by hydrocarbons and other various organic constituents. 3 Tier focuses our efforts
on the use of "Green TechnoloW that uses significantly less equipment, labor, and fuel to execute while
remediating harmful contaminates in -situ. "Green Technology' is a solid movement to identify products
and methods to clean up various contamination sites without extensive use of equipment that can emit
harmful pollutants to perform the required task and establish systems that allow for material to be
recycled and/or re -used after completing the projects.
To achieve maximum performance in these various treatment processes, 3 Tier Technologies has
discovered that current products offered in todays markets offer a single solution that only impacts
either bia-augmentation or bio-stimulation. The development of a complete regeneration and cleaning
solution would not only enhance the remediation of contaminates, it would also regenerate contaminated
soils and groundwater to a healthy and active state for effective and safe re -use. 3 Tier achieves a
complete regeneration/cleaning system with a suite of products that uses various recipes consisting of
three distinct yet synergistic components, a blend of activated organic bio-polymers derived from very
stable, organic compounds found in brown and oxidized black coal, a ultra high concentration of live
synergistic bacteria, and a readily biodegradable natural enzyme product consisting of a nutrient -rich
extract with a broad. -spectrum package of identifiable enzymes, coenzymes, amino acids and other
proteins. These multi -action products are able to degrade common organic constituents with minimal
use of equipment, labor and cost.
250 National Place. Suite 142, Longwood FL, 92750 • www,3tiertech.com • 877-226-7498

280
SA2BO a
BA 2ff 1
1-40 EAM
-low
(§43
_T
Ad
Approximate , $dAW JO L
Site Lomfion]
.......... ........ ............. ......
4k,Lb
f.
P40 rodt294
COP
It
Coy
W r*d
Appmzftsmfe Seale
0.45 0. 9WO
My"
Source. Mkrosoft Streets & Tdp, 2002 Site Lwation Diagram
PMJ$d NVIM Injection Permit
Highlands Durham, North Carolina
Highlands
LC Industries, Inc.
Solutions, Inc. 202002 SM
Scale APPmyinmfe pate
Scale as Noted I December 2014
N
T

Treatment Product:
Soil Rx -Soil Rx is the ultimate heavy lifter in hydrocarbon remediation and utilizes a new approach to
solving soil and water hydrocarbon contamination problems, Speciallyformulatedfor safety,
effectiveness and environmentally friendliness, Soil Rx utilizes a blend of Polyelectrolyte Enhanced
Biopolymers (PEB), a ultra high concentration of live synergistic bacteria, and a readily biodegradable
natural enzyme product consisting of a nutrient-rich extract with a broad..;spectrum package of
identifiable enzymes~ coenzymes, amino acids and other proteins. This tpple action product is able to
degrade hydrocarbons with minimal use of equipment, labor and cost. Soil Rx's liquid form and low cost
make this an easy to use cost effective means for industries to eliminate hydrocarbon contamination
problems that consist of gasoline, jet fuels, diesel fuels, grease, tar, motor oils, crude oils, solvents, etc.
Soil Rx is NCP Llstedd:.
Disclaim.e,-."
Soil RX is on the U.£ Environmental Pro.tectfon Agency's NCP Product Schedule. This listing does NOT mean that EPA approves,
recqmmends, licenses, certifies, or authorizes the use of Soil Rxon an oil discharge. This listing means only thatdata have been
~ . .
submitted to EPA as required by subpart J of the National Contingency P/afl, Sec 300.915.
TreatmentMethod & Rates:
Due to the relative size ofthe area to be remediated, 3 Tier recommends applying Soil Rx using a
modified bore-n~pour method of application; This 'method will provide maximum control and saturation
ofthe soiJ that will ensure proper penetration ofthe product to come In contact with th.~ contaminants
while utilizing the established pathways that the current contaminants are currently using around the
pipes and infrastructure. This method will require a minimal number of injection points per location that
will remain in.aplace until the proce~s is completed.
3 Tier recommends the use of a 2" GeoProbe direct push unit;to establish the required injection points
per location. The approximate depth of each hole will be 7.5 1 to 8'. These points wm then receive orie
section of 1•~ slotted pipe (bottom section) and one sectionofsolid riser .. Each injectionpointis to be
sand filled and capped With Bentonite. After initial injection process, pipes will trimmed flush with the
ground and capped while remaining in-place until no further action noticeis received. Established points
may be re-used at a]ater date for spot treatments or removed after completion. No further equipment
requirements will be needed· after initial injection.point establishment
SQil Rx is the remediation workhorse in our suite of hydrocarbon products and must be diluted with
water prior to use. The target goal is to apply 20 ounce of Soil Rx concentrate per cubit yard of soil to be
treated. As previously stated,.the work will focus on three target areas that continue to _exhibit hot spots
after excavation. Target area One known as Area ''C' measures 15' by 18' with approximately 60 cubic
yards of material to treat. Target area Two known as Area ''A" is approximately 28' by 2 O' with
approximately 165 cubic yards of material. Targetarea Three known as Area "D" measures 48' by 20'
and has apptoximately27.5 cubicfeetofmaterial. Though the standard dilu.tion rate is 10 to 1 with the
standard appUcation rate being 1 to 1.5 diluted gallons per cubic yard, for this application, 3 Tier
recommends thatthe dilution rate be i,ncreased to 20 to 1 to ensure proper coverage and moisture
content with the application rate being three gallons diluted materialper cubicyard. Therefore, 75
gallonsofSQil Rx concentrate will be di,luted in1425 gallons Mclean water-for thepreyiouslydescribed
areas. Area "C" will require 180 galJons of diluted material, Area "A" will require 495 gallons of diluted
material, and Area ;'D" will require 825 gallons of diluted material.
Areas "A" and "C" will require 5 injection points each, and Area "D 11 will require approximately 15
injection points. As previously mentioned these injection points will remain available for use until the
project is completed thus saving potential additional costs for equipment usage. Injection point detail is
available upon request or will be provided prior to work commencement.
Areas "A" and "C" will can be plum.bed to on 275 gallon IBC tote which would require Area "C" to be filled
twice while Area "D" will use two separate totes for each half of the area requiring just one fill each.
Tanks and plumbing will remain in-place until all material is absorbed into the injection points and
removed and stored until areas are tested and the need for any additional treatments is determined. Due
to the soil types> initial product application may require up to one week though our experience and past
excavation has shown that material may only need a day or so.
The target areas should be sampled 45 to 60 days after treatment. After the subject results are available,
3 Tier review progress and make further site recommendations. Should additional applications be
required, they will be performed using existing injection points as determined by 3 Tier and HES
personnel.
3 Tier recommends that the site work commence in the spring, once the soil temperatures begin to rise
after the winter cool temperatures. 3 Tier will provide a technical support person for the initial work as
technical support for this project
The fol1owing application protocol has been provided by Daniel J Burdette, President, 3 Tier Technologies
LLC. Please contact us for clarification, regulatory clarifications, or schedule technical support.
Stier
TEC"N0lD@IES
MATERIAL SAFETY DATA SHEET
PRODUCT: Bio-Regen Soil Rx
Section I — Chemical Product & Company identification
Trade Name: Blo-Regen Soil Rx
Chemical Family: Mixture
Product Description: A concentrated blend of organic biopolymers, bacterial cultures, and amino
acids that is non -hazardous.
Manufacturer: 3 Tier Technologies, LLC
250 National Place, Suite 142, Longwood, FL 32750
Technical Support: 877-226-7498
Chemical Emergency: 407--808-4553
Issue Date: 0712412012 Supersedes Date: 02l13/2012
Section 2 — Hazards Identification
Emergency overview: Avoid contact with eyes. Mild skin irritation.
Potential health effects:
Eyes: Contact with eyes may cause severe irritation.
Skin: May cause irritation upon prolonged contact.
Inhalation: None known
Ingestion: May cause irrhationlnausea it ingested in large quantifies
Section 3 — Composition ! information on Ingredients
Components _ CAS # Percent
Soli Rx is a blended composition 'not considered hazardous' under the OSHA Hazard Communication
Standard CFR Title 29 1910,1200. All ingredients appear on the EPA TSCA Inventory.
All Bacillus Bacteria contained in this product are DSL Listed and Compliant;
organic Blopolymer
•1415-93-6
55%
Amino Acids
various
10%
Bacillus Bacteria
ATCC 18250-7
15%
RO Water
7732-18-5
25%
Ingredients of E1 % have been added to a non -hazardous liquid organic substrate.
Active components <15% are identified above
Section 4 -- First Aid Measures
First aid procedures
Eye contact: Immediately Mush eyes with plenty of water for at least 15 minutes. Seep
medical attention if irritation persists.
Skin Contact: Flush skin with large amounts of water. Remove any contaminated clothing and wash
before reuse. Seek medical attention if irritation occurs-
0 2012 3 TFer'r0d1ndD9'es, ltC. -?n: 377-226-7496-www3aldeah.onm- MWS Bb-F e m Sd! Pc
Pape 1 of 4

Inhalation:
Ingestion:
If symptoms are experienced, remove source of contamination and/or move
victim to fresh air. If breathing is difficult,. have trained personnel administer
oxygen. If respiration stops, have trained personnel administer artificial
respiration. Get medical attention immediately.
Give large amounts of water. Do not induce vomiting. If vomiting occurs prevent
aspiration by keeping victim's head below the knees. Get immediate medical
attention.
I Section 5 -Fire Fi ghtin g Measures
Flash Point: None
Extinguishing
Media: Water fog or fine spray, carbon dioxide, dry chemical or foam. No special
requirements
Fire fighting
Protection: As in any fire, wear self-contained breathing apparatus pressure-
demand, MSHA/NIOSH (approved or equivalent) and full
protective gear.
[ Section 6 -Accidental Release Measures
Personal
Precautions: Isolate area. Keep unnecessary personnel away. Keep out of low areas. Ventilate
closed spaces before entering. Use of safety glasses and impervious gloves
recommended.
Environ mental
Precautions: Prevent further leakage or spillage if safe to do so.
Methods for
Containment: Prevent entry into waterways, sewers, basements or confined areas.
Methods for
Clean-up: Wear appropriate protective equipment and clothing during clean-up.
Large spill: Use a non-combustible material like venniculite, sand or earth to soak
up the product and place into a container for later disposal. Dispose in
accordance with all local, state and federal regulations.
Small spill: Follow same procedure as above.
I Section 7 -Handling and Storage
Handling:
Storage:
Avoid contact with skin and eyes. Wash hands thoroughly after handling .
Store this product below 120"F (49.C), preferably below 75"F (24'C), in a cool, dry,
well ventilated area away from heat, sparks, flame, oxidizers and out of direct sunlight.
For best results, use within 24 months.
C> 2012 3 Tier T edmol:,gies. llC. -Ph: 377-226-7 498 -www .3tiarteeh.com -MSDS Bio-Regan Soil Rx
Page 2 of 4
J Section 8 -Exposure Controls, Personal Protection
Personal Protection
General: Eye wash fountain Is recommended. Minimize exposure in accortlance with good
hygiene practices; Keep out of teach ofchildren.
Eyes: Wear chemical goggles.
Skin: Suitable protective clothing is recommended but not required. Use impervious gloves.
Respiratory: None required for recommended use. Avoid creating aerosols in poorly ventilated
areas:
j Section 9 -Physical & Chemical Properties
Vapor Pressure:
Vapor Density (air= 1):
Equivalent to Water
Equivalent to Water
1.0approx; Specific Gravity:
Solubility in water:
voe:
Appearance:
pH:
Bolling Point:
Flash Point:
Freezing Point:
Evaporation Rate:
Weight:
Odor:
99%
Negligible
Brown/Black Liquid
6.0to a.s
> 212• F (100" C)
None
< 32 • F (o• C)
Not Detennined
8.7 ..... 9.2 lbs. /gallon
Mild citrus odor
I Section• 10 -Stability & Reactivity
Chemical St.ability: Stable at normal conditions.
Incompatible Materials: Strong oxidizing agents, alkalis
HazardQus Decomposition
Products: None known.
Conditions to avoid: See Section 7.
Hazardous Polymerization: Will hot occur.
I Section 11 -Toxicology Information
Toxicology data: Not available.
I Section 12-Ecological Information
Ecotoxicify: Readily biodeQradable .
I Section 13 -Disposal Considerations
Disposal instructions: Dispose in accordance With all applicable regulations, All wastes must be
handled in accordance with local, state and federal regulations. Regulations
vary. ·
© 2012 3 Tier Technolog!es, LlC. -Ph: 877 •226-7498 -www.3liertec:h.com '-MSOS Bio-Regen Soll Rx
Page 3of4
I Section 14-Transportation Information
General information:
US DOT:
Non--hazardous.
Not regulated.
Proper Shipping Description: Class 55
I Section 15 -Regulato ry Information
TSCA Inventory Status: This product and/or all of its components are either included on or
exempt from the TSCA Inventory of Chemical Substances.
DSL (Canada): This product and/or all of its components are either included on or
exempt from the Domestic Substances List.
I Section 16 -Other Information
HMIS ratings:
NFPA ratings;
Disclaimer:
Health: 1
Flammability: 0
Physical hazard: 0
Health: 1
Flammability: 0
Reactivity: 0
The data and recommendations presented herein are based upon research of
others and are believed to be accurate. However, no warranty is expressed or
implied regarding this data or the results to be obtained from the use thereof.
The manufacturer assumes no responsibility for the injury to customers or
third persons proximately caused by the material if reasonable safety
procedures are not adhered to as stipulated in the data sheet. Additionally,
sine actual use by others is beyond our control, no guarantee, expressed or
implied, is made by the manufacturer as to the effect of such use, the results
to be obtained or the safety and toxicity of the product nor does the
manufacturer assume any liability arising out of use, misuse, by others, of the
product herein. Information provided herein is provided solely for the
customer's assistance in complying with the occupational safety and health
act of 1970 and regulations there under. Any other use is prohibited.
Cl 2012 S 11er Technologies, LLC . -Ph: 877-226-7498-www.3~ertech.airn-MSDS Bio-Regen Soil Rx
Page 4 of4
. ,ISD
t' UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Uj
Y WASHINGTON, D.C. 20460
NOV 17 2010
Mr. Daniel J. $urdette
3 Tier Technologies, LLC OFFICE OF
2302 Mercator Drive SOLID WASTE AND
Suite 102 EMEROENCY RESPONSE
Orlando, FL 32807
Dear Mr. Burdette,
Thank you for providing the technical product data required by the National Oil and
Hazardous Substances Pollution Contingency Plan (NCP), 40 CFR Part 300, on your product "Soil
Rx (aka, Bio-Regen Hydrocarbon)." After conducting our review, your data submissions have
satisfied the requirements contained in Title 44 of the CFR section 300.915 of the NCP. "Soil Rx
(aka, Bio-Regen Hydrocarbon)" will be listed on the NCP Product Schedule under the
Bioremediation. Agent category and may be authorized for use by Federal On -Scene Coordinators
in accordance with 40 CFR section 300.910. The technical data for this product will be kept on
file by the Office of Emergency Management Regulation and Policy Division Oil Program Center
pursoant to 40 CFR section 300.920.
Enclosed aye some ofthe relevant provisions in the NCP on restrictions regarding the
listing of your product. Please note, you are required to notify the Environmental Protection
Agency (EPA) of any changes in composition, formulation, handling Procedures, or application of
your product. Based on this notice, EPA may require retesting of the product.
Also, note that the listing of "Soil Rx (aka, Bio-Regen Hydrocarbon)" on the NCP Product
Schedule does not constitute approval, certification, authorization, licensing or promotion of the
product; nor does it imply compliance with any criteria or minimum standards for such agents.
Failure to comply with these restrictions or the making of any improper reference to EPA in an
attempt to demonstrate approval or acceptance of the product will constitute grounds for removal
of the product from the schedule.
Please review the enclosed information and contact Ms. Leigh DeHaven in the Office of
Emergency Management at (202) 564-I974 if you have any corrections or questions.
Sincerely,
12.
R Craig Matthiessen, Director
Regulation and Policy Development Division
Office of Emergency Management
In'WnWT AddMss {URQ a trt>pJAY waeps.gav
R oc 6drAecyclebla 0 Priafad w fe Vegetable D7 Bawd Inks on 1W% Postcomumar, Process ChImfne Fran Rocyded raper

i CERTIFICATE OF ANALYSIS
3 71cr Technologies, LLC
Reported To: 2302 Mercator Dr,
Suitt 102
Orlando, FL 32807
Product: SOrL-RX
Lot Number: 10050119018
Overview:
Case Number.
Date Received:
Date Repotted:
Triad Forensics
independa tService Lkm-abxy
391 Technology Way Suite 167 Lab 1
'i+lWinstoo•Salem, North Carolina 27101
Tel [phone] Fax [phone]
URL. wwwsriadforensic.rsrm
TFL-10-0721
7121120l 0
OnS/2010
Test Method: U.S. EPA Appendix C to Part 300
Swirling Flask Dispersant
Test Name: Effectiveness T ast, Revised Standard
Dispersant Test, and Sivremediation
Agent Effectiveness Test
In addition to gravimetric analysis, normal alkanes as well as the more highly resistant and
toxic polynuclear aromatic hydrocarbons (PAHs), were monitored using }sigh Resolution Gas
Chromatography Mass Spectrometry (GCIMS) to quantify changes in the oil composition resulting
from biodegradation during a 28-day effectiveness study for SOIL-Itx@'. The bioremediadon
effectiveness test was performed using a Shimadxu GC-2010 with AOC-201 auto sampler. The GC/MS
was operated in the selective ion -monitoring mode (SIM mode) at a scan rate greater than 1.5 scans
per second using Helium as the carrier gas. All other instrument settings and analytical procedures
follow U.S. EPA Method 8270 and the configuration and calibration section of reference teat A; see
below Concurrent microbiological analyses were performed to determine and monitor the viability
of the microbial cultures being studied. ASCLD-LAB International approved laboratory notebooks
were maintained to document the chemicals, media, surrogates, stock solutions, standards, and
reagents used to perform the 28-day effectiveness study. Effectiveness testing was conducted using
triplicate samples of the following: control, nutrient', and produce a Control and treatment flasks
were sampled three times over a 28-day period: clay 0, day 7, and day 28.
` Manufactured by 3 Tier Technologies
Control samples contain approximately 0.5 grams of reference oil and brought to a Finial volume of 1000-mL with non -sterile
seawater
a N u went s amples contain approximately 0.5 grams of reference vA,10-mL of N&P Sal tselution, 2-mL solutions 2-5, and brought to a
final volume of 1000-mL with non -sterile sp. awarr,
4 Product samples ccomin approximately 0.5 grains of reference oil, 10-mL of N&P Salt solution, 2-mL of Sol utlons 2-5, and brought to
a Gnat wIume of 1000-mL with 1.10 diluted Soil-Rxg/non sterile seawater solution.
Page Iof3

The .effectiveness study was performed using the test methodologies described in the
following texts:
A. EPA Appendix Cto Part 300 -Swirling Flask Dispersant Effectiveness Test, Revised
Standard Dispersant Test; andBioremediation Agent Effectiveness Test
B. 40 CFRpar;t 300 * National Oil and HazardousSubstances Pollution Contingency Plan
C. L.T. McCarthy; Jr., I. Wilder, and J.S. Dorrier, Standard Dispersant Effectiveness and Toxicity
Tests. EPA Report EPA-:RZ-73-201 (May 1973).
Every attempt was made to coinplywith all requireme'nts and quality guidelines for conducting
effectiveness testing. ln the referenced test methods, certain resources, chemicals, or equipment
were no longer available . As a result, equivalentsubstitutes were used to facilitate rigorous testing
and evaluation ofthebioremediation product studied. The equivalency of substitute themicals was
determined by comparative assessment of the mass spectra data5 for both the original and all
potential substitute chemicals. Substitutions of equipment mentioned in the reference texts were
made after consulting with the device manufacturer and examining equipment and/ or software
manuals.
Independent Laboratory Results:
Data Table 1: Bioremediatjon Agent Effectiveness Test Data
~ample Description CONTROL NUTRIENT SOIL-RX® PRODUCT
Day of Collection · DayO Day7 Day 28 DayO Day7 Day28 DayO Day7 Day28
Gravimetric Results (mg)"' 496.20 .458.24 456.24. 49i.03 487.03 454.52 497.65 482.93 347.64
M icrobfalViabllity ad Activity <3.0 <3.0 <3.0 <3.0 3.6 7.4 43 >1100 >1100
(MPN/g)
:;C/MS Results Total Mean 34908.9 35206.2 34287.8 34863.3 32894.1 3.2610.0 34993;0 24446.0 17597.0
Alkanes loom)*"'
G.C/MS Results Total Mean 6051;3 5720.9 5892.7 6047.4 5745.8 5205.1 6069.0 3219.2 1600.1
Aromatics foom)"'*
Percent Reduction in Total 1.779% 6.463% 49;7l3%.
Mean Alkanes after 28 Days
Perteht Reduction in Total 2.621% 13.928% 73;635%
Mean Aromatics after 28Days
• Gravimetric results are averages of the three replicate studies perfonned on each sample (Control, Nutrient,, and Product) for each
sample day (Day 0, Day 7, Day 28). .
"'GC/MS results of averaged total aromatic compounds of the three replicate studies performed on ~ach sample (Ccintro~ Nutrient,
and Product) for each .sarriple day (Day o, Day 7, Day 28). Total of nine samples per day sampled (Three for Controi, Nutrient, and
Product on Day O; three for CQntrol; Nutrient. and Product on Day 7, and three for Control, Nutrient, and Product on Day 28).
s Obtained by a serial dilution and three point callbration curve
Page2of3
Effectiveness testing for the control, nutrient, and product samples was conducted in
triplicate, Minor qualitative changes were noted for the oil fraction in the nutrient and control
sample flasks for days 7 and 28. However, no observable changes in either color or turbidity were
noted for the nutrient and control samples during the 28-day test period. For all three of the product
flasks, significant qualitative changes in the sample solution's turbidity, coloration, and volume of the
oil fraction were noted. The qualitative changes to the oil fraction layer in each of the samples were
verified quantitatively using U.S. EPA Methods 1664 (gravimetric) and 8270 (Characterization of
Volatile Organic Compounds).
Upon termination of the effectiveness study, a significant reduction in hydrocarbons was
documented for the product samples containing the bioremediation agent in Soil-Rx®. The
microbial viability and activity was maximal for the Soil-Rx® product samples assayed on day 7 and
day 28. The data obtained from testing those samples indicates that a strong correlation exists
between Soil-Rx® microbial activity and hydrocarbon compound reduction. The product samples
indicate that the microbes in the Soil-Rx® product are highly effective in reducing hydrocarbon
compounds in a time period ofless than 28 days.
Laboratory Statement of Qualifications {SOQ):
Triad Forensics Laboratory (TFL) is compliant with ISO/IEC 17025:2005, EPA, FDA, NELAC,
AOAC, and ASCLD-LAB International accreditation guidelines for independent testing laboratories.
We are audited and conduct external proficiency tests at least twice annually to maintain all
accreditations and certifications. All laboratory equipment and instrumentation are calibrated in
accordance with ISO/IEC 17025 guidelines. TFL is certified by, registered with, and operates in the
State of North Carolina.
END OF LABORATORY REPORT
ReportedBy, ~
Lauren A. Stainback
Forensic Laboratory Director,
Member AOAC, APHA, and NELAC
ASCLD-LAB Legacy Auditor
Date Signed: August 25, 2010
Page 3 of 3
CIItTIFICATE OF ANALYSIS
3 Tier Technologies, LLC
Reported To: 2302 Mercator Dr. Suite 102
Orlando, FL 32807
Product: Soil Rx@
Lot Number: 10050119018
Methodology Overview:
Triad Forensics
tndeperidem--�avicelahora xy
391 Technology Way Suite 167 Lab I
Winston-Salem, North Carolina 27101
Tel [phone] Fax 866-571•9264
UiiL: www.triadforensir.com
Case Number;
TFL-10-0913A
Date -Received:
6/5/2010
Date Reported:
6/7/2010
Test Method: EPA 2000.E
Test Name: 24 Hour Acute Toxicity
The freshwater organisms, Pialephales prornelas, selected for this study were
purchased from a local fishery and were certified to be free of parasitic and bacterial
pathogens. Approximately 160 live animals were purchased and transported 15 miles to
the laboratory on 61112010. Once the animals arrived at the laboratory, they were placed
in a holding tank of simulated freshwater for observation. Their physical health and size
were satisfactory according to EPA method 2000_0. The physical and chemical
characteristics of the holding water tank were recorded at least once daily and the results
are provided as attachments to this document. All aquarium tanks were cleaned using
the procedure described in EPA 2000.0 Sections 5.2.2-5.2.3. All organisms were fed
0.007 grams Aqueon Tropical Flakes fish food one time per day.
After a five-day observation period, approximately 20-24 healthy organisms were
selected for each test of 0% (control), 12.5%, 18.75%. 25%, 50% and 100% dilute effluent
toxicant. Dilute Soil Rx9 solution was prepared by the manufacturers instructions by
diluting 1 part Soil RxG) solution to 10 parts deionized water. 22 Selected organisms were
then placed into aquarium tanks (including 1 bubble air hose, 1 filter, and 1 glass
thermometer) that had been spiked with reagent grade chemicals to create simulated
freshwater having the physical and chemical composition as described in EPA method
2000.0 section 7.2.3.1 and Table 7. Physical and chemical results for all pre- and post -
toxicant water effluents were tested. The results are included as attachments.
After the organisms acclimated to the new environment, the desired level of dilute
toxicant was added to the water. The time was noted at the beginning of the study and
each study had duration of 24 hours. Some tests were terminated before 24 hours of
toxicant exposure time due to greater than 90% organism mortality. Studies in which all
organisms expired were noted and all data have been tabulated and are provided as
attachments.
"AFfordabie Excel]once in Analytical Testing and Forensic Casework'
Page I of 3

Triad Forensics
CERTIFICATE OF �AL!'SiS �>�i�tserv�e ��
391 Technology Way Suite 167 Lab 1
Wins-ton-SalertL North Carolina 27101
Tel [phone] Fax [phone]
URL.- www.triadforemsiccom
Starting Live
Effluent
Finai live Organism
Organism Qty.
Methodology
❑]lutions in
aty Post 24 Hour
%
Toxicant Exposure
Fathead minnow, Pimephales
promelas, Acute Toxicity Tests With
22
Standard Synthetic Freshwater
12'S
Effluents and Deceiving Waters
22
Fathead minnow, Pimephales
promelas, Acute Toxicity Tests with
Standard Synthetic Freshwater
22
Effluents and Receiving Waters
1 & 75 11
Fathead minnow, Pimephales
promelas, Acute Toxicity Tests with
Standard Synthetic Freshwater
22
Effluents and Recelving Waters
25 0
Fathead minnow, Pimephales
promelas, Acute Toxicity Tests with
Standard Synthetic Freshwater
22 Effluents and Receiving Waters
50 0
Fathead minnow, Pimephales
promelas, Acute Toxicity Tests with
Standard Synthefic Freshwater
22 Effluents and Receiving Waters
100 0
"Affordable Excellence in Analytical 'resting and Forensic Caseworle'
Page 2 of 3

CERTIFICATE OF ANALYSIS
Independent Laboratory Results:
Triad Forsnsits
ttdes�t Service l a�aralnry
391 Technology Way Suite 167 Lab 1
Winston-Salem, North Carolina 27101
TO 336-722-8963 Fax [phone]
URL: www.triadforensic.com
Total organism survival was 100% after 24 hours of exposure at 12.5% dilute Soil
RxS solution. LD50 was reached at 18.75% dilute Soil RxO solution after 24 hours of
exposure. All organisms expired within 12 hours of exposure to 25%, 50%, and 100%
dilute Soil Rx@ solutions.
Laboratory Statement of Qualiftcations (SOO).
Triad Forensics Laboratory (TFL) is compliant with iSD1lEC 17025:2005, EPA,
FDA, NELAC, ADAC, and ASCLD-LAB international accreditation guidelines for
independent testing laboratories. We are audited and conduct external proficiency tests
at least twice annually. All laboratory equipment and instrumentation are calibrated in
accordance with ISQIIEC 17025 guidelines. TFL is certified by, registered with, and
operates in the State of North Carolina.
Reported By
Lauren A. Stainback, Forensic Laboratory Director
Date Signed 06107/2010
'Affordable Excellence in Analytical Testing and Forensic Casework'
Page 3 of 3

ZAsphatt Perking
APPROXIMATE SCALE
0

Z
JL w
Z
�L� 1
HW-3
Grounding Point
FfW-4
Product Reca�ery n
Anse -B"
4p f
�� ApprC*dmatA Extent of
Con m ♦ , i Sall Exoe�tion
�+Oftlad - f�
'elw
/f
FancyNil
•..\ f
r
Asphalt Parking
Ares -o-
;1 •,
Emergency Generator '
3-Phose Electric. Line
•' HfW-2
.r Call Towar
Approximate Extent of
SonExCavaffon '
HW-9 - Aaphait Parking
1 ` Area 'A-
tan rd
;yr
T$l i Mrro l 1 re rw.
asp Highlands Gedo0�TlaIKM
1a sM-
Environmental 202 3"�`"'�"'
AQP►BW&Eftof A -A APPROXIMATE SCALE � � LCbdlgMWolaeetWifflt
C-C Solutions Inc. Qea°"'�r�°'� 'emofti`
••--"_•---- OwSmftTrewcb etr '�A55Fi[1NRV [1uUam,ilolllCaaine

A -A'
Injection Well
injection Welts
1w NMW 9 Petroleum Impacted Soil Petroleum Impacted Soil HMW4
B-B1
taryy_3 injertian Well Petroleum Impacted Sail
SOMMUSEM MEN IS
Lw MUMOMEMS E MEN
LOW JB Injection Permit
Highlands GmwdaW Gwb& 67A-Se*nDiMram
Environmental �
? a2oa� LC
Groundwater Elevgtian Note.-1 j Measurements were taken from the to p of 5alemians, fnc. aa�a �rx
Casa elevations, not the elevation of the
gfouln sud*;e on site. A55F IN Gulp+, NA Camku e 6

Area "W
0 c o
Grounding Point
�HW-3
(84.34) HW-4
(93.99)
Recove Then
d/ Appn"d►nate Extant or
�� it Excavation
770
C3eneralOr ', t
Electric Line
s,-ti . .
�< Call Tower
roxlF md* KxWnt DI ~
Soil e-%O=vQtton
w HW-1 .
i
ZAsphslt
a A"
APPROXIIA4 TE SCALE
Nvbe. 1. GmundwsWcm*mmwm peaars6W ft
lu— deb p*ft {fa walls].
2. Water level dsk wa cDlsct d on Septembr ll, 201&
92a
or sh/ Laphatt F";wMn7
Fence goo
HW-2
(87.20)
m

A-1
e'- a 151
Be ajrt(A�
- 60
C-1
P�isop ene - 4.955
0.120
Na hth ene 8.0
0.160
2 ethApaphthalene - 7.19
3.600
D-1
Naphthfte - 0.38
0.160
D-3
Naph halene - 0.191
0.160
�HW-3 a OrroLrtidny Point
Pru[iuet FtecuVBry Tren
Arse ^s• ��� _`ar
Area ul=-
E-3 '
for _
ApploxhY ate Extant of
saiii ExeaaveSian
PW
Area of Residue) P®Wolaum
Area ^ Impacted Soil
Fence
}C-1
A '/ter r f' Q1 ZAsphalt Parking
\ 1.
En-wwncy 'a rotor
;.. / Fence
3-Phase EiacM c. L e
�., HW 2
Call7awar
A*0
Approximate Extent of
Snit Excavation • � ..
"W-1 N. •-2 LeAsphalt Parmng
APPROXIMATE SCALE
-Ares -A-
' tart rd
• Art
Ares of Residue! Ps"66unt
Impacted Soil
z

Monitoring well Constituent Concentration 2L standard
HMW 1 bis(2-Ethythexyi)phthalate 8.0 3.0
-1L
Q
Z
"W�3 HW-4 0 Proundlnq Pohl
e�
S Product Racavery T
0 Appro &nzft Exima of
sWl �ceEre�tlen
Emergency Garwr for
s-Phase McQldo L kM
�L-
ApryNxlrnate C-xtent of -
Soil Excavag{
H W--7
APPRox1MME SCALE
..A'
Cell Tower HW-2
ZAephell Pa ";r
�AMPhAR
Monitoring Well
Constituent
Concentration
2L Standard
HMW-2
Naphthalene (8260)
98.5
6.0
Naphthalene (8270)
47.2
6.0
1-Methyinaphthalene
28.0 1.0
2-Methyinaphtholene
37.8 30.0
Fence
Highlands
Environmental
\ Solutions, Inc.
Injection Permit
21 Exceedarloe l]iagram - - - - -
LC Industries Ruse Incident
LC Industries, Inc,
Durham, North Carolina

LW-d
0 Soil Sample LKabon
TreatmentArea
■ hWtoft well Location
Areas of soil lrwe4adon
Approximafe Extent of
Sorb ExcavaBon
Areas of Residuaf Petroleum
lmpacted soil
�H W-3
HW-A
0 Grounding Paint
Product Recovery Trenc
Area ^B.. @�i®
4
NP
Area "E" E_3 ♦ C�°
�t-1 �� 1
6_T. E-2_ _ Approximate Extent of
% f _ Soll Excavation
Concrete Aed �. - ::..
.:Nb
N,f
EW
�Area of Residual Petroleum - _-
-- - Impacted Soil
Area "C" -
Fence i
f Treatment Area C
Treatment Area D
Oa �� ------ --
y C--1
J* a
D'1 Asphalt Parking
A-5 � � i
A-5
Emergency Generator j}�
l Fence
3-Phase Electric Lime
A-d
I IW_2
AM. A�3 � Gall lower
Approximate Extent of
Soil Excavation
HW-1 , �A-2 IeAsphalt Parking
Area "A"
e
�
1 Area of Residual Petroleum
Impacted Sail
Treatment Area A
APPROXIMATE SCALE
v N 46'
zz
2
-JL
Z
Highlands - Injection Permit
�BF p` SM Proposed Remedial diagram
Environmental
z02002 LC Industrm Release jil* i!
December 2014 LC lffthes, Im-
Salutions, Inc. .., auftRNo* Camrre
ASSHOWN
FJp
10

so# &ample Looffm f
0 l4fa tOq Well toollon
Areas of Sod JnvesUpOon
AAprw#wtPExkdof
Soil EExcavalion
Areas of Resrd+W Pelydlaum
lmpaded Sad
LIUFreatmerrt Area
IS Injection Point
-r4iO .3enerawr Product Recovery Trenc
Gel Controls
erg
for ti0
Area "B" @aL o�Gtd
Area "EE" E_3 G
motor - 1
rea -
Fence
Treatment Area C
Ohi'i
1%
A-6 '
Emergency Geryerator
3-Phase Electric Line
` A~4'0
Approximate Extent of
\...
Sail Excavation
41V
a�
Cell Tower
Approximate Extent of
- Soil Excavation
Area of Residuel Petroleum
Impacted Soil
__ -- Treatment Area D
?#} l7- Injection Points
0-� Asphalt Parking
�� Area "D" X
H W-2
�A-2
HW-gAspt7alt Parking
X
I-W hU Stan
s �
APPROXIMATE SCALE
0' r5' 3o'
Area "A"
Area of Residuel Petroleum
Impacted Soil
Treatment Area A
Fence
Highlands
IZ Environmental
Solutions, Inc.
JB
BF SM
M bw. ,.
202002
ate:
December 2014
SAS SHOWN
1 L
0
Z
Injection Permit
Proposed Injection Points Diagram
LC Indwties Rdme Incident
LC kkis ie;, Inc.
Ifahm, North Carolina