WI0700459_Application_20170718

July 17, 2017
Division of Water Resources - UIC Program
1636 Mail Service Center
Raleigh, NC 27699-1636
Telephone [phone]
RECEIVEDINCDEQIDWR
JUL 1 8 2017
Water Quality Regional
Operations Section
Subject: UIC Permit Application
Former West Pharmaceutical Services Site
2525 Rouse Road Extension
Kinston, North Carolina
Inactive Hazardous Site No. NCD000407582
Docket No. 09-SF-290
UIC Program:
On behalf of West Pharmaceutical Services, Inc. (West), ERM NC, Inc.
(ERM) is submitting two (2) copies of an Underground Injection Control
(UIC) Permit Application for the above referenced Site.
Sincerely,
04.
Rick Tarravechia, P.G., RSM
Principal
Enclosure
ERM NC, Inc.
15720 Brixham Hill Ave
Suite 120
Charlotte, NC 28277
Tel no [phone]
www.erm.com
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North Carolina Department of Environmental Quality — Division of water Resources
APPLICATION FOR PERMIT TO CONSTRUCT AND/OR USE A WELL(S) FOR INJECTION
In Situ Groundwater Remediation (15A NCAC 02C .0225) / Tracer Injection (15A NCAC 02C .0229)
Do not use this form for the following:
• In -situ remediation, tracer, or aquifer test injection wells permitted by rule (ref. 15A NCAC 02C .0217)
• remediation systems that reinject treated contaminated groundwater (Non -discharge) (ref. 15A NCAC 02T .1600)
Permit Number (to be completed by DWR): WI 0 ° ° s c(
APPLICATION INFORMATION
1. Project is: [X] New [ ] Modification [ ] Renewal without modification [ ] Renewal with modification
2. If this application is being submitted for Renewal and/or Modification to an existing permit, provide:
(a.) Existing permit number WI Issued Date: & Expiration Date:
For all Renewals, submit a status report including monitoring results of all injection activities to date.
For Renewal without modification only, fill out sections I & II only, sign the certification on the last page of this
form,
and obtain the property owner's signature to indicate consent (if the applicant is not the owner).
II. WELL OWNER(S)/PERMIT APPLICANT (generally the responsible party)
1. Name(s): West Pharmaceutical
2. Signing Official's Name*: Steven Walton Title: VP HSE & Sustainability
* Signing Official must be in accordance with instructions in Part X on page 5.
3. Mailing address of Permittee/Applicant: 530 Herman O. West Drive
City: Exton State: PA Zip: 19341
4. Telephone number: 610-594-3354 Email: <Steven.Waltonc iwestpharma.com>
5. Status (choose one): Individual X Business/Org. Federal State County Municipality
III. PROPERTY OWNER(S) (if different than well owners)
1. Name(s): NC Global Transpark Authority, Attn: Allen Thomas
2. Mailing address: 3800 Hwy 58 North
City: Kinston State: NC Zip: 28504-7928
3. Telephone number: 252-523-1351 Email: <amthomas iincdot.gov>
IV. PROJECT CONTACT — (generally the environmental/engineering consultant).
1. Name: Rick Tarravechia Title: Principal, P.G., RSM
2. Company: ERM NC, Inc.
3. Address: 15720 Brixham Hill Avenue, Suite 120
4. City: Charlotte State: NC Zip: 28277
5. Telephone number: 704-409-3440 Email: rick.tarravechia@@erm.com
RECENEDINCOEQIDWR
In -Situ Groundwater Remediation Application Rev. 3-1-2016
JUL 18 2017
Water Quality Regional
Operations Section
Page 1 of 14

V. FACILITY INFORMATION
1. Facility name: Former West Pharmaceutical Services Facility (undeveloped portion)
Phone No. if available: NA (Inactive, Vacant)
2. Physical address: 2525 Rouse Road Extension
City: Kinston County: Lenoir Zip: 28504
3. Geographic Coordinates: Latitude: 35° 19' 5" N
Longitude: 77° 36' 46" W
Reference Datum: Accuracy:
Method of Collection (i.e., Google Earth, GPS, etc.): Google Earth Pro
4. Brief description of business: Currently Vacant
VI. INCIDENT DESCRIPTION
1. Source and date of contamination: The West site was involved in the production of specialty rubber products for use in
the medical industry from its initial construction circa 1975, but ceased manufacturing operations in January 2003 after an
explosion occurred at the site. West entered into an Administrative Order on Consent (AOC) with the United States
Environmental Protection Agency (EPA) for management of the site investigation activities following the explosion and
fire. A comprehensive site assessment of the environmental impacts of the fire incident was required as a condition of the
AOC. Based on assessment activities following the fire, halogenated volatile organic compounds (VOCs), including
trichloroethene (TCE), cis 1, 2-dichloroethene (cDCE) and vinyl chloride (VC) were detected in site groundwater. Because
of the apparent VOC distribution, low concentrations, and the presence of TCE and associated daughter products, including
cDCE and VC, the contaminants likely predated the explosion and fire and the incident mitigation efforts. Figures 1
through 4 show the site location, layout, approximate potentiometric surface, and extent of cDCE in groundwater,
respectively.
2. List all contaminants present in soils or groundwater at the site (contaminants may be listed in groups, e.g., gasoline,
diesel, jet fuel, fuel oil, chlorinated ethenes, chlorinated ethanes, metals, pesticides/herbicides, etc):
chlorinated ethenes and chlorinated ethanes
3. Has LNAPL or DNAPL ever been observed at the site (even if outside the injection zone)?
[ ] Yes If yes, list maximum measured separate phase thickness: feet
[X] No If no, list maximum concentration of total VOCs observed at site: 3,300 (2016 data) ppb
4. Agency managing the contamination incident:
[ ] UST Section [x] Superfund Section (including REC Program and DSCA sites)
[ ] DWR Aquifer Protection Section [ ] Solid Waste Section
[ ] Hazardous Waste Section [ ] Other:
5. Incident manager's name: Dianne Thomas Phone No.: [phone]
6. Incident number or other incident mgmt. agency tracking number: NCD000407582
In -Situ Groundwater Remediation Application Rev. 3-1-2016 Page 2 of 14

VII. PERMITS
List all applicable permits or construction approvals issued for the facility or incident:
I. Previous or other UIC permits issued by DWR (e.g., NOIs) Not Applicable
2. Other Non -Discharge or NPDES permit issued by DWR: Not Applicable
3. County or DEH subsurface wastewater disposal permits: Not Applicable
4. Hazardous waste management or other environmental permits required by state or federal law: Not Applicable
In -Situ Groundwater Remediation Application Rev. 3-1-2016 Page 3 of 14

VIII. INJECTION SUMMARY
1. List all proposed injectants/additives.
NOTE: Only injectants approved by the epidemiology section of the NC Division of Public Health, Department
of Health and Human Services can be injected. Approved injectants can be found online at
http://deq. nc. gov/about/divisions/water-resources/water-resources-permits/wastewater-branch/ground-water-
protection/ground-water-approved-injectants. All other substances must be reviewed by the DHHS prior to use.
Contact the UIC Program for more info (919-807-6496) if you wish to get approval for a different additive.
However, please note it may take 3 months or longer.
Injectant: ABC with dehalococcoides Total Amt. to be injected (gal)/event 8,000 gal
Injectant: water Total Amt. to be injected (gal)/event 17,000 gal
Injectant: Total Amt. to be injected (gal)/event
Injectant: Total Amt. to be injected (gal)/event
Injectant: Total Amt. to be injected (gal)/event
2. Number of separate injection events: One (1) Duration of Event: 10 to 12 days
3. Estimated Injection rate per well: unknown gallons per minute (GPM)
4. Estimated Injection pressure: 40-100 pounds/square inch (PSI)
5. Temperature at point of injection: ambient °F
6. Injection will be via:
❑ Existing well(s); Total No.: : Well Type (DPT, permeant, etc.):
►Z�
Proposed well(s); Total No.:
50 ; Well Type (DPT, permeant, etc.): DPT
7. NC Certified Well Drilling Contractor's Name: To be determined based on vendor cost and driller availability
NC Well Contractor Certification No.:
8. Date to be constructed: Pending Work Plan Approval
9. Screened interval/Injection interval of injection wells:
Depth from 5 to 15 feet below land surface (BLS)(if multiple intervals, indicate shallowest to
deepest depth)
10. Well casing (leave blank if Geoprobes):
Type: ❑ PVC ❑ Stainless steel ❑ Other:
Casing depth: to ft. BLS
Type: ❑ PVC ❑ Stainless steel ❑ Other:
Casing depth: to ft. BLS
11. Grout (leave blank if Geoprobes):
Type: ❑ Cement ❑ Bentonite ❑ Other:
Grout depth: to ft. BLS
Type: ❑ Cement ❑ Bentonite ❑ Other:
Grout depth: to ft. BLS
In -Situ Groundwater Remediation Application Rev. 3-1-2016
Page 4 of 14

IX. ATTACHMENTS — provide the following information in separate attachments. The attachments should be
clearly identified and presented in the order below to expedite review of the permit application package.
1. INJECTION ZONE — Per 15A NCAC 02C .0225(e)(2), specify the horizontal and vertical portion of the subsurface within
which the proposed injection activity will take place and beyond which no violations of groundwater quality standards
shall result from the injection as determined by an approved monitoring plan. The determination shall be based on the
hydraulic properties of the specified zone. Provide any supporting documentation in a separate attachment.
2. HYDROGEOLOGIC EVALUATION — Per 15A NCAC 02C .0225(e)(3), provide a hydrogeologic evaluation of the
injection zone that includes all of the following:
(A) Regional and local geology and hydrology;
(B) Changes in lithology underlying the facility;
(C) Depth to bedrock;
(D) Depth to the mean seasonal high water table;
(E) Hydraulic conductivity, transmissivity, and storativity, of the injection zone based on tests of site -specific
material, including a description of the test(s) used to determine these parameters;
(F) Rate and direction of groundwater flow as determined by predictive calculations or computer modeling; and
(G) Lithostratigraphic and hydrostratigraphic logs of any existing test and injection wells.
3. INJECTANT INFORMATION — Per 15A NCAC 02C .0225(e)(5). provide information on each injectant as indicated below:
(A) MSDS, concentration at the point of injection, and percentage if present in a mixture with other injectants;
(B) The source of fluids used to dilute, carry, or otherwise distribute the injectant throughout the injection zone. If
any well within the area of review of the injection facility is to be used as the fluid source, then the following
information shall be submitted: location/ID number, depth of source, formation, rock/sediment type, and a
chemical analysis of the water from the source well, including analyses for all contaminants suspected or
historically recognized in soil or groundwater on the site;
(C) A description of the rationale for selecting the injectants and concentrations proposed for injection, including an
explanation or calculations of how the proposed injectant volumes and concentrations were determined;
(D) A description of the reactions between the injectants and the contaminants present including specific breakdown
products or intermediate compounds that may be formed by the injection;
(E)- A summary of results if modeling or testing was performed -to investigate the injectant's potential or susceptibility
for biological, chemical, or physical change in the subsurface; and
(F) An evaluation concerning the development of byproducts of the injection process, including increases in the
concentrations of naturally occurring substances. Such an evaluation shall include the identification of the specific
byproducts of the injection process, projected concentrations of byproducts, and areas of migration as determined
through modeling or other predictive calculations.
4. INJECTION PROCEDURE — Per 15A NCAC 02C .0225(e)(6), submit a table with a detailed description of the proposed
injection procedure that includes the following:
(A) The proposed average and maximum daily rate and quantity of injectant;
(B) The average maximum injection pressure expressed in units of pounds per square inch (psi); and
(C) The total or estimated total volume to be injected.
In -Situ Groundwater Remediation Application Rev. 3-1-2016 Page 5 of 14

5. FRACTURING PLAN (if applicable) — Per 15A NCAC 02C .0225(e)(7), submit a detailed description of the fracturing plan
that includes the following:
(A) Material Safety Data Sheets of fracturing media including information on any proppants used;
(B) a map of fracturing well locations relative to the known extent of groundwater contamination plus all buildings,
wells, septic systems, underground storage tanks, and underground utilities located within the Area of Review;
(C) a demonstration that buildings, wells, septic systems, underground storage tanks, and underground utilities will
not be adversely affected by the fracturing process;
(D) injection rate and volume;
(E) orientation of bedding planes, joints, and fracture sets of the fracture zone;
(F) performance monitoring plan for determining the fracture well radius of influence; and
(G) if conducted, the results of geophysical testing or pilot test of fracture behavior conducted in an uncontaminated
area of the site.
6. WELL CONSTRUCTION DETAILS — Per 15A NCAC 02C .0225(e)(8), submit the following information in tabular or
schematic form as appropriate for each item:
(A) number and depth of injection wells;
(B) number and depth of borings if using multi -level or "nested" well systems;
(C) indication whether the injection wells are existing or proposed;
(D) depth and type of casing;
(E) depth and type of screen material;
(F) depth and type of grout;
(G) indication whether the injection wells are permanent or temporary "direct push" points; and
(H) plans and specifications of the surface and subsurface construction details.
7. MONITORING PLAN — Per 15A NCAC 02C .0225(e)(9), submit a monitoring plan that includes the following:
(A) target contaminants plus secondary or intermediate contaminants that may result from the injection;
(B) other parameters that may serve to indicate the progress of the intended reactions;
(C) a list of existing and proposed monitoring wells to be used; and
(D) a sampling schedule to monitor the proposed injection.
Monitoring wells shall be of sufficient quantity and location to detect any movement of injection fluids, injection process byproducts,
or formation fluids outside the injection zone. The monitoring schedule shall be consistent with the proposed injection schedule, pace
of the anticipated reactions, and rate of transport of the injectants and contaminants.
8. WELL DATA TABULATION — Per 15A NCAC 02C .0225(e)(10), provide a tabulation of data on all existing or
abandoned wells within the area of review of the injection well(s) that penetrate the proposed injection zone, including
monitoring wells and wells proposed for use as injection wells. Such data shall include a description of each well's type,
depth, and record of construction or abandonment.
9. MAPS AND CROSS -SECTIONS — Per 15A NCAC 02C .0225(e)(11), provide scaled, site -specific site plans or maps
depicting the location, orientation, and relationship of facility components including the following:
(A) area map based on the most recent USGS 7.5' topographic map of the area, at a scale of I :24,000 and showing the
location of the proposed injection site;
(B) topographic contour intervals showing all facility related structures, property boundaries, streams, springs, lakes,
ponds, and other surface drainage features;
(C) all existing or abandoned wells within the area of review of the wells listed in the well data tabulation that
penetrate the proposed injection zone;
(D) potentiometric surface map(s) that show the direction of groundwater movement, existing and proposed wells;
(E) contaminant plume map(s) with isoconcentration lines that show the horizontal extent of the contaminant plume
in soil and groundwater, and existing and proposed wells;
(F) 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, major changes in lithology, and existing and proposed wells; and
(G) any existing sources of potential or known groundwater contamination, including waste storage, treatment, or
disposal systems within the area of review of the injection well or well system.
In -Situ Groundwater Remediation Application Rev. 3-1-2016 Page 6 of 14

X. CERTIFICATION (to be signed as required below or by that person's authorized agent*)
NCAQ IS ,, 02§ .021 ifs? wires that all permit applications shall be signed as follows:
1. for a aorp : by a responsible corporatc officer
2. for a whip or sole proprietorship: by a Friend partner or the ptolrrictor, respectively
3. for a municipality or a state, federal, or other public agency: by either a principal executive officer or
ranking publicly elected official
4. for all others: by the well owner.
*If an authorized agent Is signing on behalf of the applicant, then supply a letter signed by the applicant
that names and authorizes their agent.
"1 hereby comfy under penalty of law that 1 have personally examined and am familiar with the information
submitted in this document and all attachments therein, and that, biased on my inquiry of those individuals
immediately responsible for obtaining said information, 1 believe that the information Is true, accurate, and
complete. I am aware that there are penalties, including the possibility affirms hies and imprisonment, for submitting
false information. 1 agree to construct, operate, maintain, repair, and if applicabk, abandon the injection well(s)
and all related appurtenances in accordance with the approved specifications and conditions of the Permit."
Printed Name azd Title; Sfcyes OA_1+mv - VP JI J E g 1.0);4'Ab i 1►7'c}
Signature: ,t11 '07
XI. CONSENT OF PROPERTY OWNER (if the property is not owned by the permit applicant)
"Owner" means any person who hold" the fee or other property rights is the well being constructed. A well i real
property and its construction on land shad be deemed to vest ownership in the land owner, in the absence of
contrary agreement In writing.
"As owner of the property on which the injection well(s) are to be constructed and operated,1 hereby consent to
allow the applicant to construct each injection well as outlined in this application and agree that it shall be the
responsibility of the applicant to ensure that the injection well(s) conform to the Well Construction Stemdards
(1.54 NC:4C' 02C . ()2QQj. "
Printed Name and lilt. i t.. � A s t iC!_-
Signature:
Date: .7- / 2 17
Submit TWO copies of the completed application package, including all attachments, to:
Division of Water Resources — UIC Program
1636 Mail Service Center
Raleigh, NC 27699-1636
Telephone [phone]
In -Situ Groundwater Remediation Application Rev. 3-1-2016 Page 7 of 14

Attachments
In -Situ Groundwater Remediation Application Rev. 3-1-2016 Page 8 of 14

Attachment 1 Injection Zone:
The proposed Injection Zone is shown on Figures 5 through 9. Up to 50 injection points will be completed on
approximately 30 ft centers, each to a depth of approximately 15 feet below ground surface.
Attachment 2 — Hydrogeologic Evaluation
Site Hydrogeology
The surface water bodies within '/ mile of the Site are an unnamed stream (drainage ditch) which is a tributary of Briery
Run Creek. The stream is in the proposed injection area.
The depth to groundwater varies across the site from 0.5 to 6 ft bgs. Based on observations during remedial investigation
well installation and routine water level measurements, the shallow aquifer is unconfined. Based on groundwater
elevations collected on March 11, 2016, groundwater flow across the site is generally to the east-southeast, toward two
drainage ditches located on the perimeter of the site.
The hydraulic conductivity of the aquifer was determined using data from slug tests for MW-2, MW-3, MW-8, MW-2D,
and MW-8D. Based on rising head slug tests, hydraulic conductivities at the site range from 0.19 to 3.3 feet per day in the
shallow unconfined aquifer zone and 0.074 to 0.24 feet per day (ft/day) in the deeper confined aquifer zone. The hydraulic
conductivities determined for the shallow aquifer are within the range typical of silty and fine sands, 0.28 to 28 ft/day (10-
5 to 10-3 cm/sec) (Fetter, Jr., C.W., Applied Hydrogeology, Bell & Howell Co., Columbus, Ohio, 1985).
Based on the March 2016 water levels, the calculated groundwater velocity in the shallow aquifer at the site is
approximately 4.05 feet per year, using the geometric mean hydraulic conductivity of 0.73 feet per day and assuming an
effective porosity of 0.30 for silty sand and a gradient of 0.004.
Site Geology
The Kinston area, including the subject site, is located within the Atlantic Coastal Plain province of North Carolina. The
lithology of the Coastal Plain province generally consists of unconsolidated sediments and sedimentary rocks deposited on
top of crystalline basement rocks. Typically, coastal plain sediments dip and thicken to the east. The thickness of Coastal
Plain sediments ranges from a few feet at the western limit of deposition to over 10,000 feet along the North Carolina
coastline.
The occurrence and movement of groundwater in the Coastal Plain province is generally within the pore spaces of
unconsolidated sediments (primary porosity), and to a lesser degree, within the fractures, bedding plains, and solution
cavities (secondary porosity) of semi -consolidated rocks. Groundwater occurs in shallow unconfined aquifers and in
deeper, confined aquifers. Groundwater in the deeper confined aquifers is under pressure, and may exhibit equipotential
water levels near the land surface. Recharge of the groundwater system in the Coastal Plain occurs in interstream areas
where sand layers crop out and by downward percolation across interbedded clay and silt layers. Discharge from the
system occurs to streams, estuaries, and the ocean. Under unconfined, or water table conditions, groundwater flow will
generally mimic topography, flowing from upland areas (recharge zones) to nearby surface streams (discharge zones).
The subject site is underlain by sedimentary deposits of Late Cretaceous age Peedee and Black Creek Formations
consisting mostly of fine to medium -grained marine sands, clayey sand, clay, and lignitic sand with confining units of clay
and silt. The confining units generally range from 20 to 70 feet in thickness. According to the aquifer and confining unit
data presented by Winner and Lyke (1989), the surficial aquifer extends to approximately 20 feet below ground surface as
recorded in the existing on -site site monitoring well logs. The Peedee confining unit separates the surficial aquifer from
the underlying Peedee aquifer (50 to 130 feet bgs) and Black Creek aquifer. The Black Creek aquifer lies at
approximately 180 to 348 feet below ground surface and is hydraulically isolated from the Peedee aquifer by the Black
Creek confining unit.
Regionally, the North Carolina Coastal Plain is underlain mostly by the Peedee-Upper Cape Fear aquifer system,
including the subject area in Lenoir County, with an average thickness of approximately 570 feet. The Peedee-Upper
Cape Fear aquifer consists of the local Peedee, Black Creek, and Upper Cape Fear aquifers. The regional Peedee-Upper
Cape Fear aquifer underlies the Kinston area. The aquifer consists of permeable sands of the Peedee Formation, the Black
In -Situ Groundwater Remediation Application Rev. 3-1-2016 Page 9 of 14

Creek Formation and the upper part of the Cape Fear Formation. A clayey confining unit overlies the Peedee-Upper Cape
Fear aquifer formation in most places and the formations are separated by confining units of silt and clay that generally
range in thickness from 20 to 70 feet. The primary recharge for these aquifers is through outcrops at land surface areas
where rainfall can move into the deeper confined aquifer. These formations only reach land surface much further to the
west of the Kinston area where this recharge occurs. However, some leakage across confining beds may occur locally.
Literature about regional geology states that the shallow, surficial aquifer extends to a depth of approximately 20 feet
where the Peedee confining unit hydraulically separates it from the regional Peedee aquifer below (Winner and Lyke
(1989) in their USGS report on aquifers of Cretaceous rocks in the Coastal Plain). This clay confining unit was
encountered during installation of the monitoring wells ranging at depths ranging from 16 feet to 18 feet below ground
surface (bgs). Clayey and sandy silts, silty clays and silty sands were encountered from ground surface to approximately
16 to 18 feet bgs during monitoring well installation at the site.
Attachment 3 — Injectant Information
In -situ bioremediation is the primary remedial technology for treatment of groundwater at the West site. Under ideal
geochemical conditions, the chlorinated ethene TCE (and its anaerobic daughter products cDCE and VC) can be
biologically transformed by dehalorespiring bacteria into non -chlorinated organic compounds under anaerobic conditions.
Based on groundwater sampling results, geochemical parameters at the Site are favorable for survival of dehalorespiring
bacteria (i.e. low dissolved oxygen and negative ORP).
Dehalorespiring bacteria sequentially replace chlorine atoms in chlorinated ethenes with hydrogen. This process is
referred to as reductive dechlorination. This reaction provides energy for growth to the bacteria and reduces chlorinated
compounds to naturally occurring non -chlorinated organic compounds such as ethene and ethane. The transformation of
TCE and associated daughter products to ethene by dehalorespiring bacteria is depicted below.
Biological transformation (reductive dechlorination) of chlorinated ethenes
H2 H2 H2
TCE±" DCE+" VC—' Ethene
I HCI HCI HCI
Simple organic compounds, such as lactate, can be added to the subsurface stimu>ate the growth of dehalorespiring
bacteria and consequently promote the reduction of chlorinated ethenes. These organic compounds serve as "food" for
the dehalorespiring bacteria, providing a source of energy and carbon for the bacteria.
The proposed in -situ bioremediation method consists of injecting Anaerobic BioChem® (ABC®) (Appendix) and
Dehalococcoides (DHC) bacteria into the aquifer through injection wells. The input of hydrogen depicted in the figure
above at the West site will be provided by ABC®. ABC® is a patented mixture of lactate, fatty acids, and a phosphate
buffer.
Several strains of bacteria are capable of transforming cDCE to the daughter product vinyl chloride (VC); however, DHC
bacteria must be present to degrade vinyl chloride to ethene. DHC bacteria are not always abundantly present in the
subsurface, but can be added with the carbon substrate during injection to promote complete degradation of TCE/cDCE
and daughter products to ethene.
The proposed injection event will consist of approximately 500 pounds of Anaerobic Biochemo (ABC) -high pH buffer
and 0.5 liter of DHC bacteria mixed with approximately 340 gallons of water. This mixture will be injected into each of
the 50 injection point locations for a total for the site of 25,000 pounds of ABC, 25 liters of DHC bacteria in 17,000
gallons of water. The recipe for the ABC® solution or "injectant" for each well is summarized below:
Iniectant Recipe
Material
Volume (gallons)
ABC® compound
160 (500 pounds)
DHC bacteria
0.13
Water (municipal supply)
340
Total solution per injection well
—500
In -Situ Groundwater Remediation Application Rev. 3-1-2016 Page 10 of 14

Attachment 4 — Injection Procedure
The injection event will include 50 injection points placed on approximately 30-foot centers. The injection points will be
advanced via direct -push technology (DPT) to a depth of approximately 15 feet below ground surface (bgs). The
concentrated ABC® solution will be batch mixed in a 500-gallon tank for injection into the subsurface. Water obtained
from the municipal water system will be used to prepare the ABC® solution. Fluids will be injected into each of the
injection wells by connecting the tank of mixed injectant to the DPT well via cam -lock fittings and flexible hoses. Then
fluids will be injected into the top of the well and will flow through the well screen and into the surrounding aquifer. The
injection will be performed using a pump capable of generating up to 100 pounds per square inch pressure (psi). The
anticipated injection pressure is 40-100 psi depending on site -specific conditions. The actual injection pressure will be
determined in the field based on site -specific conditions. The injection event is expected to Last 10 to 12 days. A map of
the general locations of the injection points per event is provided in Figure 5.
Attachment 5 — Fracturing Plan
Not Applicable — Application is not for fracturing.
Attachment 6 — Well Construction Details
Fifty injection points will be advanced via temporary direct -push methods to a depth of approximately 15 feet. The
injection will be performed directly through the DPT drill rods and attached 5-foot stainless steel well screen. No
temporary PVC wells will be installed. Injection will occur on 5 foot vertical intervals between 5 and 15 ft bgs at each
location. A schematic of DPT construction details (temporary wells) used for the injection points are include as Figure
10.
Attachment 7 — Monitoring Plan
During the remediation project, groundwater samples will be collected from existing and proposed monitor wells within
the treatment area at the site. Prior to injection, baseline groundwater samples will be collected from each of the wells
referenced below including 4 new additional monitor wells (MW-16 through MW-19). Following the baseline sampling
event, quarterly sampling will be conducted in each of the wells for the first year post injection. Groundwater samples will
be collected semi-annually for year 2 following the injection and then annually thereafter, or until a new plan is proposed.
A summary of the monitoring plan is provided in the following table.
Summary of Groundwater Monitoring Plan
Wells
Sample Frequency
Year 1 Year Years
2 3+
Parameters
VOCs TOC Iron Mn S042
NO3 Field
Parameters
MW-9 131,/Qrtly SA AN X X X X X X X
MW-10 BL/Qrtly SA AN X X X X X X X
MW-11 BL/Qrtly SA AN X X X X X X X
MW-13 BL/Qrtly SA AN X X X X X X X
MW-16 (p) BL/Qrtly SA AN X X X X X X X
MW-17 (p) BL/Qrtly SA AN X X X X X X X
MW-18 (p) BL/Qrtly SA AN X X X X X X X
MW-19 (p) BL/Qrtly SA AN X X X X X X X
BL = Baseline VOCs = Volatile organic compounds TOC = Total Organic Compounds Mn = Manganese
(p) proposed by EPA 8260B S042 =Sulfate
Qrtly = Quarterly AN = Annually
SA = Semi Annually NO3 = Nitrate
Field Parameters: oxygen reduction potential (Eh), pH, dissolved oxygen (DO) temperature, and specific conductance
Attachment 8 — Well Tabulation Data
Well construction details and groundwater contaminant concentrations for existing monitoring wells within the injection
area are summarized below.
In -Situ Groundwater Remediation Application Rev. 3-1-2016 Page 11 of 14

Well Construction Details
Well ID
Installation
Date
Drilling
Method
Well
Type
Well Material)
Well Head
Details
Monitored
Aquifer Zone
Total Depth
Screened
Interval
Land Surface
Elevation
(ft msl)
Measuring Point
Elevation TOC (ft
msl)
(ft bls)
(ft bls)
(ft msl)
(ft msll
MW-9
03/20/12
H.S.A.
II
SS / Stickup
Shallow SAP
18
8 - 18
86.32
88.82
M W-10
03/20/12
H.SA.
II
SS / Stickup
Shadow SAP
18
8 -18
86.42
88,92
M W-11
10/02/12
H.SA.
II
SS / Stickup
Shallow SAP
18
8 -18
85.24
87.74
MW-12
10/02/12
H.SA.
II
SS / Stickup
Shallow SAP
18
8 -18
85.4
87.9
M W-13
10/02/12
H.S A.
II
SS / Stickup
Shallow SAP
18
8 -18
85.07
87.57
MW-13D
10/04/12
H.SA.
III
SS / Stickup
Deep SAP
50
45 - 80
85.05
87.55
MW-14
10/03/12
H.S.A.
II
SS / Stickup
Shallow SAP
18
8 -18
85.26
87.76
MW-15
10/03/12
H.SA.
II
SS / Stickup
Shallow SAP
18
8 -18
85.18
87.68
NV-1
07/09/13
H.SA.
II
SS / Stickup
Shallow SAP
18
8 - 18
-
-
W-2
07/09/13
H.SA.
II
SS / Stickup
Shallow SAP
18
8 - 18
-
-
NV-3
07/09/13
H.SA.
II
SS / Stickup
Shallow SAP
18
8 - 18
-
-
OB-1
07/09/13
H.SA.
II
SS / Stickup
Shallow SAP
18
8 - 18
-
-
OB-2
07/09/13
H.SA.
It
SS / Stickup
Shallow SAP
18
8 - 18
-
-
OB-3
07/09/13
H.SA.
II
SS / Stickup
Shallow SAP
18
8 - 18
-
-
MW-16
Proposed
H.SA.
II
SS / Stickup
Shallow SAP
18
8 -18
-
-
MW-17
Proposed
H.SA.
0
SS / Stickup
Shallow SAP
18
8 - 18
-
--
MW-18
Proposed
H.SA.
0
SS / Stickup
Shallow SAP
18
8 - 18
-
-
MW-19
Proposed
H.S.A.
1
SS / Stickup
Shallow SAP
18
8 - 18
-
-
Notes:
All measurements in feet; At wells constructed with 2-inch screen and riser pipe; Ft bls = Feet below land surface; "-" = not applicable
PVC = polyvinyl chloride; TOC = Top of Casing; SS = Stainless Steel
SAP = Saprolite
Summaof•Groundwater Qfrality - Injection Area
Volatile Organic Compounds (VOCs) EPAMethod 8260B (pg)L
Xylenes (total)
Sample ID
Sample
Date
Screened
Interval
(ftbls)
Aquifer
Zone
Monitored
Acetone
o
m
c
C
Oa
r4
Chloroform
1,1-Dichloroethene
C
g
.1
4
u
L
o
."6.
4
DCDFM
W
co
3/
Tetrachloroethene
Trichioroethene
Vinyl Chloride
NC 2L Groundwater Standard
6,000
1
4,000
70
7
70
100
1,000
20
1
3
0
500
-T
MW-9
02/23/16
8- 18
Shallow SAP
<100
<25
<50
<25
<25
340
3.4 J
<25
<25
<25
<25
64
<25
WV-10
02/23/16
8 - 18
Shallow SAP
<400
<100
<200
4.5 BJ
<100
1,700
13 J
<100
<100
<100
17 J
130
<100
MW-11
02/22/16
8 - 18
Shallow SAP
<20
<5.0
<10
<5.0
<5.0
56
0.58 J
<5.0
<5.0
<5.0
0.27 J
2.5
<5.0
OB-1
03/18/16
8 - 18
Shallow SAP
<400
<100
<200
<100
<100
2,300
29 J
<100
<100
<100
<100
2900
<100
OB-2
03/18/16
8 - 18
Shallow SAP
<200
<50
<100
<50
<50
1,700
26 J
<50
<50
<50
<50
3500
• <50
OB-3
03/18/16
8 - 18
Shallow SAP
60
<5.0
140
<5.0
0.64 J
270
2.1 J
<5.0
0.37 J
<5.0
3 J
1200
1.4 J
ug/L = micrograms per liter
SAP = Saprolite
Attachment 9 - Maps and Cross Sections
• Figure 1 Site Location Map
• Figure 2 Site Map
• Figure 3 Shallow Potentiometric Surface Map
• Figure 4 cis-1,2-DCE Isoconcentration Map
• Figure 5 Proposed Environmental Activities Map
• Figure 6 Cross Section Transect Map
• Figure 7 Cross Section A -A'
• Figure 8 Cross Section B-B'
• Figure 9 Cross Section C-C'
• Figure 10 Temporary DPT Well Schematic
In -Situ Groundwater Remediation Application Rev. 3-1-2016 Page 12 of 14