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WI0100089_Complete File - Historical_20100524
- i. State of North Carolina Department of Environment and Natural Resources Division of Water Quality RECEIVED ! DEAR / DWQ AQUIFFR PRnTF('TinN cFCTIOH MAY 2 4 2010, APPLICATION FOR PERMIT TO CONSTRUCT AND/OR USE A WELL(S) FOR INJECTION Type 5I Wells — In Situ Groundwater Remediation / Type 5T Wells — Tracer Injection • Do not use this form for remediation systems that extract contaminated groundwater, treat it, and reinject the treated groundwater. • Submit TWO copies of the completed application and all attachments to the address on the last page of this form. • Any changes made to this form will result in the application package being returned. Application Number (to be completed by DWQ): I. GENERAL INFORMATION: National Park Service - 1. Applicant's Name (generally the responsible party): Blue Ridge Parkway (BRP ) 2. Signing Official's Name*: Philip A. Francis, Jr. Title:BRP Superintendent * Signing Official must be in accordance with instructions in part VI on page 7. 3. Mailing address of applicant: 199 Hemphill Knob Road City: Asheville State: NC Zip: 28803 Telephone number: 8 2 8- 2 71- 4 7 7 9 x2 2 9 Fax number: 8 2 8- 2 71- 4 313 4. Property Owner's Name (if different from Applicant): same 5. Property Owner's mailing address: City: State: Zip: 6. Name and address of contact person who can answer questions about the proposed injection project: Name: Judd Mahan Title: Project Manager Company. Mountain Environmental Group Address: 1560 Pisgah Drive City: Canton State: NC Zip: 28716 Telephone number: 8 2 8- 6 4 8- 5 5 5 6 Fax number: 8 2 8- 6 4 8 -15 6 6 Email Address: jmahan@mountainenvironmental.com H. PERMIT INFORMATION: 1. Project is: ew ( Modification of existing permit ( Renewal of existing permit without modification ( Renewal of existing permit with modification 2. If this application is being submitted for renewal or modification to an existing permit, provide: existing permit number and the issuance date For renewal without modifications, fill out sections I & H only, sign the certification on the last page of this form, and obtain the property owner's signature to indicate consent (if the applicant is not the owner). For all renewals, submit a status report including monitoring results of all injection activities to date. Revised 6/09 UIC-51/5T Page 1 of 7 APPLICATION FOR PERNUT TO CONSTRUCT AND/OR USE A WELL(S) FOR INJECTION Type 51 Wells - In Situ Groundwater Remediation /Type 5T Wells - Tracer Injection M. INCIDENT & FACILITY DATA A. FACILITY INFORMATION 1. Facility name: Former Pisgah Inn Gas Station 2. Complete physical address of the facility: Mile Post 408, Blue Ridge Parkway City: Waynesville B. INCIDENT DESCRIPTION County: Haywood State: NC Zip: 2 8 7/1.6 1. Describe the source of the contamination: Contamination consists of gasoline -impacted soil and groundwater. The release was discovered during UST removal activities in November 2003. Four 3,000-gal USTs were removed. Approximately 36 cubic yds of impacted soil was removed. The UST excavation extended to -14 ft below ground surface. However, impacted soil extended deeper. Assessment data from the July 2009 CSA indicates gasoline -impacted soil in a smear zone that extends from 29 ft below ground surface to the approximate depth of bedrock at -41 ft. 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): Soil and groundwater at the site is impacted with gasoline. 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 0.5 feet (No If no, list maximum concentration of total VOCs observed at site: ppb 4. Agenc managing the contamination incident: ST Sectio ( Superfund Section (including REC Program and DSCA sites) ( DWQ Aquifer Protection Section ( Solid Waste Section ( Hazardous Waste Section ( Other: 5. Incident managers name Mike Streeter andphonenumber 828-296-4643 6. Incident number or other site number assigned by the agency managing the contamination incident: 28188 C. PERMITS List all permits or construction approvals that have been issued for the facility or incident, including those not directly related to the proposed injection operation: 1. Hazardous Waste Management program permits under RCRA: Not applicable 2. DWQ Non -Discharge orNPDES permits: n/a 3. County or DEH subsurface wastewater disposal permits: n/a 4. Other environmental permits required by state or federal law: n/a Revised 6/09 UIC-5I15T Page 2 of 7 MM APPLICATION FOR PERMIT TO CONSTRUCT AND/OR USE A WELL(S) FOR INJECTION Type 5I Wells —In Situ Groundwater Remediation / Type 5T Wells — Tracer Injection IV. INJECTION DATA A. INJECTION FLUID DATA I . List all proposed injectants. NOTE: Any substance to be injected as a tracer or to promote in situ remediation must be reviewed by the Occupational and Environmental Epidemiology Section (OEES) of the Division of Public Health, Department of Health and Human Services. Review the list of qpproved injectants or contact the UIC Program to determine if the injectants you are proposing have been reviewed by OEES. Injectant: Oxygen BioChem (OBC) to be mixed with water to create slurry. Concentration at point of injection: 2 0 % Percent if in a mixture with other injectants: Injectant: Concentration at point of injection: Percent if in a mixture with other injectants: Injectant: Concentration at point of injection: Percent if in a mixture with other iniectants: Concentration at point of injection: Percent if in a mixture with other injectants: 2. Source of fluids used to dilute or chase the injectants listed above: ( None ( Municipal water supply well or any well within '''A mile ( Air ( Other: 3. If any well within V4 mile of injection site, a private well, or surface water is to be used as the fluid source, supply the following information: DW-1 / DW-2 Together, these wells supply water a. Location/ID number of source: for the facility. b. Depth of source: DW -1 is 400 f t. DW - 2 is 100 f t. c. Formation: Ashe Metamorphic Suite d. Rock/Sedimenttype: fractured muscovite -biotite gneiss e. In Attachment C, provide a current, complete 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. NOTE. If contaminated groundwater is to be used as the dilution or chase fluid, this is not the proper permit application form. You must apply for a closed -loop groundwater remediation permit using application form GWRS. Revised 6/09 UIC-5I/5T Page 3 of 7 APPLICATION FOR PERMIT TO CONSTRUCT AND/OR USE A WELL(S) FOR INJECTION Type 5I Wells - In Situ Groundwater Remediation / Type 5T Wells - Tracer Injection B. PROPOSED OPERATING PARAMETERS -76 gallons of slurry to be injected into each of 10 1. Duration of Injection: temporary injection points. a. Maximum number of separate injection events: 1 b. Expected duration of each injection event2 days to complete injection for all 10 points. c. Expected duration between events (if more than one event): 2. Injection rate per well: 2-5 gallons per minute (gpm) 3. Total Injection volume: 76 per wel lgallons per day (gpd); gallons per event (if separate events) 4. Injection pressure: 5 to 20 pounds/square inch (psi) 5. Temperature at point of injection: 62 OF 6. Briefly describe how the above parameters will be measured and controlled: Slurry will be mixed in and pumped from a 200 gallon poly tank. A pneumatic diaphragm pump will be used to pump the slurry. A gauge on the injection tether monitors injection 7. Estimated hydraulic capacity of the well: 5 gpm pressure. Pressure is regulated at the air compressor. C. INJECTION WELL CONSTRUCTION DATA 1. Injection will be via: ( Existing well(s) proposed for use as an injection well. Provide the data in (2) through (6) below to the best of your knowledge. )Proposed well(s) to be constructed for use as an injection well. Provide the data in (2) through (6) below as proposed construction specifications. 2. Well Drilling Contractor's Name: Charles E . Ball NC Well Contractor Certification number: NCWC 4 0 2 5 - B 3. Date to be constructed: June 1 &2 Number of borings: 10 Approximate depth of each boring (feet): 32 &*`r�-Val 4. Screened interval/Injectio of injection wells: Depth: 3 0 to -3-2 feet below ground surface (if multiple intervals, indicate shallowest and deepest depth). 5. Well casing (N/A if injection is through direct push rods): Type: ( PVC ( Stainless steel( Other: Casing depth: to ft. 6. Grout (N/A if injection is through direct push rods): Type: ( Cement Grout depth: _ ( Bentonite ( Other: to ft. N/A - direct push N/A Revised 6/09 UIC-5I/5T Page 4 of 7 APPLICATION FOR PERMIT TO CONSTRUCT AND/OR USE A WELL(S) FOR INJECTION Type 5I Wells — In Situ Groundwater Remediation / Type 5T Wells — Tracer Injection V. ATTACHMENTS Provide the following items as separate attachments with the given headings: A. SITE HISTORY Provide a brief description of the site history including: (1) site usage historically and present, (2) origin of the contamination, (3) previous remedial action(s). NOTE. G.S. 89E-18 requires that any geologic plans, reports, or documents in which the performance is related to the public welfare or safeguarding of the environment be prepared by a licensed geologist or subordinate under their direction. G.S. 89E-13 requires that all drawings, reports, or documents involving geologic workprepared or approved by a licensed geologist, or a subordinate under their direction, be signed and sealed by the licensed geologist. B. HYDROGEOLOGIC DESCRIPTION Provide a hydrogeologic description, soils description, and cross section of the subsurface to a depth that includes the known or projected depth of contamination. The hydrogeologic description shall include: (1) the regional geologic setting; (2) significant changes in lithology; (3) the hydraulic conductivity, transmissivity, and specific yield of the aquifer to be used for injection, including a description of the test(s) used to determine these parameters; and (4) the depth to the mean seasonal high water table. C. INJECTION FLUID COMPOSITION Describe the chemical, physical, biological and radiological characteristics of each injectant. Attach the Material Safety Data Sheet (MSDS) for each injectant. If a private well. or a well within'/a mile of the injection site is used as the source well, include chemical analysis of source fluid here. D. INJECTION RATIONALE Attach a brief description of the rationale for selecting the injectants and concentrations proposed for injection, including: (1) goals of the injection project; (2) explanation and/or calculations of how the proposed injectant volume and concentration were determined; (3) a description of the reactions between the injectants and the contaminants present including specific breakdown products or intermediate compounds that may be formed by the injection; and (4) summary results of modeling or testing performed to investigate the injectant's potential or susceptibility to change (biological, chemical or physical) in the subsurface. E. INJECTION PROCEDURE AND EQUIPMENT Provide a detailed description of all planned activities related to the proposed injection including but not limited to: (1) construction plans and materials; (2) operation procedures; (3) a detailed diagram of the surface and subsurface portions of the system; and (4) a planned injection schedule. Revised 6/09 UIC-51/5T Page 5 of 7 APPLICATION FOR PERMIT TO CONSTRUCT AND/OR USE A WELL(S) FOR INJECTION Type 5I Wells —In Situ Groundwater Remediation / Type 5T Wells — Tracer Injection F. MONITORING PLAN Provide a plan for monitoring the results of the injection, including: (1) a list of existing and proposed monitoring wells to be used; (2) a list of monitoring parameters and analytical methods to be used; and (3) a schedule for sampling to monitor the proposed injection. NOTE. The selected monitoring wells must be located so as to detect any movement of injection fluids, process by- products, or formation fluids outside the injection area or zone. The monitoring parameters should include the target contaminants as well as secondary or intermediate contaminants which may result from the injection and other parameters which may serve to indicate the progress of the intended reactions, such as pH, ORP, dissolved oxygen, and other electron acceptors and donors. The monitoring schedule should be consistent with the pace of the anticipated reactions and rate of transport of the injectants and contaminants. G. WELL DATA Provide a tabulation of data on all existing or abandoned wells within 'A mile of the injection well(s) which penetrate the proposed injection zone, including, but not limited to, monitoring wells and wells proposed for use as injection wells. Such data shall include a description of each well's use (water supply, monitoring, etc), total depth, screened or open borehole depth interval, and well construction or abandonment record, if available. H. MAPS Attach the following scaled, site -specific maps: (1) Area map based on the most recent USGS 7.5' topographic map of the area, at a scale of 1:24,000 and showing the location of the proposed injection site. (2) Site map including: a. all property boundaries; b. all buildings within the property boundary; c. existing and proposed injection wells or well field(s) d. any existing sources of potential or known groundwater contamination, including waste storage, treatment or disposal systems within 1/4 mile of the injection well or well system; e. all surface water bodies within 1/4 mile of the injection well or well system; and f. _ all existing or abandoned wells within 'Amile of the injection well(s) which penetrate the proposed injection zone, including, but not limited to, monitoring wells and wells proposed for use as injection wells. (3) Potentiometric surface map(s) including: a. direction of groundwater movement b. existing and proposed monitoring wells c. existing and proposed injection wells (4) Contaminant plume map(s) including: a. the horizontal extent of the contaminant plume, including isoconcentration lines b. existing and proposed monitoring wells c. existing and proposed injection wells (5) Cross-section(s) to the known or projected depth of contamination, including: a. horizontal and vertical extent of the contaminant plume, including isoconcentration lines b. major changes in lithology c. existing and proposed monitoring wells d. existing and proposed injection wells Revised 6/09 UIC-5I/5T Page 6 of 7 APPLICATION FOR PERMIT TO CONSTRUCT AND/OR USE A WELL(S) FOR INJECTION Type 5I Wells — In Situ Groundwater Remediation / Type 5T Wells — Tracer Injection VI. CERTIFICATION (to be signed as required below or by that person's authorized agent) NCAC 15A 2C .0211(b) requires that all permit applications shall be signed as follows: 1. for a corporation: by a responsible corporate officer 2. for a partnership or sole proprietorship: by a general partner or the proprietor, 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. I hereby certify under penalty of law that I have personally examined and am familiar with the information submitted in this document and all attachments therein, and that, based on my inquiry of those individuals immediately responsible for obtaining said information, I believe that the information is true, accurate, and complete. I am aware that there are penalties, including the possibility of fines and imprisonment, for submitting false information. I agree to construct, operate, maintain, repair, and if applicable, abandon the injection well(s) and all related appurtenances in accordance with the approved specifications and conditions of the Permit. Printed N, Signature: VII. CONSENT OF PROPERTY OWNER (if the property is not owned by the applicant) ("Owner" means any person who holds the fee or other property rights in the well being constructed. A well is real property and its construction on land shall be deemed to vest ownership in the land owner, in the absence of contrary agreement in writing.) As owner of the property on which the injection well(s) are to be constructed and operated, I hereby consent to allow the applicant to construct each injection well as outlined in this application and agree that it shall be the responsibility of the applicant to ensure that the injection well(s) conform to the Well Construction Standards (Title 15A NCAC 2C .0200). Printed Name and Signature: Date: Submit TWO copies of the completed application package, including all attachments, to: RECEIVED I DFNR I DWQ P,QUIFFa PanTFr ?��N SFCT{ON. viAl 2 4 2010. Revised 6/09 UIC Program Aquifer Protection Section North Carolina DENR-DWQ 1636 Mail Service Center Raleigh, NC 27699-1636 Telephone (919) 733-3221 UIC-5I/5T RECEIVED / DENR i DWQ AQUIFFP PPnTFr'T!nN ,�FCTICN MAY 12 2010 Page 7 of 7 OUNTAIN Environmental Group environmental consulting • assessment • remediation • waste management Former Pisgah Inn Gas Station Sources for Attachments • Assessment data included in the attachments is taken from the following sources: o Comprehensive Site Assessment (CSA) submitted to NCDENR UST Section in Swannanoa, NC on March 26, 2009 o Corrective Action Plan (CAP) submitted to NCDENR on July 8, 2009 • Both the CSA and CAP were prepared by Altamont Environmental, Inc. in Asheville, NC. • Applicable text, tables and figures from the CSA and CAP are included herein to Section V of the UIC Permit Application. • Title pages with signature and professional stamp are included for the CAP and CSA. Complete copies of both the CSA and CAP are available upon request. • Subsequent to CAP approval, Mountain Environmental was contracted by the Blue Ridge Parkway to implement the CAP. 1560 Pisgah Drive Canton, NC 28716 www. mountai nenvironmental,com PHONE: (828) 648-5556 (800) 261-0031 FAX. (828) 648-1566 ... TACHMENT 3 -- CAP ENGINEERING & H YDROGEOL O G Y 231 HAYYlUUU SIREEI, ASNEVILLE, NC 28601 'tEL.828.281.3350 FAC.828.261.3351 W WW.ALTAPTONTENVIRONMEN'7AL.CO6} CORRCCTIv E ACTION _FLAN FORMER PISGAH INN GAS STATION BLUE RIDGE PARKWAY HA'YWOOI) COUNTY, NORTH CAROLINA GROUNDWATER INCIDEN'r No. 28188 Prepared f'Or Natlonal Pail: Sewice July 8, 2009 Prepared by !i.ltamont Environmental, hic. 231 I laywood Street. Asheville, North Carolina 28801 (828) 281-3350 r F. (iitben, P.C. I'rlije.ct F:n;inc�:.r i ttachment A - Site History ATTACHMENT 3 — CAP Corrective Action Plan July 8, 2009 Former Pisgah Inn Gas Station; Haywood County, Notch Carolina Altamont Envimumentai, Inc. 1.0 SITE. HISTORY AND CHARACTERIZATION On November 4, 2003, it was discovered while removing four 3,000-gallon underground storage tanks (USTs) at the former Pisgah. Inn Gas Station that an unknown quantity of gasoline had released into surrounding soils. The release may have resulted from spillage, overfilling, or leakage from the USTs or associated piping: The tanks were permanently closed by removal in November 2003. Approximately 440 gallons of gasoline product, sludge, and water were recovered from within the USTs. A total of 36 cubic yards of contaminated soil was removed and appropriately disposed of (Armstrong 2003). A summary of the former UST system, including information about the UST owner, is presented in Table_ 1. No present or former aboveground storage tanks (ASTs) have been identified at the site. No non -UST or AST releases are known to have occurred at the site. The former Pisgah Inn Gas Station is located within rugged mountain terrain on the Pisgah Ridge in the Blue Ridge Mountains along the Blue Ridge Parkway in Haywood County, North Carolina (Figure 1). The former Pisgah lnn Gas Station is now a gift shop which is part of the Pisgah Inn complex. As indicated in Figure 2, this includes an inn, a restaurant, a campground, and various hiking trails_ The land surrounding the former USTs is within the Pisgah National Forest, and exhibits high topographic relic£ It is used primarily for recreational purposes (Figure 3). No residential communities are located within two miles of the site. Several assessment and corrective action activities have been performed to date at the site, as follows: • UST Closure —Field work, performed in November 2003, included removing four 3,000-gallon USN collecting soil samples (PI -I, PI-2, PL-1 through PL 3, TP_ 1 through TP-14, and SW-1 through SW-5), and excavating and disposing of approximately 36 cubic yards of impacted soil off -site. The associated UST Closure Report was submitted in December 2003 to the UST Section of DENR (Armstrong 2003). • Limited Site Assessment (LSA). Phase I —Field work, performed in spring 2004, included performing a water -well survey, installing one monitoring well (MW-1), collecting groundwater samples from the identified water supply wells (DW-1 and DW 2) and the monitoring well MW- 1, and collecting soil samples from six soil probe holes (SP-1 through SP-6). The monitoring well MW-1 is a flush mount well and screened within the soil overlying the bedrock. The bottom of the well (total depth of 40.5 feet below ground surface [bgs]) is at the top of the bedrock. • Limited Site Assessment (LSA). Phase II —Field work, performed in June 2004, included installing five additional monitoring wells (MW-2 through MW-6) and collecting associated Pifte Ridge ParkwayWr Pisgah 1nnMq orts\CAPtRepnrt ContentsiCAP doc Corrective Action Plan Former Pisgah Inn Gas Station; Haywood County, North Carolina ATTACHMENT 3 -- CAP July 8, 2009 Altamont Environmental, Inc. groundwater samples. All of these monitoring wells are flush mount. Monitoring wells MW-3 and MW-4 are screened within the soil overlying the bedrock; monitoring wells MW 2, MW-5, and MW-6 are set within the bedrock (Figures 4 through 6 and Table 2). The boring logs for these wells are presented in the Limited Site Assessment report (including both Phase I and H work) that was submitted to the LIST Section of DENR in summer 2004 (Armstrong 2004). Groundwater Montt M97-Field work included periodically collecting groundwater samples from the two water -supply wells (DW-1 and DW 2) and selected monitoring wells (MW11, MW-5, and MW-6). No groundwater samples were collected from MW-1 during these monitoring activities because of the continued presence of free product in the well. This monitoring was conducted monthly from October 2005 through September 2006 and quarterly from December 2006 through September 2007. Altamont documented these results in periodic reports (the most recent of which is Altamont September 25, 2007). • CSA—Field work, performed in summer 2008, included collecting eight soil samples (TP-12, SMW-1, SP-1, SP-4, SB-2, S114, SB-6, and SB-8) as well as collecting groundwater samples from four of the six existing monitoring wells (MW 2 through MW-4, and MW-6) and the two water supply wells (DW-1 and DW 2; Altamont 2009). • Free Product Removal —Field work included the installation of a submersible pump in MW-1 in summer 2008 and operation and maintenance of the system which is ongoing. During the Phase I LSA, in April 2004, Armstrong Environmental conducted a receptor survey of the surrounding area within 1,500 feet of the site Two water supply wells (DW-1 and DW-2) were identified northwest (downgradient) of the former UST& These wells provide water for the Pisgah Inn and the adjacent Mount Pisgah Campground. Figure 3 indicates the location of the water supply wells. The water supply wells draw groundwater from the fractured bedrock; according to National Park Service personnel the total depths of DW-I and DW 2 are 400 feet bgs and 200 to 300 feet bgs, respectively. To the best of our knowledge, Pisgah Inn utilizes no municipal water supply systems. According to the North Carolina Source Water Assessment Program (SWAP), DWI and DW-2 are considered part of a Non -Transient Non -Community System, which is defined as a public water system that is not a community system and regularly serves at. least 2S of the same persons six or more months o per year. The site is not located within a Wellhead Protection Area and there are no other known water wells within 1,500 feet of the source area. A springhead of an unnamed stream is located appmxirnately 475 feet west of the campground area and downgtadient of the source area. The unnamed tributary drains into _Pisgah Creek, which flows PMfue Ridge Par&way\Mt Pisgah Irm\RVa rtACAP qcd troutents\CAP.doe ATTACHMENT 3 — CAP Corrective Action Plan July 8, 2009 Former Pisgah. Inn Gas Station; Haywood County, North Carolina Altamont Environmental, Inc. northwesterly into the East Fork of the Pigeon River. According to the DENR, Division of Water Quality, Pisgah Creek is a WS-III Class C stream and is part of the French Broad River Basin. The National Wetland Inventory (NWI) shows that a fieshwater forested shrub wetland lies in the central part of the Pisgah Inn campground area. The approximate outline of this wetland area is shown on Figure 3. The Pisgah inn and Mount Pisgah Campground are recreation facilities for visitors traveling in the area. The surrounding terrain is part of the Pisgah National Forest No residential communities are located within two mites of the site. PAW= Ridge Parkway\Mt Pisgah InnU?epard\CAP Repazt Cmuents@CAPAac NOTE: WATER TABLE ELEVATIONS WERE MEASURED ON AUGUST 12, 2008 BMW--5 LEGEND FIGURE . MONITORING WELL POTENTIOMETRIC ( SURFACE MAP E NofneeniHbQ�H YDROD[Ol.OpJY�W.I QO CSA SOIL BORING 701 NAYWDOD GTARCY, APMRVILLL, NC 20001 AUGUST 2008 Te L.6211.241,33ED FAc.M2N Pal 3351 A -A' CROSS SECTION LOCATIONS WWW.AVFANPNYNNYIPONMPNTAU.CQM FORMER PISGAH INN GAS STATION 4 DRAWN BY: ANNA SAYLOR SCALE (FEET) MILE POST 408 BLUE RIDGE PARKWAY a870—POTENTIOMETRICSURFACE PROJECT MANAGER: CHRIS GILBERT HAYWOOD COUNTY, NORTH CAROLINA CONTOURS (5-FOOT INTERVALS) CLIENT: NPS 30 o so ao DATE: 06/29/2009 P \nlW.. PQQE PAPXNAY\MT M161H HN\FIQWFA\FjCIPt L-POTtNTiQM1RIC "FACE MAF-AtMT 12, N04,VN4 O AM -6 (4,873,637) ®MW-4 (4, 883. 6, NOTE: WATER TABLE ELEVATIONS WERE MEASURED ON JANUARY 8, 2009 LEGEND A MONITORING WELL ® CSA SOIL BORING CROSS SECTION LOCATIONS 4990-POTENTIOMETRIC SURFACE CONTOURS (5-FOOT INTERVAL MW-5 (4,683.37) V-2 ,91T72) POTENTIOMETRIC FIGURE -% SURFACE MAP L - I NOIN[[R1 aO__&, i"I vDRO0EOLOOv --_) �231 HA.WCOP STAR.,, AgwrMLI. NC RGB01 JANUARY 2009 .cL.Ito'211.3350 Pia 024,201.33a, W.1.61'.0.15R9O1•».■.TAL.••M FORMER PISGAH INN GAS STATION 5 DRAWN BY: ANNA SAYLOR MILE POST 408 BLUE RIDGE PARKWAY PROJECT MANAGER: CHRIS GILBERT SCALE (FEET) HAYWOOD COUNTY, NORTH CAROLINA CLIENT: NPS ao a ao ao DATE: 06/29/2009 P \M 1! R-1 PAM-WMT PIS4 N Q AP O-P4MM 1ROMK S Xf![[ 1AP-4.\M - E, NO FM4 WEST EAST A Al EXTENT OF XCAVATION 4930 BLUE IN 2003 4930 RIDGE MW-I SB-2 IDG SB-8 (SMW-1) TP-12 SP-2TP-2 TP-3 MW-2 aw i 1 4920 4920 SB- 1 / Q NB ND 4910 l� 4910 r SM S w ND IND 4900 ND / 4900 MW-4 �SZ SILTY CLAYS TO SANDY SILTS ND ND APPROXIMATE EXTENT OF 4890 Np ---------CURRENT ROIL/GROUNDWATER 4890 ND / 3E * CONTAMINATION Q ONLY OF 4880 SOIL DETECTED IMPACTED IN 4680 /f .;��APPROXIMATE TOP OF BEDROCK (SEE TABLE 4 AND PETROLEUM -RELATED FIGURE 5) CONTAMINATION IS INTERPRETED TO BE G4570 4870 / ' NEISSIC BEDROCK BEDROCKNEARMW OIE "- IN GROUNDWATER Alm SMEAR ZONE LEGEND 13 I® CONCEPTUAL SITE MODEL FIGURE Lwow-wa �,7ennr...-Ixoeo ----E -,,ni a- I�i-i; 1131 •tM 10, MI1NM .,,.,„„�„». NOTES: - -- - -- - ""` CROSS SECTION A -A' +lM,F 1--v a1WrMp,1 �.wx«rv-Mrv,rw af" non-, a Nl ,��9r MVrp ww. sau„,w, �'„�'„r.,,,""-,"..�"��"�'����' " " "" "" FORMER PISGAH INN GAS STATION unin,on a. ,u n.n+w-r..Ixa.r w,,w-wn rw.-a.-n "U M"wvq I" Fwr"o-M, Af1-N, _,""."uiuw"" Q•rr.n.,.�-.. w 6 DRAWN T : AWA SA LORIO GIuaRT SCALE FACTOR MILE POST 408 BLUE RIDGE PARKWAY HAYWOOD COUNTY, NORTH CAROLINA CLIENT; NFR V: I ,N- 10 PT WIN - 20 ,i REV. DATP DeaCRIPTM NY CMl Aw PnRUR Re„ PArM.Y1N/ NMw MA TSNWTWX a ATTACHMENT 4 - CSA 50 COLLEGE !:,'r1?ECT, ASHEVILLE . 0C 28001 TEL. 828.2 Bt.:3350 F4c 6%G,2'f3!,-335t WWW. A L,rAht() NTENV I RON ME t(TAL, C GF-1 COMPREHENSIVE SITEA ABBEY SSINIENT FOR1 IER PISGAti ININ GAS STATION BLUE RIDGE PARTMAY HAYWOOD COUNTY, NORTH CAROLINA GROUNDWATE, R JN-C-11DE, NT No. 28188 Prepared for National Park Servic.e. March 26, 2009 Prepared by Altainont Environmental, Inc. 50 College Street Asheville, NC 2880.1 (828) 281-3350 r] 16j, F. Gilbert P.E. Prqject Engineer- A Attache ft B - Hydrogeologic Description (includes figures from July 2009 CAP) ATTACHMENT 4 -CSA Comprehensive Site Assessment March 26, 2009 Pisgah Inn Gas Station; Haywood County, North Carolina Aitamont Environmental, Inc. 4.0 GEOLOGY AND HYDROGEOLOGY 4.1 GEOLOGY According to the statewide geologic map ofNorth Carolina, dated 1985, the site is located within the Eastern Blue Ridge Belt physiographic province (Department of Natural Resources and Community Development, 1985). The site lies within metamorphosed rocks of the Ashe Metamorphic Suite. Rock types in the area of the site include muscovite-biotite gneiss that is intedayered and gradational with mica schist, minor amphibolite, and hornblende gneiss. The site is located along a major ridge and is covered with a relatively thin veneer of soils. Measured depths to bedrock at the site (based on soil boring refusal depths during the CSA and monitoring -well drilling during the LSA) range from I 1 to 42 feet bgs (Figure 4 and Appendix Q. The soils that were encountered during the UST removal consisted of fill material (sandy silts and well - sorted gravel). Native unsaturated material located below the former tank pit approximately 12 feet bgs are described as light -tan silty sand with cobbles and boulders (Armstrong 2003). Based on the data collected during the LSA and the boring logs from this CSA, the soils overlying the bedrock are predominantly micaceous silty clays and sandy silts. Silty sand soils are also present locally (Figure 4 and Appendix Q. The underlying bedrock:. at the site consists of micaceous schist (Armstrong, 2004). To date, no investigations associated with the release at the former UST system have evaluated the density and orientation of the fractures within the bedrock. 4.2 HYDRoGEOLOGY Based on the topography of the site and water -level measurements obtained during site investigations, groundwater appears to flow across the site from east to west (Figures 5 and 6). The highest water -level elevations are located to the east of the former UST system and the lowest elevations occur in the a o campground, west of the Blue Ridge Parkway. Depths to groundwater measured in the summer of 2008 (August 12, 2008), as part of the CSA, ranged from 14.79 feet below the monitoring well top of casing (TOC) in MW-2 to 38.73 feet below TOC in P:tBtue Ridge ParkwayEMt Pisgah hnARep rtsCCSAtCSA.docx . ATTACHMENT 4 - CSA Comprehensive Site Assessment March 26, 2009 Pisgah Inn Gas Station; Haywood County, North Carolina Ahamont Environmental, Inc. MW-3 (Table 3). Historical depths to groundwater have varied greatly. From December 2006 through August 2008, the depth to the groundwater fluctuated up to I I feet (Table 4) in the monitoring wells. The region experienced exceptional drought conditions during the spring and summer 2008, and this is reflected in the groundwater elevation data. Recent water -level measurements in January 2009 showed water levels at more normal depths. Depths to groundwater measured in the winter 2009 (January 8, 2009) ranged from 8.67 feet below the top of casing (TOC) in monitoring well MW-2 to 27.68 feet below TOC in monitoring well MW-3 (Table 3). The water table or surficial aquifer commonly occurs in the unconsolidated overburden above the bedrock. During the summer of 2008, the water table was measured,just above the top of bedrock or actually within the bedrock (Figure 4). Hydraulic connectivity between the overburden and the bedrock has not been demonstrated on a site -specific basis. However, generally in the Blue Ridge Province of Western North Carolina, groundwater hydraulic connectivity between the overburden and the underlying bedrock does exist. At a location near the top of a ridge, such as the site, commonly the groundwater moves downward from the overburden into the fractures within the bedrock (LeGrand, 2004). F-Mue Ridge ParLwayWt Pisgah hWXRepaMICSAtCSA dacx 6 Groundwater Analytical Summary for Table 7 ATTACHMENT 4 - CSA Water Supply Well DW-1 Historic Groundwater Sample Analytical Results Former Pisgah Inn Gas Station Milepost 408 Slue Ridge Parkway Haywood County, North Carolina Sample Collection Date Phase of Work Metals VPH Organic Compounds Volatile Organic Compounds (VOCs) Lead AWL Aliphatic (C05-008) µg/L Aliphatic (C09-C12) Aromatic (C09-CI0) Benzene 991L Toluene µg/L Xylenes (Total) µg/L 7/152004 LSA <5.0 NA NA NA <0.50 <1.0 <1.0 8/6/2004 LSA <5.0 NA NA NA <0.50 <0.50 <1.0 10/12/2005 Monitoring 12 <100 <100 <100 <1.0 <1.0 <1.0 11/17/2005 Monitoring <5.0 <100 <100 <100 <1.0 <1.0 <1.0 12/29/2005 Monitoring <5.0 <100 <100 <100 <1.0 <1.0 <1.0 1/13/2006 Monitoring 63 <74 <68 _ <72 <1.0 <1.0 <1.0 2/15/2006 Monitoring <5.0 <100 <100 <100 <1.0 <1.0 <1.0 3/7/2006 Monitoring 8.2 <100 <100 <100 <1.0 <1.0 <1.0 4/72006 Monitoring <5.0 <100 <100 <100 <1.0 <1.0 <1.0 DW-1 5/42006 Monitoring <5.0 <100 <100 <100 <1.0 <1.0 <1.0 6/82006 Monitoring <5.0 <100 <100 <100 <1.0 <1.0 <1.0 7/62006 Monitoring <5.0 <100 <100 <100 <1.0 <1.0 <1.0 8/112006 Monitoring NS NS NS NS NS NS NS 9/72006 Monitoring NS NS NS NS NS NS NS 12/202006 Monitoring NS NS _ _ NS NS NS NS NS 3/82007 Monitoring NS NS NS NS NS NS NS 6/1/2007 Monitoring <5.0 <100 <100 <1.0 <1.0 <2.0 9/52007 Monitoring NS _ NS _ _<100 NS NS NS NS NS 8/11/2008 CSA NA <100 <100 <100 <0.50 <0.50 <1.5 NC 21, Standard 15 420 4,200 210 1 1,000 530 GCLe 15,000 NL NL NL 5,000 257,500 1 87.500 P:1Blue Ridge ParkwaylMt Pisgah lm\ReponikCSA\AnalAceRtbl-Groundwater Analytical Results Page 4 of 5 Table 7 ATTACHMENT 4 - CSA Groundwater Analytical Summary Historic Groundwater Sample Analytical Results for Water Supply Well DW-2 Former Pisgah Inn Gas Station Milepost 408 Blue Ridge Parkway Haywood County, North Carolina Sample Collection Date Phase of Work Metals VPH Organic Compounds Volatile Organic Compounds (VOCs) Lead µg/L Aliphatic (C05-008) WL Aliphatic (C09-C12) Ag/L Aromatic (C09-C10) N1/L Benzene !9/L Toluene µg/L Xylenes (Total) µg/L 8/6/2004 LSA <5.0 NA NA _ NA <0.50 <0.50 <1.0 10/12/2005 Monitoring <5.0 <100 <I00 <100 <1.0 <1.0 <1.0 11/17/2005 Monitoring <5.0 <100 <100 <100 <1.0 <I.0 <1.0 12/29/2005 Monitoring <5.0 <100 <100 <100 <1.0 <1.0 <1.0. 1/13/2006 Monitoring <5.0 <74 <68 <72 <1.0 <1.0 <1.0 2/15/2006 Monitoring <5.0 <100 <100 <100 <1.0 <1.0 <1.0 3n12006 Monitoring <5.0 <100 <100 <100 <1.0 <1.0 <1.0 4nt2006 Monitoring <5.0 <100 <100 <100 <1.0 <1.0 <1.0 5/4/2006 Monitoring <5.0 <100 <100 <100 <I.0 <1.0 <1.0 DW-2 6/8/2006 Monitoring <5.0 <100 __<100 <100 <I.0 <1.0 <1.0 7/6/2006 Monitoring <5.0 <100 <100 <100 <I.0 <1.0 <1.0 8/11/2006 Monitoring <5.0 <100 <100 <100 <1.0 <1.0 <I.0 9/7/2006 Monitoring <5.0 <100 <100 <100 <1.0 <1.0 <3.0 1220/2006 Monitoring <5.0 <I00 <100 <100 <1.0 <1.0 <3.0 3/8/2007 Monitoring 13 <100 <100 <100 <1.0 <1.0 <2.0 6/1/2007 Monitoring <5.0 <100 <100 _ <100 <1.0 <1.0 4.0 9/52007 Monitoring <5.0 <100 <100 <100 <1.0 <1.0 <2.0 8/11/2008 CSA NA <100 . <100 <100 <0.50 <0.50 <1.5 NC 2L Standard 15 1 420 4,200 210 1 1,000 530 GCLs 15,000 1 NL NL NL 1 5,000 1 257,500 1 87,500 Notes: 1. This table represents detected compounds only. For complete analyses and detection limits see the respective laboratory analytical reports included within the Altamont and Armstrong documents included in List of Refemces. 2. NC 2L Standard from "North Carolina Administrative Code. Title 15A: Department of Environment, Health, and Natural Resources, Subchapter 2L - Groundwater Classifications and Standards," NC DENR, April 2005. 3. Aliphatic (C09-C12) and Aromatic (C09-C10) hydrocarbon ranges are fractions within the Standard Ranges ofAliphatics C9-C18 and Aromatics C9-C22 listed in the NC 2L Standard. This and related information is presented on Figure I7 "Worksheet for Analyzing MADEP Groundwater Sample Results," in "Guidelines for Assessment and Corrective Action, North Carolina Underground Storage Tank Section," April X01, Change 1. 4. µg/L, is micrograms per liter. NS indicates there was No Sample collected. NA indicates Not Analyzed. 5. Bold numbers indicate an exceedance of the NC 2L Standard. 6. GCLs-Gross Contamination Levels taken from "Guidelines for Assessment and Corrective Action for UST Release" dated July 15, 2008. P_\Blue Ridge Parkway\Mt Pisgah Jnn\Reports\CSAlAnalyticalltbl-CmoundwaterAnalytical Results Page 5 of 5 Attachment D - Injection Rationale (from the July 2009 CAP) ATTACHMENT 3 -- CAP Corrective Action Plan July 8, 2009 Former Pisgah Inn Gas Station; Haywood County, North Carolina Altamont Environmental, Inc. 5.0 PROPOSED CORRECTIVE ACTION 5.1 RECOMMENDED ALTERNATIVF To address the identified aquifer contamination at the former Pisgah Inn Gas Station, Altamont reconunends continued pumping of the free product in MW-I and in situ aerobic bioremediation. No action is recommended for the soil, because the impacted soils are part of the groundwater smear zone and under the water table (saturated) much of the year. The rationale for these recommended corrective action alternatives is supported by the following statements: • Currently, neither the impacted soil nor groundwater pose a risk of direct exposure to potential human receptors (guests, visitors, and employees of the Pisgah Inn and adjacent campground). This is based on the uppermost zone of impacted soil being approximately 29 feet bgs and the drinking water wells that supply potable water to the Pisgah Inn showing no contamination. • The source of the impacted groundwater is being reduced by the free product removal. • The volume of impacted groundwater is too small to warrant a highly invasive and capital - intensive remedial action. Also the site is used by a high volume of recreators who visit the area near MW-1 (the campground gift store) for a short period of time (up to one hour). The visitors are attracted to Pisgah Inn and the surroundings because of the aesthetic quality of the area. Therefore, installation of aboveground treatment structures (for example, for air sparging and SVE) should be avoided if possible. • Three monitoring wells (MW-04 through MW-06) are strategically located downgradient of the zone of impacted soil and groundwater and upgradient of the drinking water wells. Therefore, they may be used as sentry monitoring wells to indicate whether contamination in the groundwater is migrating toward the drinking water wells. If contamination is identified, then a point source treatment system can be installed and the water quality rigorously monitored to attain drinking water standards. The following provides a description of the free product removal and in situ aerobic bioremediation for the impacted aquifer. 5.2 FREE PRODUCT REMOVAL On August 27, 2008, a pneumatic recovery system was installed in MW-Ito remove free product from the monitoring well. This system operated throughout the fall of 2008, was shut down in late fall 2008, and resumed operating in middle June, 2009. It continues to operate and is scheduled to operate until late November, 2009 when it will be shut down for the winter, then resume operation in the warmer weather. P:'Blue Ridge Parkway\Mt Pisgah Inn\Reports\CAP\Report Contents\CAP.doc 14 ATTACHMENT 3 -- CAP Corrective Action Plan July 8, 2009 Former Pisgah Inn Gas Station; Haywood County, North Carolina Altamont Environmental, Inc. The system includes a submersible pump, a solar -powered controller, a 55-gallon storage drum with an overflow -prevention float switch, a secondary -containment platform, and a compressed -gas canister with a regulator. The recovery system is designed to operate on an intermittent basis. The pump runs for several minutes and pulls the water level down approximately two feet. The pump then remains off for several hours while the water level in the well recovers toward its static level. During these idle periods (periods during which the pump is not operating) free product coalesces in the well. When the pump operates, a mixture of free product and groundwater is removed from the well and stored in the drum for periodic removal and disposal. As of June 18, 2009, approximately 18 gallons of free product and water had been removed from the monitoring well. Altamont is visiting the site on a weekly basis to monitor the system, document how much free product and water have been removed from the well, and to properly dispose of the material as needed. f„�,.,W§«*�sr�,e*-.w,..sw,..c�.,a�r�t,,.:�„„x,+��+,-..�.....:,...r,.c.�.,.x.�..,.,: w,•r :.,,w �+u .y.-.���.;,�, ;•.. 5.3 IN SITU AEROBIC BIOREMEDIATION The corrective action alternative to address the petroleum -impacted zone of the aquifer, anticipated to be a 25-square-foot area immediately downgradient of MW-1 and to be approximately 13 feet thick, is in situ aerobic bioremediation. This bioremediation will be accomplished with an aerobic biostimulant (for example, StimuloxTM manufactured by Carus Chemical Corporation, EHC-00 by Adventus, or equivalent) designed to affect petroleum -related constituents within the impacted aquifer. The additive should significantly stimulate the catabolic activity of the indigenous microflora, thereby accelerating the rate of contaminant removal. The additive will be delivered to the site as a dry powder in drums or 5- gallon pails and mixed with water to create a slurry. The additive and water slurry will be created by mixing the additive with an appropriate amount of water, and injecting the slurry into the subsurface through direct -push technology (DPT) rods, such as GeoProbeTM rods. Given treatment dimensions of 25 feet by 25 feet by 13 feet thick, the estimated treatment volume is 8,125 cubic feet. Altamont requested a proposal and specifications from Adventus, a remediation technology company, for the injection of EHC-Oa', one of their accelerated aerobic bioremediation technology additives designed to address petroleum -impacted groundwater. These specifications, summarized below, are based on applicable analytical and hydrogeological data pertaining to the site. No pilot or bench scale test has been accomplished at the site, and Altamont feels one is not warranted PABlue Ridge Parkway\Mt Pisgah Inn\Reports\CAP\Report Contents\CAP.doc 15 ATTACHMENT 3 -- CAP Corrective Action Plan July 8, 2009 Former Pisgah Inn Gas Station; Haywood County, North Carolina Altamont Environmental, Inc. because of the small volume of the impacted aquifer. The following specifications were provided by Adventus: • EHC-O* application rate (concentration in slurry) is 20% • Total mass of EHC-000 required is 1,500 pounds (Ibs) • Total volume of water required is 710 gallons • Approximate volume of slurry to inject is 890 gallons Ptictt► tmp�etniing t�fvlwtng iujectit groccctts, n>(k ill be :. performed at the site. This sampling event will mimic the post -implementation groundwater monitoring events, described below. The slurry will be pressure -injected into ten injection points spaced approximately eight feet apart. The approximate locations of these injection points are shown on Figure 6. Approximately 150 pounds (Ibs) of EHC-00 and 90 gallons of slurry will be injected at each injection point. The injection points will be the stainless steel rods with an expendable point of an appropriate DPT rig. The bottom of the rods will be in the upper part of the impacted groundwater zone, approximately 12 feet bgs. If excessive back pressure builds up during injection, then the slurry mixture will be thinned to decrease the viscosity of the slurry. This will increase the volume of slurry injected into the subsurface. Upon completion of the slurry injection and withdrawal of the DPT rods, the borehole will be abandoned as appropriate, for instance using a bentonite hole plug. Cement grout should be avoided because it is possible that it would be displaced by subsequent injection of the slurry at nearby points. We anticipate one injection event. The groundwater quality will then be monitored to evaluate the effectiveness of the corrective alternative and to monitor natural attenuation processes. Groundwater samples will be collected from four monitoring wells, MW-1, MW-04, MW-05, and MW-06 approximately x ' " ' ' and quarterly thereafter for the first year. •t " Each groundwater sample will be submitted to an analytical laboratory certified in the State of North Carolina for analyses of volatile organic compounds (VOCs) using US Environmental Protection Agency (EPA) Method 8260, Massachusetts Department of Environmental Protection (MADEP) volatile petroleum hydrocarbons (VPH), and MADEP extractable petroleum hydrocarbons (EPH). Additionally, each of the monitoring well samples will be analyzed for the following parameters to evaluate the occurrence and mechanisms of natural attenuation of the PABIue Ridge Parkway\Mt Pisgah Inn\Reports\CAP\Report Contents\CAP.doc 16 Corrective Action Plan Former Pisgah Inn Gas Station; Haywood County, North Carolina petroleum compounds: • Nitrate, nitrite, and nitrogen using EPA Methods 351.2 and 353.2 • Total dissolved iron using EPA Method 6010 • Sulfate using EPA Method 375.4 • Methane, ethane, and ethene using RSKerr • Carbon dioxide using AM20G8X • Chloride using SM 4500 CIE • My nganese using EPA Method 3010/200 In addition the following parameters will be measured in the field: • Dissolved oxygen • Ferrous iron • Oxidation reduction potential (ORP) • Alkalinity • pH • Temperature • Turbidity • Specific conductivity ATTACHMENT 3 -- CAP July 8, 2009 Altamont Environmental, Inc. All field measurements will be based on proper calibrations of the instruments, as required by their manufacturers. 'Quarterly reports summarizingAe results of the groundwater monitoring will be submitted to the DENR for the first year. Semiannually reports will be submitted thereafter. This report will include tables summarizing the laboratory results as well the laboratory reports themselves. The initial report will include a detailed description of the in situ aerobic bioremediation injection process. All subsequent monitoring reports will include an evaluation on the injection effectiveness, including any insight on natural attenuation processes that may be occurring in the groundwater. PABlue Ridge Parkway\Mt Pisgah Inn\Reports\CAP\Report Contents\CAP.doc 17 REDOX TECH, LLC . "Providing Innovative In Situ Soil and Groundwater Treatment" April 29, 2010 Via email Judd Mahan, P.G.. Mountain Environmental Group 1560 Pisgah Drive Canton, NC 28716 828-648-5556- imahan@mountainenvironmental.com The July 2009 CAP suggested the injectant EHC-O by Adventus or a comparable product. This proposal details the specificaitons for the comparable product OBC by Redox Tech. RE: Former Pisgah Inn Gas Station Mile Post 408 Blue Ridge Parkway, Haywood County, North Carolina Dear Judd Mahan: Redox Tech is pleased to provide the following cost estimate to provide OBC® to help remediate the petroleum contaminated site in Haywood County, North Carolina. We propose using injections of our OB& product in the contaminated area. The mixture in Oxygen BioChemo (OBC) supports a two -fold mechanism for destroying the contaminants of concern, delivering one of the strongest chemical oxidants for short term ISCO (sulfate radicals from catalyzed persulfate), as well as delivering electron acceptors (oxygen and sulfate) for longer -term biological oxidation. OBC employs a mixture of calcium peroxide and sodium persulfate that provides significantly more oxygen per pound than other calcium peroxide based products. OBC is also generally less expensive than these products. OBC provides three modes of oxidation. The first is aggressive chemical oxidation from activated persulfate and calcium peroxide, the second is enhanced aerobic biodegradation from the long term oxygen release of calcium peroxide, and the third is anaerobic biological oxidation as sulfate is used as an electron acceptor. These three modes of oxidation provide a powerful and persistent treatment of contaminated soil and groundwater. Information on OBC can be found on our website www.redox-tech.com. We assumed that the treatment area is approximately 625 square feet and 13 feet thick. We assumed that injections of OBC would be performed through Geoprobe rods at multiple depths. We assumed a total of approximately 760 gallons of OBC solution (1500 lbs of OBC or approximately 2 lbs OBC per gallon) will be injected in a total of 8 Geoprobe injection locations. To develop our costs we assumed that the total oxidant demand (TOD) of the soil at the site was approximately 2 g/kg. Total oxidant demand testing on soil samples will provide a better estimate of the TOD and is recommended to determine the mass of oxidant required. Typical injections of OBC through Geoprobe rods are conducted at injection pressures between 20 psi and 200 psi and at flow rates between 1 and 20 gpm. We assumed others 200 QUADE DRIVE, CARY, NC 27513 TEL 919.678.0140 FAX 919.678.0150 WWW.REDOX-TECH.COM E-MAIL: ROSSABI@REDOX-TECH.COM 4/29/2010 Mountain Environmental Group Waynesville, NC Page 2 of 2 would complete the injection and Redox Tech will supply 1500 lbs of OBC. The price for OBC is $3 per pound plus shipping and tax. We assumed that delivery to your office in Canton, NC will cost $200 and NC tax is 7.75%. The total cost for this proposal is $5,064. The MSDS for OBC is attached. Thank you for the opportunity to provide you with this estimate. We are looking forward to hearing back from you. If you have any questions or concerns, please do not hesitate to call me at 919-678-0140. Regards, Joe Rossabi, Ph.D., P.E. Redox Tech, LLC Providing Innovative Soil and Water Solutions Oxygen BioChem (OBCym Recent applications of in situ chemical oxidation (ISCO) have shown that ISCO can be a cost-effective remedial strategy for organic contaminants in groundwater and soil. The application of ISCO to contaminated source areas usually results in an immediate benefit to groundwater in the area. In addition, further contaminant flux can be reduced or eliminated mitigating further contaminant plume issues. Redox Tech has recently formulated a mixture of sodium persulfate and calcium peroxide that can be employed for ISCO applications using FMC's patent -pending KlozurTm activation chemistry. The mixture in OBC supports a two -fold mechanism for treating contaminants of concern. OBC delivers one of the strongest chemical oxidants for short term ISCO, and also provides electron acceptors (oxygen and sulfate) for longer -term biological oxidation. Sodium persulfate has emerged recently as an important oxidant for in situ remediation of volatile and semi -volatile organic compounds. Persulfate is the strongest oxidant within the peroxygen family, with an electromotive force of 2.12 volts. As illustrated below, the direct oxidation half -cell reaction for persulfate involves a two -electron transfer: 2 S2082- + 2 H++ 2e -> 2HSO4 However in most cases, rapid destruction of the contaminant of concern requires that the persulfate be activated in order to generate sulfate radicals. Sulfate radicals are powerful oxidizing agents, with an oxidation potential of 2.6 volts. Klozur activated persulfate is catalyzed with the peroxide and base provide by the calcium peroxide S2082-+ calcium peroxide activator -* 2SO4' Activated persulfate can remain available in the subsurface for months providing an unrivaled combination of power and stability. The calcium peroxide provides several benefits. First, it imparts the alkalinity and peroxide needed to activate the persulfate using FMC's Klozufrm activation chemistry. Second, when mixed with water it provides a long-term slow release source of hydrogen peroxide and calcium hydroxide. CaO2 + 2 H2O 4 Ca(OH)2 + H2O2 The hydrogen peroxide that is slowly formed decomposes to oxygen and water, providing an extended oxygen source for subsequent bioremediation of petroleum hydrocarbons. The resultant calcium hydroxide (hydrated lime) that is produced serves several purposes. First of all, it increases the total dissolved ion concentration, which makes the solution less likely to leach metals from the soil into the groundwater. Secondly, the calcium from the 200 QUADE DRIVE, CARY NC 27513 TEL 919.678.0140 FAX 919.678.0150 WWW.REDOX-TECH.COM E-MAIL: HASELOW@REDOX-TECH.COM Providing Innovative Soil and Water Solutions hydrated lime will precipitate the sulfate that is produced during the consumption of the persulfate. The calcium sulfate (gypsum) precipitation helps to reduce sulfate groundwater concentrations, which may impact the secondary drinking water standard of 250 ppm. The mixture in OBC® provides chemical oxidation as well as electron acceptors (oxygen and sulfate) for longer term biological oxidation. The predominant short-term reaction is chemical oxidation, while the longer -term remediation process is biological oxidation. OBC® has the advantages over more traditional oxygen compounds used for bioremediation in that is works on a broader range of contaminants. Table 1. Contaminants Treated by Oxygen BioChem (OBC)® CONTAMNANTS TREATED BTEX 1,4-dioxane MTBE PCBs PAHs Pentachloro henol Chlorinated Alkenes Chlorinated Alkanes Table 2 summarizes the advantages of OBCO over other oxygenating compounds. OBC® works on a wider range of contaminants than other oxygenates because provides chemical oxidation and electron acceptors for bioremediation. The amount of oxygen in OBC® assumes that all of the oxygen in the sulfate is consumed through sulfate reduction processes. Table 2. Advantages of Oxygen BioChem (OBC)® Oxygen BioChem (OBC)* COMPETITORS Greater oxygen — as much as 46 wt % Typically 10 to 20 wt % Both chemical oxidation and bioremediation Predominantly bioremediation Greater solubility — typically 40 wt % for the persulfate portion Typically less than 5% soluble Better value - $3.25 per pound Typically $4 to $10 per pound CONTACT: John Haselow, PhD, PE Redox Tech, LLC 200 Quade Drive Cary, NC 27513 Phone: 919-678-0140 www.redox-tech.com Redox Tech LLC Attachment E .10toUNTAIN Environmental Group environmental consulting • assessment • remediation • waste management Former Pisgah Inn Gas Station Injection Procedure — Oxygen BioChem (OBC®) • As noted in the UIC application form, a release of gasoline from underground storage tanks has impacted soil and groundwater at this location. A Corrective Action Plan (CAP) dated July 8, 2009 was prepared on behalf of the Blue Ridge Parkway by Altamont Environmental. The CAP was subsequently approved by the NCDENR — UST Section. • The July 2009 CAP included specifications for the injectant EHC-O® or comparable product. Mountain Environmental as the current contractor for the Blue Ridge Parkway has selected the comparable product OBC® manufactured by Redox Tech, LLC for remediation at this site. Both products are on the list of NCDENR-approved remediation additives. • Injection is currently scheduled for June 1&2, or as soon thereafter as possible based on UIC permit approval. • OBC®will be delivered to the site in powder form in 30-gallon drums. Mixing with water will take place on site in a 250-gallon polyethylene tank. Approximately 2 lbs of OBC will be mixed per gallon of water. • Eight to ten injection points will be utilized. A direct -push unit will be used to advance probe rods to the required depth of 32 feet below ground surface. Injection will take place through the direct -push rods. • Slurry will be pumped from the poly tank with a Yamada diaphragm pump powered by a Honda air compressor. Injection pressure will be controlled by a pressure regulator on the air compressor. Injection pressure will be monitored by a pressure gauge on the injection tether mounted between the diaphragm pump and the top of the direct -push tool string. If excessive back pressure builds up during injection, then the slurry mixture will be thinned to decrease the viscosity of the slurry. This would increase the volume of slurry injected into the subsurface. • Approximately 760 gallons of slurry is planned to be injected over 8 to 10 injection points. The proposed injection points are shown on the attached Figure 8 from the July 2009 CAP. • Upon completion of the slurry injection and withdrawal of the direct -push rods, the boreholes will be abandoned using bentonite. 1560 Pisgah Drive PHONE: (828) 648-5556 Canton, NC 28716 (800) 261-0031 FAX (828) 648-1566 www.mountainenvironmental.com OUNTAIN Environmental Group Attachment F environmental consulting • assessment • remediation • waste management Monitoring Plan Groundwater will be monitored before injection in the form of a baseline monitoring well sampling event using four nearby monitoring wells (MW-1, MW-4, MW-5, and MW-6). These wells are shown on the attached Figure 8. Baseline, as well as post -injection monitoring (one week after the injection event and thereafter for one year at quarterly intervals) will include analysis of VOCs, VPH and EPH. Additionally, each monitoring well sample will be analyzed for the following parameters to evaluate the occurrence and mechanisms of natural attenuation of the petroleum compounds; o Nitrate, nitrite, and nitrogen using EPA Methods 351.2 and 353.2 o Total dissolved iron using EPA Method 6010 o Sulfate using EPA Method 375.4 o Methane, ethane, and ethane using RSKerr o Carbon dioxide using AM20G8X o Chloride using SM 4500 CIE o Manganese using EPA Method 3010/200 In addition the following parameters will be measured in the field: o Dissolved oxygen o Ferrous iron o Oxidation reduction potential (ORP) o Alkalinity o pH o Temperature o Turbidity o Specific conductivity Quarterly reports summarizing the results of the groundwater monitoring will be submitted to DENR for the first year after injection. Semiannual reports will be submitted thereafter. 1560 Pisgah Drive Canton, NC 28716 www.mountainenvironmental.com PHONE: (828) 648-5556 (800) 261-0031 FAX.• (828) 648-1566 Attachment G - Well Data I ATTACHMENT 4 - CSA Table 2 Well Construction Summary Former Pisgah Inn Gas Station Mile Post 408 Blue Ridge Parkway Haywood County, North Carolina Well Total Well TOC Top of Date Well Screened Screen Well ID Diameter Depth Elevation Installed Material Interval Elevation (inches) (ft-bgs) (ft-MSL) (ft-MSL) MW-I 04/06/04 2 _ PVC _ 40.50 Soil 4925.23 4_895.23 MW-2 06/23/04 2 PVC _ 22.50 Bedrock 4926.39 4913.39 MW-3 06/22/04 2 PVC 39.95 Soil 4928.59 4898.59 MW-4 06/23/04 _ 2 PVC 24.08 Soil Bedrock 4893.60 _ 4878.60 MW-5 06/23/04 2 PVC 28.26 4904.97 4887.47 MW-6 06/24/04 2 PVC 33.22 Bedrock 4889.17 4866.17 DW-1 1979 1 09/15/61 6 NA 400.00 Bedrock NA NA NA DW-2 6 NA 100.00 Bedrock NA Notes: 1. TOC - Top of Casing 2. ft-bgs - feet below ground surface 3. ft-MSL - feet above Mean Sea Level 4. NA indicates that the information was Not Available or is Not Applicable. 5. Surface and TOC elevations obtained from well construction logs, well surveys, and summary tables from prior site assessment reports. 6. All wells are considered flushmount unless noted otherwise. P:\Rlue Ridge Parkway\Mt Pisgah Inn\Reports\CSA\Analy-tical\tbl-CSA data tables Page I of I C - Injection Fluid Composition an6 fly well data included after the OBC d Oxygen BioChem (OBC)m Recent applications of in situ chemical oxidation (ISCO) have shown that ISCO can be a cost-effective remedial strategy for organic contaminants in groundwater and soil. The application of ISCO to contaminated source areas usually results in an immediate benefit to groundwater in the area. In addition, further contaminant flux can be reduced or eliminated mitigating further contaminant plume issues. Redox Tech has recently formulated a mixture of -sod um.persulfate-andmlcitfmpttU)dde-hat,can-bee eemployed for ISCO applications using FMC's patent -pending Iflozufm activation h istry. The mixture in OBC supports a two -fold mechanism for treating contaminants of concern. OBC delivers one of the strongest chemical oxidants for short term ISCO, and also provides electron acceptors (oxygen and sulfate) for longer -term biological oxidation. Sodium persulfate has emerged recently as an important oxidant for in situ remediation of volatile and semi -volatile organic compounds. Persulfate is the strongest oxidant within the peroxygen family, with an electromotive force of 2.12 volts. As illustrated below, the direct oxidation half -cell reaction for persulfaw involves a two -electron transfer: 2 %0. + 2 W +2e --3 2HS0j However in most cases, rapid destruction of the contaminant of concern requires that the persulfate be activated in order to generate sulfate radicals. Sulfate radicals are powerful oxidizing agents, with an oxidation potential of 2.6 volts. Klozur activated persulfate is catalyzed with the peroxide and base provide by the calcium peroxide S20a + calcium peroxide activator —* 2SO4' Activated persulfate can remain available in the subsurface for months providing an unrivaled combination of power and stability. The calcium peroxide provides several benefits. First, it imparts the alkalinity and peroxide needed to activate the persulfate using FMC's Klozufm activation chemistry. Second, when mixed with water it provides a long-term slow release source of hydrogen peroxide and calcium hydroxide. Ca% + 2 HZO 4 Ca(OH)z + H2O2 The hydrogen peroxide that is slowly formed decomposes to oxygen and water, providing an extended oxygen source for subsequent bioremediation of petroleum hydrocarbons. The resultant calcium hydroxide (hydrated lime) that is produced serves several purposes. First of all, it increases the total dissolved ion concentration, which makes the solution less likely to leach metals from the soil into the groundwater. Secondly, the calcium from the 200 QUADE DRtv1:, CARY NC 27513 TEL 919 678.0140 FAX 919.678.0150 WWWYJMOX TECH.COM E MAIU HASELOW@REDOX TECH COM Providing Innovative Soil and Water Solutions hydrated lime will precipitate the sulfate that is produced during the consumption of the persulfate. The calcium sulfate (gypsum) precipitation helps to reduce sulfate groundwater concentrations, which may impact the secondary drinking water standard of 250 ppm. The mixture in OBCO provides chemical oxidation as well as electron acceptors (oxygen and sulfate) for longer term biological oxidation. The predominant short-term reaction is chemical oxidation, while the longer -term remediation process is biological oxidation. OBCO has the . advantages over more traditional oxygen compounds used for bioremediation in that is works on a broader range of contaminants. Table 1. Contaminants Treated by Oxygen BioChem (OBC)® CONTAIVIMANTS TREATED BTEX 1,4-dioxane MTBE PCBs PAHs Pentachloro henol Chlorinated Alkenes Chlorinated Alkanes Table 2 summarizes the advantages of OBCO over other oxygenating compounds. OBCO works on a wider range of contaminants than other oxygenates because provides chemical oxidation and electron acceptors for bioremediation. The amount of oxygen in OBCO assumes that all of the oxygen in the sulfate is consumed through sulfate reduction processes. Table 2. Advantages of Oxygen BioChem (OBC)O Oxygen BioChem OBC ® COMPETITORS Greater oxygen — as much as 46 wt % Typically 10 to 20 wt % Both chemical oxidation and bioremediation Predominantly bioremediation Greater solubility — typically 40 wt % for the persulfate portion Typically less than 5% soluble Better value - $3.25 per ound t Typically $4 to $10 per pound CONTACT: John Haselow, PhD, PE Redox Tech, LLC 200 Quade Drive Cary, NC 27513 Phone: 919-678-0140 www.redox-tech.com Redox Tech, LLC MATERIAL SAFETY DATA SHEET Oxygen BioChem (OBQ@ MSDS Ref. No.: F18-44-8 o Date Approved: 04/30/2006 FMCRevision No.: 2 This document has been prepared to meet the requirements of the U.S. OSHA Hazard Communication Standard, 29 CFR 1910.1200; the Canada's Workplace Hazardous Materials Information System (WHMIS) and, the EC Directive, 2001/58/EC. 1. PRODUCT AND COMPANY IDENTIFICATION PRODUCT NAME: Oxygen BioChem (OBC)® GENERAL USE: For chemical oxidation and aerobic biorem6diation, petroleum hydrocarbon remediation, creosote remediation and partially halogenated hydrocarbon remediation. MANUFACTURER EMERGENCY TELEPHONE NUMBERS FMC CORPORATION (303) 595-9048 (Medical - U.S. - Call Collect) FMC Peroxygens 1735 Market Street For leak, fire, spill, or accident emergencies, call: Philadelphia, PA 19103 (800) 424-9300 (CHEMTREC - U.S.A. & Canada) (215) 299-6000 (General Information) 2. HAZARDS IDENTIFICATION EMERGENCY OVERVIEW: • Odorless, off-white fine granular solid (may have separation or noticeable two-tone appearance). • Oxidizer. • Contact with combustibles may cause fire. • Decomposes in storage under conditions of moisture (water/water vapor) and/or excessive heat causing release of oxides of sulfur and oxygen that supports combustion. Decomposition could form a high temperature melt. See Section 10 ("Stability and Reactivity"). • Deluge container with water at safe distance or in protected area. • May be severely irritating to the eyes. POTENTIAL HEALTH EFFECTS: Airborne dust may be irritating to eyes, nose, lungs, throat and skin upon contact. Exposure to high levels of dust may cause difficulty in breathing in sensitive persons. No significant long term inhalation hazard; irritation usually subsides after exposure ceases. Page 1 of 10 Oxygen BioChem (OBC)® (F18-44-8) Date: 04/30/2006 3. COMPOSITION / INFORMATION ON INGREDIENTS Chemical Name CAS# Wt.% EC No. EC Class Proprietary Mixture I None I Not classified 4. FIRST AID MEASURES EYES: Immediately flush with water for at least 15 minutes, lifting the upper and lower eyelids intermittently. See a medical doctor or ophthalmologist immediately. SKIN: Wash with plenty of soap and water. Get medical attention if irritation occurs and persists. INGESTION: Rinse mouth with water. Dilute by giving 1 or 2 glasses of water. Do not induce vomiting. Never give anything by mouth to an unconscious person. See a medical doctor immediately. INHALATION: Remove to fresh air. If breathing difficulty or discomfort occurs and persists, obtain medical attention. NOTES TO MEDICAL DOCTOR: Modest irritation is the only expected effect. No serious consequences are expected, except perhaps in the case of direct eye contact. Contaminated external surfaces should be flooded with water, and direct eye contact deserves ophthalmologic evaluation. If ingested, gastrointestinal irritation but not caustic burns are to be expected; dilution with water indicated as may be gastric evacuation via emesis or lavage if large doses or severe irritation is evident. Demulcents should be helpful. No systemic effects are expected though human toxicity data is sparse. 5. FIRE FIGHTING MEASURES EXTINGUISHING MEDIA: Deluge with plenty of water. FIRE / EXPLOSION HAZARDS: Product is non-combustible. Under fire conditions, may decompose and release oxygen gas, which may intensify fire. Presence of water accelerates decomposition. Mixtures with polysulfide polymers may ignite. FIRE FIGHTING PROCEDURES: Use flooding quantities of water. Use water spray to keep fire exposed containers cool. Do not use carbon dioxide or other gas filled fire extinguishers; they will have no effect on decomposition. Wear full protective clothing and self-contained breathing apparatus. Page 2 of 10 Oxygen BioChem (OBC)® (F18-44-8) Date: 04/30/2006 FLAMMABLE LIMITS: Non-combustible SENSITIVITY TO IMPACT: Oxidizable materials can be ignited by grinding and may become explosive. SENSITIVITY TO STATIC DISCHARGE: Not available 6. ACCIDENTAL RELEASE MEASURES RELEASE NOTES: Confine and collect spill, put into an approved DOT container (do not return to original container) and isolate for disposal. Isolated material should be monitored for signs of decomposition (fuming / smoking). If spilled material is wet, dissolve with large quantities of water and dispose as a hazardous waste. Runoff to sewer may create fire or explosion hazard (do not flush powdered material into sewer). Dispose of wastes according to the method outlined in Section 13, "Disposal Considerations". 7. HANDLING AND STORAGE HANDLING: Avoid contact by using personal protective equipment. Use respiratory protective equipment when release of airborne dust is expected. If compounded with organics or combustible materials be sure to exclude moisture. Use clean plastic or stainless steel scoops only. STORAGE: Keep dry (reacts with moisture). Use first in, first out storage system. Store unopened in a cool, clean, dry place away from point sources of heat (e.g, steam pipes, radiant heaters, hot air vents or welding sparks). Keep container tightly closed when not in use. Avoid contamination of opened product. Avoid contact with reducing agents. In case of fire or decmpositoin (fuming / smoking) deluge with plenty of water to control decomposition. Fore storage, refer to NFPA Bulletin 430 on storage of liquid and solid oxidizing materials. COMMENTS: VENTILATION: Provide mechanical general and/or local exhaust ventilation to prevent release of dust into work environment. Spills should be collected into suitable containers to prevent dispersion into the air. If ventilation is inadequate or not available, use dust respirator and eye protection. S. EXPOSURE CONTROLS / PERSONAL PROTECTION EXPOSURE LIMITS Chemical Name ACGIH OSHA Supplier Proprietary Ingredient 0.1 mg/m3 (TWA) Page 3 of 10 i� Oxygen BioChem (OBC)@ (F18-44-8) Date: 04/30/2006 Chemical Name ACGIH OSHA Supplier Proprietary Ingredient 5 mg/m3 (TWA) 5 mg/m3 (TWA) 5 mg/m(TWA) ENGINEERING CONTROLS: Provide mechanical local exhaust ventilation to prevent release of dust into the work area. If release is expected use respiratory protection. Remove contaminated clothing immediately and wash before reuse. PERSONAL PROTECTIVE EQUIPMENT EYES AND FACE: Use cup type chemical goggles. Full face shield may be used. RESPIRATORY: Use approved dust respirator with full face piece. PROTECTIVE CLOTHING: Long sleeve shirt, impervious apron or clothing. Rubber or neoprene footwear. GLOVES: Rubber or neoprene gloves. Thoroughly wash the outside of gloves with soap and water prior to removal. Inspect regularly for leaks. 9. PHYSICAL AND CHEMICAL PROPERTIES ODOR: Odorless APPEARANCE: Off-white fine granular solid AUTOIGNITION TEMPERATURE: Non-combustible BOILING POINT: No data available COEFFICIENT OF OIL / WATER: Not available DENSITY / WEIGHT PER VOLUME: (Bulk) 60 lbs/ft3 (loose) EVAPORATION RATE: Not applicable (Butyl Acetate = 1) FLASH POINT: Not applicable MELTING POINT: Decomposes on heating (About 275°C) OXIDIZING PROPERTIES: Oxidizer PERCENT VOLATILE: Not applicable PH: 11.3 - 12.1 @ 250C / 1 hour (1 - 40%, slurry, solution) SOLUBILITY IN WATER: 18% (insoluble @ 25C); 73% (solubility @ 25°C) SPECIFIC GRAVITY: 2.6 - 2.92 VAPOR DENSITY: Not applicable (Air =1) VAPOR PRESSURE: Not applicable Page 4 of 10 Oxygen BioChem (OBC)® (F18-44-8) 10. STABILITY AND REACTIVITY CONDITIONS TO AVOID: STABILITY: POLYMERIZATION: INCOMPATIBLE MATERIALS: Date: 04/30/2006 Heat (decomposes at 275°C), moisture, reducing agents. Grinding with organics. Stable (decomposition could occur when exposed to heat or moisture) Will not occur Grinding mixtures with organics (oxidizable materials can be ignited by grinding and may become explosive); heavy metals. Acids, alkalis, halides (fluorides, chlorides, bromides and iodides), combustible materials, most metals and heavy metals, oxidizable materials, other oxidizers, reducing agents, cleaners, and organic or carbon containing compounds. Contact with incompatible materials can result in a material decomposition or other uncontrolled reactions. HAZARDOUS DECOMPOSITION PRODUCTS: Oxygen that supports combustion and oxides of sulfur, nitrogen, and calcium hydroxide. COMMENTS: PRECAUTIONARY STATEMENT: Use of persulfates in chemical reactions requires appropriate precautions and design considerations for pressure and thermal relief. Decomposing persulfates will evolve large volumes of gas and/or vapor, can accelerate exponentially with heat generation, and create significant and hazardous pressures if contained and not properly controlled or mitigated. Use with alcohols in the presence of water has been demonstrated to generate conditions that require rigorous adherence to process safety methods and standards to prevent escalation to an uncontrolled reaction. 11. TOXICOLOGICAL INFORMATION EYE EFFECTS: No data available for the mixture. Proprietary Component: Non -irritating (rabbit) Proprietary Component: Severely irrtaitng (unwashed); Minimally irritating (washed) SKIN EFFECTS: No data available for the mixture. Expected to be non -irritating (rabbit) DERMAL LD50: No data available for the mixture. Proprietary Components: > 10 g/kg (rat) ORAL LD50: No data available for the mixture. Proprietary Component: 895 mg/kg (rat) Proprietary Component: 5 g/kg (rat) Page 5 of 10 j Oxygen BioChem (OBC)® (F18-44-8) Date: 04/30/2006 INHALATION LC50: No data available for the mixture. Proprietary Component: 5.1 mg/1(rat) Proprietary Component: > 17 mg/l (1 h) (rat) SENSITIZATION: No data available for the mixture. Proprietary Component: (Skin) May be sensitizing to allergic persons. (guinea pig) TARGET ORGANS: Eyes, skin, respiratory passages ACUTE EFFECTS FROM OVEREXPOSURE: Modest irritation is the only expected effect. No serious consequences are expected, except perhaps in the case of direct eye contact. Dust may be harmful and irritating to the eyes, nose, throat and lungs. May be harmful if swallowed. CHRONIC EFFECTS FROM OVEREXPOSURE: No data available for the mixture. Sensitive persons may develop dermatitis and asthma. One of the proprietary components was fed to groups of male,and female rats at 0, 300 and 3,000 ppm in the diet for 13 weeks, followed by 5,000 ppm for 5 weeks. Microscopic examination of tissues revealed some injury to the gastrointestinal tract at the highest dose (3,000 ppm) only. This effect is not unexpected for an oxidizer at high concentrations. CARCINOGENICITY: NTP: Not listed IARC: Not listed OSHA: Not listed OTHER: ACGIH: Not listed 12. ECOLOGICAL INFORMATION ECOTOXICOLOGICAL INFORMATION: No data available for the mixture. Effect of low concentrations on aquatic life are unknown. Proprietary Component Bluegill sunfish, 96-hour LC50 = 771 mg/L [FMC Study I92-12501 Rainbow trout, 96-hour LC50 = 163 mg/L [FMC Study 192-1251] Daphnia, 48-hour LC50 = 133 mg/L [FMC Study I92-1252] Grass shrimp, 96-hour LC50 = 519 mg/L [FMC Study I92-12531 CHEMICAL FATE INFORMATION: As indicated by chemical properties oxygen is released into the environment. Biodegradability does not apply to inorganic substances. Page 6 of 10 Oxygen BioChem (OBC)® (1718-44-8) Date: 04/30/2006 13. DISPOSAL CONSIDERATIONS DISPOSAL METHOD: Dissolve in water to allow the release of oxygen and dispose via a treatment system in accordance with governmental agencies regulations. Contact appropriate regulatory agency prior to disposal. 14. TRANSPORT INFORMATION U.S. DEPARTMENT OF TRANSPORTATION (DOT) PROPER SHIPPING NAME: PRIMARY HAZARD CLASS / DIVISION: UN/NA NUMBER: PACKING GROUP: LABEL(S): PLACARD(S): MARKING(S): ADDITIONAL INFORMATION: Oxidizing solid, n.o.s. (sodium persulfate, calcium peroxide) 5.1 (Oxidizer) UN 1479 II 5.1 (Oxidizer) 5.1 (Oxidizer) Oxidizing solid, n.o.s. (sodium persulfate, calcium peroxide), UN1479 Hazardous Substance/RQ: Not applicable 49 STCC Number: 4918733 This material is shipped in 55 lb. polyethylene pail with vented screw -on lid (approx 6.5 gallon) INTERNATIONAL MARITIME DANGEROUS GOODS (IMDG) PROPER SHIPPING NAME: Oxidizing solid, n.o.s. (sodium persulfate, calcium peroxide) INTERNATIONAL CIVIL AVIATION ORGANIZATION (ICAO) / INTERNATIONAL AIR TRANSPORT ASSOCIATION (IATA) PROPER SHIPPING NAME: ADDITIONAL INFORMATION: Page 7 of 10 Oxidizing solid, n.o.s. (sodium persulfate, calcium peroxide) Combination packaging is recommended for air transport. Oxygen BioChem (OBC)® (1718-44-8) Date: 04/30/2006 OTHER INFORMATION: Place spilled product in suitable container and wash residue with plenty of water. See Section 6 (Accidental Release Measures) above for additional instructions. 15. REGULATORY INFORMATION UNITED STATES SARA TITLE III (SUPERFUND AMENDMENTS AND REAUTHORIZATION ACT) SECTION 311 HAZARD CATEGORIES (40 CFR 370): Fire Hazard, Immediate (Acute) Health Hazard SECTION 312 THRESHOLD PLANNING QUANTITY (40 CFR 370): The Threshold Planning Quantity (TPQ) for this product, if treated as a mixture, is 10,000 lbs; however, this product contains the following ingredients with a TPQ of less than 10,000 lbs.: None SECTION 313 REPORTABLE INGREDIENTS (40 CFR 372): Not listed CERCLA (COMPREHENSIVE ENVIRONMENTAL RESPONSE COMPENSATION AND LIABILITY ACT) CERCLA DESIGNATION & REPORTABLE QUANTITIES (RQ) (40 CFR 302.4): . Proprietary component: Unlisted, RQ = 100 lbs., Ignitability TSCA (TOXIC SUBSTANCE CONTROL ACT) TSCA INVENTORY STATUS (40 CFR 710): Listed (components) RESOURCE CONSERVATION AND RECOVERY ACT (RCRA) RCRA IDENTIFICATION OF HAZARDOUS WASTE (40 CFR 261): Waste Number: D001 CANADA WHMIS (WORKPLACE HAZARDOUS MATERIALS INFORMATION SYSTEM): Chemical Name: Proprietary Component Product Identification Number: 1505 Hazard Classification / Division: Class C (Oxidizer), Class D, Div. 2, Subdiv. B. (Toxic) Ingredient Disclosure List: Listed Chemical Name: Proprietary Component Product Identification Number: 1457 Hazard Classification / Division: Class D, Div 2, Subdiv. B, Class C (Oxidizer) . Ingredient Disclosure List: Listed Page 8 of 10 Oxygen BioChem (OBC)O (F18-44-8) INTERNATIONAL LISTINGS Proprietary Component Australia (AILS): Listed China: Listed Japan (ENCS): (1)-1131 Korea: KE-12369 Philippines (PICCS): Listed Proprietary Component Australia (AICS): Listed China: Listed Japan (ENCS): (1)-181 Korea: KE-04518 Philippines (PICCS): Listed Proprietary Component Australia (AICS): Listed China: Listed Japan (ENCS): (1)-190 Korea: KE-04597 Philippines (PICCS): Listed Date: 04/30/2006 HAZARD, RISK AND SAFETY PHRASE DESCRIPTIONS: EC Symbols: (Not classified as hazardous) EC Risk Phrases: (Not classified as hazardous) EC Safety Phrases: (Not classified as hazardous) 16.OTHER INFORMATION HMIS Health 2 Flammability 0 Physical Hazard 1 Personal Protection (PPE) J Protection = J (Safety goggles, gloves, apron & combination dust & vapor respirator) HMIS = Hazardous Materials Identification System Degree of Hazard Code: 4 = Severe 3 = Serious Page 9 of 10 Oxygen BioChem (OBC)® (F18-44-8) 2 = Moderate 1 = Slight 0 = Minimal NFPA Health 2 Flammability 0 Reactivity 1 Special OX SPECIAL = OX (Oxidizer) NFPA = National Fire Protection Association Degree of Hazard Code: 4 = Extreme 3 = High 2 = Moderate 1 = Slight 0 = Insignificant REVISION SUMMARY: This MSDS replaces Revision #1, dated December 12, 2005. Changes in information are as follows: Section 1 (Product and Company Identification) Section 16 (Other Information) FMC Logo - FMC Corporation Trademark Oxygen BioChem (OBC) - Trademark of Redox Tech, LLC © 2006 FMC Corporation. All Rights Reserved. Date: 04/30/2006 FMC Corporation believes that the information and recommendations contained herein (including data and statements) are accurate as of the date hereof. NO WARRANTY OF FITNESS FOR ANY PARTICULAR PURPOSE, WARRANTY OF MERCHANTABILITY, OR ANY OTHER WARRANTY, EXPRESSED OR IMPLIED, IS MADE CONCERNING THE INFORMATION PROVIDED HEREIN. The information provided herein relates only to the specific product designated and may not be applicable where such product is used in combination with any other materials or in any process. It is a violation of Federal law to use this product in a manner inconsistent with its labeling. Further, since the conditions and methods of use are beyond the control of FMC Corporation, FMC Corporation expressly disclaims any and all liability as to any results obtained or arising from any use of the product or reliance on such information. Page 10 of 10 Attachment H - Maps ATTACHMENT 4 - GSA vI ,ct�pif M1 k „r t r ,Al ,a. I JIO LocationIF r1 l t F _ � r lk N. - Fi. •fit,' � t `.> a i •t- �'� J' rr:�.�_�- _ � _may. .t` 1• .�•` �_tir�t�/'`_ • tey { r pIr VJ � Yj V 7. USGS Topo Map: Cruso Quadrangie � ` 1 i� Created: 1941 Revised:1987 6" �`; - 'mot ,,, •'-'r-;r z �"°— USGS Topo Map: Dunsmore Mt Quadrangle �•-A �1S �g� e_ Created:1967 t ° F f J SITE LOCATION MAP FIGURE ,(I COLLEGE STREET, ASFffVRiF. NC 24801 Td. MIA 0 F. 321. 2S 1. 1111 FORMER PISGAH INN GAS STATION MILE POST 408 BLUE RIDGE PARKWAY HAYWOOD COUNTY, NORTH CAROLINA DRAWN BY: EVAN YURKOVICH SCALE ' I PROJECT MANAGER: CHRIS GILEERT 0 ooa 2000 CLIENT: NATIONAL PARK SERY ICE Feel DATE: 6/9/08 P�1BIue RKIge ParkwayM Pisgah Inn\FigureslFigure 1 - Ste Location SOURCE• 1. UNDATED CAD DRAWING PROVIDED BY THE NATIONAL PARK SERVICE. MW6 GRASS MW- CAMPGROUND M W-4 ® �L W j m MW-5 ®/ GIFT SHOP N 0 el H V O R P cc O L O O Y 231 HAYW00D 0T009T. A{H[VILL{. 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P 35,f i•Yar '' ."'Tf ' (� Appmdmate Extent of N WI NC ONE MAP ,' ,t � 'i�ay. �C� .,s • g,� t Q I500-foot Receptor Radius NATIONAL WETLANDS INVENTORY .y'Y :i'}},t�..a�msr�,);'r�5 3>y.'�k:"FF'-r'a" CorntyBoundary RECEPTOR MAP FIGURE ' N I N I H l' G Y SO COL FGE 5 MEET, ASHEVILLE, NC 289i11 Td. in281. 33% Fa. 929 2313351 FORMER PISGAH INN GAS STATION MILE POST 408 BLUE RIDGE PARKWAY HAYWOOD COUNTY, NORTH CAROLINA 3 DRA'VYN BY: EYAN YuwoviCH SCALE PROJECT MANAGER: CHRIS GILBERT CLIENT: NPS p 500 1,000 DATE: 07i 0212009 Feet PABlue Ridge ParkwayWt Pisgah Inn\Figures\VMl Receptor Map.mxd 0 NOTE: WATER TABLE ELEVATIONS WERE MEASURED ON AUGUST 12, 2008 LEGEND ® MONITORING WELL © CSA SOIL BORING A —A' CROSS SECTION LOCATIONS 4870 POTENTIOMETRIC SURFACE CONTOURS (5-FOOT INTERV, ImMW--5 231 HAYWOOD OTAL[T, AlNCVILL[, NC 20001 TCL,e 2e, 2111,aaso r,c.n7n,xAl.aael W W W, AI.TAMOMTRNVIIION M. NTAL.COM u POTENTIOMETRIC SURFACE MAP AUGUST 2008 FIGURE FORMER PISGAH INN GAS STATION DRAWN BY: ANNA SAYLOR SCALE (FEET) MILE POST 408 BLUE RIDGE PARKWAY PROJECT MANAGER; CHRIS GILQERT CLIENT: NPS so 0 30 so HAYWOOD COUNTY, NORTH CAROLINA DATE: 06/29/2009 PABL s7 PON P.wWAY\Mr Null, !WTIGMNINFIGURE 4fDTFNTIaDTRID SWIACI HAP^AtM 4T I. 1009,DWd I ®M -6 (4, 873. 637) OMW--4 (4, 883. 6, NOTE: WATER TABLE ELEVATIONS WERE MEASURED ON JANUARY 8, 2009 LEGEND ® MONITORING WELL Qa CSA SOIL BORING MW-O (4,883.37) 221 MAYW000 OTMT, AANCVILLA, NC 20001 T CL.020. 241,3360 PAC: 024,281.3301 W W W..6TA PONT Aw RIR�M•�NIAL.��M CROSS SECTION LOCATIONS DRAWN BY: ANNA SAYL.OR SCALE (FEET) 4910- POTENTIOMETRIC SURFACE PROJECT MANAGER: CHRIS GILBERT CONTOURS (5-FOOT INTERVALS) CLIENT: NPS 30 0 30 60 DATE: 06/29/2009 V2 ,917.72) POTENTIOMETRIC SURFACE MAP JANUARY 2009 FORMER PISGAH INN GAS STATION MILE POST 408 BLUE RIDGE PARKWAY HAYWOOD COUNTY, NORTH CAROL.INA FIGURE ti' � P\RrrM Rrorw PAPnW pv\Hi PleOpw IN.i\P r61n1lp\f pJtP yM�PMT1or�n1K SUP/pC! M�P•.IpPUaRV p. 1pp9. wrrt WEST A 4930 4920 J W W -' 4910 a W w z a W E W 0 a 4900 W W eL z 0 F Q J 4890 W 4880 4870 BEDROCK NEAR MW-01, IN GROUNDWATER AND SMEAR ZONE EAST Al 49301 49201 4910 1 49001 48901 4880 1 4870 1 LEGEND ICONCEPTUAL SITE MODEL FIGURE •PIP.M106 VAU •��. It"Al vLEom.Lj Tm NOTES_ �LUSOL ft-AIM 01020 j I L sm mcw Sirs So" idiT UPPER! 9. = VA-m LEWL ELMTmw Z SIN ow Ims � � SAME Ci07L73t1913 3.. it EsE.anls Rss LIDCLTme +1E Awleo®.aE Sx SMgll Lq,,m 4 M bcomms So Caw;. wTs *am-, D z Ls, 20 Am f4mom. '� SOL SOVU LWATM j �"�L� $' a�a 1 CROSS SECTION A -A FORMER PISGAH INN GAS STATION MILE POST 408 SLUE RIDGE PARKWAY HAYWOOD COUNTY. NORTH CAROLINA 6 EOGIMEE111MG Q HTONOGEOLOGT 231 MET1t00* STREET. AENETILLE. NC 29901 TEL..20.291.3350 F&C_028_261.3351 DRAWN BY- AMA SAY"* �1to.>ECT � CHM GLOERT CLIENT. � DATE: 06/7912M SCALE FACTOR V. 1 1(= 10 FT H- 1 la = 20 FT i V. BY ICWIAPV P:t9 m ROO J'E"wAy%w P IG:#E 6-cm SECT A-t ,Vft 58.6 SMW 1 14ac" to M41G 1 Soil SOMA& Collactod 7"31d'008 Depth to Sample 29.31 Mal Iva Concontranon MSCC Contaminant (MgAg) (m9A0) n•Butylhenzene 14.2 4.3 (Tthylhenzone 25,8 4.6 Naphthalene 207 0.68 mPropyloanzona 22.1 1.7 Toluene 17.4 T3 f,2,4•Tdme1hylhenzona 144 7.5 Total Xylonos 138 5 C5-CSAliphatics 670 72 CO-C10Allphatics 320 34 SD-+ O sn-+ so-3 O O b� 50.8 O S84 NOTES: CSA SOIL BORINGS SP-1 AND SP-4 WERE ORIGINALLY ADVANCED DURING THE LSA. CSA SOIL BORING TP-12 WAS ORIGINALLY ADVANCED DURING UST CLOSURE, DURING THE CSA, CONSTITUENTS WERE ONLY DETECTED IN SMW-I, THEREFORE, NO DATA IS POSTED AT OTHER CSA BORINGS. LEGEND ® MONITORING WELL LSA SOIL BORING UST CLOSURE SAMPLES �i CSA SOIL BORING ,W4 O MW- ITr.,1 SW3Q �. 231 MAYWOOD STAaaT, Ae HAVILI,a, NC 28801 Ta L.a2a.201.3350 rAe.820,281.3331 WWW.ALTAMOMTENVIN OMM.M 1A64eM DRAWN BY: ANNA SAYLOR PROJECT MANAGER: CHRIS GILBERT SCALE (FEET) CLIENT: NPS 10 0 10 DATE: 06/29/2009 T'® PL-3 Pl-2 PI-f SOIL AND GROUNDWATER SAMPLING LOCATIONS AND POSTED DATA FROM CSA FORMER PISGAH INN GAS STATION MILE POST 408 BLUE RIDGE PARKWAY 20 HAYWOOD COUNTY, NORTH CAROLINA P'\A'_Ur RJOGr PARK'NAYIMT P16GAH WNWIQ'RMFIGUtE 7-CSA 6AMRL6: LQ..6.aWG MW-2 FIGURE 7 MW-6 1 LEGEND ® MONITORING WELL ® CSA SOIL BORING ESTIMATED EXTENT OF — r AQUIFER CONTAMINATION • APPROXIMATE LOCATION OF RECOMMENDED IS -SITU AEROBIC SIOREMEDIATION INJECTION POINT Free Product SB-1 SB-3 SB-2 w. O ii SB-8 • `, _....... EpI .__._._-p N N[[ N I N O 8 H V p N p O[ O I. O Y 291 MAYWOOD fly RCeT, AAHIVILL[, NC a[N01 Y[L.[a[.zoi.93eo rAc.B2[a[1.9961 W WW.A�TAMONT[NVIOONM[NTA�.00M DRAWN BY: ANNA SAYLOR SCALE (FEET) PROJECT MANAGER: CHRIS GILBERT CLIENT: NPS 25 0 25 DATE: 06/29/2009 N--2 ESTIMATED HORIZONTAL EXTENT OF AQUIFER CONTAMINATION FORMER PISGAH INN GAS STATION MILE POST 408 BLUE RIDGE PARKWAY HAYWOOD COUNTY, NORTH CAROLINA sa ' P'\BLU= rI E PARKWAY\11T R95AM INIIYI PR\flf )RE A-4—PrR CMT—ATIM-YWH FIGURE r;� Rogers, Michael From: Judd MahanOmahan@mountainenvironmental.com] Sent: Friday, September 17, 2010 10:55 AM To: Rogers, Michael Subject: Pisgah Inn UIC permit - Michael, On page 4 of the UIC permit application the screened interval / injection interval should be 30 to 40 feet bgs. This should allow for the treatment of a zone approximately 12 to 13 feet thick. The exact interval depth may vary based on back pressure observed during injection and potential refusal of the Geoprobe tool string. Thanks, Judd Mahan, PG Project Manager Mountain Environmental Group 1560 Pisgah Drive Canton, NC 28716 Phone 828-648-5556 Mobile 828-458-2240 NCDEN North Carolina Department of Environment and Natural Resources Division of Water Quality Beverly Eaves Perdue Coleen H. Sullins Governor Director June 2, 2010 Philip A. Francis, Jr National Park Service 199 Hemphill Knob Road Asheville, NC 28803 Subject: Acknowledgement of Application No. WI0100098 Former Pisgah Inn Gas Station Injection In situ Groundwater Remediation Well (5I) Haywood Dear Mr. Francis: Dee Freeman Secretary The Aquifer Protection Section of the Division of Water Quality (Division) acknowledges receipt of your permit application and supporting materials on May 24, 2010. This application package has been assigned the number listed above and will be reviewed by Michael Rogers. The reviewer will perform a detailed review and contact you with a request for additional information if necessary. To ensure the maximum efficiency in processing permit applications, the Division requests your assistance in providing a timely and complete response to any additional information requests. Please be aware that the Division's Regional Office, copied below, must provide recommendations prior to final action by the Division. Please also note at this time, processing permit applications can take as long as 60 - 90 days after receipt of a complete application. If you have any questions, please contact Michael Rogers at 919-715-6166, or via e-mail at michael.rogers@ncdenr.gov. If the reviewer is unavailable, you may leave a message, and they will respond promptly. Also note that the Division has reorganized. To review our new organizational chart, go to h=:Hh2o.enr.state.nc.us/document-,/dwci orgchart.pdf. PLEASE REFER TO THE ABOVE APPLICATION NUMBER WHEN MAKING INQUIRIES ON THIS PROJECT. Sincerely, for Debra J. Watts Supervisor cc: Asheville Regional Office, Aquifer Protection Section Judd Mahan (Mountain Environmental Group - 1560 Pisgah Drive, Canton, NC 28716) Permit Application File WI0100098 AQUIFER PROTECTION SECTION 1636 Mail Service Center, Raleigh, North Carolina 27699-1636 Location: 2728 Capital Boulevard, Raleigh, North Carolina 27604 One Phone: 919-733-3221 1 FAX 1: 919-715-0588; FAX 2: 919-715-60481 Customer Service: 1-877-623-6748 NOI-thCarol111a Internet: www.nrwatemuality.org An Equal Opportunity t Affirmative Action Employer NaturallY OUNTAIN Environmental Group May 21, 2010 Mr. Thomas Slusser Program Manager Underground Injection Control Program Aquifer Protection Section - NCDENR 1636 Mail Service Center Raleigh, NC 27604 environmental consulting • assessment • remediation • waste management RE: In Situ Groundwater Remediation Project Former Pisgah Inn Gas Station Dear Mr. Slusser: RECEIVED / DENR / DWQ AQUIFFR *PPnTFr.TinN ,qFCTION MAY 2 4 2010 Please find attached an Application For Permit to Construct and Use Wells for Injection. This project is located at the Former Pisgah Inn Gas Station and is a listed Underground Storage Tank release site (Incident # 28188). Thank you for your time and consideration in reviewing this application. If you have any questions or comments, please feel free to call me at (828) 648-5556. Sincerely, MOUNTAIN ENVIRONMENTAL GROUP Judd Mahan, PG Project Manager Enclosure 1560 Pisgah Drive Canton, NC 28716 www.mountainenvironmental.com PHONE: (828) 648-5556 (800) 261-0031 FAX (828) 648-1566 AQUIFER PROTECTION REGIONAL STAFF REPORT Date: June 18, 2010 County: Haywood To: Aquifer Protection Central Office Permittee: NCDENR APS UIC Central Office Reviewer: B. Laverty/J. Stepp Project Name: Pisgah Inn Regional Login No: Application No.: WI0100098 L GENERAL INFORMATION 1. This application is (check all that apply): ® New ❑ Renewal ❑ Minor Modification ❑ Major Modification ❑ Surface Irrigation ❑ Reuse ❑ Recycle ❑ High Rate Infiltration ❑ Evaporation/Infiltration Lagoon ❑ Land Application of Residuals ❑ Attachment B included ❑ 503 regulated ❑ 503 exempt ❑ Distribution of Residuals ❑ Surface Disposal ❑ Closed -loop Groundwater Remediation ® Other Injection Wells (including in situ remediation) Was a site visit conducted in order to prepare this report? ® Yes or U No. a. Date of site visit: June 16, 2010 b. Person contacted and contact information: Judd Mahan (828) 648-5556 c. Site visit conducted by: Brett Laverty and Jonathan Stepp d. Inspection Report Attached: ® Yes or ❑ No. 2. Is the following information entered into the BIMS record for this application correct? ® Yes or ❑ No. If no, please complete the following or indicate that it is correct on the current application. For Treatment Facilities: a. Location: b. Driving Directions: c. USGS Quadrangle Map name and number: d. Latitude: Longitude: e. Regulated Activities / Type of Wastes (e.g., subdivision, food processing, municipal wastewater): For Disposal and Injection Sites. f multiple sites either indicate which sites the information gRplies to copy and paste a new section into the document for each site or attach additional a es for each site a. Location(s): Mile Post 408 - Blue Ridge Parkway, Waynesville, NC 28716 b. Driving Directions: U.S. 276 to Blue Ridge Parkway, Mile post 408 (Pisgah Inn) c. USGS Quadrangle Map name and number: Cruso Quad/35082-D7-TF-024 d. Latitudf- 9 "� -�1801 Longitude: 350 24' 15.42" N 820 45' 13.36" W rnudi rcntiuns sici ) to nett section) #,)escritstio t)s" Vas#e(Sl �A.nd Facilities 1.. Plea_se attach coinpleted ratintz sheet. Facility Classification: 2. Are the nevv treatment facilities adequate fo, the type of waste and disposal systelll? FORM: Pisgah Inn.docx 1 NtL,t1VtU I UtNN ! uvvU AQUIFER PROTP-710N gFCTION JUN 18 2010 J AQUIFER PROTECTION REGIONAL STAFF REPORT ❑ Yes ❑ No ❑ N/A. If no, please explain: 3. Are the new site coaidition.s (soils; topography, depth to water 'table, etc) consistent with what was reported by the soil scientist and/or Professional Engineer'? ❑ Yes ❑ No ❑ N/A./ If no, please explain: 4. Does the application (snaps, plans; etc.) represent the actual site (property lines, wells, surtke- drainage)'? ❑ Yes ❑ No ❑ N/A. If no, please explain: _ 5. Is the proposed residuals management plan adequate andlor acceptable to the Division. ❑ Yns ❑ No ❑ N/A. If uo, please explain: 6. .Are the proposed application rates for new sites (hydraulic or nutr:i.ent) acceptable'? ❑ Yes ❑ No ❑ N/A. If no, please explain: _ ?. Are the he-v treatment facilities or any new disposal sites located in a 100-year floodplain'? ❑ Yes ❑ No ❑ N,-A. It yes; please attach a map showing areas of 100-year floodplain and please explain and recormnend any mitigative measures/special conditions in Part IV: _ 8. Are there any buffer conflicts (new treatment facilities or new disposal sites)? ❑ Yes or []No. It`yess, please attach a map sho-vving conflict areas or attach any new. maps you have received from the applicant to be - incorporated into the permit: .9. ls, proposed and/or existing groundwater monitorino program (nLIMI)Or of Wells, frequency of rnonitor,ng.. monitoring parameters, etc.) adegiiate? ❑ Yes ❑ No ❑ N/A. Attach map of existing monitoring well anet+-vork if applicable.. Indicate the review and compliance boundaries. If No, explain and. recommend any changes to the groundwater monitoring program: 10. For residuals, will seasonal or other restrictions be required? ❑ Yes ❑ No ❑ N/A If yes, attach list of sites with restrictions (Certification B?) i'I: i7OT`..1�r 11fi��I�T��ti�?''I97YftN�(c��e?ret�icnxtr.aeziiE�rta�r Inc-ir;_r-r t�^r.ra�,.fxc�ri'=cr. ;€1�;. Ls'fertts' Dese j:jption Of Waste(S) And Facilities N/A 1. Are there appropriately eerti l ied ORCs for the facilities? ❑ Yes or ❑ No. Operator in Cliarge: Certificate #: Backup- Operator in Charge: Certificate #: 2. Is the design, maintenance and operation (e.g. adequate aeration,. sludge wasting, sludge storage; effluent storage; etc) of tine treatment facilities adequate for the type of. waste and disposal system? ❑ Ye's or ❑ No. If no, please explain: ;. Are the site conditions {soils, topography, depth to N-vat:er table, etc) iiiaintained ap.propri:)t._ iy ar, assimilating the waste? ❑ Yes or ❑ No. If no, please explain: PORM:.PisgahInn.docx 2 AQUIFER PROTECTION REGIONAL STAFF REPORT 4. Has the site changed. in any way that may affect perinit (drainage added, new wells inside the compliance boundary, new development, etc.)? If yes, please explainIs the residuals management plan for the facility adequate and/or adcceptable to. the Division? ❑ Yes or• ❑ No. if no, please explain: 5. Are the existing application rates (hydraulic or nutrient) still acceptable? ❑ Yes or ❑ No. If no, please explain: _ 6. Is the existing groundwater nlclnitoring program (number of,_,vells, frequency of monitoring, monitor'►► ; parameter's, etc.) adequate? ❑ Yes ❑ No ❑ N/A. Attach neap of existing monitoring -kkell network if applicable. Indicate tile. review and compliance boundaries. If No.. explain and recommend any changes to the groundwater monitoring program: 7. Will seasonal or other restrictions be regl:cired for added sites? ❑ Yes ❑ No ❑ N/A if yes, attach list of sites with restrictions (Certification B?) S. are there any buffer conflicts (treatment facilities or disposal sites)? ❑ Yes or ❑ No. If yes, please attach a neap showing conflict areas or attach ally nely- maps yott have received from the applicant to be incorporated into the peiTn-it: 9. Is the description of the facilities, type mid/or volu►Ile of wastc(s) as written in the exiAing ;x:_r tint: i ��rr,:+:'i:' L_t Yes or ❑ No. if no, please explain: 10. Were monitoring wells properly constructed and located? ❑ Yes or ❑ No ❑ N/A. if no, please explain: 11. Has a review of all self -monitoring, data been conducted (GW, NDMR, and NDAR as applicable)? ❑ Yes or ❑ No ❑ N/A. Please summarize any findings resulting from this review: 12. Check all that apply: ❑ No compliance issues; ❑ Notice(s) of violation .within the last permit cycle, ❑ Current enforcement action(s) ❑ Currently under SOC; ❑ Currently under JOC; ❑ CUI-relltiv under moratorium. if any ite►T►s checked, please,explain and attach any docurnents that play 11elp ;.larik- answer/comments (such as NOV.. NOD etc): Have all compliance dates/condidotls ill the existing pern.l t, (SOC, JOC, etc.) been complied with? ❑ Yes ❑ No ❑ Not Dete:rnlined ❑ N/A.. If no.. please explain: 13. Are there any issues related to compliance/enforcement. that should be resolved befiore issuing this permit? ❑ Ye,, pr ❑ No ❑ N/A. If yes, please explain: FORM: Pisgah Inn.doex 3 r' AQUIFER PROTECTION REGIONAL STAFF REPORT IV INJECTION WELL PERMITAPPLICA77ONS (Complete these two sections for all systems that use injection wells, including closed -loop groundwater remediation effluent injection wells, in situ remediation injection wells, and heat PUMP injection -wells.) Descrintion Of Well(S) And Facilities — New, Renewal, And Modification 1. Type of injection system: ❑ Heating/cooling water return flow (W) ❑ Closed -loop heat pump system (5QW5QW) ® In situ remediation (H) ❑ Closed -loop groundwater remediation effluent injection (5LP Non -Discharge") ❑ Other (Specify: _---) 2. Does system use same well for water source and injection? ❑ Yes ®No 3. Are there any potential pollution sources that may affect injection? ❑ Yes ® No • What is/are the pollution source(s)? • What is the distance of the injection well(s) from the pollution source(s)? 4.. What is the minimum distance of proposed injection wells from the property boundary? 250 ft. 5. Quality of drainage at site: ® Good ❑ Adequate ❑ Poor 6. Flooding potential of site: ® Low ❑ Moderate ❑ High (for injection site itself) 7. For groundwater remediation systems, is the proposed and/or existing groundwater monitoring program (number of wells, frequency of monitoring, monitoring parameters, etc.) adequate? ® Yes ❑. No. Attach map of existing monitoring well network if applicable. If No, explain and recommend any changes,to the groundwater monitoring program: 8. Does the map presented represent the actual site (property lines, wells, surface drainage)? ® Yes or ❑ No. If no or no map, please attach a sketch of the site. Show property boundaries, buildings, wells, potential pollution sources, roads, approximate scale, and north arrow. Iniection Well Permit Renewal And Modification Only: 1. For heat pump systems, are there any abnormalities in heat pump or injection -well operation (e.g. turbid water, failure to assimilate injected fluid, poor heating cooling)? ❑ Yes ❑ No. if Yes. explain: :?. For closed -loop heat pump systems. has system lost pressure oi- MILdred make-up :fluid since pertni.t 1.Ss 111C;2 or last inspection? ❑ Yes ❑ No. If yes. ex lain: 3. For renewal or modification of groundwater reivred.iation permits (of any, rime). will contiiuied/acfditiazal/modified infections have an adverse impact on migration of the phone or management of the contamination incident? ❑ Yes ❑ No. ifly s., ex lain: FORM: Pisgah lnn.doex 4 AQUIFER PROTECTION REGIONAL STAFF REPORT 4. Drilling contractor: Name: Address: Certification number: a. Complete, and alfach We]I Construction Data. Sheet. FORM: Pisgah Inn.doex 5 AQUIFER PROTECTION REGIONAL STAFF REPORT V EVALUATIONAND RECOMMENDATIONS 1. Provide any additional narrative regarding your review of the application.: The incident site is located along a ridgeline bordered by steeply dipping topography. A water /sewage utility corridor extends from the former gas station down to a lower campground. Any spills or day lighting of injection fluids could quickly migrate via overland flow or in the shallow subsurface along the utility corridor. 2. Attach Well Construction Data Sheet - if needed information is available: 3. Do you foresee any problems with issuance/renewal of this permit? ❑ Yes ® No. If yes, please explain briefly. 4. List any items that you would like APS Central Office to obtain through an additional information request. Make sure that you provide a reason for each item: Item Reason none 5. List specific Permit conditions that you recommend to be removed from the permit when issued. Make sure that you provide a reason for each condition: Condition Reason none 6. • List speck special conditions or compliance schedules that you recommend to be included in the permit when issued. Make sure that you provide a reason for each special condition: Condition Reason Make sure a spill response plan is in place and that spill kits are on site in case of accidental discharge Potential contaminate pathways include steeply dipping topography and nearby utility corridor. 7. Recommendation: ❑ Hold, pending receipt and review of additional information by regional office; ❑ Hold,_ pending review of draft permit by regional office; ❑ Issue upon receipt of needed additional information; Issue; ❑ Deny. If deny, please state reasons: 8. Signature of report preparer(s) Signature of APS regional sups Date: 6/18/2010 ADDITIONAL REGIONAL STAFF REVIEW ITEMS FORM: Pisgah Inn.docx 6 I Rogers, Michael From: Laverty, Brett Sent: Friday, June 18, 2010 3:09 PM To: Rogers, Michael Subject: UIC Permit W 10 100098 Attachments: UIC W10100098 Regional Staff Report.pdf Michael, Here is the regional staff report for Pisgah Inn UIC permit. Let me know if you need a hard copy. i Brett Laverty Brett Laverty - brett.lavertyCaD_ncdenr.gov North Carolina Dept. of Environment and Natural Resources Asheville Regional Office Division of Water Quality -.Aquifer Protection Section 2090 U.S. 70 Highway Swannanoa, NC 28778 Tel: 828-296-4500 - Fax: 828-299-7043 Notice: E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and therefore may be disclosed to third parties. 1 ` ,a STATpo ' North Carolina Department of Health and Human Services Division of Public Health — Epidemiology Section Occupational and Environmental Epidemiology Branch 1912 Mail Service Center • Raleigh, North Carolina 27699-1912 Telephone:919-707-5900 Fax: 919-870-4807 Michael F. Easley, Governor Leah Devlin, DDS, MPH Dempsey Benton, Secretary State Health Director AQURF C�EIVED/DENR/-DWQ August 25, 2008 R�TFrn��,i SFC AUG 2 rio�v MEMORANDUM 7 2008 To: Qu Qi — UIC Program Aquifer Protection System Division of Water Quality Department of Environment and Natural Resources From: Sandy Mort A1--*�LFLV Epidemiology Section Division of Public Health Department of Health and Human Services Subject: Health Risk Assessment Use of a ade o> sodium hydroxide as activator for groundwater/soil remediation with sodium persulfate The following information is provided in response to Aquifer Protection Section's (APS) request for a health risk evaluation regarding the use of sodium persulfate with calcium peroxide or sodium hydroxide as activators for groundwater or soil remediation. These chemicals are proposed for use at a Duracell battery manufacturing site contaminated with chlorinated hydrocarbons, petroleum hydrocarbons, acetone, and carbon tetrachloride. This review is provided as supplemental information to that provided to APS in September 2003 by DPH regarding the use of hydrogen peroxide and iron-EDTA activators with sodium persulfate. The information provided to DPH indicates that calcium peroxide will be used at a proportion of 20% calcium peroxide and 80% sodium persulfate. This mixture is diluted to 30%, resulting in approximately 6% calcium peroxide and. 24% sodium persulfate in 70% water. The information also states that sodium hydroxide will be used at 1 to 5% with 30% sodium persulfate. North Carolina Public Health C Working For a heakhy Ever Everysafer Noah Carolina Everywhere. Everyday. body. Location: 5505 Six Forks Rd., 2nd Floor, Room 1-2-D1 •Raleigh, NC 276.09 AnEgtd Opprn�Enp4,, Page 2 of 9 NC DPH recommends that all persons that will come into contact with the above chemicals review the MSDS and other appropriate health and safety documents and have undergone appropriate health and safety training. NC DPH also recommends that transport of these chemicals off -site be controlled to prevent potential human or ecological impacts. Access to the area of application should be limited to workers applying the product. In order to minimize exposure to unprotected individuals, measures should be taken to prevent access to the area of application. SODIUM PERSULFATE HEALTH RISK INFORMATION: Formula: Na2S203 CASN: 7775-27-1 Synonyms: Sodium peroxydisulfate, Sodium persulfate Classification: strong oxidant Sodium persulfate is a strong oxidant and reacts with combustible and reducing materials. Sodium persulfate decomposes on heating producing toxic and corrosive fumes including sulfur oxides. It reacts violently with powdered metals and strong bases. In solution in water it is a weak acid. Sodium persulfate becomes unstable when exposed to heat, moisture and/or contamination. It is incompatible with acids, alkalis, halides (fluorides, chlorides, bromides and iodides), combustible materials, most metals and heavy metals, oxidizable materials, other oxidizers, reducing agents, cleaners, and organic or carbon containing compounds. Oxidizing chemicals, including sodium persulfate, should not be stored or directly mixed with combustible material (such as fuels, papers or solvents) or reducing agents (such as metals or sulfites). Contact with incompatible materials can result in a material decomposition or other uncontrolled reactions. Oxidizing chemicals may react energetically with combustible materials or reducing agents and also release oxygen and heat during decomposition that could help support a fire. Some oxidizing agents are incompatible with one another. Decomposing persulfates will evolve large volumes of gas and/or vapor, can accelerate exponentially with heat generation, and create significant and hazardous pressures if contained and not properly controlled or mitigated. Use with alcohols in the presence of water has been demonstrated to generate conditions that require rigorous adherence to process safety methods and standards to prevent escalation to an uncontrolled reaction. Potential health effects: The primary route of toxicity is through direct inhalation of airborne dust or mist, or direct contact. Airborne persulfate dust may be irritating to eyes, nose, lungs, throat and skin upon contact. Dust dispersion should be controlled. Sodium persulfate in identified as a strong oxidizer and an irritant. Inhalation of dust may cause asthma -like reactions. Acute (short-term) health effects that may occur immediately or shortly after exposure include severe skin and eye irritation and bums. Breathing sodium persulfate can irritate the nose, throat and lungs, causing coughing, wheezing and/or shortness of breath. Long-term (chronic) or repeated exposure may cause a skin allergy or dermatitis. If allergy develops, very low future exposure can cause itching and a skin rash. An asthma -like allergy may also result from long-term or repeated inhalation exposures with future exposure potentially causing asthma attacks with shortness of +� DMMenY U Location: 5505 Six Forks Rd., 2nd Floor, Room 1-2-DI • Raleigh, N.C. 27609 An Equal Opportunity Employer \, Page 3 of 9. breath, wheezing, cough, and/or chest tightness. General allergic reactions, like urticaria (hives) or shock, may occur. Sodium persulfate has not been tested for its ability to cause cancer or reproductive effects. Evidence of exposure includes: Inhalation: cough, labored breathing, sore throat, wheezing Skin: redness, pain Eyes: redness, pain Ingestion: diarrhea, nausea, sore throat, vomiting 'Recommended personal protective equipment (PPE): Prevent release of dust into the work environment with room ventilation. All persons working with sodium persulfate should use appropriate PPE, including: Eves and face: Use cup type chemical goggles. Full face shield may be used. Respiratory: Use approved dust respirator when airborne dust is expected. A NIOSH 100 HEPA tight -fitting half -face unit is recommended (with fit testing). Protective clothing: Normal work clothes. Rubber or neoprene footwear. Gloves: Rubber or neoprene gloves. Thoroughly wash the outside of gloves with soap and water prior to removal. Inspect regularly for leaks. First Aid: Eye contact: Immediately flush with large amounts of water for at least 15 minutes, occasionally lifting upper and lower lids. Seek medical attention immediately. Skin Contact: Quickly remove contaminated clothing. Immediately wash contaminated skin with large amounts of soap and water. Breathing: Remove the person from exposure. Begin rescue breathing (using universal precautions) if breathing has stopped and CPR if heart action has stopped. Transfer promptly to a medical facility. Additional safety recommendations: Prevent release of dust into the work environment with room ventilation. Workers whose clothing has been contaminated with sodium persulfate should change into clean clothing promptly. On skin contact immediately wash or shower to remove the chemical. Remove contaminated clothing immediately and wash before reuse. At the end of the work shift, wash any areas of the body that may have contacted sodium persulfate, whether or not known skin contact has occurred. Do not take contaminated work clothes home to prevent exposure of family members. Contaminated work clothes should be laundered by individuals who have been informed of the hazards of exposure to sodium persulfate. Eye wash fountains should be provided in the immediate work area for emergency use. If there is the possibility of skin exposure, emergency shower facilities should be provided. Do not eat, smoke, or drink where sodium persulfate is handled, processed, or stored, since the chemical can be swallowed. Wash hands carefully before eating, drinking, smoking, or using the toilet. Handling and storage: Use adequate ventilation when transferring product from bags or drums. Provide mechanical general and/or local exhaust ventilation to prevent release of �G 9h41oI o'I w x ' Location: 5505 Six Forks Rd., 2,dFloor, Room l-2-DI •Raleigh, N.C. 27609 An Equal Opportunity Employer Page 4 of 9 dust into work environment. Spills should be collected into suitable containers to prevent dispersion into .the air. Wear respiratory protection if ventilation is inadequate or not available. Use eye and skin protection. Use clean plastic or stainless steel scoops only. Store (unopened) in a cool, clean, dry place away from point sources of heat, e.g. radiant heaters or steam pipes. In case of fire or decomposition (fuming/smoking) deluge with plenty of water to control decomposition. Use a vacuum or a wet method to reduce dust during clean-up. DO NOT DRY SWEEP. CALCIUM PEROXIDE HEALTH RISK INFORMATION: Formula: Ca02 CASN: 1305-79-9 Synonyms: calcium dioxide, calcium superoxide, Calper, Calper G Classification: oxidizer Calcium. peroxide is an oxidizer, thus contact with combustible materials (paper, cotton, organics, leather, reducing agents, and other oxidizers) should be avoided. Calcium peroxide is not flammable but will contribute oxygen to feed a fire. Contamination, heat, and humid conditions will enhance and accelerate decomposition. Decomposition is endothermic, unlike most oxidizers. Store calcium peroxide in a clean, dry place. Do not expose to heat sources or high humidity. Store away from combustible materials. Keep containers closed when not in use. Dilute spills with water. Potential health effects: Contact can severely irritate and burn the skin and eyes with possible eye damage -Breathing calcium peroxide can irritate the nose, throat and lungs causing coughing, wheezing and/or shortness of breath. Harmful if swallowed. The following acute (short-term) health effects may occur immediately or shortly after exposure. Contact can severely irritate and burn the skin and eyes with possible eye damage. Breathing calcium peroxide can irritate the nose, throat and lungs causing coughing, wheezing and/or shortness of breath. Chronic (long-term) health effects can occur at some time after exposure and can last for months or years and include lung . irritation. Repeated exposure may cause bronchitis with. cough, phlegm, and/or shortness of breadth. Calcium peroxide has not been tested for its ability to cause cancer or reproductive effects. Calcium peroxide should be handled in well ventilated, dust controlled areas. When handling large quantities, use a dust mask, goggles, and gloves. Evidence of exposure includes: Inhalation: nose and throat irritation Skin: irritation Eyes: irritation Ingestion: irritation of mouth and stomach Recommended personal protective equipment (PPE): Avoid skin contact with calcium peroxide. Eyes and face: Wear chemical safety goggles. Wear a face shield along with goggles when working with corrosive, highly irritating or toxic substances. ��Olr4ioo' . Location: 5505 Six Forks Rd., 2°1 Floor, Room 1-2-DI • Raleigh, N.C. 27609 G An Equal Opportunity Employer �r Page 5 of 9 Respiratory: Use NIOSH certified toxic dust respirator. A NIOSH 100 HEPA tight- fitting half -face unit is recommended (with fit testing). Protective clothing: Wear protective gloves and full cover clothing All protective clothing (suits, gloves, footwear, headgear) should be clean, available each day, and put on before work. First Aid: Eyes: Immediately flush with water for at'least 15-30 minutes, lifting the upper and lower eyelids intermittently. See a medical doctor or ophthalmologist immediately. Skin: Remove contaminated clothing. Wash with plenty of soap and water. Get medical attention if irritation occurs and persists. Ingestion: If conscious rinse mouth with water. Dilute by giving 1 or 2 glasses of water or milk. Do not induce vomiting. See a medical doctor immediately. Inhalation: Remove to fresh air. If breathing difficulty or discomfort occurs and persists, obtain medical attention. Additional safety recommendations: Workers whose clothing has been contaminated by calcium peroxide should change into clean clothing promptly. Do not take contaminated work clothes home. Family members could be exposed. Contaminated work clothes should be laundered by individuals who have been informed of the hazards of exposure to calcium peroxide. Eyewash fountains should be provided in the immediate work area for emergency use. If there is the possibility of skin exposure, emergency shower facilities should be provided. On skin contact with calcium peroxide, immediately wash or shower to remove the . chemical. Do not. eat, smoke, or drink where calcium peroxide is handled, processed, or stored, since the chemical can be swallowed. Wash hands carefully before eating, drinking, smoking, or using the toilet. Use a vacuum or a wet method to reduce dust during clean-up. DO NOT DRY SWEEP. Handling and storage: Calcium peroxide must be stored to avoid contact with combustibles; hydrocarbons; fuels; cellulose; hydrogen peroxide; and organic materials since fires may occur. Store in tightly closed containers in a cool, well -ventilated area. SODIUM HYDROXIDE HEALTH RISK INFORAMTION: Formula: NaOH CASN: 1310-73-2 Synonyms: Caustic soda, Lye, Soda lye, Sodium hydrate Classification: alkaline, corrosive Y� pivlUo� 0," Location: 5505 Six Forks Rd., 2"d Floor, Room 1-2-DI •Raleigh, N.C.27609 An Equal Opportunity Employer Page 6 of 9 Sodium hydroxide is classified as a corrosive material. Sodium hydroxide is incompatible with water, acids, flammable liquids, organic halogens, organic peroxides, metals such as aluminum, tin, zinc, or nitromethane. It is corrosive to metals. Keep this compound separated from acids, easily ignitable materials, explosives, metals, organic peroxides, and water or any moisture. Sodium hydroxide will react with water to release heat and contact with aluminum, tin, lead and zinc will release flammable and explosive hydrogen gas. Contact with nitromethane and other nitro compounds may result in the formation of shock -sensitive or -explosive salts. Contact with moisture or water may generate sufficient heat to ignite combustible substances. Potential health effects: Sodium hydroxide is a corrosive irritant of the skin, eyes, and mucous membranes. Sodium hydroxide both in solid and in solution has a markedly corrosive action upon all body tissues causing burns and frequently deep maceration, with ultimate scarring. Inhalation of the dust or concentrated mist can cause damage to the upper respiratory tract and to lung tissue, depending upon the severity of the exposure. Effects of inhalation may vary from mild irritation of the mucous membranes at 2 mg/m3 to severe pneumonitis at higher airborne concentrations. Inhalation of alkaline vapors can produce upper airway edema, respiratory failure, wheezing, pulmonary edema, and pneumonitis. Exposure to the dust or mist may cause pain, redness, irritation or full thickness burns. Contact with the eyes causes disintegration and sloughing -of conjunctival and corneal epithelium, corneal opacification (renders the cornea opaque), marked edema, and ulceration. Permanent visual loss may occur. After 7 to 13 days, either gradual recovery begins, or there is progression of ulceration and corneal opacification. On the skin, solutions of 25 to 50% sodium hydroxide cause a sensation of irritation within about 3 minutes; with 4% solutions, irritation does not develop for several hours. If it is not'removed. from the skin, severe burns with deep ulceration may occur. Produces severe abdominal pain, corrosion of the lips, mouth, tongue, esophagus, and pharynx, and the vomiting of large pieces of mucoua. It can cause perforation and scarring. Glottic edema and upper airway obstruction may occur following ingestion. Cases of squamous cell carcinoma of the esophagus have occurred with latent periods of 12 to 42 years after ingestion. These cancers were the sequelae of tissue destruction and possible scar formation, rather than due to a direct carcinogenic action of sodium hydroxide itself. The greatest industrial hazard is rapid tissue destruction of eyes or skin upon contact with either the solid or concentrated solutions. Acute (short-term exposure) health effects which may occur immediately or shortly after exposure include with contact severe irritation and burning the skin and eyes with possible eye damage or clouding of the eyes with loss of vision. Breathing sodium hydroxide can irritate the mouth, nose and throat. Breathing can also irritate the lungs causing coughing and/or shortness of breath. Higher exposures can cause a build-up of fluid in the lungs (pulmonary edema), a medical emergency, with severe shortness of breath. Chronic (long-term exposure) health effects can occur at some time after exposure to and can last for months or years. Very high chronic exposure may cause lung damage. Sodium hydroxide has not been tested for ability to cause cancer in animals. There is no evidence it .effects reproduction. Location: 5505 Six Forks Rol., 2"d Floor, Room 1-2-DI •Raleigh, N.C. 27609 An Equal Opportunity Employer Page 7 of 9 Evidence of exposure includes: Inhalation: irritation of mucous membranes, pneumonitis Skin: irritation, burns, temporary loss of hair Eyes: irritation, corneal damage Ingestion: irritation of mucous membranes, severe abdominal pain, corrosion of the lips, mouth, tongue, and pharynx, and the vomiting of large pieces of mucosa, upper airway obstruction may occur Workplace exposure limits: These exposure limits are for air levels only. OSHA: The legal airborne permissible exposure limit (PEL) is 2 mg/m3 averaged over an 8-hour work shift. NIOSH: The recommended airborne exposure limit is 2 mg/m3, which should not be exceeded at any time. The NIOSH IDLH value is 10 in in3. ACGIH: The recommended airborne exposure limit is 2 mg/m3, which should not be exceeded at any time. Recommended personal protective equipment (PPE): Appropriate, impervious, protective clothing (including gloves) should be worn to prevent skin contact. Protective equipment should not be made of aluminum, copper, soft iron, tin, or zinc (or alloys made of these metals. Eyes and face: For solid sodium hydroxide wear impact resistant eye protection with side shields or goggles. For liquids wear indirect -vent, impact and splash resistant goggles. A face shield along with goggles is recommended when working with corrosive, highly irritating or toxic substances. Contact lenses should not be worn when working with this substance. Eyewash fountains should be provided. Respiratory: Use NIOSH certified toxic dust respirator. A NIOSH 100 HEPA tight- fitting half -face unit is recommended (with fit testing). Where the potential exists for exposure over 2 mg/m3, use a MSHA/NIOSH approved supplied -air respirator with a full face piece operated in a pressure -demand or other positive -pressure mode. For increased protection use in combination with an auxiliary self-contained breathing apparatus operated in a pressure -demand or other positive -pressure mode. Exposure to 10 mg/m3 is immediately dangerous to life and health. If the possibility of exposure above 10 mg/m3 exists, use a MSHA/NIOSH approved self-contained breathing apparatus with a full face piece operated in a pressure -demand or other positive -pressure mode. Gloves: Impervious. ACGIH recommends polyvinyl chloride, butyl, butyl/neoprene, natural rubber, neoprene, polyethylene, Saranex, Teflon and Viton/neoprene as protective materials. First Aid: Eyes: Irrigate immediately Skin: Water flush immediately. Clothing which becomes significantly contaminated, or wet, should be removed as quickly as possible. Breathing: Respiratory support Ingestion: Medical attention immediately r Location: 5505 Six Forks Rd., 2nd Floor, Room 1-2-DI • Raleigh, N.C. 27609 �...•...•' An Equal Opportunity Employer Page 8 of 9 Handling and storage: Store in tightly closed containers in a cool, dry, well -ventilated area away from moisture. Wherever sodium hydroxide is used, handled, manufactured, or stored, use explosion -proof electrical equipment and fittings. Keep sodium hydroxide separated from acids, easily ignitable materials, explosives, metals, organic peroxides, and water (or any moisture). Additional safety recommendations: Workers whose clothing has been contaminated by sodium hydroxide should change into clean clothing promptly. Do not take contaminated work clothes home. Family members could be exposed. Contaminated work clothes should be laundered by individuals who have been informed of the hazards of exposure to sodium hydroxide. Eye wash fountains should be provided in the immediatework area for emergency use. If there is the possibility of skin exposure, emergency shower facilities should be provided. On skin contact sodium hydroxide, immediately wash or shower to remove the chemical. At the end of the work shift, wash any areas of the body that may have contacted sodium hydroxide, whether or not known skin contact has occurred. Do not eat, smoke, or drink where sodium hydroxide is handled, processed, or stored, since the chemical can be swallowed. Wash hands carefully before eating, drinking, smoking, or using the toilet. For solid sodium.hydroxide use a vacuum to reduce dust during clean-up. DO NOT DRY SWEEP. `��?�` Location: 5505 Six Forks Rd., 2"d Floor, Room 1-2-D1 • Raleigh, N.C. 27609 ' An Equal Opportunity Employer �rM Page 9 of 9 References: 1. International Chemical Safety Cards (ICSCs): International Programme on Chemical Safety. CDC, NIOSH. http•//www.cdc.gov/niosh/ipcs/idstart.html 2. New Jersey Department of Health and Senior Services Hazardous Substances Fact Sheets. 3. Sodium Persulfate MSDS. FMC MSDS no.: 7775-27-4, April 30, 2006, revision no. 12. FMC Corporation. 4. Calcium Peroxide Technical Data Sheet. FMC Corporation. 5. TOXNET Toxicology Data Network. US National Library of Medicine. htti):Htoxnet.nlm.nih.gov/ 6. Calcium Peroxide MSDS. FMC MSDS no.: 1305-79-9-1, April 30, 2006, revision no. 9. FMC Corporation. 7. Thomson MICROMEDEX. 8. NIOSH Pocket Guide to Chemical Hazards. CDC. 9. Technical and Regulatory Guidance for In Situ Chemical Oxidation of Contaminated Soil and Groundwater, Second Edition. The Interstate technology& Regulatory Council In Situ Chemical Oxidation Team. January 2005. http://www.itreweb.org/Documents/ISCO- 2.pdf Location: 5505 Six Forks Rd., 2„dFloor, Room 1-2-D] *Raleigh, N.C. 27609 An Equal Opportunity Employer AQUIFER PROTECTION SECTION APPLICATION REVIEW REQUEST FORM Date: June 2. 20 10 To: ® Landon Davidson, ARO-APS ❑ David May, WaRO-APS ❑ Art Barnhardt, FRO-APS ❑ Charlie Stehman, WiRO-APS ❑ Andrew Pitner, MRO-APS ❑ Sherri Knight, W-SRO-APS ❑ Jay Zimmerman, RRO-APS From: Michael Rogers Groundwater Protection Unit Telephone: (919) 715-6166 Fax: (919) 715-0588 E-Mail: Michael.RogersAncmail.net A. Permit Number: WI 0100098 B. Owner: National Park Service -Blue Ridge Pkwy. C. Facility/Operation: ❑ Proposed ® Existing ❑ Facility ❑ Operation D. Application: 1. Permit Type: ❑ Animal ❑ SFR-Surface Irrigation❑ Reuse ❑ H-R Infiltration ❑ Recycle ❑ I/E Lagoon ❑ GW Remediation (ND) ® UIC — 5I Groundwater Remediation Well For Residuals: ❑ Land App. ❑ D&M ❑ Surface Disposal ❑ 503 ❑ 503 Exempt ❑ Animal 2. Project Type: ® New ❑ Ma;or Mod. ❑ Minor Mod. ❑ Renewal ❑ Renewal w/ Mod. E. Comments/Other Information: ❑ I would like to accompany you on a site visit. NOTE: Attached, you will find all information submitted in support of the above -referenced application for your review, comment, and/or action. Within, please take the following actions: ® Return a Completed APSARR Form and attach laboratory analytical results, if applicable. ❑ Attach Well Construction Data Sheet. ❑ Attach Attachment B for Certification by the LAPCU. ❑ Issue an Attachment B Certification from the RO.* * Remember that you will be responsible for coordinating site visits and reviews, as well as additional information requests with other RO-APS representatives in order to prepare a complete Attachment B for certification. Refer to the RPP SOP for additional detail. When you receive this request form, please write your name and dates in the spaces below, make a copy of this sheet, and return it to the appropriate Central Office -Aquifer Protection Section contact person listed above. RO-APS Reviewer: Date: FORM: APSARR 07/06 Page 1 of 1 NCDENR North Carolina Department of Environment and Natural Resources Division of Water Quality Beverly Eaves Perdue Coleen H. Sullins Dee Freeman. Governor Director Secretary September 22, 2010 Philip A. Francis, Jr., Superintendent. National Park Service - Blue Ridge Pkwy 199 Hemphill Knob Rd. Asheville, NC 28803 Ref: Issuance of Injection Permit WI0100098 Former Pisgah Inn Gas Station Dear Mr. Francis: In accordance with the renewal application received on May 24, 2010, we are forwarding permit number WI0100098. This permit is to inject Oxygen Biochem (OBC) at the Former Pisgah Inn Gas Station facility located at Mile Post 408, Blue Ridge Pkwy., Waynesville, Haywood County, NC 28716. This permit shall be effective from the date of issuance until August 31, 2012, and shall be subject to the conditions and limitations stated therein, including the requirement to submit a final project evaluation as stated in PART V11— MONITORING AND REPORTING REQUIREMENTS. Please read the entire permit to ensure that you are aware of all compliance requirements of the permit. You will need to notify this office and the Asheville Regional Office by telephone 48 hours prior to initiation of operation of the facility. In order to continue uninterrupted legal use of the injection facility for the stated purpose, you must submit an. application to renew the permit 120 days prior to its expiration date. Please contact me at 919-715-6166 or Michael.Rogers(d,ncdenr. og_v if you have any questions about your permit. Best tRRe rds, Michael Rogers; P.G.-(NC & FL) Environmental Specialist Underground Injection Control Program cc: Landon Davidson - Asheville Regional Office Judd Mahan —Mountain Environmental Group WI0100098 Permit File Mike Streeter - Division of Waste Management AQUIFER PROTECTION SECTION 1636 Mail Service Center, Raleigh, North Carolina 27699-1636 Location: 2728 Capital Boulevard, Raleigh, North Carolina 27604 Phone: 919-733-3221 l FAX 1: 919-715-0588; FAX 2: 919-715-60481 Customer Service: 1-877-623-6748 Internet: www.ncwaterouality.org �7On�.- lti! o,.e.rt1Ca3 ohna An Equal Opportunity 1 Affirmative Action Employer