WI0100126_Complete File - Historical_20101029

State of North Carolina
Department of Environment and Natural Resources
Division of Water Quality
APPLICATION FOR PERMIT TO CONSTRUCT AND/OR USE A WELL(S) FOR INJECTION
Type 5I Wells — In Situ Groundwater Remediation / Type 5T Wells — Tracer 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): ��(�� V D I d� co
I. GENERAL INFORMATION:
1. Applicant's Name (generally the responsible party): Davidson River Village, LLC
2. Signing Official's Name: John B. Hanselman Title: Member
3. Mailing address of applicant: 36 Washington Street, Suite 220
City: Wellesley State: MA Zip: 02481
CD
=_
Telephone number: 781-431-8101 ext 104 Fax number: 781-431-8105
-
4. Property Owner's Name (if different from Applicant): John B. Hanselman 4 c
5. Property Owner's mailing address: Same as above
City:
State: Zip: Ul
6. Name and address of contact.person who can answer questions about the proposed injection project:
Name: Amar C. Bumb, Ph.D., PE Title: Principal Engineer/Hydrogeologisi
Company: Shaw Environmental & Infrastructure, Inc.
Address: 3 Indapcndence Pointe, Suite 107
City: Greenville
State: SC Zip; 29615
Telephone number: 864-?89-8533 Fax number: 864-254-9286
Email Address: [e-mail]
if. PERMIT INFORMATION:
1. Project is: © New ❑ 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, till out sections I & 11 only, sign the certification on the last page of this
form, and obtain the property owner's signature to indicate consent (if the applicant is not the owner).
For all renewals, you must submit a status report including monitoring results of all injection activities to
date.
Revised 8/07 UIC-5I/5T Page 1 of 7

S
APPLICATION FOR PERMIT TO CONSTRUCT AND/OR USE A WELL(S) FOR INJECTION
Type 51 Wells —In Situ Groundwater Remediation / Type 5T Wells — Tracer Injection
III. INCIDENT & FACILITY DATA
A. FACILITY INFORMATION
1. Facility name: Former Ecusta Paper Mill -- Building 7 Area
2. Complete physical address of the facility:
1 Ecusta Road
91
C.
City: Brevard County: Transylvania State: NC Zip: 28712
INCIDENT DESCRIPTION
1. Describe the source of the contamination:
Building-7 was a former solvent recovery area. Shaw collected TCRA slab investigation composite samples from
under the Solvent Recovery Slab and were analyzed using the XRF and was below all SRGs. The PID had hits
of 79 ppm when put down next to some dark soil on the southeast corner. Lab results showed 278 ppm of
acetone and 560 ppm of toluene. A TCRA request was submitted and approved to remove the impacted soil.
Shaw excavated 10 cubic yards of impacted soil from the hotspot located in the south east comer of building 7.
It appears that this area was a large sump that drained all of Building 7. Once sample was collected from each
of the sidewalls and the floor and sent to the laboratory for analysis. The confirmation samples showed the
remaining soil to be below the SRGs.
2. List all contaminants present in soils or groundwater at the site (contaminants may be listed in groups, e.g.,
gasoline, diesel, jet fuel, fuel oil, chlorinated ethenes, chlorinated ethanes, metals, pesticides/herbicides, etc):
Chlorinated ethenes - PCE and daughter products
3. Has LNAPL or DNAPL ever been observed at the site (even if outside the injection zone)?
❑ Yes If yes, list maximum measured separate phase thickness feet
© No If no, list maximum concentration of total VOCs observed at site. PCE/TCE - 59.3 ppb
4. Agency managing the contamination incident:
❑ UST Section ❑x Superfund Section (including REC Program and DSCA sites)
❑ DWQ Aquifer Protection Section ❑ Solid Waste Section
❑ Hazardous Waste Section ❑x Other: US EPA Region 4, Jennifer Wendell, RPM
5. Incident managers naive James Bateson
and phone number 919-508-8449
6. Incident number or other site number assigned by the agency managing the contamination incident:
No incident number has been assigned
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: NCDO03166675
2. DWQ Non -Discharge or NPDES pennits: NPDES 0000078
3. County or DEH subsurface wastewater disposal pen -nits:
4. Other environmental permits required by state or federal law:
Revised 8/07
UIC-5I/5T
Page 2 of 7

APPLICATION FOR PERMIT TO CONSTRUCT AND/OR USE A WELL(S) FOR INJECTION
Type 51 WeIs —In Situ Groundwater Remediation / Type 5T Wells — Tracer Injection
IV. INJECTION DATA
A. INJECTION FLUID DATA
1. List all proposed injectants.
NOTE: Any substance to be injected as a tracer or to promote in situ remediation must be reviewed by the
Occupational and Environmental Epidemiology Section (OEES) of the Division of Public Health, Department of
Health and Human Services. Review the list of approved injectantsT or contact the UIC Program to determine if
the injectants you are proposing have been reviewed by OEES
Injectant: ABC lactate/Fatty Acid (from RedoxTech) or 3-D Microemulsion from Regenesis
Concentration at point of injection: 5 to 20 weight percent slurry
Injectant: Sodium bicarbonate
Concentration at point of injection: Ibs per linear ft of screened interval
Injectant: SDC-9 from Shaw (also marketed as BAC-9 by EOS and RTB-1 by RedoxTech)
Concentration at point of injection: — 0.08 liters/ft of screened interval
Concentration at point of injection:,
Injectant:
Concentration at point of injection:
2. Source of fluids used to dilute or chase the injectants listed above:
❑ None
x❑ Municipal water supply
❑ Groundwater from private well or any well within % mile of injection site
❑ Air
❑ Other:
3. If any well within % mile of injection site, a private well, or surface water is to be used as the fluid source, supply
the following information:
a. Location/ID number of source: Not Applicable
b. Depth of
c. i ormation:
d. Rock/Sediment
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 cis 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 forn2
GWRS.
Revised 8/07 UIC-5I/5T Page 3 of 7

APPLICATION FOR PERMIT TO CONSTRUCT AND/OR USE A WELL(S) FOR INJECTION
Type 51 Wells — In Situ Groundwater Remediation / Type 5T Wells — Tracer Injection
B. PROPOSED OPERATING PARAMETERS
1. Duration of Injection:
Maximum number of separate injection events: 2
Expected duration of each injection event:15 days
Expected duration between events (if more than one event): 6 to 12 months
2. Injection rate per well: 5•0 gallons per minute (gpm)
3. Total Injection volume: 500 (max per pt) gallons per day (gpd); 10,000 gallons per event (if separate events)
4. Injection pressure: 20 pounds/square inch (psi)
5. Temperature at point of injection: 70 OF
6. Briefly describe how the above narameters will be measured and controlled:
Flow meter and pressure gauge will be used.
7. Estimated hydraulic capacity of the well: 10 (short term) gpm
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.
❑x Proposed well(s) to be constructed for use as an injection well. Provide the data in (2) through (6) below as
proposed construction specifications.
2. Well Drilling Contractor's Name: ESN Southeast
NC Well Contractor Certification number: Allen Merril - NC2004
3. Date to be constructed: November 2010 Number of borings: 40 (max)
Approximate depth of each boring (feet): 14 'f I� ✓liyl tY
4. Screened interval/Injection interval of injection wells:
Depth: 5 to 15 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 9 Other: Direct -push rods
Casing depth: to ft.
6. Grout (N/A if injection is through direct push rods):
Type: ❑ Cement ❑ Bentonite ❑x Other: Direct -push Rods
Grout depth: to ft.
Revised 8/07 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 attachments with the given headings:
A. SITE HISTORY
Provide a brief description of the site history including:
(1) site usage historically and present,
(2) origin of the contamination,
(3) previous remedial action(s).
NOTE: G.S. 89E-18 requires that any geologic plans, reports, or documents in which the performance is related to the
public welfare or safeguarding of the environment be prepared by a licensed geologist or subordinate under his or her
direction. G.S. 89E-13 requires that all drawings, reports, or documents involving geologic work which shall have been
prepared or approved by a licensed geologist or a subordinate under his or her direction be signed and sealed by him or
her.
B. HYDROGEOLOGIC DESCRIPTION
Provide a hydrogeologic description, soils description, and cross section of the subsurface to a depth that includes the
known orprojected 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 % mile of the injection site is used as the source
well, include chemical analysis of source fluid here.
D. INJECTION RATIONALE
Attach a brief description of the rationale for selecting the injectants and concentrations proposed for injection, including:
(1) goals of the injection project;
(2) a description of the reactions between the injectants and the contaminants present including specific breakdown
products or intermediate compounds that may be formed by the injection; and
(3) summary results of modeling or testing performed to investigate the injectant's potential or susceptibility to change
(biological, chemical or physical) in the subsurface.
E. INJECTION PROCEDURE AND EQUIPMENT
Provide a detailed description of all planned activities related to the proposed injection including but not limited to:
(1) construction plans and materials;
(2) operation procedures;
(3) a detailed diagram of the surface and subsurface portions of the system; and
(4) a planned injection schedule.
F. MONITORING PLAN
Provide a plan for monitoring the results of the injection, including:
(1) a list of existing and proposed monitoring wells to be used;
(2) a 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 f uids outside the injection area or zone. The monitoring parameters should include the target
contaminants as well as secondary or intermediate contaminants which may result fr•arn the injection and other
parameters which may serve to indicate the progress of the intended reactions, such as pH, ORP, dissolved oxygen, and
Revised 8107 UIC-5I/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
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'/ mile of the injection well or well system;
e. all surface water bodies within '/a mile of the injection well or well system; and
f. all existing or abandoned wells within % 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.
(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
Revised 8/07 UIC-51/5T Page 6 of 7

VI.
APPLICATION FOR PERMIT TO CONSTRUCT AND/OR USE A WELL(S) FOR INJECTION
Type 51 Wells —In Situ Groundwater Remediation / Type 5T Wells — Tracer Injection
CERTIFICATION
I, John B. Hanselraglaed name of signing official) , hereby certify under penalty of law that
I have personally examined and am familiar with the information submitted in this document and all attachments
thereto and that, based on my inquiry of those individuals immediately responsible for obtaining said information,
I believe that the information is true, accurate and complete. I am aware that there are significant penalties,
including the possibility of fines and imprisonment, for submitting false information. I agree to construct,
operate, maintain, repair, and if applicable, abandon the injection well(&) and all related appurtenances in
accordance with th roved spec' do d conditions of the Permit.
26110
4h
Signature: Date:
Title: Member
If authorized agent is acting on behalf of the applicant, supply a letter signed by the applicant authorizing the
above agent.
VU CONSENT OF PROPERTY OWNER (if the property is not owned by the applicant)
("Owner" means any person who holds the fee or other properly rights in the well being constructed. A well is
realproperty and its construction on land shall be deemed to vest ownership in the land owner, in the absence of
contrary agreement in writing.)
I, John B. HanseirMlItd name of oroyeriy owner) , as owner of the property on which the
injection wcll(s) are to be constructed and operated, hereby consent to allow the applicant to construct each
injection well as outlined in this application and agree that it shall be the responsibility of the applicant to ensure
that the injection wv4-(s) conform to d* Well Construction Standards (Title 15A NCAC 2C .0200)
fa z� iG
eL_-�' Date:
:mbe
Submit TWO copies of the completed application package, including all attachments, to:-
N>
UIC Program
Aquifer Protection Section=
�-;
North Carolina DENR DWQ .--_• _
1636 Mail Service Center
Raleigh, NC 27699-1636 �t�N
CTJ
Telephone [phone]
Revised 8107 UIC-51/5T Page 7 of 7

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V. ATTACHMENTS
REFERENCES
North Carolina Department of Environment and Natural Resources, 2007, Guidelines for Assessment
and Cleanup, Inactive Hazardous Sites Program, August.
Shaw Environmental Inc., 2007, Phase HEnvironmental Site Assessment, Ecusta Paper Mill, Pisgah
Forest, North Carolina. June 22.
Shaw Environmental Inc., 2008a, Field Sampling Plan, Ecusta Paper Mill, Pisgah Forest, North
Carolina. Rev 1, August.
Shaw Environmental Inc., 2008b, Quality Assurance Project Plan, Ecusta Paper Mill, Pisgah Forest,
North Carolina. Rev 1, August.
Shaw Environmental Inc., 2008c, Site -Specific Health and Safety Plan for Remediation Activities,
Former Ecusta Paper Mill, Pisgah Forest, North Carolina. May.
Shaw Environmental Inc., 2009e, Aquifer pump Test Work Plan, Former Ecusta Paper Mill, Pisgah
Forest, North Carolina. February.
A. SITE HISTORY
The property was first developed in 1938 as a paper manufacturing plant by Ecusta Paper Company
(Figure 1). In 1949, Olin Industries acquired the facility. Cigarette papers were the only products
manufactured at the facility until the mid- 1950's when cellophane and rayon production was added
with the construction of the film plant. In 1958, printing and lightweight paper production
capabilities were added. A wastewater treatment plant was put into service in 1974, followed by the
installation of the sludge landfill and the ASB in 1976. In 1985, in conjunction with the purchase of
the property by a corporation of former Olin employees, cellophane and rayon production was
discontinued. In 1987, P.H. Glatfelter Company purchased the property which operated the business
until 2001 when PURICO (IOM) Limited purchased the facility, former RFS Ecusta. In 2002, RFS
Ecusta declared bankruptcy and all production ceased. In late 2003, The Ecusta Business
Development Corporation, LLC (EBDC) acquired the facility. Limited production of flax pulp
resumed on site while some of the buildings and warehouse facilities were leased for use by local
UIC Attachments -Bldg 7

businesses. In January 2008, DRV purchased the property from EBDC and demolition activities
started in summer 2008.
Building 7 was a former solvent recovery area. Shaw collected Time Critical Removal Action
(TCRA) slab investigation composite samples from under the Solvent Recovery Slab and were
analyzed using the XRF and were below the applicable SRGs. Initial screening with a PID showed
hits of 79 ppm when put down next to some dark soil on the southeast corner. Lab results showed
278 ppm of acetone and 560 ppm of toluene. A TCRA request was submitted and approved to
remove the impacted soil. Shaw excavated approximately 10 cubic yards of impacted soil from the
hotspot located in the south east corner of building 7. It appears that this area was a large sump that
was from all of building 7. One sample was collected from each of the sidewalls and the floor and
sent to the laboratory for analysis. The confirmation samples showed the remaining soil to be below
the SRGs.
Based on soil contamination detected during slab removal and historical groundwater contamination
detected at MW-7, monitoring wells MW-40, MW-41, and MW-42 were installed and sampled on a
quarterly basis for metals, VOCs, and SVOCs (Figure 2). The quarterly groundwater analytical
results for detected analytes for the monitoring wells are presented in Table 1. Other than the
naturally occurring iron and manganese, tetrachloroethene (PCE), trichloroethene (TCE), and
naphthalene were the only organic analytes that exceeded groundwater 2L standards. PCE and TCE
were detected in MW-7 and naphthalene was detected in MW-42.
The center of the groundwater VOCs concentrations appears to be located at monitoring well MW-7.
VOCs were not detected at MW-7 in January 2007; however in June 2009, PCE was detected at 5.1
µg/L, above the groundwater 2L standard of 0.7 µg/L at MW-7. PCE concentrations increased to
25.8 µg/L in October 2009 and to 52.2 µg/L in March 2010 before decreasing to 14 µg/L in August
2010. TCE, a daughter product of PCE, was also detected at MW-7 in October 2009 (2.2 µg/L),
March 2010 (3.0 µg/L), and August 2010 (2.6 µg/L). The only other analyte detected above the
groundwater 2L standard was naphthalene at MW-42 in January 2010 (67.8 µg/L) and March 2010
(153 µg/L). Naphthalene concentration at MW-42 in the latest quarterly sampling event in August
2010 was 12.4 µg/L, which is below the groundwater 2L standard. In June 2009 the total VOCs
concentrations in MW-7 were 5.1 µg/L, increased to 33.2 µg/L in October 2009, and further
increased to 59.3 µg/L in March 2010. Currently the VOCs concentrations in MW-7 is 16.6 µg/L in
the most recent sampling in August 2010.
UIC Attachments -Bldg 7

With USEPA and NCDENR approval, Shaw conducted an additional soil and groundwater
investigation in the area of Building 6 and 7 in April 2010 using direct push technology (DPT) to
delineate aerial extent of the chlorinated solvents in the vicinity of monitoring well MW-7. A direct
push rig was used to collect 13 groundwater samples (B7-DPT-01 through B7-DPT-13) and soil
samples from 3 soil borings (B7-DPT-07, B7-DPT-07, and B7-DPT-14) at a depth of 6 to 7 feet
below grade on April 14-15, 2010. The direct push soil boring and groundwater sampling locations
are shown on Figure 2. PID readings for the borings are in Table 2. No VOCs were detected in any
of three soil samples collected.
The DPT groundwater borings were installed to the confining clay at approximately 15 feet below
grade at each location and groundwater was pumped through a 4-foot screen and submitted for VOCs
analysis. Only two analytes were detected in 13 groundwater samples: p-isopropyltoluene (1.7 µg/L)
at B7-DPT-02 and naphthalene (1.2 µg/L) at B7-DPT-11. Both of these results were below the
respective NCAC 2L Standards.
B. IIYDROGEOLOGIC DESCRIPTION
The subject site is located in the Blue Ridge geologic province adjacent to the Brevard fault zone.
The Brevard fault zone is a linear, southeast -dipping thrust fault that forms the boundary between the
Inner Piedmont geologic belt to the southeast and the Blue Ridge geologic belt to the northwest. The
geology in the vicinity of the site consists of moderate to high grade metamorphic rocks of middle to
late Proterozoic age. The rock units include meta -sedimentary and meta -igneous rocks, including
gneisses, amphibolites, metagabbros, and quartzite schist. According to the Geologic Map of North
Carolina (NCGS, 1985), the site is located within the Brevard fault zone which is characterized by
mylonitic and cataclastic rocks.
The general geologic stratigraphy, based on soil borings and monitoring wells that have been
completed at the building 7 area, is shown on Geologic Cross Section Location Map Figure 3 and
the Cross Section in Figure 4. This cross section provides a general representation of the subsurface
conditions below the area of building 7 which includes monitoring wells MW-7 and MW-40 through
MW-42. In general, a gravelly sand is present from ground surface to 5 feet bgs which is underlain
by a silty clay down to approximately 5 to 13 feet bgs. A silty clay to a greenish gray clay (saprolite)
is present from 13 feet bgs down to weathered rock at the bottom of the borings. Boring and Well
Construction logs from the Building 7 area are presented in Appendix A.
UIC Attachments -Bldg 7

The hydrogeologic setting in the area consists of a vadose or unsaturated zone within the alluvium
above the groundwater table. The groundwater table lies within the alluvium and is recharged by
infiltrating precipitation. The groundwater in the shallow water table aquifer moves horizontally
until it discharges into surface waters. The surface of the water table is typically a subdued replica of
the topographic surface and is generally near the ground surface in streams/valleys (discharge areas)
and is somewhat deeper beneath ridges and hills (recharge areas). Specifically, at the mill it is
expected that shallow groundwater moves under relatively flat gradients with eventual discharge to
the Davidson River.
The occurrence and movement of groundwater in the Inner Piedmont and Blue Ridge provinces is
generally within two separate, but interconnected, water bearing zones. A shallow water -bearing
zone occurs within the saprolite zone, and a deeper zone occurs within the underlying bedrock.
Groundwater in the shallow saprolite zone occurs in the interstitial pore space of the saprolite. The
depth to groundwater in the saprolitic zone can range from 20 to more than 50 feet along ridges and
upland areas. In low lying stream valleys, the groundwater level will approach the local surface water
elevations in stream channels. Groundwater flow in this zone is typically governed by water table
conditions. This means that groundwater will flow under unconfined conditions and generally mimic
the surface topography as modified by highly permeable bedding for underground utilities.
Therefore, groundwater movement will be from upland areas (recharge zones) to nearby surface
streams (discharge zones).
The occurrence and movement of groundwater in the deeper water -bearing zone within crystalline
bedrock is controlled by secondary joints, fractures, and faults within the bedrock. Groundwater
within the bedrock zone may be under confined or unconfined conditions. The occurrence and
movement of groundwater is difficult to predict on a small scale due to the erratic nature of the
secondary openings that control groundwater flow in bedrock. Small surface water features generally
do not provide an accurate indication of the direction of groundwater movement in bedrock.
However, on a regional scale, the direction of groundwater movement will generally be from upland
areas (North) to major surface streams downgradient (South).
Shaw personnel gauged building 7 area shallow monitoring welts MW-7 and MW-40 through MW-
42 on July 26, 2010 for groundwater elevatioA able ' . The groundwater potentiometric surface
for the most recent sampling event August 2010 is illustrated on Figure 5. The groundwater
potentiometric surface map indicated that groundwater flowed generally toward the east at an
average hy-lrauiliclgradireVz ■; /2rin,.the vicinity of monitoring well MW-7.
UIC Attachments -Bldg 7

Aquifer Tests
Aquifer tests (slug tests) were conducted at the former Ecusta Mill site from February 24, 2009
through March 6, 2009 in the Caustic Area and from March 29, 2010 to April 1, 2010 at the
Electrochemical Building (approximately 1,500 ft from the former Building 7). Rising and falling
head slug tests were performed by placing a LevelTrollTM 700 pressure transducer/datalogger in the
monitoring well and recording background water levels until the water level in the well stabilized.
Slug test data (both falling head and rising head tests) were analyzed to determine hydraulic
conductivity values. Slug test analysis results for the Caustic Area are summarized in Table 4 and
for the Electrochemical Building are summarized in Table 5. The data analysis was performed with
the aid of AQTESOLVTM software using the the Hyder et al. (1994) solution, also known as the KGS
Model for slug tests in a partially penetrating well in an unconfined aquifer.
The hydraulic conductivity for the gravelly clayey sand (above the first clay layer— zone of interest
at Building 7) ranged from 1.05 x 10-4 centimeters per second (cm/sec) (0.30 feet per day [ft/day])
to 1.78 x 10-3 cm/sec (5.05 ft/day) with a geometric mean value of 8.77 x 10-4 cm/se r .._ fft/d� ).
The geometric mean value of hydraulic conductivity for the clay layer was 1.28 x 10-6 cm/sec (3.63
x 10-3 ft/day).
The hydraulic conductivity for the shallow wells ranged from 1.69 x 10-5 cm/sec (0.048 ft/day) to
1.46 x 10-2 cm/sec (41.4 ft/day) with a geometric mean value of 6.53 x 104 cm/sec (1.85 ft/day).
Higher values of hydraulic conductivities were obtained in areas where soils were disturbed during
removal of footings. The hydraulic conductivity variation in undisturbed soils below the
Electrochemical Building range from 1.97 x 10-4 cm/sec (0.56 ft/day) to 1.31 x 10-3 cm/sec (3.71
ft/day).
Groundwater Flow Rate
Groundwater flow rate (VGW) was calculated using the equation:
VGw=KI/Ae
Where "K" is the hydraulic conductivity, "I" is the hydraulic gradient, and ee is the effective porosity.
Using effective porosity value of 20 percent, average hydraulic gradient of 0.010 ft/ft, and geometric
mean value of hydraulic conductivity for the caustic area, the groundwater velocity in the shallow
zone was calculated to be 45.5 feet per year (ft/yr). When geometric mean value of hydraulic
UIC Attachments -Bldg 7

conductivity for the Electrochemical Building was used, the groundwater velocity in the shallow
zone was calculated to be 33.8 ft/yr. Therefore, the range of groundwater flow rate at Building 7 is
estimated to be 33.8 to 45.5 ft/yr.
C. INJECTION FLUID COMPOSITION
The PCE/TCE plume would be treated in situ by injecting ABC- lactate/fatty acid or 3-D
Microemulsion (3DMe) as electron donor, sodium bicarbonate as pH -buffer, and Shaw
dechlorinating culture (SDC)-9T11, a dechlorinating microbial consortium specifically cultured to
degrade chlorinated solvents. The Material Safety Data Sheets (MSDSs) for all injection reagents
are included in Appendix B.
ABC', lactate/fatty acid is a product of RedoxTech, 3DMe is a product of Regenesis, SDC-9TM a
product of Shaw Environmental (also marketed as BAC-9 by EOS Remediation and RTB-1 by
RedoxTech), and sodium bicarbonate are NCDENR approved additives for enhanced bioremediation
for chlorinated solvents in groundwater.
D. INJECTION RATIONALE
The purpose of this corrective action is to meet the requirements as described in the 5A NCAC 02L
regulations, commonly known as the Groundwater 2L Standards, which require groundwater
chlorinated solvent concentrations to be at 0.7 ug/L for PCE and 2.8 ug/L for TCE. All other
chlorinated solvent constituents are currently below the Groundwater 2L Standards.
The Total VOCs Isoconcentration Map from the sampling event in March 2010 is illustrated on
Figure 6 which shows the maximum VOCs concentration for the building 7 area. The objective of
the remediation of the building 7 area groundwater is to supply electrons and maintain anaerobic
subsurface environment where dechlorinating microbial consortium will sequentially degrade PCE
and TCE to ethene and water. In order to maintain optimal pH conditions for microbial growth and
activity, sodium bicarbonate would be used as pH -buffer.
The reagents and SDC-9TM would be injected in approximately 8 feet of saturated zone, with a total
injection depth of 12 to 15 ft bgs. Based on Shaw's experience at numerous sites and injection
spacing of 15 ft, it is estimated that approximately 12 lbs per foot of injection interval (lbs/ft) of
ABC, or 3DMe, 3 lbs/ft of sodium bicarbonate, and 0.072 liters per foot of SDC-9TM would be
UIC Attachments -Bldg 7

required. The total amount of chemical injected at each well would include 96 lbs of ABC'
lactate/fatty acid or 3DMe, 241bs of sodium bicarbonate, and 0.6 liters of SDC-9T"'
E. INJECTION PROCEDURE AND EQUIPMENT
Enhanced bioremediation reagents are typically applied using direct injection techniques.
Grid Injection Layout
The groundwater in the area of building 7 where the PCE and TCE in groundwater are higher than
the Groundwater 21, Standards will be treated by means of injecting 3.7 gallons of 3DMe in 80
gallons of water in each of the injection points into the groundwater. The radius of influence for
injection is estimated to be approximately 10 to 15 feet based on the average hydraulic conductivity
of shallow gravelly clayey sand zone is 8.77 x 10-4 cm/sec (2.49 ft/day). Therefore, 15-foot spacing
for injection points will be used. Approximatel ection points will advance to 14 ft-bgs to the
top of the clay for injections. Figure 7 shows the injection points for groundwater remediation.
Injection
This process requires preparing a slurry of electron donor and pH -buffer and verifying that solution
has become anaerobic, SDC-9-Im would be added to a closed mixing tank and transferred via closed
loop (to prevent introduction of oxygen from the air) for delivery to the subsurface via DPT injection
rods or horizontal wells injection wells. Once the required amount of solution has been delivered
within each interval, the DPT rods will be removed and the point will be abandoned to the surface
with a bentonite-cement grout or bentonite pellets.
The flow and pressure to each injection point may be modified during the injection (within the
limitations imposed by the lithology). Real-time performance monitoring during injection will be
used to provide feedback for any operational changes, such as changing the target volume per
injection point. Every attempt will be made to achieve the design mass loading and hydraulic loading
for each of the injection points.
Potential Rebound and Additional Treatment
Since reductive dechlorination is a slow process and requires contact between the reagent,
dechlorinating microbes, and impacted soit/groundwater. Contact with groundwater in the dead-end
UIC Attachments -Bldg 7

pores or in low permeability clayey soils is limited by slow diffusion processes. Therefore, there is a
possibility, especially in the source areas, groundwater chlorinated solvent concentrations might
increase after they decrease initially. Should groundwater chlorinated solvent concentrations
increase to greater than the Groundwater 2L Standards, a second treatment may be required. If
second treatment is required, electron donor and pH -buffer will be reinjected in the affected areas.
Reinjection of SDC-9TM is not required since the microbial population would have been established
from initial injection.
F. MONITORING PLAN
Accurate delineation of impacted chlorinated solvent affected groundwater, an understanding of
subsurface conditions and characteristics, and identification of impacted groundwater migration rates
and direction are critical for evaluating the occurrence of natural attenuation, for designing reagent
application to reduce the chlorinated solvent values, and for establishing regulatory support for its
use at a site. These data are available and well documented in reports issued for this site.
Downgradient well (MW-41) may be too far downgradient from the known extent of the plume.
Therefore, a new downgradient well (ptQ, e M7ks urinigure )swill be installed before
injections. Should the new well have VOC detections above the 21, Standards, existing well MW-41
will serve as the downgradient well. Monitoring wells MW-7, MW-40, MW-41, and MW-67 at the
Site will be utilized for monitoring the progress of in -situ remediation, going forward.
Baseline Chlorinated Solvent Sampling
Before in -situ anaerobic bioremediation of groundwater, VOCs will be sampled at monitoring wells
MW-7, MW-40, MW-41, and MW-67. The purpose of the baasseh"nnee VBCs groundwater sampling is
to define the groundwater conditions before start of Enhanced Reductive Dechlorination. Any
groundwater sampling completed within approximately three months prior to injections may be used
to establish the baseline sampling event.
Groundwater Monitoring Parameters, Frequency, and Duration
,_MOTTrijectiown s-ai pT n r'1 start one-qu r tr tifte"ral% injections have been completed. Groundwater
VOC sampling will be performed on a4u = er y ;, asi`svGroundwater sampling will continue until
groundwater 2L standards are met, which is estimated to be approximatelb%gag, year. In addition to
groundwater VOC laboratory analysis, water levels, temperature, pH, conductivity, dissolved
oxygen, and oxidation-reduction potential will be recorded for all monitoring wells on a quarterly
basis. EPA Method 8260 will be used for laboratory analysis of VOCs.
U1C Attachments -Bldg 7

Closure Plan
After the remediation chlorinated solvent goals have been confirmed for two consecutive quarters, a
final groundwater remediation closure report will be prepared. Upon approval of the final report by
the EPA, existing monitoring wells will be abandoned.
G. WELL DATA
All wells within %-mile of the Building 7 area are monitoring wells. See Figure 1, Tables 1
through 3, and Appendix A for the requested information.
H. MAPS
Please see attached Figures 1 through 7
UIC Attachments -Bldg 7

TABLES
UIC Attachments -Bldg 7

�ff 4
B." V-dT
WELL CONSTRUCTION LOG
Project Name:
Former Ecusta Paper Mill
Project No.:
Client:
Renova/ DRV
Boring No.:
Location:
Brevard, North Carolina
Date:
Drilling Company:
ESN
logged by:
Dril Rig
Hollow Stem Auger
weather:
5
10
15
20
25
bentonite
4.25" Diameter Borehole
Top of screen at 2' bls
Depth to Water 7' bis
2.0" Sch 40 PVC
Sand Filter Pack
Bottom of screen 17' bls
Bottom of Boring 18' bls
note: elevation data not
available
3.0
9.0
12.0
15.0
18.0
21.0
24.0
131497
MW-67
8-Nov-10
Jim Wilson
cold
Dark brown gravelly clay fill, dry,
slight solvent odor
Brown gravelly clay,
moist, solvent odor
Brown/gray gravelly sand,
wet, slight solvent odor
w/brown gravelly sand
no odor
m of boring
Well Screen detector
Bentonite Seal
Concrete Seal bis = Below Land Surface

Table 1
Summary of Detected Analytes in Groundwater Samples from Buildings 6 and 7 Area
Former Ecusta Paper Mill Site
Analyte
Groundwater
2L Standard
MW-7
MW-40
MW-41
MW-42
Date Sampled
1/16/2007
6/17/2009
10/21/2009
3/9/2010
8/17/2010
10/20/2009 1
3/9/2010
8/17/2010
1/25/2010
3/9/2010
8/17/2010
1/25/2010
3/9/2010
8/18/2010
pH
6.5 to 8.5
6.33
5.83
6.31
6.58
5.88
5.71
5.90
4.59
NA
6.86
5.82
NA
7.41
6.15
METALS
Aluminum
NE
142 J
ND
ND
256
NS
ND
ND
ND
573
377
546
1160
462
375
Barium
2000
31.6
20.0
25.4
28.5
NS
14.3
12
11.1
9.7
10.5
13.5
7.5
ND
6.4
Calcium
NE
37000
21900
25000
37300
NS
14700
10700
8600
26300
22000
14500
25200
24000
18700
Cobalt
NE
0.93 J
ND
ND
ND
NS
ND
ND
ND
ND
ND
ND
ND
ND
ND
Copper
1000
2.3 J
ND
ND
ND
NS
ND
ND
ND
ND
ND
ND
ND
ND
ND
Iron
300
12,200
13700
16200
14000
NS
343
514
410
1780
1210
1130
2570
1100
646
Lead
15
2.8 J
ND
ND
ND
NS
ND
ND
ND
ND
ND
ND
ND
ND
ND
Magnesium
NE
6140
3300
3820
5590
NS
2940
2500
2260
3260
3920
3000
3360
2520
2660
Manganese
50
2690
1320
1790
1540
NS
.124
174
88.2
22.6
23.3
16.5
551
561
78.8
Potassium
NE
3730
ND
ND
ND
NS
ND
ND
ND
ND
ND
ND
ND
ND
ND
Sodium
NE
10400
5990
8010
8700
NS
ND
ND
ND
ND
5320
5080
7830
7350
ND
Zinc
1050
14.4 J
ND
ND
ND
NS
ND
ND
ND
ND
11
ND
ND
ND
ND
Mercury
1.05
ND
ND
ND
ND
NS
ND
ND
ND
ND
ND
ND
ND
ND
ND
VOt;s
Eth (benzen=(TCE)2.8
ND
ND
2
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
NaphthaleneND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
153
12.4
TetrachloroeND
5.1
25.8
52.2
14
ND
ND
ND
ND
ND
ND
ND
ND
ND
TrichloroehteND
ND
2.2
3.0
2.6
ND
ND
ND
ND
ND
ND
ND
ND
ND
m&p-XyleneND
ND
3.2
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
SVOCS
1-Methyl naphthalene
NE
--
ND
ND
ND
NS
ND
ND
ND
ND
ND
ND
6.8
ND
ND
2-Meth (naphthalene
14
--
ND
ND
ND
NS
ND
ND
ND
ND
ND
ND
6.8
ND
ND
Acenaphthene
80
--
ND
ND
ND
NS
ND
ND
ND
ND
ND
ND
8.1
ND
ND
Dibenzofuran
28
--
ND
ND
ND
NS
ND
ND
ND
ND
ND
ND
5.4
ND
ND
Naphthalene
1 21
-
ND
ND
ND
NS
ND
ND
ND
ND
ND
ND
67.8
ND
ND
All concentrations are in micrograms per liter (ug/L).
NA - not available
ND - not detected
NE - not established and/or not applicable
Exceeds 2L standards

Table 2
PID Data for DPT Borings
Ecusta Building 7 Area
Brevard, North Carolina
Shaw Project # 131497
Boring
Date
Highest PID
Reading (PPM)
Depth of
Measurement
(ft-bgs)
Scanned Water
or Soil
Submitted for
VOC Analysis
B7-DPT-01
04/14/10
0.0
14'-18'
Water
Yes
B7-DPT-02
04/14/10
0.0
1 V-15'
Water
Yes
B7-DPT-03
04/14/10
0.0
16'-20'
Water
Yes
B7-DPT-04
04/14/10
0.0
10'-14'
Water
Yes
B7-DPT-05
04/14/10
0.0
12'-16'
Water
Yes
B7-DPT-06
04/14/10
0.0
9.5'-13.5'
Water
Yes
B7-DPT-07
04/15/10
3.5
9'-13'
Water
Yes
B7-DPT-08
04/15/10
4.7
8'-12'
Water
Yes
B7-DPT-09
04/15/10
0.0
16'-20'
Water
Yes
B7-DPT-10
04/15/10
0.0
1 F-15'
Water
Yes
B7-DPT-11
04/15/10
0.0
12'-16'
Water
Yes
B7-DPT-12
04/15/10
0.0
15'-19'
Water
Yes
B7-DPT-13
04/15/10
0.0
16'-20'
Water
Yes
B7-DPT-07
04/15/10
0.0
6'-7'
Soil
Yes
B7-DPT-08
04/15/10
0.0
6'-7'
Soil
Yes
B7-DPT-14
04/15/10
0.0
6'-7'
Soil
Yes
Note: ft-bgs = feet below ground surface
Page 1 of 1

Table 3
Groundwater Levels
Ecusta Building 7 Area
Shaw Proi ect # 131497
03/09/10
5'-15'
2125.24
6.13
2119.11
MW-7
07/26/10
5'-15'
2125.24
6.90
2118.34
03/10/10
5'-25'
2128.16
8.30
2119.86
MW-40
07/26/10
5'-25'
2128.16
9.16
2119.00
03/10/10
5'-25'
2121.41
3.46
2117.95
MW-41-
07/26/10
5'-25'
2121.41
4.07
2117.34
03/10/10
T-23'
2122.58
3.96
2118.62
MW-42
07/26/10
3'-23'
2122.58
3.90
2118.68
Note: TOC = top of casing, NM = not measured, su = standard unit

Table 4
Summary of Slug Test Results
Ecusta Caustic Spill Area
Brevard, North Carolina
Monitoring
Well
Depth of
Screen
(ft-bgs)
Height of
Water
Column in
Well (feet)
Depth to
Top of (feet)
(feet)
Lithology
Across
Screened
Interval
Hydraulic Conductivity (cmis)
Falling Head Test
Rising Head Test
Geometric
Mean
Wells Screened above the first ay Layer (Sa route)
MW-1
9.8'-19.8'
13.49
NM
Sand/clay
1.32E-03
1.28E-03
1.30E-03
MW-2
7-17'
10.32
NM
Sand/gravel/
sandy silt
4.12E-04
3.68E-04
3.89E-04
MW-3
T-17'
12.31
NM
Sand
Too Much Scatter
7.04E-01
7.04E-01
MW-4
3'-13'
8.08
13+
Silt
1.76E-04
2.49E-04
2.09E-04
MW-16s
1 3'-13'
4.00
14.5
Silt/Sand/ Gravel
5.25E-03
6.02E-04
1.78E-03
PZ-30A
10'-11,
5.81
15.0
Sand
6.63E-04
1.20E-03
8.92E-04
PZ-31A
7'-8'
4.04
11
Sand
1.17E-03
3.77E-04
6.65E-04
PZ-31B
13'-14'
1 8.21
(?)
Clay (?) (Based
1 on CGW-19)
2.93E-'04
3.79E-05-
_
1.05E-04
PZ-32A
10'-11'
5.34
15 ?)
Sand
Too Much Scatter
1.46E-04
1.46E-04
PZ-33A
1 10'-11'
5.02
14.0
Sand
4.66E-04
1.06E-04
2.22E-04
AVERAGE
8.77E-04
Wells Screened in the First Cla Layer (Sa route)
PZ-30B
16-17'
11.60
15
clay
7.47E-07
Incomplete Failing
Head Test
7.47E-07
PZ-32B
16-17'
10.66
15 (?)
sand/clay
6.72E-07
Incomplete Falling
Head Test
6.72E-07
PZ-33B
16-17
1.79
14.5
cla
Incomplete Test
2.92E-06
2.92E-06
PZ-34A
10'-11,
2.35
13.0
Sand. (?)
Incomplete Test
1.81 E-061
1.81 E-06
AVERAGE
1.28E-06
Wells Screened' the Sa rolite Sandy/Gravelly Zone
PZ-30C
22'-23'
17.44
15
Sand,/Clay
8.72E-06
Incomplete Falling
Head Test
8.72E-06
PZ-32C
22'-23'
15.92
18
sand (?)
4.03E-04
5.57E-04
4.74E-04
PZ-33C
22'-23'
9.52
14.5
clay
Incomplete Test
3.57E-06
3.57E-06
PZ-34C
22'-23'
11.89
13
clay
2.65E-07
4.08E-06
1.04E-06
AVERAGE
1.11 E-05
- Deeper Wells
MW-16I
30'-35'
24.02
14.5
clayE-04
1.46E-04
1.24
1.34E-04
MW-16D .
82'-87'
76.38
14.5
rock
1.04E-04
1.20E-04
1.12E-04
Note: TOC = top of casing, NM = not measured

Table 4
Summary of Slug Test Results
Ecusta Caustic Spill Area
Brevard, North Carolina
Monitoring
Well
Depth of
Screen.
(ft-bgs)
Height -of
Water
Column in
Well (feet)
Depth to
flop of Clay
(feet)
Lithology
Across
- Screened
Interval
Hydraulic Conductivity (cm/s)
Falling Head Test
Rising Head Test
Geometric
Mean
Wells Screened above the first Clay Layer (Sa rolite)
MW-1
9.8'-19.8'
13.49
NM
Sand/clay
1.32E-03
1.28E-03
1.30E-03
MW-2
T-17'
10.32
NM
Sand/gravel/
sandy silt
4.12E-04
3.68E-04
3.89E-04
MW-3
T-17'
12.31
NM
Sand
Too Much Scatter
7.04E-01
7.04E-01
MW-4
T-13'
8.08
13+
Silt
1.76E-04
2.49E-04
2.09E-04
MW-16s
3'-13'
4.00
14.5
Silt/Sand/ Gravel
5.25E-03
6.02E-04
1.78E-03
PZ-30A
10'=11'
5.81
15.0
Sand
6.63E-04
1.20E-03
8.92E-04
PZ-31A
T-8'
4.04
11
Sand
1.17E-03
3.77E-04
6.65E-04
PZ-31B
13'-14'
8.21
(?)
Clay (?) (Based
on CGW-19)
2.93E-04
3.79E-05
1.05E-04
PZ-32A _
10'-11,
5.34
15 ?
Sand
Too Much Scatter
1.46E-04
1.46E-04
PZ-33A
10'-11,
5.02
14.0
Sand
4.66E-04
1.06E-04
2.22E-04
AVERAGE
8.77E-04
Wells Screened in the First Clay Layer (Saprolite)
PZ-30B
16'-17'
11.60
15
clay
7.47E-07
Incomplete Failing
Head Test
7.47E-07
PZ-32B
16'-17'
10.66
15 ?
sand/clay
6.72E-07
Incomplete Falling
Head Test
6.72E-07
PZ-33B
16'-17'
1.79
14.5
clay
Incomplete Test
2.92E-06
2.92E-06
PZ-34A
10'-11,
2.35
13.0
Sand (?)
Incomplete Test
1.81 E-06
1.81 E-06
AVERAGE
1.28E-06
Wells Screened in the Sa rolite Sandy/GravellySandy/Gravelly Zone
PZ-30C
22'-23'
17.44
15
Sand/Clay,8.72E-06
Incomplete Falling
Head Test
8.72E-06
PZ-32C
22'-23'
15.92
18
sand (?)
4.03E-04
5.57E-04
4.74E-04
PZ-33C
22'-23'
9.52
14.5
clay
Incomplete Test
3.57E-06
3.57E-06
PZ-34C
22'-23'
11.89
13
clay
2.65E-07
4.08E-06
1.04E-06
AVERAGE
1.11 E-05
Deeper Wells
MW-161
30'-35'
1 24.02
1 14.5
1 clay
1.46E-04
1.24E-04
1.34E-04
MW-16D
82'-87'
1 76.38
1 14.5
1 rock
1.04E-04
1.20E-04
1.12E-04
Note: TOC = top of casing, NM = not measured

Table 5
Summary of Slug Test Results
ElectoChem Building
Former Ecusta Mill, Brevard, North Carolina
Monitoring Well
Hydraulic Conductivity (cm/s)
Falling Head Test
Rising Head Test
Geometric Mean
Shallow Wells
MW-17S
4.56E-04
4.48E-04
4.52E-04
MW-18S
NR
1.31 E-03
1.31 E-03
MW-19S
2.14E-04
1.94E-04
2.04E-04
MW52-S
7.95E-04
7.08E-04
7.50E-04
MW-53
1.25E-04
3.10E-04
1.97E-04
MW-54
1.48E-05
1.92E-05
1.69E-05
MW-55S
6.83E-03
4.15E-03
5.32E-03
MW-56
2.13E-03
1.21 E-02
5.08E-03
MW-57S
2.43E-04
1.13E-04
1.66E-04
MW-58
1.93E-03
8.97E-03
3.95E-03
1.85E-03
7.60E-03
MW-59
.2.06E-04
1.08E-04
1.49E-04
MW-60
8.84E-03
1.68E-02
1.46E-02
1.39E-02
2.19E-02
MW-61S
4.92E-05
1.05E-04
7.19E-05
MW-62S
2.59E-04
3.22E-04
2.89E-04
NM-66
5.98E-03
8.14E-03
6.98E-03
GEOMETRIC MEAN
6.53E-04
Intermediate Wells
MW-19I
1.49E-04
1.03E-04
1.24E-04
MW-55I
1.32E-04
5.92E-05
8.83E-05
MW-57I
3.45E-04
9.85E-04
5.02E-04
3.86E-04
4.86E-04
MW-61I
4.06E-05
3.92E-05
3.99E-05
GEOMETRIC MEAN
1.22E-04
Deep
Wells
MW-18D
1.17E-04
8.49E-05
9.96E-05
NM-52D
MW-55D
MW-57D
1.67E-04
9.40E-05
1.25E-04
2.80E-05
2.24E-05
2.50E-05
4.71 E-04
5.87E-04
5.26E-04
MW-62D
2.93E-05
5.89E-05
4.15E-05
GEOMETRIC MEAN
9.26E-05
NR - No result.

Appendix A
Boring Logs and Well Construction Diagrams
UIC Attachments -Bldg 7

Ecusta Paper Mill
_J Ecusta Road
slia — Pisgah Forest, North Carolina
WELL CONSTRUCTION LOG
Project Name:
Ecusta Paper Mill Project No.: 123445
Client
Transylvania County Boring No.: MW7
Location:
Pisgah Forest, North Carolina Date: 9-Jan-07
Drilling Company:
American Environmental Drilling
Dril Rig
Hollow -stem Auger
Well Construct USCS IDepth
I
feet)
Description
1' bentonite seal ML
gravel at surface
1-7' Silty clay- gray to green, poorly cohesive
5
5.0
Top of screen: 5' bgs CL
T-15' Clay- wet, green to gray, moderately to poorly cohesive
depth -to -water. 8.66 bTOC
10
10.0
2" Sch 40 PVC, 0.010 slot screen
15
15.0
total depth: 15' bgs.
20
20.0
25
25.0
30
30.0
35
35.0
40
40.0
45
45.0
LEGEND
Sand Pack
50
50.0
Well Screen
Bentonke Seal
Grout
Concrete Seal

WELL CONSTRUCTION LOG
Project Name: Former Ecusta Paper Mill Project No.: 131497
Client: Renova! DRV Boring No.: MW-40
Location: Brevard, North Carolina Date: 16-Sep-09
Drilling Company: Landprobe logged by: Jim Wilson
Dril Rig Hollow Stem Auger weather: cloudy

WELL CONSTRUCTION LOG
Project Name: Former Ecusta Paper Mill Project No.: 131497
Client: Renova/ DRV Boring No.: MW-41
Location: Brevard, North Carolina Date: 117-11/2010
Drilling Company: Landprobe logged by Jim Wilson
Dril Rig Hollow Stem Auger weather: cold

WELL CONSTRUCTION LOG
Project Name:
Former Ecusta Paper Mill
Project No.:
Client:
Renovaf DRV
Boring No.:
Location:
Brevard, North Carolina
Date:
Drilling Company:
Landprobe
logged by.
Dril Rig
Hollow Stem Auger
weather:
5
10
15
20
4.25" Diameter Borehole
bentonite
3
Top of screen at T bls
6
Depth to Water 6' bls
9
2.0" Sch 40 PVC
12
15
1E
21
Sand Filter Pack
Bottom of screen 23' bls
24
Bottom of Boring 23.5' bls
note: elevation data not
available
131497
M W-42
12-Jan-10
Jim Wilson
cold
Gray clayey gravell fill, dry, no odor
0.00
0.00 Gray gravelly (1"-2" angular)
clay, moist, no odor
0.00
Brown silty clay, moist, no
0.00 odor
0.00
0.00
0.00 Brown gravelly clay,
wet, no odor
0.00
0.00
0.00
Gray thick clay, dry
0.00
0.00
Well Screen detector
Bentonite Seal
Concrete Seal bis = Below Land Surface

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Appendix B
Material Safety Data Sheet (MSDS) for Reagents to be Injected
UIC Attachments-ECUSTA Bldg 7.doc 09/30/10 2:18 PM

Material Safety Data Sheet U.S. Department of Labor
May be used to comply with OSHA's Hazard Occupational Safety and Health Administration
Communication Standard, 29 CFR 1910 1200. Standard (Non -Mandatory Form)
must be consulted for specific requirements. Form Approved
OMB No. 1218-0072
IDENTITY (as Used on Label and List) I Note: Blank spaces are not permitted. If any item is not
ABC (Anaerobic BioChem) applicable or no information is available, the space
must be marked to indicate that
Manufacturer's name
REDOX TECH, LLC
Emergency I a ephone Number 919-678-0140
Address (Number, Street, Cfty, State and ZTP Code)
e ep one Number for Information 919-678-0140
200 Quade Dr, Cary NC 27513
Date Prepared MAY 2004
Signature of PreFarer option
Section II —Hazardous Ingredients/Identity Information
Hazardous Components (Specific Chemical Identity, Common Name(s))
OSHA PEL
ACGIH TLV
Other Limits
Recommended % (optional)
Mixture of:
Lactate salts
NA
NA
(0 to 60%)
Lactic acid esters
NA
NA
(0 to 98.5%)
Phosphate buffer
NA
NA
(0 to 0.1%)
Ferrous Iron
NA
NA
(0 to 0.1%)
Fattv Acids
NA
NA
(0 to 5%)
Section III—Physical/Chemical Characteristics
Boiling Point
> 100 C
Speck Gravity (H20 = 1)
1.04
Vapor Pressure (mm s) Lactic acid esters
2.7 mbar. 20 °C
pH
6.0 to 8.0
Vapor Density = Lactic acid esters
3.8
Evaporation Rate(Butyl Acetate = 1
No information
Solubility in Water Fully soluble and miscible
Appearance and Odor Light yellow to colorless liquid, slight to mild, characteristic odor
Section IV —Fire and Explosion Hazard Data
Lactic acid esters: 61 °C (ISO 2719, closed cup) I Lactic acid esters: 11.5% (100 °C) 111.4% (100 °C)
Extinguishing g Media Water spray, carbon dioxide, dry powder, AFFF, foam
Special ire Fighting Procedures
Standard procedures for chemical fires
unusual ire and Explosion Hazards
Thermal decomposition can release irritating gases and vapors
(Reproduce locally) OSHA 174 Sept. 1985

i
Section V—Reactivity Data
I emperatures auuve o_i t. vvm nyoroiyze in
presence of water, acids and bases
uiwmNauunny _—) Strong oxidants
Hazardous Decomposition or Byproducts no known
Hazardous may uccur conditions to Avoid
Polymerization
Will of Occur X
Section VI —Health Hazard Data
Route(s)of Entry Inhalation? Yes, esters only in? Yes Ingestion? Yes
Health azar s (Acute and Chronic)Acid esters: Risk of irritation to eyes. Irritating to respiratory system. May degrease
skin.
Carcinogenicity None NTP? No IARC Monographs? NO U9RTTe—gu7a—te-d?No
Signs and Symptoms of Exposure Red irritated skin. May cause light-headedness when used in poorly ventilated area without
proper vapor mask..
Medical Conditions
Generally Aggravated by Exposure Persons susceptible or sensitive to eye and respiratory irritation
Emergency an First Aid Procedures Inhalation: Move to fresh air; Skin: Wash skin immediately with water. Eyes: Flush with
water for at least 15 minutes, consult physician; Ingestion: Drink water and consult physician.
Section VII—Precautions for Safe Handling and Use
Use safety glasses and latex or nitrile gloves. Work in well ventilated area.
Waste Disposal MethodABC can be disposed as waste water or landfilled when in compliance with local regulations
Precautions to Be Taken in Handling and Storing May be F lammable - Do not store near ignition sources or at elevated
temperatures.
Avoid long storage times, will break down to innocuous products
t er recautions Wear PPE when handling and keep containers tightly closed when stored.
Section VII—Control Measures
Respiratory Protection(Specify Type) If ventilation inadequate or in confined space, use respirator with filter (DIN 141)
Ventilation Local Exhaust Acid esters have low vapor pressure (2.7 Special Ensure fumes can not reach ignition source
mbar at 20 °C) Standard HVAC conditions typically
adequate
Mechanical enera Floor or stand fans Other
-Tr­o—tec­5v­­e­GI3ves PVA, nitrile or latex Eye Protection Safety glasses with side shields
Other rotective Clothing or Equipment
o ygienic Practices Do not eat, drink or smoke while handling. Remove/wash contaminated clothing before reuse.

Last Revised: March 26, 2007
3-D Microemulsion (3DMe)TM
MATERIALS SAFETY DATA SHEET
Section 1— Material Identification
Supplier:
REGENESIS
1011 Calle Sombra
San Clemente, CA 92673
Phone: [phone]
Fax: [phone]
E-mail: [e-mail]
• Glycerides, di-, mono [2-[2-[2-(2-hydroxy-l-oxopropoxy)-1-oxopropoxyl]-1-
oxopropoxy]propanoates]
Chemical Name(s): • Propanoic acid, 2-[2-[2-(2-hydroxy-l-oxopropoxy)-1-oxopropoxy]-1-
oxopropoxy]-1,2,3-propanetriyl ester
• Glycerol
Chemical Family: Organic Chemical
Trade Name: 3-D Microemulsion (3DMe)TM
Synonyms: HRC AdvancedTM HRC-PED (Hydrogen Release Compound — Partitioning
Electron Donor)
Product Use: Used to remediate contaminated groundwater (environmental applications)
Section 2 — Chemical Identification
CAS# Chemical
823190-10-9 HRC-PED
61790-12-3 or
112-80-1 Fatty Acids (neutralized)
201167-72-8 Glycerol Tripolylactate
56-81-5 Glycerol

Regenesis — 3-D Microemulsion MSDS
Section 3 — Physical Data
Melting Point: Not Available (NA)
Boiling Point: Not determined (ND)
Flash Point: > 200 OF using the Closed Cup method
Density: 0.9 -1.1 g/cc
Solubility: Slightly soluble in acetone. Insoluble in water.
Appearance: Amber semi -solid.
Odor: Not detectable
Vapor Pressure: None
Section 4 — Fire and Explosion Hazard Data
Extinguishing Media: Use water spray, carbon dioxide, dry chemical powder or appropriate foam
to extinguish fires.
Water May be used to keep exposed containers cool.
For large quantities involved in a fire, one should wear full protective clothing and a NIOSH approved
self contained breathing apparatus with full face piece operated in the pressure demand or positive
pressure mode as for a situation where lack of oxygen and excess heat are present.
Section 5 — Toxicological Information
May be harmful by inhalation, ingestion, or skin absorption. May cause
irritation. To the best of our knowledge, the chemical, physical, and
Acute Effects: toxicological properties of the 3-D Microemulsion have not been
investigated. Listed below are the toxicological information for glycerol,
lactic acid and fatty acid.
MA8050000
RTECS#
Glycerol
SKN-RBT 500 MG/24H MLD 85JCAE-,207,1986
Irritation Data: EYE-RBT 126 MG MLD BIOFX* 9-4/1970
EYE-RBT 500 MG/24H MLD 85JCAE-,207,1986

Regenesis — 3-D Microemulsion MSDS
Section 5 — Toxicological Information (cont)
ORL-MUS LD50:4090 MG/KG
FRZKAP (6),56,1977
SCU-RBT LD50:100 MG/KG
NURDN 6,215,1982
ORL-RAT LD50:12,600 MG/KG
FEPRA7 4,142,1945
IHL-RAT LC50: >570 MG/M3/1H
BIOFX* 9-4/1970
IPR-RAT LD50: 4,420 MG/KG
RCOCB8 56,125,1987
IVN-RAT LD50:5,566 MG/KG
ARZNAD 26,1581,1976
Toxicity Data: IPR-MUS LD50: 8,700 MG/KG
ARZNAD 26,1579,1978
SCU-MUS LD50:91 MG/KG
NHRDN 6,215,1982
IVN-MUS LD50:4,250 MG/KG
JAPMA8 39,583,1950
ORL-RBT LD50: 27 MG/KG
DMDJAP 31,276,1959
SKN-RBT LD50: >10 MG/KG
BIOFX* 9-4/1970
IVN-RBT LD50: 53 MG/KG
NIIRDN 6,215,1982
ORL-GPG LD50: 7,750 MG/KG
JIHTAB 23,259,1941
Behavioral (headache), gastrointestinal (nausea or vomiting), Paternal
Target Organ Data: effects (spermatogenesis, testes, epididymis, sperm duct), effects of fertility
(male fertility index, post -implantation mortality).
Only selected registry of toxic effects of chemical substances (RTECS) data is presented here. See
actual entry in RTECS for complete information on lactic acid and glycerol.
Fatty Acids
Acute oral (rat) LD50 value for fatty acids is 10000 mg/kg. Aspiration of liquid may cause
pneumonitis. Repeated dermal contact may cause skin sensitization.
Section 6 — Health Hazard Data
One should anticipate the potential for eye irritation and skin irritation with large scale exposure or in
sensitive individuals. Product is not considered to be combustible. However, after prolonged contact
with highly porous materials in the presence of excess heat, this product may spontaneously combust.
Handling: Avoid continued contact with skin. Avoid contact with eyes.
In any case of any exposure which elicits a response, a physician should be consulted immediately.
First Aid Procedures
Inhalation: Remove to fresh air. If not breathing give artificial respiration. In case of
labored breathing give oxygen. Call a physician.
Ingestion: No effects expected. Do not give anything to an unconscious person. Call a

Regenesis — 3-1) Microemulsion MSDS
physician immediately. DO NOT induce vomiting.
Section 6 — Health Hazard Data (cont)
Skin Contact: Flush with plenty of water. Contaminated clothing may be washed or dry
cleaned normally.
Eye Contact: Wash eyes with plenty of water for at least 15 minutes lifting both upper
and lower lids. Call a physician.
Section 7 — Reactivity Data
Conditions to Avoid: Strong oxidizing agents, bases and acids
Hazardous
Polymerization: Will not occur.
Further Information: Hydrolyses in water to form lactic acid, glycerol and fatty acids.
Hazardous Decomposition Thermal decomposition or combustion may produce carbon monoxide
Products: and/or carbon dioxide.
Section 8 — Spill, Leak or Accident Procedures
After Spillage or Neutralization is not required. The material is very slippery. Spills should
Leakage: be covered with an inert absorbent and then be placed in a container. Wash
area thoroughly with water. Repeat these steps if slipperiness remains.
Laws and regulations for disposal vary widely by locality. Observe all
Disposal: applicable regulations and laws. This material may be disposed of in solid
waste. Material is readily degradable and hydrolyses in several hours.
No requirement for a reportable quantity (CERCLA) of a spill is known.
Section 9 — Special Protection or Handling
Should be stored in plastic lined steel, plastic, glass, aluminum, stainless steel, or reinforced fiberglass
containers.
Protective Gloves: Vinyl or Rubber
Eyes: Splash Goggles or Full Face Shield. Area should have approved means of
washing eyes.
Ventilation: General exhaust.
Storage: Store in cool, dry, ventilated area. Protect from incompatible materials.

Regenesis — 3-D Microemulsion MSDS
Section 10 — Other Information
This material will degrade in the environment by hydrolysis to lactic acid, glycerol and fatty acids.
Materials containing reactive chemicals should be used only by personnel with appropriate chemical
training.
The information contained in this document is the best available to the supplier as of the time of
writing. Some possible hazards have been determined by analogy to similar classes of material. No
separate tests have been performed on the toxicity of this material. The items in this document are
subject to change and clarification as more information becomes available.

Science Lab.com
Chemicals & Laboratory Equipment
Material Safety Data Sheet
Sodium bicarbonate MSDS
Section 1: Chemical Product and Company Identification
Product Name: Sodium bicarbonate
Catalog Codes: SLS3241, SLS2446, SLS3868
CAS#: 144-55-8
RTECS: VZ0950000
TSCA: TSCA 8(b) inventory: Sodium bicarbonate
CI#: Not available.
Synonym: Baking Soda; Bicarbonate of soda; Sodium
acid carbonate; Monosodium carbonate; Sodium hydrogen
carbonate; Carbonic acid monosodium salt
Chemical Name: Sodium Bicarbonate
Chemical Formula: NaHCO3
Contact Information:
Sciencelab.com, Inc.
14025 Smith Rd.
Houston, Texas 77396
US Sales: 1-800-901-7247
International Sales: 1-281-441-4400
Order Online: ScienceLab.com
CHEMTREC (24HR Emergency Telephone), call:
1-800-424-9300
International CHEMTREC, call: 1-703-527-3887
For non -emergency assistance, call: 1-281-441-4400
Section 2: Composition and Information on Ingredients
Composition:
Name CAS # % by Weight
Sodium bicarbonate 144-55-8 100
Toxicological Data on Ingredients: Not applicable.
Section 3: Hazards Identification I
Potential Acute Health Effects: Slightly hazardous in case of skin contact (irritant), of eye contact (irritant), of ingestion, of
inhalation.
Potential Chronic Health Effects:
CARCINOGENIC EFFECTS: Not available. MUTAGENIC EFFECTS: Not available. TERATOGENIC EFFECTS: Not available.
DEVELOPMENTAL TOXICITY: Not available. Repeated or prolonged exposure is not known to aggravate medical condition.
I Section 4: First Aid Measures I
Eye Contact:
Check for and remove any contact lenses. In case of contact, immediately flush eyes with plenty of water for at least 15
minutes. Cold water may be used. Get medical attention if irritation occurs.
P. 1

Skin Contact:
Wash with soap and water. Cover the irritated skin with an emollient. Get medical attention if irritation develops. Cold water
may be used.
Serious Skin Contact: Not available.
Inhalation:
If inhaled, remove to fresh air. If not breathing, give artificial respiration. If breathing is difficult, give oxygen. Get medical
attention.
Serious Inhalation: Not available.
Ingestion:
Do NOT induce vomiting unless directed to do so by medical personnel. Never give anything by mouth to an unconscious
person. Loosen tight clothing such as a collar, tie, belt or waistband. Get medical attention if symptoms appear.
Serious Ingestion: Not available.
Section 5: Fire and Ext)losion Data
Flammability of the Product: Non-flammable.
Auto -Ignition Temperature: Not applicable.
Flash Points: Not applicable.
Flammable Limits: Not applicable.
Products of Combustion: Not available.
Fire Hazards in Presence of Various Substances: Not applicable.
Explosion Hazards in Presence of Various Substances:
Risks of explosion of the product in presence of mechanical impact: Not available. Risks of explosion of the product in
presence of static discharge: Not available.
Fire Fighting Media and Instructions: Not applicable.
Special Remarks on Fire Hazards: When heated to decomposition it emits acrid smoke and irritating fumes.
Special Remarks on Explosion Hazards: Not available.
Section 6: Accidental Release Measures
Small Spill:
Use appropriate tools to put the spilled solid in a convenient waste disposal container. Finish cleaning by spreading water on
the contaminated surface and dispose of according to local and regional authority requirements.
Large Spill:
Use a shovel to put the material into a convenient waste disposal container. Finish cleaning by spreading water on the
contaminated surface and allow to evacuate through the sanitary system.
Section 7: Handling and Storage
Precautions:
Do not ingest. Do not breathe dust. If ingested, seek medical advice immediately and show the container or the label. Keep
away from incompatibles such as acids.
Storage: Keep container tightly closed. Keep container in a cool, well -ventilated area.
Section 8: Exposure Controls/Personal Protection
p. 2

Engineering Controls:
Use process enclosures, local exhaust ventilation, or other engineering controls to keep airborne levels below recommended
exposure limits. If user operations generate dust, fume or mist, use ventilation to keep exposure to airborne contaminants
below the exposure limit.
Personal Protection: Safety glasses. Lab coat. Dust respirator. Be sure to use an approved/certified respirator or equivalent.
Gloves.
Personal Protection in Case of a Large Spill:
Splash goggles. Full suit. Dust respirator. Boots. Gloves. A self contained breathing apparatus should be used to avoid
inhalation of the product. Suggested protective clothing might not be sufficient; consult a specialist BEFORE handling this
product.
Exposure Limits: Not available.
Section 9: Physical and Chemical Properties
Physical state and appearance: Solid.
Odor: Odorless.
Taste: Saline. Alkaline.
Molecular Weight: 84.01g/mole
Color: White.
pH (1 % soln/water): Not available.
Boiling Point: Not available.
Melting Point: Not available.
Critical Temperature: Not available.
Specific Gravity: Density: 2.159 (Water = 1)
Vapor Pressure: Not applicable.
Vapor Density: Not available.
Volatility: Not available.
Odor Threshold: Not available.
Water/Oil Dist. Coeff.: Not available.
lonicity (in Water): Not available.
Dispersion Properties: See solubility in water.
Solubility:
Soluble in cold water. Slightly soluble in alcohol. Solubility in Water: 6.4, 7.6, 8.7, 10.0, 11.3, 12.7, 14.2, 16.5, 19.1 g/100
solution at 0, 10, 20, 30, 40, 50, 60, 80, adn 100 deg. C, respectively. Solubility in Water: 6.9, 8,2, 9.6, 11.1, 12.7, 14.5, 16.5,
19.7, and 23.6 g/100g water at 0, 10, 20, 30, 40, 50, 60, 80, 100 deg. C, respectively.
Section 10: Stability and Reactivitv Data
Stability: The product is stable.
Instability Temperature: Not available.
Conditions of Instability: Incompatible materials, Moisture. Stable in dry air, but slowly decomposes in moist air.
Incompatibility with various substances: Reactive with acids.
p. 3

Corrosivity: Non -corrosive in presence of glass.
Special Remarks on Reactivity:
Reacts with acids to form carbon dioxide. Dangerous reaction with monoammonium phosphate or a sodium -potassium alloy.
Special Remarks on Corrosivity: Not available.
Polymerization: Will not occur.
I Section 11: Toxicological Information I
Routes of Entry: Inhalation. Ingestion.
Toxicity to Animals: Acute oral toxicity (LD50): 3360 mg/kg [Mouse].
Chronic Effects on Humans: Not available.
Other Toxic Effects on Humans: Slightly hazardous in case of skin contact (irritant), of ingestion, of inhalation.
Special Remarks on Toxicity to Animals: Not available.
Special Remarks on Chronic Effects on Humans:
Sodium Bicarbonate as produced genetic effects in rats (unscheduled DNA synthesis). However, no affects have been found
in humans.
Special Remarks on other Toxic Effects on Humans:
Acute Potential Health Effects: Skin: May cause mild skin irritation. Eyes: May cause mild eye irritation. Inhalation: May
cause respiratory tract irritation. Symptoms may include coughing and sneezing. Ingestion: Symptoms of overexposure to
Sodium Bicarbonate include thirst, abdominal pain, gastroenteritis, and inflammation of the digestive tract. Chronic Potential
Health Effects: Skin: Repeated or prolonged skin contact may cause irritation, drying or cracking of the skin. Ingestion and
Inhalation: Chronic toxicity usually occurs within 4 to 10 days following ingestion of very large amounts. Repeated or prolonged
ingestion or inhalation of large amounts may cause metabolic abnormalities, and sodium retention. Metabolic abnormalities
such as acidosis, hypernatremia, hypochloremia, alkalosis, hypocalemia, or sodium retention may affect the blood, kidneys,
respiration (cyanosis, apnea secondary to metabolic acidosis or pulmonary edema), and cardiovascular system (tachycardia,
hypotension). Severe toxicity may also affect behavior/central nervous system/nervous system. Neurological changes may
result from metabolic abnormalities. These may include fatigue, irritability, dizziness, mental confusion, paresthesia, seizures,
tetany, cerebral edema Medical Conditions Aggravated by Exposure: Persons with pre-existing skin conditions might have
increased sensitivity. Predisposing conditions that contribute to a mild alkali syndrome include, renal disease, dehydration, adn
electrolyte imbalance, hypertension, sarcoidosis, congestive heart failure, edema, or other sodium retaining conditions.
Section 12: Ecological Information
Ecotoxicity: Not available.
BOD5 and COD: Not available.
Products of Biodegradation:
Possibly hazardous short term degradation products are not likely. However, long term degradation products may arise.
Toxicity of the Products of Biodegradation: The product itself and its products of degradation are not toxic.
Special Remarks on the Products of Biodegradation: Not available.
Section 13: Disposal Considerations
Waste Disposal:
Waste must be disposed of in accordance with federal, state and local environmental control regulations.
Section 14: Transport Information
p. 4

DOT Classification: Not a DOT controlled material (United States).
Identification: Not applicable.
Special Provisions for Transport: Not applicable.
Section 15: Other Regulatory Information .
Federal and State Regulations: TSCA 8(b) inventory: Sodium bicarbonate
Other Regulations: Not available.
Other Classifications:
WHMIS (Canada): Not controlled under WHMIS (Canada).
DSCL (EEC):
This product is not classified according to the EU regulations. Not applicable.
HMIS (U.S.A.):
Health Hazard: 1
Fire Hazard: 0
Reactivity: 0
Personal Protection: E
National Fire Protection Association (U.S.A.):
Health: 1
Flammability: 0
Reactivity: 0
Specific hazard:
Protective Equipment:
Gloves. Lab coat. Dust respirator. Be sure to use an approved/certified respirator or equivalent. Safety glasses.
Section 16: Other Information
References: Not available.
Other Special Considerations: Not available.
Created: 10/10/2005 08:26 PM
Last Updated: 11/06/2008 12:00 PM
The information above is believed to be accurate and represents the best information currently available to us. However, we
make no warranty of merchantability or any other warranty, express or implied, with respect to such information, and we assume
no liability resulting from its use. Users should make their own investigations to determine the suitability of the information for
their particular purposes. In no event shall ScienceLab.com be liable for any claims, losses, or damages of any third party or for
lost profits or any special, indirect, incidental, consequential or exemplary damages, howsoever arising, even if ScienceLab.com
has been advised of the possibility of such damages.
p. 5

Material Safety Data Sheet
Shaw Environmental, Inc.
Biotechnology Development Laboratory
17 Princess Rd.
Lawrenceville, NJ 08648
[phone]
SECTION 1 - MATERIAL IDENTIFICATION AND INFORMATION
Material Name: DHC microbial consortium (SDC-9) MSDS #: ENV 1033
Date Prepared: 1/05/2006 CAS #: N/A (Not Applicable)
Prepared By: Simon Vainberg Formula #: N/A
Material Description: Non -hazardous, naturally occurring non -altered anaerobic
microbes and enzymes in a water -based medium.
SECTION 2 - INGREDIENTS
Components
% OSHA ACGIH OTHER
PEL TLV LIMITS
Non -Hazardous Ingredients 100 N/A N/A
SECTION 3 - PHYSICAL/CHEMICAL CHARACTERISTICS
Boiling Point: 1000C (water)
Vapor Pressure @ 250C: 24 mm Hg (water)
Vapor Density: N/A
Solubility in Water: Soluble
71
Specific Gravity (H2O = U 0.9 - 1.1
Melting Point: 0°C (water)
Evaporation Rate (H2O = U 0.9 - 1.1
Water Reactive: No
pH: 6.0 - 8.0
Appearance and Odor: Murky, yellow to grey water. Musty odor.

MATERIAL SAFETY DATA SHEET FOR SDC-9 consortium
PAGE 2OF4
October 6, 2003
SECTION 4 - FIRE AND EXPLOSION HAZARD DATA
Flash Point: N/A
Flammable Limits: N/A
Extinguishing Media: Foam, carbon dioxide, water
Special Fire Fighting Procedures: None
Unusual Fire and Explosion Hazards: None
SECTION 5 - REACTIVITY DATA
Stability: Stable
Conditions to Avoid: None
Incompatibility (Materials to Avoid): Water -reactive materials
Hazardous Decomposition Byproducts: None
SECTION 6 - HEALTH HAZARD DATA
HEALTH EFFECTS
The effects of exposure to this material have not been determined. Safe handling of
this material on a long-term basis will avoid any possible effect from repetitive acute
exposures. Below are possible health effects based on information from similar
materials. Individuals hyper allergic to enzymes or other related proteins should not
handle.
Ingestion: Ingestion of large quantities may result in abdominal discomfort including
nausea, vomiting, cramps, diarrhea, and fever.
Inhalation: Hypersensitive individuals may experience breathing difficulties after
inhalation of aerosols.
Skin Absorption: N/A

MATERIAL SAFETY DATA SHEET FOR SDC-9 consortium
PAGE 3OF4
October 6, 2003
Skin Contact: May cause skin irritation. Hypersensitive individuals may experience
allergic reactions to enzymes.
Eye Contact: May cause eye irritation.
FIRST AID
Ingestion: Get medical attention if allergic symptoms develop (observe for 48 hours).
Never give anything by mouth to an unconscious or convulsing person.
Inhalation: Get medical attention if allergic symptoms develop.
Skin Absorption: N/A
Skin Contact: Wash affected area with soap and water. Get medical attention if
allergic symptoms develop.
Eye Contact: Flush eyes with plenty of water for at least 15 minutes using an eyewash
fountain, if available. Get medical attention if irritation occurs.
NOTE TO PHYSICIANS: All treatments should be based on observed signs and
symptoms of distress in the patient. Consideration should be given to the possibility
that overexposure to materials other than this material may have occurred.
SECTION 7 - SPILL AND LEAK PROCEDURES
Reportable quantities (in Ibs of EPA Hazardous Substances): N/A
Steps to be taken in case of spill or release: No emergency results from spillage.
However, spills should be cleaned up promptly. All personnel involved in the cleanup
must wear protective clothing and avoid skin contact. Absorb spilled material or
vacuum into a container. After clean-up, disinfect all cleaning materials and storage
containers that come in contact with the spilled liquid.
Waste Disposal Method: No special disposal methods are required. The material may
be sewered, and is compatible with all known biological treatment methods. To reduce
odors and permanently inactivate microorganisms, mix 100 parts (by volume) of SDC-9
consortium with 1 part (by volume) of bleach. Dispose of in accordance with local, state
and federal regulations.

MATERIAL SAFETY DATA SHEET FOR SDC-9 consortium
PAGE 4OF4
October 6, 2003
SECTION 8 - HANDLING AND STORAGE
Hand Protection: Rubber gloves.
Eye Protection: Safety goggles with side splash shields.
Protective Clothing: Use adequate clothing to prevent skin contact.
Respiratory Protection: Surgical mask.
Ventilation: Provide adequate ventilation to remove odors.
Storage & Handling:
Material may be stored for up to 3 weeks at 2-4°C without aeration.
Other Precautions: An eyewash station in the work area is recommended.
While the information and recommendations set forth herein are believed to be accurate
as of the date hereof, Shaw Environmental, Inc. MAKES NO WARRANTY WITH
RESPECT. HERETO AND DISCLAIMS ALL LIABILITY FROM RELIANCE THEREON.

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LEGEND: /
� -.... "-=-,...- ;,rfflCE: DRAWING ATE: ACAO FILE:
Mw-1 + PRE-EXISTING -.re uF 4 �� " -�- �--� Alpharetta 1 09 28 2010 B-7-SITE-FIG—I
MONITORING WELLS -_
M W-12 J
Mw-4 PHASE II 'b a ,
BUILDING 7
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SITE MAP
I
�-
MONITORING WELLS ' - __, �
mw-4 +- NEW MONITORING WELLS CLIENT: PM:
ECUSTA PAPER MILL Rg
Mw-17+ PHASE II EE/CA
MONITORING WELLS LOCATION: CHECKED:
PISGAH FOREST KM
0 250 500 NORTH CAROLINA
DESIGNED: DETAILED: PROJECT NO.: FIGURE:
APPROXIMATE SCALE IN FEET SOURCE: ENVIRONMENTAL SVCS JA JEL 131497

O 67-DPT-10 1
87-DPT-06 67- PT-11
B7-DPT-04 7'DPT-07
ROT OVA L
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B77D1 -� MW-7
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-14
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LEGEND:
Mw-1 + PRE-EXISTING "— %C -- X
MONITORING WELLS
Mw-4 -+- PHASE II
MONITORING WELLS
Mw-12 -+- DRV MONITORING WELLS
--Z---�
0 40 80
APPROXIMATE SCALE IN FEET
SOURCE: ENVIRONMENTAL SVCS
5
A
1156E GREAT OAKS WAY
SUITE 500
ALPHARETTA, GA 30022
[phone] (TEL)
Shaw~ [phone] (FAX)
FFICE: DRAWING DATE: ACAD FILE:
d horetto 9 29 2010 a-e-DPT-FIG-2
DPT SOIL AND GROUNDWATER
LOCATION MAP
MARCH 2O10
LIENT: PM:
Davidson River Village LLC RK
OCATION: CHECKED:
ECUSTA MILL AB
PISGAH FOREST, NORTH CAROLINA
DESIGNED: DETAILED: PROJECT NO.: FIGURE:
JA JEL 131497 2

!09
_ A
X X X _- X
LEGEND:
Mw-1 } PRE-EXISTING
MONITORING WELLS
Mw-4 ♦- PHASE II
MONITORING WELLS
Mw-12 -+- DRV MONITORING WELLS
PHASE II EE/CA MONITORING WELLS
A IN
x
MW-41
MW-7
0000
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0 MW-40
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MW-421_
T
6
A
1156E GREAT OAKS WAY
SUITE 500
ALPHARETTA, GA 30022
[phone] (TEL)
Shaw~ [phone] (FAX)
OFFICE: DRAWING DATE: ACAD FILE:
AlEharetta 9/29/2010 8-7-SEC LOC-FIG-3
BUILDINGS 7
CROSS-SECTION LOCATION MAP
Davidson River Village LLC I RK
LOCATION:
CHECKS
ECUSTA MILL
AB
PISGAH FOREST, NORTH CAROLINA
0 40 80
DESIGNED:
DETAILED:
PROJECT NO.:
FIGURE
APPROXIMATE SCALE IN FEET SOURCE: ENVIRONMENTAL SVCS
JA
JEL
131497

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X X ---__ X _ __
X_'``_- X
LEGEND:
mw-1 +
PRE-EXISTING
MONITORING WELLS
MW-4 -+-
PHASE 11
MONITORING WELLS
MW-12 +
DRV MONITORING WELLS
GROUNDWATER CONTOUR ELEVATION
(2119.00)
GROUNDWATER ELEVATION
i
--.mow-- z --�
0 40 80
Will
APPROXIMATE SCALE IN FEET
- MW-42
(2118.68)
SOURCE: ENVIRONMENTAL SVCS
G
A
1156E GREAT OAKS WAY
SUITE 500
ALPHARETTA. GA 30022
[phone] (TEL)
Sl1AW` [phone] (FAX)
FACE: IORAWING DATE: AD FILE:
I haretta AC
9 30 201E B-7-POT SURFACE-FIG-5
BUILDINGS 6 AND 7
POTENTOMETRIC SURFACE MAP
JULY 26 2010
LIENT: PM:
Davidson River Village LLC RK
DCATION: CHECKED:
ECUSTA MILL AB
PISGAH FOREST, NORTH CAROLINA
ESIGNED: DETAILED: PROJECT NO.: FIGURE:
JA JEL 131497 5

k ____ X __ X _-- - -�
X - X X
LEGEND:
new-1 -+
PRE-EXISTING
MONITORING WELLS
Mw-4 ♦-
PHASE II
MONITORING WELLS
Niw-1z-+-
DRV MONITORING WELLS
(2116.ss)
PHASE II EE/CA MONITORING WELLS
2116
OB7-DPT-10
-- 5
B74
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(59.3)
O O
O B PT-02
O
O MW-40 B7-DPT-03
0 40 80
APPROXIMATE SCALE IN FEET
MWAI
B7-DPT-11
B7-DPT-12
7-DPT-07 B7-DPT-13
B7-DPT-08
B7-DPT-04
B7-DPT-05
----------
X----- X
MW-42
6
A
1156E GREAT OAKS WAY
SUITE 500
ALPHARETTA, GA 30022
[phone] (TEL)
Shaw_ [phone] (FAX)
OFFICE: DRAWING DATE: ACAD FILE:
AI horetto 9 29 2010 8-7-TOT VOCs-FIG-6
TOTAL CHLORINATED SOLVENTS
ISOCONCENTRATIO MAP
MARCH 9, 2010
CLIENT: PM:
Davidson River Village LLC RK
ECUSTA MILL
PISGAH FOREST, NORTH CAROLINA
DESIGNED: DETAILED: PROJECT NO.:
SOURCE: ENVIRONMENTAL SVCS JA JEL 131497
AB
IRE
6

90
X
LEGEND:
MW-1 -t- PRE-EXISTING
MONITORING WELL:
MW-4 + PHASE II
MONITORING WELLS
MW-12* DRV MONITORING WELLS
PROPOSED INJECTION POINTS
. DPT SOIL AND GROUNDWATER LOCATIONS
PROPOSED MONITORING WELL
B7DP1`e`
O
r-- o i
SPOT REMOV.
OB7-DPT-10
�f
'U T M W-40
O B7-DPT
--�.- z __.�
0 40 80
APPROXIMATE SCALE IN FEET
50' x 50' GRID
B7-DPT-11
M W-41
B7-DPT-12
)PT-07
B7-DPT-08
F-DPT-05
I
B7-DPT-13 - r
MW-42
B7-DPT-04 6
x x
x X - - --- u
SOURCE: ENVIRONMENTAL SVCS
© 1156E GREAT OAKS WAY
SUITE 500
ALPHARETTA, GA 30022
[phone] (TEL)
SW� [phone] (FAX)
OFFICE: DRAWING DATE: JACAD FILE:
Aiphoretta 9/29/2010 B-7-PRO TREAT-FIG-7
BUILDING 7
PROPOSED AREA OF TREATMENT
:LIENT: PM:
Davidson River Village LLC RK
_OCATION CHECKED:
ECUSTA MILL AB
PISGAH FOREST, NORTH CAROLINA
DESIGNED: DETAILED: PROJECT N0: FIGURE.
JA JEL 131497 7

A �JLAi
RUDENk
North Carolina department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Coleen H. Sullins Dee Freeman
Governor Director Secretary
February 9, 2011
Mr. John B. Hanselman
Davidson River Village, LLC
36 Washington St., Suite 220
Wellesley, MA 02481
Ref: Issuance of Injection Permit WI0100126
Davidson River Village, LLC
Dear Mr. Hanselman:
In accordance with the renewal application received on October 29, 2010, and additional information received February 2,
2011, we are forwarding permit number WI0100126. This permit is to inject Anaerobic Biochem (ABC) or 3-D
Microemulsion, sodium bicarbonate, and SDC-9 at the Former Ecusta Paper Mill Building 7 Area facility located at 1
Ecusta Rd., Brevard, Transylvania County, NC 28712. This permit shall be effective from the date of issuance until
January 31, 2013, and shall be subject to the conditions and limitations stated therein, including the requirement to submit
a final project evaluation as stated in PART VII — MONITORING AND REPORTING REQUIREMENTS. Please 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 Ipplication to renew the permit 120 days prior to its expiration date. Please contact me at 919-715-6166 or
Michael.Ro;?ers(&ncdenr.gov if you have any questions about your permit.
Best Regards,
I /A-r'4�
Michael Rogers, P.G. (NC & FL)
Environmental Specialist
Underground Injection Control Program
cc: Landon Davidson, Asheville Regional Office
Amar Bumb, Shaw Environmental and Infrastructure, Inc., 3 Independence Pointe, Suite 107, Greenville, SC
29615
WI0100126 Permit File
James Bateson, DWM-Superfund Section
Jennifer Wendell, EPA Region 4
AQUIFER, PROTECTION SECTION
1636 Mail Service Center, Raleigh, North Carolina 27699-1636
Location: 2728 Capital Boulevard, Raleigh, North Carolina 27604 -
Phone: [phone] i FAX 1: 919-715-0588; FAX 2: 919-715-60481 Customer Service: 1-877-623-6748
Intemet: www.ncwateroualitv.org
dllt
Nortti.Carol tla
An Equal Opportunity t Affirmative Action Employer

F,
Rogers, Michael
From: Bumb, Amar [Am ar.Bum [e-mail]]
Sent: Wednesday, February 02, 2011 10:53 AM
To: Rogers, Michael
Cc: Bumb, Amar
Subject: RE: Davidson River Village Building 7 WI 0100126
Attachments: Tables.pdf; MW67 Log.pdf
Michael
1— Figure 7 shows our current plan for 33 injection points. However, we would like a permit for 40 injection points (as
requested in the permit) to provide us with a flexibility in the field if we need additional locations (within the same area)
to inject in case some locations do not take adequate amount of reagent.
2 — Injection interval will be 10 ft long from approximately 5 to 15 ft (see page 3, item CA). I use the word
approximately because injection interval will start at the top of the water table which may change seasonally. Actual
screen interval on the DPT injection tool is not known (different driller use different tools) but it typically varies from 1
to 5 ft. DPT injections involves advancing the screen to the desired depth, injecting, and then moving the screen up or
down the same borehole to cover the desired injection interval. Therefore, the actual screen interval of the tool is not
important.
3 — Monitoring well MW-67 was installed in November 2010 with DENR approval . Please see the attached construction
diagram.
4 — Please see attached tables file that include Table 3
5 —Source of tap water— Brevard City/Municipality.
inar ftriZd, A."' 1�'. E., CvVP
Principal Engineer/Hydrogeologist
Shaw Environmental & infrastructure
3 Independence Pointe, Suite 107
Greenville, SC 29615
[phone] direct
[phone] cell
[phone] fax
amar.bumb(a-)_shawgrg.com
www.shawgrp.com
From: Rogers, Michael.[mailto:michael.rogers(5)ncdenr.gov1
Sent: Wednesday, February 02, 2011 10:17 AM
To: Bumb, Amar
Subject: Davidson River Village Building 7 WI 0100126
Amar-
I need additional information, and/or clarification for the below:
There is a discrepancy in the total number of borings. The Application page 4 indicates 40 max, but in text part
Section E. there will be approximately 30 injection points. Please clarify. Also, confirm the screen interval.

We need the construction for `, _. ;proposed monitoring well MW-67 (screen, using, grout, bentonite seal, TD,
etc.).
Table 3 was missing. Please provide this table.
• Would you please specify the source of the municipal supplied injection water, i.e. Brevard city, Transylvania
County, etc.
Please provide this information with revised pages if necessary, in the same size and format for replacement or insertion
into the Application._
Thank you. for your cooperation.
Michael. Rogers, P.G. (NC & FL)
Environmental Specialist
NC Div of Water Quality- Aquifer, Protection Section (APS)
1636 Mail Service Center
Raleigh, NC 27699-1636
Direct Line [phone]; Fax [phone] (put to my attn on cover letter
http:/lportal. ncden r.oralweblwalaos/aworo/germ it-aoDlications#aeothermAops
E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be disclosed to third parties
****Internet Email Confidentiality Footer**** Privileged/Confidential Information may be contained in this
message. If you are not the addressee indicated in this message (or responsible for delivery of the message to
such person), you may not copy or deliver this message to anyone. In such case, you should destroy this
message and notify the sender by reply email. Please advise immediately if you or your employer do not
consent to Internet email for messages of this kind. Opinions, conclusions and other information in this message
that do not relate to the official business of The Shaw Group Inc. or its subsidiaries shall be understood as
neither given nor endorsed by it. The Shaw Group Inc.
hl�2://www.shawgEp.com

ALT-
MCDEMR,
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Coleen H. Sullins
Governor Director
November 2, 2010
John B. Hanselman
Davidson River Village, LLC
36 Washington Street, Suite 220
Wellesley, MA 02481
Subject: Acknowledgement of Application No. WI0100126
Former Ecusta Paper Mill - Building 7 Area
Injection In situ Groundwater Remediation Well (5I)
Transylvania
Dear Mr. Hanselman:
Dee Freeman
Secretary
The Aquifer Protection Section of the Division of Water Quality (Division) acknowledges receipt of your permit application and
supporting materials on October 29, 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 [e-mail]. If the
reviewer is unavailable, you may leave a message, and they will respond promptly.
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
Shaw Engineering & Infrastructure (Amar C. Bumb, PhD, PE) 3 Independence Pointe, Suite 107, Greenville, SC 29615
"z,� Permit=Applicafion`File-WI0-1-00.126 }
AQUIFER PROTECTION SECTION
1636 Mail Service Center, Raleigh, North Carolina 27699-1636
Location: 2728 Capital Boulevard, Raleigh, North Carolina 27604 One z
Phone: [phone] i FAX 1: 919-715-0588; FAX 2: 919-715-60481 Customer Service: 1-877-623-6748 No E. 3 Caro @ na
Internet: www.ncwaterauarty.ora q
An Equal Opportunity `, Affirmative Action Employer

Shaw Environmental, Inc.
Three Independence Pointe, Suite 107
Greenville, SC 29615
864.254.9285
FAX: [phone]
Shaw " shaw
October 28, 2010
Environmental, Inc.
Mr. Thomas Slusser
Aquifer Protection Section
NC Department of Environment and Natural Resources
1636 Mail Service Center
Raleigh, NC 27699-1636
Subject: UIC Permit Application
Building 7 Area Groundwater Remediation
Davidson River Village, LLC — Former Ecusta Paper Mill Site
Brevard, NC
Dear Mr. Slusser
Attached is the UIC Permit Application for in -situ bioremediation of chlorinated solvents using reagents that are
already on the NCDENR approved list. Your expedited approval of the permit is requested. Should you require
any additional information, please call me at [phone] or e-mail me at [e-mail].
Sincerely,
Amar Bumb, PE # 27625
Project Engineer
CC: Mike Singer, DRV
Ron Kenyon, Shaw
?
Jennifer Wendel, USEPA Region 4
a
Jim Bateson, NCDENR
P
Harry Zinn, NCDENR?
c�
..
i771
fTi"-
A Shaw Group Company

• AQUIFER PROTECTION REGIONAL STAFF REPORT
Date: January 6, 2011 County: Transylvania
To: Aquifer Protection Central Office Permittee: NCDENR APS UIC
Central Office Reviewer: B. Laverty Project Name: Davidson River Village LLC
Regional Login No: Application No.: WI0100126
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 ❑ No.
a. Date of site visit: January 5, 2011
b. Person contacted and contact information: Amanda Welsh (Shaw Environmental) 419 788-0413
c. Site visit conducted by: Brett Laverty
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 Infection Sites:
(If multiple sites either indicate which sites the information applies to, cony and haste a new section into the
document for each site or attach additional pages for each site)
a. Location(s): Ecusta Road Brevard, NC
b. Driving Directions: State Route 280 and turn left on Ecusta Road (Loaves). Ecusta Road is the next
light past the U.S. 276 and U.S. 64 intersection. The former Ecusta Plant entrance is approximately
300 ft on the left.
c. USGS Quadrangle Map name and number: Pisgah Forest 35082-C6-TF-024
d. Latitude:-82042115.69" Longitude: 35016'3.32"
II..;SJEI "f4NI).h:x .JtiR tiIOUllla 9.TI01t' l t'@IICA.UO& �Icis .xeiiinrr near rt�t�c(eef «r re�fce�a nfti' or minor
►ucocljcogLl ns_slcive ne.ri sr. cticrrij � �_��
De.SCH 41 Of Waste(S) And Facilities
1. please attach completed inting sheet. Facility Classification:
FORM: Staff Report.docx 1

/v
AQUIFER PROTECTION REGIONAL STAFF REPORT `
IV INJECTION WELL PERMITAPPLICATIONS (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.)
Description 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 (5QM/5QW)
® In situ remediation (5I)
❑ Closed -loop groundwater remediation effluent injection (5U Non -Discharge")
❑. Other (Specify: ____)
2. Does system use same well for water source and injection? ❑ Yes . ❑ No ® Unkown
3. Are there any potential pollution sources that may affect injection? ® Yes ❑ No
• What is/are the pollution source(s)? There are multiple releases scattered across the site. These
releases include petroleum products (WI0100091), mercury and may include other compounds or
chlorinated solvents. Contact James Bateson with NC Division of Waste Management Superfund
Section for full disclosure.
• • What is the distance of the injection well(s) from the pollution source(s)? Unknown
4. What is the minimum distance of proposed injection wells from the property boundary? Approximately 250 ft.
5. Quality of drainage at site: ®.Good ❑ Adequate ❑ Poor
6. Flooding potential of site: ❑ Low ❑ Moderate ® High (for injection site itself)
i, 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:
S. 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.
9. Injection Well Permit Renewal And Modification Only:
I . I or llr.:,.,.it p1111111 systems, are: tlle:re o ny abilorn 1,1 fit ies in Ileat I11n17p Or insect;on well opereitioi-i (e'.ii:.'turbid water,
f'aiiurl: in, ass [ill ilt e iiije_cle-d 11uicl, Door heatiq,/cooling;;,
j1 Yes ❑Igo. lf,es�rx[ail):
I For closed -loop beat rounip Systems. has systeill lost pressure or regUil'eci ITMII e-tip tl11id sine �,ernitt: I`,tiui111Q(
or la:>t inspection? ❑ Yes ❑ No. If yes, explain:
FORM: Staff Report.docx 4

AQUIFER PROTECTION REGIONAL STAFF REPORT
y EYALUATIONAND RECOMMENDATIONS
1. Provide any additional narrative regarding your review of the application.:
• The site has been contoured to promote positive drainage towards a common collection ditch.
The ditch directs runoff away from the Davidson River and is collected at the former waste water
treatment plant. Any spills or day lighting of injection fluid will captured by this ditch.
• All underground utilities and piping in and around building 7 have been removed. Preferential
flow paths may still occur along the footprint of the former utilities/piping.
• I do not see Shaw Environmental's SDC-9 cultural on the approved injectant list.
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
Identify water source used to mix and
A water.source has not been identified
prepare injection fluid
Is Shaw Environmetal's SDC-9 culture on
The SDC-9 culture does not appear on the
the approved injectant list
approved injectant list
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
6. List specific special conditions or compliance schedules that you recommend to be included in -the permit when
issued. Make sure that you provide a reason for each special condition:
Condition Reason
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 statereasons:
8. Signature of report preparer(s):
Signature of APS regional supervisor:
b 1. - * - t`i
FORM: Staff Reportdocx 6

AQUIFER PROTECTION REGIONAL STAFF REPORT
Date: January 6, 2011
ADDITIONAL REGIONALSTAFFREVIEWITEMS
FORM: Staff Report.docx 7

Roger, Michael
From: Laverty, Brett
Sent: Thursday, January 06, 2011 1:36 PM
To: Rogers, Michael
Subject: Staff Report
Attachments: UIC W10100126 Regional Staff Report.pdf
Michael,
Here is my staff report for the former.Ecusta Paper Mill in Transylvania County. I apologize for the delay.
Brett
Brett Laverty - brett.laverty0ncdenr.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: [phone]
Fax: [phone]
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.
s
1

AQUIFER PROTECTION SECTION
APPLICATION REVIEW REQUEST FORM
Date: November 4, 2010
To: ®
Landon Davidson, ARO-APS
❑
Art Barnhardt, FRO-APS
❑
Andrew Pitner, MRO-APS
❑
Jay Zimmerman, RRO-APS
From: Michael Rogers Groundwater Protection Unit
Telephone: [phone]
E Mail. Michael.Rovers@.ncmail.net
A. Permit Number: W10100126
B. Owner: Davidson River Village LLC
❑ David May, WaRO-APS
❑ Charlie Stehman, WiRO-APS
❑ Sherri Knight, W-SRO-APS
Fax. [phone]
C Facility/Oper=ation.=
❑ Proposed ® Existing ❑ Facility ❑ Operation
D. Application:
1.
Per»zit Type: ❑ Animal ❑ SFR-Surface Irrigation❑ Reuse. ❑ H-R Infiltration
❑ Recycle ❑ I/E Lagoon ❑ GW Remediation (ND)
® UIC — 5I Grroundwater Remedah_on Well
ForResiduals: ❑ Land App. ❑ D&M ❑ Surface Disposal
❑ 503 ❑ 503 Exempt ❑ Animal
2 Project Type: ® New ❑ Major Mod. ❑ Minor Mod. ❑ Renewal ❑ Renewal w/ Mod.
E. Comments/Other Information: ❑ would hke to accompany qou on as 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

1�
�aww vb"
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:[phone] Fax: [phone]
vlichael F. Easley, Governor
Dempsey Benton, Secretary
January 18, 2008
MEMORANDUM
TO: Qu Qi
Underground Injection Control Program
Aquifer Protection Section
J
FROM: Luaime K. Williams, Pharm.D., Toxicologist's
Medical Evaluation and Risk Assessment Umt
Occupational and Environmental Epidemiology Branch
North Carolina Department of Health and Human Services
Leah Devlin, DDS, MPH
State Health Director
.SUBJECT: Use of a Biological Product BAC-9(Uto Enhance Biodegradation of Groundwater
. Contaminated with Chlorinated Compounds
I am writing in response to a request for a health risk evaluation regarding the use of use
of a biological product BAC-9 ® to enhance biodegradation of groundwater contaminated with
chlorinated compounds. Based upon my review of the information submitted, I offer the
following health risk evaluation:
NCI'H
PRECAUTIONS DURING APPLICATION
The microorganisms in BAC-92) are naturally found in soil. These microorganisms are not
ordinarily associated with infection in healthy humans (except through an existing wound).
However, these microorganisms may cause infection in the young, the aged, and
immunocompromised such as individuals with AIDS, cancer, hepatitis, or with individuals
following dialysis or surgical procedures. In addition, some of the ingredients within the
BAC-9 © product have been known to cause eye, skin, and lung irritation.
North Carolina Public Health
Working fora healthier and safer North Carolina
Everywhere. Everyday. Everybody.
Location: 5505 Six Forks Rd., 2"d Floor, Room 1-2-DI • Raleigh, NC 27609
An Equal Opportunity Employer

2. Also, be -aware that mixing potassium with some of the metal and acid ingredients listed
g nts h din
the product have been. reported to be possibly explosive. Care should be taken to review the
MSDS sheets for each ingredient listed to ensure that there would be no explosive hazard.
3. If the products are released into the environment in a way that could result in a suspension of
fine solid or liquid particles (e.g., grinding, blending, vigorous shaking or mixing), then it is
imperative that proper personal protective equipment be used. The application process
should be reviewed by an industrial hygienist to ensure that the most appropriate personal
protective equipment is used.
4. Persons working with this product should at least wear goggles or a face shield, gloves, and
protective clothing. Face and body protection should be used for anticipated splashes or
sprays. Again, consult with an industrial hygienist to ensure proper protection.
5. Eating, drinking, smoking, handling contact lenses, and applying cosmetics should never be
permitted in the application area during or irmmediately following application. Safety
controls should be in place to ensure that the check valve and the pressure delivery systems
are working properly.
6. The Material Safety Data Sheets should be followed to prevent adverse reactions and
injuries.
7. Access to the area of application should be limited to the workers applying the product. In
order to minimize exposure to unprotected individuals, .measures should be taken to prevent
access to the area of application.
8. Efforts should be made to prevent contamination of existing or future wells and surface water
that may be located near the application area.
Please do not hesitate to call me if you have any questions at [phone].
cc: Dr. Robert Steffan
Shaw Environmental, Inc.
17 Princess Road
Lawrenceville, NJ 08648
Mr: Gary Birk
Ms. Susan Bostian
EOS Remediation, Inc.
1101 Nowell Road
Raleigh, NC 27607

co 0 .
North Carolina Department of Health and Human Services
Division of Public Health Epidemiology Section
1912 Mail Service Center • Raleigh, North Carolina 27699-1912
Tel [phone] • Fax [phone] -
Michael F. Easley, Governor
Carmen Hooker Odom, Secretary
November 4, 2004 z,
MEMORANDUM C
_ -orn
TO: Evan Kane oC3
Underground Injection Control Program Mrn
Aquifer Protection Section
w o
En
FROM: Luanne K. Williams, Pharm.D., Toxicologist V"
Medical Evaluation and Risk Assessment
Occupational and Environmental Epidemiology Branch
North Carolina Department of Health and Human Services
SUBJECT: Use of ABC® by Redox Tech, LLC and KB-1Tm Culture by SiREM Laboratories
and Bio-Dechlor INOCULUM to Enhance Biodegradation of Groundwater
Contaminated with Chlorinated Solvents
'I am writing in response to a request for a health risk evaluation regarding the use of
ABC® by Redox Tech, LLC and KB-1 Culture by Solutions Industrial & Environmental
Services and Bio-Dechlor INOCULUM to enhance biodegradation of groundwater contaminated
with chlorinated solvents. Based upon my review of the information submitted, I offer the
following health risk evaluation:
PRECAUTIONS DURING APPLICATION
Some effects or hazards reported to be associated with the chemicals proposed for use are
as follows:
Exposure can cause bums on the skin, eyes, nose and throat and cause dizziness,
lightheadedness, and loss of consciousness. Can be significantly absorbed through .
the skin and lungs (New Jersey Department of Health and Senior Services Hazardous
Substance Fact Sheet, Micromedex TOMEs Plus System CD-ROM Database,
Volume 62, 2004).
The chemical is highly flammable. It will be easily ignited by heat, sparks, or flames.
Vapors may form explosive mixtures with air. Vapors may travel to source of
ignition and flash back. The vapors will spread along ground and collect in low
confined areas (sewers, basements, and tanks). The storage containers for the
chemical should be kept well closed. Runoff to sewer may create fire or explosion
hazard. Containers may explode when heated (Hazardous Substances Data Bank
Micromedex TOMEs Plus System CD-ROM Database, Volume 62, 2004).
® Location 2728 Capital Boulevard • Parker Lincoln Building 9 Raleigh, N.C. 27604 An Equal Opportunity Employer

Precautions should be taken to prevent explosions to protect on -site workers,
nearby residents, and off -site workers.
• Liberates -toxic hydrogen sulfide on contact with acids. Reacts violently with carbon,
diazonium salts, n-dichloromethylamine; o-nitroaniline diazonium salt, and water.
• " Based on testing and method used to"produce the microorganisms (grown in a mineral -
salt medium), the microorganisms are not likely -to be pathogenic. These
microorganisms are not ordinarily associated with infection in healthy humans
(except through an existing wound) (Madigan MT, Martinko JM, and Parker Jack
2003. Brock Biology of Microorganisms, Tenth Edition. Pearson Education, Inc.).
However, these microorganisms may cause infection in the young, the aged, and
immunocompromised such as individuals with AIDS, cancer, hepatitis, or with
individuals following dialysis or surgical procedures. In order to provide an
additional margin of safety, it is recommended to maintain an aerobic zone around the
treatment zone, which should minimize the survival of the obligate anaerobes outside
the treatment zone.
2. If the products are released into the environment in a way that could result in a
suspension of fine solid or liquid particles (e.g., grinding, blending, vigorous shaking or
mixing), then it is imperative that proper personal protective equipment be used. The
application process should be reviewed by an industrial.hygienist to ensure that the most
appropriate personal protective equipment is used.
3. Persons working with this product should at least wear goggles or a face shield, gloves,
and protective clothing. Face and body protection should be used for anticipated splashes
or sprays. Again, consult with an industrial hygienist to ensure proper protection.
4. Eating, drinking, smoking, handling contact lenses, and applying cosmetics "should never
be permitted in the application area during or immediately following application. Safety
controls should be in place to ensure that the check valve and the pressure delivery
systems are working properly.
The Material Safety Data Sheets should be followed to prevent adverse reactions and
injuries.
6. Access to the area of application should be limited to the workers applying the product.
In.order to minimize exposure to unprotected individuals, measures should be taken to
prevent access to the area of application.
7. According to the information submitted, the area is served by a public water supply.
Based upon injections of the product at several sites, the approximate maximum distance
of travel is estimated to be 25 feet. Two unnamed tributaries to Belmont Lake are located
approximately 100 feet from the pilot test injection area. Belmont Lake "is located
approximately 130 feet downstream of the full-scale injection. Due to the shallow depth
to groundwater at the injection site, it is possible that the injected fluid could migrate into
the unnamed tributaries to Belmont Lake. Nearest residence is greater than 1,500 feet and
nearest workplace is 600 feet. Because of the potential risks associated with the use of

this product and the proximity of supply wells and surface waters, efforts should be
made to prevent contamination of existing or future wells and nearby surface waters
near the application area.
Please do not hesitate to call me if you have any questions at (9.19) 715-6429.
cc: -Mr. Mike Ranck, Underground Injection Control Program, Aquifer Protection Section
-Mr. Jerry Prosser, ERM NC, PC, 8000 Corporate Center Drive, Suite 200
Charlotte, NC 28226
-Mr. Bob Gorham, The Tuscarora Corporation, 2442 Sunset Avenue
Rocky Mount, NC 27804
-Mr. David Sordi, Ingersoll-Rand, 70 North Street, Torrington, CT 06790
-Mr. John Haselow, Redox Tech, LLC, 1006A Morrisville Parkway
Morrisville, NC 27560
-Mr. Phil Dennis, Operations Manager, SiREM Laboratories, 130 Research Lane, Suite 2,
Guelph, Ontario Canada, N1G 5G3 -

Shaw Environmental & Infrastructure, Inc.
L=1
Shaw Environmental & Infrastructure, Inc.
January 14, 2010
Thomas Slusser
NCDENR
DWQ APS
UIC Program
1636 Mail Service Center
Raleigh, NC27699-1636
Re. RTB-1 bacterial culture
Dear Mr. Slusser,
17 Princess Road
Lawrenceville, NJ 08648
609.895.5340
Fax: [phone]
I am sending you this note to confirm that the dechlorinating bacterial cultures BAC-9 marketed by EOS
Remediation, LLC and RT13-1 marketed by RedoxTech, LLC are in fact the same culture. The culture
(originally SDC-9TM) is distributed under licensing agreements between the two companies and Shaw
Environmental, Inc. Under the terms of the licensing agreements these companies are allowed to re-
name the -culture. to fit their marketing strategies..SDC-9, RTB-1, and BAC-9 are indeed the same culture
The culture is produced in and shipped from our facility.
Please feel free to contact me with any questions (609-895-5350; [e-mail])
Sincerely,
Robert Steffan, Ph.D.
Director, Biotechnology Development and Applications
A Shaw Group Company