HomeMy WebLinkAboutWI0100488_Workplan_20171129 Anchor QEA of North Carolina,PLLC ANCHOR
231 Haywood Street
Asheville,North Carolina 28801 tZ QEA
828.281.3350
November 29, 2017
Mr. David Ramey
North Carolina Department of Environmental Quality
Division of Waste Management—Inactive Hazardous Sites Branch
Mooresville Regional Office
610 East Center Avenue, Suite 301
�W�
Mooresville, North Carolina 28115 RECEIVEDINC06QI
RE: Sodium Permanganate Injection Pilot Test Work Plan DEC 0 4 2D»
Tyco Electronics Corporation water Quai�Y on
Buncombe County Regional operations`fit
Site ID Number: NCDO03163730
Dear Mr. Ramey,
Anchor QEA of North Carolina, PLLC (Anchor QEA)', on behalf of TE Connectivity Corporation (TEC), has
prepared this work plan to perform a sodium permanganate(NaMnOa) injection pilot test at the TEC
Fairview, North Carolina facility located at 1396 Charlotte Highway, Fairview, Buncombe County, North
Carolina (the Site).
This pilot test is being performed to further evaluate the technical feasibility of NaMn04 injections in
order to develop a full-scale remedial plan for the Site.The injection wells that will be utilized for this test
encompass an area that is less than 10,000 square feet which is less than 5 percent of the land surface
occupied by the known extent of groundwater contamination.Therefore, the pilot test is a small-scale
injection pilot test and is permitted by rule according to Title 15A North Carolina Administrative Code
(NCAC) 02C.0200.This Work Plan provides a narrative description of the proposed work.The required
Notification of Intent to Construct or Operate Injection Wells (NOI) is provided as Attachment 1.
Background
In 2010 a NaMnOa injection pilot test performed at the Site in the vicinity of the source area (northwest
of the manufacturing building) demonstrated that NaMnOa is an effective remedial strategy for
destroying chlorinated solvent contaminant mass in the source area. However,the 2010 pilot test had a
limited radius of influence and contaminant concentrations in the pilot test injection area rebounded
quickly to pre-pilot test concentrations.Specifically,the 2010 NaMnOa pilot test used recovery well RW-7
as an injection well. During the course of the pilot test, RW-7 received approximately 1,195 gallons of a
10946 NaMn04 solution over a period of 2 days.The goal of the pilot test was to evaluate efficacy of the
Anchor QEA of North Carolina,PLLC(Anchor QEA)is formerly Altamont Environmental,Inc(Altamont),which became Anchor QEA on
December 29,2016.
PgTEgFairvleVA2017 Pilot Test\Work PlantSubmitt to Agency\171027-TEC-Fairview-Permanganate-Injection-WorkPlan.docx
November 29,2017
Page 2
NaMnO4 solution to destroy contaminant mass and to determine the radius of influence around the
injection well. Monitoring wells MW-39, MW-40, MW-41, and RW-6 were monitored following the
injection of the NaMnO4 solution. Monitoring over the month following the injection period showed
reductions in trichloroethene (TCE) and tetrachloroethene (PCE) concentrations to below detection limits
at RW-6, located approximately 10 feet to the southeast of RW-7.To the northwest of RW-7, monitoring
wells MW-39 and MW-40 also showed decreased concentrations, but were significantly less in
magnitude.The 2010 pilot test met the goals for the test, demonstrating that the radius of influence was
approximately 30 feet(Altamont 20112).
The quick rebound observed in the 2010 source area pilot test, along with source area concentrations
greater than 1%of the solubility of TCE3, suggest the possible presence of dense non-aqueous phase
liquids in the source area. For this reason,Anchor QEA believes a pilot test to demonstrate NaMnO4
injection's efficacy in reducing contaminant mass would be better suited to a less contaminated portion
of the plume.
The challenge at the TEC Site is that the contaminants of concern (COCs) are migrating under the
manufacturing building and are,therefore,difficult to access and monitor. By moving the pilot test area
to the downgradient side of the building,an existing monitoring well network can be used.to monitor
changes in the groundwater COC concentrations and geochemical parameters.The data obtained from
the pilot test on the downgradient side of the building will be used along with the 2010 pilot test data to
evaluate the viability of a full scale NaMnO4 remedy at the Site.
The goals of the 2017 pilot test are to:
• Evaluate the efficacy of NaMnO4 to reduce contaminant mass in a downgradient location south of
the manufacturing building.
• Perform interim remedial activity to assist in planning full-scale implementation of a remedial
approach. For example,this pilot test will allow:
— Determination of achievable injection flowrates and pressures
— Understanding of oxidant distribution or area of influence
— Evaluation of geochemical impacts to the aquifer including persistence of NaMnO4 injection
into a less contaminated portion of the aquifer.
The pilot test described herein will be performed in the portion of the contaminant plume located on the
southern side of the manufacturing building in the vicinity of recovery well RW-1 (See Figure 1).Anchor
QEA plans to inject NaMnO4 into the subsurface using direct-push technology at multiple locations
positioned upgradient from recovery well RW-1.A network of piezometers and monitoring wells exists in
E Altamont Environmental,Inc.2011.Sodium Permanganate Injection Pilot Test Report.Tyco Electronics Corporation,Fairview,North
Carolina.February 28.
3 The solubility concentration of TCE is 1,100,000 pg/L;1%is 11,000 pg/L.
November 29,2017
Page 3
the vicinity of RW-1 and these will be used to monitor changes in the COC concentrations following the
injection event.The piezometers and monitoring wells are screened in the deep regolith (generally 28 to
38 feet below ground surface tft-bgs]) and RW-1 is screened from above the water table to the deep
regolith (8 to 58 ft-bgs).The targeted injection depths are from the top of the water table (approximately
20 ft-bgs) to refusal (estimated at 58 ft-bgs).
As stated above,the area surrounding recovery well RW-1 has been selected for the pilot test to evaluate
the effectiveness of NaMnO4 injection in a downgradient portion of the plume. Other reasons include the
following:
• Performing the pilot test in the area around RW-1 provides downgradient treatment that may
lessen the concentrations near the downgradient property boundary.
• There is a larger monitoring well network downgradient of the manufacturing building and more
area for additional monitoring wells to be installed, if necessary.
• Spring 2017 groundwater samples collected from piezometers PZ-2, PZ-3, and PZ-5 and from
monitoring well MW-11 indicate that the area surrounding RW-1 is located in the center of the
contaminant plume.
Pilot Test Details
The following sections describe the scope of work for completion of the NaMnO4 injection pilot test in
the vicinity of recovery well RW-1.The work is broken up into two phases:an implementation phase and
an analysis and reporting phase.
Phase 1 — Implement NaMn04 Injection Pilot Test
Task 1 —Perform Pre-Injection Groundwater Quality Monitoring
Anchor QEA will perform one round of baseline groundwater monitoring prior to the NaMnO4 injection.
The baseline groundwater monitoring results will be compared with post-injection analytical results to
monitor the effects of the NaMnO4 injection within the injection area. Baseline groundwater monitoring
of the proposed injection pilot test well network area is proposed because the piezometers PZ-1, PZ-2,
PZ-3, PZ-4,and PZ-5, and monitoring well MW-11 are not included in current semiannual monitoring
events.
Piezometers PZ-1, PZ-2, PZ-3, PZ-4, and PZ-5 and monitoring wells MW-11, MW-18, and MW-19 will be
sampled prior to injection using low-flow techniques.The groundwater samples will be analyzed for the
following compounds by the indicated analytical methods:
• Chlorinated volatile organic compounds(VOCs) (U.S. Environmental Protection Agency[EPA]
Method 8260)
November 29,2017
Page 4
• Select total metals (iron, manganese, lead, chromium, arsenic,zinc, cadmium, and copper) (EPA
Method 6010)
• Mercury (EPA Method 7470)
• Nitrate (EPA Method 353.2)
• Sulfate (EPA Method 300.0)
• Chloride (Standard Method [SM] 4500)
• Alkalinity(SM 232013)
Task 2— Design the Injection System
Anchor QEA will utilize historical Site data and operational details from the previous pilot test as the
baseline design for the proposed Na injection in this pilot test.
Anchor QEA will consult with our injection contractor to determine the specific layout and approach for
performing the injection. Seven injection points are proposed to be advanced and injectant delivery will
be accomplished through the necessary transfer and metering pumps, manifolds, residence tanks,
filtration,and other appurtenances required for the injection system.The initial design concept is as
follows:
• A 10% NaMn04 solution will be injected into seven direct-push injection points located
approximately 50 feet upgradient from RW-1 (See Figure 1).
• Recovery wells RW-1, RW-2, RW-3, and RW-4 will remain operational during the injection event.
Following the injection,groundwater from RW-1 will be monitored for the arrival of NaMnO4
using a colorimeter. Once NaMn04 is observed at recovery well RW-1,the recovery well will be
turned off. Downgradient recovery wells (RW-2, RW-3 and RW-4)will remain operational to
maintain hydraulic control at the property boundary.
• Monitoring well MW-11 and piezometers PZ-1, PZ-2, PZ-3, PZ-4, and PZ-5 will be monitored for
color changes as well to evaluate the travel time of the injectant.
Task 3 —Inject NaMnO4 Using Direct-Push Technology
The permanganate natural oxidant demand (PNOD) and soil oxidant demand (SOD)were evaluated near
the source area in 2009 and 2012/2013 (Altamont 20134).The PNOD of the source area soils was
estimated to be between approximately 0.1 and 1.4 grams of NaMnO4 per kilogram of soil (g/kg). In
2009,Carus Corporation calculated a PNOD value of 1.4 g/kg using soil samples collected from
approximately 30 feet northeast of recovery well RW-7 at depths of 32 and 46 ft-bgs. In 2012/2013,
4 Altamont Environmental,Inc.2013.Permanganate Natural Oxidant Demand(PNOD)Bench Test Results.Tyco Electronics Corporation,
Non-Discharge Groundwater Remediation Permit No.WQ0036156.Fairview,North Carolina.January 29.
November 29,2017
Page 5
Altamont performed bench testing on soil samples collected immediately adjacent to monitoring well
MW-39 from a depth of 32 to 45 ft-bgs, and calculated the SOD to be between 0.1 and 1 g/kg.
Anchor QEA shared these results with Carus Corporation,who considered the 2012/2013 bench test to
be more representative and recommended using a PNOD value closer to the 0.1 g/kg concentration
(noting that PNOD values closer to the 1 g/kg may result in NaMnO4 not being completely consumed by
the contaminants in the aquifer).
Because the recovery well RW-1 area is positioned in a geologically similar location as RW-7 and MW-39,
Anchor QEA anticipates that the PNOD will be similar. As a conservative approach,Anchor QEA has used
a PNOD value of 0.35 g/kg for estimating injectant volumes.
For this pilot test,the targeted treatment area volume is approximately 13,500 cubic yards (as compared
to the approximate 960 cubic yard area targeted in the 2010 pilot test).This estimate is based on the
spacing of seven injection points on 20-ft centers and a 40-foot depth interval based on top of water
(approximately 20 ft-bgs)to top of bedrock (58 ft-bgs).The estimated pore volume is approximately
680,000 gallons.
Based on preliminary estimations for the target treatment area and the specific Site geologic
characteristics,an estimated 7,440 pounds (652 gallons) of 40% NaMnO4 solution are estimated to be
injected to reduce treatment area contaminant concentrations.
The 401/6 NaMnO4 solution will be diluted to a 10%concentration using municipal water and injected
under low pressure into the injection wells.Approximately 3,200 gallons of 10%injection solution is
estimated to be injected into the subsurface upgradient from recovery well RW-1.
Based on initial discussions with injection contractors, Anchor QEA estimates approximately 3 days to
perform the NaMnO4 injection.
Recovery well RW-1 will be operating during injection and will be monitored for the arrival of NaMnO4,
using a colorimeter,twice per day during the injection event.After the injection event has been
completed, RW-1 will be shut down and only monitored for color during post-injection monitoring.
Task 4— Perform Post-Injection Groundwater Quality Monitoring
Anchor QEA will perform post-injection groundwater monitoring to monitor the effects of NaMnO4
injection and potential rebounding effects in the injection area. Piezometers PZ-1, PZ-2, PZ-3, PZ-4, and
PZ-5; monitoring wells MW-11, MW-18, and MW-19;and recovery well RW-1 will be sampled following
completion of injection using low-flow techniques. Post-injection groundwater monitoring samples will
be collected at the following intervals:
• 2 weeks following completion of all injection activities
0 1 month following completion of all injection activities
November 29,2017
Page 6
2 months following completion of all injection activities
• 3 months following completion of all injection activities
The wells monitored post-injection will be analyzed for the following parameters by the indicated
analytical methods:
NaMnO4 using a Hach DR900 Multiparameter Portable Colorimeter
• Chlorinated VOCs(EPA Method 8260)
— If the colorimeter indicates the presence of NaMnO4 in a sample collected,then the sample
will not be analyzed for VOCs because the presence of NaMnO4 would suggest a lack of
VOCs in the collected sample.
• Select total metals (iron, manganese, lead,chromium, arsenic,zinc, cadmium,and copper) (EPA
Method 6010)
• Mercury(EPA Method 7470)
• Nitrate (EPA Method 353.2)
• Sulfate (EPA Method 300.0)
• Chloride (SM 4500)
• Alkalinity(SM 2320B)
Phase 2 - Evaluate Pilot Test Results and Prepare Summary Report
Following the completion of NaMnO4 injection and subsequent groundwater monitoring,Anchor QEA
will evaluate the collected data and prepare a final summary report for North Carolina Department of
Environmental Quality(DEQ) submittal.
Schedule
Anchor QEA has prepared an estimated schedule for the proposed tasks described above.The schedule
is presented as Table 1.Given the sequential nature of the phases and tasks,the estimated project
schedule is projected as the number of weeks following approval of this Work Plan.
November 29,2017
Page 7
If you need additional information related to this work plan, please contact me at 828.281.3350.
Sincerely,
Charles G. ippin, PG, RSM
Project Manager
cc:
Glen Foster, Director, Global Environmental,TE Connectivity Corporation
Mike Rogers, Program Manager, North Carolina Department of Environmental Quality, Underground
Injection Control
Attachments
Table 1 Estimated Schedule
Figure 1 Direct-Push Injection Point Locations and Monitoring Wells to be Used During Sodium
Permanganate Pilot Test
Attachment 1 Notification of Intent to Construct or Operate Injection Wells
c
0
9/8
EZ/L m
9L/L m
6/L
Z/L m
SZ/9 n
n/9 r
L L/9 n
82/S N
LZ/S ry
bL/S N
US
v OE/V
n EZ/4 n
9l/b N
6/v
Q z/o
92/E
6L/E
R/E
3 S/E
9z/z
6UZ
ZL/Z
S/Z
6Z/L m
ZZA m
SLA n
9/L
L/L
sZ/ZL a
eL/ZL m
L L/ZL n
t/Zl
0
LZAL m -
i E
o' p T E p
'E
ZN
y L E f a ` a a ry a
-
n
N o o
E o .E2 E r IT
G
m
E
MW-40�/ O:MW-41
RW-
I
Q,.I MW-17 LT�MW-3
I
4)MW-2
I
I
I
I
MW-4
I
iPMpouE plrecl-Push INac(n Polnl Loca4on
■ ■ as
I ■
Z-3
■
.
—
\
W 19
MW-j0F
G
W 19 f`Q RW-/
I
I i
I
I I
I
1 It 0.W-Z
LEGEND: /\
OWell Locationfor Monhodng -
Permanganatelnjecdon ■ Direct-Push Injection Point(' S-foot
0 00
b Bedrock Monitoring Well Radius of lnfluenx)
® Deep Regolith Monitoring Well - r
® Water Table Monhoring Well
0 Recovery Well
- - Use to Compressed Gas Storage Tanks SOURCE el Center for Geographic Information and
—••- Remedied.System Piping Anahh/sk,NC el Board
lilq.�ll v._.ilH:.uI�N�Ge hyeuVl:MII mFh�nJJolJ9ua 1-Nil fid lw lisi 0[l.no:l
ANCHOR Flgure1
Q „`^"y„„ Direct-Push Injection Point Locations and Monitoring Wells to be Used
During Sodium Permanganate Pilot Test
TE Connenivity Corporation
Falniaw,North Carotin.
North Carolina Department of Environmental Quality—Division of Water Resources
NOTIFICATION OF INTENT(NOI)TO CONSTRUCT OR OPERATE INJECTION WELLS
The following are`permitted by rule"and do not require an individual permit when constructed in accordance
with the rules of 15A NCAC 02C.0200. This form shall be submitted at least 2 WEEKS mior to iniection.
AQUIFER TEST WELLS(15A NCAC 02C.02201
These wells are used to inject uncontaminated fluid into an aquifer to determine aquifer hydraulic characteristics.
INSITU REMEDIATION(15A NCAC o2C.0225)or TRACER WELLS(15A NCAC 02C.022vi:
1) Passive Injection Systems - In-well delivery systems to diffuse injectants into the subsurface. Examples include
ORC socks,iSOC systems, and other gas infusion methods.
2) Small-Scale Injection Operations—Injection wells located within a land surface area not to exceed 10,000
square feet for the purpose of soil or groundwater remediation or tracer tests. An individual permit shall be required
for test or treatment areas exceeding 10,000 square feet.
3) Pilot Tests -Preliminary studies conducted for the purpose of evaluating the technical feasibility of a
remediation strategy in order to develop a full scale remediation plan for future implementation,and where the
surface area of the injection zone wells are located within an area that does not exceed five percent of the land
surface above the known extent of groundwater contamination. An individual permit shall be required to conduct
more than one pilot test on any separate groundwater contaminant plume.
4) Air Injection Wells - Used to inject ambient air to enhance in-situ treatment of soil or groundwater.
Print Clearly or Type Information. Illegible Submittals Will Be Returned As Incomplete.
DATE: November 27 2017 PERMIT NO. W Z I O O(f p (to be filled in by DWR)
A. WELL TYPE TO BE CONSTRUCTED OR OPERATED
(1) Air Injection Well......................................Complete sections B through F,K,N
(2) Aquifer Test Well.......................................Complete sections B through F,K,N
(3) Passive Injection System...............................Complete sections B through F,H-N
(4) x Small-Scale Injection Operation......................Complete sections B through N
(5) x Pilot Test.................................................Complete sections B through N
(6) Tracer Injection Well...................................Complete sections B through N
B. STATUS OF WELL OWNER: Business/Organization
C. WELL OWNER(S)—State name of Business/Agency, and Name and Title of person delegated authority to
sign on behalf of the business or agency:
Name(s): TE Connectivity Corporation
Mailing Address:Post Office Box 3608 M/S 038-34
City: Harrisburg State:PA Zip Code: 1 71 05-3 608 County:Dauphin
Day Tele No.: 717.986.7916 Cell No.:
EMAIL Address: Fax No.:
Deemed Permitted GW Remediation NOI Rev.3-1-2016 Page I
D. PROPERTY OWNER(S)(if different than well owner)
Name and Title: Same
Company Name
Mailing Address:
City: State:_Zip Code: County:
Day Tele No.: Cell No.:
EMAIL Address: Fax No.:
E. PROJECT CONTACT(Typically Environmental Engineering Firm)
Name and Title: Chuck Pippin, P.G. Senior Geologist
Company Name Anchor OEA ofNorth Carolina. PLLC
Mailing Address:231 Haywood Street
City: Asheville State:NC Zip Code: 28801 County:Buncombe
Day Tele No.: 828.771.0378 Cell No.: 704.880.2148
EMAIL Address:cpiRpin@anchoLqea.com Fax No.: 828.281.3351
F. PHYSICAL LOCATION OF WELL SITE
(1) Facility Name&Address: TE Connectivity Corporation
1396 Charlotte Hiehwav
City: Fairview County: Buncombe Zip Code:28730
(2) Geographic Coordinates: Latitude**: 35' 31 ' 29.83 "or 350. 524953
Longitude**: -82" 24 24.57 "or -82".406825
Reference Datum: NAD I P83 State Plane North Carolina FIPS 3200
Accuracy: t5 feet
Method of Collection: AreMap
**FOR AIR INJECTION AND AQUIFER TEST WELLS ONLY: A FACILITY SITE MAP WITH PROPERTY
BOUNDARIES MAY BE SUBMITTED IN LIEU OF GEOGRAPHIC COORDINATES.
G. TREATMENT AREA
Land surface area of contaminant plume: 497847 square feet
Land surface area of injection well network: 7,285 square feet (< 10,000 ftz for small-scale
injections)
Percent of contaminant plume area to be treated: 1.46 (must be<5%of plume for pilot test injections)
H. INJECTION ZONE MAPS—Attach the following to the notification.
(1) Contaminant plume map(s) with isoconcentration lines that show the horizontal extent of the
contaminant plume in soil and groundwater,existing and proposed monitoring wells, and existing and
proposed injection wells;and
Deemed Permitted GW Remediation NOI Rev.3-1-2016 Page 2
(2) Cross-section(s)to the known or projected depth of contamination that show the horizontal and vertical
extent of the contaminant plume in soil and groundwater, changes in lithology, existing and proposed
monitoring wells,and existing and proposed injection wells.
(3) Potentiometric surface map(s)indicating the rate and direction of groundwater movement,plus existing
and proposed wells.
The following Figures are attached:
Figure I—2L Exceedance Plume Map
Figure 2—Schematic Cross-Section A to A'
Figure 3—Schematic Cross-Section B to B'
Figure 4—Potentiometric Surface Map
I. DESCRIPTION OF PROPOSED INJECTION ACTIVITIES — Provide a brief narrative regarding the
purpose, scope,and goals of the proposed injection activity. This should include the rate,volume,and duration
of injection over time.
The goal of this pilot test is to determine the efficacy of NaUnO4 injections in the portion of the
contaminantplume located on the southern side ofthe manufacturing building in the vicinity ofrecovery
well RW-1. This area corresponds to a downgradient portion of the contaminant plume. Anchor QEA
proposes to inject 10%NaMnO4 solution into seven direct push injection points located approximately
50 feet upgradient from RW-1. The pilot testis designed to evaluate the feasibility of using NaMnO4 in
a portion of the contaminant plume that is downgradient of the source area.A previous NaM404 pilot
test was performed in 2010 with positive results. The data obtained during this pilot test will be
combined with the 2010 data and used to plan the full-scale implementation of the NaMn04 injections
at the Site.
For this pilot test, an estimated 3,200 gallons of 10%NaMnO4 solution is estimated for the target
treatment area volume of 13,500 cubic yards. The NaMnO4 solution will be delivered by temporary
injection wells advanced to the target depths using direct push methods. Seven injection points are
proposed and injectant delivery will be accomplished through the necessary transfer and metering
pumps,manifolds,residence tanks,filtration,and other appurtenances required for the injection system.
Anchor QEA estimates 3 days to perform the NaMn04 injections. The initial design concept is as follows
and is presented on Figure 1:
• The system will inject a 10%NaMnO4 soh ition into seven direct push injection points located
approximately 50 feet upgradient from RW-1.
• Recovery wells RW-1, RW-Z RW-3, and RW-4 will continue to extract groundwater for
treatment during the injections;however,following injection,the withdrawn groundwater from
RW-1 will be monitored for the arrival ofpermanganate through color observations using a
colorimeter. Once NaMnO4 is observed at recovery well RW-1, the recovery well will be turned
off and only RW-2, RW-3 and RW-4 will remain in operation to maintain hydraulic control at
the property boundary.
• Monitoring well MW--11 and piezometers PZ-1, PZ-2,PZ-3,PZ-4, and PZ-5 will be monitored
for color changes as well.
Deemed Permitted GW Remediation NOI Rev.3-1-2016 Page 3
J. APPROVED INJECTANTS—Provide a MSDS for each injectant.Attach additional sheets if necessary.
NOTE: Only injectants approved by the NC Division of Public Health, Department of Health and Htmum
Services can be injected. Approved injectants can be found online at httu://deg.nc.gov/about/divisions/water-
resources/water-resources-oernits/wastewater-branch/eround-water-protection/eround-water-approved-inj ectants
All other substances must be reviewed by the DHHS prior to use. Contact the UIC Program far more info(919-
807-6496).
Injectant:NaMn04
Volume of injectant: 3,200 gallons
Concentration at point of injection: 10.0%
Percent if in a mixture with other injectants:n/a
An MSDS for sodium permanganate is attached.
K WELL CONSTRUCTION DATA
(1) Number of injection wells: 7 Proposed Existing(provideGW-ls)
(2) For Proposed wells or Existing wells not having GW-Is,provide well construction details for each
injection well in a diagram or table format.A single diagram or line in a table can be used for multiple
wells with the same construction details.Well construction details shall include the following
(indicate if construction is proposed or as-built):
(a) Well type as permanent,Geoprobe/DPT,or subsurface distribution infiltration gallery
(b) Depth below land surface of casing,each grout type and depth,screen,and sand pack
(c) Well contractor name and certification number
Proposed Wells For NaMn04 Injections:
• Well type—Direct-Push Injection Point
• Number of Locations—Seven
• Depth—Target depth is 50 feet below ground surface.
• Grout—Not Applicable
• Sand Pack—Not Applicable
• Screen—Retractable Injection Tool with 60-inch exposed screen.
• NC Certified Driller—Cascade Drilling(certification number of driller will be
provided after injections completed)
L. SCHEDULES—Briefly describe the schedule for well construction and injection activities.
NaMnO4Injections-Work is tentatively scheduled for the first or second week ofDecember 2017. The
direct push installation of injection points and injectant delivery for the NaMn04 is anticipated to be
performed over a 3-day period.
Deemed Permitted GW Remediation NOI Rev.3-1-2016 Page 4
M. MONITORING PLAN—Describe below or in separate attachment a monitoring plan to be used to determine
if violations of groundwater quality standards specified in Subchapter 02L result from the injection activity.
NaMnO4 Injections
Pre-Iniection Monitoring
Anchor QEA proposes to perform one round of baseline groundwater monitoring prior to the
NaMnO4 injection. The baseline groundwater monitoring results will be compared with post-injection
analytical results to monitor the effects of the NaMnO4 injection on injection area and recovery well
RW-1 constituent concentrations.Baseline groundwater monitoring of theproposed injection pilot test
well network area is proposed because the piezometers PZ-1, PZ�2,PZ-3,PZ-4, and PZ-5, and
monitoring well MW-11 are not included in current semiannual sampling events.
Piezometers PZ-1, PZ-2, PZ-3, PZ4, and PZ-5 and monitoring wells MW-11, MW--18, and MW-19
will be sampled prior to injections using low-flow techniques. The collected groundwater samples will
be analyzed for the following compounds by the indicated analytical methods:
• Chlorinated volatile organic compounds(VOCs) (U.S. Environmental Protection
Agency[EPAj Method 8260)
• Select total metals(iron, manganese, lead, chromium, arsenic,zinc, cadmium, and
copper) (EPA Method 6010)
• Mercury(EPA Method 7470)
• Nitrate(EPA Method 353.2)
• Sulfate(EPA Method 300.0)
• Chloride(Standard Method[SMj 4500)
• Alkalinity(SM2320B)
Post-Iniection Monitoring
Anchor QEA proposes to perform post-injection groundwater monitoring to monitor the effects of
NaM404 injection and potential rebounding effects in the injection area. Piezometers PZ-1,PZ-2,Pz�
3,PZ-4, and PZ-5,monitoring wells MW-11,MW-18, and MW--19,and recovery well RW-1 will be
sampled following completion of injections using low-flow techniques.Post-injection groundwater
monitoring samples will be collected at the following intervals:
• 2 weeks following completion ofall injection activities
• 1 month following completion of all injection activities
• 2 months following completion of all injection activities
• 3 months following completion of all injection activities
The wells sampled post-injection will be analyzed for the following parameters by the indicated
analytical methods:
• Presence ofNaMnO4 using a Hach DR900 Multiparameter Portable Colorimeter.
• Chlorinated VOCs(EPA Method 8260)
• If the colorimeter indicates the presence ofNaldnO4 in a sample collected,
then the sample will not be analyzed for VOCs because the presence of
NaMnO4 would suggest a lack of VOCs in the collected sample.
• Select total metals(lead, chromium, arsenic,zinc, cadmium, and copper) (EPA
Method 6010)
Deemed Permitted GW Remediation NOI Rev.3-1-2016 Page 5
• Mercury(EPA AYWhad 7470)
• Nitrate(EPA Method 353,2)
• Sutfate (EPA Method 300,0)
• Chloride riandard Afeethod f3iWj 4S00)
• Alkalinih,(SAT 232073)
N. SIGNATURE OF APPLICANT AND PROPERTY OWNER
APPLICANT: . '7llereby certify,under penaleyof laiv, lhat I am fmnillar•wish the lnfbrinatlon submitted in this
doermmar and all atiachments thereto and lhal, based oft my r'nquby ofthoss tndivviduale immedralely responsible
for obtaining said fi ft-inatio, 1 believe that the it formation is true, accarate and complete-I any aware Ntal
there are signicatrt penalties, inchding the 17034b1111y of foes attd imprisonment, for submitting false
infortnalion. I agree to construct, operate, ntarntatn, repair, and if applicable, obandan the injection bell and
all related a purten i n ance oveordance//with the I5E AI C�/C—AC D2D0 R/t�des."
[Tif/ L. f S%fit' 11/l� c..j7liC� !V(�lL>Nr'ait�%�i4
Signature oTApp_icant Pl'int or Type Full Name and Title
PROPERTY OWNER Cif the property is not owned bythe permit eA Gant :
"As owner of theprooerh+on ruhich the injection Well(j)are to be conch-ircted and operated,l hereby conselll la
allow the applicant to conshwel each injection well as outlined in this application arul agree mal it shall be the
responsibility of the applicant to ensure that the injection Well(s) conform to the Well Consb•uolion Standards
(l5.4_NCAC 02C.02001."
"Owner"means any person who holds the fee or osier property rights in the well being constructed.A well
is real property and its construction on land shall be deemed to vest ownership ill the land owner, in the
absence of contrary agreement in writing.
Signature^otproperty Owner(i(different tlhom applicant) Print or Type Pull Name and Title
'r4n access agreement between the applicant audlu-oper0l oivner ma)+be submirled in lieu of signature on this form.
Submit the completed notification package to:
DWR—VIC Program
1636 Mail Service Center
Raleigh,NC 27699-1636
Telephone:(919)807-6464
Deemed Peanilled GIN RemediationNol Rev.3-1-2016 Pella 6
c /
! ;!
| ! !. ! •& : !_ ! r
. . ! ; .
\ �
,#
) /■ § � \ °
� } .
,
,
!
Z I
> � )
,
\ milt
2 #!
N
. Ali
P �
v 6 C N � m
� v
_ E
t $ $$ V S n 2 1 , H'S ^ n
9
I
-° � � m � 222 � NNsBx A
`o A EDLL A
s \V�
CI S
l „
O
Qy\ m
e N 6 r
Q
r
r
Ba a„5 d a a R.$ � � E �
e i �
av� u �6
t@efr � a
�"FE c r off Q 8 H R s
4 r r e
20.
Sn yEy OE � ,, o e rTi J�
p R S C 2CN
z (laaj)UOIIBA013
i
f .
{ \ \ , ■£ , : l ; � - = ; : ; , _ , �
! [ \ ! • 2 . , � � . � . . . . -
{ ; §
� ^ V | f § § ) ( } § | § || \
_ , � ! ! l ; � � , @ ! ! ; ■ , .
-
. , ! |
\ t f
. � • ; + !
§ ; /
. ` | !
! � !
r )\{\ !
, . Mill !
■ � �
-
.lf,
Eli ® :
. . �___§
)..... ! �
• $;you,
1 x 2—N 3:rivfEM@nY
III" e f I `\ • _ "°'^- •e $ a
Y
m I
R E-
CL
-- .�
Ic ��
a
a. 5
,3 d3m & � � oa
�q�aq�
RemOx®L
ISCO Reagent
CA R lJ 5® EC- SAFETY DATA SHEET according to EC directive 2001/58/EC
MATERIAL SAFETY DATA SHEET
Page 1 of 8
Section 1 C emical Product and Company Identification
PRODUCT NAME: RemOxO L ISCO Reagent Revision Date:January 2006
TRADE NAME: RemOX®L ISCO Reagent
USES OF SUBSTANCE: RemOx®L ISCO Reagent is a liquid oxidant recommended for in-situ and ex-situ
remediation of sites that require a strong oxidant.
COMPANY NAME(Europe): COMPANY ADDRESS: Carus Nalon S.L.
CARUS NALON S.L. Barrio Nalon,s/n
33100 Trubia-Oviedo
Espana,Spain
INFORMATION: (34)985-785-513
(34)985-785-513
www.caruseurove.com(Web)
COMPANY NAME(US): . causs carusnalon.com(Email)
CARUS CHEMICAL COMPANY EMERGENCY TELEPHONE: (34)985-785-513
COMPANY ADDRESS: 315 Fifth Street
Peru,IL 61354,USA
INFORMATION: (815)-223-1500
waw.caruschem.com(Web)
salesmktnn.caruschem.com (Email)
EMERGENCY TELEPHONE: (800)435—6856(USA)
(800)424-9300(CHEMTREC,USA)
815-223-1500 Other countries
Section 2 Hazardous Ingredients
Material or Component CAS No. % Hazard Data
Sodium Permanganate 10101-50-5 40 PEL/C 5 mg Mn per cubic meter of air
TLV-TWA 0.2 mg Mn per cubic meter of air
HAZARD SYMBOLS:
O Xn N
RISK PHRASES:
8 Contact with combustibles may case fire.
22 Harmful if swallowed.
50/53 Very toxic to aquatic organisms,may cause long-term effects in the aquatic environment.
SAFETY PHRASES:
17 Keep away from combustible materials.
24/25 Avoid contact with skin and eyes.
26 In case of contact with eyes,rinse immediately with plenty of water and seek medical advice
RemOx®L
ISCO Reagent
CA R U 5® EC- SAFETY DATA SHEET according to EC directive 2001/58/EC
MATERIAL SAFETY DATA SHEET
Page 2 of 8
Section 3 Hazards Identification
1. Eye Contact
RemOx@ L ISCO Reagent is damaging to eye tissue on contact. It may cause bums that result in
damage to the eye.
2. Skin Contact
Momentary contact of solution at room temperature may be irritating to the skin,leaving brown stains.
Prolonged contact is damaging to the skin.
3. Inhalation
Acute inhalation toxicity data are not available. However,airborne concentrations of RemOx@ L ISCO
Reagent in the form of mist may cause irritation to the respiratory tract.
4. Ineestion .
RemOxV L ISCO Reagent if swallowed,may cause burns to mucous membranes of the
mouth,throat,esophagus,and stomach.
Section 4 First Aid Measures
1. Eves
Immediately flush eyes with large amounts of water for at least 15 minutes holding lids apart to ensure
flushing of the entire surface. Do not attempt to neutralize chemically. Seek medical attention immediately.
Note to physician: Decomposition products are alkaline.
2. Skin
Immediately wash contaminated areas with water. Remove contaminated clothing and footwear.(Caution:
Solution may ignite certain textiles).Wash clothing and decontaminate footwear before reuse. Seek medical
attention immediately if irritation is severe and persistent.
3. Inhalation
Remove person from contaminated area to fresh air. If breathing has stopped,resuscitate and administer
oxygen if readily available. Seek medical attention immediately.
4. Ineestion
Never give anything by mouth to an unconscious or convulsing person. If person is conscious,give large
quantities of water or milk. Seek medical attention immediately.
Section 5 Fire Fighting Measures
NFPA*HAZARD SIGNS:
Health Hazard 1 = Materials which under fire conditions would give off irritating combustion
products. (less than 1 hour exposure) Materials which on the skin could cause irritation.
Flammability Hazard 0 = Materials that will not burn.
Reactivity Hazard 0 = Materials which in themselves are normally stable,even under fire exposure
conditions,and which are not reactive with water.
Special Hazard OX= Oxidizer
*National Fire Protection Association 704
FIRST RESPONDERS:
Wear protective gloves,boots,goggles,and respirator. In case of fire,wear positive pressure breathing
apparatus. Approach incident with caution. Use 2004 Emergency Response Guidebook(U.S.DOT RSPA,TC
and STC).Guide No. 140.(htlj2://hazmat.dot.gov ubs/er 2004/er 2004. d .
RemOx®L
ISCO Reagent
GA R U S® EC- SAFETY DATA SHEET according to EC directive 2001/58/EC
MATERIAL SAFETY DATA SHEET
Page 3 of 8
FLASHPOINT None
FLAMMABLE OR EXPLOSIVE LIMITS Lower: Nonflammable Upper: Nonflammable
EXTINGUISHING MEDIA Use large quantities of water.
Water will turn pink to purple if in contact with
RemOx®L ISCO Reagent.Dike to contain.
Do not use dry chemicals,CO2Halon®or foams.
SPECIAL FIREFIGHTING PROCEDURES If material is involved in fire,flood with water.
Cool all affected containers with large quantities
of water. Apply water from as far as a distance
as possible. Wear self-contained breathing
apparatus and full protective clothing.
UNUSUAL FIRE AND EXPLOSION Powerful oxidizing material. May decompose
spontaneously if exposed to heat(1350C/275'F).
May be explosive in contact with certain other
chemicals(Section 10).May react violently with
finely divided and readily oxidizable substances.
Increases burning rate of combustible material.
May ignite wood and cloth.
Section 6 Accidental Release Measures
PERSONAL PRECAUTIONS
Personnel should wear protective clothing suitable for the task. Remove all ignition sources and incompatible
materials before attempting clean up.
ENVIRONMENTAL PRECAUTIONS:
Do not flush into sanitary sewer system or surface water. If accidental release into the environment occurs,
inform the responsible authorities. Keep the product away from drains,sewers,surface and ground water and
soil.
STEPS TO BE TAKEN IF MATERIAL IS RELEASED OR SPILLED
Contain spill by collecting the liquid in a pit or holding behind a dam(sand or soil).Dilute to approximately 6%
with water,and then reduce with sodium thiosulfate,a bisulfite or ferrous salt solution.The bisulfite or ferrous
salt may require some dilute sulfuric acid(10%w/w)to promote reduction.Neutralize with sodium carbonate to
neutral pH,if acid was used.Decant or filter and deposit sludge in approved landfill.Where permitted,the sludge
may be drained into sewer with large quantities of water.To clean contaminated floors,flush with abundant
quantities of water into sewer,if permitted by federal,state,and local regulations.If not,collect water and treat
as above.
RemOx®L
ISCO Reagent
csa R u s® EC- SAFETY DATA SHEET according to EC directive 2001/58/EC
MATERIAL SAFETY DATA SHEET
Page 4 of 8
Section 7 Handling and Storage
WORK/HYGIENIC PRACTICES
Wash hands thoroughly with soap and water after handling RemOx@ L ISCO Reagent. Do not eat,drink or
smoke when working with RemOX®L ISCO Reagent. Wear proper protective equipment. Remove clothing,
if it becomes contaminated.
VENTILATION REOUIREMETNS
Provide sufficient mechanical and/or local exhaust to maintain exposure below the TLV/TWA.
CONDITIONS FOR SAFE STORAGE
Store in accordance with NFPA 430 requirements for Class II oxidizers.Protect containers from physical
damage. Store in a cool,dry area in closed containers. Segregate from acids,peroxides,formaldehyde,and all
combustible organic,or easily oxidizable materials including antifreeze and hydraulic fluid.
Section 8 Exposure Controls and Personal Protection
RESPIRATORY PROTECTION
In cases where overexposure to mist may occur,the use of an approved NIOSH-MSHA mist respirator or an air
supplied respirator is advised. Engineering or administrative controls should be implemented to control mist.
EYE
Faceshield,gogyjes,or safety glasses with side shields should be wom. Provide eyewash in working area.
GLOVES
Rubber or plastic gloves should be worn.
OTHER PROTECTIVE EOUIPMENT
Normal work clothing covering arms and legs,and rubber,or plastic apron should be worn.Caution:If clothing
becomes contaminated,wash off immediately.Spontaneous ijZnition may occur with cloth or paper.
Section 9 Physical and Chemical Properties
APPEARANCE AND ODOR Dark purple solution,odorless
BOILING POINT,760 mm Hg 105 °C
VAPOR PRESSURE(mm Hg) 760 turn at 1050C
SOLUBILITY IN WATER%BY SOLUTION Miscible in all proportions
PERCENT VOLATILE BY VOLUME 61%(as water)
EVAPORATION RATE Same as water
FREEZING POINT -15.0°C
SPECIFIC GRAVITY 1.36-1.39
PH 5-9
OXIDIZING PROPERTIES Strong oxidizer.May ignite wood and cloth.
EXPLOSIVE PROPERTIES Explosive in contact with sulfuric acid or peroxides,or
RemOx®L
ISCO Reagent
csa rz u s® EC- SAFETY DATA SHEET according to EC directive 2001/58/EC
MATERIAL SAFETY DATA SHEET
Page 5 of 8
readily oxidizable substances.
Section 10 Stability and Reactivity
STABILITY Under normal conditions,the material is stable.
CONDITIONS TO AVOID Contact with incompatible materials or heat(135°C/275°F)
could
result in violent exothermic chemical reaction.
INCOMPATIBLE MATERIALS Acids,peroxides,formaldehyde,antifreeze,
hydraulic fluids,and all combustible organic
or readily oxidizable materials,including metal powders,
With hydrochloric acid,toxic chlorine gas is liberated.
HAZARDOUS DECOMPOSITION
PRODUCTS When involved in a fire,liquid permanganate
may form corrosive fumes.
CONDITIONS CONTRIBUTING TO Material is not known to polymerize.
HAZARDOUS POLYMERIZATION
Section 11 Toxicological Information
SODIUM PERMANGANATE: Acute oral LD50 not known.
1.Acute toxicity
Irritating to body tissue with which it comes into contact. No acute toxicity data is available for sodium
permanganate. Toxicity is expected to be similar to that of potassium permanganate. The toxicity data for
potassium permanganate is given below:
Ingestion:
LD 50 oral rat: 780 mg/kg male(14 days);525 mg/kg female(14 days).
Harmful if swallowed. ALD: 1 Og.Ingestion may cause nausea,vomiting,sore throat,stomach-ache and
eventually lead to a perforation of the intestine. Liver and kidney injuries may occur.
Skin contact:
LD 50 dermal no data available.
The product may be absorbed into the body through the skin. Major effects of exposure:severe irritation,
brown staining of skin.
Inhalation:
LC 50 inhal. no data available.
The product may be absorbed into the body by inhalation. Major effects of exposure:respiratory disorder,
cough.
2.Chronic toxicity
No known cases of chronic poisoning due to permanganates have been reported. Prolonged exposure,usually
over many years,to heavy concentrations of manganese oxides in the form of dust and fumes may lead to
RemOx®L
ISCO Reagent
C A R lJ 5® EC- SAFETY DATA SHEET according to EC directive 2001/58/EC
MATERIAL SAFETY DATA SHEET
Page 6 of 8
chronic manganese poisoning,chiefly involving the central nervous system.
3. Carcinogeniciri
Sodium permanganate has not been classified as a carcinogen by ACGIH,NIOSH,OSHA,NTP,or IARC.
4.Medical Conditions Generally Aggravated by Exposure
Sodium permanganate solution will cause further irritation of tissue,open wounds,burns or mucous
membranes.
Section 12 Ecological Information
Entry to the Environment -
Permanganate has a low estimated lifetime in the environment,being readily converted by oxidizable materials to
insoluble MnO,.
Bioconcentration Potential
In non-reducing and non-acidic environments MnO,is insoluble and has a very low bioaccumulative potential.
Aquatic Toxicity
No data.
Section 13 Disposal Considerations
Waste Disposal
RemOx@ L ISCO Reagent,once it becomes a waste,is considered a D001 hazardous(ignitable)waste.For
disposal of RemOx®L ISCO Reagent solutions,follow procedures in Section 6 and deactivate the permanganate
to insoluble manganese dioxide.Dispose of it in a permitted landfill.Contact Carus Chemical Company for
additional recommendations.
Section 14 Transport Information
USA(land,D.O.T.) Proper Shipping Name: 49 CFR172.101 Permanganates,inorganic,
aqueous
solution,n.o.s.(contains sodium permanganate
Hazard Class: 49 CFR172.101....Oxidizer
HI Number: 49 CFR172.101....UN 3214
Packing Group: 49 CFR172.101....II
Division: 49 CFR172.101....5.1
European Labeling in ID Number: UN 3214
accordance Road/Rail ADRIRID Class 5.1
Transport(ADRIRID) Description of Goods: Permanganates,inorganic,aqueous
solution,n.o.s(contains sodium permanganate)
Hazard Identification No. 50
European Labeling in Proper Shipping Name: Permanganates,inorganic,aqueous
accordance with EC solution,n.o.s(contains sodium permanganate)
directive(Water,I.M.O.) Hazard Class: Oxidizer
ID Number: UN 3214
RemOx®L
ISCO Reagent
c n sx u s® EC- SAFETY DATA SHEET according to EC directive 2001/58/EC
MATERIAL SAFETY DATA SHEET
Page 7 of 8
Packing Group: II
Division: 5.1
Marine Pollutant: No
European Labeling in Proper Shipping Name: Permanganates,inorganic,aqueous
accordance with EC solution,n.o.s(contains sodium permanganate)
directive(Air,I.C.A.O.) Hazard Class: Oxidizer
ID Number: UN 3214
Packing Group: II
Division: 5.1
Section 15 Regulatory Information(Sodium Permanganate)
TSCA Listed in the Toxic Substances Control Act(TSCA)Chemical Substance Inventory.
CERCLA Not listed.
RCRA Oxidizers such as RemOxO L ISCO Reagent solution meet the criteria of ignitable
waste.40 CFR 261.21.
SARA TITLE III Information
Section 302/303 Extremely hazardous substance: Not listed
Section 311/312 Hazard categories: Fire,acute and chronic toxicity.
Section 313 RemOx@ L ISCO Reagent contains 40%manganese compounds
as part of the chemical and is subject to the reporting requirements of
Section 313 of Title III,Superfund Amendments and Reauthorization Act
of 1986 and 40 CFR 372.
FOREIGN LIST Canadian Non-Domestic Substance List,
EINECS
Section 16 Other Information
NIOSH National Institute for Occupatioml Safety and Health
MSHA Mine Safety and Health Administration
OSHA Occupational Safety and Health Administration
NTP National Toxicology Program
IARC International Agency for Research on Cancer
PEL Permissible Exposure Limit.
C Ceiling Exposure Limit
TLV-TWA Threshold Limit Value-Time Weighted Average
CAS Chemical Abstract Service
EINECS Inventory of Existing Chemical Substances(European)
Chithambarathanu Pillai(S.O.F.)
January 2006
The information contained herein is accurate to the best of our knowledge. However,data,safety standards and government regulations are
subject to change and,therefore,holders and users should satisfy themselves that they are aware of all cmrrent data and regulations relevant to
their particular use of product. CARUS CHEMICAL COMPANY DISCLAIMS ALL LIABILITY FOR RELIANCE ON THE
COMPLETENESS OR ACCURACY OR THE INFORMATION INCLUDED HEREIN. CARUS CHEMICAL COMPANY MAKES NO
WARRANTY,EITHER EXPRESS OR IMPLIED,INCLUDING,BUT NOT LIMITED TO,ANY WARRANTIES OF MERCHANTIABILITY
OR FITNESS FOR PARTICULAR USE OR PURPOSE OF THE PRODUCT DESCRIBED HEREIN. All conditions relating to storage,
RemOx®L
ISCO Reagent
CA R"5® EC- SAFETY DATA SHEET according to EC directive 2001/58/EC
MATERIAL SAFETY DATA SHEET
Page 8 of 8
handling,and use of the product are beyond the control of Carus Chemical Company,and shall be the sole responsibility of the holder or user of
the product.
... (Carus and Design)is a registered service mark of Carus Corporation.CARUSO is a registered trademark
of Carus Corporation.RemOx®is a trademark of Carus Corporation.Responsible Care®is a registered service
mark of the American Chemistry Council.
Responsible Care
Cood Chemistry at Work