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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. 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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