WI0300181_Complete File - Historical_20120213

Goodrich, David
From: Justin Ballard [[e-mail]]
Sent: Monday, February 13, 2012 12:38 PM
To: Goodrich, David
Subject: RE: Safety -Clean Site Injection Activities under Injection Permit Number W10300181
Mr. Goodrich,
When you get the chance, I just wanted to check on the following permit addendum as listed in the email below.
Thanks.
Justin C. Ballard, P.G. I Project Geologist I ATC Associates of North Carolina, P.C.
[phone] direct 1 [phone] mobile
2725 E. Millbrook Road I Suite 121 1 Raleigh, North Carolina 27604
[phone] 1 [phone] fax I www.atcassociates.com
ATC is a leader in developing innovative Environmental, Geotechnical/CMT/Special Inspections and Health & Safety solutions.
PI_E'tSE NOTE: This rrlessage., including any attachments, may include privileged, confidential and/or inside information. Any
distribution ar use of this communication by anyone other than the intended recipient is strictly prohibited and may be unlawful. If
you are not the intended recipient, please notify the sender by replying to this message and then delete it from your computer.
From: Justin Ballard [maiIto: [e-mail]]
Sent: Tuesday, January 10, 2012 10:39 AM
To: 'Goodrich, David'
Subject: Safety -Clean Site Injection Activities under Injection Permit Number WI0300181
Mr. Goodrich,
Please find the attached pdf as ATC's Injection Permit Addendum for the Safety -Clean site in Charlotte, NC. This
attachment documents proposed changes made to the original permit application as discussed in our phone conversation
the week of December 19th, 2011. Please let me know if there are any questions. Thank you.
Justin C. Ballard, P.G. I Project Geologist I ATC Associates of North Carolina, P.C.
[phone] direct 1 [phone] mobile
2725 E. Millbrook Road I Suite 121 1 Raleigh, North Carolina 27604
[phone] 1 [phone] fax I www.atcassociates.com
From: Goodrich, David[maiIto: [e-mail]
Sent: Wednesday, December 07, 2011 9:31 AM
To: justin.ballard(aatcassociates.com
Cc: Schutte, Maria; Pitner, Andrew
Subject: Safety -Clean Site Injection Activities under Injection Permit Number WI0300181
Justin,
Thank you for contacting me this morning regarding your intentions of installing the additional monitoring well (as
required by the permit) at the subject site on Monday, December 12tn, and subsequent sampling of this well on Tuesday,
cn
December 13

It is my further understanding that injection activities will commence at the site on Wednesday, December 14tn
I am copying this transmission to the Mooresville Regional Office for their information.
Regards,
David Goodrich
Aquifer Protection Section Central Office

l 'r,
M%TC
ATC ASSOCIATES OF NORTH CAROLINA, P.C.
Engineering Individual Solutions
January 9, 2012
Mr. David Goodrich
NCDENR Division of Water Quality
Aquifer Protection Section
1636 Mail Service Center
Raleigh, North Carolina 27699-1636
RE: Injection Permit WI0300181
Safety-Kleen Service Center
2320 Yadkin Avenue
Charlotte, North Carolina
EPA ID No. NCD 079060059
ATC Project No. 45.16031.0007
Dear Mr. Goodrich:
2725 East Millbrook Road
Suite 121
Raleigh, NC 27604
Tel: [phone]
Fax: [phone]
www.atcassociates.com
N.C. Engineering License No. C-1598
ATC Associates of North Carolina, P.C. (ATC), on behalf of Safety-Kleen Systems, Inc. (S-K),
previously submitted an Injection Permit Application for the above referenced site on August 19,
2011. The NCDENR Aquifer Protection Section (APS) approved the application on October 21,
2011 under the permit number referenced above.
The original permit application provided details for two phases of injection, Phase I and Phase II.
The Phase I injection was completed on December 14, 2011. Attachment 1 contains an injection
event record for the Phase I injection event. During the Phase I injection event, the target
injection depth could not be reached due to direct -push refusal. Based'on data gathered during
the Phase I injection, ATC proposes to modify the proposed scope for the Phase II injection. The
Phase II injection will include injection into six permanent injection wells. Per our recent
telephone conversation, Attachments 2 through 5 contain excerpts from the injection permit
application which are proposed to be modified during the Phase II injection scope.
If you have questions or require additional information, please do not hesitate to contact us at
[phone].
Sincerely, .
ATC Associates of North Carolina, P.C.
Justin C. Ballard, P.G.
Project Geologist
Genna K. Olson, P.G.
Senior Project Manager

ATTACHMENT I
INJECTION EVENT RECORD

INJECTION EVENT RECORD
North Carolina Department of Environment and Natural Resources — Division of Water Quality
Permit Number WI0300181
1. Permit Information
Safety-Kleen Systems, Inc.
Pennittee
Safety-Kleen Service Center
Facility Name
2320 Yadkin -Ave, Charlotte, NC
Facility Address
2. Injection Contractor Information
ATC Associates of NC, PC
Injection Contractor / Company Name
2725 East Millbrook Road
Street Address Suite 121
Raleigh NC 27604
City State Zip Code
[phone]
Area code — Phone number
3. Well Information
Number of wells used for injection 1 direct -push
Well names IP-134
Were any new wells installed during this injection
event?
® Yes ❑ No
If yes, please provide the following information:
Number of Monitoring Wells 1 (MW-6)
Number of Injection Wells 2 direct -push
Type of Well Installed (Check applicable type):
❑ Bored ® Drilled ® Direct -Push
❑ Hand -Augured ❑ Other (specify)
Please inchide two copies of form GW-1 b for each
well installed.
Were any wells abandoned during this injection
event?
® Yes ❑ No
If yes, please provide the following information:
Number of Monitoring Wells 1 (TW-5)
Number of Injection Wells
Please include two copies of the GW-30 for each
well abandoned.
4. Injectant Information
25 LBS ZVI; 110 LBS persulfate
(Klozur); 56.74 gallons hydrogen
Injectant Type peroxide
Concentration See Attached ZET Field Report
If the injectant is diluted please indicate the source
dilution fluid. Charlotte -Mecklenburg Utilities
Total Volume Injected 100 gallons
Volume Injected per well 100 gallons
5. Injection History
Injection dates) 12/15/2011
Injection number (e.g. 3 of 5) 1 of 2
Is this the last injection at this site?
❑ Yes X❑ No
I DO HEREBY CERTIFY THAT ALL THE
INFORMATION ON THIS FORM IS CORRECT TO
THE BEST OF MY KNOWLEDGE AND THAT THE
INJECTION WAS PERFORMED WITHIN THE
STANDARDS L ID OUT IN THE PERMIT.
IG TURE INJECTION CONTRACTOR 15ATE
Justin C. Ballard, P.G.
PRINT NAME OF PERSON PERFORMING THE INJECTION
Submit the original of this form to the Division of Water Quality within 30 days of injection. Form UIC-IER
Attn: UIC Program, 1636 Mail Service Center, Raleigh, NC 27699-1636, Phone No. 919-733-3221 Rev. 07/09

NONRESIDENTIAL
WELL CONSTRUCTION RECORD
Noi-th Carolina Department oFEnvironnient and Natural ResotiI - Division of Water Quality
WELL CONTRACTOR CERTIFICATION # 3098
1. WELL CONTRACTOR:
JOHNNY BURR
Well Contractor (Individual) Name
GEOLOGIC EXPLORATION, INC
Well Contractor Company Name
176 COMMERCE BLVD
Street Address
STATESVILLE NC 28625
City or Town State Zip Code
70L 4 ) 872-7686
Area code Phone number
2. WELL INFORMATION:
WELL CONSTRUCTION PERMIT# N/A
OTHER ASSOCIATED PERMIT#(if applicable)
SITE WELL ID #(if applicable) MW-6
3. WELL USE (Check One Box) Monitoring L( Municipal/Public ❑
Industrial/Commercial ❑ Agricultural ❑ Recovery ❑ Injection ❑
Irrigation❑ Other ❑ (list use)
DATE DRILLED 12/12/11
4. WELL LOCATION:
2320 YADKIN AVENUE 28205
(Street Name, Numbers, Community, Subdivision, Lot No., Parcel, Zip Code)
CITY: CHARLOTTE COUNTY MECKLENBURG
TOPOGRAPHIC / LAND SETTING: (check appropriate box)
❑Slope ❑Valley ❑Flat ❑Ridge ❑Other
LATITUDE _°_' " DMS OR DID
LONGITUDi _°_' " DMS OR DO
Latitude/longitude source: aiPS Oropographic map
(location of well must be shown on a USGS topo map andattached to
this form if not using GPS)
5. FACILITY (Name of the business where the well is located.)
SAFETY - KLEEN
N/A
Facility Name
Facility ID# (if
applicable)
2320 YADKIN AVENUE
Street Address
CHARLOTTE
NC
28205
City or Town
State
Zip Code
SAFETY - KLEEN SYSTEMS, INC
Contact Name
1502 EAST VILLA STREET
Mailing Address
ELGIN
IL
60120
City or Town
State
Zip Code
Area code Phone number
d, TOP OF CASING IS 0.0 FT, Above Land Surface'
'Top of casing terminated
at/or below land surface may require
a variance In accordance
with 15A NCAC 2C .0118.
e. YIELD (gpm): N/A
METHOD OF TEST N/A
f. DISINFECTION: Type
N/A Amount N/A
g. WATER ZONES (depth):
Top Bottom
Top Bottom
Top Bottom
Top Bottom
Top Bottom
Top Bottom
Thickness/
: 7. CASING: Depth
Diameter Weight Material
Top 0.0 Bottom 17.0
Ft. 2 INCH SCH 40 PVC
Top Bottom
Ft.
Top Bottom
Ft.
: 8. GROUT: Depth
Material Method
Top 0.0 Bottom 13.0
Ft. PORTLANDBENTONITE SLURRY
Top Bottom
Ft.
Top Bottom
Ft.
9. SCREEN: Depth
Diameter Slot Size Material
:Top 17.0 Bottom 27.0
Ft. 2.0 in. .010 in. PVC
Top Bottom
Ft. in. in.
Top Bottom
Ft. In. in.
10. SAND/GRAVEL PACK:
Depth Size
Top 15.0 Bottom 27.0 Ft. 20-40
Top Bottom Ft.
Top Bottom Ft.
Material
FINE SILICA SAND
11. DRILLING LOG
Top Bottom Formation Description
0.0 / 7.0
7.0 / 21.0
21.0 / 27.0
RED CLAY
BROWN PARTIALLY WEATHER ROCK
GRAY ROCK
12. REMARKS:
RFNTONITF SEAL FROM 110 TO 15.0 FEET
6. WELL DETAILS:
I DO HEREBY CERTIFY THAT THIS WELL S CONSTRUCTED IN ACCORDANCE WITH
15A NC 2C, ELL CONS RUCTION ST DARDS, AND THAT A COPY OF THIS
a. TOTAL DEPTH: 27.0 FEET
: RECD D A EEN P DED TO H L O NEyV R.
�AC
12/ 2/11
b. DOES WELL REPLACE EXISTING WELL?
YES ❑ NO [� TO ATE
ATURE CERTIFIED WELL CONTRACTOR DATE
c. WATER LEVEL Below Top of Casing: 18.0 FT. JOHNNY BURR
(Use "+" if Above Top of Casing)
: PRINTED NAME OF PERSON CONSTRUCTING THE WELL
Submit within 30 days of completion to
Form GW-1b
Division of Water Qualify Information. Processing; Rev. 2/09
1617 Mail Service Center, Raleigh, NC 27699 161, Phorie (919).807 6300

NONRESIDENTIAL WELL CONSTRUCTION REcoan
North Carolina Department of Environment and Natural Resources- Division or Water Quality
WELL CONTRACTOR CERTIFICATION # 3098
1. WELL CONTRACTOR: d. TOP OF CASING IS 0.0 FT. Above Land Surface*
JOHNNY BURR 'Top of casing terminated at/or below land surface may require
Well Contractor (Individual) Name a variance in accordance with 15A NCAC 2C .011 B.
GEOLOGIC EXPLORATION, INC : e. YIELD (gpm): N/A METHOD OF TEST N/A
Well Contractor Company Name
176 COMMERCE BLVD f. DISINFECTION: Type N/A Amount N/A
Street Address ; g. WATER ZONES (depth):
STATESVILLE NC 28625 : Top Bottom Top Bottom
City or Town State Zip Cade Top Bottom Top Bottom
7004 ) 872-7686 : Top Bottom Top Bottom
1 Area code Phone number Thickness/
2. WELL INFORMATION: : 7. CASING: Depth Diameter Weight Material
WELL CONSTRUCTION PERMIT# N/A ; Top 0.0 Bottom 17.0 Ft. 2 INCH SCH 40 PVC
OTHER ASSOCIATED PERMIT#(if applicable) ; Top Bottom Ft.
SITE WELL ID #(if applicable) MW-6 : Top Bottom Ft.
3. WELL USE (Check One Box) Monitoring V Municipal/Public ❑ B. GROUT: Depth Material Method
Industrial/Commercial ❑ Agricultural ❑ Recovery❑ Injection ❑ Top 0.0 Bottom 13.0 Ft. PORTLANDBENTONITE SLURRY
i
Irrigation❑ Other ❑ (list use) : Top Bottom Ft.
DATE DRILLED 12/12/11 : Top Bottom Ft.
4. WELL LOCATION: : 9. SCREEN: Depth Diameter Slot Size Material
2320 YADKIN AVENUE 28205 Top 17.0 Bottom 27.0 Ft. 2.0 in. .010 in. PVC
(Street Name, Numbers, Community, Subdivision, Lot No., Parcel, Zip Code) ;Top Bottom Ft. In. in.
iCITY: CHARLOTTE COUNTY MECKLENBURG : Top Bottom Ft. in. in.
TOPOGRAPHIC / LAND SETTING: (check appropriate box)
❑Slope ❑Valley []Flat ❑Ridge ❑Other 10. SAND/GRAVEL PACK:
Depth Size Material
LATITUDE _°_' " DMS OR DD Top 15.0 Bottom 27.0 Ft. 20-40 FINE SILICA SAND
LONGITUDi _°_' " DMS OR DD : Top Bottom Ft.
i
Latitude/longitude source: 03PS aopographic map Top Bottom Ft.
(location of well must be shown on a USGS topo map andattached to
this form if not using GPS) 11. DRILLING LOG
S. FACILITY (Name of the business where the well is located.) Top Bottom Formation Description
SAFETY - KLEEN N/A 0.0 / 7.0 RED CLAY
Facility Name Facility ID# (if applicable) 7.0 / 21.0 BROWN PARTIALLY WEATHER ROCK
2320 YADKIN AVENUE 21.0 / 27.0 GRAY ROCK
Street Address /
CHARLOTTE NC 28205 /
City or Town State Zip Code /
SAFETY - KLEEN SYSTEMS. INC /
Contact Name /
1502 EAST VILLA STREET /
Mailing Address /
I ELGIN IL 60120 /
City or Town Stale Zip Code : 12. REMARKS:
�) BENTONITE SEAL FROM 13.0 TO 15.0 FEET
Area code Phone number
6. WELL DETAILS: ; I DO HEREBY CERTIFY THAT THIS WELL S CONSTRUCTED IN ACCORDANCE WITH
15A N 2C, ELL ON RUCTION ST DARDS, AND THAT A COPY OF THIS
a. TOTAL DEPTH: 27.0 FEET REco D A EEN P DEDTO H L O NER.
b. DOES WELL REPLACE EXISTING WELL? YES ❑ NO qI 12/12/11
ATURE WCERTIFIED WELL CONTRACTOR DATE
c. WATER LEVEL Below To of Casing: 18.FT.
p g' 0 JOHNNY BURR
(Use "+" if Above Tap of Casing) : PRINTED NAME OF PERSON CONSTRUCTING THE WELL
j Submit within 30 days of Complet(on to. Division of Water Quality InforrnatlomProcessmg'` Rev 2/rm 09 1b
1617 Mail Service Cenfer, Raleigh, NC 27699.161, Phone . [phone]

WELL ABANDONMENT RECORD
North Carolina Department of Environment and Natural Resources- Division of Water Quality
WELL CONTRACTOR CERTIFICATION # 3098
I. WELL CONTRACTOR:
JOHNNY BURR
Well Contractor (Individual) Name
GEOLOGIC EXPLORATION, INC.
Well Contractor Company Name
STREETADDRESS 176 COMMERCE BLVD.
STATESVILLE NC 28625
City or Town State Zip Code
7( 04 ) - 872-7686
Area code - Phone number
2. WELL INFORII•IATiON:
SITE WELL ID # (ifapplicable) TW-5
STATE 1\'ELL PERM [T # (ifapplicable)
COUNTY \HELL PERMIT # (ifapplicable)
DWQ or OTHER PERiMIT # (it'applicable)
WELL USE (Check applicable use): ❑✓ Monitoring ❑ Residential
❑ Municipal/Public ❑ Industrial/Commercial ❑ Agricultu•id
❑ Recovery ❑ Injection ❑ Irrigation
❑ Other (list use)
3. WELL LOCATION:
COUNTY MECKLENBURG QUADRANGLE NAME
NEARESTTOWN: CHARLOTTE
2320 YADKIN AVENUE 28205
(Street/Road Name, Number, Community, Subdivision, Lot No., Parcel, Zip Code)
TOPOGRAPHIC / LAND SETTING:
❑ Slope ❑ Valley ❑ Plat ❑ Ridge ❑ Other
(Check appropriate setting)
LATITUDE May be in degrees,
minutes, seconds, or in a
LONGITUDE" decimal format
Latitude/lougiturlesource: []CPS ❑Topographicmap
(Location of teell must be shown on a USGS iopo map and
attached to this foiui ifnot using GPSJ
4a. FACI LITY- The name of the business where illc well is located. Complete 4a and4b.
(If a residential well, skip 4a; complete 4b, well owner intannulion only.)
FACILITY ID #(ifapplicable)
NAME OP FACILITY SAFETY -KLEEN
STREETADDRESS 2320 YADKIN AVENUE
CHARLOTTE NC 28205
City or Town Stale Zip Code
4b. CONTACTPERSONAVELL OWNER:
NAME SAFETY - KLEEN SYSTEMS, INC _
STREET ADDRESS 1502 EAST VILLA STREET ELGIN, I-60120
S. 1VELL DETAILS:
a. Total Depth: 18.0 11. Diameter: 1.0 in.
b. Water Level (Below Measuring Point): a.
Measuring point is 11. above land surface.
6. CASING: Length ' Diameter
a. Casing Depth (if known): N/A ft• in.
b. Casing Removed: N A% ft. in.
7• DISINFECTION: N/A
(Amount of 65%•75% calcium hypochlorite used)
S. SEALING MATERIAL:
Neat Cement Sand Cement
Cement -" lb. Cement-- lb.
Water'- gal. Water-- gal.
Bentonite
Bentonite lb.
Type: ©Slurry ❑Pellets
Water gal.
Other
Type material PORTLAND BENTONITE SLURRY
Amount 1.75 GALLONS
9. EXPLAIN MIETE[OD OF EA•IPLACEMENT' OF MATERIAL:
-VIA TREMIE PIPE WITH PORTLAND BENTONITE
SLURRY
10. WELL DIAGRAM: Draw a detailed sketch of the well on the back of this
form showing total depth, depth and diameter of screens (if any) remaining
in the well, gravel interval, intervals ofcasing perforations, and depths and
types of till materials used.
11. DATE WELL ABANDONED 12/12/11
1 DO HEREBY CERTIFY THAT THIS WELL WAS ABANDONED IN ACCORDANCE
WITH 15A NCAC 2C, WELL CONSTR TION STANDARDS, AND THAT A COPY OF
THI :CO D HAS B • .N PROVID '0 THE WELL OWNER.
12/12/11
NATURE bf CERTIFIED WELL CONTRACTOR DATE
SIGNATURE OF PRIVATE WELL OWNER ABANDONING TI-IE WELL DATE
(fhe private well owner must be an individual who aersonnlly abandons his/her residential well
in accordoace with 15A NCAC 2C .0113.)
JOHNNY BURR
PRINTED NAME OF PERSON ABANDONING THE WELL
Submit it copy to the owner and (lie original to file Division of Water Quality within 30 days. Form GW-30
Alin: Information Management, 1617 Mail Service Center — Raleigh, NC 27699-1617, Phone No. [phone] est 568. Rev. 5/06

I .
I' F
WELL CONTRACTOR:
i
JOHNNY BURR
WELL ABANDONMENT RECORD
North Carolina Department of Environment and Natural Resources -Division of Water Quality
WELL CONTRACTOR CERTIFICATION 4 3098
Well Contractor (Individual) Nan1e
GEOLOGIC EXPLORATION, INC.
Well Contractor Company Name
STREETADDRL'SS 176 COMMERCE BLVD.
STATESVILLE NC 28625
City or Town Slate Zip Code
7� 04 )- 872-7686
Area code - Phone number
2. WELL INFORII'IATiON:
SITE WELL ID # (if applicable) TW-5
STATE IVELL PERMIT # (if applicable)
COUNTY WELL PERYIIT # (if applicable)
DWQ or OTHER PERIMIT# (ifopplicable)
11'ELL USE (Check applicable use): © Monitoring ❑ Residential
❑ Municipal/Public ❑ Industrial/Commercial ❑ Agricultural
❑ Recovery ❑ Injection ❑ Irrigation
❑ Other (list use)
3. WELL LOCATION:
COUNTY MECKLENBURG QUADRANGLE NAME
NEARESTTOWN: CHARLOTTE
2320 YADKIN AVENUE 28205
(Street/Road Name, Number, Community, Subdivision, Lot No., Parcel, Zip Code)
TOPOGRAPHIC / LAND SETTING:
❑ Slope ❑ Valley ❑ Plat ❑ Ridge ❑ Other
(Check appropriate setting)
LATITUDE May be in degrees,
minuses, seconds, or inn
LONGITUDE decimal fonnnl
Ltrtitude/longihule source: ❑ CPS ❑Topograpilic nlop
(Location Oft rell anrsl be shown on a USGS logo map and
allached to This form if not using CPS.)
4o. FACILITY -'the name critic business where the well is located. Complete 4n and4b.
(Ira residential well, skip,la; completo'Ib, well owner inlbnaation only.)
FACILITY ID #(ifapplicable)
NAME OF FACILITY SAFETY -KLEEN
STREETADDRESS 2320 YADKIN AVENUE
CHARLOTTE NC 28205
City or Town State Zip Code
4b. CONTACT PERSONAVELL OWNER:
NAME SAFETY - KLEEN SYSTEMS, INC _
STREET ADDRESS 1502 EAST VILLA STREET ELGIN, I-60120
5. WELL DETAILS:
a. Total Depth: 18.0 11. Diameter: 1.0 in.
b. Water Level (Below Measuring Point): Il.
Measuring point is R. above land surface.
6. CASING: Length Diameter
a. Casing Depth (if known): N/A R.
b. Casing Removed: N FA- R. in.
7. DISINFECTION: N/A
(Amount of 65%75% calcium hypochlorite used)
8. SEALING MATERIAL:
Neat Cement Sand Cement
Cement -' lb. Cement"" lb.
Water-- gal. Water"" gal.
Bentonite
Benlonite lb.
Type: ®Slurry ❑Pellets
Water gal.
Other
Type material PORTLAND BENTONITE SLURRY
Amount 1.75 GALLONS
9. EXPLAIN METHOD Of EMPLACEMENT OF MATERIAL:
VIA TREMIE PIPE WITH PORTLAND B NTONIT
SLURRY
10. WELL DIAGRAM: Draw a detailed sketch of the well on the back of this
form showing total depth, depth and diameter of screens (if any) remaining
in the well, gravel interval, intervals of casing perforations, and depths and
types of fill materials used.
If. DATE WELL ABANDONED 12/12/11
1 DO HEREBY CERTIFY THAT THIS WELL WAS ABANDONED IN ACCORDANCE
WITH 15A NCAC 2C, 1VELL NsTRLAFTION STANDARDS, AND THAT A COPY OF
PF
N PROVID 'O THE WELL OWNER.
12/12/11
1�4NATURL CERTIFIED WELL CONTRACTOR DATE
SIGNATURE OF PRIVATE WELL OWNER ABANDONING THE 1VELL DATE
(The privnte well owner must be an individual who personally abnadons hisfher residential well
in accordance with 15A NCAC 2C .01 13.)
JOHNNY BURR
PRINTED NA\7E OF PERSON ABANDONING THE WELL
Submit it copy to the owner and the original to the Division ofWatet• Quality within 30 days. Form GW-30
Atli: Information Management, 1617 t\'Iail Scrvice Center — Raleigh, NC 27699-1617, Phone No. [phone] est 568, Rev. 5/06

December 30, 2011
Infection Report for the Safety Kleen site in Charlotte, NC
Sent via email: Justin Ballard
Innovative Environmental Technologies, Inc. (IET) attempted an injection event on December 15,
2011 at the Safety-Kleen site in Charlotte, NC. Due to field restrictions only one injection location
was attempted, and one interval completed.
IP-134 shown below was injected at the 15-17' depth using double the amount of persulfate and
peroxide originally proposed (for that interval) because drilling refusal occurred at 19'. No other
injections were attempted due to shallow refusal across the site using a direct -push drilling rig.
Although the 17' depth was reached at one other location, (IP-B 1), it was determined that the
installation of nested, permanent injection wells would be a more efficient way of introducing the
proposed treatment slurry. An injection Log for IP-134 is included below in figure 2.
Figure 1
Injection Area "A'
Injection Grid
(1,350,FtXFt)
(5x5 FtXFt) A
F i >' i iN l� P
I
1
I
r--
jection "B"s_ is
_i_L.,_L1
I
T
2 050 FtX ISLE
_LLJ-1-4-4
I
,
�
ll__
I-(-r�-ri-I T
-,
�
i >.-I-a-�-h•iy t--•
-
r---
+-4-r+ +---
I I I
I I I
_.. WFfill" iNAIE SCALE N tEL7
".9 Resource fir Environmental Professionals Seeking Innovative Alternative Technologies"

Figure 2
A.
EAU&I
N VATIVEEWROIW1ENTALTEaiJOLOGIES,1NO
Job Name: Safety Kleen. Charlotte, NC 2011 Injections
In -Situ Chemical Oxidation using Zero Valent Iron Catalyzed Hydroxyl and Sulfate Free Radical Oxidation
Date of Injection: 12/1512011 Time of Injection: 14:00
To
Grid Location: C-16 14:07
Treatment Area B
Injection Zone
Actual
Proposed
Actual
Proposed
Actual
Proposed
Actual
Proposed
I5.17'
15-17'
0
19-21'
0
23-25'
I5-25'
Duration of Fracture (seconds):
8
8
0
8
0
8
Pressure of Pre -injection pathway development
150
150
0
ISO
0
ISO
Estimated Radius of Influence
9.5
9.5
0
95
0
95
9.5
9.5
Pounds of Klozur
110
55
0
55
0
5.5
110
165
Gallons of 50 % H,O2
2.74
1.37
0
1.37
0
1.37
2.74
4.11
Gallons of 2.5% H2O,
54
27
0
27
0
27
54
81
Gallons of Klozur1H O
100
50
0
50
0
50
I00
ISO
Lbs of ZVI
25
25
0
25
0
25
2.5
75
Pressure of Post -injection patharay development
1 50
1 50
0
1 50
1 0
SO
her Field Observations: Slight surface escape from out of injection point during shallow injection.
Please let me know if you have any questions or concerns.
Sincerely,
Ian H. Connor, Field Technician
Innovative Environmental Technologies, Inc.
www.iet-inc.net
"A Resource for Environnfental Professionals Seeking Innovative Alternative Technologies"

ATTACHMENT 2
APPLICATION FORM

State of North Carolina
Department of Environment and Natural Resources
Division of Water Quality
APPLICATION FOR PERMIT TO CONSTRUCT AND/OR USE A WELL(S) FOR INJECTION
Type 5I Wells —In Situ Groundwater Remediation / Type 5T Wells — Tracer Injection
• Do not use this form for remediation systems that extract contaminated groundwater, treat it, and reinject the treated groundwater.
• Submit TWO copies of the completed application and all attachments to the address on the last page of this form.
• Any changes made to this form will result in the application package being returned.
Application Number (to be completed by DWQ):
I. GENERAL INFORMATION:
1. Applicant's Name (generally the responsible party): safety-Kleen Systems, Inc.
2. Signing Official's Name: Robert A. Schoepke, P.G. Title: Director - Remediation
3. Mailing address of applicant: 1502 East Villa Street, 2nd Floor
City: Elgin State: Illinois Zip: 60120
Telephone number: [phone] Fax number: [phone]
4. Property Owner's Name (if different from Applicant): N/A - Property owner same as applicant
5. Property Owner's mailing address: 1502 East Villa Street, 2nd Floor
City: Elgin State: Illinois Zip:60120
6. Name and address of contact person who can answer questions about the proposed injection project:
Name: Genna K. Olson, P.G. Title: Senior Project Manager
Company: ATC Associates of North Carolina, PC
Address: 2725 East Millbrook Road, Suite 121
City: Raleigh State: NC Zip:27604
Telephone number: [phone] Fax number: [phone]
Email Address: [e-mail]
II. PERMIT INFORMATION:
1. Project is: ❑ New ❑x Modification of existing permit ❑ Renewal of existing permit without modification
❑ Renewal of existing permit with modification
2. If this application is being submitted for renewal or modification to an existing permit, provide:
existing permit number W10300181 and the issuance date 10/21/2011
For renewal without modifications, fill out sections I & II only, sign the certification on the last page of this
form, and obtain the property owner's signature to indicate consent (if the applicant is'not the owner).
For all renewals, you must submit a status report including monitoring results of all injection activities to
date.
Revised 8/07 UIC-5I/5T Page I of 7

APPLICATION FOR PERMIT TO CONSTRUCT AND/OR USE A WELL(S) FOR INJECTION
Type 51 Wells — In Situ Groundwater Remediation / Type 5T Wells — Tracer Injection
III. INCIDENT & FACILITY DATA
A. FACILITY INFORMATION
1. Facility name: Safety-Kleen Systems, Inc.
2. Complete physical address of the facility: 2320 Yadkin Avenue
City: Charlotte County: Mecklenburg State: NC Zip: 28205
B. INCIDENT DESCRIPTION
1. Describe the source of the contamination:
Safety-Kleen Systems, Inc. (S-K) currently operates a hazardous material storage and recycling facility that
began operations on June 5, 1978. The facility currently maintains a Part B Resource Conservation and
Recovery Act (RCRA) permit for hazardous waste storage. In the early 1980s, prior to installation of the current
waste mineral spirits storage system at the facility, used mineral spirits were placed into a.500-gallon
underground storage tank (UST) and then into a 10,000-gallon capacity UST. The 500-gallon UST provided
in -line solids settling for the waste mineral spirits prior to accumulation in the 10,000-gallon UST. The UST
system was operated for a five-year period from 1980 until its removal in August 1985. The waste mineral spirits
UST system constitutes the solid waste management units (SWMUs) that have been the focus of historical soil
and groundwater investigation activities.
2. List all contaminants present in soils or groundwater at the site (contaminants may be listed in groups, e.g.,
gasoline, diesel, jet fuel, fuel oil, chlorinated ethenes, chlorinated ethanes, metals, pesticides/herbicides, etc):
Mixture of chlorinated and petroleum solvent constituents.
3. Has LNAPL or DNAPL ever been observed at the site (even if outside the injection zone)?
❑ Yes If yes, list maximum measured separate phase thickness feet
❑X No If no, list maximum concentration of total VOCs observed at site: 27 ppb
4. Agency managing the contamination incident:
❑ UST Section ❑ Superfund Section (including REC Program and DSCA sites)
❑ DWQ Aquifer Protection Section ❑ Solid Waste Section
© Hazardous Waste Section ' ❑ Other:
5. Incident managers name Mr. Adam Ulishney and phone number [phone]
6. Incident number or other site number assigned by the agency managing the contamination incident:
EPA ID No. NCD 079060059
C. PERMITS
List all permits or construction approvals that have been issued for the facility or incident, including those not
directly related to the proposed injection operation:
L , Hazardous Waste Management program permits under RCRA: NCD 079060059-R
2. DWQ Non -Discharge or NPDES permits: None identified.
3. County or DEH subsurface wastewater disposal permits: None identified.
4. Other environmental permits required by state or federal law: Mecklenburg County Permit 70000633 for well construction.
Revised 8/07 UIC-5I/5T Page 2 of 7

APPLICATION FOR PERMIT TO CONSTRUCT AND/OR USE A WELL(S) FOR INJECTION
Type 5I Wells — In Situ Groundwater Remediation / Type 5T Wells — Tracer Injection
IV. INJECTION DATA
A. INJECTION FLUID DATA
l . List all proposed injectants.
NOTE: Any substance to be injected as a tracer or to promote in situ remediation must be reviewed by the
Occupational and Environmental Epidemiology Section (GEES) of the Division of Public Health, Department of
Health and Human Services. Review the list of approved iniectantsT or contact the UIC Program to determine if
the injectants you are proposing have been reviewed by OEES.
Injectant:_ Zero Valent Iron (ZVI)
Concentration at point of injection: Refer to Appendix 1 - Product Data
Injectant: Persulfate
Concentration at point of injection: Refer to Appendix 1 - Product Data
Injectant: Hydrogen Peroxide
Concentration at point of injection: Refer to Appendix 1 - Product Data
Injectant:
Concentration at point of injection:
Injectant:
Concentration at point of injection:
2. Source of fluids used to dilute or chase the injectants listed above:
❑ None
© Municipal water supply
❑ Groundwater from private well or any well within 'Amile of injection site
❑ Air
❑ Other:
3. If any well within 'A mile of injection site, a private well, or surface water is to be used as the fluid source, supply
the following information:
a. Location/ID number of source: N/A
b. Depth of source: N/A
c. Formation: N/A
d. Rock/Sediment tune: N/A
e. In Attachment C, provide a current, complete chemical analysis of the water from the source well, including
analyses for all contaminants suspected or historically recognized in soil or groundwater on the site.
NOTE: If contaminated groundwater is to be used as the dilution or chase fluid, this is not the proper permit
application form. You must apply for a closed -loop groundwater remediation permit using application form
GWRS.
Revised 8/07 UIC-5I/5T Page 3 of 7

APPLICATION FOR PERMIT TO CONSTRUCT AND/OR USE A WELL(S) FOR INJECTION
Type 5I Wells — In Situ Groundwater Remediation / Type 5T Wells — Tracer Injection
B. PROPOSED OPERATING PARAMETERS
1. Duration of Injection:
Maximum number of separate injection events: 1 Event (Description below for Phase II event, Phase I event already completed)
Expected duration of each injection event: 2 days
Expected duration between events (if more than one event): NA
2. Injection rate per well: 1 to 10 gallons per minute (gpm)
3. Total Injection volume: 966 gallons per day (gpd); 1,932 gallons per event (if separate events)
4. Injection pressure: 10 to 120 pounds/square inch (psi)
5. Temperature at point of injection: 60 to 70 of
6. Brieflv describe how the above parameters will be measured and controlled:
The injection pressure will monitored using a pressure gauge. Valves and the injection pump will be used to
control flow and pressure. The temperature of the water supply will determine the temperature of the remaining
injection fluids.
7. Estimated hydraulic capacity of the well: 1 to 10 gpm
C. INJECTION WELL CONSTRUCTION DATA
1. Injection will be via:
❑ Existing well(s) proposed for use as an injection well. Provide the data in (2) through (6) below to the best of
your knowledge.
❑X Proposed well(s) to be constructed for use as an injection well. Provide the data in (2) through (6) below as
proposed construction specifications.
2. Well Drilling Contractor's Name:Geologic Exploration (injection wells)
NC Well Contractor Certification number: 2345
3. Date to be constructed: TBn pending approval Number of borings: 6
Approximate depth of each boring (feet): 25
4. Screened interval/Injection interval of injection wells:
is la
Depth: 21 to 25 feet below ground surface (if multiple intervals, indicate shallowest and deepest depth).
5. Well casing (N/A if injection is through direct push rods):
Type: ❑x PVC ❑ Stainless steel ❑ Other:
Q 15
Casing depth: o to 21 ft.
31
Grout (N/A if injection is through direct push rods):
Type: ❑ Cement ❑ Bentonite ❑X Other: Portland/Bentonite mixture
Grout depth: 0 to 13 ft.
Revised 8/07 UIC-5I/5T Page 4 of 7

APPLICATION FOR PERMIT TO CONSTRUCT AND/OR USE A WELL(S) FOR INJECTION
Type 5I Wells — In Situ Groundwater Remediation / Type 5T Wells — Tracer Injection
V. ATTACHMENTS
Provide the following items as attachments with the given headings:
A. SITE HISTORY
Provide a brief description of the site history including:
(1) site usage historically and present,
(2) origin of the contamination,
(3) previous remedial action(s).
NOTE: G.S. 89E-18 requires that any geologic plans, reports, or documents in which the performance is related to the
public welfare or safeguarding of the environment be prepared by a licensed geologist or subordinate under his or her
direction. G.S. 89E-13 requires that all drawings, reports, or documents involving geologic work which shall have been
prepared or approved by a licensed geologist or a subordinate under his or her direction be signed and sealed by him or
her.
B. HYDROGEOLOGIC DESCRIPTION
Provide a hydrogeologic description, soils description, and cross section of the subsurface to a depth that includes the
known or projected depth of contamination. The hydrogeologic description shall include:
(1) the regional geologic setting;
(2) significant changes in lithology;
(3) the hydraulic conductivity, transmissivity, and specific yield of the aquifer to be used for injection, including a
description of the test(s) used to determine these parameters; and
(4) the depth to the mean seasonal high water table.
C. INJECTION FLUID COMPOSITION
Describe the chemical, physical, biological and radiological characteristics of each injectant. Attach the Material Safety
Data Sheet (MSDS) for each injectant. If a private well or a well within 'A mile of the injection site is used as the source
well, include chemical analysis of source fluid here.
D. INJECTION RATIONALE
Attach a brief description of the rationale for selecting the injectants and concentrations proposed for injection, including:
(1) goals of the injection project;
(2) a description of the reactions between the injectants and the contaminants present including specific breakdown
products or intermediate compounds that may be formed by the injection; and
(3) summary results of modeling or testing performed to investigate the injectant's potential or susceptibility to change
(biological, chemical or physical) in the subsurface.
E. INJECTION PROCEDURE AND EQUIPMENT
Provide a detailed description of all planned activities related to the proposed injection including but not limited to:
(1) construction plans and materials;
(2) operation procedures;
(3) a detailed diagram of the surface and subsurface portions of the system; and
(4) a planned injection schedule.
F. MONITORING PLAN
Provide a plan for monitoring the results of the injection, including:
(1) a list of existing and proposed monitoring wells to be used;
(2) a list of monitoring parameters and analytical methods to be used; and
(3) a schedule for sampling to monitor the proposed injection.
NOTE: The selected monitoring wells must be located so as to detect any movement of injection fluids, process by-
products, or formation fluids outside the injection area or zone. The monitoring parameters should include the target
contaminants as well as secondary or intermediate contaminants which may result from the injection and other
parameters which may serve to indicate the progress of the intended reactions, such. as pH, ORP, dissolved oxygen, and
Revised 8/07 UIC-5I/5T Page 5 of 7

APPLICATION FOR PERMIT TO CONSTRUCT AND/OR USE A WELL(S) FOR INJECTION
Type 5I Wells —In Situ Groundwater Remediation / Type 5T Wells —Tracer Injection
other electron acceptors and donors. The monitoring schedule should be consistent with the pace of the anticipated
reactions and rate of transport of the injectants and contaminants.
G. WELL DATA
Provide a tabulation of data on all existing or abandoned wells within'/4 mile of the injection well(s) which penetrate the
proposed injection zone, including, but not limited to, monitoring wells and wells proposed for use as injection wells.
Such data shall include a description of each well's use (water supply, monitoring, etc), total depth, screened or open
borehole depth interval, and well construction or abandonment record, if available.
H. MAPS
Attach the following scaled, site -specific maps:
(1) Area map based on the most recent USGS 7.5' topographic map of the area, at a scale of 1:24,000 and,
showing the location of the proposed injection site.
(2) Site map including:
a. all property boundaries;
b. all buildings within the property boundary;
c. existing and proposed injection wells or well field(s)
d. any existing sources of potential or known groundwater contamination, including waste storage,
treatment or disposal systems within''/4 mile of the injection well or well system;
e. all surface water bodies within'/4 mile of the injection well or well system; and
f. all existing or abandoned wells within 'Amile of the injection well(s) which penetrate the proposed
injection zone, including, but not limited to, monitoring wells and wells proposed for use as injection
wells.
(3) Potentiometric surface map(s) including:
a. direction of groundwater movement
b. existing and proposed monitoring wells
c. existing and proposed injection wells
(4) Contaminant plume map(s) including:
a. the horizontal extent of the contaminant plume, including isoconcentration lines
b. existing and proposed monitoring wells
c. existing and proposed injection wells
(5) Cross-section(s) to the known or projected depth of contamination, including:
a. horizontal and vertical extent of the contaminant plume, including isoconcentration lines
b. major changes in lithology
Revised 8/07 UIC-5I/5T Page 6 of 7

APPLICATION FOR PERMIT TO CONSTRUCT AND/OR USE A WELL(S) FOR INJECTION
Type 51 Wells —In Situ Groundwater Remediation / Type 5T Wells —Tracer Injection
VI. CERTIFICATION
I, Robert A. Schog�,6PQ�E of si,nin, oft;cial) ,hereby certify under penalty of law that
I have personally examined and am familiar with the information submitted in this document and all attachments
thereto and that, based on my inquiry of those individuals immediately responsible for obtaining said information,
I believe that the information is true, accurate and complete. I am aware that there are significant penalties,
including the possibility of fines and imprisonment, for submitting false information. I agree to construct,
operate, maintain, repair, and if applicable, abandon the injection well(s) and all related appurtenances in
accordance with the approved specifications and conditions of the Permit.
Signature: /l Date:
Title: Director - Remediation
If authorized agent is acting on behalf of the applicant, supply a letter signed by the applicant authorizing the
above agent.
V11. CONSENT OF PROPERTY OWNER (if the property is not owned by the applicant)
("Owner" means any person who holds the fee or other property rights in the well being constructed. A well is
real property and its construction on land shall be deemed to vest ownership in the land owner, in the absence of
contrary agreement in writing.)
I, N/A -Property oVMM, La fii!� c RRltf as owner of the property on which the,
injection well(s) are to be constructed and operated, hereby consent to allow the applicant to construct each
injection well as outlined in this application and agree that it shall be the responsibility of the applicant to ensure
that the injection well(s) conform to the Well Construction Standards (Title 15A NCAC 2C .0200)
Signature: Date:
Submit TWO copies of the completed application package, including all attachments, to:
UIC Program
Aquifer Protection Section
North Carolina DENR-DWQ
1636 Mail Service Center
Raleigh, NC 27699-1636
Telephone [phone]
Revised 8/07 UIC-05T Page 7 of 7

ATTACHMENT 3
APPLICATION TEXT

E. INJECTION PROCEDURE AND EQUIPMENT
Phase II Iniection
During the second phase of injection, six permanent injection wells will be installed. The wells
will each be constructed of nested 1-inch diameter polyvinyl chloride (PVC) with screened
intervals of 15 to 18 feet bgs and 21 to 25 feet bgs. Note that the final screen intervals will be
determined in the field based on depth to bedrock but will not exceed a depth of 25 feet bgs. The
injection well screen will be 30 slot size and the filter pack will consist of pea gravel. The Phase
II injected fluids will include 3,298 pounds of sodium persulfate in solution and 1,932 gallons of
2.5 percent hydrogen peroxide. Proposed injection locations are shown on Figure 8. A proposed
injection well construction diagram is included as Figure 9.
6

ATTACHMENT 4
INJECTANT CONCENTRATIONS

SAFETV4(LEEN, CHARLOTTE, NC
Pennenant Injection Wells
Saturated
Zone
Injection Event
Parameters
Units
Assumptions
Target Area
FLX Ft.
3600
Injection Radii
Ft
15
Soil Absorbsi0n Correction for GAD Constant
%
13
Area of influence of Remediation Injections)
Sq. Ft
706.85775
Estimated Number of Injections to Treat Area
4lnjections
6
vertical impacted mire
Ft.
3
Target Zone
15-18,
Total Volumes Targeted
Cu Yd.
400
Porosity
%
30.0011,
Mass of soil to be targeted
Ibs
940000
Mass of soil to be targeted
grans _
381360000
Volume of Groundwater targeted
gals
24300
Contar inam Conc.
Pp.
20 Calculations Targeted Compounds
Mass of Comar inapt- water
lb.
4.0581 Ave Mot Mass of Targeted Compounds g/nnl
92
Mass of Comaninant-rater
Grams
1842.3774 Moles
260.71906
Mass of Comaninent-sail
lb.
48,7748372 Mole Mass of H2O2
34
Mass of Contaminant -soil
Grarrs
22143.77609 Mole. of H2O2
4232.85062
Mass of Comanmem Targeted
Gra-
23986.16349 Mole Mass of Persulfate
238
Mass of Containment Targeted
Ibs
52.8329372 Moles of Na2S2O8
3746.07279
Calculated soil conc.
pp.
62.89635381
Grams of H2O2 Required
Grans
143916.9209
Lbs of H2O2 Required
Ito
316.9976232
'
Ratio of 52O3 to targeted Conpouns
Ratio
21
Grerm of sodium pemul/ate
grans
503709.2232 Molar Ratio Cale
Pounds of Sodium Persulfate Required
Pounds
1109.491681 Targeted Compounds
1
Targeted percentage of ZVI in pore volume
%
0.00 % H2O2
16.24
Pounds of ZVI (3 micron) required
pounds
0 Na2S2O8
14.37
Decomposition Rate of Sodium Persulfate
%/day
1.10%
Targeted Longevity of Persulfate
days
70.00
Total Persulfate Calcuated dosage
pounds
1963.80
Injection Summary
Number of Injection Locations
6.00
Injection Depth
15.18,
Pounds of 2-4 Mcron ZVI
0.00
Pounds of Sodium Persulfate
1109.49
Pounds of Persulfate with Longevity
1963.80
Galons of 50% H2O2
60.38
Injection Point Summary, - Number of Intervals
1.00
Injection Zones
15-18,
Pounds of ZVI per interval
0
Pounds of Sodium Persulfate per interval
185
Pounds of Sodium Persulfate per interval w/ longevity
327 6.95
Begs Persulfate per interval
Gallons of 5% F2O2 per interval
101
Cost Basis Per injection Event
Cost Basis Event pl
$[Unit
Extended Cost
Pounds of ZA (3 micron) required
0.00
$6.50
$0.00
Pounds of Sodium Persulfate Requlmd
1963.80
$3.39
$6,65728
Gallons of 50% H2O2 Required
61.00
$10.25
$62525
Number of Injection Point. per Event
6.00
Days of Injection Trailer
0.75
$4,000.00
$3.000.00
Administrative Costs
0.5
$1,250.00
$625.00
Material Cost (Including o-fle management etc)
Total
$10,907.53

SAFETY-KLEEN, CHARLOTTE, NC
Permenant Injection Wells
Saturated Zone
Injection Event
Parameters -
Units
Assumptions
Target Area
FLX Ft.
- 3600
,
Injection Radii
Ft
15
Soil Absorbsion Correction for GAC Constant
%
13
Area of influence of Rerrodiation Injection(s)
Sq. Ft
706.85775
Estimated Number of Injections to Treat Area
#Injection
6
vertical impacted zone
Ft.
4
Target Zone
21-25
Total Volume Targeted
Cu. Yd.
533,3333333
Porosity
%
30.00%
Mass of soil to be targeted
be
1120000
Mass of soil to be targeted
grans
508480000
Volume of Groundwater targeted
gals
32400
COMamnant Conc.
'I'm
5 Calculations Targeted Compounds
Mass of Contaninant - water
Ib.
1.3527 Ave Mol Mass of Targeted Compounds g/mol
92
Mass of Cordamnar4 -water
Grans
614.1258 Moles
185.967572
Mass of Contamnam-soil
lb.
36.33033217 Mole Mass of H2O2
34
Mass of Comamnant-soil
Grams
16493.97081 Moles of H2O2
2615.89656
Mass of Contamnera Targeted
Grans
17108.09661 Mole Mass of Persulfate
238
Mass of Contamnent Targeted
Ibs
37.68303217 Moles of Na2SZOe
2544.64966
Calculated soil corn.
pp.
33.64556444
Grams of F12O2 Required
Grans
85540.48304
Lbs of H2O2 Required
Ibs
188.4151609
Ratio of 52O3 to targeted Conpouns
Ratio
20
Grans of sodium persulfate
grans
342161.9321 Molar Ratio Cale
Pounds of Sodium Persulfate Required
Pounds
753.6606435 Targeted Compounds
1
Targeted percentage of ZVI in pore volume
%
0.00% H2O2
13.53
Pounds of ZVI (3 micron) required
pounds
0 Na2S2O8
13.68
Decomposition Rate of Sodium Persulfate
%/day
1.10%
Targeted Longevity of Persulfate
days
70.00
Total Persulfate Calcuased dosage
pounds
1333.98
Injection Summary
Number of Injection Locations
6.00
Injection Depth
21-25'
Pounds of 2-4 micron ZVI
0.00
Pounds of Sodium Persulfate
753.66
Pounds of Persullate with Longevity
1333.98
Galons of 50% H2O2
35.89
Injection Point Summary - Number of intervals
1.00
Injection Zones
21-25'
Pounds of ZVI per Interval
0
Pounds of Sodium Persulfate per interval
126 -,
Pounds of Sodium Persulfate per interval w/ longevity
222 4.04
Bags Persulfate per Interval
Gallons of 2.5% F12O2 per interval
120
Cost Basis Per Injection Event
Cost Basis Event 01
$/Unit
Extended Cost
Pounds of ZVI (3imicmn) required
0.00
$6.50
$0.00
Pounds of Sodium Persulfate Required
1333.98
$3.39
$4.522.19
Gallons of50%H2O2 Required
36.00
- $10.25
$369.00
Number of Injection Points per Event
6.00
Days of Injection Trailer
0.75
$4.000.00 -
$3.000.00
Administrative Costs
0.5
$1,250.00
$625.00
Material Cost (Including on -site management etc)
Total
$8,516.19

Bedrock Injection Area (3,600 FtXFt) `
cOru:rT=�;��
1
F '
Pr7 -
E
m
'
E
}
a t._...., ... .... x..._
.._ .... -
--..
ltM-7 ---- - ,.
f.

ATTACHMENT 5
FIGURES

--. ,..__._ ,......... ,--....... ........... ..................
'— — —'—
Note that the injection area extends to
O
MW-2 based on historical detections of
-I
COCs above 2L Standards in well MW-2.
If this well continues to show no exceedences
of 2L Standards during future sampling
1
events, some injection locations may be
DUMPSTER
moved to focus more on the area of
'
known groundwater impact.
PICNIC,
'
AREA
GRAVEL
I CONCRETE
I
OFFICE
'
7.
'S
a o'
I -'LANDS'
..a.t SIDEWALK
*BMW- 1B
E"
- - - - -
I
GRAVEL
1
� 1
_
!
PAVED
BMW -IA
!
..... .CONCRETE........y
0-4
�11
i
I
1
r
1 1
5
TW-OMW 4
® �-13-6
PAVED
QQ 5
W
w
STORAGE
MW-5
rw
o
�<<ROOM
WAREHOUSE
® 18-2
H
r I
l•
i i
x
o
4
1
�. t z.o'
u
O
r
�r U
w
II
TW 3
C
Q
i W ! �'
_..______...._....._I
LANDSCAPE
I
N
coo
¢
3
I 1
- _ LANDSCAPE_ _ _
..
UJ
1�
0TW-6
VW-3
MW-2
'
i I /
^
-2D
ORAGE TANKS
(15,000 CAL)
�.
1
,
{
A_
=,
1
- ... , r _ _r
_ ..
BTW-7
1 _
YADKIN AVENUE
= FENCE 4 n
OVERHEAD ELECTRICAL LINE .0
m .� p
0 = TYPE II MONITORING WELL m Co
0 = TYPE III MONITORING WELL p
= FORMER TEMPORARY WELL LOCATION
Oa = SOIL BORING LOCATION 4 �
o
O
• = PROPOSED PHASE II INJECTION WELL $
0 = PROPOSED PHASE I DIRECT PUSH °i
INJECTION POINT o O1 N
z
- LOCATION OF FORMER MINERAL u- I�
SPIRITS UST N
— — — = ESTIMATED EXTENT OF GROUNDWATER ' 8
IMPACTED ABOVE NC 2L STANDARDS u w O
0
N O
a-
U
`c < O
MW-4 06/29/2011 D.P Z
° to
i) 2. ¢
e
6 14
.:7. O.N O.W
O
06/29/2011 (n �
ZLLJ
53 ~
ON F z ¢
U
w
O D' z
I - N La
LLJ z Q U
00zLL,wz
z
MN 2 c a:':c11 Ld 0 Y -p Ld
H 3
DN 1 ¢�
UO}}O O
ui
_ Ol
IL-0-W O11: N
O Li N ¢ = 10
FtLtoNU N
o
0
MY 3 ;,11 z
�Y og
0 15 30 60
APPROXIMATE SCALE IN FEET i

C40
Ne.
LOCKABLE WELL C"
MONITORING WELL CONSTRUCTION DETAILS
FLUSH GRADE MANHOLE
CROSS SECTIONAL VIEW
(NOT TO SCALE)
CONCRETE PAD
PAD DIMENSIONS
2 feet x 2 feet
HEIGHT ABOVE GROUND
flush mounted
WELL CASING
MATERIAL
sch 40 PVC
DIAMETER
1 inch
JOINT TYPE
flush threaded
LENGTH
15 & 21 feet
BACKFILL AROUND CASING
MATERIAL
cement -sand grout
THICKNESS
13 feet
SEAL
TYPE OF SEAL
bentonite
THICKNESS
2 & 2 feet
FILTER PACK
TYPE OF FILTER
pea gravel
DISTANCE ABOVE SCREEN
1 feet
WELL SCREENS
SCREEN MATERIAL
sch 40 PVC
DIAMETER
1 inch
LENGTH
3 & 4 feet
SLOT SIZE
0.030 inches
DEPTH TO BOTTOM OF
INJECTION WELLS
18 & 25 feet
DEPTH TO BOTTOM OF
BOREHOLE
25 feet
DIAMETER OF BOREHOLE 6 inches
TITLE FIGURE 9
ASSOCIATES INC.
Injection Well Construction Diagram
Safety-Kleen Service Center 2725 East Millbrook Road, Suite 121
2320 Yadkin Avenue Raleigh, North Carolina 27604
Charlotte, Mecklenburg County, NC
PREP. BY ZO
V. BY DATE PROJECT NO.
JCB 12/23/2011 45.16031.0007

DOCUMENTS ASSOCIATED
WITH
THE ORIGINAL PERMIT
APPLICATION
(ISSUED OCTOBER 21, 2011)

(YVATC
ATC ASSOCIATES OF NORTH CAROLINA, P.C.
Engineering Individual Solutions
August 19, 2011
Mr. Thomas Slusser
NCDENR Division of Water Quality
Aquifer Protection Section, UIC Program
1636 Mail Service Center
Raleigh, North Carolina 27699-1636
RE: Injection Permit Application
Safety-Kleen Service Center
2320 Yadkin Avenue
Charlotte, North Carolina
EPA ID No. NCD 079060059
ATC Project No. 45.16031.0007
Dear Mr. Slusser:
2725 East Millbrook Road
Suite 121
Raleigh, NC 27604
Tel: [phone]
Fax: [phone]
www.atcassociates.com
N.C. Engineering License No. C-1598
Enclosed are two copies of an injection permit application prepared by ATC Associates of North
Carolina, P.C. (ATC) on behalf of Safety-Kleen Systems, Inc. (S-K). The permit application
covers injection of chemicals to stimulate both chemical oxidation and enhanced anaerobic
bioremediation at the above referenced site.
If you have questions or require additional information, please do not hesitate to contact us at
[phone].
Sincerely,
ATC Associates of North Carolina P.C. X+►���"to
' w CARpft%
�+ h
SFp
9
SEAL �
4Justin C. Ballard, G. enna lson, P.G. 16 6 0
Project Geologist Senior Project Manager G'c� \C�
.�
0 w.,OLOGy , p
RECEIVED I DENR I DWQ
A0UIFFR-PR0TFrTI()AI �FCTION
SCP 01 2011

i
State of North Carolina
Department of Environment and Natural Resources
Division of Water Quality
APPLICATION FOR PERMIT TO CONSTRUCT AND/OR USE A WELL(S) FOR INJECTION
Type 5I Wells — In Situ Groundwater Remediation / Type 5T Wells - Tracer Injection
• Do not.use this form for remediation systems that extract contaminated groundwater, treat it, and reinject the treated groundwater.
• Submit TWO copies of the completed application and all attachments to the address. on the last page of this form.
• Any changes made to this form will result in the application package being returned.
Application Number (to be completed by DWQ): .
L GENERAL INFORMATION`.
1. Applicant's Name (generally -the responsible party): safety-xleen Systems, Inc.
2. Signing Official's Name: Robert A. Schoepke, P.G. Title: Director - Remediation
3: Mailing address -of applicant. 1502 East villa Street, 2nd Floor,
City: Elgin State: Illinois . Zip: 60120
Telephone number: [phone] Fax number: [phone]
4. Property Owner's Name (if different from Applicant): N/A-- Property owner same as applicant
5. Property Owner's mailing address: 1502 East Villa Street, 2nd Floor
City: Elgin State: Illinois Zip: 60120.
6. Name and address of contact person who can answer questions about the proposed injection project:
Name: Genna K. Olson, P.G. Title: Senior Project Manager
Company: ATC Associates of North Carolina, PC
Address: 2725 East Millbrook Road, Suite 121
City: Raleigh State: NC. -Zip: 27604
Telephone number: (919) 871-09.99 Fax number:-[phone]
Email Address: [e-mail]
II. PERMIT INFORMATION:
1. Project is: ❑x New ❑ Modification of existing permit ❑ Renewal of existing permit without modification
❑ Renewal of existing permit with modification
2. If this application is being submitted for -renewal or modification to an existing permit, provide:
existing permit number and the issuance date
For renewal without modifications, fill. out sections I & II only, sign the certification on the last page of this
form, and obtain the property owner's signature to indicate consent (if the applicant is not the owner).
For all renewals, you must submit a status report including monitoring results of all injection activities to
j date.
Revised 8/07 UIC-51/5T Page 1 of 7
RE CEIVED I D[Lz-NR / DWQ
AQUIFFR'PPnTF( l-lntj SECTION
r__P 0 1 2011

j I
APPLICATION FOR PERMIT TO CONSTRUCT AND/OR USE A WELL(S) FOR INJECTION
Type 5I Wells —In Situ Groundwater Remediation / Type 5T Wells — Tracer Injection
III. INCIDENT & FACILITY DATA -
i,
A. FACILITY INFORMATION
1. Facility name: Safety-Kleen Systems, Inc.
2. Complete physical address of the facility. 2320 Yadkin Avenue
r
City: Charlotte County: Mecklenburg State: NC Zip: 28205
B. INCIDENT DESCRIPTION
1. Describe the source of the contamination:
Safety-Kleen Systems, Inc. (S-K) currently operates a hazardous material storage and recycling facility that
began operations on June 5, 1978. The facility currently maintains a.Part B Resource Conservation and
j Recovery Act (RCRA) permit for hazardous waste storage. In the early 1980s, prior to installation of the current
waste mineral spirits storage system at the facility, used mineral spirits were placed into a 500-gallon
underground storage tank (UST) and then into:a 10,000-gallon capacity UST. The 500-gallon UST provided
in -line solids settling for the waste mineral spirits prior to accumulation in the 10,000-gallon UST. The UST
system was operated for a five-year period from.1980 until its removal in August 1985. The waste mineral spirits
UST system constitutes the solid -waste management units (SWMUs) that have been the focus of historical soil
and groundwater investigation activities.
2. List all contaminants present in soils or groundwater at the site (contaminants may be listed in groups, e.g.,
gasoline; diesel, jet fuel, fuel oil, chlorinated ethenes, chlorinated ethanes, metals, pesticides/herbicides, etc):
Mixture of chlorinated and petroleum solvent constituents.
3. Has LNAPL or DNAPL ever been observed at the site (even if outside the injection zone)?
❑ Yes If yes, list maximum measured separate phase thickness feet
X No If no, list maximum concentration of total VOCs observed at site: 27 ppb
4. Agency managing the contamination incident:
❑ UST Section ❑ Superfund Section (including REC Program and DSCA sites)
❑ DWQ Aquifer Protection Section ❑ Solid Waste Section
❑x Hazardous Waste Section ❑ Other:
5. Incident managers name Mr. Adam Ulishney and phone number [phone]
6. Incident number or other site number -assigned by the agency managing the contamination incident:
EPA ID No. NCD 079060059
C. PERMITS
List all permits or construction approvals that have been issued for the facility or incident, including those not
directly related to the proposed injection operation:
1. Hazardous Waste Management program permits under RCRA: NCD 079060059-R
2. DWQ Non -Discharge or NPDES permits: None identified.
3. County or DEH subsurface wastewater disposal permits: None identified.
4. Other environmental permits required by state or federal law: Mecklenburg County Permit 70000633 for well construction.
Revised 8/07 UIC-5I/5T Page 2 of 7

APPLICATION FOR PERMIT TO CONSTRUCT AND/OR USE A WELL(S) FOR INJECTION
Type 5I Wells —In Situ Groundwater Remediation / Type 5T Wells — Tracer Injection
IV. INJECTION DATA
A. INJECTION FLUID DATA
1. List all proposed injectants.
NOTE: Any substance to be injected as a tracer or to promote in situ remediation must be reviewed by the
Occupational and Environmental Epidemiology Section (OEES) of the Division of Public Health, Department of
Health and Human Services. Review the list ofapproved injectantsT or contact the UIC Program to determine if
the injectants you are proposing have been reviewed by OEES.
Injectant: Zero Valent Iron (ZVI)
Concentration at point of injection: Refer to Appendix 1 - Product Data
Injectant: Persulfate
Concentration at point of injection: Refer to Appendix 1 - Product Data
Injectant: Hydrogen Peroxide
Concentration at point of injection: Refer to Appendix 1 - Product Data
Injectant:
Concentration at point of inj
Injectant:
Concentration at point of
2. Source of fluids used to dilute or chase the injectants listed above:
El None
❑x Municipal water supply
❑ Groundwater from private well or any well within 'Amile of injection site
❑ Air
❑ Other:
3. If any well within'/4 mile of injection site, a private well, or surface water is to be used as the fluid source, supply
the following information:
a. Location/ID number of source: N/A
b. Depth of source: N/A
c. Formation: N/A
d. Rock/Sediment type: N/A
e. In Attachment C, provide a current, complete chemical analysis of the water from the source well, including
analyses for all contaminants suspected or historically recognized in soil or groundwater on the site.
NOTE: If contaminated groundwater is to be used as the dilution or chase fluid, this is not the proper permit
- application form. -You-must apply for a -closed -loop -groundwater remediation permit using application- form
GWRS.
Revised 8/07 UIC-51/5T Page 3 of 7

APPLICATION FOR PERMIT TO CONSTRUCT AND/OR USE A WELL(S) FOR INJECTION
Type 5I Wells —In Situ Groundwater Remediation / Type 5T Wells — Tracer Injection
B. PROPOSED OPERATING PARAMETERS
1. Duration of Injection:
Maximum number of separate injection events: 2 Events (Phases I and II)
Expected duration of each injection event: 2 days for Phase I, 1 day for Phase II
Expected duration between events (if more than one event): 3 month
2. Injection rate per well: 1 to 10 gallons per minute (gpm)
2,508 - Phase I
3. Total Injection volume: 1,254-1,692 gallons per day (gpd); 1, 692 - gallons per event (if separate events)
4. Injection pressure: 10 to 120 . pounds/square inch (psi) Phase II
5. Temperature at point of injection: 60 to 70 OF
6. Brieflv describe how the above parameters will be measured and controlled:
The injection pressure will monitored using a pressure gauge. Valves and the injection pump will be used to
control flow and pressure. The temperature of the water supply will determine the temperature of the remaining
injection fluids.
7. Estimated hydraulic capacity of the well:1 to 10 gpm
C. INJECTION WELL CONSTRUCTION DATA
1. Injection will be via:
❑ Existing well(s) proposed for use as an injection well. Provide the data in (2) through (6) below to the best of
your knowledge.
❑x Proposed well(s) to be constructed for use as an injection well. Provide the data in (2) through (6) below as
proposed construction specifications. Total of 14 new direct -push injection points to be installed for Phase I
Total of 4 new injection wells to be installed for Phase II
Probe Technologies (direct -push points), -
2. Well Drilling Contractor's Name:Geoloaic Exploration (infection wells)
NC Well Contractor Certification number: 2724-A and 2345, respectively
14 direct -push points,
3. Date to be constructed: TSD Pending approval Number of borings: 4 injection wells
Approximate depth of each boring (feet): 25
4. Screened interval/Injection interval of injection wells:
Depth: 15 to 25 feet below ground surface (if multiple intervals, indicate shallowest and deepest depth).
5. Well casing (N/A if injection is through direct push rods):
Type: ❑K PVC ❑ Stainless steel ❑ Other:,
Casing depth: 0 to 15 ft.
6. Grout (N/A if injection is through direct push rods):
Type: ❑ Cement ❑ Bentonite x❑ Other: Portland/Bentonite mixture
Grout depth: 0 to 11 ft.
Revised 8/07 UIC-5I/5T Page 4 of 7

APPLICATION FOR PERMIT TO CONSTRUCT AND/OR USE A WELL(S) FOR INJECTION
Type 5I Wells —In Situ Groundwater Remediation / Type 5T Wells — Tracer Injection
V. ATTACHMENTS
Provide the'following items as attachments with the given headings:
A. SITE HISTORY
Provide a brief description of the site history including:
(1) site usage historically and present,
(2) origin of the contamination,
(3) previous remedial action(s).
NOTE: G.S. 89E-18 requires that any geologic plans, reports, or documents in which the performance is related to the
public welfare or safeguarding of the environment be prepared by a licensed geologist or subordinate under his or her
direction. G.S. 89E-13 requires that all drawings, reports, or documents involving geologic work which shall have been
prepared or approved by a licensed geologist or a subordinate under his or her direction be signed and sealed by him or
her.
B. HYDROGEOLOGIC DESCRIPTION
Provide a hydrogeologic description, soils description, and cross section of the subsurface to a depth that includes the
known or projected depth of contamination. The hydrogeologic description shall include:
(1) the regional geologic setting;
(2) significant changes in lithology;
(3) the hydraulic conductivity, transmissivity, and specific yield of the aquifer to be used for injection, including a
description of the test(s) used to determine these parameters; and
(4) the depth to the mean seasonal high water table.
C. INJECTION FLUID COMPOSITION
Describe the chemical, physical, biological and radiological characteristics of each injectant. Attach the Material Safety
Data Sheet (MSDS) for each injectant. If a private well or a well within'/a mile of the injection site is used as the source
well, include chemical analysis of source fluid here.
D. INJECTION RATIONALE
Attach a brief description of the rationale for selecting the injectants and concentrations proposed for injection, including:
(1) goals of the injection project;
(2) a description of the reactions between the inj ectants and the contaminants present including specific breakdown
products or intermediate compounds that may be formed by the injection; and
(3) summary results of modeling or testing performed to investigate the injectant's potential or susceptibility to change
(biological, chemical or physical) in the subsurface.
E. INJECTION PROCEDURE AND EQUIPMENT
Provide a detailed description of all planned activities related to the proposed injection including but not limited to:
(1) construction plans and materials;
(2) operation procedures;
(3) a detailed diagram of the surface and subsurface portions of the system; and
(4) a planned injection schedule.
F. MONITORING PLAN
Provide a plan for monitoring the results of the injection, including:
(1) a list of existing and proposed monitoring wells to be used;
(2) a list of monitoring parameters and analytical methods to be used; and
(3) a schedule for sampling to monitor the proposed injection.
NOTE: The selected monitoring wells must be located so as to detect any movement of injection fluids, process by-
products, or formation fluids outside the injection area or zone. The monitoring parameters should include the target
contaminants as well as secondary or intermediate contaminants which may result from the injection and other
parameters which may serve to indicate the progress of the intended reactions, such as pH, ORP, dissolved oxygen, and
Revised 8/07 UIC-5I/5T Page 5 of 7

APPLICATION FOR PERMIT TO CONSTRUCT AND/OR USE A WELL(S) FOR INJECTION
Type 5I. Wells —In Situ Groundwater Remediation / Type 5T Wells — Tracer Injection
other electron acceptors and donors. The monitoring schedule should be consistent with the pace of the anticipated
reactions and rate of transport of the injectants and contaminants.
G. WELL DATA
Provide a tabulation of data on all existing or abandoned wells within'/4 mile of the injection well(s) which penetrate the
proposed injection zone, including, but not limited to, monitoring wells and wells proposed for use as injection wells.
Such data shall include a description of each well's use (water supply, monitoring, etc), total depth, screened or open
borehole depth interval, and well construction or abandonment record, if available.
H. MAPS
Attach the following scaled, site -specific maps:
(1) Area map based on the most recent USGS 7.5' topographic map of the area, at a scale of 1:24,000 and
showing the location of the proposed injection site.
(2) Site map including:
a. all property boundaries;
b. all buildings within the property boundary;
c. existing and proposed injection wells or well field(s)
d. any existing sources of potential or known groundwater contamination, including waste storage,
treatment or disposal systems within'/4 mile of the injection well or well system;
e. all surface water bodies within'/4 mile of the injection well or well system; and
f. all existing or abandoned wells within'/4 mile of the injection well(s) which penetrate the proposed
injection zone, including, but not limited to, monitoring wells and wells proposed for use as injection
wells.
(3) Potentiometric surface map(s) including:
a. direction of groundwater movement
b. existing and proposed monitoring wells
c. existing and proposed injection wells
(4) Contaminant plume map(s) including:
a. the horizontal extent of the contaminant plume, including isoconcentration lines
b. existing and proposed monitoring wells
c. existing and proposed injection wells
(5) Cross-section(s) to the known or projected depth of contamination, including:
a. horizontal and vertical extent of the contaminant plume, including isoconcentration lines
b. major changes in lithology
Revised 8/07 UIC-51/5T Page 6 of 7

APPLICATION FOR PERMIT TO CONSTRUCT AND/OR USE A WELL(S) FOR INJECTION
Type 5I Wells — In Situ Groundwater Remediation / Type 5T Wells — Tracer Injection
VI. CERTIFICATION
1, RobertA. Schoy1 ft., hereby certify under penalty of law that
I have personally examined and am familiar with the information submitted in this document and all attachments
thereto and that, based on my inquiry of those individuals immediately responsible for obtaining said information,
I believe that the information is true, accurate and complete. I am aware that there are significant penalties,
including the possibility of fines and imprisonment, for submitting false information. I agree to construct,
operate, maintain, repair, and if applicable, abandon the injection well(s) and all related appurtenances in
accordance with the approved specifications and conditions of the Permit.
Signature: &4�t4
Title: Director - Remediation
Date: 9 —1 1 -- 1 1
If authorized agent is acting on behalf of the applicant, supply a letter signed by the applicant authorizing the
above agent.
VII. CONSENT OF PROPERTY OWNER (if the property is not owned by the applicant)
("Owner" means any person who holds the fee or other property rights in the well being constructed. A well is
realproperty and its construction on land shall be deemed to vest ownership in the land owner, in the absence of
contrary agreement in writing.)
I, N/A -Property olztP?�,il�llllCf as owner of the property on which the
injection well(s) are to be constructed and operated, hereby consent to allow the applicant to construct each
injection well as outlined in this application and agree that it shall be the responsibility of the applicant to ensure
that the injection well(s) conform to the Well Construction Standards (Title 15A NCAC 2C .0200)
Signature: Date:
Title:
Revised 8/07
Submit TWO copies of the completed application package, including all attachments, to:
UIC Program
Aquifer Protection Section
North Carolina DENR-DWQ
1636 Mail Service Center
Raleigh, NC 27699-1636
Telephone [phone]
UIC-5115T
RECEIVED / DIENR / DWO
ldQUIFFR-PRCTi-rTIC,NJ SECTION
SEP 01 2011
Page 7 of 7

A. SITE HISTORY
1. Site Usage
Safety-Kleen Systems, Inc. (S-K) currently operates a hazardous material storage and recycling
facility at 2320 Yadkin Avenue in Charlotte, Mecklenburg County, North Carolina. A site
location map is included as Figure I and a site map is included as Figure 2. The facility began
operations on June 5, 1978 and filed a Resource Conservation and Recovery Act (RCRA) Part A
hazardous waste permit application for interim status as a storage facility in 1980. This permit
was then revised in 1985 and 1988. A RCRA permit was issued to S-K for the Charlotte Service
Center on July 10, 1991, which allows for the storage and treatment of hazardous waste. The
facility currently maintains a Part B RCRA permit for hazardous waste storage.
2. Origin of Contamination and Assessment Data
In the early 1980s, prior to installation of the current waste mineral spirits storage system at the
facility, used mineral spirits were placed into a 500-gallon underground storage tank (UST) and
then into a 10,000-gallon capacity UST. The 500-gallon UST provided in -line solids settling for
the waste mineral spirits prior to accumulation in the 10,000-gallon UST. The UST system was
operated for a five-year period from 1980 until its removal in August 1985. The waste mineral
spirits UST system constitutes the solid waste management units (SWMUs) that have been the
focus of historical soil and groundwater investigation activities. SWMU-8 is the former 500-
gallon waste mineral spirits settling tank and SWMU-9 is the former 10,000-gallon waste mineral
spirits tank. Another 10,000-gallon mineral spirits UST was located immediately adjacent to the
waste 10,000-gallon tank and was used to store virgin mineral spirits product. The virgin mineral
spirits tank is not considered part of the SWMUs.
Several phases of assessment have been conducted to investigate potential impacts around the
waste mineral spirits UST system between 1998 and, 2009. These investigations were
documented in a Phase I RCRA Facility Investigation (RFI) report dated March 19, 1998, a Phase
H RFI report dated January 9, 2001, a Deep Monitoring Well Installation report dated November
18, 2003, a Groundwater Sampling Event report dated January 15, 2009, a Soil and Groundwater
i
Investigation Report dated February 22, 2011, and a Corrective Measures Study dated May 6,
��CEIV�D I DE--i,R I DWQ
SECTION
JQ'J!F- R-PR0T=i TI(1'!
�- 1

2011. Other than removal of the USTs, no corrective measures have been performed at the site to
date.
A total of 19 soil borings were installed between 1999 and 2010 to assess the extent of impacted
soil in the vicinity of the former waste mineral spirits UST system. As shown on Table 1, soil
r
impacted by multiple volatile organic compounds (VOCs) and semivolatile organic compounds
(SVOCs) at concentrations above NC Soil Screening Levels (SSLs) and Environmental
Protection Agency (EPA) Residential Regional Screening Levels (RSLs) is present in the area of
borings B-6 and B-7, which are located within the former mineral spirits UST pit. Boring B-5
also contained one low concentration of benzo(a)pyrene above the EPA Residential RSL, but
below the NC SSL. No exceedences of EPA Industrial RSLs were identified in the soil samples.
Vertically, the extent of impacted soil extends to the groundwater table. Metals have also been
detected in soil samples collected at the site, but prior investigations confirmed the metals are
indicative of natural background concentrations and are therefore not a concern. Installation of a
soil vapor extraction (SVE) system is currently planned to remediate impacted soil.
Seven monitoring wells were installed between 1999 and 2010 to assess the extent of impacted
groundwater. Based on the assessment data, a plume of groundwater impacted by multiple VOC
and SVOC constituents extends from the former UST area downgradient to the north-northeast.
The plume appears adequately delineated and confined to the on -site property. Vertical
assessment data indicates that the majority of the contaminant mass is present in the shallow
water table aquifer. The most recent sampling event was completed in June 2011. Monitoring
well construction data are summarized in Table 2, groundwater elevation data are summarized in
!i
Table 3, and groundwater analytical data are summarized in Table 4. Figure 3 presents the
groundwater contaminant concentration map for the June 2011 sampling event and Figure 4
presents the groundwater elevation contour map for the June 2011 gauging event.
Surface water runoff from the facility flows north onto Yadkin Avenue and East 27th Street and
discharges through storm drains into Little Sugar Creek. Little Sugar Creek is located
approximately 900 feet west of the facility and discharges into the Catawba River approximately
15 miles south of the facility. Little Sugar Creek and the Catawba River are sources of
recreational fishing and boating. According to the Charlotte -Mecklenburg Utilities Department,
public water supply in the area is obtained from the Catawba River. The Catawba River is located
2

over 10 miles west of the site. Groundwater is not a source for public water supply in the area of the
site and no water supply wells were identified during a receptor survey.
B. HYDROGEOLOGIC DESCRIPTION
According to the North Carolina Geologic Map (1985), the site is located within the Charlotte Belt
of the Piedmont Physiographic Province. The Piedmont Physiographic Province is underlain by a
complex of metamorphic and igneous rocks covered by a veneer of unconsolidated sediments and
residual soils derived from the underlying rocks. Specifically, the site is underlain by
metamorphosed granitic bedrock which is megacrystic, well foliated, and locally contains
hornblende. According to the Soil Survey of Mecklenburg County, North Carolina, the site area
is classified as Urban Land. This classification indicates that more than 85 percent of the land
surface has been covered with buildings, pavement, or other impervious cover. Soils in these
areas have been cut, filled, and graded to the extent that the natural characteristics are altered or
destroyed.
Bedrock in the Piedmont is typically overlain by a layer of regolith that includes a zone of soil
and a saprolite zone, which consists of weathered bedrock that has been decomposed in situ
(LeGrand, 2004). Saprolite can be up to 100 ft thick beneath broad upland areas but becomes
much thinner in valleys. A coarse transition zone is common between the saprolite and fractured
bedrock. This transition zone consists of progressively smaller amounts of saprolite with rock
fragments (Daniel and Dahlen, 2002). The transition zone is commonly referred to as partially
weathered rock (PWR).
Based on soils encountered during recent and historical drilling operations, subsurface soils
consist primarily of brown to orange silt with varying amounts of clay and sand. Likely fill
material was encountered in the area of the former UST pit, although the exact depth of fill was
difficult to discern. The depth to bedrock is variable and largely dependent on the type of drilling
rig utilized, which is typical of saprolite derived from weathered granitic bedrock in this region.
The depth to bedrock generally increases from south to north across the site, which is likely
reflective of grading conducted during construction of the on -site facility. A cross-section
location map and two cross -sections depicting the subsurface geology are included as Figures S,
6, and 7, respectively.
3

Groundwater flow systems in the Piedmont can be broken down into two major components
consisting of the regolith (saprolite and PWR zones) and the underlying bedrock (LeGrand,
2004). Precipitation migrates through the regolith until it reaches the saturated zone where it is
stored in inter -granular pore spaces as groundwater (LeGrand, 2004). A portion of this
groundwater flows parallel to the bedrock surface through the regolith to a groundwater discharge
area such as a perennial stream or other surface water body (LeGrand, 2004). The regolith
transmits water slowly, but has a high storage capacity with porosity ranges of 35 to 55 percent
near the ground surface and decreases with depth (LeGrand, 2004). The PWR is characterized as
a highly permeable zone that is conducive for rapid groundwater flow (LeGrand, 2004).
A review of historical groundwater elevation data indicates that the average depth to groundwater
ranges from 14.18 to 20.94 feet below ground surface (bgs) in the shallow monitoring wells
(screened between 7 and 28 feet deep in the unconsolidated aquifer) and 18.56 to 19.74 feet bgs
in the deep monitoring well (screened between 45 and 55 feet deep in the bedrock aquifer). Well
construction details are summarized in Table 2 and groundwater elevation data are summarized in
Table 3. The groundwater flow direction across the site is generally towards the north-northeast.
According to the June 2011 groundwater elevation data, the average horizontal hydraulic gradient
for the site was calculated as 0.016 in the shallow zone. A groundwater elevation contour map
showing contours for the shallow zone is included as Figure 4.
Testing has not been conducted to confirm the hydraulic conductivity of the aquifer sediments.
However, ATC has performed slug testing on numerous sites within the Charlotte area that have
similar geology. Hydraulic conductive values calculated based at these tests range from
g gY Y conductivity
approximately 0.2 feet per day (ft/d) to 2 ft/d. The hydraulic conductivity value for the subject
site likely falls within a similar range, with an estimated midrange value of around 1 ft/d. Based
on published references (McWorter and Sunada, 1977 and Freeze and Cherry, 1979), the effective
porosity (specific yield) of the aquifer is estimated at 20 percent. Using these values and the
above referenced hydraulic gradient, the groundwater flow velocity across the site is estimated at
0.08 ft/d (29.2 feet per year). Assuming an average depth to bedrock of 24 feet, the
transmissivity of the unconsolidated aquifer is estimated at 24 square ft/d.
4

C. INJECTION FLUID USE AND COMPOSITION
The goal of the proposed injection activities is to reduce COC concentrations in the groundwater
source area. To achieve these goals, injection will be performed in a two-phase approach.
Initially, a direct -push drilling rig will be utilized to attempt to complete injection into 14 direct -
push points. Based on the site geology, direct -push drilling technology may or may'not be able to
reach the target depth. If the Phase I injection is unsuccessful at achieving target depths, a
secondary phase of injection will be implemented. This phase will include the installation and
subsequent injection into up to four injection wells installed using a full-size drilling rig. Figure
8 presents the proposed injection locations.
The proposed injectant is a mixture designed to stimulate both chemical oxidation and enhanced
anaerobic bioremediation. The components of the mixture are Klozur produced by FMC
Environmental Solutions, zero valent iron (ZVI) produced by BASF, and hydrogen peroxide
produced by FMC Environmental Solutions. Klozur consists of sodium persulfate and is injected
with ZVI and hydrogen peroxide which activate the persulfate to generate sulfate free radicals.
These sulfate radicals chemically oxidize the contaminants of concern within a short timeframe.
The oxidation produces ferric iron and sulfate ions which stimulate longer term anaerobic
bioremediation in the subsurface by providing terminal electron acceptors. The primary
reduction mechanism with ZVI is direct electron transfer from the ZVI to the contaminants at the
metal -water interface, resulting in dechlorination and the production of ferrous iron. As a
secondary dechlorination mechanism, corrosion, of iron metal yields ferrous iron and hydrogen,
both of which are used biotically to reduce chlorinated VOCs. Lastly, nitrogen gas is also
included in the injection process to force the injected fluids into the formation. Innovative
Environmental Technologies (IET) will perform the injection activities, with supervision by
ATC. The volumes and concentrations of each component proposed to be injected are
summarized in Appendix 1. Material Safety Data Sheets (MSDS) for each component of the
injection mixture are included in Appendix 2. Available case studies and product literature are
included in Appendix 3 of this permit application.
E

E. INJECTION PROCEDURE AND EQUIPMENT
Phase IIniection
ATC's initial approach will involve injecting into 14 locations over an approximately 3,400-square
foot area, as indicated on Figure 8. At each location, injection will be performed from depths of
approximately 15 feet to 25 feet bgs via traditional direct -push technology, utilizing an AMS,
PowerProbe, mounted on a skid loader or Geoprobe 6620. The injection rods will consist of IET's
proprietary injection system with retractable injection zones driven to the desired injection depth
using a direct -push drilling rig. Once injection at a location is complete, the residual pressure in
the formation will be monitored until a safe level is reached. The injection rod will then be
withdrawn and the boring will be abandoned using hydrated bentonite. Assuming the target
depth is reached, the injected fluids will include 2,208 pounds of sodium persulfate in solution,
1,054 pounds of micron -sized ZVI in solution, and 1,458 gallons of 2.5 percent hydrogen
peroxide. The injection activities are expected to last approximately two days.
Phase IIIniection
If the Phase I Injection approach is unsuccessful in achieving the target injection depth in the
majority of the injection points, ATC will follow up with a second phase of injection into
permanent injection wells. During the second phase, up to four permanent injection wells will be
installed. The wells will each be constructed of 4-inch diameter polyvinyl chloride (PVC) with a
screened interval from 15 to 25 feet bgs. To facilitate effective injection of the granular ZVI, the
injection well screen will be 30 slot size and the filter pack will consist of pea gravel. If the full
scope of Phase II injection is required, the injected fluids will include 2,198,pounds of sodium
persulfate in solution, 594 pounds of micron -sized ZVI in solution, and 1,392 gallons of 2.5
percent hydrogen peroxide. However, note that the second phase of injection may not be
performed or the scope of injection may be reduced depending on the results of the first phase of
direct -push injection. Proposed injection locations are shown on Figure 8. A proposed injection
well construction diagram is included as Figure 9.
Z

Iniectate Procedures
Injection will be performed using IET's injection trailer and patented injection process. The
different components of the injectant mixture will each be injected in series as described below:
Step 1— Injection of nitrogen gas.
Step 2 — Injection of ZVI followed by hydrogen peroxide followed by sodium persulfate.
Step 3— Second injection of nitrogen gas.
IET's injection trailer is equipped with tanks for mixing the injection solutions. Municipal water
will be used for the solution mixing. All solutions will be injected at ambient temperatures. High
pressure hose or PVC pipe will extend from the direct -push rods and/or well heads on the injection
wells to the injection pump. The injection pump is connected to the mixing tank via stainless steel
pipe. A pressure gauge, shut-off valves and pressure bleed -off are also installed in -line. Injection
will be performed using a diaphragm pump. Injection pressures may range from 10 to 120 psi
and injection flow rates may range from 1 to 10 gpm. The injection pressure will be monitored
continuously using a pressure gauge and the injection rate will be adjusted using the injection
pump and valves. After injection, the injection pump will be turned off and the shut-off valve
will be closed. The residual pressure in the formation will then be monitored until a safe level is
reached. The process will then be repeated at the next injection location.
G. MONITORING PLAN
Groundwater samples will be collected from monitoring wells TW-5, TW-6, MW-2, MW-3,
MW-4, and MW-5 to monitor the effectiveness of the injection activities. Groundwater samples
will be analyzed for VOCs by EPA Method 8260, SVOCs (polynuclear aromatic hydrocarbons
only) by EPA Method 8270, and sulfate by EPA Method 9056. Sampling of the monitoring wells
will be performed using low flow sampling methods which include monitoring of temperature,
dissolved oxygen, pH, oxidation-reduction potential, and specific conductivity. Depth to water will
also be measured during each sampling event. Groundwater samples will be collected from the
wells specified above prior to injection and three months, six months, and one year following
injection.
7

H. WELL DATA
Well construction details for the existing monitoring wells are included in Table 2. Historical
receptor surveys conducted by ATC did not identify water supply wells within 1,500 feet of the
site.
8

TABLES
Table 1:
Soil Analytical Data
Table 2:
Well Construction Details
Table 3:
Groundwater Elevation Data
Table 4:
Groundwater Analytical Data
Table 5:
Groundwater Field Parameter Data

TABLE 1
SOIL ANALYTICAL DATA
SAFETY-KLEEN SERVICE CENTER
2320 YADKIN ROAD
CHARLOTTE, NORTH CAROLINA
ATC PROJECT NO.45.16031.0007
BORING
B-1
B-1
B-2
B-2
B-3
B-3
B-4
B-5
B-5
B-5
B-5
B-6
B-6
B-6
B-6
B-7
B-7
B-7
B-7 DUP
NC
US EPA
US EPA
DEPTH ft.
5'
10'
15'*
20'•
l5"
20"
10'
5'
5'
10'
10'
5'
10'
10'
15'•
5'
10'
10'
10,
HWS
Residential
Industrial
Com ound
Method Units
2/5/1998
2/5/1998
2/5/1998
2/5/1998
2/5/1998
2/5/1998
2/5/1998
2/5/1998
12/22/2010
2/5/1998
12/22/2010
12/22/2010
2/5/1998
12/27/2010
2/5/1998
12/22/2010
2/5/1998
12/22/2010
12/ 22/2010
SSLs
RSLs
RSLs
TPH
8015M
<2.5
<2.5
7.3•
12•
11•
70*
<2.5 1
NA
1,900'
NA 600 1
NA I
NA 11
NE
NE
NE
METALS
m
Barium
6010
u
180,000
180,000
200,000
170,000
170,000
180,000
150,000
74,000
NA 130 000
NA
NA
160.000
NA 150.000
NA 52 000
NA
NA
580,000
15 000 000
190,000,000
Total Chromium
6010
u
28,000
59,000
1,200
26,000
43,000
45,000
<1 000
3 000
10 500 18 000
7,410
5,130
<1 000
6,150 <1,000
1 00 1,700
13,200
6,760
NE
NE
NE
Chromium VI
3060/719
NA
NA
NA
NA
NA
NA
NA
NA
NA
9,400J NA
1,3001
6,110J
6001
4,530J
NA
NA
NA
5 550J NA
NA
11 600] NA
600J
12 600J
5003
6260J
3,800
360,000 000
290
120,000,000
5,600
1,500,000,000
Chromium III
6010**
NA
NA
NA
NA
NA
NA
NA
NA
Lead
Silver
6010
6010
u
Q 500
<1,000
<2,500
<1000
<2,500
<1000
<2,500
<1000
Q,500
<1000
<2,500
<1000
<2,500
<1000
Q 500
<1,000
NA
NA
<2 500
<1000
NA
NA
NA
NA
<2,500
<1000
NA
NA
Q 500
<1,000
NA
NA
<2,500 NA
2,300 NA
NA
NA
270,000
3,400
400,000
390,000
800,000
5,100000
VOLATH,E ORGANICS
Acetone
8260
NA
NA
NA
NA
NA
NA
NA
NA
<160
NA
<120
<5100
NA
<6200
NA
41J
NA
<5500
<4600
24,000
61 000,000
630 000 000
-Bu lbenzene
$260
u
NA
NA
NA
NA
NA
NA
NA
NA
2.7J
NA
2.0
4,400
NA
24,000
NA
33
NA
8,200
10,000
4,300
NE
NE
sec-Butylbenzene
8260
NA
NA
NA
NA
NA
NA
NA
NA
2.9J
NA
2.0
1,500
NA
7,200
NA
24
NA
3 600
3 500
3,300
NE
NE
tert-Butylbenzene
8260
uglkg
NA
NA
NA
NA
NA
NA
NA
NA
0.41
NA
OX
1901
NA
650
NA
5.3J
NA
380J
360J
3,400
NE
NE
hlorobenzene
8260
ug1kg
<5.0
<5.0
<8.7
<1,700
<8.7
<1 700
<5.0
<8.7
0.7J
<1 700
0.6J
530
630
2 000
<170
120
<170
1,100
870
450
290,000
1,400,000
Chloroethane
8260
NA
NA
NA
NA
NA
NA
NA
NA
<8.1
NA
<6
<260
NA
<310
NA
LOJ
NA
<280
<230
16,000
15,000,000
61,000,000
Chlorotoluene
8260
upAg
NA
NA
NA
NA
NA
NA
NA
NA
<16
NA
<12
<510
NA
<620
NA
2.9J
NA
<550
<460
1,200
1,600,000
20,000 000
Chlorotoluene
8260
ugtkg
NA
NA
NA
NA
NA
NA
NA
NA
<16
NA
<12
<510
NA
<620
NA
<11
NA
31J
33J
NE
5,500,000
7,200 000
1,2-Dichlorobenzene
8260
u
NA
NA
NA
NA
NA
NA
NA
NA
3.1J
NA
3.81
1,100
NA
920
NA
7AJ
NA
100J
55J
240
1,900 000
9,800 000
1,3-Dichlorobenzene
8260
u
NA
NA
NA
NA
NA
NA
NA
NA
<16
NA
0.5J
1901
NA
860
NA
3.6J
NA
320J
330J
7,600
NE
NE
14-Dichlorobenzene
8260
ugAg
NA
NA
NA
NA
NA
NA
NA
NA
1.1J
NA
1.2J
590
NA
2,000
NA
21
NA
1,000
940
70
2,400
12,000
1, 1 -Dichloroethane
8260
ug&g
NA
NA
NA
NA
NA
NA
NA
NA
3.2J
NA
2.1J
<260
NA
<310
NA
<5.4
NA
<280
<230
30
3,300
17000
is-1,2-Dichloroethene
8260
u
NA
NA
NA
NA
NA
NA
NA
NA
2.8J
NA
2.1J
<60
NA
<310
NA
4.6J
NA
<280
<230
360
160,000
2,000,000
Eth lbenzene
8260
NA
NA
NA
NA
NA
NA
NA
NA
1.3J
NA
1.11W22
NA
2,300
NA
20
NA
480
450
8,100
5,400
27,000
Iso ro ]benzene
8260
NA
NA
NA
NA
NA
NA
NA
NA
2.1J
NA
1.7J
NA
3,300
NA
23
NA
1200
1,200
1,300
2 100,000
11,000,000
Iso ro ltoluene
8260NA
NA
NA
NA
NA
NA
NA
NA
IAJ
NA
LOJ
NA
7,200
NA
9.6J
NA
93J
<460
NE
NE
NE
Methylene Chloride
8260
Ruuu.'.
NA
NA
NA
NA
NA
NA
NA
NA
OAJ
NA
<12
NA
30J
NA
<11
NA
23J
191
23
11,000
53,000
Methyl Eth1 Ketone
8260
<100
<100
<14
<13000
<63
<13000
<100
<63
<160
<13000
3.5J
<1300
<6200
<1300
12J
<1300
<5500
<4600
16,000
28,000,000
200,000 000
Naphthalene
8260
NA
NA
NA
NA
NA
NA
NA
NA
4.OJ
NA
5.2J
NA
NA
7.400
NA
NA
34
38
NA
NA
3,000
3,600
2,900
3,600
210
1,500
3,600
3,400,000
18,000
2 100,000
Pro lbenzene
8260
NA
NA
NA
NA
NA
NA
NA
NA
2.5J
NA
2.1J
etrachloroethene
8260
ugtkg
<5.0
<5.0
<10
<1,900
<10
<1,900
<5.0
150
1.5J
<1,900
0.91
<260
28J
NA
<310
45J
NA
<5.4
<11
<190
NA
<280
<550
<230
<460
5
2,200
550
22.000
2,600
99,000
1,2,4-Trichlorobenzene
8260
ug1kg
NA
NA
NA
NA
NA
NA
NA
NA
<I6
NA
<12
Trichlorofluoromethane
8260
u
NA
NA
NA
NA
NA
NA
NA
NA
0.71
NA
<12
<510
NA
<620
NA
0.6J
NA
<550
<460.
24,000
790,000
3,400,000
1 2,4-Trimeth (benzene
8260
NA
NA
NA
NA
NA
NA
NA
NA
32
NA
29
13,000
NA
52,000
NA
81
NA
490J
<460
6,700
62,000
260,000
1,3,5-Trimeth (benzene
8260
NA
NA
NA
NA
NA
NA
NA
NA
7.2J
NA
5.8J
2,700
NA
20,000
NA
9.3J
NA
72J
<460
6 700
780,000
10,000,000
Vin 1 Chloride
8260
jg�
<5
<5
<9.2
<1800
<9.2
<1800
<5
<9.2
<16
<1800
<12
<510
<180
<620
<180
1.OJ
< SO
<550
<460
0.19
60
1700
otal X lens
8260NA
NA
NA
NA
NA
NA
NA
NA
2.5J
NA
1.81
300
NA
1,700
NA
3.5J
NA
<80
9.7J
6,000
630,000
2,700,000
SEMIVOLATILE ORGANICS
Benzo a anthracene
8270
u
NA
NA
NA
NA
NA
NA
NA
NA
18
NA
<13
17
NA
<12
NA
130
NA
23
34
180
150
1 2,100
Benzo a ene
8270
u
NA
NA
NA
NA
NA
NA
NA
NA
18
NA
<13
i0i
NA
<12
NA
130
NA
28
59
15
210
Benzo fluoranthene
8270
NA
NA
NA
NA
NA
NA
NA
NA
27
NA
<13
19
NA
<12
NA
200
NA
35
45
600
150
2,100
Benzo fluoranthene
8270
u
NA
NA
NA
NA
NA
NA
NA
NA
12
NA
<13
<11
NA
<12
NA
63
NA
13
20
5,900
1,500
21,000
Dibenzo a,h anthracene
8270
u
NA
NA
NA
NA
NA
NA
NA
NA
<12
NA
<13
<11
NA
<12
NA
17
NA
<12
<12
190
15
210
1,2-Dichlorobenzene
8270
NA
NA
NA
NA
NA
NA
NA
NA
<380
NA
<410
510
NA
<390
NA
<330
NA
<390
<390
240
1900,000
9,800000
Bis 2-eth lh 1 hthalate
8270
u
NA
NA
NA
NA
NA
NA
NA
NA
<380
NA
<410
450
NA
2701
NA
<380
NA
280J
330J
7.200
35,000
120,000
uoranthene
8270
NA
NA
NA
NA
NA
NA
NA
NA
<380
NA
<410
<380
NA
<390
NA
280J
NA
<390
<390
330,000
2,300,000
22,000 000
Indeno 12,3-cd ne
8270
NA
NA
NA
NA
NA
NA
NA
NA
15
NA
<13
<11
NA
<12
NA
47
NA
12J
11J
2,000
150
2,100
2-Meth hra hthalene
8270
NA
NA
NA
NA
NA
NA
NA
NA
<380
NA
<410
560
NA
2 900
NA
<380
NA
560
560
1,600
310,000
4,100 000
Naphthalene
8270
u
NA
NA
NA
NA
NA
NA
NA
NA
<380
NA
<410
1,600
NA
NA
<390
NA
NA
210J
280J
NA
NA
1,400
<390
1,100
<390
210
57,000
3,600
NE
18,000
NE
Phenanthrene
8270
u
NA
NA
NA
NA
NA
NA
NA
NA
<380
NA
<410
<380
ene
8270
NA
NA
NA
NA
NA
NA
NA
NA
<380
NA
<410
<380
NA
<390
NA
270J
NA
<390
<390
220,000
1,700 000
17,000,000
NOTES:
1. ug/kg= micrograms per ldlogram.
2. mg/kg = milligrams per kilogram.
3. "<" = Not detected above method detection limit. Table shows "< reporting limit".
4. J = Estimated result less than the reporting limit but above the method detection limit
S. NA=Not analyzed.
6. "= Sample collected below seasonal high groundwater table.
7. "= Chromium III is equivalent to the total chromium value minus the chromium VI value.
8. Table shows only constituents detected in soil at the site.
9. NC HWS SSLs =North Carolina Hazardous Waste Section Soil Screening Levels, as referenced in Federal Remediation Branch Target Screening Values table dated January 2010.
10. RSLs = EPA Regional Screening Levels updated November 2010.
11. NE= Not established.
12. Values shown in bold are above NC HSW SSLs.
13. Values highlighted in blue are above EPA Residential RSLs. El
14. No values are above EPA Industrial RSLs.

TABLE I (Continued)
SOIL ANALYTICAL DATA
SAFETY-KLEEN SERVICE CENTER
2320 YADKIN ROAD
CHARLOTTE, NORTH CAROLINA
ATC PROJECT NO.45.16031.0007
Com ounds
Temporary Well
TW1S
TW2S
TW3S
TW4S
TW4S
TW5S
TW-5S
TW6S
TW7S
NC
HWS
SSLs
US EPA
Residential
RSLs
USE
Industrial
RSLs
DEPTH (fr
5' 10'
5' 10'
10' 151•
5' 10'
5'
5' to,
5'
10' 15'•
5'
Method Units
9/8/1999
9/8/1999
9/8/1999
9/8/1999
1222/2010
9/8/1999
12/22/2010
9/8/1999
9/9/1999
3550B/SO15B m k
Q.5 <2.5
Q.5 Q.5
<2.5 325
Q.5 Q.5
NA
Q.5 <2.5
NA
Q.5 Q.5
Q.5
NE
NE
NE
ium
V
6010B
6010
u
u
62000
4,920
71,500
7,675
45,800
3,740
54,100
3,580
197,400
4,540
171,500
3640
122800
34,110
35,400
2,490
NA
6,100
133,400
17,520
255,600
6,650
NA
42,100
60,600
6,125
33,090
1,840
132900
5060
580,000
NE
15 000000
NE
190,000,000
NE
I
3060/7196
NA
NA
NA
NA
NA
NA
NA
700J ='
NA
NA
Q,500
NA
NA
NA
3,800
290
5600
ll
6010•►
ju[gNA
NA
NA
NA
NA
NA
NA
NA
5,4001
NA
NA
<42,100
NA
NA
NA
360,000,000
120,000,000
1,500,000,000
601oB
.,6010B
5,610
<500
<4000
<500
5185
<500
9,610
<500
4420
<500
7,880
<500
<4,000
<500
NA
NA
6,250
<500
7,510
<500
NA
NA
<4,000
<500
<4000
<500
4,440
<500
270 000
3,400
400,000
390,000
800,000
5,100,000
VOLATILE ORGANICS
Acetone
8260B
WAR
66
8.3J
26
21
9.4J
<5,000
21
14J
NA
52
9.2J
NA
20
10J
15J
24,000
61,000,000
630,000 000
n-Butylbenzene
8260
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
<0.059
4,300
NE
NE
sec-Butylbenzene
8260
u
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
<0.059
3,300
NE
NE
tert-Butylbenzene
8260
u
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
<0.059
3,400
NE
NE
hlorobenzene
8260B
ug1kg
<5
<5
<S
<5
<5
<1,200
<5
<5
NA
<5
<5
NA
<5
<5
<0.059
450
290,000
1,400,000
hloroethane
Chlorotoluene.
8260
8260
ugAg
<10
NA
<10
NA
<10
NA
<10
NA
<10
NA
Q500
NA
<10
NA
<10
NA
NA
NA
<10
NA
<10
NA
NA
NA
<10
NA
<10
NA
<0.120
<0.059
16,000
1,200
15,000,000
1,600,000
61,000,000
20,000 000
hlorotoluene
1,2-Dichlorobenzene
8260
8260
uRAg
ss
I NA
<5
A
5
NA
<5
NA
<5
NA
<1200
NA
<5
NA
<5
NA
NA
NA
<5
NA
<5
NA
NA
NA
<5
NA
<5
<0.059
<0.059
NE
240
5,500,000
1,900,000
7,200,000
9,800,000
1,3-Dichlorobenzene
8260
u
<5
5
<5
<5
<1200
<5
<5
NA
<5
<5
NA
<5
<5
<0.059
7,600
NE
NE
1,4-Dichlorobenzene
8260
ss
<5
5
<5
<5
<1200
<5
<5
NA
<5
<5
NA
<5
<5
<0.059
70
2,400
12,000
%i-Dichloroethane
8260
ss
<S
5
<5
<5
<1200
<5
<5
NA
<5
<5
NA
<5
<5
<0.059
30
3,300
17,000
cis-1,2-Dichloroethene
8260 _
u
Q.5
.5
Q.5
Q.5
<620
Q.5
Q.5
NA
Q.5
Q.5
NA
Q.5
Q.5
<0.059
360
160,000
2,000,000
Eth benzene
8260
u
<5
5
<5
<5
<1200
<5
<5
NA
<5
<5
NA
<5
<5
<0.059
9,100
5,400
27,000
so ro ]benzene
8260
u
NA
A
INANA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
<0.059
1,300
2,100,000
11,000,000
Iso ro (toluene
8260
NA
A
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
<0.059
NE
NE
NE
Methylene Chloride
8260B
u
1.1J
5J
1.2J
1.21
<1,200
1.21
1.2J
NA
1.4J
1.5J
NA
1.6J
1.6J
<0.059
23
11,000
53,000
Methyl Ethyl Ketone
Naphthalene
8260,
8260 "
_
QO
NA
O
A
QO
NA
QO
NA
<5000
NA
<20
NA
QO
NA
NA
NA
QO
NA
QO
NA
NA
NA
QO
NA
QO
NA
QO
<0.059
16,000
210
28,000,000
3,600
200,000,000
18,000
Pro lbenzene
etrachloroethene
8260
u
NA
A
5
NA
<5
NA
<5
NA
<1,200
NA
<5
NA
<5
NA
NA
NA
<5
NA
<5
NA
NA
NA
<5
NA
<5
<0.059
<0.059
1,500
5
3,400,000
550
2,100,000
2,600
1,2,4-Trichlorobenzene
NA
A
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
<0.059
2,200
22,000
99,000
richlorofluoromethane
NA
NA
NA
NA
NA
NA
NA1,2,4-Trimeth
lbenzene
benzene
A8260Bug/kg<5
NA
NA
NA
NA
NA
NA
NA
NA
NA
NAVin
NA
NAJ35-Tiimeth
1 Chloride
Xle
<10
<5
<10
<5
<10
<5
<10
<5
<inTotal
<5
<1200
<5
<5
NA
<5
<5
NA
<5
<5
<0.059
6,000
630,000
2,700,000
SEMIVOLATILE ORGANICS
Benno aanduacene
8270
UPAR
<660
<660
<660
<660
<660
<660
<660
<660
NA
<660
<660
NA
<660
<660
<660
180
150
2,100
Benzo a ne
8270
uAg
<660
<660
<660
<660
<660
<660
<660
<660
NA
<660
<660
NA
<660
<660
<660
59
15
210
Benno fluoranthene
8270
u
<660
<660
<660
<660
<660
<660
<660
<660
NA
<660
<660
NA
<660
<660
<660
600
150
2,100
Benno fluoranthene
8270
<660
<660
<660
<660
<660
<660
<660
<660
NA
<660
<660
NA
<660
<660
<660
5,900
1,500
21000
Dibenzo a,h thracene
8270
u
<660
<660
<660
<660
<660
<660
<660
<660
NA
<660
<660
NA
<660
<660
<660
190
15
210
1,2-Dichlorobenzene
8270
u
<660
<660
<660
<660
<660
<660
<660
<660
NA
<660
<660
NA
<660
<660
<660
240
1900,000
9,800 000
Bis 2-eth e 1 hthalate
Fluoranthene
8270C
8270
u
591J
<660
7 44
<660
135J
<660
309J
<660
272J
<660
996
<660
502J
<660
374J
<660
NA
NA
5531
<660
<660
<660
NA
NA
221J
<660
5,060
<660
229J
<660
7,200
330,000
35,000
2,300,000
120,000
22,000,000
Inden 1,2,3-ed ne
8270
u
<660
<660
<660
<660
<660
<660
<660
<660
NA
<660
<660
NA
<660
<660
<660
2,000
150
2,100
2-Meth In ene
8270C
u
<660
<660
<660
<660
<660
409J
<660
<660
NA
<660
<660
NA
<660
<660
<660
1,600
310,000
4,100,000
Naphthalene
Phemnthrene
8270C
8270
u
u
<660
<660
<660
<660
<660
<660
<660
<660
<660
<660
430J
<660
<660
<660
<660
<660
NA
NA
<660
<660
<660
<660
NA
NA
<660
<660
<660
<660
<660
<660
210
57,000
3,600
NE
18,000
NE
ene
8270
u
<660
<660
<660
<660
<660
<660
<660
<660
NA
<660
<660
NA
<660
<660
<660
220,000
1,700,000
17,000,000
NOTES:
1. vgtkg=micrograms per kilogram.
2. mglkg= milligrams per kilogram.
3. "<" =Not detected above method detection limit. Table shows "<reporting limit".
4. J = Estimated result less than the reporting limit but above the method detection limit
5. NA = Not analyzed.
.6. • =Sample collected below seasonal high: groundwater table.
7. "' = Chromium III is equivalent to the total chromium value minus the chromium VI value.
8. Table shows onlyconstituents detected in soil at the site.
9. NC HWS SSLs = North Carolina Hazardous Waste Section Soil Screening Levels, as referenced in Federal Remediation Branch Target Screening Values table dated January 2010.
10. - RSLs = EPA Regional Screening Levels updated November 2010.
I U.NE = Not established.
12.: Values shownin bold are above NC'HEW SSLs.
13. Values highlighted in blue we aboveEPAResidential RSLs. O
:14. No values are above EPA Industrial RSLs.

TABLE 2
WELL CONSTRUCTION DETAILS
SAFETY-KLEEN SERVICE CENTER
2320 YADE IN ROAD
CHARLOTTE, NORTH CAROLINA
ATC PROJECT NO.45.1'6031.0007
Monitoring
well.. , .
We11
..Diameter,
inches
Tofal::
-Well Depth.
feet
Screen.
Interval
feet
Date
Installed
Date
Abandoned
TW-2
1
18.5
8.5-18.5
9/8/1999
9/7/2000
TW-3
1
16
6-16
9/8/1999
9/7/2000
TW-5
1
17
7-17
9/8/1999
Existing
TW-6
1
22
12-22.
9/8/1999
Existing
MW-2
2
25
15-25
9/7/2000
Existing
MW-3
2
25
15-25
9/7/2000
Existing
MW-4
2
28
13-28
12/22/2010
Existing
MW-5
2
28
13-28
12/22/2010
Existing
MW-2D
2*
55
45-55
9/26/2003
Existing
Notes:
1. Well MW-2D has a 6-inch outer casing set at a depth of 35 feet.
2. Wells were not installed at the TW-1, TW-4, TW-7, and NM-1 boring locations.

TABLE 3
GROUNDWATER ELEVATION DATA
SAFETY-ELEEN SERVICE CENTER
2320 YADHIN ROAD
CHARLOTTE, NORTH CAROLINA
ATC PROJECT NO.45.16031.0007
Monitoring Well
Date
TOC Elevation
(feet)
Depth to
Groundwater (feet)
Groundwater
Elevation (feet)
TW-2
9/9/1999
97.32
15.70
81.62
10/6/1999
15.65
81.67
11/4/1999
15.00
82.32
11/22/1999
15.38
81.94
11/30/1999
15.34
81.98
TW-3
9/9/1999
97.07
Dry
---
10/6/1999
Dry
-
11/4/1999
15.31
81.76
11/22/1999
Dry
---
11/30/1999
Dry
--
TW 5
9/9/19991
98.06
16.15
81.91
10/6/1999
16.44
81.62
11/4/1999
15.13
82.93
11/22/1999
15.64
82.42
11/30/1999
15.65
82.41
9/20/2000
16.18
81.88
10/13/2008
Dry
---
12/27/2010
97.78
Dry
---
1/24/2011
Dry
-
6/29/2011
Dry
--
TW-6
9/9/1999
98.09
17.10
80.99
10/6/1999
17.14
80.95
11/4/1999
16.15
81.94
11/22/1999
16.66
81.43
11/30/1999
16.60
81.49
9/20/2000
16.76
81.33
12/27/2010
97.75
20.89
76.86
1/24/2011
19.64
78.11
6/29/2011
20.42
77.33
MW-2
9/20/2000
95.41
14.36
81.05
10/13/2008
19.88
75.53
12/27/2010
95.41
NM
---
1/24/2011
19.79
75.62
6/29/2011
19.75
75.66
MW-2D
10/6/2003
NM
19.06
NM
10/13/2008
18.56
NM
12/27/2010
95.48
19.73
75.75
1/24/2011
19.73
75.75
6/29/2011
19.74
75.74
MW-3
9/20/2000
95.32
14.18
81.14
10/13/2008
19.84
75.48
12/27/2010
95.31
19.61
75.70
1/24/2011
19.56
75.75
6/29/2011
19.65
75.66
MW-4
12/27/2010
97.71
20.13
77.58
1/24/2011
20.16
77.55
6/29/2011
19.64
78.07
MW-5
12/27/2010
96.90
20.94
75.96
1/24/2011
20.92
75.98
6/29/2011
20.92
75.98
Notes:
1. TOC = Top of Casing
2. TOC elevations referenced to an arbitrary site benchmark of 100 feet.
2. Depth to groundwater measured from TOC.
3. Wells TW-2 and TW-3 have been abandoned.
4. New TOC survey performed on 01/24/2011 to include new wells.
5. NM=Not measured

TABLE 4
GROUNDWATER ANALYTICAL DATA
SAFETY-KLEEN SERVICE CENTER
2320 YADKIN ROAD
CHARLOTTE, NORTH CAROLINA
ATC PROJECT NO.45.16031.0007
C
G
TEFYCa
U
v
N
N
'C�O
?
•FAOU
"
.^UT,.O�GNJ
:.
... :.
':
..
.; .�y
a�w•7•
o
c
a.QCUU
o.COU
-
..
..
:
`
4
"'O
WO
.CQOU
.
UNO
QO
.
_
7fpT
QU.'
--
..oCa.
v
QydUU
WpCpN-
K
..00
U
U:2
U
U?-
N
m
z
n
A
EPA 8260u - - -
EPA 8270 u
11/23/1999
<100
<5
NA
NA
NA
NA
<10
<5
<5
<5
<5
<5
<5
<5
<5
NA
NA
<50
<5
<100
NA
NA
<5
<5
NA
<5
NA -
NA
<10
<5
<11
<11
9/21/2000
<100
<2
<10
<10
<10
NA
<5
Q
<10
<10
<10
Q
<2
Q
<2
<10
<10
<10
<5
<100
<10
<10
<2
Q
<10
Q
<10:
<10 =-
<10 :-'
<5
NA
NA
TW-5
10/13/2008
DRY
DRY
DRY
DRY
DRY
DRY
DRY
DRY
DRY
DRY
DRY
DRY
DRY
DRY
DRY
DRY
DRY
DRY
DRY
DRY
DRY
DRY
DRY
DRY
DRY
DRY
DRY
DRY--
DRY
DRYDRY
DRY
12/27/2010
DRY
DRY
DRY
DRY
DRY
gDRY
DRY
DRY
DRY
DRY
DRY
DRY
DRY
DRY
DRY
DRY
DRY
DRY
DRY
DRY
DRY
DRY
DRY
DRY
DRY
DRY
DRY
DRY
DRY-.
DRY:
DRYDRY
NNAH
DRY
TW-6
11/23/1999
<100
<5 -
NA
NA.
NA,
:NA
. <10
<5
<5
<5
<5
. <5
<5.
<5
<5
NA .
NA
<50
<5
<100
NA
NA
<5
<5
NA:
<5
NA
..NA
<10
<5.<11
<11
9/21/2000
<100
Q
<10
<10
<10..
NA
<5
<2
13
<10
<10"
8
<2
6 "
Q
<10
<10
<10
<5
<100
<10
<10
<2
Q
<10'
<2
<10, -'
<10--'
<10
<5
<10
<10
10/13/2008
<100
Q
<10
<10
<10
<10
NA
<5
Q
<10
<10
<10
Q
Q
<2
Q
NA
<10
<10
<5
<100
<10
<10
Q
<2
<10
Q
<10
<10
<2.
<5
NA
NA
MW-2
1/24/2011
<100
<2
<10
<10
<10
2.2.1
<10
<5
<2.0
0.5J
<10
0.0
1.2J
<2.0
Q
Q
<10
<10
<10
<5
<100
I <10
<10
0.3.1
<2
<10
<2
-;-M -
<I0'
<2.
<5
0.081
<10
<10
6/29/2011
<10 .
<1.0
<5.0
<5.0
<5.0
<2.0
<10
<1.0
<1.0
<1.0
<1.0
<1.0
0.5J
<1.0
<1.0
<1.0
<5.0
<5.0
<10
<1.0
510
<5.0
<5.0
<1.0
<1.0
<5.0
<1.0
<5.0
" <5.0
<1.0
<2.0
<0.9
<9.4
<0.9
10/6/2003
<100
Q
<10
<10
<10
<10
NA
<5
Q
<10
<10
<10
6
Q
8
Q
<10
<10
<10
<5
<100
<10
<10
<2
<2
<10
<10
<10 '
<10
Q
<5
NA
NA
NA
10/13/2008
<100
Q
<10
<10
<10
<10
NA
<5
Q
<10
<10
<10-
6
Q
Q
Q
NA
<10
<10
<5
<100
<10
<10
Q
Q
<10
Q
<10 "
<10
Q
<5
NA
NA
NA
VMW-2D
12/27/2010
<100
Q
<10
<10
<10
<10
<10
<5
<2.0
<10
<10
<10
3.9
Q.0
0.51
Q
<10
<10
<10
<5
<10
<10
<10
0.0
Q
<10
Q
<10--_
- <10 -
Q
<5
<1
<10
<10
6/29/2011
<10
<1.0
<5.0
<5.0
<5.0
Q.0
I <10
-<1.0
<1.0
<1.0
<1.0
<1.0
4.1
<1.0
OAJ
<1.0
<5.0
<5.0 -
<10
<1.0
<10
<5.0
<5.0
<1.0
<1.0
<5.0
<1.0
<5.0
<5.0
<10
Q.0
<1
<10
<1
9/21/2000
<100
Q
<10
<10
<10
210
NA
<5
Q
<10
<10
<10
Q
<2
Q
Q
<10
<10
<10
<5
<100
<10
<10
Q
<2
<10
Q
<10
<10
<10
<5
<10
<10
<10
10/13/2008
<100
Q
<10
<10
<10
<10
NA
<5
Q
<10
<10
<10
Q
<2
Q
<2
NA
<10
<10
<5
<100
<10
<10
<2<2
<10
<2
<10
<10-
- <2
<5
NA
NA
NA
MW-3
12/27/2010
<100
<2
<10
<10
<10
<10
<IO
<5
<2.0
<10
<10
<10
<2
<2.0<2
<2<10
<IO
<10
<5
<IO
<10
<10
Q
Q
<10
Q
<10_
<10'
<2-
<5
<0.98
<9.8
<9.8
6/29/2011
<10
<1.0
<5.0
<5.0
<5.0
<2.0
<10
<1.0
<1.0
<1.0
<1.0
<1.0
<1.0
<1.0
<1.0
<1.0
<5.0
<5.0
<10
<1.0
<10
<5.0
<5.0-
<1.0
<1.0
<5.0
<1.0
<5.0
<5.0
<1.0
Q.0
<1
<10
<1
12/27/2010
7.2J
0.51
15
6.8J
3AJ
3.3J
<10
<5
<2.0
20
2.OJ
4.8J
1.2J
Q.0
1.SJ
5.8
12
4.8J
<10
<5
5.6J
11
<10
1.0J
0.5J
2.3J
OAJ
230
71 '=
Q-
39
<0.99
9.0
7.2J
MW-4
6/29/2011
<10
1.5
<5.0
4.5J
1.11
14
<10
1.5
<1.0
20
2.2
5.6
15
0.6J
27
9.6
1.2J
3.OJ
<10
<1.0
<10
<5.0
3.9J
<1.0
<1.0
<5.0
<1.0
16
.:c3:2J'
0.6J
4.4
<1
10
0.7J
6/29/2011 (dup)
- <10
1 1.8
1, <5.0
1 11
1.5J
1 17
<IO .1
1.8
1 <1.0
24
2.6
6.1.
14
0.7J
26
11
1.2J
4.OJ
<10
<1.0
<10
4.0
6.3
<I.0
<1.0
<5.0
<1.0
33- _
'4:7J.
0.91
5.5
<1
11
0.91
12/27/2010
4.2J
OAJ
2.0
2.OJ
2.4J
11
<10
0.7J
Q.0
6.7J
0.9J
2.4J
25
Q.0
10
Q
3.21
<10
7.0J
<5
<100
3.2J
<10
Q
0.2J
2.1J
Q
2.9J
2:SJ
HE:
Q
2.5J
<1
11
<10
MW-5
12/27/2010 (du
4.9J
OAJ
2.5J
2.5J
2.5J
16
2.4J
0.81
<2.0
11
1.0
4.5J
27
<2.0
11
Q
3.0J
<10
<10
<5
7.OJ
3.1J
<10
Q
0.3J
2.IJ
Q
2:1J -
0.4J
<5
<1
9.3J
<10
6/29/2011
<10
0.3J
<5.0 _
<5.0
<5.0
17
<10
1.0 .
<1.0
2.4
1.1
3.4
53
OAJ
24
<1.0
<5.0
<5.0
<10
<1.0
<10
<5.0
<5.0
<1.0
<1.0
<5.0
<I.0
<5.0-
<5.0
OSJ
Q.0
<1
<10
<1
NC 21, Std
6.000.
- 1 1
ZO' 1
70 1
70 1
50 .
' . NE
1 3.000'
70 1
'..20-- 1
200
6
1 . 6.
7
:. 70
1 600 _
NE
:70 : -
280,
1. 5
1 4,000
6
70
0.7
600 "
70
. 200
.:400
-4W-t 7
0.03
500
0.05
20
6 "
NOTES:
1. ug/L = micrograms per liter.
2. "<" =Not detected above method detection limit. Table shows "<reporting limit".
3. J = Estimated result less than the reporting limit but above the method detection limit.
4. NA=Not analyzed.
5. Table shows only volatile or semivolatile organic compounds detected in groundwater at the site.
6. NC 2L Std = Title 15ANCAC 2L .0202 Groundwater Standard
7. NE= Not established.
8. Values shown in bold are above the 2L Standard.

TABLE 5
GROUNDWATER FIELD PARAMETER DATA
SAFETY-KLEEN SERVICE CENTER
2320 YADKIN ROAD
CHARLOTTE, NORTH CAROLINA
ATC PROJECT NO.45.16031.0007
Sample
Identifications°
Date
Time
Temperature
:.. -
'Conductivity :
DissoNed.Oxygen
: pH
'Oxygen-.
Reduction
Potential . '.
°C
ms/cm
m
standard units
my
MW-2
1/24/2011
14:33
15.43
0.328
1.01
6.23
104.0
14:36
15.75
0.328
0.97
6.30
101.4
14:39
15.89
0.238
0.86
6.28
100.9
6/29/2011
13:20
30.50
NM
7.68
5.69
351
13:25
29.23
NM
7.87
5.89
347
13:30
27.12
NM
8.31
6.21
344
13:35
26.47
NM
8.57
6.40
348
MW-2D
12/27/2010.
12:56
13.94
0.332
0.79
7.33
28.5
12:59
13.83
0.330
0.49
7.37
29.5
13:02
13.50
0.329
0.47
7.38
31.1
13:05
13.49
0.326
0.46
7.38
32.8
6/29/2011
14:15
26.20
NM
8.58
6.68
360
14:20
26.02
NM
8.46
6.88
359
14:25
26.24
NM
8.31
6.94
374
MW-3
12/27/2010
13:47
3.67
0.176
3.05
6.25
81.6
13:50
3.12
0.175
3.82
6.13
88.3
13:53
3.03
. 0.173
4.90
6.02
92.4
13:56
3.15
0.172
5.06
5.98
94.8
13:59
3.13
0.171
5.21
5.97
96.0 .
6/29/2011
15:35
27.76
NM
8.22
6.00
349
15:40
24.61
NM
9.07
6.39
332
15:45
24.11
NM
9.35
6.48
335
NM Not measured due to conductivity sensor malfunction.

TABLE 5
GROUNDWATER FIELD PARAMETER DATA
SAFETY-KLEEN SERVICE CENTER
2320 YADKIN ROAD
CHARLOTTE, NORTH CAROLINA
ATC PROJECT No. 45.16031.0007
Sample
Idenfifications
Date .. `
Time.
Temperature
Conductivity
Dissolved Oxygen
pH-
Oxygen_
Reduction
Potential . .
°C
MS/cm
m /L
standard units
mV
MW-4
12/27/2010
10:13
7.11
0.300
6.75
7.40
116.5
10:16
6.78
0.297
6.29
7.05
116.5
10:20
6.73
0.285
5.79
6.96
112.2
10:23
6.69
0.281
5.80
6.87
111.5
6/29/2011
10:26
22.94.
NM
8.48
6.33
509
10:32
22.28
NM
8.65
6.47
515
10:35
21.96
NM
8.73
6.78
512
MW-5
12/27/2010
11:25
.14.92
0.270
8.01
6.11
96.2
11:29
14.92
0.269
7.90
6.09
96.2
11:33
15.15
0.297
7.69
6.10
93.7
6/29/2011
11:50
31.41
NM
7.27
5.62
380
11:55
29.45
NM
7.49
5.69
417
12:00
29.19
NM
7.49
5.76
422
12:05
29.08
NM
7.50
5.81
442
NM=Not measured due to conductivity sensor malfunction.

l
FIGURES
Figure 1:
Site Location Map
Figure 2:
Site Map
Figure 3:
Groundwater Contaminant Concentration Map
Figure 4:
Groundwater Elevation Contour Map
Figure 5:
Cross -Section Location Map
Figure 6:
Cross -Section A -A'
Figure 7:
Cross -Section B-B'
Figure 8:
Proposed Injection Locations
Figure 9:
Injection Well Construction Diagram

APPENDIXI:
M��� �TI11_��wiKela[is)V��' f

F H A 6 t T .zNJEC-n-oN
ATC Associates
Page 6
AREA "A"
There are two groundwater treatment areas proposed to treat contamination present in the
vicinity of the drum washing area on the Safety Kleen site. The treatment area in Area "A" is in the
vicinity of monitoring well MW-4. The first treatment area, Area "A" will target a 1,350 square
foot area and will require 6 injection points based on a 9 foot proposed injection radii, treating
between 15 and 25 feet below ground surface. This treatment depth is based on the provided
boring logs. Three injection intervals are proposed to treat the ten foot vertical contaminated
zone from 15-17 feet bgs, 19-21 feet bgs, and 23-25 feet bgs. Soil concentrations are estimated to
be somewhat elevated in Area "A"; therefore the soil Freundlich absorbsion correction is
somewhat high (IET has assumed the value to be 15%).
Area "A" calculations are located below in Appendix 2. A map of the contaminated treatment
area is located below:
Ili Injection Area "A" (1,350 MR)
'0�
0 15 30 50
iiiiiiia
APMC70YATE SCAU iN FEET
AREA "B"
The second treatment area, Area "B" will target a 2,050 square foot area and will require 8
injection points based on a 9.5 foot proposed injection radii, treating between 15 and 25 feet
below ground surface. Three injection intervals are proposed to treat the ten foot vertical

ATC Associates
Page 7
contaminated zone from 15-17 feet bgs, 19-21 feet bgs, and 23-25 feet bgs. Soil concentrations
are estimated to be somewhat elevated in Area "B"; therefore the soil Freundlich absorbsion
correction is moderate (IET has assumed the value to be 10%).
Area "B" calculations are located below in Appendix 2.
IET estimates that this injection will take 1 day to implement the remedial design. The price
present herein is guaranteed regardless of the actual field time required to implement the
program described herein.
The "Lump -Sum" price set -forth assumes that a water supply and a secure storage area for
chemicals are available for the duration of the project.
SCOPE OF WORK
The first treatment at the Safety Kleen site will require the presence of IET personnel to emplace
the remedial material into the open excavation and oversee the backfilling of excavated area.
The injection event will require 6 injection points in Area "A" and 8 injection points in Area "B",
and will treat a combined area of 3,400 square feet.
Subsurface Pathway Development
Initially, compressed air shall be delivered to the subsurface via IET proprietary injection trailer
system. This process step allows for confirmation of open delivery routes while enhancing
horizontal injection pathways. The confirmation of open and viable subsurface delivery
pathways insures that upon introduction of the oxidizer(s) injections will occur freely thus
minimizing health and safety risks associated with oxidant full injection lines and injection
tooling when no subsurface delivery route has been established. Confirmation of open and free
pathways is accomplished via observed pressure drops and fee moving compressed gases to the
subsurface.
Oxidant Injection
A colloidal suspension of 2-4 micron zero valent iron (ZVI) is immediately injected into the
subsurface pathways and voids that were developed during the compressed air injection step.
jThis step will be followed by a predetermined volume of a 2.5% or 5% solution of HZOZ.
Immediately following, under constant pressure, a sodium persulfate solution will then be
introduced. A small amount of water follows this step in order to rinse the injection equipment.
Post Liquid Injection — Compressed Air Injection

ATC Associates
Page 8
Lastly, the injection lines are cleared of liquids and all injectants are forced into the created
formation and upward into the vadose zone. This step insures that all material is injected
outward into the formation and minimizes any surface excursions of injectants following the
release of the injection pressure.
Once the injection cycle is complete, the injection point is temporarily capped to allow for the
pressurized subsurface to accept the injectants.
Equipment Description:
The injections small occur via IET's mobile oxidation injection trailer and IET's direct -push
equipment as described:
Injection Lines: High Pressure Stainless steel Braided Rubber one inch and 3/ inch diameter
Injection Trailer: IET Self-contained injection trailer, consisting of: two 120 gallon conical tanks
capable of maintaining unto 30% solids as a suspension via lightning mixers; on -board
generator, all stainless steel piping system, 2" pneumatic diaphragm pump with an operating
pressure of 110 psi.; on -board 25 CFM/175 psig compressor with 120 gallons of air storage; self
contained eye wash and safety shower.
Injection Rods: IET proprietary injection rods with retractable injection zones and backflow
protection Injection zones of 18 inches are to be used in combination with 24" injection AWJ-
Rods where appropriate.
Injection Equipment:
IET Self -Contained Oxidizer Injection System - consisting of - all stainless steel 316 piping,
compressors (175 psi/25 CFM), on -board generator, self-contained safety shower and eye wash
stations. The system has a spray -on rubber lined floor and walls, with bermed secondary
containment.

ATC Associates
Page 9
United States Patent 7,044,152
lET NI' MOBILE INJEC HON SIS I LM
Injection Fwd t lrlR - f orifignr:ttion
alink � M"
Feed Systems, Safety Systems, Compressed Gas Systems
All piping II elded Stainless Steel
Floors Coated in Chemical Resistant RinoLining

ATC Associates
Page 12
a Injection Area (3,400 RXFt)
♦
' �...- �,.. •'� '�--�:�`_'•`..-:.�_� fir..
C 15 30 (3
4114ALAArk F*U

ATC Associates
Page 14
AREA A
SAFE}Y-HLEEH,CR.%nLOTTF DC
A.,.
lnjsti,:ifn,ad
Ilaunn:lux __
1pmal llnll
:714WNW l:11t cbr,llrCA•-
Are, or nfucnce of 7:trcdtl3n I1
�
l+lnlmuL:ilhna:
I
�.
sacra -----------
i
------- -- -- - - -- --
— a.aauas ma
r� a rr
Issr
I
I
Fp
coral7R Imo`
15
"cstmfs/ �Eq.FL
251A53117
l
aP. A•,:r
A;
r3
TreiVauT* ru)rAl
Cu.1V"
AD
"a'slff
�S:
j
30 (I:S
I
�'tass of salt be mrp9N
Iss
10S030)
7asa ofwIl2 bl mrwid
�1'a10
470*79:0)
"ti's a•ur„r•aln--aL,"Iu.'f-1:,1
•:1naY1nll Csne --
iv7r
PM
_ �_—.—_-
5437S
' {skull slbns7araesca [oic�osnys j-
-- .._.
I
- ..._ .._ - -- - - - {I
I
'lass of{oanrFm:-wrier 11. I
lmai;,2iave Vol'2assuiT219NOI CompLuds.;,n:i
'Lass afio7lxhln: wmer
i0nIs
5757429375 Mates
1019:0-fi!
Yassoltoilatsrrasll
la.
r
4M71E237 WA VaWa'H'e'D2
� 34I
IManor Cebatarsa2'
Cmm
USS57171i Malca+af H202
IWAS
2WogsEg9r►A6:TIIa:eJ1 _ _---
lase
Clatil -
_
191D1,601 tlris YaA 31punur--s-
i2111
--- --
.__...
-1I.13111MI, Marea7l He2S310
W,tA712A•i _.._.... _. __.
atr:orerrnen:IsrgeLrS _— __—,I _
:1kSrsdz:(em: 'Derr
_. ___-_.. .. _._ I
ursrsofFlOZFIeg13•ed-
�Grais
_Gs _el2:1 3egted
Iss
IAeta
i
210123DOW
"
i>t'o of:W5 to lu?e:ed Cc-noure
•:Lars Mardui, pan[:ttW
=oinsa of 7vllun tiillslefe�rrnl
F:u',ds
t----132Jet:V2W
_faYGo.90O rinlr liars K k
lmwt!ACompaurde
layr:ad GirmbgDollarnsovewb-ij
qqs or_V: 5nsxL:Lk,P
. 29
10.SD
0xwDoslb-r Rtx s13o91�Fersu law
----
- --- -----.
In
4Vw:rnnrfh,hY.anrnaxy-Mx.+ruu ,rfiJ•r x'l+
_ L�i:dim 7onra iS
4,a,iv u+:nN+m Verc,11�1a ps,J.arw� _
Cost East? Prr iltortlsn 2"n1
la,a,utamsd,w,,,,l„wJlub:n � J
Gatbrss orsm lam Reguirol -----
Rumatraflole-&nl.dnco perklma
Dlgs oI.R1I 1311 Tralter
D.j.of 0.11 Riq
tEaLa idCasl pi _1wi:gr a,wLLc masr�eurRnl elrl
-
M_ lniwa I I
'icR1Af ! � I
4o.1S
I
1
�10
75 -
fe I I i
t !
_ FalwwkA ".I
MM
— 1 IS4A/ j
41Z f102S U2a25j
6D] !
OA7 f7.11Aa) i f }17i0aDl

ATC Associates
Page 15
AREA B
SaFFi ALEEH;CHARLOTT!E, aC I
A". R
9nasliu. Frc,a
r.a,.pul�„ 'Itl1.
.ti".ma Ila11 i!: y.S
:at axxx m:aircim TxOAW Coral=
lily. of r.1mrco 07=rtedUm h:ancaft? `A.FL ISU234375
'7snu"I lhld..a ufruhiuu'a T-1 A•o. �A:infi. E I
rc!!:a,l iili M:cd,au 'FI _ It
!
Tir�I jyP.: i 75'^i I
TaalVaune Tsr)exy ICu. YE. 733M32;&3
Vam of salt ai mrq,30 Isr, i5•ausl,w�
123garsolbb vIp:IN
lhi'„vufGrnl'dnal_i 4l•stiL•J 'Vj. �il125
:ma-l[wlCm:.-�pxr_____---- -- ---- ) Cakulelbns T,nered Coa w[n!s _ . .
'JamorCoTasrtlso:-wirer Is. 1L1564]13o,2',Y ymi -- 92 ---
'Zan DrC*Thrrhsa:-waxr �9ra-IS i24.015747S Males I 9DASH
1JaYJaf Colt9rhsrt.=oA' Ils. I 333EEn"S W-la 110;2 at H232 34
'lase of Colt:rtm iX! Cmv 15157:5M8S Malca al H2012 3Ja.l9)f
Vale arQ7I3TV .,.Talgpp07_ _ CMSIG FI - - _ - - _ ILIB# Lila Yme l 1,31D11r-b _ � _ NO
''JascatUo1wimn:Illge1*3 I•o __. 31d,ILs38)MolaaofRe2TisEM1, r _ G_��_
lIC1T.9C 6:1.CM :•
xsysNl'242Rtglltd Orals
_Ds'YI 232 ieq"ta0 bs 172.Tt'7lSfJ• !
;two of_W310 ivyea Cwuouns 'Palo
:Y,ec MllMun,rn,:MW !aqm 3If7leNar,4 FUL-ka1ti+131r it ll-
:J.%M7:x.
.4I all M.I :LM.a. V.MI.IAM pK 1
-0laelt. e<a,Lm V�NUIxIMP.f,
Sp 11tlra g5?af2,}:;NI WiA:vIl
it mog Mrldectloli Event
OamDaroflnloeews Mlncs ptr£unc
DiY7 Oi)'.a)ecllan 7r81rr
D.gaAD. it ay
lui.'rnalNl' •C w. _
D"!as _ _^ r_— ILW.IRAULt1 Ia 1ryMedtampaloxlc __ ' _ _ --�
da) 1rin - - - -A
_T T- -- ---
d,olai 1
1S1xai
15d7; i).?i'; 9SS5'
?S
-D—q aM 1J1] �M.�R VNI NnIIYIN IINI tI/Nl ral I
I
1 ST,,S Falia.liis rlal
RIDJst; SR-% - �— _ SS;INIba
asram SMTJ - - I 31Ma11!
)Sa7 stags
88] I
DA] 5,41 S") 'j1.2i084
aR 81r5'SM) 59"JID'
J.li 41,95611] I. :S75a00
.1o14 - Tu1- -,-. i11872Ds

i-!
ATC Associates
Page 16
APPENDIX 3: TECHNOLOGY DISCUSSION
Advanced Oxidation
j 1 Oxidation is defined as a chemical process in which electrons are transferred from an atom, ion
or compound. The in -situ chemical oxidation process is designed to destroy organic
contaminants either dissolved in groundwater, sorbed to the aquifer material, or present as free
product. Oxidants most frequently used in chemical oxidation include hydrogen peroxide (HZOZ),
potassium permanganate (KMn04), persulfate (Na208S2) and ozone (03). Peroxone, which is a
combination of ozone and hydrogen peroxide, is also used. Fenton's Reagent, which is hydrogen
peroxide mixed with a metal catalyst, commonly an iron catalyst, can also be used. In -situ
chemical oxidation (ISCO) can be accomplished by introducing chemical oxidants into the soil or
aquifer at a contaminated site using a variety of injection and mixing apparatuses. Normally,
vertical or horizontal injection wells are used to deliver chemical oxidants. Ex -situ oxidation is
accomplished by pumping groundwater from extraction wells and treating the groundwater
above ground. In the recirculation approach, oxidants can be mixed with the extracted
groundwater, which is subsequently pumped back into the aquifer through injection wells.
What are the advantages and disadvantages of chemical oxidation?
Chemical oxidation offers several advantages over other in -situ or ex -situ remediation
technologies for petroleum compounds:
• The greatest advantages are the rapid treatment time and the ability to treat
contaminants present at high concentrations.
• It is effective on a diverse group of contaminants and can often achieve maximum clean-
up results.
What contaminants can be treated with chemical oxidation?
Common contaminants treated by chemical oxidation are amines, phenols, chlorophenols,
cyanides, halogenated aliphatic compounds, mercaptans, BTEX compounds, MTBE and
certain pesticides in liquid waste streams. Oxidation effectiveness depends on the organic
compound.
Is chemical oxidation safe?
While the use of chemical oxidation can be quite safe if done properly, there are significant
potential hazards. Most oxidants are corrosive. This means that they have the ability to

ATC Associates
Page 17
burn the skin and wear away certain materials. Chemical oxidation also has some
disadvantages. The disadvantages are as follows:
• Oxidation is nonselective. As such, the oxidant will not only react with the target
contaminants but also with substances found in the soil that can be readily oxidized. In the
case of gaseous ozone, the ozone can react with water and decompose to oxygen. Oxygen
production can lead to serious problems such as the development of high pressures below
the ground surface and possible explosions.
• Control of pH, temperature, and contact time is important to ensure the desired extent of
oxidation.
How long does chemical oxidation take?
The time required to clean up a contaminated site using chemical oxidation is dependent on
the reactivity of the contaminant with the oxidant, the size and depth of the contaminated
zone, the speed and direction of groundwater flow and type of soils and the conditions
present at the contaminated facility. Generally, chemical oxidation is more rapid than other
treatment technologies. The time scale is usually measured in months, rather than years.
In -situ oxidation uses contact chemistry of the oxidizing agent to react with volatile organic
compounds, munitions, certain pesticides and wood preservatives. The most common
oxidizers used in soil and groundwater remediation are hydrogen peroxide- (and the
hydroxyl radical), potassium permanganate, and ozone, which are non -selective oxidizers.
Other oxidants are available, but are used less due to cost, time or potential toxic by-
products.
Radical Production
Hydrogen peroxide when in contact with a metal catalyst such as iron (II), which is
commonly known as Fenton's reagent, forms the more powerful oxidizer, the hydroxyl
radical. The metal catalyst can be a variety of substances such as iron oxides within the soil
or fill, separately added iron sulfate, and zero-valent iron particles. Fenton's reagent has
been well documented for over 100 years and has been in use in water treatment plants for
well over 50 years (Barb et al.,1950; Stanton et al.,1996). The chemistry is well documented
(Watts, et al, 1991, 1992 and 1994) to destroy petroleum hydrocarbons and other volatile
organic compounds. Hydrogen peroxide arrives in the field as a liquid stored in poly drums.
When the oxidant hydrogen peroxide (HZOZ). is injected into the subsurface, it decomposes
readily into reactive hydroxyl radicals (OH•), hydroxyl ions (OH-) and water (HZO). The

ATC Associates
Page 18
oxidation of a contaminant by hydrogen peroxide involves complex reactions influenced by
a number of variables, including pH, reaction time, temperature, catalysts, and hydrogen
peroxide dosage. Hydrogen peroxide works best in acidic environments with low alkalinity.
There are also a large number of competing reactions including the free radical scavengers,
Most importantly, carbonate and bicarbonate alkalinity that will greatly affect the overall
reaction scheme. Although handling hydrogen peroxide and other oxidants requires
significant safety training and planning, the oxidant is effective at remediation and relatively
inexpensive. Forensic chemical analysis from various sites have shown that the hydrogen
peroxide reaction tends to work first on the longer chain carbon sources, including total
organic carbon. (TOC), rootlets, heavier -end hydrocarbons, prior to oxidizing the lighter
hydrocarbons.
Technology Selection:
Traditionally, oxidation processes utilize oxidizers, which require no activation such as peroxide,
permanganate, persulfate and ozone, or oxidants which require activation such as Fenton's
Process and activated persulfate. The advantage of activated processes is the evolution of free
radicals, which offer higher oxidation capabilities and a broader spectrum of applicable targeted
compounds. The disadvantages of activation processes and the evolution of free radicals, is the
limited half -Fives of these species. The proposed remedial approach utilizes both free radical
chemistry and oxidation chemistry in such a way as to extend the oxidant and free radical
residual, and to further stimulate the biological mineralization of the petroleum compounds
present at the site.
Further, once exhausted, the sulfate ion produced as a consequence of the decomposition of
the persulfate allows for attenuation under sulfate reducing conditions
The contractor, Innovative Environmental Technologies, Inc. (IET), intends to apply three
remedial materials to the subsurface via a patented injection process and apparatus (United
States Patent # 7,044,152) such that the activation processes occur in a controlled manner in -
situ. In a unique application of zero-valent iron metal (2-4 microns in size), the contractor will
activate both the'persulfate and the peroxide species in -situ. Typically persulfates are activated
via one of three mechanisms: heat, peroxide or soluble metal species. In the proposed
approach there is limited activation via the evolved heat produced via the interaction of the
peroxide and the iron particles. In addition to the limited heat production produced from the
interaction of the iron and the peroxides, hydroxyl radicals are produced and iron oxides are
formed on the surface of the particles. The peroxide and the metal ions at the iron surface all
serve to activate the persulfate, forming sulfate radicals.

ATC Associates
Page 19
Oxidation Reactions Proposed:.
H202+ FeO --) Fe+3+ OH'+OH'
Fe+3 + H2O2 -> Fe+2 + H+ H02
S208 + FeO --> Fe+3 + SO4- + SO4'
Direct oxidation of NaS20s and H2O2.
Attenuation Process:
Sulfate Residual:
After dissolved oxygen has been depleted in the treatment area, sulfate (by-product of the
persulfate oxidation) may be used as an electron acceptor for anaerobic biodegradation. This
process is termed sufanogenesis and results in the production of sulfide. Sulfate concentrations
may be used as an indicator of anaerobic degradation f fuel compounds. Stoichiometrically,
each 1.0 mg/L of sulfate consumed by microbes results in the destruction of approximately 0.21
mg/L of BTEX. Sulfate can play an important role in bioremediation of petroleum products,
acting as an electron acceptor in co -metabolic processes as well. As an example of benzene
mineralization under sulfate reduction:
C6H6 + 3.754 S042- + 3 H2O 4 2.25 H+ + 6HCO3- + 3.75HS-
Ferrous Iron:
Ferric iron is also used as an electron acceptor during anaerobic biodegradation of petroleum
hydrocarbons after sulfate depletion, or sometimes in conjunction with sulfate. During this
process, ferric iron is reduced to ferrous iron which is soluble in water. Ferrous iron may then
be used as an indicator of anaerobic activity. Stoichiometrically, the degradation of 1 mg/L of
BTEX results in the production of approximately 21.8 mg/L of ferrous iron.
The advantages of the approach proposed are:
1) Management and containment of the activating iron species within the treatment area,
2) Evolution of free radicals,
3) Extended residual of persulfate and the sulfate radical in -situ,
4) Attenuation following the exhaustion of the persulfate via Fete/Fe+3 interactions and
SO4+,
5) In -situ management of sulfate via in -situ precipitation of sulfate iron salts as the in -situ
conditions revert back to a less oxidizing environment.

ATC Associates
Page 20
6) Transitioning of the area in which the oxidation occurs back to anaerobic will allow for
facultative conversion of the targeted.compounds by -way of iron and sulfate reducing
pathways.
Based on the data available, the techniques practiced by Innovative Environmental Technologies,
Inc. and proposed. herein are.ekpected to greatly decrease residual concentrations at the site and
greatly accelerate the biological mineralization of both the petroleum constituents and chlorinated
solvents in both the targeted soil and the groundwater of the site.
Critical to the success of the proposed remedial technologies -is the successful delivery of the
various materials to the targeted groundwater and soils.

PO S916 LE p H k ,- .IJ-- -TN,-TE CTn a N
91ET
Innoratite EmiltlnmentW 7i4iinokgcs, Inc -
Dosage Calculations: 15-25 feet bgs
SAFETY-HLEEII, CHARLOTTE, NC
Permenani Injection Wells
Saturated Zone
Injection Event
Parameters
Units
Assumptions
Target Area
FtA Ft
:200
Injection Red.
Ft
15
Sol Absorbs*n Correction for GAC Constant
%
13
Area of influence of Remediatpn Injection(s)
Sq. FL
700.8577E
Estimated Number of Injections to Treat Area
a Injectons
4
vertical nrpacted zone
FL
10
Target Zone
1545'
Total Volume Targeted
Cu. Yd.
1037.037037
Porosity
%
10.00:.
Mass of sag to be targeted
ras
21M77.778
Mass of sod to be targeted
grams
983711I11.1
Volume of Groundwater targeted
gals
83000
Contaminant Cone
PPm
_ Calculations Targeted Compounds
Lass of Contaminant -ureter
*.
2.63025 Ave Gloi Mass of Targeted Compounds gjmol
52
Mass of Contaminant -water
Grams
1194.1335 Moles
361.58417
Glass of Contaminant -sot
W.
r
70.64231256 Vo* Glass of H202
34
Glass of Contarjinant-sot
Grams
32071.60" Moles of H2O2
4392.0211
Glass of Contamnent Targeted
Grams
33266.7434 Stole Mass of Persulfate
238
Mass of Contamnent Targeted
Its
73.27266256 Moles of Ne2S2O9
1269.7756
Calculated sal cone.
PPm
33.64656444
Grams of H2O2 Required
Grams
165328.717
Los of M202 Required
Ibs
366.3628128
Redo of S203 to targeted Comcouns
Rat*
30
Grams of sodium persulfate
grams
997972.3021 Molar Ratio Cale
Pounds of Sodium Persufate Requred
Pounds
2195.176877 Targeted Compounds
1
Targeted Percentage of ZVI n pore volume
%
0.11% H2O2
13.63
Pounds of ZVI (3 micron) rqured
pounds
_-4 Na2S208
17.34
Decomposition Rate of Sodium Persulfate
%/day
1.104E
Targeted Longevity of Persulfate
days
45.00
Total Persulfate CalculaEed dosage
pounds
3288.27
Injection Summary
Number of Injection Locations
4.00
injection Depth
15-25'
Pounds of 2-4 micron ZIA
594.00
Pounds of Sodium Persulfate
2199.13
Pounds of Persulfate with Longevity
3286.21
Galan$ of 504E H2O2
69.78
Injection Point Summary • Number of Intervals
3.00
Injection Zones
1SAT; 19-21';
23-25'
Pounds of ZVI per interval
50
Pounds of Sodium Persulfate per interval
164
Pounds of Sedum Persulfate per interval vd Ionge•ay
214 4.94
Bags Persulfate per interval
Galons of 2.5% ri202 per nterval
Its
Cost Basis Per injection Event
Cost Basis Event+1
SNnit
Extended Cost
Pounds of ZVI (3 micron) required
600.00
$6.50
$3,900.00
Pounds of Sodium Persulfate Required
3286.27
$3.33
S11,140.47
Gallons of 50%H202 Required
70.00
$10.25
S717.50
Humber of Injection Points per Event
4.00
Days of Injection Trailer
0.50
S3,150.00
S1,575.00
Packers
0.5
S1,600.00
S800.00
Administrative Costs
OS
S1,250.00
S525.00
Material Cost (Including on -site management etc)
Total S111,757.97

APPENDIX 3:
CASE STUDIES

Imwv"w FAvkup11"W Tecimk&s, hr.
DA
Proiect Summary:
The subject site is a former gasoline terminal located outside of Erie, Pennsylvania. The
site has historically had groundwater and soil contamination with free product present
due to historic petroleum spills. The site was contaminated with BTEX and varying
levels of free product. The in -situ injection program targeted these compounds as well as
the free product with advanced chemical oxidation technologies including a combination
of sodium persulfate and hydrogen peroxide, activated by zero valent iron. A total of 70
injection points were utilized to treat a total of 10,775 square feet from 8-17 feet bgs.
The geology at the site is primarily silty clay with some gravel, sand, and shale
fragments.
Remediation Plan
The remedial approach taken at the site utilizes both free radical chemistry, oxidation
chemistry and facultative biological oxidation in such a way as to extend the oxidant and
free radical residuals while enhancing the in -situ environment such that it is suitable for
biologically based attenuation. IET applied three remedial materials to the subsurface via
a patented injection process and apparatus (United States Patent # 7,044,152) such that
the activation processes occur in a controlled manner in -situ. In a unique application of
zero-valent iron metal, IET activated both the persulfate and the peroxide species in -situ,
affecting the oxidation and biological remedial processes in a single injection process.
The first phase, oxidation, oxidizes the majority of dissolved and sorbed targeted
compounds. The second phase, biological attenuation, polishes and maintains the
achieved treatment goals.
Results
The remedial goal at the site was to achieve site specific groundwater concentrations and
remove free product. Six months after the injection event, all of the groundwater
concentrations were not only below their site specific health standards but also below
their statewide health standards. No free product is present at the site. The initial
increases in benzene concentrations due to the homogenization of the subsurface have
decreased to baseline sampling event results or below with the most heavily contaminated
monitoring well, MW-7, currently having no analyzed petroleum compounds above their
laboratory detection limits. The site has reached closure less than 9 months after the
injection event.
MW-7 VOCs
InKNon
Fenl
�[mylEenzem
¢—N�ne
�lro
Ord vAV+ou WV—
'A
-Mr— VM i
W4--
V��
vVW— i/s/xo�i

INNOVATIVE ENVIRONMENTAL TECHNOLOGIES, INC.
Technology Discussion and Data Evaluation
to
Environmental Consultant
For
Former Gas Station
Central NY
October 2010
Innovative Environmental Technologies, Inc.
6130 Kit Road
Pipersville, PA 18947
[phone]

Executive Summary:
Chemical oxidation was used to degrade benzene, toluene, ethylbenzene and xylene
(BTEX) compounds present in soil and groundwater at a site in Central New York during
the days of October 28a' and 29a', 2009. Utilization of free radical chemistry, oxidation
chemistry and facultative biological oxidation was implemented in such a way as to
extend the oxidant and free radical residuals while enhancing the in -situ environment so
that it is suitable for biologically based attenuation. The two phase program effectively
introduces the remedial chemicals sodium persulfate, hydrogen peroxide and zero-valent
iron (ZVI) directly into the soil and groundwater using direct push technologies, and
retractable injection points through which the remedial materials were pumped into the
targeted zones. Phase one of the degradation program targeted BTEX compounds via
hydroxyl and sulfate free radicals, the second utilized the decomposition products of the
phase one reactions to effect facultative biological activity. A modified Fenton's
chemistry and persulfate chemistry was integrated at the site, utilizing zero-valent iron as
a catalyst for both reactions. A year after the injection event, the biological stage of the
remedial event is dominating.
The 39 injection events were distributed to the subsurface via alphanumeric points. The
programs were designed to influence an approximate area of 9,225 sq. ft. and over an
eight foot vertical zone. A site map with the treatment areas is included elow.

The mechanisms employed by IET in the injection process utilized compressed air
followed by the remedial liquid introduction. The liquid injection was accomplished via
a double diaphragm pump. As a result of the injection process, the preexisting pore
volume is displaced both laterally and vertically. The transient elevation in groundwater
and the rapid radial movement of those waters often results in an increase in the
concentration of the targeted compounds, _such as BTEX and other aromatic hydrocarbon
- concentrations. The overall effect is an in -situ mixing and homogenization of the
subsurface conditions.
An evaluation of .the analytical data and field parameters from the third sampling event
following the injection event indicates that the remedial program was -successful in
altering the geochemistry at the site and stimulating biological activity. The results from
_. the direct oxidation phase of the remedial program are unknown, however, due to the
length of time between the oxidation event and the first sampling.event as the subsurface
conditions were already reducing. Based on the concentrations seen at the site,
concentrations likely increased during the initial three month following the oxidation
event, as can be seen in monitoring point RW-2, and have begun to decrease with the
ongoing biological mineralization.
An evaluation of the VOC analytical data and field parameters is discussed below:
Data Analysis:
The remedial liquids were injected into 39 points via direct push technologies. Two
intervals between 10 and 18 feet below ground surface (bgs) were used to inject the
liquids into the targeted media affecting a radius of 7710 feet for each point. The targeted
area included 9,225 sq ft. over an 8 ft. vertical zone. Total VOC concentrations
decreased from the baseline sampling event in all monitoring points except for RW-2 and
MW-3. The late October 2009 injections were successful in influencing the
geochemistry within the targeted area, and have as a result, decreased the total
concentration of VOCs present within the contaminant :plume. The concentration of total
VOCs has decreased by 56% site wide in the year following the remedial event. A
discussion,of the injection's impact on each monitoring point follows.
MW-1
Six compounds remain above the - NYSDEC groundwater standards; benzene,
ethylbenzene, isopropylbenzene, n-propylbenzene, .total xylenes, and 1,2,4-
trimethylbenzene. The concentration of benzene has decreased slightly from the baseline
sampling event, but has remained elevated at 130 µg/L, above the standard of 1 µg/L.
The concentration of ethylbenzene has increased in MW-1 from 59 µg/L in October 2009
to 120 µg/L in October 2010. The largest. decrease .in contaminant concentration came
from total xylenes which decreased 85% from 120 µg/L to 16 µg/L.
The geochemical parameters sampled indicate that conditions are ideal for biological
attenuation, even though the concentrations of some compounds, namely benzene and
Iw'

ethylbenzene, are not decreasing significantly at MW-1. Iron is still present in MW-1,
existing mostly in the ferrous oxidation state (Fe+2), indicating that a reducing
environment is present. Sulfate concentrations remain elevated with a concentration of
840 mg/L. The pH remains neutral at 6.81 and the redox potential is negative with a
recorded value of -100 mV in October 2010. The pH has dropped since the first post -
injection value of 7.57 indicating that biological activity is occurring in the vicinity of
MW-1.
The concentration of total VOCs has decreased by 29% in the year since the injection
event. Subsurface conditions are ideal for biological attenuation. It is expected that the
concentration of VOCs, especially those more readily degraded biologically such as
xylene, will decrease. A graph of the VOCs sampled is located below.
MW-1 VOC Analytical Data
180 —
— -- -- —
—*—Benzene
-i-Ethylbenzene
160
-.. _.._ __
Naphthalene
-W—Xylenes, total
140
-- --- --
-i1L.1 7 d-Trimgjhylhnve ne
120
100
n
g 80
CA
60
40
20
0
8/25/2009 10/14/2009 12/3/2009
1/22/2010 3/13/2010 5/2/2010 6/21/2010
8/10/2010 9/29/2010 11/18/2010
Sample Date
The concentration of total VOCs has decreased significantly in MW-2 from 2,136.67
µg/L in October 2009 to 116.21 µg/L in October 2010. Benzene has decreased
drastically from 1,300 µg/L to 27 µg/L in the year following the remedial event, a
reduction of 94.5%. Five compounds, however, remain above the NYSDEC groundwater
standard; benzene, isopropylbenzene, n-propylbenzene, total xylenes, and 1,2,4-
trimethylbenzene. The current concentration of all of these compounds is significantly
less than the baseline sampling results.

Biological attenuation continues to be occurring at MW-2 and geochemical parameters
continue to indicate that ideal conditions exist, however the concentration of electron
acceptors in the vicinity of MW-2 appears to be continuing. to be a limiting factor. The
concentration of sulfate continues to decrease from the first post -remedial sampling event
result of 2,059 mg/L and is currently recorded at 193 mg/L. This concentration will
allow for biological attenuation to continue for another quarter, but should be evaluated at
that time to decrease the need for additional emplacement of materials. Iron
concentrations continue to decrease, however the concentration of ferric iron has
increased during the October 2010 sampling event. The increase in redox potential from
the June 2010 value of -153 mV to the October 2010 value of -91 mV supports that
information. The pH remains neutral at 6.62.
A graph of the VOCs present in MW-2 is located below.
MW-2 VOCs
1400
1200
1000
—
tBenzene
—11—Ethylbenzene
tr-n-Propylbenzene
800
-"FXyle nes, total
—W-1,2,4-Trimethylbenze ne
P 600
400
--
200
0
8/25/2009 10/14/2009 12/3/2009 1/22/2010- 3/13/2U%Pk "2010 6/21/2010 8/10/2010 9/29/2010 11/19/2010
The concentrations of all but one compound are currently below the NYSDEC
groundwater standard. The concentration of MTBE is currently recorded at 11 µg/L,
above the standard of 10 µg/L. The concentration of iron and sulfate remain elevated in
MW-3, indicating that the geochemistry is still conducive to biological attenuation. The
pH remains mostly neutral at 6.25 and the redox potential is reducing at -82 mV.
Additional remedial activities are not needed in the vicinity of MW-3 due to the high
concentration of electron acceptors such as sulfate and the low concentration of VOCs.

UM]
The concentration of total VOCs in the vicinity of MW-4 have decreased by 53.4% since
the baseline sampling event, however most of the compounds sampled remain above their
NYSDEC groundwater standard. The location of monitoring well MW-4 on the
perimeter of the oxidation event may be contributing to the slower rate of biological
attenuation, however the decrease in contaminates such as benzene (reduced 55%) and
total xylenes (reduced 70.5%) indicate that biological activity continues to occur. A
second injection event will most likely be necessary to further reduce these
concentrations to at or below their NYSDEC standards.
Sulfate concentrations have continued to decrease in MW-4 and currently measured at
339 mg/L during the October 2010 sampling event. The concentration of sulfate is
elevated enough to supply enough electron acceptors for at least one more quarterly
sampling event, however, a second injection event is likely to supplement both the sulfate
concentrations and the iron concentrations that have also decreased significantly. The
concentration of total iron is currently measured at 24.4 mg/L with a dissolved iron
concentration of 23 mg/L. This concentration is reduced heavily from the post -remedial
sampling event in February with a value of 137 mg/L. The pH and redox potential
remain ideal for biological attenuation at 6.67 pH units and.406 mV.
A graph of the sampled VOCs in MW-4 is located below.

MWA VOCs
1400
1200
1000
800
600
400
200
nuene
0
8/2S/2009 10/14/2009 12/3/2009 1/22/2010 3/13/2010 5/2/2010 6/21/2010 8/10/2010 9/29/2010 11/18/2010
Sample Date
I '.1`.61
Total VOCs have decreased by 71% in the year following the injection event, however
six compounds remain above their NYSDEC groundwater standards; benzene,
ethylbenzene, isopropylbenzene, n-propylbenzene, total xylenes, and 1,2,4-
trimethylbenzene. Benzene has decreased significantly from 200 µg/L to 17 µg/L in the
year following the injection event, a decrease of 91%. The concentration should continue
to decrease, however the rate of reduction will continue to be retarded due to the low
concentration of electron acceptors present. The concentrations of total xylenes and
1,2,4-trimethylbenzene has decreased significantly through biological attenuation, 76%
and 86%, respectively.
Sulfate concentrations in RW-1 remain the lowest at the site with a current concentration
of 42.1 mg/L. Iron concentrations are also depressed with a current total iron
concentration of 13.7 mg/L. The current concentrations of sulfate and iron will limit the
rate and continuation of biological attenuation in the vicinity of RW-1. The
concentrations will possibly allow for biological attenuation to continue for another
quarter, however the rate of reduction will most likely decrease. The pH and redox
potential remain ideal for attenuation with a pH of 6.81 and a redox potential of -104 mV.
A second injection event should occur in the vicinity of RW-1 and should contain both
sodium persulfate and zero valent iron in 4 to 8 months.
A graph of VOCs in RW-1 is located below.

RW-1 VOCs
600
—4-Benzene
# Ethyl be nze ne
500
_. _ _ _. _
2-Xylenes,total
—F 1,2,4-Trimethylbe nze ne
400
—
n
300
R
e
200
100
0
8/25/2009 10/14/2009 12/3/2009
1/22/2010 3/13/2010 5/2/2010
6/21/2010 8/10/2010 9/29/2010 11/18/2010
- Sample Date
I.i+.+ba
Total VOC concentrations have remained above the baseline concentration of 320 µg/L
during the October 2009 sampling event, however the total VOC concentration has
decreased by 74% from the February 2010 post -remedial sampling event. Most
compounds sampled were above their NYSDEC groundwater standard. Significant
decreases from the February 2010 sampling event have occurred, namely in the
concentrations of total xylenes and 1,2,4-trimethylbenzene which have decreased by 87%
and 71 %, respectively. Benzene and ethylbenzene concentrations have been reduced by
at least 50%.
Biological attenuation may begin to slow in RW-2 based on the sulfate and iron
concentrations, however these concentrations were depressed during the June 2010
sampling event and the concentration of total VOCs decreased 59% over those four
months. Based on that information, biological attenuation should occur in the vicinity of
RW-2 during the next quarter of groundwater sampling. The concentration of sulfate is
currently at 171 mg/L. The concentration of total and dissolved iron is also low, however
the concentration of ferric iron remains elevated as compared to other monitoring wells
which will continue to provide electron acceptors for biological activity. The pH is
currently measured at 6.68 and the redox potential is reducing at -112 mV. Geochemical
parameters indicate that the subsurface is still ideal for biological attenuation.

A graph of the current VOC concentrations is located below.
RW-2 VOCs
1600
—*—Benzene
—Ethylbenzene
1400
Xyle nes, total
-*0-1,2,4-Tri methyl ben ze ne
-
-4—Naphthalene
1200
1000
800
E
600
400
200
0
8/25/2009 10/14/2009 12/3/2009
1/22/2010 3/13/2010 5/2/2010
6/21/2010 8/10/2010 9/29/2010 11/18/2010
Sample Date
RW-3
Total VOC concentrations have decreased 64% in RW-3 since the injection event with
significant decreases in benzene and 1,2,4-trimethylbenzene concentrations seen. Seven
compounds remain above their NYSDEC groundwater standard, however most
compounds have continued to decrease in concentration.
Biological attenuation may begin to slow in RW-3 based on the sulfate concentration,
which has continued to decrease during the last quarterly sampling event. The
concentration of iron, however, has increased since the June 2010 sampling event with a
current concentration of 37.6 mg/L. The pH and redox potential remain ideal for
biological attenuation at 6.56 pH units and -104 mV. The current concentration of sulfate
is too low to sustain long-term biological attenuation but should allow for another quarter
of biological activity, when coupled with the field parameters and the concentration of
iron.
A graph of the VOCs present in RW-3 is located below.

RW-3 VOCs
350
300
250
200
Q 150
100
50
8/25/2009 10/14/2009 12/3/2009 1/22/2010 3/13/2JAWe D;4J/2010 6/21/2010 8/10/2010 9/29/2010 11/18/2010
Conclusions and Recommendations:
The concentrations of VOCs across the site have averaged a significant decrease in
concentration, with total VOC concentrations decreasing by 56% across the site, as seen
in the graph below. Biological attenuation appears to be occurring at a fast rate in many
of the monitoring wells, with the exception of MW-3 that currently has a total VOC
concentration of 12.8 µg/L.

DOCUMENTS ASSOCIATED
WITH
THE ORIGINAL PERMIT
APPLICATION
(ISSUED OCTOBER 21, 2011)

APPENDIX 2:
MSDS DATA SHEETS

MATERIAL SAFETY DATA SHEET
Hydrogen Peroxide (40 to 60%)
MSDS Ref. No.: 7722-84-14
*NC Date Approved: 04/27/2006
Revision No.: 10
This document has been prepared to meet the requirements of the U.S. OSHA Hazard Communication
Standard, 29 CFR 1910.1200; the Canada's Workplace Hazardous Materials Information System (WHMIS)
and, the EC Directive, 2001/58/EC.
1. PRODUCT AND COMPANY IDENTIFICATION
PRODUCT NAME: Hydrogen Peroxide (40 to 60%)
ALTERNATE PRODUCT NAME(S): Durox® Reg. & LR 50%, Oxypure® 50%, Hi Ox-TG, Hi Ox-SG,
Semiconductor Reg & Seg 50%, Standard 50%, Technical 50%,
Chlorate Grade 50%, Super DO 50%, OHP 50%, UP-HTP 50%,
H-IP 50%, HT? 59%
GENERAL USE: Durox® 50% Reg. and LR - meets the Food Chemical Codex
requirements for aseptic packaging and other food related
applications.
Oxypure® 50%, Hi Ox-TG and Hi Ox-SG - certified by NSF to meet
NSF/ANSI Standard 60 requirements for drinking water treatment.
Semiconductor Reg. & Seg. 50% - conforms to ACS and Semi
Specs., for wafer etching and cleaning, and applications requiring
low residues.
Standard 50% - most suitable for industrial bleaching, processing,
pollution abatement and general oxidation reactions.
Technical 50% - essentially free of inorganic metals, suitable for
chemical synthesis.
Chlorate Grade 50% - specially formulated for use in chlorate
manufacture or processing.
Super DO 50% - meets US Pharmacopoeia specifications for 3%
topical solutions when diluted with proper quality water. While
manufactured to the USP standards or purity and to FMC's
demanding ISO 9002 quality standards, FMC does not claim that its
Hydrogen Peroxide is manufactured in accordance with all
pharmaceutical cGMP conditions.
OHP 50% - specially formulated for OHP process, advanced
oxidation, and activated peroxide applications.
UP-HTP 50% - unstabilized product for semi -conductor applications.
Page 1 of 11

Hydrogen Peroxide (40 to 60%). (7722-84-1-4)
MANUFACTURER
FMC CORPORATION
FMC Peroxygens
1735 Market Street
Philadelphia, PA 19103 '
[phone] (General Information)
FMC of Canada Ltd.
FMC Peroxygens
PG Pulp Mill Road
Prince George, BC V2N2S6
[phone]. (General Information)
Date: 04/27/2006
HTP 50% and HTP 59% - specially formulated for aerospace or
other special applications.
SynergOxTM - combination of a proprietary catalyst and 50%
hydrogen peroxide, at the point of use, for environmental
applications.
EMERGENCY TELEPHONE NUMBERS
[phone] (Plant: Pasadena, TX, US - Call Collect)
[phone] (Plant: Prince George, BC, Canada - Call
Collect)
(303) 59579048 (Medical - U.S. - Call Collect)
For leak, fire, spill, or accident emergencies, call:
[phone] (CHEMTREC -U.S.A.)
[phone] (CANUTEC -Canada)
2. HAZARDS IDENTIFICATION
EMERGENCY OVERVIEW:
• Clear, colorless, odorless liquid
• Oxidizer.
• Contact with combustibles may cause fire.
• Decomposes yielding oxygen that supports combustion of organic matters and can cause overpressure
if confined.
• Corrosive to eyes, nose, throat, lungs and gastrointestinal tract.
POTENTIAL HEALTH EFFECTS: Corrosive to eyes, skin, nose, throat and lungs. May
cause irreversible tissue damage to the eyes including blindness.
3. COMPOSITION / INFORMATION ON INGREDIENTS
Chemical Name
CAS#
Wt.%
EC No.
EC Class
Hydrogen Peroxide
7722-84-1
46 - 60
231-765-0
C; R20/22-34, O; R8
Water
7732-18-5
40 - 60
231-791-2
Not classified
Page 2 of 11

Hydrogen Peroxide (40 to 60%) (7722-84-1-4) Date: 04/27/2006
4. FIRST AID MEASURES
EYES: Immediately flush with water for at least 15 minutes, lifting the upper and lower eyelids
intermittently. See a medical doctor or ophthalmologist immediately.
SHIN: Immediately flush with plenty of water while removing contaminated clothing and/or shoes, and
thoroughly wash with soap and water. See a medical doctor immediately.
INGESTION: Rinse mouth with water. Dilute by giving 1 or 2 glasses of water. Do not induce
vomiting. Never give anything_bymouth to an unconscious person. See a medical doctor immediately.
INHALATION: Remove to fresh air. If breathing difficulty or discomfort occurs and persists,
contact a medical doctor.
NOTES TO MEDICAL DOCTOR: Hydrogen peroxide at these concentrations is a strong
oxidant. Direct contact with the eye is likely to cause corneal damage especially if not washed immediately.
Careful ophthalmologic evaluation is recommended and the possibility of local corticosteroid therapy
should be considered. Because of the likelihood of corrosive effects on the gastrointestinal tract after
ingestion, and the unlikelihood of systemic effects, attempts at evacuating the stomach via emesis induction
or gastric lavage should be avoided. There is a remote possibility, however, that a nasogastric or orogastric
tube may be required for the reduction of severe distension due to gas formation.
5. FIRE FIGHTING MEASURES
EXTINGUISHING MEDIA: Flood with water.
FIRE/ EXPLOSION HAZARDS: Product is non-combustible. On decomposition releases
oxygen which may intensify fire.
FIRE FIGHTING PROCEDURES: Any tank or container surrounded by fire should be
flooded with water for cooling. Wear full protective clothing and self-contained breathing apparatus.
FLAMMABLE LIMITS: Non-combustible
SENSITIVITY TO IMPACT: No data available
SENSITIVITY TO STATIC DISCHARGE: No data available
Page 3 of 11

Hydrogen Peroxide (40 to 60%) (7722-84-14)
6. ACCIDENTAL RELEASE MEASURES
Date: 04/27/2006
RELEASE NOTES: Dilute with a large volume of water and hold in a pond or diked area until
hydrogen peroxide decomposes. Hydrogen peroxide may be decomposed by adding sodium metabisulfite
or -sodium sulfite after diluting to about 5%. Dispose according to methods outlined for waste disposal.
Combustible materials exposed to hydrogen peroxide should be immediately submerged in or rinsed with
large amounts of water to ensure that all hydrogen peroxide is removed. Residual hydrogen peroxide that is
allowed to dry (upon evaporation hydrogen peroxide can concentrate) on organic materials such as paper,
fabrics, cotton, leather, wood or other combustibles can cause the material to ignite and result in -a fire.
7. HANDLING AND STORAGE
0
HANDLING: Wear chemical splash -type monogoggles and full -face -shield, impervious clothing,
such as rubber, PVC, etc., and rubber or neoprene gloves and shoes. Avoid cotton, wool and leather. Avoid
excessive heat and contamination. Contamination may cause decomposition and generation of oxygen gas
which could result in high pressures and possible container rupture. Hydrogen peroxide should be stored
only in vented containers and transferred only in a. prescribed manner (see FMC Technical Bulletins).
Never return unused hydrogen peroxide to original container, empty drums should be triple rinsed with
water before discarding. Utensils used for handling hydrogen peroxide should only be made. of glass,
stainless steel, aluminum or plastic.
STORAGE: Store drums in cool areas out of direct sunlight and away from combustibles. For bulk
storage refer to FMC Technical Bulletins.
COMMENTS: VENTILATION: Provide mechanical general and/or local exhaust ventilation to
prevent release of vapor or mist into the work environment.
8. EXPOSURE- CONTROLS / PERSONAL PROTECTION
EXPOSURE LIMITS
Chemical Name
ACGIH
OSHA
Supplier
Hydrogen Peroxide
1 ppm (TWA)
1 ppm (PEL)
ENGINEERING CONTROLS: Ventilation should be provided to minimize the release of
hydrogen peroxide vapors and mists into the work environment. Spills should be minimized or confined
immediately to prevent release into the work area. Remove, contaminated clothing immediately and wash
before reuse.
Page 4 of 11

Hydrogen Peroxide (40 to 60%) (7722-84-1-4) Date: . 04/27/2006
PERSONAL PROTECTIVE EQUIPMENT
EYES AND FACE: Use chemical splash -type monogoggles and a full -face shield made
of polycarbonate, acetate, polycarbonate/acetate, PETG or thermoplastic.
RESPIRATORY: If concentrations in excess of 10 ppm are expected, use NIOSH/DHHS
approved self-contained breathing apparatus (SCBA), or other approved atmospheric -supplied
respirator (ASR) equipment (e.g., a full -face airline respirator (ALR)). DO NOT use any form of
air -purifying respirator (APR) or filtering facepiece (AKA dust mask), especially those containing
oxidizable sorbants such as activated carbon.
PROTECTIVE CLOTHING: For body protection wear impervious clothing such as
an approved splash protective suit made of SBR Rubber, PVC (PVC Outershell w/Polyester
Substrate), Gore -Tex (Polyester trilaminate w/Gore-Tex), or a specialized HAZMAT Splash or
Protective Suite (Level A, B, or C). For foot protection, wear approved boots made of NBR, PVC,
Polyurethane, or neoprene. Overboots made of Latex or PVC, as well as firefighter boots or
specialized HAZMAT boots are also permitted. DO NOT wear any form of boot or overboots
made of nylon or nylon blends. DO NOT use cotton, wool or leather, as these materials react
RAPIDLY with higher concentrations of hydrogen peroxide. Completely submerge hydrogen
peroxide contaminated clothing or other materials in water prior to drying. Residual hydrogen
peroxide, if allowed to dry on materials such as paper, fabrics, cotton, leather, wood or other
combustibles can cause the material to ignite and result in.a fire.
GLOVES: For hand protection, wear approved gloves made of nitrile, PVC, or neoprene.
DO NOT use cotton, wool or leather for these materials react RAPIDLY with higher
concentrations of hydrogen peroxide. Thoroughly rinse the outside of gloves with water prior to
removal. Inspect regularly for leaks.
9. PHYSICAL AND CHEMICAL PROPERTIES
ODOR:
Odorless
APPEARANCE:
Clear, colorless liquid
AUTOIGNITION TEMPERATURE:
Non-combustible
BOILING POINT:
110°C (229°F) (40%); 114°C (237°F) (50%)
COEFFICIENT OF OIL / WATER:
Not available
DENSITY / WEIGHT PER VOLUME:
Not available
EVAPORATION RATE:
Above 1 (Butyl Acetate = 1)
FLASH POINT:
Non-combustible
FREEZING POINT:
-41.4°C (-42.5°F) (40%); -52°C (-62°F) (50%)
ODOR THRESHOLD:
Not available
OXIDIZING PROPERTIES:
Strong oxidizer
PERCENT VOLATILE:
100%
PH:
(as is) < / = 3.0
SOLUBILITY IN WATER:
(in HZO % by wt) 100%
Page 5of11

Hydrogen Peroxide (40 to 60%) (7722-84-1-4) Date: 04/27/2006
SPECIFIC GRAVITY: (H20 = 1) 1.15 @ 20°C/4°C (40%); 1.19 @ 20°C/40C
(50%)
VAPOR DENSITY: Not available (Air = 1)
VAPOR PRESSURE: 22 mmHg ,@ 30°C (40%); 18.3 mmHg @ 30°C (50%)
COMMENTS:
pH (1% solution) : 5.0 - 6.0
10. STABILITY AND REACTIVITY
CONDITIONS TO AVOID: Excessive heat or contamination could cause
product to become unstable.
STABILITY: Stable (heat and contamination could cause
decomposition)
POLYMERIZATION: Will not occur
INCOMPATIBLE MATERIALS: Reducing agents, wood, paper and other
combustibles, iron and other heavy metals, copper
alloys and caustic.
HAZARDOUS DECOMPOSITION PRODUCTS: Oxygen which supports combustion.
COMMENTS: Materials to Avoid: Dirt, organics, cyanides and combustibles such as wood, paper,
oils, etc.
11. TOXICOLOGICAL INFORMATION
EYE EFFECTS: 70% hydrogen peroxide: Severe irritant (corrosive) (rabbit) [FMC Study Number:
ICG/T-79.0271
SKIN EFFECTS: 50% hydrogen peroxide: Severe irritant (corrosive) (rabbit) [FMC Study
Number: I89-1079]
DERMAL LD50: 70% hydrogen peroxide: > 6.5 g/kg (rabbit) [FMC Study Number: ICG/T-79.027]
ORAL LD50: 50% hydrogen peroxide: > 225 mg/kg (rat) [FMC Study Number: I86-914]
INHALATION LC50: 50% hydrogen peroxide: > 0.17 mg/1(rat) [FMC Study Number: I89-1080]
TARGET ORGANS: Eye, skin, nose, throat, lungs
Page 6 of l l .

Hydrogen Peroxide (40 to 60%) (7722-84-1-4) Date: 04/27/2006
ACUTE EFFECTS FROM OVEREXPOSURE: Severe irritant/corrosive to eyes, skin
and gastrointestinal tract. May cause irreversible tissue damage to the eyes including blindness. Inhalation
of mist or vapors may be severely irritating to nose, throat and lungs.
CHRONIC EFFECTS FROM OVEREXPOSURE: The International Agency for
Research on Cancer (IARC) has concluded that there is inadequate evidence for carcinogenicity of
hydrogen peroxide in humans, but limited evidence in experimental animals (Group 3 - not classifiable as
to its carcinogenicity to humans). The American Conference of Governmental Industrial Hygienists
(ACGIH) has concluded that hydrogen peroxide is a 'Confirmed Animal Carcinogen with Unknown
Relevance to Humans' (A3).
CARCINOGENICITY:
Chemical Name
IARC
NTP
OSHA
Other
Hydrogen Peroxide
Not listed
Not listed
Not listed
(ACGIH) Listed (A3,
Animal Carcinogen)
12. ECOLOGICAL INFORMATION
ECOTOXICOLOGICAL INFORMATION: Channel catfish 96-hour LC50 = 37.4 mg/L
Fathead minnow 96-hour LC50 = 16.4 mg/L
Daphnia magna 24-hour EC5o = 7.7 mg/L
Daphnia pulex 48-hour LC5o = 2.4 mg/L
Freshwater snail 96-hour LC50 = 17.7 mg/L
For more information refer to ECETOC "Joint Assessment of Commodity Chemicals No. 22, Hydrogen
Peroxide." ISSN-0773-6339, January 1993
CHEMICAL FATE INFORMATION: Hydrogen peroxide in the aquatic environment is
subject to various reduction or oxidation processes and decomposes into water and oxygen. Hydrogen
peroxide half-life in freshwater ranged from 8 hours to 20 days, in air from 10-20 brs. and in soils from
minutes to hours depending upon microbiological activity and metal contaminants.
13. DISPOSAL CONSIDERATIONS
DISPOSAL METHOD: An acceptable method of disposal is to dilute with a large amount of
water and allow the hydrogen peroxide to decompose followed by discharge into a suitable treatment
system in accordance with all regulatory agencies. The appropriate regulatory agencies should be
contacted prior to disposal.
14, TRANSPORT INFORMATION
U.S. DEPARTMENT OF TRANSPORTATION (DOT)
Page 7 of 11

Hydrogen Peroxide (40 to 60%) (7722-841-4)
Date: 04/27/2006
PROPER SHIPPING NAME_ :
Hydrogen peroxide, aqueous solutions with
more than 40% but not more than 60%
hydrogen peroxide.
PRIMARY HAZARD CLASS / DIVISION:
5.1 (Oxidizer)
UN/NA NUMBER:
UN 2014
PACKING GROUP:
II
LABEL($):
Oxidizer, Corrosive
PLACARD.(S):
5.1 (Oxidizer)
ADDITIONAL INFORMATION:
DOT Marking: Hydrogen Peroxide,
aqueous solution with more than 40%, but
not more than 60% Hydrogen_ Peroxide, UN
2014
Hazardous Substance/RQ: Not applicable
49 STCC Number: 4918775
DOT Spec: stainless steel/high purity
aluminum cargo tanks and rail cars. UN
Spec: HDPE drums. Contact FMC for
specific details.
INTERNATIONAL MARITIME DANGEROUS GOODS (IMDG)
PROPER SHIPPING NAME:
Hydrogen peroxide, aqueous solutions with
not less than 20%, but not more than 60%
hydrogen peroxide.
INTERNATIONAL CIVIL AVIATION ORGANIZATION (ICAO) /
INTERNATIONAL AIR TRANSPORT ASSOCIATION (IATA)
PROPER SHIPPING NAME: Hydrogen peroxide (40 - 60%) is forbidden
on Passenger and Cargo Aircraft, as well as
Cargo Only Aircraft,
OTHER INFORMATION:
Protect from physical damage. Keep drums in upright position. Drums should not be stacked in transit. Do
not store drum on wooden pallets.
15. REGULATORY INFORMATION
UNITED STATES
SARA TITLE III (SUPERFUND AMENDMENTS AND REAUTHORIZATION ACT)
SECTION.302 EXTREMELY HAZARDOUS SUBSTANCES (40 CFR 355, APPENDIX A):
Page 8 of 11

Hydrogen Peroxide (40 to 60%) (7722-84-1-4)
Date: 04/27/2006
Hydrogen Peroxide > 52%, RQ: 10001bs. Planning Threshold: 10,000 lbs.
SECTION 311 HAZARD CATEGORIES (40 CFR 370):
Fire Hazard, Immediate (Acute) Health Hazard
SECTION 312 THRESHOLD PLANNING QUANTITY (40 CFR 370):
The Threshold Planning Quantity (TPO) for this product, if treated as a mixture, is 10,000 lbs;
however, this product contains the following ingredients with a TPQ of less than 10,000 lbs.:
None, (cone. <52%) (hydrogen peroxide, 1000 lbs. when cone is >52%)
SECTION 313 REPORTABLE INGREDIENTS (40 CFR 372):
Not listed
CERCLA (COMPREHENSIVE_ ENVIRONMENTAL RESPONSE COMPENSATION AND
LIABILITY ACT)
CERCLA DESIGNATION & REPORTABLE QUANTITIES (RQ) (40 CFR 302.4):
Unlisted (Hydrogen Peroxide); RQ = 100 lbs.; Ignitability, Corrosivity
TSCA (TOXIC SUBSTANCE CONTROL ACT)
TSCA INVENTORY STATUS (40 CFR 710):
Listed
RESOURCE CONSERVATION AND RECOVERY ACT (RCRA)
RCRA IDENTIFICATION OF HAZARDOUS WASTE (40 CFR 261):
Waste Number: D001, D002
CANADA
WHMIS (WORKPLACE HAZARDOUS MATERIALS INFORMATION SYSTEM):
Product Identification Number: 2014
Hazard Classification / Division: Class C (Oxidizer), Class D, Div. 2, Subdiv. B (Toxic), Class E
(Corrosive)
Ingredient Disclosure List: Listed
INTERNATIONAL LISTINGS
Hydrogen peroxide:
- China: Listed
Japan (ENCS): (1)-419
Korea: KE-20204
Philippines (PICCS): Listed
HAZARD, RISK AND SAFETY PHRASE DESCRIPTIONS:
Hydrogen Peroxide, (Index #008-003-00-9):
EC Symbols: C (Corrosive)
- O (Oxidizer)
Page 9of11
l

Hydrogen Peroxide (40 to 60%) (7722-84-1-4)
Date: 04/27/2006
EC Risk Phrases: R20/22
(Harmful by inhalation and if swallowed.)
' R34
(Causes burns)
R8
(Contact with combustible material may cause fire)
EC Safety Phrases: S l/2
(Keep locked up and out of reach of children.)
S3
(Keep in a cool place.)
-' S17
(Keep away from combustible material.)
S26
(In case of contact with eyes, rinse immediately with plenty of
water and seek medical advice)
S28
(After contact with skin, wash immediately with plenty of water
and soap.)
S36/37/39 (Wear suitable protective clothing, gloves and eye/face
protection.)
S45
(In case of accident or if you feel unwell, seek medical advice
i�
immediately - show the label where possible.)
16.OTHER INFORMATION
HMIS
Health
3
Flammability
0
Physical Hazard
1
Personal Protection (PPE)
H
Protection = H (Safety goggles, gloves, apron, the use of a supplied air or SCBA respirator is required
in lieu of a vapor cartridge respirator)
HMIS = Hazardous Materials Identification System
Degree of Hazard Code:
4 = Severe
3 = Serious
2 = Moderate
1 = Slight
0 = Minimal
NFPA
Health
3
Flammability
0
Reactivity
1
—Special
OX
SPECIAL = OX (Oxidizer)
NFPA = National Fire Protection Association
Degree of Hazard Code:
Page 10 of 11

Hydrogen Peroxide (40 to 60%) (7722-84-1-4) Date: 04/27/2006
4 = Extreme
3 = High
2 = Moderate
1 = Slight
0 = Insignificant
REVISION SUMMARY:
This MSDS replaces Revision #9, dated April 05, 2005.
Changes in information are as follows:
Section 1 (Product and Company Identification) -
Section 16 (Other Information)
Durox, Oxypure, Super D, SynergOx and FMC Logo - FMC Trademarks
© 2006 FMC Corporation. All Rights Reserved.
NOTE: NFPA Reactivity is 3 - when greater than 52%
FMC Corporation believes that the information and recommendations contained herein (including data and
statements) are accurate as of the date hereof. NO WARRANTY OF FITNESS FOR ANY PARTICULAR
PURPOSE, WARRANTY OF MERCHANTABILITY, OR ANY OTHER WARRANTY, EXPRESSED
OR IMPLIED, IS MADE CONCERNING THE INFORMATION PROVIDED HEREIN. The information
provided herein relates only to the specific product designated and may not be applicable where such
product is used in combination with any other materials or in any process. It is a violation of Federal law to
use this product in a manner inconsistent with its labeling. Further, since the conditions and methods of use
are beyond the control of FMC Corporation, FMC Corporation expressly disclaims any and all liability as
to any results obtained or arising from any use of the product or reliance on such information.
Page 11 of 11

MATERIAL SAFETY DATA SHEET
KloziirTM
MSDS Ref. No.: 7775-27-1-12
Date Approved: 02/22/2005 FMCRevision No.: 1
This document has been prepared to meet the requirements of the U.S. OSHA Hazard Communication
Standard, 29 CFR 1910.1200; the Canada's Workplace Hazardous Materials Information System (WHMIS)
and, the EC Directive, 2001/58/EC.
1. PRODUCT AND COMPANY IDENTIFICATION
PRODUCT NAME:
SYNONYMS:
GENERAL USE:
MANUFACTURER
FMC CORPORATION
Active Oxidants Division
1735 Market Street
Philadelphia, PA 19103
[phone] (General Information)
KloziirTM
Sodium Persulfate, Sodium Peroxydisulfate; Disodium
Peroxydisulfate
In situ and ex situ chemical oxidation of contaminants and
compounds of concern for environmental remediation applications.
EMERGENCY TELEPHONE NUMBERS
[phone] (CHEMTREC - U.S.)
[phone] (Medical - Call Collect)
2. HAZARDS IDENTIFICATION
EMERGENCY OVERVIEW:
• White, odorless, crystals
• Oxidizer.
• Decomposes in storage under conditions of moisture (water/water vapor) and/or excessive heat causing
release of oxides of sulfur and oxygen that supports combustion. Decomposition could form a high
temperature melt. See Section 10 ("Stability and Reactivity").
POTENTIAL HEALTH EFFECTS: Airborne persulfate dust may be irritating to eyes,
nose, lungs, throat and skin upon contact. Exposure to high levels of persulfate dust may cause difficulty in
breathing in sensitive persons.
Page 1 of 9

I
Kloz&TM (7775-27-1-12)
Date: 02/22/2005
3. COMPOSITION / INFORMATION ON INGREDIENTS
Chemical Name
CAS#
Wt.%
EC No.
EC Class
Sodium Persulfate
7775-27-1
>99
231-892-1
Not classified as hazardous
4. FIRST AID MEASURES
EYES: Flush with plenty of water. Get medical attention if irritation occurs and persists.
SKIN: Wash with plenty of soap and water. Get medical attention if irritation occurs and persists.
INGESTION: Rinse mouth with water. Dilute by giving 1 or 2 glasses of water. Do not induce
vomiting. Never give anything by mouth to an unconscious person. See a medical doctor immediately.
- INHALATION: Remove to fresh air. If breathing difficulty or discomfort occurs and persists,
contact a medical doctor.
NOTES TO MEDICAL DOCTOR: This product has low oral toxicity and is not irritating to
the eyes and skin. Flooding of exposed areas with water is suggested, but gastric lavage or emesis
induction for ingestions must consider possible aggravation of esophageal injury and the expected absence
of system effects. Treatment is controlled removal:of exposure followed by symptomatic and supportive
care.
5. FIRE FIGHTING MEASURES.
EXTINGUISHING MEDIA: Deluge with water.
FIRE / EXPLOSION HAZARDS: Product is non-combustible. On decomposition releases
oxygen which may intensify fire. Presence of water accelerates decomposition.
FIRE FIGHTING PROCEDURES: Do not use carbon dioxide or other gas filled fire
extinguishers; they will have no effect on decomposing persulfates. Wear full protective clothing and self-
contained breathing apparatus.
FLAMMABLE LIMITS: Non-combustible
SENSITIVITY TO IMPACT: No data available
Page 2 of 9

Klozflfm (7775-27-1-12)
SENSITIVITY TO STATIC DISCHARGE: Not available
6. ACCIDENTAL RELEASE MEASURES
Date: 02/22/2005
RELEASE NOTES: Spilled material should be collected and put in approved DOT container and
isolated for disposal. Isolated material should be monitored for signs of decomposition (fuming/smoking).
If spilled material.is wet, dissolve with large quantity of water and dispose as a hazardous waste. All
disposals should be carried out according to regulatory agencies procedures.
7. HANDLING AND STORAGE
HANDLING: Use adequate ventilation when transferring product from bags or drums. Wear
respiratory protection if ventilation is inadequate or riot available. Use eye and skin protection. Use clean
plastic or stainless steel scoops only.
STORAGE: Store (unopened) in a cool, clean, dry place away from point sources of heat, e.g.
radiant heaters or. steam pipes. Use first in, first out storage system. Avoid contamination of opened
product. In case of fire or decomposition (fuming/smoking) deluge with plenty of water to control
decomposition. For storage, refer to NFPA Bulletin 430 on storage of liquid and.solid oxidizing materials.
COMMENTS: VENTILATION: Provide mechanical general and/or local exhaust ventilation to
prevent release of dust into work environment. Spills should be collected into suitable containers to prevent
dispersion into the air.
S. EXPOSURE CONTROLS / PERSONAL PROTECTION
EXPOSURE LIMITS .
Chemical Name
ACGIH
OSHA
Supplier
Sodium Persulfate
0.1 mg/m3 (TWA)
ENGINEERING CONTROLS: Provide mechanical local general room ventilation to
prevent release of dust into the work environment. Remove contaminated clothing immediately and wash
before reuse.
PERSONAL PROTECTIVE EQUIPMENT
EYES AND FACE: Use cup type chemical goggles. Full face shield may be used.
RESPIRATORY: Use approved dust respirator when airborne dust is expected.
Page 3 of 9

Klozijim (7775-27-1-12) Date: 02/22/2005
PROTECTIVE CLOTHING: Normal work clothes. Rubber or neoprene footwear.
GLOVES: Rubber or neoprene gloves. Thoroughly wash the outside of gloves with soap and
water prior to removal. Inspect regularly for leaks.
9. PHYSICAL AND CHEMICAL PROPERTIES
ODOR:
None
APPEARANCE:
White crystals
AUTOIGNITION TEMPERATURE:
Not applicable. No evidence of combustion up to 800°C.
Decomposition will occur upon heating.
BOILING POINT:
Not applicable
COEFFICIENT OF OIL / WATER:
Not applicable
DENSITY / WEIGHT PER VOLUME:
Not available
EVAPORATION RATE:
Not applicable (Butyl Acetate = 1)
FLASH POINT:
Non-combustible
MELTING POINT:
Decomposes
ODOR THRESHOLD:
Not applicable
OXIDIZING PROPERTIES:
Oxidizer
PERCENT VOLATILE:
Not applicable
pH:
typically 5.0 - 7.0 @ 25 °C (1% solution)
SOLUBILITY IN WATER:
73 % @ 25 °C (by wt.)
SPECIFIC GRAVITY:
2.6 (H20=1)
VAPOR DENSITY:
Not applicable (Air = 1)
VAPOR PRESSURE:
Not applicable
10 STABILITY AND REACTIVITY
CONDITIONS TO AVOID:
STABILITY:
POLYMERIZATION:
INCOMPATIBLE MATERIALS:
Heat, moisture and contamination.
Stable (becomes unstable in presence of heat,
moisture and/or contamination).
Will not occur
Acids, alkalis, halides (fluorides, chlorides,
bromides and iodides); combustible materials, most
metals and heavy metals, oxidizable materials,
other oxidizers, reducing agents, cleaners, and
organic or carbon containing compounds. Contact
Page 4 of 9

KloziirTM (7775-27-1-12)
i_
Date: 02/22/2005
with incompatible materials can result in a material
decomposition or other uncontrolled reactions.
HAZARDOUS DECOMPOSITION PRODUCTS: Oxygen that supports combustion and oxides of
sulfur.
COMMENTS: PRECAUTIONARY STATEMENT: Pumping and transport of Kloziir persulfate
requires appropriate precautions and design considerations for pressure and thermal relief.
Decomposing persulfates will evolve large volumes of gas and/or vapor, can accelerate exponentially with
heat generation, and create significant and hazardous pressures if contained and not properly controlled or
mitigated.
Use with alcohols in the presence of water has been demonstrated to generate conditions that require
rigorous adherence to process safety methods and standards to prevent escalation to an uncontrolled
reaction.
11. TOXICOLOGICAL INFORMATION
EYE EFFECTS: Non -irritating (rabbit) [FMC Study Number: ICG/T-79.029]
SKIN EFFECTS: Non -irritating (rabbit) [FMC Study Number: ICG/T-79.0291
DERMAL LD50: > 10 g/kg [FMC Study Number: ICG/T-79.0291
ORAL LD50: 895 mg/kg (rat) [FMC Study Number: ICG/T-79.029]'
INHALATION LC50: 5.1 mg/1(rat) [FMC 195-2017]
SENSITIZATION: May be sensitizing to allergic persons. [FMC Study Number: ICG/T-79.0291
TARGET ORGANS: Eyes, skin, respiratory passages
ACUTE EFFECTS FROM OVEREXPOSURE: Dust may be harmful and irritating.
May be harmful if swallowed.
CHRONIC EFFECTS FROM OVEREXPOSURE: Sensitive persons may develop
dermatitis and asthma [Respiration .3 8:144, 1979]. Groups of male and female rats were fed 0, 300 or 3000
ppm sodium persulfate in the diet for 13 weeks, followed by 5000 ppm for 5 weeks. Microscopic
examination of tissues revealed some injury to the gastrointestinal tract at the high dose (3000 ppm) only.
This effect is not unexpected for an oxidizer at high concentrations. [Ref. FMC I90-1151, Toxicologist
1:149, 1981].
Page 5 of 9

KloziirTM (7775-27-1-12)
CARCINOGENICITY:
j NTP: Not listed
IARC: Not listed
OSHA: Not listed
OTHER: ACGIH: Not listed.
12. ECOLOGICAL INFORMATION
ECOTOXICOLOGICAL INFORMATION:
Bluegill sunfish, 96-hour LC50 = 771 mg/L [FMC Study.I92-1250]
Rainbow trout, 967hour LCSo =163 mg/L [FMC Study I92-12511
Daphnia, 48-hour LC50 = 133 mg/L [FMC Study I92-12521
Grass shrimp, 96-hour LC50 = 519 mg/L [FMC Study 192-1253]
Date: 02/22/2005
CHEMICAL FATE INFORMATION: Biodegradability does not apply to inorganic
substances.
13. DISPOSAL CONSIDERATIONS
DISPOSAL METHOD: Dispose as a hazardous waste in accordance with local, state and federal
regulatory agencies.
14. TRANSPORT INFORMATION
U.S. DEPARTMENT OF TRANSPORTATION (DOT)
PROPER SHIPPING NAME:
PRIMARY HAZARD CLASS / DIVISION:
UN/NA NUMBER:
PACKING GROUP:
LABEL(S):
PLACARD(S):
MARKING(S):
ADDITIONAL INFORMATION:
Sodium Persulfate
5.1 (Oxidizer)
UN 1505
III
5.1 (Oxidizer)
5.1 (Oxidizer)
Sodium Persulfate, UN 1505
Hazardous Substance/RQ: Not applicable
Page 6 of 9

j KlozurTM (7775-27-1-12)
Date: 02/22/2005
49 STCC Number: 4918733
_ This material is shipped in 225 lb. fiber
drums, 55 lb. poly bags and 1000 - 2200 lb.
IBC's (supersacks).
'I
INTERNATIONAL MARITIME DANGEROUS GOODS PIRG)
PROPER SHIPPING NAME: Sodium Persulfate
INTERNATIONAL CIVIL AVIATION ORGANIZATION (ICAO) /
INTERNATIONAL AIR TRANSPORT ASSOCIATION (IATA)
PROPER SHIPPING NAME:
Sodium Persulfate
OTHER INFORMATION:
Protect from physical damage. Do not store near acids, moisture or heat.
15. REGULATORY INFORMATION
UNITED STATES
SARA TITLE III (SUPERFUND AMENDMENTS AND REAUTHORIZATION ACT)
SECTION 302 EXTREMELY HAZARDOUS SUBSTANCES (40 CFR 355, APPENDIX A):
Not applicable
SECTION 311 HAZARD CATEGORIES (40 CFR 370):
Fire Hazard, Immediate (Acute) Health Hazard
{ SECTION 312 THRESHOLD PLANNING QUANTITY (40 CFR 370):
- The Threshold Planning Quantity (TPQ) for this product, if treated as a mixture, is 10,000 lbs;
however, this product contains the following ingredients with a TPQ of less than 10,000 lbs.:
j None
SECTION 313 REPORTABLE INGREDIENTS (40 CFR 372):
Not listed
CERCLA (COMPREHENSIVE ENVIRONMENTAL RESPONSE COMPENSATION AND
LIABILITY ACT)
CERCLA DESIGNATION & REPORTABLE QUANTITIES (RQ) (40 CFR 302.4):
Unlisted, RQ = 100 lbs., Ignitability
i;
i
- TSCA (TOXIC SUBSTANCE CONTROL ACT)
TSCA INVENTORY STATUS (40 CFR 710):
1'
Page 7 of 9
jj
I

l
j
KloziirTM (7775-27-1-12) Date: 02/22/2005
Listed
RESOURCE CONSERVATION AND RECOVERY ACT (RCRA)
RCRA IDENTIFICATION OF HAZARDOUS WASTE (40 CFR 261):
Waste Number: D001
CANADA
WHMIS (WORKPLACE HAZARDOUS MATERIALS INFORMATION SYSTEM):
Product Identification Number: 1505
Hazard Classification / Division: Class C (Oxidizer), Class D, Div. 2, Subdiv.. B. (Toxic)
Ingredient Disclosure List: Listed
INTERNATIONAL LISTINGS
Sodium persulfate:.
Australia (AICS): Listed
China: Listed
Japan (ENCS): (1)-1131
Korea: KE-12369
Philippines (PICCS): Listed
HAZARD, RISK AND SAFETY PHRASE DESCRIPTIONS:
EC Symbols:
EC Risk Phrases:
EC Safety Phrases:
(Not classified as hazardous)
(Not classified as hazardous)
(Not classified as hazardous)
16.OTHER INFORMATION
HMIS
Health
1
Flammability
0
Physical Hazard'
1
Personal Protection (PPE)
J
Protection = J.(Safety goggles, gloves, apron & combination dust & vapor respirator)
HMIS = Hazardous Materials Identification System
Degree of Hazard Code:
4 = Severe
Page 8 of 9

KlozurTM (7775-27-1-12)
3 = Serious
2 = Moderate
1 = Slight
0 = Minimal
NFPA
Health
1
Flammability
0
Reactivity
1
—Special
OX
SPECIAL = OX (Oxidizer)
NFPA = National Fire Protection Association
Degree of Hazard Code:
4 = Extreme
3 = High
2 = Moderate
1 = Slight
0 = Insignificant
REVISION SUMMARY:
New MSDS
Klozur and FMC Logo - FMC Trademarks
© 2005 FMC Corporation. All Rights Reserved:
Date: 02/22/2005
FMC Corporation believes that the information and recommendations contained herein (including data and
statements) are accurate as of the date hereof. NO WARRANTY OF FITNESS FOR ANY PARTICULAR
PURPOSE, WARRANTY OF MERCHANTABILITY, OR ANY OTHER WARRANTY, EXPRESSED
OR IMPLIED, IS MADE CONCERNING THE INFORMATION PROVIDED HEREIN. The information
provided herein relates only to the specific product designated and may not be applicable where such
product is used in combination with any other materials or in any process. It is a violation of Federal law to
use this product in a manner inconsistent with its labeling. Further, since the conditions and methods of use
are beyond the control of FMC Corporation, FMC Corporation expressly disclaims any and all liability as
to any results obtained or arising from any use of the product or reliance on such information.
Page 9 of 9

C1•BASF
The Chemical Company
Safety data sheet
Carbonyl Iron Powder EW
Revision date : 2006/04/10 Page: 1/7
Version:3.0 (30042256/MDS GEN US/EN)
1. Substance/preparation and company identification
Company 24 Hour Emergency Response Information
BASF CORPORATION CHEMTREC: [phone]
100 Campus Drive BASF HOTLINE: (800) 832-HELP
Florham Park, NJ 07932
Molecular formula: FE (Small Quantities C, N, 0)
Chemical family: metal powder
Synonyms: Carbonyl Iron Powders
2. Composition/information on ingredients
CAS Number Content (WAN) Chemical name
7439-89-6 Carbonyl iron powder
3. Hazard identification
Emergency overview
WARNING: FLAMMABLE. MAY CAUSE EYE, SKIN AND RESPIRATORY TRACT IRRITATION.
INGESTION MAY CAUSE GASTRIC DISTURBANCES.
Use with local exhaust ventilation.
Wear a NIOSH-certified (or equivalent) particulate respirator.
Wear NIOSH-certified chemical goggles.
Wear protective clothing.
Wear chemical resistant protective gloves.
Avoid contact with the skin, eyes and clothing.
Potential health effects
Primary routes of exposure
Routes of entry for solids and liquids include eye and skin contact, ingestion and inhalation. Routes of entry
for gases include inhalation and eye contact. Skin contact may be a route of entry for liquified gases.
Acute toxicity:
Acute overexposure to iron may result in stupor, acidosis, bloody diarrhea and shock.
Information on: Carbonyl iron powder
Virtually nontoxic after a single ingestion.
Repeated dose toxicity:
Long-term inhalation of iron results in siderosis, a benign pneumoconosis.

Me F
The Chemical Company
Safety data sheet
Carbonyl Iron Powder EW
Revision date : 2006/04/10 Page: 2/7
Version:3.0 (30042256/MDS_GEN US/EN)
4. First -aid measures
General advice:
Remove contaminated clothing.
If inhaled:
Remove the affected individual into fresh air and keep the person calm. Assist in breathing if necessary.
Immediate medical attention required.
If on skin:
Wash thoroughly with soap and water.
If irritation develops, seek medical attention.
If in eyes:
Wash affected eyes for at least 15 minutes under running water with eyelids held open. If irritation develops,
seek medical attention.
If swallowed:
Rinse mouth and then drink plenty of water.
Seek medical attention.
5. Fire -fighting measures
Autoignition: > 150 °C
Flammability: Highly flammable.
Suitable extinguishing media:
water spray
Unsuitable extinguishing media for safety reasons:
carbon dioxide
Additional information:
Avoid whirling up the material/product because of the danger of dust explosion.
Protective equipment for fire -fighting:
Firefighters should be equipped with self-contained breathing apparatus and turn -out gear.
Further information:
The degree of risk is governed by the burning substance and the fire conditions. Contaminated extinguishing
water must be disposed of in accordance with official regulations.
NFPA Hazard codes:
Health : 1 Fire: 3 Reactivity: 0 Special:
6. Accidental release measures
Personal precautions:
Avoid dust formation. Use personal protective clothing.

[]aF
The Chemical Company
Safety data sheet
Carbonyl Iron Powder EW
Revision date: 2006/04/10 Page: 3/7
Version:3.0 (30042256/MDS GEN US/EN)
Environmental precautions:
Do not discharge into drains/surface waters/groundwater.
Cleanup:
Do not vacuum up powder.
For large amounts: Dampen, pick up mechanically and dispose of.
For residues: Dampen, pick up mechanically and dispose of.
7. Handling and storage
Handling
General advice:
Handle in accordance with good industrial hygiene and safety practice. Wear suitable personal protective
clothing and equipment.
Protection against fire and explosion:
Fine dust of the product is capable of dust explosion. Avoid all sources of ignition: heat, sparks, open flame.
Electrostatic discharge may cause ignition. Ground all transfer equipment properly to prevent electrostatic
discharge.
Storage
General advice:
Keep away from heat. Keep container tightly closed.
Storage incompatibility:
General: Segregate from acids. Segregate from oxidants.
8. Exposure controls and personal protection
Advice on system design:
Provide local exhaust ventilation to control dust.
Personal protective equipment
Respiratory protection:
Wear a NIOSH-certified (or equivalent) particulate respirator. Do not exceed the maximum use concentration
for the respirator facepiece/cartridge combination.
Hand protection:
Chemical resistant protective gloves
Eye protection:
Safety glasses with side -shields.
General safety and hygiene measures:
Wear protective clothing as necessary to minimize contact. Avoid inhalation of dust. Wash soiled clothing
immediately.

a•BASF
The Chemical Company
Safety data sheet
Carbonyl Iron Powder EW
Revision date: 2006/04/10 Page: 4/7
Version:3.0 (30042256/MDS GEN US/EN)
9. Physical and chemical properties
Form:
powder
Odour:
faint odour
Colour:
grey
Information on: Iron
Melting point:
1,535 °C
Literature data.
-------------------------------
Information on: Iron
Boiling point:
-------------------------------
2,735 °C
Literature data.
Density:
7.8 g/cm3
( 20 °C) Literature data.
Bulk density:
2,500 - 3,500
kg/m3
Solubility in water:
insoluble
10. Stability and reactivity
Minimum ignition energy:
3-10mJ
Inductivity: 1 mH
Conditions to avoid:
Avoid all sources of ignition: heat, sparks, open flame. Avoid electro-static charge. Avoid dust formation
Substances to avoid:
acids
Hazardous reactions:
Dust explosion hazard. Contact with acids liberates hydrogen gas.
Decomposition products:
No hazardous decomposition products if stored and handled as prescribed/indicated.
Corrosion to metals:
No corrosive effect on metal.
11. Toxicological information
Oral:
Information on: Carbonyl iron powder
LD501rat: > 5, 000 mg/kg
Carcinogenicity:
Information on: Carbonyl iron powder
In the majority of the short term assays the substance caused no carcinogenic effects.

[] a F
The Chemical Company
Safety data sheet
Carbonyl Iron Powder EW
Revision date: 2006/04/10 Page: 5/7
Version:3.0 (30042256/MDS GEN US/EN)
12. Ecological information
Inorganic product which cannot be eliminated from water by biological
purification processes.
Can be eliminated mechanically.
Information on: Carbonyl iron powder
The product will not be readily bioavailable due to its consistency and insolubility in water..
Accumulation in organisms is not to be expected.
Information on: Carbonyl iron powder
Acute and prolonged toxicity to fish:
DIN 38412 Part 15 static
golden orfe/LC50 (96 h): > 10,000 mgA
Nominal concentration.
13. Disposal considerations
Waste disposal of substance:
Dispose of in a licensed facility.
Dispose of in accordance with national, state and local regulations.
Container disposal:
Contaminated packaging should be emptied as far as possible; then it can be passed on for recycling after
being thoroughly cleaned.
14. Transport information
Land transport
USDOT
Proper shipping name: METAL POWDER, SELF -HEATING, N.O.S. (contains CARBONYL IRON
POWDER)
Hazard class: 4.2
ID -number: UN 3189
Packing group: II
Sea transport
IMDG
Proper shipping name: METAL POWDER, SELF -HEATING, N.O.S. (contains CARBONYL IRON
POWDER)
Hazard class: 4.2
ID -number: UN 3189
Packing group: 11

On
The Chemical Company
Safety data sheet
Carbonyl Iron Powder EW
Revision date : 2006/04/10 Page: 6/7
Version: 3.0 (30042256/M DS_G E N_US/EN)
Marine pollutant: NO
Air transport
IATA/ICA0
Proper shipping name:
METAL POWDER, SELF -HEATING, N.O.S. contains (CARBONYL IRON
POWDER)
Hazard class:
4.2
ID -number:
UN 3189
Packing group:
II
15. Regulatory information
Federal Regulations
Registration status:
TSCA, US
released / listed
OSHA hazard category:
Skin and/or eye irritant, Flammable Solid
SARA hazard categories (EPCRA
311/312): Acute, Fire
16. Other information
HMIS III rating
Health: 1 Flammability: 3 Physical hazard: 0
HMIS uses a numbering scale ranging from 0 to 4 to indicate the degree of hazard. A value of zero means that the
substance possesses essentially no hazard; a rating of four indicates high hazard.
Local contact information
[e-mail]

The Chemical Company
Safety data sheet
Carbonvl Iron Powder EW
Revision date : 2006/04/10 Page: 7/7
Version: 3.0 (30042256/M DS_G E N_US/EN)
IMPORTANT: WHILE THE DESCRIPTIONS, DESIGNS, DATA AND INFORMATION CONTAINED HEREIN
ARE PRESENTED IN GOOD FAITH AND BELIEVED TO BE ACCURATE, IT IS PROVIDED FOR YOUR
GUIDANCE ONLY. BECAUSE MANY FACTORS MAY AFFECT PROCESSING OR APPLICATION/USE,
WE RECOMMEND THAT YOU MAKE TESTS TO DETERMINE THE SUITABILITY OF A PRODUCT FOR
YOUR PARTICULAR PURPOSE PRIOR TO USE. NO WARRANTIES OF ANY KIND, EITHER
EXPRESSED OR IMPLIED, INCLUDING WARRANTIES OF MERCHANTABILITY OR FITNESS FOR A
PARTICULAR PURPOSE, ARE MADE REGARDING PRODUCTS DESCRIBED OR DESIGNS, DATA OR
INFORMATION SET FORTH, OR THAT THE PRODUCTS, DESIGNS, DATA OR INFORMATION MAY BE
USED WITHOUT INFRINGING THE INTELLECTUAL PROPERTY RIGHTS OF OTHERS. IN NO CASE
SHALL THE DESCRIPTIONS, INFORMATION, DATA OR DESIGNS PROVIDED BE CONSIDERED A
PART OF OUR TERMS AND CONDITIONS OF SALE. FURTHER, YOU EXPRESSLY UNDERSTAND AND
AGREE THAT THE DESCRIPTIONS, DESIGNS, DATA, AND INFORMATION FURNISHED BY BASF
HEREUNDER ARE GIVEN GRATIS AND BASF ASSUMES NO OBLIGATION OR LIABILITY FOR THE
DESCRIPTION, DESIGNS, DATA AND INFORMATION GIVEN OR RESULTS OBTAINED, ALL SUCH
' BEING GIVEN AND ACCEPTED AT YOUR RISK.
END OF DATA SHEET

DOCUMENTS ASSOCIATED
WITH
THE ORIGINAL PERMIT
APPLICATION
(ISSUED OCTOBER 21Y. 2011)

--0—� �-
= FENCE
—E —E —
= OVERHEAD ELECTRICAL LINE
= TYPE II MONITORING WELL
= TYPE III MONITORING WELL
= FORMER TEMPORARY WELL LOCATION
OO
= SOIL BORING LOCATION
eo
= LOCATION OF FORMER MINERAL
SPIRITS UST
w
w
1
/
i
I
7—
DUMPSTER
Y
PICNIC
1/ AREA I I
lb i GRAVEL I CONCRETE
OFFICE t
r
/ I n
1 I
7-
SIDEWALK
----LANDSCAPE - ---- �----� - - -� *BMW-1B r.
IL-----Ir I
I
I GRAVEL
I
I
I
PAVED I *BMW-1 A
I
I r-
I II
I OB-4 r
I
CONCRETE -
I I _
s-e—E—E—e—a—e—e—
I
TW-2 I MW-4
@
I
�
PAVED j �
-6
BTW-4
I.- . -
ms-
I
-3 CON
STORAGE
i Mw-s i
ROOM
W
TW-5
_
PAVED i o
WAREHOUSE
i �a�®z
O
w"
I I
Yt
v
I
I I
0
I
---------------I 0 w
Ld I V)
0 W
A I 0 0 O
I j4 LLJ
JA Ld YW-3 Q
LANDSCAPE I (n j }'
I
LANDSCAPE I
w
--------- A O --j w
6 =
/ W
0/ MW-3 I
/E. A
6 A
- - —c —
- - - - — — — — — — SIDEWALK
MW-2TW-6. I -
MW-2D STORAGE..TANKS . 75,000, GAL -
e —e—'E: =_ E —_E
B TW-7 ---.SIDEWALK'-------T
YADKIN AVENUE.
60
APPROXI[VPATE:SCALE•'N" FEET
Lo
M
o
r-
9
O
O
z O
F (D
U
U
O
d�
�d-
Qw
VZ�
at7
Oo
p
0 co
O
O
N
Z
O
w
o N
~ m
I\
U N
O
o
Q a
Z
:
LL, O
Z
¢ _
=
U V)
m
rn
�
m
Q
W
m LL-
Z
W
� Q
U
a
LI
U Li
>�
� Z
W W
cf) >
z Q U
N Ld z z
Li
Ld
Q I Q
:2
-1
Li
00
ui W Li. NQ
� Q rr =
1 Lr)
LL
(n (n N U
o
6
w
O
Z

— 3— 3— 3— 3— 3— 3—
3 3— 3— 3— 3— 3— 3—
3— 3— 3— 3— 3— 3-
-
a
O B-1
/
PICNICR
I
I
I
r--
�/
i
GRAVEL I CON
L _
OFFICE I
I
�
I
I
SIDEWALK
LA i ---NDSCAPE ---
- -^ Z - -� - --�
B
L-----Ir F F I
GRAVEL
PAVED
I
I
*E
I
I
I
I
I
I
I
-�
OB-4
r CONCRETE
r-
I
I I
-I----T------i----@)B-5
•-- E E
-
-,
I
/ I
i
I
TW-2 I MW-4
PAVED
d-3
I
-
LLJ
W
I
STORAGE
ROOM
w I
i Mw-s
I I
U
Z
Ul
PAVED 0
WAREHOUSE
i iB0
i
W i
j I 0
\I LJ
I
N
Z
W �-
m
>
O O
I
(�
I
I
I
fiVJ-3
W
I
W
LANDSCAPE
I
/ -
- LANDSCAPE- - - p
ILiJ
MW-3
-� [- E �- E -
E E E Ey- E
— — — — — — — — — — — — — — — — — — — — — — — — —
I SIDEWALK
TANKS
3- 3- 3-
3- 3- 3-}
WI
I
DUMPSTER
I
I
ZETE
I
W
I
N-1B
I
W
I
I
N-1A
I
I
I
I
W
E E
-1-
6
BTW-4
C=
\1 I TW-6
E - E E -- E -E - E _-E -E -e
__________
BTW-7 clnFWel Ic
YADKIN AVENUE
co
m'
o
---a--a- = FENCE
-E —E = OVERHEAD ELECTRICAL LINE
I`
m
o
Z o
= TYPE II MONITORING WELL
07
' o
= TYPE III MONITORING WELL
° U
�
a v�
%a
= FORMER TEMPORARY WELL LOCATION
Z °'
J �
L0
O® = SOIL BORING LOCATION
o
0
= LOCATION OF FORMER MINERAL
1!mmm
co
~
SPIRITS UST
��
o
— — — = ESTIMATED EXTENT OF GROUNDWATER
Z `�
ul
IMPACTED ABOVE NC 2L STANDARDS
LL
o
o r
N
a
>
co5 N
0-
0 of
fn c
Q O
0
o
J O
MW-4 06/29/2011 Dup
voce
Z
o,
(%
<
Benzene (ug/L) 1.5 1.8
Q
1,2—Dichlorobenzene (ug/L) 20 24
ca
1,4—Dichloroethane (ug/L) 5.5 6.1
1,1—Dichloroethane (ug/L) 15 14
Vinyl Chloride (ug/L) 0.61 0.91
No other exceedences of NC 2L Standards
Q
}
m
� O
z
it
CD
I=
MW-5 06/29/2011
LLJ
}
VOCs
W
~
9 LL
1,1—Dichloroethane (ug/L) 53
(,
Z
w Q
Vinyl Chloride (ug/L) 0.51
Z
LIJ
a
No other exceedences of NC 21. Standards
O
U
z
LIJ
U LLJ
a
j �
z
Drf
�wz
W
(n
zo
Z Q U
r4-) U
Ld Z Z
MW-2 06/29/2011
LLI Qf
J W
�— No exceedences of NC 2L Standards
I
Y
0
O
07
Ln
W O
LL- N Q
Q =
LL N
tY
I— C.�
(n N U
o
-21) 06/29/2011
0
:xceedences of NC 2L Standards
Q
W
o
0
O
m
-3. 06/29/2011
Z
:xceedences of.NC,,2L Standards
AI
O
rn o
Z Q
00
Z
¢
0 15 30. 60
ZEn
APPRE)XIMM.*-S :1 _NN-=-MEET:
o oz
Z

1
f— a— a— a— a— a— 7 a— a— a— a— a— a— a— a— a— a— a— a— a— ate— a— a— a— a--?
0 0 = FENCE r
-E -E
OVERHEAD ELECTRICAL LINE
= TYPE II MONITORING WELL
/ Y
= TYPE III MONITORING WELL DUMPS ER I
= FORMER TEMPORARY WELL LOCATION ►/ PICNIC
pO = SOIL BORING LOCATION �� AREA r
I I
I I
= LOCATION OF FORMER MINERAL I r I
SPIRITS UST ► I GRAVEL I CONCRETE
= GROUNDWATER ELEVATION CONTOUR L - - - - - r
(DASHED WHERE INFERRED) OFFICE I
(78.07) = GROUNDWATER ELEVATION (ft. I
(DRY) = DRY WELL I r
SIDEWALK
l_ - LANDSCAPE - 1-- _ BMW-1 B
-Z---1TT
-----II I I I I
I
I I
I GRAVEL
� I r
PAVED I
� BMW-tA
� I r
I II
I OB-4 r
f -
CONCRETE I
W
W
ry
U)
I I
—j
t -t — L
——
�-t t
----T-------- j MW-4 6 1
j I-378A7
\VED CON
Li
t i MW-5
I 75.98
U
O I
I
I
I
I
-------
wU
Ld
----�
o
>LTW-3
O
�N
r.,
r
76#5
O
00
33
MW-2D
S RAGE TANKS (15,000 GAL)
\ r
75.74
\
r
—L —L —L —t
—[ _L —■
YADKIN AVENUE
0 15.. 30 60
APPROXIMATE SCALE IN FEET
Lo
m
o
r
O
ro
o
d
Z
U �
U
w O
o
a
LL
z
L C)
O
0 O
U
x �
•-
o
O °'
N
z
O
o N
v
Q 0
N
U) c
Q o
U
3�:
t
w O
z
U In
=
_rn
rn
V)
Q
m
0-
Q
:�i
m
w O
m
�
OZ
W
O -
m
a LL-
U Z
W
w Q
a
Z U
O w
1- O
w
Q >
> ft� z
LLJ w
w�>
z<u
d LLJ Z
H W z
J Y
CD
LIJ Q W
tY Yc�
o
�o IQ�
z O
CD
m
ON
Ib
W O LL Q
n
F Qf Q n_
tL
❑ N
P: 0 (nNO
a
U
c�
0
O
O U O
U Z
C�
Z O (n Z
O N <
> N ON Z
WW 10
Z 'S U
Ld z
0 O w 0
LLJ
Zo �o
=) W d J
Q W U
W (gym �Z
r
O N
Z

i
= FENCE
=OVERHEAD ELECTRICAL LINE
= TYPE II MONITORING WELL
= TYPE III MONITORING WELL DUMPSTER
I
= FORMER TEMPORARY WELL LOCATION 1/ w
OO = SOIL BORING LOCATION �/ AIIREA I I
= LOCATION OF FORMER MINERAL
SPIRITS UST ► GRAVEL I CONCRETE
= CROSS-SECTION TRANSECT OFFICE I L I
/ I r
; I
' SIDEWALK B w
_ LANDSCAPE _ _ -- -- - - I I
_ _ BMW-1B
1111111IL-----IF I I
I
j GRAVEL I
I W
PAVED I I
I BMW-1A
I
I r
B-4 I
CONCRETE -� I
n I
---- B -5-- 4TW-1- I 7------- I r
TW-2 I MW-4 B-6 0
PAVED ; BTW-4
-3 C Y
STORAGE
ROOM U I MW
z I I T
~ z 0 I 98 I DRY
(n ad 0 WAREHOUSE 0 I iB 2 Y O Y
N I -----------; o LLJLd
r
>I >
CO
) = w
LLI
I------------.J � I w
LANDSCAPE I
LANDSCAPE ZO I
W
Of
w Q MW-2 �TW-6 r
75.66 I 75.66 000
77.33
M 2D STORAGE TANKS (15,000 GAL) r
� I 75.74
po
Y / I
Y
Ir — — — — — — — — — — — SI— —DEWALK — — — — — — — — — —
BTW-7 cinpr✓ei u
YADKIN AVENUE
0 15 30 60
APPROXIMATE SCALE IN FEET
to
O
I�
O
d0
z
U
X
1 O
O
QLL
a Ivi
z m
L0
J
°f9
d
o
0
�
rn
o
0—
N
z
w
O
o N
I
~�
N
O
/ U
O c
Q a
Z
0
J O
cn
t
_rn
N
U
Q
m
O
w U
W W
Q I-
Z
Z U
O
F- W
m
w Q
a
W
U >
O
Ld w
O Z Q U
Ln E-- W Z Z
LLJ W J Y W
(n Y 0
p
Q I-
U I iio
CO
Ld O
rn
00
N
w O W N Q
F Q Iri =
!
U (n N U
o
65
w
r-
0
z

L:2 = N01iVa300VX3 IVOUl DA
p fV
W rn
a
o c
x
m
m F
c
a
m
2
m
m
q
�9
�>• PG O
°
I
o
�'
c°s.
�9J
m
3
.-0
X_
m'
�
N
n
n
ro
�
D
_
D
O0
7
D
m
C
Z
v
Z
a
W
<
'TI
m
=
V)
N
r
�
D
O
K
2
m
m
m
�
D
G')
r
A
r
0
NOTES: TITLE FIGURE 6
CROSS—SECTION A —A'
SAFETY-KLEEN SERVICE CENTER (M%TC'
2320 YADKIN AVENUE ASSOCIATES OF NORTH CAROLINA, P.C.
CHARLOTTE, NC Raleigh, North Carolina 27604 [phone] FAX [phone]
CAD FILE PREP. BY REV. BY SCALE DATE PROJECT NO.
1252896.DWG AF GO AS SHOWN 07-27-2011 045.34016.0007

1.:2 = NOliVN300VX3 'Mlia3A
0') CN
rl 0')
O
0 o O1 0 0
0 0 0
a
O O
x
M
m N
n O
a
r
m
z
m
-P
O
I�
NOTES: TITLE FIGURE 7
CROSS-SECTION B-B'
SAFETY-KLEEN SERVICE CENTER
2320 YADKIN AVENUE (M%TC
ASSOCIATES OF NORTH CAROLINA, P.C.
CHARLOTTE, NC Raleigh, North Carolina .27604 [phone] FAX [phone]
CAD FILE PREP. BY REV. BY SCALE DATE PROJECT NO.
1252896.DWG AF GO AS SHOWN 07-27-2011 045.34016.0007

- 3 3- 3- 3- 3
Note that the injection area extends to
3— 3— 3— 3— 3— 3— 3
MW-2 based on historical detections of
COCs above 2L Standards in well MW-2.
If this well continues to show no exceedences /
of 2L Standards during future sampling
events, some injection locations may be '
moved to focus more on the area of /
known groundwater impact. PICNIC
w
LLJ
171-1
—
U)
3- 3- 3— 3- 3- 3- 3- 3- 3- 3
O B-1
MPSTER
AREA I I
/ I F — — — — — -
GRAVEL I CONCRETE
E------
/ OFFICE
I
SIDEWALK
---=LANDSCAPE
— — -------�
— — — — —
-L —— J-- _— _
BMW-1B
L-----Ir
I
j
I
GRAVEL
PAVED
I
I
BMW-1A
I
I
I
I
- j
OB-4
CONCRETE
I 1�
I
r-E
E -E
E -E -E -E
-
I
----T------- ------ �B-5 -- 1-
TW-2
QMW-4 -6
PAVED
T3-3
LLJ
STORAGE
W '
•
Mw-s
ROOM
Z
w
I
I
I
1-0
PAVED 1 o
WAREHOUSE
;
i6-2
Y
I
I
I
1
U
OQ
---- — —
— — — — ——
F
o
w
I
I
r-
I
I
I
I
- LANDSCAPE J
I w u3 (n
U >
zo O
®
O
w
I
TW-3 �Q
W
(n
I
— — LANDSCAPE—
w
IElf
MW-3�� m
MW-2 ©
------� —c —E —E E —E I—E
SIDEWALK
YADKIN AVENUE
TANKS (1
E — E
BTW-4
-`�W-5
TW-6
E E E E E-
� BTW-/ SIDEWALK i
1
I
I
I
I
I
I
W
I
I
I
I
= FENCE
o
-E -E = OVERHEAD ELECTRICAL LINE
m
o
d O
= TYPE II MONITORING WELL
� uj
# = TYPE III MONITORING WELL
v v
O
o
a
= FORMER TEMPORARY WELL LOCATION
z
OO = SOIL BORING LOCATION
0 0
0
• = PROPOSED PHASE II INJECTION WELL
m
9 = PROPOSED PHASE I DIRECT PUSH
INJECTION POINT
o
o
= LOCATION OF FORMER MINERAL
a
SPIRITS UST
0
0 N
CO a
— — = ESTIMATED EXTENT OF GROUNDWATER
IMPACTED ABOVE NC 2L STANDARDS
U N
O
0
a o
Z
U
r
J O
MW-4 06/29/2011 Dup
Z
v
vocs
r
co
Benzene (ug/L) 1.5 1.8
•�
(n
1,2—Dichlorobenzene (ug/L) 20 24
a)
Q
1,4—Dichloroethane (ug/L) 5.6 6.1
1,1—Dichloroethane (ug/L) 15 14
Vinyl
fY
m
O
Chloride (ug/L) 0.61 0.91
No other exceedences of NC 2L Standards
CD
0
1.1—Dichloroethane (ug/L) 53
Vinyl Chloride (ug/L) 0.51
No other exceedences of NC 2L Standards
MW-2 06/29/2011
No exceedences of NC 2L Standards
(/) 0�
Z LLJ
a
O I—
a
1= z
Q LLJ
W
a
U U
O LL 1
J U
z>�
O D- z
F- L L1 LLI
(n
�za�
co z LLJ z
LLJ z
W J Y W
CD
W �
CCU �Q0
LL- 0- W O
OLL-
SIN
06/29/2011 I >
of NC 2L Standards
w
0
0
m
06/29/2011
?
of NC 2L Standards
Z
2
Ln Ui
I
Z of
OA
0 15 30 60
I-
W J
Ca U N
APPROXIMATE SCALE IN FEET
o o z
Z

ATC
A S S O C I A T E S I N C.
2725 E. Millbrook Road, Suite 121
Raleigh, NC 27604
[phone]
PROJECT NO: 45.16031.0007
DATE: 4/29/2011 1 REVIEWED BY: GKO
Well finished at surface with locking well cap
^a ''" a ^ peter flush -mounted bolt -down
ver with 2' by 2' concrete pad.
ut/bentonite mixture from 0 to I
40 PVC casing from 0 to 15'
cal from 11 to 13'
From 13 to 25'
.e 40 PVC 0.030-inch slot well screen
25'
FIGURE 9
Injection Well Construction
Diagram
Safety-Kleen Service Center
2320 Yadkin Avenue
Charlotte, North Carolina

NCDENR
nlnrfh '^arolina DPrartm.Pnt of Environment and Natural Resources
Beverly Eaves Perdue
Governor
Robert A. Schoepke, Director of Remediation
1502 East Villa Street, 2nd Floor
Elgin, Illinois 60120
Division of Water Quality
Coleen H. Sullins
Director
February 28, 2012
Ref: Issuance of Modified Injection Permit W10300181
Safety-Kleen Facility
Charlotte, Nfeckle.uhr.u-e County, North Carolina.
Dear Mr. Schoepke:
Dee Freeman
Secretary
In accordance with the application received by email on January 10, 2012, we are forwarding permit number WI0300181.
This permit is to inject Zero Valent Iron, Sodium Persulfate, and Hydrogen Peroxide to remediate groundwater
contaminated with chlorinated solvents and petroleum solvents at the facility referenced above. This permit shall be
effective from the date of issuance until September 30, 2014, shall void Permit Number WI0300181 issued October 20,
2011, and shall be subject to the conditions. and limitations stated therein, including the requirement to submit a final
project evaluation as stated in PART VII — MONITORING AND REPORTING REQUIREMENTS. Please note that the
monitoring requirements are similar to the original permit that was issued on October 21, 2011, and that these include the
conditions which require the installation and monitoring of a new well. Please read the entire permit to ensure that you are
aware of all compliance requirements of the permit. The permit allows for the installation of twelve permanent injection
wells in six well nests, instead of the four permanent injection wells as originally permitted.
You will need to notify this office by telephone 48 hours prior to initiation of operation of the facility. In order to
continue uninterrupted legal use of the injection facility for the stated purpose, you must submit an application to renew
the permit 120 days prior to its expiration date. Please contact me at [phone] or at [e-mail] if
you have any questions about your permit.
Best Regards,
L
C
David Goodrich, PG
Hydrogeologist
cc: Andrew Pitner, Mooresville Regional Office
Genna K. Olson, PG, ATC Associates of North Carolina, PC, 2725 East Millbrook Road, Suite 121, Raleigh, NC 27604
Adam Ulishney, NCDWM Hazardous Waste Section, 1646 Mail Service Center, Raleigh, NC 27699-1546
WI0300181 Permit M16
AQUIFER PROTECTION SECTION
1636 Mail Service Center, Raleigh, North Carolina 27699-1636
Location: 2728 Capital Boulevard, Raleigh, North Carolina 27604
phone' 919 733-32211 F ;X 1: 919 715-0588; FAX 2: 919-715-6048 ! Customer Seivire: 1-877-623-6748
Internet: www.ncwai'6raualiN.ora
An Egdal Opportunity 1 Affirmative Action Employer
One .

Govemor
Robert A Schoepke — P.G.
Safety-Kleen Systems, Inc.
1502 East Villa St., 2nd Floor
Elgin, IL 60120
Dear Mr. Schoepke:
NCC�ENR
Director
February 17, 2012
Subject: Acknowledgement of Application
No. W10300181
Safety-Kleen Systems Inc
Injection In situ Groundwater
Remediation Well (5I) System
Mecklenburg, County
Secretary
The Aquifer Protection Section acknowledges receipt of your permit application and supporting
documentation received on 01/10/2012. Your application package has been assigned the number listed above, and
the primary reviewer is David Goodrich.
Central and Mooresville Regional Office staff will perform a detailed review of the provided application,
and may contact you with a request for additional information. To ensure maximum efficiency in processing permit
applications, the Aquifer Protection Section requests your assistance in providing a timely and complete response to
any additional information requests.
Please note that processing standard review permit applications may take as long as 60 to 90 days after
receipt of a complete application. If you have any questions, please contact David Goodrich at [phone] or
[e-mail].
S' cerel ,
for Debra J. att
Groundwater Protection Unit Supervisor
cc: Mooresville Regional Office, Aquifer Protection Section
Genna K Olson, P.G. — ATC Associates of N.C., PC, 2725 E. Millbrook Rd., Ste. 121, Raleigh,
NC 27604
G-Permit File WI0300=f81
Location: 512 N. Salisbury St., Raleigh, North Carolina 27604
Une:l.. .
Phone: [phone] FAX: [phone] No ,.hCa.Olhia
Internet: www.nmaterguality.ora u C
An Equal Opportunity \ Affirmative Action Employer`

Goodrich, David
From:
Goodrich, David
Sent:
Wednesday, February 15, 2012 12:13 PM
To:
'Justin Ballard'
Cc:
Pitner, Andrew
Subject:
RE: Safety -Clean Site Injection Activities under Injection Permit Number W10300181
Justin,
Thank you for your recent email regarding the requested changes to Phase II of the permitted injection treatment
program at the Safety -Clean Site.
Since there is no major change in the concept of Phase II, the wells will be treating the same zone and area, and the
changes are being requested in accordance with discoveries that were disclosed in the performance of Phase I, 1 am
looking into the possibility of addressing the change of extending the permit to cover 6 permanent injection wells (as
opposed to the 4 that the permit currently allows) by using a letter instead of a permit "re -do". I am contacting our
Mooresville Regional Office to find out if they have any reservations about this plan to "amend" the permit, and will
contact you when I hear from them.
Regards,
David Goodrich
Aquifer Protection Section Central Office
Office Telphone Number: [phone]
Aquifer Protection Section Main Number: [phone]
Fax Number: [phone]
From: Justin Ballard[mailto:justin.ballard(apatcassociates.com1
Sent: Monday, February 13, 2012 12:38 PM
To: Goodrich, David
Subject: RE: Safety -Clean Site Injection Activities under Injection Permit Number WI0300181
Mr. Goodrich,
When you get the chance, I just wanted to check on the following permit addendum as listed in the email below.
Thanks.
Justin C. Ballard, P.G. I Project Geologist I ATC Associates of North Carolina, P.C.
[phone] direct 1 [phone] mobile
2725 E. Millbrook Road I Suite 121 1 Raleigh, North Carolina 27604
[phone] 1 [phone] fax I www.atcassociates.com
ATC is a leader in developing innovative Environmental, Geotechnical/CMT/Special Inspections and Health & Safety solutions.
PLEASE NOTE: This message, including any attachrnents, may include privileged, confidential and/or inside information. Any
distribution or use of this communication by anyone other than the intended recipient is strictly prohibited and may be unlawful. If
you are not the intenders recipient, please notify the sender by replying to this message and then delete it from your computer.

From: Justin Ballard [mailto:justin.ballard(aatcassociates.coml
Sent: Tuesday, January 10, 2012 10:39 AM
To: 'Goodrich, David'
Subject: Safety -Clean Site Injection Activities under Injection Permit Number WI0300181
Mr. Goodrich, -
Please find the attached pdf as ATC's Injection Permit Addendum for the Safety -Clean site in Charlotte, NC. This
attachment documents proposed changes made to the original permit application as discussed in our phone conversation
the week of December 19th, 2011. Please let me know if there are any questions. Thank you.
Justin C. Ballard, P.G. I Project Geologist I ATC Associates of North Carolina, P.C.
[phone] direct 1 [phone] mobile
2725 E. Millbrook Road I Suite 121 1 Raleigh, North Carolina 27604
[phone] 1 [phone] fax I www.atcassociates.com
From: Goodrich, David Imailto:[e-mail]
Sent: Wednesday, December 07, 2011 9:31 AM
To: [e-mail]
Cc: Schutte, Maria; Pitner, Andrew
Subject: Safety -Clean Site Injection Activities under Injection Permit Number WI0300181
Justin,
Thank you for contacting me this morning regarding your intentions of installing the additional monitoring well (as
required by the permit) at the subject site on Monday, December 12tn, and subsequent sampling of this well on Tuesday,
December 13tn
It is my further understanding that injection activities will commence at the site on Wednesday, December 14tn
I am copying this transmission to the Mooresville Regional Office for their information.
Regards,
David Goodrich
Aquifer Protection Section Central Office

1,
Goodrich, David
From:
Goodrich, David
Sent:
Friday, February 17, 2012 10:59 AM
To:
'Justin Ballard'
Cc:
Pitner, Andrew
Subject:
Modification of Safety -Clean Injection Well Permit W10300181
Justin,
After some discussion and consideration, we have determined that the best course of action is to modify the subject
permit to extend permission to install and operate (4) injection wells to (6) well nests of two wells each (12 injection
wells total), in accordance with your email and its attachments received on January 10, 2012.
We are proceeding with this change. Please contact me if you have any questions or concerns regarding this action.
Thank you.
Regards,
David Goodrich
Aquifer Protection Section Central Office
Office Telphone Number: [phone]
Aquifer Protection Section Main Number: [phone]
Fax Number: [phone]

DOCUMENTS ASSOCIATED
WITH
THE ORIGINAL PERMIT
APPLICATION
(ISSUED OCTOBER 21, 2011)

A7LA
ri
RCDENR
North Carolina Department of Environment and Natural Resources
Beverly Eaves Perdue
Governor
Robert A. Schoepke, Director of Remediation
1502 East Villa Street, 2nd Floor
Elgin, Illinois 60120
Division of Water Quality
Coieen H. Sullins
Director
October 21, 2011
Ref: Issuance of Injection Permit WI0300181
Safety-Kleen Facility
Charlotte, Mecklenburg County, North Carolina.
Dear Mr. Schoepke:
Dee Freeman
Secretary
In accordance with the application received on September 1, 2011, we are forwarding permit number WI0300181. This
permit is to inject Zero Valent Iron, Sodium Persulfate, and Hydrogen Peroxide to remediate groundwater contaminated
with chlorinated solvents and petroleum solvents at the facility referenced above. This permit shall be effective from the
date of issuance until September 30, 2014, and shall be subject to the conditions and limitations stated therein, including
the requirement to submit a final project evaluation as stated in PART VII — MONITORING AND REPORTING
REQUIREMENTS. Please note that some of the monitoring requirements have changed from your application, and that
these include the installation and monitoring of a new well. Please read the entire permit to ensure that you are aware of
all compliance requirements of the permit.
You will need to notify this office by telephone 48 hours prior to initiation of operation of the facility. In order to
continue uninterrupted legal use of the injection facility for the stated purpose, you must submit an application to renew
the permit 120 days prior to its expiration date. Please contact me at [phone] or at [e-mail] if
you have any questions about your permit.
Best Regards,
David Goodrich
Hydrogeologist
cc: Andrew Pitner, Mooresville Regional Office
Genna K. Olson, ATC Associates of North Carolina, PC, 2725 East Millbrook Road, Suite 121, Raleigh, NC 27604
Adam Ulishney, NCDWM Hazardous Waste Section, 1646 Mail Service Center, Raleigh, NC 27699-1546
tiI03 0,J 87Perntl'e
AQUIFER PROTECTION SECTION
1636 Mail Service Center, Raleigh, North Carolina 27699-1636
Location: 2728 Capital Boulevard. Raleigh, North Carolina 27604
Phone: [phone] FAX 1: 919-715-0588; FAX 2: 919-715-60481 Customer Service: 1-877-623-6748
Internet: www.ncwatemualitv.orci
One
N o-,thCe1.rOhna
An Equal Opportunity , Affirmative Action Employer

�AZEMEMISM
HCDEHR
North Carolina Department of Environment and
Division of Water Quality
Beverly Eaves Perdue Coleen H. Sullins
Govemor Director
September 6, 2011
Robert A. Schoepke, P.G. — Director-Remediation
Safety-Kleen Systems, Inc.
1502 East Village Street, 2°a Floor
Elgin, NC 60120
Dear Mr. Schoepke:
Natural Resources
Dee Freeman
Secretary
Subject: Acknowledgement of
Application No. WI0300181
Safety-Kleen Systems, Inc.
Injection In situ Groundwater
Remediation Well (51) System
Mecklenburg County
The Aquifer Protection Section acknowledges receipt of your permit application and supporting
documentation received on September 1, 2011. Your application package has been assigned the number
listed above, and the primary reviewer is David Goodrich.
Central and Mooresville Regional Office staff will perform a detailed review of the provided
application, and may contact you with a request for additional information. To ensure maximum
efficiency in processing .permit applications, the Aquifer Protection Section requests your assistance in
providing a timely and complete response to any additional information requests.
Please note that processing standard review permit applications may take as long as 60 to 90 days
after receipt of a complete application. If you have any questions, please contact
David Goodrich at [phone] or [e-mail].
Sincerely,
for Debra J. Watts
Groundwater Protection Unit Supervisor
cc: Mooresville Regional Office, Aquifer Protection Section
Genna K. Olson — ATC Associates of North Carolina, PC - 2725 East Millbrook Road, Suite 121, Raleigh, NC 27604
=t-Fi.1e WI03001-&
AQUIFER PROTECTION SECTION
1636 Mail Service Center, Raleigh, North Carolina 27699-1636
Location: 2728 Capital Boulevard, Raleigh, North Carolina 27604
Phone: [phone] i FAX 1: 919-715-0588; FAX 2: 919-715-604811 Customer Service: 1-877-623-6748
Internet: www.ncwatemualitv.org
An yua! Opportunity , Affirmative ActionEmployer
One
NO d1 a:I"Olipa
riff

Goodrich, David
From: Goodrich, David
Sent: Wednesday, February 15, 2012 12:03 PM
To: Pitner, Andrew
Subject: FW: Safety -Clean Site Injection Activities under Injection' Permit Number W10300181
Attachments: SK Charlotte Inj Rpt & Permit Add 1-9-2012.pdf
Andrew,
The Permittee ran into problems in the first phase of their permitted injection treatment program, and wish to modify
Phase it of that program by installing 6 permanent injection wells instead of the 4 which have been permitted through
their existing permit (issued by us on October 21, 2011). The two additional wells are going to be in the same treatment
area and should more effectively treat the contaminants.
Instead of issuing a new permit, we are inclined to give them a go-ahead based on the attached document that they sent
to the Central Office (which explains what they intend to do and why they intend to do it) in the form of a short letter, if
you have no objections or concerns about their proposed change in plans.
Please let me know your thoughts on this.
Thank you 1
Regards,
David Goodrich
Office Telphone Number: [phone]
Aquifer Protection Section Main Number: [phone]
Fax Number: [phone]
From: Justin Ballard [mailto:justin.ballardCabatcassociates.coml
Sent: Tuesday, January 10, 2012 10:39 AM
To: Goodrich, David
Subject: Safety -Clean Site Injection Activities under Injection Permit Number WI0300181
Mr. Goodrich,
Please find the attached pdf as ATC's Injection Permit Addendum for the Safety -Clean site in Charlotte, NC. This
attachment documents proposed changes made to the original permit application as discussed in our phone conversation
the week of December 19th, 2011. Please let me know if there are any questions. Thank you.
Justin C. Ballard, P.G. I Project Geologist I ATC Associates of North Carolina, P.C.
[phone] direct 1 [phone] mobile
2725 E. Millbrook Road I Suite 121 1 Raleigh, North Carolina 27604
[phone] 1 [phone] fax I wtvw.atcassociates.com
From: Goodrich, David [mailto:david.goodrichC�ncdenr.gov]
Sent: Wednesday, December 07, 2011 9:31 AM
To: justin.ballard0atcassociates.com
Cc: Schulte, Maria; Pitner, Andrew
Subject: Safety -Clean Site Injection Activities under Injection Permit Number WI0300181

Justin,
Thank you for contacting me this morning regarding your intentions of installing the additional monitoring well (as
required by the permit) at the subject site on Monday, December 12th, and subsequent sampling of this well on Tuesday,
December 13tn
It is my further understanding that injection activities will commence at the site on Wednesday, December 14tn
I am copying this transmission to the Mooresville Regional Office for their information.
Regards,
David Goodrich
Aquifer Protection Section Central Office

Goodrich, David
From:
Schutte, Maria
Sent:
Friday, February 17, 2012 2:23 PM
To:
Goodrich, David
Cc:
Pitner, Andrew
Subject:
RE: Approval of Proposed changes to the Safety -Clean Injection Permit W10300181
David,
The MRO is okay with this modification
Maria
From: Goodrich, David
Sent: Friday, February 17, 2012 10:46 AM
To: Schulte, Maria
Subject: Approval of Proposed changes to the Safety -Clean Injection Permit WI0300181
Maria,
We are going to go ahead and modify the Safety -Clean Injection Well Permit to allow for the installation of (6) injection
well nests (12 wells total) instead of the originally -permitted (4) injection wells at this facility.
Could you send me a brief email confirming that you and Andrew approve of this modification?
Thank you!
David
Office Telphone Number: [phone]
Aquifer Protection Section Main Number: [phone]
Fax Number: [phone]
1

j \ �
Central Files: APS SWP
02/17/12
Permit Number W10300181 Permit Tracking Slip
Program Category Status Project Type
Ground Water. In review Major modification
Permit Type Version Permit Classification
Injection In situ Groundwater Remediation Well (51) Individual
Primary Reviewer Permit Contact Affiliation
david.goodrich Genna K. Olson
PG
Coastal SW Rule Atc Associates Of N Carolina
Raleigh NC 27604
Permitted Flow
Facility
Facility Name Major/Minor Region
Safety-Kleen Systems Inc Minor Mooresville
Location Address County
2320 Yadkin Ave Mecklenburg
Charlotte NC 28205 Facility Contact Affiliation
D�I^lit� y
Owner Name Owner Type
Safety-Kleen Systems Inc Unknown
Owner Affiliation
Robert Schoepke
GP
1502 E Villa St 2nd Floor
Oates/Events Elgin IL 60120
Scheduled
Orig Issue App Received Draft Initiated Issuance Public Notice Issue Effective Expiration
10/21/11 01/10/12
Regulated Activities Requested/Recelved Events
Groundwater monitoring RO staff report received
Groundwater remediation RO staff report requested
C utfall NULL
Waterbody Name Stream Index Number Current Class Subbasin

DOCUMENTS ASSOCIATED
WITH
THE ORIGINAL PERMIT
APPLICATION
(ISSUED OCTOBER 21,y 2011)

£� _
AQUIFER PROTECTION REGIONAL STAFF REPORT
Date: October 7, 2011 County: Mecklenburg
To: Aquifer Protection Central Office Permittee: Safety-Kleen Systems, Inc.
Central Office Reviewer: David Goodrich Project Name: Safety-Kleen Systems, Inc., Charlotte
Regional Login No: Application No.: WI0300181
L GENERAL INFORMATION -
1. This application is (check all that apply): ® New ❑ Renewal
❑ Minor Modification ❑ Major Modification
Surface Irrigation ❑ Reuse ❑ Recycle ❑ High Rate Infiltration ❑ Evaporation/Infiltration Lagoon
❑ Land Application of Residuals ❑ Attachment B included ❑ 503 regulated ❑ 503 exempt
❑ Distribution of Residuals ❑ Surface Disposal
❑ Closed -loop Groundwater Remediation ® Other Injection Wells (including in situ remediation)
Was a site visit conducted in order to prepare this report? ® Yes or ❑ No.
a. Date of site visit: 10/05/2011. Genna Olson (919-871-0999) is the contact for this site, but the MRO met
with Amanda Freeman (704-972-4077), as a local contact with ATC, Assoc.
b. Site visit conducted by: Maria Schutte
c. Inspection Report Attached: ❑ Yes or ® No.
2. Is the following information entered into the BIMS record for this application correct?
® Yes or ❑ No. If no, please complete the following or indicate that it is correct on the current application.
For Treatment Facilities:
a. - Location:
b. Driving Directions:
c. USGS Quadrangle Map name and number:
d. Latitude: Longitude:
e. Regulated Activities / Type of Wastes (e.g., subdivision, food processing, municipal wastewater):
For Disposal and Iniection Sites:
(If multiple sites either indicate which sites the information aDDlies to. conv and haste a new section into the
document for each site, or attach additional -pages for each site)
a. Location(s):
b. Driving Directions:
c. USGS Quadrangle Map name and number:
d. Latitude: Longitude:
II. & III. - deleted
IV. INJECTION WELL PERMIT APPLICATIONS (Complete these two sections for all systems that use injection
wells, including closed -loop groundwater remediation effluent injection wells, in situ remediation injection wells, and heat
pump injection wells.)
FORM: WI0300181 staff report Safety-Kleen Systems Facility - Meck Sept 20111
1

4
AQUIFER PROTECTION REGIONAL STAFF REPORT
Description Of Well(S) And Facilities — New, Renewal, And Modification
1. Type of injection system:
❑ Heating/cooling water return flow (5A7)
❑ Closed -loop heat pump system (5QM/5QW)
® In situ remediation (5I)
❑ Closed -loop groundwater remediation effluent injection (5L/"Non-Discharge")
❑ Other (Specify: )
2. Does system use same well for water source and injection? ❑ Yes ® No
3. Are there any potential pollution sources, that may affect injection? ® Yes ❑ No
What is/are the pollution source(s)? A former Mineral Spirits UST What is the distance of the injection well(s)
from the pollution source(s)? 0 ft.
4. What is the minimum distance of proposed. injection wells from the property boundary? —40 ft.
5. Quality of drainage at site: ❑ Good ® Adequate ❑ Poor
6. Flooding potential of site: ® Low ❑ Moderate ❑ High
7. For groundwater remediation systems, is the proposed and/or existing groundwater monitoring program
(number of wells, frequency of monitoring, monitoring parameters, etc.) adequate? ❑ Yes ® No. Attach
map of existing monitoring well network if applicable. If No, explain and recommend any changes to the
groundwater monitoring program: The current monitoring plan only calls for three samplings in the I" year.
The standard for UIC permits is 4 quarterly sampling events for the 1 st year. Maps do not show vertical extent
of contamination, TW-5 (a piezometer) extends to bedrock, which is fairly shallow in this area, but recent
sample analyses are unavailable because this well has been dry. The MRO would like to see a better well in
this area, if practical. The MRO wishes to add Iron and Sulfate to the list of analytes, to track the injectant.
Some of the wells proposed in the sampling plan are historically dry.
8. Does the map presented represent the actual site (property lines, wells, surface drainage)? ❑ Yes or ® No. If
no or no map, please attach a sketch of the site. Show property boundaries, buildings, wells, potential pollution
sources, roads, approximate scale, and north arrow. It is unclear if the fence line is the property line. The
property line is not defined on any of the maps.
Iniection Well Permit Renewal And Modification Only:
1. For heat pump systems, are there any abnormalities in heat pump or injection well operation (e.g. turbid water,
failure to assimilate injected fluid, poor heating/cooling)?
❑ Yes ❑ No. If Yes, explain:
2. For closed -loop heat pump systems, has system lost pressure or required make-up fluid since permit issuance
or last inspection? ❑ Yes ❑ No. If yes, explain:
FORM: W10300181 staff report Safety-Kleen Systems Facility - Meck Sept 20111 2

AQUIFER PROTECTION REGIONAL STAFF REPORT
3. For renewal or modification of groundwater remediation permits (of any type) will
continued/additional/modified iniections have an adverse impact on migration of the plume or management of
the contamination incident? ❑ Yes ❑ No. If Yes, explain:
4. Drilling contractor: Name: Probe Technologies (Push Points) and Geologic Exploration (Injection Wells)
Address:
Certification number: 2724-A and 2345
5. Complete and attach Well Construction Data Sheet.
V. EVALUATION AND RECOMMENDATIONS
1. Provide any additional narrative regarding your review of the application:
The facility operated an underground storage tank system to house waste mineral spirits from 1980-1985. The
waste mineral spirits and their former USTs are the focus of this proposal. There maybe two phases — the first
uses 14 direct push points to inject a mix of Sodium persulfate (2,208 lbs), Zero Valent Iron (1,054 lbs) and
Hydrogen Peroxide (1,458 gals of 2.5% solution) to depths of 15-25 ft bgs. The push points encompass the area
around MTV-4, starting about 20' west of this well and continuing northeast to MW-5, then turning northwest to
MW--2. Should results of the firstphase be less than desired, then the secondphase calls for 4 injections wells
(screened at 15-25ft) to be installed:- One near MW-4, the second in the vicinity ofMW-5 and the other two
between MW-5 and the MW-2, MW-2D group. The second phase proposes total injectant concentrations of.- 2,198
lbs of Sodium Persulfate, 594 lbs of ZVI and 1392 gals of 2.5% H2O2. Municipal water is available for mixing or
chase water as needed. According to this application, groundwater flow is NINE across the site with a velocity of
approx. 29' per year. There are not any WSWs within the 1500 ft buffer. Little Sugar Creek is approx. 900 ft West
i
and unlikely to be impacted by these injections. The proposed monitoring plan only calls for three sampling events
in the first year. The MRO recommends 4 quarterly events for the first year and the addition of Iron and d Sulfate
to the sampling protocol. TW-5 & TW-6 are part of the sampling plan, but the MRO believes they are of limited
use, as both are 1 " piezometers and when not already dry, then flow recharge is too slow to make sampling
practical. The�ould prefer to see a 2 " well between the injection area and the TW-5 location, but believes
limj ed drilling access may make this impractica . RO recommends approval ofpermit, with sampling changes
as noted.
2. Attach Well Construction Data Sheet - if needed information is available
3. Do you foresee any problems with issuance/renewal of this permit? ❑ Yes ® No. If yes, please explain
briefly.
4. List any items that you would like APS Central Office to obtain through an additional information request.
Make sure that you provide a reason for each item:
FORM: WI0300181 staff report Safety-Kleen Systems Facility - Meck Sept 20111
3

AQUIFER PROTECTION REGIONAL STAFF REPORT
Item Reason .
5. List specific Permit conditions that you recommend to be removed from the permit when issued. Make sure
that you provide a reason for each condition:
Condition Reason
6. List specific special conditions or compliance schedules that you.recommend to be included in the permit when
issued. Make sure that you provide a reason for each special condition:
Condition
Reason
Sample all proposed wells quarterly for the l st
Basic requirement of UIC permit
year
Add to sampling schedule: Iron and Sulfate to
Basic requirement of UIC permit
track injected material(s).
Intermediate MW between MW-4 and TW-5, if
TW-5 is dry and not a good proposal for the
practical for drilling access.
monitoring plan. A new 2"'well in this area
would better track contaminants and injectants.
7. Recommendation: ❑ Hold, pending receipt and review of additional information by regional office; ❑ Hold,
pending review of draft permit by regional office; ❑ Issue upon receipt of needed additional information;
Issue; ❑ Deny. If deny, please state reasons:
8. Signature of report preparer(s): Maria Schutte
oywiNsg�e byA d—Pima
AndrewPitner-•DMm-Mtlrew Pime.,o. o��wU-NPs,ema�ka�drewp�m�,®�Omgo..
Signature of APS regional supervisor:=
oace:2011a0a3 fzozeeaa•ao•
Date: October 7, 2011
ADDITIONAL REGIONAL STAFF REVIEW ITEMS
FORM: WI0300181 staff report Safety-Kleen Systems Facility - Meck Sept 20111 4

i
AQUIFER PROTECTION SECTION
APPLICATION REVIEW REOUEST FORM
Date: September 6, 2011
To: ❑
Landon Davidson, ARO-APS
❑
Art Barnhardt, FRO-APS
X
Andrew Pitner, MRO-APS
❑
Jay Zimmerman, RRO-APS
From: David Goodrich, Land Application Unit
Telephone: [phone]
E Mail: david.goodrichAncdenr.gov
A. Permit Number: WI0300181
B. Owner: Safetv-Kleen Systems, Inc.
C. Facility/Operation: Safety-Kleen Systems, Inc.
❑ Proposed X Existing
D. Application:
❑ David May, WaRO-APS
❑ Charlie Stehman, WiRO-APS
❑ Sherri Knight, WSRO-APS
Fax: [phone]
X Facility X Operation
1. Permit Type: ❑ Animal ❑ Surface Irrigation ❑
❑ Recycle ❑ I/E Lagoon X
❑ UIC - (5A7) open loop geothermal
For Residuals: ❑ Land App. ❑ D&M
❑ 503 ❑ 503.Exempi
Reuse ❑ H-R Infiltration
GW Remediation (ND)5I Injection
❑ Surface Disposal
❑ Animal
2. Project Type: X New II Major Mod. ❑ Minor Mod. ❑ Renewal ❑ Renewal w/ Mod.
E. Comments/Other Information: ❑ I would like to accompany you on a site visit.
Attached, you will find all information submitted in support of the above -referenced application for your
review, comment, and/or action. Within 30 calendar days, please take the following actions:
X Return a Completed APSARR Form. - Please comment
❑ Attach Well Construction Data Sheet.
❑ Attach Attachment B for Certification by the LAPCU.
❑ Issue an Attachment B Certification from the RO.*
* Remember that you will be responsible for coordinating site visits and reviews, as well as additional
information requests with other RO-APS representatives in order to prepare a complete Attachment B for
certification. Refer to the RPP SOP for additional detail.
When you receive this request form, please write your name and dates in the spaces below, make a copy
of this sheet, and return it to the appropriate Central Office -Aquifer Protection Section contact person
listed above.
RO-APS Reviewer:
Date:
FORM: APSARR 67/06 Page 1 of 1

Central Files: APS_ SWP_
09/06/11
Permit Number W10300181 Permit Tracking Slip
Program Category
Ground Water
Permit Type
Injection In situ Groundwater Remediation Well (51)
Primary Reviewer
david.goodrich
Coastal SW Rule
Permitted Flow
Facility
Status
Project Type
In review
New Project
Version
Permit Classification
Individual
Permit Contact Affiliation
Genna K. Olson
PG
Atc Associates Of N Carolina
Raleigh
NC 27604
Facility Name Major/Minor Region
Safety-Kleen Systems Inc Minor Mooresville
Location Address County
2320 Yadkin Ave Mecklenburg
Charlotte NC 28205 Facility Contact Affiliation
Owner Name Owner Type
Safety-Kleen Systems Inc Unknown
Owner Affiliation
Robert Schoepke
GP
1502 E Villa St 2nd Floor
Dates/Events Elgin IL 60120
Scheduled
Orig Issue App Received Draft Initiated Issuance Public Notice Issue Effective Expiration
09/01/11
Regulated Activities Reouested/Received Events
RO staff report requested
RO staff report received
Outfall NULL
Waterbody Name Stream Index Number Current Class Subbasin

North Carolina
Department of Health and Human Services
S! Division of Epidemiology
' P.O. Box 29601 • Raleigh, North Carolina 27626-0601
..;� �. Tel: [phone] Fax: [phone] ' G < <' I
James B: Hunt Jr., Governor - H. David Bruton, M.D., Secretary v d Vq 2� T v a-1
J. Steven Cline, DDS, MPH, Acting Director
October 2, 1998
c0
MEMORANDUM ` s
TO: Amy Axon -
Underground Injection Control Program --
Groundwater Section
FROM: , Luanne K. Williams, Pharm.D., Toxicologist
Medical Evaluation and Risk Assessment Branch
Occupational and Environmental Epidemiology Section
SUBJECT: Health Risk Evaluation Regarding the Use of Certain Products Manufactured by
Peerless Metal Powders and Abrasive in the Treatment of Groundwater at the
DuPont Kinston Plant in Lenoir County
I am writing in response to a request from Mr. Clifford Lee with DuPont for a health risk
evaluation regarding the use of certain products manufactured by Peerless Metal Powders and
Abrasive in the treatment of groundwater at the referenced site. Based upon my review of the
information submitted, I offer the following health risk evaluation:
WORKER PRECAUTIONS DURING APPLICATION
Some effects reported to be associated with the products proposed to be used are as
follows: eye, skin, nose, throat, and lung irritation. If the product is released into the
environment in a way that could result in a suspension of fine solid or liquid particles
(e.g., grinding, blending, vigorous shaking or nixing), then proper personal protective
equipment should be used. The application process should be reviewed by an industrial
hygienist to ensure that the most appropriate personal protective equipment is used.
2. Persons working with these products should wear goggles or a face shield, gloves, and
protective clothing. Face and body protection should be used for anticipated splashes or
sprays.
3. Eating, drinking, smoking, handling contact lenses, and applying cosmetics should not be
permitted in the application area during or immediately following application.
0
srm� ocirnei
North Carolina: Host of the 1999 Special Olympic World Summer Games

Amy Axon Memo
October 2, 1998
Page Two
4. Safety controls should be in place to ensure that the check valve and the pressure delivery
systems are working properly.
5. It is imperative that the Material Safety Data Sheets be followed to prevent incompatible
or adverse reactions and injuries.
OTHER PRECAUTIONS
1. Access to the area of application should be limited to the workers applying the product.
In order to minimize exposure to unprotected individuals, measures should be taken to
prevent access to\the area of application.
2. According to the information submitted with the letter dated September 18, 1998, "The
only groundwater production wells within one mile of the study area are DuPont Kinston
Plant wells (used for non -contact cooling water). The nearest public water supply well is
the City of Grifton Well No.2, located 3.4 miles to the northeast. The..... treatment wall
will be emplaced in the surficial aquifer at the site. This aquifer is not used as either a
public or private source of water; therefore, there will be no impact to any of the
identified wells (which pump groundwater from depths greater than 200 feet). DuPont
Kinston Plant potable water supply is provided by the local municipal water district."
In order to protect public health, it is recommended to confirm the absence of nearby well
users in the area. Measures should be taken to prevent contamination of existing or future
wells that may be located near the application area.
3. According to the information submitted, Beaverdam Branch is the nearest surface water
body located approximately 1,800 feet north of the study area. It is recommended to
contact Ms. Dianne Reid with the Water Quality Section at [phone] extension 568
to determine if these products or process could impact Beaverdam Branch.
If you have any questions, contact me at [phone].
LKW:dg
cc: Ms. Linda Blalock, Groundwater Section
Mr. Bob Cheek, Groundwater Section
Mr. Clifford Lee, DuPont Fibers
Dianne Reid, Water Quality Section

DIVISION OF WATER QUALITY
GROUNDWATER SECTION
April 2, 2002
u 1aml lmalaiJl
TO: UIC Files
FROM: . Evan Kane, Underground Injection Control Program Manager
RE: Epidemiology approval of hydrogen peroxide
Dr. Luanne Williams of DEH Occupational Epidemiology has reviewed the injection of hydrogen
peroxide as a component of the "GeoCleanse" process. On April 1, 2002, Dr. Williams called and
told me that her memo regarding the use of GeoCleanse was appropriate to use as documentation
for hydrogen peroxide alone as well.

e North Carolina
Department of Health and Human Services
Division of Epidemiology • Occupational & Environmental Epidemiology Section
P.O. Box 29601 • Raleigh, North Carolina 27626-0601
-�. Tel:[phone] Fax: [phone]
James B. Hunt Jr., Governor - H. David Bruton, M.D., Secretary - Chris Hoke, J.D., Acting Director
:_'n
co
June 3, 1998 =_ n
MEMORANDUM �
TO: Amy Axon
Underground Injection Control Programs"'
Groundwater Section
FROM: Luanne K. Williams, Pharm.D., Toxicologist�((,(r
Medical Evaluation and Risk Assessment Branch
Occupational and Environmental Epidemiology Section
SUBJECT: Health Risk Evaluation Regarding the Use of Certain Products with the
Geo-Cleanse R Technology in an In -Situ Groundwater Remediation
Project
I am writing in response to your request for a health risk evaluation regarding the
use of certain products with the Geo-CleanseR Technology in an in -situ groundwater
remediation project at the Marine Corps Air Station in Cherry Point, North Carolina.
Based upon my review of the information submitted, I offer the following health risk
evaluation:
WORKER PRECAUTIONS DURING APPLICATION
Some effects reported to be associated with the products proposed to be used
are as follows: eye, skin, nose, throat, and lung irritation. If the product is
released into the environment in a way that could result in a suspension of fine
solid or liquid particles (e.g., grinding, blending, vigorous shaking or mixing), then
proper personal protective equipment should be used. The application process
should be reviewed by an industrial hygienist to ensure that the most appropriate
personal protective equipment is used.
2. Persons working with these products should wear goggles or a face shield,
gloves, and protective clothing. Face and body protection should be used for
anticipated splashes or sprays.
3. Eating, drinking, smoking, handling contact lenses, and applying cosmetics
should not be permitted in the application area during or immediately following application.
North Carolina: Host of the 1999 Special Olympic World Summer Games

Amy Axon Memo
June 3, 1998
Page Two
4. Safety controls should be in place to ensure that the check valve and the
pressure delivery systems are working properly.
5. It is imperative that the Material Safety Data Sheets be followed to prevent
incompatible or adverse reactions and injuries.
OTHER PRECAUTIONS
1. Access to the area of application should be limited to the workers applying the
product. In order to minimize exposure to unprotected individuals, measures
should be taken to prevent access to the area of application.
2. According to the information submitted with the letter dated April 3, 1998, "two
water supply wells are located adjacent to each other, upgradient and 2,500 feet
west of the site. These wells produce non -potable water for fire protection
aboard the Air Field. Groundwater flows to the east. Potable water for the area
is supplied by the Marine Corps Air Station Bogue Field water supply system. -
The location of this public water supply was not provided, and the location of the
nearest private drinking water well was not provided. In the absence of this
information, measures should be taken to prevent contamination of existing or
future wells that may be located near the application area.
3. According to the information submitted, Goose Creek is located approximately
2,000 feet east of the site. It is recommended to contact Ms. Dianne Reid with
the Water Quality Section at [phone] extension 568 to determine if these
products or process could impact Goose Creek.
If you have any questions, contact me at [phone].
LKW:lp
cc: Ms. Linda Blalock, Groundwater Section
Mr. Bob Cheek, Groundwater Section
Ms. Patricia Coughlin, NCDENR DWQ
Mr. Kenneth Cobb, USMC
James A. Dunn, Jr., P.E., OHM Remediation Services Corp.
Dianne Reid, Water Quality Section
GEOCLEAKRA

e,x SiAlto�
a
North Carolina Department of Health and Human Services
Division of Public Health a Office of the State Health Director
1931 Mail Service Center • Raleigh, North Carolina 27699-1931
Beverly Eaves Perdue, Governor
Lanier M. Cansler, Secretary
September 25, 2009
MEMORANDUM
To: Thomas Slusser
Aquifer Protection System
Division of Water Quality
Department of Environment and Natural Resources
From: Sandy Mort
Epidemiology Section
Division of Public Health
Department of Health and Human Services
Jeffrey P. Engel, M.D.
State Health Director
Subject: Use of Klozur CR blend of sodium persulfate and calcium peroxide for
groundwater/soil remediation
N.C. DPH has reviewed the information provided for the Klozur CR blend of Iftsodium persulfate
and44M calcium peroxide for use in groundwater or soil remediation. APS states the Klozur CR
blend is a re-formulation of the OBC sodium persulfate and calcium peroxide blend that DPH
reviewed on August 25, 2008. That review identified a"calcium peroxide and � sodium
persulfate blend. As the Klozur CR blend is a modified proportion of the same two primary
components as the OBC blend, the health risk evaluation prepared for the OBC blend also applies to
Klozur CR. DPH recommends that the same handling and exposure concerns provided for the OBC
blend be followed for the Klozur CR blend.
Please contact me by telephone at 919-707-5912 or at sandy.mort(- ,dhhs.nc. ov if you need any
additional information.
North Carolina Public Health
�� Workeng fwa heahhmr and safer North Carohna
tvc"he— Everyday. Everybody.
Location: 5605 Six Forks Rd., Ist Floor, •Raleigh, N.C. 27609-3811
An Equal Opportunity Emplover

aSAT[o
�r.
North Carolina Department of Health and Human Services
Division of Public Health — Epidemiology Section
Occupational and Environmental Epidemiology Branch
1912 Mail Service Center • Raleigh, North Carolina 27699-1912
Telephone:[phone] Fax: [phone]
Michael F. Easley, Governor
Dempsey Benton, Secretary
August 25, 2008
To: Qu Qi — UIC Program
Aquifer Protection System
Division of Water Quality
Department of Environment and Natural Resources
From: Sandy Mort
Epidemiology Section
Division of Public Health
Department of Health and Human Services
Subject: Health Risk Assessment
Leah Devlin, DDS, MPH
State Health Director
AQ(/R;: IVED /DENR/DWQ
RnTFrrin�,'SFr710M
AVG 2 7 2008
Use of calcium peroxide or sodium hydroxide as activator for
groundwater/soil remediation with sodium persulfate
The following information is provided in response to Aquifer Protection Section's (APS)
request for a health risk evaluation regarding the use of sodium persulfate with calcium
peroxide or sodium hydroxide as activators for groundwater or soil remediation. These
chemicals are proposed for use at a Duracell battery manufacturing site contaminated
with chlorinated hydrocarbons, petroleum hydrocarbons, acetone, and carbon
tetrachloride. This review is provided as supplemental information to that provided to
APS in September 2003 by DPH regarding the use of hydrogen peroxide and iron-EDTA
activators with sodium persulfate.
The information provided to DPH indicates that calcium peroxide will be used at a
proportion of 20% calcium peroxide and 80% sodium persulfate. This mixture is diluted
to 30%, resulting in approximately 6% calcium peroxide and 24% sodium persulfate in
70% water. The information also states that sodium hydroxide will be used at 1 to 5%
with 30% sodium persulfate.
k-
North Carolina Public Health
Working for a healthier and safer North Carolina
Everywhere. Everyday. Everybody.
Location:
5505 Six Forks Rd., 2nd Floor, Room 1-2-DI •Raleigh, NC 27609
An Equal Oppat niiyE"pla)er

Page 2 of 9
NC DPH recommends that all persons that will come into contact with the above
chemicals review the MSDS and other appropriate health and safety documents and have
undergone appropriate health and safety training. NC DPH also recommends that
transport of these chemicals off -site be controlled to prevent potential human or
ecological impacts. Access to the area of application should be limited to workers
applying the product. In order to minimize exposure to unprotected individuals,
measures should be taken to prevent access to the area of application.
SODIUM PERSULFATE HEALTH RISK INFORMATION:
Formula: Na2S203
CASN: 7775-27-1
Synonyms: Sodium peroxydisulfate, Sodium persulfate
Classification: strong oxidant
Sodium persulfate is a strong oxidant and reacts with combustible and reducing
materials. Sodium persulfate decomposes on heating producing toxic and corrosive fumes
including sulfur oxides. It reacts violently with powdered metals and strong bases. In
solution in water it is a weak acid. Sodium persulfate becomes unstable when exposed to
heat, moisture and/or contamination. It is incompatible with acids, alkalis, halides
(fluorides, chlorides, bromides and iodides), combustible materials, most metals and
heavy metals, oxidizable materials, other oxidizers, reducing agents, cleaners, and
organic or carbon containing compounds. Oxidizing chemicals, including sodium
persulfate, should not be stored or directly mixed with combustible material (such as
fuels, papers or solvents) or reducing agents (such as metals or sulfites). Contact with
incompatible materials can result in a material decomposition or other uncontrolled
reactions. Oxidizing chemicals may react energetically with combustible materials or
reducing agents and also release oxygen and heat during decomposition that could help
support a fire. Some oxidizing agents are incompatible with one another: Decomposing
persulfates will evolve large volumes of gas and/or vapor, can accelerate exponentially
with heat generation, and create significant and hazardous pressures if contained and not
properly controlled or mitigated. Use with alcohols in the presence of water has been
demonstrated to generate conditions that require rigorous adherence to process safety
methods and standards to prevent escalation to an uncontrolled reaction.
Potential health effects: The primary route of toxicity is through direct inhalation of
airborne dust or mist, or direct contact. Airborne persulfate dust may be irritating to eyes,
nose, lungs, throat and skin upon contact. Dust dispersion should be controlled. Sodium
persulfate in identified as a strong oxidizer and an irritant. Inhalation of dust may cause
asthma -like reactions. Acute (short-term) health effects that may occur immediately or
shortly after exposure include severe skin and eye irritation and bums. Breathing sodium
persulfate can irritate the nose, throat and lungs, causing coughing, wheezing and/or
shortness of breath. Long-term (chronic) or repeated exposure may cause a skin
allergy or dermatitis. If allergy develops, very low future exposure can cause itching and
a skin rash. An asthma -like allergy may also result from long-term or repeated inhalation
exposures with future exposure potentially causing asthma attacks with shortness of
Location: 5505 Six Forks Rd., 2nd Floor, Room 1-2-DI • Raleigh, N.C. 27609 -A
!�•.� �••a•;�'� An Equal Opportunio, Employer

Page 3 of 9'
breath, wheezing, cough, and/or chest tightness. General allergic reactions, like urticaria
(hives) or shock, may occur. Sodium persulfate has not been tested for its ability to cause
cancer or reproductive effects.
Evidence of exposure includes:
Inhalation: cough, labored breathing, sore throat, wheezing
Skin: redness, pain
Eyes: redness, pain
Ingestion: diarrhea, nausea, sore throat, vomiting
Recommended personal protective equipment (PPE): Prevent release of dust into the
work environment with room ventilation. All persons working with sodium persulfate
should use appropriate PPE, including:
Eves and face: Use cup type chemical goggles. Full face shield may be used.
Respiratory: Use approved dust respirator when airborne dust is expected. A NIOSH 100
HEPA tight -fitting half -face unit is recommended (with fit testing).
Protective clothing: Normal work clothes. Rubber or neoprene footwear.
Gloves: Rubber or neoprene gloves. Thoroughly wash the outside of gloves with soap
and water prior to removal. Inspect regularly for leaks.
First Aid:
Eve contact: Immediately flush with large amounts of water for at least 15 minutes,
occasionally lifting upper and lower lids. Seek medical attention immediately.
Skin Contact: Quickly remove contaminated clothing. Immediately wash contaminated
skin with large amounts of soap and water.
Breathing: Remove the person from exposure. Begin rescue breathing (using universal
precautions) if breathing has stopped and CPR if heart action has stopped. Transfer
promptly to a medical facility.
Additional safety recommendations: Prevent release of dust into the work environment
with room ventilation. Workers whose clothing has been contaminated with sodium
persulfate should change into clean clothing promptly. On skin contact immediately
wash or shower to remove the chemical. Remove contaminated clothing immediately
and wash before reuse. At the end of the work shift, wash any areas of the body that may
have contacted sodium persulfate, whether or not known skin contact has occurred. Do
not take contaminated work clothes home to prevent exposure of family members.
Contaminated work clothes should be laundered by individuals who have been informed
of the hazards of exposure to sodium persulfate.
Eye wash fountains should be provided in the immediate work area for emergency use. If
there is the possibility of skin exposure, emergency shower facilities should be provided.
Do not eat, smoke, or drink where sodium persulfate is handled, processed, or stored,
since the chemical can be swallowed. Wash hands carefully before eating, drinking,
smoking, or using the toilet.
Handling and storage: Use adequate ventilation when transferring product from bags or
drums. Provide mechanical general and/or local exhaust ventilation to prevent release of
�G OIv410
GJ" Location: 5505 SLrForks Rd., 2"`rFloor, Room 1-2-DI •Raleigh, N.C. 27609 C
,.�, ��'� An Equal Opportunity Employer If"

Page 4 of 9
dust into work environment. Spills should be collected into suitable containers to prevent
dispersion into the air. Wear respiratory protection if ventilation is inadequate or not
available. Use eye and skin protection. Use clean plastic or stainless steel scoops only.
Store (unopened) in a cool, clean, dry place away from point sources of heat, e.g. radiant
heaters or steam pipes. In case of fire or decomposition (fuming/smoking) deluge with
plenty of water to control decomposition. Use a vacuum or a wet method to reduce dust
during clean-up. DO NOT DRY SWEEP.
CALCIUM PEROXIDE HEALTH RISK INFORMATION:
Formula:
Ca02
CASN:
1305-79-9
Synonyms:
calcium dioxide, calcium superoxide, Calper, Calper G
Classification:
oxidizer
Calcium peroxide is an oxidizer, thus contact with combustible materials (paper, cotton,
organics, leather, reducing agents, and other oxidizers) should be avoided.' Calcium
peroxide is not flammable but will contribute oxygen to feed a fire. Contamination, heat,
and humid conditions will enhance and accelerate decomposition. Decomposition is
endothermic, unlike most oxidizers. Store calcium peroxide in a clean, dry place. Do not
expose to heat sources or high humidity. Store away from combustible materials. Keep
containers closed when not in use. Dilute spills with water.
Potential health effects: Contact can severely irritate and burn the skin and eyes with
possible eye damage. Breathing calcium peroxide can irritate the nose, throat and lungs
causing coughing, wheezing and/or shortness of breath. Harmful if swallowed. The
following acute (short-term) health effects may occur immediately or shortly after
exposure. Contact can severely irritate and burn the skin and eyes with possible eye
damage. Breathing calcium peroxide can irritate the nose, throat and lungs causing
coughing, wheezing and/or shortness of breath. Chronic (long-term) health effects can
occur at some time after exposure and can last for months or years and include lung
irritation. Repeated exposure may cause bronchitis with cough, phlegm, and/or shortness
of breadth. Calcium peroxide has not been tested for its ability to cause cancer or
reproductive effects. Calcium peroxide should be handled in well ventilated, dust
controlled areas. When handling large quantities, use a dust mask, goggles, and gloves.
Evidence of exposure includes:
Inhalation: nose and throat irritation
Skin: irritation
Eyes: irritation
Ingestion: irritation of mouth and stomach
Recommended personal protective equipment (PPE): Avoid skin contact with
calcium peroxide.
Eves and face: Wear chemical safety goggles. Wear a face shield along with goggles
when working with corrosive, highly irritating or toxic substances.
An Equal Opportunity EmployerLocation: 5505 Six ForksRd., 2"d Floor, Room 1-2-D] • Raleigh, N. C_ 27609 4A nv �'�k-
,,,,,

Page 5 of 9'
Respiratory: Use NIOSH certified toxic dust respirator. A NIOSH 100 HEPA tight-
fitting half -face unit is recommended (with fit testing).
Protective clothing: Wear protective gloves and full cover clothing
All protective clothing (suits, gloves, footwear, headgear) should be clean, available each
day, and put on before work.
First Aid:
Eves: Immediately flush with water for at least 15-30 minutes, lifting the upper and lower
eyelids intermittently. See a medical doctor or ophthalmologist immediately.
Skin: Remove contaminated clothing. Wash with plenty of soap and water. Get medical
attention if irritation occurs and persists.
Ingestion: If conscious rinse mouth with water. Dilute by giving 1 or 2 glasses of water or
milk. Do not induce vomiting. See a medical doctor immediately.
Inhalation: Remove to fresh air. If breathing difficulty or discomfort occurs and persists,
obtain medical attention.
Additional safety recommendations: Workers whose clothing has been contaminated
by calcium peroxide should change into clean clothing promptly. Do not take
contaminated work clothes home. Family members could be exposed.
Contaminated work clothes should be laundered by individuals who have been informed
of the hazards of exposure to calcium peroxide.
Eye wash fountains should be provided in the immediate work area for emergency use. If
there is the possibility of skin exposure, emergency shower facilities should be provided.
On skin contact with calcium peroxide, immediately wash or shower to remove the
chemical.
Do not eat, smoke, or drink where calcium peroxide is handled, processed, or stored,
since the chemical can be swallowed. Wash hands carefully before eating, drinking,
smoking, or using the toilet.
Use a vacuum or a wet method to reduce dust during clean-up. DO NOT DRY SWEEP.
Handling and storage: Calcium peroxide must be stored to avoid contact with
combustibles; hydrocarbons; fuels; cellulose; hydrogen peroxide; and organic materials
since fires may occur. Store in tightly closed containers in a cool, well -ventilated area.
SODIUM HYDROXIDE HEALTH RISK INFORAMTION:
Formula:
NaOH
CASN:
1310-73-2
Synonyms:
Caustic soda, Lye, Soda lye, Sodium hydrate
Classification:
alkaline, corrosive .
NG DIrI.lo�ol
Location: 5505 Six Forks Rd., 2"d Floor, Room 1-2-DI •Raleigh, N.C. 27609
,�..,�'� An Equal Opportunity Employer 'r(

Page 6 of 9
Sodium hydroxide is classified as a corrosive material. Sodium hydroxide is
incompatible with water, acids, flammable liquids, organic halogens, organic peroxides,
metals such as aluminum, tin, zinc, or nitromethane. It is corrosive to metals. Keep this
compound separated from acids, easily ignitable materials, explosives, metals, organic
peroxides, and water or any moisture. Sodium hydroxide will react with water to release
heat and contact with aluminum, tin, lead and zinc will release flammable and explosive
hydrogen gas. Contact with nitromethane and other nitro compounds may result in the
formation of shock -sensitive or explosive salts. Contact with moisture or water may generate
sufficient heat to ignite combustible substances.
Potential health effects: Sodium hydroxide is a corrosive irritant of the skin, eyes, and
mucous membranes. Sodium hydroxide both in solid and in solution has a markedly
corrosive action upon all body tissues causing burns and frequently deep maceration,
with ultimate scarring. Inhalation of the dust or concentrated mist can cause damage to
the upper respiratory tract and to lung tissue, depending upon the severity of the
exposure. Effects of inhalation may vary from mild irritation of the mucous membranes
at 2 mg/m3 to severe pneumonitis at higher airborne concentrations. Inhalation of
alkaline vapors can produce upper airway edema, respiratory failure, wheezing,
pulmonary edema, and pneumonitis. Exposure to the dust or mist may cause pain,
redness, irritation or full thickness burns. Contact with the eyes causes disintegration and
sloughing of conjunctival and corneal epithelium, corneal opacification (renders the
cornea opaque), marked edema, and ulceration. Permanent visual loss may occur. After 7
to 13 days, either gradual recovery begins, or there is progression of ulceration and
corneal opacification. On the skin, solutions of 25 to 50% sodium hydroxide cause a
sensation of irritation within about 3 minutes; with 4% solutions, irritation does not
develop for several hours. If it is not removed from the skin, severe burns with deep
ulceration may occur. Produces severe abdominal pain, corrosion of the lips, mouth,
tongue, esophagus, and pharynx, and the vomiting of large pieces of mucosa. It can cause
perforation and scarring. Glottic edema and upper airway obstruction may occur
following ingestion. Cases of squamous cell carcinoma of the esophagus have occurred
with latent periods of 12 to 42 years after ingestion. These cancers were the sequelae of
tissue destruction and possible scar formation, rather than due to a direct carcinogenic
action of sodium hydroxide itself. The greatest industrial hazard is rapid tissue
destruction of eyes or skin upon contact with either the solid or concentrated solutions.
Acute (short-term exposure) health effects which may occur immediately or shortly
after exposure include with contact severe irritation and burning the skin and eyes with
possible eye damage or clouding of the eyes with loss of vision. Breathing sodium
hydroxide can irritate the mouth, nose and throat. Breathing can also irritate the lungs
causing coughing and/or shortness of breath. Higher exposures can cause a build-up of
fluid in the lungs (pulmonary edema), a medical emergency, with severe shortness of
breath. Chronic (long-term exposure) health effects can occur at some time after
exposure to and can last for months or years. Very high chronic exposure may cause lung
damage. Sodium hydroxide has not been tested for ability to cause cancer in animals.
There is no evidence it effects reproduction.
G Location: 5505 Six Forks, Rd., 2nd Floor, Roam 1-2-D] • Raleigh, N.C. 27609
.,.r,: �An Equal Opportunity Employer

Page 7 of 9•
Evidence of exposure includes:
Inhalation: irritation of mucous membranes, pneumonitis
Skin: irritation, burns, temporary loss of hair
Eyes: irritation, corneal damage
Ingestion: irritation of mucous membranes, severe abdominal pain, corrosion of
the lips, mouth, tongue, and pharynx, and the vomiting of large pieces
of mucosa, upper airway obstruction may occur
Workplace exposure limits:
These exposure limits are for air levels only.
OSHA: The legal airborne permissible exposure limit (PEL) is 2 mg/m3 averaged over
an 8-'hour work shift.
NIOSH: The recommended airborne exposure limit is 2 mg/m3, which should not be
exceeded at any time. The NIOSH IDLH value is 10 mg/m3.
ACGIH: The recommended airborne exposure limit is 2 mg/m3, which should not be
exceeded at any time.
Recommended personal protective equipment (PPE): Appropriate, impervious,
protective clothing (including gloves) should be worn to prevent skin contact. Protective
equipment should not be made of aluminum, copper, soft iron, tin, or zinc (or alloys
made of these metals.
Eves and face: For solid sodium hydroxide wear impact resistant eye protection with side
shields or goggles. For liquids wear indirect -vent, impact and splash resistant goggles. A
face shield along with goggles is recommended when working with corrosive, highly
irritating or toxic substances. Contact lenses should not be worn when working with this
substance. Eyewash fountains should be provided.
Respiratory: Use NIOSH certified toxic dust respirator. A NIOSH 100 HEPA tight- .
fitting half -face unit is recommended (with fit testing). Where the potential exists for
exposure over 2 mg/m3, use a MSHA/NIOSH approved supplied -air respirator with a full
face -piece operated in a pressure -demand or other positive -pressure mode. For increased
protection use in combination with an auxiliary self-contained breathing apparatus
operated in,a pressure -demand or other positive -pressure mode. Exposure to 10 mg/m3 is
immediately dangerous to life and health. If the possibility of exposure above 10 mg/m3
exists, use a MSHA/NIOSH approved self-contained breathing apparatus with a full face
piece operated in a pressure -demand or other positive -pressure mode.
Gloves: Impervious. ACGIH recommends polyvinyl chloride, butyl, butyl/neoprene,
natural rubber, neoprene, polyethylene, Saranex; Teflon and Viton/neoprene as protective
materials.
First Aid:
Eves: Irrigate immediately
Skin: Water flush immediately. Clothing which becomes significantly contaminated, or
wet, should be removed as quickly as possible.
Breathing: Respiratory support
Ingestion: Medical attention immediately
ap ownr,� p .
�w
r L= Location: 5505 Sir Forks Rd., 2"A Floor, Room 1-2-DI •Raleigh, N.C. 27609
.s.,.weuu'a An Equal Opportunity Employer-

Page 8 of 9
Handling and storage: Store in tightly closed containers in a cool, dry, well -ventilated
area away from moisture. Wherever sodium hydroxide is used, handled, manufactured,
or stored, use explosion -proof electrical equipment and fittings. Keep sodium hydroxide
separated from acids, easily ignitable materials, explosives, metals, organic peroxides,
and water (or any moisture).
Additional safety recommendations: Workers whose clothing has been contaminated
by sodium hydroxide should change into clean clothing promptly. Do not take
contaminated work clothes home. Family members could be exposed.
Contaminated work clothes should be laundered by individuals who have been informed
of the hazards of exposure to sodium hydroxide.
Eyewash fountains should be provided in the immediate work area for emergency use.
If there is the possibility of skin exposure, emergency shower facilities should be
provided. On skin contact sodium hydroxide, immediately wash or shower to remove the
chemical. At the end of the work shift, wash any areas of the body that may have
contacted sodium hydroxide, whether or not known skin contact has occurred.
Do not eat, smoke, or drink where sodium hydroxide is handled, processed, or stored,
since the chemical can be swallowed. Wash hands carefully before eating, drinking,
smoking, or using the toilet.
For solid sodium hydroxide use a vacuum to reduce dust during clean-up. DO NOT DRY
SWEEP.
r(rS; Location: 5505 Six Forks Rd., 2nd Floor, Room 1-2-D1 •Raleigh, N.C. 27609
.�"�.'�"� An Equal Opportunity Employer

Pag.:'9 of 9 -
I
References:
1. International Chemical Safety Cards (ICSCs): International Programme on Chemical
Safety. -CDC, NIOSH. http://www.cdc.gov/niosh/ipcs/icstart.html
2. New Jersey Department of Health and Senior Services Hazardous Substances Fact
Sheets.
3. Sodium Persulfate MSDS. FMC MSDS no.: 7775-27-4, April 30, 2006, revision no. 12.
G
FMC Corporation.
Calcium Peroxide Technical Data Sheet. FMC Corporation.
TOXNET Toxicology Data Network. US National Library of Medicine.
http://toxnet.nlm.nih.gov/
Calcium Peroxide MSDS. FMC MSDS no.: 1305-79-9-1, April 30, 2006, revision no. 9.
FMC Corporation..
Thomson MICROMEDEX.
NIOSH Pocket Guide to Chemical Hazards. CDC.
Technical and Regulatory Guidance for In Situ Chemical Oxidation of Contaminated Soil
and Groundwater, Second Edition. The Interstate technology & Regulatory Council In
Situ Chemical Oxidation Team. January 2005. htti)://www.itrcweb,.org/Documents/ISCO-
2.pdf
Location: 5505 Six Forks Rd., 2"`Floor, Room 1-2-D] •Raleigh, N.C- 27609
An Equal Opportunity Employer

(V(ATC
ATC ASSOCIATES OF NORTH CAROLINA, P.C.
Engineering Individual Solutions
April 10, 2012
Mr. David Goodrich
NCDENR Division of Water Quality
Aquifer Protection Section, UIC Program
1636 Mail Service Center
Raleigh, North Carolina 27699-1636
RE: Injection Permit WI0300181
Safety-Kleen Service Center
2320 Yadkin Avenue
Charlotte, North Carolina
EPA ID No. NCD 079060059
ATC Project No. 45.16031.0007
Dear Mr. Goodrich:
2725 East Millbrook Road
Suite 121
Raleigh, NC 27604
Tel: [phone]
Fax:[phone]
www.atcassociates.com
N.C. Engineering License No. C-1598
RECEIVEDIDENR/M
APR, 13 2012
Aquifer Protection Section
ATC Associates of North Carolina, P.C. (ATC) on behalf of Safety-Kleen Systems, Inc. (S-K), is
submitting an Injection Event Record per the requirements of Modified Injection Well Permit
WI0300181 issued on February 28, 2012. Twelve permanent injection wells (IW-1S through
IW-6S and IW-1D through IW-6D) were installed on March 14 and 15, 2011 and utilized for the
injection event that took place on March 20, 2012. A mixture of sodium persulfate (Klozur) and
hydrogen peroxide were injected during the event. Attachment 1 contains the Injection Event
Record form. Attachment 2 contains the Field Summary Report prepared by Innovative
Environmental Technologie, Inc., the injection contractor for this project. Attachment 3 contains
the injection well construction records. A separate report will be submitted at a later date
containing pre and post -injection groundwater monitoring data and additional details regarding
the injection activities.
If you have questions or require additional information, please do not hesitate to contact us at
[phone].
Sincerely,
ATC Associates of North Carolina, P.C.
00'6r�
Justin C. Ballard P.G. lor
soar
Project Geologist 4emoroject Manager
Attachments:
Attachment 1 — Injection Event Record
Attachment 2 — Field Summary Report
Attachment 3 — Well Construction Records

ATTACHMENT 1
INJECTION EVENT RECORD

INJECTION EVENT RECORD
North Carolina Department of Environment and Natural Resources — Division of Water Quality
Permit Number WI0300181
1. Permit Information
Safety-Kleen Systems, Inc.
Permittee
Safety-Kleen Service Center
Facility Name
2320 Yadkin Ave, Charlotte, NC
Facility Address
2. Injection Contractor Information
ATC Associates of NC, PC
Injection Contractor / Company Name
2725 East Millbrook Road
Street Address Suite 121
Raleigh NC 27604
City State Zip Code
[phone]
Area code — Phone number
3. Well Information
Number of wells used for injection 12
Well names IW-IS/IW-1D through IW-6S/IW-6D
Were any new wells installed during this injection
event?
N Yes ❑ No
If yes, please provide the following information:
Number of Monitoring Wells
Number of Injection Wells 12
Type of Well Installed (Check applicable type):
❑ Bored ® Drilled ❑ Direct -Push
❑ Hand -Augured ❑ Other (specify)
Please include two copies of form GW-1 b for each
well installed.
Were any wells abandoned during this injection
event?
❑ Yes ® No
If yes, please provide the following information:
Number of Monitoring Wells
Number of Injection Wells
Please include two copies of the GW-30 for each
well abandoned.
4. Injectant Information
3,621 LBS persulfate(Klozur);
97 gallons hydrogen peroxide
Injectant Type
Concentration See Attached IET Field Report
If the injectant is diluted please indicate the source
dilution fluid. Charlotte -Mecklenburg Utilities
Total Volume Injected 1,897 gallons
Volume Injected per well See Attached IET Field Report
5. Injection History
Injection date(s) 3/20/2012
Injection number (e.g. 3 of 5) 2 of 2
Is this the last injection at this site?
N Yes ❑ No
I DO HEREBY CERTIFY THAT ALL THE
INFORMATION ON THIS FORM IS CORRECT TO
THE BEST OF MY KNOWLEDGE AND THAT THE
INJECTION WAS PERFORMED WITHIN THE
STANDARD IN THE PERMIT.
fd 12
S O JECTION CONTRACTOR DA
Justin C. Ballard, P.G.
PRINT NAME OF PERSON PERFORMING THE INJECTION
Submit the original of this form to the Division of Water Quality within 30 days of injection. Form UIC-IER
Attn: UIC Program, 1636 Mail Service Center, Raleigh, NC 27699-1636, Phone No..919-733-3221 Rev. 07/09

ATTACHMENT 2
FIELD SUMMARY REPORT

INNOVATIVE ENVIRONMENTAL TECHNOLOGIES, INC.
Technology Discussion and Field Report
Hydroxyl and Sulfate Free Radical Oxidation
To
ATC
For
Safety Kleen
Charlotte, NC
March 2012
Innovative Environmental Technologies, Inc.
6130 Kit Road
Pipersville, PA
WWWAET-INCAET

r
EXECUTIVE SUMMARY
On behalf of ATC, Innovative Environmental Technologies, Inc (IET) has prepared the
following injection report. This report has been prepared to document remediation .
activities conducted at the Safety Kleen site in Charlotte, NC.
This report includes the documentation'of a, total of 12 injection. events completed in:
IW=4, IW-2, IW-3, IW-4, IW-5. and IW-6.
The injection program was implemented on March, 20 2012. The remedial approach
employed . the integration of both Fenton's chemistry and . persulfate chemistry The
integration of these'two chemistries shall allow for synergistic reactions and long :lasting,.
(via persulfate) oxidation. .
During the first phase of the. injection .implementation process, most .areas within the . .
targeted media were not accessible. using direct push equipment due to refusal in several
areas within the treatment zone. As a result IET recommended the installation of
permanent injection wells screened across the targeted intervals. -from 15-25.' bgs.
3,621 pounds of Sodium Persulfate mixed with approximately 1,950 gallons of oxidative
solution -created with 97 gallons of 50% hydrogen peroxide solution was injected across
two.targeted intervals, the shallow zone from 15-18' bgs; and the deep zone from 21.-25'
bgs. All proposed materials were injected at these, depths with the exception of IW-1S
which was installed at the depth of 11=14' bgs. In order to influence the deeper zone in
the.area around IW-1S.without having to re. -install the well, IET attempted to add more
material between IW-lS and the adjacent shallow well, IW 2S which was installed at the
proposed 154 8' depth. These adjusted volumes are reflected upon in the attached
injection logs.
T"LE:1
Originally Proposed (15-25')
Injected Amounts (11-25')
Pounds of SodiumPersulfate
3,300
3,621
Gallons of 50% Peroxide
74
97
Pounds of ZVI
1050
0
Total Gallons
3,100 .
1,800

INTRODUCTION
The Safety Kleen site located in Charlotte, NC, was identified by ATC, their consulting
engineer, as having soils and groundwater impacted by the historical release. of CVOC's.
The: primary .compound .of concern at the site was 1,1 DCA . An injection program was
proposed .by IET for the remediation of residual .levels of CVOC ,impacts at the site
utilizing advanced oxidation technologies.
REMEDIATION IMPLEMENTATION
1.1 INJECTION PROCEDURES
IET completed d.total of.12 injections at the Safety Kleen site. Injection logs are provided
in the Appendix.
Permanent Well Injection
I�
Six sets of nested injection wells were installed at the site for application of the oxidation
solution. The shallow wells were screened from 15-18' bgs, and the deep wells were
screened from. 2125' bgs. See the construction diagram in figure L .
i

Figure 1: Well Construction
LOCKABLE WELL CAP
MONITORING
WELL CONSTRUCTION DETAILS
FLUSH GRADE MANHOLE
CROSS SECTIONAL VIEW
(NOT TO SCALE)
k'
CONCRETE PAD
PAD DIMENSIONS 2 feet x 2 feet
HEIGHT ABOVE GROUND flush mounted
WELL CASING
MATERIAL sch 40 PVC
DIAMETER 1 inch
JOINT TYPE flush threaded
LENGTH 15 & 21 feet
BACKFILL AROUND CASING
MATERIAL cement -sand grout
THICKNESS 13 feet
SEAL
TYPE OF SEAL bentonite
THICKNESS 2 & 2 feet
FILTER PACK
_
TYPE OF FILTER pea gravel
DISTANCE ABOVE SCREEN 1 feet
WELL SCREENS
SCREEN MATERIAL sch 40 PVC
DIAMETER 1 inch
LENGTH 3 & 4 feet
SLOT SIZE 0.030 inches
DEPTH TO BOTTOM OF
INJECTION WELLS 18 & 25 feet
DEPTH TO BOTTOM OF
BOREHOLE 25 feet
DIAMETER OF BOREHOLE 6 inches

t
Oxidation Technique
Subsurface Fracture
Compressed 'air was used to propel all injectants into the subsurface. Compressed air was
first injected into.the subsurface at approximately 75 pounds per square inch (psi) until a
significant pressure drop was observed at the injection pressure vessel. This process is
referred to as pathway development. The intent of this step is to open pathways in. the
subsurface for theinjectants to follow. These pathways are believed to be those more
permeable pathways along which CVOCs are more likely. to have migrated, both in the
vadose and saturated zones. Liquid and liquid -entrained injectants are then delivered with
pressurized gas to the pathways that were produced during the development step.
I
Sodium Persulfate and Hydrogen Peroxide Injection
-A predetermined volume of an either 2.5% or 5% solution of H202.-followed this step.
Immediately following, under constant pressure a sodium persulfate solution was then
introduced.
Liquid Rinse
A small amount of water was injected to clear the injection lines of the .chemical oxidants
and promotes mounding of groundwater into the vadose zone.
Post Injection Line Purge
Compressed air was injected to clear the lines of all material and. to force the remedial
components further into the formation before moving to the next injection location.

The injection locations are identified in the appendix by alphanumeric labels beginning
with IW-1 and ending with IW-6, as seen in Figure 2.
Figure 2: Injection locations
!Me MRt N wjeiHM PW eARYVe b '.. ..
VN-3 EPeed e1Mta1 CNK4"wn a!
C!:t:a oEw pl SierwaMR '� .etl kW-7. '
aY 3 Si e ro e, q! D,.e ROmpx„q
r+Mrte wc+eM, otan. � w Yu.w-.rt,
RrN: I OM[RFR — I
MICE
i
15-25' Treatment Area
Ap x`In
9 Sq. Ft.
WAREHOUSE 1 ---1 T — •
Ln • �
W _o a
--3A,------J. P • / '
- _.-
YADKIN AVENUE
. FENCE
^•
OVERHEAD ELECTRICAL LINE
Q
O
O
- TYPE 11 NONITOR"C WELL
•
_ T"PF III UDNRDRMC WELL
_ FORMER TEUPORAM WELL LOCATION
;
V
•
- SOIL SORiNC LOCATION
po
♦
_ PROPOSED PHASE P INJECTION WELL
•
_ PROPOSED PHASE I DIRECT PUSH
PONT
E
ry
LOCATION
_ LOCATION FORKS AVJERAL
SPIRITS UST
T
i
KJ
J
ESTIMATED E%TEW OF DMOLN 1WATER
IMPACTED ASW NC 7L STANDARDS
p,
•NNW
ZZ
O � �
FW
J
W
OO Z
Z <E�
T Z W Z
— .
Of D Y O ,
S2 } O
J
Oi: <
N
_
x5
d
D 15 30ROp
APPROttAMTE SCALE M /ELT
z
t

CONCLUSION
The injection program was a success and all proposed materials were injected into the
targeted zones. During the injection into IW-IS surfacing occurred as IET attempted to
deliver a higher dosage .to this zone, IET also increased the volume of injected material
into IW-2S. JET recommended theadditional volume in order to influence the 15-18'
zone around IW-1S.due to the installation depth of IW-lS (11-14' bgs). ATC had
monitored the groundwater elevation in MW-4 during the injection into IW-lD and IW-
1S and noted that the elevation increased one foot during. injection..into IW-1D and one.
half foot during injection into IW-1S. Therefore IET did influence the water table during
both injections into IW-1 and expects to see -good results during first round of sampling
across the entire targeted area.

INNOYATIYE ENARONMENTAL TECIINQLO(UES, INC.
Job Name: Safety Kleen, Charlotte, NC 2012 Injections
In -Situ Chemical Oxidation using Hydroxyl and Sulfate Free Radical Oxidation
Date of Injection: 3/20/2012 Time of Injection: 2:43
To
2:57
Deep Treatment Area
IW-1D
Injection Zone
Actual
Proposed
21-25'
21-25'
Duration of Fracture (seconds):
8
8
Pressure of Pre -injection pathway development
75
75
Estimated Radius of Influence
15
15
Pounds of Klozur
222.
222
Gallons of 50% H202
6
6
Gallons of 2.5% H202
120
120
Gallons of Klozur/H202
150
150
Pressure of Post -injection pathway development
50
50

Job Name: Safety Kleen, Charlotte, NC 2012 Injections
In -Situ Chemical Oxidation using Hydroxyl and Sulfate Free Radical Oxidation
Date of Injection: 3/20/2012 Time of Injection: 2:31
To
2:43
Deep Treatment Area
IW-2D
Injection Zone
Actual
Proposed
21-25'
21-25'
Duration of Fracture (seconds):
8
8
Pressure of Pre -injection pathway development .
75
75 .
Estimated Radius of Influence
15
15
Pounds of Klozur
222
222
Gallons of 50% 1 02
6 _
6
Gallons of 2.5% H202
120
120 .
Gallons of Klozur/HZOZ .
150.
150
Pressure of Post -injection pathway development
50
50
Other Field Observations:

Job Name: Safety Kleen, Charlotte, NC 2012 Injections
In -Situ Chemical Oxidation using Hydroxyl. and Sulfate Free Radical. Oxidation
Date of Injection: 3/20/2012 Time of Injection:.. 12:57
To
1:10
Deep Treatment Area
IW-3D
Injection Zone
Actual
Proposed
21-25'
.21-25'
Duration of Fracture (seconds):
8
8
Pressure of Pre -injection pathway development.
75
75 .
Estimated Radius of Influence
15
15
Pounds of Klozur
222
222
Gallons of 50% HM
6
6
Gallons of 2.5% H202
120
120
Gallons of Klozur/HZOZ
150
150
Pressure of Post=injection pathway development
50
50 '

Injection Zone
Actual
Proposed
21-25'
.21-25'
Duration of Fracture (seconds):
8
8
Pressure of Pre -injection pathway development .
75
75
Estimated Radius of Influence
15
15
Pounds of Klozur
222
222 :
Gallons of 50% 102.
6
6
Gallons of 2.5% HZOZ
120
120
Gallons of Klozur/HZOZ
150
150
Pressure of Post -injection pathway development
50
50. '

t
INNOVATIVE ENVIRONMENTAL TRGHIO]LOWES, INC.
Job Name: Safety Kleen, Charlotte, NC
2012 Injections
In -Situ Chemical Oxidation using Hydroxyl and Sulfate Free Radical Oxidation
Date of Injection: 3/20/2012
Time of Injection: 11:48
To
12:04
Deep Treatment Area
Iw-5D
Injection Zone
Actual
Proposed
21-25'
21-25'
Duration of Fracture (seconds):
8
' 8 .
Pressure of Pre -injection pathway development.
50
75 .
Estimated Radius of Influence
15
15
Pounds of Klozur
222
222
Gallons of 50% 14202
6
6
Gallons of 2.5% H202
120
120
Gallons of Klozur/HZOZ
Pressure of Post -injection pathway development
150
150
50
50
Other Field Observations:

INNOVATIVE ENVIRONMENTAL TECHNOLQ'EMS, INC.
Job Name: Safety Kleen, Charlotte,NC 2012 Injections -
In -Situ Chemical Oxidation using Hydroxyl and Sulfate Free Radical Oxidation
Date of Injection: 3/20/2012 : Time.of Injection: 11:15
To
11:40
Deep Treatment Area
Iw-6D
Injection Zone
Actual
Proposed
21-25'
'21-25'
Duration of Fracture (seconds)!
5
8
Pressure of Pre4njection pathway development
50
75
Estimated Radius of Influence
15
15
Pounds of Klozur .
222
222
Gallons of 50% 11202
6
6
Gallons of 2.5% H202
120
120
Gallons of Klozur/HZOZ
150
150
Pressure of Post -injection pathway development
50
50
Other Field Observations:

r':1
a af, � .
INNOVATIVE ENVIRONMENTAL TEOIINOLO(aIES, INC.
Job Name: Safety Kleen, Charlotte NC 2012 Injections
In -Situ Chemical Oxidation using Hydroxyl and Sulfate Free Radical Oxidation
Deep: Treatment Area
Summary
Actual .
Proposed
Injection Zone
21-25'
21-25'
Pounds of Persulfate
1332
1332
Gallons of 50% A202
36
36
Gallons of 2.5% I3202/Klozur Solution
900
900

Job Name: Safety Kleen, Charlotte, NG 2012 Injections
In -Situ Chemical Oxidation using Hydroxyl and Sulfate Free Radical Oxidation.
Date of Injection: 3/20/2012 Time of Injection: 3:16
To
3:44
Shallow Treatment Area
IW4S
Injection Zone
Actual .
Proposed
11-14'
15-18'
Duration of Fracture (seconds):
8
8
Pressure of Pre -injection pathway development
75
75
Estimated.Radius of Influence .
15
15
Pounds of Klozur
490.5
327
Gallons of 50% Hz02
10.14
10.1
Gallons of 5% H202
151.5
101
Gallons of Klozur/HZOZ '
225
150
Pressure of Post -injection pathway development
50
50
,f
�

Job Name: Safety Kleen, Charlotte, NC. 2012 Injections
In -Situ Chemical Oxidation using Hydroxyl and Sulfate Free Radical Oxidation
Date of Injection: 3/20/2012 Time of Injection: 2:58
To
3:16
Shallow Treatment Area
1W-2S
Injection Zone
Actual
Proposed
15-18,
15-18,
Duration of Fracture (seconds):
8
8
Pressure of Pre -injection pathway development
75
75
Estimated. Radius of Influence .
15
15 .
Pounds of Klozur
490.5
327 .
Gallons of 50% Hi02
10.1
10.1
Gallons of 5% HZOZ
M.5
101
Gallons of Klozur/H202
225
150
Pressure of Post -injection pathway development
50
50
Other Field Observations:

Job Name: Safety Kleen, Charlotte, NC. 2012 Injections
In -Situ Chemical Oxidation using Hydroxyl and Sulfate Free Radical Oxidation
Date of Injection: 3/20/2012 Time of Injection: 1:32
To
1:41
Shallow Treatment Area
IW-3S
Injection Zone-
.Actual
Proposed
15-I8'
1548'
Duration of Fracture (seconds):
8
8
Pressure of Pre -injection pathway development
75
75
Estimated Radius of Influence .
15
15 .
Pounds. of Klozur
327
327
Gallons of 50% Hz02
10.1-
10.1
Gallons of 5%H202
101
101
Gallons of KlozurM202.
150
150
Pressure of Post -injection pathway development
50
50

Job Name: Safety Kleen, Charlotte, NQ 2012 Injections
In -Situ Chemical Oxidation using Hydroxyl and Sulfate Free Radical Oxidation
Date of Injection: 3/20/2012 Time of Injection: 1:14
To
1:28
Shallow Treatment Area
IW-4S
Injection Zone
Actual
Proposed
15-18'
15-18'
Duration of Fracture (seconds):
8
8
Pressure of Pre -injection pathway development
75
75
Estimated Radius of Influence .
15
.15
Pounds of Klozur
327
327
Gallons of 50% Hj02
10.1
10.1
Gallons of 5% H202
101
101
Gallons of KlozurM202 '
150
150
Pressure of Post -injection pathway development
50
50
Other Field Observations:

Job Name: Safety Kleen, Charlotte, NC 2012 Injections
In -Situ Chemical Oxidation using Hydroxyl and Sulfate Free Radical Oxidation
Date of Injection: 3/20/2012 Time of Injection: 12:27
To
12:34
Shallow Treatment Area
IWSS
Injection Zone
. Actual
Proposed
15-18'
15-18'
Duration of:Fracture (seconds):
8
8
Pressure of Pre -injection pathway development
75
75
Estimated. Radius of Influence .
15
15
Pounds of Klozur
327
327
Gallons of 50% Hj02
10.1
10.1
Gallons of 5% H2O2
101
101
Gallons of Klozur/H202
150
150
Pressure of Post -injection pathway development
50
50
Other Field Observations:

Job Name: Safety Kleen, Charlotte, NC: 2012 Injections
In -Situ Chemical Oxidation. using Hydroxyl and Sulfate Free Radical Oxidation
Date of Injection: 3/20/2012 Time of Injection: 12:16
To
12:26
Shallow Treatment Area
IW-GS
Injection Zone
Actual .
Proposed
15-18,
15-18'
Duration offracture (seconds):
8
8
Pressure of Pre -injection pathway development
75
75
Estimated. Radius of Influence .
15
.15
Pounds of Klozur
327
327 .
Gallons of 50% H2O2
10.1 '
10.1
Gallons of 5% HZOZ
101
101
Gallons of Klozur/HZOZ
150
150
Pressure of Post -injection pathway development
50
50

Job Name: Safety Kleen, Charlotte NC 2012 Injections
In -Situ Chemical Oxidation using Hydroxyl and Sulfate Free Radical Oxidation
Shallow Treatment Area
IW-1-6S
Summary
Actual
Proposed
Injection Zone
15-18' .
15-18'
Pounds of Persulfate
2289
1962
Gallons of 50% H2O2
61
61
Gallons of 2.5% H2O2/Klozur Solution
1050
900

ATTACHMENT 3
WELL CONSTRUCTION RECORDS

i Y"•i iF
1. WELL CONTRACTOR:
JOHNNY BURR
Well Contractor (Individual) Name
GEOLOGIC EXPLORATION, INC
Well Contractor Company Name
176.1COMMERCE BLVD
Street Address
STATESVILLE NC 28625
City or Town State Zip Code
70( 4 ) 872-7686
Area code Phone number
2. WELL INFORMATION:
WELL CONSTRUCTION PERMIT#
OTHER ASSOCIATED PERMIT#(if applicable)
SITE WELL ID #(if applicable) IW-1
3. WELL USE (Check One Box) Monitoring Cf Municipal/Public ❑
Industrial/Commercial ❑ Agricultural ❑ Recovery ❑ Injection ❑
Irrigation[] Other ❑ (list use)
DATE.DRILLED 03/14/12
4. WELL LOCATION:
2320 YADKIN AVENUE 28205
(Street Name, Numbers, Community, Subdivision, Lot No., Parcel, Zip Code)
CITY: CHARLOTTE COUNTY MECKLENBURG
TOPOGRAPHIC / LAND SETTING: (check appropriate box)
❑Slope ElValley g(Flat ❑Ridge ❑Other
LATITUDE 35 ° 14 22.1900 " DMS OR DD
LONGITUDE. 80. 48 44.9200_" DMS OR DO'
Latitudenongilude source: (,]BPS Uopographic map
(location of well must be shown on a USGS topo map andaltached to
this form if not using GPS)
5. FACILITY (Name of the business where the well is located.)
SAFETY-KLEEN
N/A
Facility Name
Facility ID# (if applicable)
2320 YADKIN AVENUE
Street Address
CHARLOTTE
NC
28205
City. or Town
State
Zip Code
SAFETY-KLEEN SYSTEMS_, INC
Contact Name
1502 EAST VILLA STREET
Mailing Address
ELGIN
IL
60120
City or Town
Stale
Zip Code
Area code Phone number
6. WELL DETAILS:
a. TOTAL DEPTH: 25.0/15.0 FEET
b. DOES WELL REPLACE EXISTING WELL? YES ❑ NO [j(
c. WATER LEVEL Below Top of Casing: 14.0 FT
(Use "+" if Above Top of Casing)
..NONRESIDENTIAL WELL CONSTRUCTION RECORD
North Carolina Department orEnvironment and Natural Resources- Division orwater Quality
WELL CONTRACTOR CERTIFICATION # 3098
d. TOP OF CASING IS 0:0 FT. Above Land Surface` ..
'Top of casing terminated at/or below land surface may require
a variance in accordance with 15A NCAC 2C .0118.
e. YIELD (gpm): N/A METHOD OF TEST N/A
f. DISINFECTION: Type . N/A Amount N/A
g. WATER ZONES (depth):
Top Bottom Top Bottom
Top Bottom Top Bottom
Top Bottom Top Bottom
Thickness/
: 7. ,CASING: Depth Diameter Weight Material
Top 0.0 Bottom 21.0 Ft. 1 INCH SCH 40 PVC
Top 0.0 : Bottom 12.0 Ft. 1 INCH SCH 40. PVC
Top Bottom - Ft._
8. GROUT: Depth Material Method
Top 0.0 Bottom 10.0 Ft. PORTLANDaENTONnE SLURRY
Top Bottom Ft.
Top Bottom Ft.
: 9. SCREEN: Depth Diameter Slot Size Material
Top 21.0 Bottom 25.0 Ft. 1.0 in. .030 in. PVC
: Top 12.0 Bottom 15.0 Ft. 1.0 in. .030 in. PVC
Top Bottom . Ft. in. in.
10. SAND/GRAVEL PACK:
Depth Size Material
Top 20.5 Bottom '25.0 Ft. 20-40 FINE SILICA SAND
Top 11.0 Bottom 16.0 Ft. 20-40 FINE SILICA SAND
Top Bottom Ft.
11. DRILLING LOG
: Top
Bottom
Formation Description
0.0
/
0.5
CONCRETE
0.5
/
10.0
ROCKY BACKFILL "
10.0
/
19.0
BROWN PARTIAL WEATHER ROCK
19.0
/
25.0
GRAY ROCK
/
/
/
/
12. REMARKS:
BENTONITE SEAL FROM 19 0 TO 20.5 FEET& 10 0 TO 11.0 FEET
: 1 00 HE EBY CERTIFY THAT THIS WELL CONSTRUCTED IN ACCORDANCE WITH
• 15A N 2C, ELL CON RUCTION ST ARDS, AND THAT A COPY OF THIS
RE
CO D DEDTOTv •r
03/19/12
ATURE br CERTIFIED WELL CONTRACTOR DATE
JOHNNY BURR
PRINTED NAME OF PERSON CONSTRUCTING THE WELL
Form GW-1b
Rev. 2/09

n. J
NON-RESIDENTIAL
WELL CONSTRUCTION RECORD
North Carolina Department Environment 'Natural
of
and Resources- Division
of Water Quality
N WELL CONTRACTOR CERTIr, [CATION # 3098
1. WELL CONTRACTOR:
JOHNNY BURR
d. TOP OF CASING IS 0.0 FT. Above Land Surface-
*Top of casing terminated at/or below land surface may require
Well Contractor (Individual) Name
a variance in accordance with 15A NCAC 2C.01 18.
GEOLOGIC EXPLORATION, INC
Well Contractor Company Name
e. YIELD (gpm): NIA
METHOD OF TEST N/A
176 COMMERCE BLVD.
f. DISINFECTION: Type
N/A Amount .' NIA
Street Address
g. WATER ZONES (depth):
STATESVILLE NC 28625
TOP Bottom
Top Top Bottom
City or Town State Zip Code
Top Bottom
Top . Bottom
(704 872-7686
Top Bottom
Top Bottom
Area code Phone number
Thickness/
2. WELL INFORMATION:
7. CASING: Depth
Diameter Weight Material
WELL CONSTRUCTION PERMIT4
Top 0.0 Bottom 21.0
Ft. I INCH SCH 40 PVC
OTHER ASSOCIATED PERMIT#(if applicable)
Top 0.0 ' Bottom 15.0
Ft. I INCH SCH 40 PVC
SITE WELL ID #(if applicable) IW-2
Top Bottom-
Ft.-
3. WELL USE (Check One Box) Monitoring W Municipal/Public E]
8. GROUT: Depth
Material Method
Industrial/Commercial El Agricultural [I Recovery El Injection [I
Top 0.0 Bottom 13.0
Ft. PORTLAND BENTONITE SLURRY
Irrigationo Other 0 (list use)
Top Bottom-
Ft.
DATE DRILLED 03/14112
Top Bottom
Ft.
4. WELL LOCATION:
:9. SCREEN: Depth
Diameter Slot Size Material
2320 YADKIN AVENUE 28205
Top 21.0 Bottom 25.-0
Ft. 1.0 -1 . n. ;030 in. PVC
(Street Name,. Numbers, Community, Subdivision, Lot No., Parcel, Zip Code)
Top--15.0 Bottom 18.0
Ft. 1.0 in. .030 in. PVC
CITY:CHARLOTTE COUNTYMECKLENBURG
Too Bottom-
Ft -in. in.
TOPOGRAPHIC / LAND SETTING: (check appropriate box)
0SIope E]Valley VFlat []Ridge C]Other
10. SAND/GRAVEL PACK:
LATITUDE 35 -14 -22-1900 "DMSOR DD
Depth
:Top
Size Material
20.5 Bottom 25.0
Ft. 20-40 FINE SILICA SAND
LONGITUDE 80 48 44.9200 .'DMS OR DD
: Top--14.0 Bottom 19.0
Ft. 20-40 FINE SILICA SAND
Latitude/longitude source: BPS Topographic map
:Top Bottom
Ft.-
(location of well must be shown on a USGS topo map andattached to
this f6mi If not using GPS)
5. FACILITY (Name of the business where the well is located.)
11. DRILLING LOG
Top Bottom
Formation Descrintimn
SAFETY-KLEEN
N/A
Facility Name
Facility ID# (if applicable)
2320 YADKIN AVENUE
Street Address
CHARLOTTE
NC. 28205
City or Town
Slate Zip Code
SAFETY-KLEEN SYSTEMS, INC
Contact Name
1502 EAST VILLA STREET'
Mailing Address
ELGIN
IL 60120
City or Town
State Zip Code
Area code Phonenumber
6. WELL DETAILS: 100 HEREBY CERTIFY THAT WELL.VykS CONSTRUCTED IN ACCORDANCE WITH
• 15ANC 2C.WELL CONS RUCTION STAtARDS, AND THAT A COPY OFT . HIS
a. TOTAL DEPTH: 25.0/18.0 FEET '0 DNA EENPRO DEDTOTHWAt-LL OWNER.
b. DOES WELL REPLACE EXISTING WELL? YES [I NO E-J( 03/19/12
J�AATUR . E br CERTIFIED WELL CONTRACTOR DATE
c. WATER LEVEL Below Top of Casing: 14.0 11 FT.
:
(Use +11 11 Above Top of Casing) JOHNNY BURR
0.0
0.5
.0.5
10.0
10.0
19.0
19.0
25.0
CONCRETE
ROCKY BACKFILL
BROWN PARTIAL WEATHER ROCK
GRAY ROCK
12. REMARKS:
BENTONITE SEAL FROM 19.0 To 20.5 FEET& 13.0.jo 1440 FEET
.F8 mWt4itfilif30"d -,
d, 0--
]
161
py% Pf1� fi� T bf 7, 99-11 166b 2 "
PRINTED NAME OF PERSON CONSTRUCTING THE WELL
Form GW-1b
Rev. 2/09

`
'
NONRESIDENTIAL WELL CONSTRUCTION RECORD
North Carolina Department vrau ironmo t Division of
' WELL # 3098 �
1. WELL CONTRACTOR:'
^u TOP OF CASING
JOHNNY BURR �
.*Top _- casing terminated_-.~-~~~~~~~~~. may require
Well Contractor (individual) Name ovariance maccordance With 1nAwoAcuo.o11u
GEOLbGIC EXPLORATION, INC
Well Contractor. Company Name � u YIELD (gpm):N?A -_Msr0000p TEST N/A176.COMMERCE BLVD. f. om/wpsurmw: Amount NIA
� '
Street Address �n. WATER ZONES
STATESVILLE
Cit_ NC 28625- Tun�----_-opuvn-Top Bottom
_
' State - Zip Code ��/on_---_'aouom--_-__Top Bottom
7U4 �
"' �Top �--_�-�ovu»m-_�___ Top Bottom
Area code Phone number
nocxnunx
' 2. WELL INronMxnom _ :roxuINo Depth'. Diameter _Weight Material
WELL CONSTRUCTION PERMIT# rvn_l.0/_Bottom -J21.lFt. -1INCH SCH 40� pvo'
OTHER ASSOCIATED psnm / �Top _0.0_-Bottom 15.0 Ft. I INCH -SCH 40PVC
SITE WELL m#(if ww-3 Top_Bottom' Ft.
' 3.WELL USE (Check one box) Monitoring 5('munm»avpuxlico � �u onouT oenm ' Material Mamuu
Inclustrial/Commercial El Agricultural Ei Recovery ' !Tvo—0.0 'anuun13J0_ SLURRY
Irrigation[] moa o(limvme) Top Bottom- Ft.
` DATE DRILLED :Topaoxvn____
^ ' '
4. WELL Luc«now: ' �a ocnEsw o�mom, Slot Size Mo�nu
232OYADKN � �
. ~,�""� �^"�"" �nq�_�^0_aouvn�250_n. 1^0-j» ��Ul'm`_PVl.(Street Name, ---_
Numbers, Community,`�----�'-ot ------'-ode)-` �nnp 15.0_Bottom �18.g_Ft. 1'0_m. .03U0_ in. PVC�____
cny wEcxLEwauno Top ammn�_____n:___m. xn.___�_.�_�_
TOPOGRAPHIC / LAND SETTING: (check "ppmndate box) �
onmne ovulley /Fw(no onmua []Other 10. pAcn
LATITUDE os 14 un oo : o»nm a�o �o�,m
----'----==�===� �~~'~ ---------� � r»n-�U�_-Bottom���FINE SILICA SAND
' uowo/ruosoo "4u`4�uoun^o�aon oo ''---�---
------'-------' ---------- �Top 14.0 Bottom 19.0 �. 2o-4oFINE-SILICA SANIJ
-
Latitude/longitude source: 03pa E]Topographicmap
vo�oonn,�mmcwuuSoompvm�anmm�nvdm � Top ----- �------
this form xnot using opS) �11.DRILLING LOG
5.FACILITY (Name v-the business where the well mmcat,u.) mm ommm Formation Description
NIA
^
Facility.'SAFETY-KLEEN
Facility _' (if �applicable)
~
Street
-_Address
--`
CHARLOTTE
NC
28205
City or Town
State
Zip Code
SAFETY-KLEEN SYSTEMS, INC
Contact mamo
'
1502 EAST VILLA STREET -
�
Mailing Address
City or Town
State
Zip Code
Area code Phone number-
6.vmELLosrmus:
u /u/m`uEr
'
b. DOES WELL REPLACE EXISTING WELL? YES NO IV
c.vwATEn LEVEL Below Top of Casing: 14.0 FT.
~_--�'
' ------
�
ROCKY BACKFILL
BROWN PARTIAL WEATHER ROCK
GRAY ROCK
' --------------
:12.nEMxnxm _BENTONITE SEAL FROM 19.0 To 20.5 FEET 13.0 To 14.o FEET
.`=
�
�
JOHNNYBURR
PRINTED NAME OF PERSON CONSTRUCTING THE WELL
'
Form oW-1u
no,omn

M��Iljl41 iONddESIDENTIAL
�
WELL CONSTRUCTION RECORD
` fl"1I ijf'(,�� W North Carolina Department of Environment
, �.Jc`
and Natural Resources- Division of Water Quality
WELL CONTRACTOR CERTIFICATION
#.. 3098
1. WELL CONTRACTOR:
: d. TOP OF CASING IS 0.0 FT. Above Land Surface'
JOHNNY BURR
`Top of casing terminated atfor below land surface may require
j Well Contractor (Individual) Name
a variance in accordance with 15A NCAC 2C .0118.
GEOLOGIC EXPLORATION, INC'
Well Contractor Company Name
: e. YIELD (gpm): N/A METHOD OF TEST NIA
.176 COMMERCE BLVD.
f. DISINFECTION: Type NIA Amount N/A
Street Address
; g. WATER ZONES (depth):
STATESVILLE NC. 28625
Top Bottom Top Bottom
City or Town - State' Zip Code
;Top Bottom Top Bottom
704 872-7686
��
:Top Bottom Top Bottom
Area code Phone number
Thickness/
2. WELL INFORMATION:
: 7. CASING: Depth Diameter Weight Material
WELL CONSTRUCTION PERMIT#
Top 0.0 Bottom 21.0 Ft. 1 INCH SCH 40 PVC
OTHER ASSOCIATED PERMIT#(it applicable) "
Top 0.0 Bottom 15.0 Ft. 1 INCH SCH 40 PVC
SITE WELL ID #(if applicable) IW-4
: Top Bottom Ft.
3. WELL USE (Check One Box) Monitoring Cl Municipal/Public ❑
; 8. GROUT: Depth Material Method
Industrial/Commercial ❑ Agricultural ❑ Recovery j
9 ry ❑ Inaction ❑
To 0.0 Bottom 13,0 Ft. PORTLAND BENTONITE SLURRY
P
Irrigation❑ Other ❑ (list use)
: Top Bottom Ft.
DATE DRILLED 03/15/12
: Top Bottom Ft..
4. WELL LOCATION:
: 9. SCREEN: Depth Diameter Slot Size Material .
2320 YADKIN AVENUE 28205.
; Top 21.0 Bottom 25.0 Ft.. 1.0 in. 030 in. PVC
(Street Name, Numbers, Community, Subdivision, Lot No., Parcel, Zip Code)
; Top 15.0 Bottom 18.0 Ft..1.0 In. 030. in. PVC
CITY; CHARLOTTE COUNTY' MECKLENBURG
:Top Bottom FC. in. in.
TOPOGRAPHIC / LAND SETTING; (check appropriate box)
" ❑Slope ❑Valley 91Flat ❑Ridge .❑Other
1Q. SAND/GRAVEL PACK:
LATITUDE 35 ° 14 ' 22.1900 DMS OR DD
Depth Size Material
;Top 20.5 Bottom 25.0 Ft. 20-40 FINE SILICA SAND
LONGITUDE 80 ° 48 ' 44.9200 11 DMS OR DD.
: Top 14.0 Bottom 19.0 Ft. 20-40 FINE SILICA SAND
Latitude/longitude source: BPS aopographic map
: Top Bottom Ft.
(location of well must be shown on a USGS fopo map andattached to
this form if not using GPS)
' 11. DRILLING LOG
5. FACILITY (Name of the business where the well is located.)
Top Bottom Formation Description .
SAFETY-KLEEN NIA.
0.0 / 0.5 CONCRETE
'Facility Name Facility ID# (if applicable)
0.5 / 10.0 ROCKY BACKFILL
2320 YADKIN AVENUE
10.0 / 19.0 BROWN PARTIAL WEATHER ROCK
Street.Address
19.0 / 25,0 GRAY ROCK.
CHARLOTTE NC 28205
/
City or Town Slate Zip Code
/
SAFETY-KLEEN SYSTEMS, INC
/
Contact Name
/
1502 EAST VILLA STREET
.Mailing Address
/
ELGIN IL 60120
/
City or Town State Zip Code
12. REMARKS:
BENTONITE
Are code de Phone number
SEAL FROM 19.0 TO 20.5 FEET & 13.0 TO 14.0 FEET
6. WELL DETAILS:
; I DO HEREBY CERTIFY THAT THIS WELL 5 CONSTRUCTED IN ACCORDANCE WITH
-
• 15A N 2C, WELL CON TRUCTION S DARDS, AND THAT A COPY OF THIS
a. TOTAL DEPTH: 25:0/18.0 FEET
: REc HA BEEN PR IDEDTOTH LOWNER
b.' DOES WELL REPLACE EXISTING WELL? YES ❑ NOW
03/19/12
&NATUREW
CERTIFIED WELL CONTRACTOR DATE
c. WATER LEVEL 'Below Top of Casing: 14.0 FT:
JOHNNY BURR
(Use "+" if Above Top of Casing)
: PRINTED NAME OF PERSON CONSTRUCTING THE WELL
Form GW-1b.
Rev. 2109

a STATE
NON-RESIDENTIAL ON -RESIDENTIAL WE, CONSTRUCTION RECORD
North Carolina Department orEnvironnient and Natural Resources- Division of Water Quality
WELL CONTRACTOR CERTIFICATION # 3098
1. WELL CONTRACTOR:
JOHNNY BURR
d. TOP OF CASING IS 0.0 FT. Above Land Surface-
Well Contractor (Individual) Name
"Top of casing terminated at/or below land surface may require
GEOLOGIC EXPLORATION, INC
a variance in accordance with 15A NCAC 2C .0118.
Well Contractor Company Name
: e. YIELD : N/A METHOD OF TEST N/A
(9pm )
176. COMMERCE BLVD
; f. DISINFECTION: Type NIA Amount' N/A
Street Address
; g. WATER ZONES (depth):
STATESVILLE NC 28625
Top Bottom Top Bottom
City or Town Slate Zip Code
:Top Bottom Top Bottom
70( 4. ) 872-7686
: Top Bottom Top Bottom.
Area code Phone number
Thickness/
2. WELL INFORMATION:
: 7..CASING: Depth Diameter Weight..Material
WELL CONSTRUCTION PERMIT#
Top 0.0 Bottom 21.0 Ft. 1 INCH SCH 40 PVC
OTHER ASSOCIATED PERMIT#(if applicable)
: T.op 0.0 . Bottom 15.0 Ft. 1 INCH SCH 40_ ..PVC
SITE WELL ID #(if applicable) IW-5
: Top Bottom Ft.
3. WELL USE (Check One Box) Monitoring d Municipal/Public ❑
8. GROUT: Depth Material Method
Industrial/Commercial ❑ Agricultural ❑ Recovery ❑ Injection ❑
Top 0.0 Bottom 13.0 Ft. PORTLANDBENTONITE SLURRY
Irrigation❑ Other ❑ (list use)
: Top Bottom Ft.
DATE.DRILLED 03/15/12
:Top Bottom FL
4. WELL LOCATION:
: 9. SCREEN: Depth Diameter Slot Size Material,
2320 YADKIN AVENUE 28205
:Top 21.0 Bottom 25.0 Ft. 1.0 in. .030 in. PVC
(Street Name, Numbers, Community, Subdivision, Lot No., Parcel, Zip Code)
.
:Top 15.0 Bottom . 18.0 Ft.. 1.0 in. .030 in. PVC
CITY: CHARLOTTE COUNTY MECKLENBURG -
: Top Bottom Ft. in: in.
TOPOGRAPHIC / LAND SETTING: (check appropriate box)
❑Slope ❑Valley U'Flat ORidge ❑Other
LATITUDE 35 ^ 14 ' 22.1900 "DMS OR DID
LONGITUDE 80. ° 48 44.9200 " DMS OR DID
Latitude/longitude source: MPS pTopographic map
(location of well must be.shown on a USGS topo map andattached to
this form if not using GPS)
5. FACILITY (Name of the business where the well is located.)
SAFETY-KLEEN N/A
Facility Name Facility ID# (if applicable)
2320 YADKIN AVENUE
Street Address.
CHARLOTTE NC 28205
City or Town .. State . Zip Code
SAFETY-KLEEN SYSTEMS INC
Contact Name
1502 EAST VILLA STREET
Mailing Address
ELGIN IL 60120
City or Town State Zip Code
Area.code Phone number
6. WELL DETAILS:
a. TOTAL DEPTH: 25.0/18.0 FEET
b. DOES WELL REPLACE EXISTING WELL 7. YES ❑ NO L�
C. WATER LEVEL Below Top of Casing: 14.0 FT.
(Use "+" if Above Top of Casing)
10. SAND/GRAVEL PACK:
Depth
Size Material
: Top 20.5
Bottom 25.0
Ft. 20-40 FINE SILICA SAND
Top 14.0
Bottom 19.0
Ft. 20-40 FINE SILICA SAND
Top
Bottom
Ft.
11. DRILLING LOG
Top
Bottom
Formation Descdption
0.0 /
0.5
ASPHALT
0.5 /
10.0
'ROCKY BACKFILL
10.0 /
19.0
BROWN PARTIAL WEATHER ROCK
19.0 /
25.0
GRAY ROCK
12. REMARKS:
10 HE aY CERTIFY THAT THIS WELL ' CONSTRUCTED IN ACCORDANCE WITH
• 15A N 2C, LL CONS RUCTION ST ARDS, AND THAT A COPY OF THIS
RECO D IDEDTOT L 07
!
03/19/12
NATURE CERTIFIED WELL CONTRACTOR DATE
JOHNNY BURR
PRINTED NAME OF PERSON CONSTRUCTING THE WELL
Form GW-1 b
Rev. 2/09

NONRESIDENTIAL ONRESIDENTIAL WELL CONSTRUCTION RECORD
North Carolina Department of Environment and Natural Resources- Division of Water Quality
WELL CONTRACTOR CERTIFICATION # 3098
1: WELL CONTRACTOR: : d. TOP OF CASING IS 0.0 - FT. Above Land Surface-
JOHNNY BURR 'Top of casing terminated at/or below land surface may require
Well Contractor (Individual) Name a variance in accordance with 15A NCAC 2C .0118.
GEOLOGIC EXPLORATION, INC ' e. YIELD (gpm): N/A METHOD OF TEST N/A
Well Contractor Company Name
176 COMMERCE BLVD f,, DISINFECTION: Type N/A Amount. N/A
Street Address : g. WATER ZONES (depth):
STATESVILLE NC 28625 Top Bottom. Top Bottom
City or Town State Zip Code ; Top Bottom Top Bottom
70( 4. ) 872-7686 Top Bottom Top Bottom
Area code Phone number Thickness/
2. WELL INFORMATION: : 7..CASING: Depth Diameter Weight Material
WELL CONSTRUCTION PERMIT# Top 0.6 Bottom 21.0 Ft. 1 INCH SCH 40 PVC
'OTHER ASSOCIATED PERMIT#(if applicable) ; Top 0.0 Bottom 15,0 Ft. 1 INCH SCH 40 ..PVC
SITE WELL ID #(if applicable) IW-6 : Top Bottom Ft.
3. WELL USE (Check One Box) Monitoring W Municipal/Public ❑ : 8. GROUT: Depth Material Method
Industrial/Commercial ❑ Agricultural ❑ Recovery Injection ❑ Top 0.0 .Bottom 13.0 Ft. PORTLAND BE NTONITE SLURRY
Irrigation❑ Other ❑ (list use) : Top Bottom Ft.
DATE DRILLED 03/14/1.2 - 03/15112. : Top Bottom Ft.
4. WELL LOCATION: ' 9. SCREEN: Depth Diameter Slot Size Material
2320 YADKIN AVENUE 28205 : Top 21.0 Bottom 25.0 Ft. 1.0 in. .030 in. PVC
(Street Name, Numbers, Community, Subdivision, Lot No., Parcel, Zip Code) : Top 15.0 Bottom 18.0 Ft. 1.0 in. .030 in. PVC
CITY: CHARLOTTE COUNTY MECKLENBURG : Top Bottom Ft. in. in.
TOPOGRAPHIC / LAND SETTING: (check appropriate box)
❑Slope ❑Valley Flat pRidge ❑Other 10. SAND/GRAVEL PACK:
LATITUDE 35 ° 14 ' 22.1900 " DMS OR DD .
Depth Size Material
.. : Top 20.5 Bottom 25.0 Ft. 20-40 .FINE SILICA SAND
LONGITUDE 80. ° 48 ' 44.9200 " DMS OR DD : Top 14.0 Bottom 19.0 Ft. 20-40 FINE SILICA SAND
Latitude/longitude source: WPS Qfopographic map : Top Bottom Ft.
(location of well must be shown on a USGS topo inap andattached to
this form if not using GPS) : 11. DRILLING LOG
.5. FACILITY (Name of the business where the well is located.). Top Bottom Formation Description
SAFETY-KLEEN N/A 0.0 / 0.5 ASPHALT,
Facility Name Facility ID# (if applicable) 0.5 / 10.0 ROCKY BACKFILL
2320 YADKIN AVENUE 1.0.D 1 19.0 BROWN PARTIAL WEATHER ROCK
Street Address 19.0 / 25.0 GRAY ROCK
CHARLOTTE NC .28205 /
City or Town .. Stale Zip Code .. /
SAFETY-KLEEN SYSTEMS, INC. /
Contact Name /
1502 EAST VILLA STREET /
Mailing Address /
ELGIN IL 60120 /
City or Town State Zip Code.
12..REMARKS: ..
�) BENTONITE SEAL FROM 19.0 TO 20.5 FEET & 13.0 TO 14.0 F T.
Area code Phone number
6. WELL DETAILS: : I Do EBY ERTIFV T T THIS WEL AS CONSTRUCTED IN ACCORDANCE WITH
• 15A C 2 E STRUCTI N ARDS, AND THAT A COPY OF THIS
a. TOTAL DEPTH: 25.0118.0 FEET REc ovIDEDro w L rr �/
b. DOES WELL REPLACE EXISTING WELL?. YES ❑ NOW
IGNATURE OF CERTIFIED WELL CONTRACTOR 03 DA/TE
C. WATER LEVEL Below Top of Casing: 14.0 FT. JOHNNY BURR
(Use "+" if Above Top of Casing) : PRINTED NAME OF PERSON CONSTRUCTING THE WELL
Y
Submit vlhtiiln 3Q days of coittpietion,to Division of �lllater Quaht InformafiomProcessln Form GWAb 9.
1617 Mall Service Center, Raleigh; N�, 27699 161, Phonel` (91.9)'807 6300 ' Rev. 2109

DOCUMENTS ASSOCIATED
WITH
THE ORIGINAL PERMIT
APPLICATION
(ISSUED OCTOBER 21, 2011)

Fle
Goodrich, David
To: [e-mail]
Cc: Schutte, Maria; Pitner, Andrew
Subject: RE: Safety-Kleen Charlotte New Monitoring Well Installation
WTG36oI�1
Genna,
Thank you for sending us the attached map showing the proposed location of the new monitoring well. I have contacted
our Regional Office regarding this issue, and we feel that the location you are proposing is acceptable to us.
Regards,
David Goodrich
Aquifer Protection Section Central Office
From: Genna Olson [mailto:genna.olsonCd)atcassociates.com]
Sent: Monday, November 21, 2011 9:14 AM
To: Goodrich, David; Ulishney, Adam
Cc: 'Schoepke, Robert'
Subject: RE: Safety-Kleen Charlotte New Monitoring Well Installation
Per the UIC Program's request, we plan to revise the proposed well location to be within 5 feet of well TW-5. To
accomplish this we will use a direct -push rig that can be equipped with an air hammer that can drill a short distance into
bedrock, if necessary. We are also arranging to have the power company shield one of the overhead power lines. A
figure showing the proposed well location is attached. Please let me know if the revised well location is acceptable. We
are tentatively scheduled to drill the well next Wednesday, 11/30/11. Thanks.
From: Genna Olson [mailto:genna.olson(cbatcassociates.com]
Sent: Tuesday, November 15, 2011 12:08 PM
To: '[e-mail]'; '[e-mail]'
Cc: 'Schoepke, Robert'
Subject: Safety-Kleen Charlotte New Monitoring Well Installation
David and Adam,
The UIC Program (David) has requested installation of a monitoring well between TW-5 and MW-4 at the site. The RCRA
Program (Adam) has indicated that replacement of well TW-5 may be required if it continues to be dry. We were hoping
to install just one well that will fulfill both of your requirements. We also wanted to let you know about some site
constraints that limit the proposed well location. Well TW-5 was installed with a small direct -push drilling rig (which is
why it is so shallow it is usually dry). However, to get a well down to water, we need to use a full-size drilling rig and
there are overhead utility lines that prevent access to this area with a full-size rig. The attached figure shows the closest
location we can access. A photo is also attached that shows the area. Please let me know if the proposed location is
acceptable.
Thanks
Genna K. Olson, P.G. I Senior Project Manager I ATC Associates Inc. I Raleigh, NC
[phone] direct 1 [phone] mobile
2725 East Millbrook Road I Suite 121 1 Raleigh, NC 27604
[phone] tel [phone] fax I www.atcassociates.com

PLEASE NOTE: This message, including attachments, may include privileged, confid, and/or inside information. 'Any
distribution or use of this communication by anyone other than the intended recipient is strictly prohibited and may be unlawful. If
you are not the intended recipient, please notify the sender by replying to this message and then delete it from your computer.

3- 3- 3- 3- 3- - 3- 3- 3- - 3- 3- 3- 3- 3--1
Note that the injection area extends to
MW-2 based on historical detections of /A I
COCs above 2L Standards in well MW-2.
If this well continues to show no exceedences /
of 2L Standards during future sampling I
events, some injection locations may be / DUMP
moved to focus more on the area of I
known groundwater impact. FPICNIC
AREA I
I F----- i
GRAVEL I CONCRETE
OFFICE
I I
/A I
---- SIDEWALK
I
LANDSCAPE T— T T -L----------7 8MW-1B
—
I I I I I I GRAVEL
I
PAVED I
I
I BMW-1A
I
� I I
I
CONCRETE I — E
I
I
I
I
I
w
W
in PAVED i '0 WAREHOUSE
I
I
N I
I
I— I
QCl) I
W WLANDS----
CAPE--- j
I -_-
— — LANDSCAPE — —
MW-3'111—�
r---E —E —E
T___E ---- ------
TW-
O 2 1 OMW-4
E
_5
O
BTW-4
PAVED �- 3
STORAGE
I
Mw-s
I
;
w
z I i 0
o
U O
B-2
O
0
®®__ip
w
_-__t_____
B
N
i 6
7
6
O
W_3
W
Of
In
O
W
-- E e E —E
YADKIN AVENUE
-IVNAUG IANKJ kin.uuu U: )l
�BTW-7 E E e nae v E— E --
—_�_— = FENCE
4
(�
—• —E — = OVERHEAD ELECTRICAL LINE
O
60
$ = TYPE II MONITORING WELL
m
m
Q = TYPE III MONITORING WELL
a �
w
'o 0
a
= FORMER TEMPORARY WELL LOCATION
"
LO
OO = SOIL BORING LOCATION
0 4
0
p =PROPOSED PHASE If INJECTION WELL
p m
0 = PROPOSED PHASE I DIRECT PUSH
=
m
INJECTION POINT
o
N
= LOCATION OF FORMER MINERAL
®
Z
o
o (�
SPIRITS UST
N
— � =ESTIMATED EXTENT OF GROUNDWATER
~
r
o
IMPACTED ABOVE NC 2L STANDARDS
E
0
o
<�
<
Z
U N
06/29/2011 Dap
MW:Chl.,id,
Z
0BenL)
enzene 20 24
20 2�
—
1.4ane (ag/L)
q/L)
�V,hane
(aq/L) 15 14
0. aN,(a9/L) DL
rd,Noedenco of NC 2L S[ondards
5 06/29/2011
ichloroelhane (g/L) 57
chlhero eaceedences of NC 2L St-dards
OC
Z LLJ
O H
Z
Q W
U U
O W
J U
m
w Q
a
posed
LLJ
O W
Titoring Well
Ld LZ
ation
LLJ Z QDo U
Z
Z W Z_
-JYW
3y:/a
o1 PC A St, mrd
Y
p2aene
m
_ C) 0
rn
LL n- W O Of
N
O L, NQ
� Q1h2
LL1n
❑L`1
CL N U
E5 �
06/29/2011
0
al Nc 2L Standords
0
w
a
0
O6/29/2011
?
of NC 2L Standords
Z
4
_
we
09
F�
0 15 30 60
W �N
APPROXIMATE SCALE IN FEET
o i
z

Goodrich, David
From: Goodrich, David
Sent: Tuesday, November 15, 2011 12:43 PM
To: '[e-mail]; Ulishney, Adam
Cc: 'Schoepke, Robert'
Subject. RE: Safety-Kleen Charlotte New Monitoring Well Installation
Genna,
We need to have the monitoring well installed much closer to the originally prescribed location.
David
From: Genna Olson Imailto:genna.olson(a)atcassociates.coml
Sent: Tuesday, November 15, 2011 12:08 PM
To: Goodrich, David; Ulishney, Adam
Cc: 'Schoepke, Robert'
Subject: Safety-Kleen Charlotte New Monitoring Well Installation
David and Adam,
The UIC Program (David) has requested installation of a monitoring well between TW-5 and MW-4 at the site. The RCRA
Program (Adam) has indicated that replacement of well TW-5 may be required if it continues to be dry. We were hoping
to install just one well that will fulfill both of your requirements. We also wanted to let you know about some site
constraints that limit the proposed well location. Well TW-5 was installed with a small direct -push drilling rig (which is
why it is so shallow it is usually dry). However, to get a well down to water, we need to use a full-size drilling rig and
there are overhead utility lines that prevent access to this area with a full-size rig. The attached figure shows the closest
location we can.access. A photo is also attached that shows the area. Please let me know if the proposed location is
acceptable.
Thanks.
Genna K. Olson, P.G. I Senior Project Manager I ATC Associates Inc. I Raleigh, NC
[phone] direct 1 [phone] mobile
2725 East Millbrook Road I Suite 121 1 Raleigh, NC 27604
[phone] tel [phone] fax I www.atcassociates.com
PLEASE NOTE: This message, including any attachments, may include privileged, confidential and/or inside information. Any
distribution or use of this communication by anyone other than the intended recipient is strictly prohibited and may be unlawful. If
you are not the intended recipient, please notify the sender by replying to this message and then delete it from your computer.

— 3— 3— 3— 3—
Note that the injection area extends to
MW-2 based on historical detections of
COCs above 2L Standards in well MW-2.
If this well continues to show no exceedences
of 2L Standards during future sampling
events, some injection locations may be
moved to focus more on the area of
known groundwater impact.
3— 3— 3— 3— 3— 3— 3— 3— 3— 3— 3-1
�A
DUMPSTER I
A P�� I j
I I —
I r I
GRAVEL_ I CONCRETE
L— — — — — I
OFFICE
I I
I
I ISIDEWALK
E --_--_-- _ _ I BMW-7B
Z--s----- _1
I T I r Proposed Monitoring Well Location
I GRAVEL I
I
PAVED I
� BMW-1A
I
I II
I V �,g
_4
(-----------� I
I CONCRETE
I
I
I
I
i
W
STORAGE
ROOM
(n PAVED
0 WAREHOUSE
I V
I
j
N
Ln i
r-
Ln
II
Q
W
LANDSCAPE
I V)
/ - - LANDSCAPE_
�f
W
Q
MW-3
3�:
w �
—E --
e—E
j TW-2 I OMW-4 ..
O
_5
Q -
PAVED j ®n
B-3
8TW-4I
r�
I Y
I
j MW-5 I
U I
W
*M-5
10
i.
U j
I ,B-z
'
I
I
op
oLd
z
q
S
()
I
0 o
IO U
O
=
W_3
W
Q
'
�
I
©I
J
4TWE-60
MW-2
TANKS 15.000 GAL—
---ClncwelV
—[ —E
-------I
,
YADKIN AVENUE
- = FENCE
N
4
—• —• —
= OVERHEAD ELECTRICAL LINE
m
o
=:
= TYPE II MONITORING WELL
co
Q
= TYPE III MONITORING WELL
a
'o 0
a
= FORMER TEMPORARY WELL LOCATION
u
LM
®O
= SOIL BORING LOCATION
g
0 4
LO
0
0
0
= PROPOSED PHASE If INJECTION WELL
m
O
=PROPOSED PHASE I DIRECT PUSH
o
INJECTION POINT
0 -
N
®
= LOCATION OF FORMER MINERAL
Z
o
�
SPIRITS UST
o 04
r,
=ESTIMATED EXTENT OF GROUNDWATER
'
< ,.
IMPACTED ABOVE NC 2L STANDARDS
o
o
Benzene (ug/O 1.5 1.8
1,2-131c1hi—ben.ene (eg/L) 20 24
%4—M.,hi—thone (og/L) 5.6 6.1
1,1—Dichl ,thone (ug/L) 16 14
vinyl Chloride (ug/L) 0.63 0.91
1,1—Dichloroethane (ug/L) 6J
Yrlyl chloride (ug/L) a.JJ
No other eaceeeances cl NC 2L 5lnnenree
W
Z m
O l­- . L.
F- Z w Q
Q W
U U
O W
J U
W
O W LLJ
W Z Q U
Z
°°ZwZ (�
LLJ 0 Y
}�O up
_ 0
LL 0- I J O ly
O LL_ (14
C d'QIO�!
d V) C"! 1
MW-21) 06/29/2011 0
Noe eeeencee nl NC 2L fito—l—
a
I m
MW-3 O6/29/2011 z
No a ceeeences of NC 2L Slandered Z
o
Z
0 15 30 60
APPROXIMATE SCALE IN FEET o i
z

Goodrich, David
From: Ulishney, Adam
Sent: Thursday, November 17, 2011 1:07 PM
To: [e-mail]; Goodrich, David
Cc: 'Schoepke, Robert'
Subject: RE: Safety-Kleen Charlotte New Monitoring Well Installation
Genna,
Based on a review of the map, the Hazardous Waste Section (HWS) feels that the proposed location of the.monitoring
well depicted on your map is adequately located to serve as a background well at the site. If you have any questions or
would like to discuss the matter please feel free to contact me.
Adam U11shnev
.ydr ogeologist V
Forth Carolina lRazardons Waste Section
Phone: [phone]
Email: adammlishney(i ,nedenr.2ov
NOTICE: Effective October 24, 2011 our new address will be:
217 West Jones St.
Raleigh, NC 27603
and effective October 24, 2011 my new phone number will be:
919-707-8210
Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed to third
parties unless the content is exempt by statute or other regulation.
From: Genna Olson Imailto:[e-mail]
Sent: Tuesday, November 15, 2011 12.08 PM
To: Goodrich, David; Ulishney, Adam
Cc: 'Schoepke, Robert'
Subject: Safety-Kleen Charlotte New Monitoring Well Installation
David and Adam,
The UIC Program (David) has requested installation of a monitoring well between TW-5 and MW-4 at the site. The RCRA
Program (Adam) has indicated that replacement of well TW-5 may be required if it continues to be dry. We were hoping
to install just one well that will fulfill both of your requirements. We also wanted to let you know about some site
constraints that limit the proposed well location. Well TW-5 was installed with a small direct -push drilling rig (which is
why it is so shallow it is usually dry). However, to get a well down to water, we need to use a full-size drilling rig and
there are overhead utility lines that prevent access to this area with a full-size rig. The attached figure shows the closest
location we can access. A photo is also attached that shows the area. Please let me know if the proposed location is
acceptable.
Thanks
Genna K. Olson, P.G. I Senior Project Manager I ATC Associates Inc. I Raleigh, NC
[phone] direct 1 [phone] mobile

DOCUMENTS ASSOCIATED
WITH
THE ORIGINAL PERMIT
APPLICATION
(ISSUED OCTOBER 21, 2011)
a

i
Goodrich, David
To: [e-mail]
Cc: Schutte, Maria; Pitner, Andrew
Subject: Safety -Clean Site Injection Activities under Injection Permit Number W10300181
Justin,
Thank you for contacting me this morning regarding your intentions of installing the additional monitoring well (as
required by the permit) at the subject site on Monday, December 12th, and subsequent sampling of this well on Tuesday,
December 13`h
It is my further understanding that injection activities will commence at the site on Wednesday, December 14`h
I am copying this transmission to the Mooresville Regional Office for their information.
Regards,
David Goodrich
Aquifer Protection Section Central Office

Shrestha, Shristi R
From:
Shrestha, Shristi R
Sent:
Thursday, February 09, 2017 2:46 PM
To:
'Genna Olson'
Cc:
Schoepke, Robert A
Subject:
RE: WI0300181 Safety Kleen systems
Genna,
I have reviewed the December 2016 sampling results. For the next round of sampling I would like to see sulfate results
for all 3 wells( mw 2, mw 4 and mw S). We would need 2 consecutive samples to prove concentrations have remained
below 2L limits. Hence please include Mw 4 also for March sampling.
Shristi
Shristi R. Shrestha
Hydrogeologist
Water Quality Regional Operations Section
Animal Feeding Operations & Groundwater Protection Branch
North Carolina Department of Environmental Quality
919 807-6406 office
shristi.shrestha(cDncdenr.gov
512N. Salisbury Street
1636 Mail Service Center
Raleigh, NC 27699 1636
<�Nothtng Compares--,
Email correspondence to and from this address is subject to the
North Carolina Public Records Laud and may be disclosed to third parties.
From: Genna Olson [mailto:[e-mail]]
Sent: Thursday, January 26, 2017 12:44 PM
To: Shrestha, Shristi R <[e-mail]>
Cc: Schoepke, Robert A <[e-mail]>
Subject: RE: W10300181 Safety Kleen systems
Will do. Let me know if you need anything else.
From: Shrestha, Shristi R [mailto:[e-mail]]
Sent: Thursday, January 26, 2017 9:29 AM
To: Genna Olson <[e-mail]>
Cc: Schoepke, Robert A <Robert.Schoepke safety-kleen.com>
Subject: RE: W10300181 Safety Kleen systems

Please mail me a hard copy for this and the results for March.
Thanks,
Shristi
Shristi R. Shrestha
Hydrogeologist
Water Quality Regional Operations Section
Animal Feeding Operations & Groundwater Protection Branch
North Carolina Department of Environmental Quality
919 807-6406 office
shristi.shrestha(cD_ncdenr.gov
512N. Salisbury Street
1636 Mail Service Center
Raleigh, NC 27699 1636
F -.Nothing Compares --,.,.-
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.
From: Genna Olson[mailto:[e-mail]]
Sent: Tuesday, January 24, 2017 4:36 PM
To: Shrestha, Shristi R <[e-mail]>
Cc: Schoepke, Robert A <[e-mail]>
Subject: RE: W10300181 Safety Kleen systems
Shristi — Attached is a report documenting sampling of selected wells for sulfate at the above referenced facility, as
discussed in the emails below. Based on the results, we plan to sample two of the wells again in March 2017. Let me
know if you have any questions. Also please let me know if you would like me to mail a hard copy of the attached
report to you or any other NCDEQ offices.
Thanks,
Genna
Genna Olson I SENIOR PROJECT MANAGER I ATC Group Services LLC
[phone] [phone] mobile
2725 E. Millbrook Road, Suite 121 1 Raleigh, NC 27604
[phone] fax I [e-mail] I www.atcgroupservices.com
Note that my [e-mail] email address will no longer be active after May 31, 2016,
please use my [e-mail] email address.
This email and its attachments may contain confidential and/or privileged information for the sole use of the intended recipient(s). If you
are not the intended recipient, any use, distribution or copying of the information contained in this email and its attachments is strictly
prohibited. If you have received this email in error, please notify the sender by replying to this message and immediately delete and
destroy any copies of this email and any attachments. The views or opinions expressed are the author's own and may not reflect the
titPIAIG — nr%ininnc of AT(`

From: Genna Olson
Sent: Wednesday, December 07, 2016 5:39 PM
To: 'Shrestha, Shristi R' <shristi.shrestha ncdenr.gov>; Justin Ballard <[e-mail]>
Cc:'Schoepke, Robert A' <[e-mail]>
Subject: RE: W10300181 Safety Kleen systems
Shristi — We are planning to do another sampling event for sulfate for wells MW-2, 4, and 5 to see if concentrations
have reduced. We will forward you a report documenting the sampling upon completion. Let me know if you have
any questions in the meantime.
Thanks,
Genna
Genna Olson I SENIOR PROJECT MANAGER I ATC Group Services LLC
[phone] [phone] mobile
2725 E. Millbrook Road, Suite 121 1 Raleigh, NC 27604
[phone] fax I [e-mail] I www.atcgroupservices.com
Note that my nenna.o/[e-mail] email address will no longer be active after May 31, 2016,
please use my genna.o/son0atcassociates.com email address.
This email and its attachments may contain confidential and/or privileged information for the sole use of the intended recipient{s}. If you
are not the intended recipient, any use, distribution or copying of the information contained in this email and its attachments is strictly
prohibited. If you have received this email in error, please notify the sender by replying to this message and immediately delete and
destroy any copies of this email and any attaclmients. The views or opinions expressed are the author's oven and may not reflect the
views or opinions of ATC.
From: Shrestha, Shristi R [mailto:[e-mail]]
Sent: Monday, December 05, 2016 10:58 AM
To: Genna Olson<[e-mail]>; Justin Ballard <justin.ballard@ atcassociates.com>
Subject: RE: W10300181 Safety Kleen systems
Good morning,
Is there monitoring going on at the site? Or if you have monitoring report later than May 2013 please send it to me.
According to the results in May 2013 , sulfate levels are still higher than pre -injection levels in MW-2, 4, and 5. We
cannot close out the permit because of high sulfate levels.
Per 15A NCAC 02L.0202, injectants must attenuate to pre -injection concentration levels or groundwater standards
whichever is greater in order for the permit to be closed out. Otherwise a corrective action is required.
Thank you for your cooperation.
Shristi
Shristi R. Shrestha
Hydrogeologist
Water Quality Regional Operations Section
Animal Feeding Operations & Groundwater Protection Branch
North Carolina Department of Environmental Quality
919 807-6406 office
shristi.shrestha(a7ncdenr.eov
512N. Salisbury Street
IAIR Moil Qmminm (:cnfnr

Raleigh, NC 27699 1636
N, -
-'�N thing Compares--,-,..
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.
From: Genna Olson [mailto:[e-mail]]
Sent: Thursday, November 03, 2016 9:59 AM
To: Shrestha, Shristi R <[e-mail]>; Justin Ballard <[e-mail]>
Cc: Goodrich, David <david.goodrich @ncdenr.gov>; Rogers, Michael <[e-mail]>; Watts, Debra
<[e-mail]>; Schutte, Maria <[e-mail]>
Subject: RE: W10300181 Safety Kleen systems
Attached are reports documenting the injection and four post -injection monitoring events. Let me know if you need
anything else.
Genna
Genna Olson I SENIOR PROJECT MANAGER i ATC Group Services LLC
[phone] i [phone] mobile
2725 E. Millbrook Road, Suite 121 i Raleigh, NC 27604
[phone] fax I [e-mail] i www.atcgroupservices.com
Note that my aenna.olsonCdcardno.com email address will no longer be active after May 31, 2016,
please use my aenna.olson0atcassociates.com email address.
This email and its attachments may contain confidential and/or privileged information for the sole use of the intended recipients). If you
are not the intended recipient, any use, distribution or copying of the information contained in this email and its attachments is strictly
prohibited, If you have received this email in error, please notify the sender by replying to this message and immediately delete and
destroy any copies of this email and any attachments. The views or opinions expressed are the author's own and may not reflect the
views or opinions of ATC.
From: Shrestha, Shristi R [mailto:[e-mail]]
Sent: Wednesday, November 02, 2016 3:06 PM
To: Justin Ballard <[e-mail]>; Genna Olson <[e-mail]>
Cc: Goodrich, David <[e-mail]>; Rogers, Michael <[e-mail]>; Watts, Debra
<[e-mail]>; Schutte, Maria <[e-mail]>
Subject: W10300181 Safety Kleen systems
Good afternoon,
The permit for the above mentioned site expired on 09/30/2014. Our record indicate that we have not received final
project evaluation report. If the report was submitted then please send me a digital version of it . If not please submit
report or let me know about the status of the facility.

Thank you for your cooperation.
Best Regards,
Shristi
Shristi R. Shrestha
Hydrogeologist
Water Quality Regional Operations Section
Animal Feeding Operations & Groundwater Protection Branch
North Carolina Department of Environmental Quality
919 807-6406 office
shristi.shresthaCaD-ncdenr.gov
512N. Salisbury Street
1636 Mail Service Center
Raleigh, NC 27699 1636
--Nothing Compares_ -x- ,,.
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.

Shrestha, Shristi R
From: Shrestha, Shristi R
Sent: Monday, December 05, 2016 10:58 AM
To: 'Genna Olson'; Justin Ballard
Subject: RE: WI0300181 Safety Kleen systems
Good morning,
Is there monitoring going on at the site? Or if you have monitoring report later than May 2013 please send it to me .
According to the results in May 2013 , sulfate levels are still higher than pre -injection levels in MW-2, 4, and 5. We
cannot close out the permit because of high sulfate levels.
Per 15A NCAC 02L.0202, injectants must attenuate to pre -injection concentration levels or groundwater standards
whichever is greater in order for the permit to be closed out. Otherwise a corrective action is required.
Thank you for your cooperation.
Shristi
Shristi R. Shrestha
Hydrogeologist
Water Quality Regional Operations Section
Animal Feeding Operations & Groundwater Protection Branch
North Carolina Department of Environmental Quality
919 807-6406 office
shristi.shrestha(cD-ncdenr.gov
512N. Salisbury Street
1636 Mail Service Center
Raleigh, NC 27699 1636
—Nothing Compares_--,.
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.
From: Genna Olson[mailto:[e-mail]]
Sent: Thursday, November 03, 2016 9:59 AM
To: Shrestha, Shristi R <[e-mail]>; Justin Ballard<[e-mail]>
Cc: Goodrich, David <[e-mail]>; Rogers, Michael <[e-mail]>; Watts, Debra
<[e-mail]>; Schutte, Maria <[e-mail]>
Subject: RE: W10300181 Safety Kleen systems
Attached are reports documenting the injection and four post -injection monitoring events. Let me know if you need
anything else.
Genna

Genna Olson I SENIOR PROJECT MANAGER I ATC Group Services LLC
[phone] [phone] mobile
2725 E. Millbrook Road, Suite 121 1 Raleigh, NC 27604
[phone] fax I [e-mail] I www.atcgrouoservices.com
Note that my [e-mail] email address will no longer be active after May 31, 2016,
please use my cenna.olson0atcassociates.com email address.
This email and its attachments may contain confidential and/or privileged information for the sole use of the intended reeipient(s). If you
are riot the intended recipient, any use, distribution or copying of the information contained in this email and its attachments is strictly
prohibited, if you have received this email in error, please notify the sender by replying to this message and immediately delete and
destroy any copies of this email and any attachments. The views or opinions expressed are the author's own and may not reflect the
views or opinions of ATC.
From: Shrestha, Shristi R [mailto:[e-mail]]
Sent: Wednesday, November 02, 2016 3:06 PM
To: Justin Ballard <[e-mail]>; Genna Olson <[e-mail]>
Cc: Goodrich, David <[e-mail]>; Rogers, Michael <[e-mail]>; Watts, Debra
<[e-mail]>; Schutte, Maria <[e-mail]>
Subject: W10300181 Safety Kleen systems
Good afternoon,
The permit for the above mentioned site expired on 09/30/2014. Our record indicate that we have not received final
project evaluation report. If the report was submitted then please send me a digital version of it . If not please submit
report or let me know about the status of the facility.
Thank you for your cooperation.
Best Regards,
Shristi
Shristi R. Shrestha
Hydrogeologist
Water Quality Regional Operations Section
Animal Feeding Operations & Groundwater Protection Branch
North Carolina Department of Environmental Quality
919 807-6406 office
shristi.shrestha(aD-ncdenr.gov
512N. Salisbury Street
1636 Mail Service Center
Raleigh, NC 27699 1636
Nothing Compares--,-,
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.

Shrestha, Shristi R
From: Shrestha, Shristi R
Sent: Wednesday, November 02, 2016 3:06 PM
To: [e-mail]; [e-mail]
Cc: Goodrich, David; Rogers, Michael; Watts, Debra; Schutte, Maria
Subject: WI0300181 Safety Kleen systems
Good afternoon,
The permit for the above mentioned site expired on 09/30/2014. Our record indicate that we have not received final
project evaluation report. If the report was submitted then please send me a digital version of it . If not please submit
report or let me know about the status of the facility.
Thank you for your cooperation.
Best Regards,
Shristi
Shristi R. Shrestha
Hydrogeologist
Water Quality Regional Operations Section
Animal Feeding Operations & Groundwater Protection Branch
North Carolina Department of Environmental Quality
919 807-6406 office
shristi.shrestha(a)-ncdenr.gov
512N. Salisbury Street
1636 Mail Service Center
Raleigh, NC 27699 1636
' "`Nothing Compares,---,,-,
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.

Application Reviewer:
Pre -Review. Conducted?
AN Yes ❑ No O.K. to Process? [ Yes ❑ No
If No, What Action Is Needed? ❑ Pre -Review Return
❑ Hold, Pending Receipt of Addinfo.:
Name/Affiliation of Person Contacted:
Date(s) of Contact: ❑ By Phone ❑ By E-Mail -❑ By Letter
Owner: ❑ Existing ® Unknown Owner Type Non -Gov't (❑ Ind. or ® Org) ❑ Gov. -Municipal
❑ Gov. -County ❑ Gov. -State ❑ Gov. -Federal
Facility/Operation: ❑ Proposed ❑ Existing ❑ Facility ❑ Operation
Regulated Activities:
Application/Permit:
Permit Type:
❑ Injection Water Only GSHP Well System (5QW)
❑ Injection Mixed Fluid GSHP Well System (5QM)
❑ Injection Tracer Well (5T)
❑ Injection Experimental Technology (5X25)
Project Type: ® New ❑ Major Mod.
Notes:
Injection In situ Groundwater Remediation Well (5I)
❑ Injection Heating/Cooling Water Return Well (5A7)
❑ Injection Other Wells (5Z)
❑ Injection Aquifer Recharge (5R21)
❑ Minor Mod. ❑ Renewal ❑ Renewal w/ Mod.
FORM: BIMS 10/04/2007

AnpIication Reviewer: �
}
Pre -Review: Conducted? --L, "Yes ❑ No
O.K. to Process? 1L Yes ❑ No
If No, What Action Is Needed? ❑ Pre -Review Return
❑ Hold, Pending Receipt of Addinfo.:
Name/Affiliation of Person Contacted:
Date(s) of Contact: ❑ By Phone ❑ By E-Mail ❑ By Letter
Owner: [] Existing ❑ Unlmown Owner Type Non -Gov't (❑ Ind. or ® Org) ❑ Gov. -Municipal
❑ Gov. -County ❑ Gov. -State ❑ Gov. -Federal
Facility/Operation: ❑ Proposed ® Existing P� Facility Operation
Regulated Activities:
Application/Permit:,
Permit Type:
❑ Injection Water Only GSHP Well. System (5QW)
❑ Injection Mixed Fluid GSHP Well System (5QM)
❑ Injection -Tracer Well (5T)
❑ Injection Experimental Technology.(5X25)
Injection In situ Groundwater Remediation Well (5I)
❑ Injection Heating/Cooling Water Return Well (5A7)
❑ Injection Other Wells (5Z)
❑ Injection Aquifer Recharge (5R21)
Project Type: ❑ New [ Major Mod. ❑ Minor Mod. ❑ Renewal ❑ Renewal w/ Mod.
Notes:
r—cvtr—.1.2.
FORM: BIMS 10/04/2007