WI0400345_PERMIT_20190920

Central Files: APS _ SWP _
9/20/2019
Permit Number WI0400345 Permit Tracking Slip
Program Category Status Project Type
Ground Water Issued Renewal
Permit Type
Version Permit Classification
Injection In situ Groundwater Remediation Well Individual
Primary Reviewer
shristi.shrestha
Coastal SWRule
Permitted Flow
Facility
Permit Contact Affiliation
Facility Name
Energizer Manufacturing Inc.
Location Address
419 Art Bryan Dr
Asheboro
Owner
Major/Minor Region
Minor Winston-Salem
County
Randolph
Facility Contact Affiliation
NC 27203 Scott Boyle
419 Art Bryan Dr
Asheboro
NC 27203
Owner Name
Energizer Manufacturing Inc
Dates/Events
Owner Type
Non -Government
Owner Affiliation
Steve Hall
419 Art Bryan Dr
Asheboro
NC 27203308
Orig Issue
5/30/2014
App Received Draft Initiated
Scheduled
Issuance Public Notice Issue Effective Expiration
7/17/2019 9/20/2019 9/27/2019 8/30/2024
Regulated Activities
Groundwater remediation
Well Construction
Outfall
Requested /Received Events
RO staff report requested
RO staff report received
7/17/19
9/16/19
Waterbody Name Streamlndex Number Current Class Subbasin

Central Files: APS _ SWP _
9/19/2019
Permit Number WI0400345 Permit Tracking Slip
Program Category
Ground Water
Permit Type
Status Project Type
In review Renewal
Version Permit Classification
Injection In situ Groundwater Remediation Well Individual
Primary Reviewer
shristi.shrestha
Coastal SWRuIe
Permitted Flow
Facility
Permit Contact Affiliation
Facility Name
Energizer Manufacturing Inc.
Location Address
419 Art Bryan Dr
Asheboro NC 27203
Owner
Major/Minor Region
Minor Winston-Salem
County
Randolph
Facility Contact Affiliation
Scott Boyle
419 Art Bryan Dr
Asheboro
NC 27203
Owner Name
Energizer Manufacturing Inc
Dates/Events
Owner Type
Non -Government
Owner Affiliation
Steve Hall
419 Art Bryan Dr
Asheboro
NC 27203308
Orig Issue
5/30/2014
App Received Draft Initiated
7/17/2019
Scheduled
Issuance Public Notice Issue Effective Expiration
Regulated Activities Requested /Received Events
Groundwater remediation
Well Construction
Outfall
RO staff report requested
RO staff report received
7/17/19
9/16/19
Waterbody Name Streamlndex Number Current Class Subbasin

DIVISION OF WATER RESOURCES
WQROS
September 19, 2019
MEMORANDUM
TO: Jay Zimmerman
FROM: Shristi Shrestha
RE: Renewal of permit to inject (Permit #WI0400345)
Energizer Manufacturing Inc. facility
Randolph County
I recommend that Permit Number WI0400345 be renewed. Please refer to the attached memo for further details. This is
only a renewal for continued monitoring.
REGIONAL OFFICE COMMENTS:
The Winston-Salem Regional Office recommends permit issuance.

DIVISION OF WATER RESOURCES
WATER QUALITY REGIONAL OPERATIONS SECTION
May 30, 2014
PERMIT ISSUANCE MEMO
TO: Debra Watts
FROM: Thomas Slusser
RE: Permit For Air Sparging Enhanced By Pneumatic Fracturing
Energizer Battery Manufacturing Facility
I recommend that permit number WI0400345 be issued to Energizer Battery Manufacturing, Inc. to inject nitrogen
gas for pneumatic fracturing in order to enhance the effectiveness of ambient air injection to remediate soils and
groundwater contaminated with chlorinated solvents.
SITE DESCRIPTION This project will take place at a battery manufacturing facility in Asheboro, Randolph
County. The facility is located in the midst of an area consisting of several industries commercial enterprises, and a
quarry. Residential areas are nearby this industrial/ commercial area, but are several hundred feet away from the
contaminant plume that is the focus of this permit.
HYDROGEOLOGIC DESCRIPTION The facility is located in the western Piedmont. Unconsolidated sediments occur to
depths up to 41 feet, which is underlain by partially weathered rock (PWR) encountered at depths of 25-63 feet
below land surface. Below the PWR is fractured metavolcanic bedrock of the Uwharrie Formation of the Carolina
Slate Belt. Local groundwater hydrology is significantly affected by a nearby quarry's dewatering activities, which
effectively pulls area groundwater downward and south-southwest toward the quarry floor. The quarry floor is
approximately 280 feet below land surface of the facility.
EXTENT OF CONTAMINATION Contaminants consist of chlorinated solvents such as TCE and TCA, as well
as the stabilizer compound 1,4-Dioxane, which is known to transport more extensively than the solvents. The
contaminant plume is approximately 2500 feet long, 800 feet wide, and 260 feet deep. Refer to Figures 7-12 for
details.
PROPOSED INJECTION Pneumatic fracturing and air injection with soil vapor extraction is planned to occur
in two phases: a pilot test and a larger -scale effort based on the results of the pilot test. The pilot test will be
conducted in the vicinity of the former solvent recovery operation and will consist of pneumatic fracturing in two
boreholes, one drilled to a depth of 50 feet and the other 30 feet. Fracturing will begin at the bottom and will be done
in 4-foot increments up to -5-10 feet below land surface. After fracturing the boreholes will be converted into air
injection wells. The larger -scale effort is planned to occur in similar manner using 12 additional wells spread
throughout the facility. Refer to Figure 13 for details on well locations.
HOW IT WORKS Nitrogen gas is injected under pressure at discreet intervals to induce openings in the low -
permeability soils. Ambient air is injected into the groundwater in order to volatilise contaminant compounds,
which are recovered by a soil vapor extraction system utilising wells screened in the vadose zone, above the water
table.
MONITORING Monitoring of the fracturing will occur in accordance with the fracturing plan described in
Attachment 5 of the permit application package and with agreed -upon modifications. In addition to the wells
proposed for contaminant analyses before and after fracturing and for pressure during fracturing, MW-26D (-260-ft
deep) will also be monitored as well as a new observation well that will be installed to evaluate fracturing occurring
at depths of 30-50 feet.
The groundwater monitoring plan consists of sampling all monitoring wells semi-annually in accordance
with the Remedial Action Plan approve by DWM's Inactive Hazardous Sites Branch on -February 13, 2014. Analytical
parameters include VOCs, 1,4-Dioxane, field parameters (pH, dissolved oxygen, conductivity, oxidation-reduction

potential, temperature), and geochemical indicator parameters such as chloride, sulphate, alkalinity, TDS, iron, and
manganese.
EPIDEMIOLOGY Health risk evaluations of ambient air and nitrogen gas are not necessary.
REGIONAL OFFICE COMMENTS The Winston-Salem Regional Office recommends issuance of this permit. WSRO
comments regarding monitoring well MW-26D sampling have been included in the permit.

ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
LINDA CULPEPPER
Director
Steve Hall
Energizer Manufacturing Inc.
419 Art Bryan Drive
Asheboro NC 27203-3089
NORTHCAROLINA
Environmental Quality
September 19, 2019
Re: Renewal of Injection Permit WI0400345
Energizer Manufacturing Inc.
Randolph County, NC
Dear Mr. Hall:
In accordance with the permit renewal received on July 17, 2019, we are forwarding permit number
WI0400345. This permit is to continue groundwater monitoring of the Energizer battery manufacturing
facility located at 419 Art Bryan Drive in Asheboro, Randolph County, NC 27203.This permit shall be
effective from September 27, 2019 until August 30, 2024 and shall be subject to the conditions and
limitations stated therein, including the requirement to submit a Final Project Evaluation (FPE) as stated
in PART VII — MONITORING AND REPORTING REQUIREMENTS. Please read the entire permit
to ensure that you are aware of all compliance requirements of the permit.
Please note the following:
• Per permit condition Part VI, the proposed monitoring plan from the previous permit of
May 30, 2014 shall be followed
• Per permit condition Part VI.5, prior to closing this permit, the Permittee must meet
groundwater quality standards or pre -injection levels, whichever concentration is higher,
for all of the injection constituents; otherwise, continued monitoring as approved in the
monitoring plan will be required until such levels can be established;
• Per permit conditions Part VI.3 &4, and IX.2(G), within 30 days after each injection
event, please provide the well construction (if not previously submitted) and injection
information on the applicable forms listed below. Note: if well
construction/abandonment information is essentially the same (e.g., direct push points or
geo-probes), then only one GW-1 or GW-30 form is needed. Just indicate in the
comments section on the form the total number of well points. These forms are available
on the Division of Water Resources' website at http://deq.nc.gov/about/divisions/water-
North Carolina Department of Environmental Quality I Division of Water Resources
5l2 North Salisbury Street 11636 Mall Service Center I Raleigh, North Carolina 27699-1636
919.707.9000

resources/water-resources-permits/wastewater-branch/.round-water-
p rotection/ground-water-reporting-forms
➢ Injection Event Record
> Well Construction Record (GW-1)
> Well Abandonment Record (GW-30)
In order to continue uninterrupted legal use of this well for the stated purpose, you should submit an
application to renew the permit 120 days prior to its expiration date. As indicated in the permit, this
permit is not transferable to any person without prior notice to, and approval by, the Director of the
Division of Water Resources. If you have any questions regarding your permit or the Underground
Injection Control Program, please call me at [phone].
Best Regards,
OgixeotAa
Shristi Shrestha
Underground Injection Control (UIC) Hydrogeologist
Division of Water Resources
Water Quality Regional Operations Section
cc: Lon Snider- Jim Gonsiewski, WQROS — Winston-Salem Regional Office
Central Office File, WI0400345
Alan Martin, ERM NC Inc., 15720 John J Delaney Drive, Suite 120, Charlotte, NC 28277

NORTH CAROLINA
ENVIRONMENTAL MANAGEMENT COMMISSION
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
RALEIGH, NORTH CAROLINA
PERMIT FOR THE CONSTRUCTION AND OPERATION OF A WELL FOR INJECTION
In accordance with the provisions of Article 7, Chapter 87; Article 21, Chapter 143, and other
applicable Laws, Rules, and Regulations
PERMISSION IS HEREBY GRANTED TO
Energizer Battery Manufacturing, Inc.
For continued groundwater monitoring of the Energizer battery manufacturing facility located at
419 Art Bryan Drive in Asheboro, Randolph County, NC 27203 in accordance with the application
submitted July 17, 2019, and in conformity with the specifications and supporting data, all of which
are filed with the Department of Environment and Natural Resources and are considered a part of
this permit.
This permit is for continued monitoring only, and does not waive any provisions of the Water Use
Act or any other applicable Laws, Rules, or Regulations. A permit modification and permit renewal
application (if applicable) shall be submitted for any future injections. Operation and use of an
injection well shall be in compliance with Title 15A North Carolina Administrative Code 02C
.0100 and .0200, and any other Laws, Rules, and Regulations pertaining to well construction and
use.
This permit shall be effective, unless revoked, from the date of its issuance until August 30, 2024,
and shall be subject to the specified conditions and limitations set forth in Parts I through X hereof.
Permit issued this the 27th day of September, 2019.
For Linda Culpepper, Director
Division of Water Resources
By Authority of the Environmental Management Commission.
Permit No. WI0400345
ver. 2-25-2016 UIC-5I/5T
PAGE 1 OF 7

PART I — PERMIT GENERAL CONDITIONS
1. The Permittee shall comply with all conditions of this permit and with the standards and criteria
specified in Criteria and Standards Applicable to Injection Wells (15A NCAC 2C .0200).
Noncompliance with conditions of this permit constitutes a violation of the North Carolina
Well Construction Act and is grounds for enforcement action as provided for in N.C.G.S. 87-
94.
2. This permit shall become voidable unless the facility is constructed in accordance with the
conditions of this permit, the approved plans and specifications, and other supporting data [15A
NCAC 02C .0211(1)].
3. This permit is valid only for construction or operation of the number of injection wells
described in the application and other supporting data. Construction of additional injection
wells must be approved in advance by the Division of Water Resources (DWR) [15A NCAC
.0211(a)].
4. This permit is not transferable without prior notice and approval. In the event there is a desire
for the facility to change ownership, or there is a name change of the Permittee, a formal permit
amendment request and any supporting materials must be submitted at least 30 days prior to
the date of the change [15A NCAC 02C .0211(q)].
5. The issuance of this permit shall not relieve the Permittee of the responsibility of complying
with any and all statutes, rules, regulations, or ordinances that may be imposed by other local,
state, and federal agencies having jurisdiction. Furthermore, the issuance of this permit does
not imply that all regulatory requirements have been met [15A NCAC 02C .0203].
PART II - WELL CONSTRUCTION GENERAL CONDITIONS
1. Each injection well shall not hydraulically connect separate aquifers [15A NCAC 02C
.0211(c)].
2. Multi -screened wells shall not hydraulically connect different aquifers or zones having
differences in water quality that would result in a degradation of any aquifer or zone [15A
NCAC 02C .0225(g) (17)].
3. Each injection well shall be constructed in such a manner that water from land surface cannot
migrate into the gravel pack or well screen [15A NCAC 02C .0225(g)(4)].
4. Bentonite grout shall not be used to seal any water -bearing zone with a chloride concentration
equal to or greater than 1,500 milligrams per liter. In areas where elevated chloride levels are
known to exist or are probable, such as coastal areas, chloride levels shall be verified in the
field to determine existing conditions. [15A NCAC .0225(g)(8)].
5. Each injection well shall be secured to reasonably insure against unauthorized access and use.
Each well shall be permanently labeled with a warning that it is for injection purposes and the
Permit No. WI0400345 PAGE 2 OF 7
ver. 2-25-2016 UIC-5I/5T

entrance to each well shall be secured with a locking cap as defined in G.S. 87-85(16) [15A
NCAC 02C .0225(g) (23)].
6. Each injection well shall be afforded reasonable protection against damage during construction
and use [15A NCAC 02C .0225(i)(3)].
7. Each permanent injection well shall have a permanently affixed identification plate [15A
NCAC .0225(g) (20)].
8. A copy of the completed Well Construction Record (Form GW-1) shall be submitted as
described in Part VI.3 of this permit (the original document goes to the address indicated on
the form).
PART III - WELL CONSTRUCTION SPECIAL CONDITIONS
1. At least forty-eight (48) hours prior to constructing or operating each injection well, the
Permittee shall notify the Underground Injection Control (UIC) Central Office staff, telephone
number 919-807-6406, and the Winston-Salem Regional Office staff, telephone number 336-
776-9800[15A NCAC 02C .0211(k)].
PART IV - OPERATION AND USE CONDITIONS
1. The Permittee shall be required to comply with the terms and conditions of this permit even
if compliance requires a reduction or elimination of the permitted activity [15A NCAC 02C
.0211(j)].
2. The issuance of this permit shall not relieve the Permittee of the responsibility for damages
to surface water or groundwater resulting from the operation of this facility [15A NCAC 02C
.0206].
3. The injection facility shall be properly maintained and operated at all times to achieve
compliance with the conditions of this permit and the rules of 15A NCAC 02C .0200, even
if compliance requires a reduction or elimination of the permitted activity [15A NCAC 02C
.0211(j)].
4. In the event that the facility fails to perform satisfactorily, including the creation of nuisance
conditions or failure of the injection zone to adequately assimilate the injected fluid, the
Permittee shall take immediate corrective 'actions that may be required, such as the repair,
modification, or abandonment of the injection facility [15A NCAC 02C .0206].
Permit No. WI0400345 PAGE 3 OF 7
ver. 2-25-2016 UIC-5I/5T

PART V - INSPECTIONS [15A NCAC 02C .0211(k)]
1. Any duly authorized officer, employee, or representative of the Division of Water Resources
(DWR) may, upon presentation of credentials, enter and inspect any property, premises, or
place on or related to the injection facility at any reasonable time for the purpose of determining
compliance with this permit, may inspect or copy any records that must be maintained under
the terms and conditions of this permit, and may obtain samples of groundwater, surface water,
or injection fluids.
2. DWR representatives shall have reasonable access for purposes of inspection, observation, and
sampling associated with injection and any related facilities as provided for in N.C.G.S. 87-
90.
3. Provisions shall be made for collecting any necessary and appropriate samples associated with
the injection facility activities.
PART VI - MONITORING AND REPORTING REQUIREMENTS
1. Since this is only a renewal permit the monitoring plan from previous permit of May 30, 2014
shall be followed. Any additional monitoring, including groundwater, surface water, or soil
sampling, .deemed necessary to ensure surface water and groundwater protection may be
established and an acceptable sampling reporting schedule shall be followed [15A NCAC 02C
.0225(j)].
2. An Annual Report with all historical monitoring results shall be submitted in bound hard copy
format with attached CD or flash drive to the WQROS Central Office, and Winston-Salem
Regional Office starting from date permit is issued. Monitoring reports shall include, a
summary of injection activities and monitoring results, analytical data presented in a
spreadsheet distinguishing between pre -injection and post injection data, and an update on the
status and location of monitoring and injection wells. Well locations may be given in a table
with the name and geographic coordinates or shown on an updated version of the site map
[15A NCAC 02C .0225(k)(2)].
3. Records of well construction, repair, or abandonment shall be submitted within 30 days of
completion of such activities [15A NCAC 02C .0225(k)(1)(A)].
4. An Injection Event Record shall be submitted within 30 days of each injection event [15A
NCAC 02C .0225(k)(1)(B)].
5. The Permittee shall submit a Final Project Evaluation (FPE) within 9 months after completing
all injection -related activity associated with this permit or produce an interim evaluation to be
submitted with a renewal application for this permit. Both the final project evaluation and
interim evaluation shall contain historical monitoring data and updated contaminant plume and
potentiometric surface maps. PLEASE NOTE: Injectants and related reaction byproducts must
attenuate to pre -injection concentrations or groundwater standards specified in rule 15A NCAC
02L .0202, whichever is greater, in order for this permit to be closed. Otherwise, corrective
action as described in Part VII may be required [15A NCAC 02C .0225(k)(2)].
Permit No. WI0400345 PAGE 4 OF 7
ver. 2-25-2016 UIC-5I/5T

6. All monitoring results, forms, and reports required in this Part shall be submitted to:
UIC Program
NC Division of Water Resources and
1636 Mail Service Center
Raleigh, NC 27699-1636
Water Quality Regional Operations Section
DWR Winston-Salem Regional Office
450 W. Hanes Mill Rd., Suite 300
Winston-Salem, NC 27105
7. The Permittee shall report any monitoring or other information that indicates noncompliance
with a specific permit condition, that a contaminant may cause a violation of applicable
groundwater quality standards, or that a malfunction of the injection system may cause the
injected fluids to migrate outside the approved injection zone or area. As specified in rule
15A NCAC 02C .0211(r), noncompliance notification shall be as follows:
(A)
(B)
(C)
Oral notification shall be given within 24 hours of the occurrence, or first knowledge
of the occurrence, to the Winston Salem Regional Office, telephone number 336-776-
9800.
Written notification shall be made within five days of the occurrence and submitted
to the addresses in Item #6 above.
The written notification shall contain a description of the noncompliance and its
cause; the period of noncompliance, including dates and times; if the noncompliance
has not been corrected, the anticipated time it is expected to continue; and any steps
taken or planned to reduce, eliminate, and prevent reoccurrence of the
noncompliance.
8. Where the Permittee becomes aware of an omission of any relevant facts in a permit
application, or of any incorrect information submitted in said application or in any report to
the Director, the relevant and correct facts or information shall be promptly submitted to the
Director by the Permittee [15A NCAC 02C .0211(b)].
PART VII - CORRECTIVE ACTION [15A NCAC 02C .0206]
1. Any injection well not constructed or operated in accordance with this permit, or the criteria
and standards specified in 15A NCAC 02C .0200, shall be subject to corrective action as
provided under rule 15A NCAC 02C .0206.
2. The following corrective actions shall apply to elevated concentrations of inj ectants or reaction
byproducts resulting from the permitted injection activity:
(A) Continued monitoring until concentrations return to pre -injection values or meet the
standards specified in 15A NCAC 02L .0202, whichever are greater. The frequency,
duration, and location of monitoring shall be appropriate for site specific conditions and
potential receptors.
B)
Groundwater quality parameters that do not attenuate as described in 2(A) above may
warrant a corrective action plan as provided under rule 15A NCAC 02C .0206, depending
on the type, concentration, and distribution of the groundwater quality standards being
exceeded.
Permit No. WI0400345 PAGE 5 OF 7
ver. 2-25-2016 UIC-5U5T

PART VIII - PERMIT RENEWAL [15A NCAC 02C .0211(b)]
In order to continue uninterrupted legal use of the injection facility for the stated purpose, the
Permittee should submit an application to renew the permit 120 days prior to its expiration date.
PART IX - CHANGE OF WELL STATUS [15A NCAC 02C .0240]
1. The Permittee shall provide written notification within 15 days of any change of status of an
injection well. Such a change would include the. discontinued use of a well for injection. If a
well is taken completely out of service temporarily, the Permittee must install a sanitary seal.
If a well is not to be used for any purpose that well must be permanently abandoned according
to 15A NCAC 2C .0240, Well Construction Standards.
2. When operations have ceased at the facility and a well will no longer be used for any purpose,
the Permittee shall abandon that injection well in accordance with the procedures specified in
15A NCAC 2C .0240, including but not limited to the following:
(A) All casing and screen materials may be removed prior to initiation of abandonment
procedures if such removal will not cause or contribute to contamination of the
groundwaters.
(B) The entire depth of each well shall be sounded before it is sealed to insure freedom
from obstructions that may interfere with sealing operations.
(C) The well shall be thoroughly disinfected, prior to sealing, if WQROS staff determines
that failure to do so could lead to the contamination of an underground source of
drinking water.
(D) Drilled wells shall be completely filled with cement grout or bentonite grout, which
shall be introduced into the well through a pipe which extends to the bottom of the well
and is raised as the well is filled.
(E) In the case of gravel -packed wells in which the casing and screens have not been
removed, neat -cement, or bentonite grout shall be injected into the well completely
filling it from the bottom of the casing to the top.
(F) In those cases when, as a result of the injection operations, a subsurface cavity has been
created, each well shall be abandoned in such a manner that will prevent the movement
of fluids into or between underground sources of drinking water and in accordance with
the terms and conditions of the permit.
(G) The Permittee shall submit a Well Abandonment Record (Form GW-30) as specified
in 15A NCAC 2C .0225(k)(1)(A) within 30 days of completion of abandonment.
Permit No. WI0400345 PAGE 6 OF 7
ver. 2-25-2016 UIC-51/5T

3. The written documentation required in Part IX (1) and (2)(G) shall be submitted to:
UIC Program
DEQ-Division of Water Resources
1636 Mail Service Center
Raleigh, NC 27699-1636
PART X — WORKER PRECAUTIONS DURING APPLICATION [15A NCAC 02C
.0225(a)]
1. Some effects reported to be associated with the product 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.
4. Safety controls should be in place to ensure that the check valve and the pressure delivery
systems are working properly.
5. The Material Safety Data Sheets should be followed to prevent incompatible or adverse
reactions and injuries.
Permit No. WI0400345 PAGE 7 OF 7
ver. 2-25-2016 UIC-5I/5T

DIVISION OF WATER RESOURCES
WATER QUALITY REGIONAL OPERATIONS SECTION
May 30, 2014.
PERMIT ISSUANCE MEMO
TO: Debra Watts
FROM: Thomas Slusser
RE: Permit For Air Sparging Enhanced By Pneumatic Fracturing
Energizer Battery Manufacturing Facility
I recommend that permit number WI0400345 be issued to Energizer Battery Manufacturing, Inc. to inject nitrogen
gas for pneumatic fracturing in order to enhance the effectiveness of ambient air injection to remediate soils and
groundwater contaminated with chlorinated solvents.
SITE DESCRIPTION This project will take place at a battery manufacturing facility in Asheboro, Randolph
County. The facility is located in the midst of an area consisting of several industries commercial enterprises, and a
quarry. Residential areas are nearby this industrial/commercial area, but are several hundred feet away from the
contaminant plume that is the focus of this permit.
HYDROGEOLOGIC DESCRIPTION The facility is located in the western Piedmont. Unconsolidated sediments occur to
depths up to 41 feet, which is underlain by partially weathered rock (PWR) encountered at depths of 25-63 feet
below land surface. Below the PWR is fractured metavolcanic bedrock of the Uwharrie Formation of the Carolina
Slate Belt. Local groundwater hydrology is significantly affected by a nearby quarry's dewatering activities, which
effectively pulls area groundwater downward and south-southwest toward the quarry floor. The quarry floor is
approximately 280 feet below land surface of the facility.
EXTENT OF CONTAMINATION Contaminants consist of chlorinated solvents such as TCE and TCA, as well
as the stabilizer compound 1,4-Dioxane, which is known to transport more extensively than the solvents. The
contaminant plume is approximately 2500 feet long, 800 feet wide, and 260 feet deep. Refer to Figures 7-12 for
details.
PROPOSED INJECTION Pneumatic fracturing and air injection with soil vapor extraction is planned to occur
in two phases: a pilot test and a larger -scale effort based on the results of the pilot test. The pilot test will be
conducted in the vicinity of the former solvent recovery operation and will consist of pneumatic fracturing in two
boreholes, one drilled to a depth of 50 feet and the other 30 feet. Fracturing will begin at the bottom and will be done
in 4-foot increments up to -5-10 feet below land surface. After fracturing the boreholes will be converted into air
injection wells. The larger -scale effort is planned to occur in similar manner using 12 additional wells spread
throughout the facility. Refer to Figure 13 for details on well locations.
HOW IT WORKS Nitrogen gas is injected under pressure at discreet intervals to induce openings in the low -
permeability soils. Ambient air is injected into the groundwater in order to volatilise contaminant compounds,
which are recovered by a soil vapor extraction system utilising wells screened in the vadose zone, above the water
table.
MONITORING Monitoring of the fracturing will occur in accordance with the fracturing plan described in
Attachment 5 of the permit application package and with agreed -upon modifications. In addition to the wells
proposed for contaminant analyses before and after fracturing and for pressure during fracturing, MW-26D (-260-ft
deep) will also be monitored as well as a new observation well that will be installed to evaluate fracturing occurring
at depths of 30-50 feet.
The groundwater monitoring plan consists of sampling all monitoring wells semi-annually in accordance
with the Remedial Action Plan approve by DWM's Inactive Hazardous Sites Branch on February 13, 2014. Analytical
parameters include VOCs, 1,4-Dioxane, field parameters (pH, dissolved oxygen, conductivity, oxidation-reduction

potential, temperature), and geochemical indicator parameters such as chloride, sulphate, alkalinity, TDS, iron, and
manganese.
EPIDEMIOLOGY Health risk evaluations of ambient air and nitrogen gas are not necessary.
REGIONAL OFFICE COMMENTS The Winston-Salem Regional Office recommends issuance of this permit. WSRO
comments regarding monitoring well MW-26D sampling have been included in the permit.

NORTH CAROLINA
ENVIRONMENTAL MANAGEMENT COMMISSION
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
RALEIGH, NORTH CAROLINA
PERMIT FOR THE CONSTRUCTION AND OPERATION OF A WELL FOR INJECTION
In accordance with the provisions of Article 7, Chapter 87; Article 21, Chapter 143, and other
applicable Laws, Rules, and Regulations
PERMISSION IS HEREBY GRANTED TO
Energizer Battery Manufacturing, Inc.
FOR THE CONSTRUCTION AND OPERATION OF 14 IN SITU REMEDIATION
INJECTION WELLS, defined in Title 15A North Carolina Administrative Code 02C
.0209(5)(b)(viii), to inject nitrogen gas and ambient air for pneumatic fracturing to enhance
volatilization and recovery of chlorinated solvents and 1,4-Dioxane. These injection wells will be
located at the Energizer battery_ manufacturing facility located at 419 Art Bryan Drive in
Asheboro, Randolph County, and will be operated in accordance with the application submitted
May 6, 2014, and in conformity with the specifications and supporting data submitted May 28,
2014, all of which are filed with the Department of Environment and Natural Resources and are
considered a part of this permit.
This permit is for Construction and Operation only, and does not waive any provisions of the
Water Use Act or any other applicable Laws, Rules, or Regulations. Operation and use of an
injection well shall be in compliance with Title 15A North Carolina Administrative Code 02C
.0100 and .0200, and any other Laws, Rules, and Regulations pertaining to well construction and
use.
This permit shall be effective, unless revoked, from the date of its issuance until May 30, 2019,
and shall be subject to the specified conditions and limitations set forth in Parts I through X
hereof.
Permit issued this the 30th day of May, 2014.
.010\c-
O. A. Reeder, Director
Division of Water Resources
By Authority of the Environmental Management Commission.
Permit No. WI0400345 PAGE 1 OF 7
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PART I - WELL CONSTRUCTION GENERAL CONDITIONS
1. The Permittee must comply with all conditions of this permit and with the standards and
criteria specified in Criteria and Standards Applicable to Injection Wells (15A NCAC 02C
.0200). Noncompliance with conditions of this permit constitutes a violation of the North
Carolina Well Construction Act and is grounds for enforcement action as provided for in
N.C.G.S. 87-94.
2. This permit may become voidable if the facility is not constructed in accordance with the
conditions of this permit, the approved plans and specifications, and other supporting data.
3. This permit is valid only for construction or operation of the number of injection wells
described in the application and other supporting data. Construction of additional injection
wells or deviation from the approved proposal must be approved in advance by the Water
Quality Regional Operations Section (WQROS).
4. Each injection well shall not hydraulically connect separate aquifers.
5. Each injection well shall be constructed in such a manner that water from land surface cannot
migrate into the gravel pack or well screen.
6. Each injection well shall be secured to reasonably insure against unauthorized access and
use. Each well shall be permanently labeled with a warning that it is for injection purposes
and the entrance to each well must be secured with a locking cap.
7. Each injection well shall be afforded reasonable protection against damage during
construction and use.
8. Each injection well shall have permanently affixed an identification plate.
PART II - WELL CONSTRUCTION SPECIAL CONDITIONS
1. At least forty-eight (48) hours prior to constructing each injection well, the Permittee shall
notify the WQROS Central Office staff, telephone number 919-807-6412, and the WQROS
Winston-Salem Regional Office staff, telephone number 336-771-5000.
2. Bentonite grout shall not be used to seal any water -bearing zone with a chloride
concentration equal to or greater than 1,500 milligrams per liter. In areas where elevated
chloride levels are known to exist or are probable, such as coastal areas, chloride levels shall
be verified in the field to determine existing conditions.
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PART III - OPERATION AND USE GENERAL CONDITIONS
1. This permit is effective only with respect to the nature, volume of materials, rate of injection,
and number of injection wells as described in the application and other supporting data.
2. This permit is not transferable without prior notice and approval. In the event there is a
desire for the facility to change ownership, or there is a name change of the Permittee, a
formal permit amendment request and any supporting materials must be submitted at least 30
days prior to the date of the change.
3. The issuance of this permit shall not relieve the Permittee of the responsibility of complying
with any and all statutes, rules, regulations, or ordinances that may be imposed by other
local, state, and federal agencies having jurisdiction. Furthermore, the issuance of this permit
does not imply that all regulatory requirements have been met.
PART IV - PERFORMANCE STANDARDS
1. The injection facility shall be effectively maintained and operated at all times so that there is
no contamination of groundwater which will render it unsatisfactory for normal use.
2. In the event that the facility fails to perform satisfactorily, including the creation of nuisance
conditions or failure of the injection zone to adequately assimilate the injected fluid, the
Permittee shall take immediate corrective actions including those actions that may be
required, such as the repair, modification, or abandonment of the injection facility.
3. The Permittee shall be required to comply with the terms and conditions of this permit even
if compliance requires a reduction or elimination of the permitted activity.
4. The issuance of this permit shall not relieve the Permittee of the responsibility for damages to
surface or groundwater resulting from the operation of this facility.
PART V - OPERATION AND MAINTENANCE REQUIREMENTS
1. The injection facility shall be properly maintained and operated at all times.
2. The Peiiiiittee shall notify WQROS staff and receive prior approval of any planned
alterations or additions in the permitted facility or activity not specifically authorized by the
peiiiiit.
3. At least forty-eight (48) hours prior to the initiation of the operation of the facility for
injection, the Permittee must notify by telephone the WQROS Central Office staff, telephone
number 919-807-6412, and the WQROS Winston-Salem Regional Office staff, telephone
number 336-771-5000. Notification is required so that staff can inspect or otherwise review
the injection facility and determine if it is in compliance with permit conditions.
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PART VI - INSPECTIONS
1. Any duly authorized officer, employee, or representative of the WQROS may, upon
presentation of credentials, enter and inspect any property, premises, or place on or related to
the injection facility at any reasonable time for the purpose of determining compliance with
this permit, may inspect or copy any records that must be maintained under the terms and
conditions of this permit, and may obtain samples of groundwater, surface water, or injection
fluids.
2. WQROS representatives shall have reasonable access for purposes of inspection,
observation, and sampling associated with injection and any related facilities as provided for
in N.C.G.S. 87-90.
3. Provisions shall be made for collecting any necessary and appropriate samples associated
with the injection facility activities.
PART VII - MONITORING AND REPORTING REQUIREMENTS
1. Monitoring of the pneumatic fracturing and air injection shall be as follows:
a. Pneumatic fracturing - Monitoring of the fracturing will occur in accordance with
the fracturing plan described in Attachment 5 of the permit application package
and with agreed -upon modifications. Proposed observation well OB-3 will be
installed to monitor fracturing occurring in depths of 30-50 feet. This well and
existing well MW-26D will be added to the wells proposed for contaminant
analyses before and after fracturing and for monitoring pressure and water levels
during fracturing.
b. Air injection — groundwater samples shall be collected from all monitoring wells
semi-annually in accordance with the Remedial Action Plan approve by DWM's
Inactive Hazardous Sites Branch on February 13, 2014. Analytical parameters
include:
i. VOCs and 1,4-Dioxane
ii. field parameters (pH, dissolved oxygen, conductivity, oxidation-reduction
potential, temperature)
iii. geochemical indicator parameters such as chloride, sulphate, alkalinity,
TDS, iron, and manganese.
2. Any additional monitoring, including groundwater, surface water, or soil sampling, deemed
necessary to ensure surface water and groundwater protection may be established and an
acceptable sampling reporting schedule shall be followed.
3. Results of the pilot test shall be submitted to the addresses in Part VIL8 below prior to
beginning the full-scale endeavor proposed in the permit application package.
4. All sample results shall be submitted to the WQROS Central Office and Winston-Salem
Regional Office within 60 days of each semi-annual monitoring event. Monitoring reports
shall include, at a minimum, analytical data and an update on the status and location of
monitoring and injection wells. Well locations may be given in a table with the name and
geographic coordinates or shown on an updated version of the site map.
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5. A Well Construction Record (Form GW-1) shall be submitted within 30 days of completion
of well construction.
6. An Injection Event Record shall be submitted within 30 days of each injection event.
7. The Permittee shall submit a final project evaluation within 9 months after completing all
injection -related activity associated with this permit or produce an interim evaluation to be
submitted with a renewal application for this permit. Both the final project evaluation and
interim evaluation shall contain historical monitoring data and updated contaminant plume
and potentiometric surface maps.
8. All monitoring results, forms, and reports required in this Part shall be submitted to:
UIC Program
Division of Water Resources
1636 Mail Service Center
Raleigh, NC 27699-1636
DWR - WQROS
Winston-Salem Regional Office
585 Waughtown Street
Winston-Salem, NC 27107
9. The Permittee shall report by telephone within 48 hours of the occurrence or first knowledge
of the occurrence, to the Winston-Salem Regional Office, telephone number 336-771-5000,
any of the following:
(A) Any occurrence at the injection facility which results in any unusual operating
circumstances;
(B) Any failure due to known or unknown reasons, that renders the facility incapable of
proper injection operations, such as mechanical or electrical failures.
10. Where the Permittee becomes aware of an omission of any relevant facts in a permit
application, or of any incorrect information submitted in said application or in any report to
the Director, the relevant and correct facts or information shall be promptly submitted to the
Director by the Permittee.
11. In the event that the permitted facility fails to perform satisfactorily, the Permittee shall take
such immediate action as may be required by the Director.
PART VIII - CORRECTIVE ACTION
1. Any injection well not constructed or operated in accordance with this permit, or the criteria
and standards specified in 15A NCAC 02C .0200, shall be subject to corrective action as
provided under rule 15A NCAC 02C .0206.
2. The following corrective actions shall apply to elevated concentrations of injectants or
reaction byproducts resulting from the permitted injection activity:
(A) Continued monitoring until concentrations return to pre -injection values or meet the
standards specified in 15A NCAC 02L .0202, whichever are greater. The frequency,
duration, and location of monitoring shall be appropriate for site specific conditions and
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potential receptors.
(B) Groundwater quality parameters that do not attenuate as described in 2(A) above may
warrant a corrective action plan as provided under rule 15A NCAC 02C .0206,
depending on the type, concentration, and distribution of the groundwater quality
standards being exceeded.
PART IX - PERMIT RENEWAL
In order to continue uninterrupted legal use of the injection facility for the stated purpose, the
Permittee must submit an application to renew the permit 120 days prior to its expiration date.
PART X - CHANGE OF WELL STATUS
1. The Permittee shall provide written notification within 15 days of any change of status of an
injection well. Such a change would include the discontinued use of a well for injection. If a
well is taken completely out of service temporarily, the Permittee must install a sanitary seal.
If a well is not to be used for any purpose that well must be permanently abandoned
according to 15A NCAC 2C .0240, Well Construction Standards.
2. When operations have ceased at the facility and a well will no longer be used for any
purpose, the Permittee shall abandon that injection well in accordance with the procedures
specified in 15A NCAC 2C .0240, including but not limited to the following:
(A) All casing and screen materials may be removed prior to initiation of abandonment
procedures if such removal will not cause or contribute to contamination of the
groundwaters.
(B) The entire depth of each well shall be sounded before it is sealed to insure freedom
from obstructions that may interfere with sealing operations.
(C) The well shall be thoroughly disinfected, prior to sealing, if WQROS staff determines
that failure to do so could lead to the contamination of an underground source of
drinking water.
(D) Drilled wells shall be completely filled with cement grout or bentonite grout, which
shall be introduced into the well through a pipe which extends to the bottom of the
well and is raised as the well is filled.
(E) In the case of gravel -packed wells in which the casing and screens have not been
removed, neat -cement, or bentonite grout shall be injected into the well completely
filling it from the bottom of the casing to the top.
(F) In those cases when, as a result of the injection operations, a subsurface cavity has
been created, each well shall be abandoned in such a manner that will prevent the
movement of fluids into or between underground sources of drinking water and in
accordance with the terms and conditions of the permit.
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(G) The Permittee shall submit a Well Abandonment Record (Form GW-30) as specified
in 15A NCAC 2C .O225(k)(1)(A) within 30 days of completion of abandonment.
3. The written documentation required in Part X (1) and (2) (G) shall be submitted to:
UIC Program
Division of Water Resources
1636 Mail Service Center
Raleigh, NC 27699-1636
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