WI0400345_APPLICATION FOR PERMIT_20190717

ERM
15720 Brixham Hill Avenue Telephone: [phone]
Suite 120 Fax: [phone]
Charlotte,NC
28277 www.erm.com
June 19, 2019 '"`"""•m
Ari
Shristi Shrestha, Hydrogeologist E %4
NCDEQ—Division of Water Resource ERM
1636 Mail Service Center
Raleigh, NC 27699-1636
910-796-7236
Reference: 0498725 RECEIVED/No
nEGt/oyyR
Subject: Application for Permit to Construct and/or Use a Well(s)for Injection
In-Situ Groundwater Remediation- Renewal without Modification
Permit No.W104000345 JUL 1 7 4
Energizer Battery Manufacturing Inc. Water
419 Art Bryan Drive—Plant II Regio cuaLty
Asheboro, Randolph County, North Carolina �tOABrationsSection
Site ID: NCD000822957
Dear Shristi:
On behalf of Energizer Battery Manufacturing, Inc. (Energizer), ERM NC, Inc. (ERM)is submitting
the enclosed Application for Permit to Construct and/or Use a Well(S)for renewal of the existing
permit without modification. A status report presenting monitoring results is included. Energizer
plans to continue operation of the existing air sparge/soil vapor extraction(AS/SVE)system for in-
situ removal of VOCs in soil and groundwater at the site. Two copies of the Application and status
report as well as a CD with electronic versions of both documents are included.
If you have any questions regarding this project please contact me at(704)541-8345.
Sincerely,
4
7. Aro&
Alan M rtin, P.G.
Project Manager
Enclosures
cc: Scott Boyle, Energizer
Tom Wilson, ERM

North Carolina Department of Environmental Quality—Division of Water Resources
APPLICATION FOR PERMIT TO CONSTRUCT AND/OR USE A WELL(S)FOR INJECTION
In Situ Groundwater Remediation(15A NCAC 02C.0225)/Tracer Injection USA NCAC 02C.0229)
Do not use this form for the following:
• In-situ remediation,tracer,or aquifer test injection wells permitted by rule(ref. 15A NCAC 02C.0217)
• remediation systems that reinject treated contaminated groundwater(Non-discharge)(ref. 15A NCAC 02T.1600)
Permit Number(to be completed by DWR): WI
APPLICATION INFORMATION
1. Project is: []New []Modification [X]Renewal without modification []Renewal with modification
2. If this application is being submitted for Renewal and/or Modification to an existing permit,provide:
(a.)Existing permit number WI0400345 Issued Date:May 30,2014&Expiration Date:May 30,2019
For all Renewals,submit a status report including monitoring results of all injection activities to date.
For Renewal without nodification only,jill out sections 1&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).
II. WELL OWNER(S)/PERMIT APPLICANT(generally the responsible party)
1. Name(s): Energizer Manufacturing,Inc.
2. Signing Official's Name*: Steve Hall Title: Plant Manager
*Signing Official must be in accordance with instructions in Part X on page 5.
3. Mailing address of Permittee/Applicant:419 Art Bryan Drive
City:Asheboro State:NC Zip:27203-3089
4. Telephone number: [phone] Email: [e-mail]
5. Status(choose one): Individual Business/Org. Federal State County Municipality
III. PROPERTY OWNER(S)(if different than well owners)
1. Name(s):__
2. Mailing address:
City: State: Zip:.
3. Telephone number: Email:
IV. PROJECT CONTACT—(generally the environmental/engineering consultant).
1. Name: Title:.
2. Company:
3. Address:
4. City: _ State: Zip:
5. Telephone number: Email:
In-Situ Groundwater Remediation Application Rev.4-9-2019 Page of 6

V. FACILITY INFORMATION
1. Facility name:— — Phone No.if available:
2. Physical address: — - — - -
City: - - - County — Zip: - -
3. Geographic Coordinates: Latitude: _ - Longitude:
Reference Datum: - Accuracy: - -
Method of Collection(i.e.,Google Earth,GPS,etc.): -
4. Brief description of business: - — -
VI. INCIDENT DESCRIPTION
1. Source and date of contamination: — —
2. List all contaminants present in soils or groundwater at the site(contaminants may be listed in groups, e.g.,gasoline,
diesel,jet fttel,fuel oil, chlorinated ethenes, chlorinated ethanes,metals,pesticides/herbicides, etc):
3. Has LNAPL or DNAPL ever been observed at the site(even if outside the injection zone)?
[]Yes If yes, list maximum measured separate phase thickness: _ feet
[]No If no,list maximum concentration of total VOCs observed at site: — ppb
4. Agency managing the contamination incident:
[]UST Section [] Superfund Section(including REC Program and DSCA sites)
[] DWR Aquifer Protection Section [] Solid Waste Section
[]Hazardous Waste Section [] Other:_ -
5. Incident manager's name: — _ —Phone No.:
6. Incident number or other incident mgmt.agency tracking number:
VII. PERMITS
List all applicable permits or construction approvals issued for the facility or incident:
1. Previous or other UIC permits issued by DWR(e.g.,NOIs)_
2. Other Non-Discharge or NPDES permit issued by DWR:-. - - - -
3. County or DEH subsurface wastewater disposal permits:.
4. Hazardous waste management or other environmental permits required by state or federal law: --
In-Situ Groundwater Remediation Application Rev.4-9-2019 Page 2 of 6

VIII. INJECTIONN SUMMARY
1. List all proposed injeetantsladditives.
NOTE: Only injectants approved by the epidemiology section of the NC Division of Public Health,Department of
Health and Human Services can be injected. Approved it jeciants can be found online at
http://deq.nc.gov/about/divisions/water-resources/water-resources-permits/wastewater-branch/ground-water-
protection/ground-water-approved-injectants. All other substances must be reviewed by the DINS prior to use.
Contact the UIC Program for more info ("919-80,E-649() if you wish to get approval for a different additive.
However,please note it may take 3 months or longer.
lnjectant: Total Amt.to be injected(gal)/event
Injectant: Total Amt.to be injected(gal)/event
Injectant: _ Total Amt.to be injected(gal)/event
Injectant: Total Amt.to be injected(gal)/event
Injectant: Total Amt.to be injected(gal)/event
2. Number of separate injection events: Duration of Event:
3. Estimated Injection rate per well: _ gallons per minute(GPM)
4. Estimated Injection pressure: pounds/square inch(PSI)
5. Temperature at point of injection: °F
6. Injection will be via:
( Existing well(s);'Total No.: ; Well Type(DPT,Permanent,etc.):
( Proposed well(s);Total No.: ;Well Type(DPT,Permanent,etc.):
7. NC Certified Well Drilling Contractor's Name(if known):
NC Well Contractor Certification No.:
8. Date to be constructed if proposed:. (attach GW-1s for existing injection wells)
9. Screened interval/Injection interval of injection wells:
Depth from to _ feet below land surface(BLS)(if multiple intervals,indicate shallowest
to deepest depth)
10. Well casing(leave blank if Geoprobes®):
Type: ( PVC ( Stainless steel( Other:
Casing depth: to ft. BLS
Type: ( PVC ( Stainless steel( Other:
Casing depth: to ft. BLS
11. Grout(leave blank if Geoprobes):
Type: ( Cement ( Bentonite ( Other:
Grout depth: to ft.BLS
Type: ( Cement ( Bentonite ( Other:_
Grout depth: to ft.BLS
to-Situ Groundwater Remediation Application Rev.4-9-2019 Page 3 of 6

IX. ATTACHMENTS—provide the following information in separate attachments. The attachments should be clearly
identified and presented in the order below to expedite review of the permit application package.
1. INJECTION ZONE—Per 15A NCAC 02C.0225ie1(2) specify the horizontal and vertical portion of the subsurface within
which the proposed injection activity will take place and beyond which no violations of groundwater quality standards shall
result from the injection as determined by an approved monitoring plan. The determination shall be based on the hydraulic
properties of the specified zone. Provide any supporting documentation in a separate attachment.
2. HYDROGEOLOGIC EVALUATION—Per 15A NCAC 02C.0225(0(31,provide a hydrogeologic evaluation of the injection
zone that includes all of the following:
(A) Regional and local geology and hydrology;
(B) Changes in Ethology underlying the facility;
(C) Depth to bedrock;
(D) Depth to the mean seasonal high water table;
(E) Hydraulic conductivity,transmissivity,and storativity,of the injection zone based on tests of site-specific material,
including a description of the test(s)used to determine these parameters;
(F) Rate and direction of groundwater flow as determined by predictive calculations or computer modeling;and
(G) Lithostratigraphic and hydrostratigraphic logs of any existing test and injection wells.
3. INJECTANT INFORMATION—Per I5A NCAC 02C,0225(e)(5).provide information on each injectant as indicated below:
(A) MSDS,concentration at the point of injection,and percentage if present in a mixture with other injectants;
(B) The source of fluids used to dilute,carry,or otherwise distribute the injectant throughout the injection zone. If any
well within the area of review of the injection facility is to be used as the fluid source,then the following information
shall be submitted: location/ID number, depth of source,formation,rock/sediment type,and a 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;
(C) A description of the rationale for selecting the injectants and concentrations proposed for injection, including an
explanation or calculations of how the proposed injectant volumes and concentrations were determined;
(D) 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;
(E) A summary of results if modeling or testing was performed to investigate the injectant's potential or susceptibility
for biological,chemical,or physical change in the subsurface;and
(F) An evaluation concerning the development of byproducts of the injection process, including increases in the
concentrations of naturally occurring substances. Such an evaluation shall include the identification of the specific
byproducts of the injection process,projected concentrations of byproducts,and areas of migration as determined
through modeling or other predictive calculations.
4. INJECTION PROCEDURE—Per 15A NCAC 02C.0225(e)(6), submit a table with a detailed description of the proposed
injection procedure that includes the following:
(A) The proposed average and maximum daily rate and quantity of injectant;
(B) The average maximum injection pressure expressed in units of pounds per square inch(psi);and
(C) The total or estimated total volume to be injected.
In-Situ Groundwater Remediation Application Rev.4-9-2019 Page 4 of 6

5. FRACTURING PLAN(if applicable)—Per 15ANCAC 02C.0225(e)(2I, submit a detailed description of the fracturing plan
that includes the following:
(A) Material Safety Data Sheets of fracturing media including information on any proppants used;
(B) a map of fracturing well locations relative to the known extent of groundwater contamination plus all buildings,
wells,septic systems,underground storage tanks, and underground utilities located within the Area of Review;
(C) a demonstration that buildings,wells,septic systems, underground storage tanks,and underground utilities will not
be adversely affected by the fracturing process;
(D) injection rate and volume;
(E) orientation of bedding planes,joints,and fracture sets of the fracture zone;
(F) performance monitoring plan for determining the fracture well radius of influence;and
(G) if conducted,the results of geophysical testing or pilot test of fracture behavior conducted in an uncontaminated
area of the site.
6. WELL CONSTRUCTION DETAILS — Per 15A NCAC 02C.0225(68), submit the following information in tabular or
schematic form as appropriate for each item:
(A) number and depth of injection wells;
(B) number and depth of borings if using multi-level or"nested"well systems;
(C) indication whether the injection wells are existing or proposed;
(D) depth and type of casing;
(E) depth and type of screen material;
(F) depth and type of grout;
(G) indication whether the injection wells are permanent or temporary"direct push"points;and
(H) plans and specifications of the surface and subsurface construction details.
7. MONITOR.ING PLAN—Per I5A NCAC 02C.0225(019), submit a monitoring plan that includes the following:
(A) target contaminants plus secondary or intermediate contaminants that may result from the injection;
(B) other parameters that may serve to indicate the progress of the intended reactions;
(C) a list of existing and proposed monitoring wells to be used;and
(D) a sampling schedule to monitor the proposed injection.
Monitoring wells shall be ofsufJIcient quantity and location to detect any movement of injection fluids, injection process byproducts,or
formation fluids outside the injection zone. The monitoring schedule shall be consistent with the proposed injection schedule,pace of
the anticipated reactions, and rate of transport of the injectants and contaminants.
S. WELL DATA TABULATION—Per 15A NCAC 02C.02251e}t101 provide a tabulation of data on all existing or abandoned
wells within the area of review of the injection well(s) that penetrate the proposed injection zone, including monitoring
wells and wells proposed for use as injection wells. Such data shall include a description of each well's type, depth, and
record of construction or abandonment.
9. MAPS AND CROSS-SECTIONS — Per 15A NCAC 02C .0225(e)(11). provide scaled, site-specific site plans or maps
depicting the location,orientation,and relationship of facility components including the following:
(A) 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;
(B) topographic contour intervals showing all facility related structures, property boundaries, streams, springs, lakes,
ponds,and other surface drainage features;
(C) all existing or abandoned wells within the area of review of the wells listed in the well data tabulation that penetrate
the proposed injection zone;
(D) potentiometric surface map(s)that show the direction of groundwater movement,existing and proposed wells:
(E) contaminant plume map(s)with isoconcentration lines that show the horizontal extent of the contaminant plume in
soil and groundwater,and existing and proposed wells;
(F) cross-section(s) to the known or projected depth of contamination that show the horizontal and vertical extent of
the contaminant plume in soil and groundwater, major changes in lithology,and existing and proposed wells;and
(G) any existing sources of potential or known groundwater contamination, including waste storage, treatment, or
disposal systems within the area of review of the injection well or well system.
In-Situ Groundwater Remediation Application Rev.4-9-2019 Page 5 of 6

X. CERTIFICATION(to be signed as required below or by that person's authorized agent*)
NCAC 15A 02C .021 Ice) requires that all permit applications shall be signed as follows:
1. for a corporation: by a responsible corporate officer
2. for a partnership or sole proprietorship: by a general partner or the proprietor,respectively
3. for a municipality or a state, federal, or other public agency: by either a principal executive officer or
ranking publicly elected official
4. for all others: by the well owner.
*If an authorized agent is signing on behalf of the applicant,then supply a letter signed by the applicant
that names and authorizes their agent.
"I hereby cert fy under penalty of law that I have personally examined and am familiar with the information
submitted in this document and all attachments therein, 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 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."
Printed Name and Title: Steve Hall Plant Manager
Signature: 01 Date: 6111 (1
XI. CONSENT OF PROPERTY OWNER(if the property is not owned by the permit 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.
"As owner of the property on which the injection well(s) are to be constructed and operated, I 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
(1 SA NCAC 02C.0200)."
Printed Name and Title:
Signature: _ Date:
Submit TWO hard copies of the completed application package with an electronic version in CD or USE Flash
Drive to:
DIVISION OF WATER RESOURCES—UIC PROGRAM
1636 MAIL SERVICE CENTER
RALEIGH,NORTH CAROLINA 27699-1636
TELEPHONE NUMBER: [phone]
In-Situ Groundwater Remediation Application Rev.4-9-2019 Page 6 of 6

ERM NC,Inc.
15720 John J.Delaney Drive
May 5,2014 Suite 120
Charlotte,NC 28277
[phone]
[phone] (fax)
Mr. Thomas Slusser
NCDENR- Division of Water Resources
Underground Injection Control Program •
1636 Mail Service Center
Raleigh, North Carolina 27699-1636 FRM
919-807-6412 Via Email&FedEx
Subject Application for Permit To Construct And Use Injection Wells
(In-Situ Remediation),And
Notification Of Intent To Construct Or Operate Injection Wells
Energizer Battery Manufacturing, Inc.
Asheboro Plant II
RECEIVEDIDENR/O R
NCD000822957 MAY 0 2014
Dear Thomas: Water Quality Regional
Operations Sec ion
On behalf of Energizer Battery Manufacturing, Inc. (Energizer),ERM NC,Inc. (ERM)
is transmitting the enclosed packages which include:
1. Application for Permit To Construct And Use Injection Wells (In-Situ
Remediation),and
2. Notification Of.Intent To Construct Or Operate Injection Wells.
The Application for Permit document is for pneumatic fracturing activities proposed
to be conducted in advance of installing an air sparging(AS) and soil vapor
extraction(SVE) system for in-situ remediation of soil and groundwater as part of a
remedial action at the Energizer- Asheboro Plant II site. The Notification document
is for the proposed air injection activities associated with the SVE/AS remediation
system. Both documents cover the injection wells proposed for a pilot test phase and
the subsequent full-scale remediation system.
Energizer is conducting remedial activities at the Site under an Administrative
Agreement(AA) with NCDENR DWM's Inactive Hazardous Sites Branch(IHSB). A
Remedial Action Plan (RAP) (October 21,2013) utilizing SVE/AS technology for
remediation of TCE-affected soils and groundwater was approved by NCDENR in
February 2014. The RAP included the use of pneumatic fracturing of the shallow soil
and aquifer zone to enhance soil permeability for SVE/AS effectiveness. A Pilot Test
Work Plan (March 26, 2014) describing activities for implementing a pilot-scale system
for evaluation of the SVE/AS approach was approved by NCDENR in March 2014.

Mr.Thomas Slusser
Page 2
May 5,2014
Please contact me or Alan Martin,if you have any questions or wish to discuss.
Sincerely,
P.I.9"44 1 ' l
omas M. Wilson,P.G.
Principal
Enclosures
cc: Jeff Gipson, Energizer
Scott Boyle, Energizer
Melanie Bartlett, NCDWM (transmittal letter only)
Alan Martin-ERM

NORTH CAROLINA DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
NOTIFICATION OF INTENT TO CONSTRUCT OR OPERATE INJECTION WELLS
The following are"permitted by rule"and do not require an individual permit when constructed in accordance
with the rules of 15A NCAC 02C.0200. This form shall be submitted at least 2 weeks prior to injection.
AQUIFER TEST WELLS(15A NCAC 02C.0220)
These wells are used to inject uncontaminated fluid into an aquifer to determine aquifer hydraulic characteristics.
IN SITU REMEDIATION(15A NCAC 02C.0225)or TRACER WELLS(15A NCAC 02C.0229):
1) Passive Injection Systems - In-well delivery systems to diffuse injectants into the subsurface. Examples include
ORC socks,iSOC systems,and other gas infusion methods.
2) Small-Scale Injection Operations—Injection wells located within a land surface area not to exceed 10,000
square feet for the purpose of soil or groundwater remediation or tracer tests. An individual permit shall be required
for test or treatment areas exceeding 10,000 square feet.
3) Pilot Tests - Preliminary studies conducted for the purpose of evaluating the technical feasibility of a
remediation strategy in order to develop a full scale remediation plan for future implementation.and where the
surface area of the injection zone wells are located within an area that does not exceed five percent of the land
surface above the known extent of groundwater contamination. An individual permit shall be required to conduct
more than one pilot test on any separate groundwater contaminant plume.
4) Air Injection Wells- Used to inject ambient air to enhance in-situ treatment of soil or groundwater.
Print Clearly or Type Information. Illegible Submittals Will Be Returned As Incomplete.
DATE: May 1 . 2014 PERMIT NO. (to be filled in by DWR)
A. WELL TYPE TO BE CONSTRUCTED OR OPERATED
(1) X Air Injection Well Complete sections B-F,K,N
(2) Aquifer Test Well Complete sections B-F,K,N
(3) Passive Injection System Complete sections B-F,H-N
(4) _Small-Scale Injection Operation Complete sections BRECEIVED/DENR/DWR
(5) Pilot Test Complete sections B-N
(6) Tracer Injection Well Complete sections B-N MAY o 6 2014
Water Quality Regional
B. STATUS OF WELL OWNER: Business/Organization Operations Section
C. WELL OWNER — State name of entity and name of person delegated authority to sign on behalf of the
business or agency:
Name: Energizer Batters Manufacturing Inc.. Dan Carpenter(VP Global Operations&Chief Technology Officer)
Mailing Address: 419 Art Bryan Drive
City: Achehnm State: NC Zip Code: 272f3-3)R9 County: Randolph
Day Tele No.: 336-672-4546 Cell No.: 336-736-2278
EMAIL Address: ScottV.Boylec i)energizer.com Fax No.: 336-672-4S83
UIC/In Situ Remed.Notification(Revised 11/19/2013) Page 1

D. PROPERTY OWNER(if different than well owner)
Name:
Mailing Address:
City: State: Zip Code: County:
Day Tele No.: Cell No.:
EMAIL Address: Fax No.:
E. PROJECT CONTACT-Person who can answer technical questions about the proposed injection project.
Name: ERM NC,Inc. Alan Martin,Project Manager
Mailing Address:_ 15720 John J.Delany Dr.Suite 120
City: Charlotte State: NC Zip Code: 28277 County:Mecklenburg
Day Tele No.: [phone] Cell No.: [phone]
EMAIL Address: [e-mail] Fax No.: 1704)624-7928
F. PHYSICAL LOCATION OF WELL SITE
(1) Physical Address: 419 Art Bryan Drive
County: Randolph
City: Asheboro State:NC Zip Code: 27203-3089
(2) Geographic Coordinates: Latitude**: 35 ° 46 ' 6 9 "or °.
Longitude**: 79 ° 49 ' 2.0 "or 0
Reference Datum: _ _Accuracy:
Method of Collection:
**FOR AIR INJECTION AND AQUIFER TEST WELLS ONLY: A FACILITY SITE MAP WITH PROPERTY
BOUNDARIES MAY BE SUBMITTED IN LIEU OF GEOGRAPHIC COORDINATES.
G. TREATMENT AREA
Land surface area of contaminant plume: square feet
Land surface area of inj.well network: square feet(< 10,000 ft2 for small-scale injections)
Percent of contaminant plume area to be treated: (must be<5%of plume for pilot test injections)
H. INJECTION ZONE MAPS—Attach the following to the notification.
(1) Contaminant plume map(s) with isoconcentration lines that show the horizontal extent of the
contaminant plume in soil and groundwater,existing and proposed monitoring wells, and existing and
proposed injection wells;and
(2) Cross-section(s) to the known or projected depth of contamination that show the horizontal and
vertical extent of the contaminant plume in soil and groundwater, changes in lithology, existing and
proposed monitoring wells,and existing and proposed injection wells.
UIC/In Situ Remed.Notification(Revised 11/19/2013) Page 2

DESCRIPTION OF PROPOSED INJECTION ACTIVITIES — Provide a brief narrative regarding the
purpose,scope,and goals of the proposed injection activity.
J. INJECTANTS—Provide a MSDS and the following for each injectant.Attach additional sheets if necessary.
NOTE: Approved injectants (tracers and remediation additives) can be found online at
http://portal.ncdenr.org/web/wq/aps/gwpro. All other substances must be reviewed by the Division of Public
Health, Department of Health and Human Services. Contact the UIC Program for more info(919-807-6496).
Injectant:
Volume of injectant:
Concentration at point of injection: _
Percent if in a mixture with other injectants:
Injectant:
Volume of injectant:
Concentration at point of injection:
Percent if in a mixture with other injectants:
Injectant:
Volume of injectant:
Concentration at point of injection:
Percent if in a mixture with other injectants:
K. WELL CONSTRUCTION DATA
The well construction will be conducted in two phases. For the first phase,one air sparge(AS)and one soil
vapor extraction(SVE)well will be installed for the AS/SVE pilot test. After the pilot test,the second
phase of AS and SVE wells construction will involve the installation of an additional 12 AS wells and 11
SVE wells to complete the full-scale AS/SVE system.See attached Figure 13 for proposed well locations.
See Figures 14—16 for proposed well construction details.
(1) Number of injection wells: 13 Proposed Existing
Air Sparge Wells 13 Soil Vapor Extraction Wells 12
(2) Provide well construction details for each injection well in a diagram or table format. A single
diagram or line in a table can be used for multiple wells with the same construction details. Well
construction details shall include the following:
(a) well type as permanent,direct-push,or subsurface distribution system(infiltration gallery)
(b) depth below land surface of grout,screen,and casing intervals
(c) well contractor name and certification number
UIC/In Situ Remed.Notification(Revised 11/19/2013) Page 3

L. SCHEDULES—Briefly describe the schedule for well construction and injection activities.
M. MONITORING PLAN—Describe below or in separate attachment a monitoring plan to be used to determine
if violations of groundwater quality standards specified in ubchapter 02L result from the injection activity.
N. SIGNATURE OF APPLICANT AND PROPERTY OWNER
APPLICANT: "I hereby certify, under penalty of law, that I am familiar with the information submitted in
this document and all attachments thereto and that, based on my inquiry of those individuals immediately
responsible for obtaining said information, I believe that the information is true, accurate and complete. I am
aware that there are significant penalties, including the possibility of fines and imprisonment,for submitting
false information. I agree to construct, operate, maintain, repair, and if applicable, abandon the injection well
and all related appurtenances in accordance with the 15A NCAC 02C 0200 Rules."
-b \ lam- J-
Signa re of Appl' Print or Type Full Name
PROPERTY OWNER(if the property is not owned by the permit applicant):
"As owner of the property on which the injection well(s) are to be constructed and operated, I 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 (15A NCAC 02C.0200)."
"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.
Signature*of Property Owner(if different from applicant) Print or Type Full Name
* An access agreement between the applicant and property owner may be submitted in lieu of a signature on this form.
Submit one copy of the completed notification package to:
DWR—UIC Program
1636 Mail Service Center
Raleigh,NC 27699-1636
Telephone: [phone]
UIC/In Situ Remed.Notification(Revised 11/19/2013) Page 4

ERM NC,Inc.
15720 John J.Delaney Drive
Suite 120
May 5, 2014 Charlotte,NC 28277
[phone]
[phone](fax)
Mr. Thomas Slusser
NCDENR-Division of Water Resources
Underground Injection Control Program ` .r
1636 Mail Service Center
Raleigh,North Carolina 27699-1636 ER
919-807-6412 Via Email &FedEx
Subject: Application for Permit To Construct And Use Injection Wells
(In-Situ Remediation), And
Notification Of Intent To Construct Or Operate Injection Wells
Energizer Battery Manufacturing, Inc.
Asheboro Plant II RECEIVEDIDENR/DWR
NCD000822957 'MAY 0 6 2014
Dear Thomas: Water Quality Re,TM'ry�onal
Operations .ec on
On behalf of Energizer Battery Manufacturing, Inc. (Energizer), ERM NC, Inc. (ERM)
is transmitting the enclosed packages which include:
1. Application for Permit To Construct And Use Injection Wells (In-Situ
Remediation),and
2. Notification Of Intent To Construct Or Operate Injection Wells. (tr1:241
The Application for Permit document is for pneumatic fracturing activities proposed
to be conducted in advance of installing an air sparging (AS) and soil vapor
extraction (SVE) system for in-situ remediation of soil and groundwater as part of a
remedial action at the Energizer-Asheboro Plant II site. The Notification document
is for the proposed air injection activities associated with the SVE/AS remediation
system. Both documents cover the injection wells proposed for a pilot test phase and
the subsequent full-scale remediation system.
Energizer is conducting remedial activities at the Site under an Administrative
Agreement(AA)with NCDENR DWM's Inactive Hazardous Sites Branch(IHSB). A
Remedial Action Plan (RAP) (October 21,2013) utilizing SVE/AS technology for
remediation of TCE-affected soils and groundwater was approved by NCDENR in
February 2014. The RAP included the use of pneumatic fracturing of the shallow soil
and aquifer zone to enhance soil permeability for SVE/AS effectiveness. A Pilot Test
Work Plan (March 26, 2014) describing activities for implementing a pilot-scale system
for evaluation of the SVE/AS approach was approved by NCDENR in March 2014.

North Carolina Department of Environment and Natural Resources
APPLICATION FOR PERMIT TO CONSTRUCT AND/OR USE A WELL(S)FOR INJECTION
In Situ Groundwater Remediation(15A NCAC 02C.02: I Tracer Injection(15A NCAC 02C.0229)
Do not use this form for the following:
• in situ remediation,tracer,or aquifer test injection wells permitted by rule(ref. 15A NCAC 02C.0217)
• remediation systems that reinject treated contaminated groundwater(ref. 15A NCAC 02T.1600
RECEIVED/DENR{DWR
Application Number(to be completed by DWR): ti J 1 O f
APPLICATION INFORMATION b
Water Quali Regional
1. Project is: [X]New []Modification []Renewal without modi ic �rati[�}lgdnvith 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, submit a status report including monitoring results of all injection activities to date.
II. WELL OWNER(generally the responsible party)
1. Name: Energizer Battery Manufacturing, Inc.
2. Signing Official's Name*: Dan Carpenter Title: VP Global Operations&Chief Technology Officer
* Signing Official must be in accordance with instructions in Part IX on page 5.
3. Mailing address of applicant: 419 Art Bryan Drive
City: Asheboro State: NC Zip: 27203-3089
4. Telephone number: [phone] Email: scottv.boyleZenergizer.com
5. Status(choose one): Individual X Business/Org. Federal State County Municipality
III. PROPERTY OWNER(if different than well owner)
1. Name:
2. Physical address:
City: State: Zip:
3. Mailing address:
City: _ State: Zip:. _
4. Telephone number: Email:
IIII. PROJECT CONTACT—Person who can answer technical questions about the proposed injection project.
1. Name: Alan Martin Title: Project Manager
2. Company: ERM NC.Inc.
3. Address: 15720 John J Delaney Drive. Suite 120
4. City: Charlotte State: NC Zip: 28277
5. Telephone number: [phone] Email: [e-mail]
Revised 11/19/2013 UIC-5I/5T Page 1 of 14

APPLICATION FOR PERMIT TO CONSTRUCT AND/OR USE A WELL(S)FOR INJECTION
In Situ Groundwater Remediation I Tracer Injection
V. FACILITY INFORMATION
1. Facility name: Energizer Battery Facility Ph#: [phone]
2. Mailing address: 419 Art Bryan Drive
City: Asheboro County: Randolph State:NC Zip:27203-3089
3. Geographic Coordinates: Latitude: 35°46' 6.9" N Longitude: 79°49'2.0" W
Reference Datum: Accuracy:
Method of Collection: Google Earth
4. Brief description of business: Battery Manufacturer
VI. INCIDENT DESCRIPTION
1. Source and date of contamination: Environmental assessment activities were initiated at the site in August 1999
under the NCDWQ following discovery of solvent-affected soil beneath the former location of a solvent vapor
recovery unit previously located within the interior of the building. The solvent vapor recovery unit was part of
a vapor degreaser system that utilized trichloroethylene(TCE)to clean battery cans. In 2002,a Corrective
Action Plan(CAP)was approved by NCDENR DWQ and soil vapor extraction and air sparging(SVE/AS)was
utilized for remediation of solvent-affected soil and groundwater in this source area. Subsequently,additional
areas of ICE-affected soil and groundwater have been identified and delineated in the vicinity of the former
vapor degreaser system/tank farm area. Currently,remedial activities at the Site are being conducted under an
Administrative Agreement(AA),dated November 15,2013,between NCDENR DWM's Inactive Hazardous
Sites Branch(IHSB)and Energizer Battery.A Remedial Action Plan (RAP) (October 21,2013)utilizing
SVE/AS technology for remediation of the additional sources areas of TCE-affected soils and groundwater was
approved by NCDENR in February 2014. The RAP included the use of pneumatic fracturing of the shallow
soil and aquifer zone to enhance soil permeability for SVE/AS effectiveness.A Pilot Test Work Plan(March
26,2014)describing activities for implementing a pilot-scale system for evaluation of the SVE/AS approach
was approved by NCDENR in March 2014.
2. List all contaminants present in soils or groundwater at the site(contaminants may be listed in groups, e.g.,gasoline,
diesel,jet fuel,fuel oil, chlorinated ethenes, chlorinated ethanes, metals,pesticides/herbicides, etc):
chlorinated ethenes and chlorinated ethanes
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: 663.660 ppb
4. Agency managing the contamination incident:
[] UST Section [X] Superfund Section(including REC Program and DSCA sites)
[] DWR Aquifer Protection Section [] Solid Waste Section
[]Hazardous Waste Section [] Other: _
5. Incident manager's name: Melanie Bartlett Ph#: (9191707-8373
6. Incident number or other incident mgmt.agency tracking number: NCD00822957
Revised 11/19/2013 UIC-51/5T Page 2 of 14

APPLICATION FOR PERMIT TO CONSTRUCT AND/OR USE A WELL(S)FOR INJECTION
In Situ Groundwater Remediation I Tracer Injection
VII. PERMITS
List all applicable permits or construction approvals issued for the facility or incident:
1. Hazardous Waste Management program permits under RCRA: Not applicable
2. DWR Non-Discharge or NPDES permits: Not applicable
3. County or DEH subsurface wastewater disposal permits: Not applicable
4. Other environmental permits required by state or federal law: NCDWQ monitor well construction permit.
VIII. ATTACHMENTS — provide the following information in separate attachments. The attachments should be
clearly identified and presented in the order below to expedite review of the permit application package.
1. INJECTION ZONE—Per 15A NCAC 02C.0225(0(2) specify the horizontal and vertical portion of the subsurface within
which the proposed injection activity will take place and beyond which no violations of groundwater quality standards
shall result from the injection as determined by an approved monitoring plan. The determination shall be based on the
hydraulic properties of the specified zone. Provide any supporting documentation in a separate attachment.
Not Applicable(Nitrogen Gas will be used as a fracturing media only. See Section 5.Fracturing Plan.)
2. HYDROGEOLOGIC EVALUATION — Per 15A NCAC 02C .0225(e}(31 provide a hydrogeologic evaluation of the
injection zone that includes all of the following:
(A) Regional and local geology and hydrology;
(B) Changes in lithology underlying the facility;
(C) Depth to bedrock;
(D) Depth to the mean seasonal high water table;
(E) Hydraulic conductivity, transmissivity, and storativity, of the injection zone based on tests of site-specific
material,including a description of the test(s)used to determine these parameters;
(F) Rate and direction of groundwater flow as determined by predictive calculations or computer modeling;and
(G) Lithostratigraphic and hydrostratigraphic logs of any existing test and injection wells.
3. INJECTANT INFORMATION — Per 15A NCAC 02C .0225(e1(5) list each injectant in the space below and provide the
following information for each injectant. NOTE: Approved injectants can be found online at
http:•//portal.ncdenr.org/web/wq/aps/gwpro. All other substances must be reviewed by the Division of Public Health,
Department of Health and Human Services. Contact the UIC Program for more information(Ph#919-807-6496).
Not Applicable(Nitrogen Gas will be used as a fracturing media only. See Section 5.Fracturing Plan.)
(A) MSDS,concentration at the point of injection,and percentage if present in a mixture with other injectants;
(B) The source of fluids used to dilute, carry, or otherwise distribute the injectant throughout the injection zone. If
any well within the area of review of the injection facility is to be used as the fluid source, then the following
information shall be submitted: location/ID. number, depth of source, formation, rock/sediment type, and a
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;
(C) A description of the rationale for selecting the injectants and concentrations proposed for injection, including an
explanation or calculations of how the proposed injectant volumes and concentrations were determined;
(D) 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;
(E) A summary of results if modeling or testing was performed to investigate the injectant's potential or susceptibility
for biological,chemical,or physical change in the subsurface;and
(F) An evaluation concerning the development of byproducts of the injection process, including increases in the
concentrations of naturally occurring substances. Such an evaluation shall include the identification of the specific
byproducts of the injection process,projected concentrations of byproducts, and areas of migration as determined
through modeling or other predictive calculations.
Revised 11/19/2013 UIC-5I/5T Page 3 of 14

APPLICATION FOR PERMIT TO CONSTRUCT AND/OR USE A WELL(S)FOR INJECTION
In Situ Groundwater Remediation I Tracer Injection
4. INJECTION PROCEDURE —Per 15A NCAC 02C .0225te1(6) submit a table with a detailed description of the proposed
injection procedure that includes the following:
(A) The proposed average and maximum daily rate and quantity of injectant;
(B) The average maximum injection pressure expressed in units of pounds per square inch(psi);and
(C) The total or estimated total volume to be injected.
Not Applicable(Nitrogen Gas will be used as a fracturing media only. See Section 5.Fracturing`Plan.)
5. FRACTURING PLAN(if applicable)—Per 15A NCAC 02C.0225(e](7)submit a detailed description of the fracturing plan
that includes the following:
(A) Material Safety Data Sheets of fracturing media including information on any proppants used;
(B) a map of fracturing well locations relative to the known extent of groundwater contamination plus all buildings,
wells, septic systems,underground storage tanks,and underground utilities located within the Area of Review;
(C) a demonstration that buildings, wells, septic systems, underground storage tanks, and underground utilities will
not be adversely affected by the fracturing process;
(D) injection rate and volume;
(E) orientation of bedding planes,joints,and fracture sets of the fracture zone;
(F) performance monitoring plan for determining the fracture well radius of influence;and
(G) if conducted, the results of geophysical testing or pilot test of fracture behavior conducted in an uncontaminated
area of the site.
6. WELL CONSTRUCTION DETAILS — Per 15A NCAC 02C .0225(e1[8] submit the following information in tabular or
schematic form as appropriate for each item:
(A) number and depth of injection wells;
(B) number and depth of borings if using multi-level or"nested"well systems;
(C) indication whether the injection wells are existing or proposed;
(D) depth and type of casing;
(E) depth and type of screen material;
(F) depth and type of grout;
(G) indication whether the injection wells are permanent or temporary"direct push"points; and
(H) plans and specifications of the surface and subsurface construction details.
7. MONITORING PLAN—Per 15A NCAC 02C.0225(0(9)submit a monitoring plan that includes the following:
(A) target contaminants plus secondary or intermediate contaminants that may result from the injection;
(B) other parameters that may serve to indicate the progress of the intended reactions;
(C) a list of existing and proposed monitoring wells to be used; and
(D) a sampling schedule to monitor the proposed injection.
Monitoring wells shall be of sufficient quantity and location to detect any movement of injection fluids, injection process byproducts,
or formation fluids outside the injection zone. The monitoring schedule shall be consistent with the proposed injection schedule,pace
of the anticipated reactions, and rate of transport of the injectants and contaminants.
Not Applicable(Nitrogen Gas will be used as a fracturing media only. See Section 5.Fracturing Plan.)
8. WELL DATA TABULATION—Per 15A NCAC 02C.0225(e) 101 provide a tabulation of data on all existing or abandoned
wells within the area of review of the injection well(s) that penetrate the proposed injection zone, including monitoring
wells and wells proposed for use as injection wells. Such data shall include a description of each well's type, depth, and
record of construction or abandonment.
Revised 11/19/2013 UIC-51/5T Page 4 of 14

APPLICATION FOR PERMIT TO CONSTRUCT AND/OR USE A WELL(S)FOR INJECTION
In Situ Groundwater Remediation I Tracer Injection
9. MAPS AND CROSS-SECTIONS — Per 15A NCAC 02C .0225(e)(11) provide scaled, site-specific site plans or maps
depicting the location,orientation,and relationship of facility components including the following:
(A) 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;
(B) topographic contour intervals showing all facility related structures, property boundaries, streams, springs, lakes,
ponds,and other surface drainage features;
(C) all existing or abandoned wells within the area of review of the wells listed in the well data tabulation that
penetrate the proposed injection zone;
(D) potentiometric surface map(s)that show the direction of groundwater movement,existing and proposed wells;
(E) contaminant plume map(s)with isoconcentration lines that show the horizontal extent of the contaminant plume
in soil and groundwater,and existing and proposed wells;
(F) cross-section(s)to the known or projected depth of contamination that show the horizontal and vertical extent of
the contaminant plume in soil and groundwater,major changes in lithology,and existing and proposed wells;and
(G) any existing sources of potential or known groundwater contamination, including waste storage, treatment, or
disposal systems within the area of review of the injection well or well system.
IX. CERTIFICATION*(to be signed as required below or by that person's authorized agent*)
NCAC 15A 02C.0211(e)requires that all permit applications shall be signed as follows:
1. for a corporation: by a responsible corporate officer
2. for a partnership or sole proprietorship: by a general partner or the proprietor,respectively
3. for a municipality or a state, federal, or other public agency: by either a principal executive officer or
ranking publicly elected official
4. for all others: by the well owner.
*If an authorized agent is signing on behalf of the applicant,then supply a letter signed by the applicant
that names and authorizes their agent.
"I hereby certify under penalty of law that I have personally examined and am familiar with the information
submitted in this document and all attachments therein, 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 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."
Printed Name and Title: J f1 N 1 1. C +-( iv -"R i V 1P , G LU k/nl o to& orTuk o
Signature: ( Date: ST/ 272 c3 1
Revised 11/19/2013 UIC-51/5T Page 5 of 14

APPLICATION FOR PERMIT TO CONSTRUCT AND/OR USE A WELL(S)FOR INJECTION
In Situ Groundwater Remediation Tracer Injection
X. CONSENT OF PROPERTY OWNER (if the property is not owned by the permit 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.
"As owner of the property on which the injection well(s) are to be constructed and operated, I 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
(15A NCAC 02C.0200)."
Printed Name and Title: Not Applicable
Signature: Date:
Submit TWO copies of the completed application package, including all attachments,to:
DWR—UIC Program
1636 Mail Service Center
Raleigh,NC 27699-1636
Telephone[phone]
Revised 11/19/2013 UIC-5I15T Page 6 of 14

Attachment 1 Injection Zone:
Not Applicable—Application is for pneumatic fracturing only using an inert gas(nitrogen). See Attachment 5 for
Fracturing Plan,including map of proposed locations for pneumatic fracturing. See Appendix A for additional site maps.
Attachment 2—Hydrogeologic Evaluation
Site Hydrology
The surface water bodies within'/4 mile of the Site are an unnamed intermittent tributary to Hasketts Creek,which flow
across the north-eastern corner of the Energizer parcel,and Hasketts Creek,which flows across the south-eastern tip of the
Energizer parcel. The stream locations are over 500 feet from the proposed injection area.
Site Geology
A brief summary of the site geology and hydrogeology is presented below.
The Asheboro area, including the subject site,is located within the Piedmont physiographic province of North Carolina.
Geologic and hydrogeologic data have been collected from the site soil and monitor well borings. These data indicate that
saprolitic soil extends to depths between 15 to 41 feet below ground surface(bgs). Structural fill soil underlies portions of
the building to depths of approximately 8 to 18 feet bgs. Both the fill soils and the saprolite soils consist of silt with some
fine sand and clay with clay contents increasing slightly with depth. The native soils are fine-grained,weathered
residuum of metavolcanic mudstones and exhibit relict physical features of the parent rock at depths beyond
approximately 10 feet. This soil also becomes very dense at depths greater than 10 to 15 feet.
A layer of partially weathered rock(PWR)separating the saprolitic soil from competent bedrock is encountered between
25 feet and 63 feet below ground level(ft bgl)at the site. Bedrock consisting of a dark gray metavolcanic mudstone or
tuff is encountered at 20 to 63 ft bgl. The metavolcanic bedrock is part of the Uwharrie Formation of the Carolina Slate
belt that underlies the Asheboro area.
Site Hydrogeology
The depth to groundwater varies across the site from 7 to 31 ft bgl. Groundwater elevation data collected from the site
monitor wells indicate that groundwater flows to the southeast-south in the saprolite aquifer and shallow bedrock aquifer
towards an unnamed tributary of Hasketts Creek located along the eastern portion of the site. Groundwater flow
directions in the shallow and bedrock aquifers are presented in Figures 4 and 5 respectively. The locations of two
hydrogeologic cross sections of the site are depicted on Figure 6). The subsurface hydrogeology is shown on
hydrogeologic cross sections(Figures 7 and 8).
In the downgradient area,south of the Energizer property,groundwater elevation data at MW-13 suggests that the
groundwater levels and hydraulic gradient are influenced by the adjacent rock quarry(Figure 2)located approximately
2,800 feet southwest of the Site which is over 300 feet deep. Since the rock quarry pit water level is near the bottom of
the quarry,the local hydraulic gradient is highly influenced by the quarry operations.Historical groundwater level data
suggests that the groundwater gradient in the vicinity of MW-13 is westward towards the quarry rather than eastward
toward the tributary to Hasketts Creek. The groundwater elevation data also indicate that in the vicinity of MW-14D,
located southeast of the quarry on Rock Quarry Road,the groundwater flow direction is north/northwest toward the
quarry.
The calculated groundwater velocity in the saprolite aquifer zone at the site,using the geometric mean hydraulic
conductivity of 0.80 feet/day calculated from slug test results and assuming an effective porosity of 0.35 and a typical
gradient of 0.01 to 0.02,ranges from 8 to 16 feet/year. A rough estimate of groundwater velocity that is representative of
the bedrock aquifer was calculated in 1999 by dividing the distance the contaminant plume has traveled in the
downgradient direction(2,300 feet)by the number of years(19 years)of solvent recovery unit operation(1980 to 1999)at
the source area. Using this method,the estimated groundwater velocity is 121 feet/year. This method does not account
for contaminant retardation within the aquifer.

Attachment 3—Injectant Information
Not Applicable—Application is for pneumatic fracturing only using an inert gas(nitrogen). See Attachment 5.
Attachment 4—Injection Procedure
Not Applicable—Application is for pneumatic fracturing only using an inert gas(nitrogen). See Attachment 5.
Attachment 5—Fracturing Plan
Pneumatic Fracturing Using Nitrogen Gas
Based on geologic data from site boring logs and previous experience with historic SVE/AS pilot testing at the site in
2001,pneumatic fracturing of the dense,fine-grained native saprolitic soils and partially weathered rock will be
performed to enhance soil permeability in order to increase the effectiveness of a proposed SVE/AS remediation
system.Fracturing will be completed on an open borehole using straddle packer tooling and compressed nitrogen.
The packer is lowered to the bottom of the hole,and then used to apply compressed nitrogen to a section of the
borehole at approximately 100 pounds per square inch gas(psig)of pressure at a volume of approximately 1,000
standard cubic feet per minute(SCFM). The pressure propagates fractures into the formation,which allows the
increased airflow required for successful application of SVE/AS remedial techniques. For the tank farm area,
fracturing will begin at approximate depths of 20 feet bgs within the SVE well boreholes and at 50 feet bgs within
the AS well boreholes. Fracturing is continued in 4 foot intervals up to a depth of 4 feet bgs. Typical pressurization
durations for each interval are less than 60 seconds.Unconsolidated materials such as silts and clays typically exhibit
fracture propagation distances of 20 to 40 feet. ARS Technologies,Inc., under subcontract to ERM,will conduct the
pneumatic fracturing.
The pneumatic fracturing will be conducted in two phases: the pilot-test phase and the full-scale phase. For the
initial phase(pilot test),fracturing will be conducted at two boring locations located near the southwest corner of the
tank farm area. Following the pneumatic fracturing,the two borings will be overdrilled and used for construction of
the AS and SVE wells for later use in the proposed SVE/AS pilot test. After implementation and evaluation of the
SVE/AS pilot test,the second phase of pneumatic fracturing will be conducted in a separate mobilization. For the
second phase(full-scale),fracturing will be conducted at 23 boring locations(for 12 AS wells and 11 SVE wells)
located in the vicinity of the tank farm area.
Following the each phase of pneumatic fracturing,the borings used for fracturing will be overdrilled and used for
construction of the AS and SVE wells for later use in the proposed SVE/AS system. (Prior to implementation,a
separate UIC permit-by-rule notification will be submitted as required for the air injection wells associated with the
proposed SVE/AS remediation system.)
A. Material Safety Data Sheets offracturing media including information on any proppants used;
MSDS is attached in Appendix B.
B. a map offracturing well locations relative to the known extent of groundwater contamination plus all buildings,
wells, septic systems, underground storage tanks, and underground utilities located within the Area of Review;
As described above,fracturing will be conducted at boring locations where the AS and SVE wells will
subsequently be constructed. Figure 13 in Appendix A shows the SVE/AS boring locations and other structures.
C. a demonstration that buildings, wells, septic systems, underground storage tanks, and underground utilities will
not be adversely affected by the fracturing process;

A copy of the Pneumatic Fracturing Structural Analysis Report,prepared by ARS Technologies,Inc. is attached
in Appendix C.
D. injection rate and volume;
Compressed nitrogen will be applied to each fracturing interval within the borehole at approximately 100- 150
pounds per square inch gas(psig)of pressure at a volume of approximately 1,000 standard cubic feet per minute
(SCFM).
E. orientation of bedding planes,joints, and fracture sets of the fracture zone;
Observations made at the Martin Marietta rock quarry located 0.5 miles southwest of the Energizer site,and on-
site geologic mapping provided data on fracture orientations in the vicinity of the site. The observations indicate
that the predominant fracture orientations in the area are N 10°to 60°E and N 75°to 80°W.
F. performance monitoring plan for determining the fracture well radius of influence;and
During fracturing activities,the following data will be collected: fracture initiation/maintenance pressures,gas
flow rate, surface heave via transit/heave rod assemblies and structure heave monitoring. Nearby existing
monitoring wells MW-23,MW-24 and MW-25 and proposed observation wells OB-1 and OB-2 will be
monitored for pressure influence during the pneumatic fracturing activities. ARS Technologies will utilize the
data to calculate the fracture boring radius of influence using a deformation modeling software.
G. if conducted, the results of geophysical testing or pilot test offracture behavior conducted in an uncontaminated
area of the site.
Not conducted.
Attachment 6—Well Construction Details
Initial Phase-Pneumatic Fracturing Prior to SVE/AS Pilot Test
One AS well(AS-2),one SVE well(SVE-5)and two observation wells(OB-1 &OB-2)will be installed for the
pilot test by a North Carolina-licensed well driller. Pneumatic fracturing activities will be conducted within a 4.5
inch diameter boreholes prior construction of the AS and SVE wells. Pneumatic fracturing will not be conducted
in the observation well boreholes. Well construction details are summarized below.
Air Sparge Well
The AS boring will be completed using auger,direct push,or sonic drilling equipment to a total depth of 50 feet
bgs,the approximate depth to the top of competent bedrock.The formation will then be pneumatically fractured
between 6 feet bgs and 50 feet bgs to enhance the permeability in the area.
Following the pneumatic fracturing,the 4.5-inch borehole will be overdrilled to a diameter of approximately 7.5
inches to remove sloughed soil material prior to construction of the AS well. The AS well will be constructed as
a Type II(single-cased)well with 2 feet of 0.010"slotted stainless steel screen and 48 feet of stainless steel riser.
For all subgrade portions of the well,2-inch inner diameter, stainless steel will be used. A#3-grade,washed
silica sand filter pack will be used to fill the annular space between the borehole wall and the AS well screen to 1
foot above the top of screen. A 2-foot thick bentonite seal will be placed on top of the filter sand and the
remainder of the borehole will be filled with neat Portland cement. The well head will be finished with a locking
expandable cap and a traffic rated vault cover. A schematic of the proposed AS well is presented as Figure 14.
The total depth and screened interval stated above are anticipated based on lithologic and monitoring well data in
the immediate vicinity. However,the actual total depth and screened interval will be determined in the field by a
project geologist or other qualified staff based on soil logging observations.

SVE Well
The SVE boring will be completed using auger,direct push,or sonic drilling equipment to a total depth of 20 feet
bgs,the approximate depth of the observed seasonal low water table.The formation will then be pneumatically
fractured between 4 feet bgs and 20 feet bgs to enhance the permeability in the area.
Following the pneumatic fracturing,the 4.5-inch borehole will be overdrilled to a diameter of approximately 10
inches to remove sloughed soil material prior to construction of the SVE well. The SVE well will be constructed
as a Type II(single-cased)well with 16 feet of 0.005"slotted stainless steel screen and 4 feet of stainless steel
riser. For all subgrade portions of the well,4-inch inner diameter,stainless steel will be used. A washed silica
sand filter pack(#1 grade)will be used to fill the annular space between the borehole wall and the SVE well
screen to 2 feet above the top of screen.A 2-foot thick bentonite seal will be placed on top of the filter sand and
the remainder of the borehole will be filled with neat Portland cement. The well head will be finished with a
locking expandable cap and a traffic rated vault cover.A schematic of the proposed SVE well is presented as
Figure 15.
Observation Wells
Influence achieved by the AS and SVE wells will be evaluated by monitoring the water levels in multiple
observation points. SVE/AS influence will be evaluated outside and underlying the building using existing(MW-
23,MW-24 and MW-25)and proposed(OB-1 and OB-2)monitoring points. The proposed observation wells will
be installed to a total depth of 30 feet bgs with 20 feet of 0.010"slotted two-inch internal diameter Schedule 40
PVC well screen and 10 feet of solid PVC riser. A#3-grade,washed silica sand filter pack will be used to fill the
annular space between the borehole wall and the well screen to 2 feet above the top of screen. A 2-foot thick
bentonite seal will be placed on top of the filter sand and the remainder of the borehole will be filled with neat
Portland cement. The well head will be finished with a locking expandable cap and a traffic rated vault cover. A
schematic of the proposed observation wells is presented as Figure 16.
Second Phase-Pneumatic Fracturing Prior to Full Scale SVE/AS Implementation
Following the results of the pilot test,the actual configuration of the full scale AS/SVE well system will be
determined. The conceptual layout shown on Figure 13 includes the installation of 12 additional AS wells and 11
additional SVE wells.
The AS and SVE wells will be installed for the pilot test by a North Carolina-licensed well driller. Pneumatic
fracturing activities will be conducted within a 4.5 inch diameter boreholes prior construction of the AS and SVE
wells. Pneumatic fracturing will not be conducted in the observation well boreholes. Well construction details
will be the same as described during the pilot test.
Attachment 7—Monitoring Plan
Not Applicable—Application is for fracturing only. A monitoring plan will be provided for the proposed
SVE/AS system to be permitted-by-rule, constructed and operated later.
Attachment 8—Well Tabulation Data
Well construction details and groundwater contaminant concentrations for existing monitoring wells within the
Injection Area wells are summarized below. Existing wells include MW-23,MW-24 and MW-25. Bedrock
monitor well MW-26D,co-located with MW-25 is deeper and beyond the influence of the pneumatic fracturing of
the saprolite zone.

TOTAL BBNTONTTE TOP OF APFROX.
DEPTH SCREENED INTERVAL_SANDPACK GROUT CASING GROUND
MONITOR DATE (feet (elevation INTERVAL INTERVAL ELEVATION ELEVATION
WELL I.D`I INSTALLED BGLL feet BGL in feet*s_ Ifeet BGLJ, /feet BGLj -SLeet'l.,_ (fee!. _ COA/TABIITS --, _ _ _ _
MIN-23 _ 4/13/12 27 _12-27 _682.8-667.8 10-27 8-10 694.84 695.1 -
M_W-24_ _ _4/1_0/1_2 _ _22_ _ _7-22_ 68_5.4-67_0.4 5-22 3-5 692.38 692.7
MN-25 4/9/12 25 10-25 r680.0-666.0 _8-25_ 6-8 689.96 690.6
MI L-26D 4/12/12 . 240 210-240 480.3-450.3 195-240 Y 180-195 690.26 690.E Double cased PVC-6"w ell casia9 set at 50',4"w ell casing set at 100'.
OW-1 _ _ 13endin9 _30 _ 10-30 - _ _ _ _ _ _
LOW-2 4/14/14 I 30 10-30 NA 8-30 6-8 NA NA I
•-Tap of casing elevation is given in feel relative to a temporary D-Designates"deep",Type III monitor well BGL=Below ground level
benchmark with an assigned elevation of 695.10 feet above mean sea level BTOC=Below top of well casing NA=Not Applicable
All wells were constructed of 2-inch PVC and 0.010-inch slot screen,except as noted
Wei O. nc Cartwuks-EPA Method 6290D/ems,04.
$ -
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NC 2L Ground Water Standard NE 1 600 600 500 20 70 6 400 3 0.03 7 - 5 70 100 8 70 200 OA 0.3 3 0.7 0.4 02 0 0.9 NE 3 - 3
018E VI8creerey Level-Raapenil - 13 3,600V 30 6 -9 - - _ 34 6 52 2 38 400 74 65 7 1,500 20 - 1.5 I 30 5.7 29 33 1,000 7 44 - -
H86craamBLsvel-9k.abn0 - 70 16,000 150 420 . � - - 44 1 25 220 25 1,600 LOCO - 140 330 35 6,300 9a 7.5 - 150 29 140 170 5,000-VI0 30 230 - -
055923 7/17/12 692.E-687.8 082,624<5,000 55,000 55,000<10.000 55.000 5000 4060 -- 55.000 4,000 69,600 510,000 <5,000 <5.000 59000 55,000 26,200 55,000 <5,000!3894000.4,000 <5,000 6,000 5000 59000 <5,000 <150 24
11/7/12 • 603,660 450. 1,000 450 450 450 450 450 450 450 450 170,00D 9200 730 480 1,200 260 84,000 2,400 450 1390,000I 450 450 1,200 450 <250 450 8,200 -
150824 7n9/12 1605.4.670.4 32,392 <10.0 I<10.0 <10.0 40.0 <10.0 <10.0 <10.0 - <10.0 <10.0 4,520 I 132 10,800 12 98.8 <10.0 <10.0 38.2 <10.0 10,400 1,640 <10.0 <10.0 <10.0 <10.0 <10.0 4,760 2,800
11/7/12 • 35,650 <25.0'45.0 45.0 <25.0 45.0 45.0 45.0 45.0 <25.0 45.0 5,700 160 9,800 45.0 170 45.0 48 72 45.0 II 15,000 1,200 <25.0 45.0 45.0 45.0 460 2,500 -
1/61825 711612 880.0-888.0 2,135 <10.0 <10. <10.0 40.0 <10.0 <10D <10.0 - <10.0 <10.0 854 40.0 59.8 <10.0 49.E <100 268 <100 <10.0 1,120 <10.0 <10.0 <10.0 i<10.0 <100 <10.0 <1,500 53.0
11/7/12 • 2,646 <25.0 450 45.0 525.0 525.0 45.0 <25.0 45.0 <25.0 <25.0 690 525.0 98 <25.0 31 450 280 45.0 45.01 1,600 <25.0 <25.0 <25.0 450 45.0 45.0 450 --
11/18260 7/18/12 480.3-450.3 9,470 550.0 <500 42041 100 550.0 405 40.0 - <50.0 550.0 824 100 61.2 <0.0 637 5500 7,020 550.0 550.0 I 792 90.0 <50.0 550.0 550.0550A 40.0 <7,500 38
11/7/12 I • 5,336 4.5 1 4.8 4,5 I 4.5 ' 4.5 4.5 4.5 4.5 4.5 3.6 710 4.5 68 4.5 410 4.5 3,600 6.6 4.5 L` 410 I 4.5 1 4.5 4.5 L 4.5 I 4.5 4.5 130 -
NC2LsbMaN not i,MutlaEinta. NCRAF-M.Carolina Risk Malyds Rama...dralt 13•96 92-Cummtap9mil5,conbansal won in wound water to mpel.<Mara, a-s00104b4Lateoec6Mtla9
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Attachment 9-Maps and Cross Sections
The following maps and cross sections are attached as Appendix A:
Figure 1 Site Location Map
Figure 2 Site Vicinity Map
Figure 3 Site Facility Map
Figure 4 Shallow Aquifer Groundwater Elevations
Figure 5 Bedrock Aquifer Groundwater Elevations
Figure 6 Cross Section Locations
Figure 7 Hydrogeologic Cross Section A-A'
Figure 8 TCE in Soil Cross Section AA-AA'
Figure 9 TCE in Saprolite Aquifer
Figure 10 TCE in Bedrock Aquifer
Figure 11 1,4-Dioxane in Saprolite Aquifer-July/November 2012
Figure 12 1,4-Dioxane in Bedrock Aquifer-July/November 2012
Figure 13 SVE/AS Pilot Test Layout
Figure 14 Air Sparge Well Schematic
Figure 15 Soil Vapor Extraction Well Schematic
Figure 16 Observation Well Schematic

Appendix A—Figures

'ARS TECHNOLOGIES, INC.
BREAKING NEW GROUND IN ENVIRONMENTAL TECHNOLOGY
•
. •.r .
Pneumatic Fracturing Structural
Analysis Report
Energizer Battery Company
Asheboro, North Carolina
Submitted to:
ERM
7300 Carmel Executive Park
Suite 200
Charlotte,NC 28226
April 9,2014
Prepared by:
ARS Technologies,Inc.
114 North Ward St
New Brunswick,New Jersey 08901
nn, .D.,P.E. Steve Chen. P.E.
NJ P.E. # 21- 1- ;0415.9100 NJ P.E. #24GE04129700
NY F.E. #080076-1
PA P.E. #062140
MD P.E. #39352
DE P.E.#16647
IN P.E.#PE11100195
IL P.E. #062.065564
CT P.E. #PEN0028629
KY P.E. #28161
98 NORTH WARD STREET,NEW BRUNSWICK,NJ 08901
TEL.[phone] FAX [phone]
W W W.ARSTECHNOLOGIES,COM

TABLE OF CONTENTS
1.0 INTRODUCTION AND SCOPE OF WORK 1
2.0 SITE BACKGROUND 2
2.1 Geology and Hydrogeology 2
2.2 Facility Operations 2
2.3 Structure Construction Details 3
3.0 STRUCTURAL ANALYSIS 5
3.1 Objectives 5
3.2 Deform 6
3.3 Structural Modeling Results 9
4.0 OPERATING PROCEDURES 9
5.0 CONCLUSIONS 9
APPENDIX A 12
APPENDIX B 139
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1.0 INTRODUCTION AND SCOPE OF WORK
This Structural Analysis Application Report was developed to assess the potential effects
of Pneumatic Fracturing (PF)on the building structure and Above Ground Storage Tanks
(AST)at the Energizer Plant Facility located in Asheboro, North Carolina (site) as part of
the remedial treatment that involves the application of PF and subsequent well
installation.
ARS was contracted to perform a field reconnaissance survey to assess structural
integrity of the building and above ground storage tanks that could be impacted by
Pneumatic Fracturing. The site visit consisted of collecting measurements, as well as
photo and video logging the areas that could be potentially impacted by PF. Research was
also performed on previous PF applications successfully implemented at the Asheboro
facility by ARS and other pneumatically fractured sites with similar geologic formations
and depths as the site. A thorough review of this information will allow ARS to perform
an empirical analysis relating to the response of the soils to PF injections at these depths.
This empirical data is inputted into an analytical model DEFORM to predict ground
surface heave and the affected movement on the structure.
The culmination of this research and site survey is presented in this report with detailed
movement criteria to be monitored in the field during each fracturing event.
Pneumatic Fracturing is a patented process that enhances the removal and treatment of
hazardous contaminants from geologic formations, thereby reducing treatment time and
extending the availability of in situ technologies to more difficult sub-surface conditions.
More specifically, the PF process involves the injection of pressurized gas through a
borehole/well and into the contaminated formation where the gas overcomes the in situ
stresses and cohesive forces that bind the formation together, thereby creating a fracture
network and increasing the bulk permeability of the formation. This procedure improves
access to the contaminants,which can then be removed or treated in place.
During the PF process, the geologic formation in the vicinity of the fracture plane will
deform vertically as the fractures propagate outward horizontally. For shallow fracturing
(<20 ft.), these deformations may translate into measurable heaving of the ground
surface. The magnitude of the surface heave depends on a number of variables including
the injection pressure/flow rate, depth, formation geology, and stiffness of the overlying
structures/pavement. Maximum ground surface heave is typically observed at the
injection well head, and tapers to zero with increasing radius. Peak heave values have
ranged from less than 0.1 inches to more than 1 inch at the point of injection. It is noted
that peak values are transient and occur only during the gas injections; permanent
residual heaves if any are significantly less.
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When applying PF near or adjacent to structures, the effects of ground surface heave on
the overlying structure and utilities need to be considered to prevent detrimental effects to
the structure. A thorough understanding of the interaction between the heaving geologic
formation and surface structures is required to develop site-specific field operating
procedures. The fundamental premise of this analysis is that it is widely acknowledged in
the fields of geotechnical and structural engineering: all structures experience some
amount of movement during their service life. This is usually in the form of downward
settlement due to soil compression, cyclical heaving and settling due to seasonal
variations of soil moisture and temperature. If the structure can tolerate these
geotechnical movements, then they can also tolerate some ground surface heave resulting
from PF. The goal of site-specific operating procedures is to establish tolerable
movement criteria for structure and to control PF injections so that surface heave remains
below this criterion.
2.0 SITE BACKGROUND
2.1 Geology and Hydrogeology
The geology encountered within the treatment area is comprised of three lithologic units
consisting of 1) Structural Fill - Silt with some fine sand and clay ranging from a depth of
8 to 18 feet bgs 2) Saprolitic soils ranging in depth from 10 to 15 feet bgs and 3)Partially
weathered rock consisting of dark gray metavolcanic mudstone from a depth of 25 to 63
feet bgs.
The depth to groundwater at the site varies from 7 to 31 feet bgs. Groundwater elevation
data indicates that flow is in the southeast-south direction primarily within the saprolite
and weathered bedrock.
2.2 Facility Operations
The Eveready Battery Company operates a battery manufacturing facility located at 419
Art Byran Drive in Asheboro, North Carolina. The facility is situated on approximately
28.5 acres and includes nearly 579,000 square feet of manufacturing, warehousing and
office space. Since 1968, the facility has manufactured standard dry cell alkaline
batteries. The facility is currently active with standard production/manufacturing type
activities.
During an excavation beneath a concrete floor inside the plant building, elevated
concentrations of solvents were found within the soils which are suspected to be related
to a former solvent vapor recovery unit which was used to recover TCE and 1,1,1-TCA
from a former vapor degreaser operation. The location of this operation was directly over
the area of contaminated soil.
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Soil Vapor Extractions (SVE) and Air Sparging (AS) were tested as a remediation
technology in the area. However, due to the tight nature of the formation and low flow
rates achieved during the testing, it was concluded that these technologies would be only
marginally applicable. To facilitate increased flow-rates of the treatment system within
the remediation target area, in 2001 ARS Technologies was contracted to Pneumatically
Fracture (PF) the soil strata from depths of 5 to approximately 27 feet bgs. The results of
this initial pilot test resulted in significant increases in soil permeability and increased
contaminant extraction rates.
2.3 Structure Construction Details
On March 25, 2014 a site inspection was performed to identify building load members
that may be impacted by the fracturing at specific site locations. In addition to taking
photos of the key area, a walkthrough was performed to identify any pre-existing
conditions (i.e. cracks, holes, deformations or damage to the structure) in the area of PF
injections. No evidence of significant structural damage was observed. A photo-log in
Appendix A documents pre-existing conditions at the site. As direct access to all structure
members was not possible (most notably the wall footings) and detailed subsurface
structural drawings not available, assumptions were made by ARS' structural engineer in
his analysis. A site map depicting the locations of the proposed PF points are shown in
Figure 1.
The scope of work will entail the performance of a Pilot Study consisting of fracturing
two (2) borings from a depth of 6 to 50 feet bgs. Following completion of the fracturing,
two fracture borings will be converted over to an Air Sparge (AS) well and Soil Vapor
Extraction Well (SVE) designated as AS-2 and SVE-5, respectively. It is expected that
operations relating to drilling/borehole installation will not have any potential impacts to
the structures and therefore information specific to this task item will not be included in
this report. Relevant information pertaining to the drilling phase of the work will be
included in ARS site specific Health and Safety Plan.
The field evaluation identified three(3) structural components that were determined to be
the areas with the highest likelihood of impact by fracturing. A description of these
components is as follows:
1) A series of flanged steel load bearing columns supporting the canopy roof over the
loading dock. Inspection of the column provided dimensions, overall length and
connections.
2) A total of two (2) concrete block cradles supporting AST's. Information provided on
ERM's Figure 15 "Conceptual Full-Scale SVE Layout" identified the tanks as "Former
Waste TCE &TCA"AST's with a capacity of 2,000 gallons each. Current signage on the
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tanks shows they are used for storing#2 fuel oil. Statement from the plant representative
indicates that these tanks are filled to 50%of their capacity.
3) Concrete containment berm surrounding the AST's.
Figure 1 -Plan View of the Fracture Area with Injection Wells
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3.0 STRUCTURAL ANALYSIS
The presence of the existing building and AST's at the site warrants the performance of a
structural analysis. The objective and results of the analysis are discussed throughout the
remainder of this report.
3.1 Objectives
The conducted field survey provides data that will be used to evaluate the potential
effects of PF injections on overlying structures at the site.
Safely applying fracturing technologies beneath or adjacent to structures requires the
establishment of a Maximum Movement Criteria(MMC) for the structure combined with
the precise control of the pneumatic injections so the surface heave at this load point
remains below this criterion. Thus, successful fracturing in the vicinity of an existing
structure requires a thorough assessment of the buildings construction and condition, as
well as an analysis of its deformation response to the injections.
It is difficult to determine the exact magnitude of differential foundation movement that
would cause significant damage to structures since such analysis must consider soil
heterogeneities, structural material uncertainties, settlement rates, contact pressures,
footing stiffness and connection rigidity, and the nature of the actual loads transmitted to
the foundation units. This complexity and uncertainty typically prohibits engineers from
developing a site-specific analytical solution for tolerable structural movements.
Consequently, a procedure based upon empirical methods has been established which
utilizes observations of actual building movements' potential structure damage and the
site-specific ground surface heave as a result of injections.
In most structures, the tolerable limit is governed by the aesthetic and serviceability
requirements, and not by the structural requirements. In most cases of natural settlement
damage, unsightly cracks,jamming doors and windows, and other similar problems will
develop long before the structures integrity becomes a concern. These vary depend on
numerous factors, the most obvious include the following: type of structure (wood, steel,
masonry, etc.), use of the structure (residential, commercial or industrial), presence of
sensitive finishes (tiled floors versus asphalt paving), and the rigidity of the structure
(which will determine how loads due to movements will be distributed).
In 2001, ARS was contracted by ERM to implement a four(4) hole PF Pilot Study within
the Former Solvent Vapor Recovery Area approximately 100 feet from the currently
scheduled work. A review of operational parameters specific to fracturing pressures is
summarized in Table 1 below. In 2001 pilot study, PF was successfully applied from a
depth of 5 to 27 feet bgs with detectable pressure influence at the surrounding monitoring
well network. Pressure required to initiate and propagate fractures ranged between 80 and
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120 psi. Based on this information, it is anticipated that the injection pressures required to
initiate fractures will be similar at the proposed work area. We can expect that relatively
low pressures of approximately 100 psi will be required for fracture injections shallower
than 30 feet bgs. Deeper than this depth, it is anticipated that fracture propagation
pressures will increase due to overburden pressure. Empirically, ARS has found that
overburden stresses equates to between 3 and 6 psi per foot of depth. However, this does
not account for the in situ stresses and degree of natural existing fractures and or the
presence of bedding planes. Under circumstances whereby surcharge loads are present
(buildings or concrete pads) the above value will increase slightly to overcome the
additional stresses imposed by the building on the underlying soil/rock matrix.
Table 1 - Data parameters for PF Application at Eveready Plant,2001.
Borehole Location Injection Interval Initiation Pressure Maintenance Pressure Influence
[ft bgs] [psi] [psi] [psi/location]
FW-1 24'10"-27'1" 119 91 10/0P2;5.5/SVE-1;28.5/MW1
1.5/FW3;5/FW4;13/FW2;5/0P3
20'9"-24'2" 101 96 3.7/0P3;17.5/MW1;20;SVE-1
17'6"-20'9" 109 109 5/0P3;5.5/SVE-1;25.5/MW1;6/FW3
14'4"-17'7" 99 99* 3/OP3;4.5/SVE-1;23.5/MW-1
11'2"-14'4" 121 121 3.4/0P3;5/SVE-1;1S8/MW•1
8'-11'2" 153 110 3/0P3;7.5/SVE-1;14/MW-1
2/FW-3;3/OP-1
5'2"-8'5" 80 80 3/0P3;3/SVE-1;4/MW-1;13/0P2
2/O P 1
FW-2 19'3"-23'3" 98 87 13/OP3;
15'3"-19'3" 108 108* 14.5/OP3;
11'3"-15'3" 108 118* 4/0P3
7'3"-11'3" 110 110 3.5/0P3
FW-3 18'2"-22'2" 125 115 8.5/OP1;2.2/OP3;2/FW-2;2.5/SVE-1
14'2"-18'2" 91 91 9.5/OP1
10'7"-14'2" 95 95 3/FW-2;2.5/0P3;5.5/0P1
6'2"-14'2" 96 110* 3.5/OP1
FW-4 18'10"-22'10" 120 110 2.5/0P3;3.5/SVE-1;17/MW1;2.5/FW3
14'10"-18'10" 3/0P3;5/SVE-1;3/MW1;FW2
10'10"-14'10" 107 115* 2.5/0P3;4/SVE1;16.2/MW1;FW2
6'10"-10'10" 2.5/0P3;5/SVE1;
5'-9' 120 120 1.5/0P3;4/SVE1
3.2 Deform
The first model (DEFORM) was developed at the New Jersey Institute of Technology
(NJIT) to predict the magnitude of ground surface deformation at distance from
pneumatic fracturing injection points based on site-specific data.
The ground deformation model equation is as follows:
W=Px(1-v2)(x4-2R2x2+R4) [Eq.1]
(16Ez3)
Where;
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W =ground deformation(ft.)
Px =fracture maintenance pressure (psi)
v =Poisson's ratio
x =distance from injection point(ft.)
R =radius of fracture influence (ft.)
E =modulus of elasticity(psi)
z =fracture depth(ft.)
Using site specific data from the 2001 Pneumatic Fracturing activities, a total of three (3)
ground deformation curves were generated based on the above Equation 1. Soil
properties (v and E) were obtained for dense silty clay (Table 2) identified in published
geo-technical literature and site specific heave data generated from the 2001 PF
application at the site. The curves are presented in Figure 2 depicting the amount of
expected ground deformation with respect to distance from the injection point for
injection maintenance pressures of 100 psi at 10 feet bgs, 150 psi at 20 feet bgs and 200
psi at 30 feet bgs. Further evaluation of the 100 psi at 10 feet bgs curve when compared
to the observed heave data during the 2001 PF implementation reveals a good correlation
with respect to what is predicted based on DEFORM and what was observed. In the 2001
Report of Results document produced by ARS, 0.4 inches of heave was observed at a
wall approximately 4 feet away from the injection point at a depth of 12 feet bgs. The
extent of heave within a radial distance of 5 feet from the PF borings, showed heave to
vary from 0 to 0.5 inches and is in agreement with the DEFORM generated curves. The
modeling presented in the figure indicates that a maximum heave of 0.4 inches will likely
be observed at the injection point for a 100 psi maintenance pressure at a PF depth of 10
feet bgs. The model also indicates that minimal heave will result at distances at or greater
than 15 feet from the injection point. It is also important to note and based on Equation 1
that the extent of heave is inversely proportional with depth. Therefore it can be expected
that the greatest surface heave will be most pronounced at the shallow depths and will
need to be closely monitored from depths shallower than -20 feet bgs.
It is expected that injections shallower than 10 feet bgs will require lower fracture
pressures relative to what was encountered during the 2001 Pilot Test. This statement is
based on the following criteria:
1) The proposed PF locations are located outside the structure and overburden
stresses associated with the building load will not be a factor requiring lower
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pressures necessary to exceed the in situ stresses associated with the soil matrix
only.
2) The presence of fill consisting of silt with some fine sand and clay from surface
down to 7 feet bgs will also facilitate lower pressures since it will not have the
same in situ stresses/low permeability properties associated with the native
saprolitic soils.
Table 2 -Elastic Modulus as a Function of Confining Stress Determined from
Triaxial Tests(Fairbanks,2002)
Confining
Stress E
(psi) (psi)
20 5500
10 5000
5 3700
2 3200
Figure 2—Anticipated Ground Deformation with Distance
Anticipated Ground Deformation with Distance
0.45
0.40
-100 psi Pres at 10 ft bgs
0.35 1 150 psi Pres.at 20 ft bgs
_ 1 —200 psi Pres.at 30 ft bgs
• 1a
0.30
c
.3
0.25
0
.q
f, 0.20
d
a
c
Q 0.15
0
0.10
NN
-20 -15 -10 -5 0 5 10 15 20
Fracture Radius-x(feet)
• i i.
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3.3 Structural Modeling Results
Structural modeling was used to analyze potential structural impacts on the building in
response to PF. Modeling analysis of these structural components to withstand the
pneumatic fracturing was performed and was the focus of this investigation, as shown in
Appendix A. The data including all supporting equations and documentation is provided
in Appendix A of this report. Based on the structural movement criteria determined
through analysis, the operating parameters that should be followed during Pneumatic
Fracture injections are derived.
4.0 OPERATING PROCEDURES
Based upon both the modeling output contained within this report and ARS' past field
experience with similar projects, specific operational parameters will be implemented in
the field during all injections under this project. More specifically, a MMC heave of 0.5
inches is established as the upper limits of the acceptable wall movement. Movement of
this magnitude is not expected since the PF initiation pressures are expected to be low for
the shallow intervals (< 20 bgs). The data obtained from both empirical site data and the
DEFORM modeling equation predicted maximum heave (0.4) inches for a 100 psi
maintenance pressures at a depth of 10 feet bgs. Strict adherence to these procedures will
result in effective injection operations with no detrimental impacts to the structure at the
site.
Further analysis will be conducted during the Pilot Study to further ascertain the
anticipated injection parameters (pressure, heave, radius of influence). These parameters
will be utilized to anticipate future movement criteria for the Full-Scale application.
Based on these observations, an addendum to this report will be included prior to
performing additional fracturing on the loading dock and inside the building.
5.0 CONCLUSIONS
1. The structural system of the building consists of steel joists, load bearing walls.
The structure in the immediate area of the proposed pneumatic fracturing appears
to be in sound condition. There is no apparent evidence of excessive differential
settlement or other major structural distress. Both the structure type and the
materials of construction have been shown being tolerant of movement.
2. As part of this report, an examination of previous PF applications at the Eveready
facility in 2001 was conducted. The data generated from the 2001 Pilot Study
were evaluated and used to develop and customize the DEFORM modeling
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equation specific to the injection parameters observed at the site. This data was
used to provide an estimate on how the sites geology will respond to gas
injections. The maximum magnitude of ground surface heave adjacent to the
injection well was observed and calculated to be 0.43 - 0.5 inches (within a 5 foot
radial distance). At radial distances at or beyond 10 feet, surface heave has been
shown to be minimal and trend to 0 at a 15 foot radial distance. It is recommended
that the site-specific heave and injection pressure data be collected from the
deepest zones first to ascertain the anticipated heave as the injections approach the
surface. Also, injection pressures will be decreased incrementally as shallower
injections are applied to insure excessive pressure beyond the true fracture
propagation pressure is not exceeded. This will validate the assumptions made in
the analytical model with site-specific data. It is recommended that the fracture
locations be positioned/installed no closer to 8 radial feet from any load bearing
column or tank support member.
3. The Structural Analysis provided in Appendix A includes an analysis of structures
within the facility that could be potentially impacted by PF. These included a
series of support columns, a beam and 2 existing AST's. Based on the DEFORM
modeling and previous PF applications at the site, it is anticipated that the
maximum surface heave directly adjacent to the injection well could potentially
reach a maximum of 0.5 inches. The maximum heave expected at a distance of 15
feet is expected to be minimal and/or zero. This maximum heave value of 0.5
inches was then utilized in the structural monitoring analysis with the intent to
show what structural impacts would occur if the one of the structures identified
above were subject to 0.5 inches of heave. The analysis included in Appendix A
confirmed no detrimental impacts would occur at a movement of 0.5 inches.
4. Structural monitoring during the fracturing operations will be performed using
heave rods placed on the ground surface adjacent to the injection point and
attached to the closest structures (canopy support column, AST tank cradle).
During all injections, the field crew will maintain verbal communication to
indicate sudden movement of either of the structure monitored load bearing
members. As a precaution, any movement approaching 0.5 inches will be a cease
injection condition.
5. No sensitive utilities were observed near the proposed fracture locations. The
nearest utility is a storm sewer located approximately 10 to 12 feet away. Due to
its shallow depth and the lower injection pressures used (less than 100 psi), no
detrimental impact to this utility is expected.
6. Inspection of the area adjacent to the proposed fracture location shows extensive
asphalt cracking and stress cracking on the tank berm retaining wall. See photo's
in Appendix B.
laARS Technologies,Inc.

4/11/2014
Structural Report
Eveready Site,NC
ERM-NC
11
7. The structural modeling calculations pertaining to the AST Tank Concrete Saddle
(provided in Appendix A) included a conservative assumption (factor of safety)
and neglected any additional dead load associated with the liquid in the tanks.
Any additional downward or dead loads not accounted for in the modeling
calculations will provide more resistance and a greater factor of safety to direct
any impacts from fracturing.
ARS Technologies,Inc.

APPENDIX A

COLUMN ANALYSIS
The steel structure at the loading dock has been designed to meet the AISC codes as evident that they
are still functioning. If the pneumatic fracturing near the column heaves the column by 0.5", we will
estimate the stresses this heave will cause and determine if these stresses are high enough to cause a
problem.Please note the actual heave may not be noticeable.
Assumptions
In developing the structural computer model and evaluating the structure for the building, several
assumptions were made that are presented below:
a) ARS personnel approximated dimensions since no structural drawings were available. Dimesions
were assumed where access was not available. Dimensions and load were taken from the visual
inspection.
b) Uniform Building Code (UBC) 1994 edition was used as basis for loads where loads were not
given.
c) American Institute of Steel Construction, Inc. (AISC) ninth edition was used as basis for steel
member properties and sizing. AISC manual ninth edition was used for allowable stress design
code verification.
d) American Concrete Institute code ACI 318.
e) Non Reinforced Masonry Design Guide,by National Concrete Masonry Association.
f) Assumed factory building Group B,Div.4 of UBC.
g) Proprties of colmn and roof girders were based on the AISC individual steel section properties.
h) All beams assumed simply supported connection.
i) Two dimension plane structure assumed for the structural analysis.
j) All columns assumed fixed at the base or pinned at the base.
k) Since only a small portion of the wind load at the full wind load condition is applied to columns
at the time of horizontal fracturing operation, and as all the interior columns in the same row
share this load,the impact of wind load is assumed minimal and is not taken in the analysis.
1) The ground heave under one column was assumed to be 0.5". The analysis of the structure was
based on 0.5" ground heave.
m) The beam girder is assumed to be restrained along its length in compression flange at every 10
feet by the joist.
••:•:
•
ARS Technologies,Inc.

n) No live load during injection..No personnel should be on the roof during injection.
Design Loads
LOADS on Steel Building
Dead Loads: lb./sq.
a) 22 gage steel deck and glass 2.0
b) 1" insulation(assumed) 1.5
c) Purlins 3.0
d) Beams 3.0
e) Mechanical&Miscellaneous 2.0
Dead Load 11.5 lb./sq. say 12 lb./sq.
Live Load(snow Load) 15 lb./sq.
Total 27 lb./sq.
The joists and beams are simple supported on the column. Columns are placed at 25 center. The
joist is 6'10" long.
Assume purlins load are uniformly distributed load.
Dead load on Roof Joist=12*25' =0.3Kips/ft.
Live load on roof Joist= 15*25'=0.3755Kips/ft.
As area is shielded by other buildings, neglect wind load.
Load on Building
Load Case 1, = 1.4*Dead+0.0*Live+0.0*Wind = 1.4(0.3)=0.42Kips/ft.
Load Case 2, = 1.2*Dead+ 1.6*Live+0.0*Wind = 1.2*.3+1.6*.375=1.02Kips/ft.
Load Case 3, = 1.2*Dead+0.0*Live +0.8*Wind = 1.2*.3+0=0.42 Kips/ft.
Load Case 4, PD4, MzD4, MyD4 = 1.2*Dead+0.5*Live+ 1.3*Wind=
1.2*0.3+0.5*0.3 73+0=0.547Kips/ft.
Load Case 5, PD5, MzD5,MyD5= 1.2*Dead+0.5*Live+ 0.0*Wind=0.5477Kips/ft.

Load Case 6,PD6,MzD6, MyD6= 1.2*Dead+0.5*Live+ 1.3*Wind=0.547Kips/ft.
Service Load Calculations
Use load case 1 as there will be no live load during the injection.
The joist is 6'10"=6.833
Load on column= .42*6.833/2=1.435kips=1435 lbs.
COLUMN HEAVE LOADS Steel Building
AB
8WF31
N
N
N
1- 6'10"
21 21A
Assume column 21A is uplifted by 0.5". This will cause beam member AB to be strained and
will produce axial force along its member if the column tops restrained from moving sideways.
Since column 21 and 21A are not restrained at the top, they will move slightly. This will cause
moments at the bottom of the column. The column movement is calculated and this movement is
applied as joint displacement load on the plane structure to simulate the column heave.
Also the end load on column 21 and 21A are now eccentric to column and this will cause
additional moment at the base of the column.
Calculate the beam displacement. (Typical)
Member AB(82" long)
The new length= SQRT(8202+.0.52)=SQRT(6724.25)=82.001524
Elongation S 2= 82.0001524—82.0=0.0001524 in.
Top tip of the column 21 and 21A will move by this amount.

82
Calculate the bending moment and the corresponding stress (typical)
Column 21A (length 264; I= 109.7 in4; S=27.4. in3; e=2.9E07)
Point Load on the column is 1435 lbs.(see above)
The bending moment at the base of the column due to this displacement is
BMs=6E1 (62)/L**2
BMs= 6*2.9*E07*109.7* 0.00015/ (264*264) = 41.7Ibin.
Bending moment due to load eccentricity of 0.0001524 in. (Load= 1435 lbs.)
BMe= 143 5*0.0001424= .21 lb. in
Total BM=47.1+0.21=47.31 lb. in
Total Stress due column heave=Total BM/S=47.31/27.4=1.71 psi
This will have no impact on the column.
Checking the column to resist the upward force during Pneumatic Fracturing.
Check if the column 8WF31 can take the injection force, assuming that the injections are directly
under it. (Conservative assumption,the actual injection well are 6 ft. away). The injection well is
4" diameter and the pressure (max) is 150 psi.Neglect the roof dead load (Conservative)
The column is 22 ft. long and weighs 31 lbs.per foot.
Column Dead weight CW=22*31=682 lbs.
The column foundation pier is shown below.
Weight of the footing=FW. Assume concrete 150 lbs./cu ft.
FW=7.5*7.5*2+4.*14*14/(12*12)=112.5+5.4= 118 cu ft.
FW=118*150=17700lbs.
Total weight of column+ footing= 17700+682=18382 lbs.
The total upward force on the one foot section of the wall is (4X4 x 3.14/4)x 150= 1884 lbs.
The dead weight of the footing alone will resist the upward force due to injection. The ground
under the column will not heave.

14"
•
5'-0"
- I
O
37'-0" �.
Column Foundation Pier(Footing)
AST Tank Concrete Saddle
Check if the AST Tank Concrete Saddle can take the injection force, assuming that the injections
are directly under it. (Conservative assumption, the actual injection well are 6 ft. away). The
injection well is 4" diameter and the pressure (max) is 150psi. Neglect the AST tank load dead
load(Conservative).
The total upward force due to pneumatic fracturing on the concrete saddle is (4X4 x 3.14)/4)x
150=1884 lbs.
The concrete saddle is 18'8"wide, 3'10"high and 12"thick.
Weight of saddle= 18.666*3.8333*1*150=.10729 lbs.

Neglecting both live and dead load (conservative) and assume all the upward force is resisted by
the sheer force on the Saddle.
Allowable shear for concrete=53 psi
Punching shear.
The saddle is 3.10"high (46") and 12"thick
Assume the 4 "diameter hole through saddle and force resisted by the 4" dia. perimeter area.
Area=3.14 x 4 x 46=578 sq. in. Shear stress= 1884/578=3.3.8 psi < 53 psi allowable shear
stress.
The saddle will resist the upward force of pneumatic fracturing.
The Spill Containment Wall
The spill containment wall is 8"thick and is 21'4"wide and 42'8" long and is 1'8"high. The
wall is tied to an 8"thick concrete slab.
Check for punching shear through the concrete slab. Assume 4 dia. hole through the 8" slab
resist the upward force
Area=3.14*4*8=100.48 sq. in.
Shear stress= 1884/100.48=18.75 psi <53 psi allowable shear stress for concrete.
Wall total height= 1' 8'+8"=2'4'
Wall is 8"thick
The upward force is 1884 lbs.
Check if wall can be sheared 3.14*4*28=351.68 sq. in.
Shear stress= 1884/351.86= 5.35 psi<53 psi
Wall will stand the Pneumatic Fracturing load.
The containment will resist the upward force of pneumatic fracturing.

APPENDIX B

Figure 1: Cross Section View of the Loading Dock
Figure 2: Loading Dock View (drawing)
illARS Technologies,Inc.

Figure 3: Loading Steel Framing
Roof Beam and Purlins
6-Ix17.5 Beam
=I
8WF31
8WF31
i
I Loading Dock
-4— 6'10" 4 12'6" I�— 6'10" —►1
21A 21 20
Figure 3: Loading Steel Framing

Figure 4: AST with Spill Containment Drawing
t.
4 t
, •
I 1 '

Photo 1: View of the loading dock from South
: r ,,
.,
, _
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. . ,..,,,,
. . . ..
.a _ .-1— . 14
—
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Loading Dock Column(SWF3I) ASiy " --i .4
PROPOSED - i
AS-2 &SVE-5
A V I
ilesaik ASTs

Photo 2: View of The loading Dock from North
I
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•
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is r
_ •_ � Loading Dock Column(51 �-r--
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Photo 3: Inner 1OWF100 Column
tow'Jou column
A4
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V.1

Photo 4: The AST Tanks and Containments
FUS #
,t. a• 1993
t +
l - 11"1/2;111111H'
Mk I 71*P.P74_I I We -
Photo 5: AST Tank Saddle Support
•
•

Photo 6: Pre-Existing Cracking and Damage to Tank Berm Wall
'R1
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r rs
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y :e tar , 1• +a ?ti. a :•f ~ 1' w�_ '.. -- 4 isomo.
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owe :a.; �J _ 4i _ _
ARS Technologies,Inc.

Photo 7: Pre-Existing Cracking in Tank Berm Wall
y'
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t 74 • ' •
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itety ' .
pl. .,•
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Photo 8: Inside Column Upper Support to Beam
1
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ti „ — —.-..aa
Photo 9: Asphalt Cracking and Frost Heave Adjacent to Storm Sewer
•
+ S r _
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t
{
.. _ • - T',
3
-a r- __ . .. - w • - . . r•

Photo 10: Pre-Existing Extensive Asphalt and Concrete Surface Cracking
w .
•
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111> .
11'1. e, ry •. .• '.,

Photo 11: Additional Pre-Existing Asphalt Cracking
-
. t A '
•
d

Appendix C—Pneumatic Fracturing Structural Analysis Report

Nitrogen
Label requirements Class A: Compressed gas.
Hazardous Material : Health 11111, 0
Information System (U.S.A.)
Flammability 0
;, sisal h- 0
liquid:
3
Fire hazes 0 1
Reactivity 0
Personal protection
National Fire Protection Flammability
Association (U.S.A.)
Health 0 Instability
NA
Special
liquid:
Flammability
Health 0 Instability
SA Special
Notice to reader
To the best of our knowledge,the information contained herein is accurate. However, neither the above-named
supplier, nor any of its subsidiaries,assumes any liability whatsoever for the accuracy or completeness of the
information contained herein.
Final determination of suitability of any material is the sole responsibility of the user. All materials may present
unknown hazards and should be used with caution. Although certain hazards are described herein,we cannot
guarantee that these are the only hazards that exist.
Build 1.1 Page:6/6

Nitrogen
Mexico UN1066 NITROGEN, 2.2 Not applicable (gas).Classification COMPRESSED
UN1977 Nitrogen, refrigerated
liquid
"Refer to CFR 49(or authority having jurisdiction)to determine the information required for shipment of the
product."
Section 15. Regulatory information
United State&
U.S.Federal regulations TSCA 8(a)CDR Exempt/Partial exemption:This material is listed or exempted.
United States inventory(TSCA 8b):This material is listed or exempted.
SARA 302/304: No products were found.
SARA 311/312 Hazards identification: Sudden release of pressure, Delayed (chronic)
health hazard
State regulations Connecticut Carcinogen Reporting: This material is not listed.
Connecticut Hazardous Material Survey:This material is not listed.
Florida substances:This material is not listed.
Illinois Chemical Safety Act:This material is not listed.
Illinois Toxic Substances Disclosure to Employee Act:This material is not listed.
Louisiana Reporting: This material is not listed.
Louisiana Spill:This material is not listed.
Massachusetts Spill: This material is not listed.
Massachusetts Substances:This material is listed.
Michigan Critical Material:This material is not listed.
Minnesota Hazardous Substances: This material is not listed.
New Jersey Hazardous Substances:This material is listed.
New Jersey Spill: This material is not listed.
New Jersey Toxic Catastrophe Prevention Act:This material is not listed.
New York Acutely Hazardous Substances: This material is not listed.
New York Toxic Chemical Release Reporting: This material is not listed.
Pennsylvania RTK Hazardous Substances: This material is listed.
Rhode Island Hazardous Substances:This material is not listed.
Canada
WHMIS (Canada) Class A: Compressed gas.
CEPA Toxic substances: This material is not listed.
Canadian ARET:This material is not listed.
Canadian NPRI:This material is not listed.
Alberta Designated Substances: This material is not listed.
Ontario Designated Substances: This material is not listed.
Quebec Designated Substances:This material is not listed.
Section 16. Other information
United States
Label requirements GAS:
CONTENTS UNDER PRESURE.
Do not puncture or incinerate container.
Can cause rapid suffocation.
May cause severe frostbite.
LIQUID:
Extremely cold liquid and gas under pressure.
Can cause rapid suffocation.
May cause severe frostbite.
Canada
Build 1.1 Page:5/6

Nitrogen
Section 11. Toxicological information
Toxicity data
Chronic effects on humans May cause damage to the following organs: lungs.
Other toxic effects on No specific information is available in our database regarding the other toxic effects of
humans this material to humans.
Specific effects
Carcinogenic effects No known significant effects or critical hazards.
Mutagenic effects No known significant effects or critical hazards.
Reproduction toxicity No known significant effects or critical hazards.
Section 12. Ecological information
Aquatic ecotoxicity
Not available.
Environmental fate Not available.
Environmental hazards : No known significant effects or critical hazards.
Toxicity to the environment : Not available.
Section 13. Disposal considerations
Product removed from the cylinder must be disposed of in accordance with appropriate Federal,State, local
regulation.Return cylinders with residual product to Airgas, Inc.Do not dispose of locally.
Section 14. Transport information
Regulatory UN number Proper shipping Class Packing group Label Additional
information name information
DOT Classification UN1066 NITROGEN, 2.2 Not applicable(gas). Limited
COMPRESSED quantity
Yes.
UN1977 Nitrogen, refrigerated Packaaing
liquid instruction
Passenger
aircraft
Quantity
limitation: 75
kg
Cargo aircraft
Quantity
limitation: 150
kg
TDG Classification UN1066 NITROGEN, 2.2 Not applicable (gas). Explosive
COMPRESSED Limit and
Limited
Quantity
UN1977 Nitrogen, refrigerated Index
liquid 0.125
Passenger
Carrying
Road or Rail
Index
75
Build 1.1 Page:4/6

Nitrogen
Storage Cylinders should be stored upright,with valve protection cap in place, and firmly
secured to prevent falling or being knocked over. Cylinder temperatures should not
exceed 52°C (125°F).
For additional information concerning storage and handling refer to Compressed Gas
Association pamphlets P-1 Safe Handling of Compressed Gases in Containers and P-
12 Safe Handling of Cryogenic Liquids available from the Compressed Gas Association,
Inc.
Section 8. Exposure controls/personal protection
Engineering contro Use only with adequate ventilation. Use process enclosures, local exhaust ventilation or
other engineering controls to keep worker exposure to airborne contaminants below any
recommended or statutory limits.
Personal protection
Eyes Safety eyewear complying with an approved standard should be used when a risk
assessment indicates this is necessary to avoid exposure to liquid splashes, mists or
dusts.
When working with cryogenic liquids,wear a full face shield.
Skin Personal protective equipment for the body should be selected based on the task being
performed and the risks involved and should be approved by a specialist before
handling this product.
Respiratory Use a properly fitted, air-purifying or air-fed respirator complying with an approved
standard if a risk assessment indicates this is necessary. Respirator selection must be
based on known or anticipated exposure levels, the hazards of the product and the safe
working limits of the selected respirator.
The applicable standards are (US) 29 CFR 1910.134 and (Canada)Z94.4-93
Hands Chemical-resistant, impervious gloves complying with an approved standard should be
worn at all times when handling chemical products if a risk assessment indicates this is
necessary.
Insulated gloves suitable for low temperatures
Personal protection in case Self-contained breathing apparatus(SCBA)should be used to avoid inhalation of the
of a large spill product.
Product name
Nitrogen Oxygen Depletion[Asphyxiant]
Consult local authorities for acceptable exposure limits.
Section 9. Physical and chemical properties
Molecular weight : 28.02 g/mole
Molecular formula . N2
Boiling/condensation point : -195.79°C (-320.4°F)
Melting/freezing point -210.01°C (-346°F)
Critical temperature -146.9°C (-232.4°F)
Vapor density 0.967 (Air= 1) Liquid Density@BP: 50.46 lb/ft3 (808.3 kg/m3)
Specific Volume (ft 3/Ib) 13.8889
Gas Density(Ib/fr" 0.072
Section 10. Stability and reactivity
Stability and reactivity The product is stable.
Hazardous decomposition Under normal conditions of storage and use, hazardous decomposition products should
products not be produced.
Hazardous polymerization Under normal conditions of storage and use, hazardous polymerization will not occur.
Build 1.1 Page:3/6

Nitrogen
See toxicological information (Section 11)
Section 3. Composition, Information on Ingredients
Name CAS number °I° Volume Exaosure limits
Nitrogen 7727-37-9 100 Oxygen Depletion [Asphyxiant]
Section 4. First aid measures
No action shall be taken involving any personal risk or without suitable training.lf it is suspected that fumes are still present,
the rescuer should wear an appropriate mask or self-contained breathing apparatus.lt may be dangerous to the person
providing aid to give mouth-to-mouth resuscitation.
Eye contact : Check for and remove any contact lenses. Immediately flush eyes with plenty of water
for at least 15 minutes, occasionally lifting the upper and lower eyelids. Get medical
attention immediately.
Skin contact None expected.
Frostbite Try to warm up the frozen tissues and seek medical attention.
Inhalation Move exposed person to fresh air. If not breathing, if breathing is irregular or if
respiratory arrest occurs, provide artificial respiration or oxygen by trained personnel.
Loosen tight clothing such as a collar, tie, belt or waistband. Get medical attention
immediately.
Ingestion As this product is a gas, refer to the inhalation section.
Section 5. Fire-fighting measures
Flammability of the product : Non-flammable.
Products of combustion : Decomposition products may include the following materials:
nitrogen oxides
Fire-fighting media and : Use an extinguishing agent suitable for the surrounding fire.
instructions
Apply water from a safe distance to cool container and protect surrounding area. If
involved in fire, shut off flow immediately if it can be done without risk.
Contains gas under pressure. In a fire or if heated, a pressure increase will occur and
the container may burst or explode.
Special protective : Fire-fighters should wear appropriate protective equipment and self-contained breathing
equipment for fire-fighters apparatus(SCBA)with a full face-piece operated in positive pressure mode.
Section 6. Accidental release measures
Personal precautions : Immediately contact emergency personnel. Keep unnecessary personnel away. Use
suitable protective equipment(section 8). Shut off gas supply if this can be done safely.
Isolate area until gas has dispersed.
Environmental precautions : Avoid dispersal of spilled material and runoff and contact with soil, waterways, drains
and sewers.
Methods for cleaning up : Immediately contact emergency personnel. Stop leak if without risk. Note: see Section
1 for emergency contact information and Section 13 for waste disposal.
Section 7. Handling and storage
Handling : High pressure gas. Do not puncture or incinerate container. Use equipment rated for
cylinder pressure. Close valve after each use and when empty. Protect cylinders from
physical damage; do not drag, roll, slide, or drop. Use a suitable hand truck for cylinder
movement.
Never allow any unprotected part of the body to touch uninsulated pipes or vessels that
contain cryogenic liquids. Prevent entrapment of liquid in closed systems or piping
without pressure relief devices. Some materials may become brittle at low temperatures
and will easily fracture.
Build 1.1 Page:2/6

Material Safety Data Sheet Airqas
Nitrogen
Section 1. Chemical product and company identification
Product Nitrogen
Supplier AIRGAS INC., on behalf of its subsidiaries
259 North Radnor-Chester Road
Suite 100
Radnor, PA 19087-5283
1-610-687-5253
Product use Synthetic/Analytical chemistry. Liquid—cryogenic coolant.
Synonym nitrogen (dot); nitrogen gas; Nitrogen NF, LIN, Cryogenic Liquid Nitrogen, Liquid
Nitrogen
MSDS# 001040
Date of Preparation/ 11/22/2013.
Revision
Jn case of emergency 1-866-734-3438
Section 2. Hazards identification
Physical state Gas. [NORMALLY A COLORLESS GAS: MAY BE A CLEAR COLORLESS LIQUID AT
LOW TEMPERATURES. SOLD AS A COMPRESSED GAS OR LIQUID IN STEEL
CYLINDERS.]
Emergency overview WARNING!
GAS:
CONTENTS UNDER PRESURE.
Do not puncture or incinerate container.
Can cause rapid suffocation.
May cause severe frostbite.
LIQUID:
Extremely cold liquid and gas under pressure.
Can cause rapid suffocation.
May cause severe frostbite.
Do not puncture or incinerate container. May cause target organ damage, based on
animal data.
Contact with rapidly expanding gases or liquids can cause frostbite.
Target organs May cause damage to the following organs: lungs.
Routes of entry Inhalation
Potential acute health effects
Eyes Contact with rapidly expanding gas may cause burns or frostbite. Contact with cryogenic
liquid can cause frostbite and cryogenic burns.
Skin Contact with rapidly expanding gas may cause burns or frostbite. Contact with cryogenic
liquid can cause frostbite and cryogenic burns.
Inhalation Acts as a simple asphyxiant.
Ingestion Ingestion is not a normal route of exposure for gases. Contact with cryogenic liquid can
cause frostbite and cryogenic burns.
Potential chronic health effects
Chronic effects : May cause target organ damage, based on animal data.
Target organs : May cause damage to the following organs: lungs.
Medical conditions Pre-existing disorders involving any target organs mentioned in this MSDS as being at
aggravated by over- risk may be aggravated by over-exposure to this product.
exposure
Build 1.1 Page: 1/6

Appendix B—MSDS

LEGEND // 1,• • .y
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ASHEBORO,NORTH CAROLINA

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SITE VICINITY MAP FIGURE
ERM NC, INC. ENERGIZER BATTERY
419 ART BRYAN DRIVE
r ERM ASHEBORO,NORTH CAROLINA

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•
i Approximate Scale ``'•,
SITE FACILITY MAP FIGURE
ERM NC, Inc. ENERGIZER BATTERY
419 ART BRYAN DRIVE 3
ERM ASHEBORO,NORTH CAROLINA

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_ a�
SHALLOW AQUIFER GROUND WATER ELEVATIONS FIGURE
ERM NC, INC. JULY/NOVEMBER 2012
ENERGIZER BATTERY-419 ART BRYAN DRIVE Z
ERM ASHEBORO,NORTH CAROLINA

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3 BEDROCK AQUIFER GROUND WATER ELEVATIONS FIGURE
2 ERM NC, INC. JULY/NOVEMBER 2012
ENERGIZER BATTERY-419 ART BRYAN DRIVE
ERM ASHEBORO,NORTH CAROLINA

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j CROSS SECTION LOCATIONS FIGURE
I ERM NC, INC. JULY/NOVEMBER 2012
ENERGIZER BATTERY-419 ART BRYAN DRIVE V
ERNI ASHEBORO,NORTH CAROLINA

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r I Energizer Battery Property
a MW-14D' 0 Parcel Boundary
0 300 600 Feet • pg/L=Micrograms per Liter
. s Source of Aerial Photo:
r I ,l 1,, 2012 NAVTEQ/2012 Microsoft Corp
TCE IN SAPROLITE AQUIFER FIGURE
ERM NC, INC. JULY/NOVEMBER 2012
ENERGIZER BATTERY—419 ART BRYAN DRIVE
ERM ASHEBORO,NORTH CAROLINA

II'
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+� . -' ti r-------i Parcel Boundary
- ,••' _ ugh.=Micrograms per Liter
TCE IN BEDROCK AQUIFER FIGURE
T.
y ERM NC, INC. JULY/NOVEMBER 2012 0
ENERGIZER BATTERY-419 ART BRYAN DRIVE
ERM ASHEBORO,NORTH CAROLINA

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1,4-DIOXANE IN SAPROLITE AQUIFER FIGURE
i et
ERM NC, INC. JULY/NOVEMBER 2012
ENERGIZER BATTERY-419 ART BRYAN DRIVE 11
ERM ASHEBORO,NORTH CAROLINA

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. k ,
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MW-14D <3.0 NM r f MW-13
MW-16D <3.0 NM , _ , r fy
MW-17D 30 NM ,
MW-18D 38.0 370li. -fi.
MW-21D <3.0 NM . } IdApt * ,, -
MW-26D 36 130di .1
MW-27D 44 <250 • .- - T
MW-28 71 <5 •. Seep#2 - ,.,,,.
MW-29D 5.1 <5 ' Seep#1 .
Seep#1 <3.0 <3.04/s r' P
.w
Seep#2 11.3 7.4 GRFENYALE RD
4... . •AlS ti .
-1'
N - Groundwater Seep Sample
4' Saprolite Monitor Well
H Quarry EI atlo ,• + I,�. L41 Bedrock Monitor Well
imam 0 Private Supply Water Well(Active)
-0
0 Private Supply Water Well(Inactive)
�, o •041 1,4 Dioxane Contour(ug/L)
i - Rock Intermittent Stream
- 4trARRY R❑
Stream
7\t\a
MWiT4D —Road
0 300 sno Feet .Li 0 111.
O Energizer Battery Property
g Parcel Boundary
i pg/L=Micrograms per Liter
1,4-DIOXANE IN BEDROCK AQUIFER FIGURE
ERM NC, INC. JULY/NOVEMBER 2012 12
ENERGIZER BATTERY-419 ART BRYAN DRIVE
ERM ASHEBORO,NORTH CAROLINA

Storage
Shed
•DPT-111
1
•OPT-1R Locker
Men
•D71•fi •DPT-13
•'• Boiler
Comp.
Room Room
3
•DPT-3i
•W-2e• I-
iltir
•OPL,6 Western •oPT-2e
Sump •OPTa7
/
/
L IL/ Unloading
Area a
(Curbed)
• I •DPT-a,
•Dpra9 —p- I Mix Room
(1 0 Large
•DPr-u Cell
I•DP.T-32. ®" I • .Solidified Molding
' ,_7 I 1 I'F Bad Anode
•OPT-40 1 I Storage
1•DPT-12 • c� •DPT-20
•OPT-33'
•OPT-27 •OPT•
;Proposed®' II 00 I r-
SVE
5
�"y�/�.\ Sp rose O•c 11
•OPT-15 11 24 30B21., A8c�- *DSO 0. -2 IT1 --Former
(Reposed)-Wr0P° 1 - •
,'� •OPT-�1"'— h • Degreaser
MW-250
i, System Area
MW-2en
Back
�'�. Dock
Proposed Fracturing Tank I •DpTafi Can
Pilot Test Area Farm •DPT-21 I Washing
•DPT-25
11. I1
-E-3 •DPT-
I • VE-19 VET
r MW-1A0P-22 �I
(2)F,ormer• MW-22•
Virgin TCE
ASTs }_
---------Former
Solvent Vapor
Recovery Area
I
•DPT-23
r
LEG=
• DPT Soil Boring Location(2011/2012) TCE Concentration !
Existing Wells 3 ug/L
• Saprolite Monitor Well 30 ug/L
o Bedrock Monitor Well 300 ug/L
Ix Private Supply Water Well(Active) 3000 ug/L
® Private Supply Water Well(Inactive) '30000 ug/L Small
Ore
o Abandoned Monitor Well Storage Cell
Proposed Pilot Test Wells Molding
L^rarehouse
• Pilot Test Vapor Extraction Well
O Pilot Test Air Sparge Well
'!l1 Observation Well
Proposed Full Scale AS/SVE Wells
• Vapor Extraction Well
U Air Sparge Wall 0 15 30 Feet
G Energizer Battery Property
SVE/AS WELL LAYOUT(Pilot Test&Full Scale) FIGURE
ERM NC,INC. ENERGIZER BATTERY 13
_ 419 ART BRYAN DRIVE
ASHEBORO,NORTH CAROLINA

COVER ASSEMBLY WITH
/ REMOVABLE STEEL COVER
•
GROUND SURFACE T • ,
•
1. l 1 1 1
CONCRETE "
LOCKABLE CAP -
GROUT
DEPTH TO TOTAL
6-INCH DIA. BOREHOLE BASE OF DEPTH OF
GROUT BOREHOLE
40 FT 50 FT.
2-INCH DIA. STAINLESS STEEL RISER
DEPTH TO
TOP OF
SAND
46 FT
TOTAL
• - YYY DEPTH
BENTONITE SEAL OF WELL
(6 FT.) 50 FT
SAND PACK(#3 Grade) .►
2-INCH DIA. STAINLESS STEEL SCREEN
rw-J - SCREENED
(0.01-INCH SLOTS) INTERVAL
48-50 FT.
T
BOTTOM CAP
AIR SPARGE WELL SCHEMATIC FIGURE
AS/SVE PILOT TEST WORK PLAN
• - - ERM NC, Inc. ENERGIZER BATTERY-419 ART BRYAN DRIVE 14
ERM ASHEBORO,NORTH CAROLINA

COVER ASSEMBLY WITH
■ REMOVABLE STEEL COVER
GROUND SURFACE
1 1 l !
CONCRETE r
LOCKABLE CAP
GROUT
DEPTH TO TOTAL
10-INCH DIA. BOREHOLE BASE OF DEPTH OF
GROUT BOREHOLE
2 FT. 20 FT.
4-INCH DIA. STAINLESS STEEL RISER
DEPTH TO
TOP OF
SAND
3 FT
TOTAL
DEPTH
BENTONITE SEAL OF WELL
(1 FT.) 20 FT.
SAND PACK(#1 Grade)
4-INCH DIA. STAINLESS STEEL SCREEN SCREENED
(0.005-INCH SLOTS) INTERVAL
4-20 FT
T
BOTTOM CAP ,
SOIL VAPOR EXTRACTION WELL SCHEMATIC FIGURE
ea'�" AS/SVE PILOT TEST WORK PLAN 15
ERM NC, Inc. ENERGIZER BATTERY-419 ART BRYAN DRIVE
ERM ASHEBORO,NORTH CAROLINA

COVER ASSEMBLY WITH
REMOVABLE STEEL COVER
•
GROUND SURFACE
1.' .�i
-.i . -
CONCRETE
LOCKABLE CAP
GROUT ■►
DEPTH TO TOTAL
6-INCH DIA. BOREHOLE r► BASE OF DEPTH OF
GROUT BOREHOLE
I 1 6 FT. 30 FT,
2-INCH DIA. SCH.40 PVC RISER ^ DEPTH TO
TOP OF
SAND
8 FT.
T
TOTAL
-- DEPTH
BENTONITE SEAL Qci°;— - ao_ OF WELL
(6-8 FT.) - 30 FT.
SAND PACK
2-INCH DIA. SCH.40 PVC SCREEN
H
SCREENED
(.01-INCH SLOTS) INTERVAL
10-30 FT.
BOTTOM CAP
L_— 1
OBSERVATION WELL SCHEMATIC FIGURE
AS/SVE PILOT TEST WORK PLAN Kai; 16
ERM NC, Inc. ENERGIZER BA I.1'ERY-419 ART BRYAN DRIVE
ERM ASHEBORO,NORTH CAROLINA

NCL ENR
North Carolina Department of Environment and Natural Resources
Pat McCrory John E. Skvarla, III
Governor Secretary
May 30,2014
Dan Carpenter
Energizer Battery Manufacturing,Inc.
419 Art Bryan Drive
Asheboro,NC 27203-3089
Ref: Issuance of Injection Permit WI0400345
Energizer Battery Manufacturing-Asheboro Plant II
Asheboro,Randolph County
Dear Mr.Carpenter:
In accordance with the application received on May 6,2014, and the supporting data received May
28, 2014, we are forwarding permit number WI0400345. This permit is to inject nitrogen gas to
initiate fractures for enhanced soil vapor extraction of volatile organic compounds at the facility
referenced above. This permit shall be effective from the date of issuance until May 30, 2019, and
shall be subject to the conditions and limitations stated therein. Please pay attention to the
requirements in PART VII - MONITORING AND REPORTING REQUIREMENTS. Please read
the entire permit to ensure that you are aware of all compliance requirements of the permit.
You will need to notify this office 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 919-807-6412 or [e-mail] if you have any questions about your
permit.
Best R ards,
Thomas Slusser,L.G.
Underground Injection Control Program Manager
cc: Sherri Knight,WQROS Winston-Salem Regional Office
Melanie Bartlett,DWM Superfund Section
Tom Wilson,ERM
WI0400345 Permit File
1636 Mail Service Center,Raleigh,North Carolina 27699-1636
F._ Phone:[phone] Internet:www.ncdenr.gov
An Equal Opportunity i Affirmative Action Employer—Made in part by recycled paper

Slusser, Thomas
From: Alan Martin [[e-mail]]
Sent: Wednesday, May 28, 2014 6:10 PM
To: Slusser, Thomas
Cc: Tom Wilson; Scott Boyle ([e-mail]); Jeff Gipson
([e-mail])
Subject: RE: Review of application for permit to construct wells for injection (WI0400345) at Energizer
Battery Facility in Asheboro, NC
Some files have been sent to you via the YouSendlt File Delivery Service.
Download the file - Revised Figure 13 SVE-AS Well Layout.pdf: Remedial Action Plan - Energizer
Asheboro 2013-10-18.pdf: RAP Approval.pdf; 2014-03 Energizer Plant II Pilot Test Work Planpdf
Your files will expire after 7 days.
Thomas
Per your discussion with Tom Wilson this afternoon, attached via download link are several documents for the Energizer
site, including:
2013-10 Remedial Action Plan (ERM);
2014-02 IHSB Approval of the RAP (NCDENR); and,
2014-03 Pilot Test Work Plan (ERM).
Let me know if you need paper copies of any of these documents.
As you requested, below is information regarding the groundwater testing to be conducted prior to and following the
injection/pneumatic fracturing activities. This sampling plan is based our understanding that an additional observation well
screened near the base of the fracture zone (50 ft bgs)will be required as a condition of the UIC permit. This additional
observation well has been designated as OB-3 on the attached figure.
Groundwater samples from existing monitoring wells MW-23, MW-25, MW-26D and observation well OB-1 plus proposed
observation well OB-3 will be collected to establish baseline conditions prior to the pneumatic fracturing activities. These
wells will also be sampled following the pneumatic fracturing activities and before the SVE/AS pilot test activities to
compare groundwater quality conditions. These groundwater samples will be collected via low-flow procedures and
analyzed for VOCs and 1,4-dioxane. Field parameters including pH, specific conductivity, dissolved oxygen and
oxidation-reduction potential will also be recorded during the groundwater sampling. Additional post-fracturing monitoring
will be conducted prior to initiation of the SVE/AS pilot test. The additional monitoring is described in Section 4 of the
attached Pilot Test Work Plan.
Let us know if you have questions. Thanks-
Regards,
Alan Martin,P.G.(NC,SC)
Senior Geologist, CSM Practice
ERM NC, Inc.
15720 Brixham Hill Avenue,Suite 120 I Charlotte, NC 28277 (Note road name change as of 6/1/2014)
Main+1 704-541-8345 I Direct+1704-409-3444 I Mobile[phone]
E [e-mail] I W www.erm.com
ERM
The world's leading sustainability consultancy
From: Slusser, Thomas [mailto:thomas.slusser©ncdenr.gov]
Sent: Monday, May 19, 2014 9:14 AM
1

Permit No. WI0400345
Date: 09/16/2019 County: Randolph
To: Shristi Shresta Permittee/Applicant: Energizer Manufacturing Inc.
Central Office Reviewer Facility Name: Energizer Manufacturing Inc.
L GENERAL INFORMATION
1. This application is(check all that apply): ❑New ® Renewal
❑Minor Modification❑Major Modification
a. Date of Inspection:
b. Person contacted and contact information:
c. Site visit conducted by:
d. Inspection Report Printed from BIMS attached: ❑Yes ❑No.
e. Physical Address of Site including zip code: 419 Art Bryan Drive Plant II Asheboro, NC 27203
f. Driving Directions if rural site and/or no physical address:
g. Latitude: Longitude:
Source of Lat/Long&accuracy(i.e., Google Earth, GPS,etc.):
IL DESCRIPTION OF INJECTION WELL(SI AND FACILITY
1. Type of injection system:
❑Geothermal Heating/Cooling Water Return RECE1VaiNCMOWR
®In situ Groundwater Remediation
❑Non-Discharge Groundwater Remediation SEP 1 62019
❑Other(Specify: ) Water
Regional0 Quali won
2. For Geothermal Water Return Well(s) only AetatiMs
a.For existing geothermal system only:
Were samples collected from Influent/Effluent sampling ports? ❑Yes ❑No.
Provide well construction information from well tag:
b.Does existing or proposed system use same well for water source and injection? ❑ Yes ❑No
If No,please provide source/supply well construction info(i.e.,depth,date drilled,well contractor,
etc.)and attached map and sketch location of supply well in relation to injection well and any other
features in Section IV of this Staff Report.
3. Are there any potential pollution sources that may affect injection? ❑Yes ❑No
What is/are the pollution source(s)?
What is the distance of the injection well(s)from the pollution source(s)_
4. What is the minimum distance of proposed injection wells from the property boundary?
5. Quality of drainage at site: ❑ Good ❑Adequate ❑Poor
6. Flooding potential of site: 0 Low ❑Moderate 0 High

7. For Groundwater Injection Remediation Systems only,is the proposed and/or existing groundwater monitoring
program(number of wells,frequency of monitoring,monitoring parameters,etc.)adequate? ®Yes ❑No.
If No,attach map of existing monitoring well network if applicable and recommend any changes to the
groundwater-monitoring program.
8. Does the map included in the Application reasonably represent the actual site(property lines,wells,surface
drainage)?®Yes El No. If No,or no map,please attach a sketch of the site. Show property boundaries,
buildings,wells,potential pollution sources,roads,approximate scale,and north arrow.
9. For Non-Discharge Groundwater Remediation systems only(i.e.,permits with WQ prefix):
a. Are the treatment facilities adequate for the type of waste and disposal system? ❑Yes El No ❑N/A.
If No,please explain:
b. Are the site conditions(soils,topography,depth to water table,etc.)consistent with what was reported by
the soil scientist and/or Professional Engineer? El Yes El No El N/A. If no,please explain:
IIl.EVALUATION AND RECOMMENDATIONS
1. Do you foresee any problems with issuance/renewal of this permit? El Yes ®No. If Yes,explain.
2. List any items that you would like WQROS Central Office to obtain through an additional information request.
Make sure that you provide a reason for each item:
Item Reason
3. 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
4. Recommendation
El Deny. If Deny,please state reasons:
❑Hold pending receipt and review of additional information by Regional Office
❑ Issue upon receipt of needed additional information
ElIssue DocuSigned by:
I ph.- aOVAil.k0Sk.1
5. Signature of Report Preparer(s): _
f]oeuSigned by:
Signature of WQROS Regional Supervisor: L°N ? Ss4cr
9/16/2019 145849E225C94EA...
Date:

IV.ADDITIONAL REGIONAL STAFF REVIEW COMMENTS/ATTACHMENTS(Optional/If Needed)

Docu .
� ttcukte
Certificate Of Completion
Envelope Id:150B01F981C444DB8A2E1797EBA80D6C Status:Completed
Subject:Please DocuSign:20190916 WI0400345 UIC Staff Report.docx.pdf
Source Envelope:
Document Pages:3 Signatures:1 Envelope Originator:
Certificate Pages:1 Initials:0 Jim Gonsiewski
AutoNav:Disabled 217 W.Jones Street
Envelopeld Stamping:Disabled Raleigh,NC 27699
Time Zone:(UTC-08:00)Pacific Time(US&Canada) [e-mail]
IP Address:149.168.204.10
Record Tracking
Status:Original Holder:Jim Gonsiewski Location:DocuSign
9/16/2019 1:17:10 PM [e-mail]
Signer Events Signature Timestamp
Jim Gonsiewski ((��DeauSi°nod b Sent:9/16/2019 1:17:27 PM
[e-mail] i""` a01tr."`x" Viewed:9/16/2019 1:17:33 PM
North Carolina Department of Environmental Quality E1B7BBBF18D' "' Signed:9/16/2019 1:18:17 PM
Security Level:Email,Account Authentication Freeform Signing
(None) Signature Adoption:Pre-selected Style
Using IP Address:149.168.204.10
Electronic Record and Signature Disclosure:
Not Offered via DocuSign
In Person Signer Events Signature Timestamp
Editor Delivery Events Status Timestamp
Agent Delivery Events Status Timestamp
Intermediary Delivery Events Status Timestamp
Certified Delivery Events Status Timestamp
Carbon Copy Events Status Timestamp
Witness Events Signature Timestamp
Notary Events Signature Timestamp
Envelope Summary Events Status Timestamps
Envelope Sent Hashed/Encrypted 9/16/2019 1:17:27 PM
Certified Delivered Security Checked 9/16/2019 1:17:34 PM
Signing Complete Security Checked 9/16/2019 1:18:17 PM
Completed Security Checked 9/16/2019 1:18:17 PM
Payment Events Status Timestamps

WATER QUALITY REGIONAL OPERATIONS SECTION
APPLICATION REVIEW REQUEST FORM Environments Quality _..
Received 1
Date: July 17,2019 JUL 19 2019
Lon Schneider Winston-Salem
Salem
Re-Bonal Office
Shristi Shrestha,WQROS-Animal Feeding Operations and Groundwater'Protection ranch _
Telephone: [phone] Fax: [phone] E-Mail: [e-mail]
Permit Number: WI0400345
A. Applicant: Energizer Manufacturing Inc.
it`k!iik1F1
B. Facility Name: Energizer Manufacturing Inc. Rfitt '6
C. Application: ,4.l111i9
Permit Type: In-situ Groundwater Remediation Well011�� �8n
gq6
Project Type:Renewal
E. Comments/Other Information:
I would like to accompany you on a site visit.
Attached, you will fmd all information submitted in support of the above-referenced application for your
review, comment, and/or action. Within 30 calendar days, please return a completed WOROS Staff
Report.
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 Groundwater Protection Branch contact person
listed above.RO-WOROS Reviewer: '1"R 6 nnsi j k Date: 1 1 {q
(
COMMENTS:
NOTES:
FORM:WQROS-ARR ver.092614 Page 1 of 1

WATER QUALITY REGIONAL OPERATIONS SECTION
APPLICATION REVIEW REQUEST FORM
Date: July 17,2019
To: Lon Schneider
From: Shristi Shrestha,WQROS—Animal Feeding Operations and Groundwater Protection Branch
Telephone: [phone] Fax: [phone] E-Mail: [e-mail]
Permit Number: WI0400345
A. Applicant: Energizer Manufacturing Inc.
B. Facility Name: Energizer Manufacturing Inc.
C. Application:
Permit Type: In-situ Groundwater Remediation Well
Project Type:Renewal
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 return a completed WOROS Staff
Report.
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 Groundwater Protection Branch contact person
listed above.
RO-WQROS Reviewer: Date:
COMMENTS:
NOTES:
FORM:WQROS-ARR ver.092614 Page 1 of 1

a
r ,i _ >';.�a.
ROY COOPER �,'�Y
,--c,-/)
Governor i- 'ir-
sr" i
MICHAEL S.REGAN >
•
Secretary e
LINDA CULPEPPER NORTH CAROLINA
Director Environmental Quality
July 17, 2019
Steve Hall
Energizer Manufacturing Inc.
419 Bryant Drive
Asheboro,NC 27203-3089
RE: Acknowledgement of Application No. WI0400345
Energizer Manufacturing Inc. Facility
In Situ Groundwater Remediation Well System
Randolph County
Dear Mr. Hall:
The Water Quality Regional Operations Section (WQROS) acknowledges receipt
of your permit application on July 17, 2019. Your application package has been assigned
the number listed above, and the primary reviewer is Shristi Shrestha
Central and Winston-Salem 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 Water Quality
Regional Operations Section(WQROS)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 Shristi Shrestha at 919-707-3662 or [e-mail].
Sincerely,
For Debra J. Watts, Supervisor
Animal Feeding Operations &
Groundwater
Protection Branch
Division of Water Resources
_,_-
D E_ North Carolina Department of Environmental Quality I Division of Water Resources
512 North Salisbury Street 1 1636 Mail Service Center I Raleigh North Carolina 27699-1636
"+��7 . 919.707.9000

cc: Winston-Salem Regional Office,WQROS
Permit File WI0400345
Alan Martin, ERM Inc., 15720 John J Delaney Dr., Suite 120, Charlotte,NC 28277

Slusser, Thomas
From: Wang, Shuying
Sent: Tuesday, May 27, 2014 2:10 PM
To: Slusser, Thomas
Cc: Knight, Sherri
Subject: RE: WI0400345 Regional Staff Report
Sorry! No additional information is needed, but conditions mentioned in the report should be added or specified in the
permit as you agree.The box Issue should be marked.You may print this email and attach to the form to reflect the
mistake.
I apologize for the mistake,and thank you for catching it.
Shuying
http://portal.ncdenr.org/web/wq/aps/gwp/rep
****************
E-mail correspondence to and from this address may be subject to
the North Carolina Public Records Law and may be disclosed to third parties.
****************
From: Slusser,Thomas
Sent: Tuesday, May 27, 2014 2:02 PM
To: Wang, Shuying
Cc: Knight, Sherri
Subject: RE: WI0400345 Regional Staff Report
Thanks, Shuying. The box checked above your signature indicates additional information is
needed prior to issuing the permit. Can you please let me know if this is an error or if I
need to ask there for something?
Thanks!
-Thomas.
ph# 919-807-6412 I fax#[phone]
Mailing Address: 1636 Mail Service Center,Raleigh, NC 27699-1636
Physical Address: Room 640M,Archdale Building,512 N.Salisbury St.,Raleigh,NC 27604.
Internet Address: http:/lportal.ncdenr.org/web/wq/aps/gwpro
Email correspondence to and from this address may be subject to the Worth Carolina Public Records Law and may be disclosed to third parties unless the content is
exempt by statute or other regulation.
Original Message
From: Wang, Shuying
Sent: Friday, May 23, 2014 12:27 PM
To: Slusser, Thomas
Cc: Knight, Sherri
Subject: WI0400345 Regional Staff Report
Hi Thomas,
As the permittee plans to conduct pilot test on June 2, 2014, to speed up our review, the
Regional Staff Report for WI0400345, Energizer Battery Manufacturing Inc. is attached. The
hard copy is also on the way by courier mail.
If you have any questions, please let me know.
i

Slusser, Thomas
From: Wang, Shuying
Sent: Tuesday, May 27, 2014 2:10 PM
To: Slusser, Thomas
Cc: Knight, Sherri
Subject: RE: WI0400345 Regional Staff Report
Sorry! No additional information is needed, but conditions mentioned in the report should be added or specified in the
permit as you agree.The box Issue should be marked.You may print this email and attach to the form to reflect the
mistake.
I apologize for the mistake, and thank you for catching it.
Shuying
http://portal.ncdenr.org/web/wci/aps/gwp/rep
****************
E-mail correspondence to and from this address may be subject to
the North Carolina Public Records Law and may be disclosed to third parties.
****************
From: Slusser,Thomas
Sent: Tuesday, May 27, 2014 2:02 PM
To: Wang, Shuying
Cc: Knight, Sherri
Subject: RE: WI0400345 Regional Staff Report
Thanks, Shuying. The box checked above your signature indicates additional information is
needed prior to issuing the permit. Can you please let me know if this is an error or if I
need to ask them for something?
Thanks!
-Thomas.
ph# 919-807-6412 I fax#[phone]
Mailing Address: 1636 Mail Service Center,Raleigh, NC 27699-1636
Physical Address: Room 640M,Archdale Building,512 N.Salisbury St.,Raleigh,NC 27604.
Internet Address: http://portal.ncdenr.org/web/wq/aps/gwpro
E--mail correspondence to and from this address may be subject to the North Carolina Public records Law and may be disclosed to third parties unless the content is
exempt by statute or other regulation.
Original Message
From: Wang, Shuying
Sent: Friday, May 23, 2014 12:27 PM
To: Slusser, Thomas
Cc: Knight, Sherri
Subject: WI0400345 Regional Staff Report
Hi Thomas,
As the permittee plans to conduct pilot test on June 2, 2014, to speed up our review, the
Regional Staff Report for WI0400345, Energizer Battery Manufacturing Inc. is attached. The
hard copy is also on the way by courier mail.
If you have any questions, please let me know.
1

Thank you!
Shuying
http://portal.ncdenr.org/web/wq/aps/gwp/rep
****************
E-mail correspondence to and from this address may be subject to the North Carolina Public
Records Law and may be disclosed to third parties.
****************
2

AQUIFER PROTECTION SECTION--GROUNDWATER PROTECTION UNIT
REGIONAL STAFF REPORT
Date: 05/23/2014 Permittee(s): Energizer Battet-v Manufacturing,Inc.
Permit No.: WI0400345
To: Groundwater Protection Unit County: Randolph
Central Office Reviewer: Thomas Slusser Project Name: Energizer Battery Manufacturing, Inc.
Regional Login No:
I. GENERAL INFORMATION
1. This application is(check all that apply): ❑ SFR Waste Irrigation System ❑UIC Well(s)
®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 y 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: May 22,.2014
b. Person contacted and contact information:Alan Martin,ERM NC Inc.,704-409-3444,.
[e-mail]
•
c. Site visit conducted by: Shuying Wang
d. Inspection Report Attached:❑Yes or®No.
2. Is the following information entered into the RIMS 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 SFR Treatment Facilities:
a. Location:
b. Driving Directions:
c. USGS Quadrangle Map name and number:
d. Latitude: Longitude: Method Used(GPS,GoogleTM,etc.);
e. Regulated Activities/Type of Wastes(e.g.,subdivision,food processing,municipal wastewater):
For UIC Injection Sites:
(If multiple sites either indicate which sites the information applies to, copy and paste 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: Randleman 35079-G7-TF-024
d. Latitude:, Longitude: Method Used(GPS,GoogleTM,etc.):Trimble Geo XII
APS-GPU Regional Staff Report(Sept 09) Page 1 of 6 Pages

AQUIFER PROTECTION SECTION-GROUNDWATER PROTECTION UNIT
REGIONAL STAFF REPORT
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.)
Description of Well(s)and Facilities—New,Renewal,and Modification
1. Type of injection system:
El Heating/cooling water return flow(5A7)
El Closed-loop heat pump system(5QMJ5QW)
In situ remediation(51)
❑Closed-Ioop 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)?No It fuel,TCE, sodium hydroxide.potassium hydroxide. and waste water.
What is the distance of the injection well(s)from the pollution source(s)? Within the plume area.
4. What is the minimum distance of proposed injection wells from the property boundary? 50 ft.
5. Quality of drainage at site: ❑ Good ®Adequate ❑Poor
6. Flooding potential of site: ®Low ®Moderate ❑High •
**Moderate in the proposed pilot test well area.
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: In addition to monitoring wells MW-23,MW-24,and MW-25 as
proposed in the application, MW-26D should be also monitored during the fracturing. Because the
proposed fracturing zone reaches to the interface of regolith and bedrock, and vertical fractures may
be naturally present in bedrock as bedrock aquifer has been contaminated, WSRO also suggests that
MW-26D be sampled for key water quality parameters, such as 1, I-DCE, TCE, or total of VOCs
before and after the pneumatic fracturing.
8. Does the map presented represent the actual site(property lines,wells,surface drainage)?Ej 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.
Injection 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:
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AQUIFER PROTECTION SECTION-GROUNDWATER PROTECTION UNIT
REGIONAL STAFF REPORT
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:
3. For renewal or modification of groundwater remediation permits(of any type),will
continued/additional/modified injections have an adverse impact on migration of the plume or management of
the contamination incident?❑Yes ❑No. If yes.explain:
4. Drilling Contractor: Name:
Address:
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NC Certification number:
5. Complete and attach NEW InJection FacilityInspection Report,
rt,if applicable
V. EVAL UATIONAND RECOMMENDATIONS
1: Provide any additional narrative regarding your review of the Application:Based on the data collected from a
small area where the release was first found and pneumatic fracturing was performed for SVE/AS wells were in
2001, the proposed pneumatic fracturing technique is needed to increase effective radius of a SVE/AS system
effectively. However.please note that in this small area,the pneumatic fracturing was only performed at a
depth down to 27 feet:but 50 feet,down to the interface of regolith and bedrock is proposed in this application.
Plus,bedrock aquifer has already contaminated,indicating preference channel(s)are present.Therefore,WSRO
suggests a complete pilot test report documenting pneumatic fracturing_procedures and including all monitoring
data be submitted to Groundwater Protection Unit for review before conducting the proposed full scale
pneumatic fracturing.
2. Attach.new Injection Facility Inspection Form,if applicable
3. Do you foresee any problems with issuance/renewal of this permit?®Yes ❑No. If yes,please explain
briefly. The pneumatic fracturing may push the plume down further in bedrock.
4. List any items that you would like APS Central Office to obtain through an additional information request.
Make sure that you provide a reason for each item:
Item I Reason I
- I
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:
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AQUIFER PROTECTION SECTION- GROUNDWATER PROTECTION UNIT
REGIONAL STAFF REPORT
Condition Reason - -
1
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
MW-26D should be sampled before and after See Section VI,Item 7.
the pneumatic fracturing for lab analysis for key
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water quality parameters.
A complete pilot test report documenting See Section V,Item 1.
pneumatic fracturing procedures and including
all monitoring data should be submitted to
Groundwater Protection Unit for review before
conducting the proposed full scale pneumatic
fracturing.
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): 2
Signature ofAPS regional supervisor:
Date: IJI''.93// T •
VL ADDITIONAL INFORMATION AND SITE MAP(Sketch of site showing house and waste irrigation
system,spray or drip field location of well(s), and/or other relevant information-SHOW NORTH ARROW)
APS-GPU Regional Staff Report(Sept 09) Page 6 of 6 Pages