WI0300102_Regional Office Historical File Pre 2018

W A7'F9 Michael F. Easley, Governor
O pG William G. Ross Jr., Secretary
y North Carolina Department of Environment and Natural Resources
> r
—I Alan W. Klimek, P.E., Director
'< Division of Water Quality
July 11, 2005
Mr. Steve Olp
Celanese International Corp./Global Remediation
2848 Cherry Road - Suite 100
Rock Hill, SC 29730
JUL 13 2005
6115
Subject: Permit No. WI0300102 Correction
Dreyfus Research Park
2300 Archdale Drive, Charlotte, NC
Mecklenburg County
Dear Mr. Olp:
In accordance with an e-mail request received on July 6, 2005 from Mr. Jim Cloonan of ARCADIS, we are
forwarding herewith the corrected page 4. of Permit No. W10300102, issued April 1, 2005, for the subject
facility.
The following corrections have been made to the permit:
1. Part VII — Monitoring and Reporting Requirements, paragraph 1, requirements for sampling alkalinity
and redox parameters at OMW-5, OMW-6, and OMW-7 have been removed. Additionally, requirement for
sampling MW-12 has been removed.
Please replace Page 4 with the corrected Page 4 into Permit No. WI0300102, issued April 1, 2005.
If you have any questions regarding this request, please contact me at [phone]. Thank you for your
cooperation.
Sincerely,
J. Michael Ranck, P.G., Hydrogeologist
Groundwater Protection Unit
cc: Andrew Pitner, Mooresville Regional Office
Jim Cloonan, ARCADIS
UIC-CO File
Aquifer Protection Section
Internet: http://h2o.enr.state.nc.us
1636 Mail Service Center Raleigh, NC 27699-1636 Phone [phone] Customer Service
2728 Capital Boulevard Raleigh, NC 27604 Fax [phone]
Fax [phone]
NorthCarolina
Naturally
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PART VI - INSPECTIONS
1. Any duly authorized officer, employee, or representative of the Division of Water Quality
may, upon presentation of credentials, enter and inspect any property, premises, or place on
or related to the injection facility at any reasonable time for the purpose of determining
compliance with this permit, may inspect or copy any records that must be maintained under
the terms and conditions of this permit, and may obtain samples of groundwater, surface
water, or injection fluids.
2. Department representatives shall have reasonable access for purposes of inspection,
observation, and sampling associated with injection and any related facilities as provided for
in N.C.G.S. 87-90.
3. Provisions shall be made for collecting any necessary and appropriate samples associated
with the injection facility activities.
PART VII - MONITORING AND REPORTING REQUIREMENTS
1. The proposed monitoring plan included in the application shall be followed. In addition to
the analysis plan in the application, OMW-5, OMW-6, and OMW-7 shall be analyzed for
total organic carbon at all scheduled sampling events. Additionally, all wells in the sampling
plan shall be analyzed for oxygen -reduction potential, dissolved oxygen, pH, specific
conductance, and temperature at all scheduled sampling events. All sample results shall be
submitted to the Aquifer Protection Section's Mooresville Regional Office and the Raleigh
Central Office. Any monitoring (including groundwater, surface water, or soil sampling)
deemed necessary by the Division of Water Quality to insure surface and ground water
protection, will be established and an acceptable sampling reporting schedule shall be
followed.
2.
The Permittee shall produce a final project evaluation within 9 months after completing all
injection -related activity associated with the permit application. This document shall assess.
the injection projects findings in a written summary. The final project evaluation shall also
contain monitoring well sampling data, contaminant plume maps and potentiometric surface
maps.
3. The monitoring results and the final project evaluation shall be submitted to:
and to:
Aquifer Protection Section-UIC Staff
DENR-Division of Water Quality
1636 Mail Service Center
Raleigh, NC 27699-1636
Aquifer Protection Section
DENR-DWQ Mooresville Regional Office
610 East Center Avenue / Suite 301
Mooresville, NC 28115
Permit No. WI0300102 PAGE 4 OF 6
ver.7/04 AP/UIC-6

DIVISION OF WATER QUALITY
AQUIFER PROTECTION SECTION
April 4, 2005
MEMORANDUM
L TO: _ _AndrewPtne, Aquifer -Protection -Supervisor _l
Mooresville Regional Office
From: Mike Ranck AV
Central Office
Re:
NO DRPI: y o UR 2S
HMPIT
MO cr RECEIVED
APR 7 2005
MOOR SVILLE REGIONAL GROUNDWATER SECTFFICE
ION
Issuance of injection well permit type 5I (in -situ groundwater remediation well)
Permit Number WI0300102
Celanese International Corp.
Peinut Number WI0300102 is for the injection of In -situ Reactive ZoneTM to enhance reductive
dechlorination at this site. These injection wells will be located at the Dreyfus Research Park,
2300 Archdale Drive, Charlotte, North Carolina, Mecklenburg County. Please retain the
application paper work and permit copy for the MRO-UIC files. The UIC group
appreciates the MRO's inspection and review tasks concerning this permit application. If
you have any questions regarding this permit or the UIC program, please contact me at (919)
715-6164 or Evan Kane at [phone].
cc: CO-UIC Files
Enclosures

Michael F. Easley, Governor
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
Alan W. Klimek, P.E. Director
Division of Water Quality
April 4, 2005
Mr. Steve Olp
Celanese International Corp./Global Remediation
2848 Cherry Road — Suite 100
Rock Hill, SC 29730
Dear Mr. Olp:
In accordance with your application received on January 25, 2005, we are forwarding Permit No.
WI0300102 for the operation of Type 5I injection wells at the Dreyfus Research Park, 2300
Archdale Drive, Charlotte, North Carolina.
This permit shall be effective from the date of issuance until April 1, 2009, and shall be subject
to the conditions and limitations stated therein, including the requirement to submit a final
project evaluation as stated in PART VII—MONITORING AND REPORTING
REQUIREMENTS. Please note that the permit requires additional sampling and analysis
beyond what is proposed in the original application. These additions are listed in Part VII-1 of
the permit. You will also need to notify this office by telephone 48 hours prior to initiation of
injection at this facility. In order to continue uninterrupted legal use of this injectant for the
stated purpose, you should submit an application to renew the permit three months prior to its
expiration date. Note that you should contact the Mecklenburg County Health Department to
determine what local restrictions may apply.
If you have any questions regarding your permit please contact me at [phone] or Evan
Kane at [phone].
Sincerely,
44,41t/ 4414
J. Michael Ranck
Hydrogeologist
Groundwater Protection Unit
cc: Andrew Pitner, MRO
Elizabeth Rhine, ARCADIS (fax copy)
CO-UIC file
Enclosures
NOOLCarolina
Naturally
Aquifer Protection Section 1636 Mail Service Center Raleigh, NC 27699-1636 Phone [phone] Customer Service
Internet: http://h2o.enr.state.nc.us 2728 Capital Boulevard Raleigh, NC 27604 Fax [phone]
Fax [phone]
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NORTH CAROLINA
ENVIRONMENTAL MANAGEMENT COMMISSION
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
RALEIGH, NORTH CAROLINA
PERMIT FOR THE CONSTRUCTION AND OPERATION OF WELLS FOR INJECTION
In accordance with the provisions of Article 7, Chapter 87; Article 21, Chapter 143, and
other applicable Laws, Rules, and Regulations
PERMISSION IS HEREBY GRANTED TO
Celanese International Corp.
FOR THE CONSTRUCTION AND OPERATION OF TYPE 5I INJECTION WELLS, defined
in Title 15A North Carolina Administrative Code 2C .0209(e)(3)(C), to inject In -situ Reactive
ZoneTM, to enhance reductive dechlorination of dissolved chlorinated solvent contamination.
These injection wells/points will be located at the Dreyfus Research Park, 2300 Archdale Drive,
Charlotte, North Carolina, and will be operated in accordance with the application submitted
January 25, 2005, and in conformity with the specifications and supporting data submitted March
8, 2005, all of which are filed with the Department of Environment and Natural Resources and
are considered a part of this peiniit.
This permit is for Construction and Operation only, and does not waive any provisions of the
Water Use Act or any other applicable Laws, Rules, or Regulations. Operation and use of an
injection well shall be in compliance with Title 15A North Carolina Administrative Code 2C
.0100 and .0200, and any other Laws, Rules, and Regulations pertaining to well construction and
use.
This permit shall be effective, unless revoked, from the date of its issuance until April 1, 2009,
and shall be subject to the specified conditions and limitations set forth in Parts I through X
hereof.
Permit issued this the 1' day of
,fro Jvitls
Alan W. Klimek, P.E., Director
Division of Water Quality
By Authority of the Environmental Management Commission.
, 2005.
Permit No. WI0300102 PAGE 1 OF 6
ver.7/04 AP/UIC-6

PART I - WELL CONSTRUCTION GENERAL CONDITIONS
1. The Permittee must comply with all conditions of this permit and with the standards• and
criteria specified in Criteria and Standards Applicable to Injection Wells (15A NCAC 2C
.0200). Any noncompliance with conditions of this permit constitutes a violation of the
North Carolina Well Construction Act and is grounds for enforcement action as provided for
in N.C.G.S. 87-94.
2. This permit shall become voidable unless the facility is constructed in accordance with the
conditions of this permit, the approved plans and specifications, and other supporting data.
3. This permit is valid only for construction of the number of injection wells described in the
application and other supporting data. Construction of additional injection wells must be
approved in advance by the Aquifer Protection Section.
4. Each injection well shall not hydraulically connect separate aquifers.
5. Each injection well shall be constructed in such a manner that water from land surface cannot
migrate into the gravel pack or well screen.
6. Each injection well shall be secured to reasonably insure against unauthorized access and use.
Each well shall be permanently labeled with a warning that it is for injection purposes and the
entrance to each well must be secured with a locking cap.
7. Each injection well shall be afforded reasonable protection against damage during
construction and use.
8. Each injection well shall have permanently affixed an identification plate.
9. Within 30 days of completion of well construction, a completed Well Construction Record
(Form GW-1) must be submitted for each injection well to:
Aquifer Protection Section-UIC Staff
DENR-Division of Water Quality
1636 Mail Service Center
Raleigh, NC 27699-1636
PART II - WELL CONSTRUCTION SPECIAL CONDITIONS
1. At least forty-eight (48) hours prior to constructing each injection well, the Permittee shall
notify the Aquifer Protection Section -Underground Injection Control (UIC) Central Office
staff, telephone number [phone] and the Mooresville Regional Office Aquifer
Protection Section Staff, telephone number [phone].
Permit No. WI0300102 PAGE 2 OF 6
ver.7/04 AP/UIC-6

PART III - OPERATION AND USE GENERAL CONDITIONS
1. This permit is effective only with respect to the nature, volume of materials, rate of injection,
and number of injection wells as described in the application and other supporting data.
2. This permit is not transferable without prior notice to, and approval by, the Director of the
Division of Water Quality (Director). In the event there is a desire for the facility to change
ownership, or there is a name change of the Permittee, a formal permit amendment request
must be submitted to the Director, including any supporting materials as may be appropriate,
at least 30 days prior to the date of the change.
3. The issuance of this permit shall not relieve the Permittee of the responsibility of complying
with any and all statutes, rules, regulations, or ordinances which may be imposed by other
local, state, and federal agencies which have jurisdiction. Furthermore, the issuance of this
permit does not imply that all regulatory requirements have been met.
PART IV - PERFORMANCE STANDARDS
1. The injection facility shall be effectively maintained and operated at all times so that there is
no contamination of groundwater which will render it unsatisfactory for normal use. In the
event that the facility fails to perform satisfactorily, including the creation of nuisance
conditions or failure of the injection zone to adequately assimilate the injected fluid, the
Permittee shall take immediate corrective actions including those actions that may be
required by the Division of Water Quality such as the repair, modification, or abandonment
of the injection facility.
2. The Permittee shall be required to comply with the terms and conditions of this permit even if
compliance requires a reduction or elimination of the permitted activity.
3. The issuance of this permit shall not relieve the Permittee of the responsibility for damages to
surface or groundwater resulting from the operation of this facility.
PART V - OPERATION AND MAINTENANCE REQUIREMENTS
1. The injection facility shall be properly maintained and operated at all times.
2. The Permittee must notify the Division and receive prior written approval from the Director
of any planned physical alterations or additions in the permitted facility or activity not
specifically authorized by the permit.
3. At least forty-eight (48) hours prior to the initiation of the operation of the facility for
injection, the Permittee must notify by telephone the Aquifer Protection Section-UIC, Central
Office staff, telephone number [phone]. Notification is required so that Division staff
can inspect or otherwise review the injection facility and determine if it is in compliance with
permit conditions.
Permit No. WI0300102 PAGE 3 OF 6
ver.7/04 AP/UIC-6

r'
PART VI - INSPECTIONS
1. Any duly authorized officer, employee, or representative of the Division of Water Quality
may, upon presentation of credentials, enter and inspect any property, premises, or place on
or related to the injection facility at any reasonable time for the purpose of determining
compliance with this permit, may inspect or copy any records that must be maintained under
the terms and conditions of this permit, and may obtain samples of groundwater, surface
water, or injection fluids.
2. Department representatives shall have reasonable access for purposes of inspection,
observation, and sampling associated with injection and any related facilities as provided for
in N.C.G.S. 87-90.
3. Provisions shall be made for collecting any necessary and appropriate samples associated
with the injection facility activities.
PART VII - MONITORING AND REPORTING REQUIREMENTS
1. The proposed monitoring plan included in the application shall be followed. In addition to
the analysis plan in the application, OMW-5, OMW-6, OMW-7, and MW-12 shall be
analyzed for redox parameters, alkalinity, and total organic carbon at all scheduled sampling
events. Additionally, all wells in the sampling plan shall be analyzed for oxygen -reduction
potential, dissolved oxygen, pH, specific conductance, and temperature at all scheduled
sampling events. All sample results shall be submitted to the Aquifer Protection Section's
Mooresville Regional Office and the Raleigh Central Office. Any monitoring (including
groundwater, surface water, or soil sampling) deemed necessary by the Division of Water
Quality to insure surface and ground water protection, will be established and an acceptable
sampling reporting schedule shall be followed.
2. The Permittee shall produce a final project evaluation within 9 months after completing all
injection -related activity associated with the permit application. This document shall assess
the injection projects findings in a written summary. The final project evaluation shall also
contain monitoring well sampling data, contaminant plume maps and potentiometric surface
maps.
3. The monitoring results and the final project evaluation shall be submitted to:
and to:
Aquifer Protection Section-UIC Staff
DENR-Division of Water Quality
1636 Mail Service Center
Raleigh, NC 27699-1636
Aquifer Protection Section
DENR-DWQ Mooresville Regional Office
610 East Center Avenue / Suite 301
Mooresville, NC 28115
Permit No. WI0300102 PAGE 4 OF 6
ver.7/04 AP/UIC-6

4. The Permittee shall report by telephone, within 48 hours of the occurrence or first knowledge
of the occurrence, to the Mooresville Regional Office, telephone number [phone], any
of the following:
(A) Any occurrence at the injection facility which results in any unusual operating
circumstances;
(B) Any failure due to known or unknown reasons, that renders the facility incapable of
proper injection operations, such as mechanical or electrical failures.
5. Where the Permittee becomes aware of an omission of any relevant facts in a permit
application, or of any incorrect information submitted in said application or in any report to
the Director, the relevant and correct facts or information shall be promptly submitted to the
Director by the Permittee.
6. In the event that the permitted facility fails to perform satisfactorily, the Permittee shall take
such immediate action as may be required by the Director.
PART VIII - PERMIT RENEWAL
The Permittee shall, at least 120 days prior to the expiration of this permit, request an
extension.
PART IX - CHANGE OF WELL STATUS
1. The Permittee shall provide written notification within 15 days of any change of status of an
injection well. Such a change would include the discontinued use of a well for injection. If a
well is taken completely out of service temporarily, the Permittee must install a sanitary seal.
If a well is not to be used for any purpose that well must be permanently abandoned
according to 15A NCAC 2C .0113, Well Construction Standards.
2. When operations have ceased at the facility and a well will no longer be used for any
purpose, the Permittee shall abandon that injection well in accordance with the procedures
specified in 15A NCAC 2C .0113(b), including but not limited to the following:
(A)All casing and screen materials may be removed prior to initiation of abandonment
procedures if such removal will not cause or contribute to contamination of the
groundwaters.
(B) The entire depth of each well shall be sounded before it is sealed to insure freedom
from obstructions that may interfere with sealing operations.
(C) The well shall be thoroughly disinfected, prior to sealing, if the Director determines
that failure to do so could lead to the contamination of an underground source of
Permit No. WI0300102 PAGE 5 OF 6
ver.7/04 AP/UIC-6

drinking water.
(D) Drilled wells shall be completely filled with cement grout, or bentonite grout which
shall be introduced into the well through a pipe which extends to the bottom of the
well and is raised as the well is filled.
(E) In the case of gravel -packed wells in which the casing and screens have not been
removed, neat -cement, or bentonite grout shall be injected into the well completely
filling it from the bottom of the casing to the top.
(F) In those cases when, as a result of the injection operations, a subsurface cavity has
been created, each well shall be abandoned in such a manner that will prevent the
movement of fluids into or between underground sources of drinking water and in
accordance with the terms and conditions of the permit.
(G) The Permittee shall submit a Well Abandonment Record (Form GW-30) as specified
in 15A NCAC 2C .0213(h)(1) within 30 days of completion of abandonment.
3. The written documentation required in Part IX (1) and (2) (G) shall be submitted to:
Aquifer Protection Section-UIC Staff
DENR-Division of Water Quality
1636 Mail Service Center
Raleigh, NC 27699-1636
PART X — WORKER PRECAUTIONS DURING APPLICATION
1. Persons working in the application area should wear goggles or a face shield, gloves, and
protective clothing.
2. Eating, drinking, smoking, handling contact lenses, and applying cosmetics should not be
permitted in the application area.
3. In order to minimize exposure to unprotected individuals, measures should be taken to
prevent access to the area of application to workers applying the product.
Permit No. WI0300102 PAGE 6 OF 6
ver.7/04 AP/UIC-6

AQUIFER PROTECTION SECTION REGIONAL STAFF REPORT
Date: z ; 6 —o4``
To: Aquifer Protection Section Central Office
Central Office Reviewer: /Vl ir';r, A,,,/
Regional Login No:
I. GENERAL INFORMATION
1. This application is (check all that apply): New ❑ Renewal
❑ Minor Modification ❑ Major Modification
Application No.: W 00
,�
County: /% C'l(,
Permittee: CelaSi74/�
Project Name:
❑ Surface Irrigation ❑ Reuse ❑ Recycle ❑ High Rate Infiltration ❑ Evaporation/Infiltration Lagoon
❑ Land Application of Residuals ❑ Attachment B included ❑ 503 regulated ❑ 503 exempt
❑ Distribution of Residuals ❑ Surface Disposal
❑ Closed -loop Groundwater Remediation [Other Injection Wells (including in situ remediation)
Was a site visit conducted in order to prepare this report? [Yes or ❑ No.
a. Date of site visit:
b.
c. Site visit conducted by:
d.
Person contacted and contact information: -d%c'J
Inspection Report Attached: [Yes or ❑ No.
zJr v2p
2. Is the following information entered into the BIMS record for this application correct?
❑ Yes or ❑ Ala: If no, please complete the following or indicate that it is correct on the current application.
For Treatment Facilities:,jj
a. Location: 2 30D : �-vcAc}Je Pr,
b. Driving Directions: See- a qck-c1
7 c. USGS Quadrangle Map name and number: c to rt z-
P V d. Latitude:.3S, /4-2 I6' Longitude: "'eo, ; 32S ?
e. Regulated Activities / Type of Wastes (e.g., subdivision, food processing, municipal wastewater): 1/-/S
For Disposal and Injection Sites: 7h -: 7;; c. 5,-5«
(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 Directi
Al i ,y
/litki.erO t I oc.c.{7;''"1,.� �jt���ll�ri ile, 5ame.
c. USGS Qu.drangle Map name and number:
d. Lati .. e: Longitude:
II. NEW AND MAJOR MODIFICATION APPLICATIONS (this section not needed for renewals or minor
modifications, skip to next section)
Description Of Waste(S) And Facilities
1.
p I1
Please attach completed rating sheet:' Facility Classification: r / kid ztj4', 3-1/4
2. Are the new treatment facilities adequate for the type of waste and disposal system?
/V/X n �rffl 71,; -
FORM: All Permit Reviews Form 1
/ ,f,-1;jfir/

AQUIFER PROTECTION SECTION REGIONAL STAFF REPORT
❑ Yes ❑ No III N/A. If no, please explain:
3. Are the new site conditions (soils, topography, dep to water table, etc) consistent with what was reported by
the soil scientist and/or Professional Engineer? Yes ❑ No ❑ N/A. If no, please explain:
4. Does the application (maps, plans, etc.) represent the actual site (property lines, wells, surface drainage)? ❑
Yes L4 No ❑ N/A. If no, please explain:
5. Is the proposed residuals management plan adequate and/or acceptable to the Division. ❑ Yes ❑ No 12
N/A. If no, please explain: LI —S,' G,, (� ? ,1 r ., ,x T
6. Are the proposed ap lication rates for new sites (hydraulicwor nutrient) acceptable?
El Yes ❑ No N/A. If no, please explain: / v
i -
7. Are the new ,`eatment facilities or any new disposal sites located in a 100-year floodplain?
❑ Yes No ❑ N/A. If yes, please attach a map showing areas of 100-year flood lain andplease explain
P P
and recommend any mitigative measures/special conditions in Part IV:
8. Are there any buffer conflicts (new treatment facilities or new disposal sites)? ❑ Yes or [ io. If yes, please
attach a map showing conflict areas or attach any new maps you have received from the applicant to be
incorporated into the permit:
9. Is proposed and/or existing groundwater monitoring prograrr� (number of wells, frequency of monitoring,
monitoring parameters, etc.) adequate? ❑ Yes Ft No �,- N/A. Attach map of existing monitoring well
changes to the groundwater monitoring program:
10. For residuals, will seasonal or other restrictions be required? ❑ Yes ❑ No `N/A If yes, attach list of sites
with restrictions (Certification B?)
network if applicable. Indicate the review and compliance boundaries. If No, explain and recommend any
See . Z
III. RENEWAL AND MODIFICATION APPLICATIONS (use previous section for new or major modification
systems)
Description Of Waste(S) And Facilities
1. Are there appropriately certified ORCs for the facilities? ❑ Yes or
Operator in Charge: Certificate #:
Backup- Operator in Charge: Certificate #:
2. Is the design, maintenance and operation (e.g. adequate aeration,
storage, etc) of the treatment facilities adequate for the type of waste
If no, please explain:
3. Are the site conditions (soils, topography, depth to water table, etc)
assimilating the waste? ❑ Yes or ❑ No. If no, please explain:
sludge wasting, sludge storage, effluent
and disposal system? ❑ Yes or ❑ No.
maintained appropriately and adequately
FORM: All Permit Reviews Form 2

AQUIFER PROTECTION SECTION REGIONAL STAFF REPORT
4. Has the site changed in any way that may affect permit (drainage added, new wells inside the compliance
boundary, new development, etc.)? If yes, please explain:
5. Is the residuals management plan for the facility adequate and/or acceptable to the Division?
❑ Yes or ❑ No. If no, please explain: ,-
6. Are the existing application rates (hydraulic or nutrient) still acceptable? ❑ Yes or n No. If jo, please
explain:
7. Is the existing groundwater monitoring program (number of wells, frequency of monitoring, monitoring
parameters, etc.) adequate? ❑ Yes ❑ No ❑ N/A. Attach map of existing monitoring well network if
applicable. Indicate the review and compliance boundaries. If No, explain and recommend any changes to the
groundwater monitoring program:
8. Will seasonal or other restrictions be required for added sites? ❑ Yes ❑ No ❑ N/A If yes, attach list of sites
with restrictions (Certification B?)
9. Are there any buffer conflicts (treatment facilities or disposal sites)? .❑ Yes or ❑ No. If yes, please attach a
map showing conflict areas or attach any new maps you have received from the applicant to be incorporated
into the permit:
10. Is the description of the facilities, type and/or volume of waste(s) as written in the existing permit correct? ❑
Yes or ❑ No. If no, please explain:
11. Were monitoring wells properly constructed and located? n Yes or ❑ No ❑ N/A. If no, please explain:
12. Has a review of all self -monitoring data •been conducted (GW, NDMR, and NDAR as applicable)? n Yes or
❑ No ❑ N/A. Please summarizeanyfindings resulting from this review:
13. Check all that apply: ❑ No ,compliance issues; ❑ Notice(s) of violation within the last permit cycle; ❑
Current enforcement action(s) n Currently under SOC; ❑ Currently under JOC; n Currently under
moratorium. If any,/items checked, please explain and attach any documents that may help clarify
answer/comments;( such as NOV, NOD etc):
14. Have all compliance dates/conditions in the existing permit, (SOC, JOC, etc.) been complied with? ❑ Yes
❑ No ❑Not Determined ❑ N/A.. If no, please explain:
15. Are there any issues related to compliance/enforcement that should be resolved before issuing this permit? ❑
Yesjr ❑ No ❑ N/A. If yes, please explain:
FORM: All Permit Reviews Form 3

.r
AQUIFER PROTECTION SECTION 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:
❑ Heating/cooling water return flow (5A7)
❑ Closed -loop heat pump system (5QM/5QW)
In situ remediation (5I)
❑ Closed -loop groundwater remediation effluent injection (5L/"Non-Discharge")
❑ Other (Specify: )
2. Does system use same well for water source and injection? ❑ Yes
3. Are there any potential pollution sources that may affect injection? L4'Yes
What is/are the pollution source(s)?
source(s)? 67 ft.
No
❑ No Try �J �: �'r�. •;< o 5i� / ,4 .4,1.
. What is the distance of the injection well(s) from the pollution
4. What is the minimum distance of proposed injection wells from the property boundary? ft. '
5. Quality of drainage at site: [Good ❑ Adequate
6. Flooding potential of site: [WLow ❑ Moderate
n Poor
El High
.�,,; ;
7. For groundwater remediation systems, is the proposed and/or existing groundwater monitoring program
(number of wells, frequency of monitoring, monitoring parameters, etc.) adequate? ❑ Yes No. Attach
map of existing monitoring well network if applicable. If No, explain and recommend any changes to the
groundwater monitoring program: -FA r G 'i %v �I t , � f ��, .. , a °
i r /. ri. 7�� • f'•- 1 + s 1 s �3 � Y ? .. �r9r..i i �� r
8. Does the map presented represent the actual site (property lines, wells, surface drainage)? [Yes or n 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. H 1/15 /3 -e1 S �13>=� � � �, �. 1,715
% % '•' it' j�` a, ; �oY � �10 3 a°' ?an
Injection Well Permit Renewal And Modification Only:
1. For heat pump systems, are there any abnormalities in heat pump or inje '.n well operation (e.g. turbid water,
failure to assimilate injected fluid, poor heating/cooling)?
❑ Yes n No. If yes, explain:
ra
2. For closed -loop heat pump system as system lost pressure or required make-up fluid since permit issuance
or last inspection? D Yes No. If yes, explain:
3. For renewal or modi ication of groundwater remediation permits (of any type), will
continued/ad.difional/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:
FORM: All Permit Reviews Form 4

AQUIFER PROTECTION SECTION REGIONAL STAFF REPORT
Address:
Certi . tion number:
5. Complete and att Well Construction Data Sheet.
FORM: All Permit Reviews Form 5

AQUIFER PROTECTION SECTION REGIONAL STAFF REPORT
V. EVALUATION AND RECOMMENDATIONS
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1. Provide any additional narrative regarding your review of the application.:
2. Attach Well Construction Data Sheet - if needed information is available
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3. Do you foresee any problems with issuance/renewal of this permit? ❑ Yes No. If yes, please explain
briefly.
4. List any items that you would like APS Central Office to obtain through an additional information request.
Make sure that you provide a reason for each item:
Item
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Reason
6. List specific special conditions or compliance schedules that you recommend to be included in the permit when
issued. Make sure that you provide a reason for each special condition:
Condition
Reason
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): _k1✓(r1't �P--
Signature of APS regional supervisor:
Date: / ; t'' 0
ADDITIONAL REGIONAL STAFF REVIEW ITEMS
FORM: All Permit Reviews Form 6

?riving Directions from NU Clanton Rd, Charlotte, NC to 230U Archdale Ur, Charlotte, ... 1'age 1 of 2
Send To Printer Back To Directions
Start: 200 Clanton Rd
Charlotte, NC
28217-1304 US
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4. Turn LEFT onto ARCHDALE DR.
5. Make a U-TURN onto ARCHDALE DR.
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6. End at 2300 Archdale Dr, Charlotte, NC 28210-4526 US
02005 MapOtiest,com, lhc,; [ 2005`NAVTEQ
Start:
200 Clanton Rd
Charlotte, NC
28217-1304 US
End:
2300 Archdale Dr
Charlotte, NC
28210-4526 US
http://www.mapquest.com/directions/main.adp?do=prt&mo=ma&2si navt&un=m&go=1 &... 2/3/2005

Driving Directions from 200 Clanton Rd, Charlotte, NC to 2300 Archdale Dr, Charlotte, ... Page 2 of 2-
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AQUIFER PROTECTION SECTION
APPLICATION REVIEW REQUEST FORM
Date: January 31, 2005
To: ❑ Landon Davidson, ARO-APS
❑ _Art_ B arnhardt,_ FRO -AP S_
_Andrew pitner,_MRO,APS)
❑ Jay Zimmerman, RRO-APS
From: Mike Ranck' G4'oundwater Protection Unit
Telephone: [phone]
E-Mail: michael.ranck a,ncmail.net
A. Permit Number: WI0300102
B. Owner: Celanese Acetate, LLC
C. Facility/Operation: Dreyfus Research Park
❑ Proposed ® Existing
D.
Application:
1. Permit Type: ❑ Animal ❑ Surface Irrigation
❑ Recycle n I/E Lagoon
❑ David May, WaRO-
❑ Charlie Stehman, '-ram` -APS
❑ Sherri Knight, WSIPS
N -n
Or- rn
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❑ Facility n Operation
❑ Reuse ❑ H-R Infiltration
❑ GW Remediation (ND)
® UIC - (5I) in -situ groundwater remediation molasses and whey
For Residuals: ❑ Land App. ❑ D&M n Surface Disposal
❑ 503 ❑ 503 Exempt ❑ Animal
2. Project Type: ® New ❑ Major Mod. ❑ Minor Mod. ❑ Renewal ❑ Renewal w/ Mod.
E. Comments/Other Information: ❑ I would like to accompany you on a site visit.
Attached, you will find all information submitted in support of the above -referenced application for your
review, comment, and/or action. Within 30 calendar days, please take the following actions:
® Return a Completed Form APSSRR.
❑ Attach Well Construction Data Sheet.
❑ Attach Attachment B for Certification by the LAPCU.
❑ Issue an Attachment B Certification from the RO*.
* Remember that you will be responsible for coordinating site visits, reviews, as well as additional
information requests with other RO-APS representatives in order to prepare a complete Attachment B for
certification. Refer to the RPP SOP for additional detail.
When you receive this request form, please write your name and dates in the spaces below, make a copy
of this sheet, and return it to the appropriate Central Office -Aquifer Protection Section contact person
listed above.
RO-APS Reviewer: Date:
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FORM: APSARR 09/04 Page 1 of 1

Permit Number WI0300102
Central Files: APS SWP
01/31/05
Permit Tracking Slip
Program Category
Ground Water
Permit Type
Injection In situ Groundwater Remediation Well (51)
Primary Reviewer
michael.ranck
Permitted Flow
Facility
Status Project Type
In review New Project
Version Permit Classification
Individual
Permit Contact Affiliation
Steve Olp
2848 Cherry Rd
Rock Hill
SC 29730
Facility Name
Celanese Acetate LLC
Major/Minor Region
Minor Mooresville
Location Address County
2300 Archdale Dr Mecklenburg
Charlotte NC 28210
Owner
Facility Contact Affiliation
Owner Name Owner Type
Celanese Acetate LLC Non -Government
Owner Affiliation
Joe Ramsey
2848 Cherry Rd
Rock Hill
Dates/Events
SC 29730
Scheduled
Orig Issue App Received Draft Initiated Issuance
01/25/05
Public Notice Issue
Effective Expiration
Regulated Activities Requested/Received Events
Groundwater remediation RO staff report received
RO staff report requested 01/31/05
Outfall NULL
Waterbody Name Stream Index Number Current Class Subbasin

Michael F. Easley, Governor
G William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
-> Alan W. Klimek, P.E. Director
Division of Water Quality
January 31, 2005
Mr. Steve Olp
Celanese International Corp./Global Remediation
2848 Cherry Road — Suite 100
Rock Hill, SC 29730
NC QM., OP ENVIRONMENT
AND NATURAL RECLIVED RESOURCES
FEB - 3 2005
MOORESVILLE REGIONAL OFFICE
DWQ-GROUNDWATER SECTION
Subject: Type 5I injection well permit application WI0300102
Celanese Acetate — Dreyfus Research Park, Charlotte, NC
Dear Mr. Olp:
Celanese Acetate, LLC's application for a permit to construct and use wells for injection of a
carbohydrate reagent at the subject site in Charlotte, North Carolina has been received and is
currently under review. A member of the Aquifer Protection Section's Mooresville Regional
Office staff will be contacting you to arrange an inspection of the injection well site as part of the
review.
If you have any questions regarding your permit application or the Underground Injection
Control program please contact me at [phone] or Evan Kane at [phone].
Sincerely,
4.4
J. Michael Ranck
Hydrogeologist
Groundwater Protection Unit
cc: drew Pitney Mo roesu lle Reg onalx0_ffice
CO-UIC files
Elizabeth Rhine, ARCADIS
NorthCarolina
A'a%llra/1/
Aquifer Protection Section 1636 Mail Service Center Raleigh, NC 27699-1636 Phone [phone] Customer Service
Internet: http://gw.ehnr.state.nc.us. 2728 Capital Boulevard Raleigh, NC 27604 FAX [phone]
An Equal Opportunity/Affirmative Action Employer — 50% Recycled/10% Post Consumer Paper

Infrastructure, buildings, environment, communications
Mr. Evan Kane
UIC Program
Groundwater Section
NC DENR-DWQ
P.O. Box 29578
Raleigh, North Carolina 27626-0578
Subject:
UIC Permit Application for the Injection of Carbohydrate Reagent
Dreyfus Research Park
Inactive Sites Branch
Dear Evan:
On behalf of Celanese Acetate, LLC, please find the attached application for permit
to construct and use temporary injection wells. These wells will be utilized to inject
a carbohydrate reagent (molasses/whey/potable water) into the saprolite aquifer to
stimulate the naturally -occurring anaerobic bacteria to establish a reducing zone
where reductive dechlorination of chlorinated solvents, primarily tetrachloroethene
(PCE), will be enhanced.
In addition to the information provided on the application form, ARCADIS provides
the following supplemental information:
A. See application form.
B. Although the property is currently owned by Celanese Acetate, LLC, the
property is currently under contract to be sold to Eastlan Properties for
redevelopment. Portions of the property will be rezoned for residential
development. The property where groundwater is impacted with
chlorinated solvents and the adjacent 100-foot buffer zone will not be
redeveloped as residential until clean-up goals have been met.
ARCADIS G&M, Inc.
420 East Park Avenue
Greenville
South Carolina 29601
Tel [phone]
Fax [phone]
www.arcadis-us.com
ENVIRONMENTAL
Date:
January 24, 2005
Contact:
Elizabeth Rhine-,
Phone:
864.244.5208 Y :
cJi
Email:
erhine
arcadis=iiS.com
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Our ref:
GS028605.0002
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cn
C. See application form. Currently commercial, but requested to be rezoned -°
residential. �♦♦
VJ
D. See application form. Note that the site is not currently occupied, and cn
the site contact, Steve Olp, is located in Rock Hill, South Carolina. J'
E. See Sections 3 and 4 of the attached Work Plan. The following
information is excerpted from the Work Plan:NC DEPT. OF 019I ilf
AND NATURAL.
A,
RECEIV D
Part of a bigger picture
FEB — 3 2005
MOORESVILLE WATER SECTION
DO -GROUND
•

ARCADIS
1) Construction plans and materials: Using a DPT such as a
GeoProbe® 660 unit, an injection probe will be pushed to
approximately 5 feet above the top of partially weathered rock (i.e.,
the transition zone) as determined by the boring logs of adjacent
boreholes. Once the target depth is achieved, the carbohydrate
solution will be injected on a continuous basis as the injection probe
is raised in the borehole. These procedures are more fully described
in Section 4.1 of this Work Plan. On average, approximately 40
gallons of solution will be injected per vertical foot of boring,
however, the actual volume injected will be dependent on site
geology.
2) Operation procedures: In order for the ERD technology to be
successful, a sufficient amount of carbohydrate must be added to the
subsurface to stimulate microbial activity, provide excess organic
carbon, create the zone of anaerobic and reducing conditions, and
propagate the IRZ in the target zone. Prior experience indicates that
a target carbohydrate concentration (measured as Total Organic
Carbon (TOC)) between 25 and 100 parts per million (ppm) in the
groundwater at least 100 days downgradient of the injection transect
is optimum.
Given this target carbohydrate concentration, the anticipated
hydraulic conditions in the injection area, and the initial injection of
a 10 to 20% molasses -whey solution, it is estimated that the total
volume of this solution required to effectively distribute the organic
carbon will vary between approximately 400 and 2,000 gallons per
well per event, with an initial target of 40 gallons per foot of screen
or per vertical foot of DPT. Long term water -table mounding or
other hydraulic effects are unlikely, as water table conditions will
equilibrate quickly following injection events. Injections will not
affect the plume configuration or gradients at the site.
The composition of the molasses -whey solution, injection volume,
and locations may be altered based on field measurements and
analytical results obtained during performance monitoring in order to
optimize anaerobic conditions.
3) Planned injection schedule: The carbohydrate solution will be
introduced through DPT points semi-annually for the first 30 months
(5 injections). The frequency of injections may be altered based on
field measurements and analytical results obtained during
performance monitoring in order to optimize anaerobic conditions.
Mr. Evan Kane
24 January 2005
G:\ENV\DRP\Permits\UIC Permit\Final\Application Attachments_recovered.doc
Page:
2/6

ARCADIS
F. Celanese formerly utilized PCE in a dry cleaning operation in the Stoll
Building located on the property. There is an abandoned floor drain
system in the Stoll Building that drains into a storm water sewer. It is
thought that small spills of dry cleaning fluid were probably washed into
the floor drains that discharged into a tile field downgradient of the Stoll
Building.
G. See Attachment 1, excerpts from the Remedial Investigation Report for
Dreyfus Research Park, Charlotte, North Carolina, prepared by RMT,
Inc., September 1993. Item (5) is supplied by ARCADIS, and is also
included in Attachment 1.
H. See Section 4.2 of the attached Workplan. The following information is
excerpted from the Work Plan:
The molasses -whey injections are anticipated to occur over a period
of approximately four years with quarterly groundwater monitoring
during the active remediation period. The monitoring frequency will
be extended as necessary if it is determined that a longer period of
active injection is required. A total of 16 monitoring wells will be
sampled during the initial monitoring events (see Figure 3-1 in the
attached Workplan). The number of wells sampled in subsequent
events is subject to change based on laboratory results and data
trends.
For the baseline sampling event, samples will be collected and
analyzed for VOCs, redox parameters (nitrate, total/dissolved iron,
sulfate, sulfide), dissolved gases (methane, ethane, and ethene),
alkalinity, and TOC. All groundwater sampling will be performed
using low -flow sampling techniques, except during sampling of
TOC, which may be sampled using a disposable bailer, if desired.
I. See application form.
J. See application form.
1) See application form.
2) See application form.
Mr. Evan Kane
24 January 2005
G:\ENV\DRP\Permits\UIC Permit\Final\Application Attachments_recovered.doc
Page:
3/6

ARCAD1S
3) Well casing is not applicable to DPT as no permanent casing
will be installed.
4) With the exception of abandoning the borehole, no grout or
bentonite will be used for the temporary DPT points. Portland
cement will be used to abandon the borehole.
5) Screens — Temporary screens will be moved up the borehole at
intervals from approximately 45 to 25 feet below ground surface
for shallow saprolite injection points and from approximately 65
to 45 feet below ground surface for deep saprolite injection
points. No permanent screens will be set during this phase of the
remediation project.
6) See application form. Since the injection points are temporary,
no sample ports will be attached to the well. Monitoring will
occur at nearby existing groundwater monitoring wells.
7) The injection fluid will not be provided by a source well, but
will be potable water mixed with molasses and whey. Details of
the proposed injection fluid can be found in Section 4.1.1 of the
attached Workplan and described in the response to Section 0
below.
K. See Attachment 2.
L. See application form.
M. The injection fluid comprised of potable water, molasses, and whey, will
be shipped to the Site in a tanker truck. Using a pump and the setup
depicted in Attachment 3, the reagent valve will be injected through DPT
points into the saprolite aquifer. As shown on Attachment 3, a pressure
indicator and flow meter will be used to measure injection pressures and
flow rates. These measurements will be recorded on the field form
provided in Attachment 3.
N. See Attachment 4. Per our conversation January 12, 2005, contour
intervals are shown at 10-foot intervals.
O. See Section 4.1.1 of the attached Workplan. The following information
is excerpted from the Work Plan:
1) No underground fluid source will be used for injection.
Mr. Evan Kane
24 January 2005
G:\ENV\DRP\Permits\UICPermit\Final\Application Attachments_recovered.doc
Page:
4/6

ARCADIS
2) Molasses -whey (carbon source) solution will be introduced into
the subsurface as a dilute solution of potable water, molasses,
and whey (see Appendix A for the Material Safety Data Sheet
[MSDS]). This solution will be mixed by the vendor supplying
the molasses and whey, and will be transported to the site pre-
mixed. Based on ARCADIS' experience with implementation
of this technology at similar sites and the results of the quarterly
monitoring, the initial solution will consist of a 10 to 20 percent
molasses -whey solution (i.e, with a 60:40 molasses/whey ratio).
This concentration is expected to provide sufficient carbon to
enhance and drive anaerobic bacterial activity already occurring
in the aquifer.
Based on field data from the second quarter 2004 sampling
event, pH adjustment may be unnecessary. However, if
conditions should change (i.e. excessive pH drop in monitoring
wells due to the natural formation fatty acids resulting from
biological activity), then sodium bicarbonate (NaHCO3) or
sodium hydroxide (NaOH) will be added to the carbohydrate
solution. The concentration will be adjusted as needed, to
increase the aquifer's pH buffering capacity against the potential
for accumulation of organic acids from enhanced bioactivity.
The MSDS for NaHCO3 and NaOH are presented in Appendix A
of the Work Plan.
The composition and concentration of the carbohydrate solution
may be adjusted during the design implementation, based on
interpretation of field measurements and analytical results
obtained during performance monitoring.
P. The only applicable permit for this Site is an NPDES permit for a six -
tray air stripper and bag filter. Since the existing extraction system is not
currently being used, the NPDES permit is not being utilized. See
Attachment 5 for a copy of the permit.
Mr. Evan Kane
24 January 2005
G:\ENV\DRP\Permits\UIC Permit\Final\Application Attachments_recovered.doc
Page:
5/6

ARCADOS
Q.
See application form.
R. See application form.
Sincerely,
ARCADIS G&M, Inc.
Elizabeth Rhine
Remediation Department Manager
Copies:
Copies
Mr. Evan Kane
24 January 2005
G:\ENV\DRP\Permits\UIC Permit\Final\Application Attachments_recovered.doc
Page:
6/6

NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
APPLICATION FOR PERMIT TO CONSTRUCT AND/OR USE A WELL(S) FOR
INJECTION
Class 5I Wells
In Accordance with the provisions of NCAC Title 15A: 02C.0200
Complete application and mail to address on the back page.
TO: DIRECTOR, NORTH CAROLINA DIVISION OF WATER QUALITY
DATE: January 14 , 2005
PERMIT APPLICANT
Name: Celanese Internation Corp./Global Remediation
Address: 2848 Cherry Road - Suite 100
City: Rock Hill — ---- State: _SC_ Zip Code: _29730
County: York Telephone: [phone]
PROPERTY OWNER (if different from applicant)
Name:
Address:
City: State: Zip Code:
County: Telephone:
C. STATUS OF APPLICANT.
Private: Commercial: X Federal: State:
County: Municipal: Native American Lands:
D. FACILITY (SITE) DATA
(Fill out ONLY if the Status is Federal, State, County, Municipal or Commercial).
Name of Business or Facility: Celanese Acetate - Dreyfus Research Park
Address: 2300 Archdale Drive
City: Charlotte Zip Code: 28210 County: Mecklenburg
Telephone: [phone] Contact Person: Steve Olp
E. INJECTION PROCEDURE
Provide a detailed description of all planned activities relating to the proposed injection
facility including but not limited to:
(1) construction plans and materials; SEE SECTION 3 OF THE ATTACHED WORKPLAN
(2) operation procedures; and SEE SECTION 4 OF THE ATTACHED WORKPLAN
(3) a planned injection schedule. SEE SECTION 4 OF THE ATTACHED WORKPLAN
GW-57 REM (Jan, 2000) Page 1 of 5

F. DESCRIPTION OF SITE
Provide a brief description of the contamination incident and the incident number
assigned by the Division of Water Quality staff in the Department's Regional Office:
SEE ATTACHED LETTER. EPA ID No: NCD000608117
G. HYDROGEOLOGIC DESCRIPTION - SEE ATTACHMENT 1.
SECTION (G) MUST BE ORIGINALLY SEALED AND SIGNED BY A
LICENSED GEOLOGIST
Provide a hydrogeologic description, soils description, and cross section of the subsurface to a
depth that included the known or projected depth of contamination. The number of borings
shall be sufficient to determine the following:
(1) the regional geologic setting;
(2) significant changes in lithology;
(3) the hydraulic conductivity of the saturated zone;
(4) the depth to the mean seasonaLhigh.water table; and
(5) a determination of transmissivity and specific yield of the aquifer to be used for
injection (showing calculations).
H. MONITORING PROCEDURE
Provide plans for proposed location and construction details of groundwater monitoring well
network, including a schedule for sampling and analytical methods. Include any
modeling/testing performed to investigate injectant's potential or susceptibility to change
(biological, chemical or physical) in the subsurface. SEE SECTION 4.2 OF THE WORKPLAN
I. WELL USE Will the injection well(s) also be used as the supply well(s) for the following?
(1) The injection operation?
(2) Personal consumption?
J. CONSTRUCTION DATA (check one)
X
YES NO X
YES NO X
EXISTING WELL being proposed for use as an injection well. Provide the
data in (1) through (7) below to the best of your knowledge. Attach a copy
of Form GW-1 (Well Construction Record) if available.
PROPOSED WELL to be constructed for use as an injection well. Provide
the data in (1) through (7) below as PROPOSED construction
specifications. Submit Form GW-1 after construction.
(1) Well Drilling Contractor's Name: A.E. Drilling Inc.
NC Contractor Certification number: Bill Barnes 2270
(2) Date to be constructed: _February 2005_ Number of borings: _142
Approximate depth of each boring (feet): 45 to 65
GW-57 REM (Jan, 2000) Page 2 of 5

(3)
Well casing: (NOT APPLICABLE)
Type: Galvanized steel Black steel Plastic Other (specify)
Casing depth: From to ft. (reference to land surface)
Casing extends above ground inches
(4) Grout: (NOT APPLICABLE)
Grout type: Cement_X_ Bentonite Other (specify)
Grouted surface and grout depth (reference to land surface):
around closed loop piping; from to (feet).
around well casing; from to (feet).
(5)
Screens (SEE ATTACHED LETTER)
Depth: From to feet below ground surface.
(6) N.C. State Regulations (Title 15A NCAC 2C .0200) require the permittee to make
provisions for monitoring wellhead processes. A faucet on both influent (recovered
groundwater) and effluent (fluid being injected into the well) lines is generally
required.
(7)
Will there be a faucet on the influent line?
Will there be a faucet on the effluent line?
yes no_X_
yes no_X_
SOURCE WELL CONSTRUCTION INFORMATION (if different from injection
well). Attach a copy of Form GW-1 (Well Construction Record). If Form GW-1 is not
available, provide the data in part G of this application form to the best of your
knowledge. SEE ATTACHED LETTER AND SECTION 4.1.1 OF THE WORKPLAN.
NOTE: THE WELL DRILLING CONTRACTOR CAN SUPPLY THE DATA FOR EITHER EXISTING OR
PROPOSED WELLS IF THIS INFORMATION IS UNAVAILABLE BY OTHER MEANS.
K. OTHER WELL DATA
Provide a tabulation of data on all wells within Y4 mile of the injection well(s), excepting
water supply wells serving a single-family residence, which penetrate the proposed injection
zone. Such data shall include a description of each well's type, depth, record of abandonment
or completion, and additional information the Director may require. SEE ATTACHMENT 2.
L. PROPOSED OPERATING DATA
(1) Injection rate: Less than _8 gallons per minute (gpm)
(2) Injection volume: Average _1200_ gallons per well (40 gallons per vertical foot of screen)
(3) Injection pressure: Less than 50 pounds/square inch (psi)
(4) Injection temperature: Average (January) 55_ ° F, Average (July) _70_ ° F
(5) Hydraulic capacity of the well: up to 2000 gallons per injection point
(6) Expected lifetime of the injection facility: 4 years
(7) Give a description of how the above data will be measured and controlled:
_Carbohydrate reagent will be pumped into each DPT injection point. Pressure and
_flow rate will be measured at the well head. See figure in Attachment 3.
GW-57 REM (Jan, 2000) Page 3 of 5

M. INJECTION -RELATED EQUIPMENT
Attach a diagram showing the detailed plans and specifications of the surface and subsurface
construction details of the system. SEE ATTACHMENT 3.
N. LOCATION OF WELL(S)
Attach a scaled, site -specific map(s) showing the location(s) of the following:(SEE ATTACHEMNT 4)
(1) the proposed injection well(s);
(2) all property boundaries;
(3) contour intervals not exceeding two feet;
(4) the direction and distance from the injection well or well system to two nearby,
permanent reference points (such as roads, streams, and highway intersections);
(5) all buildings within the property boundary;
(6) any other existing or abandoned wells, including water supply and monitoring wells,
within the area of review of the injection well or wells system;
(7) potentiometric surface showing direction of groundwater movement;
(8) the horizontal and vertical extent of the contaminant plume (including
isoconcentration lines and plume cross sections);
(9) 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; and
(10) all surface water bodies within 1000 feet of the injection well or well system.
O. INJECTION FLUID DATA SEE ATTACHED LETTER.
(1) Fluid source, if underground, from what depth, formation and type of rock/sediment
unit will the fluid be drawn (e.g., granite, limestone, sand, etc.).
Depth:
Formation:
Rock/sediment unit:
(2) Provide the chemical, physical, biological and radiological characteristics of the fluid
to be injected.
P. PERMIT LIST
Attach a list of all permits or construction approvals that are related to the site, including but
not limited to:
(1)
(2)
(3)
(4)
Hazardous Waste Management program permits under RCRA - Not Applicable
NC Division of Water Quality Non -Discharge permits - See Attachment 5
Sewage Treatment and Disposal Permits - Not Applicable
Other environmental permits required by state or federal law - Not Applicable.
GW-57 REM (Jan, 2000) Page 4 of 5

Q.
CERTIFICATION
"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 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 ith t1 approved specifications
and conditions of the Permit." ,� /%�
(Signature of Well Owner or Authorized Agent)
If authorized agent is acting on behalf of the well owner,
please supply a letter signed by the owner
authorizing the above agent.
R. CONSENT OF PROPERTY OWNER (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 rests ownership in the landowner in the absence of contrary agreement in writing.)
If the property is owned by someone other than the applicant, the property owner hereby
consents to allow the applicant to construct each injection well as outlined in this application
and that it shall be the responsibility of the applicant to ensure that the injection well(s)
conforms to the Well Construction Standards (Title 15A NCAC 2C .0200)
(Signature Of Property Owner If Different From Applicant)
Please return two copies of the completed Application package to:
UIC Program
Groundwater Section
North Carolina DENR-DWQ
1636 Mail Service Center
Raleigh, NC 27699-1636
Telephone [phone]
GW-57 REM (Jan, 2000) Page 5 of 5

ARCADIS
Attachment 1
Hydrogeologic Description

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SZ8£-L096Z

RMT INVESTIGATION REPORT - PHASE 1 AND PHASE 2 RESULTS SEPTEMBER 1993
HOECHST CELANESE - DREYFUS RESEARCH PARK SECTION 3
Section 3
SITE HYDROGEOLOGY
This section describes the geology and hydrogeology of the site including geologic materials, ground
water flow, and aquifer characteristics.
Regional geologic maps indicate that the site is located in the Charlotte Belt of the Piedmont
Physiographic Province (Goldsmith and Others, 1988). From regional geologic maps, the rock types
identified near the site include granites, gabbros, and metagabbros. The geology and hydrogeology of
the site has been characterized using the following data collected during the drilling of 57 borings, 24
wells, one piezometer, water level measurements, aquifer tests, and physical analyses. The locations
of these points are shown on Plate 2.
3.1 Site Hydrogeology
The site soils consist of saprolite and residual soils, weathering products of igneous and metamorphic
parent rocks (Stuckey, 1976) and river floodplain deposits. The residual soil consists of silt, clayey silt,
and sandy silt. The residual soil on -site ranges in thickness from 5 to 32 feet. The saprolite consists of
silt, clayey and sandy silt, clayey and silty sand, and clay. The saprolite ranges in thickness from 8 to
67 feet. In Area B, river floodplain deposits (alluvium) from Little Sugar Creek have been deposited on
saprolite. The alluvium consists of clay, clayey silt, silt, clayey and silty sand, and sand. In the eastern
part of Area B, a six- to ten -foot clay layer is prominent in the floodplain deposits. The clay is found
four to six feet below land surface. Thickness of the unconsolidated alluvial sediments encountered
during drilling in the Little Sugar Creek floodplain ranged from 22 to 26 feet.
Depth to rock (as defined by auger refusal) varies from greater than 75 feet below land surface to
surface outcrops. The rock surface is characterized by parallel north to northeast trending ridges and
troughs. Rock types identified on -site are granite, gabbro, and metagabbro. The rock is characterized
by granites which have been intruded by mafics (gabbro and metagabbro). The shape, orientation, and
extent of the mafic intrusions are not known. A map illustrating the estimated rock surface is presented
on Plate 4.
I:\W F'‘.9\91503. R I Rlcd193
3-1

RMT INVESTIGATION REPORT - PHASE 1 AND PHASE 2 RESULTS SEPTEMBER 1993
HOECHST CELANESE - DREYFUS RESEARCH PARK
SECTION 3
Boring Togs from Phase 1 and Phase 2 RI are included in Appendix B. Cross -sections A -A', B-B', and
C-C' (based boring logs) illustrating site geology are included on Plate 5. Cross-section locations are
shown on Plate 2.
3.2 Ground Water
Water level measurements made at monitoring wells and staff gages on November 15, 1991,
December 19, 1991, February 5, 1992, March 3, 1993, and March 29, 1993. A summary of water level
elevations is shown on Table 3-1. Water levels measured on March 3, 1993 were used to prepare the
water table configuration map shown on Plate 6. Depth to ground water varies from four to thirteen feet
below ground surface on the floodplain of Little Sugar Creek (Area B) and from approximately nine to
forty-six feet below ground surface closer to the facility. As shown on Plate 6, approximate ground
water flow direction is to the southeast towards Little Sugar Creek and to the south toward the
unnamed tributary flowing into Little Sugar Creek.
Evaluation of water level elevations measured in the deep saprolite wells, MW-2A, MW-4A, and MW-
10A, indicates a trend of decreasing hydraulic head in a southeast direction similar to that observed in
water table wells at the site. Evaluation of water levels measured in the rock wells MW-8A, MW-2B,
and MW-3A indicate a trend of decreasing hydraulic head in a southeast direction. The available data
indicates that ground water flow within the deep saprolite and bedrock aquifers is similar to the flow
pattern described in the water table configuration map:
Ground water is present in unconfined conditions in saprolite, alluvium, and in fractured rock. Ground
water has been encountered in perched conditions in Area B due to a clay layer. This clay layer is four
to six feet below land surface, approximately six to ten feet thick, discontinuous, and is present beneath
much of Area B.
Horizontal Hydraulic Gradient. The hydraulic gradient was calculated for the alluvium in Area
B and saprolite for the remainder of the site. Horizontal gradients were calculated using the
following formula:
I:1W P19191503. R I R/cdf 93
•hwt - hwz A hydraulic head
Ih s A horizontal distance
3-2

RMT INVESTIGATION REPORT - PHASE 1 AND PHASE 2 RESULTS
HOECHST CELANESE - DREYFUS RESEARCH PARK
MW-1
TABLE 3-1
SUMMARY WATER LEVEL ELEVATIONS
HOECHST CELANESE - DREYFUS RESEARCH PARK
571.64
556.61
556.14
556.60
557.70
SEPTEMBER 1993
SECTION 3
................
558.72
MW-2
572.72
558.32
557.30
559.27
562.06
564.06
MW-2A
572.59
559.59
556.64
557.32
558.92
560.29
MW-2B
572.49
559.09
560.50
MW-3
573.39
555.79
555.57
555.89
557.62
559.90
MW-3A
572.8
554.68
559.43
MW-4
572.76
560.52
560.01
562.01
565.63
567.53
MW-4A
572.68
565.47
567.36
MW-5
613.69
580.02
579.59
579.74
583.45
585.05
MW-6
618.57
588.10
587.57
587.74
591.06
' 591.59
MW-7
625.32
594.10
593.57
593.42
595.95
596.40
MW-8
643.94
624.04
624.02
624.46
626.32
626.80
MW-8A
643.92
626.02
626.45
MW-9
650.55
625.69
625.50
625.84
627.72
628.51
MW-10
645.63
625.05
624.94
625.12
626.98
627.65
MW-10A
645.41
621.31
621.31
621.81
624.16
625.04
MW-11
650.17
628.79
628.27
628.59
630.78
639.76
MW-12
661.74
646:64
646.57
647.23
649.66
639.90
MW-14
604.56
581.27
586.89
MW-15
636.79
c
600.97
601.40
MW-16
660.28
c
618.75
618.79
MW-18
633.37
621.70
622.39
MW-19
649.48
624.04
624.37
MW-20
639.29
590.97
591.64
PZ-3
663.01
c
633.81
SG-1
556.05d
555.20
555.17
555.27
556.03
SG-2
554.77d
554.04
553.87
553.98
554.29
SG-3
554.19d
553.57
553.35
553.54
553.78
a Elevations are reported in feet above mean sea level, referenced to NGVD, 1929.
b Water levels measured on March 3, 1993, were used to construct water table configuration map.
c Locations had not been installed at date that measurements were taken.
d Measuring point is a mark cut into a large rock in stream bank (on Little Sugar Creek).
e Locations were not measured during March 29, 1993 sampling round.
I:\W P19\91503. R I R/cdf93
3-3

RMT INVESTIGATION REPORT - PHASE 1 AND PHASE.2 RESULTS SEPTEMBER 1993
HOECHST CELANESE - DREYFUS RESEARCH PARK SECTION 3
Where ih = horizontal ground water flow gradient
hW1 = elevation of water level in shallow well 1
hw2 = elevation of water level in shallow well 2
s = horizontal distance between well 1 and well 2
Note: Wells within the same hydrostratigraphic units have been used for horizontal gradient
calculations. Horizontal gradients have been calculated perpendicular to equipotential
lines.
This formula has been adapted from Fetter (1980, p. 126). The calculated gradients for the site
are 0.013 feet per foot for the Area B alluvium and 0.04 feet per foot for the site saprolite.
Hydraulic gradient calculations are shown in Appendix F.
Vertical Hydraulic Gradients. Water levels measured in nested or paired wells were used to
calculate vertical ground water gradients using the following formula:
E3d - E3s
[( E3s - E2s) + E2s] - [(El d 2 E2d) + E2d]
Where is,d = vertical gradient
El = elevation of bottom of bentonite seal
E2 = elevation of bottom of well screen
E3 = elevation of water level
s = shallow well
d = deeper well
This formula has been adapted from Freeze and Cherry (1979, p. 24). The denominator of the
equation represents the adjustment required by the presence of a screened interval rather than
a single water level monitoring point.
Vertical gradients have been calculated for the well pairs (MW-10/10A, MW-8/8A, MW-4/4A,
MW-3/3A, MW-2, MW-2A/2B, and MW-2/2B). The calculated values are shown on Table 3-2.
and the worksheet calculations are included in Appendix D. In six of seven well pairs for the
last two sampling rounds, the vertical gradient is negative or downward. Caution should be
used when applying vertical gradient data which has been obtained from well pairs with
significant differences in the depths to the well screens. Well pairs MW-2/2B, MW-3/3A, and
MW-8/8A have at least 50 feet of separation between the shallow and deep well screens. The
I :\W P\9\91503. R I Ricdt93
3-4

RMT INVESTIGATION REPORT - PHASE 1 AND PHASE 2 RESULTS
HOECHST CELANESE - DREYFUS RESEARCH PARK
TABLE 3-2
VERTICAL GRADIENT DATA
SEPTEMBER 1993
SECTION 3
MW-2/2A
0.036
wE 1M N1' ee 1
-0.019
-0.054
-0.084
-0.01
MW-2A/2B
0.0036
0.0045
M W-2/2B
-0.035
-0.042
MW-3/3A
-0.044
-0.007
MW-4/4A
-0.0072
-0.0077
MW-8/8A
-0.0052
-0.0061
MW-10/10A
-0.129
-0.125
-0.074 •
-0.062
-0.057
Note: Positive values indicate upward vertical ground water flow and negative values indicate downward vertical ground water flow.
downward gradients calculated for these well pairs may not be applicable to the discussion of
shallow ground water hydraulics. The one well pair with positive gradients is well pair
MW-2A/2B. This well pair has a well screen separation of approximately 37 feet with the
deeper well (MW-2B) screened in rock. The vertical gradient for this well pair is positive
indicating upward flow from rock to saprolite.
The calculated vertical gradient at well pairs MW-3/3A, MW-4/4A, MW-8/8A, and MW-10/10A
represents a downward gradient and is consistent with the hydraulic setting of these well pairs
in an area of recharge. _
The calculated gradient for well pair MW-2/2A (located near Little Sugar Creek) has ranged
from 0.036 feet per foot to -0.085 feet per foot. These vertical gradients indicate both recharge
and discharge of ground water in the vicinity of Little Sugar Creek. Indicating that the stream is
"gaining" stream during wet seasons and a "losing" stream during dry seasons.
Hydraulic Conductivity. Hydraulic conductivity tests were conducted on 24 monitoring wells
and one piezometer. Hydraulic conductivity values were estimated using the Bouwer and Rice
I:\WP\9\91503. R I R/aN93
3-5

RMT INVESTIGATION REPORT - PHASE 1 AND PHASE•2 RESULTS SEPTEMBER 1993
HOECHST CELANESE - DREYFUS RESEARCH PARK SECTION 3
Method (1976 and 1989) and are shown on Table 3-3. Calculations and curves for the tests
are shown in Appendix E. Estimated conductivity values range from 4 x 10.6 cm/sec to 7 x 10-'
cm/sec in rock, 2 x 10-2 to 8 x 10-5 cm/sec in sandy alluvium, and 2 x 10-3 to 5 x 10-6 cm/sec in
saprolite.
Seepage velocities were calculated using the formula published by Freeze and Cherry (1979):
= ki
V
S n
Where VS = seepage velocity
k = hydraulic conductivity
i = hydraulic gradient
n = effective porosity
The calculated average hydraulic gradient ranges from 0.013 to 0.04 feet per foot. The
effective porosity values used in these calculations was 25 percent for the sandy alluvium in
Area B and 20 percent for the more silty -clayey nature of the saprolite. These are typical
values for these soil types (Fetter, 1988). The calculated seepage velocity values for the site
range from approximately 31 and 164 feet per year in the saprolite to 327 feet per year in the
sandy portion of the alluvium. Calculations for seepage velocities are shown in Appendix F.
Physical Characteristics
Ten soil samples, collected from boreholes MW-3A, MW-4A, MW-14, MW-15, MW-18, SB-26,
SB-27, SB-33, SB-34, and SB-36 were sent to the laboratory for physical analysis. Testing
included sieve analyses, Atterberg limits, and falling head permeability. Falling head
permeability tests resulted in a range of average values from 1.7 x 104 cm/sec for saprolite
(silt) collected in Area C to 1.5 x 10-8 cm/sec for alluvial clay collected in Area B. A summary of
the.physical analysis results is shown on Table 3-4. Data sheets are included in Appendix G.
I:\W P\9191503. R I R/aH93
3-6

RMT INVESTIGATION REPORT - PHASE 1 AND PHASE 2 RESULTS
HOECHST CELANESE - DREYFUS RESEARCH PARK
TABLE 3-3
SUMMARY OF HYDRAULIC CONDUCTIVITY DATA
HOECHST CELANESE - DREYFUS RESEARCH PARK
SEPTEMBER 1993
SECTION 3
MW-1
Nov. 1991
Area B
4x10-3
11.34
Clayey Sanda
MW-2
Nov. 1991
Area B
8x10-6
0.23
Silty Sand and Sanda
MW-2A
Nov. 1991
Area B
5x10-6
0.01
Sand and Clayey Sandb
MW-2B
March 1993
Area B
2xio-6
4x103
Rock
MW-3
Nov. 1991
Area B
4x10-4
1.13
Silty Sand and Silt'
MW-3A
March 1993
Area B
7x10-7
2x10-3
Rock
MW-4
Nov. 1991
Area B
2x10-2
56.7
Sanda
MW-4A
March 1993
Area B
4x10-4
1.25
silt'
MW-5
Nov. 1991
Area A
1x10-3
2.84
Silt and Sandy Siltb
MW-6
Nov. 1991
Area A
2x104
0.57
Sandy Silt and Siity Sandb
MW-7
Nov. 1991
Area A
4x10-4
1.13
Silty Sandb
MW-8
Nov. 1991
Area C
8x10-4
2.27
Clayey Silt and Siltb
MW-8A
March 1993
Area C
4x10-6
Rock
MW-9
Nov. 1991
Area C
1x10-3
2.84
Silty Sandb
MW-10
Nov. 1991
Area C
6x10-4
1.70
Clayey Silt and Silty Sandb
MW-10A
Nov. 1991
Area C
3x10-4
0.85
Sandy Siltb
MW-11
Nov. 1991
Area C
1x10-3
2.84
Silty Sandb
MW-12
Nov. 1991
Background
1x10-3
2.84
Sandy Silt and Siltb
MW-14
March 1993
Area C
2x103
4.75
Silty Sandb
MW-15
March 1993
Area C
3x1o4
0.80
Silty Sandb
MW-16
March 1993
Area C
3.53
Siltb
MW-18
March 1993
Area C
4x10-4
1.04
Silty Sandb
MW-19
March 1993
Additional Area
1x10-3
4.10
Silty Sand and Siltb
MW-20
March 1993
Area D
2x10-3
4.69
Silty Sandb
PZ-3
March 1993
Area C
8x104
2.31
Sandy Siltb
Soil is alluvium.
b Sail is saprolite.
IMP\9\91503.RIFtiodt93
3-7

RMTINVESTIGATION REPORT ' PHASE 1AND PHASE oRESULTS
TABLE 3-4
RESULTS OFPHYSICAL TESTING
aEPTEMeER1non
SECTION
MN-3
well -graded
sand with sift
KAL
sandy silt
_
K8VV-4AU4-16.51
CH
fat clay with sand
1.5x 1O-11
Gm
silty sand
_
MW-1OA
ML
silt
_
Gm
Sm
MH
silty sand
silty sand
elastic silt
_
_
8B'408-12.\
[L
clay
_
8m
silty sand
_
SB'11
0L
_
GK8
ML
silty sand
sandy silt
_
SB-33(6-8')
OL
lean clay with sand
4`2x 1O-8
SB-34(2—G1
K8H
sandy elastic silt
_
QB<38(15-17)
Gm
silty sand
_
[1'clay
ML silt
MH'elastic silt
CH'fat clay
sM'silty sand
SW - sand

Groundwater Elevations
Dreyfus Research Park - Charlotte, NC
Well ID
Top of Casing
(ftmsl)
1st
2nd
1996
3rd
4th
1st
2nd
1997
3rd
4th
EW-1
640.87
611.22
606.78
dry
604.22
dry
dry
dry
dry
EW-2
633.80
613.86
612.99
611.70
610.03
609.86
610.90
609.60
608.66
EW-3
638.16
615.76
614.31
613.88
614.75
614.42
614.86
614.12
614.16
EW-4
646.54
612.54
dry
dry
dry
dry
dry
dry
dry
EW-5
646.95
590.40
dry
dry
dry
dry
dry
dry
dry
EW-6
637.79
dry
dry
dry
dry
dry
dry
dry
dry
EW-7
633.66
dry
610.49
614.82
615.32
dry
dry
dry
dry
EW-8
636.29
619.79
618.73
616.01
613.79
615.82
622.29
614.72
613.83
EW-9
640.85
620.41
618.72
615.26
613.56
615.33
616.55
613.75
613.94
EW-10
643.12
615.76
608.18
590.58
590.19
590.60
593.08
591.37
592.23
EW-11
643.65
625.37
589.43
585.10
584.23
583.60
dry
dry
dry
EW-12
640.51
592.96
592.82
593.28
593.55
593.28
593.51
592.86
592.94
EW-13
632.93
592.35
593.03
592.63
601.02
593.03
591.78
592.13
596.64
EW-14/RW-2
643.55
604.30
602.66
604.03
601.21
602.60
596.48
603.73
603.93
EW-15
652.99
601.57
601.54
600.36
601.19
598.62
598.69
596.79
598.74
MW-1
571.64
557.16
556.98
556.36
556.39
577.09
557.04
556.82
556.43
MW-2
572.72
560.96
560.62
558.04
558.82
562.67
560.84
559.73
558.51
MW-2A
572.59
558.35
557.94
556.57
556.76
558.48
558.03
557.49
556.29
MW-2B
572.49
558.13
557.99
556.81
556.84
558.44
558.09
557.68
556.57
MW-3
573.39
556.74
556.95
556.21
556.07
558.36
557.07
556.83
555.47
MW-3A
572.80
556.65
557.02
556.12
555.80
556.82
556.83
556.75
555.38
MW-4
572.76
563.71
564.11
560.33
560.84
564.40
563.88
562.52
560.34
MW-4A
572.68
563.76
564.07
560.26
560.68
564.44
563.86
562.66
560.54
MW-5
613.69
580.47
582.03
580.40
579.39
dry
581.58
580.10
dry
MW-6
618.57
589.15
589.46
588.27
587.05
583.07
589.40
588.54
586.92
MW-7
625.32
594.80
595.15
594.40
593.12
593.62
595.00
594.57
593.07
MW-8
643.94
624.89
624.03
621.44
621.21
622.58
623.36
621.16
621.00
MW-8A
643.92
624.60
624.00
621.21
621.19
622.27
623.35
621.34
620.92
MW-9
650.55
626.43
626.04
623.85
623.03
624.65
625.28
623.61
623.13
MW-10
645.63
625.08
624.31
dry
621.32
623.23
623.72
dry
dry
MW-10A
645.41
618.18
616.47
612.37
611.44
612.99
613.38
611.01
610.84
MW-11
650.17
629.19
629.03
626.78
626.34
627.87
628.20
626.60
626.19
MW-12
661.74
648.75
649.76
647.19
645.36
647.15
648.52
646.80
645.23
MW-13
623.93
595.42
596.79
595.11
593.64
594.55
595.79
594.53
593.35
MW-14
604.56
578.42
579.24
576.97
575.95
578.02
579.20
577.60
575.95
MW-15
636.79
600.13
599.89
599.24
597.98
597.85
599.49
598.51
597.37
MW-16
660.28
645.72
618.18
617.72
616.71
616.37
617.48
617.46
616.33
MW-18
633.37
612.22
609.14
606.52
604.49
604.81
605.23
604.07
603.93
MW-19
649.48
622.85
623.37
621.96
621.18
622.08
622.73
622.26
620.78
MW-20
639.29
589.91
590.87
590.84
588.73
588.18
590.19
589.96
589.13
MW-21
619.05
605.15
605.27
604.16
603.84
605.28
605.10
604.40
603.70
MW-22
570.88
561.39
561.64
558.81
559.38
562.46
561.78
560.46
558.88
MW-23
572.33
561.42
561.71
558.91
559.33
562.35
561.68
560.41
558.77
MW-24
635.45
nm
nm
nm
nm
nm
nm
nm
nm
PZ-I
650.75
nm
605.66
603.68
602.24
602.12
602.18
601.74
602.52
PZ-2
646.72
nm
606.66
604.83
602.91
602.69
602.92
602.40
603.11
PZ-3
663.01
nm
633.45
632.30
631.54
631.74
broke
broke
broke
PZ-4
630.51
620.80
618.69
618.67
625.51
619.29
618.67
dry
PZ-5
647.91
nm
624.80
622.06
621.63
623.27
624.04
621.93
621.68
OPZ-1
589.62
OPZ-2
589.84
OPZ-3
616.92
RW-1
653.11
600.46
590.19
598.13
598.79
596.05
597.39
595.37
595.20
PT-01
571.66
nm
561.35
558.61
603.84
562.15
561.36
560.16
558.66
OMW-1
570.48
562.21
561.89
560.26
560.68
562.55
562.08
561.37
560.36
OMW-2
595.04
578.66
578.22
576.57
576.07
577.04
577.62
576.38
575.22
OMW-3
600.65
594.20
589.63
588.40
588.09
586.15
589.35
588.36
587.97
OMW-4
581.68
567.36
567.85
565.45
566.39
568.26
567.83
566.62
565.36
OMW-5
607.73
597.86
597.68
595.94
594.63
594.71
596.18
594.28
593.38
OMW-6
619.78
OMW-7
619.63
nm = not measured
Page 1 of 5

Groundwater Elevations
Dreyfus Research Park - Charlotte, NC
Well ID
Top of Casing
(ftmsl)
1st
2nd
1998
3rd
4th
1st
2nd
1999
3rd
4th
1st
EW-1
640.87
dry
dry
dry
dry
nm
nm
nm
dry
nm
EW-2
633.80
614.58
nm
610.92
608.70
nm
nm
nm
607.20
nm
EW-3
638.16
615.20
nm
615.54
612.46
nm
nm
nm
616.18
nm
EW-4
646.54
dry
dry
dry
dry
nm
nm
nm
dry
nm
EW-5
646.95
dry
dry
603.90
dry
nm
nm
nm
nm
nm
EW-6
637.79
dry
dry
dry
dry
nm
nm
nm
nm
nm
EW-7
633.66
dry
dry
dry
dry
nm
dry
dry
dry
dry
EW-8
636.29
617.47
618.43
615.41
612.99
nm
nm
nm
611.91
nm
EW-9
640.85
616.93
617.67
614.40
611.93
nm
nm
nm
611.09
nm
EW-10
643.12
592.76
nm
593.63
592.37
nm
nm
nm
592.87
nm
EW-11
643.65
592.39
nm
590.99
591.87
nm
nm
nm
590.90
nm
EW-12
640.51
593.19
nm
593.51
593.56
nm
nm
nm
593.11
nm
EW-13
632.93
592.73
nm
592.93
592.88
nm
nm
nm
593.50
nm
EW-14/RW-2
643.55
606.31
nm
603.48
600.40
nm
nm
590.05
600.80
603.88
EW-15
652.99
598.04
nm
601.32
601.19
nm
597.73
600.54
601.07
599.49
MW-1
571.64
557.57
nm
556.73
555.89
557.01
556.47
556.89
555.57
nm
MW-2
572.72
562.66
nm
560.11
557.38
560.77
558.67
nm
556.72
nm
MW-2A
572.59
558.83
558.23
557.56
555.94
557.73
556.87
nm
555.55
556.97
MW-2B
572.49
558.90
nm
557.70
556.06
557.67
556.97
nm
555.60
nm
MW-3
573.39
557.87
nm
556.62
555.25
556.55
555.97
nm
554.88
nm
MW-3A
572.80
557.67
557.35
556.63
555.44
556.33
556.13
nm
554.98
555.88
MW-4
572.76
565.57
564.98
562.87
559.31
563.53
561.16
550.26
558.19
561.08
MW-4A
572.68
565.54
564.84
562.83
559.24
563.38
561.11
nm
558.11
nm
MW-5
613.69
582.13
nm
581.29
dry
nm
nm
nm
dry
nm
MW-6
618.57
590.04
nm
589.50
587.19
nm
nm
nm
584.59
nm
MW-7
625.32
595.70
nm
595.59
593.53
nm
nm
nm
590.88
nm
MW-8
643.94
624.18
nm
622.22
620.48
nm
nm
nm
dry
nm
MW-8A
643.92
623.96
624.45
622.18
620.44
622.30
621.58
nm
618.97
nm
MW-9
650.55
626.27
nm
624.66
622.50
nm
nm
nm
620.87
nm
MW-10
645.63
624.73
nm
622.86
dry
nm
nm
nm
dry
nm
MW-10A
645.41
613.96
nm
611.49
609.49
nm
nm
nm
609.21
nm
MW-11
650.17
629.17
nm
628.09
633.99
nm
nm
nm '
623.87
nm
MW-12
661.74
649.01
nm
647.73
nm
nm
nm
nm
644.14
nm
MW-13
623.93
596.68
nm
595.09
593.41
nm
nm
nm
dry
nm
MW-14
604.56
580.05
nm
578.23
575.84
nm
nm
nm
573.36
nm
MW-15
636.79
598.65
nm
599.63
598.09
nm
nm
nm
596.03
nm
MW-16
660.28
617.48
nm
618.31
616.76
nm
nm
nm
615.06
nm
MW-18
633.37
605.22
605.78
604.31
602.97
602.99
nm
dry
dry
dry
MW-19
649.48
623.03
nm
621.65
621.33
nm
nm
nm
619.68
nm
MW-20
639.29
590.12
nm
591.40
589.27
nm
nm
nm
586.64
nm
MW-21
619.05
606.26
nm
604.64
603.43
nm
nm
nm
602.97
nm
MW-22
570.88
563.15
nm
560.83
558.03
561.40
559.46
nm
557.26
nm
MW-23
572.33
563.17
562.35
560.80
558.01
561.43
559.46
557.22
557.21
559.55
MW-24
635.45
nm
nm
nm
nm
nm
nm
nm
nm
nm
PZ-1
650.75
602.05
nm
602.15
601.68
nm
nm
nm
601.29
nm
PZ-2
646.72
602.62
nm
602.74
602.00
nm
nm
nm
601.07
nm
PZ-3
663.01
broke
nm
663.01
nm
nm
nm
nm
nm
nm
PZ-4
630.51
623.71
nm
618.63
618.56
nm
nm
nm
dry
nm
PZ-5
647.91
624.87
nm
622.99
621.17
nm
nm
nm
619.67
nm
OPZ-1
589.62
OPZ-2
589.84
OPZ-3
616.92
RW-1
653.11
595.68
598.58
598.98
598.93
598.74
598.68
598.83
598.73
595.65
PT-01
571.66
562.82
nm
560.54
557.83
nm
nm
nm
557.09
nm
OMW-1
570.48
562.78
nm
560.88
nm
nm
nm
nm
nm
nm
OMW-2
595.04
578.51
nm
576.62
574.94
nm
nm
nm
574.01
nm
OMW-3
600.65
589.75
nm
588.68
587.65
588.73
nm
586.60
586.95
nm
OMW-4
581.68
569.02
568.58
566.73
564.68
nm
nm
nm
563.00
nm
OMW-5
607.73
596.51
596.98
593.80
592.78
594.01
593.48
592.22
591.46
592.55
OMW-6
619.78
OMW-7
619.63
nm = not measured
Page 2 of 5

Groundwater Elevations
Dreyfus Research Park - Charlotte, NC
Well ID
Top of Casing
(ftmsl)
2nd
2000
3rd
4th
1st
2nd
2001
3rd
4th
EW-1
640.87
nm
nm
dry
nm
nm
nm
dry
EW-2
633.80
nm
nm
606.41
nm
nm
nm
605.23
EW-3
638.16
nm
nm
610.97
run
nm
nm
dry
EW-4
646.54
nm
nm
dry
nm
nm
nm
dry
EW-5
646.95
nm
nm
dry
nm
nm
nm
598.65
EW-6
637.79
nm
nm
dry
nm
nm
nm
dry
EW-7
633.66
nm
nm
dry
nm
nm
nm
dry
EW-8
636.29
nm
nm
dry
nm
nm
nm
dry
EW-9
640.85
nm
nm
609.43
nm
nm
nm
607.65
EW-10
643.12
nm
nm
592.34
nm
nm
nm
591.65
EW-11
643.65
nm
nm
590.73
nm
nm
nm
588.35
EW-12
640.51
nm
nm
602.24
nm
nm
nm
593.62
EW-13
632.93
nm
nm
593.35
nm
nm
nm
592.53
EW-14/RW-2
643.55
601.60
nm
596.74
594.88
598.77
593.64
596.04
EW-15
652.99
600.84
598.55
600.99
600.49
599.27
600.91
591.88
MW-1
571.64
556.23
555.86
555.57
555.51
555.92
555.54
555.16
MW-2
572.72
nm
nm
556.01
nm
nm
nm
555.28
MW-2A
572.59
nm
nm
555.08
555.58
nm
nm
544.55
MW-2B
572.49
nm
nm
555.13
555.58
nm
nm
544.62
MW-3
573.39
nm
nm
554.61
nm
nm
nm
544.13
MW-3A
572.80
555.33
nm
554.63
554.99
555.23
554.49
544.19
MW-4
572.76
559.26
557.55
557.03
557.83
558.19
556.61
556.00
MW-4A
572.68
nm
nm
556.98
nm
nm
nm
555.97
MW-5
613.69
nm
nm
dry
nm
nm
nm
dry
MW-6
618.57
nm
nm
583.43
nm
nm
nm
dry
MW-7
625.32
nm
nm
589.7
nm
nm
nm
587.76
MW-8
643.94
nm
nm
dry
nm
nm
nm
dry
MW-8A
643.92
nm
nm
616.79
nm
nm
nm
614.54
MW-9
650.55
nm
nm
618.92
nm
nm
nm
dry
MW-10
645.63
nm
nm
dry
nm
nm
nm
dry
MW-10A
645.41
nm
nm
607.46
nm
nm
nm
605.92
MW-11
650.17
nm
nm
621.87
nm
nm
nm
dry
MW-12
661.74
nm
nm
642.14
nm
nm
nm
640.41
MW-13
623.93
nm
nm
dry
nm
nm
nm
dry
MW-14
604.56
nm
nm
571.96
nm
nm
nm
570.19
MW-15
636.79
nm
nm
595.25
nm
nm
nm
593.45
MW-16
660.28
nm
nm
614.15
nm
nm
nm
dry
MW-18
633.37
nm
nm
dry
nm
nm
nm
dry
MW-19
649.48
nm
nm
618.53
nm
Jun
nm
617.23
MW-20
639.29
nm
nm
585.74
nm
nm
nm
583.95
MW-21
619.05
nm
nm
602.04
nm
nm
nm
601.18 '
MW-22
570.88
nm
nm
556.43
nm
nm
nm
555.60
MW-23
572.33
558.00
556.75
556.36
557.04
557.29
556.03
555.53
MW-24
635.45
nm
nm
nm
nm
nm
nm
nm
PZ-1
650.75
nm
nm
nm
nm
nm
nm
600.25
PZ-2
646.72
nm
nm
600.6
nm
nm
nm
600.15
PZ-3
663.01
nm
nm
nm
nm
nm
nm
nm
PZ-4
630.51
nm
nm
618.53
nm
nm
nm
618.56
PZ-5
647.91
nm
nm
617.55
nm
nm
nm
615.28
OPZ-1
589.62
OPZ-2
589.84
OPZ-3
616.92
RW-1
653.11
598.12
569.29
599.57
597.96
596.81
598.48
598.98
PT-01
571.66
nm
inn
556.3
nm
nm
nm
555.50
OMW-1
570.48
nm
nm
nm
nm
nm
nm
nm
OMW-2
595.04
nm
nm
573.05
nm
nm
nm
572.42
OMW-3
600.65
nm
nm
586.36
nm
nm
nm
585.93
OMW-4
581.68
nm
nm
561.97
nm
nm
nm
560.77
OMW-5
607.73
592.67
591.25
590.65
590.61
591.37
590.36
589.71
OMW-6
619.78
OMW-7
619.63
nm = not measured
Page 3 of 5

Groundwater Elevations
Dreyfus Research Park - Charlotte, NC
Well ID
Top of Casing
(ft msl)
1st
2nd
2002
3rd
4th
1st
2003
2nd
3rd
4th
EW-1
640.87
nm
nm
nm
612.27
613.68
616.07
618.65
619.31
EW-2
633.80
605.50
nm
nm
631.89
617.35
nm
nm
nm
EW-3
638.16
nm
nm
nm
637.41
637.16
nm
nm
nm
EW-4
646.54
nm
nm
nm
614.91
dry
nm
nm
nm
EW-5
646.95
nm
nm
nm
627.74
637.43
nm
nm
nm
EW-6
637.79
nm
nm
nm
nm
615.98
nm
nm
nm
EW-7
633.66
nm
nm
nm
619.58
619.10
621.91
621.31
622.03
EW-8
636.29
nm
nm
nm
612.62
614.89
nm
nm
nm
EW-9
640.85
nm
nm
nm
614.73
616.78
621.70
621.85
620.18
EW-10
643.12
593.32
nm
nm
617.34
619.97
624.66
nm
623.17
EW-11
643.65
594.10
nm
nm
618.67
621.12
nm
nm
nm
EW-12
640.51
592.96
nm
nm
598.63
599.68
nm
nm
nm
EW-13
632.93
619.28
nm
nm
591.89
592.96
nm
nm
598.12
EW-14/RW-2
643.55
612.35
nm
nm
618.19
620.61
624.77
nm
623.72
EW-15
652.99
609.69
nm
nm
616.69
618.24
620.21
nm
623.79
MW-1
571.64
555.66
555.85
555.53
555.97
556.39
nm
nm
nm
MW-2
572.72
556.72
556.94
556.32
558.99
559.04
nm
nm
nm
MW-2A
572.59
555.45
555.60
555.56
556.41
556.78
nm
nm
nm
MW-2B
572.49
555.50
555.69
555.63
556.29
556.66
nm
nm
nm
MW-3
573.39
554.64
554.86
554.77
555.29
555.41
nm
nm
nm
MW-3A
572.80
554.76
554.99
555.07
555.18
555.47
nm
nm
nm
MW-4
572.76
557.99
559.36
557.09
558.98
560.62
564.40
562.26
559.52
MW-4A
572.68
557.93
559.40
557.06
558.91
560.55
nm
nm
nm
MW-5
613.69
nm
nm
nm
nm
dry
nm
nm
nm
MW-6
618.57
nm
nm
nm
nm
583.19
nm
nm
nm
MW-7
625.32
587.57
587.81
586.96
586.94
588.70
nm
nm
nm
MW-8
643.94
nm
nm
nm
nm
dry
nm
nm
nm
MW-8A
643.92
617.85
618.73
616.41
617.54
619.90
nm
nm
nm
MW-9
650.55
nm
nm
nm
618.89
621.11
nm
nm
nm
MW-10
645.63
nm
nm
nm
nm
dry
nm
nm
nm
MW-10A
645.41
612.07
616.21
615.50
616.09
618.53
622.23
622.5
621.49
MW-11
650.17
nm
nm
nm
623.94
624.42
nm
nm
nm
MW-12
661.74
nm
nm
nm
640.15
642.23
nm
nm
nm
MW-13
623.93
nm
nm
nm
nm
dry
nm
nm
nm
MW-14
604.56
571.68
572.40
570.46
571.49
573.48
nm
nm
nm
MW-15
636.79
593.18
593.50
593.01
592.41
593.59
nm
nm
nm
MW-16
660.28
nm
nm
nm
nm
nm
nm
nm
nm
MW-18
633.37
nm
nm
nm
609.97
612.23
615.40
616.47
617.47
MW-19
649.48
nm
nm
nm
616.79
617.71
nm
nm
nm
MW-20
639.29
nm
nm
nm
581.86
582.57
nm
nm
nm
MW-21
619.05
602.20
602.67
601.45
601.96
603.40
nm
nm
nm
MW-22
570.88
557.18
557.46
556.73
558.50
559.40
nm
nm
nm
MW-23
572.33
557.08
557.36
556.54
558.18
559.26
562.10
560.10
558.02
MW-24
635.45
nm
nm
nm
nm
612.95
616.63
618.66
619.22
PZ-1
650.75
ntn
nm
nm
612.72
614.07
nm
nm
nm
PZ-2
646.72
nm
nm
nm
611.51
612.90
nm
nm
nm
PZ-3
663.01
nm
nm
nm
nm
nm
nm
nm
nm
PZ-4
630.51
nm
nm
nm
623.03
622.95
nm
run
nm
PZ-5
647.91
nm
nm
nm
618.16
620.58
nm
nm
nm
OPZ-1
589.62
nm
nm
nm
OPZ-2
589.84
nm
nm
nm
OPZ-3
616.92
nm
nm
nm
RW-1
653.11
608.08
603.51
613.20
614.48
615.88
nm
nm
nm
PT-01
571.66
nm
nm
nm
558.28
559.15
nm
nm
nm
OMW-1
570.48
nm
nm
nm
nm
nm
nm
nm
nm
OMW-2
595.04
572.77
573.47
572.43
572.78
574.48
nm
nm
nm
OMW-3
600.65
587.00
587.24
586.20
587.14
587.83
nm
nm
nm
OMW-4
581.68
562.63
563.11
561.28
563.16
564.58
rim
nm
nm
OMW-5
607.73
590.47
591.33
590.88
591.30
592.75
596.12
596.14
594.54
OMW-6
619.78
nm
nm
605.44
OMW-7
619.63
nm
nm
600.97
nm = not measured
Page 4 of 5

Groundwater Elevations
Dreyfus Research Park - Charlotte, NC
Well ID
Top of Casing
(ft ms1)
1st
2004
2nd
3rd
4th
EW-1
640.87
619.44
620.05
620.05
620.10
EW-2
633.80
612.90
nm
nm
612.13
EW-3
638.16
614.11
nm
nm
617.20
EW-4
646.54
613.96
nm
nm
613.79
EW-5
646.95
620.59
nm
nm
621.20
EW-6
637.79
621.50
622.11
621.32
622.06
EW-7
633.66
624.06
nm
nm
623.32
EW-8
636.29
618.01
nm
nm
618.11
EW-9
640.85
620.07
621.00
619.25
619.88
EW-10
643.12
623.03
nm
nm
623.06
EW-11
643.65
624.36
nm
nm
623.93
EW-12
640.51
603.77
nm
nm
602.46
EW-13
632.93
597.35
nm
nm
595.86
EW-14/RW-2
643.55
623.79
624.58
623.02
623.53
EW-15
652.99
623.93
624.49
624.47
624.50
MW-1
571.64
553.02
nm
nm
555.92
MW-2
572.72
554.48
nm
nm
557.24
MW-2A
572.59
553.07
nm
nm
555.80
MW-2B
572.49
553.18
nm
nm
555.83
MW-3
573.39
552.34
nm
nm
555.02
MW-3A
572.80
555.32
nm
nm
555.14
MW-4
572.76
556.46
559.84
559.10
558.98
MW-4A
572.68
554.15
559.73
558.99
558.90
MW-5
613.69
dry
nm
nm
579.29
MW-6
618.57
586.88
nm
nm
585.99
MW-7
625.32
593.66
nm
nm
592.64
MW-8
643.94
623.30
nm
nm
622.44
MW-8A
643.92
623.27
nm
nm
622.82
MW-9
650.55
624.46
nm
nm
624.16
MW-10
645.63
624.11
nm
nm
nm
MW-10A
645.41
621.51
621.91
619.26
621.38
MW-11
650.17
627.25
nm
nm
627.37
MW-12
661.74
646.22
nm
nm
645.11
MW-13
623.93
594.25
nm
nm
592.89
MW-14
604.56
574.27
nm
nm
573.81
MW-15
636.79
597.87
nm
nm
596.50
MW-16
660.28
nm
nm
nm
615.39
MW-18
633.37
617.53
618.44
618.28
618.43
MW-19
649.48
621.03
nm
nm
619.45
MW-20
639.29
589.95
nm
nm
587.46
MW-21
619.05
603.58
nm
nm
603.01
MW-22
570.88
555.23
nm
nm
557.87
MW-23
572.33
555.20
558.39
557.96
557.79
MW-24
635.45
619.35
620.05
619.89
620.15
PZ-1
650.75
619.73
nm
nm
nm
PZ-2
646.72
618.45
nm
nm
nm
PZ-3
663.01
nm
nm
nm
nm
PZ-4
630.51
618.61
nm
nm
nm
PZ-5
647.91
623.94
run
nm
nm
OPZ-1
589.62
573.76
nm
nm
nm
OPZ-2
589.84
574.08
nm
nm
576.52
OPZ-3
616.92
580.02
nm
nm
nm
RW-1
653.11
621.58
621.06
620.80
622.18
PT-01
571.66
555.02
nm
nm
557.67
OMW-1
570.48
nm
nm
nm
nm
OMW-2
595.04
574.37
nm
nm
574.15
OMW-3
600.65
587.64
nm
nm
nm
OMW-4
581.68
564.23
nm
nm
563.92
OMW-5
607.73
594.20
594.84
594.15
594.20
OMW-6
619.78
600.08
601.30
600.68
600.96
OMW-7
619.63
dry
605.92
605.08
604.89
nm = not measured
Page 5 of 5

Injection Calculations
Dreyfus Research Park
Charlotte, North Carolina
IW Spacing and Injection Volumes:
Initial Assumptions:
Comments:
1
Total porosity (migratory & static pore water)
0.3
2
Total injection well depth (feet)
50
3
Injection well screen interval (feet)
_ 30
4
Injection well diameter (inches)
1
5
Average depth to water (feet)
20
6
Target injection volume (gallons)
1200
Effective Radius Calculation Based on a Selected Infection Volume
Comments:
7
Injection well storage volume (gallons)
1.2
At static equilibrium
8
Ratio of injection well storage volume: total injection volume
0.001
Should be less than 0.05 to minimize
injection well storage effects
9
Radius around injection point to which injection fluid will travel due to plug flow (feet)
2.4
Accounts for storage volume of injection
well
10
Effective radius around injection point to which injection fluid will travel (feet)
6.8
Calculation developed to account for effects
of injection
11
Injection well spacing required for overlap of injection coverage (feet)
13.5
Carbon Loading Calculations:
Initial Assumptions:
Comments:
1
Effective radius around injection point to which injection fluid will travel (feet)
6.76
2
Injection well screen interval (feet)
30
3
Target injection volume (gallons)
1200
4
Total porosity (migratory & static pore water)
0.3
5
Assumed organic carbon half-life (days)
20
Typically 15 to 20 days, based on field data
from numerous sites
6
Target downgradient TOC concentration (ppm)
50
7
Target distance downgradient (days advective groundwater travel)
100
8
Groundwater velocity (feet per day)
0.129
Carbon Loading Calculations:
Comments:
9
Minimum TOC concentration around injection well immediately after injection (ppm)
1600
10
Total volume of water available for dilution (gallons)
10871
Accounts for dilution into static pore
fraction
11
Target OC loading (pounds)
145
12
Estimated injection frequency (days)
105
Based on injection radius and groundwater
flow velocity
Injection Calculations.xls
Page 1 of 1
January 2005

ARCADIS
Attachment 2
Well Data

Construction Details
Dreyfus Resarch Park
Charlotte, NC
Measurement
Point
Installation
Date
Aquifer
Total
Depth of
Borehole
Ground
Surface
(feet msl)
Top of
Casing
_ (feet msl)
Well Mateial
Screened Interval
MW-1
10/14/1991
22.5
569.14
571.64
2" Stainless Steel
12.5 to 22.5
MW-2
10/17/1991
Alluvium
20
570.17
572.72
2" Stainless Steel
10 to 20
MW-2A
10/16/1991
Saprolite
62.5
570.09
572.59
2" Stainless Steel
47 to 57
MW-2B
2/9/1993
Bedrock
104.1
569.99
572.49
2" Stainless Steel
94.1 to 104.1
MW-3
10/17/1991
Alluvium
22
570.26
573.39
2" Stainless Steel
9.5 to 19.5
MW-3A
2/23/1993
Bedrock
89
570.51
572.8
2" Stainless Steel
79 to 89
MW-4
10/18/1991
Alluvium
22.5
570.16
572.76
2" Stainless Steel
7.5 to 22.5
MW-4A
2/8/1993
Saprolite
40.5
570.23
572.68
2" Stainless Steel
34.87 to 39.87
MW-5
10/30/1991
Saprolite
37
611.12
613.69
2" Stainless Steel
25 to 35
MW-6
10/23/1991
Saprolite
47
616.49
618.57
2" Stainless Steel
28 to 38
MW-7
10/24/1991
Saprolite
37.5
623.22
625.32
2" Stainless Steel
27.5 to 37.5
MW-8
11/5/1991
Saprolite
27
641.58
643.94
2" Stainless Steel
14.9 to 24.9
MW-8A
1/27/1993
Bedrock
82.1
641.34
643.92
2" Stainless Steel
77.1 to 82.1
MW-9
10/24/1991
37.5
648.14
650.55
2" Stainless Steel
25 to 35
MW-10
11/4/1991
24.8
642.54
645.63
2" Stainless Steel
14.8 to 24.8
MW-10A
11/1/1991
Saprolite
72
642.71
645.41
2" Stainless Steel
62 to 72
MW-11
10/28/1991
Saprolite
27.5
647.4
650.17
2" Stainless Steel
17.5 to 27.5
MW-12
11/6/1991
27
662.26
661.74
2" Stainless Steel
13 to 23
MW-14
1/25/1993
Saprolite
67.
601.92
604.56
2" Stainless Steel
62 to 67
MW-15
1/26/1993
Saprolite
57
634.22
636.79
2" Stainless Steel
52 to 57
MW-16
5/15/1993
Saprolite
45
657.64
660.28
2" Stainless Steel
39 to 44
MW-18
1/28/1993
Saprolite
29.5
630.98
633.37
2" Stainless Steel
18.5 to 28.5
MW-19
2/2/1993
Saprolite
32
647.04
649.48
2" Stainless Steel
21.75 to 31.75
MW-20
2/25/1993
60
636.87
639.29
2" Stainless Steel
46 to 56
MW-21
8/8/1994
Saprolite
41
616.62
619.05
2" Stainless Steel
30.4 to 40.4
MW-22
8/7/1994
Saprolite
28.8
568.4
570.88
2" Stainless Steel
17.3 to 27.3
MW-23
8/6/1994
37.8
569.27
572.33
2" Stainless Steel
27.4 to 37.4
MW-24
1/22/2003
Bedrock
69
635.45
6" Open Borehole
38 to 69
OMW-1
8/10/1994
Saprolite
29.6
570.81
570.48
2" Stainless Steel
18.5 to 28.5
OMW-2
8/22/1994
Saprolite
34.6
595.18
595.04
2" Stainless Steel
24.5 to 34.5
OMW-3
8/9/1994
Saprolite
24
601.03
600.65
2" Stainless Steel
13.2 to 23.2
OMW-4
8/17/1994
Saprolite
70
581.98
581.68
2" Stainless Steel
59.8 to 69.8
OMW-5
8/23/1994
Saprolite
30.9
608.17
607.73
2" Stainless Steel
20.6 to 30.6
OMW-6
10/15/2003
Saprolite
15.5
619.78
2" Sch. 80 PVC
5.5 to 15.5
OMW-7
10/17/2003
Bedrock
81
619.63
6" Open Borehole
20.5 to 81
PT-01
8/6/1994
,Saprolite
36.9
569.57
571.66
4" PVC
14.9 to 34.9
PZ-1
Saprolite
55
650.75
PZ-2
Saprolite
50
646.72
PZ-3
2/3/1993
Saprolite
34
660.5
663.01
2" Stainless Steel
23.97 to 32.99
PZ-4
Saprolite
10
630.51
PZ-5
647.91
OPZ-1
8/13/2003
Saprolite
20
589.62
2" Sch. 80 PVC
10 to 20
OPZ-2
8/14/2003
Bedrock
35
589.84
6" Open Borehole
25 to 35
OPZ-3
10/16/2003
Saprolite
40
616.92
2" Sch. 80 PVC
30 to 40
RW-01
8/25/1994
Bedrock
103.1
650.54
653.11
2" Stainless Steel
90 to 100
G:\ENV\DRP\Permits\UIC Permit\Final\Well Construction Details.xls Page 1 of 2
January 2005

Construction Details
Dreyfus Resarch Park
Charlotte, NC
Measurement
Point
Installation
Date
Aquifer
Total
Depth of
Borehole
Ground
Surface
(feet msl)
Top of
Casing
(feet msl)
Well Mateial
Screened Interval
RW-02
9/13/1994
Bedrock
87.8
643.35
643.55
6" PVC
77 to 87
EW-1
Feb-94
Saprolite
36.2
640.87
EW-2
Feb-94
Saprolite
35.8
633.80
EW-3
Feb-94
Saprolite
30
638.16
EW-4
Feb-94
Saprolite
34.6
646.54
EW-5
Feb-94
Saprolite
60
646.95
EW-6
Feb-94
Saprolite
32
637.79
EW-7
Feb-94
Saprolite
25.2
633.66
EW-8
Feb-94
Saprolite
26.5
636.29
EW-9
Feb-94
Saprolite
34.8
640.85
EW-10
Feb-94
Saprolite
75.5
643.12
EW-11
Feb-94
Saprolite
61.5
643.65
EW-12
Feb-94
Saprolite
54.4
640.51
EW-13
Feb-94
Saprolite
48.5
632.93
EW-14/RW-02
9/13/1994
Bedrock
87.8
643.35
643.55
6" PVC
77 to 87
EW-15
652.99
Note: Limited data are available for many wells at this Site.
G:\ENV\DRP\Permits\UIC Permit\Final\Well Construction Details.xls Page 2 of 2 January 2005

ARCAD1S
Attachment 3
Injection Related
Equipment

V201
£yiu
TANKER TRUCK
6000 GALLONS
1i" FLEX HOSE
[ t%< Z DPT1
V401
[ Z DPT2
V401
[ Z DPT3
V401
[ t%J Z DPT4
V401
PORTABLE MANIFOLD
-{--TO DPT
INJECTION
FLUID FLOW
NOTE: DPT TOOLING WILL BE RAISED THROUGHOUT INJECTION PROCESS
APPROXIMATELY 40 GALLONS OF CARBOHYDRATE REAGENT WILL
BE INJECTED PER VERTICAL FOOT OF SATURATED ZONE.
LEGEND
BALL VALVE
PRESSURE INDICATOR
TOTALIZING FLOW METER
CAM —LOCK FfTTING
ARCAD1S
420 Park Avenue
Greenville. SC 29601
Tel: [phone] Fax: [phone]
www.arcadis—us.cam
PRJT MANAGER.
E. RHINE
CHECKED BY:
E. RHINE
DRAWING. pID3
PRJT N0. GS028605.0002
DVG DATE:
01JAN 05
DRAFTER:
D. MOON
PIPING AND INSTRUMENTATION DIAGRAM
REAGENT INJECTION
DREYFUS RESEARCH PARK
CHARLOTTE, NORTH CAROLINA
FIGURE:
4-2

ARCADIS
Attachment 4
Location of Wells

200 100 0 200 400 600 800
Feet
Legend
10ft Contours
Streets
Waterways
Site Property Boundary
Buildings
Water Bodies
Client: CNA - DRP
Project Number: GS028605.0001.00003
Project Manager: E. Rhine
Cartography By: T. Gore
Date: 01/13/2005
Site Map
Celanese Acetate LLC
Dreyfus Research Park
Charlotte, North Carolina
FIGURE:
N1
G:\GIS\MAPPING\ENV_CNA_DRP\ArcGIS\2005\20050113_VIC_Permit\20050113_Fig_N1 _Site_10ftContours.mxd

200 100 0
200
400
600
800
Feet
Legend
Saprolite Bedrock
• • Monitoring Well
• • Extraction Well
0 • Piezometer
• Pump Test Well
• Recovery Well
A Surface Water
Buildings
Client: CNA - DRP
Project Number: GS028605.0001.00003
Project Manager: E. Rhine
Cartography By: T. Gore
Date: 01/13/2005
G:IGISWIAPPING\ENV CNA_DRPWrcGISt2005\20050113_VIC_Permit\20050113_Fig_N2_MonitoringWell.mxd
Monitoring Well Locations
Celanese Acetate LLC
Dreyfus Research Park
Charlotte, North Carolina
FIGURE:
N2

300
150
0
Feet
300
600
Client: CNA - DRP
Project Number: GS028605.0001
Project Manager: E. Rhine
Cartography By: T. Gore
Date: 01/13/2005
G:\GI S\MAPPING\ENV_CNA_DRP1ArcG I S\2005\20050113_V IC_Penni t\20050113_Fig_N3_DechConceptualLayout mxd
• Proposed DPT Injection points (Phaset)
Proposed Shallowlnjection/Fracture Well
0 Proposed Deep Injection/Fracture Well
Existing Extraction Well
Existing Monitoring Well
Existing OS Monitoring Well
Existing Offsite Piezometer
Existing Piezomeler
Existing Recovery Well
Existing Temporary Sample Location
VOC Groundwater Isoconcentration (5 mg/I)
100 Foot BufferAround Plume
r-771 Buildings
Note: Proposed DPT and Injection well locations
are approximated. Actual locations depend
on field conditions.
Enhanced Reductive
Dechlorination Conceptual Layout
Celanese Acetate LLC
Dreyfus Research Park
Charlotte, North Carolina

59 - 3
�"` 617 E
,a 1. -- EN�2 ✓� P2 f;f/ 62-' 6 W-7!
r�81213 (62334,1.
P2 21 1;I%24,
ii
rEVJ:5{ Mw_101 6235314 ,
621 2 EC, _
- ♦ 620I. a.'PZ 4t (Ew-Z1 MWq1
EVV- : t61 a-I1 0.6I737
- M -0-0 62M 206 WY } x IEw 10; -
•;MNL9
62306, O162418
5942 - `7F.Prr. 619
��~ _ •• -. - - ._... _. SEW-'i} LjPZ3,
L'W',,.,. rye'-
557 791
MYua0
5s7141 ,� 55091
MW-227
67 I
PT11 4AL,Aj MW-2E1
,e2. (536.1 55563,
P74
t 1 ARCADIS
(trip Supr,Cte'
Client: CNA - DRP
Project Number: GS028605.0001.00003
Project Manager: E. Rhine
Cartography By: T. Gore
Date: 01/13/2005
Legend
Saprolite Bedrock
• • Monitoring Well
Extraction Well
• Piezometer
Saprolite Potentiometric
Contour (ft. MSL) - 4Q04
Saprolite Potentiometric
Contour (ft. MSL) (Inferred)
• Recovery Well
0 Surface Water
I Buildings
Potentiometric Surface of the
Shallow Aquifer
October 2004
Celanese Acetate LLC
Dreyfus Research Park
Charlotte, North Carolina
G:IGISWIAPPI NG1EN V_CNA_DRP W cGI 512005120050113_VIC_Pemlit120050121_Fig_N4_PotentiometricSurface_ShallowAquifer. mxd
FIGURE:

Client: CNA - DRP
Project Number: GS028605.0001
Project Manager: E. Rhine
Cartography By: T. Gore
Date: 01/13/2005
G:\GIS\MAPPING\ENV_CNA_DRPVarcG IS\2005{20050113_VIC_Permit\20050121_Fig_N5_PCEConcentrations. mxd
• Extraction Well
Monitoring Well
OS Monitoring Well
Offsite Piezometer
Piezometer
Recovery Well
Surface Water
• Temporary Sample Location
Saprolite Potentiometric Contour (ft. MSL)
Saprolite Potentiometric Contour (ft. MSL) (Inferred)
t_._—`{ Buildings
PCE Concentrations (mg/L)
in Groundwater
October 2004
Celanese Acetate LLC
Dreyfus Research Park
Charlotte, North Carolina

TCE � 00L
1TW16
�IOOh _�`TW02� EW'15�
TCE 0.0014
TCE <0'001
TCE<0001:
TCE,<0.001, 1TCE 0.005
`TCE0024
.TCE <0001
EWE-
iTCq0037/-
IEw
,.. - :MW.18a
fro 07032_,
:OPZ-2
TCE <0.001
300 150
MW-12
PCE<0.001
TCE <0 001
:TCE 0 0073
TCE 0.0015
.PZ'3•
MW-11
- TCE <0.001
TCE 0.0082
MW: OAy
TCE 0.0092;
MWW$I. TCE 0 0011
ONW-2',
<TCE <0,00_11
TributaryA'6Vicstream?
EW-10)
TCE0,0083'
Area 2
TCE 0:0014
Area 1
.TCEr<00011
♦'� iMWJ is
�� ;TCE 00 co ♦ MVJJAr
MW'021 0 . 00071-
iTCE021 �
MW 14�,-- 1 I SOS 1 -
TCE <0_OOPr - -,MW-0A f MW-23 i MW-2'
TCE.�.001% •/TCE 0 03 TCE <0�002
TCE 0.0055 - BMW-2B,
f 1
•7
ARCAD1S
Client: CNA - DRP
Project Number: GS028605.0001
Project Manager: E. Rhine
Cartography By: T. Gore
Date: 01 / 13/2005
Sugar Cieek,Ups'tream, -
G:\GIS\MAPPING\ENV_CNA_DRP\ArcGIS\2005\20050113_VIC_Permit\20050121_Fig_N6_TCEConcentrations mxd
Legend
• Extraction Well
▪ Monitoring Well
• OS Monitoring Well
O Offsite Piezometer
O Piezometer
• Recovery Well
A Surface Water
• Temporary Sample Location
I I Buildings
Saprolite Potentiometric Contour (ft. MSL)
Saprolite Potentiometdc Contour (ft. MSL) (Inferred)
TCE Concentrations (mg/L)
in Groundwater
October 2004
Celanese Acetate LLC
Dreyfus Research Park
Charlotte, North Carolina
FIGURE:

r \
'
\\
c.. \ \ ` 7�\. `..
/
..1
,// /
` /
ij
/f i
/ +/ r/
/ /
csm.w-5� 1 j rJk
• rUF I_.-�,._
f
�7\ \ ,\V
S��/;l \�V\z1-d
J/w-2� \s\\\/
.
f./` j
M/
RLACF-
I // I
•(
%'E
/f
RW717 �J1\
V.- -- -
«/-
1' �Gt7#,0\V
- ‘: :Jilt _
J •/A'k
/§ e
0y{o \✓ Q,
• .
7 \
Its'
if
r
:);/r/
\ jh4Vi
`� /y J 4, \./
�YJa
—.
�,
C
'iJEER 1�47U r
, MVP,'tr---
-
h',-
'\
Pi lwo.�
ccZ
`,�; \r�r:';:.-
-ice,..
1
I023c
r \ `��\
w i-.-,, --.'\\_'''\
— ram,, ;-�,5,�,'••••-.
S "\,,, c;'
\ .\--/______,____i_jj
JJI
.�-•,, y
1./.14,/, ( i e /
PLAN VIEW
ARCADIS
420 Park Ave.
Greenville, South Carolina 29601
Tel, 864/242-1717 Fax, 864/235-9062
PRJT MAN:
E. RHINE
CKD BY:
E. RHINE
DRAWING:
PRJT NO:
GS028605.0002
DWG DATE:
5JAN 05
DRAFTER:
D. MOON
CROSS SECTION — PLAN VIEW
DREYFUS RESEARCH PARK
CHARLOTTE, NORTH CAROLIVA
FIG -NO
7

A
SOUTHEAST
680
660
640
620
610
600
590
580
570
560
550
540
530
520
NA
NA
1.92 ftidaY
_1 LEGEND
- /COLLUVIUM - MAY INCLUDE
G .1• `•1:`T NA ILT, SILT, CLAYEY AND SILT
x.xxxxx.::I :.I_• !..I':II0.23 ft
• . : I.
•e.xxrxxx<x.• I•'.1;•1'•�1.1; ):
x.xxxxxxxxx.i1; '� 1. 1' '•!
xxxxxxxxxx.. I:.i: I-i' -I,•
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.„xxxxxxxxxxx
•xxxY.Nxx,xx.`
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BEEN AND BENTONITE SEAL
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IAILTY NOVEMBER, 2004
ILLIGRAMS PER LITER (mg/L)
LLIGRAMS PER LITER (mg/L)
CONDUCTIVITY (FT/DAY)
ANALYZED
DATED VALUE
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r CALCULATED
ARCADIS
P.O. BOX 1717 Greenville, SC 29607-1717
420 Park Ave. Greenville, SC 29601-2257
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N S SECTION A —A
rfib RESEARCH PARK
REE, NORTH CAROLINA
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ARCADIS
Attachment 5
NPDES Permit

NPDES Permit No. NC0084301
RECRI
JAN 2 1200
STATE OF NORTH CAROLINA '4 R E�i c
DEP
ARTMENT OF ENVIRONMENT AND NATURAL RESOURC
DIVISION OF WATER QUALITY
PERMIT
TO DISCHARGE WASTEWATER UNDER THE
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
(NPDES)
In compliance with the provision of North Carolina General Statute 143-215.1, other lawful standards
and regulations promulgated and adopted by the North Carolina Environmental Management
Commission, and the Federal Water Pollution Control Act, as amended,
Celanese Acetate, LLC
is hereby authorized to discharge wastewater from a facility located at
Dreyfus Research Park
2300 Archdale Drive, Charlotte
Mecklenburg County
to receiving waters designated as Little Sugar Creek within the Catawba River Basin,
in accordance with effluent limitations, monitoring requirements, and other
conditions set forth in Parts I, II, III and IV hereof.
This permit shall become effective November 1, 2001
This permit and authorization to discharge shall expire at midnight on July 31, 2005.
Signed this day September 26, 2001
taa"
regory J. Thorp€, Ph. i Acting Director
Division of Water Quality
By Authority of the Environmental Management Commission

NPDES Permit No. NC0084301
SUPPLEMENT TO PERMIT COVER SHEET
Celanese Acetate, LLC
is hereby authorized:
1. to operate the existing 0.1152 MGD groundwater remediation system consisting of a
• one (1) equalization storage tank
• one (1) six -tray air stripper
• one (1) activated carbon filter
• one (1) filter bag
located at, Dreyfus Research Park, 2300 Archdale Drive, Charlotte, Mecklenburg County;
and
2. to discharge treated wastewater from said treatment facility through Outfall 001 to
Little Sugar Creek (see attached map), a stream classified as C waters within the
Catawba River Basin.

Celanese Acetate, LLC
Groundwater Treatment System
Latitude 35° 08' 22" N
Laogtude 80° 51' 42" W
Receiving Stream: Little Sugar Cieek
StreamClass C
StateGridgvad: G 15 NE/ Chaiiotte, East
Permitted Flow: 0.1152 MGD
Drainage Barn: Catawba River Basin
Sub -Basin 03-08-34
NPDES Permit No. NC0084301
Mecklenburg County

NPDES Permit NC0084301
A. (L) - EkIeLUENT LIMITATIONS AND MONITORING REQUIREMENTS
Beginning with the permit renewal date and lasting until expiration, the Permittee is authorized to discharge
treated wastewater from Outfall 001. Such discharges shall be limited and monitored by the Permittee as
specified below:
zIFELt s
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Sample
a
�r
Flow
0.1152 MGD
Continuous
Recording
I or E
Trichloroethene (TCE)
Monthly
Grab
E
Tetrachloroethene (PCE)
Monthly
Grab
E .
pH2
Monthly
Grab
E
Chronic Toxicity3
Quarterly
Composite
E
Footnotes:
1. Sample Locations: E — effluent; I — Influent
2. pH shall not fall below 6.0 nor exceed 9.0 standard units.
3. Chronic Toxicity (Ceriodaphnia) P/F @ 4.9 %; February, May, August, November [See A. (2.)].
Units: MGD = million gallons per day
Facility discharge shall not contain floating solids or foam visible in other than trace amounts.
Additional Special Conditions apply to this permit [see A. (2.)].

NPDES .Permit NC0084301
EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
SPECIAL CONDITION : .
A. (2.) CHRONIC TOXICITY PERMIT LIMIT (QRTRLY)
The effluent discharge shall at no time exhibit observable inhibition of reproduction or significant mortality to Ceriodaphnia
dubia at an effluent concentration of 4.9 %.
The permit holder shall perform at a minimum, quarterly monitoring using test procedures outlined in the "North Carolina
Ceriodaphnia Chronic Effluent Bioassay Procedure," Revised February 1998, or subsequent versions or "North Carolina
Phase II Chronic Whole Effluent Toxicity Test Procedure" (Revised -February 1998) or subsequent versions. The tests will be
performed during the months of February, May, August, November. Effluent sampling for this testing shall be
performed at the NPDES permitted final effluent discharge below all treatment processes.
If the test procedure performed as the first test of any single quarter results in a failure or ChV below the permit
limit, then multiple -concentration testing shall be performed at a minimum, in each of the two following months as
described in "North Carolina Phase II Chronic Whole Effluent Toxicity Test Procedure" (Revised -February 1998) or
subsequent versions.
The chronic value for multiple concentration tests will be determined using the geometric mean of the highest concentration
having no detectable impairment of reproduction or survival and the lowest concentration that does have a detectable
impairment of reproduction or survival. The definition of "detectable impairment," collection methods, exposure regimes,
and further statistical methods are specified in the "North Carolina Phase II Chronic Whole Effluent Toxicity Test Procedure"
(Revised -February 1998) or subsequent versions.
All toxicity testing results required as part of this permit condition will be entered on the Effluent Discharge Monitoring Form
(MR-1) for the months in which tests were performed, using the parameter:cpde TGP3B for the pass/fail results and THP3B y
for the Chronic Value. Additionally, DWO'Foi-in.AT-3 (original) is'' -to be'$ent to the following address
Attention:
Environmental Sciences Brandh
North Carolina Division of Water Quality
1621 Mail Service Center;,
Raleigh, North Carolina 27699-1621 •
Completed Aquatic Toxicity Test Forms shall be filed with the Environmental Sciences Branch no later than 30 days after the
end of the reporting period for which the report is made.
Test data shall be complete, accurate, include all supporting chemical/physical measurements and all concentration/response
data, and be certified by laboratory supervisor and ORC or approved designate signature. Total residual chlorine of the
effluent toxicity sample must be measured and reported if chlorine is employed for disinfection of the waste stream.
Should there be no discharge of flow from the facility during a month in which toxicity monitoring is required, the permittee
will complete the information located at the top of the aquatic toxicity (AT) test form indicating the facility name, permit
number, pipe number, county, and the month/year of the report with the notation of "No Flow" in the comment area of the
form. The report shall be submitted to the Environmental Sciences Branch at the address cited above.
Should the permittee fail to monitor during a month in which toxicity monitoring is required, monitoring will be required
during the following month.
Should any test data from this monitoring requirement or tests performed by the North Carolina Division of Water Quality
indicate potential impacts to the receiving stream, this permit may be re -opened and modified to include alternate monitoring
requirements or limits.
NOTE: Failure to achieve test conditions as specified in the cited document, such as minimum control organism
survival, minimum control organism reproduction, and appropriate environmental controls, shall constitute an
invalid test and will require immediate follow-up testing to be completed no later than the last day of the month
following the month of the initial monitoring.

PART I
(continued)
Section B. Schedule of Compliance
1. The permittee shall comply with Final Effluent Limitations specified for discharges in accordance with
the following schedule:
Permittee shall comply with Final Effluent Limitations by the effective date of the permit unless
specified below.
2. Permittee shall at all times provide the operation and maintenance necessary to operate the existing
facilities at optimum efficiency.
3. No later than 14 calendar days following a date identified in the above schedule of compliance, the
permittee shall submit either a report of progress or, in the case of specific actions being required by
identified dates, a written notice of compliance or noncompliance. In the latter case, the notice shall
include the cause of noncompliance, any remedial actions taken, and the probability of meeting the next
schedule requirements.

PART II
STANDARD CONDITIONS FOR NPDES PERMITS
SECTION A. DEFINITIONS
1. Permit Issuing Authority: The Director of the Division of Water Quality.
2. DEM or "the Division" Means the Division of Water Quality, Department of Environment and Natural
Resources.
3. EMC Used herein means the North Carolina Environmental Management Commission.
4. Act or "the Act" The Federal Water Pollution Control Act, also known as the Clean Water Act, as amended,
33 USC 1251, et. seq.
5. Mass/Day Measurements
a. The "monthly average discharge" is defined as the total mass of all daily discharges sampled and/or measured
during a calendar month on which daily discharges are sampled and measured, divided by the number of daily
discharges sampled and/or measured during such month. It is therefore, an arithmetic mean found by
adding the weights of the pollutant found each day of the month and then dividing this sum by the number
of days the tests were reported. The limitation is identified as "Monthly Average" in Part I of the permit.
b. The "weekly average discharge" is defined as the total mass of all daily discharges sampled and/or measured
during the calendar week (Sunday - Saturday) on which daily discharges are sampled and measured, divided
by the number of daily discharges sampled and/or measured during such week. It is, therefore, an arithmetic
mean found by adding the weights of pollutants found each day of the week and then dividing this sum by
the number of days the tests were reported. This limitation is identified as "Weekly Average" in Part I of the
permit.
c. The "maximum daily discharge" is the total mass (weight) of a pollutant discharged during a calendar day. If
only one sample is taken during any calendar day the weight of pollutant calculated from it is the "maximum
daily discharge." This limitation is identified as "Daily Maximum," in Part I of the permit.
d. The "average annual discharge" is defined as the total mass of all daily discharges sampled and/or measured
during the calendar year on which daily discharges are sampled and measured, divided by the number of daily
discharges sampled and/or measured during such year. It is, therefore, an arithmetic mean found by adding
the weights of pollutants found each day of the year and then dividing this sum by the number of days the
tests were reported. This limitation is defined as "Annual Average" in Part I of the permit.
6. Concentration Measurement
a. The "average monthly concentration," other than for fecal coliform bacteria, is the sum of the concentrations
of all daily discharges sampled and/or measured during a calendar month on which daily discharges are
sampled and measured, divided by the number of daily discharges sampled and/or measured during such
month (arithmetic mean of the daily concentration values). The daily concentration value is equal to the
concentration of a composite sample or in the case of grab samples is the arithmetic mean (weighted by flow
value) of all the samples collected during that calendar day. The average monthly count for fecal coliform
bacteria is the geometric mean of the counts for samples collected during a calendar month. This limitation
is identified as "Monthly Average" under "Other Limits" in Part I of the permit.

Part II
Page 2of11
6. b. The "average weekly concentration," other than for fecal coliform bacteria, is the sum of the concentrations
of all daily discharges sampled and/or measured during a calendar week (Sunday/Saturday) on which daily
discharges are sampled and measured divided by the number of daily discharges sampled and/or measured
during such week (arithmetic mean of the daily concentration values). The daily concentration value is equal
to the concentration of a composite sample or in the case of grab samples is the arithmetic mean (weighted
by flow value) of all the samples collected during that calendar day. The average weekly count for fecal
coliform bacteria is the geometric mean of the counts for samples collected during a calendar week. This
limitation is identified as "Weekly Average" under "Other Limits" in Part I of the permit.
c. The "maximum daily concentration" is the concentration of a pollutant discharge during a calendar day. If
only one sample is taken during any calendar day the concentration of pollutant calculated from it is the
"Maximum Daily Concentration". It is identified as "Daily Maximum" under "Other Limits" in Part I of the
• permit.
d. The "average annual concentration," other than for fecal coliform bacteria, is the sum of the concentrations
of all daily discharges sampled and/or measured during a calendar year on which daily discharges are sampled
and measured divided by the number of daily discharges sampled and/or measured during such year
(arithmetic mean of the daily concentration values). The daily concentration value is equal to the
concentration of a composite sample or in the case of grab samples is the arithmetic mean (weighted by flow
value) of all the samples collected during that calendar day. The average yearly count for fecal coliform
bacteria is the geometric mean of the counts for samples collected during a calendar year. This limitation is
identified as "Annual Average" under "Other Limits" in Part I of the permit.
e. The "daily average concentration" (for dissolved oxygen) is the minimum allowable amount of dissolved
oxygen required to be available in the effluent prior to discharge averaged over a calendar day. If only one
dissolved oxygen sample is taken over a calendar day, the sample is considered to be the "daily average
concentration" for the discharge. It is identified as "daily average" in the text of Part I.
f. The "quarterly average concentration" is the average of all samples taken over a calendar quarter. It is
identified as "Quarterly Average Limitation" in the text of Part I of the permit.
g. A calendar quarter is defined as one of the following distinct periods: January through March, April through
June, July through September, and October through December.
7. Other Measurements
a. Flow, (MGD): The flow limit expressed in this permit is the 24 hours average flow, averaged monthly. It is
determined as the arithmetic mean of the total daily flows recorded during the calendar month.
b. An "instantaneous flow measurement" is a measure of flow taken at the time of sampling, when both the
sample and flow will be representative of the total discharge.
c. A "continuous flow measurement" is a measure of discharge flow from the facility which occurs continually
without interruption throughout the operating hours of the facility. Flow shall be monitored continually
except for the infrequent times when there may be no flow or for infrequent maintenance activities on the
flow device.
8. Types of Samples
a. Composite Sample: A composite sample shall consist of:
(1) a series of grab samples collected at equal time intervals over a 24 hour period of discharge and
combined proportional to the rate of flow measured at the time of individual sample collection, or

Part II
Page 3of11
8. a. (2) a series of grab samples of equal volume collected over a 24 hour period with the time intervals between
samples determined by a preset number of gallons passing the sampling point. Flow measurement
between sample intervals shall be determined by use of a flow recorder and totalizer, and the present
gallon interval between sample collection fixed at no greater than 1/24 of the expected total daily flow at
the treatment system, or
(3) a single, continuous sample collected over_a 24-hour period proportional to the rate of flow.
In accordance with (1) above, the time interval between influent grab samples shall be no greater than
once per hour, and the time interval between effluent grab samples shall be no greater than once per hour
except at wastewater treatment systems having a .detention time of greater than 24 hours. In such cases,
effluent grab samples may be collected at time intervals evenly spaced over the 24-hour period which are
equal in number of hours to the detention time of the system in number of days. However, in no case
may the time interval between effluent grab samples be greater than six (6) hours nor the number of
samples less than four (4) during a 24-hour sampling period.
b. Grab Sample: Grab samples are individual samples collected over a period of time not exceeding 15 minutes;
the grab sample can be taken manually. Grab samples must be representative of the discharge or the
receiving waters.
9. Calculation of Means
a Arithmetic Mean: The arithmetic mean of any set of values is the summation of the individual values divided
by the number of individual values.
b. Geometric Mean: The geometric mean of any set of values is the Nth root of the product of the individual
values . where N is equal to the numberofindividual values.. The geometric mean is equivalent to the antilog
of.the.arithmetic.mean of the -logarithms- of -the individual values. For -purposes of calculating the geometric
mean, values of zero (0) shall be considered to be one (1).
c. Weighted by Flow Value: Weighted by flow value means the summation of each concentration times its
respective flow divided by the summation of the respective flows.
10. Calendar Day: A calendar day is defined as the period from midnight of one day until midnight of the next day.
However, for purposes of this permit, any consecutive 24-hour period that reasonably represents the calendar day
may be used for sampling.
11. Hazardous Substance: A hazardous substance means any substance designated under 40 CFR Part 116
pursuant to Section 311 of the Clean Water Act.
12. Toxic Pollutant: A toxic pollutant is any pollutant listed as toxic under Section 307(a)(1) of the Clean
Water Act.
SECTION B. GENERAL CONDITIONS
1. Duty to Comply
The permittee must comply with all conditions of this permit. Any permit noncompliance constitutes a violation
of the Clean Water Act and is grounds for enforcement action; for permit termination, revocation and reissuance,
or modification; or denial of a permit renewal application.
a. The permittee shall comply with effluent standards or prohibitions established under section 307(a) of the
Clean Water Act for toxic pollutants and with standards for sewage sludge use or disposal established under
section 405(d) of the Clean Water Act within the time provided in the regulations that establish these
standards or prohibitions or standards for sewage sludge use or disposal, even if the permit has not yet been
modified to incorporate the requirement.

Part II
Page 4of11
1. b. The Clean Water Act provides that any person who violates a permit condition is subject to a civil penalty
not to exceed $25,000 per day for each violation. Any person who negligently violates any permit condition
is subject to criminal penalties of $2,500 to $25,000 per day of violation, or imprisonment for not more than
1 year, or both. Any person who knowingly violates permit conditions is subject to criminal penalties of
$5,000 to $50,000 per day of violation, or imprisonment for not more than 3 years, or both. Also, any person
who violates a permit condition may be assessed an administrative penalty not to exceed $10,000 per
violation with the maximum amount not to exceed $125,000. [Ref: Section 309 of the Federal Act 33 U.S.C.
1319 and 40 CFR 122.41 (a)]
c. Under state law, a civil penalty of not more than ten thousand dollars ($10,000) per violation may be assessed
against any person who violates or fails to act in accordance with the terms, conditions, or requirements of a
permit. [Ref: North Carolina General Statutes § 143-215.6A]
d. Any person may be assessed an administrative penalty by the Administrator for violating section 301, 302,
306, 307, 308, 318, or 405 of the Act, or any permit condition or limitation implementing any of such
sections in a permit issued under section 402 of the Act. Administrative penalties for Class I violations are
not to exceed $10,000 per violation, with the maximum amount of any Class I penalty assessed not to exceed
$25,000. Penalties for Class II violations are not to exceed $10,000 per day for each day during which the
violation continues, with the maximum amount of any Class II penalty not to exceed $125,000.
2. Duty to Mitigate
The permittee shall take all reasonable steps to minimize or prevent any discharge or sludge use or disposal in
violation of this permit which has a reasonable likelihood of adversely affecting human health or the
environment.
3. Civil and Criminal Liability
Except ,as .provided in permit conditions on "Bypassing" (Part II, C-4) and "Power Failures" (Part II, C-7),
nothing in this permit shall be construed to relieve the permittee from any responsibilities, liabilities, or penalties
for noncompliance pursuant to NCGS 143-215.3, 143-215.6 or Section 309 of the Federal Act, 33 USC 1319.
Furthermore, the permittee is responsible for. consequential damages, such as fish kills, even though the
responsibility for effective compliance may be temporarily suspended.
4. Oil and Hazardous Substance Liability
Nothing in this permit shall be construed to preclude the institution of any legal action or relieve the permittee
from any responsibilities, liabilities, or penalties to which the permittee is or may be subject to under NCGS 143-
215.75 et seq. or Section 311 of the Federal Act, 33 USG 1321. Furthermore, the permittee is responsible for
consequential damages, such as fish kills, even though the responsibility for effective compliance may be
temporarily suspended.
5. Property Rights
The issuance of this permit does not convey any property rights in either real or personal property, or any
exclusive privileges, nor does it authorize any injury to private property or any invasion of personal rights, nor
any infringement of Federal, State or local laws or. regulations.
6. Onshore or Offshore Construction
This permit does not authorize or approve the construction of any onshore or offshore physical structures or
facilities or the undertaking of any work in any navigable waters.
7. Severability
The provisions of this permit are severable, and if any provision of this permit, or the application of any
provision of this permit to any circumstances, is held invalid, the application of such provision to other
circumstances, and the remainder of this permit, shall not be affected thereby.

Part II
Page 5of11
8. Duty to Provide Information
The permittee shall furnish to the Permit Issuing Authority, within a reasonable time, any information which the
Permit Issuing Authority may request to determine whether cause exists for modifying, revoking and reissuing, or
terminating this permit or to determine compliance with this permit. The permittee shall also furnish to the
Permit Issuing Authority upon request, copies of records required to be kept by this permit.
9. Duty to Reapply
If the permittee wishes to continue an activity regulated by this permit after the expiration date of this permit, the
-. permittee mustapply for and obtain a new permit.
10. Expiration of Permit
The permittee is not authorized to discharge after the expiration date. In order to receive automatic authorization
to discharge beyond the expiration date, the permittee shall submit such information, forms, and fees as are
required by the agency authorized to issue permits no later than 180 days prior to the expiration date. Any
permittee that has not requested renewal at least 180 days prior to expiration, or any permittee that does not have
a permit after the expiration and has not requested renewal at least 180 days prior to expiration, will subject the
permittee to enforcement procedures as provided in NCGS 143-215.6 and 33 USC 1251 et. seq.
11. Signatory Requirements
All applications, reports, or information submitted to the Permit Issuing Authority shall be signed and certified.
a. All permit applications shall be signed as follows:
(1) For_ a corporation: by a responsible corporate officer. For the purpose of this Section, a responsible
corporate officer means: (a) a president, secretary, treasurer or vice president of the corporation in
• charge of a principal business function, or any other person who performs similar policy or decision
making functions for the .corporation, or • (b) the manager. of one .or more manufacturing production or
operating facilities employing more than. 250 persons _ or • having gross .annual.. -sales or expenditures
::•exceeding 25;million _(in second:quarter 1980; dollars);:if authority to:sign'documents has been assigned or
delegated to the manager in accordance with corporate procedures.
(2) For a partnership or sole proprietorship: by a general partner or the proprietor, respectively; or
(3) For a municipality, State, Federal, or other public agency: by either a principal executive officer or ranking
elected official.
b. All reports required by the permit and other information requested by the Permit Issuing Authority shall be
signed by a person described above or by a duly authorized representative of that person. A person is a duly
authorized representative only if:
(1) The authorization is made in writing by a person described above;
(2) The authorization specified either an individual or a position having responsibility for the overall
operation of the regulated facility or activity, such as the position of plant manager, operator of a well or
well field, superintendent, a position of equivalent responsibility, or an individual or position having
overall responsibility for environmental matters for the company. (A duly authorized representative may
thus be either a named individual or any individual occupying a named position.); and
(3) The written authorization is submitted to the Permit Issuing Authority.
c. Certification. Any person signing a document under paragraphs a. or b. of this section shall make the
following certification:
"I certify, under penalty of law, that this document and all attachments were prepared under my direction or
supervision in accordance with a system designed to assure that qualified personnel properly gather and
evaluate the information submitted. Based on my inquiry of the person or persons who manage the system,
or those persons directly responsible for gathering the information, the information submitted is, to the best
of my knowledge and belief, true, accurate, and complete. I am aware that there are significant penalties for
submitting false information, including the possibility of fines and imprisonment for knowing violations."

Part II
Page 6of11
12. Permit Actions
This permit may be modified, revoked and reissued, or terminated for cause. The filing of a request by the
permittee for a permit modification, revocation and reissuance, or termination, or a notification of planned
changes or anticipated noncompliance does not stay any permit condition.
13. Permit Modification, Revocation and Reissuance, or Termination
The issuance of this permit does not prohibit the permit issuing authority from reopening and modifying the
permit, revoking and reissuing the permit, or terminating the permit as allowed by the laws, rules, and regulations
contained in Title 40, Code of Federal Regulations, Parts 122 and 123; Title 15A of the North Carolina
Administrative Code, Subchapter 2H .0100; and North Carolina General Statute 143-215.1 et. al.
14. Previous Permits
All previous National Pollutant Discharge Elimination System Permits issued to this facility, whether for
operation or discharge, are hereby revoked by issuance of this permit. [The exclusive authority to operate this
facility arises under this permit. The authority to operate the facility under previously issued permits bearing this
number is no longer effective. ] The conditions, requirements, terms, and provisions of this permit authorizing
discharge under the National Pollutant Discharge Elimination System govern discharges from this facility.
SECTION C. OPERATION AND MAINTENANCE OF POLLUTION CONTROLS
1. Certified Operator
Pursuant to Chapter 90A-44 of North Carolina General Statutes, and upon classification of the facility by the
Certification Commission, the permittee shall employ a certified wastewater treatment plant operator in
responsible charge (ORC) of the wastewater treatment facilities. Such operator must hold a certification of the
grade equivalent to or greater than the classification assigned to the wastewater treatment facilities by the
Certification Commission. The permittee must also employ a certified back-up operator of the appropriate type
and any:grade to comply with the conditions of Title 15A NCAC Chapter 8G.0202. The ORC of the facility
must visit each Class I facility at least weekly and each Class II, III, and IV facility at least daily, excluding
weekends and holidays, and must properly manage and document daily operation and maintenance of the facility
and must comply with all other conditions of Title 15A, NCAC Chapter 8G.0202. Once the facility is classified,
the permittee shall submit a letter to the Certification Commission which designates the operator in responsible
charge within thirty days after the wastewater treatment facilities are 50% complete.
2. Proper Operation and Maintenance
The permittee shall at all times properly operate and maintain all facilities and systems of treatment and control
(and related appurtenances) which are installed or used by the permittee to achieve compliance with the
conditions of this permit. Proper operation and maintenance also includes adequate laboratory controls and
appropriate quality assurance procedures. This provision requires the operation of back-up or auxiliary facilities
or similar systems installed by a permittee only when the operation is necessary to achieve compliance with the
conditions of the permit.
3. Need to Halt or Reduce not a Defense
It shall not be a defense for a permittee in an enforcement action that it would have been necessary to halt or
reduce the permitted activity in order to maintain compliance with the condition of this permit.
4. Bypassing of Treatment Facilities
a. Definitions
(1) "Bypass" means the known diversion of waste streams from any portion of a treatment facility including
the collection system, which is not a designed or established or operating mode for the facility.
(2) "Severe property damage" means substantial physical damage to property, damage to the treatment
facilities which causes them to become inoperable, or substantial and permanent loss of natural resources
which can reasonably be expected to occur in the absence of a bypass. Severe property damage does not
mean economic loss caused by delays in production.

Part II
Page 7of11
4. b. Bypass not exceeding limitations.
The permittee may allow any bypass to occur which does not cause effluent limitations to be exceeded, but
only if it also is for essential maintenance to assure efficient operation. These bypasses are not subject to the
provisions of Paragraphs c. and d. of this section.
c. Notice
(1) -Anticipated bypass. If the permittee knows in advance of the need for a bypass, it shall submit prior
notice, if possible at least ten days before the date of the .bypass; including an evaluation of the
anticipated quality and affect of the bypass.
(2) Unanticipated bypass. The permitteeshall submit notice of an unanticipated bypass as required in Part II,
E. 6. of this permit. (24 hour notice).
d. Prohibition of Bypass
(1) Bypass is prohibited and the Permit Issuing Authority may take enforcement action against a permittee
for bypass, unless:
(A) Bypass was unavoidable to prevent loss of life, personal injury or severe property damage;
(B) There were no feasible alternatives to the bypass, such as the use of auxiliary treatment facilities,
retention of untreated wastes or maintenance during normal periods of equipment downtime. This
condition is not satisfied if adequate backup equipment should have been installed in the exercise of
reasonable engineering judgment to prevent a bypass which occurred during normal periods of
equipment downtime or preventive maintenance; and
(C) .The permittee .submitted notices as required under Paragraph c. of this section.
(2) The Permit Issuing Authority may. approve an.anticipated bypass, after considering its adverse affects, if
the Permit. Issuing:Authority-determines that: it will meet the -three: conditions listed above in Paragraph
d. (1) of this section.
5. Upsets
a. Definition: "Upset" means an exceptional incident in which there is unintentional and temporary
noncompliance with technology based permit effluent limitations because of factors beyond the reasonable
control of the permittee. An upset does not include noncompliance to the extent caused by operational
error, improperly designed treatment facilities, inadequate treatment facilities, lack of preventive maintenance,
or careless or improper operation.
b. Effect of an upset: An upset constitutes an affirmative defense to an action brought for noncompliance
with such technology based permit effluent limitations if the requirements of paragraph c. of this condition
are met. No determination made during administrative review of claims that noncompliance was caused by
upset, and before an action for noncompliance, is final administrative action subject to judicial review.
c. Conditions necessary for a demonstration of upset: A permittee who wishes to establish the
affirmative defense of upset shall demonstrate, through properly signed, contemporaneous operating logs, or
other relevant evidence that
(1) An upset occurred and that the permittee can identify the cause(s) of the upset;
(2) The permittee facility was at the time being properly operated; and
(3) The permittee submitted notice of the upset as required in Part II, E. 6. (b) (B) of this permit.
(4) The permittee complied with any remedial measures required under Part II, B. 2. of this permit.
d. Burden of proof: In any enforcement proceeding the permittee seeking to establish the occurrence of an
upset has the burden of proof.

Part II
Page 8of11
6. Removed Substances
Solids, sludges, filter backwash, or other pollutants removed in the course of treatment or control of wastewaters
shall be utilized/disposed of in accordance with NCGS 143-215.1 and in a manner such as to prevent any pollutant
from such materials from entering waters of the State or navigable waters of the United States. The permittee
shall comply with all existing federal regulations governing the disposal of sewage sludge. Upon promulgation of
40 CFR Part 503, any permit issued by the Permit Issuing Authority for the utilization/disposal of sludge may be
reopened and modified, or revoked and reissued, to incorporate applicable requirements at 40 CFR Part 503.
The permittee shall comply with applicable 40 CFR Part 503 Standards for the Use and Disposal of Sewage
Sludge -(when promulgated) within the time provided in the regulation, even if the permit is not modified to
incorporate the requirement. The permittee shall notify the Permit Issuing Authority of any significant change in
its sludge use or disposal practices.
7. Power Failures
The permittee is responsible for maintaining adequate safeguards as required by DEM Regulation, Title 15A,
North Carolina Administrative Code, Subchapter 2H, .0124 Reliability, to prevent the discharge of untreated or
inadequately treated wastes during electrical power failures either by means of alternate power sources, standby
generators or retention of inadequately treated effluent.
SECTION D. MONITORING AND RECORDS
1. Representative Sampling
Samples collected and measurements taken, as required herein, shall be characteristic of the volume and nature of
the permitted discharge. Samples collected at a frequency less than daily shall be taken on a day and time that is
characteristic of the discharge over the entire period which the sample represents. All samples shall be taken at
the monitoring points specified in this permit and, unless otherwise specified, before the effluent joins or is
diluted by any other wastestream, body of water, or substance. Monitoring points shall not be changed without
notification to and the approval of the Permit Issuing Authority.
2. Reporting
Monitoring results obtained during the previous month(s) shall be summarized for each month and reported on a
monthly Discharge Monitoring Report (DMR) Form (DEM No. MR 1,1.1, 2, 3) or alternative forms approved by
the Director, DEM, postmarked no later than the 30th day following the completed reporting period.
The first DMR is due on the last day of the month following the issuance of the permit or in the case of a new
facility, on the last day of the month following the commencement of discharge. Duplicate signed copies of
these, and all other reports required herein, shall be submitted to the following address:
NC DENR / Division of Water Quality / Water Quality Section
AI 11 NTION: Central Files
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
3. Flow Measurements
Appropriate flow measurement devices and methods consistent with accepted scientific practices shall be selected
and used to ensure the accuracy and reliability of measurements of the volume of monitored discharges. The
devices shall be installed, calibrated and maintained to ensure that the accuracy of the measurements are
consistent with the accepted capability of that type of device. Devices selected shall be capable of measuring
flows with a maximum deviation of less than 10% from the true discharge rates throughout the range of expected
discharge volumes. Once -through condenser cooling water flow which is monitored by pump logs, or pump
hour meters as specified in Part I of this permit and based on the manufacturer's pump curves shall not be
subject to this requirement.

Part II
Page 9 of 11
4. Test Procedures
Test procedures for the analysis of pollutants shall conform to the EMC regulations published pursuant to
NCGS 143-215.63 et. seq, the Water and Air Quality Reporting Acts, and to regulations published pursuant to
Section 304(g), 33 USC 1314, of the Federal Water Pollution Control Act, as Amended, and Regulation 40 CFR
136; or in the case of sludge use or disposal, approved under 40 CFR 136, unless otherwise specified in 40 CFR
503, unless other test procedures have been specified in this permit.
To meet the intent of the monitoring required by this permit, all test procedures must produce minimum
detection and reporting levels that are below the permit discharge requirements and all data generated must be
reported down to the minimum detection or lower reporting level of the procedure. If no approved methods are
determined capable of achieving minimum detection and reporting levels below permit discharge requirements,
then the most sensitive (method with the lowest possible detection and reporting level) approved method must
be used.
5. Penalties for Tampering
The Clean Water Act provides that any person who falsifies, tampers with, or knowingly renders inaccurate, any
monitoring device or method required to be maintained under this permit shall, upon conviction, be punished by
a fine of not more than $10,000 per violation, or by imprisonment for not more than two years per violation, or
by both. If a conviction of a person is for a violation committed after a first conviction of such person under this
paragraph, punishment is a fine of not more than $20,000 per day of violation, or by imprisonment of not more
than 4 years, or both.
6. Records Retention
Except for records of monitoring information required by this permit related to the permittee's sewage sludge use
and disposal activities, which shall be retained for a period of at least five years (or longer as required by 40 CFR
503), the permittee shall retain records of all monitoring information, including all calibration and maintenance
records and- all originalstrip chart recordings for continuous monitoring.. instrumentation, copies of all reports
•.required :by. this permit, for a..period of: at least: 3 years:from -the date-of'the:sample, measurement, report or
application. This period maybe extended by request of the Director at any time.
7. Recording Results
For each measurement or sample taken pursuant to the requirements of this permit, the permittee shall record
the following information:
a. The date, exact place, and time of sampling or measurements;
b. The individuals) who performed the sampling or measurements;
c. The date(s) analyses were performed;
d. The individual(s) who performed the analyses;
e. The analytical techniques or methods used; and
f. The results of such analyses.
8. Inspection and Entry
The permittee shall allow the Director, or an authorized representative (including an authorized contractor acting
as a representative of the Director), upon the presentation of credentials and other documents as may be required
by law, to;
a. Enter upon the permittee's premises where a regulated facility or activity is located or conducted, or where
records must be kept under the conditions of this permit;
b. Have access to and copy, at reasonable times, any records that must be kept under the conditions of this
permit;
c. Inspect at reasonable times any facilities, equipment (including monitoring and control equipment), practices,
or operations regulated or required under this permit; and
d. Sample or monitor at reasonable times, for the purposes of assuring permit compliance or as otherwise
authorized by the Clean Water Act, any substances or parameters at any location.

Part II
Page 10of11
SECTION E REPORTING REQUIREMENTS
1. Change in Discharge
All discharges authorized herein shall be consistent with the terms and conditions of this permit. The discharge
of any pollutant identified in this permit more frequently than or at a level in excess of that authorized shall
constitute a violation of the permit.
2. Planned Changes
The permittee shall give notice to the Director as soon as possible of any planned physical alterations or additions
to the permitted facility. Notice is required only when:
a The alteration or addition to a permitted facility may meet one of the criteria for determining whether a
facility is a new source in 40 CFR Part 122.29 (b); or
b. The alteration or addition could significantly change the nature or increase the quantity of pollutants
discharged. This notification applies to pollutants which are subject neither to effluent limitations in the
permit, nor to notification requirements under 40 CFR Part 122.42 (a) (1).
c. The alteration or addition results in a significant change in the permittee's sludge use or disposal practices,
and such alternation, addition or change may justify the application of permit conditions that are different
from or absent in the existing permit, including notification of additional use or disposal sites not reported
during the permit application process or not reported pursuant to an approved land application plan.
3. Anticipated Noncompliance
The permittee shall give advance notice to the Director of any planned changes in the permitted facility or activity
which.may result in noncompliance with permit requirements.
4. Transfers
This permit is not transferable to any person except after notice to the Director. The Director may require
modificationor revocation and reissuance of the permittee and incorporate such other requirements as may be
necessary under the Clean Water Act.
5. Monitoring Reports
Monitoring results shall be reported at the intervals specified elsewhere in this permit.
a. Monitoring results must be reported on a Discharge Monitoring Report (DMR) (See Part II. D. 2 of this
permit) or forms provided by the Director for reporting results of monitoring of sludge use or disposal
practices.
b. If the permittee monitors any pollutant more frequently than required by the permit, using test procedures
specified in Part II, D. 4. of this permit or in the case of sludge use or disposal, approved under 40 CFR 503,
or as specified in this permit, the results of this monitoring shall be included in the calculation and reporting
of the data submitted in the DMR.
c. Calculations for all limitations which require averaging of measurements shall utilize an arithmetic mean
unless otherwise specified by the Director in the permit.
6. Twenty-four Hour Reporting
a. The permittee shall report to the central office or the appropriate regional office any noncompliance which
may endanger health or the environment. Any information shall be provided orally within 24 hours from the
time the permittee became aware of the circumstances. A written submission shall also be provided within 5
days of the time the permittee becomes aware of the circumstances. The written submission shall contain a
description of the noncompliance, and its cause; the period of noncompliance, including exact dates and
times, and if the noncompliance has not been corrected, the anticipated time it is expected to continue; and
steps taken or planned to reduce, eliminate, and prevent reoccurrence of the noncompliance.

Part II
Page 11 of 11
6. b. The following shall be included as information which must be reported within 24 hours under this paragraph:
(1) Any unanticipated bypass which exceeds any effluent limitation in the permit.
(2) Any upset which exceeds any effluent limitation in the permit.
(3) Violation of a maximum daily discharge limitation for any of the pollutants listed by the Director in the
permit to be reported within 24 hours.
c. The Director may waive the written report on a case -by -case basis for reports under paragraph b. above of
this condition if the oral report has been received within 24 hours.
7. Other Noncompliance
The permittee shall report all instances of noncompliance not reported under Part II. E. 5 and 6. of this permit at
the time monitoring reports are submitted. The reports shall contain the information listed in Part II. E. 6. of
this permit.
8. Other Information
Where the permittee becomes aware that it failed to submit any relevant facts in a permit application, or
submitted incorrect information in a permit application or in any report to the Director, it shall promptly submit
such facts or information.
9. Noncompliance Notification
The permittee shall report by telephone to either the central office or the appropriate regional office of the
Division as soon as possible, but in no case more than 24 hours or -on the next working day following the
•occurrence or first knowledge of the.occurrence of any of the following:
a. Any occurrence at the water pollution control: facility which results -in the discharge of significant amounts of
:: wastes which are. abnormal in quantity or characteristic, such as the dumping of the contents of a sludge
digester; :the known 'passage •of a slug. of hazardous substance° through' the facility; or any other unusual
circumstances.
b. Any process unit failure, due to known or unknown reasons, that render the facility incapable of adequate
wastewater treatment such as mechanical or electrical failures of pumps, aerators, compressors, etc.
c. Any failure of a pumping station, sewer line, or treatment facility resulting in a by-pass directly to receiving
waters without treatment of all or any portion of the influent to such station or facility.
Persons reporting such occurrences by telephone shall also file a written report in letter form within 5 days
following first knowledge of the occurrence.
10. Availability of Reports
Except for data determined to be confidential under NCGS 143-215.3 (a)(2) or Section 308 of the Federal Act, 33
USC 1318, all reports prepared in accordance with the terms shall be available for public inspection at the offices
of the Division of Water Quality. As required by the Act, effluent data shall not be considered confidential.
Knowingly making any false statement on any such report may result in the imposition of criminal penalties as
provided for in NCGS 143-215.1 (b)(2) or in Section 309 of the Federal Act.
11. Penalties for Falsification of Reports
The Clean Water Act provides that any person who knowingly makes any false statement, representation, or
certification in any record or other document submitted or required to be maintained under this permit, including
monitoring reports or reports of compliance or noncompliance shall, upon conviction, be punished by a fine of
not more than $10,000 per violation, or by imprisonment for not more than two years per violation, or by both.

PART III
OTHER REQUIREMENTS
A. Construction
No construction of wastewater treatment facilities or additions to add to the plant's treatment capacity or to
change the type of process utilized at the treatment plant shall be begun until Final Plans and Specifications have
been submitted to the Division of Water Quality and written approval and Authorization to Construct has been
issued.
B. Groundwater Monitoring
The permittee shall, upon written notice from the Director of the Division of Water Quality, conduct
groundwater monitoring as may be required to determine the compliance of this NPDES permitted facility with
the current groundwater standards.
C. Changes in Discharges of Toxic Substances
The permittee shall notify the Permit Issuing Authority as soon as it knows or has reason to believe:
a. That any activity has occurred or will occur which would result in the discharge, on a routine or frequent
basis, of any toxic pollutant which is not limited in the permit, if that discharge will exceed the highest of the
following "notification levels";
(1) One hundred micrograms per liter (100 µg/L);
(2) Two hundred micrograms per liter (200 µg/L) for acrolein and acrylonitrile; five hundred micrograms per
liter (500 µg/L) for 2.4-dinitrophenol and for 2-methyl-4.6-dinitrophenol; and one milligram per liter (1
mg/L) for antimony;
(3) Five (5) times the maximum concentration value reported for that pollutant in the permit application.
b. That any activity has occurred or will occur which would result in any discharge, on a non -routine or
infrequent basis, of a toxic pollutant which is not limited in the permit, if that discharge will exceed the
highest of the following "notification levels";
(1) Five hundred micrograms per liter. (500 µg/L);
(2) One milligram per liter (1 mg/L) for antimony;
(3) Ten (10) times the maximum concentration value reported for that pollutant in the permit application.
D. Requirement to Continually Evaluate Alternatives to Wastewater Discharges.
The permittee shall continually evaluate all wastewater disposal alternatives and pursue the most environmentally
sound alternative of the reasonably cost effective alternatives. If the facility is in substantial non-compliance with
the terms and conditions of the NPDES permit or governing rules, regulations or laws, the permittee shall submit
a report in such form and detail as required by the Division evaluating these alternatives and a plan of action
within sixty (60) days of notification by the Division.
PART IV
ANNUAL ADMINISTERING AND COMPLIANCE MONITORING FEE
REQUIREMENTS
A. The permittee must pay the annual administering and compliance monitoring fee within 30 (thirty) days
after being billed by the Division. Failure to pay the fee in a timely manner in accordance with 15A
NCAC 2H .0105(b)(4) may cause this Division to initiate action to revoke the permit.

Celanese
Work Plan for Enhanced
Reductive Dechlorination
Full -Scale Implementation
Dreyfus Research Park
Celanese Acetate, LLC
January 10, 2005
Infrastructure, buildings, environment, communications

Infrastructure, buildings, environment, communications
Ms. Susanne Robbins
Inactive Hazardous Sites Branch
Superfund Section
NC Deptartment of Environment and Natural Resources
1646 Mail Service Center
Raleigh, North Carolina 27699-1649
Subject:
Work Plan for Enhanced Reductive Dechlorination Full -Scale Implementation
Celanese Acetate LLC — Dreyfus Research Park
Charlotte, Mecklenburg County
NCD 000 608 117
Dear Sue:
On behalf of Celanese Acetate, LLC, ARCADIS is forwarding you three copies of
the Work Plan for Enhanced Reductive Dechlorination Full -Scale Implementation
for Dreyfus Research Park located in Charlotte, North Carolina. An application for
Underground Injection Control (UIC) permit will be submitted to Mr. Evan Kane
later this week, and you will also receive a copy.
Should you have any questions or concerns regarding this report, please contact me
or Steve Olp at [phone].
•
Sincerely,
ARCADIS G&M, Inc.
Elizabeth Rhine
Project Manager
Copies:
Steve Olp — Celanese
David Wilis — ARCADIS
Carol Mowder — ARCADIS
Part of a bigger picture
ARCADIS G&M, Inc.
420 East Park Avenue
Greenville
South Carolina 29601
Tel [phone]
Fax [phone]
www.arcadis-us.com
ENVIRONMENTAL
Date:
12 January 2005
Contact:
Elizabeth Rhine
Phone:
864 241 5208
Email:
[e-mail]
Our ref:
GS028605.0002

ARCAD1S
Elizabeth M. Rhine
Project Manager
/tt,U-t a- i
Michelle R. Partsch,i
Project Engineer �-
Shelley Gib[5ons
Staff Engineer
Work Plan for Enhanced Reductive
Dechlorination Full -Scale
Implementation
Dreyfus Research Park
Prepared for:
Celanese Acetate, LLC
Prepared by:
ARCADIS
420 East Park Avenue
Greenville
South Carolina 29601
Tel [phone]
Fax [phone]
Our Ref.:
GS028543.0001
Date:
January 10, 2005
This document is intended only for the use of the
individual or entity for which it was prepared and
may contain information that is privileged,
confidential, and exempt from disclosure under
applicable law. Any dissemination, distribution, or
copying of this document is strictly prohibited.

Table of Contents
ARCADIS
1. Introduction 1-1
2. In -Situ Enhanced Reductive Dechlorination
2.1 Technology Description
2.2 Applicability to the Site
2-1
2-1
2-2
3. Full -Scale ERD Setup 3-1
3.1 Site Clearing 3-1
3.2 Injection via Direct Push Technology 3-1
3.3 Saprolite Injection Well Construction 3-3
3.4 Bedrock Injection Well Construction 3-4
4. Full -Scale ERD Operation 4-1
4.1 Molasses -Whey Injection 4-1
4.1.1 Composition of Molasses -Whey Feed Solution 4-1
4.1.2 Molasses -Whey Solution Injection Rate and Frequency 4-2
4.1.3 Molasses -Whey Injection Procedures 4-2
4.2 Groundwater Monitoring 4-3
4.2.1 Monitoring Strategy 4-3
4.2.2 Performance Monitoring 4-3
5. Reporting 5-1
6. Schedule 6-1
7. References 7-1

Table of Contents
ARCADIS
Tables
4-1 ERD Injection Field Log
4-2 Monitoring Program for Full -Scale ERD Implementation
4-3 Groundwater Sampling Parameters
Figures
1-1 Site Location
2-1 Fourth Quarter 2004 Sampling Results
2-2 Enhanced Reductive Dechlorination Conceptual Layout
3-1 Sampling and Analysis Network
3-2 Injection Well Construction Details
Appendix
A Material Safety Data Sheets
O Molasses
• Whey
• Sodium Bicarbonate
• Sodium Hydroxide

ARCADIS
1. Introduction
ARCADIS G&M, Inc. (ARCADIS) was retained by Celanese Acetate LLC to design
and implement the full-scale enhanced anaerobic bioremediation design in the shallow
and deep saprolite aquifers for the purpose of treating the concentration of volatile
organic compounds (VOCs) dissolved in groundwater at Dreyfus Research Park
located in Charlotte, North Carolina. The location of the facility and the Site layout are
shown on Figure 1-1.
This work plan describes the In -situ Reactive Zone (IRZTM) technology, the science
behind enhanced reductive dechlorination (ERD), the installation and operation of the
full-scale system, the monitoring program and analytical procedures, and the
evaluation and reporting of the results.
The objectives of the remedial action will be to:
• Establish and maintain an anaerobic and reducing IRZ throughout the targeted
treatment area; and
® Enhance the rate of reductive dechlorination of the chlorinated VOCs in
groundwater.
Performance data collected during operation of the IRZTM will periodically be
compared to baseline data and evaluated against the performance objectives. The long
term goals of the groundwater remedy are to stabilize the plume to prevent further
migration and reduce the mass of chlorinated compounds, such that cleanup can be
achieved throughout the site via natural attenuation.
Work Plan for
Enhanced Reductive
Dechlorination
Full -Scale Design
Introduction
1-1

ARCADQS
2. In -Situ Enhanced Reductive Dechlorination
2.1 Technology Description
Chlorinated aliphatic hydrocarbons (CAI -Is) such as tetrachloroethene (PCE) and
trichloroethene (TCE) can be transformed via biologically -mediated reductive
dechlorination (or dehalogenation). Reductive dechlorination involves the sequential
removal of chlorine atoms from the chlorinated hydrocarbon molecule and subsequent
replacement with hydrogen atoms. For PCE, reductive dechlorination proceeds via the
pathway: PCE -4 TCE -i cis-1,2-dichloroethene (cis-1,2-DCE) 4 vinyl chloride -
ethene. The final end product ethene is a non -chlorinated, non -toxic compound.
Reductive dechlorination reactions occur primarily in anaerobic (or oxygen -deficient)
groundwater. In order to create an anaerobic environment, any oxygen that may be
present in the groundwater system must be consumed by indigenous, aerobic
microorganisms. Indigenous microbes utilize an organic carbon source as the primary
substrate (food) for obtaining energy and utilize electron acceptors such as oxygen for
respiration. In this process, the organic carbon serves as an electron donor and is
oxidized, while the electron acceptor is reduced. Dissolved oxygen (DO), nitrate, iron,
manganese, sulfate, and/or carbon dioxide (CO2) are naturally occurring electron
acceptors that participate in these reactions.
Once anaerobic (reducing) conditions have been reached, the indigenous anaerobic
microorganisms become more prominent and reductive dechlorination more
energetically favorable. CAIds such as PCE and TCE can serve as electron acceptors in
this process, undergoing reductive dechlorination via the pathway shown above. In
addition, CAHs may be dechlorinated co -metabolically (the CAI -Is do not participate as
an electron acceptor but are fortuitously degraded).
Research conducted to date has indicated that reductive dechlorination of PCE and
TCE occurs most readily under strongly reducing (sulfate -reducing to methanogenic)
conditions. Therefore, there must be a sufficient source of carbon to support microbial
growth and maintain strongly reducing conditions [typically oxidation reduction
potential (ORP) in the range of -200 millivolts (mV) to -400 mV] within the
groundwater environment. The carbon source may occur naturally within the aquifer,
may be an anthropogenic co -contaminant (as with some aromatic co -contaminants), or
may be a non -contaminant carbon source injected intentionally to create these strongly
reducing conditions.
Work Plan for
Enhanced Reductive
Dechlorination
Full -Scale Design
In -Situ Enhanced
Reductive Dechlorination
2-1

ARCAD1S
There are several types of carbon substrates available for ERD, ranging from highly
soluble substrates such as molasses or lactate to slow release/solid compounds such as
vegetable oil or chitin. For this site, a molasses -whey solution will be used as the
electron donor in the full-scale implementation.
ARCADIS' IRZ technology (Patent #6,143,177) relies on enhancing the reductive
dechlorination reactions by supplying an additional organic carbon source (i.e.,
molasses and whey solution) as a substrate to the groundwater system. This expedites
the depletion of oxygen and other electron acceptors, driving the groundwater
environment to more reducing conditions that favor the complete degradation of
CAHs. The carbohydrate solution is injected periodically to create highly reducing
reactive zones in targeted areas through which CAH-impacted groundwater will flow
and undergo treatment. The performance of ERD is measured by monitoring the
relative concentrations of primary CAH contaminants and their degradation
byproducts, as well as other biogeochemical and tracer parameters in groundwater.
2.2 Applicability to the Site
Data collected to date indicate that the ERD technology is likely to be successful in this
geologic system. Based on the size of the plume, the thickness of the aquifer, and the
heterogeneity of Piedmont Formation soils, ERD is the most appropriate technology for
the specific site conditions. Several other technologies have been evaluated, namely
Hydrogen Release Compound (HRCTM) produced by Regenesis and in -well striping
using Accelerated Remediation Technologies (ARTTM) processes. Regenesis
determined that HRCTM would not be effective due to the thickness of the aquifer and
the heterogeneity of the site. Tight soils also eliminated the ARTTM process from use at
this site. Of the technologies evaluated, IRZTM was the only technology proven
effective in achieving adequate delivery of remediation reagents in heterogeneous
formations.
The presence of reductive dechlorination indicators and daughter products [e.g., reduced
ORP and generation of cis-1,2-DCE] reported in both field and laboratory analytical
data during the quarterly sampling indicate that reductive dechlorination of CAHs is
already occurring in portions of the Site. These results are a positive indicator for the
presence of the requisite microbial population and for achieving dechlorination of PCE
and TCE to ethene at the field scale. Further, the limited extent of dechlorination
observed in the field compared to the plume extent is consistent with a carbon -limited
system. The Fourth Quarter 2004 sampling results for PCE and TCE are shown on
Figure 2-1.
Work Plan for
Enhanced Reductive
Dechlorination
Full -Scale Design
In -Situ Enhanced
Reductive Dechlorination
2-2

ARCAD1S
The addition of excess organic carbon in the form of a dilute molasses/whey solution
will result in an increase in microbial activity and dechlorination of CAFIs. The addition
of the more complex carbohydrate whey to the solution will provide a lasting source of
carbon to the aquifer. The full-scale ERD implementation is anticipated to be successful
in enhancing reductive dechlorination processes at the Site and achieving the
groundwater clean-up goals established in the Remedial Action Plan Addendum
(ARCADIS, 2000).
There are four primary areas of impact at the Site shown on Figure 2-2. Monitored
Natural Attenuation (MNA) has been established as the selected remedy for the
Meadows and Area 1. ERD followed by MNA has been established as the selected
remedy for Areas 2, 3, and 4. More recent depictions of the groundwater plumes
developed using data from temporary well borings installed in December 2004 show
Areas 1 and 2 as one plume, referred to as "the Meadows" plume and Areas 3 and 4 as
another plume, referred to as "the Stoll" plume. A 100-foot buffer zone has been drawn
around the Meadows and Stoll plumes to be protective of potential soil vapor intrusion
issues and to disallow development in impacted areas until groundwater has been
remediated to levels acceptable and appropriate.
Work Plan for
Enhanced Reductive
Dechlorination
Full -Scale Design
In -Situ Enhanced
Reductive Dechlorination
2-3

ARCADIS
3. Full -Scale ERD Setup
The goal of the full-scale design is to create an anaerobic IRZ in both the shallow and
deep portions of the saprolite aquifer in which the reductive dechlorination of CAHs is
enhanced to promote natural attenuation. The IRZ will be created through the injection
of a molasses -whey solution using a combination of direct push technology (DPT), a
network of injection wells, and conversion of existing site extraction wells into
injection wells. The combination of direct push and fixed well injection methodology
will allow for carbon to be delivered to a wider extent within the aquifer than with only
fixed well injections. Prior to any activities at the Site, an Underground Injection
Control (UIC) permit and well construction permit will be obtained from NCDNER.
Two existing extraction wells in Area 4 (EW-6 and EW-7) will be converted into
injection wells. One existing extraction well (EW-12) in Area 3 may also be converted
into an injection well. During installation, some of the new injection wells may be
sampled for VOCs to better define the plume boundary. The layout of the well field
may be adjusted accordingly to effectively deliver solution throughout the plume.
Performance of the system will be based on: (1) achieving the desired distribution of
carbohydrate solution; (2) the establishment of an anaerobic zone; (3) the reduction of
primary contaminants such that cleanup can be achieved throughout the Site via natural
attenuation; and (4) the production and degradation of daughter products in the nearby
monitoring wells.
3.1 Site Clearing
Prior to installation of injection wells, portions of the Site will need to be cleared to
provide access for the drill rigs and ancillary equipment. Site clearing is expected to be
limited, and will not require a grading permit.
3.2 Injection via Direct Push Technology
The ERD technology relies on an active delivery method, whereby additional
injections and the natural processes of advection and dispersion also help to propagate
and maintain the IRZ away from the injection points. In water units with slow
groundwater velocities, such as the Piedmont Formation, the processes of advection
will require a long time to transport the organic carbon from the injection wells to the
impacted area of the aquifer resulting in longer remediation time frames. To expedite
the time required for the organic carbon solution to reach the impacted groundwater
and achieve the successful distribution of the carbon solution in the water unit,
Work Plan for
Enhanced Reductive
Dechlorination
Full -Scale Design
Full -Scale ERD Setup
3-1

ARCADIS
ARCADIS proposes to conduct injections using a dense network of direct push points.
The DPT injections will be closely spaced to distribute the carbohydrate solution in
both the shallow and deep portions of the surficial water unit in a short period of time.
Initially, 100 direct push injections will be performed in Area 4, 12 in Area 3, and 30 in
Area 2. Delivering carbon straight to the impacted portions of the aquifer and not
relying on advective flow of groundwater to distribute the carbon, will expedite the
reductive dechlorination process. Design of the subsequent phases of injections will be
based on the monitoring results obtained during Phase 1. It is anticipated that a second
phase of injections using DPT will be performed approximately 6 months after the
initial injections. Subsequent injections (frequency and timing) will be based on
groundwater analytical results. The configuration of injection points for Phase 1 is
shown on Figure 2-2. Performance monitoring samples will be collected from
locations selected to optimize the ERD network.
Using a DPT such as a GeoProbe® 660 unit, an injection probe will be pushed to
approximately 5 feet above the top of partially weathered rock (i.e., the transition zone)
as determined by the boring logs of adjacent boreholes. Once the target depth is
achieved, the carbohydrate solution will be injected on a continuous basis as the
injection probe is raised in the borehole. These procedures are more fully described in
section 4.1 of this Work Plan. On average, approximately 40 gallons of solution will
be injected per vertical foot of boring, however, the actual volume injected will be
dependent on site geology.
3.3 Hydraulic Fracturing in Saprolite
Due to the tightness and low permeability observed in saprolitic geology, hydraulic
fracturing will be performed in the new injection wells in Area 4 in order to increase
the aquifer permeability and improve carbohydrate solution distribution in the
treatment area. The shallow injection wells will have one fracture and the deep
injection wells will have two fractures. Hydraulic fracturing will be utilized in
addition to DPT points in areas with higher mass (i.e., hot spots) and greater aquifer
thickness where more frequent injections may be desirable. The actual number of
hydraulic fractures installed will depend on the most recent analytical data from
quarterly sampling preceding the DPT injections
Two fractures will be prepared at each deep injection well location. To accomplish
this, an 8-inch borehole will be drilled to the top of rock. If necessary, a polyvinyl
chloride (PVC) surface casing will be installed to prevent borehole collapse at the
surface, or alternately a string of augers may be left in place during fracturing
Work Plan for
Enhanced Reductive
Dechiorination
Full -Scale Design
Full -Scale ERD Setup
3-2

ARCADOS
activities. A packer assembly will be placed in the borehole. The packers are spaced
approximately 10 feet apart, and the lower packer will be set about 5 feet above the top
of bedrock. In cases where partially weathered rock (PWR) or transition zone is
observed, the lower packer will be set 5 feet above the PWR. Both packers will be
inflated, effectively segregating the target zone for the fracture. Using high pressure
water, a kerf will be made in the exposed boring section. Once the kerf is made 360°
around the borehole, a slurry of guar, sand, and an enzyme breaker (to degrade the guar
within a few days) is injected under pressure up to 60 pounds per square inch (psi).
This procedure creates a sand -filled fracture in the saprolite matrix approximately 1
centimeter (cm) thick, depending on the depth, soil conditions, and pressure. Once the
fracture is complete, the packers are deflated and raised approximately 20 feet in the
borehole, depending on the thickness of the saprolite aquifer at each specific location.
The procedure is repeated to create a second fracture in the shallow portion of the
saprolite aquifer.
All of the injection wells will be located on Site. To address the off -site impact, a line
of injection wells and DPT injection points will be installed inside the property line
behind the homes on Edgewater Drive. In order to prevent the discharge of organic
carbon to Tributary #6 of Little Sugar Creek, injection wells will not be installed
closer than 150 feet upgradient of the creek.
3.4 Saprolite Injection Well Construction
The proposed ERD system includes installation of up to 14 new shallow injection wells
and two deep injection wells in Area 4 and three new shallow injection wells in Area 3
(Figure 2-2). The actual number of wells installed will depend on the most recent
analytical data from quarterly sampling preceding the DPT injections. All saprolite
injection wells will be installed to intercept the sand fractures created as indicated in
Section 3.3. Both deep and shallow injection wells will be constructed in the same
manner. The boreholes will be installed using hollow -stern auger (HSA) drilling.
Utilizing the same borehole as the hydraulic fractures, the borehole will be cleaned out
and used to construct a single injection well in areas where the top of bedrock is
relatively shallow and a pair of injection wells in areas where the top of rock is
considerably deeper. Shallow saprolite wells are expected to be 45 feet below ground
surface (bgs) on average. Deep saprolite wells are expected to be 75 feet bgs
tenninating approximately 5 feet above the top of the transition zone (i.e., partially
weathered rock), or at the top of bedrock in areas where the transition zone is not
apparent. The wells will be separated with a conservative sand pack and bentonite seal
with a minimum thickness of 2 feet. Well materials will be 2-inch diameter PVC
screen with 0.010-inch wire wound slots (or Circumslot) and PVC casing. The actual
Work Plan for
Enhanced Reductive
Dechlorination
Full -Scale Design
Full -Scale ERD Setup
3-3

ARCADES
screen length will depend on the aquifer thickness but will not exceed 20 feet in length.
Typical well construction details for the injection wells are shown on Figure 3-2. The
radius of influence for each injection well is projected to be 25 to 60 feet or greater in
areas that are fractured based on the anticipated fracture radius. .
Injection wells installed in regularly mowed grassy areas will be completed within a
10-inch flush -mounted vault. Injection wells installed in the wooded areas will be
completed with either a flush -mount vault or a stand-up protective casing, as
appropriate.
3.5 Bedrock Injection Well Construction
The installation of bedrock injection wells is believed to be unnecessary. The ERD
system will take advantage of the natural downward hydraulic gradient; injections in
the deep saprolite should have a fortuitous effect on the remediation of the bedrock
aquifer. During the course of injections in the deep portion of the saprolite aquifer,
bedrock groundwater quality will be monitored for any changes due to the ERD
activities in the saprolite. If it is determined that injection activities in the deep
saprolite are not positively addressing bedrock contamination within the treatment area,
then the possibility of injecting the molasses -whey solution directly into bedrock wells
will be evaluated. Monitoring will be performed as described in Section 4.2 at select
monitoring wells as shown on Figures 2-2 and 3-1.
Work Plan for
Enhanced Reductive
Dechlorination
Full -Scale Design
Full -Scale ERD Setup
3-4

ARCADIS
4. Full -Scale ERD Operation
Baseline groundwater monitoring will be performed on select monitoring wells prior to
the addition of carbohydrate solution. Upon approval of the UIC permit, the
carbohydrate solution will be injected as described below.
Injection of a dilute molasses -whey solution into the subsurface will be conducted on a
scheduled batch -feed basis and adjusted as necessary based on the periodic monitoring
of groundwater quality. The use of the proposed injection system provides for
significant flexibility in terms of injection strategy. In particular, the volumes of
molasses -whey solution injected in different areas of the plume can be adjusted based
on varying demands such as higher contaminant levels or competing electron acceptor
concentrations in each area, resulting in a cost-effective use of electron donor. These
activities are described in the following sections.
4.1 Molasses -Whey Injection
The composition of the molasses -whey solution, the solution injection (or feed) rate,
and the injection procedures are discussed below.
4.1.1 Composition of Molasses -Whey Feed Solution
Molasses -whey (carbon source) will be introduced into the subsurface as a dilute
solution of water, molasses, and whey (see Appendix A for the Material Safety Data
Sheet [MSDS]). Based on ARCADIS' experience with implementation of this
technology at similar sites and the results of the quarterly monitoring, the initial
solution will consist of a 10 to 20 percent molasses -whey solution (i.e, with a 60:40
molasses/whey ratio). This concentration is expected to provide sufficient carbon to
enhance and drive anaerobic bacterial activity already occurring in the aquifer.
Based on field data from the second quarter 2004 sampling event, pH adjustment may
be unnecessary. However, if conditions should change (i.e. excessive pH drop in
monitoring wells due to the natural formation fatty acids resulting from biological
activity), then sodium bicarbonate (NaHCO3) or sodium hydroxide (NaOH) will be
added to the carbohydrate solution. The concentration will be adjusted as needed, to
increase the aquifer's pH buffering capacity against the potential for accumulation of
organic acids from enhanced bioactivity. The MSDS for NaHCO3 and NaOH are
presented in Appendix A.
Work Plan for
Enhanced Reductive
Dechlorination
Full -Scale Design
Full -Scale ERD Operation
4-1

ARCAD S
The composition and concentration of the carbohydrate solution may be adjusted
during the design implementation, based on interpretation of field measurements and
analytical results obtained during performance monitoring.
4.1.2 Molasses -Whey Solution Injection Rate and Frequency
In order for the ERD technology to be successful, a sufficient amount of carbohydrate
must be added to the subsurface to stimulate microbial activity, provide excess organic
carbon, create the zone of anaerobic and reducing conditions, and propagate the IRZ in
the target zone. Prior experience indicates that a target carbohydrate concentration
(measured as Total Organic Carbon (TOC)) between 25 and 100 parts per million
(ppm) in the groundwater at least 100 days downgradient of the injection transect is
optimum.
Given this target carbohydrate concentration, the anticipated hydraulic conditions in
the injection area, and the initial injection of a 10 to 20% molasses -whey solution, it is
estimated that the total volume of this solution required to effectively distribute the
organic carbon will vary between approximately 400 and 2,000 gallons per well per
event, with an initial target of 40 gallons per foot of screen or per vertical foot of DPT.
Long Term water -table mounding or other hydraulic effects are unlikely, as water table
conditions will equilibrate quickly following injection events. Injections will not affect
the plume configuration or gradients at the site. The carbohydrate solution will be
introduced through DPT points semi-annually for the first 30 months (5 injections).
Solution will be introduced through permanent injection wells quarterly to semi-
annually for 24 months (4 to 8 injections) starting during the second DPT injection
event. The frequency of injection into hydraulic fracture wells will depend upon
groundwater analytical data.
The composition of the molasses -whey solution and injection volume, frequency, and
locations may be altered based on field measurements and analytical results obtained
during performance monitoring in order to optimize anaerobic conditions.
4.1.3 Molasses -Whey Injection Procedures
Prior to each injection event, the carbohydrate solution will be delivered to the Site pre-
mixed to the dilution specifications ordered by the engineer, and may include
amendment with NaOH or NaHCO3 as a buffer. The solution will be injected into
DPT points or the injection wells using a mobile manifold injection system. The
mobile manifold system will be capable of injecting into as many as four wells at the
same time. The mobile manifold system will consist of a manifold, a secondary
Work Plana for
Enhanced Reductive
Dechlorination
Full -Scale Design
Full -Scale ERD Operation
4-2

ARCAD1S
storage solution tank, and an injection pump all mounted on a mobile, double axle
trailer. The solution delivered using tankers will be pressure -fed into each injection
well from the mobile injection unit. The solution will be delivered to the direct push
injection points utilizing a transfer pump and a portable polyethylene tank. Injection
pressures are expected to be below 50 psi.
A field log will be maintained to record the solution composition, the volume of solution
introduced into each injection well, the length of time required for injection, and the
injection pressure (Table 4-1).
4.2 Groundwater Monitoring
4.2.1 Monitoring Strategy
Groundwater monitoring is used to evaluate the progress of the full-scale ERD remedy
for reducing CAH concentrations. The molasses -whey injections are anticipated to
occur over a period of approximately four years with quarterly groundwater monitoring
during the active remediation period. The monitoring frequency will be extended as
necessary if it is determined that a longer period of active injection is required. These
activities are described below.
Once the plume is stabilized and the mass of chlorinated compounds is reduced such
that cleanup can be achieved throughout the site via natural attenuation, site -wide
groundwater will be monitored quarterly until performance monitoring has
demonstrated the cleanup standards continue to be met after a period of one year. A
total of 16 monitoring wells will be sampled during the initial monitoring events. The
number of wells sampled in subsequent events is subject to change based on laboratory
results and data trends. The analytical program is presented in Table 4-3. This is
subject to change based on the results collected during the carbohydrate injection
period. Any changes made to the sampling and analysis plan will be discussed in semi-
annual progress reports.
4.2.2 Performance Monitoring
Performance of ERD is evaluated through the monitoring of several analytes at
locations throughout the plume and comparison of these results to the results of the
baseline sampling event. Specifically, analytes include electron donor distribution
parameters, redox parameters, contaminants and degradation products, and water
quality parameters.
Work Plan for
Enhanced Reductive
Dechlorination
Full -Scale Design
Pull -Scale ERD Operation
4-3

ARCAD!S
Baseline sampling and analysis will be conducted at the following wells (Figure 3-1):
AREA 2: monitoring wells MW-5, MW-6, MW-7 and temporary well TW14;
AREA 3: former extraction well EW-13 and monitoring well MW-15; and,
AREA 4: piezometers PZ-1, PZ-2, and PZ-4; temporary wells TWO9, TW11, and
TW16; former extraction wells EW-15 and RW-1; and monitoring wells
MW-8, MW-8A, MW-10, MW-10A, MW-18, and MW-24.
For the baseline sampling event, samples will be collected from all of the above wells
and analyzed for VOCs, redox parameters (nitrate, total/dissolved iron, sulfate,
sulfide), dissolved gases (methane, ethane, and ethene), alkalinity, and TOC. All
groundwater sampling will be performed using low -flow sampling techniques, except
during sampling of TOC, which may be sampled using a disposable bailer, if desired.
During the injection period, performance monitoring will be performed as described on
Table 4-2 from the wells listed above and shown in Figure 3-1. Table 4-3 specifies the
method used to analyze each parameter. In addition, during the initial period of
molasses -whey injections, more frequent monitoring of TOC and pH will be performed
in order to determine that the molasses -whey is distributed throughout the entire
treatment zone as intended by the design and to document changes in redox conditions
in response to injections.
Achieving the desired distribution of carbohydrates in the aquifer is key to stimulating
reductive dechlorination throughout the plume. The parameter that is used to evaluate
the distribution of electron donor is TOC, which will be measured in a fixed lab (Table
4-3). In addition, water level monitoring is performed in the field to verify
groundwater flow directions.
As stated above, reductive dechlorination of CAHs requires the presence of strongly
reducing (i.e., sulfate -reducing to methanogenic) conditions. The monitoring program
includes the following analytes in order to evaluate changes in redox conditions as a
result of molasses -whey injection: nitrate, total/dissolved iron, sulfate, sulfide, and
methane,. These parameters are measured in a fixed lab.
Changes in the relative concentrations of primary contaminants and degradation
products are used to evaluate the effect of molasses -whey injection on reductive
dechlorination. The analytes include the primary contaminants (PCE and TCE),
chlorinated degradation products (DCE isomers and vinyl chloride), final non -
chlorinated degradation products (ethene and ethane). These parameters are all
Work Plan for
Enhanced Reductive
Dechlorination
Full -Scale Design
Full -Scale ERD Operation
4-4

ARCADE
measured in fixed lab analyses by a North Carolina -certified laboratory. STL
Laboratory located at 5102 LaRoche Avenue, Savannah, GA has been selected to
perform laboratory analyses for this project.
In addition, standard water quality parameters are measured to complete the
characterization of geochemical conditions. Field parameters include pH, specific
conductance, turbidity, and temperature. Alkalinity is measured in a fixed lab.
Work Plan for
Enhanced Reductive
Dechlorination
Full -Scale Design
Full -Scale ERD Operation
4-5

ARCAD S
5. Reporting
Reports will be prepared and submitted quarterly during active remediation and
annually during the performance monitoring phase of the project. Reports will include
a summary of activities performed, analytical data collected during the groundwater
monitoring event, an assessment of the performance to date of the full-scale ERD
design implementation, and recommendations for changes to the injection
frequency/locations, carbohydrate solution, or monitoring program.
Work Plan for
Enhanced Reductive
Dechlorination
Full -Scale Design
Reporting
5-1

ARCADOS
6. Schedule
The ERD full-scale program will be initiated after NCDENR approval of this Work
Plan and approval of the UIC permit. Site clearing and well installation are tentatively
scheduled for first quarter 2005, with baseline sampling and start-up during the third
quarter 2005. The anticipated duration of the full-scale injections is two to three years,
followed by a recommendation for performance monitoring for four quarters.
Work Plan for
Enhanced Reductive
Dechlorination
Full -Scale Design
Schedule
6-1

ARCADIS
7, References
ARCADIS, 2000. Remedial Action Plan Draft Addendum for Monitored Natural
Attenuation, Dreyfus Research Park, Celanese Acetate LLC.
North Carolina Administrative Code, August 2004. 15A NCAC 02L.0202,
Groundwater Quality Standards.
Work Plan for
Enhanced Reductive
Dechlorination
Full -Scale Design
References
7-1

ARCAD1S
Table 4-1. ERD Injection Field Log
Dreyfus Research Park
Injection
Well
Date
Water Level
(ft btoc)
pH
(SU)
Volume of
Carbon
(gallons)
Carbon
Solution
(water to molasses ratio)
NaHCO3 Added
(Ibs)
Injection
Pressure (psi)
Start Time
End Time
SU -standard unit
ft btoc - feet below top of casing
psi - pounds per square inch
NaHCO3 - sodium bicarbo
Ibs - pounds
g - grams

Table 4-2. Monitoring Program for Full Scale ERD Implementation
Dreyfus Research Park, Charlotte, North Carolina
Event
Frequency
Saprolite Wells Bedrock Wells
Analytes
Comments
Baseline Sampling
One time event 20 existing wells
Performance Monitoring Year 1 Quarterly for 1 year 20 wells
Performance Monitoring Year 2 Quarterly for 1 year 12 wells
Performance Monitoring Year 3 Quarterly for 1 year 10 wells
Quarterly for 1 year 8 injection wells
Post-Remediation Monitoring Annually as necessary 6 wells
Quarterly for 1 year 10 injection wells
Quarterly for 1 year 8 injection wells
4 existing wells
pH, VOCs, Redox Parameters, Dissolved Gases,
Alkalinity, and TOC
4 wells pH, VOCs, Dissolved Gases, Alkalinity, and TOC
4 wells
4 wells
2 wells
pH, TOC
Every event: pH, VOCs, TOC; Every other event
add: Dissolved Gases
pH, TOC
Every event: pH, VOCs, TOC; Every other event
add: Dissolved Gases
pH, TOC
VOCs, additional parameters as necessary
Wells will be sampled for TOC after initial injections. Generally,
the same wells as sampled during the baseline event.
Generally, the same wells as sampled during the baseline event.
Nitrate, chloride, alkalinity and iron analyses are discretionary.
Generally, the same wells as sampled during the baseline event.
Nitrate, chloride, alkalinity and iron analyses are discretionary.
As necessary
Notes:
Redox Parameters - Nitrate, Total/Dissolved Iron, Sulfate, and Sulfide
Dissolved Gases - Ethene, Ethane, and Methane

Table 4-3. Groundwater Sampling Parameters, Enhanced Reductive Dechlorination Full -Scale Implementation
Dreyfus Research Park, Charlotte, North Carolina
Parameter
Method
Field Parameters
Water Level Elevation
Dissolved Oxygen
Oxidation -Reduction Potential
pH
Specific Conductivity
Temperature
Turbidity
Laboratory Analyses
Volatile Organic Compounds
Nitrate
Iron (total and dissolved)
Sulfate
Sulfide
Alkalinity
Total Organic Carbon
Methane/Ethane/Ethene
Field Measurement
Field Measurement
Field Measurement
Field Measurement
Field Measurement
Field Measurement
Field Measurement
USEPA Method 8260B
USEPA Method 300
USEPA Method 200.7
USEPA Method 300
SM 4500 SE
SM 2320 B
USEPA Method 415.1
USEPA Method 3810 Modified'
Method developed by Microseeps Environmental Services, Pittsburg, Pennsylvania.
USEPA - United States Environmental Protection Agency
SM - Standard Methods Procedure

Client: CNA - DRP
Project Number: GS028605.0001
Project Manager: E. Rhine
Cartography By: T. Gore
Date: 8/10/2004
Celanese Acetate LLC
Dreyfus Research Park
Charlotte, North Carolina
X:\GRIP\CNA_DRP\ArcG IS\2004\3Q04\20040810_Fig1-1_SiteLocation4.mxd

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11:900063
Client: CNA - DRP
Project Number: GS028605.0001
Project Manager: E. Rhine
Cartography By: T. Gore
Date: 12/10/2004
G:\GIS\MAPPING\ENV CNA DRP\ArcGIS\2004\4Q04\Fig_2-1_FourthQuarterResuits_20041217.mxd
Extraction Well
Monitoring Well
OS Monitoring Well
Offsite Piezometer
Piezometer
Recovery Well
Sal Gas
Surface Water
Temporary Sample Location
VOC Groundwater Isoconcentration (5 mgil)
100 Foot Buffer Around Plume
1= -1 Buildings
Note: Soil Gas Locations - Total VOCs (ug/m3)
PCE Concentrations (mg/L)
TCE Concentrations (mg/L)
Fourth Quarter 2004
Sampling Results
Celanese Acetate LLC
Dreyfus Research Park
Charlotte, North Carolina

Client: CNA - DRP
Project Number: GS028605.0001
Project Manager: E. Rhine
Cartography By: T. Gore
Date: 12/10/2004
G:\GIS\MAPPING\ENV_CNA_DRP\ArcGIS)2004\4Q04\Fig_2-2 DechConceptualLayout_20041217.mxd
Legend
to Proposed DPT Injection points (Phasel)
Q Proposed Shallow Injection/Fracture Well
Q Proposed Deep Injection/Fracture Well
Existing Extraction Well
Existing Monitoring Well
Existing OS Monitoring Well
Existing OHsite Piezometer
Existing Piezometer
fa Existing Recovery Well
® Existing Temporary Sample location
VOC Groundwater Isoconcentration (5 mg/I)
100 Foot BulterAround Plume
I I Buildings
Note: Proposed DPT and Injection well locations
are approximated. Actual locations depend
on field conditions.
Enhanced Reductive
Dechlorination Conceptual Layout
Celanese Acetate LLC
Dreyfus Research Park
Charlotte, North Carolina

sty,!!
;;rw0g .:
Legend
Saprolite Bedrock
• Monitoring Well
0 • Extraction Well
Piezometer
A
Surface Water
Buildings
Client: CNA - DRP
Project Number: GS028605.0001
Project Manager: E. Rhine
Cartography By: D. Ward
Date: 12/17/2004
Sampling Analysis Network
Celanese Acetate LLC
Dreyfus Research Park
Charlotte, North Carolina
FIGURE:
3-1
G:\GIS\MAPPING\ENV_CNA_DRP\ArcGIS1200414Q04\Fig_3-1_MonitoringWell_SurfaceWater 20041217.mxd

/Well Number
Coordinates
Ground Elevation
Relative Top —of —Casing Elevation\
Geologist
Drilling Contractor
Drilling Method
Rig Type
Development Method
Volume Evacuated
Well Completed
Formation Monitored
0'
25' (Ns)
30' (bls)
FRACTU RE
2—INCH DIA. PVC,
0.010" WIRE —WRAPPED
WELL SCREEN
MEDIUM SAND
45' (bls)
46' (bls)
49' (bls)
55' (bls)
50' (bls)
TOP OF SCREEN
FRACTURE—'
65' (Ns)
8—in DIAMETER LOCKABLE
PROTECTIVE STEEL CASING
3—ft x 3—ft x 6—in
CONCRETE PAD
LAND SURFACE
BENTONITE
8"D BORE HOLE
SECURED W/ PVC
BENTONITE SEAL
2 INCH DIA. PVC,
0.010" WIRE —WRAPPED
WELL SCREEN
MEDIUM SAND
ARCAD1S
420 Park Ave.
Greenville, South Carolina 29601
TO 864/242-1717 Faxg 864/235-9062
PRJT MAN:
E. RHINE
CKD BY:
J. DOTTORELLI
DRAWING:
PRJT NO:
DWG DATE:
8/9/04
DRAFTER:
D. MOON
INJECTION WELL
CONSTRUCTION DETAILS
DREYFUS RESEARCH PARK
CHARLOTTE
NORTH CAROLINA
FIGURE NO.
3-2

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fi OMPL• TEL . S.OLU@•LE•• ••
viiivor Wes
Trade Nam® L Synonyms •
. • BLACKSTRAP, :CANE AMASSES- •
• Formula
• A• •MIXmURE OF SUCROSE AND•. SUGARS
Hosers9 C9gtsiflearer9
ManuPoe►ur s Phone Nuenbar
.VARIOUS
Chorntree.➢honti Number
:rec.ie,tt's
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anis
FE:..ENTATION;MAY :OCCUR`.WM
TION COO 4i{pI SS IBL.E '.TRAO
' Pe.
rted
.N. P f cat. Data
Threshotd• L)m;t Value (units),'
�li GraY►t7 (tail a i) •
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•
NON-VOLATILE
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Auf'o ladffas, T in
ANasLE
LE
LUTE() WITH H2O AND IS ACCELERATED BY ' MEAT.. DURING
F;'ETHANOL :IS GIVEN OFF.
:.Sec•tion III . - Page 1

Pestell Minerals & Ingredients - MSDS -Molasses:: Page 1 of 2
MSDS - Molasses October 10/2001
1. Chemical Product and Company Identification
Trade Name: Sweet 45, Sweet 45 Lite, Blackjack and Omalass Dried Molasses
Synonyms: Dried Molasses animal supplement
Distributed by:
Pestell Minerals & Ingredients
141 Hamilton Rd., New Hamburg, ON Canada NOB 2G0
Composition, Information on Ingredients:
CAS Registry No: N/A
ACGIH-TLV-TWA: No Data
2. Hazards Identification
Potential Health Effects
Eyes: Mild irritant if dust gets into eyes
Skin: None
Inhalation: None
3. Physical and Chemical Properties
Appearance: Dark brown coarsely ground meal
Physical State: Solid
Boiling Point: NA
Vapor Pressure: No data
Evaporation Rate: No data
Solubility in Water: Soluble
Odor: Sweet
Specific Gravity: 0.61
Freezing/Melting Point: NA
Volatile, by Volume: No data
Vapor Density in Air: Water Vapor only
pH: NA
4. Fire Fighting Measures
Flashpoint (Method used) Flammable Limits in Air
No flash below 230° F (sete flash)
Combustible carrier material
Extinguishing Agents: Water, CO2, foam
Unusual Fire and Explosion Hazards: Carrier material is combustible. Minimize dust generation. No unusual fire or
or explosion hazards.
5. Stability and Reactivity
Chemical Stability: Stable
Conditions to. Avoid: Excess moisture or heat
Incompatibility with Other Materials: Reacts with concentrated nitric acid or concentrated sulfuric acid
Hazardous Decomposition Products: No data
Hazardous Polymerization: NA
6. Toxicological Information
Acute Toxicity: No data
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:: Pestell Minerals & Ingredients - MSDS -Molasses:: Page 2 of 2
Exposure Limits: No data
7. Exposure Controls, Personal Protection
Respiratory Protection: May aggravate existing respiratory problems. Use nontoxic particle mask
Ventilation: Local exhaust recommended
Skin Protection: Work Gloves
Eye Protection: Safety Glasses
Hygiene: Wash any exposed area with soap and water. Launder contaminated clothing
Other Control Measures: None
Accidental Release Measures:
Small Release: Stop the source of the release. Recover as much product as possible for reuse. Dispose of
unusable material in dumpster.
Large Release: Stop the source of the release. Create diversionary structures to minimize the extent of the
release. Prevent the release from entering a waterway or sewer. Recover useable product.
Handling and Storage
Material should be stored indoors or protected from weather
Ecological Information
Prevent releases to land or water. Results in high Biological Oxygen Demand (BOD) and potential oxygen
depletion of aquatic system.
Disposal Information
Dispose of waste material at an approved municipal landfill or land application site
Regulatory Information
Discharges to a water of the U.S. are regulated by the Environmental Protection Agency
8. First Aid Measures
Eyes: Flush eyes for 15 minutes
Skin: Wash with soap and water
Ingestion: No data
9. Transport Information
Hazardous Materials Description/Proper Shipping Name: NA
DOT Hazard Class: NA
DOT Identification No.: NA
This product is not a DOT hazardous material
16. Other Information
The information herein is provided in good faith but makes no representation as to its comprehensiveness or
accuracy. This document is intended only as a guide to the appropriate precautionary handling of the material by
a properly trained person using this product. Individuals receiving the information must exercise their independent
judgment in determining its appropriateness for a particular purpose. No representation or warranties are made,
either express or implied, including with limitation any warranties of merchantability, fitness for a particular
purpose with respect to the information set forth herein, or the product to which the information refers.
Accordingly, we will not be responsible for damages resulting from use of or reliance upon this information.
httnJ/www.nestell.com/MSDS sheets/msds %20mo1asses.htm 1/29/2004

Page 1 of 3
SIGMA CHEMICAL COMPANY -- S8875 SODIUM BICARBONATE
MSDS Safety Information
FSC: 6505
MSDS Date: 09/22/1995
MSDS Num: BYMLB
LIIN: 00F046016
Product ID: S8875 SODIUM BICARBONATE
MFN: 01
Responsible Party
Cage: 21076
Name: SIGMA CHEMICAL COMPANY
Address: 3050 SPRUCE ST
Box: 14508
City: SAINT LOUIS MO 63178-5000
Info Phone Number: 314-771-5765/800-325-3010
Emergency Phone Number: 314-771-5765/800-325-3010
Review Ind: Y
Published: Y
Preparer Co. when other than Responsible Party Co.
Cage: 21076
Name: SIGMA CHEMICAL COMPANY
Address: 3050 SPRUCE ST
Box: 14508
City: ST LOUIS MO 63178
Contractor Summary
Cage: 21076
Name: SIGMA CHEMICAL COMPANY
Address: 3050 SPRUCE ST
Box: 14508
City: ST LOUIS MO 63178
Phone: [phone]
Ingredients
Cas: 144-55-8
RTECS #: VZ0950000
Name: SODIUM BICARBONATE
Health Hazards Data
Route Of Entry Inds - Inhalation: YES
Skin: YES
Ingestion: YES
Carcinogenicity Inds - NTP: NO
IARC: NO
OSHA: NO
Effects of Exposure: MAY BE HARMFUL BY INHALATION, INGESTION/SKIN ABSORPTION.
MAY CAUSE IRRITATION. EXPOSURE TO LARGE AMOUNTS CAN CAUSE GI DISTURBANCES
ALKALOSIS, AN ABNORMAL CONDITION OF INCREASED ALKALINITY OF THE BLOOD &
TISSUES. HEAVY/PROLONGED SKIN EXPOSURE MAY RESULT IN THE ABSORPTION OF
HARMFUL AMOUNTS OF MATERIAL.
Explanation Of Carcinogenicity: NONE
Signs And Symptions Of Overexposure: IRRITATION, GASTROINTESTINAL DISURBANCES
First Aid: EYES: IMMEDIATELY FLUSH W/COPIOUS AMOUNTS OF WATER FOR 15 MINS.
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Page 2 of 3
SKIN: FLUSH W/WATER. INHALATION: REMOVE TO FRESH AIR. INGESTION: WASH OUT
MOUTH W/WATER IF CONSCIOUS. OBTAIN MEDICAL ATTENTION IN ALL CA SES.
Handling and Disposal
Spill Release Procedures: WEAR RESPIRTOR, CHEMICAL SAFETY GOGGLES, RUBBER BOOTS
& HEAVY RUBBER GLOVES. SWEEP UP, PLACE IN A BAG & HOLD FOR WASTE
DISPOSAL. AVOID RAISING DUST. VENTILATE AREA & WASH SITE AFTER MATERIAL
PICKUP IS COMPLETE.
Waste Disposal Methods: SMALL: ADD TO A STIRRED EXCESS OF WATER. ADJUST PH TO
NEUTRAL, SEPARATE INSOLUBLE SOLIDS/LIQUIDS & PACKAGE FOR WASTE DISPOSAL.
FLUSH THE AQUEOUS SOLUTION DOWN THE DRAIN W/PLENTY OF WATER. DISPOSE OF I
AW/LOCAL, STATE & FEDERAL REGULATIONS.
Handling And Storage Precautions: STORE IN A COOL, DRY PLACE. KEEP TIGHTLY
CLOSED. SENSITIVE TO MOISTURE.
Other Precautions: AVOID BREATHING DUST AVOID CONTACT W/EYES, SKIN &
CLOTHING.
Fire and Explosion Hazard Information
Extinguishing Media: WATER SPRAY, CO2, DRY CHEMICAL POWDER/APPROPRIATE FOAM
Fire Fighting Procedures: WEAR SELF CONTAINED BREATHING APPARATUS &
PROTECTIVE CLOTHING TO PREVENT CONTACT W/SKIN & EYES.
Control Measures
Respiratory Protection: WEAR DUST MASK.
Ventilation: MECHANICAL EXHAUST
Protective Gloves: CHEMICAL RESISTANT
Eye Protection: CHEMICAL SAFETY GOGGLES
Other Protective Equipment: SAFETY SHOWER, EYE BATH
Work Hygienic Practices: WASH THOROUGHLY AFTER HANDLING.
Physical/Chemical Properties
Spec Gravity: 2.16
Appearance and Odor: WHITE POWDER
Reactivity Data
Stability Indicator: YES
Stability Condition To Avoid: MOISTURE
Materials To Avoid: STRONG OXIDIZING AGENTS, STRONG ACIDS
Hazardous Decomposition Products: CO, CO2
Hazardous Polymerization Indicator: NO
Toxicological Information
Ecological Information
MSDS Transport Information
Regulatory Information
Other Information
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Page 3 of 3
HAZCOM Label
Product ID: S8875 SODIUM BICARBONATE
Cage: 21076
Company Name: SIGMA CHEMICAL COMPANY
Street: 3050 SPRUCE ST
PO Box: 14508
City: ST LOUIS MO
Zipcode: 63178
Health Emergency Phone: [phone]
Label Required IND: Y
Date Of Label Review: 12/16/1998
Status Code: C
Label Date: 12/16/1998
Origination Code: G
Hazard And Precautions: MAY BE HARMFUL BY INHALATION, INGESTION/SKIN
ABSORPTION. MAY CAUSE IRRITATION. EXPOSURE TO LARGE AMOUNTS CAN CAUSE GI
DISTURBANCES ALKALOSIS, AN ABNORMAL CONDITION OF INCREASED ALKALINITY OF THE
BLOOD & TISSUES. HEAVY/PROLONGED SKIN EXPOSURE MAY RESULT IN THE
ABSORPTION OF HARMFUL AMOUNTS OF MATERIAL. IRRITATION,
GASTROINTESTINAL DISURBANCES
Disclaimer (provided with this information by thecompiling agencies): This
information is formulated for use by elements of the Department of Defense.
The United States of America in no manner whatsoever expressly or implied
warrants, states, or intends said information to have any application, use or
viability by or to any person or persons outside the Department of Defense
nor any person or persons contracting with any instrumentality of the United
States of America and disclaims all liability for such use. Any person
utilizing this instruction who is not a military or civilian employee of the
United States of America should seek competent professional advice to verify
and assume responsibility for the suitability of this information to their
particular situation regardless of similarity to a corresponding Department
of Defense or other government situation.
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.La11 Minerals & ingredients - ivISDS -Molasses:: Page 1 of 2
5 - Molasses
October 10/2001
�,nical Product and Company Identification
lame: Sweet 45, Sweet 45 Lite, Blackjack and Omalass Dried Molasses
rms: Dried Molasses animal supplement
ited by:
Minerals & Ingredients
iamilton Rd., New Hamburg, ON Canada NOB 2G0
asition, Information on Ingredients:
,egistry No: N/A
IH-TLV-TWA: No Data
izards Identification
ial Health Effects
: Mild irritant if dust gets into eyes
None
Lion: None
rsical and Chemical Properties
:arance: Dark brown coarsely ground meal
;al State: Solid
Point: NA
x Pressure: No data
)oration Rate: No data
ility in Water: Soluble
Odor: Sweet
Specific Gravity: 0.61
Freezing/Melting Point: NA
Volatile, by Volume: No data
Vapor Density in Air: Water Vapor only
pH: NA
Fighting Measures
hpoint (Method used) Flammable Limits in Air
'ish below 230° F (sete flash)
lustible carrier material
iguishing Agents: Water, CO2, foam
sual Fire and Explosion Hazards: Carrier material is combustible. Minimize dust generation. No unusual fire or
)losion hazards.
ability and Reactivity
:mica! Stability: Stable
-'1itions to Avoid: Excess moisture or heat
npatibility with Other Materials: Reacts with concentrated nitric acid or concentrated sulfuric acid
_drdous Decomposition Products: No data
:ardous Polymerization: NA
'oxicological Information
e Toxicity: No data

Pestell Minerals & Ingredients - MSDS -Molasses:: Page 2 of 2
:posure Limits: No data
Exposure Controls, Personal Protection
'-espiratory Protection: May aggravate existing respiratory problems. Use nontoxic particle mask
lentilation: Local exhaust recommended
in Protection: Work Gloves
e Protection: Safety Glasses
lygiene: Wash any exposed area with soap and water. Launder contaminated clothing
ier Control Measures: None
cidental Release Measures:
;mall Release: Stop the source of the release. Recover as much product as possible for reuse. Dispose of
Jsable material in dumpster.
•ge Release: Stop the source of the release. Create diversionary structures to minimize the extent of the
,ease. Prevent the release from entering a waterway or sewer. Recover useable product.
{andling and Storage
terial should be stored indoors or protected from weather
.,logical Information
'revent releases to land or water. Results in high Biological Oxygen Demand (BOD) and potential oxygen
)letion of aquatic system.
;pose' Information
'ispose of waste material at an approved municipal landfill or land application site
gulatory Information
charges to a water of the U.S. are regulated by the Environmental Protection Agency
first Aid Measures
yes:. Flush eyes for 15 minutes
1: Wash with soap and water
3stion: No data
•ransport Information
a.ardous Materials Description/Proper Shipping Name: NA
T Hazard Class: NA
_ T Identification No.: NA
its product is not a DOT hazardous material
i. Other Information
information herein is provided in good faith but makes no representation as to its comprehensiveness or
uracy. This document is intended only as a guide to the appropriate precautionary handling of the material by
„operly trained person using this product. Individuals receiving the information must exercise their independent
figment in determining its appropriateness for a particular purpose. No representation or warranties are made,
er express or implied, including with limitation any warranties of merchantability, fitness for a particular
,pose with respect to the information set forth herein, or the product to which the information refers,
:cordingly, we will not be responsible for damages resulting from use of or reliance upon this information.

DEO-16-2003 YUE Ub:28 FM INTERNATIONAL INGREDIENT FAX NO. 314 776 339b P, 02
INTERNATIONAL INGREDIENT COR OR A.TI ON
4240 T.JTAII STREET . Box 22106 ® S`f. LoutS,MO, USA 63116 e [phone] 4. FAX (3'14) 776-3395
December 16, 2003
Re: M.S.D.S Sheet for Spray Dried Why
To Whom it May Conceal,:
We acknowledge your request for an M.S.D.S. sheet on the animal feed ingredi. nt
Spray Dried Whey.
It is our understanding of the regulations that an M.S.D.S. sheet is not required for
this product.
Spray Dried Whey is a natural, not toxic feed ingredient considered as G_R.A.S.
(generally recognized as safe).
Please let me know if you require further information.
Yours Sincerely,
Mike Trotter, Ph.D.
Nutrition and Quality Assurance Manager

4,1
boki-,am

SODIUM BICARBONATE
Page 1 of 7
MSDS Number: S2954 * * * * * Effective Date: 09/12/03 * * * * * Supercedes: 05/16/03
Mate
From; Bicker, Inc.
222 clod School Lana
Phillipsburg, NJ 08205
Safety Data Sheet
Mallinckrodt •
1, am:micas r.
saru((Irtitti tics' ai:+ $31C83 ° 3t7U1d bY* : u t4 tti Diu
24 Hour Emot ploy Tolophonos S084
C8EMTAEC: t4Ua-4244aoc
Nationol Rosponae Ira Canada
CANUTECr 4 .1-4S6-446b
Outoido U.S. trod Canada
Chonruoe: 7034274887
NOTE, CHEMTHEO. C ,NU TEt3 nncl NhOiaral
H4spo chCenrsmorUencynum rotobo
tivad gray tno guar: of r eatnnoi omorpneioa
i inY6Ning m Vat SOU. WO, a><poauta ar atra[raru
in otvirrg thermals.
M-5 2.2537) tot zezisf0.
SODIUM BICARBONATE
1. Product Identification
Synonyms: Sodium hydrogen carbonate; sodium acid carbonate; baking soda; bicarbonate
of soda
CAS No.: 144-55-8
Molecular Weight: 84.01
Chemical Formula: NaHCO3
Product Codes:
J.T. Baker: 3506, 3508, 3509, 3510
Mallinckrodt: 7285, 7396, 7397, 7412, 7749, 7903
2. Comp+osition/Inf i rlr>matio on Ingredients
Ingredient CAS No Percent Hazardous
Sodium Bicarbonate 144-55-8
99 - 100% No
3. Hazards Identification
Emergency Overview
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1/12/2005

SODIUM BICARBONATE Page 2 of 7
As part of good industrial and personal hygiene and safety procedure, avoid all
unnecessary exposure to the chemical substance and ensure prompt removal from
skin, eyes and clothing.
SAF-T-DATA(tm) Ratings (Provided here for your convenience)
Health Rating: 1 - Slight
Flammability Rating: 1 - Slight
Reactivity Rating: 1 - Slight
Contact Rating: 1 - Slight
Lab Protective Equip: GOGGLES; LAB COAT
Storage Color Code: Green (General Storage)
Potential Health Effects
Inhalation:
High concentrations of dust may cause coughing and sneezing.
Ingestion:
Extremely large oral doses may cause gastrointestinal disturbances.
Skin Contact:
No adverse effects expected.
Eye Contact:
Contact may cause mild irritation, redness, and pain.
Chronic Exposure:
No information found.
Aggravation of Pre-existing Conditions:
No information found.
4. First Aid Measures
Inhalation:
Remove to fresh air. Get medical attention for any breathing difficulty.
Ingestion:
Give several glasses of water to drink to dilute. If large amounts were swallowed, get
medical advice.
Skin Contact:
Not expected to require first aid measures.
Eye Contact:
Wash thoroughly with running water. Get medical advice if irritation develops.
5. Fire Fighting Measures
Fire:
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SODIUM BICARBONATE Page 3 of 7
Not considered to be a fire hazard.
Explosion:
Not considered to be an explosion hazard.
Fire Extinguishing Media:
Use any means suitable for extinguishing surrounding fire.
Special Information:
Use protective clothing and breathing equipment appropriate for the surrounding fire.
6„ Accidental Release Measures
Ventilate area of leak or spill. Wear appropriate personal protective equipment as specified
in Section 8. Spills: Sweep up and containerize for reclamation or disposal. Vacuuming or
wet sweeping may be used to avoid dust dispersal. Small amounts of residue may be
flushed to sewer with plenty of water.
7s Handling and Storage
Keep in a well closed container stored under cold to warm conditions, 2 to 40 C, (36 to
104F). Protect against physical damage. Containers of this material may be hazardous when
empty since they retain product residues (dust, solids); observe all warnings and precautions
listed for the product.
8 Exposure Controls/Personal Protection
Airborne Exposure Limits:
None established.
Ventilation System:
In general, dilution ventilation is a satisfactory health hazard control for this substance.
However, if conditions of use create discomfort to the worker, a local exhaust system
should be considered.
Personal Respirators (NIOSH Approved):
For conditions of use where exposure to dust or mist is apparent and engineering controls
are not feasible, a particulate respirator (NIOSH type N95 or better filters) may be worn. If
oil particles (e.g. lubricants, cutting fluids, glycerine, etc.) are present, use a NIOSH type R
or P filter. For emergencies or instances where the exposure levels are not known, use a
full -face positive -pressure, air -supplied respirator. WARNING: Air -purifying respirators do
not protect workers in oxygen -deficient atmospheres.
Skin Protection:
Wear protective gloves and clean body -covering clothing.
Eye Protection:
Use chemical safety goggles. Maintain eye wash fountain and quick -drench facilities in
work area.
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SODIUM BICARBONATE Page 4 of 7
9. Physical and Chemical Properties
Appearance:
White crystalline powder.
Odor:
Odorless.
Solubility:
7.8g/100g water @ 18C (64F).
Density:
2.2
pH:
8.3 (0.1 molar @ 25C (77F))
Volatiles by volume @ 21C (70F):
0
Boiling Point:
Not applicable.
Melting Point:
60C (140F)
Vapor Density (Air=1):
No information found.
Vapor Pressure (mm Hg):
No information found.
Evaporation Rate (BuAc=1):
No information found.
10. Stability and Reactivity
Stability:
Stable under ordinary conditions of use and storage.
Hazardous Decomposition Products:
Gaseous carbon dioxide.
Hazardous Polymerization:
Will not occur.
Incompatibilities:
Reacts with acids to form carbon dioxide. Dangerous reaction with monoammonium
phosphate or a sodium -potassium alloy.
Conditions to Avoid:
Heat, moisture, incompatibles.
11. Toxicological Information
Investigated as a mutagen, reproductive effector. Oral rat LD50: 4220 mg/kg. Irritation
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SODIUM BICARBONATE
Page 5 of 7
data: human,skin, 30mg/3D-I mild, rabbit,eye, 100 mg/30 S, mild.
\Cancer Lists\
Ingredient
Sodium Bicarbonate (144-55-8)
---NTP Carcinogen ---
Known Anticipated IARC Category
No
No
None
12. Ecological Information
Environmental Fate:
No information found.
Environmental Toxicity:
No information found.
13. Disposal Considerations
Whatever cannot be saved for recovery or recycling should be managed in an appropriate
and approved waste disposal facility. Processing, use or contamination of this product may
change the waste management options. State and local disposal regulations may differ from
federal disposal regulations. Dispose of container and unused contents in accordance with
federal, state and local requirements.
14. Transport Information
Not regulated.
15. Regulatory Information
\Chemical Inventory Status - Part 1\
Ingredient TSCA EC Japan Australia
Sodium Bicarbonate (144-55-8) Yes Yes Yes Yes
\Chemical Inventory Status - Part 2\
Ingredient
Sodium Bicarbonate (144-55-8)
--Canada--
Korea DSL NDSL Phil.
Yes Yes No Yes
\Federal, State & International Regulations - Part 1\
-SARA 302- SARA 313
Ingredient RQ TPQ List Chemical Catg.
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SODIUM BICARBONATE Page 6 of 7
Sodium Bicarbonate (144-55-8)
No No No No
\Federal, State & International Regulations - Part 2\
-RCRA- -TSCA-
Ingredient CERCLA 261.33 8(d)
Sodium Bicarbonate (144-55-8) No No No
Chemical Weapons Convention: No
TSCA 12(b): No CDTA: No
SARA 311/312: Acute: No Chronic: No Fire: No Pressure: No
Reactivity: No (Pure / Solid)
Australian Hazchem Code: None allocated.
Poison Schedule: None allocated.
WHMIS:
This MSDS has been prepared according to the hazard criteria of the Controlled Products
Regulations (CPR) and the MSDS contains all of the information required by the CPR.
16. Other Information
NFPA Ratings: Health: 1 Flammability: 0 Reactivity: 0
Label Hazard Warning:
As part of good industrial and personal hygiene and safety procedure, avoid all unnecessary
exposure to the chemical substance and ensure prompt removal from skin, eyes and
clothing.
Label Precautions:
None.
Label First Aid:
Not applicable.
Product Use:
Laboratory Reagent.
Revision Information:
MSDS Section(s) changed since last revision of document include: 7.
Disclaimer:
*******************************************************************************
Mallinckrodt Baker, Inc. provides the information contained herein in good faith but
makes no representation as to its comprehensiveness or accuracy. This document is
intended only as a guide to the appropriate precautionary handling of the material by
a properly trained person using this product. Individuals receiving the information
must exercise their independent judgment in determining its appropriateness for a
particular purpose. MALLINCKRODT BAKER, INC. MAKES NO
t REPRESENTATIONS OR WARRANTIES, EITHER EXPRESS OR IMPLIED,
INCLUDING WITHOUT LIMITATION ANY WARRANTIES OF
MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE WITH
RESPECT TO THE INFORMATION SET FORTH HEREIN OR THE PRODUCT
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SODIUM BICARBONATE
Page 7 of 7
T WHICH THE INFORMATION REFERS. ACCORDINGLY, MALLINCICRODT
BAKER, INC. WILL NOT BE RESPONSIBLE FOR DAMAGES RESULTING
FROM USE OF OR RELIANCE UPON THIS INFORMATION.
*******************************************************************************
Prepared by: Environmental Health & Safety
Phone Number: [phone] (U.S.A.)
http://www.mallehem.com/msds/englishhtml/s2954.htm 1/12/2005

SODIUM HYDROXIDE Page 1 of 8
MSDS Number: S4034 * * * * * Effective Date: 07/07/04 * * * * * Supercedes: 05/11/04
Material Safety Data Sheet
From: Mallinckrodt Baker, Inc.
222 Rod School Lana
Phillipsburg. NJ 08136S
i Mallinckrodt A CHEMICALS a�.I.� @1
S
24 Hour Emorgonoy rolophorM:945 654 2r151
CteE►lTell•C:9- OO-4244300
doll nol Roo m:too in Canadtr
CRPUITEC= 4134964646
Ouledde U.B. and ennuis
ebnmteec: 7024274131
PtOTE: GHEMTi1EC. CANUTE° and t3al r i
Rowers a Como: Qm4rnar cy numhoro m•be
unotl on+p Ott* wore a? chemical :margin ao
1f19ONift3 b toff& Wait Ion. nocieslion Or 11611fNDne
ineolvi)o ohoentols.
All non.ernergency o aliens t ould bedifottCd to Cusrcxrrttxr Se co it i>OO582.2637j for amistante.
SODIUM HYDROXIDE
10 Product Identification
Synonyms: Caustic soda; lye; sodium hydroxide solid; sodium hydrate
CAS No.: 1310-73-2
Molecular Weight: 40.00
Chemical Formula: NaOH
Product Codes:
J.T. Baker: 3717, 3718, 3721, 3722, 3723, 3728, 3734, 3736, 5045, 5565
Mallinckrodt: 7001, 7680, 7708, 7712, 7772, 7798
20 Composition/Information on Ingredients
Ingredient CAS No Percent Hazardous
Sodium Hydroxide
3. Hazards Identification
Emergency Overview
1310-73-2
99 - 100% Yes
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SODIUM HYDROXIDE Page 2 of 8
POISON! DANGER! CORROSIVE. MAY BE FATAL IF SWALLOWED.
HARMFUL IF INHALED. CAUSES BURNS TO ANY AREA OF CONTACT.
REACTS WITH WATER, ACIDS AND OTHER MATERIALS.
SAF-T-DATA(tm) Ratings (Provided here for your convenience)
Health Rating: 4 - Extreme (Poison)
Flammability Rating: 0 - None
Reactivity Rating: 2 - Moderate
Contact Rating: 4 - Extreme (Corrosive)
Lab Protective Equip: GOGGLES & SHIELD; LAB COAT & APRON; VENT HOOD;
PROPER GLOVES
Storage Color Code: White Stripe (Store Separately)
Potential Health Effects
Inhalation:
Severe irritant. Effects from inhalation of dust or mist vary from mild irritation to serious
damage of the upper respiratory tract, depending on severity of exposure. Symptoms may
include sneezing, sore throat or runny nose. Severe pneumonitis may occur.
Ingestion:
Corrosive! Swallowing may cause severe burns of mouth, throat, and stomach. Severe
scarring of tissue and death may result. Symptoms may include bleeding, vomiting,
diarrhea, fall in blood pressure. Damage may appears days after exposure.
Skin Contact:
Corrosive! Contact with skin can cause irritation or severe bums and scarring with greater
exposures.
Eye Contact:
Corrosive! Causes irritation of eyes, and with greater exposures it can cause burns that may
result in permanent impairment of vision, even blindness.
Chronic Exposure:
Prolonged contact with dilute solutions or dust has a destructive effect upon tissue.
Aggravation of Pre-existing Conditions:
Persons with pre-existing skin disorders or eye problems or impaired respiratory function
may be more susceptible to the effects of the substance.
4. First Aid Measures
Inhalation:
Remove to fresh air. If not breathing, give artificial respiration. If breathing is difficult, give
oxygen. Call a physician.
Ingestion:
DO NOT INDUCE VOMITING! Give large quantities of water or milk if available. Never
give anything by mouth to an unconscious person. Get medical attention immediately.
Skin Contact:
Immediately flush skin with plenty of water for at least 15 minutes while removing
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SODIUM HYDROXIDE Page 3 of 8
contaminated clothing and shoes. Call a physician, immediately. Wash clothing before
reuse.
Eye Contact:
Immediately flush eyes with plenty of water for at least 15 minutes, lifting lower and upper
eyelids occasionally. Get medical attention immediately.
Note to Physician:
Perform endoscopy in all cases of suspected sodium hydroxide ingestion. In cases of severe
esophageal corrosion, the use of therapeutic doses of steroids should be considered. General
supportive measures with continual monitoring of gas exchange, acid -base balance,
electrolytes, and fluid intake are also required.
5. Fire Fighting Measures
Fire:
Not considered to be a fire hazard. Hot or molten material can react violently with water.
Can react with certain metals, such as aluminum, to generate flammable hydrogen gas.
Explosion:
Not considered to be an explosion hazard.
Fire Extinguishing Media:
Use any means suitable for extinguishing surrounding fire. Adding water to caustic solution
generates large amounts of heat.
Special Information:
In the event of a fire, wear full protective clothing and NIOSH-approved self-contained
breathing apparatus with full facepiece operated in the pressure demand or other positive
pressure mode.
6. Accidental Release Measures
Ventilate area of leak or spill. Keep unnecessary and unprotected people away from area of
spill. Wear appropriate personal protective equipment as specified in Section 8. Spills: Pick
up and place in.a suitable container for reclamation or disposal, using a method that does
not generate dust. Do not flush caustic residues to the sewer. Residues from spills can be
diluted with water, neutralized with dilute acid such as acetic, hydrochloric or sulfuric.
Absorb neutralized caustic residue on clay, vermiculite or other inert substance and package
in a suitable container for disposal.
US Regulations (CERCLA) require reporting spills and releases to soil, water and air in
excess of reportable quantities. The toll free number for the US Coast Guard National
Response Center is [phone].
7. Handling and Storage
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SODIUM HYDROXIDE
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Keep in a tightly closed container. Protect from physical damage. Store in a cool, dry,
ventilated area away from sources of heat, moisture and incompatibilities. Always add the
caustic to water while stirring; never the reverse. Containers of this material may be
hazardous when empty since they retain product residues (dust, solids); observe all
warnings and precautions listed for the product. Do not store with aluminum or magnesium.
Do not mix with acids or organic materials.
8. Exposure Controls/Personal Protectio
Airborne Exposure Limits:
- OSHA Permissible Exposure Limit (PEL):
2 mg/m3 Ceiling
- ACGIH Threshold Limit Value (TLV):
2 mg/m3 Ceiling
Ventilation System:
A system of local and/or general exhaust is recommended to keep employee exposures
below the Airborne Exposure Limits. Local exhaust ventilation is generally preferred
because it can control the emissions of the contaminant at its source, preventing dispersion
of it into the general work area. Please refer to the ACGIH document, Industrial
Ventilation, A Manual of Recommended Practices, most recent edition, for details.
Personal Respirators (NIOSH Approved):
If the exposure limit is exceeded and engineering controls are not feasible, a half facepiece
particulate respirator (NIOSH type N95 or better filters) may be worn for up to ten times the
exposure limit or the maximum use concentration specified by the appropriate regulatory
agency or respirator supplier, whichever is lowest.. A full -face piece particulate respirator
(NIOSH type N100 filters) may be worn up to 50 times the exposure limit, or the maximum
use concentration specified by the appropriate regulatory agency, or respirator supplier,
whichever is lowest. If oil particles (e.g. lubricants, cutting fluids, glycerine, etc.) are
present, use a NIOSH type R or P filter. For emergencies or instances where the exposure
levels are not known, use a full-facepiece positive -pressure, air -supplied respirator.
WARNING: Air -purifying respirators do not protect workers in oxygen -deficient
atmospheres.
Skin Protection:
Wear impervious protective clothing, including boots, gloves, lab coat, apron or coveralls,
as appropriate, to prevent skin contact.
Eye Protection:
Use chemical safety goggles and/or a full face shield where splashing is possible. Maintain
eye wash fountain and quick -drench facilities in work area.
9. Physical and Chemical Properties
Appearance:
White, deliquescent pellets or flakes.
Odor:
Odorless.
Solubility:
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SODIUM HYDROXIDE Page 5 of 8
111 g/100 g of water.
Specific Gravity:
2.13
pH:
13 - 14 (0.5% soln.)
% Volatiles by volume @ 21C (70F):
0
Boiling Point:
1390C (2534F)
Melting Point:
318C (604F)
Vapor Density (Air=1):
> 1.0
Vapor Pressure (mm Hg):
Negligible.
Evaporation Rate (BuAc=1):
No information found.
10. Stability and Reactivity
Stability:
Stable under ordinary conditions of use and storage. Very hygroscopic. Can slowly pick up
moisture from air and react with carbon dioxide from air to form sodium carbonate.
Hazardous Decomposition Products:
Sodium oxide. Decomposition by reaction with certain metals releases flammable and
explosive hydrogen gas.
Hazardous Polymerization:
Will not occur.
Incompatibilities:
Sodium hydroxide in contact with acids and organic halogen compounds, especially
trichloroethylene, may causes violent reactions. Contact with nitromethane and other similar
nitro compounds causes formation of shock -sensitive salts. Contact with metals such as
aluminum, magnesium, tin, and zinc cause formation of flammable hydrogen gas. Sodium
hydroxide, even in fairly dilute solution, reacts readily with various sugars to produce
carbon monoxide. Precautions should be taken including monitoring the tank atmosphere
for carbon monoxide to ensure safety of personnel before vessel entry.
Conditions to Avoid:
Moisture, dusting and incompatibles.
11. Toxicological Information
Irritation data: skin, rabbit: 500 mg/24H severe; eye rabbit: 50 ug/24H severe; investigated
as a mutagen.
\Cancer Lists\
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SODIUM HYDROXIDE
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Ingredient
---NTP Carcinogen ---
Known Anticipated IARC Category
Sodium Hydroxide (1310-73-2) No No None
12 Ecological Information
Environmental Fate:
No information found.
Environmental Toxicity:
No information found.
13. Disposal Considerations
Whatever cannot be saved for recovery or recycling should be handled as hazardous waste
and sent to a RCRA approved waste facility. Processing, use or contamination of this
product may change the waste management options. State and local disposal regulations
may differ from federal disposal regulations. Dispose of container and unused contents in
accordance with federal, state and local requirements.
14. Transport Information
Domestic (Land, D.O.T.)
Proper Shipping Name: SODIUM HYDROXIDE, SOLID
Hazard Class: 8
UN/NA: UN1823
Packing Group: II
Information reported for product/size: 300LB
International (Water, I.M.O.)
Proper Shipping Name: SODIUM HYDROXIDE, SOLID
Hazard Class: 8
UN/NA: UN1823
Packing Group: II
Information reported for product/size: 300LB
15. Regulatory Information
\Chemical Inventory Status - Part 1\
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SODIUM HYDROXIDE Page 7 of 8
Ingredient TSCA EC Japan Australia
Sodium Hydroxide (1310-73-2) Yes Yes Yes Yes
\Chemical Inventory Status - Part 2\
--Canada--
Ingredient Korea DSL NDSL Phil.
Sodium Hydroxide (1310-73-2) Yes Yes No Yes
\Federal, State & International Regulations - Part 1\
-SARA 302- SARA 313
Ingredient RQ TPQ List Chemical Catg.
Sodium Hydroxide (1310-73-2) No No No No
\Federal, State & International Regulations - Part 2\
-RCRA- -TSCA-
Ingredient CERCLA 261.33 8(d)
Sodium Hydroxide (1310-73-2) 1000 No No
Chemical Weapons Convention: No TSCA 12(b): No CDTA: No
SARA 311/312: Acute: Yes Chronic: No Fire: No Pressure: No
Reactivity: Yes (Pure / Solid)
Australian Hazchem Code: 2R
Poison Schedule: S6
WHIVHS:
This MSDS has been prepared according to the hazard criteria of the Controlled Products
Regulations (CPR) and the MSDS contains all of the information required by the CPR.
16. Other Information
NFPA Ratings: Health: 3 Flammability: 0 Reactivity: 1
Label Hazard Warning:
POISON! DANGER! CORROSIVE. MAY BE FATAL IF SWALLOWED. HARMFUL IF
INHALED. CAUSES BURNS TO ANY AREA OF CONTACT. REACTS WITH
WATER, ACIDS AND OTHER MATERIALS.
Label Precautions:
Do not get in eyes, on skin, or on clothing.
Do not breathe dust.
Keep container closed.
Use only with adequate ventilation.
Wash thoroughly after handling.
Label First Aid:
If swallowed, DO NOT INDUCE VOMITING. Give large quantities of water. Never give
anything by mouth to an unconscious person. In case of contact, immediately flush eyes or
skin with plenty of water for at least 15 minutes while removing contaminated clothing and
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SODIUM HYDROXIDE Page 8 of 8
shoes. Wash clothing before reuse. If inhaled, remove to fresh air. If not breathing give
artificial respiration. If breathing is difficult, give oxygen. In all cases get medical attention
immediately.
Product Use:
Laboratory Reagent.
Revision Information:
MSDS Section(s) changed since last revision of document include: 3.
Disclaimer:
*******************************************************************************
Mallinckrodt Baker, Inc. provides the information contained herein in good faith but
makes no representation as to its comprehensiveness or accuracy. This document is
intended only as a guide to the appropriate precautionary handling of the material by
a properly trained person using this product. Individuals receiving the information
must exercise their independent judgment in determining its appropriateness for a
particular purpose. MALLINCKRODT '::'AKER, INC. MAKES NO
REPRESENTATIONS OR WARRANTIES, EITHER EXPRESS OR IMPLIED,
INCLUDING WITHOUT LIMITATION ANY WARRANTIES OF
MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE WITH
RESPECT TO THE INFORMATION SET FORTH HEREIN OR THE PRODUCT
TO WHICH THE INFORMATION REFERS. ACCORDINGLY, MALLINCKRODT
BAKER, INC. WILL NOT BE RESPONSIBLE FOR DAMAGES RESULTING
FROM USE OF OR RELIANCE UPON THIS INFORMATION.
*******************************************************************************
Prepared by: Environmental Health & Safety
Phone Number: [phone] (U.S.A.)
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