WI0300065_Regional Office Historical File Pre 2018

•
Michael F. Easley, Governor
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
Coleen Sullins, Director
Division of Water Quality
January 11, 2008
Mr. Forrest Stevenson
Norfolk Southern Railway Company
110 Franklin Road, SE, Box 13
Roanoke, VA 24042-0013
RE: Issuance of Injection Well Permit WI0300065
Dear Mr. Stevenson:
TECEOWE
uI JAN 3 0 2008
NC DENR MRO
DWQ - Aquifer Protection
In accordance with the application submitted on August 6, 2007, we are forwarding permit
number WI0300065. This permit is for the injection of RegenOxTM and ORC AdvancedTM to
remediate groundwater contaminated with petroleum hydrocarbons at the Virginia Avenue Auto
and Wrecker at 201 W. Virginia Avenue, Bessemer City, Gaston County, North Carolina.
This permit shall be effective from the date of issuance until January 31, 2010, and shall be
subject to the conditions and limitations stated therein, including the requirement to submit a
final project evaluation as stated in PART VII — MONITORING AND REPORTING
REQUIREMENTS. Please note that some of the monitoring requirements have changed from
your application. Please read the entire permit to ensure that you are aware of all compliance
requirements of the permit. You will need to notify this office by telephone 48 hours prior to
initiation of operation of the facility. In order to continue uninterrupted legal use of the injection
facility for the stated purpose, you must submit an application to renew the permit 120 days prior
to its expiration date.
If you have any questions regarding your permit please feel free to contact me at [phone].
Sincerely,
Cg C-07
Qu Qi, P.G.
Underground Injection Control
Program Manager
cc: Suzanne Bailey — Marshall Miller & Associates
eoresvilllle °egional office
CO-UIC files
Enclosures
NorthCarolina
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 A WELL FOR INJECTION
F
L In accordance v ith tie provisions of Article 7, Chapter 87; Article 21, Chapter 143, and
other- apLaw plicable,s Rules, and Regulations
PERMISSION IS HEREBY GRANTED TO
Norfolk Southern Railway Company
FOR THE CONSTRUCTION AND OPERATION OF TYPE 51 INJECTION WELLS, defined
in Title 15A North Carolina Administrative Code 2C .0209(e)(3)(C), to inject RegenOx and
ORC Advanced, to remediate groundwater contaminated with petroleum hydrocarbons. These
injection wells/points will be located at 201 W. Virginia Avenue, Bessemer City, Gaston County,
North Carolina, and will be operated in accordance with the application submitted August 6,
2007, which is filed with the Department of Environment and Natural Resources and is
considered a part of this permit.
This permit is for Construction and Operation only, and does not waive any provisions of the
Water Use Act or any other applicable Laws, Rules, or Regulations. Operation and use of an
injection well shall be in compliance with Title 15A North Carolina Administrative Code 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 January 31,
2010, and shall be subject to the specified conditions and limitations set forth in Parts I through
X hereof.
vikkr—
Permit issued this the day of ,, r
trA
,ok.c J. uSt21-S
Coleen H. Sullins, Director
Division of Water Quality
By Authority of the Environmental Management Commission.
, 2008.
Permit No. WI0300065 PAGE 1
ver.8/07 AP/UIC-6

e
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 704-663-1699.
Permit No. WI0300065 PAGE 2
ver.8/07 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. WI0300065 PAGE 3
ver.8/07 AP/UIC-6

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 anyproperty, 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 following monitoring plan shall be followed. A new down -gradient monitoring well
should be installed twenty to thirty feet away from the proposed injection area; an one -inch
geo-probe well is acceptable. New well and MW-1, MW-2, MW-3, and MW-4 will be
sampled before injection and one (1) month after the third injection and three months after
the fourth injection followed by semi-annual sampling until the monitoring data demonstrates
that the chemical reaction is complete and geochemical conditions returned to the pre -
injection state. The monitoring wells shall be sampled for the following parameters:
a) Volatile and semi -volatile Organic Compounds (EPA Method 8260 and 8270);
b) RCRA metal (will only be sampled for three times: pre -injection, one month after
the third injection, and. final sampling event);
c) Temperature;
d) Dissolved oxygen;
e) Oxidation-reduction potential;
f) pH;
g) Specific conductivity;
h) Sulfate;
i) Sodium, total and dissolved iron.
2. 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.
3. The Permittee shall submit an Injection Event Record within 30 days of completing each
injection.
4. The Permittee shall produce a final project evaluation within 9 months after completing all
Permit No. WI0300065 PAGE 4
ver.8/07 AP/UIC-6

injection -related activity associated with this permit or produce a project interim evaluation
before submitting a renewal application for this permit. This document shall assess the
injection projects findings in a written summary. The final project evaluation shall also
contain monitoring well sampling data, contaminant plumemaps and potentiometric surface
maps.
5. 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
Mooresville, NC 28115
6. 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 704-663-1699, 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.
7. 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.
8. 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
In order to continue uninterrupted legal use of the injection facility for the stated purpose, the
Permittee must submit an application to renew the permit 120 days prior to its expiration date.
PART 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
Permit No. WI0300065 PAGE 5
ver.8/07 AP/UIC-6

4
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
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. Some effects reported to be associated with the product proposed to be used are as follows:
exposure can cause severe irritation and possibly burns to the skin, eyes, nose, throat,
lungs, and gastrointestinal tract.
2. If the product is released into the environment in a way that could result in a suspension of
fine solid or liquid particles (e.g., grinding, blending, vigorous shaking or mixing), then
proper personal protective equipment should be used.
Permit No. WI0300065 PAGE 6
ver.8/07 AP/UIC-6

3..Persons working with these products should at least wear goggles or a face shield, gloves,
and protective clothing. Face and body protection should be used for anticipated splashes
or sprays.
4. Eating, drinking, smoking, handling contact lenses, and applying cosmetics should not be
permitted in the application area during or immediately following application. Safety
controls should be in place to ensure that the check valve and the pressure delivery
systems are working properly.
5. The Material Safety Data Sheets should be followed to prevent incompatible or adverse
reactions and injuries.
6. Access to the area of application should be limited to the workers applying the product. In
order to minimize exposure to unprotected individuals, measures should be taken to
prevent access to the area of application.
7. Efforts should be made to prevent contamination of existing or future wells and surface
waters that may be located near the application area.
Permit No. WI0300065 PAGE 7
ver.8/07 AP/UIC-6

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AQUIFER PROTECTION ' : L STAFF REPORT
011E
Date: August 31, 2007
To: Aquifer Protection Central Office
Central Office Reviewer: Peter Pozzo
Regional Login No:
L GENERAL INFORMATION
1. This application is (check all that apply): ❑ New ® Renewal
❑ Minor Modification ® Major Modification
County: Mecklenburg
Permittee: Norfolk Southern
Jed Name: Virginia Ave Auto Wrecker
Application No.: WI0300065
❑ Surface Irrigation n Reuse n Recycle ❑ High Rate Infiltration ❑ Evaporation/Infiltration Lagoon
❑ Land Application of Residuals
❑ Attachment B included ❑ 503 regulated ❑ 503 exempt
n Distribution of Residuals n Surface Disposal
n 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. Person contacted and contact information:
c. Site visit conducted by:
d. Inspection Report Attached: ❑ Yes or /1 No.
2. Is the following information entered into the BIMS record for this application correct?
n Yes or ® No. If no, please complete the following or indicate that it is correct on the current application.
For Treatment Facilities:
a.
b.
c.
d.
Location:
Driving Directions:
USGS Quadrangle Map name and number:
Latitude: Longitude:
e. Regulated Activities / Type of Wastes (e.g., subdivision, food processing, municipal wastewater):
For Disposal and Injection Sites:
(If multiple sites either indicate which sites the information applies to, copy and paste a new section into the
document for each site, or attach additional pages for each site)
a. Location(s): ok
b. Driving Directions: From Mooresville, I77 south to 185 south to exit #13 for Bessemer City, go north on
Edgewood, continue onto Athenia Pl, then left (west) onto Alabama Ave. Go right (north) onto 13th and the
site is just through the tunnel under the railroad and on the left.
c. USGS Quadrangle Map name and number: Bessemer City
d. Latitude: ok Longitude: ok
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FOW10300106 staff report Norfolk Southern Virginia Ave renewal 8-07

AQUIFER PROTECTION REGIONAL STAFF REPORT
II. & III. - deleted
IV. INJECTION WELL PERMIT APPLICATIONS (Complete these two sections for all systems that use injection
wells, including closed -loop groundwater remediation effluent injection wells, in situ remediation injection wells, and heat
pump injection wells.)
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? n Yes ® No
3. Are there any potential pollution sources that may affect injection? a Yes ❑ No
What is/are the pollution source(s)? This injection is for remediation at a UST site into the plume. What is the
distance of the injection well(s) from the pollution source(s)? 0 ft.
4. What is the minimum distance of proposed injection wells from the property boundary? —25 ft.
5. Quality of drainage at site: ® Good ❑ Adequate ❑ Poor
6. Flooding potential of site: ® Low ❑ Moderate ❑ High
7. For groundwater remediation systems, is the proposed and/or existing groundwater monitoring program
(number of wells, frequency of monitoring, monitoring parameters, etc.) adequate? ® Yes ❑ No. Attach
map of existing monitoring well network if applicable. If No, explain and recommend any changes to the
groundwater monitoring program:
8. Does the map presented represent the actual site (property lines, wells, surface drainage)? ® Yes or ❑ No. If
no or no map, please attach a sketch of the site. Show property boundaries, buildings, wells, potential pollution
sources, roads, approximate scale, and north arrow.
Injection Well Permit Renewal And Modification Only:
1. For heat pump systems, are there any abnormalities in heat pump or injection well operation (e.g. turbid water,
failure to assimilate injected fluid, poor heating/cooling)?
❑ Yes ❑ No. If yes, explain:
2. For closed -loop heat pump systems, has system lost pressure or required make-up fluid since permit issuance
or last inspection? n Yes n No. If yes, explain:
3. For renewal or modification of groundwater remediation permits (of any type), will
continued/additional/modified injections have an adverse impact on migration of the plume or management of
the contamination incident? n Yes ® No. If yes, explain:
FORM: WI0300106 staff report Norfolk Southern Virginia Ave renewal 8-07 2

AQUIFER PROTECTION REGIONAL STAFF REPORT
4. Drilling contractor: Name:
Address:
Certification number:
5. Complete and attach Well Construction Data Sheet.
V. EVAL UATIONAND RECOMMENDATIONS
1. Provide any additional narrative regarding your review of the application.:
Regional evaluation was conducted in the office and consisted of review of the pollution incident file for
this site, the UIC file, and discussion with the current project manager with DWM-UST. Based on
information reviewed, the proposed renewal represents a major modification to the injection strategy, as the
old method was simply use of ORC socks. This application proposes numerous ORC injection points in an
effort to reduce benzene to levels below the GCLs in order to get risk -based site closure from DWM.
There are no water supply wells or sensitive receptors in the vicinity. Based on the maps in the application
that depict shallow flow, there are no monitoring wells downgradient of the area of MW2, which is the
single well that has contamination over the GCLs and is the area for the injection. However, given the
localized area of concern, the limited area for the injection, and the clay -rich materials, this is not
anticipated to be a significant problem as transport will be limited. The DWM case manager supports the
injection effort.
2. Attach Well Construction Data Sheet - if needed information is available
3. Do you foresee any problems with issuance/renewal of this permit? ❑ Yes ® No. If yes, please explain
briefly.
4. List any items that you would like APS Central Office to obtain through an additional information request.
Make sure that you provide a reason for each item:
Item
Reason
Hydraulic capacity information (L.5., page 8 of
their application report)
The application simply refers to assumed values.
There should be slug test data available in the
CSA or such tests are easily conducted to better
approximate needs for the injection.
FORM: WI0300106 staff report Norfolk Southern Virginia Ave renewal 8-07
3

AQUIFER PROTECTION REGIONAL STAFF REPORT
5. List specific Permit conditions that you recommend to be removed from the permit when issued. Make sure
that you provide a reason for each condition:
Condition
Reason
6. List specific special conditions or compliance schedules that you recommend to be included in the permit when
issued. Make sure that you provide a reason for each special condition:
Condition
Reason
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; n Deny. If deny, please state reasons:
8. Signature of report preparer(s): Andrew Pitner
Signature of APS regional supervisor: Andrew Pitner
Date: August 31, 2007
ADDITIONAL REGIONAL STAFF REVIEW ITEMS
FORM: WI03 00106 staff report Norfolk Southern Virginia Ave renewal 8-07 4

AQUIFER PROTECTION SECTION
APPLICATION REVIEW REQUEST FORM
Date: August 10, 2007
To: ❑ Landon Davidson, ARO-APS
❑ Art Barnhardt, FRO-APS
® Andrew Pitner, MRO-APS
❑ Jay Zimmerman, RRO-APS
From: Peter Pozzo , Groundwater Protection Unit
Telephone: [phone]
E-Mail: [e-mail]
❑ David May, WaRO-APS
❑ Charlie Stehman, WiRO-APS
❑ Sherri Knight, WSRO-APS
Fax: [phone]
ECEOWE
AUG 1 3 2007
A. Permit Number: WI0300065
B. Owner: Norfolk Southern Railway Company
C. Facility/Operation: Virgina Avenue Auto & Wrecker
❑ Proposed ® Existing
NC DENR MRO
DWQ -Aquifer Protection
❑ Facility ❑ Operation
D. Application:
1. Permit Type: ❑ Animal ❑ Surface Irrigation ❑ Reuse ❑ H-R Infiltration
❑ Recycle ❑ I/E Lagoon ❑ GW Remediation (ND)
(5I) in -situ groundwater remediation REGENOX, ORC
For Residuals: ❑ Land App. ❑ D&M ❑ Surface Disposal
❑ 503 ❑ 503 Exempt ❑ Animal
2. Project Type: ❑ New ❑ Major Mod. ❑ .Minor Mod. ❑ Renewal ® Renewal w/ Mod.
E. Comments/Other Information: n 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:
FORM: APSARR 02/06 Page 1 of 1

Michael F. Easley, Governor
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
August 9, 2007
FORREST STEVENSON
NORFOLK SOUTHERN RAILWAY COMPANY
110 FRANKLIN ROAD, SE BOX 13
ROANOKE VA 24042-0013
Dear Mr. Stevenson:
C
j� LC, �CD, sinp
AUG 1 3 2007
NC DENR MRO
DWQ - A uifer Protection
Subject: Acknowledgement of Application No. WI0300065
Virginia Avenue Auto & Wrecker
Injection In situ Groundwater Remediation Well (5I)
Gaston County
The Aquifer Protection Section of the Division of Water Quality (the Division) acknowledges receipt of
your permit application and supporting materials on August 6, 2007. This application package has been
assigned the number listed above and will be reviewed by Peter Pozzo.
The reviewer will perform a detailed review and contact you with a'request for additional information if
necessary. To ensure the maximum efficiency in processing permit applications, the Division requests
your assistance in providing a timely and complete response to any additional information requests.
Please be aware that the Division's Regional Office, copied below, must provide recommendations prior
to final action by the Division. Please also note at this time, processing permit applications can take as
long as 60 - 90 days after receipt of a complete application.
If you have any questions, please contact Peter Pozzo by phone at [phone] or by email at
[e-mail]. If the reviewer is unavailable, you may leave a message, and they will respond
promptly. Also note that the Division has reorganized. To review our new organizational chart, go to
http://h2o.enr.state.nc.us/documents/dwq orgchart.pdf.
PLEASE REFER TO '1HE ABOVE APPLICATION NUMBER WHEN MAKING INQUIRIES
ON THIS PROJECT.
For Debra J. Watts
Supervisor
cc: oresville Regional C?fI"ice, lurfel� I'rrct�ction Section
• pplication Ile WI0300065
Suzanne Bailey, Marshall Miller & Associates, 8371 Melrose Drive, Lenexa, KS 66214
ermit
Aquifer Protection Section 1636 Mail Service Center
Internet: www.ncwaterqualitv.org Location: 2728 Capital Boulevard
An Equal Opportunity/Affirmative Action Employer— 50% Recycled/10% Post Consumer Paper
'rector
uality
North Carolina
Naturally
Raleigh, NC 27699-1636 Telephone: [phone]
Raleigh, NC 27604 Fax 1: [phone]
Fax 2: [phone]
Customer Service: [phone]

State of North Carolina
Department of Environment and Natural Resoui
Division of Water Quality
APPLICATION FOR PERMIT TO CONSTRUCT AND/OR USE A
ECIodED
AUG 1 3 2007
NC DENR MRO
if
Type 51 Wells — In Situ Groundwater Remediation / Type 5T Wells — Tracer Injection
• Do not use this form for remediation systems that extract contaminated groundwater, treat it, and reinject the treated groundwater.
• Submit TWO copies of the completed application and all attachments to the address on the last page of this form.
• Any changes made to this form will result in the application package being returned.
Application Number (to be completed by DWQ):
I. GENERAL INFORMATION:
RECEIVED / DENR / DWQ
AQUIFFR'PRnTF(:TInN SECTION
AUG 0 6 2007
1. Applicant's Name (generally the responsible party): NORFOLK SOUTHERN RAILWAY COMPANY
2. Signing Official's Name: FORREST W. STEVENSON Title: ENGINEER
3. Mailing address of applicant: 110 FRANKLIN ROAD, SE, BOX 13
City: ROANOKE State: VA Zip: 24042-0013
Telephone number: 540 981-4236 Fax number: 540 981-5069
4. Property Owner's Name (if different from Applicant):
5. Property Owner's mailing address:
City: State: Zip:
6. Name and address of contact person who can answer questions about the proposed injection project:
Name: SUZANNE BAILEY Title: BRANCH MANAGER
Company: MARSHALL MILLER & ASSOCIATES
Address: 8371 MELROSE DRIVE
City: LENEXA State: KS Zip: 66214
Telephone number: 913 648-4424
Email Address: [e-mail]
H. PERMIT INFORMATION:
Fax number: 913 648-4763
1. Project is: L1 New VI Modification of existing permit ❑ Renewal of existing permit without modification
2. If this application is being submitted for renewal or modification to an existing permit, provide:
existing permit number WI0300065 and the issuance date 12/6/04
For renewalwithout modifications, fill out sections I & II only, sign the certification on the last page of this
form, and obtain the property owner's signature to indicate consent (if the applicant is not the owner).
UIC-5I/5T ver. 12-05 Page 1 of 7

APPLICATION FOR PERMIT TO CONSTRUCT AND/OR USE A WELL(S) FOR INJECTION
Type 5I Wells — In Situ Groundwater Remediation / Type ST Wells — Tracer Injection
III. INCIDENT & FACILITY DATA
A. FACILITY INFORMATION
I . Facility name: VIRGINIA AVENUE AUTO & WRECKER
2. Complete physical address of the facility: 201 W. VIRGINIA AVENUE
City: BESSEMER CITY County: GASTON State: NC Zip:28016
B. INCIDENT DESCRIPTION
1. Describe the source of the contamination:
Five gasoline underground storage tanks (USTs) and one kerosene UST were located at the Site, but were
removed in September 1998 and January 1999. Approximately 277 tons of petroleum hydrocarbon impacted soil
associated with the USTs was removed and the excavation pits were backfilled with clean material. Impacted'
soils remain at the site and may act as a source of petroleum contaminants during high groundwater levels.
2. List all contaminants present in soils or groundwater at the site (contaminants may be listed in groups, e.g.,
gasoline, diesel, jet fuel, fuel oil, chlorinated ethenes, chlorinated ethanes, metals, pesticides/herbicides, etc):
GASOLINE (BTEX)
3. Has LNAPL or DNAPL ever been observed at the site (even if outside the injection zone)?
❑ Yes If yes, list maximum measured separate phase thickness: feet
No If no, list maximum concentration of total VOCs observed at site: 91210 ppb
4. Agency managing the contamination incident:
UST Section ❑ Superfimd Section (including REC Program and DSCA sites)
L7 DWQ Aquifer Protection Section ❑ Solid Waste Section
❑Hazardous Waste Section El Other:
5. Incident number or other site number assigned by the agency managing the contamination incident:
Pollution Incident No. 19216
C. PERMITS
List all permits or construction approvals that have been issued for the facility or incident, including those not
directly related to the proposed injection operation:
1. Hazardous Waste Management program permits under RCRA: NONE
2. DWQ Non -Discharge or NPDES permits: NONE
3. County or DEH subsurface wastewater disposal permits: NONE
4. Other environmental permits required by state or federal law: NONE
UIC-5I/5T ver. 12-05 Page 2 of 7

APPLICATION FOR PERMIT TO CONSTRUCT AND/OR USE A WELL(S) FOR INJECTION
Type 51 Wells — In. Situ Groundwater Remediation / Type 5T Wells — 'Tracer Injection
IV. INJECTION DATA
A. INJECTION FLUID DATA
1. List all proposed injectants.
NOTE: Any substance to be injected as a tracer or to promote in situ remediation must be reviewed by the
Occupational and Environmental Epidemiology Section (OEES) of the Division of Public Health, Department of
Health and Human Services. Review the list of apvroved injectants or contact the UIC Program to determine if
the injectants you are proposing have been reviewed by OEES.
Injectant: REGEN OX (by Regenesis Co.)
Concentration at point of injection: 5.1% (1620 Ibs RegenOx in 1725 gal of water)
Injectant: ORC ADVANCED (by Regenesis Co.)
Concentration at point of injection: 30% solids (575 Ibs ORC Adv. in 161 gal water)
Inj ectant:
Concentration at point of injection-
Injectant:
Concentration at point of injection:
Inj ectant:
Concentration at point of injection:
2. Source of fluids used to dilute or chase the injectants listed above:
❑None
VI Municipal water supply
❑ Groundwater from private well or any well within'/4 mile of injection site
❑ Air
❑ Other:
3. If groundwater from a private well or any well within'/4 mile of injection site is to be used as the fluid source,
supply the following information:
a. Location/ID number of source well: N/A
b. Depth of source: N/A
c. Formation: N/A
d. Rock/Sediment type: N/A
e. In Attachment B, provide a current, complete chemical analysis of the water from the source well, including
analyses for all contaminants suspected or historically recognized in soil or groundwater on the site.
NOTE: If contaminated groundwater is to be used as the dilution or chase fluid, this is not the proper permit
application form. You must apply for a closed -loop groundwater remediation permit using application form
GWRS.
UIC-5I/5T ver. 12-05
Page 3 of 7

APPLICATION FOR PERMIT TO CONSTRUCT AND/OR USE A WELL(S) FOR INJE CTION
Type 5I Wells In Situ Groundwater Remediation / Type 5T Wells — Tracer Injection
B. PROPOSED OPERATING PARAMETERS
1. Duration of Injection:
Maximum number of separate injection events: 4
Expected duration of each injection event: 1 DAY
Expected duration between events (if more than one event): 2-4 WEEKS
2. Injection rate per well: UP TO 5 gallons per minute (gpm)
3. Total Injection volume: 1725 gallons per day (gpd); 1725 gallons per event (if separate events)
4. Injection pressure: < 1500 pounds/square inch (psi)
5. Temperature at point of injection: 70 (ambient) °F
6. Briefly describe how the above parameters will be measured and controlled:
Injection rates and pressures will be metered and/or pumping pressure and liquid volume
measurements will be continuously measured to calculate the injection rates.
7. Estimated hydraulic capacity of the well: 5
gpm
C. INJECTION WFI,I, CONSTRITCTTON DATA
1. Injection will be via:
❑ Existing well(s) proposed for use as an injection well. Provide the data in (2) through (6) below to the best of
your knowledge.
O Proposed well(s) to be constructed for use as an injection well. Provide the data in (2) through (6) below as
proposed construction specifications.
2. Well Drilling Contractor's Name: VIRONEX
NC Well Contractor Certification number: 3027
3. Date to be constructed: OCT- 01 W-tom ' 0•7 Number of borings: 9
Approximate depth of each boring (feet): 21
4. Screened interval/Injection interval of injection wells:
Depth: 9 to 21 feet below ground surface (if multiple intervals, indicate shallowest and deepest depth).
5. Well casing (N/A if injection is through direct push rods):
Type: ❑ PVC ❑ Stainless steel VA Other: N/A (INJECTION THROUGH DPT RODS)
Casing depth: to ft.
6. Grout (N/A if injection is through direct push rods):
Type: ❑ Cement ❑ Bentonite
Grout depth: to ft.
❑ Other: NIA (INJECTION THROUGH DPT RODS'
UIC-5I/5T ver. 12-05 Page 4 of 7

APPLICATION FOR PERMIT TO CONSTRUCT AND/OR USE A WELL(S) FOR INJE CTION
Type St Wells -- In Situ Groundwater Remediation / Type ST Wells — Tracer Injection
V. ATTACHMENTS
Provide the following items as attachments with the given headings:
A. HYDROGEOLOGIC DESCRIPTION
Provide a hydrogeologic description, soils description, and cross section of the subsurface to a depth that includes the
known or projected depth of contamination. The hydrogeologic description shall include:
(1) the regional geologic setting;
(2) significant changes in Ethology;
(3) the hydraulic conductivity, transmissivity, and specific yield of the aquifer to be used for injection, including a
description of the test(s) used to determine these parameters; and
(4) the depth to the mean seasonal high water table.
NOTE: G.S. 89E-18 requires that any geologic plans, reports, or documents in which the penforrnance is related to the
public welfare or safeguarding of the environment be prepared by a licensed geologist or subordinate under his or her
direction. G.S. 89E-13 requires that all drawings, reports, or documents involving geologic work which shall have been
prepared or approved by a licensed geologist or a subordinate under his or her direction be signed and sealed by him or
her.
B. INJECTION FLUID COMPOSITION
Describe the chemical, physical, biological and radiological characteristics of each injectant. Attach the Material Safety
Data Sheet (MSDS) for each injectant. If a private well or a well within '/a mile of the injection site is used as the source
well, include chemical analysis of source fluid here.
C. INJECTION RATIONALE
Attach a brief description of the rationale for selecting the injectants and concentrations proposed for injection, including:
(1) goals of the injection project;
(2) a description of the reactions between the injectants and the contaminants present including specific breakdown
products or intermediate compounds that may be formed by the injection; and
(3) summary results of modeling or testing performed to investigate the injectant's potential or susceptibility to change
(biological, chemical or physical) in the subsurface.
D. INJECTION PROCFDTJRF, AND F.QIJIPMF.NT
Provide a detailed description of all planned activities related to the proposed injection including but not limited to:
(1) construction plans and materials;
(2) operation procedures;
(3) a detailed diagram of the surface and subsurface portions of the system; and
(4) a planned injection schedule.
E. MONITORING PLAN
Provide a plan for monitoring the results of the injection, including:
(1) a list of existing and proposed monitoring wells to be used;
(2) a list of monitoring parameters and analytical methods to be used; and
(3) a schedule for sampling to monitor the proposed injection.
NOTE: The selected monitoring wells must be located so as to detect any movement of injection fluids, process by-
products, or formation fluids outside the injection area or zone. The monitoring parameters should include the target
contaminants as well as secondary or intermediate contaminants which may result from the injection and other
parameters which may serve to indicate the progress of the intended reactions, such as pH, ORP, dissolved oxygen, and
other electron acceptors and donors. The monitoring schedule should be consistent with the pace of the anticipated
reactions and rate of transport of the injectants and contaminants.
UIC-5I/5T ver. 12-05 Page 5 of 7

APPLICATION FOR PERMIT TO CONSTRUCT AND/OR USE A WELL(S) FOR INJE CTION
Type SI Wells — In Situ Groundwater Remediation / Type ST Wells .. Tracer Injection
F. WELL DATA
Provide a tabulation of data on all existing or abandoned wells within 'A mile of the injection well(s) which penetrate the
proposed injection zone, including, but not limited to, monitoring wells and wells proposed for use as injection wells.
Such data shall include a description of each well's use (water supply, monitoring, etc), total depth, screened or open
borehole depth interval, and well construction or abandonment record, if available.
G. MAPS
Attach the follotiving scaled, site -specific maps:
(1) Area map based on the most recent USGS 7.5' topographic map of the area, at a scale of 1:24,000 and
showing the location of the proposed injection site.
(2) Site map including:
a. all property boundaries;
b. all buildings within the property boundary;
c. existing and proposed injection wells or well field(s)
d. any existing sources of potential or known groundwater contamination, including waste storage,
treatment or disposal systems within'/4 mile of the injection well or well system;
e. all surface water bodies within '/ mile of the injection well or well system; and
f. all existing or abandoned wells within 'A mile of the injection well(s) which penetrate the proposed
injection zone, including, but not limited to, monitoring wells and wells proposed for use as injection
wells_
(3) Potentiometric surface map(s) including:
a. direction of groundwater movement
b. existing and proposed monitoring wells
c. existing and proposed injection wells
(4) Contaminant plume map(s) including:
a. the horizontal extent of the contaminant plume, including isoconcentration lines
b. existing and proposed monitoring wells
c. existing and proposed injection wells
(5) Cross-section(s) to the known or projected depth of contamination, including:
a. horizontal and vertical extent of the contaminant plume, including isoconcentration lines
b. major changes in lithology
UIC-5I/5T ver. 12-05 Page 6 of 7

APPLICATION FOR PERMIT TO CONSTRUCT AND/OR USE A WELL(S) FOR INJECTION
Type 51 Wells — Di Situ Groundwater Remediation / Type 5T Wells — Tracer Injection
VI. CERTIFICATION
I, FORREST W. STEVEN.SON,in .:; a.ai , 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. 1 am aware that there are significant penalties,
including the possibility of fines and imprisonment, for submitting false information. I agree to construct,
operate, maintain, repair, and if applicable, abandon the injection well(s) and all related appurtenances in
accordance with the approved specifications and conditions of the Permit.
Signature• �' _. Date:4440Sr `Lt Z .
Title: ENGINEER
If authorized agent is acting on behalf of the applicant, supply a letter signed by the applicant authorizing the
above agent.
VII. CONSENT OF PROPERTY OWNER (if the property is not owned by the applicant)
("Owner" means any person who holds the fee or other property rights in the well being constructed. A well is
real property and its construction on land shall be deemed to vest ownership in the land owner, in the absence of
contrail agreement in writing.)
I, i ,c:a na=sic Cif nron�I•,., as owner of the property on which the
injection well(s) are to be constructed and operated, hereby consent to allow the applicant to construct each
injection well as outlined in this application and agree that it shall be the responsibility of the applicant to ensure
that the injection well(s) conform to the Well Construction Standards (Title I5A NCAC 2C .0200)
Signature:
Title:
Date -
Submit TWO copies of the completed application package, including all attachments, to:
UIC Program
Aquifer Protection Section
North Carolina DENR-DWQ
1636 Mail Service Center
Raleigh, NC 27699-1636
Telephone [phone]
UIC-5I/5T ver.09-06 Page 7 of 7

UIC PERMIT NO. WI0300065
INJECTION PERMIT MODIFICATION APPLICATION
CLASS 5I WELL
Norfolk Southern Railway Company
Virginia Avenue Auto & Wrecker
201 W. Virginia Avenue
Bessemer City, Gaston County, North Carolina
Latitude: 35° 17' 5" North
Longitude: 81° 17' 2" West
August 2007
Prepared For:
RECEIVED / DENR / DWQ
AQUIFFR'PRnTFr..TInN SECTION
AUG 0 6 2007
NORFOLK SOUTHERN RAILWAY COMPANY
Mr. Forrest W. Stevenson
110 Franklin Road, SE, Box 13
Roanoke, Virginia 24042-0013
Norfolk Southern File No. 1-9-NC-BSMR-UT98.133-002
Prepared By:
MARSHALL MILLER & ASSOCIATES, INC.
8371 Melrose Drive
Lenexa, Kansas 66214
[phone]
MM&A Project No. NS1411

Norfolk Southern File No. 1--9-NC-BS 4R-UTQ . 13 -002
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 infoiuuation is true, accurate and complete. I am aware that
there are significant penalties, including the possibility of fines and imprisonment, for
submitting, false information. I agree to construct, operate, maintain, repair, and if
applicable, abandon the injection well and all related appurtenances in accordance with
the approved specifications and conditions of the Permit'
Forrest W. Stevensor.
Engineer Environmental Remediation
\torfolk Southern Railway Com.nia.nv
Signature of Well Owner or Authorized Agent)

TABLE OF CONTENTS PAGE
A. PERMIT APPLICANT 1
B. PROPERTY OWNER 1
C. STATUS OF APPLICANT 1
D. FACILITY (SITE) DATA 1
E. DECRIPTION OF INJECTION ACTIVITIES 1
F. DESCRIPTION OF SITE 2
G. HYDROGEOLOGIC DESCRIPTION 4
1. REGIONAL GEOLOGIC SETTING 5
2. SIGNIFICANT CHANGES IN LITHOLOGY 5
3. HYDRAULIC CONDUCTIVITY 5
4. DEPTH TO MEAN SEASONAL HIGH WATER TABLE 5
5. TRANSMISSIVITY / SPECIFIC YIELD 5
H. MONITORING PROCEDURE 6
I. WELL USE 7
J. CONSTRUCTION DATA 7
K. OTHER WELL DATA 7
L. PROPOSED OPERATING DATA 7
1. INJECTION RATE: 7
2. INJECTION VOLUME: 7
3. INJECTION PRESSURE: 8
4. INJECTION TEMPERATURE: 8
5. HYDRAULIC CAPACITY OF THE WELL 8
6. EXPECTED LIFETIME OF THE INJECTION FACILITY 9
7. DESCRIPTION OF MEASUREMENTS/CONTROLS 9
M. INJECTION RELATED EQUIPMENT 9
N. LOCATION OF WELL(S) 9

Norfolk Southern Railway Company
Injection Well Permit Modification for RegenOx® and ORC® Remediation
Bessemer City, NC
August 2007
TABLE OF CONTENTS (Continued) PAGE
O. INJECTION FLUID DATA 9
1. FLUID SOURCE 10
2. CHEMICAL, PHYSICAL, BIOLOGICAL, AND RADIOLOGICAL
CHARACTERISTICS OF INJECTION FLUID. 10
P. PERMIT LIST 10
Q. REFERENCES 10
FIGURES AND TABLES
APPENDICES

APPLICATION FOR MODIFICATION TO
UIC PERMIT NO. WI0300065
TO CONSTRUCT AND/OR USE A WELL(S) FOR INJECTION
Class 5I Wells
This permit modification application was prepared in accordance with the provisions of
NCAC Title 15A: 02C.0200. The following sections provide a detailed description of all
planned activities relating to the proposed four injections of oxygen release compounds
(ORC) which constitute a change and/or present additional information not included in the
UIC Permit No. WI0300065.
MM&A proposes three injections of Regenesis brand RegenOx® in -situ oxidant and one
injection of Advanced Formula Oxygen Release Compound® (ORC Advanced') into the
subsurface surrounding monitoring well MW-2 to reduce the hydrocarbon levels in soils and
ground water at the former UST Site.
A. PERMIT APPLICANT
No Change.
B. PROPERTY OWNER
No change.
C. STATUS OF APPLICANT
No change.
D. FACILITY (SITE) DATA
No change.
E. DECRIPTION OF INJECTION ACTIVITIES
The proposed work consists of four injection events: three injections of Regenesis brand
RegenOx® in -situ oxidant into the subsurface surrounding monitoring well MW-2 and then
1
INNEJ la?

Norfolk Southern Railway Company
Injection Well Permit Modification for RegenOx® and ORC° Remediation
Bessemer City, NC
August 2007
one final injection of ORC Advanced® into the same vicinity. The injection area includes
approximately 400 square feet with a vertical thickness of 12 feet (9 to 21 feet below ground
surface (bgs) (Figure 2). A total of nine injection points spaced on approximate 8 foot
centers will be used for the injection events (Figure 3). The oxidant material will be
injected through direct push borings on one -foot intervals from the bottom up starting at 21
feet below grade and terminating at nine feet bgs. A copy of manufacturer's Regenox® and
ORC Advanced® information, MSDS, and installation procedures is provided as Appendix
A of this permit modification application.
The Regenox® injection events will be conducted at least two to three weeks apart. To
effectively distribute the material within the subsurface, the injection point locations will be
offset a few feet horizontally between injection events. In addition to baseline sampling to
be conducted in August 2007, confirmation sampling of ground water in monitoring wells
will be completed after the second injection event to determine the RegenOx® effectiveness
and whether a third injection of this material is required to achieve remedial goals. A final
injection event of ORC Advanced® will take place six weeks after the completion of the last
RegenOx® injection event. In order to assess the effectiveness of RegenOx® and ORC
Advanced®, two ground water monitoring events will be conducted following the last
injection event. It is anticipated that the two final ground water monitoring events will be
conducted in June and December 2008.
Pending this permit modification approval, the initial injection event is planned for the Fall
of 2007. Four semi-annual ground water monitoring events (August 2007, December 2007,
June 2008, and December 2008) will provide before and after results of the injections.
F. DESCRIPTION OF SITE
This section provides updated information of the Site. The Site has been assigned Pollution
Incident No. 19216 by NCDENR. According to Mr. Brad Newton of the North Carolina
Department of Environment and Natural Resource (NCDENR), if benzene levels can be
2

Norfolk Southern Railway Company
Injection Well Permit Modification for RegenOx® and ORC® Remediation
Bessemer City, NC
August 2007
brought below the NCAC 15A 2L GCL standards (5000 µg/L) in ground water, the Site may
be considered for closure. Five gasoline underground storage tanks (USTs) and one
kerosene UST were located at the Site, but were removed in September 1998 and January
1999 by Earth Tech, Inc. (Earth Tech). Earth Tech removed approximately 277 tons of
petroleum hydrocarbon impacted soil associated with the USTs. The excavation pits were
backfilled with clean material.
Between 1999 and 2001, seven monitoring wells were installed to evaluate ground water
impacts. Data from the last four gauging events indicate the ground water typically flows to
the southwest (Figures 4-7). Volatile organic compounds (VOCs) present in the ground
water include benzene, toluene, ethylbenzene, total xylenes (BTEX), and naphthalene.
Currently, benzene is the most prevalent. Figure 8 shows the most current benzene
isoconcentration contours at the Site. Figures 9-12 show the most current isoconcentration
contours at the Site for toluene, ethylbenzene, total xylenes, and naphthalene, respectively.
A Comprehensive Site Assessment (CSA) was completed by Burns & McDonnell
Consultants, Inc. (Burns & McDonnell) and submitted in May 2000. A Corrective Action
Plan (CAP), completed by Burns & McDonnell, was submitted in October 2000, which
recommended monitored natural attenuation as the most cost effective treatment option.
Prior to approving the CAP, NCDENR requested the installation of two monitoring wells
(MW-6 and MW-7) south of the railroad trestle down gradient from the Site, to further
evaluate the extent of impacted ground water. Burns & McDonnell installed two monitoring
wells (MW-6 and MW-7) in January 2001, and submitted a summary report to NCDENR in
June 2001. Based on the results from the newly installed monitoring wells, NCDENR
approved the CAP in a letter dated July 17, 2001.
In November 2002, NSRC contracted MM&A to continue semi-annual ground water
monitoring at the Site, in accordance with the approved CAP. In the November 2003
monitoring report, MM&A recommended enhancing the natural biodegradation process by
3

Norfolk Southern Railway Company
Injection Well Permit Modification for RegenOx® and ORC® Remediation
Bessemer City, NC
August 2007
installing Regenesis brand Oxygen Release Compound (ORC®) socks in MW-2 and MW-4
and extending the semi-annual monitoring program for additional two years. MM&A
submitted an injection permit to the NCDENR Division of Water Quality (DWQ) on
November 1, 2004. NCDENR DWQ approved the permit on December 7, 2004 (permit no.
WI0300065). This permit expires on December 1, 2007.
The first set of ORC® socks were installed in January 2005; the second in June 2005; and the
third set in December 2005. MM&A conducted semi-annual ground water monitoring in
June and December of 2005. The ORC® socks were removed in June 2006 following the
sampling event. The January 2007 sampling event established ground water quality post
treatment of ORC® socks. Results indicated that the ORC® was effective in lowering the
benzene levels (range of results over treatment period, 6400 — 11000 µg/L); however, ORC®
treatment in the wells alone was insufficient to overcome the influence of remaining
impacted soils.
The objective of the remediation at this Site using RegenOx® and ORC Advanced®
injections is to effectively and permanently lower benzene levels in the ground water below
the GCL (5000 µg/L) so that NCDENR will reclassify the Site as low risk and grant closure.
G. HYDROGEOLOGIC DESCRIPTION
The following section includes updated information and revisions to support permit
modification application and was prepared in accordance with G.S. 89E-13 and has been
approved by a licensed geologist.
4

Norfolk Southern Railway Company
Injection Well Permit Modification for RegenOx® and ORC® Remediation
Bessemer City, NC
August 2007
1. REGIONAL GEOLOGIC SETTING
No change.
2. SIGNIFICANT CHANGES IN LITHOL O GY
This section includes revised cross -sections of the Site. Subsurface materials encountered in
soil borings and excavations at the Site consist of fill, clay, and clayey sand. Fill material
(subgrade composed of clay, sand, and gravel) is prevalent across the Site to a depth of
approximately two feet beneath the asphalt pavement. This fill is underlain by
approximately 10 feet of native soil composed of low plasticity clay with some sand.
Additional fill material comprised primarily of clay with some sand is also present within the
former UST excavation to an average depth of 10 feet bgs. Based on the well MW-2 boring
log, native soil consisting of low plasticity clay is present beneath the UST excavation to a
depth of approximately 25 feet. Based on boring logs for MW-4 and MW-5, clayey sand
was observed between approximately 10 and 20 feet bgs. This is the principal water bearing
unit at the Site and is underlain by at least five feet of clay. Figure 13 shows the location of
cross sections A -A' (Figure 14) and B-B' (Figure 15) which illustrate the relationship of
subsurface units and approximate extent of petroleum impacted ground water at the Site.
3. HYDRAULIC CONDUCTIVITY
No change.
4. DEPTH TO MEAN SEASONAL HIGH WATER TABLE
This section includes updated Table 1. Based on historical data, the mean seasonal high
water table is typically 10 feet bgs. Historic ground water elevations and field measurement
data can be found in Table 1.
5. TRANSMISSIVITY/SPECIFIC YIELD
No change.
5

Norfolk Southern Railway Company
Injection Well Permit Modification for RegenOx® and ORC® Remediation
Bessemer City, NC
August 2007
H. MONITORING PROCEDURE
This section has been revised to reflect additional monitoring requirements for the permit
modification. A monitoring well network consisting of seven wells already exists at the Site
and is shown on Figure 2. Historical ground water monitoring has included quarterly and
semi-annual sampling from seven shallow monitoring wells (MW-1, MW-2, MW-3, MW-4,
MW-5, MW-6, and MW-7) for VOCs (USEPA Method 8260) and polynuclear aromatic
hydrocarbons (PAHs, USEPA Method 8270).
Four semi-annual ground water monitoring events are proposed to monitor effectiveness of
RegenOx® and ORC Advanced® injections. The first of four semi-annual ground water
monitoring events will be performed in July/August 2007 before the first injection event.
The semi-annual sampling event for December 2007 will be completed between the second
and third injection event, and two additional, post -injection semi-annual ground water
monitoring events will be performed in June 2008 and December 2008.
Ground water samples will be collected and sent to an off -site laboratory to be analyzed for:
• VOCs including isopropyl ether (IPE), methyl tertiary butyl ether (MTBE), and ethylene
dibromide (EDB) following USEPA Method 8260,
• PAHs following USEPA Method 8270,
• Biological oxygen demand, and
• Chemical oxygen demand.
Field parameters to be measured during sampling will include:
• pH,
• Water temperature,
• Specific conductivity,
• Dissolved oxygen,
• Oxidation reduction potential, and
• Ferrous Iron (Hach test method using field kit).
6

Norfolk Southern Railway Company
Injection Well Permit Modification for RegenOx® and ORC® Remediation
Bessemer City, NC
August 2007
Well construction diagrams are included with the respective boring logs for the Site and
have been provided in UIC Permit No. WI0300065.
I. WELL USE
This section has been revised to reflect additional monitoring requirements for the permit
modification. All Site wells are monitoring wells designed for ground water sampling to
monitor the natural attenuation of dissolved gasoline constituents in ground water. None of
these wells will be used for injection purposes and none of the Site monitoring wells is used
for potable water. Ground water samples will be collected from all Site monitoring wells on
a semi-annual schedule for two years as described in Section H of this permit application.
J. CONSTRUCTION DATA
No change.
K. OTHER WELL DATA
No change.
L. PROPOSED OPERATING DATA
This section has been revised to reflect requirements for the permit modification.
1. INJECTION RATE
The injection rate for RegenOx and ORC Advanced® will not exceed five gallons per
minute (gpm) using bottom -up direct push placement in one -foot treatment intervals.
2. INJECTION VOLUME
During each event, injection will be conducted at nine locations (borings). In each boring,
injecting will start at approximately 21 feet below grade and will proceed upward on
one -foot intervals until the depth of nine feet is reached. This means that there will be 12
injection points for each boring (108 for the entire Site per event).
7

Norfolk Southern Railway Company
Injection Well Permit Modification for RegenOx® and ORC® Remediation
Bessemer City, NC
August 2007
For each RegenOx® application, approximately 1620 lbs of RegenOx® and 1,725 gallons of
water will be mixed at the Site. The injection of this mixture will consist of approximately
17.5 gallons per foot at depth intervals described above. This equates to a total of
approximately 191.6 gallons per location (boring).
Approximately 575 lbs of ORC Advanced® will be mixed at the Site with approximately 161
gallons of water. The injection of this mixture will be 1.5 gallons per foot at depth intervals
described above. This equates to approximately 17.9 gallons per location (boring).
3. INJECTION PRESSURE
The RegenOx® and ORC Advanced® will be injected under pressure of less than 1500 PSI.
It is anticipated; however, that actual pressures will be much lower to avoid soil fracturing.
4. INJECTION TEMPERATURE
The RegenOx® and ORC Advanced® will be injected at ambient air temperature.
S. HYDRAULIC CAPACITY OF THE WELL
Relatively low yielding materials underlie the Site. Although pumping tests have not been
conducted to determine the hydraulic capacities of the Site wells, based on typical hydraulic
capacities of low yield materials (clays, silty clays) the well capacity is estimated to be less
than five gpm.
Because RegenOx® and ORC Advanced® will be injected using temporary boreholes, the
hydraulic capacity of the borings is assumed to be similar to that of on -site monitoring wells.
The in -situ remedial compounds will be injected at rates which will not fracture or damage
the subsurface materials. Injection rates will be determined in the field and it is anticipated
that the rates will not exceed five gpm.
8
\\' ' \\ '�

Norfolk Southern Railway Company
Injection Well Permit Modification for RegenOx® and ORC® Remediation
Bessemer City, NC
August 2007
6. EXPECTED LIFETIME OF THE INJECTION FACILITY
Existing monitoring wells are expected to be viable for an estimated 10 years or more.
7. DESCRIPTION OF MEASUREMENTS/CONTROLS
The rate of oxygen released to the aquifer is an estimate. Actual rates of the oxygen release
will vary depending on the geochemical and biological conditions of the aquifer. Based on
manufacturer's (Regenesis) claims, RegenOx® and ORC Advanced® are typically depleted
within six months after injection into the subsurface.
M. INJECTION RELATED EQUIPMENT
This section has been revised to reflect requirements for the permit modification. A
Geoprobe® 6600 or similar equipment will be used for the direct push injection events.
An associated Mobile Injection System (MIS) comprised of an integrated mixing and
pumping (diaphragm, piston and progressive cavity) that can achieve injection rates up to
100 gpm and pressures up to 1500 psi will be used for injections. The injection tooling will
consist of a top -down and bottom -up injection tooling which allows for the injection
of remedial compounds at specific target depths (each foot from the depths of 9 to 21 feet
below grade).
N. LOCATION OF WELL(S)
This section has been revised to reflect requirements for the permit modification. A Site
vicinity map is shown in Figure 1 and includes topographic contours. The proposed
injection area points and monitoring wells are shown on Figure 2 along with the required
elements described in Section N of the permit. All monitoring wells are located on Norfolk
Southern Railway Company property. A topographic map of Gaston County (Appendix C)
obtained from the county website (www.co.gaston.nc.us) shows five-foot contour intervals.
A tax map (Appendix B) illustrates the NSRC right of way which encompasses the Site.
O. INJECTION FLUID DATA
This section has been revised to reflect requirements for the permit modification.
9

Norfolk Southern Railway Company
Injection Well Permit Modification for RegenOx® and ORC® Remediation
Bessemer City, NC
August 2007
1. FLUID SOURCE
Both RegenOx® and ORC Advanced® are produced by the Regenesis Company. Information
on these products are located in Appendix A.
2. CHEMICAL, PHYSICAL, BIOLOGICAL, AND RADIOLOGICAL
CHARACTERISTICS OF INJECTION FLUID.
The proposed injection materials, RegenOx® and ORC Advanced®, information provided by
the manufacturer, is included in Appendix A.
P. PERMIT LIST
No change.
Q. REFERENCES
No change.
10
►► 'J'�►►JSi3�

FIGURES AND TABLES

Prepared by:
ARSHALL ► 1,ILLE
SOCI _TES
NS1499
09 /06/07
USGS 7.5' BESSEMER CITY, NC QUADRANGLE - 1973
CONTOUR INTERVAL = 20'
NORFOLK SOUTHERN
201 W. VIRGINIA AVENUE
BESSEMER CITY, NORTH CAROLINA
2,000' 0 2,000'
SCALE 1:24,000
FIGURE 1
VICINITY MAP
NORTH CAROLINA
QUADRANGLE LOCATION
4

MW-7
50'
Q�
VIRGINIA
AVENUE
AUTO
FIBER OPTIC CABLE
—
RAILROAD
BRIDGE
MW-6
4
PENNSYLVANIA AVE.
0 50'
1"=50'
WRC/N,A
NOTE: The location and dimensions of features shown on this map have
been derived from various sources and supplemented by field
measurements. Though sufficient for its intended purpose, no
claim is made as to the degree of accuracy of this drawing.
A STORM
`®SEWER
MW-1
AUTG-
fl
4
MW-2
,MW-4
PROPOSED INJEC11ON AREA
4)- MW-5
}
MW-3
MW-1
LEGEND
MONITORING WELL
FIGURE 2
SITE MAP WITH PROPOSED INJECTION AREA
NORFOLK SOUTHERN
201 W. VIRGINIA AVENUE
BESSEMER CITY, NC
DATE:
4127107
SCALE:
1"
= 50'
DESIGNED:
JB
DRAWN:
JGS
Prepared by:
NS1411•INJECTION.dwg

A
L�
,
®
MW_2
a/
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IN
e�
®.
LEGEND
4 4 MW-1
- MONITORING WELL NO
$
1 _4, • - 1ST INJECTION EVENT A - 3RD INJECTION EVENT
NOTE: The location and dimensions of features shown on this map have 0 - 2ND INJECTION EVENT * - 4TH INJECTION EVENT
been derived from various sources and supplemented by field
measurements. Though sufficient for its intended purpose, no GROUND WATER FLOW
claim is made as to the degree of accuracy of this drawing.
11=1114SCALE:
Prepared 6y:
DATE: 7125/07
FIGURE 3
n
1"=4'
PROPOSED INJECTION AREA
NORFOLK SOUTHERN
\ \ \ L•
DESIGNED: JB
EMI
201 W. VIRGINIA AVENUE
BESSEMER CITY, NC
DRAWN: JGS
-
NS1411-INJECTION.dwg

MW-7
881.64
50'
IlRCryVfA
STORM
_�/-SEWER
MW-1
VIRGINIA 884.48 40. ay, co
AVENUE N'Oc 5
AUTO \ / / / / '882.54
FIBER OPTIC CABI
883
RAILROAD
BRIDGE
MW-6
PENNSYI VANIA AVE. 880.17
o
•MW-3
88 .61
sixiastatsataatasi/ am"
0 50'
1 = 50'
NOTE: The location and dimensions of features shown on this map have
been derived from various sources and supplemented by field
measurements. Though sufficient for its intended purpose, no
claim is made as to the degree of accuracy of this drawing.
LEGEND
MW-1
— 880 —
MONITORING WELL
GROUND WATER ELEVATION CONTOUR
(CONTOUR INTERVAL=1 FOOT)
APPROXIMATE GROUND WATER
FLOW DIRECTION
NOTES:
1: GROUND WATER ELEVATION IN
FEET ABOVE MEAN SEA LEVEL
2: GROUND WATER ELEVATIONS
OBTAINED ON JUNE 14, 2005
FIGURE 4
GROUND WATER CONTOUR MAP
JUNE 2005
r
NORFOLK SOUTHERN
201 W. VIRGINIA AVENUE
BESSEMER CRY, NC
DATE:
07/09/05
SCALE:
1"
= 50'
DESIGNED:
JB
DRAWN:
BAG
Prepared by:
LARSHALL 1ILLE
NS1411 JUNE 2005.dwg

MW-7
876.02
co
cb
50'
8>>
1 jRGIN/q
VIRGINIA
AVENUE
AUTO
8>8
FIBER..^T. SABLE
RAILROAD
BRIDGE
MW-6
PENNSYLVANIA AVE. 875.25
0 50'
1" = 50'
NOTE: The location and dimensions of features shown on this map have
been derived from various sources and supplemented by field
measurements. Though sufficient for its intended purpose, no
claim is made as to the degree of accuracy of this drawing.
STORM
—SEWER
MW-1
879.27 -
MW-5
*87.93
MW-3
MW-2 87 .27
877.86
w
r
MW-1
t)
LEGEND
MONITORING WELL
— 876 —
GROUND WATER ELEVATION CONTOUR
(CONTOUR INTERVAL=1 FOOT)
APPROXIMATE GROUND WATER
FLOW DIRECTION
NOTES:
1: GROUND WATER ELEVATION IN
FEET ABOVE MEAN SEA LEVEL
2: GROUND WATER ELEVATIONS
OBTAINED ON DECEMBER 13, 2005
FIGURE 5
GROUND WATER CONTOUR MAP
DECEMBER 2005
v�r
NORFOLK SOUTHERN
201 W. VIRGINIA AVENUE
BESSEMER CffY, NC
DATE:
01/03106
SCALE:
1"
= 50'
DESIGNED:
JB
DRAWN:
RDF
Prepared by:
ARSHALL k kILLE
MILSICEITHEINIM
NS1411 DEC 2005.dwg

MW-7
NM
50'
VIRGINIA
AVENUE
AUTO
FIBER OPTIC CABLE
RAILROAD
BRIDGE
MW-6
PENNSYLVANIA AVE. 875
0 50'
1"=50
OR
GgyIA Atie
NOTE: The location and dimensions of features shown on this map have
been derived from various sources and supplemented by field
measurements. Though sufficient for its intended purpose, no
claim is made as to the degree of accuracy of this drawing.
MW-1
879.734_
STORM
� - SEWER
MW-4
878.54
fl
MW-1
878
NM
*MW
W1-3
87 .92
LEGEND
MONITORING WELL
GROUND WATER ELEVATION CONTOUR
(CONTOUR INTERVAL=1FOOT)
APPROXIMATE GROUND WATER
FLOW DIRECTION
NOT MEASURED
NOTES:
1. GROUNDWATER ELEVATIONS IN FEET ABOVE
MEAN SEA LEVEL.
2. GROUNDWATER ELEVATIONS OBTAINED
JUNE 8, 2006
FIGURE 6
GROUND WATER CONTOUR MAP
JUNE 2006
NORFOLK SOUTHERN
201 W. VIRGINIA AVENUE
BESSEMER CITY, NC
DATE:
JUNE 2006
SCALE:
1" = 50'
DESIGNED:
JB
DRAWN:
PM
Prepared
►►►►
NS1411-June 2006.dwg

1
MW-7
DRY
50'
Q_
VIRGINIA
AVENUE
AUTO
FIBER OPTIC CABLE -
RAILROAD
BRIDGE
MW-6
DRY
PENNSYLVANIA AVE.
0 50'
1', = So,
14RGIN/A AVf
NOTE: The location and dimensions of features shown on this map have
been derived from various sources and supplemented by field
measurements. Though sufficient for its intended purpose, no
claim is made as to the degree of accuracy of this drawing.
STORM
�MW�
876.79
MW-4 r—� w
ce
878.2233 ao
r
co
MW 1
878
LEGEND
MONITORING WELL
GROUND WATER ELEVATION CONTOUR
(CONTOUR INTERVAL=1FOOT)
APPROXIMATE GROUND WATER
FLOW DIRECTION
NOTES:
1. GROUNDWATER ELEVATIONS IN FEET ABOVE
MEAN SEA LEVEL.
2. GROUNDWATER ELEVATIONS OBTAINED
JANUARY 3, 2007
FIGURE 7
GROUND WATER CONTOUR MAP
JANUARY 2007
NORFOLK SOUTHERN
201 W. VIRGINIA AVENUE
BESSEMER CITY, NC
DATE: JANUARY 2007
SCALE:
1"= 50'
DESIGNED:
JB
DRAWN:
RDF
Prepare� f
►►' ►►
NS1411June 2006.dwg

MW-7
NS
50'
,
VIRGINIA
AVENUE
AUTO
`4RG/N/A
FIBER OPTIC CABLE —
RAILROAD
BRIDGE
MW-6
NS
PENNSYLVANIA AVE.
0 50'
1"=50'
Av
STORM
SEWER
NOTE: The location and dimensions of features shown on this map have
been derived from various sources and supplemented by field
measurements. Though sufficient for its intended purpose, no
claim is made as to the degree of accuracy of this drawing.
130
5000
MW-5
*1550
500
MW-4�
310
LEGEND
MW-1
ND NOT DETECTED
NS NOT SAMPLED
— 5000 — BENZENE ISOCONCENTRATION CONTOUR
MONITORING WELL
EXCEEDS NCDENR GROSS
CONTAMINATION LEVEL (5000 Ng/L)
NOTES:
1: G a UNU WATER SA ' LES COLLECTED
N JANUARY 03, 2007
2. ALL RESULTS IN -OGRAMS PER LITER (pg/L)
3: NCDENR GROUND WATER STANDARD FOR BENZENE = 1 Ng/L
FIGURE 8
BENZENE ISOCONCENTRATION MAP
JANUARY 2007
tier
NORFOLK SOUTHERN
201 W. VIRGINIA AVENUE
BESSEMER CITY, NC
DATE: JANUARY 2007
SCALE:
1"= 50'
DESIGNED:
JB
DRAWN:
RDF
Prepared by: _
►► ►►
NS1411-June 2006.dwg

r

I
MW-7
NS
50'
C� _ ` VIRGIIVIq t/E STORM
®SEWER
VIRGINIA
AVENUE
AUTO
FIBER OPTIC CABLE
RAILROAD
BRIDGE
PENNSYLVANIA AVE.
0
MW-6
50'
1"=50'
NOTE: The location and dimensions of features shown on this map have
been derived from various sources and supplemented by field
measurements. Though sufficient for its intended purpose, no
claim is made as to the degree of accuracy of this drawing.
MW-1
690 •
fl
MW-5
{591l0
MW 3
8500 6600
MW-4
45700
r_
14.1
oho
LEGEND
MONITORING WELL
ND NOT DETECTED
NS NOT SAMPLED
J ESTIMATED VALUE
—1000— TOLUENE ISOCONCENTRATION CONTOUR
NOTES:
1: GROUND WATER SAMPLES COLLECTED
ON JANUARY 3, 2007
2: ALL RESULTS IN MICROGRAMS PER LITER (Ng/L)
3: NCDENR GROUND WATER STANDARD
FOR TOLUENE = 1000 pg/L
FIGURE 9
TOLUENE ISOCONCENTRATION MAP
JANUARY 2007
NORFOLK SOUTHERN
201 W. VIRGINIA AVENUE
BESSEMER CITY, NC
DATE: JANUARY 2007
SCALE: 1"= 50'
DESIGNED: JB
DRAWN: RDF
► .►
NS1411-June 2006.dwg

1
MW-7
NS
50'
C
VIRGINIA
AVENUE
AUTO
FIBER OPTIC CABLE
PENNSYLVANIA AVE.
s
0
RAILROAD
BRIDGE
MW-6
50'
1"= 50'
ERG/NI/4 A f STORM
_
_ ��SEWER
MW-1-
70
NOTE: The location and dimensions of features shown on this map have
been derived from various sources and supplemented by field
measurements. Though sufficient for its intended purpose, no
claim is made as to the degree of accuracy of this drawing.
AVM 5
2800
,MW 3
930
4O�
j0
LEGEND
MW-1
MONITORING WELL
ND NOT DETECTED
NS NOT SAMPLED
—1000— ETHYLBENZENE ISOCONCENTRATION CONTOUR
NOTES:
1: GROUND WATER SAMPLES COLLECTED
ON JANUARY 3, 2007
2: ALL RESULTS IN MICROGRAMS PER LITER (pg/L)
3: NCDENR GROUND WATER STANDARD
FOR ETHYLBENZENE = 29 Ng/L
FIGURE 10
ETHYLBENZENE ISOCONCENTRATION MAP
JANUARY 2007
NORFOLK SOUTHERN
201 W. VIRGINIA AVENUE
BESSEMER CITY, NC
DATE: JANUARY 2007
SCALE: 1" = 50'
DESIGNED: JB
DRAWN: RDF
Prepared y:
�.�v�llllll'
►!a\'b1:1c\�lk \IIMMEZKEITHEMI
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NS1411June 2006.dwg

1
MW-7
NS
so'
— WI?
G/NiA
VIRGINIA
AVENUE
AUTO
FIBER OPTIC CABLE --
RAILROAD
BRIDGE
MW-6
NS
PENNSYLVANIA AVE.
0 50'
1" = 50'
NOTE: The location and dimensions of features shown on this map have
been derived from various sources and supplemented by field
measurements. Though sufficient for its intended purpose, no
claim is made as to the degree of accuracy of this drawing.
AVE
STORM
®SEWER
fl
MW-5
4100
5000 ,
MW-2 I
4300-M5300
I 1--.MW-4 W
_AOOGCt
IL
3500 I 0)
r
M
LEGEND
MW-1
MONITORING WELL
ND NOT DETECTED
NS NOT SAMPLED
—5000— XYLENE ISOCONCENTRATION CONTOUR
NOTES:
1: GROUND WATER SAMPLES COLLECTED
ON JANUARY 3, 2007
2: ALL RESULTS IN MICROGRAMS PER LITER (pg/L)
3: NCDENR GROUND WATER STANDARD
FOR XYLENES = 530 Ng/L
FIGURE 11
TOTAL XYLENES ISOCONCENTRATION MAP
JANUARY 2007
NORFOLK SOUTHERN
201 W. VIRGINIA AVENUE
BESSEMER CITY, NC
DATE: JANUARY 2007
SCALE: 1" = 50'
DESIGNED: JB
DRAWN: RDF
Prepare
NS1411-June 2006.dwg

MW-7
NS
50'
G l?RGINIA AVe STORM
_®/ SEWER
El
VIRGINIA
AVENUE MW\5
AUTO 4- 1 L'
MW-3
200
FIBER OPTIC CABLE —
RAILROAD
BRIDGE
MW-6
NS
PENNSYLVANIA AVE.
s
0 50'
NOTE: The location and dimensions of features shown on this map have
been derived from various sources and supplemented by field
measurements. Though sufficient for its intended purpose, no
claim is made as to the degree of accuracy of this drawing.
LEGEND
MW-1
MONITORING WELL
ND NOT DETECTED
NS NOT SAMPLED
—500— NAPHTHALENE ISOCONCENTRATION CONTOUR
NOTES:
1: GROUND WATER SAMPLES COLLECTED
ON JANUARY 3, 2007
2: ALL RESULTS IN MICROGRAMS PER LITER (pg/L)
3: NCDENR GROUND WATER STANDARD
FOR NAPHTHALENE = 21 Ng/L
FIGURE 12
NAPHTHALENE ISOCONCENTRATION MAP
JANUARY 2007
NORFOLK SOUTHERN
201 W. VIRGINIA AVENUE
BESSEMER CITY, NC
DATE: JANUARY2007
SCALE: 1" = 50'
DESIGNED: JB
DRAWN: RDF
NS1411June 2006.dwg

MW-7
50'
�RGINIA A
•STORM
� ` SEWER
VIRGINIA
AVENUE
AUTO
FIBER OPTIC CABLE
RAILROAD
BRIDGE
PENNSYLVANIA AVE.
A
uw_
0 50'
1"=50'
5
3
LEGEND
MW-1
MONITORING WELL
- RAILROAD TRACKS
NOTE: The location and dimensions of features shown on this map have A A' CROSS SECTION LINE
been derived from various sources and supplemented by field
measurements. Though sufficient for its intended purpose, no
claim is made as to the degree of accuracy of this drawing.
0
- RAILROAD RIGHT-OF-WAY
PROPERTY BOUNDARY (APPROXIMATE)
FIGURE 13
SITE MAP SHOWING CROSS SECTION LINES
� ry
NORFOLK SOUTHERN
201 W. VIRGINIA AVENUE
BESSEMER CITY, NC
DATE:
JUNE 2007
SCALE:
1"= 50'
DESIGNED:
SB
DRAWN:
JGS
Prepared by:
►►' ►►
NS1411.dwg

SOUTH
MW-6
CLAY -
- SS-1
- SS-2
- SS-3
TD=20.8 FT.
NOTE: The location and dimensions of features shown on this mop hove
been derived from various sources and supplemented by fleld
measurements. Though sufficient for Its intended purpose, no
claim la made as to the degree of accuracy of thls drawing.
MW-6 WAS DRY
JANUARY 2006
20
10
0
APPROXIMATE HIGH
WATER TABLE
MAY 2003
APPROXIMATE LOW
WATER TABLE
NOVEMBER 2001
PROFILE SCALE
HORIZONTAL
1 "=20'
VERTICAL
1"=10'
VERTICAL
EXAGGERATION
2X
RAILROAD
EMBANKMENT
MW-2
1/3/07
GROUND WATER RESULTS
BENZENE
TOLUENE
ETHYLBENZENE
XYLENES
NAPHTHALENE
6400*E
8500 E
440
4300
260
APPROXIMATE
GROUND SURFACE
MIN--4
1/3/07
GROUND WATER RESULTS
BENZENE
TOLUENE
ETHYLBENZENE
XYLENES
NAPHTHALENE
490
8400 E
970
5800
260
20
40
s
CLAYEY SAND
SANDY CLAY
DISSOLVED IMPACTS ( CLAYEY SAND
ABOVE NCDENR
GROUND WATER STANDARDS
(APPROXIMATE)
M W-4
MW-2
NORTH
MW-5
1/3/07
GROUND WATER RESULTS
BENZENE
TOLUENE
ETHYLBENZENE
XYLENES
NAPHTHALENE
550
590
2800
4100
180
ASPHALT
PAVEMENT
- MW-5
-
_SS-2
-
UST
EXCAVA'ION
CLAY -
} SS-1
_
CLAYEY
-SS3
D-SS4
-
SS-5
FILL -•
CLAY —
SAND -
SANDY CLAY -
_
-
)
_
_
- --
-
_
— ----
,
TD=25 0 FT, TD WELL=25.0 FT.
- - — ---TD=25.0 FT.
TD SOIL BORING=27.0 FT.
LEGEND
SCREEN
APPROXIMATE HIGH
GROUND WATER ELEVATION (FT. MSL)
MAY 2003
APPROXIMATE LOW
GROUND WATER ELEVATION (FT. MSL)
NOVEMBER 2001
1.) BOLD VALUES EXCEED NCDENR
SOIL -TO -GROUNDWATER MCLs
OR GROUND WATER STANDARDS.
2.) GROUND WATER DATA IN
MICROGRAMS PER LITER (pG/L)
3.) E=CONCENTRATIONS EXCEEDS THE
CALIBRATION RANGE OF THE INSTRUMENT
4.) *=EXCEEDS NDCENR GROSS
CONTAMINATE LEVELS (GCLs)
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zw
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MW-2
ASPHALT
PAVEMENT
WEST
APPROXIMATE
MW-1 GROUND SURFACE
CLAY -
\\
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1
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EXCAVATION
]- SS-1
SS-2
usr
EXCAVATION
L
APPROXIMATE HIG
WATER TABLE
MAY 2003
-I
1- SS-1
TD=31.5 F.
SURFACE CASING
CLAY -
i
SS3
APPROXIMATE LOW
WATER TABLE
NOVEMBER 2001
SS-4
SS-5
TD WELL=25.0 FT.
TD SOIL BORING=27.0 FT.
MW-3
1/3/07
GROUND WATER RESULTS
BENZENE
600
TOLUENE
6600 E
ETHYLBENZENE
930
XYLENES
5300 E
NAPHTHALENE
200
NOTE The location and dimensions of features shown on this map have
been derived from various sources and supplemented by field
measurements. Though sufficient for Its intended purpose, no
dorm Is made as to the degree of accuracy of this drawing.
0
DISSOLVED IMPACTS
ABOVE NCDENR
GROUND WATER STANDARDS
(APPROXIMATE)
PROFILE SCALE
HORIZONTAL
1"=10'
VERTICAL
1"=10'
10
20
s
CLAY -
SS-2
SS-3
TD WELL=25.0 FT.r �S �
-SS-6
TD SOIL BORING=42.0 FT
j
LEGEND
SCREEN
APPROXIMATE HIGH
GROUND WATER ELEVATION (FT. MSL)
MAY 2003
APPROXIMATE LOW
GROUND WATER ELEVATION (FT. MSL)
NOVEMBER 2001
MW-1
1/3/07
GROUND WATER RESULTS
BENZENE
TOLUENE
ETHYLBENZENE
XYLENES
NAPHTHALENE
130
690
70
790
56
MW-2
1/3/07
GROUND WATER RESULTS
BENZENE
6400*E
TOLUENE
8500 E
ETHYLBENZENE
440
XYLENES
4300
NAPHTHALENE
260
1.) BOLD VALUES EXCEED NCDENR
SOIL -TO -GROUND WATER MCLs
• OR GROUND WATER STANDARDS.
2.) GROUND WATER DATA IN
MICROGRAMS PER LITER (pG/L)
3.) E=CONCENTRATIONS EXCEEDS THE
CALIBRATION RANGE OF THE INSTRUMENT
4.) *=EXCEEDS NDCENR GROSS
CONTAMINATE LEVELS (GCLs)
NORFOLK
SOUTHERN
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fn
W
CROSS -SECTIONAL VIEW B-B'
FIGURE
15

TABLE 1
GROUND WATER ELEVATION AND FIELD MEASUREMENT DATA
Norfolk Southern Railway Company
Bessemer City, North Carolina
GROUND WATER ELEVATION DATA
FIELD MEASUREMENT DATA
Monitoring
Well Number
Date
Measured
Ground
Surface
Elevation (MSL)
Top of
Casing
Elevation (ft MSL)
Depth
to Water
(ft TOC)
Groundwater
Elevation
(ft MSL)
Temperature
o
( Celsius)
pH
Specific
Conductivity
(uS/cm)
Dissolved
Oxygen
(mg/i)
MW-1
12/07/99
895.49
894.72
15.77
878.95
NA
NA
NA
NA
03/16/00
895.49
894.72
12.59
882.13
NA
NA
NA
NA
03/18/00
895.49
894.72
12.61
882.11
NA
NA
NA
NA
09/14/00
895.49
894.72
16.30
878.42
NA
NA
NA
NA
04/04/01
895.49
894.72
12.32
882.40
NA
NA
NA
NA
08/22/01
895.49
894.72
17.76
876.96
19.5
4.48
1390
0.26
11/29/01
895.49
894.72
19.52
875.20
19.2
4.41
1430
0.21
03/04/02
895.49
894.72
16.60
878.12
20.0
4.91
1160
0.39
06/12/02
895.49
894.72
17.41
877.31
19.5
4.58
42*
0.12
11/26/02
895.49
894.72
18.35
876.37
17.9
5.13
1410
1.47
05/14/03
895.49
894.72
8.22
886.50
19.6
5.97
1360
0.5
11/10/03
895.49
894.72
11.33
883.39
18.4
6.78
1290
NM
11/17/04
895.49
894.72
12.33
882.39
20.1
4.9
1410
1.11
06/14/05
895.49
894.72
10.24
884.48
19.1
6.87 _
85.5
NM
12/13/05
895.49
894.72
15.45
879.27
18.6
5.32
67
NM
06/08/06
895.49
894.72
14.99
879.73
21.5
5.13
71
NM
01/03/07
895.49
894.72
14.50
880.22
17.92
4.73
147
1 #
MW-2
12/07/99
894.77
894.30
15.57
878.73
NA
NA
NA
NA
03/16/00
894.77
894.30
12.93
881.37
NA
NA
NA
NA
08/22/01
894.77
894.30
17.19
877.11
19.2
5.30
1150
0.20
11/29/01
894.77
894.30
18.96
875.34
20.0
5.86
1450
0.18
03/04/02
894.77
894.30
16.90
877.40
20.0
5.60
1100
0.92
06/12/02
894.77
894.30
17.63
876.67
19.4
5.58
103*
NA
11/26/02
894.77
894.30
19.37
874.93
20.3
6.13
1480
1.7
05/14/03
894.77
894.30
10.40
883.90
21.8
6.05
1370
0.8
11/10/03
894.77
894.30
10.90
883.40
17.0
9.9
1670
NM
11/17/04
894.77
894.30
13.20
881.10
21.2
5.18
1270
NM
06/14/05
894.77
894.30
12.12
882.18
19.7
8.51
391.5
NM
12/13/05
894.77
894.30
16.44
877.86
19.9
8.66
388
NM
06/08/06
894.77
894.30
15.60
878.70
23.1
8.83
353
NM
01/03/07
894.77
894.30
15.75
878.55
18.2
6.91
600
3.7 #
Attach4-Tablel.xls
Page 1 of 4
\\' !NMI
��; SOCI; ES

TABLE 1
GROUND WATER ELEVATION AND FIELD MEASUREMENT DATA
Norfolk Southern Railway Company
Bessemer City, North Carolina
GROUND WATER ELEVATION DATA
FIELD MEASUREMENT DATA
Monitoring
Well Number
Date
Measured
Ground
Surface
Elevation (MSL)
Top of
Casing
Elevation (ft MSL)
Depth
to Water
(ft TOC)
Groundwater
Elevation
(ft MSL)
Temperature
P
o
( Celsius)
pH
Specific
Conductivity
(uS/cm)
Dissolved
Oxygen
(mg/1)
MW-3
12/07/99
894.07
893.84
15.60
878.24
NA
NA
NA
NA
03/16/00
894.07
893.84
12.59
881.25
NA
NA
NA
NA
03/18/00
894.07
893.84
12.63
881.21
NA
NA
NA
NA
09/14/00
894.07
893.84
14.84
879.00
NA
NA
NA
NA
04/04/01
894.07
893.84
12.20
881.64
NA
NA
NA
NA
08/22/01
894.07
893.84
15.51
878.33
21.3
5.10
2000
0.54
11/29/01
894.07
893.84
17.79
876.05
20.4
4.89
2220
2.08
03/04/02
894.07
893.84
16.86
876.98
20.9
5.69
2000
0.87
06/12/02
894.07
893.84
17.39
876.45
19.8
5.50
155*
0.80
11/26/02
894.07
893.84
19.03
874.81
18.2
5.29
1440
2.64
05/14/03
894.07
893.84
10.73
883.11
21.8
5.03
2080
0.60
11/10/03
894.07
893.84
11.85
881.99
16.9
10.08
1420
NM
11/17/04
894.07
893.84
15.79
878.05
20.5
5.15
1830
NM
06/14/05
894.07
893.84
12.23
881.61
19.8
7.02
186
NM
12/13/05
894.07
893.84
16.57
877.27
19.6
5.91
111
NM
06/08/06
894.07
893.84
15.92
877.92
24.6
5.62
114
NM
01/03/07
894.07
893.84
17.05
876.79
18.6
4.85
181
3.7 #
MW-4
12/07/99
894.84
894.33
16.00
878.33
NA
NA
NA
NA
03/16/00
894.84
894.33
13.20
881.13
NA
NA
NA
NA
03/18/00
894.84
894.33
13.23
881.10
NA
NA
NA
NA
09/14/00
894.84
894.33
16.89
877.44
NA
NA
NA
NA
04/04/01
894.84
894.33
13.42
880.91
NA
NA
NA
NA
08/22/01
894.84
894.33
18.34
875.99
18.5
4.70
770
0.30
11/29/01
894.84
894.33
19.92
874.41
19.2
4.97
870
0.34
03/04/02
894.84
894.33
17.37
876.96
18.7
5.09
800
0.25
06/12/02
894.84
894.33
18.25
876.08
18.4
5.02
61*
0.34
11/26/02
894.84
894.33
19.92
874.41
17.6
5.13
961
2.08
05/14/03
894.84
894.33
7.37
886.96
21.4
5.84
1680
1.3
11/10/03
894.84
894.33
9.05
885.28
17.1
9.87
1420
NM
11/17/04
894.84
894.33
12.76
881.57
19.18
4.69
780
0.81
06/14/05
894.84
894.33
10.83
883.50
18.7
7.1
225
NM
12/13/05
894.84
894.33
16.79
877.54
18.1
8.4
469
NM
06/08/06
894.84
894.33
15.79
878.54
23.1
9.34
344
NM
01/03/07
894.84
894.33
16.10
878.23
16.16
5.19
114
5 #
Attach4-Tablel .xls
Page 2 of 4

TABLE 1
GROUND WATER ELEVATION AND FIELD MEASUREMENT DATA
Norfolk Southern Railway Company
Bessemer City, North Carolina
GROUND WATER ELEVATION DATA
FIELD MEASUREMENT DATA
Monitoring
Well Number
Date
Measured
Ground
Surface
Elevation (MSL)
Top of
Casing
Elevation (ft MSL)
Depth
to Water
(ft TOC)
Groundwater
Elevation
(ft MSL)
Temperature
o
( Celsius)
pH
Specific
Conductivity
(uS/cm)
Dissolved
Oxygen
(mg/1)
MW-5
12/07/99
894.49
894.18
15.09
879.09
NA
NA
NA
NA
03/16/00
894.49
894.18
12.50
881.68
NA
NA
NA
NA
03/18/00
894.49
894.18
12.52
881.66
NA
NA
NA
NA
09/14/00
894.49
894.18
14.89
879.29
NA
NA
NA
NA
04/04/01
894.49
894.18
12.18
882.00
NA
NA
NA
NA
08/22/01
894.49
894.18
16.08
878.10
20.1
4.26
1430
0.20
11/29/01
894.49
894.18
17.86
876.32
21.0
4.20
1510
0.77
03/04/02
894.49
894.18
16.33
877.85
20.6
4.67
1270
0.37
06/12/02
894.49
894.18
17.29
876.89
20.0
4.53
237*
0.34
11/26/02
894.49
894.18
18.66
875.52
17.9
5.28
1350
1.68
05/14/03
894.49
894.18
9.92
884.26
24.4
5.86
1770
1.3
11/10/03
894.49
894.18
12.25
881.93
19.4
9.91
1580
NM
11/17/04
894.49
894.18
13.43
880.75
20.9
4.58
1310
0.89
06/14/05
894.49
894.18
11.64
882.54
19.8
8.76
153
NM
12/13/05
894.49
894.18
16.25
877.93
19.7
5.1
69
NM
06/08/06
894.49
894.18
15.57
878.61
22.5
4.79
84
NM
01/03/07
894.49
894.18
15.50
878.68
18.9
4.37
190
1.5 #
MW-6
12/07/99
893.58
893.26
NA
NA
NA
NA
NA
NA
03/16/00
893.58
893.26
NA
NA
NA
NA
NA
NA
03/18/00
893.58
893.26
NA
NA
NA
NA
NA
NA
09/14/00
893.58
893.26
NA
NA
NA
NA
NA
NA
04/04/01
893.58
893.26
15.45
877.81
NA
NA
NA
NA
08/22/01
893.58
893.26
19.73
873.53
13.7
NA
NA
2.74
11/29/01
893.58
893.26
19.81
873.45
NA
NA
NA
NA
03/04/02
893.58
893.26
19.08
874.18
17.3
4.54
1520
4.90
06/12/02
893.58
893.26
19.76
873.50
NA
NA
NA
NA
11/26/02
893.58
893.26
Dry
NA
NA
NA
NA
NA
05/14/03
893.58
893.26
10.84
882.42
18.4
5.54
1850
11.6
11/10/03
893.58
893.26
13.21
880.05
16.7
6.31
1910
NM
11/17/04
893.58
893.26
15.10
878.16
19.35
4.5
2170
3.15
06/14/05
893.58
893.26
13.09
880.17
18.7
7.12
211.5
NM
12/13/05
893.58
893.26
18.01
875.25
18.9
4.98
132
NM
06/08/06
893.58
893.26
17.57
875.69
22.5
4.34
119
NM
01/03/07
893.58
893.26
Dry
NA
NM
NM
NM
NM
Attach4-Tablel.xls
Page 3 of 4

TABLE 1
GROUND WATER ELEVATION AND FIELD MEASUREMENT DATA
Norfolk Southern Railway Company
Bessemer City, North Carolina
GROUND WATER ELEVATION DATA
FIELD MEASUREMENT DATA
Ground
Top of
Depth
Groundwater
Specific
Dissolved
Monitoring
Date
Surface
Casing
to Water
Elevation
Temperature
pH
Conductivity
Oxygen
Well Number
Measured
Elevation (MSL)
Elevation (ft MSL)
(ft TOC)
(ft MSL)
Celsius)
(uS/cm)
(mi/1)
MW-7
12/07/99
896.02
895.81
NA
NA
NA
NA
NA
NA
03/16/00
896.02
895.81
NA
NA
NA
NA
NA
NA
03/18/00
896.02
895.81
NA
NA
NA
NA
NA
NA
09/14/00
896.02
895.81
NA
NA
NA
NA
NA
NA
04/04/01
896.02
895.81
18.40
877.41
NA
NA
NA
NA
08/22/01
896.02
895.81
19.80
876.01
18.1
NA
NA
5.23
11/29/01
896.02
895.81
Dry
NA
NA
NA
NA
NA
03/04/02
896.02
895.81
Dry
NA
NA
NA
NA
NA
06/12/02
896.02
895.81
Dry
NA
NA
NA
NA
NA
11/26/02
896.02
895.81
Dry
NA
NA
NA
NA
NA
05/14/03
896.02
895.81
12.12
883.69
18.1
5.52
1420
10.9
11/10/03
896.02
895.81
15.06
880.75
16.3
6.19
1310
NM
11/17/04
896.02
895.81
16.70
879.11
18.7
5.08
1810
3.15
06/14/05
896.02
895.81
14.17
881.64
17.5
7.09
166.5
NM
12/13/05
896.02
895.81
19.79
876.02
NM
NM
NM
NM
06/08/06
896.02
895.81
19.71
876.10
NM
NM
NM
NM
01/03/07
896.02
895.81
Dry
NA
NM
NM
NM
NM
Notes:
Elevations are in reference to feet above mean sea level (MSL).
ft - Feet
uS/cm - Micro -Siemens per centimeter
mg/1 - Milligrams per liter
TOC - Top of casing
NA - Not Available
• - Units are in micro -ohms per centimeter
NM - Not Measured
Attach4-Table 1.xls Page 4 of 4
# - Estimated conversion from % DO to Mg/L

APPENDIX A
REGENESIS, REGENOX® and ORC ADVANCED® INFORMATION

ORC
"The Evolution of Controlled Release Oxygen"
ORC Advanced" is the state-of-the-art technology for stimulating aerobic
bioremediation. It offers unparalleled, maximum oxygen release for periods up
to 12 months on a single injection and is specifically designed to minimize
oxygen waste while maximizing contaminated site remediation.
HOW IT WORKS
Oxygen has been shown to be the
limiting factor for microbes capable of
aerobically degrading contaminants
such as petroleum hydrocarbons.
Without adequate oxygen,
contaminant degradation will either
cease or may proceed by much slower
anaerobic (oxygen -free) processes.
When hydrated, ORC Advanced
is designed to release its full amount
of oxygen (17% by weight) over a
12 month period. Upon injection
into the subsurface, ORC Advanced
utilizes its patented Controlled
Release Technology (CRT') to
deliver its oxygen consistently over
an extended period of time, avoiding
excessive foaming and oxygen loss
seen with commodity chemicals.
This enables aerobic microbes to
significantly accelerate rates of natural
attenuation over long periods of time.
PRODUCT FEATURES AND BENEFITS
Highest Available Oxygen Content
More active oxygen (17%) plus Regenesis' patented CRT' saves time and money
by increasing degradation rates and improving remediation performance by providing
more oxygen on a single injection. It is particularly effective at higher demand sites
where oxygen may be limited and scavenged by competing carbon sources.
Patented Controlled Release Technology (CRT")
Based on the same proven technology employed in the industry standard
Oxygen Release Compound (ORC®), CRT allows for an efficient, long-term release of
oxygen providing the optimal conditions for sustained aerobic biodegradation. This
can save time and money by reducing the potential need for multiple applications.
Also, oxygen release "lock -up" is avoided — an unfortunate problem experienced
with commodity chemicals. (See Details of CRT in Figure 1).
In -Situ Application
Remediation with ORC Advanced is typically more cost-effective than ex -situ
treatments. With the use of ORC Advanced there is minimal site disturbance with
no above -ground piping or mechanical equipment, no operations and maintenance
costs and no hazardous materials handling or disposal.
Free Technical Design and Support from Regenesis
Regenesis has been designing and evaluating in -situ accelerated bioremediation
projects for over 10 years. This "free of charge" service offers the user the highest
level of information available on stimulating natural attenuation and ensures a high
level of project success.
REGENESIS
Leaders in Accelerated Natural Attenuation
1011 Calle Sombra / San Clemente / California 92673-6244 / Tel: [phone] / Fax: [phone] / www.regenesis.com
02004 Regenesis

DEFINING THE SCIENCE BEHIND
CONTROLLED RELEASE TECHNOLOGY (CRTTM)
Early on, Regenesis researchers noted that in order to optimally stimulate the natural attenuation of aerobically degradable
contaminants, biologically usable oxygen was best supplied in low but constant concentrations. Big bursts of oxygen are
wasteful and simply "bubble off", often generating undesirable foaming and producing unwanted preferential flow paths in
the subsurface. Regenesis sought to solve this problem by controlling the rate of oxygen release from solid oxygen sources.
The answer was provided by the development of CRT. The CRT process involves intercalating (embedding) phosphates into
the crystal structure of solid peroxygen molecules. This patented feature, now available in the ORC Advanced"' formulation, slows
the reaction that yields oxygen within the crystal, minimizing "bubble off" which can waste the majority of oxygen available
in common solid peroxygen chemicals.
CRT"' provides "balance" — it slows down the rate of oxygen release while at the same time preventing "lock -up" Commodity
solid peroxygen chemicals, when in contact with water, will produce an initial rapid and uncontrolled release of oxygen. Then,
as hydroxides form, a significant portion of the oxygen deeper in the crystal is made unavailable or becomes"locked up." This
undesirable effect is ineffiecient and costly. CRT prevents lock up and controls the rate of oxygen release, representing the state-
of-the-art technology in passive oxygen delivery.
CRT Specifics
Uniformly embedded within the crystalline structure of the peroxygen are phosphate ions. These ions do two important things:
1. they slow the rate of hydration that liberates oxygen thereby creating the CRT effect and
2. they form exit pathways for the oxygen in an otherwise tightly packed crystal that can become even more "locked -up"
when hydroxides begin to form as a reaction by-product following oxygen liberation.
This patented process optimizes peroxygen performance and is only available in the Regenesis line of products.
HOSPFHATE. tesGROUP':
lntercafa" and Disrupt:
rysiel'Ar(ay)
For more information or a free
:project evaluation contact Regenesis
at (9,49) 366-8000 or visit our website
at www.regenesis.com
GENESIS
,Leaders'in.Accelerated Natural Attenuation

Oxygen Release Compound — Advanced (ORC AdvancedrM)
MATERIAL SAFETY DATA SHEET (MSDS)
Last Revised: March 13, 2007
Section 1 - Material Identification
Supplier:
REGENESIS
1011 Calle Sombra
San Clemente, CA 92673
Phone: [phone]
Fax: [phone]
E-mail: info(a,regenesis.com
Chemical A mixture of Calcium OxyHydroxide [CaO(OH)2] and
Description: Calcium Hydroxide [Ca(OH)2].
Chemical Family: Inorganic Chemical
Advanced Formula Oxygen Release Compound
Trade Name:
(ORC Advancedrm)
Chemical Synonyms Calcium Hydroxide Oxide; Calcium Oxide Peroxide
Product
Use:
Used to remediate contaminated soil and groundwater
(environmental applications)
Section 2 — Composition
CAS No. Chemical
682334-66-3 Calcium Hydroxide Oxide [CaO(OH)2]
1305-62-0 Calcium Hydroxide [Ca(OH)2]
7758-11-4 Dipotassium Phosphate (HK2O4P)
7778-77-0 Monopotassium Phosphate (H2K04P)

Regenesis - ORC Advanced MSDS
Section 3 — Physical Data
Form: Powder
Color: White to Pale Yellow
Odor: Odorless
Melting Point: 527 °F (275 °C) — Decomposes
Boiling Point: Not Applicable (NA)
Flammability/Flash NA
Point:
Auto- Flammability: NA
Vapor Pressure: NA
Self -Ignition NA
Temperature:
Thermal
Decomposition:
527 °F (275 °C) — Decomposes
Bulk Density: 0.5 — 0.65 g/ml (Loose Method)
Solubility: 1.65 g/L @ 68° F (20° C) for calcium hydroxide.
Viscosity: NA
pH: 11-13 (saturated solution)
Explosion Limits %
by Volume:
Hazardous
Decomposition
Products:
Hazardous
Reactions:
Non -explosive
Oxygen, Hydrogen Peroxide, Steam, and Heat
None

Regenesis - ORC Advanced MSDS
Section 4 — Reactivity Data
Stability:
Conditions to Avoid:
Incompatibility:
Hazardous
Polymerization:
Stable under certain conditions (see below).
Heat and moisture.
Acids, bases, salts of heavy metals, reducing agents, and
flammable substances.
Does not occur.
Section 5 — Regulations
TSCA Inventory Listed
List:
CERCLA Hazardous Substance (40 CFR Part 302)
Listed Substance:
No
Unlisted Substance: Yes
Reportable Quantity
(RQ):
Characteristic(s):
RCRA
Number:
Waste
100 pounds
Ignitibility
D001
SARA, Title III, Sections 302/303 (40 CFR Part 355 — Emergency Planning and
Notification)
Extremely
Hazardous
Substance:
No
SARA, Title HI, Sections 311/312 (40 CFR Part 370 — Hazardous Chemical
Reporting: Community Right -To -Know
Hazard Category:
Immediate Health Hazard
Fire Hazard
Threshold Planning 10,000 pounds
Quantity:

Regenesis - ORC Advanced MSDS
Section 5 — Regulations (cont)
SARA, Title III, Section 313 (40 CFR Part 372 — Toxic Chemical Release
Reporting: Community Right -To -Know
Extremely
Hazardous
Substance:
WIIMIS
Classification:
No
C
D
Canadian Domestic Not Listed
Substance List:
Oxidizing Material
Poisonous and Infectious
Material
Material Causing Other Toxic
Effects —
Eye and Skin Irritant
Section 6 — Protective Measures, Storage and Handling
Technical Protective
Measures
Storage:
Handling:
Keep in tightly closed container. Store in dry area, protected
from heat sources and direct sunlight.
Clean and dry processing pipes and equipment before
operation. Never return unused product to the storage
container. Keep away from incompatible products. Containers
and equipment used to handle this product should be used
exclusively for this material. Avoid contact with water or
humidity.

Regenesis - ORC Advanced MSDS
Section 6 — Protective Measures, Storage and Handling (cont)
Personal Protective Equipment (PPE)
Engineering
Controls:
Respiratory
Protection:
Hand Protection:
Eye Protection:
Skin Protection:
Other:
Industrial Hygiene:
Protection Against
Fire & Explosion:
Calcium Hydroxide
ACGIH® TLV® (2000)
5 mg/m3 TWA
OSHA PEL
Total dust-15 mg/m3 TWA
Respirable fraction-
5 mg/m3 TWA
NIOSH REL (1994)
5 mg/m3
For many conditions, no respiratory protection
however, in dusty or unknown atmospheres
approved dust respirator.
Impervious protective gloves made of nitrile,
or neoprene.
Use chemical safety goggles (dust proof).
may be needed;
use a NIOSH
natural rubbber
For brief contact, few precautions other than clean clothing are
needed. Full body clothing impervious to this material should
be used during prolonged exposure.
Safety shower and eyewash stations should be present.
Consultation with an industrial hygienist or safety manager for
the selection of PPE suitable for working conditions is
suggested.
Avoid contact with skin and eyes.
NA
Section 7 — Hazards Identification
Emergency
Overview:
Potential Health
Effects:
Oxidizer — Contact with combustibles may cause a fire. This
material decomposes and releases oxygen in a fire. The
additional oxygen may intensify the fire.
Irritating to the mucous membrane and eyes. If the product
splashes in ones face and eyes, treat the eyes first. Do not dry
soiled clothing close to an open flame or heat source. Any

Regenesis - ORC Advanced MSDS
clothing that has been contaminated with this product should
be submerged in water prior to drying.
Inhalation:
Eye Contact:
Skin Contact:
Ingestion:
High concentrations may cause slight nose and throat irritation
with a cough. There is risk of sore throat and nose bleeds if
one is exposed to this material for an extended period of time.
Severe eye irritation with watering and redness. There is also
the risk of serious and/or permanent eye lesions.
Irritation may occur if one is exposed to this material for
extended periods.
Irritation of the mouth and throat with nausea and vomiting.
Section 8 — Measures in Case of Accidents and Fire
After
Spillage/Leakage/Gas
Leakage:
Extinguishing
Media:
Suitable:
Further Information:
First Aid:
Collect in suitable containers. Wash remainder with copious
quantities of water.
See next.
Large quantities of water or water spray. In case of fire in
close proximity, all means of extinguishing are acceptable.
Self contained breathing apparatus or approved gas mask
should be worn due to small particle size. Use extinguishing
media appropriate for surrounding fire. Apply cooling water to
sides of transport or storage vessels that are exposed to flames
until the fire is extinguished. Do not approach hot vessels that
contain this product.
After contact with skin, wash immediately with plenty of water
and soap. In case of contact with eyes, rinse immediately with
plenty of water and seek medical attention. Consult an
opthalmologist in all cases.
Section 8 — Measures in Case of Accidents and Fire
Eye Contact:
Inhalation:
Flush eyes with running water for 15 minutes, while keeping
the eyelids wide open. Consult with an ophthalmologist in all
cases.
Remove subject from dusty environment. Consult with a
physician in case of respiratory symptoms.

Regenesis - ORC Advanced MSDS
Ingestion:
Skin Contact:
Special Precautions:
Specific Hazards:
If the victim is conscious, rinse mouth and admnister fresh
water. DO NOT induce vomiting. Consult a physician in all
cases.
Wash affected skin with running water. Remove and clean
clothing. Consult with a physician in case of persistent pain or
redness.
Evacuate all non -essential personnel. Intervention should only
be done by capable personnel that are trained and aware of the
hazards associated with this product. When it is safe,
unaffected product should be moved to safe area.
Oxidizing substance. Oxygen released on exothermic
decomposition may support combustion. Confined spaces
and/or containers may be subject to increased pressure. If
product comes into contact with flammables, fire or explosion
may occur.
Section 9 — Accidental Release Measures
Precautions:
Observe the protection methods cited in Section 3. Avoid
materials and products that are incompatible with product.
Immediately notify the appropriate authorities in case of
reportable discharge (> 100 lbs).
Collect the product with a suitable means of avoiding dust
formation. All receiving equipment should be clean, vented,
dry, labeled and made of material that this product is
Cleanup Methods: compatible with. Because of the contamination risk, the
collected material should be kept in a safe isolated place. Use
large quantities of water to clean the impacted area. See
Section 12 for disposal methods.
Section 10 — Information on Toxicology
Toxicity Data
Acute Toxicity:
Irritation:
Oral Route, LD50, rat, > 2,000 mg/kg (powder 50%)
Dermal Route, LD50, rat, > 2,000 mg/kg (powder 50%)
Inhalation, LD50, rat, > 5,000 mg/m3 (powder 35%)
Rabbit (eyes), severe irritant

Regenesis - ORC Advanced MSDS
Sensitization: No data
Chronic Toxicity: In vitro, no mutagenic effect (Powder 50%)
Target
Effects:
Organ
Eyes and respiratory passages.
Section 11— Information on Ecology
Ecology Data
10 mg Ca(OH)2/L: pH = 9.0
100 mg Ca(OH)2/L: pH = 10.6
Acute Exotoxicity: Fishes, Cyprinus carpio, LC50, 48 hrs, 160 mg/L
Crustaceans, Daphnia sp., EC50, 24 hours, 25.6 mg/L
(Powder 16%)
Mobility: Low Solubility and Mobility
Water — Slow Hydrolysis.
Degradation Products: Calcium Hydroxide
Abiotic Degradation: Water/soil — complexation/precipitation. Carbonates/sulfates
present at environmental concentrations.
Degradation products: carbonates/sulfates sparingly soluble
Biotic Degradation: NA (inorganic compound)
Potential for NA (ionizable inorganic compound)
Bioaccumulation:
Section 11— Information on Ecology (cont)
Comments:
Observed effects are related to alkaline properties of the
product. Hazard for the environment is limited due to the
product properties of:
• No bioaccumulation
• Weak solubility and precipatation as carbonate or
sulfate in an aquatic environment.
Diluted product is rapidly neutralized at environmental pH.
Further Information: NA

Regenesis - ORC Advanced MSDS
Section 12 — Disposal Considerations
Waste Disposal Consult current federal, state and local regulations regarding
Method: the proper disposal of this material and its emptied containers.
Section 13 — Shipping/Transport Information
D.O.T Shipping Oxidizing Solid, N.O.S [A mixture of Calcium OxyHydroxide
Name: [CaO(OH)2] and Calcium Hydroxide [Ca(OH)2].
UN Number: 1479
Hazard Class: 5.1
Label(s): 5.1 (Oxidizer)
Packaging Group: II
STCC Number: 4918717
Section 14 — Other Information
HIVES® Rating
Health — 2
Flammability — 0
Reactivity — 1
PPE - Required
HMIS® is a registered trademark of the National Painting and Coating Association.
Health — 2 Reactivity —1
NFPA® Rating
Flammability — 0 OX
NFPA® is a registered trademark of the National Fire Protection Association.
Reason for Issue: Update toxicological and ecological data
Section 15 — Further Information
The information contained in this document is the best available to the supplier at
the time of writing, but is provided without warranty of any kind. Some possible
hazards have been determined by analogy to similar classes of material. The items
in this document are subject to change and clarification as more information
become available.

Regen
Ox
TM
CHEMICAL OXIDATION REDEFINED...
RegenOxr" is an advanced in situ chemical oxidation technology* designed to treat organic
contaminants including high concentration source areas in the saturated and vadose zones
PRODUCT FEATURES:
Rapid and sustained oxidation of target compounds
• Easily applied with readily available equipment
Destroys a broad range of contaminants
• More efficient than other solid oxidants
• Enhances subsequent bioremediation
4g Avoids detrimental impacts to groundwater aquifers
RegenOx product application
HOW IT WORKS:
RegenOx maximizes in situ performance using a solid alkaline oxidant that employs a sodium percarbonate complex with
a multi -part catalytic formula. The product is delivered as two parts that are combined and injected into the subsurface using
common drilling or direct -push equipment. Once in the subsurface, the combined product produces an effective oxidation
reaction comparable to that of Fenton's Reagent without a violent exothermic reaction. RegenOx safely, effectively and rapidly
destroys a wide range of contaminants in both soil and groundwater (Table 1).
ACHIEVES RAPID OXIDATION VIA A NUMBER OF MECHANISMS
RegenOx directly oxidizes contaminants while its unique catalytic complex generates a suite of highly charged, oxidative free
radicals that are responsible for the rapid destruction of contaminants. The mechanisms by which RegenOx operates are:
• Surface- Mediated Oxidation: (see Figure 1 and description below)
Direct Oxidation: C2CL, + 2 Na,CO3 • 3 H20, + 2 H2O "—► 2CO3 + 4 NaCI + 4 H2O + 2 H,CO3
a Free Radical Oxidation:
— Perhydroxyl Radical (H02.)
— Hydroxyl Radical (OH-)
— Superoxide Radical (02')
Figure 1. Surface -Mediated Oxidation is
responsible for the majority of RegenOx
contaminant destruction. This process takes
place in two stages. First, the RegenOx activator
complex coats the subsurface. Second, the
oxidizer complex and contaminant react with
the activator complex surface destroying the
contaminant.
* Patent applied for
Figure 1. RegenOx'' Surface -Mediated Oxidation

From Mass Reduction to Bioremediation:
RegenOx`" is an effective and rapid contaminant mass reduction technology. A single injection will remove significant amounts
of target contaminants from the subsurface. Strategies employing multiple Regenox injections coupled with follow-on accelerated
bioremediation can be used to treat highly contaminated sites to regulatory closure. In fact, RegenOx was designed specifically to
allow for a seamless transition to low-cost accelerated bioremediation using any of Regenesis controlled release compounds.
Significant Longevity:
RegenOx has been shown to destroy contaminants for periods of up to one month.
Product Application Made Safe and Easy:
RegenOx produces minimal heat and as with all oxidants proper health and safety procedures must be followed. The necessary
safety guidance accompanies all shipments of RegenOx and additional resources are available on request. Through the use of
readily available, highly mobile, direct -push equipment and an array of pumps, RegenOx has been designed to be as easy to
install as other Regenesis products like ORC® and HRC®.
Effective on a Wide Range of Contaminants:
RegenOx has been rigorously tested in both the laboratory and the field on petroleum hydrocarbons (aliphatics and aromatics),
gasoline oxygenates (e.g., MTBE and TAME), polyaromatic hydrocarbons (e.g., naphthalene and phenanthrene) and chlorinated
hydrocarbons (e.g., PCE, TCE, TCA).
Oxidant Effectiveness vs. Contaminant Type:
Contaminant
RegenOx"
Tablet
Fenton's
Reagent Permanganate Persulfate
Activated
Persulfate
Ozone
Petroleum Hydrocarbons
A
A
B
B
B
A
Benzene
A
A
D
B
B
A
MTBE
A
B
B
C
B
3
Phenols 1
A
A
B
C
B
A
Chlorinated Ethenes
(PCE, TCE, DCE, VC)
A
A
A
B
A
A
Chlorinated Ethanes
(TCA, DCA)
A
B
C
D
C
B
Polycyclic Aromatic
Hydrocarbons (PAHs)
A
A
B
B
A
A
Polychlorinated
Biphenyls (PCBs)
B
C
D
D
D
13
Explosives (RDX, HMX)
A
A
A
A
A
A
Based on laboratory kinetic data, thermodynamic calculations, and literature reports.
Oxidant Effectiveness Key:
A = Short half life, low free energy (most energetically favored), most complete
B = Intermediate half life, low free energy, intermediate degree of completion
C = Intermediate half life, intermediate free energy, low degree of completion
D = Long half life, high free energy (least favored), very low degree of completion
REGENESIS
Advanced Technologies for Groundwater Resources
1011 Calle Sombra i San Clemente !California 92673-6244
Tel: [phone] Fax: [phone] i www.regenesis.com

Regen OX — Part A (Oxidizer Complex)
Material Safety Data Sheet (MSDS)
Last Revised: November 7, 2005
Section 1— Supplier Information and Material Identification
Supplier:
REGENES1S
1011 Calle Sombra
San Clemente, CA 92673
Telephone: [phone]
Fax: [phone]
E-mail: [e-mail]
Chemical Description:
Chemical Family:
Trade Name:
Product Use:
A mixture of sodium percarbonate [2Na2CO3.3H2O2],
sodium carbonate [Na2CO3], sodium silicate and silica gel.
Inorganic Chemicals
Regen Ox — Part A (Oxidizer Complex)
Used to remediate contaminated soil and groundwater
(environmental applications)
Section 2 — Chemical Information/Other Designations
CAS No.
15630-89-4
5968-11-6
1344-09-8
63231-67-4
Chemical
Sodium Percarbonate
Sodium Carbonate Monohydrate
Silicic Acid, Sodium Salt, Sodium Silicate
Silica Gel
Section 3 — Physical Data
Form:
Color:
Odor:
Melting Point:
Boiling Point:
Powder
White
Odorless
NA
NA

RegenOx — Part A
Section 3 — Physical Data (cont)
Flammability/Flash Point:
Vapor Pressure:
Bulk Density:
Solubility:
Viscosity:
pH (3% solution):
Decomposition
Temperature:
NA
NA
0.9 — 1.2 g/cm3
Min 14.5g/100g water @ 20 °C
NA
" 10.5
Self -accelerating decomposition with oxygen release starts
at 50 °C.
Section 4 — Reactivity Data
Stability:
Conditions to
Avoid/Incompatibility:
Hazardous Decomposition
Products:
Stable under normal conditions
Acids, bases, salts of heavy metals, reducing agents, and
flammable substances
Oxygen. Contamination with many substances will cause
decomposition. The rate of decomposition increases with
increasing temperature and may be very vigorous with
rapid generation of oxygen and steam.
Section 5 — Regulations
TSCA Inventory Listed: Yes
CERCLA Hazardous Substance (40 CFR Part 302)
Listed Substance:
Unlisted Substance:
No
Yes
SARA, Title III, Sections 313 (40 CFR Part 372) — Toxic Chemical Release Reporting:
Community Right -To -Know
Extremely Hazardous No
Substance:
WHMIS Classification:
Canadian Domestic
Substance List:
C, D2B
Appears
J:\Operations\MSDS\Regenox Page 2

RegenOx — Part A
Section 6 — Protective Measures, Storage and Handling
Technical Protective Measures
Storage:
Handling:
Oxidizer. Store in a cool, well ventilated area away from
all sources of ignition and out of the direct sunlight. Store
in a dry location away from heat and in temperatures less
than 40'C.
Keep away from incompatible materials and keep lids
tightly closed. Do not store in improperly labeled
containers.
Protect from moisture. Do not store near combustible
materials. Keep containers well sealed.
Store separately from reducing materials. Avoid
contamination which may lead to decomposition.
Avoid contact with eyes, skin and clothing. Use with
adequate ventilation.
Do not swallow. Avoid breathing vapors, mists or dust.
Do not eat, drink or smoke in the work area.
Label containers and keep them tightly closed when not in
use.
Wash hands thoroughly after handling.
Personal Protective Equipment (PPE)
Engineering Controls:
Respiratory Protection:
Hand Protection:
General room ventilation is required if used indoors. Local
exhaust ventilation, process enclosures or other
engineering controls may be needed to maintain airborne
levels below recommended exposure limits. Avoid
creating dust or mists. Maintain adequate ventilation at all
times. Do not use in confined areas. Keep levels below
recommended exposure limits. To determine actual
exposure limits, monitoring should be performed on a
routine basis.
For many conditions, no respiratory protection is
necessary; however, in dusty or unknown conditions or
when exposures exceed limit values a NIOSH approved
respirator should be used.
Wear chemical resistant gloves (neoprene, rubber, or
PVC).
J:\Operations\MSDS\Regenox Page 3

RegenOx — Part A
Section 6 — Protective Measures, Storage and Handling (cont)
Eye Protection:
Skin Protection:
Other:
Protection Against Fire &
Explosion:
Wear chemical safety goggles. A full face shield may be
worn in lieu of safety goggles.
Try to avoid skin contact with this product. Chemical
resistant gloves (neoprene, PVC or rubber) and protective
clothing should be worn during use.
Eye wash station.
Product is non -explosive. In case of fire, evacuate all non-
essential personnel, wear protective clothing and a self-
contained breathing apparatus, stay upwind of fire, and use
water to spray cool fire -exposed containers.
Section 7 — Hazards Identification
Potential Health Effects
Inhalation: Causes irritation to the respiratory tract. Symptoms may
include coughing, shortness of breath, and irritations to
mucous membranes, nose and throat.
Eye Contact: Causes irritation, redness and pain.
Skin Contact: Causes slight irritation.
Ingestion: May be harmful if swallowed (vomiting and diarrhea).
Section 8 — Measures in Case of Accidents and Fire
After Spillage/Leakage: Eliminate all ignition sources. Evacuate unprotected
personnel and never exceed any occupational exposure
limit. Shovel or sweep spilt material into plastic bags or
vented containers for disposal. Do not return spilled or
contaminated material to the inventory.
Extinguishing Media:
First Aid
Eye Contact:
Water
Flush eyes with running water for at least 15 minutes with
eyelids held open. Seek a specialist.
Inhalation: Remove affected person to fresh air. Seek medical
attention if the effects persist.
Ingestion: If the individual is conscious and not convulsing, give two-
four cups of water to dilute the chemical and seek medical
attention immediately. Do Not induce vomiting.
J:\Operations\MSDS\Regenox Page 4

RegenOx — Part A
Section 8 — Measures in Case of Accidents and Fire (cont)
Skin Contact:
Wash affected areas with soap and a mild detergent and
large amounts of water.
Section 9 — Accidental Release Measures
Precautions:
Cleanup Methods:
Shovel or sweep spilt material into plastic bags or vented
containers for disposal. Do not return spilled or
contaminated material to the inventory.
Section 10 — Information on Toxicology
Toxicity Data
LD50 Oral (rat):
LD50 Dermal (rabbit):
LD50 Inhalation (rat):
2,400 mg/kg
Min 2,000 mg/kg
Min 4,580 mg/kg
Section 11— Information on Ecology
Ecology Data
Ecotoxicological
Information:
NA
Section 12 — Disposal Considerations
Waste Disposal Method
Waste Treatment:
Package (Pail) Treatment:
Dispose of in an approved waste facility operated by an
authorized contactor in compliance with local regulations.
The empty and clean containers are to be recycled or
disposed of in conformity with local regulations.
J:\Operations\MSDS\Regenox Page 5

RegenOx — Part A
Section 13 — Shipping/Transport Information
D.O.T. Shipping Name: Oxidizing Solid, N.O.S. [A mixture of sodium
percarbonate [2Na2CO3.3H2O2], sodium carbonate
[Na2CO3], sodium silicate and silica gel.]
UN Number: 1479
Hazard Class: 5.1
Labels: 5.1 (Oxidizer)
Packaging Group: III
Section 14 — Other Information
HMIS® Rating
Health —1 (slight) Reactivity —1 (slight)
Flammability — 0 (none) Lab PPE — goggles, gloves,
and lab coat
HMIS" is a registered trademark of the National Painting and Coating Association.
Section 15 — Further Information
The information contained in this document is the best available to the supplier at the
time of writing, but is provided without warranty of any kind. Some possible hazards
have been determined by analogy to similar classes of material. The items in this
document are subject to change and clarification as more information become
available. This document is intended only as a guide to the appropriate precautionary
handling of the material by a properly trained person. Individuals receiving this
information must exercise their independent judgment in determining its
appropriateness for a particular purpose.
J:\Operations\MSDS\Regenox Page 6

Regen OX — Part B (Activator Complex)
Material Safety Data Sheet (MSDS)
Last Revised: November 7, 2005
Section 1— Supplier Information and Material Identification
Supplier:
REGENES1S
1011 Calle Sombra
San Clemente, CA 92673
Telephone: [phone]
Fax: [phone]
E-mail: [e-mail]
Chemical Description:
Chemical Family:
Trade Name:
Product Use:
A mixture of sodium silicate solution, silica gel and
ferrous sulfate
Inorganic Chemicals
Regen Ox — Part B (Activator Complex)
Used for environmental remediation of contaminated
soils and groundwater
Section 2 — Chemical Information/Other Designations
CAS No.
1344-09-8
63231-67-4
7720-78-7
7732-18-5
Chemical
Silicic Acid, Sodium Salt, Sodium Silicate
Silica Gel
Ferrous Sulfate
Water
Section 3 — Physical Data
Form:
Color:
Odor:
Melting Point:
Boiling Point:
Flammability/Flash Point:
Vapor Pressure:
Liquid
Blue/Green
Odorless
NA
NA
NA
NA

RegenOx — Part B
Section 3 — Physical Data (cont)
Specific Gravity 1.39 g/cm3
Solubility: Miscible
Viscosity: NA
pH (3% solution): 11
Hazardous Decomposition Oxides of carbon and silicon may be formed when
Products: heated to decomposition.
Section 4 — Reactivity Data
Stability: Stable under normal conditions.
Conditions to Avoid: None.
Incompatibility: Avoid hydrogen fluoride, fluorine, oxygen difluoride,
chlorine trifluoride, strong acids, strong bases, oxidizers,
aluminum, fiberglass, copper, brass, zinc, and
galvanized containers.
Section 5 — Regulations
TSCA Inventory Listed: Yes
CERCLA Hazardous Substance (40 CFR Part 302)
Listed Substance: No
Unlisted Substance: Yes
SARA, Title III, Sections 302/303 (40 CFR Part 355) — Emergency Planning and
Notification
Extremely Hazardous No
Substance:
SARA, Title III, Sections 311/312 (40 CFR Part 370) — Hazardous Chemical
Reporting: Community Right -To -Know
Hazard Category: Acute
SARA, Title III, Sections 313 (40 CFR Part 372) — Toxic Chemical Release
Reporting: Community Right -To -Know
Extremely Hazardous No
Substance:
Page 2

RegenOx — Part B
Section 6 — Protective Measures, Storage and Handling
Technical Protective Measures
Storage:
Keep in a tightly closed container (steel or plastic) and
store in a cool, well ventilated area away from all
incompatible materials (acids, reactive metals, and
ammonium salts). Store in a dry location away from
heat and in temperatures less than 24 ?C. Do not store in
aluminum, fiberglass, copper, brass, zinc or galvanized
containers.
Handling: Avoid contact with eyes, skin and clothing. Avoid
breathing spray mist. Use with adequate ventilation.
Do not use product if it is brownish -yellow in color.
Personal Protective Equipment (PPE)
Engineering Controls:
Respiratory Protection:
General room ventilation is required if used indoors.
Local exhaust ventilation, process enclosures or other
engineering controls may be needed to maintain airborne
levels below recommended exposure limits. Safety
shower and eyewash station should be within direct
access.
Use NIOSH-approved dust and mist respirator where
spray mist exists. Respirators should be used in
accordance with 29 CFR 1910.134.
Hand Protection: Wear chemical resistant gloves.
Eye Protection:
Skin Protection:
Other:
Wear chemical safety goggles. A full face shield may
be worn in lieu of safety goggles.
Try to avoid skin contact with this product. Gloves and
protective clothing should be worn during use.
Protection Against Fire & Product is non -explosive and non-combustible.
Explosion:
Page 3

RegenOx — Part B
Section 7 — Hazards Identification
Potential Health Effects
Inhalation:
Eye Contact:
Skin Contact:
Ingestion:
Causes irritation to the respiratory tract. Symptoms may
include coughing, shortness of breath, and irritations to
mucous membranes, nose and throat.
Causes irritation, redness and pain.
Causes irritation. Symptoms include redness, itching
and pain.
May cause irritation to mouth, esophagus, and stomach.
Section 8 — Measures in Case of Accidents and Fire
After Spillage/Leakage
(small):
After Spillage/Leakage
(large):
Extinguishing Media:
Further Information:
First Aid
Eye Contact:
Inhalation:
Ingestion:
Skin Contact:
Mop up and neutralize liquid, then discharge to sewer in
accordance with local, state and federal regulations.
Keep unnecessary personnel away; isolate hazard area
and do not allow entrance into the affected area. Do not
touch or walk through spilled material. Stop leak if
possible without risking injury. Prevent runoff from
entering into storm sewers and ditches that lead to
natural waterways. Isolate the material if at all possible.
Sand or earth may be used to contain the spill. If
containment is not possible, neutralize the contaminated
area and flush with large quantities of water.
Material is compatible with all extinguishing media.
Flush eyes with running water for at least 15 minutes
with eyelids held open. Seek a specialist.
Remove affected person to fresh air. Give artificial
respiration if individual is not breathing. If breathing is
difficult, give oxygen. Seek medical attention if the
effects persist.
If the individual is conscious and not convulsing, give
two-four cups of water to dilute the chemical and seek
medical attention immediately. DO NOT induce
vomiting.
Wash affected areas with soap and a mild detergent and
large amounts of water. Remove contaminated clothing
and shoes.
Page 4

RegenOx — Part B
Section 9 — Accidental Release Measures
Precautions:
PPE:
Environmental Hazards:
Cleanup Methods:
Wear chemical goggles, body -covering protective
clothing, chemical resistant gloves, and rubber boots
(see Section 6).
Sinks and mixes with water. High pH of this material
may be harmful to aquatic life. Only water will
evaporate from a spill of this material.
Pick-up and place in an appropriate container for
reclamation or disposal. US regulations (CERCLA)
require reporting spills and releases to soil, water and air
in excess of reportable quantities.
Section 10 — Information on Toxicology
Toxicity Data
Sodium Silicate:
When tested for primary eye irritation potential
according to OECD Guidelines, Section 405, a similar
sodium silicate solution produced corneal, iridal and
conjunctival irritation. Some eye irritation was still
present 14 days after treatment, although the average
primary irritation score has declined from 29.7 after 1
day to 4.0 after 14 days. When tested for primary skin
irritation potential, a similar sodium silicate solution
produced irritation with a primary irritation index of 3 to
abraded skin and 0 to intact skin. Human experience
confirms that irritation occurs when sodium silicates get
on clothes at the collar, cuffs, or other areas where
abrasion may exist.
The acute oral toxicity of this product has not been
tested.
Ferrous Sulfate: LD50 Oral (rat): 319 mg/kg not a suspected carcinogen.
Page 5

RegenOx — Part B
Section 11— Information on Ecology
Ecology Data
Ecotoxicological Based on 100% solid sodium silicate, a 96 hour median
Information: tolerance for fish of 2,320 mg/1; a 96 hour median
tolerance for water fleas of 247 mg/L; a 96 hour median
tolerance for snail eggs of 632 mg/L; and a 96 hour
median tolerance for Amphipoda of 160 mg/L.
Section 12 — Disposal Considerations
Waste Disposal Method
Waste Treatment:
Package (Pail) Treatment:
Neutralize and landfill solids in an approved waste
facility operated by an authorized contactor in
compliance with local regulations.
The empty and clean containers are to be recycled or
disposed of in conformity with local regulations.
Section 13 — Shipping/Transport Information
D.O.T. This product is not regulated as a hazardous material so
there are no restrictions.
Section 14 — Other Information
HMIS Rating
Health — 2 (moderate) Reactivity — 0 (none)
Flammability — 0 (none) Lab PPE — goggles,
Contact —1 (slight) gloves, and lab coat
HMISis a registered trademark of the National Painting and Coating Association.
Section 15 — Further Information
The information contained in this document is the best available to the supplier at
the time of writing, but is provided without warranty of any kind. Some possible
hazards have been determined by analogy to similar classes of material. The items
in this document are subject to change and clarification as more information
become available. This document is intended only as a guide to the appropriate
precautionary handling of the material by a properly trained person. Individuals
receiving this information must exercise their independent judgment in determining
its appropriateness for a particular purpose.
Page 6

RegenOx — Part B
Page 7

APPENDIX B
GASTON COUNTY MAPS

Map Output
Disclaimer: The information provided is not to be considered as a L
Gaston County does not guarantee the accuracy of thi:
Page 1 of 1
http://public_gis.co.gaston.nc.us/website/ParcelDai
10/19/2004

Map Output
Disclaimer: The information provided is not to be considered as a
Gaston County does not guarantee the accuracy of th
Page 1 of 1
http://public_gis.co.gaston.nc.us/website/Parcela
10/25/2004

Michael F. Easley, Governor
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
Coleen H. Sullins Director
Division of Water Quality
July 11, 2007
Forrest W. Stevenson
Norfolk Southern Railway Company
110 Franklin Road, SE, Box 13
Roanoke, VA 24042-0013
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
7006 2150 0003 5466 3174
Subject: Notice of Expiration
UIC Permit No. WI0300065
Virginia Avenue Auto & Wrecker
Gaston County
Dear Mr. Stevenson:
The Underground Injection Control (UIC) Program of the North Carolina Division of Water
Quality is responsible for regulating injection well construction and operation activities within
the state. Our records show that the injection well permit referenced above will expire on
December 1, 2007. This permit was issued on December 6, 2004 for the injection system located
at 201 West Virginia Avenue in Bessemer City, North Carolina.
Please submit the enclosed form, STATUS OF INJECTION WELL SYSTEM (form GW/UIC-68) to
indicate the current status of this injection well system within 30 calendar days of the receipt of
this letter. If you intend to conduct additional injections or pursue any injection -related activities
that are beyond the scope of the permit referenced above, you must submit a letter requesting a
renewal and/or amendment of the permit that describes in detail the procedure, locations,
volume, and frequency of injected material, and any other pertinent information regarding the
proposed activity.
In addition, our records indicate that a final project evaluation is due within 9 months after
completion of the injection operation. If the injection project has been completed, please submit
the required final project evaluation as indicated in your permit in PART VII — MONITORING
AND REPORTING REQUIREMENTS.
If any injection well is no longer being used for any purpose, it must be permanently abandoned
according to the regulatory requirements specified in the North Carolina Administrative Code
Title 15A Subchapter 2C Section .0214. If any injection well is to be permanently abandoned,
well abandonment records must be submitted to our office to ensure proper abandonment.
Aquifer Protection Section 1636 Mail Service Center
Internet: www.ncwaterqualitv.org Location: 2728 Capital Boulevard
An Equal Opportunity/Affirmative Action Employer— 50% Recycled/10% Post Consumer Paper
NorthCarolina
Naturally
Raleigh, NC 27699-1636 Telephone: [phone]
Raleigh, NC 27604 Fax 1: [phone]
Fax 2: [phone]
Customer Service: [phone]

Please call Qu Qi at [phone], or email him at [e-mail] if you have any questions
regarding this correspondence, your permit, or the enclosed form.
Sincerely,
W
Jesse Wiseman
Aquifer Protection Section
Enclosure
cc: Suzanne Bailey, MM&A _
fo_oresville.Regional-Office._APS w/o -enclosure_ 1
APS Central Files - Permit No. WI0300065 w/o enclosure

MEMORANDUM
To:
From:
Re:
DIVISION OF WATER QUALITY
AQUIFER PROTECTION SECTION
December 7, 2004
!Andrew-P-itner, Aquifer Protection Supervisor
Mooresville Regional Office
Mike Ranck/t
Central Office
Issuance of injection well permit type 5I (in -situ groundwater remediation well)
Permit Number WI0300065
Norfolk Southern Railway Company
Permit Number WI0300065 is for the injection of Oxygen Release Compound® to enhance
bioremediation of the dissolved phase hydrocarbon contamination at this site. These injection
wells will be located at 201 W. Virginia Avenue, Bessemer City, North Carolina, Gaston 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 [phone] 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
December 7, 2004
Mr. Forrest W. Stevenson
Norfolk Southern Railway Company
110 Franklin Road, SE, Box 13
Roanoke, VA 24042-0013
Dear Mr. Stevenson:
In accordance with your application received on August 25, 2004, we are forwarding Permit No.
WI0300065 for the operation of Type 5I injection wells at 201 W. Virginia Avenue, Bessemer
City, North Carolina.
This permit shall be effective from the date of issuance until December 1, 2007, 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.
If you have any questions regarding your permit please contact me at [phone] or Evan
Kane at [phone].
Sincerely,
/. &Wed ilt/4„.
J. Michael Ranck
Hydrogeologist
Groundwater Protection Unit
cc: Andrew Pitner, MRO
CO-UIC file
Suzanne Bailey, MM&A
Enclosures
No One Carolina
aurally
Aquifer Protection Section 1636 Mail Service Center Raleigh, NC 27699-1636
Internet: http://h2o.enr.state.nc.us 2728 Capital Boulevard Raleigh, NC 27604
An Equal Opportunity/Affirmative Action Employer-50% Recycled/10% Post Consumer Paper
Phone [phone] Customer Service
Fax [phone]
Fax [phone]

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
Norfolk Southern Railway Company
FOR THE CONSTRUCTION AND OPERATION OF TYPE 5I INJECTION WELLS, defined
in Title 15A North Carolina Administrative Code 2C .0209(e)(3)(C), for use to inject Oxygen
Release Compound® for enhanced bioremediation of dissolved petroleum hydrocarbons. These
injection wells will be located at 201 West Virginia Avenue, Bessemer City, North Carolina, and
will be operated in accordance with the application submitted August 25, 2004 and in conformity
with the specifications and supporting data submitted November 1, 2004, all of which are filed
with the Department of Environment and Natural Resources and are considered a part of this
permit.
This permit is for Construction and Operation only, and does not waive any provisions of the
Water Use Act or any other applicable Laws, Rules, or Regulations. Operation and use of an
injection well shall be in compliance with Title 15A North Carolina Administrative Code 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 December 1,
2007, and shall be subject to the specified conditions and limitations set forth in Parts I through
X hereof.
Permit issued this the (n day of reC*nkrt ( , 2004.
(05\c,-
'Ted L. Bush, Jr., Chief
Aquifer Protection Section
Division of Water Quality
By Authority of the Environmental Management Commission.
Permit No. WI0300065 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 peiniit, 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. A completed Well Construction Record (Form GW-1) must be submitted for each injection
well to DENR-Division of Water Quality, Aquifer Protection Section — UIC Program, 1636
Mail Service Center, Raleigh, NC 27699-1636, within 30 days of completion of well
construction.
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].
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.
Permit No. WI0300065 PAGE 2 OF 6
ver.7/04 AP/UIC-6

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 maybe 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 -
Underground Injection Control (UIC), Central Office staff, telephone number (919) 715-
6164. 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.
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
Permit No. WI0300065 PAGE 3 OF 6
ver.7/04 AP/UIC-6

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 monitor plan included in the application shall be followed. In addition to the
monitor plan in the application, all samples shall be analyzed for ferrous iron, oxidation-
reduction potential, biological oxygen demand, and chemical oxygen demand. Additionally,
samples shall be collected and analyzed from MW-1 on the same schedule as MW-3, MW-6,
and MW-7. All sample results shall be submitted to the Aquifer Protection Section's
Mooresville Regional Office and the Raleigh Central Office (see VII-3 for addresses). 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 final project evaluation shall be submitted to the Underground Injection Control
Program, Aquifer Protection Section, NC DENR-Division of Water Quality, 1636 Mail
Service Center, Raleigh, NC 27699-1636 and to the Aquifer Protection Section, Mooresville
Regional Office, 610 East Center Avenue, Suite 301, Mooresville, NC 28115.
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
Permit No. WI0300065 PAGE 4 OF 6
ver.7/04 AP/UIC-6

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 three (3) months 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
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.
Permit No. WI0300065 PAGE 5 OF 6
ver.7/04 AP/UIC-6

(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. Exposure can cause irritation of skin, eyes, nose, and throat.
2. Contents within the product proposed for use may ignite combustibles (wood, paper and oil).
In addition, contents within the product react violently with reducing agents, hydrocarbons
such as fuels, and strong acids which can lead to a fire hazard.
3. If the products are released into the environment in a way that could result in a suspension of
fine solid or liquid particles (e.g., grinding, blending, vigorous shaking or mixing), then it is
imperative that proper personal protective equipment be used. The application process
should be reviewed by an industrial hygienist to ensure that the most appropriate personal
protective equipment is used.
4. Persons working with these products should wear goggles or a face shield, gloves, and
protective clothing. Face and body protection should be used for anticipated splashes or
sprays.
5. Eating, drinking, smoking, handling contact lenses, and applying cosmetics should not be
permitted in the application area during or immediately following application.
6. Safety controls should be in place to ensure that the check valve and the pressure delivery
systems are working properly.
7. The Material Safety Data Sheets should be followed to prevent incompatible or adverse
reactions and injuries.
8. Access to the area of application should be limited to the workers applying the product. In
order to minimize exposure to unprotected individuals, measure should be taken to prevent
access to the area of application.
Permit No. WI0300065 PAGE 6 OF 6
ver.7/04 AP/UIC-6

October 28, 2004
Mr. Michael Ranck
Groundwater Protection Unit
NCDENR-DWQ
1636 Mail Service Center
Raleigh, North Carolina 27699-1637
Re: Addendum to Application for Permit, Class 5I Wells
Virginia Avenue Auto & Wrecker Site
Bessemer City, Gaston County, North Carolina
Pollution Incident #19216
Norfolk Southern File No. 1-9-NC-BSMR-UT98.133-002
MM&A Project # NS1411
Dear Mr. Ranck:
Marshall Miller & Associates, Inc. (MM&A), on behalf of Norfolk Southern Railway
Company (NSRC), is submitting the enclosed information as an addendum to the Class 5I
Well Permit Application, per your letter dated September 24, 2004. Following are
numbered responses corresponding to your comments in the September 24, 2004 letter.
A copy of your letter is enclosed for reference in Attachment 1.
1. Per our telephone conversation on October 5, 2004, MM&A has enclosed copies
of the groundwater potentiometric maps from the last three sampling events at the
site (Attachment 2). Monitoring wells MW-3, MW-6, and MW-7 are down
gradient from the proposed ORC treatment wells (MW-2 and MW-4). The 2003
groundwater elevations at MW-3, MW-6, and MW-7 are lower than those of
MW-2 and MW-4. In June 2002, groundwater elevations were lower overall,
reflecting regional drought conditions. During that time, groundwater elevations
at MW-6 and MW-7 were lower than MW-2 and MW-4, while the groundwater
elevation at MW-3 was similar to MW-2 and MW-4. Table 1 (Attachment 3)
summarizes monitoring well depths, screening intervals, and historical
groundwater elevation data. MW-3, MW-6, and MW-7 will be used to monitor
the effects of oxygen injection at the site.
2. The topographic and tax maps in Attachment 4 were obtained from the Gaston
County website (www.co.gaston.nc.us). The topographic map has a five-foot
contour interval and the tax map illustrates the NSRC right of way which
encompasses the site at 201 W. Virginia Avenue. In Attachment 5, MM&A has
included a site map showing the approximate NSRC right of way property
8371 Melrose Drive / Lenexa, KS 66214 / Tel [phone] / Fax [phone]
Web Site — http://www.mmal.com • E-mail — [e-mail]
ranch Offices in Bluefield, VA / Richmond, VA / Kingsport, TN / Charleston, WV / Morgantown, WV / Lexington, KY / Raleigh, NC / Harrisburgh, PA

Mr. Michael Ranck
NCDENR-DWQ
October 28, 2004
Page 2
boundaries, November 2003 isoconcentration maps for all detected chemicals in
groundwater, and cross sections for the site. Cross sections has been included
showing the approximate vertical extent of the dissolved plume at the site.
3. The cross sections A -A' and B-B' in Attachment 5 illustrate the approximate
depth of petroleum impacts at the site. Soil data have been provided, where
available. Groundwater analytical data for the November 2003 sampling event
have also been included on the cross sections.
4. Attachment 6 includes the drilling logs with well construction diagrams for all
monitoring wells at the site. In addition, the well depth and screen intervals for
each well are listed on Table 1 (Attachment 3).
MM&A appreciates the opportunity to provide this additional information to your
depai Intent. If you have any questions or comments, please call me at [phone].
Sincerely,
M�IZSHALL MILLER & ASSOCIA' §1 INC.
iste
Suzfiiine E. Bailey,
Branch Manager
Enclosures
cc: Forrest W. Stevenson, NSRC
File NS1411
\► HALL\\LLE

Attachment 1
NCDENR Letter — September 24, 2004

o' WA1
Q�
RECEIVED
OCT 0 4 1UU4
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
September 24, 2004
Mr. Forrest Stevenson
Norfolk Southern Railway Company
110 Franklin Road, SE, Box 13
Roanoke, VA 24042-0013
Subject: Type 5I Injection Well Permit Application
Virginia Avenue Auto & Wrecker Site, Bessemer City, NC
Dear Mr. Stevenson:
Norfolk Southern Railway Company's application for a permit to use wells for the injection of
ORC® at the subject site is currently under review. Applications for injection must adhere to the
North Carolina Administrative Code (NCAC), Title 15A, Subchapter 2C. In this regard, we have
found your application incomplete. In order for our staff to complete their review of your permit
application, please address the following issues:
1. Submit a revised monitoring procedure that includes a monitor well array
downgradient from the injection locations in accordance with 15A NCAC 2C
.0213(c)(2)(D). Injection wells (e.g. MW-2, MW-4) should not be used as
monitor wells. 15A NCAC 2C .0213(c)(2)(D) requires that monitoring wells
shall be located in such a fashion as to detect any movement of injection
fluids, process by-products, or formation fluids outside the injection area or
zone.
2. Submit a site map including all property boundaries, contour intervals not
exceeding two feet, and the horizontal and vertical extent of the contaminant
plume (including plume cross sections), in accordance with 15A NCAC 2C
.0211(d)(1)(D) and (d)(3)(B).
3. Submit a cross section of the subsurface to a depth that includes the known or
projected depth of contamination, as required by 15A NCAC 2C
.0211(d)(3)(D). •
4. Submit plans for the proposed location and construction details of the
groundwater monitoring well network, in accordance with 15A NCAC 2C
.0211(d)(3)(G).
N"os,�e Carolina
,Naturally
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]
An Equal Opportunity/Affirmative Action Employer — 50% Recycled/10% Post Consumer Paper

Mr. Forrest Stevenson
September 24, 2004
Page 2
You are requested to submit this additional information within 30 days of receipt of this letter,
otherwise your application will be returned. If you have any questions regarding this letter or
your permit application, please contact Michael Ranck at [phone].
Sincerely,
Debra J. Watts
Supervisor
Groundwater Protection Unit
cc: Suzanne Bailey, Marshall Miller & Associates
APS-Mooresville Regional Office UIC
UIC Central Office File

Attachment 2
Groundwater Potentiometric Maps

MW-7
880.75
50'
881
yR-"A Alt STORM
VIRGINIA
AVENUE
AUTO
FIBER OPTIC CABLE
RAILROAD
BRIDGE
882
MW—B
PENNSYLVANIA AVE. 880.05
0
50'
1"=50
NOTE The location and dimensions of features shown on this map have
been derived from various sources and supplemented by field
measurements. Though sufficient for its intended purpose, no
claim is made as to the degree of accuracy of this drawing.
MW-1
883.39
885.
8
883.40�
t'
M ` —2
MW1
880.05
N 881.99
5
3
1
LEGEND
MONITORING WELL
GROUND WATER ELEVATION CONTOUR
(CONTOUR INTERVAL=1FOOT)
APPROXIMATE GROUND WATER
FLOW DIRECTION
NOTES:
1: GROUND WATER ELEVATION IN
FEET ABOVE MEAN SEA LEVEL
2: GROUND WATER ELEVATIONS
OBTAINED ON NOVEMBER 10, 2003
FIGURE 3
GROUND WATER CONTOUR MAP
NOVEMBER 2003
NORFOLK
SOUTHERN
•
201 W. VIRGINIA AVENUE
BESSEMER CITY, NC
DATE:
JAN. 2004
SCALE:
1"=50'
DESIGNED:
SB
DRAWN:
BFW

MW-1
876
LEGEND
MONITORING WELL
GROUND WATER ELEVATION CONTOUR
(CONTOUR INTERVAL=1FOOT)
APPROXIMATE GROUND WATER
FLOW DIRECTION
883.69
MW-7
VIRGINIA
AVENUE
AUTO
G11y1A Alt
MW-1
STORM
SEWER
883.90
MW-2
8 86 .96
//FIBER OPTIC CABLE Nil\0q ch
PENNSYLVANIA AVE.
RAILROAD
BRIDGE
882.42
40*
MW-6
NOTES:
1: GROUND WATER ELEVATION IN
FEET ABOVE MEAN SEA LEVEL
2: GROUND WATER ELEVATIONS
OBTAINED ON MAY 14, 2003
5
884.26
*W 3
883.11
1
50'
0
50'
1"=50'
FIGURE 3
SHOWING:
GROUND WATER CONTOURS-05/03
BESSEMER CITY, NC
Designed:
Drawn:
SB
D
Checked. SB
Project Number.
N51411
Date:
JUL Y, 2003
Scale:
= 50'
File Name:
F70-3. dwg
Map Number.

WELL #
NORTHING
EASTING
GROUND
ELEV.
TOP OF
CASING ELEV.
W. L.
06/12/02
GW
ELEV.
MW-1
566543.66
1317774.06
895.49
894.72
17.41
877.31
MW-2
566541.05
1317790.01
894.77
894.30
17.63
876.67
MW-3
566513.84
1317811.44
894.07
893.84
17.39
876.45
MW-4 '
566489.85
1317773.66
894.84
894.33
18.25
876.08
MW-5
5665432.72
1317810.50
894.49
894.18
17.29
876.89
MW-6
566349.02
1317710.90
893.58
893.26
19.76
873.50
MW-7
566359.57
1317639.10
896.02
895.81
DRY
NA
LEGEND
• MONITORING WELL
MW-1
876.00
GROUNDWATER CONTOUR
CONTOUR INTERVAL = 1.0 FT.
NA NOT APPLICABLE
NA
MW-7
875.00
874.00
t/RGINIA A
VIRGINIA
AVENUE
AUT0877.
876.00
FIBER 0P11C CABLE
RAILROAD
BRIDGE
873.50
MW-
PENNSYLVANIA AVE.
NOTE: GROUNDWATER MEASUREMENTS COLLECTED ON JUNE 12, 2002
MW-1
877`31*
•
STORM
SEWER
874.00
50
5
89
3
.45
875.00
0
877.p0
50
100
SCALE IN FEET
Bu rns&
McDon nell
SIIICE 1898
Figure 2
GROUNDWATER
POTENTIOMETRIC
SURFACE MAP
NORFOLK SOUTHERN
RAILWAY COMPANY
BESSEMER CITY, NC

Attachment 3
Table
SOCI: ES

Ground Water Elevation and
ca
co
co L
4E' .0
d
E 0
• Z
al
d
• V
2 `m
E
G7 Gf
LL N
N
d
m
FIELD MEASUREMENT DATA �I
^i T bI
QF.ZZZZZO
Q d Q Q Q N N M .N. V
OOO,.OzZZZZZOOOZ-.OZZZZZZCNOON
Q Q Q Q Q N Q l-: ao
d Q Q Q Q 7); O o�0 21 53 'Z
OZZZZZZOOCON".z
Q Q Q Q Q g M N M 8,1
Specific
Conductivity
(uS/cm)
d Q d d Q 00 0 80 N 00 00 N
ZZZZZ . V
Q d d Q Q 0 00 O O 00 00 00
ZZZZZ.~-.,.,,.,. ,..ZZZZZNNN-.
Q d 0 0 0 O N O vll O v
l Coo).
Q d Q Q Q P. F2 O -. l0 c. 7
ZZZZZr0oVC)
Gq
G
QddQd�crChV1,.ch°r°ddddd,)oco
ZZZZZvvvvvito; voZZZZZviv;v;vilcldo;ZZZzzv;vv;v;v,v;OZZZZZvvv;v;viv,rn
VDv°O�oQ
QdQdd��s�No�Qddddg�o00-00000
e y
i
EV
'
Q d d d d vl N O vl b V
Z Z Z Z Z O 0' s. 0'
Q Q Q d Q N O O '7 rn W O
Z Z Z Z Z- N N- N N _
Q d Z d M V 0\ 00 N W T
ZZ Z Z Z ry O O ry
vl N r" V 7 -•
d Z d d
Z Z Z Z Z oo O+ o0 00 h N -,-:•
GROUND WATER ELEVATION DATA
Groundwater
Elevation
(ft MSL)
vl M .-. N O \0 O N .-. I, O T
Q. -- -. V V ch N„ M M vl M
00 N N 00 N 6 vl 00 N- r- 0O 00
00 00 00 00 00 00 0 00 00 00 00 00
00 a0 00 00 00 00 00 00 00 00 00 00
en n CO VD 1, -• 7 O r- on O O
r, M o l or, vl .. M 7 40 Q. 01 <t
W 00 .. 00 -. lZ N N N N 00 0
00 00 00 00 00 00 00 00 00 00 00 00
co 00 00 00 00 00 00 00 00 00 co 00
`7 vl -. O V' M vl 00 vl .-+ -. CA
Cl N N O V0 on O O1 V' 00 -. 0\
Do 00 -. 01 0. W �0 �0 �O N 00 00
00 00 00 00 00 00 00 00 00 00 00 00
co 00 00 W co 00 00 00 00 00 00 00
rn M O '7 .• 0\ .-. V0 00 -. V0 00
M .--. .-. d' T Ol 7 0\ co V cp N
00 .. -. lZ O up V �0 00 7 00 vl
00 00 00 00 00 00 00 00 00 00 00 00
co 00 co 00 co 00 00 00 OO 00 00 00
Depth
to Water
(ft TOC)
r- 00 .-. co N b N co vl 00
l- vl V0 on rh N vl VD 47 '+l N onvl
00 N N 6 N l4 00 6 N 00 W .-.
r- 00 N V 00 01 VD O 00 r- O O
01 0\ O1 V- -. 0\ CN VD en V' Ol
vl N N vl N N 00 6 lz Ol O O
O 01 00 V' O -. 00 \0 00 00 00 vl
VDvl VD 0o N vl l- 00 on O l— co)
V"i N N V N vl lZ b N 0; O -.
CD O 00 00 Cl V' N N vl N
O N N 00 7 M T of N 00 M O
6 rri r.l b 00 00 00 N 00 01 0\
Top of
Casing
Elevation (ft MSL)
N N N N N N N N N N N N
N N N N N N n N r V- N n
00 00 00 0 00 00 0 00 00 00 7 00
00 00 00 O\ 00 0l 0, 0l 00 00 00 00
00 00 00 00 00 00 00 00 00 00 00 CO
O O O O O O O O O O O O
M on r•1 en r+l rrl r+l r+l M M rrl M
00 00 00 00 00 00 R 00 00 V 00 00
0A COCr,01 00 00 0. 00 00 0Cr+0 ON 0l 00
00 00 00 00 00 W 00 00 00 00 00 00
V V' V '7 '7 '7 V' V' V <! '7 '7
00 00 00 00 00 00 00 00 00 00 00 00
M M 00 00 00 rri 00 00 00 00 rrl r.l
00 00 00 00 0A 00 0\ 01 00 00 00 01
00 00 00 00 00 00 00 00 00 00 Oo oo
00 rrl 00 r+l rn 00 rn rrl 00 00 00 00
en on on on r+l rn M rn r.'1 rrl M on
00 00 00 0 00 00 00 00 00 00 V V
00 O, CNN 0A 0l 01 0\ 0\ 00 0l 01 0A
00 oo 00 oo oo 0000 00 00 CO 00 oo
Ground
Surface
Elevation (ft MSL)
01 ON 0\ O. ON CI 0l 00 00 00 00 Ch
V V V V V V '7 '7 '7 7 7 7
vl vl vl vh v00 l vl vl l
Cr,00 00
0l 01 0l 0l 00 00 00 0001 01 00Ol
00 00 00 00 00 0o ao co 00 00 00 CO
r, c- N F- N N- N N N N S
[., N N N n n r N N r N N
v Ni 00 Ni Ni v Ni 00 00 00 00 00
01 0i 0` 00 00 00 00 00 0 00 00 00
CO 00 00 CO 00 00 00 0o 00 00 00 00
r- N 0 N t 0- N N N r- r-
o o O O O O O O O o 0 0
v 00 00 00 Ni 00 00 00 00 00 00 v
00000001 00COCO00 00 01 0000
00 00 00 00 00 00 00 00 00 00 00 00
v v v v v v v v v v v v
00 00 00 CO 00 00 00 00 CO 00 00 00
00 00 v 00 Ni 00 00 00 00 00 004
00 00Cl 0000 CO00 00 00 00 0001
00 00 CO 00 00 00 00 00 00 00 00 00
Date
Measured
00 C. O O N N N 00 00
CA-.„ 0 0 0 0 0 0 0 0 0 0 0
N b 00 Yr R N 00 V' N VO 7 O
C^ ". -. O rl N O -. r, .. ..
N 00 00 00 'V' 00 .-. 00 00 00 -.\N.
.-. O O O O O .. O O -. O ".
0\ O O O N N N 00 00
0, O CO O O O O O O O O O
n l0 00 Yr Y7 N Cl R N VD V O
O .-. -. O N N O -. N o...
00 00 00 R 00 -. 00 VD .. Vl ".
O O O O O -. O O .. O -.
00 0 0 0 N N N 00 00
rT 0 0 0 0 0 0 0 0 CO O O
t- b 00 7 'V N 00 V' N l0 V O
O .., ". -. O N N O .-. r4....
� 00 00 00 V 00 .-. 00 00 -. Vl .--.
O O O O O .-. O O -. O -.
ON O 0 0 -+ -. -. N N Cl 00 rrl
0, O O O O O O Co O O O O
N b 00 V R N T C N l0 -,. O
O ,. -. -. O N N O -. N
� 00 00 00 '7 00 -- it l0 .. 0 ..
O O O O O .. O O -• o -•
Screened
Interval
(ft bgs)
Un
N
O
V
N
O
vl
b
N
h
N
O
Total
Depth
(ft bgs)
vl
N
vl
N
41
In
00
N
Monitoring
Well Number
2
00

Table 1
Ground Water Elevation and
Field Measurement Data
Bessemer City, North Carolina
GROUND WATER ELEVATION DATA
FIELD MEASUREMENT DATA
Monitoring
Total
Screened
Ground
Top of
Depth
Groundwater
Specific
Dissolved
Well Number
Depth
Interval
Date
Surface
Casing
to Water
Elevation
Temperature
p13
Conductivity
Oxygen
(ft bgs)
(ft bgs)
Measured
Elevation (ft MSL)
Elevation (ft MSL)
(ft TOC)
(ft MSL)
(°Celsius)
(uS/cm)
(mg/1)
MW-5
25
10-25
12/07/99
894.49
894.18
15.09
879.09
NA
NA
NA
NA
03/16/00
894.49
894.18
12.50
881.68
NA
NA
NA
NA
03/18/00
894.49
894.18
12.52
881.66
NA
NA
NA
NA
09/14/00
894.49
894.18
14.89
879.29
NA
NA
NA
NA
04/04/01
894.49
894.18
12.18
882.00
NA
NA
NA
NA
08/22/01
894.49
894.18
16.08
878.10
20.1
4.26
1430
0.20
11/29/01
894.49
894.18
17.86
876.32
21.0
4.20
1510
0.77
03/04/02
894.49
894.18
16.33
877.85
20.6
4.67
1270
0.37
06/12/02
894.49
- 894.18
17.29
876.89
20.0
4.53
237*
0.34
11/26/02
894.49
894.18
18.66
875.52
17.9
5.28
1350
1.68
05/14/03
894.49
894.18
9.92
884.26
24.4
5.86
1770
1.3
11/10/03
894.49
894.18
12.25
881.93
19.4
9.91
1580
NM
MW-6
20.8
5-20
12/07/99
893.58
893.26
NA
NA
NA
NA
NA
NA
03/16/00
893.58
893.26
NA
NA
NA
NA
NA
NA
03/18/00
893.58
893.26
NA
NA
NA
NA
NA
NA
09/14/00
893.58
893.26
NA
NA
NA
NA
NA
NA
04/04/01
893.58
893.26
15.45
877.81
NA
NA
NA
NA
08/22/01
893.58
893.26
19.73
873.53
13.7
NA
NA
2.74
11/29/01
893.58
893.26
19.81
873.45
NA
NA
NA
NA
03/04/02
893.58
893.26
19.08
874.18
17.3
4.54
1520
4.90
06/12/02
893.58
893.26
19.76
873.50
NA
NA
NA
NA
11/26/02
893.58
893.26
Dry
<873.48
NA
NA
NA
NA
05/14/03
893.58
893.26
10.84
882.42
18.4
5.54
1850
11.6
11/10/03
893.58
893.26
13.21
880.05
16.7
6.31
1910
NM
MW-7
20.3
5-20
12/07/99
896.02
895.81
NA
NA
zzzzz:zzzz�
d d d d d d d d d d V
zzzzzzzzzzvi,g5
NA
NA
03/16/00
896.02
895.81
NA
NA
NA
NA
03/18/00
896.02
895.81
NA
NA
NA
NA
09/14/00
896.02
895.81
NA
NA
NA
NA
04/04/01
896.02
895.81
18.40
877.41
NA
NA
08/22/01
896.02
895.81
19.80
876.01
NA
5.23
11/29/01
896.02
895.81
Dry
NA
NA
NA
03/04/02
896.02
895.81
Dry
NA
NA
NA
06/12/02
896.02
895.81
Dry
NA
NA
NA
11/26/02
896.02
895.81
Dry
<875.90
NA
NA
05/14/03
896.02
895.81
12.12
883.69
1420
10.9
11/10/03
896.02
895.81
15.06
880.75
1310
NM
Notes:
Elevations are in reference to feet above mean sea level (MSL). bgs - below ground surface
ft - Feet TOC - Top of casing
uS/cm - Micro-siemen per centimeter NA - Not Available
mg I - Milligrams per liter • - Units are in micro -ohms per centimeter
NM- Not Measured
Table 1 Page 2 of 2

Attachment 4
Topographic and Tax Maps
•
SOCI • ES

Map Output Page 1 of 1
201 W. Virginia Avenue
4,
!"
Legend
Major Roads
AtioupSpcx3d35m I
Aweritp Spejed45sndi
Aserxp Cwvrl 55 CH41
Roads
'Parcel Lines
Topo Annotation
Easements
Paws
Raid
Tdgiticettl
Stricture Footprints
ADDITION
®UUSSTLYG
G NE
YEW
Qll T)ONAALE
Lases, Streams Edge
Tope (Contour Lines 5°
Intenrai)
Lidr.Cai .xr!1Y]
of corky Lin,
f./ STATE_tine
Disclaimer: The information provided is not to be considered as a Legal Document or Description. The Map and Parcel Data is believed to be accurate, but
Gaston County does not guarantee the accuracy of this information.
http://public gis.co.gaston.nc.us/website/ParcelDataSite/MapFrame.htm 10/19/2004

Map Output
Page 1 of 1
Print Scale 1:16096 or 1" = 1258'
201 W. Virginia Avenue
:t�; .
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teaall' _''•'►
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Legend
Major.Roads
`/ hMa9?ob135edl
A9xsaga S .u145 mCta
h.Sraed5ni0
Parboi Lines
/1 STATE Erne
.i
4,
OrAi.i
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Disclaimer: The information provided is not to be considered as a Legal Document or Description. The Map and Parcel Data is believed to be accurate, but
Gaston County does not guarantee the accuracy of this information.
http://publicgis. co.gaston.nc.us/website/ParcelDataSite/MapFrame.htm
10/25/2004

Attachment 5
Site Map, Cross Sections, and Isoconcentration Maps

MW-7
VIRGINIA
AVENUE
AUTO
FIBER OPTIC CABLE
PENNSYLVANIA AVE.
A
RAILROAD
BRIDGE
50' 0 50'
= 50'
yRGll ylq
STORM
SEWER
-1
5
3
LEGEND
MW-1
W MONITORING WELL
I I I I I I I RAILROAD TRACKS
NOTE: The location and dimensions of features shown on this map have A A' CROSS SECTION LINE
been derived from various sources and supplemented by field
measurements. Though sufficient for its intended purpose, no
claim is made as to the degree of accuracy of this drawing.
0
— RAILROAD RIGHT-OF-WAY
PROPERTY BOUNDARY (APPROXIMATE)
FIGURE 2
SITE MAP
MySNORFOLK
SOUTHERN
0
201 W. VIRGINIA AVENUE
BESSEMER CITY, NC
DATE:
JAN. 2004
SCALE:
1' = 50'
DESIGNED:
SB
DRAWN:
BFW
NS1411.dwg

� a
SOUTH
MW-6
CLAY -
ALL GROUND WATER RESULTS
FOR MW-6 WERE NON -DETECTABLE
11-10-03
1
-SS-1
- SS-2
•
SS-3
TD=20.8 FT.
NOTE: The location and dimensions of features shown on this map have
been derived from venous sources and supplemented by field
measurements. Though sufficient for its intended purpose, no
claim is made as to the degree of accuracy of this drawing.
Source map and date
20
10
0
APPROXIMATE
WATER TABLE
11-10-03
PROFILE SCALE
HORIZONTAL
1 "=20'
VERTICAL
1"=10'
VERTICAL
EXAGGERATION
2X
RAILROAD
EMBANKMENT.
MW-2
11/10/03
GROUND WATER RESULTS
BENZENE
12000
TOLUENE
36000
ETHYLBENZENE
2700
XYLENES
17000
NAPHTHALENE
950
2-METHYLNAPHTHALENE
180
APPROXIMATE
GROUND SURFACE
MW-4
11/10/03
GROUND WATER RESULTS
BENZENE
2200
TOLUENE
24000
ETHYLBENZENE
1800
XYLENES
11000
NAPHTHALENE
370
2- METHYLENAPHTHALEN E
59
20
40
CLAYEY SAND
SANDY CLAY
DISSOLVED IMPACTS ( CLAYEY SAND -
ABOVE NCDENR
GROUND WATER STANDARDS
(APPROXIMATE) �---�
(SANDY CLAY
LH,'GH,WD
SCREEN
MW-4
1
NORTH
MW-5
11/10/03
GROUND WATER RESULTS
BENZENE
260
TOLUENE
5500
ETHYLBENZENE
1500
XYLENES
8400
NAPHTHALENE
380
2-METHYLNAPHTHALENE
62
ASPHALT
PAVEMENT
MW-2 .MW-5
--
=
EXCAVATION
CLAY -
3SS-1
-
-
_
-SS-2
CLAYEY
-SS-3
FILL -
CLAY
,
SAND -
_
- 1
-
_
1 _ , -
'
-
-
-}
- SS-4
SANDY CLAY -
SS 5
/ I
TD=25 0 FT., TD WELL=25.0 FT.- _ --TD=25.0 FT,
L GROUND WATER ELEVATION (FT. MSL)
11-10-03
1.) BOLD VALUES EXCEED NCDENR
SOIL -TO -GROUND WATER MCLs
OR GROUND WATER STANDARDS.
2.) SOIL DATA IN MILLIGRAMS
PER KILOGRAM (MG/KG).
3.) GROUND WATER DATA IN
MICROGRAMS PER LITER (uG/L)
TD SOIL BORING=27.0 FT.
MW-2 SOIL RESULTS
SS-1
SS-2
SS-3
SS-4
SS-5
5-7
10-12
15-17
20-22
25-27
NAPHTHALENE
18.62
105.1
403.9
34.35
30.49
N-PROPYLBENZENE
13.77
70.15
232.2
23.38
20.62
1,2,4-TRIMETHYLBENZENE
109.4
764.7
586.E
235.1
213.9
1,3,5-TRIMETHYLBENZENE
31.67
219.1
536.2
52.99
47.08
XYLENES
213.9
1,482
3,934
420.1
336.1
BENZENE
1.812
25.29
63.16
9.545
4.028
ETHYLBENZENE
37.97
251.5
710.5
75.32
59.51
ISOPROPYLBENZENE
2464
13.75
44.74
4.935
4.167
STYRENE
3.623
24.49
67.11
6.039
4.722
TOLUENE
82.61
565.4
530.3
187.0
121.5
4-ISOPROPYLTOLUENE
ND
5.294
17.11
5.13
1.597
VPH C5-C8 ALIPHATICS
29.6
7,500
6,360
1,870
238
VPH C9-C12ALIPHATICS
16.5
3,530
3,080
1,350
135
VPH C9-C10 AROMATICS
19.3
3,530
2,950
1,640
179
❑❑
Y ;
5 �{g
❑ ❑
xg
t
A
d
PROJECT NO.: N51411
F.
2
z
a.. • ¢
• z
J
aw¢
U
a�
¢rr
u-zO
zz
USE
F? U
O�w
`1J N W
O W
0 C°
z
CROSS -SECTIONAL VIEW A -A'

EAST
MW-3
zw
- J
W CC
CO 0_
MW-2
ASPHALT
PAVEMENT
WEST
MW-1
APPROXIMATE
GROUND SURFACE
L _
ICLAY-
\
1'
/
/
/
/
/
/
/
/
/
/
/
/
/
/
/
/
/
/
/
/
TD=31.5 FT.
UST
EXCAVATION
SURFACE CASIN
CLAY
]- SS-1
I SS-2
UST
EXCAVATION
L
APPROXIMATE
WATER TABLE
11-10-03
SS-3
SS-4
- SS-5
TD WELL=25.0 FT.
/ TD SOIL BORING=27.0 FT.
MW-3
11/10/03
GROUND WATER RESULTS
BENZENE
TOLUENE
ETHYLBENZENE
XYLENES
NAPHTHALENE
1400
18000
1800
10000:
390
`t%%tI ei1gt���,r
•,,,,to
NOTE: The location and dimensions of features shown on this mop hove
been derived from various sources and supplemented by field
measurements. Though sufficient for Its Intended purpose, no
claim is made as to the degree of accuracy of this drawing.
Source map and date
2
1
0
PROFILE SCALE
HORIZONTAL
1"=10'
VERTICAL
1"=10'
10
20
DISSOLVED IMPACTS
ABOVE NCDENR
GROUND WATER STANDARDS
(APPROXIMATE)
CLAY -
SS-1
•
SS-2
ss-3 - -
- TD WELL=25.0 FT.�SS 4
SSS
-SS.6'
TD SOIL BOR NG=42.0 FT
LEGEND
SCREEN
s GROUND WATER ELEVATION
(FT. MSL) 11-10-03
1.) BOLD VALUES EXCEED NCDENR
SOIL -TO -GROUND WATER MCLs
OR GROUND WATER STANDARDS.
2.) SOIL DATA IN MILLIGRAMS
PER KILOGRAM (MG/KG).
3.) GROUND WATER DATA IN
MICROGRAMS PER LITER (uG/L)
MW-1
11/10/03
GROUND WATER RESULTS
ETHYLBENZENE
XYLENES
NAPHTHALENE
2-METHYLNAPHTHALENE
35
600
38
22
MW-2
11/10/03
GROUND WATER RESULTS
BENZENE
12000
TOLUENE
36000
ETHYLBENZENE
2700
XYLENES
17000
NAPHTHALENE
950
2-METHYL NAPHTHALENE
180
MW-1 SOIL RESULTS
SS-1
10-12
SS-2
15-17
SS-3
20-22
SS-4
20-22
SS-5
25-27
SS-6
40-42
NAPHTHALENE
.0062
.3732
.0176
ND
.0038
zzzzzzzzz
000000000
N-PROPYLBENZENE
ND
.5070
ND
ND
ND
1,2,4-TRIMETHYLENZENE
ND
4.246
.1085
.0168
.0414
1,3,5-TRIMETHYLBENZENE
ND
1:444
.0331
.0046
.0095
XYLENES
ND
1.937
.0324
ND
.0135
VPH C5-C8 ALIPHATICS
ND
62.3
9.80
7.31
8.23
VPH C9-C12ALIPHATICS
ND
11.6
ND
ND
ND
VPH C9-C10 AROMATICS
ND
11.4
ND
ND
ND
EPH C9-C18 ALI PHATICS
ND
29.0
ND
ND
ND
SS-1
SS-2
SS-3
SS-4
SS-5
MW-2 SOIL RESULTS
5-7
10-12
15-17
20-22
25-27
NAPHTHALENE
18.62
105.11
403.9
34.35
30.49
N-PROPYLBENZENE
13.77
70.15
232.2
23.38
20.62
1, 2,4-TR I M ETHYLBENZEN E
109.4
764.7
586.8
235.1
213.9
1,3,5-TRIMETHYLBENZENE
31.67
219.1
536.2
52.99
47.08
XYLENES
213.9
1,482
3,934
420.1
336.1
BENZENE
1.812
25.29
63.16
9.545
4.028
ETHYLBENZENE
37.97
251.5
710.5
75.32
59.51
ISOPROPLYBENZENE
2.464
13.75
44.74
4.935
4.167
STYRENE
3.623
24.49
67.11
6.039
4.722
TOLUENE
82.61
565.4
530.3
187
121.5
4-ISOPROPYLTOLUENE
ND
5.294
17.11
5,13
1.597
VPH C5-C8 ALIPHATICS
29.6
7,500
6,360
1,870
238
VPH C9-C12 ALIPHATICS
16.5
3,530
3,080
1,350
135
VPH C9-C10 AROMATICS
19.3
3,630
2,950
1,640 ,
179
d
z
a
a
z
>-
ct
0-- z
2 z
O 0
U W cc
< w O
a1-
cc
z z
aim ��
> U
,_
to 2
Y N
cnu
JJo w
Ix CO
0
z
CROSS -SECTIONAL VIEW B-B'

•~ Ayr: STORM
MW-1
VIRGINIA ND
AVENUE 26
AUTO 4
FIBER OPTIC C LE
RAILRO
BRIDGE
MW-6
PENNSYLVANIA AVE ND
NOTE The location and dimensions of features shown on this map have
been derived from various sources and supplemented by field
measurements. Though sufficient for its intended purpose, no
claim is made as to the degree of accuracy of this drawing.
FIGURE 4
BENZENE IN GROUND WATER
ISOCONCENTRATION MAP
NOVEMBER 2003
LEGEND
MONITORING WELL
ND NOT DETECTED
—1,000 — BENZENE ISOCONCENTRATION CONTOUR
NOTES:
1: GROUND WATER SAMPLES COLLECTED
ON NOVEMBER 10, 2003
2: ALL RESULTS IN MICROGRAMS PER LITER (pg/L)
3: NCDENR GROUND WATER STANDARD FOR BENZENE=1 ug/L
NORFOLK
SOUTHERN
201 W. VIRGINIA AVENUE
BESSEMER CRY, NC
DATE:
JAN.2004
SCALE
1'
= 50'
DESIGNED:
BB
DRAWN:
BFW

yRGfNfA A it
STORM
MW-1
VIRGINIA ND
AVENUE
AUTO
FIBER OPTIC CAB
RAILROAD
BRIDGE
PENNSYLVANIA AVE.
NOTE The location and dimensions of features shown on this map have
been derived from various sources and supplemented by field
measurements. Though sufficient for its Intended purpose, no
claim is made as to the degree of accuracy of this drawing.
FIGURE 5
TOLUENE IN GROUND WATER
ISOCONCENTRATION MAP
NOVEMBER 2003
LEGEND
MVW1
MONITORING WELL
ND NOT DETECTED
-1,000 - TOLUENE ISOCONCENTRATION CONTOUR
NOTES:
1: GROUND WATER SAMPLES COLLECTED
ON NOVEMBER 10, 2003
2: ALL RESULTS IN MICROGRAMS PER LITER (Ng/L)
3: NCDENR GROUND WATER STANDARD
FOR TOLUENE=1,000 pg/L
NORFOLK
SOUTHERN
201 W. VIRGINIA AVENUE
BESSEMER CITY, NC
DATE:
JAN. 2004
SCALE
1'
= 50'
DESIGNED:
SB
DRAWN:
BFW

•
MW-7
ND
50'
VIRGINIA
AVENUE
AUTO
FIBER OPTIC C
RAILROAD
BRIDGE
MW-6
PENNSYLVANIA AVE ND
0
50'
1°=sa
�RG/N1
NOTE The location and dimensions of features shown on this map have
been derived from various sources and supplemented by field
measurements. Though sufficient for its intended purpose, no
claim is made as to the degree of accuracy of this drawing.
A A�
STORM
MW-1
5
3
LEGEND
MONITORING WELL
ND NOT DETECTED
—1,000— ETHYLBENZENE ISOCONCENTRATION CONTOUR
NOTES:
1: GROUND WATER SAMPLES COLLECTED
ON NOVEMBER 10, 2003
2: ALL RESULTS IN MICROGRAMS PER LITER (pg/L)
3: NCDENR GROUND WATER STANDARD
FOR ETHYLBENZENE=29 Jg/L
FIGURE 6
ETHYLBENZENE IN GROUND WATER
ISOCONCENTRATION MAP
NOVEMBER 2003
NORFOLK
SOUTHERN
201 W. VIRGINIA AVENUE
BESSEMER CITY, NC
DATE:
JAN. 2004
SCALE:
1"
= 50'
DESIGNED:
SB
DRAWN:
BFW

VIRGINIA
AVENUE
AUTO
MW-7
ND
MW-6
PENNSYLVANIA AVE. ND
50'
0
50'
1"= 50'
NOTE The location and dimensions of features shown on this nap have
been derived from various sources and supplemented by field
measurements. Though sufficient for its intended purpose, no
claim is made as to the degree of accuracy of this drawing.
LEGEND
MW-1
MONITORING WELL
ND NOT DETECTED
—5,000— XYLENE ISOCONCENTRATION CONTOUR
NOTES:
1: GROUND WATER SAMPLES COLLECTED
ON NOVEMBER 10, 2003
2: ALL RESULTS IN MICROGRAMS PER LITER (pg/L)
3: NCDENR GROUND WATER STANDARD
FOR XYLENES=530 pg/L
FIGURE 7
XYLIENE IN GROUND WATER
ISO CONCENTRATION MAP
NOVEMBER 2003
NORFOLK
SOUTHERN
201 W. VIRGINIA AVENUE
BESSEMER CITY, NC
DATE:
JAN. 2004
SCALE:
1"
= 50'
DESIGNED:
SB
DRAWN:
BFW

MW-7
ND
_
` 46'C1NlA A►t: STORM
�/SEWER
VIRGINIA
AVENUE
AUTO
FIBER OPTIC CA
RAILROAD
BRIDGE
MW-6
PENNSYLVANIA AVE ND
50' 0
50'
1"=50
NOTE The location and dimensions of features shown on this map have
been derived from various sources and supplemented by field
measurements. Though sufficient for its intended purpose, no
claim is made as to the degree of accuracy of this drawing.
MW1
LEGEND
MONITORING WELL
ND NOT DETECTED
-500 NAPHTHALENE ISOCONCENTRATION CONTOUR
NOTES:
1: GROUND WATER SAMPLES COLLECTED
ON NOVEMBER 10, 2003
2: ALL RESULTS IN MICROGRAMS PER LITER (Ng/L)
3: NCDENR GROUND WATER STANDARD
FOR NAPHTHALENE=21 Ng/L
FIGURE 8
NAPHTHALENE IN GROUND WATER
ISOCONCENTRATION MAP
NOVEMBER 2003
NORFOLIC
SOUTHERN
201 W. VIRGINIA AVENUE
BESSEMER CITY, NC
DATE:
JAN.2004
SCALE
1"=50'
DESIGNED:
SB
DRAWN:
BFW

Attachment 6
Well Drilling Logs and Construction Diagrams
►►E ' ►►
��; SOCI; ES

Drilling Lo
Protect Name
Nogfclit
Protect Number
q5?-S?0-y-aoy-ol
Boring Number'
r1 t- - /
Ground Elevation
Location
0'0) Iv. 1/I �u.; A A v e $�5.-'M P/ C;//
Pape /
o f 1/
Air Monitoring Equipment p
Total Footage , , _
Drilling Type
Hole Size
Overburden Footage
Bedrock Footage
No. 0f Samples
No. 0f Core Boxes
h1-5.4
/0,51/
a,o
A/g-
//4
Drilling Company ?lcAbL R(p71.1,,e(s 271,6 .
Drller (s)xfN fLDct id) Po&t-,fo4M5 i )"T Lt, hr,v ti /
OrBpng Rig
GPti Berri G. y$o
Type of
��
sampler Sp SPco»/
Date V /---5,/? Q To 6 / 6 L!1
r I f
Field Observer (s) g RR L[S
L
Depth
(feet)
Description
Class
Blow
Count
Recov.
Run/
Time
Sample
Desig.
PID (ppm)
Remarks/
Mater Levels
BZ
BH
O
-
f/},ferneA11-
y�"
_
•
•
•
090.E i
Sef vio _
oA.-itw -1
q....:ose,ve k5T)--eye
93D
8`'-9"A- to
/1- r _
BA_ is 6 S%ZD;
io.5 o p --
-
—
_
_
_
_
-
_
_
_
-,
_
—
-
_
2_
-
3—
4—
-c
5
-
6—
7-
8—
9-
10—
-
-
11—
-
-
12-
13—
14-
Clny, }-rote 9(4vec1 yeno�,,sl, Reci •
yfzida)/Da-9P,�ech-,,, 5bCii,v6.v-
pi-As-Iv:4/ CFiLL�
,;
^
f ` `f 7fZ y/ v4 --)P) l FF I" e ,-'n
Pin lc A.-.)-7c'( L)
%
//N/�/
/
a
J
� /50
l�o`
0
,
GGAyi yei/,;."�.;Sh fezi( sr/?� 1,
oj
d4�it, �;.-,,Fl :I14 e prs1--cc;,/Y
i
6
aC
9.L)
i0,6
SS-%
S✓
EPI)
vp//
17 _ o
; 0/5
�;/�ec55-/
BZ=Breathing Zone
BH=Bete Hole
S=Sample
WWijaaste
CnnsultanLS.

Drilling Log Continuation
A-ID/CTot 4-
Project Number 9g —7?..0 — q—ooj/'al
Project Name
Depth
(feet)
DescriptIon
15 = a'y, yellor~,5 h 4‘14 yAg%)
lb - �a.st ') q' t)mod; pri fr5
_ �� I
p
17
Class
Blow
Count
Recov.
Run/
Time
Sample
Deslg.
Boring Number
Page 'A of it
Date 6%.0T
PID (ppm)
C-9y/yedi.,i541r?Gr�Kyt?/C(+) r- f;
'1"
cif. fe . 4, tor)c-iXl",19, 5 it j #1c:51
—
a�=
a5 =
r
ye, llcw 2•5 y/ ) w; )„
yzif�wT, S re ft1 h /� ./R
b))
5 rpr-, z(
77 = Pq-e) Sh',/ y
3g
3`BZ=Breathing Zone BH=Bore Hole S=Sample
S/7/7
ao
az)
tom
do
!CY5
r
a.o
IO5D
ODD
)1Ic
>56
v
BZ I BH
P-L'0/ $o
P;'D - 55-
f--J 75-
f41
P 1?
p-77
Remarks/
Hater Levels
TL-4"R4
"ar).c' /ycv
:cso
Ssj k
., w-1,s5 -3
?o
1
1
•
Burns
Waste

Drilling Log Continuation
Boring Number Ai k' _
Protect Name A/p R_'oL 4
Page 3 of
Protect
Number 9aO— q?-0 -y-00 L/--O/
Date 6� .Vy�"'TTT"'
3
Depth
(feet)
Description
Class
Blow
Count
Recov.
Run/
Time
Sample
Desig.
PID (PPm)
Water Levels
BZ BH /��
��J
:
:
33
3�
3� ^
7=
3g=
¥J-544vb1c14fgo-1/4
If 1 ----
_
L/4i % yells a'sys ,-t..i7%� .
ye//.w,5i red ,„.,..>`:j'•„�'Sye7 )
�`� ,�
j1G9S),,;9
,D
11, s
35 /
5 C
v/�
r=o 'a
..
_
„30
c,�L C
30-3�
y
)1115
-
• _,
_
re3s —
S/
-
9"'I 44,9,13
1So 5 -
Tp=3j0' -
i1 30
r/Yeel w sy/6� —;'h
1c;SL, r ,, r�Ztr�
) r c•ht,
D51K l' dam., sf/fr=, fiHx
/
•
/si-0,9;1)
7/l
-�
a-o
11Y0
.
•
_—
.
Y I
i ,
�y
Ili-
o30
5.-C
VD e..3
vili
" =� s
y
=
_A
_
-
-
7' =ya0r spL; SPGoh,
rpm ya.d
=Breathing Zone
BH=Bore Hole
S=Sample
Burns
Sr.
Waste
Consultants,

Drilling Log Continuation
Protect Name Np jZ F°(
Project Number
Depth
fleet)
?8-9ac,-
Description
Class
Blow
Count
Recov.
Run/
Time
Sample
Deslg.
Boring Number / " ! ki — r
Pace if Of Y J
Oate 0.677 q
PID (ppm)
BZ BH S
Remarks/
Water Levels
/FI'v5t1
vveLL, cover
A d/� tio' N;imiz�
A A ,,,,,I. iA.0- ;Lie,
y "�fj7
BO�JoM o F-
oF-.e)/
er4- a5,0 Ft- i365
Pc 0
7/1/21-R t Z a
15.oF4-
v.ofc"5L )k4
\.,ed-► FI-a" r�rn1
)o
f.
1roJ-f-ef
ex)14rd/e'r
1240-t iikt r7ri-(;:i 71'
;'-� 3 t
1
A
1
1
1
1
BZ=Breathing Zone BH=Bore Hole S=Sample
Burns
Waste

Drilling Log
Project Name
NORFCLA-
Project Number
4g —9 — 1/oo 9 —(3' /
Boring Number
r} -7,
Ground Elevation
•
Location
p.a) w. VI1yiA-)/1 A-✓e nec5e--i9; Li11
Page
1 of 3
Alr Monitoring Equipment FITTotai
Footage a-2 0
Drilling Type
Hole Size Overburden Footage
Bedrock Footage
No. Of Samples
No. Of Core Boxes
N- 5A-
) 0 _ (or,) 1 a-7 o
NA-
5
N -
Drilling Company /1 6 L L 8 r oj- 4Pr 5
Driler (s) reti M L90n-.4 IdPo — Totin.5 °A,/ fci/vP yk"e,.)A 1 L
DrMling Rig Ceti Lf 4_ �T L7'S0
�
sT
pe of
Sampler 5/7Lif 5i'eo/1/
Date 6/ /9Q
!
To 6,/�6�r9
Field Observer (s) g le�6iS
Depth
(feet)
Description
Class
Blow
Count
Recov.
Run/
Time
Sample
Desig.
PID (ppm)
Remarks/
Water Levels
BZ BH JS
-
1=
2-
3-
4-
6-
-
-
8-
-
g
11—
-
12 _
-
13-
14
g ve',tiT,.4—
l 1
fps P = '1'35"
0 6515
/.'y;w-Ito -
'L-( -�
-,
_
,
-
-
-
—
-
-
apt' -
-
c 4 yi3one groye( aS%o(52,ie
Yei��
h rstip1 iD4p,_5,v-F1.+.0.-
(Pu)
w04 (5('
°rY (FCC
1/?)
/�n‹
r
j
1
C/`"�/l
^
PF
Mil3j%
vplp
- DV k0730
5 fiye55 3'
/
09/5
VDCS
1-Ti iqr<
vflii
BZ=Breathing Zone
BH=Bore Hole
S=Sampie
Waste
Consultants.

Drilling Log Continuation
Project Name
Protect Number
Depth
(feet)
NO, Fo1,K---
- Y coy-o/
Description
44-iz5.r<cooes-Se/,-9( �; f/,,,C
c FitiPy &lcKr54 /a-V(5-)',4
i of e l y fi- f/V n Y(ioR
17 -
Class
Blow
Count
i
%5
Recov.
Run/
Time
Gy/5
Sample
Desig.
15
i
)7
Tp OFlo,548cr, = -S.-o
oFb-
0473s
7
5$-5
yoc; 5
-06
v pfi-
Boring Number M
Page of
Date C/6/q,f
PID (ppm)
BZ I OH I S--
p ~73 5
p.Lp= j/32--
c
l'ry 'fo
)P7o=a92.-
I
1
Remarks/ -
-Water-Levels- -
o910
j•i r �^^�
5/`t el!
SS -Y
5hor-, -
645cA. ]
S,fed I
4).75'5
:Tr:5
- 1
4, t'k )( -
-1I
BZ=Breathing Zone
BH=Bore Hole S=Sample
Waste

Drilling Log Continuation
Boring Ntnber r/ w —
Protect Name A7o,Z / /IC
Page 3 of 3
Project Number (N- q ".)C> - L/ --coy -01 Coate
, 0/7',,,
Depth
(feet)
Description
Class
Blow
Count
Recov.
Run/
Time
Sample
Desig.
PID (PPm)
Remarks/
Water Levels
BZ
BH
S
-
-
-
P
F/ P711 MOvN{-
Govei
•a4pvLiix?-
•
•
OfSS
iN4// I-e// -
iS c,cf- -
tive// 5r i ee -
w' ' SL(p -
zip l o,07' :
411Spl1 _
L1n,r Fhi tg
r'
�n -}fir: ,�
Zc � -
7r01 KYa;1 /e4 -
—,
Cl/b4y -
=
)(co
SA5Pa►1
Coferf� �e n
wr►h FL" )1)
MovNi'Go ✓e( -
0.3o
w =iy s>•
cc�crZiz
-
:
_
-
-
—_
-
__
_
-
-
_
-
_
10,07- r
P'
L?2015e,(
`�
n�/,o
40
;
fe le
16 L'� 1
- •
591
iS.o
c-� r
, k �nsF
-}r.
jl ce� tn<<L
�'c
J-c F F
5L feery
-
-
7.O
B�t+G�, �r �,e 1-1-
asi q Fee-)-
NbT To 644
��-
B 6-5
t E
BZ=Breathing Zone
BH=Bore Hole
S=Sample
Burn.
Waste

Drilling Lo
Project Name
/ilOX Fo L X
Project Number
5'F- 92 v .- V - o o y — o ?
Boring Number M 1,‘/_3
Ground Elevation
Location
Page
/ o f 3
Air Monitoring Equipment `
"/D d'- LEA .0L tines
Total Footage l
�S•v
Drilling Type
Hole Size
Overburden Footage
Bedrock/Footage
No. 0f Samples
No. 0f Core Boxes
.N�-AA/A' ice'
Z ZS � 3 SS---7- — I 3S. 0 r
/ V,4
NA-
W,4
Drilling Company ge14,/- 1 1.✓ 2 // /1// / /I^
// /
Drifer (s) /ri^„; e fix.b
T^
Drilling Rig 0) ✓CISr ' //
�T���
Type of )
Sampler 2.1 �� �raM er^41rkvs
Date / z I/ /f
To J 2 ,-7 /S 5
Field Observer (s) ��- •�- g5 ch an
Depth
(feet)
Class
Blow
Count
Recov.
Run/
Time
Sample
P1D (ppm)
Description
Desig.
BZ
BH
S
Hater Levels
Ay114 1,1-
-
Conc(e+�
r.; 1)
/VA
/J'1-
llit
0 0
1_•
-
2-
3-
4-
5-
7 -
8-
9-
_7
sN�d GIc
`1 7) fps Cz �',
Y� l�) MLd,.,m
i /
CL
�3y�
y
g-
eo...
'o%
f'7
ZZo
-
_
-
-
-
-
-.
-
-
_
10--
_
11 _
12 =
_
13-
14 -
5,,,d7 c!47
1 z ,. Iv
,
f'a 4 I
,1111j P/
, )4ik (et
; lt) i J;
( o'^5 I
4 5 J.C.; I )'i'1 v I S
/
jl
2O�
2g7
-
--1
-
-
T,
-
=
_
=8reath:r.q Zone
= Bore Hole
=5empte
ttiaste —I

Drilling Log Continuation
Boring Number » L. _
Protect Name l.tj )X cr Z. ;'(
Page of 3
Project Number aYZ � - — � � y_ 0 c,
Date r ' % 1 - I Z / ;' .;' 'Y
Depth
(feet)
/
Description
Class
Blow
Count
Recov.
Run/
Time
mple
Sample
Deslg.
PID (ppm)
Remarks/
Water Levels
BZ
1 BH
1 S
_=
S 5 —
_
_
�-
3 —
fc:A) C 14 ac(t ill
CZ. / /e 3/6) 501"/
Cc.j5kCI) l•j /'G) )
we. 4- J
CL
;1/4
,'U.q
,VA
LE== DSo
''2.- 2 $7 ' l
�J
7 f
10
_.
-.
A; Ilz,) :D 35'
wella 31..
bfs. -
-
—
-
—
_
-
_
_
—
-
-
—
—
-
4.0M d 1 da = 3S D
J.
,_,,,cz
•
,� S- J r�
‘.:. rrd O.. 4-.y.;,'
::n,t 7 c i.:,j `.,
,Z/117fi -
j`j--/c/lee(- -
257<<"017
Jc- .-/ :I:
/ ": _
'� /SS,- -- -
O f Z ti _
/ ; Ji i
r� IL^Z —
0_ -
7J)
hZS.5 Sjf :
%)tcl. Z 55 -
•
i
tD1S--
fr L
I c,5) r. _'_
rtl ..lr lC.
2>;- ,, "- -
;2i. - '' /'/y -
-
S--7i JT 1i - ..-I,_—
\;,..,-,5
1
:
• f
,
/,
i
23
/ j I�
I
i I2C.S'
I I
i •
.9y -. l
; .',,-1 . -
I
I
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1
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i.2 ;z, -_ 7; 5
1 _�
/✓, .� / ) L. / 1 L
-
-,l,i-
1 3,r _
-j J . _-i - • -
— -
BZ=Breathing Zone
BH=Bore Hole
S=Sample
waste

Drilling Log Continuation
Boring Number _yr,// L✓ —3 I
Project Name /1/45/1 J-p L 1C
Pape Z of
Project Number yc-- S 2 p - 7 — O C C' — D2
Date ) Z /6 — )Z /74 ,
Deptheet
(f)
Description
Class
Blow
Count
Recov.
Run/
Time
Sample
Desig.
PID (PM)
i
f
Remarks/
Water Levels
BZ BH S
/(
/(
7
-
i7-
1_
ill —
'
-
L 1 _
7 2—
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Z-)—
ZL _
-
b° _
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j6.,17 C14y, Cl4(k ♦tct.
(I, rR 3%6) N^c1,--.1
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1
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Nfi
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a 4"
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J=Zo,Cjo
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ill
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2.17
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IY nd C 14 4 ) dark
I (?,r y; /6)
II y
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R7=Rraatnina 7one
BH=Bore Hole
S=Sample

Drilling Log
Project Name
,1%Qgl-6 Z.—K
Project Number
TP-526 - y-0o`/-oZ
Boring Number
M 1/-- y
Ground Elevation
Location
/ w . ✓, - --;ti %e � If6,-+c/ (,:.l;
Page
/ D f z
Air Monitoring Equipment n�� /T
✓ / 6 C!
Total Footage 26 • O i
Drilling Type
Hole 51ze
Overburden Footage
Bedrock Footage
No. Of Samples
No. 0f Core Boxes
//SA-
s 7; -- 1 2‘ d
,'1/4-
/ Z
/VA
Drilling Company /fL d 4-d We // / r
Driler (s) / ,,r,
Drilling Rig /�;vzis; e Zoo
d A
Type of
Sampler J/);7 f Ja-(
Date / Z /3 /
To / Z /3 / J
Feld Observer (s) e-iol gisi,t,frat
Depth
(feet)
Description
Class
Blow
Count
Recov.
Run/
Time
Sample
Desig.
f ID (ppm)
Remarks/
Hater Levels
BZ
BH
S
--
1 _
-
2-
_
_
3-
-
4-
5-
-
6
7
_
8 _
9-
10—
11
12-
13-
-
14 -
Ai�ti41}
o934
LFC-= °%
02 = 2/.110
o
G
L.�
2 3..r
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a g,) y7.I
LPL = a /p 2p 9
02 = 2/.25,,
/ I
6/
� �
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0 34,'2
S/7
T.: zai.72,�
5/7
—'
-
_
-
-
-
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2
y
_
_
-
y
-
-
-
C/47_, f o4-1c. 1-7-4/7 ,fine;/a),[2
j L red (2.3_/iQ 5/j7)
wled; M ci-,1.1'�'-� C,,,%S Cy
-f'' e D /ti 171 c: rKf � Ale N
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CL
a
y
1.1
2
4k_Co
S5�l
i
2
/
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.S5/1 C l47/ /2 J (/0 �
y /
ii/6 W/ ,,f / eafehot
�u.r�f a d- ti �• S °
f,h,1-1 L 14-c% J , ate,/Jf
/o 6se_ mz��,.n J-1 i
( f;S)C7) A-11
i
1, -7
Z
0o1
7
is')
3
/.
55N
0,7,7 f44 . , reoC
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ref d ! 4 4 ^'j .., /5 , -,4 /h
•
Z
3
j
2
i
3.
-
i
1`>
j;,(L
2-
o9' Z
BZ=Breathing Zone
EH=Bore HWe
S=Sample

Drilling Log Continuation
Boring Number 4-7 (,,./ — L7/
Project Name /1%/6-2)L /C
Page Z of 2
Project Number yc- —�y L, — y— 2OY — 02
Date / Z /? / .
Depth
(feet)
it-/
Description
Class
Blow
Count
Recov.
Run/
Time
Sample
Desig.
PID (pptfl)
Remarks/
Water Levels -
BZ
BH
s
-
-,
-
=
lk-
-
c,
7D-
n ^
2_.
� —
-
z'y=
Z.f —
=
-
11—
_
-
—
_
-
—
-
C 147ri 1'4„I_, rl
(z. l Yi SQL) %acit 4--;-,Z
J �
J
ir, 1L4i 6+J Dn'rita
S`
Z
Z
iO. , 27.173,
•
-EL_ cs C; S I
70 o
620
Sig
�/ 1. Z?
LE��v� 3
2 °L2)
36
/
��'�
rip
�lZcf
i2 p
r
l
/$'l ' �
•
.yf:-_0,
r�IPi,t .� •
n
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s . -`3� I -
n^•'
ns,
o Ds_
'��,, c y I IIv
04 �f '1 -
:Ikk- f-ck
z
3
7
/?
6j3�
C/47, f4-I,L., �41�
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/voj � ,,4»t f4J'72pt 1't4;-1 •-,14/�
f.✓C C
L
2
/
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l
d e.n N•�
%/7 7.. ji p/q fOU; 4-'7/ 5.:,+ .11
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--2.
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crisp
j;_ IJ
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i
S
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ley
SS 1Z
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-r - : k_
•;�- s; ,�.•c
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try
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t
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C11-1-1=Inro IJnlo
C=Cmmnlo

Drilling Log
Project Name
,./o/Fo L 1<
Project Nunn er
? - 7Za - y- do=/- o Z
Boring Number
Ali✓-s
Ground Elevation
Location
ao;
Pape
71
Ak Monitoring Equipment /i v• EL �O�
Total Footage 2 T O
Drilling Type
Hole Size
Overburden Footage
Bedrock Footage
No. 0f Samples
No. 0f Core Boxes
S/4
s. r —
2s o
/1.44- I 4/
A/A- ,
Drilling Company e6,14.4 tv-C // 7///;
Driller n
ler (s) /Pey eL 1�0c,r•t O
Drilling Rig A� �trl; ke of / 1 Z vO
Sape of
pier �, T S ;,1
Date /Z /3 1
To /2 /? /7 G
Field Observer (s) ---rip.1./0 ! yS h d.--,
Depth
(feet)
Class
Blow
Count
Recov.
Run/
Sample
PID (Ppm)
Remarks/
Description
Time
Desig.
BZ
BH
S
Water Levels
-
1-
co•�crek
'r
I1y3
VI
LEL= L)/p
-
_
// j4,tzqq coed. C /4,7
dal k �j r4 .l O o �� '//i) ;,.%e,¢'
l
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02 = 2Q��%
-
-
2-
3-
_
5-
mei;,,, J. f.C•T� co„f;s,1
i!7'.,,,, /yn'':) ,k L o 1`-7 d 4 M O
7° °' S {' . . /
C.L
/, 3
-
-
-
-
6_
7-
i
/Zzo
rz.3
=
8-
72,
-
9 -
10—
C /47 c7 S4 ., Cep
(z.Y- Y� f/6) /oaft
.1.,HQ' Cj/4/L1Li 1^/Z'//
r% 2..
_ .
12-
/
Z
553
-
13-
14-
345
=

Drilling Log Continuation
DorIN Number / 1-V — S , 1
Project Name A/dieir--DL
Pape 2_ Of Z.
Project Number 9--- 5j 2 D — to _ d j _ O Z ,Date
/ 2 / g/ s 5
Depth
(fee)
j
Description
Class
Blow
Count
Recov.
Run/
Time
Sample
Deslg.
PID (ppm)
Remarks/
Water Levels J
BZ
BH
S
-
I <=
-
11-1
_11
-
-
-
-
2
SL
9,7 35.2 go/
L=0., 261
p` = Zo.>r5� y7o
ssd
L J 2
z
3
LA/'r✓d1J
Tit-6-'
Iv-4
ci IL /‘ -
Snlit � is.v1
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4
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ei/Or (2tY)' -/2)
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/
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v
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SEAL

Drilling Log
Protect Name ,
Nuber_Borng
. 7 C , ,/ c-
Number[Project
/a'/; 1 • -- ".,
Eround Elevation
Location
5..J. j1;Al;,-,t� —'k &.LSSt3.-+:/L ry N L
Papa ) �•;
I of .: .
Air Monitoring Equipment ,.- 7 1 - a
l j-r i. i r 2 :u-:e"
Total Footage ...., G ,y
L-6 .
Drilling Type I Hole Size I Overburden Footage
aedroc'c rootage I No. GI Samples I Mo. Of Cie Boxes
I
t `" =7 :"1 0: "t"-
• Ad t iAl I I `'y'
.Drilling Company - /V?C- G; ; r !.S fD ik3
Diller (s) •,') 1 k. e. . ;....1 j
Drilling Rig /' ? y 1 S
Type of • • 1 '
Sampler S A% i T C J,� 4 av1
Date v !
1 •
To ; 17 i 0.i
Paid Observer (s) ll;✓c /. 624 j fi o,-
Depth
• (feet)
Description
Class
Blow
Count
Recov.
Run/
Time
Sample
Desig.
. PID (ppm)
Remarks/
Water Levels
BZ { 9H
S
_�
-
1*
2—
3—
5
6-
-
7-
$—
_
11—
12—
13-
14 -
(s la .:-, -
.,. 4614
=r. n
6`1,i-4
1)1')
" 0 0
i. /4.n o
S
o
0
t U
0
,n
bel
01= 0
(7
0
2)
c 0
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=
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J
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-
C L
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✓ d y 14a �` S.S•r C•8iJ';.S4 -- 6�
vrii 15 ' 1 r
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o
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�„g-
mid-1,
5S-1
v r;�
}yn.ry (7 47, fl. _ (10R 7/ )
LA pi ftJ Jr,st1 .rd! _' (o( tiL)
5Ji'4J,s.�l too„tIAikC_ S'e�f-h-
C61C;s,.tc7 . s)I�a 5\f—
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S -' ti H , i1t.ap/ sJ . S3V`AI-
iI
1-610—
1 Ni 5
M W-4
I
BZ=Breathing Zone
BH=Bore Hole
S=Sample

Driiiing Log Continuation
Boring Number j�
Project Name Al ;) f;: sr. ;Pape of ��
iProject Number .4 -:, e` iJ i02te { r
a
1 Depth
(feet)
Desc;jpticn
t Cass
Blow
^'
Count
Recov.
Run/. +Sample)
Time ; GaslS.
I
°ID ippm).
1
j
Remark,./ t
1 Water leveis 1
BZ I EH I g-
i y
d
-
33
1
_
Ly_
_
• •
;„;i,
'
i'ld![cZ,-�
viS
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t'.,t c .
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S f 0
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=
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—
—
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rf' l
•
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�-
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t✓� -
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-
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-
-•
✓
(.:."
'Ir �
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31-
"16
pp
?-o.
r
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rt'a.-44, Li.72.+ -
1,t!e. ti =". _.
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,a.J ... �31 .-
u;:, 12 �45 -•
(sr: is L4) G
do v,d. aJd .A -
c.A
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34"'.6#110t4;k:
dt
i., � •5.s =
A�,
:� 7
,g,= :vt',;#t;z.ipS
c
. .
-
-
•
3:w
• j L. I -
_�.
--
_.
BZ=Breathing Zone
BH=Bore Hole
S=Sample
Waste
Consultants,
Inc.

Drilling Log
fProect Name Pro)ect Number .- -,-- • . Boring Number
,Ground EievatIon iLocatlon Page i
U. i.:
' ! 4 G i �. � ;=�,���4 is s� �j�r�'-�r%: ��1'7 A�; of �-
.Zlr Monitoring Equipment ins 2` 'r" 1 fL- / .1," ,— !Total Footage j
I
Drilling Type I Hole Size I Overburden Footage
Bedrock Footage No. Of Samples , • No. Of Core Boxes
j54,I ;?:25 •JIj .. J I J, 5
r
,fn j iL
Drilling Company A.,,,,e, (/ Y ,s °3 . 5
Driller (s) 14 ; /L.r 5 . si . /
Drilling Rig 11, ?' e `-
���
Type of . t
Sampler S.lJ/r•7' „WCOel
Date % 6 / I} / ITo ) /' /LI /
Field Obser-ver is) ' 7 ' a t'-7j q a
Depth
(feet)
Description •
Class
Blow
Count
Recov.
Run/
Time
Sample
Desig.
PID (ppm)
Remarks/ I
dater Levels
BZ BH S
_
-
2 _
_
3—
4-
-
0-
=
7-
-
9-
10 -
-
-
11-
-•U
12-
_
-
14 -
CL
/�f'r
in
r>�,0is
L�
L ryy
n -TO70
0
0
0 G C.
�, i
,
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J
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-
—
-
,
—
-
,
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—
-
-
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Si4hiC./4 fe61-00/� 7//)
;� O is
•
(64,15 ii f Cyr kr 0;i f
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�r
-
v f 4
.-
a
0
o
ej" 6
2
i
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s
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V
r
;`
V
, cL,by76
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31
J 4 n 6/1 e. f o.7,' ct (� iron �/b)
a.,i1t,;�d�[s�i tda,./ (Jai GL�C)
5'd i-i �,.a'n5 1'1 0 y. iC4A'C j 3 4 4"
C6r,>1 0.,,, r, u)sfi i/,4iL45
ni:1 c%,rg6C U"` ii6�
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Ski 4..4.•::..> rneii; u.-, /A c ;71y
.la4-T co, .s;S +oj, I,je.,-)'
-
-
-
BZ=Breathing Zone
BH=Bore Hole
S=Sample

Drilling Log Continuation
Boring Number f' €,^,} ---
Protect Name ✓,�;a S jPage of s
•
.Project Number ;� ti .' IBate ry
1 Depth
;)
(feet)
Description
Class
Blow
Count
Reoov-
Run!
a
Time
Sample
Desig-j
PiD (PPm)
Remarks.
��
1 Water Levels
I BZ 1 BN c
-f
_
-
1 _
_
I7
-
-
-
11,
_
- _
-
—
-
-
—
_
-
-
—
-
1 ::, I„ � . 91,, , +'Ft:' 616j^_ :;:,,,.�.. ,
,"„ d4.1-] • i �' i
�`
�1r":'1,
...
•. 0
-
eyo!
1'"D
,,;�
. 5''
' L' r
In ,
ii;�
•
a
-
j
)4A141
(?° .
6 met
r
u l-6.7n
v
•
n'i
Uti:.
y f
6 4`11 J 1 1` f 1 r y
:1/i) 1 at
�
1,: k:) 5 I'9 ;)-^S %n.ti;•.,;j.A
1 Li m 7
Stf2
zy�
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y ..; '
y
1. 5
l,mEe=:ii �,s
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�u�l'
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y,•�y--_=,-c;a.
jct. /id j)�C �;SE/-
cpri- O.1 - o 4- -
!E dil�� r! -
p k 1: ',^ '
si
i! ea.) y475.64--
01, .4d!!__J,.d-
✓`�'-•0N i.K- iinM1pS
1nq�+.tNEwf duce^
3-Ai -dui• -
�1S�r P fmi'�% -
4- .2SZ -
-
_/jam
1 ��
z7
!
C
"
-
_
-
-
y -
-
_
yt--
,�.
.—
.5i1! 73 3 citLei
BZ=Breathing Zone
BH=Bore Hole
S=Sample

Page. Fof2
// f S vs c Gr�uf'
' ttf t e Gh6 �.
Potential pollution source
Potential pollution source
COPY
Pat Y/'(t'r L%: nco (J L4:Id/✓
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Aquifer Protection Section
PRECONSTRUCTION INJECTION FACILITY INSPECTION
REPORT -FORM A
INJECTION WELL PERMIT NO. WI DATE
NAME OF OWNER Nor' / l Sot4erg'► ,1i1/14+ Cn
ADDRESS OF OWNER fj l 101 /^fran/ J4i Il d f St"; j Yox
I on h o l VA z 9-04Z — nO /3
)4751/ /t'1Y, For/ eS7- Sfe✓enson
(Street/ road or lot and subdivision, county, town)
Zp —O(f--
LOCATION OF PROPOSED INJECTION'�^,/WELLJ(and source fwell(s), if applicable)
/Ll®ri,fait ,lri9 �e/k /114 —� 6aA Ar t � , /h l^Oh�7 LU1/diYi/ lJit s: e.
o1• Gro v, B si 13 f�, S�r>°e✓
(Street/ road or lot and subdivision , county, town, if different than owner's address, plus description of location on site)
/t1po:7or,^), Lie/
Distance from well (' /'L w - z
Distance from well
Potential pollution source Distance from well
Minimum distance of proposed wellfrom property boundary
Quality of drainage at site a060/ Flooding potential of site 2d1-1/
(good,adequate,poor) (high,moderate,low)
DRAW SKETCH OF SITE
(Show property boundaries, buildings, wells, potential pollution sources, roads, approximate scale, and north arrow.)
/11q/5
CC: /t -/Ps f,hles
e.
GW/UIC-1 July 28, 2.004

Page 2 of 2
PRECONSTRUCTION INJECTION FACILITY
INSPECTION REPORT - FORM A (cont.)
GPS Data:
3S17/ Z' d'gl�17�10 7r
Latitude: D% `T� At
Longitude: a S� 2SS �/t/
COMMENTS J � e
RP
fr
o,100SS eo4,re D/ C soc
in?- �n /41„1//7z6r/no i/e A 7c e
i7 P Lt/c l�1BA/ °/H9 r/
v7 Y�L�AY e J/
/Urvr P 7 , ��� ✓Pr �1 F_ ‘-e-///Stoke d CO /fie► %—
re.v,gin Sn 7fie+7L / e 1i1S7
J/ Sec7�i, <a�(A 5� oT c0
Sqs / z'/c°Aie w P/15--;Ar. t e. Lncssiit
s
are lewQroattvrr��. 74 7i�2
INSPECTOR /311ic c r ArfAr `—
Office R.O
WITNESS
Address
WITNESS
Address
GW/UIC-1 July 28, 2004

Norfolk Southern UIC - Bessemer City
From USGS 1993 Bessemer City Topographic Map
til•l!
0 162.5 325 650 Feet

Norfolk Southern UIC -Bessemer City
From 1998 DOQQ
0 95 190 380 Feet

:MapQuest: Maps: print
El Send To Printer Back to Map
201 W Virginia Ave
Bessemer City NC
28016-2374 US -
Notes:
W91f9 4ve
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Map Legend
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NW-7
880.75
881
VIRGINIA
AVENUE
AUTO
MW-6
PENNSYLVANIA AVE 88"5
0
sa
1"=5Q .
NOTE The location and dimensions of features shown on this map have
been derived from various sources and supplemented by field
measurements. Though sufficient for its intended purpose, no
claim is made as to the degree of accuracy of this drawing.
LEGEND
M1 MONITORING WELL
880.05
GROUND WATER ELEVATION CONTOUR
(CONTOUR INTERVAL=1FOOT)
APPROXIMATE GROUND WATER
FLOW DIRECTION
NOTES:
1: GROUND WATER ELEVATION IN
FEET ABOVE MEAN SEA LEVEL
2: GROUND WATER ELEVATIONS
OBTAINED ON NOVEMBER 10, 2003
FIGURE 3
GROUND WATER CONTOUR MAP
NOVEMBER 2003
NORFOLK
SOUTHERN
201 W. VIRGINIA AVENUE
BESSEMER CITY, NC
DATE
JAN. 2004
SCALE.
1' = 50'
DESIGNED:
SB
DRAWN:
BFW
PfC�JB��
►►• ►►
NS1411.dwg

. • ••
4-
MW-7
ND
50
C4 --
AtZ STORM
VIRGINIA .
AVENUE,
AUTO
FIBER
RAILRO
BRIDGE
MW-6
PENNSYLVANIA AVE ND ,
0
50'
LEG -END
MONITORING WELL
ND NOT DETECTED
—1,000 — BENZENE ISOCONCENTRATION CONTOUR
• NOTES:
1: GROUND WATER SAMPLES COLLECTED
ON NOVEMBER 10, 2003
2: ALL RESULTS IN MICROGRAMS PER LITER (pg/L)
•
NOTE The location and dimensions of features shown on this map have . .
been derived from various sources and supplemented by field . • •
measurements. Though sufficient fof its intended purccee, no - 3: . NCDENR GROUND WATER STANDARD FOR BENZENE=1 ug/L
claim is made as to the degree of accuracy of this drawing • , - . ,
FIGURE 4
BENZENE:IN GROUND WATER
ISOCONCENTRATION MAP
NOVEMBER 2003- •
NOsornFOHleRN
•
201 W. VIRGINIA AVENUE
BESSEMER CITY, NC
DATE:
JAN. 2004
SCALE
1"
= 50'
DESIGNE):-
S8
DRAWN:-
BFW
Pmpared by:
i:iJ
NS1411.thira

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
September 24, 2004
Mr. Forrest Stevenson
Norfolk Southern Railway Company
110 Franklin Road, SE, Box 13
Roanoke, VA 24042-0013
REC•EIVF[)zz
3EP 2 9 2004`
NO DE r"1151Wit:MdiENT
r�
AND NATURAL klt:..-Oct �. l.
M'OORE:S Y ll-S:le REGIONAL OFF CE
Subject: Type 5I Injection Well Permit Application
Virginia Avenue Auto & Wrecker Site, Bessemer City, NC
Dear Mr. Stevenson:
Norfolk Southern Railway Company's application for a permit to use wells for the injection of
ORC® at the subject site is currently under review. Applications for injection must adhere to the
North Carolina Administrative Code (NCAC), Title 15A, Subchapter 2C. In this regard, we have
found your application incomplete. In order for our staff to complete their review of your permit
application, please address the following issues:
1. Submit a revised monitoring procedure that includes a monitor well array
downgradient from the injection locations in accordance with 15A NCAC 2C
.0213(c)(2)(D). Injection wells (e.g. MW-2, MW-4) should not be used as
monitor wells. 15A NCAC 2C .0213(c)(2)(D) requires that monitoring wells
shall be located in such a fashion as to detect any movement of injection
fluids, process by-products, or formation fluids outside the injection area or
zone.
2. Submit a site map including all property boundaries, contour intervals not
exceeding two feet, and the horizontal and vertical extent of the contaminant
plume (including plume cross sections), in accordance with 15A NCAC 2C
.0211(d)(1)(D) and (d)(3)(B).
3. Submit a cross section of the subsurface to a depth that includes the known or
projected depth of contamination, as required by 15A NCAC 2C
.0211(d)(3)(D).
4. Submit plans for the proposed location and construction details of the
groundwater monitoring well network, in accordance with 15A NCAC 2C
.0211(d)(3)(G).
Aquifer Protection Section
Internet: http://h2o.enr.state.nc.us
f r Caro ina
,Naturally
1636 Mail Service Center Raleigh, NC 27699-1636 Phone [phone] Customer Service
2728 Capital Boulevard Raleigh, NC 27604 Fax [phone]
Fax [phone]
An Equal Opportunity/Affirmative Action Employer — 50% Recycled/10% Post Consumer Paper

Mr. Forrest Stevenson
September 24, 2004
Page 2
You are requested to submit this additional information within 30 days of receipt of this letter,
otherwise your application will be returned. If you have any questions regarding this letter or
your permit application, please contact Michael Ranck at [phone].
Sincerely,
E a .
Debra J. Watts
Supervisor
Groundwater Protection Unit
cc: Suzanne Bailey, Marshall Miller & Associates
TAPS -Mooresville Region-alO ffice_UIC)
UIC Central Office File

DIVISION OF WATER QUALITY
AQUIFER PROTECTION SECTION
August 26, 2004
MEMORANDUM
_ _ Aridrew Pitney, Aquifer Protection Supervisor
Aquifer Protection Section
Mooresville Regional Office
From: Mike Ranck
Central Office
NC DEPT. OF ENVIRONMENT
AND NATURAL RESOURCES
RECEIVED
-AUG 3 I= 2004-
IOORESVILLE'REGIONAL OFFICE
DWQ-GROUNDWATER SECTION
Re: Request for review of an injection well application, type 5I injection well (groundwater
remediation), submitted by Norfolk Southern Railway Company, to construct and use
injection wells for injection of ORC® socks to remediate dissolved petroleum
hydrocarbons at their site in Bessemer City, North Carolina.
1. Please review the application and submit any comments to CO-UIC group. Retain the
application for your UIC file.
2. Please inspect the injection well site to verify that the location and construction plans
submitted in the application are accurate and that the NCAC Title 15A 2C.0200 standards
are being complied with, using the enclosed Preconstruction Injection Facility Inspection
Report (Form A) as appropriate.
You are requested to return The Review Comments and the completed Preconstruction
Injection Facility Inspection Report (Form A) to the CO-UIC by September 27, 2004. If the
inspection and review cannot be accomplished by this date, please let me know.
The UIC group appreciates your assistance with this review. If you have any questions regarding
this review or the UIC program, please contact me at [phone].
cc: CO-UIC Files
Enclosures

oc.WA T9 Michael F. Easley, Governor
Q William G. Ross Jr., Secretary
\O. QG North Carolina Department of Environment and Natural Resources
Cq r Alan W. Klimek, P. E. Director
j —i Division of Water Quality
0 Coleen H. Sullins, Deputy Director
Division of Water Quality
August 26, 2004
Mr. Forrest Stevenson
Norfolk Southern Railway Company
110 Franklin Road, SE, Box 13
Roanoke, VA 24042-0013
Subject: Type 5I injection well permit application
Virginia Avenue Auto & Wrecker Site, Bessemer City, NC
Dear Mr. Stevenson:
Norfolk Southern Railway Company's application for a permit to construct and use wells for
injection of ORC® socks at.the subject site in Bessemer City, North Carolina has been received
and is currently under review. A member of the Groundwater 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,
/ laud .//6"eit
J. Michael Ranck
Hydrogeologist
Groundwater Protection Unit
cc: Andr ew Pitner,:Mooresville-R egional"Office'
CO-UIC files
Suzanne Bailey, Marshall Miller & Associates
N. C. Division of Water Quality / Aquifer Protection Section
1636 Mail Service Center Raleigh, N.C. 27699-1636
Phone: [phone] Fax: [phone] Internet: http://gw.ehnr.state.nc.us
Customer Service
1-877-623-6748

Norfolk Southern File No. 1-9-NC-BSMR-UT98.133-002
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 with
the approved specifications and conditions of the Permit."
90sitabl W
Forrest W. Stevenson
Engineer Environmental Remediation
Norfolk Southern Railway Company
(Signature of Well Owner or Authorized Agent)

APPLICATION FOR PERMIT TO CONSTRUCT AND/OR USE A WELL(S) FOR
INJECTION, Class 5I Wells
This permit application was generated in accordance with the provisions of NCAC Title 15A:
02C.0200. The following sections provide a detailed description of all planned activities
relating to the proposed placement of Regenesis brand Oxygen Release Compound® (ORC®)
socks into two existing monitoring wells to aid with biodegradation of petroleum hydrocarbons.
kt
illA. PERMIT APPLICANT /'V\ Y rS
Norfolk Southern Railway Company C
�'. ��°��
110 Franklin Road, SE, Box 13 �`��7 1
'1A
Roanoke, Virginia 24042-0013
Contact: Mr. Forrest W. Stevenson, Engineer Environmental Remediation da'�S �e r6d4
Contact Phone: [phone]-
/4V,1 rygle
B. PROPERTY OWNER
Norfolk Southern Railway Company
110 Franklin Road, S.E., Box 13
Roanoke, Virginia 24042-0013
Contact: Mr. Forrest W. Stevenson, Engineer Environmental Remediation
Contact Phone: [phone]
C. STATUS OF APPLICANT
yi A Ics • vim
r
1U.r ;2$ ii-elgi
zp, W.
Norfolk Southern Railway Company (NSRC) is a private transportation organization.
D. FACILITY (SITE) DATA
Virginia Avenue Auto & Wrecker
201 W. Virginia Ave.
Bessemer City, North Carolina
►►' ' ,, •4

Norfolk Southern Railway Company
Injection Well Permit for ORC® Remediation
8/24/2004
Page 2 of 12
Gaston, County
Contact: Mr. Forrest W. Stevenson (NSRC)
The Site location is shown on an excerpt from the United States Geological Survey (USGS) 7.5-
minute series Bessemer City topographic quadrangle (Figure 1).
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;
2. operation procedures; and
3. a planned injection schedule
The proposed underground injection consists of installing Regenesis brand ORC socks in
existing monitoring wells MW-2 and MW-4 and conducting semi-annual ground water
monitoring for two years. MW-2 and MW-4 were selected for treatment because of the
presence of gasoline range petroleum hydrocarbons in ground water at concentrations that
exceed the North Carolina ground water standards. ORC® socks contain a proprietary solid
form of magnesium peroxide that, when placed in a well, react with the ground water to promote
the timed release of molecular oxygen to the aquifer. The release of additional molecular
oxygen aids the aerobic degradation of dissolved petroleum hydrocarbons in ground water.
Once the ORC® socks are installed, they must remain undisturbed in the wells for at least six
months to promote affective treatment. A copy of ORC® information and installation
procedures is provided as Appendix A.
The ORC® sock installation could occur during the next semi-annual sampling event (currently
scheduled for November 2004). During the May 2005 sampling event, the ORC® socks would
be removed, the wells sampled, and new ORC® socks would be placed in the wells. In total,
three sets of ORC® socks will be installed over the two-year semi-annual sampling schedule. At
the end of the two year monitoring schedule, future actions for the Site will be evaluated.

Norfolk Southern Railway Company
Injection Well Permit for ORC® Remediation
8/24/2004
Page 3 of 12
According to Mr. Brad Newton of the North Carolina Department of Environment and Natural
Resource (NCDENR), if benzene levels can be brought below the NCAC 15A 2L GCL
standards (5000 µg/L) in ground water, the Site may be considered for closure.
F. DESCRIPTION OF SITE
The Site has been assigned Pollution Incident No. 19216 by NCDENR. Five gasoline
underground storage tanks (USTs) and one kerosene UST were located at the Site, but were
removed in September 1998 and January 1999 by Earth Tech, Inc. (Earth Tech). Earth Tech
removed approximately 277 tons of petroleum hydrocarbon impacted soil associated with the
USTs. The excavation pits were backfilled with clean material. Between 1999 and 2001, seven
monitoring wells were installed to evaluate ground water impacts. The ground water typically
flows to the southwest (Figure 3). Volatile organic compounds (VOCs) present in the ground
water include benzene, toluene, ethylbenzene, total xylenes (BTEX), and naphthalene.
Currently, benzene is the most prevalent. Figure 4 shows the benzene isoconcentration
contours at the Site. A Comprehensive Site Assessment (CSA) was completed by Burns &
McDonnell Consultants, Inc. (Burns & McDonnell) and submitted in May 2000. A Corrective
Action Plan (CAP), completed by Burns & McDonnell, was submitted in October 2000, which
recommended monitored natural attenuation as the most cost effective treatment option. Prior
to approving the CAP, NCDENR requested the installation of two monitoring wells (MW-6 and
MW-7) south of the railroad trestle down gradient from the Site, to further evaluate the extent of
impacted ground water. Burns & McDonnell installed two monitoring wells (MW-6 and MW-
7) in January 2001, and submitted a summary report to NCDENR in June 2001. Based on the
results from the newly installed monitoring wells, NCDENR approved the CAP in a letter dated
July 17, 2001. In November 2002, NSRC contracted MM&A to continue semi-annual ground
water monitoring at the Site, in accordance with the approved CAP. As part of the previous
CAP submittals, periodic ground water monitoring events have been conducted, with the most
recent sampling event occurring on November 10, 2003.
3 ►► ►
��; SOCI. ES

Norfolk Southern Railway Company
Injection Well Permit for ORC® Remediation
8/24/2004
Page 4 of 12
G. HYDROGEOLOGIC DESCRIPTION
The following section was prepared in accordance with G.S. 89E-13 and has been approved by a
licensed `��pd� �.
'� %bii
0
�iraeaaaa��►�
Suzanne E. Bailey, L.G. 1778
1. REGIONAL GEOLOGIC SETTING
The Site is at an elevation of approximately 894 feet above mean sea level (MSL) and is located
in the southern portion of the Kings Mountain Belt Physiographic Province of North Carolina.
According to the geologic map of North Carolina (North Carolina Geological Survey, 1985), the
uppermost bedrock in the Site vicinity is the Battleground Formation, which contains quartz-
sericite schist with metavolcanic rock, quartz -pebble metaconglomerate, kyanite-sillimanite
quartzite, and garnet -quartz rock. Bedrock has not been encountered in soil borings at the Site.
2. SIGNIFICANT CHANGES IN LITHOLOGY
Subsurface materials encountered in soil borings and excavations at the Site consist of fill, clay,
and clayey sand. Fill material (subgrade composed of clay, sand, and gravel) is prevalent across
the Site to a depth of approximately two feet below grade (bg) beneath the asphalt cover. This
fill is underlain by approximately 10 feet of native soil composed of low plasticity clay with
some sand. Fill material (primarily clay with some sand) is also present within the former UST
excavation to an average depth of 10 feet bg. Native soil consisting of low plasticity clay is
present beneath the UST excavation to a depth of 25 feet according to the boring log for MW-2.
Clayey sand, observed between approximately 10 and 20 feet bg, is the principle water bearing
4
►' ►v
��; SOCI. ES

Norfolk Southern Railway Company
Injection Well Permit for ORC® Remediation
8/24/2004
Page 5 of 12
unit at the Site and is underlain by at least five feet of clay according to boring logs for MW-4
and MW-5.
3. HYDRAULIC CONDUCTIVITY
The CSA reports an average hydraulic conductivity of 3.77 x 10-2 ft/day or 1.33 x 10 -5 cm/sec
based on the results of slug tests performed in wells MW-4 and MW-5. This value is consistent
with typical hydraulic conductivity values for sandy clay and clayey sand.
4. DEPTH TO MEAN SEASONAL HIGH WATER TABLE
Based on historical data, the mean seasonal high water table is typically 10 feet bg.
5. TRANSMISSIVITY/SPECIFIC YIELD
Using data from the CSA Report, the transmissivity (T) across the zone of proposed ORC®
installation at the Site was calculated using the average hydraulic conductivity value (K=3.77 x
10-2 ft/day) and the thickness of the saturated zone that will be treated (b=15 ft, based on the
screened interval in MW-2 and MW-4 from 10 ft bg to 25 ft bg). Therefore, the transmissivity
is T=bK, or approximately 0.5655 ft2/day. The specific yield of the saturated zone cannot be
determined from available Site data, but can be inferred based on the subsurface materials
observed in soil borings. According to Fetter (1994), clay and sandy clay have a specific yield
averaging 2%, but this value can range from 0 to 5%.
H. MONITORING PROCEDURE
A monitoring well network already exists at the Site as shown on Figure 2. Ground water
monitoring has included quarterly and semi-annual sampling from seven shallow wells for
VOCs (USEPA Method 8260) and polynuclear aromatic hydrocarbons (PAHs, USEPA Method
8270). Two years of semi-annual ground water monitoring is proposed during ORC® treatment.
The first of four semi-annual ground water monitoring events will be performed in November
2004 before installing the ORC® socks. ORC® socks will be installed in monitoring wells MW-
5
��; SOCI. ES

Norfolk Southern Railway Company
Injection Well Permit for ORC® Remediation
8/24/2004
Page 6 of 12
2 and MW-4 immediately following ground water sampling in November 2004. Three
additional semi-annual ground water monitoring events will be performed in May 2005,
November 2005 and May 2006. The ORC® socks will then be replaced in May 2005 and again
in November 2005. Ground water samples will be analyzed for VOCs, including isopropyl
ether (IPE), methyl tertiary butyl ether (MTBE), and ethylene dibromide (EDB) using USEPA
Method 8260; and PAHs using USEPA Method 8270. Field parameters monitored for will
include: pH, water temperature, specific conductivity, and dissolved oxygen.
Well construction diagrams on the respective boring logs for MW-2 and MW-4 are provided in
Appendix B.
I. WELL USE
Monitoring wells MW-2 and MW-4 are proposed to undergo treatment with ORC® socks.
These and all other Site wells are monitoring wells designed to allow access for ground water
sampling to monitor the natural attenuation of dissolved gasoline constituents in ground water.
None of the Site monitoring wells is used for potable water. Monitoring wells MW-2 and MW-
4 will have three sets of ORC® socks installed at six-month intervals over the two-year
monitoring and treatment period. Ground water samples will also be collected from all Site
monitoring wells on a semi-annual schedule for two years.
J. CONSTRUCTION DATA
Both MW-2 and MW-4 have a total depth of 25 feet bg and are constructed with two-inch
diameter schedule 40 PVC. Each well has 15 feet of 0.01-inch slotted screen and 10 feet of PVC
riser. Number 2 filter pack sand was installed through the augers to at least two feet above the
top of the screen. Each well has at least two feet of seal above the screen composed of hydrated
bentonite chips. Both wells were completed with cement to ground surface and finished with
flush mount well covers and vaults. Well construction information for MW-2 and MW-4 are
provided on the last page of the boring logs in Appendix B.
6 ►®' ' ►►
��; SOCI. ES

Norfolk Southern Railway Company
Injection Well Permit for ORC® Remediation
8/24/2004
Page 7 of 12
K. OTHER WELL DATA
The CSA Report indicates that the Bessemer City has a city ordinance requiring all residences
and businesses within the city limits to use the municipal water supply. The Site and
surrounding area within 1/4 mile are all within the city limits. The CSA Report indicates that no
private water wells exist within 1,500 feet of the Site and that all residences and businesses
within this radius use the municipal water supply. Bessemer City obtains its municipal water
supply from two reservoirs, Webber Lake and Arrowood Lake. Public water is available at the
Site from water lines along W. Virginia Avenue and 13th Street.
L. PROPOSED OPERATING DATA
1. INJECTION RATE:
Each ORC"' sock releases molecular oxygen at an estimated rate of 0.2 grams per day. Each
monitoring well will have 15 ORC® socks installed at a time. Therefore, the estimated rate of
molecular oxygen release per well is 3 grams per day, assuming a constant rate of release.
2. INJECTION VOLUME:
Given the rate of molecular oxygen release of 3 grams/day per well, the volume of oxygen
released from the ORC® socks over six months is estimated to be 540 grams per well or a total
of 1080 grams. Three six-month treatment periods with ORC® socks would release an estimated
3240 grams of molecular oxygen.
3. INJECTION PRESSURE:
The oxygen will be released passively from the ORC® socks under ambient pressure.
4. INJECTION TEMPERATURE:
The oxygen will be released from the ORC® at the ambient air temperature.

Norfolk Southern Railway Company
Injection Well Permit for ORC® Remediation
8/24/2004
Page 8 of 12
S. HYDRAULIC CAPACITY OF THE WELL
Because oxygen will be released passively, versus injected under pressure, the hydraulic
capacity of the wells is not of concern.
6. EXPECTED LIFETIME OF THE INJECTION FACILITY
Existing monitoring wells are expected to be viable for an estimated 10 years or more.
7. DESCRIPTION OF MEASUREMENTS/CONTROLS
The rate of oxygen released to the aquifer is an estimate. Actual rates of the oxygen release will
vary depending on the geochemical and biological conditions of the aquifer. ORC® socks are
typically depleted six months after installation in water.
M. INJECTION RELATED EQUIPMENT
The program consists of installing ORCsocks within existing monitoring wells. Equipment
consists of ORC® socks and polypropylene rope. A diagram showing the configuration of a
typical ORC® sock installation is included in Appendix A.
N. LOCATION OF WELL(S)
A Site vicinity map is shown in Figure 1 and includes topographic contours. The proposed
ORC® sock installation points are monitoring wells shown on Figure 2 along with the required
elements described in section N of the permit. All monitoring wells are located on Norfolk
Southern Railway Company property.
O. INJECTION FLUID DATA
1. FLUID SOURCE
No fluids will be injected into the subsurface.
8
=M. SOCI. ES

Norfolk Southern Railway Company
Injection Well Permit for ORC® Remediation
8/24/2004
Page 9 of 12
2. CHEMICAL, PHYSICAL, BIOLOGICAL, AND RADIOLOGICAL
CHARACTERISTICS OF INJECTION FLUID.
No fluid will be injected; however, the characteristics of ORC®, the proposed injection material
provided by the manufacturer, are included in Appendix A.
P. PERMIT LIST
No additional permits or construction approvals are known to be required outside of this permit.
Q. REFERENCES
Fetter, C. W., Applied Hydrogeology, 3rd Edition. (New York: Macmillan College Publishing
Company, Inc., 1994).
9
\► nF LL\\
SOCI. ES

FIGURES
SOLI. ES

Prepared by:
\\M \\
SOCI ES
NS1411
01/06/04
jugNORFOLK
SOUTHERN
USGS 7.5' BESSEMER CITY, NC QUADRANGLE -1973
CONTOUR INTERVAL = 20'
201 W. VIRGINIA AVENUE
BESSEMER CITY, NORTH CAROLINA
2,000' 0 2,00a
SCALE 1:24,000
FIGURE 1
VICINITY MAP
NORTH CAROLINA
QUADRANGLE LOCATION

MW-7
880.75
50'
881
"RG/Nlq A
tz
VIRGINIA
AVENUE
AUTO
FIBER OPT1C CABLE
RAILROAD
BRIDGE
882
•
MW-6
PENNSYLVANIA AVE 880.05
0
883
50'
1"=50'
NOTE: The location and dimensions of features shown on this map have
been derived from various sources and supplemented by field
measurements. Though sufficient for its intended purpose, no
claim is made as to the degree of accuracy of this drawing.
FIGURE 3
GROUND WATER CONTOUR MAP
NOVEMBER 2003
MW-1
2tgl3 3r,
885.28
805
8
STORM
��SEMcR
MWi
880.05
5
3
LEGEND
MONITORING WELL
GROUND WATER ELEVATION CONTOUR
(CONTOUR INTERVAL=1FOOT)
APPROXIMATE GROUND WATER
FLOW DIRECTION
NOTES:
1: GROUND WATER ELEVATION IN
FEET ABOVE MEAN SEA LEVEL
2: GROUND WATER ELEVATIONS
OBTAINED ON NOVEMBER 10, 2003
NORF©PK
SOUTHERN
201 W. VIRGINIA AVENUE
BESSEMER CITY, NC
DATE:
JAN. 2004
SCALE:
1" = 50'
DESIGNED:
SB
DRAWN:
BFW

MW-7
ND
50'
V/RC1NlA Atr STORM
VIRGINIA
AVENUE
AUTO
FIBER OPTIC CABLE
RAILROAD
BRIDGE
•
MW-6
PENNSYLVANIA AVE ND
0
sa
1"=50.
NOTE The location and dimensions of features shown on this map have
been derived from various sources and supplemented by field
measurements. Though sufficient for its intended purpose, no
claim is made as to the degree of accuracy of this drawing.
FIGURE 4
BENZENE IN GROUND WATER
ISOCONCENTRATION MAP
NOVEMBER 2003
MW-1
3
LEGEND
MONITORING WELL
ND NOT DETECTED
- BENZENE ISOCONCENTRATION CONTOUR
NOTES:
1: GROUND WATER SAMPLES COLLECTED
ON NOVEMBER 10, 2003
2: ALL RESULTS IN MICROGRAMS PER LITER (Ng/L)
3: NCDENR GROUND WATER STANDARD FOR BENZENE=1 ug/L
NOREOEK
SOUTHERN
201 W. VIRGINIA AVENUE
BESSEMER CRY, NC
DATE:
JAN.2004
SCALE:
1" = 50'
DESIGNED:
SB
DRAWN:
BFW

MW-7
Q•••••::
VIRGIN
AVENUE
AUTO
STORM
��SEWER
MW-1
IA40-
FIBER OPTIC ,CABLE
PENNSYLVANIA AVE.
RAILROAD
BRIDGE
MW-6
50' 0 50'
1" = 50
NOTE The location and dimensions of features shown on this map have
been derived from various sources and supplemented by field
measurements. Though sufficient for its intended purpose, no
claim is made as to the degree of accuracy of this drawing.
MW
5
*PAW 3
MW-2
,MW-4
MW1
LEGEND
MONITORING WELL
FIGURE 2
SITE MAP
•
NORFOLK
SOUTHERN
201 W. VIRGINIA AVENUE
BESSEMER CITY, NC
DATE:
JAN. 2004
SCALE:
1"
= 50'
DESIGNED:
SB
DRAWN:
BFW
„I RJI'II LL„
INEMINCEN
NS1411.dwg

APPENDIX A
REGENESIS, OXYGEN RELEASE COMPOUND (ORC®) INFORMATION
SOCI. ES

- Products - ORC® - Overview
http://www.regenesis.com/products/orc/
Leaders in Accelerated Natural Attenuation •
Search I Contact Us I Ordor
REGENESIS , 6
Product
PRODUCTS
OVERVIEW
SOLUTIONS Ii RESOURGEBi a' ABOUT US i ?WORLDWIDE;,
ORC is a proprietary formulation of phosphate -intercalated magnesium peroxide that time releases
oxygen when hydrated.
Purpose
To supply oxygen to accelerate the rate of naturally occurring aerobic contaminant biodegradation in groundwater and saturated
soils.
Functionality
ORC is typically applied using direct -injection techniques. This process requires ORC to be mixed with water to form an injectable
slurry which is then pressure injected (using a pump), into the zone of contamination. Once in the aquifer, ORC particles will sorb to
or reside in the soil matrix and slowly release oxygen for periods of up to 1 year. ORC is also available in 2", 4" and 6" filter socks
that can be emplaced in wells and removed when exhausted. Upon removal the old socks can be replaced with new ones to
rejuvenate the oxygen supply and maintain aerobic biodegradation as needed.
Product Specifications
• A powdery material less than 10 microns in diameter
• Composition - Magnesium Peroxide (Mg02)
• Non -hazardous, food grade product
• Intercalated design allows for slow -release of oxygen without "lock -up"
• Releases 10% of its weight as oxygen when hydrated
• Packaged and delivered in 30 Ib. PVC buckets
By -Products
• "Milk of magnesia" or Mg(OH)2 a common antacid formula
Field Applications
• Straight powder application in excavations
• ORC and water mixture (slurry) application in excavations
• Replaceable filter socks for single well and barrier applications
• Directly -injectable slurry (most common) for source area and permeable reactive barrier applications
Benefits of Use
• Slow -release of molecular oxygen to support aerobic microbial activity
• Long-term source of oxygen to the subsurface (up to 12 months)
• Clean, low-cost, non -disruptive application (direct -push or socks)
• Direct Injection not limited by presence of surface structures
• No Operations and Maintenance
• Faster and often lower cost than drawn out natural attenuation approaches
• Complimentary product application design and site analysis from Regenesis
Application Considerations
• Contaminant mass
• Groundwater Flow Rates
• Distribution of oxygen in the aquifer
• Longevity
(C)2004 Regenesis, All Rights Reserved
re,
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Brochures:
o ORC Brochure (PDF)

- Products - ORC® - How It Works
http://www.regenesis.com/products/orc/howitworks.aspx
Leaders In Accelerated Natural Attenuation
REGENESIS PRODUCTSt,I soLUTlo
How it Works?
RESOURCES _l._, ABOUT,_
Soarch I Contact Us I Order
oftirDWA'pElq
HOW IT WORKS
Oxygen is often the limiting factor for aerobic microbes capable of biologically degrading contaminants such as petroleum
hydrocarbons. Without adequate oxygen, contaminant degradation will either cease or may proceed by much slower anaerobic
(oxygen -free) processes. ORC is designed to release oxygen, into the subsurface, for up to one year depending on site conditions.
In the presence of this long-lasting oxygen source, aerobic microbes flourish accelerating natural attenuation of gasoline and fuel
additives (BTEX and MTBE), diesel, kerosene, jet fuel, gas condensates, fuel oils, lubricants, bunker oil, PAHs, certain metals
(arsenic), certain pesticides/herbicides and certain industrial solvents (alcohols and ketones).
Critical Timed Release
ORC is intercalated with food -grade phosphate, this gives it the time -release properties that are critical in a passive, low-cost
oxygen application system. The term "intercalation" is used here to describe the permeation of phosphates into the crystalline
structure of magnesium peroxide (Fiqure 1). This feature slows the reaction that yields oxygen thus facilitating the extended
release. Phosphate intercalation also prevents a process known as "oxygen lock -up." When water reacts with an un-intercalated
magnesium peroxide, a cement -like coating of magnesium hydroxide forms which prevents water from penetrating deeper into the
crystal to release all of the available oxygen. ORC's phosphate intercalation keeps the crystal "open," preventing this problem and
continuing the release of oxygen.
Figure 1:
ORC Intercalation
O nd C r
PHOSPHATE GROUP
" ("intercalates" and
Disrupts Crystal Array)
ORC
CRYSTAL
OXYGEN co
(9Q
Figure 1 (Click to Enlarge)
Product Applications
ORC is typically applied in the subsurface via direct push injection, borehole backfill or filter
socks. When using direct push and/or borehole backfill, ORC powder is mixed with water to form
an injectable slurry. The slurry is then pumped into the groundwater where it disperses into the
aquifer via diffusive and advective forces. In filter sock form, ORC is placed into monitoring wells
where the compound reacts when contacted with water. Upon exhaustion, which can take up to
1 year, filter socks can be removed and replaced to replenish the oxygen supply and continue ,
treatment. Special canisters are available with filter socks to avoid lodging them in deeper wells
(> 40 ft.). Additionally ORC can be applied into excavated areas either in its native powder form
or by broadcasting the slurry mixture. Excavation treatments take advantage of fluctuating
groundwater levels and percolation from the surface to activate the oxygen releasing capabilities
of ORC.
(C)2004 Regenesis, All Rights Reserved
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Expert Answer Your
Questions
SITE EVALUATION
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Evaluation of the
Use of ORC, HRC
or HRC-X at Your
Site
Brochures:
❑ ORC Brochure (PDF)

ei?
REGENESIS
Oxygen Release Compound (ORC®)
Installation Instructions
(Replaceable Filter -Sock Application)
ORC Filter Socks are used to enhance bioremediation of petroleum hydrocarbons in
groundwater. The filter sock contains ORC and an inert carrier matrix. The socks
come in one foot sections. They are laced together to span the vertical polluted
saturated zone in monitoring type wells. Once the socks are laced together and
lowered into the wells, they become hydrated and begin releasing oxygen. The
following instructions are vital to proper installation and subsequent removal of the
socks.
SAFETY PRECAUTIONS:
• ORC is completely non -toxic, but is composed of ultra -fine particles.
• Wear dust masks and goggles to prevent soft tissue irritation
• Reference the Material Safety Data Sheet for specific technical and physical
information.
CONDITION OF SOURCE WELL:
• Test for well deviation and smoothness before ORC installation.
• For the test, use a 5 foot section of pipe with an outside diameter 1/2 inch
smaller than the source well's inside diameter.
KEY REQUIREMENTS FOR INSTALLATION:
• SOCKS MUST BE INSTALLED WITH BLACK GROMMETS ON TOP
• Wrap Socks as independent units (see page 3, figure 5)
• A maximum of 20 ea. 2-inch socks per section.
• A maximum of 8 ea. 4-inch socks per section.
• A maximum of 6 ea. 6-inch socks per section.
• Make sure each sock is properly shaped (cylindrical and without bends) to
facilitate ease of installation and removal.
HELPFUL HINTS:
• ORC matrix hardens into a cement once hydrated
• Minimize slack between each sock, by periodically pulling up slack while lacing
• Tie off ORC retrieval lines to the well cap. Regenesis recommends the use of a
3/8" diameter x 6" long eyebolt.
1

• The ORC Socks should be wetted to prevent excessive dusting prior to
installation
• Make sure your work area is clean to avoid oil and dirt deposits on the socks.
FILTER -SOCK REMOVAL:
• ORC Socks will be approximately 20% heavier after water saturation
• Static friction from screened casing may cause difficulty in removal
• A winch and stanchion (or comparable equipment) may be necessary to help
remove the socks due to increased weight, friction, etc.
LACING DIAGRAMS FOR SOCK INSTALLATION:
4 INCH AND 6 INCH SOCK LACING DIAGRAM:
WHITE
GROMMETS
CENTER
OF ROPE
BLACK
GROMMETS
BLACK
GROMMETS
-441:1111iN N.
r ..i%4III.II
WHITE 4 � , �::04SI:
4,A.A i es• III N
GROMMETS ""�'•••'"
E i�III •II//I/I��N
..IIII i
:/
WHITE
GROMMETS
CENTER
OF ROPE
BLACK
GROMMET:
1. Find the center of the rope. Begin
lacing the ORC Socks by threading
the two ends of the installation rope
through the black grommets and
then through the white grommets at
the bottom of the same side of the
bottom sock
2. Pull the rope through the bottom
sock, making sure the center of the
rope is between the black
grommets. Cross the ropes over
each other.
3. Loop the ends of the rope around
the back of the sock and cross
them. Repeat this step once again,
so the rope is wrapped around the
sock with two full turns.
2

WHITE BLACK
GROMMETS GROMMETS
1 1
FRONT VIEW
BACK VIEW
WHITE
GROMMETS y
WHITE
GROMMETS
BLACK
GROMMETS
4. Bring the ends of the rope around
from the back, cross them, and
thread them into the black
grommets. The rope ends should
be inserted into the black grommets
diagonally from the white ones they
started from. Threading the black
grommets will be tight only on the
bottom sock due to the unique
lacing pattern.
5. To avoid the ORC Sock slipping
past each other, the socks must be
laced with the grommet flaps of the
bottom sock and second sock
butting against each other (as
shown)
6. The remaining socks on the rope
section are laced up according to
Figure 6. Make sure that the rope
is turned around the sock two full
turns, with the grommets of each
sock butting up against the next
sock as shown in Figure 5.
7. Lace each subsequent ORC
Sock exactly the same as in
Figure 5 and 6.
IMPORTANT: Do not exceed the
maximum number of socks per section
(see "Key Requirements D & E" on
page 1).
Minimize the slack between the socks
3

TOP SE CIION
TIE KNOT-^ `�*-
OOTTOJA SECTION
CENTER
OF ROPE
WHITE
GROMMET
8. If you need to install more ORC
Socks than the maximum
allowed per well size (see "Key
Requirements D & E on page
1), then multiple sections must
be installed. Each section is
laced exactly the same, but
they should be tied off to each
other. Tie the end of the rope
from the lower section to the
bottom sock of the upper
section; this allows each
section to be installed and
removed independently (see
well diagram)
2 INCH SOCK LACING DIAGRAM:
2" SOCK,„..„..."
1
BLACK
GROMMET
Well Diagram
9. Find the center of the rope. Begin
lacing the ORC Socks by threading
one end of the installation rope
through the white grommet. Make
sure that the center of the rope is
pulled through to the center of the
white grommet on the bottom sock.
4

2" SOCK
CENTER
OF ROPE
WHITE
GROMMET
WHITE;-
GROMMET S
1
•,`.� BLACK
GROMMET
1o. Wrap each end of the
BLACK installation rope around the sock
GROMMET twice and then cross them
through the black grommet.
11. Lace each subsequent sock using
the same method ad describe in
Figure 2 above.
IMPORTANT:
Do not exceed the maximum
number of socks per section (see
"Key requirements B" on Page 1)
Minimize the slack between socks
For direct assistance or answers to any questions you may have regarding
these instructions, contact Regenesis Technical Services at 949-366-8000.
REGENESIS, 2002
www.regenesis.com
5

- Products - ORC® - MSDS
http://www.regenesis.com/products/orc/msds.aspx
Leaders in Accelerated Natural Attenuation
REGENESIS r
RpDUCTt
' ;,`zt� t< i� « �, �- ��—4s-°,� �u v.r-•� � a.��ys; ,�' f r ,��, ��' � a� ��
iLUTIONS [ RESOURCES + ] ABOUTUS a ] WORLDWIDE a
MATERIAL SAFETY DATA SHEET
A printable PDF version of the MSDS is available here.
Last Revised: February 10, 2004
Section 1 - Material Identification
Soarch I Contact Us I Order
Supplier:
REGENESIS
1011 Calle Sombra
San Clemente, CA 92673
Phone: [phone]
Fax: [phone]
Email: infoaregenesis.com
Chemical Description: A mixture of Magnesium Peroxide (Mg02), Magnesium Oxide (MgO), and Magnesium
Hydroxide [Mg(OH)2]
Chemical Family: Inorganic Chemical
Trade Name: Oxygen Release Compound (ORC®)
Product Use: Used to remediate contaminated soil and groundwater (environmental applications).
CAS #
14452-57-4
1309-48-4
1309-42-8
Assay:
Melting Point:
Boiling Point:
Section 2 - Chemical Identification
Chemical
Magnesium Peroxide (MgO2)
Magnesium Oxide (MgO)
Magnesium Hydroxide [Mg(OH)22]
25-35% Magnesium Peroxide (MgO2)
Section 3 - Physical Data
Not Determined (ND)
ND
Flash Point: Not Applicable (NA)
Self -Ignition Temperature NA
Thermal Decomposition: Spontaneous Combustion possible at —150°C
Density: 0.6-0.8 g/cc
Solubility: Reacts with water
pH: Approximately 10 in saturated solution
Appearance: White powder
Odor: None
Vapor Pressure: None
Hazardous Decomposition
Products:
Not Known
Hazardous Reactions: Hazardous Polymerization will not occur
Further Information: Non-combustible, but will support combustion
Section 4 - Reactivity Data
•
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Brochures:
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APPENDIX B
SOIL BORING LOGS WITH WELL CONSRUCTION DIAGRAMS
►►, ' ►► '4

Drilling Log
Project Name
nvoFcGA-
Project Number
4q -9 - y ooy -o (
Boring Number
A k,-7.
Ground Elevation
Location
mac) In". V)r5,A-1/1 4ve'5e4>C ; 6i,
Page
i of 3
i
Mr Nonitoring Equipment 1Z n
Total Footage
Drilling Type
Hole Size Overburden Footage
Bedrock Footage
No. 0f Samples
No. 0f Core Boxes
4 '/ _
1 I o. S 017)1 ?-7 o
NA-
5
,v 4
Drilling Company /,i 6.6/4 L L 5✓ 04 46,✓ S
D(ialer Is) Ken, /`') c.p0n-4 Id Don. Totiti.5 o�. 10 i✓v,r✓7kPrvh IL
Drilling Rig Gel 4 r(4 �7—yso
Tpe of
Sampler SML%,1 . J/10O/1"
Date 6/-���o
! 1
To 6/�6�9�
/
Field Observer(5) R Qil.1,rs
Depth
(feet)
Description
Description
Class
Blow
Count
Recov.
Run/
Time
SamplePID
Desig.
(ppm)
Remarks/
Water Levels
BZ BH S
BZ BH 0
2-
3-
4-
5 =
6 -
=
8 -
9-
10 --
-'
11-
12 -
_
13-
14 -
Ayve ,A-
Otiy5
o SYS
&y;,�1ic,
S.,o,e' SS -I
043�
San ''
7
—
—
-=
—,
2
-
—
_
-
-+
7
-
G 6 r/sone c1.0ve( a-S%j�Y/e
cv4(5e
GLI7 k-i I''�/ �4 S:fh, f-r•Xt'
51-4-veli51%Ff)✓t-c).. j,14S/le/
ICYPl.
e)
o o�
v6
rl TOP-
`�°��
rp:v -1f3S
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PD=yo •
pt7 �/
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5 ��C SS �'
- ---
,462
j
oVis
voc%
)"Tl iqr
v9it
BZ=Breathing Zone
BH=Bore Hole
S=Sanpie
Bums
8
McDonnell
Waste
Consultants,
Inc

uriiiing Log continuation
Boring Number /AN, _?--
Pro)ect Name /VofFo1/
Page �. of 3
Project Number ��I -� b - li -Goy O/
Date .6./ 9`f
Depth
(feet)
Description
Class
Blom
Count
Recov.
Run/
Time
Sample
Deslg.
PID (PM)J
Remarks/
BZ BH S
Water Levels
6 5
Gu —
-
/ 7 2_
JJ
U —
=
I —
_
-
22
44i/ 50,c Go7 c-i-- Si / 11141'
- Fi t.e ,.d vrl, yc'i(c—r5I' ---),A
-,-. 1 �ppplelUri°r/11mr oRW
2T ,-7- .15 A--o" t s7-. c( F!/ t)
-
h,e 4 -- 20--- -3, /
Do�p �l -T�'
ll—
cY�s
-
-
��3� -
e,
cal,
0955 -
5'5
T A-12)41/ tinZJ/ A
..s
r
3r►F
J 5
0��
5S 3
VcCS
vv/
pJ'D=`735
pzp= 3�
.. _
.
0995
•
c
vLcs
,41vA?
�9.Yyo
air
•
'3
) 7
6-774`45yTn
v� 5
VPI�
J
y
'ip = a7 (D ' S,�-�;i- Sac �
BZ=Breathing Zone
BH=Bore Hole
S=Sample
EMI Wute
Consult n!J 1

Drilling Log Continuation
Project Name
Project Number
Depth
(feet)
qq-9�(1-q-coy-01
Description
Class
Blow
Count
Recov.
Run/
Time
Sample
Desig.
Boring Number
r/w —
Pa9e 3 of 3
Date 6/36/iY
PID (ppm)
- 10 o7'p:
_ (eA)5e{
n
a
Gc> ve
$%Hon of 4ve i-L 4-)
asicA Fee 4- B 6 5
A/ T To e-4 t E-
BZ 1 BH I S
Remarks/
Water Levels
(29SS
_
0..c/c Sty4
.v i/ 541 r
v,;f4, 4t ip :
148, 10,07'
w)spl
Ihrx �
JS.cF? CF `
Ft.k'f
70F s -
P5v qyy)
7r0' /YY-J(4,tJ -
kk-,:1' pt ' t �.
C9b/iys)
1 co
T,44 i(
coiure J? phi)
Wrtb F6v5i)
Mov vl— p ✓e(
/5.20
BZ=Breathing Zone
BH=Bore Hole
S=Sample
MGMWaste

Drilling Log
,lect Name Alag fD �\ /�/ I,0,ect Nun4Der-Zv-y-
QDy-O Z
>und Elevation 1Locatlon ✓ ;
Monitoring Equipment ,/ /J ^ J [� 6� /T2
Drilling Type I Overburden Footage I Bedrock Footage No. Of Samples
-7, I 2‘ d '. I /V / -
Drllef (S) /rJ,,,e f7L••-rr/
Type of (
Sampler 1 f %, f J d �1 / Lr�
Field Ooserver (s) e+/o7 Cuff 7, 0-.7
Hole Size
Ss/4-
Company icclhf1 L✓e // D/r /11.1
filing Rig d Zoo G G
ite /Z /3 /ycl ITo /Z /3 /
epth
feet)
Description
1 _ C/47, Jo?'1G ✓L/y 4'n2 J/c/hlL/1-
JG�tO� re� (2 .s %Q 572)
2- Ca^ r sue,
4C� 4/;J�ic,s4 )<•4f
wo
o l Ti""
3-
4-
5-
6- Sti�,,�.7 c/47i rz�
y/')w/;�, Sw
- S,,: f d to4:1-z SG,raQiJ o
7- rd 1 Cet. A-c/c ,,,,,,/)Gf& %
▪ /0o5e./ ma. -,m do f t-
g- Ca4f %s ^c7) 0G N,/
9-
10_
11=
12 ;
13-
Class
CL
Blow
Count
Recov.
Run/
Time
Boring Number ./vi tv—
Page
of 2—
Total Footage C O
Sample
Desig.
PID (ppm)
No. Of Core Boxes
35-/
C/ 7`7 f4 / rep(
CZIr Y, r/ /c
dL / Shh4I'
gok v 1LA) ci0%r^.: 44-
Sc_
Z
/j
Z
2
otis
2
BZ I BH I S
O O
0 = 2/•FI,
O
0
G
/.•7
a 8.1 ci Z I
LAG= a50 2 1
02_2/.7.,
/5.9
Remarks/
Water Levels
14 -
R?=Rreathina Zone EH=Bore Hole 5=Sample
Waste
Consultant_.

Drilling Log Continuation
^,
Boring Number _yY/ (�/ — L7/
n
Project Name / / F',/—L ��
f
Page Z of
Protect Number � —y — — 6/0 G71— p Z
Date / Z. / S Cf
Depth
(feet)
Class
Blow
Recov.
Run/
Sample
PID (ppm)
Remarks/
r�
Description
Count
Time
Desig.
BZ
BH
S
dater Levels
_
_ c i``1``f-,��'
i r v--
`� ra, well 5';citci,
SC-
Z
SS
/O.b 27,173_,
)V:Zo.f
-
_
_
17
yrrt,}J goi,^+,1a-14-
z
SS-9
6Zv
11
=
Clay r4 -7, / 4.1 e
j—
7
2
d33,
5:fg
; '
/ -
jlooj2 ,4h�yy/-4-,zd. 1H44-+ •-,14r-
l✓6/l9-4d�i
/ 7u4 ?Z 4.4a4e,,;etif
T
l
.�1-9
`7Z7
i�6 7Z.Z
�S S� .
}
_
• -
S.,vy G /4/ J fd (/ U\ 1
i / ,1
C L
?
,,-
/
-.
•
,r« =, t i +� '�
.': -'- •i .-.. . ) c: i
:::.,.).1::- •.,..
2 _
-
zy=
., iy (/4 Jkc, // $ - -
(6)4f;/S "7 rno•; 4
(,,,Ld" /
?
3_
-
Z
c3?f�
;;_ li
�Z�
$ 3C?
•,-):-.
,,),(5-
> - ;''� -
91s �y-er5)
04' Ds
Z,q2k
ei I
S
i
Icy
SJ lZ
W20
Ati.hd ,,,,,,,,,e
,L.:o,a,k c l-,p i
1
tk�_ck-
J
-
--
_
���,�, off— �1a16 = 21,O'
Sz. well G� ZS,o'
ri.,-, d.c_ •._
0 0 - ;; .
✓fzx•
g.:' : /ice.; j_ -
—
ell:. r
i(:
i J - �.�
J
-
A
4 i. ,"3.•L
,i j
—
1--4
�i1+W
r
.,
_ _
I
—
'°
—�
To
-_
-
2-5 S C ,�j L �
BZ=Breathing Zone
BH=Bore Hole
S=Sampie
Waste