HomeMy WebLinkAboutWI0300127_Regional Office Historical File Pre 2018ATA
NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Coleen H. Sullins Dee Freeman
Governor Director Secretary
March 23, 2009
Mr. John W. Kirby
NCDOT Roadside Environmental Unit
4809 Beryl Road
Raleigh, NC 27606
Ref: Issuance of Injection Permit WI0300127
NCDOT — Roadside Environmental Unit
Former NCDOT Asphalt Testing Laboratory #35
Rockwell, North Carolina.
Dear Mr. Kirby:
0
9 7.009 1i
In accordance with the application received on November 12, 2008, and the supporting data submitted December 5, 2008,
and March 17, 2009, we are forwarding permit number WI0300127. This permit is for a pilot study to inject EOS®
solution plus 1000 gallons of potable "chase water" to remediate groundwater contaminated with chlorinated solvents at
the former NCDOT Asphalt Testing Laboratory #35 facility located in Rockwell, Rowan County, North Carolina. This
permit shall be effective from the date of issuance until February 28, 2011, and shall be subject to the conditions and
limitations stated therein, including the requirement to submit a final project evaluation as stated in PART VII —
MONITORING AND REPORTING REQUIREMENTS. Please note that during a site inspection by the Mooresville
Regional Office (MRO), two monitoring wells (35MW-1 and 35DW-1) were partially covered by road construction
materials and possibly damaged and do not meet well construction requirements per Title 15A NCAC 2C .0100. If the
wells are damaged beyond repair and need to be replaced, a permit will need to be obtained from the MRO.
You will need to notify this office by telephone 48 hours prior to initiation of operation of the facility. In order to
continue uninterrupted legal use of the injection facility for the stated purpose, you must submit an application to renew
the permit 120 days prior to its expiration date. Please contact me at 919-715-6166 or Michael.Rogers@ncmail.net if you
have any questions about your permit.
cc: Anci w _tue es i�lde„ i a1�(�7ffG
Robert Bost, BOSTCO tEEC
Jessica Dehart, Solutions-IES
WI0300127 Permit File
AQUIFER PROTECTION SECTION
1636 Mail Service Center, Raleigh, North Carolina 27699-1636
Location: 2728 Capital Boulevard, Raleigh, North Carolina 27604
Phone: 919-733-32211 FAX 1: 919-715-0588; FAX 2: 919-715-6048 l Customer Service: 1-877-623-6748
Internet: www.ncwaterquality.orq
An Equal Opportunity 1 Affirmative Action Employer
Best Regards,
Michael Rogers
Environmental Specialist
Aquifer Protection Section.
NorthCarolina
Naturally
NORTH CAROLINA
ENVIRONMENTAL MANAGEMENT COMMISSION
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
RALEIGH, NORTH CAROLINA
PERMIT FOR THE CONSTRUCTION AND OPERATION OF A WELL FOR INJECTION
In accordance with the provisions of Article 7, Chapter 87; Article 21, Chapter 143, and other
applicable Laws, Rules, and Regulations
PERMISSION IS HEREBY GRANTED TO
NCDOT - Roadside Environmental Unit
FOR THE CONSTRUCTION AND OPERATION OF 6 TYPE 5I INJECTION WELLS, defined in
Title 15A North Carolina Administrative Code 2C .0209(e)(3)(C), to inject EOS 598, to stimulate
bioremediation of chlorinated ethenes. These injection wells/points will be located at the NCDOT
Former Asphalt Testing Laboratory Site #35, 500 Industrial Drive, Rockwell, Rowan County, North
Carolina, and will be operated in accordance with the application submitted November 12, 2008, and
in conformity with the specifications and supporting data submitted December 5, 2008, and March
17, 2009, 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 Actor 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 February 28, 2011,
and shall be subject to the specified conditions and limitations set forth in Parts I through X hereof.
Permit issued this the day of 11'`e\N — , 2009.
f Coleen H. Sullins, Director
Division of Water Quality
By Authority of the Environmental Management Commission.
Permit No. WI0300127 PAGE 1 OF 6
ver.8/07 AP/UIC-6
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 short-term exposure to chemicals in the product
proposed to be used include eye, skin, nose, and throat irritation. Significant inhalation
exposure can cause coughing, wheezing, and shortness of breath. The chemicals may cause a
skin allergy where very low exposures can cause itching and skin rash.
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. The application process should be
reviewed by an industrial hygienist to ensure that the most appropriate personal protective
equipment is used.
3. 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.
4. Eating, drinking, smoking, handling contact lenses, and applying cosmetics should not be
permitted in the application area during or immediately following application.
5. Safety controls should be in place to ensure that the check valve and the pressure delivery
systems are working properly.
6. The Material Safety Data Sheets should be followed to prevent incompatible or adverse
reactions and injuries.
Permit No. WI0300127 PAGE 6 OF 6
ver.8/07 AP/UIC-6
AQUIFER PROTECTION REGIONAL STAFF REPORT
Date: 12/17/08
To: Aquifer Protection Central Office
Central Office Reviewer: Thomas Slusser
Regional Login No:
County: Rowan
Permittee: NCDOT
Project Name: NCDOT Asphalt Site #35
Application No.: WI0300127
L GENERAL INFORMATION
1. This application is (check all that apply): ® New ❑ Renewal
❑ Minor Modification ❑ Major Modification
n Surface Irrigation ❑ Reuse n Recycle ❑ High Rate Infiltration ❑ Evaporation/Infiltration Lagoon
n Land Application of Residuals
n Distribution of Residuals
❑ Attachment B included
❑ Surface Disposal
n Closed -loop Groundwater Remediation
❑ 503 regulated ❑ 503 exempt
® Other Injection Wells (including in situ remediation)
Was a site visit conducted in order to prepare this report? N Yes or ❑ No.
a. Date of site visit: 12/09/08
b. Person contacted and contact information: onsite fellow working with Bost Construction (current site
owner is Bostco LLC)
c. Site visit conducted by: Andrew Pitner & Maria Schutte
d. Inspection Report Attached: n Yes or ® No.
2. Is the following information entered into the BIMS record for this application correct?
® Yes or ❑ No. If no, please complete the following or indicate that it is correct on the current application.
For Treatment Facilities: info in BIMS for the facility was updated by MRO
a. Location:
b. Driving Directions:
c. USGS Quadrangle Map name and number:
d. Latitude: Longitude:
e. Regulated Activities / Type of Wastes (e.g., subdivision, food processing, municipal wastewater):
For Disposal and Injection Sites: info in BIMS for the facility was updated by MRO
(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): see above
b. Driving Directions:
c. USGS Quadrangle Map name and number:
d. Latitude: Longitude:
II. NEW AND MAJOR MODIFICATION APPLICATIONS (this section not needed for renewals or minor
modifications, skip to next section)
Section II is not applicable to this project.
FORM: APRSR040929-UIC review NCDOT Asphalt #35 1
AQUIFER PROTECTION REGIONAL STAFF REPORT
III. RENEWAL AND MODIFICATION APPLICATIONS (use previous section for new or major modification
systems)
Section III is not applicable to this project.
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)
n Closed -loop groundwater remediation effluent injection (5L/"Non-Discharge")
❑ Other (Specify: )
2. Does system use same well for water source and injection? ❑ Yes0 No
3. Are there any potential pollution sources that may affect injection? ® Yes ❑ No
What is/are the pollution source(s)?
The injection is designed to treat groundwater contamination associated with previous use of chlorinated
solvents at the site by a DOT lab. The former lab location is now partly occupied by several fuel ASTs and
their containment structure. The injection wells are proposed to be installed about 60 feet from the ASTs.
There is no data at this point that suggests that the ASTs are a significant source of pollution, though some very
minor staining was observed in their vicinity.
What is the distance of the injection well(s) from the pollution source(s)? Roughly 60 ft from the former lab..
4. What is the minimum distance of proposed injection wells from the property boundary? —225ft.
5. Quality of drainage at site: n 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 n 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. Maps provided don't do a very good job of illustrating
property lines, but do adequately show significant site features in the vicinity of the injection area. If the CO
wants a map from MRO's GIS, let us know and we'll send one.
FORM: APRSR040929-UIC review NCDOT Asphalt #35 2
AQUIFER PROTECTION REGIONAL STAFF REPORT
Injection Well Permit Renewal And Modification Only:
This section not applicable to this project.
Y. EVAL UATIONAND RECOMMENDATIONS
1. Provide any additional narrative regarding your review of the application: This is a small-scale injection
intended to remediate a small plume of dissolved chlorinated solvents from a DOT asphalt testing lab. In terms
of potential receptors, there is one water supply well about 1500 feet away that is not likely to be impacted by
any injection activities. The facility and adjacent businesses are connected to municipal water supply.
Unnamed tributaries to Second Creek can be found to the south and east sides of the property; the closest to the
injection is to the east about 250 feet and it is also unlikely to be impacted by the injection given the volume of
injectant, distance and conductivity of the regolith. One issue is that the key monitoring wells, 35MW-1 and
35DW-1, have been partially covered by gravel & asphalt due to activities at the site. After scraping briefly
with a shovel, one of the well covers was visible and part of the pad of the other well was visible. These wells
need maintenance as they are in a traffic area — likely reconstruction of the protective covers and pads — but it
is possible they might need to be replaced if the wells have been damaged beyond repair. If replacement were
necessary, then a permit would be required from the MRO. Otherwise, the MRO sees no significant issues
with this proposal and recommends that it be permitted.
2. Attach Well Construction Data Sheet - if needed information is available
3. Do you foresee any problems with issuance/renewal of this permit? n 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
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
1.
Maintenance / repair to 35MW-1 and
35DW-1.
1.
These MWs have been partially covered
by gravel/asphalt.
FORM: APRSR040929-UIC review NCDOT Asphalt #35
3
AQUIFER PROTECTION REGIONAL STAFF REPORT
7. Recommendation: ❑ Hold, pending receipt and review of additional information by regional office; ❑ Hold,
pending review of draft permit by regional office; n Issue upon receipt of needed additional information;
Issue; ❑ Deny. If deny, please state reasons:
8. Signature of report preparer(s): Andrew HPitner
Signature of APS regional supervisor: Andrew HPitner
Date: December 17, 2008
ADDITIONAL REGIONAL STAFF REVIEW ITEMS
FORM: APRSR040929-UIC review NCDOT Asphalt #35 4
TABLE 1
Summary of Groundwater Analytical Data for Target Compounds
NCDOT Former Asphalt Laboratory Site #35
Rockwell, North Carolina
NCDOT WBS #36413.1.49
Well ID
Sampled by
Sample
Date
1,1,1-
TCA
1,1,2-
TCA
1,1-
DCA
1,2-
DCA
1,1-
DCE
Chloroethane
PCE
TCE
cis-1,2-
DCE
trans
DCE
Chloroform
Vinyl
Chloride
NC 2L Standard
200
NE
70
0.38
7
2,800
0.7
2.8
70
100
70
0.015
SHALLOW MONITORING WELLS
35MW-1
G&M
12/13/1996
120
<25
<25
<25
,170:::
<25
<25
,410;.
<25
<25
<25
<25
G&M
12/13/1996*
120
<50
<50
<50
a220 '
<50
<50
500 `_
<50
<50
<50
<50
Solutions-IES
2/21/2006
35
<0.5
4.8
<0.5
120
<0.5
;`18 ..
1300:
2.9
- <0.5
3.0
<0.5
Solutions-IES
8/8/2006
63
<25
<25
<25
``:240:._
<25
<25
;1800.!;
<25
<25
<25
<25
35MW-2
G&M
11/22/1996
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
Solutions-IES
2/21/2006
<0.5
<0.5
<0.5
<0.5
<0.5
<0.5
<0.5
<0.5
<0.5
<0.5
<0.5
<0.5
Solutions-IES
8/9/2006
<0.5
<0.5
<0.5
<0.5
<0.5
<0.5
<0.5
<0.5
<0.5
<0.5
<0.5
<0.5
35MW-3
G&M
12/13/1996
<1
<1
<1
<1
<1
<1
<1
<1
<I
<1
<1
<1
G&M
12/13/1996*
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
- <1
Solutions-IES
2/21/2006
<0.5
<0.5
<0.5
<0.5
<0.5
<0.5
<0.5
<0.5
<0.5
<0.5
<0.5
<0.5
Solutions-IES
8/8/2006
<0.5
<0.5
<0.5
<0.5
<0.5
<0.5
<0.5
<0.5
<0.5
<0.5
<0.5
<0.5
35MW-4
G&M
11/22/1996
<1
<1
<I
<1
<I
<I
<1
<1
<1
<1
6
<1
G&M
11/22/1996*
<1
<1
<1
<1
<1
<l
<I
<1
<1
<1
5 -
<1
Solutions-IES
2/21/2006
<0.5
<0.5
<0.5
<0.5
<0.5
<0.5
<0.5
<0.5
<0.5
<0.5
<0.5
<0.5
Solutions-IES
8/8/2006
<0.5
<0.5
<0.5
<0.5
<0.5•
<0.5
<0.5
<0.5
<0.5
<0.5
<0.5 -
<0.5
35MW 5
G&M
11/22/1996
. <1
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
Solutions-IES
8/9/2006
<0.5
<0.5
<0.5
<0.5
<0.5
<0.5
<0.5
<0.5
<0.5
<0.5
<0.5
<0.5
35MW-6
G&M
4/3/1997
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
Solutions-IES
2/21/2006
<0.5
<0.5
<0.5
<0.5
<0.5
<0.5
<0.5
<0.5
<0.5
<0.5
• <0.5
<0.5
Solutions-IES
8/9/2006
<0.5
<0.5
<0.5
<0.5
<0.5
<0.5
<0.5
<0.5
<0.5
<0.5
<0.5
<0.5
35MW-7
Solutions-IES
8/9/2006
<0.5
<0.5
<0.5
<0.5
<0.5
<0.5
<0.5
<0.5
<0.5
<0.5
<0.5
<0.5
En
ull DEC - 9 2003 119
-1TC DrhlR iVIRO
DWQ - Ac infer Protection
Page 1 of 2
APPLICATION FOR PERMIT To CONSTRUCT AND/OR USE A WELL(S) FOR INJECTION
TYPE 51 WELLS — IN SITU GROUNDWATER REMEDIATION
SECTION V. ATTACHMENTS
F. MONITORING PLAN
F.1 Monitoring Wells
The following wells will be used for post -injection monitoring:
• 35MW-1
• 35MW-4
• 35DMW-1
• 35DMW-2
• 35DMW-7
RECEIVED / DENR / DWQ
AQUIFFRPR(1TFCTION SECT
NC DENR MRO
DWQ - A. uifer Protection
Table 3 provides a summary of the well construction for existing monitoring wells and proposed
temporary injection wells.
F.2 MONITORING PARAMETERS AND ANALYTICAL METHODS
During each sampling event, a set of site -wide water level measurements will be collected from
all monitoring wells. Each well to be sampled will then be purged and DO, ORP, specific
conductance, pH, and temperature measurements will be taken. Groundwater samples will then
be collected and submitted to a certified laboratory for analysis of VOCs (Method 8260 B), Total
Organic Carbon (Method 5310B), Nitrate (Method 353.2), Sulfate (Method 375.4).
F.3 MONITORING SCHEDULE
A groundwater monitoring event will be conducted prior to injection activities to act as a baseline
for evaluation of groundwater data. Post -injection monitoring will be completed at 1-month and
3-months following injection at the wells indicated in Section F.1. At approximately 6-month
post injection, groundwater monitoring will be conducted at all on -site monitoring wells.
G. WELL DATA
Well construction data for the existing monitoring well network and the proposed temporary
injection wells are presented in Table 3. A receptor survey conducted in 2004 by Hart &
Hickman did not identify any water supply wells within 1500 feet of the site.
11
•
0
0
0
Z
W
0]
r
W�
0
›-
OD ❑
W
0
U
W
U
m
p
0
0
W
0
W
J
a
125)
RIgC
11J8.
35MW-2
35MW-7
35MW-3
4-1
C7
35DW-6
<0.5
35DW-1
310
2.8
351\m-1
tl
335DW-2
2.820
35MW-6
35DW-4
<0.5
35DW-3
<0.5
35MW-5
1So1utions -IES
Industrial & Environmental Services
1101 NOWELL ROAD
RALEIGH, NORTH CAROLINA 27607
TEL.: (919) 873-1060 FAX.: (919) 873-1074
NOTES:
1) BASEMAP REFERENCE, "SITE MAP, NC DEPARTMENT OF TRANSPORTATION,
SITE NO. 35", GERAGHTY & MILLER ENVIRONMENTAL SERVICES, DATED 4/17/97.
RECEIVED / DENR / DWQ
AQUIFFR'PROTECTION SECTION
DEC 052008
---- 2.8
LEGEND
35 MW-5 SHALLOW MONITORING WELL
35 DW-1 DEEP MONITORING WELL
TCE CONCENTRATION (ug/L)
ESTIMATED EXTENT OF TCE
ABOVE 2L STANDARD
0
50
100
SCALE IN FEET
FORMER NCDOT ASPHALT TESTING LABORATORY
SITE NO. 35
500 INDUSTRIAL DRIVE
ROCKWELL, ROWAN COUNTY, NORTH CAROLINA
TCE ISOCONCENTRATION MAP
DEEP AQUIFER
AUGUST 2006
FIGURE:
7
>-
Q] ❑
o
0
U
W
0
U
35MW-3
<0.5
0
co
W
a
0
s
LL
35DW-6
LJ
35MW-6
<0.5
L.
35DW-4
1800
2.8
35DW-3
35MW-5
<0.5
AQU! FR PROD FCT ON/SFCQ
DEC p 5 r�o�
2008
LEGEND
35MW-5 SHALLOW MONITORING WELL
35DW-4 DEEP MONITORING WELL
TCE CONCENTRATION (ug/L)
ESTIMATED EXTENT OF TCE
ABOVE 2L STANDARD
0
50
100
SCALE IN FEET
Solutions -JES
Industrial & Environmental Services
1101 NOWELL ROAD
RALEIGH, NORTH CAROLINA 27607
TEL.: (919) 873-1060 FAX.: (919) 873-1074
NOTES:
1) BASEMAP REFERENCE, "SITE MAP, NC DEPARTMENT OF TRANSPORTATION,
SITE NO. 35", GERAGHTY & MILLER ENVIRONMENTAL SERVICES, DATED 4/17/97.
FORMER NCDOT ASPHALT TESTING LABORATORY
SITE NO. 35
500 INDUSTRIAL DRIVE
ROCKWELL, ROWAN COUNTY, NORTH CAROLINA
TCE ISOCONCENTRATION MAP
,SHALLOW AQUIFER
AUGUST 2006
FIGURE:
6
AQUIFER PROTECTION SECTION
APPLICATION REVIEW REQUEST FORM
Date: November 19, 2008
To: ❑ Landon Davidson, ARO-APS ❑ David May, WaRO-APS
❑ Art Barnhardt, FRO-APS ❑ Charlie Stehman, WiRO-APS
►.� . n t�ew �',�ttner. O+wA1PS 111 Sherri Knight, WSRO-APS
❑ Jay Zimmerman, RRO-APS
From: Thomas Slusser , Groundwater Protection Unit
Telephone: (919) 715-6164
E-Mail: thomas.slusser@ncmail.net
A. Permit Number: 0VII`[+16iU;)112it7es
B. Owner: NCDOT ROADSIDE ENVIRON. UNIT
Fax: (919) 71
C. Facility/Operation: FORMER ASPHALT TESTING FACILITY
® Proposed ❑ Existing ❑ Facility
SQ•
I� 1 =C1 IVVy?E
"' -NOV 2 1 2008
NC.DENR MRO
C'' DWQ`- A. uiter Protection
® Operation
D. Application:
1. Permit Type: ❑ Animal N Surface Irrigation ❑ Reuse ❑ H-R Infiltration
❑ Recycle N I/E Lagoon ❑ GW Remediation (ND)
UIC - (5I) in -situ groundwater remediation
For Residuals: ❑ Land App. ❑ D&M N S• urface Disposal
❑ 503 ❑ 503 Exempt N A• nimal
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 5 0 iznzlarflays; please take the following actions:
,E) 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
Coleen H. Sullins Director
Division of Water Quality
November 18, 2008
Mr. John W. Kirby
NCDOT-Roadside Environmental Unit
4809 Beryl Road, CEP 880-1911
Raleigh, NC 27606
Subject: Acknowledgement of Application No. WI0300127
NCDOT Former Asphalt Testing Laboratory Site # 35
Injection In situ Groundwater Remediation Well (5I)
Rowan
Dear Mr. Kirby:
EHE
NOV 2 1 2008
NC DENR MRO
DWQ -A uifer Protection
The Aquifer Protection Section of the Division of Water Quality (Division) acknowledges receipt of your permit
application and supporting materials on November 12, 2008. This application package has been assigned the number
listed above and will be reviewed by Thomas Slusser.
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 Thomas Slusser at 919-71.5-6164 or via e-mail at
thomas.slusser@ncmail.net. 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 THE ABOVE APPLICATION NUMBER WHEN MAKING INQUIRIES ON THIS
PROJECT.
Sine 1y,
j
for Debra atts
Supervisor
cc: Maoresa��id ebiona ff Aqui+f Prottecfiori bion
Solutions-IES (Jessica L. Dehart, 1101 Nowell Rd., Raleigh, NC 27607)
Permit Application File WI0300127
NorthCarolina
Naturally
Aquifer Protection Section 1636 Mail Service Center
Internet: www.ncwaterquality.orq Location: 2728 Capital Boulevard
An Equal Opportunity/Affirmative Action Employer- 50% Recycled/10% Post Consumer Paper
Raleigh, NC 27699-1636 Telephone: (919) 733-3221
Raleigh, NC 27604 Fax 1: (919) 715-0588
Fax 2: (919) 715-6048
Customer Service: (877) 623-6748
State of North Carolina
Department of Environment and Natural Resources
Division of Water Quality
APPLICATION FOR PERMIT TO CONSTRUCT AND/OR USE A WELL(S) FOR INJECTION
Type 5I Wells — In Situ Groundwater Remediation / Type 5T Wells — Tracer Injection
• Do not use this form for remediation systems that extract contaminated groundwater, treat it, and reinject the treated groundwater.
• Submit TWO copies of the completed application and all attachments to the address on the last page of this form.
• Any changes made to this form will result in the application package being returned.
Application Number (to be completed by DWQ):
I. GENERAL INFORMATION:
1. Applicant's Name (generally the responsible party): NCDOT - Roadside Environmental Unit
2. Signing Official's Name: Mr. John W. Kirby Title: Project Manager
3. Mailing address of applicant: 4809 Beryl Road
City: Raleigh
Telephone number: 919-835-8481
State: NC Zip: 27606
Fax number: 919-715-0679
4. Property Owner's Name (if different from Applicant): BOSTCO, LLC.
5. Property Owner's mailing address: 500 Industrial Drive
City: Rockwell
State: NC Zip: 28138
6. Name and address of contact person who can answer questions about the proposed injection project:
Name: Jessica L. Dehart
Company: Solutions-IES
Address: 1101 Nowell Road
Title: Project Hydrogeologist
City: Raleigh
State: NC Zip: 27607
Telephone number: 919-873-1060 Fax number: 919-873-1074
Email Address: jdehart@solutions-ies.com
PERMIT INFORMATION:
Project
2. if this applic
existing perr,
For renewal
form, and o
For all rene
date.
Revised 8/07
New 0 Modification of existing permit ❑ Renewal of existing permit without modification
Renewal of existing permit with modification
or
er
ii : u t d. r s or modification to an existing permit, provide:
1and the issuance date
t
t modifications, fill of
�e miler& si
a ou must submit a statu
NC DENR MRO
DWQ - Aquifer Protection
t lions I & II only, sign the certification on the last page of this
re to indicate consent (if the applicant is not the owner).
report including monitoring results of all injection activities to
RECEIVED / DENR / DWQ
IC-51/5T Aquifer Protection Section
NOV 12 2008
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 5T Wells — Tracer Injection
III. INCIDENT & FACILITY DATA
A. FACILITY INFORMATION
1. Facility name: NCDOT Former Asphalt Testing Laboratory Site #35
2. Complete physical address of the facility: 500 Industrial Drive
City: Rockwell County: Rowan
State: NC
Zip: 28138
B. INCIDENT DESCRIPTION
1. Describe the source of the contamination:
The site formerly housed an NCDOT asphalt testing laboratory facility. NCDOT conducted on -site testing of
asphalt using ASTM Method D2172-88. The method required the use of a solvent (such as TCE, 1,1,1-TCA, or
CT) to extract petroleum binder from the aggregate. Solvents stored, spilled or disposed of on -site near
operating Tabs resulted in releases of chlorinated solvents to the environment.
2. List all contaminants present in soils or groundwater at the site (contaminants may be listed in groups, e.g.,
gasoline, diesel, jet fuel, fuel oil, chlorinated ethenes, chlorinated ethanes, metals, pesticides/herbicides, etc):
Chlorinated ethenes
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
El No If no, list maximum concentration of total VOCs observed at site: 2,103
ppb
4. Agency managing the contamination incident:
❑ UST Section ❑ Superfund Section (including REC Program and DSCA sites)
❑ DWQ Aquifer Protection Section ❑ Solid Waste Section
❑ Hazardous Waste Section i Other: IHSB (formerly DWQ Aquifer Protection Section
5. Incident managers name Unknown (not assigned) and phone number 919-508-8400
6. Incident number or other site number assigned by the agency managing the contamination incident:
NONCD0002166
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: NA
2. DWQ Non -Discharge or NPDES permits: NA
3. County or DEH subsurface wastewater disposal permits: NA
4. Other environmental permits required by state or federal law:
NA
Revised 8/07 UIC-5I/5T 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 approved injectantsT or contact the UIC Program to determine if
the injectants you are proposing have been reviewed by OEES.
Injectant: EOS 598 (emulsified vegetable oil 60%, aqueous solution 40%)
Concentration at point of injection: 10% solution
Injectant:
Concentration at point of injection:
Injectant:
Concentration at point of injection:
Injectant:
Concentration at point of injection:
Injectant:
Concentration at point of injection:
Source of fluids used to dilute or chase the injectants listed above:
❑ None
N Municipal water supply
❑ Groundwater from private well or any well within 'A mile of injection site
❑ Air
❑ Other:
3. If any well within'/4 mile of injection site, a private well, or surface water is to be used as the fluid source, supply
the following information:
a. Location/ID number of source: NA
b. Depth of source:
c. Formation:
d. Rock/Sediment type:
e. In Attachment C, provide a current, complete chemical analysis of the water from the source well, including
analyses for all contaminants suspected or historically recognized in soil or groundwater on the site.
NOTE: If contaminated groundwater is to be used as the dilution or chase fluid, this is not the proper permit
application form. You must apply for a closed -loop groundwater remediation permit using application form
GPM'.
Revised 8/07 UIC-51/5T Page 3 of 7
APPLICATION FOR PERMIT TO CONSTRUCT AND/OR USE A WELL(S) FOR INJECTION
Type 5I Wells —In Situ Groundwater Remediation / Type 5T Wells — Tracer Injection
B. PROPOSED OPERATING PARAMETERS
1. Duration of Injection:
Maximum number of separate injection events: 1
Expected duration of each injection event: 3-5 days
Expected duration between events (if more than one event):
2. Injection rate per well: 2 gallons per minute (gpm)
3. Total Injection volume: 3,030 gallons per day (gpd); gallons per event (if separate events)
4. Injection pressure: <10 psi pounds/square inch (psi)
5. Temperature at point of injection: ambient °F
6. Briefly describe how the above parameters will be measured and controlled:
Flow distribution manifold with flow meters, gate valves, and pressure gauges.
7. Estimated hydraulic capacity of the well: 2 gpm
gpm
C. INJECTION WELL CONSTRUCTION DATA
1. Injection will be via:
❑ Existing well(s) proposed for use as an injection well. Provide the data in (2) through (6) below to the best of
your knowledge.
El 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: Solutions-IES (Brian Reber); Parratt Wolff, Inc.
NC Well Contractor Certification number: SIES: 3061-B Parratt Wolff: 2487
3. Date to be constructed: November 2008 Number of borings: 6
Approximate depth of each boring (feet): 3 @ 20 ft bgs; 3 @ 50 ft bgs
4. Screened interval/Injection interval of injection wells:
Depth: 10 to 60 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 ❑ Other:
Casing depth: 0 to ft. shallow 0-10ft; deep 0-50
6. Grout (N/A if injection is through direct push rods):
Type: I Cement ❑ Bentonite ❑ Other:
Grout depth: 0 to 7 ft. shallow. Deep 0-45 ft.
Revised 8/07 UIC-5I/5T Page 4 of 7
APPLICATION FOR PERMIT TO CONSTRUCT AND/OR USE A WELL(S) FOR INJECTION
Type 51 Wells — In Situ Groundwater Remediation / Type 5T Wells — Tracer Injection
V. ATTACHMENTS
Provide the following items as attachments with the given headings:
A. SITE HISTORY
Provide a brief description of the site history including:
(1) site usage historically and present,
(2) origin of the contamination,
(3) previous remedial action(s).
NOTE: G.S. 89E-18 requires that any geologic plans, reports, or documents in which the performance is related to the
public welfare or safeguarding of the environment be prepared by a licensed geologist or subordinate under his or her
direction. G.S. 89E-13 requires that all drawings, reports, or documents involving geologic work which shall have been
prepared or approved by a licensed geologist or a subordinate under his or her direction be signed and sealed by him or
her.
B. HYDROGEOLOGIC DESCRIPTION
Provide a hydrogeologic description, soils description, and cross section of the subsurface to a depth that includes the
known or projected depth of contamination. The hydrogeologic description shall include:
(1) the regional geologic setting;
(2) significant changes in lithology;
(3) the hydraulic conductivity, transmissivity, and specific yield of the aquifer to be used for injection, including a
description of the test(s) used to determine these parameters; and
(4) the depth to the mean seasonal high water table.
C. INJECTION FLUID COMPOSITION
Describe the chemical, physical, biological and radiological characteristics of each injectant. Attach the Material Safety
Data Sheet (MSDS) for each injectant. If a private well or a well within A mile of the injection site is used as the source
well, include chemical analysis of source fluid here.
D. INJECTION RATIONALE
Attach a brief description of the rationale for selecting the injectants and concentrations proposed for injection, including:
(1) goals of the injection project;
(2) a description of the reactions between the injectants and the contaminants present including specific breakdown
products or intermediate compounds that may be formed by the injection; and
(3) summary results of modeling or testing performed to investigate the injectant's potential or susceptibility to change
(biological, chemical or physical) in the subsurface.
E. INJECTION PROCEDURE AND EQUIPMENT
Provide a detailed description of all planned activities related to the proposed injection including but not limited to:
(1)
(2)
(3)
(4)
construction plans and materials;
operation procedures;
a detailed diagram of the surface and subsurface portions of the system; and
a planned injection schedule.
F. MONITORING PLAN
Provide a plan for monitoring the results of the injection, including:
(1) a list of existing and proposed monitoring wells to be used;
(2) a list of monitoring parameters and analytical methods to be used; and
(3) a schedule for sampling to monitor the proposed injection.
NOTE: The selected monitoring wells must be located so as to detect any movement of injection fluids, process by-
products, or formation fluids outside the injection area or zone. The monitoringparameters should include the target
contaminants as well as secondary or intermediate contaminants which may result from the injection and other
parameters which may serve to indicate the progress of the intended reactions, such as pH, ORP, dissolved oxygen, and
Revised 8/07
UIC-5I/5T Page 5 of 7
APPLICATION FOR PERMIT TO CONSTRUCT AND/OR USE A WELL(S) FOR INJECTION
Type 5I Wells —In Situ Groundwater Remediation / Type 5T Wells — Tracer Injection
other electron acceptors and donors. The monitoring schedule should be consistent with the pace of the anticipated
reactions and rate of transport of the injectants and contaminants.
G. WELL DATA
Provide a tabulation of data on all existing or abandoned wells within' '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.
H. MAPS
Attach the following scaled, site -specific maps:
(1) Area map based on the most recent USGS 7.5' topographic map of the area, at a scale of 1:24,000 and
showing the location of the proposed injection site.
(2) Site map including:
a. all property boundaries;
b. all buildings within the property boundary;
c. existing and proposed injection wells or well field(s)
d. any existing sources of potential or known groundwater contamination, including waste storage,
treatment or disposal systems within' 'A mile of the injection well or well system;
e. all surface water bodies within'/a mile of the injection well or well system; and
f. all existing or abandoned wells within'/4 mile of the injection well(s) which penetrate the proposed
injection zone, including, but not limited to, monitoring wells and wells proposed for use as injection
wells.
(3) Potentiometric surface map(s) including:
a. direction of groundwater movement
b. existing and proposed monitoring wells
c. existing and proposed injection wells
(4) Contaminant plume map(s) including:
a. the horizontal extent of the contaminant plume, including isoconcentration lines
b. existing and proposed monitoring wells
c. existing and proposed injection wells
(5) Cross-section(s) to the known or projected depth of contamination, including:
a. horizontal and vertical extent of the contaminant plume, including isoconcentration lines
b. major changes in lithology
Revised 8/07
UIC-51/5T Page 6 of 7
APPLICATION FOR PERMIT TO CONSTRUCT AND/OR USE A WELL(S) FOR INJECTION
Type 5I Wells — In Situ Groundwater Remediation / Type 5T Wells — Tracer Injection
VI. CERTIFICATION
I, t-TO a-/4 ... VV . K t i - )1,V , hereby certify under penalty of law that
I have personally examined and am familiar with the information submitted in this document and all attachments
thereto and that, based on my inquiry of those individuals immediately responsible for obtaining said information,
I believe that the information is true, accurate and complete. I am aware that there are significant penalties,
including the possibility of fines and imprisonment, for submitting false information. I agree to construct,
operate, maintain, repair, and if applicable, abandon the injection well(s) and all related appurtenances in
accordance with the approved specifications and conditions of the Permit.
Signature:
Title: N'ti' 0 T- i4GC:
Date: l eV i S eUa
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
contrary agreement in writing.
I, BOSTCO, LLC.
, as owner of the property on which the
injection well(s) are to be constructed and operated, hereby consent to allow the applicant to construct each
injection well as outlined in this application and agree that it shall be the responsibility of the applicant to ensure
that the injection well(s) conform to the Well Construction Standards (Title 15A NCAC 2C .0200)
Signature: t�•
Title: PD d-4— rlt.'-
Date: U(1 /es
s
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 (919) 733-3221
Revised 8/07 UIC-5I/5T
RECEIVED / DENR / DWQ
Aquifer Protertinrn Qantion
NOV 12 2008
Page 7 of 7
APPLICATION FOR PERMIT TO CONSTRUCT AND/OR USE A WELL(S) FOR INJECTION
Type 5I Wells - In Situ Groundwater Remediation/Type 5T Wells — Tracer Injection
This work has been prepared under my direct supervision as per G.
all drawings, reports, or documents involving geologic work which
approved by a licensed geologist or a subordinate under his or her
by him or her.
Jessica L. Dehart, P.G.
Printed Name
S. 89E-131twhich requires that
shall have been prepared or
direction be singed ancije i,,a®
�. • ��GE Pl O•�2 v
i SEAL irt
rn : 2169 if —
a
�"Se N 14amest®®�®
RECEIVED / DENR / DWQ
Aquifer Protection Section
NOV 12 2008
t 't
ATTACHMENTS
APPLICATION FOR PERMIT To CONSTRUCT AND/OR USE A WELL(S) FOR INJECTION
TYPE 5I WELLS —IN SITU GROUNDWATER REMEDIATION
SECTION V. ATTACHMENTS
A. SITE HISTORY
A.1 BACKGROUND
Site #35 is located on approximately 10.75 acres about one mile northwest of downtown
Rockwell, North Carolina at 500 Industrial Drive. Figure 1 shows the approximate location of
the site, and Figure 2 depicts the approximate site layout. The site formerly housed an NCDOT
asphalt testing facility and was an active asphalt plant until the early 1990s. The property is
currently owned by Bostco, LLC and is used as a vehicle maintenance facility with a small
adjacent aboveground storage tank (AST) farm containing fuel for the construction vehicles.
Historical information on the years of laboratory operation and solvent types and usage at this
location is not available. However, other NCDOT testing facilities in North Carolina generally
ceased operations in the early 1990s. NCDOT conducted on -site testing of asphalt at many
asphalt -producing facilities using American Society for Testing and Materials (ASTM) Method D
2172-88. The ASTM test method required the use of a solvent such as trichloroethene (TCE),
1,1,1-trichloroethane (1,1,1-TCA) or carbon tetrachloride (CT) to extract the petroleum binder
from the aggregate. The aggregate was then subject to a particle size gradation test.
According to NCDOT, on -site laboratories primarily used TCE and 1,1,1-TCA in progression
when the laboratory was in operation. The solvents were usually purchased new, and were reused
until they were no longer effective. Recycled solvents possibly containing impurities were also
used. Solvents stored, spilled or disposed of onsite near operating laboratories, resulted in
releases of chlorinated solvents to the environment.
The NCDOT entered into a memorandum of agreement with the North Carolina Department of
Environment and Natural Resources (NCDENR) Division of Water Quality's (DWQ)
Groundwater Section in 1999 outlining the objectives and procedures to be used in evaluating the
potential environmental impacts at former asphalt testing laboratories. Since that time, the
NCDENR has undergone a reorganization and the asphalt sites are currently under the
jurisdiction of the Inactive Hazardous Sites Branch (IHSB).
1
APPLICATION FOR PERMIT To CONSTRUCT AND/OR USE A WELL(S) FOR INJECTION
TYPE 5I WELLS -IN SITU GROUNDWATER REMEDIATION
SECTION V. ATTACHMENTS
A.1.2 Environmental Assessments and Remedial Actions
An initial site screening conducted by NCDOT in 1989 indicated the presence of TCA and TCE
in a soil sample collected at an unspecified location. A comprehensive site assessment (CSA)
was conducted by Geraghty & Miller in 1996 and early 1997 which included a soil vapor survey,
soil and groundwater sample collection and analysis, installation of 10 monitor wells, surveying,
water level measurements, and aquifer testing. Results of the CSA indicated the possible
presence of target chlorinated solvents in the soil vapor samples in the vicinity of the former
asphalt testing laboratory. The Geoprobe® groundwater investigation identified the presence of
TCE, TCA, and 1,1-dichloroethene (1,1-DCE) at concentrations above the 15 NCAC 2L.0202
groundwater standards (NC 2L standards) in one groundwater sample collected in the vicinity of
the former asphalt testing laboratory.
The CSA concluded that the extent of TCE-impacted soils was horizontally delineated, but not
vertically delineated. In addition, the lateral extent of target chlorinated solvents had been
adequately defined for the shallow groundwater plume; however, the vertical extent of target
chlorinated solvents had not been fully defined.
In a letter dated July 1, 1997, the NCDENR issued written comments on the CSA submitted in
May 1997. The letter agreed with the CSA that the vertical extent of target chlorinated solvents
in soil and groundwater had not been adequately delineated. The letter recommended additional
soil sampling at the location of SS-3 to define the vertical extent of soil contamination, additional
monitor wells adjacent to or downgradient of SS-3 (the presumed source area), and an additional
deep monitor well to the east of 35MW-3 to define the horizontal extent of deep groundwater
contamination.
Solutions-IES conducted soil and groundwater sampling in August 2006 to complete the
delineation activities. An additional shallow monitoring well was installed in the presumed
source area. Soil samples were collected during well installation activities to define the extent of
soil contamination remaining in this area. In addition, two deep monitoring wells were installed
with the intent of delineating the horizontal extent of groundwater contamination in the western
portion of the site (35-DW6) and the vertical extent of contamination in the current groundwater
plume area (35-DW7).
APPLICATION FOR PERMIT TO CONSTRUCT AND/OR USE A WELL(S) FOR INJECTION
TYPE 51 WELLS —IN SITU GROUNDWATER REMEDIATION
SECTION V. ATTACHMENTS
B. HYDROGEOLOGIC DESCRIPTION
B.1 REGIONAL GEOLOGIC SETTING
The town of Rockwell is situated within the Carolina Slate Belt, part of the Piedmont
physiographic province. Bedrock within the Carolina Slate Belt is predominantly composed of
low grade metavolcanic rocks. The site is located in an area described as being underlain by
metavolcanic rock of interbedded mafic to felsic tuffs on the 1985 Geologic Map of North
Carolina (North Carolina Geologic Survey). The mafic rocks are described as medium grayish
green to dark green to black, fine -to medium -grained andesitic to basaltic tuffs and flows.
The typical Piedmont aquifer system is divided into three zones. These zones include the
unconsolidated saturated soil zone, the underlying saprolite and weathered bedrock. All three
zones are interconnected and act as a single aquifer system, although each zone varies in its
ability to transmit water (permeability). The base of the Piedmont bedrock aquifer is indistinct
and occurs where the fracture system is no longer effective in transmitting flow. The number of
fractures decreases with increasing depth, and often fractures are non -water bearing below a
depth of approximately 300 feet (Heath, 1980).
The site is specifically underlain by the Cecil Loam soil unit (CeB2) (NRCS Web Soil Survey
2.0). This soil type is described as: "sandy clay loam".
B.2 SIGNIFICANT CHANGES IN LITHOLOGY
The characteristics of the subsurface materials at the site were evaluated from the description of
onsite borings completed by Geraghty & Miller, as well as information obtained during the
installation of new monitor wells in July 2006 by Solutions-IES. Figure 3 shows the location of
cross sections across the site generated from historical and recent boring information. Figures 4
and 5 are cross sections showing the site lithology. Based on the boring logs, the subsurface
materials generally consist of 1 to 2 feet of fill material overlaying interbedded clays and silts to a
depth of approximately 15 feet and sandy silts to the top of a saprolite layer. The bedrock at this
site was encountered at approximately 50 ft bgs and was overlain by 1 to 5 feet of saprolite.
Numerous fractured zones were identified during the drilling of borings for the deep monitor
wells.
3
APPLICATION FOR PERMIT To CONSTRUCT AND/OR USE A WELL(S) FOR INJECTION
TYPE 51 WELLS -IN SITU GROUNDWATER REMEDIATION
SECTION V. ATTACHMENTS
At the site, the shallow aquifer includes surficial sediments and saprolite and has been delineated
during previous work at the site as land surface to approximately 50 ft bgs. The deep aquifer lies
below the 50 ft bgs depth and consists of a highly fractured zone to a depth of approximately 60 ft
bgs under which lies competent bedrock with few fractures.
B.2.1 Current Site Conditions
Only one well (35MW-1) screened in the shallow groundwater monitoring zone contained
concentrations of target compounds above the NC 2L standards during the February and August
2006 sampling events. TCE concentrations in 35MW-1 have been detected in concentrations
ranging from 1300 µg/L in February 2006, to 1800 µg/L in August 2006, while 1,1-DCE has
been detected at concentrations of 120 µg/L and 240 µg/L in February and August 2006
respectively.
Target compounds detected above the NC 2L standards in monitoring wells screened in the deep
aquifer include 1,1-DCE and TCE. Concentrations of 1,1-DCE have been detected in 35DW-1 at
concentrations ranging from 57 µg/L to 41 µg/L in February and August 2006 respectively. TCE
has historically been detected in 35DW-1 at concentrations as high as 820 µg/L, but has most
recently been detected at 310 µg/L in both the February and August 2006 events. In well 35DW-
2, concentrations of TCE appear to be decreasing, with the most recent concentrations being 21
µg/L and 20 µg/L, in February and August 2006 respectively. Table 1 provides a summary of
historical groundwater analytical data.
In summary, TCE and 1,1-DCE are the main target compounds presently detected in groundwater
at Site #35 at concentrations above the NC 2L standards. Target compounds were detected above
the NC 2L standards in monitor wells 35MW-1, 35DW-1, and 35DW-2 (Figures 6 and 7). Of
these wells, the most favorable conditions for reductive dechlorination were detected in 35DW-2.
Generally reducing conditions were also detected in 35DW-1. Based on current conditions, there
is some indication of natural biodegradation of TCE to cis-1,2-DCE in 35DW-1; however, in
35MW-1 and 35DW-2 there has been little change (or increase in TCE) with no appearance of
daughter products. In fact, the current TCE concentration in 35MW-1 is more than double the
1996 concentration. Conversely, in all three wells with target compounds, the concentration of
4
APPLICATION FOR PERMIT To CONSTRUCT AND/OR USE A WELL(S) FOR INJECTION
TYPE 51 WELLS — IN SITU GROUNDWATER REMEDIATION
SECTION V. ATTACHMENTS
1,1,1-TCA has decreased appreciably since 1996 with the accompanying presence of 1,1-DCE,
which is an abiotic breakdown product of 1,1,1-TCA.
B.2.2 Lithology of the Injection Area
Based on the boring logs, the subsurface materials generally consist of 1 to 2 feet of fill material
overlaying interbedded clays and silts to a depth of approximately 15 feet and sandy silts to the
top of a saprolite layer. The bedrock at this site was encountered at approximately 50 ft bgs and
was overlain by 1 to 5 feet of saprolite. Numerous fractured zones were identified during the
drilling of borings for the deep monitor wells.
At the site, the shallow aquifer includes surficial sediments and saprolite and has been delineated
during previous work at the site as land surface to approximately 50 ft bgs. The deep aquifer lies
below the 50 ft bgs depth and consists of a highly fractured zone to a depth of approximately 60 ft
bgs under which lies competent bedrock with few fractures.
B.3 HYDROGEOLOGIC PARAMETERS USED FOR DESIGN
Groundwater at the site flows in a south to southeasterly direction in both the shallow and the
deep aquifer toward the unnamed creek located along the southeastern border of the property.
The water -level elevation data collected during the August 2006 sampling event were used to
create a potentiometric surface map of the shallow aquifer (Figure 8). The overall groundwater
gradient was estimated from the August 2006 water level data to be approximately 0.03 ft/ft in
the shallow aquifer and 0.007 ft/ft in the deep aquifer.
Geraghty & Miller estimated that the average hydraulic conductivity for the shallow aquifer was
0.79 ft/day and 25.54 ft/day in the bedrock aquifer. The average groundwater velocity at this site
was estimated to be 27 ft/year. Using a geometric mean hydraulic conductivity of 0.79 ft/day, an
average hydraulic gradient of 0.03 ft/ft between 35MW-2 and 35MW-4, and an estimate of 30
percent for porosity, the site -wide groundwater flow velocity is estimated as:
K Ah 0.79ft/day x0.03ft/ft=0.079ft/day
0.30
5
APPLICATION FOR PERMIT To CONSTRUCT AND/OR USE A WELL(S) FOR INJECTION
TYPE 5I WELLS -IN SITU GROUNDWATER REMEDIATION
SECTION V. ATTACHMENTS
where K is the hydraulic conductivity, Ne is the effective porosity, and Ah/Al is the slope of the
water table; which is appropriate for contaminant transport calculations downgradient of the
source area.
B.4 DEPTH TO MEAN SEASONAL HIGH WATER TABLE
During the most recent groundwater sampling event in August 2006 by Solutions-IES, the water
levels in the shallow aquifer ranged from 18.87 ft below top of casing (btoc); (elevation of 724.0
ft above mean sea level (amsl)) in MW-4 to 13.98 ft btoc (elevation of 731.17 ft amsl) in MW-7.
The water levels in the deep aquifer ranged from 17.69 ft btoc (elevations of 724.44 ft asml) in
monitoring well DW-4 to 16.28 ft btoc (elevation of 726.63 ft amsl) in DW-6. These values are
consistent with historical water levels recorded at the site. Table 2 provides a summary of the
historical water levels at this site.
C. INJECTION FLUB) COMPOSITION
The injection fluid is a stable emulsified -oil concentrate (EOS®) composed of food -grade soybean
oil, surfactants, amino acids, and vitamins blended to maintain a non -separated phase concentrate.
The concentrate will be diluted in the field with potable water to assist in distribution into the
aquifer. The emulsified liquid contains oil droplets in the 0.7 to 1.5 micron size range which
allow for ease of dilution, simplicity of injection and optimal subsurface distribution. The EOS®
will be handled according to the manufacturer's recommendations and in accordance with the
site's Health & Safety Plan. All materials used in the process are Generally Recognized As Safe
(GRAS) food -grade materials (21 CFR 184.1400). A Material Safety Data Sheet for EOS® is
included in Appendix A. The water source will be from a potable water supply obtained from
the City of Salisbury, which provides potable water to this area.
D. INJECTION RATIONALE
D.1 GOALS OF THE INJECTION PROJECT
The remediation goal for groundwater is to return it to its most beneficial use (which is drinking
water). The NC 2L Standards are proposed as the cleanup goals for groundwater. The goal of
this injection is to introduce a biodegradable organic substrate into portions of the aquifer with
high VOC concentrations to stimulate microbial activity and enhance reductive dechlorination of
6
APPLICATION FOR PERMIT To CONSTRUCT AND/OR USE A WELL(S) FOR INJECTION
TYPE 51 WELLS — IN SITU GROUNDWATER REMEDIATION
SECTION V. ATTACHMENTS
dissolved chlorinated ethene contaminants present in groundwater at the site. Six injection wells
will be utilized for the injection of EOS®, chase water and Vitamin B-12. The well configuration
provides for two treatment zones with three injection wells per zone: one zone in the shallow
aquifer and one zone in the deep aquifer. The locations of the six proposed injection wells are
shown on Figure 9.
D.2 INJECTANT/CONTAMINANT REACTIONS
This project injects a biodegradable organic substrate into a contaminated aquifer. The
technology involves a one-time injection of slowly biodegradable, emulsified oil substrate
(EOS®). EOS® is a water miscible emulsion with an engineered droplet size that is prepared
using food -grade edible oils, surfactants, macro- and micronutrients. The EOS® process is
patented by Solutions-IES (U.S. Patent #US RE40,448E).
The emulsion is injected and distributed throughout the treatment zone using conventional
injection wells. The vegetable oil becomes trapped within the sediment grain pores leaving a
residual oil phase to support long-term anaerobic biodegradation of the target contaminants. As
the oil slowly biodegrades, it provides a continuous source of dissolved organic carbon to the
native microbial community to stimulate microbiological consumption of oxygen and production
of hydrogen. This reaction is illustrated generically in Equation 1:
(Eq. 1) C18H3202 (linoleic acid) + 34 H2O --Bacteria--> 18 CO2 + 50 H2
The organic substrate is the electron donor in this sequence of reaction. The hydrogen itself then
drives the desired anaerobic biological metabolism of the target contaminants by a second, more
specialized, group of microorganisms. These metabolic biotransfonnations are illustrated in
Equations 2 through 5 where hydrogen is used sequentially to replace each chlorine atom:
(Eq. 2) C2C14 (PCE) + H, -- Bacteria --> C,HC13 (TCE) + Cl + H
(Eq. 3) C2HC13 (TCE) + H, -- Bacteria --> C2H2C1, (DCE) + Cl + H+
(Eq. 4) C,H2C12 (cis%trans-DCE) + H2 -- Bacteria --> C2H3C1(VC) + Cl + H+
(Eq. 5) C2H3C1 (VC) + H2 -- Bacteria --> C2H4 (ethene) + CI + H+
APPLICATION FOR PERMIT To CONSTRUCT AND/OR USE A WELL(S) FOR INJECTION
TYPE 5I WELLS - IN SITU GROUNDWATER REMEDIATION
SECTION V. ATTACHMENTS
Overall, four hydrogen molecules (4H2) are needed to completely dechlorinate the PCE molecule
to chloride.
D.3 MODELING AND TESTING RESULTS
Reductive dechlorination of chlorinated ethenes using a carbon source electron donor is a proven
groundwater remediation methodology. The amount of EOS® injected into the subsurface is
determined based on the concentrations of the target compounds (TCE and 1,1-DCE), the
concentrations of competing electron acceptors (i.e., dissolved oxygen, nitrate, sulfate,
manganese dioxide and ferric iron) and hydrogeologic conditions (i.e., subsurface lithology and
heterogeneity, hydraulic conductivity and effective porosity of the treatment zone). The available
site -specific information obtained from the Comprehensive Site Assessment (Geraghty & Miller,
1997) and testing by Solutions-IES in August 2006, were entered into the design spreadsheet
provided by EOS Remediation of Raleigh, NC. The design indicated that 5 drums
(approximately 1,300 lbs) of EOS® would be required to treat both injection zones. The design
life for this amount of substrate is approximately 3 to 5 years.
To optimize the injection process, the injection was designed to involve diluting the concentrate
10-fold as it is injected until all the EOS® has been placed in the aquifer. Then the EOS® is
further distributed away from each injection point using potable chase water.
EOS® has been thoroughly tested and is manufactured from food grade soybean oil, emulsifying
agents, micronutrients, vitamin B-12 and water. EOS® was used in a source area treatment
project at the Tarheel Army Missile Plant (TAMP) in Burlington, NC. In 2004, Solutions-IES
injected 13,000 pounds of EOS® concentrate into the 100 x 100 ft (30.5m X 30.5m) zone believed
to be the primary source area for the TCE plume. The EOS® treatment quickly stimulated
anaerobic conditions as evidenced by decreased dissolved oxygen, oxidation-reduction potential,
and sulfate concentrations and increasing ferrous iron, and methane. TCE was gone and only
degradation products were evident within one year of treatment. The regular monitoring program
confirmed the effectiveness of the selected treatment technology. Suitable conditions were
established for the contaminants to be reduced to non -chlorinated end -products.
8
APPLICATION FOR PERMIT To CONSTRUCT AND/OR USE A WELL(S) FOR INJECTION
TYPE 5I WELLS - IN SITU GROUNDWATER REMEDIATION
SECTION V. ATTACHMENTS
E. INJECTION PROCEDURE AND EQUIPMENT
E.1 CONSTRUCTION PLANS AND MATERIALS
A total of six temporary injection wells will be installed to treat both the shallow and deep
treatment zones. Three shallow borings will be advanced drilled using Geoprobe® direct push
drilling techniques. The borings will be advanced to approximately 20 feet below ground surface
(ft bgs). The shallow injection wells will be constructed as 1-inch diameter PVC with 10 feet of
0.020-slot screen. An appropriately sized sand pack will be placed around the screen to
approximately 2 feet above the top of the screen. The remaining annular space will be backfilled
with bentonite pellets (periodically hydrated as they are added to the annular space) to within 3
feet of land surface. The last 3 feet of annular space shall be completed with a bentonite grout
cement mix.
In addition, three deep borings will be advanced using air -rotary drilling techniques. The borings
will be advanced to approximately 60 ft bgs. A temporary surface casing will be set during well
construction to prevent caving of the overburden. The deep injection wells will be constructed as
2-inch diameter PVC with 10 feet of 0.020-slot screen. An appropriately sized sand pack will be
placed around the screen to approximately 2 feet above the top of the screen. The remaining
annular space will be backfilled with bentonite pellets (periodically hydrated as they are added to
the annular space) to within 3 feet of land surface. The last 3 feet of annular space shall be
completed with a bentonite grout cement mix. After injection activities are completed, all of the
temporary injection wells will be abandoned.
Injection activities will be conducted in two phases, one phase will inject into the shallow aquifer
and the other phase will inject into the deep aquifer. For each phase of the injection process, the
wells will be manifolded together, but will have individual flow meters, gate valves and pressure
gauges. The Dosatron® diluter (or transfer pump) will be plumbed into a splitter that will allow
individual wells to be shut off from the injection process as needed. This will allow for the
control of pressure and flow rates of injection at each well. The manifold will be plumbed to a
Dosatron® with a potable water source (City of Salisbury) to provide dilution of the EOS®
concentrate. The Dosatron® will only allow a maximum total flow of 7 gpm. Therefore, to inject
three wells simultaneously the injection rate will be limited to 2 gpm per well.
9
APPLICATION FOR PERMIT To CONSTRUCT AND/OR USE A WELL(S) FOR INJECTION
TYPE 51 WELLS - IN SITU GROUNDWATER REMEDIATION
SECTION V. ATTACHMENTS
E.2 OPERATING PROCEDURES
Implementation of the process involves on -site blending of the EOS® concentrate with potable
water utilizing a Dosatron® water -powered proportional dosing pump. A Dosatron® will be set up
on a drum of EOS® via a flexible hose. Water from a fire hydrant will go through a City supplied
flow meter, then into the Dosatron® for use in diluting the EOS® to the proper 10:1 concentration
(10 parts water to 1 part EOS®). If the Dosatron® proportional dosing pump is unable to achieve
the design flow rate, alternative mixing and pumping approaches will be implemented.
Alternative designs may include using dilution tanks, chemical feed and transfer pumps to
conduct the injection.
The mixture will then be piped to the splitter where the injectant will be directed into flexible
hoses going to each well head manifold. Each braided hose line will have a flow meter to
determine the total volume of injectant going into each well. A gate valve and pressure valve at
each well manifold will allow field personnel to monitor and adjust flow rates and fluid pressures
during the injection process.
E.3 SYSTEM DESIGN
The EOS® solution will be injected into 6 temporary injection wells located down gradient of the
source area (Figure 9). The injection process will be performed during one mobilization in
several steps. EOS® concentrate will be diluted with potable water to a 10% concentration using
an in -line metering system. Approximately 505 gallons of dilute EOS® will be injected into each
of the 6 wells via the EOS® Metering System. Afterwards, approximately 1,000 additional
gallons of potable water will be injected to move the emulsion out into the formation away from
each well. If an injection rate of one gpm is achievable, then the injection should be completed
within approximately three days. However, if injection rates are significantly less, then additional
time in the field will be required. Figure 10 shows a schematic of the injection process.
E.4 INJECTION SCHEDULE
The injection is anticipated to occur during the Fall of 2008. The injection well installation
activities will commence within one month of receiving an approved UIC permit. The actual
injection of EOS® will occur within two weeks of the completion of the injection wells.
10
APPLICATION FOR PERMIT TO CONSTRUCT AND/OR USE A WELL(S) FOR INJECTION
TYPE 5I WELLS —IN SITU GROUNDWATER REMEDIATION
SECTION V. ATTACHMENTS
F. MONITORING PLAN
F.1 Monitoring Wells
The following wells will be used for post -injection monitoring:
• 35MW-1
• 35MW-4
• 35DMW-1
• 35DMW-2
• 35DMW-7
Table 3 provides a summary of the well construction for existing monitoring wells and proposed
temporary injection wells.
F.2 MONITORING PARAMETERS AND ANALYTICAL METHODS
During each sampling event, a set of site -wide water level measurements will be collected from
all monitoring wells. Each well to be sampled will then be purged and DO, ORP, specific
conductance, pH, and temperature measurements will be taken. Groundwater samples will then
be collected and submitted to a certified laboratory for analysis of VOCs (Method 8260 B), Total
Organic Carbon (Method 5310B), Nitrate (Method 353.2), Sulfate (Method 375.4).
F.3 MONITORING SCHEDULE
A groundwater monitoring event will be conducted prior to injection activities to act as a baseline
for evaluation of groundwater data. Post -injection monitoring will be completed at 1-month and
3-months following injection at the wells indicated in Section F.1. At approximately 6-month
post injection, groundwater monitoring will be conducted at all on -site monitoring wells.
G. WELL DATA
Well construction data for the existing monitoring well network and the proposed:temperry,
injection wells are presented in Table 3. A receptor survey conducted'in xxx by xxx did nod
identify any water supply wells within 1500 feet of the site.
11
APPLICATION FOR PERMIT To CONSTRUCT AND/OR USE A WELL(S) FOR INJECTION
TYPE 51 WELLS - IN SITU GROUNDWATER REMEDIATION
SECTION V. ATTACHMENTS
H. MAPS
The following maps are attached:
Figure 1
Figure 2
Figure 3
Figure 4
Figure 5
Figure 6
Figure 7
Figure 8
Figure 9
Figure 10
REFERENCES
Site Location/Topographic Map
Site Layout
Cross Section Trace
Geologic Cross Section A -A'
Geologic Cross Section B-B'
Shallow Groundwater TCE Isoconcentration Map — August 2006
Deep Groundwater TCE Isoconcentration Map — August 2006
Shallow Groundwater Potentiometric Surface Map — August 2006
Proposed Injection Locations
Injection Schematic
Geraghty & Miller, 1997. Comprehensive Site Assessment, May 1997.
Heath, R.C. 1980. Ground -Water Regions of the United States. United States Geological Survey
Water Supply Paper 2232.
LeGrand, H.E., Sr. 1967. Ground Water of the Piedmont and Blue Ridge Province in the
Southeastern United States. United States Geological Survey Circular 538.
12
TABLES
TABLE 1
Summary of Groundwater Analytical Data for Target Compounds
NCDOT Former Asphalt Laboratory Site #35
Rockwell, North Carolina
NCDOT WBS #36413.1.49
Well ID
Sampled bySample
p
Date
1,1,1-
TCA
1,1,2-
TCA .
1,1-
DCA
1,2-
DCA
1,1-
DCE
Chloroethane
PCE
TCE
cis-1,2-
DCE
trans-1,2
DCE
Chloroform
Vinyl
Chloride
NC 2L Standard
200
NE
70
0.38
7
2,800
0.7
2.8
70
100
70
0.015
DEEP MONITORING
WELLS
35DW-1
G&M
12/13/1996
:'430=
<100
<100
<100
.180
<100
<100
. 820
<100
<100
<100
<100
G&M
1/21/1997
s:260
<1
<1
1 :
,150J;
<1
1 °'
520
<1
<1
<1
<1
G&M
1/21/1997*
-.=370e-,
<1
<1
1
140; :
<1
; 1
660
<1
<1
<1
<1
G&M
4/3/1997
430`.
<1
<1
2
160
<1
2 `:.
780
<1
<1
<1
<1
G&M
4/3/1997*
420
<1
<1
2
150
<1
1 ,
=:750
<1
<1
<1
<1
Solutions-IES
2/21/2006
37
<0.5
1.4
<0.5
57-
<0.5
``0 77
:310,=;
3.7
<0.5
<0.5
<0.5
Solutions-IES
8/8/2006
23
<5
<5
<5
41 ':
<5
<5
310'
<5
<5
<5
<5
35DW-2
G&M
4/3/1997
18
<1
<1
<1
7t,- :
<1
<1
` 33 : „
<1
<1
<1
<1
G&M
4/16/1997
19
<1
<1
<1
°' 7° . '
<1
<1
35.: -
<1
<I
<1
<1
G&M
4/16/1997*
19
<1
<1
<1
6
<1
<1
..:-35
<1
<1
<1
<1
Solutions-IES
2/21/2006
<0.5
<0.5
1.8
<0.5
3
<0.5
<0.5
21., `
<0.5
<0.5
<0.5
<0.5
Solutions-IES
8/8/2006
1.1
<0.5
<0.5
<0.5
2
<0.5
<0.5
;-20..;°
<0.5
<0.5
<0.5
<0.5
35DW-3
G&M
4/3/1997
1
<1
<1
<1
<1
<1
<1
"" 3. "
<1
<1
<1
<1
G&M
4/16/1997
11
<1
<1
<1
3
<1
<1
; `18
<1
<1
<1
<1
Solutions-IES
2/21/2006
<0.5
<0.5
<0.5
<0.5
<0.5
<0.5
<0.5
<0.5
<0.5
<0.5
<0.5
<0.5
Solutions-IES
8/9/2006
<0.5
<0.5
<0.5
<0.5
<0.5
<0.5
<0.5
<0.5
<0.5
<0.5
<0.5
<0.5
35DW-4
G&M
4/3/1997
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
Solutions-IES
2/21/2006
<0.5
<0.5
<0.5
<0.5
<0.5
<0.5
<0.5
<0.5
<0.5
<0.5
<0.5
<0.5
Solutions-IES
8/9/2006
<0.5
<0.5
<0.5
<0.5
<0.5
<0.5
<0.5
<0.5
<0.5
<0.5
<0.5
<0.5
35DW-6
Solutions-IES
8/8/2006
<0.5
<0.5
<0.5
<0.5
<0.5
<0.5
<0.5
<0.5
<0.5
<0.5
<0.5
<0.5
35DW-7
Solutions-IES
8/8/2006
<0.5
<0.5
<0.5
<0.5
1.2
<0.5
<0.5
10
<0.5
<0.5
<0.5
<0.5
Notes:
All concentrations reported in pg/L (ppb).
NC 2L Standards are the 15A NCAC 2L.0200 groundwater standards.
Shaded concentrations exceed the NC 2L groundwater standards.
NE denotes not established.
* denotes duplicate sample.
Page 2 of 2
TABLE 1
Summary of Groundwater Analytical Data for Target Compounds
NCDOT Former Asphalt Laboratory Site #35
Rockwell, North Carolina
NCDOT WBS #36413.1.49
Well ID
Sampled by
Sample
Date
1,1,1-
TCA
1,1,2-
TCA
1,1-
DCA
1,2-
DCA
1,1-
DCE
Chloroethane
PCE
TCE
cis-1,2-
DCE
trans-1,2
DCE
Chloroform
V1nyl
Chloride
NC 2L Standard
200
NE
70
0.38
7
2,800
0.7
2.8
70
100
70
0.015
DEEP MONITORING
WELLS
35DW-1
G&M
12/13/1996
, 430
<100
<100
<100
180
<100
<100
,;; 820
<100
<100
<100
<100
G&M
1/21/1997
.260_...
<1
<1
1
150J
<1
;°1
0'_"
<1
<1
<1
<1.
G&M
1/21/1997*
370':,:
<1
<1
1 ,..
140
<1
1
•:''660
<1
<1
<1
<1
G&M
4/3/1997
430
<1
<1
2'160e,
<1`:�`2
780
<1
<1
<1
<1
G&M
4/3/1997*
420'>
<1
<1
-2 , ..
150
<1
1
'�750 > _<
<1
<1
<1
<1
Solutions-IES
2/21/2006
37
<0.5
1.4
<0.5
57 ..n
<0.5
0.77
" 310
3.7
<0.5
<0.5
<0.5
Solutions-IES
8/8/2006
23
<5
<5
<5
41,
<5
<5
':`310=
<5
<5
<5
<5
35DW-2
G&M
4/3/1997
18
<1
<1
<I
,; 7 ;.
<1
. <1
33`t
<1
<1
<1
<1
G&M
4/16/1997
19
<1
<1
<1
7 .;s
<1
<1
-35; '
<1
<1
<1
<1
G&M
4/16/1997*
19
<1
<1
<1
6
<1
<1
35,F
<1
<1
<1
<1
Solutions-IES
2/21/2006
<0.5
<0.5
1.8
<0.5
3
<0.5
<0.5
21
<0.5
<0.5
<0.5
<0.5
Solutions-IES
8/8/2006
1.1
<0.5
<0.5
<0.5
2
<0.5
<0.5
` 20
<0.5
<0.5
<0.5
<0.5
35DW-3
G&M
4/3/1997
1
<1
<1
<1
<1
<1
<1
3
<1
<1
<1
<1
G&M
4/16/1997
11
<1
<1
<1
3
<1
<1
18 `;
<1
<1
<1
<1
Solutions-IES
2/21/2006
<0.5
<0.5
<0.5
<0.5
<0.5
<0.5
<0.5
<0.5
<0.5
<0.5
<0.5
<0.5
Solutions-IES
8/9/2006
<0.5
<0.5
<0.5
<0.5
<0.5
<0.5
<0.5
<0.5
<0.5
<0.5
<0.5
<0.5
35DW-4
G&M
4/3/1997
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
Solutions-IES
2/21/2006
<0.5
<0.5
<0.5
<0.5
<0.5
<0.5
<0.5
<0.5
<0.5
<0.5
<0.5
<0.5
Solutions-IES
8/9/2006
<0.5
<0.5
<0.5
<0.5
<0.5
<0.5
<0.5
<0.5
<0.5
<0.5
<0.5
<0.5
35DW-6
Solutions-IES
8/8/2006
<0.5
<0.5
<0.5
<0.5
<0.5
<0.5
<0.5
<0.5
<0.5
<0.5
<0.5
<0.5
35DW-7
Solutions-IES
8/8/2006
<0.5
<0.5
<0.5
<0.5
1.2
<0.5
<0.5
: ` 10 .'„
<0.5
<0.5
<0.5
<0.5
Notes:
All concentrations reported in µg/L (ppb).
NC 2L Standards are the 15A NCAC 2L.0200 groundwater standards.
Shaded concentrations exceed the NC 2L groundwater standards.
NE denotes not established.
* denotes duplicate sample.
Page 2 of 2
TABLE 2
Summary of Groundwater Elevation Data
NCDOT Former Asphalt Laboratory Site #35
Rockwell, North Carolina
NCDOT WBS #36413.1.49
Monitoring
Well
Well Depth
t
(ft bgs)
Screened
Interval
(feet)
Top of Casing
Elevation
(feet)
Measurement
Date
Depth to Water
(ft BTOC)2
Groundwater
Elevation
(feet)
SHALLOW
MONITORING
WELLS
35MW-1
20
10-20
743.7
11/22/1996
14.40
729.30
4/3/1997
13.92
729.78
5/2/1997
13.57
730.13
2/21/2006
15.76
727.94
8/8/2006
16.99
726.71
35MW-2
20
10-20
744.02
11/22/1996
10.50
733.52
4/3/1997
10.32
733.70
5/2/1997
8.90
735.12
2/21/2006
11.27
732.75
8/8/2006
12.99
731.03
35MW-3
20
10-20
744.21
11/22/1996
13.60
730.61
5/2/1997
12.69
731.52
2/21/2006
14.83
729.38
8/8/2006
16.17
728.04
35MW-4
20
10-20
742.87
11/22/1996
16.42
726.45
4/3/1997
15.23
727.64
5/2/1997
15.62
727.25
2/21/2006
17.87
725.00
8/8/2006
18.87
724.00
35MW-5
20
10-20
739.97
11/22/1996
13.10
726.87
5/2/1997
12.47
727.50
8/8/2006
15.85
724.12
35MW-6
20
10-20
738.25
4/3/1997
5.36
732.89
5/2/1997
5.03
733.22
2/21/2006
7.11
731.14
8/8/2006
8.63
729.62
35MW-7
30
20-30
745.15
8/8/2006
13.98
731.17
DEEP MONITORING WELLS
35DW-1
60
50-60
743.71
11/22/1996
14.87
728.84
1/21/1997
14.55
729.16
4/3/1997
14.27
729.44
5/2/1997
14.06
729.65
2/21/2006
16.40
727.31
8/8/2006
17.53
726.18
35DW-2
100
89-99
743.93
4/3/1997
13.48
730.45
4/16/1997
15.05
728.88
5/2/1997
14.86
729.07
2/21/2006
17.23
726.70
8/8/2006
18.15
725.78
35DW-3
60
50-60
737.01
4/3/1997
8.48
728.53
4/16/1997
8.52
728.49
5/2/1997
8.20
728.81
2/21/2006
10.50
726.51
8/8/2006
11.47
725.54
35DW-4
60
48.5-58.5
742.13
4/3/1997
14.62
727.51
5/2/1997
14.47
727.66
2/21/2006
16.61
725.52
8/8/2006
17.69
724.44
35DW-6
60
50-60
742.91
8/8/2006
16.28
726.63
35DW-7
150
130-150
743.33
8/8/2006
17.55
725.78
Notes:
1. ft bgs denotes feet below ground surface.
2. ft BTOC denotes feet below top of casing.
TABLE 3
Well Construction Data
NCDOT Former Asphalt Laboratory Site #35
Rockwell, North Carolina
NCDOT WBS #36413.1.49
Monitoring
Well
Well Type
Well Depth
(ft bgs)1
Screened
Interval
(feet)
Top of Casing
Elevation
(feet)
SHALLOW WELLS
35MW-1
Monitoring
20
10-20
743.7
35MW-2
Monitoring
20
10-20
744.02
35MW-3
Monitoring
20
10-20
744.21
35MW-4
Monitoring
20
10-20
742.87
35MW-5
Monitoring
20
10-20
739.97
35MW-6
Monitoring
20
10-20
738.25
35MW-7
Monitoring
30
20-30
745.15
351W-1
Temporary
Injection
20
20-30
NA
35IW-2
Temporary
Injection
20
20-30
NA
35IW-3
Temporary
Injection
20
20-30
NA
DEEP WELLS
35DW-1
Monitoring
60
50-60
743.71
35DW-2
Monitoring
100
89-99
743.93
35DW-3
Monitoring
60
50-60
737.01
35DW-4
Monitoring
60
48.5-58.5
742.13
35DW-6
Monitoring
60
50-60
742.91
35DW-7
Monitoring
150
130-150
743.33
35IW-4
Temporary
Injection
60
50-60
NA
35IW-5
Temporary
Injection
60
50-60
NA
35IW-6
Temporary
Injection
60
50-60
NA
Notes:
1. ft bgs denotes feet below ground surface.
2. ft BTOC denotes feet below top of casing.
3. NA = not applicable.
Page 1 of 1
FIGURES
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SITE LOCATION MAP
FORMER NCDOT ASPHALT LABORATORY SITE # 35
500 INDUSTRIAL DRIVE
ROCKWELL, ROWAN COUNTY, NORTH CAROLINA
-.1•••ar
:71
.1 a
re
•
REFERENCE:
USGS 7.5 MINUTE TOPOGRAPHIC MAP-
ROCKWELL, NC, 1962, Photorevised 1987.
(DRG digital map from N.C. Geological Survey, 1997)
,
Solutions -TES
Industrial & Environmental Services
1101 Nowell Road, Raleigh, NC 27606
Phone (919) 873-1060, Fax (919) 873-1074
Created by: KBB
Checked by: CZ
File: Figure 1.mxd
Software: ESRI ArcMap 9.1
Project: 7060.08A3.NCDO
Date: JULY 2008
FIGURE
1
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W Q
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20
7
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35DW-6
35DW-1
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35DW-2
35DW-7
35MW-6
t7
35DW-4
35DW-3
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35v1 W-5
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LEGEND
35MW-5 SHALLOW MONITORING WELL
35DW-4 DEEP MONITORING WELL
0 50 100
SCALE IN FEET
sijaSolutions -IES
Industrial & Environmental Services
1101 NOWELL ROAD
RALEIGH, NORTH CAROLINA 27607
TEL.: (919) 873-1060 FAX.: (919) 873-1074
NOTES:
1) BASEMAP REFERENCE, "SITE MAP, NC DEPARTMENT OF TRANSPORTATION,
SITE NO. 35", GERAGHTY & MILLER ENVIRONMENTAL SERVICES, DATED 4/17/97.
FORMER NCDOT ASPHALT TESTING LABORATORY
SITE NO. 35
500 INDUSTRIAL DRIVE
ROCKWELL, ROWAN COUNTY, NORTH CAROLINA
SITE LAYOUT
FIGURE:
2
l
35MW-2 -
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0
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35MW-3
35DW-6
35DW-2
35DW-7
35MW-6
35DW-4
35DW-3
4)
35MW-5
1
LEGEND
35MW-5 SHALLOW MONITORING WELL
35DW-4 DEEP MONITORING WELL
A A' CROSS SECTION TRACE
0
50
100
SCALE IN FEET
11 Solutions -IES
Industrial & Environmental Services
1101 NOWELL ROAD
RALEIGH, NORTH CAROLINA 27607
TEL.: (919) 873-1060 FAX.: (919) 873-1074
NOTES:
1) BASEMAP REFERENCE, "SITE MAP, NC DEPARTMENT OF TRANSPORTATION,
SITE NO. 35", GERAGHTY & MILLER ENVIRONMENTAL SERVICES, DATED 4/17/97.
FORMER NCDOT ASPHALT TESTING LABORATORY
SITE NO. 35
500 INDUSTRIAL DRIVE
ROCKWELL, ROWAN COUNTY, NORTH CAROLINA
CROSS SECTION TRACE
FIGURE:
3
J
Cross Section.dwg
w
LL
ELEV
(ft msl)
750-
740-
730-
720-
710-
700-
690-
680-
670-
660-
650-
640-
630 —
620 —
610 —
600 —
590 —
35PMV--2
<0.5
<0.5
A A;L
rb
CL
<0
ML
35M W-7
<0.5
<0.5
SAPROLITE /
WEATHERED
BEDROCK
CL
2, A
r5 r5('D nD�
1800
240
j .
35DW-1
310
41
— ML
35DW-2
20
2
CL
35DW-7
10
1.2
A'
CL
35MMNV-4 —
<0.5 —
<0.5 —
GROUNDWATER ELEVATION
AUGUST 2006
SAPROLITE
ML
WEATHERED
BEDROCK
35DW-4
<0.5
<0.5
CL
ML
35DW-4
<0.5
<0.5
LEGEND
CLAY
SILT
SCREENED INTERVAL
MONITORING WELL ID
TCE CONCENTRATION
1,1-DCE CONCENTRATION
ESTIMATED EXTENT OF TCE
ABOVE 2L STANDARDS
60
HORIZONTAL SCALE
1"=60'
120
So1utions -TES
Industrial & Environmental Services
1101 NOWELL ROAD
RALEIGH, NORTH CAROLINA 27607
TEL.: (919) 873-1060 FAX.: (919) 873-1074
NOTES:
1. CROSS-SECTION BASED ON PREVIOUS WORK BY GERAGHTY & MILLER, INC.
2. WELL LOCATIONS ARE RELATIVE TO TRACE OF CROSS-SECTION
FORMER NCDOT ASPHALT LABORATORY
SITE #35
500 INDUSTRIAL DRIVE
ROCKWELL, ROWAN COUNTY, NORTH CAROLINA
GEOLOGIC CROSS SECTION A -A'
FIGURE:
4
1
o
W�
0
}
m 0
0
W
0
U
x
0
uJ
0
0
z
o
0
W
0
0
a
Cross Section.dwg
ELEV B *;5
(ft msl) rS°�
740-
730— —
720-
710-
700-
690-
680-
35ATN-3
<0.5
<0.5
CL
ML
SAPROLITE
WEATHERED
BEDROCK
35DW-1
310
41
rgo
rb
CL
GROUNDWATER ELEVAT
AUGUST 2006
SAPROLITE
WEATHERED
BEDROCK
3510W-6
<0.5
<0.5
35DW-3
<0.5
<0.5
B'
CL
ML
35DW-4
<0.5
<0.5
LEGEND
CLAY
SILT
SCREENED INTERVAL
MONITORING WELL ID
TCE CONCENTRATION
1,1-DCE CONCENTRATION
ESTIMATED EXTENT OF TCE
ABOVE 2L STANDARDS
HORIZONTAL SCALE
1"=60'
W
J
0
to b
J
< II
U
W
7
Solutions -IFS
Industrial & Environmental Services
1101 NOWELL ROAD
RALEIGH, NORTH CAROLINA 27607
TEL.: (919) 873-1060 FAX.: (919) 873-1074
NOTES:
1. CROSS-SECTION BASED ON PREVIOUS WORK BY GERAGHTY & MILLER, INC.
2. WELL LOCATIONS ARE RELATIVE TO TRACE OF CROSS-SECTION
FORMER NCDOT ASPHALT LABORATORY
SITE #35
500 INDUSTRIAL DRIVE
ROCKWELL, ROWAN COUNTY, NORTH CAROLINA
GEOLOGIC CROSS SECTION B-B'
FIGURE:
5
0
0
Z
W co
0.
o
z�
Z
W
0
a
CO
0
0
CO
W
0
a
L
cn
J
LL
l S.NA vR1AC
vE
35MW-7
AST
(TYPICAL)
CONCRETE BERM
35MW-3
611
35DW-6
35MW-1
35DW-1
l'l
35DW-2
35MW-6
r1
35DW-4
35DW-3
35MW-5
LEGEND
35MW-5 SHALLOW MONITORING WELL
35DW-4 DEEP MONITORING WELL
1800 TCE CONCENTRATION (ug/L)
2.8 ESTIMATED EXTENT OF TCE
ABOVE 2L STANDARD
0
50
100
SCALE IN FEET
Solutions -IES
Industrial & Environmental Sen-ices
1101 NOWELL ROAD
RALEIGH, NORTH CAROLINA 27607
TEL.: (919) 873-1060 FAX.: (919) 873-1074
NOTES:
1) BASEMAP REFERENCE, "SITE MAP, NC DEPARTMENT OF TRANSPORTATION,
SITE NO. 35", GERAGHTY & MILLER ENVIRONMENTAL SERVICES, DATED 4/17/97.
FORMER NCDOT ASPHALT TESTING LABORATORY
SITE NO. 35
500 INDUSTRIAL DRIVE
ROCKWELL, ROWAN COUNTY, NORTH CAROLINA
TCE ISOCONCENTRATION MAP
SHALLOW AQUIFER
AUGUST 2006
FIGURE:
6
l
t
m 2
w ❑
r
0
❑
>-
m❑
❑
W
V
W
2
O
m
0
0
0
W
w
J
LL
35MW-2
U A , 1OF
35MW-7
AST
(TYPICAL)
CONCRETE BERM
35DW-6
35MW-3
35MW-1
35DW-1
41
35DW-2
350W-7
35MW-6
35DW-4
35DW-3
4-
35MW-5
w
LEGEND
35 MW-5 SHALLOW MONITORING WELL
35 DW-1 DEEP MONITORING WELL
TCE CONCENTRATION (ug/L)
2.8 ESTIMATED EXTENT OF TCE
ABOVE 2L STANDARD
0
50
100
SCALE IN FEET
•
11 Solutions —TES
•
Industrial 4 Environmental Services
NOTES:
1) BASEMAP REFERENCE, "SITE MAP, NC DEPARTMENT OF TRANSPORTATION,
SITE NO. 35", GERAGHTY & MILLER ENVIRONMENTAL SERVICES, DATED 4/17/97.
FORMER NCDOT ASPHALT TESTING LABORATORY
SITE NO. 35
500 INDUSTRIAL DRIVE
ROCKWELL, ROWAN COUNTY, NORTH CAROLINA
TCE ISOCONCENTRATION MAP
DEEP AQUIFER
AUGUST 2006
FIGURE:
7
1101 NOWELL ROAD
RALEIGH, NORTH CAROLINA 27607
TEL.: (919) 873-1060 FAX.: (919) 873-1074
J
E-
LL
O
}
p
0
W
0
W
U
35MW-3
728.04
op
p
0
m
W
1-
0
35MW-4
724.00
�j 35DW-3
35MW-6
29.62
350W-4
724.12
v 1-5
724.12
LEGEND
35MW-5 SHALLOW MONITORING WELL
35DW-4 DEEP MONITORING WELL
WATER TABLE ELEVATION
728 WATER TABLE CONTOUR
IMPLIED DIRECTION OF GROUNDWATER
FLOW
0
50 100
SCALE IN FEET
FIGURE:
111 Solut•
ions -TES
Industrial & Environmental Services
1101 NOWELL ROAD
RALEIGH, NORTH CAROLINA 27607
TFi • ia14i R73-1060 FAX.: (9191 873-1074
NOTES:
1) BASEMAP REFERENCE, "SITE MAP, NC DEPARTMENT OF TRANSPORTATION,
SITE NO. 35", GERAGHTY & MILLER ENVIRONMENTAL SERVICES, DATED 4/17/97.
FORMER NCDOT ASPHALT TESTING LABORATORY
SITE NO. 35
500 INDUSTRIAL DRIVE
ROCKWELL, ROWAN COUNTY, NORTH CAROLINA
POTENTIOMETRIC SURFACE MAP
SHALLOW AQUIFER
AUGUST 2006
0
U
mo
2D co
Z
cc
W
a.
>-
m0
0'
W
0
W
0
0
CD
0
co
W
0
a
LL
4-
35MW-3
Solutions -IES
Industrial & Environmental Services
1101 NOWELL ROAD
RALEIGH, NORTH CAROLINA 27607
TEL.: (919) 873-1060 FAX.: (919) 873-1074
35DW-6
APPROXIMATE LOCATION OF
FORMER ASPHALT LAB
35MW-1
NOTES:
1) BASEMAP REFERENCE, "SITE MAP, NC DEPARTMENT OF TRANSPORTATION,
SITE NO. 35", GERAGHTY & MILLER ENVIRONMENTAL SERVICES, DATED 4/17/97.
35DW-2
r1
LEGEND
PROPOSED DEEP INJECTION WELL
PROPOSED SHALLOW INJECTION WELL
35MW-5 SHALLOW MONITORING WELL
35DW-4 DEEP MONITORING WELL
35MW-4
0
20
40
SCALE IN FEET
35DW-7
FORMER NCDOT ASPHALT TESTING LABORATORY
SITE NO. 35
500 INDUSTRIAL DRIVE
ROCKWELL, ROWAN COUNTY, NORTH CAROLINA
PROPOSED INJECTION
WELL LOCATIONS
FIGURE:
9
1
0
0
0
Z
W Q
0
CO p
2 o
Z
0
w
O
0
W
m 2
o -3
w
0
U
W
0
w
w
0
z
0
w
0
0
0
w
w
m
2
co
W
w
w
0
FIGURE 10.pdf
HYDRANT
EMULSION DILUTION
BACKFLOW
PREVENTER
NOTE:
FOR WATER CHASE LINE, INLINE DILUTER IS REMOVED
& REPLACED WITH BLANK PIPE SECTION
® E►
INUNE
DILUTER
DOSATRON®
OR
EQUIIVALENT
A
EOS®
CONCENTRATE
EMULSION INJECTION
INJECTION LINE
TEMPORARY
INJECTION WELL
® ® TO ADDITIONAL
® 0 0 INJECTION WELLS
ua ► ra ua
BENTONITE SEAL
WELL SCREEN
m
EOS®INJECTION SEQUENCE DEPENDS ON
SITE CONDITIONS
LEGEND
PRESSURE GAGE
FLOW METER
VALVE - GATE
VALVE - BALL
QUICK -CONNECT UNION
AIR RELEASE VALVE
0
—}
1So1utions -JES
lnc�n tri.11& kn.ircinnlrntal 5rrvicrs
1101 NOWELL ROAD
RALEIGH, NORTH CAROLINA 27607
TEL.: (919) 873-1060 FAX (919) 873-1074
FORMER NCDOT ASPHALT TESTING LABORATORY
SITE #35
500 INDUSTRIAL DRIVE
ROCKWELL. ROWAN COUNTY. NORTH CAROLINA
INJECTION SCHEMATIC
FIGURE:
10
7
APPENDIX A
EOS®MSDS
MATERIAL SAFETY DATA SHEET
EMULSIFIED EDIBLE OIL SUBSTRATE
D.O.T. HAZARD CLASSIFICATION: NONE
MANUFACTURER'S NAME
EOS Remediation, LLC
1101 Nowell Road
Raleigh, NC 27607
www.EOSRemediation.com
DATE OF PREPARATION
01-24-03, Rev. 04-19-05
HEALTH
FLAMMABILITY
REACTIVITY
PERSONAL PROTECTION
INFORMATION TELEPHONE NO.
919-873-2204
SECTION I - PRODUCT IDENTIFICATION
PRODUCT NAME
PRODUCT CLASS
CAS NUMBER
EOS®CONCENTRATE 598B42
VEGETABLE OIL BASED EMULSION
MIXTURE
SECTION II - HAZARDOUS INGREDIENTS
COMPONENT(S)
EXPOSURE LIMIT
THIS PRODUCT IS A MIXTURE OF EDIBLE FOOD GRADE ADDITIVES AND CONTAINS NO
HAZARDOUS INGREDIENTS.
SECTION III - PHYSICAL DATA
BOILING POINT:
SPECIFIC GRAVITY:
VAPOR PRESSURE:
PERCENT VOLATILE BY VOLUME (%):
VAPOR DENSITY:
EVAPORATION RATE:
SOLUBILITY IN WATER:
APPEARANCE AND ODOR:
212°F
0.97; .92 (pure oil phase)
NOT ESTABLISHED
24 (AS WATER)
HEAVIER THAN AIR
NOT ESTABLISHED
SOLUBLE
OFF WHITE LIQUID WITH VEGETABLE OIL ODOR
EMULSIFIED EDIBLE OIL SUBSTRATE
SECTION IV - FIRE AND EXPLOSION HAZARD DATA
FLASH POINT:
FLAMMABLE LIMITS:
EXTINGUISHING MEDIA:
UNUSUAL FIRE AND
EXPLOSION HAZARDS:
SPECIAL FIRE FIGHTING
PROCEDURES:
>300°F
NOT ESTABLISHED
CO2, FOAM, DRY CHEMICAL
NOTE: WATER, FOG, AND FOAM MAY CAUSE
FROTHING AND SPATTERING.
BURNING WILL CAUSE OXIDES OF CARBON.
WEAR SELF CONTAINED BREATHING APPARATUS
AND CHEMICAL RESISTANT CLOTHING. USE WATER
SPRAY TO COOL FIRE EXPOSED CONTAINERS.
SECTION V - PHYSICAL HAZARDS
STABILITY:
CONDITIONS TO AVOID:
STABLE
NONE
INCOMPATIBILITY: STRONG ACIDS AND OXIDIZERS.
HAZARDOUS DECOMPOSITION THERMAL DECOMPOSITION MAY PRODUCE OXIDES
PRODUCTS: OF CARBON.
HAZARDOUS POLYMERIZATION: WILL NOT OCCUR
SECTION VI - HEALTH HAZARDS
SIGNS AND SYMPTOMS OF EXPOSURE:
1. Acute Overexposure - NONE
2. Chronic Overexposure - NONE
MEDICAL CONDITIONS GENERALLY NONE KNOWN
AGGRAVATED BY EXPOSURE:
CHEMICAL LISTED AS CARCINOGEN OR POTENTIAL CARCINOGEN:
N.T.P. - NO I.A.R.C. - NO OSHA- NO
EMERGENCY AND
1.) Inhalation-
2.) Eyes-
3.) Skin-
4.) Ingestion -
FIRST AID PROCEDURES:
REMOVE TO FRESH AIR.
FLUSH WITH WATER FOR 15 MINUTES, IF IRRITATION PERSISTS
SEE PHYSICIAN.
WASH WITH MILD SOAP AND WATER.
PRODUCT IS NON -TOXIC. IF NAUSEA OCCURS, INDUCE VOMITING
AND SEEK MEDICAL ATTENTION.
4
EMULSIFIED EDIBLE OIL SUBSTRATE
SECTION VII - SPECIAL PROTECTION INFORMATION
RESPIRATORY PROTECTION:
VENTILATION:
PROTECTIVE GLOVES:
EYE PROTECTION:
OTHER PROTECTIVE CLOTHING
OR EQUIPMENT:
NOT NORMALLY REQUIRED
LOCAL EXHAUST
NOT NORMALLY REQUIRED
NOT NORMALLY REQUIRED
NONE
SECTION VIII - SPECIAL PRECAUTIONS AND SPILL/LEAK PROCEDURES
PRECAUTIONS TO BE TAKEN
IN HANDLING AND STORAGE:
OTHER PRECAUTIONS:
STEPS TO BE TAKEN IN CASE
MATERIAL IS SPILLED:
WASTE DISPOSAL METHODS:
DO NOT STORE NEAR EXCESSIVE HEAT OR
OXIDIZERS.
NONE
SOAK UP WITH DRY ABSORBENT AND FLUSH AREA
WITH LARGE AMOUNTS OF WATER.
DISPOSE OF ACCORDING TO FEDERAL, STATE, AND
LOCAL REGULATIONS.
SECTION IX - ADDITIONAL REGULATORY INFORMATION
SARA TITLE III
UNDER THE PROVISIONS OF TITLE 111, SECTION 311/312 OF THE SUPERFUND
AMENDMENTS AND REAUTHORIZATIONS ACT, THIS PRODUCT IS CLASSIFIED
INTO THE FOLLOWING HAZARD CATEGORIES: NONE
THIS PRODUCT DOES NOT CONTAIN SECTION 313 REPORTABLE INGREDIENTS.
THE INFORMATION CONTAINED HEREIN IS BASED ON AVAILABLE DATA AND IS BELIEVED TO BE
CORRECT. HOWEVER, EOS REMEDIATION, INC. MAKES NO WARRANTY, EXPRESSED OR IMPLIED,
REGARDING THE ACCURACY OF THIS DATA OR THE RESULTS TO BE OBTAINED THEREOF. THIS
INFORMATION AND PRODUCT ARE FURNISHED ON THE CONDITION THAT THE PERSON RECEIVING
THEM SHALL MAKE HIS/HER OWN DETERMINATION AS TO THE SUITABILITY OF THE PRODUCT FOR
HIS/HER PARTICULAR PURPOSE.