WI0600067_Permit (Issuance)_20110201

DIVISION OF WATER QUALITY
AQUIFER PROTECTION SECTION
February 1, 2011
PERMIT ISSUANCE MEMO
TO: Debra Watts
THROUGH: Thomas Slusser Z/
FROM: David Goodrich
RE: Permit To Inject Emulsified Vegetable Oil (EVO) with additives
Former Eaton Corporation Facility
I recommend that Permit Number WI0600067 be issued to Eaton Corporation to inject Emulsified Vegetable Oil
to remediate soils and groundwater contaminated with chlorinated ethanes and volatile organics.
SITE DESCRIPTION The site is the location of the former Eaton Corporation — Golf Grip Division
manufacturing facility, shut down in 2008. Multiple source areas have been identified, including a product line
failure from an above ground storage tank that took place in 1988. Earlier remediation efforts have consisted of
extraction wells and free product recovery operations with eight extraction wells and five sparging wells. The
property is currently being used by Nature's Earth to produce pelletized wood fuel for residential wood/pellet
burning stoves. This is a flat industrialized area with no residential structures located within 1,000 feet of the
site. There are two other industrial properties within one-half mile of the site that are also undergoing
groundwater remediation.
HYDROGEOLOGIC DESCRIPTION The site is situated at the western edge of the Atlantic Coastal Plain
physiographic province, underlain by the Cretaceous Middendorf Formation. The suficial materials consist of
fine to medium sand in a clay matrix to a depth of approximately 30 feet. Drilling at the site has shown the
stratigraphy to be composed of sands and sandy clays with some laterally discontinuous clay lenses. Bedrock
was not encountered in any of the site borings, but it is expected to be at an average depth of approximately 30
feet. The typical depth to water has been 5 to 11 feet below the surface of the ground. The average hydraulic
gradient appears to be 5.7 to 9.6 x 10-3 ft/ft, with a calculated shallow groundwater flow velocity of 1.3 to 2.1
feet per day.
EXTENT OF CONTAMINATION Several contaminants are present, as shown on Figures 4, 5 & 6, and
each contaminant has its own plume. The overall composite impact area measures approximately 600 feet in
length (measured along a southeast -northwest axis) and 300 feet in width (measured along a southwest -northeast
axis), with an estimated vertical extent of 20 to 25 feet (depth of the surficial aquifer). The composite impact
area extends from US Highway 401 (southeast edge of impact area) to beyond the western track of the railroad
track triangle (northwest edge of impact area), and from the asphalt parking area on the southwestern side of the
facility to the Cone Ramp at the northeast comer of the facility.
PROPOSED INJECTION The injectant is commercially known as Newman Zone Standard Emulsified
Vegetable Oil (EVO), composed of soybean oil, sodium lactate, emulsification additives and preservatives. Five
permanent injection/monitoring wells will be installed to inject the injectant through. There will be a single
injection event consisting of 840 gallons per well that will require approximately one week to complete. The
specific yield of the affected shallow aquifer was determined by field testing to be approximately 8.6 x 10-3.
Assuming a resulting effective porosity of approximately 1 x 10-2, the total injectant volume of 4,200 gallons
should occupy an aquifer volume of 56,150 cubic feet, or an area of approximately 2,800 square feet (assuming
a saturated thickness of 20 feet). The total composite aquifer volume impacted by the contaminants is estimated
to be approximately 3.6 million cubic feet.

HOW IT WORKS The Emulsified Vegetable Oil and Emulsification Additives are intended to perform a
reductive dehalogenation (dechlorination) of the halogenated organic compounds, reducing them to daughter
products. The injectant also contains ionic and nonionic surfactants that produce a very stable emulsion that
resists movement.
MONITORING As proposed by the applicant, post -injection monitoring will be performed in June of
2011, and in June and December thereafter, at Monitoring Wells OW-3, OW-7, OW-10, OW-11, OW-12, OW-
14, OW-22, OW-24, OW-25, OW-26, OW-27, OW-29, OW-30, OW-31V, OW-32, OW-33, OW-34, OW-35,
and OW-36V for VOCs by Method 8260, dissolved gases (ethane, ethane and methane) by Method RSK-75,
and for pH, Dissolved Oxygen, temperature, ORP, conductivity, Nitrate, Sulfate, Sulfide, Alkalinity, Chloride,
Dissolved Iron, and Dissolved Manganese.
EPIDEMIOLOGY On October 7, 2004, the DHHS' Epidemiology Branch provided comments on Newman
Zone for groundwater remediation. Dr. Luanne K. Williams did not present any information that would
preclude the use of these products for injection, but did provide a health risk analysis and worker safety
precautions, which are in Part X of the attached permit.
REGIONAL OFFICE COMMENTS Jim Barber of the Fayetteville Regional Office recommended issuance of this
permit. The Regional Office Staff recommends that a copy of this permit be furnished to the DWM's Inactive
Sites Branch — REC Program — Superfund Section.

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
Eaton Corporation
FOR THE CONSTRUCTION AND OPERATION OF FIVE (5) TYPE 5I INJECTION WELLS,
defined in Title 15A North Carolina Administrative Code 2C .0209(e)(3)(C), to inject Newman
Zone Standard — Emulsified Vegetable Oil (EVO), for the reductive dehalogenation of
halogenated organic compounds, which are industrial solvents consisting of chlorinated ethanes
and volatile organic compounds. These injection wells/points will be located at the former Eaton
Corporation Golf Pride Golf Grip Division facility, located at 16900 Aberdeen Road,
Laurinburg, in Scotland County, North Carolina, and will be operated in accordance with the
application submitted December 8, 2010, and in conformity with the specifications and
supporting data submitted January 7, 2011, 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
.01.00 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 3,
2013, and shall be subject to the specified conditions and limitations set forth in Parts I through
X hereof.
Permit issued this the third day of February. 2011.
ebt_ s
,k/kColeen H. Sullins, Director
Division of Water Quality
By Authority of the Environmental Management Commission.
Permit No. Vv I0600067 PAGE 1 OF 6
ver. Oct.2010 AP/U1C-6

ti
PART I - WELL CONS I i JCTION GENERAL CONDITION,
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 Program
DENR-Division of Water Quality
1636 Mail Service Center
Raleigh, NC 27699-1636
PART II - WELL CONSTRUCTION SPECIAL CONDITIONS
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 Fayetteville Regional Office Aquifer Protection
Section Staff, telephone number [phone].
Permit No. WI0600067 PAGE 2 OF 6
ver. Oct.2010 ' AP/UIC-6

PART III - OPERATION-ar D USE GENERAL CONDITION:;'-=
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 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. WI0600067 PAGE 3 OF 6
ver. Oct 2010 AP/UIC-6

PART VI - INSPECTIOwS
1. Any duly authorized officer, employee, or representative of the Division of Water Quality
may, upon presentation of credentials, enter and inspect any property, premises, or place on
or related to the injection facility at any reasonable time for the purpose of determining
compliance with this permit, may inspect or copy any records that must be maintained under
the terms and conditions of this permit, and may obtain samples of groundwater, surface
water, or injection fluids.
2. Department representatives shall have reasonable access for purposes of inspection,
observation, and sampling associated with injection and any related facilities as provided for
in N.C.G.S. 87-90:
3. Provisions shall be made for collecting any necessary and appropriate samples associated
with the injection facility activities.
PART VII - MONITORING AND REPORTING REQUIREMENTS
1. The proposed monitoring plan included in the application shall be followed. All sample
results shall be submitted to the Aquifer Protection Section's Fayetteville 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 ensure surface and
ground water protection, will be established and an acceptable sampling reporting schedule
shall be followed.
2. The Permittee shall submit an Injection Event Record within 30 days of completing each
injection.
3. The Permittee shall produce a final project evaluation within 9 months after completing all
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 samplingdata, contaminant plume maps and potentiometric surface
maps.
4. The monitoring results and the final project evaluation shall be submitted to:
and to:
Aquifer Protection Section-UIC Program
DENR-Division of Water Quality
1636 Mail Service Center
Raleigh, NC 27699-1636
Aquifer Protection Section
DENR-DWQ Fayetteville Regional Office
225 Green Street, Suite 714 / Systel Building
Fayetteville, NC 28301-5043
Permit No. WI0600067 PAGE 4 OF 6
ver. Oct.2010 AP/UIC-6

5. The Permittee shall report by telephone, within 48 hours of the occ rrence or first knowledge
of the occurrence, to the Fayetteville 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.
6. 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.
7. 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
according to 15A NCAC 2C .0214, 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 .0214, 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
Permit No. WI0600067 PAGE 5 OF 6
ver. Oct.2010 AP/U1C-6

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 Program
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:
eye, skin, nose, throat, and lung irritation. If the product is released into the environment in a
way that could result in a suspension of fine solid or liquid particles (e.g., grinding, blending,
vigorous shaking or mixing), then proper personal protective equipment.should be used. The
application process should be reviewed by an industrial hygienist to ensure that the most
appropriate personal protective equipment is used.
2. Persons working with these products should wear goggles or a face shield, gloves, and
protective clothing. Face and body protection should be used for anticipated splashes or
sprays.
3. Eating, drinking, smoking, handling contact lenses, and applying cosmetics should not be
permitted in the application area during or immediately following application.
4. Safety controls should be in place to ensure that the check valve and the pressure delivery
systems are working properly.
5. The Material Safety Data Sheets should be followed to prevent incompatible or adverse
reactions and injuries.
Permit No. WI0600067 PAGE 6 OF 6
ver. Oct.2010 AP/UIC-6

Coastal SW Rule
Permitted Flow
Facility
Permit Number WI0600067
Central Files: APS_ SWP_
01/27/11
Permit Tracking Slip
Program Category
Ground Water
Status Project Type
In review New Project
Permit Type Version Permit Classification
Injection In situ Groundwater Remediation Well (51) Individual
Primary Reviewer Permit Contact Affiliation
david.goodrich Michael T. Stanforth
625 Huntsman Ct
Gastonia
NC 28054
Facility Name
Former Eaton Corporation - Golf Grip Division
Location Address
16900 Aberdeen Rd
Laurinburg
Owner
Major/Minor Region
Minor Fayetteville
County
Scotland
NC 28352 Facility Contact Affiliation
Owner Name Owner Type
Eaton Corporation Non-Govemment
Owner Affiliation
Jeffery Allen
111 Superior Ave
Cleveland
Dates/Events
Orig Issue
App Received Draft Initiated
12/08/10
Scheduled
Issuance
OH 44114
Public Notice Issue Effective Expiration
Regulated Activities Reauested/Received Events
Groundwater monitoring RO staff report requested 01/06/11
Groundwater remediation Additional information requested 01/06/11
Additional information received 01/07/11
RO staff report received 01/26/11
Outfall NULL
Waterbody Name Stream Index Number Current Class Subbasin